19

converted into a solid waste disposal area in 1957. By

1977, over 6 million pounds of uranium had been put

into drums and placed in this disposal area.

PGDP had no integrated waste management

program until the early 1980s. Before then, waste

disposal was performed by each organization performing

work in conjunction with the Maintenance Department,

which operated several disposal sites. When requested

by the operating departments, limited guidance was

provided by the site safety and health organization.

In 1978, the site Environmental Control Department

conducted a study of PGDP waste management

practices. The report recommended better management

of solid waste, closure of miscellaneous burial areas,

improved management of existing facilities, provision

of additional space for facilities, and construction of

facilities for recovery and reduction of waste. The report

stated that the passage of the Resource Conservation

and Recovery Act (RCRA) in 1976 required Federal

facilities to comply with all state solid waste regulations

and that the Plant ìis only partially meeting both present

and planned regulations.î In part, this study led to the

creation of the Material Terminal Management (MTM)

Department within the Maintenance organization. The

MTM Department implemented the integrated waste

management program by gaining control of waste

management facilities and developing waste

management procedures for the Plant.

The 1978 study and the formation of the MTM

Department also impacted the disposal of radioactive

waste on site. In 1978 and 1979, the amount of

radioactive waste disposed of on site was 330,690

pounds annually, but this declined significantly to 18,000

pounds per year in the 1980s. An overriding assumption

regarding the stability of the radioactive disposal sites

was that the underlying clay layer would prevent

contamination from leaching into the groundwater and

travelling off site.

In the early 1980s, the MTM Department began

addressing hazardous waste disposal practices by

working with waste generators to ensure that waste

streams would be in compliance with RCRA

requirements and by implementing standard practice

procedures for waste management. Concurrently, the

MTM and the Environmental Control Departments

worked with regulators to obtain permits for storage,

treatment, and disposal facilities, including the C-400

gold dissolver precipitation system and C-410

neutralization pit. Legacy hazardous waste was brought

to several locations, including the C-733 Hazardous

Waste Storage Area, the C-746R Waste Solvent Storage

Area, and the C-746Q Hazardous Waste Storage Area.

However, the absence of sufficient characterization to

ensure long-term storage and compliance with disposal

acceptance criteria has led to existing hazardous waste

storage problems and the need for significant

recharacterization.

PCBs, which were in widespread use by the Plant

throughout its early history, were not considered a hazard

nationwide until the early 1980s. In 1980, the newly

formed MTM Department performed the first sitewide

PCB inventory in response to new Toxic Substances

Control Act (TSCA) regulations on PCBs. By 1982, a

PCB program was established that addressed PCBs as

an environmental contaminant and a regulated waste.

Based on site records, there was a clear

understanding in the 1950s that materials contaminated

above certain limits could not be released to the public.

Procedures were used to govern the handling of scrap

materials, which were generally categorized into one of

four groups: classified scrap, unclassified clean scrap,

unclassified contaminated scrap, and unclassified

nonmetal scrap. However, there was a concern in the

mid-1970s that the contaminated items were being

released to public parties as part of equipment and scrap

sales. In mid-1975 a Scrap Handling Committee was

established to evaluate onsite solid waste disposal

problems. The source of these problems included the

ongoing upgrade program, lack of awareness of the

proper procedures ñ especially among new workers and

supervisors ñ and an increase in the number of entities

hauling waste to the scrap yards. The Scrap Handling

Committee also examined the effectiveness of

equipment and scrap sales to the public, and despite

recommendations for improvements, continued

problems were evident in 1977. The extent to which

proper procedures were not followed, combined with

the small number of health physics personnel, suggests

that materials exceeding proper radiological limits were

likely released off site until the late 1980s.

2.7 Air and Water Emissions

Radioactive air emissions began with startup

operations in 1952 and have continued to present. Air

emissions from the site were released from process

stacks, diffuse and fugitive emission sources, accidental

releases, and a limited number of planned releases. No

evidence of measurements or monitoring of stack

emissions was found prior to 1975. From 1959 to 1974,

the air emission reports consisted of ambient air

monitoring. Starting in mid-1960, continuous ambient

air samples were taken at four locations at the perimeter

fence and were analyzed for alpha and beta
20

contamination to provide input for annual reports on

ambient air concentrations. In 1961, four additional

ambient continuous air samplers were installed one mile

outside the perimeter fence, although actual stack

monitoring of emissions did not occur until the mid1970s.

From 1975 through 1990, annual discharges to the

atmosphere based on stack measurements were reported

in annual emission reports. It has been estimated that

from 1952 to 1983, 60,000 kg of uranium were released

to the atmosphere, 75 percent of this prior to 1965 and

most from C-410 and C-340. A number of accidental

releases of UF6

 occurred (perhaps as many as 15),

during which more than 50 pounds of UF6 were

released. Dust and fugitive emissions were generally

not calculated for the site from 1952 to 1990.

Fluorine emissions to the atmosphere also

commenced with startup operations in 1952 and have

continued to the present. These emissions were from

process stacks, diffuse and fugitive emission sources,

accidental releases, and a limited number of planned

releases. During the period from 1959 to 1990, the air

emission reports consisted of ambient air monitoring

results for fluorides. Starting in mid-1960, continuous

ambient gaseous air samples were taken at four locations

at the perimeter fence and were analyzed for gaseous

fluorides to provide input for annual reports on ambient

air concentrations. Only limited information could be

found for stack emissions of fluoride prior to 1986.

The first environmental reporting of stack emissions of

fluorine that was found addressed 1986 emissions. For

the period 1986 through 1990, discharges to the

atmosphere based on stack measurements were reported

in annual emission reports.

Construction of the PGDP incorporated systems

and strategies for disposing of liquid effluents from

production and support operations. Liquid effluents

were released in a number of ways, including via the

sanitary sewage and storm water drainage systems. The

C-615 sewage treatment plant was used from the

beginning to treat sanitary and sink wastes from

production buildings. Other effluents were discarded

either in batches or through continuous feed into ditches,

ponds, and streams, with subsequent flow into the Big

and Little Bayou Creeks, ultimately reaching the Ohio

River.

Liquid effluent discharge limits for radionuclides

have always been controlled under the AEC and ERDA

regulations and later DOE orders as maximum

permissible concentrations (MPCs) or radiation

concentration guides (RCGs) in water. A review of

historical correspondence identified instances where

specific decisions were made to discharge waste

materials containing uranium, transuranics, and fission

products directly to local ditches.

Federal and Commonwealth of Kentucky

requirements on chemical discharges from the Plant

did not exist during the early years of operations, and

the Plant discharged significant amounts of hazardous

chemicals, such as TCE and chromium. One of the

major components of liquid process waste during early

Plant operations was recirculating cooling tower

blowdown wateróapproximately 500,000 gallons per

day, with a 20 ppm concentration of chromium, was

pumped to the Little Bayou Creek. As a result, there

was a time when parts of the Little Bayou were dead

and colored yellow from the chromium.

In the early 1970s, the Clean Water Act established

the National Pollutant Discharge Elimination System

(NPDES), which administered effluent limitations and

water quality requirements for chemical releases. A

total of 18 outfalls were permitted at the site. In

response to changing expectations for environmental

protection, in 1977 the C-616 Wastewater Treatment

Plant came on line. Major liquid effluent streams that

feed into the North-South Diversion Ditch were then

routed by a lift station to this facility, resulting in

significantly better water quality in local streams.

The most significant liquid effluent discharge source

at the site was from the C-400 decontamination building.

Wastes from this source included TCE from degreasing

operations, contaminated liquids from cleaning

operations, and various contaminated raffinate solutions

from uranium, neptunium, and technetium recovery

operations. Essentially all isotopes at the site were

present in various portions of this facility and in its

liquid waste streams, including uranium, neptunium,

plutonium, thorium, and technetium.

In 1988, concerns over residential water quality

led to sampling of residential wells north of the Plant. Little Bayou Creek - 1999
21

TCE, an industrial degreaser, and technetium-99, a

radionuclide fission product from nuclear fuel, were

discovered in the wells. This discovery prompted the

government to provide municipal water free of charge

to all residences and businesses in an area bounded by

the Ohio River to the north, by the DOE property to

the south, by Metropolis Lake Road to the east, and by

Bethel Church Road to the west. Under the

Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA), DOE and

the EPA developed an Administrative Consent Order,

effective November 23, 1988, that established a

schedule to investigate and remediate offsite

groundwater contamination. Phase I of the CERCLA

review, conducted in 1989 and 1990, identified

contaminants of concern and solid waste management

units (SWMUs) that could have contributed to offsite

contamination, outlined the physical characteristics of

the SWMUs, and described the risk of offsite

contamination. Phase II of the CERCLA review,

conducted in 1990 and 1991, further assessed the risk

of offsite contamination, characterized SWMUs that

could have contributed to offsite contamination, and

identified migration pathways for contaminants.

2.8 Key External Assessments

In April 1985, a DOE task force evaluated the

adequacy of practices to support handling of radioactive

contaminants in uranium recycle materials at the Oak

Ridge Y-12 Plant, the Feed Materials Production Center

(in Fernald, Ohio), and the RMI Company (in Ashtabula,

Ohio), and examined past operations at the PGDP and

the Portsmouth Oxide Conversion Facility. The task

force concluded that an in-depth examination of PGDP

handling and processing practices was warranted, that

quantities of recycle materials with undetermined levels

of contaminants were present at PGDP, and that PGDP

was periodically receiving commercially-produced UF6

containing trace levels of transuranic elements. This

study recommended that PGDP line management assess

worker exposures to transuranic elements and fission

products from processing of recycled materials and

recommend a feasible method for disposing of uranium

recycle material.

An overall concern regarding ES&H conditions at

all DOE sites led then-Secretary of Energy Watkins to

establish the Tiger Team program and to conduct a

Tiger Team assessment of PGDP in June and July 1990.

The assessment concluded that ceasing PGDP

operations was not warranted, that compliance issues

were known by those Federal and State agencies that

issue permits, and that the following ES&H and

management issues required prompt attention: (1)

environmental monitoring and evaluation programs were

not being effectively implemented due to a lack of

technical direction, formal procedures, and a

coordinated quality assurance program; (2) formal

procedures for implementing environmental protection

activities were lacking, and quality assurance programs

had not been implemented for many environmental

activities; (3) compliance with DOE orders and

mandatory standards for worker safety and health was

deficient, as was the system for managing administrative

control documents; (4) training and certification

programs did not meet site needs; (5) instrument

calibration practices did not always meet minimum

standards; (6) there was no long-range plan for safe

storage of UF6

 cylinders; (7) no integrated sitewide

management system was available to track and correct

identified deficiencies; (8) DOE was not effectively

performing oversight to ensure that ES&H initiatives

were being implemented; and (9) the site contractor did

not have a corporate strategic plan to accomplish DOEís

ES&H objectives.

These issues became the framework for the siteís

ES&H activities for much of the decade of the 1990s.

The siteís effectiveness in addressing these concerns,

the current ES&H posture of the site, and the transition

of the siteís uranium enrichment operations to a

privatized enterprise (USEC) are documented in the

Office of Oversightís report from the first phase of this

investigation (Phase I Independent Investigation of the

Paducah Gaseous Diffusion Plant: Environment,

Safety, and Health Issues, October 1999). A detailed

discussion of historic hazards at PGDP; operational,

maintenance, and environmental activities and practices;

and the effectiveness of these practices in addressing

historic hazards is provided in Sections 3 and 4 of this

report.