Paducah Gaseous Diffusion Plant

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The Paducah Gaseous Diffusion Plant site encompasses 300 hectares (750 acres) inside a 1,369-hectare (3,422-acre) reservation owned by the Department of Energy. It is located approximately 8 kilometers (5 miles) west of the City of Paducah, Kentucky.

FACILITY MISSION

Construction of the Paducah Gaseous Diffusion Plant began in 1951. Initial operations began in 1952, and full operations were initiated by 1955. Currently, the Plant has two primary missions. The first primary mission continues to be the enrichment of uranium by a gaseous diffusion process. Since 1991, the plant has only produced low-enriched uranium for use as fuel in commercial nuclear power plants. On July 1, 1993, the United States Enrichment Corporation, a government corporation formed under the Energy Policy Act of 1992, assumed operation of the production portion of the plant. However, the Department of Energy retained responsibility for environmental restoration and related waste management activities, which comprise the other primary mission at the plant. These activities focus on environmental remediation efforts; environmental compliance; storage, treatment, and/or disposition of waste; and the decommissioning of inactive and surplus facilities.

In July 1988, contamination, which included detectable levels of technetium-99 and trichloroethylene, was found in an offsite drinking water well north of the Paducah Gaseous Diffusion Plant. To address immediate risks, the Department of Energy extended a community water line as an alternative water supply to residences with contaminated wells while it pursued long-term remedial actions. Two areas of ground-water contamination, or plumes, have been identified offsite of the plant (that is, Northwest Plume and Northeast Plume) with trichloroethylene levels reaching 30,000 parts per billion and technetium-99 reaching approximately 1000 picocuries per liter at offsite locations.

Waste management activities at the Paducah Gaseous Diffusion Plant are included within the scope of the Environmental Restoration program.

Landlord activities are the responsibility of the United States Enrichment Corporation and the Department of Energy, Office of Nuclear Energy, Science and Technology. This report assumes that this responsibility will continue until the shutdown of operations, when it will transfer to the Environmental Management program. This report assumes that the Environmental Management program will assume landlord responsibilities at the site in FY 2005 and will continue in this capacity until decommissioning activities are complete.

FUTURE USE

This report considered the following factors when making an assumption for future land use: stakeholder input, existing laws and lease commitments, and the nature of the environmental contamination present at the site.

The Department of Energy began preliminary discussions with stakeholders on future land use at Paducah during a public workshop on June 30, 1994. Subsequently, it discussed future land use at public workshops on December 1, 1994, January 26, 1995, and September 26, 1995. In addition, the Department has discussed the subject at various meetings with the Paducah Gaseous Diffusion Plant Neighborhood Council, the Paducah Gaseous Diffusion Plant Environmental Advisory Committee, with city and county officials, and economic development interests.

On October 24, 1992, the Energy Policy Act of 1992 became effective. This Act established the United States Enrichment Corporation, whose charter is to provide uranium enrichment services on a profitable and competitive basis at the Paducah Gaseous Diffusion Plant. The original term of the lease is for six years from July 1, 1993, with exclusive options to lease such facilities and related properties for additional periods. Lease agreements are also in place for the West Kentucky Wildlife Management Area to use certain Department of Energy properties.

Based on the complex nature of waste (for example, radionuclides, dense nonaqueous phase liquids) present at the Paducah Plant, the future use of the site may principally be Industrial. The land may never be appropriate for certain uses, such as Residential.

After considering all the above factors, the Department of Energy Site Office at Paducah considers a combination of Industrial and Recreational use as the most likely future scenario for the site. The Gaseous Diffusion Plan Turnover Contingency Alternative Missions Plan provides a preliminary list of alternative missions that may be viable options for future consideration. It suggests various strategies that could be implemented to evaluate alternative missions in detail and pursue others that may be applicable to site reuse. If additional information suggests that an alternative land use may be more appropriate, the Department will revise its land-use assumptions accordingly.

This report assumes that the institutional controls will be required for the life cycle of this estimate. Residual contamination and the need for long-term surveillance and monitoring limits options for future use, and this report assumes that the plant area will remain under Department of Energy control for governmental Industrial use. However, large portions of the surrounding buffer zone could be released for Recreational use.

The decommissioning estimate in this report assumes that all gaseous diffusion facilities will be removed to grade. The site landscape will be significantly changed with low disposal mounds where former structures stood. To the extent practical, auxiliary building rubble will be placed in one of the process building mounds. An onsite disposal cell will undergo closure and long-term monitoring. Other facilities will be reused for other restricted activities consistent with the stakeholder's land-use decision made for the site.

ENVIRONMENTAL RESTORATION

The operation of the Paducah Gaseous Diffusion Plant has produced a number of contaminated areas, both at the site and beyond its boundaries. Ground water northwest of the site has been found to be contaminated with technetium­99 and the chlorinated solvent trichloroethylene. The Reactor Fuels program, which involved the reprocessing of spent nuclear fuel, introduced technetium-99 at Paducah. Trichloroethylene was used for cleaning metal and machinery parts. Polychlorinated biphenyl contamination is present at the site and in offsite drainage ditches. Polychlorinated biphenyls were used in electrical equipment, in hydraulic systems, and as a fire retardant. In 1988, the Department implemented a Paducah Gaseous Diffusion Plant ground-water program to test residual wells exceeding regulatory levels. Municipal water is supplied to all residents with elevated contaminant levels.

The source areas where environmental releases originally occurred are often referred to as solid waste management units and areas of concern. In general, solid waste management units and areas of concern are burial grounds, spill sites, landfarms, surface impoundments, and underground storage tanks. Releases from these source areas can migrate into the surrounding soils and, in some cases, to the underlying ground water and adjacent surface waters. Subsequent investigations revealed that environmental releases from certain solid waste management units and areas of concern had migrated to the ground water and surface water, resulting in offsite contamination.

The site evaluates solid waste management units and areas of concern and groups them together into individual study areas known as Waste Area Groupings. The Paducah Plant areas under investigation have been divided into 28 Waste Area Groupings. There are 204 potential release sites (solid waste management units) from which contaminants could migrate. This report does not discuss all of the 28 Waste Area Groupings because many will require No Further Remedial Action or are not yet part of the Environmental Restoration program activities. Some Waste Area Groupings have been combined in the following text because the same remedial actions will be applied. In all cases, if the excavated soil is clean, it will be landfilled; if it is contaminated, it will be sent to offsite treatment and disposal facilities.

Several laws and regulations govern the Environmental Restoration program at the Paducah Gaseous Diffusion Plant. They include the National Environmental Policy Act; the Resource Conservation and Recovery Act; the Comprehensive Environmental Response, Compensation, and Liability Act; the Clean Water Act; and the Toxic Substances Control Act. Site-specific permits, enforcement orders, and compliance agreements further define the specific requirements of these regulations. Although all these regulations impact the Environmental Restoration program to some degree, the Resource Conservation and Recovery Act and the Comprehensive Environmental Response, Compensation, and Liability Act are considered to be the primary regulations that currently drive the majority of investigation and remediation activities at the site.

In July 1988, ground-water samples collected from residential wells north of the Paducah Gaseous Diffusion Plant detected levels of trichloroethylene and technetium­99. Polychlorinated biphenyls were later found downstream of the plant in sediment and fish.

On July 16, 1991, two separate but related permits were issued to the Paducah Gaseous Diffusion Plant: (1) Hazardous Waste Management Permit and (2) the Hazardous and Solid Waste Amendment Permit. The State of Kentucky issued the Hazardous Waste Management Permit to regulate treatment, storage, and disposal units permitted prior to the Hazardous and Solid Waste Amendment. The permit contains provisions that require corrective action for solid waste management units. The Environmental Protection Agency's Hazardous and Solid Waste Amendment Permit is limited to the Hazardous and Solid Waste Amendment provisions of the Resource Conservation and Recovery Act, including corrective action requirements for solid waste management units.

On May 31, 1994, the Paducah Plant was placed on the National Priorities List, making it a high priority for site remediation under the Comprehensive Environmental Response, Compensation, and Liability Act. A Federal Facility Agreement is being developed to integrate the cleanup process of the Resource Conservation and Recovery Act and the Comprehensive Environmental Response, Compensation, and Liability Act into a single comprehensive procedure for site remediation. The Federal Facility Agreement is expected to be signed in FY 1996.

Hazardous waste facilities are operated under Resource Conservation and Recovery Act-permitted status granted by the State of Kentucky for five storage and 15 treatment units. The Toxic Substances Control Act regulates waste containing polychlorinated biphenyls. Sanitary and inert waste is disposed of in accordance with regulations published in Kentucky Administrative Regulations. The Federal Atomic Energy Act of 1954 regulates radioactive waste without hazardous or toxic constituents and the Department of Energy Order 5820.2A (September 1988) stipulates its management.

The scope of the Environmental Restoration program includes the costs associated with the characterizing, packaging, and shipping of waste. The treatment, storage, and disposal of waste shipped offsite to commercial facilities is also included within the scope of the Environmental Restoration program at Paducah.

Major Environmental Restoration Activity Milestones

TASK	COMPLETION DATE Fiscal Year
Waste Area Groupings 1 through 28
Assessment	2035
Remedial Action	2040
Long-Term Surveillance and Monitoring	2040
Decommissioning	2025

Waste Area Groupings 1-28

ASSESSMENT

The Waste Area Groupings at Paducah are being investigated, characterized, and evaluated to determine the types of remediation that will be required to comply with Department of Energy, Environmental Protection Agency, and Kentucky State environmental regulations. Activities include well construction and sampling, work plan and sampling plan development, field investigation, laboratory analysis, risk assessment, treatability studies, and feasibility studies.

The fieldwork completed to date includes the Phase I and II site investigations associated with the Comprehensive Environmental Response, Compensation and Liability Act Administrative Consent Order, field investigations for the Northeast and Northwest Plumes, and field work for Waste Area Groupings 1 and 7. Fieldwork has started on Waste Area Groupings 17 and 6, and outfall ditches 011/012.

As a result of the information developed during the site investigation conducted under the Administrative Consent Order, the Department concluded that ground water and surface water were the primary pathways for migration of contaminants offsite. The investigations also provided sufficient data to divide the site contamination into the following categories: 1) media that presents immediate risks; 2) hot spots associated with offsite contamination; 3) suspected sources of offsite contamination; and 4) the ground-water and surface-water operable units. These categories will provide the primary framework for approaching site remediation and establishing priorities.

Actions taken to date have focused on imminent threats and hot spots associated with offsite contamination. Minimal emphasis has been placed on the contributing sources. Containment of sources prevents ongoing releases to ground water and surface water, thereby allowing cleanup of those media based on risk and cost-benefit analyses and technically feasible approaches. With existing actions under way to address imminent risks and hot spots associated with offsite contamination, the Department of Energy is in the process of shifting program focus to onsite sources of the offsite contamination, including assessment activities for Waste Area Groupings 22, 6, 1, 7, and 17 in FY 1996. This estimate assumes that assessment activities at the Waste Area Groups 22, 6, 1, 7, and 17 will be complete by FY 2002, FY 1997, FY 2020, FY 2020, and FY 2008, respectively. This report also assumes that all assessments for Waste Area Groupings will be completed by FY 2035.

REMEDIAL ACTION

Waste Area Grouping 1 includes one active training area and one trichloroethylene spill site. Waste Area Grouping 7 comprises five underground storage tanks at an active waste treatment plant and an inactive sanitary landfill. The projected remedial action for the landfill includes installation of an upgradient subsurface barrier supplemented with a leachate collection system. Based on risk assessment results, No Further Actions will be required for the rest of the solid waste management units in Waste Area Groupings 1 and 7. If remedial actions are required, treatment systems and removal/excavation technologies are currently being planned. This estimate assumes that remedial actions at Waste Area Groupings 1 and 7 will be completed by FY 2030.

Waste Area Grouping 3 consists of three inactive burial pits used to dispose of radioactive and nonradioactive trash, equipment, and scrap metal. The Department has identified this unit as a potential source of radionuclide contamination. This report assumes that the remedial action will be to cap the area. This report assumes that remedial actions at Waste Area Grouping 3 will be completed by FY 2040.

Waste Area Groupings 4 and 15 consist of underground storage tanks. Waste Area Grouping 4 consists of four inactive gasoline and diesel underground storage tanks that are suspected of leaking gasoline, diesel, and associated breakdown products. The tanks have been partially removed, and this report assumes that the remaining tanks and contaminated soil will be removed as a part of the remedial actions. Waste Area Grouping 15 consists of one underground storage tank used to accumulate waste oils, two underground storage tanks used to store petroleum products, and one No. 2 fuel oil spill area. The underground tanks will be removed, and the sites will be excavated and backfilled. This estimate assumes that remedial actions at Waste Area Groups 4 and 15 will be completed in FY 1996 and FY 2040, respectively.

Waste Area Grouping 6 includes a neutralization tank, an underground transfer line, and a trichloroethylene release site near Building C-400. Suspected contamination includes trichloroethylene and technetium-99. In-place vapor extraction is the assumed remediation for these sites. This estimate assumes that remedial actions at Waste Area Grouping 6 will be completed by FY 1997.

Waste Area Grouping 8 is located inside the northeast corner of the security fence and consists of four switch yards. This report assumes that remedial action will involve excavating the soil and backfilling the area. This estimate assumes that remedial action at Waste Area Grouping 8 will be complete by FY 2040.

Waste Area Grouping 9, located near the center of the plant, consists of four potential release sites. The first confirmed release site involves soil contamination around a pipeline and vaults at the Chromate Reduction Facility. Contaminants include polychlorinated biphenyls, uranium, and technetium-99. The second site involves an acid neutralization tank that received rinsewater from an instrument shop. The third site, the acetylene-building drain pits, received waste from an acetylene generation process. The fourth site is an acid neutralization lagoon, which receives effluents from the C-710 Laboratory. The remedial actions at these sites will involve removing the acid neutralization tank, grouting the associated drains and pipelines in place, removing contaminated soils, and backfilling areas with clean soil. This estimate assumes that remedial actions at Waste Area Grouping 9 will be completed by FY 2040.

Waste Area Grouping 10 includes the Kentucky Ordnance Works standpipe, trickling filter and leach field, burn area, and toluene spill sites. This site will be transferred to the Department of Defense after the Remedial Investigation is complete.

Waste Area Grouping 12 is associated with the chromate reduction facility that was used to treat chromated cooling water before discharge. A phosphate-based corrosion inhibitor later replaced the chromate. The facility's sludge lagoon and the full-flow lagoon contain chromium, polychlorinated biphenyls, and uranium. Remedial actions will remove the contaminants, stabilize the area, backfill it, and cover it with a multilayered cap. The Department will demolish and remove the chromate reduction facility and restore its site. This estimate assumes that remedial actions at Waste Area Grouping 12 will be completed by FY 2035.

Waste Area Grouping 13 includes four lagoons associated with the effluent waste treatment plant and an earthen berm in the southwest portion of the plant. The sediments in lagoons and the soils within and adjacent to the berm may be contaminated with polychlorinated biphenyls and mercury. When operations cease, the assumed remedial action is in-place vapor extraction to treat the lagoons. The areas will then be stabilized, backfilled, and covered with a multilayered cap. The soils at the earthen berm will be washed and removed, and the berm will be backfilled. This estimate assumes that remedial actions at Waste Area Grouping 13 will be completed by FY 2035.

Waste Area Grouping 14 consists of two scrapyards. The site uses these units to accumulate nonradiologically contaminated scrap metal. One unit is located in a former fabrication building, and the Department suspects that radiological soil contamination is present. The assumed remedial action selected for this site is material removal, and is expected to be completed by FY 2040.

Waste Area Groupings 16, 17, 19, 20, 21, and 23 are numerous potential release or spill sites. Waste Area Grouping 16 contains six areas contaminated with low-level polychlorinated biphenyls. This includes spill sites and soil backfill areas. Waste Area Grouping 17 includes 37 scattered potential release sites that consist of rubble piles. The suspected contaminants are radionuclides. Waste Area Grouping 19 consists of seven polychlorinated biphenyl spill sites. These resulted from either direct polychlorinated biphenyl spills or from movement of polychlorinated biphenyl-contaminated soil used as backfill. The contaminant of concern is polychlorinated biphenyls. Waste Area Grouping 20 consists of three soil contamination sites. These units result from either sandblasting activities or from the movement of radiologically contaminated soil used as backfill. The contaminant of concern is radionuclides. Waste Area Grouping 21 consists of seven areas where soils/sludges have been imported from contaminated areas within the Plant. The contaminants of concern include polychlorinated biphenyls, radionuclides, and metals. Waste Area Grouping 23 consists of eight polychlorinated biphenyl spill sites. These sites resulted from equipment/transformer oil spills. The contaminant of concern is polychlorinated biphenyls. The remedial action for these sites is limited removal of soil and capping, except for Waste Area Group 16, where all of the contaminated soil will be removed, and Waste Area Group 17, which will not be capped. This estimate assumes that Waste Area Groupings 16, 17, 19, 20, 21, and 23 will be completed by FY 2040, FY 2020, FY 2040, FY 2040, FY 2040, and FY 2007, respectively.

Waste Area Grouping 18 is a network of surface water discharge ditches, a monitoring station, and the Big Bayou Creek. The remedial action for these sites is selected surface water diversions and removal of hot spots of contamination. This report assumes that remedial actions at Waste Area Grouping 18 will be completed by FY 2030.

Waste Area Grouping 22 consists of four burial grounds. The site used these units to dispose of radioactively contaminated metals, uranium metal, and uranium precipitate. In 1987, the Department closed one unit with a multilayer cap and a ground-water monitoring plan under Resource Conservation and Recovery Act requirements. The contaminants of concern include solvents, radionuclides, and metals. The assumed remedial action is capping, which is expected to be completed by FY 2005.

Waste Area Grouping 24 consists of three scrapyards. The sites used these units to store radiologically contaminated scrap metal. The contaminants of concern include radionuclides and metals. The assumed remedial action is removal of the scrap and partial excavation and capping, which is expected to be completed by FY 2000.

Waste Area Grouping 25 consists of nine effluent ditches receiving discharges from the plant. The contaminants of concern include radionuclides and metals. An interim action for Solid Waste Management Unit 59 (N\S Diversion Ditch) has been completed and consists of an effluent treatment system and sediment control measures. The assumed remedial action for the remaining areas includes limited excavation and capping. The estimate assumes that remedial actions at Waste Area Grouping 25 will be completed by FY 1996.

Waste Area Grouping 26 consists of two offsite ground-water plumes, the Northwest and Northeast Plumes. This contamination results from past operations and disposal activities at the plant. The contaminants of concern include solvents and radionuclides. The site has initiated interim remedial actions, consisting of pump-and-treat systems, for both plumes. This estimate assumes that other treatments being investigated will be used, including iron filings, carbon filters, and ion exchange units. This estimate assumes that remedial actions at Waste Area Grouping 26 will be completed by FY 1999.

Waste Area Grouping 27 consists of three solvent/radiological spill sites. The contamination resulted from landfarming of oil contaminated with solvents, equipment testing, and releases of radiological material. The contaminants of concern include solvents and radionuclides. The assumed remedial action includes capping of the landfill/landfarm and removal of the septic system, and possibly limited in-situ vapor extraction. This estimate assumes that remedial actions at Waste Area Grouping 27 will be completed by FY 1997.

Waste Area Grouping 28 consists of three sites previously used during plant construction. These sites have been identified as potential sources of the northeast ground-water plume contamination. The contaminants of concern include solvents, radionuclides, and metals. This report assumes that remedial actions at Waste Area Grouping 28 will be completed by FY 1999.

Waste Area Groupings 2 and 11 require remedial action, but are currently part of the decommissioning baseline. Waste Area Grouping 2 consists of four pumphouses and cooling towers. These units are concrete wet well pump station basins associated with induced-draft cooling towers used to cool recycled cooling water from the process buildings. The site that used these units originally contained chromated water, which has now been replaced with phosphate water. Waste Area Grouping 11 consists of two impoundments and one tank. The site used these units, located at the C-410 building, for acid neutralization. The potential contaminants of concern include radionuclides and metals. This report assumes that remedial actions at Waste Area Groupings 2 and 11 will be completed in FY 2040 and FY 2035, respectively. This report also assumes that decommissioning activities at these Waste Area Groupings will be completed by FY 2035.

Decommissioning

This report assumes that when uranium enrichment processes are no longer needed, the Department will shut down and decommission the Paducah Gaseous Diffusion Plant. Under provisions in the United States Enrichment Corporation lease, stabilization and shutdown activities are the responsibility of the Enrichment Corporation, except for legacy contamination. During the transition phase, the Department of Energy's Environmental Management program will remove all polychlorinated biphenyl-containing oils, lube oils, Freon, and other hazardous materials and uranium deposits from the facilities.

The Department has recently used several different scenarios to reevaluate the estimate for decommissioning the gaseous diffusion facilities. The scenario described in this report uses a new approach for recycling process equipment and other radioactive metals into usable products. It also includes the onsite disposal of low-level and mixed radiological waste.

The regulatory strategy for decommissioning is based on the May 22, 1995 joint Department of Energy and Environmental Protection Agency policy on decommissioning under the Comprehensive Environmental Response, Compensation, and Liability Act. This policy provided guidance that indicated a preferred method of conducting decommissioning actions at Department of Energy sites, namely that these activities would be conducted as nontime critical removal actions with the associated Engineering Evaluation/Cost Analyses and Action Memorandums prepared to document the decisions. Under the Comprehensive Environmental Response, Compensation, and Liability Act actions, the analyses will have to incorporate National Environmental Policy Act values and comply with the substantive provisions of all applicable or relevant and appropriate requirements, including public involvement.

As noted in the National Contingency Plan, the Comprehensive Environmental Response, Compensation and Liability Act process provides for compliance with the substantive provisions of "applicable or relevant and appropriate requirements" unless compliance waivers are obtained from the appropriate regulatory agencies. Additionally, onsite Comprehensive Environmental Response, Compensation, and Liability Act actions are exempt from permits. In reference to decontamination and decommissioning, this would mean that permits would not be required for air emissions, wastewater discharges, or similar activities. Instead, the substantive portions of the laws governing these resources would be applicable, and the removal process would not be delayed because of lengthy permit review and approval requirements.

This report assumes that the facilities have gone through the transition phase paid for by United States Enrichment Corporation prior to the decommissioning. During this transition phase, it is assumed that all polychlorinated biphenyl-containing oils, lube oils, freon, and other hazardous materials and uranium deposits are removed from the facilities.

The first major phase of decommissioning will be the removal of the major components from the process buildings. These major components include motors; cell housing and structural framing; compressors and converters; piping and valves; instrumentation, instrument panels, and tubing; support equipment; electrical equipment; utilities systems and ventilation systems. In general, all equipment will be removed in one piece unless it is more efficient to section for removal. The process piping and equipment will be cut loose so that it can be removed from the cell. This report assumes that adequate purging and the use of portable high-efficiency particulate air ventilation systems will allow personnel to work without respirators.

Safeguards and security requirements, including nuclear material control and accountability practices for enriched uranium, are streamlined to the extent necessary to allow the equipment removal and recycle contractors to perform their work unimpeded and efficiently. Contamination control procedures will be adhered to so that the removal process does not cause trackout problems or additional cleanup work before the structure can be demolished.

Following the removal of the equipment, the Department will remove loose contamination from the internal structural components (for example, walls, floors, roofs) with a water spray and/or steam cleaning. The wash water will be collected, recycled to the extent possible, treated, and discharged. The Department will dispose of sludges in the onsite disposal cell.

Buildings constructed with transite siding will require removal of these asbestos-containing materials prior to structural demolition. The transite siding and other building materials will be wrapped properly and placed in storage prior to the demolition of the above-grade structure.

All of the Gaseous Diffusion Process Buildings will be demolished down to the concrete slabs. Nonprocess buildings, buildings that contain nonradiologically contaminated equipment, and process buildings can be demolished by conventional means (heavy equipment such as wrecking balls). In most cases, segregation of structural steel for recycle will take place during demolition or from demolition rubble using heavy equipment. Demolition rubble will be used for in-place backfill in cavities and/or left on the slabs-on-grade and covered with a vegetative layer. All below-grade structures remain with utility lines conduit, trenches, etc. capped off and left in place. The demolition fill will not be placed in a manner that will provide an adequate foundation for future development; however, no free liquids will be left in the rubble.

The Department will transport metal materials removed from the buildings, including structural steel removed during building demolition, to Nuclear Regulatory Commission-licensed recyclers. The metal will be disassembled as necessary, sized, smelted, milled, recycled where economically feasible, rolled and fabricated into use for products such as storage and disposal boxes, barrels and pallets. The Department will transport melt slag and any unused metals back to Paducah for disposal. Radiologically contaminated metal waste from recycling will be disposed of in the onsite disposal cells.

Small levels of fixed radioactive contamination will remain on building structures (mainly concrete). An assessment of the amount of residual contamination left at the building sites will be performed in the Streamlined Risk Evaluation in the Engineering Evaluation/Cost Analysis to ensure that contamination left onsite will not pose an unacceptable risk to human health and the environment. This report assumes that all decommissioning activities will be completed by FY 2025.

Treatment, Storage, and Disposal

The Environmental Restoration program directs the safe treatment, storage, and disposal of waste generated by past operations and current environmental restoration projects. The United States Enrichment Corporation has operated the Paducah Gaseous Diffusion Plant since July 1993 and is responsible for waste from normal plant operations. Waste generated by operations prior to July 1993, as well as environmental restoration-generated waste, remain the responsibility of the Department of Energy.

All waste generated is characterized and labeled by type at the site of generation. All waste shipped offsite for disposal must be certified to meet the acceptance criteria for disposal at the particular disposal facility. Because of the nature of the work performed at the Paducah Gaseous Diffusion Plant, the following waste types are generated and stored at the onsite: low-level radioactive waste, hazardous waste, low-level mixed waste, polychlorinated biphenyl waste, polychlorinated biphenyl-radioactive waste, asbestos waste, and conventional sanitary waste.

Waste minimization activities at the Paducah Gaseous Diffusion Plant consist primarily of recycling projects and segregation techniques. Current recycling projects involve cardboard, aluminum cans, waste office paper, and spent fluorescent light bulbs. Projects being prepared are recycling polychlorinated biphenyl materials, such as transformers and capacitors for the metal, and recycling the lead metal waste stream from lead-acid batteries. Other projects such as scrap metal recycling are still in the planning stages.

This report assumes that the Department of Energy will leave approximately 55 cubic meters (72 cubic yards) of transuranic waste and 244,120 cubic meters (319,797 cubic yards) of low-level mixed waste from the Paducah Gaseous Diffusion Plant remedial actions and decommissioning in the areas of containment. All other waste will be treated and disposed of offsite or placed in the onsite disposal cell.

Low-level and mixed radiological waste from decommissioning the Paducah facilities will be disposed of in an engineered facility. The engineered disposal cell will be located onsite so that any resulting low-level waste or mixed waste generated from the recycle process can be placed in the cell. Instead of the traditional permitting process, a Comprehensive Environmental Response, Compensation, and Liability Act Remedial Investigation/Feasibility Study, followed by a Record of Decision, will be used to determine the acceptability for siting the onsite disposal cell. An assessment of the risk of the onsite disposal cell will be performed as part of the Comprehensive Environmental Response, Compensation, and Liability Act process. One of the goals of this process is to pre-qualify the waste for placement in the onsite disposal cell and to identify any waste streams that are not appropriate for onsite disposal.

The generation rate for low-level mixed waste at the Paducah site during 1994 was approximately 50 cubic meters (65.5 cubic yards). Mixed waste generated includes liquids, solids, sludges, and soil contaminated with hazardous waste and polychlorinated biphenyl constituents. The types of waste that will be accepted for mixed waste storage at the Paducah site are identified in the Resource Conservation and Recovery Act Part-B Permit. The Paducah Gaseous Diffusion Plant Site Treatment Plan outlines plans and schedules for treatment of mixed waste. Liquid mixed waste treatment at the K-25 Site Toxic Substances Control Act Incinerator totaled approximately 322,200 kilograms (716,000 pounds) for FY 1995. Approximately 1,090 cubic meters (1,428 cubic yards) of mixed waste is inventoried and stored at the Paducah site. Waste storage facilities consist of four Resource Conservation and Recovery Act-permitted units. A fifth storage facility will be operational by May 1996 and will provide roughly 900 cubic meters (1,179 cubic yards) of additional mixed waste storage space. No mixed waste is currently being disposed of onsite. Plans are currently under way to ship mixed waste to Envirocare of Utah for disposal. The first shipment took place in the summer of 1995. Shipment of liquid mixed waste to the K-25 Toxic Substance Control Act Incinerator will continue in FY 1996. Decommissioning waste will be disposed of in the onsite disposal cell.

This baseline report estimates that approximately 212,860 cubic meters (278,847 cubic yards) of solid low-level mixed waste (mostly soils) will be generated by remedial actions will remain in the area of containment during the life cycle of this estimate. This report assumes that approximately 330 cubic meters (432 cubic yards) of liquid low-level mixed waste will also be generated by remedial activities.

This report further assumes that approximately 9,854 cubic meters (12,909 cubic yards) of solid transuranic waste and 767 cubic meters (1,005 cubic yards) of liquid transuranic waste will be generated during remedial action and decommissioning activities. Most of this waste is in the form of mixed transuranic contaminated soil. All transuranic and mixed transuranic waste will be temporarily stored onsite until it can be shipped to the Waste Isolation Pilot Plant in Carlsbad, New Mexico.

Low-level waste generated at the Paducah site is primarily uranium-contaminated materials. During FY 1994, the Paducah site generated 685 cubic meters (897 cubic yards) of solid low-level waste. All solid low-level waste generated is placed in storage. Liquid low-level waste is placed in storage to await onsite treatment. No solid low-level waste is treated onsite. Liquid low-level waste (wastewater) may be treated onsite at the carbon filtration unit or the lime precipitation unit. Low-level nonwastewater is also not treated onsite. The Paducah site low-level waste storage facilities consist of modified portions of former uranium enrichment process buildings and the use of outside storage areas. Approximately 5,700 cubic meters (7,467 cubic yards) of low-level waste is stored onsite. Additional low-level waste storage space will be provided onsite because of the construction of the new environmental restoration waste storage facility, which will provide roughly 460 cubic meters (603 cubic yards) of storage area. No low-level waste is disposed of at the Paducah site. Future disposal for low-level radioactive waste generated at Paducah will be provided by offsite facilities or at central disposal facilities to be developed for the Oak Ridge Reservation.

This baseline report assumes that low-level waste from decommissioning of the gaseous diffusion facilities will be stored in the onsite disposal cell described above. This report assumes that approximately 785,975 cubic meters (1,029,627 cubic yards) of solid low-level waste will be generated and left in the area of containment during the life cycle of this estimate. Most of this waste is metal and debris resulting from the decommissioning activities. This report assumes that usable metal will be recycled, and the recycling residuals and debris will be placed in the onsite disposal cell. This report also assumes that approximately 1,023 cubic meters (1,340 cubic yards) of liquid waste will be generated during decommissioning activities.

All hazardous waste generated at the Paducah site, including all waste subject to Resource Conservation and Recovery Act and Toxic Substances Control Act regulations, is managed as mixed waste. The Paducah site Resource Conservation and Recovery Act Part B permit identifies the types of hazardous waste capable of being generated and stored at the Paducah site. The onsite facilities available for treatment of liquid hazardous waste at the Paducah site are the C-400 activated carbon absorption unit and the northwest pump-and-treat facility. The Paducah site has no specific storage facilities for hazardous waste because it is stored as mixed waste in four mixed waste storage facilities onsite.

This baseline report assumes that approximately 706,718 cubic meters (925,801 cubic yards) of solid hazardous waste will be generated and left in the area of containment during the life cycle of this estimate. Most of this waste is soil resulting from the remedial actions. This report assumes that approximately 947 cubic meters (1,241 cubic yards) of hazardous liquid waste will also be generated by remedial activities.

During FY 1994, industrial and sanitary solid waste generation rates at the Paducah site totaled approximately 5,500 metric tons (5,000 tons). The C-746-S Landfill was required to close on June 30, 1995. The new contained landfill (C-146-U) became operational June 30, 1995. No treatment of solid waste will be performed at the Paducah site. No storage of solid waste is proposed onsite with the exception of legacy waste identified for disposal at C-746-U Landfill. Solid sanitary/industrial waste will be collected and transported to the C-746-U contained landfill at the Paducah Site.

This baseline report assumes that approximately 39,402 cubic meters (51,617 cubic yards) of solid sanitary, industrial, and asbestos waste will be generated and left in the area of containment during the life cycle of this estimate. Most of this waste is metal resulting from the decommissioning of the gaseous diffusion facilities. This report also assumes that approximately 105 cubic meters (138 cubic yards) of sanitary, industrial, and asbestos liquid waste will be generated.

All polychlorinated biphenyl waste generated at the Paducah site is managed as radioactive waste unless verified to be nonradioactive. Currently, only potentially surface contaminated waste can be surveyed and verified non-radioactive by Department of Energy-approved procedures. The generation rate for polychlorinated biphenyl waste during 1994 was approximately 550 cubic meters (721 cubic yards). An onsite facility available for treatment of wastewater containing polychlorinated biphenyls is the C-400 Activated Carbon Adsorption Unit. No treatment capabilities exist for polychlorinated biphenyl waste at the Paducah site. Approximately 3,600 cubic meters (4,716 cubic yards) of polychlorinated biphenyl waste is stored at several storage units. These storage facilities are modified portions of uranium enrichment buildings and new constructed facilities. The newest facility is C-753-A, which provides approximately 1,885 cubic meters (2,469 cubic yards) of storage space. No polychlorinated biphenyl waste is disposed of at the Paducah site, except treated wastewater as allowed under the Kentucky Pollutant Discharge Elimination System. This report assumes that the waste will be shipped to the K-25 Site in Oak Ridge, Tennessee, for treatment at the Toxic Substances Control Act Incinerator.

This baseline report assumes that approximately 32,877 cubic meters of polychlorinated biphenyl waste will be generated and left in the area of containment during the life cycle of this estimate. Approximately 33 percent of that waste is soil resulting from the remedial actions. This report assumes that remedial activities will generate approximately 382 cubic meters (500 cubic yards) of polychlorinated biphenyl liquid waste.

Long-Term Surveillance and Monitoring

All costs associated with long-term surveillance and monitoring are included as one line item in this estimate. These activities are expected to continue for a five-year period following the conclusion of remedial action and decommissioning activities. This report assumes that, after that time, the responsibility will be returned to the other federal users of the site. This report also assumes that long-term surveillance and monitoring activities at the Paducah Gaseous Diffusion Plant will continue until FY 2040.

Direct Program Management/Support

Program management functions provide essential administrative and oversight to the environmental restoration activities at the Paducah Gaseous Diffusion Plant. This support focuses on ensuring proper identification, characterization, remediation, and revitalization of the contaminated sites. Business management accounts for a large portion of the program management. It includes progress tracking, contract management, facility management, and financial management (budget preparation and control) for the Paducah projects. Project management personnel for the Lockheed Martin Energy System, Inc. and support groups provide project management support skills as well as coordination with the other sites in the Oak Ridge Operations Office.

Federal employees oversee the contractors for the Paducah Gaseous Diffusion Plant Environmental Restoration program. However, their costs are included in the Oak Ridge Operations Office section of this report along with the Integrating Contractor Central Operations Office Support.

LANDLORD ACTIVITIES

The Department of Energy's Uranium Enrichment Programs is the landlord for the Paducah Gaseous Diffusion Plant. Because there are no directly appropriated landlord costs at the Paducah site, funds for landlord activities are obtained through the budget process for ongoing Environmental Restoration, Waste Management, and Uranium Enrichment program activities or legacy activities at the plant. Each year, all programs supported by the Paducah Gaseous Diffusion Plant landlord provide planned budget requests based on prioritization. Landlord activities include security, fire protection, emergency management, waste management, corrective actions, general plant maintenance, roads and ground, and decommissioning of property and facilities retained by the Department of Energy. In addition, the landlord leases portions of the land and facilities to the United States Enrichment Corporation for uranium enrichment production.

This report assumes that, once production discontinues at the site, the Department of Energy's Environmental Management program will be the landlord for the facilities. The activities will mostly be surveillance and maintenance (for example, fire protection and security) of the facilities until they can be decommissioned. This estimate assumes a ten-year period between discontinued operations and the start of decommissioning.

DESCRIPTION OF PERSONNEL

Current Composition

Employees of Lockheed Martin Energy Systems include engineers, scientists, technicians, managers, construction crafts personnel, operators, laborers, and general workers, administrative professionals, general administrators, and managers. Because there are few waste operations facilities at Paducah, there are fewer operators at this site than at other facilities. This report expects this work force to remain relatively stable through 1997. In addition, the Department of Energy contracts to Science Applications International Corporation and Foster Wheeler. Both companies predominantly employ scientists and engineers. MK-Ferguson is the construction contractor. Lockheed Martin subcontracts to a variety of engineering, consulting, and site investigation firms, including several small disadvantaged businesses under the Small Business Administration "8a" set aside program. The costs for the federal Full-Time Equivalents are included in the Oak Ridge Operations Office section of this report. The following table presents the contractor work force by skill mix.

* The Projections for Full-Time Equivalent employees are based on FY 1996 planning baselines (see Reader's Guide).

Site Management Structure

In accordance with the Energy Policy Act, the Department of Energy leased the plant production operations at Paducah Gaseous Diffusion Plant to the United States Enrichment Corporation for five years, effective July 1, 1993. The Department of Energy and the United States Enrichment Corporation have negotiated the lease of specific plant facilities, written in a Memorandum of Agreement defining their respective roles under the lease, and developed the administrative program elements necessary to support their respective roles. Under these agreements, the Department of Energy retains the environmental restoration and waste management functions at the Paducah Gaseous Diffusion Plant; these operations are currently managed by Lockheed Martin Energy Systems, Inc. Plant production operations are currently managed by the subsidiary corporation, Lockheed Martin Utility Services, Inc.

Lockheed Martin Energy Systems is the integrating contractor for the environmental restoration activities at Paducah for the Department of Energy. They integrate their own work activities as well as those of the Department of Energy prime contractors for technical support, engineering, and construction and their own subcontractors for site remedial investigation work.

The Lockheed Martin Energy Systems contract has recently been extended for two years. As part of contractual reform, Lockheed Martin has committed to incentive contracting. An increasing number of Lockheed Martin-managed activities will be task order contracts. The primary features of these task order projects are as follows: contracting companies function as a team; the Department of Energy and the team negotiate terms of the project; the team collects an incentive fee for finishing under budget, but absorbs a percentage of any cost overrun; the Department of Energy shares risk for cost overruns; and streamlined bid specifications simplify the process and reduce cost estimates.

This report assumes that decommissioning of the plant will be managed by a decommissioning project management contractor who will perform the project management services necessary to execute the project and is the contractor responsible for the overall success of the project. The Department of Energy and the decommissioning project management contractor will use an incentive contracting approach with various subcontractors.

Future Full-Time Equivalent Needs

This estimate assumes that the mix of needed Full-Time Equivalents supported by the Environmental Management program will remain fairly stable. However, in FY 2015, when decommissioning activities begin, the mix and number of Full-Time Equivalents should change substantially. The yearly budgets will be substantially higher and all areas of employment will rise. As the buildings are cleared and demolished, heavy equipment operators, laborers, and health and safety personnel will be needed. The construction of the onsite disposal cell will also require construction workers. This report assumes that because permitting and reporting activities will be streamlined, the numbers of technical and administrative personnel will not increase as dramatically.

FUNDING ESTIMATE

The following tables present funding information for the Paducah Gaseous Diffusion Plant.

COMPARISON WITH PREVIOUS ESTIMATE

The 1996 life-cycle estimate of $4.8 billion for the Paducah Gaseous Diffusion Plant represents a nine percent decrease from the 1995 estimate of $5.3 billion.

Comparison Table

Activity	FY 1995 Life Cycle	FY 1995 Only 1	FY 1996 Life Cycle	Change in Dollars	Change in Percent
	Thousands of Dollars
Nuclear Mat. & Fac. Stab.	-	-	-	-	-
Environmental Restoration	4,725,084	53,600	4,830,653	159,169	3
Waste Management	-	-	-	-	-
Landlord	-	-	-	-	-
Program Management 2	617,270	5,400	-	-	-
Site Total	5,342,353	59,000	4,830,653	­452,700	­9
1 The FY 1995 life-cycle and annual costs are provided to determine the corrected FY 1995 cost. 2 Program Management was reported in an independent cost table last year, but is reported as a line item in the relevant program (Nuclear Material and Facility Stabilization, Environmental Restoration, and Waste Management) activity cost estimate tables for the FY 1996 Baseline Report.

The FY 1995 Baseline Environmental Management Report used an estimate for decommissioning the gaseous diffusion plants that was prepared in FY 1991 by Ebasco Corporation for the Department of Energy. That estimate was for a "clean closure" of the site. This included removing everything from the buildings, treating the contents at major support facilities (low assay decontamination facilities) and disposing of the waste offsite. The new estimate assumes that much of the metal in the buildings and process equipment will be recycled and that waste will be disposed onsite. These assumptions reduce the cost and schedule for decommissioning the facilities.