Cornell University Radiation Disposal Site Feasibility Study February 1999 EXECUTIVE SUMMARY McLaren/Hart, at Cornell University’s request, has performed a feasibility study to identify the most appropriate and cost-effective clean-up and containment approach for Cornell’s radiation disposal site in Lansing, New York. The study was conducted in two major phases: 1) a preliminary screening of alternatives based on their effectiveness and implementability in meeting remedial goals and objectives for the site 2) a detailed comparison of the proposed alternatives to a list of seven criteria specified in the New York State Technical and Administrative Guidance Memorandum, for the selection of remedial actions at inactive hazardous waste sites and numerical ranking of the alternatives using these criteria. This process identified the approach that is consistent with regulatory requirements, meets site-specific goals and objectives for remediation, and is cost effective. The final remedy will be selected by the New York State Department of Environmental Conservation (NYSDEC) in a formal process that seeks and considers public opinion. Once selected, the NYSDEC will document the final remedy in a Record of Decision (ROD) that will be implemented by Cornell. The radiation disposal site is located north of Snyder Road in the Town of Lansing, Tompkins County, New York. It is an approximately two-acre inactive low-level radioactive waste landfill. The site was operational from the late 1950s through June 1978, during which time wastes generated during radiological research activities were buried in trenches excavated at the site. Based on RDS site dimensions the estimated maximum volume of the RDS waste material is 1,044,000 cu. ft. or 38,667 cu. yards of which approximately 255,000 cubic feet (9,400 cubic yards) comprises low level radioactive waste. In 1996 an interim cap was installed over the disposal area, drainage was improved, and access to the site was further restricted using improved fencing and locking gates. A remedial investigation and supplemental remedial investigation were performed at the site from October 1995 through December 1997. The major conclusions from these investigations, as they relate to the feasibility study, are: 1) both ground water and surface water are the media requiring remediation 2) tritium, strontium-90, paradioxane, dichloroethylene, and benzene are the contaminants of concern in ground water 3) paradioxane is the contaminant of concern in surface water 4) the contaminant that is most widespread in the ground water plume is paradioxane, which is used to define the maximum extent of ground water contamination, and 5) cleaning and containing the ground water will also clean the surface water The primary contaminant transport pathway is through the ground water via a shallow, highly fractured bedrock zone. The highest concentrations of contaminants are observed in monitoring wells immediately adjacent to the site. It is estimated that 96% (by mass) of the paradioxane plume with concentrations greater than 50 parts per billion (ppb) is within the bounds of the Cornell University property north of Snyder Road. NYSDEC has set a preliminary clean-up criterion of 50 ppb for paradioxane for ground water at the site. Detection of paradioxane in surface waters generally has been limited to those sample locations north of Snyder Road. Capping the site eliminated potential impacts from runoff upon surface water. It also halted infiltration of surface water through waste materials in the site disposal area. The conceptual plan for an Interim Remedial Measure was approved by the NYS Department of Environmental Conservation in August of 1998. This second interim remedial measure is planned for 1999. A series of ground water extraction wells, located just north of Snyder Road and downgradient of the disposal area, will be used to collect and monitor ground water issuing from the radiation disposal site. Recovered ground water will be pumped to the plant located next to Cornell’s chemical disposal site for treatment by a specially designed mechanism. Discharge standards for the plant are being modified by the NYSDEC to include the addition of the radiation disposal site’s treated water; after treatment to meet these discharge standards the water will eventually be discharged as surface water. Procedures and criteria used in this feasibility study were designed to select the most environmentally sound, technically feasible, and cost-effective remedial action alternative for this site. This was accomplished through a phased evaluation that included defining goals and objectives, identifying and screening appropriate remedial technologies and alternatives, and conducting a detailed and comparative analysis of retained alternatives. The site-specific goals and objectives that were developed for the site are as follows: Minimize future contaminant releases from the radiation disposal site Meet regulatory requirements Eliminate or minimize off-site migration of contaminated surface water and ground water Minimize the generation of new radioactive and mixed (radioactive and hazardous) wastes during the remediation process As part of the preliminary remedial alternative evaluation, six alternatives were developed for the site. These were: Alternative 1: No further action beyond capping and ground water interim remedial measures Alternative 2: Containment of source area with a slurry wall and a grout curtain; ground water recovery, treatment, and discharge; and natural attenuation. Alternative 3: Containment of source area with a slurry wall; source area ground water and ground water recovery, treatment, and discharge; and natural attenuation Alternative 4: Containment of source area with a slurry wall, a grout curtain, and bottom sealing; ground water recovery, treatment, and discharge; and natural attenuation Alternative 5: Excavation of source area and off-site disposal; ground water recovery, treatment, and discharge; and natural attenuation Alternative 6: Excavation of source area and on-site disposal in a new landfill; ground water recovery, treatment, and discharge; and natural attenuation. All of the alternatives evaluated as final remedies for the site incorporate both the capping and ground water interim remedial measures, as appropriate. The capital costs of the interim measures have not been included in the cost estimates for the alternatives. The operation and maintenance costs of the interim measures have been included for each alternative, as appropriate. In the preliminary screening, the six alternatives were evaluated primarily on: their ability to meet site-and-medium-specific remedial goals their implementability, and their short-term and long-term effectiveness. All alternatives except the first comply with all the requirements of the New York State Standards, Criteria, and Guidelines and the site-specific remedial goals and objectives. Based on the preliminary screening, only Alternative 4 was not retained for further analysis; it involves placing a bottom seal of grout below the disposal area using horizontal drilling. This technology would have been far more difficult to implement, and no more effective than other alternatives screened (such as Alternative 2). Following the preliminary screening, a detailed comparative analysis was performed for the five remaining alternatives. Each was evaluated against the following seven factors, together with an eighth non-weighted criteria of community acceptance: protection of human health and environment compliance with the New York State Standards, Criteria, and Guidelines short-term effectiveness (construction phase) long-term effectiveness (operations phase) reduction of contaminants’ toxicity, mobility, and volume implementability, and cost With the exception of Alternative 1, the overall ratings of the alternatives were comparable when evaluated against the first six criteria listed above. Generally, all the alternatives provided overall protection of human health and environment, with Alternative 1 providing the least protection. The estimated costs developed for comparison of the alternatives ranged from $5,826,000 for Alternative 1 to $154,807,000 for Alternative 5. With NYSDEC guidance, a numerical scoring was made for each of the alternatives using the criteria identified above. The scores ranged from a low of 62 for Alternative 1 to a high of 79 for Alternative 2, with the higher value indicating greater compliance with the evaluation criteria. Based upon this comparative analysis, Alternative 2, containment with a slurry wall and a grout curtain; ground water recovery, treatment, and discharge, and natural attenuation, is the recommended alter-native. This alternative is capable of fulfilling all of the goals and objectives of the radiation disposal site remediation in a cost-effective manner. This alternative also should be favorably viewed by the community since it best complies with all state standards, criteria, and guidelines and remedial goals. This recommended alternative involves the installation of a vertical subsurface barrier wall (a slurry of bentonite and soil) around the perimeter of the radiation disposal area, and a subsurface grout curtain, at depth, to seal the fractured shale. The existing cap would be extended over the slurry wall, thus eliminating direct contact with the waste materials and preventing surface water from percolating through the waste. The ground water recovery and treatment system would be operated to stop further movement of contaminants past Snyder Road by capturing and treating ground water. The current monitoring program will be revised to monitor both the effectiveness of the source and plume containment measures and the plume south of Snyder Road that is not captured by the ground water recovery system. Thus, Alternative 2 will effectively isolate the source area and prevent further migration of paradioxane in ground water above 50 ppb, thus meeting remedial goals and objectives and complying with regulatory requirements.