Notification of Concurrence - K-25/K-27 D&D Project, ETTP - Change Number of EMWMF Waste Lots in the Waste Handling Plan for Demolition of the K-25 and K-27 Building Structures and Remaining Components Located at the ETTP, Oak Ridge, TN From Two to Three

Abstract

Section 5.1 of the approved Waste Handling Plan for Demolition ofthe K-25 and K-2 7 Building Structures and Remaining Components Located at the East Tennessee Technology Park, Oak Ridge, Tennessee (WHP) includes two Environmental Management Waste Management (EMWMF) waste lots: (1) Asbestos-contaminated roofing/transite; and (2) Construction debris, such as nonasbestos roofing, structural steel/miscellaneous metal/equipment, nonradiological piping, wood, and miscellaneous small quantities of concrete. This concurrence form adds an additional EMWMF waste lot 6.47 for lavatory sink drains. Based on an analysis of the building structure characterization data, the only individual building structure with either an analytic carcinogenic or Hazard Index (HI) sum-of-fractions (SOF) greater than 1 is the lavatory sink drains (Table 1). The HI SOF for the lavatory sink drains is 1.34 (Table 2). When all media are combined with the material of construction calculations, the HI SOF is 1.22 (Table 3). However, when the lavatory sink drains are segregated from all other media, the HI SOF is only 0.256, which is well below the EMWMF waste acceptance criteria SOF limit of 1 (Table 4). Given the large volume (124, 625 cubic yards) of other building structure media with a small HI SOF of 0.256 and the small volume (one cubic yard) of lavatory sink drains with a large HI SOF of 1.34, a separate waste lot for lavatory sink drains is recommended. Lead is the primary contributor to the large HI SOF in the lavatory sink drains. Lead in the lavatory sink drains was shown using the Wilcoxon rank-sum test statistically to have higher concentrations than all other building structure media combined. Other analytes having statistically different median concentrations in the lavatory sink drains compared to all other media are antimony, arsenic, boron, cadmium, selenium, solver, vanadium, zinc, mercury, strontium, and Uranium-233/234 (Table 5). A separate waste lot for the lavatory sink drains minimizes the volume weighted sum-of fractions since a much smaller volume of waste will have the higher HI SOF of 1.34, while a much larger volume of waste will have a small HI SOF of 0.256.