Chair
Renie Barger
Vice-Chair
Mike Kemp
Board Members
Charles Allen
Cindy Butterbaugh
Victoria Caldwell
Judy Clayton
Basil Drossos
Nancy Duff
Celeste Emerson
Lesley Garrett
Tom Grassham
Shay Morgan
Bill Murphy
Kevin L. Murphy
Cindy Ragland
Richard Rushing
Ken Wheeler
Patrick White
Carol Young
Jennifer Woodard
DOE DDFO
Buz Smith
DOE Federal Coordinator
Board Liaisons
Brian Begley
Division of Waste
Management
Julie Corkran
Environmental Protection Agency
Mike Hardin Fish and Wildlife Resources
Stephanie Brock Radiation Health Branch
Support Services
EHI Consultants, Inc.
111 Memorial Drive Paducah, KY 42001
Phone 270.554.3004
Fax 270.554.3248
www.pgdpcab.energy.gov
October 20, 2016
Agenda for the October Educational Session
6:00
Call to order, introductions
Presentation
DOE at Paducah
Comments, Questions, Path Forward
Adjourn
PADUCAH GASEOUS DIFFUSION PLANT
CITIZENS ADVISORY BOARD
115 Memorial Drive • Paducah, Kentucky 42001 • (270) 554-3004 • [email protected] • www.pgdpcab.energy.gov
Paducah Gaseous Diffusion Plant Citizens Advisory Board
Educational Session Summary
October 20, 2016
The Citizens Advisory Board (CAB) Educational Session met at the Environmental Information Center (EIC) in
Paducah, Kentucky on Thursday, October 20th at 6:00 p.m.
Board members present: Mike Kemp, Judy Clayton, Ken Wheeler, Bill Murphy, Dick Rushing, Lesley Garrett, Charles
Allen, Celeste Emerson, Patrick White, Tom Grassham, Carol Young, and Renie Barger.
U.S. Department of Energy (DOE) related employees: Jennifer Woodard, Buz Smith, DOE; Eric Roberts, Jim
Ethridge, EHI.
Roberts opened the meeting and introduced the topic for the meeting. He then turned over the meeting to Woodard for a
presentation about the overall history of operations at the Paducah site.
Murphy asked if the KY drivers’ license would still be accepted as identification to enter the plant since it had been
reported that they had not been updated to the newer Real ID version. Woodard indicated that KY had until January
2018 to become compliant with that regulation, but after that date it would be an issue to use the KY license for entry if
they had not been updated. Grassham asked if there was any other form of identification that would allow access.
Woodard said that a U.S. Passport would be acceptable.
Murphy asked if there were plans to combine the DUF6 Conversion plant contract with the Deactivation/Remediation
contract. Woodard indicated that they were two different missions and would not be combined.
Murphy asked if there had been any recent studies performed to check the relationship between reported cases of cancer
in the plant neighbors that might be attributed to their proximity to the plant property. Smith said that the University of
Kentucky did a study a few years back and that he would send a link to that study out to everyone. Roberts said that he
thought the results of the study was on the CAB web site.
Murphy asked if any Superfund money had ever been used at the plant site. Woodard indicated that there had not, and
that those funds were for private industry. Murphy then asked if adding EPA to the oversight agencies for the plant was
all the Superfund designation for the site did. Woodard said that for the most part, yes it did.
Murphy asked if the equipment that was seen on a recent tour of the C-400 building would be considered legacy waste.
Woodard said that what he saw in the C-400 building were DOE Material Storage Areas (DMSA). She added that waste
is defined as something that is no longer of use or has value, you have to declare the material as waste. She said that some
things that are stored at the site are spare parts that might be needed at a later time.
Kemp asked what drove planning for the site work to levels above what is usually funded. Woodard said that DOE has
to build budget schedules to go along with regulatory end dates that are agreed on among the parties.
Murphy asked if the tails from production were the responsibility of the United States Enrichment Corporation (USEC).
Woodard said that the tails were DOE’s responsibility and that USEC was responsible for removing the product when the
plant shut down.
White asked with the new Remediation contract if the new contractor would just take over with existing employees or is
there would be layoffs. Woodard said that DOE would not know how the new contractor would handle their
- 2 -
employment until the contract was actually awarded. White continued by asking if as the new contractor finished projects
they might lay employees off. Woodard said that DOE’s contractors were good in the respect that if they have a short
term job to perform they would hire a subcontractor to come in, do the work and then leave. She said that that was not
considered layoffs.
Roberts asked if a sizeable piece of the site’s hotel costs (base requirements) would supply employees to maintain the
site. Woodard indicated that it would. Roberts also commented that all of DOE’s remediation projects kept running
while USEC turned the plant back over to DOE.
Roberts adjourned the meeting at 7:30 pm.
www.energy.gov/EM 1
Paducah Gaseous Diffusion Plant Program History
Jennifer Woodard, Paducah Site LeadDOE Portsmouth/Paducah Project Office
October 20, 2016
www.energy.gov/EM 2
Paducah Gaseous Diffusion Plant
• In October 1950, the United States Atomic Energy Commission chose Paducah, Kentucky as the site for the second of three planned uranium enrichment plants in the United States.
• The other two enrichment plants were located near Portsmouth, Ohio and Oak Ridge, Tennessee.
Portsmouth, OH
Oak Ridge, TN
Paducah, KY
www.energy.gov/EM 3
• The Paducah Gaseous Diffusion Plant (PGDP) was first used to enrich uranium for military reactors and the nation’s nuclear weapons program.
• In the 1960’s the PGDP was used to supply enriched uranium for commercial power plants.
• In 1988 offsite contamination, from plant operations was discovered.
• In 2013, uranium enrichment operations ceased.
PGDP Plant Operations
www.energy.gov/EM 4
Site Description
• The plant is located on a 3,556-acre DOE site
• Approximately 750 acres are within the fenced security area.
• The remaining acres are licensed to the Commonwealth of Kentucky as part of the West Kentucky Wildlife Management Area for recreational activities and conservation
DOE property licensed to KDWFR
DOE owned industrial area
WKWMA owned by KDWFR
Rural residential/agriculture
TVA boundary
www.energy.gov/EM 5
An Integrated Facility
Facilities Owned by or Leased to USEC
Facilities Retained by DOE or Formerly Leased to USEC
Common Areas Leased to USEC
DOE Reservation Boundary Area and West KY Wildlife Management Area
www.energy.gov/EM 6
An Integrated Facility
Deactivation Facilities
Infrastructure Facilities
DUF6 Facilities
Demolished, Slab or Gravel Only
DOE Boundary
www.energy.gov/EM 7
PGDP Site Operations
• DOE (or it’s predecessors) ran uranium enrichment operations until 1991
• In 1993, the United States Enrichment Corporation (USEC) was privatized to operate uranium enrichment.
• DOE continued to manage environmental legacy from 40 years of operations
www.energy.gov/EM 8
DOE Environmental Management
• DOE Environmental Management was created in 1989
• Paducah and Portsmouth were managed from Oak Ridge Operations Office until 2003
• Portsmouth Paducah Project Office created in 2003 to specifically address cleanup at the two sites
• PPPO Paducah site office manages day to day environmental cleanup operations
www.energy.gov/EM 9
Points to Remember
1.Uranium Enrichment operations spanned 60 years.
2. Site functions similar to small city.
3. Off-site contamination discovered in 1988.
4. DOE Environmental Management (EM) formed in 1989.
5. DOE EM Paducah site office runs day to day cleanup operations.
6. DOE forms the United States Enrichment Corporation to privatize uranium enrichment operations.
www.energy.gov/EM 10
1989 - 1991 Site Investigations
• In 1988 off-site contamination was discovered in residential wells adjacent to the plant.
• DOE entered into an Administrative Order by Consent agreement with EPA to:
• Investigate and address the nature and extent of the PGDP-related contamination and
• Assess its impacts on human health and the environment.
• Phase I CERCLA site investigation began in 1989 to determine nature and extent of off-site contamination.
• Phase II CERCLA site investigation began in 1992 for on-site source areas.
www.energy.gov/EM 11
DOE Paducah Overview
Off-site TCE plumes
• Residential wells contaminated
Legacy waste
• Mixed
• TSCA
• Low-Level
• TRU waste
Burial grounds
• Some contain radioactive, pyrophoric and
RCRA waste
Tc-99 plume
• Radionuclide releases have
migrated off-site, but not above
MCLs
Major TCE source
• DNAPL present; >500,000 ppb
of TCE in groundwater
• Primary source of off-site
contamination
Inactive facilities
• Contaminated
facilities; no reuse
TCE seeps
• Upspringing in Little Bayou
Creek
Contaminated soils
• e.g., PCB and uranium
Depleted uranium
• More than 39,000 cylinders
www.energy.gov/EM 12
CERCLA and the NPL
EPA listed the PGDP as a Superfund site on the National Priorities List (NPL) in 1994
• The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, was enacted by Congress on December 11, 1980.
• The National Priorities List (NPL) is the list of hazardous waste sites in the United States eligible for long-term remedial action (cleanup).
• Environmental Protection Agency (EPA) regulations outline a formal process for assessing hazardous waste sites and placing them on the NPL.
www.energy.gov/EM 13
Regulatory Structure
• Cleanup decisions, in accordance with CERCLA, is accomplished through a tri-party agreement between DOE, the Commonwealth of Kentucky, and the US EPA.
• 1988 Federal Facility Agreement (FFA) serves as the Primary Regulatory Driver:
Coordinates and Integrates Cleanup Requirements of RCRA & CERCLA
Establishes Enforceable Milestones
Regulator review/approval
Site Management Plan (SMP)
• SMP updated annually and serves as the primary cleanup strategy for implementing the FFA.
www.energy.gov/EM 14
Pre-Shutdown (“2019”) Scope
Environmental Remediation Projects Material Disposition Projects
OU
Lev
elP
roje
ct L
eve
l
C-400 TCESource
Removal
SouthwestPlume
Sources
Dissolved-Phase
Plumes
GroundwaterOU
Scrap MetalRemoval
Surface Water
Remedial
Surface WaterOU
InactiveFacilities
C-410 Bldg.
D&DOU
Soils Removal
Soils Remedial
SoilsOU
Burial Grounds
OU
BGOURemedial
LegacyWaste
NewlyGenerated
Waste
Waste Disposition
East End Smelter
Inactive Soils
Facilities
SWMU 4
SWMUs5 & 6
Surface Water
Removal
C-340 Bldg.
Pre-Shutdown ScopeNOTE: Each environmental project is expected to have a corresponding CERCLA decision document (i.e., ROD, AM)
SWMUs2, 3, 7, & 30
Pump and Treat
www.energy.gov/EM 15
Additional Scope
• DOE Material Storage Areas Returned from USEC Inside and outside areas About 1/4 returned to USEC, common use
• Soil and Rubble Piles 150 soil piles and rubble areas in various location
• Additional Inactive Facilities
• Waste Disposal Options Implementation of the CERCLA Decision
• Design, Construct and Operate Depleted Uranium Hexafluoride (DUF6) plant
www.energy.gov/EM 16
Pre-Shutdown (“2019”) Scope
Environmental Remediation Projects Material Disposition Projects
OU
Lev
el
Pro
ject
Lev
el
C-400 TCESource
Removal
SouthwestPlume
Sources
Dissolved-Phase
Plumes
GroundwaterOU
Scrap MetalRemoval
Surface Water
Remedial
Surface WaterOU
InactiveFacilities
C-410 Bldg.
D&DOU
Soils Removal
Soils Remedial
SoilsOU
Burial Grounds
OU
BGOURemedial
C Priority
B Priority
A Priority
DMSAs
LegacyWaste
NewlyGenerated
Waste
Waste DispositionDUF6
Construction of Plant
East End Smelter
Operation of Plant
(25+) YearsInactive Soils
Facilities
SWMU 4
SWMUs5 & 6
WasteDisposal Options
Surface Water
Removal
C-340 Bldg.
Startup and Testing
of DUF6 Plant
Pre-Shutdown ScopeNOTE: Each environmental project is expected to have a corresponding CERCLA decision document (i.e., ROD, AM)
SWMUs2, 3, 7, & 30 = Completed since 2007
= Does not have ROD/AM
Pump and Treat
www.energy.gov/EM 19
Points To Remember
1. Investigations identified nature and extent of on/off-site contamination.
2. Paducah designated as a Superfund site and placed on the National Priorities List in 1994.
3. Tri-party (DOE, KDEP, and EPA) agreement (FFA) established to guide CERCLA cleanup process.
4. 2019 Scope organized into logical and manageable projects, annually updated in the Site Management Plan, based on anticipated funding.
5. Additional scope incorporated.
6. Updated timeline reflects changes and is based on anticipated funding.
7. Flat-Lined Funding directive creates significant impacts to enforceable milestones and moves project completion out.
www.energy.gov/EM 20
Plant Shutdown and Transition
In June 2013, USEC ceased uranium enrichment operations. On August 1, 2013 USEC formally notified DOE that they were returning the facilities back to DOE, triggering the following:
• De-leasing Activities
Administrative and technical lease requirements to return the facilities back to DOE.
• Transfer from NRC to DOE control
The management and operation of the PDGP facilities by USEC was under NRC authority.
When USEC leaves and returns the facilities to DOE the operations will change and all authority and responsibility will be DOE’s.
• Deactivation Request For Proposal
DOE development and release of bridge contractor to manage returned facilities and re-align scope.
www.energy.gov/EM 21
De-leasing Process
De-lease Process with USEC and DOE/ORO/PPPO
• USEC Issues 2 Year Notice
• USEC Issues Transition Plan
• DOE and USEC Negotiate a Framework Agreement
• DOE Evaluates USEC’s Deposit Removal Approach
• DOE Evaluates and Monitors USEC’s Facility and System Turn-over Condition and Configuration
• Negotiating Power Agreements
• DOE and USEC Conduct Lease Compliance Walkdowns
www.energy.gov/EM 22
Nuclear Regulatory Commission to DOE
• The Nuclear Regulatory Commission is the primary regulatory oversight for nuclear operations in the United States.
• DOE is a self-regulating federal agency.
• USEC, as a private entity, had an NRC license to operate nuclear operations. The following items were required to transfer from NRC to DOE: Preparing Safety Basis Documents
Preparing Safety Management Programs
Developing Security Optimization Strategies
Transferring Regulatory Permits
Walking Down Facilities
Planning Security Changes,
www.energy.gov/EM 23
Procurement Activities
Procurement activity for a deactivation contractor award
• Scope of Work development • RFP release – 18 – 24 month award• Use existing Headquarters contracting vehicle to expedite award
Modify existing contract services to maintain accelerated turnover, hire displaced USEC workers and integrate with new contractor
• LATA Kentucky• 16 tasks to support rapid turnover success by deactivation contractor• Hold-up removal system design, procure, and fabricate• Heating system design, procure, and install• Regulatory permitting
• Pro2Serve• Documented safety analysis development• Significant document development and support• Walk-down completion and lease compliance assessment
• Swift and Staley• IT system upgrades and deployment• Records management upgrade and transfer
www.energy.gov/EM 24
Paducah Plant Turnover
• Deactivation bridge contract awarded to Fluor Federal Services in July, 2014 with a 90-day transition period.
• Bridge contract will integrate existing cleanup scope with plant facilities (D&D) and create a high-level strategic plan to move forward.
• Facilities transferred from USEC to DOE October 21, 2014.
• Fluor Federal Services began performing contract scope (fieldwork) on October 21, 2014.
www.energy.gov/EM
24
www.energy.gov/EM 25
Bridge Contract timeline
July 2014
PERIOD 1Task Order
Implementation Period
PERIOD 2De-Lease Planning &
Transfer Period
NTPTransfer of
GDPEnd of Current
Remediation ContractEnd of Task Order
July 2017October 2014 July 2015
PERIOD 4
Post-GDP Shutdown Environmental Remediation Services Period
PERIOD 3
Facility Deactivation & Infrastructure Optimization Period
Futu
re D
&D
www.energy.gov/EM 26
Facility Stabilization
• Preparation and/or removal of nuclear materials and contaminants from facilities.
• Stabilization activities are performed during early stages of facility deactivation.
Facility Deactivation
• Removal of radioactive and hazardous materials
• Shut down facility systems
• De-energize equipment in preparation for long-term maintenance and cleanup
Infrastructure Optimization
• Scale down and optimization of utilities including water, sewage treatment, and steam to meet the needs of the project
26
Paducah Deactivation Project
www.energy.gov/EM 27
Environmental Remediation • Complete Southwest Plume Deep
Soil Mixing.
• Complete D&D of C-410
Waste Management • Continue to remove hazardous
and radiological waste from the site including deposit removal waste, laboratory waste, and waste generated by deactivation, environmental remediation, and limited D&D.
Environmental Monitoring • Maintain environmental permit
compliance for all off-site discharge including air, soil and water compliance requirements.
Environmental Remediation Project
27
www.energy.gov/EM 28
Scope Integration and Life Cycle Planning
28
Burial grounds• 10 burial grounds, ~100
acres• Some contain radioactive,
pyrophoric and RCRA waste
Major TCE source• Primary source of off-site
contamination• Heavy concentrations
present; >500,000 ppb of TCE in groundwater
Depleted uranium• About 53,300 cylinders
Long-term facilities removal• >500 structures with a
footprint of nearly 200 acres to be razed
• Underlying soils to be investigated, cleaned up as needed
Surface Water• Remediation of ~6 miles
contaminated creeks, ditches, etc.
Deactivation• Infrastructure
optimization, e.g., switchyard consolidation
• Facility modifications incl. repairs for ~3mil. s.f. of roofs
• Deactivation activities incl. oils and refrigerant removal from process buildings
• Uranium deposit removal from process buildings
Tc-99 plume• Radionuclide releases have
migrated off-site, but not above Drinking Water Standards.
Contaminated soils• PCBs and uranium• 66 areas totaling ~ 115
acres
Inactive facilities• Demolished 32 buildings
prior to transition. 12 additional facilities to be completed in 2016.
www.energy.gov/EM 29
Scope Re-alignment
• Proposed Change:
Perform the investigation under the C-400 Building slab instead of treating the southeast corner of C-400
Place OSWDF on hold for 10 years
Delay the burial grounds actions until after the OSWDF is constructed
• Continue Deactivation Activities
www.energy.gov/EM 30
Points To Remember
1. USEC shuts down plant operations in June 2013.
2. DOE mobilizes efforts to de-lease facilities, transfer NRC license to DOE authority and procure deactivation (bridge) contractor.
3. DOE (LATA) continues to perform environmental remediation activities.
4. Plant officially turned over to DOE on October 21, 2014.
5. DOE (Fluor) begins facility stabilization, facility modification, and optimization activities (deactivation).
6. In July 2015, all work is integrated into one contract. Life-cycle planning begins to develop high level strategy for site cleanup.
7. A proposed scope re-alignment submitted to regulators.
www.energy.gov/EM 32
DOE uses a combination of factors to prioritize work being implemented under the EM program at PGDP:
• Regulatory expectations
• Risk-based decision making
• Compliance with other programs
• Technical considerations associated with GDP facilities
• "Mortgage"/landlord cost reduction
• Demonstrated progress toward completing the EM mission
• Future use initiatives