WESKEM was awarded the multi-million dollar, multi-year contract to provide the characterization and cleanup of 160 Department of Energy Material Storage Areas (DMSAs) at the Paducah, KY site. WESKEM provided characterization and remediation activities that were required to properly manage, inventory, package, ship, and track all waste types that were stored in these multiple areas. An accurate and complete DMSA inventory did not exist when WESKEM, and its subcontractors started the cleanup project. Previous waste document entries and discussions with subject matter experts typically having over 20 to 30 years plant experience were still able to identify:

• Surplus equipment, parts, and materials
 • Low-level radioactive wastes
 • Resource Conservation and Recovery Act (RCRA) materials
 • Polychlorinated biphenyl (PCB) wastes
 • Asbestos

These preliminary data gathering efforts provided sufficient information to determine the DMSAs could be categorized in one of three ways:

 1. Items expected to have no fissionable material, but not fully characterized.
 2. Items possibly containing fissionable material.
 3. Items characterized for storage and containing no fissionable materials.

A graded approach to determine the project scope was used consisting of the following elements:

 • Initial assessment (i.e., field walk down)
 • Preparation of specific work package (i.e., Integrated Safety Management or ISM)
 • Activity Hazard Review (AHR)/Activity Hazard Analysis (AHA)
 • Choosing the appropriate personal protective equipment (PPE)
 • Field mobilization
 • Conducting visual inventories
 • Collecting industrial hygiene and radiological monitoring information
 • Performing nuclear criticality assessments
• Taking video or pictures where possible
 • Addressing waste management issues
 • Field demobilization
 • Report generation and submittal

WESKEM used the information collected to assess and understand the known and suspect hazards in each DMSA. We also used the information to perform the required characterization activities for reuse, off-site shipment and ultimate disposal in accordance with site-specific regulations and waste acceptance criteria.

Due to the presence of unknown hazardous materials, the DMSAs were subject to Title 29 of the Code of Federal Regulations, Part 1910.120 (29 CFR 1910.120), Hazardous Waste Operations and Emergency Response (HAZWOPER) regulations. According to the definitions found in 29 CFR 1910.120(a)(3), this activity was classified as a cleanup operation. A cleanup operation means an operation where hazardous substances were removed, contained, incinerated, neutralized, stabilized, cleared-up, or in any other manner processed or handled with the ultimate goal of making the site safer for people or the environment.

The site hazardous waste program organizational structure defined and provided for a site safety and health officer (SSHO). The SSHO was located on the hazardous waste site and was responsible to the client for implementing the site safety and health plan and verify compliance with applicable safety and health requirements.

Because so many cleanup sites were included in the project scope, involving multiple SSHOs each with their individual record keeping styles, WESKEM developed four standardized logbook templates that were implemented using the DOE’s Integrated Safety Management System (ISMS) for consistent record keeping across 160 DSMA HAZWOPER sites. A total of 55 DMSAs were characterized and two were eliminated.