Staff Reports
WC Monitor
12/4/2015
The Department of Energy is preparing a fourth draft of the remedial investigation/feasibility study (RI/FS) for a new CERCLA landfill in Oak Ridge, which underscores the number of issues raised by environmental regulators and the continuing differences about the project, which DOE deems critical to finishing the environmental cleanup campaign from former defense nuclear operations in the area.
Mike Koentop, executive officer of DOE’s Environmental Management Office in Oak Ridge, said the agency wasn’t surprised by the Tennessee Department of Environment and Conservation’s tough position on a number of landfill issues or the growing controversy among local entities, such as the city of Oak Ridge – which recently submitted unsolicited comments on the project to DOE and environmental regulators.
“I wouldn’t say we’ve been surprised,” Koentop said. “People are interested in the topic and making sure we’re looking at everything we’re supposed to. It’s part of the process.”
TDEC has insisted the Department of Energy consider other potential sites for the landfill on the government’s Oak Ridge reservation. DOE’s preferred site is adjacent to the Environmental Management Waste Management Facility (EMWF), which has received radioactive and hazardous wastes from cleanup projects at Oak Ridge and a couple local Superfund sites since 2002 and is nearing capacity. The proposed site to the east of EMWF is only 650 yards from the boundary with the city of Oak Ridge.
“We are continuing to work with the DOE and EPA on this issue and taking the matter very seriously,” Kelly Brockman, TDEC communications chief, said in an email response to questions.
In an 80-page response to DOE’s third draft of the feasibility plan for the site, TDEC raised numerous objections about the landfill plans, including the proposed location “over steep slopes” and a shallow water table. The state is also concerned about DOE’s desire to dispose of significant quantities of mercury waste at the site, and that may become a crux issue.
According to the state’s Aug. 6 response, DOE wants TDEC and the Environmental Protection Agency to waive some aspects of federal rules to allow the disposal of mercury in the new landfill.
DOE has repeatedly said that opening a new landfill on the Oak Ridge reservation – rather than shipping the wastes to commercial disposal sites — would save taxpayers hundreds of millions of dollars and reduce transportation-related risks.
David Adler of DOE’s EM Office in Oak Ridge confirmed the department is looking at two other possible sites for the landfill on the federal reservation. He also acknowledged that DOE wants the proposed landfill – to be known as the Environmental Management Disposal Facility – to receive large volumes of waste with mercury that will be generated during cleanup and demolition activities at the Y-12 nuclear weapons plant. Y-12 lost tons of mercury to the environment during Cold War operations in the 1950s and ‘60s, and much more still cannot be accounted for.
“Mercury is a key focus of the cleanup program at Y-12,” Adler stated.
He said DOE plans to treat mercury-containing wastes with some form of “macro-encapsulation” to help reduce the possibility of mercury leaking into the environment at the landfill far into the future. But TDEC expressed concerns about mercury and appeared reluctant to grant any waivers to meet the standards for land disposal. “Since mercury does not degrade over time, it presents a long-term hazard similar to that of long-lived radionuclides, and its disposal in unlimited amounts … raises similar concerns relative to the limitations presented by the (landfill) location and viability of the proposed engineered controls over the course of hundreds and thousands of years.”
The existing Environmental Management Waste Management Facility is expected to run out of room around 2020 or perhaps the early 2020s if the redesign of the landfill cap adds space as currently anticipated. DOE has said it wants to have the new landfill operational about 18 to 24 months before the existing site is closed. The lifetime cost of the proposed Oak Ridge landfill, according to DOE estimates, is about $817 million. That includes a 25 percent contingency, the agency has said.
Koentop said the initial investment would be about $90 million to construct the landfill’s infrastructure and the first two disposal cells. The planned capacity would be six cells, with each pair of cells to cost about $30 million after the initial construction. The yearly operating cost is estimated to be about $20 million, he said.
