Department of Energy Portsmouth/Paducah Project Office 1017 Majestrc Drive, Suite 200 Lexington, Kentucky 4051 3 (85s) 219-4000 MAR 21 \An Ms. Maria Galanti PPPO-03- t426732-12 Ohio Environmental Protection Agency Southeast District Office 2195 Front Street Logan, Ohio 43138 Dear Ms. Galanti: FINAL ACTION MEMORANDUM FOR TFIB PLANT SUPPORT BUILDINGS AND S'TRUCTURES AT THE PORTSMOUTI{ GASBOUS DIFFUSION PLANT, PIKETON' OHIO References: l. Letter from V. Adams to M. Galanti, "Draft Action Memorandum for the Plant Sr"rpport Buildings and Structnres at the Portsmouth Gaseotts Diffusion Plant, Piketon, Ohio, (PPPO-03-141 6007-1 2)," dated February 29, 2012 2, Letter from M. Galanti to J. Bradburne and K. Wiehle, "Ohio EPA Concurrence with the Draft Action Memorandum for the Plant Support Buildings and Draft Structures at the Portsmouth Gaseous Diffusion Plant," dated March 8,2012 al Enclosecl, please fi¡d the Action Mentorctnchrnt Jbr the Plunl Sup¡torÍ Builtlings ancl Struclt'tres the Port;;ltouth Gaseous Dffision Plctnt, Pikelon, Ohio (DOE/PPPO/O3-0230eDÐ' Tlie Ohio Environmental Protection Agency (Ohio EPA) was provided with the draft Action Menrorandum, which Ohio EPA concurred on in the letter dated March 8,2012. This culrent Action Memorandum is the fi¡al version and has been signed by Mr' William E. Murphie, Manager of the ports¡routh/Paducah Project Office. This document was prepared in accordance wjthihe Aprit 13,2010 Director's Fincti Findings ctnd orcler,s.for Rentoval Action and Rentedictl lhe Investigaüàn ctncl Feasibiliry Stndy anrJ Rentediul Design ctncl lì.entediul Action, including September 12, 201I Modificcttion thereto. This transmittal includes: P ort sntouth Gaseon5 Dffi s ion Pl ant, P ike t on, Ohi o (DOE/PPPO/03-0230&D4); (DOE/PPPO/03- Structures ctt the Þorrsntoith Gct:;eous Di//Ltsion Plttnt, PikeÍon, Ohio 0207&D4),wliich the Ohio EPA reviewed and concurred on in a letter dated March S, 2012; and Ms. Galanli PPPO-03-1426732-t2 Þ Attacllreut 2: Responsiveness Sumrnary for Public Comnents Receivecl on the Engineering Ettcrluctl iott/Cost Annlysi,s.fòr lhe Pltrnl Suppotl Builtlings and Structures ¿tt lhe Porlsntouth Gaseou,; Di.llusion Pl.cutt, Piketon, Ohio, which inchrdes Appendix A: Tlansclipt of the Public Availability Session. Ohio EPA's engagenenl and participation in eally discussior, ar.rd dlaft docunent leviews was a tremendous ber.reht to the ploject and DOE appreciates yout cooperatìon. Ilyou l.rave auy questions ol lequile aclditional infor-mation, please coutacl me at (740) 8()7-2759 or I(risti Wielile o1'my staff a1 (740) 897-5020. Sincercly, // ". 1¿ -\ Y,ô ) Portsr.r]outh Site Dil ector Portsmouth/Paducah Ploj ect Olfi ce Enclosule: FtnaI Aclion. Mentorandum .fitr the Plctnt Sultporl Builtlings ond Stntt'tures ¿tt the Pù.tsmoutl't Gaseous Di/fùsion Plant, Piketon, Ollio cc w/ enclosule: lìachel.Bh"[email protected]. gov. PPPO/ORO [email protected]. gov, PPPO/POlìT'S Belt. [email protected]. gov, PPPO/LEX [email protected], PPPO/POR'l'S [email protected]. gov, PPPO/I-EX [email protected]. gov, PPPO/LEX I(Listi, [email protected]. gov, PPPO/POR'l-S Jìm. S1èr'[email protected],oh. us, Ohio EPA/Logan .Tamie. Jar.neson(-!fbports.corr, FBP/POR'lS Dennis.Carr@lbpo1 ts.col't't, FBP/PORTS [email protected], FBP/POR'f S Malc.Jervelt@lbpolts, com, FtlP/POR f S M ike. [email protected], gor,. IìSVPORTS [email protected],gov. RSI/POlìTS PPPO. DIrlì[email protected]. gov U.S. Department of Energy Portsmouth/Paducah Project Office This document has been approved for public release: Henry Thomas (signature on file) 3/14/2012 Classification & Information Officer Date Action Memorandum for the Plant Support Buildings and Structures at the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio (DOE/PPPO/03-0230&D4) 1.0 PURPOSE The purpose of this Action Memorandum (AM) is to document the selection of the non-time-critical removal action for the decontamination and decommissioning (D&D) of 46 process support buildings/structures located at the Portsmouth Gaseous Diffusion Plant (PORTS), including associated materials or equipment anywhere within or adjacent to the buildings or structures. The removal action recommended in the Engineering Evaluation/Cost Analysis for the Plant Support Buildings and Structures at the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio (EE/CA) (U.S. Department of Energy [DOE] 2011) is selected in this AM. The EE/CA is provided in Attachment 1, which is incorporated by reference into this AM as if it is fully set forth herein. 2.0 SITE DESCRIPTION AND CONTAMINANTS The plant support buildings and structures addressed in this AM are identified in Table 1 and shown on Figure 2 of the EE/CA. Table 1. PORTS Process Support Buildings Building Number Building Name DFF&O Groupa X-100 Administration Building 2 X-100B Air Conditioner Equipment Building 2 X-101 Dispensary 2 X-102 Cafeteria 2 X-104 Guard Headquarters 2 X-106 Tactical Response Building 1 X-106C New Fire Training Building 1 X-108H Pike Avenue Portal 1 X-109A Personnel Monitoring Station 1 X-109B Personnel Monitoring Station 1 X-109C Personnel Monitoring Station 1 X-343 Feed Vaporization and Sampling Building 4 X-530A High Voltage Switchyard 2 X-530B Switch House 2 X-530C Test and Repair Building 2 X-530D Oil House 2 X-530E Valve House 2 X-530F Valve House 2 X-600 Steam Plant 3 X-600B Steam Plant Shop Building 3 X-600C Ash Wash Treatment Building 3 X-611 Water Treatment Plant 2 X-611C Filter Building 1 X-611D Recarbonization Instrumentation Building 1 X-611E Clear Well and Chlorine Building 1 X-612 Elevated Storage Tank 1 X-614A Sewage Pumping Station 1 X-614B Sewage Pumping Station 1 1 U.S. Department of Energy Portsmouth/Paducah Project Office Table 1. PORTS Process Support Buildings (Continued) Building Number Building Name DFF&O Groupa X-618 North Holding Pond Storage Building 1 X-621 Coal Pile Treatment Facility 3 X-624-1 Decontamination Pad 2 X-640-1 Fire Water Pump House 1 X-640-2 Elevated Storage Tank 1 X-735A Landfill Utility Building 1 X-743 Lumber Storage Facility 1 X-744B Salt Storage Building 1 X-744G Bulk Storage Building 2 X-744H Bulk Storage Building 1 X-744J Bulk Storage Building 1 X-744L Stores and Maintenance Warehouse 1 X-744S Warehouse S Non-UEA 1 X-744W Surplus and Salvage Warehouse 1 X-750 Mobile Equipment Maintenance Shop 2 X-750A Garage Storage Building 1 X-752 Warehouse 1 X-752AT 1-4 Trailer Complex 1 aGroup 1 – Low Risk/Low Complexity, Group 2 – Industrial/Medium Complexity, Group 3 – Chemical/Medium Complexity, Group 4 – Radiological/High Complexity DFF&O = The April 13, 2010 Director’s Final Findings and Orders for Removal Action and Remedial Investigation and Feasibility Study and Remedial Design and Remedial Action, including the September 12, 2011 Modification thereto Based on previous reports (DOE 1993 and Theta Pro2Serve Management Company [TPMC] 2006), materials of construction, process knowledge, and the nature and extent of potential contamination, the most common contaminants of potential concern (COPCs) have been identified and presented along with the building descriptions in the EE/CA. The most common COPCs, which are substances that have the potential to adversely affect human health and the environment because of their concentrations, distribution, and toxicity, include asbestos, lead, radionuclides (primarily uranium), mercury, and polychlorinated biphenyls (PCBs). Some individual facilities also have the potential for volatile organic compounds, semivolatile organic compounds, heavy metals, corrosives, and biological hazards contaminants to be present. The process knowledge inquiry included examination of available records and photographs about building use and history, interviews, and walkdowns of the buildings and structures. The walkdowns provided information about chemicals used in the buildings, materials used in building construction and their current condition, and radiologically controlled areas that resulted from existing radiological surveys. Knowledge of materials or chemicals used in the buildings was the basis for identifying additional COPCs and for the information in the building descriptions provided in Appendix A of the EE/CA. The presence of older insulation or tiled floors indicates that asbestos is a COPC; older painted surfaces may contain lead and PCBs. DOE has evaluated potential reuse of the proposed buildings consistent with existing policies on disposition of buildings, DOE Order 458.1, and applicable segments of DOE Order 5400. Due to the presence of contamination, the aging condition of the buildings, and anticipated cost of maintenance, no future use has been identified at this time for these buildings. Inclusion of a building on this list does not preclude its future reuse, if a need should be identified. Buildings that are shown to be free of contamination according to DOE Order 458.1 and applicable segments of DOE Order 5400, either under current conditions or after decontamination for the purpose of reusing the building, can U.S. Department of Energy Portsmouth/Paducah Project Office be removed from this decision through a decision modification pursuant to agreement between DOE and the Ohio Environmental Protection Agency (Ohio EPA) and in accordance with The April 13, 2010 Director’s Final Findings and Orders for Removal Action and Remedial Investigation and Feasibility Study and Remedial Design and Remedial Action, including the September 12, 2011 Modification thereto (DFF&O) (Ohio EPA 2011) and the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). The set of buildings addressed in the EE/CA and this AM includes a subset of buildings presented in Attachment G of the DFF&O, as well as the X-530A facility, which has been recently added to Attachment G.