RCRA Summary Document for the David Witherspoon 1630 Site, Knoxville, Tennessee

Abstract

The 48-acre David Witherspoon, Inc. (DWI) 1630 Site operated as an unregulated industrial landfill and scrap yard. The Tennessee Division of Superfund (TDSF) closed the landfill in 1974. During the period of operation, the site received solid and liquid wastes from salvage and industrial operations. The site consists of five separate tracts of land including a small portion located across the Norfolk Southern Railroad track. The landfill occupies approximately 5 acres of the site, and roughly 20 acres of the 48 acres contains surface and buried debris associated with the DWI dismantling business operation. Beginning in 1968, the state of Tennessee licensed DWI to receive scrap metal at the DWI 1630 Site, contaminated with natural uranium and enriched uranium (235U) not exceeding 0.1 percent by weight (TDSF 1990). The U.S. Department of Energy (DOE) has agreed to undertake remedial actions at the DWI 1630 Site as specified under a Consent Order with the Tennessee Department of Environment and Conservation (TDEC) (Consent Order No. 90-3443, April 4, 1991), and as further delineated by a Memorandum of Understanding (MOU) between DOE and the State of Tennessee (MOU Regarding Implementation of Consent Orders, October 6, 1994). The soil and debris removal at the DWI 1630 Site is being performed by Bechtel Jacobs Company LLC (BJC) on behalf of the DOE. Remediation consists of removing contaminated soil and debris from the DWI 1630 site except for the landfill area and repairing the landfill cap. The DWI 1630 remediation waste that is being disposed at the Environmental Management Waste Management Facility (EMWMF) as defined as waste lot (WL) 146.1 and consists primarily of soils and soil like material, incidental debris and secondary waste generated from the excavation of debris and soil from the DWI 1630 site. The WL 146.1 includes soil, soil like material (e.g., shredded or chipped vegetation, ash), discrete debris items (e.g., equipment, drums, large scrap metal, cylinders, and cable) and populations of debris type items (e.g., piles of bricks, small scrap metal, roofing material, scaffolding, and shelving) that are located throughout the DWI 1630 site. The project also generates an additional small volume of secondary waste [e.g., personal protective equipment (PPE), and miscellaneous construction waste] that is bagged and included in bulk soil shipments to the EMWMF. The Waste Acceptance Criteria (WAC) for the EMWMF does not allow for material that does not meet the Resource Conservation and Recovery Act (RCRA) Land Disposal Restrictions (LDRs). The waste being excavated in certain areas of the DWI 1630 site contained soil that did not meet RCRA LDR criteria; therefore this waste had to be segregated for treatment or alternate disposal offsite. This document identifies the approach taken by the DWI 1630 project to further characterize the areas identified during the Phase II Remedial Investigation (RI) as potentially containing RCRA-characteristic waste. This document also describes the methodology used to determine excavation limits for areas determined to be RCRA waste, post excavation sampling, and the treatment and disposal of this material.