Previous Land Use Studies
Over the last fifteen years, several different organizations have formulated potential future visions for the land associated with the Paducah Gaseous Diffusion Plant. These have included DOE (1995, 2008), the PGDP Citizens Advisory Board (2007, 2008, 2009) and PACRO and PUPAU, the Commonwealth of Kentucky (2008,2010). These efforts are summarized in the following sections:
DOE Future Land Use Report
Future Land Use Process for Oak Ridge Operations, A Report to the U.S. Department of Energy on Recommended Future Uses of The Oak Ridge Reservation, Paducah Gaseous Diffusion Plant, and the Portsmouth Gaseous Diffusion Plant, December 1995, ES/EN/SFP-43/D-1
Summary of the Report:
1.1 Internal Stakeholder Preferred Options
“A facilitated workshop was conducted April 28, 1995, in Oak Ridge, Tennessee, with approximately 22 internal stakeholders. Participants included representatives of DOE and contractors from the Portsmouth, Paducah, and Oak Ridge facilities. The workshop was held to identify general types of alternative missions deemed by the group as "most likely" for further development or consideration should the Department receive notification the USEC intends to terminate its lease agreement at one or both of the gaseous diffusion plants in Portsmouth and Paducah, Kentucky. The workshop was part of the GDP Turnover Contingency Planning Alternative Missions Plan submitted to DOE in October 1995: DOE initiated the contingency planning project to achieve a state of readiness should USEC provide notification of lease termination for either facility. Once notification is received, DOE would at that time involve external stakeholders and the affected communities in identifymg and selecting alternative uses for the site facilities. Workshop participants considered alternative missions that would take advantage of or accommodate site characteristics such as power supply and infrastructure, ample land space, transportation means and routes, and the plant's isolated location. In addition, the workshop participants selected three evaluation criteria to expedite initial evaluation of the feasibility of 48 ideas compiled as possible alternative missions. These criteria were:
- feasibility for DOE,
- regulatory compliance, and
- political considerations.
A smaller core team of eight key internal stakeholders consolidated the 48 possible alternative missions from the results of the workshop brainstorming session into six categories of likely alternative missions:
- Training and Education Center;
- Low-level Radioactive Material Treatment Storage Disposal Facility;
- Heavy Industry Complex;
- Industrial Park;
- Resource Recovery Center;
- and Facility to meet federal needs, including DOE'S.
1.2 External Stakeholder Preferred Options
DOE began preliminary discussions with stakeholders on Future Land Use at Paducah on June 30, 1994. A public workshop was conducted, and one of the break-out tables featured Future Land Use as a topic. Subsequently, Future Land Use was presented and discussed at public workshops on, December 1, 1994, January 26, 1995, and September 26, 1995. In addition, the subject has been discussed at various meetings with the PGDP Neighborhood Council, the PGDP Environmental Advisory Committee, with city and county officials, and economic development interests.
The Neighborhood Council, administered by Lockheed Martin Utility Services, Inc. (LMUS), is an eight-member body comprised of individuals who live near the plant. The Environmental Advisory Committee, which has five active members comprised of scientists, businessmen and plant neighbors, is administered by LMES and has been an active committee since 1986. In general, these organizations, including city and county officials, support a continued industrial/commercial presence at the site that would preserve existing jobs and continue to contribute to the regional economy.
The Environmental Advisory Committee suggested some specific uses of the property that involved turning the facility into a national research center to test new technologies for groundwater remediation. The committee has suggested that resources from regional and state universities and colleges be used to accomplish this goal. The committee has suggested pulling together academic, economic, environmental, and scientific interests to discuss such a proposal. Because of the nature of the contamination at PGDP and its extent off-site, the committee considers the plant an ideal site for such research.
Another major stakeholder in the region besides DOE and USEC is the Kentucky Department of Fish and Wildlife (KDFW). Most DOE property outside the 748-acre fenced security area is leased to KDFW as part of a wildlife management area adjacent to property owned by KDFW. KDFW has indicated that it supports the current land use arrangement at the site; however, if DOE ever decides to sell the property that KDFW currently leases, they would like the first opportunity to acquire the property before it is offered to another entity.'
Of the residents living within a three-mile radius of the plant that choose to express views on this subject, the majority had a preference to retain the jobs and economic benefits associated with the current land use practices. However, they have expressed a desire to ensure that site contamination is contained within the DOE property, thus preventing any off-site migration that may result in devaluation of their properties.
Certain environmental activist groups have suggested that the area inside the plant fence be remediated enough to prevent further migration of contaminants off-site, but stopped short of recommending cleanup to green field standards, because of the exorbitant costs involved and the lack of-technologies to accomplish such a standard. However, these groups suggest an "iron fence" approach to the 748-acre fenced area, restricting access and continuing surveillance and maintenance. These groups have suggested that DOE offer to buy out any property owners in the vicinity of the plant whose property is contaminated or could potentially be contaminated.
PGDP is in the process of establishing a Site-Specific Advisory Board (SSAB) to review issues and provide input into the decision-making process on DOE environmental matters at PGDP. Oncethe SSAB is established, land use will be one of the first items discussed with the Board.
Also, DOE has encouraged the establishment of Community Reuse Organizations (CROs) to get a community to speak "with one voice" regarding the future uses of DOE sites. The CRO, through strategic planning, determines actions that a community will take to offset local consequences of DOE downsizing at its facilities. The CRO would work cooperatively with the public and private sectors in developing a comprehensive plan for the reuse of the Paducah Site. CRO's include broad-based representation of public and private sector organizations and individuals capable of forming a community consensus and marshaling the local support and prospective clients necessary to successfully bring alternative missions to the site. While a CRO does not exist at PGDP, the GDP Turnover Contingency Plan Alternative Missions document recommends that one be established at PGDP.
1.3 Site Contamination
During past operations of PGDP, hazardous substances generated as byproducts from the enrichment process were released into the environment. These releases are typically associated with burial grounds, spill sites, landfarms, surface impoundments, and USTs. Subsequent investigations at PGDP revealed that these environmental releases have migrated to the soils, groundwater, and surface waters, thus resulting in off-site contamination. These areas now require investigation and remediation under RCRA and CERCLA.
The primary contaminants of concern at PGDP include radionuclides, organic solvents, and PCBs. The extent to which DOE can remediate these contaminants will have a large influence on future use of DOE property at PGDP. Some burial grounds at the site contain radionuclides that have the potential to be unstable if disturbed, due to the pyrophoric nature of the material. In such cases, leaving the material in place with a protective cap and monitoring system may be the only economically-feasible and safe remedial option available. With regard to such situations and other on-site landfills, it is very unlikely that the future land use of these areas will change, given the nature of the material buried, the volume of wastes, and the fact that EPA's presumptive remedy for landfills is containment rather than removal. The landfill remediation strategy accompanies a presumptive future land use. Residential development of land-based disposal units is prevented through a post-closure period of 30 years and into perpetuity by deed restrictions.
Other types of contamination at PGDP that will have a direct affect on future use decisions involve certain organic solvents (i.e., TCE). In some cases, TCE, which is a DNAPL (dense nonaqueous-phase liquid), has migrated downward to the groundwater and formed high concentration pools, thereby serving as long-term sources of groundwater contamination. Existing EPA guidance acknowledges that no remedial technologies currently exist that can clean up DNAPLs to drinking water standards, making it technically impracticable to remediate such areas for unrestricted use.
In cases where contamination will remain in place due to the complex nature of the wastes or due to remedial limitations, the remedy selection process must consider what level of restrictions is appropriate for future use of the site. For example, contaminants left in place and covered with a protective cap may be deemed adequate for industrial use but not for residential use. In such cases, institutional controls (e.g., deed restrictions) should be used to ensure that industrial use of the land is restricted to prevent any potential risks from residential exposure. See the Paducah Gaseous Diffusion Plant Site Management Plan for further discussion.
1.4 Future Land Use Recommendations
The primary objective of this limited study was to provide a recommendation for future use of the DOE property currently occupied by the operations associated with PGDP. As part of the evaluation process, numerous options were originally identified and subsequently narrowed down to four primary land use scenarios: (mixed industrial/recreational, expanded industrial, expanded recreational, expanded residential. In making a final recommendation, the following factors were considered:
- 1. stakeholder input,
- 2. existing laws and lease commitments, and
- 3. the nature of the environmental contamination present at the site.
Based on a limited sampling of stakeholder preferences, the majority favored maintaining the property for its current industrial/recreational use (Option 1). No stakeholders recommended converting the property to residential use or the other remaining options.
Other factors that must be considered include future use restrictions imposed by existing laws and current lease agreements. On October 24, 1992, the President signed the Energy Policy Act of 1992, Pub. L. 102-486 (the Act) which amended the Atomic Energy Act of 1954, 5 201 1-2296 (1992, as amended). The Act established a new government corporation, USEC, whose charter is to provide uranium enrichment services on a profitable and competitive basis. The original term of the lease is for a period of six years from the transition date of July 1, 1993, with exclusive options for USEC to lease such facilities and related properties for additional periods.
Lease agreements are also in place with KDFW to use certain DOE properties for the West Kentucky Wildlife Management Area (WKWMA).' The subject property is highlighted by red shading in Option 1. KDFW has indicated a desire to obtain the DOE property it leases should DOE ever decide to sell the property. However, the current lease agreement with USEC gives the Corporation the first right to obtain any real property associated with the GDP which is not part of the existing lease agreement.
Site contamination is another important factor that must be considered in such a determination. Based on the complex nature of wastes (e.g., radionuclides, DNAPLs) present at PGDP, the future use of the site may never be appropriate for certain uses such as residential. In such cases, institutional controls (e.g., deed restrictions) may be used to place restrictions on the property to prevent certain future uses.
After consideration of all the above factors, the DOE Site Office at Paducah considers the current land use of mixed industrial/recreational as the most likely future use scenario for the site. A preliminary list of alternative missions that may be viable options for future consideration are detailed in the GDP Turnover Contingency Alternative Missions Plan. The subject document also suggests various strategies that could be implemented to evaluate the alternative missions in detail and pursue others that may be applicable to site reuse. Should additional information become available suggesting that an alternative land use may be more appropriate, the land use assumptions generated from this limited study will be revised accordingly.”
DOE Risked Based End State Report
Update the End State Vision for the Paducah Gaseous Diffusion Plant, Paducah, Kentucky, May 2008, DOE/LX/07-0013&D1
Summary of the Report
“This Update to the End State Vision for the Paducah Gaseous Diffusion Plant, Paducah, Kentucky, (formerly Risk-Based End State Vision and Variance Report for the Paducah Gaseous Diffusion Plant, Paducah, Kentucky), DOE/LX/07-0013&D1, which originally was prepared to meet requirements set forth in a memorandum from Jessie Roberson to Distribution dated September 22, 2003, as amended by clarification contained in a memorandum entitled “Risk Based End State Guidance Clarification” dated December 23, 2003 (DOE 2003), and in the notes from the U.S. Department of Energy (DOE) Risk- Based End State (RBES) Next Steps Workshop, October 6 and 7, 2004. This revision also includes a summary of interaction with stakeholders through July 2007.
The presentation of material in this document is consistent with DOE Policy, DOE P 455.1, entitled Use of Risk-Based End States (DOE 2003), the standardized approach set forth in a guidance document entitled Guidance for Developing a Site-Specific End State Vision (dated September 11, 2003) (DOE 2003), as amended by the “Risk Based End State Guidance Clarification,” and the notes from the DOE RBES Next Steps Workshop, October 6 and 7, 2004. The document is a tool for communicating the Paducah Gaseous Diffusion Plant’s (PGDP’s) end state vision to stakeholders (i.e., DOE, the U.S. Environmental Protection Agency, the Commonwealth of Kentucky, and the general public). As discussed in the notes from the DOE Next Steps Workshop, this document will be updated as needed to reflect actual decisions from the ongoing Comprehensive Environmental Response, Compensation, and Liability Act process at the site.
Although this report presents potential actions to address hazards that could be used to reach the PGDP’s end state, this report is not a decision document. Rather, discussions of potential specific mechanisms are included to provide an analytical framework that DOE will use to further evaluate the cleanup activities and the strategic approaches at PGDP to determine if it is appropriate to pursue changes in the PGDP baseline. Any decision to pursue changes to the baseline will include factors beyond those presented in this document, including input from stakeholders. If DOE ultimately decides to seek changes to the current compliance agreements, decisions, or statutory/regulatory requirements, then those changes will be made in accordance with applicable requirements and procedures.”
Update to the End State Vision for Paducah Gaseous Diffusion Plant
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PGDP Citizens Advisory Board
“The Paducah Citizens Advisory Board (CAB) is a stakeholders' board that provides advice and recommendations to the U.S. Department of Energy (DOE) on environmental remediation, waste management and related issues at the Paducah Gaseous Diffusion Plant (PGDP) site. The Board is composed of up to 18 members, chosen to reflect the diversity of gender, race, occupation, views, and interests of persons living near the PGDP. The board is committed to reflecting the concerns of the communities impacted by environmental management of the plant site. Members are appointed by DOE and serve on a voluntary basis. Non-voting liaisons include representatives from the U.S. Environmental Protection Agency, the Kentucky Department for Environmental Protection, the Kentucky Department of Fish and Wildlife Resources and the Kentucky Radiation Health Branch. These members advise the CAB on their agencies' policies and views.”
CAB Website: http://www.pgdpcab.org/index.html
Over the last several years the CAB has made several recommendations with regard to the possible future use of the PGDP property.
Three examples are provided below:
CAB Recommendation: 04-07
Dr. Jim Smart, CAB Presentation, December 2007
Bobby Ann Lee, CAB Presentation, October 2008 -
PACRO
“The Paducah-Area Community Reuse Organization (PACRO) was formed in August of 1997 by regional community representatives from western Kentucky and southern Illinois in an effort to mitigate potential downsizing and restructuring of the Paducah Gaseous Diffusion Plant (PGDP) workforce as a result of the end of the Cold War and changing Department of Energy (DOE) priorities. Membership of the PACRO is designed to represent the counties in which the majority of the PGDP workforce lives. The PACRO impact area includes McCracken, Ballard, Graves and Marshall Counties in western Kentucky and Massac County in southern Illinois.” The various initiatives of PACRO can be found at their website:
PACRO Website:
http://www.purchaseadd.org/Paducah_Area_Community_Reuse_Organization_%28PACRO%29/PACRO has initiated various studies to examine what to promote economic development associated with the PGDP. One initiative involved the creation of the Paducah Uranium Plant Asset Utilization (PUPAU) Task Force:
The mission of PUPAU is to “Provide community consensus to our local elected officials on strategic optimization of the national assets of the Paducah Gaseous Diffusion Plant and promote the development and use of those assets for the benefit of our country, state, and community."
The Task Force is concentrating on three areas of asset utilization for the facility:
- Optimization of the existing operational, cleanup, and recreational activities at the site.
- Explore and promote new missions for the site, both short and long term, that will fully utilize site assets.
- Mobilize at the national, state, and community level support for the task force's strategic and tactical recommendations.
“The PUPAU Task Force is seeking to return value back to the community. The marketable assets on site are the buildings, infrastructure, equipment, land, metals, service, technology, and the most important asset, the employees. With the precedent set at sites such as Oak Ridge, Mounds, and Savannah River, the Task Force is working with DOE to establish a path forward to return value back to the community through the reuse of the site assets”.
PUPAU Website: http://www.co.mccracken.ky.us/paducah/pupau-task-force
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Kentucky Energy Strategy
The Commonwealth of Kentucky has developed a comprehensive energy strategy for the state that has included a detailed analysis of the PGDP site as a potential site for alternative energy production facilities. Additional information on the state's energy strategy can be found at: Energy Strategy For Kentucky
Additional information on the Commonwealth of Kentucky Alternative Energy Facilities Site Bank (which includes analysis of the PGDP site) is provided at: www.kysitebank.com
More Documents: www.paducahvision.org/documents