ML20236N129

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Provides Comments on Renewal Applications for Certification of Paducah & Portsmouth Gaseous Diffusion Plants
ML20236N129
Person / Time
Site: Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date: 06/19/1998
From: Hooks C
ENVIRONMENTAL PROTECTION AGENCY
To: Ten Eyck E
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9807150019
Download: ML20236N129 (2)


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fOj UNITED STATES ENVIRONMENTAL PROTECTION AGENCY y

WASHINGTON, D.C. 20460 OFFICE OF JUN I 9 1998

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COMPLIANCE ASSURANCE Ms. Elizabeth Q. Ten Eyck, Director Division of Fuel Cycle Safety and Safeguards, NMSS U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Ms. Teu Eyck:

f We have received and reviewed the Nuclear Regulatory Commission's (NRC) renewal applications for certification of the gaseous diffusion plants located in Piketon, Ohio (Portsmouth) and Paducah, Kentucky. Our comments follow:

PADUCAH:

EPA found the environmental section of the application to be factually accurate and complete. There are no current enforcement actions being taken at the USEC Paducah plant.

PORTSMOUTH:

USEC has requested that the NRC renew the Certificate of Compliance for 5 years until the expiration date of December 31,2003. This 5 year period may be excessive, especially with annual re-certification no longer required, and the likelihood that USEC will be a private corporation in approximately one year. It is suggested that the " periodic" review period be every two years (with current certification expiring in December,2000). This determination should relate to and be based upon, among other factors, the degree of environmental compliance at the facility.

The significant amount ofinformation " incorporated by reference" makes a thorough e

review of the Renewal Application diflicult.

\\0 The statement "Due to the required schedule for submission of this document, effluent and l

environmental data and the public dose assessments for CY 1997 will not be available in time for inclusion here," (Page 1) is too general and insufficient. Additional u

justification / explanation which details for the reader the reasons why data up to FY97 can nU' not be available should be provided.

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Clean Water Act: While there is passing mention ofTCE being present in onsite groundwater plumes in this section, there is no mention of a groundwater monitoring program on page 5 under Section 4, Environmental Monitoring Data, and the monitoring data summary tables do not include groundwater monitoring. Are there offsite public or private water supply wells that have or could be impacted by the facilities groundwater contamination plumes? If so, what steps is the facility taking to monitor and remediate offsite contamination?

Resource Conservation and Recovery Act (RCRA): According to RCRIS, USEC returned to compliance on July 15,1997, with the one violation cited. The date of compliance i

should be mentioned in the document.

Underground Storage Tanks (UST): Portsmouth has 1I USTs. The application indicates p

that they are in compliance with applicable State requirements. EPA RegionV will pass j

this info to Ohio-EPA.

Polychlorinated Biphenyls: USEC and DOE have overlapping environmental l

responsibilities at this site. DOE's main responsibility includes storage, disposal, spills, l-and waste prior to the inception of USEC in July of 1993 (referred to as " legacy waste").

. After July,1993, uncontrolled discharges of PCBs from electrical equipment operated by USEC, together with other TSCA regulations, are the responsibility of USEC. A recent Notice of Non-compliance issued to USEC, we understand, has initiated dialogue between USEC and DOE to detail environmental responsibilities between the two parties located at this facility.

l Ifyou have any questions regarding these comments, please call David Levenstein at 202-l 564-2591 (Paducah), or Lance Elson at 202-564-2577 (Portsmouth).

S' cerely, m

Crai ooks, Director Federal Facilities Enforcement Office

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