Text

DOE Input to NRC Annual Rept to Congress Re Status of Environ,Safety & Health Conditions at Paducah & Portsmouth Gaseous Diffusion Plants for FY98
	ML20199E355
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date:	10/31/1998
From:	; ENERGY, DEPT. OF
To:	;
Shared Package
ML20199E339	List: ML20199E334; ML20199E355;
References
	DOE-ORO-2074, NUDOCS 9901200392
	Download: ML20199E355 (46)
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DOE /ORO-2074 i DEPARTMENT OF ENERGY INPUT TO THE NUCLEAR REGULATORY COMMISSION'S ANNUAL REPORT TO CONGRESS REGARDING THE STATUS OF ENVIRONMENTAL, SAFETY, AND HEALTH CONDITIONS AT TIIE PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANTS FOR FISCAL YEAR 1998 October 1998 Prepared by Department of Energy Regulatory Oversight Program I l l Prepared for U.S. Department of Energy Oak Ridge Operations Oak Ridge, Tennessee 37830 d
i CONTENTS Acronyms.. ....... v Executive Summary.................. vii 1. Background................ .I 1.1 Regulatory Responsibilities. .1 l.2 Memoranda of Understanding.......... 3 2. DOE Regulatory Oversight Program.. 3 2.1 Inspections. 4 2.2 Operational Readiness Evaluations..... 5 2.3 Safety Evaluation Reports 6 2.4 Safeguards and Security Activities 6 2.5 International Atomic Energy Agency Activities. 7 3. Highly Enriched ' tium Activities... 7 3.1 Highly Enra ed Uranium Refeed and Cylinder-cleaning Program........ 8 3.2 Highly Eri.rit.ed Uranium Suspension and Removal Program .8 3.3 Highly Enriched Uranium Transparency Program. 10 4. Compliance Plan Activities 11 5. Nuclear Safay Upgrades Program................ 12 5.1 Nuclear Safety Upgrades Program Status....... 13 5.2 Nuclear Safety Upgrades Cost Settlement.. 14 6. Lease hiodiGeations...... 15 7. Environment, Safety, and Health Status of Nonleased Areas 15 7.1 Environment, Safety, and Health Status of Nonleased Areas at Paducah. 16 7.1.1 Facilities and Acreage. 16 7.1.2 Depleted Uranium Hexafluoride Management. 17 7.1.3 Environmental Restoration 18 7.1.4 Waste Management. 20 7.1.5 DOE Material Storage Areas.. 23 7.1.6 Update of Safety Analysis Report. 23 7.1.7 Environmental Status..... 23 iii
~. -.. _... -.. - -. -. .-. - ~ I 1 i I ii. I l 7.1.8 Safety and Health Status............... 24 l 7.1,9 Reportable Occurrences......... ...... 25 7.2 Environment, Safety, and Health Status of Nonleased Areas at Portsmouth.. 26 l 7.2.1 Facilities and Acreage................................... ...... 26 j 7.2.2 Depleted Uranium Hexafluoride Management. ..... 26 l l 7.2.3 Environmental Restoration............. 27 7.2.4 Waste Management............... .............. 29 i 7.2.5 DOE Material Storage Areas............... 30 ~ 7.2.6 Update of Safety Analysis Report..... . 30 7.2.7 Environmental Status............................... 30 7.2.8 Safety and Health Status........................... .. 31 l 7.2.9 Reportable Occurrences................................. ...... 31 i 8. Compliance With Applicable Laws............... .......... 32 I ? y A p pe n d i ce s.................................................................. 3 3 A. Summary of DOE Regulatory Oversight Program Inspection Reports....... . A-1 l B. Summary of Reportable Occurrences in Nonleased Areas at the Gaseous Diffusion Plants......................... B-l l
1. Paducah Gaseous Diffusion Plant..
. B-3 i (
2. Portsmouth Gaseous Diffusion Plant..,.....
........... B.............. l t r l I e I l t [ ? l i r r r I f L I Iv I I I t n i l~ I
ACRONYMS ATSDR Agency for Toxic Substances and Disease Registry CAP Corrective Action Plan CAS/ CMS Cleanup Alternatives Study / Corrective Measures Study CAAS Criticality Accident Alarm System CD-ROM compact disc read only electronic file CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code ofFederalRegulations ~ CY calendar year D&D decontamination and decommissioning DMSA DOE Material Storage Area DNAPL dense non-aqueous phase liquid DNFSB Defense Nuclear Facilities Safety Board DOE U.S. Department of Energy DOT U.S. Department of Transportation DUF. depleted uranium hexafluoride EA Environmental Assessment EF Enrichment Facilities EM Environmental Management EPAct Energy Policy Act of 1992 ER environmental restoration ES&H environment, safety, and health ETTP East Tennessee Technology Park FFA Federal Facility Agreement FFCA Federal Facilities Compliance Agreement FLM First Line Manager FY fiscal year 3DP gaseous diffusion plant HASA High Assay Sampling Area HEU highly enriched uranium IAEA International Atomic Energy Agency ISCOR in situ cher tical oxidation and recirculation ISMS Integrateu Safety Management System KPDES Kentucky Pollutant Discharge Elimination System LEU low enriched uranium LWC lost workday case M&O management and operating M&I management and integration MINATOM Russian Federation's Ministry of Atomic Energy MOA Memorandum of Agreement MOU Memorandum of Understanding NCS Nuclear Criticality Safety NCSA Nuclear Criticality Safety Approval NDA nondestructive assay NFS Nuclear Fuel Services,Inc. NOV Notice of Violation v
I l 4 NPDES National Pollutant Discharge Elimination System NPL National Priorities List NRC U.S. Nuclear Regulatory Commission f NSU Nuclear Safety Upgrades NTS Noncompliance Tracking System OCAW Oil, Chemical, and Atomic Workers ORE Operational Readiness Evaluation ORO Oak Ridge Operations OSR Operational Safety Requirement PAAA Price-Anderson Amendments Act PCB polychlorinated biphenyl j PEIS Programmatic Environmental Impact Statement PGDP Paducah Gaseous Diffusion Plant PORTS Portsmouth Gaseous Diffusion Plant PPE personnel protective equipment .. PPO Permanent Presence Office PSS Plant Shift Superintendent l RCRA Resource Conservation and Recovery Act l Ril recordable, illnesses and injuries { RO Regulatory Oversight ROA Regulatory Oversight Agreement ROD Record of Decision SAR Safety Analysis Report SER Safety Evaluation Report SSR Site Safety Representative l .STOP. Safety Team of Paducah i SWMU solid waste management unit TCE trichloroethylene TCLP Toxicity Characteristic Leaching Procedure TSCA Toxic Substances Control Act i TSD treatment, storage, and/or disposal - UF. uranium hexafluoride USEC United States Enrichment Corporation USEPA-U.S. Environmental Protection Agency i USQ Unreviewed Safety Question USQD Unreviewed Safety Question Determination VOC volatile organic compound WAC Waste Acceptance Criteria j WAG Waste Area Group WM waste management i l vi i I
EXECUTIVE
SUMMARY
effective and efficient cooperation in theirjoint oversight of activities conducted at the GDPs. The Energy Policy Act of 1992 (EPAct), This report demonstrates the effectiveness which amended the Atomic Energy Act of 1954, of ES&H protection at the GDPs under DOE required that the Department of Energy (DOE) regulatory oversight. During FY 1998, all transfer certain functions ofits uranium environmental releases and discharges for which enrichment operations at the Paducah and DOE was responsible at both the Paducah Portsmouth Gaseous Diffusion Plants (GDPs) to Gaseous Diffusion Plant (PGDP) and the the United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant (PORTS) (USEC). This transfer occurred on July 1,1993, were within established regulatory limits except with the signing of the Lease Agreement for three minor Kentucky Pollutant Discharge Between the UnitedStates Department of Elimination System (KPDES) permit Energy and the UnitedStates Enrichment exceedances at PGDP. There were no Corporation. In addition, the EPAct aise environmental impacts from these minor required that regulatory oversight responsibility exceedances. for the leased portions of the GDPs be transferred from DOE to the Nuclear Regulatory In FY 1998, the DOE Environmental Commission (NRC). This transfer occurred on Restoration (ER) and Waste Management (WM) March 3,1997. Programs at PGDP and PORTS met all regulatory deadlines. In July, the Ohio EPA To ensure that Congress is informed of the issued a Notice of Violation (NOV) relating to a status of the environmental, safety, and health 90-day hazardous waste accumulation area. The (ES&li) conditions at the GDPs, Section 1701 NOV was later abated. Both PGDP and PORTS of the EPAct requires that "[t]he Nuclear continued to make significant progress in ER Regulatory Commission, in consultation with and WM activities. For example, during the Department [of Energy] and the FY 1998, PGDP completed or continued Environmental Protection Agency, shall report remedial actions for Waste Area Groups at least annually to the Congress on the status of (WAGS) I and 7, which include the C-746-K health, safety, and environmental conditions at inactive sanitary landfill and other areas; treated the gaseous diffusion uranium enrichment more than 198 million gallons of contaminated facilities of the Department [of Energy]." This grour.dwater; and treated, shipped, or disposed report consolidates and presents the information of more than 6,600 tons of waste. During the that DOE is obligated to provide to the NRC to same time, PORTS implemented three pilot meet this statutory requirement for fiscal year projects to evaluate difTerent treatment (FY) 1998. technologies; completed a collection trench; capped two landfills; and treated, recycled, or in particular, the report provides disposed of more than 2,000 tons of waste and information about the status of ES&H wastewater. conditions for those portions of the gaseous diffusion uranium enrichment facilities for Conditions in the nonleased portions of the which DOE retained oversight responsibility GDPs reflect the effectiveness of DOE safety during FY 1998. This report also ad&csses the and health programs. For example, in calendar activities of the highly enriched uranium (HEU) year (CY) 1997, radiation exposures for both refeed, suspension and removal, and PGDP and PORTS personnel under DOE transparency programs conducted by DOE and radiation protection programs averaged describes the Memorandum of Understanding 5.6 mrem and 1.65 mrem per person per year. (MOU) employed by DOE and NRC to ensure respectively. These averages should be vii I
contrasted to average annual background at PGDP and PORTS. Also, DOE continued the radiation exposure levels per person of 30 mrem disposition of HEU by removal of stored HEU from cosmic radiation,30 mrem from terrestrial materials at PORTS. The removal of these sources,40 mrem from food, and 200 mrem materials will significantly reduce ES&H risks from naturally occurring radon sources. During and safeguards and security operating costs at FY 1998, DOE and its contractors had no Lost PORTS. Work Day Cases (LWCs), one Lost Work Day Restricted Case, and two recordable injuries and in addition to demonstrating the adequacy illnesses (RIls) at PGDP ano seven Riis, of DOE's oversight of the nonleased areas at including five LWCs, at PORTS. PGDP and PORTS, this report demonstrates that DOE exercised effective regulatory oversight During this period,20 incidents at PGDP over the leased, but not certified, areas of and 19 incidents at PORTS associated with PORTS for which it also retains oversight l activities in nonleased areas were classified as responsibility. During FY 1998, DOE reportable occurrences by DOE, PGDP reported conducted more than 100 inspections of HEU-that a few of their occurrences were Price-related activities in these areas. As a result of Anderson Amendments Act noncompliances. these inspections, DOE issued three NOVs in l While the adverse effects of the rcportable response to USEC violations of DOE occurrences on ES&H were insignificant, requirements contained in the Regulatory j important lessons learned were derived and Oversight Agreement (ROA). I applied at the GDPs and distributed throughout the DOE complex. Finally, this report presents the determination that in those instances where During FY 1998, the DOE Enrichment regulatory violations occurred, actions were Facilities (EF) Program continued initiatives to taken to notify appropriate authorities, identify enhance ES&H protection related to the storage the cause of the violation, and institute of cylinders containing depleted uranium corrective measures. Such responsiveness hexafluoride (DUF.) at.both GDPs and to the enabled DOE to maintain adequate and effective disposition of HEU at PORTS. For example, ES&H protection in both the nonleased and DOE is completing a Programmatic leased, but not certified, areas at the GDPs for Environmental Impact Statement (PEIS) to which it retained regulatory oversight determine the recommended alternative for responsibility during FY 1998. dispositioning the inventory of DUF in storage O viii
1. BACKGROUND the United States' interest in USEC. On July 28,1998, USEC became a private The Energy Policy Act of 1992 (EPAct),
corporation, USEC inc., through an initial which was signed into law on October 24,1992, public offering. amended the Atomic Energy Act of 1954 to require that the U.S. Department of Energy The EPAct assigns responsibility to DOE (DOE) transfer certain functions associated with for the payment of any costs of decontamination its uranium enrichment operations' to the United and decommissioning (D&D), response actions, States Enrichment Corporation (USEC), a or corrective actions at the GDPs related to government corporation created pursuant to the preexisting conditions (i.e., conditions existing EPAct. In furtherance of this mandate, DOE before the lease of the GDPs to USEC). With leased certain portions of the gaseous diffusion this assignment, DOE retains responsibility for plants (GDPs) located in Paducah, Kentucky, environmental restoration and legacy waste and Piketon, Ohio, to USEC on July 1,1993. In management at the GDP sites and for the the Lease Agreement Between the UnitedStates operation of facilities used for the storage of Department ofEnergy and the UnitedStates DOE-owned source and special nuclear material Enrichment Corporation (hereinafter referred to such as the cylinder storage yards for depleted as the Lease), dated July 1,1993, and in other uranium hexaGuoride (DUF.) generated before subsequent agreements, DOE and USEC July 1,1993.3 established the roles and responsibilities for each organization at both GDPs. The EPAct also required that regulatory oversight authority over the leased portions of To promote the privatization of DOE's the GDPs be transferred from DOE to the U.S. uranium enrichment operations, the EPAct also Nuclear Regulatory Commission (NRC). This required that within 2 years after the transition transfer occurred on March 3,1997. However, date of July 1,1993, USEC prepare a plan for DOE retains possession of and regulatory transferring ownership of USEC to private responsibility for all highly enriched uranium investors. Pursuant to this requirement, USEC (HEU). submitted a plan entitled Planfor the Privati:ation of the United States Enrichment Corporation to the President and Congress in 1.1 REGULATORY RESPONSIBILITIES June 1995. On April 26,1996, the USEC Privatization Act was enacted.2 This act The EPAct assigns safety and safeguards directed the USEC Board of Directors to and security regulatory responsibility at the establish a for-profit private corporation to USEC-operated GDPs to NRC. In furtherance receive the assets and obligations of USEC, to of this assignment,the EPAct required that continue the operations of the government within 2 years of the date ofits enactment, NRC corporation, and to secure the maximum establish by regulation both (1) safety and proceeds to the United States from the sale of ' Ibid. With the signing of the USEC Privatization Act. the liability of the United States and the Secretary of 'The original purpose of the uranium enrichment Energy was modified. The United States assumed operations was to supply enriched uranium to the U.S. responsibility for liabilities arising out of the operation of nuclear weapons programs. Today, the urciium USEC until the date of privatization (unless otherwise enrichment operations produce enriched uranium primarily provided in a Memorandum of Agreement). The disposal for commercial customers to operate nuclear power plants. of depleted uranium generated by USEC between July 1. 1993, and the date of privatization is the responsibility of 242 U.S.C. # 2297(h). the Secretary of Energy. 1
l l l I l safeguards and security standards for the GDPs standards. Provisions also are included for and (2) a cenification process to ensure that enforcement actions-including civil penalties USEC complies with these standards. This and curtailment or shutdown of operations-in certification process is in lieu of any response to violations. Because the ROA l requirement for a license. Thus, the EPAct requirements were deemed adequate for made NRC regulation of the GDPs conditional continued safe and secure operation cif the on the issuance of new regulations, which were GDPs, DOE exempted USEC and the leased promulgated in September 1994. However, the portions of the GDPs from the regulations that EPAct required DOE to lease the GDPs to DOE promulgated to implement the Prlce-USEC on July 1,1993, more than a year before Anderson Amendments Act (PAAA). l the deadline for establishing safety and safeguards and security regulations. This The EPAct also made provision for the schedule created an interim period between the possibility that USEC might not initially be able lease of the GDPs to USEC and assumption of to comply with the safety and safeguards and regulatory oversight by the NRC on March 3, security standards established by NRC. To 1997. During this period, there was a need for address this contingency, the EPAct permitted continued regulatory oversight of safety and NRC to approve continued USEC operation of safeguards and security at the GDPs until NRC the GDPs if NRC approved DOE-prepared assumed regulatory oversight responsibility. plans' for bringing the GDPs into compliance Consequently, DOE developed a Regulatory with any unsatisfied provisions of the NRC Oversight Agreement (ROA) that became the regulations. On November 26,1996, NRC basis for DOE oversight of safety and certified USEC's operation of the GDPs to be in safeguards and security for the leased areas of compliance with 10 CFR 76, with the exception the GDPs during this period. of the noncompliances identified in the NRC-approved Compliance Plans. The ROA consists of those performance-based standards extracted from the DOE Orders Following a transition period, NRC began that are related to nuclear safety and safeguards regulation of most USEC operations in the i and security. These standards are considered leased areas at the GDPs on March 3,1997. essential for continued safe and secure operation DOE retains responsibility for the of the GDPs. The ROA is included as a part of environmental, safety and health (ES&H) the Lease (Exhibit D to the Lease), and its protection, and safeguards and security for the standards are commensurate with the standards portions of the Paducah Gaseous Diffusion that were promulgated by NRC in Title 10 of Plant (PGDP) and PORTS that are not leased to Code offederalRegulations (CFR), Part 76 USEC and for those portions of PORTS that are (10 CFR 76)," Certification of Gaseous leased to USEC that contain HEU material. Diffusion Plants." Originally used to regulate Thus, at PGDP, regulatory oversight the USEC-leased portions of the GDPs during responsibility is divided into two programs: the interim period, the ROA continues to be (1) NRC oversight for leased areas and (2) DOE used by DOE to regulate HEU refeed activities oversight for nonleased areas. At PORTS, at the Portsmouth Gaseous Diffusion Plant regulatory oversight responsibility is divided (PORTS)in Piketon, Ohio. The ROA also contains provisions for DOE appraisals and I inspections of the leased facilities, for issuance 'The DOE-prepared plans entitled Planfor Achieving af Notices of Violation (NOVs) in response to compliance with NRC Regulations at the Paducah failures to meet ROA standards, and for USEC Gaseous Plant and Planfor Achieving Compliance wah self-assessments of compliance with ROA i# ###"'"""""' ' "' "'"""'^ O"""# /lant, are commonly referred to as Compliance Plans. l 2
into three programs based on the location and interim period, defines the responsibilities of type of activity being performed. These consist DOE and NRC regarding continuing of(l) NRC oversight ofleased areas, (2) DOE cooperation at the GDPs after NRC assumption oversight ofleased areas involving HEU, and of regulatory oversight responsibility for USEC (3) DOE oversight of nonleased areas. DOE activities. The MOU also clarifies the regulates nonleased areas under DOE orders and framework for coordination regarding issues applicable PAAA regulations. DOE regulates that may involve DOE and NRC areas of HEU material activities that occur in leased responsibility. According to this MOU, DOE areas (i.e., in Buildings X-326 and X-705 at not only remains responsible for regulatory PORTS) under the ROA. It will continue to oversight of the PORTS HEU refeed activities regulate these activities under the ROA until that take place in leased space (Buildings X-326 (1) all the HEU material has been downblended and X-705) but also will continue to review and, (diluted) into low enriched uranium (LEU) in where appropriate, approve USEC-proposed the PORTS LEU cascade,(2) HEU refeed modifications to the PGDP and PORTS activities are completed, (3) all cylinders that Compliance Plans before their submittal to contain HEU material are cleaned or shipped NRC. In addition to the recognition of these off-site, and (4) the associated areas are continuing DOE responsibilities, DOE and.NRC transitioned to NRC regulation. At the same (1) agreed to exchange information and ' time, NRC regulates USEC operations in the technical support, (2) defined responsibilities leased areas according to 10 CFR 76, other for emergency response, (3) described the applicable NRC regulations, the USEC manner in which inues iderttified during an certification applications, and the certificates of inspection by either agency would be referred to compliance issued to USEC by NRC. Currently, the other, and (4) defined responsibilities for the areas regulated by NRC at the GDPs coordination of activities. The security roles comprise a much larger portion of the operations and responsibilities of DOE and NRC after than those regulated by DOE. NRC assumption of regulatory oversight responsibility for USEC activities are defined in the Agreement Defining Security I.2 MEMORANDA OF UNDERSTANDENG Responsibilities at Ihe Paducah and Portsmouth Gaseous Diffusion Plants Between the In October 1997, DOE and NRC signed a Department ofEnergy 's Office ofSafeguards Memorandum of Understanding (MOU) entitled and Security and the Nuclear Regulatory Memorandum of Understanding Between the Commission, which DOE and NRC established Department ofEnergy andthe Nuclear in March l995. . Regulatory Commission - Cooperation Regarding the Gaseous Diffusion Plants.' This MOU, which replaces a previous MOU for the
2. DOE REGULATORY OVERSIGHT PROGRAM Although NRC assumed regulatory oversight responsibility for the majority of the
'ne MOU states that "[t]he Regulatory Oversight ea e areas o% Ws on Mard 3. N, Agreement (ROA), Exhibit D to the Lease Agreement DOE retains nuclear safety and safeguards and Between DOE and USEC, sets forth the requirements and security oversight authority under the ROA for a safety basis for the operation of DOE activities in the limited immber of operations in the leased, but leased areas of the GDPs. The activities govemed by the not certified, areas at PORTS that involve HEU ROA consist ofilEU Refeed activity in Buildings X-326 and X 705 at the Portsmouth Gaseous Diffusion Plant." 3
material.' These operations involve 2.1 INSPECTIONS dispositioning excess lieu through downblending into the gaseous diffusion process DOE conducts routine, special, and (lieu refeed) in Building X-326 and cleaning functional area inspections in the leased, but not the lieu cylinders following refeed in certified, facilities at PORTS. In accordance segregated areas of Building X-705. The leased, with the ROA, DOE may issue NOVs and but not certified, portions of PORTS that remain impose civil penalties if these inspections under DOE regulatory oversight are scheduled identify ROA violations. The amount of a civil to be transitioned to NRC regulation by penalty is based on the severity of the violation. January 31,1999, or when USEC certifes that The DOE RO Manager assigns one of three the total quantity of special nuclear material severity levels to the violations. Severity (other than inaccessible residual holdup) within Level I violations are violations that all leased areas is within the possession limits in significantly increase the hazard to plant the NRC certificate of compliance for USEC workers or the risk of off-site co. sequences and operations at PORTS. are the most serious violations. Severity Level 11 violations are violations tf.at moderately The DOE Oak Ridge Operations (ORO) increase the hazard to plar.t workers or the risk Regulatory Oversight (RO) Manager manages of off-site consequences and are serious or the DOE RO Program for the leased, but not recurring violations. Severity Level Ill certified, portions of PORTS that contain lieu violations are significant violations that do not material. The RO Manager schedules and indicate any overall degradation in nuclear coordinates all DOE RO Program activities, safety or safeguards and security programs. including inspections and enforcement actions. The RO Manager is also authorized to modify During FY 1998, DOE conducted more than the ROA whenever he/she determines that such 100 inspections of activities in the leased, but changes are required either to protect public not certified, facilities at PORTS. The majority health and safety or to promote the common of these inspections were routine announced and j defense and security. (The ROA also includes a unannounced inspections conducted by the DOE j change control process whereby USEC may SSR, primarily in the X-326 Process Building propose changes to the ROA.) In addition to and the X-705 Decontamination Building where l DOE staffin Oak Ridge, the DOE RO Program HEU activities take place. These DOE maintains a DOE site safety representative inspections focused primarily on the following l (SSR) at PORTS. This SSR provides day-to-functional areas of plant operations related to day surveillance and oversight of HEU-related if EU refeed: Managerial Controls and activities to help ensure USEC's compliance Oversight, Operations, Radiation Protection with the ROA. Programs, Nuclear Criticality Safety (NCS), and Security. During these inspections, DOE The foFowing five sections discuss the selectively examined procedures and records, activities of the DOE RO Program in FY 1998. interviewed personnel, and observed activities in progress. These inspections included one functional appraisal that was performed to ensure ROA requirements were being met for the Quality Assurance functional area and one special inspection that focused on the NCS l 'The NRC Certificates of Compliance for PGDP and PORTS limit USEC's possession of uranium enriched to 20% or greater in "U at each site to less than 1000 grams. 2 4
In February 1998, DOE performed a special failure to complete NCS interaction calculations review of NCS activities related to the HEU and make required postings to control possible cylinder-cleaning operation in Building X-705. interactions between fissile material stored in DOE conducted this review in response to adjacent areas within the X-326 and X-705 numerous NCS concerns identified by DOE and facilities. In accordance with the October 1997 NRC. As a result of this review, a MOU, DOE notiDed NRC of this violation determination was made that the NCS which was identified in a shared area at PORTS. Corrective Action Plan (CAP) that had been All of these violations were Severity Level III developed by USEC for use in leased areas violations. Corrective actions associated with regulated by NRC should also apply to leased these violations are tracked to closure by the areas regulated by DOE. Accordingly, USEC DOE SSR. The DOE inspections, inspection committed to, and is implementing, the NCS reports, and NOVs issued for activities in CAP in all leased facilities, including those leased, but not certiDed, facilities at PORTS are ponions regulated by DOE. summarized in Appendix A. " Summary of DOE Regulatory Oversight Program inspection in June 1998, DOE conducted a special Repons." inspection of the portions of the NCS program in the leased, but not certified, facilities at PORTS under DOE'sjurisdictior.. Violations of 2.2 OPERATIONAL READINESS NCS controls and findings of denciencies in the EVALUATIONS NCS program prompted DOE to initiate this comprehensive specialinspection. This Section 3.3.2.6 of the ROA requires USEC inspection examined relevant NCS to obtain DOE consent and written approval for documentation, training records, procedure any proposed changes that involve an controls, configuration management, corrective Unreviewed Safety Question (USQ) or a change action program, and other pertinent aspects of in the authorization basis or an Operational the NCS program. A Severity Level 111 Safety Requirement (OSR). In Ai+ gust 1997, violation, described below (third FY 1998 USEC requested DOE approval to chemically violation) was cited. DOE continues to closely clean cylinders containing residual (heel) HEU monitor implementation of the NCS CAP at material and to downblend the resultant product PORTS. to an assay ofless than 10% "U at PORTS. In 2 September 1997, DOE conducted an In FY 1998, DOE issued three NOVs to Operational Readiness Evaluation (ORE) to USEC, all of which involved NCS issues. The evaluate the HEU cylinder-cleaning facility first violation involved improper storage of an located in Building X-705. Following an HEU cylinder in the X-326 High Assay extensive on-site evaluation and subsequent Sempling Area (HASA) Vault. This HEU resolution of outstanding issues, DOE issued an cylinder was stored within 35 inches of other ORE report entitled Department ofEnergy uranium-bearing materials in violation of NCS OperationalReadiness Evaluation Reportfor administrative spacing requirements for this the Cleaning ofHighly Enriched Uranimn area. TI~ second violation also involved a Cylinders at the Portsmouth Gaseous Diffusion violu.c c f NCS administrative spacing Plant, dated November 7,1997. requirements. HEU cylinders were moved within 35 inches of other uranium-bearing On November 12,1997, DOE gave USEC materials in the X-326 Product Withdrawal area approval to begin cleaning HEU cylinders and where HEU refeed activities were being downblending the product HEU material te -ee g 8 conducted. The third violation resulted from a than 10% assay at PORTS. Two ORE findings, / 5 p t
which were resolved before startup of the Enriched Uranium Cylinders and Blending of cleaning operations, involved procedural HEU Hect Material in the X-705 Building, difficulties in simulating cleaning operations dated November 7,1997, was issued to approve and inconsistencies in engineering calculations the cylinder-cleaning operations. Other SERs related to safety features intended to limit were issued to approve the 11ASA Vault and uranium hexafluoride (UF.) releases. USEC's inoperable cylinder valve replacement response to these ORE findings was reviewed operations. DOE plans to revise the SER on and found acceptable. The cylinder-cleaning cylinder cleaning to approve the use of operations approved by DOE include cleaning additional FLMs. These SERs are part of the of 5-inch cylinders in the designated space in safety basis for DOE approval of continued the high bay area of Building X-705 and operations by USEC under the ROA. cleaning of 8-inch and 12-inch cylinders in the West Annex of Building X-705. 2.4 SAFEGUARDS AND SECURITY During FY 1998, DOE performed three ACTIVITIES additional ORES related to lieu refeed operations. These ORES included evaluating the On October 15,1997, DOE approved the (1) use of the liASA Vault for cylinder storage, Security Plan for the X-326 safeguards and (2) replacement of several inoperable cylinder security surveys to confirm the quantity cf valves, and (3) use of additional First Line uranium enriched above 9.99% "U contained 2 Menagers (FLM) in the cylinder-cleaning in the X-326 facility. operations. Regarding the first two ORES, DOE approved use of the 11ASA Vault for cylinder On November 26,1997, DOE approved the storage and replacement ofinoperable cylinder Safeguards and Security Plan for International valves. Regarding the third ORE, upon receipt Atomic Energy Agency (IAEA) activities at of additional training and operating experience, PORTS that began in December 1997. On two additional FLM trainees will achieve full December 30,1997, an addendum addressing qualification status and become available to help additional information, limitations, and other r increase the rate of cylinder cleaning. modifications to the Safeguards and Security Plan for IAEA monitoring of HEU refeed activities at PORTS was approved. This 2.3 SAFETY EVALUATION REPORTS Safeguards and Security Plan was required to support I AEA's first trial inspection of a U.S. The safety evaluation report development uranium processing operation, process specified in DOE Order 5480.23, Nuclear Safety Analysis Reports, was utilized by In December 1997, the Security Plan for the DOE RO Manager to document DOE PORTS X-705 inoperable llEU cylinder valve approval of USEC's proposed changes under replacement activities was approved. This plan Section 3.3.2.6 of the ROA. During FY 1998, outlined the physical security requirements and safety evaluation reports (SERs) were issued in addressed the protection of all assets maintained I response to USEC request; for approval of in the South Annex of Building X-705 for the changes in the llEU refeed operations described purpose of replacing inoperable llEU cylinder in Section 2.2 of this report. One SER, entitled valves in support of11EU refeed activities. Department ofEnergy Safety Evaluation Report Also, in December 1997, a revised Personnel for the Portsmouth Gaseous Diffusion Plant, Security Assurance Program was prepared to Cleaning of 5-inch, 8-inch, and 12-inch Highly implement DOE's requirements at PORTS. 6
i On July 29,1998, DOE directed a in support of the IAEA activities at PORTS, recategorization of the X-326 facility from a the DOE RO Program modified its inspection DOE Category I to a Category 111 status. This program to address llEU refeed activities i action was taken following (1) completion of impacted by the presence of the I AEA i lieu Suspension and Removal activities in the inspectors. Additionalinspection activities X-326 facility, (2) completion of surveys to included examination of(l) equipment and l confirm the quantity of uranium enriched above procedures related to the IAEA inspections and 2 9.99% "U in the X-326 facility,(3) collection (2) compliance with applicable safeguards and of til uninstalled equipment containing security plans. measurable quantities of11EU in a fenced and guarded storage area in the X-326 facility, (4) DOE approval of the revised X-326 Security
3. IIIGIILY ENRICIIED URANIUM Plan, and (5) DOE approval of Material Control ACTIVITIES and Accountability information. It is expected that this action will significantly reduce the in November 1991, the Secretary of Energy safeguards and security operating costs to DOE directed the suspension ofIlEU production at at PORTS.
PORTS. At that time, PORTS was the only remaining facility in the United States producing lieu. As a result of past IIEU 2.5 INTERNATIONAL ATOMIC ENERGY production, excess 11EU material remained in AGENCY ACTIVITIES storage at PORTS. DOE retains responsibility for this excess lieu as reflected in the During FY 1998,IAEA inspectors visited December 1993 Joint Statement of PORTS to independently verify the 11EU refeed Understanding Between the Nuclear Regulatory operations to downblend weapons-grade Commission and the Department ofEnergy on uranium to uranium suitable for peaceful uses implementing the Energy Policy Act Provisions (i.e., fuel for civilian nuclear power plants). on Regulation ofGascous Diffusion Uranium Specifically, the activity conducted by the IAEA Enrichment Plants.' Regarding the ultimate inspectors involved verifying that a measured disposition of this excess 11EU at PORTS, DOE quantity ofliEU was converted to LEU through efforts during FY 1998 have been directed independent measurements of the material. In toward reduction and removal of the excess announcing the verification activity by the 11EU from PORTS, as described in Sections 3.1 IAEA, Energy Secretary Peita stated that and 3.2 below. Activities conducted to support the HEU Purchase Agreement between DOE [t]his is the first time the Intemational Atomic and the Russian Federation through the HEU Energy Agency has verified the transparency activities performed at both PGDP transformation of nuclear material no longer and PORTS are described in Section 3.3. needed for defense use into a form usable by the commercial nuclear industry. lAEA monitoring provides confidence to the international community that nuclear reductions are moving forward and will be irreversible. The verification activity here (at 'The Joint Statement of Understanding states that PORTS] will also provide the knowledge "[djuring the entire period that uranium enriched to needed to conduct similar activities in other 20 percent or more U* [IlEU] is located at the Portsmouth countties. facility, DOE will retain title to and possess such uranium l and will be solely responsible for providing for, establishing and maintaining nuclear safety, safeguards and security controls applicable to such uranium." 7
3,1 IIIGIILY ENRICilED URANIUM West Annex of Building X-705 under DOE REFEED AND CYLINDER-CLEANING regulatory oversight. In order to complete a PROGRAM Compliance Plan commitment related to USEC's possession limits for uranium enriched to 10% The purpose of the llEU refeed activities at or more in *U. :pproximately 370 cylinders PORTS is to downblend excess IIEU in the (5-ino Lir.ch, and 12-inch-diameter) are form of UF. gas into LEU to be sold scheduled to be cleaned at PORTS by l commercially for peaceful purposes. The lieu, December 31,1998. Approximately 940 other j which originally was produced for U.S. military 11EU cylinders are being cleaned off-site at purposes during the Cold War, was declared Nuclear Fuel Services, Inc. (NFS) in Erwin, excess to the nation's defense needs. In the Tennessee. December 15,1994, Memorandum of Agreement (MOA) between DOE and USEC Following DOE's approval on November 12, entitled Memorandum ofAgreement Relating to 1997, cylinder cleaning at PORTS began the the Transfer ofFunctions and Activitiesfrom week of May 11, l998. Ilowever, because of the Department ofEnergy to the UnitedStates startup and continued operational problems, of Enrichment Corporation, both parties agreed the approximately 370 cylinders, only eight l that DOE would provide this material to USEC 8-inch cylinders and two 12-inch cylinders have l for refeed and downblending. been cleaned by USEC as of September 30, l 1998. Two options, multishift-cleaning lieu refeed activities at PORTS are operations and potential off-site cleaning, are conducted in three areas of Building X-326 being reviewed by USEC to accelerate cleaning under DOE regulatory oversight. These areas, of these remaining IIEU cylinders at PORTS. the Product Withdrawal area, Area Control l Room 6, and Unit X-25-7, are clearly delineated A byproduct of the cylinder-cleaning l so that there is no confusion regarding which process is uranyl nitrate solution. This solution 2 agency is the cognizant regulatory authority. is downblended to less than 10% "U j Approximately 14 metric tons ofIIEU were enrichment in the Wst Annex of safely refed and downblended to LEU by USEC Building X-705 under DOE regulatory l from May 1995 to July 1998. This amount oversight. The cylinder-cleaning operation I represents a significant reduction in the quantity could result in approximately 19,000 liters of ofIIEU at PORTS as well as a gross value of this solution. USEC will process the uranyl $153.5 million in enrichment services to USEC. nitrate solution for final disposition either in the The lieu Refeed Program was completed ahead X-705 facility or at an off-site commercial l of schedule on July 17,1998. This early facility. completion was due to an increased refeed rate attributed primarily to the following factors: l (1) increased availability of feed stations, 3.2 IllGIILY ENRICIIED URANIUM l (2) improved purge cascade performance and SUSPENSION AND REMOVAL operation, and (3) optimum feed position PROGRAM utilization. The DOE 11EU Suspension and Removal After completion of refeeding, the 11EU Program addresses the overall disposition of cylinders are chemically cleaned to remove lieu at PORTS. This program is designed to residual IIEU material for disposition. The accomplish the following: (1) safely suspend lieu cylinder cleaning effort is conducted in a llEU operations and shut down llEU equipment designated space in the high bay area and in the in Building X-326;(2) modify equipment and 8 l
systems to preclude production of11EU and A plan for the disposition ofliEU-bearing perform maintenance in X-326 that is necessary materials, issued in March 1996, continues to be for continued LEU production (" legacy implemented. In late 1997, approximately maintenance"); (3) modify the conGguration of 400 kg of uranium oxides were shipped to the shutdown equipment to minimize long-term Oak Ridge (Tennessee) Y-12 Plant for interim surveillance and maintenance requirements; and storage. The remaining uranium oxides stored (4) remove stored IIEU materials from PORTS, in the X-345 facility (about 7 metric tons) are including uranyl nitrate hexahydrate, uranium authorized for shipment to a commercial oxide, and lieu-contaminated materials. The downblending facility under a recently approved removal of these stored 11EU materials will MOA between DOE and USEC.8 On reduce the related ES&li risks and is expected August 31,1998, USEC selected its to reduce safeguards and security operating downblending vendor. Shipment of these oxides costs at PORTS. started on September 15,1998, and is expected to be complete by August 1999. A large portion As described previously, portions of the of the llEU-bearing materials classified as lieu Suspension and Removal Program are Resource Conservation and Recovery Act regulated by DOE under the ROA. Three (RCRA) waste previously stored in the X-326 PORTS facilities are directly affected by the L-cage facility was shipped to Los Alamos HEU Suspension and Removal Program. These National Laboratory for treatability studies in facilities include the X-326 process facility, the February 1998. The treatability studies are X-705 decontamination and uranium recovery underway and are scheduled to be complete by facility, and the X-345 special nuclear material May 1999. Other lieu-bearing material that is storage facility. Buildings X-326 and X-705 are not classified as RCRA waste, consisting largely critical to the ongoing LEU mission; therefore, ofliEU trapping materials, was shipped to NFS USEC leases these facilities from DOE. for lieu recovery and downblending to LEU for Building X-345 is retained by DOE. Activities possible resale. These shipments were that are conducted in this building are regulated coiapleted in January 1998, and processing is in accordance with DOE orders and PAAA underway at NFS. As of September 30,1998, regulations. all of the trapping material has been processed through uranium dissolution and purification Operations related to removing IIEU. and two of seven blesd-down campaigns have bearing materials from cascade equipment in been completed. Blend-down and conversion to Building X-326 and downblending these LEU oxide is scheduled to be completed in materials to LEU are complete (ifEU suspension). After removal ofliEU-bearing materials from approximately 200 cells in the cascade to deposit sizes below " safe mass" as 'On April 20,1998. DOE and USEC entered into a determined by NCS anal ' sis,158 cells were MOA enthled uern randum opgmmensfor Trans/n of I Natural Uranium and Highly Enriched Uranium andfor placed in permanent shutdown condition. The Blend-down of/hghly Enriched Uranium. As prosided by permanently shutdown lieu cells in Building the USEC Privatization Act. this MOA describes the X-326 were buffered with dry air / nitrogen to manner in which " DOE shall transfer to USEC without ensure that NCS requirements were met, charge up to 50 metric tons of enriched uranium and up to Surve.llance and maintenance of the 7.000 tons of natural uranium from DOE's stockpile." The i MOA also describes the manner in w hich DOE will 158 shutdown cells continues. Periodic transfer and USEC will accept the uranium and defines the nondestructive assay (NDA) surveys are being DOE and U3EC safeguards and security responsibilities for performed to ensure that no unacceptable enriched uranium. In the MOA, DOE and USEC agree that 7 metric tons ofIIEU oxides at PORTS will be available migration of remaining HEU deposits occurs. for delisery no later than the end of FY 1999. 9
l l December 1998, with commercial disposal of all and provides for the purchase of 500 metric tons process waste to be completed by June 1999. of HEU fiom dismantled Russian weapons over a period of 20 years. Since the signing of this Under the provisions of a pending initial agreement, an MOU, an llEU Purchase agreement between DOE and USEC regarding Contract, and a Protocol to the MOU have been HEU disposition, DOE will store USEC signed to delineate terms of the agreement. In l equipment and containers of material containing addition, a total of 16 annexes to the Protocol uranium enriched to 10% or more 235U that have been signed at Transparency Review resulted from DOE legacy operations at PORTS. Committee meetings. These annexes define the Under NRC regulations, USEC cannot, at any rights of each party to provide confidence that time, possess quantities of uranium that will each party is abiding by the terms of the cause the total quantity possessed by USEC agreement. j across all leased and cenified areas to exceed NRC Category Ill limits. Therefore, USEC has The GDPs have played key roles in several proposed to NRC that because DOE has aspects of the DOE I1EU Transparency regulatoryjurisdiction over accessible uranium Program. The HEU material covered under enriched to 10% or more 235U, activities terms of the agreement is sent to the United involving this material in USEC-leased areas States as LEU suitable for use as fuel in light-i l will be conducted in accordance with the ROA. water reactors. The HEU is blended with i l HEU-related activities in nonleased facilities slightly enriched uranium in Russian facilities will continue to be conducted in accordance and shipped to the United States as LEU for sale with the nuclear safety and safeguards and by USEC, which acts as agent for the U.S. security requirements of the DOE orders and government. The material arrives at PORTS as PAAA regulations applicable to such uranium. UF in 30B cylinders,in which it is stored This agreement is intended to provide the until its sale to utilities and subsequent shipment framework for an efficient and cost-effective to fuel fabricators. During CY 1998 (through process for disposition of this uranium at August), PORTS has received approximately PORTS. 277 30B cylinders from Russian blending facilities. Since CY 1995, PORTS has received j a total of 888 30B cylinders. Under terms of the l 3.3 HIGHLY ENRICHED URANIUM agreement, DOE and MINATOM are allowed to TRANSPARENCY PROGRAM establish Permanent Presence Offices (PPOs) at certain facilities where personnel can monitor The HEU Transparency Program, prescribed activities to provide confidence that f established within DOE's Office of Nuclear each side is abiding by the terms of the j Energy, Science and Technology, is responsible agreement. In the United States, MINATOM l for implementing all transparency measures has established a PPO at PORTS. Thus far, I related to the HEU Purchase Agreement MINATOM has maintained only a sporadic between DOE and the Russian Federation's presence at PORTS, and no Russian delegation l-Ministry of Atomic Energy (MINATOM).' The has been at PORTS this fiscal year. However, HEU Government-to-Government Umbrella office space is maintained and other services are Agreement was signed on February 18,1993, on standby to support this activity. ' Transparency measures are those measures employed I by DOE to provide confidence to the United States that the downblending of Russian llEU is occurring in accordance A JOB cylinder can contain a maximum net weight with the agreement. of approximately 2.3 metric tons of UF,,. 10
PGDP has played a key role in the testing and the public and to promote the common and demonstration of some nonintrusive defense and security. instrumentation for monitoring UF. gas flow and enrichment. This equipment was developed DOE prepared Compliance Plans for in DOE's national laboratories for installation in submittal with the USEC applications for initial Russian blending facilities as a means of certification of PGDP and PORTS. These plans providing confidence that the downblending of were initially submitted to NRC on April 24, l IIEU is actually occurring. To demonstrate the 1995. Revisions to accommodate USEC l equipment in actual use to a Russian delegation, application changes and commitments to NRC a UF. flow loop simulating the flow conditions were submitted through August 1996." Final l in Russian blending facilities was fabricated and applications were submitted by USEC to NRC l installed in the PGDP purge cascade. To obtain in August 1996, and NRC issued the initial neccssary approvals to proceed with the Certificates of Compliance to USEC on demonstration, a rigorous and methodical November 26,1996. On April 15,1998, USEC l review of all aspects of the equipment was submitted applications for renewal of the initial conducted. Final approval for the demonstration Certificates of Compliance for PGDP and at PGDP was granted on October 31,1997. PORTS. l Actual installation of the flow loop was delayed until March 1993 because of equipment The original Compliance Plans address the problems in the purge cascade. Process gas noncompliances identified by USEC before flow through the test loop first occurred in certification and provide the following: (1) a mid-April 1998. description of the noncompliance,(2) a reference to USEC's application commitment with which USEC had not yet complied,(3) a
4. COMPLIANCE PLAN ACTIVITIES justification for continued operations, and (4) a description of the plan of action and schedule For NRC to permit continued USEC for achieving compliance with NRC regulations.
operation of the GDPs, the EPAct required that The Compliance Plans were revised as USEC DOE prepare plans for bringing the leased areas revised its applications and identified additional of the GDPs into compliance with any noncompliances.i2 No new Compliance Plan unsatisfied provisions of NRC regulations. issues were identified in the Aprd 15,1998, l Following the promulgation of 10 CFR 76, it applications for renewal of cWhation to became apparent that there were portions of the operate, although modifications to the original l regulations with which USEC could not Compliance Plans have been requested by l immediately comply. The existence of these noncompliances does not indicate a difference in the overall level of health, safety, and - safeguards and security protection provided to "NRC's initial certification of USEC's operations at workert and the public under DOE oversight each GDP was based on USEC's application for versus that provided under NRC oversight. certification. which included Rev. 3 A of the DOE prepared Rather, these noncompliances reflect either Compliance Plan for each GDP. (1) areas where full compliance with existing "For a discussion on the types of noncompliances, the DOE requirements had not been ach,eved or reader is referred to the report entitled Department of i \\ (2) differences between the NRC and DOE Energy input to the Nuclear Regulatory Commission's regulatory approaches used to ensure adequate Annual Report to Congress Regarding the Status of protection of the health and safety of workers Ilealth. Safety. and Environmental Conditions at the Paducah and Portsmouth Gaseous Diffusion Plants, DOE /ORO/2059. dated October 1997. i 4 11
USEC through Certificate Amendment Requests requested modifications to NRC for review and to the NRC. final approval. As illustrated in Table 1, during ( FY 1998, DOE reviewed seven USEC-The dates by which compliance with NRC submitted change requests. One of these change regulations will be achieved range from 1996 requests was subsequently withdrawn by USEC. through 2002 for the various noncompliances, Following a review period, DOE approved all depending on the specific upgrade actions that remaining change requests. are required. During the fall of 1996 and continuing through February 1997, DOE verified completion of approximately half of the
5. NUCLEAR SAFETY UPGRADES actions required to achieve compliance. On PROGRAM February 24,1997, DOE advised NRC that it had reviewed those action items scheduled for Section 1403(d) of the EPAct states that l
completion prior to March 3,1997 (with the ] exception of action items that had been delayed [t]he payment of any costs of D&D, response by USEC). When NRC assumed regulatory actions, or corrective actions with respect to oversight on March 3,1997, additional conditions existing before the transition date, i Compliance Plan issues were completed as part in c nnection with propeny of the Depanment of the transition. Responsibility for reviewing [ f Energy] leased under subsection (a) (of EPAct, i.e., the leased portions of the GDPs] and verifying completion of all remaining open shall remain the sole responsibihty of the action items in the Compliance Plans transferred Department, to NRC at this time. The nuclear safety and safeguards and In the October 1997 MOU between DOE security aspects of this DOE liability for and NRC (described in Section 1.2 of this preexisting conditions were further defined in report), both parties agreed that USEC must the Lease and in the Memorandum ofAgreement obtain DOE approval of any modifications to Relating to the Transfer ofFunctions and the Compliance Plans before submittal of the Activitiesfrom the UnitedStates Department of Table 1. Modified Compliance Plan Issues Approved by DOE in FY 1998 Plant Issue Title Date Approved PGDP 3 Autoclave Upgrades 10/27/97 2 PORTS A.4 Possession of Uranium Enriched to Greater than 10% "U 11/18/97 PORTS 21 Management Controls iI/25/97 PORTS 24 Maintenance Program 12/08/97 PGDP 27 Procedures Program Withdrawn PORTS 30 01/08/98 PGDP 44 Operational / Safety System Trip Redundancy 02/17/98 PORTS 11 Exceptions for Criticality Accident Alarm System 05/29/98 12
i Energy to the UnitedStates Enrichment result, DOE ORO reviewed and managed the Corporation, dated December 15,1994, NSU costs by (1) establishing a cost validation between DOE and USEC. This MOA requires process; (2) preparing estimates of DOE DOE to reimburse USEC for all work in the liabilities; (3) making partial offset payments to l following categories: (1) work required to bring USEC against a portion of the $153.5 million l the GDPs into compliance with the nulear value of the approximately 14 metric tons of l safety and safeguards and security requirements HEU provided to USEC under the MOA dated of the ROA, (2) safety improvements directed December 15,1994, as amended by Amendment l by DOE, and (3) work to obtain either an initial FY 98-2, dated May 18,1998; and (4) denying l certificate of compliance from NRC or NRC costs that were not in accordance with l approval of DOE-prepared Compliance Plans. established criteria for reimbursement. In The Nuclear Safety Upgrades (NSU) Program January 1995, to validate the NSU costs consists of various projects in these categories contained in periodic USEC requests for that were initiated by USEC after July 1,1993. reimbursement, DOE ORO assembled a team USEC has grouped the NSU projects into five (DOE Cost Validation Team) knowledgeable of i ( major areas: (1) ROA compliance activities, the USEC cost-estimating and cost-collecting (2) NRC certification activities, (3) DOE-systems, the NSU projects proposed by USEC, i directed safety improvements,(4) functional the DOE-prepared Compliance Plans, the NRC improvements, and (5) equipment or facility Compliance Evaluation Reports, and the upgrades. provisions of the Lease and the MOA regarding reimbursable costs. The USEC NSU Program Plan, Uranium Enrichment (UE) Nuclear Safety Upgrades Program Plan, Rev. 3 A, UEO-1036, dated 5.1 NUCLEAR SAFETY UPGRADES April 14,1997, describes the NSU projects and PROGRAM STATUS related activities. Although most of these l projects support achievement of NRC As described previously, DOE is l certification by ensuring compliance with responsible for funding a broad range of NSU 10 CFR 76, others were initiated to meet ROA activities at the GDPs. Since January 1995, requirements or to make other safety or DOE ORO has monitored the progress of the safeguards and security improvements mandated NSU projects required for compliance with by DOE. Finally, some projects were initiated DOE or NRC regulations and validated NSU by USEC to support operations at the GDPs. costs as they were incurred by USEC based on Consequently, some of the projects in the NSU USEC invoices, cost documentation, and Program Plan do not correspond to issues that completed deliverabies. As of December 1997, are included in the Compliance Plans for the DOE had validated approximately $100 million GDPs. For those additional NSU projects that in NSU costs for 70 projects and related are not discussed in Compliance Plan issues, activities. At that time, approximately USEC has determined that these projects are 45 projects were complete (i.e., about 64% of l appropriate to support the continued safe the total). The major NSU projects that remain operations of the GDPs even though USEC, to be completed by USEC include the following. DOE, and NRC have not found them to be necessary for compliance with 10 CFR 76. Seismic Modifications to C-331 and C-335 (PGDP). This NSU project provides for The DOE ORO Office of Enrichment structural modifications necessary to upgrade l Facilities has lead responsibility for Buildings C-331 and C-335 to meet the administering the Lease for the GDPs. As a requirements for ensuring structural integrity 13
of these buildings in the event of a 250-year-condensate removal to reduce the risk of an recurrence-interval earthquake. These inadvertent criticality. At PGDP, the modifications, along with interim upgrades include improved autoclave 4 compensatory and corrective actions imposed containment testing and instrumentation to by DOE, will reduce the risk to the public reduce the risk of exposure of the public and and on-site workers in the event of seismic on-site workers to an accidental release of activity that could damage the buildings. U F., e Safeguards and Security Surveys Seismic Modifications as a Result of a Safety Analysis Report (SAR) Update (PORTS). This project, completed in (PGDP). This project provides for structural FY 1998, provides necessary measurements modifications to Buildings C-310/310A and to con 0rm that the special nuclear material in C-315 and other leased facilities at PGDP Building X-326 (excluding inaccessible identified through the update of the SAR as residual 2"U holdup material in the process ."~ being necessary to improve the seismic equipment) is below NRC Category til capacity of these facilities. safeguards and security limits. e Radiation Protection (PORTS and Criticality Accident Alarm System a a PGDP). This major project (1) provides Upgrades (PGDP). These projects provide National Voluntary Accreditation Laboratory enhanced Criticality Accident Alarm System 14ogram dosimetry to the GDPs, (2) provides (CAAS) horn audibility in the PGDP process 'I*' for performance of characterization surveys buildings and improved CAAS coverage for of radiological hazards at the GDPs, and nearby buildings at PGDP. (3) provides for posting of the radiological ha7ards so that they are readily identifiable These remaining NSU projects are projected by workers. to be complete by 2001 in accordance with the Compliance Plans for the GDPs. The remaining Integrated SAR Update (PORTS and costs for these projects are included in a lump PGDP). This major NSU project provides sum settlement on the DOE financial liabilities for the coordination of activities required for for NSU costs described in the following USEC to prepare and resubmit to NRC an section. updated SAR based on the upgraded 1995 DOE SAR submitted in January 1997. The updated SAR and associated Technical 5.2 NUCLEAR SAFETY UPGRADES COST Safety Requirements provide an updated SETTLEMENT safety basis for NRC approval of continued operations of the GDPs by USEC. In late FY 1997, DOE and USEC reached agreement on a proposed lump sum settlement Autoclave Modifications (PORTS and of $220 million to completely satisfy DOE's PGDP). These projects provide for safety financial liabilities for preexisting nuclear safety improvements to the autoclaves used in UF, and safeguards and security conditions at the feed systems at both GDPs. At PORTS, GDPs. The amount of this settlement was improvements include containment valve established based primarily upon (1) DOE and testing, installati n of fail-safe containment USEC agreements in the Lease and the MOA valves, modification of containment controls dated December 15,1994;(2) the specific to prevent inadvertent opening of autoclaves, requirements and commitments contained in the improved operational alarms, and improved DOE-prepared Compliance Plans and NRC / !4
Compliance Evaluation Reports," which agreements between DOE and USEC are used identined the actions USEC was required to by DOE, USEC, and subcontrutor peconnel. take to meet NRC regulations; and (3) the DOE evaluation of NSU costs incurred and the in February 1998, the DOE ORO Of6ce of estimate of the future reimbursable costs for Enrichment Facilities issued a guidance NSU activities. Subsequently, under the document entitled ComputerSoftware Files December 15,1994, MOA, as amended by Configuration Control Guidance Document that Amendment FY 98-1, dated May 18,1998, DOE provides specific control measures for the agreed to transfer to USEC sufficient enriched computer software data files. These files and natural uranium material, in addition to the consist of PGDP and PORTS site maps, DMSA 14 metric tons of HEU previously provided to drawings, the listings in Lease Exhibit A and USEC, to fund this agreed-upon settlement. The Lease Exhibit B, and applicable letters. This subsequent transfer of this material, in con 0guration control guidance document 4 combination with the $35 million settlement in defines a lease configuration control process for Section 5.l(a) of the Lease, satisfies DOE's PGDP and PORTS Building Lease Status financial responsibilities under Section 1403(d) drawings using compact disc read-only of the EPAct, electronic files (CD-ROM). It ensures that DOE ORO will properly establish the baseline files, perform a controlled distribution of the files to
6. LEASE MODIFICATIONS USEC and each DOE site manager, and effectively control changes to the files. This As stated previously, pursuant to the EPAct, process ensures that all personnel at the GDPs DOE leased portions of PGDP and PORTS to will have accurate and ready access to a USEC on July 1,1993. DOE and USEC controlled copy of the electronic files describing subsequently agreed that DOE, in its role as the buildings, areas, and structures that are landlord of the leased facilities at the GDPs, leased to USEC, owned by USEC, or retained would maintain the controlled copy of the by DOE.
Lease, including the Building Lease Status drawings and the DOE Material Storage Area No modifications were made to the Lease (DMSA) drawings. In August 1997, Lease during FY 1998. USEC submitted a proposal to Exhibits A (Leased Premises) and B (Leased DOE to delease acreage at both GDPs that was Personalty) Configuration Control Directives not essential to uranium enrichment operations. were developed and issued by DOE with the Although DOE has agreed to the proposed concurrence of USEC. The purpose of these deleasing, USEC has not approved this revision Directives, which provide configuration control to the Lease. DOE notified NRC on June 25, guidance for Building Lease Status drawings 1998, that, pending USEC approval, the acreage and DMSA drawings, is to ensure that only proposed for deleasing remains part of the those drawings reflecting the most recent leased premises subject to NRC regulation. l l
7. ENVIRONMENT, SAFETY, AND 11EALTII STATUS OF
" Compliance Evaluation Reportfor the Certification ofthe UnitedStates Enrichment Corporation Pcducah NONLEASED AREAS Gaseous Dif]usion Plant. Paducah, Kentucky (Docket 70-7001) and Compliance Evaluarton Reportfor The DOE mission at PGDP and PORTS the Certification ofthe UnitedStates Enrich,nent includes Environmental Management (EM) and Corporation fortsmouth Gaseous Difusion Plant. Portsmouth. Ohio (Docket 70-7002). Enrichment Facilities (EF) activities. The EM 1 15 I I =
i Program identi6es and reduces the ES&H risks 7.1 ENVIRONMENT, SAFETY, AND at the GDPs through environmental restoration HEALTIl STATUS OF NONLEASED 1 (ER) and waste management (WM) activities. AREAS AT PADUCAll ] The EF Program manages and reduces ES&H risks at the GDPs through the following During FY 1998, DOE and its contractors activities:(1) management of DUF to ensure and subcontractors made good progress toward 6 safe storage of cylinders and to develop long-completion of their mission at PGDP with no term management strategies for this material, occupational injuries that caused any employee (2) participation in the NRC certi6 cation and to miss a day of work. DOE met all regulatory process (e.g., review of all proposed 72 regulatory deliverables on schedule. Compliance Plan modifications; oversight of activities in areas that are leased, but not Improved strategies for environmental certi6ed; and coordination and information cleanup and WM were developed during exchange with NRC), (3) maintenance of FY 1998. Implementation of these strategies nonleased facilities, and (4) administration of will begin in FY 1999. Environmental cleanup the Lease with USEC. Integration of ES&H will focus on site-wide remedial cleanup activities ensures that DOE EM nd EF objectives, rather than on individual locations. activities at the GDPs are conducted in a way This approach will save money by reducing that avoids accidents or injuries to workers and documentation costs, and the savings will be the public and avoids harm to the environment. mvested in cleanup. For WM, all waste streams DOE ES&H activities at the GDPs include in storage have been ranked according to risk. environmental protection, nuclear safety, Wastes that pose a higher risk by remaining in engineering, public health, industrial hygiene, storage will have top priority for disposition. radiation protection, construction safety, risk management, epidemiology, and occupational 7.1.1 Facilities and Acreage medicine. The DOE EM and EF Programs at the GDPs are managed by DOE ORO. DOE owns the 3,556-acre PGDP reservation and leases the uranium enrichment facilities to On April 1,1998, as part of DOE's contract USEC. At PGDP, DOE leases 315 buildings reform initiative, DOE implemented a and facilities to USEC and retains 134 as management and integration (M&I) contract for "nonleased." The nonleased facilities include the EM and EF work at the Oak Ridge Reservation in Oak Ridge, Tennessee, and at roads and grounds outside the perimeter both GDPs. Objectives of the M&l contract, security fence on the DOE Reservation, which replaced a management and operating parcels ofland designated for environmental (M&O) contract, include accelerating cleanup cleanup [ solid waste management units and maximizing cost-effective completion of (SWMUs)], I work. At the foundation of the M&l contract is an operating solid waste contained land 611, DOE's Integrated Safety Management System (ISMS). The objective ofISMS is to waste storage and treatment facilities, systematically integrate safety and two groundwater treatment systems, environmental protection into planning and two complexes of facilities under performance of work at all levels so that surnillance and maintenance in the D&D workers, the public, and the environment are
program, protected.
nonleased facilities not in use and not yet in the D&D program, 16
l 1 1 1 office and laboratory facilities, and rate of the surfaces of the steel cylinders, storage yards for cylinders containing DUF.. which are stored outdoors. DOE responded with an implementation Plan containing a set l 7.1.2 Depleted Uranium llexafluoride of actions and schedule for resolving the Management concerns. These actions have been either l completed or incorporated into procedures l The DOE EF Program is responsible for for ongoing maintenance and management, l management of DUF generated at PGDP from as appropriate. the start of enriched uranium production in 1952 i until the creation of USEC on July 1,1993. DOE is refurbishing older cylinders by DOE has oversight of the DUF based on the blasting their exterior surfaces with a Atomic Energy Act of 1954. DOE is recyclable steel grit before applying a zinc-responsible for storage, inspection, and based paint to minimize the corrosion rate of maintenance of 30,263 UF. cylinders, of which the steel. Then, an approximately 4-ft x l 28,689 contain DUF, and 1,574 contain natural 12-ft area on the bottom of each cylinder is or slightly enriched uranium." The cylinders topcoated with an epoxy mastic for extra are stored on 1 I concrete storage yards with a Protection. During FY 1996 and FY 1997, a combined area of approximately 48 acres. The total of 2,168 cylinders were coated. During newest cylinder storage yard is the 121-acre FY 1998, a total of 1,200 cylinders were C-745-T facility, which was completed in coated as scheduled. March 1998. In addition to routine cylinder management activities, the following upgrades DOE surveillance and maintenance of and other activities are being performed at cylinders included the annual inspection of PGDP: 10,679 cylinders, quadrennial inspection of 10,582 cylinders, and cleaning of DOE has improved ES&H and other aspects 1,203 cylinder skirts. of cylinder management through its response to a recommendation from the Defense DOE's Office of Nuclear Energy, Science Nuclear Facilities Safety Board (DNFSB). and Technology is finalizing a Programmatic In 1995, the DNFSB issued Environmental Impact Statement (F EIS) to Recommendation 95-1," Improved Safety of determine a recommended alternative for Cylinders Containing Depleted Uranium." dispositioning the inventory of DUF. in The recommendation identified concerns storage at PGDP and PORTS and at the East with the overall condition and the corrosion Tennessee Technology Park (ETTP) ln Oak Ridge, T(nnessee. Several meetings ebout l this program have been held with the public l and with industry representatives. The final PElS is expected to be issued in 1998; a "In accordance with the Privatization Act, DOE and Record of Decision (ROD) is expected to be USEC signed an MOA during FY 1998 by which about issued in early 1999. 6.500 additional cylinders at PGDP and 2.600 additional cylinders at PORTS containing DUF. generated by USEC from July 1,1993, through privatization on July 28,1998, EF work at PGDP was projected to cost were transferred to DOE. According to a second MOA that $14.5 million in FY 1998. The proposed budget was also signed in FY 1998, an additional 2.026 USEC for FY 1999 is $13.3 million. t DUF. cylinders will be transferred to DOE between the l date of privatization and FY 2004. The total number of cylinders discussed in the text does not reflect the cylinders addressed in these MOAS. 17 I t l l
1 7.1.3 Environmental Restoration contamination, monitoring migration of groundwater contamination, and maintaining DOE ORO has an aggressive plan to signs and fences installed to limit access to accelerate completion ofits EM mission, which contaminated ditches, streams, and lagoons. includes ER and WM activities. The plan and its assumptions are described in a document The number two priority is control of high-titled Initial Accelerating Cleanup, Paths to concentration contaminated areas that are Closure, Oak Ridge Operations Office associated with aff-site contamination. (DOE /OR/01-1746, published in June 1998). Control actions that were initiated as early as 1995 and that are continuing include The regulatory framework for ER at PGDP operation of systems for hydraulic is the Pr.ducah Federal Facility Agreement containment of high-concentration portions (FFA)- a tri-party agreement among DOE, U.S. of the northwest and northeast groundwater Environmental Protection Agency (USEPA) contamination plumes, sediment controls at Region 4, and the Commonwealth of Kentucky the scrap yards (on-site), and source that became effective on February 13,1998. For treatment measures to reduce the several years before this date, PGDP ER was contamination in discharge through an on-based on a draft FFA. The FFA coordinates the site ditch. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), The number three priority, address suspected administered by USEPA, with the RCRA sources of off-site contamination [primarily corrective action program administered by polychlorinated biphenyls (PCBs) and Kentucky. PGDP was placed on the National trichloroethylene (TCE)], is under way and Priorities List (NPL) on May 31,1994. scheduled for completion in FY 2004. This priori +y, which includes remedial actions PGDP has identified 208 SWMUs, grouped such as excavation of PCB-contaminated into 30 Waste Area Groups (WAGS). Most of soils, also will include decision-making these areas are on DOE. property either within regarding remedial actions for certain burial the security fence or on the DOE Reservation. grounds and for TCE in dense non-aqueous Off-site contamination has affected groundwater phase liquids (DNAPLs). DNAPLs are between the plant and the Ohio River to the formed when groundwater contaminants sink north and, to a limited distance, downstream through the layers of the ground and pool in surface water, sediment, and soils. locations that are not permeable. To facilitate a logical environmental The number four priority, complete site remediation of PGDP, DOE has identified five evaluations for suspected sources of on-site major steps and prioritized them as follows: contamination, began in FY 1998 and is scheduled to end in FY 2004. Areas being The number one priority, mitigate immediate evaluated include those areas with low-risk risks, has been accomplished. Mitigation environmental concerns. Some of these began in CY 1988 and continued into areas may require no further action. CY 1993. Several continuing actions are being performed to ensure that immediate The number five priority, the final rem,1! risks remain at acceptable levels. These action on groundwater and surfM -w actions include providing municipal water to will address the effects of all specific sources l residents north of the plant in a designated of contamination. This priority wiM be area affected by off-site groundwater addressed in future years through the FFA 18
process based on results of three major $250,000-$850,000 in future disposal costs. On RemedialInvestigations. The three August 24,1998, DOE's prime contractor l investigations are WAG 6, which includes awarded the sale of an additional 30% of the l the C-400 Chemical Cleaning Facility and Duorine cells and associated equipment to a other areas; WAG 27, which includes the commercial Duorine production company. By C-720 Maintenance Facility and other areas; selling the cells and equipment, DOE expects to and WAG 28, which includes locations of save another $2 million or more in future the staging areas for original construction of hazardous waste disposal costs. the plant in the 1950s. Other FY 1998 DOE ER accomplishments The contaminants of primary focus in ER at at PGDP include the following: PGDP are TCE, a common industrial solvent; technetium-99 ("Tc), a radioactive materia! Completed Remedial Actions described in present in used nuclear reactor fuel that was the ROD for WAGS I and 7 at PGDP. recycled at the plant periodically during its first Actions at the C-746-K inactive sanitary approximately 20 years of operation; PCBs, a landHil include (1) continuation of existing fire retardant commonly used in oils in electrical surface water and groundwater sampling, systems; and uranium from the enrichment (2) installation of warning and entrance opcrations at PGDP. The environmental signs,(3) repair of a small area of the cap contamination that DOE is in the process of damaged by Dooding, (4) abandonment of remediating resulted primarily from historical two groundwater wells, (5) installation of practices no longer in use at PGDP. For one new monitoring well, and instance, PGDP ended its use of TCE as a (6) establishment of deed restrictions. The degreaser in 1993. Reactor " returns" are no WAGS 1 and 7 project also included No longer processed in the enrichment facilities; Further Action on six SWMUs, institutional however, residual "Tc remains in the process controls on a Gre training area, and deferral equipment. Use of PCBs is controlled and is in of action on the PGDP sewage treatment the process of being phased out in accordance plant. USEPA Region 4 approved this ROD with the Uranium Enrichment Toxic Substances on August 10,1998. Control Act (TSCA) FFCA. Treated more than 198 million gallons of The current scope of the D&D program at contaminated groundwater at the two PGDP consists of surveillance and maintenance groundwater treatment systems in FY 1998. of two complexes of facilities-C-340 Metals The C-612 Northwest Plume Groundwater Plant and C-410 Feed Plant-both of wh;ch System has treated more than 306 million ceased operation in 1977. DOE surveillance gallons of groundwater contaminated with and raaintenance maintains the structures and TCE and "Tc from the start of operations in contains residral contaminants. DOE September 1995 through FY 1998. The encourages opportunities to recover assets or C-614 Northeast Plume Groundwater System reduce costs associated with excess equipment has treated almost 146 million gallons of from the D&D facilities. DOE transferred 20% groundwater contaminated with TCE from of the Duorine celk sad support equipment the start of operatioas in February 1997 pieviously used a the C-410 facility to through FY 1998. manufacture UF feed material and Duorine to another federal agency in a series of seven Issued The Five-Year Review (Type 1) l shipments. The transfer, completed March 24, Paducah Gaseous Diffusion Plant Northwest 1998, resulted in a cost avoidance estimated at Plume Interim Remedial Action Record of l 19 l
Decision (DOE /OR/07-1740 and DI) on Obtained USEPA final signature on + July 9,1998, as required by the ROD for the August 10,1998, and Kentucky concurrence C-612 facility. The review determined that on a ROD to use the Lasagna soil the Northwest Plume groundwater treatment remediation technology as the remedial system is meeting its intended objectives "to action at SWMU 91, a former cylinder drop provide adequate protection of human health test site contaminated with TCE. The and the environment" and recommended technology was demcnstrated successfully at continued operation until a more PGDP in 1995-1997 by DOE and an comprehensive remedial action is in effect. industry consortium involving DuPont, The review also noted that contaminant Monsanto, and General Electric. levels in groundwater have declined significantly downgradient from both ER costs were projected as $24.6 million for extraction well fields. FY 1998, with a proposed budget of $29.2 million for FY 1999. Excavated approximately IC. cubic yards of historical spill site soils contaminated with 7.1.4 Waste Management PCBs at 25 ppm and above (the federal USEPA cleanup level) from WAG 23 DOE is responsible for the characterization, as a CERCLA Removal Action in storage, treatment, and disposal of certain December 1997 and January 1998. After wastes at PGDP. The responsibility includes I excavation, the remaining PCB waste generated before the establishment of concentrations at the nine SWMUs on the USEC on July 1,1993; ongoing generation of plant site that comprise WAG 23 were below wastes from DOE projects; and a limited cleanup levels recommended by the amount of the wastes generated by USEC. By regulators. DOE issued a Draft Post FY 2006, DOE plans to dispose of all legacy Construction / Final Remedial Action Report waste in storage as of FY 1998. DOE defines to the regulators on June 9,1998, with a legacy wastes as RCRA, TSCA, asbestos, request for No Further Action, chromium, arsenic, pentachlorophenol, TCE, low-level radioactive, and transuranic wastes. l Completed fieldwork on the first two + Remedial Invest gations conducted at leased After characterizatic n to assure the facilities still in operation by USEC. appropriate dispositio'.nethod, wastes are sent Fieldwork at WAG 6, the C-400 Chemical for disposal to DOE's C-746-U Solid Waste. Cleaning Facility, was completed in Contained Land 311 on the PGDP reservation or January 1998; the Draft Remedial shipped off-site to nproved DOE or Investigation Report was submitted to the commercial treatment and disposal facilities. regulators on August 14,1998. Historical Wastewater is treated on-site. practices no langer in use at this facility contributed to TCE and "Tc groundwater The USEPA and Kentucky Division of contamination. Fieldwork at WAG 27, the Waste Management are the regulatory agencies C 720 Maintenance Facility, and other areas for PGDP WM. Regulations governing WM w here historical practices contributed to include the following: TCE contamination in groundwater was completed in June 1998; a Draft Remedial RCRA, Part B, Hazardous Waste investigation Report is scheduled for Management Permit; submittal to the regulators in FY 1999. TSCA regulations for PCB wastes; 18 i 20
l DOE Order 5820.2A for Radioactive Waste Minimized the amount of mixed waste Management; and involved in disposition of 809 ash receiver Kentucky solid waste regulations for other vessels removed from the shutdown C-410 wastes. Feed Plant. The project began in 1996 with 809 ash receivers considered to be mixed Agreements related to implementation of waste (both hazardous under RCRA and these regulations include the following: radioactive). Of the 809 vessels,163 were determined to actually contain mixed waste Site Treatment Plan and associated Agreed ash. The other 646 receivers were empty. Order under a Federal Facilities Compliance From June to November of 1997, mixed Agreement (FFCA) for characterization, waste ash was removed from receivers and treatment, and disposal of mixed transferred into 55-gallon drums. The hazardous / radioactive wastes; Project concluded with 809 empty ash receiver vessels classified as low-level Toxicity Charmteristic Leaching Procedure raEactive waste and stated for disposal in (TCLP) FFC/ Tor TCLP characterization fd are years at a lower cost than disposing of under RCRA tt - waste generated prior to W the vessels and contents as mixed waste. September 25, lW, and Twenty-eight (55-gallon equivalent) drums of the mixed wast': ash removed from the Uranium Enrichment TSCA FFCA for use, receivers were shipped to Envirocare of Utah cleanup, storage, treatment, and disposal of for treatment and disposal in May 1998; the PCBs. remaining six drums, which did not meet Waste Acceptance Criteria (WAC) for )o DOE WM acc splishments at PGDP during Envirocare, will be treated under the Site FY 1998 include me following: Treatment Plan schedule. b 0 Treated, shipped, or disposed of more than Reduced operating costs with the 6,600 tons of waste in FY 1998, reducing the downposting of 40,000 square feet of storage " waste storage footprint" at PGDP by 20%. space from contamination zones to The total includes wa te disposed ofin Radioactive Material Areas in the C-746-Q DOE's C-746-U Solid Waste Contained RCRA and C-746-B TSCA Waste Storage Landfill, wastewaRr treated on-site, and Facilities and with closure of the C-746-R off-site shipments to DOE's TSCA Hazardous Waste Solvent Storage Facility. Incinerator at ETTP and other DOE facilities Upon concurrence by the Commonwealth of and to approved commercial disposal Kentucky with the independent Professional facilities. Engineer's report on the C-746-R closure, this will be the fourth RCRA closure at the Made the first two shipments of wastes site. (consisting of 27 containers of mixed waste Passed the annual, unannounced RCRA on April 17 and 56 containers of RCRA mixed waste on August 27) from PGDP to inspection by the Kentucky Division of the Idaho National Engineering and Waste Management in September 1998 with Environmental Laboratory for incineration in no NOVs issued for the fifth consecutive the Laboratory's Waste Experimental year. (Final report for this inspection is Reduction Facility, pending.) 21 L.
Passed every unannounced monthly ORO Type B Investigation and as part of the inspection of the C-746-U Solid Waste Occurrence Report for the September 15, Contained Landfill by the Kentucky Division 1997, C-746-Q drum rupture incident were of Waste Management with all aspects completed by the end ofJune 1998. deemed acceptable and no deficiencies cited since the landfill began operation in lssued a WAC document for DOE treatment, + February 1997. storage, and/or disposal (TSD) facilities in April 1998 entitled Scrap Metal Acceptance Ptepared a draft Environmental Assessment Criteria and Waste Acceptance Criteriafor = (EA) of the potential impacts f rom the Department ofEnergy Treatment, i construction, demonstration, and operation Storage, and Disposal Units at the Paducah of th:: Vortec Corporation Cyclone Melting Gaseous Diffusion Plant, Paducah. j Sy', tem technology. DOE intends to evaluate Kentucky. This document was developed to the capability of the Vortec system for establish (1) criteria that generators must treating the following types of wastes, meet to send waste to the TSD facilities and primarily in contaminated soils currently (2) acceptance criteria for scrap material stored at the plant: low-level radioactive, going to the scrap yards. Requirements for RCRA hazardous, and PCB mixed TSD include proper waste planning; (radioactive, PCB and RCRA-hazardous). characterization; marking; labeling; The Vortec system will use a glass-making containerization; compliance with technology known as vitrification to melt radiological, TSCA, RCRA, and U.S. wastes into a solid product that will meet Department of Transportation (DOT) RCRA Land Disposal Requirements. Based regulations; and certification. The first on the impacts analysis of the EA, DOE will revision of the document was completed either issue a Finding of No Significant during FY 1998 to incorporate Shared Site Impact for the proposed Vortec project or criteria related to USEC. prepare an EnvironmentalImpact Statement, which would further study the project's Obtained approval from USEPA impact to human health and the environment. Headquarters for modifications to the Uranium Enrichment TSCA FFCA. This Treated 36 drums of acidic waste and FFCA regulates PCB management, removal, repackaged 17 acid waste containers in the and disposal at PGDP and PORTS. These C-746-Q RCRA waste storage facility at modifications, which are expected to result PGDP by December 20,1997,just over in an estimated $450 million to $600 million 3 months after the mid-September rupture of cost avoidance, allow the removal of PCB a drum of acidic waste inside the facility. gaskets at both plants and hydraulic systems Within the 100-day time frame, the site at the C-340 Metals Complex at PGDP to be l procured and mobilized a subcontractor for coordinated with the overall j treatment and repackaging and completed decommissioning of the involved facilities. ] most of the cleanup from the incident. Final Completion of removal remains within ten cleanup was completed in February 1998. years ofinitiation date. Successful PCB Development of a risk-based WM strategy, management and removal projects were one of several positive initiatives during provided to USEPA asjustification for the recovery, is expected to improve overall WM modification. at the site in addition to reducing the potential for future incidents. Corrective Applied waste minimization practices actions identified in response to the DOE whenever practical, including recycling of 1 22
approximately 5,562 pounds of white office facilities. This SAR document will be updated paper (thus saving waste disposal cost md annually. The 1997 SAR update concluded that, landfill space); reduction of the generatin of with implementation or continuation of controls steel shot wastes by approximately 96 t,ns identified in the 1995 SAR, the operations in the by using reusable steel shot to blast surfaces nonicased facilities and areas can be concted in the DUF cylinder coating project; and safely with adequate protection provided for reduction of the amount of waste water health and safety of the public and employees as generated in groundwater monitoring by well as protection of the environment. DOE is 2,285 gallons (approximatelv 83%) annually in the p cess of reviewing the 1997 SAR by using the "micropurging" technique. update. WM costs were projected as $16 million for 7.1.7 Environmental Status FY 1998, with a proposed budget of $16.5 million for FY 1999. DOE requires that all its sites conduct and document environmental monitoring and 7.1.5 DOE ?>1aterial Storage Areas surveillance on the basis of DOE Order 5400.1, General Environmental Protection Program. DOE is in the process of documenting and DOE's environmental monitoring at PGDP consolidating waste and unused equipment at a includes groundwater, surface water, sediment, total of 148 locations at PGDP designated as fish, aquatic organisms, deer, and small DOE Material Storage Areas (DMSAs). The mammals. DOE's annual site environmental DMSAs are nonleased facilities that are located report for PGDP documents the inonitoring inside leased buildings and outdoors. DOE and results, which verify compliance with permits USEC established the DMSAs on December 31, and applicable laws. 1996, to facilitate NRC certification of the GDPs. Since that time, work on the DMSAs has During FY 1998, DOE expanded its involved documenting the contents, resolving environmental monitoring of small mammals as environmental problems with the contents such a result of previous findings from a study on as draining and disposing of oils from old PCB levels in " rice rats" during the summer of equipment, and beginning the process of proper 1997. DOE is monitoring raccoons for effects disposal of wastes. During FY 1998, DOE from potential PCB and heavy metal placed priority on documenting the contents of contamination in the areas surrounding the DMSAs located inside leased facilities to plant. Raccoons were chosen because they eat a support USEC's upgrade of seismic wide variety of food items and thus have the reinforcements. potential for contaminant exposure and bioaccumulation. Fieldwork for the racoon 7.1.6 Update of Safety Analysis Report study was conducted from March through August 1998, with a final report scheduled for The PGDP 1997 SAR Update was issued to release in FY 1999. the DOE Site Office and DOE ORO on March 30,1998. This document establishes the Environmental permits for DOE projects authorization basis for operation of nonleased and activities at PGDP include the following: facilities at PGDP. Information in the document was updated from September 30,1995, to September 30,1997. The 1995 SAR covered both leased and nonleased facilities; the updated " Analysis f USEC Inc. leased facilities and SAR is the first edition to focus on nonleased paan ns a cmend in mc app &ation for enewal ofits certification to operate. 23
Kentucky Pollutant Discharge Elimination 7.1.8 Safety and Health Status System (KPDES) permit under the Clean V uter Act, from the Kentucky Division of DOE goals in Safety and 11ealth at PGDP Water, Department for Environmental include (1) zero accidents and (2) limiting Protection The current KPDES permit is exposures to chemicals and radiation to "as low effective April 1,1998, through March 31, as reasonably achievable." The basis of the 2002. Kentucky has issued a separatevermit Safety and Health requirements supporting these to USEC, which previously shared a K PDES goals includes 10 CFR 835 for radiation i permit with DOE. The DOE permit includes protection and the 29 CFR 1910 and 1926 series four KPDES outfall. (1) 001, treated for industrial hygiene and safety. A focus on discharge from the C-612 Northwest Plume safety at work and at home is encouraged by the Groundwater System and the C-616 Safety Team of Paducah (STOP). Members %, treatment lagoon leased to USEC; (2) 015, in STOP is comprised of representatives of surface water runoff from nonleased areas DOE, USEC, and their prime contractors and 'ncluding the C-404 inactive hazardous waste subcontractors. landfill; (3) 017, runoff from the DOE DUF. cylinder storage yards; and (4) 019, runoff DOE and its prime contractors and from the C-746-U Solid Waste Contained subcontractors worked a total of 866,332 hours Landfill. and drove a total of 176,821 miles in government vehicles during FY 1998 with no As required by the KPDES permit, DOE occupational injuries that caused any employee submitted a watershed monitoring plan to the to miss a day of work. However, one Lost Work Commonwealth af Kentucky within 60 days Day Case Restricted occurred for a of the effective date of the permit. This plan subcontractor employee who experienced back provides for m )nitoring of Little Bayou and pain in November 1997 that resulted in some Big Bayou creeks, including fish, temporary work restrictions. The other FY 1998 bioaccumulation, and toxicity monitoring. injuries included two recordable illnesses and Through September 30,1998, DOE met the injuries (RIls). One RII occurred in conditions of the KPDES permit with the December 1997 when a subcontractor cut his exception of three minor exceedances: one knee with a utility knife, and one occurred in pH exceedance at Outfall 017 in April 1998 when a subcontractor pricked his October 1997 and two TCE exceedances at finger with a needle. Also, there was one minor Outfall 011 in March 1998. vehicle damage incident in which a plant security gate damaged a DOE vehicle upon An air permit unde the Clean Air Act, from closing. the Kentucky Division of Air, Department for Environmente.1 Protection, relates The average radiation exposure for the specifically to the DUF, cylinder coating 442 personnel monitored as part of the DOE project operations. All conditions were met radiation protection program during calendar throughout FY 1998 year /CY) 1997 was 5.6 mrem. compared with the 5 '100 mrem occupational exposure limit set by federal law in 10 CFR 835. This compares with annual background radiation exposure levels per person of 200 mrem from naturally occurring radon,40 mrem from food, and 30 mrem from cosmic radiation (according to " DOE.is responsible for an exceedance of TCE at any outfall because it is considered a legacy waste. the National Council on Radiation Protection 24
and Measurements, NCRP Report 94, Exposure Surveillance Program at the DOE GDPs in ofthe Population in the UnitedStates and Paducah, Portsmouth, and Oak Ridge. OCAW Canadafrom Natural Background Radiation). completed Phase I, a needs assessment, during FY 1997 to determine whether it considers any As a result of a chemical explosion in former workers to be at risk for work-related May 1997 at the 11anford Plutonium Finishing health effects from exposures while employed Plant in Washington, DOE Headquarters at the GDPs. In FY 1998, DOE approved directed all DOE facilities to conduct a broad OCAW's application to conduct a medical initiative aimed at preventing similar surveillance of former workers as Phase 11 of the occurrences. The initiative includes scrutinizing study. the use, storage, and prompt disposal of chemicals; reassessing known chemical and 7.1.9 Reportable Occurrences radiological vulnerabilities in shutdown, standby, and deactivated facilities and facilities DOE uses an Occurrence Report system on a that have recently changed their conventional national basis to communicate incidents at its mode of operation; assessing staff technical facilities that need to be shared with all DOE competencies; and assessing site lessons learned sites and evaluated for lessons learned. Copies and occurrence reporting programs. In its of final Occurrence Reports are made available responses to the lleadquarters initiative, PGDP at DOE reading rooms and information centers. identified no new vulnerabilities and verified Appendix B.1 summarizes the reportable that corrective or mitigating actions are in place occurrences at PGDP for FY 1998. During for the known chemical and radiological FY 1998, a total of 20 Occurrence Reports were vulnerabilities related to long-term storage of filed at PGDP. Nineteen were classified as "off-legacy wastes. A DOE ORO team visited PGDP normal" occurrences. Off-normal occurrences in March 1998 to validate the site's response to are defined as abnormal or unplanned events or the initiatives of Energy Secretary PeSa conditions that adversely affect or indicate regarding these chemical and radiological problems in the safety, security, ES&H vulnerabilities. protection, or operation of a facility. The remaining report was classified as an " unusual" The Agency for Toxic Substances and occurrence, which is defined as a situation that, Disease Registry (ATSDR), based in Atlanta, although worse than off-normal events, is not an Georgia, continued preparation of a Public emergency. None of the occurrences resulted in Health Assessment on PGDP during FY 1998. harm to people or the environment. However, The assessment is required by federal law corrective actions were taken on each incident because PGDP is on the NPL for environmental to prevent recurrences of similar or more serious cleanup. ATSDR, which has sent events. Also, lessons learned were identified representatives to DOE public briefings and and communicated across the DOE complex to workshops to stay informed on site activities help ensure that PGDP and other DOE sites and stakeholder interests and concerns, plans to avoid similar problems. issue its assessment :n FY 1999. Occurrences also are assessed to determine DOE Headquarters awarded a grant to the whether they are potential violations of PA AA. Oil, Chemical, and Atomic Workers PAAA provides DOE with the authority to International Union (OCAW) based in assess civil and criminal penalties for violation Lakewood, Colorado, as required by the of DOE nuclear safety rules, regulations, or National Defense Reauthorization Act for 1993, orders. During FY 1998, one FY 1997 and two to conduct a Former Worker Medical FY 1998 occurrences at PGDP were reported as 25
potential PAAA violations. The Senior Review security fencing, Board of DOE's prime contractor determined holding ponds' a that the September 1997 rupture of a drum of nitric acid waste inside the C-746-Q RCRA warehouses (active and inactive), five groundwater treatment facilities, Waste Storage Facility was a potentially significant PAAA violation to be tracked RCRA Part B-permitted Hazardous Waste through DOE's Noncompliance Tracking Storage Facility, System (NTS). DOE Headquarters determined DUF. cylinder storage yards, that no enforcement action or penalty would be
SWMUs, assessed because of the thorougimess of administrative facilities, PGDP's response and recovery and completion of the DOE Oak Ridge Operations Type B facilities leased by DOE to the Ohio Army investigation and associated corrective actions.
National Guard, and One FY 1998 occurrence (see item 10, inactive process facilities. Appendix B.1) also was reported as a potentially significant PAAA noncompliance to be tracked USEC leases, and is responsible for, most of through NTS. The contractor's Senior Review the grounds within Perimeter Road as well as all Board determined another FY 1998 occurrence roads and railroads. DOE retains, and is (see Item 13, Appendix B.1) to be a minor responsible for, most of the grounds on the PAAA noncompliance to be tracked and trended exterior of Perimeter Road. DOE is also internally. responsible for limited property adjacent to its primary facilities inside Perimeter Road. 7.2 ENVIRONMENT, SAFETY, AND 7.2.2 Depleted Uranium Hexafluoride HEALTH STATUS OF NONLEASED Management AREAS AT PORTSMOUTH The DOE EF Program is responsible for During FY 1998, the DOE EM and EF management of DUF. generated at PORTS from Programs at PORTS have continued to make the start of enriched uranium production in 1954 good progress toward completing ER work by until the creation of USEC on July 1,1993. The the end of FY 2001 and WM activities by the DOE DUF cylinder storage yards are some of end of FY 2006 and continuing the EF mission the more important nonleased areas from an at PORTS which includes management of ES&H perspective. DOE stores more than DUF., HEU program management, safeguards 15,000 cylinders, including approximately and security, and maintenance of nonleased 13,400 full DUF cylinders." The remaining buildings and grounds. cylinders include cylinders with residual materials and empty cylinders. 7.2.1 Facilities and Acreage In response to DNFSB concerns about DOE owns the 3,714-acre federal reservation cylinder corrosion, DOE embarked on a project at PORTS and leases the uranium enrichment to repaint the skirted ends of the older cylinders, facilities to USEC. DOE leases 274 of the 357 including full DUF cylinders and those that facilities and systems at PORTS to USEC and contain residual quantities. This project was retains 83 as nonleased facilities and systems. completed in FY 1998. The cleaning of l These nonleased facilities and systems include j-portals (vehicular and pedestrian), usee rootnote i4. 26
500 skirts was completed in December 1997 At areas of contamination on the plant site. Two the end of FY 1998, a total of 7,100 skirted consent orders signed in 1989, one between cylinder ends had been painted over a three-year DOE and the State of Ohio and the other signed period. by DOE and the USEPA, provide the regulatory frsmework for remedial actions. The By the end of FY 1998, all DOE-owned Administrative Order by Consent with the cylinders had been moved and restacked, with USEPA was amended in August 1997 to include the exception of 2,639 full DUF. cylinders that the Ohio EPA as a party to the agreement and to were transferred to DOE when USEC was delegate day-to-day oversight to the state privatized. These cylinders will be restacked in agency. The cleanup program is being FY 1999. A total of 15,249 full DUF and other conducted in compliance with RCRA and cylinders have been restacked to facilitate visual applicable aspects of CERCLA. PORTS is not inspections of the cylinders at PORTS. PORTS an NPL site. conducted annual radiological surveys on 14,000 cylinders in FY 1998 and performed The site was divided into four sections, or ultrasonic wall thickness measurements on quadrants, for investigation and remedial action. 150 DOE-managed cylinders that were planned Under RCRA, the cleanup at PORTS follows a for measurement in this FY. Cylinders are three-phased approach: RCRA Facility visually inspected either annually or Investigations, Corrective Measures Studies, quadrennially. PORTS completed annual and Corrective Measures Implementation. inspections on 502 cylinders in November 1997 Since 1990, all four quadrants have been and quadrennial inspections on 3,725 cylinders investigated, and PORTS is now completing the in FY 1998. last two phases ofcleanup. As of FY 1998, a total of 450 soil borings have been taken and DOE's Office of Nuclear Energy, Science sampled, and more than 600 groundwater and Technology is finalizing a PElS to monitoring wells across the federal reservation determine a recommended altemative for have been installed and sampled, thus providing dispositioning the inventory of DUF. in storage information on the extent of contamination that at PORTS, PGDP, and ETTP. Several meetings resulted from the more than 40 years of plant have been held with the public and industry operations. These investigative studies show representatives on this program, including a that there are five groundwater plumes, all public meeting at PORTS on February 26,1998, located within the plant boundaries. The main and an industry meeting in Cincinne.ti, Ohio, on contaminant in these plumes is the chemical June 29,1998. The final PEIS is expected to be solvent TCE that was used for many years to issued by the end of CY 1998 with a ROD to be degrease industrial equipment at PORTS. TCE issued in early CY 1999. has since been replaced with a more environmentally friendly water-based solvent. EF activities at PORTS were projected to cost $29.7 million in FY 1998. The proposed As of FY 1998, PORTS has identified budget for FY 1999 is $33.1 million. 156 release sites. Contaminants include volatile organic compounds (VOCs), uranium, "Tc, and 7.2.3 Environmental Restoration PCBs. Several of the sites are being deferred for cleanup until final D&D of the plant sa as The PORTS ER Program has made not to interfere with current plant operations or extensive progress in recent years to remediate to avoid recontaminating an area while the plant continues to operate. 27
More than 30 cleanup projects have been recirculation of an oxidant solution through completed through FY 1998 at PORTS, multiple horizontal and vertical wells was including remediating lagoons, closing landfills, conducted at PORTS. The new ISCOR pilot constructing Ove groundwater treatment project will incorporate lessons learned from the facilities, consolidating and closing waste previous test and other related laboratory and storage facilities, and conducting soil field data. Field activities for this project began remediations. Three pilot projects were the Orst week in July 1998 and are scheduled to approved by the Ohio EPA. These projects, be completed by early CY 1999. initiated in FY 1998, are being conducted to evaluate different treatment technologies for A third pilot project will test the applicability at PORTS and to remove the effectiveness of a vacuum-enhanced recovery source of groundwater contamination. Data method in extracting contaminants from from the pilot projects will be reviewed by the groundwater and saturated soils at the south end Ohio EPA as it is available. A report will be of the plant property. The primary contaminant issued following the completion of each pilot is TCE. During this project, approximately five ~ project. In addition, the data will be vacuum vapor and groundwater extraction wells incorporated into the Corrective Measures Study were installed in stages at various locations to documents for Quadrants I and 11. determine (1) the ability of the technology to remove water and generate vapor How through One of the pilot projects will implement a tight clay soils,(2) the well spacing needed for process called dynamic underground steam optimal dewatering in a full-scale project, and, stripping to extract subsurface VOCs in an area (3) the vertical distribution of contamination. of groundwater contamination on the east side The objectives of the pilot project are to provide of the plant. The process rapidly accelerates design parameters for full implementation of the VOC removal by injecting steam below the technology at PORTS and to achieve surface through multiple wells, thus raising the contaminant mass removal in the groundwater temperature of the contaminated area to above plume. Field activities began in mid-the contaminants' boiling point. This heating August 1998 and were completed in early vaporizes the VOCs and drives them to centrally October 1998; a final report of results is located vacuum extraction wells. By using a expected to be issued in November 1998. Data process called hydrous pyrolysis oxidation in collected from the project will be used along conjunction with the steam stripping, with existing site data to select a remedial contaminants not removed by the extraction alternative for final remediation of the wells can be destroyed in place by oxidation groundwater plume. m without further treatment. Field activities began in July 1998, and the pilot project is to be Each of these projects has been selected to completed by early CY 1999, provide essential technical information that will be used to expedite remedial action decisions Another project will test an in situ chemical for treatment of the four primary groundwater oxidation and recirculation (ISCOR) process. plumes that'are located within plant boundaries. The project involves recirculation of Data collected from these demonstrations will groundwater using four pumping wells located also be provided to other DOE sites. at fixed distances from a central injection well. The extracted groundwater is dosed with an In other actions during FY 1998, the oxidant and is reinjected to the subsurface to Quadrant I draft final Cleanup Alternatives r degrade DNAPL compounds. During 1996, an Study / Corrective Measures Study (CAS/ CMS) initial treatability study involving injection and report was submitted to the Ohio EPA on 28 a b
December 31,1997. Comments from the Two major construction projects were agency were received and answered. Final completed this Oscal year. Capping of the Peter submission of the report will be withheld until Kiewit Land 611 and the X-735 Industrial Solid the data from the pilot projects are received. Per Waste Land 611 were both completed in agreement with the Ohio EPA, the Quadrant 11 September 1998, ahead of schedule and under CAS/ CMS report is being combined with a budget. The X-735 Industrial Solid Waste report for another unit, the X-701 B CAS/ CMS Landfill closure was the first design / build report. This report, which is to include data project at PORTS and resulted in a $2.3 million from the pilot projects, is expected to be cost savings. submitted during second quarter 1999. The Ohio EPA approved the Quadrant Ill CAS/ CMS ER activities at PORTS were projected to report on July 13,1998. This was the Erst cost $23.6 million in FY 1998. For FY 1999, quadrant-wide CAS/ CMS report to be approved the proposed budget is $23.4 million. for PORTS. The Quadrant IV CAS/ CMS report was submitted to the Ohio EPA on April 3, 7.2.4 Waste Management ~ 1998, and the final report was submitted on August 21,1998. The mission of the PORTS WM program is to treat, store, and dispose of all legacy The installation of a collection trench was environmental management waste in compliance completed in October 1997 as an interim action with applicable federal, state, and local ES&H to collect and treat seeps detected in a ditch line regulations in a manner that protects the health south of the Peter Kiewit Land 611. Four wells and safety of the public, the work force, and the were installed downgradient of the interim environment. PORTS has implemented ongoing action collection system in January 1998 to recycling programs to focus on paper products, monitor the effectiveness of the collection aluminum cans, and scrap metal. system as required by the Ohio EPA. Baseline monitoring was conducted on January 23,1998. PORTS has also implemented many The collection trench became operational in noteworthy pollution prevention initiatives, and February 1998. several of the DOE environmental cleanup activities have resulted in off-site shipment of Several special sampling events occurred signincant quantities of waste and recycling of during FY 1998. Samples were collected at Eve materials. In particular, the following activities areas (X-740, X-749, 5-Unit, 7-Unit, and were completed in FY 1998: X-701B) to assist in determining whether natural attenuation was occurring in the disposal of 835 tons of soils from a groundwater plumes. The results of this remediation project, sampling event will be detailed in the disposal of 70 tons of micro 61tration sludge, appropriate CAS/ CMS report. Sampling was also conducted along old process dram lines that disposal of 310 tons of X-6619 sewage have been abandoned or plugged and capped. treatment sludge, disposal of 2 tons of crushed fluorescent This sampling event will be reported in the a Quadrant 11 CAS/ CMS report. In addition, light bulbs, sampling was conducted this Oscal year along disposal of 8 tons of oil and grease removal a on-site drainage ditches for TCE and unit sludge, radionuclides and will be completed by the end recycle of 654 tons of scrap metal, of CY 1998. recycle of I ton of fluorescent light bulbs, 29
recycle of 2.8 tons oflead bullets, tracked using the PORTS waste tracking data recycle of 6.4 tons of brass casings base. treatment of 0.4 ton of motor clean ng 7.2.6 Update of Safety Analysis Report
solution, treatment of 54 tons of RCRAffSCA waste The PORTS 1997 SAR Update was issued at the ETTP TSCA Incinerator, and for approval to the DOE Site Office and DOE treatment of 69.5 tons of wastewater through ORO on March 30,1998. This document on-site wastewater treatment facilities.
establishes the authorization basis for operation of nonleased facilities at PORTS. This first On July 8,1998, DOE and its prime revision of the SAR incorporates resolution of contractor received an NOV from the Ohio DOE's SER comments relating to the EPA. The violation involved a 90-day September 30,1995, version of the S AR. hazardous waste accumulation area. Improper Although the 1995 SAR covered both leased closure and failure to rnaintain adequate and nonleased facilities, the updated 1997 SAR, inspection records were cited as grounds for the at the direction of DOE, focuses on nonleased violation. The violation was abated on facilities. The 1997 SAR update concluded that, August 19,1998. with implementation or continuation of controls ) identified in the 1995 SAR, operations in The projected budget for WM activities at nonleased facilities and areas can be conducted PORTS was $22.5 million for FY 1998. For safely with adequate protection provided for FY 1999, the proposed budget is $22.3 million. health and safety of the public and employees as well as protection of the environment. DOE is 7.2.5 DOE Material Storage Areas in the process of reviewing the 1997 SAR update.'8 On December 31,1996, DOE and USEC entered into two MOAS, one at each GDP, 7.2.7 Environmental Status delineating the responsibilities of DOE and USEC regarding DMSAs. Under the Lease, DOE requires that all its sites conduct and DOE had retained the option to leave certain document environmental monitoring and materials in the leased space. DOE and USEC surveillance on the basis of DOE Order 5400.I, agreed that DMSAs would be established in General Environmental Protection Program. response to NRC's request indicating that such a DOE's environmental monitoring program at change would facilitate certification of the PORTS includes groundwater and surface GDPs. These DMSAs, although located in water. Approximately 100 monitoring wells are space formerly leased to USEC, are now located sampled routinely to maintain compliance, in space retained by DOE and are under the monitor the effectiveness of corrective actions. regulatory oversight of DOE. USEC and DOE and track the movement of groundwater plumes. identified the areas to be established and, under DOE's annual site environmental report for the MOA, established 44 DMSAs at PORTS. PORTS documents the results, which verify The DMSAs are located both inside of USEC-compliance with permits and applicable laws. leased buildings and within certain USEC-leased outdoor areas. The DMSAs contain various types and pieces of operating equipment as well as PCB wastes. Since December 31, 1996, DOE has inventoried the non-PCB DMSAs. Inventories for PCB DMSAs are "see footnote 15. 30
Environmental permits for DOE projects 7.2.8 Safety and IIcalth Status and activities at PORTS that do or could potentially require monitoring include The average radiation exposure for DOE's prime contractor and subcontractor employees National Pollutant Discharge Elimination at PORTS was 1.65 mrem / year, with a System (NPDES) permit under the Clean 144 personnel monitored in CY 1997. No Water Act from the Ohio EPA. The current trending was performed because doses have NPDES permit, which includes six outfalls, varied little over the last 5 years and have is effective September 1,1995, through consistently averaged well below March 31,1999. Outfalls 012,013, and 015 100 mrem / year. For comparison purposes, refer are point source discharges to waters of the to the discussion of radiation exposure for state. The efDuent from Outfalls 608,610. PGDP in Section 7.1.8. and 611 are treated by the X-6619 wastewater treatment facility. This facility During the period from October 1,1997, is leased by USEC and monitored through through September 30,1998, the DOE prime USEC Outfall 003 before reaching waters of contractors at PORTS had no Riis or Lost the state. There were no exceedances during Workday Cases (LWCs). Subcontractors FY 1998. The regulatory limits for experienced eight Riis, including Ove LWCs. environmental releases related to DOE activities at PORTS have not changed since 7.2.9 Reportable Occurrences last year." From October 1,1997, through Air permits under the Clean Air Act from the September 30,1998,19 incidents occurred in Ohio EPA. As of September 30,1998, DOE the nonleased areas at PORTS that were holds 10 air permits at PORTS,8 of which sufficiently serious to be classified as reportable are under appeal with Ohio's Enviroamental ES&H occurrences by DOE. Seventeen Board of Review. During FY 1998, one air incidents were classified as "off-normal." The permit was transferred to USEC, one air remaining two incidents were classified as permit was not renewed because the project " unusual." Eleven of the reportable occurrences for which it was issued was completed. and involve violations of NCS procedures or three permits were canceled due to the indicate NCS programmatic denciencies. None closure of the X-735 Industrial Solid Waste of these occurrences resulted in a criticality. Landfill, certi6ed September 15,1998. Because actual emissions are at levels that in April 1998, in view of these occurrences, cannot be detected by instruments, the DOE conducted an independent audit of the emissions are modeled rather than NCS Program for the nonleased facil; ties at monitored. No violations of air permit limits PORTS. This audit of the effectiveness of the occurred during FY 1998. NCS Program indicated that Dowdown of NCS requirements into procedures, use of procedures in operator training and work, and the condition of one fissile material storage area (DMSA-1)
For a description of the regulatory limits for needed improvement. At the same time, the environmental releases, the reader is referred to the report audit determmed that the other fissile material entitled Department ofEnergy Input to the Nuclear storage areas were in very good shape and that
.\\'egulatory Commission 's A nnual Report to Congress the nowdown of NCS requirements into safety Regarding the Status ofHealth. Safety, and Ennronmental Conditions at the Paducah and Portsmouth Gaseous basis documents was eflective. Eight findings Diffusion Plants. DOE /ORO'2059, dated October 1997. and thirteen observations from th.is audit 31
i l l required corrective action responses and summarizes the reportable occurrences at tracking to closure. PORTS for FY 1998. l l In June 1998, in response to DNFSB I Recommendation 97-2, DOE Field Managers at
8. COMPLIANCE WITil sites with significant quantities of fissile APPLICABLE LAWS materials conducted a self-assessment survey, using criteria consistent with the principles of During FY 1998, PAAA violations were l
Integrated Safety Management, to determine reported at PGDP, as discussed in Section 7.1.9 l that li..e management is functioning properly and Appendix B.1. Some environmental l with respect to NCS. DOE established violations, discussed in Sections 7.1.7 and 7.2.4 l 11 review criteria by which tojudge the were also identified at PGDP and PORTS. effectiveness of the NCS rrograms. Although Incidents occurred at both GDPs involving the previous independent nudh r. PORTS violations of DOT regulations, and one incident identified several findings and observations that occurred at PORTS involving a violation of an required aggressive follow-up tracking and OSHA regulation. These incidents are corrective actions, input from the independent described in Appendix B. In all these instances. audit to this survey determined that the NCS actions were taken to notify appropriate Program for the nonleased facilities at PORTS authorities, identify the cause of the violation, l is in place and effectively implemented to and institute corrective measures. provide safe nuclear operations. Appendix B.2 t l l [ l l l l l l i 32
p ? r APPENDICES l l l I l i l l l C 1 h i J 33 I L
A.
SUMMARY
OF DOE REGULATORY OVERSIGIIT PROGRAM INSPECTION REPORTS l l A-1 1
l l Summary of DOE Regulatory Oversight Program Inspection Reports l Inspection l Report No. Areas Examined Results 70-7002/97-072 Sixteen 11EU refeed-related problem No violations of the Nuclear Safety and i reports, one open item (Uranium Deposit Safeguards and Security requirements of the i Monitoring), five functional areas ROA or deviations from commitments made l (Managerial Controls and Oversight, to DOE were identified. An inspection Operations, Nuclear Criticality Safety. Follow-up Item (70-7002/97-07-01) was p Emergency Preparedness, and Security), established regarding facility emergency I and one functional appraisal (Quality packets for the X-326 Process Building and Assurance). the X-705 Decontamination Facility. An g Unresolved item (70-7002/97-04-05) l " Uranium Deposit Monitoring in the X-326 l Process Building" was closed. 70-7002/97-08" One llEU refeed related event report, Two activities were identified as being in thirteen lieu refeed related problem violation of Nuclear Safety and Safeguards reports, two open items, and three and Security requirements of the ROA. A functional areas (Managerial Controls and Notice of Violation (70-7002/97-08-01) was Oversight, Operations, Nuclear Criticality issued with regard to one of the two violations Safety). of NCS administrative spacing requirements; the second violation was considered to be a additional example of a previously cited violation (70-7002/97-06-02). An unresolved l item (70-7002/97-08-02) was established to track closure of corrective actions. Two open items were closed: Violation l 70-7002/97-05-01. " Operational Safety Requirement [OSR] Violation - 11 eating of lieu Refeed Cylinders" and Inspector l Follow-up Item, 70-7002/97-06-01, " Shift Turnover at X-326." I l l [ l l i I G 2 includes inspections conducted in September and October 1997. " Includes inspections conducted in November and December 1997, d A-3
l-l^ \\ l-1 Summary of DOE Regulatory Oversight Program Inspection Reports (cont.) Inspection Report No. Areas Examined Results 70-7002/98-0122 One HEU refeed related event report, No violations of the Nuclear Safety and twenty-six HEU refeed related problem Safeguards and Security requirements of the reports, and six functional areas ROA or deviations from commitments made (Managerial Controls and Oversight; to DOE were identified. Three unresolved Operations, Engineering Reviews; items were identified. The first Radiation Protection Prograias, Systems, (70-7002/98-01-01) involved Nuclear Designs, and Permits; Nuclear Criticality Criticality Safety Approvals (NCSAs) for the Safety; and Security). HASA Vault, the second (70-7002/98-01-02) involved controls used during the NDA measurement of HEU rciced cylinders, and the third (70-7002/98-bl-03) involved the completion of a procedure under development for the use of a volumetric test cart for IAEA monitoring activities. 70-7002/98-022' One HEU refeed related event report, No violations of the Nuclear Safety and twenty-two HEU refeed related problem Safeguards and Security requirements of the reports, and five functional areas ROA or deviations from commitments made (Managerial Controls and Oversight; to DOE were identified. An Unresolved item Operations; Radiation Protection (70-7002/98-02-01) was established regarding Programs, Systems, Designs, and Permits; discovery of free liquid in a container in the Nuclear Criticality Safety; and Security). X-326 HASA Vault. Three open items were closed: Violation 70-7002/97-06-02," Pigtail Storage at the Product Withdrawal [PW] - Station," Violation 70-7002/97-08-01, " Storage of an 8-inch HEU Cylinder near the HASA Vault Sampling Manifold," and Unresolved item 70-7002/97-08-02,"F-Can and Refeed Position #1 Spacing Interference at the Product Withdrawal Station." i I 221ncludes inspections conducted in January and February 1998. 2' Includes inspections conducted in March and Apcil 1998. j t A-4 1
.__._.~-.m Summary of DOE Regulatory Oversight Program Inspection Reports (cont.) Inspection Report No. Areas Examined Results i 70-7002/98-0324 One HEU refeed related problem report One activity was identified as being in and five functional areas (Managerial violation of Nuclear Safety and Safeguards Controls and Oversight; Operations; and Security requirements of the ROA. A Radiation Protection Programs, Systems, Notice of Violation (70-7002/98-03-02) was Designs, and Permits; Nuclear Criticality issued with regard to a violation of Nuclear p Safety; and Security). Criticality Safety requirements. Seven l Inspector Follow-up items were established, j All Inspector Follow-Up ltems were identified y during a special NCS inspection. Two open l items were closed: Unresolved item 70-l 7002/98-01-02," Enrichment Measurements ofIIEU Refeed Cylinders in Product Withdrawal (PW) Area" and Inspector Follow-Up Item 70-7002/98-01-03, " Operation of the Volumetric Test Cart." 25 70-7002/98-04 Twelve HEU related problem reports and No violations of the Nuclear Safety and five functional areas (Managerial Safeguards and Security requirements of the j Controls and Oversight; Operations; ROA or deviations from commitments to Radiation Protection Programs, Systems, DOE were identified. Two inspector Follow-i Designs, and Permits; Nuclear Criticality Up items were established. Two open items Safety; and Security). were closed: Inspector Follow-Up item 70-7002/97-04-03," Cylinder at PW With Broken Valve Stem" and Unresolved item 70-7002/98-02-01," Liquids in Dry Active Waste (DAW)." { l I I l l I 2* Includes inspections conducted in May and June 1998. 1 251ncludes inspections conducted in July and August 1998-A-5 s i
s 4 l B.
SUMMARY
OF REPORTABLE OCCURRENCES IN NONLEASED AREAS AT TIIE GASEOUS DIFFUSION PLANTS f l B-1
l. PADUCAH GASEOUS DIFFUSION PLANT

1. Drum Spill During Intraplant Transfer Operations. On Octaber 7, l997,1 l of 12 overpacked drums containing uranium tetrafleoride waste and rust fell off a truck bed on the plant site during transport between two waste storage facilities. Less than i quart of condensate liquid leaked onto the roadway. The spill area was decontaminated. A second and similar event included in the Occurrence Report involved a 5-gallon overpacked drum of PCB/ RCRA laboratory waste that dropped off a forklift during transport to a waste storage facility on October 3,1997. Although the outer drum was osmaged, the inner drum did not leak. The corrective action included revision of the applicable procedure to require overstrapping of full waste containers and securing single waste containers onto pallets or using an approved containment device during transport.

2. PCB Waste Storedin DMSA Without Proper Authori:ation. On October 29,1997. PCB wastes were inadvertently placed in a DMSA without DOE authorization. Such action was not in compliance
{ with DOE /USEC agreements. No environmental violations resulted, however, as the DMSA was a PCB storage area in compliance with requirements. On December 9.1997, a similar violation was discovered. Sometime during November / December 1997, two 55-gallon drums of new motor oil and a containment pan,were placed in another DMSA, also without written authorization. The PCB waste, oil drums, and pan were removed from the DMSAs to proper storage. The corrective action to prevent recurrences consisted of the USEC prime contractor's reemphasizing to employees the need to carefully read postings each time before entering an area in order to distinguish LMSAs.
3. PersonnelSkin Contamination Above Reportable Limits. On December 14,1997, radiological skin contamination above 10 CFR 835 limits was detected on a subcontractor who was monitoring out of the waste treatment and cleanup task at the C-746-Q RCRA Waste Storage Facility. A slight contamination, below reporting criteria, also was detected on skin and/or personnel protective clothing of four other subcontractor employees. After the skin areas v;cre cleaned, monitoring did not detect any remaining contamination. Corrective actions to prevent recurrences include more direct involvement of health physics technicians and a reduction in the amount of time spent inside the treatment work area.

4. PersonnelSkin Contamination Above Reportable Limits. On January 6. I998, radiological skin contamination above 10 CFR 835 limits was detected on a subcontractor who was monitoring out of the C-746-R RCRA Waste Storage Facility. The subcontractor was outfitted in personnel protective clothing appropriate for typically cold winter weather. However, unseasonably warm weather l
caused him to perspire, thus leading to contamination soaking through to the skin on his stomach. l The corrective actions to prevent recurrences include modifying the protective clothing for the ( particular task and increasing awareness of the requirements included in the procedure to modify personnel protective equipment (PPE) under changing conditions such as weather. I 5. Vehicle WheelLug Nuts Loose or Missing. On March 18,1998, a contractor employee noticed a i wheel vibration on a DOE pickup truck. Upon inspection, two of six lug nuts on one wheel were missing (the studs were missing or damaged) and the remaining four lug nuts were only finger tight. i Although the exact cause was not confirmed, a precautionary corrective action was initiated that consisted ofinspecting tires that had been changed in the past 6 months on all DOE vehicles at I B-3 i 4
PGDP, beginning a monthly inspection utilizing a checklist, and Olling out a checklist each time maintenance is performed. Both checklists specifically include verifying tightness oflug nuts. 6. Windstorm Destruction ofPortable Carport. On March 26, I998, a sudden gust of wind transported a portable carport approximately 300 yards from its original anchored position in the C-745-F UF. cylinder storage yard. The carport, used for occasional cylinder repair work, was demolished, and the tops of three cylinders apparently were scraped by the carport as it sailed overhead. No major damage resulted to the cylinders or any other property or facility. A walkdown of other areas in the cylinder yards showed that everything was in good condition and weighted down appropriately. The corrective acticn involved revis;ng the applicable procedure to ensure all portable structures in the cylinder yards are secured against wind damage. The incident was considered a "near miss" because of the potential for injury to people or more serious damage to the I cylinders. Because of the infrequent use of the carport, it was not replaced.
7. ImproperlyIdentifiedShipping Documentation. On April 9,1998, it was discovered that a set of Ove soil samples shipped April 8,1998, from PGDP to ETTP had incomplete shipping documentation. Although the subcontractor had properly documented and labeled the shipment for the primary potential hazard associated with hexane in the soil samples, the shipment lacked the documentation and labeling required by DOT for the hydrochloric acid that was used to preserve three small cials of water included in the shipment. No environmental, health, or safety problems resulted. A corrective action was instituted to add an inspection checklist to help ensure proper labeling of dangerous goods and hazardous materials prior to shipment in accordance with DOT regulations. Another corrective action involved training personnel associated with the off-site shipment of samples regarding DOT Hazardous Materials Regulations.

8. Overpressurized Waste Polyethylene Bottle. On April 17,1998, the inner container (a 5-gallon polyethylene bottle containing corrosive laboratory liquid waste) of a 5-gallon steel drum was found to be pressurized in the C-752-A RCRA Waste Storage Facility. The drum was vented under supervision of the Plant Shift Superintendent (PSS) with no spill of contents. DOE har applied to the Kentucky Division of Waste Management for approval of a modification to the RCRA Part B l
Permit so that drums containing corrosive laboratory waste liquids can be neutralized to eliminate l the potential to pressurize. Pending treatment, the site will continue to inspect and vent the drums as necessary.
9. DOTHazardaus Materials Noncompliance. On May 8, lW several minor DOT noncompliances were identified on paperwork and container markings for 1rch and April 1998. A subcontractor, providing shipment service to DOE's prime contractor under a work authorization, had prepared the shipments. No environmental or safety problems resulted. Written guidance was provided to help ensure accurate interpretation of detailed and complex DOT regulations. Subsequent assessments found that DOT requirancut: were being interpreted correctly.
l
10. Contamination Det, ted During Sample Equipment Transfer. On May 12,1998, adiological contamination was de ected on the shoes and work clothing of nine employees at the C-746-Q RCRA Waste Storage "acility, which is designated as a radiological material area. The incident was caused during movement of a plastic bag containing sampling equipment contaminated with a residue of *Tc waste. Because of a breach in the plastic bag, a small amoun* of the waste leaked and was inadvertently spread as the employees worked in the area. Corrective actions included 1
B-4
conducting awareness sessions, modifying training, and making administrative changes, all of w hich emphasized the higher potential for spread of"Tc contamination because of the unique radiological and chemical properties of"Tc.
11. RadiologicalSkin Contamination. On May 28,1998, a worker's skin became contaminated during j
sampling of magnesium fluoride pellets, one of PGDP's higher risk waste streams, as it is both potentially fissile and RCRA hazardous for metals. Workers were sampling the pellets while wearing air line respirators and double anticontamination clothing; however, the worker's ear became contaminated during doffing of the protective clothing. The contamination was removed. The preliminary evaluation indicated that proper procedures were used. A corrective action included modifying the PPE configuration to require the issuance of company coveralls and a double layer of disposable coveralls rather than the issuance of company coveralls, disposable coveralls, disposable apron, and disposable sleeves. l 2. Underground Water Supplyfor C-746-A Penetrated During Subsurface Soil Samplingfor UndergroundStorage Tank (UST) Investigation. On June 30,1998, a 1-inch copper low-pressure line supplying sanitary water to the C-746-A RCRA Waste Storage Facility was penetrated when a borehole was drilled as part of an ER UST investigation. The line was repaired, and the area was reseeded. The water line was not shown on the utility drawings; however, it was noted on other drawings as part of the excavation permit. The incident was considered a near-miss due to the potential for impact to other utility lines, although none were in the immediate vicinity. Corrective actions included revising the excavation / penetration permit procedure in order to prevent a recurrence of a similar situation. 13, Baseline Bioassay Sample Not Submitted by Subcontractor. On 3uly 10, l998, DOE's prime contractor confirmed that one subcontractor employee did not obtain a baseline bioassay (urine) sample as required at the start of a field sampling task for the WAG 22 ER investigation. A bioassay sample was submitted at the end of the task. Corrective actions included more formal tracking to assure that bioassay requirements are met prior to commencement of tasks.
14. Forkhft Overturned. On July 20,1998, a forklift overturned onto its side while the operator was moving a stack of wooden pallets outside the C-746-A and B waste storage facilities. A brake locked when the operator was backing the vehicle, causing the forklift to skid, slide down into a shallow ditch, and turn over. The driver was not injured; he was wearing his seatbelt. The incident t
was classified as a near-miss because the potential existed for injury. Corrective utions included a safety briefing for all heavy equipment operators that addressed (1) the forklift incident, (2) general safe driving habits, (3) the requirement to perform and document pre-operational checks, and (4) awareness of hazards in areas where work is being performed. l
15. Possible Pandalism ofAir Compressors. On August 6,1998, eight of sixteen bolts were found to be i
loosened on the hose connections on air compressors used in the UF cylinder blasting and coating l task. The situation was discovered by a subcontractor employee who started the equipment and promptly shut it off upon hearing hissing noises and air leaks. The incident was classified as a near-miss because of the potential for injury resulting from a loosened hose connection. An investigation of the incident is ongoing. 1 B-5 4
16. Mower Accident. On August 24,1998, an employee of USEC's prime contractor was making a turn on a riding mower adjacent to a ditch near the C-404 inactive landfill. When the left tire of the mower started to slide into the ditch, the employee immediately engaged the brakes. However, his foot slipped off the right brake, and the mower flipped over in the ditch. The employee was wearing his seatbelt and the mower had roll-over protection. There was no injury to the employee. An investigation of the incident is underway.

17. Forkhft li'cight Limit Exceedance. On September 13,1998, DOE's prime contractor learned that two waste containers had been moved in violation of procedures regarding weight limits for a forklift. During the movement, which occurred on September 2, two waste container metal boxes slid off a forklift when the vehicle tipped forward on a metal ramp. The containers fell to the floor, damaging the lids and breaking the seals. No material was released. The work was being performed by USEC's prime contractor for DOE's prime contractor under a work authorization. An investigation is underway.
I8. Radiological Contamination ofPersonnel. On September 25,1998, a visitor to the inactive C-340 Metals Reduction Facility, which was under surveillance and maintenance in the D&D Program, accidentally brushed the top of his head against a piece of piping, contaminating his hair. The contamination was subsequently removed. All procedures for visiting the facility had been followed.
19. Labeling Error en Sample Shipment. On September 29,1998, a labeling error was discovered on a shipment of waste samples from PGDP to a commercial laboratory. No violations of DOT or NRC regulations occurred. However, a different type of packaging might have been chosen had the subcontractor preparing the shipment known that the samples should have been classified as sodium fluoride trap mix rather than alumina trap mix. A review of protocol for transmission of sample information is planned by a team that includes DOE's prime contractor and subcontractors.

20. Arrival of Breached PGDP Low Level IF'aste Container at Hanford. On September 30, l998, DOE's prime contractor learned that one of 40 waste containers shipped from PGDP to the DOE Hanford, Washington, site arrived with corrosion on the bottom. A small amount of radiological contamination was detected on the top of the trailer bed, the bottom of the breached container, and one adjacent container. Contamination levels were under limits allowed by DOT regulations but above DOE criteria. The breached container was wrapped and overpacked, pending decisions on disposition of the waste shipment. No contamination was spread to the environment or people. An investigation of the incident is underway.
B-6
I l
2. PORTSMOUTH GASEOUS DIFFUSION PLANT

1. NCS Noncompliances in ClassifiedStorage Area. On September 5,1997. during an NCS walkdown inspection of a classified storage area in the X-300lN facility, several noncomphance issues were identified. Approximately fifty to sixty 55-gallon drums and fourteen B-25 boxes (hereafter identified as containers) of classified metal parts with an unverified amount of 2"U content from the uranium enrichment cascade were discovered in the facility. Results of the walkdown were documented and preparations for Non-Destructive Assay (NDA) measurement of the identified containers were initiated. On September 30,1997, NDA measurement activities conn.cced.
Between September 30 and October 14,1997, six containers were identified as potentially 2 exceeding the "U mass limits for the facility. Containers that measured greater than 15 grams of 2"U were transferred to a facility approved for the storage of classified material and protected by the CAAS, as required. Containers that were verified to have less than 15 grams of 2"U were returned to the X-300lN classified storage area. NCS postings were placed on all entrance gates, and the facility manager was required to attend NCS training. There were no environmental, safety or health impacts.
2. Mislabehng ofHa:ardous MaterialShipment. On November 17,1997, a shipment of DOE hazardous material was transported to the X-10 site in Oak Ridge, TN from PORTS. On November 18,1997, an X-10 representative contacted the PORTS PSS stating that the shipment had arrived but that a type 6M overpack had potentially been mislabeled. The labeling was determined to be a noncompliance with DOT Hazardous Material Regulations 49 CFR 172.403. There was no impact on the environment, safety and health as a result of this event. DOT requirements for regulated shipments have been emphasized at the site by training / retraining efforts.

3. Storage of UF, Cylinders in Prohibited Area. On November 20,1997, during an inspection of the X-345 Special Nuclear Materials Storage Facility by the site's NCS Engineer, two eight-inch UF.
cylinders were identified as being stored in in-floor storage receptacles prohibited from use by the applicable NCSA. One of these receptacles is within approximately 17 inches of a filled hoke tube cabinet which resulted in the loss of a single contingency. Immediately upon discovery, all fissile material operations within the area were suspended. Site M?nagement reviewed the NCS Engineer's evaluation, developed a recovery plan, and implemented corrective actions to relocate the cylinders and to assure rigorous conduct of operations in the facility. There were no environmental, safety or health impacts. \\
4. Errors in Labeling andMovement ofDrums During Sampling Activity. On April 7,1998, WM personnel, while performing a review of LEU Trap Material sampling records, determined that two 2
sampled 55-gallon drums containing a "U mass greater than 350 grams had been moved from the X-744G(R) to the X-744G(U) area in the X-744G facility. The applicable procedure identifies a 2"U mass limit of 350 grams per container for acceptance into the X-744G (U) area. Subsequent evaluation revealed that the drums were mislabeled and that the safe mass (based on enrichment) had not been exceeded. Sampling activities in this area were placed on hold pending resolution of the issue with NCS and facility operations personnel. Approved corrective actions, w hich addressed review and awareness of the applicable procedure, were implemented and sampling activities were resumed. B-7
5. NCSIssues identi/ledin DMSA. An NCS-walkdown review on April 15,1998, of DMSAs 8A and 12 in the X-326 Process Building identified the following issues: (1) contaminated metal not covered with plastic as required by procedure,(2) postings no ampliant with plant procedures (both found in DMSA 8A),(3) a scrap metal drum filled in D OSA 12 by USEC subcontractors and (4) a small bucket of oil and a lube oil return container found abandoned in DMSA 12. The posting deficiency for DMSA 8A was corrected in accordance with procedure and the contaminated metal was covered. With regard to the issues in DMSA 12, the USEC construction engineer briefed personnel on the DMSA requirements and moved the identified drum and oil bucket to USEC-leased space outside the DMSA 12 area. DMSA 8A and 12 are EU DMSAs used for the storage of contaminated equipment and material per an agreement between DOE and USEC. Additional corrective actions included conducting a review of the applicable NCSA, protocol requirements, and protocol usage with subcontractor personnel who routinely enter DMSAs 8A and 12. There were no environmental, safety or healtn impacts.
6. Violation ofNCS Spacing Requirements. On April 16, ;998, during performance of an NCS self-assessment walkdown of the X-7745R storage pad, eighteen B-25 boxes were found spaced less than the 24 inches required by procedure. Subsequent evaluation determined that double contingency was still in effect. Project management, u, der NCS technical direction, stopped all movement of uranium bearing material within the facility until proper spacing of the identified containers was initiated and completed. In addition, the importance of NCS controls was reemphasized to operators and their supervisors. 7 Violation ofNCSSpacing Requirements. On April 21,1998, multiple NCS spacing violations were identified by the NCS Staff Engineer and Facility Custodian during a walkdown of DMSA 1 in the X-333 Process Building. This DMSA contains contaminated process equipment and scrap metal. Mcvement of equipment or scrap metal within the DMSA was stopped unless written approval was chained from the NCS Engineer. All work was ceased in the area pending resolution of the NCS spacing violation. The Facility DMSA owner initiated and completed a recovery plan that addressed the NCS concerns. There were no environmental, safety, or health impects.
8. Roller Equipment Overturns at Landfill Construction Site. On May 14,1998, a subcontractor construction employee was operating a smooth drum roller at the X-749B landfill closure construction site. While sealing the compacted surface of a 12-inch engineering fill, the operator moved the roller too close to the edge of the fill. The edge of the fill collapsed, causing the roller to slide approximately 15 inches from the height of the engineere.1 fill and to tip over on its right side.
The operator was immediately removed from the eouipment. No injuries were sustained. The operator was wearing all required PPE. The roller was placed in an upright position with a crane and a spill kit was implemented to remediate less than one quart of spilled fuel, oil and hydraulic fluid from the roller. Corrective action included revising the subcontractor's Activity llazard Analysis to require that compactor / roller operators maintain at least a three-foot distance from the edge of the fill layer with their equipment. All operators were retrained regarding this revision. No insult to the environment res;lted.
9. Drum Failure in PCB Storage Facility. On May 18,1998, a project engineer, perform:ng a self assessment walkdown of the X-7725A PCB storage facility, discovered PPE I. tying on the concrete floor in an aisle way. He also noticed that a lid had become unsealed from a 55-gallon drum, exposing the contents. Ilealth Physics and Industrial flygiene surveys were Performed. No B-8 l
l
~ radiological contamination was found. The contaLc was isolated, the loose PPE was placed into an empty drum, and new lids were placed on both drums. Other containers in the facility were checked for any evidence of pressurization. Corrective actions included sorting, sampling, and repackaging contents of the drum and developing and disseminating formal lessons learned. No negative impacts on the environment resulted from this occurrence.
10. NCSIssue Identifiedin DMSA. On June 9,1998, Ove 55-gallon drums in the X-700 DMSA were measured using NDA. The NDA measurements were requested to meet USEC's prime contractor's operational requirements. One of the drums was identiDed as potentially containing more than 350 grams of 2"U, which was in excess of the prime contractor's operational requirements. The drum was isolated and all movement of uranium bearing material associated with the drums was halted.
Double contingency was maintained. Additional memrements of drums in the X-700 DMSA identified other drums that potentially exceeded operational requirements. NCS controls were established by placing a boundary and appropriate signage around the drums.
11. Incorrect Calculation Performed to Determine Maximum Allowable Load Limitsfor Shipping Containers. On June 26,1998, an occurrence report was Gled to initiate an Unreviewed Safety Question Determination (USQD) on the maximum allowable loading limit calculation that was calculated on September 17,1996, and that was used to accept or reject containers for packaging and shipping HEU oxides. This calculation was discovered to be incorrect during a procedure review. The NCS engineer determined that PORTS had a potential violation of the facility authorization basis and therefore may have a USQ. The shipping records for oxides previously shipped in DC-1 shipping packages from PORTS were reviewed to determine whether the corrected i
maximum allowable loading limits had been exceeded. No exceedances were identiGed. Corrective actions include documenting the basis for reducing the current maximum allowable loading limits by 100 grams and notifying the original calculati?n preparers of the incorrect caiculation assumptions. No impacts to the environment, sr.fety or health resulted from this oc:urrence.
12. NOVfrom Ohio EPAfor 90 Day Ha:ardous Waste Accumulation Area. On July 8, l998, Ohio EPA notified DOE and its prime contractor of a violation of the Ohio Administrative Code Inspections and Closure Performance Standard for the X-622 groundwater treatment facility hazardous waste accumulation area. The Ohio EPA conducted an unannounced RCRA inspection of the facility on June 24-25,1998. According to the NOV, adequate inspection records were not maintained. DOE provided written documentation on August 6,1998, regarding the inspection records to Ohio EPA.
On August 19,1998, Ohio EPA notified DOE in writing that the violation had been abated.
13. NCS Procedure Violation h Handling Uranium Bearing Material. On July 13, l998, two DOT 7A Combo overpacks of uranium bearing material were moved in the X-326 process building in violation of NCS procedures for movement and proper spacing. Personnel involved did not adequately understand the applicable procedures and NCSA requirements. All fissile material operations associated with this activity were immediately stopped, and the material was placed in a safe con 0guration within the X-326 L-cace. Before restart of this activity, the training of the operators was validated, including any " Ell-in" or temporary replacements. There were no environmental, safety or health impacts from this event.

14. ContaminatedEquipment Brought On-site By Roofing Subcontractor. On July 2l. l998, a baseline radiological survey of the: X-7725 roofing subcontractor's equipment and materials determined that B-9
2 a roof drain strainer with fixed surface contamination of 300,000 dpm/100 cm maximum beta / gamma was included in the materials that were brought on plant site by the subcontractar. Upon completion of the survey activities, the strainer was bagged, tag;ed, and placed in a posted, j controlled radiological area. No personnel contaminaus, adiation exposure, or spread of I contamination resulted from this event nor was there any env:ronmental release. The subsequent j shipments of the subcontractor's material and equipment were staged outside the radiot ' ally controlled area and a comprehensive survey conducted prior to oi, site entry.
15. USQ Concerning Uranium Material Ha idlingfor Batching ofScrap Metal. As the result af operations involving the batching of ur.mium contaminated pigtails with limited hidden volumes into unfavorable geometry containers. a USG3 was performed on July 21,1998. The applicable NCSA and procedure permit batching of up w one gallon of total hidden volume into an unfavorable geometry container. It was detcir.iined that volume control in this NCS A is de0cient because it does not adequately cover the heterogenous con 0guration. The safety signific.mce of this event is low. Although the NCSA did not adequately control the batching of contaminateJ metal by volume, double contingency was nnintained.

16. Incorrect Evacuation Zone for the X-7745R Storage Pad. On August 3,1998, an error was identified in a procedure for the CAAS. The map in the procedure inaccurately reDected the l
Immediate Evacuation Zone for the L7745R Storage Pad. This error was determined to be a USQ. Using the map in the procedure could have resulted in improper personnel evacuation and emergency preparedness / management response in the event of a CAAS evacuation of the storage pad. A problem report was submitted which provided the PSS with a corrected map showing the proper evacuation area for the X-7745R storage pad.
17. FallProtection Violation. On September 14,1998, subcontractor personnel assigned to paint the roofon a trailer at the X-622T groundwater treatment facility were observed performing work in violation of the instructions of the Safety and Health Work Permit. The workers were observed walking on the roof of the trailer without proper fall protection equipment. No injuries were I
sustained. Subcontractor management was immediately notified of the Safety and Health Permit violation and noncompliance with OSHA regulations, and subcontractor personnel were told that no f' Are violations of these regulations would be tolerated. 1F Potential USQ Concerning NCSAfor Contaminated Process Equipment. A problem report was genera;ed on September 18,1998, by USEC's prime contractor. This report identified a potential USQ regarding calculations in an NCSA procedure (NCSA-PLANT 062) for safe storage of favorable geometry equipment. This procedure was adopted by the DOE's contractor on April 23, 1998. The safety significance of this event is low. Operations were reviewed, and it was determined that double contingency was maintained. A USQD will be completed.
19. 480 Volt Electrical Cable Severed During Excavation Activity. On September 30,1998, maintenance personnel severed an energized 480-volt cable with a backhoe during excavation activities to repair a recirculating hot water line located on the west side of the X-772.5 Building.
The associated circuit breaker operated correctly and interrupted the ground fault caused by the excavation equipment. Blueprints did not indicate a buried cable in this area. Subsite surveys were 1 performed prior to and during the excavation. The cable was not identi6ed by the surveys. No injuries resulted from the incident. Excavation activities were ceased and a stop work order was B-10
i 1 issued on all excavation activities until an ii vestigation cauld be completed A critique of the event indicated that engineering and administrativ i controls w2e in place, f I l i 1 e i I I 1 1 l 1 1 f l a B-11 i i .}}

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