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Agenda for the October Educational · PDF fileWoodard said that what he saw in the C-400...

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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 [email protected] October 20, 2016 Agenda for the October Educational Session 6:00 Call to order, introductions Presentation DOE at Paducah Comments, Questions, Path Forward Adjourn
Transcript

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

[email protected]

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 17

Updated Pre-shutdown Scope Timeline

www.energy.gov/EM 18

Impact of Flat Lined Funding Directive

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 31

BACKUP

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


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