Featured Project Video: Demolition work Completed at the C-410 Feed Plant Facility at the Paducah Site.
Decades of uranium enrichment and support activities at the Paducah Site necessitated a need for a cleanup strategy to evaluate and take appropriate actions to ensure protection of human health and the environment.
Past operations generated hazardous, radioactive, mixed (both hazardous and radioactive), and non-chemical (sanitary) waste and resulted in soil, groundwater and surface water contamination. Environmental investigations have been conducted since the 1980s to understand the extent of contamination.
Following environmental investigations of the entire site, the Paducah Gaseous Diffusion Plant was placed on the Superfund National Priorities List (NPL) in 1994. Sites on the NPL must be cleaned up in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). CERCLA is a United States federal law designed to identify, investigate and cleanup hazardous wastes sites that may pose a threat to human health or the environment.
In accordance with CERCLA, DOE worked with the U.S. Environmental Protection Agency (EPA) and Kentucky Department for Environmental Protection (KDEP) to establish the Federal Facility Agreement (FFA). The FFA established the framework for cleanup at Paducah.
The overall environmental cleanup strategy at the Paducah Site is based on taking near-term actions to control or eliminate ongoing sources of contamination along with continued investigation of other potential sources. DOE is working with the Kentucky Department for Environmental Protection and the U.S. Environmental Protection Agency (EPA) to define project sequencing, while optimizing resources and utilizing a risk-based approach, to ensure timely environmental cleanup and minimize workforce impacts.
The Paducah annual Site Management Plan outlines the approach for achieving cleanup under the Federal Facilities Agreement between DOE, Kentucky and EPA. Priorities for reducing risks are established as early as possible. Based on priorities, cleanup actions are divided into units, called operable units (OUs), which are grouped by the effected material (media) or activities—i.e., Groundwater OU, Surface Water OU, Soils OU, Burial Grounds OU, and Decontamination and Decommissioning (D&D) OU.
The cleanup scope is associated with these media-specific OUs that were established by assessing risks for each source area at the site. This process included looking at the type and amount of the contaminant, how the contaminant is released, and whether exposure could occur based on current and possible future use of the Paducah Site.
Groundwater is the water found below the surface of the land and contained in spaces in saturated geologic media (sand, gravel). Groundwater is the source of water found in wells and springs. The Groundwater OU is using sequenced response actions designed to accomplish the following goals: Prevent human exposure to contaminated groundwater; prevent or minimize further movement of contaminant plumes; prevent, reduce or control contaminant sources contributing to groundwater contamination and restore the groundwater to its beneficial uses wherever practicable.
A burial ground is a disposal site for radioactive waste materials that uses earth as a shield. The Burial Grounds OU is grouped into more manageable subprojects called Solid Waste Management Units (SWMU). The Burial Grounds OU uses the CERCLA process to accomplish the following goals: Address sources of groundwater contamination, protects industrial workers from exposure to waste and contaminated soils and treats or removes potentially harmful wastes wherever practicable.
Surface Water is all water naturally open to the atmosphere (rivers, reservoirs, streams, impoundments) and all springs, wells or other collectors that are directly influenced by surface water. Goals of the Surface Water OU is to prevent human exposure to contaminated sediments presenting an unacceptable risk to on-site workers and off-site recreational users of surface water.
Soils are the particles of mineral and/or organic matter from the earth’s surface that are located outdoors or are used indoors to support plant growth. Goals of the Soils OU is to prevent human exposure to contamination presenting an unacceptable risk, prevent or minimize further off-site migration and to reduce, control or minimize contaminated soil hot spots contributing to off-site contamination.
Decontamination is the reduction or removal of contaminated radioactive material from a structure, object or person. Decommissioning is the process of removing a nuclear facility from service.
The D&D OU uses the CERCLA removal action process to administer decommissioning activities of excess buildings (i.e., inactive with no reuse potential) that have a known or potential release of contamination to the environment. The primary objective for this OU is to minimize or eliminate the potential threats to health and the environment caused by the potential uncontrolled release of hazardous substances from contaminated structures and to reduce long-term surveillance and maintenance costs.
Paducah Regulatory Approach
Past uranium enrichment operations and support activities generated hazardous, radioactive, mixed (both hazardous and radioactive), and non-chemical (sanitary) waste. Past operations also resulted in soil, groundwater, and surface water contamination. Environmental investigations have been conducted since the 1980s to understand the extent of contamination.
Following environmental investigations of the entire site, the Paducah Gaseous Diffusion Plant was placed on the Superfund National Priorities List (NPL) in 1994. Sites on the NPL must be cleaned up in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). CERCLA is a United States federal law designed to identify, investigate and clean-up hazardous wastes sites that may pose a threat to human health or the environment.
In accordance with CERCLA, DOE worked with the U.S. Environmental Protection Agency (EPA) and Kentucky Department for Environmental Protection (KDEP) to establish the Federal Facility Agreement (FFA). The FFA established the framework for cleanup at Paducah, instituted enforceable milestones, and coordinated site-specific cleanup requirements for achieving comprehensive site cleanup, including stakeholder involvement under CERCLA and the Resource Conservation and Recovery Act.
The FFA directs the comprehensive remediation of the Paducah Gaseous Diffusion Plant. It contains requirements for implementing investigations of known or potential releases of hazardous substances, pollutants or contaminants, or hazardous wastes or hazardous constituents, selection and implementation of appropriate remedial and removal actions and establishing priorities for action and development of schedules, consistent with the established priorities, goals and objectives of this agreement.
A key aspect of PPPO’s Strategic Vision is an effort underway to work cooperatively with U.S. EPA Region 4 and the Commonwealth of Kentucky to re-align the regulatory approach at Paducah to a more holistic, integrated approach successfully used at Portsmouth. PPPO has proposed to integrate and accelerate the Paducah clean-up decisions for Environmental Media, D&D and Waste Disposition to 2029. The Decision 2029 plan is projected to accelerate final clean-up decisions by up to 25 years. This initiative will maintain focus on the TCE source at C-400 while streamlining the regulatory process to maximize an integrated project portfolio strategy. The plan will reduce more than 50 regulatory decision documents to five decisions, assuring consistent and aligned Applicable or Relevant and Appropriate Requirements.