ML21277A366

NRC-2021-000238 - Resp 3 - Interim, Agency Records Subject to the Request Are Enclosed

ML21277A366
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DOE/ORO-2087 DEPARTMENT OF ENERGY ANNUAL REPORT ON THE STATUS OF ENVIRONMENTAL, SAFETY, AND HEALTH CONDITIONS AT THE PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANTS FOR FISCAL YEAR 1999 U.S. Department of Energy Oak Ridge Operations Oak Ridge, Tennessee 37830 AS3O

DISCLAIMER This document was prepared by the U.S. Department of Energy (DOE) Regulatory Oversight Program under the direction ofthe DOE Regulatory Oversight Manager. Neither the United States Government nor any agency thereof, nor any of their employees, makes .y warrant-, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, o. isefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof.

DOE/ORO-2087 DEPARTMENT OF ENERGY ANNUAL REPORT ON THE STATUS OF ENVIRONMENTAL, SAFETY, AND HEALTH CONDITIONS AT THE PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANTS FOR FISCAL YEAR 1999 November 1999 Prepared by Department of Energy Regulatory Oversight Program Prepared for U.S. Department of Energy Oak Ridge Operations Oak Ridge, Tennessee 37830

CONTENTS A cronym s ......................................................................... vii Executive Sum m ary ................................................................... xi

1. B ackground ..................................................................... 1 1.1 Regulatory Responsibilities .................................................... 2 1.2 M emorandum of Understanding ................................................. 4

2. DOE Regulatory Oversight Program Status ............................................ 4 2.1 Inspections .................................................................. 5 2.2 Safety Evaluations and Operational Readiness Assessments ........................... 6 2.3 Safeguards and Security Activities ............................................... 7 2.3.1 Arming and Arrest Authority ............................................. 7 2.3.2 Security Plans ....................... ................................. 8 2.4 Compliance Plan Activities ...................................................... 8

3. Lease M odifications ............................................. ................ 9

4. DOE Environmental, Safety, and Health Policy ........................................ 11

5. DOE Environmental, Safety, and Health Initiatives .................................. 13 5.1 Highly Enriched Uranium Disposition ........................................... 13 5.1.1 Highly Enriched Uranium Agreements .................................... 13 5.1.2 Highly Enriched Uranium Refeed and Cylinder-cleaning Program .............. 14 5.1.3 Highly Enriched Uranium Suspension and Removal Program .................. 14 5.1.4 Highly Enriched Uranium Transparency Implementation Program .............. 16 5.2 Depleted Uranium Hexafluoride Long-term Management ............................ 18 5.2.1 Final Programmatic Environmental Impact Statement ........................ 18 5.2.2 Plan for Conversion of Depleted Uranium Hexafluoride ...................... 19 5.3 Uranium M anagement Activities ............................................... 20 5.3.1 Uranium Management Center ........................................... 20 5.3.2 Storage of Fernald Uranium Materials ..................................... 22 5.3.3 Storage of Uranium Materials from Hanford and Universities .................. 22 iii

5.4 Other DOE Environmental, Safety, and Health Initiatives ............................ 23 5.4.1 Secretarial Initiative on Environmental, Safety, and Health Conditions at Paducah.. 23 5.4.2 Integrated Safety Management Initiative ................................... 23 5.4.3 Paducah Environmental, Safety, and Health Initiatives ........................ 24 5.4.4 Portsmouth Environmental, Safety, and Health Initiatives ..................... 25

6. Environmental, Safety, and Health Status of Nonleased Areas ............................ 25 6.1 Environmental, Safety, and Health Status of Nonleased Areas at Paducah ............... 26 6.1.1 Facilities and A creage ................................................. 26 6.1.2 Construction Activities ................................................ 26 6.1.3 Depleted Uranium Hexafluoride Management .............................. 27 6.1.4 Update of Safety Analysis Report ........................................ 28 6.1.5 Environmental Restoration .............................................. 28 6.1.6 W aste M anagem ent ................................................... 32 6.1.7 DOE M aterial Storage Areas ............................................ 33 6.1.8 Environm ental Status .................................................. 33 6.1.9 Safety and Health Status ............................................... 34 6.1.10 Reportable Occurrences ................................................ 35 6.1.11 Sum mary ........................................................... 36 6.2 Environmental, Safety, and Health Status of Nonleased Areas at Portsmouth ............. 36 6.2.1 Facilities and A creage ................................................. 36 6.2.2 Construction Activities ................................................ 36 6.2.3 Depleted Uranium Hexafluoride Management .............................. 37 6.2.4 Update of Safety Analysis Report ........................................ 38 6.2.5 Environmental Restoration .............................................. 38 6.2.6 W aste M anagem ent ................................................... 41 6.2.7 DOE Material Storage Areas ............................................ 41 6.2.8 Environm ental Status .................................................. 41 6.2.9 Safety and Health Status ............................................... 43 iv

6.2.10 Reportable Occurrences ................................................ 43 6.2.11 Summ ary ............................................................ 44

7. Compliance W ith Applicable Laws ................................................. 44 A ppendices ........................................................................ 45 A. Summary of DOE Regulatory Oversight Program Inspection Reports ...................... A-1 B. Summary of Reportable Occurrences in Nonleased Areas at the Gaseous Diffusion Plants ..... B-i

1. Paducah Gaseous Diffusion Plant ............................................... B-3

2. Portsmouth Gaseous Diffusion Plant ............................................. B-9 V

vi ACRONYMS AEA Atomic Energy Act of 1954, as amended AHA Activity Hazard Analyses AOC Area of Concern ATSDR Agency for Toxic Substances and Disease Registry CAS/CMS Cleanup Alternatives Study/Corrective Measures Study CAAS Criticality Accident Alarm System CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of FederalRegulations CMI corrective measures implementation CSOU Comprehensive Sitewide Operable Unit CY calendar year D&D decontamination and decommissioning DF&O Director's Findings and Orders DMSA DOE Material Storage Area DNFSB Defense Nuclear Facilities Safety Board DOE U.S. Department of Energy DOT U.S. Department of Transportation DP Office of Defense Programs DUF 6 depleted uranium hexafluoride DU Depleted Uranium EA Environmental Assessment EE/CA Engineering Evaluation and Cost Analysis EF Enrichment Facilities EIS Environmental Impact Statement EM Environmental Management (when referring to the program)

EM Office of Environmental Management (when referring to DOE Program Office)

EPA Environmental Protection Agency EPAct Energy Policy-Act of 1992 ER environmental restoration ES&H environmental, safety, and health ETTP East Tennessee Technology Park FEMP Fernald Environmental Management Project FFA Federal Facility Agreement FFCA Federal Facility Compliance Agreement FS Feasibility Study FY fiscal year GDP gaseous diffusion plant HEU highly enriched uranium IGWMP Integrated Groundwater Monitoring Plan ISCOR in situ chemical oxidation and recirculation ISMS Integrated Safety Management System ITRD Innovative Treatment Remediation Demonstration KDEP Kentucky Department for Environmental Protection vii

KPDES Kentucky Pollutant Discharge Elimination System LANL Los Alamos National Laboratory LEU low-enriched uranium LWC lost workday case MD Office of Fissile Materials Disposition 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 NCRP National Council on Radiation Protection and Measurements NE Office of Nuclear Energy, Science and Technology NEPA National Environmental Policy Act NN Office of Nonproliferation and National Security NOV Notice of Violation NPDES National Pollutant Discharge Elimination System NPL National Priorities List NRC U.S. Nuclear Regulatory Commission NTS Noncompliance Tracking System NU normal uranium O&M Operations and Maintenance OAC Ohio Administrative Code ORA Operational Readiness Assessment ORO Oak Ridge Operations OSHA Occupational Safety and Health Administration OU Operable Unit OVM Organic Vapor Monitor PAAA Price-Anderson Amendments Act PACE Paper, Allied-Industrial, Chemical, and Energy Workers International Union PCB polychlorinated biphenyl PEIS Programmatic Environmental Impact Statement PEL Permissible Exposure Limit PGDP Paducah Gaseous Diffusion Plant PORTS Portsmouth Gaseous Diffusion Plant PPO Permanent Presence Office PSAP Personnel Security Assurance Program RCRA Resource Conservation and Recovery Act RFI RCRA Facility Investigation RIlIs recordable illnesses and injuries RO Regulatory Oversight ROA Regulatory Oversight Agreement ROD Record of Decision RWP Radiological Work Permit SAR Safety Analysis Report SER Safety Evaluation Report viii

SPIRA Special Applications Portable Infrared Analyzer SSR site safety representative STOP Safety Team of Paducah SWMU solid waste management unit TCE trichloroethylene TCLP Toxicity Characteristic Leaching Procedure TRE Toxicity Reduction Evaluation TSCA Toxic Substances Control Act TUa Toxicity Units Acute UF 6 uranium hexafluoride UMC Uranium Management Center USEC United States Enrichment Corporation USEPA U.S. Environmental Protection Agency VOC volatile organic compound WAC Weapons Authorization Card WAG Waste Area Group WM waste management ix

EXECUTIVE

SUMMARY

and transparency implementation programs conducted by DOE; (2) activities to develop and implement plans and strategies for the long-term The Energy Policy Act of 1992 (EPAct) management of DOE-owned depleted uranium amended the Atomic Energy Act of 1954 to hexafluoride (DUF 6) and other uranium materials; require that the U.S. Department of Energy and (3) other DOE ES&H initiatives. The report (DOE) transfer or lease certain functions also discusses the status of the DOE Regulatory associated with its uranium enrichment Oversight Program for designated leased, but not operations to the United States Enrichment NRC-certified, portions of PORTS as well as Corporation (USEC), a government corporation modifications to the Lease Agreement Between created pursuant to the EPAct. In addition, the the United States Department of Energy and the EPAct required that regulatory oversight United States Enrichment Corporationfor authority over the leased portions of the Gaseous FY 1999. The report briefly describes the Diffusion Plants (GDPs) be transferred from Memorandum of Understanding employed by DOE to the U.S. Nuclear Regulatory Commission DOE and NRC to ensure effective and efficient (NRC) and that USEC prepare a plan for cooperation in their joint oversight of activities transferring ownership of USEC to private conducted at the GDPs.

investors within 2 years of the lease date. In furtherance of this mandate, DOE leased certain This annual report demonstrates the portions of the Paducah Gaseous Diffusion Plant effectiveness of ES&H protection at the GDPs (PGDP) near Paducah, Kentucky, and the under DOE regulatory oversight. During Portsmouth Gaseous Diffusion Plant (PORTS) FY 1999, environmental releases and discharges near Piketon, Ohio, to USEC on July 1, 1993. for which DOE was responsible at PGDP and Transfer of regulatory oversight authority for the PORTS were within established regulatory limits leased portions of the GDPs from DOE to NRC except for three Kentucky Pollutant Discharge occurred on March 3, 1997. On July 28, 1998, Elimination System permit exceedances at one approximately 16 months after transfer of outfall at PGDP. These exceedances were related, regulatory oversight authority from DOE to NRC, in part, to runoff from the cylinder storage yards USEC became a private corporation, USEC, Inc., containing painted DUF 6 cylinders. Although through an initial public offering. these permit exceedances had no significant environmental impact, DOE implemented a This report, covering fiscal year (FY) 1999, is Toxicity Reduction Evaluation plan. No the third annual report on the status of additional exceedances of this nature occurred environmental, safety, and health (ES&H) during the remainder of the reporting period.

conditions of the nonleased portions of the GDPs for which DOE retains regulatory oversight During FY 1999, the Environmental responsibility. It is prepared in furtherance of the Restoration (ER) and Waste Management (WM)

EPAct mandate that NRC consult with DOE and programs at PGDP and PORTS met all regulatory the U.S. Environmental Protection Agency in deadlines. PGDP and PORTS continued making preparing a report to Congress on the status of good progress toward eventual site cleanup ES&H conditions at DOE's gaseous diffusion through their ER and WM activities. For uranium enrichment facilities. This report also example, PGDP (1) completed remedial actions provides information on the status of DOE ES&H for Waste Area Groups 1 and 7, which include initiatives for the GDPs during FY 1999 the C-746-K inactive sanitary landfill and other including (1) activities of the highly enriched areas; (2) treated approximately 174 million uranium (HEU) refeed, suspension and removal, gallons of contaminated groundwater; xi

(3) completed the remediation process on two incident resulted in minor injuries to a contractor.

10,000-gallon underground storage tanks installed Important lessons learned were derived from during the 1950s; (4) obtained regulatory these incidents, applied at the GDPs, and approval for the remediation plans for application distributed throughout the DOE complex.

of the LasagnaTM soil remediation technology at Solid Waste Management Unit 91; (5) treated, During FY 1999, DOE continued with major shipped, or disposed of more than 4,935 tons of initiatives to enhance safety and environmental waste; and (6) initiated engineering evaluations protection at both PGDP and PORTS. In response for the removal of 65,000 tons of scrap metal. to an initiative of the President and the Secretary During the same period, PORTS (1) completed of Energy, DOE's Enrichment Facilities (EF) field activities on three ER pilot projects to Program completed the removal of DOE-owned evaluate different treatment technologies; HEU materials stored at the PORTS site. The (2) completed a phytoremediation project; removal of these HEU materials significantly (3) began capping a landfill; (4) disposed of reduces ES&H risks and safeguards and security approximately 2,000 tons of sludge and soils operating costs at PORTS. DOE also continued from remediation projects; and (5) treated or with initiatives related to the storage of cylinders recycled approximately 230 tons of waste and containing DUF 6. In April 1999, DOE issued a wastewater. final Programmatic Environmental Impact Statement (PEIS) that identified the This annual report also provides information recommended alternative for dispositioning the reflecting the status of safety and health inventory of DUF 6 in storage at PGDP, PORTS, conditions for those areas at the GDPs under and the East Tennessee Technology Park DOE regulatory oversight. The calendar year (formerly K-25) in Oak Ridge, Tennessee. The 1998 radiation exposure averages for PGDP and PEIS was followed by issuance of the Record of PORTS personnel were 10 mrem and 0.95 mrem Decision in August 1999. DOE's EF Program is per person per year, respectively. These averages responsible for management of DUF 6, a should be contrasted with the average annual byproduct of uranium enrichment, generated at background radiation levels per person of PGDP and PORTS from the start of production in 30 mrem from cosmic radiation, 30 mrem from the 1950s. Also in FY 1999, the DOE Oak Ridge terrestrial sources, 40 mrem from food, 200 mrem Operations Office created the Uranium from naturally occurring radon sources, and the Management Center (UMC) to serve as the single 5,000 mrem occupational exposure limit set by focal point for the management of all DOE federal law in 10 CFR 835. In FY 1999, DOE and potentially reusable uranium materials throughout its prime contractors and subcontractors at PGDP the DOE complex. The UMC will provide a had five recordable injuries and illnesses (RIIs) coordinated, cost-effective, and efficient program but no Lost Workday Cases (LWCs). During this for management of the nation's surplus uranium period, DOE and its prime contractors and resources.

subcontractors at PORTS had eight RIIs, including two LWCs. During FY 1999, certain DOE EF, ER, and WM program activities in the DOE nonleased In FY 1999, 22 incidents at PGDP and 15 areas at the GDPs continued to experience incidents at PORTS associated with activities in funding reductions or limitations that impact the the nonleased areas were significant enough to be performance of ES&H-related work. Although no classified as reportable occurrences by DOE. At Notices of Violation (NOVs) or noncompliances PGDP, no harm to the environment or to people have been identified as a result of funding resulted from these incidents. At PORTS, one reductions, these situations are impacting the EF Xii

DUF 6 cylinder management project, cylinder changes for both GDPs and performed the storage yard construction, and schedules for necessary safety evaluations before approving completion of ER and WM site cleanup work at these changes. In response to FY 1999 the GDPs. Congressional legislation, actions were taken to extend, under the Regulatory Oversight In addition to its oversight of the nonleased Agreement between DOE and USEC, DOE's areas of PGDP and PORTS, DOE regulates oversight of the federal arming and arrest USEC HEU-related activities in designated authority for the plant protective forces at both leased, but not NRC-certified, areas at PORTS. GDPs. Finally, DOE continued effective and During FY 1999, DOE conducted more than 60 responsible administration of the Lease inspections of HEU-related activities in these Agreement between DOE and USEC during areas. As a result of these inspections, DOE FY 1999.

issued one NOV to USEC. The NOV involved a failure to meet Nuclear Criticality Safety (NCS) In conclusion, this report presents the requirements. During the same period, DOE determination that in those instances where issued three noncited violations to USEC. These regulatory violations occurred, actions were taken noncited violations involved failure to meet NCS to notify appropriate authorities, identify the and emergency preparedness requirements. cause of the violation, and institute corrective Because of USEC's prompt and aggressive measures. Such responsiveness enabled DOE to corrective actions, DOE exercised enforcement maintain adequate and effective ES&H protection discretion and categorized these violations as in both the nonleased and leased, but not noncited violations. In addition to its inspection certified, areas at the GDPs for which it retained activities, DOE reviewed several USEC-proposed regulatory oversight responsibility during plant changes at PORTS and Compliance Plan FY 1999.

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AIX

1. BACKGROUND Enrichment Corporation(hereinafter referred to as the Lease), dated July 1, 1993, and in other For more than 50 years, the U.S. Department subsequent agreements, DOE and USEC of Energy (DOE) and its predecessor agencies established the roles and responsibilities for each operated the nation's uranium enrichment organization at both GDPs.

enterprise at facilities near Oak Ridge, Tennessee; Paducah, Kentucky; and Portsmouth, To promote the privatization of DOE's Ohio. The original purpose of the uranium uranium enrichment operations, the EPAct also enrichment operations, which are regulated under required that within 2 years after the transition the Atomic Energy Act of 1954 (AEA), as date of July 1, 1993, USEC prepare a plan for amended, was to supply enriched uranium to the transferring ownership of USEC to private U.S. nuclear weapons programs. Today, however, investors. Pursuant to this requirement, USEC the uranium enrichment operations produce submitted a plan entitled Planfor the enriched uranium primarily for commercial Privatizationof the UnitedStates Enrichment customers to operate nuclear power plants. The Corporationto the President and Congress in Oak Ridge Gaseous Diffusion Plant, which was June 1995. On April 26, 1996, the USEC built during the World War II Manhattan Project, Privatization Act was enacted.' This act directed ceased production in 1985 and was permanently the USEC Board of Directors to establish a for shut down in 1987. The Paducah Gaseous _ profit private corporation to receive the assets Diffusion Plant (PGDP), located in Paducah, and obligations of USEC, to continue the Kentucky, which began operations in 1952, and operations of the government corporation, and to the Portsmouth Gaseous Diffusion Plant secure the maximum proceeds to the United (PORTS), located near Piketon, Ohio, which States from the sale of the United States' interest began operations in 1954, operated under DOE in USEC. On July 28, 1998, USEC became a and its predecessor agencies until July 1993, at private corporation, USEC Inc., through an initial which time the United States Enrichment public offering.

Corporation (USEC) assumed responsibility for uranium enrichment operations at both facilities. The EPAct assigns responsibility to DOE for the payment of any costs of decontamination and On October 24, 1992, the Energy Policy Act decommissioning (D&D), response actions, or of 1992 (EPAct) amended the AEA to require corrective actions at the GDPs related to that DOE transfer certain functions associated preexisting conditions (i.e., conditions existing with its uranium enrichment operations to USEC, before lease of the GDPs to USEC). With this a government corporation created pursuant to the assignment, DOE retains responsibility for EPAct. On July 1, 1993, in furtherance of this environmental restoration and legacy waste mandate, DOE leased to USEC those portions of management at the GDP sites and for the the gaseous diffusion plants (GDPs) that are operation of the nonleased facilities used for the required for uranium enrichment. In the Lease storage of DOE-owned source and special nuclear Agreement Between the United States material such as the cylinder storage yards for Department of Energy and the United States

'42 U.S.C: § 2297(h).

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depleted uranium hexafluoride (DUF 6) generated deadline for establishing safety and safeguards before July 1, 1993.2 and security regulations. This schedule created an interim period between the lease of the GDPs to The EPAct also required that regulatory USEC and assumption of regulatory oversight by oversight authority over the leased portions of the the NRC on March 3, 1997. During this period, GDPs be transferred from DOE to the U.S. there was a need for continued regulatory Nuclear Regulatory Commission (NRC). This oversight of safety and safeguards and security at transfer occurred on March 3, 1997. However, the GDPs until NRC assumed regulatory under the EPAct, DOE retains possession of, and oversight responsibility. Consequently, DOE regulatory responsibility for, all highly enriched developed a Regulatory Oversight Agreement uranium (HEU) and oversight authority over the (ROA) with USEC that became the basis for nonleased portions of the GDPs. DOE oversight of safety and safeguards and security for the leased areas of the GDPs during this period.

1.1 REGULATORY RESPONSIBILITIES The ROA consists of those performance The EPAct assigns safety and safeguards and based standards extracted from the DOE Orders security regulatory responsibility at the leased that are related to nuclear safety and safeguards (i.e., USEC-operated) portions of the GDPs and security. These standards are considered involving low-enriched uranium (LEU) activities essential for continued safe and secure operation to NRC. In furtherance of this assignment, the of the GDPs. The ROA is included as a part of EPAct required that within 2 years of the date of the Lease (Exhibit D to the Lease), and its its enactment, NRC establish by regulation standards are commensurate with the standards (I) safety and safeguards and security standards that were promulgated by NRC in Title 10 of for the GDPs and (2) a certification process to Code of FederalRegulations (CFR), Part 76 ensure that USEC complies with these standards. (10 CFR 76), "Certification of Gaseous Diffusion This certification process is in lieu of any Plants." Originally used to regulate the USEC requirement for a license. Thus, the EPAct made leased portions of the GDPs during the interim NRC regulation of the GDPs conditional on the period, the ROA continues to be used by DOE to issuance of new regulations, which were regulate HEU-related activities at PORTS and promulgated in September 1994. However, the will be used to regulate the federal arming and EPAct required DOE to lease the GDPs to USEC arrest authority of the protective force personnel on July 1, 1993, more than a year before the at both GDPs beginning in fiscal year (FY) 2000.

(See Section 2.3.1.) The ROA also contains provisions for DOE appraisals and inspections of the leased facilities, for issuance of Notices of

'lbid. With the signing of the USEC Privatization Act, the liability of the United States and the Secretary of Energy Violation (NOVs) in response to failures to meet was modified. The United States assumed responsibility for ROA standards, and for USEC self-assessments liabilities arising out of the operation of USEC until the date of compliance with ROA standards. Provisions of privatization [unless otherwise provided in a also are included for enforcement actions Memorandum of Agreement (MOA)]. The disposal of depleted uranium generated by USEC between July 1, 1993, including civil penalties and curtailment or and the date of privatization is the responsibility of tht shutdown of operations-in response to Secretary of Energy. Pursuant to a June 30, 1998, MOA violations. Because the ROA requirements were between DOE and USEC, DOE agreed to accept additional deemed adequate for continued safe and secure depleted uranium generated by USEC after privatization. operation of the GDPs, DOE exempted USEC (See Sections 6.1.3 and 6.2.3.)

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and the leased portions of the GDPs from the (3) DOE oversight of nonleased areas. In the near regulations that DOE promulgated to implement future, DOE will assume responsibility for the Price-Anderson Amendments Act (PAAA). interim regulation of the federal arming and arrest authority of the protective force personnel at The EPAct also made provision for the PGDP and PORTS under the ROA. (See possibility that USEC initially might not be able Section 2.3.1.) Although regulatory to comply with the safety and safeguards and responsibilities at the GDPs are divided between security standards established by NRC. To DOE and NRC, DOE maintains overall address this contingency, the EPAct permitted ownership responsibilities for the sites.

NRC to approve continued USEC operation of the GDPs if NRC approved DOE-prepared plans 3 DOE regulates nonleased areas at the GDPs for bringing the GDPs into compliance with any under DOE Orders and applicable PAAA unsatisfied provisions of the NRC regulations. On regulations. DOE regulates HEU-related November 26, 1996, NRC certified USEC's activities that occur in designated leased areas at operation of the GDPs to be in compliance with PORTS (i.e., in Buildings X-326 and X-705) 10 CFR 76 with the exception of the under the ROA. It will continue to regulate the noncompliances identified in the NRC-approved HEU-related activities in designated leased areas Compliance Plans. Following a transition period, under the ROA until (1) all the HEU material has NRC began regulation of most USEC operations been downblended (diluted) into LEU in the in the leased areas at the GDPs on March 3, 1997. PORTS LEU cascade, (2) HEU refeed activities are completed, (3) all cylinders that contain HEU DOE retains responsibility for the material are cleaned or shipped offsite, and environmental, safety, and health (ES&H) (4) the associated areas are transitioned to NRC protection and safeguards and security for the regulation. The HEU refeed activities in the portions of PGDP and PORTS that are not leased designated leased area of the X-326 Building to USEC and for those portions of PORTS that were completed and the area was transitioned to are leased to USEC that contain HEU material. NRC regulation in CY 1998. All designated Thus, at PGDP, regulatory oversight leased areas where HEU-related activities occur responsibility is divided into two programs: are scheduled to transition to NRC regulation by (1) NRC oversight of leased areas and (2) DOE April 30, 2000. However, DOE will continue to oversight of nonleased areas. At PORTS, regulate indefinitely any "as-found" HEU regulatory oversight responsibility is divided into material in leased areas at PORTS under the three programs based on the location and type of ROA.

activity being performed. These consist of (1) NRC oversight of leased areas, (2) DOE At the same time, NRC regulates USEC oversight of leased areas involving HEU, and operations in the leased areas according to 10 CFR 76, other applicable NRC regulations, the USEC certification applications, and the certificates of compliance issued to USEC by NRC. Currently, the areas regulated by NRC at the GDPs comprise a much larger portion of the operations than those regulated by DOE.

'The DOE-prepared plans, entitled Planfor Achieving Compliancewith NRC Regulations at the PaducahGaseous Plantand Planfor Achieving Compliance with NRC Regulations at the Portsmouth Gaseous Diffusion Plant,are commonly referred to as the Compliance Plans.

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1.2 MEMORANDUM OF 2. DOE REGULATORY OVERSIGHT UNDERSTANDING PROGRAM STATUS In October 1997, DOE and NRC signed a Although NRC assumed regulatory oversight Memorandum of Understanding (MOU) entitled responsibility for the majority of the leased areas Memorandum of UnderstandingBetween the of the GDPs on March 3, 1997, DOE retains Departmentof Energy and the Nuclear nuclear safety and safeguards and security Regulatory Commission-CooperationRegarding oversight authority under Exhibit D of the Lease the Gaseous Diffusion Plants. This MOU, which Agreement (i.e., the ROA) for the limited number replaced a previous MOU for the interim period, of operations in the leased, but not NRC-certified, defines the responsibilities of DOE and NRC areas at PORTS that involve HEU material.4 regarding continuing cooperation at the GDPs During FY 1999, these operations involved after NRC assumption of regulatory oversight dispositioning excess HEU by cleaning cylinders responsibility for USEC activities. The MOU also that contained residual amounts of HEU and clarifies the framework for coordination downblending the HEU byproduct into LEU in regarding issues that may involve DOE and NRC segregated areas of Building X-705. The leased, areas of responsibility. According to this MOU, but not certified, portions of PORTS that remain DOE not only remains responsible for regulatory under DOE regulatory oversight authority are oversight of the HEU-related activities at PORTS scheduled to be transitioned to NRC regulation that take place in designated leased areas [i.e., in by April 30, 2000, or when USEC certifies that Buildings X-326 (now complete) and X-705] but the total quantity of special nuclear material also will continue to review and, where (other than inaccessible residual holdup) within appropriate, approve USEC-proposed all leased areas is within the possession limits in modifications to the PGDP and PORTS the NRC certificate of compliance for USEC Compliance Plans before their submittal to NRC operations at PORTS During FY 1999, actions for final approval. In addition to the recogi-.tion were taken to extend DOE's regulatory oversight of these continuing DOE responsibilities, DOE authority under the ROA to include (1) the and NRC (1) agreed to exchange information and federal arming and arrest authority for the plant technical support, (2) defined responsibilities for protective forces at the GDPs and (2) activities emergency response, (3) described the manner in associated with uranium enriched to greater than which issues identified during an inspection by or equal to 10% assay 235U discovered or made either agency would be referred to the other, and accessible in the USEC-leased portions of (4) defined responsibilities for coordination of PORTS. (See Sections 5.1.1 and 5.1.3.)

activities. The security roles and responsibilities of DOE and NRC after NRC assumption of The DOE Oak Ridge Operations (ORO) regulatory oversight responsibility for USEC Regulatory Oversight (RO) Manager manages the activities are defined in the Agreement Defining DOE RO Program for the (1) leased, but not Security Responsibilitiesat the Paducah and certified, portions of PORTS that contain HEU Portsmouth Gaseous Diffusion Plants Between the Department of Energy's Office of Safeguards and Security andthe Nuclear Regulatory 4 The NRC Certificates of Compliance for PGDP and Commission, which DOE and NRC formalized in PORTS limit USEC's possession of enriched uranium. At March 1995. each site, possession of uranium enriched to 20% or greater in 235U is limited to less than 1000 grams; possession of uranium 23 enriched to 10% or greater, but less than 20%, in

..U is limited to less than 10,000 grams.

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material enriched to greater than or equal to 20% off-site consequences and are serious or recurring violations. Severity Level III violations are assay . 35U and (2) the leased portions of PORTS that contain accessible uranium enriched to significant violations that do not indicate any greater than or equal to 10% assay 235U. In the overall degradation in nuclear safety or near future, the RO manager will manage safeguards and security programs. Corrective activities at both GDPs related to the federal actions associated with both cited and noncited arming and arrest authority for the protective violations are tracked to closure by the DOE force personnel: The RO Manager schedules and SSR.

coordinates all RO Program activities, including inspections and enforcement actions. The RO During FY 1999, DOE conducted more than Manager is authorized to modify the ROA 60 inspections of activities in the leased, but not whenever he/she determines that changes are certified, portions of PORTS. The majority of required either to protect public health and safety these inspections were routine announced and or to promote the common defense and security. unannounced inspections conducted by the DOE (The ROA also includes a change control process SSR primarily in the X-705 decontamination and whereby USEC may propose changes to the uranium recovery facility where HEU cylinder ROA.) In addition to DOE staff in Oak Ridge, the cleaning is performed. These DOE inspections RO Program maintains a DOE site safety focused primarily on the following functional representative (SSR) at PORTS. This SSR areas of plant operations related to HEU provides day-to-day surveillance and inspection activities: Managerial Controls and Oyersight, of HEU-related activities to help assure USEC's Operations, Radiation Protection, Nuclear compliance with the ROA. Criticality Safety (NCS), Emergency Preparedness, and Security. During these Sections 2.1 through 2.4 discuss the activities inspections, DOE selectively examined of the DOE RO Program in FY 1999. procedures and records, interviewed personnel, and observed activities in progress. These inspections included examination of one event 2.1 INSPECTIONS report related to a December 9, 1998, fire in the X-326 building; 65 HEU-related problem reports; DOE conducts routine, special, and and the follow-up of previously identified functional area inspections in the leased, but not inspection findings.

certified, facilities at PORTS. In accordance with the ROA, DOE may issue NOVs and impose civil In FY 1999, DOE issued one NOV to USEC.

penalties if these inspections identify ROA This violation involved failures to adhere to NCS violations. The amount of a civil penalty is based labeling and spacing requirements in the 5-inch on the severity of the violation. The DOE RO cylinder cleaning area of the X-705 West Annex Manager assigns one of three severity levels to at PORTS. This violation was categorized as a the violations. Severity Level I violations are Severity Level III violation. In addition, three violations that significantly increase the hazard to noncited violations were issued to USEC during this period. Two of the noncited violations plant workers or the risk of off-site consequences; they are the most serious violations. Severity involved NCS posting and marking requirements Level II violations are violations that moderately in the X-705 West Annex. The other noncited increase the hazard to plant workers or the risk of violation involved multiple examples of 5

emergency preparedness deficiencies related to Operations Center, the Joint Public Information Facility Emergency information packets in the Center, and the field. The exercise simulated an X-705 West Annex. Because of USEC's prompt emergency response to two fires located in the and aggressive corrective actions, DOE exercised X-333 building at PORTS. A report on the enforcement discretion by categorizing these performance of the exercise was pending at the violations as noncited violations and encouraged end of FY 1999.

USEC to continue self-identification and prompt remediation of any noncompliances. Because these violations were identified in a shared area at 2.2 SAFETY EVALUATIONS AND PORTS, DOE notified NRC in accordance with OPERATIONAL READINESS the October 1997 MOU. The DOE inspections, ASSESSMENTS inspection reports, and NOV issued for activities in leased, but not certified, facilities at PORTS Section 3.3.2.6 of the ROA requires USEC to are summarized in Appendix A, "Summary of obtain DOE consent and written approval for any DOE Regulatory Oversight Program Inspection proposed plant change that involves an Reports." Unreviewed Safety Question or a change in the authorization basis for USEC operations at In February 1999, DOE conducted a special PORTS regulated by DOE. The safety evaluation review of the Emergency Preparedness program report development process specified in DOE under DOE's ROA jurisdiction at PORTS. Heater Order 5480.23, Nuclear Safety Analysis Reports, equipment fires in the X-705 facility and the is used by the DOE RO Manager to document December 9, 1998, fire in the X-326 Building DOE approval of USEC's proposed plant changes prompted the DOE RO Manager to initiate this under Section 3.3.2.6 of the ROA.

review. Interviews of personnel and revieNs of training records, procedures, and other reh. vant During FY 1999, DOE prepared several programmatic elements were conducted. As a Safety Evaluation Reports (SERs) and one result of the noncited violation related to Operational Readiness Assessment (ORA) in emergency preparedness and findings of this response to USEC requests for approval of review, a follow-up inspection was conducted in changes in operations in the X-705 facility at March 1999. The noncited violation and all PORTS. In November 1998, DOE approved the inspection follow-up items related to the certification of two additional First Line February 1999 special review were reviewed and Managers for the chemical cleaning of HEU closed following prompt USEC corrective cylinders in the X-705 facility at PORTS. DOE actions. issued a revised SER entitled Departmentof Energy Safety EvaluationReportfor the In September 1999, DOE participated in a PortsmouthGaseous Diffusion Plant,Cleaning of Full Participation Emergency Management 5-inch, 8-inch, and 12-inch Highly Enriched exercise at PORTS. The exercise involved federal Uranium Cylinders and Blending of HEU Heel (i.e., DOE and NRC), state, and local agencies as Material in the X- 705 Building to document this well as site contractor organizations responsible approval. In August 1999, DOE approved an for operations at PORTS. During the exercise, increase in the 235U mass, allowed in an 8-inch DOE observed activities in the Emergency HEU cylinder during cleaning, from 1,350 to 6

1,500 grams. An SER entitled Department of 2.3 SAFEGUARDS AND SECURITY Energy Safety Evaluationfor the Portsmouth ACTIVITIES Gaseous Diffusion Plant,8-Inch Cylinder U2s5 Heel MaterialGram Limit Increase in the X-705 2.3.1 Arming and Arrest Authority Building documented this approval.

In the FY 1999 Energy and Water In September 1999, DOE evaluated a USEC Development Appropriations bill,5 Congress proposed "heel" reduction process for HEU amended the USEC Privatization Act to address cylinders using the Special Applications Portable the federal arming and arrest authority of the Infrared Analyzer (SPIRA) buggy equipment and plant protective forces at PGDP and PORTS.

issued an ORA entitled Departmentof Energy DOE is in the process of implementing these OperationalReadiness Assessment Reportfor amendments to the Privatization Act by assuming Heel Reduction in Highly EnrichedUranium regulatory authority for the plant protective force Cylinders at the Portsmouth Gaseous Diffusion activities under the provisions of the ROA to the Plant,dated September 10, 1999. The heel extent required to permit DOE to issue Weapons reduction process involves (1) using the SPIRA Authorization Cards (WAC). These cards, issued buggy equipment to add nitrogen, fluorine and/or pursuant to the AEA of 1954, as amended,6 will chlorine tri-fluoride gases to an 8-inch cylinder authorize protective force personnel to carry containing more than the allowable 235U mass of firearms and, in certain specified situations, to 1,500 grams and (2) collecting uranium make arrests at the GDPs.

hexafluoride (UF6) into a 5-inch cylinder, thus reducing the heel mass in the 8-inch cylinder. During FY 1999, the focus of the DOE approved the use of this heel-reduction implementation effort was at PGDP, where process in the West Annex of the X-705 facility protective force personnel do not have federal with an SER entitled Departmentof Energy arming and arrest authority. At PORTS, the Safety Evaluationfor the Portsmouth Gaseous protective force personnel currently have federal Diffusion Plant,SpecialApplications Portable arming and arrest authority under DOE for InfraredAnalyzer Buggyfor 8-Inch Cylinder U23s protection of Categories I and II special nuclear Heel MaterialRemoval in the X- 705 Building, materials. However, when these materials are dated September 10, 1999. removed from the PORTS site in the near future, the federal arming and arrest authority for the These SERs and ORA are part of the safety PORTS protective force personnel will transition basis for DOE approval of continued operations to regulation under the ROA, as at PGDP. The by USEC in leased, but not certified, areas at NRC intends to promulgate rule making for PORTS regulated by DOE. The DOE SERs and nuclear facilities giving NRC authority and ORA provide assurance that USEC operations in responsibility to issue federal arming and arrest these areas of PORTS are conducted in authority under the AEA. When the NRC accordance with nuclear safety and safeguards assumes this responsibility, the use of the ROA and security requirements of the ROA. for DOE oversight of implementation of this Congressional legislation will cease.

During FY 1999, DOE also performed several other safety evaluations associated with the DOE review and approval of USEC-requested 5 Pub. L. No. 105-245, October 7, 1998.

changes to the Compliance Plans. (See Section 2.4.) 6 Codified at 42 U.S.C. 220 1(k).

7

A revision to Section 3.18, "Security," of the In August 1999, DOE approved the Security ROA, was issued in April 1999. This revision Plan entitled Arming andArrest Authority identifies the DOE requirements that USEC must Security Planfor the Paducahand Portsmouth meet for DOE to issue WACs at PGDP and Gaseous Diffusion Plants, Revision 0, that PORTS. After a DOE assessment of the USEC establishes the USEC program for the protective protective force program at PGDP, USEC force personnel at the GDPs to meet the revised provided a Security Plan to DOE entitled Arming DOE ROA requirements related to the arming and Arrest Authority Security Planfor the and arrest authority as described in Section 2.3.1.

Paducahand Portsmouth Gaseous Diffusion Plants,Revision 0, in July 1999 to meet the During FY 1999, DOE reviewed and revised Section 3.18 requirements of the ROA. approved a revised USEC Personnel Security DOE approved the USEC Security Plan in Assurance Program (PSAP) that incorporated August 1999. Following a DOE assessment of the DOE comments and implemented DOE's PSAP implementation of the USEC Security Plan, DOE requirements at PORTS. However, following the will issue an updated ROA revision and WACs to reduction in the quantities of HEU at PORTS and the protective force personnel at PGDP in early the downgrading of the X-345 facility to a FY 2000. Category III facility (see Section 5.1.3), PSAP requirements were no longer needed at PORTS.

2.3.2 Security Plans Therefore, in September 1999, USEC terminated the PSAP program.

In partial fulfillment of DOE's responsibilities under the December 1993 Joint Statement of Understanding 7 between NRC and 2.4 COMPLIANCE PLAN ACTIVITIES DOE, the DOE RO Program Manager is responsible for review and approval of USEC Following the promulgation of 10 CFR 76, it Safeguards and Security Plans and related became apparent that there were portions of the information applicable to activities conducted regulations with which USEC could not under the ROA. The DOE oversight ensures that immediately comply. For NRC to permit appropriate safeguards and security controls are continued USEC operation of the GDPs, the in place for these activities at the GDPs. EPAct required that DOE prepare plans for bringing the leased areas of the GDPs into In May 1999, DOE approved the X- 705 compliance with any unsatisfied provisions of Security Plan, Revision 2, to incorporate changes NRC regulations. The existence of these that were required to recategorize and protect the noncompliances does not indicate a difference in nonleased X-705 E-area as a DOE Category IV the overall level of health, safety, and safeguards area and to remove one material surveillance and security protection provided to workers and requirement for the leased, but not certified, the public under DOE oversight versus that X-705 West Annex as a DOE Category III area. provided under NRC oversight. Rather, these noncompliances reflect either (1) areas where full compliance with existing DOE requirements had not been achieved or (2) differences between the 7

Joint Statement of UnderstandingBetween the Nuclear NRC and DOE regulatory approaches used to Regulatory Commission and the Department of Energy on ensure adequate protection of the health and Implementing the Energy Policy Act Provisionson safety of workers and the public and to promote Regulation of Gaseous Diffusion Uranium Enrichment Plants. (See Section 5.1.)

the common defense and security.

8

DOE prepared Compliance Plans8 for reopening of a few original Compliance Plan submittal with the USEC applications for initial issues have been requested by USEC through certification of PGDP and PORTS. These plans Certificate Amendment Requests to the NRC in were initially submitted to NRC on April 24, FY 1999.

1995. Revisions to accommodate USEC application changes and commitments to NRC The dates by which compliance with NRC were submitted through August 1996.9 Final regulations will be achieved range from 1996 applications were submitted by USEC to NRC in through 2002 for the various noncompliances, August 1996, and NRC issued the initial depending on the specific upgrade actions that are Certificates of Compliance to USEC on required. During the fall of 1996 and continuing November 26, 1996. On April 15, 1998, USEC through February 1997, DOE verified completion submitted applications for renewal of the initial of approximately half of the actions required to Certificates of Compliance for PGDP and achieve compliance. On February 24, 1997, DOE PORTS. In the second quarter of FY 1999, NRC advised NRC that it had reviewed those action issued the first renewal of the Certificates of items scheduled for completion prior to March 3, Compliance to USEC. 1997 (with the exception of action items that had been delayed by USEC). When NRC assumed The Compliance Plans address the regulatory oversight on March 3, 1997, additional noncompliances identified by USEC before Compliance Plan issues were completed by certification and provide the following: (1) a USEC as part of the transition. Responsibility for description of the noncompliance, (2) a reference reviewing and verifying completion of all to USEC's application commitment with wh; ;h remaining open actio.. items in the Compliance USEC had not yet complied, (3) a justification for Plans transferred to N RC at that time.

continued operations, and (4) a descriptiop )f the plan of action and schedule for achieving In the October 1997 MOU between DOE and compliance with NRC regulations. The NRC (described in Section 1.2 of this report),

Compliance Plans were revised as USEC revised both parties agreed that USEC must obtain DOE its applications and identified additional approval of any modifications to the Compliance noncompliances.' 0 No new Compliance Plan Plans before submittal of the requested issues were identified in the April 15, 1998, modifications to NRC for review and final applications for renewal of certification to approval. As illustrated in Table 1, during operate, although modifications to and the FY 1999, DOE reviewed 11 USEC-submitted change requests including the reopening of three Compliance Plan issues at PORTS. Following a

'See Footnote 3. review period, and in some cases, on-site safety evaluations, DOE approved all changes requested

'NRC's initial certification of USEC's operation- at in FY 1999.

each GDP was based on USEC's application for certification, which included Rev. 3A of the DOE-prepared Compliance Plan for each GDP.

3. LEASE MODIFICATIONS "0For a discussion on the types of noncompliances, the reader is referred to the report entitled Department of Energy As stated previously, pursuant to the EPAct, Input to-the Nuclear Regulatory Commission's Annual Report to Congress Regardingthe Status of Health, Safety, DOE leased portions of PGDP and PORTS to and Environmental Conditionsat the Paducahand USEC on July 1, 1993. DOE and USEC Portsmouth Gaseous Diffusion Plants, DOE/ORO/2059, subsequently agreed that DOE, in its role as dated October 1997.

9

Table 1. Modified Compliance Plan Issues Approved by DOE in FY 1999 Plant Issue Title Date Approved PORTS A.4 Possession of Uranium Enriched to 10/13/98 Greater Than 10% 235U PGDP 46 Criticality Accident Alarm System - Horn 10/29/98 Audibility PGDP 50 Criticality Accident Alarms for Nearby 10/29/98 Buildings PORTS A.2 Receipts Based on Measured Values 12/14/981 PGDP 36 Seismic Capability of Buildings C-331 1/8/99 and C-335 PORTS 8R12 Nuclear Criticality Safety Approval 4/14/99 Documents PORTS 9R Nuclear Criticality Safety Approval 4/14/99 Implementation PORTS 23R Plant Changes and Configuration 4/14/99 Management PORTS 8R13 Nuclear Criticality Safety Approval 5/5/99 Documents PORTS 23R14 Plant Changes and Configuration 5/10/99 Management PORTS 5 23R Plant Changes and Configuration 5/12/99 Management "Approved by the DOE RO Program; however, it was noted that there may be HEU Transparency Implementation Program implications associated with this request, and the issue was referred to the head of the DOE HEU Transparency Implementation Program for final approval.

"" R " indicates that the Compliance Plan Issue was reopened and included a modified Description of Noncompliance to reflect the current status of the noncompliance, a Justification for Continued Operations, and a Plan of Action and Schedule.

"3This Compliance Plan modification was requested after the initial DOE approval; DOE reviewed the requested modification and approved it.

"4 See Footnote 13.

"5 See Footnote 13.

10

landlord of the leased facilities at the GDPs, 4. DOE ENVIRONMENTAL, SAFETY, AND would maintain the controlled copy of the Lease, HEALTH POLICY including the facility lease status drawings and the DOE Material Storage Area (DMSA) A fundamental policy of DOE is that work at drawings. On December 30, 1998, Revision III of its sites, including the nonleased portions of Exhibit A to the Lease, which identifies leased PGDP and PORTS for which DOE has oversight areas at both GDPs, was approved. Revision I of responsibility, must be conducted in a manner the PaducahGaseousDiffusion PlantFacil.iy that (1) protects the safety and health of the Lease Status drawing, No. C5EC90000A046, and workers and the public and (2) safeguards the Revision I of the Portsmouth Gaseous Diffusion environment. Attention to ES&H concerns, PlantFacilityLease Status drawing, No. therefore, is an integral part of DOE's planning, CX-761-1040.01-A, were approved and signed in budgeting, and work activities. Within DOE, May 1999. Major changes to Exhibit A and the functional areas have been established to help lease status drawings include the following: DOE sites implement an overall ES&H program.

To assist in ES&H program implementation, nine

"*Deleasing approximately 198 acres (formerly safety and health and seven environmental common ground) to DOE at PGDP. functional areas have been defined.

"*Deleasing the C-200A Security and Fire Safety and Health FunctionalAreas. These Training Trailer to DOE at PGDP. functional areas include site activities that are directed toward protection of the health and

"*Deleasing the C-616-E Chromium Sludge safety of the public and employees and that are Lagoon to DOE at PGDP. required by federal, state, regional, or local law or regulation; Executive Order; or DOE Order.

"*Deleasing approximately 476 acres (formerly common ground) to DOE at PORTS. " Emergency Preparedness-includes all activities that are intended to provide the final

"*Deleasing the X-106 Fire Training Building at barrier for ensuring the safety and health of PORTS. workers and the public and for protecting property and the environment in the event of an

"*Color coding the perimeter roads, access roads, emergency.

and railroads at both GDPs on the facility lease status drawings to reflect these areas as "*Fire Protection-includes all activities that are common ground leased to USEC. intended to prevent, detect, and suppress fires.

The deleased acreage at the GDPs was " Industrial Hygiene-includes all activities that determined by USEC to be nonessential to are intended to provide protection to workers uranium enrichment operations. Upon deleasing, from chemical, physical, biological and regulatory responsibility for this acreage returned physiological hazards.

to DOE from NRC.

"*Industrial Safety-includes all activities that are intended to protect workers from occupational injury and illness.

I1

"*Occupational Medical Services-includes all " Protection of Water Quality-includes activities activities that are intended to provide a relating to compliance with the Clean Water comprehensive occupational medical program. Act and the Safe Drinking Water Act to protect groundwater and surface waters.

"*Nuclear Safety-includes all activities that serve to maintain or improve the level of safety " Environmental Restoration-includes activities involved with radioactive and fissionable whose primary purpose is compliance with materials that exist in such form and quantity regulations promulgated under Comprehensive that a nuclear hazard potentially exists to the Environmental Response, Compensation, and employees or the general public. Liability Act (CERCLA), the Superfund Amendments and Reauthorization Act, or

"*Radiation Protection-includes all activities Resource Conservation and Recovery Act that are intended to control exposures of (RCRA) for remedial investigation and workers and the public to radioactivity. remedial actions required to clean up radioactive, hazardous, or mixed waste

"*Transportation Safety-includes all activities contamination.

that are intended to ensure safe packaging and transportation. " Pollution Prevention and Waste Minimization-includes all sitewide and facility

"*Management and Oversight-includes all waste generator-specific activities that are activities that are intended to coordinate, direct, predominantly associated with waste integrate, and control safety and health minimization and pollution prevention.

activities across multiple safety and health functional areas of a facility's ES&H program. " Waste Management-includes those activities addressing the treatment, storage, and disposal EnvironmentalFunctionalAreas. These of wastes.

functional areas include site activities that are directed toward protection of air, water, and other " Management, Oversight, and Reporting environmental media and that are required by includes those activities that are intended to federal, state, or local law or regulation; coordinate, direct, and integrate environmental enforcement action (including NOVs); activities across multiple environmental Compliance Agreement; Executive Order; or functional areas.

DOE Order.

DOE's ES&H policy demonstrates DOE's Protection of Air Quality-includes activities commitment to protect and promote the health designed to assess and monitor air quality and and safety of its workers and the public and to to control air contaminant emissions in protect the environment. In those areas at the compliance with the Clean Air Act. GDPs for which DOE retains regulatory oversight responsibility, DOE applies its ES&H policy

• Control of Toxic Substances-includes through the Integrated Safety Management activities that comply with federal, state, or System (ISMS) program of its management and local regulations to control the use and integration (M&I) contractor. Organizationally, management of materials regulated because of DOE personnel at PGDP and PORTS consist of a their known or suspected toxic or hazardous Site Manager and staff who provide site characteristics. management and oversight.

12

Section 5 of this report presents DOE's reduction and removal from PORTS, as described ES&H initiatives, and Section 6 presents the in Sections 5.1.1, 5.1.2, and 5.1.3. Activities status of ES&H conditions for those portions of conducted to support the HEU Purchase the GDPs for which DOE had oversight Agreement between DOE and the Russian responsibility during FY 1999. Federation through HEU transparency activities performed at PGDP and PORTS are described in Section 5.1.4.

5. DOE ENVIRONMENTAL, SAFETY, AND HEALTH INITIATIVES 5.1.1 Highly Enriched Uranium Agreements The following sections provide an overview On April 20, 1998, pursuant to the of the ES&H initiatives undertaken to address requirements of the USEC Privatization Act, specific situations at the PGDP and PORTS sites. DOE and USEC entered into an MOA entitled Section 5.1 describes the manner in which DOE Memorandum of Agreement for Transfer of owned HEU materials at the PORTS site are Natural Uranium andHighly EnrichedUranium dispositioned, while Section 5.2 describes DOE's andfor Blend-down of Highly EnrichedUranium.

planned approach for handling and disposing of This MOA describes the manner in which "DOE the large quantities of DUF 6 for which it is shall transfer to USEC without charge up to 50 responsible. Section 5.3 describes uranium metric tons of enriched uranium and up to 7,000 management activities, including the new tons of natural uraniL.n from DOE's stockpile."

Uranium Management Center, which is being The MOA also describes the manner in which developed to assist DOE in managing its uranium DOE will transfer and USEC will accept the inventory. Section 5.4 discusses other ES&H uranium and defines the DOE and USEC initiatives, including the implementation of the safeguards and security responsibilities for ISMS program at the two sites. enriched uranium. In the MOA, DOE and USEC agree that 7 metric tons of HEU oxides at PORTS will be available for delivery no later than the end 5.1 HIGHLY ENRICHED URANIUM of FY 1999. Shipment of these HEU oxides from DISPOSITION PORTS was completed in June 1999.

In November 1991, the Secretary of Energy On January 8, 1999, the USEC and DOE directed the suspension of HEU production at Agreement for Disposition of Uranium Enriched PORTS, which was the only remaining facility in to Ten (10) Percentor GreaterAssay at the the United States producing HEU. As a result of Portsmouth Gaseous Diffusion Plant (PORTS) past HEU production, excess HEU material was signed. This agreement states that "USEC remained in storage at PORTS. DOE retains cannot, at any time, possess quantities of uranium responsibility for this excess HEU as reflected in that will cause the total quantity to exceed the December 1993 Joint Statement of Nuclear Regulatory Commission (NRC) Category UnderstandingBetween the NuclearRegulatory III limits. This requirement is in effect the entire Commission and the Departmentof Energy on time the NRC Certificate of Compliance is in Implementing the Energy Policy Act Provisions effect." This agreement supplements the on Regulation of Gaseous Diffusion Uranium December 1993 Joint Statement of Understanding EnrichmentPlants.Regarding the ultimate between NRC and DOE in which, in the case of disposition of this excess HEU, DOE efforts 20% or greater assay 235U, "DOE retains title to during FY 1999 have been directed toward its and possesses such uranium and will be solely 13

responsible for providing for, establishing, and enriched to 10% or greater in 2 35U, approximately maintaining nuclear safety, safeguards and 370 (5-inch-, 8-inch-, and 12-inch-diameter) security controls applicable to such uranium." cylinders are scheduled to be cleaned at PORTS The agreement was entered into by DOE and by March 31, 2000. Because of operational start USEC "to provide a framework for the efficient up difficulties, USEC requested and DOE and and cost effective management and disposition of NRC approved an extension to the Compliance 235 uranium enriched to 10% or greater assay U at Plan date for completion of the cylinder cleaning the Portsmouth gaseous diffusion plant from December 31, 1998, to March 31, 2000.

(PORTS)." (See Section 2.4.) Approximately 940 other HEU cylinders have been cleaned off-site at a 5.1.2 Highly Enriched Uranium Refeed and contractor's facility.

Cylinder-cleaning Program Under DOE regulatory oversight, HEU The HEU refeed program at PORTS was cylinder cleaning commenced at PORTS in completed in July 1998. The purpose of the HEU May 1998. Of the 367 cylinders that were refeed activities was to downblend excess HEU required to be cleaned to meet the Compliance in the form of UF 6 gas into LEU to be sold Plan commitment, one-hundred-three 5-inch, commercially for peaceful purposes. The FIEU, sixty-four 8-inch, and fourteen 12-inch (i.e. a which originally was produced for U.S. military total of 181) cylinders have been cleaned by purposes during the Cold War, was declared USEC by the end of FY 1999. In May 1999, excess to the nation's defense needs. In the USEC began using multishift operations to December 1994 MOA between DOE and USEC expedite cleaning of the remaining HEU entitled Memorandum ofAgreement Relating to cylinders. The USEC HEU refeed and cylinder the Transfer of Functionsand Activities from the cleaning and the DOE HEU suspension and Departmentof Energy to the United States removal efforts (see Section 5.1.3) support the Enrichment Corporation,both parties agreed that overall effort to remove stored HEU from the DOE would provide this material to USEC for PORTS site.

refeed and downblending.

A byproduct of the cylinder-cleaning process Approximately 14 metric tons of HEU were is uranyl nitrate solution. USEC downblends this safely refed into the enrichment cascade and solution to less than 10% 235U enrichment in the downblended into LEU by USEC from May 1995 West Annex of Building X-705 under DOE to July 1998. This amount represented a regulatory oversight. USEC then processes the significant reduction in the quantity of HEU at uranyl nitratesolution for final disposition in the PORTS. After refeeding, the HEU cylinders leased portion of the X-705 facility under NRC contained small residual quantities of HEU (heel) regulatory oversight.

material. These cylinders are being chemically cleaned to remove the heel material for 5.1.3 Highly Enriched Uranium Suspension downblending and disposition. The HEU cylinder and Removal Program cleaning effort is conducted in designated leased, but not certified, portions of Building X-705 at The DOE HEU Suspension and Removal PORTS under DOE regulatory oversight. Program addresses the overall disposition of HEU at PORTS. This program is designed to To complete a Compliance Plan commitment accomplish the following: (1) safely suspend related to USEC's possession limits for uranium HEU operations and shut down HEU equipment 14

in Building X-326; (2) modify equipment and were met. Surveillance and maintenance of the systems to preclude production of HEU and 158 shutdown cells continues. Periodic perform maintenance in X-326 that is necessary nondestructive assay surveys are being performed for continued LEU production ("legacy to ensure that no unacceptable migration of maintenance"); (3) modify the configuration of remaining inaccessible HEU deposits occurs.

shutdown equipment to minimize long-term surveillance and maintenance requirements; and DOE continued to implement the plan for the (4) remove stored HEU materials from PORTS, disposition of HEU-bearing materials that it including uranyl nitrate hexahydrate-, uranium issued in March 1996. In late 1997, oxide-, and HEU-contaminated materials. The approximately 400 kg of uranium oxides were removal of these stored HEU materials will shipped to the Oak Ridge (Tennessee) Y- 12 Plant reduce the related ES&H risks and is expected to for interim storage. The remaining uranium reduce safeguards and security operating costs at oxides stored in the X-345 facility (about PORTS. 7 metric tons) were authorized for shipment to a commercial downblending facility under an As described previously, portions of the HEU approved MOA between DOE and USEC. (See Suspension and Removal Program are regulated Section 5.1.1.) On August 31, 1998, USEC by DOE under the ROA. Three PORTS facilities selected a downblending vendor. Shipment of the are directly affected by the HEU Suspensio- and HEU oxides, which started on September 15, Removal Program. These facilities include the 1998, was completed on June 23, 1999..

X-326 process facility, where HEU refeed activities are complete; the X-705 In February 1998, a large portion of the HEU decontamination and uranium recovery facility; bearing materials classified as RCRA waste that and the X-345 special nuclear material storage was previously stored in the X-326 L-Cage facility. Buildings X-326 and X-705 are critical to facility was shipped to Los Alamos National the ongoing LEU mission; therefore, USEC Laboratory (LANL) for treatability studies.

leases these facilities from DOE. HEU-related Because LANL was unable to complete the activities in these buildings continue to be treatability studies within the RCRA-regulated regulated by DOE under the ROA. Building 1-year time limit required by the New Mexico X-345 is retained by DOE. Activities that are Environmental Department, LANL returned 68 conducted in this building are regulated in containers of i{EU mixed waste to PORTS in accordance with DOE Orders and PAAA June 1999. The treatability studies report has not regulations. been received from LANL, and no additional studies are planned. The 68 containers will Operations related to removing HEU-bearing continue to be stored in the X-326 L-Cage facility materials from cascade equipment in Building at no additional safeguards and security operating X-326 and downblending these materials to LEU cost until final disposition.

(HEU suspension) are complete. After removal of HEU-bearing materials from approximately 200 A large portion of HEU-bearing material that cells in the cascade to deposit sizes below "safe is not classified as RCRA waste, consisting mass" as determined by NCS analysis, 158 cells largely of HEU trapping materials, was shipped were placed in permanent shutdown condition. to a contractor for HEU recovery and The permanently shutdown HIEU cells in downblending to LEU for possible resale. These Building X-326 were buffered with dry shipments were completed in January 1998, and air/nitrogen to ensure that NCS requirements processing was completed in December 1998.

15

Commercial sale of the downblended LEU USEC equipment, containers, and material product is scheduled to be completed by June 30, containing uranium enriched to 10% or greater in 2000. At that time, any remaining LEU product 235U that resulted from DOE legacy operations at will be returned to PORTS for storage and PORTS. Under NRC regulation, USEC cannot, at eventual sale. any time, possess quantities of uranium that will cause the total quantity possessed by USEC In April 1999, an initiative of the President across all leased and certified areas to exceed and Secretary of Energy was established to NRC Category III limits. Because DOE has remove remaining stored quantities of DOE regulatory jurisdiction over accessible uranium owned HEU-bearing materials to permit enriched to 10% or greater in . 35U, activities downgrading of the X-345 facility to a Category involving this material in USEC-leased areas will III security level by September 30, 1999. This be conducted in accordance with the ROA. HEU initiative involved the shipment of UF6 contained related activities in nonleased facilities (e.g.,

in hoke tubes and 2-S and 5A/5B type cylinders enriched uranium in DMSAs) will continue to be to a contractor for interim storage. This initiative conducted in accordance with the nuclear safety also included the removal of HEU-bearing and safeguards and security requirements of the materials from in-place traps in the X-345 High DOE Orders and PAAA regulations applicable to Assay Sampling Area and the shipment of these such uranium. Also, in the January 8, 1999, materials to the interim storage contractor. A agreement, DOE agreed to accept USEC-owned large portion of the materials covered by this or -leased equipment, containers, and material initiative are standards for nuclear material containing uranium enriched to 10% or greater in accountability equipment calibration being held 235U provided that such acceptance will not until the end of the HEU Suspension and violate DOE standards, DOE Orders, U.S.

Removal Program and for possible use under the Environmental Protection Agency (USEPA)

HEU Transparency Implementation Program. regulations, or Ohio EPA regulations or orders.

Shipments to the interim storage contractor were Storage normally will be in enriched uranium completed on August 18, 1999. DMSAs or other DOE areas meeting appropriate regulatory and safeguards and security Following the removal of stored HEU requirements. DOE has also agreed to store up to materials, DOE's M&I contractor conducted a 3,000 liters of liquid cleaning solutions that are confirmatory survey of the X-345 facility to generated from equipment cleaning operations determine the location and quantity of any and that are not regulated as hazardous waste remaining residual material. The results of the under RCRA until USEC can dispose of the confirmatory survey were provided to DOE for liquid.

review and approval. Upon receipt of DOE approval, the X-345 facility was downgraded to a 5.1.4 Highly Enriched Uranium Transparency Category III facility on September 27, 1999. Implementation Program Under the provisions of the January 8, 1999, The HEU Transparency Implementation agreement between DOE and USEC regarding Program, originally established within DOE's HEU disposition,16 DOE will store and manage Office of Nuclear Energy, Science and Technology (NE), is responsible for implementing all transparency measures related 16USEC and DOEAgreement for Disposition of to the HEU Purchase Agreement between DOE Uranium Enriched to Ten (10) Percent or GreaterAssay at and the Russian Federation's Ministry of Atomic the Portsmouth Gaseous Diffusion Plant (PORTS).

16

Energy (MINATOM)."7 The HEU Government (through September 30), PORTS has received to-Government Umbrella Agreement was signed approximately 255 30B cylinders from Russian on February 18, 1993, and provides for the blending facilities. Since CY 1995, PORTS has purchase of 500 metric tons of lEU from received a total of 1,247 30B cylinders.

dismantled Russian weapons over a period of 20 years. Since the signing of this initial Under terms of the HEU Purchase agreement, an MOU, an HEU Purchase Contract, Agreement, DOE and MINATOM are allowed to and a Protocol to the MOU have been signed to establish Permanent Presence Offices (PPOs) at delineate terms of the agreement. In addition, a certain facilities where personnel can monitor total of 16 annexes to the Protocol have been prescribed activities to provide confidence that signed at Transparency Review Committee each side is abiding by the terms of the meetings. These annexes define the rights of each agreement. In the United States, MINATOM has party to provide confidence that each party is established a PPO at PORTS. Thus far, abiding by the terms of the agreement. MINATOM has maintained only a sporadic presence at PORTS, and no Russian delegation During the fall of 1998, the HEU has been at PORTS this fiscal year. However, Transparency Implementation Program direction office space is maintained and other services are was transferred from NE to DOE's Office of on standby to support this activity.

Nonproliferation and National Security (NN) to more formally recognize the program's alignment PGDP has played a key role in the testing and with NN's national security aspects. Within NN, demonstration of some nonintrusive the program reports to the Office of International instrumentation for monitoring UF 6 gas flow and Nuclear Safety and Cooperation. enrichment. This equipment was developed in DOE's national laboratories for installation in The GDPs have continued to play key roles in Russian blending facilities as a means of several aspects of the DOE HEU Transparency providing confidence that the downblending of Implementation Program. The HEU material HEU is actually occurring. To demonstrate the covered under terms of the agreement is sent to equipment in actual use to a Russian delegation, a the United States as LEU suitable for use as fuel UF 6 flow loop simulating the flow conditions in in light-water reactors. The HEU is blended with Russian blending facilities was fabricated and slightly enriched uranium in Russian facilities installed in the PGDP purge cascade. A high and shipped to the United States as LEU for sale level delegation consisting of U.S. Department of by USEC, which acts as agent for the U.S. State, DOE, Russian Federation Ministry of government. The material arrives at PORTS as Atomic Energy, Gosatomnadzor (equivalent to UF 6 in 30B cylinders,"8 in which it is stored until the NRC), and Ural Electrochemical Integrated its sale to utilities and subsequent shipment to Enterprise personnel visited PGDP in June 1998 fuel fabricators. During calendar year (CY) 1999 to witness the operation of the instrumentation.

This was the first visit of Russian Federation personnel to PGDP. After this successful demonstration, the UF 6 flow loop was removed "7Transparency measures are those measures employed from the PGDP purge cascade and the loop by DOE to provide confidence to the United States that the downblending of Russian HEU is occurring in accordance decontaminated and decommissioned in January with the agreement. 1999, thus completing PGDP's role in this phase of the project.

"8A 30B cylinder can contain a maximum net weight of approximately 2.3 metric tons of UF 6.

17

5.2 DEPLETED URANIUM Public scoping meetings were held to obtain HEXAFLUORIDE LONG-TERM public comments on DOE's proposed alternative MANAGEMENT management strategies to be addressed in the PEIS. DOE published the draft PEIS in DOE is responsible for approximately December 1997. Approximately 600 public 739,000 metric tons of DUF 6 located at PGDP, comments were received during the 120 day PORTS, and East Tennessee Technology Park public comment period. The PEIS examines the (ETTP). The DUF 6 is contained in approximately environmental consequences of alternative 61,000 cylinders, the majority of which are strategies of long-term storage, use, and disposal located at PGDP. While most cylinders have a of the DUF 6 inventory.

14-ton capacity, other smaller cylinders are also used to store the DUF 6. Although DOE maintains In April 1999, DOE published the Final an active cylinder management program, many of ProgrammaticEnvironmental Impact Statement the cylinders have shown evidence of external (PEIS)for Alternative Strategiesfor the Long corrosion. This corrosion is believed to be the Term Management and Use of Depleted Uranium result of past storage practices. DOE's current Hexafluoride. DOE's preferred management management program includes routine strategy, which was identified in the draft PEIS, inspections of the cylinders, performance of was modified based on public comments. DOE's cylinder maintenance and repairs as required, and preferred alternative involves converting the painting of cylinders. DOE's previously existing DUF 6 inventory as soon as possible, either to DUF 6 management plan provided for DOE to uranium oxide, uranium metal, or a combination continue safe storage of the cylinders, use the of both, while allowing for use of as much of the DUF 6 should a feasible alternative be found, and, inventory as possible.'9 The PEIS examined if no use had been found for the DUF 6 by 2010, DOE's management strategy for DUF 6 and the to take steps to convert the DUF 6 to triuranium potential environmental impacts of various octaoxide (U 30 8 ). Under this plan, the conversion alternatives to that strategy. The basic was estimated to commence in 2020, and U30 8, a alternatives analyzed included (1) no action, more chemically stable compound representing a (2) long-term storage as DUF 6 at a consolidated lower ES&H risk, would be stored until a site, (3) long-term storage as uranium oxide at a determination was made that it should be consolidated site, (4) use as uranium oxide, disposed of as a low-level radioactive waste. (5) use as uranium metal, and (6) disposal as uranium oxide. For those alternatives that involve 5.2.1 Final Programmatic Environmental the conversion of DUF 6, hydrogen fluoride would Impact Statement be produced that could be sold for commercial 20 use.

Stakeholders near the sites, however, have expressed concerns regardingthe plan to delay conversion of the DUF 6 until 2020. In addition, because the perceived demand for potential uses of the uranium has diminished and because DOE "9 DOE does not anticipate conversion to uranium metal is no longer responsible for the production of unless a use for the metal product becomes available.

enriched uranium, DOE began work in 1994 on the DUF 6 Programmatic Environmental Impact "20Additional information relating to the environmental Statement (PEIS) to reexamine its management impact of the basic alternatives and DOE's preferred alternative may be found at http://web.ead.anl.gov/uranium strategy for the DUF 6. /final/finalpeis.cfm.

18

On August 2, 1999, DOE issued its Record of need to be appropriated by Congress. Decisions Decision (ROD)forLong-Term Management and regarding funding and execution of the Final Plan Use of Depleted Uranium Hexafluoride. In the for Conversion of DUF 6, which will be made in ROD, DOE selected the alternative identified as the course of the federal budget process, may the preferred alternative in the final PEIS and affect the nature and timing of the conversion noted that "any proposal to proceed with the program.

siting, construction, and operation of a facility or facilities [to convert DUF 6] will involve As a part of an integrated approach to manage additional review under [National Environmental the DUF 6 inventory, DOE has developed a Policy Act])NEPA." DOE anticipates that the program that includes the following components:

DUF 6 cylinders currently stored at the ETTP site will be shipped to a conversion facility. "*cylinder surveillance and maintenance; 5.2.2 Plan for Conversion of Depleted "*conversion services that include the design, Uranium Hexafluoride construction, operation, and D&D of conversion facilities; Pub. L. No. 105-204, signed in July 1998, directs DOE to prepare "a Plan and legislation to "*storage of uranium conversion products to ensure that all amounts accrued on the books of include design, construction, operation, and D&D of storage facilities; the United States Enrichment Corporation for the disposition of depleted uranium hexafluoride will be used to commence construction of, not later "*use of conversion products; and than January 31, 2004, and to operate, an onsite facility at each of the gaseous diffusion plants at "*disposal of end products not used, such as Paducah, Kentucky, and Portsmouth, Ohio, to uranium and fluorine compounds, and empty storage cylinders.

treat and recycle depleted uranium hexafluoride consistent with the National Environmental Policy Act." According to the Plan, two conversion plants will be constructed, one each at PGDP and In response to Pub. L. No. 105-204, DOE PORTS. In addition to meeting the requirements issued a Requestfor Expressions of Interestfor a of Pub. L. No. 105-204, the construction of two Depleted Uranium HexafluorideIntegrated plants decreases (1) the risk that would otherwise Solution Conversion Contractand Near-Term be associated with the transportation of large Demonstrationson March 4, 1999. On March 12, numbers of DUF 6 cylinders, (2) transportation 1999, the InitialPlanfor the Conversion of costs, and (3) concerns that stakeholders may Depleted Uranium Hexafluoride was released. have with the shipment of large numbers of DUF 6 DOE issued its FinalPlanfor the Conversion of cylinders through their states. The relatively Depleted UraniumHexafluoride, in July 1999.2" small number of cylinders located at ETTP, The plan notes that Pub. L. No. 105-204 only set however, are to be relocated to the PORTS site aside the $373 million accrued by USEC for for conversion.

disposition of DUF 6. In order for DOE to award contracts to begin conversion, these funds will DOE believes that the private sector is well equipped to provide the services needed for conversion of the DOE DUF 6 inventory.

21 "The Plan is available at http://www.ne.doe.gov/ Responses to the Request for Expressions of DUF6/finalplan.pdf.

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Interest support this belief. DOE hopes to award On July 30, 1999, DOE issued Draft Request one or more contracts (1) to manage the cylinders for Proposal No. DE-RP05-99OR22717 for pending conversion of the DUF 6, (2) to convert comment. The draft was issued in order to the DUF6, and (3) to store the conversion provide for early stakeholder input. Comments on products. Although financing options have not the draft were submitted by August 20, 1999.

been finalized, DOE believes that private DOE plans to issue a revised Draft Request for financing will provide the best options for the Proposal for comment in the fall of 1999. DOE is project. DOE anticipates that economically hopeful that early stakeholder input will assure recoverable conversion products will be sold and that the concerns and issues of local that revenues will be used to offset a portion of communities, community reuse organizations, the conversion cost. Payment to the contractor(s) local and state governments, Congress, interested is expected to be provided on a fixed-unit-price citizens and potential bidders will be addressed basis. The uranium metal or oxide product will, successfully.

however, remain the property of DOE until it is sold or transferred. DOE hopes to award one or more integrated conversion and management 5.3 URANIUM MANAGEMENT services contract(s) in CY 2000, with ACTIVITIES construction of conversion facilities to commence in 2002. DOE anticipates that the facilities would 5.3.1 Uranium Management Center begin conversion operations in 2004 and that they would be operated for approximately 25 years, In June 1998, DOE initiated the collection for a total life-cycle cost of $3 billion to and interim storage of potentially reusable

$4 billion. Revenues from the sale of the uranium materials from across the DOE complex conversion products may approach at a central location. The DOE-ORO Office was

$200 million.22 given the task to establish a facility for storage of these uranium materials. The Uranium Design, construction, operation, and D&D of Management Center (UMC) was formed to the conversion plants will be undertaken in a provide a coordinated, cost-effective, and manner that ensures adequate protection of efficient program for management of the nation's workers, the public, and the environment and will surplus uranium resources.

take into account appropriate NRC, U.S.

Department of Transportation (DOT), One major emphasis area for the UMC is the Occupational Safety and Health Administration consolidation, stabilization, and interim storage (OSHA), USEPA, and DOE ES&H requirements of surplus DOE uranium in preparation for reuse, and standards. Additionally, environmental disposition, sale, or barter. The UMC provides a permits will be obtained from appropriate state single focal point for the management of all DOE authorities. DOE does not anticipate that any uranium, thereby improving the potential for sale additional legislation will be required in order to and coordinating use of government resources.

implement this Plan, with the exception of Activities associated with the uranium materials legislation to provide funding. at the UMC include packaging, handling, storage, processing, transportation, disposition, sale, or barter. These services are available from the UMC, as appropriate, to all DOE, other government agency, and commercial customers.

"2Final estimates are not yet available.

The UMC uses existing DOE knowledge, 20

technical expertise, and commercial capabilities, "*Office of Defense Programs (DP) to the extent available, to characterize uranium - Nuclear Materials Management program, inventories and increase their market value. The - Optimize uranium materials management UMC works to foster new commercial activities, development in the uranium industry by - Conservation of nuclear materials resources, increasing the potential reuse and sale of DOE and surplus uranium. - Central Scrap Metal Office for uranium.

A second major emphasis area for the UMC "*Office of Fissile Materials Disposition (MD) is assisting DOE Program Offices in meeting - Management of surplus uranium; their objectives related to consolidation and - Identification, characterization, management of DOE LEU, normal uranium consolidation, and storage of surplus (NU), and depleted uranium (DU). These uranium; program offices handle DOE activities associated - Development of nuclear materials with nuclear materials inventories at multiple information system; and sites throughout the DOE complex. The UMC is - Sales of excess or surplus uranium.

a central focal point for the DOE Program Offices and provides them with the following uranium "*Office of Nonproliferation and National consolidation, management, and disposition Security (NN) services: - Nonproliferation and verification activities.

" Office of Nuclear Energy, Science and The activities of the UMC will enhance Technology (NE) ES&H conditions across the DOE complex by

- Disposition of LEU, NU, DU at PGDP, reducing or removing excess uranium materials PORTS, and ETTP; from multiple DOE sites, such as the Fernald and

- Business development, marketing, Hanford sites, and consolidating them at a disposition, or sales of research reactor fuel; centralized location in preparation for final and disposition, sale, or barter.

- Identification, characterization, consolidation, storage, and sales of excess During FY 1999, an initiative was undertaken uranium. by DOE at PORTS to provide interim storage of uranium materials for the UMC until the material

"*Office of Environmental Management (EM) can be permanently stored, disposed, reused, or

- Accelerated disposition of LEU, NU, and sold. The UMC Interim Storage Facility located DU at Fernald, at PORTS is used to temporarily store

- Accelerated disposition of LEU at commercially marketable solid uranium in several Hanford,23 forms and enrichments. The uranium is stored in

- Reduction of the legacy nuclear materials compliance with DOE Orders and PAAA inventories, and regulations and does not present additional

- Support nuclear material management hazards to facility workers, the public, or the studies. environment. The operation and maintenance of this facility are the responsibility of the DOE ORO UMC and its M&I contractor. Initial uranium materials from the Fernald 23 "AIso supports Hanford material disposition plans of Environmental Management Project (FEMP), in the NE, DP, and MD Program Offices.

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Fernald, Ohio, were placed in storage at PORTS Fernald to meet agreements with the State of during FY 1999. Additional uranium materials Ohio to remove uranium from the site to support from the DOE Hanford site in Richland, site closure milestones. The uranium materials Washington, are anticipated to be consolidated at are being stored in the UMC Interim Storage PORTS beginning in FY 2000. Facility in the X-744G building at PORTS, which is used for storage of similar uranium materials.

Following completion of Environmental Assessments (EAs) for the interim disposition of 5.3.3 Storage of Uranium Materials from the Fernald and Hanford uranium materials, DOE Hanford and Universities plans to prepare an Environmental Impact Statement (EIS) on the consolidation of reusable Approximately 1,700 metric tons of Hanford DOE uranium materials from various DOE sites uranium materials similar to the Fernald materials in accordance with the NEPA and the DOE and approximately 20 metric tons of LEU on loan NEPA implementing procedures. The EIS is from DOE to universities and other organizations scheduled to support issuance of a ROD in are also being considered for interim storage at CY 2000. PORTS. On July 26, 1999, a public meeting was conducted by DOE in Piketon, Ohio, to discuss 5.3.2 Storage of Fernald Uranium Materials plans for the storage of these materials at PORTS.

Upon completion of an EA under NEPA in Approximately 2.2 metric tons of LEU were April 1999 that evaluated impacts for receipt and retrieved from Seattle University and placed in storage of the uranium from FEMP, PORTS was storage at the UMC Interim Storage Facility in selected by DOE for interim storage of this August 1999. In September 1999, 2.5 metric tons material. Based on this EA, DOE determined that of natural uranium were retrieved from the no significant environmental impacts would University of Nebraska and placed in storage at result from the transfer of the uranium to PORTS. the UMC Interim Storage Facility at PORTS.

These uranium materials were lent by the Atomic Approximately 3,800 metric tons of uranium Energy Commission to the universities in 1970 materials from FEMP in the form of normal, and 1962, respectively, for educational and depleted, and LEU compounds and metal will be research purposes. These uranium materials, placed in storage at the UMC Interim Storage which are commercially marketable and are not Facility at PORTS. Potential commercial uses classified as waste, are packaged in clean include use as a radiation shielding material and containers and do not present additional hazards as an agent for special alloy metal applications. to facility workers, the public, or the environment.

Shipments of the uranium materials from FEMP began arriving at PORTS on June 2, 1999, Uranium materials from Hanford are not and will continue until approximately CY 2001. expected to begin arriving at PORTS until During FY 1999, approximately 1,250 metric FY 2000, following completion of an EA for this tons of uranium materials were shipped from material. Like the Fernald materials, these FEMP to PORTS. The schedule will enable uranium materials will be stored for future use or sale by DOE.

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5.4 OTHER DOE ENVIRONMENTAL, schedules). In response to the initial observations SAFETY, AND HEALTH INITIATIVES and concerns elicited during the stand-down, the Secretary identified a series of corrective actions 5.4.1 Secretarial Initiative on Environmental, to be taken immediately: (1) an independent Safety, and Health Conditions at review of the contractor's radiation protection Paducah program, (2) an examination of existing air monitoring systems used at the site to confirm In June 1999, in response to concerns raised that these monitors will record any significant in a lawsuit, a team of health physicists was sent DOE contributions to overall site emissions, to the PGDP site to identify the existence of any (3) an expansion of worker training programs, imminent threats to public health, worker safety, and (4) stationing two full-time DOE facility or the environment. No imminent threats were representatives at the site.

identified. In August 1999, the Secretary of Energy, Bill Richardson, ordered a full 5.4.2 Integrated Safety Management Initiative investigation into ES&H conditions at the PGDP site. The two-phased investigation focuses first DOE is committed to conducting work on issues and concerns from the past 10 years. efficiently and in a manner that ensures The second phase will involve examination of protection of workers, the public, and the longer-term legacy ES&H issues. On environment. The ISMS is DOE's approach for September 8, 1999, the Secretary ordered a safety accomplishing this goal. Safety Management stand-down at the site to permit DOE and its Systems provide a formal, organized process contractor employees and managers to review whereby people plan, perform, assess, and safety procedures. The stand-down did not improve the safe conduct of work. DOE policy identify any imminent hazards to the health and requires that safety management systems be used safety of DOE and contractor workers. to systematically integrate safety into Employees did indicate interest in receiving more management and work practices at all levels so communication and feedback in the area of that missions are accomplished while protecting radiation monitoring programs. the workers, the public, and the environment.

Direct involvement of workers during the On September 14, 1999, Secretary development and implementation of safety Richardson announced the investigating team's management systems is essential for success.

initial observations.2 4 At that time, the Secretary noted that while the investigating team did not The DOE ISMS establishes a hierarchy of find any imminent hazards to the workers or the components to facilitate the orderly development public and confirmed that general radiation and implementation of safety management hazards are low and that radiation protection throughout the DOE complex, including the programs have improved over the past decade, it GDPs. The safety management system consists of identified areas for improvement (e.g., six components: (1) the objective, (2) guiding radiological protection, procedures, conduct of principles, (3) core functions, (4) mechanisms, operations, and acceleration of cleanup (5) responsibilities, and (6) implementation. The objective, guiding principles, and core functions are defined by DOE policy and are used 24 "The team observations and corrective actions are consistently in implementing safety management available at http://www.doe.izov/news/releases99/seppr/ throughout the DOE complex. The mechanisms, PaducahCW.pdf. As of September 30, 1999, the first phase responsibilities, and implementation components investigative report had not been released.

23

are established for all work by the DOE meetings during which scope, hazards, hazard contractor (with approval by DOE) and vary, controls and other related issues are discussed in based on the nature and hazard of the work and conjunction with proposed work. Additionally, the site location. The requirement for DOE workers are involved in procedure development, contractors to develop and implement an ISMS is and any subcontract prepared for work established by 48 CFR 970.5204-2, Integrationof incorporates the ISMS principles. The ISMS Environment, Safety and Health into Work process is also used for nonroutine work, as was Planningand Execution. demonstrated by the successful installation of a vented lid on an 85-gallon over-pack with a 55 Consistent with Secretarial direction given on gallon inner container of corrosive liquid March 3, 1999,25 DOE plans to verify classified as Class C radioactive waste. This implementation of ISMS at all DOE sites, installation involved a diverse group of including PGDP and PORTS, by specialists who worked together to identify all September 2000. The verification will take place safety concerns associated with the activity in two phases. Phase I will verify that before completing the work.

programmatic elements are in place. Phase II will consist of a field verification. DOE ORO is Integrated Safety Management is also being expected to perform the Phase I and Phase II effectively implemented at PORTS. This verifications by December 1999 or January 2000. determination was made after a recent internal assessment of the program. Processes currently in The focus of the DOE ORO M&I place include assignment of team members to contractor's implementation of ISMS is to each project to promote uniformity and systematically integrate ES&H controls into consistency throughout the project. The project management and work practices. The M&I team is responsible for defining the scope of contractor for DOE ORO, who is responsible for work, identifying hazards and implementing managing and integrating the activities at PGDP effective control measures. A training course and PORTS, implements the following five entitled "Supervising for Safety" is mandatory for 26 integrated safety management functions: all personnel, including subcontractors. A Project Readiness Review is required to ensure all

"*define the scope of work, aspects of a project are in place before project

"*analyze hazards, approval. PORTS gained approval from DOE on

"*develop and implement hazard controls, Phase I implementation and is currently preparing

"*perform work within controls, and for Phase II verification of the ISMS program in

"*provide feedback and continuous improvement. FY 2000.

The implementation of the ISMS process has 5.4.3 Paducah Environmental, Safety, and been successfully initiated at the GDPs through Health Initiatives FY 1999. At PGDP, for example, the ISMS process is applied in weekly work planning At PGDP, the Safety Team of Paducah (STOP) continued to meet monthly throughout the year as it has since its beginning in 1993. The 25 "Information relating to the Secretary's direction may team includes employees representing the DOE be found at http://tis.eh.doe.gov/ism/bbmessape.html. Paducah Site Office, DOE's M&I contractor, 2

'Integrated Safety Management System Description subcontractors, and USEC. This team identifies dated April 1999, document BJC/OR-87, Revision 1.

and addresses safety issues affecting employees 24

both at home and at work. STOP helped to GDPs through the following activities:

increase awareness of the need for caution in (1) management of DUF 6 to ensure safe storage driving on the plant access road and, in of cylinders and to implement long-term coordination with community and statewide management strategies and plans for this material initiatives, STOP promoted 100% seat belt usage including conversion and storage of the converted and correct use of child seats. To identify areas of DUF 6, (2) management of the polychlorinated concern or suggest solutions to existing problems, biphenyl (PCB) program, (3) participation in the the parties involved in the M&I contract (DOE, NRC certification and regulatory process (e.g.,

the M&I contractor, and their subcontractors) use review of all proposed Compliance Plan one safety suggestion form. modifications; oversight of activities in areas that are leased, but not certified; and coordination and 5.4.4 Portsmouth Environmental, Safety, and information exchange with NRC),

Health Initiatives (4) maintenance of nonleased facilities, and (5) administration of the Lease within these At PORTS, safety is emphasized -through programs with USEC.

personnel awareness by commencing every meeting with a safety topic and by recognizing Integration of ES&H activities within these subcontractors who show outstanding programs assures that DOE EM and EF activities performance toward zero accidents and at the GDPs are conducted in a way that avoids commitment to safety excellence through a accidents or injuries to workers and the public "Safety Subcontractor of the Month" program. and avoids harm to the environment. DOE ES&H-related activities at the GDPs include, but are not limited to, environmental protection,

6. ENVIRONMENTAL, SAFETY, environmental restoration, waste management, AND HEALTH STATUS OF nuclear safety, engineering, industrial hygiene, NONLEASED AREAS industrial safety, radiation protection, transportation safety, risk management, and The DOE mission at PGDP and PORTS occupational medicine. The DOE EM and EF includes Environmental Management (EM), Programs at the GDPs are managed by DOE which is under the direction of the Office of ORO and its M&I contractor.

Environmental Management, and Enrichment Facilities27 (EF) programs and projects, which are On April 1, 1998, as part of DOE's contract under the direction of the Office of Nuclear reform initiative, DOE implemented an M&I Energy, Science and Technology. The EM contract for the EM and EF work at the Oak Program identifies and reduces the ES&H risks at Ridge Reservation in Oak Ridge, Tennessee, and the GDPs through environmental restoration (ER) at both GDPs. Objectives of the M&I contract, and waste management (WM) activities. The EF which replaced a management and operating Program manages and reduces ES&H risks at the contract, include accelerating cleanup and maximizing cost-effective completion of work.

During FY 1999, the M&I contractor issued several major subcontracts involving work at the GDPs in support of the DOE EM and EF j 27 Programs. Integrated Safety Management, "On September 23, 1999, DOE ORO renamed the Enrichment Facilities Program. The new name is Uranium described in Section 5.4, is the foundation of the Programs. For purposes of consistency, this report uses the M&I contract implementation.

term EF to refer to the EF Program during FY 99.

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6.1 ENVIRONMENTAL, SAFETY, AND "*an operating solid waste contained landfill, HEALTH STATUS OF NONLEASED AREAS AT PADUCAH "*waste storage and treatment facilities, During FY 1999, DOE and its contractors and "*two groundwater containment systems, subcontractors made good progress toward completion of their mission at PGDP with no "*two complexes of facilities under surveillance occupational injuries that caused any employee to and maintenance in the D&D program, miss a day of work. DOE met all 78 regulatory deliverables on schedule for FY 1999. These " nonleased facilities not in use and not yet in the deliverables included reports to the Kentucky D&D program, Department for Environmental Protection (KDEP) and to the USEPA. " office and laboratory facilities, and Improved strategies for environmental "*storage yards for cylinders containing DUF 6.

cleanup and WM were implemented during FY 1999. Environmental cleanup is now focused 6.1.2 Construction Activities on sitewide remedial cleanup objectives rather than individual locations. The individual DOE construction activities on the PGDP locations requiring investigation and, in some reservation during FY 1999 included:

cases, remediation have been incorporated into the sitewide remedial objectives. This approach is " Completion of the DOE cylinder yards fencing expected to save money by reducing project in October 1998, which is expected to documentation costs, with savings to be invested save more than $1 million by reducing security in cleanup. For WM, all waste streams in storage costs over a 5-year period. This project have been ranked according to risk. Wastes that included installatioa of 5,400 linear feet of pose a higher risk by remaining in storage have fencing, lighting, and patrol roads.

top priority for disposition.

" Construction on the C-745-L-North DUF 6 6.1.1 Facilities and Acreage Cylinder Storage Yard began in May 1999.

When complete, the yard will provide DOE owns the 3,556-acre PGDP reservation approximately 196,000 square feet of concrete and leases the uranium enrichment facilities to surfaced storage space with an estimated USEC. At PGDP, DOE leases 315 buildings and capacity of 4,330 cylinders. Construction is on facilities to USEC and retains 134 as nonleased. schedule for completion by March 31, 2000.

The nonleased facilities include:

" Completion of construction of an enclosed

" roads and grounds outside the perimeter containment structure in the C-752-A RCRA security fence on the DOE Reservation and Waste Storage Facility in August 1999 for approximately 200 acres of deleased grounds waste sampling, treatment, and treatability (formerly common ground) inside the fence, studies. Scheduled to begin operations in FY 2000, it will contain airborne or

"*parcels of land designated for investigation transferable radiological contamination that and/or environmental cleanup [solid waste may be released during waste sampling or management units (SWMUs)], treatment.

26

• Completion of approximately 50% of the responded with an Implementation Plan construction work associated with the containing a set of actions and schedule for Lasagna TM soil remediation process. resolving the concerns. These actions have been Construction is scheduled to be completed in either completed or incorporated into procedures November 1999. The process will be used for ongoing maintenance and management, as under a ROD for cleanup of trichloroethylene appropriate. Major initiatives in the safe storage (TCE)-contaminated soils at SWMU 91. of cylinders include:

6.1.3 Depleted Uranium Hexafluoride

" Refurbishment of a total of 3,368 of the older cylinders from FY 1996 through FY 1998.

Management Exterior surfaces were blasted with a recyclable steel grit before applying paint to minimize the The DOE EF Program is responsible for corrosion rate of the steel. An approximately 4 storage, inspection, and maintenance of ft by 12-ft area on the bottom of each cylinder approximately 450,000 metric tons was topcoated with an epoxy mastic for extra

(-500,000 tons) of DUF 6 in 36,910 steel cylinders protection. No cylinders were painted in at PGDP. DOE has oversight of the DUF6 FY 1999.

pursuant to the AEA. The number of DOE cylinders at PGDP includes the 28,351 cylinders " Constructing new concrete cylinder storage generated between November 1952 and July 1, yards and upgrading existing yards from gravel 1993, and an additional 8,559 cylinders that have to concrete. The newest concrete cylinder been or will be transferred from USEC to DOE in storage yard is the 11-acre C-745-T facility accordance with the 1996 USEC Privatization completed in March 1998. Construction of the Act. 28 The DOE inventory includes an additional C-745-L yard began in FY 1999, with 1,940 cylinders containing natural or slightly completion scheduled for FY 2000. When the enriched uranium. entire C-745-L yard is completed, 28 acres of the 60-acre DOE cylinder yard complex will be DOE has improved ES&H and other aspects concrete.

of cylinder management through its response to a recommendation from the Defense Nuclear " Improvement in inspection and monitoring of Facilities Safety Board (DNFSB). In 1995, the cylinders by stacking them to provide better DNFSB issued Recommendation 95-1, Improved access for inspectors. In FY 1999, DOE Safety of Cylinders ContainingDepleted surveillance and maintenance of cylinders Uranium. The recommendation identified included the annual inspection of concerns with the overall condition and the 2,460 cylinders, quadrennial inspection of corrosion rate of the surfaces of the steel 2,964 cylinders, and baseline inspections of cylinders, which are stored outdoors. DOE 6,729 cylinders.29 28

" in accordance with the Privatization Act, DOE and USEC signed an MOA during FY 1998 by which about 6,500 additional cylinders at PGDP and 2,600 additional 29 cylinders at PORTS containing DUF 6 generated by USEC

" A1l cylinders require at least a quadrennial inspection.

The cylinders transferred from USEC received a baseline from July 1, 1993, through privatization on July 28, 1998, inspection. A smaller number of cylinders receive annual were transferred to DOE. According to a second MOA that inspections based upon an identified defect. Each inspection was also signed in FY 1998, an additional 2,026 USEC utilizes the same detailed checklist, and results are entered DUF 6 cylinders will be transferred to DOE between the date of privatization and FY 2004. into the Cylinder Inventory Database.

27

Safe storage of DUF 6 has been, and remains, facilities; the updated SAR is the first edition to a significant commitment for DOE. However, the focus on nonleased facilities. The 1997 SAR focus has expanded to include converting the update concluded that with implementation or DUF 6 to a more stable form either for future use continuation of controls identified in the 1995 or disposition. (See Section 5.2.) Representatives SAR, the operations in the nonleased facilities of the Commonwealth of Kentucky and DOE met and areas can be conducted safely with adequate June 17, 1999, regarding development of an protection provided for health and safety of the Agreed Order to assure that DUF 6 cylinders at public and employees as well as protection of the PGDP will be maintained, painted, and inspected environment. DOE is reviewing the 1997 SAR until the material is converted. Ohio and update.

Tennessee have similar Orders in place.

6.1.5 Environmental Restoration EF work at PGDP cost $9 million in FY 1999. The proposed budget for FY 2000 is DOE ORO has an aggressive plan to

$17 million. The funding levels have increased to accelerate completion of its EM mission, which account for planned cylinder yard construction in includes ER and WM activities. The plan and its FY 2000. In recent years, overall expenditures on assumptions are described in a document titled EF Program work at PGDP, PORTS, and Oak AcceleratingCleanup, Paths to Closure, Oak Ridge have declined from approximately Ridge OperationsOffice (DOE/OR/0I-1746, R1,

$124 million in FY 1995 to $64 million in published in May 1999).

FY 1999. The majority of the decrease has been related to the completion of the HEU Suspension The regulatory framework for ER at PGDP is and Removal Program at PORTS. However, other the Paducah Federal Facility Agreement EF Program activities at all three sites have been (FFA)--a tri-party agreement among DOE, impacted by this trend. Construction of some USEPA Region IV, and the Commonwealth of cylinder yards will be deferred for the third year Kentucky that became effective on February 13, in FY 2000. Cylinder painting, cylinder 1998. The FFA coordinates CERCLA movements, and engineering development compliance, administered by USEPA, with the activities have also been deferred. As a result, RCRA corrective action program administered by DOE agreements with the prime contractor Kentucky. PGDP was placed on the National regarding systems engineering requirements of Priorities List (NPL) on May 31, 1994.

the cylinder project have not been fully implemented. PGDP has identified 211 SWMUs and Areas of Concern (AOCs) subject to investigation under 6.1.4 Update of Safety Analysis Report the FFA. Most of these areas are on DOE property either within the security fence or on the The PGDP 1997 Safety Analysis Report DOE Reservation. Off-site contamination has (SAR) Update was issued to the DOE Site Office affected groundwater between the plant and the and DOE ORO on March 30, 1998. This Ohio River to the north and, to a limited distance, document establishes the authorization basis for downstream surface water and sediments.

operation of nonleased facilities at PGDP.

Information in the document was updated from To facilitate a logical environmental September 30, 1995, to September 30, 1997. The remediation of PGDP, DOE initially focused on 1995 SAR covered leased and nonleased addressing immediate risks and 28

high-concentration areas associated with off-site detail in Section 3.2 of the PaducahSite contamination: ManagementPlan (DOE/OR/07-1780&D2). This change is intended to maximize opportunities to

" Mitigation of immediate risks has been benefit from regional approaches and economies accomplished. Several continuing actions are of scale, reduce documentation costs, and provide being performed to ensure that immediate risks a better process to evaluate cumulative effects remain at acceptable levels. These actions from all media. Based on these objectives, the include providing municipal water to residents new strategy establishes a framework for north of the plant in a designated area; conducting five major operable units (OUs):3' monitoring migration of groundwater contamination; and maintaining signs and 1. Groundwater Operable Unit: focuses on fences installed to limit access to contaminated investigation and remediation of the ditches, streams, and lagoons. groundwater for protection of off-site residents. The recently discovered Southwest

"*Mitigation of the spread of high-concentration plume will be addressed as a part of this OU.

contaminated areas associated with off-site contamination continues. Actions include 2. Surface Water Operable Unit: focuses on operation of systems for hydraulic containment investigation and remediation of the surface of high-concentration portions of the Northwest waters for protection of recreational users and and Northeast groundwater contamination ecosystems.

plumes, maintenance of sediment controls on site at the scrap metal yards, and use of source 3. Burial Grounds Operable Unit: focuses on treatment measures to reduce the contamination investigation and remediation of the burial in discharges to an on-site ditch. These actions grounds for protection of industrial workers.

have been successful in meeting the goals contained in the RODs30 to maintain hydraulic 4. Surface Soils Operable Unit: focuses on control and reduce migration of the plumes. investigation and remediation of the surface soils for the protection of industrial workers.

When the immediate risks and off-site high concentration contamination areas had been 5. D&D Operable Unit: focuses on addressed, the remaining SWMUs and AOCs characterization and D&D of facilities for the were initially segregated into Waste Area Groups protection of industrial workers.

(WAGs) based on common characteristics (such as contaminant types, media and location) for After the actions agreed to in a ROD for each further investigation and remediation. However, of the five Operable Units are complete, a in 1998, DOE further refined this strategy and Comprehensive Sitewide Operable Unit (CSOU) grouped the existing WAGs into larger areas based on site remedial objectives, as explained in "3AnOperable Unit is a discrete action that comprises an incremental step toward comprehensively addressing site remedial problems. This discrete portion of a remedial 30

" Record of Decisionfor Interim Remedial Action of the response manages mitigation, or eliminates or mitigates a Northwest Plume at the PaducahGaseous Diffusion Plant, release, a threat of a release, or pathway of exposure.

Paducah, Kentucky, DOE/OR/06-1143, and Record of Operable Units may address geographical portions of a site, Decisionfor Interim Remedial Action of the Northeast specific site problems or initial phases of an action, or may Plume at the PaducahGaseous Diffusion Plant,Paducah, consist of any set of actions performed over time located in Kentucky, DOE/OR/06-1356. different parts of a site.

29

project will be undertaken that will include a neptunium. The environmental contamination sitewide baseline risk assessment to evaluate any that DOE is in the process of remediating resulted residual risk remaining at the site after primarily from historical practices no longer in completion of the five OUs. If the CSOU risk use at PGDP. For instance, PGDP ended its use assessment concludes that the actions taken of TCE as a degreaser in 1993. Reactor "returns,"

collectively provide adequate protection to which were the source of 99Tc and the transuranic human health and the environment, a final CSOU radionuclides at PGDP, are no longer processed Proposed Plan and ROD will be issued, followed in the enrichment facilities; however, residual by a final remediation report declaring site "9Tc remains in the process equipment, in remediation complete. In the event that the CSOU decontamination solutions, and in soils, risk assessment determines additional actions are sediments and groundwater. Use of PCBs is needed, a Feasibility Study (FS) will be controlled and is in the process of being phased developed with the preferred alternative out in accordance with the Uranium Enrichment documented in a Proposed Plan and ROD, Toxic Substances ControlAct (TSCA) Federal followed by the necessary remedial actions. FacilityCompliance Agreement (FFCA).

Consolidation of work scope under this new The current scope of the D&D program at strategy is expected to result in approximately PGDP consists of surveillance and maintenance

$50 million in cost avoidances compared with the of two complexes of facilities-the C-340 Metals original compliance case under the FFA. These Plant and the C-410 Feed Plant-both of which cost avoidances are the result of gained ceased operations in 1977. DOE surveillance and efficiencies and reduced documentation costs. maintenance activities include maintaining the Additionally, the consolidation of the work scope structures and ensuring residual contaminants are will accelerate remedial actions for groundwater contained.

and surface water by several years. The new strategy also includes initiatives to reduce long DOE encourages opportunities to recover term Operations and Maintenance (O&M) costs. assets or reduce costs associated with excess One particular initiative includes an FS to equipment from the D&D of facilities. During evaluate remedial alternatives for converting the FY 1999, DOE shipped 30% of the surplus existing groundwater pump-and-treat system into fluorine cells and support equipment which were an in situ passive treatment system, which has the previously used at the C-410 Feed Plant facility potential to reduce life cycle O&M costs by to manufacture UF 6 feed material and fluorine.

approximately $100 million if successful. By selling these cells and equipment to a commercial fluorine production company, DOE The contaminants of primary focus in ER at expects to save $1.4 million in future waste PGDP are TCE, a common industrial solvent; disposal costs.

technetium-99 (9Tc), a radioactive material present in used nuclear reactor fuel that was Other FY 1999 DOE ER accomplishments at recycled at the plant periodically during its first PGDP include the following:

approximately 20 years of operation; PCBs, a fire retardant commonly used in oils in electrical

• Completed the Remedial Design/Remedial systems; and uranium from the enrichment Action process prescribed by the FFA for operations at PGDP. Secondary contaminants WAGs 1 and 7. This accomplishment was consist of various metals, organics, and other achieved when the USEPA Region IV and the radionuclides such as americium, plutonium, and KDEP approved the Post Constructionand 30

Operations andMaintenance Planfor Waste situ soil remediation system started in Area Groups 1 and 7 at the PaducahGaseous August 1999. Construction was approximately Diffusion Plant, DOE/OR/07-1743D1, in May 50% complete by the end of FY 1999.

1999. WAGs 1 and 7 include nine SWMUs; the Operations are scheduled to start in primary focus is the C-746-K inactive November 1999. The Lasagna TM technology sanitary landfill. Actions completed or ongoing was selected under a 1998 ROD to clean up at the C-746-K landfill under a 1998 ROD TCE contamination after the successful include: (1) continuation of existing surface national demonstration of the technology at water and groundwater sampling, PGDP. The system is expected to run 2 years to (2) installation of warning and entrance signs, achieve targeted cleanup levels.

(3) repair of a small area of the cap damaged by flooding, (4) abandonment of two groundwater "Commenced fieldwork on WAGs 3, 8, 28/Data wells, (5) installation of one new monitoring Gaps Project. WAG 3, scheduled for well, and (6) establishment of deed restrictions. completion in FY 2000, includes three burial The WAGs 1 and 7 project also included No grounds; WAG 8, completed at the end of Further Action on six SWMUs, institutional September 1999, includes the four plant switch controls on a fire training area, and deferral of yards; and WAG 28, which was completed at action on the PGDP sewage treatment plant. the end of July 1999, includes locations related to the original construction of the plant. The Treated approximately 174 million gallons of project also includes collection of groundwater contaminated groundwater at the two and subsurface soil samples to supplement groundwater treatment systems in FY 1999. existing data. The data gaps portion of the The C-612 Northwest Plume Groundwater project was completed at the end of July 1999.

System has processed approximately This project will complete all major 406 million gallons of groundwater investigations for the Groundwater Operable contaminated with TCE and 99Tc from the start Unit.

of operations in September 1995 through FY 1999. The C-614 Northeast Plume " Issued the D2 Remedial Investigation Reports Groundwater System has processed for WAGs 6 and 27 in May 1999 and approximately 213 million gallons of June 1999, respectively. Information in both groundwater contaminated with TCE from the reports will be used to develop remedial start of operations in February 1997 through decisions for groundwater contamination.

FY 1999.

" Initiated the Innovative Treatment Remediation

• Completed the remediation process on the two Demonstration (ITRD) process for the 10,000-gallon underground storage tanks that Groundwater Operable Unit FS. The ITRD were part of the original 1950s gas station at team included representatives of DOE, the plant. regulatory agencies, industry, and national laboratories. It will help to evaluate remedial

• Obtained regulatory approval for the Remedial technologies with potential application to Design Report, Remedial Action Work Plan, groundwater contamination.

and Construction/Quality Control Plan for application of Lasagna TM soil remediation ER costs were $29 million for FY 1999, with technology at SWMU 91, a former UF 6 a proposed budget of $21.8 million for FY 2000.

cylinder drop-test site. Construction of the in Budget reductions in recent years have resulted in 31

extensions for completion of the EM program. No

• Kentucky solid waste regulations for other noncompliances have resulted from these reduced wastes.

funds, nor have any impacts to the ES&H conditions been identified. However, projects Agreements related to implementation of delayed due to funding limitations included these regulations and the Order include the additional fence control related to access control following:

and sales of additional surplus fluorine cells.

" Site Treatment Plan and associated Agreed 6.1.6 Waste Management Order under the Federal Facilities Compliance Act for characterization, treatment, and DOE is responsible for the characterization, disposal of mixed hazardous/radioactive storage, treatment, and disposal of certain wastes wastes; at PGDP. These wastes include waste generated before the establishment of USEC on July 1, " Toxicity Characteristic Leaching Procedure 1993, ongoing generation of wastes from DOE (TCLP) FFCA for TCLP characterization under projects, and a limited amount of the wastes RCRA for waste generated prior to generated by USEC. By FY 2012, DOE plans to September 25, 1990; and dispose of all legacy waste in storage as of the beginning of FY 1999. DOE defines legacy

• Uranium Enrichment Toxic Substances Control wastes as any DOE waste generated prior to Act (TSCA) FFCA for use, cleanup, storage, FY 1999 and certain wastes generated by USEC treatment, and disposal of PCBs.

that are identified in the lease between DOE and USEC. These wastes include RCRA, PCB, DOE WM accomplishments at PGDP during asbestos, chromium, arsenic, pentachlorophenol, FY 1999 include the following:

TCE, low-level radioactive, and transuranic wastes. Treated, shipped, or disposed of more than 4,935 tons of DOE waste and USEC waste. All After characterization to assure the of the USEC waste and most of the DOE waste appropriate disposition method, wastes are sent were either wastewater treated on-site or waste for disposal to DOE's C-746-U Solid Waste disposed of in DOE's C-746-U Solid Waste Contained Landfill on the PGDP reservation or Contained Landfill, shipped off-site to DOE's shipped off-site to approved DOE or commercial TSCA Incinerator at ETTP, to other DOE treatment and disposal facilities. Wastewater is facilities, or to approved commercial disposal treated on-site. facilities.

The USEPA and Kentucky Division of Waste Set daily and monthly disposal records at the Management are the regulatory agencies for C-746-U Solid Waste Contained Landfill with PGDP WM. Regulations and the DOE Order the disposal of 1,795 tons of waste over 31/2 governing WM include the following: days in June 1999 and a monthly total of 4,000 tons disposed in June. Use of this

"*RCRA, Part B, Hazardous Waste Management operating landfill has saved $15 million to date Permit; compared with off-site disposal options.

"*TSCA regulations for PCB wastes;

"*DOE Order 5820.2A, Radioactive Waste Passed every unannounced monthly inspection Management; and of the C-746-U Solid Waste Contained Landfill 32

by the Kentucky Division of Waste Areas-EM&EF-078,in September 1999. An Management with all aspects deemed Independent Readiness Assessment was also acceptable and no deficiencies cited since the completed in September, and conditional landfill began operation in February 1997. approval to begin work to address NCS concerns within the DMSAs was issued.

Issued the draft Engineering Evaluation and Cost Analysis (EE/CA) for regulatory review. 6.1.8 Environmental Status This EE/CA addresses the removal of an estimated 65,000 tons of scrap metal from DOE requires that all its sites conduct and PGDP. Removal of the scrap is necessary to document environmental monitoring and investigate the SWMUs underneath. surveillance on the basis of DOE Order 5400.1, GeneralEnvironmentalProtectionProgram.

WM costs were $13.4 million for FY 1999, DOE's environmental monitoring at PGDP with a proposed budget of $16 million for includes groundwater, surface water, sediment, FY 2000. Budget reductions in recent years have fish, aquatic organisms, deer, and small resulted in extensions for completion of the EM mammals. DOE's annual site environmental program. No noncompliances have resulted from reports for PGDP document the monitoring these reduced funds, nor have any impacts to the results, which verify compliance with permits and ES&H conditions been identified. However, applicable laws.

certain fire protection and electrical upgrade projects have been moved to outyears. Environmental permits for DOE projects and activities at PGDP include the following:

6.1.7 DOE Material Storage Areas

" An air permit under the Clean Air Act from the DOE is in the process of consolidating and Kentucky Division of Air, Department for documenting waste and unused equipment at a Environmental Protection. This permit, which total of 148 locations at PGDP designated as expires in June 2003, relates specifically to the DMSAs. The DMSAs are nonleased facilities that DUF 6 cylinder coating project operations.32 are located inside leased buildings and outdoor areas. DOE and USEC established the DMSAs on " A Solid Waste Disposal permit issued by the December 31, 1996, to facilitate NRC Kentucky Division of Waste Management in certification of the GDPs. Work on the DMSAs 1997 for the C-746-U Solid Waste Contained has involved documenting the contents, resolving Landfill. This landfill began operation in environmental problems with the contents such as February 1997 for disposal of nonhazardous, draining and disposing of oils from old nonradioactive solid waste. The permit expires equipment, and beginning the process of proper in November 2006.

segregation and disposal of wastes. During FY 1999, DOE continued to place priority on " Kentucky Pollutant Discharge Elimination documenting the contents of DMSAs located System (KPDES) permit under the Clean Water inside leased facilities to support USEC's Act from the Kentucky Division of Water, upgrade of seismic reinforcements. In addition, Department for Environmental Protection. The following receipt of a safety evaluation, DOE current KPDES permit is effective April 1, issued an SER entitled Safety Evaluation Report for Unreviewed Safety QuestionsAssociated with Department of Energy MaterialStorage "32No cylinder painting was done in FY 1999.

33

1998, through March 31, 2002. This permit Protection Cabinet issued a final order indicating includes four KPDES outfalls: (1) 001, includes that the state can regulate radionuclide levels in treated discharge from the C-612 Northwest waste disposed of in the C-746-U Solid Waste Plume Groundwater System and the C-616 Contained Landfill; DOE filed suit against treatment lagoon leased to USEC, as well as Kentucky in U.S. District Court challenging the surface runoff from scrap metal storage yards; order.

(2) 015, includes surface water runoff from nonleased areas including the C-404 inactive 6.1.9 Safety and Health Status hazardous waste landfill; (3) 017, includes runoff from the DOE DUF 6 cylinder storage DOE goals in Safety and Health at PGDP yards; and (4) 019, includes runoff from the include (1) zero accidents and (2) limiting C-746-U Solid Waste Contained Landfill.33 exposures to chemicals and radiation to "as low as reasonably achievable." The basis of the As required by the KPDES permit, DOE Safety and Health requirements supporting these submitted a watershed monitoring plan to the goals includes 10 CFR 835 for radiation Commonwealth of Kentucky within 60 days of protection and the 29 CFR 1910 and 1926 series the effective date of the permit. This plan, which for industrial hygiene and safety.

was implemented in October 1998, provides for monitoring of Little Bayou and Big Bayou creeks, DOE and its prime contractors and including fish, bioaccumulation, and toxicity subcontractors worked a total of 841,747 hours0.00865 days <br />0.208 hours <br />0.00124 weeks <br />2.842335e-4 months <br /> monitoring. and drove a total of 184,109 miles in government vehicles during FY 1999 with no occupational In FY 1999, DOE met the conditions of the injuries that caused any employee to miss a day KPDES permit with the exception of exceedances of work. Five recordable injuries and illnesses of permit limits for toxicity at Outfall 017 in (RIIs) were experienced during FY 1999, three by October and December 1998 and April 1999. subcontractors to the M&I contractor and two by DOE implemented a Toxicity Reduction DOE subcontractor employees. In October 1998, Evaluation plan, which was approved by the an employee fell while entering a building, state, to determine the cause. Painting of DUF 6 resulting in back strain. In April 1999, two cylinders (1996-1998) may have contributed to employees traveling in a DOE vehicle on the the problem. The outfall has met all permit limits plant access road were hit by another vehicle that from May through September 1999. Evaluations failed to stop at an intersection, resulting in minor of alternative paints that do not cause acute contusions and bruises to both employees. In toxicity in the surface runoff have been initiated. May 1999, an employee cut his hand while A paint that does not cause acute toxicity in the retracting a portable tent during fieldwork. The surface runoff will be used when the painting cut required stitches. In September 1999, an operation is restarted. employee performing Health Physics technician work experienced a back strain when lifting During FY 1999, the Secretary of the survey equipment.

Kentucky Natural Resources and Environmental The average radiation exposure for the 530 personnel monitored as part of the DOE "33For a description of the regulatory limits for radiation protection program during CY 1998 was environmental releases, the reader is referred to DOE Annual 10 mrem, compared with the 5,000 mrem Site Environmental Reports (BJC/PAD-5) and the occupational exposure limit set by federal law in Environmental MonitoringPlan, (BJC/PAD- 121).

34

10 CFR 835. No individual received radiological 6.1.10 Reportable Occurrences exposures in excess of regulatory limits. This compares with annual background radiation DOE uses an Occurrence Report system on a exposure levels per person of 200 mrem from national basis to communicate incidents at its naturally occurring radon, 40 mrem from food, facilities that need to be shared with all DOE 30 mrem from terrestrial sources, and 30 mrem sites and evaluated for lessons learned. Copies of from cosmic radiation (according to the National final Occurrence Reports I are madeI available at Council on Radiation Protection and DOE reading rooms and information centers.

Measurements, NCRP Report 94, Exposure of the Appendix B. 1 summarizes the reportable Population in the United States and Canadafrom occurrences at PGDP for FY 1999. During NaturalBackgroundRadiation). FY 1999, a total of 22 Occurrence Reports were filed at PGDP. All but ten of these reports have The Agency for Toxic Substances and been finalized; these ten reports were initiated Disease Registry (ATSDR), based in Atlanta, and/or updated during the latter part of FY 1999.

Georgia, continued preparation of a Public Health All 22 reports were classified as "off-normal" Assessment on PGDP during FY 1999. The occurrences. Off-normal occurrences are defined assessment is required by federal law because as abnormal or unplanned events or conditions PGDP is on the NPL for environmental cleanup. that adversely affect or indicate problems in the ATSDR, which has sent representatives to DOE safety, security, ES&H protection, or operation of public briefings and workshops to stay informed a facility. None of the occurrences resulted in on site activities and stakeholder interests and harm to people or the environment. However, concerns, plans to issue its draft assessment to the corrective actions were taken on each incident to public in FY 2000. prevent recurrences of similar or more serious events. Also, lessons learned were identified and As required by the National Defense communicated across the DOE complex to help Reauthorization Act for 1993, DOE Headquarters ensure that PGDP and other DOE sites avoid awarded a grant to the Paper, Allied-Industrial, similar problems.

Chemical, and Energy Workers International Union34 (PACE) to conduct a Former Worker Occurrences and findings from assessments Medical Surveillance Program at the DOE GDPs also are assessed to determine whether they are in Paducah, Portsmouth, and Oak Ridge. PACE potential noncompliances with PAAA completed Phase I, a needs assessment, during regulations. PAAA provides DOE with the FY 1997 to determine whether it considers any authority to assess civil and criminal penalties for former workers to be at risk for work-related violation of DOE nuclear safety rules, health effects from exposures while employed at regulations, or orders. During FY 1999, based on the GDPs. In FY 1998, DOE approved PACE's preliminary concerns from a DOE EH Office of application to conduct a medical surveillance of Oversight Investigation Team, one submittal was former workers as Phase II of the study. During entered into the DOE Noncompliance Tracking FY 1999, PACE completed the medical System (NTS) as a potential noncompliance with surveillance of approximately 85 of the 350 10 CFR 835. This concern, and any others former PGDP workers identified for this identified in the DOE EH Team's final report, surveillance. will be assessed. Then, a final decision will be made on whether potential PAAA noncompliances to 10 CFR 835 exist. Revisions 34 "Formerly Oil, Chemical & Atomic Workers will be made, as needed, to the submittal in NTS.

International Union (OCAW).

35

6.1.11 Summary PORTS. The EF Program will include the new DUF 6 conversion facility upon completion.

DOE accomplishments and initiatives to enhance and improve ES&H conditions at PGDP 6.2.1 Facilities and Acreage during FY 1999 include, but are not limited to, the following: DOE owns the 3,714-acre federal reservation at PORTS and leases the uranium enrichment

"*Continued making good progress toward facilities to USEC. DOE leases 274 of the 357 eventual site cleanup. facilities and systems at PORTS to USEC and retains 83 as nonleased facilities and systems.

"*Completed remedial actions for WAGs I and 7, These nonleased facilities and systems include which include the C-746-K inactive sanitary landfill and other areas. "*portals (vehicular and pedestrian),

"*security fencing,

"*Treated approximately 174 million gallons of "*holding ponds, contaminated groundwater. "*warehouses (active and inactive),

"*five groundwater treatment facilities,

"*Completed the remediation process on two "*RCRA Part B-permitted Hazardous Waste 10,000-gallon underground storage tanks Storage Facility, installed during the 1950s. "*DUF 6 cylinder storage yards,

"*SWMUs,

"*Obtained regulatory approval for the Remedial "*administrative facilities, Design Report, Remedial Action Work Plan, "*facilities leased by DOE to the Ohio Army and Construction/Quality Control Plan for National Guard, and application of the LasagnaTm soil remediation "*inactive process facilities.

technology at SWMU 91.

USEC also leases, and is responsible for, the

"*Treated, shipped, or disposed of more than grounds in the immediate vicinity of the GDP 4,935 tons of waste. facilities within Perimeter Road as well as all roads and railroads. DOE retains, and is responsible for, most of the grounds on the 6.2 ENVIRONMENTAL, SAFETY, AND exterior of Perimeter Road and approximately HEALTH STATUS OF NONLEASED 60% of the grounds inside the Perimeter Road AREAS AT PORTSMOUTH with the exception of areas in the immediate vicinity of GDP facilities.

During FY 1999, the DOE EM and EF Programs at PORTS have continued to make 6.2.2 Construction Activities good progress. The DOE EM Program at PORTS met all 47 regulatory deliverables on schedule From April to June 1999, portions of the during FY 1999. X-744G building were completely renovated and modified to prepare for the arrival of shipments The DOE EF Program continued to manage of uranium materials from the DOE FEMP site.

DUF 6, HEU, safeguards and security, and All materials from previous work projects and maintain nonleased buildings and grounds at debris were removed from the building. The 36

structure was cleaned, the floors were sealed with The DOE DUF 6 cylinder storage yards are some a special epoxy coating, and the walls were of the more important nonleased areas from an painted up to 14 feet high. A loading dock was ES&H perspective. DOE stores more than added to the north side of the building, and 16,000 cylinders, including approximately 13,400 85 cubic yards of concrete were added to the full DUF 6 cylinders. The remaining cylinders entrance to the loading dock. The X-744G include cylinders with residual materials, empty renovation turned 70,000 square feet of cylinders, and 2,653 cylinders transferred from contaminated Radiological Work Permit (RWP) USEC upon privatization.

controlled area into a clean, freshly painted, well lit storage area. Material from Fernald is now As discussed in Section 6.1.3, DOE has stored in a clean, accessible and easily monitored improved ES&H conditions and other aspects of storage area. Since this large area has been cylinder management through its response to renovated, there is a substantial reduction in areas DNFSB recommendation 95-1 and Director's to be surveyed and less chance for personal Findings and Orders (DF&Os) with Ohio EPA. In contamination. response to concerns about the manner in which DUF 6 cylinders were stored, by the end of Construction of an expansion of the X-745C FY 1998 all DOE-owned cylinders had been West DUF 6 cylinder storage yard is scheduled to moved and restacked with the exception of the begin in October 1999. When complete, the 2,653 full DUF 6 cylinders that were transferred to storage yard will provide approximately 3.5 acres DOE when USEC was privatized. The goal is to of additional storage capacity to relocate DUF6 restack 1,000 of the 2,653 cylinders by the end of cylinders at PORTS. The cylinders, which are September 2000 and the remainder in FY 2001.

currently stored on USEC space, recently To provide additional information about the reverted to DOE ownership under terms of a current status of cylinders, PORTS performed DOE/USEC MOA. Construction of the new yard ultrasonic wall thickness measurements on 150 is planned to be completed in March 2000. DOE-managed cylinders during FY 1999. Finally, to provide additional assurance that the cylinders A small project to add a handicapped ramp to remain in a safe condition, cylinders are visually the DOE Public Environmental Information inspected either annually or quadrennially.

Center, which is located in a modular complex on PORTS completed annual inspections on the west side of the plant, was completed in 11 cylinders and quadrennial inspections on May 1999. Students from the local vocational 5,991 cylinders. Quadrennial inspections far school's carpentry class built the ramp and exceeded the goal of 3,725 cylinders by the end installed it at the site. of September-1999.36 6.2.3 Depleted Uranium Hexafluoride NE has finalized a Programmatic Management Environmental Impact Statement (PEIS) to determine a recommended alternative for The DOE EF Program is responsible for dispositioning the inventory of DUF 6 in storage at management of DUF 6 generated at PORTS from PORTS, PGDP, and ETTP. Several meetings the start of enriched uranium production in 1954 have been held with the public and industry until the privatization of USEC in July 1998."5 36 "Some cylinders have been identified as requiring more frequent inspections than others, thus some cylinders are 35

" See footnote 28. inspected on an annual rather than a quadrennial basis.

37

representatives on this program, including a DOE's SER comments relating to the public meeting at PORTS on February 26, 1998, September 30, 1995, version of the SAR.

and an industry meeting in Cincinnati, Ohio, on Although the 1995 SAR covered both leased and June 29, 1998. The final PEIS was issued in nonleased facilities, the updated 1997 SAR, at the April 1999, and a Record of Decision (ROD) was direction of DOE, focuses on nonleased facilities.

issued in August 1999. (See Section 5.2.) The 1997 SAR update concluded that with implementation or continuation of controls DOE issued a Draft Request for Proposals in identified in the 1995 SAR, operations in late July 1999 for the construction of DUF 6 nonleased facilities and areas can be conducted conversion facilities at PGDP and PORTS. Both safely with adequate protection provided for conversion plants are expected to be operational health and safety of the public and employees as by December 31, 2004. well as protection of the environment. DOE is in the process of reviewing the 1997 SAR update.

EF activities at PORTS were projected to cost $30.49 million in FY 1999. The proposed 6.2.5 Environmental Restoration budget for FY 2000 is $15.5 million. The completion of the HEU Suspension and Removal The PORTS ER Program has made extensive Program under the EF Program will significantly progress in recent years in remediating reduce the Safeguards and Security costs to DOE contaminated areas of the plant site. Two consent in FY 2000. In recent years, overall expenditures orders signed in 1989, one between DOE and the on EF Program work at PGDP, PORTS, and Oak State of Ohio and the other between DOE and the Ridge have declined from approximately USEPA, provide the regulatory framework for

$124 million in FY 1995 to $64 million in remedial actions. The Administrative Order by FY 1999. The majority of the decrease has been Consent with the USEPA was amended in August related to the completion of the HEU Suspension 1997 to include the Ohio EPA as a party to the and Removal Program at PORTS. However, other agreement and to delegate day-to-day oversight to EF program activities at all three sites have been the state agency. In March 1999, the Ohio Order impacted by this trend. Construction of some was further amended to integrate on-site work concrete cylinder yards will be deferred for the covered under various regulations and third year in FY 2000. Cylinder painting, cylinder agreements. This approach avoids duplication and movements, and engineering development permits more efficient performance of sitewide activities have also been deferred. As a result, monitoring, surveillance, and maintenance DOE agreements with the prime contractor activities. The cleanup program is being regarding systems engineering requirements of conducted in compliance with RCRA and the cylinder project have not been fully applicable aspects of CERCLA. PORTS is not an implemented. NPL site.

6.2.4 Update of Safety Analysis Report The site is divided into four sections, or quadrants (I through IV), for investigation and The PORTS 1997 SAR Update was issued remedial action. Under RCRA, the cleanup at for approval to the DOE Site Office and DOE PORTS follows a three-phased approach: RCRA ORO on March 30, 1998. This document Facility Investigations (RFIs), Corrective establishes the authorization basis for operation Measures Studies, and Corrective Measures of nonleased facilities at PORTS. This first Implementation (CMI). Since 1990, all four revision of the SAR incorporates resolution of quadrants have been investigated, and all RFIs 38

have been approved. PORTS is now completing the completion of each pilot project. In addition, the last two phases of cleanup. As of FY 1999, the data will be incorporated into the Corrective over 450 soil borings have been taken and Measures Study documents for Quadrants I and sampled, and more than 600 groundwater II.

monitoring wells across the federal reservation have been installed and sampled, thus providing One of the pilot projects implemented a information on the extent of contamination that process called dynamic underground steam resulted from the nearly 40 years of plant stripping to extract subsurface VOCs in an area operations. These investigative studies show that of groundwater contamination on the east side of there are five groundwater plumes, all located the plant. The process rapidly accelerates VOC within the plant boundaries. The main removal by injecting steam below the surface contaminant in these plumes is the chemical through multiple wells, thus raising the solvent TCE that was used for many years in temperature of the contaminated area to a level industrial processes at PORTS. TCE has since above the contaminants' boiling point. This been replaced with a more environmentally heating vaporizes the VOCs and drives them to friendly water-based solvent. centrally located vacuum extraction wells. By using a process called hydrous pyrolysis As of FY 1999, PORTS has identified oxidation in conjunction with the steam stripping, 156 release sites. Contaminants include volatile contaminants not removed by the extraction wells organic compounds (VOCs), uranium, 9Tc, and can be destroyed in place by oxidation without PCBs. Trace levels of transuranic elements further treatment. In late January 1999, the actual (plutonium, neptunium, and americium) have injection of steam into the subsurface began. On been detected in sediments in Little Beaver Creek June 12, 1999, pumping and vapor extraction and in the on-site X-70 1B holding pond area. from the well field was terminated under the pilot demonstration. Pending completion of a mass Operational units, with minimal contaminants balance of the area for total TCE removed, it is and risk, will be evaluated as a part of the final estimated that approximately 68 gallons of TCE D&D of the plant so as not to interfere with was collected (or about 80% of the contaminant current plant operations. All final Corrective was removed) from the 200 feet by 200 feet area Measures Studies are to be completed by in 4'/2 months at a cost of $26,000/gallon of TCE July 2000. collected. This demonstration validated the technology for use in a variety of locations at the More than 33 cleanup projects have been site.

completed through FY 1999 at PORTS, including remediating lagoons, closing landfills, Another project tested an in situ chemical constructing five groundwater treatment facilities, oxidation and recirculation (ISCOR) process. The consolidating and closing waste storage facilities, project involves recirculation of groundwater and conducting soil remediations. Three pilot using four pumping wells located at fixed projects were approved by the Ohio EPA. These distances from a central injection well. The projects, initiated in FY 1998, are being extracted groundwater is dosed with an oxidant conducted to evaluate additional treatment and is reinjected to the subsurface to degrade technologies for applicability at PORTS and to organic compounds. During 1996, an initial remove sources of groundwater contamination. treatability study involving injection and Data from the pilot projects will be reviewed by recirculation of an oxidant solution through the Ohio EPA. A report will be issued following multiple horizontal and vertical wells was 39

conducted at PORTS. The new ISCOR pilot action process, which factor cost, reliability, and project incorporated lessons learned from the effectiveness over time into the decision process.

previous test and other related laboratory and field data. Field activities for this project, which Each of these projects was selected to began in July 1998, were completed in provide essential technical information that will March 1999. Treatment was performed in two be used to expedite remedial action decisions for locations to demonstrate (1) general area cleanup treatment of the four remaining groundwater (X-770 facility) and (2) final remediation design plumes that are located within plant boundaries.

scale (X-626 facility). In both locations, evidence Data collected from these demonstrations will of contaminant delivery was observed and also be provided to other DOE sites.

destruction of contaminant verified. This demonstration validated the technology for use in A phytoremediation project was selected as a variety of locations at the site. Additional the CMI alternative for Quadrant III and was knowledge was gained on sitewide applicability completed in FY 1999 at PORTS.

and design limitations. Phytoremediation uses the natural growth process of plants to treat contaminated soils, and A third pilot project tested the effectiveness groundwater. At PORTS, 765 hybrid poplar trees of a vacuum-enhanced recovery method in were planted to remediate a small TCE extracting contaminants from groundwater and contaminated groundwater plume on the west saturated soils at the south end of the plant side of the plant. Fieldwork began in April 1999 property. The primary contaminant was TCE. and was completed in late May 1999. The trees During this project, approximately five vacuum are expected to remove the contaminants in the vapor and groundwater extraction wells were plume naturally within 10 years, thus saving more installed in stages at various locations to than $31 million by eliminating the need to determine (1) the ability of the technology to construct and operate a conventional groundwater remove water and generate vapor flow through pump-and-treatment system for 30 years.

tight clay soils, (2) the well spacing needed for optimal dewatering in a full-scale project, and Also in FY 1999, work began to cap the (3) the vertical distribution of contamination. The X-734 Landfill in two phases. Phase I includes objectives of the pilot project were to provide capping of the southern portion of the X-734 design parameters for full implementation of the Landfill closure which was completed in technology at PORTS and to achieve contaminant September 1999. Phase II design work on the mass removal in the groundwater plume. Field northern portion was 95% complete by the end of activities began in mid-August 1998 and were FY 1999 with the final landfill cap construction completed in early November 1998. The to be completed in FY 2000.

objectives, to provide design parameters and achieve contaminant mass removal, were In other actions, the Quadrant I Final Cleanup effectively met. The final report was issued in Alternatives Study/Corrective Measures Study February 1999. Data collected from the project (CAS/CMS) report was submitted to the Ohio indicate that this technology is more effective EPA on May 28, 1999. The Quadrant II than conventional pump and treat strategies. CAS/CMS report was combined with a report for Comparisons of this technology with others are another unit, the X-701B CAS/CMS report. This made in the Corrective Measures Studies being report, which includes data from the pilot completed at the site under the RCRA corrective projects, was submitted during the last quarter of 40

FY 1999. The Ohio EPA issued the Decision "*treatment of 6.1 tons of PCB mineral oil, and Document on Quadrant III on May 18, 1999. The "*treatment of 87.8 tons of wastewater through Quadrant III CAS/CMS was the first on-site wastewater treatment facilities.

quadrantwide report to be approved for PORTS.

The Quadrant IV CAS/CMS final report was The budget for WM activities at PORTS was submitted to the Ohio EPA on August 21, 1998. $16.46 million for FY 1999. For FY 2000, the proposed budget is $11.06 million. Continuing Continued reductions in funding for ER reductions in budget could result in extensions to activities at PORTS could result in extensions to the outyears for completion of the WM program.

the outyears for completion of the ER program.

Even though the proposed budget for FY 2000 is 6.2.7 DOE Material Storage Areas approximately $5 million higher than the FY 1999 funding of $21.9 million, with levelized On December 31, 1996, DOE and USEC funding the completion of the overall PORTS ER entered into two MOAs, one at each GDP, program is expected to slip to FY 2007 in delineating the responsibilities of DOE and comparison to the originally scheduled USEC regarding DMSAs. Under the Lease, DOE completion date of FY 2002. had retained the option to leave certain materials in the leased space. DOE and USEC agreed that 6.2.6 Waste Management DMSAs would be established in response to NRC's request indicating that such a change The mission of the PORTS WM program is would facilitate certification of the GDPs. These to treat, store, and dispose of all legacy DOE DMSAs, although located in space formerly waste in compliance with applicable federal, leased to USEC, are now located in space state, and local ES&H regulations in a manner retained by DOE and are under the regulatory that protects the health and safety of the public, oversight of DOE. USEC and DOE identified the the work force, and the environment. PORTS has areas to be established and, under the MOA, implemented ongoing recycling programs that established 44 DMSAs at PORTS. The DMSAs focus on paper products, aluminum cans, and are located both inside of USEC-leased buildings scrap metal. and within certain USEC-leased outdoor areas.

The DMSAs contain various types and pieces of PORTS has also implemented many operating equipment as well as PCB wastes.

noteworthy pollution prevention initiatives, and Since December 31, 1996, DOE has inventoried several of the DOE environmental cleanup the non-PCB DMSAs. Inventories for PCB activities have resulted in off-site shipment of DMSAs are tracked using the PORTS waste significant quantities of waste and recycling of tracking data base.

materials. In particular, the following activities were completed in FY 1999: 6.2.8 Environmental Status

"*disposal of 1,090 tons of soils from remediation DOE requires that all its sites conduct and projects, document environmental monitoring and

"*disposal of 950 tons of X-701B sludge, surveillance on the basis of DOE Order 5400.1,

"*recycle of 127.3 tons of radioactively General EnvironmentalProtectionProgram.

contaminated empty drums, DOE's environmental monitoring program at

"*recycle of 5.3 tons of fluorescent light bulbs, PORTS includes groundwater and surface water.

• recycle of 4.1 tons of nickel-cadmium batteries, Approximately 100 monitoring wells are sampled 41

routinely to maintain compliance, monitor the Board of Review due to radiological limits in effectiveness of corrective actions, and track the the permits. During the first half of FY 1999, movement of groundwater plumes. DOE's annual three air permits were not renewed, and two site environmental report for PORTS documents permits were withdrawn because DOE no the results, which verify compliance with permits longer operates these sources. Because actual and applicable laws. emissions are at levels that cannot be detected by instruments, the emissions are modeled Environmental permits for DOE projects and rather than monitored. No violations of air activities at PORTS that do or could potentially permit limits occurred during FY 1999.

require monitoring include:

In November 1998, DOE and its M&I

" National Pollutant Discharge Elimination contractor finalized a document titled Integrated System (NPDES) permit under the Clean Water GroundwaterMonitoringPlan (IGWMP). The Act from the Ohio EPA. The current NPDES IGWMP integrates into a single, unified permit, which includes six outfalls, was document the regulatory and technical effective September 1, 1995, through March 31, requirements for wells and units within a given 1999. A renewal permit application was groundwater contamination AOC. Economies of submitted to Ohio EPA prior to the expiration scale are established for groundwater monitoring of the permit. Ohio EPA has given DOE written by focusing activities over larger areas rather than approval to continue operations under the terms on individual wells or waste management units of the expired permit until a new permit can be within an area. Specifically, the identity and issued. Outfalls 012, 013, and 015 are point location of the appropriate subset of monitoring source discharges to waters of the state. The wells, the identity of constituents for sampling, effluent from Outfalls 608, 610, and 611 are and the frequency of sampling are determined on treated by the X-6619 wastewater treatment the basis of an evaluation of historical monitoring facility. This facility is leased by USEC and results, process knowledge, and other information monitored through USEC Outfall 003 before and requirements from previous investigations reaching waters of the state. There were no conducted at PORTS.

exceedances during FY 1999. The regulatory limits for environmental releases related to The IGWMP was approved by the Ohio EPA DOE activities at PORTS have not changed on January 27, 1999; however, the IGWMP was since last year.37 approved with a provision that it could not be implemented until the development and

" Air permits under the Clean Air Act from the negotiation of an Ohio EPA DF&O. It was Ohio EPA. As of September 30, 1999, DOE determined that the DF&O would allow for the holds three air permits at PORTS, two of which integration of the postclosure and corrective are under appeal with Ohio's Environmental action groundwater monitoring. The DF&O was also developed to recognize that a substantial portion of the tasks required under existing approved closure plans for several closed landfill "For a description of the regulatory limits for environmental releases, the reader is referred to the report units (X-616, X-735N, X-735S, X-749N, X-749S, entitled Departmentof Energy Input to the Nuclear and X-749A) have been completed, to provide for Regulatory Commission's Annual Report to Congress the incorporation of the remaining tasks into the Regarding the Status of Health, Safety, and Environmental approved IGWMP and a Surveillance and Conditions at the PaducahandPortsmouth Gaseous Diffusion Plants, DOE/ORO/2059, dated October 1997.

42

Maintenance Plan, and to terminate any further PORTS. The DF&O was signed by the Director obligations under the existing closure plans. and journalized on March 18, 1999.

Several exemptions in the DF&O to the 6.2.9 Safety and Health Status requirements contained in the'Ohio Administrative Code (OAC) were required to The average radiation exposure for DOE's allow the integration of the closure and corrective prime contractor and subcontractor employees at actions mandated for the integrated units. The PORTS was 0.95 mrem/year, with 156 personnel exemptions were needed to facilitate the monitored in CY 1998. Trending was performed, integration process including deferring the timing and doses have not varied over the last 5 years and procedural requirements applicable to the and have consistently averaged well below integrated units. Several exemptions to the 100 mrem/year compared with the 5,000 mrem requirements contained in the OAC were also occupational exposure limit set by federal law in required to allow the integration of all required 10 CFR 835. No individuals received radiological groundwater monitoring at PORTS and the exposures in excess of regulatory limits. For postclosure surveillance and maintenance comparison purposes, refer to the discussion of activities at the closed landfill facilities. Specific radiation exposure for PGDP in Section 6.1.9.

exemptions to be granted in the DF&O addressed the submittal of monitoring reports, the submittal During the period from October 1, 1998, of inspection reports, and the schedules for through September 30, 1999, the DOE prime conducting monitoring of selected parameters. contractor at PORTS experienced one RII that Other exemptions addressed the requirements for resulted in one Lost Workday Case (LWC).

submitting closure plans and postclosure plans, Subcontractors, including the USEC hourly submitting closure and postclosure certification workforce, experienced seven RIIs, one of which reports, and the time requirements for submittals resulted in a LWC. The leading causes of injuries and performance of activities. The DF&O sets are slips, trips, pinch points, and strains.

forth new timeframes for the submittal of documents and for the completion of corrective 6.2.10 Reportable Occurrences actions for the integrated units that are consistent with the schedules approved pursuant to the From October 1, 1998, through Consent Decree and any corrective actions September 30, 1999, 15 incidents occurred in the selected in the Decision Documents for each of nonleased areas at PORTS that were sufficiently the four Quadrants at PORTS. Decision serious to be classified as reportable ES&H Documents are the terms for final cleanup occurrences by DOE. Fourteen incidents were decisions under RCRA and are similar to a ROD classified as "off-normal" and one classified as under CERCLA. "unusual." Several of the occurrences were determined to be potential noncompliances with Throughout late 1998 and early 1999, DOE PAAA regulations, but none were assessed by and its M&I contractor negotiated the DF&O DOE as PAAA violations. Four of the reportable with the Ohio EPA. The Orders allowed for the occurrences involved violations of NCS implementation of the IGWMP and the Integrated procedures or indicated NCS programmatic Surveillance and Maintenance Plan to more deficiencies. None of these occurrences resulted efficiently perform sitewide groundwater in a criticality. This is an improving trend as monitoring and surveillance and maintenance compared to the previous year results, both in activities at the closed landfill facilities at reportable events and NCS-related events.

43

Reduction of occurrences is a result of additional Continuing reductions in budget could result worker training and emphasis on NCS in extensions to the outyears for completion of compliance. Appendix B.2 summarizes the the EM program. No NOVs or noncompliances reportable occurrences at PORTS for FY 1999. have resulted from these reduced funds, nor have any impacts to ES&H conditions been identified; 6.2.11 Summary however, maintenance services to facilities have been reduced, and projected completion DOE accomplishments and initiatives to schedules are being impacted for ER work.

enhance and improve ES&H condition at PORTS during FY 1999 include, but are not limited to, the following: 7. COMPLIANCE WITH APPLICABLE LAWS

"*Good progress in the ER, WM, and EF programs at PORTS. During FY 1999, several potential PAAA noncompliances were reported at PGDP and

"*Removal of the HEU materials from the site PORTS, as discussed in Sections 6.1.10 and was completed ahead of the September 30, 6.2.10. Some environmental permit violations 1999, schedule. have occurred in the past year as discussed in Section 6.1.8 and Appendix B. 1. PGDP received

" The total waste inventory has been reduced by an NOV in late September relating to a failure to more than 4 million pounds in FY 1999 through provide timely notification to the KDEP that off-site shipments, recycling, or on-site waste excavation was going to take place in accordance treatment. with the excavation permit. PORTS received an NOV relating to modifications in an ER report to

" Several environmental restoration projects were the Ohio EPA. Meetings were held in 1999 with completed during the year, including three pilot DOE and Ohio EPA to discuss this issue.

treatment projects that are providing valuable Incidents occurred at both GDPs involving errors information for evaluation in the final cleanup on shipping manifests and exceedances of OSHA alternatives studies. exposure limits. These incidents are described in Appendix B. In all these instances, actions were

"*No environmental noncompliances occurred at taken to notify appropriate authorities, identify the site. the cause of the violation, and institute corrective measures.

44

APPENDICES 45

46 A.

SUMMARY

OF DOE REGULATORY OVERSIGHT PROGRAM INSPECTION REPORTS A-1

A-2

SUMMARY

OF DOE REGULATORY OVERSIGHT PROGRAM INSPECTION REPORTS Inspection Areas Examined Results Report No.

70-7002/98-053s Six HEU-related problem reports and six No violations of the Nuclear Safety and functional areas (Managerial Controls Safeguards and Security requirements of the and Oversight; Operations; Radiation ROA or deviations from commitments made to Protection Programs, Systems, Designs, DOE were identified. Inspection Follow-up and Permits; Nuclear Criticality Safety; Items 70-7002/98-03-05, "Nuclear Criticality Emergency Preparedness; and Security). Training Issues," and 70-7002/98-03-08, "Root Cause Program," were closed.

70-7002/98-06'9 One event report, seven HEU-related No violations of the Nuclear Safety and problem reports and five functional areas Safeguards and Security requirements of the (Managerial Controls and Oversight; ROA or deviations from commitments made to Operations; Radiation Protection DOE were identified. An unresolved item (70 Programs, Systems, Designs, and 7002/98-06-01) was established to track Permits; Nuclear Criticality Safety; and closure of revision of NCSA-PLANT Security). 006.A04.

70-7002/99-0140 Ten HEU-related problem reports and six Several activities were identified as being in functional areas (Managerial Controls violation of Nuclear Safety and Safeguards and and Oversight; Operations; Radiation Security requirements of the ROA. Because of Protection Programs, Systems, Designs, prompt and aggressive corrective actions, no and Permits; Nuclear Criticality Safety; NOV was issued with regard to these Emergency Preparedness; and Security). activities. Three noncited violations: 70 7002/99-01-01 and 70-7002/99-01-02 relating to NCS posting and labeling concerns and 70 7002/99-01-03 relating to a failure to have up to-date Emergency Packets were identified.

Four Inspector Follow-up Items were identified. These items all related to other concerns associated with Emergency Packets.

Three open items were closed: Inspector Follow-Up Items 70-7002/98-03-04, "Nuclear Criticality Safety Approvals (NCSAs)

Surveys," 70-7002/98-03-06, "NCSA Prioritization," and 70-7002/98-03-07, "Task 5 of the NCS CAP."

38 lncludes inspections conducted in September and October 1998.

39

" Includes inspections conducted in November and December 1998.

40

" Includes inspections conducted in January and February 1999.

A-3

SUMMARY

OF DOE REGULATORY OVERSIGHT PROGRAM INSPECTION REPORTS (cont.)

Inspection Report No. Areas Examined Results 70-7002/99-02"' Ten HEU-related problem reports and six No violations of the Nuclear Safety and functional areas (Managerial Controls Safeguards and Security requirements of the and Oversight; Operations; Radiation ROA or deviations from commitments made to Protection Programs, Systems, Designs, DOE were identified. One noncited violation, and Permits; Nuclear Criticality Safety; 70-7002/99-01-03, "Non-cited Violation, Emergency Preparedness; and Security). Emergency Packet," was closed. Five previous Inspector Follow-up Items were closed: 70 7002/98-03-03, "Nuclear Criticality Safety Approvals (NCSAs) Spacing Inconsistencies";

70-7002/99-01-01, "Emergency Packet Phone List"; 70-7002/99-01-02, "Emergency Packet Effective Date"; 70-7002/99-01-03, "Emergency Packet Hazardous Materials List";

and 70-7002/99-01-04, "Emergency Packet Pre-Fire Plan."

70-7002/99-0342 Twenty-seven HEU-related problem Two activities were identified as being in reports and five functional areas violation of Nuclear Safety and Security (Managerial Controls and Oversight; requirements of the ROA. An NOV (70 Operations; Radiation Protection 7002/99-03-0 1) was issued with regard to a Programs, Systems, Designs, and failure to adhere to nuclear criticality safety Permits; Nuclear Criticality Safety; and (NCS) labeling requirements and a failure to Security). maintain NCS spacing requirement in the 5 inch-cylinder cleaning area of the X-705 West Annex. One noncited violation, 70-7002/99 01-01, "Nuclear Criticality Safety Posting,"

was closed.

70-7002/99-0441 Five HEU-related problem reports and No violations of the Nuclear Safety and five functional areas (Managerial Safeguards and Security requirements of the Controls and Oversight; Operations; ROA or deviations from commitments made to Radiation Protection Programs, Systems, DOE were identified. One Unresolved Item, Designs, and Permits; Nuclear Criticality 70-7002/98-06-01, "Unresolved Item, Nuclear Safety; and Security). Criticality Safety Approval (NCSA) PLANT 006 Issue," was closed.

"4Includes inspections conducted in March and April 1999.

42

" Includes inspections conducted in May and June 1999.

"43Includes inspections conducted in July and August 1999.

A-4

B.

SUMMARY

OF REPORTABLE OCCURRENCES IN NONLEASED AREAS AT THE GASEOUS DIFFUSION PLANTS B-1

B-2

1. PADUCAH GASEOUS DIFFUSION PLANT

1. Loss of Control of Shipment. On October 14, 1998, DOE's prime contractor became aware that a package consisting of a container of two paint waste samples not intended for shipment had been picked up by a commercial package carrier on the afternoon of October 13, 1998, at PGDP. The carrier returned the package to PGDP the following morning. No DOT regulations were violated by the prime contractor, which was the shipper, because the package was not "offered for transportation in commerce." Corrective actions included preparation of a turnover checklist to be used when preparing a package for shipment to ensure that all necessary paperwork is completed, along with a procedure revision and crew briefings to address changes in the procedure.

2. PressurizedContainerDiscovered DuringSamplingActivities. On December 15, 1998, during Miscellaneous Metal Debris sampling activities, one side of the lid on a container raised 10-12 inches into the air when the container was opened. No employee injury or contamination occurred.

The contents of the container consisted of hoses and absorbent pads coated with a fine powder generated from a breached fluorine cell at the C-410 Feed Plant D&D facility. The waste was generated on August 11, 1997. When the fluorine cell breached, an acidic electrolyte mixture consisting of hydrogen fluoride, potassium bifluoride, lithium fluoride, and condensed steam was spilled on the floor, on the cell steam supply hoses used for heating the fluorine cell, and on the surrounding equipment. Soda ash, a neutralizing media, was added to the electrolyte mixture.

Sixteen containers of this miscellaneous metal debris were scheduled for radiological sampling for the evaluation of treatment options. As a corrective action, the PGDP Waste Acceptance Criteria list of potentially pressurized waste streams was updated to include these drums.

3. Kentucky PollutantDischargeEliminationSystem (KPDES)Permit KY0004049 Outfall K01 7 Exceedance. On December 31, 1998, Environmental Compliance determined that an exceedance had occurred at Outfall KO 17, which is located west of the PGDP access road. Following routine compliance sampling of the outfall, a sample was sent to an offsite laboratory for analysis. Results from an acute toxicity test indicated 1.5 Toxicity Units Acute (TUa). A retest was initiated with the next rainfall event, with results measuring 2.2 TUa. Because the toxicity exceeded 1.2 times the TUa limit of 1.0 for both samples, a Toxicity Reduction Evaluation (TRE) is required by the KPDES permit. A TRE plan and implementation schedule has been submitted to the Kentucky Division of Water and is awaiting approval. Update reports indicate that the source of the toxicity is believed to be zinc from paint used in the depleted uranium hexafluoride cylinder recoating project.

Toxicity levels in the outfall have since been tested and shown to meet the permit limits. The final occurrence report is pending State approval of the TRE.

4. Improper Shipment of Hazardous MaterialfromNon-DOE Laboratoryto Paducah Gaseous Diffusion Plant.On April 6, 1999, a shipment consisting of containers of unused sample residuals, liquid laboratory waste, and contaminated personnel protection equipment waste arrived at PGDP.

The shipment originated from a non-DOE facility in Utah. Upon arrival in Paducah, an assessment identified several errors in the shipping paperwork, material, and packaging. Errors include incorrectly prepared DOT paperwork, improper DOT descriptions, improper package marking and labeling, improper RCRA identification codes, improper CERCLA identification, incomplete Land B-3

Ban Disposal generator notification requirements, unmarked packages, and improper TSCA waste manifest information. The shipper was notified and paperwork discrepancies were corrected.

5. Cracks Discovered in Boom of Cylinder Hauler.During a routine inspection of a DOE NCH-35 cylinder hauler in early February 1999, cracks were discovered in the welds of the guide blocks that guide the hydraulic lines during extension and retraction of the boom. Engineering and Technical Services inspected the cracks and provided guidance on weld repairs. The NCH-35 manufacturer was contacted, and the manufacturer concurred with the recommended weld repair method. Repairs were initiated on April 16, 1999. On April 19, 1999, an inspection was performed which showed that the cracks extended into the boom of the cylinder hauler. It has been determined that the cracks are due to a combination of a defective weld and fatigue of the guide block weld joint on the boom over several years of service. The final report is pending DOE comment resolution.

6. FieldLaboratoryPersonnelMethylene ChlorideExposure Above OSHA Short-Term Exposure Limits. On May 27, 1999, it was determined that laboratory personnel working in a mobile field semivolatile laboratory had been exposed to methylene chloride above the 15-minute short-term exposure limit as defined by OSHA 1910.1052. Personnel monitoring using passive dosimeters followed by additional laboratory monitoring using an Organic Vapor Monitor (OVM) and Sensidyene 138 tubes showed elevated readings. The laboratory was temporarily shut down until the problem could be alleviated. It was determined that the fume hood in use was too small to allow adequate work space for the volume of samples being received. Corrective actions included installation of a larger laboratory fume hood, checking face velocities, and performance of confirmatory monitoring. Group meetings were held for all laboratory personnel to discuss the fume hood operations and capacities and to review procedural requirements. An exposure of this type is not believed to have long-term health effects. It is important to identify this exposure and to mitigate it to avoid long-term exposures that could potentially lead to health effects.

7. Near Miss: Concrete Chip Breaks FrontGlass of Track Hoe. On May 27, 1999, a track hoe with attached concrete breaker was damaged while demolishing reinforced concrete light pole foundations as part of the C-745-L Cylinder Yard construction project. Concrete chips deflected by the breaker hit the front windows of the track hoe. The bottom window was completely destroyed.

The top window was shattered, resulting in an 18-inch hole in the glass. No injuries resulted from the incident. Corrective actions included (1) ensuring that breaking areas are flagged and restricted to the equipment and operator only, and (2) placing the light pole foundation in an excavated area or depression to help prevent small concrete chips from becoming projectile hazards during the breaking process.

8. Small Bottle with Unknown Contents DiscoveredDuring Sampling. On May 28, 1999, a small green glass bottle with an eye-dropper type top was placed in secured storage at PGDP because it contained approximately one-third of an ounce of liquid and crystal mixture of undetermined content. A conservative approach was taken in case the liquid might be shock sensitive. The bottle was found in a sediment sample collected on May 28 from a lagoon on DOE property just outside the northwest comer of the plant fence. The lagoon was being sampled to determine whether it needed to be further investigated for environmental cleanup. Corrective actions for this occurrence included a procedure revision to establish a policy on how to handle unexpected items located B-4

during task performance and a revision of General Employee Training to include a statement on how to handle unexpected items and appropriate contacts to be made.

9. Unexpected Legacy PCB Contaminationin Paint Wastefrom FluorineCells. In May 1999, twenty eight fluorine cells, which had been sold to a private company in September 1998, were removed from the PGDP site. In June 1999, it was determined that the wastewater used in the decontamination of the fluorine cells was contaminated with 71 parts per million (ppm) PCBs. Paint samples were taken from six fluorine cells remaining at the plant site, and wipe samples were taken from the areas adjacent to where the paint had been removed. Results of the paint samples indicate the presence of PCBs above 50 ppm on two of the cells and below 50 ppm on four. Results of samples from the cell piping were all below 50 ppm, and all wipe sample results were less than 10 [tg/wipe. This indicates the source is the paint used on the fluorine cells and not a PCB spill.

Investigation results have not been finalized.

10. Near Miss Accident Resultingfrom Tank Being Dropped. On June 7, 1999, while an operator was using an all-terrain (ATV) forklift to transport a water poly tank from a flatbed trailer to a field drill site near the trailer, the tank slid off the tines of the forklift, spilling an estimated ten gallons of water. The only damage was to the poly tank valve; there were no personnel injuries. An investigation revealed that the tank was not positioned properly on the forklift and that the tines were not tilted back as required by procedure before the tank was removed from a flatbed trailer. In addition, the investigation revealed that the tanks being used for the job were too large, which left void space that enabled the load to shift, and that the bottoms of the.tanks were not tilt-proof.

Corrective actions included refresher training on forklift operations, a Health and Safety stand down, and purchasing new, smaller tanks with tilt-proof bottoms.

11. Work Stopped Due to Failureto Comply with Activity HazardAnalyses (AHA). On Saturday, June 19, 1999, as an electrical sub-tier subcontractor was preparing to initiate work associated with a pole-mounted transformer installation, the work was stopped because the sub-tier subcontractor did not have the proper equipment available to conduct the work. Specifically, the subcontractor had failed to bring the necessary grounding equipment to the job site. The subcontractor attempted to verify that electrical lines were deenergized by using a disconnect switch pole ("hot stick") instead of approved test equipment ("glow stick"). This activity was observed and stopped. After it was determined that appropriate test equipment was not available, work activities were suspended for the day. Corrective actions include (1) ensuring that no work will be done without appropriate communication with the M&I's Subcontract Technical Representative, (2) utilizing activity checklists for electrical work to verify that each preparatory step is performed before starting the job, (3) retraining sub-tier subcontractor employees on AHA with increased focus on ISM, and (4) replacing the electrical subcontractor superintendent with a certified/qualified individual.

12. Near Miss Associated with WAG 8/28 DrillingActivities. On July 8, 1999, as a well bailer was being lifted with a drill rig apparatus, the load swung toward the drill rig operator. The operator had to move from his work platform to avoid being struck by the slowly moving suspended load. The bailer struck the drill rig, but the rig was not damaged. No injuries resulted from this occurrence.

Corrective actions included reviewing proper hoisting and lifting techniques with field crews, revising the AHA to include instructions on orientation and proper lifting techniques of bailers and B-5

piping in general, requiring pre-task hazard reviews before starting work, and using tag/tie lines as outlined in the ANSI code.

13. Errorin Shipping Documentationfor Asbestos Shipments to C- 746- U Landfill. On July 14, 1999, a subcontractor notified Paducah Waste Operations that six shipments of asbestos waste which were made on June 9 and July 1, 1999, had not been properly described on the shipping papers. Each of the six shipments consisted of twenty cubic yards of asbestos and was covered by a separate manifest. The UN/NA identification number on the manifests, which was listed as NA2122, should have been NA2212. All other descriptions and markings were correct. It was determined that the numbers had been transposed when transferring the information from draft paperwork to DOE format. A peer review had been performed on draft paperwork, as the procedure did not specify a peer review of the final version of the documentation. A crew briefing was held to emphasize the necessity of attention to detail, and procedures have been modified to ensure that reviews are performed on the final versions of shipping documentation.

14. Investigationof Items Left at DOE C- 746-U Landfill as PotentialSecurity Threat. On August 2, 1999, items were found abandoned outside the DOE C-746 Solid Waste Contained Landfill. These items consisted of seven tires, three one-gallon containers, one car battery, and a 3-5 gallon container wrapped in Christmas paper and placed inside a clear plastic bag which was taped shut.

The PGDP Emergency Operations Cadre addressed the incident as a potential bomb threat. Because the content of the 3-5 gallon container was questionable, the PGDP security department restricted access to the area pending resolution of the incident. Analysis of the container determined there was no explosive device. Waste manifests were prepared, and the items were properly disposed.

15. Radioactive MaterialDiscoveredat C-746-S Landfill. On July 15, 1999, subcontractors discovered tar-like material oozing from the ground in an area outside the security fence near the C-746-S and C-746-T landfills. Initial radioactive contamination surveys did not detect any contamination.

During monitoring, however, on August 6, the material was determined to exhibit radioactive contamination of 8,600 dpm, which exceeds the DOE limit of 5,000 dpm for material released to the public. The area was covered with a tarpaulin and approximately one to two feet of clean soil. It was also demarcated with stanchions and rope. Corrective actions include the installation of a three-strand barbed wire fence to secure the area of concern near the landfills, and installation of two steel gates at the west entrance road to provide site access control. Other methods of controlling access to the contaminated area are being examined, and an enclosure of some type will be erected.

There were no ES&H consequences as a result of this occurrence, and no instances of personnel contamination.

16. Violation of Excavation/PenetrationPermit. On August 25, 1999, a track hoe operator performing excavation activities at the entrance road to Gate 49 struck a warning tape located 4 to 6 inches underground that marked the presence of a buried telecommunications line. The operator stopped work and notified the M&I's Subcontract Technical Representative. Excavation in the immediate area of the buried telephone line was suspended. Inquiry into the matter revealed that the subcontractor had not contacted the underground utility locator service as required by the excavation permit. The final report has not been issued.

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17. Needfor Thermoluminescent Dosimeters (TLDs) Identified. On April 22, 1999, prior to commencement of construction of a paved yard for storage of DUF 6 cylinders at PGDP, radiation dose readings were collected at the site of the cylinder yard project. [Federal regulations require that workers who are likely to be routinely exposed to radiation in excess of 100 mrem be provided with personnel monitoring. TLDs are used to monitor radiation exposure at PGDP.] The readings indicated that workers were not likely to be exposed to radiation in excess of the 100 mrem per year threshold. Consequently, workers were not issued TLDs. On May 21, 1999, construction of the paved yard began. Additional readings collected on June 4 indicated potential exposure values below the April 22 readings. Readings taken at the request of the DOE ES&H Office of Oversight Investigation team on August 30, 1999, however, indicated that there was a potential for exposure to exceed 100 mrem per year. The source of the radiation is DUF 6 contained within the DUF 6 cylinders. Before starting work on August 31, an information session to review the situation was conducted with subcontractor workers, and additional worker training was conducted. TLDs were issued at this session to workers involved with the cylinder yard construction project who were determined to have the potential to receive greater than the 100 mrem threshold dose. Discrepancies between the readings are under investigation. The final report is pending receipt of investigation results.

18. Subcontractor Working Without FallProtection.On August 31, 1999, a subcontractor employee was observed walking on top of the second tier of 48-inch UF 6 cylinders without fall protection.

Work was stopped, and an immediate stand-down was held to discuss the incident. The final report is pending approval.

19. SubcontractorLockout-Tagout Violation. On August 31, 1999, a subcontractor lifted a GeoProbe over active oxygen and propane lines. Although a lockout/tagout permit had been issued by the building owner and signed by the GeoProbe operator, the permit was removed because the building owner needed to have the lines back in service before the lift, which had been delayed, could take place. The building owner notified the M&I contractor and the GeoProbe operator of the lockout/tagout removal. Subcontractor personnel failed to obtain a lockout/tagout of the lines when they were ready to proceed with the lift. A meeting of the M&I contractor, facility owner, and subcontractor managers, and health and safety personnel was conducted at the site immediately after notification, and an investigation was begun.

20. Discovery oflmproperly Stored ClassifiedDocuments. On September 3, 1999, CRD classified information was discovered in an unapproved storage area. Details are classified in incident report PC99-15. Following discovery, the documents were properly secured.

21. Waste Area Group 3, Solid Waste Management Unit 4 Ground Water SamplingEvent. On September 24, 1999, an M&I subcontractor was using a bailer to take a water sample from an angled hollow stem auger boring in SWMU 4. When the angled boring was at a depth of 83 feet with an approximate vertical depth of 60 feet and as the bailer was being lowered, personnel heard a gurgling sound like the normal sound of a bailer filling with groundwater. Another sound, described as water trickling into the auger or a bubbling sound, was also heard. One worker then asked if others in the immediate area noticed an odor. The Health and Safety Officer, utilizing the OVM, B-7

immediately measured the area around the boring, obtaining a reading of 2,009 ppm. Work was stopped and all personnel immediately evacuated the area. Investigation into the incident is ongoing.

22. NOV Received for Failure to Comply with Permit Conditions. On August 30, 1999, as part of the C-745-L Cylinder Yard Renovation project, approximately 275 cubic yards of soil was excavated from the southern edge of SWMU 194 and moved to a spoils stockpile located in the southeastern area of SWMU 193. Although an excavation permit was in place for the work, it was determined on September 1, 1999, that prior notification of this work had not been provided to the KDEP. Work was suspended in the area and KDEP was notified. On September 29, 1999, an NOV was issued by the state for "failure to report planned changes per Conditions III.E. 10 and IV.J. I of the Hazardous Waste Permit."

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2. PORTSMOUTH GASEOUS DIFFUSION PLANT

1. Incorrect Spacing of PCB Polybottles in X-326 DOE MaterialsStorageArea (DMSA) #1. On October 1, 1998, an NCS surveillance was conducted in DMSA #1 located in the X-326 Process Building. During this surveillance, five of nine polybottles stored in the polybottle storage rack holding uranium-bearing PCB liquid were found stored from 21 to 22 inches apart, center-to-center spacing. NCSA PLANT006 requires that this material be stored no closer than the minimum 23 inches center to center. This spacing violation resulted in loss of one control; however, a single control was still in place. The root cause was determined to be design error. The rack that holds the polybottles is designed to hold small-diameter containers less than 50 inches high. These racks were not designed specifically to hold 50 inch-tall polybottles even if polybottle sleeves were used. An additional contributing cause was determined to be training deficiency. Personnel were not documented as being trained to the NCSA and operational procedures. At the time of discovery, the NCS engineer corrected the spacing of the affected polybottles. No impact on environment, safety, or health resulted.

2. Radioactive ContaminationFoundin DOE Assigned Vehicle. On October 8, 1998, during a routine final vehicle exit survey, radioactive contamination was found on the floor of a DOE-operated pickup truck. Maximum levels of 250,000 dpm/1 00 cm 2 removable contamination were discovered.

2 The radioactivity was determined to be technetium and was isolated on a 100-cm area of the floor.

Radioactive contamination was removed using standard decontamination techniques. The vehicle was released for unrestricted use. Multiple office spaces and clothing of multiple employees were surveyed and no contamination was found. The source of the radiological contamination could not be determined. There was no impact on the environment, safety, or health because the contamination was discovered before the vehicle left the limited/controlled area.

3. Small-DiameterContainerAisle Spacing Concerns. On November 12, 1998, a subcontractor performing NCS calculations assumed that the aisle spacing between double rows of small-diameter container holders was at least 6 feet center to center. The NCSA calculations accounted for a 6-foot spacing requirement, but the NCSA requirements section never documented this as a requirement.

The subcontractor preparing, reviewing, and approving the NCSA missed this oversight. The NCS staff concluded that double contingency was maintained if an aisle width of at least 51/2 /feet is maintained between double rows of small-diameter containers or an aisle width of 4 feet and 11 inches is maintained between double rows of small-diameter containers in a facility that does not have concrete walls or whose concrete walls are at least 10 feet away from the array. The NCSA has been revised to incorporate the proper flowdown of the spacing requirement. There was no impact on the environment, safety, or health as a result of this occurrence.

4. Vehicular Incident. On January 6, 1999, while responding to a sprinkler alarm in the X-3346 facility, a fire truck and protective services vehicle were involved in a collision. As emergency response personnel approached the entrance to the facility, they realized that the gate to the facility was locked. The driver of the protective forces vehicle attempted to pass the fire truck so that he could unlock the gate; however, the fire truck turned left, and struck the protective forces vehicle, causing it to skid into a steel pipe stand. The driver of the protective forces vehicle was injured and transported to a local area hospital, where he was treated and released. The protective forces vehicle B-9

was extensively damaged; the fire truck sustained minor damage. The direct cause of the accident was determined to be Personnel Error-Inattention to Detail; the root cause was determined to be Personnel Error, Procedure Not Used or Used Incorrectly. An accident investigation team was assigned to investigate the incident, and a complete inspection of the fire truck was performed before it was returned to service. There was no impact on the environment as a result of this occurrence.

5. Employee Tests Positivefor Substance Abuse. On January 13, 1999, an employee suspected of being under the influence of alcohol consented to a drug/alcohol screening. The employee tested positive for alcohol. Upon obtaining positive results, the employee was escorted from the site and denied access to security areas until an investigation was complete. Disciplinary action was taken and recorded in the employee's personnel file. There was no impact to the environment, safety, or health as a result of this occurrence.

6. Loose Contaminationon Company Clothing. Upon completion of routine batching of LEU trap material on February 27, 1999, two employees detected radiological contamination on their company-issued clothing. The contamination was at a level exceeding but less than five times the 10 CFR 835 total contamination limits. The clothing was decontaminated. The direct cause was determined to be Personnel Error-Inattention to Detail. The contamination of company-issued coveralls occurred during bulking operations of F-cans of alumina into 55-gallon drums in the X-326 L-cage area. The personnel were not wearing the required personal protective equipment as indicated by the RWP. A letter was issued to all organizations on the PORTS project stressing verbatim compliance with RWPs. Additional training was conducted on the existing Entry Control procedure. No impact on the environment, safety, or health resulted from this occurrence.

7. PressurizedDrum Lid Release. On March 5, 1999, waste handlers were removing the drum rings from a drum for waste verification. As the waste handlers loosened the drum ring, the lid blew off and landed approximately 8 feet from the drum. The drum contained carbon blocks used in a fluorine generation process. Operations were ceased and the area was isolated. A radiological survey of operators and floor was performed. No radioactive contamination or elevated chemical concentrations were identified. An equipment/material problem, personnel error, and procedure error were identified as the causes for this occurrence. Several corrective actions were implemented revising operations procedures to include safety precautions, conducting training, and purchasing safety devices to be used on various size containers. No impact on the environment, safety, or health resulted from this occurrence.

8. X-744G Near Miss. On May 27, 1999, workers were in the process of dismantling the second of two prefabricated metal buildings within the X-744G facility by unbolting panels from the angle iron bolted to the side walls. Two workers on an aerial lift platform were lifting a single roof panel when the side walls spread causing the remaining roof panels to fall. One worker was caught underneath the panels when they fell and was grazed by a panel. As the worker came out from underneath the panel, he tore his Tyveck suit. The worker was not injured, and a survey was performed to confirm that there was no contamination of his overalls or Tyveck suit. The cause was determined to be deficient work organization and planning and inadequate supervision during the performance of this work. Corrective actions included closer supervision of work activities on this project, development B-10

of a Lessons Learned and use of the Lessons Learned in contractor safety training. There was no impact on the environment, safety, or health as a result of this occurrence.

9. Eight-Inch UF6 Cylinder Larger Than NCSA Limits. On June 29, 1999, an 8-inch UF 6 cylinder shipped from the X-345 South Vault to the X-705 facility for cleaning was found to have a larger outside diameter and inside diameter than expected. The cylinder exceeded the inside diameter allowable for 8-inch cylinders as calculated in the X-345 South Vault NCSA. NCS review determined the loss of one contingency. NCS developed a revision to the NCSA to allow storage of the cylinder in the X-345 South Vault. No impact on the environment, safety, or health resulted from this occurrence.

10. Southwest CriticalityAccident Alarm System (CAAS) ClusterAlarmed in the X-345 South Vault. On June 29, 1999, the southwest CAAS cluster in the X-345 South Vault alarmed, initiating a facility evacuation and accountability. The X-345 facility was evacuated and accountability was conducted.

Appropriate emergency response personnel performed radiation monitoring in the facility. No elevated radiation readings were discovered. An investigation is in progress to determine the cause of the alarm. There was no impact on the environment, safety, or health as a result of this occurrence.

11. CriticalityAccident Alarm System-Plantwide. On July 2, 1999, it was determined that the sitewide CAAS clusters were not calibrated in accordance with Technical Safety Requirements. As a precaution, the Plant Shift Superintendent declared that the CAAS was inoperative, and an Alert was declared by the owner of the sitewide CAAS. Protective actions were taken in accordance with the Alert, and maintenance completed calibration of the clusters on July 3, 1999. Although the system is managed, repaired, and calibrated by USEC, this incident was entered into the DOE occurrence reporting system for information purposes. There was no impact on the environment, safety, or health as a result of this occurrence.

12. ContaminatedBoot. On July 27, 1999, a random internal self-assessment activity was conducted by the PCB Program. During this self-assessment activity, three pairs of government-issued work boots were surveyed for radiological contamination. During the survey activities, one pair of stored work 2

boots was found to contain one area of fixed radiological contamination at 15,000 dpm/l100 cm beta/gamma. This contamination Was located on the sole of one work boot. The last time the work boots were worn in an area requiring exit radiological monitoring was in December 1998. At that time, the boots were determined to be free of radiological contamination. Random radiological surveys were conducted on other government-issued boots with no additional contaminated items found. Field investigation did not identify any company project, procedural, or environmental conditions or deficiencies which may have caused this event. No root cause determination could be made. There was no impact on the environment, safety, or health as the contamination was fixed on the sole of the worker's boot. This incident was believed to be an isolated incident. No further corrective actions are required.

13. Misclassificationof Sample Shipment to Y-12 Laboratory.On July 26, 1999, a sample of cleaner (SIOUX A) was shipped to the Y-12 laboratory and was received on July 27, 1999. This material was classified as a Class 9 excepted quantity, and with this classification the volume limit for the B-I1

Class 9 excepted material was exceeded. The material should have been classified as a DOT non regulated shipment. The importance of the 5-day turnaround requirements was reinforced to the transportation specialist and project engineer. There was no impact on the environment, safety or health as a result of this occurrence.

14. Overflow of HEUDecontaminationWash Solution. On August 6, 1999, during an inspection of the X-326 L-Cage area, it was noted that a plastic polybottle (GP) container holding decontamination wash solution of liEU (50% assay, 50 grams plus or minus 30 grams), appeared to have overflowed causing solution to run down the side of the container and around the location where the container was being held. This was a loss of containment in a radioactive material area. Upon further investigation, it was discovered that the container contained a saturated cheese cloth that came from the X-705 Annex HEU Cylinder Cleaning Project. It was non-waste and had a radiation level count rate greater than 25,000,000 dpm/l100 cm 2 . The release material had dried when discovered. The dose rate was 2.5 mrem/hour beta and less than 0.2 mrem/hour gamma on contact. The dose rate was less than 0.2 mrem/hour beta-gamma at one foot. The condition did not exist on weekly inspection of the area. Determination is that the lid was not on tight enough, and elevated building temperatures caused internal expansion leading to the overflow. The area was bounded off. The localized area of contamination was cleaned and decontaminated. There was no impact on the environment, safety or health as a result of this occurrence.

15. Elevated Lead Exposure of Employee. On September 1, 1999, during the initiation of a recycling project for various materials, including lead liners from a chromic acid tank, a field test on the floor surface of the work area identified the presence of lead. Project activity regarding lead liners immediately ceased. The general area and breathing zone samples were collected and sent to a laboratory for analysis for lead. The project manager was verbally notified of the results which indicated that the breathing zone sample was approximately three times the OSHA Permissible Exposure Limit (PEL) for lead. Affected personnel were notified and samples to determine lead levels in their blood were initiated. All personnel tested had blood lead levels within background or normal levels. Enhanced administrative and engineering controls along with additional personal protective equipment were put into place to keep exposure levels below OSHA PEL limits. The project was restarted on September 20, 1999, and completed on September 30, 1999. There was no impact on the environment, safety or health as a result of this unusual occurrence.

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