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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.
xiii
 
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).
I
 
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).
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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.
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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.
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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.
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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.
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"*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.
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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.
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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.
19
 
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.
21
 
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.
22
 
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.
25
 
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 hours 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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Revision as of 20:46, 16 January 2022

NRC-2021-000238 - Resp 3 - Interim, Agency Records Subject to the Request Are Enclosed
ML21277A366
Person / Time
Issue date: 09/29/2021
From:
NRC/OCIO
To:
Shared Package
ML21277A364 List:
References
FOIA, NRC-2021-000238
Download: ML21277A366 (77)
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