Paducah Remedial Action
| Project Code: | OR-45301 |
| Problem Areas: | Remedial Action (Primary) Decontamination and Decommissioning Health / Ecology / Risk |
| Life-Cycle Cost in 2007+: | $432,000,000 |
| DOE Project Manager: | Robert C. Sleeman, 423-576-0715, sleemanrc@oro.doe.gov |
| Contractor Manager: | T. W. Morris, 423-241-4921, morristw@ornl.gov |
| For More Information: | http://www.em.doe.gov/closure/pbs/orp17.html |
Maximum Public, Worker, and Environmental Risks in the year 2007 and beyond:
| Public: High | Worker: High | Environment: Urgent |
Technical Approach Provided by Project Manager:
The technical approach for the RA Program includes strategies for establishing site priorities, remedial goals based on land use, source control actions, and RAs for groundwater and surface water contamination. The 208 SWMUs/AOCs have been divided into 30 WAGs (potential operable units [OUs]) based on common characteristics including contaminant types, geographic locations, media, remedial alternatives and other common factors. The WAGs were then prioritized for the purpose of undergoing the RA process to focus resources and ensure prompt actions are taken to address threats to human health and the environment. The WAGs were prioritized based on the following criteria: 1) Mitigate immediate threats in all media, either on- or off-site 2) Control "hot spots" associated with off-site contamination 3) Address suspected sources of off-site contamination 4) Address suspected sources of on-site contamination 5) Final actions for groundwater and surface water integrator units The RA process for the various WAGs will typically include work plan development for sampling activities, remedial investigations, risk assessments, treatability studies, feasibility studies, remedy selection, remedial design, remedial construction, operation/surveillance, and maintenance, as appropriate. The current and anticipated future use of the property that comprises PGDP will have a significant impact on the cleanup standards, types of RAs selected, and total costs for site remediation (e.g., industrial use vs. residential). Based on existing lease agreements, congressional plans to privatize USEC, the complex nature of site contamination, and stakeholder input gathered to date, the current land use of mixed industrial/recreational is expected to be the most likely future use at the site. Therefore, the following remedial goals and points of exposure have been established to provide the framework for developing cleanup standards at the site: 1) Protect industrial workers from direct contact of surface and subsurface soils (0'-10') for work conducted inside the security fence 2) Protect groundwater users at the DOE property boundary 4) Protect recreational users outside security fence 5) Protect sensitive ecosystems outside security fence To accomplish these goals, the remedial strategy includes a combination of source-control actions at the individual SWMUs, followed by RAs for groundwater and surface water contamination also referred to as integrator units. Because integrator units typically encompass large geographic areas that collect releases from multiple source units, final actions for integrator units are deferred until releases from the contributing source units are mitigated. However, because integrator units also serve as migration pathways to potential receptors, interim actions early in the process may be necessary to ensure adequate protection to human health and the environment while source units are being addressed. Several interim actions addressing imminent risks and hot spots have already been implemented, and the need for additional interim actions will continually be considered during the remaining source unit investigations, as appropriate. Groundwater and surface water data collected during the individual source unit investigations will ultimately be combined to complete the RI data needs for the surface water and groundwater OUs. Certain types of contamination cannot be effectively remediated to acceptable levels. TCE, which is a dense, nonaqueous-phase liquid (DNAPL), has been released to the environment and migrated downward to the groundwater, forming high concentration pools, thereby serving as long-term sources of groundwater contamination. EPA guidance (OSWER Directive 9234.2-25) published October 4, 1993, discusses the technical impracticability associated with DNAPL remediation. In such cases, containment technologies (e.g., barrier walls) may be more effective at achieving the site remedial goals for groundwater, rather than technologies involving mass removal. However, some innovative technologies currently under evaluation have shown some promise in removing these contaminants. One technology referred to as "Lasagna" was field tested at SWMU 91, and was recently deemed successful. Therefore, full-scale deployment of this technology for SWMU 91 is expected in the FY 1998/1999 time frame. However, this application is primarily limited to the unsaturated zone. Other promising technologies for DNAPL remediation currently being evaluated include dual-phase extraction, cosolvent/ surfactant flushing, in situ oxidation, dynamic underground stripping, and hydrous pyrolysis. The technical approach for these types of source areas will likely include a combination of actions including containment technologies for source areas, mass removal for high-concentration areas, and natural attenuation of the dissolved-phased plume. Landfills are assumed to be capped in place with long-term monitoring. However, some stakeholders have expressed a preference for excavation as opposed to the capping assumption. Several WAGs at the Paducah Plant, designated under the site priorities as "Suspected sources of on-site contamination," are considered low-risk WAGs that may be good candidates for No Further Action (NFA). The RCRA Permits and FFA contain a schedule of compliance requiring a remedial investigation for these WAGs by a certain date. However, as part of the Accelerated Cleanup Plan strategy, site evaluations (PA/SIs) will be conducted for these units in an attempt to reach NFA decisions (the NFA is based on land use assumptions) prior to the scheduled RI/FS date. If the site is successful in obtaining early NFA decisions, a significant cost savings will be recognized compared to the original baseline which assumed these WAGs would be subject to the complete RA process. In the event some of the subject SWMUs require an RI/FS, additional funding will be required to comply with the RI/FS requirements of the RCRA Permits and FFA. While full-scale D&D is not currently in the scope of the Accelerated Cleanup Plan, significant opportunities exist to utilize emerging, innovative D&D technologies or to provide for technology demonstration. However, it is likely that standard industry practices and technologies will be employed for D&D of Paducah facilities. D&D of the two current accepted facilities is being delayed to integrate these with the total plant D&D, and thus gain efficiency of scale during project implementation. Detailed planning or design for these D&D projects has not been conducted, but preliminary plans include decontamination and reuse of certain facilities as part of a reindustrialization scenario with dismantlement and on-site entombment of wastes from the balance of the plant facilities. Operations and Maintenance (O&M) at groundwater plume pump and treat facilities and postremedial sites utilize accepted techniques consistent with regulatory requirements and best-management practices. Deficiencies identified from surveillance and inspection will be corrected as appropriate. Generally, the requirements outlined in DOE Orders or standard industry practices are applied in the conduct of maintenance at DOE support facilities. Maintenance will be performed to correct identified deficiencies or as a preventive measure to retard degradation or improve operation factors.Post 2006 Project Scope Provided by Project Manager:
All RA activity is expected to be complete by FY 2006, with the exception of WAG 24 and the groundwater (WAG 26) and surface water (WAGs 18 and 25) integrator units. WAG 24 is scheduled to be completed by FY 2009, dependant on the completion of scrap removal activities at SWMUs 14 and 15 by FY 2003 under the WM Project. However, it should be noted that WAGs 29 and 30, which are currently scheduled for an SE and NFA decision prior to FY 2006, could result in post-2006 scope due to the nature of these units. WAG 29 contains operating facilities that have been identified as SWMUs/AOCs due to historic practices. WAG 30 contains SWMUs located within or below facility structures with limited access. While the current baseline under the 2006 Plan is to seek early NFA decisions through the SE process, the nature of these units may require DOE to coordinate the investigation and, if appropriate, remediation of these units when they cease operation, and/or during D&D activities. If this occurs, a Baseline Change Proposal (BCP) will be implemented to reflect these changes. Completion of the surface water and groundwater units is baselined to be completed after releases of contributing source areas (SWMUs/AOCs) have been mitigated. Based on this sequencing, the groundwater and surface water units will be completed by FY 2010. Activities following the remediation of these units will include long-term S&M to ensure remedial activities remain effective, and performance of five-year reviews for any remediation in which wastes or contamination is left in place, as required by CERCLA. Because wastes are assumed to remain in place at landfills and some burial grounds at the site, at least some portion of the site will be restricted from certain types of future uses (e.g., intrusive activities, residential development). Maintaining these institutional controls will be a portion of post-2006 scope for the Paducah Environmental Restoration Program. Groundwater plume pump and treat operations will continue. Long-term S&M of DOE facilities will continue in order to assure the continued stability of the sites.Project End State Provided by Project Manager:
The final end state for the Paducah Program will be a long-term S&M with institutional controls. This condition is expected because of existence of several on-site WM units, such as landfills or burial grounds, that will be closed or remediated with wastes or contamination remaining in place. Kentucky regulations require a postclosure groundwater monitoring and care period of 30 years. Many of the wastes that will remain in place at Paducah are long half-life radionuclides, so a longer monitoring period will be required. For areas where contamination remains in place, five-year reviews of RAs will be performed as required by CERCLA. The enrichment process will continue to operate under USEC control, or a successor organization. Reindustrialization or reuse of existing DOE facilities, or use of infrastructure, is a possibility, with deed restrictions or use limitations applied to areas that have contamination remaining in place. The final end state for D&D buildings is the effective cleanup of the contaminated facilities such that release for reuse is allowed, or the dismantlement of facilities that cannot be reused. While the 2006 Plan does not contain scope for actual D&D activities, preliminary assessments for both C-340 and C-410 facilities indicate that each facility will require dismantlement to the grade level with the potential for remediation of soils underlying each facility.The full list of science research awards that have the potential to address projects such as this one, which deals with Remedial Action, Decontamination and Decommissioning, and Health / Ecology / Risk problems, are listed in the Index of Research Awards by Environmental Management Problem Area, in the back of this appendix, under the headings "Remedial Action, Decontamination and Decommissioning, and Health / Ecology / Risk".
The following awards were identified through systems engineering to have the potential to address the specific needs of this Project. Those research awards that may have the strongest link to this project are designated by the symbol "§".
The following tree shows how the above awards link to this project. When multiple brances are shown leading to or from a problem area, branches to the left are primary links and branches to the right are secondary.
| High Cost Project | OR-45301 - Paducah Remedial Action | ||||||||||||||||||||||||||||||||||||||||||||||||||||
| Problem Areas Linked to OR-45301: | Remedial Action | Health / Ecology / Risk | Decontamination and Decommissioning | ||||||||||||||||||||||||||||||||||||||||||||||||||
| Research Awards Linked to OR-45301: Pass the mouse over an Award ID for more information, below. Click ID for more detail: |
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