October Public Meeting Question and Answer's
Deactivation and Demolition
Deactivation and Demolition
The X-326 facility was deactivated prior to removing the transite siding. This deactivation was extensive and took more than nine years. During deactivation, the process equipment (compressors, coolers and converters) were removed and disposed of offsite. Extensive measurements of all piping were conducted and any material that did not meet strict activity levels was removed. All piping and components that could not be measured in the building were also and shipped offsite or staged in other facilities for measurement to be followed by compliant disposal.
Approximately 93.5% of the radioactivity within the building was removed. In addition, hazardous materials were also removed including asbestos components and insulation. The facility was inspected several times to ensure that all materials within met the Waste Acceptance Criteria for the onsite disposal cell. Following deactivation, the interior of the building was sprayed with fixative to immobilize any material that could generate dust. In addition, once the siding was taken off, fixative was sprayed through the outside of the building to further immobilize any potential dust. Following that application of fixative, a screen was placed on the exterior to prevent material from entering or leaving the facility.
During all that time our particulate monitors and the air monitors were in place and the data indicate that material did not escape from the building.
DOE has a robust monitoring network that reports real time project specific and site wide evaluated data. This provides assurance there aren’t any off-site radiation issues. This data is made available regularly, as well as reported in our Annual Site Environmental Report.
The data reports involving the non-destructive analysis and the deactivation were extensively reviewed by subject matter experts at FBP followed by DOE. Calculations that resulted from those reviews were further reviewed by the ODH with the assistance of independent subject matter experts.
Extensive characterization of the X-326 building was performed over a period of decades of operation, shutdown and deactivation. Transuranic elements were identified in the Portsmouth cascade. Transuranic elements are artificially made, radioactive elements that has an atomic number higher than uranium in the periodic table of elements (i.e., 92).
However, the amount of transuranic material within the cascade was very small or only trace amounts. To date air monitors surrounding the X-326 building have not detected any transuranic material. Because of the very low amounts, none of the demolition debris from the X-326 is transuranic waste. Transuranic waste is concentrations greater than 100 nanocuries per gram.
The demolition approach for the X-326 is focused on minimizing the spread of all radiological materials including uranium, technetium and any transuranic.
One of the known and planned for hazards related to deactivating and demolishing gaseous diffusion plants is the potential for water to come into contact with a deposit of uranium and fluorine compounds (i.e., uranium hexafluoride, UF6) within the process piping. The water or moisture in the air can react with the fluorine and produce hydrogen fluoride gas or hydrofluoric acid (HF) and uranyl fluoride (UO2F2). Uranyl fluoride mainly form a crust or coating inside the process equipment and piping, while hydrogen fluoride gas can disperse in air.
This potential hazard was anticipated in our planning for both deactivation and demolition. The deactivation process included specific chemical and wet air treatments of the uranium enrichment equipment to remove deposits and to react remaining deposits in a controlled system within the building. Following treatments, most of the uranium-containing enrichment equipment, including all converters, all compressors, and all coolers were removed; moreover, all pipes and valves that did not meet rigorous criteria were also removed from the building and shipped for offsite disposal.
The demolition process has also planned for the potential that hydrogen fluoride could be generated in small quantities and isolated in instances. Our workers have buffer distances from active work of 75 feet from size reduction activities and 100 feet from demolition activities. In addition, the Industrial Health technicians for the project are sampling and monitoring for the presence of hydrogen fluoride in the work zone.
Building Demolition
The interior of the building was sprayed with fixative to immobilize any material that could generate dust. In addition, once the siding was taken off, we sprayed fixative through the outside of the building to further immobilize any potential dust. Following that application of fixative, a screen was placed on the exterior to prevent material from entering or leaving the facility. During all that time our particulate monitors and the air monitors were in place and the data have consistently indicated that material did not escape from the building.
The exterior of the building was sprayed with fixative. This fixative is what give the building the blue color in demolition photos. A licensed asbestos contractor removed the exterior material after the fixative was sprayed. The removal was monitored, and in addition, joint OEPA and DOE monitors also sampled for asbestos.
The data reports involving the non-destructive analysis and the deactivation were extensively reviewed by subject matter experts at FBP followed by DOE. Calculations that resulted from those reviews were further reviewed by the ODH with the assistance of independent subject matter experts.
Extensive nuclear safety evaluations of this have been completed. The evaluations were done based on the samples collected during the deactivation of X-326, and postulated if an amount of uranium material did remain and collected in one spot in the landfill, could it cause a criticality? The evaluation determined that it could not cause a criticality. These analyses were reviewed by the OEPA and ODH.
There will be extensive sampling completed as part of the slab removal and any remediation required will be completed.
For the Deferred Units RCRA Facility Investigation (DU RFI) sampling, 10 soil samples were collected at three depth intervals down to the water table (11.33 ft) for a total of 30 samples beneath the X-326 Process Building and 31 soil borings were collected at three depth intervals down to the water table (13.5 ft) for a total of 93 samples around the perimeter of the building, extending out to approximately 20 ft from the foundation. These soil samples were collected in 2016 and analyzed for anions, metals, Polycyclic Aromatic Hydrocarbons (PAHs), Polychlorinated Biphenyl (PCBs), radionuclides, Semi-volatile organic compound (SVOCs) and volatile organic compounds (VOCs). No excavation of soils was required based on the human health screening evaluation. However, elevated concentrations of TCE in groundwater in well X326-09G near the southwest corner of the 326 building further warranted investigation as requested by OEPA. Per discussions with OEPA, a 200 ft by 300 ft excavation of soils from the bottom of the X-326 building concrete slab to the water table in the southwest corner of the building was recommended.
Demo Safety Controls
Wind
When determining wind limits and what conditions might limit operations, the project must consider the type of demolition, the contaminants of concern, and the ability for those contaminants to be transported off-site or out of the project footprint. It is planning and modeling that is unique to each demolition project
The work at Portsmouth involves uranium processing facilities very similar to the work and conditions encountered at the Oak Ridge demolition of uranium facilities, where 15 miles an hour measured 10 meters above ground was successfully implemented.
The demolition at Hanford involved a former plutonium facility and different contaminants than the ones we are monitoring for at Portsmouth. The 15 mile per hour limit at Portsmouth is in alignment with many of the other DOE demolition sites working on similar materials, including Idaho, West Valley, and Paducah. In fact, some areas that have different contaminants of concern have a 25 mile an hour wind speed limit during demolition.
Air Monitoring
All the monitors were in place and operating (continuous and grab sample) prior to the start of transite removal. The X-326 demo project air monitoring network map can be found at https://portsdemo.com/data-education/
The project started sampling at the X-326 project before removal of the first panel of transite, and sampling will continue until demolition has been completed and the waste has been removed. Future projects will include project-specific monitors as well. Site-wide monitoring is planned to continue throughout cleanup and beyond.
The ambient air monitors around the site were installed in the 1990s
The co-located ODH monitors began operations in October 2020.
The co-located OEPA monitors began operations in December 2020.
The air monitors around X-326 began operating in January 2021.
The Intelligent Continuous Air Monitors (ICAMs) around X-326 began operations in April 2021.
Sampling for a wide array of chemical and radiological potential contaminants of concern is underway during demolition. The X-326 project air monitors have detected low levels of Uranium and Technetium-99. The radiological detections up to this point are far below regulatory limits and are below the modeled levels that we estimated in our planning. Thus far, the X-326 monitoring network has not detected any transuranic elements.
We also monitor for chemicals, asbestos, and metals. We have detected polychlorinated biphenyl (PCB), volatile organic compounds, and metals that have exceeded our internal, conservative low-action level, but we have detected no contaminants of concern that approach the project’s medium or high-action levels or regulatory limits.
As an example, a low action level for PCB’s was exceeded. After evaluating we increased our sampling frequency to increase our information of PCB emissions.
We use the monitoring system to give us a quantified indication of how the contamination control systems are working and to give us an early warning if we see signs of any rising levels. The data that we have collected verifies that our contamination control systems are effective at maintaining contamination below regulatory limits that are fully protective of human health and the environment.
Fluor B&W Portsmouth (FBP) is the cleanup contractor. The FBP environmental remediation and protection organizations review the analytical data and real-time particulate matter data. There have been exceedances of an internal, low-action level for heavy metals and PCBs. As a result of these indicators, we increased the sampling for PCBs. We have had no results approach the medium or high action levels for any of the pollutants for which we are monitoring.
If a high action level is exceeded, project management will issue a stop work in conjunction with FBP’s environmental protection organization.
It is important to note is that we are monitoring and responding to these action levels at the project boundary, and a high action level exceedance at a project area monitor does not necessarily mean that that there is an imminent danger at the site boundary or in the community. action levels are established to mitigate the likelihood of offsite consequences during demolition activities.
At low and medium actions levels, the project evaluates the situation and implements operational improvements as necessary. No off-site notifications are made. If a high action level is exceeded, the project will stop work to identify, report and correct the causes immediately upon receipt of the data. Notifications are made to the Ohio Environmental Protection Agency and Pike County Sheriff’s Office.
The data is readily available. The OEPA data is posted on an OEPA website. The ODH data is published on their website. The DOE data will be posted on the DOE X-326 building demolition website. All three sources of data are being posted side by side on a quarterly basis on the PEGASIS website.
Additional Information:
ODH data site:
OEPA data site:
https://epa.ohio.gov/dapc/ams/amsmain/AMSSpecSam-DOE
Combined DOE/OEPA/ODH data (PEGASIS):
The X-326 Demolition project is monitoring the air around the work site for 11 different heavy metals, 8 individual PCB arochlors (types of PCBs) , 9 different radioactive isotopes, total uranium, asbestos fibers, and 20 individual volatile organic compounds. In addition, OEPA and ODH are conducting independent monitoring activities in and around the Portsmouth Site
The ICAMs are large, fixed monitoring stations that are placed around the project boundary to continuously monitor for alpha and beta particulate radioactivity in the ambient air. The ICAM monitors have been in operation around the X-326 demolition project since April 2021.
The X-326 demolition Intelligent Continuous Air Monitors (iCAMs) sample every 15 seconds in a ~50 Liter/min air flow and determine the 5-minute and 20-minute average of Alpha and Beta particulate activity levels in air. The iCAMs immediately activate an alarm when any detected levels reach the preset limits. There are also other air monitors around the X-326 demolition project being used to sample and determine radionuclide-specific concentrations through laboratory analyses with very low detection limits.
The project workers do not wear ICAMs, but they do wear breathing zone sampling units which are analyzed for a variety of parameters based upon the work being performed and the Industrial Hygiene evaluations.
The Portsmouth monitoring network, which was the bulk of the 18 monitors that are at the site perimeter and some of them are off-site, have been in place for over 30 years and that data is published in the Annual Site Environmental Reports. The detector that was near the Zahn’s Corner Middle School was part of that network, and we have data from that sampling point for 30 years. The additional monitors are adjacent to the demolition project to monitor demolition activities. The joint OEPA and ODH monitors have been placed to provide an additional layer of verification. Feedback from the community was considered in the decision to collect independent samples while this project is occurring.
After the Zahn’s Corner Middle School was closed, the Department sent a sampling team in and confirmed no contaminants above any levels of concern were found in the school. Later in discussions with the local community the Department agreed to fund an independent study to do sampling in areas surrounding the PORTS site including a professional risk assessment organization to do a risk assessment associated with that the sample results. The department has funded that study and it's being administered by Ohio University. We are awaiting results of that study.
The Annual Site Environmental Reports (ASERs) documents information related to DOE’s environmental monitoring network and show the locations of air monitors. We'll continue to monitor at locations on and off the Portsmouth Site for specific radioisotopes for the duration of this project. All of the ASERS are available in the environmental information center and links are available on our website.
The X-326 Air Monitoring Plan is a small portion of a much larger X-326 demolition document. The portion containing the information about air monitoring at the X-326 is under Appendix F. This is something that is uploaded in several places on the Frequently Asked Questions, or FAQ, section of portsdemo.com
The monitoring plan is at:
https://portsdemo.com/wp-content/uploads/2021/10/X-326-DDP-D5R9_App-F_Air-Monitor-Plan_2-10-21.pd
Demolition workers are required to wear TLDs that can record exposures to all types of radiation including Gamma, Beta, Alpha, and Neutron. Although the iCAMs only monitor Alpha and Beta activities in air, other air monitors are being used around the project to monitor all of the X-326 radiological contaminants of concern
We have tested and sampled repeatedly following these odor events, but we have not yet isolated what these odors might be or where they are coming from.
We have moved to an improved Air Purifying Respirator Cartridge for the Transite Removal work to filter out volatile organic compounds (VOCs) in addition to High Efficiency Particulate Air, or HEPA filters. And we are continuing with the active Industrial Health program and Air Monitoring systems to gather information. We will continue to investigate and identify unusual odors as they occur.
Natural background radiation varies quite a lot across the United States because of the underlying geology, land elevation and a number of other factors. Fallout is another small contributor to our background radiation dose. Department of Energy sites across the country, as part of their Annual Site Environmental Reports provide some of this information and those reports are available to the public. The general understanding of what contributes to background and fallout is that the dose is quite variable across the country and from region to region.
Transuranic material, gamma, and neutron radiation need to be evaluated, and our project includes these capabilities. Transuranic isotopes as well as all types of ionizing radiation are being monitored in both the X-326 project and site-wide air monitoring systems.
Not all radiological monitoring approaches are real time. The iCAM, Hi-Vol air monitors, Low-Vol air monitors, TLDs, and hand-held meters are included in various monitoring systems to provide monitoring data for a wide range of evaluations.
Water
Controlling dust and particles that can become airborne is a key safety consideration during demolition. The area where workers are doing shearing has already been coated with fixative, which gives the X-326 structure the blue color. Misters and foggers are specialized equipment that distribute fine atomized mist of water over an area to adhere on dust particles causing them to fall. Water cannons direct a spray of water over a distance to a specific point. Misting and fogging is a science, and the X-326 demolition is using the lessons learned and best practices from other demolition projects in the complex. The foggers blanket the area with a steady mist that prevents dust from leaving the demolition area. Directing the water foggers directly at the shear site could actually spread contamination and would not create the fogging effect needed to capture dust particles over a wider area. Equipment operators capture the dust with the mist and let it fall to the ground as opposed to having it spread beyond the worksite. Results from our sampling data has shown dust (particulate matter) and radiological samples are all below actionable limits. We set actionable limits to ensure we keep exposures to a minimum, below regulatory limits which are fully protective of human health and the environment.
The data collected demonstrates that water fogging, and sprays and the demolition approach are effective for addressing dust and particulate matter.
The project has created a berm surrounding the building to collect water from the demolition site. That berm is lined with an impermeable liner that's been leak tested. It's like the liner that we use at the OSWDF and the water is collected in sumps – pits in which water collect - so none of the material that runs off the slab has a chance to be absorbed in the ground.
The berm surrounds the entire building and water collected from it goes to the treatment center and then permitted outfall.
Following the prescribed treatment, the water associated with the X-326 demolition is being discharged to the National Pollutant Discharge Elimination System (NPDES) Permit location #004 which discharges to the Scioto River. This location is monitored in accordance with the NPDES permit.
Any dust that may be generated during the demolition process is captured by the water mist/fog and falls to the ground. If it lands on other debris, it would be immobilized by the fixative that is applied daily and removed with the debris taken to the OSWDF. If it is contained in the water that runs off the slab, it is collected in the berm and transported to the water treatment facility and processed prior to discharge to our permitted outfall.
Groundwater is being monitored for contaminants associated with the X-326 Process Building above-grade demolition, in nearby wells east, west, and north of the building footprint. Five existing monitoring wells are being sampled for total metals, PCBs, and radionuclides (total uranium, isotopic uranium, and technetium-99).
DOE is using the best practices and lessons learned from the safe and compliant demolition of hundreds of radiologically contaminated facilities over the past 30 years. The facilities most analogous to the Portsmouth site is the Oak Ridge site. The K25 plant in Oak Ridge, in which five uranium enrichment buildings were demolished while using similar controls and wind speeds, occurred without issues.
The demolition approach, training, oversight, and controls in place at X-326 are equally protective to measures taken for demolitions at other cleanup sites. The project is using the best practices and lessons learned from three decades of demolition experience in the DOE complex. This approach, combined with regulatory limits, conservative safety controls, and stringent oversight, enable safe operations at the site.
OnSite Waste Disposal Facility (OSWDF)
Some of the debris is not packaged for disposal. Asbestos containing waste such as transite material is packaged by procedure. It is double wrapped, emplaced, and forms the base for specific grids within the On-Site Waste Disposal Facility (OSWDF). The other debris is placed in trucks that are certified leak proof and tested regularly, covered with a tarp, and sealed. The material is transferred into the cell in the OSWDF using a ramp. When that material is placed in the OSWDF, foggers are used to control dust.
Construction landfills are typically not required to cover debris daily because they do not attract animals. The OSWDF is not required to be covered. However, as an enhanced safety measure DOE chose to apply a waterproof fixative to immobilize any material. This is done at the close of operations each day. Tarping was also evaluated but the potential for tearing due to irregular debris and escaping dust due daily tarp movement drove the decision towards fixative application.
Contaminated water will continue to be generated and treated throughout the operational lifetime of the cell and into post-closure when all the cells are capped. Treatment will be provided until no observable water is captured for treatment.
A40. DOE conducted a structured public engagement process from 2011-2014, including public meetings and an extended formal public comment period for the proposed plan.
Community Outreach
Communications will be ongoing. The Department of Energy (DOE) launched the demolition website at www.portsdemo.com, and held the first two meetings with the public in October. DOE will continue to update the website and hold regular public meetings to present data, provide information, and answer questions. Feedback and input from the community on the frequency these meetings and the level of information provided at the meetings and on the website is important so that the Department can meet the community’s information needs. We invite feedback from the community at ports-demo-questions@pppo.gov.
In addition, we will work with our regulators to post data on a regular basis. The data is currently available at the following locations:
Ohio Department of Health (ODH) data site:
Ohio Environmental Protection Agency (OEPA) data site:
https://epa.ohio.gov/dapc/ams/amsmain/AMSSpecSam-DOE
Combined DOE/OEPA/ODH data (PEGASIS) (quarterly):
https://pegasis.ports.pppo.gov/Pegasis/Default.aspx
In addition, the process monitoring data will be available at the 326 demolition website:
Other
The Department takes COVID very seriously and we have extensive protocols in place to protect workers. While there have been COVID cases amongst our workforce, there is no indication from contact tracing that any transmissions have occurred onsite. COVID cases onsite have ranged from 0 up to the high 20s. We also have workers in quarantine because of close contact with a COVID-positive worker or family member. There have been no COVID deaths associated with site transmissions. Out of respect to the families and privacy constraints, we do not provide information on COVID-related deaths.
As an added safety precaution, the northern portion of the perimeter road has been blocked off at the point where it crosses the haul road. This was to prevent possible automobile accidents with our transport trucks. In addition, we’ve also closed off what is known as Fog Road until we build an overpass. Initially, operations started with gates that were closed when a truck crossed. The site received complaints because the closings did not occur at a consistent time and caused delays. The decision was made to shut the road down from 7:00 a.m. until 7:00 p.m. so that commuters can plan accordingly.