58

4.0 Environmental Management Practices

PGDP operations have resulted in the release

of a variety of contaminants into the environment

through stack and diffuse air emissions;

discharges through sewers into lagoons, local

ditches, and streams; accidental releases; and past

waste disposal practices such as the burial of

low-level and hazardous waste.

The primary mission of the Plant involved

the enrichment of uranium to support defense

and commercial nuclear industries. The uranium

used in the Plant was obtained both from

commercial industries and from the recycle of

reactor tails through separating irradiated fuel and

targets. These reactor tails contained trace levels

of transuranic and fission products, which were

introduced into the enrichment system and the

resulting waste materials. Uranium was the

largest contributor to environmental

contamination. Because uranium was a valued

commodity, uranium releases and transfers were

minimized from the start of Plant operations in

1952. A variety of chemicals were used directly

in the feed production and enrichment processes,

or used to in support operations such as cooling

water treatment and cleaning.

Requirements relating to the release of

chemical and radionuclides into the environment

were limited in the early years of Plant operations.

AEC established allowable limits for the release

of radionuclides into the environment, but Federal

and state agencies had few restrictions on

discharge and disposal activities until the late

1960s. Releases from U.S. industrial operations

during the 1950s and 1960s, including those at

Paducah, were significant. Past PGDP operations

resulted in a significant environmental degradation

in the vicinity of the Plant due to the accumulation

and transport of contaminants associated with past

disposal and spill sites as well as release and

migration of contaminants to local streams and

groundwater. DOE submitted a RCRA Part B

permit on February 8, 1985; this permit and a

RCRA Hazardous and Solid Waste Amendments

permit were effective on August 19, 1991. In May

1994, PGDP was listed on the National Priorities

under CERCLA, and in February 1998, and DOE,

EPA, and the Commonwealth of Kentucky entered

into a Federal Facility Agreement for environmental

remediation. On February 20, 1992, DOE and

EPA entered into the Uranium Enrichment Federal

Facility Compliance Agreement that regulating

PCB removal and disposal at PGDP. Site

remediation of environmental contamination is

currently estimated to cost 1 to 2 billion dollars,

and it will take more than 20 years to complete.

4.1 Waste Management

ÿ Solid Waste Disposal

ÿ Hazardous Waste Management

ÿ Radioactive Waste Management

Construction and operations at PGDP

generated a wide variety of waste and scrap

materials beginning in the early 1950s. An

integrated waste management program did not

ENVIRONMENTAL MANAGEMENT PRACTICES

• Waste Management

• Management and Disposal of Scrap and Surplus Materials

• Liquid Effluents

• Atmospheric Releases of Radioactivity and Fluorine
59

begin at the Plant until the early 1980s. Before the

establishment of this integrated program, each

organization at the Plant disposed of its own waste.

The Maintenance Department provided support by

operating a number of common disposal sites.

Former and current workers provided information

regarding past waste disposal practices at the site.

Former workers recounted past disposal practices that

involved discarding waste materials at locations around

the site. With few exceptions, these locations correspond

to past landfills, scrap yards, lagoons, and spill sites

that have been identified as SWMUs as part of the

current cleanup program. Several other possible

disposal locations were identified to site management

for their evaluation.

The formation of an integrated program began in

response to a December 1978 report by the site

Environmental Control Department on disposal of solid

waste (including radioactive and hazardous waste). This

report stated that the Plant was not meeting current

and planned solid waste regulations. In addition to the

recommendations for better management of existing

facilities and the need for additional facilities, the report

recommended that specific individuals be made

responsible for operation, maintenance, record-keeping,

and planning of solid waste storage and disposal areas.

The resulting organization, the MTM Department,

implemented the integrated waste management program

by gaining control of the waste management facilities

and developing waste management procedures for the

Plant.

Solid Waste Disposal

During construction of the original Plant, the prime

contractor established an inert disposal site for

construction rubble north of the Plant. Over time, this

site continued to be used for disposing of construction

materials. As the Plant became operational and

generated hazardous and radioactive waste materials,

contaminated materials were introduced into this disposal

site, including contaminated roofing material and

concrete, asbestos, and chemically treated wood from

the cooling towers. On the southwest side of the Plant,

a borrow pit was used to dispose of ash from the Plantís

coal-fired steam plant, which was subsequently

designated as the C-746-K landfill.

Over time, these two sites apparently evolved into

landfills not requiring permits according to

Commonwealth of Kentucky regulations; the

Maintenance Department operated the landfills. The

limit established during early site operations for

radioactive material in these areas was 2 pounds of

uranium per ton; however, no records of sampling were

located to demonstrate compliance with this limit. For

depleted uranium, the limit would correspond to a

volumetric concentration of approximately 333 pCi/g

or 670 pCi/g for natural uranium. Records from the

1960s and 1970s indicated that floor sweepings were

disposed of at these landfills. Since process materials,

including green salt and yellowcake, were routinely

present in large quantities on floors and equipment in

some buildings, it is clear that these radioactive materials,

in much higher concentrations than allowed, were

inappropriately sent to these landfills.

Within the Plantís security fence in the northwest

corner, a 30-foot-high ramp and pit arrangement, known

as the teepee, was used to burn combustible waste.

As an aid to combustion, waste oils were added;

however, these oils were not controlled and they were

likely contaminated with solvents and PCBs. This

operation continued until December 1, 1967, when air

control regulations for open burning at disposal sites

required termination. At that time, these waste streams

were sent to the coal ash disposal site.

Although landfills were on government property and

patrolled by Plant security, the public could access these

areas. Some members of the public routinely retrieved

scrap wood and others used construction items from

the inert disposal site, starting during Plant construction

and continuing into the 1970s. At the 746-K landfill,

for example, redwood with brass bolts from the cooling

towers and used wood paneling from Plant offices

attracted salvaging from the public and possibly workers.

Limited controls had been established on disposal of

material from the cascade and other process and

Site Posting - 1999
60

operations buildings in order to keep highly contaminated

items from going to the landfill. However, when

surveillances were conducted at the landfill in later years,

such items would occasionally be identified, indicating

weaknesses in the implementation of management controls.

Maintenance workers operated these disposal sites

during the day, implementing verbal guidance from their

supervisors. These workers used bulldozers and other

heavy equipment to compact and dress the working

areas. Since their equipment did not have closed cabs,

the workers were exposed to both unconfined asbestos

and ash from the coal-fired steam plant. As the Plantís

heavy equipment operators, these workers also hauled

construction rubble to both the landfills and the inert

disposal areas around the Plant, including parts of what

is now the Kentucky Wildlife Area. Concrete rubble

and debris, some with radioactive contamination, was

sent offsite to areas in the former KOW, a fact that was

known due to environmental investigations conducted

under the Federal Facility Agreement and predecessor

environmental regulations and confirmed by the team

through visual inspection and walkover radiological

surveys. The limited space available for disposal within

the Plant security fence probably affected the decision

to discard these materials on the KOW.

In the early 1980s, additional controls were

implemented at the landfills. These controls eventually

included controlled access to the landfills, waste

acceptance criteria, record keeping, and licensing both

the landfill and the operators with the Commonwealth

of Kentucky. Controls were also applied to waste

generators. Segregated dumpsters for both nonhazardous and radioactive wastes were acquired, and

procedures and guidance on acceptable disposal practices

in the Plantís sanitary landfills were established.

Hazardous Waste Management

Hazardous waste regulations did not emerge in the

United States until the early 1980s. In response to

these regulations, the newly created MTM Department

began to aggressively address hazardous waste disposal

practices by identifying and controlling these practices.

As an example, a discontinued attempt to use

biodegradation for waste oil treatment left a legacy of

drums containing not only used oil but also waste

solvents. The practice had involved disking waste oil

into the soil along with nutrients to allow microbial

biodegradation. Although the practice had ceased,

generators continued to bring drums of waste liquids to

the site. The MTM Department, as one of its first

actions, worked with generators to identify other disposal

options and characterize the drums already at the

biodegradation site. This approach was repeated for

other disposal sites across the Plant.

The existing waste streams in numerous disposal

sites were evaluated by the MTM Department to

determine the generators, who were then contacted to

determine the process that produced the waste. Disposal

options were explored that would be in compliance with

emerging new requirements under RCRA. In addition,

MTM Department personnel began to develop standard

practice procedures for waste management, assigning

responsibility for implementing pollution control

programs to the generators with support from several

organizations, including the MTM and Environmental

Control Departments. Plant Services was responsible

for operating the disposal facilities and recording waste

transactions. As an example of tightening controls, the

blanket request for disposal used before 1983 was

cancelled and a ìrequest for disposalî form was required

for each waste pickup.

Concurrent with these activities, the MTM and

Environmental Control Departments began working with

regulators to obtain permits for storage, treatment, and

disposal facilities at the Plant. These facilities ranged from

the C-400 gold dissolver precipitation system to the C410 neutralization pit. As hazardous waste streams were

identified and brought under control, storage needs were

met by using several existing locations for storing all types

of materials and waste. Subsequently, these facilities were

permitted under the Commonwealth of Kentucky RCRA

authority, with the RCRA Part A permit submitted on

February 8, 1985, and the RCRA Part B permit effective

on August 19, 1991.

Wastes were characterized only to determine

compatible storage requirements; this characterization

was not sufficient to ensure long-term storage and satisfy

Biodegradation Site - 1999
61

final disposal acceptance criteria. In 1987, for example,

840 ash receivers from the 1977 shutdown of the feed

plant that were stored in C-746B, a radioactive waste

storage facility, were determined to also be hazardous

under RCRA. Therefore, this facility became a nonpermitted RCRA storage facility until the ash receivers

could be overpacked and moved to a permitted RCRA

facility. The limited degree of characterization has

resulted in storage problems and a need for very large

recharacterization efforts at the Plant, as discussed in

the Office of Oversight Phase I investigation report.

Oversight for hazardous waste activities also

increased from being a subset of landfill reviews to being

focused inspections. In the 1970s, OR conducted annual

appraisals of the C-746-K landfill and of water and air

pollution control facilities at the Plant. These appraisals

increased in scope and duration in the 1980s, with a

section specifically focused on hazardous waste

management practices. In addition, external regulators

began inspecting RCRA facilities and operations in the

1980s. Generally, these appraisals and inspections

praised the waste management programs. However,

problems were identified, including Notices of Violation

in 1985 for not performing detailed chemical and physical

analysis, and concerns about contingency planning with

local authorities and incomplete contingency plans. A

Notice of Violation was issued in 1986 for routine

disposal of sludge determined to be hazardous in the C404 facility, which had not been permitted for hazardous

waste. Conversely, the Plant also conducted evaluations

to determine whether private disposal sites were

adequately operated and capable of disposing of Plant

waste in accordance with applicable environmental

regulations.

Radioactive Waste Management

Radioactive waste management has been evolving

since the 1950s. In April 1953, efforts were initiated to

reduce the spread of contamination by using drums

designed for disposal in work locations known for

generating highly contaminated waste. Operating logs

in C-340 from 1958 discuss using a supply of scrap

drums from the holding pond for packaging black oxide

rather than putting the oxide in dumpsters. Actions to

segregate these wastes from the Plantís other waste

streams resulted in establishing radioactive disposal sites.

Although several small sites were used for special

disposal activities, including contaminated aluminum and

a modine trap, the Plant had three main radioactive

disposal sites:

ï C-749 Uranium Burial Ground. Used from 1957

to 1977, this site primarily contained pyrophoric

uranium metal in the form of saw dust, shavings,

and turnings covered in oil. The total amount of

uranium placed in this site is approximately 540,000

pounds.

ï C-340 Drum and Contaminated Burial Area. Used

from the late 1950s until the mid-1970s, this area

received C-340 uranium powder scrap. In the

1950s, 50 to75 drums were emptied into a pit 10

feet by 20 feet, and 7 feet deep. In the 1970s, two

more 7-foot-deep pits were used for disposal of

contaminated metals and equipment.

ï C-404 Solid Radioactive Waste Disposal Area. This

was the primary disposal site for radioactive waste

at the Plant. This area was constructed as a holding

pond for C-400 liquid waste, but in early 1957, it

was converted to a solid waste disposal area. The

pond was 380 by 140 feet, with 6-foot-high dikes.

By 1977, approximately 6,400,000 pounds of

uranium had been drummed and placed in the

holding area. Waste streams included incinerator

ash, contaminated alumina, highly contaminated

roofing waste, and gold recovery sludge. This area

continued in use into the mid-1980s. Subsequently,

this area was determined to contain sludge that was

also hazardous, thus requiring closure under RCRA

in 1987.

After the formation of the MTM Department,

radioactive waste disposal on site rapidly decreased. In

1978 and 1979, the amount of disposal was 330,690

pounds per year; in the 1980s, the average was 18,000

pounds per year. As a result of not burying radioactive

waste on site and restrictions for offsite disposal, the

site experienced a large buildup of contaminated waste

and scrap, as discussed in the Office of Oversight Phase

I investigation report.

4.2 Management and Disposal of

Scrap and Surplus Materials

Large volumes of scrap metal and surplus materials

were generated during construction, maintenance, and

facility upgrade activities at PGDP. These materials

were either managed as waste for disposal or stored

and managed as a commodity for resale. Much of the

material was contaminated, and large volumes have been