** 
**PHASEI INDEPENDENT INVESTIGATION OF THE PADUCAH GASEOUS DIFFUSION PLANT**
 

 

October 1999Prepared byOffice of OversightOffice of Environment, Safety and HealthU.S. Department of Energy** 

**TABLEOF CONTENTS**
- Executive Summary
- 1.0 Introduction   - 1.1 Purpose and Scope
  - 1.2 Site Background,        Operations, and Hazardous Materials
  - 1.3        Past Worker Safety, Public Safety, and Environmental Protection Assessments
  - 1.4        Recently Identified Concerns
  - 1.5        Investigative Approach 
- 2.0 Assessment    of Current Conditions   - 2.1 Public and Environmental Protection
  - 2.2 Radiation Protection and Worker        Safety     - 2.2.1 Radiation Protection
    - 2.2.2 Worker Safety and Health 
  - 2.3 Line Oversight 
- Appendix A - Issues for Corrective    Action and Follow-Up
- Appendix B - Characterization of Selected Solid Waste Management    UnitsAppendix C - Team Composition
 
**   Executive Summary****EVALUATION:****Office of Oversight    Investigation****SITE:****Paducah    Gaseous Diffusion Plant****DATES:****August-September    1999**
**Background/Scope**

In August 1999, in response to a number of environment, safety, andhealth (ES&H) allegations and concerns, the Secretary of Energy initiated anindependent investigation at the Paducah Gaseous Diffusion Plant (PGDP or Plant). TheseES&H concerns centered on areas such as improper onsite and offsite disposal ofhazardous and radioactive materials, release of contamination into site streams anddrainage ditches, inadequate posting and control of contaminated areas, exposure ofworkers to uranium and transuranic elements, and ineffective communication of hazards toworkers.
To provide timely feedback to the Secretary on the current status ofenvironmental protection, worker and public health and safety, and the status of legacyissues, this Department of Energy (DOE) Office of Oversight investigation was divided intotwo phases. Phase I, the subject of this report, covers the period from 1990 to thepresent. Phase II, which will begin in October 1999, will evaluate ES&H performanceand concerns about Plant operations prior to 1990. Various assessments in the early 1990s,including a DOE Tiger Team and the initial investigation under the DOE EnvironmentalProtection Agency Consent Order, identified numerous concerns about environmentalcontamination, radiological protection, and the presence of transuranic materials.

This first phase of the investigation focused on legacy areas andactivities—those that remain the responsibility of DOE and its current management andintegrating contractor, Bechtel Jacobs, which took over operation of the DOE-controlledactivities at PGDP in 1998. The investigation did not examine areas leased by the UnitedStates Enrichment Corporation (USEC) that are under Nuclear Regulatory Commission (NRC)jurisdiction. NRC has undertaken a separate confirmatory inspection to assess workersafety in those areas of the PGDP under NRC control.

Rather than separately investigating each of the many specificallegations and concerns, the Office of Oversight investigation team independentlyexamined the implementation of PGDP ES&H programs within which the allegations andconcerns fell. These programs include public and environmental protection, radiationprotection, worker safety, and line management oversight. This approach was chosen toidentify issues and programmatic weaknesses that need to be corrected and help DOE toimplement long-term and effective improvements in ES&H performance, rather than merelyaddressing symptoms.**Results
Although weaknesses remain, significant corrective actions andimprovements have been implemented in PGDP ES&H programs since the early 1990s. ThePGDP site is being cleaned up under enforceable agreements established with theCommonwealth of Kentucky and the Environmental Protection Agency. The site is currently incompliance with the terms of Federal Facility Agreements. Compensatory measures have beentaken to protect the public and to mitigate the impact of radiological and chemicalcontamination, such as connecting homes that are in the path of contamination plumes topublic water. In the worker safety arena, the radiation protection program has beenenhanced, radiation exposures to employees have been low, and injury and illness rates atPGDP are lower than at many other DOE sites.
Despite the improvements since 1990 and actions to clean up the site,this investigation identified a number of weaknesses in each of the areas reviewed. Whilethe investigation team found no immediate threat to health and safety that would requireimmediate cessation of site activities, the cumulative impact of a number of deficienciesis cause for concern.
**   **Severalthousand tons of nickel and aluminum ingots were produced.   These materials arecurrently stored outside with no protection.**

**Public and Environmental Protection.** Extensiveefforts have been undertaken at PGDP to characterize major sources of groundwatercontamination, and the extent of that contamination, as a result of the 1988 discovery ofcontaminated offsite residential drinking wells. Limited progress has been made, however,in accurrately isolating or remidiating the numerous sources of offsite contamination.Groundwater contamination plumes now extend over two miles offsite and continue to grow atapproximately one foot per day, and, in some areas, PGDP has not adequately characterizedthe plumes, including defining the leading edges. Most of the site’s funding has beendevoted to characterizing contamination, operating and maintaining the siteinfrastructure, meeting regulatory requirements, and implementing compensatory measures inreaction to immediate threats. The funding available for cleanup and remediation has beenmuch less than requested, and little progress has been made. As a result, two ofPDGP’s early major cleanup milestones under the Federal Facility Agreement, toremediate Drum Mountain (also known as Barrel Mountain) and to characterize the waste unitbeneath it, are in significant jeopardy of not being met. Examples of other deficienciesin environmental and public protection include:
- 
Large quantities of scrap metal and    low-level and mixed waste (equivalent to approximately 50,000 barrels) are stored in    conditions that cause degradation of the containers (e.g., drums stored outdoors without    protection from the weather) and the potential for spread of contamination.

- 
Numerous contaminated areas and shutdown process    facilities have not been adequately characterized and analyzed to identify potential    exposure pathways and have not been controlled and maintained to prevent the spread of    contamination.

- 
Information provided to stakeholders, including workers,    the public, and the Site Specific Advisory Board, has not been comprehensive or presented    in a manner that is easy for a non-technical audience to understand (e.g., annual    environmental reports do not reflect data resulting from site remediation investigations).

**Radiation Protection. Since the early 1990s,the PGDP radiological protection program has been enhanced by adding radiation protectionstaff and establishing numerous controls, such as dosimetry (monitoring radiation exposureby means of a film badge), bioassay (monitoring radiation exposure by sampling bodyfluids), and contamination controls. Despite these improvements, the PGDP radiationprotection program is not implemented with the level of discipline, formality, and rigorrequired for DOE facilities. Examples of deficiencies in radiological protection include:
- 
Insufficient    radiological postings and barriers for contaminated areas, some of which are outside the    security fence and could be accessible to the publicInconsistent implementation of radiological control mechanisms including    radiation work permits, procedures, surveys, and air monitoringSubcontractors working in radiological    exposure areas without the required training or dosimetry.

**Worker Safety and Health.** Since the early 1990swhen the DOE Tiger Team assessment identified numerous deficiencies in worker safetyprograms, significant improvements have been made. Most occupational and worker exposurehazards have been identified and analyzed, they are adequately controlled, and workers aremore involved in work planning. However, improvements are needed in establishing,maintaining, and following procedures, particularly for work performed by subcontractors.Deficiencies in worker safety practices and controls indicate the lack of a disciplined,rigorous, and consistent approach to safety management. Other deficiencies were evident insuch areas as:
- 
Criticality safety hazards    in DOE material storage areas (DMSAs) have not been characterized, analyzed, and resolved    even though they were identified more than two years ago. Medical personnel have not been sufficiently involved in    evaluating hazards to ensure the effectiveness of medical surveillance programs,    particularly those for subcontractors.Worker training programs do not ensure familiarity with    workplace hazards and have not adequately addressed the presence of transuranics    (elements, such as plutonium, that have a higher atomic number than uranium). This    shortcoming in training may have exacerbated workers’ fear of exposure and    contributed to instances of mistrust by workers.******   **DOE Material Storage Area****Line Oversight.The operating gaseous diffusion facility was leased to USEC in 1993, and NRC’sregulatory oversight of these leased facilities began in 1997. DOE retains regulatoryoversight responsibility only for non-leased portions of the facilities. Line managementoversight of ES&H by the DOE Oak Ridge Operations Office (OR) and the Paducah SiteOffice has been limited. DOE Headquarters ES&H oversight, including the programoffices and the Office of Environment, Safety and Health, has also been very limited.Further, Bechtel Jacobs oversight of subcontractors’ ES&H performance has notassured compliance with ES&H requirements*.* The lack of sufficient lineoversight has contributed to situations in which previously identified problems andweaknesses have resurfaced and have remained uncorrected for extended periods.

**Conclusions**
Many improvements in ES&H programs have been made in the past tenyears, and current operations do not present an immediate risk to workers or the public.However, the current radiation protection program and some elements of worker safetyprograms do not exhibit the required levels of discipline and formality. Further, therehas been little progress in reducing or mitigating site hazards or sources ofenvironmental contamination. Weaknesses in hazard controls are evident, ES&H oversighthas not been sufficient, and communication with stakeholders and workers has not beencomprehensive and responsive to stakeholder needs. In combination, these weaknessesundermine workers’ and stakeholders’ confidence and perpetuate the risks andhazards of legacy operations.

A key to regaining stakeholder, worker, and public support andconfidence, reducing hazards and risks to as low as reasonably achievable, and ensuringthe continuing operation of the PGDP is to begin to accelerate progress in the cleanupeffort, including compliance with impending initial major cleanup milestones such as DrumMountain and the waste buried beneath it. Timely progress in cleanup and remediation willrequire a reevaluation of priorities and funding allocations within the DOE Office ofEnvironmental Management and OR and/or additional cleanup funding from Congress.Systematic progress needs to be demonstrated in key cleanup and hazard reduction effortssuch as the elimination of the many sources of contamination, characterization anddisposition of the DMSAs, including resolution of criticality safety concerns, the properstorage or shipment offsite of low-level waste, and the removal of hazards and properupkeep or demolition of shutdown hazardous facilities. Other areas where timelyimprovement is needed include:
- Establishing a high level of discipline and rigor in the radiological    protection program and other programs affecting worker safety, such as criticality safety.    This effort should emphasize strict compliance with posting and barrier requirements,    improved radiation work permits, comprehensive radiological training, strict use of and    compliance with procedures, characterization of materials to improve effective hazard    analysis, and the use of engineered hazard controls whenever possible. 
- Strengthening communications and outreach to workers, the public, and    stakeholders to ensure understanding, confidence in site operations, and empowerment in    contributing to cleanup strategies, priorities, and decisions. This effort is particularly    important for the Site Specific Advisory Board, whose charter is to contribute to site    cleanup through involvement in establishing priorities and milestones and achieving public    support. 
- Restoring a reasonable level of DOE and contractor oversight of ES&H    performance to ensure adequate subcontractor safety performance, accountability for    compliance with DOE requirements, and continuous improvement. 

Continued improvements in safety management will be particularlyimportant as the PGDP initiates additional site cleanup and remediation activities. Thiswork presents unique hazards (e.g., handling material that contains radioactive andchemical carcinogens and that has not been fully characterized) and has already resultedin several occurrences of workers being contaminated in the limited remediation efforts todate. The need for effective safety management is further highlighted by the fact that,under the management and integrating contractor concept, a large fraction of thepotentially hazardous work will be performed by subcontractor employees, some of whom donot have a long-term knowledge of site hazards or controls. As subcontractors’cleanup and waste management activities increase, Bechtel Jacobs and DOE personnel who areknowledgeable of DOE requirements will need to increase their level of oversight.
**OVERVIEW OF ISSUES
- There has been limited progress in remediating and characterizing        environmental contamination, low-level wastes, and stored hazardous materials that were        produced by past industrial activities, and major cleanup milestones under the Federal        Facility Agreement are jeopardized by funding constraints.
- There are continuing weaknesses in the radiation protection management of        known environmental contamination areas by both Bechtel Jacobs and DOE.
- Radiological exposure pathways for DOE operations have not been fully        assessed or documented.
- Groundwater contamination has not been adequately characterized in some        areas.
- Unclear assignment of responsibilities and weaknesses in the integration        and interpretation of environmental information have adversely impacted the understanding        of environmental conditions.
- Information to the public has sometimes been delayed and is in forms not        clearly understood by the general public and other stakeholder groups, contributing to a        perception that DOE and the contractor are withholding information from the public.
- Incomplete radiological characterization of the workplace adversely        affects the ability of the radiological control organization to identify hazards and        institute controls as necessary to ensure consistent and appropriate radiological        protection for workers.
- There is a lack of rigor, formality, and discipline in the development,        maintenance, and implementation of the Bechtel Jacobs radiation protection program.
- Criticality safety deficiencies in DMSAs have not been resolved by DOE in        a timely manner, posing an unnecessary hazard to workers in surrounding areas.
- Safety and health procedures are not consistently applied and followed,        and in some cases, hazards are not adequately addressed by those procedures.
- Bechtel Jacobs has not assured that subcontracted medical personnel are        sufficiently involved in the identification, evaluation, and integration of workplace        hazards to ensure effective worker medical programs.
- Bechtel Jacobs training programs do not ensure that all workers are        knowledgeable of hazards and protection requirements, including those associated with        transuranic contamination.
- DOE has not conducted effective oversight of ES&H or ensured that        Bechtel Jacobs and its subcontractors effectively implement all DOE and regulatory        requirements.
- Bechtel Jacobs has not conducted fully effective oversight of ES&H        performance or ensured that its subcontractors effectively implement all DOE and        regulatory requirements and are held accountable.

 

    **Introduction**
**1.1 Purpose and Scope
The Department of Energy (DOE) Office of Oversight, within the Officeof Environment, Safety and Health, conducted an investigation of the Paducah GaseousDiffusion Plant (PGDP or Plant) during August and September 1999. The purpose of thisinvestigation was to determine whether current work practices for DOE-controlled areas ofthe site are sufficient to protect workers, the public, and the environment. Thisinvestigation was performed at the direction of the Secretary of Energy, who instructedthe Office of Environment, Safety and Health to examine recent employee concerns with pastoperations and work practices, and current management of legacy materials at PGDP.
This investigation is being conducted in two phases. The first phase,the subject of this report, addressed DOE and site contractor activities and environment,safety, and health (ES&H) issues arising since 1990. The second phase will addresslegacy ES&H issues that occurred prior to 1990. This investigation is beingcoordinated with other organizations that have regulatory authority at PGDP, including theCommonwealth of Kentucky, the Nuclear Regulatory Commission (NRC), the EnvironmentalProtection Agency (EPA), and the Occupational Safety and Health Administration (OSHA).Excluded from this investigation is any activity currently under NRC jurisdiction (i.e.,the portions of the Plant leased to the United States Enrichment Corporation, or USEC).

The scope of the investigation includes: (1) facilities and propertiesunder DOE jurisdiction; (2) ES&H issues associated with these facilities andproperties from 1990 to the present, including interactions between DOE and stakeholders;and (3) ES&H issues associated with uranium enrichment facilities from 1990 to March3, 1997 — the point when NRC assumed regulatory oversight of the gaseous diffusionprocesses, facilities, and personnel. The DOE-controlled operations that were examinedinclude: landlord infrastructure; treatment, storage, and disposal of legacy wasteremaining from past operations and newly generated waste; site remediation; uraniumhexafluoride (UF6) cylinder storage; facilitydecontamination and decommissioning; and polychlorinated biphenyl (PCB) collection,treatment, and cleanup. Consistent with the memorandum of understanding between the NRCand DOE regarding PGDP operation, any activities, operations, or facilities shared by USECand DOE or its contractors were examined as part of this investigation.**1.2 Site Background,Operations, and Hazardous Materials
The PGDP is located in McCracken County, Kentucky, approximately 10miles west of the city of Paducah and 3 miles south of the Ohio River. The site occupiesabout 3,425 acres, of which 750 acres are within a security fence and contain uraniumenrichment process equipment and support facilities. The mission of the Plant is to"enrich" uranium for use in domestic and foreign commercial power reactors.Enrichment involves increasing the percentage of the uranium-235 isotope in the materialused for creating reactor fuel (UF6).Uranium-235 is highly fissionable, unlike the more common isotope uranium-238. The PGDPenriches the UF6 from roughly 0.7 percenturanium-235 to about 2.75 percent uranium-235. This slightly enriched material is shippedto the Portsmouth Gaseous Diffusion Plant, where currently it is further enriched to 5percent uranium-235. Figures 1, 2, and 3 are site maps and an aerial view of PGDP.
**Figure 1. Map of Paducah Gaseous Diffusion Plant, Leased andNon-Leased Areas**

**Figure 2. Aerial View of Paducah Gaseous Diffusion Plant**

**Figure 3. Map of Paducah Gaeous Diffusion Plant, MajorBoundaries and Features**

The PGDP was constructed in the early 1950s, and the first productcylinders with enriched uranium were shipped to Oak Ridge in late 1952. Carbide andChemicals Company (now Union Carbide) was the original site contractor and operated thePlant for the Atomic Energy Commission. In the mid-1960s, the mission of the Plant shiftedfrom military to commercial applications, and the Plant began enriching uranium for use innuclear power plants. In 1975, the Energy Research and Development Administration assumedresponsibility for regulatory oversight of the uranium enrichment program from the AtomicEnergy Commission; in 1977, these functions were transferred to DOE. Martin Mariettabecame the operating contractor for the Plant, replacing Union Carbide, in 1984.

The Energy Policy Act of 1992 created USEC and was a first step in theprocess of privatizing the government’s uranium enrichment enterprises. In July 1993,USEC leased portions of the Plant from DOE, assumed responsibility for uranium enrichmentactivities, and contracted with Martin Marietta Utility Services, a subsidiary of MartinMarietta, for operation and maintenance of enrichment activities. Through a June 1995corporate merger, Martin Marietta Utility Services became Lockheed Martin UtilityServices. NRC granted a certificate of compliance to the Plant in November 1996 under 10CFR Part 76, and regulatory oversight of enrichment operations was transferred from DOE toNRC in March 1997. As a result of an initial public offering, USEC was privatized as aninvestor-owned corporation in July 1998. USEC took over direct operation of all enrichmentactivities at the Plant in May 1999, with most Lockheed Martin Utility Services personnelbecoming employees of USEC.

DOE is the site "landlord," owns the physical plant, and isresponsible for operation of the Northwest Groundwater Treatment Facility and threeinactive landfills. DOE retains responsibility for the environmental restoration program,most elements of the waste management program, and all waste materials generated by pastDOE activities. Bechtel Jacobs is the management and integrating contractor for DOE,having been awarded this contract in April 1998. Bechtel Jacobs relies on subcontractorsto conduct environmental restoration and waste management functions. Simplifiedorganization charts for the DOE Paducah Site Office and Bechtel Jacobs are shown in Figure4.

**Figure 4. Simplified Organization Charts for the DOE PaducahSite Office and Bechtel Jacobs**

****
USEC facilities consist of process buildings, electrical switchyards, asteam plant, a water treatment facility, a chemical cleaning and decontamination facility,and maintenance and laboratory facilities. Over its operating lifetime, PGDP has processedmore than 1,000,000 tons of uranium. The process of enriching uranium at PGDP involvesconversion of UF6 to compressed gas, which isin turn fed through a series of diffusion stages; PGDP has over 1,800 diffusion stages.The diffusion process generates enriched uranium product and tailings. The product is thenshipped to the Portsmouth Gaseous Diffusion Plant in Ohio for further enriching. Thetailings, containing less than 0.5 percent uranium-235, remain on site in cylinders.
During the Plant’s operating history, the process of enrichinguranium for military and commercial applications has — in addition to the product andthe tailings — generated other radioactive and non-radioactive wastes, and hasintroduced other materials to the Plant not associated with naturally occurring uranium.These waste materials include transuranic elements (isotopes with atomic numbers greaterthan uranium) such as neptunium-237 and plutonium-239, fission products such astechnetium-99, PCBs, and volatile organic compounds such as trichloroethene (TCE). Thesewaste materials present differing levels of risk to workers and to the public dependingupon their concentration, pathway of release, and method of exposure. Figure 5 shows thehistoric process of uranium enrichment and its byproducts. Characteristics of selectedhazardous materials (i.e., radioactive and non-radioactive) at the Plant are described onthe page following Figure 5.****Figure 5. Schematic of Historic UraniumEnrichment Process**** 

 
*****CHARACTERISTICS OF    SELECTED HAZARDOUS MATERIALS AT PGDP*****Radioactive Materials**- Uranium  – An element that naturally occurs in the earth and is        mined for commercial purposes. Natural uranium is 99.3 percent U-238 and 0.7 percent        U-235; U-235 is used as nuclear reactor fuel. Enriched uranium contains more U-235 and        depleted uranium contains less U-235 than natural uranium. U-238 has a radioactive        half-life of 4,470,000,000 years (the period of time for material to decay to half of its        initial radioactive amount). Once in the body, uranium may concentrate in the kidneys and        bones or lungs, depending on its solubility. As a heavy metal, uranium is toxic and can        damage the kidney. At enrichments less than 10 percent (PGDP’s maximum enrichment is        less than 5 percent), uranium’s chemical toxicity to the kidney predominates over its        radiological hazards.
- Transuranic Elements  – A series of elements        whose atomic numbers are greater than 92 (i.e., greater than uranium) and can be produced        when U-238 absorbs neutrons as part of a nuclear reaction. Among the transuranic elements        are neptunium and plutonium. Transuranics were introduced to the Plant when spent reactor        fuel was processed.- Neptunium-237 – Np-237 has a radioactive half-life of 2,140,000 years. Once in the          body, Np-237 concentrates in the bones and liver.
- Plutonium-239 – Pu-239 has a radioactive half-life of 24,065 years. Once in the          body, Pu-239 concentrates in the bones.
- Fission Products  – A series of elements that are created when        U-235 is split by neutrons as part of a nuclear reaction. The products of this splitting        are typically elements with atomic mass numbers in the range of 80 to 108 and 125 to 153.        Among the fission product elements are technetium and strontium. Fission products were        introduced to the Plant when recycled uranium from spent reactor fuel was received from        other DOE sites.
- **Technetium-99** – Tc-99 has a radioactive half-life          of 213,000 years. Tc-99 is highly mobile in groundwater and is readily absorbed throughout          the body, contributing relatively little radioactive dose compared to transuranic          elements. If deposited in the lung, Tc-99 would only remain in the lung for a period of          weeks.
- **Strontium-90** – Sr-90 has a radioactive half-life of          29 years. Similar to Pu-239, Sr-90 concentrates in the bones. However, if inhaled, Sr-90          would only remain in the lung for a period of days.
***Hazardous Materials**- **Trichloroethene** – TCE is a colorless liquid with        a chloroform-like odor that is often used as an industrial degreaser. TCE is a mild        irritant to the respiratory tract and the skin. Critical exposure pathways are inhalation,        ingestion, and skin or eye contact. When humans are exposed, TCE concentrates in the        respiratory system, heart, liver, kidneys, central nervous system, and skin.
- ***Chlorodiphenyl or Polychlorinated Biphenyl****–        PCB is colorless to lightly-colored, viscous liquid with a mild odor that is generally        used as a cooling medium in transformers and at PGDP in ventilation system gaskets as a        fire retardant. The critical pathways of exposure are inhalation, ingestion, and        absorption. When humans are exposed, PCBs concentrate in the skin, eyes, and liver.*

**1.3 Past Worker Safety, Public Safety, and EnvironmentalProtection Assessments**

Since the mid-1980s, there have been a number of assessments andregulatory actions related to PDGP operations. These events resulted in the identificationof issues in worker safety, public safety, and environmental protection and established aseries of actions required of DOE and contractor management to ensure resolution of theissues. Corrective actions were developed to address some of the issues and concernsidentified in the studies discussed below. The investigation team did not individuallyevaluate the effectiveness of each corrective action. ***The Report of the Joint Task Force on Uranium Recycle MaterialsReprocessing. 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 Fernald Materials Production Center, and at 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 handling andprocessing practices at PGDP 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.***Identification of Groundwater Contamination and Development ofAdministrative Consent Order.In 1988, concerns over residential water quality ledto sampling of residential wells north of the Plant and discovery of TCE, an industrialdegreaser, and technetium-99, a product of fissioning nuclear fuel. 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, 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, 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. A summary of key SWMUs, ascharacterized in Phase II, is provided in Appendix B.
***Office of Environment, Safety and Health Assessments.In thelate 1980s and early 1990s, the DOE Office of Environment, Safety and Health conducted anumber of assessments of ES&H activities and programs at PGDP. These assessmentsexamined such areas as radiation protection, health physics, industrial hygiene, andindustrial safety. Among the weaknesses identified were inadequacies in construction areahazard posting and control, failure to consistently use personal protective equipment,limitations in the systems and equipment used to measure potential exposures totransuranic elements, and the absence of monitoring of stack effluents and waterbornepathways for the presence of transuranic activity. (e.g., neptunium). Improvements werenoted in such areas as the process for conducting frisking for contamination and thehazard communication labeling program.
***Drum Spill. In March 1990, an accident during routine wastehandling operations in Building C-746-Q Warehouse resulted in the breaching of one drumwaste controlled under the Resource Conservation and Recovery Act (RCRA). High levels ofalpha contamination were present at the spill site, and review of storage records promptedradiological control personnel to conduct transferable contamination surveys for isotopicanalyses. Transuranic contaminants in the spilled material included americium-241,plutonium-239, plutonium-240, and neptunium-237. These results led to surveys of otherPlant areas. Several transuranic areas were posted as hazards, and controls commensuratewith the potential hazard were established.
***DOE Tiger Team Assessment.A concern regarding ES&Hconditions at all DOE sites led a Tiger Team assessment of PGDP in June-July 1990. Theassessment concluded that ceasing PGDP operations was not warranted, that complianceissues were known by Federal and State agencies issuing permits, and that the followingES&H and management issues required prompt attention:
- 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. 
- Formal procedures for implementing environmental protection activities    were lacking, and quality assurance programs had not been implemented for many    environmental activities. 
- Compliance with DOE orders and mandatory standards for worker safety and    health was deficient, as was the system for managing administrative control documents. 
- Training and certification programs did not meet site needs. 
- Instrument calibration practices did not always meet minimum standards. 
- There was no long-range plan for safe storage of UF6 cylinders.No integrated sitewide management system was available to track and    correct identified deficiencies.
DOE was not performing effective oversight to ensure that ES&H    initiatives were being implemented.
The site contractor did not have a corporate strategic plan to    accomplish DOE’s ES&H objectives.
***DOE Office of Nuclear Safety Radiological Oversight. In 1994, DOE’s Office of Nuclear Safety evaluated the PGDP radiologicalprotection program. The evaluation identified two strengths and five programmatic issues.The strengths included a highly competent and experienced contractor management team thatwas aware of the elements of effective radiological control. The programmatic issuesincluded (1) the need to establish standards for the sitewide radiological controlprogram, (2) the need for substantive improvement in management systems that affectcontamination control, (3) the need to improve radiological control technical bases, and(4) the need to improve the radiological control training program.***Defense Nuclear Facilities Safety Board (DNFSB) Recommendation 95-1.In May 1995, the DNFSB issued recommendation 95-1 in response to a concern over thedeteriorating conditions of cylinders housing solid UF6 across the DOE complex. At PGDP, there are more than 37,000 cylinders. The DNFSB concluded that poor maintenance and storageconditions, combined with mechanical damage suffered during handling, led to corrosion andsubsequent breaching of several cylinders. It was the DNFSB’s view that promptremedial actions should include: (1) a program to renew the protective coating ofcylinders; (2) an evaluation of additional measures to protect these cylinders from thedamaging effects of exposure to the elements; and (3) a study to determine whether a moresuitable chemical form should be selected for long-term storage of the depleted uranium.***DOE Office of Occupational Medicine and Medical Surveillance"Needs Assessment."In 1996, the Paducah Site Office asked the Office ofOccupational Medicine and Medical Surveillance, within the Office of Environment, Safetyand Health, to determine whether the available occupational medicine services weresufficient to meet the needs of the DOE Office of Emergency Management and USEC contractorand subcontractor personnel at PGDP. The assessment concluded that the occupationalmedicine program provides good medical services to workers, although services were moreoriented to family practice than to occupational health. Advanced life support serviceswere judged to be sophisticated and of high quality. Occupational health services werefound to lack formal linkage between the health and safety organization and the onsitemedical department of DOE and USEC. The lack of information sharing among healthprofessionals was also cited as a weakness.
***Department of Health and Human Services (DHHS) Public HealthAssessment.DHHS completed a draft public health assessment of PGDP in the fall of1999, which is required for all sites on the EPA’s National Priorities List; thePlant was designated as such in May 1994. A draft of the assessment concluded that, undernormal operating conditions, PGDP does not currently pose a health hazard to offsitepopulations, although members of the public near PGDP may be exposed to low levels ofcontamination. This conclusion assumes that access restrictions and fish advisories remainin effect. DHHS also concluded that a future groundwater pathway could exist if new wellsare drilled into plumes northeast and northwest of PGDP by future landowners. Contaminatedsurface water, soil and sediment, and biota surrounding the Plant were judged to pose nohealth hazard due to the low levels of exposure. Offsite transportation of cylinderscontaining depleted uranium was examined as a potential public health hazard. DHHSconcluded that a transportation accident involving a fire and rupture of a cylinder wouldpose an urgent public health hazard to individuals within 70 meters of the rupturedcylinder, although the probability of this event is very low.
**1.4 Recently Identified Concerns**
****   **Quantities of uranium materials areclearly evident at product handling points in Building 340.**

There have been recently identified concerns associatedwith prior operations, past work practices, and the management of legacy materials (thoseremaining from past operations) at PGDP. These concerns, described in more detail in aseries of disclosure statements made by three current and/or former Plant employees andone member of a private interest group, can be characterized as follows:
- Information provided to DOE, the Commonwealth of    Kentucky, and the public regarding the nature of occupational risks and levels of offsite    contamination was incomplete and/or not fully accurate. 
- Safety-related roles and responsibilities were not    clearly assigned, so key safety responsibilities are not being properly addressed.Contractor management discouraged personnel from raising    safety issues, and/or concerns that were raised were not addressed in a timely manner.Information on site hazards was not communicated to    workers in a timely manner and/or training programs were not sufficient or rigorous enough    to convey these hazards to workers.Hazard controls (administrative and engineering controls,    and use of personal protective equipment) for workers in radiation areas did not ensure    adequate protection.Occupational radiation exposures were not accurately    communicated to workers.Radioactive and hazardous materials were disposed of in    unapproved onsite and offsite locations, were improperly shipped, and/or were not surveyed    before leaving the site.**1.5 Investigative Approach
To support the overall objective of determining whether current workpractices are sufficient to protect workers, the public, and the environment, the Officeof Oversight investigation team interviewed personnel; observed work activities; performedwalkdowns of facilities, work areas, and the site grounds; sampled and analyzedgroundwater, surface water, sediment, and soil; conducted radiological surveys; andreviewed documents. Issues identified by the investigation team are summarized in AppendixA of this report.
Over 100 interviews were conducted with DOE Headquarters, Oak RidgeOperations Office (OR), and Paducah Site Office personnel; Bechtel Jacobs andsubcontractor managers, supervisors, and workers; selected USEC personnel; andstakeholders. USEC personnel were interviewed to clarify the nature of DOE activitiesconducted in USEC-controlled space and to better understand how USEC performs work forBechtel Jacobs under a subcontracting arrangement. To ensure that an accurate record ofinterviews was maintained, 25 formal interviews with DOE and Bechtel Jacobs personnel werecaptured in transcripts.

The investigation team observed numerous facilities and work areas tofamiliarize themselves with Plant operations, work practices, and hazard controls.Essentially all DOE-controlled Plant facilities, waste and material storage areas, andsite grounds were visited by the investigation team. Many facilities and storage areaswere examined multiple times. A variety of job planning, maintenance, and operationalactivities were also observed to understand how work activities are planned and executed.

****  **The sampling team collected soil samples at the baseof Drum Mountain. Grass areas were surveyed at 8 million disintegrations per minute withvisible uranium materials present.**
The investigation team collected over 30 samples from groundwaterwells, surface water sources, sediments, and soil, as well as from materials, equipment,and facilities (see Section 2.1 for more information). Samples were collected both insideand outside the perimeter security fence. These samples were evaluated for the presence ofradioactive and non-radioactive contaminants. Most samples were "split" orseparated into two samples for purposes of running a parallel test, and samples weremaintained under a strict chain of custody.

To supplement the interview, observation, and sampling processes,hundreds of documents — including plans, procedures, and assessments — werereviewed by the investigation team. These reviews provided crucial perspectives on theassignment of roles and responsibilities, conduct of work activities, and the record ofassessment findings. This extensive process for gathering information enabled the team toproceed in a structured fashion to: (1) understand conditions as they existed in 1990; (2)fully comprehend the issues being raised regarding past operations, past work practices,and management of legacy materials; (3) evaluate the effectiveness of actions taken by thePlant in the last decade to address ES&H issues; and (4) assess current conditions atthe site and their impact on worker safety, public safety, and the protection of theenvironment. These evaluations are documented in the remainder of this report.
**    **Assessmentof Current Conditions**

In keeping with the investigation team’s mission of evaluatingcurrent conditions at the Plant and their impact on ES&H, the results of theseevaluations are organized in three main sections — Public and EnvironmentalProtection (Section 2.1), Radiation Protection and Worker Safety (Section 2.2), and LineOversight (Section 2.3). The Public and Environmental Protection section examines existingpathways for hazardous materials to be transported to the environment, the types ofeffluents that are being transported, legacy sources of contamination, the extent ofcontamination in groundwater and in surface waters, the site’s efforts undertaken bythe site to control contamination, key results from the sampling and analysis conducted bythe investigation team, and the effectiveness of efforts to provide information to thepublic and other stakeholders. The Radiation Protection and Worker Safety section outlinesthe nature and extent of risks that workers face at the site from both radiological andnon-radiological hazards, the use of engineering and administrative controls to mitigatethese hazards, and the effectiveness of systems for planning and managing work at thesite. The Line Oversight section examines the effectiveness of DOE and contractormanagement functions that are necessary to ensure protection of workers, the public, andthe environment.**2.1 Public and Environmental Protection
Since the 1950s, past industrial operations at PGDP produced largequantities of legacy materials that have been disposed of in landfills or burial grounds,released into the environment, or placed in long-term storage. Current DOE operations atPGDP focus primarily on the administration of programs to address legacy materials and oninfrastructure maintenance. 
***Current Pathways for Contaminant Transport in the Environment from DOE    Operations Include:
- *Discharges of process and stormwater runoff from the site into local        surface water bodies*
- *Sediment transport through erosion and surface water runoff*
- *Air emissions from diffuse sources, such as wind-blown dispersion of        surface contamination and suspension of contaminated dusts by vehicle traffic*
- *Rainwater infiltration, leaching, and transport of contamination into        the groundwater from former spills, burial grounds, and landfills*

DOE has the responsibility to characterize and control emissions ofcontaminants into the environment from DOE operations or past practices. To characterizechemical and radionuclide effluents into the environment from DOE operations at PGDP, thesite has established an environmental monitoring program as required by DOE Order 5400.1, *GeneralEnvironmental Protection Program*. Compliance with the terms of the Commonwealth ofKentucky permit for discharges of liquid effluents is also monitored on a routine basis.In addition to routine environmental monitoring, DOE, with oversight by the EPA and theCommonwealth of Kentucky, is conducting extensive investigations into the nature andmagnitude of contamination in the environment as provided for in agreements and permits.

**   Investigations conducted in 1990 and 1991 reported that the offsitecontaminated groundwater plumes are some of the largest in the DOE complex.**
Investigations conducted in 1990 and 1991 reported that the offsitecontaminated groundwater plumes are some of the largest in the DOE complex. Additionally,numerous areas of radiological and chemical contamination have been discovered within thesite security fence, outside the security fence on surrounding DOE property, and inoffsite areas now managed by the State of Kentucky Fish and Wildlife Service. Sources ofcontamination include waste burial grounds, old sanitary landfills, scrap yards, wastelagoons, spill sites, and leaks from contaminated buildings. These areas will be examinedin more detail in Phase II of this investigation.

Interim steps have been taken since 1990 to protect the environment andpublic health. Groundwater pumping and treating efforts have helped to impede some of thehighest areas of contamination. In a defined area referred to as the water policy area,alternative sources of water have been provided to residents with contaminated wells.These steps have reduced public risk, but contamination sources still exist, and thegroundwater plumes have continued to spread from the site at approximately one foot perday.

***Activities to Control Migration    of and Exposure to Contaminants at PGDP***
- *Supplying public water to residents and businesses with the potential        for contaminated drinking water wells*
- *Installing limited groundwater pump and treatment systems on the        Northwest and Northeast Plumes*
- *Placing sediment fences around the scrap yard*
- *Diverting the discharge from the North-South Diversion Ditch through        the wastewater treatment plant*
- *Installing clay caps on some old landfills*
- *Excavating "hot spot" PCB contamination*
- *Retrieving contaminated material from the Ballard Wildlife Area*

Cleanup plans and strategies have beendeveloped in accordance with Federal environmental regulations. The site is currently incompliance with the provisions of the Federal Facility Agreement. DOE developed a SiteManagement Plan that includes program management requirements and a Site RemediationStrategy to coordinate RCRA and CERCLA cleanup requirements. The Site Remediation Strategydefines remediation priorities and provides a framework for establishing site-specificgoals that are consistent with the overall cleanup goals and priorities outlined in the ORdocument, "U.S. DOE Accelerating Cleanup: Paths to Closure," revised May 1999.****    DOE has taken a number of steps to improve the efficiency of sitecleanup operations.****
DOE has taken a number of steps to improve the efficiency of sitecleanup operations. A management and integration contract was established to increaseaccountability for meeting cleanup milestones. DOE waste areas were organized into asmaller number of operable units to accelerate regulatory review and approval of cleanupmethods and strategies. Actions have been taken to control waste management activities atthe point of generation and in the facilities regulated by external environmentalrequirements. These actions include developing and implementing procedures for managingand disposing of waste generated by DOE operations at the site. In part, these procedureswere developed to address findings from the 1990 DOE Tiger Team assessment involving wastemanagement, waste characterization, and the scrap yard and landfill operations.
In addition, the site constructed two new waste management facilities,built a new landfill, and adequately maintains existing waste management facilities forregulated waste streams including hazardous waste, asbestos and PCB wastes, and sanitarywaste. The site’s waste acceptance criteria document, revised in May 1999, providesguidance and requirements for meeting the acceptance criteria for these facilities formost waste streams generated by DOE operations at the site. 

**    Radiological and chemical contamination from past industrial activitiesat PGDP has been released into the surrounding ground, soil, and air.**
Radiological and chemical contamination from past industrial activitiesat PGDP has been released into the ground, soil, and air around the Plant. Effluents fromcurrent DOE operations appear to be in compliance with State discharge limits.Radiological and chemical contamination has spread from the site boundary into thegroundwater and surface sediments, particularly into the Big and Little Bayou Creeks, andis documented in investigation reports published by DOE. Contamination continues topropagate in these media, prompting DOE and regulatory organizations to take precautionarysteps to protect public health, such as connecting local residents to public watersupplies and limiting public use of lakes and sections of local streams and ditches.Contamination continues to migrate from source areas into the environment. However, basedon the limited duration of public exposure to contamination and the mitigation measurestaken to prevent the consumption of contaminated water and foodstuffs, DOE operations at PGDP do not now present a significant public health risk. ****    Limited progress has been made in remediating hazardous materialsource areas.
Despite the limited public health risk, significant improvements inprotecting the public and the environment are needed. Limited progress has been made inremediating hazardous material source areas such as landfills, burial grounds, and wasteand scrap piles. Limited funding has played a significant role. Additionally, weaknessesin characterization of groundwater and surface contamination were identified. Controls toprevent the spread of contamination have not yet been fully implemented. While limited inmagnitude, some radiological exposure pathways to the public have not been fully assessedor evaluated. These include airborne fugitive emissions from contaminated areas and thedirect radiation from cylinder yards. Although improvements were noted in most wastemanagement practices, the investigation team noted a number of concerns, primarilyrelating to inappropriate storage of legacy waste materials. Additionally, programmanagement weaknesses were identified within the Paducah Site Office and Bechtel Jacobs regarding their ability to integrate and interpret environmentalinformation. Technical personnel are not assigned or available in sufficient numbers tointerpret the vast amounts of data associated with specific environmental disciplines,such as groundwater and environmental radiation protection. Finally, public communicationhas not been effective in providing information regarding environmental contamination andcleanup initiatives, contributing to the perception among some stakeholders that DOE andthe contractor are withholding information.**Issues
**1. There has been limited progress in remediating and characterizingenvironmental contamination, low-level wastes, and stored hazardous materials that wereproduced by past industrial activities, and major cleanup milestones under the FederalFacility Agreement are jeopardized by funding constraints. A keyelement contributing to the lack of progress is limited available funding. DOE has notprovided sufficient funds to significantly reduce sources of contamination, such as buriedwastes, soil contaminated by previous spills and releases, exposed contaminated scrapmetal and waste materials, and degrading contaminated buildings. The scope of PGDP workfunded by DOE has been limited primarily to characterizing contamination, operating andmaintaining the site infrastructure, meeting regulatory requirements, and controlling thespread of contamination. While the site is currently in compliance with the 1998 FederalFacility Agreement, near-term milestones are in jeopardy. Progress has been limited in thefollowing areas.****    Contamination continues to propagate at one foot per day and nowextends for over two miles.**
****    **One ash receiver in Building 410remains in place after 22 years, held in place by corroded C-Clamps. Uranium materialswere clearly migrating from the receiver.**

•   Most of the sources of contamination identified in 1991 still remain.Contaminated materials from burial grounds, old landfills, inactive waste lagoons, orspill sites have not been removed or treated. Groundwater plumes containing TCE andtechnetium-99 that have resulted from some of these sources continue to propagate at onefoot per day and now extend for over two miles.
**    Shutdown buildings have been allowed to deteriorate and are subject toanimal infestation, broken windows, and leaking roofs.**- 
Contaminated process buildings, which    were shut down over 20 years ago and for which no future use is expected, have not been    adequately maintained or taken down. Residual materials have not been fully analyzed or    removed, and surveys indicate that contamination is spreading within the buildings. Large    volumes of low-level radioactive wastes remain stored within the buildings. These shutdown    buildings have been allowed to deteriorate and are subject to animal infestation, broken    windows, and leaking roofs. They are not included in the 2010 cleanup schedule, and they    are increasing in risk and cost to decommission.

- 
A large volume of contaminated waste materials (Drum    Mountain) and scrap metal that has accumulated since the 1950s is stored outside in piles    and inside the Plant security fence. These areas continue to contribute contamination to    the environment through surface water runoff and dispersion. The Federal Facility    Agreement requires removal of this material from Drum Mountain and beneath it by 2003. The    site estimated and requested funding, but current budget proposals provide only $1.3M    (versus $3.6M required) for fiscal year 2000 and $3.2M (versus $13.7M required) for fiscal    year 2001 (see Figure 6).

******   **Outdoor drum storage.******
**    Disposal of low-level waste has received low funding priority becausethere are no regulatory requirements or identified safety concerns requiring near-termdisposition.**

•   Atotal of 6,444 cubic meters (equivalent to approximately 31,000, 55-gallon drums) oflow-level waste are stored onsite at PGDP. This includes 1,775 m3 stored outsidein over 8,000 containers that were not designed for long-term storage. Many of thecontainers stored outside are severely degraded, and some have leaked as a result. Much ofthe site’s low-level waste is not fully characterized for shipment, and some maycontain transuranic materials. Disposal of this waste has received low funding prioritybecause there are no regulatory requirements or identified safety concerns requiringnear-term disposition. As a result, only 157 m3 have been shipped from the site since 1990. The schedule for completing disposalhas subsequently changed from fiscal year 2006 to fiscal year 2012. Additionally, currentfunding targets assume that no new waste management facilities will be needed toaccomplish the site mission. This assumption does not take into account necessary effortsto open, inspect, and characterize the thousands of low-level and mixed waste drumscurrently stored onsite. Elsewhere in the DOE complex (Rocky Flats EnvironmentalTechnology Site and Nevada Test Site), engineered facilities are used to conduct thesecharacterization and segregation efforts. Such facilities would significantly reduce therisk to the workers who open the containers for inspection and characterization.
**Figure 6. PGDP Funding History (Budgetinformation provided by Bechtel Jacobs)**
**    DMSAs contain large amounts of uncharacterizedmaterial.**
- DOE Material Storage Areas (DMSAs) belonging to DOE but located in    facilities that have been leased to USEC, contain large amounts of uncharacterized    material that includes drums labeled as asbestos waste, drums labeled as containing    detectable levels of PCBs, and old electrical equipment. A multiyear project to    characterize this material has identified waste regulated under RCRA. DOE is not managing    DMSAs pursuant to either RCRA or CERCLA regulatory requirements. 
- The nearly 37,000 UF6 cylinders stored on site in the open at PGDP constitute a radiological    exposure hazard and a potential threat to worker and public health in the event of fire    and rupture. In 1995, the DNFSB recommended upgrading the condition of the cylinders and    converting the UF6 to a more stable form. Plans to paint    1,400 cylinders (to seal them) were cancelled due to funding constraints, and funds for a    UF6 conversion facility have not yet    been appropriated. 

****   **Approximately37,000 cyclinders of UF6, each containing up to 14 tons, remain stored onsite pending conversion to more stable forms.**

•   The published accelerated cleanup schedule forremediation of environmental hazards at PGDP is not realistic. PGDP received a total of$36M for fiscal year 1999. Site estimates indicate that PGDP will require significantincreases in funding, up to $160M in fiscal year 2008, to meet the completion goal offiscal year 2012. The scheduled completion date is based on an assumed increase in fundingfor PGDP. Nevertheless, appropriations have decreased significantly since 1995, despiterequests for increases, and have been significantly below the targets necessary toaccomplish the accelerated cleanup. The funding necessary to accomplish the 2012 goal willnot be available without a significant change in appropriations. As indicated in Figure 7,current funding levels will extend site cleanup until 2020, well beyond the required 2012milestone.

**Figure 7. PGDP Funding Requirements vs. Target, Fiscal Years2000-2020**
****    The Site Remediation Strategy does not reflect the increasing risk andcleanup costs associated with decontamination and decommissioning of shutdown processbuildings.**- The Site Remediation Strategy does not reflect the increasing risk and    cleanup costs associated with decontamination and decommissioning of shutdown process    buildings. The schedule also assumes the success of cost-saving initiatives, such as    reduction of overhead expenses by use of an management and integrating contractor, use of    a revised documentation strategy to limit the number of remedial investigations and    feasibility studies, significant cost savings by recycling scrap left on site, and    reduction of long-term site maintenance costs by replacing the current pump-and-treat    approach to groundwater remediation with a passive alternative. Achieving the necessary    cost savings through these initiatives has not been demonstrated. 
****    DOE has not been successful in conveying needs and obtainingcongressional funding for cleanup of PGDP.**- DOE has not been successful in conveying needs and obtaining    congressional funding for cleanup of PGDP. PGDP has consistently been allocated less    funding than requested for waste management and environmental remediation. These    reductions occurred during a period when environmental risks and regulatory commitments    for cleanup were increasing. Cleanup activities at PGDP have been funded almost entirely    from the Uranium Decontamination and Decommissioning Fund. A 1998 report to Congress by    DOE on the use of this fund did not identify the need for additional funds to keep the    contamination at PGDP from spreading to the surrounding environment. This OR-prepared    report emphasized accomplishments, but did not discuss the challenges faced at the site to    reduce and prevent spread of contamination to the environment within a declining budget. 
****2. There are continuingweaknesses in the radiation protection management of known environmental contaminationareas by both Bechtel Jacobs and DOE.** These include deficiencies in radiologicalcharacterization, posting, contamination control, and application of principles to reduceenvironmental hazards as low as reasonably achievable (ALARA). Such weaknesses arecontrary to sound health physics practices and the radiological expectations delineated byDOE in orders, regulations, and standards.********   ****Thisarea was recently discovered near the S&T Landfill. Black "ooze" wasdiscovered to be radiologically contaminated. This area has been covered and posted,pending further investigation.******
**    The full extent of radiological contamination bothinside and outside the site security fence has still not been characterized through asitewide survey and sampling program.**

•   The areas of most significant radiologicalcontamination have been identified during past investigations; however, the full extent ofradiological contamination both inside and outside the site security fence has still notbeen characterized through a sitewide survey and sampling program. For example, an area ofcontamination adjacent to the S Landfill was recently identified. At this location, atar-like substance reading 43,000 disintegrations per minute was discovered andsubsequently covered and posted to control access. There is no documented listing ordatabase of radiologically contaminated areas other than what is included in the SWMUlist, which is not maintained by the radiological control organization and does notclearly designate contaminants of concern for each SMWU.

**    Areas of contamination that exceed Bechtel Jacobs radiological postingcriteria were noted.**- The investigation team noted areas of    contamination that exceed Bechtel Jacobs radiological posting criteria in Kentucky Permit    Discharge Elimination System Outfall 011, the North-South Diversion Ditch, and along    Little Bayou Creek at some distance from the site security boundary. Under the Bechtel    Jacobs health physics procedures, these areas would require posting as soil contamination    areas and/or contamination areas, and appropriate measures would be needed to prevent    inadvertent entry. Some of these areas are currently posted with signage and wording that    are the result of CERCLA Records of Decision or interim corrective measures, but these    postings are not consistent and, in some cases, do not specify the presence of a    radiological hazard. Neither DOE nor Bechtel Jacobs could provide a basis for not    controlling such areas in accordance with the Bechtel Jacobs radiation protection program.    The relationship among the radiation protection program, DOE orders, 10 CFR 835    (Occupational Radiation Protection), and CERCLA requirements has not been adequately    defined. It appears that DOE and Bechtel Jacobs believed that the provisions of 10 CFR 835    were not applicable, because these areas are outside the security fence. However, the    scope of 10 CFR 835 includes protecting individuals from ionizing radiation resulting from    DOE activities. Since the contamination of these areas is the direct result of DOE    activities, 10 CFR 835 would apply.
****   **Drum Mountain contains residual uraniummaterials that are contributing to contamination of the environment.**
•    Radiological contamination has migrated from known sources at PGDP. These environmentalproblems may impact areas previously free from radiological contamination. Resuspension ofwind-blown, radiologically contaminated soils or the impact of radiologically contaminatedsurface water runoff represent potential problems, further complicated by the potentialtracking of contamination by personnel and vehicle traffic. Only limited and incompletemitigation measures for these potential sources have been implemented on site, such as atDrum Mountain, the scrap yards, or the three decontamination and decommissioningbuildings. Sediment fencing has been installed but does not eliminate sediment runoff. 
****    Environmental ALARA considerations have not beenintegrated into all processes.- Environmental ALARA considerations have not    been integrated into all processes, and appropriate controls have not always been    incorporated into design, construction, and remediation activities. An effort was made to    develop an environmental ALARA program in 1995 in anticipation of 10 CFR 834, Radiation    Protection of the Public and the Environment, but the process is not fully documented or    implemented. Environmental ALARA considerations have not been formally integrated into    environmental programs as required by DOE Order 5400.5,*Radiation Protection of the    Public and the Environment*. The manner in which liquid and airborne radiological    discharges are subjected to the ALARA process is not defined. 
- The current waste acceptance criteria for the    sanitary landfill do not specifically prohibit disposal of objects that could be    classified as low-level radioactive waste based on exceeding DOE Order 5400.5 surface    contamination limits. The current landfill waste acceptance criteria fail to specify any    limits for surface contamination and rely solely on a uranium limit of 30 pCi per gram as    the only radiological criterion to determine the suitability of waste for disposal. The    technical basis document that established waste acceptance criteria for the landfill does    not address surface contaminated objects, such as roofing material, concrete, rubble, and    debris that are disposed of in the landfill. It is unclear whether, or how, such materials    are to be sampled volumetrically, or whether waste disposal practices would allow for    disposal of materials that exceed DOE Order 5400.5 radiological limits in the sanitary    landfill. This technical basis, although approved by the Field Office Manager, contained    items that exceeded the Field Office approval criteria. Therefore, pursuant to DOE Order    5400.5, this technical basis document should have been approved by the Office of    Environment, Safety and Health. 

**3. Radiological exposure pathways for DOEoperations have not been fully assessed or documented.** While projected doses areexpected to remain low, weaknesses are evident in the assessment and reporting of allpossible air emission sources and in the accuracy of public dose calculations.
**    The magnitude of "fugitive"emissions at PGDP DOE facilities is not known.**
****    **Manylocations in shutdown buildings contain degraded lagging probably containing asbestos.**
•   The magnitude of"fugitive" emissions at PGDP DOE facilities is not known, and this pathway hasnot been fully evaluated or documented. Radionuclide calculations do not include anycontribution to dose from fugitive emissions as required under the National EmissionStandards for Hazardous Air Pollutants. Fugitive emissions from a number of diffusesources — such as contaminated ground resuspension, scrap piles, rooftop dispersion,and vehicular traffic — are inevitable and could contribute significantly to thecalculated public dose (estimated to be 1.14 mrem in 1997). In lieu of actual source termdata, the concentration of uranium and transuranic contaminants in soils has never beenused in estimating a release fraction or fugitive emission source term for input to thedose model. Instead, the site assumes that fugitive emissions are insignificant andreports negligible contributions to dose from this pathway; this assumption is notsupported by any documented technical basis. The absence of measurable readings on theambient air monitors used by USEC and the Commonwealth of Kentucky is not a valid basisfor concluding that fugitive emissions from DOE activities are insignificant, since thesensitivity and location of the air monitors are not sufficient to make thatdetermination. ****    Public dose estimates from ingestion of contaminatedsediment are not consistent.- Estimates of radiation doses to the public    from ingestion of contaminated sediment are not consistent. Although no remediation of    contamination has occurred, the reported dose changed from 2 mrem per year in 1992 to 0.07    mrem per year in 1995. The main difference is the use of sediment sampling results    obtained during the current year for dose calculations. While actual radionuclide    concentrations may be decreasing because contamination is spreading downstream, only one    or two sediment samples are taken in each location annually. This variation raises    questions about the use of such data as accurate, representative, and conservative. In    lieu of a complete characterization or remediation of sediments, the highest reported    historical values would be more appropriate for use in the public dose calculations. In    addition, even though transuranics and thorium were found in some samples, dose    calculations are only based on uranium and technetium data.The 1998 draft Annual Site    Environmental Report provides data on studies of thermoluminescent dosimetry conducted in    the vicinity of the UF6cylinder storage yards. Before 1998, direct    exposure to penetrating radiation from cylinder storage was not considered in the public    dose calculations. The 1998 data indicate that up to 1,000 mrem in a year could be accrued    just outside the security fence; however, the 1998 draft Annual Site Environmental Report    indicates no actual public dose from this pathway. DOE and Bechtel Jacobs justify this    assessment by using the nearest resident as the "maximally exposed receptor    point" when calculating radiation exposures. This is not the most conservative or    realistic receptor point, given that there are members of the public who have access to    areas in close enough proximity to potentially receive a dose (e.g., staged truck drivers    awaiting offload, joggers, hunters, and hikers) greater than the nearest resident.
**4. Groundwater contamination has notbeen adequately characterized in some areas.**Extensive efforts have been undertaken tocharacterize the major sources and the extent of groundwater contamination as a result ofthe discovery in 1988 of contaminated residential drinking water wells near the site. DOEhas generally defined the nature and extent of contamination in the Regional GravelAquifer and the McNairy Formation, has established a water policy to ensure that thepublic is adequately protected, and has taken interim pump-and-treat actions. While thesecharacterization and control efforts were appropriate, some areas have not been fullycharacterized. 
**    Sufficient data are lacking on theleading edges of both the Northeast and the Northwest Plumes.
****    **Thepump-and-treat facility for the Northeast Plume was installed to slow the spread of TCE.**
•   Sufficient data are lacking on the leading edges of both the Northeast andthe Northwest Plumes. The density and positioning of monitoring wells are not adequate toassess the furthest movement or the discharge locations, such as streams, of the twonorthern plumes. The most recent plume map shows that movement has occurred under aportion of the Tennessee Valley Authority (TVA) property (see Figure 8). Groundwatersamples taken by the site in the early 1990s indicated low concentrations of technetium-99on TVA property. Those sampling efforts were discontinued in the early 1990s. The TVAShawnee Steam Plant borders the Ohio River.

**Figure 8. Northeast and Northwest Plumes**
 
- The Southwestern Plume was recently    discovered. The rate of movement and the direction have not yet been characterized, but    the apparent movement is initially toward the southwest. After a short distance it bends    toward the north. Because groundwater flow may be influenced by the abundant gravel in    river deposits in this area, this plume will require additional characterization. Recent    field studies have bounded the plume to the north and the south as it exists in the fenced    area. 
- Several sources are responsible for the    groundwater contamination in the two major plumes. A major contributor to the Northwest    Plume is a facility that used large volumes of TCE for degreasing equipment (Building    C-400). High concentrations of TCE dissolved in groundwater near C-400 and    characterization studies suggest that TCE exists in pure form in the subsurface. Building    C-400 is also a major source of technetium-99 contributing to the Northwest Plume.    Building C-400, which contributes to both northern plumes, indicates the complexity of the    source areas. Because of this complexity and interaction of plumes and source areas at    PGDP, it is necessary to analyze these elements as one interactive system in the    subsurface. However, since 1992, plumes and sources have been analyzed individually or in    limited groups, resulting in redundant work and limiting the effectiveness of the sitewide    analysis. The recently established Groundwater Operable Unit concept is designed to    consider all sources and plumes in an integrated fashion.****    Removal or treatment of the sources of groundwatercontamination has not begun.- Removal or treatment of the sources of    groundwater contamination has not begun, although extensive characterization studies and    treatability studies have been conducted. Innovative removal technologies have been    reviewed for application, and the Lasagna treatment technology will be initiated on one    major source in the near future. The site has also installed two groundwater    pump-and-treat systems to contain and reduce concentrations in the Northeast and Northwest    Plumes. During the Office of Oversight investigation, the Northeast Treatment System was    not operational due to maintenance of the cooling towers. These systems were installed as    interim measures to contain contamination existing in the most concentrated portions of    the plumes. Limited pumping rates decrease the effectiveness of the plume removal systems,    as confirmed by subcontractors’ calculations. Small portions of the contaminated    groundwater plumes with the highest concentrations are being treated by the systems.**5. Unclear assignment of responsibilities and weaknesses in theintegration and interpretation of environmental information have adversely impacted theunderstanding of environmental conditions. DOE and Bechtel Jacobs staff at the site donot have the requisite comprehensive knowledge of the nature of existing contamination inthe various environmental media (surface water, sediment, soils, groundwater, and air). Inthis area, sufficient technical personnel are not assigned or available to interpret thevast amounts of data associated with specific environmental disciplines. The site has notestablished clear staff responsibilities for environmental radiation protection functions.The site’s outsourcing strategy will compound this weakness, at least in the nearterm, as additional environmental professionals are transitioned to subcontractorpositions or find other employment. Specific weaknesses were identified in the followingareas.
- Although the TCE and technetium-99 plume    maps have been updated regularly, their interpretation has not been reported. Such a    report would discuss data used in preparing the map, changes in the plumes from previous    interpretations, and recommended actions. A comprehensive sitewide discussion of    hydrogeology is available in an investigation released in November 1992. In 1995, two    reports were issued regarding further characterization efforts on the Northeast and the    Northwest Plumes. However, since 1992 there has been no integrated interpretation of    groundwater data; such an interpretation would include water level and plume maps prepared    for selected dates to support assessment projection of contaminant transport.
****   **Existing landfillshave been capped, monitoring wells have been put in place, and controls have beeninstalled to limit erosion of sediments and spread of contamination.**
•   Accountability andprotection issues have not been clearly defined. Neither DOE nor Bechtel Jacobs hasdefined clear responsibilities or designated specific individuals for managingenvironmental radiation protection issues including pathway analysis, public dose,environmental ALARA, postings, and contamination control. One subcontracted individual hasaddressed some of these issues, but his current contract does not include radiologicalsupport. Such support is handled on a task-specific basis through contract extensions.
- While the scope of DOE and USEC responsibilities    was adequately delineated in lease agreements, the magnitude of continuing DOE    environmental responsibilities following the transition may have been underestimated by    DOE and site contractors, adversely impacting effective environmental management. For    example, in the area of radiological air emissions, the initial assumption was that    process air emissions constitute the only emissions from the site. This assumption has led    to inaccurate representations in the DOE environmental monitoring plan that there are no    airborne radioactive emissions resulting from DOE legacy operations.****    The site has not included technical data gathered fromremedial investigations in the Annual Site Environmental Report since 1993.- Another programmatic weakness noted was in    the information collected from the environmental monitoring program, which forms the basis    of the information reported in Annual Site Environmental Reports. While these reports make    generic statements about the types and kinds of remedial investigations, the site has not    included technical data gathered from remedial investigations in the Annual Site    Environmental Report since 1993. This is contrary to the intent of DOE Order 5400.1, which    states that results of sampling conducted as part of the environmental monitoring program    or as part of a special study should be summarized in Annual Site Environmental Reports.    By omitting this data, site management is not providing a complete description regarding    the nature and extent of the presence and transport of environmental contamination at the    site. Bechtel Jacobs has indicated that DOE site management concurred with the decision to    provide only a generic summary rather than a quantitative report.**6. Information to the public has sometimes been delayed and is in formsnot clearly understood by the general public and other stakeholder groups, contributing toa perception that DOE and the contractor are withholding information from the public.Public participation and communications are fundamental components in DOE programoperations, planning activities, and decision-making. Pursuant to the Department’spublic participation policy (DOE Policy 1210.1, Public Participation), the public isentitled both to provide input to Departmental decision-making and to fully understand theimpacts of the site’s activities on their quality of life. Upon discovery ofgroundwater contamination in 1988, the site prepared a Community Relations Plan inresponse to CERCLA requirements. Initially, the communication mechanisms used by the sitepertaining to groundwater contamination were useful, such as public meetings, informationbulletins, press releases, personal contacts, and advisory committees. While someimprovements have been initiated, a review of current public participation and communityoutreach programs and activities identified a number of weaknesses resulting primarilyfrom the lack of clearly defined roles and responsibilities for public communicationactivities at PGDP. This shortcoming has contributed to deficiencies in the planning,development, implementation, and evaluation of public affairs and community relationsefforts. Specific concerns include the following.
- There are limited DOE and Bechtel Jacobs    personnel trained to communicate technical information to the public in such areas as risk    communication, public involvement, and media relations. This has contributed to instances    where information was presented to members of the public in a manner that was difficult to    understand. 
- The site has not implemented all the elements    outlined in its 1997 Community Relations Plan. From 1996 to 1998, the site significantly    reduced public communication efforts. For example, the site did not provide significant    public information in the forms of information bulletins, public meetings, personal    contacts, and speaker bureaus as outlined in the Plan. In addition, public information    bulletins were not published for this three-year period. Furthermore, the evaluation    conducted for the 1997 update included recommendations for program enhancements, such as    providing information in language that the public can easily understand. These    recommendations have not been implemented, indicating a lack of attention by DOE and    Bechtel Jacobs management.  
- Members of the public may have difficulty in    understanding ES&H conditions and initiatives from the available technical    information. For example, annual environmental reports published by the site did not    contain a clear summary of site conditions and public health risks. Other materials    prepared by the site have generally not been effective in communicating to the public the    presence and hazards of transuranic materials at the site. ****    Some members of the SSAB are dissatisfied with thequality of information they are receiving.- The site has developed a public    participation process through the Site Specific Advisory Board (SSAB), which was    established under the Federal Advisory Committee Act in 1996**.**However, some members    of the SSAB are dissatisfied with the quality (type, amount, completeness, and timeliness)    of information they are receiving. Some members also expressed concerns about not being    included in the planning process for environmental restoration activities. Additionally,    the Paducah Site Office is partially reliant on the SSAB as their vehicle for notifying    the public of activities and issues at PDGP. Although the SSAB has a written mission    statement, discussions with SSAB members determined that the mission and function of the    SSAB are not well understood. 
- Members of the public believe that DOE does not    adequately disclose information about hazards and risks and does not provide information    that meets their needs. Some have stated that they have not received complete information    on health data, health risks, or general cleanup activity for the site and often find it    difficult to obtain such information from the site. In addition, many stakeholders    question the availability of the Environmental Information Center, which is open only    during normal business hours and not on nights or weekends.**Independent Investigation Team Sampling Results
****   **The team used historical sampling results andlocal topography to map out their sampling locations.**
Environmental samples were collected andanalyzed by the investigation team in an effort to confirm that the current analyticalresults being reported by the site are accurate and representative of environmentalconditions. The types of environmental samples and the locations where they were taken areshown in Figure 9. The total sampling effort consisted of 15 groundwater, 9 surface water,and 8 soil/sediment samples. All samples but one were collected outside the Plant securityfenced area, some on DOE property. Site subcontractor personnel collected all the samplesin accordance with approved procedures that follow the guidelines established by the EPA.The Oversight investigators witnessed the collection of all samples, and chain-of-custodyforms were completed. The Oversight investigators affixed adhesive labels to thecontainers in the field to ensure sample integrity. The Oversight investigators alsoobserved all samples being placed in locked refrigerators at the end of the sampling dayand subsequently accompanied them to the USEC Laboratory, where the samples wereheld until shipment off site. Additionally, to witness the condition of the samples asthey arrived, one of the investigators met the samples upon arrival at the independentanalytical laboratory that performed the analysis.

**Figure 9. Locations of Samples(Plume Delineation Performed by Bechtel Jacobs)**

**    Groundwater, surface water, soil, and stream sedimentwere sampled and analyzed for several key radionuclides and volatile organic compounds.**
In general, the groundwatersamples were taken at the extremities of the reported plumes to confirm the extent ofcontaminant migration. Surface water samples were taken at major site outfalls flowingduring the sampling period and at points associated with surface waterways in the vicinityof the Plant. Soil and sediment were primarily sampled at outfalls and ditches near sourceareas of contamination. Groundwater, surface water, soil, and stream sediment were sampledand analyzed for several key radionuclides and volatile organic compounds, focusing on thecompounds listed in the box below. Some analytical results were not available in time tobe considered in this report. Any abnormal results from this remaining analytical workwill be incorporated into subsequent reports. Laboratory analytical detection limits weredesigned to be low enough to ensure that contaminants would be detected at levels wellbelow those that could be significant to public health.
**Radionuclides**
**Chemicals**
Technetium-99    Plutonium-239/240    Neptunium 237    Uranium-235    Uranium-238    Thorium-230    Americium-241    Cesium-137
Volatile organic compounds,    including trichloroethene (TCE)

Polychlorinated biphenyls (PCBs)**Summary of Sampling Results

**   The types and levels of contamination detected in samplesanalyzed independently were generally consistent with the site’s past environmentalmonitoring results.**
Radiological and chemical contamination ingroundwater, surface water, and soils/sediment was detected in some of the samples takenfor this investigation. With a few exceptions, the types and levels of contaminationdetected in the samples were consistent with the levels identified by past environmentalmonitoring conducted by the site. At some locations, contamination was not detected, orwas detected at insignificant levels or at levels representing background conditions. Theanalysis of split samples by the site produced results that were in general agreement withresults produced by the independent analyses undertaken by the Oversight investigationteam. The broad agreement between data produced by the site and the results from thisindependent investigation provide a level of assurance that the site can produce, and hasproduced, accurate environmental monitoring results. However, for two media—surfacewater and sediments—the site performs only very limited sampling annually and doesnot include all analytes in all sets of samples. Therefore, it is not clear that thesite’s environmental monitoring and surveillance results are fully representative ofactual conditions. In two instances, independent soil/sediment sample analyses identifiedconcentrations of isotopes other than uranium and technetium at levels not previouslyreported by the site for locations outside the site security fence. These were in Outfall15 and in the North-South Diversion Ditch, where the independent analyses detectedtransuranics and cesium-137 at significant environmental concentrations. The site has notroutinely taken samples from these locations as part of the environmental surveillanceprogram.**Groundwater 

The Oversight investigation team’s groundwater sampling strategyinvolved taking a sample ahead of the plume in the direction of the plume movement inorder to confirm the advance of the contamination. In a one-to-one comparison usingprevious data from the same wells, analytical results agreed with the site database andthe chemical analyses of contaminants being reported by the site. The numerical values forkey parameters are tabulated in Table 1.

**Table 1. Measured Values of Activities and Concentrations ofConstituentsin Groundwater Samples Taken from Fifteen Wells**
**Well    Identification**Pu-239/240    (pCi/L)**Pu-238    (pCi/L)**Tc-99    (pCi/L)**Am-241    (pCi/L)**Sr-90    (m**g/L)****U-238    (m**g/L)****TCE1    (m**g/L)**MW-1990.0080.007ND2<0.02NA0.79NDMW-1460.009NDND0.24NA0.008NDMW-152NDND148<0.03NAV0.0060.8MW-100NDNDND<0.03NA0.006NDTVA D-47, W-13NA4NA0.9NAV5NA15.4NDR83NDNDND<0.02NA0.004NDR53NANANDNAVNA1.87NDMW-1940.008ND0.6<0.02NA0.004NDR-13NDNDNDNAVNA0.02NDMW-1210.014**NDND<0.01NA0.04NDMW-122NDNDND<0.02NA0.03NDMW-1330.010NDND<0.02NA0.29NDMW-138NANA20NAVNA6.40NDMW-1370.006ND87<0.03NAV0.013.0MW-135NDND81<0.03NAV0.193.5
1TCE    samples experienced elevated temperatures during shipping.2    ND = analyzed value at or below detection limit3    Water contained suspended solids.4NA    = not analyzed5 NAV = not available - analysis in progress
**    The Northwest and Northeast Plumes are containedwithin the water policy boundaries.**
The technetium-99 results confirm that the Northwest Plume is containedwithin the water policy boundaries and that it is migrating northward in the vicinity ofMW-152 through the TVA property. The concentration of technetium-99 reported in MW-152 was148 pCi/L. In other sampled well water, technetium-99 was not detected or was found inlower concentrations. These values were consistent with site information obtained fromprevious monitoring and investigations. Of the wells sampled in this study, none haddetectable levels of other radionuclides above background levels.

Trace concentrations of TCE were detected in MW-135, MW-137, andMW-152. The highest concentration detected, 3.5 parts per billion (ppb), is below thedrinking water standard of 5 ppb. The presence of TCE is in agreement with the TCE plumelocation maps prepared by the site. The absence of TCE in MW-100 confirms the eastwardextent of the Northeast Plume. This plume is within the eastern boundary of the waterpolicy area. In addition, residential wells sampled by the investigation team that wereoutside, but near the plume boundaries, were found to be free of contaminants. Theseresults indicate that the offsite groundwater contamination is currently within the waterpolicy area. Elevated uranium values were reported for a subset of the well water samples.These wells are scattered throughout the water policy area and do not occur in any patternassociated with the plumes or the groundwater flow system.**Surface Water
Surface water samples were collected from nine selected locations alongthe Little and Big Bayou Creeks, as well as at several Plant Outfalls where surface waterwas present. Since there were drought conditions during this sampling event, surface watersamples could not be collected from some of the desired Outfalls, such as K015 and K017,west and southwest of the Plant. A sample was collected from the Lagoon by the S and TLandfill and from a location in the North-South Diversion Ditch where enough standingwater was found. Analytical results for key parameters are shown in Table 2.

**Table 2. Measured Values of Activities and Concentrations of SixConstituentsin Surface Water Samples Taken at PGDP**
**Sample    Number**Pu-239/240    (pCi/L)**Pu-238    (pCi/L)**Am-241    (pCi/L)**Tc-99    (pCi/L)**U-238    (m**g/L)****TCE1    (m**g/L)**SW 01ND2ND<0.050.51.73**NDSW 02NDND<0.050.81.68NDSW 030.352ND0.1722637.1NDSW 04NDND<0. 25.31.160.4SW 05NDND<0.035.50.79NDSW 06ND**ND<0.03ND0.25NDSW 07NDND<0.041.40.83NDSW 08NDND<0.032.00.76NDSW 09NDND0.0541.90.96ND
1TCE    samples experienced elevated temperatures during shipping.2    ND = analyzed value at or below detection limit
**    Surface waters showed minimal levels ofcontaminants.**
Radioactivity analyses for surface waters showed relatively lowconcentrations for all isotopes, with the North-South Diversion Ditch sample showing thehighest levels of uranium and technetium-99 at 37 mg/L (12.5 pCi/L) and 26 pCi/L,respectively. Transuranic and thorium isotopes were either not detected or were present invery low concentrations, consistent with prior sampling results conducted by the site. Forcomparison purposes, one may note that the surface water results are all well below theDerived Concentration Guidelines (DCGs) established by DOE Order 5400.5. The DCGs can beused to evaluate the risk associated with the presence of radionuclides in surface water.The DCG for water is the concentration of a radionuclide that, under conditions of normalingestion of water for one year, would result in an effective dose equivalent of 100 mrem.As a condition of DOE Order 5400.5, DOE sites are prohibited from releasing processeffluents to surface waters in excess of the DCG guidelines.

With respect to other analytes, surface water samples were alsoanalyzed for volatile organic compounds and PCBs. Only trace amounts of volatile organiccompounds were detected, and none of these exceeded the Maximum Contaminant Levels (MCLs),which are considered the maximum acceptable levels for drinking water. For PCBs, only theNorth-South Diversion Ditch sample showed any positive results. The level detected(0.00035 mg/L) is also below the MCL for PCBs (0.0005 mg/L), although there have beenprevious PCB results in surface water that exceeded the MCL.**Soil and Sediments

**   Results for soil and sediment samples varied greatly, andsome analyses showed higher concentrations of contaminants than noted in the past.**
The results of the soil and sediment sampling are shown in Table 3. Atotal of eight soil/sediment locations were sampled for radionuclide and PCB contaminants.Seven of the samples were collected from outfalls and ditches adjacent to the site, andone was collected inside the site security fence near the Drum Mountain area. Themagnitude of the radionuclide results was generally in keeping with historical datareported by the site in the Outfall and Big Bayou locations. Sediments collected atOutfalls 11 and 15 and the North-South Diversion Ditch clearly exhibited radioactivitylevels above what would be expected from natural background or radioactive fallout and areof sufficient magnitude to warrant management as soil contamination areas under theDOE/Bechtel Jacobs radiological protection program. In fact, Outfall 15 exhibitedrelatively high levels of plutonium, thorium, and cesium, at 18.5, 14, and 44.6 pCi/grespectively, which are higher than has been reported for transuranic and fission productisotopes at similar locations in the past. The North-South Diversion Ditch containedplutonium at 52.3 pCi/g and thorium-230 at up to 808 pCi/g. Results for split samplesanalyzed by the site are consistent with these results. PCB contaminants were alsodetected in all of the soil/sediment samples at levels similar to past reporting with oneexception: Outfall 11 exhibited a PCB concentration of 84,121 mg/kg, which isapproximately five times the highest reported level from prior sampling. The possibilityof high variability and lack of homogeneity of contaminants in these media highlights theuncertainty associated with the process of limited soil sampling conducted annually byBechtel Jacobs. This uncertainty also demonstrates the need for conservativedecision-making and assumptions, including the use of historical data when drawingconclusions or conducting pathway analyses using data from sample results.****Table 3. MeasuredValues of Activities and Concentrations of Constituentsin Soil and Sediment Samples Taken at PGDP******
**Sample    Number**
**Pu-239/240    (pCi/g)**
**Pu-238    (pCi/g)**
**Np-237    (pCi/g)**
**Tc-99    (pCi/g)**
**Cs-137    (pCi/g)**
**Th-230    (pCi/g)**
**U-238    (pCi/g)**
**U (total)    (**m**g/g)****Am-241    (pCi/g)****PCBs    (**m**g/kg)**SS-10.009ND1<0.007NAV21.02NAV100232<0.384,1213SS-252.30.687.89NAV
NAVNAVNAVNAVNAV10,549SS-30.38ND<0.3NAV
NAVNAVNAVNAVNAV1,832SS-418.50.199<0.3NAV44.6NAV771600.88790SS-50.004ND<0.003NAVNDNAV<20.44<0.219SS-60.013
ND
<0.004
NAV0.35NAV<42.14<0.244SS-70.012ND<0.003NAV0.04NAV1.22.21<0.311SS-80.022ND<0.005NAV0.05NAV<31.43<0.323**1 ND = analyzed value at or below detection limit2 NAV = not available - analysis in progress3 Duplicate sample result reported at this location
**Conclusions**
Radiological and chemicalcontamination from PGDP industrial activities has been released into the ground, soil, andair around PGDP. These conditions have prompted DOE and regulatory organizations to take anumber of steps to protect public health. Because of the limited duration of exposure ofthe public to contamination and the mitigation measures taken, DOE operations at PGDP donot present a significant public health risk at this time. Nevertheless, significantimprovements in DOE’s protection of the public and the environment are needed.Increased funding and management emphasis on actual remediation activities are needed toaddress the sources of continuing contamination, to limit the degradation of contaminatedbuildings, and to control the continued spread of contamination pending cleanup. Exposurepathways need to be better analyzed to fully document the technical basis and thesite’s conclusion that no significant public exposures to radiation sources, such asfugitive air emissions, are occurring. Site management also needs to improve thecharacterization of groundwater in several areas, such as the extent of progression of theNorthwest Plume towards the Ohio River. Improvements in waste management practices areneeded to address storage of materials in DMSAs and the degrading containers of low-levelwaste. Additionally, DOE and Bechtel Jacobs need to supplement staff assignments andsubcontractor support to ensure that site personnel can effectively integrate, interpret,and communicate environmental information.**2.2 Radiation Protection and WorkerSafety

2.2.1Radiation Protection
The Bechtel Jacobs radiation protection program exists to protectindividuals from radiological exposures that could occur as a result of DOE activities atthe PGDP. These activities have changed during the 1990s with the transition of gaseousdiffusion operations to USEC. Currently, DOE’s responsibilities include environmentalrestoration and management of legacy contamination and the large quantity of radioactivewastes present at the site. Despite the mission change, the nature, extent, and magnitudeof contaminated facilities and uncharacterized materials at the site present uniquechallenges and highlights the importance and need for a comprehensive and robustradiological protection program.

**    During the early 1990s, radiological assessmentsidentified fundamental program weaknesses in the site’s ability to control potentialexposures to transuranics.**
During the early 1990s, radiological assessments, including the 1990DOE Tiger Team, identified fundamental program weaknesses in the site’s ability tocontrol potential exposures to transuranics and to conduct an effective contaminationsurvey program. In response, the site enhanced the quality and sensitivity of radiologicalsurvey equipment and increased the number of radiological control technician staffing fromjust a few to more than 50 to handle the increased survey workload caused by the discoveryof transuranics in the workplace. Also the use of personal protective equipment wasupgraded, and more emphasis was placed on posting and access control. Finally, thebioassay program was continued. When the radiological control program transitioned toUSEC, many of the resources went to USEC, creating a shortage of resources for DOEactivities.
To meet current 10 CFR 835 requirements for comprehensive assessment ofthe radiological control program, Bechtel Jacobs developed checklists of topical questionsfor 12 functional areas. The checklists are completed by the project health physicist, whodescribes how the site meets each of the requirements. Audit teams from the site QualityAssurance organization typically do not include health physics expertise. Radiologicalcontrol audits by the radiological control organization in 1995 and 1997 identifiedsimilar weaknesses (e.g., auditors with no audit training, auditors assessing their ownwork, and audits that did not assess the adequacy of procedures and programs). In general,audit findings were minimal and did not reflect an extensive scope of audit review or anexamination of the adequacy of corrective actions, although some recent improvement wasnoted.

OR conducted regulatory oversight reviews from July 1993 to March 1997.Radiological findings, the second most common deficiency after operations, were tracked toclosure. At the termination of the DOE regulatory oversight program in 1997, there were nooutstanding or unresolved radiological control issues at PGDP.

**    The lack of formality and rigor inradiological controls is exacerbated by an absence of DOE or Bechtel Jacobs oversight ofradiological work practices.**
The transition of gaseous diffusion activities to USEC has essentiallycreated two distinct radiological protection programs at PGDP. Tiger Team issuesattributable to the health physics activities associated with gaseous diffusion operationswere not reviewed since those activities are now under USEC and regulated by NRC. On theDOE-regulated side, Bechtel Jacobs has a functional radiological control program thatworkers consider superior to the program as it was in the early 1990s. While theinvestigation team found deficiencies similar to those raised by the 1990 Tiger Teamreport, their magnitude (in areas such as postings, procedures, air monitoring, andcontamination control) is less. Nevertheless, the number of deficiencies, combined withlegacy radiological hazards, widespread contamination, uncharacterized materials andwaste, and deteriorating contaminated facilities, is cause for concern. The lack offormality and rigor in radiological controls is exacerbated by an absence of DOE orBechtel Jacobs oversight of radiological work practices.
At the time of the investigation, worker training on transuraniccontamination and health effects had not been incorporated into current training. Otherradiation protection training weaknesses include a lack of effective oversight ofradiation protection training programs and a lack of assurance that individuals havereceived training before work is initiated in radiological areas. The current program wasalso found to be inconsistent with several requirements of Federal regulations onOccupational Radiation Protection (10 CFR 835) and Quality Assurance (10 CFR 830.120).Additional information on radiation protection training weaknesses can be found underWorker Safety and Health (Section 2.2.2).**Issues
**7. Incomplete radiological characterization of the workplace adverselyaffects the ability of the radiological control organization to identify hazards andinstitute controls as necessary to ensure consistent and appropriate radiologicalprotection for workers.**
**    The North-South Diversion Ditch inside the ControlledArea was not controlled as a transuranic area.**- There is a lack of knowledge as to the isotopic mix of radionuclides    present in various work areas. This information has never been obtained through    comprehensive characterization, nor is it available in technical basis documentation.    Radiological control technicians need this information to analyze the hazards and    establish proper radiological controls. Lacking this information, they generally have    established radiological control limits based upon the most restrictive radionuclides    thought to be present (e.g., Np-237). However, the North-South Diversion Ditch inside the    Controlled Area was not controlled as a transuranic area. This area has not been    adequately controlled because the radiological control technicians are not aware of    isotopic analysis information indicating the transuranic levels in the ditch. 
- The procedures for planning and implementing radiological controls in    the workplace presume knowledge of radiological control personnel about the isotopic mix    in work areas. 
**8. There is a lack of rigor, formality, and discipline in thedevelopment, maintenance, and implementation of the Bechtel Jacobs radiation protectionprogram.

**    Bechtel Jacobs RWPs lack information required byprocedure to control radiological work effectively.**- Bechtel Jacobs radiological work permits (RWPs) lack information    required by procedure to control radiological work effectively. They do not provide    required survey information or the anticipated radiological conditions to be expected,    such as the presence of transuranics. No radiological suspension limits are delineated to    stop work if conditions are encountered beyond the scope of the designated radiological    controls. Further, training requirements are not specified on RWPs. The investigation team    noted specific instances where personnel were unaware that the radiological conditions at    the work site were beyond what was appropriate for the scope of the general RWP in use. In    these cases, the radiological control supervisors, who were contacted by the team,    concurred that the activities should be stopped pending more complete planning and    preparation of more specific RWPs. 
****    In many cases, the monitored work activity was alreadycompleted before the final air sample activity was determined.**- Air sampler placement is not always consistent or adequate to sample the    air in the work area or representative of the air breathed by the worker. In addition,    analysis of air samples is not timely. Many air sample analyses are delayed from six to    ten days to allow radon progeny to decay. This site does not perform a more timely (e.g.,    four-hour decay count) screening count of air samples (even though Bechtel Jacobs’    procedures address how to screen samples) to evaluate whether appropriate radiological    controls are in place. In many cases, the monitored work activity was already completed    before the final air sample activity was determined. Also, site procedures do not identify    the conditions that require isotopic analysis of air samples. 
****    A survey of the interior of one work area inaccuratelyshowed radiation levels a factor of ten lower than those observed by the investigationteam.**
****   **The Building 410 ash receiver, held in placewith corroded C-Clamps.**
•   Linemanagement’s initial determination that no dosimetry or radiological worker trainingwas needed for construction personnel working at the cylinder yard project wasinappropriate. This Bechtel Jacobs decision was initially based on an April 1999 surveythat focused on the perimeter of the cylinder yard work area. Another survey, taken June3, 1999, to confirm the initial determination included only the perimeter area and not theinterior of the work area. On June 4, 1999, a survey of the interior of the work areainaccurately showed radiation levels a factor of ten lower than those observed by theinvestigation team on August 30, 1999. Contrary to Bechtel Jacobs’ initialassessment, independent dose rate measurements of the work area by the investigation team(see Figure 10) indicated that, based on an anticipated six-month job duration, workerdoses would likely exceed the 100 mrem threshold for such controls, and workers shouldhave been monitored and provided Radiation Worker I training. This finding led to ashutdown of work and implementation of radiation monitoring (thermoluminescent dosimeters)and radiological training for workers. One worker escort who was monitored recorded a doseof 24 mrem in 35 days on the job in May and June. A subsequent Bechtel Jacobs evaluationindicated that worker doses would probably not have exceeded 100 mrem. However, thisevaluation assumed an average work area dose rate that was two to three times lower thanthe dose rate that the investigation team observed in the work area.- The Bechtel Jacobs program for auditing and assessing the radiation    protection program was not effective in identifying programmatic deficiencies such as    those observed by the investigation team. 
- The project health physicist’s expectations for day-to-day    operations are not effectively communicated to the radiological control technicians.    Radiological control technicians believe that they have the authority to allow work in    certain areas (North-South Diversion Ditch) or decide not to take the air samples required    by ALARA reviews. These beliefs are contrary to the project health physicist’s    expectation for control of the work. 

**Figure 10. L Cylinder Yard SurveyReadings******    Bechtel Jacobs cannot adequately demonstrate thatthe unconditional release of equipment from the site is consistent with DOE requirements.**- Bechtel Jacobs cannot adequately demonstrate that the unconditional    release of equipment from the site, such as the release of fluorine cells, is consistent    with DOE requirements. Bechtel Jacobs does not have a technical basis for determining how    to meet the DOE requirements for unconditional release of equipment, including appropriate    criteria for determining when it is necessary to use more restrictive transuranic limits    versus uranium limits. While Bechtel Jacobs does have a procedure for unrestricted release    of equipment, they did not apply it during the process of releasing the fluorine cells.  
****    Contamination levels in excess of eight milliondisintegrations per minute per 100 cm2 were measured in outdoor contaminationareas.**- Outdoor contamination areas, particularly in the vicinity of Drum    Mountain, were not adequately posted and barricaded, even though contamination levels in    excess of eight million disintegrations per minute per 100 cm2 were measured in    these areas. Other onsite areas, primarily drainage ditches, were posted as contamination    areas in the absence of specific information on the radiological or chemical hazards being    present. Removable contamination levels were in excess of 10 CFR 835 Appendix D. Because    there is no contamination monitoring of individuals leaving the site, there is the    potential for contamination to be taken off site. Items, such as manhole covers, with    "fixed" contamination were not labeled to warn individuals of the radiological    hazards. Postings for some areas were either missing or not visible to personnel accessing    the area, and in other cases were not consistent with the work controls in the area. 

****   **Uranium materialsat product handling points in Building 340.**
•   During the 1980s and early 1990s (before Buildings 340, 410, and420 were controlled as contamination areas), the security force conducted daily patrols,periodic security drills, and joint exercises with the Paducah Police Department, theMcCracken County Sheriff’s Department, and Kentucky State Police in Building 340.There were no controls in place at that time to prevent exercise participants frompotentially becoming contaminated and unknowingly carrying the contamination off the site.****    Subcontractor personnel attributed the lack of postingsto inadequate funding.**- Bechtel Jacobs subcontractor personnel attributed the lack of postings    to inadequate funding for maintenance of the barricades and postings, and the assertion    that workers knew the areas where they were allowed to go. 
- Bechtel Jacobs procedures do not always contain specific instructions on    required radiological control activities, including entry control, posting and labeling,    radiation surveys, and radioactive contamination control and monitoring. 
- Numerous instances of a failure to follow procedures were noted,    including radiation safety training, generating and implementing RWPs, performing    contamination surveys, and implementing the pre-job ALARA review requirements. 
- Bechtel Jacobs allows individuals who lack the requisite training to    work for up to 40 hours in radiological areas and potentially receive occupational    exposure. This practice is not consistent with DOE radiation safety training requirements. 
- The practice of allowing individuals to work at different    company-managed sites using their home site’s dosimetry is inconsistent with the DOE    exposure reporting requirements. USEC employees performing work for DOE continue to wear    USEC-issued dosimeters. USEC dosimetry, which is accredited by the National Voluntary    Laboratory Accreditation Program (and accepted by NRC) and is not accredited under the DOE    system (DOE Laboratory Accreditation Program), is therefore used to monitor exposures from    DOE activities. This practice is not approved under the DOE Laboratory Accreditation    Program as required. 
- Procedural requirements for establishing airborne radioactivity areas    are inconsistent and conflicting. One section calls for use of the uranium Derived Air    Concentration if the isotopic mixture is unknown. This conflicts with another section that    specifies use of the most restrictive Derived Air Concentration for the radionuclides    known to be present when the percentage of radionuclides is unknown. In some cases,    following the uranium Derived Air Concentration guidance would result in airborne controls    that are much less restrictive than those required for the transuranic contaminants    present. 

***Description of PGDP 1990 Bioassay    Issue***

**Background.**The 1990 bioassay results of urine specimens taken from PGDP workers    and evaluated by an outside analytical laboratory were subsequently declared invalid by    the PGDP contractor (Martin Marietta Energy Systems, or MMES). This declaration continues    to be an issue of great concern to the union (Paper, Allied-Industrial, Chemical, and    Energy, or PACE), and there is a great deal of misunderstanding about the facts.
**Sequence of Events. On March 22, 1990, radioactive waste was spilled in    warehouse C-746-Q. Workers involved in the spill were sent to Fernald for whole body/lung    counts on June 8-14, 1990. On July 8-10, 1990, a first set of urine samples was sent to an    offsite analytical laboratory for evaluation; the results, received on August 7, 1990,    indicated that all samples tested positive for the presence of plutonium. On August 13,    1990, additional workers provided urine samples. On August 22, 1990, MMES questioned the    analytical laboratory on the validity of the results, and they also met with the    analytical laboratory and DOE on September 10, 1990. A second set of samples was taken    from workers on September 26, 1990; the samples were "split" and provided to the    Oak Ridge National Laboratory (ORNL) and the original analytical laboratory for    evaluation. During this period, MMES conducted two audits of the analytical laboratory    (September 12, 1990, and October 18, 1990). On January 11, 1991, MMES officially declared    the original analytical laboratory results invalid. MMES provided a briefing to workers    and to PACE on the urinalysis results on March 6, 1991.

**Actions Taken by Oversight Investigation Team.**Records associated with the    bioassay process were reviewed in the USEC Building 710 vault. Additional records from the    Building C-100 vault, which included whole count data, were also examined. The    investigation team attempted to interpret the raw data and also reviewed supporting    documents.
**Results. The investigation team’s review of information indicated the    following:- The results for all 23 original bioassay sample results were reported as positive for        the presence of plutonium. The samples included 20 from workers, 2 unexposed control        samples, and a blank water sample. Blind samples "spiked" by Martin Marietta        Energy Systems with plutonium were reported high by a factor of 2.5.
- The plutonium blind spike samples sent to the analytical laboratory by MMES were 1,000        times too high due to a misunderstanding between MMES  and ORNL of typical spike        levels. MMES  interpreted the ORNL recommendations as disintegrations per        minute/milliliter rather than disintegrations per minute/liter. Since the spiked samples        were abnormally radioactive (hot), compared to the samples typically encountered by the        analytical laboratory, these samples could have contaminated the laboratory equipment. If        this occurred, it would account for the reported results.
- The initial uranium results were not consistent with what would be expected for actual        exposures to uranium contaminated with transuranic elements.
- MMES audits of the analytical laboratory revealed problems in procedural compliance,        quality assurance and quality control, failure to meet contractual requirements for        Minimum Detectable Activities, and failure to subtract natural background radiation before        reporting results.
- All results of the whole body/lung counts conducted by Fernald were negative for the        presence of uranium-235, uranium-238, plutonium-239, neptunium-237, and americium-241.
- All results of the resampled urine samples split between the analytical laboratory and        ORNL were also negative for the presence of plutonium-238, plutonium-239, and        americium-241.
**Assessment. Based upon the investigation team’s review of the available    information, there is no evidence to invalidate the MMES basic conclusions that the    original sample results were false and that worker intakes did not occur from the original    spill. The sampling and analysis approach used by the contractor, which bases a    determination of intake on the predominance of the sample trial results (i.e., if two out    of three trials are negative, the results are judged to be negative), is consistent with    the Internal Dosimetry Implementation Guide and Internal Dosimetry Technical Standards as    issued by DOE Headquarters. A determination of intakes is rarely confirmed based on the    results of a single sample. As a general practice, follow-up or confirmatory samples are    always prescribed. Also, due to the slow excretion of transuranic elements from the body,    samples taken years after the initiating event would detect the presence of transuranic    elements if significant intakes were involved.
**Conclusions**
Records indicate that the external doses to employees from the types ofradiation present at PGDP are very low, and there have been no recent significant intakesof radioactive material. However, the multiple deficiencies that were identified inradiological protection are symptomatic of a site that has had to cope with the samelegacy hazards for many years and that is no longer in an operational mode. The site hasincreasingly relied on the workers’ knowledge of and sensitivity to radiologicalhazards. The site radiation protection program exhibits a level of informality, ratherthan a disciplined and rigorous application of controls such as detailed radiation workpermits, procedures, postings, barriers, and air monitoring. An event in which multiplepersonnel were contaminated with technetium-99, the presence of contamination with legacymaterials in shutdown hazardous facilities, and the site’s failure to monitor andtrain all workers in radiation protection are indications of program weaknesses. While some of these deficiencies are not significant, collectively they are ofconcern because of the remaining uncharacterized hazards, the unique and challenging risksassociated with future hazardous material cleanup, and the move toward almost totalreliance on subcontractors—some of whom lack the historical knowledge of siteradiological hazards, including transuranics, and the applicable precautions and controls.
In conclusion, it is important that DOE and Bechtel Jacobs recognizethat the cumulative deficiencies, in what could be a viable and effective radiologicalprotection program, represent a weakness that warrants management attention. A level ofdiscipline, rigor, and formality needs to be established in the process to protect workerhealth and safety during hazardous material characterization and onsite cleanupactivities. DOE and Bechtel Jacobs also need to accept increased responsibility for theoversight of subcontractor radiological safety and performance, including holding themaccountable for adhering to applicable DOE requirements.
**2.2.2 Worker Safety and Health**
The 1990 DOE Tiger Team identified significant deficiencies in workersafety programs and practices at PGDP. Corrective actions were taken and performanceimproved. Since that time, DOE contractors at PGDP and the nature of work performed bythese contractors have changed. In 1993, USEC assumed full responsibility for managingenrichment operations. In 1997, regulatory oversight of enrichment operations wastransferred from DOE to NRC. The nature of work by DOE contractors since that transitionhas focused on maintenance of UF6 cylinders,maintenance and characterization of packaged waste, and assessment of environmentalimpacts. Completion of the cleanup mission at PGDP will require a significant increase inhazardous activities, such as removing buried waste and inspecting the contents ofthousands of drums of radioactive waste. This work presents risks because it involveshandling material containing radioactive and chemical carcinogens, much of which has notbeen fully characterized. There have already been several occurrences of drumpressurization due to improper drum handling practices, one of which resulted in thecontamination of workers.
**    Most occupational physical hazards andworker exposure hazards at PGDP have been adequately identified and characterized.**
Most occupational physical hazards (e.g., electrical hazards) andworker exposure hazards (e.g., to chemicals) at PGDP have been adequately identified andcharacterized. Bechtel Jacobs has developed a comprehensive set of safety and healthprocedures for identifying, evaluating, and controlling occupational hazards. A review ofselected work activities indicated that most physical hazards are adequately identified,and job hazard analyses and/or activity hazard analyses are performed in accordance withprocedures. However, some safety and health procedures are not being followed, and somehazards are not sufficiently analyzed, particularly for work performed by subcontractors.The type, quantity, enrichment, and configuration of fissionable materials in DMSAs havenot been fully characterized, and the risk of a criticality accident occurring in severalof these DMSAs is unknown.
Limited safety and health resources have resulted in overreliance onpersonal protective equipment in lieu of performing hazard analyses and implementingengineering controls. Assessment of employee exposures relies heavily on screeningmechanisms (e.g., chemical detector tubes) and professional judgment. Record keeping forair and noise sampling data is weak. Locating historical sampling data is difficult, andreconstructing personnel exposures is not always possible, particularly forsubcontractors. Access to worker exposure and job hazard information by medical personnelis a longstanding weakness that has never been fully resolved.

********   **DOE Material Storage Area**
Workers are generallyinvolved in the work planning process, and the workers and line managers who wereinterviewed expressed satisfaction with the level of management attention to workersafety. The monthly safety committee meeting is well attended by DOE, Bechtel Jacobsmanagement and workers, and subcontractors. Injury and illness rates at the PGDP are lowerthan at many DOE sites, and lower than the other two DOE sites managed by Bechtel Jacobs.Notwithstanding these positive attributes, many precursor conditions are developing that,if not addressed, will lead to decreased safety performance and an increased risk toworkers.
**Issues**
**9. Criticality safety deficiencies in DMSAs have not been resolvedby DOE in a timely manner, posing an unnecessary hazard to workers in surrounding areas.** Lockheed Martin Utility Services documented these deficiencies in an occurrencereport to the DOE identifying the issue as a potential unreviewed safety question onJanuary 15, 1997 (ORO-LMES-PGDPENVRES-1997-001). This issue was subsequently upgraded toan unreviewed safety question on July 21, 1998, based on the results of non-destructiveanalysis performed on an axial compressor in DMSA 31 inside the C-333 process building atPGDP. The analysis indicated that the compressor contains less than 1,737 gramsuranium-235 at an assay of 1.157 weight percent. No nuclear criticality safety analysisdocumentation had been prepared for this compressor as required by DOE orders, Work Smartstandards, and American National Standards Institute standards when the mass of uraniumexceeds 700 grams. Corrective actions have not been taken in the higher-risk DMSAs, andcurrent compensatory measures are not adequate.

***DOE Material Storage Area Weaknesses***

**Background. Uncharacterized radiological and chemical    equipment, materials, and waste in DMSAs (as shown in the picture) continue to present    unnecessary and avoidable risk to workers and the environment.** In 1996, DOE accepted    responsibility for large amounts of legacy materials (e.g., uncharacterized scrap,    equipment, drums, and other wastes) that were stored in the leased facilities so that USEC    could obtain a certificate of compliance from the NRC. These materials are currently    stored in 148 DMSAs located across the site, including "islands" within in the    USEC operating facilities. Eleven DMSAs have been identified as high-priority areas based    on nuclear criticality safety concerns. These 11 DMSAs include equipment that could    contain large deposits and fissile materials with enrichments as high as 93 percent. - Continuing Management Weaknesses   - Responsibilities and accountabilities for DMSAs have not been clearly            established.
  - Although problems and corrective actions were identified            and submitted to the Paducah Site Office in 1997, an acceptable plan and schedule for            disposition of the materials have not been developed.
  - DOE has not provided the funds to disposition the            materials.
  - Almost no actions to disposition the material have            been accomplished.- **Criticality Concerns**- The risk of an inadvertent criticality is not known.
- The fissionable material content has not been quantified.          Acceptable safeguards to preclude reconfiguration of fissionable materials have not been          established.
- Protection from introduction of moderator (e.g.,          sprinklers, pipe ruptures, fire hose locations, and flooding) has not been established.
- Double-contingency protection against criticality          has not been established.- **Environmental Concerns**- Only limited action has been taken to inventory          and characterize the hazardous materials that are known to be present.
- DMSAs are not managed in accordance with RCRA waste          storage requirements.
- On at least two occasions, USEC has introduced new          materials without DOE’s prior knowledge or authorization.

**    In several of the DMSAs, the risk of a criticality accident is notknown.**- In several of the DMSAs, the risk of a criticality accident is not    known. However, non-destructive assay data obtained from some, but not all, of the    equipment that originated at Portsmouth or Oak Ridge indicate that there is insufficient    localized fissile mass in the equipment surveyed to make a criticality accident possible. 
- The type, quantity, enrichment, and configuration of fissionable    materials in these areas have not been fully characterized. 
- Safeguards are not sufficient to preclude unauthorized movement of    material in DMSAs. 
- Procedures are not in place nor have workers been trained to properly    respond in the event of inadvertent addition of moderator due to activation of sprinkler    systems or flooding. There is a remote possibility that such an event could initiate a    criticality accident. 
- The DMSAs do not comply with DOE Order 420.1, Section 4.3 and American    Nuclear Standards Institute/American Nuclear Society Criticality Safety Standards that    require that no single abnormal event can cause a criticality accident. Such an event    cannot be precluded since the DMSA material has not been characterized. 
- Lockheed Martin Utility Services documented these deficiencies in an    occurrence report identifying the issue as a potential unreviewed safety question on    January 15, 1997 (ORO-LMES-PGDPENVRES-1997-001); however, corrective actions have not been    taken in the higher risk DMSAs and current compensatory measures are not adequate. 
- Agreements between DOE and USEC to characterize and correct conditions    within the DMSAs have not been adhered to, and DOE has not identified or provided    alternative funding. The only planned DMSA characterization program was initiated to    support seismic upgrades and only addresses a small fraction of the equipment that is    suspected of containing fissile material. There is no funding for correcting the    deficiencies in all the DMSAs and eliminating the criticality safety hazard. 
**10. Safety and health procedures are not consistently applied andfollowed, and in some cases, hazards are not adequately addressed by those procedures.**- Of the occurrence reports submitted to DOE by Bechtel Jacobs since April    1998, a number were attributed to either inadequate procedures or a failure to follow    procedures. For example:    - On July 10, 1998, a subcontractor did not follow a section of an RWP,        resulting in a failure to obtain a required baseline bioassay sample. 
  - On June 30, 1998, a low-pressure sanitary water line was inadvertently        penetrated as a result of an inadequate procedure. 
  - On September 3, 1998, two waste containers were found to have been moved        in violation of procedures regarding weight limits for a forklift. 
  - On December 15, 1998, a pressurized container was discovered during        sampling activities. Evaluation of such "neutralized media" had not been        included in the Bechtel Jacobs "Scrap Metal Acceptance Criteria and Waste Acceptance        Criteria." 
  - On May 28, 1999, a small bottle with unknown contents was discovered in        a sediment sample. The procedure for this activity was judged to be inadequate and a        contributing cause to the occurrence, since the procedure did not address what to do if        unexpected items are encountered. 
  - On August 25, 1999, a subcontractor violated an Excavation/Penetration        Permit by failing to notify the underground utility locator service for the Commonwealth        of Kentucky as required by the permit. Consequently, they nearly severed a        telecommunications line. ****    Laboratory personnel did not adhere to the laboratorystandard operating procedures or follow guidelines for safe handling of methylenechloride.- On May 27, 1999, it was determined that    laboratory personnel working in a mobile field extraction laboratory had been exposed to    methylene chloride above the 15-minute Short-Term Exposure Limit defined by OSHA    Regulation 1910.1052. Both root and direct causes of this event were that laboratory    personnel did not adhere to the laboratory standard operating procedures or follow    guidelines for safe handling of methylene chloride as described in the Material Safety    Data Sheet. 
- The investigation team observed that some    safety and health procedures are not consistently followed. Sections of the sitewide    procedure and the subcontractor’s Health and Safety Plan for confined space entry    were not followed at the L Cylinder Yard. Confined spaces were not evaluated, were not    posted in accordance with procedures, and did not have required permits. Sections of    Bechtel Jacobs procedures on biological monitoring for industrial chemicals, and workplace    air sampling were not followed. 
- At the L Cylinder Yard Project, occupational    noise is not discussed in the subcontractor’s Health and Safety Plan, nor are    administrative controls (e.g., hearing protection and hearing conservation program    requirements) described in the subcontractor’s procedure on noise. Exposure to    occupational noise is a safety concern for heavy equipment operators at the L Cylinder    Yard. Furthermore, the subcontractor’s lack of a documented basis to support the    prescribed hearing protection, the absence of sound surveys or noise dosimetry, and the    lack of an evaluation to determine whether workers should be enrolled in a hearing    conservation program are not in compliance with either OSHA regulations or the Bechtel    Jacobs procedure on occupational noise exposure.  
- Some subcontractor safety and health procedures    have not kept current with changes in OSHA regulations. At the L Cylinder Yard, Bechtel    Jacobs approved a subcontractor procedure for confined space entry that differed from the    sitewide confined space procedure, resulting in two conflicting procedures being applied.    Further, the subcontractor procedure did not reflect current OSHA requirements for    confined spaces. 
- Bechtel Jacobs does not have a clearly defined    or expressed policy on procedure adherence. The Bechtel Jacobs procedure on "Use of    Procedures" was deleted and replaced by a procedure on the "Procedure Document    Process" that is less stringent in requiring the use of procedures. Bechtel    Jacobs’ policy statements do not adequately address the importance of following    procedures when performing work. 
**11. Bechtel Jacobs has not assured thatsubcontracted medical personnel are sufficiently involved in the identification,evaluation, and integration of workplace hazards to ensure effective worker medicalprograms.**
****  **Animal material in Building 340poses potential health effects to workers.**
•   Several Office of Environment, Safety and Health reviews and assessmentsof the PGDP occupational medical program performed during the 1990s identified the needfor site medical personnel to be more involved in the identification, evaluation, andintegration of workplace hazards to ensure effective worker medical surveillance programs.This deficiency has yet to be resolved.
- The Bechtel Jacobs Work Authorization for ES&H    services to be provided by USEC is brief and focuses on the frequency and cost of medical    services, rather than on the scope and quality of services. 
- The required interfaces between industrial hygiene    and safety, health physics, emergency planning, and subcontractor medical programs are not    well documented, and they are not feasible for the USEC Medical Director to accomplish. 
- The site’s Work Smart Standards have not    incorporated DOE Order 440.1A and the subsequent DOE requirements for contractor medical    programs. **    **Neither Bechtel Jacobs nor DOE has performed anassessment of subcontractor medical programs.**- Neither Bechtel Jacobs nor DOE has performed an assessment    of subcontractor medical programs. 
**12. Bechtel Jacobs training programs do notensure that all workers are knowledgeable of hazards and protection requirements,including those associated with transuranic contamination.**- The Bechtel Jacobs radiation safety training    program does not include a process to assure that individuals receive the required    training before working in controlled or radiological areas. Although required by    procedure, mandatory training is not included in RWPs. The site does not maintain training    records for individuals working at the site who are based at other Bechtel Jacobs    locations. These individuals are escorted but are not given site-specific training.****    None of the current Bechtel Jacobs radiation safetytraining modules adequately address the presence of transuranic contaminants at the site.- None of the current Bechtel Jacobs    radiation safety training modules adequately address the presence of transuranic    contaminants at the site. Training on transuranics was provided once in 1992, and although    DOE and Bechtel Jacobs personnel believed that such training was being conducted, in fact    the 1992 transuranic-based training was not incorporated into the ongoing radiation worker    training program. 
- Training for Bechtel Jacobs radiological control    technicians does not include monitoring for transuranics, the release criteria to be used,    or the use of isotopic analysis information to determine the need for controls. 
- Bechtel Jacobs personnel and subcontractors    trained to the "Site Access Orientation" level are allowed access to    radiological and controlled areas for a period of up to 40 hours per year. This level of    training does not meet all 10 CFR 835 training requirements. 
- Some workers have not completed required ES&H    training. Several subcontractor personnel at the L Cylinder Yard had not met training    requirements commensurate with the hazards to which they are exposed (e.g., confined    spaces, hazard communication, and noise). 
- Although Bechtel Jacobs provides a measure of    oversight of subcontractor training programs through quality assurance audits,    surveillances, and readiness reviews, this oversight is not consistently applied and is    performed at the discretion of the Bechtel Jacobs project manager. There is no threshold    or guidance for performing surveillances based on risk or previously identified ES&H    deficiencies. At the L Cylinder Yard, for example, no surveillances have been performed to    date, although there are a number of hazards, and training deficiencies were previously    identified in the project readiness review.
**Conclusions**
Most occupational and worker exposure hazards have been identified andanalyzed, and they are adequately controlled, although criticality safety deficienciespose an unknown degree of risk and hazard to workers. The failure to address potentialcriticality safety deficiencies that have been apparent for more than 20 months indicatesthat DOE management has not placed sufficient priority on this important area of workersafety. Procedures address most occupational hazards; however, improvements are needed inestablishing, maintaining, and following procedures, particularly on the part ofsubcontractors. Pre-job mentoring and review of subcontractor programs by Bechtel Jacobsare evident. However, the rigors of future waste remediation work and the increasingnumbers of subcontractors will require more demand for oversight of subcontractors. Thelack of training for workers and radiation control technicians regarding the presence oftransuranics has exacerbated workers’ fear of exposure and contributed to the currentmistrust between some workers and line management. The need for medical personnel to bemore involved in the identification, evaluation, and integration of workplace hazards waspreviously identified at the site. Ensuring an effective medical surveillance program isespecially important at PGDP in view of the health concerns that have been raised.Overall, increased management attention is needed, particularly in criticality safety riskanalysis, oversight of worker training, occupational medicine, and procedure adherence.
**2.3 LineOversight**
DOE established the Paducah Site Office in1989 to provide program direction and day-to-day oversight. In the early 1990s, DOE tooksteps to strengthen the oversight of contractor activities at PGDP. The need for moreeffective oversight was based on emerging environmental and worker safety issues.Technetium-99 had been discovered in offsite wells in 1988, and numerous sources ofcontamination at PGDP were being investigated as potential contributors to a plume ofcontaminated groundwater. A 1990 DOE Tiger Team assessment identified a number of safetyproblems at the site, problems with contractor activities, and a failure to provide cleardirection to the management and operating contractor. A 1997 Type B accident investigationby OR concluded that "DOE does not adequately perform oversight." In addition, a1992 OR investigation of a former worker’s concern about radiological controlpractices at PGDP found evidence that workers were intimidated and afraid to raise safetyconcerns.
**    The Site Safety Representative Program was completedin 1997 and its two staff members were reassigned to other duties.**
Following the Tiger Team assessment, the recently established PaducahSite Office staff was increased from five to 12 staff members to provide more effectiveline oversight of contractor activities. In 1993, OR assigned two Site SafetyRepresentatives to provide DOE oversight of enrichment activities while line oversightresponsibility was being transferred to NRC. The two individuals were selected from thePaducah Site Office staff and reported directly to OR for this assignment. The Site SafetyRepresentative Program was completed in 1997 and the two staff members were reassigned toother duties. With the final transition to NRC regulation of the enrichment facilities in1997, the scope of DOE activities at PGDP decreased significantly to involving only wastemanagement, environmental assessment, and remediation. Paducah Site Office activities havefocused primarily on project management. In April 1998, DOE transitioned from a managementand operations contract with Lockheed Martin Energy Services to a management andintegration contract with Bechtel Jacobs. The work of the current DOE contractors isfocused on maintenance of UF6 cylinders, maintenance and characterization of packaged waste,assessment of environmental impacts, environmental monitoring, containment of thegroundwater plume, and control of surface water runoff.
The current level and effectiveness of line management oversight ofES&H and assurance of compliance with DOE requirements are a matter of concern.Programmatic deficiencies identified through the 1990s either continue or have recurred.Written or verbal direction provided by DOE, primarily OR, regarding implementation of themanagement and integration contract has significantly reduced the level of oversightconducted by both the Paducah Site Office and Bechtel Jacobs. Consequently, linemanagement has not identified and corrected many of the programmatic problems identifiedelsewhere in this report.**Issues****13. DOE has not conducted effectiveoversight of ES&H or ensured that Bechtel Jacobs and its subcontractors effectivelyimplement all DOE and regulatory requirements.****- The improvements in oversight of contractor activities during the early    1990s are no longer apparent. There has been no formal oversight program and few oversight    activities since the Site Safety Representative Program was completed in 1997.  
- OR has provided little written direction to the Paducah Site Office for    oversight of the management and integration contractor, Bechtel Jacobs. Written guidance    stated that "the DOE role will center on establishing policies, standards, baselines,    and objectives and measuring performance rather than focusing on day-to-day oversight and    control." Consequently "day-to-day oversight" has received little    attention.  
- Without an ongoing program of surveillance and oversight, DOE was unable    to provide timely information regarding the status of hazards to workers and the public    when allegations regarding worker safety and health were raised in the lawsuit against    former operating contractors for PGDP. 

**    Neither OR nor the Paducah Site Office has providedsufficient direction to Bechtel Jacobs to assure adequate oversight of subcontractors.**- Neither OR nor the Paducah Site Office has    provided sufficient direction to Bechtel Jacobs to assure adequate oversight of    subcontractors, even though subcontractors are performing an increasing amount of work.    Written guidance for administration of the Bechtel Jacobs contract was provided to all OR    employees in a memorandum from the OR Manager, dated January 29, 1998, which stated that    "the DOE role will center on establishing policies, standards, baselines, and    objectives and measuring performance rather than focusing on day-to-day oversight and    control." 
- The investigation team observed subcontractor ES&H performance that    did not meet DOE requirements. 
- Performance deficiencies were particularly evident in radiation    protection, an area where the Paducah Site Office lacks sufficient expertise to provide    effective oversight. The investigation team observed a number of deficiencies in this area    that had not been previously identified by the Site Office. 
- The Paducah Site Office does not have a formal program or process,    including definition of roles and responsibilities, for assessment of Bechtel Jacobs’    performance at the activity level, and has performed little assessment of Bechtel    Jacobs’ activities or conditions. 
- OR has not maintained a DOE Facility Representative at PGDP since the    regulation of enrichment was transferred to NRC. 
- There is little oversight of training programs by DOE, and there are no    mechanisms to ensure that the training that is provided is adequate. 
- The Paducah Site Office did not identify the appropriate DOE    requirements for unrestricted release of potentially contaminated property before    approving the sale of fluorine cells. 

**14. Bechtel Jacobs has not conducted fully effective oversight ofES&H performance or ensured that its subcontractors effectively implement all DOE andregulatory requirements and are held accountable.**
- Numerous weaknesses were identified in procedure adherence, safe work    practices, occupational medicine, and worker training. These weaknesses resulted in a    stop-work action for one subcontractor during the investigation period.  
- Bechtel Jacobs’ subcontractors do not consistently follow safety    and health procedures. 
- Subcontractors are screened by Bechtel Jacobs before starting work, but    these screenings are not adequate to ensure that the subcontractors have working programs    in place that meet DOE requirements for industrial safety, industrial hygiene, and medical    surveillance. 
- Some recent subcontractor work activities have resulted in unsafe work    practices. 
- Although Bechtel Jacobs provides a measure of oversight of subcontractor    training programs through quality assurance audits, surveillances, and readiness reviews,    the oversight is not consistently applied and is performed only at the discretion of the    Bechtel Jacobs project manager. 
**    Planned reductions in staff will further reduceBechtel Jacobs’ technical capability to conduct oversight and surveillance ofsubcontractor activities.**- Planned reductions in staff within Bechtel    Jacobs will further reduce Bechtel Jacobs’ technical capability to conduct oversight    and surveillance of subcontractor activities. Planned staffing changes include a reduction    in Safety Advocates from four (one Safety Advocate and three Safety Engineers who perform    the Safety Advocate function) to one and elimination of the training coordinator position.    In addition, there are significant shortages in key safety disciplines, such as industrial    hygiene.
**Conclusions**
DOE and Bechtel Jacobs line management practices and processes have notassured compliance with ES&H requirements*.* Previously-identified problems thathad been corrected after the Tiger Team assessment have resurfaced. With the shift to amanagement and integration contract, expanding reliance on subcontractors for the cleanupand waste management activities will require significantly more surveillance and oversightby both Bechtel Jacobs and DOE personnel who are knowledgeable of DOE requirements. Insome cases, these requirements may be more stringent than the subcontractors’normally accepted practices. It has been demonstrated throughout the DOE complex that moreactive oversight and surveillance at the activity level is necessary to raise thethreshold of acceptability for safe work practices and environmental conditions. If DOE issuccessful in obtaining funding to accelerate cleanup activities at PGDP, significantlymore effort must be expended on surveillance and oversight to achieve and maintain therequisite standards for protecting the environment, the public, and especially theworkers.
**Appendix AIssues for Corrective Action and Follow-up**
Line management is responsible forcorrecting deficiencies and addressing weaknesses identified in Office of Oversightreviews. Following each review, line management prepares a corrective action plan. TheOffice of Oversight follows up on significant issues as part of a multifaceted programthat involves follow-up reviews, site profile updates, and tracking of individual issues.

This appendix summarizes the significant issuesidentified in this report of the Phase I investigation of PGDP. The issues identified in Table A-1 will be formally tracked in accordance with the DOE plandeveloped in response to DNFSB Recommendation 98-1, which addressed follow-up ofindependent oversight findings. OR, the Paducah Site Office, and Bechtel Jacobs need tospecifically address these issues in the corrective action plan.

During an investigation, the Office of Oversightteam may identify isolated weaknesses and/or minor deficiencies in otherwise effectiveprograms. Although the site needs to correct such weaknesses and deficiencies, the Officeof Oversight does not include every identified weakness in the formal tracking system.However, all weaknesses and deficiencies are considered as part of the Office of Oversightfollow-up program when evaluating performance and planning future Oversight evaluation andfollow-up activities.

**Table A-1. IssuesIdentified in the Phase I Investigation at PGDP**
**IDENTIFIER**ISSUE STATEMENTPGDP-INV-99-01There has been limited progress in    remediating and characterizing environmental contamination, low-level wastes, and stored    hazardous materials that were produced by past industrial activities and major cleanup    milestones under the Federal Facility Agreement are jeopardized by funding constraints.PGDP-INV-99-02There are continuing weaknesses in the    radiation protection management of known environmental contamination areas by both Bechtel    Jacobs and DOE.PGDP-INV-99-03Radiological exposure pathways for DOE    operations have not been fully assessed or documented.PGDP-INV-99-04Groundwater contamination has not been    adequately characterized in some areas.PGDP-INV-99-05Unclear assignment of responsibilities    and weaknesses in the integration and interpretation of environmental information have    adversely impacted the understanding of environmental conditions.PGDP-INV-99-06Information to the public has sometimes    been delayed and is in forms not clearly understood by the general public and other    stakeholder groups, contributing to a perception that DOE and the contractor are    withholding information from the public.PGDP-INV-99-07Incomplete radiological    characterization of the workplace adversely affects the ability of the radiological    control organization to identify hazards and institute controls as necessary to ensure    consistent and appropriate radiological protection for workers.PGDP-INV-99-08There is a lack of rigor, formality,    and discipline in the development, maintenance, and implementation of the Bechtel Jacobs    radiation protection program.PGDP-INV-99-09Criticality safety deficiencies in    DMSAs have not been resolved by DOE in a timely manner, posing an unnecessary hazard to    workers in surrounding areas.PGDP-INV-99-10Safety and health procedures are not    consistently applied and followed, and in some cases, hazards are not adequately addressed    by those procedures.PGDP-INV-99-11Bechtel Jacobs has not assured that subcontracted medical    personnel are sufficiently involved in the identification, evaluation, and integration of    workplace hazards to ensure effective worker medical programs.PGDP-INV-99-12Bechtel Jacobs training programs do not    ensure that all workers are knowledgeable of hazards and protection requirements,    including those associated with transuranic contamination.PGDP-INV-99-13DOE has not conducted effective    oversight of ES&H or ensured that Bechtel Jacobs and its subcontractors effectively    implement all DOE and regulatory requirements.PGDP-INV-99-14Bechtel Jacobs has not conducted fully    effective oversight of ES&H performance or ensured that its subcontractors effectively    implement all DOE and regulatory requirements and are held accountable.
**Appendix BCharacterization of Selected Solid Waste Management Units**
Table B-1 provides a characterization of selectedSWMUs at PGDP as they were understood in the early 1990s. Information in the table wasobtained from "Results of the Site Investigation, Phase II at the Paducah GaseousDiffusion Plant," KY/ER-4, Volume 2 of 6, April 1992. SWMUs presented in the tableare those units for which quantitative sampling information on either radioactive orhazardous materials was provided in the reference document.
**Number & Location**
**Areal Extent**
**Period of Operation**
**Sampling Data**
**Comments**SWMU 1: C-747C Oil Landfarm96,300 ft21975-1979Phase I:    TCE – 190 �g/kg    Aroclor 1242 and 1254 – 1,400 �g/kg    Semivolatile organics – 1,800 �g/kg    PCBs – range from 25-10,000 ppm    Tc-99 – 2.36J � 8.7    pCi/g    U-234, U-238 – 15.7J � 1.28 pCi/gAt least 5,000 gallons of waste oil were applied    to the landfarm.
Periodically, lime and fertilizer were applied to the area, and the    surface was replowed.SWMU 2: C-749 Uranium Burial Ground32,000 ft21951-1977270 tons of uranium    59,000 gallons of oils    450 gallons of TCE
Phase I well data near Burial Ground:    Tc-99 – 747J pCi/g    U-234 – 1,860J pCi/g    U-238 – 3,333J pCi/gBurial ground included pyrophoric forms of U    metal.
Only 4 of 15 (30-gallon) drums with TCE were recovered.SWMU 3: C-404 Low-Level Waste Radioactive Waste    Burial Ground53,200 ft21951-1986Phase I:    Tc-99 – 2,175 pCi/g    TCE – 210 �g/LMost Tc-99 was released from the C-400 facility to    the C-404 facility.
The upper tier of waste includes 450 drums with Cd, Se, and Pb.SWMU 5: C-746F Classified Burial Yard168,000 ft21965 – presentPhase I:    Benzene – 980J �g/kg    TCE – 9 �g/kgaSWMU 7: C-747A Burial Ground7 areas ranging from 1,500 ft2 to    19,250 ft2 , with an overall total of 53,650 ft21957-1979Phase I:    TCE – 6,100 and 5,300 �g/L    Tc-99 – 3,195 and 2,830 pCi/L
Phase I Deep Borings:    Tc-99 – 72.7 pCi/g    Aroclor 1254 – 730 �g/kg    Aroclor 1260 – 26 �g/kgNo record of TCE disposal, although Well 66 has    the highest concentrations of any onsite or offsite wells.
Burial ground contains    uranium-contaminated material from C-410 Feed Plant and uranium powder scrap from C-340    facility.SWMU 9: C-746S Residential Landfill6 cells with occupying 700,000 ft21982 – presentPhase I:    TCE – 21 �g/L    Tc-99 – 83 pCi/LLandfill is a potential offsite contamination    source.SWMU 11: C-400 Trichloroethene Leak Site4,200 ft2Storm sewer received TCE from early 1950s to June    1986 from C-400 Cleaning Building1986 samples from excavation:    TCE – 7,000 mg/kg
Phase I:    TCE – 33 �g/l    Tc-99 – 177J pCi/g

Phase I Deep Boring:    TCE – 220 �g/kgIn 1986, 310 ft3 of contaminated soil    was removed containing 150 pounds of TCE.
Some contaminated soil was left in and around    C-400 Cleaning Building for structural reasons.

Deep boring identified detectable concentrations to the base of the Regional Gravel    Aquifer.
1 Information obtained from "Results of the Site Investigation, PhaseII at the Paducah Gaseous Diffusion Plant," KY/ER-4, Volume 2 of 6, April 1992. SWMUspresented in the table are those for which quantitative sampling information on eitherradioactive or hazardous materials was provided in the reference document. The symbol"J" indicates an estimated, measured value.

**Number & Location**
**Areal Extent**
**Period of Operation**
**Sampling Data**
**Comments**SWMU 17: 
C-616E Sludge LagoonImpoundment of 215,000 ft21979 – presentPhase I:    Tc-99 – 4.9 pCi/L
Phase I Deep Borings:    TCE, chloroform, and chloromethane – 1.0J to 34 �g/L    Gross beta, Tc-99, U-238, Pu-239 – 0.05 � 0.05 to 16 � 1.7 pCi/gThe lagoon is located north of Plant security    fence.
The lagoon sludge also contains chromium.SWMU 18: C-616F Full Flow LagoonN/A1977 – presentPhase I:    TCE – 22 �g/L    Tc-99 – 76 pCi/L
Phase I Deep Borings:    Toluene, TCE, chloroform, and chloromethane – 1.0J to 34 �g/L    Gross beta, Tc-99, U-238, Pu-239 – 0.05 � 0.05 to 16 � 1.7 pCi/gThe lagoon is located north of the Plant security    fence.
The lagoon receives much of the Tc-99 discharged from the Plant.

The lagoon overflows to Big Bayou Creek through Outfall 001.SWMU 20: Emergency Holding PondBelow grade impoundment of 600 ft21950s – presentPhase I samples from sludge:     Tc-99 – 56 pCi/g    Total Uranium – 381.8 pCi/g    Np-237 – 1.2 pCi/g    Nickel – 201,600 �g/L, TCLP extract PCBs – 3,000 �g/kgIt is reported that the unit never received TCE,    Tc-99, or PCBs.SWMU 30: 
C-747A Burn Area128,000 ft21951-1970Phase I – from Well 66:    TCE – 5,300 �g/L    Tc-99 – 2,830 pCi/g
Phase I Deep Boring:    Aroclors 1254 – 120 �g/kg    Aroclors 1260 – 26 �g/kgAsh and burned material were buried when the    incinerator was closed.
Much lower concentrations of TCE and Tc-99 were obtained during    Phase I sampling from Wells 63, 64, and 65 that are all located west of the unit.SWMU 33: C-727 Motor Cleaning FacilityN/A1957 – presentPhase I Shallow Borings:    PCBs – 66,000 �g/kg    Dioxins/furans – 3.29J �g/kg    VOCs (e.g., benzene, ethylbenzene, and xylenes) – 210 �g/kgProcess for cleaning changed in 1975 from dipping    in mineral spirits to steam cleaning.SWMU 40: C-403 Neutralization TankN/A1950s – presentApproximately 3,200 Ci of Tc-99 were discharged at    a controlled rate from the Plant to surface waters, primarily from C-400 effluents and,    therefore, potentially through C-403.C-403 receives effluents from C-400 Cleaning    Building and discharges to North/South Diversion Ditch, where it is directed to the    C-616-F Full Flow Lagoon. C-616 discharges to Big Bayou Creek through Outfall 001.SWMU 47: C-400 Technetium Storage Tank Area4,000 gallons1960s –1986 when the tank was removed1986 samples in and around tank: Tc-99 – 0.5    ppm in soil, 0.08 ppm in concrete    Chromium – 10.1 ppm in soil, 17.2 ppm in concrete    Uranium – 165 ppm in soil, 28 ppm in concreteNo spills of Tc-99 were documented.SWMUs 58-69: Effluent Ditches and Little and Big    Bayou CreeksThe two creeks follow along the western and    eastern sides of the Plant, respectively, and empty into the Ohio River.N/APhase I;    Evidence of transuranic, Tc-99, PCB, and organic compound contamination in sediments and    surface water.
Subsequent assessment indicated risk from exposure to creek sediments.Reaches with contaminated soils and sediments    include: the North/South Diversion Ditch from the Plant to Little Bayou Creek (10,000 ft),    Little Bayou Creek from Plant Outfall 011 to the North/South Diversion Ditch (16,000 ft),    and Big Bayou Creek from Plant Outfall 009 to New Water Line Road (3,000 ft).
 

**Number & Location**
**Areal Extent**
**Period of Operation**
**Sampling Data**
**Comments**SWMU 74: PCB Spill SiteN/ASpills occurred from 1950s to early 1970sPhase I:    Aroclor 1260 – 2,974.8 �g/kg    Dioxins – 16 �g/kg    Gross beta – 38.5 � 2.1 pCi/gExact release dates are unknown.SWMU 75: PCB Spill SiteN/ASpills occurred from 1950s to early 1970sPhase I:    Aroclor 1254 and 1260 – 770 �g/kg    Dioxins/furans – 230 �g/kgExact release dates are unknown.SWMU 79: PCB Spill SiteN/ASpills occurred from 1950s to early 1970sPhase I:    Aroclor 1260 – 12,000 �g/kg    Dioxin (OCDD) – 8.69J �g/kg    Organics – 80J �g/kg    Tc-99 – 1.0J pCi/g    Pu-239 – 0.36 � 0.17 pCi/gExact release dates are unknown.SWMU 80: PCB Spill SiteN/ASpills occurred from 1950s to early 1970sPhase I:    Aroclor 1260 – 150,000 �g/kg    Dioxins – 37.2 �g/kg    OCDD – 8.3 �g/kg    Tc-99 – 1.9J � 0.2 pCi/gExact release dates are unknown.SWMU 81: PCB Spill SiteN/ASpills occurred from 1950s to early 1970sPhase I:    Aroclor 1260 – 17,417 �g/kg    Dioxins – 12.63J �g/kg    OCDD – 170 �g/kgExact release dates are unknown.SWMU 82: Electrical SwitchyardN/A1951 – presentPhase I:    Aroclor 1260 < 112.9 �g/kg    OCDD < 7.51 �g/kg    Gross beta – 21.7 � 1.9 pCi/gPre-RCRA, TCE was dumped on the ground when    cleaning operations were finished. Several hundred gallons were used annually. PCB    contamination also found.SWMU 83: Electrical SwitchyardN/A1951 – presentPhase I:    Aroclor 1260 < 570 �g/kgPre-RCRA, TCE was dumped on the ground when    cleaning operations were finished. Several hundred gallons were used annually. PCB    contamination was found.SWMU 84: Electrical SwitchyardN/A1953 – presentPhase I:    Aroclor 1260 < 63 �g/kgPre-RCRA, TCE was dumped on the ground when    cleaning operations were finished. Several hundred gallons were used annually.SWMU 85: Electrical SwitchyardN/A1951 – presentPhase I    Chloromethane – 480J �g/kg    Total xylenes – 250J �g/kgPre-RCRA, TCE was dumped on the ground when    cleaning operations were finished. Several hundred gallons were used annually.SWMU 91: UF6 Cylinder Drop Test AreaN/A1979Phase I Deep Boring:    TCE – present to 24 feet below level surface in concentrations up to 260 �g/kgTCE was typically left in pit for days prior to    pumping.SWMUs 94 and 95: Old Kentucky Ordnance WorksN/A1942 – 19461988 leach field samples, SWMU 94:    PAH – 131 to 1,040 �g/kgaSWMU 138: C-100 South Side LawnN/ASee commentsNo samples identified as having been taken for    SWMU 138; however, historic analyses of the SWMU 38 sludge (one of two sources of the    sludge) reported the presence of PCBs and uranium.Receives sludge from the C-611 Water Treatment    Plant and the C-615 Sewage Disposal Plant (SWMU 38).
Sludge applied directly to lawn as    fertilizer.

C-615 sludge contained PCBs and uranium. 
**AppendixCTeam Composition**
To reflect the investigation team’s overall mission of assessingthe impact of current DOE activities on worker safety, public safety, and environmentalprotection, the investigation activities of the team are organized into three groups– management and worker safety, environmental management, and radiation protection.Each group is composed of a group leader and individual members with relevant expertise.Each group developed lines of inquiry that guided the evaluation scope of interest forthat group. The specific activities of the investigation team are discussed in Section1.4.

The team composition and areas of responsibility are shown below.

**Senior Manager**
S. David Stadler, Ph.D.

**Team Leader**
Patricia Worthington, Ph.D.

**Managementand Worker Safety Group**
Brad Davy - Group LeaderMarvin Mielke, RNBob FreemanRegina GriegoBill McArthur, Ph.D., CIHJerry McKamy, Ph.D.Al Gibson**Jim Lockridge, PE, CIH, CSP**Mark Good**

**EnvironmentalManagement Group**
Bill Eckroade, REM – Group LeaderVic Crawford, PE, REMArlene Weiner, REM**Thomas Naymik, Ph.D., CPG, RG**Chris Perry, CPG**Mario Vigliani, CHP**

**RadiationProtection Group**
Ed Blackwood – Group LeaderRobert Loesch, RRPTBill Cooper, CSPPete O’Connell, CHP

**Communicationsand Support**
Mary Anne SirkBarbara HarshmanBob McCallumMarcia TaylorKathy Moore

**QualityReview Board**
S. David StadlerRaymond HardwickThomas StakerTom Davis

** Technical Adviser

 
RN    CIH    CSP    REM    PE    CPG    RG    CHP    RRPTRegistered Nurse    Certified Industrial Hygienist    Certified Safety Professional    Registered Environmental Manager    Professional Engineer    Certified Professional Geologist    Registered Geologist    Certified Health Physicist    Registered Radiation Protection Technologist***********************************************************************************************************************************************************************************************************