ML22071A003

DOE-OR-01-2676 K-31 Title Transfer Document (EIS Reference for Kairos Hermes CP Application)

ML22071A003
Person / Time
Site:	Hermes
Issue date:	09/12/2015
From:	US Dept of Energy (DOE)
To:	Office of Nuclear Material Safety and Safeguards
Dozier C
References
DOE/OR/01-2676
Download: ML22071A003 (174)

Text

DOE/OR/01-2676 COVENANT DEFERRAL REQUEST FOR THE PROPOSED TITLE TRANSFER OF THE FORMER K-31 AREA AT THE EAST TENNESSEE TECHNOLOGY PARK, OAK RIDGE, TENNESSEE FINAL-CONCURRED September 2015 This document is approved for public release per review by:

ETTP Classification and Information Date Control Office

Regulator Approvals

APPROVAL OF COVENANT DEFERRAL REQUEST The United States Department of Energy {DOE) has requested that the U.S.

Environmental Protection Agency (EPA) approve DOE's request to defer the deed covenant required by Section 120(h)(3){A)(ii)(I) of the Comprehensive Environmental Response, Compensation, and Liability Act {CERCLA). DOE maintains that this approval will facilitate DOE's transfer ofreal property on the Oak Ridge Reservation (ORR) National Priorities List Site before it has been determined that all necessary remedial action has been taken at this parcel.

DOE has designated this property, which is located at ORR's East Tennessee Technology Park (ETTP) area, as the Former K-31 Area {or the Property). The Property contains a total of 61 acres, more or less, and is located in the western portion of the ETTP Heritage Center. The Property comprises a portion of the Zone 2 Soil Record of Decision {ROD) that has been divided into a set of Exposure Units {EUs). The transfer footprint is located on five EUs and comprises the entire area of some EUs and a portion of others. The Former K-31 Area occupies three Zone 2 ROD EUs in their entirety {Z2 approximately 25.6 acres, Z2 approximately 10.9 acres, and Z2-IO - approximately 20.9 acres); and a portion of two EUs where the balance of these EUs were addressed under the K-33 CDR {Z2 approximately 1.6 acres and Z2 approximately 1.6 acres).

Based on the attached Findings, and in the exercise of authority granted to EPA under CERCLA Section 120(h)(3){C) to approve the deferral of this covenant upon determining that the Property is suitable for transfer prior to completion of all necessary remedial action, I have so determined and I hereby APPROVE this request. This approval is expressly contingent upon the transfer proceeding to a final recorded Deed as presented to EPA in the CDR, Environmental Baseline Survey and draft Deed, including the Response Action Assurances, the characterization of contamination on the Property, the extent and definition of the Property, the intended use of the Property, and Public Notice and opportunity for comment as required. Any change to the underlying contingencies will effect a revocation of this approval.

In accordance with CERCLA Section 120(h){3)(C), the covenant may not be deferred unless and until the Governor of Tennessee, or his delegatee, has concurred in this deferral.

Director, Superfund Division EPA Region4

FINDINGS OF THE DIRECTOR, SUPERFUND DIVISION, EPA REGION 4, REGARDING EARLY TRANSFER BY THE UNITED STATES DEPARTMENT OF ENERGY OF LAND PARCEL K-31 AT EAST TENNESSEE TECHNOLOGY PARK, OAK RIDGE, TENNESSEE Whenever the federal government transfers real property to another person or entity, Section 120(h)(3)(A)(ii)(I) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) requires the landholding federal agency to include in its deed of transfer a covenant warranting that "all remedial action necessary to protect human health and the environment ... has been taken before the date of such transfer ...".However, CERCLA Section 120(h)(3)(C) authorizes such transfer without this covenant under a statutorily defined process. For federal real property on the National Priorities List (NPL), this section authorizes the Administrator of the U.S. Environmental Protection Agency (EPA), with the concurrence of the Governor, or his delegatee, of the State in which the NPL facility is located, to defer this covenant upon determining that the property is suitable for transfer prior to completion of all necessary remedial action. The Administrator's authority to defer the covenant has been delegated to the Regional Administrator of EPA Region 4, which has been further delegated in this Region to the Director of the Superfund Division.

In April 2015, the United States Department of Energy (DOE) submitted to EPA and the State of Tennessee a Draft Covenant Deferral Request (CDR) covering a parcel of property within the East Tennessee Technology Park (ETTP) area ofDOE's Oak Ridge Reservation NPL site, Oak Ridge, Tennessee. The property, which DOE has designated as Land Parcel K-31 (Parcel K-31 or the Property), is located in the northwestern portion of the ETTP Heritage Center, within the City of Oak Ridge in Roane County and consists of 61 acres, more or less.

The Property is located inside the "main plant" area. The K-31 Building, the K-761 Switch House and the K-903 Pad will be demolished before the underlying land is transferred.

Confirmatory sampling will be conducted post-demolition and the results will be documented and submitted to the EPA and TDEC for review and approval as an addendum to the appropriate Phased Construction Completion Report (PCCR). If contamination is found beneath the demolished buildings above the response level, response actions consistent with the Zone 2 Record of Decision would be undertaken. These actions will be milestoned in FFA Appendix E and/or J if the response action requires further planning.

DOE proposes to transfer the Property to an as yet undisclosed transferee prior to making a final determination as to whether all necessary remedial action has been taken at Parcel K-31.

The Property has been identified by DOE as a potential site for new facilities to be used for office space, industrial activities, or other commercial uses, also described by DOE as a brownfield mixed-use commercial and industrial park.

I have reviewed the particulars of DOE's proposed transfer of Parcel K-31, described and depicted in CDR Attachment A. Based on consideration of this and other information received from DOE in its Final For Regulator Concurrence CDR (July 2015), I hereby make the following findings, in accordance with CERCLA Section 120(h)(3)(C):

1. The Property is suitable for transfer for the use intended by the transferee, and the intended use is consistent with protection of human health and the environment. Information regarding the nature and extent of contamination and the results of a risk evaluation presented in its Environmental Baseline Survey Report (CDR Attachment A) supports the conclusion that the intended use of the Property for office, commercial, or industrial activities would not cause unacceptable exposures to adults engaged in those activities or be otherwise inconsistent with protection of human health and the environment.

EPA Guidance 1 presumes that the CDR includes the results of a completed Remedial Investigation and Risk Assessment. The Guidance allows for the transferring federal agency to demonstrate why a completed Remedial Investigation or Risk Assessment is not necessary before the land is transferred. In this instance, the DOE Environmental Management (EM) program has completed a Remed ial Investigation and Risk Assessment for soils but has not completed a Remedial Investigation or Risk Assessment for groundwater, including the vapor intrusion pathway. The risk evaluation using all available data for the Exposure Units (EUs) that comprise the K-31 transfer footprint is summarized in Section 4 of the Final CDR (DOE/OR/01-2676). The risk evaluation indicates that there are no unacceptable risks associated with using the Property in the office/commercial/industrial manner proposed and wBl be restricted in the transfer documentation (deed).

The DOE has divided approximately 1,400 acres at ETTP into 80 exposure units (EUs) under the Zone I Interim ROD for purposes of evaluating risk and making remedial decisions.

The remedial decisions address soil and subsurface structures to a depth of 10 feet, buried waste and sources of groundwater contamination. Zone 2 of ETTP, consisting of approximately 800 acres, has been divided into 44 EUs for purposes of evaluating risk and making remedial decisions under the Zone 2 Interim ROD. The Property is located with Zone 2.

DOE completed three Phased Construction Completion Reports (PCCRs) to address any soil contamination in areas of ETTP that include the Property, which is located on all or parts of Exposure Units (EUs) Z2-03, Z2-05, Z2-06, Z2-07 and Z2-10. The PCCRs for these EUs documented the remedial actions conducted for these EUs concluded that no further remedial actions, with respect to soils, were needed in addition to the institutional controls within the area of all seven EUs. The PCCRs and supporting documentation evaluated the environmental data for the Property, evaluated the potential risk to industrial receptors, and described the remedial actions (RAs) completed within the boundaries of the Property. The PCCRs provide some of the foundational information to support transfer. EPA concurs with the conclusions in those documents, and has approved the PCCRs. The Final Record of Decision for ETTP (Sitewide ROD) will finalize all remedial actions for groundwater (including vapor intrusion), surface water, sediment within the Property, which must be evaluated and any necessary remediation taken before the covenant that all remedial action has been taken may be given by DOE. Based on the above PCCR documents, however, soil samples indicate that no contaminants are present at levels above a level protective for the uses planned for the Property.

The groundwater investigation has begun and the nature and extent of groundwater 1

EPA Guidance 011 the Transfer of Federal Property by Deed Before All Necessary Remedial Action Has Been Taken P11rs11a111 to CERCLA Section 120('1)(3) - (Early Transfer Authority Guidance), June 16, 1998.

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contamination will be addressed in the Final Sitewide RI/FS, and submitted to EPA for its review and approval.

Current evidence indicates that a vapor intrusion exposure pathway is unlikely at the Property. While currently present on the site, the K-31 Building, the K-761 Switch House and the K-903 Pad will not be transferred at K-31 because DOE intends to demolish these buildings prior to transfer. Additionally, soil vapor samples have been taken from approximately 95 sample locations across ETIP. Based on these soil vapor sample results and the results of the soil and groundwater investigations to date, a complete vapor intrusion pathway has not been identified for any of the buildings that have been sampled at ETTP. Although the available data suggest the general absence ofVOCs in the groundwater beneath the study area, as summarized by the DOE Environmental Baseline survey, there is uncertainty concerning the groundwater flow paths due to the karst conditions in the bedrock underlying the K-31 area. Due to available information and this uncertainty, deed language will ensure that necessary measures will be taken to ensure protectiveness in any future building construction.

EPA Region 4 has provided guidance to DOE on evaluation of the vapor intrusion pathway (Proposed Modifications to the Evaluation of the Vapor Intrusion Pathway in Support ofProperty Transfers at the East Tennessee Technology Park (E1TP), January 6, 2006, Oak Ridge, Tennessee," EPA 2006). Consistent with this guidance, no sampling was determined to be necessary at the Property because DOE has agreed that the Quitclaim Deed for the property will include, as determined by the Grantor (DOE) and the Grantee, the necessary building design features to minimize this potential exposure. After the public comment period on the CDR, EPA finalized guidance on the evaluation of vapor intrusion, OSWER 9200.2-154, OSWER Technical Guide for Assessing and Mitigating the Vapor lntntsion Pathway for Subsurface Vapor Sources to Indoor Air, July 2015. In addition to the above deed requirement, any unacceptable risks due to vapor intrusion will be addressed in the Sitewide ROD and will be consistent with the July 2015 EPA guidance.

2. The Deed proposed to govern the transfer between DOE and the transferee of the Property contains the Response Action Assurances required by CERCLA Section 120(h)(3)(C)(ii). DOE has agreed that the draft Deed will, as to the Response Action Assurances and other substantive provisions relevant to the suitability of this specific parcel for transfer, be finalized and recorded as presented to EPA in its draft form.

(a) The draft Deed, which, when finalized, will effect transfer of the Property, contains all use restrictions necessary to ensure protection of human health and the environment, as set out below. Consistent with DOE's prior determination that use of the entire ETIP area should be limited to industrial activities both before and after all ETIP remediation has been completed, the draft Deed contains land use restrictions prohibiting, by means of covenants by the Grantee: i) use or disturbance of any portion of the Property located more than 10 feet below ground surface level without having first obtained authorization from DO E's Excavation/Penetration Permit Program; ii) use of any portion of the Property for residential housing, any elementary or secondary school, or any child care facility or children's playground; and iii) any use .of groundwater underlying the Property without prior written approval of DOE, EPA, and TDEC. Further, the Grantee covenants 3

and agrees that buildings w 11 be des* gned and constructed to minimize exposure to volatile organic compounds, consistent with EPA guidance. 2 All of the Deed s and use restnctions and covenants will express y bind the initial transferee and every successor transferee, and "run wit the land." In addition, the Deed will operate as a Notice of Land Use Restrictions, T.C.A. §68-212-225 enforceable by the TDEC Commiss10 er or any unit of local government hav'ngjurisdiction over the Property.

(b) The draft Deed provides that there will be restrictions on use necess ry to ensure that the required remedial investigations, response act on and oversight activities will not be disrupted. Restrictive covenants ensuring this are agreed to by and binding upon the Grantee and all its successors and assigns.

(c) The draft Deed provides that all necessary response action will be aken and identifies the schedule for investigation and completion of a 1necessary respo se action as approved by the EPA under the Federal Fae lity Agreement (FFA), subject to modification through processes under the FFA. These processes for schedule modification include approval by EPA or resolution through the dispute resolution process. The current schedule establishes that t e completion of Zone 2 remedial actions 1s scheduled to occur in 2026, and the Sitew de Groundwater OU (including the soil vapor pathway) Record of Decision wi 1 be subm tted fo EPA review in 2023. Tha Record of Decision will estabhsh the timeframe for the groundwater action to meet its remedial action objectives.

(d) The Deed prov des that DOE w'l submit annual budget requests to the Office of Managemen and Budget that adequately address schedules for mvestigation and completion of remediation of the Property, subject to congressional authoriza ion and app opriations.

3. DOE provided pu lie notice of the proposed transfer and opportunity for written comment. as required by CERCLA Section 120(h)(3)(C)(i)(Ill). The CDR and EBS were issued in draft form for regulator review on April 23, 2015. TDEC provided written comments on May 20, 2015 Comments were received from EPA Region 4 on May 21, 2015 Those comments and DOE's responses are included in this CDR The CDR package was available for public review from June 8, 2015, until J ly 8, 2015, and the availability of the documents for review was announced in three area newspapers and in the online version of one newspaper. No public comments were received.

4. The deferral and the transfer of the Property will not substantia ly delay any necessary response action a the Property. Implementation of the ETTP Zone 2 ROD will not be delayed by the transfer of his Property. The schedules for investigation and comp etion of Zone 2 soils actions and to address ETTP groundwater and sod vapor contamination have been agreed upon by DOE, EPA, and TDEC as part of their ongoing planning and priori ization activities under the FFA needed to structure and sequence the many elements of the overall cleanup of the Oak 2 Radon prevention in the design and constn1ction ofsclwols and other large bmldings, EP N625/R-92/0 6, January 1993.

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Ridge Reservation NPL site. The currently-approved schedule, included in Appendices E and J of the FFA, provides for completion of Zone 2 remedial actions by 2026 and submittal of a Final Record of Decision for other pathways (e.g., groundwater, surface water and sediment) in 2023.

Although the schedules may be amended in accordance with FFA provisions allowing changes to schedules because of future events affecting the overall site cleanup, there is no reason to anticipate that any response actions would be delayed by this deferral or transfer.

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BILL HASLAM September 4, 2015 Ms. Sue Cange Environmental Manager Un ited States Department of Energy Oak Ridge Operations Office P.O. Box 200 1 Oak Ridge, Tennessee 37831 Re: Concurrence pursuant to CERCLA Section 120 (h)(3)(C) for East Tennessee Technology Park land transfers , K-31 and K-33 building areas and related parcels

Dear Ms. Cange:

This letter is to express my concurrence in the Covenant Deferral Requests (CDR) for transfers of federal property located at the East Tennessee Technology Park. Based on information provided in the Covenant Deferral Requests and review by staff in the Tennessee Department of Environment and Conservation (TDEC), the State concurs with the approvals by the federal Environmental Protection Agency (EPA) provisions found in Section 120(h)(3)(C) of the federal Comprehensive Environmental Response, Compensation and Liabi lity Act as evidenced by signed documents by the Region IV EPA Director of the Superfund Division dated January 22, 2015 and August 25, 201 5 attached to this letter.

It is my understanding and expectation that the Department of Energy (DOE) will remain fu lly responsible for any remediation that may be necessary at these sites. Further, it is my understanding that this CDR does not waive or impact in any way the State's right to recover any damages that may have been caused to its Natural Resources.

DOE ' s approach to handling its statutory environmental cleanup responsibilities while also seeking to provide opportunities for economic development for the Oak Ridge area is appreciated.

Bill Haslam

'15 SEP: 5 A!J.~l:3H STATE CAPITOL

• N ASll VILLE, TN 3 724 3-000 1

• PH: 615 .74 i.2oor

• www.t n .gov

APPROVAL OF COVENANT DEFERRAL REQUEST The United States Department of Energy (DOE) has requested that the U.S.

Environmental Protection Agency (EPA) approve DOE's request to defer the deed covenant required by Section 120(h)(3)(A)(ii)(I) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). DOE maintains that this approval will facilitate OOE's transfer of real property on the Oak Ridge Reservation (ORR) National Priorities List Site before jt has been determined that all necessary remedial action has been taken at this parcel.

DOE has designated this property, which is located at ORR 's East TeMessee Technology Parle (EITP) area, as the Fonner K-33 Area (or the Property). The Property contains a total of 136.4 acres, more or less, and is located in the western portion of the ETTP Heritage Center. The Property comprises a portion of the Zone 2 Soil Record of Decision (ROD) that has been divided into a set of Exposure Units (EUs). The transfer footprint is located on seven EUs and comprises the entire area of some EUs and a portion of others. The Fonner K-33 Area occupies three Zone 2 ROD EUs in their entirety (Z2 approximately 25. l acres, Z2 approximately 24 acres, Z2-09 ... approximately 21.5 acres); a portion of two EUs where the balance of these EUs have already been transferred (Z2-0I *approximately 21.8 acres, Z2-02 .. approximately 11.7 acres);

and, a portion of two EUs where the balance of these EUs are being addressed under the K*31 Building decontamination and decommissioning (D&D) Project (Z2 approximately 12.8 acres, Z2-0S - approximately 19.S acres). Two buildings are located in EU Z2-08 that will undergo D&D. Although EU Z2-08 soils have been characterized and confinned to only require industrial use land controls, confinnation soil sampling will be conducted beneath these buildings after completion of D&D to ensure soil cleanup levels have been achieved. DOE is proposing to transfer the title of this land for mixed (industriaVcommercial) use.

Based on the attached Findings, and in the exercise of authority granted to EPA under CERCLA Section 120(h)(3)(C) to approve the deferral of this covenant upon detennining that the Property is suitable for transfer prior to completion of all necessary remedial action, I have so detennined and I hereby APPROVE this request. This approval is expressly contingent upon the transfer proceeding to a final recorded Deed as presented to EPA in the CDR, Environmental Baseline Survey and draft Deed, including the Response Action Assurances, the characterization of contamination on the Property, the extent and definition of the Property, the intended use of the Property, an4 Public Notice and opportunity for comment as required. Any change to the underlying contingencies will effect a revocation of this approval.

In accordance with CERCLA Section 120(h)(3)(C), the covenant may not be deferred unless and until f Tennessee, or his delegatee, has concurred in this deferral.

APPROVAL OF COVENANT DEFERRAL REQUEST The United States Department of Energy (DOE) has requested that the U.S.

Environmental Protection Agency (EPA) approve DOE's request to defer the deed covenant required by Section 120(h)(3)(A)(ii)(I) of the Comprehensive Environmental Response, Compensation, and Liability Act {CERCLA). DOE maintains that this approval will facilitate DOE's transfer of real property on the Oak Ridge Reservation (ORR) National Priorities List Site before it has been detennined that all necessary remedial action has been taken at this parcel.

DOE has designated this property, which is located at ORR's East Tennessee Technology Park (EITP) area, as the Fonner K-31 Area {or the Property). The Property contains a total of 61 acres, more or less, and is located in the western portion of the ETTP Heritage Center. The Property comprises a portion of the Zone 2 Soil Record of Decision (ROD) that has been divided into a set of Exposure Units (EUs). The transfer footprint is located on five EUs and comprises the entire area of some EUs and a portion of others. The Former K-31 Area occupies three Zone 2 ROD EUs in their entirety (Z2 approximately 25.6 acres, Z2 approximately 10.9 acres, and Z2 approximately 20.9 acres); and a portion of two EUs where the balance of these EUs were addressed under the K-33 CDR (Z2 approximately 1.6 acres and Z2-0S -

approximately 1.6 acres).

Based on the attached Findings, and in the exercise of authority granted to EPA under CERCLA Section 120(h)(3)(C) to approve the deferral of this covenant upon determining that the Property is suitable for transfer prior to completion of aJI necessary remedial action, I have so detennined and I hereby APPROVE this request. This approval is expressly contingent upon the transfer proceeding to a final recorded Deed as presented to EPA in the CDR, Environmental Baseline Survey and draft Deed, including the Response Action Assurances, the characterization of contamination on the Property, the extent and definition of the Property, the intended use of the Property, and Public Notice and opportunity for comment as required. Any change to the underlying contingencies will effect a revocation of this approval.

In accordance with CERCLA Section 120(h)(3)(C), the covenant may not be deferred unless and until the Governor of Tennessee, or his delegatee, has concurred in this deferral.

Director, Superfund Division EPA Region 4

Table of Contents Acronyms ................................................................................................................................ v Introduction ............................................................................................................................... 1 1.0 Property Description ...................................................................................................... 6 2.0 Nature/Extent of Contamination .................................................................................10 2.1 Evaluation of Potential Contamination in the Former K-31 Area............................ 11 2.2 ETTP Soil and Groundwater Contamination ......................................................... 16 2.3 ETTP Building Demolition Activities.................................................................... 17 3.0 Analysis of Intended Land Use During the Deferral Period ......................................18 4.0 Risk Evaluation Results ...............................................................................................18 4.1 Vapor Intrusion Pathway Evaluation ..................................................................... 21 5.0 Response/Corrective Action and Operation and Maintenance Requirements ...........21 6.0 Contents of Deed/Transfer Agreement .......................................................................23 6.1 Background Introduction........................................................................................ 23 6.2 Selected Excerpts from the Draft Quitclaim Deed Related to Protection of Human Health and the Environment ............................................................................. 24 7.0 Responsiveness Summary ...........................................................................................39 7.1 Regulator Comments .............................................................................................. 39 7.2 Public Comments ................................................................................................... 53 List of Attachments ATTACHMENT A - ENVIRONMENTAL BASELINE SURVEY REPORT FOR THE PROPOSED TITLE TRANSFER OF THE FORMER K-31 AREA AT THE EAST TENNESSEE TECHNOLOGY PARK, OAK RIDGE, TENNESSEE iii

Acronyms bgs below ground surface CDR Covenant Deferral Request CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 CFR Code of Federal Regulations COC contaminant of concern D&D decontamination and decommissioning DCE dichloroethene DOE U.S. Department of Energy DVS Dynamic Verification Strategy EA Environmental Assessment EBS Environmental Baseline Survey ELCR excess lifetime cancer risk EM Environmental Management EPA U.S. Environmental Protection Agency ETTP East Tennessee Technology Park EU exposure unit FFA Federal Facility Agreement FY fiscal year HI hazard index MCL maximum contaminant level NCP National Contingency Plan NEPA National Environmental Policy Act of 1969 NFA No Further Action NPL National Priorities List OREM Oak Ridge Office of Environmental Management ORGDP Oak Ridge Gaseous Diffusion Plant ORO Oak Ridge Office ORPMP Oak Ridge Performance Management Plan ORR Oak Ridge Reservation PCCR Phased Construction Completion Report RAO remedial action objective RI Remedial Investigation RL remediation level ROD Record of Decision Tc technetium T.C.A. Tennessee Code Annotated TCE trichloroethene TDEC Tennessee Department of Environment and Conservation TVS Transportable Vitrification System U.S.C. United States Code VOC volatile organic compound g/L microgram per liter v

Covenant Deferral Request for the Proposed Title Transfer of the Former K-31 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee Introduction The U.S. Department of Energy (DOE) is proposing to transfer land designated as the Former K-31 Area, hereafter also referred to as the Property, at the East Tennessee Technology Park (ETTP) Heritage Center in Oak Ridge, Tennessee, by deed, and is submitting this Covenant Deferral Request (CDR) pursuant to Section 120(h)(3)(C) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, and applicable U.S. Environmental Protection Agency (EPA) guidance. The Oak Ridge Reservation (ORR), which includes the ETTP Heritage Center, was placed on the National Priorities List (NPL) in November 1989. Environmental investigation and cleanup activities are continuing at ETTP in accordance with CERCLA, the National Contingency Plan (NCP), and the Federal Facility Agreement (FFA). The FFA was entered into by the DOE-Oak Ridge Office (ORO), EPA Region 4, and the Tennessee Department of Environment and Conservation (TDEC) in 1991. The FFA establishes the schedule and milestones for environmental remediation of the ORR.

The proposed property transfer is a key component of the Oak Ridge Performance Management Plan (ORPMP) for cleanup of the ORR.

The Property is proposed as the potential site for new facilities to be used for office space, industrial activities, or other commercial uses. The Property consists of one contiguous tract of land, consisting of a total of approximately 61 acres, located in the northwestern portion of the Heritage Center. Figure 1 shows the location of the Former K-31 Area within the Heritage Center. The boundaries of the Property are shown on Figure 2. No buildings are included in the proposed transfer. The K-31 Building, the K-761 Switch House, and the K-903 Pad (see Figure 2) will be demolished before the underlying land is transferred. Confirmatory sampling will be conducted post-demolition and the results will be documented and submitted to the EPA and TDEC for review and approval in a Concurrence Form and an addendum to the appropriate Phased Construction Completion Report (PCCR). Additionally, DOE has a policy that independent verification is also conducted at all exposure units (EUs) following the completion of all activities within the EU and prior to release of the property.

The soil and slab underlying Building K-761 and the K-903 Pad are part of an exposure unit (EU) [see Section 1.0] with an approved no further action (NFA) determination; hence, the land underlying these structures is included in the transfer footprint of this CDR. Likewise, Dynamic Verification Strategy (DVS) sampling of EU Z2-06, including 54 samples of the soils underlying the K-31 slab, detected no contamination above average or maximum remediation levels (RLs) and an NFA determination has been recommended in the draft Technical Memorandum that was provided to EPA in March 2015; hence, the 1

FORMER K-31 AREA LEGEND:

EAST TENNESSEE TECKNOLOGY PARK OAK RIDGE, TENNESSEE Figure 1. Location Map of the Former K-31 Area Within the ETTP Heritage Center 2

Z1-59 Z1-63 Z1-68 Z1-58 Z2-01 Z2-16 K-891 Z1-57 K-892-Y C AR PL PO Z2-04 EK RE Z2-02 Z2-17 K-792 K-892 Z1-54 FORMER K-33 Z2-08 BUILDING Z1-52 Z2-05 Z1-51 Z1-50 Z2-09 FORMER K-31 BUILDING K-762 K-761 K-861 Z1-49 Z2-06 Z1-48 Z2-03 Z2-07 Z2-10 Z1-46 Z2-19 Z2-11 LEGEND:

EAST TENNESSEE TECHNOLOGY PARK OAK RIDGE, TENNESSEE Figure 2. The Former K-31 Area Transfer Footprint 3

land underlying the K-31 building is included in the transfer footprint of this CDR. As an additional measure for ensuring that no contamination above established Zone 2 RLs remains when demolition of these structures is completed, the subsurface soils and structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and subsurface structures meet the Zone 2 Record of Decision (ROD) RLs.

If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented for approval in a Concurrence Form and the appropriate PCCRs, as described in Section 1.0 below.

DOE continues to be responsible for any contamination that is present on the Property at the time of transfer but found after the date of transfer. The deed transferring the Property contains various restrictions and prohibitions on the use of the Property that are subject to enforcement pursuant to State Law Tennessee Code Annotated (T.C.A.)

68-212-225 and real property law. These restrictions and prohibitions are designed to ensure protection of human health and the environment.

CERCLA requires that when the Federal government transfers property where hazardous substances have been stored for one year or more, released, or disposed of, the deed must contain two covenants warranting that 1) all remedial actions necessary to protect human health and the environment from hazardous substances remaining on the property have been taken before the date of the property transfer [CERCLA 120(h)(3)(A)(ii)(I)], and

2) any additional remedial action found to be necessary after the date of the property transfer shall be conducted by the United States [CERCLA 120(h)(3)(A)(ii)(II)]. The deed will contain this last covenant. However, in certain circumstances, EPA, with concurrence of the Governor of the State in which the facility is located, may defer the covenant set forth in CERCLA 120(h)(3)(A)(ii)(I) warranting all remedial actions necessary to protect human health and the environment have been taken, if EPA determines that the property is suitable for transfer based upon the following findings:

1. The property is suitable for transfer for the use intended by the transferee, and such use is consistent with protection of human health and the environment;

2. The deed proposed to govern the transfer between the United States and the GRANTEE of the property contains the Response Action Assurances described in Section 120(h)(3)(C)(ii) of CERCLA with regard to a release, or threatened release, of a hazardous substance for which the Federal agency is potentially responsible, including:

a) Provide for any necessary restrictions on the use of the property to ensure the protection of human health and the environment; 4

b) Provide that there will be restrictions on use necessary to ensure that required remedial investigations (RIs), response actions, and oversight activities will not be disrupted; c) Provide that all necessary response actions will be taken, and identify the schedules for investigation and completion of all necessary response actions as approved by the appropriate regulatory agency; and d) Provide that the Federal agency responsible for the property subject to transfer will submit a budget request to the Director of the Office of Management and Budget that adequately addresses schedules for investigation and completion of all necessary response actions, subject to congressional authorizations and appropriations.

3. The Federal agency requesting deferral has provided notice by publication in a newspaper of general circulation in the vicinity of the property, of the proposed transfer and of the opportunity for the public to submit, within a period of not less than 30 days after the date of notice, written comments on the suitability of the property for transfer; and

4. The deferral and the transfer of property will not substantially delay any necessary response action at the property.

These findings are intended to ensure that there is a sound basis for the proposed transfer because the intended reuse of the property does not pose an unacceptable risk to human health or the environment. As stated in CERCLA Section 120(h)(3)(C)(iv), all statutory obligations required of, and rights granted to, a Federal agency remain the same, regardless of whether the property is transferred subject to a covenant deferral.

Ecological Impacts Potential impacts to ecological receptors can occur from either:

1. impacts that are associated with residual contamination of environmental media that result in risk to ecological receptors; or

2. impacts to ecological receptors from development and/or operational activities occurring after transfer of the property.

Potential impacts to ecological receptors from the first category will be addressed as ecological risk in the final ETTP Sitewide ROD, which will also evaluate risk from groundwater and surface water to human and ecological receptors. DOE will remain responsible, regardless of property ownership, for providing the necessary response actions to address any residual contamination on the property to ensure protection of ecological receptors, and any efforts needed will be coordinated with EPA and TDEC under the FFA.

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Potential impacts to ecological receptors from development and/or operational activities resulting from property transfer were addressed in the Environmental Assessment for Transfer of Land and Facilities within the East Tennessee Technology Park and Surrounding Area, Oak Ridge, Tennessee, DOE/EA-1640, October 2011 (DOE 2011),

which resulted in a Finding of No Significant Impact. Exhibit B of the Quitclaim Deed, included in Section 6.2 of the CDR, restricts development of the property to the industrial, commercial, and recreational uses evaluated in the Environmental Assessment.

Additionally, following transfer, the new property owner is still subject to regulatory requirements such as storm water management, wetlands protection, and Clean Air Act compliance. Finally, adverse environmental impacts to existing ecological receptors would be limited because construction activities would primarily occur within previously disturbed areas.

DOE hereby requests that EPA Region 4 determine, with the concurrence of the Governor of the State of Tennessee, that the Property is suitable for transfer and that the CERCLA Section 120(h)(3)(A)(ii)(I) covenant may be deferred. The deferral is necessary because a final remedial action under an ETTP Sitewide ROD has not been taken. Once the deferral request is granted, DOE will proceed to convey the Property while DOE continues to complete all necessary remediation at the ETTP site in accordance with CERCLA, the NCP, and the FFA. In accordance with CERCLA Section 120(h)(3)(B), this CDR pertains solely to the transfer of this Property, or any portion thereof, to a non-Potentially Responsible Party.

1.0 Property Description As shown in Figure 1, the Former K-31 Area is located in the northwestern portion of the Heritage Center and consists of approximately 61 acres. General descriptions of the Property are contained in the Environmental Baseline Survey (EBS), which is included as Attachment A and summarized below. The Heritage Center, located in the far western end of the ORR, within the city of Oak Ridge, is the site of the former Oak Ridge Gaseous Diffusion Plant (ORGDP) where uranium enrichment operations occurred from the mid-1940s until the mid-1980s. Prior to construction of the ORGDP, the area was used as farmland. When the ORGDP was active, the Former K-31 Area was predominately used for the production of enriched uranium using the gaseous diffusion process. Portions of the area were also used for pumping and treatment of recirculated cooling water. The Heritage Center is now transitioning from DOE to private ownership as cleanup from prior DOE operations progresses. Hence, some of the Heritage Center is owned by DOE, while some has been transferred to the private sector.

As shown in Figure 2, the Former K-31 Area consists of one contiguous tract of land (approximately 61 acres). The boundaries of the Property along with EU boundaries are shown in Figure 3. The Former K-31 Area transfer footprint is bounded by the former K-762 Switchyard (Z2-03) and vacant land (EU Z1-46) to the west; the Former K-33 Area to the north (EUs Z2-02, Z2-05, Z2-08, and Z2-09); and Poplar Creek to the east and south. The transfer footprint includes three Zone 2 EUs in their entirety: Z2-06 6

PO A

PL EK RE RC K-792 FORMER K-33 BUILDING K-31 K-762 K-761 K-861 K-1206-F LEGEND:

EAST TENNESSEE TECHNOLOGY PARK OAK RIDGE, TENNESSEE Figure 3. Exposure Units in the Former K-31 Area (aerial photo circa 2013) 7

(approximately 25.6 acres), Z2-07 (approximately 10.9 acres), and Z2-10 (approximately 20.9 acres). Portions of EUs Z2-03 and Z2-05 were excluded from the K-33 Area CDR and EBS because these areas were needed to support the K-31 Building Decontamination and Decommissioning (D&D) project and are, therefore, included in this K-31 Area CDR and EBS. The transfer footprint portions included in this proposed transfer are 2.1 acres of EU Z2-03 and 1.6 acres of EU Z2-05. The Property includes:

land that was not previously included in the Former K-33 Area transfer footprint CDR on the east side of the former K-762 Switchyard (includes the balance of EU Z2-03);

a narrow strip of land on the north side of the former K-31 building that was not previously included in the Former K-33 Area transfer footprint CDR (includes the balance of EU Z2-05);

land on which the demolished Building K-31 was located (EU Z2-06);

mostly vacant land south of the former K-31 building (EU Z2-07); and mostly vacant land to the southeast of the former K-31 building location where the K-1206 Fire Water Tank was formerly located (EU Z2-10).

No buildings are included in the proposed transfer. The existing unpaved and improved roadways are included in the proposed transfer. Building K-31, Building K-761, and the K-903 Pad (Figure 3) are excluded from the proposed transfer and will be demolished before the underlying land is transferred. Confirmatory sampling will be conducted post-demolition in EUs Z2-03, Z2-05, Z2-06, and Z2-10 where demolition has occurred.

Additionally, DOE has a policy that independent verification is also conducted at all EUs following completion of all activities and prior to release of the property.

The soil and slab underlying Building K-761 and the K-903 Pad are part of an EU with an approved NFA determination; hence, the land underlying these structures is included in the transfer footprint of this CDR. The soils beneath K-761 and the K-903 Pad were not sampled under the DVS, but they were included within the scope of the PCCR for EUs Z2-03 and Z2-05. However, to ensure that no contamination above established Zone 2 RLs remains, when removal of the K-903 Pad is complete, the subsurface soils will be characterized during confirmatory sampling to ensure that the soils meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until K-903 Pad removal, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the PCCR Addendum for EUs Z2-04 and Z2-05 in Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Section XXI of the FFA. Likewise, when demolition of K-761 is complete, the subsurface soils and/or exposed remaining structures, if any, will be further 8

characterized during confirmatory sampling to ensure that the soils and/or subsurface structures, such as concrete subsurface foundation elements and electrical ducts, meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the FY 2007 PCCR Addendum for Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Section XXI of the FFA.

DVS sampling of EU Z2-06 included 54 samples of the soils underlying the K-31 slab. No contamination above average or maximum RLs was detected in these below-slab soil samples. An NFA determination has been recommended in the draft Technical Memorandum that was provided to EPA in March 2015. As an additional measure for ensuring that no contamination above established Zone 2 RLs remains when demolition of K-31 and its slab is completed, the subsurface soils and structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and subsurface structures meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the EU Z2-06 PCCR.

Remedial actions performed within the Former K-31 Area have included demolition of the former K-31 building, staging and sorting of the building debris, disposal of the demolition materials, and grouting of electrical manholes and oil/water separators (within the transfer footprint).

The K-903 concrete pad is located in the narrow strip of EU Z2-05 that is included in the Former K-31 Area transfer footprint. This concrete pad was the location of the Supercompaction Facility used during the Three-Building D&D. This facility operated from 2001 to 2004, at which time and the building and equipment were decommissioned and removed.

The northeastern corner of EU Z2-07 was the location of the Transportable Vitrification System (TVS) in 1996 to 1997. TVS was a large-scale vitrification system for the treatment of mixed wastes (see EBS Figure 4.1). The wastes contained both hazardous and radioactive materials in the form of sludge, soil, and ash. The TVS was moved to the site and erected in 1996. The TVS was demonstrated at ETTP during September and October of 1997. During this period, approximately 16,000 pounds of actual mixed waste were processed, producing over 17,000 pounds of glass. After the demonstration was complete, it was determined that it was more expensive to use the TVS unit to treat and dispose of mixed waste than to direct bury this waste in a permitted facility. Thus, 9

the unit was deactivated and a Resource Conservation and Recovery Act (RCRA) closure of the facility was conducted and approved, and the unit subsequently was dismantled.

In addition, demolition of the K-1206-F Fire Water Tank, located in the central portion of EU Z2-10, was conducted in August of 2013 through a controlled explosive demolition.

The 382-foot-tall water tank was toppled onto an empty field, where the tank was dismantled and the metal from the tank was recycled.

2.0 Nature/Extent of Contamination In accordance with CERCLA Section 120(h), reviews of government records, title documents, and aerial photographs; visual and physical inspections of the Property and adjacent properties; and interviews with current and former employees were conducted to identify any areas on the Property where hazardous substances and petroleum products or their derivatives were stored for one year or more, known to have been released, or disposed of. Additionally, radiological survey and environmental sampling were conducted under the DVS process to assess the condition of the Property. The summary details of these evaluations, including discussions of the nature and extent of contamination, are presented in Section 6.0 of the EBS Report (Attachment A). The findings of the evaluations are summarized in subsections 2.1 through 2.2 below.

EPA guidance allows for the transferring Federal agency to demonstrate why a completed Remedial Investigation (RI) or Risk Assessment is not necessary before the land is transferred. Risk evaluations using the regulator-approved DVS process were prepared by the Environmental Management (EM) Program for soils in all of the EUs in which the Former K-31 Area is located. The results of these risk evaluations for soils indicate that all risks, doses, and hazards are within acceptable levels of EPAs target risk range for an industrial worker; hence, neither an RI nor a Risk Assessment was necessary. The evaluations are summarized in Section 4.0.

The EM Program has divided approximately 800 acres at ETTP into 44 EUs under the Zone 2 ROD for the purposes of evaluating risk and making remedial decisions to protect future users of the site and to protect underlying groundwater. The objective of the Zone 2 remediation measures is to protect industrial workers from exposure to hazardous substances in Zone 2. The institutional controls restricting property use to industrial use, and the limited potential for off-site migration of contaminants, limit the potential for exposure to other individuals.

The Former K-31 Area is located in five Zone 2 EUs (Figure 2). The Property includes all of EUs Z2-06, Z2-07, and Z2-10, and portions of EUs Z2-03 and Z2-05. The balance of EUs Z2-03 and Z2-05, which is not included in the transfer footprint, has already been included in the transfer footprint for the Former K-33 Area.

10

The Former K-31 Area EBS report (Attachment A) relies upon regulator-approved documentation in the PCCRs (listed below) for the foundational information about the potential for surface and subsurface soil and subsurface structure contamination:

Fiscal Year 2006 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2317&D2), December 2006 (approved) [DOE 2006] (addresses EUs Z2-02, Z2-07, Z2-09, and Z2-10).

Fiscal Year 2007 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2723&D2), September 2007 (approved) [DOE 2008] (addresses EUs Z2-01, Z2-03, and Z2-08).

Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2590&D1), November 2012 (approved) [DOE 2012].

Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-XXXX),

2015 (approval pending) [DOE 2015] (addresses EU Z2-06) [NFA recommended, D1 version to EPA in November 2015 (planned)].

The PCCRs were prepared as part of the EM DVS, a decision document supporting NFA under an industrial land use risk scenario in the EUs that include the Former K-31 Area. This process is in use for remedial action decision-making across the ETTP Heritage Center. Based on the DVS results, EPA and TDEC concurrence for the fiscal year (FY) 2006 PCCR for Zone 2 (addresses EUs Z2-07 and Z2-10) was received on February 26, 2006, and December 8, 2006, respectively. EPA and TDEC concurrence for the FY 2007 PCCR for Zone 2 (addresses EU Z2-03) was received on June 9, 2008, and February 6, 2008, respectively, and EPA and TDEC approval of the PCCR addressing EU Z2-05 was received on February 6, 2013, and February 8, 2013, respectively. Based on the results of confirmation sampling, EU Z2-06 (location of former K-31 building) meets the requirements for NFA and concurrence on this determination has been requested from EPA and TDEC [NFA recommended, D1 version to EPA and TDEC in November 2015 (planned)].

Although a groundwater plume has not been identified in the subsurface of the Former K-31 Area, volatile organic compounds (VOCs) and metals have been sporadically detected in some of the wells on the Property. Currently, groundwater contamination present in Zone 2 will be addressed in the ETTP Sitewide ROD.

2.1 Evaluation of Potential Contamination in the Former K-31 Area The results of the evaluation are as follows:

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The EUs in which the Former K-31 Area are located were assessed under a Work Plan (2007) prepared and approved according to the DVS protocol. The Work Plan was approved by EPA and TDEC on December 7 and 13, 2007, respectively. All verified and validated data used to make regulatory decisions have been placed in the Oak Ridge Environmental Information System database and are available for review.

The locations of soil samples collected under the DVS within the EUs included in the transfer footprint are shown in Figure 4. These data were deemed sufficient to reach NFA decisions for soils under an industrial land use scenario for all of the EUs (Z2-03, Z2-05, Z2-06, Z2-07, and Z2-10) included in the Former K-31 Area.

An evaluation was conducted of the potential impact on the DVS decisions due to the difference in transfer footprint and EU boundaries for EUs Z2-03 and Z2-05. This evaluation indicated that for the two EUs partially included in the transfer footprint (the balance of EUs Z2-03 and Z2-05 has already been included in the proposed transfer footprint for the Former K-33 Area), the NFA decisions are appropriate for these partial EUs. For the remaining three EUs (Z2-06, Z2-07, and Z2-10), the NFA decisions, as documented in the approved PCCRs, are appropriate.

Building K-761 is located in EU Z2-03, which has an approved NFA for soils, slabs, and subsurface structures. Building K-761 is the Switch House for the former K-762 Switchyard and is planned for demolition in Fall 2015. The K-903 Pad is located in EU Z2-05 and is also planned for removal.

Because the soil and slab underlying Building K-761 and the K-903 Pad are part of an EU with an approved no NFA determination, the land underlying these structures is included in the transfer footprint of this EBS/CDR. The soils beneath K-761 and the K-903 Pad were not sampled under the DVS, but they were included within the scope of the PCCR for EUs Z2-03 and Z2-05. Sampling locations for these EUs were established during DQOs workshops with EPA and TDEC approval, which did not identify a need for samples beneath these facilities. However, as an additional measure for ensuring that no contamination above established Zone 2 RLs remains, when removal of the K-903 Pad is complete, the subsurface soils will be further characterized during confirmatory sampling to ensure that the soils meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until K-903 Pad removal, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the PCCR Addendum for EUs Z2-04 and Z2-05 in Zone 2.

The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Section XXI of the FFA. Likewise, when demolition of K-761 is complete, the subsurface soils and/or exposed remaining structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and/or subsurface structures, such as concrete subsurface foundation elements and 12

PL PO AR E

CR EK K-792 FORMER K-33 BUILDING K-31 LEGEND:

EAST TENNESSEE TECHNOLOGY PARK OAK RIDGE, TENNESSEE Figure 4. Former K-31 Area DVS Sample Locations 13

electrical ducts, meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the FY 2007 PCCR Addendum for Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Section XXI of the FFA.

DVS sampling of EU Z2-06 included 54 samples of the soils underlying the K-31 slab. No contamination above average or maximum RLs was detected in these below-slab soil samples. An NFA determination has been recommended in the draft Technical Memorandum that was provided to EPA in March 2015. As an additional measure for ensuring that no contamination above established Zone 2 RLs remains when demolition of K-31 and its slab is completed, the subsurface soils and structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and subsurface structures meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the EU Z2-06 PCCR. The PCCR will be submitted to EPA and TDEC for formal review and approval in accordance with Section XXI of the FFA.

Several VOCs, including 2-butanone, 1,1-dichloroethene (DCE), 1,2-DCE, 1,2-dimethylbenzene, acetone, carbon disulfide, chloroform, chloromethane, methylene chloride, tetrachloroethene, toluene, and trichloroethene (TCE) have been detected in bedrock wells and unconsolidated zone wells south and east of K-31 (Figure 5). Although VOCs have been detected in this area, a groundwater plume has not been defined because these compounds have only been detected sporadically and these detections have generally occurred in only historical samples. Only TCE at wells BRW-064 and BRW-066 has exceeded its respective maximum contaminant level (MCL) of 5 micrograms per liter (µg/L) in samples collected since 1994. A concentration of 10 µg/L was reported in March 1995 at well BRW-064 and 54 µg/L in June 1998 at well BRW-066; however, TCE concentrations during subsequent sampling events at well BRW-064 have not exceeded the MCL, and TCE has been detected in only 5 of 25 samples collected at well BRW-066 since the June 1998 sampling event. The detected concentrations of TCE at BRW-066 since 1998 have all been below the MCL with concentrations ranging from 0.2 µg/L to 4 µg/L.

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GEOLOGY:

Oc Olv K-8 92-J Ok C

AR Oma PL PO EK RE Ops K-792 FORMER K-33 BUILDING Om Ord FORMER K-31 K-861 BUILDING Olb Oca Om Ord Olb Oca Ocn-Ocy Oh LEGEND:

EAST TENNESSEE TECHNOLOGY PARK OAK RIDGE, TENNESSEE Figure 5. Former K-31 Area Monitoring Well Locations 15

Metals that have been detected in at least one sampling event at concentrations above MCLs include antimony, arsenic, cadmium, chromium, lead, selenium, and thallium.

Total chromium is the metal detected the most frequently at concentrations above the MCL of 0.1 milligram per liter (mg/L) with the exceedances primarily limited to wells located east and northeast (BRW-030, BRW-063, UNW-043, and UNW-083) of the former K-31 building (Figure 5). With the exception of total chromium, the other metals that have historically exceeded MCLs have not been detected above MCLs in the most recent sampling events for these wells.

Well UNW-039 (Figure 5) located immediately northwest of the Former K-31 Area has exhibited gross alpha activity above the MCL of 15 picocuries per liter (pCi/L) during one sampling event in September 1994 with a concentration of 58 pCi/L.

However, the duplicate sample had no detectable alpha activity. Five of the six samples analyzed for gross alpha activity from this well were either nondetects for alpha activity or the detected concentration was well below the MCL. The gross beta activity has not exceeded the guidance level of 50 pCi/L at any of the K-31 area wells since 1990. Technetium-99 (99Tc) has exceeded the derived MCL of 900 pCi/L at two unconsolidated zone wells (UNW-081 and UNW-082) and three bedrock wells (BRW-027, BRW-065, and BRW-068) [Figure 5] with concentrations ranging from 947 to 1300 pCi/L in 1992 and 1993 groundwater samples from these wells.

However, the limit of error for these results ranges from 320 to 1400 pCi/L indicating the uncertainty associated with these results is relatively high, and 99Tc was not detected in subsequent groundwater samples collected from these wells.

2.2 ETTP Soil and Groundwater Contamination Currently, of the approximately 2,200 acres within Zones 1 and 2 at the Heritage Center, about 1,970 acres have been characterized for soil media (surface and subsurface). To support characterization activities, over 2,100 samples have been collected and evaluated by EM. These activities have resulted in NFA determinations under an industrial land use risk scenario for approximately 1,680 of the 2,200 acres within the two zones.

The Heritage Center has known contaminated groundwater plumes consisting mainly of VOCs with concentrations ranging from a high of approximately 15 parts per million in the far northeast portion of the site to non-detectable concentrations that resulted from past operations. No contaminated groundwater plume has been identified beneath the Former K-31 Area. The nearest identified plume is located approximately 2,000 feet northwest of the Property (Figure 5). Although available potentiometric maps indicate that this plume may be considered to be upgradient of the Property, groundwater data and dye tracer studies indicate that the predominant flow direction of this plume is to the southwest and not southeastward toward the Property. However, there is uncertainty concerning groundwater flow paths due to the karst conditions in the bedrock underlying most of the Heritage Center.

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2.2.1 Vapor Intrusion Sampling Because of the occurrence of VOCs in known contaminated groundwater plumes at the Heritage Center, EPA Region 4 recommended investigation of the potential vapor intrusion pathway for site facilities that are targeted for transfer under a CERCLA Section 120(h) CDR. In accordance with EPAs Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (EPA 530-F-02-052, November 2002), and through consultation with representatives from EPA Region 4, DOE-ORO developed a process to evaluate the potential for vapor intrusion at ETTP Heritage Center properties to be transferred to the private sector. This process calls for development of vapor intrusion investigation and control requirements on a case-by-case basis, dependent upon conditions present at properties being transferred. The Quitclaim Deed condition addressing this for the former K-31 Area is found in Section 6.2, Condition (11). The Oak Ridge Office of Environmental Management (OREM), EPA Region 4, and TDEC have agreed that vapor intrusion will be addressed in the ETTP final Sitewide ROD.

Soil vapor sampling within existing buildings at ETTP has been conducted in the K-791-B and K-796-A buildings located approximately 200 feet northwest of the Former K-31 Area transfer footprint (see Figure 5). Sub-slab soil vapor was collected in K-791-B (four locations) and K-796-A (two locations) during September 2006 (dry season) and February 2007 (wet season) to determine if a potential source for VOCs exists under these buildings. Soil vapor samples were collected in accordance with an approved Sampling and Analysis Plan. Based on the soil vapor sampling results for these two buildings, as presented in the K-792 Switchyard Complex EBS, the vapor intrusion pathway is not considered complete beneath the buildings.

2.3 ETTP Building Demolition Activities As part of the cleanup of the Heritage Center, numerous facilities are being demolished. Facilities that formerly occupied portions of the Former K-31 Area, but have, or will be, demolished, include the following:

K-31 Process Building, K-33/K-31 Tie Lines, K-1206 Fire Water Tank, and K-761 Building Demolition planning and execution will include appropriate work controls that will be utilized to minimize and control the release of hazardous substances during demolition activities, such as the ETTP Storm Water Pollution Prevention Plan, so that surrounding properties and persons are protected.

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3.0 Analysis of Intended Land Use During the Deferral Period The Property proposed for transfer is situated within an industrial site (Heritage Center) that is being transitioned from the federal ownership to private ownership. As stated previously, the Heritage Center is being remediated to allow for its conversion to a brownfield mixed-use commercial and industrial park. During the deferral period, the Property may be left as it is, or facilities may be constructed on it as allowed by the deed.

Risk evaluations were performed to determine whether the Property is acceptable for industrial uses by the private sector. The results of the risk evaluations are presented in Section 4.0 below.

4.0 Risk Evaluation Results Zone 2 remedial action objectives (RAOs) were developed for soils by the DVS to support the future industrial use of the Heritage Center. Therefore, remediation criteria were designed for the protection of the future industrial worker.

The decision rules for soils established in the DVS were based on one or more of the following criteria:

exceedance of a maximum RL at any location, exceedance of an average RL across the EU, unacceptable future threat to groundwater, or unacceptable cumulative excess lifetime cancer risk (ELCR) of > 1 x 10-4 and hazard index (HI) >1 across the EU.

The NCP preamble (55 Federal Register 8716, March 8, 1990) describes the process used to establish the remediation goal for environmental media as consisting of a two-step approach. First, an individual lifetime excess cancer risk of 10-6 is used as a starting point for establishing remediation goals for the risks from contaminants at specific sites. The second step involves consideration of a variety of site-specific or remedy-specific factors, which enter into the determination of where, within the risk range, the cleanup standard for a given contaminant will be established. The factors considered in the development of the Zone 2 ROD and subsequent steps in the implementation of the ROD, such as the DVS, included an acceptable cumulative risk level of 10-4, which is the upper bound of the EPA-acceptable risk range. From the Zone 2 ROD (Section 1.4): The remedial action objective (RAO) for Zone 2 includes the following: Protect human health under an industrial land use to an excess cancer risk at or below 1 x 10-4. Zone 2 RAOs were developed by the DVS to support the future use of 10-4 cumulative ELCR across the EU as one of the decision criteria. To achieve the RAO, constituent-specific cleanup goals were developed. Per the NCP preamble, these cleanup goals are to be based on a risk level of 10-6 for 18

individual constituents unless site-specific or remedy-specific factors exist to suggest modifications are appropriate. For the Zone 2 Interim ROD, these factors include the following:

Site-Specific Exposure Factors exposure of the industrial worker is limited to soil-related pathways only (multiple media exposures are not applicable to this scenario), and the limited contaminant of concern (COC) list indicates that the potential for a large number of remedial goal exceedances was considered unlikely in the ROD, allowing for a higher risk level for each COC considered, while still achieving a cumulative risk <10-4. However, the ROD indicates that additional COCs were identified in four EUs within Zone 2, and additional COCs may be identified from the characterization sampling to be conducted for a wide range of potential contaminants.

Remedy-Specific Technical Factors remedial goals for particular COCs were generated at a risk level >10-5 due to cost prohibitiveness and impracticality of remediation to a lower concentration, and remedial goals for particular COCs were revised to reflect consideration of elevated background levels.

Incorporation of the factors above provided RLs that reflect the RAO of achieving a cumulative human health risk that will not exceed 10-4 for a given EU or FFA site.

Table 4.1 summarizes the decisions and final status summary under an industrial land use risk scenario for the EUs in which the Former K-31 Area is located.

The risk evaluation results (found in Section 7.0 of Attachment A of this CDR) indicate that all risks, doses, and hazards are considered within acceptable levels of EPAs target risk range for an industrial worker.

DOE also considered risks from exposure to the larger Heritage Center site through evaluation of a roving worker who may access multiple areas across the site. The roving worker scenario is considered to be applicable to all of the Heritage Center, including transferred areas.

This evaluation was based on certain assumptions, including (1) the worker will not be exposed to areas that are inaccessible due to radiological or other controls, such as fences or other barriers, or postings that prevent casual entry by a worker at a nearby building; and (2) there are no hotspots of contamination at the Heritage Center that are accessible to these workers.

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Table 4.1. Risk Evaluation Results for the Former K-31 Area Associated Decision rule evaluationa FFA sites within the transfer Risk Final status EU footprint Max RL Avg RL Risk GW evaluation decisiona K-762 Valve Vault 2 (known as Z2-03 K-896) NFA NFA NFA NFA Passes NFA for soils K-897-M Oil Containment Structure Z2-05 None NFA NFA NFA NFA Passes NFA for soils NFA NFA NFA NFA NFA for soils Z2-06 None Passes recommended recommended recommended recommended recommended K-897-E Oil Containment Structure Z2-07 NFA NFA NFA NFA Passes NFA for soils K-897-F Oil Containment Structure K-897-G Oil Z2-10 Containment NFA NFA NFA NFA Passes NFA for soils Structure a

Decision rule, risk evaluation, and final status information are from:

Fiscal Year 2006 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2317&D2 (DOE 2006).

Fiscal Year 2007 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2723&D2 (DOE 2008).

Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2590&D1 (DOE 2012).

Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-XXXX (DOE 2015) [NFA recommended, D1 version to EPA and TDEC in November 2015 (planned)].

Avg = average Max = maximum EU = exposure unit. NFA = No Further Action.

FFA = Federal Facility Agreement. RL = remediation level.

GW = groundwater.

The results of the roving worker risk screen, which used all available data, show that risk was 1.8 x 10-5, which is within the EPA acceptable risk range of 10-4 to 10-6. The calculated hazard for the roving worker was 0.33, which is below the EPA acceptable level of 1.0. As a part of the ongoing Heritage Center cleanup, soil data and confirmatory sampling data continue to be collected and have been used to support numerous NFA decisions under an industrial land use risk scenario. Cleanup and confirmatory sampling work are ongoing. The EUs associated with the Former K-31 Area have either obtained NFA concurrence from EPA and TDEC, or have met the requirements for NFA and EPA and TDEC concurrence on this recommendation is pending. Therefore, the Property is suitable for transfer for the intended industrial use.

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4.1 Vapor Intrusion Pathway Evaluation VOCs have been detected in groundwater, soil, and soil vapors in the Former K-31 Area at low concentrations. The limited data available do not indicate a high likelihood of the presence of subsurface vapor sources (e.g., groundwater volatile organic plume) in the Former K-31 Area that pose a significant threat of vapor intrusion.

At other locations across the Heritage Center, soil vapor samples have been taken from approximately 95 sample locations from within 13 buildings and 2 land parcels, with a total of 191 soil vapor samples collected, including buildings over known groundwater plumes. Based on these soil vapor sample results, a complete vapor intrusion pathway does not exist for any of the buildings that have been sampled, including Buildings K-791-B and K-796-A located 200 feet northwest of the Former K-31 Area transfer footprint.

5.0 Response/Corrective Action and Operation and Maintenance Requirements The FFA parties divided the Heritage Center into two smaller operating units to facilitate site CERCLA decisions. The two operating units are Zone 1 (outside the main plant area) and Zone 2 (inside the main plant). The Former K-31 Area is located within Zone 2. The Zone 1 Interim ROD was signed in October 2002, and the Zone 2 ROD was signed on April 19, 2005; remedial actions for soils and sources of groundwater contamination in Zone 1 were completed in FY 2011, with the exception of the former K-770 Scrap Yard and the K-720 Fly Ash Pile, and are underway for Zone 2.

Located within some of the Zone 1 and Zone 2 EUs are sites designated as requiring special attention because they were listed in the FFA as having the potential for contamination. These FFA sites have been the focus of several remedial actions across the Heritage Center. Table 5.1 summarizes the regulatory status of the EUs in which the Former K-31 Area is located.

OREM plans to address the key sources to the contaminated groundwater plumes at the site to ensure protection of human health and the environment. The decision for groundwater will also be made through the CERCLA process. The final Sitewide ROD will include groundwater and any needed remedial action. Any measures planned to address groundwater contamination are not expected to impact the Property.

In order to ensure the protection of human health by preventing exposure to contaminants present in the groundwater, the deed for the Property prohibits the extraction, consumption, exposure, or use, in any way, of the groundwater without the prior written approval of DOE, EPA, and TDEC. Additional provisions are included to prevent inadvertent exposure to contaminated groundwater and/or any contamination that could possibly be present in the soils. Such provisions include requiring adherence 21

to applicable Federal, State, and local laws with respect to any development of the property.

Table 5.1. Former K-31 Area Components and Summary of CERCLA Decisions Associated FFA sites Geographic EU within the transfer area Group PCCR (acreage)a footprintb Decision K-31/33 Area K-31/K-33 FY 2007 PCCR Z2-03 K-762 Valve Vault2 NFA for soils for Zone 2 Soils, (known as K-896) approvedc (14.9 acres)

Slabs, and K-897-M Oil Subsurface Containment Structure Structures at ETTP K-31/33 Area K-31/K-33 2012 PCCR for Z2-05 None NFA for soils EUs Z2-04 and approvedd (22 acres)

Z2-05 at ETTP K-31/33 Area K-31/K-33 2014 PCCR for Z2-06 None NFA for soils EU Z2-06 recommendede (25.6 acres)

K-31/33 Area K-31/K-33 FY 2006 PCCR Z2-07 K-897-E Oil NFA for soils for Zone 2 Soils, Containment Structure approvedf (10.9 acres)

Slabs, and K-897-F Oil Subsurface Containment Structure Structures at ETTP K-31/33 Area K-31/K-33 FY 2007 PCCR Z2-10 K-897-G Oil NFA for soils for Zone 2 Soils, Containment Structure approvedf (20.9 acres)

Slabs, and Subsurface Structures at ETTP a

Component names and acreages as provided in the PCCRs listed in Sect. 3.2.

b No FFA sites are located within the former K-31 building EU.

c NFA approved from the Fiscal Year 2007 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2723&D2 (DOE 2008).

d NFA approved in the Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2590&D1 (DOE 2012).

e NFA approved in the Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-XXXX (DOE 2015) [NFA recommended, D1 version to EPA and TDEC in November 2015 (planned)].

f NFA approved from the Fiscal Year 2006 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2317&D2 (DOE 2006).

EBS = Environmental Baseline Survey Report. FFA = Federal Facility Agreement.

CERCLA = Comprehensive Environmental Response, NFA = no further action.

Compensation, and Liability Act of 1980. PCCR = Phased Construction Completion EU = exposure unit. Report.

Vapor intrusion will be addressed in the final Sitewide ROD, which will include groundwater. Any new building or structure built on the Property that will be occupied must be designed and constructed to minimize potential exposure of workers to VOC vapors, using EPA/625/R-92/016 (June 1994), Radon Prevention in the Design and 22

Construction of Schools and Other Large Buildings, as guidance, as noted in Section 6.1 and in the Quitclaim Deed, Condition (11).

6.0 Contents of Deed/Transfer Agreement This section includes the Quitclaim Deed clauses and/or exhibits required to enable EPAs determination under an industrial land use risk scenario that the property is suitable for transfer. The following items are included:

a. Notice - A copy of the notice as required by CERCLA Section 120(h)(1) and (3) and in accordance with regulations set forth at 40 Code of Federal Regulations (CFR)

Part 373;

b. Covenant - A copy of the covenant warranting that any additional remedial action found to be necessary after the date of transfer shall be conducted by the United States as required by CERCLA Section 120(h)(3)(A)(ii)(II);

c. Access - A copy of the clause that reserves the United States access to the property in any case in which an investigation, response, or corrective action is found to be necessary after the date of transfer as required by CERCLA Section 120(h)(3)(A)(iii);

and

d. Response Actions Assurances - A copy of the response action assurances that must be included in the deed or other agreement proposed to govern the transfer as required under CERCLA Section 120(h)(3)(C)(ii).

6.1 Background Introduction The Quitclaim Deed for the Property includes various prohibitions and restrictions intended to ensure that the proposed transfer is protective of human health and the environment.

The deed prohibits the use of the Property in a manner inconsistent with the land use assumptions of industrial use. Industrial use is defined by the Zone 2 ROD as potential exposure to surface conditions for 2,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br />s/year for 25 years. In addition, the deed specifically prohibits residential use, which includes residential housing, elementary or secondary schools, or any child care facility or childrens playground. Also, in accordance with the National Environmental Policy Act (NEPA) Environmental Assessment (EA), Transfer of Land and Facilities within the East Tennessee Technology Park and Surrounding Area, Oak Ridge, Tennessee, DOE/EA-1640, dated October 2011, industrial uses considered are the permitted principal uses and uses requiring a Board of Zoning Appeals permit in the City of Oak Ridge Zoning Ordinance for IND-1, IND-2, and IND-3, Industrial Districts. Additional commercial and recreational uses are those included in the Zoning Ordinance for UB-2, Unified General Business Districts.

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Although the vapor intrusion potential, as described in Section 4.1, is not high, uncertainty remains due to the limited data available. Therefore, the deed requires that any buildings newly constructed on the Property, which are intended to be occupied by workers eight hours or more per scheduled work day or by public visitors, will be designed and constructed to minimize exposure to VOC vapors. To ensure the protection of human health from exposure to contaminants in groundwater plumes throughout the site, the deed prohibits the GRANTEE from extracting, consuming, or using, in any way, the groundwater underlying the Property without the prior written approval of DOE, EPA, and TDEC. Finally, the deed requires compliance with all applicable Federal, State, and local laws and regulations with respect to any development on the Property.

The deed excerpts shown in Section 6.2, below, are from the draft Quitclaim Deed for the Property.

6.2 Selected Excerpts from the Draft Quitclaim Deed Related to Protection of Human Health and the Environment THIS QUITCLAIM DEED, made between the UNITED STATES OF AMERICA, its successors, transferees and assignees, hereinafter referred to collectively as the GRANTOR, acting by and through the Secretary of the Department of Energy, under and pursuant to the powers and authority contained in Section l61g of the Atomic Energy Act of 1954, as amended (42 United States Code [U.S.C.] § 2201(g)), and the GRANTEE. The GRANTOR and GRANTEE have agreed that in order to assure enforceability of land use restrictions, this Quitclaim Deed, including all of its exhibits, shall serve as a Notice of Land Use Restrictions pursuant to Tennessee Code Annotated 68-212-225, having all the effectiveness and enforceability of such Notice. By acceptance of this Quitclaim Deed or any rights hereunder, the GRANTEE, for itself, its successors and assignees forever, agrees that the transfer of all the Property transferred by this Deed is accepted subject to all terms, obligations, restrictions, reservations, covenants and conditions set forth in this Quitclaim Deed and all exhibits hereto, and that these terms, obligations, restrictions, reservations, covenants and conditions shall run with the land.

(1). It is the intent of the GRANTEE to utilize the property conveyed herein for purposes consistent with the mission of economic development for the community. All activities and development of the real property by the GRANTEE shall be consistent with the requirements contained within Exhibits B and D to this Quitclaim Deed.

(9). The GRANTEE shall comply with all applicable Federal, State, and local laws and regulations with respect to any present or future development of the property herein conveyed, including, but not limited to, those laws and regulations which govern sewage disposal, facilities, water supply, and other public health requirements.

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(10). All structures, facilities, and improvements requiring a water supply shall be required to be connected to an appropriate regulatory approved water system for any and all usage. GRANTEE covenants not to extract, consume, expose, or use in any way the groundwater underlying the property or water from any streams or ponds located on the property without the prior written approval of the GRANTOR, the U.S. Environmental Protection Agency and the Tennessee Department of Environment and Conservation.

(11). The GRANTEE covenants and agrees that any buildings intended to be occupied by workers eight hours or more per scheduled work day or by public visitors will be designed and constructed to minimize exposure to volatile organic contaminant vapors. The GRANTOR and the GRANTEE will determine the necessary building design features to minimize this potential exposure using EPA/625/R-92/016 (June 1994), Radon Prevention in the Design and Construction of Schools and Other Large Buildings, as guidance.

(15). The GRANTOR acknowledges that the Oak Ridge Reservation has been identified as a National Priorities List Site under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended. The GRANTEE acknowledges that the GRANTOR has provided it with a copy of the Oak Ridge Reservation Federal Facility Agreement (FFA), effective on January 1, 1992, and relevant amendments entered into by the GRANTOR, Region 4 of the United States Environmental Protection Agency, and the Tennessee Department of Environment and Conservation. The GRANTEE agrees that should any conflict arise between the terms of such agreement as it presently exists or may be amended and the terms of this Quitclaim Deed, the terms of the FFA will take precedence.

An Addendum addressing requirements of Section l20(h)(3), including response action assurances and use restrictions, is attached as Exhibit D and is made a part of this Quitclaim Deed and all provisions of that Addendum are fully incorporated herein.

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EXHIBIT A TO QUITCLAIM DEED SURVEY PLAT SHOWING THE TRANSFER FOOTPRINT 27

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EXHIBIT B TO QUITCLAIM DEED NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)

ALLOWABLE USES OF THE REAL PROPERTY In accordance with the Environmental Assessment Transfer of Land and Facilities within the East Tennessee Technology Park and Surrounding Area, Oak Ridge, Tennessee, DOE/EA-1640, dated October 2011, industrial uses considered are the permitted principal uses and uses requiring a Board of Zoning Appeals permit in the City of Oak Ridge Zoning Ordinance for IND-1, IND-2, and IND-3, Industrial Districts.

Additional commercial and recreational uses are those included in the Zoning Ordinance for UB-2, Unified General Business Districts. These uses could include, but are not limited to, the following:

Light to heavy processing, manufacturing, assembly, and fabrication plants, excluding slaughtering plants and paper or pulp mills.

Public utility facilities with or without storage yards.

Storage; wholesaling; distribution; warehousing, including shipping and freight terminals; and related facilities.

Research and testing facilities, including renewable and advanced energy, industrial, and scientific research laboratories that include incidental pilot plant processing operations.

Administrative, technical, and professional offices.

Storage facilities for materials such as, but not limited to, salt, switch grass, other alternative fuel feedstocks, coal, coke, building material, sand, gravel, stone, lumber, and enclosed or open storage of construction contractors equipment and supplies.

Waste treatment facilities, including nonhazardous waste recycling centers, hazardous and mixed waste treatment for shipment to off-site storage and disposal facilities.

Recycling operations, including those for radioactively contaminated materials and those associated with metal and other material treatment and processing.

Bulk oil and gasoline storage or bulk storage of natural gas.

Power plants, including renewable energy generation.

Broadcasting, publishing, recording, and telecommunications.

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Food processing such as dairy products, bakery products, and beverage products (all activities are conducted in an enclosed building).

Airports (additional NEPA review would be necessary).

Commercial uses, including restaurants and service establishments such as: gas station/convenience store, bank, post office/mailing/shipping center, copying/printing, bulk cleaning and laundry, cold storage lockers, furniture and carpet warehouses, car washes, equipment and appliance repair, vehicle service centers, etc.

Public recreation uses such as parks, historic legacy interpretation, playgrounds, golf courses, athletic fields, and stadiums.

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EXHIBIT D ADDENDUM TO QUITCLAIM DEED CERCLA SECTION 120(h) REQUIREMENTS AND ASSURANCES A. In accordance with CERCLA Section 120(h)(1) and (3) and 40 Code of Federal Regulations Section 373, and based on a complete search of agency files, the GRANTOR provides notice that:

A contaminated groundwater plume has not been identified in the subsurface of the Former K-31 Building and Surrounding Area. Trichloroethene (TCE) has historically been detected above the maximum contaminant level (MCL) in the easternmost portion of the Property but has not been detected above the MCL in samples since 1998. Chromium has also been sporadically detected above the MCL in groundwater beneath the Property. The presence of TCE and chromium in groundwater is considered a release of a hazardous substance on the Property.

The deed (Condition 10) includes a prohibition for use of the groundwater, in any way, unless such use is approved in advance by the GRANTOR, the U.S. Environmental Protection Agency (EPA), and the Tennessee Department of Environment and Conservation (TDEC). Additional provisions are included to prevent inadvertent exposure to contaminated groundwater and/or any contamination that could possibly be present in the soils. Such provisions include requiring the GRANTEE to adhere to applicable Federal, State, and local laws with respect to any development of the Property (Condition 9). Further information on the nature and extent of groundwater contamination is contained in Section 4.3 of the Environmental Baseline Survey (EBS)

Report issued in September 2015, which is incorporated by reference into this Quitclaim Deed as Exhibit F. Said Report shall be placed within the permanent historical realty audit files of the U.S. Department of Energy-Oak Ridge Office (DOE-ORO), within the GRANTORs Oak Ridge Office Information Center, and within the GRANTEES realty records. The Oak Ridge Office of Environmental Management (OREM) plans to address the key sources to the contaminated groundwater plumes at the site to ensure protection of human health and the environment. The decision for groundwater will be made through the CERCLA process. The final Sitewide Record of Decision (ROD) will include groundwater and any needed remedial action to address contaminated groundwater in Zone 2.

B. The GRANTOR warrants that any additional response action found to be necessary after the date of transfer for contamination on the Property existing prior to the date of this transfer will be conducted by the United States. The obligation of the United States under this warranty will be limited to the extent that a response action is required by an act or omission of any GRANTEE which either a) introduces new contamination or b) increases the cost or scope of the required response action by negligently managing 33

any contamination present on the Property at the time of the initial transfer by the United States.

C. The GRANTOR reserves a right of access to all portions of the Property for environmental investigation, remediation, or other corrective action. In the event the GRANTOR must access the Property, the GRANTOR must provide notice to and coordinate access with the GRANTEE, or its successors, and any authorized occupants of the Property. Any such entry, including such activities, responses, or remedial actions, shall be coordinated with the GRANTEE or its successors, assignees, and tenants and shall be performed in a manner which minimizes, to the extent practicable, interruption with the GRANTEEs activities on the Property. The GRANTORs right to access the Property shall be exercisable in any case in which a response action or corrective action is found to be necessary by the GRANTOR, or applicable regulatory authority, after the date of conveyance of the Property, or in which the GRANTOR determines access is necessary to carry out a response action or corrective action on adjoining property. Pursuant to this reservation, the United States and its officers, agents, employees, contractors, and subcontractors shall have the right (upon reasonable notice to and coordination with the GRANTEE or the then-owner and any authorized occupant of the Property) at the direction of the GRANTOR to enter upon the Property and (1) conduct investigations and surveys, including but not limited to, sample collection, drilling, data and record compilation, and other activities related to environmental investigation; and (2) to carry out any other response and/or corrective actions as required or necessary under CERCLA and other applicable authorities, including but not limited to installation and operation of groundwater monitoring and/or restoration wells, and any treatment of hazardous substances or materials required under CERLCA and other applicable authorities.

D. The GRANTEE covenants that the Property shall not be used or developed in a manner inconsistent with the land use assumptions of industrial use contained in approved applicable RODs. The GRANTEE covenants that it will not at any time cause or allow any portion of the Property to be used for any residential housing, any elementary or secondary school, or any child care facility or childrens playground.

E. The GRANTEE covenants that it will not at any time cause or allow any other use or disturbance of any portion of the Property located more than 10 feet below ground surface level, without having first obtained authorization from DOEs Excavation/Penetration Permit Program.

F. The GRANTEE covenants that it will not inhibit or hinder the GRANTOR from required remedial investigations, response actions, or oversight activities including, but not limited to, properly constructing, upgrading, operating, maintaining, and monitoring any groundwater treatment facilities or groundwater monitoring on the Property or adjoining property. Further, the GRANTEE covenants that it will not tamper with or willfully destroy any monitoring wells or other monitoring or remediation systems that may be located in the vicinity of the Property.

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G. The GRANTOR shall submit on an annual basis, through established channels, appropriate budget requests to the Director of the Office of Management and Budget that adequately address those agreed upon schedules for investigation and completion of all necessary response actions required by the Federal Facility Agreement (FFA) until such time that all necessary remedial action has been taken. The actual amount available for such activities is subject to congressional authorizations and appropriations.

H. When all response actions necessary to protect human health and the environment with respect to any substance remaining on the Property on the date of transfer have been taken, the United States shall execute and deliver to the transferee an appropriate document containing a warranty that all such response actions have been taken.

I. After notice and coordination with the GRANTEE as set forth in Item C, above, any response actions taken by the GRANTOR will be in accordance with schedules developed and included in Appendix E and J of the FFA for the Oak Ridge Reservation, approved by the GRANTOR, Region 4 of the EPA, and TDEC. The GRANTOR will take all necessary action to remediate the East Tennessee Technology Park (ETTP),

including groundwater contamination where applicable. The schedule for completion of the remedial action activities addressing Zone 2 of the ETTP Heritage Center, and the groundwater (to be addressed in the final Sitewide ROD), is set forth in the following milestones which are subject to adjustment through amendment pursuant to Chapter XVIII, Scoping Work Priorities of the FFA:

Zone 2 Final Record of Decision Record of Decision - completed April 19, 2005 Completion of Remedial Actions - projected 2026 Final Sitewide Record of Decision Final Record of Decision - projected 2023 Completion of Remedial Actions - TBD 35

EXHIBIT F TO QUITCLAIM DEED ENVIRONMENTAL BASELINE SURVEY REPORT The Environmental Baseline Survey Report for the Former K-31 Area was issued in September 2015, by the GRANTOR. Said Report is incorporated by reference to this Quitclaim Deed as noted in Exhibit D, Paragraph A.

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7.0 Responsiveness Summary The Covenant Deferral Request (CDR) and Environmental Baseline Survey (EBS) were issued in draft form for regulator review on April 23, 2015. A written response was received from the Tennessee Department of Environment and Conservation (TDEC) on May 20, 2015. Comments were received from the U.S. Environmental Protection Agency (EPA) Region 4 on May 22, 2015. These comments and DOEs responses are presented below.

7.1 Regulator Comments EPA General Comments on Both the Covenant Deferral Request (CDR) and Attachment A [Environmental Baseline Survey (EBS)]

1. DOE should revisit the document numbers as the cover letter for the Fiscal Year 2007 Phased Construction Completion Report has the transmittal letter with document number DOE/OR/01-2823&D2 while the binder cover reflects DOE/OR/01-2723&D2.

DOE RESPONSE: The document number referenced in the CDR has been verified and is correct.

2. EBS, p. xiii. Please check and confirm the document references for all PCCRs. The approved Fiscal Year 2007 PCCR that includes Z2 EU-03 should be DOE/OR/01-2723&D2. Please make global changes in both the EBS and CDR documents, where applicable.

DOE RESPONSE: The references for the FY 2007 PCCR have been corrected to indicate the correct document version.

3. Please modify the document references to include DOE/OR/01-2317&D2, where Zone 2 exposure units include EU-02, Z2-07, Z2-09, and Z2-10. Please make global changes to both EBS and CDR.

DOE RESPONSE: The document has been revised to reference DOE/OR/01-2317&D2 includes EU-02, Z2-07, Z2-09, and Z2-10.

4. CDR Executive Summary, pp. x and xv. Include the following sentence after the current statements regarding updates to select PCCRs (i.e., Z2 2007 PCCR Addendum; Z2-04/05 PCCR Addendum; Z2-06 PCCR Addendum) after confirmatory sampling: The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Section XXI of the Federal Facility Agreement. Modify all portions of the CDR and EBS where these addenda are described.

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DOE RESPONSE: The suggested statement has been added to the appropriate locations within the CDR and EBS.

5. Where the document refers to implementing remediation contingent upon subsequent data collection, revise the statement, If contamination above ROD RLs were discovered, it would be remediated. Please change this statement to, If contamination above ROD RLs were discovered, it will be remediated on a schedule that is milestoned in FFA Appendix E and/or J. This was identified at the following locations and should be revised throughout the CDR and EBS:

a. Introduction, p. 4

b. Section 1.0, Property Description, pp. 8 and 9

c. Section 2.1, p. 13 DOE RESPONSE:1 The following statements, which reflect the process being implemented, will be added to the appropriate locations within the CDR and EBS.

If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J.

Specific Comments on the CDR

1. Page 1, Introduction, Paragraph 3. The document should discuss the DOE approach for evaluating previously approved NFA decisions in light of potential impact to soils surrounding the K-31 demolition.

DOE RESPONSE:1 The following text will be added to paragraph 3 of the Introduction. Confirmatory sampling will be conducted post-demolition and the results will be documented and submitted to the EPA and TDEC for review and approval in a Concurrence Form and an addendum to the appropriate PCCR.

Additionally, DOE has a policy that independent verification is also conducted at all exposure units (EUs) following the completion of all activities within the EU and prior to release of the property.

2. Page 1, Paragraph 4. Please modify the reference to EU Z2-06 Technical Memorandum (TM) as draft. Since all sampling information has not been submitted and the TM is an appendix to the PCCR (which has not yet been submitted), the reference to draft is more appropriate.

DOE RESPONSE: Draft has been added to the Technical Memorandum reference.

1 DOE response revised after the Public Review period based on further discussions with EPA on July 9, 2015.

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3. Page 4. At the top of the page, please insert and approved following the word documented when describing the future plans for submitting the PCCR.

DOE RESPONSE: The text for approval will be added after documented at the top of page 4.

4. Introduction, Ecological Impacts, p. 6. In the first full paragraph, please revise the second sentence to replace because an ETTP Sitewide ROD ... has not been approved, with because a final remedial action under an ETTP Sitewide ROD has not been taken.

DOE RESPONSE: The second sentence of the first full paragraph on page 6 has been revised as requested.

5. Page 6, Section 1.0. Please describe the DOE assessment of the exposure unit impacts to DOE activities associated with demolition of Building K-31 and other soon to be demolished structures following the approval of the PCCRs that address EU Z2-03, EU Z2-07, EU Z2-09, and EU Z2-10.

DOE RESPONSE:1 The following text will be added to page 6 of Section 1.0.

Confirmatory sampling will be conducted post-demolition in EUs Z2-03, Z2-05, Z2-06, and Z2-10 where demolition has occurred. Additionally, DOE has a policy that independent verification is also conducted at all EUs following completion of all activities and prior to release of the property.

Section 4.1 of the EBS addresses the documentation of post-demolition sampling, including additional text in response to communications with EPA and TDEC regarding the K-1206 Water Tank area in EU Z2-10.

6. Page 8, Paragraph 2. Please include a statement that the soils will be evaluated per the Zone 2 ROD and the evaluation will be submitted in a PCCR for approval.

DOE RESPONSE: Per Comment #4 the following sentence will be added at the end of this paragraph. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Section XXI of the FFA.

7. Page 8, Last Paragraph. Please identify the Technical Memorandum as draft.

DOE RESPONSE: Draft has been added to the reference for the Technical Memorandum.

8. Page 13 in Bullet 3. Please identify the Technical Memorandum as draft.

DOE RESPONSE: Draft has been added to the reference for the Technical Memorandum.

1 DOE response revised after the Public Review period based on further discussions with EPA on July 9, 2015.

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9. Page 17, Section 2.3. Please note that the PCCR for the K-33/K-31 Process Tie Lines has not been approved. However, based on the removal of the K-903 Pad, the DOE is expected to submit a revised document for this demolition project.

DOE RESPONSE: Comment noted.

10. Page 17, Section 2.3. Please add the Storm Water Pollution Prevention Plan as a work control document that assists in minimizing the release of hazardous substances during demolition.

DOE RESPONSE: The ETTP Storm Water Pollution Prevention Plan has been added as a potential work control document assisting with minimizing the release of hazardous substances during demolition to the text of Section 2.3.

11. Page 17, Section 4.0. Please clarify that the DVS process addresses soils only.

DOE RESPONSE: Clarification that the DVS process addresses soils only has been added to the text in Section 4.0.

12. Table 4.1. Please correct the title to reflect K-31 not K-33.

DOE RESPONSE: The title of Table 4.1 has been corrected.

13. Page 20, Section 4.0. Please insert the calculated CERCLA risk for the roving worker so this risk can be transparent.

DOE RESPONSE: The risk calculated from the roving worker risk screen has been added to the text of Section 4.0.

14. Page 20, Section 5.0. Please correct the reference to the Zone 2 ROD. The ROD is not an interim decision. Although, structured similar to the Zone 1 Interim ROD, the Zone 2 ROD is a final decision that reflects soils only and human health impacts.

DOE RESPONSE: Interim has been deleted from the Zone 2 ROD reference in Section 5.0.

15. Table 5.1. Please confirm the reference to the Former K-33 in the title as this appears to be confusing. Although, Building K-31 is included in the K-31/K-33 Area, the title of the table appears to be misleading. Also, please correct the reference to the Associated FFA sites as being within: the transfer footprint.

DOE RESPONSE: The title of Table 5.1 has been corrected to indicate K-31 not K-33. The fifth column header has been revised to Associated FFA sites within the transfer footprint.

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16. Deed, Exhibit D, p. 37. In paragraph I, the subheading Zone 2 Final Record of Decision is not consistent with the descriptor of lnterim in the title of the 4/19/2005 ROD.

DOE RESPONSE: Interim has been deleted from the reference to the Zone 2 ROD in the Deed Exhibit D.

17. Deed, Exhibit D, p. 37. In paragraph I, the listing of milestones should differentiate between actual events and projected milestones. Under Zone 1, it appears that the IROD was finalized on 11/8/02, as was the Zone 1 Final ROD on 5/8/15. This summary is therefore misleading.

DOE RESPONSE: The word projected or completed has been inserted before the dates indicated in the Deed Exhibit D for clarification.

18. Please provide the deed prior to the time of DOEs request for EPA concurrence in order to ensure inclusion of the necessary items in the deed. Once the deed has been recorded, please provide it to EPA in order to verify that any conditions necessary for EPA concurrence were included in the deed.

DOE RESPONSE: A copy of the draft deed will be included with the request for regulator approval of the CDR. The DOE Real Estate Contracting Officer will maintain a copy of the recorded deed, and make it available upon request.

Specific Comments on the EBS

1. Page xiv, Bullet 2. The approved PCCR identified 20 transformer vaults of which two (2) were sampled for sediment. However, the remaining vaults either contained no sediment or were inaccessible. The document should identify the DOE plans to gather information pertaining to the remaining vaults and specify which may contain sediments. The document also needs to identify the plans to evaluate those vaults previously identified as inaccessible. Please make this a global change in both the EBS and CDR documents, where applicable.

DOE RESPONSE: The sampling approach for EU Z2-03 was developed in accordance with the DQO process and conducted under the DVS. The results of the DVS sampling were presented and evaluated in the approved PCCR, which demonstrated NFA was appropriate for this EU.

2. Page xvii, Conclusions, Bullet 4. Please modify the text to more accurately reflect that it was not that TDEC nor EPA believed there was no need to sample beneath the buildings, the presence of the buildings were an obstacle to sampling under DVS approach and the buildings were identified in another CERCLA decision document.

Further, DOE chose not to sample beneath the buildings at the time of the soil DVS evaluation but wait until demolition and revisit the underlying soils. Please make this a global change in both the EBS and CDR.

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DOE RESPONSE: The text in the Conclusions, 4th bullet, will be revised as follows: The soils beneath K-761 and the K-903 Pad were not sampled under the DVS, due to their inaccessible nature, but they were included within the scope of the Phased Construction Completion Reports (PCCRs) for EUs Z2-03 (DOE 2008) and Z2-05 (DOE 2012). However, to ensure that no contamination above established Zone 2 remediation levels (RLs) remains, when removal of these structures is complete, the subsurface soils will be characterized during confirmatory sampling to ensure that the soils meet the Zone 2 Record of Decision (ROD) RLs.

3. Page xvii, Conclusions, Bullet 5. Please modify the reference to EU Z2-06 Technical Memorandum (TM) as draft. Since all sampling information has not been submitted and the TM is an appendix to the PCCR (which has not yet been submitted), the reference to draft is more appropriate.

DOE RESPONSE: Draft has been added to the reference for the Technical Memorandum.

4. Page 3-2. In the last paragraph, please modify the text to accurately describe the location of the appendices. The current text indicates that Appendix A is the location for all of the sampling results and data, which is not the case. Appendix A for Z2 EU-03 is actually in Appendix B of the approved PCCR.

DOE RESPONSE: Text of the last paragraph has been revised to indicate the correct PCCR Appendix for the location of the sampling results for the EUs in the transfer footprint.

5. Page 3-3, Table 3.1. Please review the reference to the K-762 Switchyards and K-762 Valve Vaults 1 and 2. The table indicates that these sites are outside the transfer footprint. The first two columns list both K-31 and K-33.

DOE RESPONSE: The fifth column header has been revised to Associated FFA sites within the transfer footprint, and the FFA sites not included in the transfer footprint have been deleted from this table.

6. Page 3-4, Paragraph 2. Please address and clarify the following. DOE did not sample under the K-761 because the DOE decision was to sample after demolition.

However, the K-903 Pad was not identified in the PCCR that included Z2 EU-04 and Z2 EU-05. This was identified and included in the scope of the K-33 Remedial Action PCCR. This issue is identified in the EPA letter dated December 31, 2013, which referenced the K-33/K-31 Process Tie Lines. DOE is preparing to modify the PCCR as the pad was in the fall zone of Building K-31.

DOE RESPONSE: The text in this paragraph will be revised to read as follows.

The soils beneath K-761 and the K-903 Pad were not sampled under the DVS, due to the inaccessible nature of the soils while these structures remained in-place, but they were included within the scope of the PCCRs for EUs Z2-03 (DOE 2008) and 44

Z2-05 (DOE 2012). Sampling locations for these EUs were established during DQOs workshops with EPA and TDEC approval. However, to ensure that no contamination above established Zone 2 remediation levels (RLs) remains, when removal of the K-903 Pad is complete, the subsurface soils will be characterized during confirmatory sampling to ensure that the soils meet the Zone 2 ROD RLs.

7. Page 3-6, Section 3.2.3. In paragraph 3, please add text that discusses the evaluation of actions associated with the lead paint chips associated with the demolition of the water tank. This matter was the subject of either a concurrence form or modification to a LRILC or PUF PCCR.

DOE RESPONSE:1 The following text will be added to the end of the third paragraph in this section: Paint chips dislodged during size reduction of the metal structure were collected, packaged, and disposed. Approximately 4 ft3 of lead-containing paint chips were collected following demolition and disposed at an off-site RCRA facility. The distribution of any remaining paint chips on the ground is consistent with historical sand blasting operations on the tank for re-coating performed prior to the DVS evaluation of EU Z2-10. Additionally, confirmatory samples were collected in June 2015, after this demolition action, and the results will be provided to the FFA parties for review and approval in a Concurrence Form. If appropriate, DOE will also document no change to NFA for EU Z2-10 in a Concurrence Form and an Addendum to the FY 2007 PCCR for Zone 2 (DOE 2008).

8. Page 4-2, K-903 Supercompactor. Have soils associated with the rail line been evaluated? If so, please include in description.

DOE RESPONSE: The soils associated with the rail line were included within the scope of the DVS evaluation of soils in EU Z2-05.

9. Page 4-4, Figure 4.3. Please include an appropriate after photo of the demolition of the process tie lines. Although full approval is pending, the picture in the EBS does not reflect the current state of the tie line project demolitions represented in the PCCR for the K-33/K-31 Process Tie Line Demolition Project (DOE/OR/01-2620&01).

DOE RESPONSE: An appropriate after photo for the K-33/K-31 Process Tie Lines has been added as Fig. 4-4 to Section 4.1 of the EBS.

10. Page 4-5, EU Z2-10. Please see comment above regarding the lead paint chips and impact on the exposure unit and the regulatory approval of the soils associated with the demolition.

1 DOE response revised after the Public Review period based on further discussions with EPA on July 9, 2015.

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DOE RESPONSE: The following text has been added to the EU Z2-10 discussion of Section 4.1. The demolition debris was size-reduced prior to disposal. Paint chips dislodged during size reduction of the metal structure were collected, packaged, and disposed at an off-site RCRA facility. The distribution of any remaining paint chips on the ground is consistent with historical sand blasting operations on the tank for re-coating performed prior to the DVS evaluation for EU Z2-10.

11. Page 4-6, EU Z2-03. The text is confusing regarding the acreage. Please clarify the acreage associated with the former K-31 and ensure that this reference is not meant to identify the K-33 footprint transfer.

DOE RESPONSE: Text in Section 4.2 has been revised as follows: The portion of EU Z2-03 that was included in the Former K-33 Area transfer footprint includes approximately 12.8 acres of the total 14.9 acres contained in the EU, with the remaining 2.1 acres included in the Former K-31 Area transfer footprint. The 12.8 adjacent acres were included in the Former K-33 Area EBS and CDR, and were primarily used for electrical power distribution associated with the former K-31 building.

12. Page 4-6, Former K-33 Building. Please clarify the sub-slab sampling conducted by DOE not associated with an approved concurrence form and the post slab removal sampling activities conducted to clear the exposure unit. Sub slab characterization was conducted prior to DOEs decision to demolish and sample following demolition. There needs to be a description of the distinction between the two data sets.

DOE RESPONSE: This section only presents a summary of the activities conducted within the property adjacent to the transfer footprint. Details of the K-33 characterization and confirmatory sampling are presented in the PCCR for EUs Z2-04 and Z2-05 and are summarized in the Former K-33 Area CDR/EBS.

13. Page 4-8, K-892 Pumphouse. Please describe the PCCR containing the RCW information regarding demolition.

DOE RESPONSE: Demolition of the K-892 Pumphouse will be described in the FY 2015 PCCR for Low Risk/Low Complexity Facilities of the Remaining Facilities Demolition Project.

14. Page 6-3, Paragraph 2, Last Sentence. Please insert and approved following the word documented. Please make this a global change where the reference to modifying a PCCR by submitting an addendum to an already approved PCCR (see General Comment #4 above).

DOE RESPONSE: In response to Comment #4 the following text will be added after the sentence containing documented in Section 6.1: The PCCR Addendum 46

will be submitted as a modification for formal review and approval in accordance with Section XXI of the FFA.

15. Page 6-3, Section 6.2. Please define RWS.

DOE RESPONSE: The definition of RWS has been added to the text in Section 6.2.

16. Page 6-4, Last Paragraph, Section 6.2. Please clarify that neither the CERCLA PCCR for D&D nor RA defined the K-903 as remaining in the exposure unit. Please refer to the approved RA PCCR and the EPA letter of December 31, 2013, associated with the Process Tie Lines.

DOE RESPONSE: Removal of the K-903 Pad is planned for summer 2015.

Additional discussion of the K-903 Pad has been added to the text of Section 6.2 as follows: Although not identified in the PCCR for EUs Z2-04 and Z2-05 (DOE 2012), this slab was used as a laydown area during removal of the process tie lines, and it is suspected that contamination was transferred to the slab from the process tie line removal activities. EPA identified the presence of the contaminated pad, and requested additional information on the monitoring activities for the pad, following review of the PCCR for the K-33/K-31 Process Tie Line Demolition Project (DOE 2014b) in their letter of December 31, 2013 (DOE 2013).

17. Page 6-14, Section 6.4. Please describe the DOE actions to ensure that demolition activities of Building K-31 did not impact EU Z2-07.

DOE RESPONSE: All demolition waste is staged within EU Z2-06 and no waste placed in Z2-07. Misting during demolition, routine air sampling, and sampling to support the ETTP Storm Water Pollution Prevention Plan are conducted to monitor the potential transport of contamination via these pathways. Independent verification will be conducted in EU Z2-07 after all demolition activities are completed.

18. Page 7-2, Table 7.1. See Specific Comment #5 above - confirm whether EU Z2-03 to include the K-762 Switchyard and K-762 Valve Vaults are a portion of the K-33 or K-31 transfer footprint.

DOE RESPONSE: See response to Comment #5 above.

19. Page 7-3, Last Bullet. See Specific Comment #2 above.

DOE RESPONSE: The text will be revised as follows: The soils beneath K-761 were not sampled under the DVS, due to their inaccessible nature beneath the building, but they were included within the scope of the PCCR for EU Z2-03.

However, to ensure that no contamination above established Zone 2 RLs remains, when demolition of K-761 is complete, the subsurface soils and/or exposed remaining structures, if any, will be characterized during confirmatory sampling to 47

ensure that the soils and/or subsurface structures, such as concrete subsurface foundation elements and electrical ducts, meet the Zone 2 ROD RLs.

20. Page 7-3, Last Bullet. Please insert and approved following the word documented. Please make this a global change where the reference to modifying a PCCR by submitting an addendum to an already approved PCCR (see General Comment #4 above).

DOE RESPONSE: In response to Comment #4, the following text will be added after the sentence containing documented: The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Section XXI of the FFA.

21. Page 7-5, Top of the Page. Please insert the calculated CERCLA risk for the roving worker scenario. Although the risk should be acceptable, the risk should be transparent.

DOE RESPONSE: The calculated risk for the roving worker has been added to the text of Section 7.

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TDEC General Comments:

1. The FY 2015 PCCR for EU Z2-06, that recommends an NFA for soils, will not be submitted for review until November 2015. Is it DOEs expectation that the CDR will be approved before that PCCR is reviewed and approved?

DOE RESPONSE: DOE anticipates that the K-31 CDR can be approved prior to final approval of the FY 2015 PCCR for EU Z2-06 as the CDR states that the property transfer is dependent upon DOE determining that the property is protective of human health and the environment. This protectiveness determination is obtained by meeting the Zone 2 RAOs as demonstrated in the evaluation for the EU in the Technical Memorandum, which is also the basis of the risk evaluation in the PCCR.

The draft Technical Memorandum has been provided to EPA and TDEC and will also be included with the PCCR when it is submitted.

2. The confirmatory sampling identified for K-903 (EU Z2-05) and K-761 (EU Z2-03) should be presented to the FFA parties for review and approval. These EUs have been previously approved for NFA in FY 2012 and FY 2007. Since ongoing demolition support activities have been conducted at these sites, the confirmatory sampling is necessary to ensure that the NFA determination is still valid.

DOE RESPONSE: 1 The confirmatory sampling identified for K-903 (EU Z2-05) and K-761 (EU Z2-03) will be presented to the FFA parties for review and approval in Concurrence Forms and the respective PCCR addenda.

Specific Comments:

CDR/EBS

1. K-761 - Throughout both documents, it says that confirmatory sampling will be done to ensure that the soils and/or subsurface structures meet the Zone 2 RLs. Clarify what subsurface structures will remain following demolition.

DOE RESPONSE: Appropriate text throughout both documents has been revised to read ensure that the soils and/or subsurface structures, such as concrete subsurface foundation elements and electrical ducts, meet the Zone 2 RLs.

2. K Throughout both documents, it says that confirmatory sampling will be done to ensure that the soils and subsurface structures meet the Zone 2 RLs. Clarify what subsurface structures will remain following demolition.

1 DOE response revised after the Public Review period based on further discussions with EPA on July 9, 2015.

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DOE RESPONSE: Appropriate text throughout both documents has been revised to read ensure that the soils and/or subsurface structures, such as concrete subsurface foundation elements and electrical ducts, meet the Zone 2 RLs.

CDR

1. Page 19, Table 4.1 - The title of this table should reference K-31, not K-33.

DOE RESPONSE: Title of Table 4.1 has been corrected.

2. Page 22, Table 5.1 - The title of this table should reference K-31, not K-33. Also, there is a typo in this table - K-8797-M should be K-897-M.

DOE RESPONSE: Title of Table 5.1 has been corrected, and the typo in the table has been corrected.

EBS

1. Page xv - The acreages listed for EU Z2-07 and EU Z2-10 is inconsistent with the acreages listed on Table 3.1.

DOE RESPONSE: Acreages for EU Z2-07 and EU Z2-10 on page xv have been corrected to be consistent with the acreages throughout the document.

2. Page 3-1, Section 3.1, 4th Paragraph - This says the map is included in Appendix A. It is actually in Appendix B.

DOE RESPONSE: The reference to Appendix A for the map has been corrected to Appendix B.

3. Page 3-3, Table 3.1 - There is a typo in the table. K-897-M is referred to as K-8797-M.

DOE RESPONSE: Typo in Table 3.1 has been corrected.

4. Page 4-1, Section 4.1, EU Z2 The text in this paragraph refers to EU Z2-01. I think it should be EU Z2-03.

DOE RESPONSE: The typo referring to EU Z2-01 has been corrected to EU Z2-03.

5. Page 4-1, Section 4.1, EU Z2 The K-761 Switch House and Building K-761 are both identified in EU Z2-03. Are these two separate buildings? If not, it should only be included once.

50

DOE RESPONSE: These references are to the same building. The discussion on page 4-1 has been revised to include only one reference to the K-761 Switch House.

6. Page 4-3, Section 4.1, EU Z2-05, K-903 Supercompactor, Last Paragraph - The last sentence says, The concrete foundation pad remains and was decontaminated and surveyed prior to demobilization of the Three-building D&D project. Please summarize the survey results. Confirm that decontamination of the slab was conducted. Also, I think this statement is kind of misleading, since the slab still has contamination remaining and is posted as a CA. Also, identify any additional history of the slab associated with supporting subsequent D&D activities.

DOE RESPONSE: The text has been revised to the following: The concrete foundation pad remains and was used as a laydown area during removal of the process tie lines conducted in 2013. It is suspected that contamination was transferred to the slab from the process tie line removal activities. EPA identified the presence of the contaminated pad and requested additional information on the monitoring activities for the pad following review of the PCCR for the K-33/K-31 Process Tie Line Demolition Project (DOE 2014b) in their letter of December 31, 2013 (DOE 2013).

7. Page 4-4, Section 4.1, EU Z2-06, K-31 Recirculating Cooling Water Lines - Are the RCW lines included in the NFA determination for EU Z2-06? The final state of the RCW (whether free release or isolation) should be identified in the FY 2015 PCCR for Z2-06.

DOE RESPONSE: The RCW lines for the entire transfer footprint have been determined to be free releasable. This section has been revised to reflect the updated status of the RCW lines.

8. Page 4-6, Section 4.1, EU Z2-10, K-1206-F Fire Water Tank - Identify what actions were taken to verify that demo of K-1206-F in 2013 did not impact the NFA determination made in 2007.

DOE RESPONSE: Additional text has been added to Section 4.1 to describe the collection and disposal of paint chips from the tank and the evaluation of the potential impacts to the NFA decision.

9. Page 4-6, Section 4.2, EU Z2 The first sentence says, Approximately 11.7 acres of the total 29.7 acres of EU Z2-02 are located within the Former K-31 Area proposed transfer footprint. I think this should say that the 11.7 acres is in the Former K-33 Area transfer. Transfer of any portion of EU Z2-02 is not mentioned elsewhere in the document (including Figure 1.5 or Table 3.1).

DOE RESPONSE: The text in Section 4.2 for EU Z2-02 has been corrected to indicate the 11.7 acres are in the Former K-33 Area transfer footprint.

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10. Page 4-6, Section 4.2, EU Z2-02, Former K-792 Switchyard - The last sentence says, The activities conducted in the balance of the EU, which has been transferred, are described in Sect. 4.2. This is Section 4.2. Correct the reference.

DOE RESPONSE: This sentence has been deleted in its entirety as the activities conducted in the Former K-792 Switchyard are discussed within this paragraph.

11. Page 4-7, Section 4.2, EU Z2-03, Former K-762 Switchyard - The last sentence says, The activities conducted in the balance of the EU, which has been transferred, are described in Sect. 4.2. This is Section 4.2. Correct the reference.

DOE RESPONSE: This sentence has been deleted in its entirety as the activities conducted in the Former K-762 Switchyard are discussed within this paragraph.

12. Page 4-8, EU Z2-08, K-892 Pumphouse, Last Paragraph - The last sentence says, Prior to transfer, any accessible portions of the RCW lines remaining in-place will be evaluated to ensure they meet the free release criteria of DOE Order 458.1 for residual radioactive materials or alternatively, the lines will be isolated through engineered controls to eliminate the potential exposure pathway. EU Z2-08 has already been transferred as part of the K-33 Area transfer. Correct the statement.

Include information about whether the RCW lines met the free release criteria or if they were isolated through engineered controls.

DOE RESPONSE: This statement has been revised as follows to indicate the current status of the RCW lines: The accessible RCW lines have been filled to eliminate any potential exposure pathway and meet the free release criteria.

13. Page 7-3, Section 7.0, 2nd Bullet - Therefore, it is concluded that the operating floor of Bldg. K-31 in EU Z2-06 will not cause the EU to exceed the risk limits of the Zone 2 ROD. Explain the significance of the K-31 operating floor, since it will be removed prior to transfer.

DOE RESPONSE: This statement is from the draft PCCR which was prepared prior to the decision to remove the pad. This bullet has been revised to indicate that the K-31 concrete pad will be removed; thus, there will be no risk associated with the pad.

14. Page 7-3, Section 7.0, 3rd Bullet - The portion EU Z2-03 that has not been included in the K-33 transfer footprint contains three sample locations collected under the DVS. Earlier in the document (Section 6.1), six sample locations are identified for the portion of EU Z2-03 that has not been included in the K-33 transfer footprint. Confirm the number of samples.

DOE RESPONSE: The correct number of samples collected under the DVS from EU Z2-03 is 6. The reference to three samples on page 7-3 has been corrected to six.

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7.2 Public Comments The CDR package was available for public review from June 8, 2015, to July 8, 2015, and the availability of the documents for review was announced in three area newspapers and in the online version of one paper. No public comments were received.

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DOE/OR/01-2677 FINAL - CONCURRED ATTACHMENT A Environmental Baseline Survey Report for the Proposed Title Transfer of the Former K-31 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee 14-060(E)/092815

LEIDOS [formerly part of SCIENCE APPLICATIONS INTERNATIONAL CORPORATION (SAIC)]

contributed to the preparation of this document and should not be considered an eligible contractor for its review.14-060(E)/092815

DOE/OR/01-2677 FINAL - CONCURRED Environmental Baseline Survey Report for the Proposed Title Transfer of the Former K-31 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee Date IssuedSeptember 2015 Prepared by Leidos Oak Ridge, Tennessee under subcontract 30492-BA-RR011 under work release 0034 Prepared for the U.S. Department of Energy Office of Environmental Management URS l CH2M Oak Ridge LLC Managing and Safely Delivering the Department of Energys Vision for the East Tennessee Technology Park Mission under contract DE-SC-0004645 14-060(E)/092815

This report has been prepared by Leidos (formerly part of Science Applications International Corporation [SAIC]) for the sole and exclusive use of URS l CH2M Oak Ridge LLC (UCOR) and the U.S. Department of Energy. Any other person or entity obtaining, using, or relying on this report hereby acknowledges that they do so at their own risk, and that Leidos shall have no responsibility or liability for the consequences thereof. This report is prepared by Leidos in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) 120(h)(1) and (3)(C) requirements.

This report is intended to be used in its entirety. Excerpts, which are taken out-of-context, run the risk of being misinterpreted and are, therefore, not representative of the findings of this assessment.

Opinions and recommendations presented in this report apply only to site conditions and features as they existed at the time of the site visit, and those inferred from information observed or available at that time, and cannot be applied to conditions and features of which Leidos is unaware and has not had the opportunity to evaluate.

The results of this report are based on record reviews, site reconnaissance, interviews, and the radiological report reviewed and approved by UCOR. Leidos has not made, nor has it been asked to make, any independent investigation concerning the accuracy, reliability, or completeness of such information.

All sources of information on which Leidos has relied in making its conclusions are identified in Chap. 8 of this report. Any information, regardless of its source, not listed in Chap. 8 has not been evaluated or relied upon by Leidos in the context of this report.14-060(E)/092815 v

CONTENTS FIGURES ..................................................................................................................................................... ix TABLES ...................................................................................................................................................... ix ABBREVIATIONS ..................................................................................................................................... xi EXECUTIVE

SUMMARY

....................................................................................................................... xiii CONCLUSIONS....................................................................................................................................... xvii

1. PROPERTY IDENTIFICATION ...................................................................................................... 1-1

2. TITLE SEARCH................................................................................................................................ 2-1

3. FEDERAL RECORDS SEARCH AND COMPLIANCE

SUMMARY

........................................... 3-1 3.1 FEDERAL RECORDS SEARCH ........................................................................................... 3-1 3.2 REGULATORY

SUMMARY

................................................................................................. 3-2 3.2.1 Background................................................................................................................... 3-2 3.2.2 The EM DVS Protocol and Former K-31 Area ............................................................ 3-5 3.2.3 Actions Taken Within the Former K-31 Area EBS Study Area Exposure Units ......... 3-6

4. PAST AND PRESENT ACTIVITIES ............................................................................................... 4-1 4.1 PAST AND PRESENT ACTIVITIES FOR THE REAL PROPERTY PROPOSED FOR TRANSFER .................................................................................................................... 4-1 4.2 PAST AND PRESENT ACTIVITIES FOR THE ADJACENT PROPERTY ........................ 4-6 4.3 HYDROGEOLOGIC ENVIRONMENT ............................................................................... 4-10

5. RESULTS OF VISUAL AND PHYSICAL INSPECTIONS ............................................................ 5-1 5.1 VISUAL AND PHYSICAL INSPECTIONS OF THE PROPERTY TO BE TRANSFERRED ..................................................................................................................... 5-1 5.2 VISUAL AND PHYSICAL INSPECTION OF ADJACENT PROPERTY ........................... 5-1

6. SAMPLING RESULTS ..................................................................................................................... 6-1 6.1 DATA FOR EU Z2-03 ............................................................................................................. 6-1 6.2 DATA FOR EU Z2-05 ............................................................................................................. 6-3 6.3 DATA FOR EU Z2-06 ............................................................................................................. 6-4 6.4 DATA FOR EU Z2-07 ........................................................................................................... 6-14 6.5 DATA FOR EU Z2-10 ........................................................................................................... 6-14

7. RISK EVALUATION ....................................................................................................................... 7-1

8. REFERENCES .................................................................................................................................. 8-1 14-060(E)/092815 vii

APPENDIX A REAL ESTATE LETTER .......................................................................................... A-1 APPENDIX B STUDY AREA MAP FROM RECORDS SEARCH ................................................. B-1 APPENDIX C PCCR APPROVAL LETTERS ................................................................................. C-1 14-060(E)/092815 viii

FIGURES Fig. 1.1. Location of the proposed Former K-31 Area transfer footprint within the Heritage Center. ...... 1-2 Fig. 1.2. Proposed Former K-31 Area transfer footprint and EU boundaries. ........................................... 1-3 Fig. 1.3. Former K-31 Area, circa 1952. .................................................................................................... 1-4 Fig. 1.4. Former K-31 Area, circa 2000. .................................................................................................... 1-5 Fig. 1.5. Aerial photograph of the Former K-31 Area footprint and EU boundaries, circa 2013. ............. 1-6 Fig. 3.1. Demolition of the K-1206-F Water Tower, August 2013. .......................................................... 3-7 Fig. 3.2. K-1206-F Water Tower after demolition. .................................................................................... 3-7 Fig. 4.1. Rail spur leading up to the former Supercompactor vehicle loading bay. ................................... 4-2 Fig. 4.2. K-31 building with transite panels removed, September 2014 (EU Z2-06). ............................... 4-3 Fig. 4.3. K-31/K-33 process tie line structure (EU Z2-06). ....................................................................... 4-4 Fig. 4.4. K-31/K-33 process tie line end state along north side of Bldg. K-31 (EU Z2-06). ..................... 4-4 Fig. 4.5. Transportable vitrification system located south of the K-31 building. ...................................... 4-5 Fig. 4.6. Geologic map of the K-31 and surrounding area EBS study area. ............................................ 4-11 Fig. 5.1. Demolition of K-31 building, December 2014 (EUs Z2-05 and Z2-06). .................................... 5-1 Fig. 5.2. Former K-33 building footprint condition looking south (former K-31 building in background) [EUs Z2-04 and Z2-05]............................................................................................ 5-2 Fig. 5.3. K-861 Cooling Tower Basin before fill (EU Z2-09). .................................................................. 5-3 Fig. 5.4. K-861 Cooling Tower Basin after fill (EU Z2-09). ..................................................................... 5-3 Fig. 6.1. DVS sample locations in the Former K-31 Area transfer footprint. ............................................ 6-2 Fig. 7.1. Aerial view of north side of K-31 building prior to demolition. ................................................. 7-4 TABLES Table 3.1. Summary of CERCLA decisions for the Zone 2 EUs addressed in this EBS........................... 3-3 Table 4.1. Summary of hydrogeologic conditions at the K-31 study area ............................................... 4-12 Table 6.1. Data summary for EU Z2-06 (K-31) sub-slab soil samples (0 to 10 ft) ................................... 6-7 Table 6.2. Data summary for EU Z2-06 (K-31) concrete samples .......................................................... 6-11 Table 7.1. Risk evaluation results for the Former K-31 Area .................................................................... 7-2 14-060(E)/092815 ix

ABBREVIATIONS Avg average bgs below ground surface CDR Covenant Deferral Request CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 CNF Central Neutralization Facility COC contaminant of concern COE U.S. Army Corps of Engineers D&D decontamination and decommissioning DCE dichloroethene DOE U.S. Department of Energy DQO data quality objective DVS Dynamic Verification Strategy EA Environmental Assessment EBS Environmental Baseline Survey ELCR excess lifetime cancer risk EM Environmental Management EPA U.S. Environmental Protection Agency ETTP East Tennessee Technology Park EU exposure unit FFA Federal Facility Agreement FY fiscal year HI hazard index IV independent verification LLW low-level waste Max maximum MCL maximum contaminant level NCP National Contingency Plan NFA no further action NFI no further investigation ORAU Oak Ridge Associated Universities OREIS Oak Ridge Environmental Information System ORGDP Oak Ridge Gaseous Diffusion Plant ORO Oak Ridge Office ORR Oak Ridge Reservation PCB polychlorinated biphenyl PCCR Phased Construction Completion Report pCi/g picocuries per gram PCP pentachlorophenol PRG preliminary remediation goal RAO remedial action objective RCRA Resource Conservation and Recovery Act of 1976 RCW recirculating cooling water RL remediation level ROD Record of Decision RSL risk screening level SAIC Science Applications International Corporation SU soil unit SVOC semivolatile organic compound 14-060(E)/092815 xi

Tc technetium TCE trichloroethene TDEC Tennessee Department of Environment and Conservation TVA Tennessee Valley Authority TVS Transportable Vitrification System UCOR URS l CH2M Oak Ridge LLC UF6 uranium hexafluoride VOC volatile organic compound

µg/L micrograms per liter 14-060(E)/092815 xii

EXECUTIVE

SUMMARY

This environmental baseline survey (EBS) report documents the baseline environmental conditions at the U.S. Department of Energys (DOEs) Former K-31 Area, hereafter also referred to as the Property, consisting of approximately 61 acres located at the East Tennessee Technology Park (ETTP) Heritage Center (Heritage Center). DOE is proposing to transfer the title of this land for mixed (industrial/commercial) use, consistent with the applicable Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) Records of Decision (RODs) and the Environmental Assessment completed pursuant to the National Environmental Policy Act. This EBS provides a summary of information to support the transfer of this government-owned property at the Heritage Center to a non-federal entity under the requirements of Sect. 120(h) of CERCLA. More specifically, the goal is to obtain a covenant deferral under CERCLA Sect. 120(h)(3)(C).

This EBS for the Former K-31 Area relies upon documentation in the four relevant Phased Construction Completion Reports (PCCRs) for the environmental data evaluation and human health risk evaluation. It summarizes no further action (NFA) determinations that have been approved by the U.S. Environmental Protection Agency (EPA) Region 4 and Tennessee Department of Environment and Conservation (TDEC) for the soils, slabs, and subsurface structures of the Former K-31 Area. The PCCRs used for source information for the proposed transfer are:

Fiscal Year 2006 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2317&D2),

December 2006 (approved) [DOE 2006] (addresses Exposure Units [EUs] Z2-02, Z2-07, Z2-09, and Z2-10).

Fiscal Year 2007 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2723&D2),

September 2007 (approved) [DOE 2008] (addresses EUs Z2-01, Z2-03, and Z2-08).

Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2590&D1), November 2012 (approved) [DOE 2012].

Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-XXXX), 2015 (in-preparation) [DOE 2015]

(addresses EU Z2-06) [NFA recommended, D1 version to EPA and TDEC in November 2015 (planned)].

The NFA determinations under an industrial land use risk scenario documented in the referenced PCCRs were reached using the Environmental Management (EM) Programs Dynamic Verification Strategy (DVS) process [Remedial Design Report/Remedial Action Work Plan for Zone 2 Soils, Slabs, and Subsurface Structures, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2224&D2 (DOE 2007b)], a process designed to facilitate real-time decision-making. This process is in use for remedial action decision-making across the Heritage Center, which has been divided into Zone 1 and Zone 2 and further subdivided into Geographic Areas, then Groups, then EUs. For consistency with the EM nomenclature, this EBS will use the EU as the basis for discussion.

All of the acreage addressed in this EBS (approximately 61 acres) is contained within Zone 2 and includes three Zone 2 EUs in their entirety: Z2-06 (approximately 25.6 acres), Z2-07 (approximately 10.9 acres), and Z2-10 (approximately 20.9 acres). Portions of EUs Z2-03 and Z2-05 were excluded from 14-060(E)/092815 xiii

the K-33 Area Covenant Deferral Request (CDR) and EBS and are included in this K-31 Area CDR and EBS because these portions were needed, at the time, to support the K-31 Building Decontamination and Decommissioning (D&D) project. The transfer footprint portions included in this proposed transfer are 2.1 acres of EU Z2-03 and 1.6 acres of EU Z2-05. For purposes of the Former K-31 Area EBS, information is presented on the land proposed for transfer in its entirety. However, in order to provide context and a tie-in with the status of the EUs, this EBS provides regulatory details for the relevant EUs or partial EUs in Chap. 3 and the results of the risk evaluation in Chap. 7.

The primary objective of the remediation measures presented in the Zone 2 ROD is to protect industrial workers from exposure to hazardous substances. The institutional controls restricting property use of the Heritage Center to a mixed-use commercial and industrial park, and the limited potential for off-site migration of contaminants, limit the potential for exposure to other individuals. Therefore, remediation criteria were designed for the protection of the future industrial worker. Accordingly, land use controls have been established to control excavations or soil penetrations below 10 feet and to restrict future land use to industrial/commercial activities.

The DVS process included a detailed records search, which included Federal Government records and title documents. That search has been relied upon for this report. The DVS process and the preparation of this report evaluated aerial photographs that may reflect prior uses, visual and physical inspections of the Property and adjacent properties, and interviews with current and former employees involved in the operations on the real Property to identify any areas on the Property where hazardous substances and petroleum products, or their derivatives, and acutely hazardous wastes were stored for one year or more, known to have been released, or disposed of. The following is a summary of the findings of the evaluation that was performed:

The results of the DVS evaluation for EUs Z2-03, Z2-05, Z2-06, Z2-07, and Z2-10, in which the Former K-31 Area EBS footprint is located, show that the EUs met the requirements specified for an NFA determination for soils under an industrial land use risk scenario.

EU Z2-03, which is only partially included in the transfer footprint, included five field test kit sample results for polychlorinated biphenyls (PCBs), and one sediment sample from the K-897-M Oil Containment Structure within the K-31 transfer footprint. There were no detections of PCBs in the field test kit results. Evaluation of the field test results against laboratory results during the DVS found that there was good correlation between the field test kit results and laboratory results. The sediment sample from K-897-M contained four semivolatile organic compounds and PCB-1260 at concentrations below remediation levels (RLs) and residential preliminary remediation goals (PRGs). Because the highest chemical and radiological concentrations detected in soils in EU Z2-03 were detected in the portion of the EU that is not included in the K-31 transfer footprint area, the findings of NFA in the PCCR are also appropriate for the portion of the EU included in the Former K-31 Area transfer footprint. The results of the confirmatory sampling identified for EU Z2-03, and any necessary remediation, will be documented in a Concurrence Form and the Fiscal Year 2007 PCCR Addendum for Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the Federal Facility Agreement (FFA).

Because the soil and slab underlying the K-761 Switch House is part of an EU with an approved NFA determination, the land underlying this structure is included in the transfer footprint of this EBS/CDR. The soils beneath K-761 were not sampled under the DVS, due to their inaccessible nature beneath the building, but they were included within the scope of the PCCR for EU Z2-03.

However, to ensure that no contamination above established Zone 2 RLs remains, when demolition of K-761 is complete, the subsurface soils and/or exposed remaining structures, if any, will be characterized during confirmatory sampling to ensure that the soils and/or subsurface structures, such 14-060(E)/092815 xiv

as concrete subsurface foundation elements and electrical ducts, meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the Fiscal Year 2007 PCCR Addendum for Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the FFA.

EU Z2-05, which is only partially included in the transfer footprint, included sampling of soil around the outside of the former K-33 building, prior to demolition of the building; sampling of soil through the concrete slab prior to slab removal; and sampling of the underlying soil following removal of the slab. Soil samples collected from EU Z2-05 at the completion of decontamination and decommissioning (D&D) and remediation activities indicated the soils in EU Z2-05 met the requirements of the Zone 2 ROD for NFA. The portion of the EU (~ 1.6 acres) that was not included in the Former K-33 Area transfer footprint contains little exposed soils, as the area is essentially covered by concrete and asphalt. Thus, the findings of NFA for the entire EU Z2-05 are appropriate for the narrow strip of EU Z2-05 included in the Former K-31 Area transfer footprint.

The K-903 concrete slab is posted as containing fixed radiological contamination. The K-903 slab will be removed prior to transfer of the Former K-31 Area. Because the soil underlying the K-903 Pad is part of an EU with an approved NFA determination, the land underlying this structure is included in the transfer footprint of this EBS/CDR. The soils beneath the K-903 Pad were not sampled under the DVS, due to their inaccessible nature beneath the pad, but they were included within the scope of the PCCR for EU Z2-05. However, to ensure that no contamination above established Zone 2 RLs remains, when removal of the K-903 Pad is complete, the subsurface soils will be characterized during confirmatory sampling to ensure that the soils meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until K-903 Pad removal, confirmatory soil sampling, and soil remedial actions, if any, are completed.

The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the PCCR Addendum for EUs Z2-04 and Z2-05 in Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the FFA.

EU Z2-06: A PCCR is being prepared with an NFA recommendation for this EU. The data used in this EBS are the same data used in the risk evaluation for the PCCR. DVS sampling of EU Z2-06 included a total of 54 samples of the soils underlying the K-31 slab. No contamination above average or maximum RLs was detected in these below-slab soil samples. An NFA determination has been recommended in the draft Technical Memorandum that was provided to EPA in March 2015. As an additional measure for ensuring that no contamination above established Zone 2 RLs remains when demolition of K-31 and its slab is completed, the subsurface soils and structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and subsurface structures meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be 14-060(E)/092815 xv

documented in a Concurrence Form and the EU Z2-06 PCCR. The PCCR will be submitted for formal review and approval in accordance with Sect. XXI of the FFA.

EU Z2-07: This EU is south of the K-31 building and is 10.9 acres in size. EU Z2-07 was the location of the K-897-E and K-897-F oil containment structures. There are 18 sample locations in EU Z2-07, with 15 of the samples collected at depths of 0 to 3 ft below ground surface (bgs). The remaining three samples were composited over the 0 to 10 ft bgs interval at three locations. There were no maximum or average RL exceedances.

EU Z2-10: This EU is southeast of the K-31 building and is approximately 20.9 acres in size. The only Federal Facility Agreement site is the K-897-G oil containment structure. There were seven sample locations in EU Z2-10, with all samples collected at depths of 0 to 1 ft bgs. There were no maximum or average RL exceedances.

An evaluation of the adjacent land did not indicate a risk posed by the adjacent areas.14-060(E)/092815 xvi

CONCLUSIONS Based on the U.S. Department of Energys (DOEs) review of the existing information, including discussions and interviews referenced herein, and evaluation of the data gathered in preparation of the environmental baseline survey for the Former K-31 Area, DOE recommends the following:

Because of the uncertainty associated with the nature of the on-site groundwater and the need to evaluate and possibly address groundwater in the future, DOE recommends that the transfer of the Former K-31 Area be achieved by a covenant deferral per the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) Sect. 120(h)(3)(C).

Based on the results of the Dynamic Verification Strategy (DVS) evaluation and the remedial actions completed, soils in the five Exposure Units included in the transfer footprint have been approved by the regulatory agencies (see Appendix C) for industrial use. Therefore, the soils in the Property are safe for industrial use and are suitable for transfer.

The K-31 building, the K-761 Switch House, and the K-903 Pad (see Fig. 1.2) will be demolished before the underlying land is transferred.

The soil and slab underlying Bldg. K-761 and the K-903 Pad are part of an exposure unit (EU) with an approved no further action (NFA) determination;, hence, the land underlying these structures is included in the transfer footprint of this Environmental Baseline Survey (EBS)/Covenant Deferral Request (CDR), including the land underlying these structures. The soils beneath K-761 and the K-903 Pad were not sampled under the DVS, due to their inaccessible nature, but they were included within the scope of the Phased Construction Completion Reports (PCCRs) for EUs Z2-03 (DOE 2008) and Z2-05 (DOE 2012). However, to ensure that no contamination above established Zone 2 remediation levels (RLs) remains, when removal of these structures is complete, the subsurface soils will be characterized during confirmatory sampling to ensure that the soils meet the Zone 2 Record of Decision (ROD) RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in Federal Facility Agreement (FFA) Appendix E and/or J. The underlying land will not be transferred until K-903 Pad removal, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the PCCR Addendum for EUs Z2-04 and Z2-05 in Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the FFA. Likewise, when demolition of K-761 is complete, the subsurface soils and/or exposed remaining structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and/or subsurface structures, such as concrete subsurface foundation elements and electrical ducts, meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the Fiscal Year 2007 PCCR Addendum for Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the FFA.14-060(E)/092815 xvii

DVS sampling of EU Z2-06, including 54 samples of the soils underlying the K-31 slab, detected no contamination above average or maximum RLs. An NFA determination has been recommended in the draft Technical Memorandum that was provided to the U.S. Environmental Protection Agency (EPA) in March 2015; hence, the land underlying the K-31 building is included in the transfer footprint of this EBS. As an additional measure for ensuring that no contamination above established Zone 2 RLs remains when demolition of these structures is completed, the subsurface soils and structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and subsurface structures meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the EU Z2-06 PCCR for Zone

2. The PCCR will be submitted for formal review and approval in accordance with Sect. XXI of the FFA.

LAND USE RESTRICTIONS Land use restrictions are an important component of a CERCLA covenant deferral; they help to ensure that transfer of the Property is protective for the intended use. The restrictions that will apply to the Former K-31 Area are summarized below. Full details are found in Sect. 6.1 of the Covenant Deferral Request.

1. The Property shall not be developed in a manner that is inconsistent with the land use assumptions of industrial use contained in the approved applicable ROD for Zone 2 [Record of Decision for Soil, Buried Waste, and Subsurface Structure Actions in Zone 2 of East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2161&D2 (DOE 2005)].

2. Development of the Property must comply with all applicable federal, state, and local laws and regulations with respect to any present or future development of the Property.

3. All structures, facilities, and improvements requiring a water supply shall be required to be connected to an approved water system for any and all usage. Extraction, consumption, exposure, or use, in any way, of the groundwater underlying the Property is prohibited without the prior written approval of DOE, EPA, and the Tennessee Department of Environment and Conservation (TDEC).

4. Disturbance of any portion of the Property deeper than 10 ft bgs without prior authorization from DOE is prohibited.

5. In order to ensure that the migration of volatile organic compounds (VOCs) in contaminated groundwater does not contribute to an unacceptable risk to human health, DOE will address the potential for vapor intrusion in the East Tennessee Technology Park final Sitewide ROD, which is currently scheduled to be signed in 2022, and will take interim protective measures to ensure protectiveness until the ROD is signed. Any new building or structure built on the Property that is intended to be occupied by workers 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or more per scheduled work day, or by public visitors, must be designed and constructed to minimize potential exposure to VOC vapors, using EPA/625/R-92/016 (June 1994), Radon Prevention in the Design and Construction of Schools and Other Large Buildings, as guidance.14-060(E)/092815 xviii

6. DOE reserves the right of access to all portions of the Property for environmental investigation, remediation, or other corrective action.

RESPONSE TO REGULATOR COMMENTS The CDR and EBS were issued in draft form for regulator review on April 23, 2015. Comments were received from EPA Region 4 on May 22, 2015. Comments were received from TDEC on May 20, 2015.

EPA requested clarification on the NFA status of EUs where demolition activities have been conducted, clarification that PCCR addenda would be submitted for review and approval, clarification on the history of the K-903 Pad, clarification on the decision to wait until demolition was completed before sampling beneath buildings and pads, and clarification on the actions taken post-demolition of the K-1206 Water Tank. EPA also requested to receive a copy of the deed, and correction of various typographical errors.

TDEC also requested clarification on the status of NFA for EUs where demolition activities have been conducted, clarification on the history of the K-903 Pad, clarification on the status of the recirculating cooling water lines, clarification on what actions were taken for the paint chips from demolition of the K-1206 Water Tank, clarification on what subsurface structures will remain at the buildings being demolished, and correction of typographical errors.

Comments received from EPA and TDEC, and DOEs responses, are included in the CDR in Sect. 7.1.

Comments received have been incorporated into the CDR and EBS.

RESPONSE TO PUBLIC COMMENTS The CDR and EBS were available for public review from June 8, 2015, until July 8, 2015, and the availability of the documents for review was announced in three area newspapers and in the online version for one of those papers. No public comments were received.14-060(E)/092815 xix

1. PROPERTY IDENTIFICATION This environmental baseline survey (EBS) report documents the baseline environmental conditions for the Former K-31 Area transfer footprint. The U.S. Department of Energy (DOE) is proposing to transfer this property for mixed (industrial/commercial) use, pursuant with the applicable Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) Records of Decision (RODs) and the Environmental Assessment (EA) completed pursuant to the National Environmental Policy Act (DOE 2003). The Property is composed of a single contiguous tract of land totaling 61.01 acres. The transfer footprint is located in the far northwestern portion of the East Tennessee Technology Park (ETTP) [formerly the Oak Ridge Gaseous Diffusion Plant (ORGDP) or K-25 Site]

Heritage Center on the Oak Ridge Reservation (ORR) in Roane County, Tennessee.

The Former K-31 Area transfer footprint is bounded by the former K-762 Switchyard (Z2-03) and vacant land (Exposure Unit [EU] Z1-46) to the west; the Former K-33 Area to the north (EUs Z2-02, Z2-05, Z2-08, and Z2-09); and Poplar Creek to the east and south. The transfer footprint includes the land on which Bldg. K-31 was located, which includes EU Z2-06 and the southernmost portion of EU Z2-05, which served as a buffer and work area for the decontamination and decommissioning (D&D) of the K-31 building, and was not included in the Former K-33 Area transfer footprint (DOE 2014).

Figure 1.1 shows the location of the study area at the Heritage Center, and Fig. 1.2 shows the proposed transfer footprint. Figure 1.3 provides an aerial photograph of the K-31 area in 1952, and Fig. 1.4 provides an aerial photograph of the study area in 2000.

Figure 1.2 indicates the boundary of the proposed transfer footprint and the boundaries of the EUs Z2-03, Z2-05, Z2-06, Z2-07, and Z2-10 in which the proposed transfer footprint is located. DOE received regulatory concurrence for no further action (NFA) determinations for soil under an industrial land use risk scenario for Z2-03 in 2008; EUs Z2-07 and Z2-10 in 2007; and EU Z2-05 in 2013. NFA concurrence has been recommended for EU Z2-06, which meets the requirements for NFA for soils and subsurface structures as required under the Zone 2 ROD.

Preparation of this report relied on the Phased Construction Completion Reports (PCCRs) that discuss the transfer footprint area and included a detailed search of government records and title documents for the area. Preparation of this report and the relevant PCCRs included reviews of historic aerial photographs that may reflect prior uses; visual and physical inspections of the Property and adjacent properties; and interviews with current and former employees involved in the operations on the real property to identify any areas on the Property where hazardous substances and petroleum products, or their derivatives, were known to have been stored, released, or disposed.14-060(E)/092815 1-1

FORMER K-31 AREA LEGEND:

EAST TENNESSEE TECKNOLOGY PARK OAK RIDGE, TENNESSEE Fig. 1.1. Location of the proposed Former K-31 Area transfer footprint within the Heritage Center.

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Z1-59 Z1-63 Z1-68 Z1-58 Z2-01 Z2-16 K-891 Z1-57 K-892-Y C AR PL PO Z2-04 EK RE Z2-02 Z2-17 K-792 K-892 Z1-54 FORMER K-33 Z2-08 BUILDING Z1-52 Z2-05 Z1-51 Z1-50 Z2-09 FORMER K-31 BUILDING K-762 K-761 K-861 Z1-49 Z2-06 Z1-48 Z2-03 Z2-07 Z2-10 Z1-46 Z2-19 Z2-11 LEGEND:

EAST TENNESSEE TECHNOLOGY PARK OAK RIDGE, TENNESSEE Fig. 1.2. Proposed Former K-31 Area transfer footprint and EU boundaries.

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Poplar Creek K-31 Clinch River Fig. 1.3. Former K-31 Area, circa 1952.14-060(E)/092815 1-4

Poplar Creek K-33 K-31 Fig. 1.4. Former K-31 Area, circa 2000.14-060(E)/092815 1-5

PO A

PL EK RE RC K-792 FORMER K-33 BUILDING K-31 K-762 K-761 K-861 K-1206-F LEGEND:

EAST TENNESSEE TECHNOLOGY PARK OAK RIDGE, TENNESSEE Fig. 1.5. Aerial photograph of the Former K-31 Area footprint and EU boundaries, circa 2013.

1-6

2. TITLE SEARCH On October 16, 1996, the State of Tennessee Roane County Recorders Office was visited, and a review was conducted of the recorded deeds documenting previous ownership of the land tract where the Former K-31 Area and adjacent areas are located. The deeds contained no information or references to other recorded evidence that, prior to DOE ownership, the Property was utilized for the storage of hazardous substances and/or petroleum products or their derivatives. Additionally, no information contained in the deeds would indicate that hazardous substances and/or petroleum products or their derivatives were released from or disposed of on the Property. Prior to acquisition by the government, the area was farmland and was a combination of cultivated fields and pastures with scattered wooded areas.

Because the Tennessee Valley Authority (TVA) was the previous owner of several large tracts of ORR land, the TVA Real Estate Office was contacted regarding their knowledge of any previous land uses.

The U.S. Army Corp of Engineers (COE) was another source of information that has been contacted regarding previous land uses (see Sect. 3.1).14-060(E)/092815 2-1

3. FEDERAL RECORDS SEARCH AND COMPLIANCE

SUMMARY

3.1 FEDERAL RECORDS SEARCH In 1997, the TVA in Knoxville, Tennessee (TVA 1997), and the COE District Office in Nashville, Tennessee (COE 1997), were contacted to determine if they maintained any records reflecting past or present land use relative to the land that is now the Heritage Center. Neither TVA nor COE had any information regarding the history of past or present land use that would indicate if hazardous substances or petroleum products or their derivatives were stored or released on the site.

DOE real estate records documenting previous ownership of the land tracts where the Former K-31 Area is located were examined. Page A-3 of Appendix A is a statement from the Realty Officer of the DOE-Oak Ridge Office (ORO) that the real estate records contained no information or references to other recorded evidence that, prior to ownership by DOE and its U.S. Government predecessor agencies, the property had been used for the storage of hazardous substances. Additionally, no information contained in these records indicated that hazardous substances had been released from or disposed of on the property.

Pre-construction aerial photographs and maps reflecting prior use of this land were also reviewed. A copy of these photographs and maps is maintained on file in the DOE-ORO Real Estate Office.

Aerial Photographs:

Photograph Nos. and Date Flight By Source No. 130-3-9, dated 1939 Unknown DOE-ORO, Real Estate Office Nos. 820-2-20 through -23 and 820-3-20 Aero Service Corp. for DOE-ORO, Real Estate through -24, dated September 25, 1942 Stone and Webster Office These photographs, which were taken in 1939 and 1942, show that the land where the study area is located was predominantly used for agricultural purposes. Approximately 90% of the Property was used in some type of agricultural pursuit, and the remaining acreage was wooded. A map depicting pre-World War II structures, archeological sites, and cemeteries that were present in the area of the Heritage Center is included in Appendix B.

Topographic and real estate maps:

A November 1, 1942, topographic map identified as Section B-1 of ORR that was prepared by Aero Service Corporation for Stone and Webster and a February 19, 1945, real estate map (sheet 9 of 16) prepared by the U.S. Army shows the boundaries of all land tracts upon which facilities at the site are currently located. The area addressed in this EBS is located primarily on a portion of Land Tract K-1007, with the southern border of the study area located on a portion of Land Tract B.

Neither the aforementioned photographs nor maps contained any information regarding the history of the past land usage that would indicate that storage or releases of hazardous substances or petroleum products have occurred on the land where the Former K-31 Area is located. Copies of the 1942 topographic map and real estate map are maintained in the DOE-ORO Real Estate Office.14-060(E)/092815 3-1

3.2 REGULATORY

SUMMARY

3.2.1 Background As mentioned previously, for the foundational information about the potential for surface and subsurface soil contamination, this EBS relies upon documentation presented in the following PCCRs:

Fiscal Year 2006 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2317&D2),

December 2006 (approved) [DOE 2006] (addresses EUs Z2-02, Z2-07, Z2-09, and Z2-10).

Fiscal Year 2007 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2723&D2),

September 2007 (approved) [DOE 2008] (addresses EUs Z2-01, Z2-03, and Z2-08).

Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2590&D1), November 2012 (approved) [DOE 2012].

Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-XXXX), 2015 (in preparation) [DOE 2015]

(addresses EU Z2-06) [NFA recommended, D1 version to the U.S. Environmental Protection Agency (EPA) and Tennessee Department of Environment and Conservation (TDEC) in May 2015 (planned)].

The PCCRs for EUs Z2-03, Z2-05, Z2-07, and Z2-10 (DOE 2006; DOE 2007c; and DOE 2012) have been approved by EPA Region 4 and TDEC (Appendix C). Approval of the PCCR addressing EU Z2-06 (DOE 2015) is currently pending. The PCCRs address the EUs where characterization or remedial actions had to be completed before the Property could meet the requirements of the Zone 2 ROD [Record of Decision for Soil, Buried Waste, and Subsurface Structure Actions in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2161&D2 (DOE 2005)]. The PCCRs were prepared as part of the Environmental Management (EM) Dynamic Verification Strategy (DVS). The DVS process is in use for remedial action decision-making across the Heritage Center, and decisions are based on hierarchical land unit divisions of Zones, then Geographic Areas, then Groups, then EUs.

All of the acreage in the Former K-31 Area EBS footprint is included in EUs Z2-03, Z2-05, Z2-06, Z2-07, and Z2-10. These EUs are located in Zone 2 of the Heritage Center. The component and surrounding EUs and the Former K-31 Area transfer footprint are shown on Fig. 1.2.

CERCLA decisions for EUs Z2-03, Z2-05, Z2-06, Z2-07, and Z2-10 are indicated in Table 3.1.

These EUs were assessed under an approved Work Plan [Remedial Action Work Plan for Dynamic Verification Strategy for Zone 1, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2182&D4 (DOE 2007)] prepared according to the DVS process. The Work Plan was approved by EPA and TDEC on December 7 and 13, 2007, respectively. It was used for both Zone 1 and Zone 2. All verified and validated data used to make regulatory decisions have been placed in the Oak Ridge Environmental Information System (OREIS) database (see http://www-oreis.ettp.energy.gov/oreis/help/oreishome.html) and are available for review. The sampling results and data evaluation can be found in Appendix A of the PCCRs for EUs Z2-07 and Z2-10 (DOE 2006); EUs Z2-04 and Z2-05 (DOE 2012); and Z2-06 (DOE 2015). Sampling results and data evaluation can be found in Appendix B of the PCCR for EU Z2-03 (DOE 2008). These data were deemed sufficient to 14-060(E)/092815 3-2

reach NFA decisions for soils under an industrial land use risk scenario for EUs Z2-03, Z2-05, Z2-07, and Z2-10, and an NFA has been recommended for Z2-06.

Table 3.1. Summary of CERCLA decisions for the Zone 2 EUs addressed in this EBS Associated FFA sites Geographic PCCR within the transfer area Group EU (acreage)a footprintb Decision K-31/33 Area K-31/K-33 FY 2007 PCCR Z2-03 K-762 Valve Vault 2 NFA for soils for Zone 2 Soils, (14.9 acres) (known as K-896) approvedc Slabs, and K-897-M Oil Containment Subsurface Structure Structures at ETTP K-31/33 Area K-31/K-33 2012 PCCR for Z2-05 None NFA for soils EUs Z2-04 and (22 acres) approvedd Z2-05 at ETTP K-31/33 Area K-31/K-33 2015 PCCR for Z2-06 None NFA for soils EU Z2-06 (25.6 acres) recommendede K-31/33 Area K-31/K-33 FY 2006 PCCR Z2-07 K-897-E Oil Containment NFA for soils for Zone 2 Soils, (10.9 acres) Structure approvedf Slabs, and K-897-F Oil Containment Subsurface Structure Structures at ETTP K-31/33 Area K-31/K-33 FY 2007 PCCR Z2-10 K-897-G Oil Containment NFA for soils for Zone 2 Soils, (20.9 acres) Structure approvedf Slabs, and Subsurface Structures at ETTP a

Component names and acreages as provided in the PCCRs listed in Sect. 3.2.

b No FFA sites are located within the former K-31 building EU.

c NFA approved from the Fiscal Year 2007 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2723&D2 (DOE 2008).

d NFA approved in the Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2590&D1 (DOE 2012).

e NFA recommended in the Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-XXXX (DOE 2015) [NFA recommended, D1 version to EPA and TDEC in November 2015 (planned)].

f NFA approved from the Fiscal Year 2006 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2317&D2 (DOE 2006).

EBS = Environmental Baseline Survey Report. FFA = Federal Facility Agreement.

CERCLA = Comprehensive Environmental Response, NFA = no further action.

Compensation, and Liability Act of 1980. PCCR = Phased Construction Completion Report.

ETTP = East Tennessee Technology Park.

EU = exposure unit.14-060(E)/092815 3-3

Building K-761 is located west of the K-31 building in EU Z2-03, which has an approved NFA for soils, slabs, and subsurface structures. Building K-761 was the Switch House for the former K-762 Switchyard and the building is scheduled for demolition. The building is a three-story structure that was previously associated with switchyard operations and used for offices, a receipt inspection area, and during the Three-Building D&D, a warehouse and passive neutron waste assay system were located there. The warehouse handled miscellaneous office supplies and small metal parts needed for the Three-Building D&D efforts. All equipment was removed from Bldg. K-761, but it was not demolished as the Three-Building D&D project concluded in 2005.

Because the soil and slab underlying Bldg. K-761 and the K-903 Pad are part of an EU with an approved NFA determination, the entire EU is included in the transfer footprint of this EBS/Covenant Deferral Request (CDR), including the land underlying these structures. The soils beneath K-761 and the K-903 Pad were not sampled under the DVS, due to the inaccessible nature of the soils while these structures remained in-place, but they were included within the scope of the PCCR for EUs Z2-03 (DOE 2008) and Z2-05 (DOE 2012). Sampling locations for these EUs were established during DQOs workshops with EPA and TDEC approval. However, to ensure that no contamination above established Zone 2 remediation levels (RLs) remains, when removal of the K-903 Pad is complete, the subsurface soils will be characterized during confirmatory sampling to ensure that the soils meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in Federal Facility Agreement (FFA) Appendix E and/or J. The underlying land will not be transferred until K-903 Pad removal, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the PCCR Addendum for EUs Z2-04 and Z2-05 in Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect.

XXI of the FFA. Likewise, when demolition of K-761 is complete, the subsurface soils and/or exposed remaining structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and/or subsurface structures, such as concrete subsurface foundation elements and electrical ducts, meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the Fiscal Year (FY) 2007 PCCR Addendum for Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the FFA.

DVS sampling of EU Z2-06, including 54 samples of the soils underlying the K-31 slab, detected no contamination above average or maximum RLs. An NFA determination has been recommended in the draft Technical Memorandum that was provided to EPA in March 2015; hence, the land underlying the K-31 building is included in the transfer footprint of this EBS. As an additional measure for ensuring that no contamination above established Zone 2 RLs remains when demolition of these structures is completed, the subsurface soils and structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and subsurface structures meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the EU Z2-06 PCCR for Zone 2. The PCCR will be submitted for formal review and approval in accordance with Sect. XXI of the FFA.14-060(E)/092815 3-4

Ecological Impacts Potential impacts to ecological receptors can occur from either:

1. impacts that are associated with residual contamination of environmental media that result in risk to ecological receptors; or

2. impacts to ecological receptors from development and/or operational activities occurring after transfer of the property.

Potential impacts to ecological receptors, both within the transfer property and the adjacent property, from the first category will be addressed as ecological risk in the final ETTP Sitewide ROD, which will also evaluate risk from groundwater and surface water to human and ecological receptors. DOE will remain responsible, regardless of property ownership, for providing the necessary response actions to address any residual contamination on the property to ensure protection of human health and the environment.

Potential impacts to ecological receptors, both within the transfer property and the adjacent property, from development and/or operational activities resulting from property transfer were addressed in the Environmental Assessment for Transfer of Land and Facilities within the East Tennessee Technology Park and Surrounding Area, Oak Ridge, Tennessee, DOE/EA-1640, October 2011 (DOE 2011), which resulted in a Finding of No Significant Impact. Exhibit B of the Quitclaim Deed, included in Sect. 6.2 of the CDR, restricts development of the property to the industrial, commercial, and recreational uses evaluated in the EA. Additionally, following transfer, the new property owner is still subject to regulatory requirements such as storm water management, wetlands protection, and Clean Air Act compliance.

Finally, adverse environmental impacts to existing ecological receptors would be limited because construction activities would primarily occur within previously disturbed areas.

3.2.2 The EM DVS Protocol and Former K-31 Area Regulatory information for Zone 2, as it relates to the Former K-31 Area, will be discussed below along with a summary of the EM DVS approach. Technical information for EUs Z2-03, Z2-05, Z2-06, Z2-07, and Z2-10 will be presented in Chap. 7.

The EM DVS process was designed to facilitate real-time decision-making and includes five steps:

1. Preparation of Data Quality Objectives (DQOs) scoping packages.

2. Classification of SUs using a graded approach.

3. Determination of additional sampling or surveying needs.

4. Determination of the need for remedial action using decision rules.

5. Use of confirmation sampling to determine if remedial action is complete.

The decision rules mentioned in Step 4 were based on one or more of the following criteria:

exceedance of a maximum RL (Max RL) at any location, exceedance of an average RL (Avg RL) across the EU, unacceptable future threat to groundwater, or 14-060(E)/092815 3-5

unacceptable cumulative excess lifetime cancer risk (ELCR) of > 1 x 10-4 and hazard index (HI) > 1 across the EU.

The potential threat to groundwater from Zone 2 soils is evaluated by reviewing historical groundwater data and, if necessary, screening soil data against established screening levels. Based on the screening, site-specific modeling may be conducted. Consideration of an action on groundwater is required if any of these steps indicate a site may be a potential source of contamination to groundwater.

3.2.3 Actions Taken Within the Former K-31 Area EBS Study Area Exposure Units The Former K-31 Area EBS study area footprint is located within EUs Z2-03, Z2-05, Z2-06, Z2-07, and Z2-10. Located within three of these EUs (Z2-03, Z2-07, and Z2-10) are sites designated as requiring special attention because they were listed in the Federal Facility Agreement (FFA) [Federal Facility Agreement for the Oak Ridge Reservation, DOE/OR-1014 (DOE 1992)] as having the potential for contamination (see Table 3.1). (The FFA agreement was entered into by DOE, the state of Tennessee, and EPA-Region 4 under the authority of CERCLA.)

There are no FFA sites located within Z2-05 and Z2-06. It should be noted that the DQOs Scoping Package [Data Quality Objective Scoping Package for the K-31/K-33 Buildings (EUs Z2-04, Z2-05, and Z2-06) at the East Tennessee Technology Park, Oak Ridge, Tennessee, BJC/OR-3234 (BJC 2009)]

identifies the K-33 Recirculating Cooling Water (RCW) Lines Leak Site FFA site as being located in EUs Z2-04 and Z2-05 (DOE 2012). However, the RCW Lines Leak Site listed in the FFA is actually in the adjacent EU Z2-08 and was evaluated as part of that EU (DOE 2008).

Demolition of the K-1206-F Fire Water Tank, located in the central portion of EU Z2-10, was conducted in August of 2013 through a controlled explosive demolition (Fig. 3.1). The 382-ft tall water tank toppled into an empty field (Fig. 3.2), and the metal from the tank was recycled. Paint chips dislodged during size reduction of the metal structure were collected, packaged, and disposed. Approximately 4 ft3 of lead-containing paint chips were collected following demolition and disposed at an off-site Resource Conservation and Recovery Act of 1976 (RCRA) facility. The distribution of any remaining paint chips on the ground is consistent with historical sand blasting operations on the tank for re-coating performed prior to the DVS evaluation of EU Z2-10. Additionally, confirmatory samples were collected in June 2015, after this demolition action, and the results will be provided to the FFA parties for review and approval in a Concurrence Form. If appropriate, DOE will also document no change to NFA for EU Z2-10 in a Concurrence Form, and an Addendum to the FY 2007 PCCR for Zone 2 (DOE 2008).

Characterization, evaluation, and remediation of the FFA sites are used as a metric for completion of the closure of DOE facilities at the Heritage Center. Some EUs contain one or more FFA sites. However, the final action/NFA decisions are made on an EU basis and are not predicated upon the results from any smaller scale subdivision of the EU. If the evaluation of all of the available data for an EU supports an NFA determination at the EU level, then all of the FFA sites within that EU are considered NFA by inclusion. Based on sampling analytical results and an evaluation of the EU-wide contaminant profile, soils in the FFA sites shown in Table 3.1 in EUs Z2-03, Z2-05, Z2-06, Z2-07, and Z2-10 do not pose a potential threat to the future industrial worker or groundwater.14-060(E)/092815 3-6

Fig. 3.1. Demolition of the K-1206-F Water Tower, August 2013.

Fig. 3.2. K-1206-F Water Tower after demolition.14-060(E)/092815 3-7

4. PAST AND PRESENT ACTIVITIES 4.1 PAST AND PRESENT ACTIVITIES FOR THE REAL PROPERTY PROPOSED FOR TRANSFER The following describes the past and present activities for the Property proposed for transfer under this EBS on an EU basis.

EU Z2-03 The portion of EU Z2-03 that was included in the Former K-33 Area transfer footprint includes approximately 12.8 acres of the total 14.9 acres contained in the EU, with the remaining 2.1 acres included in the Former K-31 Area transfer footprint. The 12.8 adjacent acres were included in the Former K-33 Area EBS and CDR, and were primarily used for electrical power distribution associated with the former K-31 building. The primary activities conducted within the proposed transfer footprint portion of the EU are described below.

K-761 Switch House The K-761 Switch House (also known as the K-31 Switch House) is a three-story structure that was constructed in the early 1950s. This facility and the associated K-762 Switchyard served as the power distribution and electrical switching station for the K-31 building. It has two building galleries and a control room gallery. It housed an electrical equipment test area that was relocated to the Elza Facility at the Y-12 National Security Complex. Following shutdown in 1985, maintenance personnel working in the area used the building during the day. During the Three-Building D&D, K-761 was used for offices, as a receipt inspection area, for warehouse space, and was the location of a passive neutron waste assay system. The warehouse handled miscellaneous office supplies and small metal parts needed for the Three-Building D&D efforts. All equipment was removed from K-761 as the Three-Building D&D project concluded in 2005, but it was not demolished. D&D of K-761 is currently planned for the summer of 2016.

A Rubb tent was previously located between the K-761 and K-31 buildings and was used to support D&D operations in the area. The Rubb tent was removed in 2014. There are railroad tracks just outside the western boundary of the transfer footprint.

Z2-05 EU Z2-05 is one of two EUs that the former K-33 building occupied, with Z2-04 containing the northern half of the building, and Z2-05 the southern half of the K-33 building. Only a narrow strip at the southern end EU Z2-05, which is largely paved with asphalt or covered with concrete with an imbedded rail line, is included in the Former K-31 Area transfer footprint. This narrow strip of land, which was not included in the transfer footprint of the Former K-33 Area, was needed to support D&D activities for the K-31 building. The K-33 building, which previously occupied EUs Z2-04 and Z2-05, is described in Sect. 4.2 as part of the adjacent area. This strip of land is the location of the K-903 Supercompactor concrete pad.14-060(E)/092815 4-1

K-903 Supercompactor The Supercompaction Facility (K-903) was built to support D&D activities for the Three-Building D&D project. Facility construction commenced March 2000 and operation began January 2001. The Supercompactor operation was housed in a new, temporary, pre-engineered building attached to the south side of the K-33 building. The building measured approximately 205 ft in length (parallel to south wall of K-33) and extended south toward K-31 approximately 86 ft. It was approximately 62 ft high. A new switch and short rail spur (250 ft) was also constructed to the Supercompactor vehicle loading bay from the existing rail track servicing K-33.

The Supercompactor had a waste unloading station on the east side of the building and a waste loading station on the west side (Fig. 4.1). Each station was serviced with a new 25-ton crane that could lift intermodals or sea-land containers on and off trucks or rail cars. A third crane utilizing a four-claw grapple hook was fitted to run into K-33 to lift waste materials from the compaction waste staging areas on the second floor of K-33, and then transfer the waste materials to the compactor on the first floor of the facility.

The compactor was monitored from a control room on the second floor of the facility.

Fig. 4.1. Rail spur leading up to the former Supercompactor vehicle loading bay.

This facility compacted and containerized contaminated metal sections and other low-level waste (LLW) to provide significant waste volume reduction and facilitate more economical off-site waste disposal operations. The process of compaction applied intense pressures, on the order of tons per square inch, to achieve substantial volume reductions. The facility accepted complete components such as coolers, compressor stators, valve bodies, and converter end caps. All waste fed into the compactor was Class A LLW as defined by 10 Code of Federal Regulations 61.55. Due to the relatively low intensity of gamma radiation from these materials, no radiological shielding was needed to adequately protect operations personnel. After the waste was compacted, it was placed in intermodal boxes for out-of-state transport by truck or railcar to Envirocare or the Nevada Test Site. Free liquids, asbestos-containing material, soft organic wastes, soil, demolition rubble, and other loose metallic and inorganic materials were not processed in the Supercompactor.14-060(E)/092815 4-2

Compactor operations concluded in the fall of 2004, and the building and equipment were decommissioned and removed. The concrete foundation pad remains and was used as a laydown area during removal of the process tie lines conducted in 2013. The presence of contamination was identified in the PCCR for the K-33/K-31 Process Tie Line Demolition Project (DOE 2013).

EU Z2-06 EU Z2-06 occupies the northern portion of the transfer footprint and is the location of the former K-31 building, which is described below.

Building K-31 The K-31 building is located to the south of the study area and is a two-story structure with a total floor area of approximately 32 acres. The building was part of the low-enriched uranium gaseous diffusion cascade at the ORGDP and began operations in 1954. All enrichment operations were discontinued in 1985 and Bldg. K-31 was shut down in 1987. Building K-31 and associated equipment have historical radiological and chemical contamination from past operations and are being addressed under the ORR FFA under CERCLA authority. Between 1997 and 2005, a CERCLA removal action was undertaken by DOE to remove the process equipment and to decontaminate the facilities [Engineering Evaluation/Cost Analysis for Equipment Removal and Building Decontamination for Buildings K-29, K-31, and K-33, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/02-1579/D2 (DOE 1997)]. All process and non-process equipment and associated piping, ducting, and electrical services have been removed from the K-31 building. Removal of the exterior transite siding was initiated in May 2014 in preparation for D&D of the building (Fig. 4.2). D&D of Bldg. K-31 is expected to be complete in the summer of 2015.

Fig. 4.2. K-31 building with transite panels removed, September 2014 (EU Z2-06).14-060(E)/092815 4-3

The K-33/K-31 tie lines were elevated transfer lines located outside, between the former K-33 building and the K-31 building. A small portion of the tie lines was in and above the proposed transfer footprint prior to their removal in 2013. Figure 4.3 shows the K-33/K-31 tie line structure prior to demolition, but after completion of the K-33 building demolition. The tie lines provided for the distribution of process gas between the enrichment cascades. They were enclosed in thermally insulated housings and provided with hot air or steam heat and temperature control instrumentation. They were composed of multiple uranium hexafluoride (UF6) distribution pipes of 3- to 42-in. diameter. They operated between 1954 and 1985.

When gaseous diffusion operations were stopped in 1985, the volatile UF6 inventory was evacuated, and the tie lines were purged and isolated from the process system by closing valves in the interconnection buildings.

Fig. 4.3. K-31/K-33 process tie line structure (EU Z2-06).

Fig. 4.4. K-31/K-33 process tie line end state along north side of Bldg. K-31 (EU Z2-06).14-060(E)/092815 4-4

K-31 Recirculating Cooling Water Lines The K-31 RCW lines were located immediately east of the former K-31 building. The system provided RCW for the K-31 Cascade. There were some releases associated with the RCW lines. In 1956, a leak caused by local galvanic action occurred in the south K-862 supply header. Cathodic protection was installed following this release. In 1968, seepage occurred at ground level (K/ER-47/R1 [Energy Systems 1995]). Approximately 10 valve vaults, which were associated with the RCW lines, are located within the transfer footprint. Prior to transfer, the RCW lines will be evaluated to ensure they meet the free release criteria of DOE Order 458.1 for residual radioactive materials or, alternatively, the lines will be isolated through engineered controls to eliminate the potential exposure pathway.

EU Z2-07 EU Z2-07 is adjacent to the southern end of the proposed transfer footprint (see Fig. 1.2). This EU is generally vacant, flat-lying land that has primarily been used for temporary staging of support trailers and facilities during construction and demolition activities at ETTP.

The northeastern corner of this EU was the location of the Transportable Vitrification System (TVS) in 1996 to 1997. TVS was a large-scale vitrification system for the treatment of mixed wastes (Fig. 4.5). The wastes contained both hazardous and radioactive materials in the form of sludge, soil, and ash. The TVS was moved to the site and erected in 1996. The TVS was demonstrated at ETTP during September and October of 1997. During this period, approximately 16,000 pounds of actual mixed waste were processed, producing over 17,000 pounds of glass. After the demonstration was complete, it was determined that it was more expensive to use the TVS unit to treat and dispose of mixed waste than to direct bury this waste in a permitted facility. Thus, the unit was deactivated and a RCRA closure of the facility was conducted and the unit subsequently was dismantled.

Fig. 4.5. Transportable vitrification system located south of the K-31 building.14-060(E)/092815 4-5

Mixed waste treated at the TVS consisted of dried K-1407-B and -C Pond Sludge and newly generated waste sludge from the Central Neutralization Facility (CNF). The mixed waste was transported to the site as needed and was not stored at the TVS location. At the end of waste feed operations, all tanks and lines from the inside of the batch module were flushed and the resulting flush water was fed to the melter. The melter was drained of glass to the lowest point without exposing the electrodes. Approximately 3 tons of glass, containing vitrified waste, remained in the melter. All treated and untreated wastes were removed from the area and placed in permitted storage facilities located elsewhere on the ETTP reservation.

Aqueous waste remaining in the 20,000-gallon blow-down tank was removed and transported to the CNF for disposal. The TVS unit was successfully closed under RCRA in 2002.

EU Z2-10 EU Z2-10 lies adjacent to the southeastern portion of the transfer footprint. This EU is generally vacant land that was the location of the former K-1206-F fire water storage tank. This water tower was demolished in 2013. The demolition debris was size-reduced prior to disposal. Paint chips dislodged during size reduction of the metal structure were collected, packaged, and disposed at an off-site RCRA facility. The distribution of any remaining paint chips on the ground is consistent with historical sand blasting operations on the tank for re-coating performed prior to the DVS evaluation for EU Z2-10.

Additionally, confirmatory samples were collected in June 2015, after this demolition action, and the results will be provided to the FFA parties for review and approval in a Concurrence Form. If appropriate, DOE will also document no change to NFA for EU Z2-10 in a Concurrence Form, and an Addendum to the 2007 PCCR (DOE 2008).

K-1206-F Fire Water Tank The K-1206-F Fire Water Tank, located in the central portion of EU Z2-10, was demolished in August 2013 through a controlled explosive demolition. The 382-ft-tall water tank toppled into an empty field.

The 400,000-gallon structure was built in 1958 to service the ORGDPs fire protection system. It operated until June 3, 2013, when the valves were turned off, and it was drained, disconnected, and permanently taken out of service on July 15, 2013.

4.2 PAST AND PRESENT ACTIVITIES FOR THE ADJACENT PROPERTY All of these adjacent areas have NFA determinations and were also included in the previously approved Former K-33 Area CDR and EBS.

EU Z2-02 Approximately 11.7 acres of the total 29.7 acres of EU Z2-02 are located within the Former K-33 Area transfer footprint. The remaining 18 acres of EU Z2-02 were transferred in 2010. The northern portion of EU Z2-02 is currently owned by Environmental Dimensions, Inc. The southern portion of EU Z2-02 was transferred to Energy Solutions LLC. EU Z2-02 was historically used for electrical power distribution associated with the former K-33 building. The primary facilities that previously occupied the transfer footprint portion of the EU are described below.

Former K-792 Switchyard The K-792 Powerhouse Complexa three-building complexconsisted of the K-791-N Switch House, K-791 Control House, and K-791-S Switch House that formerly occupied the area of EU Z2-02 proposed for transfer. This complex was originally designed to receive the power from the former K-792 Switchyard and distribute it to the K-33 process facility and K-892 Pump House. The footprints of 14-060(E)/092815 4-6

these former buildings lie to the east of the former K-792 Switchyard, across the railroad spur, and are included in the proposed transfer footprint. In 1998, demolition of the switchyard and switch houses began as part of the ETTP Three-Building D&D and Recycle Project. Since that time the K-791-N Switch House, K-791 Control House, and K-791-S Switch House have been demolished down to their concrete pads [see Fig. 1.5; Environmental Baseline Survey Report for the Proposed Transfer of the K-792 Switchyard Complex at the East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2347 (DOE 2010)]. The activities conducted in the balance of the EU, which has been transferred, are described in Sect. 4.2.

EU Z2-03 The portion of EU Z2-03 that is adjacent to the K-31 transfer footprint includes approximately 12.8 acres of the total 14.9 acres contained in the EU, with the remaining 2.1 acres included in the K-31 transfer footprint. The 12.8 adjacent acres were included in the Former K-33 Area EBS and CDR, and were primarily used for electrical power distribution associated with the former K-31 building. The primary activities conducted within EU Z2-03 that is adjacent to the proposed K-31 transfer footprint are described below.

Former K-762 Switchyard The K-762 Switchyard Complex was constructed in 1952 to receive TVA power and supply the K-31 Process Facility. In some documents, it is also referred to as the K-31 Switchyard. At the time of construction, a system of French drains was installed immediately below the switchyards gravel bed. An oil skimmer for runoff was installed in 198081. Approximately 20 transformers were located in the switchyard and there were also four vaults/pits. The footprint of the K-762 Switchyard is coincident with the boundaries of the K-762 Switchyard Soils FFA site. In 1951, two related transformer explosions and a subsequent fire resulted in the release of polychlorinated biphenyls (PCBs) [Site Descriptions of Environmental Restoration Units at the Oak Ridge K-25 Site, Oak Ridge, Tennessee, K/ER-47/R1 (Energy Systems 1995)]. Railroad tracks are located next to the vaults/pits near the eastern border of the proposed transfer footprint. The switchyard was shut down in 1985 and the 161-kV feeds were disconnected and the transformers were either drained or removed from the switchyard. Following shutdown, surplus electrical equipment was stored in the switchyard. It currently is mostly grass-covered and is partially fenced. It contains 21 transformer vault concrete pits. It also contains four Synchronous Condenser Buildings made of concrete block above grade and poured concrete basements in each.

Associated concrete pits for each have been filled in with gravel. Various concrete equipment pedestals, saddles, and slabs also remain in the switchyard. The activities conducted in the balance of the EU that will remain as adjacent property are described in Sect. 4.2.

EUs Z2-05 EU Z2-05 is the EU that the southern half of the former K-33 building occupied, with Z2-04 containing the northern half of the building. A small strip at the southern end of EU Z2-05 is included in the proposed transfer footprint. The K-33 building, which previously occupied EUs Z2-04 and Z2-05 is described below. This portion of EU Z2-05 was included in the Former K-33 Area CDR and EBS.

Former K-33 Building Construction of Bldg. K-33 began in July 1952, and it was placed in operation in March 1954 as the largest and last of the ORGDP cascades for the isotopic enrichment of uranium. The first floor was the operating floor that contained the process control room, offices, maintenance shops, and auxiliary equipment such as electrical switchgear, ventilation fans and ducts, process control instrument cabinets, lube oil storage tanks,14-060(E)/092815 4-7

chlorofluorocarbon evaporative coolant storage tanks, and vacuum pumps with chemical solvent traps. The UF6 enrichment process equipment was located on the second floor, which was called the cell floor. All enrichment operations were discontinued in 1985 and Bldg. K-33 was shut down in 1987. Portions of the building were then used for hazardous waste storage (Site Descriptions of Environmental Restoration Units at the Oak Ridge K-25 Site, Oak Ridge, Tennessee, K/ER-47/R1). From 1998 to 2005, the building was decontaminated and all process equipment was removed. The demolition of the building (Fig. 4.1) began in 2010 and was completed in 2011 (DOE 2012b). During the preparation stages of the demolition, the soil beneath the slab was characterized using DVS. Removal of the slab began immediately following demolition of the building and was completed in 2012. Following slab removal, the area within the building foundation footprint was graded and seeded with grass (DOE 2012a).

EU Z2-08 The activities that have historically been conducted within EU Z2-08 were primarily water pumping, treatment, and cooling associated with the RCW lines. The main facilities that currently, or previously, occupied this EU are described below.

K-892-G and -H Cooling Towers and Basins The K-892-G and -H cooling towers were located immediately east of the former K-33 building. They were built in 1954 and operated until 1985. They were part of the RCW system for the K-33 cascade. The treated redwood towers and Munters fill superstructure were demolished as part of the Cooling Tower Demolition Project in 1995. However, the aboveground concrete basins were cleaned, demolished, left in place, and covered with soil and vegetation. A portion of the west wall of the center basin between the -G and -H towers remains as it serves as the east wall of the K-892 Pumphouse.

During operation, the lines to the K-892-G basin became corroded. A chromate/zinc/phosphate treatment was used for corrosion control. In 1963 and 1973, a Mar-treat system'1 was used to control biological attack. That process reportedly produces copper fluoride, copper chromate, zinc arsenate, copper arsenate, and zinc chromate. In the early 1960s, the Steam Chem system', which contains semivolatile organics, was used to fight biological attack in cooling towers. A pentachlorophenol (PCP) fungicide treatment, which contains or degrades to traces of dioxin, may have been used on this systems cooling towers.

K-892 Pumphouse The K-892 Pumphouse is located immediately east of the former K-33 building. It was built in 1954 and operated until 1989 to pump treated water for the K-33 RCW system. Auxiliary units include the K-896 Recycle Blowdown Facility; the K-896-A, -B, and -C Clarifier Tanks; K-892-D, -E, -K, -M, -P, -U, and -W valve houses; K-892-V Valve House and Electrical Panels; K-892-N HCl Pump House; K-892-R, -S, and -T tanks; K-892-Q HCl Storage Tank and Basin; K-892-X Sludge Tank; K-894 Acid Unloading Station; K-896-C Pump House; and K-700-A-40 Pump House Transformers. Clarifier tanks have been demolished but the concrete basins for the tanks remain. The K-892 building consists of three sections. The northwest section contains water treatment chemical tanks and feed equipment. The east section contains 11 RCW pumps, piping, and valves. The south section contains electrical transformers, diesel fuel tanks, and chemical storage tanks. Outside the west wall are the seven transformers. Outside the south end of the building is an empty, 500-gal diesel tank for the fire water pump engine. There are 1

Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof or its contractors or subcontractors.14-060(E)/092815 4-8

two empty, 500-gal sulfuric acid tanks outside the northwest end of the building. Building demolition was recently completed in March 2015. Demolition of the K-892 Pumphouse will be described in the FY 2015 PCCR for Low Risk/Low Complexity Facilities of the Remaining Facilities Demolition Project.

Approximately 80 lead acid batteries, each containing 1 gal of sulfuric acid, have been used and stored in the building along with flammable materials and lime. Chromates and PCBs have also been possible contaminants. The building is posted as having radiological contamination inside the RCW pipes. The above-ground portion of the RCW lines will be removed as part of the building demolition. The RCW lines remaining in-place have been filled to eliminate any potential exposure pathway and meet the free release criteria.

K-892-Y Recirculating Water Sludge Softener Facility and Maintenance Shop The K-892-Y Recirculating Water Sludge Softener Facility and Maintenance Shop is located immediately east of the former K-33 building. It was built for handling, thickening, and fixing sludge from RCW treatment. The facility was only operated for testing and evaluation and was later used for storage. The building contains sludge processing equipment. Outside the building is the K-892-X steel thickener tank.

The facility has been recently demolished.

EU Z2-09 All of the acreage included in EU Z2-09 was included in the transfer footprint of the Former K-33 Area CDR and EBS. The majority of the EU is primarily vacant land containing a segment of the West Poplar Creek Patrol Road. The historical activities that have been conducted within this EU were primarily water pumping, treatment, and cooling associated with the RCW lines. The main facilities that currently, or previously, occupied this EU are described below.

K-861 and K-861-J Cooling Towers and Basins The K-861 and K-861-J cooling towers were located immediately east of the K-31 building. K-861 was built in 1951 and operated until 1985. The K-861-J cooling tower was an adjacent, one-cell counterflow tower added at the north end of K-861 in 1979. The towers were part of the RCW system for the K-31 cascade. The treated redwood and Douglas fir and Munters fill towers were demolished as part of the Cooling Tower Demolition Project in 1996. However, all sediment was removed from the in-ground concrete basins, and the internal surfaces were steam cleaned and the basin left in place. The sludge removed from the basins was disposed of at the Envirocare facility in Utah. TDEC recommended NFA for the facilities addressed under the Cooling Tower Demolition Project on March 4, 1998, and EPA concurred with no further investigation (NFI) for the study area addressed under the Cooling Tower Demolition Project on March 23, 1998. The basins have been filled with concrete rubble and gravel.

During operation, a chromate/zinc/phosphate treatment was used for corrosion control. In 1969, a Mar-treat system' was used to control biological attack. That process reportedly produces copper fluoride, copper chromate, zinc arsenate, copper arsenate, and zinc chromate. A PCP fungicide treatment, which contains or degrades to traces of dioxin, may have been used on this systems cooling towers.

Former K-862 Pumphouse The former K-862 Pumphouse was located immediately east of the K-31 building. It was built in 1951 and operated until 1985 to pump treated water for the K-31 RCW system. The building was demolished under the Cooling Tower Demolition Project. Auxiliary units associated with the pumphouse included the 14-060(E)/092815 4-9

K-861-A, and -B valve houses; the K-862-S Sulfuric Acid Tank; and the K-700-A-39 Pump House Transformers, all of which were demolished in 1996.

4.3 HYDROGEOLOGIC ENVIRONMENT This information is being presented to provide the basis for the evaluation of the potential for vapor intrusion into existing or future buildings within the Former K-31 Area transfer footprint.

The Former K-31 Area is located in the northwestern portion of the Heritage Center. This portion of the ETTP is underlain by bedrock of the lower Chickamauga Supergroup (Lemiszki 1994). The Chickamauga Supergroup formations in this area include the Pond Spring Formation, the Murfreesboro Limestone, the Ridley Limestone, the Lebanon Limestone, the Carters Limestone, and the Hermitage Formation (Fig. 4.6). Structurally, these formations dip to the southeast in the vicinity of the study area.

The angle of dip ranges from 20 to 74 degrees to the southeast based on measurements obtained from bedrock exposures along Poplar Creek (see Lemiszki 1994) in the Former K-31 Area.

The bedrock formations underlying the Former K-31 Area consist primarily of interbedded limestone, argillaceous limestone, and calcareous shale of the Chickamauga Supergroup. Calcareous shales and argillaceous limestones are characteristic of the Pond Spring Formation, which is found at the very northwestern corner of the K-31 study area. Thin- to thick-bedded, fine-grained crystalline limestones of the Murfreesboro Limestone overlie the Pond Spring Formation, and underlie northwestern portion of the transfer footprint. Thick to massively bedded, fucoidal-textured limestone is characteristic of the Ridley Limestone, which occupies the middle portion of the transfer footprint. Fucoidal texture is a term used to describe the presence of tan-brown, irregularly shaped, fine- to coarse-grained dolomitic patches within the limestone beds of the Ridley. A distinctive characteristic of the Lebanon Limestone, which underlies a narrow area in the southeastern portion of the study area, is the abundance of fossils in this unit. Bedding in the Lebanon Limestone ranges from regular and even, thin to medium beds, to irregular, cobbly beds.

Some thick to massive limestone beds also occur. Thick to massive beds of interbedded micritic- and coarse-grained limestone characteristic of the lower part of the overlying Carters Limestone, which underlies the southern portion of the study area. The top of the lower Carters consists of olive-gray, argillaceous limestone that is mud-cracked and devoid of fossils and weathers into thin chips. The middle part of the Carters Limestone consists of medium to thick, regular- and even-bedded, blue-gray limestone.

At the top of the middle part are two apple green, sometimes partly maroon, metabentonite beds that range from 1 to 3 ft in thickness. Although exposures of the metabentonites were not found in the Heritage Center area during mapping by Lemiszki (1994), they have been observed along strike toward the southwest and northeast. The upper part of the Carters is poorly exposed but generally consists of micritic, greenish-gray and yellowish-gray, poorly-bedded, mud-cracked limestone. Limestones of the Hermitage Formation, which underlies the southeasternmost corner of the study area, consist of thin to medium, irregular, uneven, cobbly beds that are abundantly fossiliferous. A maroon, olive-tan, calcareous shale has been observed near the base of the unit.

Formations of the Chickamauga Supergroup are subject to karst development due to their carbonate content.

Evidence of karst development in the Chickamauga includes cavities encountered in drilling at the Heritage Center. Approximately 30% of the monitoring wells completed in the Chickamauga at the Heritage Center have encountered cavities ranging in size from a few inches up to 7 ft. Pre-construction topographic maps indicate the occurrence of sinkholes in the vicinity of the K-31 study area. A closed depression that appears to be a large sinkhole existed in the area along the western side of the former K-31 building, and additional closed depressions existed in the vicinity of the study area. All of these sinkholes were filled during construction of the K-31/K-33 buildings circa 1950.14-060(E)/092815 4-10

GEOLOGY:

Oc Olv K-8 92-J Ok C

AR Oma PL PO EK RE Ops K-792 FORMER K-33 BUILDING Om Ord FORMER K-31 K-861 BUILDING Olb Oca Om Ord Olb Oca Ocn-Ocy Oh LEGEND:

EAST TENNESSEE TECHNOLOGY PARK OAK RIDGE, TENNESSEE Fig. 4.6. Geologic map of the K-31 and surrounding area EBS study area.

4-11

Hydrogeologic characterization data for the Former K-31 Area are provided by 14 monitoring wells located within or adjacent to the study area (see Fig. 4.6). Much of the hydrogeologic characterization data discussed below for the K-31 study area reflect the information available from these wells and from other available Heritage Center site-wide information.

The water table at the Heritage Center generally mimics topography with shallow groundwater flowing from higher topographic areas to the surrounding surface water bodies. Groundwater flow paths in bedrock are a key uncertainty in the conceptual model of the Heritage Center, but fractures, bedding planes, and hydraulic gradient are expected to be the primary controlling factors. Based on the data obtained during installation of monitoring wells in the vicinity of the K-31 study area, it appears likely that bedrock occurs at depths from approximately 20 to greater than 45 ft below ground surface (bgs).

Based on pre-construction topographic maps, it appears that as much as 10 ft of fill material was potentially placed beneath the western portion of the former K-31 building during construction.

Water levels obtained from the wells in the vicinity of the Former K-31 Area indicate depths to water ranging from 8 to 25 ft bgs with shallow groundwater movement anticipated to be primarily to the south, southeast, and east toward Poplar Creek. Vertical hydraulic gradients determined from the paired unconsolidated zone and bedrock monitoring wells in the vicinity of the study area indicate generally downward vertical gradients from the unconsolidated zone to the bedrock. Hydraulic conductivity of subsurface materials has been determined from slug tests conducted in numerous monitoring wells throughout the Heritage Center. Based on these tests average values for the Chickamauga bedrock and the overburden materials above bedrock have been determined and are presented in Table 4.1.

Table 4.1. Summary of hydrogeologic conditions at the K-31 study area Parameter Site conditions Is a groundwater plume present beneath the site? None identified Distance from site to nearest upgradient plume (ft) 2000 NW Is karst present? Yes Depth to bedrock (ft) 20 to 45 Depth to groundwater (ft) 8 to 25a Are fill materials present at the site? Yes Composition of overburden materials present. Primarily silty clay Shallow groundwater flow direction East, southeast, and south Hydraulic conductivity of overburden materials (cm/sec) 1.25E-03b Hydraulic conductivity of bedrock (cm/sec) 4.28E-03c Hydraulic gradient at the site (ft/ft) 0.008a Is a perched water table present at the site? None identified a

Represents range based on available data.

b Represents average hydraulic conductivity of unconsolidated zone at the Heritage Center based on slug test results for wells completed in overburden materials at the Heritage Center.

c Represents average hydraulic conductivity of bedrock at the Heritage Center based on slug test results.

A groundwater plume has not been identified beneath or within the vicinity of the K-31 study area. The nearest identified plume, sourced from the K-1070-A Burial Ground, is located upgradient and approximately 2000 ft northwest of the study area. Although available potentiometric maps indicate that this plume may be considered to be upgradient of the Former K-31 Area, groundwater data and dye tracer 14-060(E)/092815 4-12

studies indicate that flow from the K-1070-A Burial Ground is primarily to the southwest toward the K-901-A Pond and not southeastward toward the K-31 study area. Analytical data for the well pair of BRW-027 and UNW-039 indicate the general absence of volatile organic compounds (VOCs) in both the bedrock and unconsolidated zone materials. Only low estimated concentrations of 2-butanone (3 micrograms per liter [µg/L]) and trichloroethene (TCE) [1 µg/L] were reported in one of five sampling events (August 1998) at the bedrock well BRW-027. August 1998 is the last sampling event of record for this well, and these compounds had not been detected in the previous six sampling events at this well dating back to 1990. Only a single detection of acetone (16 µg/L) in 1994 has been reported at well UNW-039 in five sampling events since 1990. The sporadic detection of low estimated concentrations of VOCs also occurs in the wells located south and east of K-31. Several VOCs including 2-butanone, 1,1-dichloroethene (DCE), 1,2-DCE, 1,2-dimethylbenzene, acetone, carbon disulfide, chloroform, chloromethane, methylene chloride, tetrachloroethene, toluene, and TCE have been detected in bedrock wells and unconsolidated zone wells south and east of K-31. However, of these detections, only TCE at wells BRW-064 and BRW-066 has exceeded its respective maximum contaminant level (MCL) of 5 µg/L in all samples collected since 1994. A concentration of 10 µg/L was reported in March 1995 at well BRW-064 and 54 µg/L in June 1998 at well BRW-066; however, TCE concentrations during subsequent sampling events at well BRW-064 have not exceeded the MCL, and TCE has been detected in only 5 of 25 samples collected at well BRW-066 since the June 1998 sampling event. The detected concentrations of TCE at BRW-066 since 1998 have all been below the MCL with concentrations ranging from 0.2 µg/L to 4 µg/L.

Metals that have been detected in at least one sampling event at concentrations above MCLs include antimony, arsenic, cadmium, chromium, lead, selenium, and thallium. Total chromium is the metal detected the most frequently at concentrations above the MCL of 0.1 mg/L with the exceedances primarily limited to wells located east and northeast (BRW-030, BRW-063, UNW-043, and UNW-083) of the former K-31 building. With the exception of total chromium, the other metals that have historically exceeded MCLs have not been detected above MCLs in the most recent sampling events for these wells.

Well UNW-039 located immediately northwest of the Former K-31 Area has exhibited gross alpha activity above the MCL of 15 pCi/L during one sampling event in September 1994 with a concentration of 58 picocuries per liter (pCi/L). However, the duplicate sample had no detectable alpha activity. Five of the six samples analyzed for gross alpha activity from this well were either nondetects for alpha activity or the detected concentration was well below the MCL. The gross beta activity has not exceeded the guidance level of 50 pCi/L at any of the Former K-31 Area wells since 1990. Technetium-99 (99Tc) has exceeded the derived MCL of 900 pCi/L at two unconsolidated zone wells (UNW-081 and UNW-082) and three bedrock wells (BRW-027, BRW-065, and BRW-068) with concentrations ranging from 947 to 1300 pCi/L in 1992 and 1993 samples. However, the limit of error for these results ranges from 320 to 1400 pCi/L indicating the uncertainty associated with these results is relatively high, and 99Tc was not detected in subsequent groundwater samples from these wells.

VOCs have been detected sporadically in soil samples from the Former K-31 Area at low concentrations.

Although the available data suggest the general absence of elevated levels of VOCs in the groundwater beneath the study area, there is uncertainty concerning groundwater flow paths due to the karst conditions in the bedrock underlying the Former K-31 Area. Since the remedial investigation for groundwater and soil gas is incomplete, and since there are uncertainties associated with the available data, further evaluation is necessary to confirm that a vapor intrusion threat does not exist in the area.14-060(E)/092815 4-13

5. RESULTS OF VISUAL AND PHYSICAL INSPECTIONS 5.1 VISUAL AND PHYSICAL INSPECTIONS OF THE PROPERTY TO BE TRANSFERRED Visual and physical inspections of portions of the Former K-31 Area were initially conducted on October 25, 2012, and March 7, 2014, as part of the adjacent area inspections for the Former K-33 Area. A follow-up visual and physical inspection of the K-31 Area footprint was conducted on December 16, 2014.

The study area is generally flat with low relief and is primarily occupied by the remaining structure of the partially demolished K-31 building (Fig. 5.1) with paved roads crisscrossing the area. Areas not occupied by the K-31 building and paved roads and concrete pads are grass-covered for the most part (Fig. 5.2) with trees and other vegetation occupying a buffer zone adjacent to Poplar Creek.

At the time of the December 2014 inspection, demolition of the K-31 building was in an advanced stage of completion with primarily only the structural framework remaining (Fig. 5.1). Several excavators using grappling claws and shears were actively removing the K-31 building structure. Piles of scrap metal and debris from demolition were being staged on the east side of the former building footprint for sorting prior to disposal. A steady flow of dump trucks was providing concrete rubble for use as fill in the K-861 Cooling Tower Basin (Fig. 5.3). Several valve vaults and oil containment structures exist throughout the property.

These are also in the process of being filled with gravel.

Fig. 5.1. Demolition of K-31 building, December 2014 (EUs Z2-05 and Z2-06).

5.2 VISUAL AND PHYSICAL INSPECTION OF ADJACENT PROPERTY The adjacent areas include the location of the former K-33 building to the north, the former K-762 Switchyard and the portion of the K-792 Switchyard area that has been transferred to the Community Reuse Organization 14-060(E)/092815 5-1

of East Tennessee (CROET) to the west, and Poplar Creek to the east and south. With the exception of the portion of the K-792 Switchyard area that has been transferred to CROET, the adjacent areas are owned by DOE and have been assessed to determine actual or potential releases of hazardous substances or petroleum products. Information about each of the adjacent areas that may contain contamination is documented in Sect. 4.2.

The former K-33 building footprint is covered with grass (Fig. 5.2) and was surrounded by the remaining building foundation wall, a truck alley with imbedded rail line on the northern side, gravel or grassy areas and paved roadways on all sides, and a truck alley on the southern side.

The K-762 and K-791 Switchyard areas contained concrete slabs and concrete transformer pedestals, and the four Synchronous Condenser superstructure housings in K-791, but were otherwise grass-covered with small shrubs.

Fig. 5.2. Former K-33 building footprint condition looking south (former K-31 building in background)

[EUs Z2-04 and Z2-05].14-060(E)/092815 5-2

Fig. 5.3. K-861 Cooling Tower Basin before fill (EU Z2-09).

Former K-861 Cooling Tower Basin Fig. 5.4. K-861 Cooling Tower Basin after fill (EU Z2-09).14-060(E)/092815 5-3

6. SAMPLING RESULTS All five of the EUs (EUs Z2-03, Z2-05, Z2-06, Z2-07, and Z2-10) associated with this Former K-31 Area EBS were assessed under an approved Work Plan (DOE/OR/01-2182&D4 [DOE 2007b]) prepared according to the DVS process. The Work Plan was approved by EPA and TDEC on December 7 and 13, 2007, respectively. All verified and validated data used to make regulatory decisions have been placed in the OREIS database (http://www-oreis.ettp.energy.gov/oreis/help/oreishome.html) and are available for review. The sampling results and data evaluation can be found in the Appendices of the PCCRs. These data were deemed sufficient to reach NFA decisions under an industrial land use risk scenario for soil and subsurface structures in the five EUs, which are included, either partially or completely, in the Former K-31 Area transfer footprint. EUs Z2-06, Z2-07, and Z2-10 are completely contained in the transfer footprint, and EUs Z2-03 and Z2-05 are partially included in the transfer footprint. The portions of EUs Z2-03 and Z2-05, which are not included in the Former K-31 Area transfer footprint, have previously been included in the transfer footprint for the Former K-33 Area. The locations of soil samples collected under the DVS within the EUs included in the K-31 Area transfer footprint are indicated in Fig. 6.1.

In support of the transfer of the K-792 Switchyard Complex, soil vapor samples were collected through the sub-slab of Bldgs. K-791-B and K-796-A, located approximately 200 ft northwest of the Former K-31 Area transfer footprint, to evaluate the potential vapor intrusion pathway. Sub-slab soil vapor was collected in these buildings during September (dry season) 2006 and February (wet season) 2007 to determine if a potential source for VOCs exists under the buildings. The results were validated, and the average concentration for each VOC was calculated and compared to its respective ETTP soil vapor trigger level (TL); TLs are EPA-approved concentrations calculated to be health protective. In addition, to ensure that the VOCs did not cumulatively exceed TLs, the average concentration for each VOC was divided by its respective TL to determine what fraction the concentration represented. The resulting fractions were then added for all VOCs that had at least one detection. If, collectively, the VOC concentrations had exceeded the TLs, the resulting value would be above 1.0 (i.e., the fractions would add up to over 1.0).

The soil vapor sampling results for Bldgs. K-791-B and K-796-A indicated that none of the VOCs detected in the sampling events exceeded individual TLs, and the sum of TL fractions was below 1.0. Therefore, based on the soil vapor sampling results for these two nearby buildings, the vapor intrusion pathway is not considered complete beneath these buildings. The complete soil vapor results and evaluation are presented in the EBS for the K-792 Switchyard Complex (DOE 2010).

6.1 DATA FOR EU Z2-03 Following is a summary of the sampling results for EU Z2-03. Soil sample locations are indicated in Fig. 6.1. A total of 34 samples were collected under DVS for this EU, and 6 of the 34 sample locations were within the K-31 transfer footprint. Based on DVS and historical sampling analytical results and results of the Class 3 walkover assessment, and evaluation of the data, the following was determined:

There were no maximum RL exceedances in EU Z2-03.

No average contaminant of concern (COC) concentration across EU Z2-03 exceeded its average RL.

There are no sources for groundwater contamination in EU Z2-03.14-060(E)/092815 6-1

PL PO AR E

CR EK K-792 FORMER K-33 BUILDING K-31 LEGEND:

EAST TENNESSEE TECHNOLOGY PARK OAK RIDGE, TENNESSEE Fig. 6.1. DVS sample locations in the Former K-31 Area transfer footprint.

6-2

Although only a portion of the EU is proposed for transfer (the western portion of the EU was previously included in the K-33 transfer footprint), six samples were collected from within the Former K-31 Area transfer footprint portion of the EU. Five of these samples were collected for field test analysis for PCBs.

The results indicated that no PCBs were detected in the field test results for these samples. The remaining sample from the proposed transfer footprint was collected from the K-897-M Oil Containment Structure.

This sediment sample was analyzed for semivolatile organic compounds (SVOCs), PCBs, and VOCs.

The sediment sample from K-897-M contained four SVOCs and PCB-1260 at concentrations below both RLs and residential preliminary remediation goals (PRGs). Because the highest chemical and radiological concentrations detected in soils in EU Z2-03 were detected in the portion of the EU that is not included in the Former K-31 Area transfer footprint, and less than 10% of the 2.1 acres of EU Z2-03 included in the Former K-31 Area transfer footprint contains exposed soils (the remaining acreage is paved, graveled, or concrete), the findings of NFA as described in the approved PCCR are appropriate for the portion of the EU included in the Former K-31 Area transfer footprint.

Because the soil and slab underlying Bldg. K-761 is part of an EU with an approved NFA determination, the land underlying this structure is included in the transfer footprint of this EBS/CDR. The soils beneath K-761 were not sampled under the DVS, but they were included within the scope of the PCCR for EU Z2-03. Sampling locations for this EU were established during DQOs workshops with EPA and TDEC approval, which did not identify a need for samples beneath these facilities. However, as an additional measure for ensuring that no contamination above established Zone 2 RLs remains, when demolition of K-761 is complete, the subsurface soils and/or exposed remaining structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and/or subsurface structures, such as concrete subsurface foundation elements and electrical ducts, meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the FY 2007 PCCR Addendum for Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the FFA.

As documented in the approved PCCR (DOE 2008), NFA is necessary to meet industrial land use in this EU.

6.2 DATA FOR EU Z2-05 Sampling of soil around the outside of the K-33 building was conducted in 2006, prior to demolition of the building (Fig. 6.1). The soil under the building was characterized for DVS by drilling through the slab prior to slab removal but after demolition of the building. DQOs planning assumed the slab would remain in place. With removal of the slab during remedial action, concrete characterization data were no longer necessary. The underlying soil (now exposed) was sampled at statistical and biased locations and a radiological walkover survey of the soil in the former slab footprint was conducted following the slab removal remedial action.

No soil is exposed in the narrow strip of property that is included in EU Z2-05 and addressed in this EBS for the transfer of the Former K-31 Area. This area of EU Z2-05 is completely paved with asphalt, or covered by concrete or gravel. The details of the sampling and analysis conducted under the DVS in EU Z2-05 are presented in Appendix A of the PCCR (DOE 2012). Based on the results of the sampling conducted, and evaluation of the data, the following was determined:

14-060(E)/092815 6-3

There were no maximum RL exceedances in EU Z2-05.

No average COC concentration across EU Z2-05 exceeded its average RL.

There are no sources for groundwater contamination in EU Z2-05.

As documented in the approved PCCR (DOE 2012), NFA is necessary to meet industrial land use in this EU.

As discussed in the EBS for the Former K-33 Area (DOE 2014), gamma walkover surveys were conducted as the K-33 building slab was being removed and confirmation soil samples were collected following slab removal. The sample locations are shown in Fig. 7 of the Z2-04 and Z2-05 PCCR (DOE 2012) and illustrated in Fig. 6.1. These samples showed no results greater than the average RLs.

At DOEs request, Oak Ridge Associated Universities, under the ORISE contract, performed independent verification (IV) of the gamma survey results and reviewed, to the extent possible, preliminary radiological results from the aforementioned soil samples. Judgmental soil samples were collected as a result of gamma walkover survey results. Only one surface soil sample was collected from a judgmental location in EU Z2-05 where elevated direct gamma radiation levels suggested the potential presence of contamination. This sample is representative of current residual concentrations. The results for this sample showed no average or maximum RL exceedances. Additional information on the IV sampling can be found in DOE (2014).

The K-903 concrete slab, located within the strip of EU Z2-05 that is included in the K-31 transfer footprint, is currently posted as containing fixed radioactive contamination. Although not identified in the PCCR for EUs Z2-04 and Z2-05 (DOE 2012), this slab was used as a laydown area during removal of the process tie lines, and it is suspected that contamination was transferred to the slab from the process tie line removal activities. EPA identified the presence of the contaminated pad and requested additional information on the monitoring activities for the pad following review of the PCCR for the K-33/K-31 Process Tie Line Demolition Project (DOE 2014b) in their letter of December 31, 2013 (DOE 2013).

This concrete slab will be removed prior to transfer of the property. Because the soil underlying the K-903 Pad is part of an EU with an approved NFA determination, the land underlying this structure is included in the transfer footprint of this EBS/CDR. The soils beneath the K-903 Pad were not sampled under the DVS, due to the inaccessible nature of the soils. However, to ensure that no contamination above established Zone 2 RLs remains, when removal of the K-903 Pad is complete, the subsurface soils will be characterized during confirmatory sampling to ensure that the soils meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until K-903 Pad removal, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the PCCR Addendum for EUs Z2-04 and Z2-05 in Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the FFA.

6.3 DATA FOR EU Z2-06 Sampling of soil around the outside of the K-31 building was conducted in 2006 prior to demolition of the building (see Fig. 6.1). Additional sampling was performed in 2014 during building demolition.

The results of these sampling efforts are discussed in the PCCR for EU Z2-06 (DOE 2015), and summarized below.14-060(E)/092815 6-4

Sub-slab soil samples were collected at 27 locations beneath the operating floor of the former K-31 building in EU Z2-06. Multiple samples were collected at most locations resulting in a total of 54 soil samples being collected from the top of the soil below the slab to a depth of 10 ft. A summary of the evaluation of EU Z2-06 soil data against Zone 2 ROD criteria is presented in Table 6.1. The analytical data for the sub-slab soil samples were compared to the Zone 2 ROD evaluation criteria. In summary, there is only one Zone 2 ROD evaluation criterion exceedance: technetium-99 (Tc-99) exceeds its groundwater (GW) soil screening level (SSL) in one (313 picocuries per gram [pCi/g]) out of 54 samples.

Potassium-40 (K-40) shows up as exceeding its risk screening level (RSL), but because the K-40 background concentration is so high relative to the RSL, K-40 is not considered as a potential risk problem. PCBs, SVOCs, and VOCs were all detected with PCBs being the most prevalent, but no RLs, nor RSLs, were exceeded. Based on DVS sampling analytical results, the following was determined:

There were no maximum RL exceedances in sub-slab soils in EU Z2-06.

No average contaminant of concern (COC) sub-slab soil concentration exceeded its average RL.

Although one sub-slab soil Tc-99 result, and the average detected Tc-99 concentration (166 pCi/g),

exceeds the GW SSL, given that there are only 2 detects out 54 analyses and that only one of those detects exceeds the Tc-99 groundwater soil screening level (GW SSL), there is insufficient mass of Tc-99 in the EU Z2-06 sub-slab soils to pose a threat to groundwater.

In addition to the sub-slab soil samples, samples were collected from the concrete slab at 30 locations on the operating floor of Bldg. K-31 in EU Z2-06. Twenty-four of these sample locations are paired and consist of a center point sample location plus a composite of four step-out locations, which are sample locations spaced 12.5 ft from the center point location. Twenty-three of the paired sample locations occur at locations where British Nuclear Group (BNG) identified elevated PCBs and one of these locations occurs at a location of elevated radioactivity also identified by BNG. Samples from all center point locations were analyzed for metals, PCBs, radionuclides, and SVOCs. Samples from 22 step-out locations at the historical elevated PCB locations were analyzed for PCBs only and the sample from the other of these locations was analyzed for PCBs and SVOCs. The step-out sample from the historical elevated radioactivity location was analyzed for radionuclides only. The remaining concrete samples from EU Z2-06 were analyzed for metals, PCBs, radionuclides, and SVOCs.

A summary of the screening of EU Z2-06 concrete slab data against the Zone 2 ROD criteria is presented in Table 6.2. In summary, PCBs were detected in every sample and the PCB average RL was exceeded in three samples. However, the average detected PCB concentration (5745 µg/kg) in the EU Z2-06 concrete samples does not exceed the PCB Avg RL (10,000 µg/kg). Other than K-40 concentrations which occur within permissible limits, there are no other Zone 2 ROD criteria exceedances in the EU Z2-06 concrete slab sample results. Based on the DVS concrete sampling results, the following was determined:

There were no maximum RL exceedances in the EU Z2-06 concrete samples.

No average COC concentration across EU Z2-06 exceeded its average RL.

There are no sources for groundwater contamination in the K-31 concrete slab in EU Z2-06.

As an additional measure for ensuring that no contamination above established Zone 2 RLs remains when demolition of K-31 and its slab is completed, the subsurface soils and structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and subsurface structures meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD.14-060(E)/092815 6-5

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Table 6.1. Data summary for EU Z2-06 (K-31) sub-slab soil samplesa (0 to 10 ft)

Frequency Frequency Frequency Frequency Location(s) of of detects of detects of detects of detects Frequency Minimum Maximum maximum detected Average Maximum exceeding Average exceeding RSL (10-5 or exceeding exceeding GW Analyte of detect detectb,c detectb,c result detected result RL maximum RL RL average RL HI = 1) RSL GW SSL SSL Inorganics (mg/kg)

Aluminum 54/54 3200J 18800 Z2-EU06BM-326 9590 NA NA 1100000 0/54 NA Antimony 0/54 ND ND ND NA NA 470 0/54 144 0/54 Arsenic 54/54 2.6J 13.5 Z2-EU06B-216 6.2 900 0/54 300 0/54 300 0/54 66.3 0/54 Barium 54/54 13.2 133 Z2-EU06B-202 30.4 NA NA 220000 0/54 9150 0/54 Beryllium 32/54 0.302J 2.41 Z2-EU06B-324 0.572 NA NA 2300 0/54 NA Boron 32/54 1.12J 5.94 Z2-EU06B-203 2.76 NA NA 230000 0/54 NA Cadmium 50/54 0.0218J 0.439 Z2-EU06B-324 0.073 NA NA 980 0/54 NA Calcium 54/54 1480 270000 Z2-EU06B-203 90169 NA NA NA NA Chromium 54/54 7.42 28.6 Z2-EU06B-342 15.3 NA NA 1800000 0/54 172 0/54 Cobalt 54/54 1.86 16.4 Z2-EU06BM-326 4.62 NA NA 350 0/54 NA Copper 54/54 5.39 26.7J Z2-EU06B-316 10 NA NA 47000 0/54 NA Iron 54/54 8100J 32900 Z2-EU06BM-326 20376 NA NA 820000 0/54 NA Lead 40/54 0.536J 22.9 Z2-EU06B-342 9.04 NA NA 8000 0/54 3370 0/54 Lithium 54/54 7.47 26.9 Z2-EU06B-204 13.8 NA NA 2300 0/54 NA Magnesium 54/54 438 13300 Z2-EU06B-202 4471 NA NA NA NA Manganese 54/54 80.5 2180 Z2-EU06B-342 341 NA NA 26000 0/54 NA Mercury 54/54 0.0148J 0.169 Z2-EU06BM-326 0.06 1800 0/54 600 0/54 600 0/54 NA Molybdenum 35/54 0.223J 3.03 Z2-EU06B-216 0.686 NA NA 5800 0/54 NA Nickel 54/54 3.48 25.8 Z2-EU06BM-326 7.64 NA NA 22000 0/54 NA Potassium 54/54 298 1260 Z2-EU06BM-326 592 NA NA NA NA Selenium 36/54 0.54J 3.92 Z2-EU06B-342 1.14 NA NA 5800 0/54 NA Silver 23/54 0.123J 9.05J Z2-EU06B-316 0.951 NA NA 5800 0/54 NA Sodium 54/54 14.6J 211 Z2-EU06B-316 101 NA NA NA NA Thallium 54/54 0.0699J 0.337J Z2-EU06B-342 0.171 NA NA 12 0/54 10.8 0/54 Uranium 54/54 0.549 1.71 Z2-EU06B-206 0.961 NA NA 3500 0/54 NA Vanadium 54/54 6.57J 41 Z2-EU06B-342 22.5 NA NA 5800 0/54 NA Zinc 54/54 10.5 79 Z2-EU06BM-326 26 NA NA 350000 0/54 NA Organics, pesticides, and PCBs (µg/kg)

PCB-1016 0/54 ND ND ND 100000 0/54 10000 0/54 10000 0/54 NA PCB-1221 0/54 ND ND ND 100000 0/54 10000 0/54 10000 0/54 NA PCB-1232 0/54 ND ND ND 100000 0/54 10000 0/54 10000 0/54 NA PCB-1242 0/54 ND ND ND 100000 0/54 10000 0/54 10000 0/54 NA PCB-1248 0/54 ND ND ND 100000 0/54 10000 0/54 10000 0/54 NA PCB-1254 35/54 1.91J 2240 Z2-EU06B-325 133 100000 0/54 10000 0/54 10000 0/54 NA PCB-1260 26/54 1.39J 730 Z2-EU06B-325 67.7 100000 0/54 10000 0/54 10000 0/54 NA PCB-1262 0/54 ND ND ND 100000 0/54 10000 0/54 10000 0/54 NA PCB-1268 1/54 4.29 4.29 Z2-EU06B-207 4.29 100000 0/54 10000 0/54 10000 0/54 NA Polychlorinated biphenyl 36/54 1.91J 2970 Z2-EU06B-325 178 100000 0/54 10000 0/54 10000 0/54 NA Radionuclides (pCi/g)

Alpha activity 54/54 7.15 30.3 Z2-EU06B-207 17.3 NA NA NA NA Beta activity 54/54 13.1J 38.8J Z2-EU06B-207 20.3 NA NA NA NA Cesium-137 0/54 ND ND ND 20 0/54 2 0/54 2 0/54 NA Cobalt-60 0/54 ND ND ND NA NA 0.582 0/54 NA Neptunium-237 0/54 ND ND ND 50 0/54 5 0/54 5 0/54 NA Plutonium-238 0/54 ND ND ND NA NA 157 0/54 NA Plutonium-239 0/54 ND ND ND NA NA 136 0/54 NA 14-060(E)/092815 6-7

Table 6.1. Data summary for EU Z2-06 (K-31) sub-slab soil samplesa (0 to 10 ft) - cont.

Frequency Frequency Frequency Frequency Location(s) of of detects of detects of detects of detects Frequency Minimum Maximum maximum detected Average Maximum exceeding Average exceeding RSL (10-5 or exceeding exceeding GW Analyte of detect detectb,c detectb,c result detected result RL maximum RL RL average RL HI = 1) RSL GW SSL SSL Potassium-40 54/54 7.27 29.7 Z2-EU06BM-326 11.1 NA NA 2.67 54/54 NA Ra/Th decay seriesd 54/54 0.00001 1.47 Z2-EU06B-332 0.376 15 0/54 5 0/54 NA NA Radium-226 54/54 0.735 2.18 Z2-EU06B-325 1.43 NA NA NA NA Technetium-99 2/54 18.8 313 Z2-EU06BM-210 166 NA NA 8520 0/54 85.6 1/54 Thorium-228e 54/54 0.636 1.78J Z2-EU06B-217 1.3 NA NA NA NA Thorium-230e 41/54 0.87 2.67J Z2-EU06B-332 1.4 NA NA NA NA Thorium-232e 54/54 0.748 1.9J Z2-EU06B-217 1.26 NA NA NA NA Thorium-234 24/54 0.841 3.42 Z2-EU06B-318 1.92 NA NA 4750 0/54 NA Z2-EU06B-201 Uranium-234 48/54 0.656 1.6 Z2-EU06B-207 1.07 7000 0/54 700 0/54 700 0/54 61.1 0/54 Uranium-235 0/54 ND ND ND 80 0/54 8 0/54 8 0/54 61.1 0/54 Uranium-238 53/54 0.56 1.6 Z2-EU06B-207 0.987 500 0/54 50 0/54 50 0/54 61.1 0/54 Semivolatile organics (µg/kg) 1,2,4-Trichlorobenzene 0/54 ND ND ND NA NA 260000 0/54 NA 1,2-Dichlorobenzene 0/54 ND ND ND NA NA 9300000 0/54 NA 1,3-Dichlorobenzene 0/54 ND ND ND NA NA NA NA 1,4-Dichlorobenzene 0/54 ND ND ND NA NA 110000 0/54 NA 2,3,4,6-Tetrachlorophenol 0/54 ND ND ND NA NA 25000000 0/54 NA 2,4,5-Trichlorophenol 0/54 ND ND ND NA NA 82000000 0/54 NA 2,4,6-Trichlorophenol 0/54 ND ND ND NA NA 820000 0/54 NA 2,4-Dichlorophenol 0/54 ND ND ND NA NA 2500000 0/54 NA 2,4-Dimethylphenol 0/54 ND ND ND NA NA 16000000 0/54 NA 2,4-Dinitrophenol 0/54 ND ND ND NA NA 1600000 0/54 NA 2,4-Dinitrotoluene 0/54 ND ND ND NA NA 74000 0/54 NA 2,6-Dinitrotoluene 0/54 ND ND ND NA NA 15000 0/54 NA 2-Chloronaphthalene 0/54 ND ND ND NA NA 93000000 0/54 NA 2-Chlorophenol 0/54 ND ND ND NA NA 5800000 0/54 NA 2-Methyl-4,6-dinitrophenol 0/54 ND ND ND NA NA 66000 0/54 NA 2-Methylnaphthalene 1/54 37.8J 37.8J Z2-EU06B-342 37.8 NA NA 3000000 0/54 NA 2-Methylphenol 0/54 ND ND ND NA NA 41000000 0/54 NA 2-Nitrobenzenamine 0/54 ND ND ND NA NA 8000000 0/54 NA 2-Nitrophenol 0/54 ND ND ND NA NA NA NA 3,3'-Dichlorobenzidine 0/54 ND ND ND NA NA 51000 0/54 NA 3-Nitrobenzenamine 0/54 ND ND ND NA NA NA NA 4-Bromophenyl phenyl ether 0/54 ND ND ND NA NA NA NA 4-Chloro-3-methylphenol 0/54 ND ND ND NA NA 82000000 0/54 NA 4-Chlorobenzenamine 0/54 ND ND ND NA NA 120000 0/54 NA 4-Chlorophenyl phenyl ether 0/54 ND ND ND NA NA NA NA 4-Nitrobenzenamine 0/54 ND ND ND NA NA 1200000 0/54 NA 4-Nitrophenol 0/54 ND ND ND NA NA NA NA Acenaphthene 1/54 190J 190J Z2-EU06B-342 190 NA NA 45000000 0/54 NA Acenaphthylene 0/54 ND ND ND NA NA NA NA Aniline 0/54 ND ND ND NA NA 4100000 0/54 NA Anthracene 1/54 352 352 Z2-EU06B-342 352 NA NA 230000000 0/54 NA Benz(a)anthracene 2/54 96.1J 866 Z2-EU06B-342 481 NA NA 29000 0/54 NA Benzenemethanol 0/54 ND ND ND NA NA 82000000 0/54 NA Benzo(a)pyrene 1/54 774 774 Z2-EU06B-342 774 NA NA 2900 0/54 NA Benzo(b)fluoranthene 1/54 721 721 Z2-EU06B-342 721 NA NA 29000 0/54 NA 14-060(E)/092815 6-8

Table 6.1. Data summary for EU Z2-06 (K-31) sub-slab soil samplesa (0 to 10 ft) - cont.

Frequency Frequency Frequency Frequency Location(s) of of detects of detects of detects of detects Frequency Minimum Maximum maximum detected Average Maximum exceeding Average exceeding RSL (10-5 or exceeding exceeding GW Analyte of detect detectb,c detectb,c result detected result RL maximum RL RL average RL HI = 1) RSL GW SSL SSL Benzo(g,h,i)perylene 3/54 13J 278J Z2-EU06B-342 180 NA NA NA NA Benzo(k)fluoranthene 1/54 344 344 Z2-EU06B-342 344 NA NA 290000 0/54 NA Benzoic acid 1/54 598J 598J Z2-EU06B-317 598 NA NA 3300000000 0/54 NA Bis(2-chloroethoxy)methane 0/54 ND ND ND NA NA 2500000 0/54 NA Bis(2-chloroethyl) ether 0/54 ND ND ND NA NA 10000 0/54 NA Bis(2-chloroisopropyl) ether 0/54 ND ND ND NA NA 220000 0/54 NA Bis(2-ethylhexyl)phthalate 1/54 795J 795J Z2-EU06B-320 795 NA NA 1600000 0/54 2350000 0/54 Butyl benzyl phthalate 0/54 ND ND ND NA NA 12000000 0/54 NA Carbazole 1/54 372 372 Z2-EU06B-342 372 NA NA NA NA Chrysene 2/54 236J 709 Z2-EU06B-342 472 NA NA 2900000 0/54 NA Dibenz(a,h)anthracene 1/54 101J 101J Z2-EU06B-342 101 NA NA 2900 0/54 NA Dibenzofuran 1/54 136J 136J Z2-EU06B-342 136 NA NA 1000000 0/54 NA Diethyl phthalate 0/54 ND ND ND NA NA 660000000 0/54 NA Dimethyl phthalate 0/54 ND ND ND NA NA NA NA Di-n-octylphthalate 0/54 ND ND ND NA NA 8200000 0/54 NA Diphenylamine 0/54 ND ND ND NA NA 21000000 0/54 NA Fluoranthene 2/54 18.9J 2140 Z2-EU06B-342 1079 NA NA 30000000 0/54 NA Fluorene 1/54 192J 192J Z2-EU06B-342 192 NA NA 30000000 0/54 NA Hexachlorobenzene 0/54 ND ND ND NA NA 14000 0/54 NA Hexachlorobutadiene 0/54 ND ND ND NA NA 320000 0/54 NA Hexachlorocyclopentadiene 0/54 ND ND ND NA NA 4900000 0/54 NA Hexachloroethane 0/54 ND ND ND NA NA 580000 0/54 NA Indeno(1,2,3-cd)pyrene 1/54 361 361 Z2-EU06B-342 361 NA NA 29000 0/54 NA Isophorone 0/54 ND ND ND NA NA 24000000 0/54 NA m+p Methylphenol 0/54 ND ND ND NA NA NA NA Naphthalene 1/54 94.4J 94.4J Z2-EU06B-342 94.4 NA NA 170000 0/54 NA Nitrobenzene 0/54 ND ND ND NA NA 220000 0/54 NA N-Nitroso-di-n-propylamine 0/54 ND ND ND NA NA 3300 0/54 NA N-Nitrosomethylethylamine 0/54 ND ND ND NA NA NA NA Pentachlorophenol 0/54 ND ND ND NA NA 40000 0/54 NA Phenanthrene 3/54 13.6J 1890 Z2-EU06B-342 647 NA NA NA NA Phenol 0/54 ND ND ND NA NA 250000000 0/54 NA Pyrene 2/54 316J 1500 Z2-EU06B-342 908 NA NA 23000000 0/54 NA Pyridine 0/54 ND ND ND NA NA 1200000 0/54 NA Volatile Organics (µg/kg) 1,1,1-Trichloroethane 0/6 ND ND ND NA NA 36000000 0/6 97900 0/6 1,1,2,2-Tetrachloroethane 0/6 ND ND ND NA NA 27000 0/6 NA 1,1,2-Trichloroethane 0/6 ND ND ND NA NA 6300 0/6 1370 0/6 1,1-Dichloroethane 0/6 ND ND ND NA NA 160000 0/6 NA 1,1-Dichloroethene 0/6 ND ND ND NA NA 1000000 0/6 1750 0/6 1,2-Dichloroethane 0/6 ND ND ND NA NA 20000 0/6 NA 1,2-Dichloropropane 0/6 ND ND ND NA NA 44000 0/6 NA 2-Butanone 1/6 772 772 Z2-EU06B-204 772 NA NA 190000000 0/6 NA 2-Hexanone 0/6 ND ND ND NA NA 1300000 0/6 NA 4-Methyl-2-pentanone 1/6 1510 1510 Z2-EU06B-204 1510 NA NA 56000000 0/6 NA Acetone 1/6 119 119 Z2-EU06B-204 119 NA NA 67000000 0/6 NA Benzene 1/6 0.456J 0.456J Z2-EU06B-323 0.456 NA NA 51000 0/6 1150 0/6 Bromodichloromethane 0/6 ND ND ND NA NA 13000 0/6 NA 14-060(E)/092815 6-9

Table 6.1. Data summary for EU Z2-06 (K-31) sub-slab soil samplesa (0 to 10 ft) - cont.

Frequency Frequency Frequency Frequency Location(s) of of detects of detects of detects of detects Frequency Minimum Maximum maximum detected Average Maximum exceeding Average exceeding RSL (10-5 or exceeding exceeding GW Analyte of detect detectb,c detectb,c result detected result RL maximum RL RL average RL HI = 1) RSL GW SSL SSL Bromoform 0/6 ND ND ND NA NA 2900000 0/6 NA Bromomethane 0/6 ND ND ND NA NA 30000 0/6 NA Carbon disulfide 0/6 ND ND ND NA NA 3500000 0/6 NA Carbon tetrachloride 1/6 3.07J 3.07J Z2-EU06B-204 3.07 NA NA 29000 0/6 2770 0/6 Chlorobenzene 0/6 ND ND ND NA NA 1300000 0/6 NA Chloroethane 0/6 ND ND ND NA NA 57000000 0/6 NA Chloroform 0/6 ND ND ND NA NA 14000 0/6 1230 0/6 Chloromethane 1/6 0.968J 0.968J Z2-EU06B-318 0.968 NA NA 460000 0/6 NA cis-1,2-Dichloroethene 0/6 ND ND ND NA NA 2300000 0/6 NA cis-1,3-Dichloropropene 0/6 ND ND ND NA NA NA NA Dibromochloromethane 0/6 ND ND ND NA NA 32000 0/6 NA Ethylbenzene 0/6 ND ND ND NA NA 250000 0/6 NA Methylene chloride 0/6 ND ND ND NA NA 3200000 0/6 241 0/6 Styrene 4/6 0.994J 1.11J Z2-EU06B-318 1.06 NA NA 35000000 0/6 NA Tetrachloroethene 0/6 ND ND ND NA NA 390000 0/6 4720 0/6 Toluene 2/6 0.446J 0.504J Z2-EU06B-204 0.475 NA NA 47000000 0/6 502000 0/6 Total Xylene 0/6 ND ND ND NA NA 2500000 0/6 NA trans-1,2-Dichloroethene 0/6 ND ND ND NA NA 23000000 0/6 NA trans-1,3-Dichloropropene 0/6 ND ND ND NA NA NA NA Trichloroethene 0/6 ND ND ND NA NA 19000 0/6 1720 0/6 Vinyl chloride 0/6 ND ND ND NA NA 17000 0/6 176 0/6 a

Stations in summary include Z2-EU06B-201, Z2-EU06B-202, Z2-EU06B-203, Z2-EU06B-204, Z2-EU06B-205, Z2-EU06B-206, Z2-EU06B-207, Z2-EU06B-211, Z2-EU06B-216, Z2-EU06B-217, Z2-EU06B-316, Z2-EU06B-317, Z2-EU06B-318, Z2-EU06B-319, Z2-EU06B-320, Z2-EU06B-321, Z2-EU06B-322, Z2-EU06B-323, Z2-EU06B-324, Z2-EU06B-325, Z2-EU06B-330, Z2-EU06B-331, Z2-EU06B-332, Z2-EU06B-342, Z2-EU06BM-210, Z2-EU06BM-215, and Z2-EU06BM-326.

b The values in these columns are for detected results. Non-detects are not included.

c The J validation qualifier means that the analyte was positively identified and the result is the approximate concentration in the sample; XV signifies that the result was not validated.

d The Ra/Th (radium/thorium) decay series results are calculated values for each sample based on detections of radium-226, thorium-230, and thorium-232 as discussed in the Zone 2 ROD. Because the calculation involves subtraction of background from analytical results and negative numbers are not allowed, 0 (zero) is a legitimate result.

e These radionuclides are not included in aggregate risk calculations for the EU. Instead, human health risk effects of these radionuclides (thorium-228 is included in the thorium-232 decay series) are evaluated with the Ra/Th decay series RLs as discussed in the Zone 2 ROD.

EU = exposure unit. ND = not detected. ROD = Record of Decision.

GW = groundwater. PCB = polychlorinated biphenyl. RSL = risk screening level.

HI = hazard index. pCi/g = picocuries per gram. SSL = soil screening level.

mg/kg = milligram per kilogram. RL = remediation level. µg/kg = microgram per kilogram.

NA = not applicable.14-060(E)/092815 6-10

Table 6.2. Data summary for EU Z2-06 (K-31) concrete samplesa Frequency Frequency Frequency Frequency Location(s) of of detects of detects of detects of detects Frequency Minimum Maximum maximum detected Average Maximum exceeding Average exceeding RSL (10-5 or exceeding exceeding GW Analyte of detect detectb,c detectb,c result detected result RL maximum RL RL average RL HI = 1) RSL GW SSL SSL Inorganics (mg/kg)

Aluminum 18/18 2330 8130 Z2-EU06B-331 6328 NA NA 1100000 0/18 NA Antimony 2/18 0.359J 0.428J Z2-EU06B-332 0.393 NA NA 470 0/18 144 0/18 Arsenic 18/18 1.25J 4.84 Z2-EU06B-330 2.28 900 0/18 300 0/18 300 0/18 66.3 0/18 Barium 18/18 17.1 68 Z2-EU06B-228 51.5 NA NA 220000 0/18 9150 0/18 Beryllium 11/18 0.158J 0.539J Z2-EU06B-224 0.376 NA NA 2300 0/18 NA Boron 18/18 1.92J 20.9 Z2-EU06B-219 5.81 NA NA 230000 0/18 NA Cadmium 16/18 0.0215J 0.127J Z2-EU06B-219 0.064 NA NA 980 0/18 NA Calcium 18/18 32500 113000 Z2-EU06B-331 84983 NA NA NA NA Chromium 18/18 3.69 18.6 Z2-EU06B-330 12.4 NA NA 1800000 0/18 172 0/18 Cobalt 18/18 1.23 105J Z2-EU06B-219 10.2 NA NA 350 0/18 NA Copper 18/18 12.3 43.6 Z2-EU06B-226 31.5 NA NA 47000 0/18 NA Iron 18/18 4380J 16000J Z2-EU06B-330 10836 NA NA 820000 0/18 NA Lead 9/18 0.447J 6.96 Z2-EU06B-224 2.87 NA NA 8000 0/18 3370 0/18 Lithium 18/18 4.89 8.85 Z2-EU06B-332 6.88 NA NA 2300 0/18 NA Magnesium 18/18 1430 4860 Z2-EU06B-211 3631 NA NA NA NA Manganese 18/18 62.3 416 Z2-EU06B-330 235 NA NA 26000 0/18 NA Mercury 7/18 0.00436J 0.0211 Z2-EU06B-210 0.009 1800 0/18 600 0/18 600 0/18 NA Molybdenum 18/18 0.253J 0.956J Z2-EU06B-224 0.643 NA NA 5800 0/18 NA Nickel 18/18 1.87 8.26J Z2-EU06B-219 6.2 NA NA 22000 0/18 NA Potassium 18/18 329 1430J Z2-EU06B-223 719 NA NA NA NA Selenium 16/18 0.541J 7.72 Z2-EU06B-219 1.46 NA NA 5800 0/18 NA Silver 14/18 0.402J 15.6 Z2-EU06B-225 4.98 NA NA 5800 0/18 NA Sodium 18/18 49.8 894J Z2-EU06B-223 337 NA NA NA NA Thallium 0/18 ND ND ND NA NA 12 0/18 10.8 0/18 Uranium 18/18 0.763 2.84 Z2-EU06B-210 1.11 NA NA 3500 0/18 NA Vanadium 18/18 4.03 19.6 Z2-EU06B-330 11.9 NA NA 5800 0/18 NA Zinc 18/18 25 103 Z2-EU06B-226 64.6 NA NA 350000 0/18 NA Organics, pesticides, and PCBs (µg/kg)

PCB-1016 0/29 ND ND ND 100000 0/29 10000 0/29 10000 0/29 NA PCB-1221 0/29 ND ND ND 100000 0/29 10000 0/29 10000 0/29 NA PCB-1232 0/29 ND ND ND 100000 0/29 10000 0/29 10000 0/29 NA PCB-1242 0/29 ND ND ND 100000 0/29 10000 0/29 10000 0/29 NA PCB-1248 0/29 ND ND ND 100000 0/29 10000 0/29 10000 0/29 NA PCB-1254 29/29 1.94J 70000 Z2-EU06B-219A 4442 100000 0/29 10000 3/29 10000 3/29 NA PCB-1260 24/29 1.41J 18900 Z2-EU06B-219A 1557 100000 0/29 10000 2/29 10000 2/29 NA PCB-1262 3/29 48.2 67.6 Z2-EU06B-225 54.7 100000 0/29 10000 0/29 10000 0/29 NA PCB-1268 6/29 2.67J 88J Z2-EU06B-227 39.7 100000 0/29 10000 0/29 10000 0/29 NA Polychlorinated biphenyl 29/29 3.35J 88900 Z2-EU06B-219A 5745 100000 0/29 10000 3/29 10000 3/29 NA Radionuclides (pCi/g)

Alpha activity 19/19 4.32 17.8 Z2-EU06B-331 9.6 NA NA NA NA Beta activity 19/19 5.34J 22.2J Z2-EU06B-220 11.8 NA NA NA NA Cesium-137 0/19 ND ND ND 20 0/19 2 0/19 2 0/19 NA Cobalt-60 0/19 ND ND ND NA NA 0.582 0/19 NA Neptunium-237 0/19 ND ND ND 50 0/19 5 0/19 5 0/19 NA Plutonium-238 0/19 ND ND ND NA NA 157 0/19 NA Plutonium-239 0/19 ND ND ND NA NA 136 0/19 NA 14-060(E)/092815 6-11

Table 6.2. Data summary for EU Z2-06 (K-31) concrete samplesa - cont.

Frequency Frequency Frequency Frequency Location(s) of of detects of detects of detects of detects Frequency Minimum Maximum maximum detected Average Maximum exceeding Average exceeding RSL (10-5 or exceeding exceeding GW Analyte of detect detectb,c detectb,c result detected result RL maximum RL RL average RL HI = 1) RSL GW SSL SSL Potassium-40 19/19 5.36 8.72 Z2-EU06B-220 7.08 NA NA 2.67 19/19 NA Ra/Th decay seriesd 19/19 0 1.19 Z2-EU06B-224 0.081 15 0/19 5 0/19 NA NA Radium-226 19/19 0.485 2.44 Z2-EU06B-224 1.12 NA NA NA NA Technetium-99 1/19 10.2 10.2 Z2-EU06B-210 10.2 NA NA 8520 0/19 85.6 0/19 Thorium-228e 17/19 0.298 1.2 Z2-EU06B-210 0.679 NA NA NA NA Thorium-230e 8/19 0.648 1.17 Z2-EU06B-224 0.855 NA NA NA NA Thorium-232e 19/19 0.391 1.45 Z2-EU06B-227 0.648 NA NA NA NA Thorium-234 4/19 0.756 0.96 Z2-EU06B-224 0.836 NA NA 4750 0/19 NA Uranium-234 10/19 0.506 2.22 Z2-EU06B-210 0.844 7000 0/19 700 0/19 700 0/19 61.1 0/19 Uranium-235 0/19 ND ND ND 80 0/19 8 0/19 8 0/19 61.1 0/19 Uranium-238 7/19 0.448 1.88 Z2-EU06B-210 0.796 500 0/19 50 0/19 50 0/19 61.1 0/19 Semivolatile organics (µg/kg) 1,2,4-Trichlorobenzene 0/19 ND ND ND NA NA 260000 0/19 NA 1,2-Dichlorobenzene 0/19 ND ND ND NA NA 9300000 0/19 NA 1,3-Dichlorobenzene 0/19 ND ND ND NA NA NA NA 1,4-Dichlorobenzene 0/19 ND ND ND NA NA 110000 0/19 NA 2,3,4,6-Tetrachlorophenol 0/19 ND ND ND NA NA 25000000 0/19 NA 2,4,5-Trichlorophenol 0/19 ND ND ND NA NA 82000000 0/19 NA 2,4,6-Trichlorophenol 0/19 ND ND ND NA NA 820000 0/19 NA 2,4-Dichlorophenol 0/19 ND ND ND NA NA 2500000 0/19 NA 2,4-Dimethylphenol 0/19 ND ND ND NA NA 16000000 0/19 NA 2,4-Dinitrophenol 0/19 ND ND ND NA NA 1600000 0/19 NA 2,4-Dinitrotoluene 0/19 ND ND ND NA NA 74000 0/19 NA 2,6-Dinitrotoluene 0/19 ND ND ND NA NA 15000 0/19 NA 2-Chloronaphthalene 0/19 ND ND ND NA NA 93000000 0/19 NA 2-Chlorophenol 0/19 ND ND ND NA NA 5800000 0/19 NA 2-Methyl-4,6-dinitrophenol 0/19 ND ND ND NA NA 66000 0/19 NA 2-Methylnaphthalene 0/19 ND ND ND NA NA 3000000 0/19 NA 2-Methylphenol 0/19 ND ND ND NA NA 41000000 0/19 NA 2-Nitrobenzenamine 0/19 ND ND ND NA NA 8000000 0/19 NA 2-Nitrophenol 0/19 ND ND ND NA NA NA NA 3,3'-Dichlorobenzidine 0/19 ND ND ND NA NA 51000 0/19 NA 3-Nitrobenzenamine 0/19 ND ND ND NA NA NA NA 4-Bromophenyl phenyl ether 0/19 ND ND ND NA NA NA NA 4-Chloro-3-methylphenol 0/19 ND ND ND NA NA 82000000 0/19 NA 4-Chlorobenzenamine 0/19 ND ND ND NA NA 120000 0/19 NA 4-Chlorophenyl phenyl ether 0/19 ND ND ND NA NA NA NA 4-Nitrobenzenamine 0/19 ND ND ND NA NA 1200000 0/19 NA 4-Nitrophenol 0/19 ND ND ND NA NA NA NA Acenaphthene 0/19 ND ND ND NA NA 45000000 0/19 NA Acenaphthylene 0/19 ND ND ND NA NA NA NA Aniline 0/19 ND ND ND NA NA 4100000 0/19 NA Anthracene 0/19 ND ND ND NA NA 230000000 0/19 NA Benz(a)anthracene 0/19 ND ND ND NA NA 29000 0/19 NA Benzenemethanol 0/19 ND ND ND NA NA 82000000 0/19 NA Benzo(a)pyrene 0/19 ND ND ND NA NA 2900 0/19 NA Benzo(b)fluoranthene 0/19 ND ND ND NA NA 29000 0/19 NA 14-060(E)/092815 6-12

Table 6.2. Data summary for EU Z2-06 (K-31) concrete samplesa - cont.

Frequency Frequency Frequency Frequency Location(s) of of detects of detects of detects of detects Frequency Minimum Maximum maximum detected Average Maximum exceeding Average exceeding RSL (10-5 or exceeding exceeding GW Analyte of detect detectb,c detectb,c result detected result RL maximum RL RL average RL HI = 1) RSL GW SSL SSL Benzo(g,h,i)perylene 0/19 ND ND ND NA NA NA NA Benzo(k)fluoranthene 0/19 ND ND ND NA NA 290000 0/19 NA Benzoic acid 0/19 ND ND ND NA NA 3300000000 0/19 NA Bis(2-chloroethoxy)methane 0/19 ND ND ND NA NA 2500000 0/19 NA Bis(2-chloroethyl) ether 0/19 ND ND ND NA NA 10000 0/19 NA Bis(2-chloroisopropyl) ether 0/19 ND ND ND NA NA 220000 0/19 NA Bis(2-ethylhexyl)phthalate 0/19 ND ND ND NA NA 1600000 0/19 2350000 0/19 Butyl benzyl phthalate 0/19 ND ND ND NA NA 12000000 0/19 NA Carbazole 0/19 ND ND ND NA NA NA NA Chrysene 0/19 ND ND ND NA NA 2900000 0/19 NA Dibenz(a,h)anthracene 0/19 ND ND ND NA NA 2900 0/19 NA Dibenzofuran 0/19 ND ND ND NA NA 1000000 0/19 NA Diethyl phthalate 0/19 ND ND ND NA NA 660000000 0/19 NA Dimethyl phthalate 0/19 ND ND ND NA NA NA NA Di-n-octylphthalate 0/19 ND ND ND NA NA 8200000 0/19 NA Diphenylamine 0/19 ND ND ND NA NA 21000000 0/19 NA Fluoranthene 0/19 ND ND ND NA NA 30000000 0/19 NA Fluorene 0/19 ND ND ND NA NA 30000000 0/19 NA Hexachlorobenzene 0/19 ND ND ND NA NA 14000 0/19 NA Hexachlorobutadiene 0/19 ND ND ND NA NA 320000 0/19 NA Hexachlorocyclopentadiene 0/19 ND ND ND NA NA 4900000 0/19 NA Hexachloroethane 0/19 ND ND ND NA NA 580000 0/19 NA Indeno(1,2,3-cd)pyrene 0/19 ND ND ND NA NA 29000 0/19 NA Isophorone 2/19 921J 1980 Z2-EU06B-228A 1450 NA NA 24000000 0/19 NA m+p Methylphenol 0/19 ND ND ND NA NA NA NA Naphthalene 0/19 ND ND ND NA NA 170000 0/19 NA Nitrobenzene 0/19 ND ND ND NA NA 220000 0/19 NA N-Nitroso-di-n-propylamine 0/19 ND ND ND NA NA 3300 0/19 NA N-Nitrosomethylethylamine 0/19 ND ND ND NA NA NA NA Pentachlorophenol 0/19 ND ND ND NA NA 40000 0/19 NA Phenanthrene 0/19 ND ND ND NA NA NA NA Phenol 0/19 ND ND ND NA NA 250000000 0/19 NA Pyrene 0/19 ND ND ND NA NA 23000000 0/19 NA Pyridine 0/19 ND ND ND NA NA 1200000 0/19 NA a

Stations in summary include Z2-EU06-210, Z2-EU06-211, Z2-EU06-215, Z2-EU06-218, Z2-EU06-218A, Z2-EU06-219, Z2-EU06-219A, Z2-EU06-220, Z2-EU06-220A, Z2-EU06-221, Z2-EU06-221A, Z2-EU06-222, Z2-EU06-222A, Z2-EU06-223, Z2-EU06-223A, Z2-EU06-224, Z2-EU06-224A, Z2-EU06-225, Z2-EU06-225A, Z2-EU06-226, Z2-EU06-226A, Z2-EU06-227, Z2-EU06-227A, Z2-EU06-228, Z2-EU06-228A, Z2-EU06-229, Z2-EU06-229A, Z2-EU06-330, Z2-EU06-331, and Z2-EU06-332.

b The values in these columns are for detected results. Non-detects are not included.

c The J validation qualifier means that the analyte was positively identified and the result is the approximate concentration in the sample; XV signifies that the result was not validated.

d The Ra/Th (radium/thorium) decay series results are calculated values for each sample based on detections of radium-226, thorium-230, and thorium-232 as discussed in the Zone 2 ROD. Because the calculation involves subtraction of background from analytical results and negative numbers are not allowed, 0 (zero) is a legitimate result.

e These radionuclides are not included in aggregate risk calculations for the EU. Instead, human health risk effects of these radionuclides (thorium-228 is included in the thorium-232 decay series) are evaluated with the Ra/Th decay series RLs as discussed in the Zone 2 ROD.

EU = exposure unit. ND = not detected. ROD = Record of Decision.

GW = groundwater. PCB = polychlorinated biphenyl. RSL = risk screening level.

HI = hazard index. pCi/g = picocuries per gram. SSL = soil screening level.

mg/kg = milligram per kilogram. RL = remediation level. µg/kg = microgram per kilogram.

NA = not applicable.14-060(E)/092815 6-13

If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the EU Z2-06 PCCR in Zone 2. The PCCR will be submitted for formal review and approval in accordance with Sect. XXI of the FFA.

6.4 DATA FOR EU Z2-07 Following is a summary of the sampling results for EU Z2-07, which is included in its entirety in the proposed transfer footprint. Soil samples collected under the DVS are shown in Fig. 6.1. There were 13 systematic grid samples and 5 biased samples collected under the DVS within this EU. Two sediment samples were collected from the K-897-E and K-897-F Oil Containment structures. Samples were analyzed for metals, PCBs, radionuclides, SVOCs, and VOCs. Based on both historical and DVS sampling results, the results of the Class 3 walkover assessment, and evaluation of the data as documented in the PCCR (DOE 2006), the following was determined:

There were no maximum RL exceedances in EU Z2-07.

No average COC concentration across EU Z2-07 exceeded its average RL.

There are no sources for groundwater contamination in EU Z2-07.

Thus, as documented in the approved PCCR (DOE 2006), NFA is necessary to meet industrial land use in this EU.

6.5 DATA FOR EU Z2-10 Following is a summary of the sampling results for EU Z2-10, which is included in its entirety in the proposed transfer footprint. Soil samples collected under the DVS are shown in Fig. 6.1. There were six biased samples collected under the DVS within this EU. These locations included one sample from the sediment in the K-897-G Oil Containment structure. Samples were analyzed for metals, PCBs, radionuclides, SVOCs, and VOCs. Based on both historical and DVS sampling results, the results of the Class 3 walkover assessment, and the evaluation of the data documented in the PCCR (DOE 2006), the following was determined:

There were no maximum RL exceedances in EU Z2-10.

No average COC concentration across EU Z2-10 exceeded its average RL.

There are no sources for groundwater contamination in EU Z2-10.

Thus, as documented in the approved PCCR (DOE 2006), NFA is necessary to meet industrial land use in this EU.14-060(E)/092815 6-14

7. RISK EVALUATION The Zone 2 remedial action objectives (RAOs) were developed by the DVS process to support the future use of the Heritage Center as a mixed-use commercial and industrial park. Therefore, remediation criteria were designed for the protection of the future industrial worker.

Within that constraint, the decision rules established in the DVS were based on one or more of the following criteria:

exceedance of a Max RL at any location, exceedance of an Avg RL across the EU, unacceptable future threat to groundwater, or unacceptable cumulative ELCR of > 1 x 10-4 and HI > 1 across the EU.

The National Contingency Plan (NCP) preamble (55 Federal Register 8716, March 8, 1990) describes the process used to establish the remediation goal for environmental media as consisting of a two-step approach. First, an individual lifetime excess cancer risk of 10-6 is used as a starting point for establishing remediation goals for the risks from contaminants at specific sites. The second step involves consideration of a variety of site-specific or remedy-specific factors, which enter into the determination of where, within the risk range, the cleanup standard for a given contaminant will be established. The factors considered in the development of the Zone 1 and Zone 2 RODs and subsequent steps in the implementation of the RODs, such as the DVS, included an acceptable cumulative risk level of 10-4, which is the upper bound of the EPA acceptable risk range. From the Zone 2 ROD (Sect. 1.4): The remedial action objective (RAO) for Zone 2 is to Protect human health under an industrial land use to an excess cancer risk at or below 10-4. A comparable statement is included in the Zone 1 ROD. Zone 1 and 2 RAOs were developed by the DVS to support the future use of 10-4 cumulative ELCR across the EU as one of the decision criteria. To achieve the RAO, constituent-specific cleanup goals were developed.

Per the NCP preamble, these cleanup goals are to be based on a risk level of 10-6 for individual constituents unless site-specific or remedy-specific factors exist to suggest modifications are appropriate.

For the Zone 1 and Zone 2 RODs, these factors include the following:

Site-Specific Exposure Factors Exposure of the industrial worker is limited to soil-related pathways only (multiple media exposures are not applicable to this scenario).

The limited COC list indicates that the potential for a large number of remedial goal exceedances was considered unlikely in the ROD, allowing for a higher risk level for each COC considered, while still achieving a cumulative risk <10-4. However, the ROD indicates that additional COCs were identified in four EUs within Zone 2, and additional COCs may be identified from the characterization sampling to be conducted for a wide range of potential contaminants.

Remedy-Specific Technical Factors Remedial goals for particular COCs were generated at a risk level >10-5 due to cost prohibitiveness and impracticality of remediation to a lower concentration.14-060(E)/092815 7-1

Remedial goals for particular COCs were revised to reflect consideration of elevated background levels.

Incorporation of these factors provided RLs that reflect the RAO of achieving a cumulative human health risk that will not exceed 10-4 for a given EU or FFA site. A summary of the risk evaluation results for the Zone 2 EUs addressed in this EBS is provided in Table 7.1.

Table 7.1. Risk evaluation results for the Former K-31 Area Associated FFA sites Decision rule evaluationa within the transfer Risk Final status EU footprint Max RL Avg RL Risk GW evaluation decisiona K-762 Valve Vault (also identified as K-869)

Z2-03 NFA NFA NFA NFA Passes NFA for soils K-879-M Oil Containment Structure Z2-05 None NFA NFA NFA NFA Passes NFA for soils NFA NFA NFA NFA NFA for soils Z2-06 None Passes recommended recommended recommended recommended recommended K-897-E Oil Containment Structure Z2-07 NFA NFA NFA NFA Passes NFA for soils K-897-F Oil Containment Structure K-897-G Oil Z2-10 Containment NFA NFA NFA NFA Passes NFA for soils Structure a

Decision rule, risk evaluation, and final status information are from:

Fiscal Year 2006 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2317&D2 (DOE 2006).

Fiscal Year 2007 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2723&D2 (DOE 2008).

Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2590&D1 (DOE 2012).

Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-XXXX (DOE 2015) [NFA recommended, D1 version to EPA and TDEC in November 2015 (planned)].

Avg = average. Max = maximum.

EU = exposure unit. NFA = No Further Action.

FFA = Federal Facilities Agreement. RL = remediation level.

GW = groundwater.14-060(E)/092815 7-2

An evaluation of risk from exposure to soils and subsurface structures is documented in the approved PCCRs for the EUs included in the proposed transfer footprint. The results of the risk evaluations for all five EUs included in the Former K-31 Area transfer footprint indicate that the risk to an industrial worker is less than 1 x 10-4 ELCR, and the target organ HI is less than, or equal to, 1. Thus, all five EUs meet the RAOs of the Zone 2 ROD, and no further action is necessary.

An evaluation of the potential impact on the DVS decisions was conducted for the two EUs that are only partially included in the transfer footprint due to the difference in transfer footprint and EU boundaries.

This evaluation is summarized in Chap. 6, and the results of the evaluation indicated the following:

EUs Z2-06, Z2-07, and Z2-10 are fully contained within the transfer footprint, and the results of the risk evaluation documented in the PCCRs, which indicated that no average concentration of chemicals or radionuclides exceeded the industrial PRGs, are valid for these three EUs. (Only K-40 exceeded its RSL [2.67 pCi/g] in the EU Z2-06 sub-slab soil data. Since neither the K-40 maximum detected concentration [29.7 pCi/g] nor its average detected concentration [11.1 pCi/g] exceeded the K-40 background concentration [32.12 pCi/g], K-40 is not considered as a contributor to risk.) As an additional measure for ensuring that no contamination above established Zone 2 RLs remains when demolition of K-31 and its slab are completed, the subsurface soils and structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and subsurface structures meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the EU Z2-06 PCCR in Zone 2. The PCCR will be submitted for formal review and approval in accordance with Sect. XXI of the FFA.

Although there were PCB and K-40 RSL exceedances in the EU Z2-06 concrete slab data (see Table 6.2), the K-31 building slab will be removed; thus, there will be no risk/hazard associated with the pad.

The portion EU Z2-03 that has not been included in the K-33 transfer footprint contains six sample locations collected under the DVS. These samples were analyzed for PCBs using field test kits.

There were no detections of PCBs indicated by the test kit results. The K-761 building occupies a significant portion of the transfer footprint. Because the soil and slab underlying Bldg. K-761 are part of an EU with an approved NFA determination, the land underlying this structure is included in the transfer footprint of this EBS/CDR. The soils beneath K-761 were not sampled under the DVS, due to their inaccessible nature beneath the building, but they were included within the scope of the PCCR for EU Z2-03. However, to ensure that no contamination above established Zone 2 RLs remains, when demolition of K-761 is complete, the subsurface soils and/or exposed remaining structures, if any, will be characterized during confirmatory sampling to ensure that the soils and/or subsurface structures, such as concrete subsurface foundation elements and electrical ducts, meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the FY 2007 PCCR Addendum for Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the FFA.14-060(E)/092815 7-3

A small portion of EU Z2-05, which was not included in the K-33 transfer footprint, is included in the transfer footprint for K-31. This area located immediately north of the former K-31 building was needed as a buffer for the K-31 building demolition. There are essentially no soils exposed in this narrow strip of property, as can be seen in Fig. 7.1. The area is completely paved with asphalt or covered with concrete; thus, no DVS samples were collected from this portion of the EU. The results of the risk evaluation described in the PCCR (DOE 2012) indicated that EU Z2-05 meets the Zone 2 ROD requirements for industrial use. Although the K-903 Pad currently remains in this strip of land, the pad will be addressed prior to transfer of the property. The soils beneath the K-903 Pad were not sampled under the DVS, but they were included within the scope of the PCCR for EUs Z2-03 and Z2-05. Sampling locations for this EU were established during DQOs workshops with EPA and TDEC approval, which did not identify a need for samples beneath these facilities. However, as an additional measure for ensuring that no contamination above established Zone 2 RLs remains, when removal of the K-903 Pad is complete, the subsurface soils will be further characterized during confirmatory sampling to ensure that the soils meet the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until K-903 Pad removal, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the PCCR Addendum for EUs Z2-04 and Z2-05 in Zone 2. The PCCR Addendum will be submitted as a modification for formal review and approval in accordance with Sect. XXI of the FFA.

Fig. 7.1. Aerial view of north side of K-31 building prior to demolition.

DVS sampling of EU Z2-06, including 54 samples of the soils underlying the K-31 slab, detected no contamination above average or maximum RLs. An NFA determination has been recommended in the draft Technical Memorandum that was provided to EPA in March 2015; hence, the land underlying the K-31 building is included in the transfer footprint of this EBS. As an additional measure for ensuring that no contamination above established Zone 2 RLs remains when demolition of these structures is completed, the subsurface soils and structures, if any, will be further characterized during confirmatory sampling to ensure that the soils and subsurface structures meet 14-060(E)/092815 7-4

the Zone 2 ROD RLs. If contamination above ROD RLs were discovered, appropriate actions would be taken pursuant to the Zone 2 ROD. If the contamination were significant enough to require planning then it would be milestoned in FFA Appendix E and/or J. The underlying land will not be transferred until building demolition, confirmatory soil sampling, and soil remedial actions, if any, are completed. The results of the confirmatory sampling and any necessary remediation will be documented in a Concurrence Form and the EU Z2-06 PCCR for Zone 2. The PCCR will be submitted for formal review and approval in accordance with Sect. XXI of the FFA.

In addition to the individual EU evaluations, a roving worker scenario was also evaluated in the risk assessment to evaluate exposure to a worker from adjacent property. The roving worker evaluation was based on certain assumptions, including: (1) the worker will not be exposed to areas that are inaccessible due to radiological or other controls, such as fences or other barriers, or postings that prevent casual entry by a worker at a nearby building; and (2) there are no hotspots of contamination at the Heritage Center that are accessible to these workers. The results of the roving worker risk screen, which used all available data, show that risk was 1.8 x 10-5, which is within the EPA acceptable risk range of 10-4 to 10-6. The calculated hazard for the roving worker was 0.33, which is below the EPA acceptable level of 1.0.

As a part of the ongoing Heritage Center cleanup, soil data and confirmatory sampling continue to be collected and have been used to support numerous NFA decisions in Zone 1 and Zone 2 under an industrial land use risk scenario. All of the EU components within which the Former K-31 Area proposed transfer footprint is located have either obtained NFA concurrence from the regulators or have met the requirements for NFA and regulator concurrence is pending. Based on these NFA determinations, which address soil and subsurface structures under an industrial worker exposure scenario, and based on consideration of potential impacts to surface water, groundwater, and ecological receptors, the proposed transfer footprint is suitable for the intended industrial use.14-060(E)/092815 7-5

8. REFERENCES BJC (Bechtel Jacobs Company LLC) 2009. Data Quality Objective Scoping Package for the K-31/K-33 Buildings (EUs Z2-04, Z2-05, and Z2-06) at the East Tennessee Technology Park, Oak Ridge, Tennessee, BJC/OR-3234, Bechtel Jacobs Company LLC, Oak Ridge, TN.

COE (U.S. Army Corps of Engineers) 1998. Personal communication with Bill Barnes of the U.S. Army Corps of Engineers on April 6, 1998.

DOE (U.S. Department of Energy) 1992. Federal Facility Agreement for the Oak Ridge Reservation, DOE/OR-1014, U.S. Department of Energy, U.S. Environmental Protection Agency, Region 4, and Tennessee Department of Environment and Conservation, U.S. Department of Energy, Washington, D.C.

DOE 1996. Groundwater Remedial Site Evaluation Report for the Oak Ridge K-25 Site, Oak Ridge, Tennessee, DOE/OR/01-1468V1&D1, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, May.

DOE 1997. Engineering Evaluation/Cost Analysis for Equipment Removal and Building Decontamination for Buildings K-29, K-31, and K-33, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/02-1579/D2, Jacobs Engineering, Oak Ridge, TN.

DOE 2002. Record of Decision for Interim Actions in Zone 1 of East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-1997&D2, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, October.

DOE 2003. Environmental Assessment Addendum for the Proposed Title Transfer of East Tennessee Technology Park Land and Facilities, DOE/EA-1175-A, U.S. Department of Energy, Oak Ridge Operations, Oak Ridge, TN, July.

DOE 2005. Record of Decision for Soil, Buried Waste, and Subsurface Structure Actions in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2161&D2, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, March.

DOE 2006. Fiscal Year 2006 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2317&D2, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, December.

DOE 2007a. Remedial Design Report/Remedial Action Work Plan for Zone 2 Soils, Slabs, and Subsurface Structures, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2224&D2, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

DOE 2007b. Remedial Action Work Plan for Dynamic Verification Strategy for Zone 1, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2182&D4, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, February.

DOE 2007c. Fiscal Year 2006 Phased Construction Completion Report for the Low Risk/Low Complexity Facilities of the Remaining Facilities Demolition Project at the East Tennessee Technology Park,14-060(E)/092815 8-1

Oak Ridge, Tennessee, DOE/OR/01-2327&D2, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, April.

DOE 2008. Fiscal Year 2007 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2723&D2, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, September.

DOE 2010. Environmental Baseline Survey Report for the Proposed Transfer of the K-792 Switchyard Complex at the East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2347, Final-Concurred, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, January.

DOE 2011. Environmental Assessment, Transfer of Land and Facilities Within the East Tennessee Technology Park and Surrounding Area, Oak Ridge, Tennessee, DOE/EA-1640, U.S. Department of Energy, Oak Ridge Operations, Oak Ridge, TN, October.

DOE 2012. Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2590&D1, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, November.

DOE 2013. Phased Construction Completion Report for the K-33/K-31 Process Tie Line Demolition Project at the East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2620&D1, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, September.

DOE 2014. Environmental Baseline Survey Report for the Proposed Title Transfer of the Former K-33 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-2658, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN, September.

DOE 2015 (in preparation). Phased Construction Completion Report for Exposure Unit Z2-06 in Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/OR/01-XXXX, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN.

EPA (U.S. Environmental Protection Agency) 1994. Radon Prevention in the Design and Construction of Schools and Other Large Buildings, Third Printing with Addendum, June 1994, EPA/625/R-92/016.

Office of Research and Development, Washington D.C.

Energy Systems 1995. Site Descriptions of Environmental Restoration Units at the Oak Ridge K-25 Site, Oak Ridge, Tennessee, K/ER-47/R1, authored by P. L. Goddard, et al., Lockheed Martin Energy Systems, Inc., K-25 Site, Oak Ridge, TN, November.

Lemiszki, P. J. (compiler) 1994. Geological Mapping of the Oak Ridge K-25 Site, Oak Ridge, Tennessee, K/ER-111, Environmental Restoration Division, Oak Ridge K-25 Site, Martin Marietta Energy Systems, Inc., Oak Ridge, TN.

TVA (Tennessee Valley Authority) 1998. Personal communication with Jimmy Massengill of the Tennessee Valley Authority on April 6, 1998.

UCOR (URS l CH2M Oak Ridge LLC) 2012a. Personal communications with Bob Kiser (employed at the East Tennessee Technology Park) in August 2012.14-060(E)/092815 8-2

APPENDIX A REAL ESTATE ACQUISITION LETTER 14-060(E)/092815

A-3 A-4 APPENDIX B STUDY AREA MAP FROM RECORDS SEARCH 14-060(E)/092815

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APPENDIX C PCCR APPROVAL LETTERS14-060(E)/092815

E ' 0)2.,1, 65l 0100 i)~ ~ .3 )..3 ..l-'(2:,

~~"r DOE*07*0114 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

" REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303*8960 1-10033-0278 Certified Mail Return Receipt Requested 4WD-FFB Mr. David G. Adler, Project Manager Federal Facilities Agreement Oak Ridge Reservation Management Group Department of Energy P.O. Box 2001 Oak Ridge, TN 37831 SUBJ: EPA Approval of the Fiscal Year 2006 Phased Construction Completion Report for the Zone 2 Soils, Slabs, and Subsurface Structures at East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/ORlOI-2317 &D2)

Dear Mr. Adler:

The Environmental Protection Agency (EPA) has reviewed the above-referenced document which was submitted on January 29,2007. The Phased Construction Completion Report (PCCR) for the Zone 2 Soils, Slabs, and Substructures serves to:

• document the characterization results of the Dynamic Verification Strategy (DVS) for the accessible Exposure Units (EU) in Zone 2;

• describe and document the risk evaluation for each EU evaluated under the DVS and the determination of whether the EU met the Zone 2 Record of Decision (ROD) requirements for unrestricted industrial use to 10 feet below ground surface;

• identifY additional areas not defined in the Zone 2 ROD that require remediation based on the DVS evaluation results;

• evaluates 20 Federal FacilityAgreement (FFA) sites and recommends no further action (NFA) for 11 of these sites;

• deferring NFA determination on the remaining nine FFA sites located in EU Z2-42 until the remedial action (removing approximately 30 cubic feet ofsoil)is cOJ;nplete in that EU;

• recommends 108.8 acres for unrestricted industrial use to 10 feet below ground surface; and RBCllHlED fEB 2 8 2007 Internet Address (URL)

• http;lIwww,epa,gov RocyclodJRGcycililbl0

• Prlnlod with V~gQlabte on Based Inks on Recyekld Pe.por (Minimum 30'% Postcot'lSumer)

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• provided a qualitative assessment that the 108.8 acres had a low probability of being released for unrestricted industrial land use throughout the soil zone.

The EPA has no further comments on this document and is approving the PCCR as submitted. Although this interim remedial action document is approved, the Department of Energy should ensure that the Zone 2 Remedial Action Report (RAR) clearly specifies all land use controls implemented for all acreage within Zone 2, including all changes to the dig restLictions below 10 feet. Revising the industrial land use restrictions may require further specification of the remaining land use controls (e.g.,

restrictions on digging into contaminated aquifers). The current discussions to remove these controls need to conclude with an agreement between the FFA Parties regarding the specific conditions to apply pLior to submitting the Dl RAR.

The EPA commends the efforts of the Remedial Action Core Team to achieve this major milestone for Zone 2. If you have any questions regarding this matter, please feel free to contact Constance Jones of my staff at (404) 562-8551.

Sincerely, " ~

J!:!i~f:t:ttut Federal Facilities Branch Chief Superfund Division cc: R. Doug McCoy, TDEC Patricia Halsey, DOE James Kopotic, DOE Thomas Gebhart, TDEC

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C-5 C-6 DOE~13~0075 1-10033-0700 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303*8960 February 6, 2013 CERTIFIED MAIL RETURN BECEIPT REQUESTED Mr. John Michael Japp, Project Manager Federal Facilities Agreement Oak Ridge Reservation Management Group Department of Energy P.0. Box 2001 Oak Ridge, 1N 37831

Dear Mr. Japp:

The U.S. Environmental Protection Agency has received and reviewed the document titled "Phased Construction Completion Report for Exposure Units Z2-04 and Z2-05, at the East Tennessee Technology Park, Oak Ridge, Tennessee (DOE/OR/01-2590&D1)," which was transmitted by the Department of Energy on December 19,2012.

The review of this document did not identify any factual omissions or discrepancies which warranted revision. Therefore, the EPA is approving the document as submitted.

If you have questions regarding this matter, please contact me at (404) 562-8551.

[;~??

Constance Allison Jones, Senior RPM AUFLIMS!I'N Federal Oversight Section Federal Facilities Branch Superfund Division cc: Roger Petrie, TDEC Patricia Halsey, DOE James Kopotic, DOE Michael Travaglini, DOE Thomas Gebhart, TDEC ORSSAB

~tECEIVED 20 Internet Address (URL)

• http://www.epa.gov , ~ j *.:y b b 0 Recycled/Recyclable

• Prfnled with Vegetable oA Based Inks on Rocyc:led Paper (Minimum 30% Poalcansumlll) ,

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1-10033-0256 STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION DOE OVERSIGHT DIVISION 761 EMORY VALLEY ROAD OAK RIDGE. TENNESSEE 37830-7072 December 8, 2006 Mr. David Adler DOE FFA Project Manager PO Box 2001 Oak Ridge, TN 37830 Dear Mr. Adler TDEC Approval Letter PCCR for the Zone 2 Soils, Slabs, and Subsurface Structures East Tennessee Technology Park, Oak Ridge, Tennessee DOE/ORlOl-2317&D1, September 2006 The Tennessee Department of Envirorunent and Conservation, DOE Oversight Division has reviewed the above referenced document pursuant to the Federal Facility Agreement for the Oak Ridge Reservation. The State approves this document upon resolution of the EPA's comments.

Questions or comments concerning the contents of this letter should be directed to Erin Dixon or Thomas Gebhart at the above address or by phone at (865) 481-0995.

Res ,ctfully I ' ;J /CCrl.

a i

R. Dou ceo; v FFA Project Manager cc Jeff Crane-EPA Pat Halsey - DOE Donna Perez - DOE er779.10 RECEIVED DEC 1 92006 C-9

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DOE-13-0115 1-10033-0708 STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION DOE OVERSIGHT DIVISION 781 EMORY VALLEY ROAD OAK RIDGE, TENNESSEE 37830o7072 February 8, 2013 John Michael Japp DOE FFA Project Manager POBox2001 Oak Ridge, TN 37831 Dear Mr. Japp TDEC Approval Letter Phased Construction Completion Report for Exposure Units Z2-o4 and Z2-05 In Zone 2, East Tennessee Technology Park, Oak Ridge, Tennessee DOE/OR/01-2590&D1 November, 2012 The Tennessee Department of Environment and Conservation, DOE Oversight Division has reviewed the above referenced document pursuant to the Federal Facility Agreement for the Oak Ridge Reservation.

This PCCR is well organized, concise, and literate. No comments were generated during the review of this PCCR and therefore the State approves the document as presented.

Questions or comments concerning the contents of this letter should be directed to Thomas Gebhart at the above address or by phone at (865) 481-0995.

Sincerely Rof:e FFA Project Manager xc: JeffCrane-EPA Pat Halsey- DOE Jim Kopotic- DOE David Adler - DOE L_.

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DOE/OR/01-2677 FINAL - CONCURRED DISTRIBUTION FileEMEF DMCRC