Environmental Impact

Statement for the Proposed 

Eagle Rock Enrichment Facility 

in Bonneville County, Idaho

Final Report

Chapters 1 through 10

Office of Federal and State Materials and

Environmental Management Programs

NUREG-1945, Vol. 1
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Environmental Impact 

Statement for the Proposed 

Eagle Rock Enrichment Facility 

in Bonneville County, Idaho 

Final Report 

Chapters 1 through 10 

Manuscript Completed: February 2011 

Date Published: February 2011 

Office of Federal and State Materials and 

 Environmental Management Programs 

NUREG-1945, Vol. 1

 iii 

1 ABSTRACT 

2 

3 On December 30, 2008, AREVA Enrichment Services LLC (AES) submitted an application to 

4 the U.S. Nuclear Regulatory Commission (NRC) for a license to construct, operate, and 

5 decommission the proposed Eagle Rock Enrichment Facility (EREF). The proposed EREF 

6 would be located in Bonneville County, Idaho, approximately 32 kilometers (20 miles) west of 

7 Idaho Falls. Revisions to the license application were submitted by AES on April 23, 2009, and 

8 April 30, 2010. If licensed, the proposed facility would enrich uranium for use in commercial 

9 nuclear fuel for power reactors. AES would employ a gas centrifuge enrichment process to 

10 enrich uranium to up to five percent uranium-235 by weight, with a planned maximum target 

11 production of 6.6 million separative work units (SWUs) per year. AES initiated preconstruction 

12 activities (e.g., site preparation) in late 2010 under an exemption approved by the NRC to 

13 conduct such activities prior to licensing. If its license application is approved, AES expects to 

14 begin facility construction in 2011and commence initial production in 2014, reaching peak 

15 production in 2022. AES’s license would be for a term of 30 years. Prior to license expiration in 

16 2041, AES would seek to renew its license to continue operating the proposed facility or plan for 

17 the decontamination and decommissioning of the proposed facility per the applicable licensing 

18 conditions and NRC regulations. The proposed EREF would be licensed in accordance with the 

19 provisions of the Atomic Energy Act. Specifically, an NRC license under Title 10, “Energy,” of 

20 the U.S. Code of Federal Regulations (10 CFR) Parts 30, 40, and 70 would be required to 

21 authorize AES to possess and use special nuclear material, source material, and byproduct 

22 material at the proposed EREF site. 

23 

24 This Environmental Impact Statement (NUREG-1945) (EIS) was prepared in compliance with 

25 the National Environmental Policy Act of 1969, as amended (NEPA), and the NRC regulations 

26 for implementing NEPA (10 CFR Part 51). This EIS evaluates the potential environmental 

27 impacts of preconstruction activities and of the proposed action, which is to construct, operate, 

28 and decommission the proposed EREF near Idaho Falls in Bonneville County, Idaho. Also, this 

29 EIS describes the environment potentially affected by AES’s proposal, evaluates reasonable 

30 alternatives to the proposed action, describes AES’s environmental monitoring program and 

31 mitigation measures, and evaluates the costs and benefits of the proposed action. 

32 

33 Paperwork Reduction Act Statement 

34 

35 This NUREG contains and references information collection requirements that are subject to the 

36 Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were 

37 approved by the Office of Management and Budget, approval numbers 3150-0014, 3150-0017, 

38 3150-0020, 3150-0009, 3150-0002, 3150-0123, and 3150-0047. 

39 

40 Public Protection Notification 

41 

42 The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 

43 information or an information collection requirement unless the requesting document displays a 

44 currently valid OMB control number. 

45 

NUREG-1945 has been reproduced from 

the best available copy.

 v 

1 CONTENTS 

2 

3 ABSTRACT ............................................................................................................................ iii 

4 

5 EXECUTIVE SUMMARY ....................................................................................................... xxvii 

6 

7 ACRONYMS AND ABBREVIATIONS .................................................................................... xlvii 

8 

9 1 INTRODUCTION .............................................................................................................. 1-1

10 

11 1.1 Background .............................................................................................................. 1-1

12 1.2 The Proposed Action ............................................................................................... 1-1

13 1.3 Purpose and Need for the Proposed Action ............................................................ 1-3

14 1.3.1 The Need for Enriched Uranium to Fulfill Electricity Requirements .............. 1-4

15 1.3.2 The Need for Domestic Supplies of Enriched Uranium for National 

16 Energy Security ............................................................................................. 1-7

17 1.4 Scope of the Environmental Analysis ...................................................................... 1-8

18 1.4.1 Scope of the Proposed Action ....................................................................... 1-8 

19 1.4.2 Scoping Process and Public Participation Activities ...................................... 1-11

20 1.4.3 Issues Studied in Detail ................................................................................. 1-11

21 1.4.4 Issues Eliminated from Detailed Study .......................................................... 1-12

22 1.4.5 Issues Outside the Scope of the EIS ............................................................. 1-12

23 1.4.6 Draft EIS Public Comment Period and Public Participation Activities ........... 1-14 

24 1.4.7 Changes from the Draft EIS .......................................................................... 1-14 

25 1.4.8 Related Relevant Documents ........................................................................ 1-17 

26 1.5 Applicable Statutory and Regulatory Requirements ................................................ 1-19

27 1.5.1 Applicable State of Idaho Requirements ....................................................... 1-19

28 1.5.2 Permit and Approval Status........................................................................... 1-19

29 1.5.3 Cooperating Agencies ................................................................................... 1-19

30 1.5.4 Consultations ................................................................................................ 1-19

31 1.5.4.1 Endangered Species Act of 1973 Consultation ............................. 1-24

32 1.5.4.2 National Historic Preservation Act of 1966 Section 106 

33 Consultation ................................................................................... 1-25

34 1.6 Organizations Involved in the Proposed Action ....................................................... 1-27

35 1.7 References .............................................................................................................. 1-27

36 

37 2 ALTERNATIVES .............................................................................................................. 2-1

38 

39 2.1 Proposed Action ...................................................................................................... 2-1

40 2.1.1 Location and Description of the Proposed Site and Vicinity .......................... 2-2

41 2.1.2 Gas Centrifuge Enrichment Process ............................................................. 2-4

42 2.1.3 Description of the Proposed Eagle Rock Enrichment Facility ....................... 2-5

43 2.1.3.1 Major Facility Buildings and Structures .......................................... 2-7

44 2.1.3.2 Utilities ........................................................................................... 2-12

45 2.1.3.3 Local Road Network ....................................................................... 2-12

46 
 vi 

1 CONTENTS (Cont.) 

2 

3 2.1.4 Description of the Phases of the Proposed Action ........................................ 2-13

4 2.1.4.1 Preconstruction and Construction Activities ................................... 2-14

5 2.1.4.2 Facility Operation ........................................................................... 2-15

6 2.1.4.3 Decontamination and Decommissioning ........................................ 2-21

7 2.1.5 Depleted Uranium Management ................................................................... 2-24

8 2.1.5.1 Conversion of Depleted UF6 .......................................................... 2-25 

9 2.1.5.2 Disposal of Depleted Uranium ....................................................... 2-26 

10 2.2 No-Action Alternative ............................................................................................... 2-26

11 2.3 Alternatives Considered but Eliminated ................................................................... 2-27

12 2.3.1 Alternative Sites ............................................................................................ 2-28

13 2.3.1.1 Identification of Regions and Sites ................................................. 2-28

14 2.3.1.2 Screen Candidate Sites (Phase I) .................................................. 2-29

15 2.3.1.3 Site Evaluation (Phase II) .............................................................. 2-29

16 2.3.1.4 Preferred Site Identification ............................................................ 2-29

17 2.3.2 Alternative Sources of Low-Enriched Uranium .............................................. 2-32

18 2.3.2.1 Re-Activate the Portsmouth Gaseous Diffusion Facility at 

19 Piketon ........................................................................................... 2-32

20 2.3.2.2 Downblending Highly Enriched Uranium ....................................... 2-33

21 2.3.2.3 Purchase Low-Enriched Uranium from Foreign Sources ............... 2-33

22 2.3.3 Alternative Technologies for Enrichment ....................................................... 2-39

23 2.3.3.1 Electromagnetic Isotope Separation Process ................................ 2-39

24 2.3.3.2 Liquid Thermal Diffusion ................................................................ 2-40

25 2.3.3.3 Gaseous Diffusion Process ............................................................ 2-40

26 2.3.3.4 Atomic Vapor Laser Isotope Separation ........................................ 2-41

27 2.3.3.5 Molecular Laser Isotope Separation .............................................. 2-41

28 2.3.3.6 Separation of Isotopes by Laser Excitation .................................... 2-42

29 2.4 Summary and Comparison of Predicted Environmental Impacts ............................ 2-42

30 2.5 Staff Recommendation Regarding the Proposed Action ......................................... 2-65

31 2.6 References .............................................................................................................. 2-65

32 

33 3 AFFECTED ENVIRONMENT ........................................................................................... 3-1

34 

35 3.1 Site Location and Description .................................................................................. 3-1

36 3.2 Land Use ................................................................................................................. 3-1

37 3.2.1 Bonneville County and Proposed EREF Property ......................................... 3-3

38 3.2.2 Bingham County ............................................................................................ 3-5

39 3.2.3 Jefferson County ........................................................................................... 3-5

40 3.2.4 Special Land Use Classification Areas .......................................................... 3-5

41 3.3 Historic and Cultural Resources .............................................................................. 3-6

42 3.3.1 Prehistoric ..................................................................................................... 3-6

43 3.3.2 Protohistoric and Historic Indian Tribes ......................................................... 3-6

44 3.3.3 Historic Euro-American ................................................................................. 3-7

45 
 vii 

1 CONTENTS (Cont.) 

2 

3 3.3.4 Historic and Archaeological Resources in the Vicinity 

4 of the Proposed Site ...................................................................................... 3-7

5 3.4 Visual and Scenic Resources .................................................................................. 3-8

6 3.5 Climatology, Meteorology, and Air Quality ............................................................... 3-15

7 3.5.1 Climatology ................................................................................................... 3-15 

8 3.5.1.1 Idaho .............................................................................................. 3-15

9 3.5.1.2 Proposed EREF Site ...................................................................... 3-15

10 3.5.2 EREF Site Meteorology ................................................................................. 3-15

11 3.5.2.1 Temperature .................................................................................. 3-16

12 3.5.2.2 Precipitation and Relative Humidity ............................................... 3-16

13 3.5.2.3 Winds, Atmospheric Stability, and Temperature Inversions .......... 3-21

14 3.5.2.4 Severe Weather Conditions ........................................................... 3-24

15 3.5.2.5 Mixing Heights ............................................................................... 3-27

16 3.5.3 Air Quality ...................................................................................................... 3-28

17 3.5.3.1 Regional Air Quality ....................................................................... 3-30

18 3.5.3.2 Criteria Pollutant Emissions ........................................................... 3-30

19 3.5.3.3 Nonattainment and Maintenance Areas ......................................... 3-33

20 3.5.3.4 Prevention of Significant Deterioration ........................................... 3-34

21 3.5.3.5 Conformity ...................................................................................... 3-34

22 3.6 Geology, Minerals, and Soil ..................................................................................... 3-34

23 3.6.1 Regional Geology .......................................................................................... 3-35

24 3.6.1.1 Seismic Setting, Earthquakes, and Volcanic Activity ..................... 3-38

25 3.6.1.2 Mineral and Energy Resources ...................................................... 3-42

26 3.6.2 Site Geology .................................................................................................. 3-44

27 3.6.3 Site Soils ....................................................................................................... 3-45

28 3.6.4 Soil Radiological and Chemical Characteristics ............................................ 3-45

29 3.6.4.1 Soil Radiological Characteristics .................................................... 3-45

30 3.6.4.2 Soil Chemical Characteristics ........................................................ 3-48

31 3.7 Water Resources ..................................................................................................... 3-48

32 3.7.1 Surface Water Features ................................................................................ 3-48

33 3.7.1.1 Rivers, Streams, and Lakes ........................................................... 3-48

34 3.7.1.2 Wetlands ........................................................................................ 3-51

35 3.7.1.3 Floodplains ..................................................................................... 3-51

36 3.7.2 Groundwater Resources ............................................................................... 3-55

37 3.7.2.1 Regional Hydrogeology .................................................................. 3-55

38 3.7.2.2 Site Hydrogeology .......................................................................... 3-56

39 3.7.2.3 Groundwater Use ........................................................................... 3-57

40 3.7.2.4 Groundwater Quality ...................................................................... 3-60

41 3.8 Ecological Resources .............................................................................................. 3-61

42 3.8.1 Plant Communities ........................................................................................ 3-61

43 3.8.2 Wildlife ........................................................................................................... 3-63

44 3.8.3 Rare, Threatened, and Endangered Species ................................................ 3-70

45 3.8.4 Wetlands ....................................................................................................... 3-73

46 
 viii 

1 CONTENTS (Cont.) 

2 

3 3.8.5 Environmentally Sensitive Areas ................................................................... 3-73

4 3.9 Noise ........................................................................................................................ 3-73

5 3.9.1 Expected Sound Propagation Characteristics at the Proposed EREF Site ... 3-74

6 3.9.2 Existing Sound Sources and Potential Receptors at the Proposed 

7 EREF Site ..................................................................................................... 3-74

8 3.9.3 Noise Regulatory Controls ............................................................................ 3-75

9 3.9.4 Noise Analyses Performed for the Proposed EREF ...................................... 3-76

10 3.10 Transportation .......................................................................................................... 3-77

11 3.10.1 Roads ........................................................................................................... 3-77

12 3.10.2 Rail ................................................................................................................ 3-82

13 3.10.3 Air ................................................................................................................. 3-82 

14 3.10.4 Water ............................................................................................................ 3-82

15 3.11 Public and Occupational Health ............................................................................... 3-82

16 3.11.1 Background Radiological Exposure .............................................................. 3-83

17 3.11.1.1 General Background Radiation ...................................................... 3-83

18 3.11.1.2 Idaho National Laboratory .............................................................. 3-84

19 3.11.2 Background Chemical Exposure ................................................................... 3-85

20 3.11.3 Public Health Studies .................................................................................... 3-85

21 3.11.3.1 Regulatory Requirements for Public and Occupational 

22 Exposure ........................................................................................ 3-85

23 3.11.3.2 Health Effects from Radiological Exposure .................................... 3-86

24 3.11.3.3 Health Effects from Chemical Exposure ........................................ 3-87

25 3.12 Socioeconomics ....................................................................................................... 3-88

26 3.12.1Population Characteristics ............................................................................. 3-88

27 3.12.1.1 Major Population Centers .............................................................. 3-88

28 3.12.1.2 Population Growth Trends ............................................................. 3-89

29 3.12.1.3 Transient and Special Populations ................................................ 3-89

30 3.12.2Economic Trends and Characteristics ........................................................... 3-89

31 3.12.2.1 Employment ................................................................................... 3-89

32 3.12.2.2 Unemployment ............................................................................... 3-89

33 3.12.2.3 Income ........................................................................................... 3-90

34 3.12.3 Housing Resources and Community and Social Services ............................ 3-90

35 3.12.3.1 Housing .......................................................................................... 3-93

36 3.12.3.2 Schools .......................................................................................... 3-93

37 3.12.3.3 Public Safety .................................................................................. 3-93

38 3.12.4 Tax Structure and Distribution ....................................................................... 3-95

39 3.13 Environmental Justice .............................................................................................. 3-95

40 3.13.1 Minority Populations ..................................................................................... 3-96

41 3.13.2 Low-Income Populations............................................................................... 3-97 

42 3.13.3 Resource Dependencies and Vulnerabilities of Minority 

43 and Low-Income Populations ........................................................................ 3-97

44 3.14 References .............................................................................................................. 3-99

45 

46 
 ix 

1 CONTENTS (Cont.) 

2 

3 4 ENVIRONMENTAL IMPACTS ......................................................................................... 4-1

4 

5 4.1 Introduction .............................................................................................................. 4-1

6 4.2 Potential Impacts of Preconstruction and the Proposed Action ............................... 4-2

7 4.2.1 Land Use Impacts ......................................................................................... 4-3

8 4.2.1.1 Preconstruction and Construction .................................................. 4-3

9 4.2.1.2 Facility Operation ........................................................................... 4-4

10 4.2.1.3 Mitigation Measures ....................................................................... 4-4

11 4.2.2 Historic and Cultural Resources Impacts ...................................................... 4-4

12 4.2.2.1 Preconstruction and Construction .................................................. 4-5

13 4.2.2.2 Facility Operation ........................................................................... 4-7

14 4.2.2.3 Mitigation Measures ....................................................................... 4-7

15 4.2.3 Visual and Scenic Impacts ............................................................................ 4-8

16 4.2.3.1 Preconstruction and Construction .................................................. 4-8

17 4.2.3.2 Facility Operation ........................................................................... 4-10

18 4.2.3.3 Mitigation Measures ....................................................................... 4-11

19 4.2.4 Air Quality Impacts ........................................................................................ 4-11

20 4.2.4.1 Preconstruction and Construction .................................................. 4-12

21 4.2.4.2 Facility Operation ........................................................................... 4-22

22 4.2.4.3 Mitigation Measures ....................................................................... 4-29

23 4.2.5 Geology and Soil Impacts ............................................................................. 4-31

24 4.2.5.1 Preconstruction and Construction .................................................. 4-31

25 4.2.5.2 Facility Operation ........................................................................... 4-33

26 4.2.5.3 Mitigation Measures ....................................................................... 4-34

27 4.2.6 Water Resources Impacts ............................................................................. 4-34

28 4.2.6.1 Preconstruction and Construction .................................................. 4-35

29 4.2.6.2 Facility Operation ........................................................................... 4-38

30 4.2.6.3 Mitigation Measures ....................................................................... 4-44

31 4.2.7 Ecological Impacts ........................................................................................ 4-45

32 4.2.7.1 Preconstruction and Construction .................................................. 4-46

33 4.2.7.2 Facility Operation ........................................................................... 4-54

34 4.2.7.3 Mitigation Measures ....................................................................... 4-55

35 4.2.8 Noise Impacts ............................................................................................... 4-57

36 4.2.8.1 Preconstruction and Construction .................................................. 4-58

37 4.2.8.2 Facility Operation ........................................................................... 4-62

38 4.2.8.3 Mitigation Measures ....................................................................... 4-63

39 4.2.9 Transportation Impacts.................................................................................. 4-65

40 4.2.9.1 Preconstruction and Construction .................................................. 4-65

41 4.2.9.2 Facility Operation ........................................................................... 4-67

42 4.2.9.3 Mitigation Measures ....................................................................... 4-74

43 4.2.10Public and Occupational Health Impacts ....................................................... 4-75

44 4.2.10.1 Preconstruction and Construction .................................................. 4-76

45 4.2.10.2 Facility Operation ........................................................................... 4-77

46 
 x 

1 CONTENTS (Cont.) 

2 

3 4.2.10.3 Mitigation Measures ....................................................................... 4-86

4 4.2.11 Waste Management Impacts ......................................................................... 4-91

5 4.2.11.1 Preconstruction and Construction .................................................. 4-91

6 4.2.11.2 Facility Operation ........................................................................... 4-93

7 4.2.11.3 Mitigation Measures ....................................................................... 4-98

8 4.2.12Socioeconomic Impacts ................................................................................ 4-101

9 4.2.12.1 Methodology .................................................................................. 4-102

10 4.2.12.2 Preconstruction and Construction .................................................. 4-103

11 4.2.12.3 Facility Operation ........................................................................... 4-105 

12 4.2.12.4 Potential Effect on Property Values ............................................... 4-107 

13 4.2.13Environmental Justice Impacts ...................................................................... 4-108

14 4.2.14Separation of Preconstruction and Construction Impacts ............................. 4-111

15 4.2.15Accident Impacts ........................................................................................... 4-111

16 4.2.15.1 Accidents Considered .................................................................... 4-111

17 4.2.15.2 Accident Consequences ................................................................ 4-117

18 4.2.15.3 Mitigation Measures ....................................................................... 4-120

19 4.2.16 Decontamination and Decommissioning Impacts ......................................... 4-120

20 4.2.16.1 Land Use ........................................................................................ 4-122

21 4.2.16.2 Historic and Cultural Resources .................................................... 4-122

22 4.2.16.3 Visual and Scenic Resources ........................................................ 4-122

23 4.2.16.4 Air Quality ...................................................................................... 4-122

24 4.2.16.5 Geology and Soils .......................................................................... 4-123

25 4.2.16.6 Water Resources ........................................................................... 4-123

26 4.2.16.7 Ecological Resources .................................................................... 4-124

27 4.2.16.8 Noise .............................................................................................. 4-124

28 4.2.16.9 Transportation ................................................................................ 4-124

29 4.2.16.10 Public and Occupational Health ..................................................... 4-125

30 4.2.16.11 Waste Management ....................................................................... 4-126

31 4.2.16.12Socioeconomics ............................................................................. 4-126

32 4.2.16.13Environmental Justice .................................................................... 4-126

33 4.2.16.14Mitigation Measures ....................................................................... 4-127

34 4.2.17 Greenhouse Gas Emissions Associated with the Proposed EREF ............... 4-127

35 4.2.17.1 Greenhouse Gases ........................................................................ 4-127

36 4.2.17.2 Greenhouse Gas Emissions and Sinks in the United States ......... 4-128

37 4.2.17.3 Greenhouse Gas Emissions and Sinks in Idaho ............................ 4-130

38 4.2.17.4 Projected Impacts from the Preconstruction, Construction, 

39 Operation, and Decommissioning of the Proposed EREF 

40 on Carbon Dioxide and Other Greenhouse Gases ........................ 4-130 

41 4.2.18 Terrorism Consideration ................................................................................ 4-142 

42 4.2.18.1 Background Information ................................................................. 4-142

43 4.2.18.2 Potential Impacts of Terrorist Events ............................................. 4-142 

44 4.2.18.3 Mitigative Measures ....................................................................... 4-146 

45 4.3 Cumulative Impacts ................................................................................................. 4-147

46 
 xi 

1 CONTENTS (Cont.) 

2 

3 4.3.1 Land Use ....................................................................................................... 4-149

4 4.3.2 Historic and Cultural Resources .................................................................... 4-149

5 4.3.3 Visual and Scenic Resources ........................................................................ 4-150

6 4.3.4 Air Quality ...................................................................................................... 4-150

7 4.3.5 Geology and Soils ......................................................................................... 4-152

8 4.3.6 Water Resources........................................................................................... 4-152

9 4.3.7 Ecology ......................................................................................................... 4-154

10 4.3.8 Noise ............................................................................................................. 4-157

11 4.3.9 Transportation ............................................................................................... 4-157

12 4.3.10Public and Occupational Health .................................................................... 4-158

13 4.3.11 Waste Management ...................................................................................... 4-158

14 4.3.12Socioeconomics ............................................................................................ 4-159

15 4.3.13Environmental Justice ................................................................................... 4-159

16 4.4 Impacts of the No-Action Alternative........................................................................ 4-160

17 4.4.1 Land Use ....................................................................................................... 4-162

18 4.4.2 Historic and Cultural Resources .................................................................... 4-162

19 4.4.3 Visual and Scenic Resources ........................................................................ 4-162

20 4.4.4 Air Quality ...................................................................................................... 4-162

21 4.4.5 Geology and Soils ......................................................................................... 4-162

22 4.4.6 Water Resources........................................................................................... 4-163

23 4.4.7 Ecological Resources .................................................................................... 4-163

24 4.4.8 Noise ............................................................................................................. 4-163

25 4.4.9 Transportation ............................................................................................... 4-163

26 4.4.10Public and Occupational Health .................................................................... 4-163

27 4.4.11 Waste Management ...................................................................................... 4-163

28 4.4.12 Socioeconomics ............................................................................................ 4-164

29 4.4.13 Environmental Justice ................................................................................... 4-164

30 4.4.14 Accidents ....................................................................................................... 4-164

31 4.5 References .............................................................................................................. 4-164

32 

33 5 MITIGATION .................................................................................................................... 5-1

34 

35 5.1 Mitigation Measures Identified by AES .................................................................... 5-1

36 5.2 Potential Mitigation Measures Identified by the NRC ............................................... 5-21

37 5.3 References .............................................................................................................. 5-21

38 

39 6 ENVIRONMENTAL MEASUREMENT AND MONITORING PROGRAMS ...................... 6-1

40 

41 6.1 Radiological Measurements and Monitoring Program ............................................. 6-1

42 6.1.1 Air Emissions Monitoring ............................................................................... 6-2

43 6.1.2 Ambient Air Quality Monitoring ...................................................................... 6-6

44 6.1.3 Wastewater Discharge Monitoring ................................................................ 6-7

45 6.1.4 Stormwater and Basin Sediment Monitoring ................................................. 6-8

46 
 xii 

1 CONTENTS (Cont.) 

2 

3 6.1.5 Groundwater Monitoring ................................................................................ 6-9

4 6.1.6 Soil and Vegetation Sampling ....................................................................... 6-10

5 6.1.7 Direct Gamma Radiation Monitoring ............................................................. 6-10

6 6.1.8 Monitoring Procedures and Laboratory Standards ........................................ 6-10 

7 6.1.9 Reporting ....................................................................................................... 6-11

8 6.2 Nonradiological Measurements and Monitoring Program ........................................ 6-11

9 6.2.1 Physiochemical Monitoring............................................................................ 6-12

10 6.2.1.1 Liquid Effluent Monitoring .............................................................. 6-15

11 6.2.1.2 Stormwater Monitoring ................................................................... 6-15

12 6.2.1.3 Environmental Monitoring .............................................................. 6-16

13 6.2.1.4 Meteorological Monitoring .............................................................. 6-17

14 6.2.1.5 Local Flora and Fauna ................................................................... 6-17

15 6.2.1.6 Quality Assurance .......................................................................... 6-17

16 6.2.2 Ecological Monitoring .................................................................................... 6-18

17 6.2.2.1 Monitoring Program Elements ....................................................... 6-18

18 6.2.2.2 Observations and Monitoring Program Design .............................. 6-19

19 6.3 References .............................................................................................................. 6-24

20 

21 7 BENEFIT-COST ANALYSIS ............................................................................................ 7-1

22 

23 7.1 Costs and Benefits of Preconstruction and the Proposed Action ............................ 7-2

24 7.1.1 Costs of Preconstruction and the Proposed Action ....................................... 7-2

25 7.1.2 Benefits of the Proposed Action .................................................................... 7-6

26 7.1.3 Summary Regarding the Proposed Action .................................................... 7-7

27 7.2 Comparative Benefit-Cost Analysis of Proposed Action Relative to No-Action 

28 Alternative ................................................................................................................ 7-7

29 7.2.1 No-Action Alternative..................................................................................... 7-8

30 7.2.2 The Proposed Action ..................................................................................... 7-8

31 7.2.3 Compliance with Policy and Technical Objectives ........................................ 7-8 

32 7.2.3.1 Meeting Demand for Enriched Uranium ......................................... 7-9

33 7.2.3.2 National Energy Security ............................................................... 7-9

34 7.2.3.3 Technology Upgrade ...................................................................... 7-10 

35 7.2.3.4 Energy Generation with Fewer Emissions 

36 of Criteria Pollutants and Carbon ................................................... 7-10

37 7.2.4 Conclusions Regarding the Proposed Action versus the No-Action 

38 Alternative ..................................................................................................... 7-10

39 7.3 Overall Benefit-Cost Conclusions ............................................................................ 7-10 

40 7.4 References .............................................................................................................. 7-11 

41 

42 8 SUMMARY OF ENVIRONMENTAL CONSEQUENCES ................................................. 8-1

43 

44 8.1 Unavoidable Adverse Environmental Impacts ......................................................... 8-3

45 
 xiii 

1 CONTENTS (Cont.) 

2 

3 8.2 Relationship between Local Short-Term Uses of the Environment and the 

4 Maintenance and Enhancement of Long-Term Productivity .................................... 8-4

5 8.3 Irreversible and Irretrievable Commitment of Resources ......................................... 8-5 

6 8.4 References .............................................................................................................. 8-7 

7 

8 9 AGENCIES AND ORGANIZATIONS CONSULTED ........................................................ 9-1

9 

10 9.1 Federal Agencies ..................................................................................................... 9-1

11 9.2 Federally Recognized Indian Tribes ........................................................................ 9-2

12 9.3 State Agencies ......................................................................................................... 9-3

13 9.4 Local Governments and Agencies ........................................................................... 9-4

14 9.5 Other Organizations ................................................................................................. 9-4

15 

16 10 LIST OF PREPARERS .................................................................................................... 10-1

17 

18 10.1 U.S. Nuclear Regulatory Commission Contributors ................................................. 10-1

19 10.2 Argonne National Laboratory Contributors .............................................................. 10-2

20 

21 APPENDIX A ENVIRONMENTAL SCOPING SUMMARY REPORT .................................. A-1

22 

23 APPENDIX B CONSULTATION CORRESPONDENCE ..................................................... B-1

24 

25 B.1 Threatened and Endangered Species Consultation ................................................ B-3

26 B.2 National Historic Preservation Act Consultation ...................................................... B-36 

27 B.3 Other Consultation ................................................................................................... B-85 

28 

29 APPENDIX C AIR QUALITY ANALYSIS ............................................................................. C-1

30 

31 C.1 Selection of Air Dispersion Model ............................................................................ C-3

32 C.2 Determination of Surface Characteristics ................................................................ C-4

33 C.3 Meteorological Data Processing .............................................................................. C-5

34 C.4 Terrain Data Processing .......................................................................................... C-7

35 C.5 Modeling Assumptions ............................................................................................. C-10

36 C.6 Modeling Results ..................................................................................................... C-10

37 C.7 References .............................................................................................................. C-11

38 

39 APPENDIX D TRANSPORTATION METHODOLOGY, ASSUMPTIONS, 

40 AND IMPACTS ............................................................................................. D-1

41 

42 D.1 Introduction .............................................................................................................. D-3

43 D.2 Methodology ............................................................................................................ D-3 

44 D.2.1 Routine Transportation Risk Methodology .................................................... D-4

45 D.2.1.1 Collective Population Risk ............................................................. D-4

46 D.2.1.2 Maximally Exposed Individual Risk ................................................ D-5

47 
 xiv 

1 CONTENTS (Cont.) 

2 

3 D.2.1.3 Vehicle-Related Risk ...................................................................... D-5

4 D.2.2 Accident Transportation Risk Methodology ................................................... D-5

5 D.2.2.1 Radiological Accident Risk Assessment ........................................ D-6

6 D.2.2.2 Chemical Accident Risk Assessment ............................................. D-6

7 D.2.2.3 Vehicle-Related Accident Risk Assessment .................................. D-7 

8 D.3 Input Parameters and Assumptions ......................................................................... D-7

9 D.3.1 Route Characteristics .................................................................................... D-8

10 D.3.1.1 Route Selection .............................................................................. D-8

11 D.3.1.2 Population Density ......................................................................... D-9 

12 D.3.1.3 Accident and Fatality Rates ........................................................... D-11 

13 D.3.2 Packaging ..................................................................................................... D-12

14 D.3.3 Shipment Configurations and Number of Shipments .................................... D-15 

15 D.3.4 Accident Characteristics ................................................................................ D-17 

16 D.3.4.1 Accident Severity Categories ......................................................... D-17

17 D.3.4.2 Package Release Fractions ........................................................... D-18 

18 D.3.4.3 Atmospheric Conditions during Accidents ..................................... D-20

19 D.3.5 Radiological Risk Assessment Input Parameters and Assumptions ............. D-21 

20 D.3.6 Routine Nonradiological Vehicle Emission Risks .......................................... D-22 

21 D.4 Summary of Transportation Impacts ........................................................................ D-24

22 D.5 Uncertainty in Transportation Risk Assessment ...................................................... D-30 

23 D.5.1 Routing of Radioactive Material .................................................................... D-30 

24 D.5.2 Shipping Container Characteristics ............................................................... D-30 

25 D.5.3 Source or Destination of Radioactive Material .............................................. D-30 

26 D.6 References .............................................................................................................. D-30 

27 

28 APPENDIX E DOSE METHODOLOGY AND IMPACTS ..................................................... E-1

29 

30 E.1 Introduction .............................................................................................................. E-3

31 E.2 Pathway Assessment Methodology ......................................................................... E-3

32 E.2.1 Members of the General Public ..................................................................... E-3

33 E.2.2 Construction Workers .................................................................................... E-4

34 E.2.3 Nonradiological Workers ............................................................................... E-5

35 E.2.4 EREF Radiation Workers .............................................................................. E-5

36 E.2.5 Environmental Transport Methodology ......................................................... E-5

37 E.3 Radiological Impact Assessment Input .................................................................... E-7

38 E.3.1 Radionuclide Releases.................................................................................. E-7

39 E.3.2 Population Distributions................................................................................. E-8

40 E.3.3 Exposure Time Fractions and Receptor Locations ....................................... E-8

41 E.3.4 Agricultural Productivity ................................................................................. E-10

42 E.3.5 Radionuclide-Specific Input ........................................................................... E-10

43 E.4 Results of the Radiological Impact Analyses ........................................................... E-11

44 E.4.1 Collective Population ..................................................................................... E-12

45 E.4.2 Individual Public Doses ................................................................................. E-13

46 
 xv 

1 CONTENTS (Cont.) 

2 

3 E.4.3 Worker Doses ............................................................................................... E-13

4 E.5 References .............................................................................................................. E-15

5 

6 APPENDIX F SOCIOECONOMIC ANALYSIS METHODS ................................................. F-1

7 

8 F.1 Employment, Income, and Tax Impacts................................................................... F-3

9 F.2 Impacts on Population ............................................................................................. F-4

10 F.3 Impacts on Local Housing Markets .......................................................................... F-4

11 F.4 Impacts on Community Services ............................................................................. F-4 

12 F.5 References .............................................................................................................. F-5

13 

14 APPENDIX G ENVIRONMENTAL JUSTICE ANALYSIS DATA .......................................... G-1

15 

16 APPENDIX H BENEFIT-COST ANALYSIS OF PROPRIETARY DATA .............................. H-1

17 

18 H.1 Introduction .............................................................................................................. H-3

19 H.2 Benefits .................................................................................................................... H-3

20 H.3 Costs ........................................................................................................................ H-4

21 H.4 References .............................................................................................................. H-5

22 

23 APPENDIX I PUBLIC PARTICIPATION AND NRC RESPONSE TO COMMENTS 

24 ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT ...................... I-1

25 

26 I.1 Introduction .............................................................................................................. I-3

27 I.2 Public Participation .................................................................................................. I-3

28 I.2.1 Initial Notification and Notice of Formal Proceeding ...................................... I-3

29 I.2.2 Public Scoping .............................................................................................. I-3

30 I.2.3 Draft EIS Development and Availability for Public Comment ........................ I-4

31 I.2.4 Draft EIS Public Comment Meetings ............................................................. I-5

32 I.2.5 Additional Public Comments Received on the Draft EIS ............................... I-5

33 I.3 Draft EIS Public Comment Compilation, Identification, Organization, Review, 

34 and Response .......................................................................................................... I-5

35 I.3.1 Comment Compilation ................................................................................... I-5

36 I.3.2 Commenter and Comment Identification ....................................................... I-5

37 I.3.3 NRC Comment Organization, Review, and Response .................................. I-6

38 I.3.4 Major Comment Issues and Topics ............................................................... I-6

39 I.3.5 Comments on Out-of-Scope Issues and Topics ............................................ I-7

40 I.4 Mandatory Hearing .................................................................................................. I-7

41 I.5 Public Comments on the Draft EIS and NRC Responses ....................................... I-24

42 I.5.1 General Opposition to the Project ................................................................. I-24

43 I.5.2 General Support for the Project..................................................................... I-36

44 I.5.3 NEPA Process............................................................................................... I-56

45 I.5.4 Purpose and Need ........................................................................................ I-71

46 
 xvi 

1 CONTENTS (Cont.) 

2 

3 I.5.5 Scope of the EIS Analysis ............................................................................. I-98

4 I.5.6 Nuclear Proliferation ...................................................................................... I-116

5 I.5.7 Alternatives Considered but Eliminated ........................................................ I-122

6 I.5.8 Land Use ....................................................................................................... I-124

7 I.5.9 Historic and Cultural Resources .................................................................... I-129

8 I.5.10 Visual and Scenic Resources ........................................................................ I-132

9 I.5.11 Air Quality ..................................................................................................... I-135

10 I.5.12 Geology, Minerals, and Soil ......................................................................... I-139

11 I.5.13 Water Resources.......................................................................................... I-141

12 I.5.14 Ecological Resources ................................................................................... I-151

13 I.5.15 Noise ............................................................................................................ I-164

14 I.5.16 Transportation .............................................................................................. I-164

15 I.5.17   Public and Occupational Health ................................................................... I-174

16 I.5.18 Waste Management ..................................................................................... I-182

17 I.5.19 Socioeconomics ........................................................................................... I-208

18 I.5.20 Environmental Justice .................................................................................. I-225

19 I.5.21 Accidents ...................................................................................................... I-225

20 I.5.22 Decontamination and Decommissioning ...................................................... I-233

21 I.5.23 Greenhouse Gas Emissions ......................................................................... I-236

22 I.5.24 Terrorism ...................................................................................................... I-240

23 I.5.25 Cumulative Impacts ...................................................................................... I-241

24 I.5.26 Mitigation ...................................................................................................... I-252

25 I.5.27 Environmental Measurement and Monitoring Programs .............................. I-252

26 I.5.28 Benefit-Cost Analysis ................................................................................... I-258

27 I.5.29 Editorial Comments ...................................................................................... I-261

28 I.6 References .............................................................................................................. I-261

29 

30 

31 
 xvii 

1 FIGURES 

2 

3 1-1 Location of the Proposed Eagle Rock Enrichment Facility ...................................... 1-2 

4 

5 1-2 Nuclear Fuel Cycle .................................................................................................. 1-4 

6 

7 2-1 Location of the Proposed EREF Site in Bonneville County, Idaho .......................... 2-3 

8 

9 2-2 Schematic of a Gas Centrifuge ................................................................................ 2-5 

10 

11 2-3 Diagram of Enrichment Cascade ............................................................................. 2-6 

12 

13 2-4 Stacking Depleted UF6 Cylinders in a Storage Yard ................................................ 2-8 

14 

15 2-5 Centrifuges inside a Cascade Hall ........................................................................... 2-9 

16 

17 2-6 Site Plan for the Proposed Eagle Rock Enrichment Facility .................................... 2-13 

18 

19 2-7 Truck Loaded with Five 30B Enriched Product Cylinders Loaded for Transport 

20 in Their Protective Overpacks .................................................................................. 2-18 

21 

22 2-8 United States Regions Meeting the Original Site Selection Criteria ........................ 2-30 

23 

24 2-9 Final 10 Candidate Gas Centrifuge Uranium Enrichment Facility Site 

25 Locations ................................................................................................................. 2-33 

26 

27 2-10 Organization of Gas Centrifuge Uranium Enrichment Facility Site 

28 Selection Objectives, Criteria Categories, and Criteria ............................................ 2-34 

29 

30 2-11 Candidate Sites Phase II Evaluation Results ........................................................... 2-39 

31 

32 2-12 Electromagnetic Isotopic Separation Process ........................................................ 2-40 

33 

34 2-13 Liquid Thermal Diffusion Process ............................................................................ 2-40 

35 

36 2-14 Gaseous Diffusion Stage ......................................................................................... 2-41 

37 

38 2-15 Atomic Vapor Laser Isotope Separation Process .................................................... 2-41 

39 

40 3-1 Location of Proposed Eagle Rock Eenrichment Facility .......................................... 3-2 

41 

42 3-2 Special Land Use Classification Areas .................................................................... 3-4 

43 

44 3-3 Photo of the Proposed EREF Site Area ................................................................... 3-9 

45 

46 
 xviii 

1 FIGURES (Cont.) 

2 

3 3-4 Center of Proposed EREF Site Area Facing South ................................................. 3-9 

4 

5 3-5 Photo from US 20 Facing North ............................................................................... 3-10 

6 

7 3-6 Agricultural Sheds near Proposed EREF Site Area ................................................. 3-10 

8 

9 3-7 Hell’s Half Acre National Natural Landmark ............................................................. 3-11 

10 

11 3-8 Meteorological Monitoring Stations near the Proposed EREF Site ......................... 3-17 

12 

13 3-9 Monthly Mean Temperatures in the Vicinity of the Proposed EREF Site ................. 3-18 

14 

15 3-10 Monthly Mean Precipitation in the Vicinity of the Proposed EREF Site ................... 3-21 

16 

17 3-11 Wind Rose for MFC ................................................................................................. 3-23 

18 

19 3-12 Idaho Air Quality Planning Areas ............................................................................. 3-31 

20 

21 3-13 Geologic Time Scale ................................................................................................ 3-36

22 

23 3-14 Regional Physiography ............................................................................................ 3-37 

24 

25 3-15 Lava Fields and Volcanic Rift Zones of the ESRP ................................................... 3-38 

26 

27 3-16 General Stratigraphy of the ESRP ........................................................................... 3-39 

28 

29 3-17 Peak Horizontal Acceleration ................................................................................... 3-41 

30 

31 3-18 Idaho Mineral Resources ......................................................................................... 3-44 

32 

33 3-19 Cross Sections Showing Depth to Basalt at the Proposed EREF Site .................... 3-46 

34 

35 3-20 Soil Map of the Proposed EREF Site and Surrounding Area ................................... 3-47 

36 

37 3-21 Surface Soil and Borehole Sample Locations .......................................................... 3-49 

38 

39 3-22 USGS-Designated Sub-basins within the Eastern Snake River Plain ..................... 3-53 

40 

41 3-23 Drainage Features in the Vicinity of the Proposed EREF Site ................................. 3-54 

42 

43 3-24 Annual Average and Peak Flows at the Snake River above Eagle Rock 

44 Station ...................................................................................................................... 3-56 

45 

46 
 xix 

1 FIGURES (Cont.) 

2 

3 3-25 Groundwater Flow Contours for the ESRP Aquifer .................................................. 3-57 

4 

5 3-26 Groundwater Potentiometric Surface Map for the Proposed EREF Property .......... 3-58 

6 

7 3-27 Snake River Plain Aquifers ...................................................................................... 3-59 

8 

9 3-28 Land Cover Types of the Region ............................................................................. 3-64 

10 

11 3-29 Land Cover Types of the Proposed EREF Property ................................................ 3-65 

12 

13 3-30 Vegetation Types of the Proposed EREF Property ................................................. 3-66 

14 

15 3-31 Noise Measurement Locations at the Proposed EREF Property ............................. 3-78 

16 

17 3-32 Sound Pressure Levels (dB) of Common Sources .................................................. 3-79 

18 

19 3-33 Percentage Contribution to the Effective Dose from All Sources of Radiation 

20 in the U.S. Population for 2006 ................................................................................ 3-84 

21 

22 4-1 VRM Classes in the Area Surrounding the Proposed EREF Site ............................ 4-9 

23 

24 4-2 Water Use during Period When Construction and Operations 

25 Activities Overlap ..................................................................................................... 4-41

26 

27 4-3 Locations of the Proposed EREF Stormwater Basins ............................................. 4-42

28 

29 4-4 Proposed EREF Footprint Relative to Vegetation .................................................... 4-48

30 

31 4-5 Proposed EREF Site Plan........................................................................................ 4-61

32 

33 6-1 Proposed Radiological Sampling Stations and Monitoring Locations ...................... 6-3

34 

35 6-2 Proposed Physiochemical Monitoring Locations ..................................................... 6-14 

36 

37 6-3 Vegetation Sampling Locations ............................................................................... 6-20

38 

39 C-1 Wind Rose at 10-meter Level at the Meteorological Station near the Materials 

40 and Fuels Complex within the Idaho National Laboratory in Idaho, 2004–2008 ...... C-9 

41 

42 D-1 Schematic of a Type 48Y Cylinder........................................................................... D-13 

43 

44 D-2 Schematic of a Type 30B Cylinder........................................................................... D-14

45 

46 
 xx 

1 FIGURES (Cont.) 

2 

3 D-3 Scheme for NUREG-0170 Classification by Accident Severity 

4 Category for Truck Accidents................................................................................... D-19 

5 

6 

7 TABLES 

8 

9 1-1 State of Idaho Environmental Requirements ........................................................... 1-20 

10 

11 1-2 Potentially Applicable Permitting and Approval Requirements and 

12 Their Status for the Construction, Operation, and Decommissioning 

13 of the Proposed Eagle Rock Enrichment Facility ..................................................... 1-22 

14 

15 2-1 Proposed Eagle Rock Enrichment Facility Schedule ............................................... 2-2 

16 

17 2-2 Depleted UF6 Tails Generation ................................................................................ 2-19 

18 

19 2-3 Candidate Sites for Phase I Screening .................................................................... 2-31 

20 

21 2-4 Objectives, Categories, and Criteria with Weights and Contribution 

22 to Site Score ............................................................................................................ 2-35 

23 

24 2-5 Candidate Sites Considered in Phase II Evaluation ................................................ 2-37 

25 

26 2-6 Summary of Environmental Impacts for the Proposed Action 

27 and the No-Action Alternative .................................................................................. 2-43 

28 

29 3-1 Scenic Quality: Explanation of Rating Criteria ......................................................... 3-13 

30 

31 3-2 Scenic Quality Inventory and Evaluation Chart ........................................................ 3-14 

32 

33 3-3 Mean, Average, and Extreme Temperatures near the Proposed EREF Site .......... 3-19 

34 

35 3-4 Monthly Precipitation near the Proposed EREF Site ............................................... 3-20 

36 

37 3-5 Relative Humidity at ID46W ..................................................................................... 3-22 

38 

39 3-6 Average Monthly and Annual Wind Speeds near the Proposed EREF Site ............ 3-24 

40 

41 3-7 Highest Hourly Wind Speed and Direction near the Proposed EREF Site .............. 3-25 

42 

43 3-8 Stability Class Distribution near the Proposed Site .................................................. 3-25 

44 

45 3-9 Inversion Persistence at MFC .................................................................................. 3-26 

46 
 xxi 

1 TABLES (Cont.) 

2 

3 3-10 Storm Events in the Vicinity of the Proposed EREF Site ......................................... 3-26 

4 

5 3-11 Estimated Seasonal and Annual Mixing Heights in the Vicinity of the 

6 Proposed EREF Site ................................................................................................ 3-28 

7 

8 3-12 National Ambient Air Quality Standards................................................................... 3-29 

9 

10 3-13 Emissions from the Four Counties Closest to the Proposed EREF Site .................. 3-31 

11 

12 3-14 Air Toxics Emissions from the Four Counties Closest to the Proposed 

13 EREF Site ................................................................................................................ 3-32 

14 

15 3-15 Hazards Associated with Basaltic Volcanism on the ESRP. .................................... 3-43 

16 

17 3-16 Radiochemical Analyses of Proposed EREF Property Surface Soil ........................ 3-50 

18 

19 3-17 Metals, Soluble Fluoride, and Percent Moisture in Proposed EREF 

20 Property Surface Soil ............................................................................................... 3-51 

21 

22 3-18 VOCs, SVOCs, and Pesticides Detected in Proposed EREF 

23 Property Surface Soil ............................................................................................... 3-52 

24 

25 3-19 Plant Species Identified on the Proposed EREF Property and 

26 Percent Areal Cover ................................................................................................ 3-67 

27 

28 3-20 Wildlife Species Occurring on the Proposed EREF Property .................................. 3-69 

29 

30 3-21 HUD Land Use Compatibility Guidelines ................................................................. 3-77 

31 

32 3-22 Extant Sound Levels at the Proposed EREF Property as Measured by AES .......... 3-79

33 

34 3-23 Annual Average Daily Traffic on Major Roads near the Proposed EREF Site ......... 3-81

35 

36 3-24 Occupational Dose Limits for Adults Established by 10 CFR Part 20 ...................... 3-87 

37 

38 3-25 Cancer Incidence and Death Rates for All Cancers for 2002 to 2006 ..................... 3-88

39 

40 3-26 Population in the Two-County ROI and Idaho ......................................................... 3-90 

41 

42 3-27 Two-County ROI Employment in 2006 .................................................................... 3-91 

43 

44 3-28 Two-County ROI Unemployment Rates ................................................................... 3-92 

45 

46 
 xxii 

1 TABLES (Cont.) 

2 

3 3-29 Two-County ROI and State Personal Income .......................................................... 3-92 

4 

5 3-30 Two-County ROI Housing Characteristics ............................................................... 3-94 

6 

7 3-31 School District Data for the Two-County ROI in 2007 .............................................. 3-95 

8 

9 3-32 Public Safety Employment in the Two-County ROI in 2009 ..................................... 3-95 

10 

11 3-33 Minority and Low-Income Populations within 6.4-kilometer Radius 

12 of the Proposed EREF Site ...................................................................................... 3-97 

13 

14 3-34 Selected Health Statistics for Counties near the Proposed EREF, 20052007 ....... 3-98 

15 

16 4-1 NRC’s Estimated Emissions of Criteria Pollutants from Construction Support 

17 Vehicles ................................................................................................................... 4-13

18 

19 4-2 NRC’s Estimated Emissions of Criteria Pollutants from Construction Vehicles 

20 and Equipment ......................................................................................................... 4-14

21 

22 4-3 NRC’s Estimated Daily Emissions during Preconstruction and Construction .......... 4-17

23 

24 4-4 Background Ambient Air Quality at Monitoring Stations Closest 

25 to the Proposed EREF Site ...................................................................................... 4-19

26 

27 4-5 Estimated Air Quality Impacts at the Proposed EREF Property Boundary 

28 Associated with Initial Preconstruction and Construction ........................................ 4-21

29 

30 4-6 Sensitivity of AERMOD Dispersion Modeling Results to Low Wind 

31 Speed Default Values .............................................................................................. 4-23

32 

33 4-7 NRC’s Estimated Emissions of Criteria Pollutants Resulting 

34 from Operations at the Proposed EREF .................................................................. 4-25

35 

36 4-8 Idaho Chemically Specific Air Quality Standards ..................................................... 4-27 

37 

38 4-9 Water Use for the Preconstruction and Construction Period ................................... 4-36

39 

40 4-10 Water Use for Overlapping Years of Construction and Operations ......................... 4-40

41 

42 4-11 Special Status Species Identified for the Proposed EREF ...................................... 4-46

43 

44 4-12 Summary of Annual Impacts on Humans from Truck Transportation of 

45 Radioactive Material ................................................................................................ 4-72

46 
 xxiii 

1 TABLES (Cont.) 

2 

3 4-13 Risk to the MEI from a Single Radioactive Material Shipment ................................. 4-73

4 

5 4-14 Estimated Occupational Health Related Incidences during Preconstruction 

6 and Construction ...................................................................................................... 4-77

7 

8 4-15 Estimated Occupational Health-Related Incidences during Plant Operation ........... 4-79

9 

10 4-16 Source Term Used for the Radiological Impact Assessment 

11 for Normal Operations ............................................................................................. 4-82

12 

4-17 Locations and Annual Average Atmospheric Dispersion Factors χ/Q (s/m3 13 ) for 

14 the Construction Workers during the Period of Construction and Operations 

15 Overlap .................................................................................................................... 4-83

16 

17 4-18 Worker Population Distribution during the Period of Construction 

18 and Operations Overlap .......................................................................................... 4-84

19 

20 4-19 Summary of Annual Radiological Impacts Associated with the Construction 

21 Workers during the Overlap Period of Construction and Operations at the 

22 Proposed EREF ....................................................................................................... 4-85

23 

24 4-20 Estimated Occupational Annual Exposures for Various Occupations for the 

25 Proposed EREF ...................................................................................................... 4-85

26 

27 4-21 Estimated Dose Rates at Various Locations within the Proposed EREF ................ 4-86

28 

29 4-22 Extrapolated Population Distribution within 80 km of the Proposed EREF .............. 4-87 

30 

31 4-23 General Public Receptor Locations for Radiological Impact Assessment ............... 4-88 

32 

4-24 Annual Average Atmospheric Dispersion Factors χ/Q (s/m3 33 ) for the 

34 General Population .................................................................................................. 4-89 

35 

36 4-25 Summary of Radiological Impacts for Members of the Public Associated with 

37 the Proposed EREF ................................................................................................ 4-90 

38 

39 4-26 Hazardous Waste Types and Quantities Expected during 

40 Preconstruction and Facility Construction ................................................................ 4-92 

41 

42 4-27 Radiological and Mixed Waste Types and Quantities Expected 

43 during Facility Operation .......................................................................................... 4-94 

44 

45 4-28 Socioeconomic Effects of the Proposed EREF ........................................................ 4-104 

46 
 xxiv 

1 TABLES (Cont.) 

2 

3 4-29 Summary and Comparison of Environmental Impacts from 

4 Preconstruction and Construction ............................................................................ 4-112 

5 

6 4-30 Definition of High- and Intermediate-Consequence Events ..................................... 4-118 

7 

8 4-31 Summary of Health Effects Resulting from Accidents ............................................. 4-119 

9 

10 4-32 Idaho Historical and Reference Case GHG Emissions, by Sector .......................... 4-131 

11 

12 4-33 Comparison of Idaho vs. U.S. GHG Emissions by Sector ....................................... 4-133 

13 

14 4-34 CO2 Emissions from Onsite Fuel Consumption over the Presconstruction 

15 and Heavy Construction Period ............................................................................... 4-134 

16 

17 4-35 Emissions from Workforce Commuting and Delivery Activities over the 

18 Preconstruction and Construction Period ................................................................ 4-135 

19 

20 4-36 Annual CO2 Emissions as a Result of Workforce Commuting 

21 during EREF Operation............................................................................................ 4-138 

22 

23 4-37 Annual CO2 Emissions as a Result of Deliveries during EREF Operation............... 4-139 

24 

25 4-38 Minority and Low-Income Populations within the 2-mi Buffer 

26 Associated with the Proposed Transmission Line ................................................... 4-160 

27 

28 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction 

29 and Construction Environmental Impacts ................................................................ 5-2 

30 

31 5-2 Summary of Mitigation Measures Identified by AES for Operations 

32 Environmental Impacts ............................................................................................ 5-11 

33 

34 5-3 Summary of Potential Mitigation Measures Identified by NRC for 

35 Preconstruction and Construction Environmental Impacts ...................................... 5-22 

36 

37 5-4 Summary of Potential Mitigation Measures Identified by NRC for 

38 Operations Environmental Impacts .......................................................................... 5-24 

39 

40 6-1 NRC Guidance Documents Relevant to Radiological Monitoring Programs ........... 6-2 

41 

42 6-2 EREF Proposed Gaseous Effluent Monitoring Program .......................................... 6-4 

43 

44 6-3 Radiological Sampling and Analysis Program for Liquid Waste Effluents ............... 6-8 

45 

46 
 xxv 

1 TABLES (Cont.) 

2 

3 6-4 Physiochemical Sampling and Analysis Program .................................................... 6-13 

4 

5 6-5 Stormwater Monitoring Program for Detention and Retention Basins ..................... 6-16 

6 

7 6-6 Birds Potentially Using the Proposed EREF Property ............................................. 6-22 

8 

9 6-7 Mammals Potentially Using the Proposed EREF Property ...................................... 6-25 

10 

11 6-8 Amphibians and Reptiles Potentially Using the Proposed EREF Property .............. 6-27 

12 

13 7-1 Socioeconomic Benefits Associated with the Proposed EREF in the 

14 11-County ROI ......................................................................................................... 7-7 

15 

16 C-1 Meteorological Data Information .............................................................................. C-6 

17 

18 C-2 Maximum Air Quality Impacts Due to Emissions Associated with 

19 Construction Activities of the Proposed Eagle Rock Enrichment 

20 Facility in Idaho ........................................................................................................ C-7 

21 

22 C-3 Maximum Air Quality Impacts Due to Emissions Associated with 

23 Construction Activities of the Proposed Eagle Rock Enrichment 

24 Facility in Idaho ........................................................................................................ C-8 

25 

26 D-1 Shipping Origins and Destinations ........................................................................... D-9 

27 

28 D-2 Distance, Density, and Stop Information Generated by WebTRAGIS 

29 for Truck Route ........................................................................................................ D-10

30 

31 D-3 Annual Number of Containers and Trucks Required for Transport .......................... D-13 

32 

33 D-4 Type 48Y Cylinder Specifications ............................................................................ D-14 

34 

35 D-5 Type 30B Cylinder Specifications ............................................................................ D-15 

36 

37 D-6 Curie Inventory in Selected Shipping Containers for Truck Transportation ............. D-16 

38 

39 D-7 Fractional Occurrences for Accidents by Severity Category and 

40 Population Density Zone .......................................................................................... D-19 

41 

42 D-8 Fraction of Package Released, Aerosolized, and Respirable .................................. D-20 

43 

44 D-9 Direct Radiation Surrounding Shipping Containers ................................................. D-22 

45 

46 
 xxvi 

1 TABLES (Cont.) 

2 

3 D-10 RADTRAN 5 Input Parameters ................................................................................ D-23 

4 

5 D-11 Annual Collective Population Risks from Truck Transportation ............................... D-25 

6 

7 D-12 Doses and Total Risk of Latent Cancer Fatalities from Accidents 

8 during Truck Transportation of Radioactive Materials ............................................. D-28 

9 

10 E-1 Source Term Used for the Radiological Impact Assessment 

11 for Normal Operations ............................................................................................. E-8 

12 

13 E-2 Extrapolated Data on Population within 80-kilometer (50-mile) Radius 

14 of Proposed EREF in 2050 ...................................................................................... E-9 

15 

16 E-3 Worker Population Distribution during Build-Out/Operational Phase ....................... E-10 

17 

18 E-4 Receptor Locations for Radiological Impact Assessment ........................................ E-11 

19 

20 E-5 Agricultural Input Parameters Used in the Radiological Impact Assessment .......... E-11 

21 

22 E-6 Radionuclide-Specific Input Used in the Radiological Impact Assessment ............. E-12 

23 

24 E-7 Collective Doses for Members of the General Public and Construction 

25 Workers during Proposed EREF Build-Out .............................................................. E-14 

26 

27 E-8 Summary of Individual Doses for Workers and Members of the Public ................... E-14 

28 

29 E-9 Estimated Annual Exposures for Various Occupations at the Proposed 

30 EREF ....................................................................................................................... E-15 

31 

32 E-10 Estimated Dose Rates at Various Locations within the Proposed EREF ................ E-15 

33 

34 G-1 State and County Minority Population Totals, 2000 ................................................. G-3 

35 

36 G-2 Census Block Group Minority Population Totals, 2000 ............................................ G-3 

37 

38 G-3 State and County Low-Income Population Totals, 1999 ......................................... G-4 

39 

40 G-4 Census Block Group Low-Income Population Totals, 1999 ..................................... G-4 

41 

42 I-1 Draft EIS Commenter Identification and Comment Response Locations ................ I-8 

43 
 xxvii 

1 EXECUTIVE SUMMARY 

2 

3 BACKGROUND 

4 

5 Under the provisions of the Atomic Energy Act and pursuant to Title 10 of the U.S. Code of 

6 Federal Regulations (10 CFR) Parts 30, 40, and 70, the U.S. Nuclear Regulatory Commission 

7 (NRC) is considering whether to issue a license that would allow AREVA Enrichment Services, 

8 LLC (AES) to possess and use byproduct material, source material, and special nuclear 

9 material at a proposed gas centrifuge uranium enrichment facility near Idaho Falls in Bonneville 

10 County, Idaho, for a period of 30 years. The scope of activities to be conducted under the 

11 license would include the construction, operation, and decommissioning of the proposed Eagle 

12 Rock Enrichment Facility (EREF). The application for the license was filed with the NRC by 

13 AES by letter dated December 30, 2008. Revisions to the license application were submitted by 

14 AES on April 23, 2009 (Revision 1) and April 30, 2010 (Revision 2). To support its licensing 

15 decision on AES’s proposed EREF, the NRC determined that the NRC’s implementing 

16 regulations in 10 CFR Part 51 for the National Environmental Policy Act (NEPA) require the 

17 preparation of an Environmental Impact Statement (EIS). The development of this EIS is based 

18 on the NRC staff’s review of information provided by AES, independent analyses, and 

19 consultations with the U.S. Fish and Wildlife Service and other Federal agencies, Native 

20 American tribes, the Idaho State Historic Preservation Office (SHPO) and other State agencies, 

21 and local government agencies. 

22 

23 The enriched uranium produced at the proposed EREF would be used to manufacture nuclear 

24 fuel for commercial nuclear power reactors. Enrichment is the process of increasing the 

25 concentration of the naturally occurring and fissionable uranium-235 isotope. Uranium ore 

26 usually contains approximately 0.72 weight percent uranium-235. To be useful in light-water 

27 nuclear power plants as fuel for electricity generation, the uranium must be enriched up to 

28 5 weight percent uranium-235. 

29 

30 THE PROPOSED ACTION 

31 

32 The proposed action considered in this EIS is for AES to construct, operate, and decommission 

33 a uranium enrichment facility, the proposed EREF, at a site near Idaho Falls in Bonneville 

34 County, Idaho. To allow the proposed action to take place, the NRC would issue a license to 

35 AES as discussed above. The proposed EREF would be located on a 186-hectare (460-acre) 

36 section of a 1700-hectare (4200-acre) parcel of land that it intends to purchase from a single 

37 private landowner. Current land uses of the proposed EREF property include native rangeland, 

38 nonirrigated seeded pasture, and irrigated cropland. The proposed EREF, if approved, would 

39 be situated on the north side of US 20, about 113 kilometers (70 miles) west of the 

40 Idaho/Wyoming State line and approximately 32 kilometers (20 miles) west of Idaho Falls. The 

41 eastern boundary of the U.S. Department of Energy’s (DOE) Idaho National Laboratory (INL) is 

42 1.6 kilometers (1 mile) west of the proposed property. The lands north, east, and south of the 

43 proposed property are a mixture of private-, Federal-, and State-owned parcels, with the Federal 

44 lands managed by the Bureau of Land Management (BLM). 

45 

46 Using a gas centrifuge process, the proposed EREF would produce uranium enriched up to 

47 5 percent by weight in the isotope uranium-235, with a planned maximum target production of 

48 6.6 million separative work units (SWUs) per year. An SWU is a unit of measurement used in 

49 the nuclear industry, pertaining to the process of enriching uranium for use as fuel for nuclear 
 xxviii 

1 power plants. If the license is approved, facility construction would begin in 2011 with heavy 

2 construction (construction of all major buildings and structures) continuing for 7 years into 2018. 

3 The proposed EREF would begin initial production in 2014 and reach peak production in 2022. 

4 Operations would continue at peak production until approximately 9 years before the license 

5 expires. Decommissioning activities would then begin and be completed by 2041. 

6 Decommissioning would involve the sequential shutdown of the 4 Separation Building Modules 

7 (SBMs) resulting in a gradual decrease in production. Each SBM would take approximately 

8 4.5 years to decommission. 

9 

10 Supplemental information on a proposed 161-kilovolt (kV) electrical transmission line required to 

11 power the proposed EREF was submitted by AES on February 18, 2010. The NRC has no 

12 jurisdiction over transmission lines; therefore, the transmission line for the proposed EREF is 

13 not considered part of the proposed action. However, construction and operation of this 

14 transmission line are considered in this EIS under cumulative impacts. 

15 

16 NRC EXEMPTION FOR AES TO CONDUCT CERTAIN PRECONSTRUCTION ACTIVITIES 

17 

18 On June 17, 2009, AES submitted a request for an exemption from certain NRC regulations to 

19 allow commencement of certain preconstruction activities on the proposed EREF site prior to 

20 NRC’s decision to issue a license for the construction, operation, and decommissioning of the 

21 proposed EREF. On March 17, 2010, the NRC granted an exemption authorizing AES to 

22 conduct the requested preconstruction activities. Under the exemption, these preconstruction 

23 activities are not considered by the NRC as part of the proposed action, although the 

24 environmental impacts of these activities are discussed in this EIS along with the impacts of 

25 facility construction. 

26 

27 Specifically, the exemption covers the following activities and facilities: 

28 

29 • clearing of approximately 240 hectares (592 acres) for the proposed EREF 

30 

31 • site grading and erosion control 

32 

33 • excavating the site including rock blasting and removal 

34 

35 • constructing a stormwater retention pond 

36 

37 • constructing main access and site roadways 

38 

39 • installing utilities 

40 

41 • erecting fences for investment protection 

42 

43 • constructing parking areas 

44 

45 • erecting construction buildings, offices (including construction trailers), warehouses, and 

46 guardhouses 

47 
 xxix 

1 This exemption authorizes AES to conduct the stated activities, provided that none of the 

2 facilities or activities subject to the exemption would be components of AES’s Physical Security 

3 Plan or its Standard Practice Procedures Plan for the Protection of Classified Matter, or 

4 otherwise be subject to NRC review or approval. AES initiated preconstruction activities in late 

5 2010. 

6 

7 PURPOSE OF AND NEED FOR THE PROPOSED ACTION 

8 

9 The purpose of the proposed action would be to allow AES to construct, operate, and 

10 decommission a facility using gas centrifuge technology to enrich uranium up to 5 percent by 

11 weight of uranium-235, with a production capacity of 6.6 million SWU per year, at the proposed 

12 EREF near Idaho Falls in Bonneville County, Idaho. This facility would contribute to the 

13 attainment of national energy security policy objectives by providing an additional reliable and 

14 economical domestic source of low-enriched uranium to be used in commercial nuclear power 

15 plants. 

16 

17 Nuclear power currently supplies approximately 20 percent of the nation’s electricity. The 

18 United States Enrichment Corporation Paducah Gaseous Diffusion Plant, Paducah, Kentucky, is 

19 currently the primary U.S. supplier of low-enriched uranium for nuclear fuel in the United States. 

20 However, the URENCO USA facility (formerly known as the National Enrichment Facility) in Lea 

21 County, New Mexico, which began initial operations in June 2010, may provide additional 

22 enrichment services in the future as construction continues on its remaining cascade halls. The 

23 American Centrifuge Plant (ACP) in Piketon, Ohio, which is currently under construction, and 

24 the proposed Global Laser Enrichment (GLE) Facility in Wilmington, North Carolina, for which 

25 the NRC is currently reviewing its license application, may also provide additional domestic 

26 enrichment services in the future. The existing operating Paducah, Kentucky, enrichment plant 

27 supplies approximately 15 percent of the current U.S. demand for low-enriched uranium. The 

28 United States Enrichment Corporation also imports downblended (diluted) weapons-grade 

29 uranium from Russia through the Megatons to Megawatts Program to supply an additional 

30 38 percent of the U.S. demand. The remaining 47 percent of low-enriched uranium is imported 

31 from foreign suppliers. The current primary dependence on a single U.S. supplier and foreign 

32 sources for low-enriched uranium imposes reliability risks for the nuclear fuel supply to 

33 U.S. nuclear power plants. National energy policy emphasizes the importance of having a 

34 reliable domestic source of enriched uranium for national energy security. The production of 

35 enriched uranium at the proposed EREF would be equivalent to about 40 percent of the current 

36 and projected demand (15 to16 million SWUs) for enrichment services within the United States. 

37 

38 ALTERNATIVES TO THE PROPOSED ACTION 

39 

40 In this EIS, the NRC staff considered a reasonable range of alternatives to the proposed action, 

41 including alternative sites for an AES enrichment facility, alternative sources of low-enriched 

42 uranium, alternative technologies for uranium enrichment, and the no-action alternative. Two of 

43 the alternatives, the proposed action and the no-action alternative, were analyzed in detail. The 

44 approved preconstruction activities discussed earlier are assumed to occur prior to NRC’s 

45 decision to grant a license to AES and, therefore, are assumed to occur under both the 

46 proposed action and the no-action alternative. 

47 
 xxx 

1 Under the no-action alternative, the proposed EREF would not be constructed, operated, and 

2 decommissioned in Bonneville County, Idaho. Uranium enrichment services would continue to 

3 be performed by existing domestic and foreign uranium enrichment suppliers. However, 

4 URENCO USA would provide and the ACP and potentially the proposed GLE Facility may 

5 provide enrichment services in the future. 

6 

7 AES considered 44 alternative sites throughout the United States. AES evaluated these sites 

8 based on various technical, safety, economic, and environmental selection criteria, and 

9 concluded that the Eagle Rock site in Bonneville County, Idaho, met all of the criteria. The NRC 

10 staff reviewed AES’s site-selection process and results to determine if any site considered by 

11 AES was obviously superior to the proposed Eagle Rock site. The NRC staff determined that 

12 the process used by AES was rational and objective, and that its results were reasonable. 

13 Based on its review, the NRC staff concluded that none of the candidate sites were obviously 

14 superior to the AES preferred site in Bonneville County, Idaho. 

15 

16 The NRC staff examined three alternatives to satisfy domestic enrichment needs: (1) reactivate 

17 the Portsmouth Gaseous Diffusion Plant near Piketon, Ohio; (2) downblend highly enriched 

18 uranium instead of constructing a domestic uranium enrichment facility; and (3) purchase low19 enriched uranium from foreign sources. These alternatives were eliminated from further 

20 consideration based on concerns related to reliability, excessive energy consumption, and 

21 national energy security, and did not meet national energy policy objectives involving the need 

22 for a reliable, economical source of domestic uranium enrichment. 

23 

24 The NRC staff also evaluated alternative technologies to the gas centrifuge process: 

25 electromagnetic isotope separation, liquid thermal diffusion, gaseous diffusion, Atomic Vapor 

26 Laser Isotope Separation, Molecular Laser Isotope Separation, and separation of isotopes by 

27 laser excitation. These technologies were eliminated from further consideration based on 

28 factors such as the technology immaturity, economic impracticality, or exclusive licensing. 

29 

30 In addition, the NRC staff considered conversion and disposition methods for depleted uranium 

31 hexafluoride (UF6): (1) beneficial use of depleted UF6, and (2) conversion at facilities other than 

32 the new facilities that the U.S. Department of Energy (DOE) has built at Portsmouth and 

33 Paducah. For the purposes of this analysis, because the current available inventory of depleted 

34 uranium exceeds the current and projected future demand for the material, the depleted UF6

35 generated by the proposed EREF was considered a waste product, and disposition alternatives 

36 involving its use as a resource were not further evaluated. 

37 

38 Existing fuel fabrication facilities have not expressed an interest in performing depleted UF6

39 conversion services, and the cost for the services would be difficult to estimate; therefore, this 

40 alternative was eliminated from further consideration. However, International Isotopes, Inc. 

41 submitted a license application to the NRC on December 31, 2009, to construct and operate a 

42 depleted UF6 conversion facility near Hobbs, New Mexico. On February 23, 2010, the NRC 

43 staff accepted the license application, and has initiated a formal safety and environmental 

44 review. 

45 

46 
 xxxi 

1 POTENTIAL ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION 

2 

3 This EIS evaluates the potential environmental impacts of the proposed action. A standard of 

4 significance has been established for assessing environmental impacts. Following the Council 

5 on Environmental Quality’s regulations in 40 CFR 1508.27, the NRC staff has assigned each 

6 impact one of the following three significance levels: 

7 

8 • SMALL. The environmental effects are not detectable or are so minor that they would 

9 neither destabilize nor noticeably alter any important attribute of the resource. 

10 

11 • MODERATE. The environmental effects are sufficient to noticeably alter but not destabilize 

12 important attributes of the resource. 

13 

14 • LARGE. The environmental effects are clearly noticeable and are sufficient to destabilize 

15 important attributes of the resource. 

16 

17 As described in Chapter 4, the environmental impacts of preconstruction and the proposed 

18 action would mostly be SMALL. Some potential impacts would be SMALL to MODERATE or 

19 MODERATE in a few cases; and there would be LARGE, though intermittent, short-term 

20 impacts in one resource area during preconstruction. Methods for mitigating the potential 

21 impacts are identified in Chapters 4 and 5. Environmental measurement and monitoring 

22 methods are described in Chapter 6. 

23 

24 Summarized below are the potential environmental impacts of the proposed action on each of 

25 the resource areas considered in this EIS. Each summary is preceded by the impact 

26 significance level for the respective resource areas. 

27 

28 Land Use 

29 

30 SMALL. The construction of a uranium enrichment facility would alter the current land use, 

31 which consists primarily of agriculture and undeveloped rangeland. The 240-hectare (592-acre) 

32 proposed EREF site under consideration would be located entirely on a 1700-hectare 

33 (4200-acre) private parcel of land. Bonneville County has zoned the location as G-1, Grazing, 

34 which allows for industrial development, and is intended to allow certain activities that should be 

35 removed from population centers in the county. The operation of a uranium enrichment facility 

36 is consistent with the county’s zoning. It is not anticipated that construction and operation of the 

37 proposed EREF would have any effect on the current land uses found on the surrounding public 

38 lands managed by the BLM. 

39 

40 Restrictions to land use would begin with the purchase of the proposed property by AES. The 

41 alteration of land use would begin during preconstruction and continue during construction. 

42 Preconstruction activities would result in the alteration of the land as a result of activities such 

43 as land clearing and grading, restricted access to the proposed EREF property, and cessation 

44 of agricultural uses (grazing and crop production). The majority of impacts to land use would 

45 occur during preconstruction. However, since large land areas in the county will continue to be 

46 used for grazing and crop production, including the BLM-managed lands surrounding the 

47 proposed EREF property, land use impacts resulting from preconstruction and construction 

48 would be SMALL. 

49 
 xxxii 

1 Operation of the proposed EREF would restrict land use on the proposed property to the 

2 production of enriched uranium. The operation of the proposed EREF is not expected to alter 

3 land use on adjacent properties. Impacts on land use due to operations would be SMALL. 

4 

5 At the end of decommissioning, the buildings and structures would be available for unrestricted 

6 use. As a result, impacts on land use due to decommissioning would be SMALL. 

7 

8 Historic and Cultural Resources 

9 

10 SMALL TO MODERATE. Impacts to historic and cultural resources would occur primarily 

11 during preconstruction. Construction would take place on ground previously disturbed by 

12 preconstruction activities. There are 13 cultural resource sites (3 prehistoric, 6 historic, and 

13 4 multi-component) in the surveyed areas of the proposed EREF property. One of these sites, 

14 the John Leopard Homestead (MW004), is located within the footprint of the proposed EREF, 

15 and has been recommended as eligible for the National Register of Historic Places. Site 

16 MW004 would be destroyed by preconstruction activities. However, AES mitigated impacts to 

17 site MW004 prior to land disturbance through professional excavation and data recovery, and 

18 other similar homestead site types exist in the region. Therefore, the impact to site MW004 

19 would be limited to a MODERATE level. 

20 

21 Construction and operation of the proposed EREF would be unlikely to result in visual or noise 

22 impacts on the Wasden Complex, an important group of archaeological sites, because it is 

23 located approximately 1.6 kilometers (1.0 mile) from the proposed EREF site and sits behind a 

24 ridge that partially blocks the view. Other impacts during operations would be SMALL because 

25 no intact historic or cultural resources would remain. 

26 

27 Decommissioning would not likely affect historic and cultural resources because any areas 

28 disturbed during decommissioning would have been previously disturbed during preconstruction 

29 and construction. Therefore, impacts would be SMALL. 

30 

31 Visual and Scenic Resources 

32 

33 SMALL TO MODERATE. Impacts to visual and scenic resources result when contrasts are 

34 introduced into a visual landscape. The proposed project site and surrounding areas consist 

35 primarily of sagebrush semi-desert to the north, east, and west of the proposed site. The 

36 proposed facility would be located approximately 2.4 kilometers (1.5 miles) from areas of public 

37 view, including US 20 and the Hell’s Half Acre Wilderness Study Area (WSA) to the south which 

38 contains the remains of a 4000-year-old lava flow. The BLM gave a Visual Resource 

39 Management (VRM) Class I designation to the WSA, which applies to areas of high scenic 

40 quality. 

41 

42 Visual impacts during preconstruction could result along US 20 from increased activity at the 

43 proposed site and fugitive dust, but these would be of a relatively short duration. The clearing of 

44 vegetation and installation of a perimeter fence would change the visual setting; however, they 

45 would not drastically alter the overall appearance of the area. Impacts on visual and scenic 

46 resources due to preconstruction would be SMALL. 

47 
 xxxiii 

1 Construction of the proposed EREF would introduce visual intrusions that are out of character 

2 with the surrounding area. While initial construction activities would commence on a cleared 

3 area, such a view is not very intrusive on the visual landscape. Similarly, fugitive dust 

4 generated during the construction period would be of a temporary nature and cause minimal 

5 disturbance to the viewshed. However, because of the extent of the proposed EREF project, 

6 the type and size of equipment involved in construction, and the industrial character of buildings 

7 to be built, construction of the proposed EREF would create significant contrast with the 

8 surrounding visual environment, which is predominantly rangeland and cropland. Thus, visual 

9 impact levels associated with construction would range from SMALL to MODERATE. 

10 

11 Construction and operation of the proposed EREF would be unlikely to result in visual impacts 

12 on the Wasden Complex due to its distance from the proposed EREF site and location behind a 

13 ridgeline that obscures views of the lower portions of the proposed facility. However, operations 

14 would have an impact on the surrounding visual landscape. The proposed facility is visually 

15 inconsistent with the current setting, and its operation is expected to alter the visual rating on 

16 surround public lands, which would be a MODERATE visual impact. Also, plant lighting at night 

17 could be perceivable at the trailhead of the Hell’s Half Acre WSA, although probably not from 

18 the Craters of the Moon National Park located 72 kilometers (45 miles) to the west of the 

19 proposed EREF site. 

20 

21 At the end of decommissioning, the buildings and structures would be available for unrestricted 

22 use. As a result, impacts on visual and scenic resources would remain MODERATE. 

23 

24 Air Quality 

25 

26 SMALL to LARGE. Air emissions during preconstruction and construction would include fugitive 

27 dust from heavy equipment working on the proposed site, engine emissions from construction 

28 equipment onsite and vehicles transporting workers and materials to the proposed site, and 

29 emissions from diesel-fueled generators. The generators, although not intended to provide 

30 power for construction activities, would be operated weekly for preventative maintenance. 

31 During preconstruction, fugitive dust from land clearing and grading operations would result in 

32 large releases of particulate matter. Such impacts would be MODERATE to LARGE during 

33 certain preconstruction periods and activities that would be temporary and brief in duration. 

34 Otherwise, impacts on ambient air quality from preconstruction would be SMALL for all 

35 hazardous air pollutants (HAPs) and all criteria pollutants except particulates. Air quality 

36 impacts during construction would be SMALL for all HAPs and all criteria pollutants. 

37 

38 During operations, the proposed EREF would not be a major source of air emissions, although 

39 there is a potential for small gaseous releases associated with operation of the process that 

40 could contain UF6, hydrogen fluoride (HF), and uranyl fluoride (UO2F2). Also, small amounts of 

41 nonradioactive air emissions consisting of carbon monoxide (CO), nitrogen oxides (NOx), 

42 particulate matter (PM), volatile organic compounds (VOCs), and sulfur dioxide (SO2) would be 

43 released: 

44 

45 • from the auxiliary diesel electric generators to supply electrical power when power from the 

46 utility grid is not available 

47 

48 • during building and equipment maintenance activities 

49 
 xxxiv 

1 • from trucks, automobiles, and other vehicles in use onsite 

2 

3 Air emissions are not expected to impact regional visibility. Ambient air modeling predicts that 

4 impacts on ambient air quality from the routine operation of the proposed EREF would be 

5 SMALL with respect to all criteria pollutants and all HAPs. 

6 

7 During decommissioning, impacts would result from emissions including fugitive dust (mitigated 

8 by dust suppression work practices) and CO, NOx, PM, VOCs, and SO2 from transportation 

9 equipment and would be SMALL. 

10 

11 Geology and Soils 

12 

13 SMALL. Impacts on about 240 hectares (592 acres) of land would occur primarily during 

14 preconstruction, as a result of soil-disturbing activities (blasting, excavating, grading, and other 

15 activities) that loosen soil and increase the potential for erosion. Because these impacts are 

16 short-term and can be mitigated, impacts on geology and soils would be SMALL. Construction 

17 activities could cause short-term impacts such as an increase in soil erosion at the proposed 

18 site. Soil erosion could result from wind action and rain, although rainfall in the vicinity of the 

19 proposed site is low. Compaction of soils due to heavy vehicle traffic would increase the 

20 potential for soil erosion via runoff. Impacts would be SMALL. 

21 

22 Impacts on soils during operations at the proposed facility would also be SMALL because 

23 activities would not increase the potential for soil erosion beyond that for the surrounding area. 

24 The impacts to soil quality from atmospheric deposition of pollutants during operations would be 

25 SMALL. 

26 

27 Land disturbance associated with decommissioning could temporarily increase the potential for 

28 soil erosion at the proposed EREF site, resulting in impacts similar to (but less than) those 

29 during the preconstruction/construction phase. As a result, impacts to soils due to 

30 decontamination and decommissioning activities would be SMALL. 

31 

32 Water Resources 

33 

34 SMALL. During preconstruction and construction, stormwater runoff would be diverted to a 

35 stormwater detention basin, thus the potential for contaminated stormwater discharging to water 

36 bodies on adjacent properties is low. No surface water sources would be used. Natural surface 

37 water bodies are absent within and near the proposed EREF site, and groundwater occurs at 

38 depths of 202 meters (661 feet) to 220 meters (722 feet). Annual maximum groundwater usage 

39 rates from the Eastern Snake River Plain (ESRP) aquifer in Bonneville County during 

40 preconstruction and construction comprise about 16 percent of the annual water right 

41 appropriation that has been transferred to the proposed property for use as industrial water. 

42 Therefore, impacts on surface water quality, the regional water supply, and groundwater quality 

43 during preconstruction and construction would be SMALL. 

44 

45 Water usage rates during operations would remain well within the water right appropriation. 

46 Both average and peak annual water use requirements would be less than 1 percent of the total 

47 groundwater usage from the ESRP aquifer. No process effluents would discharge to the 

48 retention or detention basins or into surface water. Therefore, liquid effluents would have a 
 xxxv 

1 SMALL impact on water resources. Because all the water discharged to the Cylinder Storage 

2 Pads Stormwater Retention Basins would evaporate, the basins would have a SMALL impact 

3 on the quality of water resources. The site Stormwater Detention Basin seepage would also 

4 have a SMALL impact on water resources of the area because no wastewater would be 

5 discharged to the basin. 

6 

7 Since the usage and discharge impacts to water resources during the decommissioning phase 

8 would be similar to those during construction, the impacts to water resources would remain 

9 SMALL. 

10 

11 Ecological Resources 

12 

13 SMALL TO MODERATE. Preconstruction activities such as land clearing could result in direct 

14 impacts due to habitat loss and wildlife mortality as well as indirect impacts to ecological 

15 resources in surrounding areas, primarily from fugitive dust and wildlife disturbance. 

16 Approximately 75 hectares (185 acres) of sagebrush steppe habitat and 55 hectares 

17 (136 acres) of nonirrigated pasture would be eliminated. Impacts on plant communities and 

18 wildlife from preconstruction would be MODERATE. Construction activities that could impact 

19 ecological resources include constructing the proposed UF6 storage pads and EREF buildings. 

20 However, most construction activities would occur in areas that would have already been 

21 disturbed by preconstruction activities. Impacts on vegetation would occur primarily from any 

22 additional vegetation clearing. Impacts would include the generation of fugitive dust, spread of 

23 invasive species, changes in drainage patterns, soil compaction, erosion of disturbed areas, 

24 potential sedimentation of downgradient habitats, and accidental releases of hazardous or toxic 

25 materials (e.g., fuel spills). These activities could also result in some wildlife mortality and would 

26 cause other wildlife to relocate as a result of noise, lighting, traffic, and human presence. 

27 Collisions with construction equipment and other vehicles may cause some wildlife mortality. 

28 No rare or unique plant communities, or threatened or endangered species, have been found or 

29 are known to occur on the proposed site, although habitat on the proposed property is known to 

30 be used by greater sage-grouse (a Federal candidate species). Construction (and 

31 preconstruction) activities are not expected to result in population-level impacts on any 

32 Federally listed or State-listed species, which the U.S. Fish and Wildlife Service has stated are 

33 not present on the proposed EREF property. Impacts of construction of the proposed facility 

34 would be SMALL. 

35 

36 Operation of the proposed EREF could result in impacts on wildlife and plant communities as a 

37 result of noise, lighting, traffic, human presence, air emissions, and retention/detention ponds. 

38 However, these impacts would be SMALL. 

39 

40 Vegetation and wildlife that became established near the proposed facility could be affected by 

41 decommissioning activities. Impacts during decommissioning would be similar to those during 

42 construction and would be SMALL. 

43 

44 Noise 

45 

46 SMALL. Most of the major noise-producing activities (site clearing and grading, excavations 

47 [including the use of explosives], utility burials, construction of onsite roads [including the US 20 

48 interchanges], and construction of the ancillary buildings and structures) would occur during 
 xxxvi 

1 preconstruction. Noise impacts from initial preconstruction activities may exceed established 

2 standards at some locations along the proposed EREF property boundary for relatively short 

3 periods of time. However, because of the distances involved, expected levels of attenuation, 

4 application of mitigation measures, and the expected limited presence of human receptors at 

5 these locations, the impacts of noise during preconstruction would be SMALL for human 

6 receptors. The nearest resident is located approximately 7.7 kilometers (4.8 miles) east of the 

7 proposed site. No residence is expected to experience unacceptable noise levels during 

8 construction. Noise impacts from construction may exceed established standards at some 

9 offsite locations for relatively short periods of time. However, because of the distances involved, 

10 expected levels of attenuation, and AES’s commitment to appropriate mitigations, the impacts 

11 would be SMALL for human receptors. During the overlap period when partial operations begin 

12 while building construction continues, noise impacts from construction and operation are 

13 expected to be additive, but still substantially reduced from noise levels during initial 

14 construction. 

15 

16 Major noise sources associated with facility operation include the six diesel-fueled emergency 

17 generators, commuter traffic, the movement of delivery vehicles, and operation of various 

18 pumps, compressors, and cooling fans. Operational noise estimates at the proposed property 

19 boundary satisfy all relevant or potentially relevant U.S. noise standards and guidance. 

20 Residents in the vicinity of US 20, who would otherwise be unaffected by noise from the 

21 proposed EREF industrial footprint, would be impacted by slightly increased traffic noise. Noise 

22 impacts from proposed EREF operation would be SMALL. 

23 

24 Noise sources and levels during decommissioning would be similar to those during construction, 

25 and peaking noise levels would be expected to occur for short durations. As a result, noise 

26 impacts from decommissioning would be SMALL. 

27 

28 Transportation 

29 

30 SMALL TO MODERATE. Preconstruction activities for the proposed EREF would cause an 

31 impact on the local transportation network due to the construction of highway entrances, the 

32 daily commute of workers, daily construction deliveries, and waste shipments. Traffic 

33 slowdowns or delays would only be expected to occur at the entrance to the proposed EREF 

34 during access road construction and shift changes; the impacts on overall traffic patterns and 

35 volumes would be MODERATE on US 20 and SMALL on Interstate 15 (I-15). The primary 

36 impact would be increased traffic on nearby roads. Impacts during construction would occur 

37 from transportation of personnel, construction materials, and nonradiological waste. All traffic to 

38 and from the proposed EREF during preconstruction and construction would use US 20. 

39 Construction activities at the proposed EREF site could result in a 55 percent increase in traffic 

40 volume on US 20 (including the period when construction and operations overlap). Because 

41 traffic volume is expected to remain below the design capacity of I-15 and traffic slowdowns or 

42 delays would only be expected to occur at the entrance to the proposed EREF during shift 

43 changes, the impacts on overall traffic patterns and volumes during construction would be 

44 SMALL to MODERATE on US 20 and SMALL on I-15. For the most part, the impacts from the 

45 truck traffic to and from the proposed site during construction would be SMALL. 

46 

47 Operations impacts would occur from the transport of personnel, nonradiological materials, and 

48 radioactive material to and from the proposed EREF, especially during the period when 
 xxxvii 

1 construction and operation overlap. Increased traffic during facility operation would have a 

2 SMALL to MODERATE impact on the current traffic on US 20 (SMALL for any off-peak shift 

3 change). The impacts of truck traffic to and from the proposed site during operation would be 

4 SMALL. Annual transportation routine impacts and accident risks (radiological and chemical) 

5 would be SMALL. 

6 

7 Traffic during the initial portion of the decommissioning would be approximately the same as for 

8 the period when construction and operations overlap. Traffic after the cessation of operations 

9 would be less than during either construction or operation. Impacts on local traffic on US 20 

10 would be SMALL to MODERATE. 

11 

12 Public and Occupational Health 

13 

14 SMALL. During preconstruction, impacts on occupational safety resulting from injuries, 

15 illnesses, and exposures to fugitive dust, pollutants, and vapors would be SMALL, based on 

16 estimates of the number of incidents. During construction, nonradiological impacts could 

17 include injuries and illnesses incurred by workers and impacts due to exposure to chemicals or 

18 other nonradiological substances. All such potential impacts would be SMALL because all 

19 activities would take place under typical construction workplace safety regulations. No 

20 radiological impacts are expected during facility construction. 

21 

22 Nonradiological impacts during facility operation include worker illnesses and injuries and 

23 impacts from worker or public exposure to hazardous chemicals used or present during 

24 operations, mainly uranium and HF. Due to low estimated concentrations of uranium and HF at 

25 public (proposed property boundary) and workplace receptor locations, nonradiological impacts 

26 due to exposures to hazardous chemicals (including uranium and HF) during operations would 

27 be SMALL. 

28 

29 Assessment of potential radiological impacts from facility operations considers both public and 

30 occupational exposures to radiation, and includes exposures to workers completing the facility 

31 construction during initial phases of operation. Exposure pathways include inhalation of 

32 airborne contaminants, ingestion of contaminated food crops, direct exposure from material 

33 deposited on the ground, and external exposure associated with the stored UF6 cylinders. 

34 Impacts from exposure of members of the public would be SMALL. Worker exposures would 

35 vary by job type, but would be carefully monitored and maintained as low as reasonably 

36 achievable (ALARA) and impacts would be SMALL. 

37 

38 For a hypothetical individual member of the public at the proposed EREF property boundary and 

39 the nearest resident, the maximum annual total effective dose equivalents would be 0.014 

millisievert per year (1.4 millirem per year) and 2.1  10-6 millisievert per year (2.1  10-4 40 millirem 

41 per year), respectively. Dose equivalents attributable to operation of the proposed EREF would 

42 be small compared to the normal background radiation range of 2.0 to 3.0 millisieverts (200 to 

43 300 millirem) dose equivalent. This equates to radiological impacts during proposed EREF 

44 operation that would be SMALL. 

45 

46 The nature of decommissioning activities would be similar to that during construction and 

47 operation. Impacts from occupational injuries and illnesses and chemical exposures would be 

48 SMALL. Occupational radiological exposures would be bounded by the potential exposures 
 xxxviii 

1 during operation, because the quantities of uranium material handled would be less than or 

2 equal to that during operations. An active environmental monitoring and dosimetry (external 

3 and internal) program would be conducted to maintain ALARA doses to workers and to 

4 individual members of the public. Therefore, the impacts of decommissioning on public and 

5 occupational health would be SMALL. 

6 

7 Waste Management 

8 

9 SMALL. Solid nonhazardous wastes generated during preconstruction would be transported 

10 offsite to an approved local landfill. Hazardous wastes (e.g., waste oil, greases, excess paints, 

11 and other chemicals) generated during preconstruction would be packaged and shipped offsite 

12 to a licensed treatment, storage, and disposal facility (TSDF). Impacts from nonhazardous solid 

13 waste and hazardous waste generation during preconstruction would be SMALL due to the 

14 available current or future capacity at local and regional disposal facilities. Construction would 

15 generate about 6116 cubic meters (8000 cubic yards) of nonhazardous solid waste per year, not 

16 including recyclable materials such as scrap structural steel, sheet metal, and piping. About 

17 23,000 liters (6200 gallons) and 1000 kilograms (2200 pounds) of hazardous waste would be 

18 generated annually. The impacts of nonhazardous and hazardous waste generation during 

19 construction would be SMALL due to the available current or future capacity at local and 

20 regional disposal facilities. 

21 

22 During operation, approximately 70,307 kilograms (154,675 pounds) of industrial, 

23 nonhazardous, nonradioactive solid waste and approximately 146,400 kilograms 

24 (322,080 pounds) of low-level radioactive waste (not including depleted UF6) are expected to be 

25 generated annually. The proposed facility would also generate approximately 5062 kilograms 

26 (11,136 pounds) of hazardous wastes and 100 kilograms (220 pounds) of mixed waste 

27 annually. All wastes would be transferred to offsite licensed waste disposal facilities with 

28 suitable disposal capacity. The impacts of this waste generation would be SMALL. 

29 

30 During peak operation, the proposed EREF is expected to generate 1222 cylinders of depleted 

31 UF6 annually, which would be temporarily stored on an outdoor cylinder storage pad in 

32 approved Type 48Y containers before being transported to a DOE-owned or private conversion 

33 facility. Storage of uranium byproduct cylinders at the proposed EREF would occur for the 

34 duration of, but not beyond, the proposed facility’s 30-year operating lifetime. The impacts from 

35 temporary storage of depleted UF6, from the conversion of depleted UF6 to U3O8 at an offsite 

36 location, and from the transportation of the U3O8 conversion product to a potential disposal site 

37 would be SMALL. 

38 

39 During decommissioning, radioactive material from decontamination of contaminated equipment 

40 would be packaged and shipped offsite for disposal. Wastes to be disposed would include 

41 7700 cubic meters (10,070 cubic yards) of low-level radioactive waste. Due to the availability of 

42 adequate disposal capacity, waste management impacts would be SMALL. 

43 

44 Socioeconomics 

45 

46 SMALL. Employment and income impacts were evaluated using an 11-county ROI in Idaho – 

47 including Bannock, Bingham, Blaine, Bonneville, Butte, Caribou, Clark, Fremont, Jefferson, 

48 Madison, and Power Counties. Wage and salary spending and expenditures associated with 
 xxxix 

1 materials, equipment, and supplies would produce income and employment and local and State 

2 tax revenue, resulting in a beneficial impact. Preconstruction would create 308 jobs and 

3 $11.9 million in the first year, and 1687 jobs would be created during the peak year of 

4 construction with $65.0 million of income. Operations would produce 3289 jobs and 

5 $92.4 million in income in the first year of full operations. The jobs created include jobs at the 

6 proposed EREF and those indirectly created elsewhere in the 11-county ROI due to 

7 preconstruction, construction, and operation of the proposed EREF. Because preconstruction 

8 and construction activities would constitute less than 1 percent of total 11-county ROI 

9 employment, the economic impact of constructing the proposed EREF would, therefore, be 

10 SMALL. 

11 

12 As it is anticipated that a number of workers will move into the area during each phase of the 

13 proposed project, with the majority of the demographic and social impacts associated with 

14 population in-migration likely to occur in Bingham and Bonneville Counties, the impacts of the 

15 proposed EREF on population, housing, and community services are assessed for a two-county 

16 ROI, consisting of Bingham and Bonneville Counties. The migration of workers and their 

17 families into surrounding communities would affect housing availability, area community 

18 services such as healthcare, schools, and law enforcement, and the availability and cost of 

19 public utilities such as electricity, water, sanitary services, and roads resulting in an adverse 

20 impact. Because of the small number of in-migrating workers expected during preconstruction, 

21 construction, and operations, the impact on housing and community and educational services 

22 employment would be SMALL. 

23 

24 Decommissioning would provide continuing employment opportunities for some of the existing 

25 workforce and for other residents of the 11-county ROI. Additional, specialized 

26 decommissioning workers would also be required from outside the 11-county ROI. 

27 Expenditures on salaries and materials would contribute to the area economy, although less 

28 than during operations, and the State would continue to collect sales tax and income tax 

29 revenues. The socioeconomic impact of decommissioning activities would be SMALL. 

30 

31 Environmental Justice 

32 

33 SMALL. The potential impacts of the proposed EREF would mostly be SMALL for the resource 

34 areas evaluated. For these resources areas, the impacts on all human populations would be 

35 SMALL. Potential impacts would be SMALL to MODERATE or MODERATE in a few cases, 

36 which could potentially affect environmental justice populations; and there would be LARGE, 

37 though intermittent, short-term impacts from fugitive dist during preconstruction. However, as 

38 there are no low-income or minority populations within the 4-mile area around the proposed 

39 facility, these impacts would not be disproportionately high and adverse for these population 

40 groups. 

41 

42 Impacts of decommissioning would be SMALL. Because impacts on the general population 

43 would generally be SMALL to MODERATE in other resource areas, and because there are no 

44 low-income or minority populations defined according to Council on Environmental Quality 

45 (CEQ) guidelines within the 4-mile area around the proposed facility, decommissioning would 

46 not be expected to result in disproportionately high or adverse impacts on minority or low47 income populations. 

48 
 xl 

1 Accidents 

2 

3 SMALL TO MODERATE. Six accident scenarios were evaluated in this EIS as a representative 

4 selection of the types of accidents that are possible at the proposed EREF. The representative 

5 accident scenarios selected vary in severity from high- to intermediate-consequence events and 

6 include accidents initiated by natural phenomena (earthquake), operator error, and equipment 

7 failure. The consequence of a criticality accident would be high (fatality) for a worker in close 

8 proximity. Worker health consequences are low to high from the other five accidents that 

9 involve the release of UF6. Radiological consequences to a maximally exposed individual (MEI) 

10 at the Controlled Area Boundary (proposed EREF property boundary) are low for all six 

11 accidents including the criticality accident. Uranium chemical exposure to the MEI is high for 

12 one accident and low for the remainder. For HF exposure to an MEI at the proposed property 

13 boundary, the consequence of three accidents is intermediate, with a low consequence 

14 estimated for the remainder. All accident scenarios predict consequences to the collective 

15 offsite public of less than one lifetime cancer fatality. Impacts from accidents would be SMALL 

16 to MODERATE. Plant design, passive and active engineered and administrative controls, and 

17 management of these controls would reduce the likelihood of accidents. 

18 

19 POTENTIAL ENVIRONMENTAL IMPACTS OF THE NO-ACTION ALTERNATIVE 

20 

21 This EIS also considers the potential environmental impacts of the no-action alternative, which 

22 are summarized below. It is assumed that preconstruction activities have taken place under the 

23 no-action alternative. The impact conclusions presented in this EIS for the no-action alternative 

24 address the impacts of denying the license, but do not include the impacts of the NRC-approved 

25 preconstruction activities. This is because a decision by the NRC not to issue the license does 

26 not cause the impacts of preconstruction under the no-action alternative. As described in 

27 Chapter 4, the anticipated environmental impacts from the no-action alternative would range 

28 from SMALL to MODERATE. 

29 

30 Should the nation’s need for enriched uranium continue to increase and necessitate the 

31 construction and operation of another domestic enrichment facility at an alternate location, 

32 impacts could occur for each resource area and could range from SMALL to LARGE. The 

33 nature and scale of these impacts could be similar to those of the proposed action, but would 

34 depend on several facility- and site-specific factors. 

35 

36 Land Use 

37 

38 SMALL. Under the no-action alternative, AES would purchase the proposed property and 

39 restrictions on grazing and agriculture would occur. The zoning designation for the property 

40 would remain G-1 Grazing whether or not the proposed EREF is constructed. Current land 

41 uses of grazing and farming could potentially resume. Impacts to local land use would be 

42 SMALL. 

43 

44 Historic and Cultural Resources 

45 

46 SMALL TO MODERATE. Under the no-action alternative, the proposed EREF would not be 

47 constructed. Site MW004 would not be affected by NRC’s licensing action, and Section 106 of 

48 the National Historic Preservation Act would not apply because no Federal action would be 
 xli 

1 involved. However, the removal of site MW004, which has already occurred, resulted in a 

2 LARGE impact because the site no longer exists; but because AES removed this site through 

3 professional excavation and data recovery and there are other homestead sites of this type 

4 found in the region, the impact has been mitigated to a MODERATE level. No visual or noise 

5 effects would occur to the viewshed for the Wasden Complex. 

6 

7 Visual and Scenic Resources 

8 

9 SMALL. Under the no-action alternative, since the proposed EREF would not be constructed, 

10 no visual intrusions to the existing landscape would occur. The current land cover would be 

11 altered, but no large industrial structures would be constructed. The existing natural character 

12 of the area would largely remain intact. The lack of development would be consistent with 

13 BLM’s VRM Class I designation for the Hell’s Half Acre WSA, and no intrusions to the Wasden 

14 Complex viewshed would occur. 

15 

16 Air Quality 

17 

18 SMALL. Under the no-action alternative, the air quality impacts associated with construction 

19 and operation of the proposed EREF would not occur. The proposed site could revert to 

20 agricultural activities, which would impact ambient air quality through the release of criteria 

21 pollutants from the operation of agricultural vehicles and equipment and the release of fugitive 

22 dusts from the tilling of soils. Local air impacts associated with the no-action alternative would 

23 be SMALL. 

24 

25 Geology and Soils 

26 

27 SMALL. Under the no-action alternative, no additional land disturbance from construction would 

28 occur, and the proposed site could revert to crop production and grazing activities. Wind and 

29 water erosion would continue to be the most significant natural processes affecting the geology 

30 and soils at the proposed site. Impacts would be SMALL. 

31 

32 Water Resources 

33 

34 SMALL. Under the no-action alternative, additional water use may or may not occur, depending 

35 on future plans for the proposed property. Water resources would be unchanged. Water usage 

36 could continue at the current rate should agricultural activities resume at the proposed site. No 

37 changes to surface water quality would be expected, and the natural (intermittent) surface flow 

38 of stormwater on the proposed site would continue. No additional groundwater use or adverse 

39 changes to groundwater quality would be expected. Impacts would be SMALL. 

40 

41 Ecological Resources 

42 

43 SMALL. Most impacts on ecological resources would occur during preconstruction. The 

44 potential impacts associated with the construction, operation, and decommissioning of the 

45 proposed EREF would not occur. Revegetation of the proposed site could occur with renewal of 

46 some wildlife habitat. The land could revert to crop production and grazing activities. Impacts 

47 would be SMALL. 

48 

49 
 xlii 

1 Noise 

2 

3 SMALL. Under the no-action alternative, none of the noise impacts associated with proposed 

4 EREF construction, operation, or decommissioning would occur. Land uses on the proposed 

5 EREF site could revert to previous applications, livestock grazing and/or crop production, with 

6 concomitant noise levels and SMALL impacts. 

7 

8 Transportation 

9 

10 SMALL. Under the no-action alternative, traffic volumes and patterns would remain unchanged 

11 from existing conditions. The current volume of radioactive material and chemical shipments 

12 from other sources in the area would not increase. Impacts would be SMALL. 

13 

14 Public and Occupational Health 

15 

16 SMALL. Under the no-action alternative, health impacts from construction, operation, and 

17 decommissioning would not occur. Worker and public impacts from chemical and radioactive 

18 hazards would also not occur. Should the land be returned to grazing and agriculture, current 

19 use impacts would be expected and would be SMALL. 

20 

21 Waste Management 

22 

23 SMALL. Under the no-action alternative, no proposed EREF construction, operational, or 

24 decommissioning wastes (including sanitary, hazardous, low-level radioactive wastes, or mixed 

25 wastes) would be generated or require disposition. Impacts from waste management would be 

26 SMALL. 

27 

28 Socioeconomics 

29 

30 SMALL. Under the no-action alternative, any beneficial or adverse consequences of the 

31 proposed action would not occur. All socioeconomic conditions in the 11-county ROI would 

32 remain unchanged. Impacts would be SMALL. 

33 

34 Population in the area surrounding the proposed EREF, in Bonneville and Bingham Counties, is 

35 expected to grow in accordance with current projections, with the total population in the region 

36 projected to be approximately 156,491 in 2013 and 168,331 in 2017. In association with 

37 population growth, the social characteristics of the region, including housing availability, school 

38 enrollment, and availability of law enforcement and firefighting resources, are expected to 

39 change over time. However, future changes in these characteristics are difficult to quantify, and 

40 no projections of their future growth are available. 

41 

42 Environmental Justice 

43 

44 SMALL. The no-action alternative would not be expected to cause any high and adverse 

45 impacts. It would not raise any environmental justice issues. 

46 

47 
 xliii 

1 Accidents 

2 

3 SMALL. Under the no-action alternative, potential accidents and accident consequences from 

4 operation of the proposed EREF would not occur. Impacts would be SMALL. 

5 

6 COSTS AND BENEFITS OF THE PROPOSED ACTION 

7 

8 While there are national energy security and fiscal benefits associated with the proposed action, 

9 and local socioeconomic benefits in the 11-county ROI in which the proposed EREF would be 

10 located, there are also direct costs associated with the preconstruction, construction, and 

11 operation phases of the proposed project, as well as impacts on various environmental 

12 resources. These impacts would mostly be SMALL, and in a few cases SMALL to MODERATE, 

13 or MODERATE in magnitude and small in comparison to the local and national benefits of the 

14 proposed action. In addition, most of the impacts to environmental resources associated with 

15 the proposed action would result from preconstruction activities at the proposed site, and would 

16 also occur under the no-action alternative. The principal socioeconomic impact or benefit of the 

17 proposed EREF project would be an increase in employment and income in the 11-county ROI. 

18 Although the majority of the costs, and most of the socioeconomic impacts, of the various 

19 phases of proposed EREF development would occur in the 11-county ROI, there would be 

20 economic, fiscal and, in particular, energy security benefits, which would occur at the local, 

21 State, and national levels. 

22 

23 Average employment created in the 11-county ROI during the year of peak construction is 

24 estimated at 1687 full-time jobs, with $0.7 million in State income tax revenues and $5.1 million 

25 in State sales taxes. During the proposed EREF full operations phase beginning in 2022, 

26 3289 annual jobs would be created. During this period, the State of Idaho would benefit from 

27 $1.3 million annually in income taxes, while Bonneville County would collect $3.5 million 

28 annually in property tax receipts. Although it can be assumed that some portion of paid State 

29 sales and income taxes would be returned to the 11-county ROI under revenue-sharing 

30 arrangements between each county and the State government, the exact amount that would be 

31 received by each county cannot be determined. Although there are economic and fiscal 

32 benefits associated with the proposed action in the 11-county ROI, these impacts would be 

33 SMALL. 

34 

35 The direct costs associated with the proposed action may be categorized by the following life36 cycle stages: facility construction, operation, depleted uranium disposition, and 

37 decommissioning. In addition, costs would be incurred for preconstruction activities under both 

38 the proposed action and the no-action alternative. In addition to monetary costs, the proposed 

39 action would result in impacts on various resource areas, which are considered “costs” for the 

40 purpose of this analysis. The resource areas and corresponding impacts are described in detail 

41 in Chapter 4 of this EIS. As discussed earlier, the impacts of preconstruction and the proposed 

42 action would mostly be SMALL, and in a few cases SMALL to MODERATE, or MODERATE, for 

43 all resource areas. 

44 

45 The proposed action could result in the maximum annual production of 6.6 million SWUs of 

46 enriched uranium in peak years, which would represent an augmentation of the domestic supply 

47 of enriched uranium and, along with other planned new enrichment facilities, would meet the 

48 need for increased domestic supplies of enriched uranium for national energy security. Thus, 
 xliv 

1 the proposed action would generate national and regional benefits and costs. The national 

2 benefit would be an increase in domestic supplies of enriched uranium that would assist the 

3 national energy security need. The regional benefits would be increased employment, 

4 economic activity, and tax revenues in the 11-county ROI. Costs associated with the proposed 

5 project are, for the most part, limited to the resource areas in the 11-county ROI. 

6 

7 COMPARISON OF THE PROPOSED ACTION AND NO-ACTION ALTERNATIVE 

8 

9 The impacts of the proposed action and the no-action alternative are briefly summarized and 

10 compared below. A more detailed summary and comparison is provided in Chapter 2, 

11 Table 2-6. As discussed earlier, it is assumed that the previously discussed preconstruction 

12 activities take place under both alternatives and, therefore, the impacts associated with 

13 preconstruction activities take place regardless of which alternative is selected. As a result, the 

14 comparison of alternatives presented below and in Chapter 2 is intended to highlight the 

15 differences between the two alternatives after preconstruction activities have occurred. 

16 

17 Under the no-action alternative, the proposed EREF would not be constructed, operated, and 

18 decommissioned in Bonneville County, Idaho. The Paducah Gaseous Diffusion Plant in 

19 Paducah, Kentucky, the URENCO USA facility in Lea County, New Mexico, and the 

20 downblending of highly enriched uranium under the Megatons to Megawatts Program would 

21 remain the sole sources of domestically generated low-enriched uranium for U.S. commercial 

22 nuclear power plants. The URENCO USA facility is still under construction and with the ACP, 

23 which is currently under construction, may provide additional enrichment services in the future. 

24 The license application for an additional enrichment facility, the proposed GLE Facility, is 

25 currently under review by the NRC. Foreign enrichment sources would be expected to continue 

26 to supply approximately 85 percent of U.S. nuclear power plants’ demand until new domestic 

27 enrichment facilities are constructed and operated. 

28 

29 The no-action alternative would have SMALL impacts on land use, visual and scenic resources, 

30 air quality, geology and soils, water resources, ecological resources, noise, transportation, 

31 public and occupational health, waste management, socioeconomics, environmental justice, 

32 and facility accidents, and SMALL to MODERATE impacts on historic and cultural resources. 

33 The costs and benefits of constructing, operating, and decommissioning the proposed EREF 

34 would not occur. Additional domestic enrichment facilities could be constructed in the future 

35 with impacts expected to be SMALL to LARGE, depending on facility- and site-specific 

36 conditions. 

37 

38 In comparison to the no-action alternative, the proposed action would also have SMALL impacts 

39 on land use, air quality, geology and soils, water resources, ecological resources, noise, public 

40 and occupational health, waste management, socioeconomics, and environmental justice, but 

41 would have SMALL to MODERATE impacts on historic and cultural resources, visual and scenic 

42 resources, transportation, and facility accidents. The proposed action would have positive 

43 impacts in the region on employment and income, and on State and Federal tax revenues. 

44 

45 CUMULATIVE IMPACTS 

46 

47 This EIS also considers cumulative impacts that could result from the proposed action when 

48 added to other past, present, and reasonably foreseeable future actions (Federal, non-Federal, 

49 or private). No ongoing or planned developments were identified within 16 kilometers (10 miles) 
 xlv 

1 of the proposed project location, which includes the ROI for all affected resource areas except 

2 socioeconomics, which extends to an 80.5-kilometer (50-mile) radius. Proposed developments 

3 within 80.5 kilometers (50 miles) that could contribute to a regional socioeconomic impact in 

4 combination with the proposed project include the proposed Mountain States Transmission 

5 Intertie, a proposed 500-kV electrical transmission line running between western Montana and 

6 southeastern Idaho. The preferred route lies approximately 40 kilometers (25 miles) to the west 

7 of the proposed EREF site, running north-south. Two other alternate routes lie closer, the 

8 nearest running adjacent to the western boundary of the proposed EREF property just outside 

9 of INL property, and the other route crossing US 20 about 10 miles east of the proposed EREF 

10 site. In addition, impacts from the construction of a proposed new 161-kV transmission line, a 

11 substation, and substation upgrades for the proposed EREF are addressed as cumulative 

12 impacts in this EIS, as this action is not under the NRC’s jurisdiction and, therefore, not 

13 considered by the NRC to be part of the proposed action. In general, the anticipated cumulative 

14 impacts from the proposed action would be SMALL. Cumulative impacts associated with the 

15 no-action alternative would be generally less than those for the proposed action, except in terms 

16 of local job creation. 

17 

18 SUMMARY OF ENVIRONMENTAL CONSEQUENCES 

19 

20 Preconstruction activities and the proposed action would result in unavoidable adverse impacts 

21 on the environment. These impacts would mostly be SMALL and SMALL to MODERATE or 

22 MODERATE in a few cases, with the potential for temporary and brief LARGE impacts on air 

23 quality from fugitive dust, and would, in most cases, be mitigated. The area needed for 

24 construction and operation of the proposed EREF would be cleared of vegetation, which would 

25 lead to the displacement of some local wildlife populations. There would be temporary impacts 

26 from preconstruction and the construction of new facilities, including increased fugitive dust, 

27 increased potential for soil erosion and stormwater pollution, and increased vehicle traffic and 

28 emissions. Water consumption from onsite wells would be relatively small, and the risk for 

29 significant adverse impacts on neighboring residential wells or public supply wells would be 

30 SMALL. During operations, workers and members of the public could be exposed to radiation 

31 and chemicals, although the impacts of these exposures would be SMALL. 

32 

33 Preconstruction and the proposed action would necessitate short-term commitments of 

34 resources and would permanently commit certain other resources (such as energy and water). 

35 This EIS defines short-term uses as generally affecting the present quality of life for the public 

36 (i.e., the 30-year license period for the proposed EREF) and long-term productivity as affecting 

37 the quality of life for future generations on the basis of environmental sustainability. The short38 term use of resources would result in potential long-term socioeconomic benefits to the local 

39 area and the region. 

40 

41 Workers, the public, and the environment would be exposed to increased amounts of hazardous 

42 and radioactive materials over the short term from operations of the proposed EREF. 

43 Construction and operation would require a long-term commitment of terrestrial resources, such 

44 as land, water, and energy. Short-term impacts would be minimized by the application of 

45 appropriate mitigation measures. Upon the closure of the proposed EREF, AES would 

46 decontaminate and decommission the buildings and equipment and restore them for 

47 unrestricted use. Continued employment, expenditures, and tax revenues generated during the 

48 proposed action would directly benefit the local, regional, and State economies. 

49 
 xlvi 

1 Irreversible commitment of resources refers to resources that are destroyed and cannot be 

2 restored, whereas an irretrievable commitment of resources refers to material resources that 

3 once used cannot be recycled or restored for other uses by practical means. The proposed 

4 action would include the commitment of land, water, energy, raw materials, and other natural 

5 and human-generated resources. Following decommissioning, the land occupied by the 

6 proposed facility would likely remain industrial beyond license termination. Water required 

7 during preconstruction and the proposed action would be obtained from new and existing wells 

8 at the proposed EREF property and would be replenished through natural mechanisms. 

9 Wastewaters would be treated to meet applicable standards and would evaporate. Energy used 

10 in the form of electricity and diesel fuel would be supplied through new infrastructure connecting 

11 to existing systems in the Idaho Falls area. The specific types of construction materials and the 

12 quantities of energy and materials used cannot be determined until final facility design is 

13 completed, but it is not expected that these quantities would strain the availability of these 

14 resources. 

15 

16 During operation of the proposed EREF, natural UF6 would be used as feed material, requiring 

17 the mining of uranium (not licensed by the NRC) and other front end operational steps in the 

18 uranium fuel cycle (licensed by the NRC). This use of uranium would be an irretrievable 

19 resource commitment. 

20 

21 Even though the land used to construct the proposed EREF would be returned to other 

22 productive uses after the proposed facility is decommissioned, there would be some irreversible 

23 commitment of land at other offsite locations used to dispose of solid wastes generated by the 

24 proposed facility. In addition, wastes generated during the conversion of depleted UF6

25 produced by the proposed facility and the depleted uranium oxide conversion product from the 

26 conversion of depleted UF6 would be disposed at a licensed offsite LLRW disposal facility. Land 

27 used for disposal of these materials would represent an irreversible commitment of land. No 

28 solid wastes or depleted uranium oxide conversion product originating from the proposed EREF 

29 would be disposed of on the proposed EREF property. When the proposed facility is 

30 decommissioned, some building materials would be recycled and reused. Other materials 

31 would be disposed of in a licensed and approved offsite location, and the amount of land used 

32 to dispose of these materials would be an irretrievable land resource. 

33 
 xlvii 

1 ACRONYMS AND ABBREVIATIONS 

2 

234 3 U uranium-234 (U-234) 

235 4 U uranium-235 (U-235) 

235 5 UF6 uranium-235 hexafluoride 

238 6 U uranium-238 (U-238) 

238 7 UF6 uranium-238 hexafluoride 

8 

9 AAC acceptable ambient concentration 

10 AASHTO American Association of State Highway and Transportation Officials 

11 ACHP Advisory Council on Historic Preservation 

12 ACP American Centrifuge Plant 

13 ADAMS Agencywide Documents Access and Management System 

14 AERMOD AMS/EPA Regulatory Model 

15 AES AREVA Enrichment Services, LLC 

16 ALARA as low as reasonably achievable 

17 ANSI American National Standards Institute 

18 APE Area of Potential Effect 

19 Argonne Argonne National Laboratory 

20 ASTM American Society of Testing and Materials 

21 ATSDR Agency for Toxic Substances and Disease Registry 

22 AVLIS Atomic Vapor Laser Isotope Separation 

23 

24 BEA U.S. Bureau for Economic Analysis 

25 BLM U.S. Bureau of Land Management 

26 BLS U.S. Bureau of Labor Statistics 

27 BMP best management practice 

28 BSPB Blending, Sampling, and Preparation Building 

29 

30 CAA Clean Air Act

31 CAB Centrifuge Assembly Building or Controlled Area Boundary 

32 CaF2 calcium fluoride 

33 Cal/EPA California Office of Environmental Health Hazard Assessment 

34 CCS Center for Climate Studies 

35 CDC Centers for Disease Control and Prevention 

36 CEDE committed effective dose equivalent 

37 CEQ Council on Environmental Quality 

38 CFR U.S. Code of Federal Regulations

39 CH4 methane 

40 CTF Centrifuge Test Facility 

41 CO carbon monoxide 

42 CO2 carbon dioxide 

43 CREP Conservation Reserve Enhancement Program 

44 CWA Clean Water Act

45 CY calendar year 

46 

47 D&D decontamination and decommissioning 

48 DDT dichlorodiphenyltrichloroethane 
 xlviii 

1 DEM Digital Elevation Model 

2 DNFSB Defense Nuclear Facilities Safety Board 

3 DNL day/night average noise level 

4 DOC U.S. Department of Commerce 

5 DOE U.S. Department of Energy 

6 DOEQAP DOE Quality Assurance Program 

7 DOL U.S. Department of Labor, U.S. Bureau of Labor Statistics 

8 DOT U.S. Department of Transportation 

9 

10 EA Environmental Assessment 

11 EDE effective dose equivalent 

12 EIA Energy Information Administration 

13 EIS Environmental Impact Statement 

14 EMP Effluent Monitoring Program 

15 EPA U.S. Environmental Protection Agency 

16 ER Environmental Report 

17 ERDA Energy Research and Development Administration 

18 EREF Eagle Rock Enrichment Facility 

19 ESA Endangered Species Act

20 ESRP Eastern Snake River Plain 

21 

22 FBI Federal Bureau of Investigation 

23 FEMA Federal Emergency Management Agency 

24 FGR Federal Guidance Report 

25 FR Federal Register 

26 FTE full-time equivalent 

27 FWCA Fish and Wildlife Coordination Act

28 FWS U.S. Fish and Wildlife Service 

29 

30 GAO U.S. General Accounting Office 

31 GCRP U.S. Global Climate Change Research Program 

32 GDP Gaseous Diffusion Plant 

33 GE General Electric 

34 GEVS Gaseous Effluent Ventilation System 

35 GHG greenhouse gas 

36 GLE Global Laser Enrichment 

37 GWP Global Warming Potential 

38 

39 HAP hazardous air pollutant 

40 HEPA high-efficiency particulate air 

41 HEU high-enriched uranium 

42 HF hydrogen fluoride or hydrofluoric acid 

43 HFC hydrofluorocarbon 

44 HPS Health Physics Society 

45 HRCQ Highway Route Controlled Quantity 

46 HVAC heating, ventilating, and air conditioning 

47 HUD U.S. Department of Housing and Urban Development 

48 

49 
 xlix 

1 I Interstate 

2 IAC Idaho Administrative Code

3 ICRP International Commission on Radiological Protection 

4 IDAPA Idaho Administrative Procedures Act

5 IDC Idaho Department of Commerce 

6 IDEQ Idaho Department of Environmental Quality 

7 IDFG Idaho Department of Fish and Game 

8 IDWR Idaho Department of Water Resources 

9 IGS Idaho Geological Survey 

10 INL Idaho National Laboratory 

11 IPCC Intergovernmental Panel on Climate Change 

12 IPCS International Programme on Chemical Safety 

13 IROFS Items Relied on for Safety 

14 IS Idaho Statutes

15 ISA Integrated Safety Analysis 

16 ISAC Idaho Sage-grouse Advisory Committee 

17 ISACTAT Idaho Sage-grouse Advisory Committee Technical Assistance Team 

18 ISCORS Interagency Steering Committee on Radiation Standards 

19 ISTC Idaho State Tax Commission 

20 ITD Idaho Transportation Department 

21 IWRB Idaho Water Resource Board 

22 

23 LCF latent cancer fatality 

24 Ldn day/night maximum average sound level 

25 Leq equivalent sound level 

26 LES Louisiana Energy Services 

27 LEU low-enriched uranium 

28 LLRW low-level radioactive waste 

29 LOS level of service 

30 LTTS Low Temperature Take-off Stations 

31 LWR light water reactor 

32 

33 MAPEP Mixed Analyte Performance Evaluation Program 

34 MCL maximum contaminant level 

35 MCNP Monte Carlo N-Particle 

36 MDC minimum detectable concentration 

37 MDEQ Montana Department of Environmental Quality 

38 MEI maximally exposed individual 

39 MFC Materials and Fuels Complex 

40 MLIS molecular laser isotope separation 

41 MOA Memorandum of Agreement 

42 MRI Midwest Research Institute 

43 MSL mean sea level 

44 MW(e) Megawatt electric 

45 

46 NAAQS National Ambient Air Quality Standards 

47 NCDC National Climatic Data Center 

48 NCES National Center for Education Statistics 
 l 

1 NCRP National Council on Radiation Protection and Measurements 

2 NEF National Enrichment Facility 

3 NELAC National Environmental Laboratory Accreditation Conference 

4 NELAP National Environmental Laboratory Accreditation Program 

5 NEPA National Environmental Policy Act of 1966

6 NESHAP National Emission Standards for Hazardous Air Pollutants 

7 NHPA National Historic Preservation Act of 1966

8 NIOSH National Institute of Occupational Safety and Health 

9 NIST National Institute of Standards and Technology 

10 NLCD 1992 National Land Cover Data 1992 

11 NMFS National Marine Fisheries Service 

12 NMVOC nonmethane volatile organic compound 

13 NNL National Natural Landmark 

14 N2O nitrous oxide 

15 NO2 nitrogen dioxide 

16 NOAA National Oceanic and Atmospheric Administration 

17 NOI Notice of Intent 

18 NOx nitrogen oxides 

19 NPCR National Program of Cancer Registries 

20 NPDES National Pollutant Discharge Elimination System 

21 NPS National Park Service 

22 NRC U.S. Nuclear Regulatory Commission 

23 NRCP National Council on Radiation Protection 

24 NRCS U.S. Natural Resources Conservation Service 

25 NRHP National Register of Historic Places

26 NWS National Weather Service 

27 

28 O3 ozone 

29 OECD Organisation for Economic Co-operation and Development 

30 OEL occupational exposure levels 

31 OSHA Occupational Safety and Health Administration 

32 

33 PAH polycyclic aromatic hydrocarbon 

34 Pb lead 

35 PCB polychlorinated biphenyl 

36 PFC perfluorocarbon 

37 PGA peak ground acceleration 

38 PM particulate matter 

39 PM2.5 particulate matter equal to or smaller than 2.5 micrometers in diameter 

40 PM10 particulate matter equal to or smaller than 10 micrometers in diameter 

41 PNNL Pacific Northwest National Laboratory 

42 PSD Prevention of Significant Deterioration 

43 PTE Potential to Emit 

44 PWR pressurized water reactor 

45 

46 RAB Restricted Area Boundary 

47 RAI Request for Additional Information 

48 RCRA Resource Conservation and Recovery Act

49 
 li 

1 REMP Radiological Environmental Monitoring Program 

2 RMP Rocky Mountain Power or range management plan 

3 ROI region of influence 

4 ROW right-of-way 

5 

6 SAAQS State Ambient Air Quality Standards 

7 SARA Superfund Amendments and Reauthorization Act

8 SBM Separations Building Module 

9 SDWA Safe Drinking Water Act 

10 SER Safety Evaluation Report 

11 SF6 sulfur hexafluoride 

12 SHPO State Historic Preservation Office(r) 

13 SILEX separation of isotopes by laser excitation 

14 SMCL secondary maximum contaminant level 

15 SO2 sulfur dioxide 

16 SPCC Spill Prevention Control and Countermeasures 

17 SPL sound pressure level 

18 SUNSI Sensitive Unclassified Non-Safeguards Information 

19 SVOC semivolatile organic compound 

20 SWPPP Stormwater Pollution Prevention Plan 

21 SWU separative work unit 

22 

23 TEDE Total Effective Dose Equivalent 

24 TI transportation index 

25 TLD thermoluminescent dosimeter 

26 TRAGIS Transportation Routing Analysis Geographic Information System 

27 TSB Technical Support Building 

28 TSDF treatment, storage, and disposal facility 

29 

30 U3O8 triuranium octaoxide 

31 UO2F2 uranyl fluoride 

32 UBC uranium byproduct cylinder 

33 UF4 uranium tetrafluoride 

34 UF6 uranium hexafluoride 

35 UN United Nations 

36 UNFCCC United Nations Framework Convention on Climate Change 

37 URENCO URENCO Group 

38 USACE U.S. Army Corps of Engineers 

39 U.S.C. United States Code

40 USCB U.S. Census Bureau

41 USDA U.S. Department of Agriculture 

42 USEC U.S. Enrichment Corporation 

43 USGS U.S. Geological Survey 

44 USSLWG Upper Snake Sage-grouse Local Working Group 

45 

46 VOC volatile organic compound 

47 VRI visual resource inventory 

48 
 lii 

1 VRM visual resource management 

2 VTM vehicle miles traveled 

3 

4 WSA Wilderness Study Area 
 1-1 

1 1 INTRODUCTION 

2 

3 1.1 Background 

4 

5 The U.S. Nuclear Regulatory Commission (NRC) prepared this Environmental Impact 

6 Statement (EIS) in response to an application submitted by AREVA Enrichment Services, LLC 

7 (AES) for a license that would allow the construction, operation, and decommissioning of a gas 

8 centrifuge uranium enrichment facility near Idaho Falls in Bonneville County, Idaho (Figure 1-1). 

9 Revisions to the license application were submitted by AES on April 23, 2009 (Revision 1) and 

10 April 30, 2010 (Revision 2). The proposed facility is referred to as the Eagle Rock Enrichment 

11 Facility (EREF). 

12 

13 The NRC’s Office of Federal and State Materials and Environmental Management Programs 

14 prepared this EIS as required by Title 10, “Energy,” of the U.S. Code of Federal Regulations

15 (10 CFR) 51.20(b)(10). In particular, 10 CFR 51.20 (b)(10) states that issuance of a license for 

16 a uranium enrichment facility requires the NRC to prepare an EIS or a supplement to an EIS. 

17 The NRC’s regulations under 10 CFR Part 51 implement the requirements of the National 

18 Environmental Policy Act of 1969, as amended (NEPA) (Public Law 91-190). The Act requires 

19 Federal agencies to assess the potential impacts of their actions affecting the quality of the 

20 human environment. 

21 

22 1.2 The Proposed Action 

23 

24 The proposed action is for AES to construct, operate, and decommission a gas centrifuge 

25 uranium enrichment facility near Idaho Falls, in Bonneville County, Idaho. If the NRC issues a 

26 license to AES under the provisions of the Atomic Energy Act of 1954, the license would 

27 authorize AES to possess and use special nuclear material, source material, and byproduct 

28 material at the proposed EREF for a period of 30 years, in accordance with the NRC’s 

29 regulations in 10 CFR Parts 70, 40, and 30, respectively. The scope of activities to be 

30 conducted under the license would include the construction, operation, and decommissioning of 

31 the proposed EREF. 

32 

33 AES has proposed that the EREF be located on a 186-hectare (460-acre) section of a 

34 1700-hectare (4200-acre) parcel of land that it intends to purchase from a single private 

35 landowner. The only structure presently on the property is a potato storage facility at the south 

36 end of the site. Current land uses of the property include native rangeland, nonirrigated seeded 

37 pasture, and irrigated cropland. 

38 

39 AES plans to conduct preconstruction and construction of the proposed EREF from 2010 to 

2022.1 40 Partial facility operations will commence in 2014, with an 8-year startup period that 

41 would run concurrently with construction activities. The facility is expected to reach full 

42 production capacity in 2022. Decommissioning or potential license renewal activities would 

43 begin in advance of scheduled license expiration (anticipated to be 2041). 

44 

 

1

 As discussed in Section 1.4.1, certain site preparation activities, referred to as “preconstruction” 

activities in this EIS, are explicitly excluded from the definition of construction in 10 CFR 51.4. 

Preconstruction activities are not considered part of the proposed action. 
 1-2 

1 

Figure 1-1 Location of the Proposed Eagle Rock Enrichment Facility (EREF) 2 

3 
 1-3 

1 AES intends that the proposed EREF would help fulfill needs for domestic enriched uranium 

2 capacity for nuclear electrical generation and contribute to national energy security (i.e., provide 

3 additional reliable and economical uranium enrichment capacity in the United States) 

4 (AES, 2010b). This purpose and need are discussed in detail in Section 1.3. 

5 

6 Natural uranium ore usually contains approximately 0.72 weight percent uranium-235, and this 

7 percentage is significantly less than the 3 to 5 weight percent uranium-235 required by the 

8 nuclear power plants currently employed or proposed in the United States and in most other 

9 countries as fuel for electricity generation. Therefore, uranium must be enriched in one of the 

10 steps of the nuclear fuel cycle (Figure 1-2) so it can be used in commercial light-water nuclear 

11 power plants. Enrichment is the process of increasing the percentage of the naturally occurring 

12 and fissile uranium-235 isotope and decreasing the percentage of uranium-238. 

13 

14 AES’s license application seeks authorization to produce enriched uranium up to a nominal 

15 5 percent by weight of uranium-235, which meets the needs of most U.S. power plants. 

16 Enriched uranium from the proposed EREF would be used in commercial light-water nuclear 

17 power plants and is called low-enriched uranium (LEU). Uranium used in military reactors and 

18 nuclear weapons has a much higher percentage of uranium-235 by weight and is called highly 

19 enriched uranium (HEU). 

20 

21 AES has requested a license for a nominal annual production capacity of 6 million separative 

work units (SWUs) per year and a maximum production capacity of 6.6 million SWUs2 22 per year. 

23 An SWU represents the level of effort or energy required to raise the concentration of 

24 uranium-235 to a specified level. 

25 

26 1.3 Purpose and Need for the Proposed Action 

27 

28 As discussed in Section 1.2, the proposed action is for AES to construct, operate, and 

29 decommission a facility to enrich uranium up to 5 percent by weight of uranium-235, with a 

30 nominal annual production capacity of 6 million SWUs and a maximum annual production 

31 capacity of 6.6 million SWUs. The proposed facility would use the gas centrifuge uranium 

32 enrichment process and would be constructed on an undeveloped site in Bonneville County, 

33 Idaho. The proposed action is intended to satisfy the need for an additional economical 

34 domestic source of enriched uranium. 

35 

36 The purpose of the proposed action is to fulfill the following needs: 

37 

38 • the need for enriched uranium to fulfill electricity generation requirements 

39 

40 • the need for domestic supplies of enriched uranium for national energy security 

 

2

 An SWU is a unit of measurement used in the nuclear industry pertaining to the process of enriching 

uranium for use as fuel for nuclear power plants. It describes the effort needed to separate 

uranium-235 and uranium-238 atoms in natural uranium to create a final product that is richer in 

uranium-235 atoms. For 114 kilograms (251 pounds) of natural uranium, it takes about 70 SWUs to 

produce 10 kilograms (22 pounds) of uranium enriched to 5 percent uranium-235. It takes on the 

order of 100,000 SWUs of enriched uranium to fuel a typical 1000-megawatt commercial nuclear 

reactor for a year (USEC, 2009). 
 1-4 

1 

2 Figure 1-2 Nuclear Fuel Cycle (NRC, 2008) 

3 

4 The following sections discuss each of these needs and how each is addressed by the 

5 proposed action. 

6 

7 1.3.1 The Need for Enriched Uranium to Fulfill Electricity Requirements 

8 

9 Enriched uranium from the proposed EREF would be used in U.S. commercial nuclear power 

10 plants. According to the Energy Information Administration (EIA) in its Annual Energy 

11 Outlook 2010 with Projections to 2035 (EIA, 2010a), these plants currently supply approximately 

12 20 percent of the nation’s electricity requirements. As future demand for electricity increases, 

13 the need for LEU to fuel nuclear power plants is also expected to increase (EIA, 2010a). 

14 
 1-5 

1 For the case based on established policies and current trends (the reference case), the EIA 

2 estimates that nuclear capacity grows from 100,600 megawatts in 2008 to 112,900 megawatts 

3 in 2035, including 4000 megawatts of expansion at existing plants and 8400 megawatts of new 

4 capacity (EIA, 2010a). Also, the EIA estimates that nuclear generation will grow from 806 billion 

5 kilowatt hours in 2008 to between 882 and 951 billion kilowatt hours in 2035, depending on the 

6 low- or high-growth scenarios. 

7 

8 The NRC expects to license the next generation of nuclear power plants using 10 CFR Part 52. 

9 Part 52 governs the issuance of standard design certifications (DCs), early site permits (ESPs), 

10 and combined licenses (COLs) for nuclear power plants. The NRC staff is engaged in 

11 numerous ongoing interactions with vendors and utilities regarding prospective new reactor 

12 applications and licensing activities. Based on these interactions, the NRC staff has received a 

13 significant number of new reactor COL applications (COLAs) since 2007. As of December 

14 2010, the NRC is actively reviewing 12 COLAs for a total of 20 nuclear reactor units. The NRC 

15 has suspended 6 COLA reviews due to changes in applicants’ business strategies or the timing 

16 of their construction plans. One of the suspended COLAs was converted by the applicant to an 

17 ESP application. Assuming licensing requirements are met, the NRC is poised to issue two 

18 COLs by the end of 2011. 

19 

20 The NRC has three DC applications and two DC amendment applications currently under 

21 review. As of December 2010, one DC application and one DC amendment are in rulemaking. 

22 The NRC received two Advanced Boiling Water Reactor (ABWR) DC renewal requests in 

23 calendar year 2010 and expects to receive one new DC application by FY2012. 

24 

25 The EIA forecasts of nuclear generating capacity combined with applications from the nuclear 

26 power industry for construction and operation of new plants suggest a continuing, if not 

27 increasing, demand for LEU. In addition, the EIA forecasts that the annual demand for 

28 enrichment services may vary between 12.9 million and 15.7 million SWUs from 2006 through 

29 2025 (EIA, 2003). 

30 

31 The demand for enriched uranium in the United States is currently being fulfilled by three main 

32 categories of supply: 

33 

34 • Domestic production of enriched uranium provides about 15 percent of U.S. demand

35 (EIA, 2010b). The primary uranium enrichment facility currently operating in the 

36 United States is the Paducah Gaseous Diffusion Plant (PGDP) in Paducah, Kentucky, run 

37 by USEC Inc.’s subsidiary, the United States Enrichment Corporation. A similar existing 

38 enrichment facility in the United States is the Portsmouth Gaseous Diffusion Plant in 

39 Piketon, Ohio, but it ceased production in May 2001 and will no longer produce enriched 

40 uranium, as the plant has been placed in cold shutdown (a condition whereby the plant is 

41 undergoing preparation for decommissioning and decontamination) (DOE, 2010a). The 

42 URENCO USA facility (formerly known as the National Enrichment Facility [NEF]) in Lea 

43 County, New Mexico, operated by Louisiana Energy Services LLC (LES), began initial 

44 operations in June 2010. This facility, which is still under construction and will continue to 

45 increase production as its remaining cascade halls are completed, is expected to reach a 

46 capacity of about 1.6 million SWUs per year in August 2011 (about half of its full capacity of 

47 approximately 3 million SWUs per year, as currently licensed by the NRC). Full licensed 

48 capacity would not be reached until sometime later. An expansion to 5.9 million SWUs per 
 1-6 

1 year is being considered by LES, but an application for the expansion has not yet been 

2 submitted to the NRC. 

3 

4 • The Megatons to Megawatts Program provides about 38 percent of U.S. demand

5 (EIA, 2010b). Under this program, the United States Enrichment Corporation implements 

6 the 1993 government-to-government agreement between the United States and Russia that 

7 calls for Russia to convert 500 metric tons (550 tons) of HEU from dismantled nuclear 

8 warheads into LEU (DOE, 2010b). This is equivalent to about 20,000 nuclear warheads. 

9 The United States Enrichment Corporation purchases the enriched portion of the 

10 “downblended” material, tests it to make sure it meets specifications, adjusts the enrichment 

11 level if needed, and then sells it to its electric power generation customers for fuel in 

12 commercial nuclear power plants. All program activities in the United States now take place 

13 at the Paducah plant (NRC, 2006). This program is scheduled to expire in 2013 

14 (DOE, 2010b). 

15 

16 • Other foreign sources provide about 47 percent of U.S. demand. Other countries that 

17 produce and export enriched uranium to the United States include China, France, Germany, 

18 the Netherlands, and the United Kingdom (EIA, 2010b). 

19 

20 The current 5-year average U.S. demand for enriched uranium is approximately 14 million 

21 SWUs per year (EIA, 2010b). As noted, recent forecasts indicate that this demand could reach 

22 15 to 16 million SWUs by 2025, depending on the rate of nuclear generation growth in the 

23 United States (EIA, 2003). From 2005 through 2009, the United States Enrichment Corporation 

24 delivered approximately 10 to 13 million SWUs to customers annually, of which 5.5 million 

25 SWUs per year were from the Megatons to Megawatts Program. Of the remaining 4.5 to 

26 7.5 million SWUs, an average of approximately 2 million SWUs were sold for use in the 

27 United States and the balance exported (USEC, 2010). Therefore, of the amount sold for use in 

28 the United States from 2005 to 2009, approximately 2 million SWUs (about15 percent of U.S. 

29 demand) came from enrichment at the PGDP and 5.5 million SWUs (about 38 percent of 

30 U.S. demand) came from downblending at the Megatons to Megawatts Program, which 

31 depends on deliveries from Russia (EIA, 2010b; USEC, 2010). Accordingly, about 85 percent 

32 (38 percent from the Megatons to Megawatts Program plus 47 percent from other foreign 

33 sources) of U.S. demand is currently supplied by foreign sources. 

34 

35 It is anticipated that all gaseous diffusion enrichment operations in the United States will cease 

36 to exist in the near future due to the higher cost of aging facilities (DOE, 2007). The Megatons 

37 to Megawatts Program is scheduled to expire in 2013 (DOE, 2010b). As noted, these two 

38 sources meet about half (53 percent) of the current U.S. demand for LEU. 

39 

40 To help fill the anticipated supply deficit, other potential future domestic sources of supply have 

41 emerged in recent years. In addition to the URENCO USA facility mentioned above, the USEC 

42 American Centrifuge Plant (ACP) in Piketon, Ohio, has received a license from the NRC 

43 (NRC, 2005, 2006) and is currently under construction. The NRC is currently reviewing a 

44 license application submitted by GE-Hitachi Global Laser Enrichment, LLC (GE-Hitachi) to 

45 construct and operate the proposed Global Laser Enrichment (GLE) Facility in Wilmington, 

46 North Carolina (GE-Hitachi, 2009). The URENCO USA facility and ACP are based on the 

47 gaseous centrifuge technology, while the GLE Facility is based on a newer, laser enrichment 

48 process under development. LES has announced a potential plan to expand the annual 
 1-7 

1 capacity of its URENCO USA facility in New Mexico from 3 million to 5.9 million SWUs per year 

2 in response to customer expressions of the need for additional enrichment services 

3 (URENCO, 2008). However, as noted above, the URENCO USA facility, although currently 

4 operating, is still under construction and is not expected to reach half of its currently licensed 

5 annual capacity of 3 million SWUs per year until August 2011. ACP is licensed to produce 

6 3.5 million SWUs annually. The GE-Hitachi application is for a 6-million-SWU-per-year plant. 

7 Based on the projected need for LEU by existing reactors and proposed new reactors, with the 

8 target capacity of 6.6 million SWUs per year for the proposed EREF (this EIS), the total 

9 projected enrichment capacity in the United States would exceed the projected demand 

10 (approximately 16 million SWUs per year) by about 6 million SWUs per year if all of the 

11 enrichment facilities were constructed and operated at their rated capacities (and assuming the 

12 URENCO USA facility is authorized to operate at 5.9 million SWUs and the Paducah Gaseous 

13 Diffusion Plant is shut down). However, given the uncertainties in future development and/or 

14 potential expansion of the proposed projects, this projected level of extra capacity would not 

15 provide the needed assurance that the enriched uranium would be reliably available when 

16 needed for domestic nuclear power production. 

17 

18 1.3.2 The Need for Domestic Supplies of Enriched Uranium for National Energy Security 

19 

20 All of the current domestic production of enriched uranium currently originates primarily from the 

21 aging gaseous diffusion plant in Paducah, Kentucky, and to a lesser extent from the URENCO 

22 USA facility in Lea County, New Mexico, that began initial operations in June 2010 and is still 

23 under construction. This situation creates a severe reliability risk in U.S. domestic enrichment 

24 capacity. Any disruption in the supply of enriched uranium for domestic commercial nuclear 

25 reactors could have a detrimental impact on national energy security because nuclear reactors 

26 supply approximately 20 percent of the nation’s electricity requirements. The proposed EREF 

27 could play an important role in assuring the nation’s ability to maintain a reliable and economical 

28 domestic source of enriched uranium by providing such additional enrichment capacity. Further, 

29 this additional capacity would lessen U.S. dependence on foreign sources of enriched uranium. 

30 

31 In a letter to the NRC regarding general policy issues raised by the LES license application, the 

32 U.S. Department of Energy (DOE) stated that uranium enrichment is a critical step in the 

33 production of nuclear fuel and noted the decline in domestic enrichment capacity (DOE, 2002). 

34 In its 2002 letter, DOE also referenced comments made by the U.S. Department of State 

35 indicating that “maintaining a reliable and economical U.S. uranium enrichment industry is an 

36 important U.S. energy security objective” (DOE, 2002). The proposed EREF could contribute to 

37 the attainment of national energy security policy objectives by providing an additional domestic 

38 source of enriched uranium. This additional capacity would lessen U.S. dependence on foreign 

39 sources of enriched uranium. 

40 

41 At present, gaseous diffusion is the primary technology currently in commercial use in the 

42 United States. Gaseous diffusion technology has relatively large resource requirements that 

43 make it less attractive than gas centrifuge technology, from both an economic and an 

44 environmental perspective (NRC, 2006). Gas centrifuge technology, used at the URENCO USA 

45 facility, proposed for the EREF, and to be used at the ACP, is known to be more efficient and 

46 substantially less energy-intensive than gaseous diffusion technology. The new laser 

47 enrichment technology proposed for the GLE Facility is still under development. 

48 
 1-8 

1 1.4 Scope of the Environmental Analysis 

2 

3 To fulfill its responsibilities under NEPA, the NRC has prepared this EIS to analyze the 

4 environmental impacts (i.e., direct, indirect, and cumulative impacts) of the proposed EREF as 

5 well as reasonable alternatives to the proposed action. The scope of this EIS includes 

6 consideration of both radiological and nonradiological impacts associated with the proposed 

7 action and the reasonable alternatives. 

8 

9 In addition, this EIS identifies resource uses, monitoring programs, potential mitigation 

10 measures, unavoidable adverse environmental impacts, the relationship between short-term 

11 uses of the environment and long-term productivity, and irreversible and irretrievable 

12 commitments of resources. 

13 

14 The development of this EIS was based on (1) the NRC staff’s review of the AES license 

15 application (AES, 2010a), which includes a supporting Environmental Report, AES’s responses 

16 to Requests for Additional Information (RAIs) (AES, 2009b), and subsequent sage-grouse 

17 survey (North Wind, 2010a) and supplemental wildlife survey report submittals (North 

18 Wind, 2010b); (2) the NRC staff’s review of additional information provided by AES and its 

19 consultants in recent letters to and from State agencies (AES, 2010c; Idaho SHPO, 2010; 

20 WCRM, 2010); (3) the NRC staff’s independent verification and analyses; (4) public and agency 

21 comments received during the scoping period and the Draft EIS public comment period; and 

22 (5) the NRC staff’s consultations with other Federal agencies and with Native American tribes 

23 and State and local government agencies. In addition, the development of this EIS was closely 

24 coordinated with the development of the NRC’s Safety Evaluation Report (SER) (Safety 

25 Evaluation Report for the Eagle Rock Enrichment Facility in Bonneville County, Idaho, NUREG26 1951, September 2010 [NRC, 2010a]), which is the outcome of the NRC safety review of the 

27 AES license application for the proposed EREF. 

28 

29 1.4.1 Scope of the Proposed Action 

30 

31 The scope of the proposed action consists of the construction, operation, and decommissioning 

32 of the proposed EREF. Therefore, all activities associated with these actions must be 

33 considered. Construction activities consist of site preparation (e.g., clearing the land and 

34 construction of access roads) and facility construction (erection of the buildings and structures 

35 concerned with uranium enrichment). A distinction between site preparation and facility 

36 construction is made because of an exemption request submitted by AES as discussed below. 

37 Operation activities include those involved in the enrichment of uranium (shipment, receipt, 

38 storage, and processing of natural uranium and storage and shipment of enriched and depleted 

39 uranium). Decommissioning activities include those involved in facility shutdown such as 

40 equipment and building decontamination for disposal or reuse. 

41 

42 On June 17, 2009, AES submitted a request for exemption (AES, 2009a) from specific NRC 

43 requirements governing “Commencement of Construction” as specified under 10 CFR 70.4, 

44 70.23(a)(7), 30.4, 30.33(a)(5), 40.4, and 40.32(e). This exemption was approved by the NRC 

45 on March 17, 2010 (NRC, 2010b). The exemption allows AES to proceed with certain activities 

46 that are considered outside of NRC regulatory purview (they are not related to radiological 

47 health and safety or the common defense and security) before obtaining an NRC license to 

48 construct and operate the proposed EREF (the proposed action). These activities, discussed 
 1-9 

1 further in Section 2.1.4.1, are referred to as “preconstruction” activities, because they are not 

2 considered construction activities as defined in NRC regulations. See 10 CFR 51.4 (defining 

3 “construction”) and 10 CFR 70.4 (defining “commencement of construction”); also compare 

4 10 CFR 50.2 (defining “construction” and “constructing”) and the NRC’s Final Interim Staff 

5 Guidance COL/ESP-ISG-004 on the Definition of Construction and on Limited Work 

6 Authorizations (NRC, 2009). Specifically, 10 CFR 51.4 states, in relevant part, that 

7 “construction” does not include the following activities: 

8 

9 i. Changes for temporary use of the land for public recreational purposes; 

10 

11 ii. Site exploration, including necessary borings to determine foundation conditions or other 

12 preconstruction monitoring to establish background information related to the suitability 

13 of the site, the environmental impacts of construction or operation, or the protection of 

14 environmental values; 

15 

16 iii. Preparation of a site for construction of a facility, including clearing of the site, grading, 

17 installation of drainage, erosion and other environmental mitigation measures, and 

18 construction of temporary roads and borrow areas; 

19 

20 iv. Erection of fences and other access control measures; 

21 

22 v. Excavation; 

23 

24 vi. Erection of support buildings (such as, construction equipment storage sheds, 

25 warehouse and shop facilities, utilities, concrete mixing plants, docking and unloading 

26 facilities, and office buildings) for use in connection with the construction of the facility; 

27 

28 vii. Building of service facilities, such as paved roads, parking lots, railroad spurs, exterior 

29 utility and lighting systems, potable water systems, sanitary sewerage treatment 

30 facilities, and transmission lines; 

31 

32 viii. Procurement or fabrication of components or portions of the proposed facility occurring 

33 at other than the final, in-place location at the facility; 

34 

35 ix. Manufacture of a nuclear power reactor under a manufacturing license under subpart F 

36 of part 52 of this chapter to be installed at the proposed site and to be part of the 

37 proposed facility; or 

38 

39 x. With respect to production or utilization facilities, other than testing facilities and nuclear 

40 power plants, required to be licensed under Section 104.a or Section 104.c of the Act, 

41 the erection of buildings which will be used for activities other than operation of a facility 

42 and which may also be used to house a facility (e.g., the construction of a college 

43 laboratory building with space for installation of a training reactor). 

44 

45 As indicated in (iii) of the list above, site preparation is one component of preconstruction. As 

46 used in this document, the term “site preparation” includes the items specifically listed in (iii) 

47 above (i.e., clearing of the site, grading, installation of drainage, erosion and other 

48 environmental mitigation measures, and construction of temporary roads and borrow areas). 
 1-10 

1 The NRC’s decision to grant the exemption request to AES was based on the NRC staff finding 

2 that the request to perform certain preconstruction activities is authorized by law, will not 

3 endanger life or property or common defense and security, and is in the public interest. The 

4 exemption covered the following activities and facilities: 

5 

6 • clearing of approximately 240 hectares (592 acres) 

7 

8 • site grading and erosion control 

9 

10 • excavating the site including rock blasting and removal 

11 

12 • constructing a stormwater retention pond 

13 

14 • constructing main access and site roadways 

15 

16 • installing utilities 

17 

18 • erecting fences for investment protection 

19 

20 • constructing parking areas 

21 

22 • erecting construction buildings, offices (including construction trailers), warehouses, and 

23 guardhouses 

24 

25 The authorization to conduct these listed activities or construct the listed facilities prior to the 

26 NRC licensing decision was based on the condition that none of the facilities or activities subject 

27 to the exemption will be, at a later date, a component of AES’s Physical Security Plan or its 

28 Standard Practice Procedures Plan for the Protection of Classified Matter or otherwise subject 

29 to NRC review or approval. Approval of the exemption request does not indicate that a 

30 licensing decision has been made by the NRC. Preconstruction activities would be completed 

31 by AES with the risk that a license may not be issued. Although the activities covered by the 

32 NRC’s March 17, 2010, exemption (NRC, 2010b) are referred to in this document as 

33 “preconstruction” activities, some of these activities may continue after the commencement of 

34 construction, if a license is issued. 

35 

36 These activities authorized under the exemption approval are expected to occur whether or not 

37 the license is granted. As a result, the NRC does not consider these activities as part of the 

38 proposed action or the no-action alternative. However, because they are related to the 

39 construction of the proposed EREF, NRC staff analyzed their impacts in Chapter 4 as part of the 

40 impacts considered under “Preconstruction and Construction.” However, the staff also 

41 attempted, to the extent possible, to separate the impacts from preconstruction and construction 

42 activities into those that would occur as a result of preconstruction activities and those that 

43 would occur as a result of construction activities as defined in 10 CFR 50.2 and 10 CFR 51.4. 

44 The staff also considered all of these impacts in evaluating the cumulative impacts of the EREF 

45 project. 

46 

47 Further, the NRC has no regulatory jurisdiction over the 161-kilovolt (kV) electrical transmission 

48 line that is required to power the EREF (its installation and operation are not related to 
 1-11 

1 radiological health and safety or the common defense and security). Therefore, the installation 

2 and operation of this transmission line is not considered by the NRC to be part of the proposed 

3 action. The installation and operation of this transmission line is considered under cumulative 

4 impacts in Chapter 4 of this EIS. 

5 

6 1.4.2 Scoping Process and Public Participation Activities 

7 

8 The NRC regulations in 10 CFR Part 51 contain requirements for conducting a scoping process 

9 prior to the preparation of an EIS. Scoping was used to help identify the relevant issues to be 

10 discussed in detail in this EIS. Scoping was also used to help determine issues that are beyond 

11 the scope of this EIS, which do not warrant a detailed discussion, or that are not directly 

12 relevant to the assessment of potential impacts from the proposed action. 

13 

14 On May 4, 2009, the NRC published in the Federal Register (74 FR 20508) a Notice of Intent 

15 (NOI) to prepare an EIS for the construction, operation, and decommissioning of the proposed 

16 EREF and to conduct the scoping process for the EIS. The NOI summarized the NRC’s plans 

17 to prepare the EIS and presented background information on the proposed EREF. For the 

18 scoping process, the NOI initiated the public scoping period and invited comments on the 

19 proposed action, and announced a public scoping meeting to be held concerning the project. 

20 

21 On June 4, 2009, the NRC staff held the public scoping meeting in Idaho Falls, Idaho. During 

22 this meeting, a number of individuals offered oral and written comments and suggestions to the 

23 NRC concerning the proposed EREF and the development of the EIS. In addition, the NRC 

24 received written comments from various individuals during the public scoping period that ended 

25 on June 19, 2009. The NRC carefully reviewed the scoping comments (both oral and written) 

26 and then consolidated and categorized these comments by topical areas. 

27 

28 After the scoping period, the NRC issued the Environmental Scoping Summary Report: 

29 Proposed AREVA Enrichment Services Eagle Rock Enrichment Facility in Bonneville County, 

30 Idaho in September 2009. This report is provided in Appendix A. The report identifies

31 categories of issues to be analyzed in detail in the EIS and issues determined to be beyond the 

32 scope of the EIS. 

33 

34 1.4.3 Issues Studied in Detail 

35 

36 As stated in the NOI, the NRC identified issues to be studied in detail as they relate to 

37 implementation of the proposed action. The public identified additional issues during the 

38 subsequent public scoping process. Issues identified by the NRC and the public that could 

39 have short- or long-term impacts from the potential construction and operation of the proposed 

40 EREF include: 

41 

42 • accidents • historic and cultural resources 

43 • alternatives • land use 

44 • air quality • need for the facility 

45 • compliance with applicable regulations • noise 

46 • costs and benefits • public and occupational health 

47 • cumulative impacts • resource commitments 

48 • decommissioning • socioeconomic impacts 
 1-12 

1 • depleted uranium disposition • transportation 

2 • ecological resources • visual and scenic resources 

3 • environmental justice • waste management 

4 • geology and soils • water resources 

5 

6 1.4.4 Issues Eliminated from Detailed Study 

7 

8 The NRC has determined that detailed analysis associated with mineral resources was not 

9 necessary because there are no known nonpetroleum mineral resources at the proposed site 

10 that would be affected by any of the alternatives being considered. 

11 

12 The NRC also determined that detailed analysis of the impact of the proposed EREF on 

13 associated actions that include the overall nuclear fuel cycle activities was not necessary. This 

14 is because the proposed project would not measurably affect uranium mining and milling 

15 operations and the demand for enriched uranium. The amount of mining and milling depends 

16 upon the stability of market prices for uranium balanced with the concern of environmental 

17 impacts associated with such operations (NRC, 1980). The demand for enriched uranium in the 

18 United States is primarily driven by the number of commercial nuclear power plants and their 

19 operation. The proposed EREF would only result in the creation of new transportation routes 

20 within the fuel cycle to and from the enrichment facility. The existing transportation routes 

21 between the other facilities are not expected to be altered. Because the environmental impacts 

22 of all of the transportation routes other than those to and from the proposed EREF have been 

23 previously analyzed, they are eliminated from further study (NRC, 1977, 1980). 

24 

25 1.4.5 Issues Outside the Scope of the EIS 

26 

27 The following issues raised during the scoping process have been determined to be outside the 

28 scope of this EIS: 

29 

30 • safety and security 

31 

32 • credibility of the applicant 

33 

34 • nonproliferation 

35 

36 As noted in Section 1.4, some of these issues are analyzed in detail in the NRC’s SER 

37 (NRC, 2010a) and are only summarized in the EIS. For example, within the area of safety and 

38 security, the SER analyzes the probabilities and consequences of various accidents at the 

39 proposed EREF, as well as measures to prevent those accidents and mitigate their effects. 

40 This EIS does not go into the same level of detail, but provides, in Section 4.2.15, an accident 

41 analysis for the purpose of assessing the potential environmental impacts of accidents. 

42 

43 NRC regulations require that information submitted as part of a license application be complete 

44 and accurate in all material respects. See, e.g., 10 CFR 70.9. At the same time, the general 

45 credibility of an applicant is not an issue the NRC addresses in an EIS. Rather, the NRC 

46 evaluates the submitted application based on its merits and performs an independent 

47 verification of the proposal put forth in the applicant’s application. 

48 
 1-13 

1 The issue of nonproliferation was most recently addressed by the NRC in an August 25, 2010, 

2 letter from NRC Chairman Gregory B. Jaczko to the Honorable John M. Spratt, Jr., 

3 Congressman, U.S. House of Representatives (NRC, 2010c). This letter was in response to 

4 Congressman Spratt’s June 30, 2010, letter (Spratt et al., 2010) in which he requested that the 

5 NRC conduct a nuclear nonproliferation assessment as part of the review of license applications 

6 for new nuclear technologies. The relevant statements from Chairman Jaczko’s letter are as 

7 follows: 

8 

9 “The NRC has adopted a comprehensive regulatory infrastructure and implements an 

10 integrated set of activities directed against the unauthorized disclosure of information 

11 and technology considered important to common defense and security and the diversion 

12 of nuclear materials inimical to public health and safety and the common defense and 

13 security. The NRC’s key regulations in this area (10 CFR Parts 73, 74, and 95) provide 

14 comprehensive requirements governing the control of, and access to, information, 

15 physical security of materials and facilities, and material control and accounting. Other 

16 NRC regulatory requirements are directed at preventing unauthorized disclosure of 

17 classified information, safeguards information (SGI), and sensitive unclassified 

18 nonsafeguards information. As appropriate, the NRC may supplement these 

19 requirements by order consistent with its statutory obligation to protect the common 

20 defense and security and public health and safety.

21 

22 “Beyond the NRC’s regulations, uranium enrichment facility licensees have voluntarily 

23 committed to implement additional measures to protect information associated with 

24 classified enrichment technologies. The Nuclear Energy Institute developed a guidance 

25 document for the enrichment facility licensees and certificate holders which the NRC 

26 staff has endorsed. Licensees are now implementing these additional measures and 

27 incorporating their commitments in their site security plans. These additional measures 

28 and commitments become part of their licensing basis. In addition, the staff is working 

29 with other agencies to provide additional Federal involvement in protecting uranium 

30 enrichment technologies and establishing information protection measures. 

31 

32 “Given the NRC’s comprehensive regulatory framework, ongoing oversight, and active 

33 interagency cooperation, it is the NRC’s current view that a formal nuclear 

34 nonproliferation assessment would not provide any additional benefit to protection of the 

35 common defense and security.... 

36 

37 “I want to assure you that the NRC takes your concerns very seriously and that we will 

38 continue to regulate nuclear materials and sensitive technology to ensure protection of 

39 public health and safety and the environment, promotion of the common defense and 

40 security, and fulfillment of U.S. obligations for nonproliferation and international 

41 agreements.” 

42 

43 Nonproliferation is therefore outside the scope of the EIS. 

44 

45 

46 
 1-14 

1 1.4.6 Draft EIS Public Comment Period and Public Participation Activities 

2 

3 The NRC staff issued the Draft EIS for public review and comment on July 21, 2010, and 

4 announced its availability on that date in the Federal Register (75 FR 4266) in accordance with 

5 10 CFR 51.73, 51.74, and 51.117. The official public comment period on the Draft EIS began 

6 with publication in the Federal Register on July 23, 2010, of a Notice of Availability of the Draft 

7 EIS (75 FR 43160). The 45-day public comment period ended on September 13, 2010. 

8 

9 During the public comment period, the NRC staff held two public comment meetings – in Boise, 

10 Idaho, on August 9, 2010, and in Idaho Falls, Idaho, on August 12, 2010. The NRC staff posted 

11 meeting notices for both meetings in the NRC’s public involvement website. Oral comments on 

12 the Draft EIS were presented by about 50 people at the Boise meeting and about 46 people at 

13 the Idaho Falls meeting. A court reporter recorded the oral comments and other meeting 

14 proceedings and prepared a written transcript for each meeting. In addition to oral comments 

15 received at the public meetings, the NRC staff received written comments on the Draft EIS 

16 during the public meetings, and written comments by postal mail and emails during the public 

17 comment period. The public meeting transcripts and written comments are part of the public 

18 record for the proposed EREF project. 

19 

20 All the comments received by the NRC on the Draft EIS were reviewed and considered by the 

21 NRC staff in developing the Final EIS. In Appendix I of this EIS, these comments are presented 

22 in groups by topic and summarized, and the NRC’s responses to the comments are provided. 

23 The NRC staff made the public comment meeting transcripts part of the public record, contained 

24 in the NRC’s Agencywide Documents Access and Management System (ADAMS). The 

25 meeting transcripts are also available in the NRC’s public website for the proposed EREF 

26 project, at http://www.nrc.gov/materials/fuel-cycle-fac/arevanc.html#3. Other comment 

27 documents were added to ADAMS as they were received by the NRC. 

28 

29 Members of the public can access ADAMS at http://www.nrc.gov/reading-rm/adams.html. From 

30 this website, the transcripts and other comment documents can be accessed by entering their 

31 ADAMS Accession Numbers (or ML numbers). The ADAMS Accession Numbers for the 

32 comment documents are identified in Table I-1 in Appendix I. 

33 

34 In general, the issues identified in the comments were similar to those brought up during the EIS 

35 scoping process (see Section 1.4.2 and Appendix A). The comments received during the Draft 

36 EIS public comment period were on topics in all the major issues and resource areas addressed 

37 in the EIS except for noise and environmental justice. As discussed in Section 1.4.5, issues that 

38 are related to safety and security, nonproliferation, and the credibility of the applicant are not 

39 part of the scope of the EIS. Other safety issues are addressed in the NRC’s SER (NRC, 

40 2010a). 

41 

42 1.4.7 Changes from the Draft EIS 

43 

44 The majority of changes to the Draft EIS that the NRC staff made in preparing the Final EIS 

45 were minor corrections and a number of updates and clarifications. Among these changes, 

46 based on recent project developments or certain comments on the Draft EIS (see Appendix I, 

47 Section I.5), updated or additional information has been included in the EIS in some of the 

48 resource area sections and other sections and appendices, to provide more current or complete 
 1-15 

1 information and/or analyses. The impacts assessed and the NRC staff’s findings and 

2 conclusions remain unchanged for all resource areas. 

3 

4 The most noteworthy of the changes from the Draft EIS are identified below: 

5 

6 Chapter 1 Introduction

7 

8  Information in Sections 1.3.1 and 1.3.2 relating to purpose and need for the proposed 

9 action has been updated. 

10 

11  Additional information explaining why nonproliferation is not within the scope of the EIS 

12 has been added to Section 1.4.5. 

13 

14  Information on the Draft EIS public comment period and associated public participation 

15 activities, and on comments received on the Draft EIS, has been added (see 

16 Section 1.4.6). 

17 

18  Information in Sections 1.5.4.1 and 1.5.4.2 regarding Endangered Species Act and 

19 National Historic Preservation Act (NHPA) consultations, respectively, conducted by the 

20 NRC staff has been updated. 

21 

22 Chapter 2 Alternatives

23 

24  Information in the introduction to Section 2.1 has been updated to indicate that AES 

25 initiated preconstruction activities in late 2010. 

26 

27  Information in Section 2.1.5.1 regarding the status of conversion facilities for depleted 

28 uranium hexafluoride has been updated. 

29 

30  Information in Section 2.2 regarding the no-action alternative has been updated. 

31 

32  Information on mitigation of impacts to historic and cultural resources due to 

33 preconstruction activities, and on the NHPA Section 106 consultation, has been updated 

34 in Table 2-6, Section 2.4, under both the proposed action and no-action alternative. 

35 

36 Chapter 3 Affected Environment

37 

38  Information in Section 3.2.1 regarding the applicability of the Farmland Protection Policy 

39 Act to the proposed EREF project has been updated. 

40 

41  Additional information on seismicity/earthquakes has been added to Section 3.6.1.1. 

42 

43 Chapter 4 Environmental Impacts and Chapter 5 Mitigation

44 

45  Information on mitigation of impacts to historic and cultural resources due to 

46 preconstruction activities, and on the NHPA Section 106 consultation, has been 

47 updated in Sections 4.2.2.1 and 4.2.2.3. 

48 
 1-16 

1  Information on potential visual impacts from construction and operation of the proposed 

2 EREF on the quality of the recreational experience at Hell’s Half Acre Wilderness Study 

3 Area (WSA) has been added to Section 4.2.3.1. 

4 

5  Information on water appropriation and usage during construction and operation was 

6 updated in Sections 4.2.6.1 and 4.2.6.2, respectively. 

7 

8  Additional NRC-recommended mitigation measures for potential impacts to water quality 

9 during preconstruction and construction have been added to Sections 4.2.6.3 and 5.2 

10 (Table 5-3). 

11 

12  Expanded discussions of impacts on sage–grouse during operation of the proposed 

13 EREF have been provided in Sections 4.2.7.2 and 4.3.7. 

14 

15  Additional AES mitigation measures for potential impacts to ecological resources have 

16 been added to Sections 4.2.7.3 and 5.1 (Table 5-1), and additional NRC-recommended 

17 mitigation measures have been added to Sections 4.2.7.2 and 5.2 (Tables 5-3 and 5-4). 

18 

19  For comparison with the original ground-level release calculations, impacts on public 

20 health from elevated releases of radionuclides from the proposed EREF during normal 

21 operation were added in Section 4.2.10.2 (details added in Appendix E, Section E.3.1). 

22 

23  Expanded coverage on solid, liquid, and mixed wastes has been provided in 

24 Section 4.2.11.2. 

25 

26  Section 4.2.12.4 has been added to provide a discussion of the potential effect of a 

27 facility such as the proposed EREF on surrounding property values. 

28 

29  Information has been added to Section 4.2.17 regarding the estimated amount of CO2

30 emissions avoided from coal-burning power plants through use by nuclear power plants 

31 of fuel fabricated from UF6 enriched at the proposed EREF 

32 

33  Clarification on the region of influence (ROI) used in the cumulative impact analysis has 

34 been added to the introduction to Section 4.3 

35 

36  Information on water usage during construction and operation of the proposed EREF 

37 was updated in Section 4.3.6. Also provided in Section 4.3.6 is additional information 

38 on prior contamination of the Eastern Snake River Plain (ESRP) aquifer originating from 

39 Idaho National Laboratory (INL). 

40 

41 Chapter 6 Environmental Measurement and Monitoring Programs

42 

43  Clarifications regarding the groundwater monitoring program have been added to 

44 Section 6.1.5.

45 

46  Additional information has been added to Section 6.2.2.1 regarding ecological 

47 monitoring along the proposed 161-kV transmission line to provide power for the 

48 proposed EREF.
 1-17 

1 Appendix B Consultation Letters

2 

3  Appendix B has been updated to reflect additional consultations conducted since the 

4 Draft EIS was issued.

5 

6 Appendix E Dose Methodology and Impacts

7 

8  Impacts on public health from elevated releases of radionuclides from the proposed 

9 EREF during normal operation were estimated in Section E.3.1 for comparison with the 

10 previously estimated impacts from ground-level releases. 

11 

12 1.4.8 Related Relevant Documents 

13 

14 The following documents were reviewed as part of the development of this EIS. 

15 

16 • Environmental Impact Statement for the Proposed American Centrifuge Plant in Piketon, 

17 Ohio, Final Report. NUREG-1834, Office of Nuclear Material Safety and Safeguards, 

18 U.S. Nuclear Regulatory Commission, April 2006. This EIS analyzes the potential 

19 environmental impacts of the proposed siting, construction, operation, and decommissioning 

20 of a gas centrifuge uranium enrichment facility at the existing DOE reservation in Piketon, 

21 Ohio. Its description of the purpose and need of the proposed action, as well as its review 

22 of alternatives to the proposed action, are highly relevant to the alternatives analysis for the 

23 proposed ERE project. The environmental impacts discussed for the proposed ACP are 

24 also relevant to the impact analysis for the proposed EREF, especially the analysis of 

25 cumulative impacts associated with the management of depleted uranium and low-level 

26 wastes from the proposed EREF, the ACP, the NEF, and the proposed GLE Facility, as well 

27 as the existing DOE inventory of depleted uranium hexafluoride (UF6). 

28 

29 • Environmental Impact Statement for the Proposed National Enrichment Facility in Lea 

30 County, New Mexico, Final Report. NUREG-1790, Office of Nuclear Material Safety and 

31 Safeguards, U.S. Nuclear Regulatory Commission, June 2005. This EIS analyzes the 

32 potential environmental impacts of the proposed siting, construction, operation, and 

33 decommissioning of a gas centrifuge uranium enrichment facility near Eunice, New Mexico. 

34 Its description of the purpose and need of the proposed action, as well as its review of 

35 alternatives to the proposed action, are highly relevant to the alternatives analysis for the

36 proposed EREF project. The environmental impacts discussed for the proposed NEF are 

37 also relevant to the impact analysis for the proposed EREF, especially the analysis of 

38 cumulative impacts associated with the management of depleted uranium and low-level 

39 wastes from the proposed EREF, the ACP, the NEF, and the proposed GLE Facility, as well 

40 as the existing DOE inventory of depleted UF6. 

41 

42 • Final Environmental Impact Statement for the Construction and Operation of a Depleted 

43 Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio, Site. DOE/EIS-0360, 

44 Oak Ridge Operations, Office of Environmental Management, U.S. Department of Energy, 

45 June 2004. This site-specific EIS analyzes the impacts associated with the construction, 

46 operation, and decommissioning of a depleted UF6 conversion facility at the Portsmouth, 

47 Ohio, site. The EIS also evaluates the impacts of transporting cylinders (depleted UF6, 

48 enriched uranium, and empty) to Portsmouth that used to be stored at the East Tennessee 
 1-18 

1 Technology Park near Oak Ridge, Tennessee. Also evaluated are transportation of 

2 depleted UF6 conversion products and waste materials to a disposal facility; transportation 

3 and sale of the hydrogen fluoride produced as a conversion co-product; and neutralization of 

4 hydrogen fluoride to calcium fluoride and the sale or disposal of the calcium fluoride in the 

5 event that the hydrogen fluoride product is not sold. The results presented in the EIS are 

6 relevant to the management, use, and potential impacts associated with the depleted UF6

7 that would be generated at the proposed EREF and the cumulative impacts of depleted UF6

8 from the ACP, the NEF, the proposed EFEF, and the proposed GLE Facility, as well as the 

9 existing DOE inventory of depleted UF6.

10 

11 • Final Environmental Impact Statement for the Construction and Operation of a Depleted 

12 Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky, Site. DOE/EIS-0359, 

13 Oak Ridge Operations, Office of Environmental Management, U.S. Department of Energy, 

14 June 2004. This site-specific EIS is very similar to the EIS for the Portsmouth, Ohio, site, 

15 except that the conversion facility is at the Paducah, Kentucky, site. 

16 

17 • Environmental Assessment: Disposition of Russian Federation Titled Natural Uranium. 

18 DOE/EA-1290, Office of Nuclear Energy, Science and Technology, U.S. Department of 

19 Energy, June 1999. This Environmental Assessment (EA) analyzed the environmental 

20 impacts of transporting natural UF6 from the gaseous diffusion plants to the Russian 

21 Federation. Transportation by rail and truck were considered. The EA addresses both 

22 incident-free transportation and transportation accidents. The results presented in this EA 

23 are relevant to the transportation of UF6 for the proposed EREF. 

24 

25 • Final Programmatic Environmental Impact Statement for Alternative Strategies for the Long26 Term Management and Use of Depleted Uranium Hexafluoride. DOE/EIS-0269, Office of 

27 Nuclear Energy, Science and Technology, U.S. Department of Energy, April 1999. This EIS 

28 analyzes strategies for the long-term management of the depleted UF6 inventory that was 

29 stored at three DOE sites near Paducah, Kentucky; Portsmouth, Ohio; and Oak Ridge, 

30 Tennessee, at the time this EIS was prepared. This EIS also analyzes the potential 

31 environmental consequences of implementing each alternative strategy for the period 1999 

32 through 2039. The results presented in this EIS are relevant to the management, use, and 

33 potential impacts associated with the depleted UF6 that would be generated at the proposed 

34 EREF and the cumulative impacts of depleted UF6 from the ACP, the NEF, the proposed 

35 EREF, and the proposed GLE Facility, as well as the existing DOE inventory of depleted 

36 UF6. 

37 

38 • Advanced Mixed Waste Treatment Project (AMWTP) Final Environmental Impact Statement. 

39 DOE/EIS-0290, Idaho Operations Office, U.S. Department of Energy, January 1999. This 

40 site-specific EIS evaluates the alternatives associated with the treatment and packaging of 

41 stored onsite radioactive waste at the Idaho National Laboratory (INL) site for offsite 

42 disposal. Treatment of offsite radioactive waste is also considered. As the INL is located 

43 within approximately 1 mile of the proposed EREF property located in Bonneville County, 

44 Idaho, the characterization of the affected environment in this EIS is relevant to existing 

45 conditions (e.g., air quality, ecology, geology, and hydrology) at and near the proposed 

46 EREF site. 

47 
 1-19 

1 • Idaho High-Level Waste & Facilities Disposition, Final Environmental Impact Statement. 

2 DOE/EIS-0287, Idaho Operations Office, U.S. Department of Energy, September 2002. 

3 This site-specific EIS evaluates the alternatives associated with the treatment and disposal 

4 of certain mixed wastes (waste with both hazardous and radioactive components) generated 

5 by past spent nuclear fuel reprocessing operations at the INL. As the INL is located within 

6 approximately 1 mile of the proposed EREF property located in Bonneville County, Idaho, 

7 the characterization of the affected environment in this EIS is relevant to existing conditions 

8 (e.g., air quality, ecology, geology, and hydrology) at and near the proposed EREF site. 

9 

10 • Draft Environmental Impact Statement for the Proposed Consolidation of Nuclear 

11 Operations Related to Production of Radioisotope Power. DOE/EIS-0373D, Office of 

12 Nuclear Energy, Science and Technology, U.S. Department of Energy, June 2005. This EIS 

13 analyzes the impacts from the consolidation of facilities necessary for the production of 

14 radioisotope power systems. One site considered is the INL in southeastern Idaho. As the 

15 INL is located within approximately 1 mile of the proposed EREF property located in 

16 Bonneville County, Idaho, the characterization of the affected environment in this EIS for the 

17 INL is relevant to existing conditions (e.g., air quality, ecology, geology, and hydrology) at 

18 and near the proposed EREF site. 

19 

20 1.5 Applicable Statutory and Regulatory Requirements 

21 

22 1.5.1 Applicable State of Idaho Requirements 

23 

24 Certain environmental requirements, including some discussed earlier, have been delegated to 

25 State authorities for implementation, enforcement, or oversight. Table 1-1 provides a list of 

26 State of Idaho environmental requirements. 

27 

28 1.5.2 Permit and Approval Status 

29 

30 Several construction and operating permit applications must be prepared and submitted by AES 

31 or its agents, and regulatory approval and/or permits must be received prior to EREF project 

32 construction or facility operation. Decommissioning of the EREF would be addressed in the 

33 decommissioning plan required pursuant to 10 CFR Parts 30 and 40. Table 1-2 lists the 

34 potentially required Federal, State, and local permits and their present status. 

35 

36 1.5.3 Cooperating Agencies 

37 

38 No Federal, State, or local agencies or tribes have come forward as cooperating agencies in the 

39 preparation of this EIS. 

40 

41 1.5.4 Consultations 

42 

43 The consultation requirements of the Endangered Species Act of 1973 and the National Historic 

44 Preservation Act apply to the NRC regarding the licensing of the proposed EREF. The 

45 consultation correspondence discussed below is provided in Appendix B of this EIS.

46 
 1-20 

Table 1-1 State of Idaho Environmental Requirements 

Law/Regulation Citation Requirements 

Air Pollution Control Idaho Administrative 

Procedures Act (IDAPA) 

58.01.01 authorized by Idaho 

Statutes (IS), Title 39, 

Chapter 1, Environmental 

Quality – Health 

Requires a permit before an owner or 

operator may begin the construction 

or modification of any stationary 

source, facility, major facility, or 

major modification; stationary source 

permit applicants must demonstrate 

compliance with all applicable 

Federal, State, and local emission 

standards, and that the source will 

not cause or significantly contribute 

to a violation of any ambient air 

quality standard. 

Water Quality Standards IDAPA 58.01.02, authorized by 

IS, Title 39, Chapter 1, 

Environmental Quality – 

Health, and Chapter 36, Water 

Quality 

Designates uses for waters in the 

State and establishes water quality 

standards to protect those uses; 

places restrictions on the discharge 

of wastewaters and on human 

activities which may adversely affect 

public health and water quality in 

State waters. 

Public Water Drinking Systems IDAPA 58.01.08 authorized by 

IS, Title 39, Chapter 1, 

Environmental Quality – Health 

Controls and regulates the design, 

construction, operation, 

maintenance, and quality control of 

public drinking water systems; 

adopts 40 CFR Parts 141 and 

143 national primary and secondary 

drinking water regulations by 

reference. Requires a plan that 

demonstrates that the water system 

has adequate technical and 

managerial capacity and written 

approval of the site by the Idaho 

Department of Environmental Quality 

prior to drilling a public water system 

well. 

Hazardous Waste IDAPA 58.01.05 as authorized 

by IS, Title 39, Chapter 44, 

Hazardous Waste 

Management 

Requires hazardous waste permits 

for treating, storing, or disposing of 

hazardous wastes; permit provisions 

are dependent on volumes and types 

of wastes generated and 

management level (i.e., storage, 

treatment, and/or disposal). 
 1-21 

Table 1-1 State of Idaho Environmental Requirements (Cont.) 

Law/Regulation Citation Requirements 

Protection of Graves IS, Title 27, Chapter 5, 

Protection of Graves 

Prohibits willful removal, mutilation, 

defacing, injuring, or destroying any cairn 

or grave; allows excavation by a 

professional archaeologist if action is 

necessary to protect the burial site from 

foreseeable destruction and upon prior 

notification to affected parties. 

Disposal of Radioactive Materials IDAPA 58.01.10 as authorized by 

IS, Title 39, Chapter 44, 

Hazardous Waste Management 

Regulates the disposal of radioactive 

materials not regulated under the Atomic 

Energy Act of 1954, as amended, at 

State-permitted facilities; places 

restrictions on disposal of certain 

radioactive materials at municipal solid 

waste landfills and identifies other 

approved disposal options for radioactive 

materials. Adopts the radiation 

protection standards contained in 

10 CFR Part 20. 

Preservation of Historic Sites IS, Title 67, Chapter 46, 

Preservation of Historic Sites 

Authorizes the governing body of any 

county or city to establish a historic 

preservation commission that can 

conduct surveys of local historic 

properties, acquire interests in them, and 

participate in land use planning. 

Wastewater Rules IDAPA 58.01.16 as authorized by 

IS, Title 39, Chapter 1, 

Environmental Quality – Health, 

and Chapter 36, Water Quality 

Requires the State to certify that the 

NPDES permit issued by the EPA 

complies with the State’s water quality 

standards. 

Well Construction Standards 

Rules 

IDAPA 37.03.09 as authorized by 

IS, Title 42, Chapter 2, 

Appropriation of Water – Permits, 

Certificates, and Licenses – 

Survey 

Establishes minimum standards for the 

construction of all new wells and the 

modification and decommissioning 

(abandonment) of existing wells; applies 

to all water wells, monitoring wells, and 

other artificial openings and excavations 

in the ground that are more than 18 feet 

in vertical depth below land surface. 

Rules Governing Classification 

and Protection of Wildlife 

IDAPA 13.01.06, as authorized by 

IS, Title 36, Chapter 2, 

Classifications and Definitions 

Defines and lists State threatened and 

endangered species and bans taking or 

possessing them. 

Individual/Subsurface Sewage 

Disposal Rules 

IDAPA 58.01.03 as authorized by 

IS, Title 39, Chapter 1, 

Environmental Quality – Health 

Requires a permit to construct, modify, or 

repair individual or subsurface sewage 

disposal systems. 

1 
 1-22 

Table 1-2 Potentially Applicable Permitting and Approval Requirements and Their 

Status for the Construction, Operation, and Decommissioning of the Proposed 

Eagle Rock Enrichment Facility 

License, Permit, or 

Other Required 

Approval 

Responsible Agency Authority Relevance and 

Status 

Federal 

Domestic Licensing of 

Special Nuclear Material, 

Domestic Licensing of 

Source Material, Rules of 

General Applicability to 

Domestic Licensing of 

Byproduct Material 

NRC 10 CFR Part 70, 

10 CFR Part 40, 

10 CFR Part 30 as 

authorized by the 

Atomic Energy Act

Submitted 

NPDES Industrial 

Stormwater Permit 

EPA Region 10 40 CFR Part 122 as 

authorized by the CWA 

Application to be 

submitteda

NPDES Construction 

General Permit 

EPA Region 10 40 CFR Part 122 as 

authorized by the CWA 

Applications to be 

submitted by AES and 

Rocky Mountain 

Powera

 

Section 404 Permit U.S. Army Corps of 

Engineers (USACE) 

40 CFR Part 230 

authorized by the CWA 

Not required per letter 

issued by the USACE 

Endangered Species Act

Consultation 

FWS 50 CFR Part 402 

authorized by the 

Endangered Species 

Act

Not required per letter 

issued by the FWS 

State 

Air: Permit to Construct Idaho Department of 

Environmental 

Quality/Air Quality 

Division (IDEQ/AQD) 

Idaho Administrative 

Procedures Act

(IDAPA) 58.01.01 

authorized by the 

Idaho Environmental 

Protection and Health 

Act

Not required; 

proposed EREF 

satisfies IDAPA 

Permit to Construct 

exemptions 

Air: Operating Permit 

(under Title V) 

IDEQ/AQD IDAPA 58.01.01 

authorized by the 

Idaho Environmental 

Protection and Health 

Act

Not required; 

proposed EREF 

emissions do not 

meet thresholds 

1 
 1-23 

Table 1-2 Potentially Applicable Permitting and Approval Requirements and Their 

Status for the Construction, Operation, and Decommissioning of the Proposed 

Eagle Rock Enrichment Facility (Cont.) 

License, Permit, or 

Other Required 

Approval 

Responsible Agency Authority Relevance and 

Status 

State (Cont.) 

National Emission 

Standards for Hazardous 

Air Pollutants Permit 

IDEQ/AQD IDAPA 58.01.01 

authorized by the 

Idaho Environmental 

Protection and Health 

Act

Not required; 

proposed EREF 

would not be a major 

source of criteria air 

pollutants or source of 

hazardous air 

pollutants 

Hazardous Waste Permit IDEQ/Waste 

Management and 

Remediation Division 

IDAPA 58.01.05 

authorized by the 

Hazardous Waste 

Management Act

Not required; the 

proposed EREF 

qualifies as a small 

quantity generator – a 

generator 

identification number 

will be requested 

NPDES Section 401 

Permit Certification 

IDEQ/Water Quality 

Division (WQD) 

IDAPA 58.01.16 

authorized by the 

Idaho Environmental 

Protection and Health 

Act

Certification decisions 

will be made when 

EPA issues the 

proposed final 

NPDES permits 

Well Drilling Permit Idaho Department of 

Water Resources 

IDAPA 37.03.09 as 

authorized by Title 42 

of the Idaho Statutes

Application to be 

submitted 

Easement on State 

Owned Land 

Department of Lands IDAPA 20.03.08 

authorized by the 

Public Depository Law

Not required; access 

nor easement is 

needed over the 

endowment trust 

lands proximate to the 

proposed EREF 

Safe Drinking Water Act

Drinking Water System 

IDEQ/WQD IDAPA 58.01.08 

authorized by the 

Idaho Environmental 

Protection and Health 

Act

Comprehensive 

treatment plan will be 

prepared; operations 

will be placed under a 

licensed operator 

Sanitary System Permit IDEQ/WQD IDAPA 58.01.03 

authorized by the 

Idaho Environmental 

Protection and Health 

Act

Not required for the 

proposed EREF 

(zero-discharge 

system), but may be 

required for the Visitor 

Center. 

 
 1-24 

Table 1-2 Potentially Applicable Permitting and Approval Requirements and Their 

Status for the Construction, Operation, and Decommissioning of the Proposed 

Eagle Rock Enrichment Facility (Cont.) 

License, Permit, or 

Other Required 

Approval 

Responsible Agency Authority Relevance and 

Status 

State (Cont.) 

Access Permit Idaho Transportation 

Department 

IDAPA 39.03.42 

authorized by Titles 40, 

49, and 67 of the Idaho 

Statutes

Application to be 

submitted 

Construction Permits: 

Electrical, Plumbing, 

HVAC 

Idaho Division of 

Building Safety 

IDAPA 07.01.01, 

07.02.04, 07.07.01 

authorized by Title 54 

of the Idaho Statutes 

Application to be 

submitted 

Machine-produced 

Radiation Registration 

Idaho Department of 

Health and 

Welfare/Radiation 

Control Agency 

IDAPA 16.02.27 

authorized by Title 56 

of the Idaho Statutes

Application to be 

submitted 

County 

Construction Permits: 

Structural, Mechanical

Bonneville County Bonneville County 

Ordinance 218-07

Application to be 

submitted a

 Updates on the NPDES permitting process can be viewed on the EPA website at: 

http://cfpub.epa.gov/npdes/stormwater/noi/noidetail_new.cfm?ApplId=IDR10CI01.

1 

2 1.5.4.1 Endangered Species Act of 1973 Consultation 

3 

4 NRC staff consulted with the FWS to comply with the requirements of Section 7 of the 

5 Endangered Species Act. On June 17, 2009, the NRC staff sent a letter to the FWS Eastern 

6 Idaho Field Office describing the proposed action and requesting a list of threatened and 

7 endangered species and critical habitats that could potentially be affected by the proposed 

8 action. By letter dated July 15, 2009, the FWS Eastern Idaho Field Office indicated that no 

9 listed species are present at the project location. On February 18, 2010, the NRC sent a letter 

10 to the FWS Eastern Idaho Field Office reporting the installation of a proposed electrical 

11 transmission line to power the proposed EREF project and requesting a list of threatened and 

12 endangered species and critical habitats that could potentially be affected by the proposed 

13 transmission line and associated facilities. By letter dated March 9, 2010, the FWS Eastern 

14 Idaho Field Office pointed out that the protections provided to bald eagles under the Bald and 

15 Golden Eagle Protection Act and the Migratory Bird Treaty Act remain in place even though the 

16 bald eagle is no longer included on the list of threatened and endangered species in the lower 

17 48 States. The March letter also referenced the potential of transmission lines to affect 

18 migratory birds. A letter dated July 14, 2010, from the NRC to the FWS Eastern Idaho Field 

19 Office, transmitted a copy of the Draft EIS, summarized the contents of the above 

20 correspondence, and also summarized an April 15, 2010, telephone conversation between the 

21 NRC and Mr. Ty Matthews of the FWS Eastern Idaho Field Office. During that conversation, 

22 Mr. Matthews indicated that the list of endangered, threatened, proposed, and candidate 
 1-25 

1 species provided by the FWS with its March 9, 2010, letter was for Bonneville County in 

2 general; he did not believe that these species are in the vicinity of, or potentially impacted by, 

3 the proposed transmission line project; and consultation by the NRC with the FWS under 

4 Section 7 of the Endangered Species Act would not be needed for these species for the 

5 proposed project. 

6 

7 In addition, the NRC has reviewed the results of field surveys (see Section 4.2.7) and 

8 determined that no threatened or endangered species would be affected by the proposed 

9 EREF. 

10 

11 Additionally, by letters dated June 22, 2009, and June 24, 2009, the NRC communicated with 

12 the Idaho Department of Fish and Game and the Idaho Office of Energy Resources, 

13 respectively, regarding the proposed action. The NRC again corresponded with the Idaho 

14 Department of Fish and Game and the Idaho Office of Energy Resources on February 10, 2010, 

15 and February 18, 2010, respectively, reporting the installation of a transmission line to power 

16 the proposed EREF project. The Idaho Department of Fish and Game (IDFG) corresponded 

17 with the NRC on August 4, 2009, and April 14, 2010. On June 8, 2010, the NRC provided IDFG 

18 with additional information on sage grouse surveys conducted for the project. 

19 

20 1.5.4.2 National Historic Preservation Act of 1966 Section 106 Consultation 

21 

22 Pursuant to Section 106 of the NHPA, in a letter dated June 17, 2009, the NRC initiated 

23 consultation with the Idaho State Historical Society, State Historic Preservation Office (SHPO). 

24 In this letter, the NRC identified the Area of Potential Effect (APE) for the proposed project and 

25 informed the SHPO that archaeological surveys of the APE had been undertaken by a 

26 contractor to AES. Also in the letter, the NRC stated its intent to use the NEPA process to 

27 comply with Section 106 of the NHPA as allowed in 36 CFR Part 800.8. In a letter dated 

28 September 16, 2009, the NRC discussed the AES request to commence preconstruction 

29 activities prior to NRC’s completion of its environmental review. In a letter dated February 17, 

30 2010, the NRC relayed that a 161-kV transmission line would be constructed and operated to 

31 power the proposed EREF and that the APE for the proposed EREF had changed. On April 16, 

32 2010, Argonne National Laboratory (Argonne), on behalf of the NRC, provided the SHPO with 

33 copies of the following AES documents: a report providing information on the proposed 161-kV 

34 transmission line project to provide power to the proposed EREF; a Treatment Plan describing 

35 the process for mitigating the adverse effect from the proposed EREF project to site MW004 

36 (the National Register of Historic Places (NRHP)-eligible John Leopard Homestead) by 

37 professional excavation and data recovery (see Sections 3.3.4 and 4.2.2); a report presenting 

38 the findings of X-ray fluorescence (XRF) analysis conducted on obsidian artifacts found in the 

39 proposed EREF project’s APE; and an archaeological survey report conducted for the 

40 unsurveyed portions of the expanded APE identified in the NRC’s February 17, 2010 letter. In a 

41 letter dated May 3, 2010, the SHPO acknowledged the expanded EREF project footprint and 

42 proposed transmission line project described in the NRC’s February 17, 2010, letter; requested 

43 additional copies and/or clarifications of certain AES cultural resource survey reports; expressed 

44 support for the proposed treatment of (i.e., mitigation of an adverse effect to) site MW004, and 

45 appreciation for receiving a letter report on the XRF analysis of obsidian artifacts; and outlined 

46 the next steps in the consultation process including development of a Memorandum of 

47 Agreement (MOA) between the NRC and the SHPO to define the mitigation of the adverse 

48 effect resulting from the removal of site MW004 as a result of the proposed EREF project. 
 1-26 

1 A letter from the NRC dated July 14, 2010, continued the Section 106 consultation process, 

2 notified the SHPO of the issuance of the Draft EIS, and transmitted copies of the Draft EIS for 

3 the SHPO’s review and comment. In addition, this letter discussed the NRC staff’s 

4 determination of the APE for the proposed EREF and transmission line projects and the staff’s 

5 preliminary determination in the Draft EIS of the impacts on historic and cultural resources that 

6 would result from the preconstruction, construction, operation, and decommissioning of the 

7 proposed project, including the adverse effect on site MW004 and the proposed mitigation of the 

8 adverse effect by professional excavation. In a letter dated July 22, 2010, the SHPO stated that 

9 they had reviewed the Draft EIS and found that the historic and cultural resource sections 

10 accurately reflected the identification efforts conducted to date under Section 106 of the NHPA. 

11 Additionally, the letter recommended that a statement be added in the Final EIS that effects on 

12 site MW004 will be resolved through an MOA. 

13 

14 By letter dated August 31, 2010, the NRC informed the Advisory Council on Historic 

15 Preservation (ACHP) of the adverse effect to site MW004 as a result of the proposed EREF 

16 project and that the NRC is drafting an MOA regarding the mitigation of this adverse effect. 

17 Also, this letter presented the NRC’s invitation to the ACHP to participate in the NHPA Section 

18 106 consultation for the proposed EREF project; provided relevant background information on 

19 the proposed project and on the MOA; and transmitted copies of project consultation letters, 

20 cultural resource survey reports, and related documents. By letter dated September 20, 2010, 

21 the ACHP responded that they do not believe their participation in the consultation to resolve 

22 the adverse effect is needed at this time, but may reconsider this decision if they receive a 

23 request for participation from a consulting party or other party. The ACHP also stated that once 

24 the MOA is signed, it must be filed with the ACHP to complete the requirements of Section 106 

25 of the NHPA. 

26 

27 On June 4, 2009, the NRC met with the Shoshone-Bannock Tribal Council to inform them of the 

28 project. By letter dated July 29, 2009, the NRC formally initiated the Section 106 consultation 

29 process with the Shoshone-Bannock Tribes. By letters dated September 16, 2009, and 

30 February 19, 2010, the NRC continued the consultation process with the Shoshone-Bannock 

31 Tribes regarding the AES request to commence certain activities prior to NRC’s completion of 

32 its environmental review and the installation of the transmission line and associated structures, 

33 respectively. On August 11, 2010, the NRC again met with the Shoshone-Bannock Tribal 

34 Council to discuss, and answer questions about, the proposed project. In a letter dated October 

35 8, 2010, the NRC described the adverse effect to site MW004, informed the Tribes about the 

36 development of an MOA for the proposed EREF project, and invited the Shoshone-Bannock 

37 Tribes to participate in the development of the MOA as a concurring party. In a December 22, 

38 2010, telephone conversation with a tribal representative, the NRC was informed that the 

39 Shoshone-Bannock Tribes want to be a party to the MOA. 

40 

41 Follow-ups on correspondence with the SHPO and the Shoshone-Bannock Tribes were 

42 conducted through subsequent telephone conversations and emails (see Appendix B, 

43 Section B.2). On October 13, 2010, the NRC informed the SHPO, by email, that AES had 

44 begun work on the mitigation of site MW004, in the manner identified in the Treatment Plan 

45 provided to the SHPO with Argonne’s letter dated April 16, 2010. On January 26, 2011, the 

46 NRC informed the SHPO that the Shoshone-Bannock Tribes had accepted the NRC’s invitation 

47 to be a concurring party on the MOA, and about the NRC’s progress on developing a draft of the 
 1-27 

1 MOA for review by the parties. Additional information regarding development of the MOA is 

2 presented in Section 4.2.2.1 of this EIS. 

3 

4 1.6 Organizations Involved in the Proposed Action 

5 

6 Two organizations have specific roles in the implementation of the proposed action: 

7 

8 • AES is the NRC license applicant. If the license is granted, AES would be the holder of an 

9 NRC license to construct, operate, and decommission the proposed EREF and for the 

10 possession and use of special nuclear material, source material, and byproduct material at 

11 the proposed EREF. AES would be responsible for constructing, operating, and 

12 decommissioning the proposed facility in compliance with that license and applicable NRC 

13 regulations. 

14 

15 AES is a Delaware limited liability corporation that was formed solely to provide uranium 

16 enrichment services for commercial nuclear power plants. AES is a wholly owned 

17 subsidiary of AREVA NC Inc. AREVA NC Inc. is a wholly owned subsidiary of the AREVA 

18 NC SA, which is part of AREVA SA (AES, 2010b). AES has indicated that its principal 

19 business location is in Bethesda, Maryland. The NRC intends to examine any foreign 

20 relationship to determine whether it is inimical to the common defense and security of the 

21 United States. The foreign ownership, control, and influence issue is beyond the scope of 

22 this EIS and is addressed as part of the NRC’s SER (NRC, 2010a). 

23 

24 • The NRC is the licensing agency. The NRC has the responsibility to evaluate the license 

25 application for compliance with the NRC regulations associated with uranium enrichment 

26 facilities. These include standards for protection against radiation in 10 CFR Part 20 and 

27 requirements in 10 CFR Parts 30, 40, and 70 that would authorize AES to possess and use 

28 byproduct material, source material, and special nuclear material, respectively, at the 

29 proposed EREF. The NRC is responsible for regulating activities, as applicable, performed 

30 within the proposed EREF through its licensing review process and subsequent inspection 

31 program. To fulfill the NRC responsibilities under NEPA, the environmental impacts of the 

32 proposed project are evaluated in accordance with the requirements of 10 CFR Part 51 and 

33 documented in this EIS. 

34 

35 1.7 References 

36 

37 (AES, 2009a) AREVA Enrichment Services, LLC. Letter from Sam Shakir (President and CEO, 

38 AES) to the U.S. Nuclear Regulatory Commission dated June 17. “Subject: Request for 

39 Exemption from 10 CFR 70.4, 10 CFR 70.23(a)(7), 10 CFR 30.4, 10 CFR 30.33(a)(5), 

40 10 CFR 40.4, and 10 CFR 40.32(e) Requirements Governing ‘Commencement of 

41 Construction.’” ADAMS Accession No. ML091770390. 

42 

43 (AES, 2009b) AREVA Enrichment Services, LLC. Letter from Jim Kay (Licensing Manager, 

44 AES) to the U.S. Nuclear Regulatory Commission dated September 9, 2009. “Subject: 

45 Response to Requests for Additional Information – AREVA Enrichment Services LLC 

46 Environmental Report for the Eagle Rock Enrichment Facility.” ADAMS Accession 

47 No. ML092530636. 

48 
 1-28 

1 (AES, 2010a) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility, Revision 2 

2 to License Application.” April. ADAMS Accession No. ML101610549. 

3 

4 (AES, 2010b) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

5 Environmental Report, Rev. 2.” Bethesda, Maryland. April. ADAMS Accession 

6 No. ML101610549. 

7 

8 (AES, 2010c) AREVA Enrichment Services, LLC. Letter from Jim Kay (Licensing Manager, 

9 AES) to the Idaho Department of Fish and Game dated December 7, 2010. “Subject: Response 

10 to IDFG Comments to NRC Related to the EREF Transmission Line.” ADAMS Accession 

11 No. ML103420579. 

12 

13 (DOE, 2002) U.S. Department of Energy. Letter from W.J. Magwood, IV (U.S. Department of 

14 Energy) to M.J. Virgilio (U.S. Nuclear Regulatory Commission) dated July 25. ADAMS 

15 Accession No. ML022350130. 

16 

17 (DOE, 2007) U.S. Department of Energy. “Uranium Enrichment Decontamination & 

18 Decommissioning Fund 2007 Report to Congress.” Oak Ridge Office and Portsmouth/Paducah 

19 Project Office. <http://www.em.doe.gov/pdfs/5th_triennial_report_final.pdf> (Accessed April 16, 

20 2010). ADAMS Accession No. ML103490664. 

21 

22 (DOE, 2010a) U.S. Department of Energy. “Portsmouth Plant History.” Portsmouth/Paducah 

23 Project Office. January. <http://www.pppo.energy.gov/port_history.html> (Accessed 

24 January 28, 2010). ADAMS Accession No. ML101790051. 

25 

26 (DOE, 2010b) U.S. Department of Energy, National Nuclear Security Administration. 

27 “U.S.-Russian Highly Enriched Uranium Purchase Agreement.” January. <http://www.nnsa. 

28 energy.gov/nuclear_nonproliferation/highly_enriched_uranium_disposition.htm> (Accessed 

29 January 28, 2010). 

30 

31 (EIA, 2003) Energy Information Administration, U.S. Department of Energy. “U.S. Nuclear Fuel 

32 Cycle Projections 2000-2025.” Washington, D.C. January. <http://www.eia.doe.gov/cneaf/ 

33 nuclear/page/forecast/projection.html> (Accessed April 5, 2005). ADAMS Accession 

34 No. ML101790059. 

35 

36 (EIA, 2010a) Energy Information Administration, U.S. Department of Energy. “Annual Energy 

37 Outlook 2010 with Projections to 2035.” DOE/EIA-0383(2010). Washington, D.C. April. 

38 <http://www.eia.doe.gov/oiaf/archive/aeo10/index.html> (Accessed November 15, 2010). 

39 ADAMS Accession No. ML103480627. 

40 

41 (EIA, 2010b) Energy Information Administration, U.S. Department of Energy. “Uranium 

42 Marketing Annual Report.” Washington, D.C. August. <http://www.eia.doe.gov/cneaf/ 

43 nuclear/umar/umar.html> (Accessed November 15, 2010). ADAMS Accession 

44 No. ML103480604. 

45 

46 
 1-29 

1 (GE-Hitachi, 2009) GE-Hitachi Global Laser Enrichment, LLC. “GE-Hitachi Global Laser 

2 Enrichment LLC Commercial Facility Wilmington, North Carolina, License Application.” April 30. 

3 <http://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML091

4 870999> (Accessed August 18, 2009). ADAMS Accession No. ML091870999. 

5 

6 (Idaho SHPO, 2010) Idaho State Historic Preservation Office. Letter from S. Pengilly (Idaho 

7 Deputy SHPO) to J. Kay (AREVA) dated November 26, 2010. “Re: Geotechnical Borings at the 

8 Proposed Twin Buttes Substation within Cultural Resource Site 10BV246 (MW004), Eagle Rock 

9 Enrichment Facility, Bonneville County, Idaho.” ADAMS Accession No. ML110240061. 

10 

11 (North Wind, 2010a) North Wind, Inc. “Sage Grouse Survey Report, Eagle Rock Enrichment 

12 Facility.” May 13. ADAMS Accession No. ML103570078. 

13 

14 (North Wind, 2010b) North Wind, Inc. “Wildlife Survey Report, Eagle Rock Enrichment Facility.” 

15 December 10. ADAMS Accession No. ML103570068. 

16 

17 (NRC, 1977) U.S. Nuclear Regulatory Commission. “Final Environmental Statement on the 

18 Transportation of Radioactive Material by Air and Other Modes.” NUREG-0170, Vol. 1. 

19 December. ADAMS Accession No. ML022590265. 

20 

21 (NRC, 1980) U.S. Nuclear Regulatory Commission. “Final Generic Environmental Impact 

22 Statement on Uranium Milling, Project M-25.” NUREG- 0706. Office of Nuclear Material Safety 

23 and Safeguards. September. ADAMS Accession No. ML032751663. 

24 

25 (NRC, 2005) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for the 

26 Proposed National Enrichment Facility in Lea County, New Mexico.” Final Report. 

27 NUREG-1790, Vol. 1. Office of Nuclear Material Safety and Safeguards, Washington, D.C. 

28 June. <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1790/> (Accessed July 21, 

29 2009). 

30 

31 (NRC, 2006) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for the 

32 Proposed American Centrifuge Plant in Piketon, Ohio.” NUREG-1834. Office of Nuclear 

33 Material Safety and Safeguards, Washington, D.C. April. <http://www.nrc.gov/reading-rm/doc34 collections/nuregs/staff/sr1834/> (Accessed March 26, 2009). 

35 

36 (NRC, 2008) U.S. Nuclear Regulatory Commission. “Typical Stages of the Nuclear Fuel Cycle.” 

37 November 21. <http://www.nrc.gov/materials/fuel-cycle-fac/stages-fuel-cycle.html> (Accessed 

38 August 18, 2009). ADAMS Accession No. ML101790076. 

39 

40 (NRC, 2009) U.S. Nuclear Regulatory Commission. “Final Interim Staff Guidance COL/ESP41 ISG-004 on the Definition of Construction and on Limited Work Authorizations.” February. 

42 ADAMS Accession No. ML090430435. 

43 

44 (NRC, 2010a) U.S. Nuclear Regulatory Commission. “Safety Evaluation Report for the Eagle 

45 Rock Enrichment Facility in Bonneville County, Idaho.” Docket No. 70-7015, AREVA 

46 Enrichment Services, LLC, NUREG-1951, Office of Nuclear Material Safety and Safeguards. 

47 September. ADAMS Accession No. ML102710296. 

48 
 1-30 

1 (NRC, 2010b) U.S. Nuclear Regulatory Commission. Letter from D. Dorman (U.S. Nuclear 

2 Regulatory Commission) to G. Harper (AREVA Enrichment Services, LLC) dated March 17. 

3 “Subject: Approval of AREVA Enrichment Services LLC Exemption Request Related to 

4 Requirements Governing Commencement of Construction (TAC L32730).” ADAMS Accession 

5 No. ML093090152. 

6 

7 (NRC, 2010c) U.S. Nuclear Regulatory Commission. Letter from G. Jaczko (U.S. Nuclear 

8 Regulatory Commission) to J. Spratt, Jr. (U.S. House of Representatives) dated August 25. 

9 ADAMS Accession No. ML10200056. 

10 

11 (Spratt et al., 2010) Letter from J.M. Spratt, Jr., J. Fortenberry, A. Carson, A. Schiff, B. Foster, 

12 and D. Lamborn (U.S. House of Representatives) to G. Jaczko (U.S. Nuclear Regulatory 

13 Commission) dated June 30, 2010. ADAMS Accession No. ML101870023. 

14 

15 (URENCO, 2008) URENCO. “National Enrichment Facility Expansion.” Press release. 

16 December 12. <http://www.urenco.com/content/169/National-Enrichment-Facility17 expansion.aspx> (Accessed February 1, 2010). ADAMS Accession No. ML101790083. 

18 

19 (USEC, 2009) USEC, Inc. “What’s a SWU?” <http://www.usec.com/whatisaswu.htm> 

20 (Accessed July 1, 2010). 

21 

22 (USEC, 2010) USEC, Inc. “Annual Report Pursuant to Section 13 or 15(d) of the Securities 

23 Exchange act of 1934 for the Fiscal Year Ended December 31, 2009.” March 1. 

24 <http://phx.corporate-ir.net/External.File?item=UGFyZW50SUQ9MzcxMTE0fENoaWxk 

25 SUQ9MzY4MDY0fFR5cGU9MQ==&t=1> (Accessed December 9, 2010). ADAMS Accession 

26 No. ML103480637. 

27 

28 (WCRM, 2010) Western Cultural Resources Management, Inc. Letter from J. Sigler (WCRM) to 

29 K. Reid (Idaho Deputy SHPO) dated November 17, 2010. “Re: To Summarize Western 

30 Cultural Resource Management’s Data Recovery Activities for the Eagle Rock Enrichment 

31 Facility Project Located in Bonneville County, Idaho.” ADAMS Accession No. ML103280087. 

32 
 2-1 

1 2 ALTERNATIVES 

2 

3 This chapter describes and compares the proposed action and alternatives to the proposed 

4 action. As discussed in Chapter 1, the proposed action is for AREVA Enrichment Services, LLC 

5 (AES) to construct, operate, and decommission a gas centrifuge uranium enrichment facility, 

6 known as the Eagle Rock Enrichment Facility (EREF), near Idaho Falls, in Bonneville County, 

7 Idaho. In this Environmental Impact Statement (EIS), the U.S. Nuclear Regulatory Commission 

8 (NRC) staff evaluated a reasonable range of alternatives to the proposed action, including 

9 alternative sites for the AES facility, alternative sources of low-enriched uranium, alternative 

10 technologies for uranium enrichment, and the no-action alternative. Under the no-action 

11 alternative, AES would not construct, operate, or decommission the proposed EREF. 

12 Therefore, the no-action alternative provides a basis against which the potential environmental 

13 impacts of the proposed action are evaluated and compared. The EIS also discusses 

14 alternatives for the disposition of depleted uranium hexafluoride (UF6) resulting from enrichment 

15 operations over the lifetime of the proposed EREF. 

16 

17 Section 2.1 presents detailed technical descriptions of the proposed action and related actions, 

18 including descriptions of the proposed site, gas centrifuge enrichment technology, and activities 

19 at the proposed EREF. The activities at the proposed EREF are grouped under preconstruction 

20 and construction, operation, and decontamination and decommissioning. Disposition of 

21 depleted UF6 is also discussed in Section 2.1. Section 2.2 describes the no-action alternative. 

22 Section 2.3 discusses alternatives to the proposed action that were considered but not analyzed 

23 in detail, including alternative sites, enrichment technologies other than the proposed gas 

24 centrifuge technology, and use of alternate sources of enriched uranium. The chapter 

25 concludes with a comparison of predicted environmental impacts of the proposed action and 

26 no-action alternatives (Section 2.4) and a preliminary recommendation from the NRC staff 

27 regarding the proposed action (Section 2.5). 

28 

29 2.1 Proposed Action 

30 

31 The proposed action is for AES to construct, operate, and decommission a gas centrifuge 

32 uranium enrichment facility near Idaho Falls, in Bonneville County, Idaho. To allow the 

33 proposed action, the NRC would need to grant AES a license to possess and use special 

34 nuclear material, source material, and byproduct material at the proposed EREF. The NRC 

35 license, if granted, would be for a period of 30 years (i.e., through 2041), after which AES would 

36 request renewal of the license or begin decommissioning of the proposed facility. AES initiated 

37 preconstruction activities for the proposed EREF in late 2010, under an exemption granted by 

38 NRC (see Section 1.4.1). If NRC grants the license, AES plans to start construction of the 

39 proposed EREF in 2011, begin commercial enrichment operations in 2014, and increase to the 

40 maximum target production capacity by 2022, as shown in Table 2-1. 

41 

42 The location of the proposed site is described in Section 2.1.1. The gas centrifuge enrichment 

43 process and the proposed facility are described in Sections 2.1.2 and 2.1.3, respectively. 

44 Section 2.1.4 describes the phases of the proposed action. The options for management of the 

45 depleted UF6 tails generated at the proposed facility are reviewed in Section 2.1.5. 

46 
 2-2 

Table 2-1 Proposed Eagle Rock Enrichment Facility Schedule 

Milestone Estimated Date 

Initiate Preconstruction Work October 2010 

Requested License Approval February 2011 

Initiate Facility Construction February 2011 

Start First Cascade February 2014 

Complete Heavy Construction February 2018 

Achieve Production Output of 3.3 million SWUs March 2018 

Complete Construction February 2022 

Achieve Full Nominal Production Output March 2022 

Submit Decommissioning Plan to NRC February 2030 

Complete Construction of Decontamination and 

Decommissioning Facility 

February 2032 

Decontamination and Decommissioning Completed February 2041 

Source: AES, 2010a. 

1 

2 Much of the information presented below on the description of the proposed site, the proposed 

3 EREF, and the proposed action and related activities is taken from information provided by AES 

4 in its Environmental Report (AES, 2010a). 

5 

6 2.1.1 Location and Description of the Proposed Site and Vicinity 

7 

8 As shown in Figures 1-1 and 2-1, the proposed EREF, if approved, would be situated on the 

9 north side of US 20, about 113 kilometers (70 miles) west of the Idaho/Wyoming State line. The 

10 proposed EREF would be located approximately 32 kilometers (20 miles) west of Idaho Falls 

11 (the nearest major city), approximately 32 kilometers (20 miles) east of Atomic City, and 

12 approximately 40 kilometers (25 miles), 60 kilometers (37 miles), and 76 kilometers (47 miles) 

13 north of Blackfoot, Fort Hall, and Pocatello, respectively. The Fort Hall Indian Reservation, 

14 which encompasses about 220,150 hectares (544,000 acres), lies to the south. The nearest 

15 boundary of the reservation is about 44 kilometers (27 miles) from the proposed site. The 

16 nearest residence is 7.7 kilometers (4.8 miles) east of the proposed site. The nearest counties 

17 are Bonneville, Jefferson, and Bingham Counties, parts of which are within 8 kilometers 

18 (5 miles) of the proposed site. 

19 

20 The proposed EREF would be located on a 186-hectare (460-acre) site (the “proposed site”) 

21 within a privately owned, approximately 1700-hectare (4200-acre) property (the “property” or 

22 “proposed property”) that would be purchased by AES from a single landowner (AES, 2010a). 

23 Within the 1700-hectare (4200-acre) proposed property are a 16-hectare (40-acre) parcel 

24 administered by the U.S. Bureau of Land Management (BLM) and two additional 16-hectare 

25 (40-acre) parcels for which the Federal Government had reserved rights under the Atomic 

26 Energy Act of 1946, as amended, to certain radioactive materials that might be present 

27 (e.g., uranium, thorium), along with the right to enter the land to prospect for, mine, and remove 
 2-3 

1 

Figure 2-1 Location of the Proposed EREF Site in Bonneville County, Idaho 2 
 2-4 

1 those materials. However, these reservations were subsequently relinquished pursuant to 

2 Section 68.b of the Atomic Energy Act of 1954, as amended, 42 U.S.C. 2098(b), and no longer 

3 have any legal effect on the property (AES, 2010a). The only right-of-way (ROW) on the 

4 proposed property is the ROW for US 20, which forms part of the southern property boundary. 

5 

6 The proposed EREF property consists primarily of relatively flat and gently sloping surfaces with 

7 small ridges and areas of rock outcrop; and is semiarid steppe covered by eolian soils of 

8 variable thickness that incompletely cover broad areas of volcanic lava flows. Uses of this 

9 property, including the proposed EREF site within it, include native rangeland, nonirrigated 

10 seeded pasture, and irrigated cropland. Wheat, barley, and potatoes are grown on 

11 389 hectares (962 acres) of the proposed property. A potato storage facility is located at the 

12 south end. The property is seasonally grazed. 

13 

14 The main land uses within 8 kilometers (5 miles) of the proposed site are grazing and 

15 agriculture. Grazing occurs on State-owned land immediately to the west of the proposed 

16 property and on BLM land immediately to the east. The nearest offsite croplands are located 

17 within about 0.8 kilometer (0.5 mile) of the southeast corner of the proposed property; and the 

18 nearest feedlot and dairy operations are about 16 kilometers (10 miles) to the east. 

19 

20 The eastern boundary of the U.S. Department of Energy’s (DOE) Idaho National Laboratory 

21 (INL) is 1.6 kilometers (1 mile) west of the proposed property. The INL land closest to the 

22 proposed site is undeveloped rangeland. The closest facility on the INL property to the 

23 proposed EREF property is the Materials and Fuels Complex (MFC), located approximately 

24 16 kilometers (10 miles) west of the proposed property boundary. The lands north, east, and 

25 south of the proposed property are a mixture of private-, Federal-, and State-owned parcels. 

26 

27 Structures located within an 8-kilometer (5-mile) radius of the proposed EREF site include a 

28 transformer station (Kettle Substation) adjacent to the proposed site to the east and potato 

29 cellars, one 3.2 kilometers (2 miles) to the west of the proposed site and one 7.7 kilometers 

30 (4.8 miles) to the east. Public use areas in the immediate vicinity of the proposed AES property 

31 include a hiking trail in Hell’s Half Acre Lava Field National Natural Landmark (NNL) on the 

32 south side of US 20 (see Figure 2-1). Hell’s Half Acre is also a Wilderness Study Area (WSA) 

33 and is on Federal land managed by the BLM. There is also a small lava tube cave located 

34 approximately 8 kilometers (5 miles) east and south of the proposed property. The Wasden 

35 Complex, consisting of caves formed by collapsed lava tubes, is located approximately 

36 3.2 kilometers (2 miles) northeast of the footprint of the proposed EREF. 

37 

38 2.1.2 Gas Centrifuge Enrichment Process 

39 

40 The proposed EREF would employ a proven gas centrifuge technology for enriching natural 

41 uranium (NRC, 2005b). Figure 2-2 shows the basic construction of a gas centrifuge. The 

42 technology uses a rotating cylinder (rotor) spinning at a high circumferential rate of speed inside 

43 a protective casing. The casing maintains a vacuum around the rotor and provides physical 

44 containment of the rotor in the event of a catastrophic rotor failure. 

45 

46 Uranium hexafluoride (UF6) gas is fed through a fixed pipe into the middle of the rotor, where it 

47 is accelerated and spins at almost the same speed as the rotor. The centrifugal force produced 

by the spinning rotor causes the heavier uranium-238 hexafluoride (238 48 UF6) molecules to 
 2-5 

1 concentrate close to the rotor wall and the lighter 

uranium-235 hexafluoride (235 2 UF6) molecules to collect 

3 closer to the axis of the rotor. This separation effect 

4 initially occurs only in a radial direction, which increases 

5 when the rotation is supplemented by a convection 

6 current produced by a temperature difference along the 

7 rotor axis (thermoconvection). A centrifuge with this kind 

8 of gas circulation (i.e., from top to bottom near the rotor 

9 axis and from bottom to top by the rotor wall) is called a 

10 counter-current centrifuge. 

11 

12 The inner and outer streams become more 

13 enriched/depleted in uranium-235 in their respective 

14 directions of movement. The biggest difference in 

15 concentration in a counter-current centrifuge does not 

16 occur between the axis and the wall of the rotor, but 

17 rather between the two ends of the centrifuge rotor. In 

18 the flow pattern shown in Figure 2-2, the enriched UF6 is 

19 removed from the lower end of the rotor and the depleted 

20 UF6 is removed at the upper end through take-off pipes 

21 that run from the axis close to the wall of the rotor. 

22 

23 The enrichment level achieved by a single centrifuge is 

24 not sufficient to obtain the desired concentration of 3 to 

25 5 percent by weight of uranium-235 in a single step; 

26 therefore, a number of centrifuges are connected in 

27 series to increase the concentration of the uranium-235

28 isotope. Additionally, a single centrifuge cannot process 

29 a sufficient volume for commercial production, which 

30 makes it necessary to connect multiple centrifuges in 

31 parallel to increase the volume flow rate. The 

32 arrangement of centrifuges connected in series to 

33 achieve higher enrichment and in parallel for increased 

34 volume is called a “cascade.” A full cascade contains 

35 hundreds of centrifuges connected in series and parallel. 

36 Figure 2-3 is a diagram of a segment of a uranium 

37 enrichment cascade showing the flow path of the UF6

38 feed, enriched UF6 product, and depleted UF6 gas. In the 

39 proposed EREF, 12 cascades would be grouped in a 

40 Cascade Hall, and each Separations Building Module 

41 (SBM) would house two Cascade Halls. There would be four identical SBMs in the full-capacity 

42 plant. 

43 

44 2.1.3 Description of the Proposed Eagle Rock Enrichment Facility 

45 

46 The major facility buildings and structures in the proposed EREF are described in 

47 Section 2.1.3.1. Section 2.1.3.2 describes the supporting utilities. Site access would be via the 

48 local road network, as discussed in Section 2.1.3.3. 

Figure 2-2 Schematic of a Gas 

Centrifuge (NRC, 2009a) 
 2-6 

1 

2 

3 

4 Figure 2-3 Diagram of Enrichment Cascade (NRC, 2005b) 

5 

What Is Enriched Uranium? 

Uranium is a naturally occurring radioactive element. In its natural state, uranium contains 

approximately 0.72 percent by weight of the uranium-235 isotope, which is the fissile isotope of 

uranium. There is a very small (0.0055 percent) quantity of the uranium-234 isotope, and most of the 

remaining mass (99.27 percent) is the uranium-238 isotope. All three isotopes are chemically identical 

and only differ slightly in their physical properties. The most important difference between the isotopes 

is their mass. This small mass difference allows the isotopes to be separated and makes it possible to 

increase (i.e., “enrich”) the percentage of uranium-235 in the uranium to levels suitable for nuclear 

power plants or, at very high enrichment, nuclear weapons. 

Most civilian nuclear power reactors use low-enriched uranium fuel containing 3 to 5 percent by 

weight of uranium-235. Uranium for most nuclear weapons is enriched to greater than 90 percent. 

Uranium would arrive at the proposed EREF as natural UF6 in solid form in a Type 48X or 

48Y transport cylinder from existing conversion facilities in Port Hope, Ontario, Canada; Metropolis, 

Illinois; or overseas sources. To start the enrichment process, the cylinder of UF6 is heated, which 

causes the material to sublime (change directly from a solid to a gas). The UF6 gas is fed into the 

enrichment cascade where it is processed to increase the concentration of the uranium-235 isotope. 

The UF6 gas with an increased concentration of uranium-235 is known as “enriched” or “product.” 

Gas with a reduced concentration of uranium-235 is referred to as “depleted” UF6 or “tails.” 

Source: NRC, 2005b. 
 2-7 

1 2.1.3.1 Major Facility Buildings and Structures 

2 

3 Buildings/structures within the proposed EREF will include the following: 

4 

5 • Cylinder Storage Pads 

6 

7 • Centrifuge Assembly Building 

8 

9 • Separations Building Modules 

10 

11 • Cylinder Receipt and Shipping Building 

12 

13 • Blending, Sampling, and Preparation Building 

14 

15 • Technical Support Building 

16 

17 • Operations Support Building 

18 

19 • Electrical and Mechanical Services Buildings 

20 

21 • Administration Building 

22 

23 • Visitor Center 

24 

25 • Security and Secure Administration Building 

26 

27 The main process facilities at the proposed EREF are the four SBMs, with each identical unit 

28 capable of handling approximately one-quarter of plant capacity (AES, 2010a). Each SBM 

29 consists of two Cascade Halls. Each Cascade Hall is able to produce enriched UF6 with a 

30 specific assay (weight percent uranium-235), giving the proposed EREF the capability of 

31 producing up to eight different assays at one time. 

32 

33 Cylinder Storage Pads

34 

35 Concrete storage pads would be constructed for storing full feed cylinders (Type 48Y) 

36 containing natural UF6 prior to use in the enrichment process, full tails cylinders (Type 48Y) 

37 containing depleted UF6 after the enrichment process, full product cylinders (Type 30B) 

38 containing enriched UF6 after the enrichment process, and empty feed, tails, and product 

39 cylinders. There will be a total of four pads (one pad for each of the above uses), although the 

40 empty tails pad will bisect the full tails cylinder pad. 

41 

42 The pads for storage of the full feed cylinders, full tails cylinders, and empty cylinders would be 

43 located next to each other on the north side of the proposed facility. The pad capacities would 

44 be 712 full feed cylinders, 25,718 full tails cylinders, and 1840 empty cylinders. The feed 

45 cylinders would be single-stacked, while the tails and empty cylinders would be double-stacked. 

46 The pad for empty cylinders would be sized to temporarily store these cylinders for up to six 

47 months. The full tails cylinders would be stacked two high in concrete saddles that would 

48 elevate them approximately 20 centimeters (8 inches) above ground level. The pad for full tails 
 2-8 

1 cylinders would be expanded as additional 

2 storage is required up to the maximum expected 

3 facility lifetime generation of 25,718 cylinders, if 

4 necessary (AES, 2010a). Figure 2-4 shows a 

5 cylinder stacking operation using a specialized 

6 carrier. 

7 

8 Full product cylinders would be single-stacked 

9 on a single pad adjacent to the Cylinder Receipt 

10 and Shipping Building. The pad would be sized 

11 to accommodate approximately 1032 cylinders. 

12 

13 Centrifuge Assembly Building

14 

15 The Centrifuge Assembly Building would be 

16 used for the assembly, inspection, and 

17 mechanical testing of the centrifuges prior to installation in the Cascade Halls. The building 

18 would be separated into areas for centrifuge component storage, centrifuge assembly, and 

19 assembled centrifuge storage. This building would also contain the Centrifuge Test and 

20 Postmortem Facilities that would be used to test the functional performance and operational 

21 problems of production centrifuges and ensure compliance with design parameters in addition to 

22 providing an area for the dismantlement of potentially contaminated centrifuges and also to 

23 prepare for their disposal. 

24 

25 Separations Building Modules

26 

27 The eight proposed Cascade Halls would be contained in four identical Separations Building 

28 Modules near the center of the proposed EREF. Figure 2-5 is a photograph of centrifuges 

29 inside a Cascade Hall at URENCO. Each of the eight proposed Cascade Halls would house 

30 12 cascades, and each cascade would consist of hundreds of centrifuges connected in series 

31 and parallel to produce enriched UF6. Each Cascade Hall would be capable of producing a 

32 maximum of 825,000 separative work units (SWUs) per year. 

33 

34 The centrifuges would be mounted on precast concrete floor-mounted stands (flomels). Each 

35 Cascade Hall would be enclosed by a structural steel frame supporting insulated sandwich 

36 panels (metal skins with a core of insulation) to maintain a constant temperature within the 

37 cascade enclosure. 

38 

39 In addition to the Cascade Halls, each SBM would house a UF6 Handling Area and a Process 

40 Service Corridor. The UF6 Handling Area would contain the UF6 feed input system as well as 

41 the enriched UF6 product and depleted UF6 take-off systems. The Process Service Corridor 

42 would contain the gas transport piping and equipment, which would connect the cascades with 

43 each other and with the product and depleted materials take-off systems. The Process Service 

44 Corridor would also contain key electrical and cooling water systems. 

45 

46 

Figure 2-4 Stacking Depleted UF6

Cylinders in a Storage Yard 

(DOE, undated a) 
 2-9 

1 

2 Figure 2-5 Centrifuges inside a Cascade Hall (NRC, 2005b) 

3 

4 Cylinder Receipt and Shipping Building

5 

6 All UF6 cylinders (feed, product, and tails) would enter and leave the proposed EREF through 

7 the Cylinder Receipt and Shipping Building. Full feed and empty product and tails cylinders 

8 delivered to the proposed EREF would be inspected, unloaded off the transport trucks, and sent 

9 to their appropriate locations. Outgoing cylinders (empty feed and full product and tails) would 

10 be prepared for shipment, including overpack protection as necessary, and loaded on the 

11 transport trucks. 

12 

13 Blending, Sampling, and Preparation Building

14 

15 The primary function of the Blending, Sampling, and Preparation Building would be filling and 

16 sampling the Type 30B product cylinders with UF6 enriched to customer specifications. Other 

17 activities within the building would include cylinder preparation, inspection, testing, and 

18 maintenance. The Ventilation Room, which is also located in this building, would provide a set19 aside area for testing and inspecting Type 30B, 48X, and 48Y cylinders for use in the proposed 

20 EREF. The Ventilation Room would be maintained under negative pressure and would require 

21 entry and exit through an airlock. 

22 

23 
 2-10 

1 Technical Support Building

2 

3 The Technical Support Building would contain radiological support areas for the proposed 

4 facility and would act as the secure point of entry to the SBMs and the Blending, Sampling, and 

5 Preparation Building. This building would contain the following functional areas: 

6 

7 • The Radiation Monitoring Room would separate the uncontaminated areas from the 

8 potentially contaminated areas of the proposed plant. It would include personnel radiation 

9 monitoring equipment, hand-washing facilities, and safety showers. 

10 

11 • The Laundry Sorting Room would be used to sort potentially contaminated and soiled 

12 clothing and similar articles according to their level of contamination for either disposal or 

13 laundering onsite or offsite. 

14 

15 • The Solid Waste Collection Room would be used for processing wet and dry low-level solid 

16 waste. 

17 

18 • The Liquid Effluent Collection and Treatment Room would be used to collect, monitor, and 

19 treat potentially contaminated liquid effluents produced onsite. 

20 

21 • The Truck Bay/Shipping and Receiving Area would be used to load and ship low-level 

22 radioactive and hazardous wastes to licensed treatment and disposal facilities. 

23 

24 • The Gaseous Effluent Ventilation System would be used to remove uranium and other 

25 radioactive particles and hydrogen fluoride from the potentially contaminated process gas 

26 streams. 

27 

28 • The Decontamination Workshop would provide a facility for removing radioactive 

29 contamination from contaminated materials and equipment. 

30 

31 • Other workshops would provide space for maintenance of chemical traps, mobile vacuum 

32 pump skids, valves, and pumps. 

33 

34 • The Maintenance Facility would provide space for the normal maintenance of contaminated 

35 equipment used at the proposed EREF, as well as all instrument and control equipment, 

36 lighting, power, and associated processes and pipe work. 

37 

38 • The Laboratory Areas contain rooms for the receipt, preparation, analysis, and storage of 

39 various samples. A number of chemical analysis methods used for uranium isotope 

40 measurement and UF6 quality assurance are available including mass spectrometry, atomic 

41 emission spectroscopy, alpha/beta/gamma counting, and gas Fourier transform infrared 

42 spectrometry. 

43 

44 Operation Support Building

45 

46 The Operation Support Building would be located next to the Technical Support Building and 

47 would provide nonradiological support functions for the proposed EREF. This building would 

48 contain the following functional areas: 

49 
 2-11 

1 • The Control Room would be the main monitoring point for the entire plant and provide all of 

2 the facilities for the control of the plant. 

3 

4 • The Security Alarm Center would be the primary security monitoring station for the proposed 

5 facility. All electronic security systems would be controlled and monitored from this center. 

6 

7 • Workshops for the maintenance and repair of uncontaminated plant equipment would be 

8 provided. The Vacuum Pump Rebuild Workshop would service pumps and other 

9 miscellaneous equipment. The Mechanical, Electrical, and Instrumentation Workshop would 

10 service pump motors, all instrument and control equipment, lighting, power, and associated 

11 process and services pipe work. 

12 

13 • The Medical Room would provide space for a nurse’s station and room for medical 

14 examinations. 

15 

16 • The Environmental Laboratory Area would provide rooms and space for various laboratory 

17 areas that receive, prepare, and store various samples. 

18 

19 Electrical and Mechanical Services Buildings

20 

21 The Electrical Services Building would be adjacent to the north side of the SBMs, housing four 

22 standby diesel generators. Building heating, ventilation, and air-conditioning equipment as well 

23 as switchgears and control panels would be housed in the building. 

24 

25 The Mechanical Services Building would be located south of the SBMs, housing air 

26 compressors, demineralized water systems, and the centrifuge cooling water system pumps, 

27 heat exchangers, and expansion tanks. 

28 

29 Administration Building

30 

31 The Administration Building would contain general office areas. All personnel access to the 

32 proposed EREF would occur through the Administration Building. 

33 

34 Visitor Center

35 

36 The Visitor Center would be located outside the security fence close to US 20. 

37 

38 Security and Secure Administration Building

39 

40 The Security and Secure Administration Building would be near the Administration Building. 

41 The building would contain secure office areas and would provide the only access (the Entry 

42 Exit Control Point) to the inside areas of the proposed EREF. Personnel must first pass through 

43 the Administration Building to gain access to the Security and Secure Administration Building. 

44 

45 
 2-12 

1 2.1.3.2 Utilities 

2 

3 The proposed EREF would require the installation of water and electrical utility lines. Natural 

4 gas will not be used. Sanitary waste would be treated in a packaged domestic Sanitary Sewage 

5 Treatment Plant. 

6 

7 Water for the proposed facility would be provided from onsite groundwater wells. The proposed 

8 EREF’s water requirement is expected to be approximately 24,900 cubic meters per year 

9 (6,570,000 gallons per year) in support of plant operations. Of this, approximately 2100 cubic 

10 meters per year (554,800 gallons per year) would be consumed by plant processes and 

11 22,800 cubic meters per year (6,023,000 gallons per year) would be used for potable water 

12 (AES, 2010a). 

13 

14 The proposed EREF is anticipated to require approximately 64 megavolt-amperes (MVA) of 

15 power when all cascades are in operation (AES, 2010a). A new 161-kV electrical transmission 

16 line would be run from the existing Bonneville Substation approximately 16 kilometers (10 miles) 

17 east of the proposed EREF site (AES, 2010a). The new transmission line and associated 

18 structures would be located entirely on private land within Bonneville County. Rocky Mountain 

19 Power, a division of PacifiCorp, will be the builder, owner, and operator. The line would extend 

20 west from the Bonneville Substation 14.5 kilometers (9 miles) to the Kettle Substation, 

21 continuing an additional 1.2 kilometers (0.75 mile) to the west to the proposed EREF property. 

22 Once on the property, the transmission line would go to the north and then circle to the west and 

23 south around the proposed EREF site to the proposed new Twin-Buttes Substation, which 

24 would be adjacent to the proposed EREF site. The entire length of the transmission line would 

25 be approximately 22.1 kilometers (13.8 miles) (AES, 2010a). 

26 

27 A packaged sanitary sewage treatment system (Domestic Sanitary Sewage Treatment Plant) 

28 would be installed onsite for the collection and treatment of sanitary and uncontaminated liquid 

29 wastes. Residual treated effluent from the system would be discharged to the two single-lined 

30 Cylinder Storage Pads Stormwater Retention Basins where it would evaporate. The total 

31 annual discharge from the system is expected to be approximately 18,700 cubic meters per 

32 year (4,927,500 gallons per year) (AES, 2010a). This sanitary discharge source is not expected 

33 to contain any uranic material. Solid sanitary wastes from the treatment system would be 

34 temporarily stored in a holding tank and disposed of at an approved offsite location. 

35 

36 2.1.3.3 Local Road Network 

37 

38 The proposed EREF property lies immediately north of US 20, approximately 32 kilometers 

39 (20 miles) west of Idaho Falls and the junction of US 20 and Interstate 15 (I-15). US 20 extends 

40 from Idaho Falls in the east to the junction with US 26 northwest of Atomic City. The proposed 

41 EREF property lies along this route where US 20 is a two-lane highway. Access to the 

42 proposed EREF site would be from two planned access roads to US 20 (see Figure 2-6). All 

43 traffic to and from the proposed EREF (for construction, employees, and shipments) would use 

44 one of these access roads (AES, 2010a). Controlled and public access to these roads has yet 

45 to be determined by AES. 

46 

47 The primary shipping route for all of the proposed EREF’s incoming and outgoing truck 

48 shipments would be eastbound US 20 to its intersection with I-15, which is the major 
 2-13 

1 

2 Figure 2-6 Site Plan for the Proposed Eagle Rock Enrichment Facility (AES, 2010a) 

3 

4 north-south access to the region. The nearest interstate highway access to the west would be 

5 I-84, which intersects US 20 approximately 296 kilometers (184 miles) away from the proposed 

6 site. Idaho Falls is also served by US 26 and US 91. 

7 

8 2.1.4 Description of the Phases of the Proposed Action 

9 

10 As discussed previously, the proposed action would be conducted in three phases: 

11 (1) preconstruction and construction, (2) facility operation, and (3) decontamination and 

12 decommissioning. Each of these phases is described in the following sections. The general 

13 site plan is shown in Figure 2-6. 

14 
 2-14 

1 2.1.4.1 Preconstruction and Construction Activities 

2 

3 Preconstruction

4 

5 As discussed in Section 1.4.1, the NRC has approved an exemption request from AES 

6 (AES, 2009) to conduct certain preconstruction activities prior to the NRC issuing a license to 

7 AES for the construction, operation, and decommissioning of the proposed EREF. The 

8 exemption (NRC, 2010a) covers the following activities and facilities: 

9 

10 • clearing the site (e.g., removal of vegetation and debris) 

11 

12 • site grading and erosion control 

13 

14 • excavating the site including rock blasting and removal 

15 

16 • installing parking areas 

17 

18 • constructing the stormwater detention pond 

19 

20 • constructing two highway access roadways and site roads 

21 

22 • installing utilities (e.g., temporary and permanent power) and storage tanks 

23 

24 • installing fences for investment protection (not used to implement the Physical Security 

25 Plan) 

26 

27 • installing construction buildings, offices (including construction trailers), warehouses, and 

28 guardhouses 

29 

30 Conventional earthmoving and grading equipment would be used to clear and grade the site. In 

31 some areas, blasting and rock excavation may be required. Preconstruction for the proposed 

32 EREF would affect approximately 240 hectares (592 acres) on the 1700-hectare (4200-acre) 

33 proposed property. The disturbed area would consist of 186 hectares (460 acres) for 

34 construction activities (see below), including future permanent plant structures, and an 

35 additional 53.6 hectares (132.5 acres) for temporary construction facilities, parking areas, 

36 material storage, and excavated areas for underground utilities. The total disturbed area would 

37 be cleared of vegetation, and approximately 164.9 hectares (407.5 acres) would be graded. 

38 Grading would include cutting and filling approximately 778,700 cubic meters (27,500,000 cubic 

39 feet) of soil (AES, 2010a). 

40 

41 Facility Construction

42 

43 Facility construction would encompass the erection of the SBMs and facility support structures 

44 described in Section 2.1.3. All major facility support structures would be constructed in the first 

45 3 years (2011–2013). The first SBM would be completed in 2014, and heavy construction 

46 would continue into 2018 when the second SBM would become operational. During this period 

47 of heavy construction (2011–2018), typical building construction activities would take place 

48 involving the construction trades and associated truck deliveries of concrete, steel and steel 
 2-15 

1 reinforcement, wiring, piping, and other building materials. Scrap pieces of construction debris 

2 would be trucked offsite to local landfills. Hazardous waste would be sent to an appropriately 

3 licensed facility for treatment and disposal. 

4 

5 By early 2018, SBMs 1 and 2 would be fully operational and the building shells for SBMs 3 and 

6 4 would have been erected. After 2018, truck delivery of centrifuge components would occur 

7 during the latter phase of construction as centrifuges are installed in the remaining SBMs with 

8 completion of the last SBM in 2022. 

9 

10 Temporary construction buildings and warehouses would be removed after facility construction 

11 is complete. Also, temporary construction areas, such as laydown areas, would be restored at 

12 this time. 

13 

14 2.1.4.2 Facility Operation 

15 

16 The proposed EREF would be constructed in stages to allow enrichment operations to begin 

17 while additional Cascade Halls are still under construction. Facility operation would commence 

18 with limited production after the completion of the first cascade. This ramped production 

19 schedule would allow the proposed facility to begin operation only 3 years after the license is 

20 issued. Production of enriched UF6 product would increase from approximately 825,000 SWUs 

21 in the third year to a maximum of 6.6 million SWUs by the 10th year and start to ramp down 

22 again in the 24th year (AES, 2010a). 

23 

24 At full production, the proposed EREF would employ an estimated 550 full-time workers and 

25 receive up to 17,518 metric tons (19,310 tons) per year, in up to 1424 Type 48Y cylinders, of 

26 UF6 feed material containing a concentration of 0.72 percent by weight of the uranium-235

27 isotope (AES, 2010a). The natural UF6 feed material would be processed by the cascades to 

28 generate up to 2252 metric tons (2482 tons) of low-enriched UF6 product and 15,270 metric tons 

29 (16,832 tons) of depleted UF6 material each year. 

30 

31 The subsections below discuss operations in detail, including receipt of UF6 feed material, 

32 generation of UF6 product, shipping UF6 product, generation rate of depleted UF6 tails, and 

33 supporting production process systems. 

34 

35 Receiving UF6 Feed Material

36 

37 The natural feed material would be shipped to the proposed EREF in standard Type 48Y 

38 cylinders. This cylinder is a U.S. Department of Transportation-approved container for 

39 transporting Type A material (DOE, 1999a). The radioactive materials transported in this 

40 container are subject to 10 CFR Part 71 and 49 CFR Parts 171 to 173 shipping regulations. 

41 These regulations include requirements for an internal pressure test without leakage, free drop 

42 test without loss or dispersal of UF6, and thermal test requirements without rupture of the 

43 containment system. In addition, shipments would be required to have fissile controls. A fully 

44 loaded Type 48Y cylinder contains approximately 12 metric tons (14 tons) of material and is 

45 shipped one per truck (DOE, 1999b). After receipt and inspection, the cylinder could be stored 

46 until needed or connected to the gas centrifuge cascade at one of several feed stations 

47 discussed in the next section. Once installed in the feed station, the transport cylinders would 
 2-16 

1 be heated to sublime the solid UF6 into a gas that would be fed to the gas centrifuge enrichment 

2 cascade. 

3 

4 AES anticipates receiving feed cylinders at the proposed EREF from U.S. and foreign origins. 

5 In the United States, the UF6 production facility is located in Metropolis, Illinois. The proposed 

6 EREF would receive feed cylinders from foreign UF6 production facilities through ports in 

7 Baltimore, Maryland; and Portsmouth, Virginia; as well as from Port Hope, Ontario, Canada. 

8 

9 After each feed cylinder has been emptied, it would be inspected and processed for reuse. The 

10 proposed EREF would have the capability to provide for internal cleaning or decontamination of 

11 the cylinders in the Blending, Sampling, and Preparation Building. This capability is intended for 

12 preparation of the 30B enriched product cylinders, but could be used for empty feed cylinders if 

13 necessary (AES, 2010a). The empty Type 48Y feed cylinders would be used as tails cylinders 

14 to store depleted UF6 material on the Cylinder Storage Pads or would be returned to the 

15 supplier (empty feed cylinder with a “heel”). 

16 

17 Producing Enriched UF6 Product

18 

19 The enrichment process would begin with sublimation of the solid UF6 into the gas phase and 

20 purification of the gaseous UF6. The UF6 would then be routed through the centrifuge cascades 

21 where enriched and depleted streams would be created, as discussed in Section 2.1.2. The 

22 enriched product stream and the depleted waste stream would exit the cascades separately and 

23 would be desublimed (solidified) in their respective systems. These four major elements of the 

24 enrichment process would occur in the following systems contained in the SBMs (AES, 2010b): 

25 

26 • UF6 Feed System 

27 

28 • Cascade System 

29 

30 • Product Take-off System 

31 

32 • Tails Take-off System 

33 

34 In the UF6 Feed System, feed cylinders would be loaded into Solid Feed Stations, vented for 

35 removal of light gases, primarily air and hydrogen fluoride (HF), and heated to sublime the UF6. 

36 The light gases and UF6 gas generated during feed purification would be routed to the Feed 

37 Purification Subsystem where the UF6 would be desublimed in cold traps and the HF would be 

38 captured in chemical traps. The UF6 would be then sublimed again and routed into the cascade 

39 system. 

40 

41 After sublimation and purification, the UF6 would be routed through the centrifuge cascades in 

42 the Cascade System. As discussed in Section 2.1.2, each centrifuge has a thin-walled, vertical, 

43 cylindrically shaped rotor that spins around a central post within an outer casing. Feed, product, 

44 and tails streams would enter and leave the centrifuge through the central post. Control valves, 

45 restrictor orifices, and controllers would provide uniform flow of product and tails. 

46 

47 Depleted UF6 exiting the cascades would be transported from the high vacuum of the centrifuge 

48 for desublimation into Type 48Y tails cylinders at subatmospheric pressure. This process would 
 2-17 

1 occur in the Tails Take-off System. The primary equipment in this system includes vacuum 

2 pumps and the Tails Low Temperature Take-off Stations (LTTS). Chilled air would flow over 

3 cylinders in the Tails LTTS to effect the desublimation. Filling of the Type 48Y cylinders would 

4 be monitored with a load cell system, and filled cylinders would be transferred outdoors to the 

5 Full Tails Cylinder Storage Pad. 

6 

7 In the Product Take-off System, enriched UF6 from the cascades – low-enriched product 

8 between 3 and 5 percent by weight of the uranium-235 isotope – would be desublimed into Type 

9 30B product cylinders. The Product Take-off System consists of vacuum pumps, product LTTS, 

10 UF6 cold traps, and vacuum pump/chemical trap sets. The pumps would transport the UF6 from 

11 the cascades to the Product LTTS at subatmospheric pressure. The heat of desublimation of 

12 the UF6 would be removed by cooling air routed through the LTTS. The product stream 

13 normally would contain small amounts of light gases that may have passed through the 

14 centrifuges. Therefore, a UF6 cold trap and vacuum pump/trap set would be provided to vent 

15 these gases from the Type 30B product cylinder. Any UF6 captured in the cold trap is 

16 periodically transferred to another product cylinder for use as product or blending stock. Filling 

17 of the product cylinders would be monitored with a load cell system, and filled cylinders would 

18 be transferred to the Product Liquid Sampling System for sampling. 

19 

20 Blending stock would be used in the Product Blending System, which would be used to produce 

21 enrichment levels other than those produced in any given Cascade Hall. The system would 

22 contain donor stations for two donor cylinders of different assays and a receiver station. 

23 Operation of the donor and receiver stations would be similar to that for the Solid Feed Stations 

24 and the LTTS, respectively. The Product Liquid Sampling System would use autoclaves to 

25 liquefy the UF6 in Type 30B product cylinders. Samples would be extracted from each cylinder 

26 to verify the product assay level (weight percent uranium-235). 

27 

28 Supporting functions of the enrichment process would include sample analysis, equipment 

29 decontamination and rebuild, liquid effluent treatment, and solid waste management. All gas30 phase processes would be conducted at subatmospheric pressures to mitigate hazards, should 

31 a break in the process lines or equipment occur. 

32 

33 Shipping Enriched Product

34 

35 Enriched UF6 product would be shipped in a Type 30B cylinder, which is 76 centimeters 

36 (30 inches) in diameter and 206 centimeters (81 inches) long and holds a maximum of 

2.3 metric tons (2.5 tons) of 5-percent enriched 235 37 UF6. Figure 2-7 shows Type 30B enriched 

38 product cylinders and overpacks loaded for transport. At full production, the proposed EREF 

39 would produce approximately 1032 enriched product cylinders annually for shipment to 

40 customers. Potential customers are fuel fabrication facilities in Richland, Washington; 

41 Columbia, South Carolina; Wilmington, North Carolina; and overseas through ports at 

42 Portsmouth, Virginia, and Baltimore, Maryland. 

43 

44 Depleted UF6 Generation

45 

46 During operation of the proposed EREF, the production of depleted UF6 material would increase 

47 from 1909 metric tons (2105 tons) per year during initial production to 15,267 metric tons 

48 (16,830 tons) per year during peak production. This material would fill between 153 and 
 2-18 

1 

2 Figure 2-7 Truck Loaded with Five 30B Enriched Product Cylinders 

3 Loaded for Transport in Their Protective Overpacks 

4 (DOE, undated b) 

5 

6 1222 Type 48Y cylinders per year. Table 2-2 shows the potential maximum expected quantity 

7 of cylinders that would be filled with depleted UF6 material each year during the anticipated life 

8 of the proposed EREF. The values presented reflect the sequential startup and shutdown of the 

9 cascades. 

10 

11 Production Process Support Systems

12 

13 Enriched UF6 would be the primary product of the proposed EREF. Production of enriched UF6

14 would require the safe operation of multiple plant support systems to ensure the safe operation 

15 of the proposed facility. The supporting process systems required for the safe and efficient 

16 production of enriched UF6 product would include the following (AES, 2010b): 

17 

18 • Gaseous Effluent Ventilation Systems (GEVSs) 

19 

20 • Liquid Effluent Collection and Treatment System 

21 

22 • Centrifuge Test and Postmortem Facilities Exhaust Filtration System 

23 

24 • Solid Waste Collection System 

25 

26 • Decontamination System 

27 

28 Gaseous Effluent Ventilation Systems

29 

30 Gaseous effluent ventilation systems for each SBM and for the Technical Services Building 

31 would be designed to collect the potentially contaminated gaseous effluent streams in the plant 

32 and treat them before discharge to the atmosphere. Each system would route these streams 

33 through a filter system prior to exhausting out a vent stack, which would contain a continuous 
 2-19 

Table 2-2 Depleted UF6 Tails Generationa

Years 

(number after 

license is issued) 

Annual Number 

of 48Y Tails 

Cylinders 

Cumulative 

Number of 48Y 

Tails Cylinders 

1 0 0 

2 0 0 

3 153 153 

4 306 459 

5 459 918 

6 611 1529 

7 764 2293 

8 917 3210 

9 1069 4279 

10 to 23 1222 5501 to 21,387 

24 1069 22,456 

25 917 23,373 

26 764 24,137 

27 611 24,748 

28 459 25,207 

29 306 25,513 

30 166 25,679 

31 26 25,705 

32 13 25,718 

a

 Note that the tails generation provided by AES is conservative 

in that it provides a maximum number of tails cylinders that 

could be produced over the lifetime of the proposed EREF. It is 

based on a 30-year production life with appropriate rampup/ramp-down in capacity rather than an actual 30-year license 

period which includes the time necessary to first construct the 

proposed facility. In reality, AES would not be producing 

additional tails cylinders beyond 30 years after a license is 

issued and may start the ramp-down sooner than 24 years after 

the license is issued. 

Source: AES, 2010b.

1 

2 
 2-20 

1 monitor to measure radioactivity level (alpha) and HF levels. The GEVS for SBM 1 would also 

2 serve the Blending, Sampling, and Preparation Building. 

3 

4 Each gaseous effluent vent system would transport potentially contaminated gases through a 

5 subatmospheric duct network to a set of redundant filters (a pre-filter, a high-efficiency 

6 particulate air [HEPA] filter, an activated carbon filter impregnated with potassium carbonate, 

7 and another HEPA filter) and fans. The cleaned gases would be discharged to the atmosphere 

8 via rooftop stacks. The fan would maintain an almost constant subatmospheric pressure in front 

9 of the filter section by means of a differential pressure controller. 

10 

11 Liquid Effluent Systems

12 

13 The Liquid Effluent Collection and Treatment System would collect potentially contaminated 

14 liquid effluents generated in a variety of plant operations and processes. These liquid effluents 

15 would be collected and stored in tanks prior to processing. The effluent input streams would 

16 include hydrolyzed UF6, degreaser water, citric acid, floor wash water, and miscellaneous 

17 effluent. The contaminated liquids would be processed for uranium removal through several 

18 precipitation units, filtration units, microfiltration units, and evaporation units. The final step 

19 would use an evaporation process that discharges clean steam to the atmosphere. Any 

20 resulting solid waste would be shipped offsite for disposal at an approved facility. 

21 

22 Centrifuge Test and Postmortem Facilities Exhaust Filtration System

23 

24 The Centrifuge Test and Postmortem Facilities Exhaust Filtration System would exhaust 

25 potentially hazardous contaminants from the Centrifuge Test and Postmortem Facilities. The 

26 system would also ensure the Centrifuge Postmortem Facility is maintained at a negative 

27 pressure with respect to adjacent areas. 

28 

29 The ductwork would be connected to a one-filter station and would exhaust through a fan. The 

30 filter station and fan would be able to handle 100 percent of the effluent exhaust. Activities that 

31 require the Centrifuge Test and Postmortem Facilities Exhaust Filtration System to be 

32 operational would be manually stopped if the system fails or shuts down. After filtration, the 

33 clean gases would be discharged through the monitored exhaust stack on the Centrifuge 

34 Assembly Building. The Centrifuge Assembly Building exhaust stack would be monitored for 

35 hydrogen fluoride and alpha radiation. 

36 

37 Solid Waste Collection System

38 

39 In addition to the depleted UF6, operation of the proposed EREF would generate other 

40 radioactive and nonradioactive solid wastes. Solid waste would be segregated and processed 

41 based on its classification as wet-solid or dry-solid wastes and segregated into radioactive, 

42 hazardous, or mixed-waste categories. Wet solid waste would include wet trash (waste paper, 

43 packing material, rags, wipes, etc.), oil-recovery sludge, oil filters, miscellaneous oils (such as 

44 cutting machine oils), solvent recovery sludge, and uranic waste precipitate. Dry solid waste 

45 would include trash (combustible and nonmetallic items), activated carbon, activated alumina, 

46 activated sodium fluoride, HEPA filters, scrap metal, laboratory waste, and dryer concentrate. 

47 
 2-21 

1 Radioactive solid waste would be sent to a licensed low-level radioactive waste disposal facility. 

2 AES is considering options that include shipping its low-level radioactive waste to a treatment 

3 facility in Oak Ridge, Tennessee, and disposal sites near Richland, Washington, and Clive, 

4 Utah. Material that would be classified as mixed waste may also be handled at the Oak Ridge, 

5 Tennessee, and Clive, Utah, facilities. Nonradioactive and nonhazardous wastes – including 

6 office and warehouse trash such as wood, paper, and packing materials; scrap metal and 

7 cutting oil containers; and building ventilation filters – would be sent to a commercial landfill for 

8 disposal. Hazardous wastes would be sent to an appropriately licensed facility for treatment 

9 and disposal. 

10 

11 Decontamination System

12 

13 The Decontamination System would be designed to remove radioactive contamination from 

14 centrifuges, pipes, instruments, and other potentially contaminated equipment. The system 

15 would contain equipment and processes to disassemble, clean and degrease, decontaminate, 

16 and inspect plant equipment. Scrap and waste material from the decontamination process 

17 would be sent to the Solid Waste Collection System or the Liquid Effluent Collection and 

18 Treatment System for segregation and treatment prior to offsite disposal at a licensed facility. 

19 Exhaust air from the decontamination system area would pass through the gaseous effluent 

20 ventilation systems before discharge to the atmosphere. 

21 

22 2.1.4.3 Decontamination and Decommissioning 

23 

24 The proposed EREF would be licensed to operate for 30 years. At the end of this period, unless 

25 AES files a timely application for license renewal, the proposed EREF would be decontaminated 

26 and decommissioned in accordance with applicable NRC license termination requirements. The 

27 intent of decommissioning is to return the entire proposed EREF site to levels suitable for 

28 unrestricted use in accordance with 10 CFR 20.1402 requirements (AES, 2010a). 

29 Decontamination and decommissioning is projected to take 9 years, beginning in 2032 with 

30 completion expected in 2041. The SBMs would be decommissioned in the first 8 years, and 

31 there would be one additional year for final site surveys and activities (AES, 2010b). SBM 1 is 

32 scheduled to be the first to operate and would be the first to undergo decontamination and 

33 decommissioning. Decontamination and decommissioning of the other SBMs would follow in 

34 turn. SBM 4 would be the last module to operate and to be decommissioned. The remaining 

35 plant systems and buildings would be decommissioned after final shutdown of SBM 4 

36 (AES, 2010b). All proprietary equipment and radiologically contaminated components would be 

37 removed, decontaminated, and shipped to a licensed disposal facility. The buildings, structures, 

38 and selected support systems would be cleaned and released for unrestricted use. 

39 

40 Decontamination and decommissioning of the proposed EREF would be funded in accordance 

41 with the Decommissioning Funding Plan (DFP) for the proposed EREF (AES, 2010b). The 

42 DFP, prepared by AES in accordance with 10 CFR 70.25(a) and the guidance in NUREG-1757 

43 (NRC, 2006), would provide information required by 10 CFR 70.25(e) regarding AES’s plans for 

44 funding the decommissioning of the proposed EREF and the disposal of depleted uranium tails 

45 generated as a result of plant operations. Funding would be provided by AES by means of a 

46 Letter of Credit in accordance with NRC regulations in 10 CFR Part 70 and guidance in 

47 NUREG-1757 (NRC, 2006). 

48 
 2-22 

1 Decontamination and decommissioning activities for the proposed EREF are anticipated to 

2 occur more than 20 years in the future, and therefore only a general description of the activities 

3 that would be conducted can be developed at this time for the EIS. The proposed facility would 

4 follow NRC decommissioning requirements in 10 CFR 70.38. 

5 

6 Decommissioning of a facility such as the proposed EREF would generally include the following 

7 activities: 

8 

9 • installation of decontamination facilities 

10 

11 • purging of process systems and equipment 

12 

13 • dismantling and removal of facilities and equipment 

14 

15 • decontamination and destruction of confidential materials 

16 

17 • decontamination of equipment, facilities, and structures 

18 

19 • survey and spot decontamination of outdoor areas 

20 

21 • removal and sale of any salvaged materials 

22 

23 • removal and disposal of wastes 

24 

25 • management and disposal of depleted uranium 

26 

27 • final radiation survey to confirm that the release criteria have been met 

28 

29 At the end of the useful life of each SBM, the enrichment process equipment would be shut 

30 down and UF6 removed to the fullest extent possible by normal process operation. This would 

31 be followed by evacuation and purging with nitrogen. The shutdown and purging portion of the 

32 decommissioning process would take approximately 3 months for each cascade. 

33 

34 Decontamination Facilities

35 

36 New decontamination facilities would be constructed in existing site buildings such as the 

37 Centrifuge Assembly Building prior to shutdown of SBM 1. The decontamination facilities would 

38 provide specialized handling of the thousands of centrifuges along with the UF6 vacuum pumps 

39 and valves. 

40 

41 Contaminated plant components would be cut up or dismantled and then processed through the 

42 decontamination facilities. Contamination of site structures would be limited to areas in the 

43 Separations Building Modules and Technical Services Building, and would be maintained at low 

44 levels throughout plant operation by regular surveys and cleaning. The use of special sealing 

45 and protective coatings on porous and other surfaces that might become radioactively 

46 contaminated during operation would simplify the decontamination process, and the use of 

47 standard good-housekeeping practices during operation of the proposed facility would ensure 
 2-23 

1 that final decontamination of these areas would require minimal removal of surface concrete or 

2 other structural material. 

3 

4 Dismantling the Facility

5 

6 Dismantling would require cutting and disconnecting all components requiring removal. The 

7 activities would be simple but very labor-intensive and would generally require the use of 

8 protective clothing. The work process would be optimized through consideration of the following 

9 measures: 

10 

11 • minimizing the spread of contamination and the need for protective clothing 

12 

13 • balancing the number of cutting and removal operations with the resultant decontamination 

14 and disposal requirements 

15 

16 • optimizing the rate of dismantling with the rate of decontamination facility throughput 

17 

18 • providing storage and laydown space as required for effective workflow, criticality, safety, 

19 security, etc. 

20 

21 • balancing the cost of decontamination and salvage with the cost of disposal 

22 

23 To avoid laydown space and contamination problems, dismantling would proceed generally no 

24 faster than the downstream decontamination process. 

25 

26 Items to be removed from the facilities would be categorized as potentially reusable equipment, 

27 recoverable scrap, and wastes. However, operating equipment would not be assumed to have 

28 reuse value after 30 years of operation. Wastes would also have no salvage value. 

29 

30 A significant amount of scrap aluminum, steel, copper, and other metals would be recovered 

31 during the disassembly of the enrichment equipment. For security and convenience, the 

32 uncontaminated materials would likely be shredded or smelted to standard ingots and, if 

33 possible, sold at market price. The contaminated materials would be disposed of as low-level 

34 radioactive waste. 

35 

36 Prompt decontamination or removal of all materials from the proposed site that would prevent 

37 release of the facility for unrestricted use would be performed. This approach would avoid long38 term storage and monitoring of radiological and hazardous wastes onsite. All of the enrichment 

39 equipment would be removed, and only the building shells and site infrastructure would remain. 

40 All remaining facilities would be decontaminated to levels that would allow for unrestricted use. 

41 

42 Disposal

43 

44 All wastes produced during decontamination and decommissioning would be collected, handled, 

45 and disposed of in a manner similar to that described for those wastes produced during normal 

46 operation. Wastes would consist of normal industrial trash, nonhazardous chemicals and fluids, 

47 small amounts of hazardous materials, and radioactive wastes. Radioactive wastes would 
 2-24 

Waste Classification of Depleted 

Uranium 

Depleted uranium is different from most lowlevel radioactive waste in that it consists mostly 

of long-lived isotopes of uranium, with small 

quantities of thorium-234 and protactinium-234. 

Depleted uranium is source material as defined 

in 10 CFR Part 40, and, if treated as a waste, it 

falls under the definition of low-level radioactive 

waste per 10 CFR 61.2. The Commission 

affirmed that depleted uranium is properly 

considered a form of low-level radioactive waste 

in Louisiana Energy Services, L.P. (National 

Enrichment Facility), CLI-05-5, 61 NRC 22 

(January 18, 2005). This means that depleted 

uranium could be disposed of in a licensed lowlevel radioactive waste facility if the licensing 

requirements for land disposal of radioactive 

waste as indicated in 10 CFR Part 61 are met. 

Sources: NRC, 1991, 2005b. 

1 consist primarily of crushed centrifuge rotors, trash, and citric cake. Citric cake consists of 

2 uranium and metallic compounds precipitated from citric acid decontamination solutions. 

3 

4 Radioactive wastes would ultimately be disposed of in licensed low-level radioactive waste 

5 disposal facilities. Hazardous wastes would be disposed of in licensed hazardous waste 

6 disposal facilities. Nonhazardous and nonradioactive wastes would be disposed of in a manner 

7 consistent with good industrial practice and in accordance with applicable regulations. A 

8 complete estimate of the wastes and effluent to be produced during decommissioning would be 

9 provided in the Decommissioning Plan that AES would submit prior to the start of the 

10 decommissioning. 

11 

12 Final Radiation Survey

13 

14 A final radiation survey would verify complete decontamination of the proposed EREF prior to 

15 allowing the proposed site to be released for unrestricted use. The evaluation of the final 

16 radiation survey would be based in part on an initial radiation survey performed prior to initial 

17 operation. The initial site radiation survey would determine the natural background radiation 

18 levels in the area of the proposed EREF, thereby providing a benchmark for identifying any 

19 increase in radioactivity levels in the area. The final survey would measure radioactivity over 

20 the entire site and compare it to the original benchmark survey. The intensity of the survey 

21 would vary depending on the location (i.e., the buildings, the immediate area around the 

22 buildings, and the remainder of the site). A final radiation survey report would document the 

23 survey procedures and results, and would include, among other things, a map of the survey of 

24 the proposed site, measurement results, and a comparison of the proposed EREF site’s 

25 radiation levels to the surrounding area. The 

26 results would be analyzed to show that they 

27 were below allowable residual radioactivity 

28 limits; otherwise, further decontamination 

29 would be performed. 

30 

31 2.1.5 Depleted Uranium Management 

32 

33 The term “depleted uranium” refers to any 

34 chemical form of uranium (e.g., UF6 and 

35 U3O8) that contains uranium-235 in 

36 concentrations less than the 0.7 percent 

37 found in natural uranium. As discussed in 

38 Section 2.1.4.2, the uranium enrichment 

39 process would generate a depleted UF6

40 stream (also called tails). In contrast to the 

41 uranium in the enriched UF6 produced by the 

42 enrichment facility, the uranium in the 

43 depleted UF6 stream would be depleted in 

44 the uranium-235 isotope of uranium. At full 

45 production, the proposed EREF would 

46 generate 15,270 metric tons per year 

47 (16,800 tons per year) of depleted UF6. 

48 Initially, the depleted UF6 would be stored in 
 2-25 

1 Type 48Y cylinders on the Full Tails Cylinder Storage Pads (AES, 2010a). Each Type 48Y 

2 cylinder would hold approximately 12.5 metric tons (13.8 tons), which means that at full 

3 production the proposed site would generate approximately 1222 cylinders of depleted UF6

4 every year. During the operation of the proposed facility, the plant could generate and store up 

5 to 25,718 cylinders of depleted UF6 (AES, 2010a). AES would own the depleted UF6 and 

6 maintain the cylinders while they are in storage. Maintenance activities would include periodic 

7 inspections for corrosion, valve leakage, and distortion of the cylinder shape, and touch-up 

8 painting as required. Problem cylinders would be removed from storage and the material 

9 transferred to another storage cylinder. The proposed storage area would be kept neat and free 

10 of debris, and all stormwater or other runoff would be routed to the Cylinder Storage Pad 

11 Stormwater Retention Basins for monitoring and evaporation. 

12 

13 The Defense Nuclear Facilities Safety Board (DNFSB) has reported that long-term storage of 

14 depleted UF6 in the UF6 form represents a potential chemical hazard if not properly managed 

15 (DNFSB, 1995). For this reason, the strategic management of depleted uranium includes the 

16 conversion of depleted UF6 stock to a more stable uranium oxide (e.g., triuranium octaoxide 

17 [U3O8]) form for long-term management (OECD, 2001). Also, the DOE evaluated multiple 

18 disposition options for depleted UF6 and agreed that conversion to U3O8 was preferable for long19 term storage and disposal of the depleted uranium in its oxide form, due to the chemical stability 

20 of U3O8 (DOE, 2000). Therefore, the disposal option considered in the EIS is the conversion of 

21 the depleted UF6 to U3O8 at either a DOE-owned or commercial conversion facility followed by 

22 disposal as U3O8. Direct disposal of depleted UF6 was ruled out because of its chemical 

23 reactivity (DOE, 1999b). 

24 

25 2.1.5.1 Conversion of Depleted UF6

26 

27 AES has requested the DOE to accept all depleted UF6 generated at the proposed EREF for 

28 conversion to the oxide form for disposal (AES, 2010a). This plan is based on Section 3113 of 

29 the 1996 USEC Privatization Act, 42 U.S.C. 2297h-11, which states the DOE “shall accept 

30 for disposal low-level radioactive waste, including depleted uranium if it were ultimately 

31 determined to be low-level radioactive waste, generated by ... any person licensed by the 

32 Nuclear Regulatory Commission to operate a uranium enrichment facility under section 53, 63, 

33 and 193 of the Atomic Energy Act of 1954 (42 U.S.C. 2073, 2093, and 2243).” On January 18, 

34 2005, the Commission issued its ruling that depleted uranium is considered a form of low-level 

35 radioactive waste (NRC, 2005a). The Commission also stated that, pursuant to Section 3113 of 

36 the USEC Privatization Act, disposal at a DOE facility represents a “plausible strategy” for the 

37 disposition of depleted uranium tails (NRC, 2005a). 

38 

39 DOE has constructed two conversion plants to convert the depleted UF6 now in storage at 

40 Portsmouth, Ohio, and Paducah, Kentucky, to U3O8 and hydrofluoric acid. Both plants are 

41 currently undergoing operational tests. The Portsmouth plant is expected to go into full 

42 operation in summer 2011, and the Paducah plant by early fall of 2011 (Sparks, 2011). AES 

43 would transport the depleted UF6 generated by the proposed EREF to either of these new 

44 facilities and pay DOE to convert and dispose of the material. The proposed EREF would 

45 generate approximately 321,235 metric tons (354,101 tons) in total over its operating lifetime 

46 (AES, 2010a). The depleted UF6 would be processed in a DOE-operated conversion facility and 

47 then shipped offsite for disposal. 

48 
 2-26 

1 

2 

3 In addition to the DOE disposition option for depleted UF6, one or more NRC-licensed 

4 commercial depleted UF6 conversion facilities may become available during the proposed 

5 EREF’s operational lifetime. One commercial entity (International Isotopes, Inc.) submitted a 

6 license application (International Isotopes, 2009) on December 31, 2009, to construct and 

7 operate a new depleted UF6 “de-conversion” facility in Hobbs, New Mexico. 

8 

9 The NRC staff is currently reviewing this application (NRC, 2010b). Although International 

10 Isotopes calls its process “de-conversion,” it is similar to DOE’s conversion process. If a 

11 commercial facility performs the conversion to U3O8, DOE is still obligated to accept the U3O8

12 for disposal if requested by AES, per Section 3113 of the USEC Privatization Act. 

13 

14 2.1.5.2 Disposal of Depleted Uranium 

15 

16 The Commission has stated that depleted uranium in any form (e.g., UF6, U3O8) is considered a 

17 form of low-level radioactive waste (NRC, 2005a). However, the chemical reactivity of depleted 

18 UF6 precludes it from being a stable waste form, and thus makes it unsuitable for direct disposal 

19 without conversion (DOE, 1999b). As discussed in Section 2.1.5.1, AES has requested the 

20 DOE to accept all depleted UF6 generated at the proposed EREF for conversion to the oxide 

21 form for disposal (AES, 2010a). After conversion of depleted uranium tails (depleted UF6) to 

22 U3O8, disposal of this U3O8 at a commercial low-level waste disposal facility would be a viable 

23 option if the disposal facility meets the requirements of 10 CFR Part 61. 

24 

25 2.2 No-Action Alternative 

26 

27 Under this alternative, AES would not construct, operate, and decommission the proposed 

28 EREF in Bonneville County, Idaho. Under the no-action alternative, the NRC assumes that the 

29 preconstruction activities that have been approved by exemption and are described in 

30 Section 2.1.4.1 will take place. 

31 

Depleted UF6 Conversion Process 

Depleted UF6 conversion is a continuous process in which depleted UF6 is vaporized and 

converted to U3O8 by reaction with steam and hydrogen in a fluidized-bed conversion unit. 

The hydrogen is generated using anhydrous ammonia, although an option of using natural 

gas is being investigated. Nitrogen is also used as an inert purging gas and is released to the 

atmosphere through the building stack as part of the clean off-gas stream. The depleted 

U3O8 powder is collected and packaged for disposition. The process equipment would be 

arranged in parallel lines. Each line would consist of two autoclaves, two conversion units, a 

hydrofluoric acid recovery system, and process off-gas scrubbers. The Paducah facility would 

have four parallel conversion lines. Equipment would also be installed to collect the 

hydrofluoric acid co-product and process it into any combination of several marketable 

products. A backup hydrofluoric acid neutralization system would be provided to convert up to 

100 percent of the hydrofluoric acid to calcium fluoride for storage and/or sale in the future, if 

necessary. 

Source: DOE, 2004a,b. 
 2-27 

1 Under the no-action alternative, the uranium fuel fabrication facilities in the United States would 

2 continue to obtain low-enriched uranium from the currently available sources or potential new 

3 sources. As described in Section 1.3.1, the two currently available domestic sources of low4 enriched uranium available to fuel fabricators are the Paducah Gaseous Diffusion Plant (PGDP) 

5 and the URENCO USA facility. Foreign enrichment sources are currently supplying as much as 

6 85 percent of U.S. nuclear power plants’ demand. 

7 

8 The Megatons to Megawatts Program will expire by 2013, potentially eliminating downblending 

9 as a source of low-enriched uranium (LEU) (DOE, 2010). The PGDP, which opened in 1952, 

10 uses gaseous diffusion technology, a process that is more energy intensive than newer 

11 technologies such as gas centrifuge. The NRC has already granted licenses to two commercial 

12 entities to construct and operate gas centrifuge enrichment facilities: the Louisiana Energy 

13 Services (LES) URENCO USA facility in New Mexico and the USEC American Centrifuge Plant 

14 (ACP) in Ohio. These two facilities are currently under construction and are designed to 

15 produce 3 million and 3.5 million SWUs per year, respectively, when complete and generating at 

16 full licensed capacity. However, the URENCO USA facility, while currently operating, is still 

17 under construction and is not expected to reach half of its currently licensed annual capacity of 

18 3 million SWUs until August 2011, and LES has yet to submit an application to the NRC for a 

19 potential expansion from 3 million to 5.9 million SWUs per year. In addition, the NRC is 

20 currently reviewing an application from GE-Hitachi Global Laser Enrichment, LLC to construct 

21 and operate the Global Laser Enrichment (GLE) Facility, a proposed laser-based enrichment 

22 facility that would be located in North Carolina. If the GLE Facility is licensed and constructed, it 

23 would produce enriched uranium with annual production levels of up to 6 million SWU annually. 

24 If the three facilities begin operations, this would represent a more efficient and less costly 

25 means of producing low-enriched uranium than the current gaseous diffusion technology at the 

26 PGDP. 

27 

28 2.3 Alternatives Considered but Eliminated 

29 

30 As required by NEPA and NRC regulations, the NRC staff has considered alternatives to the 

31 proposed action of construction, operation, and decommissioning of the proposed EREF. The 

32 range of alternatives to the proposed action was determined by considering the underlying 

33 purpose and need for the proposed action. Specifically, the range of alternatives was 

34 determined by considering other ways to provide enriched uranium to fulfill electricity generation 

35 requirements and provide reliable and economic domestic supplies of enriched uranium for 

36 national energy security. This analysis led to the following set of alternatives: 

37 

38 • alternative sites other than the proposed Bonneville County site 

39 

40 • alternative sources of LEU 

41 

42 • alternative technologies available for uranium enrichment 

43 

44 These alternatives were considered but eliminated from further analysis based on economic, 

45 environmental, national security, or technological maturity factors. The following sections 

46 discuss these alternatives and the reasons NRC staff eliminated them from further 

47 consideration. 

48 
 2-28 

1 2.3.1 Alternative Sites 

2 

3 This section discusses AES’s site-selection process and site selection criteria, and identifies the 

4 alternative sites for the proposed AES uranium enrichment facility (including the proposed 

5 EREF site in Bonneville County, Idaho). AES used a structured four-step approach to select a 

6 preferred site within the United States that met technical, environmental, safety, and business 

7 requirements (AES, 2010a): 

8 

9 1. Identify potential regions and sites, 

10 2. Screen candidate sites (Phase I), 

11 3. Evaluate sites passing Phase I criteria (Phase II), and 

12 4. Identify a preferred site. 

13 

14 The primary objectives of environmental acceptability, meeting technical requirements, and 

15 providing operational efficiencies were adhered to by AES throughout the screening process. 

16 Many environmental impacts can be avoided or significantly reduced through proper site 

17 selection. 

18 

19 The NRC staff reviewed the AES site-selection process to determine if a site considered by AES 

20 was obviously superior to the proposed EREF site in Bonneville County, Idaho (NRC, 2002). 

21 The NRC staff determined that the process used by AES was rational and objective, and that 

22 the results were reasonable. None of the candidate sites was obviously superior to the AES 

23 preferred site in Bonneville County, Idaho. 

24 

25 2.3.1.1 Identification of Regions and Sites 

26 

27 Four criteria were used for the identification of suitable regions in which to site a proposed 

28 uranium enrichment facility: 

29 

30 1. Peak ground acceleration (PGA). Consideration of PGA is necessary due to centrifuge 

31 sensitivity to vibration; U.S. Geological Survey (USGS) general seismic hazard maps were 

32 reviewed to identify areas with a PGA less than 0.09g. 

33 

34 2. Tornado frequency. Construction of facilities designed to withstand tornado wind speeds 

greater than 257 kilometers per hour (160 miles per hour; probability of 10-5 35 per year) was 

36 considered to be cost-prohibitive to meeting design standards and safety and operational 

37 requirements. 

38 

39 3. Hurricane frequency. Areas were identified where hurricanes with wind speeds no greater 

40 than 154 kilometers per hour (96 miles per hour) were likely to occur in order to meet design 

41 standards and safety and operational requirements. 

42 

43 4. Severe winter weather. Evaluated because of their potential impact on maintaining 

44 operations, weather and road closure data were reviewed in order to avoid areas with a high 

45 potential for road closures caused by severe winter weather. 

46 

47 Areas of the United States that were clearly to be avoided because of seismic or weather 

48 concerns were excluded from further consideration. Those regions that were marginal were 
 2-29 

1 retained. Figure 2-8 shows the regions of the United States that were found to meet the initial 

2 four criteria. Suitable sites were identified within the retained areas with assistance from local 

3 elected officials and economic development organizations. 

4 

5 2.3.1.2 Screen Candidate Sites (Phase I) 

6 

7 Following application of the initial criteria, the 44 sites as identified in Table 2-3 were considered 

8 in the next site selection step. Phase I screening consisted of evaluation of the candidate sites 

9 against 11 criteria. Professional judgment was used by AES staff to assign a passing or failing 

10 grade to each criterion. Sites were not considered further if they failed any one criterion. The 

11 criteria used were: (1) Seismic History, (2) Geology, (3) Facility/Site (site size relative to facility 

12 footprint), (4) Redundant Electrical Power Supply, (5) Flooding Potential, (6) Prior Land 

13 Contamination, (7) Availability of Existing Site Data, (8) Threatened and Endangered Species 

14 near or on site, (9) Sensitive Properties (e.g., national parks), (10) Climate and Meteorology, 

15 and (11) Wetlands within the Facility Footprint on the site. Table 2-3 summarizes the results of 

16 the Phase I screening. Based on this screening, 10 of the 44 sites were recommended for 

17 further evaluation. Figure 2-9 shows the locations of these 10 sites. 

18 

19 2.3.1.3 Site Evaluation (Phase II) 

20 

21 A decision analysis approach known as multi-attribute analysis was used to produce a 

22 consistent, repeatable, and documented evaluation of the 10 candidate sites identified by 

23 Phase I screening. Site rankings were assigned based on 38 criteria spanning the 

24 12 categories and the 3 site selection objectives shown in Figure 2-10. The weighting system 

25 used by AES, as shown in Table 2-4, was assigned to each objective, category, and criterion 

26 and was applied to a score of 1 to 10, which was given to each criterion for a particular site. 

27 Table 2-5 summarizes the features and drawbacks of each site. Figure 2-11 summarizes the 

28 total weighted scores for the candidate sites, with the Bonneville site having the highest score 

29 by a slim margin over the McNeil site. 

30 

31 2.3.1.4 Preferred Site Identification 

32 

33 Forty-four sites in 7 States of 54 potential sites in 9 States were passed on from Step 1 to 

34 Step 2 (Phase I) of the selection process. The Phase I selection process identified 10 candidate 

35 sites (see Figure 2-9) for detailed evaluation in Phase II. The Phase II evaluation demonstrated 

36 that all 10 sites would be technically and environmentally suitable locations for AES’s proposed 

37 uranium enrichment facility, with none obviously superior to the others. AES selected the 

38 Bonneville County, Idaho, site as the proposed site for an enrichment plant because this site 

39 has the greatest amount of acreage; readily available water supply; some of the lowest 

40 estimated costs for electric power, labor, and materials; and Bonneville County and the State of 

41 Idaho have shown strong support for the proposed enrichment plant. The second highest rated 

42 site, the McNeil, Idaho, site, has a size that is only one-quarter that of the Bonneville County site 

43 and has a much closer nearest resident that is about 2.0 kilometers (1.25 miles) away vs. 

44 7.6 kilometers (4.75 miles) for the Bonneville County site. With the larger size (which provides a 

45 greater distance to the site boundary from the proposed facility) and greater distance to the 

46 nearest resident, selection of the Bonneville County site would be expected to result in reduced 

47 air, visual, noise, human health, transportation, and potential accident impacts as compared to 

48 those at the McNeil, Idaho, site. 
 2-30 

1 

Figure 2-8 United States Regions Meeting the Original Site Selection Criteria (modified from AES, 2010a) 2 
 2-31 

Table 2-3 Candidate Sites for Phase I Screening 

No. County, State Site Result: Basis for Exclusion 

1 Bonneville, ID Bonneville Passed: Evaluated in Phase II 

2 Bonneville, ID McNeil Passed: Evaluated in Phase II 

3 Power, ID Power County-1 Failed: Sensitive properties 

4 Power, ID Power County-2 Failed: Contamination 

5 Bingham, ID Blackfoot Failed: Sensitive properties 

6 Butte, ID Atomic City Failed: Ownership/transfer 

7 Lea, NM ELEA Passed: Evaluated in Phase II 

8 Lea, NM Lea County-1 Failed: Data availability 

9 Lea, NM Lea County-2 Failed: Wetlands 

10 Lea, NM Lea County-3 Failed: Karst 

11 Eddy, NM Seven Rivers Failed: Size, bisected by a public road 

12 Eddy, NM Berry Parcel Failed: Liquefaction 

13 Eddy, NM Harroun Failed: Liquefaction, karst, electric power, 

sensitive properties 

14 Eddy, NM Becker Failed: Liquefaction, karst, contamination 

15 Eddy, NM WIPP-1 Failed: Ownership/transfer 

16 Eddy, NM WIPP-2 Passed: Evaluated in Phase II 

17 Pike, OH Portsmouth Passed: Evaluated in Phase II 

18 Pike, OH Zahn’s Corner-1 Failed: Size, contamination, wetlands 

19 Pike, OH Zahn’s Corner-2 Failed: Wetlands, contamination 

20 Aiken, SC Savannah River Site 

(DOE) 

Failed: Ownership/transfer, endangered species, 

wetlands 

21 Cherokee, SC Jobe Sand Failed: Size 

22 Laurens, SC Copeland Stone Failed: Sensitive properties, wetlands 

23 Laurens, SC Fleming Smith Passed: Evaluated in Phase II 

25 Greenwood, SC Solutia Failed: Size 

26 Chester, SC L&C Mega Site Failed: Data availability, wetlands 

27 Edgefield, SC Gracewood Failed: Wetlands 

28 Andrews, TX Grist Passed: Evaluated in Phase II 

29 Andrews, TX Tom Failed: Site characterization data 

30 Andrews, TX Parker Failed: Site characterization data 
 2-32 

Table 2-3 Candidate Sites for Phase I Screening (Cont.) 

No. County, State Site Result: Basis for Exclusion 

31 Andrews, TX Fisher Failed: Site characterization data 

32 Andrews, TX WCS-1 Modified: To become part of WCS-2 

33 Andrews, TX WCS-2 Passed: Evaluated in Phase II 

34 Martin, TX Midland North Failed: Site characterization data 

35 Midland, TX Midland South Failed: Data availability 

36 Amherst, VA Amherst County-1 Failed: Floodplains, wetlands 

37 Amherst, VA Amherst County-2 Failed: Endangered species, sensitive properties 

38 Appomattox, VA Concord Failed: Floodplains, wetlands 

39 Carroll, VA Wildwood Passed: Evaluated in Phase II 

40 Benton, WA West Richland Failed: Seismic, faults 

41 Benton, WA Horn Rapids (DOE) Passed: Evaluated in Phase II 

42 Benton, WA Energy NW-1 (DOE) Failed: Faults, contamination, ownership/transfer 

43 Benton, WA Energy NW-2 (DOE) Failed: Contamination, ownership/transfer 

44 Benton, WA Highway 240 (DOE) Failed: Seismic, ownership/transfer, sensitive 

properties 

1 

2 2.3.2 Alternative Sources of Low-Enriched Uranium 

3 

4 The NRC staff examined three alternatives to fulfill U.S. domestic enrichment needs. These 

5 alternatives were eliminated from further consideration for reasons summarized below. 

6 

7 2.3.2.1 Re-Activate the Portsmouth Gaseous Diffusion Facility at Piketon 

8 

9 In 2001, USEC closed the Portsmouth Gaseous Diffusion Plant (GDP) (in Piketon, Ohio) to 

10 reduce operating costs (DOE, 2003). USEC cited long-term financial benefits, more attractive 

11 power price arrangements, operational flexibility for power adjustments, and a history of reliable 

12 operations as reasons for choosing to continue operations at the Paducah GDP. In a 

13 June 2000 press release, USEC explained that it “clearly could not continue to operate two 

14 production facilities.” (USEC, 2000). Key business factors in USEC’s decision to reduce 

15 operations to a single production plant included long-term and short-term power costs, 

16 operational performance and reliability, design and material condition of the plants, risks 

17 associated with meeting customer orders on time, and other factors relating to assay levels, 

18 financial results, and new technology issues (USEC, 2000). 

19 

20 The NRC staff does not believe that there has been any significant change in the factors that 

21 were considered by USEC in its decision to cease uranium enrichment at the Portsmouth GDP. 

22 In addition, the gaseous diffusion technology is substantially more energy intensive than other 

23 enrichment technologies. The higher energy consumption results in larger indirect impacts, 

24 especially those impacts that are attributable to significantly higher electricity usage (e.g., air 
 2-33 

1 

2 Figure 2-9 Final 10 Candidate Gas Centrifuge Uranium Enrichment 

3 Facility Site Locations (AES, 2010a) 

4 

5 emissions from coal-fired electricity generation plants) (DOE, 1995). The age of the existing 

6 plant also calls into question its overall reliability. Furthermore, a contract has been awarded to 

7 decommission the plant (DOE, 2010b). Therefore, this proposed alternative was eliminated 

8 from further consideration. 

9 

10 2.3.2.2 Downblending Highly Enriched Uranium 

11 

12 Under this alternative, a domestic uranium enrichment plant would not be constructed to replace 

13 existing production. Instead, an equivalent amount of SWU would be obtained from 

14 downblending highly enriched uranium from either United States or Russian nuclear warheads. 

15 This alternative was eliminated because U.S. reliance on foreign sources of enrichment 

16 services, as an alternative to the proposed action, would not meet the national energy policy 

17 objective of a “viable, competitive, domestic uranium enrichment industry for the foreseeable 

18 future” (DOE, 2000). Also, it does not meet the need for a reliable source of enriched uranium, 

19 as discussed in Section 1.3. Furthermore, as discussed in Section 1.3.1, the Megatons to 

20 Megawatts Program downblending agreement is set to expire in 2013. 

21 

22 2.3.2.3 Purchase Low-Enriched Uranium from Foreign Sources 

23 

24 There are several potential sources of enrichment services worldwide. However, U.S. reliance 

25 on foreign sources of enrichment services, as an alternative to the proposed action, would not 
 2-34 

1 

2 Figure 2-10 Organization of Gas Centrifuge Uranium Enrichment Facility Site 

3 Selection Objectives, Criteria Categories, and Criteria (AES, 2010a) 

4 

5 
 2-35 Table 2-4 Objectives, Categories, and Criteria with Weights and Contribution to Site Score OBJECTIVE CATEGORY CRITERI

A

Objective Weight Contribution Category Weight Contributiona Criteria & Contribution Weight Contribution

Technical Requirements 

100 0.49 Site 100 0.17 Topography & Geology 100 0.05

Size 70 0.04Surface & Mineral Rights 70 0.04Zoning & Ownership 70 0.04New Radiation Hazard 5 <0.01

Safety Design 70 0.12 Peak Ground Acceleration 100 0.06

Fire Hazard 15 0.01Wind Hazard 40 0.02Existing Survey Data 60 0.03

Electrical System 60 0.10 Quality 100 0.03

Rates 90 0.03Cost 75 0.02Feeders 70 0.02

Workforce 30 0.05 Construction Workforce 100 0.03

Operational Workforce 65 0.02Technical Resources 35 0.01

Water Treatment & Supply 

20 0.04 Water Treatment & Supply 100 0.04
 2-36 Table 2-4 Objectives, Categories, and Criteria with Weights and Contribution to Site Score (Cont.) OBJECTIVE CATEGORY CRITERI

A

Objective Weight Contribution Category Weight Contributiona Criteria & Contribution Weight Contribution

Environmental Acceptability 

70 0.34 Environmental 

Protection 

95 0.10 Permitting 100 0.04

Onsite Water Features 65 0.02Groundwater 100 0.04

Offsite Contamination Hazard 

40 0.04 Current Offsite Plumes 100 0.02

Future Migration 30 0.01Documented Monitoring 50 0.01

Land Use & Demography 

100 0.11 Environmental Justice 100 0.04

Hazardous Facilities 95 0.03Sensitive Areas 75 0.03Adjacent Site Plans 40 0.02

Human Services 80 0.09 Emergency Services 100 0.03

Housing & Necessities 90 0.03Schools 65 0.02Recreational & Cultural Options 50 0.01

Operational Efficiencies 

34 0.17 Lo

w-Level Waste 

(LLW) Disposal 

15 0.02 LLW Disposal 100 0.02

Transportation 35 0.04 Highway Access 100 0.02

Construction Traffic 80 0.02

Support & Business Environment 

100 0.11 Business Environment 30 0.02

Public Support 100 0.05Agencies 50 0.03Labor Support 30 0.02 a Values do not add to 1.00 in the contribution columns for category and criteria due to rounding.

1 
 2-37 Table 2-5 Candidate Sites Considered in Phase II Evaluation Site Location Selection Considerations Potential Drawbacks Bonneville Bonneville, ID Remote location; near major highway; few nearby residences/activities; bounded by BLM and private land used for grazing/farming; topology and geology are favorable; simple land transfer; no surface or mineral rights issues; close to power; water from onsite wells; good workforce availability and housing; strong local and state support. McNeil Bonneville, ID Similar attributes as the Bonneville site. Smaller than Bonneville (1000 acres [405 hectares] vs. >4000 acres [1619 hectares]); nearest resident closer than Bonneville (2.0 kilometers [1.25 miles] vs. 7.6 kilometers [4.75 miles]). ELEA Lea, NM Remote location; near major highway; few nearby residences/activities; bounded by BLM and private land; favorable seismic characteristics; strong local support; privately owned/simple land transfer; most site-specific data of all 10 sites; Lea County water 

system capable of additional load. 

Mineral leases under and adjacent to site; rights-ofway onsite (pipelines, transmission line, water line, and communication tower); workforce availability and housing not as good as other sites. 

WIPP-2 Eddy, NM Remote location; near major highway; few nearby 

residences/activities; bounded by BLM and private land; favorable seismic characteristics; strong local support; good regional data. 

Complicated land transfer – portions owned by BLM and State of New Mexico; mineral leases under and adjacent to site; may require additional cultural resources permitting; Eddy County water system would require expansion; workforce availability and housing not as good as other sites. 

Portsmouth Piketon, 

OH 

Adjacent to major interstate highway; DOE and USEC enrichment facilities adjacent to site; excellent utility infrastructure; good workforce availability; no surface or mineral rights. 

Residents within 2 kilometers (1 mile) of the site; multiple private owners of site could affect land transfer; earthmoving required because of topography; fill may adversely affect seismic characteristics; floodplain onsite near boundary; irregular shape – small effective area compared to most other sites; site divided by road and rail line; closed landfill adjacent to site with trichloroethylene contamination. 
 2-38 Table 2-5 Candidate Sites Considered in Phase II Evaluation (Cont.) Site Location Selection Considerations Potential Drawbacks Fleming Smith Laurens, SC Near major interstate highway; next to existing and proposed industrial developments; available electric supply and other utilities; large workforce; sufficient water capacity from existing system; strong local and state support. Residents within 0.4 kilometer (0.25 mile) of the site; extensive earthmoving required because of topography; extensive fill may impact seismic stability; several ROWs onsite including sewer and a pressurized pipeline; wetland permit may be required. Grist Andrews, TX Remote location; near major highway; few nearby residences; favorable seismic characteristics, topography, and geology; simple land transfer; surrounded by private landowners; strong local and state support; no special permitting issues. New water lines from Gaines County would be needed; one of smallest sites at 900 acres (364 hectares); mineral rights onsite would have to be purchased; low workforce availability and housing score. WCS-2 Andrews, TX Similar attributes as the Grist site; second largest site at 2560 acres (1036 hectares). New water lines from Gaines County would be needed; within 3 kilometers (2 miles) of the WCS low- level and hazardous waste facility; pipeline ROWs are present; mineral rights onsite would have to be purchased; low workforce availability and housing 

score. 

Wildwood Carroll, VA Adjacent to major interstate highway and a 

commercial development; privately owned – simple land transfer; no surface or mineral rights. 

Residents within 3 kilometers (2 miles) of the site; extensive earthmoving required because of topography; extensive fill may impact seismic stability; drainage that bisects site may have associated wetlands; irregular shape – smallest effective area of all sites; small regional airport less than 3 kilometers (2 miles) away with flight patterns over the site; water available but system capacity would require expansion; has least amount of sitespecific data available. 

Horn Rapids Benton, 

WA 

On south edge of the DOE Hanford Reservation; no surface or mineral rights; excellent utility 

infrastructure and workforce availability; no nearby sensitive resources or areas; AES fuel fabrication facility adjacent to the site. 

Land transfer may be complicated because of DOE requirements; small regional airport about 3 kilometers (2 miles) away with flight patterns over 

the site; lacks strong support at the State and national levels. 

Source: AES, 2010a.
 2-39 

1 

2 Figure 2-11 Candidate Sites Phase II Evaluation Results (modified from AES, 2010a) 

3 

4 meet the national energy policy objective of a “viable, competitive, domestic uranium enrichment 

5 industry for the foreseeable future” (DOE, 2000). For this reason, the NRC staff does not 

6 consider this alternative to meet the need for the proposed action, and therefore has eliminated 

7 it from further study. 

8 

9 2.3.3 Alternative Technologies for Enrichment 

10 

11 A number of different processes have been invented for enriching uranium; only three (gaseous 

12 diffusion, gas centrifuge, and laser excitation) are candidates for commercial use, and of those 

13 only the gaseous diffusion and gas centrifuge technologies have been deployed for large-scale 

14 industrial use. Other technologies – namely, electromagnetic isotope separation, liquid thermal 

15 diffusion, and early-generation laser enrichment – have proven too costly to operate or remain 

16 at the research and laboratory developmental scale, or in the case of laser-enrichment have 

17 been superseded by a more advanced technology. All of these technologies are discussed 

18 below. 

19 

20 2.3.3.1 Electromagnetic Isotope Separation Process 

21 

22 Figure 2-12 shows a sketch of the electromagnetic isotope separation process. In this process, 

23 a monoenergetic beam of ions of normal uranium travels between the poles of a magnet. The 

24 magnetic field causes the beam to split into several streams according to the mass of the 

25 isotope. Each isotope has a different radius of curvature and follows a slightly different path. 

26 Collection cups at the ends of the semicircular trajectories catch the homogenous streams. 

27 Because the energy requirements for this process proved very high – in excess of 3000 kilowatt 

28 hours per SWU – and production was very slow (Heilbron et al., 1981), electromagnetic isotope 

29 separation was not considered viable and was removed from further consideration. 

30 
 2-40 

1 2.3.3.2 Liquid Thermal Diffusion 

2 

3 Figure 2-13 is a diagram of the liquid thermal 

4 diffusion process, which was investigated in the 

5 1940s. It is based on the concept that a temperature 

6 gradient across a thin layer of liquid or gas causes 

7 thermal diffusion that separates isotopes of differing 

8 masses. When a thin, vertical column is cooled on 

9 one side and heated on the other, thermal 

10 convection currents are generated and the material 

11 flows upward along the heated side and downward 

12 along the cooled side. Under these conditions, the 

13 lighter UF6 molecules diffuse toward the warmer 

14 surface and heavier UF6 molecules concentrate near 

15 the cooler side. The combination of this thermal 

16 diffusion and the thermal convection currents causes 

17 the lighter uranium-235 molecules to concentrate on 

18 top of the thin column while the heavier uranium-235 

19 goes to the bottom. Taller columns produce better 

20 separation. Eventually, a facility using this process 

21 was designed and constructed at Oak Ridge, 

22 Tennessee, but it was closed after about a year of 

23 operation because of cost and maintenance 

24 concerns (Settle, 2004). Based on high operating 

25 costs and high maintenance requirements, the liquid 

26 thermal diffusion process has been eliminated from 

27 further consideration. 

28 

29 2.3.3.3 Gaseous Diffusion Process 

30 

31 The gaseous diffusion process is based on molecular 

32 effusion, a process that occurs whenever a gas is 

33 separated from a vacuum by a porous barrier. The 

34 gas flows from the high-pressure side to the low35 pressure side. The rate of effusion of a gas through 

36 a porous barrier is inversely proportional to the 

37 square root of its mass. Thus, lighter molecules pass 

38 through the barrier faster than heavier ones. 

39 Figure 2-14 is a diagram of a single gas diffusion 

40 stage. The gaseous diffusion process consists of thousands of individual stages connected in 

41 series to multiply the separation factor. 

42 

43 Gaseous diffusion is the only enrichment technology in commercial use in the United States, but 

44 it has relatively large resource requirements. The Paducah GDP contains 1760 enrichment 

45 stages and is designed to produce UF6 enriched up to 5.5 percent uranium-235. The design 

46 capacity of the Paducah GDP is approximately 8 million SWUs per year, but it has never 

47 operated at greater than 5.5 million SWUs. Paducah consumes approximately 2200 kilowatt 

48 hours per kilogram of SWU (DOE, 2000). DOE anticipates “the inevitable cessation of all 

49 domestic gaseous diffusion enrichment operations” due to the higher cost of aging diffusion 

Figure 2-12 Electromagnetic Isotopic 

Separation Process (Milani, 2005) 

Figure 2-13 Liquid Thermal Diffusion 

Process (NRC, 2005b) 
 2-41 

1 facilities (DOE, 2001). Therefore, the gas diffusion 

2 process has been eliminated from further 

3 consideration. 

4 

5 2.3.3.4 Atomic Vapor Laser Isotope Separation 

6 

7 The Atomic Vapor Laser Isotope Separation 

8 (AVLIS) process, shown in Figure 2-15, is based on 

9 the circumstance that different isotopes of the same 

10 element, though chemically identical, have different 

11 electronic energies and absorb different 

12 wavelengths of laser light. The isotopes of most 

13 elements can be separated by a laser-based 

14 process if they can be efficiently vaporized into 

15 individual atoms or molecules. In AVLIS, uranium 

16 metal is vaporized, and the vapor stream is illuminated 

17 with a laser light of a specific wavelength that is 

18 absorbed only by uranium-235. The laser selectively 

19 adds enough energy to ionize or remove an electron 

20 from uranium-235 atoms, while leaving the other 

21 isotopes unaffected. The ionized uranium-235 atoms 

22 are then collected on negatively charged surfaces 

23 inside the separator unit. The collected material 

24 (enriched product) is condensed as a liquid on the 

25 charged surfaces and then drains to a caster where it 

26 solidifies as metal nuggets. 

27 

28 The high separation factor in AVLIS means fewer stages to achieve a given enrichment, lower 

29 energy consumption, and smaller waste volume. However, budget constraints compelled USEC 

30 to discontinue development of the U.S. AVLIS program in 1999 (USEC, 1999). Because 

31 development of the AVLIS process was not continued, and the technology has been 

32 superseded by a more advanced laser-based technology discussed in Section 2.3.3.6, AVLIS 

33 has been eliminated from further consideration. 

34 

35 2.3.3.5 Molecular Laser Isotope Separation 

36 

37 Like AVLIS, the Molecular Laser Isotope Separation (MLIS) process uses a tuned laser to excite 

38 uranium-235 molecules in the UF6 feed gas. A second laser then dissociates excited molecules 

39 into UF5 and free fluorine atoms. The enriched UF5 then precipitates and is filtered as a powder 

40 from the feed gas. Each stage of enrichment requires conversion of enriched UF5 back to UF6. 

41 The advantages of MLIS include low power consumption and the use of UF6 as a process gas. 

42 However, it is less efficient and up to four times more energy intensive than AVLIS. Therefore, 

43 all countries except Japan have discontinued development of MLIS. Because development of 

44 the MLIS process was not continued and the technology has been superseded by the more 

45 advanced laser-based technology discussed in Section 2.3.3.6, MLIS has been eliminated from 

46 further consideration. 

47 

Figure 2-14 Gaseous Diffusion Stage 

(NRC, 2009a) 

Figure 2-15 Atomic Vapor Laser 

Isotope Separation Process 

(Hargrove, 2000) 
 2-42 

1 2.3.3.6 Separation of Isotopes by Laser Excitation 

2 

3 The separation of isotopes by laser excitation (SILEX) process is a third-generation laser-based 

4 technology for enriching natural uranium. The SILEX technology, developed by Silex Systems 

5 Ltd., in partnership with GE-Hitachi Global Laser Enrichment, LLC (GLE) (and formerly, USEC), 

6 is similar to the two earlier laser-excitation technologies, MLIS and AVLIS, discussed in above in 

7 Sections 2.3.3.4 and 2.3.3.5, respectively (USEC, 2003; GLE, 2008). All three laser-based 

8 processes isolate uranium-235 by optical rather than mechanical means. The SILEX laser9 based technology has several advantages over the conventional technologies of gas diffusion 

10 and gas centrifuge, including lower capital costs, lower operating costs, simpler and more 

11 versatile deployment, more flexibility in product enrichment, smaller facility footprint for 

12 comparable enrichment capacity, and reduced environmental impacts. 

13 

14 In laser excitation enrichment, UF6 vapor is illuminated with a tuned laser of a specific 

15 wavelength that is absorbed only by uranium-235 atoms while leaving other isotopes 

16 unaffected. The stream then passes through an electromagnetic field to separate the ionized 

17 uranium-235 atoms from other uranium isotopes. 

18 

19 The SILEX technology is the world’s only third-generation laser-based enrichment technology. 

20 (GLE, 2008). In a 2006 agreement with Silex Systems, General Electric (GE) acquired “the 

21 exclusive rights to complete the process development and commercial deployment of Silex’s 

22 enrichment technology” (GE, 2006). GLE has submitted an application to the NRC for a 

23 proposed facility in Wilmington, North Carolina, that would be the first enrichment facility to 

24 employ the SILEX technology. This application is currently under NRC review (NRC, 2009b), 

25 and a Draft EIS was published for public comment (NRC, 2010c). 

26 

27 It is possible at some point in the future that after successfully obtaining a license and 

28 designing, constructing, and deploying its first SILEX-based enrichment facility, GLE could 

29 decide to license the technology to other companies. However, such a possibility is merely 

30 speculative at this time because the first full-scale commercial facility has yet to be licensed, 

31 constructed, or operated. At present, only GLE has the rights to the SILEX technology, and 

32 thus only GLE has the ability to design and build a facility using the technology. Therefore, 

33 because this alternative is not available for use by AES for the proposed EREF, it has been 

34 eliminated from further consideration. 

35 

36 2.4 Summary and Comparison of Predicted Environmental Impacts 

37 

38 Chapter 4 of this EIS presents a detailed evaluation of the environmental impacts of the 

39 proposed action and the no-action alternative. Table 2-6 summarizes and compares these 

40 environmental impacts. A common element between the two alternatives is the occurrence of 

41 preconstruction activities. It is assumed that preconstruction activities take place under both 

42 alternatives and, therefore, the impacts associated with preconstruction activities take place 

43 regardless of which alternative is selected. As a result, the comparison of alternatives 

44 presented in Table 2-6 is intended primarily to highlight the differences between the two 

45 alternatives after preconstruction activities have occurred. 

46 
 2-43 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Land Use SMALL. The property to be purchased by AES for the proposed project is privately owned, contains mostly sagebrush rangeland and agricultural areas, and is bordered by similar land covers. The proposed property is zoned by Bonneville County G-1 Grazing, and a uranium enrichment facility is consistent with current zoning. Restrictions to land use would begin with the purchase of the property by AES. All grazing and agriculture would cease on the proposed property prior to construction. Similar land uses on surrounding properties would 

continue. Impacts on land use due to construction would be SMALL. Operation of the proposed EREF would restrict land use on the proposed property to the production of enriched uranium. The operation of the proposed EREF is not expected to alter land use on adjacent properties. Impacts on land use due to operations would be SMALL. At the end of decommissioning, the buildings and structures would be available for unrestricted use. As a result, impacts on land use due to decommissioning would be SMALL. 

SMALL. AES would purchase the proposed property and restrictions on grazing and agriculture would initially occur. However, the zoning designation for the proposed property would remain G-1 Grazing whether the proposed EREF is built or not, and the land uses of grazing and farming could potentially resume. Should another domestic enrichment facility be constructed at an alternate location, land use impacts could occur and could range from SMALL to LARGE, depending on factors such as the existing land uses at the alternate location and the nature of the facility. 

1 
 2-44 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Historic and Cultural Resources SMALL to MODERATE. Construction would take place on ground previously disturbed by preconstruction activities, and impacts on historic or archaeological resources would primarily occur prior to construction. There are 13 cultural resource sites (3 prehistoric, 6 historic, and 4 multi-component) in the surveyed areas of the proposed EREF property. One of these sites, the John Leopard Homestead (MW004), is located within the footprint of the proposed EREF and has been recommended as eligible for the National Register of 

Historic Places. The removal of site MW004, which has already occurred, resulted in a LARGE impact because the site no longer exists; however, because AES removed the site through professional excavation and data recovery and there are other homestead sites of this type found in the region, the impact has been mitigated to a MODERATE level. The Wasden Complex is an important group of archaeological sites, located approximately 1.6 kilometers (1 mile) from the proposed EREF site. Construction and operation of most of the proposed facility would not be visible from the Wasden Complex because a ridgeline would obscure views of the lower portions of the proposed facility. Other impacts during operations would be SMALL because no intact historic or cultural resources would 

SMALL to MODERATE. The proposed EREF would not be constructed. Site MW004 would not be affected by NRC’s licensing action, and Section 106 of the National Historic Preservation Act would not apply because no Federal action would be involved. However, the removal of site MW004, which has already occurred, resulted in a LARGE impact because the site no longer exists; but because AES removed this site through professional excavation and data recovery and there are other homestead sites of this type found in the region, the impact has been mitigated to a MODERATE level. No visual effects would occur to the viewshed for the Wasden Complex. Should another domestic enrichment facility be constructed at an alternate location, historical and cultural resource impacts could occur and could range from SMALL to LARGE. Consideration of historical and cultural resources at the alternate location would be reviewed in consultation with the appropriate SHPO. 
 2-45 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Historic and Cultural Resources (Cont.) remain and nearby resources would not be impacted by noise. Decommissioning would not likely affect historic and cultural resources because any areas disturbed during decommissioning would have been previously disturbed during construction. Impacts would be SMALL. Visual and Scenic Resources SMALL to MODERATE. The visual environment of the proposed EREF property and of surrounding areas is 

predominantly rangeland and cropland. Activities such as clearing and grading of the proposed site would change the visual setting, but would not drastically alter the appearance of the area. The same is true for fugitive dust generation during construction (which would be of temporary duration) and construction traffic on the proposed property. However, because of the extent of the proposed EREF project, the type and size of equipment involved in construction, and the industrial character of buildings to be used, construction of the proposed EREF would create significant contrast with the surrounding visual environment. The proposed facility would be located approximately 2.4 kilometers (1.5 miles) from areas of public view, including US 20 and the Hell’s Half Acre Wilderness Study Area (WSA). The U.S. Bureau of Land Management (BLM) gave a Visual Resource Management (VRM) Class I designation to the WSA, 

SMALL. Since the proposed EREF would not be constructed, no major visual intrusions to the existing landscape would occur. The current land cover would be altered by preconstruction activities, but no large industrial structures would be constructed. The existing natural character of the area would largely remain intact. The lack of development would be consistent with BLM’s VRM Class I designation for the Hell’s Half Acre WSA, and no intrusions to the Wasden Complex viewshed would occur. Should another domestic enrichment facility be constructed at an alternate location, visual and scenic resource impacts could occur and could range from SMALL to LARGE. These impacts would depend on factors such as the visual setting in which the facility is to be constructed and operated and the nature of the facility. 
 2-46 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Visual and Scenic Resources (Cont.) which applies to areas of high scenic quality. Construction of the proposed EREF would introduce visual intrusions that are out of character with the surrounding area. While certain construction activities would have a SMALL impact (e.g., fugitive dust generation), the significant contrast posed by the buildings under construction would have a MODERATE impact. Construction and operation of most of the proposed facilities would not be visible from the Wasden Complex 

because a ridgeline obscures views of the proposed facility. Operations would have an impact on the surrounding visual landscape. The proposed facility is visually inconsistent with the current setting, and its operation is expected to alter visual ratings on surrounding public lands, which constitutes a MODERATE visual impact. At the end of decommissioning, the buildings and structures would be available for unrestricted use. As a result, impacts on visual and scenic resources would remain MODERATE. 
 2-47 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Air Quality SMALL. Air emissions during construction would include fugitive dust from heavy equipment working on the proposed site and engine emissions from construction equipment onsite and vehicles transporting workers and materials to the proposed site. Toward the latter portion of the construction period, the auxiliary diesel electric generators would also contribute to air emissions. Air quality impacts during construction would be SMALL for all hazardous air pollutants (HAPs) and all criteria pollutants. 

During operations, the proposed EREF would not be a major source of air emissions, although there is a potential for small gaseous releases associated with operation of the process that could contain uranium isotopes, hydrogen fluoride (HF), and uranyl fluoride (UO2F2). 

Also, small amounts of nonradioactive air emissions consisting of carbon monoxide (CO), nitrogen oxides (NOx), particulate matter (PM), volatile organic 

compounds (VOCs), and sulfur dioxide (SO2) would be 

released: 

• from auxiliary diesel electric generators to supply 

electrical power when power from the utility grid is not available, 

SMALL. The air quality impacts associated with construction and operation of the proposed EREF would not occur. The proposed site could revert to agricultural activities, which would impact ambient air quality through the release of criteria pollutants from the operation of agricultural vehicles and equipment and the release of fugitive dusts from the tilling of soils. Should another domestic enrichment facility be constructed at an alternate location, air quality impacts could occur and could range from SMALL to LARGE. The nature and scale of air impacts resulting from the operation of similar enrichment technologies at alternative locations could be similar to those predicted for the proposed action, but the impacts on the local environments of such alternative facilities would be dependent on extant local conditions and cannot be predicted at this time. 
 2-48 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Air Quality (Cont.) • during building and equipment maintenance activities, and 

• from trucks, automobiles, and other vehicles in use 

onsite. 

Air emissions are not expected to impact regional visibility. Ambient air modeling predicts that impacts on ambient air quality from routine operation of the proposed EREF would be SMALL with respect to all criteria pollutants and all HAPs. During decommissioning, emissions could include fugitive dust and CO, NOx, PM, VOCs, and SO2 from 

transportation equipment, and the impacts of these emissions would be SMALL. 

Geology and Soil SMALL. Construction activities could cause short-term 

impacts such as an increase in soil erosion at the proposed site. Soil erosion could result from wind action and rain, although rainfall in the vicinity of the proposed site is low. Compaction of soils due to heavy vehicle traffic would increase the potential for soil erosion via runoff. Impacts would be SMALL. Impacts on soils during operations at the proposed facility 

would also be SMALL because activities would not increase the potential for soil erosion beyond that for the 

SMALL. No additional land disturbance from construction would occur, and the proposed site could revert to crop and grazing activities. Wind and water erosion would continue to be the most significant natural processes affecting the geology and soils at the proposed site. Should another domestic enrichment facility be constructed at an alternate location, geology and soil impacts could occur and could range from SMALL to LARGE. These impacts could be 
 2-49 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Geology and Soil (Cont.) surrounding area. The impacts to soil quality from atmospheric deposition of pollutants during operations would be SMALL. Land disturbance associated with decommissioning could temporarily increase the potential for soil erosion at the proposed EREF site, resulting in impacts similar to (but less than) those during construction. As a result, impacts to soils due to decontamination and decommissioning activities would be SMALL. similar to those of the proposed action, but would depend on factors such as the design of the facility, construction and operations methods used, and local geology and soil conditions. 

Water Resources SMALL. Annual maximum groundwater usage rates 

during construction comprise about 16 percent of the annual water right appropriation that has been transferred to the proposed property for use as industrial water. No surface water sources would be used. As a result, only SMALL impacts to water resources during construction would occur. No wastewater would be generated or discharged during the construction period. Because natural surface water bodies are absent within and near the proposed EREF site and groundwater occurs at depths of 202 meters (661 feet) to 220 meters (722 feet), water quality impacts during the construction period would be SMALL. 

SMALL. Additional water use may or may not occur, depending on future plans for the property. Water resources would be unchanged. Water usage could continue at the current rate should agricultural activities resume at the proposed site, and impacts on the ESRP aquifer and downgradient water users would be SMALL. No changes to surface water quality would be expected, and natural (intermittent) surface flow of stormwater on the proposed site would continue; therefore, the impact on surface water is expected to be SMALL. Because no additional groundwater use or adverse changes to groundwater quality 
 2-50 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Water Resources (Cont.) Water usage rates during operations are well within the water right appropriation. Both average and peak annual water use requirements would be less than 1 percent of the total groundwater usage from the Eastern Snake River Plain (ESRP) aquifer in Bonneville County. No process effluents would discharge to the retention or detention basins or into surface water. Therefore, liquid effluents would have a SMALL impact on water resources. Because all of the water discharged to the Cylinder Storage Pads Stormwater Retention Basins would 

evaporate, the basins would have a SMALL impact on the quality of water resources. The site Stormwater Detention Basin seepage would also have a SMALL impact on water resources of the area because no wastewater would be discharged to the basin. Since the usage and discharge impacts to water resources during the decommissioning phase would be similar to those during construction, the impacts to water resources would remain SMALL. 

would be expected, the impact on groundwater resources would be SMALL. Should another domestic enrichment facility be constructed at an alternate location, surface water or groundwater impacts could occur and could range from SMALL to LARGE. These impacts would depend on factors such as the water usage and discharge characteristics of the facility and the nature and extent of groundwater and surface water conditions at the alternate location. 
 2-51 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Ecological Resources SMALL. Construction activities that could impact ecological resources include constructing the proposed EREF buildings and uranium hexafluoride (UF6) cylinder storage pads. Most construction activities would occur in areas that would have already been disturbed by preconstruction activities. Impacts on vegetation would occur primarily from any additional vegetation clearing. Indirect impacts would include the generation of fugitive dust, spread of invasive species, changes in drainage patterns, soil compaction, erosion of disturbed areas, 

potential sedimentation of downgradient habitats, and accidental releases of hazardous or toxic materials (e.g., fuel spills). These activities would also result in some wildlife mortality and would cause other wildlife to relocate as a result of noise, lighting, traffic, and human presence. Collisions with construction equipment and other vehicles may cause some wildlife mortality. No rare or unique plant communities, or threatened or endangered species, have been found or are known to occur on the proposed site, although habitat on the proposed property is known to be used by greater sage-grouse (a Federal candidate species). No population-level impacts would be expected on any Federally listed or State-listed species from construction activities. Impacts of construction of the proposed facility would be SMALL. 

SMALL. Most impacts on ecological resources would occur during the preconstruction phase. 

However, such impacts would also occur under the proposed action. The potential impacts associated with the construction, operation, and decommissioning of the proposed EREF would not occur. The land on the proposed EREF site could revert to crop and grazing activities. Because denying the license would not result in additional land disturbance on the proposed EREF property, anticipated impacts on ecological resources from the no-action alternative would be SMALL. Should another domestic enrichment facility be constructed at an alternate location, ecological impacts could occur and could range from SMALL to LARGE. The nature and scale of impacts at the alternate location would depend on factors such as the ecological resources present and type of facility. 
 2-52 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Ecological Resources (Cont.) Operation of the proposed EREF could result in impacts on wildlife and plant communities as a result of noise, lighting, traffic, human presence, air emissions, and retention/detention ponds. However, these impacts would be SMALL. No impacts from operations would be expected on any Federally listed or State-listed species. Impacts on greater sage-grouse would be SMALL Vegetation and wildlife that became established near the proposed facility could be affected by decommissioning 

activities. Impacts during decommissioning would be similar to those during construction and would be SMALL. 

Noise SMALL. The nearest resident is located approximately 

7.7 kilometers (4.8 miles) east of the proposed site. No residence is expected to experience unacceptable noise levels during construction. Noise impacts from construction may exceed established standards at some offsite locations for relatively short periods of time. However, because of the distances involved, expected 

levels of attenuation, and AES’s commitment to appropriate mitigations, the impacts would be SMALL for human receptors. During the overlap period when partial operations begin while building construction continues, noise impacts from construction and operation are expected to be additive, but still substantially reduced from noise levels during initial construction. 

SMALL. None of the noise impacts associated with construction, operation, or decommissioning of the proposed EREF would occur. Land uses on the proposed EREF site could revert to previous applications, livestock grazing and/or crop production, with concomitant SMALL noise impacts. Should another domestic enrichment facility be constructed at an alternate location, noise impacts could occur and could range from SMALL to LARGE. These impacts could be similar to those of the proposed action. However, impacts would be dependent on circumstantial factors such as 
 2-53 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Noise (Cont.) Major noise sources associated with operation of the proposed facility include the six diesel-fueled emergency generators, commuter traffic, the movement of delivery vehicles, and operation of various pumps, compressors, and cooling fans. Operational noise estimates at the proposed property boundary satisfy all relevant or potentially relevant U.S. noise standards and guidance. Residents in the vicinity of US 20, who are otherwise unaffected by noise from the proposed EREF industrial footprint, would be impacted by slightly increased traffic 

noise. Noise impacts from operation of the proposed EREF would be SMALL. Noise sources and levels during decommissioning would be similar to those during construction, and peaking noise levels would be expected to occur for short durations. As a result, noise impacts from decommissioning would be SMALL. 

local meteorologic conditions, the number and location of the nearest members of the public, and the types and extent of activities necessary to prepare the site for construction at the alternate location. 

Transportation SMALL to MODERATE. The primary impact of the 

proposed action would be increased traffic on nearby roads. Impacts during construction would occur from transportation of personnel, construction materials, and nonradiological waste. All traffic to and from the proposed EREF during construction and operations would use US 20. Construction activities at the proposed EREF site could result in a 55 percent increase in traffic volume on 

SMALL. Traffic volumes and patterns would remain unchanged from existing conditions. The current volume of radioactive material and chemical shipments to/from facilities other than the proposed EREF would not increase. Should another domestic enrichment facility be constructed at an alternate location, transportation 
 2-54 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Transportation (Cont.) US 20 (including the period when construction and operations overlap). Because traffic volume is expected to remain below the design capacity of Interstate 15 (I-15) and traffic slowdowns or delays would only be expected to occur at the entrance to the proposed EREF during access road construction and shift changes, the impacts on overall traffic patterns and volumes during construction would be SMALL to MODERATE on US 20 and SMALL on I-15. The impacts from the truck traffic to and from the proposed site during construction would be SMALL. 

Operations impacts would occur from the transport of personnel and nonradiological and radioactive materials to and from the proposed EREF, especially during the period when construction and operation overlap. Increased traffic during operation of the proposed facility would have a SMALL to MODERATE impact on the current traffic on US 20 (SMALL for any off-peak shift change). The impacts of truck traffic to and from the proposed site during operation would be SMALL. Annual transportation accident impacts (radiological and chemical) would be SMALL. 

impacts could occur and could range from SMALL to LARGE. These impacts could be similar to those of the proposed action, depending on factors such as the existing road network and traffic patterns. 
 2-55 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Transportation (Cont.) Traffic during the initial portion of decommissioning would be approximately the same as for the period when construction and operations overlap. Traffic after the cessation of operations would be less than during either construction or operation. Impacts on local traffic on US 20 would be SMALL to MODERATE. Public and Occupational Health SMALL. During construction, nonradiological impacts include injuries and illnesses incurred by workers as well as impacts due to exposure to chemicals or other 

nonradiological substances. All such potential impacts would be SMALL. No radiological impacts are expected during construction. Nonradiological impacts during operation include worker illnesses and injuries and impacts from worker or public exposure to hazardous chemicals used or present during operations, mainly uranium and HF. Due to low estimated concentrations of uranium and HF at public (proposed property boundary) and workplace receptor locations, nonradiological impacts due to exposures to hazardous chemicals (including uranium and HF) during operations would be SMALL. 

SMALL. Health impacts from construction, operation, and decommissioning would not occur. Associated worker and public impacts from chemical and radioactive hazards would also not occur. Should the land be returned to grazing and agriculture, current use impacts would be expected. Should another domestic enrichment facility be constructed at an alternate location, public and occupational health impacts could occur and could range from SMALL to LARGE. These impacts could be similar to those of the proposed action, but would depend on factors such as the nature of the facility and the population density in the area and its proximity to the facility. 
 2-56 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Public and Occupational Health (Cont.) Assessment of potential radiological impacts from facility operations considers both public and occupational exposures to radiation, and includes exposures to workers completing facility construction during initial phases of operation. Exposure pathways include inhalation of airborne contaminants, ingestion of contaminated food crops, direct exposure from material deposited on the ground, and external exposure associated with stored UF6 cylinders. Worker exposures would vary by job type, but would be carefully monitored and maintained as low as 

reasonably achievable (ALARA) and impacts would be SMALL. For a hypothetical individual member of the public at the proposed EREF property boundary and the nearest resident, the maximum annual total effective dose equivalents would be 0.014 millisievert per year (1.4 millirem per year) and 2.1  10-6 millisievert per year 

(2.1  10-4 millirem per year), respectively. This equates 

to impacts from exposure of members of the public that would be SMALL. Dose equivalents attributable to operation of the proposed EREF would be small compared to the normal background radiation range of 2.0 to 3.0 millisievert 
 2-57 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Public and Occupational Health (Cont.) (200 to 300 millirem) dose equivalent. This equates to radiological impacts during operation of the proposed EREF that would be SMALL. The nature of decommissioning activities would be similar to those during construction and operation. Impacts from occupational injuries and illnesses and chemical exposures would be SMALL. Occupational radiological exposures would be bounded by the potential exposures during operation, because the quantities of uranium 

material handled would be less than or equal to that during operations. An active environmental monitoring and dosimetry (external and internal) program would be conducted to maintain ALARA doses to workers and to individual members of the public. Therefore, the impacts of decommissioning on public and occupational health would be SMALL. 

Waste Management SMALL. Construction would generate about 6116 cubic 

meters (8000 cubic yards) of nonhazardous solid waste, in addition to scrap structural steel, sheet metal, piping, etc., that would be recycled. About 23,000 liters (6200 gallons) 

and 1000 kilograms (2200 pounds) of hazardous waste would be generated annually. Disposal impacts would be SMALL because there is adequate disposal capacity at the appropriate disposal facilities. 

SMALL. No EREF construction, operational, or decommissioning wastes (including sanitary, hazardous, low-level radioactive, or mixed wastes) would be generated or require disposition. Local impacts from waste management would be SMALL as under current site conditions. 
 2-58 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Waste Management (Cont.) Annually, during operations, generation of approximately 70,307 kilograms (154,675 pounds) of industrial, nonhazardous, nonradioactive solid waste and approximately 146,400 kilograms (322,080 pounds) of low-level radioactive waste (not including depleted UF6) are expected. The proposed facility would also generate approximately 5062 kilograms (11,136 pounds) of hazardous wastes and 100 kilograms (220 pounds) of mixed waste annually. All wastes would be transferred to offsite licensed waste disposal facilities with adequate 

capacity for the proposed EREF wastes. Therefore, impacts during operations would be SMALL. Liquid process effluents would be treated and discharged by evaporation to the atmosphere. No process effluents from plant operations would be discharged to the retention or detention basins or into surface water. Impacts due to process water discharges from operations of the proposed EREF would be SMALL. 

Should another domestic enrichment facility be constructed at an alternate location, waste management impacts could occur and could range from SMALL to LARGE. These impacts could be similar to those of the proposed action but would depend on factors such as the nature of the facility and availability of waste disposal sites. 
 2-59 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Waste Management (Cont.) The proposed EREF is expected to generate 1222 cylinders of depleted UF6 annually, which would be temporarily stored on an outdoor cylinder storage pad. Storage of depleted UF6 tails cylinders at the proposed site would occur for the duration of, but not beyond, the proposed facility’s 30-year operating lifetime. An active cylinder maintenance program for stored cylinders such as that proposed by AES would result in a SMALL impact for cylinder storage. 

During decommissioning, materials eligible for recycling would be sampled or surveyed to ensure that contaminant levels would be below release limits. Radioactive material from decontamination and contaminated equipment would be packaged and shipped offsite to an appropriately licensed facility. Waste disposal would include approximately 7700 cubic meters (10,070 cubic yards) of low-level radioactive waste. Due to the availability of adequate disposal capacity, waste management impacts would be SMALL. 
 2-60 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Socioeconomics SMALL. The economic impacts of the proposed EREF project are evaluated for an 11-county region of influence (ROI) in Idaho – including Bannock, Bingham, Blaine, Bonneville, Butte, Caribou, Clark, Fremont, Jefferson, Madison, and Power Counties – which encompasses the area that is expected to be the primary source of labor for each phase of the proposed project, and where workers employed during construction and operation of the proposed EREF are expected to live and spend most of their salaries. The 11-county ROI is also the area in 

which a significant portion of site purchase and nonpayroll expenditures are expected to occur. The impacts of the EREF on population, housing, and community services are assessed for the two-county ROI, consisting of Bingham and Bonneville Counties, where most in-migrating construction and operations workers are likely to live, and where the majority of economic impacts would occur. The impacts of facility construction and operation would be SMALL. There would be increases in regional employment, income, and tax revenue during construction and operation. Wage and salary spending and expenditures associated with materials, equipment, and supplies would produce income and employment and local and State tax revenue. Although these impacts 

SMALL. Any beneficial or adverse consequences of the proposed action would not occur. Socioeconomic conditions in the ROI would remain unchanged, and the impact of no action would be SMALL. Population in the area surrounding the proposed EREF, in Bonneville and Bingham Counties, is expected to grow in accordance with current projections, with the total population in the region projected to be approximately 156,491 in 2013 and 168,331 in 2017. In addition to population growth, the social characteristics of the region, including housing availability, school enrollment, and availability of law enforcement and fire-fighting resources, are expected to change over time. However, future changes in these characteristics are difficult to quantify, and no projections of their future growth are available. Should another domestic enrichment facility be constructed at an alternate location, socioeconomic impacts could occur and could range from SMALL to LARGE. These impacts could be similar to those of the proposed action, 
 2-61 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Socioeconomics (Cont.) would be SMALL compared to the 11-county economic baseline, they are generally considered to be positive. Construction would create 1687 jobs and $65.0 million in the peak year, while operations would produce 3289 jobs and $92.4 million in income in the first year of operations. In-migration into the two-county ROI during construction and operation of the facility would also impact area housing resources and community services such as schools and law enforcement, and the availability and cost 

of public utilities such as electricity, water, sanitary services, and roads. These impacts could be negative if significant population in-migration were to occur; however, impacts would be SMALL. Decommissioning would provide continuing employment 

opportunities for the existing workforce and for other residents of the 11-county ROI. Expenditures on salaries and materials would contribute to the area economy, although less than during operations, and the State would continue to collect sales tax and income tax revenues. The socioeconomic impact of decommissioning activities would be SMALL. 

but would depend on the nature of the facility and 

on existing socioeconomic factors in the ROI associated with the alternate facility location. 
 2-62 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Environmental Justice SMALL. The majority of the environmental impacts on environmental resources associated with construction and operation of the proposed EREF would be mostly SMALL, and generally would be mitigated where necessary. For these resource areas, the associated impacts on all human populations would be SMALL, so there would not be any disproportionately high and adverse impacts on minority or low-income populations. Resources for which environmental impacts would be MODERATE are expected to most directly affect residents in the immediate 

area of the proposed EREF, but because there are no low-income or minority populations defined according to CEQ guidelines within the 4-mile area around the proposed facility, operation of the proposed facility also would not be expected to result in disproportionate impacts on low-income or minority residents, and therefore would not produce any environmental justice 

concerns. Impacts of decommissioning would be SMALL. Because impacts on the general population would generally be SMALL to MODERATE in other resource areas and because there are no low-income or minority populations defined according to CEQ guidelines within the 4-mile area around the proposed facility, decommissioning would not be expected to result in disproportionately high or adverse impacts on minority or low-income populations. 

SMALL. The no-action alternative would not be expected to cause any high and adverse impacts; it would not raise any environmental justice issues. Therefore, any impacts would be SMALL. Should another domestic enrichment facility be constructed at an alternate location, environmental justice impacts could occur and could range from SMALL to LARGE. These impacts would depend on factors such as the nature of the impact significance levels and populations impacted by the facility at the alternate location. 
 2-63 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Accidents SMALL to MODERATE. A range of six hypothetical facility accidents were considered. The accidents include a criticality accident and the remaining five accidents were representative accident scenarios that varied in severity from high- to intermediate-consequence events, including accidents initiated by natural phenomena (earthquake), operator error, and equipment failure. The latter five accidents could cause varying amounts of UF6 to be released, resulting in potential exposure to UF6 and its reaction products with humidity in the air, UO2F2, and HF. 

All credible accidents at the proposed EREF were considered. The consequence of a criticality accident would be high (fatality) for a worker in close proximity. Worker health consequences are low to high from five scenarios involving the release of UF6, due to uranium 

and/or HF chemical exposure. Radiological consequences to a maximally exposed individual (MEI) at the Controlled Area Boundary (proposed EREF property boundary) are low for all six accidents including the criticality accident. Uranium chemical exposure to the MEI is high for one accident and low for the remainder. For HF exposure to an MEI at the proposed property boundary, the consequence of three accidents is intermediate, with a low consequence estimated for the remainder. All accident scenarios predict consequences to the collective offsite public of less than one lifetime cancer fatality. Impacts 

SMALL. Under the no-action alternative, potential accidents and accident consequences from operation of the proposed EREF would not occur. Should another domestic enrichment facility be constructed at an alternate location, accident impacts could occur and could range from SMALL to LARGE. These impacts could be similar to those of the proposed action, but would depend on the nature of the facility at the alternate location. 
 2-64 Table 2-6 Summary of Environmental Impacts for the Proposed Action and the No-Action Alternative (Cont.) Affected Environment Proposed Action No-Action Alternative AES would construct, operate, and decommission the proposed EREF in Bonneville County, Idaho. The proposed EREF would not be constructed, operated, and decommissioned. Enrichment services would be met with existing domestic and foreign uranium enrichment suppliers and other planned or future facilities. Accidents (Cont.) from accidents would be SMALL to MODERATE. Plant design, passive and active engineered controls, and administrative controls would reduce the likelihood of accidents. 1 2 
 2-65 

1 A standard of significance has been established for assessing environmental impacts. Based 

2 on the Council on Environmental Quality’s regulations (40 CFR 1508.27), each impact is to be 

3 assigned one of the following three significance levels: 

4 

5 • SMALL. The environmental effects are not detectable or are so minor that they would 

6 neither destabilize nor noticeably alter any important attribute of the resource. 

7 

8 • MODERATE. The environmental effects are sufficient to noticeably alter but not destabilize 

9 important attributes of the resource. 

10 

11 • LARGE. The environmental effects are clearly noticeable and are sufficient to destabilize 

12 important attributes of the resource. 

13 

14 These impact levels are used in the summary and comparison of alternatives in Table 2-6. 

15 

16 2.5 Staff Recommendation Regarding the Proposed Action 

17 

18 After weighing the impacts of the proposed action and comparing the proposed action and the 

19 no-action alternative, the NRC staff, in accordance with 10 CFR 51.91(d), sets forth its NEPA 

20 recommendation regarding the proposed action. 

21 

22 The NRC staff recommends that, unless safety issues mandate otherwise, the proposed license 

23 be issued to AES. In this regard, the NRC staff has concluded that environmental impacts are 

24 generally SMALL, and application of the environmental monitoring program described in 

25 Chapter 6 and the proposed AES mitigation measures discussed in Chapter 5 would eliminate 

26 or substantially lessen any potential adverse environmental impacts associated with the 

27 proposed action. 

28 

29 The NRC staff has concluded that the overall benefits of the proposed EREF outweigh the 

30 environmental disadvantages and costs based on consideration of the following: 

31 

32 • The need for an additional economical domestic source of enrichment services. 

33 

34 • The environmental impacts from the proposed action are generally SMALL, although they 

35 could be as high as MODERATE for certain aspects of the areas of historic and cultural 

36 resources, visual and scenic resources, ecological resources, and transportation and as 

37 high as LARGE for certain aspects of air quality on a temporary basis. 

38 

39 2.6 References 

40 

41 (AES, 2009) AREVA Enrichment Services, LLC. Letter from Sam Shakir (President and CEO, 

42 AES) to the U.S. Nuclear Regulatory Commission dated June 17. “Subject: Request for 

43 Exemption from 10 CFR 70.4, 10 CFR70.23(a)(7), 10 CFR 30.4, 10 CFR 30.33(a)(5), 

44 10 CFR 40.4, and 10 CFR 40.32(e) Requirements Governing ‘Commencement of 

45 Construction.’” ADAMS Accession No. ML091770390. 

46 

47 (AES, 2010a) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

48 Environmental Report, Rev. 2.” Bethesda, Maryland. April. 

49 
 2-66 

1 (AES, 2010b) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility Safety 

2 Analysis Report, Rev. 2.” Bethesda, Maryland. April. 

3 

4 (DNFSB, 1995) U.S. Defense Nuclear Facilities Safety Board. “Integrity of Uranium 

5 Hexafluoride Cylinders.” Technical Report DNFSB/TECH-4. May 5.

6 

7 (DOE, 1995) U.S. Department of Energy. “Electricity Generation and Environmental 

8 Externalities: Case Studies.” DOE/EIA-0598. Energy Information Administration, Office of Coal, 

9 Nuclear Electric, and Alternative Fuels, Coal and Electric Analysis Branch. September. 

10 

11 (DOE, 1999a) U.S. Department of Energy. “Environmental Assessment, Disposition of Russian 

12 Federation Titled Natural Uranium.” DOE/EA-1290. Office of Nuclear Energy, Science, and 

13 Technology, Washington, D.C. June. 

14 

15 (DOE, 1999b) U.S. Department of Energy. “Final Programmatic Environmental Impact 

16 Statement for Alternative Strategies for the Long-Term Management and Use of Depleted 

17 Uranium Hexafluoride.” DOE/EIS-0269. Office of Nuclear Energy, Science, and Technology, 

18 Washington, D.C. April. 

19 

20 (DOE, 2000) U.S. Department of Energy. “Report to Congress on Maintenance of Viable 

21 Domestic Uranium, Conversion, and Enrichment Industries.” December. 

22 

23 (DOE, 2001) U.S. Department of Energy. “Effect of U.S./Russia Highly Enriched Uranium 

24 Agreement.” Report to Congress. Washington, D.C. December. <http://www.ne.doe.gov/ 

25 pdfFiles/HEUAgreement2001.pdf> (Accessed March 29, 2009). 

26 

27 (DOE, 2003) U.S. Department of Energy. “Cold Standby Program at the Portsmouth Gaseous 

28 Diffusion Plant.” DOE-0634. Audit Report. Office of Inspector General, Office of Audit 

29 Services. December. 

30 

31 (DOE, 2004a) U.S. Department of Energy. “Final Environmental Impact Statement for 

32 Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

33 Paducah, Kentucky Site.” DOE/EIS-0359. Office of Environmental Management. June 2004.

34 

35 (DOE, 2004b) U.S. Department of Energy. “Final Environmental Impact Statement for 

36 Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

37 Portsmouth, Ohio, Site.” DOE EIS-0360. Office of Environmental Management. June. 

38 

39 (DOE, 2010a) U.S. Department of Energy, National Nuclear Security Administration. 

40 “U.S.-Russian Highly Enriched Uranium Purchase Agreement.” January. <http://www.nnsa. 

41 energy.gov/nuclear_nonproliferation/highly_enriched_uranium_disposition.htm> (Accessed 

42 January 28, 2010). ADAMS Accession No. ML101790115. 

43 

44 (DOE, 2010b) U.S. Department of Energy. “DOE Awards Cleanup Contract for Portsmouth 

45 Decontamination and Decommissioning.” August, 16. Portsmouth Paducah Project Office. 

46 <http://www.pppo.energy.gov/pdf/Ports%20D%20%20D%20081210%209%20am%20FINAL.pdf

47 > (Accessed December 15, 2010). ADAMS Accession No. ML103500151. 

48 
 2-67 

1 (DOE, undated a) U.S. Department of Energy. DOE Digital Photo Archive, Image ID: 2010809. 

2 <http://www.doedigitalarchive.doe.gov/index.cfm?CFID=399386&CFTOKEN=78120854> 

3 (Accessed May 6, 2010). ADAMS Accession No. ML101790118. 

4 

5 (DOE, undated b) U.S. Department of Energy. DOE Digital Photo Archive, Image ID:2010833. 

6 <http://www.doedigitalarchive.doe.gov/index.cfm?CFID=399386&CFTOKEN=78120854> 

7 (Accessed May 6, 2010). ADAMS Accession No. ML101790142. 

8 

9 (EIA, 2010) Energy Information Administration, U.S. Department of Energy. “Uranium 

10 Marketing Annual Report.” U.S. Department of Energy. August. <http://www.eia.doe.gov/ 

11 cneaf/nuclear/umar/umar.html> (Accessed November 15, 2010). ADAMS Accession 

12 No. ML103480627. 

13 

14 (GE, 2006) GE Energy. “Press Release, GE Signs Agreement with Silex Systems of Australia 

15 To Develop Uranium Enrichment Technology.” Wilmington, N.C. May 22. 

16 <http://www.gepower.com/about/press/en/2006_press/052206b.htm> (Accessed June 21, 

17 2010). 

18 

19 (GLE, 2008) GE-Hitachi Global Laser Enrichment, LLC. “Environmental Report for the GLE 

20 Facility.” December. 

21 

22 (Hargrove, 2000) Hargrove, S. “Laser Technology Follows in Lawrence’s Footsteps.” In 

23 Science and Technology Review. Lawrence Livermore National Laboratory. 

24 May.<http://www.llnl.gov/str/Hargrove.html> (Accessed March 31, 2009). ADAMS Accession 

25 No. ML101790145. 

26 

27 (Heilbron et al., 1981) Heilbron, J.L., R.W. Seidel, and B.R. Wheaton. “Lawrence and His 

28 Laboratory: A Historian’s View of the Lawrence Years.” June. 

29 

30 (International Isotopes, 2009) International Isotopes, Inc. “License Application – Fluorine 

31 Extraction Process Depleted Uranium Hexafluoride De-conversion Plant (FEP/DUP).” 

32 December. ADAMS Accession No. ML100120736. 

33 

34 (Milani, 2005) Milani, K. “The Scientific History of the Atomic Bomb.” Hibbing Community 

35 College. <http://www.hcc.mnscu.edu/chem/abomb/index.html> (Accessed May 5, 2010). 

36 

37 (NRC, 1991) U.S. Nuclear Regulatory Commission. “Policy Issue: Disposition of Depleted 

38 Uranium Tails from Enrichment Plant.” SECY-91-019. January 25.

39 

40 (NRC, 2002) U.S. Nuclear Regulatory Commission. “Denial of Petition for Rulemaking to 

41 Eliminate Review of Alternate Sites, Alternative Energy Sources, and Need for Power in Nuclear 

42 Power Reactor Siting and Licensing Reviews (PRM-52-2).” SECY-02-0175. September 27. 

43 

44 (NRC, 2005a) U.S. Nuclear Regulatory Commission. “Memorandum and Order.” CLI-05-05. 

45 NRC Docket No. 70-3103. January 18. <http://www.nrc.gov/reading-rm/doc46 collections/commission/orders/2005/2005-05cli.html> (Accessed January 29, 2010). 

47 
 2-68 

1 (NRC, 2005b) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for the 

2 Proposed National Enrichment Facility in Lea County, New Mexico.” Final Report. 

3 NUREG-1790, Vol. 1. Office of Nuclear Material Safety and Safeguards, Washington, D.C. 

4 June. <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1790/> (Accessed July 21, 

5 2009). 

6 

7 (NRC, 2006) U.S. Nuclear Regulatory Commission. “Consolidated Decommissioning Guidance, 

8 Decommission Process for Materials Licensees.” NUREG-1757, Rev. 2. Office of Nuclear 

9 Material Safety and Safeguards, Washington, D.C. September. 

10 

11 (NRC, 2009a) U.S. Nuclear Regulatory Commission. “Enrichment Processes.” 

12 <http://www.nrc.gov/images/reading-rm/photo-gallery/20080922-013.jpg> (Accessed August 20, 

13 2009). 

14 

15 (NRC, 2009b) U.S. Nuclear Regulatory Commission. Letter from T. Johnson (U.S. Nuclear 

16 Regulatory Commission) to A. Kennedy (GE-Hitachi Global Laser Enrichment, LLC) dated 

17 August 6, 2009. “Subject: Acceptance of General Electric-Hitachi Global Laser Enrichment 

18 Application for a Laser-Based Uranium Enrichment Facility. ADAMS Accession 

19 No. ML091960561. 

20 

21 (NRC, 2010a) U.S. Nuclear Regulatory Commission. Letter from D. Dorman (U.S. Nuclear 

22 Regulatory Commission) to G. Harper (AREVA Enrichment Services, LLC) dated March 17. 

23 “Subject: Approval of AREVA Enrichment Services LLC Exemption Request Related to 

24 Requirements Governing Commencement of Construction (TAC L32730).” 

25 

26 (NRC, 2010b) U.S. Nuclear Regulatory Commission. “Press Release: NRC to Hold Public 

27 Meeting Jan. 14 in Hobbs, N.M., to Discuss License Review of Proposed Uranium 

28 De-Conversion Plant.” <http://www.nrc.gov/reading-rm/doc-collections/news/2010/10-002.html> 

29 (Accessed January 25, 2010). 

30 

31 (NRC, 2010c) U.S. Nuclear Regulatory Commission. “Draft Environmental Impact Statement for 

32 the Proposed GE-Hitachi Global Laser Enrichment LLC Facility in Wilmington, North Carolina.” 

33 NUREG-1938, Draft. Office of Federal and State Materials and Environmental Management 

34 Programs, Washington, D.C. June. 

35 

36 (OECD, 2001) Organisation for Economic Co-operation and Development. “Management of 

37 Depleted Uranium.” A joint report by the OECD Nuclear Energy Agency and the International 

38 Atomic Energy Agency. 

39 

40 (Settle, 2004) Settle, F. “Nuclear Chemistry, Uranium Enrichment.” Kennesaw State University. 

41 <http://www.chemcases.com/nuclear/nc-07.html> (Accessed March 31, 2009). ADAMS 

42 Accession No. ML101790147. 

43 

44 (Sparks, 2011) Personal communication from K. Sparks (Haselwood Enterprise, Inc.) to 

45 B. Biwer and H. Avci (Argonne National Laboratory). January 26, 2011. ADAMS Accession 

46 No. ML110340433. 

47 
 2-69 

1 (USEC, 1999) USEC Inc. “USEC Inc. Suspends AVLIS Technology Development.” News 

2 release. June 9. ADAMS Accession No. ML101790149. 

3 

4 (USEC, 2000) USEC Inc. “USEC to Cease Uranium Enrichment at the Portsmouth, Ohio, 

5 Facility in June 2001.” News release. June 21. ADAMS Accession No. ML101790160. 

6 

7 (USEC, 2003) USEC Inc. “USEC Ends Funding of Research on SILEX Process.” News 

8 release. April 30. ADAMS Accession No. ML101790166. 

 3-1 

1 3 AFFECTED ENVIRONMENT 

2 

3 This chapter describes the existing regional and local environmental conditions at and near the 

4 site of the proposed AREVA Enrichment Services, LLC (AES) Eagle Rock Enrichment Facility 

5 (EREF) before any preconstruction activities are performed and prior to the proposed action. 

6 After an initial overview of the proposed site location and activities, this chapter presents 

7 information on land use; historic and cultural resources; visual and scenic resources; 

8 climatology, meteorology, and air quality; geology, minerals, and soils; water resources; 

9 ecological resources; noise; transportation; public and occupational health; socioeconomics; 

10 and environmental justice. This information forms the basis for assessing the potential impacts 

11 of the proposed action in Chapter 4. 

12 

13 3.1 Site Location and Description 

14 

15 The proposed EREF site is located in eastern Idaho in Bonneville County, approximately 

16 32 kilometers (20 miles) west of Idaho Falls, Idaho, along US 20 and 117 kilometers (70 miles) 

17 west of the Idaho/Wyoming border (Figure 3-1). Idaho Falls, the closest population center, is 

18 located at the cross-junction of Interstate 15 (I-15) with US 20 and US 26. Approximately 

19 2 kilometers (1 mile) to the west of the proposed EREF property is the Idaho National 

20 Laboratory (INL), a large Federal Government-owned research laboratory that encompasses 

21 230,321 hectares (890 square miles or 569,135 acres). 

22 

23 The proposed EREF property consists of approximately 1700 hectares (4200 acres) to be 

24 purchased by AES from a single landowner. The proposed EREF site would occupy 

25 approximately 186 hectares (460 acres) within this area. An additional 53 hectares (132 acres) 

26 will be disturbed during preconstruction and construction by excavation of underground utilities 

27 and by temporary use for construction facilities, material storage, and parking. The proposed 

28 site and surrounding area within the proposed property boundary consist of rangeland, 

29 nonirrigated seeded pasture, and irrigated cropland. Wheat, barley, and potatoes are grown on 

30 389 hectares (962 acres) of the irrigated land (AES, 2010). Aside from the areas devoted to 

31 crops, the predominant plant type in the area is sagebrush steppe, which is seasonally grazed. 

32 

33 3.2 Land Use 

34 

35 This section describes the land uses in and near the proposed EREF property to be purchased 

36 by AES and the proposed EREF site within that property. This area includes the 186 hectares 

37 (460 acres) that the proposed EREF industrial site itself will occupy, plus an additional 

38 53 hectares (132 acres) that will be temporarily disturbed during preconstruction and 

39 construction. Therefore, this is the area that would be directly affected by preconstruction, 

40 construction, operation, and decommissioning of the proposed EREF. 

41 

42 The following discussion focuses on the region within 8 kilometers (5 miles) of the proposed 

43 EREF site. The proposed EREF site is located in Bonneville County; however, both Jefferson 

44 County to the north and Bingham County to the west are within 8 kilometers (5 miles) of the 

45 proposed EREF site. As a result, land use in all three counties is discussed below. Special 

46 land use classification areas are also discussed. 

47 

48 
 3-2 

1 

Figure 3-1 Location of Proposed Eagle Rock Enrichment Facility 2 
 3-3 

1 3.2.1 Bonneville County and Proposed EREF Property 

2 

3 Bonneville County is located in southeastern Idaho. The largest community in the county is 

4 Idaho Falls, the county seat, with a population of 101,667 as of the 2000 Census. Idaho Falls is 

5 located 32 kilometers (20 miles) east of the proposed EREF site. No other large cities are found 

6 in Bonneville County. Based on the available land use data for the county, the dominant land 

7 use is cultivated crops (17 percent), with undeveloped sagebrush or woodlands being the next 

8 largest land use (14 percent). Less than 3 percent of the land in the county is developed 

9 (USGS, 2009g). 

10 

11 The 1700-hectare (4200-acre) parcel of land to be purchased by AES is bordered on the west 

12 by State-owned land and to the south and east by U.S. Bureau of Land Management (BLM)-

13 managed lands as shown in Figure 3-2. The BLM land is managed for multiple uses, which 

14 include grazing and hunting (Reynolds, 2010). Also, there is private land to the northeast and 

15 south. To the north and west is the INL, which is a U.S. Department of Energy (DOE) applied 

16 engineering laboratory that covers approximately 2306 square kilometers (890 square miles). 

17 Much of the INL property is an undeveloped sagebrush-steppe environment. Laboratory 

18 complexes are scattered throughout the INL property. The nearest INL complex to the 

19 proposed EREF site is the Materials and Fuels Complex located approximately 18 kilometers 

20 (11 miles) to the west. South of the proposed EREF site is the Hell’s Half Acre National Natural 

21 Landmark (NNL) and Wilderness Study Area (WSA). A lava flow occurred in this location 

22 approximately 4100 years ago. The lava flow covers 57,498 hectares (222 square miles) of the 

23 Idaho desert. (See Section 3.2.4 for more discussion of Hell’s Half Acre.) Farming occurs 

24 northeast and southeast of the proposed EREF site. The nearest residence to the proposed 

25 EREF site is 8 kilometers (5 miles) to the east. 

26 

27 Land use within the 1700-hectare (4200-acre) parcel of land to be purchased by AES is 

28 primarily cultivated cropland (43 percent), followed by sagebrush-steppe (36 percent) and 

29 pasture/hay (7 percent), with the remainder being open space and upland grasslands 

30 (14 percent) (USGS, 2009g). A few agricultural buildings are located along US 20 near the 

31 south end of the proposed EREF property. There are no existing rights-of-way (ROWs) within 

32 the proposed EREF property. The proposed EREF property consists entirely of private land. 

33 Within the proposed property, there is a 16-hectare (40-acre) parcel of land managed by the 

34 BLM. AES has no plans to purchase the BLM parcel (AES, 2010). The 16-hectare parcel is 

35 surrounded by the proposed EREF property. Adjacent to an access road being purchased for 

36 the proposed project are two 6.5-hectare (16-acre) parcels on which the Federal Government 

37 previously held uranium land patents. The uranium leases have been relinquished 

38 (42 U.S. Code (U.S.C.) 2098 Sec. 68b). Some of the land located within the proposed property 

39 was designated as prime farmland by the U.S. Natural Resources Conservation Service 

40 (NRCS). The use of prime farmland is subject to review under the Federal Farmland Protection 

41 Policy Act (FPPA) (see Title 7 of the U.S. Code of Federal Regulations (7 CFR 658.2). Per 

42 7 CFR 658.2 (c)(1)(i), the intent of this Act is to protect prime farmland from other uses as the 

43 result of certain Federal actions. The Act does not apply to Federal permitting or licensing 

44 actions on private lands, such as the potential licensing of the proposed EREF by the NRC. In 

45 May 2010, DOE issued a conditional commitment for a Federal loan guarantee to AES for the 

46 proposed EREF (DOE, 2010a). Issuing a loan guarantee is subject to review under the FPPA 

47 to assess the effect of the project associated with the loan guarantee on prime farmland. DOE 

48 has conducted and submitted the required farmland conversion impact analysis to the NRCS 
 3-4 

1 

Figure 3-2 Special Land Use Classification Areas (BLM, 2009a; IDFG, 2010) 2 
 3-5 

1 (DOE, 2010b). The issuance of the Federal loan guarantee is not a factor in the NRC’s decision 

2 to issue a license. 

3 

4 The proposed EREF property is zoned by Bonneville County as Grazing Zone G-1. The zoning 

5 allows for manufacturing, testing, and storage of materials or products considered to be 

6 hazardous. Areas with this zoning designation are generally large tracts of open land. The 

7 purpose of the zone is to allow for certain uses and activities that should be conducted in 

8 locations removed from densely populated areas of the county. There are no building size or 

9 height restrictions within this zoning designation (Serr, 2009). 

10 

11 3.2.2 Bingham County 

12 

13 Bingham County is located approximately 6 kilometers (4 miles) west of the proposed EREF 

14 site. The county seat of Bingham County is Blackfoot, located 43 kilometers (27 miles) south of 

15 the proposed site. The population of Blackfoot was 10,419 in the 2000 Census. Atomic City, 

16 32 kilometers (20 miles) west of the proposed EREF site, is the nearest community in Bingham 

17 County to the proposed EREF. The population of Atomic City was reported as 25 in the 

18 2000 Census. The portion of the county within 8 kilometers (5 miles) of the proposed EREF site 

19 is zoned natural resources/agricultural (Halstead, 2009). Land use in the county consists 

20 primarily of rangeland (46.8 percent), with agricultural land (31.7 percent) and barren lands 

21 (14.9 percent) being the other main land uses (Bingham County, 2005). The primary 

22 agricultural products from Bingham County in 2002 were wheat and potatoes (USDA, 2002). 

23 

24 3.2.3 Jefferson County 

25 

26 Jefferson County is located directly north of the proposed EREF site The portion of the county 

27 that falls within 8 kilometers (5 miles) of the proposed EREF site is zoned Agricultural Forty 

28 Zone (Ag. 40 Acres) (Jefferson County, 2008). This zone allows for agricultural uses and the 

29 development of residential lots that are minimally 16 hectares (40 acres) in size (Jefferson 

30 County, 2005). Industrial uses are not permitted within this zoning designation. The nearest 

31 town in Jefferson County to the proposed site is Rigby, approximately 42 kilometers (26 miles) 

32 to the northeast. Rigby has a population of 2998 (2000 Census). Land use in Jefferson County 

33 is dominated by undeveloped sagebrush and rangeland (56 percent) and cultivated cropland 

34 and pasture (39 percent), with only minimal development (3 percent) (USGS, 2009g). 

35 

36 3.2.4 Special Land Use Classification Areas 

37 

38 There are ten special land use areas near the proposed EREF site (Figure 3-2). The closest is 

39 Hell’s Half Acre WSA just south of US 20, approximately 2 kilometers (1 mile) from the 

40 proposed site. A WSA is a BLM management designation for areas that (1) have retained their 

41 naturalness, with the imprint of man’s work substantially unnoticeable; (2) are large (at least 

42 2023 hectares [5000 acres]); and (3) have outstanding opportunities for solitude or for primitive 

43 or unconfined types of recreation in at least parts of the areas. Retaining wilderness 

44 characteristics is achieved by limiting road access and not allowing mineral leasing within a 

45 WSA. The northern portion of the Hell’s Half Acre WSA was named a National Natural 

46 Landmark (NNL) in 1973. National Natural Landmarks are chosen by the Secretary of the 

47 Interior to recognize some of the best examples of biological or geological resources in the 

48 nation. National Natural Landmarks are designated by the National Park Service. There are 
 3-6 

1 three additional NNLs in the region: Big Southern Butte NNL (51 kilometers [32 miles] to the 

2 southwest), North Menan Butte NNL (32 kilometers [20 miles] to the northeast), and Great Rift 

3 NNL (72 kilometers [45 miles] to the southwest). The 750,000-acre Craters of the Moon 

4 National Monument and Preserve is 80 kilometers (50 miles) west of the proposed EREF site; it 

5 is managed by the National Park Service and the BLM. There are two national forests located 

6 northwest of the INL property; these are the Challis National Forest (48 kilometers [30 miles] 

7 northwest) and the Targhee National Forest (48 kilometers [30 miles] north northwest). 

8 The Mud Lake Wildlife Management Area (WMA), located 35 kilometers (22 miles) north of the 

9 proposed site, and Market Lake WMA, located 32 kilometers (20 miles) northeast, are both 

10 managed for hunting by the Idaho Department of Fish and Game (IDFG). Camas National 

11 Wildlife Refuge is 43 kilometers (27 miles) north of the proposed EREF site and is managed by 

12 the U.S. Fish and Wildlife Service (FWS). Fort Hall Indian Reservation is 60 kilometers 

13 (37 miles) south of the proposed EREF site and is the property of the Shoshone-Bannock 

14 Tribes. The reservation was established in 1868 by the Fort Bridger Treaty. 

15 

16 3.3 Historic and Cultural Resources 

17 

18 This section describes the prehistoric and historic background of the area. 

19 

20 3.3.1 Prehistoric 

21 

22 The prehistory of southern Idaho is divided into the Early Prehistoric Period (13,000 B.C. to 

23 5500 B.C.), the Middle Prehistoric Period (5500 B.C. to A.D. 700), and the Late Prehistoric 

24 Period (A.D. 700 to A.D. 1700). The Clovis and Folsom cultures are associated with the Early 

25 Prehistoric Period. These cultures relied on hunting large mammals for survival. The climate 

26 was cooler and wetter than today. Projectile points associated with the Early Prehistoric 

27 Period’s Folsom culture have been found at sites within a mile of the proposed EREF site. 

28 There is evidence of more intensive use of local resources during the Middle Prehistoric Period. 

29 Grinding stones for processing plant food are commonly found on Middle Prehistoric 

30 archaeological sites. Large spear points were used during the Early Prehistoric Period. Smaller 

31 darts from the Middle Prehistoric Period suggest the hunting of smaller game. There were large 

32 climatic fluctuations during the Middle Prehistoric Period. The Late Prehistoric Period is marked 

33 by the introduction of the bow and arrow and the use of pottery. Most evidence suggests that 

34 mobility and hunting remained important parts of the subsistence strategies of the late 

35 prehistoric cultures. Sedentary seasonal farming along major rivers was more prevalent during 

36 the Late Prehistoric Period (INL, 2007). 

37 

38 3.3.2 Protohistoric and Historic Indian Tribes 

39 

40 Three tribal groups are known to have been in the vicinity of the proposed site during the 

41 protohistoric period (A.D. 1700 to 1850). They were the Shoshone, Paiute, and Bannock 

42 (Ringhoff et al., 2008). These groups engaged in seasonal rounds of foraging during which they 

43 exploited various resources. The lifeways of protohistoric tribes were greatly modified after 

44 1700 with the introduction of horses. The increased mobility allowed by the horse expanded the 

45 ranges of these groups and altered many of their customs. These were the same tribes that 

46 were present in the historic period. 

47 
 3-7 

1 3.3.3 Historic Euro-American 

2 

3 Historic use of the area began in the early 1800s when trappers came into the area to collect 

4 beaver skins. More intensive use of the land began in 1852 with the establishment of Goodale’s 

5 Cutoff in the northern portion of what is now the INL property. The cutoff began as a northern 

6 extension of the Oregon Trail. By 1860, the route began to be used for moving cattle and sheep 

7 from Oregon and Washington to eastern markets. From the 1860s to 1880s, numerous gold 

8 and other precious metal mines began to open in central Idaho, which led to increased traffic on 

9 Goodale’s Cutoff and the creation of numerous other roads and trails through the area. 

10 Ranches were established along the Big Lost River by the 1880s where livestock was raised 

11 and then transported across what would become INL. Populations began to rise steadily with 

12 passage of the Carey Land Act of 1894 and the Desert Reclamation Act of 1902, which set 

13 aside a million acres of public lands for homesteading and provided funds to aid in development 

14 of irrigation systems, respectively (INL, 2007). 

15 

16 By the early 20th century, the town of Powell had been established on the INL property near the 

17 intersection of the Oregon Shortline Railroad (now the Union Pacific Railroad) and the Big Lost 

18 River. The town was located near the current location of INL’s Radioactive Waste Management 

19 Complex. Most of the homesteads failed by the 1920s and were abandoned due to a lack of 

20 available water resulting from extensive water use upstream of the INL property for irrigation 

21 (INL, 2007). 

22 

23 3.3.4 Historic and Archaeological Resources in the Vicinity of the Proposed Site 

24 

25 Significant archaeological sites are found in the vicinity surrounding the proposed EREF 

26 property. One of the most important sites found in the region is the Wasden Complex located 

27 approximately 1.6 kilometers (1 mile) from the proposed EREF site. The Wasden Complex is a 

28 series of lava blister caves that contain evidence of human use dating back to at least 

29 10,000 B.C. The complex shows evidence of people hunting mammoth and a type of bison that 

30 is now extinct (INL, 2007). Complexes of this age that have direct evidence of humans hunting 

31 extinct animals are extremely rare. The complex is made up of three distinct sites. The sites 

32 contain evidence of continuous use up to the Historic Period. 

33 

34 The Area of Potential Effect (APE) for the National Historic Preservation Act of 1966 (NHPA) 

35 Section 106 review of the proposed project, as defined by the U.S. Nuclear Regulatory 

36 Commission (NRC), is the 240-hectare (592-acre) portion of the proposed site that would be 

37 directly affected by preconstruction and construction activities. Archaeological surveys have 

38 been undertaken by AES’s archaeological contractor for the proposed project. The contractor 

39 directly examined 381 hectares (941 acres) of the proposed EREF property 

40 (Ringhoff et al., 2008), within which the 240-hectare (592-acre) APE is included. The acreage 

41 surveyed included additional areas for expansion outside the presently proposed construction 

42 and operations areas, which are no longer deemed necessary for the proposed project. An 

43 additional 26 hectares (64 acres) was surveyed in 2009 due to changes in the project design 

44 (Estes and Raley, 2009). This brought the amount of land surveyed for historic and cultural 

45 resources to 407 hectares (1005 acres). The AES surveys identified 13 archaeological sites 

46 and 24 isolated finds within the APE. Isolated finds are isolated occurrences of cultural 

47 resource material that are not associated with subsurface remains and are not considered 

48 archaeological sites. Three of the archaeological sites were prehistoric in age, six were from 
 3-8 

1 the historic era, and four contained evidence from both the historic and prehistoric periods 

2 (Ringhoff et al., 2008). The prehistoric sites consisted of stone tools or evidence of stone tool 

3 manufacture. The historic sites were primarily historic trash scatters consisting of cans and 

4 glass. None of the isolated finds are considered eligible for listing on the NRHP. On the basis 

5 of the survey results, nine of the sites were recommended not eligible for listing on the National 

6 Register of Historic Places (NRHP). One site, the John Leopard Homestead (MW004), is 

7 recommended eligible for listing on the NRHP for its potential to provide information on the 

8 practices of historic era farmers in the region. Several other sites of this type have been 

9 previously identified on INL property north of the proposed EREF site (Gilbert, 2010). MW004 

10 consists of several structural remains including a cistern, privy, and historic dugout house 

11 foundation. AES’s archaeological contractor recommended additional research for three other 

12 sites found during the survey (MW002, MW012, and MW015). Subsequently, AES’s 

13 archaeological contractor found that these three sites lacked sufficient information to be 

14 considered significant (Ringhoff et al., 2008). 

15 

16 The NRC conducted a file search for the 1700-hectare (4200-acre) parcel. The file search 

17 revealed that the proposed EREF property had not been previously surveyed for the presence 

18 of historic and cultural resources (i.e., prior to AES’s license application); therefore, no 

19 resources were previously known. The file search identified seven previously recorded 

20 archaeological sites within one mile of the proposed EREF. Three of the sites are associated 

21 with the Wasden Complex (10BV30, 10BV31, and 10BV32) and are all eligible for listing on the 

22 NRHP. 10BV30 is known as Owl Cave and contains some of the only known evidence of early 

23 prehistoric peoples in association with extinct mammoth bones. 10BV31 is known as Coyote 

24 Cave and also contains extensive evidence of human use. The final site associated with the 

25 Wasden Complex is 10BV32, which is also a collapsed lava tube. A fourth site (10BV47) 

26 consisted of a fluted spear point and associated materials and is considered eligible for listing 

27 on the NRHP. No information was available for the remaining three sites (10BV83, 10BV84, 

28 and 10BV87). 

29 

30 3.4 Visual and Scenic Resources 

31 

32 This section describes the visual and scenic resources in the vicinity of the proposed EREF. 

33 

34 The proposed EREF site is on undeveloped land 32 kilometers (20 miles) west of Idaho Falls, 

35 Idaho. The main portion of the proposed facility would be located approximately 3 kilometers 

36 (1.7 miles) north of US 20 (Figure 3-3). The tallest structures at the proposed facility would be 

37 approximately 20 meters (65 feet) high. The area is gently rolling, sagebrush semi-desert, with 

38 some high points (Figure 3-4). The tallest vegetation on the proposed property is sagebrush 

39 that stands approximately 1 meter (3 feet) tall. The highest point in the vicinity of the proposed 

40 project is Kettle Butte, which is located 1.2 kilometers (0.75 mile) east of the proposed EREF 

41 (Figure 3-5). Larger buttes are visible in the distance. The eastern portion of the proposed 

42 EREF site is currently used for agriculture. Single-story agriculture storage structures are 

43 located adjacent to US 20 on the proposed property in the vicinity of the proposed EREF site 

44 (Figure 3-6). The nearest residence is 7.7 kilometers (4.8 miles) east of the proposed site along 

45 US 20. 

46 

47 
 3-9 

1 

2 Figure 3-3 Photo of the Proposed EREF Site Area (AES, 2010) 

3 

4 

5 Figure 3-4 Center of Proposed EREF Site Area Facing South (AES, 2010) 
 3-10 

1 

2 Figure 3-5 Photo from US 20 Facing North 

3 (Note butte in distance.) (Argonne staff photo) 

4 

5 

6 Figure 3-6 Agricultural Sheds near Proposed EREF Site Area (AES, 2010) 
 3-11 

1 

2 Figure 3-7 Hell’s Half Acre National Natural Landmark (Argonne staff photo) 

3 

4 The lands immediately surrounding the proposed property to the west, north, and east are 

5 primarily covered in sagebrush semi-desert. The land to the west and north is managed by 

6 BLM and currently used for grazing and multiple use, a BLM land management designation 

7 (Reynolds, 2010). The land to the south of US 20 is a mix of private and BLM-managed land. 

8 Some of the private land to the southeast is under cultivation. Much of the land south of the 

9 proposed site is the remains of a 4000-year-old lava flow, which is managed by the BLM as 

10 Hell’s Half Acre WSA (Figure 3-7). See Section 3.2.4 for a description of WSA and NNL. 

11 

12 Another visually sensitive resource in the vicinity of the proposed project is the Wasden 

13 Complex, a significant archaeological complex. See Section 3.3.4 for a discussion of the 

14 Wasden Complex. 

15 

16 BLM has developed a visual resource management (VRM) system to manage the resources 

17 under its control (BLM, 2009b). Even though the BLM’s VRM system is officially applicable only 

18 to BLM land, it does provide a useful tool for generally inventorying and managing visual 

19 resources. The system has two main components. The first is the visual resource inventory 

20 (VRI), which attempts to establish the inherent visual qualities of an area, assess whether the 

21 public has any concerns related to scenic quality for a location, and determine if there are key 

22 observation points for a given location. The inventory characterizes the visual appeal of a 

23 location and is discussed further below. The second component of the system is the VRM 

24 rating, which reflect the management decisions made by the BLM defining how they will 

25 manage the visual resources in a given location. There are four levels of VRM rating, 

26 designated as VRM Classes I to IV, with VRM Class I being the most restrictive and protective 

27 of the visual landscape and IV being the least restrictive. VRM Class I areas are managed to 
 3-12 

1 preserve their existing visual character. VRM II areas are managed to retain their existing visual 

2 character; VRM III areas are managed to partially retain their existing visual character; and 

3 VRM IV areas are those that allow major modification of the existing visual character of the 

4 landscape. 

5 

6 The Hell’s Half Acre WSA has a VRM rating of I, which indicates that the BLM has decided to 

7 manage the area to retain its existing character. Under VRM I, the level of change must not 

8 attract viewer attention. The lands surrounding the WSA and the property to be purchased by 

9 AES are designated as VRM II by the BLM. They are managed to retain their existing visual 

10 character. Changes in the characteristics of the location should be low and should not attract 

11 the attention of a viewer (BLM, 2009b). 

12 

13 The BLM VRI process involves evaluating the visual landscape to determine the (1) sensitivity 

14 of the location for visual intrusions, (2) scenic qualities of the location, and (3) distance from 

15 which the location would be viewed. Sensitivity refers to the public’s concern or expectation for 

16 scenic quality. Sensitivity is based on the types of users that would view the location 

17 (e.g., recreational users, commuters, or workers), the amount of use, public interest, and 

18 adjacent land uses. Distance considerations are a factor when determining visual resource 

19 inventory values and associated impacts. The proposed EREF site is located within 

20 3 kilometers (2 miles) of US 20, which would place it in the foreground-middleground zone 

21 where visual intrusions are very obvious, as opposed to the distant background where they are 

22 less obvious. Visual intrusions in this zone typically have the greatest apparent contrast 

23 because they are highly visible from key observation points. 

24 

25 Sensitivity is an important factor in the VRI process because it addresses the expectation for 

26 pristine environments. The proposed EREF property is in a relatively undeveloped setting. 

27 US 20 is most heavily used by workers commuting to INL. Other people traveling US 20 include 

28 farmers going to their fields and tourists visiting the Hell’s Half Acre WSA. The public has not 

29 expressed any opinions indicating a preference for or against maintaining the current visual 

30 situation (see Appendix A). Uses for adjacent land in the immediate vicinity of the proposed 

31 property include farming and the Hell’s Half Acre WSA. Most of the area surrounding the 

32 proposed EREF site is undeveloped sagebrush semi-desert. Industrial developments are found 

33 on INL, but none of them are visible from the proposed site. Sensitivity to changes in the visual 

34 landscape would be expected to be low for workers and farmers using the area and moderate to 

35 high for those using the Hell’s Half Acre WSA. 

36 

37 The VRI process measures the scenic quality of an area through application of the scenic 

38 quality rating criteria, which cover landforms, vegetation, water, color, adjacent scenery, 

39 scarcity, and cultural modification. The scenic quality criteria applied to a landscape are 

40 presented in Table 3-1. Examples of how to apply the criteria are presented in Table 3-2. The 

41 landform is rolling desert landscape with large open vistas (Rating 1). The vegetation is 

42 primarily sagebrush semi-desert (Rating 1). No water sources are evident from the proposed 

43 site (Rating 0). The color range in the proposed site area is various hues of green from the 

44 sagebrush environment and the agricultural fields (Rating 1). Adjacent scenery is similar to that 

45 found in the proposed site area and has little influence on the visual quality (Rating 1). Although 

46 the proposed site is adjacent to the unique geologic features associated with Hell’s Half Acre 

47 WSA, the land occupied by the proposed project is not unique (Rating 1). Currently, very little 

48 by way of cultural modifications are visible in the proposed site area. Storage sheds, 
 3-13 

Table 3-1 Scenic Quality: Explanation of Rating Criteria 

Landform Topography becomes more interesting as it gets steeper, more massive, or 

more severely or universally sculptured. Outstanding landforms may be 

monumental (e.g., Grand Canyon in Arizona, Sawtooth Mountain Range in 

Idaho, Wrangell Mountain Range in Alaska) or exceedingly artistic and subtle 

(e.g., certain badlands, pinnacles, arches, and other extraordinary formations). 

Vegetation Ratings give primary consideration to the variety of patterns, forms, and textures 

created by plant life. They consider short-lived displays when they are known to 

be recurring or spectacular. They also consider smaller-scale vegetative 

features that add striking and intriguing detail elements to the landscape 

(e.g., gnarled or wind-beaten trees and joshua trees). 

Water Ratings consider ingredients that add movement or serenity to a scene. The 

degree to which water dominates the scene is the primary consideration in 

selecting the rating score. 

Color Ratings consider the overall color(s) of the basic components of the landscape 

(e.g., soil, rock, vegetation) as they appear during seasons or periods of high 

use. Key factors to use when rating “color” are variety, contrast, and harmony. 

Adjacent Scenery Ratings consider the degree to which scenery outside the unit being rated 

enhances the overall impression of the scenery within the rating unit. The 

distance from which adjacent scenery influences scenery within the rating unit 

normally ranges from zero to 8 kilometers (5 miles), depending on the 

characteristics of the topography, vegetative cover, and other such factors. This 

criterion is generally applied to units that would normally score very low, but for 

which the influence of the adjacent unit would enhance the visual quality and 

raise the score. 

Scarcity This criterion provides an opportunity to give added importance to one or all of 

the scenic features that appear to be relatively unique or rare within one 

physiographic region. It also covers cases for which a separate evaluation of 

each of the key criteria does not give a true picture of the overall scenic quality 

of an area. It is often the case that a number of rather unspectacular elements, 

in the proper combination, produce the most pleasing and memorable scenery. 

The scarcity criterion can be used to recognize this type of area and give it the 

added emphasis it needs. 

Cultural 

Modifications 

Cultural modifications in the landform, water, and vegetation, as well as the 

addition of structures, should be considered. They may detract from the scenery 

in the form of a negative intrusion or complement or improve the scenic quality of 

a unit. They should be rated accordingly. 

Source: BLM, 2007.

1 
 3-14 

Table 3-2 Scenic Quality Inventory and Evaluation Chart 

Key Factors Rating Criteria and Score 

Landform High vertical relief as expressed 

in prominent cliffs, spires, or 

massive rock outcrops; or severe 

surface variation or highly eroded 

formations, including major 

badlands or dune systems; or 

detail features dominant and 

exceptionally striking and 

intriguing, such as glaciers. 

5 

Steep canyons, mesas, 

buttes, cinder cones, and 

drumlins; or interesting 

erosional patterns or 

variety in the size and 

shape of landforms; or 

detail features that are 

interesting but not 

dominant or exceptional. 

3 

Low rolling hills, 

foothills, or flat valley 

bottoms; or few or no 

interesting landscape 

features. 

1 

Vegetation A variety of vegetative types as 

expressed in interesting forms, 

textures, and patterns. 

5 

Some variety of 

vegetation, but only one 

or two major types. 

3 

Little or no variety or 

contrast in vegetation. 

1 

Water Clear and clean appearing, still, 

or cascading white water, any of 

which is a dominant factor in the 

landscape. 

5 

Flowing, or else still but 

not dominant in the 

landscape. 

3 

Absent, or else 

present but not 

noticeable. 

0 

Color Rich color combinations, variety 

or vivid color; or pleasing 

contrasts in the soil, rock, 

vegetation, water, or snow fields. 

5 

Some intensity or variety 

in colors and contrasts of 

the soil, rock, and 

vegetation, but not a 

dominant scenic element. 

3 

Subtle color variations, 

contrast, or interest; 

generally mute tones. 

1 

Adjacent 

Scenery 

Adjacent scenery greatly 

enhances visual quality. 

5 

Adjacent scenery 

moderately enhances 

overall visual quality. 

3 

Adjacent scenery has 

little or no influence on 

overall visual quality. 

0 

Scarcity One of a kind; or unusually 

memorable, or very rare within 

region. Consistent chance for 

exceptional wildlife or wildflower 

viewing, etc. 

5+ 

Distinctive, although 

somewhat similar to 

others within the region. 

3 

Interesting within its 

setting, but fairly 

common within the 

region. 

1 

Cultural 

Modification 

Modifications add favorably to 

visual variety while promoting 

visual harmony. 

2 

Modifications add little or 

no visual variety to the 

area and do not introduce 

discordant elements. 

0 

Modifications add 

variety but are very 

discordant and 

promote strong 

disharmony. 

-4 

Source: BLM, 2007.

1 
 3-15 

1 agricultural crops, and US 20 are the only visible cultural modifications (Rating 0). The overall 

2 scenic quality rating is 5. According to the BLM VRI criteria, an A or high quality classification is 

3 for a rating of 19 or more. For a rating of 12 to 15, the area is considered a B, and a rating of 

4 11 or less is a C (BLM 2009). The scenic resource inventory rating for the landscape near the 

5 proposed EREF is a C, which means that the proposed EREF site does not contain a high level 

6 of scenic quality. 

7 

8 3.5 Climatology, Meteorology, and Air Quality 

9 

10 This section describes the climatology, meteorology, and air quality of the proposed EREF site 

11 and vicinity. 

12 

13 3.5.1 Climatology 

14 

15 3.5.1.1 Idaho 

16 

17 Idaho lies 480 kilometers (300 miles) east of the Pacific Ocean, but is nevertheless influenced 

18 by maritime air carried east by the prevailing westerly winds. The maritime influence is 

19 strongest in the northern part of the State with wet winters and dry summers. Eastern Idaho’s 

20 climate is more continental in character than the western and northern portions of the State and 

21 is instead characterized as a semiarid steppe with dry winters and wet summers. Temperature 

22 patterns in the State are influenced by latitude and elevation. Precipitation patterns in Idaho are 

23 complex, with most of the moisture coming from the Pacific Ocean. Snowfall is affected by 

24 elevation and moisture availability with major mountain ranges accumulating deep snow in the 

25 winter. Floods occur most often during the spring snowmelt, but there are out-of-season floods. 

26 Fog events are extremely variable in frequency. Windstorms are not uncommon, but Idaho has 

27 no hurricanes and an extremely small incidence of tornadoes. The annual percentage of 

28 possible sunshine ranges from about 50 percent in the north to about 70 percent in the south, 

29 with lower frequencies in the winter and up to near 80 percent during July and August in the 

30 east and north (NCDC, 2009a). 

31 

32 3.5.1.2 Proposed EREF Site 

33 

34 The proposed EREF site lies in the middle of the Eastern Snake River Plain (ESRP), a broad, 

35 flat river valley running southwest to northeast for about 80 kilometers (50 miles). The average 

36 elevation of the valley is about 1524 meters (5000 feet) mean sea level (MSL), and it is 

37 bordered by mountain ranges rising to about 3353 meters (11,000 feet) MSL. The orientations 

38 of the valley and the bordering mountains have a significant impact on the wind flow patterns at 

39 the proposed EREF site. Air masses typically move from west to east and lose their moisture 

40 over the mountains to the west before reaching the ESRP. Thus, rainfall is generally light and 

41 the region is semiarid. The temperature regime is moderate. There is little cloud cover and 

42 generally large diurnal temperature variation (AES, 2010). 

43 

44 3.5.2 EREF Site Meteorology 

45 

46 Four National Weather Service (NWS) stations in the vicinity of the proposed EREF produce 

47 meteorological data that are generally representative of conditions at the proposed EREF site: 

48 
 3-16 

1 • Kettle Butte (KET), 

2 

3 • Idaho National Laboratory (MFC), 

4 

5 • Idaho Falls 46 West (ID46W), and 

6 

7 • Idaho Falls 2 ESE (ID2ESE), an urban location. 

8 

9 These stations are all located in the ESRP, and are shown in Figure 3-8. These are the closest 

10 NWS monitoring stations to the proposed EREF site; weather data collected at these sites is 

11 therefore most representative of weather that can be expected at the proposed EREF site. 

12 

13 3.5.2.1 Temperature 

14 

15 Figure 3-9 presents monthly mean temperature data for all four meteorological stations. 

16 Temperature trends throughout the year are similar at all four stations. During July and August, 

17 the monthly average temperatures at MFC and KET are higher than at the other two stations, 

18 and the monthly average temperature is always lowest at ID46W (AES, 2010). 

19 

20 Table 3-3 tabulates more detailed, long-term data from NCDC for the ID46W (48 years of data) 

21 and ID2ESE (50 years of data) sites. Both stations show monthly average temperatures as 

being lowest in January and highest in July.1 22 The smallest daily temperature range at both 

23 stations occurs in winter and the largest in summer, due to the more intense solar radiation 

24 experienced in summer. The urban ID2ESE station experiences a smaller daily variation in 

25 temperature than the rural ID46W station. The highest and lowest temperatures recorded at 

26 ID2ESE are 38C (100F) and –37C (–34F), and are 38C (101F) and –44C (–47F) at 

27 ID46W (AES, 2010). 

28 

29 3.5.2.2 Precipitation and Relative Humidity 

30 

31 Precipitation

32 

33 Air masses approaching the proposed EREF site from the west must cross high mountain 

34 ranges, making the annual precipitation light. Table 3-4 presents normal and extreme 

35 precipitation data collected at the ID2ESE and ID46W monitoring stations. Showers and 

36 thundershowers occur in the summer. Spring and fall precipitation are generally showers or 

37 steady rain. Winter precipitation is usually snow (AES, 2010; NOAA, 2004a,b). 

38 

39 Annual average precipitation at ID2ESE is about 361 millimeters (14.2 inches) with a peak in 

40 May. The maximum monthly recorded precipitation is 116 millimeters (4.56 inches) in May 

41 1993. Annual average precipitation at ID46W is less, about 224 millimeters (9 inches). The 

42 maximum monthly recorded precipitation is 118 millimeters (4.64 inches) in June 1995. There 

43 have been at least 10 months with no recorded precipitation in the 30-year period of record. 

44 

 

1

 The monthly average temperature is –6.1C (21.1F) in January and 20.4C (68.7F) in July at 

ID2ESE, and –8.8C (16.2F) in January and 19.8C (67.6F) in July at ID46W. 
 3-17

1 

Figure 3-8 Meteorological Monitoring Stations near the Proposed EREF Site 2 
 3-18 

1 

2 Figure 3-9 Monthly Mean Temperatures in the Vicinity of the Proposed EREF Site 

3 (AES, 2010) 

4 

5 Figure 3-10 compares monthly mean precipitation at the four nearby stations (the data for MFC 

6 and KET are from 2003 to 2007 and are not concurrent with the 1971–2000 record for the other 

7 two sites. All four stations have higher precipitation in the spring (April–June) with a second 

8 increase in October at MFC and KET. IDESE2 always has the highest precipitation (AES, 2010; 

9 NOAA, 2004a,b). 

10 

11 Based on hourly data for KET and MFC for 2003–2007, precipitation occurs only 3 percent of 

12 the time and is mostly less than 2.5 millimeters (0.1 inch) (AES, 2010). 

13 

14 Annual average snowfall at ID2ESE is 833 millimeters (32.8 inches) with a highest daily snowfall 

15 of 254 millimeters (10 inches) that has occurred at least twice during the 39 years from January 

16 1950 through December 1988. The highest monthly snowfall was 572 millimeters (22.5 inches) 

17 in December 1994. Annual average snowfall at ID46W is 637 millimeters (25.1 inches) with a 

18 highest daily snowfall of 218 millimeters (8.6 inches). The highest monthly snowfall was 

19 566 millimeters (22.3 inches) in December 1971 (NOAA, 2004a,b). 

20 

21 Relative Humidity

22 

23 Table 3-5 presents monthly and annual average relative humidity data for ID46W for the period 

24 1956–1961. Relative humidity is higher in the winter and lower in the summer. Values of 

25 100 percent have been observed in all months except July. During the day, the highest relative 

26 humidity generally occurs near sunrise, and the lowest in mid-afternoon (Clawson et al., 1989). 
 3-19 Table 3-3 Mean, Average, and Extreme Temperatures near the Proposed EREF Site Station Temperaturea PORb Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Ann Idaho Falls 2 ESE (ID2ESE) Extreme highest 1952–2001 55.0 63.0 75.0 85.0 92.0 100.0 100.0 100.0 95.0 87.0 73.0 60.0 100.0 12.8 17.2 23.9 29.4 33.3 37.8 37.8 37.8 35.0 30.6 22.8 15.6 37.8 Mean maximum 1971–2000 29.7 36.6 47.6 58.7 67.9 77.8 86.0 85.8 75.1 61.4 43.0 31.3 58.4 –1.3 2.6 8.7 14.8 19.9 25.4 30.0 29.9 23.9 16.3 6.1 –0.4 14.7 Average 1971–2000 21.1 26.7 36.2 45.0 53.3 61.9 68.7 67.9 58.2 46.8 33.1 22.4 45.1 –6.1 –2.9 2.3 7.2 11.8 16.6 20.4 19.9 14.6 8.2 0.6 –5.3 7.3 Mean minimum 1971–2000 12.5 16.8 24.8 31.3 38.7 46.0 51.4 49.9 41.3 32.2 23.2 13.4 31.8 –10.8 –8.4 –4.0 –0.4 3.7 7.8 10.8 9.9 5.2 0.1 –4.9 –10.3 –0.1 Extreme lowest 1952–2001 –29.0 –34.0 –15.0 9.0 20.0 28.0 34.0 31.0 18.0 7.0 –12.0 –29.0 –34.0 –33.4 –36.7 –26.1 –12.8 –6.7 –2.2 1.1 –0.6 –7.8 –13.9 –24.4 –33.7 –36.7 Idaho Falls 46 W Extreme highest 1954–2001 51.0 60.0 73.0 86.0 91.0 100.0 101.0 101.0 96.0 87.0 67.0 57.0 101.0 10.6 15.6 22.8 30.0 32.8 37.8 38.3 38.3 35.6 30.6 19.4 13.9 38.3

 Mean maximum 1971–2000 27.9 34.0 44.8 56.9 66.3 76.8 86.6 85.7 74.6 60.9 41.4 29.4 57.1c

 –2.3 1.1 7.1 13.8 19.1 24.9 30.3 29.8 23.7 16.1 5.2 –1.4 13.9 Average 1971–2000 16.2 22.1 32.8 42.4 51.2 60.0 67.6 66.2 55.7 43.4 28.7 17.1 42.0

 –8.8 –5.5 0.4 5.8 10.7 15.6 19.8 19.0 13.2 6.3 –1.8 –8.3 5.6 Mean minimum 1971–2000 4.5 10.2 20.7 27.9 36.1 43.2 48.5 46.7 36.8 25.9 15.9 4.8 26.8c

 –15.3 –12.1 –6.3 –2.3 2.3 6.2 9.2 8.2 2.7 –3.4 –8.9 –15.1 –2.9 Extreme lowest 1954–2001 –40.0 –36.0 –28.0 6.0 13.0 23.0 28.0 24.0 12.0 1.0 –24.0 –47.0 –47.0

 –40.0 –37.8 –33.3 –14.4 –10.6 –5.0 –2.2 –4.4 –11.1 –17.2 –31.1 –43.9 –43.9

a For each temperature, the first line gives the temperature in F, the second in C. b POR: Period of Record. C Average of the twelve monthly means. 

Source: NOAA, 2004a,b.

1 
 3-20 Table 3-4 Monthly Precipitation near the Proposed EREF Site Monthly Precipitation Station Totala PORb Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual Total Idaho Falls 2 ESE Highest 1952–2001 2.38 3.13 4.30 2.82 4.56 3.16 2.13 2.66 2.81 2.49 3.20 3.18 60.45 79.50 109.22 71.63 115.82 80.26 54.10 67.56 71.37 63.25 81.28 80.77 Average 1971–2000 1.25 1.01 1.33 1.27 2.01 1.18 0.74 0.93 0.94 1.12 1.17 1.26 14.21 31.75 25.65 33.78 32.26 51.05 29.97 18.80 23.62 23.88 28.45 29.72 32.00 360.93 Lowest 1952–2001 0.22 0.00 0.04 0.20 0.33 0.15 0.00 0.07 0.00 0.00 0.00 0.00 5.59 0.00 1.02 5.08 8.38 3.81 0.00 1.78 0.00 0.00 0.00 0.00 Idaho Falls 46 W Highest 1954–2001 1.20 2.36 2.03 1.99 2.34 4.64 2.29 1.13 2.08 1.67 1.74 1.91 30.48 59.94 51.56 50.55 59.44 117.86 58.17 28.70 52.83 42.42 44.20 48.51 Average 1971–2000 0.64 0.62 0.69 0.79 1.24 1.08 0.66 0.44 0.73 0.57 0.69 0.67 8.82 16.26 15.75 17.53 20.07 31.50 27.43 16.76 11.18 18.54 14.48 17.53 17.02 224.03 

 Lowest 1954–2001 0.01 0.00 0.00 0.00 0.31 0.01 0.00 0.02 0.00 0.00 0.00 0.00 0.25 0.00 0.00 0.00 7.87 0.25 0.00 0.51 0.00 0.00 0.00 0.00 a For each statistic, the first line gives the precipitation in inches, the second in millimeters. b POR: Period of Record. 

Source: NOAA, 2004a,b. 

1 
 3-21 

1 

2 Figure 3-10 Monthly Mean Precipitation in the Vicinity of the Proposed EREF Site 

3 (AES, 2010; NOAA, 2004a,b) 

4 

5 3.5.2.3 Winds, Atmospheric Stability, and Temperature Inversions 

6 

7 Winds

8 

9 Several phenomena influence the wind patterns at the proposed EREF property. It is in the 

10 region of prevailing westerly winds that are channeled by the topography within and surrounding 

11 the ESRP to produce predominantly west-southwest or southwesterly winds. Some of the 

highest wind speeds are observed under these conditions. Drainage winds2 12 also affect the wind 

13 flow at the proposed EREF site. On clear nights, air near the ground, including mountain 

14 slopes, cools rapidly and sinks downslope into the valley floor. On sunny days, an opposite flow 

15 develops as the air near the surface heats and rises. 

16 

17 This flow upslope is generally weaker than the downslope flow and is often masked by the 

18 channeled prevailing westerlies. 

19 

20 

21 

 

2

 Drainage winds, also sometimes called katabatic winds or fall winds, are winds that carry high-density 

air masses down the slope of a mountain from higher elevations. The air masses involved are 

generally cold with low relative humidity and can greatly influence local air circulation patterns. 
 3-22 

Figure 3-11 presents an annual wind rose3 1 for MFC based on 

2 data for 2004 to 2008. This wind rose clearly shows the 

3 channeling effect of local topography with winds predominately 

4 from the southwest and northeast. 

5 

6 Table 3-6 presents average monthly and annual wind speeds 

7 for ID46W and MFC. The ID46W data were taken at 6 meters 

8 (20 feet) above the ground, and the MFC data were taken at 

9 10 meters (33 feet) above the ground. Since wind speed 

10 changes with height, extensive direct comparisons between 

11 monitoring stations are problematic. Average wind speeds are 

12 generally highest in the spring and lowest in winter. The KET 

13 site which has the highest monitor also has the highest wind 

14 speeds for each month and for the year. Table 3-7 shows the 

15 peak winds and the concurrent direction by month. At both 

16 sites, March is the month with the highest hourly wind speeds 

17 that range between 41 and 51 miles per hour (18 and 

18 23 meters per second). The highest hourly winds blow from 

19 the southwest. 

20 

21 Atmospheric Stability 

22 

23 Atmospheric stability plays an important role in dispersing 

24 atmospheric emissions. Vertical motions and pollution 

25 dispersion are enhanced in unstable atmospheres and 

26 suppressed in stable atmospheres. Stability is usually 

27 classified by the Pasquill-Gifford stability classes ranging from 

28 A though G, which depend on solar insolation, wind speed, and cloud cover. 

29 

30 A-stability (most unstable) occurs in low winds with high incoming levels of solar radiation 

31 typically during the daytime. E-stability (slightly stable) and F-stability (moderately stable) 

32 conditions arise on clear nights with little wind. G-stability (extremely stable) generally occurs 

33 infrequently with very light winds and clear skies and is often included with F-stability. 

34 D-stability (neutral) conditions occur with higher wind speeds and/or greater cloud cover 

35 during both day and night. 

36 

37 Table 3-8 shows the frequency of unstable, neutral, and stable conditions for the station nearest 

38 the proposed site (Doty et al., 1976). The frequency data are presented as ranges rather than 

39 as point estimates. The best dispersion (unstable conditions) occurs 16–25 percent of the time, 

40 and poor dispersion (stable conditions) occurs 26–35 percent of the time. 

41 

 

3

 A wind rose summarizes wind speed and direction graphically as a circle displaying series of radial 

bars pointing in different directions. The direction of a bar shows the direction from which the wind 

blows. Each bar is divided into segments. Each segment represents wind speeds in a given range of 

speeds; for example, 6–8 meters per second. The length of a given segment represents the 

percentage of the summarized hours that winds blew from the indicated direction with a speed in the 

given range. 

Table 3-5 Relative 

Humidity at ID46W 

Montha Average Relative 

Humidity (%) 

January 68 

February 70 

March 58 

April 44 

May 46 

June 36 

July 30 

August 31 

September 38 

October 48 

November 60 

December 68 

Annual 50 

a

 Based on 1956–1961. 

Source: Clawson et al., 1989. 
 3-23 

1 

2 Figure 3-11 Wind Rose for MFC (data from Hukari, 2009) 

3 

4 Inversions

5 

6 Normally, the temperature in the atmosphere decreases with altitude. A temperature inversion 

7 occurs when there is an increase in temperature of the air mass with increasing elevation above 

8 the ground (see Atmospheric Stability text box). Inversions limit vertical dispersion, causing 

9 pollutants to be trapped close to the ground. The length of time an inversion lasts (its 

10 persistence) is important for determining its impact on dispersion, and thus the ambient air 

11 quality in the area impacted by the inversion. 

12 

13 
 3-24 

1 Table 3-9 summarizes inversion persistence for the MFC 

2 site for 1953 to 1960. The longest inversion for the 8-year 

3 period lasted 66 hours, and every month had at least one 

4 inversion lasting longer than 13 hours 

5 (Clawson et al., 1989). 

6 

7 3.5.2.4 Severe Weather Conditions 

8 

9 The National Climatic Data Center (NCDC ) storm event 

10 database tabulates storm events by county (NCDC, 2009b). 

11 Table 3-10 presents data from this database on various 

12 storm events in the four-county region comprised of 

13 Bonneville, Bingham, Butte, and Jefferson Counties. The 

14 proposed EREF property is entirely within Bonneville 

15 County but lies at the approximate centroid of these four 

16 counties. The following paragraphs discuss the most 

17 frequent storm events and identify additional classes of 

18 events documented in INL data (Clawson et al., 1989). 

19 There were no droughts, dust storms, hurricanes, tropical 

20 storms, waterspouts, or temperature-extreme events 

21 recorded in the NCDC data. 

22 

23 Thunderstorms and High Winds

24 

25 NCDC (2009b) lists 236 thunderstorms and high wind days, 

26 or about 4.0 thunderstorms and high wind days per year, as 

27 having occurred during the period January 1, 1950, through 

28 December 31, 2008, in the four-county region. There may 

29 be several thunderstorms during a thunderstorm day. 

30 Storms can occur throughout the year but are most 

31 prevalent in the March to October period. Strong winds, hail, and tornadoes can accompany 

32 severe storms, but thunderstorms tend to be less severe than those east of the Rocky 

33 Mountains, as the associated precipitation often evaporates before reaching the ground (a 

34 meteorological phenomenon known as virga). Winds greater than 94 kilometers per hour 

35 (58 miles per hour) occurred on 147 of the days. Hail accompanied thunderstorms on 8 days. 

36 

37 Tornadoes

38 

39 NCDC (2009b) lists 40 tornadoes during the period in the four-county region, giving an annual 

incidence of 0.68. One F2 tornado4 40 was sighted during the period on April 7, 1978. It caused 

 

4

 The Fujita six-point scale (F0 to F5) is used to rate the intensity of a tornado based on the damage it 

inflicts to structures and vegetation from the lowest intensity, F0, to the highest, F5. Fujitia scale 

categories are based on estimated (not measured) sustained wind speeds compared against 

observed structural damage. The enhanced Fujitia scale replaced the original Fujita scale in February 

2007. The enhanced Fujita scale still uses six categories of tornado intensity (EF0 to EF5) but defines 

those categories differently. Overall, most tornadoes (around 77 percent) in the United States are EF0 

or EF1 and about 95 percent are below EF3 in intensity. Approximately 0.1 percent of all tornadoes 

each EF5 status with sustained winds in excess of 200 mph (NOAA, 2008). For additional information 

about the Fujitia scales, see the NOAA Web site at http://www.spc.noaa.gov/efscale. 

Table 3-6 Average Monthly 

and Annual Wind Speeds near 

the Proposed EREF Site 

Wind Speed 

[mi/hr (m/sec)]

Month ID46Wa MFCb

January 5.6 (2.5) 7.2 (3.2)

February 6.9 (3.1) 7.3 (3.2)

March 8.7 (3.9) 9.6 (4.3)

April 9.3 (4.2) 10.9 (4.9)

May 9.3 (4.2) 10.7 (4.8)

June 8.9 (4.0) 10.7 (4.8)

July 8.0 (3.6) 9.8 (4.4)

August 7.7 (3.4) 9.9 (4.4)

September 7.2 (3.2) 9.0 (4.0)

October 6.8 (3.0) 8.5 (3.8)

November 6.4 (2.9) 8.6 (3.9)

December 5.2 (2.3) 8.4 (3.8)

Annual 7.5 (3.4) 9.1 (4.1)

a

 6-meter (20-foot) level for April 1950 

to October 1964. 

b

 10 meters (33 feet) for 2004 to 2008. 

Source: ID46W: Clawson et al., 1989; 

MFC: Hukari, 2009. 
 3-25 

Table 3-7 Highest Hourly Wind Speed and Direction near the 

Proposed EREF Site 

 ID46Wa MFCb

Month Speed 

[mi/hr(m/sec)] Direction Speed [mi/hr(m/sec)] Direction 

January 48 (21) WSW 37 (17) SSW/NNEc 

February 36 (16) SW 32 (14) NNE 

March 51 (23) WSW 41 (18) SW 

April 39 (17) WSW 11 (17) SW 

May 41 (18) SW 34 (15) SW 

June 36 (16) SW 35 (16) SW 

July 35 (16) WSW 38 (17) SW 

August 40 (18) WSW 36 (16) SW 

September 42 (19) WSW 30 (13) SSW 

October 44 (20) WSW 33 (15) SSW 

November 40 (18) WSW 35 (16) SW 

December 43 (19) SW 39 (17) SSW 

Annual 51 (23) WSW 41 (18) SW 

a 6-meter (20-foot) level for April 1950 to October 1964. 

b

 10 meters (33 feet) for 2004 to 2008. 

c

 Almost equal number of hours in both directions. 

Source: ID46W: Clawson et al., 1989; MFC: Hukari, 2009. 

1 

2 $2.5 million in damage and one injury. Twenty of the tornadoes 

3 were F1 in strength; the remainder were F0. 

4 

5 In addition to tornadoes, 12 funnel clouds, violent atmospheric 

6 vortices that do not reach the ground, were sighted during the 

7 period in the four-county region. 

8 

9 Airborne Dust and Sand

10 

11 NCDC (2009b) lists no dust storms during the period in the 

12 four-county region. However, since the proposed EREF site is in 

13 a semiarid area, blowing and drifting dust could be a nuisance 

14 when winds are strong. Vehicles and construction equipment could also contribute to airborne 

15 dust. 

16 

Table 3-8 Stability Class 

Distribution near the 

Proposed Site 

Stability Frequency (%) 

Unstable 16–25 

Neutral 56–65 

Stable 26–35 

Source: Doty et al., 1976. 
 3-26 

Table 3-9 Inversion Persistence at MFCa

Month 

Average 

Hours 

per Day 

Max Hours 

per Day 

Longest 

Duration (hr) 

January 17.0 24 46 

February 15.7 23 24 

March 13.5 18 20 

April 11.8 14 14 

May 10.8 15 13 

June 10.2 13 15 

July 10.7 15 15 

August 11.7 14 14 

September 12.8 15 18 

October 14.3 17 17 

November 15.1 21 21 

December 16.8 24 66 

a

 Based on January 1953 to December 1960. 

Source: Clawson et al., 1989. 

1 

Table 3-10 Storm Events in the Vicinity of the Proposed EREF Site 

 Type and Number of Storm Eventa,b 

County 

Thunderstorms 

and High 

Winds 

Tornados Precipitationc 

Snow 

and 

Iced 

Lightning Funnel 

Cloud Flood Hail Fog

Bonneville 48 (5) 5 (4) 6 4 4 4 3 22 1 

Bingham 87 (20) 15 (8) 4 0 5 5 5 28 1 

Butte 52 (1) 7 (2) 0 0 0 3 1 23 0 

Jefferson 49 (3) 13 (9) 0 0 0 0 0 19 0 

Total 236 (29) 40 (23) 10 4 9 12 9 92 2 

a

 Period of Record: January 1, 1950, to May 31, 2009. 

b

 Numbers in parentheses are number of events associated with property damage. 

c

 All events were heavy rains. 

d

 All events were snow. 

Source: NCDC, 2009b. 

2 

3 
 3-27 

1 Dust Devils

2 

3 Dust devils are small rotating updrafts over hot land surfaces. Dust devils are common in the 

4 summer at the proposed EREF site when intense solar heating of the ground makes dust devil 

5 formation possible. Because of their relatively weak wind speeds and short duration, they rarely 

6 damage people or property (Clawson et al., 1989). 

7 

8 Blowing Snow

9 

10 Blowing snow occurs when snow is picked up from the ground and entrained in the air by high 

11 winds. Blowing snow can reduce visibility and accumulate into drifts on the downwind side of 

12 buildings and other obstacles. The flat terrain around the proposed EREF is not conducive to 

13 the formation of snowdrifts. However, at INL to the immediate west, drifts may occasionally 

14 render parking lots and roads impassable and cause traffic to be rerouted 

15 (Clawson et al., 1989). 

16 

17 Floods

18 

19 Of the nine listed flood events listed in NCDC (2009b), one was an urban event, one was a 

20 small stream event, three were combined urban/small stream events, and four were flash flood 

21 events. 

22 

23 Lightning

24 

25 Lightning strikes can cause injury, death, and property damage. Of the nine events listed in 

26 NCDC (2009b) for the four-county region, none caused injury or death and five resulted in 

27 property damage. NOAA (2009) gives a lightning strike density for this area of 0.1 to 1 per 

28 square kilometer per year, a value at the lower end of the strike density range. The analysis 

29 presented in AES (2010) uses a more conservative density of one flash per square kilometer 

30 per year to estimate a lightning strike frequency of 0.75 flashes per square kilometer per year 

31 for the proposed EREF industrial complex (including the Cylinder Storage Pad). 

32 

33 3.5.2.5 Mixing Heights 

34 

35 The mixing height is defined as the height above the surface through which relatively vigorous 

36 vertical mixing occurs, primarily through the action of atmospheric turbulence. When the mixing 

37 height is low (i.e., very little vertical motion), ground-level pollutant concentrations will be 

38 relatively high because the pollutants are prevented from dispersing upward. Mixing heights 

39 commonly go through large diurnal variations due to solar heating and surface cooling. Mixing 

40 heights are generally lowest late at night or early in the morning and highest during mid to late 

41 afternoon. Afternoon mixing heights display a large seasonal variation, and mixing heights in 

42 summer are typically higher than those in winter. 

43 

44 Table 3-11 presents seasonal and annual mixing heights estimated at INL 

45 (Clawson et al., 1989). The mixing height is greatest on summer afternoons and least on 

46 summer mornings. The average annual mixing height is 370 meters (1210 feet) in the morning 

47 and 2090 meters (6860 feet) in the summer. 

48 

49 
 3-28 

1 3.5.3 Air Quality 

2 

3 There are several U.S. Environmental Protection Agency 

4 (EPA) programs authorized by the Clean Air Act and its 

5 amendments that define the regulatory environment for air 

6 emission sources at the proposed EREF property. The 

7 Idaho Department of Environmental Quality (IDEQ) has 

8 authority to administer these programs in the State. The 

9 major programs are summarized below. 

10 

11 EPA’s National Ambient Air Quality Standards (NAAQS) 

12 set maximum levels of air pollutants in the ambient air 

13 deemed to provide protection for human health and 

14 welfare. Areas where these standards are not being met 

15 are designated as nonattainment areas. When a 

16 nonattainment area attains the standard, it becomes a 

17 maintenance area. States must develop Federally 

18 approved plans specifying how the NAAQS will be attained 

19 and maintained. NAAQS are shown in Table 3-12. 

20 

21 Sulfur dioxide (SO2) is a gas emitted largely by stationary internal or external combustion 

22 sources burning fossil fuels. Particulate matter (PM) includes solid matter and liquid droplets in 

23 the atmosphere. Particles with aerodynamic diameters below 10 micrometers (1 micrometer is 

24 about 0.000039 inch) constitute PM10. Smaller particles with diameters below 2.5 micrometers 

25 constitute PM2.5. Carbon monoxide (CO) is a gas produced primarily by the incomplete 

26 combustion of carbon in fuels; vehicles and stationary internal combustion engines emit most of 

27 the carbon monoxide. Nitrogen dioxide (NO2) is a gas formed primarily when using fuels 

28 containing nitrogen, or when the temperatures of combustion are high enough to thermally 

29 degrade the otherwise inert nitrogen molecules in the stream of ambient air used to support the 

30 combustion. In the presence of sunlight, NO2 reacts with volatile organic compounds (VOCs) in 

31 the atmosphere to produce ozone (O3). Lead is a metal that can be emitted by some stationary 

combustion sources (as the stable oxide).5 32 

33 

34 In areas with pollutant levels below the NAAQS, the Prevention of Significant Deterioration 

35 (PSD) Program (40 CFR 52.21) places limits on the total allowable increases in ambient 

36 pollutant levels above established baseline levels for SO2, NO2, and PM10. This prohibits 

37 “polluting up to the limits” specified in the NAAQS for these pollutants. Under these regulations, 

38 the allowable increases are smallest in Class I areas (e.g., national parks and wilderness areas) 

39 where the air quality value of visibility must be preserved. The rest of the country is subject to 

40 larger Class II increments. 

41 

 

5

 Until 1976, a major source of lead in the atmosphere resulted from the combustion of leaded gasoline. 

Tetraethyl lead was used as an anti-knock and octane-boosting gasoline additive between the years 

1930 and 1976. 

Table 3-11 Estimated Seasonal 

and Annual Mixing Heights in 

the Vicinity of the Proposed 

EREF Site 

Estimated EREF Average 

Mixing Heights [m (ft)] 

Season Morning Afternoon 

Spring 480 (1600) 2330 (7640) 

Summer 260 (850) 2900 (9510) 

Autumn 330 (1100) 1550 (5100) 

Winter 400 (1300) 730 (2400) 

Annual 370 (1210) 2090 (6860) 

Source: Clawson et al., 1989.
 3-29 

Table 3-12 National Ambient Air Quality Standardsa

Pollutantb Averaging Time Standard Value Standard 

Typec

SO2 3 h 0.5 ppm (1300 g/m3) S 

 24 h 0.14 ppm (365 g/m3) P 

 Annual 

arithmetic mean 

0.030 ppm (80 g/m3) P 

NO2 Annual 

arithmetic mean 

0.053 ppm (100 g/m3) P, S 

CO 1 h 35 ppm (40 mg/m3) P 

 8 h 9 ppm (10 mg/m3) P 

O3 1 h 0.12 ppmd (235 g/m3) P, S 

 8 h 0.075 ppm (157 g/m3) P, S 

PM10 24 h 150 g/m3 P, S 

PM2.5 24 h 35 g/m3 e P, S 

 Annual 15.0 g/m3 P, S 

Lead Calendar quarterf 1.5 g/m3 P, S 

a

 Refer to 40 CFR Part 50 for detailed information on attainment determination 

and reference method for monitoring (refer to http://www.gpoaccess.gov/cfr/ 

index.html). 

b

 CO = carbon monoxide; NO2 = nitrogen dioxide; O3 = ozone; PM2.5 = particulate 

matter  2.5 μm; PM10 = particulate matter 10 μm; and SO2 = sulfur dioxide. c

 P = primary standards, which set limits to protect public health; S = secondary 

standards, which set limits to protect welfare and quality of life. 

d

 On June 15, 2005, the 1-hour O3 standard was revoked for all areas except the 

8-hour O3 nonattainment Early Action Compact areas (those do not yet have an 

effective date for their 8-hour designations). The 1-hour standard will be revoked 

for these areas 1 year after the effective date of their designation as attainment or 

nonattainment for the 8-hour O3 standard. e

 Effective December 17, 2006, EPA revoked the annual PM10 standard of the 

current 50 μg/m3

 and revised the 24-hour PM2.5 standard from 65 μg/m3 to 

35 μg/m3

. f

 On October 15, 2008, the EPA revised the lead standard from a calendar-quarter 

average of 1.5 μg/m3

 to a rolling 3-month average of 0.15 μg/m3. 

Source: 40 CFR Part 50; 40 CFR 52.21 (for PSD). 

1 

2 
 3-30 

1 Idaho has promulgated State Ambient Air Quality Standards (SAAQS) under analogous State 

authority (see Idaho Administrative Procedures Act [IDAPA] 58.01.01.577).6 2 Standards for SO2, 

3 NO2, CO, 1-hour O3, PM10, and lead are substantively identical to the NAAQS. However, Idaho 

4 has not established standards for 8-hour O3 or PM2.5. The State has also adopted standards for 

fluorides.7 5 EPA has granted IDEQ authority to implement the Federal program. 

6 

7 Section 112 of the Clean Air Act specifies a list of 188 air toxics. EPA has issued National 

8 Emission Standards for Hazardous Air Pollutants (NESHAP) requiring control of sources of 

9 these pollutants. These standards are based on an emission control technology, rather than 

10 being derived from a health-based approach; but an assessment of the health risk remaining 

11 after the emission controls are in place is still required. 

12 

13 3.5.3.1 Regional Air Quality 

14 

15 IDEQ (2007a) summarizes Idaho ambient air monitoring data through 2007: most areas of the 

16 State are well within the NAAQS. Isolated areas are nonattainment for PM10 and are areas of 

17 concern for PM2.5. One area in the far western part of the State is a maintenance area for CO 

18 and PM10. The locations of the above noted areas, as well as the Class I areas, are shown on 

19 Figure 3-12. 

20 

21 Ambient air quality data for Bonneville County for calendar year 2008 include the following: CO, 

22 35 ppm (1-hour average), 9 ppm (8-hour average); NO2, 0.053 ppm (annual mean). 

23 

24 3.5.3.2 Criteria Pollutant Emissions 

25 

26 Table 3-13 presents 2005 emissions of criteria pollutants from the four counties including and 

27 surrounding the proposed EREF site (Bingham, Bonneville, Butte, and Jefferson) (IDEQ, 2009). 

28 Emissions of all pollutants are dominated by nonpoint and mobile sources. There were 

29 11 facilities in the point emissions inventory in Bingham, Butte, and Jefferson Counties. (These 

30 are traditional stationary sources rather than mobile or area source like wind-blown dust.) Eight 

31 were associated with activities at INL located in Bingham, Butte, and Jefferson Counties, and 

32 the other three were food processing facilities. 

33 

34 Table 3-14 presents 2005 emissions of air toxics in excess 9.1 metric tons per year 

35 (i.e., >10 tons per year) from the four counties surrounding the proposed EREF. (Single 

36 sources emitting 10 tons per year or more of an air toxic are defined as major and are subject to 

37 more stringent emission limits than smaller sources.) Other inventoried air toxics were emitted 

38 in lesser amounts. 

39 

40 Idaho does not require sources to report emissions of greenhouse gases. In response to the 

41 Consolidated Appropriations Action of 2008 (Public Law 110-161), EPA promulgated final 

42 mandatory greenhouse gas reporting regulations on October 30, 2009, that became effective in 

43 December 2009 (EPA, 2009a). The rules are applicable to major sources of CO2, defined as 

 

6

 Idaho regulations, “Rules for the Control of Air Pollution in Idaho,” can be accessed at http://www.deq. 

idaho.gov/air/data_reports/monitoring/overview.cfm. 

7

 There is no Federal standard for fluorides. Idaho SAAQS for fluoride include 80 ppm monthly, 60 ppm 

bimonthly, and 40 ppm annual arithmetic mean. See IDAPA 58.01.01.577.06. 
 3-31 

1 

2 Figure 3-12 Idaho Air Quality Planning Areas (IDEQ, 2007b; Richards, 2009a,b) 

3 

Table 3-13 Emissions from the Four Counties 

Closest to the Proposed EREF Sitea

2005 Annual Emissions [103 metric tons/yr (103 tons/yr)] 

PM10 PM2.5 SO2 NOX CO VOC 

69 (76) 0.58 (0.64) 1.3 (1.4) 7.1 (7.8) 65 (72) 12 (13) 

a

 Bingham, Bonneville, Butte, and Jefferson Counties. 

Source: IDEQ, 2009. 

4 
 3-32 

Table 3-14 Air Toxics Emissions from the Four 

Counties Closest to the Proposed EREF Sitea,b

Pollutant 2005 Annual Emissions 

[metric tons/yr (tons/yr)] 

Formaldehyde 220 (240) 

Methanol 56 (62) 

Benzene 200 (220) 

Methyl bromide 44 (49) 

Chloromethane 1000 (1100) 

Hydrogen cyanide 12 (14) 

Acetaldehyde 110 (120) 

Methyl ethyl ketone 17 (18) 

Trichloroethylene 210 (231) 

2,4-D 25 (28) 

Styrene 14 (15) 

1,3-Butadiene 38 (42) 

Acrolein 49 (54) 

Methyl isobutyl ketone 40 (44) 

Toluene 170 (190) 

Chlorobenzene 10 (11) 

Hexane 53 (58) 

Tetrachloroethylene 53 (58) 

Carbonyl sulfide 27 (30) 

1,3-Dichloropropene 160 (180) 

Xylene (mixed isomers) 57 (63) 

Trifluralin 9.5 (10) 

Hydrochloric acid 11 (12) 

Hydrofluoric acid 28 (31) 

Chlorine 11 (12) 

a

 Bingham, Bonneville, Butte, and Jefferson Counties. 

b

 Only pollutants with total emissions above 9 metric tons/yr 

(10 tons/yr) are listed. 

Source: IDEQ, 2009. 

1 

2 
 3-33 

1 those emitting more than 25,000 tons per year, and require annual reporting of greenhouse gas 

2 emissions directly to EPA. 

3 

4 3.5.3.3 Nonattainment and Maintenance Areas 

5 

6 Information in the section was compiled from IDEQ (2007a,b) and Richards (2009a,b). The 

7 areas discussed are shown in Figure 3-12. 

8 

9 The proposed EREF site is not located in, or in close proximity to, a nonattainment or 

10 maintenance area for any NAAQS. 

11 

12 There are no nonattainment or maintenance areas for lead, sulfur dioxide, or nitrogen dioxide. 

13 

14 Idaho is in attainment for CO, while a portion of Ada County remains a maintenance area. 

15 

16 The areas of Sandpoint and Pinehurst in far northern Idaho present PM issues. Idaho will 

17 submit a maintenance plan to EPA for Sandhurst this year. Pinehurst remains nonattainment 

18 for PM10. A portion of Ada County and Bannock County (the Portneuf Valley) are maintenance 

19 areas for PM10. Portneuf Valley, the closest nonattainment or maintenance area to the 

20 proposed EREF site, is located about 56 kilometers (35 miles) south. The Fort Hall area in 

21 Power County next to the Portneuf Valley is also designated as nonattainment for PM10. 

22 

23 All of Idaho was designated attainment/unclassifiable for PM2.5 in 2007. The State will probably 

24 recommend that EPA designate Pinehurst County and a portion of Franklin County as 

25 nonattainment for PM2.5 (IDEQ, undated). 

26 

27 There are no nonattainment or maintenance areas for ozone in Idaho. However, Treasure 

28 Valley is close to the new standard and may go into nonattainment when the 2008 monitoring 

29 data are analyzed. 

30 

31 The U.S. Department of Energy (DOE) conducts ambient air monitoring for PM10 and NO2 at 

32 various locations within and surrounding its INL, which is located proximate to the proposed 

EREF site (DOE, 2005).8 33 PM10 monitoring is performed at the INL site boundary and in the 

34 surrounding communities of Rexburg, Blackfoot, and Atomic City. In 2003, 60 samples 

35 collected at Rexburg ranged from 0.42 to 153.9 micrograms per cubic meter, 60 samples 

36 collected at Blackfoot ranged from 1.3 to 173.7 micrograms per cubic meter, and 59 samples 

37 collected at Atomic City ranged from 0.7 to 73.0 micrograms per cubic meter. NO2 monitoring is 

38 performed at two locations on INL. In 2003, both locations showed NO2 levels well below the 

39 ambient standard of 0.053 ppm (53 parts per billion [ppb]). Quarterly mean concentrations at 

40 the first location ranged from 2.9 to 3.9 ppb with an annual mean of 3.5 ppb. Quarterly mean 

41 values at the second monitoring station ranged from 7.4 to 10.7 ppb with a mean annual 

42 concentration of 9.1 ppb (based on two quarters of data). 

43 

 

8

 The INL monitoring sites are used to measure INL’s impact on its local environment and to 

demonstrate INL’s compliance with applicable regulations, DOE orders, standards, and permit 

conditions. They are not part of the official monitoring network maintained by the State of Idaho with 

which conformance to NAAQS is demonstrated and ambient air quality status is established. 
 3-34 

In 2006, the last year for which full yearly data are available,9 1 PM10 24-hour samples collected 

2 at the above three monitoring stations showed the following concentration ranges: Rexburg, 

3 0.0–44.8 micrograms per cubic meter; Blackfoot, 0.3–50.1 micrograms per cubic meter; and 

4 Atomic City, 0.0–66.1 micrograms per cubic meter (DOE, 2007). These data indicate that the 

5 counties surrounding the proposed EREF site were in attainment with all NAAQS over the 

6 period the monitoring was performed. 

7 

8 3.5.3.4 Prevention of Significant Deterioration (PSD) 

9 

10 Figure 3-12 shows the Class I areas in and around Idaho. These areas are of special concern 

11 because of the small air quality increments that apply in them and because sources impacting 

12 them may need to consider visibility impacts and “air quality-related values.” The following are 

13 the closest Class I areas to the proposed EREF site (NPS, 2007): 

14 

15 • Craters of the Moon National Monument and Preserve, about 75 kilometers (47 miles) to the 

16 west; 

17 

18 • Red Rock Lakes National Wildlife Refuge, about 95 kilometers (59 miles) to the north19 northeast; 

20 

21 • Yellowstone National Park, about 105 kilometers (65 miles) to the northeast; and 

22 

23 • Grand Teton National Park, about 105 kilometers (65 miles) to the east. 

24 

25 All areas are Class II unless they are one of the listed Class I areas; no areas have requested 

26 redesignation to Class III. The proposed EREF site is not one of these Class I areas and 

27 retains the PSD Class II designation. 

28 

29 3.5.3.5 Conformity 

30 

31 Actions involving major Federal involvement may need to demonstrate that they conform to the 

32 State’s implementation plan. Conformity applies only if the action will take place in a 

33 nonattainment or maintenance area. Since the proposed EREF site is not in such an area, 

34 conformity would not apply. 

35 

36 3.6 Geology, Minerals, and Soils 

37 

38 This section describes the regional and local geology and identifies the characteristics of the 

39 soil, mineral, and energy resources at the proposed EREF site. While the NRC staff’s process 

40 for reviewing the license application includes an examination of the applicant’s seismic and 

41 volcanic hazards assessment and the structural design of the proposed EREF, the discussion of 

42 geology in this section is not intended to support a detailed safety analysis. The NRC staff 

43 documented its analysis of seismic and volcanic hazards in its Safety Evaluation Report (SER) 

44 (NRC, 2010). 

45 

 

9

 PM10 monitoring was discontinued at these three locations in March 2007 because the results were no 

longer required to demonstrate INL compliance. 
 3-35 

1 Figure 3-13 shows a geologic time scale to depict when different geologic units formed, as 

2 described in the following sections. 

3 

4 3.6.1 Regional Geology 

5 

6 The proposed EREF site is located on the East Snake River Plain (ESRP), within the ESRP 

7 physiographic province (Figure 3-14). The ESRP is an east-northeast trending 600-kilometer 

8 (373-mile)-long and 100-kilometer (62-mile)-wide topographic depression extending from Twin 

9 Falls to Ashton, Idaho. The predominant physiographic features of the ESRP province are 

10 Quaternary-age volcanic landforms: basaltic lava flows, shield volcanoes, and rhyolitic domes. 

11 These landforms, along with other eruptive features (e.g., dikes and pyroclastic domes), are 

12 concentrated along a northeast-trending axial volcanic zone. That zone constitutes the 

13 topographically high central axis of the ESRP. The ESRP is bounded on the north and south by 

14 the north-to-northwest trending mountains of the northern Basin and Range physiographic 

15 province. The mountain peaks, reaching heights of 3660 meters (12,000 feet), are separated by 

16 basins filled with terrestrial sediments and volcanic rocks. The basins are 5 to 20 kilometers 

17 (3 to 12 miles) wide and grade onto the ESRP. The Yellowstone Plateau lies to the northeast of 

18 the ESRP (Hughes et al., 1999; DOE, 2005). 

19 

20 The upper 1 to 2 kilometers (0.62 to 1.2 miles) of the ESRP is composed of numerous basaltic 

21 lava flows with intercalated sediment. Several volcanic rift zones, each with a northwestern 

22 trend, cut across the ESRP and have been identified as the source areas for these lava flows 

23 (Figure 3-15). The volcanic rift zone orientations are the result of basalt dikes that intruded 

24 perpendicular to the northeast-southwest direction of crustal extension associated with the 

25 Basin and Range province, located to the north and south of the ESRP. Widespread basaltic 

26 volcanic activity occurred intermittently on the ESRP throughout the Pleistocene and Holocene. 

27 The most recent episode of basaltic volcanism occurred about 2000 years ago in the Great Rift 

28 volcanic rift zone to the west. Volcanism on the ESRP is a result of the movement of the North 

29 American tectonic plate southwestwardly over the Yellowstone mantle plume or hotspot 

30 (Hughes et al., 1999; DOE, 2005; Anderson et al., 1996; Smith, 2004). 

31 

32 Figure 3-16 shows the stratigraphy of the ESRP in the vicinity of the proposed EREF site. The 

33 ESRP is underlain by Quaternary and Tertiary age basaltic lava interbedded with poorly 

34 consolidated sedimentary materials to depths of 2 kilometers (1.2 miles). The thickness of most 

35 individual basalt flows in the upper part of the section ranges from 5 to 25 meters (16 to 82 feet), 

36 and their lengths extend up to 48 kilometers (30 miles). Sediments consist of materials 

37 deposited by streams (silts, sands, and gravels), lakes (clays, silts, and sands), and wind (silts 

38 and sands) that accumulated on the ESRP between volcanic events. During long periods of 

39 inactivity, sediments accumulated to thicknesses greater than 60 meters (197 feet). These 

40 interbedded sequences are collectively known as the Snake River Group. Underlying the 

41 Snake River Group is a thick sequence of Tertiary rhyolitic (silicic volcanic) rocks that erupted 

42 when the area was over the Yellowstone hotspot, more than 4 million years ago. The last 4 

43 million years have been a period of crustal subsidence within the ESRP as it isostatically adjusts 

44 to the mass of dense mantle-derived basalt (gabbro) that now comprises the middle crust. 

45 Because temperatures in the upper mantle below the ESRP remain relatively high, partial 

46 melting of mantle material continues to produce basaltic magmas that rise to the surface and 

47 erupt as lavas that fill the subsiding basin (Hughes et al., 1999; DOE, 2005; 

48 Ackerman et al., 2006; Smith, 2004). 
 3-36 

1 

2 Figure 3-13 Geologic Time Scale (USGS, 2009a) 

3 
 3-37 

1 

2 Figure 3-14 Regional Physiography (AES, 2010) 

3 

4 During the late Pleistocene to late Holocene (recent), surficial processes such as glacial 

5 outburst flooding, range fires, and eolian erosion and deposition have contributed significantly to 

6 the appearance of the ESRP landscape. Extensive eolian deposition has produced thick 

7 blankets of loess across the ESRP and the areas to the southeast. These processes continue 

8 to modify the landscape today. 

9 
 3-38 

1 

2 Figure 3-15 Lava Fields and Volcanic Rift Zones of the ESRP (modified from 

3 Payne, 2006; Quaternary fault and earthquake data from USGS and IGS, 2006) 

4 

5 3.6.1.1 Seismic Setting, Earthquakes, and Volcanic Activity 

6 

7 Seismic Setting

8 

9 The proposed EREF site is situated on the axial volcanic zone, a northeast-to-southwest 

10 trending volcanic ridge that stretches across the middle of the ESRP (Figure 3-15). The ESRP 

11 is thought to mark the track of the Yellowstone hotspot, which is currently located beneath 

12 Yellowstone National Park in Wyoming. The hotspot was centered near the proposed EREF 

13 site about 4 to 10 million years ago (Smith, 2004). 

14 

15 Earthquakes

16 

17 Most earthquakes with the potential to affect the proposed EREF occur along the normal faults 

18 in the Basin and Range province north of the ESRP (Figure 3-15). These faults are capable of 

19 magnitudes of 7 or greater on the Richter scale and have recurrence intervals on the order of 

20 thousands or tens of thousands of years. Earthquakes within the Basin and Range province 

21 indicate extension in a predominantly northeast-southwest direction. Crustal extension began in 

22 this area in the Middle Miocene, about 16 million years ago. The ESRP itself is less seismically 

23 active, although very low level seismic activity is common. Seismic history and geologic 

24 conditions indicate that earthquakes with a magnitude of more than 5.5 and the associated 
 3-39 

1 

2 Figure 3-16 General Stratigraphy of the ESRP (adapted from Ackerman et al., 2006) 

3 

4 
 3-40 

1 strong ground shaking and surface rupture would probably not occur within the ESRP; however, 

2 moderate to strong ground shaking from earthquakes in the Basin and Range province could be 

3 felt at the proposed EREF site (DOE, 1996; Hughes et al., 1999; Weston Geophysical 

4 Engineers, 2008). 

5 

6 Figure 3-17 shows the peak horizontal acceleration in the ESRP region as a percentage of the 

7 acceleration of gravity, g, which has a 10 percent probability of being exceeded over a 50-year 

8 period. The peak horizontal acceleration ranges from 0 g (insignificant ground-shaking) to 1 g 

9 (strong ground-shaking). The highest ground-shaking hazard in the region occurs to the north 

10 of the ESRP and along the Intermountain Seismic Belt to the west, with the highest probable 

11 peak acceleration (greater than 0.30, or 30 percent of g) occurring in western Wyoming. In the 

12 region of the proposed EREF property on the ESRP, the probable peak acceleration is low, in 

13 the range of 0.05 g to 0.07 g (equal to or less than 7 percent of g), because the region is 

underlain by hard rock and seismically active areas are at some distance away.10 14 

15 

16 A probabilistic seismic hazard study conducted by Weston Geophysical Engineers (2008) 

determined that the peak horizontal accelerations for annual probabilities of once in 1000 (10-3 17 ), 

10,000 (10-4), and 100,000 (10-5) years would be 0.063g, 0.15g, and 0.30g, respectively.11 18 

19 These estimates are in agreement with similar studies conducted at INL by DOE (1996) and 

20 Payne et al. (2000). Similar levels are now part of the seismic design criteria for new facilities at 

21 INL (Payne, 2008). Additional information on seismic hazards is provided in the SER (NRC, 

22 2010). 

23 

24 Volcanic Activity

25 

26 Early volcanism associated with the Yellowstone hotspot produced large-volume silicic 

27 eruptions that were followed by predominantly basaltic volcanism. Currently, basaltic volcanism 

28 occurs within the several northwest-trending volcanic rift zones and the axial volcanic zone 

29 (Figure 3-15). The most recent and closest volcanic eruption occurred at Craters of the Moon 

30 National Monument, 43.5 kilometers (27 miles) southwest of the proposed site, about 

31 2000 years ago (Payne, 2006). 

32 

33 Using the probabilistic approach of Hackett et al. (2002), a recent volcanic hazard analysis 

34 determined that the major volcanic hazard at the site of the proposed EREF is the inundation 

35 and burning of facilities by basaltic lava flows in the event of an eruption within the volcanic rift 

36 zones of the ESRP (Figure 3-15). Hazards associated with basalt flows are listed in Table 3-15. 

37 The mean annual probability of a basaltic eruption that could impact the proposed EREF is 

 

10 Seismic waves during an earthquake cause ground-shaking that radiates outward from the rupturing 

fault. Shaking intensity is mainly a function of an earthquake’s magnitude and the distance from the 

fault, but can be amplified by other factors, such as the softness of the ground (soft rocks and 

sediments versus hard rock) and the total thickness of sediments below the area. Shaking tends to be 

stronger in soft rocks and sediments and increases with increasing thickness of underlying sediments 

(Field et al., 2001). 

11 Peak horizontal acceleration is expressed as a percentage of gravity (g), a common value of 

acceleration equal to 9.8 m/s2

, the acceleration due to gravity at the earth’s surface. Peak horizontal 

acceleration values range from 0 (insignificant ground shaking) to 1.0 (very strong ground shaking). 
 3-41

1 

Figure 3-17 Peak Horizontal Acceleration (as a percent of g) near the ESRP (USGS, 2008a) 2 

3 
 3-42 

about 3.7  10-6 (with estimated upper and lower bounds ranging from 10-5 to 10-7 1 ). The 

2 proposed EREF site lies within a shallow topographic basin with an area of about 230 square 

3 kilometers (89 square miles). The basin is larger than the median and mean areas of lava flows 

4 measured within the INL site (to the northwest), and it is estimated that 70 percent of lava flows 

5 erupted from a vent within the basin would reach the proposed EREF site. Eruptions along the 

6 axial volcanic zone, however, would likely inundate the entire topographic basin, including the 

7 proposed EREF site (AES, 2010). 

8 

9 Sources of more explosive silicic volcanism include: the potentially new or reactivated caldera 

10 volcanoes on the ESRP; the Yellowstone Plateau volcanic field, about 230 kilometers 

11 (143 miles) to the northeast; and ash-fall deposits from the volcanoes of the Cascade range, 

12 more than 700 kilometers (435 miles) west. The estimated recurrence of silicic volcanism within 

the volcanic axial zone is 4.5  10-6 13 per year. Hazards associated with silicic volcanism are 

14 considered to be less important than for basaltic volcanism in the area of the proposed EREF 

15 since the spatial distribution of Quaternary rhyolite flows in the area (e.g., at INL) generally 

16 impacts smaller areas than basalt flows. Pyroclastic flows and ash-fall deposits are also 

17 considered to pose no significant hazard in the area of the proposed EREF (AES, 2010). The 

18 annual probabilities calculated for the proposed EREF site are consistent with those made by 

19 Hackett et al. (2002) for facilities in the southwestern portion of INL. Additional information on 

20 volcanic hazards is provided in the SER (NRC, 2010). 

21 

22 3.6.1.2 Mineral and Energy Resources 

23 

24 AES has not found any abandoned drill holes or former or existing production wells to indicate 

25 petroleum was drilled for or produced within the site of the proposed EREF. The NRC staff 

26 verified during a site visit that there are no current mining operations at the proposed EREF site. 

27 According to information collected by the Idaho Geological Survey (IGS) and U.S. Geological 

28 Survey (USGS), the top nonfuel minerals in Idaho are, in descending order of value, 

29 molybdenum concentrates, construction sand and gravel, phosphate rock, silver, crushed stone, 

30 lead, and portland cement. These minerals accounted for more than 96 percent of the State’s 

31 total nonfuel mineral production in 2006 (USGS, 2008b). Figure 3-18 shows the potential 

32 mineral resources in Idaho. According to the USGS survey (USGS, 2008b), suitable mineral 

33 resources exist in Bonneville County for the extraction of construction sand and gravel, pumice 

34 and pumicite, and crushed stone for aggregate. The nearest quarrying operations for sand and 

35 gravel, pumice, and crushed stone are those at INL. 

36 

37 Idaho has limited petroleum resources; however, there is interest in the production potential of 

38 the Overthrust Belt in southeastern Idaho and the Tertiary basin sediments in the far western 

39 portion of the Snake River Plain. An oil and gas well was recently drilled on private land near 

40 Gray’s Lake in southeastern Idaho, about 100 kilometers (62 miles) from the proposed EREF 

41 site. Geothermal potential is high in Idaho. The first geothermal power plant, located at the Raft 

42 River site about 150 kilometers (93 miles) southwest of the proposed EREF site, began 

43 commercial operation in November 2007, with a 25-year, 13-megawatt full output purchase 

44 agreement with Idaho Power. Further exploration at Raft River is planned (Gillerman and 

45 Bennett, 2008). 

46 
 3-43 

Table 3-15 Hazards Associated with Basaltic Volcanism on the ESRP 

Phenomenon Relative 

Frequency 

Size or Area of 

Influence Hazard Level 

Lava flow Common 0.1 to 400 km2 (0.039 to 

154 mi2

) in area; up to 

32 km (20 mi) in length 

based on sizes of ESRP 

lava flows of the past 

400,000 years 

Significant hazard; typical 

basaltic phenomenon; 

lava from fissures or 

shield volcanoes may 

inundate large areas 

downslope of vents and 

burn structures in its path 

Ground deformation: 

fissuring, faulting, and 

uplift 

Common; 

associated with 

virtually all shallow 

magma intrusion 

and eruption 

Fissuring could affect 

areas of 10 km2 

(3.9 mi2 ); minor tilting 

and broad uplift in areas 

to 40 km2

 (15 mi2) 

Significant hazard due to 

shallow dike intrusion; 

“dry” intrusion may occur 

without lava flows, 

affecting smaller areas 

than for lava inundation 

Volcanic earthquakes Common; 

associated with 

magma intrusion 

before and during 

eruption 

Maximum Richter scale 

magnitude of 5.5, with 

most events less than 

3.0; ground vibration 

may affect facilities 

within 25 km (16 mi) 

Low to moderate hazard; 

swarms of shallow 

earthquakes (less than 

4-km [2.5-mi] focal depth) 

occur as dikes propagate 

underground 

Gas release (toxic and 

corrosive vapors) 

Common; 

associated with 

fissuring and lava 

eruption 

Restricted to near-vent 

areas; may affect areas 

of several square 

kilometers downwind 

Low hazard; local plume 

of corrosive vapor 

downwind from eruptive 

vent or fissure; cooled 

vapor may collect in local 

topographic depressions 

Tephra fall (volcanic ash 

and bombs) 

Common Restricted to near-vent 

areas; may affect areas 

of several square 

kilometers downwind 

Low hazard; basaltic 

eruptions are inherently 

nonexplosive and may 

form small tephra cones 

but little fine ash to be 

carried downwind 

Base surge (groundhugging blast of steam 

and tephra) 

Rare Effects limited to radius 

of several kilometers 

from vent; less than 

10 km2

 (3.9 mi2) 

Low hazard due to depth 

of water table (greater 

than 200 m [656 ft]); 

steam explosions due to 

interaction between 

ascending magma and 

shallow groundwater 

Pyroclastic flow (groundhugging flow of hot, 

pyroclastic material) 

Extremely rare Near vent; affected area 

less than 1 km2

(0.39 mi2

) 

Very low hazard; as per 

tephra fall but affecting 

even smaller areas 

Source: modified from Hackett et al., 2002.

1 

2 
 3-44 

1 

2 Figure 3-18 Idaho Mineral Resources (modified from USGS, 2008b) 

3 

4 3.6.2 Site Geology 

5 

6 The proposed EREF site is located in a shallow topographic depression within the axial volcanic 

7 zone between the Lava Ridge-Hells Half Acre and the Circular Butte-Kettle Butte rift zones 

8 (Figure 3-15). The surface is relatively flat and gently sloping, with small ridges and areas of 

9 rock outcrop. Elevations range from about 1556 meters (5105 feet) to about 1600 meters 

10 (5250 feet). 

11 

12 The axial volcanic zone is underlain by numerous basalt lava flows erupted from fissures and 

13 small shield volcanoes over the past 4 million years. Basaltic rock outcrops of the Quaternary 

14 age Snake River Group cover a portion of the proposed site (especially in the northwestern and 

15 southern parts) and occur as low irregular ridges, small areas of blocky rubble with thin soils, 

16 and erosional surfaces in intermittent stream drainages. The basalts are strongly vesicular and 

17 show a range of oxidation and secondary mineral formation; some show columnar jointing. 
 3-45 

1 Geologic mapping in the area suggests that the basalt flows at the proposed site originated from 

2 the volcanic vent at Kettle Butte (AES, 2010; Kuntz et al., 1994). 

3 

4 Rock cores drilled at the proposed site identify numerous basalt flows, ranging in thickness from 

5 less than 0.6 to 15 meters (less than 2 to 50 feet). Rock cores sampled across the proposed 

6 EREF site indicate the depth to bedrock (basalt) ranges from 0 (at outcrop locations) to 

7 6.6 meters (0 to 21.5 feet) (Figure 3-19). In one core (GW-1), thin, vesicular pahoehoe flows 

8 occur at depths of 95, 131, 152, 157, and 209 meters (310, 430, 500, 515, and 685 feet). The 

9 tops of these flows are generally characterized by the presence of black, fine-grained to glassy 

10 crusts a few centimeters thick, with stretched vesicles, pervasive matrix oxidation, and olivine 

11 phenocrysts. Within a few meters of the lava-flow tops is a highly vesicular zone with closely 

12 spaced, vertically oriented cooling fractures. In thicker flows, the fractured lava grades 

13 downward into finely vesicular and nonvesicular (massive) lava of the flow interior (AES, 2010). 

14 

15 3.6.3 Site Soils 

16 

17 Figure 3-20 presents a soil map of the proposed EREF site. Unconsolidated surficial material at 

18 the proposed site consists mainly of Pleistocene age loess deposits rather than soil developed 

19 in situ. The loess, composed of silt and sandy silt, is massive or faintly bedded and moderately 

20 to well-sorted. Small angular to subrounded basalt gravel is sparsely present (Scott, 1982). 

21 

22 The U.S. Department of Agriculture soil survey for Bonneville County categorizes most of the 

23 soils at the proposed EREF site as Pancheri silt loam, with slopes ranging from 0 to 8 percent. 

24 The Pancheri series consists of deep to very deep, well-drained soils that formed in loess25 covered lava plains where the mean annual precipitation is about 25 centimeters (10 inches). 

26 Other soils at the proposed site include the Pancheri- and Polatis-rock outcrop complexes, 

27 which are moderately deep, well-drained, silt loams occurring on steeper slopes (up to 

28 25 percent) of basalt outcrops. Basalt outcrops occur as low irregular ridges of blocky rubble 

29 that cover about 28 percent of the total area of the proposed EREF site and as erosional 

30 surfaces within intermittent stream drainages (NRCS, 2009). 

31 

32 Soils of the Pacheri silt loam (0 to 4 percent slope), which cover about 63 percent of the 

33 proposed EREF site, are classified as prime farmland (if irrigated) by the U.S. Natural 

34 Resources Conservation Service (NRCS) (NRCS, 2009). 

35 

36 3.6.4 Soil Radiological and Chemical Characteristics 

37 

38 3.6.4.1 Soil Radiological Characteristics 

39 

40 Ten surface soil samples were collected from various locations across the proposed EREF site 

41 as part of the initial characterization of soils (Figure 3-21). Samples were analyzed for uranium, 

42 thorium, and their daughter products. Potassium-40, a naturally occurring radionuclide, and 

43 cesium-137, produced by past weapons testing, were also measured. Table 3-16 presents the 

44 results of these measurements. The measured radionuclides are all naturally occurring, except 

45 for cesium-137, which is ubiquitous in the environment. Cesium-137 concentrations fall within 

46 the low end of the concentration range reported by the IDEQ for soil monitoring by in situ

47 gamma spectrometry in and around the INL in 2006 and 2007 and well below the IDEQ action 

48 level of 6.8 picocuries per gram (IDEQ, 2006a, 2007c). 
 3-46 

1 

2 Figure 3-19 Cross Sections Showing Depth to Basalt at the Proposed 

3 EREF Site (AES, 2010) 
 3-47

1 

Figure 3-20 Soil Map of the Proposed EREF Site and Surrounding Area (based on data from NRCS, 2009) 2 

3 
 3-48 

1 3.6.4.2 Soil Chemical Characteristics 

2 

3 The surface soil samples collected at the proposed EREF site were also analyzed for 

4 nonradiological constituents, including metals, pesticides, herbicides, phosphorous, fluoride, 

5 VOCs, and semivolatile organic compounds (SVOCs) (AES, 2010). Samples were also tested 

6 for percent moisture content. The results of the analyses for metals, fluoride, and moisture 

7 content in soils are summarized in Table 3-17. All metals fall within the range of background 

8 concentrations in surface soils reported for INL. Mercury was not detected in any of the 

9 samples. Moisture content varied from 9.1 to 16.5 percent. 

10 

11 VOCs were detected in only one of the 10 samples analyzed. Sample SS1, located within one 

12 of the crop circles in the northeastern portion of the proposed EREF property (Figure 3-21), had 

13 detectable levels of three VOCs: 1,3,5-trimethylbenzene, 1,3-dichlorobenzene, and 

14 tetrachloroethene (Table 3-18). The compound 1,3-dichlorobenzene has applications as a 

15 fumigant and insecticide/pesticide; its presence is likely related to the farming activities at the 

16 proposed site. The compounds 1,3,5-trimethylbenzene and tetrachloroethene are typically used 

17 as solvents; the source of these two VOCs is not clear. All compounds were detected at levels 

18 well below EPA’s regional screening levels for industrial soils (EPA, 2009a). 

19 

20 Three SVOCs were detected in four soil samples (SS2, SS4, SS9, and SS10) from the 

21 north-central and south-central portions of the proposed property (Figure 3-21). These samples 

22 had detectable levels of benzo(a)pyrene, dibenzo(a,h)anthracene, and ideno(1,2,3-cd)pyrene 

23 (Table 3-18). These are a few of the many polycyclic aromatic hydrocarbons (PAHs) that are 

24 found in the environment, usually as a result of the incomplete combustion or pyrolysis of 

25 organic matter, such as fossil fuels (IPCS, 2009). All compounds were detected at levels well 

26 below EPA’s regional screening levels for industrial soils (EPA, 2009a). 

27 

28 Of all the pesticides and herbicides tested, only chlorpropham (a pesticide) was detected in four 

29 samples from the north-central portion of the proposed property (Table 3-18; Figure 3-21). 

30 Concentrations of chlorpropham were well below EPA’s regional screening levels for industrial 

31 soils (EPA, 2009a). 

32 

33 3.7 Water Resources 

34 

35 3.7.1 Surface Water Features 

36 

37 3.7.1.1 Rivers, Streams, and Lakes 

38 

39 The proposed EREF site is located in the American Falls sub-basin (HUC 17040206), 

40 immediately west of the Idaho Falls sub-basin (HUC 17040201), on the easternmost edge of the 

41 Snake River Plain in southeast Idaho (USGS, 2009b; IDEQ, 2006b; Shumar, 2004) 

42 (Figure 3-22). These sub-basins encompass a portion of the South Fork Snake River from 

43 Heise (about 32 kilometers [20 miles] northeast of Idaho Falls) to Henry’s Fork and a section of 

44 the Snake River from the Henry’s Fork confluence through the diversion dams south of Idaho 

45 Falls to the American Falls Reservoir. The Snake River is about 32 kilometers (20 miles) to the 

46 east of the proposed EREF site; it generally flows from the northeast to the southwest. The 

47 largest surface water bodies downgradient of the proposed site are on the Snake River – the 

48 American Falls Reservoir and Lake Wolcott, about 79 kilometers (49 miles) and 127 kilometers 
 3-49

1 

Figure 3-21 Surface Soil and Borehole Sample Locations (AES, 2010) 2 
 3-50 

Table 3-16 Radiochemical Analyses of Proposed 

EREF Property Surface Soil 

Measured 

Concentrationsa

Representative Soil 

Concentrationsb

Radionuclides Bq/kg pCi/kg Bq/kg pCi/kg

Actinium-228 

Thorium-228 

38 ± 3.2 1020 ± 87.8 −c −

Cesium-137 10 ± 4.4 288 ± 118 252d 6800d

Potassium-40 660 ± 57 17,900 ± 1540 400 10,800 

Thorium-228 47 ± 4.8 1270 ± 131 − −

Thorium-230 46 ± 5.0 1250 ± 136 − −

Thorium-232 44 ± 3.5 1190 ± 92.0 37 999 

Uranium-234 29 ± 2.5 784 ± 68.3 − −

Uranium-235 3.3 ± 1.8 90.1 ± 48.9 − −

Uranium-238 30 ± 2.7 805 ± 73.0 66 1782 

a

 Concentrations noted as mean ± standard deviation; n=10 for all 

radionuclides but cesium-137 for which n=9. Source: AES, 2010. 

b

 Representative soil concentrations are taken from Table 4.3 of the National 

Council on Radiation Protection (NRCP) Report No. 94 (NCRP, 1998). 

c

 A dash indicates value is not available from NRCP, 1998. 

d

 Value from the IDEQ INL Oversight Program (Jones, 2009). 

1 

2 (79 miles), respectively, to the southwest of the proposed EREF site (Figure 3-22). There is an 

3 extensive network of canal systems that conveys water to agricultural areas near Idaho Falls. 

4 

5 Major land uses within the American Falls sub-basin are dryland and irrigated agriculture and 

6 livestock grazing. All water bodies within the sub-basin support cold water aquatic life; water 

7 supplies for domestic, agricultural, and industrial use; wildlife habitat; and recreation. The 

8 American Falls Reservoir provides water for irrigation and electricity generation. The Snake 

9 River and the American Falls Reservoir are designated sources of domestic water supply 

10 (IDEQ, 2006b). The EPA has classified 17 waters within the sub-basin as impaired, mainly 

11 because of sedimentation and siltation problems (EPA, 2010a). 

12 

13 There are no rivers, streams, or lakes within the proposed EREF property; however, a few small 

14 drainage features occur in the northeastern corner and in the southern portion of the proposed 

15 site (Figure 3-23). None of these features are regulated under Section 404 of the Clean Water 

16 Act (Joyner 2008). The drainage features in the northeastern corner are less visible in the field 

17 because they occur within the irrigated crop circles where the natural topography has been 

18 smoothed for crop production. Ephemeral drainage features in the southern portion of the 

19 proposed property were formed from natural erosional processes during snowmelt or episodic 

20 rain events, and they also drain water from irrigated agricultural areas. Most of these drainages 

21 lose water to infiltration and evapotranspiration; the potential for ponding of water is low 
 3-51 

Table 3-17 Metals, Soluble Fluoride, and Percent Moisture in Proposed EREF Property 

Surface Soil 

Analyte 

Soil Concentrations (mg/kg)a Detection 

Limit 

(mg/kg) 

Backgroundb

SS1 SS2 SS3 SS4 SS5 SS6 (mg/kg) SS7 SS8 SS9 SS10

Arsenic 5.5 7.7 5.5 7.1 6.6 7.3 6.7 7.1 6.9 6.5 1.3–1.8 3.7–24.4 

Barium 160 180 180 200 170 170 200 170 170 190 0.50 87−255 

Cadmium 0.56 0.61 NDc 0.69 0.59 0.58 0.74 0.57 0.6 0.55 0.50 1.3−2.8 

Chromium (III) 21 20 20 25 23 21 23 21 22 25 0.50 14−27 

Lead 15 16 14 18 16 16 17 16 16 18 0.60–0.81 9−28 

Selenium 0.26 0.19 0.15 0.17 0.42 0.2 0.15 0.16 0.16 0.13 0.05 0.3−16.7 

Silver ND ND ND 0.7 ND ND ND 0.7 ND ND 0.5–0.8 2.7−2.8 

Total mercury ND ND ND ND ND ND ND ND ND ND 0.05 0.05−0.06 

Soluble fluoride 12 ND ND ND 10 ND 10 ND ND ND 5 −d

Percent moisture 15.9 12.2 9.1 12.2 15.7 11.1 15.7 11.8 16.5 10.5 0.1 − a

 Source: AES, 2010. 

b

 Background values from ranges of mean background levels compiled by Westinghouse Idaho Nuclear Company, 

Inc. (1994) for surface soils at INL. 

c

 ND = not detected (the detection limit, i.e., the lowest measurable level, is reported in far right column). d

 Dash indicates no data were reported. 

1 

2 (NRCS, 2009). One drainage feature conveys water offsite. It starts in the south-central part of 

3 the proposed property within the footprint of the proposed EREF and runs southward toward 

4 US 20 (Figure 3-22). A series of small ponds to the north of US 20 were used at one time to 

5 collect and store water from this drainage for agricultural uses, but they are no longer in use and 

6 are currently dry. The NRC staff confirmed that a culvert at US 20 conveys water from this 

7 drainage to the south away from the roadway but does not connect to offsite resources or larger 

8 drainages. 

9 

10 3.7.1.2 Wetlands 

11 

12 There are no wetlands on the proposed EREF property (Joyner, 2008). The closest wetland is 

13 the Market Lake WMA, near Roberts, about 32 kilometers (20 miles) to the northeast. No 

14 commercial or sport fisheries are located on the proposed property; the nearest fisheries (trout) 

15 are on the Upper Snake River (Idaho Fish and Game Fisheries Region 7) along Henry’s Fork 

16 (in Bonneville County) and the South Fork (IDFG, 2009c). 

17 

18 3.7.1.3 Floodplains 

19 

20 The proposed EREF property is not located within any 100-year or 500-year floodplains 

21 (FEMA, 2010). There are no reservoirs, levees, or surface water that could cause flooding of 

22 the proposed EREF. The Snake River is the closest river to the proposed EREF site. It is 

23 located about 32 kilometers (20 miles) to the east. Its headwater is a spring near the southern 

24 boundary of Yellowstone National Park in the northwestern corner of Wyoming. The USGS 
 3-52 Table 3-18 VOCs, SVOCs, and Pesticides Detected in Proposed EREF Property Surface Soil Analyte Soil Concentrations (mg/kg) Regional Screening Level (mg/kg)a SS1 SS2 SS3 SS4 SS5 SS6 SS7 SS8 SS9 SS10 VOCs 1,3,5-Trimethylbenzene 0.0067 NDb ND ND ND ND ND ND ND ND 200 1,3-Dichlorobenzene 0.0082 ND ND ND ND ND ND ND ND ND 10,000c Tetrachloroethene 0.0086 ND ND ND ND ND ND ND ND ND 2.7 SVOCs Benzo(a)pyrene ND 0.014 ND 0.035 ND ND ND ND 0.059 0.014 0.21 Dibenzo(a,h)anthracene ND 0.012 ND 0.024 ND ND ND ND 0.038 0.0099 0.21 Ideno(1,2,3-cd)pyrene ND 0.025 ND 0.081 ND ND ND ND 0.146 0.024 2.1 Pesticide Chlorpropham ND ND ND 0.0074 ND 0.0055 ND 0.0110 ND ND 120,000 a Regional screening levels (RSLs) based on carcinogenic target risk for industrial soils, except for 1,3,5-trimethylbenzene and chlorpropham 

which are based on a noncancerous hazard index. Source: EPA, 2009a. 

b ND = not detected. c RSL not available for 1,3-dichlorobenzene; value provided is for 1,2-dichlorobenzene. 

Source: AES, 2010. 

1 
 3-53 

1 

2 Figure 3-22 USGS-Designated Sub-basins within the Eastern Snake River Plain 

3 (adapted from Seaber et al., 2007) 

4 

5 station (13057155) on the Snake River above Eagle Rock (about 13 kilometers [8 miles] 

6 upstream of Idaho Falls) has an average daily flow of 162 cubic meters per second (5738 cubic 

7 feet per second), as measured between water years 1987 and 2008 (USGS, 2009c). During 

8 this period, monthly averages ranged from 87 cubic meters per second (3070 cubic feet per 

9 second) in December to 337 cubic meters per second (11,900 cubic feet per second) in June 

10 (USGS, 2009d). Annual average and peak flows at the Snake River above Eagle Rock station 

11 are shown in Figure 3-24. Annual peak flows tend to be about two to three times the average 

12 flow rates. The maximum flow rate at this site, 1376 cubic meters per second (48,600 cubic feet 

13 per second), occurred during a storm on June 16, 1997 (USGS, 2009e). 

14 

15 According to the NCDC, southeastern Idaho has been in a drought since 2000. From 1988 

16 through 2000, the average annual flow recorded at the Snake River above Eagle Rock station 

17 was 164 cubic meters per second (5793 cubic feet per second); since 2000, the average annual 

18 flow at the station has been reduced to 127 cubic meters per second (4501 cubic feet per 
 3-54

1 

Figure 3-23 Drainage Features in the Vicinity of the Proposed EREF Site (AES, 2010) 2 
 3-55 

1 second) (USGS, 2009e). Recent data from NCDC (2009c) indicate some improvement in the 

region’s drought conditions.12 2 

3 

4 3.7.2 Groundwater Resources 

5 

6 3.7.2.1 Regional Hydrogeology 

7 

8 Because the climate in southeastern Idaho is cold and semiarid, natural soil development due to 

9 the growth and decomposition of vegetation is minimal on the ESRP. Surface soils are 

10 predominantly of eolian (wind) origin; soil cover is variable, ranging from nonexistent in areas of 

11 recent volcanism to tens of meters thick in areas of loess (wind-blown silt) accumulation. Thin 

12 soils and basalt outcrops are common in many areas along ridge lines and wind-swept areas 

13 (Hughes et al., 1999; Lindholm, 1996; Whitehead, 1994). 

14 

15 Soil types on the ESRP fall into six orders of lightly weathered soils typical of arid climates: 

16 alfisols, aridisols, entisols, inceptisols, mollisols, and vertisols (based on the taxonomy of 

17 USDA, 2010a). Most of these soils fall into the silt-loam textural class: 0 to 27 percent clay, 

18 55 to 80 percent silt, and 10 to 35 percent sand. The mineralogy of soils at the INL reported by 

19 Nimmo et al. (2004) includes quartz, plagioclase, olivine, calcite, dolomite, and clay minerals; 

20 these are likely typical of the soils on the ESRP. Data summarized for INL by Nimmo et al. 

(2004) indicate that saturated hydraulic conductivities range from about 5.0  10-4 21 centimeters 

per second (1.6  10-5 feet per second) to 1.0  10-2 centimeters per second (3.3  10-4 22 feet per 

23 second), although reported ranges in the literature span over six orders of magnitude from 

1.1  10-8 centimeters per second (3.6  10-10 feet per second) to 1.2  10-2 24 centimeters per 

second (3.9  10-4 25 feet per second). Porosities ranged from 0.42 to 0.55, and moisture contents 

26 from about 5 percent to 30 percent were also reported. 

27 

28 The vadose zone below the ESRP is spatially heterogeneous, ranging in thickness from 

29 60 meters (197 feet) to 300 meters (984 feet). It is made up of unconsolidated alluvium and 

30 basalts of the Snake River Group (Section 3.6.1). Perched water zones are common 

31 throughout the ESRP, especially near rivers, canals, or other sources of surface water. Water 

32 within the vadose zone moves (1) by diffusion that is predominantly vertical and driven by 

33 gravity and (2) by preferential flow that is both vertical and horizontal and influenced by the 

34 presence and orientation of pores and fractures within the basalts and by the interlayers of 

35 sediment between basalt flows (Nimmo et al., 2004; Smith, 2004). 

36 

37 The groundwater system underlying the Snake River Plain in the vicinity of the proposed 

38 EREF site (and the source of its potable and process water supply) is the ESRP aquifer. 

39 The ESRP aquifer underlies an area of 26,000 square kilometers (10,040 square miles) and 

40 is up to 400 meters (1312 feet) thick, but it is most productive in the upper 90 to 150 meters 

41 (300 to 500 feet). Water volume in the ESRP aquifer is about 100 billion cubic meters 

42 (81 million acre-feet). The aquifer is largely unconfined; groundwater flows southwestwardly 

 

12 The NCDC uses the Palmer Drought Severity Index (PDSI) as a measure of long-term drought 

conditions. The PDSI takes into account precipitation, temperature, and soil moisture. Numbers 

range between –6.0 and +6.0, with negative numbers representing drier-than-normal conditions and 

positive numbers representing wetter-than-normal conditions (zero is normal). For the week ending 

February 20, 2010, the ESRP had a near-normal PDSI between 1.9 and +1.9 (NOAA, 2010). 
 3-56 

1 

2 Figure 3-24 Annual Average and Peak Flows at the Snake River above Eagle Rock 

3 Station (Source: based on data from USGS, 2009e,f) 

4 

5 from recharge areas on the Yellowstone Plateau (and from precipitation- and surface-water6 irrigated areas on the Snake River Plain) at an average gradient of 1.9 meters per kilometer 

7 (or 0.0019) and discharges to the Snake River through a series of springs between Twin Falls 

8 and King Hill. Flow velocities average about 3 meters per day (10 feet per day) (Smith, 2004; 

9 Wood and Low, 1988; Lindholm, 1996). Figure 3-25 shows groundwater flow contours for the 

10 ESRP aquifer based on data from the Idaho Department of Water Resources’ (IDWR’s) map 

11 service (IDWR, 2010). 

12 

13 3.7.2.2 Site Hydrogeology 

14 

15 Well logs show that most of the basalt bedrock below the proposed EREF site is fractured to 

16 some degree, although massive zones with few or no fractures (indicating basalt flow interiors) 

17 are also present. Flow interiors typically contain narrow vertical fractures; flow tops and bottoms 

18 have large vertical and horizontal fractures and are also marked by the presence of scoria, 

19 cinder, red oxidation, and increased vesicles. Massive zones in wells GW-1 and GW-4 (shown 

20 in Figure 3-26) are up to 3 meters (10 feet) in thickness. Three well-developed sedimentary 

21 interbeds, with thicknesses ranging from 1.2 to 2.4 meters (4.0 to 8.0 feet), were observed in 

22 GW-1 at depths of 18.3 meters, 59.4 meters, and 122.5 meters (60 feet, 195 feet, and 402 feet) 

23 (AES, 2010). 

24 

25 Field tests indicate that the aquifer is unconfined or semi-confined. Estimates of hydraulic 

26 conductivity (flow velocity) range from 0.007 meter per second (0.023 foot per second) to 

27 0.015 meter per second (0.05 foot per second). Hydraulic conductivities are highest in the 

28 fractured basalt and lowest in sedimentary interbeds and massive zones within the basalt flow 
 3-57 

1 

2 Figure 3-25 Groundwater Flow Contours for the ESRP Aquifer (IDWR, 2010) 

3 

4 interiors. Sedimentary interbeds and massive basalt zones, therefore, significantly impede the 

5 downward movement of water and may cause perching above the water table or lateral flow 

6 (AES, 2010). 

7 

8 About 60 percent of the ESRP aquifer recharge comes from irrigation water; other sources of 

9 recharge include small aquifers in valleys along the plain’s edge (about 18 percent), infiltration 

10 from rivers and canals (about 13 percent), and precipitation (rain and snow) (about 9 percent) 

11 (IWRB, 2009). Although low-permeability layers are present in the vadose zone, little or no 

12 perching of groundwater has been observed below the proposed site. Depth to groundwater in 

13 onsite wells ranges from 201.5 meters (661 feet) to 220.0 meters (722 feet) below the ground 

14 surface. Groundwater flow below the proposed EREF site is consistent with the regional 

15 groundwater flow, from the northeast to the southwest, with a hydraulic gradient that drops 

16 1.3 meters (4.3 feet) over a distance of 2260 meters (7460 feet) between wells GW-5 and GW-1 

17 (about 0.0006) (Figure 3-26). 

18 

19 3.7.2.3 Groundwater Use 

20 

21 Snake River Plain Aquifers

22 

23 The aquifers of the Snake River Plain are located in the basalt flows that formed the 

24 40,404-square-kilometer (15,600-square-mile), crescent-shaped lobe in southern Idaho 
 3-58 

1 

2 Figure 3-26 Groundwater Potentiometric Surface Map for the Proposed EREF Property 

3 (AES, 2010) 

4 

5 (Figure 3-27). The eastern half of the plain (the ESRP aquifer) consists of basalt flows with 

6 thicknesses up to 610 meters (2000 feet) that are overlain by and interbedded with 

7 unconsolidated sedimentary deposits. The western half is composed predominantly of 

8 unconsolidated sedimentary deposits with some basalt flows that are less thick than those 

9 making up the eastern half. The saturated thickness of the eastern half is much greater than 

10 that of the western half (Maupin and Barber, 2005). About 86 percent of the groundwater 

11 flowing through the Snake River Plain aquifers eventually discharges to the Snake River. The 

12 balance (about 14 percent) is withdrawn for irrigation, drinking water, and commercial and 

13 livestock use (IDEQ, 2005). In 2005, total water withdrawals – of both surface water and 

14 groundwater – in Bonneville County were 3.3 million cubic meters (882 million gallons per day 

15 or 988 thousand acre-feet per year). Groundwater withdrawn from the ESRP aquifer was 

16 about 19 percent of the total water withdrawn that year (USGS, 2010). The largest usage of 

17 groundwater in 2005 was for crop irrigation (at 96 percent). The second largest usage was for 

18 the public and domestic water supply (at 3.5 percent). 

19 

20 Public Water Supply and Water Rights

21 

22 The ESRP aquifer was designated a sole source aquifer in 1991. A sole source aquifer is 

23 defined as one that supplies at least 50 percent of the drinking water in the petitioned area and 
 3-59 

1 

2 Figure 3-27 Snake River Plain Aquifers (modified from Maupin and Barber, 2005) 

3 

4 for which there is not a reasonably available alternative source to supply drinking water to all 

5 those who depend on the aquifer (EPA, 2009c). Currently, the ESRP aquifer is the sole 

6 source of drinking water for populations in southeast and south-central Idaho. The largest 

7 municipalities on the ESRP are Idaho Falls (Bonneville County) and Pocatello (Bannock 

8 County). The City of Idaho Falls operates a system of groundwater wells that meet an average 

9 daily usage of about 76,000 cubic meters (20 million gallons), with a maximum daily usage of 

10 about 220,000 cubic meters (58 million gallons). The City of Pocatello obtains its drinking water 

11 from the ESRP and Portneuf aquifers. Its municipal system meets an average daily usage of 

12 about 49,160 cubic meters (13 million gallons), with a maximum daily usage of about 

13 130,700 cubic meters (34 million gallons) (IDC, 2009). 

14 

15 The proposed EREF would use groundwater appropriated by a 1961 water right that would 

16 transfer to AES with the purchase of the proposed EREF property. The transfer approval notice 

17 (for Water Right No. 35-2642) specifies an annual industrial diversion rate of 1713 cubic meters 

18 per day (452,527 gallons per day) and an annual irrigation diversion rate (from April 1 to 

19 October 31) of 147 cubic meters per day (38,833 gallons per day) (Carlsen, 2009). The primary 

20 point of diversion would be the existing onsite agricultural well (Lava Well; Figure 3-25) and an 

21 additional well installed to supply potable water. 

22 

23 
 3-60 

1 3.7.2.4 Groundwater Quality 

2 

3 The upper portion of the ESRP aquifer has a predominantly calcium bicarbonate composition 

4 and is of high quality when compared with drinking water standards. The concentrations of 

5 minor elements and metals in the aquifer are generally low due to its neutral to slightly alkaline 

6 pH and moderately reducing conditions (Lindholm, 1996; Wood and Low, 1988). 

7 

8 Currently, there are two agricultural wells (Lava Well 3 and Spud Well), five deep aquifer 

9 monitoring wells (GW-1 through GW-5), and one shallow perched water well (GW-4S) at the 

10 proposed EREF site (Figure 3-25). Well GW-4S has been dry since it was installed. Water 

11 from monitoring wells GW-1 through GW-5 were sampled following their completion in May and 

12 July 2008 and then again in October 2008. The agricultural wells were sampled in March, May, 

and October 2008. Samples from all wells were analyzed for metals (dissolved and total13 13 ), 

14 total organic carbon, VOCs, SVOCs, PCBs, total petroleum hydrocarbons, pesticides, and 

15 herbicides (AES, 2010). Analytes were compared to the EPA’s maximum contaminant levels 

(MCLs) and secondary MCLs (SMCLs),14 16 since these represent stringent limits for potable water 

17 supplies (EPA, 2010b). 

18 

19 Total dissolved solids in onsite well samples were found in the range of 200 to 260 milligrams 

20 per liter, less than the EPA MCL of 500 milligrams per liter. Dissolved metal concentrations 

21 were also detected at levels below their corresponding MCL. Except for aluminum and iron, 

22 which were found in samples from the agricultural wells, total metal concentrations were below 

23 the EPA MCLs. Aluminum and iron concentrations likely resulted from the presence of 

24 suspended particles, which do not dissolve in the slightly alkaline pH of the aquifer. 

25 

26 No VOCs, SVOCs, PCBs, pesticides, or herbicides were detected in groundwater samples 

27 collected in March, May, and July 2008. October 2008 samples from some monitoring wells 

28 contained low levels of plasticizers (bis[2-ethylhexyl]phthalate and diethylphthalate) and trace 

29 amounts of chloroform. Low levels of lubricating oil were also detected in samples from some 

30 wells. These concentrations likely resulted from contamination introduced by sample handling 

31 (e.g., collecting or laboratory analysis) and drilling (in the case of the lubricating oil) and do not 

32 represent contamination within the aquifer. 

33 

34 Radiological analyses (gamma spectroscopy, gross alpha and beta, and tritium) were also 

35 performed on groundwater samples collected in 2008. Radium-224 and -228 and uranium-234, 

36 -235, and -238 were detected in some monitoring wells. Radium-228 and uranium-234, -235, 

37 and -238 were all below their respective EPA MCLs (5 picocuries per liter and 20 picocuries per 

38 liter). Detectable levels of gross beta were found in some monitoring wells, but in each case, 

39 they were less than the EPA MCL of 15 picocuries per liter. Tritium was detected in one well 

40 (GW-3) at a concentration of 530 picocuries per liter in May 2008. The EPA MCL for beta 

41 particle and photon radioactivity from radionuclides (like tritium) in drinking water is 4 millirem 

 

13 Total metals in groundwater consist of those metals that are dissolved as free ions and metal 

complexes and those that are suspended (and filterable) as adsorbed or precipitated particles. 

14 The Safe Drinking Water Act defines primary drinking water standards or MCLs as the maximum 

permissible level of a contaminant in public drinking water. Secondary drinking water standards or 

SMCLs are for contaminants that are not threatening to health but could give rise to undesirable 

aesthetic (e.g., taste or odor), cosmetic (e.g., skin discoloration), or technical (e.g., corrosivity) effects. 
 3-61 

1 per year; the average concentration of tritium that would yield this level of radioactivity is about 

2 20,000 picocuries per liter (EPA, 2002). The concentration of tritium (530 picocuries per liter) 

3 detected in well GW-3 represents about 3 percent of that concentration. 

4 

5 3.8 Ecological Resources 

6 

7 This section describes the ecological resources, including plant communities; wildlife; rare, 

8 threatened, and endangered species; wetlands; and environmentally sensitive areas, of the 

9 proposed EREF site and property and surrounding areas. Surveys were conducted by AES in 

10 June and October 2008 for vegetation on the property and in May, June, and October 2008, 

11 January and April 2009, and April 2010 for wildlife. Ecological surveys also have been 

12 conducted at INL, a 2305-square-kilometer (890-square-mile) DOE laboratory about 

13 1.6 kilometers (1 mile) west of the property, for more than 50 years. 

14 

15 3.8.1 Plant Communities 

16 

17 The EPA through its Western Ecology Region has developed, in cooperation with the 

18 U.S. Forest Service and the National Resource Conservation Service (formerly the Soil 

19 Conservation Service), a common framework for describing, classifying, and mapping ecological 

20 regions of the United States. The ecological regions mapped are typically geographically large. 

21 

22 These geographically distinct areas are associated with clearly observable groupings of plant 

23 and animals that live there under specific environmental conditions. The EREF property is 

24 located in what is called the Snake River Plain (Ecological Region 12), an area that covers 

25 about 51,023 square kilometers (19,700 square miles) (McGrath et al., 2002). The region is 

26 further divided into ten sub-regions, three of which are associated with the area ecology and/or 

27 the EREF property. These sub-regions are the: (1) 12b Lava Fields, (2) 12g East Snake River 

28 Basalt Plain, and (3) 12e Upper Snake River Plain. The approximate size of the sub-regions is 

29 1100, 6400 and 1500 square miles, respectively. The Snake River Plain is also referred to as 

30 the Sagebrush Steppe, and in its more native state (12g) is characterized by large expanses of 

31 sagebrush and a variety of native grasses with saltbush and shad scale found in the saltier 

32 soils. The major difference between the 12g and 12e types is that the latter typically has deeper 

33 soils and where irrigation is available is used for the production of pastures and small grains 

34 such as wheat, potatoes, sugar beets, beans, and alfalfa. Type 12b is the lava field and can be 

35 found at the Craters of the Moon National Monument and Preserve. 

36 

37 A fairly large part of this ecological region is located in within the BLM’s Upper Snake land unit 

38 managed out of its field office in Idaho Falls, Idaho. The boundaries of the Upper Snake unit 

39 total about 11,100 square miles or 7.1 million acres and roughly correspond to the same 

40 ecological sub-regions described under the EPA mapping system for the sagebrush steppe 

41 region. About 4000 square miles or 2.6 million acres (36.1 percent) are privately held lands, 

42 about 2800 square miles or 1.8 million acres (25.3 percent) are managed by BLM, about 

43 2600 square miles or 1.7 million acres (23.4 percent) are managed by the U.S. Forest Service, 

44 and about 600 square miles or 0.4 million acres (5.3 percent) are owned by the State of Idaho. 

45 The nearby INL contains about 900 square miles or 0.6 million acres (8.0 percent). Together 

46 these land groupings total over 90 percent of the 7.1-million-acre BLM land management unit. 

47 
 3-62 

1 The BLM is tasked with the management of the rangeland under its control for multiple uses. 

2 Principal activities managed include grazing, wildlife habitat, hunting, and recreation, and this is 

3 performed under a comprehensive range management plan (RMP). Periodically the BLM 

4 reevaluates its current management plan and revises it. Revising an RMP is considered to be a 

5 major Federal action and requires that the BLM prepare an EIS. On February 28, 2008, the 

6 BLM published in the Federal Register a Notice of Intent to prepare an EIS to revise the Upper 

7 Snake RMP (73 FR 10802) and has completed a Final Public Scoping Report. The RMP 

8 planning process is a cooperative effort involving, in part, the DOE, EPA, U.S. Forest Service, 

9 the FWS, and a number of Idaho government agencies including the Department of Fish and 

10 Game, Department of Agriculture, and Department of Parks and Recreation. 

11 

12 The BLM Field Office estimates that 98 percent of the RMP area consists of sagebrush steppe 

13 and that the largest single land use for the public lands is livestock grazing. The BLM received 

14 684 comments that were then grouped into seven planning issues. The seven planning issues 

15 identified are now being used to develop alternatives to be evaluated in the EIS. Two of the 

16 seven issues listed relate directly to the scope of the AES EIS and include impacts to the 

17 long-range health of the Sagebrush Steppe and its wildlife and plant communities and the 

18 resolution of conflicts over livestock grazing. 

19 

20 In 1995, the National Biological Service listed the Sagebrush Steppe ecosystem as a critically 

21 endangered ecosystem across its entire range (BLM/DOE, 2004) and has experienced more 

22 than a 98 percent decline since European settlement. The INL Sagebrush Steppe Ecosystem 

23 Reserve was established in 1999. This reserve is significant in many respects, not the least of 

24 which is the fact that it is currently the largest non-grazed reserve of sagebrush steppe in the 

25 region with approximately 40 percent of the area not having been grazed for over 50 years, and 

26 is the closest example of what the sagebrush steppe looked like before European settlement. 

27 The site maintains a long-term management plan that is jointly implemented and administered 

28 by DOE and the BLM in consultation with the FWS and the Idaho Department of Fish and 

29 Game. The most recent management plan was finalized in May 2004 (Final Management Plan 

30 EA ID-074-02-067 Finding of No Significant Impact) with a preferred alternative of multiple land 

31 use with a continued emphasis on natural resource protection and controlled livestock grazing 

32 principally on the BLM land within the boundaries of INL. 

33 

34 Large areas of the INL site support high-quality, relatively undisturbed sagebrush steppe 

35 habitat, and are included in the INL Sagebrush Steppe Ecosystem Reserve (BLM/DOE, 2004). 

36 Species diversity is high because of the reduced level of disturbances, such as grazing. 

37 Wyoming big sagebrush (Artemisia tridentata ssp. wyomingensis) and basin big sagebrush 

38 (Artemisia tridentata ssp. tridentata) are the dominant shrubs in this habitat; other frequently 

39 occurring shrubs include green rabbitbrush (Chrysothamnus viscidiflorus), winterfat 

40 (Krascheninnikovia lanata), prickly phlox (Leptodactylon pungens), and spiny hopsage (Grayia 

41 spinosa) (BLM/DOE, 2004). Perennial grasses commonly occurring in this habitat include thick42 spiked wheatgrass (Elymus lanceolatus), Indian ricegrass (Achnatherum hymenoides), needle43 and-thread (Hesperostipa comata), and Sandburg bluegrass (Poa secunda), while fernleaf 

44 biscuitroot (Lomatium dissectum), threadstock milkvetch (Astragalus filipes), Hoods phlox 

45 (Phlox hoodii), and hoary aster (Machaeranthera canescens) are commonly occurring forbs. 

46 Some areas of former sagebrush habitat on INL have been converted to grassland due to 

47 wildfire. 
 3-63 

1 The EREF property is located within both the 12g East Snake River Basalt Plain and the 

2 12e Upper Snake River Plain or Sagebrush Steppe ecoregions. Figure 3-28 shows the land 

3 cover types in the region around the EREF property, while Figure 3-29 provides cover types on 

4 the EREF property and immediate vicinity (Landscape Dynamics Lab, 1999). The property is 

5 transitional in that the western part of the property (Figure 3-30); 429 hectares (1060 acres) is 

6 sagebrush steppe whereas the remainder of the property managed as either nonirrigated 

7 pasture (882 hectares [2180 acres]) or as irrigated cropland (389 hectares [962 acres]) 

8 (AES, 2010). Immediately to the east of the property, the land is intensively managed as 

9 agricultural lands and falls within the 12g East Snake River Basalt Plain ecoregion. 

10 

11 As shown in Table 3-19, 34 plant species were identified within the sagebrush steppe 

12 community. The dominant species in this community on the EREF property are the shrubs 

13 Wyoming big sagebrush (approximately 16 percent areal cover), dwarf goldenbush (Ericameria 

14 nana) (approximately 17 percent areal cover), and Sandberg bluegrass (Poa secunda), a native 

15 perennial bunchgrass (approximately 11 percent areal cover) (AES, 2010). Only 8 of the 

16 14 commonly occurring species in high-quality INL sagebrush steppe habitats were found on 

17 the EREF property. The total areal cover of all plants, excluding mosses, is about 60 percent. 

18 The total areal cover of shrubs is about 34 percent, of grasses about 20 percent, and forbs 

19 about 6 percent. The sagebrush steppe community has been impacted for many years by 

20 grazing, resulting in soil disturbance and reduced cover of herbaceous species. Four of the 

21 34 species (12 percent) identified in this community were non-native, including cheatgrass, a 

22 highly invasive annual species which currently covers about 4 percent of the sagebrush steppe 

23 habitat. The density of Wyoming big sagebrush ranges from 6000 plants per hectare (2428 per 

24 acre) for short shrubs, those less than 40 centimeters (15.7 inches) in height, to 6900 plants per 

25 hectare (2792 per acre) for taller shrubs, those at least 40 centimeters (15.7 inches) in height. 

26 

27 The other predominant plant community type at the EREF property is nonirrigated pasture, 

28 which represents the remnant of sagebrush steppe that was mechanically modified to develop 

29 improved grazing (AES, 2010). Modification included the removal of shrubs from most of the 

30 area composing this community; grasses, such as crested wheatgrass (Agropyron cristatum), a 

31 non-native perennial bunchgrass, were planted. The remaining shrubs are primarily located at 

32 rock outcrops. The dominant species in the pasture community on the property are crested 

33 wheatgrass (about 34 percent areal cover) and cheatgrass (approximately 12 percent areal 

34 cover) (AES, 2010), both non-native species. This community has much lower species diversity 

35 than the native sagebrush steppe community. A total of only 17 plant species have been 

36 identified within this community. The total areal cover of all plants is about 55 percent. The 

37 total areal cover of grasses is about 47.5 percent, of forbs about 7 percent, and shrubs about 

38 0.5 percent. Seven of the 17 species (41 percent) identified in this community are non-native. 

39 Bur buttercup (Ranunculus testiculatus), a non-native forb, occurs frequently in this community 

40 (about 5 percent areal cover). Other non-native species include alfalfa (Medicago sativa), 

41 tansymustard (Descurainia sophia), goats beard (Tragopogon dubius), and Canada thistle 

42 (Cirsium arvense), all at less than 1 percent cover. 

43 

44 3.8.2 Wildlife 

45 

46 The wildlife species observed or determined to be present, based on evidence observed, on the 

47 EREF property are presented in Table 3-20. A total of 27 wildlife species were identified in the 

48 sagebrush steppe community. Sagebrush obligate species, which depend on sagebrush during 
 3-64

1 

Figure 3-28 Land Cover Types of the Region (data from Landscape Dynamics Lab, 1999) 2 

3 
 3-65 

1 

Figure 3-29 Land Cover Types of the Proposed EREF Property (data from Landscape Dynamics Lab, 1999) 2 

3 
 3-66

1 

Figure 3-30 Vegetation Types of the Proposed EREF Property (AES, 2010) 2 
 3-67 

Table 3-19 Plant Species Identified on the Proposed EREF Property and 

Percent Areal Cover 

 Plant Community 

Scientific Namea Common Name Sagebrush 

Steppe 

Nonirrigated 

Pasture 

Shrubs 

Artemisia tridentata ssp. 

wyomingensis

Wyoming big 

sagebrush 

16.00 0.18 

Artemisia tripartita Threetip sagebrush 0.30 b

Atriplex nuttallii Nuttall’s saltbush 0.10 

Ericameria nauseosa Rubber rabbitbrush  0.18 

Ericameria nana Dwarf goldenbush 17.00 0.18 

Krascheninnikovia lanata Winterfat 0.09 

Grasses 

Agropyron cristatum* Crested wheatgrass 0.60 33.60 

Bromus tectorum* Cheatgrass 4.00 11.90 

Elymus elymoides Squirreltail 0.09 

Elymus lanceolatus Thick-spike wheatgrass 1.00 

Hesperostipa comata Needle-and-thread 0.02 

Hordeum jubatum Foxtail barley 3.00 0.05 

Achnatherum hymenoides Indian ricegrass 0.04 

Poa secunda Sandberg bluegrass 11.00 1.90 

Forbs 

Agoseris glauca False dandelion  0.80 

Allium textile Textile onion 0.10 

Arabis lignifera Desert rockcress 0.20 

Astragalus curvicarpus Curvepod milkvetch 0.20 

Castilleja sp. Indian paintbrush 0.07 

Chenopodium leptophyllum Slimleaf goosefoot 0.04 

Cirsium arvense* Canada thistle  0.05 

Crepis acuminata Hawksbeard 0.10 

Cryptantha interrupta Bristly cryptantha 0.10 

Delphinium andersonii Anderson’s larkspur 0.02 

Descurainia sophia* Tansymustard 1.00 0.14 

Erigeron pumilus Shaggy fleabane 0.40 0.41 
 3-68 

Table 3-19 Plant Species Identified on the Proposed EREF Property and 

Percent Areal Cover (Cont.) 

 Plant Community 

Scientific Name Common Name Sagebrush 

Steppe 

Nonirrigated 

Pasture 

Lappula occidentalis Flatspine stickseed 0.50 0.05 

Lepidium sp. Pepperwort 0.09 

Lomatium dissectum Fernleaf biscuitroot 0.30 

Medicago sativaa Alfalfa  0.14 

Oenothera caespitosa Desert evening 

primrose 

0.02 

Packera cana Woolly groundsel 0.02 0.05 

Phlox hoodii Hood’s phlox 0.60 0.05 

Phlox longifolia Longleaf phlox 2.00 

Ranunculus testiculatusa Bur buttercup 0.02 5.00 

Schoenocrambe linifolia Flaxleaf plainsmustard 0.30 

Sphaeralcea munroana Orange globemallow 0.02 

Tragopogon dubiusa Goat’s beard  0.09 

Cacti 

Opuntia polyacantha Prickly pear 0.20  a Non-native species. 

b

 Dash = not observed. 

Source: AES, 2010; native status from USDA, 2010b.

1 

2 at least some portion of the year for survival, that are known to occur on the property include 

3 greater sage-grouse (Centrocercus urophasianus), sage thrasher (Oreoscoptes montanus), 

4 Brewer’s sparrow (Spizella breweri), sage sparrow (Amphispiza belli), and pronghorn antelope 

5 (Antiliocapra americana). 

6 

7 Fifteen wildlife species were observed in the nonirrigated pasture habitat and 10 in the irrigated 

8 crops area. No small-mammal trapping was conducted on the property; however, small 

9 mammals common in similar habitats at INL include black-tailed jack rabbit (Lepus californicus), 

10 mountain cottontail (Sylvilagus nattallii), pygmy rabbit (Brachylagus idahoensis), Townsend’s 

11 ground squirrel (Spermophilus townsendii), least chipmunk (Tamias minimus), Great Basin 

12 pocket mouse (Perognathus parvus), Ord’s kangaroo rat (Dipodomys ordii), western harvest 

13 mouse (Reithrodontomys megalotis), deer mouse (Peromyscus maniculatus), bushy-tailed 

14 woodrat (Neotoma cinerea), and montane vole (Microtus montanus) (S.M. Stoller 

15 Corporation, 2001). 

16 

17 
 3-69 

Table 3-20 Wildlife Species Occurring on the Proposed EREF Propertya

Scientific Name Common Name Sagebrush 

Steppe 

Nonirrigated 

Pasture 

Irrigated 

Cropland 

Amphibians 

Ambystoma tigrinum Tiger salamander b X 

Reptiles 

Phrynosoma douglassi Short-horned lizard X  

Birds 

Ammodramus savannarum Grasshopper sparrow X  

Amphispiza belli Sage sparrow X  

Asio flammeus Short-eared owl X  

Buteo jamaicensis Red-tailed hawk   

Centrocercus urophasianus Greater sage-grouse X  

Charadrius vociferus Kildeer  X 

Circus cyaneus Northern harrier X X X 

Corvus brachyrhynchos American crow X X X 

Eremophila alpestris Horned lark X X X 

Euphagus cyanocephalus Brewer’s blackbird X  

Falco mexicanus Prairie falcon X  

Molothrus ater Brown-headed cowbird X X 

Numenius americanus Long-billed curlew   X 

Oreoscoptes montanus Sage thrasher X X 

Pica hudsonia Black-billed magpie X X X 

Pooecetes gramineus Vesper sparrow X X 

Spizella breweri Brewer’s sparrow X X 

Spizella passerina Chipping sparrow   

Sturnella neglecta Western meadowlark X X X 

Zenaida macroura Mourning dove X X X 

Mammals 

Taxidea taxis Badger X  

Canis latrans Coyote X X 

Antiliocapra americana Pronghorn X X 

Microtus montanus Montane vole X  

Odocoileus virginianus White-tailed deer X  

Lepus californicus Black-tailed jack rabbit X  

 
 3-70 

1 

2 Pronghorn have been observed on the EREF property. Pronghorn use the property throughout 

3 the year, and the property is located within important winter-spring pronghorn habitat. Mule 

4 deer (Odocoileus hemionus) and elk (Cervus canadensis) occur in the region during summer 

5 and winter and migrate through the INL area between summer and winter use areas 

6 (BLM/DOE, 2004). There are no indications that mule deer, elk, or pronghorn populations are 

7 declining in the region; elk and pronghorn populations may be slightly increasing (IDFG, 2009b). 

8 

9 3.8.3 Rare, Threatened, and Endangered Species 

10 

11 No Federally listed threatened or endangered species are known to occur, or are expected to 

12 occur, on the EREF property (FWS, 2009a), and none were identified on the property during 

13 field surveys. The following Federally listed species are known to occur in Bonneville County 

14 and adjacent Jefferson and Bingham Counties, and are found in stream, forest, wetland, and 

15 riparian habitats: the Utah valvata snail (Valvata utahensis), endangered; Canada lynx (Lynx 

16 canadensis), threatened; Ute ladies’-tresses (Spiranthes diluvialis), threatened; grizzly bear 

17 (Ursus arctos), threatened; and yellow-billed cuckoo (Coccyzus americanus), a candidate for 

18 listing (FWS, 2009b). None of their habitat types are found on the EREF property nor within an 

19 8-kilometer (5-mile) radius of the property. 

20 

21 The Utah valvata snail is a freshwater aquatic snail that occurs in the mainstem of the Snake 

22 River (FWS, 2010a). The Snake River is about 32 kilometers (20 miles) from the property, and 

23 there are no freshwater habitats on or in the vicinity of the property. Therefore, this species 

24 would not occur on or near the property. 

25 

26 The Canada lynx (Lynx canadensis) is typically associated with forested habitats and may use 

27 riparian habitat along rivers as travel corridors. Ute ladies’-tresses (Spiranthes diluvialis), a 

28 plant primarily of wetland and riparian habitats, occurs in the Snake River floodplain 

29 (IDFG, 2009a). The yellow-billed cuckoo (Coccyzus americanus) is typically associated with 

30 riparian woodlands and shrubs and occurs along the Snake River. The grizzly bear occurs in a 

31 variety of habitats within portions of the Greater Yellowstone Area (FWS, 2010b). 

32 

Table 3-20 Wildlife Species Occurring on the Proposed EREF Propertya

 (Cont.) 

Scientific Name Common Name Sagebrush 

Steppe 

Nonirrigated 

Pasture 

Irrigated 

Cropland 

Spermophilus townsendii Townsend’s ground squirrel X  

Tamias minimus Least chipmunk X X 

Peromyscus maniculatus Deer mouse X   a

 Species that were identified as present on the property based on visual observation, calls, or evidence of recent presence are

indicated with an “X”. 

b

 Dash = not observed. 

Source: AES, 2010; MWH, 2008a,b,c; MWH, 2009. 
 3-71 

1 The bald eagle (Haliaeetus leucocephalus) is listed as a threatened species by the State of 

2 Idaho, but is no longer a Federally listed species. It nests in trees along the Snake River 

3 northeast and southeast of the proposed EREF site and winters near open water (IDFG, 2005; 

4 FWS, 2007). Foraging is generally near rivers, lakes, or other water bodies. Bald eagles do not 

5 nest in the vicinity of the proposed EREF, and winter habitat does not occur in the vicinity. 

6 

7 Species of concern that were observed on the EREF property include the long-billed curlew 

8 (Numenius americanus), ranked as an imperiled breeding population in the State and BLM 

9 watch list; Brewer’s sparrow (Spizella breweri), ranked as a vulnerable breeding population in 

10 the State and BLM regional/State imperiled; grasshopper sparrow (Ammodramus savannarum), 

11 ranked as an imperiled breeding population in the State and BLM watch list, which are all 

12 species of conservation concern (FWS, 2008) and BLM species of special concern. 

13 

14 Greater sage-grouse (Centrocercus urophasianus) was added to the Federal list of candidate 

15 species by the U.S. Fish and Wildlife Service (FWS) on March 5, 2010. The FWS determined 

16 that listing the sage-grouse as a protected species under the Endangered Species Act was 

17 warranted but precluded by the need to list higher priority species. Sage-grouse is also a 

18 species of conservation concern in Idaho and ranked as imperiled in the State and BLM 

19 rangewide/globally imperiled. The proposed EREF property appears to be located within the 

20 annual range of a local sage-grouse population, and sage-grouse evidently use the site. Sage21 grouse were observed, and male sage-grouse were heard just north of the EREF property 

22 during surveys in 2008 (MWH, 2008a), and evidence of the presence of sage-grouse was 

23 observed on the property in 2008 and 2009 (MWH, 2008b, 2009). In June 2008, sage-grouse 

24 pellets (droppings), feathers, and a roost used by sage-grouse were found in sagebrush habitat 

25 on the property (MWH, 2008b). In January 2009, sage-grouse tracks were found in the 

26 sagebrush habitat on the property and the irrigated crops area of the property; in April 2009, 

27 sage-grouse feathers were found at three locations in sagebrush habitat on the property (MWH, 

28 2009). In April 2010, old sage-grouse pellets were found in sagebrush habitat on the property 

29 (North Wind, 2010). No greater sage-grouse leks (breeding areas) were found during surveys 

30 of the proposed property on May 6–7, 2008 (MWH, 2008a) and April 2829, 2010 (North 

31 Wind, 2010). Recommended survey dates are early March to early May (Connelly et al., 2003); 

32 specifically, lek surveys should be conducted March 25 through April 30 for low elevation areas 

33 and April 5 through May 10 for higher elevations (ISAC, 2006). At approximately 5200 feet 

34 (1600 meters) MSL, the EREF property could be considered a high elevation site. The nearest 

35 known breeding ground (lek) is 5.6 kilometers (3.5 miles) from the EREF site, and numerous 

36 leks are located within 16 kilometers (10 miles) (IDFG, 2009b). Key sage-grouse habitat occurs 

37 in the vicinity of the EREF property (IDFG, 2009b; ISAC, 2006). 

38 

39 Sage-grouse have experienced long-term declines throughout their range, which includes much 

40 of the western United States. These declines are associated in large part with the loss and 

41 degradation of sagebrush habitat. Sagebrush is an important component of sage-grouse 

42 breeding, nesting, and winter habitat. The Idaho populations of sage-grouse declined at an 

43 average rate of 3.0 percent per year from 1965 to 1984, but declines from 1985 to 2003 

44 averaged only 0.1 percent per year (Connelly et al., 2004). 

45 

46 The proposed EREF property is located within the Upper Snake Local Working Group Planning 

47 Area, which is within sage-grouse Management Zone IV. Since 1996, sage-grouse populations 

48 in the Upper Snake Local Working Group Planning Area appear to be stable (USSLWG, 2009). 
 3-72 

1 Male lek attendance was up slightly in 2009 from 2008. In the Upper Snake Planning Area, the 

2 average males per lek in 2009 was 15, a drop from 19 in 2008 and 24 in 2007. Total males 

3 counted on leks in the Upper Snake Planning Area (on leks counted each year) was 1465 in 

4 2009, 1366 in 2008, and 2052 in 2007. 

5 

6 Productivity measured as chicks per hen (chicks alive in September and October) is strongly 

7 influenced by weather. Idaho sage-grouse productivity in 2008 was 1.48 chicks per hen, which 

8 was slightly lower than the previous 5-year average of 1.93 (ISACTAT, 2010). However, in 

9 2009, productivity was 2.0, slightly higher than previous 5-year average of 1.88 

10 (ISACTAT, 2010). In the Upper Snake Planning Area, productivity is increasing with a chick/hen 

11 ratio of 2.17 in 2009, 1.84 in 2008, and 1.16 in 2007 (ISACTAT, 2010). A chicks/hen ratio of 

12 2.25 or more generally results in a stable to increasing population. 

13 

14 The major threats to sage-grouse in Idaho are the loss, degradation, and fragmentation of 

15 sagebrush habitat (Connelly et al., 2004). Alteration of historical fire regimes, conversion of 

16 land to farming or intensive forage production for livestock, water developments, herbicide and 

17 pesticide use, establishment of invasive species, urbanization, energy development, mineral 

18 extraction, and recreation are all factors that contribute to sagebrush habitat degradation 

19 (Connelly et al., 2004). Restoration of disturbed areas should include sagebrush, native forbs 

20 (especially legumes), and native bunchgrasses to provide suitable breeding habitat for sage21 grouse (USSLWG, 2009). Fences may be a source of sage-grouse mortality unless visibility is 

22 increased by flagging or other means (USSLWG, 2009). Noxious weeds invade sagebrush 

23 steppe plant communities and displace desirable species, change fire frequencies, and reduce 

24 the value of the habitat for sage-grouse (USSLWG, 2009). 

25 

26 Many sage-grouse populations in Idaho are migratory. Sage-grouse occur year-round on the 

27 INL site and migrate between leks, nesting areas, late brood-rearing habitat (June to early 

28 November), and winter habitat (BLM/DOE, 2004). Nesting sites have been known to be up to 

29 18 kilometers (11 miles) from leks. Important characteristics for winter habitat include 

30 topographic diversity and a diversity of sagebrush heights. DOE, the BLM, and the Idaho 

31 Department of Fish and Game all participate in and follow the Idaho Sage-Grouse Advisory 

32 Committee’s Conservation Plan for the Greater Sage-Grouse in Idaho (ISAC, 2006) and will 

33 continue to follow this document. 

34 

35 Species of conservation concern that occur in the region and are likely to occur on the EREF 

36 property include Townsend’s big-eared bat (Corynorhinus townsendii), ranked as vulnerable in 

37 the State and BLM regional/State imperiled. Lava tube caves approximately 8 kilometers 

38 (5 miles) from the property are used by Townsend’s big-eared bat as roosts and hibernacula 

39 (IDFG, 2009c). The bats likely forage for insects above the sagebrush steppe habitat. The 

40 ferruginous hawk (Buteo regalis), a migratory species, is ranked as a vulnerable breeding 

41 population in the State and BLM regional/State imperiled. Ferruginous hawks, including a nest, 

42 have been observed within 8 kilometers (5 miles) of the proposed site (IDFG, 2009c). The prey 

43 species in western shrubsteppe habitats primarily include black-tailed jackrabbit, ground 

44 squirrels, and pocket gophers. Ferruginous hawk nests tend to be located on the ground or in 

45 relatively isolated trees (Dechant et al., 1999). The pygmy rabbit (Brachylagus idahoensis) is 

46 ranked as imperiled in the State and BLM rangewide/globally imperiled. This burrowing species 

47 has been frequently observed on the INL site (S.M. Stoller Corporation, 2001). The sharp-tailed 

48 grouse (Tympanuchus phasianellus) is known to occur in the vicinity of the proposed EREF site 
 3-73 

1 (IDFG, 2010) and occupies shrub and grass habitats (IDFG, 2005). The sharp-tailed grouse 

2 does not occur throughout the Upper Snake River Plain, and its distribution in the proposed 

3 EREF site area is somewhat limited (IDFG, 2005). 

4 

5 3.8.4 Wetlands 

6 

7 Wetlands are “areas that are inundated or saturated by surface or ground water at a frequency 

8 and duration sufficient to support, and that under normal circumstances do support, a 

9 prevalence of vegetation typically adapted for life in saturated soil conditions” (USACE, 1987). 

10 No wetlands occur on or adjacent to the EREF property (FWS, undated; Joyner, 2008). No 

11 aquatic habitats, such as streams, rivers, lakes, or ponds, are present on or adjacent to the 

12 property. Surface water on and near the property consists of intermittent and ephemeral 

13 drainages that carry flows following storms and typically dissipate due to infiltration and 

14 evapotranspiration (USGS, 1964; NRCS, 2009). A drainage in the southwestern corner of the 

15 property may occasionally convey surface water off the property. A small impoundment on this 

16 drainage occasionally contains surface water following storms. Small wet areas in the irrigated 

17 cropland and near the potato shed occasionally receive water from agricultural operations and 

18 support such species as cattail (Typha sp.) and spikerush (Eleocharis sp.), as well as providing 

19 potential breeding areas for the tiger salamander (Ambystoma trigrinum). Permanent surface 

20 waters nearest to the property are the Snake River, about 32 kilometers (20 miles) to the east, 

21 Mud Lake and Market Lake, about 32 kilometers (20 miles) to the northeast, and the Big Lost 

22 River, about 32 kilometers (20 miles) to the west. 

23 

24 3.8.5 Environmentally Sensitive Areas 

25 

26 Three State wildlife management areas are located about 32 kilometers (20 miles) north27 northeast of the EREF property. Market Lake State Wildlife Management Area is managed 

28 primarily to provide habitat for waterfowl; the North Lake State Wildlife Management Area and 

29 Mud Lake Wildlife Management Area are managed for fish and wildlife resources. Hell’s Half 

30 Acre WSA (BLM), immediately south of US 20, is a 26,790-hectare (66,200-acre) area of lava 

31 flows with sparse vegetation (BLM, 2008). Camas National Wildlife Refuge, about 32 kilometers 

32 (20 miles) north, includes lakes, ponds, and marshes. 

33 

34 3.9 Noise 

35 

36 This section describes the existing conditions at the proposed EREF site with respect to 

37 anthropogenic sources of noise, characterizes the geography and land cover with respect to 

38 noise propagation and attenuation, and identifies receptors that may be impacted by noise 

39 generated during preconstruction, construction, operation, or decommissioning of the proposed 

40 EREF. Existing noise regulatory controls and their respective enforcement authorities are also 

41 discussed. 

42 

43 Sound is a physical phenomenon and form of energy that can be described and measured and 

44 represented with precise mathematical expressions. Noise, on the other hand, is defined 

45 generally as any unwanted sound. Recognition of sound is based on the receptor’s objective 

46 and reproducible response to sound’s primary physical attributes: intensity (perceived by a 

47 receptor as loudness), frequency (perceived as pitch), frequency distribution and variation over 

48 time, and duration (continuous, sporadic [rhythmic], or impulsive). Perception of sound, 
 3-74 

1 however, is subjective and circumstantial. Sounds that are soothing to some are annoying to 

2 others, and sounds barely noticed and generally ignored in one circumstance may be 

3 considered highly objectionable in another. Sound levels that are acceptable during daytime 

4 hours are often unacceptable during nighttime hours. 

5 

6 3.9.1 Expected Sound Propagation Characteristics at the Proposed EREF Site 

7 

8 Sound propagation follows the inverse square law: the intensity of a sound wave decreases 

9 inversely with the square of the distance between the source and the receptor. Thus, doubling 

10 the distance between a receptor and a sound source reduces the intensity of the sound to one11 fourth of its initial value, and tripling the distance results in one-ninth the original intensity, etc. 

12 

13 Throughout much of the continental United States, land cover results in attenuation of sound 

14 originating at or near ground level at a rate of 6 decibels for every doubling of distance between 

15 source and receptor. At a typical semiarid steppe with sparse vegetation and exposed, hard 

16 surface soils or rock, the ground surface would be expected to act primarily as a reflective 

17 surface rather than an absorptive surface, resulting in minimal attenuation of sound as it 

18 propagates from its source. However, the land surface composition around the proposed EREF 

19 does not represent a typical semiarid desert steppe. Native vegetation, primarily sage and 

20 cacti, exists in natural areas. However, crested wheatgrass, which had been introduced into the 

21 area some years ago, has spread throughout the area to a great extent, and, with the exception 

22 of small areas of basalt outcropping, the entire land surface of natural areas is now covered with 

23 a natural or introduced vegetative cover throughout the growing season. Other land areas 

24 surrounding the proposed EREF site that are currently in agricultural cultivation for potatoes or 

25 barley and that would continue to be used for those purposes after the proposed EREF 

26 becomes operational are also nearly fully covered with vegetation during much of the crop27 growing cycle. Thus, given these circumstances and current and future surrounding land uses, 

28 it is reasonable to expect that the ground surface would be relatively sound-absorptive and that 

29 SPL attenuations would be at the average of 6 decibels with every doubling of distance from the 

30 source. 

31 

32 3.9.2 Existing Sound Sources and Potential Receptors at the Proposed EREF Property 

33 

34 Current activities at the proposed EREF property and on the surrounding land parcels are 

35 primarily agricultural. Noise sources related to current land use include an irrigation pump 

36 located in the approximate center of the site, the only identified significant anthropogenic point 

37 source, and machinery and equipment used seasonally to prepare the fields and to plant and 

38 harvest the crops. Truck transport of harvested crops to area processing plants represents 

39 another seasonal source. 

40 

41 The southern border of the proposed EREF property is defined by US 20, the only major 

42 transportation corridor in the immediate vicinity of the site. In addition to being used for 

43 commerce, US 20 is currently used by many employees of INL, located immediately west of the 

44 proposed EREF property, to commute between the laboratory and their homes in Idaho Falls. It 

45 is expected that US 20 will also be the primary route for the majority of employees of the 

46 proposed EREF once it becomes operational. Section 3.10 provides additional information 

47 about existing traffic patterns for US 20. No other significant anthropogenic sound sources exist 

48 in the immediate vicinity of the proposed EREF site. 

49 
 3-75 

1 The nearest human receptors are farm workers who may periodically be in agricultural fields 

2 bordering the proposed property (presumably only during daylight hours), hikers who may 

3 frequent a trail located on the BLM WSA about 0.5 kilometer (0.3 mile) southwest of the 

4 proposed property, and residents; the nearest residence was estimated to be located 

5 7.7 kilometers (4.8 miles) east of the site on a parcel bordering US 20. No sensitive human 

6 receptors were identified. Individuals traveling on US 20 are not considered to be human 

7 receptors because of the short time during which they would be within a critical distance of any 

8 EREF sound source. The nearest community was identified as Idaho Falls, approximately 

9 32 kilometers (20 miles) east of the site. Archeological sites at the Wasden Complex were 

10 identified at a distance of 1 kilometer (0.6 mile) from the proposed property. It is also presumed 

11 that indigenous wildlife would use the site and the vicinity throughout construction and operation 

12 and that cattle grazing would continue to occur on adjacent land parcels that are not involved in 

13 crop production. Cattle grazing may also be allowed on fallow portions of the proposed EREF 

14 property (excluding the industrial portion of the site) once construction is completed. AES 

15 identified one irrigation pump as the only anthropogenic point source of any significance and 

16 identified traffic on US 20 (which borders the site on its south boundary) as the only 

17 anthropogenic line source of note within the vicinity of the proposed site. Once construction of 

18 the proposed facility starts, the irrigation pump’s operation will be discontinued. However, that 

19 same groundwater source is likely to be fitted with a different pump to provide water for 

20 construction-related activities. 

21 

22 3.9.3 Noise Regulatory Controls 

23 

24 Regulations addressing sound, or more precisely what society considers noise, exist for noise 

25 sources that originate or propagate on or above the ground surface. Federal noise standards 

26 have been established under the Noise Control Act of 1972 for transportation and construction 

27 activities as well as for a variety of products. The Noise Control Act and subsequent Federal 

28 legislation (Quiet Communities Act of 1978, 42 U.S.C. 2901-4918) delegate the authority to 

29 regulate noise to State and local governments. Although there has been no formal noise control 

30 program functional at the Federal level since 1981, Federal noise standards have served as the 

31 basis for State and local regulations and ordinances addressing noise. Such State and local 

32 controls initially focused on construction or industrial noise but have evolved to also include 

33 noise control strategies in building codes to protect occupants from both exterior noise and 

34 noise generated within the structure. State and local regulations are typically enforced at the 

35 municipal or county level under broadly written nuisance statutes. 

36 

37 In addition to technical standards, the EPA has also published numerous guidance manuals for 

38 conducting community noise surveys, establishing acceptable levels of noise control at the 

39 community level, and enforcing those noise limits (e.g., EPA, 1980). Because of the increased 

40 sensitivity of most individuals to sound at night, a 10-decibel weighting factor is often added to 

41 the measured nighttime sound level to establish an equivalent sound level, or Leq, that is then 

42 compared with the established standards. A day-night maximum average sound level 

43 (represented as Ldn or DNL) of 55 A-weighted decibels has been established as sufficient to 

44 protect the public from the effects of broadband environmental noise in quiet settings and 

45 residential neighborhoods (EPA, 1974). EPA guidelines also recommend that the Leq (a sound 

46 level maintained continuously over a 24-hour period) be limited to 70 dBA or less over a 40-year 

47 period to protect the general population against hearing loss from nonimpulsive noise. 

48 
 3-76 

1 In addition to the EPA, other Federal agencies have issued circumstantially specific noise 

2 standards. The Federal Aviation Administration, in conjunction with the Federal Interagency 

3 Committee on Urban Noise, has issued land-use compatibility guidelines indicating that a yearly 

4 Ldn of less than 65 A-weighted decibels is compatible with residential land uses and that, if a 

5 community determines it is necessary, levels up to 75 dBA may be compatible with residential 

6 uses and transient lodgings if such structures also incorporate noise-reduction construction 

7 technologies (see 14 CFR Part 150, Appendix A). The U.S. Department of Housing and Urban 

8 Development (HUD) has also published noise guidance: levels of 65 Ldn or less (measured at 

9 the outside of an occupied residence) are acceptable under all circumstances, levels between 

10 65 and 75 dBA are normally unacceptable but could become acceptable with the introduction of 

11 appropriate sound attenuation measures, and levels above 75 dBA are always unacceptable 

12 (Table 3-21). HUD has also promulgated standards (see 24 CFR Part 51, Subpart B) for 

residential noise that apply only to activities for which HUD provides assistance.15 13 Finally, 

14 regulations governing the amount of noise to which workers can be exposed in the workplace 

15 are promulgated and enforced by the Occupational Safety and Health Administration (OSHA) 

16 (see 29 CFR Part 1910, Subpart G). 

17 

18 Noise limits in the ordinances are generally applied at the exterior of the nearest resident or 

19 sensitive receptor, such as a school or hospital, within a minimum distance, typically less than 

20 2 kilometers (less than 1 mile). Limits on broadband noise in the various ordinances range from 

21 45 to 65 dBA, with levels of about 50 dBA being the most frequently cited. Separate limits on 

22 low-frequency noises, which range up to 75 decibels, are included in many of the ordinances. 

23 A number of penalties, usually 5 dBA, are applied to these basic values to reduce impacts from 

24 annoyances such as evening operations, steady pure tones, or repetitive impulse sounds. 

25 There are no quantitative noise-limit regulations at the city, county, or State levels in Idaho; 

26 however, complaints about obtrusive noise that are made to local law enforcement authorities 

27 can be addressed under general nuisance ordinances. 

28 

29 3.9.4 Noise Analyses Performed for the Proposed EREF 

30 

31 Measurements of extant sound levels at various locations along the proposed property 

32 boundary of the proposed EREF site were performed by AES (AES, 2010). Background noise 

33 levels were established by using an A-weighted sound meter and data collected over six 

34 24-hour periods at six locations from June 1 through 7, 2008 (see Figure 3-31). Data were 

35 collected and managed in accordance with applicable American Society of Testing and 

36 Materials (ASTM) standards (see ASTM Standard E-1686-03; ASTM, 2003). Average 

37 background noise levels ranged from 30.4 to 78.2 dBA; they are displayed in Table 3-22. The 

38 majority of measured levels met both the HUD and EPA standards. Levels exceeding 50 dBA 

39 were measured near US 20 during periods of heavy truck traffic, within the vicinity of the 

40 irrigation pump, and in the northeast corner of the proposed property during a windy (more than 

41 40 kilometers or 25 miles per hour) period. As a contextual reference, Figure 3-32 presents 

42 levels representative of common everyday sounds. 

43 

44 Measurements of background noise levels conducted by AES are consistent with previously 

45 published measurements and estimates for the nearby INL (DOE, 2005) and are therefore 

46 considered to be an accurate representation of extant conditions at the site. For the general 

 

15 For additional details, consult the HUD Web site: http://www.hudnoise.com/. 
 3-77 

Table 3-21 HUD Land Use Compatibility Guidelines 

 Day-Night Sound Pressure Level or Ldn (dBA) 

Land Use Category Clearly 

Acceptable 

Normally 

Acceptable 

Normally 

Unacceptable 

Clearly 

Unacceptable 

Residential <60 60–65 65–75 >75 

Livestock farming <60 60–75 75–80 >80 

Office buildings <65 65–75 75–80 >80 

Wholesale, industrial, 

manufacturing, and utilities <70 70–80 80–85 >85 

Source: HUD, 2009.

1 

2 area surrounding the INL site (which would include the proposed EREF property), the county3 wide Ldn, based on population density, was estimated to be the highest – at 39 dBA – in 

4 Bonneville County. It was estimated to be 35 dBA in Bingham and Jefferson Counties, a level 

5 representative of typical rural areas, and 30 dBA in Butte County, a level representative of the 

6 natural background noise level of a wilderness area. Noise measurement data obtained from 

7 locations within 15 meters (50 feet) of US 20 showed traffic noise ranged from 64 to 86 dBA, 

8 with buses identified as the primary source, contributing from 71 to 80 dBA. 

9 

10 3.10 Transportation 

11 

12 This section describes the existing transportation infrastructure at and in the region of the 

13 proposed EREF site. The proposed EREF site is served directly and exclusively by road. 

14 There are no plans for rail access to the site. AES has stated that local roads and highways 

15 would be the sole means for conveying workers and materials to and from the site and region 

16 (AES, 2010). Nearby rail and air transportation routes also serve the region, but there are no 

17 viable water transportation routes. Figure 1-1 shows transportation routes near the proposed 

18 EREF site. 

19 

20 3.10.1 Roads 

21 

22 The site lies immediately north of US 20, approximately 32 kilometers (20 miles) west of Idaho 

23 Falls (and the junction of US 20 and I-15). US 20 is predominantly a two-lane highway 

24 traversing east-west between Idaho Falls to the east and the junction with US 26 to the 

25 northwest of Atomic City. Access to the proposed EREF site would be from one or two planned 

26 access roads to US 20. Control and public access to the access road(s) have yet to be 

27 specified. All traffic traveling to and from the proposed EREF (construction workers, employees, 

28 and shipments) would use one of these access roads (AES, 2010). 

29 

30 US 20 intersects I-15 at Idaho Falls, and I-15 and US 20 (north of Idaho Falls) would serve as 

31 the main routes between the proposed EREF (via US 20 West) and population centers to the 

32 north and south of Idaho Falls. I-15 is the major north-south artery in the region and would 

33 serve as the primary route for all incoming and outgoing truck shipments. The nearest interstate 

34 access to the west is I-84, approximately 296 kilometers (184 miles) away at its closest point by 

35 way of US 20. Idaho Falls is also served by US 26 and US 91. 
 3-78

1 

Figure 3-31 Noise Measurement Locations at the Proposed EREF Property (modified from AES, 2010) 2 
 3-79 

Table 3-22 Extant Sound Levels at the Proposed EREF Property as Measured by AES 

Measurement 

Location Location Description Average Sound Level (Leq) 

Location 1 Northwest corner of proposed property 30.4 dBA 

Location 2 North-central boundary of proposed property 39.8 dBA 

Location 3 Northeast corner of proposed property (high wind conditions) 54.7 dBA 

Location 4 Southeast corner nearest to proposed facility 37.1 dBA 

Location 5 South boundary of proposed property next to US 20 57.5 dBA 

Location 6 Southwest corner nearest to proposed facility 31.1 dBA 

Location 7 Irrigation well pump in northeast portion of proposed property 78.2 dBA 

Source: AES, 2010.

1 

2 

3 Figure 3-32 Sound Pressure Levels (dB) of Common Sources (All data reflect 

4 sound propagation in air and imply a human receptor.) (EPA, 1978) 

5 

6 As shown in Table 3-23, US 20 has an average daily traffic volume of 2210 vehicles in the 

7 vicinity of the proposed EREF site (mean monthly average from July 2008 to June 2009). 

8 A significant portion of this traffic is morning and afternoon commuting to and from INL 

9 (NRC, 2009; ITD, 2010e). This volume could increase if the INL park-and-ride bus system is 
 3-80 

discontinued.16 1 The speed limit on US 20 in the vicinity of the proposed EREF site is 

2 104.6 kilometers per hour (65 miles per hour); the average vehicle speed for all of 2009 was 

3 103.8 kilometers per hour (64.5 miles per hour) (ITD, 2010b). 

4 

5 The relationship between the current/anticipated traffic volume on US 20 (in the vicinity of the 

6 proposed EREF site) and the road’s design capacity is unknown, because the road was 

7 established before it became a major commuter route to INL. The Idaho Transportation 

Department (ITD) notes that the road was not designed for a specific level of service (LOS)17 8 

9 and is not engineered to accommodate the current traffic flow. However, the LOS is considered 

10 high for a two-lane road (NRC, 2009). Based on average traffic volumes, average traffic 

11 speeds, and the highly directional nature of peak flow (largely consisting of INL commuters), the 

12 LOS on US 20 is estimated to be high density but stable flow during peak periods and free flow 

13 at all other times (AASHTO, 1994; ITD, 2010b,c,e). 

14 

15 There is a local perception that US 20 between Idaho Falls and INL is unsafe (likely due to a 

16 history of high-profile accidents) and would get worse if the proposed EREF is licensed 

17 (NRC, 2009). However, ITD notes that the accident rate on the affected stretch of US 20 is 

18 actually lower than the statewide average and base area rates (ITD, 2005; NRC, 2009). In 

19 2005, ITD performed an internal study of potential safety improvements for US 20 (i.e., widening 

20 and/or passing lanes) in the vicinity of the proposed EREF site (ITD, 2005, 2010c). At that time, 

21 funding was not available to implement the studied improvements (primarily selective passing 

22 lanes), and ITD does not anticipate a funding allocation in the foreseeable future (NRC, 2009). 

23 

24 According to ITD, US 20 is overbuilt (i.e., engineered to accommodate a higher LOS than 

25 presented by current traffic levels) to a distance of 8 kilometers (5 miles) west of Idaho Falls to 

26 accommodate growth at INL that was anticipated but did not materialize (NRC, 2009). This 

27 likely improves capacity and LOS for approximately 25 percent of the segment between Idaho 

28 Falls and the proposed EREF site. There are currently no plans to expand US 20 between 

29 Idaho Falls and the proposed EREF site, and no large projects are anticipated near the 

30 proposed site (NRC, 2009). However, the 18-mile stretch of US 20 from Idaho Falls to the 

31 Bonneville-Butte county line (west of the proposed EREF site) was resurfaced during the 

32 summer of 2010. ITD also noted that the need to upgrade or rebuild the interchange of US 20 

33 and I-15 (through which all shipping to and from the proposed EREF would flow) may be 

34 accelerated by increased traffic from the proposed EREF, since the geometry of the interchange 

35 is not favorable and the right-of-way is limited (NRC, 2009). Currently, there are no funded 

36 plans for this work. 

37 

38 US 20 between Idaho Falls and the proposed EREF site is subject to chronic weather-related 

39 closure, primarily in winter months because of unfavorable road conditions, snow drifts, and low 

40 visibility (NRC, 2009; ITD, 2010d). The section of US 20 subject to closure extends from 

41 approximately 5 miles west of Idaho Falls to the junction of US 20 and US 26 near INL 

 

16 During a consultation meeting in June 2009, the Idaho Transportation Department noted that INL has 

discussed discontinuing the bus system as a cost-saving measure, but that no decisions had been 

made (NRC, 2009). 

17 LOS is a measure used by traffic engineers to assess the service quality of road infrastructure, taking 

into account factors such as traffic volume, road capacity, traffic speed, freedom to pass, and driver 

comfort and convenience. 
 3-81 

Table 3-23 Annual Average Daily Traffic (AADT) on Major Roads near 

the Proposed EREF Site 

Road Direction Location AADT 

US 20 E-W At US 26 near Atomic City 1900 

US 20 E-W Near proposed EREF site 2210a

US 20 E-W Idaho Falls west city limit 9900 

US 20 E-W Immediately east of I-15 29,733a

US 20 N-S Idaho Falls north city limit 16,000 

I-15 N-S North of Idaho Falls 5400 

I-15 N-S At US 20 18,000 

I-15 N-S South of Idaho Falls (65th Street) 20,000 

US 26 E-W Atomic City 1100 

a

 Average July 2008–June 2009. Source: ITD, 2009b. 

Source: ITD, 2009a. 

1 

2 (mileposts 264 to 301), encompassing the proposed EREF site. These closure points are the 

3 most convenient for ITD, include the stretches of US 20 that are the most problematic, and 

4 include few access points via intersecting county roads. Road closures typically last from 

5 6 hours to 1 day, with the maximum closure occurring only once or twice in the last 5 years. 

6 About five closures of US 20 are anticipated in a typical snow year. ITD is currently working 

7 with INL to install snow fencing to the west of the proposed EREF site (and is considering 

8 locations east of the proposed site), but this work will be gradual, subject to private landowner 

9 approval, and dependent on the annual ITD District 6 operating budget. Where snow fencing is 

10 not an option (and landowners approve), trenching can be an effective method of snow drift 

11 reduction. ITD has worked with the local school system to provide a plow escort and maintain 

12 access (i.e., for school buses) during road closures; ITD would likely work with the proposed 

13 EREF to facilitate shift changes that occur during road closures (ITD, 2010c,d). 

14 

15 Fire-related closures of US 20 are possible, but are less frequent and shorter in duration than 

16 weather-related closures. Most fire-related closures occur near INL; ITD has observed few fires 

17 to the east of the proposed EREF site. Dust storms occurring after fires (in the spring) can 

18 create localized drifting problems (ITD, 2010d). 

19 

20 Load limits on US 20 (between Idaho Falls and the proposed EREF site) and I-15 are controlled 

21 by ITD. The three-axle gross vehicle weight limits are 29,257 kilograms (64,500 pounds) on 

22 US 20 and 31,979 kilograms (70,500 pounds) on I-15 (AES, 2010; ITD, 2010a). Overweight 

23 permits can be issued for vehicles and/or loads exceeding this limit (ITD, 2007). 

24 

25 The current traffic volume on I-15 in the vicinity of Idaho Falls (and the junction with US 20) is 

26 approximately 18,000 vehicles per day (see Table 3-23). Design capacities for highways are 

27 not typically calculated, as capacities are considered high by default. However, the LOS on I-15 

28 in the vicinity of Idaho Falls has been described as free flow (typically), with the LOS south of 
 3-82 

1 the city dropping to reasonably free flow or stable during peak periods (ITD, 2010c). Currently 

2 there are no plans to make any upgrades to I-15 in the vicinity of Idaho Falls. 

3 

4 There is currently no road or parking infrastructure at the proposed EREF site. 

5 

6 3.10.2 Rail 

7 

8 There is no direct rail access to the proposed EREF site, and there are no plans to perform any 

9 shipping operations by rail (AES, 2010). Nevertheless, Union Pacific provides three branches of 

10 freight rail service through Idaho Falls (Montana Main, Yellowstone, and Aberdeen), with the 

11 nearest access being approximately 32 kilometers (20 miles) to the east (AES, 2010; 

12 ITD, 1996). 

13 

14 In addition, a DOE-owned spur that connects at the Scoville Siding provides active freight 

15 service to the nearby INL, approximately 40 kilometers (25 miles) to the west of the proposed 

16 EREF site. A regional short line carrier, Eastern Idaho Railroad, connects areas north and east 

17 of Idaho Falls to Union Pacific lines (AES, 2010). 

18 

19 3.10.3 Air 

20 

21 Two airports serve the region of the proposed EREF site. The Idaho Falls Regional Airport, 

22 approximately 32 kilometers (20 miles) east of the proposed site, is operated by the City of 

23 Idaho Falls. It provides regularly scheduled regional passenger service to Denver, Salt Lake 

24 City, Boise, Seattle, and Las Vegas. The airport has two runways that are different sizes to 

25 accommodate commercial and private aviation. Approximately 32 kilometers (20 miles) to the 

26 west of the proposed EREF site is Midway Airport in Atomic City. This airport is used 

27 exclusively by private planes (AES, 2010). 

28 

29 In addition to these small regional airports that serve eastern Idaho is the Salt Lake City 

30 International Airport, which is approximately 336 kilometers (210 miles) south of Idaho Falls. 

31 

32 3.10.4 Water 

33 

34 Although the Snake River flows through Idaho Falls east of the proposed EREF site, there are 

35 no ports or viable water transportation routes that serve the region.

36 

37 3.11 Public and Occupational Health 

38 

39 This section describes background radiation exposure in general and potential local influences 

40 near the proposed EREF. Potential health effects from exposure to radiation and to chemicals 

41 relevant to the proposed EREF are discussed as well. Several different media in and around 

42 the proposed EREF site contain radionuclides and chemicals that are both naturally occurring 

43 and anthropogenic (i.e., human-made) from historical and current operations at the nearby INL 

44 and from atomic bomb testing fallout. These media include soil, surface water, sediment, 

45 groundwater, and air. This section describes these radiological and chemical background and 

46 anthropogenic levels in terms of public and occupational exposure and health. It also 

47 summarizes the cancer incidence and death rates in the region, which were sufficient to 
 3-83 

1 establish baseline information for the analysis in Chapter 4 of the impacts on public and worker 

2 health that may be a result of preconstruction and the proposed action. 

3 

4 3.11.1 Background Radiological Exposure 

5 

6 Section 3.11.1.1 discusses the exposure from general background radiation that includes 

7 naturally occurring sources and man-made sources, except the exposure from INL operations. 

8 Offsite radiological exposures from the operation of INL are discussed in Section 3.11.1.2. 

9 

10 3.11.1.1 General Background Radiation 

11 

12 Humans are exposed to ionizing radiation from many sources in the environment, as shown 

13 below. Radioactivity from naturally occurring elements in the environment is present in soil, 

14 rocks, and living organisms. A major proportion (68 percent) of natural background radiation 

15 comes from naturally occurring radon. Together, these natural radiation sources contribute 

16 approximately 3.1 millisieverts (310 millirem) per year to the average total radiation dose that 

17 members of the general public annually receive (NCRP, 2009). 

18 

19 Ubiquitous background radiation contributes 50 percent of the average total radiation doses 

20 members of the general public receive. The remaining 50 percent of the average total radiation 

21 dose is associated with medical (48 percent) and industrial (2 percent) sources. As shown in 

22 Figure 3-33, approximately 48 percent of the annual background radiation dose (corresponding 

23 

24 

Radiation Dose and Dose Equivalent 

The exposure to radioactive material results in a radiation dose to the body. Radiation dose can 

result from external (outside the body) exposures such as gamma radiation emanating from the 

soil as well as internal exposures resulting from ingestion, such as potassium-40 (40K) that resides 

naturally in bananas. The amount of energy deposited in matter is called the radiation dose and 

has SI units of gray (Gy) 

In order to account for the damage done by different types of radiation, the term “dose equivalent” 

was developed. This allows different radiation doses from different radiation types to be 

compared. The radiation dose equivalent has SI units of sieverts (Sv). 

Depending on its chemical form, radioactive material may transport to different parts of the body 

and reside in different organs when it is either ingested or inhaled. Each of these organs has 

different sensitivity to radiation. In addition, the radioactive material may reside in the body for 

many years. Therefore, to derive a whole body radiation dose equivalent, one must combine the 

effects of different radiation types with different organ sensitivities and consider the amount of time 

the radioactive material remains in the body. The term committed dose equivalent is used to 

describe the radiation dose equivalent a person will receive due to the radioactive material 

residing in the body after inhaling or ingesting radioactive material. This whole body dose 

equivalent has SI units of sieverts (Sv). 

For brevity, it is common to refer to the whole body radiation dose equivalent as just the radiation 

dose. When the term radiation dose is used in this EIS, it refers to the total whole body committed 

radiation dose equivalent and will be expressed in SI units of Sv and parenthetically in 

conventional units of rem where 100 rem = 1 Sv. 
 3-84 

1 

2 Figure 3-33 Percentage Contribution to the Effective Dose from All Sources of Radiation 

3 in the U.S. Population for 2006 (NCRP, 2009) (Reprinted with permission of the NCRP, 

4 http://NCRPonline.org.) 

5 

6 to 3.0 millisieverts [300 millirem]) is associated with medical sources, including computer 

7 tomography (24 percent), nuclear medicine (12 percent), interventional fluoroscopy (7 percent), 

8 and conventional radiograph/ fluoroscopy (5 percent). Consumer products and industrial and 

9 occupational sources of radiation comprise the remaining 2 percent (0.1 millisievert 

10 [10 millirem]) (NCRP, 2009). 

11 

12 3.11.1.2 Idaho National Laboratory 

13 

14 The location of the proposed EREF is within 8 kilometers (5 miles) of INL, a DOE laboratory in 

15 eastern Idaho. INL prepares an annual site environmental report for DOE summarizing 

16 environmental monitoring programs and other environmental activities at INL (DOE, 2007). 

17 Since the INL site is in such close proximity, the routine release of radioactive material from the 

18 INL would be considered part of the affected environment. 

19 

20 The radiological dose to the public surrounding the INL site is too small to be measured by 

21 available monitoring techniques. To show compliance with Federal regulations established to 

22 ensure public safety, the dose from INL site operations was calculated by using the amounts of 

23 radionuclides released during the year from INL site facilities that were reported and appropriate 

air dispersion computer codes. The noble gas krypton-85 (85 24 Kr) accounted for approximately 

58 percent of the total release, followed by tritium (3

H) with 25 percent and argon-41 (41 25 Ar) with 

16 percent of the total. The noble gas xenon-135 (135 26 Xe) contributed 1 percent. However, 

27 because these are noble gases, they contribute very little to the cumulative dose (affecting 

immersion only). Other than 41Ar and 3 28 H, the radionuclides contributing to the overall dose were 

29 0.01 percent of the total radionuclides released (DOE, 2007). 

30 

31 According to the 2007 INL site environmental report (DOE, 2007), the calculated maximum 

32 individual dose was 0.93 microsievert (0.093 millirem). The radionuclides contributing the most 

to this calculated dose were strontium-90 (90 33 Sr), which contributed 47 percent; isotopes of 
 3-85 

plutonium (plutonium-238 [238Pu], plutonium-239 [239Pu], and plutonium-240 [240 1 Pu]), which 

contributed 27 percent; isotopes of americium (americium-241 [241 2 Am] and americium-243 

[

243Am]), which contributed 15 percent; cesium-137 (137 3 Cs), which contributed 9 percent; and 

iodine-129 (129 4 I), which contributed 1 percent. For comparison, the calculated maximum 

5 individual doses for 2003, 2004, 2005, and 2006 were 0.04, 0.04, 0.08, 0.04 millirem, 

6 respectively (DOE, 2007). 

7 

8 As part of an oversight program for the INL, the State of Idaho maintains 12 high-pressure ion 

9 chambers (HPICs) that provide real-time radiation exposure rates. Data are collected by the 

10 Idaho Department of Environmental Quality via radiotelemetry and are available to the public 

11 on the World Wide Web. The HPIC closest to the proposed EREF site (Rover Met Tower) 

has recorded an average exposure rate of 3.55  10-9 ± 0.24  10-9 12 coulombs per kilogram per 

13 hour (13.75 ± 0.92 microroentgen per hour) over the last 3.5 years (AES, 2010). These 

14 recorded values are comparable with exposure measurements obtained from background 

15 locations (IDEQ, 2008). 

16 

17 3.11.2 Background Chemical Exposure 

18 

19 The location for the proposed EREF is on a site currently operated as a farm in an area 

20 characterized by farming and public lands. There are no known major sources of chemical 

21 exposure at this site that might impact the public. From the fall of 2007 to spring 2008, as part 

22 of soil characterization, AES collected 10 surface soil samples across the proposed site. The 

23 results of this sampling are presented in Section 3.6.4.2 and are summarized here. The 

24 samples were analyzed for metals, fluoride, pesticides, VOCs, and SVOCs (AES, 2010). All 

25 eight metals analyzed were within the range of local background areas. Only sporadic hits of 

26 trace levels of a few VOCs and SVOCs were found; they were mainly polycyclic aromatic 

27 hydrocarbons (PAHs) attributable to vehicle exhaust and other combustion sources. The only 

28 detection of a pesticide or herbicide compound in the samples was of trace levels (maximum 

29 0.0110 milligram per kilogram) of the substance chlorpropham, which is used to inhibit sprouting 

30 of potatoes in storage. 

31 

32 Regarding other media, regional air quality in Bonneville County is classified as “good” 

33 95.7 percent of the time and “moderate” 4.3 percent of the time, as discussed in Section 3.5.3. 

34 No surface water resources exist on the proposed site, as indicated in Section 3.7.1.1. Site 

35 groundwater has been tested for and found to be unimpacted by chemical contamination, 

36 including organic compounds, PCBs, pesticides, and metals, as discussed in Section 3.7.2.4. 

37 

38 3.11.3 Public Health Studies 

39 

40 3.11.3.1 Regulatory Requirements for Public and Occupational Exposure 

41 

42 NRC regulations in 10 CFR Part 20 identify maximum allowable concentrations of radionuclides 

43 in air and water above background at the boundary of unrestricted areas to control radiation 

44 exposures of the public and releases of radioactivity. The most restrictive maximum allowable 

concentration in air and water for uranium isotopes is 5  10-14 and 3 10-7 45 microcuries per cubic 

46 centimeter, respectively. Other 10 CFR Part 20 requirements are that the sum of the external 

47 and internal doses (Total Effective Dose Equivalent [TEDE]) for a member of the public may not 

48 exceed 1 millisievert per year (100 millirem per year), and the radiation levels at any 
 3-86 

1 unrestricted area should not exceed 0.02 millisievert (2 millirem) in any 1 hour and 

2 0.5 millisievert (50 millirem) in a single year. 

3 

4 In addition to keeping within NRC requirements, releases to the environment must comply with 

5 EPA standards in 40 CFR Part 190, Subpart B. These standards specify limits on the annual 

6 dose equivalent from normal operations of uranium fuel-cycle facilities (except mining, waste 

7 disposal operations, transportation, and reuse of recovered special nuclear and byproduct 

8 materials). The public dose limit for annual whole body and any organ is 0.25 millisievert 

9 (25 millirem), and for the thyroid it is 0.75 millisievert (75 millirem). 

10 

11 10 CFR 20.1201 limits the TEDE of workers to ionizing radiation. Table 3-24 provides 

12 occupational dose limits for radiation workers who work at nuclear facilities. 

13 

14 3.11.3.2 Health Effects from Radiological Exposure 

15 

16 Radiation interacts with the atoms that form cells. There are two mechanisms by which 

17 radiation affects cells: direct action and indirect action. In a direct action, the radiation interacts 

18 directly with the atoms of the DNA molecule or some other component critical to the survival of 

19 the cell. Since the DNA molecules make up a small part of the cell, the probability of direct 

20 action is small. Because most of the cell is made up of water, there is a much higher probability 

21 that radiation would interact with water. In an indirect action, radiation interacts with water and 

22 breaks the bonds that hold water molecules together and produces reactive free radicals that 

23 are chemically toxic and destroy the cell. The body has mechanisms to repair damage caused 

24 by radiation. Consequently, the biological effects of radiation on living cells may result in one 

25 of three outcomes: (1) injured or damaged cells repair themselves, resulting in no residual 

26 damage; (2) cells die, much like millions of body cells do every day, being replaced through 

27 normal biological processes and causing no health effects; or (3) cells incorrectly repair 

28 themselves, which results in damaging or changing the genetic code (DNA) of the irradiated 

29 cell. Stochastic effects, that is, effects that may or may not occur based on chance, may occur 

30 when an irradiated cell is modified rather than killed. The most significant stochastic effect of 

31 radiation exposure is that a modified cell may, after a prolonged delay, develop into a cancer 

32 cell. 

33 

34 The biological effects on the whole body from exposure to radiation depend on many factors, 

35 such as the type of radiation, total dose, time interval over which the dose is received, and part 

36 of the body that is exposed. Not all organs are equally sensitive to radiation. The blood-forming 

37 organs are most sensitive to radiation; muscle and nerve cells are relatively insensitive to 

38 radiation. Health effects may be characterized according to two types of radiation exposure: 

39 (1) a single accidental exposure to high doses of radiation for a short period of time (acute 

40 exposure), which may produce biological effects within a short time after exposure, and (2) long41 term, low-level overexposure, commonly called continuous or chronic exposure. High doses of 

42 radiation can cause death. Other possible effects of a high radiation dose include erythema, 

43 dry desquamation, moist desquamation, hair loss, sterility, cataracts, and acute radiation 

44 syndromes. Currently there are no data to unequivocally establish the occurrence of cancer 

45 following exposure to low doses and dose rates – below about 100 millisieverts 

46 (10,000 millirem) (NRC, 2004). 

47 
 3-87 

Table 3-24 Occupational Dose Limits for Adults Established by 10 CFR Part 20 

Tissue Dose Limit 

Whole body or any individual 

organ or tissue other than the 

lens of the eye 

More limiting of 0.05 Sv/yr (5 rem/yr) TEDE to whole body or 

0.5 Sv/yr (50 rem/yr) sum of the deep dose equivalent and the 

committed dose equivalent to any individual organ or tissue 

other than the lens of the eye 

Lens of the eye 0.15 Sv/yr (15 rem/yr) dose equivalent 

Extremities, including skin 0.50 Sv/yr (50 rem/yr) shallow dose equivalent 

1 

2 In estimating the health impacts from low dose or low dose rate exposure to occupational 

3 workers and the general public, the probability of a fatal cancer per unit of radiation exposure 

4 recommended by the EPA was used. The estimated probability for both workers and the public 

is 6  10-2 sievert-1 5 (EPA, 1999). 

6 

7 The National Program of Cancer Registries (NPCR) is the Centers of Disease Control and 

8 Prevention (CDC) State-based cancer control program. Under this program, States collect, 

9 manage, and analyze data about cancer incidence and mortality. The CDC and the National 

10 Cancer Institute release U.S. cancer statistics annually. Table 3-25 lists the cancer incidence 

11 and death rates for all cancers for 2002 to 2006 for Idaho and the United States. 

12 

13 3.11.3.3 Health Effects from Chemical Exposure 

14 

15 The primary hazardous chemicals of interest associated with the proposed EREF are uranium 

16 and hydrofluoric acid (HF). The latter is produced in the reaction of UF6, the form of uranium 

17 used in the enrichment process, with moisture in air. HF is an irritant gas that causes eye, 

18 nose, and skin irritation. Breathing high levels can also harm the lungs and heart 

19 (ATSDR, 2003). Irritant effects in humans, including respiratory track inflammation, begin to be 

20 observed in the 1 to 10 ppm range, similar to occupational exposure limits. Low-level exposure 

21 effects are reversible once the exposure is terminated. Members of the public are generally not 

22 exposed to levels that have observable health effects from routine industrial emissions. There 

23 are no known background sources of HF exposure in the vicinity of the proposed EREF. 

24 

25 Uranium in various chemical forms exerts heavy metal toxicity, primarily to the kidneys 

26 (ATSDR, 1999). Exposure to UF6 or any other uranium compounds that might be released from 

27 the proposed EREF or present within the proposed facility may be via inhalation or ingestion. 

28 The degree of absorption of inhaled uranium from the lung or ingested uranium into the 

29 bloodstream is greater for more soluble forms of uranium, such as UO2F2, which is formed from 

30 the reaction of UF6 and water along with HF. Little direct toxicological data are available on 

31 chemical toxicity in humans at low inhalation exposures. Standards are based mainly on tests 

32 in mammals, which show low-level systemic health effects beginning at inhalation exposures in 

33 the 0.1 to 1 milligram per cubic meter range for chronic exposures. As for HF, there are no 

34 known background sources of uranium exposure in the vicinity of the proposed EREF, except 

35 from the very low levels occurring naturally in soils. 

36 
 3-88 

Table 3-25 Cancer Incidence and Death 

Rates for All Cancers for 2002 to 2006a 

Area All Cancer 

Incidence Rate 

All Cancer 

Death Rate 

United States 471.3 186.9 

Idaho 461.7 171.6 

a

 Per 100,000 persons and are age adjusted to the 2000 

U.S. standard population. 

Source: CDC, 2010. 

1 

2 3.12 Socioeconomics 

3 

4 This section describes current socioeconomic conditions and local community services within 

5 the region of influence (ROI) surrounding the site of the proposed EREF. Although the data 

6 used (BEA 2010) to estimate the impacts of the proposed EREF project comprised an 

7 11-county ROI in Idaho – including Bannock, Bingham, Blaine, Bonneville, Butte, Caribou, 

8 Clark, Fremont, Jefferson, Madison, and Power Counties – the majority of the economic impacts 

9 of the proposed facility are expected to occur in two of these counties, Bingham and Bonneville 

10 Counties. These two counties (i.e., the two-county ROI) are expected to encompass the area in 

11 which the majority of EREF workers are expected to spend most of their wages and salaries, 

12 and which are expected to be the primary source of labor for each phase of the proposed 

13 EREF. It is also the area in which a significant portion of site purchases and non-payroll 

14 expenditures from the construction, manufacturing, operation, and decommissioning phases of 

15 the proposed facility are expected to occur. As it is anticipated that a number of workers will 

16 move into the area during each phase of the proposed project, with the majority of the 

17 demographic and social impacts associated with population in-migration likely to occur in 

18 Bingham and Bonneville Counties, the impacts of the proposed EREF on population, housing, 

19 and community services are assessed for a two-county ROI, consisting of Bingham and 

20 Bonneville Counties. 

21 

22 3.12.1 Population Characteristics 

23 

24 The population in the two-county ROI is characterized in terms of the major population centers 

25 around the proposed site, population growth trends, and significant transient and special 

26 populations. Minority and low-income populations are discussed in the environmental justice 

27 discussion in Section 3.13. 

28 

29 3.12.1.1 Major Population Centers 

30 

31 One city, Idaho Falls (estimated 2006 population 52,786), is located in Bonneville County, and 

32 several small towns are located in the remainder of the ROI, including Pocatello 

33 (53,932 residents in 2006), Blackfoot (11,007) and Shelley (4195) (U.S. Census Bureau, 

34 2009a). 

35 

36 Estimated population density in the two-county ROI is highest in Bingham County, with 

37 34.4 persons per square kilometer (89.1 per square mile) in 2008. Bonneville County has more 
 3-89 

1 land area than Bingham County and has a smaller population, with a population density of 

2 9.1 persons per square kilometer (23.5 per square mile) (U.S. Census Bureau, 2009b). 

3 

4 3.12.1.2 Population Growth Trends 

5 

6 Table 3-26 presents recent and projected populations for the two-county ROI and Idaho. As 

7 shown, estimated population in the ROI stood at 143,038 in 2008, having grown at an average 

8 annual rate of 1.8 percent since 2000. This growth was lower than the 2.1 percent annual 

9 average growth rate for Idaho as a whole of over the same period. 

10 

11 The population has grown in both counties in the two-county ROI since 2000. Bonneville 

12 County recorded an annual average population growth of 2.3 percent between 2000 and 2008, 

13 while Bingham County grew by 0.6 percent during the same period. The estimated ROI 

14 population is expected to increase to 156,491 by 2013 and to 168,331 by 2017. Both counties 

15 in the ROI are projected to experience positive population growth between 2008 and 2017. 

16 

17 3.12.1.3 Transient and Special Populations 

18 

19 In addition to the residential population, institutional, transient, and seasonal populations occur 

20 in the two-county ROI. Institutional populations include school populations, which are described 

21 in Section 3.12.3.2. The transient population consists of visitors participating in various 

22 seasonal, social, and recreational activities within the local area. The region also has a large 

23 number of seasonal farm workers, as well as a number of seasonal workers in the construction 

24 and hospitality industries. Although U.S. Census and other Federal data may include transient 

25 and special population groups that were present when the Census was taken, data on the 

26 education level, ethnicity, and income characteristics of specific transient and special 

27 populations are not available. 

28 

29 3.12.2 Economic Trends and Characteristics 

30 

31 3.12.2.1 Employment 

32 

33 Employment in the two-county ROI stood at 62,608 in 2006 (Table 3-27). Over the past 

34 decade, employment within the two-county ROI has shifted slightly from government, 

35 construction, and farm sectors toward service, wholesale and retail trade, and manufacturing 

36 sectors. Currently, the service sector provides the highest percentage of employment in the 

37 region at 51.2 percent, followed by the wholesale and retail trade at 19.2 percent. Smaller 

38 employment shares are held by transportation and public utilities (10.4 percent) and agriculture 

39 (9.2 percent). The distribution of employment across sectors within the ROI is similar to that of 

40 the ROI as a whole, with a slightly higher percentage of employment in agriculture 

41 (12.6 percent), manufacturing (18.7 percent), and transportation and public utilities 

42 (21.1 percent) in Bonneville County. At 32.4 percent of total employment, Bonneville has less 

43 service employment than in the ROI as a whole. 

44 

45 3.12.2.2 Unemployment 

46 

47 Unemployment rates have varied across the two counties in the ROI (Table 3-28). Over the 

48 10-year period 19992008, the average rate in Bingham County was 4.0 percent, with a lower 
 3-90 

Table 3-26 Population in the Two-County ROI and Idaho 

Location 2000 2008 

Average 

Annual 

Growth (%) 

20002008 

2013 2017 

Bingham County 41,735 43,903 0.6 45,315 46,477 

Bonneville County 82,522 99,135 2.3 111,176 121,854 

ROI 124,257 143,038 1.8 156,491 168,331 

Idaho 1,293,953 1,523,816 2.1 1,687,782 1,831,569 

Source: U.S. Census Bureau, 2009a; Argonne, 2010.

1 

2 rate of 3.1 percent in Bonneville County. The average rate in the ROI as a whole over this 

3 period was 3.4 percent, which was lower than the average rate for the State of 4.4 percent. 

4 Unemployment rates for the first three months of 2009 contrast markedly with rates for 2008 as 

5 a whole; in Bonneville County, the unemployment rate increased to 6.1 percent, while in 

6 Bingham County the rate reached 5.6 percent. The average rate for the two-county ROI 

7 (5.7 percent) and the State (7.0 percent) during this period were also higher than the 

8 corresponding average rates for 2008. 

9 

10 3.12.2.3 Income 

11 

12 Total personal income in the two-county ROI stood at $4.5 billion in 2007 and had grown at an 

13 annual average rate of 3.1 percent over the period 1998 to 2007 (Table 3-29). ROI personal 

14 income per capita also rose over the same period, but at a slower rate of 1.7 percent, increasing 

15 from $27,023 to $31,973. Per capita incomes were higher in Bonneville County ($34,630) in 

16 2007 than in Bingham County ($26,068). Although personal income and per capita income 

17 growth rates in the two-county ROI have been higher than for the State as a whole, personal 

18 income per capita was slightly higher in the State ($32,908) in 2007 than in the ROI. Although 

19 no corresponding data are available for Bingham and Bonneville Counties, in Idaho as a whole 

20 in 2007, there were 74,152 single-parent families, 18.7 percent of the total number of families in 

21 the State (U.S. Census Bureau, 2009b). The median annual family income of a single female 

22 parent with children under the age of 18 was $22,369. 

23 

24 Median household income in the two-county ROI over the period 20062008 ranged from 

25 $44,232 in Bingham County to $51,232 in Bonneville County (Table 3-29). The average in the 

26 ROI as a whole was $47,732, slightly higher than the State average of $47,331. 

27 

28 3.12.3 Housing Resources and Community and Social Services 

29 

30 This section describes housing and social services in the two-county ROI, including schools, law 

31 enforcement, and firefighting. 

32 
 3-91 Table 3-27 Two-County ROI Employment in 2006a Industry Bingham County % of Total Bonneville County % of Total ROI % of Total Idaho % of Total Agriculturea 4324 8.5 1456 12.6 5780 9.2 50,540 8.5 Mining 0 0.0 0 0.0 0 0.0 2202 0.4 Construction 3409 6.7 1093 9.4 4502 7.2 52,804 8.9 Manufacturing 2728 5.3 2173 18.7 4901 7.8 64,212 10.8 Transportation and public utilities 4079 8.0 2448 21.1 6527 10.4 80,257 13.5 Wholesale and retail trade 9461 18.5 2540 21.9 12,001 19.2 104,604 17.6 Finance, insurance, and real estate 1686 3.3 310 2.7 1996 3.7 30,576 5.2 Services 28,286 55.0 3759 32.4 32,045 51.2 268,527 45.3 Other 24 0.0 1 0.0 25 0.0 184 0.0 Total 51,007 11,601 62,608 593,185 

a Agricultural employment includes 2007 data for hired farm workers. 

Source: U.S. Census Bureau, 2009c; USDA, 2009. 

1 
 3-92 

Table 3-28 Two-County ROI Unemployment 

Rates (percent) 

Location 19992008 2008 2009a

Bingham County 4.0 3.9 5.6 

Bonneville County 3.1 3.4 6.1 

ROI 3.4 3.5 5.7 

Idaho 4.4 4.9 7.0 

a

 Rates for 2009 are the average for January through 

March. 

Source: DOL, 2009a–d. 

1 

Table 3-29 Two-County ROI and State Personal Income 

Location 1998 2007 

Annual Average 

Growth, 

19982007 (%) 

Bingham County 

 Total income (billion 2008 $) 1.0 1.1 1.6 

 Per capita income ($) 23,303 26,068 1.1 

 Median household incomea 44,232 

Bonneville County 

 Total income (billion 2008 $) 2.3 3.3 3.6 

 Per capita income ($) 28,925 34,630 1.8 

 Median household incomea 51,232 

Two-County ROI 

 Total income (billion 2008 $) 3.3 4.5 3.1 

 Per capita income ($) 27,023 31,973 1.7 

 Median household incomea 47,732 

Idaho 

 Total income (billion 2008 $) 36.5 49.2 3.0 

 Per capita income ($) 29,120 32,908 1.2 

 Median household incomea 47,331 a

 20062008, 3-year average. 

Source: DOC, 2009; U.S. Census Bureau, 2009d.

2 

3 
 3-93 

1 3.12.3.1 Housing 

2 

3 Nearly 196,000 housing units were located in the two counties in 2007, with more than 

4 70 percent of these located in Bonneville County (Table 3-30). The majority of housing units in 

5 the region are single-family structures (75 percent), but the number of multi-family structures is 

6 increasing as the region develops (U.S. Census Bureau, 2009b). Vacancy rates do not vary 

7 significantly between the two counties, with 9.2 percent of units vacant in Bingham County and 

8 9.0 percent in Bonneville County. Owner-occupied units comprise 81 percent of the occupied 

9 units in Bingham County, but only 73 percent of the occupied units in Bonneville County. At the 

10 time of the 2000 Census, 480 seasonal-, recreational-, or occasional-use units were vacant. 

11 

12 Housing density in the two-county ROI was 6.8 units per square kilometer (17.7 per square 

13 mile), compared to 2.9 units per square kilometer (7.6 per square mile) for the State as a whole. 

14 There were 7.7 units per square kilometer (19.9 per square mile) in Bonneville County and 

15 5.4 units per square kilometer (13.9 per square mile) in Bingham County (U.S. Census 

16 Bureau, 2009a). 

17 

18 Housing stock in the two-county ROI as a whole grew at an annual rate of 2.3 percent over the 

19 period 20002007, with 7872 new units added to the existing housing stock in the ROI 

20 (Table 3-30). With an overall vacancy rate of 9.1 percent, there were 4770 vacant housing units 

21 in the two-county ROI in 2007, of which 1073 (251 in Bingham County, 822 in Bonneville 

22 County) are expected to be rental units available to construction workers at the proposed EREF. 

23 

24 The median value of a home in Bonneville County of $93,500 was about 10.7 percent greater 

25 than the $84,400 in Bingham County. The median value of homes in both counties was 

26 somewhat lower than the $106,300 median value for the State of Idaho (U.S. Census 

27 Bureau, 2009a). 

28 

29 3.12.3.2 Schools 

30 

31 Seventy-four public and private elementary, middle, and high schools are located in the 

32 two-county ROI (NCES, 2009). Table 3-31 provides summary statistics for the school districts 

33 in the ROI, including enrollment, educational staffing, and two indices of educational quality – 

34 student-teacher ratios and levels of service (number of teachers per 1000 population). The 

35 student-teacher ratio in Bonneville County schools (19.8) is slightly higher than for schools in 

36 Bingham County (18.0), while the level of service is slightly higher in Bingham County. Five 

37 colleges and adult learning centers are located within 80.5 kilometers (50 miles) of the proposed 

38 EREF site, with a combined enrollment of 27,820 (NCES, 2009). The closest schools to the 

39 proposed EREF site are about 32 kilometers (20 miles) east in Idaho Falls. 

40 

41 3.12.3.3 Public Safety 

42 

43 Several State, county, and local police departments provide law enforcement in the two-county 

44 ROI. Bonneville County has 57 officers and would provide law enforcement services to the 

45 proposed EREF (Table 3-32); Bingham County has 30 officers (Table 3-32) (FBI, 2009). 

46 Currently there are 95 professional firefighters in Bonneville County and 39 in Bingham County 

47 (Table 3-32). The Idaho Falls Fire Department, the Ucon Volunteer Fire Department, and the 

48 Shelley Firth Rural Fire District all are located about 32 kilometers (20 miles) from the site of the 
 3-94 

Table 3-30 Two-County ROI Housing 

Characteristics 

Parameter 2000 2007a

Bingham County 

Owner occupied 10,564 11,290 

Rental 2753 2735 

Vacant units 986 1415 

Seasonal and recreational use 103 NAb

Total units 14,303 15,540 

Median value of owneroccupied units $84,400 $121,400 

Bonneville County 

Owner occupied 21,467 24,742 

Rental 7286 9122 

Vacant units 1731 3355 

 Seasonal and recreational use 377 NA 

Total units 30,484 37,219 

Median value of owneroccupied units $93,500 $148,300 

Two-County ROI Total 

Owner occupied 32,031 36,034 

Rental 10,039 11,857 

Vacant units 2717 4770 

 Seasonal and recreational use 480 NA 

Total units 44,787 52,659 

Median value of owneroccupied units$88,950 $134,850 

a

 20062008, 3-year average. b

 NA = not available. 

Source: U.S. Census Bureau, 2009a,b,d.

1 
 3-95 

Table 3-31 School District Data for the Two-County 

ROI in 2007 

Location Number of 

Students 

Number of 

Teachers 

StudentTeacher Ratio Level of 

Servicea

Bingham County 9902 550 18.0 12.7 

Bonneville County 19,557 988 19.8 10.2 

ROI 29,459 1538 19.2 11.0 

a

 Number of teachers per 1000 population. 

Source: NCES, 2009.

1 

Table 3-32 Public Safety Employment in the Two-County 

ROI in 2009 

Location Number of 

Police Officers 

Level of 

Servicea

Number of 

Firefightersb

Level of 

Servicea

Bingham County 30 0.7 39 0.9 

Bonneville County 57 0.6 95 1.0 

ROI 87 0.6 134 0.9 

a

 Number per 1000 population. 

b

 Number does not include volunteers. 

Source: FBI, 2009; FireDepartments.Net, 2009.

2 

3 proposed facility. Levels of service in police and fire protection in each county are similar to 

4 those for the two-county ROI as a whole (Table 3-32). 

5 

6 3.12.4 Tax Structure and Distribution 

7 

8 Tax revenue in Idaho comes from primarily personal and corporate income taxes, sales and use 

9 taxes, and property taxes. Personal income taxes range from 1.6 percent on the first $1198 of 

10 taxable income to 7.8 percent of taxable income above $23,963 for single filers and $47,926 for 

11 married couples filing jointly (ISTC, 2009). A 6 percent sales tax is applied to the sale, rental, or 

12 lease of tangible personal property, while rates on some services, including food, hotel, motel, 

13 and campground accommodations, vary from 8 percent to 12 percent. A use tax is applied to 

14 stored goods if sales taxes have not already been paid (ISTC, 2009). Property taxes are 

15 collected by the county in which the proposed EREF property is located. The property tax rates 

16 for Bonneville County were 1.6 percent on average for urban property and 1.01 percent on 

17 average in rural areas. In Bingham County, the average 2007 rates were 2.1 percent for urban 

18 property and 1.2 percent for rural property (ISTC, 2009). 

19 

20 3.13 Environmental Justice 

21 

22 On February 11, 1994, the President signed Executive Order 12898, “Federal Actions to 

23 Address Environmental Justice in Minority Populations and Low-Income Populations,” which 

24 directs all Federal agencies to develop strategies for considering environmental justice in their 
 3-96 

1 programs, policies, and activities. Environmental justice is described in the Executive Order as 

2 “identifying and addressing, as appropriate, disproportionately high and adverse human health 

3 or environmental effects of its programs, policies, and activities on minority populations and 

4 low-income populations.” 

5 

6 On December 10, 1997, the Council on Environmental Quality (CEQ) issued Environmental 

7 Justice Guidance under the National Environmental Policy Act (CEQ, 1997). In addition to 

8 following general guidelines on the evaluation of environmental analyses set forth in the 

9 document Environmental Review Guidance for Licensing Actions Associated with NMSS 

10 [Nuclear Material Safety and Safeguards] Programs (NUREG-1748) (NRC, 2003a), the NRC 

11 has issued a final policy statement on the Treatment of Environmental Justice Matters in NRC 

12 Regulatory and Licensing Actions (69 FR 52040) and environmental justice procedures to be 

13 followed in NEPA documents prepared by the NRC’s Office of Nuclear Material Safety and 

14 Safeguards (NRC, 2003b). 

15 

16 Consistent with NRC guidelines and procedures set forth in Appendix C to NUREG-1748 

17 (NRC, 2003a) and the NRC’s Policy Statement on the Treatment of Environmental Justice 

18 Matters in NRC Regulatory and Licensing Actions (NRC, 2004), this section describes data from 

19 the 2000 U.S. Census on minority and low-income populations within a 6.4-kilometer (4-mile) 

20 radius of the proposed EREF site (see Appendix G). This area includes a total of four Census 

21 block groups, including two in Bonneville County, the location of the proposed EREF, and one 

22 each in Bingham and Jefferson Counties (U.S. Census Bureau, 2009a). 

23 

24 3.13.1 Minority Populations 

25 

26 The CEQ guidelines define “minority” to include members of American Indian or Alaska Native, 

27 Asian or Pacific Islander, Black non-Hispanic, and Hispanic populations (CEQ, 1997). 

28 

29 Minority individuals are persons who identify themselves as members of the following population 

30 groups: Black or African American, American Indian or Alaska Native, Asian, Native Hawaiian or 

31 other Pacific Islander, some other race, two or more races (meaning individuals who identified 

32 themselves on the 2000 Census form as being a member of two or more races, for example, 

33 White and Hispanic), and Hispanic or Latino. The 2000 Census allowed individuals the option 

34 of identifying themselves in one or more race categories, thereby creating the multiracial 

35 Census category of “two or more races.” They are generally counted as part of the minority 

36 group they identified. 

37 

38 Minority populations can be determined by subtracting White, Not Hispanic or Latino 

39 populations from the total population. 

40 

41 There are no Census block groups in which the minority population either exceeds 50 percent of 

42 the total population and/or is more than 20 percentage points higher than the State or county 

43 percentage. Table 3-33 presents data for minority populations for the 6.4-kilometer (4-mile) 

44 area, for each county, and for the State.

45 
 3-97 

Table 3-33 Minority and Low-Income Populations within a 6.4-kilometer (4-mile) 

Radius of the Proposed EREF Site 

County 

4-mile Radius County 

Percent 

Minority 

State 

Percent 

Minority 

Total 

Populationa

Minority 

Population 

Percent 

Minority 

Bingham County 1438 234 16.3 17.6 

Bonneville County 1777 244 13.7 7.2 9.0 

Jefferson County 957 202 21.1 9.1 

 4-mile Radius 

County 

Percent 

Low-Income 

State 

Percent 

County Low-Income 

Total 

Populationb

LowIncome 

Population 

Percent 

LowIncome 

Bingham County 1384 162 11.7 12.4 

Bonneville County 1745 178 10.2 10.1 11.8 

Jefferson County 957 223 23.3 10.4 

a

 2000 data. 

b

 1999 data. 

Source: U.S. Census Bureau, 2009a.

1 

2 3.13.2 Low-Income Populations 

3 

4 Low-income populations are those that fall below the poverty level identified by the U.S. Census 

5 Bureau, including variations by family size and composition. If the total income for a family or 

6 unrelated individual falls below the relevant poverty threshold, then the family or unrelated 

7 individual is classified as being “below the poverty level.” For example, in 1999, the most recent 

8 year for which Census block group data on poverty are available, the poverty threshold for a 

9 family of five with three children below the age of 18 was $19,882. For any given family below 

10 the poverty line, all family members are considered as being below the poverty line for the 

11 purposes of analysis. 

12 

13 There are no Census block groups in which the low-income population either exceeds 

14 50 percent of the total population and/or is more than 20 percentage points higher than the 

15 State or county percentage. Table 3-33 presents data for low-income populations for the 

16 6.4-kilometer (4-mile) area, for each county, and for the State. 

17 

18 3.13.3 Resource Dependencies and Vulnerabilities of Minority and Low-Income 

19 Populations 

20 

21 In some cases, minority and low-income groups may rely on natural resources for their 

22 subsistence and to support unique cultural practices. Differential patterns of consumption of 

23 natural resources should be considered (i.e., differences in rates and/or patterns of fish, 

24 vegetable, water, and/or wildlife consumption among groups defined by demographic factors 

25 such as socioeconomic status, race, ethnicity, and/or cultural attributes). In some 
 3-98 

1 circumstances, these groups could be unusually vulnerable to impacts from the proposed 

2 action. In particular, higher participation in outdoor recreation, home gardening, and 

3 subsistence fishing may increase exposure risk to low-income and minority groups through 

4 inhalation or ingestion through various environmental pathways. 

5 

6 Potential resource dependencies were sought in the course of public meetings and other 

7 information supplied by the Hispanic/Latino and African American/Black communities in 

8 meetings with the NRC staff. Letters were also sent to the Federally recognized Shoshone9 Bannock Tribes to determine any potential resource dependencies. These letters solicited their 

10 concerns on the proposed project and inquired about whether they desired to participate in the 

11 Section 106 consultation process (see Appendix B). Currently, very few Native Americans live 

12 in the vicinity of the proposed EREF site (U.S. Census Bureau, 2009a). 

13 

14 In addition, the NRC staff examined data provided by the State of Idaho concerning the health 

15 status of the general population in Bingham and Bonneville Counties (Table 3-34). No 

16 exceptional health problems were found among residents in the two counties. It was not 

17 possible to identify any unusual incidences of birth defects, chronic diseases, or cancer clusters 

18 at the district level, the smallest area for which published health information is available. Age19 adjusted cancer deaths are slightly lower in District 6, which includes Bingham County, than in 

20 District 7, which includes Bonneville County; rates in Districts 6 and 7 are lower than in Idaho as 

21 a whole. The income and ethnicity of individuals with chronic diseases are not available. 

22 

Table 3-34 Selected Health Statistics for Counties near the 

Proposed EREF, 20052007 (per 100,000 population) 

District 6 

(includes 

Bingham 

County) 

District 7 

(includes 

Bonneville 

County) 

Idaho 

Annual average age-adjusted major 

causes of death 

 

 Cancer 148.0 145.7 166.5 

 Heart disease 198.2 196.6 169.8 

 Lung cancer 32.0 30.0 42.7 

 Cerebrovascular disease 57.1 49.7 48.8 

 Chronic lower respiratory diseases 46.1 48.6 48.9 

Source: Idaho Department of Health and Welfare, 2009.

23 

24 
 3-99 

1 3.14 References 

2 

3 (AASHTO, 1994) American Association of State Highway and Transportation Officials. “A 

4 Policy on Geometric Design of Highways and Streets.” 

5 

6 (Ackerman et al., 2006) Ackerman, D.J., G.W. Rattray, J.P. Rousseau, L.C. Davis, and B.R. Orr. 

7 “Conceptual Model of Ground-Water Flow in the Eastern Snake River Plain Aquifer at the Idaho 

8 National Laboratory and Vicinity with Implications for Contaminant Transport.” U.S. Geological 

9 Survey Scientific Investigations Report 2006-5122. DOE/ID-22198. Prepared in cooperation 

10 with the U.S. Department of Energy. 

11 

12 (AES, 2010) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

13 Environmental Report, Rev. 2.” Bethesda, Maryland. April. 

14 

15 (Anderson et al., 1996) Anderson, S.R., Liszewski, M.J., and Ackerman, D.J. “Thickness of 

16 Surficial Sediment at and near the Idaho National Engineering Laboratory, Idaho.” 

17 U.S. Geological Survey Open-File Report 96-330. Idaho Falls, Idaho. June. 

18 

19 (Argonne, 2010) Argonne National Laboratory. “State and County Population Projections.” 

20 Memorandum from T. Allison (Argonne) to B. Biwer (Argonne). May. 

21 

22 (ASTM, 2003) American Society of Testing and Materials. Standard E-1686-03, “Standard 

23 Guide for Selection of Environmental Noise Measurements and Criteria.” 

24 <http://webstore.ansi.org/FindStandards.aspx?SearchString=E1686-03&SearchOption= 

25 0&PageNum=0&SearchTermsArray=null%7cE1686-03%7cnull> (Accessed July 7, 2009). 

26 

27 (ATSDR, 1999) Agency for Toxic Substances and Disease Registry. “Toxicological Profile for 

28 Uranium.” September. <http://www.atsdr.cdc.gov/toxprofiles/tp150.html> (Accessed 

29 January 29, 2010). 

30 

31 (ATSDR, 2003) Agency for Toxic Substances and Disease Registry. “Toxicological Profile for 

32 Fluorides, Hydrogen Fluoride, and Fluorine.” September. <http://www.atsdr.cdc.gov/ 

33 toxprofiles/tp11.html> (Accessed January 29, 2010). 

34 

35 (BEA 2010) Bureau of Economic Analysis. “Regional Economic Accounts: RIMS II Multipliers.” 

36 <https://www.bea.gov/regional/rims/rimsii/> (Accessed April 19, 2010). 

37 

38 Bingham County, 2005) Bingham County. “Bingham County Comprehensive Plan.” Blackfoot, 

39 Idaho. March. ADAMS Accession No. ML101790177. 

40 

41 (BLM, 2007) U.S. Bureau of Land Management. “Manual 8400 Visual Resource Management.” 

42 <http://www.blm.gov/nstc/VRM/8400.html> (Accessed September 27, 2009). ADAMS 

43 Accession No. ML101790184. 

44 

45 (BLM, 2008) Bureau of Land Management. “Hell’s Half Acre, Wilderness Study Area, Upper 

46 Snake Field Office.” ADAMS Accession No. ML101790192. 

47 
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1 (BLM, 2009a) U.S. Bureau of Land Management. E-mail from J. Gilbert (U.S. Bureau of Land 

2 Management) to M. George (U.S. Nuclear Regulatory Commission) dated July 9. “Subject: RE: 

3 Follow Up – GIS Shape Files from BLM.” ADAMS Accession No. ML101870057. 

4 

5 (BLM, 2009b) U.S. Bureau of Land Management. “Visual Resource Inventory.” 

6 Manual H-8410-1. <http://www.blm.gov/nstc/VRM/8410.html> (Accessed October 8, 2009). 

7 ADAMS Accession No. ML101790201. 

8 

9 (BLM/DOE, 2004) Bureau of Land Management and U.S. Department of Energy. “Final 

10 Management Plan, INEEL Sagebrush Step Ecosystem Reserve.” EA ID-074-02-067. May. 

11 

12 (Carlsen, 2009) Carlsen, E. “Transfer No. 75268, Water Right No. 35-2642 – Transfer Approval 

13 Notice.” From E. Carlsen (Water Resources Manager, Idaho Department of Water Resources) 

14 to AREVA NC, Inc., Bethesda, Maryland. July 2. ADAMS Accession No. ML101790209. 

15 

16 (CDC, 2010) Centers for Disease Control and Prevention and National Cancer Institute, 

17 U.S. Cancer Statistics Working Group. “United States Cancer Statistics: 1999–2006 Incidence 

18 and Mortality Web-based Report.” U.S. Department of Health and Human Services, Atlanta, 

19 Georgia. <http://www.cdc.gov/uscs> (Accessed March 17, 2010). ADAMS Accession No. 

20 ML101830111. 

21 

22 (CEQ, 1997) Council on Environmental Quality. “Environmental Justice Guidance under the 

23 National Environmental Policy Act.” Executive Office of the President, Washington, D.C. 

24 

25 (Clawson et al., 1989) Clawson, K., G. Start, and N. Ricks (eds.). “Climatography of the Idaho 

National Engineering Laboratory, 2nd 26 Edition.” Report No. DOE/ID-12118. National Oceanic 

27 and Atmospheric Administration, Environmental Research Laboratories, Air Resources 

28 Laboratory Field Research Division, Idaho Falls, Idaho. December. <http://niwc.noaa.inel.gov/ 

29 climate/inelclimatologyedition2.pdf> (Accessed May 15, 2009). 

30 

31 (Connelly et al., 2003) Connelly, J.W., K.P. Reese, and M.A. Schroeder. “Monitoring of Greater 

32 Sage-grouse Habitats and Populations.” University of Idaho College of Natural Resources 

33 Experiment Station, Moscow, Idaho. Station Bulletin 80. 

34 

35 (Connelly et al., 2004) Connelly, J.W., S.T. Knick, M.A. Schroeder, and S.J. Stiver. 

36 “Conservation Assessment of Greater Sage-grouse and Sagebrush Habitats.” Unpublished 

37 report. Western Association of Fish and Wildlife Agencies, Cheyenne, Wyoming. 

38 

39 (Dechant et al., 1999) Dechant, J.A., M.L. Sondreal, D.H. Johnson, L.D. Igl, C.M. Goldade, 

40 A.L. Zimmerman, and B.R. Euliss. “Effects of Management Practices on Grassland Birds: 

41 Ferruginous Hawk.” Northern Prairie Wildlife Research Center, Jamestown, North Dakota. 

42 

43 (DOC, 2009) U.S. Department of Commerce. “Local Area Personal Income.” Bureau of 

44 Economic Analysis. <http://www.bea.gov/regional/reis/default.cfm?selTable=CA1-3§ion=2> 

45 (Accessed March 16, 2010). ADAMS Accession No. ML101790214. 

46 

47 
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1 (DOE, 1996) U.S. Department of Energy. “Site-Specific Probabilistic Seismic Hazard Analyses 

2 for the Idaho National Engineering Laboratory, Volume 1 – Final Report.” INEL-95/0536. 

3 Prepared by Woodward-Clyde Federal Services and Pacific Engineering and Analysis for the 

4 U.S. Department of Energy. May. 

5 

6 (DOE, 2005) U.S. Department of Energy. “Draft Environmental Impact Statement for the 

7 Proposed Consolidation of Nuclear Operations Related to Production of Radioisotope Power 

8 Systems.” DOE/EIS-0373D. Office of Nuclear Energy, Science, and Technology, Washington, 

9 D.C. June. <http://www.gc.energy.gov/NEPA/draft-eis0373d.htm> (Accessed May 27, 2009). 

10 

11 (DOE, 2007) U.S. Department of Energy. “Idaho National Laboratory Site Environmental Report 

12 Calendar Year 2006.” DOE/ID-12082(07). 

13 

14 (DOE, 2010a) U.S. Department of Energy. “DOE Offers Conditional Loan Guarantee for Front 

15 End Nuclear Facility in Idaho.” Press release, May 20. <http://www.energy.gov/news/ 

16 8996.htm> (Accessed November 29, 2010). ADAMS Accession No. ML103410146. 

17 

18 (DOE, 2010b) U.S. Department of Energy. Letter from M. McMillen (Director, Environmental 

19 Compliance Division, DOE) to J. Fullmer (Soil Conservationist-Bonneville County, NRCS) dated 

20 December 3, 2010. “Subject: NRCS Conversion Impact Rating for the Areva Eagle Rock 

21 Project.” ADAMS Accession No. ML103480644. 

22 

23 (DOL, 2009a) U.S. Department of Labor. “Local Area Unemployment Statistics: States and 

24 Selected Areas: Employment Status of the Civilian Noninstitutional Population, 1976 to 2007 

25 Annual Averages.” Bureau of Labor Statistics. <http://www.bls.gov/lau/staadata.txt> 

26 (Accessed October 4, 2009). ADAMS Accession No. ML101790215. 

27 

28 (DOL, 2009b) U.S. Department of Labor. “Local Area Unemployment Statistics: Unemployment 

29 Rates for States.” Bureau of Labor Statistics. <http://www.bls.gov/web/laumstrk.htm> 

30 (Accessed October 4, 2009). ADAMS Accession No. ML101790222. 

31 

32 (DOL, 2009c) U.S. Department of Labor. “Local Area Unemployment Statistics: County Data.” 

33 Bureau of Labor Statistics. <http://www.bls.gov/lau/> (Accessed October 4, 2009). ADAMS 

34 Accession No. ML101790229. 

35 

36 (DOL, 2009d) U.S. Department of Labor. “Consumer Price Index, All Urban Consumers 

37 (CPI-U) U.S. City Average, All items.” Bureau of Labor Statistics. <http://data.bls.gov/PDQ/ 

38 servlet/SurveyOutputServlet?data_tool=latest_numbers&issues_id=CUUR0000SA0&output_ 

39 view=pct_1mth> (Accessed October 4, 2009). ADAMS Accession No. ML101790267. 

40 

41 (Doty et al., 1976) Doty, S.R., R. Wallace, and G.C. Holzworth. “A Climatological Analysis of 

42 Pasquill Stability Categories Based on ‘Star’ Summaries.” National Oceanic and Atmospheric 

43 Administration, Environmental Data Service, National Climate Center, Asheville, North Carolina. 

44 April. 

45 

46 
 3-102 

1 (EPA, 1974) U.S. Environmental Protection Agency. “Information on levels of Environmental 

2 Noise Requisite to Protect Public health and Welfare with an Adequate Margin of Safety.” 

3 EPA/ONAC 550/9-74-004. Office of Noise Abatement and Control, Washington, D.C. March. 

4 <http://www.nonoise.org/library/levels74/levels74.htm> (Accessed May 13, 2009). ADAMS 

5 Accession No. ML101790269. 

6 

7 (EPA, 1978) U.S. Environmental Protection Agency. “Protective Noise Levels; Condensed 

8 Version of EPA Levels Document.” EPA 550/9-79-100. Office of Noise Abatement and Control, 

9 Washington, D.C. November. <http://www.nonoise.org/library/levels/levels.htm> 

10 (Accessed May 13, 2009). ADAMS Accession No. ML101790276. 

11 

12 (EPA, 1980) U.S. Environmental Protection Agency. “Guidelines for Considering Noise in Land 

13 Use and Planning Control. EPA 550-9-81-423. Federal Interagency Committee on Urban 

14 Noise. <http://www.nonoise.org/epa/> (Accessed March 19, 2010). 

15 

16 (EPA, 1999) U.S. Environmental Protection Agency. “Cancer Risk Coefficients for 

17 Environmental Exposure to Radionuclides.” Federal Guidance Report No. 13. EPA 402-R-99-

18 001. Prepared by Oak Ridge National Laboratory for U.S. Environmental Protection Agency, 

19 Office of Radiation and Indoor Air. September. <http://www.epa.gov/rpdweb00/docs/ 

20 federal/402-r-99-001.pdf> (Accessed March 1, 2010). 

21 

22 (EPA, 2002) U.S. Environmental Protection Agency. “EPA Facts about Tritium.” July. 

23 

24 (EPA, 2009a) U.S. Environmental Protection Agency. “Final Mandatory Greenhouse Gas 

25 Reporting Rule.” <http://www.epa.gov/climatechange/emissions/ghgrulemaking.html> 

26 (Accessed December 15, 2009). ADAMS Accession No. ML101790281. 

27 

28 (EPA, 2009b) U.S. Environmental Protection Agency. “Regional Screening Levels Table – 

29 Industrial Soils (April 2009).” <http://www.epa.gov/reg3hwmd/risk/human/rb30 concentration_table/Generic_Tables/index.htm> (Accessed June 18, 2009). ADAMS Accession 

31 No. ML101790284. 

32 

33 (EPA, 2009c) U.S. Environmental Protection Agency. “Region 10 Sole Source Aquifer 

34 Program.” <http://yosemite.epa.gov/r10/water.NSF/Sole+Source+Aquifers/SSA> (Accessed 

35 October 6, 2009). ADAMS Accession No. ML101790288. 

36 

37 (EPA, 2010a) U.S. Environmental Protection Agency. “Section 303(d) List Fact Sheet for 

38 Watershed – American Falls.” <http://iaspub.epa.gov/tmdl_waters10/huc_rept.control?p_huc= 

39 17040206&p_huc_desc=American Falls> (Accessed March 10, 2010). ADAMS Accession No. 

40 ML101790289. 

41 

42 (EPA, 2010b) U.S. Environmental Protection Agency. “Drinking Water Contaminants – List of 

43 Contaminants and Their MCLs.” <http://www.epa.gov/safewater/contaminants/index.html> 

44 (Accessed February 24, 2010). ADAMS Accession No. ML101790290. 

45 

46 (Estes and Raley, 2009) Estes, M.B., and J. Raley. “Amendment to: A Class III Cultural 

47 Resource Inventory of the Proposed Eagle Rock Enrichment Facility Bonneville County, Idaho.” 

48 Western Cultural Resource Management, Inc., Sparks, Nevada. August 28. 

49 
 3-103 

1 (FBI, 2009) Federal Bureau of Investigation. “Crime in the United States: 2006.” 

2 http://www.fbi.gov/ucr/cius2006/about/table_title.html> (Accessed October 4, 2009). ADAMS 

3 Accession No. ML101790291. 

4 

5 (FEMA, 2010) Federal Emergency Management Agency. “Map Service Center – Quick Order 

6 (Map Panel 1600270025C).” <http://msc.fema.gov/webapp/wcs/stores/servlet/QuickOrder 

7 ResultView> (Accessed March 31, 2010). ADAMS Accession No. ML101790293. 

8 

9 (Field et al., 2001) Field, N., L. Jones, T. Jordan, M. Benthien, and L. Wald. “Earthquake 

10 Shaking – Finding the ‘Hotspots.” U.S. Geological Survey Fact Sheet 001-01. 

11 <http://pubs.usgs.gov/fs/2001/fs001-01/fs001-01.pdf (Accessed November 29, 2010). ADAMS 

12 Accession No. ML103410201. 

13 

14 (FireDepartments.Net, 2009) Fire Departments Network. “Fire Department Listings.” 

15 <http://www.firedepartments.net/fire-department-listings/> (Accessed October 4, 2009). 

16 ADAMS Accession No. ML101790295. 

17 

18 (FWS, 2007) U.S. Fish and Wildlife Service. “National Bald Eagle Management Guidelines.” 

19 <http://www.fws.gov/migratorybirds/baldeagle.htm> (Accessed May 17, 2010). ADAMS 

20 Accession No. ML101790298. 

21 

22 (FWS, 2008) U.S. Fish and Wildlife Service. “Birds of Conservation Concern 2008, 

23 United States.” Division of Migratory Bird Management, Arlington, Virginia. 

24 <http://www.fws.gov/migratorybirds/> (Accessed October 4, 2009). 

25 

26 (FWS, 2009a) U.S. Fish and Wildlife Service. Letter from Damien Miller (Supervisor, Eastern 

27 Idaho Field Office, U.S. Fish and Wildlife Service) to Gloria Kulesa (NRC) dated July 15, 2009. 

28 “Subject: Proposed AREVA Eagle Rock Enrichment Facility in Bonneville County, Idaho. 

29 SL #09-0471.” 

30 

31 (FWS, 2009b) U.S. Fish and Wildlife Service. “Species Information by County.” 

32 <http://www.fws.gov/idaho/agencies/Countybycounty.htm> (Accessed May 14, 2009). ADAMS 

33 Accession No. ML101790299. 

34 

35 (FWS, 2010a) U.S. Fish and Wildlife Service. “Species Profile, Utah Valvata Snail (Valvata 

36 utahensis).” <http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=G05R> 

37 (Accessed October 5, 2009). ADAMS Accession No. ML101790304. 

38 

39 (FWS, 2010b) U.S. Fish and Wildlife Service. “Grizzly Bear Recovery, Yellowstone Ecosystem.” 

40 <http://www.fws.gov/mountain-prairie/species/mammals/grizzly/yellowstone.htm> (Accessed 

41 April 21, 2010). ADAMS Accession No. ML101790297. 

42 

43 (FWS, undated) U.S. Fish and Wildlife Service. “National Wetland Inventory, Kettle Butte, 

44 Idaho, quadrangle map.” August 1980 aerial photography. Available from Earth Science 

45 Information Office, Blaisdell House, University of Massachusetts, Amherst, MA 01003. 

46 

47 
 3-104 

1 (Gilbert, 2010) Gilbert, H. Personal communication from H. Gilbert (Idaho National Laboratory) 

2 to D.J. O’Rourke (Argonne National Laboratory) dated April 26, 2010. “Subject: Uniqueness of 

Late 19th 3 Century Homestead Sties in the General Vicinity of the EREF Property.” ADAMS 

4 Accession No. ML101790310. 

5 

6 (Gillerman and Bennett, 2008) Gillerman, V.S., and E.H. Bennett. “Idaho Mining and 

7 Exploration, 2007.” Mining Engineering, Vol. 60, No. 5, pp. 84–88. 

8 

9 (Hackett et al., 2002) Hackett, W.R., R.P. Smith, and S. Khericha. “Volcanic Hazards of the 

10 Idaho National Engineering Laboratory, Southeast Idaho.” In: Tectonic and Magmatic Evolution 

11 of the Snake River Plain Volcanic Province. (B. Bonnichsen, C.M. White, and M. McCurry, eds). 

12 Idaho Geological Survey, Bulletin 30. 

13 

14 (Halstead, 2009) Halstead, M. E-mail from M. Halstead (Bingham County, Idaho) to 

15 D.J. O’Rourke (Argonne National Laboratory) dated July 9. “Subject: RE: Information Need.” 

16 ADAMS Accession No. ML101790314. 

17 

18 (HUD, 2009) U.S. Housing and Urban Development. “Chapter 2: The Noise Regulation.” In: 

19 The Noise Guidebook. 24 CFR 51.103. <http://www.hud.gov/offices/cpd/environment/ 

20 training/guidebooks/noise/index.cfm> (Accessed September 14, 2009). 

21 

22 (Hughes et al., 1999) Hughes, S.S., R.P. Smith, W.R. Hackett, and S.R. Anderson. “Mafic 

23 Volcanism and Environmental Geology of the Eastern Snake River Plain, Idaho.” In: Guidebook 

24 to the Geology of Eastern Idaho, Idaho Museum of Natural History, pp. 143–168. (S.S. Hughes 

25 and G.D. Thackray, eds). 

26 

27 (Hukari, 2009) Hukari, N. Personal communication from N. Hukari (NOAA/ARLFRD) to R. Kolpa 

28 (Argonne National Laboratory) dated July 15. ADAMS Accession No. ML101870068. 

29 

30 (Idaho Department of Health and Welfare, 2009) Idaho Department of Health and Welfare. 

31 “Idaho Vital Statistics: Health District Report.” <http://healthandwelfare.idaho.gov/Portals/0/ 

32 Health/Statistics/Idaho%20Vital%20Statistics%20Health%20District%20Report,%201999-

33 2007.pdf> (Accessed March 10, 2010). 

34 

35 (IDC, 2009) Idaho Department of Commerce. “Community Profiles of Idaho.” 

36 <http://commerce.idaho.gov/business/socioeconomic-profiles.aspx> (Accessed October 6, 

37 2009). ADAMS Accession No. ML101830116.

38 

39 (IDEQ, 2005) Idaho Department of Environmental Quality. “State of Idaho Oversight Monitor: 

40 Idaho’s Treasure  the Eastern Snake River Plain Aquifer.” Idaho INL Oversight Program. 

41 Boise, Idaho. May. ADAMS Accession No. ML101790328. 

42 

43 (IDEQ, 2006a) Idaho Department of Environmental Quality. “INL Oversight Annual Report 

44 2006.” Idaho National Laboratory Oversight. <http://www.deq.idaho.gov/inl_oversight/library/ 

45 2006_annual.pdf> (Accessed May 16, 2009). 

46 
 3-105 

1 (IDEQ, 2006b) Idaho Department of Environmental Quality. “American Falls Subbasin Total 

2 Maximum Daily Loan Plan: Subbasin Assessment and Loading Analysis.” Prepared by 

3 Pocatello Regional Office, Shoshone-Bannock Tribes, and EPA Region 10. July. 

4 

5 (IDEQ, 2007a) Idaho Department of Environmental Quality. “2007 Air Quality Monitoring Data 

6 Summary.” <http://www.deq.idaho.gov/air/data_reports/monitoring/07_aq_monitoring_ 

7 report.pdf> (Accessed May 6, 2009). 

8 

9 (IDEQ, 2007b) Idaho Department of Environmental Quality. “Idaho Air Quality Planning Areas.” 

10 <http://www.deq.idaho.gov/air/data_reports/planning/air_planning_areas_2007.pdf> 

11 (Accessed May 11, 2009). ADAMS Accession No. ML101790334. 

12 

13 (IDEQ, 2007c) Idaho Department of Environmental Quality. “INL Oversight Program Annual 

14 Report 2007.” Idaho National Laboratory Oversight. <http://www.deq.idaho.gov/inl_oversight/ 

15 library/2007_annual.pdf> (Accessed May 16, 2009). 

16 

17 (IDEQ, 2008) Idaho Department of Environmental Quality. “INL Oversight Annual Report 2008.” 

18 Idaho National Laboratory Oversight. <http://www.deq.idaho.gov/inl_oversight/library/ 

19 2008_annual.pdf> (Accessed February 1, 2010). 

20 

21 (IDEQ, 2009) Idaho Department of Environmental Quality. “2005 Idaho EI.” Access database 

22 file from Gary Reinbold, Air Quality Analyst, Idaho Department of Environmental Quality. 

23 May 11. ADAMS Accession No. ML101870076. 

24 

25 (IDEQ, undated) Idaho Department of Environmental Quality. “Idaho Area Designation 

26 Recommendations for the 2006 PM2.5 NAAQS.” <http://www.deq.idaho.gov/air/data_reports/ 

27 planning/designation_area_recommendations_06pm25_naaqs.pdf> (Accessed May 11, 2009). 

28 

29 (IDFG, 2005) Idaho Department of Fish and Game. “Idaho Comprehensive Wildlife 

30 Conservation Strategy.” Idaho Conservation Data Center, Boise, Idaho. <http://fishandgame. 

31 idaho.gov/cms/tech/CDC/cwcs.cfm> (Accessed November 16, 2009). ADAMS Accession No. 

32 ML101800019. 

33 

34 (IDFG, 2009a) Idaho Department of Fish and Game. “Spiranthes diluvialis Sheviak, Ute ladies’ 

35 tresses.” <http://fishandgame.idaho.gov/cms/tech/CDC/spp_accounts_plants/spidil.cfm> 

36 (Accessed May 20, 2009). ADAMS Accession No. ML101800026. 

37 

38 (IDFG, 2009b) Idaho Department of Fish and Game. Letter from Sharon W. Kiefer (Assistant 

39 Director-Policy, Idaho Department of Fish and Game) to Andrea Kock (NRC). 

40 

41 (IDFG, 2009c) Idaho Department of Fish and Game. “Upper Snake Region  Annual Fisheries 

42 Report, 2008 Activities and Accomplishments.” Issue 4. April. ADAMS Accession No. 

43 ML101800034. 

44 

45 (IDFG, 2010) Idaho Department of Fish and Game. Email from Sharon W. Kiefer (Assistant 

46 Director-Policy, Idaho Department of Fish and Game) to Stephen Lemont (NRC). 

47 
 3-106 

1 (IDWR, 2010) Idaho Department of Water Resources. “Internet Map Server.” 

2 <http://maps.idwr.idaho.gov/mapall2/viewer.htm> (Accessed February 25, 2010). ADAMS 

3 Accession No. ML101800036. 

4 

5 (INL, 2007) Idaho National Laboratory. “Idaho National Laboratory Cultural Resource 

6 Management Plan.” DOE/ID-10997. Revision 2. February. 

7 

8 (IPCS, 2009) International Programme on Chemical Safety. “INCHEM – Chemical Safety Data 

9 from Intergovernmental Organizations.” <http://www.inchem.org/> (Accessed May 17, 2009). 

10 ADAMS Accession No. ML101800038. 

11 

12 (ISAC, 2006) Idaho Sage-Grouse Advisory Committee. “Conservation Plan for the Greater 

13 Sage-Grouse in Idaho.” ADAMS Accession No. ML101800045. 

14 

15 (ISACTAT, 2010) Idaho Sage-grouse Advisory Committee Technical Assistance Team. “Idaho 

16 Sage-grouse Local Working Groups Statewide Annual Report 2009.” March 12. ADAMS 

17 Accession No. ML101800048. 

18 

19 (ISTC, 2009) Idaho State Tax Commission. “Property Tax Publications.” <http://tax.idaho.gov/ 

20 pubs/EPB00129_12-31-2008.pdf> (Accessed October 4, 2009). ADAMS Accession No. 

21 ML101800049. 

22 

23 (ITD, 1996) Idaho Transportation Department. “Idaho State Rail Plan.” June. 

24 <http://www.itd.idaho.gov/planning/railfreight/rail.pdf> (Accessed October 2, 2009). 

25 

26 (ITD, 2005) Idaho Transportation Department. “US 20 Mileposts 263-301.3 Potential Safety 

27 Improvement Analysis.” July. ADAMS Accession No. ML101800051. 

28 

29 (ITD, 2007) Idaho Transportation Department. “Purple Overweight Chart.” May 22. 

30 <http://www.itd.idaho.gov/dmv/poe/Purple_Route_Chart.htm> (Accessed May 10, 2010). 

31 ADAMS Accession No. ML101800056. 

32 

33 (ITD, 2009a) Idaho Transportation Department. “District Six 2008 Rural Traffic Flow Map.” 

34 May. <http://www.itd.idaho.gov/planning/roadwaydata/RTFMaps/2008/TF2008RuralD6.pdf> 

35 (Accessed October 2, 2009). ADAMS Accession No. ML101800058. 

36 

37 (ITD, 2009b) Idaho Transportation Department. “Idaho Transportation Department Monthly 

38 Bulletin.” <http://dot.idaho.gov/planning/roadwaydata/Monthly_Bulletin/index.html> 

39 (Accessed October 2, 2009). ADAMS Accession No. ML101830118. 

40 

41 (ITD, 2010a). Idaho Transportation Department. “Route Capacity Map.” January. 

42 <http://www.itd.idaho.gov/dmv/POE/documents/route_cap2.pdf> (Accessed February 26, 2010). 

43 ADAMS Accession No. ML101800061. 

44 

45 (ITD, 2010b). Idaho Transportation Department. “Annual Vehicle Speed Report 2009: 

46 Station #57.” January 12. <http://www.itd.idaho.gov/planning/roadwaydata//057KettleButte/ 

47 2009/09-Annual/L057_KettleButte_2009_AnnualVehicleSpeedReport.pdf> 

48 (Accessed March 12, 2010). ADAMS Accession No. ML101800088. 

49 
 3-107 

1 (ITD, 2010c) Idaho Transportation Department. Personal communication from M. Davison 

2 (Idaho Transportation Department) to K. Fischer (Argonne National Laboratory) dated 

3 February 26, 2010. ADAMS Accession No. ML101800099. 

4 

5 (ITD, 2010d) Idaho Transportation Department. Personal communication from K. Hahn (Idaho 

6 Transportation Department) to K. Fischer (Argonne National Laboratory) dated February 26 and 

7 March 1, 2010. ADAMS Accession No. ML101800102. 

8 

9 (ITD, 2010e) Idaho Transportation Department. “Hourly Traffic Volume Report By Direction: 

10 Station #57.” March 9. <http://dot.idaho.gov/planning/roadwaydata//057KettleButte/2010/10-

11 02feb/L057_KettleButte_Feb10_HourlyTrafficVolumeReportByDirection.pdf> 

12 (Accessed April 22, 2010). ADAMS Accession No. ML101800161. 

13 

14 (IWRB, 2009) Idaho Water Resource Board. “Eastern Snake Plain Aquifer (ESPA) – 

15 Comprehensive Aquifer Management Plan.” January. 

16 

17 (Jefferson County, 2005) Jefferson County, Idaho. “Jefferson County Comprehensive Plan.” 

18 2005 Update. Adopted April 25, 2005. 

19 

20 (Jefferson County, 2008) Jefferson County, Idaho. “Jefferson County Zone Map.” ADAMS 

21 Accession No. ML101800179. 

22 

23 (Jones, 2009) Jones, D. E-mail communication from D. Jones (Idaho Department of 

24 Environmental Quality INL Oversight Program) to B. Biwer (Argonne National Laboratory) dated 

25 July 14. “Subject: Soil Data.” 

26 

27 (Joyner, 2008) Letter from J.M. Joyner (Regulatory Division, Walla Walla District, U.S. Corps of 

28 Engineers) to G. Harper (AREVA NP Inc.) dated October 10. NWW-2008-00670-120. ADAMS 

29 Accession No. ML101800184. 

30 

31 (Kuntz et al., 1994) Kuntz, M.A., B. Skipp, M.A. Lanphere, G.B. Dalrymple, D.B. Champion, 

32 G.F. Embree, W.R. Page, L.A. Morgan, R.P. Smith, W.R. Hackett, and D.W. Rodgers. 

33 “Geologic Map of the Idaho National Engineering Laboratory and Adjoining Areas, Eastern 

34 Idaho.” U.S. Geological Survey Miscellaneous Inv. Map I-2330. 

35 

36 (Landscape Dynamics Lab, 1999) Landscape Dynamics Lab. “Idaho Land Cover.” Version 2.1. 

37 February. ADAMS Accession No. ML101800245. 

38 

39 (Lindholm, 1996) Lindholm, G.F. “Summary of the Snake River Plain Regional Aquifer-System 

40 Analysis in Idaho and Eastern Oregon.” Part of the Snake River Plain Regional Aquifer System 

41 Analysis (RASA) Project, U.S. Geological Survey Professional Paper 1408-A. 

42 

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19 (MWH, 2009) MWH. “Ecology Field Study Report, Proposed Site for the Eagle Rock Enrichment 

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38 (NCES, 2009) National Center for Education Statistics. “National Center for Education 

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21 (NOAA, 2009) National Oceanographic and Atmospheric Administration. “Lightning Safety 

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25 (NOAA, 2010) National Oceanographic and Atmospheric Administration. “Drought Severity 

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33 (NPS, 2007) National Park Service. “Explore Air, Class I Area Locations, All Class I Areas.” 

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36 

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5 (NRC, 2010) U.S. Nuclear Regulatory Commission. “Safety Evaluation Report for the Eagle 

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28 (Reynolds, 2010) Personal communication from W. Reynolds (U.S. Bureau of Land 

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31 

32 (Richards, 2009a) Richards, S. Personal communication from Susan Richards (Air Quality 

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34 Accession No. ML101800358. 

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36 (Richards, 2009b) Richards, S. Personal communication from Susan Richards (Air Quality 

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41 (Ringhoff et al., 2008) Ringhoff, M., E.J. Stoner, C.C. Chambellan, and S. Mehls. “A Class III 

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44 Enrichment Services, LLC. November. 

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46 (Scott, 1982) Scott, W.E. “Surficial Geologic Map of the Eastern Snake River Plain and 

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7 (Shumar, 2004) Shumar, M.L. “Idaho Falls Subbasin Assessment and Total Maximum Daily 

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10 (Smith, 2004) Smith, R.P. “Geologic Setting of the Snake River Aquifer and Vadose Zone.” 

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13 (S.M. Stoller Corporation, 2001) S.M. Stoller Corporation. “Idaho National Laboratory 

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19 

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22 ML101800428. 

23 

24 (U.S. Census Bureau, 2009b) U.S. Census Bureau. “Land Area, Population, and Density for 

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27 

28 (U.S. Census Bureau, 2009c) U.S. Census Bureau. “County Business Patterns, 2006.” 

29 <http://www.census.gov/ftp/pub/epcd/cbp/view/cbpview.html> (Accessed October 4, 2009). 

30 ADAMS Accession No. ML101800445. 

31 

32 (U.S. Census Bureau, 2009d) U.S. Census Bureau. “GCT1901. Median Household Income: 

33 Households Data Set: 2006-2008 American Community Survey 3-Year Estimates.” 

34 <http://factfinder.census.gov/servlet/GCTTable?_bm=y&-geo_id=01000US&-_box_head_nbr= 

35 GCT1901&-ds_name=ACS_2008_3YR_G00_&-_lang=en&-mt_name=ACS_2008_3YR_G00_ 

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37 ML101800450. 

38 

39 (USDA, 2002) U.S. Department of Agriculture, Marketing Services Branch. “Idaho: Bingham 

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41 ML101800465. 

42 

43 (USDA, 2009) U.S. Department of Agriculture. “2007 Census of Agriculture: Idaho State and 

44 County Data, Volume 1, Geographic Area Series.” National Agricultural Statistics Service, 

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47 Accession No. ML101800495. 

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2 Natural Resources Conservation Service. <http://sols.usda.gov/technical/soil_orders> 

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4 

5 (USDA, 2010b) United States Department of Agriculture. “United States Department of 

6 Agriculture, Natural Resource Conservation Service, Plants Database.” 

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8 

9 (USGS, 1964) U.S. Geological Survey. “Kettle Butte, Idaho Topographic Quadrangle.” ADAMS 

10 Accession No. ML101800506. 

11 

12 (USGS, 2008a) U.S. Geological Survey. “National Seismic Hazard Maps – 2008: Peak 

13 Horizontal Acceleration (%g) with 10% Probability of Exceedance in 50 Years.” 

14 <http://gldims.cr.usgs.gov/nshmp2008/viewer.htm> (Accessed November 19, 2010). ADAMS 

15 Accession No. ML103410170.

16 

17 (USGS, 2008b) U.S. Geological Survey. “2006 Minerals Yearbook.” Prepared under a 

18 Memorandum of Understanding between the USGS and the Idaho Geological Survey. 

19 

20 (USGS, 2009a) U.S. Geological Survey. “What is Geologic Time?” 

21 <http://geomaps.wr.usgs.gov/parks/gtime/index.html> (Accessed May 15, 2009). ADAMS 

22 Accession No. ML101800515. 

23 

24 (USGS, 2009b) U.S. Geological Survey. Science in Your Watershed.” <http://water.usgs.gov/ 

25 wsc/cat/17040201.html> (Accessed May 26, 2009). ADAMS Accession No. ML101800518. 

26 

27 (USGS, 2009c) U.S. Geological Survey. “National Water Information System: USGS 13057155 

28 Snake River above Eagle Rock near Idaho Falls, Idaho – Daily Statistics.” 

29 <http://nwis.waterdata.usgs.gov/> (Accessed June 29, 2009). ADAMS Accession No. 

30 ML101800527. 

31 

32 (USGS, 2009d) U.S. Geological Survey. “National Water Information System: USGS 13057155 

33 Snake River above Eagle Rock near Idaho Falls, Idaho – Monthly Statistics.” 

34 <http://nwis.waterdata.usgs.gov/> (Accessed June 29, 2009). ADAMS Accession No. 

35 ML101800531. 

36 

37 (USGS, 2009e) U.S. Geological Survey. “National Water Information System: USGS 13057155 

38 Snake River above Eagle Rock near Idaho Falls, Idaho – Peak Streamflow.” 

39 <http://nwis.waterdata.usgs.gov/> (Accessed June 29, 2009). ADAMS Accession No. 

40 ML101800533. 

41 

42 (USGS, 2009f) U.S. Geological Survey. “National Water Information System: USGS 13057155 

43 Snake River above Eagle Rock near Idaho Falls, Idaho – Annual Statistics.” 

44 <http://nwis.waterdata.usgs.gov/> (Accessed June 29, 2009). ADAMS Accession No. 

45 ML101800539. 

46 
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2 <http://gap.uidaho.edu/index.php/gap-home/Northwest-GAP> (Accessed March 16, 2010). 

3 ADAMS Accession No. ML101800542. 

4 

5 (USGS, 2010) U.S. Geological Survey. “Estimated Use of Water in the United States – County 

6 Level Data for 2005.” <http://water.usgs.gov/watuse/data/2005> (Accessed February 24, 2010). 

7 ADAMS Accession No. ML101830107. 

8 

9 (USGS and IGS, 2006) U.S. Geological Survey and Idaho Geological Survey. “Quaternary 

10 Fault and Fold Database of the United States.” <http://earthquake.usgs.gov/hazards/qfaults> 

11 (Accessed March 11, 2010). ADAMS Accession No. ML101800544. 

12 

13 (USSLWG, 2009) Upper Snake Sage-grouse Local Working Group. “Plan for Increasing Sage14 grouse Populations.” June. ADAMS Accession No. ML101800564. 

15 

16 (Westinghouse Idaho Nuclear Company, 1994) Westinghouse Idaho Nuclear Company, Inc. 

17 “Background Concentrations of Selected Metals and Radionuclides in Big Lost River Alluvium at 

18 the Idaho Chemical Processing Plant, Rev. 1.” U.S. Department of Energy Idaho Field Office. 

19 February 28. <http://ar.inel.gov/owa/search_all_by_title_2?F_title=RIVER> (Accessed 

20 March 16, 2010). 

21 

22 (Weston Geophysical Engineers, 2008) Weston Geophysical Engineers Inc. “Probabilistic 

23 Seismic Hazard Assessment – Final Report for the Eagle Rock Enrichment Facility.” Prepared 

24 for AREVA NP, Inc. October 28. 

25 

26 (Whitehead, 1994) Whitehead, R.L. “Ground Water Atlas of the United States – Idaho, Oregon, 

27 Washington. HA 730-H.” U.S. Geological Society. <http://pubs.usgs.gov/ha/ha730/ch_h/ 

28 index.html> (Accessed June 30, 2009). ADAMS Accession No. ML101800567. 

29 

30 (Wood and Low, 1988) Wood, T.R., and W.H. Low. “Solute Geochemistry of the Snake River 

31 Plain Regional Aquifer System, Idaho and Eastern Oregon.” Part of the Snake River Plain 

32 Regional Aquifer System Analysis (RASA) Project. U.S. Geological Survey Professional 

33 Paper 1408-D. 

 4-1 

Determination of the Significance of 

Potential Environmental Impacts 

A standard of significance has been established 

for assessing environmental impacts. Based on 

the Council on Environmental Quality’s 

regulations, each impact is to be assigned one 

of the following three significance levels: 

• Small: The environmental effects are not 

detectable or are so minor that they would 

neither destabilize nor noticeably alter any 

important attribute of the resource. 

• Moderate: The environmental effects are 

sufficient to noticeably alter but not destabilize 

important attributes of the resource. 

• Large: The environmental effects are clearly 

noticeable and are sufficient to destabilize 

important attributes of the resource. 

Source: NRC, 2003a. 

1 4 ENVIRONMENTAL IMPACTS 

2 

3 This chapter presents the potential environmental impacts associated with preconstruction, 

4 construction, operation, and decommissioning of the proposed AREVA Enrichment Services, 

5 LLC (AES) Eagle Rock Enrichment Facility (EREF). 

6 

7 4.1 Introduction 

8 

9 For the proposed action, this Environmental Impact Statement (EIS) considers impacts from 

10 construction activities, normal operations, credible accidents, terrorism, and decommissioning, 

11 as well as cumulative impacts and resource commitments. The impacts associated with 

12 preconstruction activities are also discussed, although, as discussed in Sections 1.2 and 4.2 of 

13 this EIS, preconstruction is not part of the proposed action. The chapter is organized by 

14 environmentally affected areas (i.e., land use, historic and cultural resources, visual and scenic 

15 resources, air quality, geology and soils, water resources, ecological resources, noise, 

16 transportation, public and occupational health, waste management, socioeconomics, and 

17 environmental justice) based on the descriptions of the preconstruction activities and the 

18 proposed action that are included in Section 2.1. The discussion of impacts on each 

19 environmentally affected area is divided into three categories – (1) preconstruction and 

20 construction, (2) operation, and (3) decontamination and decommissioning. Impacts from the 

21 intermediate time period during which both construction and operations take place are included 

22 in the sections on operations. 

23 

24 Within each resource area, those mitigation 

25 measures proposed by AES, including 

26 additional mitigation measures identified by 

27 the U.S. Nuclear Regulatory Commission 

28 (NRC) staff, are disclosed in this EIS. While 

29 the NRC cannot impose mitigation outside 

30 its regulatory authority under the Atomic 

31 Energy Act, mitigation measures have been 

32 identified within this chapter and in 

33 Chapter 5 that could potentially reduce the 

34 impacts of preconstruction and the proposed 

35 action. For the purposes of the National 

36 Environmental Policy Act of 1969, as 

37 amended (NEPA), per Title 10, “Energy,” of 

38 the U.S. Code of Federal Regulations 

39 (10 CFR) Part 51, the NRC is disclosing 

40 measures that could potentially reduce or 

41 avoid environmental impacts of 

42 preconstruction, construction, and operation 

43 of the proposed EFEF. Any mitigation 

44 measures identified by the applicant (AES) 

45 and proposed for implementation within the 

46 Environmental Report (ER) (AES, 2010a) 

47 are listed in Tables 5-1 and 5-2 in Chapter 5 

48 
 4-2 

1 and have been factored into the NRC staff’s environmental impact analysis in Chapter 4. The 

2 additional mitigation measures identified by the NRC staff, which are listed in Tables 5-3 and 

3 5-4 of Chapter 5, are not requirements being imposed upon the applicant. 

4 

5 Section 4.2 discusses potential environmental impacts of preconstruction and the proposed 

6 action under consideration in this EIS, namely the preconstruction, construction, and operation 

7 of the proposed EREF in Bonneville County, Idaho. The decontamination and decommissioning 

8 impacts discussed in Section 4.2.16 are preliminary, or estimated, for the proposed EREF. 

9 Detailed impacts from decontamination and decommissioning will be assessed by the staff at 

10 the end of the proposed EREF’s operations and prior to NRC approval to begin such activities. 

11 Under 10 CFR 70.38, the NRC requires that AES file an application for decommissioning of the 

12 proposed EREF to be filed 12 months prior to the expiration of the license. This application 

13 would include a detailed Decommissioning Plan that would take into account the extent of 

14 radiological contamination at the site and would require a separate environmental review and 

15 NEPA document. Because decontamination and decommissioning would take place well in the 

16 future, advanced technology improving the decontamination and decommissioning process may 

17 be available. In addition, this chapter discusses the potential cumulative impacts (Section 4.3) 

18 and impacts of the no-action alternative (Section 4.4). 

19 

20 The proposed EREF, if licensed, will possess and use special nuclear material, source material, 

21 and byproduct material. Environmental impacts from the proposed EREF may be radiological or 

22 nonradiological. Radiological impacts from the proposed EREF could include radiation doses to 

23 workers and members of the public from the routine operations, transportation, potential 

24 accidents, potential terrorist activities, and decommissioning and environmental impacts from 

25 potential releases to the air, soil, or water. Nonradiological impacts could include chemical 

26 hazards, emissions (e.g., vehicle fumes), occupational accidents and injuries (e.g., vehicle 

27 collisions), and workplace accidents that could occur during preconstruction, construction, 

28 operation, and decommissioning. 

29 

30 4.2 Potential Impacts of Preconstruction and the Proposed Action 

31 

32 As described in Section 2.1 of this EIS, the proposed action is the construction, operation, and 

33 decommissioning of the proposed EREF near Idaho Falls in Bonneville County, Idaho. Under 

34 the proposed action, the NRC would issue a license to AES in accordance with the 

35 requirements of 10 CFR Parts 70, 40, and 30 to possess and use source, byproduct, and 

36 special nuclear material. 

37 

38 As described in Sections 1.4.1 and 2.1.4.1, the NRC has granted an exemption (NRC, 2010a) 

39 for AES to conduct certain preconstruction (e.g., site preparation) activities prior to granting the 

40 license for the proposed EREF. The NRC staff concluded that the request by AES to perform 

41 these activities is authorized by law, will not endanger life or property or common defense and 

42 security, and is in the public interest. No core production facilities would be constructed as part 

43 of the preconstruction activities. Because preconstruction and construction activities are closely 

44 related and their respective impacts are difficult to separate, Section 4.2 discusses the impacts 

45 of preconstruction and construction together for each resource area, in addition to the impacts 

46 of operation and decommissioning, although preconstruction activities are not part of the 

47 proposed action. Section 4.2.14 provides a summary of estimates regarding the apportionment 
 4-3 

1 of impacts between preconstruction (authorized under the exemption) and construction as 

2 defined by NRC (NRC, 2009a). 

3 

4 The potential environmental impacts are evaluated below for each of the potentially affected 

5 environmental resources. Sections 4.2.1 through 4.2.13 discuss impacts of preconstruction, 

6 construction, and operation. Section 4.2.14 discusses the relative contributions of 

7 preconstruction and construction activities to the impacts assessed in each environmentally 

8 affected area. Potential accident impacts are covered in Section 4.2.15. Section 4.2.16 

9 discusses the decontamination and decommissioning impacts. Section 4.2.17 discusses the 

10 impacts of carbon dioxide and greenhouse gases. Potential terrorist activities are considered in 

11 Section 4.2.18. 

12 

13 4.2.1 Land Use Impacts 

14 

15 This section describes the potential impacts on land use during preconstruction, construction, 

16 and operation of the proposed EREF. Construction of a uranium enrichment facility such as the 

17 proposed EREF would alter the current land use, which consists primarily of agricultural and 

18 undeveloped rangeland. Land use impacts would result when project activities restrict future 

19 land use activities from occurring on or near the proposed facility or when the land use for the 

20 proposed project is not compatible with local, State, or Federal land use plans. Land use 

21 impacts could also occur if the activity restricts current or planned mineral resources 

22 exploitation. The proposed 240-hectare (592-acre) EREF site would be located entirely on 

23 private land. Proposed land uses on the property must comply with the zoning requirements of 

24 Bonneville County; and the county has zoned the location as G-1 Grazing, which allows for 

25 industrial development. This zoning is intended to allow certain activities that should be 

26 removed from population centers in the county (Serr, 2009). The operation of a uranium 

27 enrichment facility is consistent with the county’s zoning. It is not anticipated that the proposed 

28 EREF preconstruction, construction, and operation would have any effect on the current land 

29 uses found on the surrounding Federal lands administered by the U.S. Bureau of Land 

30 Management (BLM) (Ennes, 2010). Land use impacts resulting from preconstruction, 

31 construction, and operation would be SMALL. 

32 

33 4.2.1.1 Preconstruction and Construction 

34 

35 Preconstruction and facility construction would result in the alteration of 240 hectares 

36 (592 acres) of land. Access to the 1700-hectare (4200-acre) property to be purchased by AES 

37 would be restricted beginning with preconstruction activities. It is probable that once 

38 preconstruction begins, all agricultural use on the proposed EREF property, including grazing 

39 and cultivation, would cease. However, similar land uses on surrounding lands would continue. 

40 As mentioned in Chapter 3, about 202 hectares (500 acres) on the proposed property are under 

41 cultivation. This area would no longer be used for agriculture, but this impact is not considered 

42 major due to the approximately 81,747 hectares (202,000 acres) of cultivated cropland found in 

43 Bonneville County (USGS, 2009). No other land uses could occur on the proposed property 

44 once preconstruction begins, other than those associated with the proposed EREF. 

45 

46 There is a potential for ongoing agricultural activities in surrounding areas to be temporarily 

47 affected by fugitive dust generated during preconstruction and construction. These offsite land 

48 use impacts could be lessened through the application of measures for fugitive dust control, 
 4-4 

1 which are discussed in Section 4.2.4.3. There is also the potential for preconstruction and 

2 construction activities to drive away some game species due to the increased activity on the 

3 proposed EREF site. This could affect successful hunting on surrounding lands because the 

4 preconstruction and construction activities would temporarily disturb game species such as 

5 pronghorn antelope, mule deer, and elk. However, these impacts on surrounding agriculture 

6 and local game would be temporary and would be SMALL. 

7 

8 The impacts of alteration of current land uses and the potential for temporary offsite land use 

9 impacts to agriculture and hunting resulting from preconstruction and construction would be 

10 SMALL. The alteration of land use would begin with preconstruction of the proposed EREF, 

11 and would continue through completion of construction. The majority (about 90 percent) of 

12 impacts to land use would occur during preconstruction when most of the land disturbance 

13 would occur. 

14 

15 4.2.1.2 Facility Operation 

16 

17 Operation of the proposed EREF would restrict land use on the proposed EREF property to the 

18 production of enriched uranium (AES, 2010a). The 1700-hectare (4200-acre) property would no 

19 longer be open to grazing and cultivation and would remain vacant (AES, 2010a). Operation of 

20 the proposed EREF is not expected to affect land use on adjacent public lands 

21 (Reynolds, 2010). Land use impacts from operation would be SMALL. 

22 

23 4.2.1.3 Mitigation Measures 

24 

25 Mitigation measures would be employed to minimize any potential impacts on offsite land use 

26 from erosion or fugitive dust. The following best management practices (BMPs), which have 

27 been identified by AES, would mitigate short-term increases in soil erosion or fugitive dust 

28 (additional discussion is provided in Section 4.2.5.3, Geology and Soils) (AES, 2010a): 

29 

30 • minimize the construction footprint to the extent practicable 

31 

32 • limit site slopes to a horizontal-vertical ratio of four to one, or less 

33 

34 • use a sedimentation detention basin 

35 

36 • protect undisturbed areas with silt fencing and straw bales, as appropriate 

37 

38 • use site stabilization practices such as placing crushed stone on disturbed soil in areas of 

39 concentrated runoff 

40 

41 • water onsite construction roads at least twice daily, when needed, to control fugitive dust 

42 emissions and, after construction is complete, stabilize the site with natural low-water43 consumption, low-maintenance landscaping and pavement 

44 

45 4.2.2 Historic and Cultural Resources Impacts 

46 

47 This section describes the potential environmental impacts on historic and cultural resources 

48 resulting from preconstruction, construction, and operation of the proposed EREF. Historic and 
 4-5 

1 cultural resources include archaeological sites, historic structures, and places of cultural 

2 importance to groups for maintaining their heritage. Cultural resources are nonrenewable; that 

3 is, once altered, the information contained in cultural resources cannot be recovered. Impacts 

4 to cultural resources at the proposed EREF site would occur primarily during initial ground5 disturbing activities. Some cultural resources could also be impacted by visual intrusions, in 

6 which case they are expected to occur primarily during construction and operation, as these are 

7 the actions that would most significantly affect the visual landscape through increased traffic 

8 and construction activities and the presence of an industrial complex. Impacts on historical and 

9 cultural resources from preconstruction, construction, and operation of the proposed EREF 

10 would range from SMALL to LARGE, although with the appropriate mitigation discussed below, 

11 the impacts would range from SMALL to MODERATE. 

12 

13 The National Historic Preservation Act of 1966, as amended (NHPA), requires that all adverse 

14 effects to National Register of Historic Places (NRHP)-eligible historic and cultural resources be 

15 considered during Federal undertakings, such as the NRC licensing activity for the proposed 

16 EREF. A resource is considered eligible for listing on the NRHP by meeting at least one of the 

17 following four criteria (36 CFR 60.4): (1) association with an historic person, (2) association with 

18 an historic event, (3) representation of the work of a master, or (4) potential to provide 

19 information on the history or prehistory of the United States. 

20 

21 Section 106 of the NHPA identifies the process for considering whether a project would affect 

22 significant cultural resources. The Area of Potential Effect for the Section 106 review for the 

23 proposed EREF project is the 240 hectares (592 acres) that would be directly affected by 

24 preconstruction and construction of the proposed EREF. The Section 106 process requires 

25 consultation between the lead Federal agency and the State Historic Preservation Office 

26 (SHPO), which is the custodian of information on cultural resources for the State. The 

27 Section 106 process also requires that Federally recognized Native American groups who have 

28 ancestral interest in the property should be consulted to determine if resources important to the 

29 tribe are present (36 CFR 800.2(4)(c)(ii)). For the proposed EREF project, Section 106 

30 consultations are currently in progress between NRC and the Idaho SHPO and between the 

31 NRC and the Shoshone-Bannock Tribes. The NRC has contacted the Idaho SHPO and the 

32 Shoshone-Bannock Tribes concerning the presence of historic and cultural resources in the 

33 areas of the proposed EREF site and of the route of the proposed electrical transmission line 

34 needed to power the proposed EREF (see Section 1.5.6.2 and Appendix B). 

35 

36 4.2.2.1 Preconstruction and Construction 

37 

38 The greatest potential for impacts on historic and cultural resources would occur during ground 

39 disturbance during preconstruction. No additional significant impacts on historic and cultural 

40 resources are anticipated during facility construction because nearly all of the ground-disturbing 

41 activities would have already occurred during preconstruction. The proposed 240-hectare 

42 (592-acre) EREF site area has been surveyed for the presence of historic and cultural 

43 resources. The surveys were documented in two reports that were provided to, and reviewed 

44 by, the Idaho SHPO (Ringhoff et al., 2008; Estes and Raley, 2009). They identified site 

45 MW004, the John Leopard Homestead, and indicated that this site may be eligible for 

46 nomination to the NRHP. The site, which is described in Section 3.3.4 of this EIS, is important 

47 for the information it could provide on the homesteading activities in the area. 

48 
 4-6 

1 The SHPO concurred with the evaluations and recommendations in the two survey reports and 

2 agreed that site MW004 is the only one of the 13 sites located in the proposed EREF site 

3 eligible for listing on the NRHP (Idaho SHPO, 2009). During scoping and in its comments on 

4 the Draft EIS, the Shoshone-Bannock Tribes indicated that it would like to be part of the cultural 

5 resource surveys of the proposed EREF site area (Shoshone-Bannock, 2009). The tribes 

6 issued no response to requests for information relevant to the cultural resources aspect of the 

7 proposed project during the consultation under Section 106 of the NHPA (see Appendix B, 

8 Section B.2). 

9 

10 Site MW004 would be directly impacted by preconstruction activities at the proposed EREF site. 

11 Preconstruction activities would completely destroy this site because it would be under the 

12 footprint of the security fence and a proposed electrical substation for a proposed transmission 

13 line that would bring power to the proposed EREF. Therefore, AES prepared a treatment plan 

14 that detailed how it would mitigate site MW004 by professional excavation and data recovery 

15 prior to disturbing site MW004 during preconstruction activities (AES, 2010e). This treatment 

16 plan was provided to the Idaho SHPO for review, and the SHPO indicated its support for the 

17 proposed treatment of site MW004 (Idaho SHPO, 2010a). 

18 

19 During preconstruction and construction activities, there is the possibility for unexpected 

20 discoveries of archaeological or human remains. Therefore, AES also commissioned the 

21 development of the Archaeological Monitoring and Discovery Plan for the EREF, AES, in 

22 Bonneville County, Idaho (Stoner et al., 2009), which specifies procedures for addressing and 

23 handling the unexpected discovery of human remains or archaeological material at the 

24 proposed EREF. This plan has also been provided to the Idaho SHPO. 

25 

26 In a letter to the Idaho SHPO dated November 17, 2010, AES’s archaeological consultant, 

27 Western Cultural Resource Management, Inc. (WCRM), provided a summary of its activities 

28 during the professional excavation of, and data recovery at, site MW004, which was conducted 

29 from October 5 to November 8, 2010 (WCRM, 2010). This mitigation serves to reduce the 

30 impact of the proposed EREF project on site MW004; however, the destruction of the site 

31 through formal professional excavation still is considered an adverse effect because the site no 

32 longer exists. In a letter dated November 26, 2010, the SHPO indicated that it had received and 

33 accepted the data recovery report (Idaho SHPO, 2010b). However, AES must receive a notice34 to-proceed from the SHPO before initiating preconstruction activities in the area of site MW004. 

35 WCRM is preparing a report detailing the results of the excavations and an analysis of the 

36 information collected from the mitigation efforts (WCRM, 2010). 

37 

38 Preconstruction and construction are not expected to impact the Wasden Complex 

39 (see Section 3.3.4 for a description of the Wasden Complex). The site is distant enough from 

40 the proposed EREF property that no effects from these activities are anticipated. Visual or 

41 noise impacts are possible, but the distance makes it unlikely that the Wasden Complex would 

42 be affected. 

43 

44 Consultation among the NRC, the SHPO, the Shoshone-Bannock Tribes, and AES is ongoing. 

45 The NRC is developing a Memorandum of Agreement (MOA) with these parties. It is planned 

46 that the NRC, the SHPO, and AES will be signatories of the MOA. In addition, the Shoshone47 Bannock Tribes has accepted the NRC’s invitation to be a concurring party on the MOA (see 

48 Appendix B, Section B.2). The draft MOA addresses the completed mitigation of site MW004, 
 4-7 

1 the completed X-ray fluorescence analysis of obsidian artifacts found at the proposed EREF site 

2 (Idaho SHPO, 2010a), and the survey by AES for historical and cultural resources of any 

3 previously un-surveyed areas that may be identified following final design. Also, the draft MOA 

4 references AES’s unanticipated discoveries and monitoring plan (Stoner et al., 2009). 

5 

6 The NRC staff initially considered that impacts on historic and cultural resources would be 

7 LARGE due to the destruction of site MW004 to accommodate preconstruction of the proposed 

8 EREF. However, since site MW004 was professionally excavated prior to ground disturbance in 

9 the area of this site, and because other examples of this particular homestead site type are 

10 found in the region (Gilbert, 2010), the impacts have been reduced to MODERATE. Impacts to 

11 other historic and cultural resources would be SMALL. The majority of impacts to historic and 

12 cultural resources would occur during preconstruction when most of the ground disturbances 

13 would occur; therefore, an estimated 90 percent of the impacts would be associated with 

14 preconstruction and only 10 percent with construction. 

15 

16 4.2.2.2 Facility Operation 

17 

18 No ground-disturbing activities are expected during operation of the proposed EREF. As a 

19 result, there is no potential for impacts on historic and cultural resources during operation. 

20 Operation is not expected to have any impact on the Wasden Complex because of its distance 

21 from the proposed EREF site. The greatest threat to the proposed site is unlawful collection of 

22 artifacts at the site by site workers; however, educating workers should minimize any effects. 

23 Therefore, impacts from operation would be SMALL. 

24 

25 4.2.2.3 Mitigation Measures 

26 

27 As discussed earlier, site MW004 was professionally excavated (with data recovery) by AES in 

28 accordance with a treatment plan supported by the SHPO (Idaho SHPO, 2010a). The Idaho 

29 SHPO received a summary of the data recovery efforts (WCRM, 2010) undertaken as mitigation 

30 (Idaho SHPO, 2010b). A report documenting the information discovered during the excavation, 

31 and an analysis of that information is being developed (WCRM, 2010). Any additional mitigation 

32 measures for historic and cultural resources, if needed, would be implemented through the 

33 Archaeological Monitoring and Discovery Plan for the EREF, AES, in Bonneville County, Idaho

34 (Stoner et al., 2009) and the MOA that is being developed. The cultural resource mitigation 

35 measures identified by AES are listed below: 

36 

37 • educate workers on the regulations governing cultural resources stressing that unauthorized 

38 collecting is prohibited. 

39 

40 • use of onsite cultural resource monitors during construction activities 

41 

42 • procedures to address unexpected discoveries of human remains or previously unidentified 

43 archaeological materials during ground-disturbing activities and procedures for the 

44 evaluation and treatment of these resources 

45 

46 • cessation of construction activities in the area around any discovery of human remains or 

47 other item of archaeological significance and notification of the State Historic Preservation 
 4-8 

1 Officer to make the determination of appropriate measures to identify, evaluate, and treat 

2 the discoveries 

3 • treatment/mitigation plan for site MW004 (recommended eligible for inclusion in the NRHP) 

4 to recover significant information on that site (professional excavation and data recovery 

5 have been conducted) 

6 

7 4.2.3 Visual and Scenic Impacts 

8 

9 This section discusses the potential visual and scenic impacts that could result from 

10 preconstruction, construction, and operation of the proposed EREF. Visual impacts result when 

11 contrasts are introduced into a visual landscape. The current visual setting of the proposed 

12 EREF site is cultivated and undeveloped rangeland. The greatest potential for visual impacts 

13 would be expected from operation of the proposed EREF, as this would represent a long-term 

14 alteration of the existing landscape. Impacts on visual and scenic resources from 

15 preconstruction, construction, and operation of the proposed EREF would range from SMALL to 

16 MODERATE. 

17 

18 Visual impacts are often difficult to characterize due to the subjective nature of what is a 

19 concern visually. Opinions can vary widely on what is visually acceptable and whether it can 

20 enhance or detract from a visual setting. The BLM has developed an effective Visual Resource 

21 Management (VRM) System (BLM, 2007). This system relies on two main components: visual 

22 resource inventories (VRIs) and visual resource management. VRIs consider the base line 

23 visual characteristics of a location. VRM is a management decision by the BLM to either 

24 preserve a visual setting or to focus on resources other than visual resource considerations for 

25 a location. A more detailed discussion of this process is provided in Section 3.2. The visual 

26 resource impact discussion that follows relies on the terminology and concepts from the BLM 

27 VRM System. 

28 

29 BLM manages the visual resources on BLM lands in the area surrounding the proposed EREF, 

30 as illustrated in Figure 4-1 and described below. BLM has designated the public lands that 

31 immediately surround the proposed EREF property as VRM Class II. This designation reflects 

32 BLM’s determination that the lands have scenic quality and that BLM will manage the lands to 

33 maintain the current visual character. Most of the BLM land south of US 20 (e.g., Hell’s Half 

34 Acre WSA) is designated by BLM as VRM Class I. VRM I areas are managed to preserve the 

35 visual character with no new visual intrusions permitted. Also, in this region, some of the land 

36 that immediately borders US 20 is managed by BLM. The land along the highway is designated 

37 as VRM III. In VRM III areas, BLM is not trying to preserve the current visual setting. 

38 

39 4.2.3.1 Preconstruction and Construction 

40 

41 Preconstruction activities would be concentrated in the proposed EREF site area. Visual 

42 impacts could result along US 20 from the increased activity at the proposed site. Fugitive dust 

43 from preconstruction activities could also create visual impacts along US 20. These impacts 

44 would be of relatively short duration, with all activities occurring during daylight hours. The 

45 clearing of vegetation and installation of a perimeter fence would change the visual setting; 

46 however, they would not significantly alter the overall appearance of the area. The vehicular 

47 traffic associated with preconstruction would not be a permanent feature of the proposed 

48 project. The Wasden Complex a significant archaeological site located 1.6 km (1 mile) from the 
 4-9

1 

Figure 4-1 VRM Classes in the Area Surrounding the Proposed EREF Site 2 

3 4 
 4-10 

1 EREF site could also be impacted visually by preconstruction and construction 

2 (see Section 3.3.4 for a description of the Wasden Complex). An intervening ridgeline, would 

3 largely shield these activities from the site. Visual impacts associated with preconstruction 

4 would be SMALL. 

5 

6 Facility construction activities would involve erecting permanent buildings. The impact of such 

7 permanent structures is discussed in the following section on facility operation. The current 

8 visual landscape does not include any industrial structures of the types proposed for the 

9 proposed EREF. Industrial buildings are present at the Idaho National Laboratory (INL), but are 

10 not visible from the proposed EREF site. Facility construction activities would begin to introduce 

11 visual intrusions that are out of character with the surrounding region. The vehicular traffic 

12 associated with construction would not be a permanent feature of the plant. These activities 

13 would have an effect on the visual landscape; however, much of the activity associated with 

14 construction would end once construction was complete. Construction activities would not be 

15 expected to affect the Wasden site because the activities would be screened by an intervening 

16 ridgeline. Construction of the proposed facility may negatively affect the visual setting as 

17 perceived by visitors to Hell’s Half Acre WSA. Construction activities would be partially visible 

18 from portions of Hell’s Half Acre WSA. However, the security lighting required at the facility 

19 would result in the greatest impact due to it being visible to night users of Hell’s Half Acre WSA 

20 (e.g., campers). 

21 

22 Visual impact levels associated with construction would range from SMALL to MODERATE. 

23 The majority of the impacts on visual and scenic resources would occur during construction 

24 (80 percent) when the taller built features are constructed; impacts associated with 

25 preconstruction are largely the result of increased activity (20 percent). 

26 

27 4.2.3.2 Facility Operation 

28 

29 The operation of the proposed EREF would have an effect on the overall visual setting of the 

30 area. The operation of a uranium enrichment facility would represent a significant visual 

31 departure from the existing visual setting. No developments of the type being proposed are 

32 currently visible near the proposed EREF site. The operation of the proposed facility would, 

33 using the BLM VRM System, be expected to lower the VRI value for the area of the proposed 

34 project. Based on the BLM VRI process, the visual landscape would be affected due to 

35 (1) sensitivity of the location for visual intrusions, (2) scenic qualities of the location, and 

36 (3) distances from which the location would be viewed (see Section 3.4 for a discussion of the 

37 VRI process). The area of the proposed project is presumed to have high sensitivity for 

38 recreational users, but lower sensitivity to the INL employees and farmers who use US 20. The 

39 scenic quality of the area is low, and the main viewing distance is roughly 2.4 kilometers 

40 (1.5 miles) away on US 20, which puts the proposed EREF site at a distance where intrusions 

41 are visible. Based on the BLM system, the impact level for operation of the plant is linked to its 

42 effect on the VRI class. BLM has indicated that the plant would reduce the relative visual value 

43 of the area (Boggs, 2010). 

44 

45 The Wasden Complex could be visually affected by the operation of the EREF. Due to an 

46 intervening ridgeline, only the top portions of the buildings would be visible from the Wasden 

47 Complex. Because only a portion of the complex would be visible, the operation of the EREF is 

48 not expected to visually affect the Wasden Complex. 

49 
 4-11 

1 Another factor to be considered in assessing the visual effect of operating a plant of this sort is 

2 the introduction of light pollution at night. Lights are perceivable over great distances in open 

3 environments like the vicinity of the proposed EREF site. The most sensitive locations where 

4 lights from the proposed EREF could be perceivable are at the trailhead for Hell’s Half Acre 

5 Wilderness Study Area (WSA) located less than 3.5 kilometers (2 miles) south of the proposed 

6 EREF and from Craters of the Moon National Park located 72 kilometers (45 miles) to the west 

7 (NPS, 2009). The perimeter lighting for the plant would be plainly visible to campers at the 

8 Hell’s Half Acre Twenty Mile Lava Trail trailhead where camping is permitted. Data is available 

9 from the National Park Service (NPS) for perception of the light dome from Craters of the Moon 

10 National Park (NPS, 2010). The NPS data show that the light from Idaho Falls is visible from 

11 the park. While the proposed EREF site is 20 miles closer to the park, it is a significantly 

12 smaller light source, and therefore is not expected to generate sufficient light that it would be 

13 perceivable from Craters of the Moon National Park. 

14 

15 The majority of those who would see the new plant are workers at INL who are not using the 

16 area for its visual qualities. The INL workers are the main group of commuters on US 20. 

17 Operation of the proposed facility may negatively affect the visual setting as perceived by 

18 visitors to Hell’s Half Acre WSA. Operation would reduce the quality of the recreational 

19 experience for campers at the Hell’s Half Acre trailhead for the duration of the proposed license. 

20 Additionally, operation would have an adverse impact on wilderness values at the Hell’s Half 

21 Acre WSA because opportunities for solitude would be reduced due to the facility being within 

22 sight of user portions of the WSA. The impact would be greatest at night when artificial light is 

23 in use. Based on the NRC staff’s review, the impact of operation of the proposed EREF on 

24 visual resources in the area of the proposed project would be MODERATE. 

25 

26 4.2.3.3 Mitigation Measures 

27 

28 Several mitigation measures have been identified by AES to reduce the effect of the proposed 

29 project on visual and scenic resources (AES, 2010a). They include the use of accepted natural 

30 low-water-consumption landscaping techniques using native landscape plantings on bare areas 

31 on the perimeter of the proposed EREF to limit any potential visual impacts, and the use of 

32 crushed stone in areas where planting is not viable. Revegetation would occur as quickly as 

33 possible during construction. Painting the proposed facility in colors that would blend with the 

34 surrounding vegetation could also reduce the contrast between the proposed EREF plant and 

35 the surrounding landscape. Creation of earthen berms or other types of visual screens made of 

36 other natural material would also help reduce the visibility of the proposed facility. To minimize 

37 light pollution, all perimeter lights would be downfacing (AES, 2010a). 

38 

39 4.2.4 Air Quality Impacts 

40 

41 Air quality impacts from the operation of construction equipment during preconstruction and 

42 facility construction were evaluated based on the construction schedules and parameters 

43 provided by AES (AES, 2010a). U.S. Environmental Protection Agency (EPA)-approved 

44 algorithms were applied to estimate emissions, and EPA-approved dispersion models were 

45 used to estimate ambient air concentrations of criteria pollutants at the proposed EREF property 

46 boundary under expected meteorological conditions. The impacts of travel to and from the 

47 EREF property by the construction workforce as well as truck deliveries of equipment and 

48 materials to the proposed EREF site were included in the evaluation. Air quality impacts during 
 4-12 

1 operation of the proposed EREF from the anticipated release of certain chemicals, the periodic 

2 operation of certain pieces of equipment such as emergency generators, and the potential 

3 release of uranium hexafluoride (UF6) from the Cascade Halls were also evaluated. The NRC 

4 staff concludes that impacts on ambient air quality from preconstruction and construction would 

5 be SMALL for all hazardous air pollutants (HAPs) and all criteria pollutants except particulates, 

6 but may be MODERATE to LARGE for particulates during certain preconstruction periods and 

7 activities, despite application of mitigation measures. However, such impacts are expected to 

8 be the result of fugitive dust generation and to occur only when fugitive dust-generating 

9 activities are actually occurring. The NRC staff further concludes that impacts on ambient air 

10 quality from the routine operation of the proposed EREF would be SMALL with respect to all 

11 criteria pollutants and all HAPs. 

12 

13 4.2.4.1 Preconstruction and Construction 

14 

15 The NRC staff anticipates that air quality impacts may occur as a result of preconstruction and 

16 construction. Criteria pollutants would be generated as a result of the onsite operation of 

17 construction vehicles and equipment burning fossil fuels in internal combustion engines and 

18 from the operation of delivery vehicles and workforce transport vehicles traveling to and from 

19 the site. Lesser amounts of criteria pollutants may be released from the operation of heating 

20 systems using external combustion sources such as boilers or furnaces. Releases of volatile 

21 organic compounds (VOCs) (nonmethane hydrocarbons) may result from many onsite activities, 

22 including the onsite storage and/or dispensing of vehicle and equipment fuels, the use of 

23 cleaning solvents, and the applications of paints and corrosion-control coatings. Lesser 

24 amounts of VOCs may be released from the storage and use of fossil fuels for comfort heating 

25 and from the use of various industrial gases for welding, brazing, and other construction-related 

26 activities. Fugitive dust may result from the disturbance of the ground surface during cut-and-fill 

27 activities, excavations for foundations and footings, burial of utilities, construction of onsite 

28 roads, operation of an onsite concrete batch plant (including delivery, storage, and handling of 

29 sand, aggregate, and cement), and travel of construction vehicles on bare ground or on 

30 unpaved onsite roads. Lesser amounts of fugitive dust may result from wind erosion of bare 

31 ground. 

32 

33 Amounts of pollutants generated and released as a result of the above-noted activities would be 

34 functions of the scope and duration of each activity, circumstantial factors such as soil types, 

35 extant pollution-control devices, prevailing meteorological conditions, and mitigations resulting 

36 from the application of BMPs and appropriate controls. Although AES has not yet developed 

37 and submitted a detailed construction plan and schedule, sufficient details have been provided 

38 to derive a reasonable approximation of the air quality impacts that may result from 

39 preconstruction and construction. A similar array of assumptions and air impact-related 

40 parameters was developed by AES and provided in the EREF Environmental Report (ER) 

41 (AES, 2010a) and in supplementary information (AES, 2009b). 

42 

43 The NRC staff evaluated the assumptions and tentative schedules used by AES in estimating 

44 construction-related air impacts and, with exceptions noted below, found them to be reasonable, 

45 generally conservative, and appropriate representations of expected activities necessary and 

46 sufficient to support construction-related air impact analyses. Relevant parameters for 

47 construction activities proposed by AES are also consistent with industrial construction activities 

48 representative of EREF preconstruction and construction. Consequently, with the exception of 
 4-13 

1 expected reductions in fugitive dust from mitigation efforts (see below), AES’s proposed 

2 construction-related parameters and schedules were used to form the basis for an assessment 

3 of air quality impacts. 

4 

5 The air emission model MOBILE 6.2, published by EPA (EPA, 2003), was used to estimate unit 

6 emissions of criteria pollutants from vehicles and equipment using fossil fuels in internal 

7 combustion engines (both compression-ignition [diesel] and spark-ignition engines). The NRC 

8 staff determined that the complement of construction support vehicles and construction vehicles 

9 and equipment proposed by AES was reasonable for the construction tasks at hand. 

10 Consequently, the number and type of vehicles proposed by AES were used to define the 

11 MOBILE 6.2 modeling inputs. Results for unit emission rates and daily emissions from 

12 construction support vehicles and construction vehicles and equipment as calculated by the 

13 NRC are displayed in Tables 4-1 and 4-2, respectively. 

14 

15 Supplemental information submitted by AES provide details of the onsite vehicle fuel storage 

16 and dispensing activities that would be occurring onsite during preconstruction and construction 

17 (AES, 2009b). Gasoline and diesel fuel would each be stored onsite in 2000-gallon 

18 aboveground steel tanks, each enclosed in reinforced concrete and each equipped with a 

19 5-gallon overfill protection feature. Estimated throughputs during construction include 

20 1325 liters (350 gallons) of gasoline per week and 37,854 liters (10,000 gallons) of diesel fuel 

21 per week. Assuming that design features that control releases of nonmethane VOCs are 

22 functional and BMPs are employed in the storage and dispensing of fuels (see Section 4.2.4.3), 

23 algorithms published in EPA AP-42, Fifth Edition, Volume 1, Chapter 7.1 (EPA, 2006a), and the 

24 EPA TANKS computer program (Version 4.09) (EPA, 2006b) predict VOC losses of 

25 312 kilograms (688 pounds) per year during construction. Because each of the tanks has a 

26 

Table 4-1 NRC’s Estimated Emissions of Criteria Pollutants from Construction 

Support Vehicles 

Vehicle Type 

Emission 

Factor 

g/km (g/mi) 

Number in 

Operationa

Daily 

Estimated 

Mileage 

km (mi)a

Daily 

Emissions 

g (lb) 

Workday 

Emission 

Rate g/s 

(lb/hr) 

Carbon monoxide 

Light-duty vehicle 

Light-duty truck I 

Light-duty truck II 

Heavy-duty truck 

13.31 (21.41) 

15.55 (25.03) 

15.60 (25.10) 

2.80 (4.50) 

40 

53 

4 

3 

16.1 (10) 

16.1 (10) 

16.1 (10) 

16.1 (10) 

8572 (18.90) 

13,269 (29.25) 

1005 (2.22) 

135 (0.30) 

0.238 (1.890) 

0.369 (2.925) 

0.028 (0.222) 

0.004 (0.030) 

Totals 22,981 (50.67) 0.638 (5.066) 

Nitrogen oxides 

Light-duty vehicle 

Light-duty truck I 

Light-duty truck II 

Heavy-duty truck 

0.66 (1.07) 

0.69 (1.12) 

0.88 (1.42) 

5.82 (9.37) 

50 

53 

4 

3 

16.1 (10) 

16.1 (10) 

16.1 (10) 

16.1 (10) 

425 (0.94) 

589 (1.30) 

57 (0.13) 

2.81 (0.62) 

0.018 (0.143) 

0.016 (0.130) 

0.002 (0.013) 

0.094 (0.744) 

Totals 1352 (2.99) 0.130 (1.029) 

a

 Source: AES, 2010a.

27 
 4-14 

Table 4-2 NRC’s Estimated Emissions of Criteria Pollutants from Construction 

Vehicles and Equipmenta,b

 Workday Emission Rate in g/s (lb/hr) 

Equipment Number Carbon 

Monoxide 

Nitrogen 

Oxides 

Sulfur 

Oxides Particulatesc

Wheeled tractor 1 0.006 (0.044) 0.015 (0.116) 0.001 (0.007) 0.001 (0.001) 

Grader 4 0.021 (0.170) 0.057 (0.450) 0.004 (0.028) 0.001 (0.004) 

Pans 5 0.023 (0.185) 0.058 (0.462) 0.004 (0.028) 0.001 (0.005) 

Wheeled loader 8 0.440 (0.350) 0.117 (0.932) 0.007 (0.057) 0.001 (0.008) 

Bulldozer 5 0.080 (0.633) 0.048 (0.380) 0.007 (0.056) 0.002 (0.015) 

Dump truck 20 0.319 (2.531) 0.191 (1.519) 0.028 (0.225) 0,008 (0.060) 

Roller 6 0.005 (0.041) 0.151 (1.197) 0.007 (0.056) 0.002 (0.013) 

Water truck 4 0.022 (0.175) 0.059 (0.466) 0.004 (0.028) 0.001 (0.004) 

Backhoe 9 0.036 (0.289) 0.094 (0.749) 0.006 (0.049) 0.001 (0.010) 

25-ton crane 3 0.037 (0.295) 0.095 (0.757) 0.004 (0.032) 0.001 (0.008) 

>25-ton crane 4 0.064 (0.506) 0.038 (0.304) 0.006 (0.045) 0.002 (0.012) 

Manlift 16 1.119 (8.877) 0.061 (0.487) 0.002 (0.016) 0.002 (0.001) 

Telehandler 5 0.350 (2.774) 0.019 (0.152) 0.001 (0.005) 0.001 (0.004) 

Concrete truck 9 0.145 (1.139) 0.086 (0.684) 0.013 (0.101) 0.003 (0.027) 

Concrete pumper truck 3 0.016 (0.128) 0.043 (0.388) 0.003 (0.021) 0.001 (0.003) 

Miscellaneous 9 0.629 (4.994) 0.035 (0.274) 0.001 (0.001) 0.001 (0.001) 

Total 111 2.914 (23.129) 1.167 (9.263) 0.097 (0.766) 0.022 (0.173) 

a

 Data displayed are the result of the application of MOBILE 6.2 to EREF construction period parameters. b

 Some rounding errors exist. 

c

 Does not include particulates released as fugitive dust.

1 

2 capacity of less than 37,854 liters (10,000 gallons), dispenses fuels with vapor pressures less 

3 than 80 mm of Hg @ 21°C, and is equipped with appropriate VOC controls, Idaho regulations 

4 categorize the tanks as insignificant sources (see IDAPA 58.01.01 Part 317.01(b)(i)(3)). The 

5 NRC staff concludes that VOC releases associated with the onsite storage and dispensation of 

6 vehicle fuels during preconstruction and construction would have a SMALL impact on air quality. 

7 

8 Fugitive dust from a variety of sources is a notable air impact from construction. Specific 

9 emission factors have been established for fugitive dust resulting primarily from vehicle travel on 

10 unpaved onsite roads (EPA, 2006c), cut-and-fill operations, aggregate handling and storage 

11 piles (EPA, 2006d), and other activities typically associated with heavy construction 

12 (EPA, 1995). EPA has also adopted guidance on adjusting emission factors to reflect local 

13 conditions in order to estimate PM10 (particulate matter ≤10 micrometers in aerodynamic 

14 diameter) and PM2.5 (particulate matter ≤2.5 micrometers in aerodynamic diameter) fractions of 

15 fugitive dust generated (MRI, 2006). Particle size distribution of fugitive dust depends on a 
 4-15 

1 number of factors, particularly the silt and moisture contents of the impacted soils. Although the 

2 proposed EREF site is characterized broadly as a semiarid environment where soils typically 

3 have low silt content, available information indicates silt content of soils on the site to be as high 

4 as 70 percent (NRCS, 2009). Correction factors published by EPA that allow estimation of PM10

5 and PM2.5 fractions of total suspended particulates (generally accepted to be represented as 

6 PM30, which is particulate matter ≤30 micrometers in aerodynamic diameter) were derived from 

7 analyses of the behavior of soils with silt content no higher than 30 percent. For such soils, 

8 EPA guidance suggests that the modeled value of pounds of particulate per vehicle miles 

9 traveled (VMT) be multiplied by correction factors of 0.306 and 0.0306 to estimate PM10 and 

10 PM2.5 fractions, respectively (MRI, 2006). However, EPA has not published correction factors 

11 for soils with exceptionally high silt content such as those present at the proposed EREF 

12 property; consequently, no additional corrections beyond those noted above are introduced in 

13 estimating PM10 and PM2.5 fractions for indigenous soils at the proposed EREF site. To 

14 estimate fugitive dust generation, the NRC assumed an average rate of fugitive dust emissions 

15 of 1.2 tons per acre per month and an average daily disturbed acreage (i.e., active construction 

16 zone as indicated by AES) to be 89.4 hectares (221 acres). Without the introduction of any 

17 mitigative controls, this would result in estimated uncontrolled releases of PM10 at a rate of 

18 97.3 grams per second (773.2 pounds per hour) and PM2.5 of 9.7 grams per second 

19 (77.3 pounds per hour) over the construction hours of operation (10 hours per day for 21 days 

20 per month). 

21 

22 As noted above, the moisture content of the soils on unpaved roads plays a significant role in 

23 the rate of fugitive dust generation. AES has committed to a mitigative strategy that involves 

24 watering onsite roads at least twice a day. AES estimates that such a watering schedule would 

25 result in a 90 percent reduction in fugitive dust generated. However, EPA estimates that 

26 achieving a 90 percent reduction in fugitive dust would require maintaining the soil moisture 

content ratio, M,1 27 well over 4.0 (see Figure 13.2.2-2 of EPA, 2006c). Given the high silt content 

28 of the soils, moisture levels that high could be expected to cause the roads to become safety 

29 hazards and even impassable in some cases. Instead, it is more reasonable to expect that a 

30 watering strategy that maintains a value for M of approximately 2.0 would be an appropriate 

31 compromise between mitigating fugitive dust to the greatest extent practical and avoiding 

32 hazardous road conditions. At an M value of approximately 2.0, a fugitive dust reduction of 

33 75 percent would be anticipated. However, this analysis does not preclude additional mitigative 

34 measures such as use of alternative dust control techniques in addition to watering that would 

35 effect a greater reduction in fugitive dust without compromising safety. Additional mitigation 

36 options that could contribute to further reductions in fugitive dust generation are discussed in 

37 Section 4.2.4.3. A 75 percent reduction in uncontrolled fugitive dust results in controlled fugitive 

38 dust releases of PM10 at a rate of 24.3 grams per second (193.3 pounds per hour) and PM2.5 of 

39 4.9 grams per second (38.7 pounds per hour). 

40 

41 The EREF development plan states that four 2500-watt diesel-fueled emergency generators 

42 and two smaller diesel-fueled generators not related to construction but intended to support 

43 facility operation would become operational while the construction phase is still ongoing 

44 (AES, 2010a). Once installed, these generators would be enrolled in a preventative 

 

1

 The moisture content ratio, M, is defined as the ratio of the moisture content of a watered roadway to 

that of an unwatered roadway (i.e., the roadway in a representative natural condition). It essentially 

represents the percentage of soil pore spaces that are filled with water. 
 4-16 

1 maintenance protocol that requires their operation for an average of 1.6 hours per week, 

2 52 weeks per year. Therefore, these generators would release criteria pollutants during both 

3 the construction and operation phases. However, none of the generators is expected to be 

4 used to provide power to support construction-related activities. To ensure the estimated 

5 impacts are conservative, emission calculations presume all six generators have nameplate 

6 ratings of 2500 watts. The generators would be exempt from permit requirements under a 

7 Category II Exemption as provided for in Section 222(01)(d) of Idaho air pollution rules 

8 (IAC, 2010). The generators would burn ultra-low-sulfur diesel fuel, the only diesel fuel 

9 expected to be available in the area through commercial vendors. Using the preventative 

10 maintenance schedule suggested by the equipment manufacturer and applying appropriate 

11 EPA-published algorithms reflective of the above assumptions, the estimated air quality impacts 

12 of the generators include: the generation of 61 kilograms per year (0.067 tons per year) of PM10, 

13 8437 kilograms per year (9.3 tons per year) of nitrogen oxides (NOx), 726 kilograms per year 

14 (0.080 ton per year) of carbon monoxide (CO), and 168 kilograms per year (0.185 ton per year) 

15 of nonmethane VOCs (AES, 2010a). Annual impacts of the above magnitude would continue 

16 throughout the operating phase of the proposed EREF and may increase if any of the 

17 generators are called into service to provide emergency power. 

18 

19 On June 17, 2009, AES submitted a request to the NRC for an exemption from 10 CFR 

20 requirements governing commencement of certain preconstruction activities. As granted by the 

21 NRC (NRC, 2010a), the exemption allows AES to undertake certain preconstruction activities 

22 prior to NRC completing its environmental review and issuing a materials license for the EREF. 

23 Activities covered under the exemption include preconstruction actions such as clearing the site; 

24 site grading and erosion control; excavating the site (including rock blasting and removal, if 

25 required); installing parking areas, stormwater control features, and utilities; and constructing 

26 permanent highway access roads, onsite roads, buildings, offices, and other structures not 

27 subject to NRC licensing authority and not radiation safety-related. 

28 

29 Collectively, the identified preconstruction activities would constitute the majority of air quality 

30 impacts associated with preconstruction and construction. The construction activities that would 

31 remain to be addressed under the NRC license include construction of the Separation Building 

32 Modules (SBMs) and installation of centrifuges and their monitoring and emission-control 

33 systems. Because these remaining construction actions can be expected to occur on a 

34 relatively small disturbed land area and utilize a reduced construction workforce, and with the 

35 major pollutant-emitting activities being completed under the exemption, the NRC staff 

36 concludes that the identified preconstruction activities would constitute as much as 90 percent 

37 of the overall impacts expected from preconstruction and construction combined. Further, 

38 commencement of the identified preconstruction activities would coincide with cessation of 

39 agricultural activities on the site, thus eliminating the seasonal air quality impacts associated 

40 with the agricultural activities (e.g., fugitive dust from field cultivation and criteria pollutant 

41 releases from operating farm vehicles and equipment). 

42 

43 Average emissions of criteria pollutants and fugitive dust for a typical construction workday are 

44 shown in Table 4-3. The estimated emissions, adjusted for local conditions, and the relevant 

45 most recently available meteorological data from the National Weather Service (NWS) were 

46 used as inputs to the EPA-approved air dispersion model, AERMOD, to estimate air quality 
 4-17 

Table 4-3 NRC’s Estimated Daily Emissions during Preconstruction and 

Construction 

Pollutant 

Total Workday 

Average Emissions

g/s (lb/hr) 

Notes 

Vehicle emissions 

Hydrocarbons 

Carbon monoxide 

Nitrogen oxides 

Sulfur oxides 

Particulates 

0.34 (2.67) 

3.55 (28.19) 

1.30 (10.29) 

0.10 (0.77) 

0.02 (0.17) 

• Includes contributions from diesel emergency 

generators installed during construction and 

enrolled in a preventative maintenance program. 

• Particulates from vehicle exhaust are assumed to 

be PM2.5. 

Fugitive dust 

PM10 

PM2.5

24.3 (193.1) 

2.43 (19.3) 

• Assumes a 75 percent reduction in fugitive dust 

from unpaved roads as a result of twice/day 

watering mitigations and maintenance of a 

moisture content ratio of 1.75. 

• Assumes an average daily disturbed acreage of 

221 acres and a 10-hour workday for 21 days 

each month. 

• Assumes an uncontrolled fugitive dust emission 

rate of 1.2 tons/acre/month. 

• Assumes fine particle size ratios of 1.5/4.9 for 

PM10 and 0.15/4.9 for PM2.5 with respect to PM30. 

1 

impacts of the preconstruction and construction phases of the proposed EREF.2 2 Local 

3 meteorological data from the NWS meteorological station located at the Idaho National 

4 Laboratory’s Materials and Fuels Complex (identified in NWS databases as the MFC station) for 

5 the period calendar year (CY) 2005 through CY 2008 and upper-level data from the NWS 

6 Automated Surface Observing Systems station located at the Boise International Airport 

7 (the closest station to the proposed EREF at which upper-level data are recorded) collected 

8 over the same period were used as meteorological data inputs. Data from the Pocatello 

9 Municipal Airport NWS station over the same time frame were used to fill gaps in the MFC data, 

10 pursuant to the AERMOD model. 

11 

12 To determine whether the estimated emission levels would cause an exceedance of an ambient 

13 air quality standard, the modeled results were added to existing ambient air quality data 

14 representative of background conditions, and the sum was compared to the National Ambient 

15 Air Quality Standards (NAAQS) (see Table 3-12). The ambient air monitoring network in Idaho 

16 is maintained by the Idaho Department of Environmental Quality (IDEQ). Not all criteria 

17 pollutants are monitored at each authorized monitoring station, and there is no monitoring 

18 station close to the proposed EREF site. Therefore, the NRC staff selected the monitoring 

19 stations closest to the EREF site for each criteria pollutant. It is important to note that the 

 

2

 Details of the model and the methodology for its application are presented in Appendix C. Additional 

descriptive information is available from the EPA Web site at http://www.epa.gov/scram001/ 

dispersion_prefrec.htm#aermod. 
 4-18 

1 closest monitoring station for particulates is in an urban setting in Pocatello. That monitoring 

2 location was determined to have a similar geographic setting to the proposed EREF site, and 

3 thus was expected to experience similar meteorological conditions over time, especially with 

4 respect to wind speeds and directions. However, because that monitoring station is in an urban 

5 setting, the potential sources of particulate emissions would be different from those expected 

6 from the proposed EREF’s rural and agricultural setting, and the Pocatello particulate monitor 

7 may not capture seasonal peaks in airborne particulates associated with agricultural activities. 

8 Thus, the monitoring results from the Pocatello station may underrepresent background 

9 particulate values at the EREF site, which is surrounded by cultivated fields. However, since no 

10 monitoring data collected in an Idaho agricultural setting was available from which to assess the 

11 magnitude of the impact agricultural activities could have on particulate values, no attempt was 

12 made to introduce correction factors reflective of these acknowledged differences. Further, EPA 

13 guidance regarding the application of AERMOD does not require that quantitative corrections be 

14 made for unique circumstantial factors or events but does recommend consideration of such 

15 factors in interpreting modeling results (EPA, 2005a). The highest values for each criteria 

16 pollutant for calendar years 2006 and 2007 were identified, and the higher of the two values was 

17 selected as a conservative representation of the background concentration for each criteria 

18 pollutant at the proposed EREF site. Selected background ambient air quality data for the 

19 impact assessment are displayed in Table 4-4. 

20 

21 Results of AERMOD modeling are displayed in Table 4-5. The results suggest that over the 

22 preconstruction and construction phases, the NAAQS for both PM10 and PM2.5 may be exceeded 

23 at the boundary of the proposed EREF property during certain meteorological conditions when 

24 actions to mitigate the release of fugitive dust from unpaved onsite roads are limited to twice25 per-day watering to the extent necessary to effect a 75 percent reduction. Modeled results at 

26 the proposed EREF property boundary show 24-hour PM10 and PM2.5 concentrations to be as 

27 high as 271.5 percent and 105.3 percent of their respective standards while all other NAAQS 

28 are satisfied. It must be noted, however, that meteorological data for the MCF station obtained 

29 from the NWS and used in the AERMOD model included wind speed data as low as 

30 0.134 meter (5.3 inches) per second, reflecting the sensitivity of the wind speed monitoring 

31 instrument used at the NWS MCF weather station. Evaluation of the modeling data suggests 

32 that exceedance of the ambient air quality standard for particulates at the proposed EREF 

33 property boundary would occur primarily during periods of very low wind speed, as might 

34 typically occur during the early morning hours over the spring and summer seasons. 

35 

36 EPA recognizes that the manner in which AERMOD conceptualizes fugitive dust dispersion at 

37 low wind speeds and evaluates impacts from low-level (i.e., ground-level) sources introduces 

38 some bias that may result in overpredictions of near-field impacts during such conditions. 

39 Independent studies are ongoing designed to demonstrate the impacts of possible modeling 

40 bias (Paine and Connors, 2009). Nevertheless, the current EPA guidance does not provide the 

41 opportunity for corrections to reflect possible low wind speed bias, and actual observed wind 

42 speeds must be used as inputs to the model when they are available. While the modeled 

43 concentrations in Table 4-5 should be viewed as representative of preconstruction and 

44 construction impacts, some consideration of possible bias is appropriate. In order to evaluate 

45 
 4-19 Table 4-4 Background Ambient Air Quality at Monitoring Stations Closest to the Proposed EREF Site Measured Ambient Background Concentrations Selected Background Concentration Pollutant Averaging Period Closest Monitoring Station Station ID 2006 2007 Carbon monoxide 1-hour Eastman Building 166 N. 9th Street Boise, ID 160010014 3.5 ppm 4.3 ppm 4.3 ppm Carbon monoxide 8-hour Eastman Building 166 N. 9th Street, Boise, ID 160010014 2.1 ppm 1.6 ppm 2.1 ppm Nitrogen dioxide Annual N. of Lancaster Road Hayden, ID 16055003 11.3 μg/m3 11.3 μg/m3 11.3 μg/m3 Sulfur dioxide 3-hour Sewage treatment plant Batiste and Chubbuck Roads Pocatello, ID 160050004 159.7 μg/m3 133.5 μg/m3 159.7 μg/m3 Sulfur dioxide 24-hour Sewage treatment plant 

Batiste and Chubbuck Roads Pocatello, ID 

160050004 62.8 μg/m3 62.8 μg/m3 62.8 μg/m3

Sulfur dioxide Annual Sewage treatment plant 

Batiste and Chubbuck Roads Pocatello, ID 

160050004 13.1 μg/m3 15.7 μg/m3 15.7 μg/m3

Particulate PM10 24-hour G&G 

Corner of Garret and Gould Pocatello, ID 

160050015 52 μg/m3 45 μg/m3 52 μg/m3

Particulate PM10 Annual G&G 

Corner of Garret and Gould Pocatello, ID 

160050015 21 μg/m3 22 μg/m3 22 μg/m3

Particulate PM2.5 24-hour G&G 

Corner of Garret and Gould Pocatello, ID 

160050015 21 μg/m3 Not detected 21 μg/m3
 4-20 Table 4-4 Background Ambient Air Quality at Monitoring Stations Closest to the Proposed EREF Site (Cont.) Measured Ambient Background Concentrations Selected Background Concentration Pollutant Averaging Period Closest Monitoring Station Station ID 2006 2007 Particulate PM2.5 Annual G&G Corner of Garret and Gould Pocatello, ID 160050015 6.4 μg/m3 Not detected 6.4 μg/m3 Sources: IDEQ annual air quality monitoring reports for the calendar years 2006 and 2007 (IDEQ, 2007 and 2008, respectively). 1 2 
 4-21 1 Table 4-5 Estimated Air Quality Impacts at the Proposed EREF Property Boundary Associated with Initial Preconstruction and Constructiona Concentration (μg/m3, except ppm for CO) Percent of Standard Pollutant Emission Rate (g/s) Averaging Time Background Modeled Maximum* Total NAAQS/ SAAQSb Modeled Maximum Total CO 3.55 1-hour 4.3 0.8 5.1 35 2.4 14.6 3.55 8-hour 2.1 0.1 2.2 9 1.5 24.9 NO2 1.3 Annual 11.3 1.0 12.3 100 1.0 12.3 SO2 0.1 3-hour 159.7 11.3 171.0 1300 0.9 13.2 0.1 24-hour 62.8 1.8 64.6 365 0.5 17.7 0.1 Annual 15.7 0.1 15.8 80 0.1 19.7 PM10 24.3 24-hour 52.0 355.2 407.2 150 236.8 271.5 24.3 Annual 22.0 15.9 37.9 50 31.8 75.8 

PM2.5 2.4 24-hour 21.0 15.9 36.9 35 45.3 105.3  2.4 Annual 6.4 1.6 8.0 15 10.5 53.2 a AERMOD model uses the following: 

• The highest of the second-highest concentrations over 5 years for CO and for 30-hr and 8-hr sulfur dioxide (SO2). 

• The highest of the annual averages over 5 years for nitrogen dioxide (NO2) and SO2. 

• The high-6th-high concentration over 5 years for 24-hr PM10. 

• The highest of multiyear average of high-8th-high at each receptor for 24-hr PM2.5, the highest of the annual averages over 

5 years for NO2 and SO2, and with a wind speed measurement sensitivity of 0.134 m/s and no default value applied for low 

wind speed. b SAAQS = State Ambient Air Quality Standards. 

2 
 4-22 

1 how AERMOD low wind speed bias might impact near-field results for the proposed EREF, the 

2 NRC staff also modeled impacts using the same emission factors, but introduced a “calm wind” 

3 default wind speed of 1.0 meter (3.3 feet) per second, allowing all other modeling parameters to 

4 remain unchanged. As expected, selection of a higher wind speed as the default value for calm 

5 wind resulted in reductions in near-field (i.e., property boundary) modeled concentrations of 

6 particulates. Table 4-6 displays the changes to modeling results that would occur if the “calm 

7 wind speed” default value was set at 1.0 meter (3.3 feet) per second. Under those conditions, 

8 only the 24-hour PM10 standard would be exceeded (by 161 percent) while all other standards 

9 are met. 

10 

11 The NRC staff concludes that preconstruction and construction would have a SMALL impact on 

12 ambient air quality for all criteria pollutants except particulates, but would have a MODERATE 

13 impact on near-field air quality (as modeled at the EREF property boundary) with respect to 

14 particulates when fugitive dust-producing construction activities (site clearing, grading, travel on 

15 unpaved onsite roads, transfer and stockpiling of materials) coincide with low prevailing wind 

16 speeds in the direction of the closest property boundary from the proposed EREF industrial 

17 area. Such wind directions are expected to occur less than 4 percent of the time (see 

18 Figure 3-11). 

19 

20 4.2.4.2 Facility Operation 

21 

22 Air Impacts during the Four-Year Overlap Period

23 

24 The plan of development for the proposed EREF calls for a 4-year period of overlap during 

25 which some limited production (i.e., enrichment of UF6) would begin before heavy construction 

26 has been completed (AES, 2010a). AES has indicated that all preconstruction work 

27 (site clearing, grading, stockpiling of materials), construction of all permanent onsite roads and 

28 parking areas (i.e., hard-surface paving for both roads and parking areas), construction of some 

29 production facilities, and construction of all ancillary faculties necessary to support full 

30 production would have been completed before the start of this overlap period (i.e., before any 

31 partial production begins) (AES, 2010a). AES indicates that construction during the overlap 

32 period would be limited to construction of the remaining SBMs, necessitating the disturbance of 

33 a relatively small land area and allowing for dramatic reductions in both the complement of 

34 construction vehicles and equipment and the construction workforce (AES, 2010a). Air quality 

35 impacts associated with continuing construction and limited facility operation would be additive 

36 during the overlap period. Air quality impacts during preconstruction and construction result 

37 primarily from the use of numerous pieces of heavy construction equipment, the disturbance of 

38 a large land area, the presence of a large construction workforce, and frequent material and 

39 equipment deliveries. With all such activities being completed or reduced during the 

40 construction/operation overlap period, the NRC staff concludes that approximately 85 percent of 

41 the air quality impacts related to preconstruction and construction would have occurred before 

42 any facility operations begin, with the remaining construction activities, approximately 

43 15 percent, occurring during the construction/operation overlap period. 

44 

45 
 4-23 Table 4-6 Sensitivity of AERMOD Dispersion Modeling Results to Low Wind Speed Default Values Concentration (μg/m3, except ppm for CO) Pollutant Averaging Time NAAQS/ SAAQSa Background Modeled Maximum at Calm Wind Default Value of 0.134 m/sec Total Percent of Standard Modeled Maximum at Calm Wind Default Value of 1.0 m/s Total Percent of Standard CO 1-hour 35 4.3 0.8 5.1 14.6 0.3 4.6 13.2 8-hour 9 2.1 0.1 2.2 24.9 0.1 2.2 24.1 NO2

b Annual 100 11.3 1.0 12.3 12.3 0.8 12.1 12.1 

SO2

b 3-hour 1300 159.7 11.3 171.0 13.2 6.3 166.0 12.8 

 24-hour 365 62.8 1.0 63.8 18.4 0.3 65.1 17.5  Annual 80 15.7 0.1 15.8 19.7 0.1 15.8 19.7 PM10 24-hour 150 52.0 355.2 407.2 271.5 189.9 241.9 161.3  Annual 50 22.0 15.9 37.9 75.8 13.1 35.1 70.2 PM2.5 24-hour 35 21.0 15.9 36.9 105.3 12.0 33.0 94.1  Annual 15 6.4 1.6 8.0 53.2 1.3 7.7 51.3 a SAAQS = State Ambient Air Quality Standards. b NO2 = nitrogen dioxide; SO2 = sulfur dioxide.

1 
 4-24 

1 Plans submitted by AES indicate that the majority of preconstruction (cut and fill, onsite road 

2 construction, trenching, and burial of components) would all be completed for the entire site 

3 during the initial construction period, before any facility operation commences, and that 

4 construction of the second, third, and fourth SBMs and other miscellaneous structures and 

5 expansions of cask storage pads would occur during the 4-year overlap period (AES, 2010a). 

6 These remaining construction activities would result in a significant reduction in the number and 

7 types of heavy-duty construction vehicles onsite, as well as a substantial reduction in workforce; 

8 thus, air quality impacts would be substantially less than impacts during the initial 

9 preconstruction and construction phase. Impacts on air quality from partial operation during the 

10 period when operation and construction overlap would be minimal. Consequently, air quality 

11 impacts during the initial preconstruction and construction phase would represent a bounding 

12 condition that would not be exceeded during any subsequent phase of facility development 

13 and/or operation, including the 4-year construction/operation overlap period. Because of the 

14 bounding nature of the air impacts of the initial construction phase, a detailed air quality impact 

15 assessment representative of the overlap period and a more detailed plan of development for 

16 the overlap period are unnecessary. 

17 

18 Generation and Release of Criteria Pollutants Resulting from EREF Operations

19 

20 Air impacts during operation include criteria pollutant releases from passenger vehicles and 

21 delivery vehicles traveling to and from the site, the periodic preventative maintenance-directed 

22 operation of emergency diesel generators (see below), and the operation of miscellaneous 

23 comfort heating systems burning fossil fuels. In its Environmental Report, AES (2010a) 

24 estimated the number of passenger vehicles involved in the workforce’s daily commute to be 

25 550 vehicles, which is equivalent to the number of individuals in the workforce (i.e., no credit 

26 taken for buses or carpools), and assumed each vehicle completes an average commute of 

80.5 kilometers (50 miles) (daily, roundtrip).3 27 AES also estimated the number and type of 

28 delivery vehicles traveling to or from the site daily to deliver materials, equipment, and feedstock 

29 and remove products and waste materials to be 36 heavy-duty trucks and estimated the 

30 average travel distance of each to be 805 kilometers (500 miles). AES has also estimated that 

31 there would be 250 workdays per year. Air impacts from the above activities were determined 

32 using the EPA-approved MOBILE 6.2 model. The NRC staff has reviewed the assumptions 

33 used by AES to define the input parameters for MOBILE 6.2 and has determined that all are 

34 reasonable and appropriate. The NRC staff confirmed the resulting air impacts through an 

35 independent analysis. The results are displayed in Table 4-7. 

36 

37 Not reflected in Table 4-7 are the incidental amounts of criteria pollutants that would result from 

38 the operation of comfort heating systems using fossil fuels such as natural gas and/or propane. 

39 However, because of the difficulty in predicting how much fuel would be consumed and because 

40 these contributions are expected to be negligible, they are not represented in Table 4-7. Also 

41 not reflected in Table 4-7 are impacts from the onsite storage and dispensing of vehicle fuels 

42 during EREF operation. Fuel consumption during operation is estimated at 568 liters 

43 (150 gallons) of gasoline per week and 568 liters (150 gallons) of diesel fuel per week. 

44 

 

3

 This assumption is consistent with the expectation that the majority of the EREF workforce would 

reside in Idaho Falls, approximately 25 miles east of the site. 
 4-25 

Table 4-7 NRC’s Estimated Emissions of Criteria Pollutants Resulting from 

Operations at the Proposed EREF 

Vehicle Type 

Emission 

Factor 

(g/mi) 

Estimated 

Daily 

Number of 

Vehicles 

Estimated 

Daily Mileage

km (mi) 

Daily Workday 

Emissions 

grams (tons) 

Nonmethane hydrocarbons

Light-duty vehicles (gasoline) 1.219 550 80 (50) 33,523 (3.7  10-2) 

Heavy-duty vehicles (diesel) 0.506 36 805 (500) 9108 (1.0  10-2)

Emergency generators NAa 6 NA 646b (7.1  10-4) 

Total 43,277 (4.78  10-2) 

Carbon monoxide

Light-duty vehicles (gasoline) 20.350 550 80 (50) 559,625 (6.17  10-1) 

Heavy-duty trucks (diesel) 2.560 36 805 (500) 46,080 (5.08  10-2) 

Emergency generators 2792c (3.1  10-3) 

Total 608,497 (6.81  10-1) 

Nitrogen oxides

Light-duty trucks (gasoline) 1.193 550 80 (50) 32,808 (3.6  10-2) 

Heavy-duty trucks (diesel) 10.292 36 805 (500) 185,256 (0.204) 

Emergency generators NA NA 32,450d (3.6  10-2) 

Total 250,514 (0.277) 

a

 NA = not applicable. 

b

 Based on the AES estimate of 168 kg/yr (0.185 tons/yr) from preventative maintenance operations. c

 Based on the AES estimate of 726 kg/yr (0.80 tons/yr) from preventative maintenance operations. d

 Based on the AES estimate of 8437 kg/yr (9.3 tons/yr) from preventative maintenance operations.

1 

2 EPA-approved algorithms predict releases of 298 kilograms (657 pounds) per year of VOCs 

3 during operation. Given the VOC control features of the tanks, their modest size, the limited 

4 volumetric throughputs, the estimated annual releases, and commitments by AES to identify 

5 and employ BMPs for the storage and dispensing of fuels (AES, 2010a), impacts on air quality 

6 from the storage and dispensing of fuels during operation would be SMALL. 

7 

8 Generation and Release of Non-Criteria Chemical Pollutants Related to EREF Operations

9 

10 In addition to the criteria pollutants released as a result of preventative maintenance testing of 

11 emergency generators, AES has identified the potential for release of certain specific chemicals 

12 as a result of routine operations of the proposed EREF (AES, 2010a). Based on the operating 

13 experiences at a European enrichment facility using the same centrifuge technology as EREF, 

14 and scaled to the number of separative work units (SWUs) represented in the currently 

15 proposed EREF design, AES estimates the following releases: 2.0 kilograms (4.4 pounds) per 
 4-26 

year of hydrogen fluoride (HF),4 1 173 kilograms (382 pounds) per year of ethanol, and 

2 1684 kilograms (3713 pounds) per year of methylene chloride. In addition to the above noted 

3 releases associated with operation of the centrifuges, the ER (AES, 2010a) also notes the 

4 potential for release of uranic materials to the atmosphere from the operation of the Liquid 

5 Effluent System Evaporator. The uranic materials in the liquid effluents discharged to the 

6 evaporator that are not removed and captured by precipitation or filtration would be evaporated 

7 to the atmosphere. AES estimates that the discharge of total uranium to the atmosphere from 

8 the evaporator would be <0.0356 grams per year (AES, 2010a). Idaho air regulations (Title 58 

9 of the Idaho Administrative Code [IAC, 2010]) establish specific controls for fluoride, ethanol, 

10 methylene chloride, and total uranium (natural isotopic distribution, both soluble and insoluble 

salts).5 11 The regulations establish occupational exposure levels (OEL), maximum allowable 

12 emission limits (EL), and acceptable ambient concentrations (AACs) for each, as shown in 

13 Table 4-8. 

14 

15 In addition to the applicable standards displayed in Table 4-8, the following allowable levels of 

16 fluoride in animal feed crops and forage crops are established in Title 58 Part 557.06: 40 ppm 

17 (dry basis, monthly), 60 ppm (dry basis, two consecutive months), and 80 ppm (dry basis, never 

18 to be exceeded) (IAC, 2010). Emissions of UF6 from the GEVSs of the SBMs will result in the 

19 formation of HF in the atmosphere. These crop fluoride accumulation standards are relevant to 

20 the proposed EREF because of the potential for animal feed or forage crops to be grown on 

21 adjacent land parcels. 

22 

23 The NRC staff evaluated whether the estimated maximum annual amount of fluoride emissions 

24 would exceed Idaho limits for the maximum rate of fluoride release, AAC for fluoride, and/or the 

25 maximum amount of fluoride accumulation on forage crops (AES, 2010a). To ensure a 

26 conservative evaluation of the maximum concentration of fluoride in air, the NRC staff assumed 

27 that release of the entire projected annual amount of HF (2 kilograms [4.4 pounds]) occurred 

28 instead within a one-month period (i.e., over a period of 720 hours instead of over 8760 hours in 

29 a year). Those conditions would result in a release rate of approximately 2.7 grams per hour 

(6.0  10-3 30 pound per hour). Thus, the maximum release rate, even over a compressed time 

31 frame, is substantially less than the allowable rate of 75.8 grams (0.167 pound) per hour in 

32 Idaho rules. Based on the European experience, AES estimated an HF concentration at the 

33 point of release of 7.7 micrograms per cubic meter. The NRC staff has independently verified 

 

4

 Trace amounts of UF6 are potentially released from the gaseous emission ventilation systems 

(GEVSs). Each mole of UF6 released will hydrolize when exposed to humidity in ambient air to form 

4 moles of HF and one mole of uranyl fluoride (UO2F2). 

5

 Releases from GEVSs would be in the form of UF6. Although the feedstock arriving at EREF would 

contain a natural distribution of uranium isotopes, as the UF6 progresses through the centrifuge chain, 

enrichment of the 235U isotope occurs and the UF6 no longer exhibits the natural isotopic ratio. UF6

could be released from any of the centrifuges in the series, and releases from a particular centrifuge 

could change over time. All such releases are collected in a common header before being sent to a 

GEVS; thus, it is difficult to ascertain the precise isotopic ratio of the collective UF6 releases arriving at 

each GEVS. However, for the purpose of this impact assessment, the Idaho standard for uranium 

releases is still presumed to apply to all GEVS releases, even though most such releases are unlikely 

to exhibit the natural isotopic distribution. 
 4-27 

Table 4-8 Idaho Chemically Specific Air Quality Standardsa

CAS 

Number Pollutant OEL (mg/m3

) 

EL 

(lb/hr) AAC 

NA Fluorideb 2.5 0.167 0.125 mg/m3

64-17-5 Ethanolb 1880 125 94 mg/m3

75-9-2 Methylene chloridec 4.1  10-6 1.6  10-3 0.24 μg/m3

7440-61-1 Uraniumb 0.2 0.013 0.01 mg/m3

a

 CAS = Chemical Abstract Service Number (unique identifier). 

NA = not applicable. 

OEL = occupational exposure level. 

EL = exposure level. 

AAC = acceptable ambient concentration (mg/m3 for noncarcinogens, μg/m3 for 

carcinogens). 

b Idaho Administrative Procedures Act (IDAPA) 58.01.01 Part 585, “Toxic Air 

Pollutants Noncarcinogenic Increments.” Uranium as natural isotopic distribution, all 

soluble and insoluble salts. 

c

 IDAPA 58.01.01 Part 586, “Toxic Air Pollutants Carcinogenic Increments.” 

1 

this concentration at the point of release (SBM rooftop),6 2 and finds it to be substantially less than 

3 the allowable 0.125 milligrams per cubic meter in Idaho rules. Dispersion even in the most 

4 stable atmospheric stability class would reduce this concentration even further at the proposed 

5 EREF property boundary, the closest possible distance for public access; thus, the public’s HF 

6 exposure potential would be well below allowable levels. 

7 

8 The amount of HF released annually, 2 kilograms (4.4 pounds), represents 100 moles of HF 

9 (1900 grams of fluoride). Coincident with the formation of 100 moles of HF will be the formation 

10 of 25 moles of uranyl fluoride (UO2F2) (7700 grams [16.9 pounds]) (equivalent to 50 moles of 

11 fluoride, or 950 grams [2 pounds]). This represents a rate of release of 2850 grams 

(6.3 pounds) of fluoride over the course of 1 year (0.33 gram per hour or 7.2  10-4 12 pound per 

13 hour (lb/hr) over the course of a year, assuming a steady rate of release over the entire year). 

14 This amount would be substantially less than the Idaho allowable amount of 5.9 grams 

15 (0.013 pound) per hour. 

16 

17 Operation of the evaporator would result in the atmospheric release of less than 0.0356 gram 

18 per year of additional uranic materials. Assuming a continuous operation of the evaporator over 

the course of the year (8760 hours/yr), the release would equate to 3.99  10-4 19 gram per hour 

(8.79  10-7 20 pound per hour). This projected release rate is also substantially below the 

allowable 1.3  10-2 21 pound per hour exposure level. Collectively, all releases of uranic materials 

22 resulting from routine operation are also substantially below the allowable exposure level. 

23 

24 The most conservative site-specific air dispersion factor calculated at the proposed EREF 

property boundary is 4.3  10-6 25 second per cubic meter. Applying that to the calculated 

maximum rate of release for HF results in a concentration of HF in air of 2.7  10-7 26 milligram per 

cubic meter (1.7.  10-14 27 pounds per cubic foot). This value is substantially less than the AAC of 

 

6

 Flow rates from the GEVS are withheld from public disclosure in accordance with 10 CFR 2.390. 
 4-28 

fluoride in ambient air of 0.125 milligram per cubic meter (8.  10-9 1 pound per cubic foot) (annual 

average) specified in Idaho Administrative Procedures Act (IDAPA) 58.01.01 Part 585.7 2 

3 

4 The highest estimated deposition factor, occurring in the northeast sector of the proposed EREF 

site, was calculated to be 2.43  10-7 5 per square meter. Applying this deposition factor to the 

6 annual fluoride emissions of 2.0 kilograms (4.4 pounds) results in an estimated maximum HF 

deposition rate of 4.9  10-7 kilogram per square meter (2.6  10-6 7 pound per square meter). 

8 Over the course of the year, this rate of deposition would be distributed over surrounding 

9 sectors in accordance with the expected wind rose (e.g., a circular diagram showing, for a 

10 specific location, the percentage of time the wind blows from each compass direction over a 

11 specified period), and the IDAPA regulatory limits would not be exceeded. 

12 

13 An annual emission of 173 kilograms (382 pounds) of ethanol represents an emission rate of 

2.0  10-2 kilogram per hour (4.4  10-2 14 pound per hour). This emission rate is less than the 

15 allowable rate of 56.7 kilograms (125 pounds) per hour contained in Idaho regulations 

16 (IAC, 2010). Applying a conservative assumption that the entire annual emissions of ethanol 

17 would occur over a 1-month period (720 hours), an emission rate of 0.24 kilogram per hour 

18 (0.53 pound per hour) would result, which is less than the allowable amount. 

19 

20 AES indicated that methylene chloride is used exclusively in small bench-top quantities to clean 

21 certain pieces of equipment on an average of 20 hours each week (based on a 5-day work 

22 week) (AES, 2010a). Of the total 5295 liters (849 gallons) of methylene chloride used each 

23 year, 4415 liters (638 gallons) would be recovered from the cleaning operation and managed as 

24 liquid hazardous waste, while an estimated 1055 kilograms (2325 pounds) would be released 

25 from the cleaning operation as vapor (AES, 2010a). Idaho rules establish a maximum allowable 

emission rate for methylene chloride of 7.2  10-5 gram per hour (1.6  10-3 26 pound per hour) and 

a maximum AAC concentration standard of 2.4  10-1 27 microgram per cubic meter 

(1.4  10-13 28 pound per cubic feet). Applying the most conservative site-specific air dispersion 

factor at the proposed EREF boundary of 4.3  10-6 29 second per cubic meter to the methylene 

30 chloride usage parameters proposed by AES, the emissions of methylene chloride would be in 

31 compliance with all applicable Idaho standards even without the application of any emission 

32 controls. The use of charcoal filters in the ventilation system serving the cleaning operation 

33 would further reduce the amount of methylene chloride actually released to the atmosphere to 

34 well below applicable standards. 

35 

36 NRC’s analysis supports the conclusion that all emission standards in Idaho regulations for 

37 noncriteria pollutants released from point sources would be satisfied during normal operation, 

38 and all Idaho standards for AAC are met at the proposed EREF property boundary. The NRC 

39 further concludes that National Ambient Air Quality Standards would also be met at the 

40 proposed EREF property boundary during normal operations. The NRC staff therefore 

41 concludes that air quality impacts during operation of the EREF would be SMALL. 

42 

 

7

 The Idaho standard is based on releases of the fluoride ion and not releases of HF. Correcting for the 

differences in weight of HF and the fluoride ion involves multiplying the amount of HF released by a 

correction faction of 18/19, or 0.95, to provide the amount of fluoride ion contained in that HF release. 

Given the five orders of magnitude difference between HF released and the fluoride standard, even 

with application of this correction factor, the HF releases are well below the fluoride standard. 
 4-29 

1 4.2.4.3 Mitigation Measures 

2 

3 Impacts from the release of criteria pollutants, aside from PM associated with fugitive dust, from 

4 the operation of vehicles and equipment during preconstruction, construction, and operation are 

5 not expected to result in exceedance of ambient air quality standards or violation of applicable 

6 stationary source standards extant in Idaho. 

7 

8 Various mitigative measures are available to reduce, or in some cases eliminate, certain air 

9 quality impacts related to preconstruction, construction, and operation. AES has identified the 

10 following mitigative options for preconstruction and construction (AES, 2010a): 

11 

12 • BMPs would be applied during preconstruction and construction to reduce fugitive dust 

13 generation to the greatest practical level; such measures would include: 

14  twice per day watering of unpaved onsite roads, excavation areas, and clearing and 

15 grading areas 

16  use of alternative dust palliatives (inorganic salts, asphaltic products, synthetic organics) 

17  established and enforced speed limits for onsite roads 

18  suspension of certain dust-producing activities during windy conditions 

19  application of gravel to the unpaved surfaces of onsite haul roads as an interim measure 

20 before permanent pavements are installed 

21  apply erosion mitigation methods in areas of disturbed soils 

22  use of water sprays at material-drop and conveyor-transfer points 

23  limit the height and disturbance of material stockpiles 

24  apply water to the surfaces of stockpiles 

25  cover open-bodied trucks that transport materials that could be sources of airborne dust 

26  promptly remove earthen materials deposited on paved roadways by wind, trucks, or 

27 earthmoving equipment 

28  promptly stabilize or cover bare areas resulting from roadway or highway interchange 

29 construction 

30 

31 To mitigate potential impacts from onsite vehicle fuel storage and dispensing during 

32 preconstruction, construction, and operation, AES has identified the following mitigation 

33 measures (AES, 2010a): 

34 

35 • BMPs would be applied to the design and operation of onsite vehicle and equipment fueling 

36 activities to minimize the release to the atmosphere of nonmethane hydrocarbons and 

37 mitigate the potential impact of spills or accidental releases; these measures would include: 

38  storage tanks would be equipped with appropriate VOC controls, liquid level gauges, 

39 and overfill protection 

40  fuel delivery drivers would receive adequate training prior to being allowed onsite 

41  appropriate warning signs would be posted at the fuel dispensing facility 

42  fuel unloading and dispensing areas would be paved and equipped with curbs to control 

43 small spills 

44  delivery contractors would carry spill kits and would be required to address minor spills 

45 during fuel deliveries 

46 

47 Mitigation measures identified by AES to control the release of volatile organic compounds and 

48 criteria pollutants during preconstruction and construction include: 
 4-30 

1 • maintaining all internal combustion engines and their pollution control devices in good 

2 working order 

3 

4 Mitigation measures identified by AES for operation include the following: 

5 

6 • install the SBM Safe-by-Design Gaseous Effluent Vent System (GEVS) and SBM Local 

7 Extraction GEVS, which are designed to collect and clean all potentially hazardous gases 

8 from the plant prior to release to the atmosphere; provide instrumentation to detect and 

9 signal, via alarm, all nonroutine process conditions, including the presence of radionuclides 

10 or HF in the exhaust stream that will trip the system to a safe condition in the event of 

11 effluent detection beyond routine operational limits 

12 

13 • install the Technical Services Building (TSB) GEVS, which is designed to collect and clean 

14 all potentially hazardous gases in the serviced areas from the TSB prior to release to the 

15 atmosphere; provide instrumentation to detect and signal the Control Room, via alarm, 

16 regarding all nonroutine process conditions, including the presence of radionuclides or HF in 

17 the exhaust stream; operators would then take appropriate actions to mitigate the release 

18 

19 • install the Centrifuge Test and Postmortem Facilities GEVSs, which are designed to collect 

20 and clean all potentially hazardous gases in the serviced areas from the Centrifuge 

21 Assembly Building prior to release to the atmosphere; provide instrumentation to detect and 

22 signal the Control Room, via alarm, regarding all nonroutine process conditions, including 

23 the presence of radionuclides or HF in the exhaust stream; operators would then take 

24 appropriate actions to mitigate the release 

25 

26 • design the TSB Contaminated Area heating, ventilating, and air conditioning (HVAC) 

27 system, the Ventilated Room HVAC system in the Blending, Sampling, and Preparation 

28 Building (BSPB), and the Centrifuge Test and Postmortem Facilities exhaust filtration 

29 system to collect and clean all potentially hazardous gases in the serviced areas prior to 

30 release to the atmosphere 

31 

32 • apply gravel to the unpaved surface of the secondary access road 

33 

34 • impose speed limits on the unpaved secondary access road 

35 

36 • maintain air concentrations of criteria pollutants resulting from vehicle emissions and fugitive 

37 dust below NAAQS 

38 

39 The NRC staff concludes that the above mitigation measures and BMPs would be sufficient to 

40 ensure that air quality impacts would remain at acceptable levels over the majority of time 

41 throughout the preconstruction and initial construction phases. Additionally, the NRC staff 

42 concludes proper application of these mitigation measures, including temporary suspension of 

43 certain dust-producing activities, would ensure that periods of potentially unacceptable levels of 

44 air impacts would be avoided. The NRC further concludes that the BMPs committed to by AES 

45 for application during the operation of the proposed EREF would be sufficient to ensure air 

46 impacts remain at acceptable levels. The following mitigation measures identified by NRC would 

47 further reduce air quality impacts: 

48 
 4-31 

1 • ensure vehicles and equipment with internal combustion engines are properly tuned and 

2 pollution control devices are functional 

3 

4 • provide first responder training to selected workers; ensure storage tanks are equipped with 

5 fully functional overflow and vapor control features 

6 

7 • install hard-surface pavements, curbs, scupper drains, and drainage ways at fuel dispensing 

8 islands that will channel spilled fuels to fire-safe containment sumps; require delivery drivers 

9 to remain in attendance throughout all fuel deliveries; require drivers to verify the proper 

10 working condition of storage tank overfill features before commencing fuel deliveries; require 

11 drivers to promptly address all spills occurring during fuel deliveries (including removal of all 

12 fuels in overfill devices after completion of fuel transfers) 

13 

14 • install emergency shut-offs for fuel dispensing pumps; post spill response directives at the 

15 fuel dispensing islands; provide spill containment and cleanup materials at the fuel 

16 dispensing islands for cleanup of small spills; ensure the fuel dispensing islands have 

17 adequate lighting 

18 

19 • adopt a policy that requires prompt cleanup of all spilled materials 

20 

21 • identify and select construction-related products and chemicals that are free of volatile 

22 solvents 

23 

24 • suspend high fugitive dust-generating activities during early morning hours with calm winds 

25 and during windy periods 

26 

27 4.2.5 Geology and Soil Impacts 

28 

29 This section describes the potential environmental impacts on geologic resources and soils 

30 during preconstruction/construction and operation of the proposed EREF. Impacts could result 

31 primarily during the preconstruction and construction phases from planned surface grading and 

32 excavation activities that loosen soil and increase the potential for erosion by wind and water. 

33 Soil compaction as a result of heavy vehicle traffic could also increase the potential for soil 

34 erosion by increasing surface runoff. Spills and inadvertent releases during all project phases 

35 could contaminate site soils. Implementation of mitigation measures would ensure that these 

36 impacts would be SMALL. Because there are no known petroleum resources or nonpetroleum 

37 mineral deposits on the proposed EREF site (see Section 3.6.1.2), impacts on geologic 

38 resources are not expected. 

39 

40 4.2.5.1 Preconstruction and Construction 

41 

42 Preconstruction and construction activities for the proposed EREF site have the potential to 

43 impact site soils in the construction area. During preconstruction, conventional earth- and rock44 moving and earth-grading equipment would be used. Blasting and mass rock excavation may 

45 also be required. Activities would include surface grading and excavation of the soils for roads, 

46 utility lines, stormwater basins, and installation of certain building foundations. 

47 
 4-32 

1 Preconstruction and construction activities would disturb a total of about 240 hectares 

2 (592 acres) within the proposed 1700-hectare (4200-acre) property, or about 14 percent of the 

3 total property area (AES, 2010a). This total includes the proposed EREF footprint of about 

4 186 hectares (460 acres) and an additional 53.6 hectares (132.5 acres) for temporary 

5 construction facilities, parking areas, material storage areas, and excavated areas for 

6 underground utilities (AES, 2010a). The proposed EREF footprint would include buildings and 

7 other permanent structures such as parking areas, retention/detention ponds, cylinder storage 

8 pads, and roads. Facility structures would have foundations and footings with depths ranging 

9 from 0.76 meter (2.5 feet) to 6.0 meters (20 feet) (AES, 2009b); utility trenches would range in 

10 depth from 0.9 meter (3 feet) to 3.7 meters (12 feet) (AES, 2009b). The remaining land, about 

11 1460 hectares (3608 acres), would be left in a natural state with no designated use for the life of 

12 the proposed facility (AES, 2010a). About 3 hectares (7.5 acres) would be landscaped, of which 

13 about 2 hectares (5 acres) would be irrigated (AES, 2009b). Areas within the proposed property 

14 boundaries currently used for irrigated crops and grazing would be taken out of service during 

15 the construction and operation of the proposed EREF (AES, 2010a). 

16 

17 The proposed EREF would be located on relatively flat terrain; however, some cut and fill would 

18 be required to bring the ground level to final grade (AES, 2010a). Onsite soils are suitable for fill 

19 and consist of a combination of soil and basaltic bedrock. Excavated soils would be used for fill 

20 at lower areas of the proposed site; no offsite disposal of soils would be required (AES, 2009b). 

21 Current plans are for a total of 778,700 cubic meters (1,018,500 cubic yards) of soil to be cut 

22 and used as fill (AES, 2010a). The deepest cut would be about 6 meters (20 feet), and the 

23 deepest fill also would be about 6 meters (20 feet) (AES, 2010a). Onsite soils would be used in 

24 site grading to the extent possible. Additional soil from offsite sources would be used to 

25 augment fill requirements of roads and structures, as needed (AES, 2009b). Approximately 

26 66,000 cubic meters (86,325 cubic yards) of clay would be brought onto the proposed EREF 

27 site from a nearby source for use as liner material for the two Cylinder Storage Pads 

28 Stormwater Retention Basins (AES, 2009b). 

29 

30 Geologic Hazards

31 

32 Preliminary site geotechnical investigations indicate that the entire area of the proposed EREF 

33 footprint is underlain by competent bedrock of basaltic lava (AES, 2010a). Subsidence due to 

34 construction is not expected; however, there is some potential for collapse due to increased 

35 loads during construction where lava tubes occur in the subsurface. Lava tubes have been 

36 observed at other locations on the Eastern Snake River Plain (ESRP) (such as that reported by 

37 Kesner, 1992). The presence of lava tubes will be considered during subsurface investigations 

38 associated with facility construction. The potential for landslides on the proposed EREF site is 

39 considered low because slopes across the proposed site are low, soils are thin or absent, and 

40 precipitation rates are low. 

41 

42 The proposed EREF site is in an area of very low seismic activity (see Section 3.6.1.1). Seismic 

43 history and geologic conditions indicate that earthquakes with a magnitude of more than 5.5 are 

44 not likely to occur within the ESRP; however, moderate to strong ground shaking from 

45 earthquakes with loci in other areas within the Basin and Range province could be felt at the 

46 proposed EREF site. The liquefaction potential of soils at the proposed EREF site is considered 

47 to be low since soils are dry or only partially saturated and groundwater at the proposed site is 

48 very deep. 
 4-33 

1 The likelihood of a volcanic event (basaltic or silicic eruption) is very low at the proposed EREF 

2 site (see Section 3.6.1.1). 

3 

4 Impacts Summary

5 

6 Preconstruction and construction activities could cause an increase in soil erosion at the 

7 proposed EREF site by loosening soils and making them more susceptible to erosion by wind 

8 action and rain, although rainfall in the vicinity of the proposed site is low. Compaction of soils 

9 due to heavy vehicle traffic could also contribute to soil erosion in some areas if infiltration rates 

10 are reduced to the point of causing increased surface runoff. Because these impacts are short11 term and can be mitigated (see Section 4.2.5.3), they would be SMALL. 

12 

13 Chemical spills or releases around vehicle maintenance and fueling locations, storage tanks, 

14 and painting operations could introduce contaminants to soils during the preconstruction and 

15 construction phase. Contaminated soils could leave the proposed site via wind or water erosion 

16 (as fugitive dust or surface runoff). Leaching of contaminated soils could affect shallow 

17 groundwater. These processes are naturally mitigated by site characteristics such as thin or 

18 absent soil coverage, a low rate of precipitation, and the absence of onsite perennial drainages 

19 (see Sections 3.6.3 and 3.7.1). They also could be controlled by following best management 

20 practices and procedures (e.g., diverting stormwater to a detention basin). For all these 

21 reasons, impacts due to chemical spills or releases at the proposed EREF site would be 

22 SMALL. 

23 

24 The majority of soil-disturbing activities (i.e., blasting, excavating, and grading) and heavy 

25 equipment traffic would occur during the preconstruction period; it is estimated, therefore, that 

26 about 95 percent of the impacts described in this section would be attributed to the 

27 preconstruction phase of development (AES, 2010a). 

28 

29 4.2.5.2 Facility Operation 

30 

31 Soil conditions would stabilize during the operations period as ground-disturbing activities 

32 associated with construction wind down and mitigation measures such as revegetation are 

33 implemented. Impacts on soils during operation of the proposed EREF would be SMALL 

34 because operations would not involve activities that increase the potential for soil erosion and 

35 the rate of soil erosion due to wind and rain would be similar for the proposed site as that for the 

36 surrounding area. 

37 

38 Releases to the atmosphere during normal operation of the proposed EREF, as discussed in 

39 Section 4.2.4.2, could contribute to a small increase in the amount of HF, ethanol, methylene 

40 chloride, and UF6 in surrounding soils as they are transported downwind. All estimated 

41 atmospheric releases of pollutants would be below the amounts allowed by permits, and the 

42 impacts on soil quality due to aerial deposition during operations would be SMALL. Therefore, 

43 operations at the proposed EREF would result in SMALL impacts on site and surrounding area 

44 soil resources. 

45 

46 
 4-34 

1 4.2.5.3 Mitigation Measures 

2 

3 Mitigation measures identified by AES (2010a) to avoid or minimize impacts due to soil erosion 

4 include: 

5 

6 • using BMPs to reduce soil erosion (e.g., earth berms, dikes, and sediment fences) 

7 

8 • revegetating or covering bare areas with natural materials promptly 

9 

10 • watering soils to control fugitive dust 

11 

12 • using standard drilling and blasting methods to reduce the potential for over-excavation, 

13 minimize damage to surrounding rock, and protect adjacent surfaces intended to remain 

14 intact 

15 

16 • placing stockpiles in an appropriate manner 

17 

18 • reusing excavated materials whenever possible 

19 

20 The NRC identified the following additional mitigation measures: 

21 

22 • minimizing the areas affected by construction to the extent possible 

23 

24 • covering stockpiles to reduce exposure to wind and rain 

25 

26 • limiting routine vehicle traffic to paved or gravel roads 

27 

28 AES would be required to comply with the provisions in the National Pollutant Discharge 

29 Elimination System (NPDES) Construction General Permit and Industrial Stormwater Permit, 

30 issued by EPA Region 10 with an oversight review by the IDEQ (AES, 2010a). The NPDES 

31 Construction General Permit requires AES also to develop a Stormwater Pollution Prevention 

32 (SWPP) Plan to identify control measures to minimize disturbed areas and protect natural site 

33 features and erodible soil (EPA 2010a). A stormwater detention basin would be used during 

34 preconstruction, construction, and operation (AES, 2009b). Following the requirements of a 

35 Spill Prevention Control and Countermeasures (SPCC) Plan would reduce the potential impacts 

36 from chemical spills or releases around vehicle maintenance and fueling locations, storage 

37 tanks, and painting operations during construction and operation, and ensure prompt and 

38 appropriate cleanup. Appropriate waste management procedures would be followed to 

39 minimize the impacts on soils from solid waste and hazardous materials that would be 

40 generated during all phases. Where practicable, a recycling program for materials suitable for 

41 recycling would be implemented. 

42 

43 4.2.6 Water Resources Impacts 

44 

45 This section discusses the potential environmental impacts on surface water and groundwater 

46 during preconstruction/construction and operation of the proposed EREF. The discussion 

47 includes the potential impact to natural drainage on and around the proposed EREF property 

48 and the effect of the proposed EREF on the regional water supply. 
 4-35 

1 During preconstruction, construction, and operation, the water supply for the proposed EREF 

2 would be obtained from onsite wells completed in the ESRP aquifer. The primary point of 

3 diversion would be the existing onsite agricultural well (Lava Well; as discussed in 

4 Section 3.7.2.3) and an additional well installed to supply potable water. No surface water 

5 sources would be used. Because the annual maximum usage rates during preconstruction, 

6 construction, and normal operations would be well below the annual water right appropriation 

7 (Carlsen, 2009), impacts on the groundwater supply would be SMALL. 

8 

9 All preconstruction and construction activities would comply with the requirements of the 

NPDES Construction General Permit8 10 (AES, 2010a). Stormwater runoff would be diverted to a 

11 stormwater detention basin (AES, 2009b). During operations, stormwater would be released to 

12 onsite detention and retention basins from the central footprint area of the proposed EREF 

13 (AES, 2010a); stormwater runoff to adjacent properties therefore would not be increased. There 

14 would be no direct discharges of wastewater to surface water or groundwater (AES, 2010a). 

15 AES would develop an SWPP Plan to identify control measures to minimize disturbed areas and 

16 protect natural site features and erodible soil. Process effluents in the Liquid Effluent Treatment 

17 System Evaporator would only be discharged by evaporation to the atmosphere (AES, 2010a). 

18 Compliance with the requirements of an SPCC Plan would minimize impacts to water quality 

19 due to potential chemical spills or releases. For these reasons, impacts on water resources 

20 would be SMALL. 

21 

22 4.2.6.1 Preconstruction and Construction 

23 

24 Water Use

25 

26 The water supply during the 12-year preconstruction and construction period would be obtained 

27 from one or more onsite wells completed in the ESRP aquifer. No surface water sources would 

28 be used. During this period, the proposed EREF would consume water to meet potable and 

29 sanitary needs, as well as for concrete mixing, dust control, compaction of fill, and watering of 

30 vegetation. None of this water would be returned to its original source. 

31 

32 Average daily water usage during the preconstruction and construction period would be about 

33 207 cubic meters (54,700 gallons), with a peak daily usage of 382 cubic meters 

34 (101,000 gallons) in the second year (Table 4-9). Water requirements for construction are 

35 expected to taper off significantly after the seventh year. Average daily water usage during the 

36 last five years of construction would be about 28 cubic meters (7326 gallons). These usage 

37 rates are within the water right appropriation that has been transferred with the proposed 

38 property for use as industrial water. The annual appropriation for industrial use is 

39 506.8 acre-feet, which is 625,000 cubic meters (165 million gallons), or about 1700 cubic meters 

40 (453,000 gallons) per day (Carlsen, 2009). 

41 

42 

 

8

 Updates on the NPDES permitting process can be viewed on the EPA’s website at 

http://cfpub.epa.gov/npdes/stormwater/noi/noidetail_new.cfm?ApplId=IDR10CI01. 
 4-36 

Table 4-9 Water Use for the Preconstruction and Construction Period

 Constructiona

Year 

Potable Water 

cubic meters 

(gallons) 

Concreteb

cubic meters 

(gallons) 

Dustc

cubic meters 

(gallons) 

Soil 

Compactiond

cubic meters 

(gallons) 

Total 

Construction

cubic meters 

(gallons) 

1 19,555 

(5,166,000) 

1216 

(321,331) 

52,466 

(13,860,000) 

16,982 

(4,486,100) 

90,219 

(23,833,431) 

2 28,141 

(7,434,000) 

3649 

(963,993) 

52,466 

(13,860,000) 

12,130 

(3,204,350) 

96,385 

(25,462,343) 

3 19,078 

(5,040,000) 

10,948 

(2,891,978) 

52,466 

(13,860,000) 

9704 

(2,563,500) 

92,196 

(24,355,478) 

4 13,832 

(3,654,000) 

72,989 

(1,927,985) 

52,466 

(13,860,000) 

4852 

(1,281,750) 

78,448 

(20,723,735) 

5 13,832 

(3,654,000) 

6082 

(1,606,655) 

52,466 

(13,860,000) 

4582 

(1,281,750) 

77,232 

(20,402,405) 

6 8347 

(2,205,000) 

4561 

(1,204,991) 

52,466 

(13,860,000) 

0 

(0) 

65,374 

(17,269,991) 

7 6677 

(1,764,000 

2433 

(642,662) 

52,466 

(13,860,000) 

0 

(0) 

61,576 

(16,266,662) 

8 6677 

(1,764,000) 

1216 

(321,331) 

26,233 

(6,930,000) 

0 

(0) 

34,127 

(9,015,331) 

9 6677 

(1,764,000) 

304 

(80,333) 

6558 

(1,732,500) 

0 

(0) 

13,540 

(3,576,833) 

10 5962 

(1,575,000) 

76 

(20,083) 

1640 

(433,125) 

0 

(0) 

7678 

(2,028,208) 

11 5008 

(1,323,000) 

19 

(5021) 

410 

(108,281) 

0 

(0) 

5437 

(1,436,302) 

12 3816 

(1,008,000) 

5 

(1255) 

102 

(27,070) 

0 

(0) 

3923 

(1,036,326) a

 Assumes 252 workdays per year for construction-related activities (5 days per week). 

b

 Assumes a usage rate of 151.4 liters (40 gal) used per cubic yard of concrete mixing and curing. c

 Assumes a usage rate of 208,198 liters (55,000 gal) per day. 

d

 Earthwork and soil compaction are assumed to be completed by the end of the 5th year. 

Source: AES, 2010a. 

2 

3 The average daily (industrial) water usage during the preconstruction and construction period 

4 would be less than 1 percent of the total daily groundwater withdrawals of 640,000 cubic meters 

5 (169 million gallons) from the ESRP aquifer in Bonneville County, as measured by the USGS in 

6 2005 (USGS, 2010). The preconstruction phase is estimated to occur during an 8-month 

7 period. 

8 
 4-37 

1 Water usage for landscaping and restoration of disturbed areas would begin in the second year 

2 of construction (2013) and continue to increase until construction is completed in 2022. AES 

3 would use xerophilic plants in landscaped areas and drought-tolerant native plants to reclaim 

4 disturbed areas. The method of irrigation would be chosen so water usage does not exceed 

5 24,670 cubic meters (6.5 million gallons) during the growing season, April 1 through October 31, 

6 as defined by the IDWR in Carlsen (2009) (AES, 2009b). This is within the appropriation for 

7 irrigation, which is 20.0 acre-feet per year, or 25,000 cubic meters (6.5 million gallons) 

8 (Carlsen, 2009). 

9 

10 Water Quality

11 

12 No wastewater would be generated or discharged during the preconstruction and construction 

13 period. Sanitary waste would be handled by portable systems until such time that the sanitary 

14 waste facility is operational. Short-term increases in sediment, oil and grease, fuel, and 

15 chemical constituents in surface (stormwater) runoff would be expected. Stormwater runoff 

16 would be collected in a stormwater detention basin in accordance with the NPDES Construction 

General Permit to contain stormwater within the boundaries of the proposed EREF property.9 17 

18 The stormwater detention basin would allow water to evaporate or infiltrate the ground surface 

19 and would overflow only during extreme rainfall events exceeding its design capacity (5.70 cm 

20 [2.22 inches] of rainfall in a 24-hour period) (AES, 2010a). Flood control measures would not be 

21 required because the site grade is above the 100- and 500-year floodplain elevations 

22 (see Section 3.7.1.3). 

23 

24 Ground-disturbing activities such as blasting, surface grading, and excavation could increase 

25 groundwater contamination by creating conduits that could accelerate downward migration of 

26 contaminants, if present. However, these activities are not expected to affect groundwater in 

27 the ESRP aquifer because they would take place at relatively shallow depths (i.e., no deeper 

28 than 6.0 meters [20 feet]) as compared to groundwater below the proposed site, which occurs at 

29 depths of 201.5 meters (661 feet) below the ground surface (see Section 3.7.2.2). 

30 

31 Chemical spills or releases around vehicle maintenance and fueling locations, storage tanks, 

32 and painting operations could infiltrate the ground surface and contaminate shallow 

33 groundwater during the preconstruction and construction phase. However, such spills and 

34 releases are not expected to affect groundwater in the ESRP aquifer because it occurs at great 

35 depths (201.5 meters [661 feet]) below the ground surface (see Section 3.7.2.2) and 

36 contaminants would likely be adsorbed by overlying soils before reaching the aquifer. 

37 

38 Impacts Summary

39 

40 During the preconstruction and construction period, the proposed EREF would consume water 

41 to meet potable and sanitary needs, as well as for concrete mixing, dust control, compaction of 

42 fill, and watering of vegetation. Water for these uses would be obtained from one or more 

43 onsite wells completed in the ESRP aquifer; no surface water would be used. Average and 

 

9

 Because site preparation and construction activities would disturb an area greater than 0.4 hectare 

(1 acre), a NPDES Construction General Permit from EPA Region 10 and an oversight review by the 

IDEQ would be required (EPA, 2010b). The permit also requires the development of a SWPP Plan 

(EPA, 2010a). 
 4-38 

1 peak daily water usages during this period would be well within the water right appropriation that 

2 has been transferred with the proposed property for use as industrial and irrigation water. The 

3 daily water usage would be less than 1 percent of the total daily groundwater withdrawals from 

4 the ESRP aquifer in Bonneville County. For these reasons, the impact to the regional water 

5 supply from water consumption during preconstruction and construction would be SMALL. 

6 

7 No wastewater would be generated or discharged during the preconstruction and construction 

8 period. Sanitary waste would be handled by portable systems until such time that the sanitary 

9 waste facility is operational. Surface water quality could be affected by short-term increases in 

10 sediment, oil and grease, fuel, and chemical constituents in surface (stormwater) runoff. 

11 Because stormwater would be diverted to an onsite detention basin, the potential for 

12 contaminated stormwater discharging to water bodies on adjacent properties is low. For these 

13 reasons, the NRC staff concludes that the impact to surface water quality would be SMALL. 

14 

15 Ground-disturbing activities have the potential to increase groundwater contamination by 

16 creating conduits that could accelerate the downward migration of contaminants, if present; 

17 chemical spills or releases could contaminate groundwater resources by infiltrating the ground 

18 surface. Because groundwater in the ESRP aquifer in the vicinity of the proposed site occurs at 

19 great depths (201.5 meters [661 feet]) and contaminants would likely be adsorbed by overlying 

20 soils before reaching the aquifer, the impact to groundwater quality would be SMALL. 

21 

22 4.2.6.2 Facility Operation 

23 

24 Water Use

25 

26 The water supply for operation of the proposed EREF would be obtained from one or more 

27 onsite wells completed in the ESRP aquifer. No surface water sources would be used. The 

28 proposed EREF would consume water to meet potable, sanitary, and process consumption 

29 needs. None of this water would be returned to its original source. 

30 

31 Average and peak daily water usage during the operation period would be about 68 cubic 

32 meters (18,100 gallons) and 1567 cubic meters (416,160 gallons), respectively (AES, 2010a). 

33 Usage rates under normal operations are within the water right appropriation that has been 

34 transferred with the proposed property for use as industrial water. The annual appropriation for 

35 industrial use is 506.8 acre-feet, which is 625,000 cubic meters (165 million gallons), or about 

36 1700 cubic meters (453,000 gallons) per day (Carlsen, 2009). Usage rate estimates under peak 

37 conditions could exceed the water right appropriation during the 8-hour period following a fire 

38 when the proposed facility would be required to refill its fire water storage tanks (with an 

39 estimated usage rate of up to 1.4 cubic meters per minute [375 gallons per minute]; AES, 

40 2010a). Both the average and peak annual water use requirements would be less than 

41 1 percent of the total groundwater withdrawals of 640,000 cubic meters (169 million gallons) per 

42 day from the ESRP aquifer in Bonneville County, (as measured by the USGS in 2005 

43 (USGS 2010). 

44 

45 Water would continue to be used for landscaping during the operations phase. AES would use 

46 xerophilic plants in landscaped areas and choose a method of irrigation that would limit water 

47 usage to no more than 24,670 cubic meters (6.5 million gallons) during the growing season, 

48 April 1 through October 31, as defined by the IDWR in Carlsen (2009) (AES, 2009b). This is 
 4-39 

1 within the appropriation for irrigation, which is 20.0 acre-feet per year, or 25,000 cubic meters 

2 (6.5 million gallons) (Carlsen, 2009). 

3 

4 During the first 7 years of construction (which includes the period when construction and 

5 operations activities overlap), the average annual water usage would be about 92,740 cubic 

6 meters (24.5 million gallons), with an estimated annual maximum of 98,460 cubic meters 

7 (26.0 million gallons) during the second year, decreasing to 85,550 cubic meters (22.6 million 

8 gallons) during the seventh year (AES, 2010a; Table 4-10). The maximum annual usage rate 

9 comprises about 16 percent of the annual water right appropriation that has been transferred 

10 with the proposed property for use as industrial water. Figure 4-2 shows the change in water 

11 usage for construction and operation during the overlap period, starting with construction in 

12 2011 and ending with full facility production in 2022. 

13 

14 The closest and largest municipalities that rely on the ESRP aquifer for drinking water are Idaho 

15 Falls (Bonneville County) and Pocatello (Bannock County). Groundwater consumption at the 

16 proposed EREF would not affect groundwater availability in these municipalities because of 

17 their location relative to the predominant groundwater flow pattern in the ESRP aquifer 

18 (see Figure 3-24; Section 3.7.2.1). Idaho Falls is hydrologically upgradient of the proposed 

19 EREF; Pocatello is on the other (southeastern) side of the Snake River, a major discharge area. 

20 

21 Water Quality

22 

23 Liquid effluent generation rates would be relatively small, and no direct discharges to surface 

24 water or groundwater would occur. Wastewater volume from all sources would be about 

25 18,800 cubic meters (5 million gallons) annually. This includes approximately 59.1 cubic meters 

26 (15,600 gallons) annually of wastewater from the Liquid Effluent Collection and Treatment 

27 System and 18,700 cubic meters (4.9 million gallons) from the Domestic Sanitary Sewage 

28 Treatment Plant. 

29 

30 The Liquid Effluent Collection and Treatment System would treat (by precipitation and filtration) 

31 liquid wastes such as laboratory wastes, floor washings, miscellaneous condensates, degreaser 

32 water, and spent citric acid and discharge them to the atmosphere by evaporation through the 

33 Liquid Effluent Treatment System Evaporator. None of these waste effluents would be 

34 discharged to the stormwater basins. Domestic sanitary sewage effluent would be discharged 

35 to the two Cylinder Storage Pads Stormwater Retention Basins. 

36 

37 Approximately 420,090 cubic meters (111 million gallons) of stormwater would be released 

38 annually to the onsite detention and retention basins from the developed central footprint area of 

39 the proposed EREF, which comprises about 164.9 hectares (407.5 acres), or 9.7 percent of the 

40 proposed site property area. In addition, about 3.9 million cubic meters (1.0 billion gallons) of 

41 annual runoff from the undeveloped areas within the proposed site property could be expected. 

42 Site drainage is intermittent and generally flows to the south; however, runoff does not 

43 discharge into any natural surface water bodies because there are no natural surface water 

44 bodies within or near the proposed EREF property and most of the water would be consumed 

45 by evapotranspiration or infiltration before it reaches the proposed property line. Water that 

46 infiltrates the ground surface may be held in soil and taken up by plant roots or eventually make 

47 its way to the water table. It is not expected, therefore, that the proposed EREF would increase 

48 stormwater runoff to adjacent properties. 
 4-40 

Table 4-10 Water Use for Overlapping Years of Construction and Operations

 Construction Operations Total

Year 

Total 

Construction 

cubic meters 

(gallons) 

Potable Water 

cubic meters 

(gallons) 

Process 

Watera

 

cubic meters 

(gallons) 

Total 

Operationsb

cubic meters 

(gallons) 

Total 

Construction 

and Operation 

cubic meters 

(gallons) 

1 90,219 

(23,833,431)

 0 

(0)

0 

(0)

0 

(0)

 90,219 

(23,833,431) 

2 96,385 

(25,462,343)

 2073 

(547,500)

0 

(0)

2073 

(547,500)

 98,458 

(26,009,843) 

3 92,196 

(24,355,478)

 4145 

(1,095,000)

1593c

(420,833)c

5738 

(1,515,833)

 97,934 

(25,871,311) 

4 78,448 

(20,723,735)

 17,409 

(4,599,000)

461 

(121,667)

17,870 

(4,720,667)

 96,318 

(25,444,402) 

5 77,232 

(20,402,405)

 17,409 

(4,599,000)

691 

(182,500)

18,100 

(4,781,500)

 95,332 

(25,183,905) 

6 65,374 

(17,269,991)

 19,896 

(5,256,000)

921 

(243,333)

20,817 

(5,499,333)

 86,191 

(22,769,324) 

7 61,576 

(16,266,662)

 22,798 

(6,022,500)

1151 

(304,167)

23,949 

(6,326,667)

 85,525 

(22,593,329) 

8 34,127 

(9,015,331)

 22,798 

(6,022,500)

1382 

(365,000)

24,179 

(6,387,500)

 58,306 

(15,402,831) 

9 13,540 

(3,576,833)

 22,798 

(6,022,500)

1554 

(410,625)

24,352 

(6,433,125)

 37,892 

(10,009,958) 

10 7678 

(2,028,208)

 22,798 

(6,022,500)

1727 

(456,250)

24,525 

(6,478,750)

 32,203 

(8,506,958) 

11 5437 

(1,436,302)

 22,798 

(6,022,500)

1900 

(501,875)

24,697 

(6,525,375)

 30,134 

(7,960,677) 

12 3923 

(1,036,326)

 22,798 

(6,022,500)

2073 

(547,500)

24,870 

(6,570,000)

 28,793 

(7,606,325) a Process water includes demineralized water, fire water, and liquid effluent water. b

 Value represents industrial water use only. Irrigation water use would not exceed 24,700 cubic meters (6.5 million 

gallons) during the growing season, April 1 through October 31. C Process (makeup and deionized) water and fire protection water values begin in the third year, just before the first 

cascade is placed into service. About 1363 cubic meters (360,000 gallons) of the process water demand value for this 

year is for a one-time fill of two Fire Water Tanks, each storing 681.5 cubic meters (180,000 gallons). 

Source: AES, 2010a.

1 

2 Liquid Effluent Collection and Treatment System

3 

4 Routine liquid effluents discharging to the Liquid Effluent Collection and Treatment System are 

5 listed in Table 4-10. Liquid process effluents would be contained on the proposed EREF site in 

6 collection tanks. Effluents in the tanks would be sampled and analyzed periodically to 

7 determine if treatment is needed before being discharged to the Liquid Effluent Treatment 

8 System Evaporator. About 59.1 cubic meters (15,600 gallons) of liquid process effluents would 
 4-41 

1 

2 Figure 4-2 Water Use during Period When Construction and Operations Activities 

3 Overlap (AES, 2010a) 

4 

5 be treated and discharged annually by evaporation to the atmosphere in the Liquid Effluent 

6 Treatment System Evaporator. Because no process effluents from plant operations would be 

7 discharged to the retention or detention basins or into surface water, the Liquid Effluent 

8 Collection and Treatment System would have a SMALL impact on water resources. 

9 

10 Cylinder Storage Pads Stormwater Retention Basins

11 

12 Treated sanitary effluents from the Domestic Sanitary Sewage Treatment Plant and stormwater 

13 runoff from the concrete-paved areas in the cylinder storage areas would be discharged to two 

14 Cylinder Storage Pads Stormwater Retention Basins, located northwest of the proposed EREF 

15 footprint (Figure 4-3). The retention basins would serve an area of about 26 hectares 

16 (63 acres); each would have a storage capacity of about 83,000 cubic meters (67 acre-feet), 

17 maintaining a freeboard of 0.3 meter (1.0 feet). Water discharged from the Domestic Sanitary 

18 Sewage Treatment Plant would consist only of treated sanitary effluents; no process-related 

19 effluents would be treated there (AES, 2010a). The retention basins would be open to the air 

20 and lined to prevent infiltration, and would have no outlets. The only discharge from the 

21 retention basins would be by evaporation to the atmosphere; no direct discharge to surface 

22 water or groundwater would occur. If necessary, residual solids would be removed for 

23 treatment and disposal (AES, 2010a). 

24 

25 A water balance of each of the retention basins (which have identical construction), including 

26 consideration of effluent and precipitation inflows and evaporation outflows, indicates that they 

27 could be dry for up to 5 months of the year (June through October), depending on annual 

28 precipitation rates. The basins would have the capacity to hold all inflows for the life of the 

29 proposed EREF. Because all of the water discharged to the Cylinder Storage Pads Stormwater 

30 Retention Basins would evaporate, the basins would have a SMALL impact on water resources. 

31 

32 
 4-42 

1 Site Stormwater Detention Basin

2 

3 Site stormwater runoff from paved surfaces (except the Cylinder Storage Pad area), building 

4 roofs, and landscaped areas would be diverted to the Site Stormwater Detention Basin located 

5 to the south of the proposed EREF footprint (Figure 4-3). The Site Stormwater Detention Basin 

6 would be unlined and would serve an area of about 139.3 hectares (344 acres). It would have a 

7 storage capacity of about 32,800 cubic meters (27 acre-feet), maintaining a freeboard of 

8 0.6 meter (2 feet). Discharges from the detention basin would occur mainly by evaporation and 

9 infiltration into the ground. The detention basin would also have an outlet that would allow 

10 overflow runoff to the surrounding ground surface (and downgradient terrain) in the event of 

11 extreme rainfall events (exceeding 24-hour, 100-year design criteria) (AES, 2010a). 

12 

13 

14 Figure 4-3 Locations of the Proposed EREF Stormwater Basins (AES, 2010a) 
 4-43 

1 A water balance of the Site Stormwater Detention Basin, including consideration of effluent and 

2 precipitation inflows and evaporation outflows, indicates that it would be dry every month of the 

3 year except during rainfall events (because the evaporation rate typically exceeds the rate of 

4 effluent and precipitation inflows except during rainfall events). Most of the water discharged 

5 into the basin would seep into the ground or evaporate and would not find its way to a natural 

6 surface water body. Water seeping into the ground from the detention basin would flow 

7 vertically downward until reaching a low-permeability layer such as a sedimentary interbed. 

8 There the water could become temporarily perched or flow laterally until the low-permeability 

9 layer pinches out or contacts a higher permeability zone (e.g., fractures in the basalt). Water 

10 would migrate from the ground surface downward in a step-like manner until it reaches the 

11 saturated zone. Further transport would depend on the transmissivity and flow direction of 

12 groundwater in the aquifer. 

13 

14 The water quality of the basin discharge would be typical of runoff from paved surfaces and 

15 building roofs from any industrial facility. Except for small amounts of soil products and grease 

16 expected from onsite traffic that would readily adsorb onto the soil, the plume would not be 

17 expected to contain contaminants. As a result, the Site Stormwater Detention Basin seepage 

18 would have a SMALL impact on water resources of the area. 

19 

20 Compliance with the requirements of an SPCC Plan would minimize the impacts due to 

21 potential spills during operations. Following standard BMPs to minimize and contain stormwater 

22 within the proposed site boundaries would also minimize impacts on offsite surface water 

23 bodies. Sanitary wastewater generated during operation of the proposed EREF would be 

24 discharged to a lined stormwater retention basin. Because natural surface water bodies are 

25 absent within and near the proposed EREF site and no wastewater would be discharged to the 

26 ground surface, water quality impacts during the operations period would be SMALL. 

27 

28 Impacts Summary

29 

30 During the operations period, the proposed EREF would consume water to meet potable, 

31 sanitary, and process consumption needs. Water for these uses would be obtained from one or 

32 more onsite wells completed in the ESRP aquifer. No surface water sources would be used. 

33 Average and peak daily water usages during normal operations are within the water right 

34 appropriation that has been transferred with the proposed property for use as industrial and 

35 irrigation water. The daily water usage would be less than 1 percent of the total daily 

36 groundwater withdrawals from the ESRP aquifer in Bonneville County. For these reasons, the 

37 impact on the regional water supply would be SMALL. 

38 

39 The maximum annual (industrial) water usage would occur during the second year of the 

40 construction and operations overlap period. Because this value represents only about 

41 16 percent of the annual water right appropriation that has been transferred with the proposed 

42 property for use as industrial water, the impact to the regional water supply would be SMALL. 

43 

44 Liquid effluent generation rates would be relatively small, and no direct discharges to surface 

45 water or groundwater would occur. Stormwater runoff does not discharge into any natural 

46 surface water bodies because there are no natural surface water bodies within or near the 

47 proposed EREF property and most of the water is consumed by evapotranspiration or infiltration 

48 before it reaches the proposed property line. Routine liquid process effluents would be treated 
 4-44 

1 and discharged only by evaporation to the atmosphere. Runoff from the cylinder storage areas 

2 would be discharged to two lined retention basins, each designed with the capacity to hold all 

3 inflows for the life of the proposed EREF. Therefore, the impacts to surface water and 

4 groundwater quality would be SMALL. 

5 

6 4.2.6.3 Mitigation Measures 

7 

8 Water Use

9 

10 Mitigation measures to minimize water use (relative to conventional practices) at the proposed 

11 EREF identified by AES (2010a) include: 

12 

13 • using low-water consumption landscaping practices 

14 

15 • implementing conservation practices when spraying water for dust control 

16 

17 • installing low-flow toilets, sinks, and showers 

18 

19 • localizing floor washing by using mops and self-contained cleaning machines 

20 

21 • incorporating closed-loop cooling systems 

22 

23 • eliminating evaporative losses and cooling tower blowdown by not using cooling towers 

24 

25 Water Quality

26 

27 Mitigation measures to minimize potential impacts on water quality identified by AES (2010a,b) 

28 include: 

29 

30 • employing BMPs to control the use of hazardous materials and fuels 

31 

32 • maintaining construction equipment in good repair, without visible leaks of oils, grease, or 

33 hydraulic fluids 

34 

35 • controlling and mitigating spills in conformance with the SPCC Plan 

36 

37 • ensuring all discharges to surface impoundments meet the standards for stormwater and 

38 treated domestic sanitary wastewater, and that no radiological discharges are made 

39 

40 • using BMPs to control stormwater runoff to prevent releases to nearby areas 

41 

42 • using BMPs for dust control associated with excavation and fill operations (water 

43 conservation would be considered when deciding how often dust suppression sprays would 

44 be applied) 

45 

46 • using silt fencing and/or sediment traps 

47 

48 • using only water (no detergents) for external vehicle washing 

49 
 4-45 

1 • placing stone construction pads at entrances/exits in areas where unpaved construction 

2 accesses adjoin a State road 

3 

4 • arranging all temporary construction basins and permanent basins to provide for prompt, 

5 systematic sampling of runoff in the event of special needs 

6 

7 • controlling water quality impacts by compliance with the NPDES Construction General 

8 Permit requirements and by applying BMPs as detailed in the site SWPP Plan 

9 

10 • implementing a SPCC Plan for the proposed facility to identify potential spill substances, 

11 sources, and responsibilities 

12 

13 • berming or self-containing all aboveground gasoline and diesel storage tanks 

14 

15 • constructing curbing, pits, or other barriers around tanks and components containing 

16 radioactive wastes 

17 

18 • handling any hazardous materials by approved methods and shipping offsite to approved 

19 disposal sites. 

20 

21 • handling sanitary wastes by portable systems until the Domestic Sanitary Sewage 

22 Treatment Plant is available for site use and providing an adequate number of these 

23 portable systems 

24 

25 • requiring control of surface water runoff for activities covered by the NPDES Construction 

26 General Permit 

27 

28 • eliminating the need to discharge treated process water to an onsite basin by using 

29 evaporators in the Liquid Effluent Collection and Treatment System 

30 

31 The NRC identified additional mitigation measures to reduce the impacts of stormwater runoff 

32 from impervious surfaces. The following mitigation measures are based on EPA (2005, 2007): 

33 

34 • reducing the size of impervious surfaces (parking lots, roads, and roofs) to the extent 

35 possible 

36 

37 • implementing a “fix it first” infrastructure policy to set spending priorities on the repair of 

38 existing infrastructure (e.g., roads) over the installation of new infrastructure 

39 

40 • employing low-impact development strategies and practices during construction and 

41 operation activities, as defined and promoted by the EPA (EPA, 2007). 

42 

43 4.2.7 Ecological Impacts 

44 

45 The potential impacts on ecological resources from preconstruction, construction, and operation 

46 of the proposed EREF are evaluated in this section. Preconstruction could result in direct 

47 impacts due to habitat loss and wildlife mortality as well as indirect impacts to ecological 

48 resources in surrounding areas primarily from fugitive dust and wildlife disturbance. Impacts 
 4-46 

1 associated with construction of facility components would primarily include wildlife disturbance 

2 and fugitive dust. Facility operations would result in impacts primarily due to wildlife 

3 disturbance. Impacts on plant communities and wildlife from preconstruction would be 

4 MODERATE. Impacts from facility construction would be SMALL, and impacts from facility 

5 operation would be SMALL. 

6 

7 According to the U.S. Fish and Wildlife Service (FWS) (FWS, 2009), no Federally listed 

8 threatened or endangered species, or critical habitat for any species, occur in the vicinity of the 

9 proposed EREF site; therefore, no impacts on these species or habitats would occur as a result 

10 of the preconstruction, construction, and operation of the proposed EREF. Similarly, no impacts 

11 on the yellow-billed cuckoo (Coccyzus americanus), a candidate species, would occur because 

12 that species does not occur in the vicinity of the proposed EREF site. The greater sage-grouse 

13 (Centrocercus urophasianus), a candidate species (FWS, 2010), occurs on the proposed 

14 property and would be affected by preconstruction, construction, and operation of the proposed 

15 EREF. Potential impacts on species identified by FWS and the Idaho Department of Fish and 

16 Game (IDFG) are summarized in Table 4-11. 

17 

18 4.2.7.1 Preconstruction and Construction 

19 

20 Preconstruction and construction activities would extend over an 84-month period, with 

21 preconstruction comprising the first 8 months. A total of approximately 240 hectares 

22 (592 acres) of the proposed, approximately 1700-hectare (4200-acre), property to be 

23 

Table 4-11 Special Status Species Identified for the Proposed EREF 

Common Name Scientific Name Statusa Impact 

Level 

Plants 

Ute ladies’-tresses Spiranthes diluvialis FT None 

Animals 

Canada lynx Lynx canadensis FT, ST None 

Utah valvata snail Valvata utahensis FE None 

Grizzly bear Ursus arctos FT, ST None 

Yellow-billed cuckoo Coccyzus americanus FC, PNS None 

Greater sage-grouse Centrocercus urophasianus FC Moderate 

Ferruginous hawk Buteo regalis SGCN, PNS Moderate 

Townsend’s big-eared bat Corynorhinus townsendii SGCN, PNS Small 

Sharp-tailed grouse Tympanuchus phasianellus SGCN Moderate 

Bald eagle Haliaeetus leucocephalus ST Small a

 FE = Federally listed as endangered, FT = Federally listed as threatened, FC = Federal 

candidates for listing as threatened or endangered, SGCN = Species of Greatest Conservation 

Need in Idaho, ST = State listed as threatened, PNS = Idaho protected nongame species. 

Source: FWS, 2010; IDFG, 2009, 2010. 
 4-47 

1 purchased by AES would be disturbed during preconstruction and facility construction. This 

2 area would include the proposed facility footprint as well as temporary construction areas such 

3 as temporary construction facilities, parking areas, material storage areas, and areas excavated 

4 for underground utilities. The proposed EREF footprint would occupy 186 hectares (460 acres) 

5 and would include buildings and other permanent structures such as parking areas, retention/ 

6 detention ponds, cylinder storage pads, and roads, and all habitats and non-mobile biota would 

7 be eliminated within this footprint. About 53.6 hectares (132.5 acres) of the disturbed area 

8 would be replanted with native plant species following the completion of construction activities 

9 (AES, 2010a). 

10 

11 Vegetation

12 

13 Plant communities would be affected by direct and indirect impacts associated with 

14 preconstruction and construction. Direct impacts would result from land clearing and grading as 

15 well as construction activities such as underground utility installation and road construction 

16 during preconstruction. All vegetation would be cleared from the proposed facility footprint, as 

17 well as from construction laydown areas and equipment assembly and staging areas. 

18 Approximately 75 hectares (185 acres) of sagebrush steppe habitat, 55 hectares (136 acres) of 

19 nonirrigated pasture, and 109 hectares (268 acres) of irrigated cropland would be eliminated by 

20 preconstruction and construction activities (AES, 2010a). Figure 4-4 shows the proposed EREF 

21 in relation to habitats on the proposed site. No rare or unique habitats, wetlands, riparian areas, 

22 or aquatic habitat would be impacted by preconstruction and construction. 

23 

24 Sagebrush steppe is the predominant plant community type in the region, and provides valuable 

25 habitat for numerous native species. The sagebrush steppe that would be lost under the 

26 proposed action is a small proportion of sagebrush (Artemisia spp.) habitat in the area 

27 (0.7 percent within an 8-kilometer [5-mile] radius of the center of the proposed EREF site) 

28 (Landscape Dynamics Lab, 1999). Because the sagebrush steppe habitat that would be lost is 

29 located adjacent to irrigated cropland and nonirrigated pasture, habitat fragmentation of this 

30 community type would be limited. 

31 

32 The exclusion of livestock from the remaining 1514 hectares (3740 acres) of the proposed 

33 property outside the proposed EREF footprint would increase species diversity and overall 

34 habitat quality in the remaining sagebrush steppe habitat. Spring forb production would likely 

35 increase with the removal of grazing, and non-native species, such as cheatgrass (Bromus 

36 tectorum), would likely decrease due to increased shading. Livestock exclusion would also 

37 likely result in an increase in native plant species in the remaining nonirrigated pasture habitat. 

38 

39 Nonirrigated pasture is a highly modified and degraded habitat, resulting from the removal of 

40 shrubs from sagebrush steppe and the planting of crested wheatgrass (Agropyron cristatum), 

41 which has become the dominant species, and other grasses. Small areas of native species are 

42 associated with rock outcrops. Because of the high degree of disturbance, this community type 

43 includes a high representation of non-native species, particularly crested wheatgrass. The loss 

44 of 55 hectares (136 acres) of this habitat type would have a negligible effect on native 

45 vegetation. 

46 

47 Fugitive dust levels would, in certain conditions, exceed NAAQS at the proposed EREF property 

48 boundary during portions of the preconstruction period (see Section 4.2.4.1). Deposition of 
 4-48 

1 

2 Figure 4-4 Proposed EREF Footprint Relative to Vegetation (AES, 2010a) 

3 

4 fugitive dust could occur in nearby offsite areas, potentially including the Hell’s Half Acre 

5 Wilderness Study Area (WSA) immediately south of the proposed EREF site near the proposed 

6 new access road entrance. Deposition of fugitive dust can adversely affect plants, potentially 

7 reducing productivity and species diversity. However, soils in the region are wind-formed soils, 

8 and plant species in native habitats are regularly exposed to wind-generated fugitive dust. 

9 Because of the smaller, finer leaf structure of the native evergreen shrubs, grasses, and forbs, 

10 they may be less susceptible to the effects of fugitive dust deposition (Hlohowskyj et al., 2004). 

11 Impacts of fugitive dust would be minor. 

12 

13 Disturbed soils could provide an opportunity for the establishment and spread of non-native 

14 invasive species. Seven non-native species have been identified on the proposed EREF 

15 property (see Section 3.8). Additional non-native species could be introduced by construction 

16 equipment. Herbicides would not be used during the preconstruction and construction period 

17 (AES, 2010a). Invasive species present in low population densities on the proposed site, such 

18 as Canada thistle (Cirsium arvense), could develop large populations during the preconstruction 

19 and construction overlap period and contribute to increased occurrences in the sagebrush 

20 steppe habitat beyond the proposed site. Although these species are known to already occur in 

21 various habitats in the region, the development of increased seed sources in disturbed areas 

22 during the preconstruction and construction period could increase the spread of these species in 

23 nearby habitats. 

24 
 4-49 

1 Stormwater runoff from construction areas could result in erosion of disturbed soils and could be 

2 a source of sedimentation. Although the release of surface runoff or sediment to areas outside 

3 of the proposed EREF site is unlikely, if sediment was released from the proposed EREF site, 

4 plant communities in adjacent areas could be adversely affected by sediment accumulation, 

5 resulting in decreased plant cover and diversity. Also, sedimentation could promote the 

6 establishment and spread of invasive species. 

7 

8 Although spills are unlikely, accidental releases of hazardous materials such as fuels, lubricants, 

9 or other materials used or stored on the proposed EREF site could adversely affect biotic 

10 communities near and downgradient from a spills. The potential impacts of a spill would depend 

11 on the material spilled, its volume, its location, the season, and the efficacy of cleanup 

12 measures. The movement of spilled materials to areas off the proposed EREF project site 

13 would be unlikely due to the infiltration capacity of soils on the proposed site. 

14 

15 Impacts on plant communities due to the loss of 75 hectares (185 acres) of sagebrush steppe 

16 habitat as a result of preconstruction and construction would be MODERATE. 

17 

18 Wildlife

19 

20 Vegetation removal and site grading would result in direct impacts on wildlife present on the 

21 proposed EREF site. Preconstruction would result in mortality of less mobile species, such as 

22 reptiles and small mammals, and nesting or burrowing species; species with greater mobility 

23 would likely be displaced to nearby suitable habitat. Increased competition in these areas could 

24 result in reduced survival of displaced individuals. The loss of 75 hectares (185 acres) of 

25 sagebrush steppe would particularly affect individuals of sagebrush obligate species that would 

26 be present at the start of preconstruction, due to their restriction to sagebrush habitats for 

27 breeding, nesting, brood-rearing, and foraging. However, species currently present on the 

28 proposed site occur throughout the region, and preconstruction and construction would not 

29 result in the local elimination of any wildlife species. 

30 

31 The sagebrush steppe community type provides habitat for numerous wildlife species. As noted 

32 above, the sagebrush steppe that would be lost under the proposed action is a small proportion 

33 of sagebrush steppe in the area (0.7 percent within an 8-kilometer [5-mile] radius of the center 

34 of the proposed EREF site). Some wildlife species are totally dependent on the sagebrush 

35 steppe ecoregion for their livelihood and are classified as sagebrush obligates. Depending on 

36 the species and specific habitat requirements, this loss of sagebrush habitat could potentially 

37 reduce available habitat for various life stages, such as breeding, nesting, brood rearing, or 

38 wintering. Pygmy rabbits (Brachylagus idahoensis), a sagebrush obligate species and Idaho 

39 species of conservation concern, live in burrows. Because they are abundant in similar habitats 

40 at the nearby INL (S.M. Stoller Corporation, 2001), pygmy rabbits may occur on the proposed 

41 site. Clearing and grading of sagebrush steppe habitat could potentially result in mortality of 

42 pygmy rabbits as well as habitat loss. 

43 

44 Migratory birds could be affected by preconstruction and construction activities. Several 

45 migratory species, such as sage thrasher (Oreoscoptes montanus), sage sparrow (Amphispiza 

46 belli), and Brewer’s sparrow (Spizella breweri), which were observed on the proposed EREF 

47 property, are also sagebrush obligate species (see Section 3.8.2). Disturbance of active nests 

48 would be unlikely due to the seasonal timing of land clearing, as clearing would occur outside 
 4-50 

1 the nesting period. However, depending on specific habitat requirements, the loss of sagebrush 

2 steppe from the proposed EREF property could reduce the amount of habitat available for 

3 nesting of some species, and could potentially reduce the local overall level of nesting success. 

4 Because these species’ populations occur over the large area of sagebrush habitat that is 

5 available in the region, population-level effects for the region would be unlikely. 

6 

7 Wildlife species with large home ranges, such as pronghorn antelope (Antilocapra americana), 

8 would likely avoid the proposed EREF site area; however, no impacts on local populations 

9 would occur due to habitat loss because of the contiguous extensive habitat available in the 

10 vicinity. Although the proposed EREF site is located within the crucial winter range for 

11 pronghorn, the total area affected, including an avoidance zone, would represent a small portion 

12 of that habitat. Migration patterns of other wildlife, such as elk (Cervus canadensis) or mule 

13 deer (Odocoileus hemionus), would not be altered due to the extensive undisturbed landscape 

14 in the region available for migratory movements. Onsite roads would present a hazard to 

15 wildlife from construction-related traffic, and traffic would increase on roads off the proposed 

16 site. Wildlife mortality from vehicles could increase; however, limiting vehicle speeds on the 

17 proposed site would help reduce impacts on wildlife (AES, 2010a). 

18 

19 Wildlife in nearby habitats would be disturbed by preconstruction and construction activity, 

20 human presence, and noise. Preconstruction and construction would result in increased noise 

21 levels from various sources, such as equipment operation during site grading 

22 (see Section 4.2.8). In addition, activities such as blasting would result in periodic high noise 

23 levels. While current background noise levels are approximately 30 A-weighted decibels (dBA), 

24 noise levels of approximately 61 dBA are estimated to occur at the north boundary of the 

25 proposed EREF property, the closest boundary to the industrial footprint of the proposed facility 

26 (for comparison, an automobile at 15 meters (50 feet) ranges from about 60 to 90 dBA; see 

27 Section 3.9.1). As a result, many wildlife species in adjacent habitats would be expected to 

28 avoid the vicinity of the proposed project site. Many species, such as migratory birds, would 

29 continue to be affected by noise throughout the 84-month preconstruction and construction 

30 period. 

31 

32 The loss of sagebrush steppe habitat would likely affect greater sage-grouse. No sage-grouse 

33 leks (breeding areas) were found during surveys of the proposed property on May 6–7, 2008 

34 (MWH, 2008a) and April 2829, 2010 (North Wind, 2010). Recommended survey dates are 

35 early March to early May (Connelly et al., 2003); specifically, lek surveys should be conducted 

36 March 25 through April 30 for low elevation areas and April 5 through May 10 for higher 

37 elevations (ISAC 2006). At approximately 5200 feet (1600 meters) MSL, the proposed EREF 

38 property could be considered a high elevation site. Surveys of the proposed EREF property 

39 indicated that the sagebrush steppe on or near the proposed property is used by the local sage40 grouse population (AES, 2010a; MWH, 2008 a,b,c; MWH, 2009). However, extensive 

41 sagebrush habitat is available in the region, and loss of habitat on the proposed site would not 

42 threaten the local sage-grouse population. 

43 

44 Sage-grouse annually migrate between seasonal use areas in southeast Idaho, and populations 

45 occupy relatively large areas (Leonard et al., 2000; BLM/DOE, 2004). In one Idaho study, 

46 conducted northeast of the proposed EREF site, the average distance sage-grouse moved from 

47 their lek was 3.5 kilometers (2.2 miles) in spring, 12.1 kilometers (7.52 miles) in summer, 

48 21.9 kilometers (13.6 miles) in fall, and 27.7 kilometers (17.2 miles) in winter 
 4-51 

1 (Leonard et al., 2000). These sage-grouse utilized large areas over the course of a year, 

2 moving an average of 107 kilometers (66.5 miles). A population may occupy a summer home 

3 range of 3 to 7 square kilometers (1-3 square miles), while a winter home range may be more 

4 than 140 square kilometers (54 square miles) (Connelly et al., 2000). 

5 

6 Sage-grouse habitat requirements include breeding habitat (consisting of nesting habitat and 

7 early brood-rearing habitat), summer late brood-rearing habitat, and fall and winter habitat. 

8 

9 Within breeding habitat, female sage-grouse may travel more than 20 kilometers (12.4 miles) 

10 from lek to nest in the spring (Connelly et al., 2000). At INL, nesting sites have been known to 

11 be up to 18 kilometers (11 miles) from leks (BLM/DOE, 2004). Studies in Idaho indicate that 

12 nesting habitat includes a grass height of 15–34 centimeters (5.9–13 inches), coverage of 

13 3–30 percent, and sagebrush height of 5879 centimeters (2331 inches) at the nest site and 

14 an overall canopy cover of 15–38 percent (Connelly et al., 2000). Guidelines for productive 

15 sage-grouse breeding habitat include a sagebrush height of 3080 centimeters (10–30 inches), 

16 varying by moisture regime, with a cover of 1525 percent, and a grass/forb height more than 

17 18 centimeters (7.1 inches) with a cover of at least 15 percent and in mesic sites greater than 

18 10 percent forb cover (Connelly et al., 2000). Greater nesting success occurs in areas of 

19 greater sagebrush canopy cover and greater height and cover of grasses 

20 (Connelly et al., 2000). Early brood-rearing habitat is usually near nesting areas and is 

21 characterized by a high species diversity and abundant forb cover with tall grasses and forbs, 

22 although sagebrush cover may be relatively open with about 14 percent cover 

23 (Connelly et al., 2000). 

24 

25 Summer habitats for sage-grouse broods include a variety of habitat types but are usually mesic 

26 areas with a relatively abundant forb component (Connelly et al., 2000). Guidelines for 

27 productive sage-grouse summer late brood-rearing habitat include a sagebrush canopy cover of 

28 10–25 percent with a height of 40–80 centimeters (16–31 inches), along with a grass/forb cover 

29 greater than 15 percent (Connelly et al., 2000), although the grass/forb cover can be greater 

30 than 60 percent (Braun et al., 2005). 

31 

32 Fall habitat is frequently located on higher north-facing slopes that provide succulent native 

33 forbs (Braun et al., 2005). Sage-grouse begin to shift toward traditional winter use areas and 

34 the increased use of areas with a sagebrush canopy cover greater than 20 percent and more 

35 than 25 centimeters (9.8 inches) tall (Braun et al., 2005). 

36 

37 Winter habitat requires an adequate sagebrush component, as this constitutes nearly the entire 

38 winter diet of sage-grouse (Connelly et al., 2000; Braun et al., 2005). Studies in Idaho indicate 

39 the sagebrush canopy above snow may range 15–26 percent with a height of 

40 26–46 centimeters (10–18 inches) above snow; studies that measured the entire canopy found 

41 a 38 percent coverage of sagebrush and a sagebrush height of 56 centimeters (22 inches) 

42 (Connelly et al., 2000). Guidelines for productive sage-grouse winter habitat include a 

43 sagebrush canopy cover of 10–30 percent and height of 25–35 centimeters (9.8–14 inches) 

44 above snow (Connelly et al., 2000). Sage-grouse tend to use south- and southwest-facing 

45 slopes in hilly areas (Braun et al., 2005). 

46 

47 The canopy coverage of Wyoming big sagebrush (Artemisia tridentata ssp. wyomingensis) on 

48 the proposed EREF property is approximately 16 percent and that of threetip sagebrush 
 4-52 

1 (Artemisia tripartita) is approximately 0.3 percent (AES, 2010a). The total areal cover of all 

2 plants, excluding mosses, is about 60 percent. The total areal cover of shrubs is about 

3 34 percent, of grasses about 20 percent, and forbs about 6 percent. The density of Wyoming 

4 big sagebrush ranges from 6000 plants per hectare (2428 per acre) for those less than 

5 40 centimeters (15.7 inches) in height to 6900 plants per hectare (2792 per acre) for those at 

6 least 40 centimeters (15.7 inches) in height. The average maximum vegetation height is about 

7 43 centimeters (17 inches). 

8 

9 Although the spatial relationships of habitat used by sage-grouse are not well understood 

10 (Braun et al., 2005), habitat characteristics can help evaluate potential use of a particular habitat 

11 by sage-grouse populations. The canopy cover and height of sagebrush on the proposed EREF 

12 property would provide suitable habitat for sage-grouse. Although the grass cover within this 

13 community would potentially provide habitat, forb production is relatively low. The proposed 

14 EREF property appears to be located within the annual range of a local sage-grouse population, 

15 and sage-grouse evidently use the proposed site. Sage-grouse were observed, and male sage16 grouse were heard, just north of the proposed property during surveys in 2008, and evidence of 

17 the presence of sage-grouse was observed on the proposed property in 2008 and 2009. The 

18 nearest known lek is located approximately 5.6 kilometers (3.5 miles) from the boundary of the 

19 proposed site, and numerous leks are located within 16 kilometers (10 miles). The loss of 

20 75 hectares (185 acres) of sagebrush steppe, plus an additional area of avoidance around the 

21 proposed EREF, could reduce available habitat for the local sage-grouse population; however, 

22 based on the size of seasonal use areas in Idaho and elsewhere, the area likely represents a 

23 small portion of seasonal habitat use. 

24 

25 The exclusion of livestock from grazing the proposed 1700-hectare (4200-acre) EREF property 

26 would result in an increase in species diversity and overall habitat quality in the remaining 

27 sagebrush steppe habitat, including an increase in available forage in the spring, especially 

28 forbs production and a decrease in non-native species, such as cheatgrass. Livestock 

29 exclusion would also likely result in an increase in native plant species in the remaining 

30 nonirrigated pasture habitat. These changes in habitat quality would likely increase the habitat 

31 value for sage-grouse. 

32 

33 Greater sage-grouse breeding behavior at lek sites can be affected by high noise levels that are 

34 more than 10 dBA above ambient levels. The nearest known lek is located approximately 

35 5.6 kilometers (3.5 miles) from the boundary of the proposed EREF site. At that distance, noise 

36 levels due to preconstruction and construction of the proposed EREF, other than from blasting, 

37 are estimated to be approximately 35 dBA (see Section 4.2.8.1). This is less than 10 dBA 

38 above the ambient levels of approximately 30 dBA, measured at the northwest corner of the 

39 proposed EREF property (see Section 3.9). In addition, recommendations for avoiding 

40 disturbance to breeding sage-grouse from construction of energy-related facilities in the Upper 

41 Snake Sage-Grouse Planning Area include maintaining a distance of at least 3.2 kilometers 

42 (2 miles) from active leks (USSLWG, 2009), while the proposed EREF site boundary is 

43 approximately 5.6 kilometers (3.5 miles) from the nearest lek. Impacts on sage-grouse from 

44 preconstruction/construction-related noise would be minimal. 

45 

46 Ferruginous hawks (Buteo regalis), an Idaho species of conservation concern, are known to 

47 nest within 8 kilometers (5 miles) of the proposed EREF site (IDFG, 2009). Impacts on this 

48 species could result from habitat loss or human disturbance in the vicinity of nesting sites. 
 4-53 

1 Ferruginous hawks hunt for small mammals, such as ground squirrels, on grassland and shrub2 steppe habitats. The average home range for breeding males in Idaho is approximately 

3 7 to 8 square kilometers (2.7 to 3.0 square miles) (IDFG, 2005). The loss of habitat as a result 

4 of proposed EREF preconstruction/construction could affect a locally nesting pair; however, 

5 grassland and shrub-steppe habitats are relatively abundant in the area. Ferruginous hawks 

6 are easily disturbed during the breeding season, and disturbance may result in nest 

7 abandonment (White and Thurow, 1985; Dechant et al., 1999). Noise and human presence 

8 associated with preconstruction and construction activities for the proposed EREF could 

9 potentially impact ferruginous hawks in the vicinity of the proposed project. 

10 

11 Townsend’s big-eared bats (Corynorhinus townsendii), an Idaho species of conservation 

12 concern, use lava tube caves, approximately 8 kilometers (5 miles) from the proposed EREF 

13 site, for roosts and winter hibernacula (IDFG, 2009). This species forages for insects, primarily 

14 moths, above shrub-steppe habitats (Pierson et al., 1999). The loss of 75 hectares (185 acres) 

15 of sagebrush steppe would constitute a small impact on the foraging habitat of local bat 

16 populations. Noise from preconstruction and facility construction would be unlikely to disturb 

17 roosting or hibernating bats. 

18 

19 The sharp-tailed grouse (Tympanuchus phasianellus), an Idaho species of conservation 

20 concern, is known to occur in the vicinity of the proposed EREF site (IDFG, 2010). The sharp21 tailed grouse does not occur throughout the Upper Snake River Plain, and its distribution in the 

22 proposed EREF site area is somewhat limited (IDFG, 2005). The loss of shrub and grass 

23 habitat as a result of vegetation clearing during preconstruction could reduce habitat used by 

24 sharp-tailed grouse in the area. No sharp-tailed grouse leks are known to occur in the vicinity of 

25 the proposed EREF site; however, disturbance from noise and human presence would affect 

26 sharp-tailed grouse use of habitat near the proposed EREF site. 

27 

28 The bald eagle (Haliaeetus leucocephalus), listed as a threatened species by the State of Idaho, 

29 nests along the Snake River and winters near open water (IDFG, 2005; FWS, 2007). Foraging 

30 is generally near rivers, lakes, or other water bodies. Disturbance during nesting is considered 

31 the greatest threat to bald eagles in Idaho (IDFG, 2005). Because bald eagles do not nest in 

32 the vicinity of the proposed EREF and winter habitat does not occur in the vicinity, the bald 

33 eagle would be unlikely to be affected by disturbance or habitat loss resulting from 

34 preconstruction or construction. 

35 

36 The implementation of BMPs and mitigation measures during construction would reduce 

37 potential impacts on wildlife on and in the vicinity of the proposed EREF. Therefore, impacts on 

38 wildlife due to preconstruction and construction would be SMALL to MODERATE. 

39 

40 Preconstruction activities would result in most (95 percent) of the habitat losses associated with 

41 development of the proposed EREF, while approximately 5 percent of habitat loss would be 

42 attributable to the construction of facility components. Preconstruction and construction are 

43 expected to extend over an 84-month time period, with the preconstruction phase estimated to 

44 comprise 10 percent of that period and facility component construction comprising 90 percent. 

45 Some impacts, such as wildlife disturbance due to noise and human presence, would occur 

46 throughout the long facility construction period. Because the greatest ecological impacts would 

47 be attributable to habitat loss and mortality associated with preconstruction activities, the 

48 estimated contribution to ecological impacts from preconstruction would be 80 percent, with 
 4-54 

1 20 percent from construction. On this basis, preconstruction would result in MODERATE 

2 impacts, and facility construction would result in SMALL impacts. 

3 

4 4.2.7.2 Facility Operation 

5 

6 Limited facility operations would begin 8 years before the end of the construction phase. 

7 Operation of the proposed EREF is assumed to continue for approximately 30 years. 

8 Permanent structures of the proposed EREF would include buildings, depleted UF6 storage 

9 pads, retention and detention basins, parking areas, and local roadways. Stormwater runoff 

10 from buildings, roads, and parking areas would be collected in a detention basin. Runoff from 

11 the Cylinder Storage Pads would be collected in two lined retention basins, which would also 

12 receive treated domestic sanitary effluent. The detention basins would have an overflow 

13 discharge, while the retention basins would be designed to prevent overflow (AES, 2010a). 

14 Potential impacts from stormwater runoff, such as erosion and sedimentation, would be 

15 minimized by the stormwater collection basins. 

16 

17 Vegetation

18 

19 Maintenance activities associated with facility operation would include the periodic application of 

20 herbicides along roadways, the security fence, and the industrial area to control noxious weed 

21 species (AES, 2010a). Invasive species populations in areas of the proposed property outside 

22 of the industrial footprint would remain unaffected. Although nontarget species in the area could 

23 be impacted by drift during herbicide application, the amount of drift and associated effects 

24 would be very small. 

25 

26 The area of native plant communities would increase as the remaining irrigated crop areas and 

27 temporary construction areas would be replanted using native plant species at the conclusion of 

28 the preconstruction and construction phase. Successful restoration of habitats in arid climates 

29 is difficult, however, and extended periods of time may be required (Monsen et al., 2004). Thus, 

30 the restored plant community may be different from regional sagebrush steppe communities in 

31 species composition and shrub cover (Newman and Redente, 2001; Paschke et al., 2005). 

32 

33 Although operation of the proposed EREF could result in some impacts on plant communities, 

34 habitat quality in the undisturbed areas would continue to improve from the exclusion of cattle, 

35 and the area of native communities would increase from the replanting of disturbed areas. 

36 Therefore, impacts on plant communities from facility operation would be SMALL. 

37 

38 Wildlife

39 

40 Wildlife use of the undeveloped portions of the proposed AES property may increase as a result 

41 of improved habitat quality from the exclusion of livestock, and because the existing boundary 

42 fence around the proposed 1700-hectare (4200-acre) property would be modified to be 

43 conducive to access by wildlife, such as pronghorn antelope (smooth wire would be used for the 

44 bottom wire, which would be at least 40 centimeters [16 inches] above the ground 

45 [AES, 2010a]). However, many wildlife species would likely avoid areas near the proposed 

46 facility due to noise, structures, and human presence, although noise and human presence 

47 would decrease following the construction period. 

48 
 4-55 

1 The proposed EREF would not discharge process water to the onsite basins. However, the 

2 retention basins would receive Cylinder Storage Pad runoff and treated domestic sanitary 

3 effluents, and the detention basins would receive general site stormwater runoff. The retention 

4 and detention basins would be fenced to minimize access by wildlife. However, birds, reptiles, 

5 tiger salamanders (Ambystoma tigrinum), or small mammals could potentially enter the basins 

6 and be exposed to contaminants when the basins contain water. Contaminants in the retention 

7 basins could include water treatment chemicals and, potentially, small amounts of radionuclides. 

8 Small amounts of oil, grease, or other automotive fluids could be present in the detention 

9 basins. Because of the scarcity of surface water in the region, birds and small wildlife species 

10 would likely be attracted to the basins. 

11 

12 Collisions with vehicles along the entrance road would continue to be a hazard for wildlife, and 

13 may increase if wildlife use of the habitat on the proposed site increases. In addition, facility 

14 buildings could present a collision hazard for birds. Lights would be located along roadways 

15 and near building areas. Nocturnal insects attracted to lights could be preyed upon by bats, 

16 such as the Townsends big-eared bat. 

17 

18 Although the Cylinder Storage Pads would be fenced to exclude wildlife, entry to the storage 

19 pads by small species could occur. A small number of individuals could subsequently be 

20 exposed to elevated radiation levels from the cylinders. However, it is unlikely that wildlife 

21 would be present for extended periods. Atmospheric releases of materials such as UF6 could 

22 also result in exposures of wildlife or plants. The U.S. Department of Energy (DOE) has 

23 established radiation dose limits of 1 rad (10 milligray) per day for the protection of terrestrial 

24 plants and 0.1 rad (1 milligray) per day for terrestrial animals (DOE, 2002). Based on 

25 atmospheric releases of radionuclides from the proposed EREF, estimated doses to biota in the 

26 surrounding area would be below the DOE limits. Therefore, impacts on biota from exposure to 

27 elevated radiation levels would also be small. 

28 

29 Greater sage-grouse would also be affected by factors related to operation of the proposed 

30 EREF. Sage-grouse would likely avoid areas near the proposed facility due to noise, visibility of 

31 structures, lighting, and human presence. Avoidance of otherwise suitable habitat would result 

32 in a larger area of effective loss of habitat for the local population and would displace individuals 

33 to other areas of their seasonal range. In addition, the EREF property fence could be a source 

34 of mortality for sage-grouse. Although, as noted above, the fence would be modified for access 

35 by wildlife, fences are known to create a collision hazard for sage-grouse (ISAC, 2006). The 

36 addition of markers to increase wire visibility (AES, 2010g) could help reduce collision-related 

37 mortality. 

38 

39 Operation of the proposed EREF could result in impacts on wildlife and plant communities on 

40 the proposed EREF site and occupying nearby habitats. However, the implementation of 

41 mitigation measures and BMPs would reduce potential impacts. Therefore, impacts on 

42 ecological resources from facility operation would be SMALL. 

43 

44 4.2.7.3 Mitigation Measures 

45 

46 This section presents mitigation measures to minimize impacts on ecological resources. 

47 Included are mitigation measures that AES has committed to (AES, 2010a) and mitigation 

48 measures identified during the NRC staff’s review. 

49 
 4-56 

1 Mitigation Measures Identified by AES 

2 

3 • unused open areas, including areas of native grasses and shrubs, would be left undisturbed 

4 and managed for the benefit of wildlife 

5 

6 • native plant species (i.e., low-water-consuming plants) would be used to revegetate 

7 disturbed areas, to enhance wildlife habitat 

8 

9 • the detention and retention basins would be fenced to limit access by wildlife 

10 

11 • vehicle speeds on the proposed site would be reduced 

12 

13 • dust suppression BMPs would be used to minimize dust, thereby reducing the impact of 

14 fugitive dust on nearby plant communities; when required, and at least twice daily, water 

15 would be applied to control dust in construction areas in addition to other fugitive dust 

16 prevention and control methods 

17 

18 • during construction and operations, all lights would be focused downward 

19 

20 • the boundary fence around the proposed property would be improved to allow pronghorn 

21 access to the remaining sagebrush steppe habitat on the proposed property; the fence 

22 would include a smooth top wire no more than 42 inches above the ground, adequate wire 

23 spacing to prevent wildlife entanglement, a smooth bottom wire approximately 16 to 

24 18 inches above the ground, and durable markers to increase wire visibility (AES, 2010g) 

25 

26 • livestock grazing on the proposed property would be eliminated when the proposed EREF 

27 becomes operational 

28 

29 • measures would be taken to protect migratory birds during construction and 

30 decommissioning, e.g., clearing or removal of habitat, such as sagebrush, including buffer 

31 zones, would be performed outside of the migratory bird breeding and nesting season; 

32 additional areas to be cleared would be surveyed for active nests during the migratory bird 

33 breeding and nesting season; activities would be avoided in areas containing active nests of 

34 migratory birds; the FWS would be consulted to determine appropriate actions regarding the 

35 taking of migratory birds, if needed 

36 

37 • herbicides would not be used during construction, but would be used in limited amounts 

38 along the access roads, plant area, and security fence surrounding the plant to control 

39 noxious weeds during operation of the plant; herbicides would be used according to 

40 government regulations and manufacturer’s instructions to control noxious weeds 

41 

42 • eroded areas would be repaired and stabilized, and sediment would be collected in a 

43 stormwater detention basin 

44 

45 • erosion- and runoff-control methods, both temporary and permanent, would follow BMPs 

46 such as minimizing the construction footprint to the extent possible, limiting site slopes to a 

47 horizontal-to-vertical ratio of four to one or less, using sedimentation detention basins, 
 4-57 

1 protecting adjacent undisturbed areas with silt fencing and straw bales, as appropriate, and 

2 using crushed stone on top of disturbed soil in areas of concentrated runoff 

3 

4 • cropland areas on the proposed property would be planted with native species when the 

5 proposed EREF becomes operational 

6 

7 • consider all recommendations of appropriate State and Federal agencies, including the 

8 Idaho Department of Fish and Game and the FWS 

9 

10 Additional Mitigation Measures Identified by NRC

11 

12 • plant disturbed areas and irrigated crop areas with native sagebrush steppe species to 

13 establish native communities and prevent the establishment of noxious weeds; plant 

14 immediately following the completion of disturbance activities and the abandonment of crop 

15 areas 

16 

17 • develop and implement a noxious weed control program to prevent the establishment and 

18 spread of invasive plant species; hose down tires and undercarriage of off-road vehicles 

19 prior to site access to dislodge seeds or other propagules of noxious weeds; monitor for 

20 noxious weeds throughout the construction and operations phases and immediately 

21 eradicate new infestations; minimize indirect impacts of weed control activities, such as 

22 herbicide effects on nontarget species, and soil disturbance and fire hazards from vehicle 

23 operation in undisturbed areas during weed control activities 

24 

25 • develop areas that will retain water of suitable quality for wildlife and provide wildlife access 

26 to such areas with suitable water quality 

27 

28 • for basins with water quality unsuitable for wildlife, use animal-friendly fencing and netting or 

29 other suitable material over basins to prevent use by migratory birds 

30 

31 • place metal reflectors on the top wire of the fence along the AES property boundary, to 

32 reduce sage-grouse mortality resulting from collisions with the fence 

33 

34 • coordinate with Idaho National Laboratory in monitoring risks to sage-grouse and other 

35 sensitive species and identifying measures to reduce risks and protect these species and 

36 their habitat, particularly sagebrush steppe 

37 

38 • coordinate with Idaho Department of Fish and Game to determine corrective action or 

39 mitigation for the offsite public lands lost to wildlife due to project effects 

40 

41 4.2.8 Noise Impacts 

42 

43 Noise impacts from preconstruction and construction were evaluated based on the number and 

44 type of construction equipment proposed to be on the proposed EREF site during those periods, 

45 together with other relevant parameters associated with those actions. The noise assessment 

46 also included an assessment of incremental noise along US 20 resulting from travel to and from 

47 the proposed site by the construction and operating workforces, as well as resulting from trucks 

48 delivering equipment and materials during construction and trucks delivering feedstock and 
 4-58 

1 removing wastes and enriched uranium products from the proposed site during operation. 

2 Background noise levels at the proposed property boundary were provided by AES and 

3 documented in the ER (AES, 2010a). No independent measurements of background noise 

4 were conducted. Instead, NRC verified the appropriateness of the data collection instruments 

5 and methodology used by AES. 

6 

7 NRC assigned typical noise signatures of construction vehicles and equipment in order to 

8 anticipate noise sources during preconstruction and construction. A standard noise attenuation 

9 rate of 6 dB per doubling of distance from the source was applied to each significant noise 

10 source that was presumed to be operating anywhere along the perimeter of the proposed EREF 

11 site (i.e., the industrial footprint of the proposed EREF) in order to estimate approximate noise 

12 levels at the nearest human receptor (beside the construction workforce). 

13 

14 Noise estimates from operation were based on expected noise signatures of the various pieces 

15 of noise-producing equipment that would be operating in outside locations. 

16 

17 The NRC staff has concluded from its noise assessments that, notwithstanding short-term noise 

18 impulse events such as blasting, adequate mitigation controls would ensure noise impacts 

19 during preconstruction, construction, and operation would all be below recommended standards 

20 at the closest human receptor; thus, noise impacts would be SMALL. 

21 

22 4.2.8.1 Preconstruction and Construction 

23 

24 Noise impacts would result from preconstruction and from construction activities. Specifically, 

25 noise would result from: the operation of various construction vehicles and equipment; the 

26 operation on area roads of vehicles used by the workforce to commute to and from the 

27 proposed site and delivery trucks bringing materials and equipment to the proposed site; the 

28 use of explosives (together with associated warning alarms), pile drivers, and/or backhoes to 

29 remove rock outcrops, install foundations, and bury utilities or facilitate cut and fill and grade 

30 alterations; travel of vehicles on onsite roads, loading, unloading, transferring, and stockpiling 

31 soils and materials; onsite support activities such as a concrete batch plant operation; and the 

32 operation of stationary sources such as the six emergency generators that would become 

33 operational while construction is still ongoing and, once installed, would be operated periodically 

34 throughout the construction period for the purpose of preventative maintenance. A similar 

35 preventative maintenance schedule would extend throughout the operation phase for each of 

36 the generators. 

37 

38 Although a detailed preconstruction and construction plan has not yet been produced, AES has 

39 developed a comprehensive list of the number and types of vehicles that would be involved and 

40 identified the general parameters of their expected use (AES, 2010a). In addition to light-duty 

41 commuting and light-duty and heavy-duty delivery vehicles, AES has indicated that the following 

42 types of vehicles and equipment would be used: cranes, cherry pickers, water trucks, concrete 

43 delivery trucks, concrete pump trucks, stake body trucks, compressors, generators, and pumps 

44 (AES, 2010a). 

45 

46 Noise would be generated at US 20 during construction of the site access roads and at their 

47 interconnection with US 20. Noise related to traffic on US 20 would increase due to traffic 

48 increases in delivery vehicles and commuting vehicles of the construction workforce. 
 4-59 

1 Notwithstanding construction of the US 20 interchange, the majority of the construction activities 

2 would occur within the proposed EREF site (i.e., the industrial footprint of the proposed facility), 

3 which is located in the approximate center of the proposed EREF property, approximately 

4 3060 meters (10,039 feet) north of the US 20 interchange. AES estimates that noise from the 

5 operation of construction vehicles and equipment would range from 80 to 95 dBA at a distance 

6 of 15 meters (50 feet) from each source (AES, 2010a). Given that the majority of vehicles and 

7 equipment would be operating primarily within the industrial footprint (construction of the 

8 highway interchange and site access roads notwithstanding) and with the expectation that 

9 access to the active area would be limited to the authorized, fully informed, and adequately 

10 protected construction workforce, it is reasonable to expect that all potential public receptors 

11 would be at least no closer than 15 meters (50 feet) from high noise sources and, in most 

12 instances, at substantially greater distances from those sources. Members of the public 

13 traveling on US 20 would be close to high noise sources associated with construction of the 

14 interchange, but those individuals would be in vehicles and their exposures would be limited to a 

15 relatively short duration as their vehicle passed by the active construction zone. The noise level 

16 is expected to vary throughout the 10-hour workday with certain activities such as blasting 

17 creating short-term, high-intensity impulse noise that is likely to be higher than 95 dB at the 

18 source. 

19 

20 According to the facility construction plan proposed by AES (AES, 2010a), most of the major 

21 noise-producing activities (site clearing and grading, excavations [including the use of 

22 explosives], utility burials, construction of onsite roads [including the US 20 interchanges], and 

23 construction of the ancillary buildings and structures) would occur during preconstruction. 

24 

25 As discussed in Section 3.9, various noise standards have been promulgated at the Federal 

26 level that could serve as a basis for local ordinances. Although no specific noise ordinances 

27 have been adopted for the local area, the Federal standards of relevance in evaluating the 

28 acceptability of noise impacts from preconstruction and construction of the proposed EREF 

29 include: 

30 

31 • Day-night average noise levels, Ldn, less than 65 dBA are considered clearly acceptable for 

32 residential, livestock, and farming land uses; Ldn between 65 dBA and 75 dBA are normally 

33 unacceptable but could be made acceptable (to human receptors) with the application of 

34 noise attenuation features to occupied structures; Ldn above 75 dBA are always 

35 unacceptable for residential land uses, but Ldn between 70 and 80 dBA are acceptable for 

36 industrial and manufacturing areas (HUD, 2009). 

37 

38 • Day-night average noise levels, Ldn, less than 65 dBA are considered compatible with 

39 residential land uses; levels up to 75 dBA may be compatible with residential uses and 

40 transient lodging if structures have noise isolation features (EPA, 1980). 

41 

42 • Day-night average noise levels, Ldn, below 55 dBA are always acceptable (EPA’s goal for 

43 outdoor spaces). 

44 

45 Noise attenuation with distance is dependent on a number of factors, including land type and 

46 cover, topography, the presence of natural or man-made obstructions, and meteorological 

47 conditions such as wind speed and direction, temperature inversions, and cloud cover. The 

48 widely accepted rate of noise attenuation is a reduction of 6 dBA for every doubling of distance. 
 4-60 

1 However, this rate represents a fully vegetated land surface. In arid or semiarid locations where 

2 vegetative cover is less than complete and surface soils tend to be highly sound-reflective, 

3 lesser amounts of attenuation can be expected. However, despite its characterization as a 

4 semiarid steppe, the proposed EREF site has a relatively complete vegetative cover, 

5 notwithstanding the volcanic rock outcroppings that constitute approximately 28 percent of the 

6 land area (see Section 3.6 for additional details). It is therefore reasonable to expect that noise 

7 attenuation would occur at or near the average of 6 dBA with every doubling of distance from 

the source.10 8 

9 

10 Figure 4-5 shows the site plan for the proposed EREF site, the access roads, US 20 

11 interchange, and the visitor center. The proposed EREF property boundary closest to the 

12 industrial footprint is to the north at a distance of approximately 762 meters (2500 feet). The 

13 industrial footprint is approximately 3060 meters (10,039 feet) north of US 20. Except as noted 

14 below, adjacent land parcels are expected to continue to be used for livestock grazing and 

15 agricultural activities. The nearest residence to the proposed site was identified by AES as 

16 being 7.7 kilometers (4.8 miles) east of the proposed site. No other sensitive human receptors 

17 (schools, churches, hospitals) are closer. The Wasden Complex, an archeological site, is 

18 approximately 1.0 kilometer (0.6 mile) outside the proposed EREF property boundary. The 

19 Wasden Complex contains no brick-and-mortar or masonry structures and, at its distance from 

20 the proposed site, would not experience any potentially destructive sound pressure levels. 

21 (See Section 4.2.7 for a more detailed discussion of ecological impacts from noise related to 

22 preconstruction, construction, and operation.) 

23 

24 Assuming a noise level of 95 dBA at the perimeter of the proposed EREF site (potentially 

25 occurring during preconstruction activities), applying an attenuation rate of 6 dBA per distance 

26 doubling, and considering the distances from the active construction zone to facility boundaries, 

27 noise levels of 61 dBA are estimated to occur at the north boundary of the proposed EREF 

28 property. Assuming the maximum noise levels from site access road construction to also be 

29 95 dBA, an attenuation rate of 6 dBA per doubling of distance, and considering that access 

30 roads approach the west facility boundary of the proposed EREF property as close as 

31 37 meters (120 feet), noise levels at that boundary are estimated to be as high as 89 dBA. 

32 Although this anticipated level exceeds suggested acceptable limits, construction activities for 

33 the road in proximity to the west boundary of the proposed EREF property would be short-term, 

34 and the immediately adjacent offsite land parcel is expected to be used for either livestock 

35 grazing or agriculture and to not have a human presence during the majority of time the 

36 preconstruction activities are occurring. 

37 

38 At their closest point, one access road, the highway interchange, and the visitor center are 

39 immediately adjacent to BLM’s Hell’s Half Acre WSA located to the south. However, individuals 

40 visiting Hell’s Half Acre are expected to be no closer than the start of the hiking trail, another 

41 0.5 kilometer (0.3 mile) farther to the south. At the start of the hiking trail, attenuated 

42 construction noise is estimated to be between 51 and 66 dBA. Although construction noise 

43 would be audible at the hiking trail, the initial preconstruction and construction activities that 

44 represent the highest potential noise emissions would be short-term (for intermittent periods 

 

10 Some slight seasonal variation in noise attenuation is anticipated due to the presence or absence of 

vegetative cover or snow cover. No quantitative estimates were made, however, since it is difficult to 

anticipate the manner in which adjacent land parcels would be used from year to year. 
 4-61 

1 

2 Figure 4-5 Proposed EREF Site Plan (AES, 2010a) 

3 

4 
 4-62 

1 over the 12 month construction period for the highway interchanges) and associated noise 

2 would combine with highway noise already occurring in that area, measured and documented 

3 by AES in the AES ER at 57 dBA (AES, 2010a). 

4 

5 Available data suggest that construction noise during preconstruction would be audible at some 

6 boundaries of the proposed EREF property. Construction noise emanating from activities within 

7 the industrial footprint is expected to be attenuated to acceptable levels at the boundaries of the 

8 proposed EREF property. Noise resulting from highway interchange, site access road, and 

9 visitor center construction may occur at offsite locations at levels above values suggested in 

10 Federal standards as acceptable, albeit for relatively short periods of time throughout 

11 construction of the US 20 interchanges (estimated by AES as 12 months or less). However, 

12 with the exception of individuals using the Hell’s Half Acre hiking trail or traveling on US 20 

13 (at highway speeds), the potentially impacted offsite areas are all used for livestock grazing 

14 and/or agricultural purposes and would typically not have a human presence. No residence is 

15 expected to experience unacceptable levels of noise during any phase of preconstruction and 

16 construction. 

17 

18 The NRC staff concludes that noise impacts from initial preconstruction activities may exceed 

19 established standards at some locations along the proposed EREF property boundary for 

20 relatively short periods of time. However, because of the distances involved, expected levels of 

21 attenuation, the application of mitigation measures, and the expected limited presence of human 

22 receptors at these locations, the impacts would be SMALL for human receptors. During the 

23 4-year overlap period when partial operations begin as heavy construction is completed, noise 

24 impacts from remaining construction activities and from operation are expected to be additive, 

25 but nevertheless substantially reduced from noise levels during preconstruction and 

26 construction would be SMALL. 

27 

28 4.2.8.2 Facility Operation 

29 

30 Current development plans provide for a period of approximately 4 years when the proposed 

31 facility becomes partially operational while some structure construction is still ongoing within the 

32 industrial footprint. However, the majority of the largest noise emissions are expected to occur 

33 during preconstruction. Those activities would all have been completed throughout the 

34 proposed site before any operations begin, with ongoing construction confined to a small area 

35 and not involving major noise-producing equipment or activities. The combined noise impacts 

36 from simultaneous remaining construction and partial operation would be dominated by the 

37 higher noise source but nevertheless is expected to be diminished from impacts during initial 

38 preconstruction and construction. 

39 

40 Major noise sources associated with operation of the proposed EREF include the six diesel41 fueled emergency generators located at outdoor areas within the industrial footprint, commuter 

42 traffic noise for the operational workforce (and a small construction workforce for the 4-year 

43 period of heavy construction and operation overlap), traffic noise from the movement of delivery 

44 vehicles to bring feedstock materials and other support materials to the proposed site and 

45 remove product and waste materials from the proposed site, noise from operation of various 

46 pumps and compressors, and cooling fan noise. Numerous pieces of equipment associated 

47 with operation can be expected to have noise signatures. However, with the exception of 

48 emergency generators, cooling fans, and large compressors, the majority of noise-producing 
 4-63 

1 equipment would be located inside buildings and their noise sources would be significantly 

attenuated by those structures.11 2 Some of the outdoor equipment with significant noise 

3 signatures are expected to be located within noise-suppressing enclosures. 

4 

5 AES referenced noise measurements from the Almelo Enrichment Plant in Almelo, The 

6 Netherlands, a facility also using the same gas centrifuge design as the proposed EREF, as 

7 ranging from 30 to 47 dBA at the facility boundary (AES 2010a). Because the Almelo Facility’s 

8 design does not include a substantial fallow buffer area between industrial activities and the 

9 facility’s boundary, AES has characterized the Almelo-measured operational noise levels as 

10 conservative representations of the proposed EREF operational noise levels (as measured at 

11 the proposed EREF property boundary) and concluded they satisfy all relevant or potentially 

12 relevant U.S. noise standards and guidance. NRC concurs that same noise levels that would 

13 occur at the proposed EREF would comply with relevant U.S. noise standards and guidance. 

14 

15 Traffic associated with operations at the proposed EREF would result in increased noise levels 

16 along US 20 in the vicinity of the proposed EREF, contributing to traffic-related noise that 

17 already exists in proximity to the highway, especially during expected periods of commuting of 

18 INL personnel from Idaho Falls. Residents in the vicinity of US 20, but otherwise unaffected by 

19 operational noise emanating from the proposed EREF site, would be impacted by increased 

20 traffic noise. Traffic noise can be expected to increase slightly and, depending on the 

21 operational schedules established for the proposed EREF, the duration of traffic noise may 

22 increase over the course of a workday. 

23 

24 The NRC staff concludes that distances from noise sources to sensitive receptors would result 

25 in adequate control of noise sources related to operation of the proposed EREF, and noise 

26 impacts from operation of the proposed EREF would be SMALL. 

27 

28 4.2.8.3 Mitigation Measures 

29 

30 The most effective strategy for mitigating noise impacts to the general public involves 

31 maximizing the distance between noise sources and potential public receptors. The size of the 

32 proposed EREF property, the positioning of the proposed EREF site within that property, the 

33 design of the proposed EREF site, and site access controls would guarantee such separations 

34 during preconstruction, construction, and operating periods. In addition to the intrinsic controls 

35 of the proposed EREF property and the placement of the proposed EREF site within that 

36 property, AES identified the following noise mitigation strategies for preconstruction and 

37 construction (AES, 2010a): 

38 

39 • restricting most of US 20 use after twilight through early morning hours to minimize noise 

40 impacts to the nearest residence; restrict usage of heavy truck and earthmoving equipment 

41 after twilight through early morning hours during construction of the access roads and 

 

11 The gas centrifuges operate at extremely high speeds. However, because they are supported 

magnetically and operate under high vacuum, their operation is expected to be extremely quiet. 

Catastrophic failure of a centrifuge may create a high impulsive noise. Their design, together with 

their locations inside buildings, suggest that the centrifuges would not contribute significantly to the 

operational noise signature of the proposed EREF that would be experienced at the proposed EREF 

property boundary. 
 4-64 

1 highway entrances, to minimize noise impacts on the Hell’s Half Acre Wilderness Study 

2 Area 

3 

4 • performing construction or decommissioning activities with the potential for noise or vibration 

5 at residential areas that could have a negative impact on the quality of life, during the 

6 daytime hours (7:00 am–7:00 pm); if it is necessary to perform an activity that could result in 

7 excessive noise or vibration in a residential area after hours, AES would notify the 

8 community in accordance with site procedures 

9 

10 • using engineered and administrative controls for equipment noise abatement, including the 

11 use of equipment and vehicle mufflers, acoustic baffles, shrouding, barriers, and noise 

12 blankets 

13 

14 • sequencing construction or decommissioning activities to minimize the overall noise and 

15 vibration impact (e.g., establish the activities that can occur simultaneously or in succession) 

16 

17 • using blast mats, if necessary, when using explosives 

18 

19 • creating procedures for notifying State and local government agencies, residents, and 

20 businesses of construction or decommissioning activities that may produce high noise or 

21 vibration that could affect them 

22 

23 • posting appropriate State highway signs warning of blasting 

24 

25 • creating a Complaint Response Protocol for dealing with and responding to noise or 

26 vibration complaints, including entering the complaint into the site’s Corrective Action 

27 Program 

28 

29 • establishing and enforcing onsite speed limits 

30 

31 The NRC identified the following additional noise mitigation measure for preconstruction and 

32 construction: 

33 

34 • suspend the use of explosives during periods when meteorological conditions (e.g., low 

35 cloud cover) can be expected to reduce sound attenuation 

36 

37 AES has identified the following mitigative actions to control noise impacts during operation of 

38 the proposed EREF (AES, 2010a): 

39 

40 • mitigating operational noise sources primarily by plant design, whereby cooling systems, 

41 valves, transformers, pumps, generators, and other facility equipment are located mostly 

42 within plant structures and the buildings absorb the majority of the noise located within 

43 

44 • restricting most of US 20 use after twilight through early morning hours to minimize noise 

45 impacts to the nearest residence 

46 

47 • establishing preventative maintenance programs that ensure all equipment is working at 

48 peak performance (AES, 2009b) 

49 
 4-65 

1 4.2.9 Transportation Impacts 

2 

3 This section discusses the potential impacts from transportation to and from the proposed EREF 

4 site. Transportation impacts resulting from the movement of personnel and material during 

5 preconstruction, construction, and operation of the proposed EREF include: 

6 

7 • transportation of construction materials and construction debris 

8 

9 • transportation of the construction workforce 

10 

11 • transportation of the operational workforce 

12 

13 • transportation of feed material (including natural UF6 [i.e., not enriched], empty tails 

14 cylinders, and supplies for the enrichment process) 

15 

16 • transportation of the enriched UF6 product (and empty product cylinders) 

17 

18 • transportation of process wastes, including depleted UF6 and other radioactive wastes 

19 

20 The primary impact of preconstruction and the proposed action on transportation resources is 

21 expected to be increased traffic on nearby roads and highways. Transportation impacts during 

22 preconstruction and construction, and during facility operation would be SMALL to MODERATE 

23 on adjacent local roads (due to the potentially significant increase in average daily traffic), but 

24 regional impacts would be SMALL. 

25 

26 No fatalities are expected as a result of construction worker traffic to and from the proposed 

27 EREF site during each of the peak years of construction. Measures proposed by AES to 

28 mitigate potential traffic impacts at the entrance to the proposed EREF include encouraging 

29 carpooling, varying shift change times, and incorporating traffic safety measures to improve 

30 traffic flow on US 20 (AES, 2010a). 

31 

32 No construction or operational worker fatalities are expected from traffic accidents. Less than 

33 two latent fatalities are expected from truck emissions on an annual basis. Less than two latent 

34 cancer fatalities (LCFs) to either the general public or occupational workers are expected from 

35 incident-free transport of radioactive materials. No fatalities to the general public resulting from 

36 truck accidents are anticipated. The potential health impacts from the transportation of 

37 radioactive materials and from chemical exposures resulting from a transportation accident 

38 would be SMALL. 

39 

40 4.2.9.1 Preconstruction and Construction 

41 

42 Preconstruction and construction activities for the proposed EREF would cause an impact on 

43 the local transportation network due to the construction of the highway entrance(s), the daily 

44 commute of up to 590 construction workers during the peak years of construction, and daily 

45 construction deliveries and waste shipments (AES, 2010a). The commute of the peak number 

46 of construction workers, combined with the anticipated number of construction deliveries and 

47 waste shipments, could increase the daily traffic on US 20 from 2210 vehicle trips per day 

48 (see Table 3-23 in Chapter 3) to 3420 vehicle trips per day (2210 plus 590 commuting round 
 4-66 

1 trips and 15 delivery/waste round trips). This represents a 55 percent increase in traffic volume 

2 over current levels. Based on employment and delivery/shipment projections for the proposed 

3 facility, this estimate also represents the maximum number of vehicle-trips during the period 

4 when construction and operations overlap (AES, 2009b) (see Section 4.2.9.2). 

5 

6 Because traffic volume is expected to remain below capacity on Interstate 15 (I-15) and traffic 

7 slowdowns or delays would only be expected to occur at the entrance to the proposed EREF 

8 during shift changes, the impacts on overall traffic patterns and volumes would be MODERATE 

9 on US 20 and SMALL on I-15. 

10 

11 In addition to the increased traffic that might result from the construction of the site entrance(s) 

12 along US 20, there would be an increased potential for traffic accidents. Assuming an 

13 80-kilometer (50-mile) round-trip commute (i.e., the round-trip distance between the Idaho Falls 

14 area and the proposed EREF) for 250 workdays per year, 590 vehicles would travel an 

15 estimated total of 11,800,000 vehicle kilometers (7,375,000 vehicle miles) per year. This 

16 average round-trip distance was assumed because Idaho Falls is the closest principal business 

17 center to the proposed EREF. Based on the statewide vehicle accident and fatality rates of 

18 85.8 injuries and 1.59 fatalities per 100 million annual vehicle miles (ITD, 2009), seven injuries 

19 and no fatalities (risk of <0.12 fatalities estimated) would be expected to occur during a peak 

20 preconstruction/construction employment year. Therefore, the impacts from construction 

21 vehicle accidents would be SMALL. 

22 

23 An average of 3940 delivery and waste trucks would arrive and depart the proposed site in each 

24 of the three peak years of construction (about 16 trucks per day) (AES, 2010a). Assuming an 

25 average round-trip distance of 80 kilometers (50 miles), construction-related trucks would travel 

26 an estimated 315,200 vehicle kilometers (197,000 vehicle miles) per year. Based on State-level 

27 surface freight accident rates of 63.4 injuries and 40.1 fatalities per 100 million annual truck 

28 miles (Saricks and Tompkins, 1999), no injuries (risk of <0.13 injuries) and no fatalities (risk of 

29 <0.08 fatalities) from construction delivery and waste shipments would be expected to occur 

30 during peak preconstruction/construction. The impacts from the truck traffic to and from the 

31 proposed site during preconstruction and construction would have a SMALL impact on overall 

32 traffic. 

33 

34 In addition to the potential for injuries and fatalities from construction shipments, there are 

35 potential impacts from truck emissions. Based on a conservative (Class VIIIB) emission rate 

36 (Biwer and Butler, 1999), no latent fatalities would be expected from truck emissions during a 

37 peak year of construction (risk of <0.17 latent fatalities). Therefore, pollution impacts from 

38 construction vehicle traffic would be SMALL. 

39 

40 Two access roadways into the proposed EREF site are planned to support access during 

preconstruction, construction, and facility operation (AES, 2010a).12 41 The main (eastern) access 

42 road would run north from US 20 to the southern entrance of the proposed EREF site. The 

43 construction/alternate (western) access road would run north from US 20 to the western 

44 entrance of the proposed EREF site. One or both roadways would eventually be converted to 

 

12 Plans for permanent access to US 20, including the number of full-time operational connections, have 

not been finalized. As of August 2010, AES continues to consult with ITD. The impacts described in 

this EIS are not expected to be sensitive to the number or placement of access roads. 
 4-67 

1 permanent access roads upon completion of construction. The Idaho Transportation 

2 Department (ITD) would require AES to secure and maintain a permit for access to the 

3 proposed EREF site (NRC, 2009b). 

4 

5 AES has initiated discussions with ITD regarding the construction of the site access roads from 

6 US 20 and related safety requirements. For the main (eastern) access road, AES has 

7 expressed little interest in at-grade turn lanes (which would not solve difficulties associated with 

8 left turns to and from the main site access road) or a loop road similar to that used by INL 

9 (which would not solve difficulties associated with the high-speed merge into peak traffic that 

10 includes few gaps) (ITD, 2010). Instead, AES has indicated a preference for a grade-separated 

11 interchange (ITD, 2010). The proposed EREF site is favorable for construction of an overpass 

12 due to existing physical features, peak directional flow to/from INL, and low traffic volumes at all 

13 other times (ITD, 2010). Ramp construction would likely require 3 to 4 months and would 

14 present a minor impact on current traffic flow (due to the mandatory construction zone speed 

15 reduction to 72 kilometers per hour [45 miles per hour]); overpass construction would result in 

16 some traffic flow disruption, but it is not expected to be significant (ITD, 2010). US 20 appears 

17 to have the available capacity to absorb additional traffic created by construction and operations 

18 related to the proposed EREF without adverse effects, with the possible exception of peak, 

19 directional travel periods (i.e., rush hour) in the morning and afternoon. Impacts on US 20 peak 

20 flow could be minimized by ceasing construction activities during peak directional flow 

21 (see Section 3.12.1) (ITD, 2010). Impacts on US 20 traffic flow due to construction of site 

22 access roads would be SMALL and temporary, occurring only during the period of access road 

23 construction. 

24 

25 As noted above, there is currently no road or parking infrastructure at the proposed EREF site. 

26 Therefore, site-specific traffic levels (e.g., during construction and shift changes) are based on 

27 maximum projections of construction traffic, regular operational workforce, incoming deliveries, 

28 and outgoing shipments. Peak traffic flows are anticipated at shift changes, with the principal 

29 problem area occurring where the site access roads meet US 20. The proposed EREF site is 

30 assumed to have enough parking capacity to accommodate each working shift and any 

31 necessary visitors (AES, 2010a). 

32 

33 Overall, the anticipated transportation impacts from preconstruction and construction, as well as 

34 the period when construction activities and operation overlap, would be SMALL to MODERATE. 

35 Assuming AES estimates for the first year of construction are representative of preconstruction 

36 (AES, 2010a), and assuming eight months of preconstruction, the estimated relative 

37 contributions to these impacts are 10 percent during preconstruction and 90 percent during 

38 construction. 

39 

40 4.2.9.2 Facility Operation 

41 

42 Operations impacts could occur from the transport of personnel, nonradiological materials, and 

43 radioactive material to and from the proposed EREF site, with the highest impacts occurring 

44 during the period when facility construction and operation overlap. The impacts from each are 

45 discussed below. 

46 

47 
 4-68 

1 Transportation of Personnel

2 

3 Operations at the proposed EREF would be continuous, requiring an operational workforce of 

4 550 workers, approximately 4.2 employees to staff each position, three shifts per day (seven 

5 days per week), and an average of 130 positions per shift (AES, 2010a). Based on a 

6 conservative commuting density of one employee per vehicle, the average increase in daily 

7 local traffic (on US 20) due to employee commuting is estimated to be 35 percent (2210 plus 

8 780 employee vehicle trips). Assuming a round-trip distance of 80 kilometers (50 miles) and 

9 statewide vehicle accident rates, employees would travel approximately 11,388,000 vehicle 

10 kilometers (7,117,500 vehicle miles) per year of facility operation. Based on statewide vehicle 

11 accident and fatality rates (ITD, 2009), seven injuries and no fatalities (risk of <0.12 fatalities) 

12 would be anticipated from traffic accidents during a peak year of operation. 

13 

14 As noted in Section 4.2.9.1, the maximum number of daily vehicle-trips during the period when 

15 construction and operations overlap is projected to be 590 commuting round trips (1180 vehicle16 trips) and 15 delivery/waste round trips (30 vehicle-trips). This projection bounds the 780 daily 

17 vehicle-trips that are anticipated during peak operation, and the associated level of increased 

18 traffic would have a SMALL to MODERATE impact on the current traffic on US 20 (SMALL for 

19 an off-peak shift change). 

20 

21 Transportation of Nonradiological Materials

22 

23 The transportation of nonradiological materials would include the delivery of routine supplies 

24 and equipment necessary to sustain operation and the removal of nonradiological wastes 

25 (including hazardous wastes). The transportation of hazardous waste is subject to EPA and 

26 U.S. Department of Transportation (DOT) regulations. Nonradiological deliveries and waste 

27 removal would require an estimated 3889 truck round-trips per year (including eight shipments 

28 of hazardous waste per year) (AES, 2010a), or approximately 16 round-trips per day. This 

29 traffic would have a SMALL impact on the current traffic on US 20. Assuming a round-trip 

30 distance of 80 kilometers (50 miles), these trucks would travel approximately 311,120 kilometers 

31 (194,450 miles) per year of operation, no injuries (risk <0.13), and no fatalities (risk <0.8) would 

32 be expected per year of peak operation. Therefore, the impacts from accidents involving the 

33 shipment of nonradiological materials would be SMALL. The 80-kilometer (50-mile) distance is 

34 reflective of the round-trip distance between the proposed EREF site and the Idaho Falls area. 

35 Peterson Hill Landfill, the proposed destination for most of the nonhazardous and 

36 nonradioactive waste generated by the proposed EREF, is located near Idaho Falls. Hazardous 

37 wastes would be shipped to a local or regional Resource Conservation and Recovery Act 

38 (RCRA)-permitted treatment, storage, and disposal facility (TSDF), such as the U.S. Ecology 

39 facility near Grandview, Idaho (approximately 121 kilometers [75 miles] from the proposed 

40 EREF site). 

41 

42 Transportation of Radiological Materials

43 

44 Transportation of radiological materials would include shipments of feed material (natural UF6), 

45 product material (enriched UF6), depleted tails (depleted UF6) and other radioactive wastes, and 

46 empty feed, tails, and product cylinders. Due to the lack of rail access in the region, AES did 

47 not propose rail transportation as a future means of shipping radioactive material and wastes 
 4-69 

1 (AES, 2010a). AES has proposed trucking as the sole mode of freight transportation to and 

2 from the proposed EREF. 

3 

4 Transportation of radiological materials is subject to NRC and DOT regulations. All materials 

5 shipped to or from the proposed EREF could be shipped in Type A containers. The product 

6 (enriched UF6) is considered by the NRC to be fissile material and would require additional 

7 fissile packaging considerations such as using an overpack surrounding shipping containers. 

8 However, when impacts are evaluated, the effects of the overpack are not incorporated into the 

9 assessment and result in a set of conservative assumptions. 

10 

11 The potential impacts from radiological shipments, other than the traffic increase on local roads, 

12 were analyzed using the WebTRAGIS and RADTRAN computer codes. WebTRAGIS (Johnson 

13 and Michelhaugh, 2003) is a Web-based version of the Transportation Routing Analysis 

14 Geographic Information System (TRAGIS), which is used to model highway, rail, and waterway 

15 routes within the United States. RADTRAN 5 (Weiner et al., 2008) is used to calculate the 

16 potential impacts of radiological shipments using the routing information generated by 

17 WebTRAGIS. Appendix D presents details of the methodology, calculations, and results of 

18 these analyses. 

19 

20 RADTRAN 5.6 estimates several different types of transportation impacts. “Incident-free” 

21 impacts are those not involving any release of radioactive material, including health impacts 

22 from traffic accidents (fatalities) and due to radiation exposure from a passing radiological 

23 shipment (latent cancer fatalities [LCFs]). These impacts are estimated based on one year of 

24 shipments and are presented for both the general public near the transportation routes and the 

maximally exposed individual (MEI).13 25 Risks are calculated based on a population density 

26 located within 800 meters (0.5 mile) of the transportation route. In addition to incident-free 

27 impacts, RADTRAN presents impacts and resultant risks (impact multiplied by probability of 

28 occurrence) from a range of accidents severe enough to release radioactive material to the 

29 environment. It was conservatively assumed that once a container is breached, the material 

30 that is released is completely aerosolized and respirable (see Section D.3.4.2). 

31 

32 Health effects from vehicle exhaust emissions (latent fatalities) are also considered to be an 

33 incident-free impact. These impacts are estimated using the methodology discussed in 

34 Appendix D. 

35 

36 Radiological Shipments by Truck

37 

38 Impacts discussed in this section include the traffic impacts from EREF-related truck traffic as 

39 well as the radiation exposure from the radiological shipments involving UF6, enriched product, 

40 depleted UF6, and other low-level radioactive wastes, and empty shipping containers. 

41 

42 The NRC staff evaluated the number of shipments of each type of material based on the 

43 amount and type of material being transported to and from the proposed EREF: 

44 

 

13 A maximally exposed individual (MEI) is a member of the general public that would be expected to 

receive the highest potential radiological dose for a given scenario. 
 4-70 

1 • Feed material (natural UF6) would be shipped to the proposed EREF site in Type 48Y 

2 cylinders (up to 1424 per year) primarily from UF6 conversion facilities near Metropolis, 

3 Illinois, or Port Hope, Ontario, Canada (AES, 2010a). Feed material could also be received 

4 from international sources, via major international shipping ports on the East Coast 

5 (Portsmouth, Virginia, or Baltimore, Maryland). There would be one 48Y cylinder per truck, 

6 resulting in approximately six shipments per day (assuming 250 shipping days per year). 

7 

8 • Enriched UF6 product would be shipped in Type 30B cylinders (up to 1032 per year) to any 

9 of three domestic fuel manufacturing plants (located in Richland, Washington; Wilmington, 

10 North Carolina; or Columbia, South Carolina) or to international destinations via the two 

11 international shipping ports (Portsmouth, Virginia, or Baltimore, Maryland). Up to five 

12 Type 30B cylinders could be shipped on one truck; however, AES proposes to ship only two 

13 cylinders per truck (AES, 2010a). Therefore, 516 truck shipments per year (approximately 

14 two per day) would leave the proposed site. 

15 

16 • The impacts of transporting depleted UF6 to a conversion facility in preparation for eventual 

17 disposal were also analyzed. Conversion could be performed at a DOE facility or a private 

18 facility (see Section 2.1.5), although AES has not indicated any plans to use a private 

19 facility. DOE conversion facilities are currently being constructed at Paducah, Kentucky, 

20 and Portsmouth, Ohio, and the NRC is currently reviewing a license application for a private 

21 conversion facility (International Isotopes, Inc.) (NRC, 2010d). Depleted UF6 would be 

22 placed in Type 48Y cylinders for temporary storage at the proposed EREF site and eventual 

23 shipment offsite. Approximately 1222 truck shipments per peak year (one cylinder per truck) 

24 would be required to transport the depleted UF6 to a conversion facility where the waste 

25 would be converted into U3O8. If DOE performs the conversion at the Paducah or 

26 Portsmouth facilities, the resulting U3O8 could be shipped offsite for disposal. 

27 

28 • In addition to full feed, product, and depleted UF6 shipments, 1424 empty feed, 1032 empty 

29 product, and 1222 empty depleted UF6 cylinders on an average annual basis would be 

30 shipped to or from the proposed EREF. Assuming two cylinders per truck for all shipments 

31 (AES, 2010a), 1839 truck shipments would be required per year (about 7 to 8 per day, 

32 assuming 250 shipping days per year). 

33 

34 • Other radiological waste of approximately 146,500 kilograms (323,000 pounds) per year 

35 would be shipped offsite to EnergySolutions (in Oak Ridge, Tennessee) for processing or to 

36 EnergySolutions (near Clive, Utah) or U.S. Ecology (in Hanford, Washington) for disposal 

37 (AES, 2010a). These shipments would total approximately 16 truck shipments per year. 

38 The distance to the Oak Ridge disposal site, which is the furthest of the two disposal sites 

39 from the proposed EREF, adequately encompasses the range of radiological waste disposal 

40 sites that could be available in the future. 

41 

42 Based on the discussion above, the total number of trucks containing radiological shipments 

43 (i.e., both incoming and outgoing material) would be about 20 per day (5017 total shipments 

44 over 250 shipping days per year), which would have a minimal impact on US 20 traffic in the 

45 vicinity of the proposed EREF site. 

46 
 4-71 

1 

2 

3 Table 4-12 presents a summary of the potential health impacts to the public and transportation 

4 crews for one year of shipments via truck, calculated using RADTRAN 5. The results are 

5 presented in terms of a range of values for each type of shipment. The range represents the 

6 lowest to highest impacts for the various proposed shipping routes. For example, for feed 

7 material, the range of impact values represents one year of shipments from any of the four 

8 locations where feed material shipments could originate. If feed materials were provided from 

9 one or more of the locations, the impacts would be somewhere between the low and high 

10 values (impacts could be evaluated by summing the products of the fraction of material from 

11 each location and the calculated impacts from those locations). Also included in the table are 

12 the range of impacts summed over shipments of the feed, product, depleted uranium, and 

13 waste. 

14 

Latent Cancer Fatality from Exposure to Ionizing Radiation 

A latent cancer fatality (LCF) is a death from cancer resulting from, and occurring an appreciable time 

after, exposure to ionizing radiation. Death from cancer induced by exposure to radiation may occur 

at any time after the exposure takes place. However, latent cancers would be expected to occur in a 

population from 1 year to many years after the exposure takes place. To place the significance of 

these additional LCF risks from exposure to radiation into context, the average individual has 

approximately 1 chance in 4 of dying from cancer (LCF risk of 0.25). 

The EPA has suggested a conversion factor such that for every 100 person-sieverts (10,000 personrem) of collective dose, approximately 6 individuals would ultimately develop a radiologically induced 

cancer (Eckerman et al., 1999). If this conversion factor is multiplied by the individual dose, the result 

is the individual increased lifetime probability of developing an LCF. For example, if an individual 

receives a dose of 0.00033 sieverts (0.033 rem), that individual’s LCF risk over a lifetime is estimated 

to be 2  10-5. This risk corresponds to a 1 in 50,000 chance of developing a LCF during that 

individual’s lifetime. If the conversion factor is multiplied by the collective (population) dose, the result 

is the number of excess latent cancer fatalities. 

Because these results are statistical estimates, values for expected latent cancer fatalities can be, 

and often are, less than 1.0 for cases involving low doses or small population groups. If a population 

group collectively receives a dose of 50 sieverts (5000 rem), which would be expressed as a 

collective dose of 50 person-sieverts (5000 person-rem), the number of potential latent cancer 

fatalities experienced from within the exposure group is 3. If the number of latent cancer fatalities 

estimated is less than 0.5, on average, no latent cancer fatalities would be expected. 

Source: NRC, 2004, 2005.
 4-72 

Table 4-12 Summary of Annual Impacts on Humans from Truck Transportation of 

Radioactive Materiala 

 Incident-Free LCF Accident 

Material Range 

Latent 

Emissions 

Fatalities 

Public 

Radiation 

LCF 

Crew 

Radiation 

LCF 

Physical 

Fatalities LCFb

Feed High 6.1  10-1 1.9  10-1 1.1  10-2 8.2  10-2 6.6  10-3

Low 3.5  10-1 9.6  10-2 7.2  10-3 5.7  10-2 4.8  10-3

Product High 2.4  10-1 8.4  10-2 3.1  10-3 3.0  10-2 5.9  10-3

Low 3.9  10-2 1.3  10-2 6.6  10-4 7.3  10-3 8.4  10-4

Depleted UF6/tails High 3.5  10-1 1.1  10-1 7.8  10-3 5.9  10-2 4.4  10-3

Low 3.1  10-1 9.6  10-2 6.0  10-3 5.0  10-2 3.2  10-3

Empty feed High 3.0  10-1 2.7  10-1 1.6  10-2 4.1  10-2 2.5  10-8

Low 1.8  10-1 1.6  10-1 1.1  10-2 2.9  10-2 1.6  10-8

Empty product High 2.4  10-1 3.2  10-1 1.5  10-2 3.0  10-2 1.2  10-8

Low 3.9  10-2 6.6  10-2 3.3  10-3 7.3  10-3 1.7  10-9

Empty depleted 

UF6/tails 

High 2.6  10-1

 2.3  10-1 1.4  10-2 3.5  10-2 2.5  10-8

Low 1.5  10-1 1.3  10-1 9.0  10-3 2.5  10-2 1.0  10-8

Waste High 5.0  10-3 1.4  10-3 1.9  10-4 7.6  10-4 1.3  10-6

Low 1.2  10-3 2.6  10-4 3.0  10-5 1.1  10-4 2.5  10-7

Total High 2.0 1.2 6.7  10-2 2.8  10-1 1.7  10-2

Low 1.1 5.6  10-1 3.7  10-2 1.8  10-1 8.8  10-3

a

 Risks calculated based on a population density within 800 meters (0.5 mile) of the transportation route. b

 LCF from accidental release is a population risk (probability  consequence). 

1 

2 Table 4-13 presents the radiological risk from each type of shipment to a member of the general 

3 public who is an MEI (calculated using RADTRAN 5). The MEI is defined as being located 

4 30 meters (98 feet) from a shipment passing at a speed of 24 kilometers per hour (15 miles per 

5 hour) (NRC, 1977). MEI dose and risk are dependent only on the cargo dose rate, not on the 

6 route or distance traveled. 

7 

8 For members of the general public, the largest impacts from the shipment of radioactive 

9 materials are from incident-free transportation (one to two latent fatalities from the vehicle 

10 emissions per year and less than one fatality from traffic accidents per year). The high-range 

11 risk of LCFs would be approximately one per year from incident-free radiation exposure and no 

12 LCFs would be expected from postulated accidents. These impacts on the public would be 

13 SMALL, because the collective radiation exposure would be distributed among all people along 

14 the transportation routes and each exposed individual would receive a minimal dose. The 

greatest radiological risk to an MEI would be from empty product cylinders (risk of 2.1  10-7 15 , or 

16 1 chance in 4.8 million) and the associated dose would be less than 0.00001 percent of the 
 4-73 

Table 4-13 Risk to the MEI from a Single 

Radioactive Material Shipmenta

Material Dose (rem) LCFb

Feed 1.9  10-4 1.1  10-7

Product 6.9  10-5 4.1  10-8

Depleted UF6/tails 1.6  10-4 9.6  10-8

Empty feed 2.9  10-4 1.7  10-7

Empty product 3.5  10-4 2.1  10-7

Empty depleted UF6/tails 2.5  10-4 1.5  10-7

Waste 2.1  10-6 1.3  10-9

a

 MEI is located 30 m from a passing shipment that is traveling 

24 km/h (15 mph). 

b

 LCFs based on risk of 6  10-4 fatal cancer per person-rem 

(EPA, 1999). 

1 

2 100-millirem annual regulatory limit for members of the general public. No LCFs would be 

3 expected from incident-free radiation exposure to transportation crews, so these impacts would 

4 also be SMALL. 

5 

6 Import and Export Impacts

7 

8 As noted in the previous section, AES has indicated that the proposed EREF could import feed 

9 materials from overseas suppliers or export enriched product to overseas purchasers (AES, 

10 2010a). In this case, the proposed EREF would need to comply with licensing and other 

11 requirements for import and export activities in 10 CFR Part 110. Any import or export activity 

12 would also need to be conducted in accordance with transportation security requirements in 

13 10 CFR Part 73. Transportation security for the proposed EREF should be addressed in a 

14 physical security plan. The discussion below summarizes expected transportation impacts 

15 associated with potential import/export activities along routes to the two seaports identified by 

16 AES (Portsmouth, Virginia, and Baltimore, Maryland). 

17 

18 For this EIS, the NRC staff performed analyses for the transportation of enriched uranium from 

19 the proposed EREF to fuel fabrication facilities in Wilmington, North Carolina (Global Nuclear 

20 Fuels-America); Columbia, South Carolina (Westinghouse Electric); and Richland, Washington 

21 (AREVA NP). These analyses are representative of enriched uranium shipments from the 

22 proposed EREF to the seaports identified above, because the truck and rail routes that would 

23 be used in transporting enriched uranium to these seaports have similar distances and 

24 population densities to the routes analyzed for shipments to the domestic fuel fabrication facility 

25 destinations. 

26 

27 The NRC staff also performed analyses for the transportation of feed material to the proposed 

28 EREF from Port Hope, Ontario, Canada. This analysis is considered representative of potential 

29 feed material shipments from the seaports to the proposed EREF, because the distances, 
 4-74 

1 population densities, and expected external radiation doses for such shipments would not be 

2 significantly different from those already analyzed. 

3 

4 Therefore, for shipments of both enriched uranium and feed material to or from seaports, 

5 transportation impacts (incident-free and accidents) would be SMALL and would not be 

6 significantly different from transportation impacts referenced above. 

7 

8 Chemical Impacts during Transportation of Radioactive Materials

9 

10 In addition to the potential radiological impacts from the shipment of UF6, chemical impacts from 

11 an accident involving UF6 could affect the surrounding environment and public. No chemical 

12 impacts are expected during normal transportation conditions as no releases from packaging 

13 would occur. However, when released from a shipping container, UF6 would react with moisture 

14 in the atmosphere to form hydrofluoric acid and uranyl fluoride (UO2F2), which are chemically 

15 toxic to humans. Hydrofluoric acid is extremely corrosive and can damage the lungs and result 

16 in death if inhaled at high enough concentrations. Uranium compounds, in addition to being 

17 radioactive, can have toxic chemical effects (primarily on the kidneys) if they enter by way of 

18 ingestion and/or inhalation (DOE, 2004a,b). 

19 

20 The potential chemical impacts resulting from transportation accidents involving depleted UF6

21 have been analyzed in EISs previously published by DOE (DOE, 2004a,b). The results of these 

22 analyses were used to estimate the chemical impacts associated with the proposed EREF and 

23 are discussed in Appendix D. The results are applicable because the chemical impact analysis 

24 performed by DOE is independent of shipping route and level of enrichment. Chemical impacts 

25 would be only dependent on the quantity of UF6 being transported. In addition, the proposed 

26 EREF would use the same containers (Type 48Y cylinders) that DOE evaluated. The DOE 

27 analyses showed the estimates of irreversible adverse effects from chemical exposure to be 

28 approximately 1 to 3 orders of magnitude lower than the estimates of public latent cancer 

29 fatalities from radiological accident exposure. Since the estimated public health effects from 

30 radiological accident exposure would be SMALL, the chemical impacts would also be SMALL. 

31 

32 4.2.9.3 Mitigation Measures 

33 

34 Measures identified by AES to mitigate transportation impacts during preconstruction activities, 

35 construction, and facility operation include (AES, 2010a): 

36 

37 • encourage carpooling and minimize traffic due to employee travel 

38 

39 • stagger shift changes to reduce the peak traffic volume on US 20 

40 

41 • promptly remove earthen materials on paved roads or the proposed EREF site carried onto 

42 the roadway by wind, trucks, or earthmoving equipment 

43 

44 • promptly stabilize or cover bare earthen areas once roadway and highway entrance 

45 earthmoving activities are completed 

46 

47 • cover open-bodied trucks that transport materials likely to give rise to airborne dust 

48 
 4-75 

1 • construct acceleration and deceleration lanes at the entrances to the proposed EREF site to 

2 improve traffic flow and safety on US 20 

3 

4 • construct acceleration and deceleration lanes (or a grade-separated interchange) on US 20 

5 at the entrances to the proposed EREF site to improve traffic flow and safety 

6 

7 • build gravel pads at the proposed EREF entry/exit points along US 20 in accordance with 

8 the Idaho Department of Environmental Quality (IDEQ) Catalog of Stormwater Best 

9 Management Practices for Idaho Cities and Counties, Volume 2, Erosion and Sediment 

10 Controls (IDEQ, 2009) 

11 

12 • apply periodic top dressing of clean stone to the gravel pads, as needed, to maintain the 

13 effectiveness of the stone voids 

14 

15 • perform tire washing, as needed, on a stabilized stone (gravel) area that drains to a 

16 sediment trap 

17 

18 • prior to entering US 20, inspect vehicles for cleanliness from dirt and other matter that could 

19 be released onto the highway 

20 

21 • maintain low speed limits onsite to reduce noise and minimize impacts on wildlife 

22 

23 The NRC identified the following additional mitigation measures to reduce transportation 

24 impacts during facility operation: 

25 

26 • consider working with INL to operate a joint bus system 

27 

28 • establish shift changes outside of INL peak commuting periods 

29 

30 The ITD would review any access permit application, as noted in Table 1-3. If a permit is 

31 issued, ITD may assign mitigation measures specific to the proposed EREF (e.g., turning 

32 lanes). 

33 

34 4.2.10 Public and Occupational Health Impacts 

35 

36 This section analyzes the potential impacts on public and occupational health from proposed 

37 EREF preconstruction/construction and operation. The analysis is divided into two main 

38 sections: nonradiological impacts and radiological impacts. 

39 

40 The analysis of nonradiological impacts during the preconstruction and facility construction 

41 phase includes estimated numbers of injuries and illnesses incurred by workers and an 

42 evaluation of impacts due to exposure to chemicals and other nonradiological substances, such 

43 as particulate matter (dust) and vehicle exhaust. All such potential nonradiological impacts 

44 would be SMALL. Analysis of nonradiological impacts during facility operation likewise 

45 evaluates the numbers of expected illnesses and injuries and impacts from exposure to toxic 

46 chemicals used or present during operations, mainly uranium and HF. These impacts would be 

47 SMALL. 

48 
 4-76 

1 No radiological impacts are expected during preconstruction and initial facility construction, prior 

2 to radiological materials being brought onsite. The radiological impacts analysis for facility 

3 operations addresses both public and occupational exposures to radiation. Exposures to 

4 construction workers completing facility construction during initial phases of operation are also 

5 evaluated. Evaluated exposure pathways include inhalation of airborne contaminants, ingestion 

6 of contaminated food crops, and direct exposure from material deposited on the ground and 

7 external exposure associated with stored UF6 cylinders. Impacts from exposure of members of 

8 the public would be SMALL. Worker exposures would vary by job type, but would be carefully 

9 monitored and maintained as low as reasonably achievable (ALARA) and impacts would be 

10 SMALL. 

11 

12 4.2.10.1 Preconstruction and Construction 

13 

14 This section evaluates the potential for occupational injuries and illnesses associated with the 

15 proposed preconstruction and construction activities. It also evaluates the potential public and 

16 occupational health impacts from nonradiological and radiological releases during 

17 preconstruction and construction. 

18 

19 Occupational Injuries and Illnesses

20 

21 The proposed EREF project involves a major construction activity with the potential for industrial 

22 accidents related to construction-vehicle accidents, material-handling accidents, and trips and 

23 falls. Resultant injuries could range from minor temporary injuries to long-term injuries and/or 

24 disabilities, and even to fatalities. The proposed activities are not anticipated to be any more 

25 hazardous than those for other major industrial construction or demolition projects. 

26 

27 Numbers of injuries and illnesses potentially incurred by workers during preconstruction and 

28 construction were estimated using annual injury and illness data for heavy construction 

29 compiled by the U.S. Department of Labor (DOL) Bureau of Labor Statistics (BLS). For 

30 preconstruction and construction of the proposed EREF, North American Industry Classification 

31 System Code 237, “Other Heavy and Civil Engineering Construction,” is applicable. Incident 

32 rates for total recordable cases and lost workday cases for calendar year 2007 for this activity 

33 code were obtained from the BLS data for 2007 (BLS, 2008a). Fatality incident rates for 2007 

34 were taken from BLS data for construction occupations (BLS, 2008b) to estimate potential 

35 fatalities during preconstruction and construction of the proposed EREF. The number of 

36 construction workers per year (full-time equivalents [FTEs]) and the duration of construction 

37 were obtained from AES’s ER (AES, 2010a). The incident rates for total recordable cases, lost 

38 workday cases, and fatalities were applied to the number of construction workers per year and 

39 the construction schedule to estimate the total number of respective incidents. The estimated 

40 total incidents are summarized in Table 4-14. 

41 

42 A total of 202 nonfatal illnesses and injuries and less than one fatality are estimated during the 

43 projected 7 years of heavy preconstruction and construction activities based on peak 

44 construction levels. The numbers of such incidents would be substantially smaller during the 

45 four following years of assemblage and testing of the proposed project, as a much smaller 

46 number of worker-years would be involved, while the nature of work would shift from primarily 

47 structural crafts to primarily electrical and mechanical crafts with typically lower injury rates. 
 4-77 

Table 4-14 Estimated Occupational Health Related Incidences during Preconstruction 

and Construction

FTE Injury and Illness Cases Lost Workday Cases Fatalities

FTEs per 

Year Total FTEa

 

Incidents 

per 

100 FTEsb

Total 

Recordable 

Cases 

Incidents per 

100 FTEsb

Lost 

Workday 

Cases 

Incidents per 

100,000 FTEsc

Total 

Fatalities 

590 4130 4.9 202 2.6 107 12.3 0.51 a

 FTEs = full time equivalents; total FTEs based on 7 years at a peak level of 590 per year. 

b

 BLS, 2008a. 

c

 BLS, 2008b.

1 

2 Based on these estimates, impacts on occupational safety from preconstruction and 

3 construction would be SMALL. 

4 

5 Nonradiological Exposures

6 

7 Occupational exposures during preconstruction and construction would include exposure of 

8 construction workers to airborne fugitive dust generated from vehicle traffic and heavy 

9 equipment use, exposure to pollutants emitted from diesel- and gasoline-powered equipment 

10 (e.g., CO, NOx, SOx, and PM), and exposure to vapors from any fuels, paints, or solvents that 

11 are used. Any such exposures would be minor and would be minimized using the work 

12 practices and personal protective equipment as required by OSHA (29 CFR 1910). Such 

13 exposures would be typical of other construction projects of industrial facilities. Therefore, 

14 impacts to workers from chemical and dust exposure during preconstruction and construction 

15 would be SMALL. 

16 

17 Approximately 10 percent of the total occupational injury and nonradiological impacts discussed 

18 above would occur from the preconstruction activities. This value is based on AES’s estimate 

19 that the preconstruction activities would be completed within the first 8 months of a total 

20 84-month construction schedule (AES, 2009b). This 10 percent estimate is likely an upper 

21 bound, as fewer workers would be expected to be involved during preconstruction than during 

22 the main facility construction phase. 

23 

24 Radiological Exposures

25 

26 The radionuclide concentrations at the proposed EREF site are either at or below background 

27 natural levels (see Section 3.6.4). Therefore, there would not be any radiological impacts above 

28 normal background levels. 

29 

30 4.2.10.2 Facility Operation 

31 

32 This section evaluates the potential for occupational injuries and illnesses associated with the 

33 operation of the proposed EREF. It also evaluates the potential public and occupational health 

34 impacts from nonradiological and radiological releases during facility operation. 

35 

36 
 4-78 

1 Occupational Injury and Illness Rates and Fatalities

2 

3 Workplace safety regulations are administered by the Occupational Safety and Health 

4 Administration (OSHA). Occupational hazards would be minimized when workers adhere to 

5 safety standards and use appropriate protective equipment; however, fatalities and injuries from 

6 accidents could still occur. 

7 

8 The ER summarizes a comparison of yearly reportable lost-time accidents for fiscal years 2003–

9 2007 for the similar URENCO Capenhurst Limited uranium enrichment facility in Great Britain. 

10 The OSHA lost workday case rates varied from 0 to 1.62 per 100 FTE workers (FTEs) per year 

11 (AES, 2010a). For comparison, the BLS compiles annual injury and illness incidence rates by 

12 industry (BLS, 2008a). The national average incidence rate of nonfatal occupational injuries 

13 and illnesses resulting in lost workdays for classification 325, “Chemical Manufacturing,” for 

14 calendar year 2007 was 0.8 per 100 FTEs per year, which is within range of 0 to 1.62 reported 

15 for the Capenhurst enrichment facility. Thus, the rates of occupational injuries and illnesses at 

16 the proposed EREF would be expected to be similar to those at the existing Capenhurst facility 

17 and to those in the chemical manufacturing industry in general. 

18 

19 Assuming an estimated 550 FTEs during operation of the proposed EREF (AES, 2010a) and 

20 using a rate of 3.1 total incidents and 0.8 lost-time injuries and illnesses per 100 workers, 

21 17 total incidents and 4.4 lost-time injuries and illnesses per year would be projected. For an 

22 operating period of 30 years, 512 total incidents and 132 lost-time incidents would be projected, 

23 as shown in Table 4-15. 

24 

25 The number of fatal accidents projected during operations was computed assuming an incident 

26 rate of 2.0 per 100,000 FTEs for chemical manufacturing (BLS, 2008b). For 30 years of 

27 operation, less than one fatality is projected. Accordingly, impacts for occupational illnesses 

28 and injuries and fatalities during facility operation would be SMALL. 

29 

30 Nonradiological Exposures

31 

32 Chemical exposures of primary concern to workers and members of the public during plant 

33 operations would be to UF6 vapors and HF, which are produced along with UO2F2 when UF6

34 vapors contact moisture in air. Exposures to uranium compounds and HF would be of similar 

35 concern, given similar exposure standards for these chemicals in occupational settings. 

36 However, the potential for exposures to any of these chemicals during normal operations would 

37 be slight, since the UF6 process line is maintained at subatmospheric pressure. Exposure risks 

38 at process line points where feed and product vessels are connected and disconnected would 

39 be minimized through the use of flexible fume collection lines operated at subatmospheric 

40 pressure and through the use of personal protective equipment by workers. Handling of all 

41 chemicals would be done in accordance with the Environment, Health, and Safety Program for 

42 the proposed EREF, which would conform to 29 CFR 1910 and specify the use of engineering 

43 controls, including personal protective equipment, to minimize chemical exposures during 

44 operations (AES, 2010a). 

45 

46 Process ventilation lines would be run to chemical traps before venting to the outdoors to 

47 prevent exposures to the public. AES estimates that the annual average HF concentration 

48 emission from a nominal 6 million SWU per year centrifuge enrichment plant would be 
 4-79 

Table 4-15 Estimated Occupational Health-Related Incidences during Plant Operation 

FTE Injury and Illness Cases Lost Workday Cases Fatalities 

FTEs per 

Year 

Total 

FTEa

Incidents per 

100 FTEsb

Total 

Recordable 

Cases 

Incidents per 

100 FTEsb

Lost 

Workday 

Cases 

Incidents per 

100,000 FTEsc

Total 

Fatalities

550 16,500 3.1 512 0.8 132 2.0 0.33 a

 Assumes 30 years of operation. 

b

 BLS, 2008a. 

c

 BLS, 2008b.

1 

2 7.7 micrograms per cubic meter (0.0094 ppm) at the point of discharge (rooftop) based on 

3 annual emission of less than 2.0 kilograms (4.4 pounds) (AES, 2010a). This concentration is 

4 well below the occupational exposure limit of 2.5 milligrams per cubic meter (3.1 ppm) for 8-hour 

5 exposure set by both OSHA and the National Institute for Occupational Safety and Health 

6 (NIOSH) (ATSDR, 2003). Workers would not be expected to be exposed to HF concentrations 

7 greater than that at the discharge point. 

8 

9 Taking atmospheric dispersion into consideration, the discharge point concentration would fall to 

3.4  10-4 micrograms per cubic meter (4.2  10-7 10 ppm) at the proposed property boundary 

11 1100 meters (3600 feet) to the north, based on dispersion modeling (see Appendix E), and to 

12 even lower levels at further distances where members of the public might be exposed. These 

13 levels are several orders of magnitude below Idaho’s AAC of 125 micrograms per cubic meter 

14 (0.15 ppm) for fluoride (IDAPA 58.01.01). 

15 

16 Occupational and public exposure to uranium compounds, UF6 and UO2F2, would be to 

17 concentrations similar to or less than that of HF. Using releases from a 1.5 million SWU plant 

18 described in NUREG-1484 (NRC, 1994) linearly scaled up to a 6.6 million SWU facility, the size 

19 of the proposed EREF, results in an estimated annual gaseous release of 743 grams 

20 (1.63 pounds) of uranium which is about half the estimate of the annual HF release. 

21 Conservatively applying the same dispersion factors as used for HF, uranium concentrations at 

the proposed property boundary would be on the order of 1  10-4 22 microgram per cubic meter. 

23 While no Federal or Idaho ambient air standard is available for uranium with which to compare 

24 this level, it is more than five orders of magnitude below the NIOSH and OSHA occupational 

25 exposure limit of 50 micrograms per cubic meter (soluble uranium forms, 8-hour time weighted 

26 average) (NIOSH, 1996, 2005). 

27 

28 Occupational exposures would be expected to be low, but might be briefly elevated to some 

29 workers during cylinder connection and disconnection activities. Estimates of such “puff” 

30 emissions of UF6 performed for the proposed American Centrifuge Plant in Piketon, Ohio, of up 

31 to 0.7 milligram per cubic meter (NRC, 2006) are similar to the short-term exposure limit of 

32 0.6 milligram per cubic meter for uranium set by the American Conference of Governmental 

33 Industrial Hygienists (NIOSH, 1996), and well below the NIOSH “Immediately Dangerous to Life 

34 and Health” standard of 10 milligrams per cubic meter for exposures over a 1-hour period 

35 (NIOSH, 1996). At the proposed EREF, any such brief exposures would be mitigated with a 

36 gaseous effluent ventilation system (AES, 2010a), which would be expected to maintain levels 

37 below occupational health standards based on the similarity of the design of the proposed 

38 EREF to that of the American Centrifuge Plant (NRC, 2006). 
 4-80 

1 Thus, due to low estimated concentrations of uranium and HF at public (proposed property 

2 boundary) and workplace receptor locations, the public and occupational health impacts due to 

3 exposures to hazardous chemicals during normal operations would be SMALL. 

4 

5 Radiological Exposures

6 

7 Exposure to uranium may occur from routine operations as a result of small controlled releases 

8 to the atmosphere from the uranium enrichment process lines and decontamination and 

9 maintenance of equipment, releases of radioactive liquids to surface water, and as a result of 

10 direct radiation from the process lines, storage, and transportation of UF6. Direct radiation and 

11 skyshine (radiation reflected from the atmosphere) in offsite areas due to operations within the 

12 SBMs is expected to be undetectable because most of the direct radiation associated with the 

13 uranium would be almost completely absorbed by the heavy process lines, walls, equipment, 

14 and tanks that would be employed at the proposed EREF, and would have to travel 8 kilometers 

15 to reach the nearest member of the public. 

16 

17 At the proposed EREF, the major source of occupational exposure would be from direct 

18 radiation from UF6 with the largest exposure source being the empty Type 48Y cylinders with 

19 residual material, full Type 48Y cylinders containing either the feed material or depleted UF6, 

20 Type 30B product cylinders, and various traps that help minimize UF6 losses from the cascade 

21 (AES, 2010a). Atmospheric releases would be expected to be a source of public exposure. 

22 Such releases would be primarily controlled through the Technical Support Building and SBM 

23 gaseous effluent vent systems (AES, 2010a). 

24 

25 Radiological Sources

26 

27 The estimated release of gaseous uranium from the proposed EREF would be less than 

28 20 grams (0.7 ounces) per year (AES, 2010a). However, for conservatism, the radiological 

29 impacts to both workers and members of the public were modeled, using the CAP88-PC 

30 computer code (EPA, 2009d), on the basis of releases from a 1.5 million SWU plant described 

31 in NUREG-1484 (NRC, 1994), Final Environmental Impact Statement for the Construction and 

32 Operation of Claiborne Enrichment Center, Homer, Louisiana, linearly scaled up to a 6.6 million 

33 SWU facility resulting in an annual gaseous release of 743 grams (1.63 pounds) of uranium 

34 (AES, 2010a). This corresponds to an activity concentration of 19.5 megabecquerels 

35 (527 microcuries) (AES, 2010a). 

36 

37 During the time period when the proposed EREF is operational and construction activities 

38 continue, construction workers would be exposed to gaseous uranium effluents and external 

39 radiation from UF6 cylinders. For conservatism, the same 19.5-megabecquerel (527-microcurie) 

40 annual release was used when estimating the dose from airborne releases during construction 

41 and operation. Two different release points were used to model doses to the construction 

42 workers during the period of expansion. One release point was associated with the Technical 

43 Service Building and the other release point was associated with the Separation Building 

44 Modules (AES, 2009b). For the external dose calculations, the construction workers were 

45 conservatively modeled, using the MCNP computer code (X5 Monte Carlo Team, 2003), as 

46 being positioned in the cylinder yard as if they were completing the last 20 percent of the 

47 cylinder pad, when the largest amount of material is in storage during construction, and thus 
 4-81 

1 were exposed to external radiation from stored UF6 tails, full UF6 feed, and empty cylinders 

2 (AES, 2009b). 

3 

4 Doses to members of the public were modeled, using CAP88-PC (EPA, 2009d), based on the 

5 same 19.5-megabecquerel (527-microcurie) annual release from the proposed EREF. Due to 

6 the distance (8000 m) of the nearest resident to the TSB and SBM, all releases were modeled 

7 as originating from a single source. For the external pathway it was conservatively assumed 

8 members of the public were exposed to a full cylinder storage pad (AES, 2010a). Table 4-16 

9 provides the radiological sources used for the normal operation impact assessment for 

10 occupational workers and members of the public. 

11 

12 Occupational Exposure

13 

14 Occupational exposure to radioactive material could result from releases to the atmosphere 

15 from the proposed EREF through stack releases from the Technical Support Buildings and 

16 SBMs gaseous effluent vent system and direct external radiation from the Cylinder Storage Pad. 

17 

18 The expected exposure pathways for the public include inhalation of airborne contaminants, 

19 direct exposure from material deposited on the ground, and external exposure associated with 

20 the stored UF6 cylinders. 

21 

22 Two groups of workers were evaluated, the construction worker dose during the overlap period 

23 when construction is continuing at the proposed EREF and routine operations have begun, and 

24 the worker population supporting the proposed EREF during operations. 

25 

26 The construction worker population dose was modeled by considering 10 different receptor 

27 locations around the proposed EREF (AES, 2009b). Receptors 1 to 4 considered the 

28 construction workers at the SBMs and the UF6 handling areas, and receptors 5 to 10 considered 

29 the storage pad workers completing the last 20 percent of the UF6 Cylinder Storage Pad 

30 (AES, 2009b). Table 4-17 provides the atmospheric dispersion factors (χ/Q) used in the dose 

31 calculations for the collective construction worker population dose during the overlap period of 

32 construction and operations. Table 4-18 provides the worker population distribution and 

33 duration of exposure during this period of construction and operation overlap. 

34 

35 Table 4-19 provides a summary of the dose impacts to the construction workers during the 

36 overlap period of construction and operations. The collective construction worker annual 

37 population dose was estimated to be 0.376 person-sievert (37.6 person-rem) with over 

38 99.99 percent of the radiation dose being attributable to the external dose associated with the 

39 stored UF6 cylinders. 

40 

41 The most significant impact would be from direct radiation exposure to the construction workers 

42 completing the cylinder storage pads. The dose to an average construction worker completing 

43 the last 20 percent of the UF6 cylinder pad is estimated to receive a dose of 1.96 millisieverts 

44 per year (196 millirem per year). Since this dose exceeds the limit specified in 10 CFR 20.1301, 

45 these workers should be part of a radiation dosimetry program and reclassified as radiation 

46 workers. 

47 

48 
 4-82 

Table 4-16 Source Term Used for the 

Radiological Impact Assessment for 

Normal Operationsa

Radionuclide Wt % Activity 

MBq (μCi) 

234U 5.5  10-3 9.5 (260) 

235U 0.71 0.5 (10) 

238U 99.3 9.5 (260) 

Total 19.5 (530) 

a

 Members of the general public, 6.6-million-SWU 

facility. Annual uranium released: 760 grams, 

19.5 MBq (530 μCi). 

Source: Derived from AES, 2010a.

1 

2 Table 4-20 provides estimated annual doses for representative workers within the proposed 

3 EREF, and Table 4-21 provides estimated dose rates for workers at several areas at the 

4 proposed EREF. Annual whole-body dose equivalents accrued by workers at an operating 

5 uranium enrichment plant are typically low and range from 0.22 to 0.44 millisievert (22 to 

6 44 millirem) (URENCO, 2003, 2004, 2005, 2006, 2007). In general, annual doses to workers 

7 are expected to range from 0.050 millisievert per year (5 millirem per year) for general office 

8 staff to 3 millisieverts per year (300 millirem per year) for cylinder handlers. For the proposed 

9 EREF, AES has proposed an administrative limit of 0.01 sievert per year (1 rem per year) to any 

10 radiation worker. This limit is 20 percent of the limit provided in 10 CFR 20.1201. Impacts to 

11 workers at the proposed EREF are expected to be typical of similar facilities, and would be 

12 SMALL. 

13 

14 Public Exposure

15 

16 Public exposure to radioactive material could result from releases to the atmosphere from the 

17 proposed EREF through stack releases from the Technical Support Building and SBM gaseous 

18 effluent vent systems. Also, although members of the public would not be expected to spend a 

19 significant amount of time at the property boundary closest to the Cylinder Storage Pad, this 

20 exposure possibility is considered in the impact assessment. The analysis estimated the 

21 potential radiation dose to the collective population residing within 80 kilometers (50 miles) of 

22 the proposed EREF, a hypothetical MEI located at the proposed EREF property boundary and 

23 the nearest resident who lives 8 kilometers (5 miles) from the proposed EREF. 

24 

25 The expected exposure pathways for the public include: inhalation of airborne contaminants, 

26 external exposure from material deposited on the ground, external exposure associated with the 

27 stored UF6 cylinders, and ingestion of resuspended soil. In addition, members of the public may 

28 be exposed to uranium compounds that are incorporated into the edible portions of plants and 

29 animals. These additional exposure pathways include the ingestion of vegetables, the ingestion 

30 of locally produced meat, and the ingestion of locally produced milk. Table 4-22 provides the 

31 population distribution used to estimate the collective population dose for airborne releases 

32 associated with the proposed EREF. Table 4-23 provides the locations and exposure times for 
 4-83 Table 4-17 Locations and Annual Average Atmospheric Dispersion Factors 

χ/Q (s/m3) for the Construction 

Workers during the Period of Construction and Operations Overlap

Receptor Location 1 2 3 4 5 6 7 8 9 10 

Direction/distance from release point 1 to receptor location (m)a

WSW/ 

202 

WSW/101 SW/241 SW/173 N/310 NNW/317 NNW/349 N/504 N/515 NNE/533 

Atmospheric dispersion factors (s/m3) 

1.18  10-4 2.88  10-4 7.84  10-5 1.34  10-4 5.65  10-5 4.73  10-5 3.93  10-5 2.33  10-5 2.24  10-5 1.80  10-5

Direction/distance from release point 2 to receptor location (m)a

W/252 WNW/151 WSW/252 WSW/158 N/389 NNW/414 NNE/410 N/587 NNW/605 NNE/601 

Atmospheric dispersion factors (s/m3) 

5.70  10-5 6.32  10-5 8.29  10-5 1.70  10-4 3.76  10-5 2.94  10-5 2.93  10-5 1.76  10-5 1.47  10-5 1.44  10-5

a Source: AES, 2009b.

1 
 4-84 

Table 4-18 Worker Population Distribution during the 

Period of Construction and Operations Overlap 

Labor Craft Plant Area Craft Hours 

per Year Persons 

Civil/structural UF6 handling 109,174 54 

 SBM 269,296 134 

 Cylinder pad 24,729 12 

Mechanical UF6 handling 65,504 32 

 SBM 161,577 80 

 Cylinder pad 14,837 7 

Electrical UF6 handling 43,669 22 

 SBM 107,718 53 

 Cylinder pad 9891 5 

Totals UF6 handling 218,348 108 

 SBM 538,592 267 

 Cylinder pad 49,459 24.5 

Source: AES, 2009b.

1 

2 the public receptors evaluated in the radiological impact assessment. The impacts of normal 

3 operations at the proposed EFEF to public health would be SMALL. 

4 

5 The most significant impact would be from direct radiation exposure to public receptors close to 

6 the storage of full feed, full tails, and empty Cylinder Storage Pads. 

7 

8 For conservatism the dose to the maximally exposed individual was calculated at the proposed 

9 northern site boundary since this was the location of both the maximum external and inhalation 

10 dose to a receptor. The dose was calculated assuming 2000 hours per year occupancy. The 

11 2000 hours per year was selected as the exposure time assuming a 40-hour work week and 

12 that any developments adjacent to the proposed EREF would be commercial resulting in a 

13 person occupying the adjacent site part time (approximately 2,000 hours per year rather than a 

14 full time (8,760 hours per year). The dose equivalent for this exposure scenario was estimated 

15 to be 0.014 millisievert per year (1.4 millirem per year) 

16 

17 The collective population dose for persons living within 80 kilometers (50 miles) of the proposed 

EREF was estimated to be 1.7  10-5 person-sievert (1.7  10-3 18 person-rem). The dominant 

19 pathway is inhalation, which comprises approximately 88 percent of the total dose. Due to the 

20 large distance between the population and the stored UF6 cylinders, the entire dose is due to 

21 atmospheric releases of uranium compounds during normal operations. Table 4-24 provides 

22 the calculated atmospheric dispersion factors (χ/Q) used in the dose calculations for members 

23 of the general public. 
 4-85 

Table 4-19 Summary of Annual Radiological Impacts Associated with the Construction 

Workers during the Overlap Period of Construction and Operations at the 

Proposed EREF 

Receptor 

Atmospheric 

Dispersion 

Factorsa

(s/m3

) 

Dose 

Associated with 

Air Releases 

person-Sv 

(person-rem) or 

mSv (mrem) 

Dose Associated with 

Direct Radiation from 

Stored UF6 Cylinders 

person-Sv 

(person-rem) 

or 

mSv (mrem) 

Total 

Committed 

Effective Dose 

person-Sv 

(person-rem) 

or 

mSv (mrem) 

Construction worker 

Population: 

 SBM + UF6 handling area 

Storage pad 

Total 

 

1.57  10-4

(1.57  10-2) 

2.39  10-6

(2.39  10-4) 

1.59  10-4

(1.59  10-2) 

0.136b

(13.6) 

0.24b

24 

0.376 

(37.6)

0.136 

(13.6) 

0.24 

24 

0.376 

(37.6)

Construction pad worker 5.65  10-5 c 1.59  10-7 d

(1.59  10-5) 

1.96b

(196) 

1.96 

(196) 

Regulatory limit for Individual 0.1e: 1f: 5g

(10:100:500) a

 The atmospheric dispersion factors are provided in Table 4-16. 

b

 Source: AES, 2009b. 

c

 This represents the maximum atmospheric dispersion factor for the six areas (locations 5-10) that were modeled for the 

construction pad worker. See Table 4-16. 

d

 For airborne releases, the construction worker is assumed to be present in the area yielding the largest inhalation dose. 

e

 Source: 10 CFR 20.1101 (applies to airborne releases only). 

f

 Source: 10 CFR Part 20, Subpart D. 

g

 Source: 10 CFR Part 20, Subpart C. 

1 

Table 4-20 Estimated Occupational Annual Exposures for Various 

Occupations for the Proposed EREF 

Position Annual Dose Equivalent 

mSv (mrem) 

General office staff <0.05 (<5.0) 

Typical operations and maintenance technician 1 (100) 

Typical cylinder handler 3 (300) 

Source: AES, 2010a.

2 
 4-86 

Table 4-21 Estimated Dose Rates at Various Locations within 

the Proposed EREF 

Position Dose Rate 

mSv per hour (mrem per hour) 

Plant general area 0.0001 (0.01) 

Separation building cascade halls 0.0005 (0.05) 

Separation building 0.001 (0.1) 

Empty used UF6 shipping cylinder 

 on contact 

 At 1 meter (3.3 feet) 

0.1 (10) 

0.01 (1) 

Full UF6 shipping cylinder 

 on contact 

 At 1 meter (3.3 feet) 

0.05 (5) 

0.002 (0.2) 

Source: AES, 2010a.

1 

The dose to the nearest resident was estimated to be 2.12  10-6 2 millisievert per year 

(2.12  10-4 3 millirem per year). Due to the large distance between the stored UF6 cylinders and 

4 the receptor, only the dose contribution is associated with the airborne release. The dominant 

5 pathway is inhalation comprising 94 percent of the total dose. For comparative purposes, this 

6 dose is over 470,000 times lower than the 0.1 millisievert per year (10 mrem per year) dose limit 

7 for members of the public as codified in 10 CFR 20.1101 for airborne releases. 

8 

9 The dose to a member of the public at the proposed property boundary was estimated to be 

10 approximately 0.014 millisievert per year (1.4 millirem per year). Approximately 98.6 percent of 

11 the total dose to this individual is due to the external dose of the stored UF6 cylinders. Since the 

12 vast majority of the dose is from external gamma radiation from the UF6 cylinders, for 

13 comparative purposes, this dose is over 70 times lower than the 1 millisievert per year 

14 (100 mrem per year) dose limit for members of the public as codified in 10 CFR 20.1301. 

15 

16 Table 4-25 provides a summary of all radiological impacts to members of the general public 

17 associated with the proposed EREF. Because of the low doses involved, these impacts would 

18 be SMALL. 

19 

20 4.2.10.3 Mitigation Measures 

21 

22 Plant design features such as controls and processes for the proposed EREF have been 

23 identified by AES to minimize the gaseous and liquid effluent releases, and to maintain the 

24 impacts to workers and the surrounding population below regulatory limits (AES, 2010b). These 

25 would include: 

26 

27 • maintain system process pressures that are subatmospheric 

28 

29 • pass process gases through desublimers to solidify as much UF6 as possible 

30 
 4-87 Table 4-22 Extrapolated Population Distribution within 80 km (50 miles) of the Proposed EREF Direction 0-1.6 km (0-1 mi) 1.6-3.2 km (1-2 mi) 3.2-4.8 km (2-3 mi) 4.8-6.4 km (3-4 mi) 6.4-8.0 km (4-5 mi) 8.0-16 km (5-10 mi) 16-32 km (10-20 mi) 32-48 km (20-30 mi) 48-64 km (30-40 mi) 64-80 km (40-50 mi) S 0 0 0 0 0 0 169 20,589 3835 61,264 SSW 0 0 0 0 0 0 49 757 1172 3477 SW 0 0 0 0 0 0 49 55 5 38 WSW 0 0 0 0 0 0 0 33 9 6 W 0 0 0 0 0 0 0 0 10 2142 WNW 0 0 0 0 0 0 0 56 220 562 NW 0 0 0 0 0 0 0 0 0 84 NNW 0 0 0 0 0 0 53 299 58 18 N 0 0 0 0 0 0 921 223 146 70 NNE 0 0 0 0 0 0 290 559 157 831 

NE 0 0 0 0 0 3 193 8 1365 4882 

ENE 0 0 0 0 0 3 1561 9655 29,946 4229 

E 0 0 0 0 0 17 1004 13,654 3436 37 

ESE 0 0 0 0 0 14 12,744 68,188 421 0 

SE 0 0 0 0 0 0 741 10,303 21 2 

SSE 0 0 0 0 0 75 142 6214 78 114 

Source: AES, 2010a. 

1 
 4-88 

Table 4-23 General Public Receptor Locations for Radiological 

Impact Assessment 

Receptor 

Direction from 

the Source to 

the Receptor 

Distance from 

Source to 

Receptor 

(m) 

Time Spent at 

the Location 

(hr) 

Nearest residenta Northeast 8000 8761 

Hypothetical member of the public at 

the proposed site boundary:b

 Cylinder pad 

 Atmospheric release 

North 

North 

760 

1100 

2000 

a Source: AES, 2010a. 

b

 Derived from AES, 2010a.

1 

2 • pass gaseous effluents through pre-filters, high-efficiency particulate air (HEPA) filters, and 

3 activated carbon filters to reduce the radioactivity in the final discharged effluent to very low 

4 concentrations 

5 

6 • investigate alternative solvents or apply control technologies for methylene chloride solvent 

7 use 

8 

9 • use administrative controls, practices, and procedures to assure compliance with the 

10 proposed EREF Health, Safety, and Environmental Program; design the program to ensure 

11 safe storage, use, and handling of chemicals to minimize the potential for worker exposure 

12 

13 • monitor all UF6 process systems by instrumentation that will activate alarms in the Control 

14 Room and will either automatically shut down the facility to a safe condition or alert 

15 operators to take the appropriate action to prevent release in the event of operational 

16 problems 

17 

18 • put in place radiological practices and procedures to ensure compliance with the proposed 

19 EREF Radiation Protection Program; design the program to achieve and maintain 

20 radiological exposure to levels that are as low as reasonably achievable (ALARA) 

21 

22 • conduct routine facility radiation and radiological surveys to characterize and minimize 

23 potential radiological dose/exposure 

24 

25 • monitor all radiation workers by use of dosimeters and area air sampling to ensure that 

26 radiological doses remain within regulatory limits and are ALARA 

27 

28 • provide radiation monitors in the gaseous effluent vents to detect and alarm and effect the 

29 automatic safe shutdown of process equipment in the event contaminants are detected in 

30 the system exhaust; design systems to automatically shut down, switch trains, or rely on 

31 operator actions to mitigate the potential release 

32 
 4-89 Table 4-24 Annual Average Atmospheric Dispersion Factors 

χ/Q (s/m3) for the General Population

Direction 

0-1.6 km 

(0-1 mi) 

1.6-3.2 km 

(1-2 mi) 

3.2-4.8 km 

(2-3 mi) 

4.8-6.4 km 

(3-4 mi) 

6.4-8.0 km 

(4-5 mi) 

8.0-16 km 

(5-10 mi) 

16-32 km 

(10-20 mi) 

32-48 km 

(20-30 mi) 

48-64 km 

(30-40 mi) 

64-80 km 

(40-50 mi) 

S 3.86  10-7 1.92  10-7 1.11  10-7 7.54  10-8 5.58  10-8 3.02  10-8 1.26  10-8 6.60  10-9 3.98  10-9 2.53  10-9

SSW 6.11  10-7 2.90  10-7 1.65  10-7 1.12  10-7 8.24  10-8 4.48  10-8 1.88  10-8 1.00  10-8 6.15  10-9 4.00  10-9

SW 4.85  10-7 2.64  10-7 1.60  10-7 1.12  10-7 8.50  10-8 4.88  10-8 2.15  10-8 1.18  10-8 7.42  10-9 4.90  10-9

WSW 2.05  10-7 1.61  10-7 1.08  10-7 7.90  10-8 6.26  10-8 3.89  10-8 1.81  10-8 1.03  10-8 6.59  10-9 4.39  10-9

W 1.16  10-7 9.11  10-8 6.14  10-8 4.53  10-8 3.63  10-8 2.31  10-8 1.07  10-8 6.04  10-9 3.79  10-9 2.47  10-9

WNW 8.35  10-8 6.31  10-8 4.16  10-8 3.01  10-8 2.35  10-8 1.42  10-8 6.22  10-9 3.39  10-9 2.04  10-9 1.26  10-9

NW 8.15  10-8 6.59  10-8 4.40  10-8 3.19  10-8 2.49  10-8 1.50  10-8 6.56  10-9 3.60  10-9 2.19  10-9 1.37  10-9

NNW 1.66  10-7 1.38  10-7 9.41  10-8 6.93  10-8 5.51  10-8 3.42  10-8 1.60  10-8 9.21  10-9 6.00  10-9 4.09  10-9

N 2.88  10-7 2.06  10-7 1.36  10-7 9.82  10-8 7.67  10-8 4.61  10-8 2.10  10-8 1.19  10-8 7.60  10-9 5.08  10-9

NNE 5.19  10-7 2.75  10-7 1.66  10-7 1.16  10-7 8.77  10-8 5.03  10-8 2.25  10-8 1.26  10-8 8.15  10-9 5.59  10-9

NE 6.45  10-7 2.79  10-7 1.58  10-7 1.07  10-7 7.89  10-8 4.32  10-8 1.87  10-8 1.02  10-8 6.52  10-9 4.47  10-9

ENE 4.24  10-7 1.79  10-7 9.87  10-8 6.55  10-8 4.79  10-8 2.55  10-8 1.06  10-8 5.61  10-9 3.47  10-9 2.30  10-9

E 2.29  10-7 9.78  10-8 5.49  10-8 3.67  10-8 2.68  10-8 1.42  10-8 5.67  10-9 2.91  10-9 1.72  10-9 1.07  10-9

ESE 2.31  10-7 9.89  10-8 5.58  10-8 3.72  10-8 2.72  10-8 1.43  10-8 5.61  10-9 2.84  10-9 1.65  10-9 1.00  10-9

SE 2.69  10-7 1.14  10-7 6.31  10-8 4.18  10-8 3.04  10-8 1.59  10-8 6.29  10-9 3.20  10-9 1.87  10-9 1.15  10-9

SSE 3.18  10-7 1.49  10-7 8.45  10-8 5.67  10-8 4.16  10-8 2.22  10-8 8.98  10-9 4.64  10-9 2.75  10-9 1.72  10-9

1 
 4-90 

Table 4-25 Summary of Radiological Impacts for Members of the Public Associated with 

the Proposed EREF

Receptor 

Atmospheric 

Dispersion 

Factors 

(s/m3

) 

Dose 

Associated with 

Air Releases 

person-Sv 

(person-rem) or 

mSv (mrem) 

Dose Associated with 

Direct Radiation from 

Stored UF6 Cylinders 

person-Sv 

(person-rem) 

or 

mSv (mrem) 

Total 

Committed 

Effective Dose 

person-Sv 

(person-rem) 

or 

mSv (mrem) 

General population See Table 4-24 1.74  10-5

(1.74  10-3) 

~ 0 1.74  10-5

(1.74  10-3) 

Nearest resident 1.26  10-7 2.12  10-6

(2.12  10-4) 

~0 2.12  10-6

(2.12  10-4) 

Hypothetical member of the 

public at the proposed site 

boundary 

5.39  10-6 1.94  10-5

(1.94  10-3) 

0.014a

(1.4) 

0.014 

(1.4) 

Regulatory limit for individualb 0.1c:1 

(10:100) a

 Source: AES, 2010a. 

b

 Source: 10 CFR Part 20, Subpart D. 

c

 Source: 10 CFR 20.1101 (applies to airborne releases only).

1 

2 • design the proposed facility to delay and reduce UF6 releases inside the buildings in a 

3 potential fire incident from reaching the outside environment, including automatic shutoff of 

4 room HVAC systems during a fire event 

5 

6 • move UF6 cylinders only when cool and when UF6 is in solid form, to minimize the risk of 

7 inadvertent release due to mishandling 

8 

9 • separate uranic compounds and various other heavy metals in waste material generated by 

10 decontamination of equipment and systems 

11 

12 • use liquid and solid waste handling systems and techniques to control wastes and effluent 

13 concentrations 

14 

15 • route process liquid waste to collection tanks and treat through a combination of 

16 precipitation, evaporation, and ion exchange to remove most of the radioactive material prior 

17 to a final evaporation step to preclude any liquid effluent release from the proposed facility 

18 

19 • to further mitigate radiation dose, implement an ALARA program in addition to routine 

20 radiological surveys and personnel monitoring 

21 

22 The NRC identified the following additional mitigation measure: 

23 

24 • store “empty” cylinders with heels in the middle of a storage pad between full tail cylinders to 

25 reduce external exposure to workers 

26 
 4-91 

1 4.2.11 Waste Management Impacts 

2 

3 This section describes the analysis and evaluation of the potential impacts of the solid, 

4 hazardous, and radioactive waste management program at the proposed EREF, and includes 

5 impacts resulting from temporary storage, conversion, and disposal of depleted UF6. The 

6 impacts of gaseous effluent and wastewater releases are addressed in Sections 4.2.4, 4.2.6, 

7 and 4.2.10 of this EIS. Waste management impacts (not including depleted UF6) would be 

8 SMALL due to the low volumes of waste generated by the proposed facility in comparison to the 

9 availability of disposal options and capacity for the various waste streams. Impacts from the 

10 conversion of depleted UF6 from the proposed EREF at an offsite location would be SMALL. 

11 

12 Due to the nature, design, and operation of a gas centrifuge enrichment facility, the generation 

13 of waste materials can be categorized by three distinct facility operations: (1) preconstruction 

14 and construction, which generates typical construction wastes associated with an industrial 

15 facility; (2) enrichment process operations, which generate gaseous, liquid, and solid waste 

16 streams; and (3) generation and temporary storage of depleted UF6. Section 4.2.16 of this 

17 chapter discusses decommissioning wastes. Waste materials include low-level radioactive 

18 waste (i.e., depleted UF6 and material contaminated with UF6), designated hazardous materials 

19 (as defined in 40 CFR Part 261), mixed (radioactive and hazardous), and nonhazardous 

20 materials (any other wastes not identified as radioactive or hazardous). Hazardous materials 

21 include any fluids, equipment, and piping contaminated as defined in 40 CFR Part 261 that 

22 would be generated due to preconstruction, construction, operation, and maintenance activities. 

23 

24 The handling and disposal of waste materials are governed by various Federal and State 

25 regulations. The proposed EREF waste management program is intended to minimize the 

26 generation of waste through reduction, reuse, or recycling, and includes systems for the 

27 collection, removal, and proper disposal of waste materials (AES, 2010a). This program would 

28 assist in identifying process changes that can be made to reduce or eliminate mixed wastes, 

29 methods to minimize the volume of regulated wastes through segregation of materials, and the 

30 substitution of nonhazardous materials as required under Resource Conservation and Recovery 

31 Act (RCRA) regulations. 

32 

33 4.2.11.1 Preconstruction and Construction 

34 

35 Nonhazardous/Nonradioactive Solid Wastes

36 

37 Solid nonhazardous wastes generated during preconstruction and construction would be very 

38 similar to wastes generated from the construction sites of other industrial facilities. These 

39 wastes would be transported offsite to an approved local landfill (AES, 2010a). 

40 

41 Approximately 6116 cubic meters (8000 cubic yards) per year of noncompacted packing 

42 material, paper, and scrap lumber would be generated (AES, 2010a), based largely on 

43 projections for the National Enrichment Facility (NEF) in Lea County, New Mexico (LES, 2005). 

44 In addition, there would also be scrap structural steel, piping, and sheet metal that would not be 

45 expected to pose significant impacts on the surrounding environment because most could be 

46 recycled or directly placed in an offsite landfill. 

47 
 4-92 

1 Nonhazardous construction wastes would likely be transported to the Bonneville County Hatch 

2 Pit for disposal (AES, 2010a). The Hatch Pit is a former gravel mining site that is being 

3 reclaimed as a landfill. Upon opening in 1999, it was expected to reach capacity within 15 years 

4 (Bonneville County, 2006). Preconstruction and major construction activities at the proposed 

5 EREF site would begin in 2010 and last for approximately 8 years. Therefore, the Hatch Pit 

6 may reach capacity and stop accepting waste during construction of the proposed EREF, 

7 requiring the identification of an alternate disposal location for construction wastes in Bonneville 

8 County or a nearby county. Although detailed information on current waste acceptance rates 

9 are not available, the Bonneville Country Public Works Department has confirmed that a new 

10 construction and demolition waste disposal site will be permitted when the Hatch Pit nears 

11 capacity (Bonneville County, 2009). 

12 

13 Impacts from nonhazardous solid waste generation during preconstruction and construction 

14 would be SMALL due to the available current or future capacity at nearby disposal facilities. 

15 

16 Hazardous Wastes

17 

18 Hazardous wastes (e.g., waste oil, greases, excess paints, and other chemicals) generated 

19 during preconstruction and facility construction (e.g., due to the maintenance of construction 

20 equipment and vehicles, painting, and cleaning) would be packaged and shipped offsite to a 

21 licensed TSDF in accordance with Federal and State environmental and occupational 

22 regulations (AES, 2010a). The local TSDF is the U.S. Ecology facility near Grandview, Idaho, 

23 which is permitted to receive at least 4.5 million cubic meters (5.9 million cubic yards) of 

24 hazardous waste (AES, 2010a). Table 4-26 shows the hazardous wastes that would be 

25 expected from preconstruction and construction of the proposed EREF, which are based largely 

26 on projections for the NEF in Lea County, New Mexico (LES, 2005). This quantity of hazardous 

27 waste totals approximately 26 tons and represents less than 0.005 percent of the hazardous 

28 waste received by the U.S. Ecology facility in 2009 (IDEQ, 2010). The quantity of hazardous 

29 waste generated during preconstruction and construction would result in SMALL impacts due to 

30 the available capacity. 

31 

Table 4-26 Hazardous Waste Types and Quantities 

Expected during Preconstruction and Facility Construction 

Waste Type Annual Quantity 

Paints, solvents, thinners, organics 11,360 liters (3000 gallons) 

Petroleum products, oils, lubricants 11,360 liters (3000 gallons) 

Sulfuric acid (battery) 379 liters (100 gallons) 

Adhesives, resins, sealers, caulking 910 kilograms (2000 pounds) 

Lead (batteries) 91 kilograms (200 pounds) 

Pesticides 379 liters (100 gallons) 

Source: AES, 2010a.

32 

33 
 4-93 

1 Stormwater

2 

3 As discussed in Section 4.2.6 (Water Resources Impacts), stormwater runoff during 

4 preconstruction and construction would be collected in a stormwater detention basin that would 

5 allow the water to evaporate or infiltrate the ground surface (with allowance for overflow runoff 

6 to downgradient terrain). 

7 

8 Due to the types of activities performed and the types of wastes generated during 

9 preconstruction and construction, the relative contributions to waste impacts are estimated to be 

10 10 percent for preconstruction and 90 percent for construction. 

11 

12 4.2.11.2 Facility Operation 

13 

14 Gaseous effluents, liquid effluents, and solid wastes containing nonhazardous/nonradioactive, 

15 hazardous, and/or radioactive, and/or mixed waste materials would be generated onsite during 

16 normal operation of the proposed EREF. Appropriate treatment systems would be established 

17 to control releases or collect hazardous materials for onsite treatment or shipment offsite 

18 (AES, 2010a). Waste generation would be minimized, liquid wastes would be treated onsite, 

19 and solid wastes would be appropriately packaged and shipped offsite for further processing or 

20 final disposition (AES, 2010a). The impacts from gaseous and liquid effluents are described in 

21 Sections 4.2.4, 4.2.6, and 4.2.10. This section presents the onsite and offsite impacts from the 

22 management of solid and liquid wastes. 

23 

24 Solid Wastes

25 

26 The operation of the proposed EREF would generate approximately 75,369 kilograms 

27 (165,812 pounds) of solid nonradioactive waste annually, including approximately 

28 5062 kilograms (11,136 pounds) of hazardous wastes (AES, 2010a). Approximately 

29 146,500 kilograms (322,300 pounds) of radiological and mixed waste would be generated 

30 annually, of which approximately 100 kilograms (220 pounds) would be mixed waste 

31 (AES, 2010a). The types and quantities of radioactive and mixed waste are shown in 

32 Table 4-27. 

33 

34 Solid wastes generated during operations would be segregated and processed based on 

35 whether the material could be classified as wet solid or dry solid wastes and segregated into 

36 industrial (nonhazardous/nonradioactive), radioactive, hazardous, or mixed-waste categories. 

37 

38 Radioactive solid wastes would be Class A low-level radioactive wastes as defined in 10 CFR 

39 Part 61, packaged per DOT standards, and shipped to a licensed commercial low-level 

40 radioactive waste disposal facility or for further processing for volume reduction (AES, 2010a). 

41 Wet solid radioactive waste would include uranic waste precipitate from the liquid waste 

42 treatment process (AES, 2010a) (see Section 4.2.6). In its most recent analysis of low-level 

43 radioactive waste disposal capacity, the U.S. Government Accountability Office (GAO) 

44 concluded that the availability of disposal capacity in the United States for Class A low-level 

45 radioactive waste is not considered to be a problem for the short or long term (GAO, 2004, 

46 2007). Therefore, the impact of low-level radioactive waste generation would be SMALL on 

47 disposal facilities. Management of depleted UF6 is discussed later in this section. 

48 
 4-94 

Table 4-27 Radiological and Mixed Waste Types and Quantities Expected during 

Facility Operation 

Waste Type Annual Quantity 

kg (lb) 

Uranium Content 

kg (lb) 

Activated carbon 600 (1323) 50 (110) 

Activated alumina 4320 (9524) 4.4 (9.7) 

Perfluoropolyether oil 2054 (4528) 10 (22) 

Liquid waste treatment sludgea 2086 (4599) 114 (251)b

Activated sodium fluoridec – – 

Assorted materials (paper, clothing, 

etc.) 

4200 (9262) 60 (132) 

Ventilation filters 92,196 (203,259) 11 (24) 

Non-metallic components 10,000 (22,050) Traced

Miscellaneous mixed wastes (organic 

compounds)e

100 (220) 4 (8.8) 

Combustible waste 7000 (15,436) Traced

Scrap metal 24,000 (52,920) Traced

a

 Sludge and evaporator concentrates. 

b

 Value is composed of uranium in the citric acid and degreaser tanks, precipitated aqueous solutions, 

uranium in precipitated laboratory/miscellaneous effluents, and uranium in sludge from the citric acid and 

degreaser tanks. 

c

 No wastes are produced on an annual basis. Sodium fluoride traps are not expected to saturate over the 

life of the plant. 

d

 Not detectable above naturally occurring background concentrations. 

e

 Representative organic compounds consist of acetone, toluene, ethanol, and petroleum ether. 

Source: AES, 2010a. 

1 

2 As described in Sections 2.1.4.2 and 4.2.4.3, gaseous effluent from the GEVSs would pass 

3 through a pre-filter (to capture dust and other particulates), two sets of HEPA filters (to capture 

4 uranium particulates and aerosols), and an activated carbon filter (to capture HF). Similar filters 

5 would be used in the Centrifuge Test and Postmortem Facilities Exhaust Filtration System. 

6 After loaded filters are removed from service, they would be bagged to prevent the spread of 

contamination, sampled for 235 7 U content, and packaged for storage and eventual shipment to a 

8 volume reduction facility or low-level waste disposal facility (AES, 2010a). 

9 

10 Hazardous wastes (e.g., solvents, hydrocarbon sludge, chemicals, and empty hazardous 

11 material containers) generated at the proposed EREF would be collected at the point of 

12 generation, classified, packaged, and shipped offsite to a licensed TSDF in accordance with 

13 Federal and State environmental and occupational regulations. Hazardous wastes would not be 

14 treated, stored, or disposed of at the proposed EREF in a manner that requires a RCRA permit 

15 (AES, 2010a). The annual quantity of hazardous waste that would be generated by the 

16 proposed EREF represents approximately 0.001 percent of the hazardous waste received by 

17 the U.S. Ecology facility in 2009 (IDEQ, 2010). EPA and Idaho regulations, including the Idaho 
 4-95 

1 Standards for Hazardous Waste (IAC, 2008), would guide the management of hazardous 

2 wastes (AES, 2010a). 

3 

4 Mixed wastes that can be processed to meet land disposal requirements would be treated, 

5 packaged per DOT requirements, and shipped to a licensed commercial low-level radioactive 

6 waste disposal facility (AES, 2010a). Other mixed wastes would be collected, packaged per 

7 DOT standards, and shipped to a licensed commercial TSDF (such as the EnergySolutions 

8 facilities in Clive, Utah or Oak Ridge, Tennessee). Mixed wastes would not be treated, stored, 

9 or disposed of at the proposed EREF in a manner that requires a RCRA permit (AES, 2010a). 

10 Due to the small quantity of mixed waste that would be generated, the impact of mixed waste 

11 generation would be SMALL on disposal facilities. 

12 

13 The annual volume of industrial wastes generated at the proposed EREF would require 

14 approximately 181 shipments per year to a local landfill for disposal (AES, 2010a). The 

15 Peterson Hill Landfill is Bonneville County’s sole municipal landfill, accepting between 

16 58,960 and 68,040 metric tons (65,000 and 75,000 tons) of waste annually. Based on current 

17 waste generation rates and service population, Bonneville County expects the landfill to have a 

18 lifetime of 130 years, which would adequately encompass the operating lifetime of the proposed 

19 EREF (AES, 2010a; Bonneville County, 2009). Based on the estimate of waste accepted by the 

20 landfill in 2007, industrial solid waste generation from operation of the proposed EREF would 

21 increase the volume of wastes impounded at the landfill by less than 0.1 percent. Based on the 

22 quantities of solid wastes generated, the application of industry-accepted procedures, and the 

23 availability of capacity at regional disposal facilities, the impacts from solid wastes generated 

24 during operation would be SMALL. 

25 

26 Liquid Wastes

27 

28 As noted in Section 4.2.6.2, there would be no discharge of liquid effluents to surface water or 

29 groundwater during facility operation, and water quality impacts from facility operations are 

30 expected to be SMALL. 

31 

32 Liquid waste streams from facility operations would be processed by the Liquid Effluent 

33 Collection and Treatment System and would include laboratory effluent, degreaser water, citric 

34 acid, floor washings, miscellaneous condensates, and emergency hand washing and shower 

35 water from radiation areas. Most of these waste streams would be collected in the 

36 Miscellaneous Effluent Collection Tank, and some wastes (such as floor washings) would be 

37 sampled for uranic content prior to collection in the tank. Waste in this tank would be sampled 

38 for uranic content, treated by filtration and precipitation (if necessary), and vaporized in the 

39 Liquid Effluent Treatment System Evaporator to produce a chemically decontaminated gaseous 

40 effluent (see Section 4.2.10.2) (AES, 2010a). 

41 

42 Effluents containing uranium would be treated with potassium hydroxide to precipitate uranium 

43 and other precipitating agents (such as lime) to precipitate fluoride. Treated effluents would be 

44 sampled for uranium and fluoride content, and microfiltration and precipitation cycles would be 

45 repeated, as necessary. Uranium precipitate and calcium fluoride sludge would be removed by 

46 filtration and disposed of as low-level radioactive waste. Effluents meeting regulatory release 

47 levels for uranium and fluorine would be sent to the Liquid Effluent Treatment System 
 4-96 

1 Evaporator. A small volume of liquid evaporator concentrate would be periodically removed, 

2 analyzed for uranium content, and disposed of as low-level radioactive waste (AES, 2010a). 

3 

4 The proposed EREF would not be connected to a publicly operated treatment works (POTW). 

5 All domestic sanitary sewage would be treated onsite to comply with 10 CFR 20.2003 and 

6 collected in the cylinder storage pad stormwater retention basins for evaporation to the 

7 atmosphere (AES, 2010a). 

8 

9 Stormwater runoff during facility operations would be collected in a Site Stormwater Detention 

10 Basin that would allow the water to evaporate or infiltrate the ground surface (with allowance for 

11 overflow runoff to downgradient terrain). Because this basin would only receive runoff from 

12 paved surfaces (not including the Cylinder Storage Pads), building roofs, and landscaped areas, 

13 no uranic content would be expected. Stormwater runoff from the Cylinder Storage Pads would 

14 be collected in two lined Cylinder Storage Pads Stormwater Retention Basins and allowed to 

15 evaporate. Because these basins would not receive process-related effluents, the only potential 

16 sources of radiological contamination would be residual contamination on the exterior of a 

17 cylinder or the accidental release of UF6 from a leaking cylinder or handling accident. 

18 Therefore, no significant releases of uranic material to these basins would be expected (AES, 

19 2010a). Although all three basins would not receive process-related effluents and would not be 

20 expected to contain uranium or hazardous constituents from other sources, stormwater and 

21 sediment from all three basins would be sampled quarterly as a part of the site environmental 

22 measurement and monitoring program (as described in Chapter 6). 

23 

24 Depleted UF6 Waste Management

25 

26 The proposed EREF is expected to generate 1222 cylinders of depleted UF6 annually (AES, 

27 2010a). As discussed in Section 2.1.3 of this EIS, until a conversion facility is available, 

28 depleted UF6-filled Type 48Y cylinders would be temporarily stored on an outdoor Cylinder 

29 Storage Pad. Storage of depleted UF6 cylinders at the proposed EREF would occur for the 

30 duration of the facility’s 30-year operating lifetime and before final removal of depleted UF6 from 

31 the proposed EREF site (AES, 2010a). However, AES has stated that depleted UF6 cylinders 

32 would not be stored at the proposed EREF site beyond the facility’s licensed lifetime (AES, 

33 2010a). 

34 

35 The proposed EREF’s Full Tails Cylinder Storage Pads are currently designed to accommodate 

36 up to 33,638 depleted UF6 cylinders (AES, 2010a), which provide storage capacity for the 

37 expected lifetime generation of the facility in the event that a DOE conversion facility should be 

38 unavailable or delayed. 

39 

40 Temporary Depleted UF6 Storage Impacts

41 

42 Proper and active depleted UF6 cylinder management, which includes routine inspections and 

43 maintaining the anticorrosion layer on the cylinder surface, has been shown to limit exterior 

44 corrosion or mechanical damage necessary for safe storage (DNFSB, 1995a,b, 1999). DOE 

45 has stored depleted UF6 in Type 48Y or similar cylinders at the Paducah and Portsmouth 

46 Gaseous Diffusion Plants and the East Tennessee Technical Park in Oak Ridge, Tennessee, 

47 since the mid-1950s, and cylinder leaks due to corrosion led DOE to implement a cylinder 

48 management program (Biwer et al., 2001). Past evaluations and monitoring by the Defense 
 4-97 

1 Nuclear Facility Safety Board (DNFSB) of DOE’s cylinder maintenance program confirmed that 

2 DOE met all of the commitments in its cylinder maintenance implementation plan, particularly 

3 through the use of a systems engineering process to develop a workable and technically 

4 justifiable cylinder management program (DNFSB, 1999). AES intends to implement a similar 

5 cylinder management program at the proposed EREF (AES, 2010a), as a properly implemented 

6 cylinder maintenance program would assure the integrity of the depleted UF6 cylinders for 

7 temporary onsite storage of depleted UF6 on the Cylinder Storage Pads. 

8 

9 The principal impacts from temporary storage of depleted UF6 would be the radiological 

10 exposure from an increasing quantity of depleted UF6 temporarily stored in cylinders on the Full 

11 Tails Cylinder Storage Pad (up to the design capacity of 33,638 cylinders at the end of the 

12 facility’s operating lifetime) under normal conditions and the potential release (slow or rapid) of 

13 depleted UF6 from the depleted UF6 cylinders due to an off-normal event or accidents 

14 (operational, external, or natural hazard phenomena events). These radiation exposure 

15 pathways are analyzed in Section 4.2.10, and based on these results, the impacts from 

16 temporary storage of depleted UF6 would be SMALL. The annual impacts from temporary 

17 storage would continue until the depleted UF6 cylinders are removed from the proposed EREF 

18 site. 

19 

20 Offsite Disposal Impacts

21 

22 For the offsite disposal of the depleted UF6, AES has proposed that the Type 48Y cylinders 

23 would be transported to either of the DOE’s conversion facilities at Paducah, Kentucky, or 

24 Portsmouth, Ohio, for conversion to triuranium octaoxide (U3O8) (AES, 2010a). Following 

25 conversion, the U3O8 would be stored for potential future use or transported to a licensed 

26 disposal facility (DOE, 2004a,b). The transportation of the Type 48Y cylinders from the 

27 proposed EREF to either of the conversion facilities would have environmental impacts that are 

28 included in the transportation analysis presented in Section 4.2.9.2. 

29 

30 If the DOE conversion facility could not immediately process the depleted UF6 cylinders upon 

31 arrival, potential impacts would include radiological impacts proportional to the time of 

32 temporary storage at the conversion facility. DOE has previously assessed the impacts of 

33 depleted UF6 cylinder storage during the operation of a depleted UF6 conversion facility 

34 (DOE, 2004a,b), which bounds the impacts of temporary storage of EREF-originated depleted 

35 UF6 cylinders at the conversion facility site. At the Paducah and Portsmouth conversion 

36 facilities, the maximum collective dose to workers (i.e., workers at the cylinder yards) would be 

37 0.055 person-sieverts (5.5 person-rem) per year and 0.03 person-sievert (3 person-rem) per 

38 year, respectively considering the existing stored inventories of depleted UF6 (DOE, 2004a,b). 

39 There would be negligible exposure to noninvolved workers or the public due to their distance 

40 from the cylinder yards and because air emissions from the cylinder preparation and 

41 maintenance activities would be negligible (DOE, 2004a,b). 

42 

43 The Paducah conversion facility would operate for approximately 25 years to process the 

44 436,400 metric tons (481,000 tons) that were in storage prior to anticipated startup of the 

45 conversion facility in 2006 (DOE, 2004a). Similarly, the Portsmouth conversion facility would 

46 operate for 18 years to process 243,000 metric tons (268,000 tons) (DOE, 2004b). The 

47 projected lifetime production of depleted UF6 by the proposed EREF (321,235 metric tons 

48 [354,101 tons]) would represent approximately 74 percent and 132 percent of the initial 
 4-98 

1 Paducah and Portsmouth inventories, respectively. The proposed EREF would produce (and 

2 provide for conversion) approximately 7635 metric tons (8418 tons) of depleted UF6 per year at 

3 full production capacity (AES, 2010a), which represents approximately 47 percent of the annual 

4 conversion capacity of the Paducah facility (18,000 metric tons [20,000 tons]) and approximately 

5 62 percent of the annual conversion capacity of the Portsmouth facility (13,500 metric tons 

6 [15,000 tons]). The proposed EREF’s projected lifetime production of depleted UF6 inventory, if 

7 processed by either the Paducah or Portsmouth conversion facility, could extend the potential 

8 duration of conversion facility operation by approximately 18 years or 24 years, respectively. 

9 

10 With routine facility and equipment maintenance, and periodic equipment replacements or 

11 upgrades, DOE indicated that the Paducah and Portsmouth conversion facilities could be 

12 operated safely beyond their proposed operational lifetimes to process the depleted UF6 such 

13 as that originating at the proposed EREF (DOE, 2004a,b). In addition, DOE indicated the 

14 estimated impacts that would occur from prior conversion facility operations would remain the 

15 same when processing depleted UF6 such as the proposed EREF wastes (DOE, 2004a,b). The 

16 overall cumulative impacts from the operation of a DOE conversion facility would increase 

17 proportionately with the increased life of the facility (DOE, 2004a,b). 

18 

19 Additional conversion processing capacity could also be achieved through increased efficiency 

20 of the Paducah and Portsmouth conversion plants and the possibility of a commercial 

21 conversion plant being constructed. International Isotopes, Inc. submitted a license application 

22 to the NRC on December 31, 2009, to construct and operate a depleted UF6 conversion facility 

23 near Hobbs, New Mexico (the NRC staff is currently conducting environmental and safety 

24 reviews of the application) (NRC, 2010d). 

25 

26 To meet the increased demand for enriched uranium, as discussed in Section 1.3.1, three other 

27 uranium enrichment facilities are planned or under construction. These facilities would also 

28 generate depleted UF6, in addition to the currently operating gaseous diffusion enrichment plant 

29 at Paducah, that would also require conversion and disposal. Should all of the facilities become 

30 operational, extended storage times for the depleted UF6 cylinders at conversion facilities may 

31 be necessary and could result in the need for an additional conversion facility. 

32 

33 The above assumptions and data indicate that environmental impacts from the conversion of 

34 depleted UF6 from the proposed EREF at an offsite location such as Portsmouth or Paducah 

35 would be SMALL. 

36 

37 The impacts from transportation of U3O8 (from the conversion of depleted UF6) to potential 

38 disposal sites have been previously evaluated for the depleted UF6 stored at the Paducah and 

39 Portsmouth sites (DOE, 2004a,b). Transportation impacts relating to the shipment of EREF40 originated U3O8 from the DOE conversion facilities to a potential disposal site would be SMALL. 

41 

42 4.2.11.3 Mitigation Measures 

43 

44 Measures identified by AES to mitigate waste management impacts during preconstruction 

45 activities, construction, and facility operation include (AES, 2010a): 

46 

47 • develop a construction phase recycling program 

48 
 4-99 

1 • design system features to minimize the generation of solid waste, liquid waste, and gaseous 

2 effluent (gaseous effluent design features are described above under Public and 

3 Occupational Health) 

4 

5 • store waste in designated areas of the facility until an administrative limit is reached, then 

6 ship offsite to a licensed disposal facility; no disposal of waste onsite 

7 

8 • dispose of all radioactive and mixed wastes at offsite licensed facilities 

9 

10 • maintain a cylinder management program to monitor storage conditions on the Full Tails 

11 Cylinder Storage Pads, to monitor cylinder integrity by conducting routine inspections for 

12 breaches and to perform cylinder maintenance and repairs as needed 

13 

14 • store all tails cylinders filled with depleted UF6 on saddles of concrete, or other suitable 

15 material, that do not cause corrosion of the cylinders; place saddles on a concrete pad 

16 

17 • segregate the storage pad areas from the rest of the enrichment facility by barriers, such as 

18 vehicle guard rails 

19 

20 • double-stack depleted uranium tails cylinders on the storage pad, arrayed to permit easy 

21 visual inspection of all cylinders 

22 

23 • survey depleted uranium tails cylinders for external contamination (wipe test) prior to being 

24 placed on a Full Tails Cylinder Storage Pad or transported offsite 

25 

26 • fit depleted uranium tails cylinder valves with valve guards to protect the cylinder valves 

27 during transfer and storage 

28 

29 • make provisions to ensure that depleted uranium tails cylinders will not have defective 

30 valves (identified in NRC Bulletin 2003-03, “Potentially Defective 1-inch Valves for Uranium 

31 Hexafluoride Cylinders”) (NRC, 2003c) installed 

32 

33 • perform touch-up application of paint coating on depleted uranium tails cylinders if coating 

34 damage is discovered during inspection (UF6 cylinder manufacturing will include abrasive 

35 blasting and coating with anticorrosion primer/paint, as required by specification) 

36 

37 • allow only designated vehicles, operated by trained and qualified personnel, on the Full Tails 

38 Cylinder Storage Pads, Full Feed Cylinder Storage Pads, Full Product Cylinder Storage 

39 Pad, and the Empty Cylinder Storage Pad (refer to the Integrated Safety Analysis [ISA] 

40 Summary, Section 3.8, for controls associated with vehicle fires on or near the Cylinder 

41 Storage Pads) 

42 

43 • inspect depleted uranium tails cylinders for damage prior to placing a filled cylinder on a 

44 storage pad. Annually reinspect depleted uranium tails cylinders for damage or surface 

45 coating defects. These inspections will verify that: 

46  lifting points are free from distortion and cracking 

47  cylinder skirts and stiffener rings are free from distortion and cracking 

48  cylinder surfaces are free from bulges, dents, gouges, cracks, or significant corrosion 
 4-100 

1  cylinder valves are fitted with the correct protector and cap 

2  cylinders are inspected to confirm that the valve is straight and not distorted, two to six 

3 threads are visible, and the square head of the valve stem is undamaged 

4  cylinder plugs are undamaged and not leaking 

5 

6 • if inspection of a depleted uranium tails cylinder reveals significant deterioration or other 

7 conditions that may affect the safe use of the cylinder, transfer the contents of the affected 

8 cylinder to another cylinder in good condition and discard the defective cylinder; determine 

9 the root cause of any significant deterioration and, if necessary, make additional inspections 

10 of cylinders 

11 

12 • make available onsite proper documentation on the status of each depleted uranium tails 

13 cylinder, including content and inspection dates 

14 

15 • use the lined Cylinder Storage Pads Stormwater Retention Basins to capture stormwater 

16 runoff from the Full Tails Cylinder Storage Pads 

17 

18 • minimize power usage by efficient design of lighting systems, selection of high-efficiency 

19 motors, and use of proper insulation materials 

20 

21 • control process effluents by means of the following liquid and solid waste handling systems 

22 and techniques: 

23  follow careful application of basic principles for waste handling in all of the systems and 

24 processes 

25  collect different waste types in separate containers to minimize contamination of one 

26 waste type with another; carefully package materials that can cause airborne 

27 contamination; provide ventilation and filtration of the air in the area as necessary; 

28 confine liquid wastes to piping, tanks, and other containers; use curbing, pits, and sumps 

29 to collect and contain leaks and spills 

30  store hazardous wastes in designated areas in carefully labeled containers; also contain 

31 and store mixed wastes separately 

32  neutralize strong acids and caustics before they enter an effluent stream 

33  decontaminate and/or reuse radioactively contaminated wastes to reduce waste volume 

34 as far as possible 

35  reduce the volume of collected waste such as trash, compressible dry waste, scrap 

36 metals, and other candidate wastes at a centralized waste processing facility 

37  include administrative procedures and practices in waste management systems that 

38 provide for the collection, temporary storage, processing, and disposal of categorized 

39 solid waste in accordance with regulatory requirements 

40  design handling and treatment processes to limit wastes and effluent; perform sampling 

41 and monitoring to assure that plant administrative and regulatory limits will not be 

42 exceeded 

43  monitor gaseous effluent for HF and radioactive contamination before release 

44  sample and/or monitor liquid wastes in liquid waste treatment systems 

45  sample and/or monitor solid wastes prior to offsite treatment and disposal 

46  return process system samples to their source, where feasible, to minimize input to 

47 waste streams 

48 
 4-101 

1 • implement a spill control program for accidental oil spills; prepare a Spill Prevention Control 

2 and Countermeasure (SPCC) Plan prior to the start of operation of the facility or prior to the 

3 storage of oil on the proposed site in excess of de minimis quantities, which will contain the 

4 following information: 

5  identification of potential significant sources of spills and a prediction of the direction and 

6 quantity of flow that will likely result from a spill from each source 

7  identification of the use of containment or diversionary structures such as dikes, berms, 

8 culverts, booms, sumps, and diversion ponds, at the facility to control discharged oil 

9  procedures for inspection of potential sources of spills and spill containment/diversion 

10 structures 

11  assigned responsibilities for implementing the plan, inspections, and reporting 

12  as part of the SPCC Plan, other measures will include control of drainage of rain water 

13 from diked areas, containment of oil and diesel fuel in bulk storage tanks, aboveground 

14 tank integrity testing, and oil and diesel fuel transfer operational safeguards 

15 

16 • implement a nonhazardous materials waste recycling plan during operation; perform a 

17 waste assessment to identify waste reduction opportunities and to determine which 

18 materials will be recycled; contact brokers and haulers to find an end-market for the 

19 materials; perform employee training on the recycling program so that employees will know 

20 which materials are to be recycled; purchase and clearly label recycling bins and containers; 

21 periodically evaluate the recycling program (i.e., waste management expenses and savings, 

22 recycling and disposal quantities) and report the results to the employees 

23 

24 4.2.12 Socioeconomic Impacts 

25 

26 This section provides an analysis of the socioeconomic impacts associated with 

27 preconstruction, construction, and operation of the proposed EREF. Wage and salary spending 

28 and expenditures associated with materials, equipment, and supplies would produce income 

29 and employment and local and State tax revenue, while the migration of workers and their 

30 families into the area would affect housing availability, area community services such as 

31 schools, education, and law enforcement, and the availability and cost of public utilities such as 

32 electricity, water, sanitary services, and roads. The economic impacts of the proposed EREF 

33 project are evaluated for an 11-county region of influence (ROI) in Idaho – including Bannock, 

34 Bingham, Blaine, Bonneville, Butte, Caribou, Clark, Fremont, Jefferson, Madison, and Power 

35 Counties – which encompasses the area that is expected to be the primary source of labor for 

36 each phase of the proposed project and where workers employed during preconstruction, 

37 construction, and operation of the proposed EREF are expected to live and spend most of their 

38 salary. The 11-county ROI is also the area in which a significant portion of site purchase and 

39 non-payroll expenditures are expected to occur. The majority of the economic impacts of the 

40 proposed facility are expected to occur in two of these counties, Bingham and Bonneville. It is 

41 anticipated that a number of workers will move into the area during each phase of the proposed 

42 project, with the majority of the demographic and social impacts likely to occur in Bingham and 

43 Bonneville Counties. The impacts of the proposed EREF on population, housing, and 

44 community services are assessed for a two-county ROI, consisting of Bingham and Bonneville 

45 Counties. The impacts of preconstruction, construction, and facility operation would be SMALL. 

46 

47 
 4-102 

1 4.2.12.1 Methodology 

2 

3 This analysis of socioeconomic impacts includes impacts on employment, income, State tax 

4 revenues, population, housing, and community and social services. 

5 

6 Employment impacts are evaluated by estimating the level of direct and indirect employment 

7 associated with the proposed facility. Direct employment is created by preconstruction and 

8 construction activities and facility operations, while indirect employment is created in the 

9 11-county ROI to support the needs of the workers directly employed by the proposed EREF 

10 and jobs created to support site purchase and non-payroll expenditures. The number of direct 

11 jobs created in each stage is estimated based on anticipated labor inputs for various 

12 engineering and construction activities. Indirect employment is estimated using economic 

13 multipliers from the RIMS-II input-output model, developed by the U.S. Bureau for Economic 

14 Analysis (BEA, 2010), which accounts for inter-industry relationships within regions. 

15 

16 State income tax revenue impacts are estimated by applying State income tax rates to project17 related construction and operations earnings. State and local sales tax revenues are estimated 

18 by applying appropriate State and local sales tax rates to after-tax income generated by 

19 construction and operations employees, spent within the 11-county ROI. Impacts on population 

20 characteristics are evaluated by estimating the fraction of direct and indirect jobs that would be 

21 filled by in-migrating workers from outside the two-county ROI. The average family size and 

22 age profiles of in-migrating families are estimated using appropriate demographic assumptions 

23 based on U.S. Census Bureau statistics. Impacts on area housing resources are estimated by 

24 comparing rental and owner-occupied vacancy statistics with estimated population in-migration 

25 into the two-county ROI during the preconstruction, construction, and operations phases of the 

26 proposed project. 

27 

28 Impacts on community and social services are assessed by estimating the number of additional 

29 local community service employees that would be required to maintain existing levels of service 

30 of education, law enforcement, and fire services, given the number of in-migrating workers 

31 expected into the two-county ROI during the various phases of the proposed project. Although 

32 Bingham and Bonneville Counties are expected to be the primary sources of labor for the 

33 proposed EREF, some labor in-migration is expected during each phase of the proposed 

34 project. The number of in-migrating workers used in the analysis was assumed to be small, with 

35 the majority of craft skills available in the two-county ROI. Sixty-five percent of in-migrating 

36 workers were assumed to be accompanied by their families, which would consist of an 

37 additional adult and one school-age child (AES, 2010a). 

38 

39 There are large differences between the indirect (offsite) impact of the proposed EREF during 

40 the operations phase and during other phases of the proposed project. These differences are 

41 due to the relatively minor role in the economy of the 11-county ROI of suppliers of capital 

42 equipment, materials, and services provided to the proposed project during construction, 

43 compared to other phases of the proposed project, particularly operations (AES, 2010a). 

44 

45 As no detailed data on the preconstruction share of total construction employment or total 

46 construction expenditures were available for the proposed EREF, payroll expenditure data 

47 provided for the proposed Global Laser Enrichment, (GLE) Facility in North Carolina 

48 (GLE, 2009) were used as a basis for estimating the impacts of preconstruction and 
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1 construction activities for the proposed EREF. The proposed GLE Facility is another proposed 

2 nuclear fuel fabrication facility, with proposed preconstruction activities similar in nature, and on 

3 a similar scale, to those for the proposed EREF. Income data for Idaho Falls, Idaho, are 

4 estimated using data presented in the AES Environmental Report (AES, 2010a). Based on this 

5 information, preconstruction activities at the proposed EREF would contribute 5 percent of the 

6 impacts during the preconstruction period (2010–2011), and construction activities would 

7 contribute 95 percent (2012–2022). 

8 

9 Impacts for each phase of the proposed project are summarized in Table 4-28, and are based 

10 on data provided in the AES Environmental Report (AES, 2010a). These impacts are discussed 

11 in the following sections. The NRC has reviewed and verified the data and methodology. 

12 

13 4.2.12.2 Preconstruction and Construction 

14 

15 Preconstruction

16 

17 Preconstruction activities in 2010–2011 would create 108 direct jobs at the proposed EREF site 

18 (AES, 2010a). An additional 200 indirect jobs would be created in the 11-county ROI with the 

19 procurement of material and equipment and the spending of direct worker wages and salaries 

20 (Table 4-28). Preconstruction would produce $4.4 million in income in the 11-county ROI. 

21 Preconstruction would produce $0.1 million in direct State income taxes and $0.9 million in 

22 direct State sales taxes (AES, 2010a). Preconstruction activities would constitute less than 

23 1 percent of total two-county ROI employment (see Section 3.12.2); the economic impact of 

24 preconstruction of the proposed EREF would be SMALL. 

25 

26 Given the likelihood of a lack of local worker availability in the required occupational categories, 

27 EREF preconstruction would require some in-migration of workers and their families from 

28 outside the two-county ROI, with an estimated 49 persons in-migrating into the two-county ROI 

29 during the peak of preconstruction (AES, 2010a). Although in-migration may potentially impact 

30 local housing markets, the relatively small number of in-migrants and the availability of 

31 temporary accommodation (hotels, motels, and mobile home parks) would mean that the impact 

32 of preconstruction on the number of vacant rental housing units is not expected to be large, with 

33 21 additional rental units being expected to be occupied in the two-county ROI during 

34 preconstruction (AES, 2010a). These occupancy rates would represent less than 0.1 percent of 

35 the vacant rental units expected to be available in the two-county ROI during preconstruction; 

36 the impact of EREF preconstruction on housing would, therefore, be SMALL. 

37 

38 In addition to the potential impact on housing markets, in-migration would also affect local 

39 community and educational services employment to maintain existing levels of service in the 

40 two-county ROI. Accordingly, less than one additional police officer and less than one 

41 additional firefighter would be required during the preconstruction period (AES, 2010a). 

42 Assuming that a certain number of workers are accompanied by their families during 

43 preconstruction, 14 additional school-age children would be expected in the two-county ROI 

44 during the preconstruction period, meaning that one additional teacher would be required to 

45 maintain existing student–teacher ratios in the local school system (AES, 2010a). These 

46 staffing increases would represent less than 0.1 percent of community service employment in 

47 each employment category expected in the two-county ROI; the impact of EREF 

48 preconstruction on community and educational services employment would be SMALL. 
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Table 4-28 Socioeconomic Effects of the Proposed EREFa

Parameter Preconstruction Peak Facility 

Construction 

ConstructionOperations 

Overlap 

Period 

Operations

Employment (number of jobs) 

 Direct 108 590 275 550 

 Indirect 200 1097 1370 2739 

 Total 308 1687 1645 3289 

Income ($m 2008 $) 

 Direct 4.4 23.9 14.1 28.2 

 Indirect 7.5 41.2 32.1 64.2 

 Total 11.9 65.0 46.2 92.4 

Tax Revenues 

 Income Taxes ($m 2008 $) 0.1 0.7 0.7 1.3 

 Sales and use Taxes ($m 2008 $) 0.9 5.1 NAb NA 

 Property Taxes ($m 2008 $) NA NA 1.8 3.5 

Population (number of new 

residents) 

49 266 124 199 

Housing (number of units required) 21 112 52 87 

Public Service Employment 

(number of new employees) 

 

 Police officers <1 <1 <1 <1 

 Firefighters <1 <1 <1 <1 

 Teachers 1 4 2 3 

a

 Impacts are shown for preconstruction (2011), the peak year of construction (2012), the first year of start-up 

(2014) and the first year of operations (2022). Employment, income and tax impacts are estimated for the 

11-county ROI; population, housing and public service employment impacts are estimated for the two-county ROI. b

 NA = not applicable. 

Sources: AES, 2010a; direct preconstruction figures based on information in GLE, 2009.

1 

2 Facility Construction

3 

4 Construction activities in the peak year (2012) would create 590 direct jobs at the proposed 

5 EREF site (AES, 2010a). An additional 1097 indirect jobs would be created in the 11-county 

6 ROI with the procurement of material and equipment and the spending of direct worker wages 

7 and salaries (Table 4-28). Facility construction would produce $65.0 million in income in the 

8 11-county ROI in 2012. Construction would produce $0.7 million in direct State income taxes 

9 and $5.1 million in direct State sales taxes (AES, 2010a). Peak year construction activities 

10 would constitute less than 1 percent of total two-county ROI employment in 2012 
 4-105 

1 (see Section 3.12.2); the economic impact of constructing the proposed EREF would be 

2 SMALL. 

3 

4 Given the scale of construction activities and the likelihood of local worker availability in the 

5 required occupational categories, EREF construction would mean that some in-migration of 

6 workers and their families from outside the two-county ROI would be required, with 266 persons 

7 in-migrating into the two-county ROI during the peak year of construction (AES, 2010a). 

8 Although in-migration may potentially impact local housing markets, the relatively small number 

9 of in-migrants and the availability of temporary accommodation (hotels, motels, and mobile 

10 home parks) would mean that the impact of facility construction on the number of vacant rental 

11 housing units is not expected to be large, with 112 additional rental units expected to be 

12 occupied in the two-county ROI during construction (AES, 2010a). These occupancy rates 

13 would represent less than 0.1 percent of the vacant rental units expected to be available in the 

14 two-county ROI in 2012; the impact of EREF construction on housing would be SMALL. 

15 

16 In addition to the potential impact on housing markets, in-migration would also affect local 

17 community and educational services employment to maintain existing levels of service in the 

18 two-county ROI. Accordingly, less than one police officer and less than one firefighter would be 

19 required in the peak construction year, 2012 (AES, 2010a). During construction, 76 additional 

20 school-age children would be expected in the two-county ROI in 2012, meaning four additional 

21 teachers would be required to maintain existing student–teacher ratios in the local school 

22 system (AES, 2010a). These staffing increases would represent less than 0.1 percent of 

23 community service employment in each employment category expected in the two-county ROI 

24 in 2012; the impact of EREF construction on community and educational service employment 

25 would be SMALL. 

26 

27 4.2.12.3 Facility Operation 

28 

29 Facility Construction/Operations Startup Overlap Period

30 

31 Full production at the proposed EREF would not occur until 2022 when final construction would 

32 be completed. However, limited production of enriched uranium would begin with the opening 

33 of the first cascade in 2014 because of the modular nature of the proposed EREF. Enriched 

34 uranium production would increase and heavy construction would continue until 2018 when all 

35 major building structures would be completed and SBMs 1 and 2 would be fully operational. 

36 During this period, construction employment is expected to decline from levels reached in the 

37 peak construction year (2012) and startup employment would likely remain at the level 

38 established in 2014 until full facility operation commences in 2022 with the completion of the 

39 cascades in SBM 4 (AES, 2010a). 

40 

41 Startup activities in the first year (2014) would create 275 direct jobs at the proposed EREF 

42 (AES, 2010a). An additional 1370 indirect jobs would be created in the 11-county ROI with the 

43 procurement of material and equipment and the spending of direct worker wages and salaries 

44 (Table 4-28). Facility startup would produce $46.2 million in income in the 11-county ROI in 

45 2014 and $0.7 million in direct State income taxes (AES, 2010a). Property taxes payable to 

46 Bonneville County would amount to $1.8 million annually between 2015 and 2017. Startup 

47 activities would constitute less than 1 percent of total two-county ROI employment in 2014 
 4-106 

1 (see Section 3.12.2); the economic impact during the period of construction/operations overlap 

2 of the proposed EREF would be SMALL. 

3 

4 Given the scale of startup activities and the likelihood of local worker availability in the required 

5 occupational categories, startup of the proposed EREF would result in some in-migration of 

6 workers and their families from outside the two-county ROI, with 124 persons in-migrating into 

7 the two-county ROI during the first year of startup (AES, 2010a). Although in-migration may 

8 potentially impact local housing markets, there would be a relatively small number of 

9 in-migrants, and temporary accommodation (hotels, motels, and mobile home parks) would be 

10 available. Approximately 52 additional rental units would be expected to be occupied in the two11 county ROI during this period (AES, 2010a). These occupancy rates would represent less than 

12 0.1 percent of the vacant rental units expected to be available in the two-county ROI in 2014; 

13 therefore, the impact of the proposed EREF project on housing during the 

14 construction/operations overlap period would be SMALL. 

15 

16 In addition, in-migration would also affect local community and educational services 

17 employment to maintain existing levels of service in the two-county ROI. Accordingly, less than 

18 one police officer and less than one firefighter would be required in the first year, 2014, when 

19 operations begin. During startup, 35 additional school-age children would be expected in the 

20 two-county ROI in 2014, meaning two additional teachers would be required to maintain existing 

21 student–teacher ratios in the local school system (AES, 2010a). These staffing increases would 

22 represent less than 0.1 percent of community service employment in each employment category 

23 expected in the two-county ROI in 2012; therefore, the impact of the proposed EREF project on 

24 community and educational service employment during the construction/operations overlap 

25 period would be SMALL. 

26 

27 Full Operation

28 

29 Operations activities in the first full year (2022) would create 550 direct jobs at the proposed 

30 EREF site itself (AES, 2010a). An additional 2739 indirect jobs would be created in the 

31 11-county ROI with the procurement of material and equipment and the spending of direct 

32 worker wages and salaries (Table 4-28). Facility operations would produce $92.4 million in 

33 income in the 11-county ROI in 2022. Operations would produce $1.3 million in direct State 

34 income taxes and $3.5 million in direct property taxes (AES, 2010a). Property taxes would be 

35 payable to Bonneville County. Operations activities would constitute less than 1 percent of total 

36 two-county ROI employment in 2022 (see Section 3.12.2); the economic impact of operating the 

37 proposed EREF would be SMALL. 

38 

39 Given the scale of operations activities and the likelihood of local worker availability in the 

40 required occupational categories, EREF operation would result in some in-migration of workers 

41 and their families from outside the two-county ROI, with 199 persons in-migrating into the 

42 two-county ROI during the first year of operation (AES, 2010a). Although in-migration may 

43 potentially impact local housing markets, the relatively small number of in-migrants and the 

44 availability of temporary accommodation (hotels, motels, and mobile home parks) would mean 

45 that the impact of facility operation on the number of vacant owner-occupied housing units is not 

46 expected to be large, with 87 rental units expected to be occupied in the two-county ROI during 

47 operations (AES, 2010a). These occupancy rates would represent less than 0.1 percent of the 
 4-107 

1 vacant owner-occupied units expected to be available in the two-county ROI in 2022; the impact 

2 of EREF operations on housing would be SMALL. 

3 

4 In addition to the potential impact on housing markets, in-migration would also affect local 

5 community, and educational services employment to maintain existing levels of service in the 

6 two-county ROI. Accordingly, less than one police officer and less than one firefighter would be 

7 required in the first year of operations, 2022 (AES, 2010a). Fifty-seven additional school-age 

8 children would be expected in the two-county ROI in 2022, meaning an additional 

9 three teachers would be required to maintain existing student–teacher ratios in the local school 

10 system (AES, 2010a). These staffing increases would represent less than 0.1 percent of 

11 community service employment in each employment category expected in the two-county ROI 

12 in 2022; the impact of EREF operations on community and educational services employment 

13 would be SMALL. 

14 

15 4.2.12.4 Potential Effect on Property Values 

16 

17 Because it is not possible to accurately predict the response in regional property markets to the 

18 construction and operation of the proposed EREF, this section discusses how a facility such as 

19 the proposed EREF might affect property values based on findings from potentially hazardous 

20 facilities elsewhere in the United States. In general, potentially hazardous facilities have the 

21 potential to affect property values in two ways (Clark et al., 1997). First, negative perceptions 

22 associated with these facilities may reduce property values if potential buyers believe that any 

23 given facility poses a potential health risk. Negative perceptions may be based on individual 

24 sensitivities regarding risks associated with proximity to these facilities, and also on sensitivities 

25 at the community level that the presence of such a facility may adversely affect the prospects for 

26 local economic development. Even though potential buyers may not personally fear a 

27 potentially hazardous facility, they may offer less for a property in the vicinity of a facility if there 

28 is fear that the facility will reduce the rate of appreciation of housing in the area. Second, there 

29 may be a positive influence on property values associated with workplace accessibility for 

30 workers at the facility, with workers offering more for property close to the facility to minimize 

31 commuting times. Workers directly associated with the facility are likely to have considerably 

32 less fear of the technology and operations at the facility than the population as a whole. The 

33 importance of this influence on property values will vary with the size of the workforce involved. 

34 

35 While there is no evidence that uranium enrichment facilities impact local property values, a 

36 number of studies have assessed the impact of other potentially hazardous facilities on local 

37 property markets, including facilities such as nuclear power plants and spent nuclear fuel 

38 facilities (Clark and Nieves, 1994; Clark et al., 1997) and hazardous material and municipal 

39 waste incinerators and landfills (Kohlhase, 1991; Kiel and McClain, 1995). Many of these 

studies use a hedonic modeling approach14 40 to take into account the wide range of spatial 

41 influences on property values near noxious facilities, including crime (Thaler, 1978), fiscal 

42 factors (Stull and Stull, 1991), and noise and air quality (Nelson, 1979). The general conclusion 

43 from these studies is that while there may be a small negative effect on property in the 

 

14 Hedonic modeling of property markets is a form of multivariate regression analysis that incorporates 

numerous potential influences on housing values, including housing quality and location, distance to 

regional employment and retail centers, the quality of regional transportation networks, and the quality 

and fiscal characteristics of regional educational and public service providers. 
 4-108 

1 immediate vicinity of noxious facilities (i.e., less than 1 mile), this effect is often temporary, often 

2 coming with announcements related to specific project phases, such as site selection, the start 

3 of construction, the start of operations, etc. At larger distances and over the longer duration of 

4 the each project, no significant enduring negative property value effects have been found in 

5 these studies. Given these findings, it is unlikely that the proposed EREF would have a 

6 significant impact on local property values in the long term. 

7 

8 4.2.13 Environmental Justice Impacts 

9 

10 As described in Sections 4.2.1 through 4.2.12 above and in Section 4.2.15 below, the impacts of 

11 the proposed EREF would mostly be SMALL for the resource areas evaluated. For these 

12 resources areas, the impacts on all human populations would be SMALL. The NRC staff has 

13 concluded that potential impacts would be SMALL to MODERATE or MODERATE in a few 

14 cases, which could potentially affect environmental justice populations; and there would be 

15 LARGE, though intermittent, short-term impacts from fugitive dust during preconstruction. 

16 However, as there are no low-income or minority populations within the 4-mile area around the 

17 proposed facility, these impacts would not be disproportionately high and adverse for these 

18 population groups. 

19 

20 A brief description of impacts potentially affecting the general population in each resource area 

21 follows: 

22 

23 • Land Use. As described in Section 4.2.1, the proposed EREF would be located entirely on 

24 private land. The operation of a uranium enrichment facility is consistent with the county’s 

25 zoning. Current agricultural uses of the proposed EREF property would be curtailed, but 

26 similar activities would continue over large land areas surrounding the proposed EREF 

27 property and vicinity. For example, it is not anticipated that EREF preconstruction, 

28 construction, and operation would have any effect on the current land uses found on the 

29 surrounding Federal lands administered by the U.S. Bureau of Land Management. Land 

30 use impacts resulting from preconstruction, construction, and operation would be SMALL. 

31 

32 • Historic and Cultural Resources. As described in Section 4.2.2, there are 13 cultural 

33 resource sites in the immediate vicinity of the proposed EREF. Only one of these sites is 

34 eligible for listing on the National Register of Historic Places, the John Leopard Homestead 

35 (site MW004). This site is within the construction footprint of the proposed EREF. 

36 Preconstruction activities would destroy site MW004, and the resulting impacts would be 

37 LARGE, but were considered MODERATE because the appropriate mitigation involving 

38 professional excavation of, and data recovery at, site MW004 was implemented by AES and 

39 other homestead sites of this type exist in the region (WCRM, 2010; Idaho SHPO, 2010b; 

40 Gilbert, 2010). Other than for site MW004, the impacts of the proposed project on historic 

41 and cultural resources would be SMALL. 

42 

43 • Visual and Scenic Resources. As described in Section 4.2.3, preconstruction and 

44 construction equipment and the industrial character of the proposed EREF buildings would 

45 create significant contrast with the surrounding visual environment of the primarily 

46 agricultural and undeveloped rangeland. The proposed facility would be approximately 

47 2.4 kilometers (1.5 miles) from public viewing areas such as US 20 and the Hell’s Half Acre 

48 Wildlife Study Area (WSA), thus the impact on views would be SMALL to MODERATE. 
 4-109 

1 

2 • Air Quality. As described in Section 4.2.4, preconstruction and construction traffic and 

3 operation of construction equipment are projected to cause a temporary increase in the 

4 concentrations of particulate matter. These impacts would be SMALL. However, fugitive 

5 dust from land clearing and grading operations could result in large releases of particulate 

6 matter for temporary periods of time. Such impacts would be MODERATE to LARGE during 

7 certain preconstruction periods and activities. Facility operations could produce small 

8 gaseous releases associated with operation of the process that could contain uranium 

9 compounds and hydrogen fluoride. Small amounts of nonradioactive air emissions 

10 consisting of carbon monoxide (CO), nitrogen oxides (NOx), particulate matter (PM), volatile 

11 organic compounds (VOCs), and sulfur dioxide (SO2). Air quality impacts during operations 

12 would be SMALL. 

13 

14 • Geology and Soil. As described in Section 4.2.5, impacts would result primarily during 

15 preconstruction and construction from surface grading and excavation activities that loosen 

16 soil and increase the potential for erosion by wind and water. Soil compaction as a result of 

17 heavy vehicle traffic would also increase the potential for soil erosion by increasing surface 

18 runoff. Spills and inadvertent releases during all project phases could contaminate site 

19 soils. Implementation of mitigation measures identified by AES would ensure that these 

20 impacts would be SMALL. 

21 

22 • Water Resources. As described in Section 4.2.6, the water supply for the proposed facility 

23 would be from onsite wells, and water usage would be within the water appropriation for the 

24 proposed EREF property. The plant would also have no discharges to surface water or 

25 groundwater. The impact of the proposed EREF on water resources would be SMALL. 

26 

27 • Ecological Impacts. As described in Section 4.2.7, impacts would occur primarily as a result 

28 of preconstruction and construction activities, which would mean the removal of shrub 

29 vegetation and the relocation and displacement of wildlife presently on the proposed site as 

30 a result of noise, lighting, traffic, and human presence. Collisions with vehicles, construction 

31 equipment, and fences may cause some wildlife mortality. No rare or unique communities 

32 or habitats or Federally-listed threatened or endangered species have been found or are 

33 known to occur on the proposed site. The impact of the proposed EREF on ecological 

34 resources would be SMALL to MODERATE. 

35 

36 • Noise. As described in Section 4.2.8, increased noise associated with the operation of 

37 construction machinery is expected during preconstruction and construction, with noise 

38 levels of between 80 to 95 dBA at the highway entrances, access roads, and the Visitor 

39 Center. Construction noise would be temporary and would be reduced to about 51 to 

40 66 dBA at the nearest hiking trail point on the Hell’s Half Acre WSA. Impacts would be 

41 SMALL. Impacts during the operation of the proposed facility itself would also be SMALL. 

42 

43 • Transportation. As described in Section 4.2.9, the primary impact of preconstruction, 

44 construction and operation on transportation resources is expected to be increased traffic on 

45 nearby roads and highways due to truck shipments and site worker commuting. 

46 Transportation impacts during preconstruction and construction, and during facility operation 

47 would be SMALL to MODERATE on adjacent local roads (due to the potentially significant 

48 increase in average daily traffic), but regional impacts would be SMALL. 
 4-110 

1 

2 • Public and Occupational Health. As described in Section 4.2.10, the analysis of 

3 nonradiological impacts during preconstruction and construction includes estimated 

4 numbers of injuries and illnesses incurred by workers and an evaluation of impacts due to 

5 exposure to chemicals and other nonradiological substances, such as particulate matter 

6 (dust) and vehicle exhaust. All such potential nonradiological impacts would be SMALL. No 

7 radiological impacts are expected during preconstruction and initial facility construction, prior 

8 to radiological materials being brought onsite. Operation of the proposed EREF could 

9 release of small quantities of UF6 during normal operations. Total uranium released to the 

10 environment via airborne effluent discharges is anticipated to be less than 10 grams 

11 (6.84 μCi or 0.253 MBq) per year. No liquid effluent wastes are expected from facility 

12 operation. For a hypothetical member of the public at the proposed property boundary, the 

13 annual dose was estimated to be approximately 0.014 millisievert per year (1.4 millirem per 

14 year). Doses attributable to normal operation of the proposed EREF would be small 

15 compared to the normal background dose range of 2.0 to 3.0 millisievert (200 to 

16 300 millirem). Radiological impacts during operations would be SMALL. 

17 

18 • Waste Management. As described in Section 4.2.11, small amounts of hazardous waste 

19 and approximately 6116 cubic meters (8000 cubic yards) of nonhazardous and 

20 nonradioactive wastes would be generated during preconstruction and construction 

21 activities. During operations, approximately 75,369 kilograms (165,812 pounds) of solid 

22 nonradioactive waste would be generated annually, including approximately 5062 kilograms 

23 (11,136 pounds) of hazardous wastes. Approximately 146,500 kilograms (322,300 pounds) 

24 of radiological and mixed waste would be generated annually, of which approximately 

25 100 kilograms (220 pounds) would be mixed waste. All wastes would be transferred offsite 

26 to licensed waste facilities with adequate disposal capacity for the wastes from the proposed 

27 EREF. Overall, impacts would be SMALL. 

28 

29 • Socioeconomics. As described in Section 4.2.12, there would be increases in regional 

30 employment and income and tax revenue during preconstruction, construction, and 

31 operation. Although these impacts would be SMALL compared to the 11-county economic 

32 baseline, they are generally considered to be positive. Impacts on housing and local 

33 community services, which could be negative if significant in-migration were to occur, would 

34 also be SMALL. 

35 

36 • Accidents. As described in Section 4.2.15, six accident scenarios were evaluated in this EIS 

37 as a representative selection of the types of accidents that are possible at the proposed 

38 EREF. The representative accident scenarios selected vary in severity from high- to 

39 intermediate-consequence events and include accidents initiated by natural phenomena 

40 (earthquake), operator error, and equipment failure. The consequence of a criticality 

41 accident would be high (fatality) for a worker in close proximity. Worker health 

42 consequences are low to high from the other five accidents that involve the release of UF6. 

43 Radiological consequences to a maximally exposed individual (MEI) at the Controlled Area 

44 Boundary (proposed EREF property boundary) are low for all six accidents including the 

45 criticality accident. Uranium chemical exposure to the MEI is high for one accident and low 

46 for the remainder. For HF exposure to an MEI at the proposed property boundary, the 

47 consequence of three accidents is intermediate, with a low consequence estimated for the 

48 remainder. All accident scenarios predict consequences to the collective offsite public of 
 4-111 

1 less than one lifetime cancer fatality. Impacts from accidents would be SMALL to 

2 MODERATE. 

3 

4 4.2.14 Separation of Preconstruction and Construction Impacts 

5 

6 As described in Section 1.4.1, the NRC has granted an exemption for AES to conduct certain 

7 preconstruction activities, and previous sections have provided estimates (where applicable) of 

8 the fractions of such impacts that are attributable to preconstruction and construction. 

9 Table 4-29 summarizes those estimates and compares the environmental impacts of 

10 preconstruction (which is not part of the proposed action) and construction (which is part of the 

11 proposed action). 

12 

13 4.2.15 Accident Impacts 

14 

15 The operation of the proposed EREF would involve risks to workers, the public, and the 

16 environment from potential accidents. The regulations in 10 CFR Part 70, Subpart H, 

17 “Additional Requirements for Certain Licensees Authorized to Possess a Critical Mass of 

18 Special Nuclear Material,” require that each applicant or licensee evaluate, in an ISA, its 

19 compliance with certain performance requirements. The NRC staff has conducted a 

20 confirmatory analysis (NRC, 2010f) to independently evaluate the consequences of potential 

21 accidents identified in AES’s ISA (AES, 2010c). The accidents evaluated are a representative 

22 selection of the types of accidents that are possible at the proposed EREF. 

23 

24 The analytical methods used in this consequence assessment are based on NRC guidance for 

25 analysis of nuclear fuel-cycle facility accidents (NRC, 1990, 1991, 1998, 2003b). The NRC staff 

26 analyzed accidents that involve the release of UF6 liquid and/or gas from process systems, 

27 components, and containers. Such accidents, if unmitigated, pose a chemical and radiological 

28 risk to workers, the public, and the environment. A generic nuclear criticality accident was also 

29 analyzed. 

30 

31 4.2.15.1 Accidents Considered 

32 

33 AES’s ISA (AES, 2010c) and its Emergency Plan (AES, 2010d) describe potential accidents that 

34 could occur at the proposed EREF. Accident descriptions are provided for two groups of events 

35 according to the severity of the accident consequences: high-consequence events and 

36 intermediate-consequence events. 

37 

38 The NRC selected a range of possible accidents for detailed evaluation to assess the potential 

39 human health impacts associated with accidents. The representative accident scenarios 

40 selected vary in severity from high- to intermediate-consequence events and include accidents 

41 initiated by natural phenomena (earthquake), operator error, and equipment failure. The ISA 

42 considered all credible accidents at the proposed EREF. Evaluation of most accident 

43 sequences resulted in identification of design bases and design features that prevent criticality 

44 events or chemical releases to the environment. The accident scenarios evaluated were as 

45 follows: 

46 

47 • Generic Inadvertent Nuclear Criticality 

48 
 4-112 

Table 4-29 Summary and Comparison of Environmental Impacts from Preconstruction 

and Construction 

Resource Area Preconstruction Construction 

Land Use SMALL. Restrictions on land use 

would begin when preconstruction 

begins, when all grazing and 

agriculture would cease on the 

proposed EREF property. This 

constitutes 90 percent of the impacts 

to land use. The loss of the grazing 

and agricultural land is not considered 

a major impact due to the large 

amount of land locally available for 

agriculture and grazing. 

SMALL. Most impacts to land use 

(i.e., restricting land use) would have 

already occurred during preconstruction. 

Access restrictions would only increase 

during construction. Land use impacts 

from construction are expected to be a 

continuation of those from 

preconstruction. Only 10 percent of the 

land use impacts are expected during 

construction. 

Historic and 

Cultural Resources 

MODERATE. The greatest potential 

for impacts on historic and cultural 

resources would occur during initial 

ground-disturbing activities, and 

constitutes 90 percent of the impacts 

on these resources. Site MW004, 

located within the footprint of the 

proposed EREF, was found to be 

eligible for listing on the NRHP. It 

would not be possible to avoid this 

site during preconstruction. With 

proper mitigation, the impact on 

historical and cultural resources 

would be MODERATE. 

SMALL. The majority of impacts to 

historic and cultural resources in the 

proposed EREF site would have 

occurred during preconstruction, when 

most of the ground disturbances would 

occur. It is estimated that 10 percent of 

the impacts would occur during 

construction. 

Visual and Scenic 

Resources 

SMALL. Visual impacts could result 

from increased traffic entering the 

proposed site. Fugitive dust could 

also create visual impacts along 

US 20. Because preconstruction 

activities would not significantly alter 

the overall appearance of the area, 

impacts would be SMALL. Only 

20 percent of the impacts on visual 

and scenic resources are expected 

during preconstruction because most 

activities will occur at ground level. 

SMALL to MODERATE. Visual impacts 

would result from increased traffic 

entering the proposed site. Fugitive 

dust would also create visual impacts 

along US 20. Eighty percent of the 

impacts on visual and scenic resources 

would occur during construction 

because the tallest and most visible 

components of the proposed project 

(i.e., industrial buildings) would be 

constructed at this time. 

 

1 
 4-113 

Table 4-29 Summary and Comparison of Environmental Impacts from Preconstruction 

and Construction (Cont.) 

Resource Area Preconstruction Construction 

Air Quality SMALL to LARGE. Impacts on 

ambient air quality from 

preconstruction would be SMALL for 

all HAPs and all criteria pollutants 

except particulates, but would be 

MODERATE to LARGE for 

particulates during certain periods of 

preconstruction, despite application of 

appropriate mitigations. Collectively, 

preconstruction activities are 

expected to constitute as much as 

90 percent of the overall air quality 

impacts from preconstruction and 

construction. 

SMALL. Impacts on ambient air quality 

from construction would be SMALL for 

all HAPs and all criteria pollutants. 

Because construction activities are 

expected to occur on a relatively small 

disturbed land area and utilize a much 

reduced construction workforce, and 

with the major pollutant-emitting 

activities being completed during 

preconstruction, construction activities 

are expected to constitute 10 percent of 

the overall impacts from preconstruction 

and construction. 

Geology and Soils SMALL. The terrain change on the 

proposed site, from gently sloping to 

flat, would result in SMALL impacts 

on soils. Short-term impacts such as 

an increase in soil erosion and 

compaction of soils would be SMALL. 

The majority of soil-disturbing 

activities (e.g., blasting and mass rock 

excavation) would occur during the 

preconstruction period; therefore, it is 

estimated that about 95 percent of the 

impacts on geology and soils would 

be attributed to the preconstruction 

phase of development. 

SMALL. Because the majority of soildisturbing activities would have occurred 

during the preconstruction period, it is 

estimated that about 5 percent of the 

impacts on geology and soils would be 

attributed to the construction phase of 

development. 

Water Resources SMALL. The preconstruction period 

is estimated to occur during an 

8-month period within the first year of 

the overall construction period; 

therefore, it is estimated that about 

10 percent of the impacts on water 

resources would be attributed to the 

preconstruction phase of 

development. 

SMALL. During the 7 years of heavy 

construction, the annual maximum 

usage rate would be within the annual 

water right appropriation that has been 

transferred to the proposed EREF 

property for use as industrial water. As 

a result, impacts on the groundwater 

supply would be SMALL. About 

90 percent of the impacts on water 

resources would be attributed to the 

construction phase of development. 
 4-114 

Table 4-29 Summary and Comparison of Environmental Impacts from Preconstruction 

and Construction (Cont.) 

Resource Area Preconstruction Construction 

Ecological 

Resources 

MODERATE. Preconstruction would 

result in direct impacts due to habitat 

loss and wildlife mortality as well as 

indirect impacts primarily from fugitive 

dust and wildlife disturbance. 

Preconstruction activities on the 

proposed site would result in most 

(95 percent) of the habitat losses 

associated with development of the 

proposed EREF. The development of 

the proposed facility is expected to 

extend over an 84-month time period, 

with the preconstruction phase 

estimated to comprise 10 percent of 

that period. Because the greatest 

ecological impacts during facility 

development would be attributable to 

habitat loss and mortality associated 

with preconstruction activities, the 

estimated contribution from 

preconstruction would be 80 percent. 

SMALL. Impacts associated with 

construction of facility components 

would primarily include wildlife 

disturbance and fugitive dust. 

Approximately 5 percent of habitat loss 

would be attributable to the construction 

of facility components. Facility 

component construction would comprise 

90 percent of the 84-month construction 

period. Some impacts, such as wildlife 

disturbance due to noise and human 

presence, would occur throughout the 

long facility construction phase. The 

estimated contribution from facility 

construction to overall ecological 

impacts during the construction period 

would be 20 percent. 

Noise SMALL. Construction noise from the 

proposed EREF would be highest 

during construction of the highway 

entrances, access roads, and visitor 

center, and would range from 80 to 

95 dBA. Construction noise would be 

temporary and would be reduced to 

about 51 to 66 dBA at the nearest 

hiking trail point on the Hell’s Half 

Acre Wilderness Study Area. Noise 

resulting from highway interchange, 

proposed site access road, and visitor 

center construction may occur at 

offsite locations at levels above 

values suggested in Federal 

standards as acceptable, albeit for 

relatively short periods. 

Notwithstanding short-term noise 

impulse events such as blasting, 

adequate mitigation controls would 

ensure noise impacts during 

preconstruction would all be below 

recommended standards at the 

closest human receptor. Most of the 

major noise-producing activities would 

occur during preconstruction. 

SMALL. Construction noise emanating 

from activities within the industrial 

footprint is expected to be attenuated to 

acceptable levels at the proposed facility 

boundaries. Adequate mitigation 

controls would ensure noise impacts 

during facility construction would all be 

below recommended standards at the 

closest human receptor. 
 4-115 

Table 4-29 Summary and Comparison of Environmental Impacts from Preconstruction 

and Construction (Cont.) 

Resource Area Preconstruction Construction 

Transportation SMALL to MODERATE. The primary 

impact on transportation resources is 

expected to be increased traffic on 

nearby roads. Impacts from access 

road construction would be SMALL 

but temporary (i.e., occurring only 

during the period of access road 

construction). Approximately 

10 percent of estimated transportation 

impacts would be attributable to 

preconstruction activities. 

SMALL to MODERATE. Construction 

activities at the proposed EREF would 

result in a 55 percent increase in traffic 

volume over current levels (including the 

period when construction and operations 

overlap). Approximately 90 percent of 

estimated transportation impacts would 

be attributable to construction activities. 

Public and 

Occupational 

Health 

SMALL. No radiological impacts are 

expected during the preconstruction 

period. Approximately 10 percent of 

the total occupational injury and 

nonradiological impacts would occur 

from preconstruction activities. This 

value is based on AES’s estimate that 

preconstruction activities would be 

completed within the first 8 months of 

a total 84-month construction 

schedule. This 10 percent estimate is 

likely an upper bound, as fewer 

workers would be expected to be 

involved during preconstruction than 

during the main construction phase. 

SMALL. No radiological impacts are 

expected during the initial phase of 

facility construction. Some radiological 

impacts to construction workers would 

occur during the time period when 

construction and operations overlap. 

Approximately 90 percent of the total 

occupational injury and nonradiological 

impacts would occur from facility 

construction activities. 

Waste 

Management 

SMALL. Solid nonhazardous wastes 

generated during preconstruction 

would be very similar to wastes from 

other construction sites of industrial 

facilities. These wastes would be 

transported offsite to an approved 

local landfill with sufficient capacity. 

Approximately 10 percent of 

estimated waste impacts would be 

attributable to preconstruction 

activities. 

SMALL. Solid nonhazardous wastes 

generated during construction would be 

very similar to wastes from other 

construction sites of industrial facilities 

and would be transported offsite to an 

approved local landfill. The hazardous 

wastes generated in association with the 

construction of the proposed facility due 

to the maintenance of construction 

equipment and vehicles, painting, and 

cleaning would be packaged and 

shipped offsite to licensed facilities in 

accordance with Federal and State 

environmental and occupational 

regulations. Approximately 90 percent 

of estimated waste impacts would be 

attributable to construction activities. 

 
 4-116 

Table 4-29 Summary and Comparison of Environmental Impacts from Preconstruction 

and Construction (Cont.) 

Resource Area Preconstruction Construction 

Socioeconomics SMALL. Wage and salary spending 

and expenditures associated with 

materials, equipment, and supplies 

would produce income and 

employment and local and State tax 

revenue, while the migration of 

workers and their families into a 

community would affect housing 

availability, area community services 

such as healthcare, schools, and law 

enforcement, and the availability and 

cost of public utilities such as 

electricity, water, sanitary services, 

and roads. Preconstruction activities 

would produce total (direct and 

indirect) employment of 308 jobs and 

$11.9 million in income. 

Preconstruction activities would 

constitute less than 1 percent of total 

two-county ROI employment. 

Proposed EREF preconstruction 

activities (2010–2011) would 

contribute 5 percent of the impacts 

during preconstruction and 

construction. 

SMALL. Wage and salary spending and 

expenditures associated with materials, 

equipment, and supplies would produce 

income and employment and local and 

State tax revenue, while the migration of 

workers and their families into a 

community would affect housing 

availability, area community services, 

and the availability and cost of public 

utilities. Construction would create 

1687 jobs and $65.0 million in income 

the peak year. Peak year construction 

activities would constitute less than 

1 percent of total two-county ROI 

employment. Proposed EREF 

construction activities would contribute 

95 percent (2012–2022) of the impacts 

during preconstruction and construction. 

Environmental 

Justice 

SMALL. The environmental impacts 

associated with preconstruction of the 

proposed EREF would be mostly 

SMALL, and generally would be 

mitigated. For these resources 

areas, the impacts on all human 

populations would be SMALL. 

Potential impacts would be SMALL to 

MODERATE or MODERATE in a few 

cases, which could potentially affect 

environmental justice populations; 

and there would be LARGE, though 

intermittent, short-term impacts from 

fugitive dust during preconstruction. 

However, as there are no low-income 

or minority populations within the 

4-mile area around the proposed 

facility, these impacts would not be 

disproportionately high and adverse 

for these population groups. 

SMALL. For the same reasons 

discussed in the Preconstruction 

column, construction of the proposed 

EREF is not expected to result in 

disproportionately high or adverse 

impacts on minority or low-income 

populations. 

1 

2 
 4-117 

1 • Heater Controller Failure (Hydraulic Rupture of Vessel) in the Centrifuge Test Facility 

2 

3 • Natural Phenomena Hazard – Earthquake 

4 

5 • Sampling Manifold Release of UF6 to Room 

6 

7 • Large Facility Fire Propagating between Areas 

8 

9 • Sampling Cylinder Release 

10 

11 Due to its nature, inadvertent nuclear criticality is the only one of the accidents that does not 

12 involve a significant release of UF6. The accident analysis does not include an estimate of the 

13 probability of occurrence of accidents, which, in combination with consequences, would reflect 

14 the overall importance of accident types; rather, analyzed accidents are assumed to occur. 

15 

16 4.2.15.2 Accident Consequences 

17 

18 Accidents involving release of UF6 liquids or vapors were analyzed, in general, by identifying the 

19 quantity of a containerized material at risk inside the proposed facility, the amount of material 

20 released into a room as vapor or particulates under the accident scenario, the fraction of 

21 released material that is of respirable size, and the fraction of material exhausted to the 

22 atmosphere through an available pathway, typically a building ventilation system. The 

23 dispersion of released material in the atmosphere and transport to onsite locations were 

24 calculated using guidance provided in Regulatory Guide 1.111 (NRC, 1977). Dispersion and 

25 transport to offsite locations were then analyzed using the GENII computer model (PNNL, 2007) 

26 with conservative inputs for exposure parameters and atmospheric transport factors. These 

27 methods estimated direct exposures to members of the public from an airborne plume, as well 

28 as exposures over a year’s time from deposited uranium materials, to determine accident 

29 consequences to the public. Impacts on the public from a criticality accident were analyzed 

30 similarly, but for radioactive gases that would be released from a criticality event in a vessel 

31 inside the proposed facility, including fission products and radioiodine. 

32 

33 The performance requirements in 10 CFR Part 70, Subpart H, define acceptable levels of risk of 

34 accidents at nuclear fuel-cycle facilities, such as the proposed facility. The regulations in 

35 Subpart H require that the applicant reduce the risks of credible high-consequence and 

36 intermediate-consequence events, and assure that under normal and credible abnormal 

37 conditions, all nuclear processes are subcritical. Threshold consequence values that define the 

38 high- and intermediate-consequence events, except for criticality events, are described in 

39 Table 4-30 as taken from AES’s Safety Analysis Report (SAR) (AES, 2010b). 

40 

41 Receptors located at the Restricted Area Boundary (RAB) within the proposed site and at the 

42 Controlled Area Boundary (CAB) (property boundary) represent worst-case exposures to 

43 nonradiological workers at the proposed facility and members of the public, respectively. 

44 
 4-118 

Table 4-30 Definition of High- and Intermediate-Consequence Events 

Receptor Intermediate Consequencea High Consequence 

Worker – radiological >25 rem (0.25 Sv) >100 rem (1 Sv) 

Worker – chemical 

(10-minute exposure) 

>AEGL-2 for UF6

>AEGL-2 for HF 

(>19 mg U/m3

)

b

 

(>78 mg HF/m3

) = (95 ppm) 

>AEGL-3 for UF6

>AEGL-3 for HF 

(>147 mg U/m3

) 

(>139 mg HF/m3

) = (170 ppm)

Environment at the restricted 

area boundary 

>24-hour average release greater 

than 5000 times the values in 

Table 2 of Appendix B of 10 CFR 

Part 20 (=1.5  10-8 μCi/mL) 

NAb

Individual at the controlled area 

boundary – radiological 

>5 rem (0.05 Sv) >25 rem (0.25 Sv) 

Individual at the controlled area 

boundary – chemical (30-minute 

exposure) 

>4.06 mg soluble U intake

>AEGL-1 for HF 

(>2.4 mg U/m3

) 

(>0.8 mg HF/m3

) = (0.98 ppm) 

>21 mg soluble U intake 

>AEGL-2 for HF 

(>13 mg U/m3

) 

(>28 mg HF/m3

) = (34.23 ppm) a

 AEGL: Acute Exposure Guideline Levels are public and private sector derived consensus values intended to 

describe the risk to humans resulting from once-in-a-lifetime, or rare, exposure to airborne chemicals (EPA at 

http://www.epa.gov/oppt/aegl/). 

b U = uranium; NA = not applicable. 

1 

2 Table 4-31 presents the consequences from the hypothetical accidents. Consequences were 

3 evaluated against the above criteria. For the criticality accident, a worker within a few feet of the 

4 event would likely be killed. A maximally exposed individual at the CAB would receive a 

5 radiation dose of 5.7 millisieverts (0.57 rem) total effective dose equivalent, which represents a 

6 low consequence to an individual (<0.05 sievert [<5 rem]). The collective dose to the offsite 

7 population to the east-southeast, as determined using GENII (PNNL, 2007), is estimated to be 

8 4.51 person-sieverts (451 person-rem). This population dose would cause an estimated 

9 0.3 lifetime cancer fatalities, or less than one fatality. Thus, the risk of health effects to the 

10 offsite public from this accident would be MODERATE. 

11 

12 The consequences of the five accident scenarios involving a release of UF6 vary widely, as 

13 shown in Table 4-31. Worker consequences are intermediate (between 0.05 and 0.25 sievert 

14 [5 and 25 rem]) for the scenario involving a hydraulic rupture of a Centrifuge Test Facility (CTF) 

15 feed vessel and high for the scenario involving a sampling cylinder release (>0.25 Sv [25 rem]). 

16 

17 Consequences to the maximally exposed member of the public located at the CAB would be low 

18 for the hydraulic rupture of a feed vessel scenario and for the sampling manifold release 

19 scenario (<2.5 milligrams per cubic meter uranium and <0.8 milligrams per cubic meter HF). 

20 Consequences to this receptor are intermediate for the earthquake and facility-wide fire 

21 scenarios on the basis of HF exposure (between 0.8 and 28 milligrams per cubic meter), but low 

22 for uranium exposure (<2.4 milligrams per cubic meter). Consequences to this receptor are 

23 high for the sampling cylinder release on the basis of uranium exposure (>13 milligrams per 

24 cubic meter) and intermediate for HF exposure (between 0.8 and 28 milligrams per cubic 

25 meter). 
 4-119 

Table 4-31 Summary of Health Effects Resulting from Accidentsa

 Workerb Environment 

at RAB 

Individual at CAB, Collective Dose 

Accident U, mg/m3

(rem) 

HF, 

mg/m3 μCi/mL U, mg/m3

(rem) 

HF, 

mg/m3 Direction Personrem 

LCFs 

Inadvertent 

nuclear 

criticality 

(Highc) Not 

applicable 

 18.4d

(ratio >1) 

(0.57)e NA ESE 451 0.3 

Hydraulic 

rupture 

of a CTF 

feed vesself

2.03  104

(14.2) 

6.83  103 4.23  10-9 1.43 

(0.006) 

0.54 ESE 0.632 4  10-4

Earthquake 9.59 

(0.136) 

32.2 1.28  10-9 0.274 

(0.001) 

2.08 ESE 0.47 3  10-4

Facility-wide 

fire 

13 

(0.805) 

4.36 2.57  10-9 0.549 

(0.002) 

2.08 ESE 0.94 6  10-4

Sampling 

manifold 

release 

89 

(0.062) 

29.9 2.85  10-10 4.07  10-2

(<0.001) 

1.54  10-2 ESE 4.27  10-2 3  10-5

Sampling 

cylinder 

release 

1.74  105

(122) 

5.85  104 4.82  10-7 69.8 

(0.293) 

26.4 ESE 72 4  10-2

a

 A safety evaluation (NRC, 2010f) has been conducted as part of the facility licensing process to identify Items Relied On For 

Safety (IROFS) for which changes in facility design may be required. Health effect impact estimates are based on calculations 

assuming the current design prior to any IROFS determinations. These results will be used to identify which, if any, IROFS are to 

be incorporated into facility designs or procedures to reduce the risks to workers, the public, and the environment to acceptably low 

levels. 

b

 Worker exits after 5 minutes in all cases but the earthquake in which the exit is assumed to occur in 2.5 minutes. U = uranium. c

 High consequence could lead to a fatality. 

d

 Pursuant to 10 CFR 70.61(c)(3), this value is the sum of the fractions of individual fission product radionuclide concentrations 

over 5000 times the concentration limits that appear in 10 CFR Part 20, Appendix B, Table 2. e

 The dose to the individual at the CAB is the sum of internal and external doses from fission products released from the criticality. f

 Though the consequences of the rupture of a liquid-filled UF6 vessel would be high, redundant heater-controller trips would make 

this event highly unlikely to occur. 

1 

2 Total consequences to the public in terms of radiation dose to the population in the east3 southeast direction (toward Idaho Falls) and resultant total lifetime cancer fatalities are given 

4 under Collective Dose in Table 4-31. All the accident scenarios predict less than one lifetime 

5 cancer fatality in this population. 

6 

7 Of the accident scenarios analyzed by the NRC staff, the most significant accident 

8 consequences are those associated with the release of UF6 caused by rupturing an overfilled or 

9 overheated cylinder and a nuclear criticality. Facility design reduces the risk (likelihood) of the 

10 rupture event by using redundant heater controller trips. In addition, the proposed facility 

11 Emergency Plan (AES, 2010d) addresses this type of event and all other lower-risk, high- and 

12 intermediate-consequence events. The NRC staff concludes that through the combination of 

13 plant design, passive and active engineered controls (Items Relied on for Safety [IROFS]), 

14 
 4-120 

1 administrative controls, and management of these controls, accidents at the proposed facility 

2 pose an acceptably low risk to workers, the environment, and the public. 

3 

4 4.2.15.3 Mitigation Measures 

5 

6 NRC regulations and AES’s operating procedures for the proposed EREF are designed to 

7 ensure that the high and intermediate accident scenarios would be highly unlikely (10 CFR 

8 Part 70, Subpart H, and AES [2010f]). The NRC staff assesses the safety features and 

9 operating procedures required to reduce the risks from accidents. The combination of 

10 responses by IROFS that mitigate or prevent emergency conditions and the implementation of 

11 emergency procedures and protective actions in accordance with the proposed EREF 

12 Emergency Plan (AES, 2010d) would limit the consequences and reduce the likelihood of 

13 accidents that could otherwise extend beyond the proposed EREF site and property boundaries. 

14 The following mitigation measures have been identified by AES to reduce the risks posed by 

15 accidents at the proposed EREF (AES, 2010c). 

16 

17 Preventative and mitigative measures within the proposed facility relevant to a fire/explosion 

18 and UF6 release scenario would include: (1) fire alarm and detection systems, possibly including 

19 a fire suppression system; (2) fire barriers preventing propagation of fires into and out of areas 

20 holding quantities of uranium materials; (3) reliable protection features to prevent overheating of 

21 UF6 cylinders; and (4) explicit design bases to minimize the impacts of initiating events, such as 

22 those for a seismic event. Preventative measures to guard against a criticality accident include 

23 the use of safe-by-design components (AES, 2010c). 

24 

25 Mitigative measures relevant to radiological accidents would include: (1) radiation protection 

26 systems to alert workers and isolate systems when parameters exceed set limits; (2) physical 

27 separation of areas within the facility designed to prevent or reduce exposure; (3) controlled 

28 positive or negative air pressures within designated areas to control air flow; (4) carbon 

29 absorbers, HEPA filters, and automatic trips on ventilation systems to prevent releases outside 

30 of affected areas; and (5) limited building leakage paths to the outside environment through 

31 appropriate door and building design. These features are designed to contain UF6 vapors within 

32 specified building areas and attenuate any release to the environment. Preventative controls for 

33 a nuclear criticality accident would include maintaining a safe geometry of all vessels, 

34 containers, and equipment that contain fissile material and ensuring that the amount of such 

35 material in these vessels does not exceed set limits. Mitigative controls would include criticality 

36 monitoring and alarm systems and emergency response training (AES, 2010a). 

37 

38 4.2.16 Decontamination and Decommissioning Impacts 

39 

40 This section summarizes the potential environmental impacts of decontamination and 

41 decommissioning of the proposed EREF site through comparison with normal operational 

42 impacts. Decontamination and decommissioning would involve the removal and disposal of all 

43 operating equipment while leaving the structures and most support equipment decontaminated 

44 to free release levels in accordance with 10 CFR Part 20. 

45 

46 Decommissioning activities are generally described in Section 2.1.4.3 of this EIS based on the 

47 information provided by AES in the SAR (AES, 2010b). However, a complete description of 

48 actions taken to decommission the proposed EREF at the expiration of its NRC license period 
 4-121 

1 cannot be fully determined at this time. In accordance with 10 CFR 70.38, AES must prepare 

2 and submit a decommissioning plan to the NRC at least 12 months prior to the expiration of the 

3 NRC license for the proposed EREF. AES would submit a final decommissioning plan to the 

4 NRC prior to the start of decommissioning. This plan would be the subject of further NEPA 

5 review, as appropriate, at the time the decommissioning plan is submitted to the NRC. 

6 Decontamination and decommissioning activities would be conducted to comply with all 

7 applicable Federal and State regulations in effect at the time of these activities. 

8 

9 The decommissioning process is expected to occur over a 9-year period. The SBMs would be 

10 decommissioned in the first 8 years, and there would be one additional year for final site 

11 surveys and activities (AES, 2010b). SBM 1 is scheduled to be the first to operate and would be 

12 the first to undergo decontamination and decommissioning. The other SBMs would follow in 

13 turn. A single SBM is assumed by AES to take 4.5 years to decommission, with 3 years for 

14 decommissioning of the centrifuges and associated equipment and 1.5 years for 

15 decontamination of the structure (AES, 2010b). SBM 4 would be the last module to operate and 

16 to be decommissioned. The remaining plant systems and buildings would be decommissioned 

17 after final shutdown of SBM 4. 

18 

19 The decontamination and decommissioning would include: 

20 

21 • installation of decontamination facilities 

22 

23 • purging of process systems 

24 

25 • dismantling and removal of equipment 

26 

27 • decontamination and destruction of confidential and secret restricted data material 

28 

29 • sales of salvaged materials 

30 

31 • disposal of wastes 

32 

33 • completion of a final radiation survey 

34 

35 The primary environmental impacts of the decontamination and decommissioning of the 

36 proposed EREF site include changes in releases to the atmosphere and surrounding 

37 environment and disposal of industrial trash and decontaminated equipment. The types of 

38 impacts that may occur during decontamination and decommissioning would be similar to many 

39 of those that would occur during the initial construction of the proposed facility. Some impacts, 

40 such as water usage and the number of truck trips, could increase during the decontamination 

41 and disposal phase of the decommissioning but would be less than during the construction 

42 phase; thus they would be bounded by the impacts in Sections 4.2.4 through 4.2.9. 

43 

44 
 4-122 

1 4.2.16.1 Land Use 

2 

3 As discussed in Section 4.2.1, the proposed AES property is zoned for uses such as the 

4 proposed EREF. The potential for impacts on land use is greatest during preconstruction and 

5 construction of the proposed EREF. The decontamination and decommissioning of the 

6 proposed facility would not be expected to result in a change in land use from operation. 

7 The land use would remain restricted to industrial uses. Since decontamination and 

8 decommissioning is not expected to affect land use, the impacts would be SMALL. 

9 

10 4.2.16.2 Historic and Cultural Resources 

11 

12 Ground-disturbing activities have the greatest potential for impacting historic and cultural 

13 resources. Ground disturbance at the proposed EREF site affecting cultural resources would 

14 have occurred during preconstruction for the proposed EREF. Any area disturbed during 

15 decontamination and decommissioning would be expected to no longer have the potential for 

16 historic and cultural resources. Therefore, it is not expected that any historic and cultural 

17 resources would be affected by decontamination and decommissioning of the proposed EREF; 

18 therefore, the impact would be SMALL. 

19 

20 4.2.16.3 Visual and Scenic Resources 

21 

22 The decontamination and decommissioning of the proposed EREF would have little additional 

23 effect on visual and scenic resources. Many buildings and the perimeter lighting would remain 

24 in place as part of the decontamination and decommissioning. Thus, the overall visual and 

25 scenic landscape would not be altered drastically from operations. Therefore, the impacts on 

26 visual and scenic resources of decontamination and decommissioning would be SMALL to 

27 MODERATE. 

28 

29 4.2.16.4 Air Quality 

30 

31 Decontamination and decommissioning activities would result in air quality impacts similar to 

32 those resulting from preconstruction and construction, although to a lesser magnitude and for a 

33 substantially shorter duration. Primary sources of air impacts during decontamination and 

34 decommissioning would include the operation of various construction equipment, onsite fueling 

35 and maintenance of construction equipment, the use of explosives to remove foundations if 

36 necessary, material handling and stockpiling, commuting to the proposed site (by a workforce 

37 that is expected to be substantially smaller than the initial construction workforce), and offsite 

38 transfer of recyclable materials and equipment and wastes destined for offsite treatment and 

39 disposal facilities. The most significant sources of fugitive dust expected in preconstruction and 

40 construction, cut-and-fill operations and travel on unpaved onsite roads, would either not be 

41 operative during decontamination and decommissioning or would be undertaken at substantially 

42 reduced levels. Unique aspects of the decontamination and decommissioning plan, such as 

43 whether buried utilities and improvements are removed or abandoned in place, can be expected 

44 to have incremental impacts on associated air quality impacts. 

45 

46 The absence of a specific decontamination and decommissioning plan prevents a quantitative 

47 analysis of decontamination and decommissioning impacts on air quality. The NRC staff 

48 concludes that air impacts from preconstruction and construction would be bounding 
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1 (see Tables 4-1 through 4-3 in Section 4.2.4.1 of this EIS) and that air impacts from 

2 decontamination and decommissioning would be less. The NRC staff therefore concludes that 

3 air impacts from decontamination and decommissioning would be SMALL. 

4 

5 4.2.16.5 Geology and Soils 

6 

7 Impacts to geology and soils during the decontamination and decommissioning phase would 

8 result from short-term disturbances of land (e.g., clearing and grading) for equipment laydown 

9 and disassembly. Land disturbance could temporarily increase the potential for soil erosion at 

10 the proposed EREF site, resulting in impacts similar to (but less than) those described for the 

11 preconstruction/construction phase (see Section 4.2.5.1). Mitigation measures would be 

12 implemented to minimize soil erosion and to control fugitive dust. Thus, impacts to geology and 

13 soils due to decontamination and decommissioning activities would be SMALL. 

14 

15 4.2.16.6 Water Resources 

16 

17 The water supply for the decontamination and decommissioning of the proposed EREF would 

18 be obtained from one or more onsite wells already completed in the ESRP aquifer. No surface 

19 water sources would be used. During this phase, water would be consumed for potable and 

20 sanitary needs, and for building and equipment rinsing (decontamination). Other water uses 

21 would include dust control, compaction of fill, and watering of vegetation. None of this water 

22 would be returned to its original source. 

23 

24 Water use rates would vary during the 9-year decontamination and decommissioning period but 

25 would not exceed annual usage during normal operations, because less than half as many 

26 workers would be onsite during decontamination and decommissioning (AES, 2010a) and water 

27 usage would be within the capacity of the water right appropriation throughout this phase. 

28 Liquid effluent quantities from decontamination and decommissioning activities are expected to 

29 be higher than during normal operations (AES, 2009b). All liquid effluents, including the spent 

30 citric acid solution used for building and equipment rinsing, would be treated and discharged by 

31 evaporation to the atmosphere in the Liquid Effluent Treatment System Evaporator. Once the 

32 Liquid Effluent Collection and Treatment System is removed from service, temporary skid33 mounted systems would be used to process any remaining liquid wastes. No process effluents 

34 would be discharged to the stormwater retention/detention basins or into surface water 

35 (AES, 2009b). 

36 

37 Runoff from paved areas and building roofs would continue to be diverted to three stormwater 

38 detention/retention basins for evaporation during the decontamination and decommissioning 

39 phase. At the end of this phase, mud or soil in the bottom of these basins would be tested for 

40 contamination and disposed of accordingly. The basins and berms would then be leveled to 

41 restore the land to its natural contour. 

42 

43 The Liquid Effluent Treatment System Evaporator would remain in operation throughout most of 

44 the decontamination and decommissioning phase. Liquids used to clean and decontaminate 

45 buildings and equipment would be treated and discharged by evaporation to the atmosphere in 

46 the system evaporator. Once the decontamination process has concluded and all effluents 

47 have evaporated, sludge and soil in the bottom of the evaporator would be tested and disposed 
 4-124 

1 of in accordance with regulatory requirements and in such as way as to meet the standards for 

2 releasing the proposed site for unrestricted use, as defined in 10 CFR 20.1402. 

3 

4 Since the usage and discharge impacts to water resources during the decontamination and 

5 decommissioning phase would be similar to those during operations, the impacts to water 

6 resources would be SMALL. 

7 

8 4.2.16.7 Ecological Resources 

9 

10 Plant communities and wildlife that became established near the proposed facility during the 

11 operational period could be affected by decontamination and decommissioning activities. 

12 Although the structures of the proposed EREF would be left in place, vegetation would be 

13 removed from land areas disturbed during decontamination and decommissioning activities, 

14 such as regraded basin areas. During the decontamination and decommissioning period, 

15 wildlife in the vicinity of the proposed facility would be disturbed by noise associated with 

16 decommissioning activities, and many species would be displaced to adjacent habitats. Noise 

17 levels generated by decommissioning would likely be similar to those during preconstruction 

18 and initial facility construction. Wildlife use of the proposed site would increase following the 

19 termination of decommissioning activities. Ecological impacts from decontamination and 

20 decommissioning would be SMALL. 

21 

22 4.2.16.8 Noise 

23 

24 Noise sources and levels would be similar to noise during site preconstruction and construction, 

25 and peaking noise levels would be expected to occur for short durations, primarily during 

26 preconstruction. Although a detailed decontamination and decommissioning plan has not yet 

27 been developed, major noise sources can be expected to include: the operation of heavy-duty 

28 construction equipment; traffic noise resulting from the commuting decontamination and 

29 decommissioning workforce and delivery vehicles used to transport disassembled components 

30 and waste materials to offsite facilities for redeployment, recycling, or disposal; the potential use 

31 of explosives or impact hammers to break up some structures if necessary, such as 

32 foundations, roads, and pavements; excavations of buried utilities and components; and cut33 and-fill operations designed to return the proposed site to its original grades and contours in 

34 some areas. 

35 

36 Offsite noise impacts can be expected to be similar to those for preconstruction and 

37 construction (see Section 4.2.8.1). Noise associated with excavation and removal of buried 

38 utilities would not occur for those belowground components that are abandoned in place. 

39 Based on detailed information currently available, the NRC staff concludes that noise impacts 

40 from decommissioning would be less than those expected to occur in the preconstruction and 

41 construction phases and would therefore be SMALL. 

42 

43 4.2.16.9 Transportation 

44 

45 Traffic during the initial portion of the decontamination and decommissioning activities would be 

46 approximately the same as during the period when construction and facility operation overlap 

47 (AES, 2010a). Traffic after the cessation of facility operation would be less than the volume 

48 experienced during either construction or operation. Site roads, if properly maintained, would 
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1 be adequate to accommodate the additional traffic volume, and the increased traffic would have 

2 a SMALL to MODERATE impact on the current traffic on US 20. However, the number of heavy 

3 trucks would be substantial for brief periods of time as waste materials were removed; therefore, 

4 transportation impacts for construction would be bounding. 

5 

6 If the depleted UF6 has not been removed prior to the cessation of operations, it would be 

7 shipped offsite during the decommissioning phase. As shown in Table 2-2 in Section 2.1.4.2 of 

8 this EIS, the operation of the proposed EREF would generate up to 25,718 Type 48Y cylinders 

9 of depleted UF6 tails during its operational lifetime. Type 48Y cylinders would be shipped one 

10 cylinder per truck for disposal. Assuming that all of the material is shipped during the first 

11 8 years of decommissioning (the final radiation survey and decontamination would occur during 

12 the final year of decommissioning), approximately 4205 truckloads per year would be shipped 

13 from the proposed EREF. If the trucks are limited to weekday, nonholiday shipments, 

14 approximately 17 trucks per day would leave the proposed site for the depleted UF6 conversion 

15 facility. Section 4.2.9 presents the impacts of shipping depleted UF6 to the conversion facility, 

16 which would be SMALL. 

17 

18 4.2.16.10 Public and Occupational Health 

19 

20 Occupational Injuries and Illnesses

21 

22 Occupational injuries and illnesses would be expected to be incurred during decontamination 

23 and decommissioning of the proposed EREF. The staged decommissioning is expected to take 

24 9 years to complete. The nature of decontamination and decommissioning activities, which 

25 would involve dismantling some structures and equipment, would be similar to those for 

26 preconstruction and construction of the proposed facility, while the job classification used to 

27 estimate construction injuries in Section 4.2.12.1, North American Industry Classification 

28 System Code 237, “Other Heavy and Civil Engineering Construction,” should also apply to 

29 dismantlement. In addition, the expected 9-year duration for decontamination and 

30 decommissioning is similar to the expected 7-year heavy construction period, and impacts from 

31 occupational injuries and illnesses during decontamination and decommissioning would be 

32 similar to those during construction. Chemical exposures would be controlled to below levels of 

33 concern through removal of hazardous chemicals from process lines and equipment. Thus, 

34 public and occupational health impacts would be SMALL. 

35 

36 Radiological Impacts

37 

38 Exposures during decontamination and decommissioning would be bounded by the potential 

39 exposures during operation because standard quantities of uranium material (i.e., UF6 in 

40 Type 48Y cylinders) would be handled during the portion of the decontamination and 

41 decommissioning operations that purges the gaseous centrifuge cascades of UF6. Once this 

42 decontamination operation is completed, UF6 would be present only in residual amounts and 

43 handled significantly less than during operations. Because systems containing residual UF6

44 would be opened, decontaminated (with the removed radioactive material processed and 

45 packaged for disposal), and dismantled, an active environmental monitoring and dosimetry 

46 (external and internal) program would be conducted to maintain ALARA doses and doses to 

47 individual members of the public as required by 10 CFR Part 20. Therefore, the impacts to 

48 public and occupational health would be SMALL. 

49 
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1 4.2.16.11 Waste Management 

2 

3 The waste management and recycling programs used during operations would also apply to 

4 decontamination and decommissioning. Materials eligible for recycling would be sampled or 

5 surveyed to ensure that contaminant levels would be below release limits. Enrichment 

6 equipment would be removed, depleted UF6 would be transported to a conversion facility, 

7 buildings and other structures would be decontaminated, and debris would be shipped offsite for 

8 disposal. Radioactive material from decontamination and contaminated equipment would be 

9 packaged and shipped offsite to an appropriately licensed facility. Staging and laydown areas 

10 would be segregated and managed to prevent contamination of the environment and creation of 

11 additional wastes. Long-term storage and monitoring of wastes at the proposed EREF site 

12 would be avoided, as the generated wastes would not require delayed removal from the site. 

13 Disposal volumes of the various waste streams are anticipated to be similar to those for the 

14 NEF, including 7700 cubic meters (10,070 cubic yards) of low-level radioactive waste 

15 (AES, 2010a). Due to the availability of adequate disposal capacity for Class A low-level 

16 radioactive waste over the long term (GAO, 2004), the waste management impacts of 

17 decontamination and decommissioning would be SMALL. 

18 

19 4.2.16.12 Socioeconomics 

20 

21 Decontamination and decommissioning of the proposed EREF would provide continuing 

22 employment opportunities for some of the existing operations workforce and for other residents 

23 of the 11-county ROI. Additional specialized decommissioning workers would be required from 

24 outside the 11-county ROI. Although at a lower level than during operations, expenditures on 

25 salaries and materials would contribute to the area economy, and the State would continue to 

26 collect sales tax and income tax revenues. As was the case with the preconstruction, 

27 construction, and operations phases of the proposed project, the socioeconomic impact of 

28 decommissioning activities would be SMALL. 

29 

30 4.2.16.13 Environmental Justice 

31 

32 As described in Sections 4.2.16.1 through 4.2.16.12, the impacts of the proposed action during 

33 decontamination and decommissioning would be SMALL for all of the resource areas evaluated, 

34 and would not potentially affect environmental justice populations. Even where environmental 

35 impacts would be SMALL, the behaviors of some subpopulations may lead to disproportionate 

36 exposure through inhalation or ingestion (e.g., higher participation in outdoor recreation, home 

37 gardening, and subsistence fishing). However, because impacts on the general population 

38 would be SMALL, and because there are no Census block groups in which the low-income 

39 population either exceeds 50 percent of the total population and/or is more than 20 percentage 

40 points higher than the State or county percentage, decontamination and decommissioning of the 

41 proposed facility would not, therefore, produce any environmental justice concerns. 

42 

43 Overall, therefore, decontamination and decommissioning of the proposed EREF is not 

44 expected to result in disproportionately high or adverse impacts on minority or low-income 

45 populations. 

46 

47 
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1 4.2.16.14 Mitigation Measures 

2 

3 AES identified the measures listed below to mitigate impacts of decontamination and 

4 decommissioning activities (AES, 2010a). These measures should be considered preliminary 

5 because decontamination and decommissioning would occur more than 20 years in the future. 

6 

7 • Ecological resources: Mitigation measures would be taken to protect migratory birds during 

8 decommissioning, e.g., clearing or removal of habitat, such as sagebrush, including buffer 

9 zones, would be performed outside of the migratory bird breeding and nesting season; 

10 additional areas to be cleared would be surveyed for active nests during migratory bird 

11 breeding and nesting season; activities would be avoided in areas containing active nests of 

12 migratory birds; the FWS would be consulted to determine the appropriate actions regarding 

13 the taking of migratory birds, if needed. 

14 

15 • Noise: Mitigation of noise impacts from decommissioning would include sequencing noise16 producing activities to minimize the overall noise and vibration impacts. 

17 

18 • Public and occupational health: Mitigation measures during decontamination and 

19 decommissioning operations are similar to those for the operational period. The goal of the 

20 mitigation measures would be to reduce the spread of radioactive contamination which 

21 would then reduce the unnecessary exposure or overexposure. These mitigation measures 

22 would be implemented by adapting design concepts that would minimize/prevent the spread 

23 of contamination from room to room. In addition, the creation of unrestricted and restricted 

24 areas would possibly reduce the spread of contamination by limiting the numbers of 

25 personnel within the work area. In addition, the creation of design features such as 

26 providing curbing and other barriers around tanks and other components containing liquids 

27 in order to limit spills would possibly reduce the spread of contamination. 

28 

29 4.2.17 Greenhouse Gas Emissions Associated with the Proposed EREF 

30 

31 This section presents an assessment of the effect preconstruction, construction, operation, and 

32 decommissioning of the proposed EREF can be expected to have on carbon dioxide and other 

33 greenhouse gas emissions. 

34 

35 4.2.17.1 Greenhouse Gases 

36 

37 Greenhouse gases (GHGs) include those gases, such as carbon dioxide (CO2), water vapor, 

38 nitrous oxide (N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and 

39 sulfur hexafluoride (SF6), that are transparent to solar (short-wave) radiation but opaque to long40 wave (infrared) radiation from the earth’s surface. The net effect over time is a trapping of 

41 absorbed radiation and a tendency to warm the planet’s surface and the boundary layer of the 

42 earth’s atmosphere, which constitute the “greenhouse effect” (IPCC, 2007). Some direct GHGs 

15 43 (CO2, CH4, and N2O) are both naturally occurring and the product of industrial activities, while 

44 others such as the hydrofluorocarbons are man-made and are present in the atmosphere 

45 exclusively due to human activities. Each GHG has a different radiative forcing potential 

 

15 Direct GHGs are those gases that can directly affect global warming once they are released into the 

atmosphere. 
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1 (the ability to affect a change in climatic conditions in the troposphere, expressed as the amount 

2 of thermal energy [in watts] trapped by the gas per square meter of the earth’s surface) 

3 (IPCC, 2007). The radiative efficiency of a GHG is directly related to its concentration in the 

4 atmosphere. 

5 

6 As a way to compare the radiative forcing potentials of various GHGs without directly calculating 

7 changes in their atmospheric concentrations, an index known as the Global Warming Potential 

8 (GWP) (IPCC, 2007) has been established with CO2, the most abundant of GHGs released to 

the atmosphere (after water vapor),16 9 established as the reference point. GWPs are calculated 

10 as the ratio of the radiative forcing that would result from the emission of 1 kilogram 

11 (2.2 pounds) of a GHG to that which would result from the emission of 1 kilogram (2.2 pounds) 

12 of CO2 over a fixed period of time. GWPs represent the combined effect of the amount of time 

13 each GHG remains in the atmosphere and its ability to absorb outgoing thermal infrared 

14 radiation. As the reference point in this index, CO2 has a GWP of 1. On the basis of a 100-year 

15 time horizon, GWPs for other key GHGs are as follows: 21 for CH4, 310 for N2O, 11,700 for 

16 HFC-23, and 23,900 for SF6 (IPCC, 2007). 

17 

Indirect GHGs, carbon monoxide (CO), nitrogen oxides (NOx),17 18 nonmethane volatile organic 

19 compounds (NMVOCs), and sulfur dioxide (SO2), indirectly affect terrestrial solar radiation 

20 absorption by influencing the formation and destruction of tropospheric and stratospheric ozone 

21 or, in the case of SO2, by affecting the absorptive characteristics of the atmosphere. 

22 

23 4.2.17.2 Greenhouse Gas Emissions and Sinks in the United States 

24 

25 The EPA is responsible for preparation and maintenance of the official U.S. Inventory of 

Greenhouse Gas Emissions and Sinks18 26 to comply with existing commitments under the United 

Nations Framework Convention on Climate Change (UNFCCC). GHG emissions19 27 are reported 

28 in sectors, using the GWPs established in the Second Assessment Report of the 

Intergovernmental Panel on Climate Change (IPCC).20 29 Preconstruction, construction, operation, 

30 and decommissioning of the proposed EREF would result in the release of GHGs as a result of 

31 the same human activities that were identified by EPA as the sources of GHGs in the 

 

16 Water vapor is the most abundant and most dominant greenhouse gas in the atmosphere. However, it 

is neither long-lived nor well mixed in the atmosphere, varying spatially from 0 to 2 percent. 

17 NOx represents all thermodynamically stable oxides of nitrogen, excluding nitrous oxide (N2O). 

18 GHG sinks are those activities or processes that can remove GHGs from the atmosphere. 

19 In keeping with the GWP convention that names CO2 as the reference gas, assigning it a GWP of 1, 

GWPs of other direct GHGs are expressed as equivalents (Eq.) of CO2, expressed in teragrams (Tg) 

of CO2 equivalent (Tg CO2 Eq.). One teragram is equal to 1012 grams, or one million metric tons 

(1.12 million tons). 

20 IPCC assessment reports are a compilation of separate reports of the various working groups that are 

established by the Panel. IGCC periodically updates assessment reports to incorporate newly 

established data, including revisions to GWPs and radiative forcing potentials of GHGs. The latest is 

the Fourth Assessment Report, published in 2007. Revised GWPs are contained in the report of 

Working Group I (IPCC, 2007). However, to provide for the analysis of trends of GHG emissions and 

sinks over time, nations responsible for GHG inventories continue to use the GHG GWPs established 

in the Second Assessment Report published in 1996. 
 4-129 

1 U.S. Inventory. Results of the most recent report on the U.S. Inventory of GHG Emissions and 

2 Sinks (EPA, 2009b) for direct GHGs that are most relevant to the proposed EREF include: 

3 

4 • The primary GHG emitted by human activities in the United States was CO2, representing 

5 approximately 85.4 percent of the total GHG emissions. 

6 

7 • In 2007, total U.S. GHG emissions were 7150.1 Tg CO2 Eq., an increase of 17 percent from 

8 1990. 

9 

10 • Overall emissions of GHGs rose from 2006 to 2007 by 1.4 percent (9 Tg CO2 Eq.). 

11 

12 • CO2 emissions for 2007 were 6103.4 Tg CO2 Eq., 5735.8 of which was the result of 

13 combustion of fossil fuel primarily related to electricity generation (2397.2), transportation 

14 (1887.4), industrial applications (845.4), residential heating (340.6), and commercial 

15 applications (214.4). 

16 

17 • Sixty percent of the CO2 emissions related to transportation were the result of consumption 

18 of gasoline in privately owned vehicles; the remainder was from combustion of fuels in 

19 diesel trucks and aircraft. 

20 

21 • Emissions of methane in 2007 as a result of combustion of fossil fuels in mobile sources 

22 were 2.3 Tg CO2 Eq. 

23 

24 • Emissions of nitrous oxide in 2007 as a result of combustion of fossil fuels in mobile sources 

25 were 30.1 Tg CO2 Eq. 

26 

27 • Emissions of HFCs (released from equipment) in 2007 were 108.3 Tg CO2 Eq. 

28 

• Emissions of SF6 in 2007 as a result of electrical transmission and distribution21 29 were 

30 12.7 Tg CO2 Eq. 

31 

32 • The primary GHG sinks functional in 2007 included carbon sequestration in forests, trees in 

33 urban areas, agricultural soils, and landfilled yard trimmings and food scraps, all of which, in 

34 aggregate, offset 14.9 percent of the total GHG emissions in 2007. 

35 

36 • The most significant emissions of indirect GHGs in 2007 included: 

37 

38  14,250 Tg CO2 Eq. of NOx primarily from mobile fossil fuel combustion (7831), stationary 

39 fuel combustion (5445), and industrial processes (520). 

40  63,875 Tg CO2 Eq. of CO primarily from mobile fossil fuel combustion (54,678), 

41 stationary fossil fuel combustion (4792), and industrial processes (1743). 

42  13,747 Tg CO2 Eq. of NMVOCs primarily from mobile fossil fuel combustion (5672), 

43 solvent use (3855), industrial processes (1878), and stationary fossil fuel combustion 

44 (1470). 

 

21 SF6 is a gas at standard conditions and is used as a dielectric medium in high-voltage electrical 

equipment. 
 4-130 

1  11,725 Tg CO2 Eq. of SO2 primarily from stationary fossil fuel combustion (10,211), 

2 industrial processes (839), and mobile fossil fuel combustion (442). 

3 

4 As noted above, consumption of fossil fuels for electricity generation represents the single 

5 greatest source of CO2 emissions in 2007 (5735.8 Tg CO2 Eq.). The CO2 equivalents 

6 represented in the electricity that was delivered to end users in four sectors in 2007 include: 

7 transportation (1892.2), industrial (1553.4), residential (1198.0), and commercial (1041.4). The 

8 total gross GHG emissions in the United States from all sectors in 2007 were 7150 Tg CO2 Eq. 

9 Net emissions (including all emissions and sinks) were 6087.5 Tg CO2 Eq. 

10 

11 4.2.17.3 Greenhouse Gas Emissions and Sinks in Idaho 

12 

13 A review of statewide emissions of GHGs can provide an understanding of the impact 

14 anticipated GHG emissions from the proposed EREF would have in a regional context. Among 

15 States, Idaho ranks 47th with respect to emissions of GHGs and 39th in population (based on 

16 2003 data) (NextGenerationEarth, 2009). However, Idaho’s emissions of GHGs increased by 

17 31 percent over the period 1990 to 2005 while GHG emissions on a national level increased by 

18 only 16 percent (IDEQ, 2009). The Idaho Department of Environmental Quality, in collaboration 

with the Center for Climate Strategies (CCS),22 19 published a report in the spring of 2008 on 

20 Idaho’s Greenhouse Gas Inventory and Reference Case projections for the period 1990–2020 

21 (CCS, 2008). The relevant data from that report appear in Table 4-32. Table 4-33 provides the 

22 most recent comparison of GHG inventories by sector in Idaho vs. the United States for 

23 calendar year 2000. 

24 

25 4.2.17.4 Projected Impacts from Preconstruction, Construction, Operation, and 

26 Decommissioning of the Proposed EREF on Carbon Dioxide and Other 

27 Greenhouse Gases 

28 

29 Preconstruction, construction, operation, and decommissioning of the proposed EREF can be 

30 expected to result in emissions of CO2 and other GHGs through various mechanisms, primarily 

31 from combustion of fossil fuels in both mobile and stationary sources. Individual contributions of 

32 preconstruction, construction, operation, and decommissioning are discussed below. 

33 Transportation volumes used in the following sections were established in Section 4.2.10 and 

34 are applied here without modification. 

35 

36 Estimated GHG Emissions during Preconstruction and Construction

37 

38 During preconstruction and construction, fossil fuels would be consumed onsite to support 

39 construction vehicles and equipment, as a result of commuting to and from the proposed site by 

40 the construction workforce and by delivery vehicles bringing materials and equipment to the 

41 proposed site and removing construction-related wastes from the proposed site to area landfills 

42 and treatment/disposal facilities. 

43 

 

22 The Center for Climate Strategies is a public-purpose, nonprofit, nonpartisan 501(c)(3) partnership 

organization established in 2004 to assist in climate policy development at the Federal and State 

levels. 
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Table 4-32 Idaho Historical and Reference Case GHG Emissions, 

by Sectora

Carbon Dioxide Equivalents 

(million metric tons) 

Sector 1990 2000 2005 2010 2020 

Energy 16.6 22.2 22.1 23.4 26.8 

 Electricity production 0.0 0.1 0.6 0.6 0.9 

 Coal 0.00 0.00 0.00 0.00 0.00 

 Natural gas 0.00 0.09 0.62 0.64 0.92 

 Oil 0.00 0.00 0.00 0.00 0.00 

 Net imported electricity 3.9 4.8 4.7 4.6 5.5 

Electricity consumption based 3.9 4.9 5.3 5.2 6.4 

Residential/commercial/industrial 

(RCI) fuel use 5.1 6.8 6.1 6.7 7.7 

 Coal 0.96 1.29 0.96 1.01 1.00 

 Natural gas 2.17 3.47 3.09 3.42 4.05 

 Wood (CH4 and N2O) 0.05 0.06 0.05 0.06 0.06 

Transportation 7.3 10.1 10.2 11.0 12.2 

 Motor gasoline 5.25 7.13 6.98 7.25 7.67 

 Diesel 1.47 2.48 2.79 3.29 4.01 

 Natural gas, LPG, other 0.07 0.07 0.07 0.07 0.09 

 Jet fuel and aviation gasoline 0.46 0.36 0.35 0.37 0.38 

Fossil fuel industry 0.3 0.4 0.4 0.5 0.6 

 Natural gas industry 0.32 0.45 0.42 0.46 0.55 

 Oil industry 0.00 0.00 0.00 0.00 0.00 

 Coal mining (methane) 0.00 0.00 0.00 0.00 0.00 

Industrial processes 0.4 0.8 1.1 1.3 1.9 

 Cement manufacture (CO2) 0.06 0.06 0.13 0.14 0.16 

 Lime manufacture (CO2) 0.03 0.03 0.06 0.07 0.08 

 Limestone & dolomite use (CO2) 0.00 0.00 0.01 0.01 0.01 

 Soda Ash (CO2) 0.01 0.01 0.01 0.01 0.01 

 ODS substitutes (HFC, PFC, and SF6) 0.08 0.21 0.13 0.09 0.05 

 Semiconductor manufacturing (HFC, 

 PFC, and SF6) 0.08 0.21 0.13 0.09 0.05 

 Electric power T&D (SF6) 0.19 0.11 0.09 0.07 0.04 

 
 4-132 

Table 4-32 Idaho Historical and Reference Case GHG Emissions, 

by Sectora (Cont.) 

Carbon Dioxide Equivalents 

(million metric tons) 

Sector 1990 2000 2005 2010 2020 

Waste management 1.0 1.2 1.4 1.5 1.8 

 Solid waste management 0.85 1.09 1.19 1.31 1.59 

 Wastewater management 0.13 0.16 0.17 0.18 0.21 

Agriculture 6.8 9.0 9.1 9.9 10.0 

 Enteric fermentation 2.26 2.81 3.19 3.52 3.52 

 Manure management 0.70 1.50 1.97 2.33 2.33 

 Soils and residue burning 3.88 4.66 3.97 4.04 4.15 

Forestry and land use 3.6 3.6 3.6 3.6 3.6 

Total gross emissions 28.4 36.8 37.2 39.6 44.1 

Increase relative to 1990 30% 31% 40% 56% 

Agriculture soils 1.2 1.2 1.2 1.2 1.2 

Net emissions (including sinks) 27.2 35.6 36.0 38.4 42.9 a Totals may not equal exact sum of subtotals shown in this table due to independent 

rounding. LPG = liquefied petroleum gas; ODS = ozone-depleting substance; T&D = 

transmission and distribution; SF6 = sulfur hexafluoride. 

Source: CCS, 2008.

1 

2 AES (2010a) has estimated that over the 7-year period of preconstruction and heavy 

3 construction when the most construction activity would take place (50 weeks per year, 250 days 

4 per year), gasoline and diesel fuel would be consumed at rates of 1325 liters (350 gallons) per 

5 week and 37,854 liters (10,000 gallons) per week, respectively (assumed to be an average over 

6 each year of the 7-year preconstruction and heavy construction period). Total amounts of fuels 

7 consumed throughout the expected 350 weeks of the preconstruction and heavy construction 

8 period were then estimated to be 463,713 liters (122,500 gallons) of gasoline and 

9 13,248,941 liters (3,500,000 gallons) of diesel (AES, 2010a). Following the IPCC guidelines for 

calculating emission inventories,23 10 gasoline combustion is expected to occur at 99 percent 

11 efficiency, each gallon releasing 8.8 kilograms (19.4 pounds) of CO2. Likewise, diesel fuel 

12 burned at the same combustion efficiency would release 10.0 kilograms (22.2 pounds) of CO2

13 per gallon. The resulting CO2 emissions from onsite consumption of fossil fuels are shown in 

14 Table 4-34. 

15 

 

23 IPCC guidelines for emission calculations can be found at the following EPA Web sites: 

http://www.epa.gov/OMS/climate/420f05001.htm and http://www.epa.gov/otaq/climate/index.htm. 

Consumption of one gallon of gasoline will result in the release of 8.8 kilograms (19.4 pounds) of CO2; 

one gallon of diesel fuel will yield 10.4 kilograms (22.2 pounds) of CO2 (EPA, 2005b). 
 4-133 

Table 4-33 Comparison of Idaho vs. U.S. GHG Emissions by Sectora

Sector % of State Total GHG 

Emissions 

% of U.S. GHG 

Emissions 

Transportation 27 26 

Agriculture 24 7 

Electricity consumption 13 32 

Industrial fuel use 11 14 

Forestry 10 NAb

Residential/commercial fuel use 7.8 9 

Waste 3.4 4 

Industrial processes 2.1 5 

Fossil fuel industry (CH4) 1.2 3 a

 All data, calendar year 2000. 

b

 At a national level, forests act as a net GHG sink (i.e., absorbing more GHG than they 

emit) and thus are not displayed as a national GHG emission source. 

Sources: CCS, 2008; EPA, 2009b. 

1 

2 During each of the 3 peak years of heavy construction, an estimated 590 workers would 

3 commute to and from the proposed site an average daily trip distance of 80.5 kilometers 

4 (50 miles) for 250 days each year. Over the 3-year peak construction period, workforce 

5 commuting would amount to 35,606,736 kilometers (22,125,000 miles). To calculate the 

6 resulting CO2 emissions associated with workforce commuting, it is assumed that 80 percent of 

7 the vehicles used will be gasoline-fueled with an average mileage of 20 miles per gallon (mpg) 

8 (accounting for 472 daily round trips) and 20 percent of the commuting vehicles will be diesel9 fueled with an average mileage of 15 mpg (118 daily round trips) and that no credit is extended 

10 for busing or carpooling. During each of the 3 peak years, delivery trucks (presumed to be 

11 diesel-fueled long-haul semi-trailer trucks averaging 10 mpg) would make 31 delivery trips per 

12 day (at an average round trip distance of 80.5 kilometers [50 miles]) to transport materials and 

13 equipment and remove wastes, making for 7720 delivery and waste trips for each of the 3 peak 

14 activity years, and traveling a total of 1,870,862 kilometers (1,162,500 miles) over the 3-year 

15 peak heavy construction period. Table 4-35 shows the total amount of CO2 released from 

16 commuting of the workforce and as a result of delivery vehicle activities. 

17 

18 Finally, onsite storage and dispensing of fuels during the period of preconstruction and 

19 construction will result in minor GHG emissions as NMVOCs. AES (2010a) estimates that 

20 approximately 150 gallons each of gasoline and diesel fuels would be dispensed each week 

21 during this period. Applying the EPA algorithm for estimating GHG emissions from fuel handling 

22 (EPA, 2005b) results in estimated annual CO2 emissions of 73 tons (66 metric tons [MT]) and 

23 83 tons (76 MT) for gasoline and diesel, respectively. 
 4-134 Table 4-34 CO2 Emissions from Onsite Fuel Consumption over the Preconstruction and Heavy Construction Period Fuel Consumption Rate Total Fuel Consumption CO2 Emission Factor Total CO2 Emissions (7 years) Annual CO2 Emissions Activity Fuel Type (gal/wk) (liter/wk) (gal) (liter) (lb/gal) (kg/liter) (ton) (MT) (ton) (MT) Heavy equipment Gasoline 350 1327 122,500 464,275 19.4 2.3 1188 1078 170 154 Diesel 10,000 37,900 3,500,000 13,265,000 22.2 2.7 38,850 35,318 5550 5046 Subtotal for onsite fuel consumption 40,038 36,396 5720 5200 1 
 4-135 Table 4-35 Emissions from Workforce Commuting and Delivery Activities over the Preconstruction and Construction Period Total Distances for 3 Peak Yrs Total Fuel Consumption CO2 Emission Factor Total CO2 Emissions (3 years of peak construction) Annual CO2 Emissions (entire 7-year preconstruction/ construction period) a Activity Fuel Type (mi) (km) (gal) (liter) (lb/gal) (kg/liter) (ton) (MT) (ton) (MT) Commuting traffic Gasoline 17,700,000 28,485,389 885,000 3,350,089 19.4 2.3 8585 7788 1840 1669 Diesel 4,425,000 7,121,347 295,000 1,116,696 22.2 2.7 3275 2977 702 638 Delivery truck traffic Diesel 1,162,500 1,870,862 116,250 440,054 22.2 2.7 1290 1173 277 252 Subtotal for workforce commuting 

and deliveries 

22,125,000 35,606,736 1,180,000 4,466,786 13,149 11,938 2818 2559 

a To calculate an annual average over the entire 7-year preconstruction and heavy construction period, it is assumed that that the 2 years following 

the 3-year peak construction period will have activity levels (including workforce reductions) approximately 50 percent of peak years, and the last 

2 years of heavy construction will have activity levels (including workforce reductions) 25 percent of peak construction years.

1 
 4-136 

1 Therefore, the total CO2 emissions expected during preconstruction and heavy construction are: 

2 

3 • 5720 tons (5189 MT) per year (averaged) from onsite fuel consumption 

4 

5 • 2818 tons (2556 MT) per year from workforce commuting and materials/equipment 

6 deliveries and waste removals during preconstruction and heavy construction 

7 

8 • 8537 tons (7745 MT) per year (averaged) for each year of the 7-year preconstruction and 

9 heavy construction period 

10 

11 • 59,759 tons (54,215 MT) over the entire 7-year preconstruction and heavy construction 

12 period. 

13 

14 Estimated GHG Emissions during Operation

15 

16 During operation, GHG emissions would result from commuting of the operational workforce, 

17 deliveries of feedstock to the proposed facility, deliveries of enriched product to fuel fabrication 

18 facilities, return of empty feedstock containers to their points of origin, and delivery of 

19 operational wastes to designated offsite disposal facilities. An incidental amount of GHG 

20 emissions also results from the onsite storage and dispensing of fossil fuels to support 

21 operations. 

22 

23 A workforce of 550 is assumed to commute a round-trip distance of 80.5 kilometers (50 miles), 

24 assuming 250 round trips per year and no credit for carpooling or busing, with a commuting 

25 vehicle fleet comprised of 90 percent gasoline-fueled vehicles averaging 20 miles per gallon 

26 (mpg) and 10 percent diesel-fueled vehicles averaging 15 mpg. The resulting annual travel 

27 distances are 9,957,816 kilometers (6,187,500 miles) for the gasoline-fueled vehicles and 

28 1,106,424 kilometers (687,500 miles) for the diesel-fueled vehicles. The total fuels consumed 

29 are estimated to be 1,171,112 liters (309,375 gallons) of gasoline and 173,498 liters 

30 (45,833 gallons) of diesel. 

31 

32 Daily deliveries to support facility operation include deliveries of nonradiological materials from 

33 vendors in the local area and shipments of nonradiological solid wastes to area landfills; 

34 deliveries of (natural) UF6 feedstock from UF6 production facilities in Metropolis, Illinois, and Port 

35 Hope, Ontario, Canada; delivery of enriched UF6 product to any of three fuel fabrication facilities 

36 in Richland Washington; Wilmington, North Carolina; or Columbia, South Carolina; and 

37 shipments of low-level radioactive (process) wastes (LLRW) to the waste disposal facility at 

Portsmouth, Ohio.24 38 Because it is difficult to anticipate the proportion of shipments among the 

39 three feedstock suppliers and the three recipients of enriched product, and in order to establish 

40 a conservative (worst-case, bounding) scenario of deliveries and shipments with respect to 

41 GHG emissions, it is presumed that the longest routes would always be selected, maximizing 

the total distance traveled by delivery trucks.25 42 It is further assumed that separate shipments 

43 would be initiated to return empty cylinders and waste containers to their points of origin and 

44 that all delivery vehicles will be diesel-fueled with an average mileage of 10 mpg. 

45 

24 Process-related waste will also be delivered to Oak Ridge, Tennessee; however, those shipments are 

not included in these GHG emission calculations because the quantities would be very small. 

25 See distances between EREF and each facility in Appendix D, Table D-7. 
 4-137 

1 In addition to deliveries and shipments, fossil fuels would be consumed onsite to support 

2 miscellaneous activities: 568 liters (150 gallons) per week each of gasoline and diesel, making 

for 28,391 liters (7500 gallons) per year,26 3 and a small amount of GHG will be emitted from the 

4 onsite storage and dispensing of fossil fuels. Applications of the operational parameters offered 

5 by AES and the assumptions discussed above result in the estimates of CO2 emissions during 

6 operation from workforce commuting and deliveries shown in Tables 4-36 and 4-37, 

7 respectively. It is assumed that onsite gasoline and diesel fuel dispensing will occur on 

8 approximately 50 days each year for each fuel, resulting in emissions of 66 MT (73 tons) of CO2

9 from gasoline dispensing and 76 MT (83 tons) of CO2 from diesel fuel dispensing for an annual 

10 total of 142 MT (156 tons) of NMVOCs released during each year of operation as a result of 

11 onsite fossil fuel handling. 

12 

13 The estimated annual emissions of CO2 from EREF operation, therefore, are 26,136 MT 

14 (28,809 tons). 

15 

16 Estimated GHG Emissions during Decommissioning

17 

18 Activities associated with decommissioning are generally described in Section 2.1.4.3. GHG 

19 emissions associated with decommissioning would result primarily from three activities: (1) the 

20 onsite consumption of fossil fuels in vehicles and equipment used to dismantle and in some 

21 cases demolish existing structures or excavate buried utilities and components, (2) the 

22 transportation of waste materials and salvage materials from the proposed site to appropriate 

23 offsite disposal or recycling facilities, and (3) the commuting to the proposed site of the 

decommissioning workforce. The absence of a detailed decommissioning plan27 24 precludes 

25 detailed quantification of GHG emissions associated with decommissioning. However, AES’s 

26 general descriptions of the expected decommissioning strategy and schedule can provide some 

27 insight into potential GHG impacts and allow for the application of conservative assumptions to 

28 estimate bounding conditions. 

29 

30 AES has indicated that decommissioning would take approximately 8 years, including a brief 

31 period at the start of decommissioning when limited facility operation is still ongoing. In its Final 

32 SAR (AES, 2010b), AES further estimated the volume of LLRW that would be generated to be 

approximately 7700 cubic meters (10,070 cubic yards)28 33 and estimated the workforce in the 

34 overlap period to be approximately the same as the operating workforce, 590 individuals. 

35 

 

26 The onsite storage of fossil fuels would also result in the release of insignificantly small amounts of 

NMVOCs from the normal venting of the storage tanks. However, because neither the specific volume 

nor the chemical speciation of these evaporative losses can be firmly known, resulting GHG emissions 

cannot be estimated. 

27 A detailed decommissioning plan will be submitted to the NRC near the end of the operating license, in 

accordance with 10 CFR 70.38. 

28 AES anticipates processing some wastes for the purposes of volume reduction prior to shipments to 

offsite disposal or recycling facilities (AES, 2010b). However, specific details were not provided and no 

credit is therefore extended for any anticipated waste volume reductions in this GHG analysis. 
 4-138 Table 4-36 Annual CO2 Emissions as a Result of Workforce Commuting during EREF Operation RT Distance Total Distances per Year Total Fuel Consumption Annual CO2 Emissions Activity Fuel Type Total Workers (mi) (km) Working Days/y (mi) (km) (gal) (liter) (ton) (MT) Commuting traffic Gasoline 495 50 80.5 250 6,187,500 9,957,816 309,375 1,171,112 3001 2722 Diesel 55 50 80.5 250 687,500 1,106,424 45,833 173,498 509 462 Subtotal of CO2 emissions from workforce commuting 550 6,875,000 11,064,240 355,208 1,344,610 3510 3184 1 
 4-139 Table 4-37 Annual CO2 Emissions as a Result of Deliveries during EREF Operation One-way Trip Distance Annual Traveled Distance Fuel Consumption @10 mpg Annual CO2 Emissions Material Origin/ Destination (mi) (km) Annual Number of Trips (mi) (km) (gal) (liter) (ton) (MT) Process-related nonradiological, nonhazardous wastes Local vendors/ Idaho Falls and vicinity 25 40 3889 194,450 312,937 19,445 73,607 216 196 (Natural) UF6 feedstock Port Pope, Ontario, Canada 2314 3724 1424 6,590,272 10,606,015 659,027 2,494,689 7315 6636 Enriched UF6 product Columbia, SC 2359 3796 516 2,434,488 3,917,929 243,449 921,554 2702 2451 Depleted UF6 tails Portsmouth, OH 2101 3381 1222 5,134,844 8,263,730 513,484 1,943,750 5700 5171 LLRW Licensed TSDFs (Oak Ridge, TN) 1907 3068 16 30,512 49,088 3051 11,533 34 31 Empty feedstock 

cylinders 

Port Pope, Ontario, Canada 2314 3724 712 3,295,136 5,303,007 329,514 1,247,345 3658 3318 

Empty product cylinders Colombia, SC 2359 3796 516 2,434,488 3,917,929 243,449 921,554 2702 2451 Empty tails containers Portsmouth, OH 2101 3381 611 2,567,422 4,131,865 256,742 971,875 2850 2585 Subtotal of CO2 emissions related to deliveries 8906 22,651,900 36,454,699 2,265,190 8,574,677 25,177 22,840 

1 
 4-140 

1 The following are conservative reasonable assumptions that can be made relative to EREF 

2 decommissioning and that can be used to estimate GHG impacts associated with 

3 decommissioning: 

4 

5 • CO2 emissions from shipments of enriched uranium product and operational waste 

6 shipments still occurring during the initial period of decommissioning are treated as 

7 operational GHG impacts. 

8 

9 • Shipments of wastes or recycling materials would occur by diesel-fueled trucks averaging 

10 10 mpg. 

11 

12 • Annual CO2 emissions from onsite consumption of fossil fuels is expected to be less than 

13 the average annual emissions of CO2 experienced during facility preconstruction and 

14 construction, as presented in Table 4-34 above. 

15 

16 • LLRW resulting from decontamination activities would be substantially greater in volume 

17 than LLRW resulting from routine EREF operation. 

18 

19 • Assuming an average density for the decommissioning waste and an expected weight for 

20 individual shipments, an estimated 4205 shipments of LLRW will occur annually over the 

21 8-year period of decommissioning, for an annual total of 33,640 trip miles to the LLRW 

22 treatment, storage, and disposal facility (TSDF) in Oak Ridge, Tennessee. This will result in 

23 total trip length of 206,415,040 kilometers (128,302,960 miles) and the consumption of 

24 484,985,188 liters (12,830,296 gallons) of diesel fuel, and estimated CO2 emissions of 

25 129,469 MT (142,416 tons) over the entire decommissioning period. 

26 

27 • All nonradioactive and nonhazardous solid wastes are presumed to be delivered to the 

28 same area landfills and treatment facilities that received wastes of similar nature during 

29 EREF operation. Assuming successful decontamination of the majority of EREF equipment 

30 and structures, a significantly higher number of annual trips would occur throughout the 

31 8-year decommissioning phase than would have occurred annually during EREF operation, 

32 and the resulting CO2 emissions would be at least an order of magnitude greater than the 

33 values for such waste shipments appearing in Table 4-37. 

34 

35 • All nonradioactive hazardous waste generated during EREF operations would already have 

36 been delivered to permitted TSDFs, and the CO2 emissions of such deliveries would be 

37 credited to the EREF operational phase. The amount of nonradioactive hazardous waste 

38 newly generated as a result of decommissioning activities is expected to be very small and 

39 would likely be delivered to the same TSDF that received similar waste during EREF 

40 operation. It is further assumed that an appropriately permitted TSDF will be located within 

41 a reasonable distance from the proposed EREF, resulting in limited amounts of GHG 

42 emissions from transport. 

43 

44 • Except for the brief period at the beginning of decommissioning when some operations are 

45 still ongoing, the decommissioning workforce is expected to be similar in size to the 

46 operational workforce – 550 individuals. For the early years of decommissioning, 

47 parameters of workforce commuting are therefore assumed to be the same as those 

48 described above for commuting impacts during operation, resulting in an annual release of 
 4-141 

1 CO2 related to workforce commuting similar in magnitude to the values displayed in 

2 Table 4-36 above, 3184 MT (3510 tons). In the early years when operations and 

3 decommissioning are coincident, CO2 emissions from workforce commuting are expected to 

4 be proportionally higher. 

5 

6 Indirect Positive Impacts from EREF Facility Operation

7 

8 Nuclear power generated with fuel fabricated from the enriched uranium generated at the 

9 proposed EREF would indirectly displace GHG emissions that would otherwise be released 

10 from fossil-fueled power plants. Accordingly, enriched UF6 produced at the proposed EREF can 

11 be thought of as indirectly helping to avoid GHG emissions. AES estimates that, at full 

12 production, the proposed EREF would produce approximately 2252 metric tons (2482 tons) of 

13 enriched UF6 annually, which would be equivalent to 1727 metric tons (1904 tons) of UO2 fuel. 

14 A typical 1100-MWe pressurized water reactor (PWR) would have approximately 98 MT 

15 (108 tons) of UO2 in its core (Nero, 1979). Thus, annual production of the proposed EREF 

16 could replace the fuel cores of 17.9 PWRs. Operating at a capacity factor of 95 percent, each 

17 PWR would be capable of producing 8322 megawatt hours per year (MWh/yr). Thus the total 

18 amount of power associated with the proposed EREF’s annual enriched UF6 production would 

19 be 146,467 MWh/yr. 

20 

21 In 2005, emission factors for CO2 from coal-burning power plants ranged from a minimum of 

22 1341.64 pounds per megawatt hour to a maximum of 2449.43 pounds per megawatt hour, with 

23 the U.S. composite value (representing an average of all operating coal plants) of 

2134.64 pounds per megawatt hour (EPA, 2009b).30 24 Thus, displacing power from coal-burning 

25 power plants with an equivalent amount of power produced in nuclear reactors from fuel 

26 fabricated from an annual amount of EREF-enriched UF6 would have prevented the release of 

3117  106 27 pounds of CO2, or 1.42 million metric tons (1.56 million tons). 

28 

29 Carbon Dioxide and Other GHG Emissions Summary

30 

31 Using calendar year 2005 as a reference point (the latest year for which Idaho GHG emission 

32 data are available), and as shown in Table 4-33, total net CO2 emissions for Idaho for the year 

33 2005 were 36.0 million metric tons of CO2 equivalents. For the United States for that same 

34 year, total net CO2 emissions were 5985.9 million metric tons (6584.5 million tons) 

35 (EPA, 2009a). By comparison, during all of the 3 peak activity years of construction, EREF CO2

36 emissions are projected to be 11,929 metric tons (13,149 tons), or 0.03 percent of Idaho’s 

37 statewide output and 0.0002 percent of the projected nationwide CO2 emissions for the same 

38 period. 

39 

40 During any typical year of EREF operation, CO2 emissions are projected to be 26,136 MT 

41 (28,809 tons), approximately 0.07 percent of the Idaho statewide output or 0.00044 percent of 

42 the nationwide emissions for calendar year 2005. The NRC staff concludes that, even without 

43 giving credit to the proposed EREF for contributing to the avoidance of CO2 emissions as 

 

30 Coal-burning power plants in Idaho had the lowest CO2 emission factor in 2005; however, because 

fuel fabricated from EREF-enriched uranium could conceivably be installed in any nuclear reactor 

operating within the North American Electric Reliability Corporation (NERC) geographic area of 

authority, the composite emission factor is the most representative value for use in this comparison. 
 4-142 

1 discussed above, impacts from the preconstruction, construction, operation, and 

2 decommissioning of the proposed EREF from the emissions of CO2 and other GHGs would be 

3 SMALL. 

4 

5 4.2.18 Terrorism Consideration 

6 

7 This section discusses the potential environmental impacts of a hypothetical terrorist attack at 

8 the proposed EREF. The terrorism threats that were considered are associated with releases to 

9 the environment of radioactive and hazardous material at the proposed EREF and of radioactive 

10 and hazardous material transported to and from the proposed EREF. In this terrorism analysis, 

11 radioactive and hazardous material includes natural, enriched, and depleted uranium (all as 

12 UF6) that would be present in large quantities during onsite storage and shipment to and from 

13 the proposed EREF site. 

14 

15 4.2.18.1 Background Information 

16 

17 In its Notice of Hearing and Order in the matter of the proposed AES EREF (74 FR 38052, 

18 July 30, 2009) (NRC, 2009c), the Commission directed, and provided relevant guidance to, the 

19 NRC staff to address in the EIS the environmental impacts of a terrorist attack at the proposed 

20 EREF. Consistent with the Commission’s guidance, the terrorism consideration presented 

21 herein has been developed using available information in agency records and other available 

22 information on the proposed EREF design, mitigations, and security arrangements that have a 

23 bearing on likely environmental consequences, in accordance with the requirements of NEPA 

24 and the regulations for the protection of sensitive unclassified and classified information. 

25 

26 Also, consistent with the Commission’s guidance, this terrorism consideration relies on as much 

27 publicly available information as practicable and makes public as much of its environmental 

28 analysis as feasible recognizing, however, that it may prove necessary to withhold certain NRC 

29 staff findings and conclusions as sensitive unclassified and classified information. In addition, 

30 the analysis relies, where appropriate, on qualitative rather than quantitative considerations. 

31 

32 In the case of the proposed EREF, the terrorism consideration uses publicly available 

33 information from accident analyses conducted for the proposed facility and similar facilities, as 

34 well as certain security-related information not available to the public. Whether the release of 

35 radioactive and hazardous material into the environment occurs because of an explosion or 

36 other cause due to an accidental sequence of events or to a series of premeditated terrorist 

37 activities, the results would be similar given an explosion or other incident of the same 

38 magnitude and the same amount of material involved, regardless of the initiating event. Thus, a 

39 range of potential impacts from hypothetical terrorist acts can be estimated from a range of 

40 potential accidents with similar characteristics and consequences, as further discussed below. 

41 

42 Section 4.2.18.2 discusses potential terrorism impacts, and Section 4.2.18.3 discusses 

43 mitigative measures intended to defeat a terrorist attack and reduce potential consequences. 

44 

45 4.2.18.2 Potential Impacts of Terrorist Events 

46 

47 Terrorist events leading to the dispersion of radioactive and hazardous material into the 

48 environment could occur during transportation of such materials to or from the proposed EREF 
 4-143 

1 or at the proposed EREF site. In either case, impacts ranging from minor incidents to wider 

2 spread releases of contamination are possible. As discussed below, the resulting quantities of 

3 radioactive and hazardous material potentially released by a terrorist event would be similar to 

4 those for transportation accidents as analyzed in this EIS in Section 4.2.9.2 and in Appendix D, 

5 Section D.5, and for facility accidents as analyzed in Section 4.2.15. 

6 

7 Unlike the accident analysis, which considers potential accidents with some likelihood of 

8 occurrence, the consideration of terrorist events provides an estimate of the potential 

9 consequences of such events without attempting to assess the likelihood that any one specific 

10 scenario would be attempted or would succeed. There are limitless potential scenarios 

11 involving a specific initiating event whereby radioactive and hazardous material could be 

12 released as a result of a terrorist attack. The likelihood of occurrence of any terrorist scenario is 

13 speculative and cannot be determined. However, there are certain classes of events that may 

14 be identified and qualitatively analyzed to provide estimates of a potential range of impacts. 

15 In addition, any estimate of the likelihood of a terrorist attack would not account for any security 

16 measures that might be implemented to assist in the prevention of such attacks. Thus, the 

17 comparison of terrorist events with accidents in the following sections addresses the potential 

18 consequences should a terrorist act occur and does not discuss the likelihood of such events. 

19 

20 As part of the analysis, a literature review of available studies by the NRC and DOE was 

21 conducted, which considered potential accidents at current or proposed uranium enrichment 

22 facilities. The consequences associated with these potential accidents were reviewed and 

23 compared against potential consequences from terrorist attacks at the proposed EREF and at 

24 other uranium enrichment facilities. 

25 

26 Transportation Impacts

27 

28 A terrorist attack on vehicles transporting radioactive and hazardous material to and from the 

29 proposed EREF would result in the threat for partial or complete release of transported material 

30 to the environment. The consequences of such a terrorist act depend on the quantity of 

31 material that could be released, on the chemical, radiological, and physical properties of the 

32 material involved, how it is packaged, and its ease of dispersion. Consequences also depend 

33 on the surrounding environment, land use, and population density in the vicinity of the event. 

34 Radioactive and hazardous material would be transported through areas of varying population 

35 density and land use, to the proposed EREF as natural uranium in 14-ton 48Y cylinders and 

36 from the proposed EREF as enriched uranium in 2.5-ton 30B cylinders (in protective Type B 

37 overpacks) and depleted uranium in 48Y cylinders. 

38 

39 A number of studies have been published by DOE on the potential impacts should these types 

40 of shipments become involved in a serious accident (DOE, 1999, 2004a,b). In these studies, 

41 accident scenarios were characterized by extreme mechanical and thermal forces. In all cases, 

42 these accidents would result in a release of radioactive and hazardous material to the 

43 environment. The accidents corresponding to those with the highest accident severity represent 

44 low-probability, high-consequence accident events. Regardless of the initiating event, the 

45 highest potential impacts from terrorist acts would be similar to severe transportation accident 

46 impacts. 

47 
 4-144 

1 To account for terrorist events that could occur in a range of population densities, the impacts 

2 have been estimated for generic rural, suburban, and urban locations with assumed population 

densities of 6 persons/km2

, 719 persons/km2, and 1600 persons/km2 3 , respectively. From 

4 accident consequence estimates (DOE, 2004a), the collective population dose from a single, 

5 14-ton 48Y cylinder shipment of depleted UF6 (one cylinder per truck) involved in a severe 

6 accident in a highly populated urban area corresponds roughly to one latent cancer fatality. 

7 Impacts in rural and suburban areas would be lower because of their lower population densities 

8 (DOE, 2004a). Acute fatalities from radioactive exposure to depleted UF6 are not expected 

9 under any scenario. Impacts from a similar incident involving a natural uranium shipment are 

10 expected to be approximately the same because natural uranium is also shipped in 

11 48Y cylinders (one per truck). 

12 

13 In addition, a severe transportation incident would restrict the use of the affected road and of 

14 surrounding land, homes, and businesses that would have been contaminated from the incident. 

15 Use of the land, housing, or businesses would resume after completion of cleanup activities and 

16 permission for use is allowed by authorities. 

17 

18 Socioeconomic impacts will depend on the location of the event along the transportation route 

19 within a generic rural, suburban, and urban area. The specific use of the area (e.g., agricultural, 

20 retail, service, commercial, industrial (manufacturing), residential, or mixed use) will determine 

21 the specific socioeconomic impacts in the affected area. The temporary closing of businesses 

22 will have direct and indirect impacts on the employment from these businesses, which is 

23 expected to last until cleanup activities are complete. In addition to loss of employment, other 

24 impacts could occur. For example, in the case of manufacturing or agricultural areas, the loss 

25 of material goods or produce that would have been generated during the cleanup period could 

26 result in higher cost of goods in the area due to a loss in supply; contaminated housing could 

27 result in relocation of residents until cleanup efforts are complete; or a contaminated 

28 transportation link (e.g., a subway station) could result in disruption of the commuter network 

29 while cleanup activities are under way. 

30 

31 Acute chemical fatalities from exposure to HF formed following a release of UF6 would be 

32 possible, depending on the proximity of the nearest individuals. For the same potential incident, 

33 DOE (2004a) estimated that as many as several to several hundred or more adverse impacts 

34 could occur, but only up to three irreversible adverse health effects were estimated. Adverse 

35 effects range from mild and transient effects, such as respiratory irritation or skin rash 

36 (associated with lower chemical concentrations), to irreversible (permanent) effects which could 

37 include death or impaired organ function (associated with higher chemical concentrations). For 

38 exposures to uranium and HF, it was estimated that the number of fatalities occurring would be 

39 about 1 percent of the number of irreversible adverse effects (DOE, 1999); therefore, in this 

40 case no fatalities are expected. 

41 

42 Similar impacts would be expected from terrorist events involving shipments of natural or 

43 enriched uranium. The UF6 enrichment results in no additional effect on any potential chemical44 related impacts, nor is it expected to have any significant effects on the radiological impacts, 

45 because of the relatively small amount of U-235 compared to that of U-238. 

46 

47 According to AES (2010a), shipments involving enriched uranium would occur with two 

48 cylinders per truck in smaller (2.5-ton) Type 30B cylinders in protective Type B overpacks, 
 4-145 

1 resulting in a reduced amount of UF6 released as the result of a severe terrorist incident. 

2 Therefore, the results from a terrorist act involving a shipment of natural or enriched uranium is 

3 expected to be less than that from a depleted uranium shipment. Appendix D of this EIS 

4 includes a discussion of the differences between the shipping configurations for the different 

5 types of cylinders. 

6 

7 Facility Impacts

8 

9 Section 4.2.15 of this EIS discusses potential accidents considered at the proposed EREF and 

10 the resulting health effects. The accidents evaluated are representative of the types of 

11 accidents that are possible at a uranium enrichment facility, covering a range of initiating events. 

12 The consequences of these events are directly affected by the type and amount of material 

13 released at different locations at the proposed EREF. Therefore, similar consequences are 

14 expected from similar incidents involving the same material resulting from a terrorist attack. 

15 Thus, consequences from potential accidents discussed in Section 4.2.15, including health 

16 effects to workers and the public, are also applicable to potential terrorist attacks. 

17 

18 Chemical impacts to workers at the proposed EREF associated with a potential terrorist attack 

19 could range from no adverse effects to adverse effects to the majority of workers. Similarly, 

20 DOE (1999) estimated that chemical impacts to members of the general public could range from 

21 no adverse health effects to adverse health effects to less than 1900 members of the public. 

22 However, it is expected that much fewer than 1900 members of the public could be affected in 

23 the vicinity of the proposed EREF because the DOE analysis was for a location with a higher 

24 population density (>34,000 people within 16 kilometers [10 miles]) than that of the proposed 

25 EREF location, which has no appreciable population within 16 kilometers [10 miles] 

26 (see Table 4-22). 

27 

28 A terrorist attack on the proposed EREF that causes a release of UF6 to the air would result in 

29 an airborne contamination plume in the prevailing wind direction during the release. The plume 

30 would eventually precipitate and settle on the ground surface. The resulting areal extent of the 

31 ground contamination would depend on the wind speed and degree of vertical mixing (stability 

32 class) during the release. In any case, the extent of the plume containing uranium compounds 

33 and ground contamination would be limited by the expected high deposition rate of uranium in 

34 any chemical form. UF6 would be rapidly converted to particulate uranyl fluoride (UF2O2) 

35 through reaction with moisture in the air. HF, which is also produced in this reaction, would not 

36 have any residual effects following an incident because of its relatively low concentration and 

37 because it will quickly react in air or upon deposition. However, dependent on the amount of 

38 UF6 released, the airborne HF plume generated in the vicinity of the release point could cause 

39 fatality to humans and animals from inhalation, but would rapidly disperse downwind. Lethal air 

40 concentrations of HF immediately following a release of UF6 would not be expected at the 

41 proposed EREF site boundary as supported by the results of the accident analysis in 

42 Section 4.2.15. 

43 

44 Uranium contamination deposited on the ground would be initially confined to a thin surface 

45 layer on vegetation and surface soil. Uranium concentrations in soil and vegetation near the 

46 release point would be expected to be similar to those measured following the accidental 

47 rupture of 14-ton cylinders containing liquid UF6 at fuel cycle facilities (DOE, 1978; NRC, 1986). 

48 Based on this historical data and supported by atmospheric dispersion models, a plume might 
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1 be expected to extend on the order of 1 to 2 kilometers (0.6 to 1.2 miles) in the primary wind 

2 direction, with rapidly decreasing contaminant concentrations moving away from the source. 

3 For the proposed EREF, the highest ground and vegetation concentrations would be expected 

4 to be confined to the proposed EREF property because of the large distance from the proposed 

5 facility to the property boundary. The resultant environmental concentrations beyond a few tens 

6 of meters from the release point after the plume has passed by and deposition has occurred 

7 would not be expected to cause any long-term chemical or radiological effects to humans, 

8 wildlife, or vegetation. In the short term, resuspension of uranium particulates could result in a 

9 small inhalation hazard, but weathering processes (e.g., wind and precipitation) would be 

10 expected to reduce average concentration levels. However, some concentration of the uranium 

11 could occur in certain areas due to preferential flow of water runoff during heavy precipitation 

12 events. 

13 

14 The actual extent of any plume would be determined with high precision using appropriate 

15 radiation surveys following an incident. The amounts of uranium and HF directly deposited on 

16 plants near the release point would be measured and the consumption of vegetation by humans 

17 and/or animals restricted as necessary (NRC, 1986). The restrictions in consumption would 

18 occur for a defined time interval and would be removed after new measurements indicate safe 

19 use of vegetation by humans and/or animals. In addition, if necessary, exposures to the public 

20 would be prevented by restricting access. Survey data would be used to compute risks to the 

21 public and environment, and appropriate cleanup actions would be taken. Exposure analysis 

22 would include direct and indirect pathways, including food chain analyses. 

23 

24 Cleanup conducted in a timely manner would minimize migration of contamination to greater soil 

25 depths or to surface water or groundwater. Little or no surface water exists in area of the 

26 proposed EREF, which is primarily rangeland and farmland. Depending on the extent of the 

27 contamination, cleanup could include decontamination and repair of damaged equipment and 

28 buildings, possible excavation of a thin surface layer of soil, and removal of vegetation. Wastes 

29 from cleanup activities would be shipped offsite for disposal at a licensed low-level waste 

30 facility. Such cleanup would reduce residual risks to acceptably low levels, likely to background 

31 levels if soil were removed. Depending on the extent of the contamination and damage, 

32 cleanup costs could reach into the tens of millions of dollars or more for decontamination and 

33 cleanup of the local area, costs for repair of damaged facilities, (DOE, 2007; see Appendix H for 

34 construction costs), and remediation of the surrounding area, if uranium and soil concentrations 

35 in soil and vegetation are considered excessive. 

36 

37 A terrorist act would interrupt facility operations until the essential cleanup activities are 

38 complete. This would have an impact on the economic activity in the area because people 

39 would be out of work for the duration of the cleanup activities. At the same time, some 

40 economic activity will take place, such as employment of workers to conduct the cleanup 

41 activities. The duration of these cleanup activities and the number of personnel required would 

42 depend on the severity of the contamination. 

43 

44 4.2.18.3 Mitigative Measures 

45 

46 Mitigative measures proposed for potential releases under accident conditions as described in 

47 Section 4.2.15.3 would also be applied, as appropriate, as mitigative measures against terrorist 

48 attack. Such measures identified by AES include, but are not limited to, process system(s) and 
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1 building construction designed to minimize the quantity of radioactive material at any given 

2 location and to isolate that material from the outside environment and detection and alarm 

3 systems for radiation and fire hazards, in conjunction with barriers designed to prevent the 

4 spread of material within the proposed facility (AES, 2010c). While adversaries might seek to 

5 defeat some of the listed elements of the mitigative controls, the protective system would be 

6 designed to provide defense-in-depth and would be robust to limited degradation. 

7 

8 Prior to operation of the proposed EREF, AES would also be required to fully implement security 

9 measures required by 10 CFR Parts 73, 74, and 95 of the regulations and additional security 

10 requirements issued by order. The NRC anticipates imposing additional security measures on 

11 AES to address the current threat environment (NRC, 2010e). Under the additional security 

12 measures, AES would need to identify critical target areas, if any, and provide a means for 

13 protecting these areas. Critical target areas would be determined based on hazards related to 

14 licensed radioactive materials. In addition, these measures would include, for example, 

15 information protection, personnel trustworthiness and access authorization, material control and 

16 accounting, and physical protection systems and programs. Compliance with these security 

17 measures would mitigate potential consequences of adversary actions. 

18 

19 4.3 Cumulative Impacts 

20 

21 The CEQ regulations implementing NEPA define cumulative impacts, or effects, as “the impact 

22 on the environment which results from the action when added to other past, present, and 

23 reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or 

24 person undertakes such other actions” (40 CFR 1508.7). In the following analysis, cumulative 

25 impacts are assessed from the anticipated impacts of the proposed EREF project when added 

26 to other identified projects, facilities, or activities in the region that have impacts that affect the 

27 same resources or human populations. Effects from the various sources may be direct or 

28 indirect and they may be additive or interactive. Such effects are assessed that, when on their 

29 own, may be minor, but in combination with other effects may produce a cumulative effect that 

30 is of greater concern. 

31 

32 To identify the activities in the region that could contribute to cumulative impacts, an ROI was 

33 defined for each resource that is expected to be impacted by the proposed EREF project. An 

34 ROI for a particular resource is the size of the surrounding area within which impacts from 

35 multiple sources may be additive or interactive. The sizes of the ROIs may be different for 

36 various resources, and some resources may be remote from the proposed site, such as a waste 

37 disposal facility or a receiving water body downstream of the proposed project. Still others 

38 might cover large areas, such as a watershed or airshed. The resource ROIs are discussed 

39 further later in this section. For the proposed EREF, an ROI radius of 16 kilometers (10 miles) 

40 was identified for all resources except socioeconomics, for which an ROI radius of 80 kilometers 

41 (50 miles) was identified. Impacts on the full extent of the resources affected, such as an 

42 ecoregion, were analyzed, even if the resource extends beyond the identified ROIs. 

43 

44 A search was conducted to identify projects or activities in the region that would contribute to 

45 cumulative effects. This review included existing activities in the region that would affect the 

46 same resources as the proposed EREF project, known past impacts on these resources, and 

47 reasonably foreseeable proposed new projects, activities, or facilities that would impact these 

48 resources. Foreseeable development in the region was assessed through consultation with 
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1 local development boards and agencies with which proposed plans for projects must be filed. 

2 Past impacts have resulted primarily from the development of agriculture in the region and the 

3 development of the INL near the proposed project site. The main INL facilities lie outside the 

4 16-kilometer (10-mile) ROI, but within the 80-kilometer (50-mile) ROI for socioeconomics. 

5 

6 Impacts from preconstruction activities for the proposed EREF are addressed as cumulative 

7 impacts in this EIS, as these actions are not part of the proposed action. These impacts are 

8 discussed within the various resource area discussions in Section 4.2 so that they can be 

9 presented alongside similar impacts from construction of the proposed facility, which are part of 

10 the proposed action. For the purposes of cumulative impacts analysis in this EIS, 

11 preconstruction activities are considered past activities because they occur prior to the main 

12 aspects of facility construction and prior to facility operation. 

13 

14 Also considered in this section is the construction and operation of the proposed 161-kilovolt 

15 (kV) electrical transmission line and associated substation installation and upgrades to provide 

16 electrical power for the operation of the proposed EREF. Rocky Mountain Power (RMP) 

17 proposes to build a 161-kV transmission line that would extend westward from the existing 

18 Bonneville Substation 14.5 kilometers (9 miles) along an existing 69-kV transmission line ROW 

19 to the existing Kettle Substation near the proposed EREF site and continue a total 

20 7.6 kilometers (4.75 miles) further to the proposed new Twin Buttes Substation within the 

21 proposed EREF property, a total length of 22.1 kilometers (13.75 miles). This proposed project 

22 would involve a rebuild/replacement of the 14.5-kilometer (9-mile) long 69-kV line portion to 

23 include a double circuit line, with one side energized at 69 kV and the other side at 161 kV to 

24 provide service to the proposed Twin Buttes Substation. The proposed Twin Buttes Substation 

25 will be located within a 15-acre area on the proposed EREF site that would be excavated during 

26 preconstruction activities. The proposed project would also include modifications at the 

27 Bonneville Substation. The details of the route as well as other critical parameters of the 

28 transmission line construction that would impact air quality are contained in Appendix H to the 

29 EREF ER (AES, 2010a), and the proposed transmission line is further described in 

30 Section 2.1.3.2. 

31 

32 No additional ongoing or planned developments were identified within 16 kilometers (10 miles) 

33 ROI of the proposed project location. However, several ongoing and proposed developments 

34 within 80 kilometers (50 miles) have been identified that could contribute to a regional 

35 socioeconomic impact in combination with the proposed project. A listing of these projects and 

36 potential cumulative socioeconomic impacts are presented in Section 4.3.12 below. Among 

37 these is the proposed Mountain States Transmission Intertie, a proposed 500-kV transmission 

38 line running between western Montana and southeastern Idaho (NorthWestern Energy, 2008). 

39 The project is currently undergoing environmental review under NEPA. The preferred route lies 

40 approximately 40 kilometers (25 miles) to the west of the proposed EREF site, running north41 south. Two alternate routes lie closer, the nearest running adjacent to the western boundary of 

42 the proposed EREF property just outside of INL property, and the other route crossing US 20 

43 about 10 miles east of the proposed EREF site. Construction of this transmission line is 

44 planned to begin in 2010 and be completed in early 2013, with service starting in 2013. 

45 Assuming that the preferred route will be selected, cumulative impacts would occur only to 

46 socioeconomics in the region. If one of the closer alternative routes is selected, cumulative 

47 impacts on other resources would have to be considered. 

48 
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1 The following sections present assessments of the potential cumulative impacts of the 

2 construction and operation of the proposed EREF for each resource area. Under the no-action 

3 alternative, the proposed site would continue to be used for agriculture and cumulative impacts 

4 would be equivalent to current impacts and generally less than those for the proposed action, 

5 except in terms of local job creation. Therefore, except for socioeconomic impacts, the 

6 cumulative impacts of the no-action alternative are not discussed in detail. 

7 

8 4.3.1 Land Use 

9 

10 The EREF is being proposed on private land located in a remote location. The area is zoned for 

11 grazing, which in Bonneville County allows for industrial activities such as construction and 

12 operation of a uranium enrichment facility. Cumulative land use impacts would result if land use 

13 designations were altered through incremental development. The proposed EREF project is 

14 consistent with other development that has occurred in the county on INL land under the current 

15 zoning. No future development activities are reasonably foreseeable that would result in a 

16 cumulative alteration to land use designations. Therefore, cumulative land use impacts would 

17 be SMALL. 

18 

19 The proposed installation of the 161-kV transmission line to power the proposed EREF would 

20 be entirely on private land (AES, 2010a). Current land use within the proposed transmission 

21 line corridor is agricultural and open rangeland (USGS, 2009), and is not expected to be 

22 restricted as a result of the installation of the transmission line. Cumulative land use impacts 

23 associated with the construction and operation of the proposed transmission line would be 

24 SMALL. 

25 

26 4.3.2 Historic and Cultural Resources 

27 

28 The proposed EREF would be constructed on private land in a remote location. No additional 

29 development is currently known for the region. The Wasden Complex archaeological site is 

30 located in the general vicinity of the proposed EREF. In the event that additional development 

31 did take place, there could be the potential for impacts to occur to the viewshed associated with 

32 this significant historic and cultural resource. Cumulative impacts could also occur to historic 

33 and cultural resources if a particular site type was systematically removed. The significant 

34 cultural resource site known on the proposed EREF site, site MW004, is a historic homestead. 

35 This site type is found throughout the region (Gilbert, 2010), and the potential for this site type to 

36 be removed entirely from the region is unlikely. Therefore, cumulative impacts to historic and 

37 cultural resources would be SMALL. 

38 

39 The Area of Potential Effect (APE) for the proposed 161-kV transmission line project is 

40 202.3 hectares (500 acres) for the line itself. The fenced area at the proposed modified 

41 Bonneville Substation is 1.3 hectares (3.1 acres), and the proposed new Twin Buttes Substation 

42 on the proposed EREF site itself would occupy a 2.1-hectare (5.2-acre) fenced area. Portions 

43 of the proposed Twin Buttes Substation and of the proposed transmission line adjacent to the 

44 proposed EREF were surveyed previously as part of the survey for the main portion of the 

45 proposed EREF site (Ringoff et al., 2008). Site MW004 was identified during this survey near 

46 the location of the proposed Twin Buttes Substation. See Section 4.2.2.1 for a discussion of the 

47 effects on the site MW004 and the mitigation approach. The ROW for the proposed 161-kV 

48 transmission line has been surveyed for the presence of historic and cultural resources 
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1 (Harding, 2010). The survey examined the 202.3-hectare (500-acre) APE which is derived from 

2 the 22.12-kilometer (13.74-mile) transmission line and 45.72 meters (150 feet) on either side of 

3 the centerline (91.4-meter [300-foot] total width). No historic and cultural resources were 

4 identified in these surveys. It is currently unclear whether additional areas would be needed for 

5 some aspects of the transmission line construction (e.g., pulling and tensioning sites). AES has 

6 stated that an unanticipated discoveries and monitoring plan will be in place during construction 

7 (AES, 2010e). Consultation between the NRC and the Idaho SHPO is ongoing concerning 

8 historic and cultural resources along the proposed transmission line ROW and at the 

9 substations (NRC, 2010b). The Shoshone-Bannock Tribes was also contacted to determine if it 

10 had issues of importance to the tribe concerning the proposed transmission line project 

11 (NRC, 2010c). 

12 

13 4.3.3 Visual and Scenic Resources 

14 

15 Cumulative impacts to visual and scenic resources would occur if additional development 

16 resulted in a significant change in the visual qualities of the region. No additional development 

17 is planned for the region. In the event that additional industrial development occurred in the 

18 vicinity of the proposed EREF, it could have a negative impact on the scenic qualities of the 

19 Wasden Complex archaeological site and the Hell’s Half Acre WSA. The natural character of 

20 the area is currently intact. A series of industrial developments could alter the visual qualities of 

21 the area, which would not be consistent with the BLM VRM class currently in place for the Hell’s 

22 Half Acre WSA. However, no additional development is reasonably foreseeable for the area; 

23 therefore, the cumulative impact would be SMALL. 

24 

25 The proposed transmission line to be constructed for the proposed EREF has the potential to 

26 affect visual and scenic resources. The proposed transmission line largely follows an existing 

27 ROW for an existing 69-kV line. The proposed transmission line is a 161-kV line that will 

28 replace the 69-kV line. It will be mounted on poles that can be as much as 24.4 meters (80 feet) 

29 tall (AES, 2010a). The new transmission line would be plainly visible from US 20. However, 

30 there are no specific key observation points along most of the route. The closest key 

31 observation point is the trailhead for the Twenty Mile Trail at the Hell’s Half Acre WSA, but most 

32 of the proposed transmission line would not be visible from this trailhead. The only portion of 

33 the proposed line that would be visible is where this line enters the proposed EREF site. The 

34 cumulative visual impact from the proposed transmission line would be SMALL. 

35 

36 4.3.4 Air Quality 

37 

38 Some expansions of local businesses can be expected to occur in support of construction and 

39 operation of the proposed EREF. However, the air impacts from such expansions are expected 

40 to be negligible. No other major facility is expected to be constructed in the local area 

41 specifically to support, or as a direct result of, EREF operations. However, operation of the 

42 proposed EREF would result in increased energy requirements for the local area. Air impacts 

43 could result from expansions of existing sources of energy generation or construction of new 

44 energy generating sources to meet increased electricity demands or as a result of modifications 

45 to electricity distribution networks. However, no specific plans are known to exist for any such 

46 activities, so it is not possible to quantify the air impacts to the local airshed. Activities at the 

47 preexisting major sources of air pollution in the four-county area (see Section 3.5.3.2) are not 
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1 expected to be affected by the construction and operation of the proposed EREF, and extant 

2 emissions of criteria pollutants from those major sources are expected to remain unchanged. 

3 

4 To provide electrical power to the proposed EREF, RMP proposes to build a 161-kV 

5 transmission line as discussed earlier in Section 2.1.3.2. Air quality impacts associated with 

6 construction of this transmission line would include the release of criteria pollutants from the 

7 operation of reciprocating internal combustion engines of the construction vehicles and 

8 equipment, the delivery trucks that bring components to the job site, and the vehicles used by 

9 the construction workforce to commute to and from the job site (AES, 2010a). Fugitive dust 

10 would be created during construction of access roads, vegetation clearing of the proposed 

11 transmission line ROW and ground clearing and/or grading to create equipment laydown areas 

12 and staging areas for cranes and conductor pulling/tensioning equipment, and ground clearing 

13 and excavations associated with constructing foundations for the support towers. Similar 

14 impacts would occur during construction of new or modified substations. Some additional 

15 criteria pollutant emissions and fugitive dust would be associated with ancillary activities such as 

16 production of concrete for foundations. During operation, air impacts would result from vehicles 

17 traveling to and within the ROW for regular inspections, repairs, and occasional component 

18 replacements and from corona discharges from the conductors that would produce negligible 

19 amounts of ozone and nitrogen oxides (AES, 2010a). 

20 

21 According to AES (2010a), critical aspects of the planned construction from an air quality 

22 perspective include: a relatively small workforce (6–8 persons), a relatively short construction 

23 time frame (4 months for the proposed transmission line, 6 months to complete construction of 

24 the proposed Twin Buttes Substation and necessary upgrades to the Bonneville Substation), the 

25 relatively short commute of the workforce (from a hotel in Idaho Falls, a distance of 25 miles or 

26 less to any point along the proposed route or to a substation location), foundations for towers 

27 constructed with minimal ground surface disturbance (augered holes, backfilled with excavated 

28 materials and without concrete) (AES, 2010a). Also, RMP has proposed the use of mitigative 

29 measures such as watering the disturbed ground in construction areas and the unpaved access 

30 roads to reduce fugitive dust generation. Finally, except for one new unpaved 500-foot 

31 (152.4-meter) access road, existing paved roads and construction roads on the proposed EREF 

32 property would provide sufficient access to the ROW. Given the topography of the proposed 

33 route, the amount of grade alteration that would be required to create level areas for staging of 

34 cranes and conductor pulling/tensioning equipment is expected to be minimal. All of the 

35 scheduled construction activities that would result in air impacts are of relatively modest 

36 proportion and limited duration. Further, many of the air impacting activities typically associated 

37 with transmission line construction such as access road construction would occur to a very 

38 limited extent. The NRC staff concludes, therefore, that the air impacts from construction of the 

39 proposed transmission line would be of short duration and would be SMALL. 

40 

41 According to AES (2010a), during operation the proposed transmission line would undergo 

42 scheduled visual inspection once every two years with inspectors traveling from Shelly, Idaho, 

43 eight miles southwest of Idaho Falls. Maintenance actions would also result in the release of 

44 criteria pollutants and fugitive dust resulting from vehicle travel on access roads and within the 

45 ROW. Pole inspections would occur on a 10-year interval (AES, 2010a). It is reasonable to 

46 assume that pole replacements (similar in air impacts to initial construction) would occur only 

47 rarely, when found to be necessary. Given the nominal voltage of the line (161 kV), corona 

48 discharges that would result in the formation of ozone and nitrogen oxides would be negligible. 
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1 The NRC staff concludes that air impacts associated with operation of the proposed 

2 transmission line would be SMALL. 

3 

4 The NRC staff concludes that cumulative impacts to air quality from the construction and 

5 operation of the proposed EREF and from construction and operation of the proposed 

6 transmission line serving the proposed site would be SMALL. 

7 

8 4.3.5 Geology and Soils 

9 

10 The proposed EREF site is located in a region predominantly used for irrigated crops and 

11 grazing. Contamination of soils and the underlying aquifer have been reported at the INL site, 

12 just to the northwest of the proposed site (EPA, 2009c). Other sources of contamination in the 

13 region include animal feedlots, land applications (fertilizer, pesticide, wastewater, and sludge), 

14 storage tanks, waste tailings, landfills, and industrial facilities. Excessive irrigation in the region 

15 increases the potential for soil contaminant leaching and runoff (Shumar et al., 2007). Because 

16 of these concerns, the U.S. Department of Agriculture and the State of Idaho have partnered to 

17 create the Conservation Reserve Enhancement Program (CREP) to provide incentives to 

18 farmers who volunteer to take cropland and marginal pastureland out of agricultural production 

19 (USDA, 2006). 

20 

21 Potential soil contamination resulting from preconstruction, construction, and operation of the 

22 proposed EREF could be avoided or minimized by implementing BMPs and mitigation 

23 measures, such as those that would be described in the proposed facility’s SPCC Plan (to be 

24 prepared by AES). Mitigation measures would also be implemented during all project phases to 

25 minimize soil erosion and control fugitive dust (AES, 2010a). In addition, potentially 

26 contaminated runoff from the storage pads would discharge only to lined stormwater retention 

27 basins, and solids carried in process effluents from plant operations would remain within the 

28 Liquid Effluent Treatment System Evaporator (AES, 2010a). For these reasons, NRC staff 

29 concludes that the proposed EREF project’s contribution to cumulative impacts on soils would 

30 be SMALL. 

31 

32 For construction of the proposed 161-kV transmission line, soil impacts such as increased 

33 potential for erosion and compaction could result from soil-disturbing activities at pulling and 

34 tensioning sites, construction and staging yards, and structure sites, and along the new access 

35 road and substation construction site. Because soil impacts would occur primarily during the 

36 construction phase, they would be short in duration. Disturbance-related impacts could be 

37 avoided or minimized by implementing standard BMPs and mitigation measures, such as those 

38 that would be described in the proposed facility’s SPCC Plan. Mitigation measures would also 

39 be implemented during all project phases to minimize soil erosion and control fugitive dust 

40 (AES, 2010a). Limiting heavy equipment and vehicles to designated areas (roads and staging 

41 areas) would minimize the extent of soil compaction. For these reasons, the NRC staff 

42 concludes that the proposed transmission line project’s contribution to cumulative impacts on 

43 soils would be SMALL. 

44 

45 4.3.6 Water Resources 

46 

47 The ESRP aquifer is the source of water for the proposed EREF. Because it is the principal 

48 source of drinking water for southeastern and south-central Idaho, the ESRP aquifer was 
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1 designated as a sole source aquifer in 1991 (EPA, 2009e). The IDEQ estimated that the ESRP 

2 aquifer contains as much as 1233 billion cubic meters (1 billion acre-feet) of water (IDEQ, 

3 2005). Use of the regional water supply is regulated by the IDWR through appropriations that 

4 are granted by water rights. Water rights permit their holders to divert public waters for 

5 beneficial uses (IDWR, 2010). 

6 

7 The proposed EREF would be expected to use about 837,000 cubic meters (221 million gallons) 

8 of water during its first 12 years (see Table 4-10) and an average of 24,900 cubic meters 

9 (6.6 million gallons) of water annually during years 13 through 30 (AES, 2009a). Based on 

10 these projections, the total water usage would be as high as 1.3 million cubic meters 

11 (340 million gallons or 1043 acre-feet) of ESRP aquifer waters over the 30-year life of the 

12 proposed facility, taking into account industrial usage during preconstruction, construction, and 

13 operations (AES, 2010a). This constitutes a very small portion, less than 1 percent, of the 

14 1233 billion cubic meters (1 billion acre-feet) of the ESRP aquifer reserves in the State of Idaho 

15 (IDEQ, 2006). Therefore, the NRC staff concludes that the proposed EREF project’s 

16 contribution to cumulative impacts on the region’s groundwater supply would be SMALL. 

17 

18 Portions of the ESRP aquifer have been contaminated, mainly as a result of the disposal 

19 operations at the INL site (Shumer et al., 2007; EPA, 2009c). Recent multilevel groundwater 

20 monitoring of INL wells conducted by the USGS INL project office indicates that contamination 

21 in the aquifer varies with depth and that wastewater constituents originating from INL (such as 

22 tritium and various VOCs) tend to sink to greater depths as groundwater moves to the 

23 southwest (downgradient). These data are consistent with models predicting that contaminants 

24 downgradient of the INL boundary are most concentrated in deeper zones of the aquifer, at 

25 depths beyond those of residential wells in southeastern Idaho (Roy Bartholomay as quoted in 

26 Lundquist, 2010). The vertical distribution of contaminants in the ESRP aquifer is attributed to 

27 variability in groundwater movement, which is influenced locally by geologic conditions and 

28 patterns of recharge (e.g., precipitation, wastewater returns, streamflow infiltration, irrigation 

29 infiltration, inflow from adjoining drainage basins, underflow from drainage basins, and 

30 groundwater upwelling) and discharge, including heavy pumpage for irrigation (Bartholomay and 

31 Twining, 2010). 

32 

33 Land applications of fertilizer and pesticides and excessive irrigation are the main causes of 

34 contamination in shallow aquifers, and present a future concern for the ESRP aquifer 

35 (Shumer et al., 2007). Potential groundwater contamination resulting from the operation of the 

36 proposed EREF could be avoided or minimized by implementing BMPs and mitigation 

37 measures, such as those that would be described in the proposed facility’s SPCC Plan. In 

38 addition, potentially contaminated runoff from the storage pads would discharge only to lined 

39 stormwater retention basins, and no process effluents would be discharged to the stormwater 

40 basins or into surface water (AES, 2010a). For these reasons, the NRC staff concludes that the 

41 proposed EREF project’s contribution to cumulative impacts on surface water and groundwater 

42 quality would be SMALL. 

43 

44 Impacts to water resources from construction of the proposed 161-kV transmission line would 

45 occur in areas where soil-disturbing activities would change natural drainage patterns or 

46 increase surface runoff (and sedimentation potential) offsite. (Poles are not likely to be installed 

47 deep enough to create conduits to groundwater.) Accidental releases of hazardous materials 

48 and wastes (such as those used in voltage transformers) could impact the quality of surface 
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1 water or groundwater. Because soil-disturbing activities would occur primarily during the 

2 construction phase, they would be short in duration. Water quality-related impacts could be 

3 avoided or minimized by implementing standard BMPs and mitigation measures, such as those 

4 that would be described in the proposed facility’s SPCC Plan. Mitigation measures also would 

5 be implemented during all project phases to minimize surface runoff and soil erosion and the 

6 potential for inadvertent spills or releases (AES, 2010a). For these reasons, the proposed 

7 transmission line’s contribution to cumulative impacts on water resources would be SMALL. 

8 

9 4.3.7 Ecology 

10 

11 Past and ongoing impacts to sagebrush steppe, the predominant community type in the Eastern 

12 Snake River Basalt Plains ecoregion, and wildlife have resulted primarily from habitat losses, 

13 such as from agriculture, fragmentation, and decreases in habitat quality due to livestock 

14 grazing (Connelly et al., 2004; BLM/DOE, 2004; ISAC, 2006). Invasive species and changes in 

15 fire regimes have also impacted sagebrush steppe in the region. Large areas of sagebrush 

16 habitat have been replaced by non-native grasses, through range improvement efforts or by 

17 wildfires. All of these factors, as well as roadway construction, have contributed to 

18 fragmentation of sagebrush habitat within the ecoregion. Increasing fragmentation decreases 

19 the patch size of undisturbed habitat, increases edge area, and decreases habitat connectivity 

20 (NorthWestern Energy, 2008). Species that require large contiguous habitat areas may decline. 

21 Some sagebrush obligate bird species, for example, can show declines within 100 meters 

22 (328 feet) of roadways, and mule deer and elk are affected by the proximity of roads 

23 (NorthWestern Energy, 2008). 

24 

25 These land uses and associated impacts are expected to continue into the foreseeable future. 

26 Additional future losses of habitat may result from additional conversion to cropland or 

27 development. Impacts to habitat and wildlife in the region could result from the construction of 

28 the Mountain States Transmission Intertie. An alternative route of that transmission line would 

29 be located adjacent to the proposed EREF property (MDEQ, 2010). The proposed action would 

30 contribute a loss of approximately 75 hectares (185 acres) to the cumulative impacts on 

31 sagebrush steppe habitat (AES, 2010a). This area represents approximately 0.7 percent of the 

32 sagebrush steppe within 8 kilometers (5 miles) and 0.2 percent within 16 kilometers (10 miles), 

33 and would result in a minor contribution to losses of sagebrush habitat within the area and 

34 ecoregion. The contribution to habitat fragmentation would be small due to the location of the 

35 proposed facility adjacent to previously disturbed nonirrigated pasture and cropland. Greater 

36 sage-grouse (Centrocercus urophasianus), a sagebrush obligate species and a candidate for 

37 Federal listing, have experienced severe long-term population declines in Idaho and throughout 

38 their range. These declines have been due in large part to the loss, degradation, and 

39 fragmentation of sagebrush habitat (Connelly et al., 2004; BLM/DOE, 2004; 

40 ISAC, 2006). Throughout the region, sagebrush communities have been converted to farmland 

41 and grasslands and have been lost or severely degraded by wildfires (Connelly et al., 2004; 

42 BLM/DOE, 2004; ISAC, 2006). As noted in Section 3.8, approximately 98 percent of the BLM 

43 Upper Snake Field Office Planning Area, which includes the proposed EREF property, is 

44 sagebrush steppe. Approximately 20,725 hectares (51,213 acres) of cultivated cropland and 

45 3892 hectares (9617 acres) of recently burned grassland and introduced annual grasses occur 

46 within 16 kilometers (10 miles) of the proposed EREF (Landscape Dynamics Lab, 2009). Based 

47 on surrounding areas, these, along with other disturbed areas, likely represent losses of what 

48 had been mostly sage-grouse habitat. As discussed in Section 4.2.7, the proposed action 
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1 would result in a minor contribution to losses and fragmentation of sagebrush habitat within the 

2 area and ecoregion. Sage-grouse would also likely avoid areas near the proposed facility 

3 during construction and operations, creating a somewhat larger area of effective loss of habitat. 

4 This loss would be a small incremental addition to the cumulative impacts on sage-grouse 

5 habitat within the 16-kilometer (10-mile) area and within the ecoregion, and would continue 

6 throughout the license period and potentially beyond, depending on post-decommissioning use 

7 of the site. Therefore, the contribution to cumulative impacts from the proposed EREF project 

8 on sage-grouse and other ecological resources would be SMALL. 

9 

10 For construction of the proposed 161-kV transmission line, vegetation would be cut where 

11 necessary for equipment operation at work areas for pole locations and pulling and tensioning 

12 sites. Pole location work areas would be 1444 square meters (15,625 square feet) in area; 

13 pulling and tensioning site work areas would be 7442 square meters (80,000 square feet) or 

14 5978 square meters (64,000 square feet) in area (AES, 2010a). At some pulling and tensioning 

15 sites, ground disturbance could occur within a 150-meter (500-foot) radius (AES, 2010a). 

16 Disturbed soil in work areas would be graded to blend with natural contours and reseeded as 

17 necessary (AES, 2010a). One new access road, a 2-track dirt road, would be constructed on 

18 the east side of the proposed EREF site. Larger shrubs within the ROW or access roads would 

19 be cut to allow equipment access, while shorter shrubs would be driven over. 

20 

21 Vegetation types within a 91-meter (300-foot) wide corridor surveyed for the proposed 

22 transmission line route are similar to those of the proposed EREF site and include 48 hectares 

23 (118 acres) of sagebrush steppe, 155 hectares (382 acres) of irrigated cropland, and small 

24 areas of nonirrigated pasture planted with crested wheatgrass (AES, 2010a). Approximately 

25 3.2 hectares (7.9 acres) of sagebrush steppe habitat would be permanently removed for access 

26 road and structure locations. Most of the sagebrush steppe within the corridor occurs within the 

27 existing ROW between the Bonneville and Kettle Substations. This habitat has been previously 

28 fragmented by the existing 69-kV transmission line and access roads. Expansion of the 

29 Bonneville Substation would primarily affect cropland. The location of the new Twin Buttes 

30 Substation on the proposed EREF site would be cleared and graded during EREF 

31 preconstruction. The loss of 3.2 hectares (7.9 acres) of sagebrush steppe habitat would 

32 contribute incrementally to the loss of this habitat type in the region, including the loss of 

33 75 hectares (185 acres) associated with construction of the proposed EREF, and would result in 

34 a small contribution to cumulative impacts on this habitat type. 

35 

36 Indirect effects on sagebrush steppe habitat of transmission line construction and operation 

37 could also include erosion, sedimentation, spread of invasive species, reduction in habitat 

38 quality, and habitat fragmentation. Populations of sagebrush steppe species that are cut or 

39 crushed by heavy equipment in work areas, such as at pulling and tensioning sites, may require 

40 considerable periods of time to return to pre-disturbance levels, and some species may not 

41 recover. Some mortality of big sagebrush or other species would likely occur. In addition, 

42 non-native species occurring in the area or introduced to the sites could become established or 

43 expand into areas disturbed by construction activities. The habitat quality of these areas may 

44 subsequently be reduced. Invasive species, such as cheatgrass, can greatly change the fire 

45 regime, increasing the frequency and intensity of fires, adversely affecting native habitats such 

46 as sagebrush steppe. Transmission line ROWs can promote the spread of invasive species 

47 (BPA, 2000). Erosion of disturbed soils or from cut-over areas may contribute to reduction in 

48 sagebrush steppe habitat or habitat quality. Sedimentation from disturbed soils may degrade 
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1 habitat along drainages or in wetlands that occur downstream. Erosion and sedimentation 

2 impacts would be reduced, however, by planned mitigation measures. Although habitat 

3 fragmentation can occur as a result of transmission line construction, the sagebrush steppe 

4 along the proposed transmission line route would be predominantly included within an existing 

5 ROW or would be located adjacent to the proposed EREF. Small portions of the proposed 

6 transmission line route east of the proposed EREF would be located in undisturbed areas and 

7 would contribute to the fragmentation of sagebrush steppe habitat. These indirect impacts 

8 would result in a small contribution to cumulative impacts on native habitats within the region. 

9 

10 Impacts of transmission line construction and operation could also include wildlife disturbance 

11 and wildlife mortality. The proposed transmission line route includes potentially suitable habitat 

12 for sagebrush obligate species, including migratory bird species, although much of this habitat 

13 has been affected by the existing transmission line and access roads. These species could be 

14 affected by the permanent loss of 3.2 hectares (7.9 acres) of sagebrush steppe habitat and the 

15 temporary loss of habitat in work areas and reduction in habitat quality of disturbed areas of 

16 sagebrush steppe in work areas. No sage-grouse leks have been found in the immediate 

17 vicinity of the new transmission line route (North Wind, 2010). 

18 

19 Wildlife would also be disturbed by noise and human presence during the construction of the 

20 proposed transmission line and expansion of the Bonneville Substation. Migratory birds nesting 

21 in the vicinity of the transmission line construction could be affected if nest abandonment 

22 occurs. The new transmission line would be approximately 150 meters (490 feet) closer to the 

23 nearest sage-grouse lek, compared to the proposed EREF. As with EREF construction, 

24 however, noise levels associated with transmission line construction would not be expected to 

25 affect sage-grouse at the lek. These indirect impacts would result in a small contribution to 

26 cumulative impacts on wildlife populations within the region. 

27 

28 The construction of a new transmission line could contribute to avian mortality as a result of bird 

29 collisions with the power lines, and could affect migratory bird species. Sage-grouse and sharp30 tailed grouse, which are known to occur in the area, could be impacted due to the proximity of 

31 US 20 and movements between habitat north and south of the highway and proposed 

32 transmission line, or when migrating between seasonal use areas. While bald eagles, which 

33 nest along the Snake River, could potentially be affected by collisions with the transmission 

34 lines, such impacts are unlikely because of the distance from nesting and foraging areas. In 

35 addition, raptors, such as hawks and eagles, may perch on transmission line support structures, 

36 potentially resulting in mortality from electrocution. Ferruginous hawks, which nest in the region, 

37 could be also affected by the new transmission lines. However, RMP would implement design 

38 measures for the protection of raptors and other bird species, reducing potential impacts 

39 (AES, 2010a). Most of the proposed transmission line would be included within the existing 

40 69-kV transmission line ROW, with about 7.6 kilometers (4.75 miles) of new ROW between the 

41 Kettle Substation and the proposed Twin Buttes Substation. The number of birds affected by the 

42 new line within the existing ROW could be greater than those currently affected. Relatively few 

43 birds would be expected to be affected by the new line within the proposed 161-kV transmission 

44 line ROW, much of which would be located within or adjacent to the proposed EREF site. The 

45 contribution of the proposed new transmission line to cumulative impacts on bird populations in 

46 the ecoregion would be SMALL. 

47 
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1 Because support structures can provide perch sites for raptors and corvids (ravens and crows), 

2 construction of the proposed transmission line may increase predation by raptors and corvids in 

3 the area. Populations of prey species, such as sage-grouse or pygmy rabbits, which may occur 

4 in the area, could be impacted by increased predation. 

5 

6 4.3.8 Noise 

7 

8 With the exception of the construction of the proposed transmission line connecting the 

9 proposed EREF with the transmission grid operated by RMP, no major industrial facilities are 

10 expected to be constructed in the vicinity of the proposed EREF property. Noise impacts will 

11 occur from the construction of the proposed transmission line, but those impacts would be 

12 sporadic and SMALL. The noise impacts on the proposed EREF property associated with the 

13 continuing activities at INL would be SMALL. Cumulative impacts to noise from preconstruction, 

14 construction, and operation of the proposed EREF, from the construction and operation of the 

15 proposed transmission line that would serve the proposed EREF, and from activities at INL 

16 would be SMALL. 

17 

18 4.3.9 Transportation 

19 

20 The impacts of construction (including preconstruction activities) and operation of the proposed 

21 EREF due to increased traffic from commuting construction workers would be SMALL to 

22 MODERATE, although no highway upgrades would be required other than safety 

23 enhancements on US 20 such as the construction of turning/acceleration/deceleration or a 

24 grade-separated interchange for entry to and exit from the proposed EREF. As noted in the 

25 introduction to Section 4.3, there are no planned or proposed/future actions the vicinity of the 

26 proposed EREF that would contribute to cumulative transportation impacts (i.e., affect traffic 

27 levels. Current activities that would contribute to cumulative transportation impacts include the 

28 shipment of radioactive materials from INL to Idaho Falls along US 20 (approximately 

29 25–40 shipments per month) (INL, 2010). Because the INL shipments comprise less than 

30 2 percent of current traffic flow on US 20 in the vicinity of the proposed EREF and the 

31 population density along this route is low, the cumulative effects on transportation would be 

32 SMALL. 

33 

34 Construction and maintenance of the proposed 161-kV transmission line and the substation 

35 work would require access to the ROW from US 20. Traffic volume could increase along US 20, 

36 and slowing or accelerating construction and maintenance vehicles could result in intermittent 

37 disruption of high-speed traffic flow (see Section 3.10.1). However, only two access points from 

38 US 20 are anticipated (both of which currently exist near the proposed EREF site); the 

39 remaining access points are from an adjacent county road. Less than 10 vehicles would be 

40 used at any one time during construction of the proposed transmission line and new substation 

41 (AES, 2010a), and large construction equipment would not likely travel to and from work sites 

42 on a daily basis during construction period. The additional number of daily vehicle-trips 

43 resulting from these activities would represent less than 2 percent of the anticipated peak 

44 increase in daily traffic to and from the proposed EREF site during preconstruction and 

45 construction (see Section 4.2.9.1). In addition, this impact would occur during the construction 

46 phase of the proposed EREF and would be short in duration. The NRC staff concludes that 

47 transportation impacts associated with transmission line construction and operation would be 

48 SMALL. 
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1 4.3.10 Public and Occupational Health 

2 

3 Public and occupational health impacts that might contribute to cumulative impacts would be 

4 associated with the construction and operation of the proposed 161-kV transmission line that 

5 would serve the proposed EREF. It is estimated that 30 workers would complete the 

6 construction of the proposed transmission line within one year (AES, 2010a). This level of effort 

7 represents less than 1 percent of the total FTE-years estimated to construct the proposed 

8 facility (see Table 4-14). Maintenance of the line and ROW during its operational life would add 

9 minimally to already small occupational injury rates for operating the proposed EREF 

10 (see Table 4-15). Since the public and occupational impacts of facility construction and 

11 operation would be SMALL, the small incremental addition of the transmission line construction 

12 and operation would only negligibly contribute to cumulative impacts. 

13 

14 With regard to cumulative impacts from fluoride emissions during facility operation, there are 

15 currently very low levels of exposure to the public from industrial chemical emissions in the 

16 region surrounding the proposed facility in general and no other known or anticipated sources of 

17 fluoride emissions. Thus cumulative effects on the public of the minor HF emissions expected 

18 from the proposed facility in combination with other chemical emissions in the region would be 

19 SMALL. 

20 

21 The annual collective population dose from operations was estimated to be approximately 

1.7  10-5 person-sievert (1.7  10-3 22 person-rem) in Section 4.2.10.2. Such a dose is so low that 

23 it cannot be monitored, as is the case for the annual collective population dose from operations 

24 at the nearby INL, as discussed in Section 3.11.1. Exposure of individuals that may be near the 

25 proposed EREF property boundary would also be low. Thus, cumulative impacts to the public 

26 from radiological sources at the proposed EREF and other nearby sources would be SMALL. 

27 

28 4.3.11 Waste Management 

29 

30 As shown in Section 4.2.11, the impact of disposal of hazardous, nonhazardous solid, and solid 

31 low-level radioactive wastes from the proposed EREF at the appropriate facilities would be 

32 SMALL given past and present conditions. Based on available capacities at low-level 

33 radioactive and hazardous waste treatment and disposal sites, in conjunction with the 

34 expectation that there will be no large developments in the Idaho Falls area that would cause a 

35 significant increase in municipal waste disposal volume, the cumulative impacts from hazardous 

36 and solid waste generation would be SMALL.

37 

38 Nonhazardous and sanitary wastes would be generated during construction and maintenance of 

39 the proposed 161-kV transmission line and the new and upgraded substations. Nonhazardous 

40 construction wastes (including debris from the dismantled 69-kV transmission line) would be 

41 recycled or transported to an approved landfill such as the Bonneville County Hatch Pit 

42 (see Section 4.2.11.1). Sanitary waste would be collected locally in portable systems. The 

43 generation of hazardous waste is not anticipated, but hazardous materials that are typical of a 

44 high-voltage application (including oil in transformers, sulfuric acid in batteries, diesel fuel in 

45 generators, and sulfur hexafluoride gas in circuit breakers) would be used and could require 

46 disposal at an approved disposal facility (AES, 2010a). Because the number and volume of 

47 waste shipments from construction of the proposed transmission line and new substation would 

48 represent less than 1 percent of those from preconstruction and construction of the proposed 
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1 EREF, the NRC staff concludes that the cumulative waste management impacts of transmission 

2 line construction and operation would be SMALL. 

3 

4 4.3.12 Socioeconomics 

5 

6 A number of other development projects have been proposed for the two-county ROI that could 

7 produce cumulative socioeconomic impacts in association with the proposed EREF, depending 

8 upon project scope and development schedules of the additional projects. (Note: These 

9 projects are all located within the 80.5-kilometer [50-mile] radius ROI for socioeconomics, but, 

10 with the exception of the proposed EREF transmission line, outside the 16-kilometer [10-mile] 

11 ROI for all other environmental resources.) The construction of the proposed 13.75-mile, 

12 161-kv transmission line to support the proposed EREF would produce 57 jobs and produce 

13 $2.8 million in income, $0.1 million in direct sales taxes, and $0.1 million in direct income taxes 

14 in the region including Bingham and Bonneville Counties (AES, 2010a). Jobs, income, and tax 

15 revenues produced during transmission line operations would be small. In Bonneville County, 

16 additional developments could include the Snake River Landing planned community, the Taylor 

17 Crossing planned community, The Narrows mixed-use office/residential development, the 

18 Central Valley development, the McNeil Development that includes a Marriott Hotel and 

19 condominiums, the Sleep Inn Hotel, and the West Broadway soccer complex presently under 

20 construction (AES, 2009a). In Bingham County, planned developments would include the 

21 construction of a 150-unit wind power development (AES, 2009a). 

22 

23 These projects would provide additional employment opportunities for construction workers and 

24 would increase the economic activity in the region. Depending upon the timing of construction 

25 and operation of each of these projects, however, there could be a number of negative impacts. 

26 Although competition for the hiring of construction and operations workers may lead to wage 

27 inflation in the area, the size of the regional labor force is likely large enough to prevent this 

28 being a major issue. The development of additional projects would also lead to long-term 

29 employment opportunities and might result in in-migration into the area. Depending on the 

30 timing of construction for these projects and the type and quantity of construction materials 

31 needed, there could be supply shortages of some materials, leading to price increases. 

32 However, the magnitude of these impacts would likely be SMALL. Given all these 

33 considerations, the cumulative socioeconomic impacts of the proposed EREF project would be 

34 SMALL. 

35 

36 4.3.13 Environmental Justice 

37 

38 Minority and low-income populations occur within a 4-mile radius of the proposed EREF site 

39 (see Section 3.13) and within a two-mile buffer either side of the proposed 13.75-mile 

40 transmission line ROW that would be constructed to support the proposed EREF (Table 4-38). 

41 However, none of the Census block groups associated with the proposed EREF or the 

42 proposed transmission line route have minority or low-income populations that exceed county or 

43 State averages by more than 20 percentage points, or exceed 50 percent of total block group 

44 population. Preconstruction, construction, and operation of the proposed EREF and 

45 construction and operation of the associated transmission line would not produce high and 

46 adverse impacts to the general population, and so would not disproportionately impact minority 

47 and low-income populations. Accordingly, the cumulative impacts on minority and low-income 

48 populations would be SMALL. 
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Table 4-38 Minority and Low-Income 

Populations within the 2-mi (3.2-km) Buffer 

Associated with the Proposed 

Transmission Line 

Parameter 

Total population 1777 

White, non-Hispanic 1470 

Hispanic or Latino 266 

Non-Hispanic or Latino minorities 41 

 One race 22 

 Black or African American 6 

 American Indian or Alaskan Native 2 

 Asian 13 

 Native Hawaiian or other Pacific Islander 1 

 Some other race 0 

 Two or more races 19 

Total minority 307 

Low-income 178 

Percent minority 17.3 

County percent minority 10.5 

State percent minority 9.0 

Percent low-income 10.2 

County percent low-income 10.1 

State percent low-income 11.8 

Source: U.S. Census Bureau (2010).

2 

3 Although minority and low-income populations occur in the vicinity of the proposed EREF site 

4 (see Section 3.13), construction and operation of the proposed EREF would not affect such 

5 populations. Accordingly, the cumulative impacts on environmental justice populations would 

6 be SMALL. 

7 

8 4.4 Impacts of the No-Action Alternative 

9 

10 As presented in Section 2.2 of this EIS, the no-action alternative would be to not construct, 

11 operate, and decommission the proposed EREF in Bonneville County, Idaho. As discussed in 

12 the introduction to Section 4.2, the NRC has granted an exemption for AES to conduct certain 

13 preconstruction activities in advance of a formal licensing decision. If the NRC does not grant a 

14 construction and operating license for the proposed EREF, some or all of the preconstruction 

15 activities granted under the exemption approval (NRC, 2010a) are expected to have already 
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1 occurred. It follows that the impacts associated with these preconstruction activities, as 

2 described in Section 4.2, will also have occurred. There may be additional activities occurring at 

3 the proposed site in the future under the no-action alternative that may have adverse or 

4 beneficial impacts on the environment. The impacts associated with these activities would 

5 depend on what AES would decide to do with the proposed site or any improvements 

6 (e.g., access roads) already constructed on the site. The impact conclusions presented in this 

7 section for the no-action alternative address the impacts of denying the license, but do not 

8 include the impacts of the NRC-approved preconstruction activities, some or all of which are 

9 expected to have already occurred. 

10 

11 Under the no-action alternative, nuclear electricity generation customers would continue to 

12 depend on existing suppliers (i.e., existing uranium enrichment facilities, foreign sources, and 

13 the Megatons to Megawatts Program) to fulfill uranium enrichment needs. In addition, three 

14 future domestic sources of enriched uranium are planned – two of which are currently under 

15 construction (American Centrifuge Plant [ACP] and NEF) and the third is planned and seeking a 

16 license from the NRC (GLE Facility). Current U.S. demand for low-enriched uranium is about 

17 12 to 14 million SWU annually (EIA, 2009). USEC is currently the only domestic supplier of 

18 enrichment services, providing enriched uranium to both domestic and foreign users. Existing 

19 USEC enrichment activities include operation of the Paducah Gaseous Diffusion Plant (GDP), 

20 the downblending of highly enriched uranium under the Megatons to Megawatts Program that is 

21 managed by USEC and scheduled to expire in 2013, and the import of foreign-enriched product. 

22 By combining its domestic enrichment facilities and the downblending of foreign highly enriched 

23 uranium, USEC can provide for approximately 56 percent of the U.S. enrichment market needs 

24 (USEC, 2004) while foreign suppliers provide the remaining 44 percent. 

25 

26 Under the no-action alternative, the Paducah GDP, including the Megaton to Megawatts 

27 Program, would serve as the only domestic source of low-enriched uranium. Reliance on one 

28 domestic source for enrichment services could result in disruptions to the supply of low-enriched 

29 uranium, and consequently to reliable operation of U.S. nuclear energy production, should there 

30 be any disruptions to foreign supplies and/or the operations of domestic suppliers (i.e., if the 

31 ACP, NEF, or GLE Facility would not be constructed and operated and the Megatons to 

32 Megawatts Program would not be extended beyond 2013). 

33 

34 If the license application for the proposed EREF is not granted, nuclear electricity generation 

35 using enriched uranium from the proposed EREF could be replaced with other power generation 

36 sources (e.g., fossil-fuel plants), which would present of range of impacts that are outside the 

37 scope of this EIS. Alternatively, enriched uranium could be provided by sources constructed at 

38 other locations. Therefore, impacts similar to those quantified in this EIS would simply occur at 

39 a different location. Should another domestic enrichment facility be constructed at an alternate 

40 location, environmental impacts would occur and could range from SMALL to LARGE. These 

41 impacts could be similar to those of the proposed action, but would depend on various factors, 

42 e.g., the type of facility and the affected environment at the alternate location. 

43 

44 The site-specific impacts of the no-action alternative for each resource area are discussed in the 

45 following sections. 

46 

47 
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1 4.4.1 Land Use 

2 

3 Under the no-action alternative, AES would purchase the property and restrictions on grazing 

4 and agriculture would occur. The zoning designation for the property would remain G-1 Grazing 

5 whether or not the proposed EREF is constructed. Current land uses of grazing and farming 

6 could potentially resume. Impacts to local land use would be SMALL. 

7 

8 4.4.2 Historic and Cultural Resources 

9 

10 Under the no-action alternative, the proposed EREF would not be constructed. No visual 

11 effects or noise would affect the Wasden Complex. Nevertheless, it is assumed that AES would 

12 purchase the property and undertake preconstruction activities that would destroy site MW004. 

13 However, site MW004 would not be affected by the Federal (NRC) licensing action and the 

14 NHPA would not apply. However, the removal of site MW004, which has already occurred, 

15 resulted in a LARGE impact because the site no longer exists; but because AES removed this 

16 site through professional excavation and data recovery and there are other homestead sites of 

17 this type found in the region, the impact has been mitigated to a MODERATE level (WCRM, 

18 2010; Idaho SHPO, 2010b; Gilbert, 2010). The impact on historic and cultural resources would 

19 be SMALL to MODERATE under the no-action alternative. 

20 

21 4.4.3 Visual and Scenic Resources 

22 

23 Under the no-action alternative, impacts to visual and scenic resources would be SMALL. The 

24 proposed EREF would not be constructed. AES would purchase the property and clear the 

25 vegetation; however, these activities are not expected to alter the viewshed. No major visual 

26 intrusions to the existing landscape would occur because no large industrial structures would be 

27 constructed. The existing natural character of the area would largely remain intact. The lack of 

28 development would be consistent with the BLM VRM Class 1 designation for the Hell’s Half 

29 Acre WSA. No visual intrusions to the Wasden Complex viewshed would occur. 

30 

31 4.4.4 Air Quality 

32 

33 Under the no-action alternative, the air quality impacts associated with the construction, 

34 operation, and decommissioning of the proposed EREF would not occur. The proposed site 

35 could revert to agricultural activities, which would impact ambient air quality through the release 

36 of criteria pollutants from the operation of agricultural vehicles and equipment and the release of 

37 fugitive dust from the tilling of soils. Those impacts are expected to be substantially less than 

38 impacts resulting from preconstruction and the proposed action. The NRC staff concludes that 

39 local air impacts associated with the no-action alternative would be SMALL. 

40 

41 4.4.5 Geology and Soils 

42 

43 Under the no-action alternative, no additional land disturbance from construction would occur 

44 and the land on the proposed EREF site could revert to crop and grazing activities. Wind and 

45 water erosion would continue to be the most significant natural processes affecting the geology 

46 and soils at the proposed site. Impacts to geology and soils would therefore be expected to be 

47 SMALL. 

48 

49 
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1 4.4.6 Water Resources 

2 

3 Under the no-action alternative, additional water use may or may not occur, depending on future 

4 plans for the property. Water resources would be unchanged. Water usage could continue at 

5 the current rate, should agricultural activities resume at the proposed site, and impacts on the 

6 ESRP aquifer and downgradient water users would be SMALL. No changes to surface water 

7 quality would be expected, and the natural (intermittent) surface flow of stormwater on the 

8 proposed site would continue. No additional groundwater use or adverse changes to 

9 groundwater quality would be expected. Impacts therefore would be SMALL. 

10 

11 4.4.7 Ecological Resources 

12 

13 Most impacts on ecological resources would occur during the preconstruction phase. However, 

14 such impacts would also occur under the proposed action. The potential impacts associated 

15 with the construction, operation, and decommissioning of the proposed EREF would not occur. 

16 The land on the proposed EREF site could revert to crop and grazing activities. Denying the 

17 license would not result in additional land disturbance on the proposed EREF property. 

18 Revegetation of the site could occur with renewal of some wildlife habitat. Anticipated impacts 

19 on ecological resources from the no-action alternative would be SMALL. 

20 

21 4.4.8 Noise 

22 

23 Under the no-action alternative, none of the noise impacts associated with construction, 

24 operation, and decommissioning at the proposed EREF would occur. Land uses on the 

25 proposed EREF site could revert to previous applications, livestock grazing and/or crop 

26 production, with concomitant noise impacts. Impacts would be SMALL. 

27 

28 4.4.9 Transportation 

29 

30 Under the no-action alternative, traffic volumes and patterns would remain the same as 

31 described in the affected environment section. The current volume of radioactive material and 

32 chemical shipments to/from facilities other than the proposed EREF would not increase. 

33 Transportation impacts would be SMALL. 

34 

35 4.4.10 Public and Occupational Health 

36 

37 Under the no-action alternative, public and occupational health impacts would be SMALL. 

38 Occupational health impacts from construction, operation, and decommissioning would not 

39 occur. Associated worker and public impacts from chemical and radioactive hazards would also 

40 not occur. Should the land be returned to grazing and agriculture, the impacts would be 

41 SMALL. 

42 

43 4.4.11 Waste Management 

44 

45 Under the no-action alternative, since construction, operation, and decommissioning of the 

46 proposed EREF would not occur, new wastes including sanitary, hazardous, low-level 

47 radioactive, or mixed wastes would not be generated that would require disposition. Impacts 

48 from waste management would be SMALL. 
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1 4.4.12 Socioeconomics 

2 

3 Under the no-action alternative, any positive or adverse consequences of the construction, 

4 operation, and decommissioning of the proposed EREF would not occur and socioeconomic 

5 conditions in the ROI would remain unchanged. As a result, the impact of no action on social 

6 and economic conditions in the region would be SMALL. 

7 

8 Population in the area surrounding the proposed EREF, Bingham and Bonneville Counties, is 

9 expected to grow in accordance with current projections, with total population in the region 

10 projected to be approximately 156,491 in 2013 and 168,331 in 2017 (AES, 2010a). In addition 

11 to population growth, the social characteristics of the region, including housing availability, 

12 school enrollment, availability of health service resources, and law enforcement and firefighting 

13 resources, are expected to change over time. However, future changes in these characteristics 

14 are difficult to quantify, and no projections of their future growth are available. 

15 

16 4.4.13 Environmental Justice 

17 

18 The no-action alternative would not be expected to cause any high and adverse impacts; it 

19 should not raise any environmental justice issues. Therefore, any impacts would be SMALL. 

20 

21 4.4.14 Accidents 

22 

23 There would be no facility accidents during operation if the proposed EREF is not constructed. 

24 Therefore, impacts would be SMALL. 

25 

26 4.5 References 

27 

28 (AES, 2009a) AREVA Enrichment Services, LLC. Letter from Sam Shakir (President and CEO, 

29 AES) to the U.S. Nuclear Regulatory Commission dated June 17, 2009. “Subject: Request for 

30 Exemption from 10 CFR 70.4, 10 CFR 70.23(a)(7), 10 CFR 30.4, 10 CFR 30.33(a)(5), 

31 10 CFR 40.4, and 10 CFR 40.32(e) Requirements Governing ‘Commencement of 

32 Construction.’” ADAMS Accession No. ML091770390. 

33 

34 (AES, 2009b) AREVA Enrichment Services, LLC. Letter from Jim Kay (Licensing Manager, 

35 AES) to the U.S. Nuclear Regulatory Commission dated September 9, 2009. “Subject: 

36 Response to Requests for Additional Information – AREVA Enrichment Services LLC 

37 Environmental Report for the Eagle Rock Enrichment Facility.” AES-O-NRC-09-01234-0. 

38 ADAMS Accession No. ML092530636. 

39 

40 (AES, 2010a) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

41 Environmental Report, Rev. 2.” Bethesda, Maryland. April. 

42 

43 (AES, 2010b) AREVA Enrichment Services, LLC. “Final Safety Analysis Report, Rev. 2.” 

44 Bethesda, Maryland. 

45 

46 (AES, 2010c) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility Integrated 

47 Safety Analysis.” Revision 2. 

48 
 4-165 

1 (AES, 2010d) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility Emergency 

2 Plan.” Revision 2. 

3 

4 (AES, 2010e) AREVA Enrichment Services, LLC. Letter from J.A. Kay (Licensing Manager, 

5 AES) to U.S. Nuclear Regulatory Commission dated February 19, 2010. “Subject: Treatment 

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 5-1 

1 5 MITIGATION 

2 

3 This chapter identifies possible measures to mitigate potential environmental impacts from 

4 preconstruction and the proposed action, as required by Appendix A of Title 10, “Energy,” 

5 Part 51, of the U.S. Code of Federal Regulations (CFR) (10 CFR Part 51). Under Council on 

6 Environmental Quality (CEQ) regulation 40 CFR 1500.2(f), Federal agencies shall, to the fullest 

7 extent possible, “use all practicable means consistent with the requirements of the National 

8 Environmental Policy Act and other essential considerations of national policy to restore and 

9 enhance the quality of the human environment and avoid or minimize any possible adverse 

10 effects of their actions on the quality of the human environment.” The CEQ regulations define 

11 mitigation to include activities that (1) avoid the impact altogether by not taking a certain action 

12 or parts of an action; (2) minimize impacts by limiting the degree or magnitude of the action and 

13 its implementation; (3) repair, rehabilitate, or restore the affected environment; (4) reduce or 

14 eliminate impacts over time by preservation or maintenance operations during the life of the 

15 action; or (5) compensate for the impact by replacing or substituting resources or environments 

16 (40 CFR 1508.20). This definition has been used in identifying potential mitigation measures. 

17 As such, mitigation measures are those actions or processes (e.g., process controls and 

18 management plans) that would be implemented to control and minimize potential impacts 

19 associated with the proposed Eagle Rock Enrichment Facility (EREF). 

20 

21 AREVA Enrichment Services, LLC (AES) must comply with applicable laws and regulations, 

22 including obtaining all appropriate construction and operating permits. A complete discussion of 

23 applicable laws and regulations is included in Chapter 1 of this Environmental Impact Statement 

24 (EIS). The mitigation measures identified by AES (AES, 2010a), many of which are compliance 

25 related, are discussed in Section 5.1. Further, based on the potential impacts identified in 

26 Chapter 4 (Environmental Impacts) of this EIS, the U.S. Nuclear Regulatory Commission (NRC) 

27 staff has identified additional potential mitigation measures for impacts of the proposed EREF 

28 project. These measures are described in Section 5.2. 

29 

30 The mitigation measures identified in this chapter do not include environmental monitoring 

31 activities. Environmental monitoring activities are described in Chapter 6 of this EIS. 

32 

33 5.1 Mitigation Measures Identified by AES 

34 

35 Tables 5-1 and 5-2 summarize those mitigation measures that were identified in AES’s 

36 Environmental Report (ER) for the proposed EREF (AES, 2010a) as applicable to the 

37 preconstruction/construction and operations phases, respectively. The information in 

38 Tables 5-1 and 5-2 is taken largely from the ER. These mitigation measures were identified by 

39 AES to reduce the potential environmental impacts of preconstruction and the proposed action. 

40 AES did not identify mitigation measures for socioeconomics or environmental justice for either 

41 construction or operations because the socioeconomic impacts of the proposed project are 

42 mostly positive and the proposed project will result in no disproportionately high impacts on low43 income and minority populations (see Sections 4.2.12 and 4.2.13). Additional mitigation 

44 measures may be considered by AES as a result of AES’s consultations and/or permitting 

45 activities with Federal, State, and local regulatory agencies other than the NRC. 

46 
 5-2 

Table 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction and 

Construction Environmental Impacts 

Impact Area Activity Mitigation Measures 

Land Use Land 

disturbance 

Use the following best management practices (BMPs) to 

mitigate short-term increases in soil erosion and fugitive dust 

(additional discussion is provided below under Geology and 

Soils): 

• minimize the construction footprint to the extent practicable 

• limit site slopes to a horizontal-vertical ratio of four to one, or 

less 

• use a sedimentation detention basin 

• protect undisturbed areas with silt fencing and straw bales, 

as appropriate 

• use site stabilization practices such as placing crushed stone 

on disturbed soil in areas of concentrated runoff 

• water onsite construction roads at least twice daily, when 

needed, to control fugitive dust emissions 

• after construction is complete, stabilize the site with natural 

low-water consumption, low-maintenance landscaping, and 

pavement 

Historic and 

Cultural 

Resources 

Disturbance of 

prehistoric 

archaeological 

sites and sites 

eligible for listing 

on the National 

Register of 

Historic Places

Educate workers on the regulations governing cultural 

resources, stressing that unauthorized collecting is prohibited. 

Use onsite cultural resource monitors during construction 

activities. 

Implement procedures to address unexpected discoveries of 

human remains or previously unidentified archaeological 

materials during ground-disturbing activities and procedures for 

the evaluation and treatment of these resources. 

Cease construction activities in the area around any discovery 

of human remains or other item of archaeological significance 

and notify the State Historic Preservation Officer to make the 

determination of appropriate measures to identify, evaluate, 

and treat the discoveries. 

Treatment/mitigation plan for site MW004 (recommended 

eligible for inclusion in the National Register of Historic Places) 

to recover significant information on that site (professional 

excavation and data recovery have been conducted). 1 
 5-3 

Table 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction and 

Construction Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Visual and 

Scenic 

Resources 

Potential visual 

intrusions in the 

existing 

landscape 

character 

Use accepted natural, low-water-consumption landscaping 

techniques to limit any potential visual impacts. Such 

techniques will incorporate, but not be limited to, the use of 

native landscape plantings and crushed stone pavements on 

difficult-to-reclaim areas. 

Use prompt revegetation or covering of bare areas with natural 

materials. 

Paint the proposed facility in colors that would blend with the 

surrounding vegetation to reduce the contrast between the 

proposed EREF plant and the surrounding landscape. 

Create earthen berms or other types of visual screens made of 

other natural material to help reduce the visibility of the 

proposed facility. 

Focus all perimeter lights to be downfacing to minimize light 

pollution. 

Air Quality Fugitive dust 

and pointsource releases 

of criteria 

pollutants 

Apply construction BMPs to minimize fugitive dust, including: 

• apply water twice daily (when needed) to unpaved onsite 

roads, excavation areas, and clearing and grading areas 

• use alternative dust palliatives (inorganic salts, asphaltic 

products, synthetic organics) 

• establish and enforce speed limits for onsite roads 

• suspend certain dust-producing activities during windy 

conditions 

• apply gravel to the unpaved surfaces of onsite haul roads as 

an interim measure before permanent pavements are 

installed 

• apply erosion mitigation methods in areas of disturbed soils 

• use water sprays at material drop and conveyor transfer 

points 

• limit the height and disturbance of material stockpiles 

• apply water to the surfaces of stockpiles 

• cover open-bodied trucks that transport materials that could 

be sources of airborne dust 

 
 5-4 

Table 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction and 

Construction Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Air Quality 

(Cont.)

• promptly remove earthen materials deposited on paved 

roadways by wind, trucks, or earthmoving equipment 

• promptly stabilize or cover bare areas resulting from roadway 

or highway interchange construction 

Apply BMPs to the design and operation of onsite vehicle and 

equipment fueling activities to minimize the release to the 

atmosphere of nonmethane hydrocarbons and mitigate the 

potential impact of spills or accidental releases; including: 

• equip storage tanks with appropriate VOC controls, liquid 

level gauges, and overfill protection 

• provide training to fuel delivery drivers 

• post appropriate warning signs at the fuel dispensing facility 

• pave fuel unloading and dispensing areas and equip them 

with curbs to control small spills 

• ensure delivery contractors carry spill kits and are required to 

address minor spills during fuel deliveries 

Maintain all internal combustion engines and their pollution 

control devices in good working order. 

Geology and Soil 

Resources 

Soil disturbance Use BMPs to reduce soil erosion (e.g., earth berms, dikes, and 

sediment fences). 

Promptly revegetate or cover bare areas with natural materials. 

Use water to control fugitive dust emissions. 

Use standard drilling and blasting techniques to minimize 

impact to bedrock, reducing the potential for over-excavation, 

thereby minimizing damage to the surrounding rock and 

protecting adjacent surfaces that are intended to remain intact. 

Place soil stockpiles generated in a manner to reduce erosion. 

Reuse onsite excavated materials whenever possible. 

Use a stormwater detention basin. 

 
 5-5 

Table 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction and 

Construction Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Geology and Soil 

Resources 

(Cont.) 

Follow the requirements of a Spill Prevention Control and 

Countermeasures (SPCC) Plan to reduce the potential impacts 

from chemical spills or releases around vehicle maintenance 

and fueling locations, storage tanks, and painting operations, 

and ensure prompt and appropriate cleanup. 

Follow appropriate waste management procedures to minimize 

the impacts on soils from solid waste and hazardous materials 

that would be generated during all phases. Where practicable, 

implement a recycling program for materials suitable for 

recycling. 

Water Resources Water quality Employ BMPs to control the use of hazardous materials and 

fuels. 

Maintain construction equipment in good repair without visible 

leaks of oil, greases, or hydraulic fluids. 

Control and mitigate spills in conformance with the Spill 

Prevention Control and Countermeasure (SPCC) Plan. 

Ensure discharges to surface impoundments meet the 

standards for stormwater and treated domestic sanitary 

wastewater, and that no radiological discharges are made. 

Use BMPs to control stormwater runoff to prevent releases to 

nearby areas to the extent possible. 

Use BMPs for dust control associated with excavation and fill 

operations. Water conservation will be considered when 

deciding how often dust suppression sprays will be applied. 

Use silt fencing and/or sediment traps. 

Use only water (no detergents) for external vehicle washing. 

Place stone construction pads at entrance/exits where an 

unpaved construction access adjoins a State road. 

Arrange all temporary construction basins and permanent 

basins to provide for the prompt, systematic sampling of runoff 

in the event of any special needs. 

Control water quality impacts by compliance with the National 

Pollution Discharge Elimination System (NPDES) Construction 

General Permit requirements and by applying BMPs as detailed 

in the proposed site’s Stormwater Pollution Prevention Plan 

(SWPPP). 
 5-6 

Table 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction and 

Construction Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Water Resources 

(Cont.) 

 Implement a SPCC Plan for the proposed facility to identify 

potential spill substances, sources, and responsibilities. 

Berm or self-contain all aboveground gasoline and diesel 

storage tanks. 

Construct curbing, pits, or other barriers around tanks and 

components containing radioactive wastes. 

Handle any hazardous materials by approved methods and 

ship offsite to approved disposal sites. Handle sanitary wastes 

by portable systems until the Domestic Sanitary Sewage 

Treatment Plant is available for site use. Provide an adequate 

number of these portable systems. 

Require control of surface water runoff for activities covered by 

the NPDES Construction General Permit. 

 Water use Use low-water-consumption landscaping rather than 

conventional landscaping to reduce water usage. 

Implement conservation practices when spraying water for dust 

control. 

Ecological 

Resources 

Habitat and 

wildlife 

disturbance 

Manage unused open areas (i.e., leave undisturbed), including 

areas of native grasses and shrubs, for the benefit of wildlife. 

Use native plant species (i.e., low-water-consuming plants) to 

revegetate disturbed areas, to enhance wildlife habitat. 

Fence the stormwater discharge basins to limit access by 

wildlife. 

Reduce vehicle speeds onsite. 

Use BMPs to minimize dust. Apply water at least twice daily, 

when needed, to control dust in construction areas, in addition 

to other fugitive dust prevention and control methods. 

Focus all lights downward. 

 
 5-7 

Table 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction and 

Construction Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Ecological 

Resources 

(Cont.) 

 Improve the existing boundary fence to ensure pronghorn 

access to the remaining habitat on the proposed site. The 

fence would include a smooth top wire no more than 42 inches 

above the ground, adequate wire spacing to prevent wildlife 

entanglement, a smooth bottom wire approximately 16 to 

18 inches above the ground, and durable markers to increase 

wire visibility (AEA, 2010b). 

Remove livestock to improve sagebrush habitat. 

Take the following measures during construction and 

decommissioning of the proposed EREF to protect migratory 

birds: 

• perform clearing or removal of habitat, such as sagebrush, 

including buffer zones, outside of the migratory bird breeding 

and nesting season 

• survey additional areas to be cleared for active nests during 

migratory bird breeding and nesting season 

• avoid activities in areas containing active nests of migratory 

birds 

• consult the U.S. Fish and Wildlife Service (FWS) to 

determine the appropriate actions regarding the taking of 

migratory birds, if needed 

Use no herbicides during construction. 

Repair and stabilize any eroded areas, and collect sediment in 

a stormwater detention basin. 

Follow BMPs for temporary and permanent erosion and runoff 

control methods (as identified under Land Use). 

Consider all recommendations of appropriate State and Federal 

agencies, including the Idaho Department of Fish and Game 

and the FWS. 

 
 5-8 

Table 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction and 

Construction Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Noise Exposure of 

workers and the 

public to noise 

Restrict most of US 20 use after twilight through early morning 

hours to minimize noise impacts to the nearest residence. 

Restrict usage of heavy truck and earthmoving equipment after 

twilight through early morning hours during construction of the 

access roads and highway entrances, to minimize noise 

impacts on the Hell’s Half Acre Wilderness Study Area. 

Perform construction or decommissioning activities with the 

potential for noise or vibration at residential areas that could 

have a negative impact on the quality of life, during the daytime 

hours (7:00 am–7:00 pm). If it is necessary to perform an 

activity that could result in excessive noise or vibration in a 

residential area after hours, notify the community in accordance 

with site procedures. 

Use engineered and administrative controls for equipment 

noise abatement, including the use of equipment and vehicle 

mufflers, acoustic baffles, shrouding, barriers, and noise 

blankets. 

Sequence construction or decommissioning activities to 

minimize the overall noise and vibration impact (e.g., establish 

the activities that can occur simultaneously or in succession). 

Use blast mats, if necessary. 

Create procedures for notifying State and local government 

agencies, residents, and businesses of construction or 

decommissioning activities that may produce high noise or 

vibration that could affect them. 

Post appropriate State highway signs warning of blasting. 

Create a Complaint Response Protocol for dealing with and 

responding to noise or vibration complaints, including entering 

the complaints into the proposed site’s Corrective Action 

Program. 

Establish and enforce onsite speed limits. 

 
 5-9 

Table 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction and 

Construction Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Transportation Traffic volume Use the following BMPs to reduce traffic volumes, minimize 

noise, and minimize wildlife mortality: 

• encourage carpooling to minimize traffic due to employee 

travel 

• stagger shift changes to reduce the peak traffic volume on 

US 20 

• construct acceleration and deceleration lanes at the 

entrances to the proposed EREF site to improve traffic flow 

and safety on US 20 

• maintain low speed limits onsite to reduce noise and 

minimize impacts to wildlife 

 

 Deposition on 

roadways 

Use the following measures to minimize the release of dirt and 

other matter onto US 20: 

• promptly remove earthen materials on paved roads carried 

onto the roadway by wind, trucks, or earthmoving equipment 

• promptly stabilize or cover bare earthen areas once roadway 

and highway entrance earthmoving activities are completed 

• build gravel pads at the proposed EREF’s entry/exit points 

along US 20 in accordance with the Idaho Department of 

Environmental Quality (IDEQ) Catalog of Stormwater Best 

Management Practices for Idaho Cities and Counties, 

Volume 2, Erosion and Sediment Controls (IDEQ, 2009) 

• apply periodic top dressing of clean stone to the gravel pads, 

as needed, to maintain the effectiveness of the stone voids 

• perform tire washing, as needed, on a stabilized stone 

(gravel) area that drains to a sediment trap 

• prior to entering US 20, inspect vehicles for cleanliness from 

dirt and other matter that could be released onto the highway 

• cover open-bodied trucks (e.g., install tarps over open beds) 

to prevent debris from falling off or blowing out of vehicles 

onto the highway 
 5-10 

Table 5-1 Summary of Mitigation Measures Identified by AES for Preconstruction and 

Construction Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Waste 

Management 

Generation of 

industrial and 

hazardous 

wastes (air and 

liquid emissions 

in Air Quality 

and Water 

Resources 

above) 

Develop a construction phase recycling program. 

Source: AES, 2010a.
 5-11 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts 

Impact Area Activity Mitigation Measures 

Visual and 

Scenic 

Resources 

Potential visual 

intrusions in the 

character of the 

existing 

landscape 

Use aesthetically pleasing screening measures such as berms 

and earthen barriers, natural stone, and other physical means 

to soften the impact of the buildings. 

Use neutral colors for structures. 

Limit lighting to that necessary to meet security requirements; 

focus lighting downward to reduce night lighting in the 

surrounding area. 

Air Quality Facility 

emissions of 

hazardous 

gases 

Apply BMPs to the design and operation of onsite vehicle and 

equipment fueling activities to minimize the release to the 

atmosphere of nonmethane hydrocarbons and mitigate the 

potential impact of spills or accidental releases; including: 

• equip storage tanks with appropriate VOC controls, liquid 

level gauges, and overfill protection 

• provide training to fuel delivery drivers 

• post appropriate warning signs at the fuel dispensing facility 

• pave fuel unloading and dispensing areas and equip them 

with curbs to control small spills 

• ensure delivery contractors carry spill kits and are required to 

address minor spills during fuel deliveries 

Install the Separations Building Module (SBM) Safe-by-Design 

Gaseous Effluent Vent System (GEVS) and SBM Local 

Extraction GEVS, which are designed to collect and clean all 

potentially hazardous gases from the plant prior to release to 

the atmosphere. Provide instrumentation to detect and signal, 

via alarm, all nonroutine process conditions, including the 

presence of radionuclides or hydrogen fluoride (HF) in the 

exhaust stream that will trip the system to a safe condition in 

the event of effluent detection beyond routine operational limits. 
 5-12 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Air Quality 

(Cont.) 

 Install the Technical Services Building (TSB) GEVS, which is 

designed to collect and clean all potentially hazardous gases in 

the serviced areas from the TSB prior to release to the 

atmosphere. Provide instrumentation to detect and signal the 

Control Room, via alarm, regarding all nonroutine process 

conditions, including the presence of radionuclides or HF in the 

exhaust stream. Operators would then take appropriate actions 

to mitigate the release. 

Install the Centrifuge Test and Postmortem Facilities GEVSs, 

which are designed to collect and clean all potentially 

hazardous gases in the serviced areas from the Centrifuge 

Assembly Building prior to release to the atmosphere. Provide 

instrumentation to detect and signal the Control Room, via 

alarm, regarding all nonroutine process conditions, including 

the presence of radionuclides or HF in the exhaust stream. 

Operators would then take appropriate actions to mitigate the 

release. 

Design the TSB Contaminated Area heating, ventilating, and air 

conditioning (HVAC) system, the Ventilated Room HVAC 

System in the Blending, Sampling, and Preparation Building 

(BSPB), and the Centrifuge Test and Postmortem Facilities 

Exhaust Filtration System to collect and clean all potentially 

hazardous gases in the serviced areas prior to release to the 

atmosphere. 

 Fugitive dust 

and equipment 

emissions 

Apply gravel to the unpaved surface of the secondary access 

road. 

Impose speed limits on the unpaved secondary access road. 

Maintain air concentrations of criteria pollutants resulting from 

vehicle emissions and fugitive dust below the National Ambient 

Air Quality Standards. 

Geology and Soil 

Resources 

Soil disturbance Follow the requirements of a Spill Prevention Control and 

Countermeasures (SPCC) Plan to reduce the potential impacts 

from chemical spills or releases around vehicle maintenance 

and fueling locations, storage tanks, and painting operations, 

and ensure prompt and appropriate cleanup. 

Follow appropriate waste management procedures to minimize 

the impacts on soils from solid waste and hazardous materials 

that would be generated. Where practicable, implement a 

recycling program for materials suitable for recycling. 

 
 5-13 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Water Resources Water quality Employ BMPs to control the use of hazardous materials and 

fuels. 

Control and mitigate spills in conformance with the SPCC Plan. 

Ensure discharges to surface impoundments meet the 

standards for stormwater and treated domestic sanitary 

wastewater, and that no radiological discharges are made. 

Use BMPs to control stormwater runoff to prevent releases to 

nearby areas to the extent possible. 

Use only water (no detergents) for external vehicle washing. 

Arrange all temporary construction basins and permanent 

basins to provide for the prompt, systematic sampling of runoff 

in the event of any special needs. 

 Berm or self-contain all aboveground gasoline and diesel 

storage tanks. 

Construct curbing, pits, or other barriers around tanks and 

components containing radioactive wastes. 

Handle any hazardous materials by approved methods and 

ship offsite to approved disposal sites. Handle sanitary wastes 

by portable systems until the Domestic Sanitary Sewage 

Treatment Plant is available for site use. Provide an adequate 

number of these portable systems. 

Use evaporators in the Liquid Effluent Collection and Treatment 

System, thereby eliminating the need to discharge treated 

process water to an onsite basin. 

 Water use Use low-water-consumption landscaping rather than 

conventional landscaping to reduce water usage. 

Install low-flow toilets, sinks, and showers to reduce water 

usage. 

Implement localized floor washing using mops and selfcontained cleaning machines rather than conventional washing 

with a hose to reduce water usage. 

Incorporate closed-loop cooling systems instead of cooling 

towers, thereby eliminating evaporative losses and cooling 

tower blowdown, resulting in reduced water usage. 

 
 5-14 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Ecological 

Resources 

Habitat 

disturbance 

Reduce vehicle speeds onsite. 

Focus all lights downward. 

Use herbicides in limited amounts during operations along 

access roads, industrial area, and security fence surrounding 

the proposed facility. Use herbicides according to government 

regulations and manufacturer’s instructions to control noxious 

weeds. 

Reseed cropland areas on the proposed site with native 

species when the proposed EREF becomes operational. 

Consider all recommendations of appropriate State and Federal 

agencies, including the Idaho Department of Fish and Game 

and the FWS. 

Noise Exposure of 

workers and the 

public to noise 

Mitigate operational noise sources primarily by plant design, 

whereby cooling systems, valves, transformers, pumps, 

generators, and other facility equipment are located mostly 

within plant structures and the buildings absorb the majority of 

the noise located within. 

Restrict most of US 20 use after twilight through early morning 

hours to minimize noise impacts to the nearest residence. 

Establish preventative maintenance programs that ensure all 

equipment is working at peak performance. 

Transportation Traffic volume Encourage carpooling to minimize traffic due to employee 

travel. 

Stagger shift changes to reduce the peak traffic volume on 

US 20. 

Maintain low speed limits onsite to reduce noise and minimize 

impacts to wildlife. 

 
 5-15 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Public and 

Occupational 

Health 

Nonradiological 

effects 

Design process systems that handle uranium hexafluoride 

(UF6) to operate at subatmospheric pressure, to minimize 

outward leakage of UF6. 

Direct process off-gas from UF6 purification and other 

operations through cold traps to solidify and reclaim as much 

UF6 as possible. Pass remaining gases through high-efficiency 

filters and chemical absorbers to remove HF and uranic 

compounds. 

Monitor all UF6 process systems by instrumentation that will 

activate alarms in the Control Room and will either 

automatically shut down the proposed facility to a safe 

condition or alert operators to take the appropriate action to 

prevent release in the event of operational problems. 

Investigate alternative solvents or apply control technologies for 

methylene chloride solvent use. 

Use administrative controls, practices, and procedures to 

assure compliance with the proposed EREF’s Health, Safety, 

and Environmental Program. Design the program to ensure 

safe storage, use, and handling of chemicals to minimize the 

potential for worker exposure. 

 Radiological 

effects 

Put in place radiological practices and procedures to ensure 

compliance with the proposed EREF’s Radiation Protection 

Program. Design the program to achieve and maintain 

radiological exposure to levels that are as low as reasonably 

achievable (ALARA). 

Conduct routine facility radiation and radiological surveys to 

characterize and minimize potential radiological dose/exposure. 

Monitor all radiation workers by use of dosimeters and area air 

sampling to ensure that radiological doses remain within 

regulatory limits and are ALARA. 

Provide radiation monitors in the gaseous effluent vents to 

detect and alarm and effect the automatic safe shutdown of 

process equipment in the event contaminants are detected in 

the system exhaust. Design systems to automatically shut 

down, switch trains, or rely on operator actions to mitigate the 

potential release. 

 
 5-16 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Public and 

Occupational 

Health (Cont.) 

 Design the proposed facility to delay and reduce UF6 releases 

inside the buildings in a potential fire incident from reaching the 

outside environment, including automatic shutoff of room HVAC 

systems during a fire event. 

Design process systems that handle uranium hexafluoride 

(UF6) to operate at subatmospheric pressure, to minimize 

outward leakage of UF6. 

Move UF6 cylinders only when cool and when UF6 is in solid 

form, to minimize the risk of inadvertent release due to 

mishandling. 

Direct process off-gas from UF6 purification and other 

operations through cold traps to solidify and reclaim as much 

UF6 as possible. Pass remaining gases through high-efficiency 

filters and chemical absorbers to remove HF and uranic 

compounds. 

Separate uranic compounds and various other heavy metals in 

waste material generated by decontamination of equipment and 

systems. 

Use liquid and solid waste handling systems and techniques to 

control wastes and effluent concentrations. 

Pass gaseous effluent through pre-filters, high-efficiency 

particulate air (HEPA) filters and activated carbon filters to 

reduce the radioactivity in the final discharged effluent to very 

low concentrations. 

Route process liquid waste to collection tanks and treat through 

a combination of precipitation, evaporation, and ion exchange 

to remove most of the radioactive material prior to a final 

evaporation step to preclude any liquid effluent release from the 

proposed facility. 

Monitor all UF6 process systems by instrumentation that will 

activate alarms in the Control Room and will either 

automatically shut down the proposed facility to a safe 

condition or alert operators to take the appropriate action to 

prevent release in the event of operational problems. 
 5-17 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Waste 

Management 

Generation of 

industrial, 

hazardous, 

radiological, and 

mixed wastes 

(air emissions 

are addressed 

under Air 

Quality and 

liquid emissions 

are addressed 

under Water 

Resources) 

Design system features to minimize the generation of solid 

waste, liquid waste, and gaseous effluent (gaseous effluent 

design features are described above under Public and 

Occupational Health). 

Store waste in designated areas of the proposed facility until an 

administrative limit is reached, then ship offsite to a licensed 

disposal facility; no disposal of waste onsite. 

Dispose of all radioactive and mixed wastes at offsite licensed 

facilities. 

Maintain a cylinder management program to monitor storage 

conditions on the Full Tails Cylinder Storage Pads, to monitor 

cylinder integrity by conducting routine inspections for breaches 

and to perform cylinder maintenance and repairs as needed. 

Store all tails cylinders filled with depleted UF6 on saddles of 

concrete, or other suitable material, that do not cause corrosion 

of the cylinders. Place saddles on a concrete pad. 

Segregate the storage pad areas from the rest of the proposed 

enrichment facility by barriers, such as vehicle guard rails. 

Double stack depleted uranium tails cylinders on the storage 

pad, arrayed to permit easy visual inspection of all cylinders. 

Survey depleted uranium tails cylinders for external 

contamination (wipe test) prior to being placed on a Full Tails 

Cylinder Storage Pad or transported offsite. 

Fit depleted uranium tails cylinder valves with valve guards to 

protect the cylinder valves during transfer and storage. 

Make provisions to ensure that depleted uranium tails cylinders 

will not have defective valves (identified in NRC Bulletin 2003-

03, “Potentially Defective 1-inch Valves for Uranium 

Hexafluoride Cylinders”) (NRC, 2003) installed. 

Perform touch-up application of paint coating on depleted 

uranium tails cylinders if coating damage is discovered during 

inspection (UF6 cylinder manufacturing will include abrasive 

blasting and coating with anticorrosion primer/paint, as required 

by specification). 
 5-18 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Waste 

Management 

(Cont.) 

 Allow only designated vehicles, operated by trained and 

qualified personnel, on the Full Tails Cylinder Storage Pads, 

Full Feed Cylinder Storage Pads, Full Product Cylinder Storage 

Pad, and the Empty Cylinder Storage Pad (refer to the 

Integrated Safety Analysis Summary, Section 3.8, for controls 

associated with vehicle fires on or near the Cylinder Storage 

Pads. 

Inspect depleted uranium tails cylinders for damage prior to 

placing a filled cylinder on a storage pad. Annually reinspect 

depleted uranium tails cylinders for damage or surface coating 

defects. These inspections will verify that: 

• lifting points are free from distortion and cracking 

• cylinder skirts and stiffener rings are free from distortion and 

cracking 

• cylinder surfaces are free from bulges, dents, gouges, 

cracks, or significant corrosion 

• cylinder valves are fitted with the correct protector and cap 

• cylinders are inspected to confirm that the valve is straight 

and not distorted, two to six threads are visible, and the 

square head of the valve stem is undamaged 

• cylinder plugs are undamaged and not leaking 

If inspection of a depleted uranium tails cylinder reveals 

significant deterioration or other conditions that may affect the 

safe use of the cylinder, transfer the contents of the affected 

cylinder to another cylinder in good condition and discard the 

defective cylinder. Determine the root cause of any significant 

deterioration and, if necessary, make additional inspections of 

cylinders. 

Make available onsite proper documentation on the status of 

each depleted uranium tails cylinder, including content and 

inspection dates. 

Use the lined Cylinder Storage Pads Stormwater Retention 

Basins to capture stormwater runoff from the Full Tails Cylinder 

Storage Pads. 

Minimize power usage by efficient design of lighting systems, 

selection of high-efficiency motors, and use of proper insulation 

materials. 
 5-19 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Waste 

Management 

(Cont.) 

 Control process effluents by means of the following liquid and 

solid waste handling systems and techniques: 

• follow careful application of basic principles for waste 

handling in all of the systems and processes 

• collect different waste types in separate containers to 

minimize contamination of one waste type with another; 

carefully package materials that can cause airborne 

contamination; provide ventilation and filtration of the air in 

the area as necessary; confine liquid wastes to piping, tanks, 

and other containers; use curbing, pits, and sumps to collect 

and contain leaks and spills 

• store hazardous wastes in designated areas in carefully 

labeled containers; also contain and store mixed wastes 

separately 

• neutralize strong acids and caustics before they enter an 

effluent stream 

• decontaminate and/or reuse radioactively contaminated 

wastes to reduce waste volume as far as possible 

• reduce the volume of collected waste such as trash, 

compressible dry waste, scrap metals, and other candidate 

wastes at a centralized waste processing facility 

• include administrative procedures and practices in waste 

management systems that provide for the collection, 

temporary storage, processing, and disposal of categorized 

solid waste in accordance with regulatory requirements 

• design handling and treatment processes to limit wastes and 

effluent. Perform sampling and monitoring to assure that 

plant administrative and regulatory limits will not be 

exceeded 

• monitor gaseous effluent for HF and radioactive 

contamination before release 

• sample and/or monitor liquid wastes in liquid waste treatment 

systems 

• sample and/or monitor solid wastes prior to offsite treatment 

and disposal 
 5-20 

Table 5-2 Summary of Mitigation Measures Identified by AES for Operations 

Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Waste 

Management 

(Cont.) 

• return process system samples to their source, where 

feasible, to minimize input to waste streams 

Implement a spill control program for accidental oil spills. 

Prepare a Spill Prevention Control and Countermeasure 

(SPCC) Plan prior to the start of operation of the proposed 

facility or prior to the storage of oil on the proposed site in 

excess of de minimis quantities, which will contain the following 

information: 

• identification of potential significant sources of spills and a 

prediction of the direction and quantity of flow that will likely 

result from a spill from each source 

• identification of the use of containment or diversionary 

structures such as dikes, berms, culverts, booms, sumps, 

and diversion ponds, at the proposed facility to control 

discharged oil 

• procedures for inspection of potential sources of spills and 

spill containment/diversion structures 

• assigned responsibilities for implementing the plan, 

inspections, and reporting 

• as part of the SPCC Plan, other measures will include control 

of drainage of rain water from diked areas, containment of oil 

and diesel fuel in bulk storage tanks, aboveground tank 

integrity testing, and oil and diesel fuel transfer operational 

safeguards 

Implement a nonhazardous materials waste recycling plan 

during operation. Perform a waste assessment to identify 

waste reduction opportunities and to determine which materials 

will be recycled. Contact brokers and haulers to find an endmarket for the materials. Perform employee training on the 

recycling program so that employees will know which materials 

are to be recycled. Purchase and clearly label recycling bins 

and containers. Periodically evaluate the recycling program 

(i.e., waste management expenses and savings, recycling and 

disposal quantities) and report the results to the employees. 

Source: AES, 2010a.
 5-21 

5.2 Potential Mitigation Measures Identified by the NRC 

This section presents additional potential mitigation measures that were identified by the NRC 

staff, following their evaluation of the potential environmental impacts of the proposed EREF in 

Chapter 4. Tables 5-3 and 5-4 list the NRC-identified mitigation measures for 

preconstruction/construction and operations, respectively. 

5.3 References 

(AES, 2010a) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

Environmental Report, Rev. 2.” Bethesda, Maryland. April. 

(AES, 2010b) AREVA Enrichment Services, LLC. Letter from J.A. Kay (Licensing Manager, 

AES) to Sharon W. Kiefer (Assistant Director-Policy, IDFG) dated December 7, 2010. “Subject: 

Response to IDFG Comments to NRC Related to the EREF Transmission Line.” ADAMS 

Accession No. ML103420579. 

(IDEQ, 2009) Idaho Department of Environmental Quality. “Catalog of Stormwater Best 

Management Practices for Idaho Cities and Counties, Volume 2: Erosion and Sediment 

Controls.” 

(NRC, 2003) U.S. Nuclear Regulatory Commission. “Potentially Defective 1-Inch Valves for 

Uranium Hexafluoride Cylinders.” NRC Bulletin 2003-03. August. 
 5-22 

Table 5-3 Summary of Potential Mitigation Measures Identified by NRC 

for Preconstruction and Construction Environmental Impacts 

Impact Area Activity Mitigation Measures 

Air Quality Point source 

releases of 

criteria 

pollutants 

Ensure vehicles and equipment with internal combustion 

engines are properly tuned and pollution control devices are 

functional. 

Install hard-surface pavements, curbs, scupper drains, and 

drainage ways at fuel dispensing island that will channel spilled 

fuels to fire-safe containment sumps; require delivery drivers to 

remain in attendance throughout all fuel deliveries; place spill 

containment/response equipment at fuel dispensing stations. 

Provide first responder training to selected workers; ensure 

storage tanks are equipped with fully functional overflow and 

vapor control features. 

Install emergency shut-offs for fuel dispensing pumps; post spill 

response directives at the fuel dispensing islands; provide spill 

cleanup materials at the fuel dispensing islands for cleanup of 

small spills; ensure the fuel dispensing islands have adequate 

lighting. 

Adopt a policy that requires prompt cleanup of all spilled 

materials. 

Identify and select construction-related products and chemicals 

that are free of volatile solvents. 

Suspend high fugitive dust-generating activities during early 

morning hours with calm winds and during windy periods. 

Geology and Soil Soil disturbance Minimize the construction footprint to the extent possible. 

Cover stockpiles to reduce exposure to wind and rain. 

Limit routine vehicle traffic to paved or gravel roads. 

Water Resources Stormwater 

management 

Reduce the size of impervious surfaces (parking lots, roads, 

and roofs) to the extent possible; implement a “fix-it-first” 

infrastructure policy to set spending priorities on the repair of 

existing infrastructure over the installation of new infrastructure; 

and employ low-impact development strategies and practices 

during construction activities. 
 5-23 

Table 5-3 Summary of Potential Mitigation Measures Identified by NRC 

for Preconstruction and Construction Environmental Impacts (Cont.) 

Impact Area Activity Mitigation Measures 

Ecological 

Resources 

Habitat 

disturbance 

Plant disturbed areas and irrigated crop areas with native 

sagebrush steppe species to establish native communities and 

prevent the establishment of noxious weeds. Plant immediately 

following the completion of disturbance activities and the 

abandonment of crop areas. 

Develop and implement a noxious weed control program to 

prevent the establishment and spread of invasive plant species. 

Hose down tires and undercarriage of off-road vehicles prior to 

site access to dislodge seeds or other propagules of noxious 

weeds. Monitor for noxious weeds throughout the construction 

and operations phases and immediately eradicate new 

infestations. Minimize indirect impacts of weed control 

activities, such as herbicide effects on nontarget species, and 

soil disturbance and fire hazards from vehicle operation in 

undisturbed areas during weed control activities. 

Noise Exposure of 

workers and the 

public to noise 

Suspend the use of explosives during periods when 

meteorological conditions (e.g., low cloud cover) can be 

expected to reduce sound attenuation. 
 5-24 

Table 5-4 Summary of Potential Mitigation Measures Identified by NRC for Operations 

Environmental Impacts 

Impact Area Activity Mitigation Measures 

Water Resources Stormwater 

management 

Reduce the size of impervious surfaces (parking lots, roads, 

and roofs) to the extent possible. 

Implement a “fix-it-first” infrastructure policy to set spending 

priorities on the repair of existing infrastructure over the 

installation of new infrastructure. 

Employ low-impact development strategies and practices 

during operations.

Ecological 

Resources 

Wildlife 

protection 

Develop areas that will retain water of suitable quality for 

wildlife and provide wildlife access to such areas with suitable 

water quality. 

For basins with water quality unsuitable for wildlife, use animalfriendly fencing and netting or other suitable material over 

basins to prevent use by migratory birds. 

Place metal reflectors on the top wire of the fence along the 

AES property boundary, to reduce sage-grouse mortality 

resulting from collisions with the fence. 

Coordinate with Idaho National Laboratory in monitoring risks to 

sage-grouse and other sensitive species and identifying 

measures to reduce risks and protect these species and their 

habitat, particularly sagebrush steppe. 

Coordinate with Idaho Department of Fish and Game to 

determine corrective action or mitigation for the offsite public 

lands lost to wildlife due to project effects.

Transportation Traffic volume Consider working with INL to operate a joint bus system. 

Establish shift changes outside of INL peak commuting periods. 

Public and 

Occupational 

Health 

Radiological 

effects 

Store “empty” cylinders with heels in the middle of a storage 

pad between full tail cylinders to reduce external exposure to 

workers. 
 6-1 

1 6 ENVIRONMENTAL MEASUREMENT AND MONITORING PROGRAMS 

2 

3 This chapter describes the proposed measurement and monitoring programs that would be 

4 used by AREVA Enrichment Services, LLC (AES) to characterize the effects on human health 

5 and the environment of radiological and nonradiological releases from the proposed Eagle Rock 

6 Enrichment Facility (EREF) in Bonneville County, Idaho. This proposed program includes direct 

7 monitoring of radiological and physiochemical (i.e., chemical and meteorological properties that 

8 affect measurements) gaseous and liquid effluents from facility operations, and monitoring and 

9 measurement of ambient air, surface water, groundwater, stormwater, soil, sediment, and direct 

10 radiation in the vicinity of the proposed EREF during preconstruction, construction, and 

11 operation. 

12 

13 6.1 Radiological Measurements and Monitoring Program 

14 

15 The U.S. Nuclear Regulatory Commission (NRC) requires that a radiological monitoring 

16 program be established for the proposed EREF to monitor and report the release of radiological 

17 gaseous and liquid effluents to the environment. These requirements are specified in Title 10, 

18 “Energy,” of the U.S. Code of Federal Regulations (10 CFR) Part 20, Appendix B, 

19 and10 CFR 70.59. Table 6-1 lists the NRC guidance documents that apply to the radiological 

20 monitoring program. The NRC staff has reviewed engineering designs and proposed 

21 operational procedures submitted by AES in order to identify the locations and activities 

22 associated with potential emissions and effluents with radiologic character, and has verified that 

23 the pathways for these releases to the environment are appropriately represented in the 

24 proposed radiological monitoring program. Those pathways for environmental release are 

25 summarized below. 

26 

27 Radiological monitoring at the proposed EREF would be addressed through the Effluent 

28 Monitoring Program (EMP) and the Radiological Environmental Monitoring Program (REMP). 

29 The EMP addresses the monitoring, recording, and reporting of data for radiological 

30 contaminants emitted from specific points. Physical samples collected for analysis in this 

31 program would include exhaust vent air sampler filters, filters from mobile air monitors, and 

32 liquid condensate from the evaporator exhaust vent. Corrective actions would be implemented 

33 if action levels are exceeded. The REMP addresses the monitoring of general environmental 

34 media (i.e., soil, sediment, groundwater, biota, and ambient air) within and outside the proposed 

35 EREF property boundary. The REMP will be initiated at least two years prior to the start of plant 

36 operations in order to develop a baseline (AES, 2010a). In addition, the REMP may be 

37 enhanced as necessary to maintain the collection and reliability of environmental data based on 

38 changes to regulatory requirements or facility operations (AES, 2010a). Every six months, AES 

39 will submit a summary report of the environmental sampling program at the proposed EREF to 

40 the NRC (AES, 2010a). Monitoring locations are shown in Figure 6-1. Data collected under this 

41 program would be used to assess radiological impacts on the environment and estimate 

42 potential impacts on the public. The REMP would be used to confirm the effectiveness of the 

43 effluent controls and the EMP and to verify that facility operations do not result in detrimental 

44 radiological impacts on the environment. 

45 

46 As discussed in the following sections, radiological measurement and monitoring would include 

47 monitoring of air emissions, ambient air quality, wastewater discharge, stormwater and basin 

48 sediment, groundwater, and soil and vegetation, along with direct gamma radiation monitoring. 
 6-2 

Table 6-1 NRC Guidance Documents Relevant to Radiological Monitoring Programs 

Guidance Purpose and Content 

Regulatory Guide 4.15, “Quality 

Assurance for Radiological Monitoring 

Programs (Normal Operations) – Effluent 

Streams and the Environment”a

Provides acceptable methods for designing a program to 

ensure the quality of the results of measurements for 

radioactive materials in the effluents and the environment 

outside of nuclear facilities during normal operations. 

Regulatory Guide 4.16, “Liquid and 

Gaseous Effluents from Nuclear Fuel 

Processing and Fabrication Plants and 

Uranium Hexafluoride Production 

Plants”b

Provides descriptions of acceptable methods for 

submitting semiannual reports that specify the quantity of 

each principal radionuclide released to unrestricted areas 

to estimate the maximum potential annual doses to the 

public resulting from such releases. a

 NRC, 1979. 

b

 NRC, 1985.

1 

2 6.1.1 Air Emissions Monitoring 

3 

4 The Air Emissions Monitoring Program would monitor each individual point source or pathway of 

5 potential radioactive airborne release to the atmosphere from the proposed EREF. Radioactive 

6 airborne releases of gaseous effluents could result from the following events or activities: 

7 

8 • controlled releases of gaseous effluents from ventilation stacks 

9 

10 • controlled gaseous releases from the uranium enrichment equipment during 

11 decontamination and maintenance of equipment 

12 

13 • handling, temporary storage, and transportation of uranium hexafluoride (UF6) feed 

14 cylinders, product cylinders, and depleted uranium cylinders 

15 

16 Monitoring for radioactive air emissions from the proposed EREF is conducted as part of the 

17 EMP, which would monitor, report, and record data on radiological contaminants released to the 

18 atmosphere from specific point sources. Gaseous effluents from the proposed EREF that have 

19 the potential for airborne radioactivity would be discharged from the sources listed below, and 

20 monitoring and sampling at these locations would be conducted in accordance with NRC 

21 Regulatory Guide 4.16 (NRC, 1985). These sources would all lie within the industrial footprint of 

22 the proposed EREF; however, the precise locations of these effluent points have been withheld 

23 as security-related information. Table 6-2 provides a summary of the EMP for gaseous 

24 discharges (AES, 2010a). Additional details on the exhaust vents enrolled in the monitoring 

25 program are provided below. 

26 

27 • Separations Building GEVSs. Each of the four Separations Building Modules (SBMs) 

28 would have exhaust vents on its roof. Each vent would be continuously monitored for alpha 

radiation and hydrogen fluoride (HF).1 29 In addition, samples would undergo uranium isotopic 

 

1

 In the strict sense, HF is not released as a result of EREF operations. Instead, trace amounts of UF6

could be released from the pollution control devices installed on building and processing area 

ventilation systems. The UF6 would be immediately hydrolyzed by the humidity in the ambient air, 

resulting in the formation of HF. 
 6-3 

1 

2 Figure 6-1 Proposed Radiological Sampling Stations and Monitoring Locations 

3 (AES, 2010a) 
 6-4 

Table 6-2 EREF Proposed Gaseous Effluent Monitoring Program 

Sample Location Sample Type Analysis/ 

Frequency 

• Separation Building GEVS exhaust vents 

• TSB GEVS exhaust vent 

• TSB Contaminated Area HVAC System exhaust vent 

• Centrifuge Test and Postmortem Facilities GEVS 

exhaust venta

 

• Centrifuge Test and Postmortem Facilities exhaust 

filtration system exhaust venta

 

• Ventilated Room HVAC System exhaust vent 

Continuous air 

monitoring for 

particulates 

Gross alpha/beta weekly; 

isotopic analysis on 

quarterly composite 

sampleb

Evaporator Continuous 

liquid 

condensate 

from exhaust 

vent 

Gross alpha/beta weekly; 

isotopic analysis on 

quarterly composite 

sampleb

Process areasc Local area 

continuous air 

particulate 

filterd

 

Gross alpha/beta weekly; 

isotopic analysis on 

quarterly composite 

sampleb

Nonprocess areasc Local area 

continuous air 

particulate 

filterd

 

Gross alpha/beta on 

quarterly composite 

sampleb

a

 Continuous sampling protocols are in effect only when this proposed facility is operational. b

 Isotopic analyses for uranium isotopes (238U, 236U, 235U, and 234U) would commence whenever gross alpha and 

gross beta activities indicate that an individual radionuclide could be present in a concentration >10 percent of the 

specified concentrations in Table 2 of Appendix B to 10 CFR Part 20. c

 Process areas include any area or facility at which UF6 transfers between feed, product, or tails cylinders occur, 

including areas where cylinders containing UF6 are opened for testing, inspection, or sampling. A nonprocess area 

is any area or facility where uranic material is present in an open form. 

d

 Mobile devices may be used to collect the necessary samples. 

Source: AES, 2010a.

1 

2 analysis quarterly or if the gross alpha and gross beta activities indicate that an individual 

3 radionuclide could be present in a concentration greater than 10 percent of the 

4 concentrations specified in Table 2, Appendix B, of 10 CFR Part 20. 

5 

6 • Technical Services Building GEVS. This system would discharge to a vent on the 

7 Technical Support Building (TSB) roof. The vent would be continuously monitored for alpha 

8 radiation and HF. In addition, samples would undergo uranium isotopic analysis quarterly or 

9 if the gross alpha and gross beta activities indicate that an individual radionuclide could be 

10 present in a concentration greater than 10 percent of the concentrations specified in 

11 Table 2, Appendix B, of 10 CFR Part 20. 

12 

13 • Centrifuge Test and Postmortem Facilities GEVS. This system would discharge through 

14 an exhaust vent on the roof of the Centrifuge Assembly Building (CAB). The Centrifuge 
 6-5 

1 Test and Postmortem Facilities GEVS vent-sampling system would provide for continuous 

2 monitoring and periodic sampling of the gaseous effluent in the exhaust vent. The exhaust 

3 vent would be continuously monitored for alpha radiation and HF. In addition, samples 

4 would undergo uranium isotopic analysis quarterly or if the gross alpha and gross beta 

5 activities indicate that an individual radionuclide could be present in a concentration greater 

6 than 10 percent of the concentrations specified in Table 2 of Appendix B to 10 CFR Part 20. 

7 

8 • Centrifuge Test and Postmortem Facilities Exhaust Filtration System. When 

9 operational, this system would maintain a negative pressure with the Centrifuge Test and 

10 Postmortem Facilities, thus reducing the potential for radiologic contamination of adjacent 

11 areas. The system would discharge through an exhaust vent on the roof of the CAB. 

12 Sampling of this vent for alpha radiation and HF would occur only when the Centrifuge Test 

13 Facility or the Centrifuge Postmortem Facility are in operation.

14 

15 • TSB Contaminated Area HVAC System. This vent would be continuously monitored for 

16 alpha radiation and HF. In addition, samples would undergo uranium isotopic analysis 

17 quarterly or if the gross alpha and gross beta activities indicate that an individual 

18 radionuclide could be present in a concentration greater than 10 percent of the 

19 concentrations specified in Table 2, Appendix B, of 10 CFR Part 20. 

20 

21 • BSPB Ventilated Room HVAC System. The vent would be continuously monitored for 

22 alpha radiation and HF. In addition, samples would undergo uranium isotopic analysis 

23 quarterly or if the gross alpha and gross beta activities indicate that an individual 

24 radionuclide could be present in a concentration greater than 10 percent of the 

25 concentrations specified in Table 2, Appendix B, of 10 CFR Part 20. 

26 

27 In addition to the specific exhaust vents described above, all HVAC systems serving process 

28 areas where radioactive airborne contamination is possible would be designed to allow access 

29 for periodic sampling of exhaust air in accordance with NRC Regulatory Guide 4.16 

30 (NRC, 1985). Periodic sampling would also occur in nonprocess areas, and may include the 

31 use of mobile continuous air monitors (see Table 6-2). 

32 

33 Sample analysis would employ methodologies with minimum detectable concentrations (MDC) 

of 1.8  10-9 becquerel per milliliter (5.0  10-14 34 microcurie per milliliter), a value representing 

5 percent of the limit of 1.0  10-12 35 microcurie per milliliter set by the NRC in 10 CFR Part 20, 

36 Appendix B, Table 2, “Effluent Concentrations (retention Class W).” 

37 

38 In addition, a separate vent on the TSB roof would be designed to allow for the capture and 

39 sampling of air and condensate from saturated air delivered to the TSB vent from the evaporator 

40 of the Liquid Effluent Collection and Treatment System. Periodic sampling of both the discharge 

41 air and condensate for isotopic uranium would take place. The evaporator condensate samples 

42 would be analyzed to a MDC equivalent to 5 percent or less of the 10 CFR Part 20, Appendix B, 

43 Table 2, Column 1 (Air), value for retention Class W. 

44 

45 In addition to the pollution control devices affixed to each point source of potential radiological 

46 effluent release, administrative action levels would be established for effluent samples and 

47 monitoring instrumentation as an additional element of the effluent control procedure. All action 

48 levels would be established sufficiently low so as to permit implementation of corrective actions 
 6-6 

1 before regulatory limits are exceeded. Effluent sample analytical results that exceed the action 

2 levels would precipitate an investigation into the source of elevated radioactivity. For example, 

3 radiological analyses would be performed more frequently on ventilation air filters if there were a 

4 significant increase in gross radioactivity or when a process change or other circumstances 

5 cause significant changes in radioactivity concentrations. Additional corrective actions would be 

6 implemented based on the level, automatic shutdown programming, and operating procedures 

7 that would be developed in the detailed alarm design phase. Under routine operating 

8 conditions, controls and interventions would ensure that radioactive material in gaseous 

9 effluents discharged from the proposed facility would comply with regulatory release criteria at 

10 all times. 

11 

12 Compliance with regulatory release criteria would be demonstrated through effluent and 

13 environmental sampling data. Meteorological data from an onsite station would be continuously 

14 collected and used to assess the impacts of accidental releases. 

15 

16 As part of the proposed EREF EMP, the gaseous effluent sampling program supports the 

17 determination of the quantity and concentration of radionuclides discharged from the proposed 

18 facility as well as the collection of other information required to be reported to the NRC or to 

19 demonstrate compliance with State and Federal regulations and permits. All potentially 

20 radioactive effluents from the proposed EREF would be discharged through monitored 

21 pathways. All effluent monitoring instruments would be capable of attaining a minimum 

detectable concentration (MDC) of at least 1.8  10-9 22 becquerel per milliliter 

(5.0  10-14 23 microcurie per milliliter) and would be subject to periodic maintenance and 

24 calibration, functional tests to verify operability, and appropriate quality controls. 

25 

26 Uranium compounds expected in the gaseous effluent could include depleted hexavalent 

27 uranium, triuranium octaoxide (U3O8), and uranyl fluoride (UO2F2), and the uranium isotopes 

uranium-238 (238U), uranium-236 (236U), uranium-235 (235U), and uranium-234 (234 28 U) would be 

29 expected to be the prominent radionuclides. Representative samples would be collected from 

30 each release point identified above. Effluent data would be maintained, reviewed, and 

31 assessed by the EREF Radiation Protection Manager to ensure that gaseous effluent 

32 discharges comply with regulatory release criteria for uranium. 

33 

34 6.1.2 Ambient Air Quality Monitoring 

35 

36 While the EMP’s Air Emissions Monitoring Program described above (Section 6.1.1) monitors 

37 each individual point source or pathway of potential radioactive airborne release to the 

38 atmosphere from the proposed EREF, the REMP’s Ambient Air Quality Monitoring Program 

39 monitors general air quality within and beyond the proposed EREF property boundary, collecting 

40 data at various locations around and outside the property. 

41 

42 Continuous monitoring for airborne radioactive particulate would be conducted at five locations 

43 – two along the north property boundary of the proposed EREF; one along the south boundary 

44 at a point closest to the industrial area; one on the east property boundary in the direction of the 

45 closest residence, approximately 8 kilometers (5 miles) away (Figure 6-1); and one located 

46 32 kilometers (20 miles) to the east in Idaho Falls. These sampling locations have been 

47 selected in accordance with the NUREG-1302, “Offsite Dose Calculation Manual Guidance: 

48 Standard Radiological Effluent Controls for Boiling Water Reactors” (NRC, 1991) and are based 
 6-7 

1 on consideration of the locations of effluent point sources within the proposed EREF industrial 

2 area, meteorological data (the most prevalent wind directions experienced at the proposed site), 

3 and current and projected surrounding land uses. In addition, because particulate releases can 

4 be expected to behave primarily as ground-level plumes with particulate concentrations 

5 diminishing rapidly and uniformly with distance from the source, and because radioactive 

6 emissions during routine operations are expected to be very low, sampling at the proposed 

7 property boundaries, rather than at locations more distant from the sources, is expected to 

8 represent worst-case conditions and the best opportunity to detect released radioactivity. 

9 

10 Particulate monitoring is an element of the proposed EREF REMP and is designed to collect 

11 representative samples that yield data that demonstrate the effectiveness of effluent controls 

12 and the EMP. Samples would be retrieved biweekly; however, periods of heavy concentrations 

13 of airborne dust may require more frequent sample retrieval. All samples collected from the 

14 particulate monitors would be analyzed in the onsite laboratory; however, for quality control 

15 purposes and as a contingency, samples may sometimes be shipped to an independent offsite 

16 laboratory for analysis. 

17 

Sample analysis for gross alpha would employ methodologies with MDC of 1.8  10-9 18 becquerel 

per milliliter (5.0  10-14 19 microcuries per milliliter), a value representing 5 percent of the limit of 

1.0  10-12 20 microcurie per milliliter set by the NRC in 10 CFR Part 20, Appendix B, Table 2, 

21 “Effluent Concentrations (retention Class W).” Quality controls on sample recovery, handling, 

22 and analysis would be sufficient to validate results in accordance with Regulatory Guide 4.15 

23 (NRC, 1979). 

24 

25 6.1.3 Wastewater Discharge Monitoring 

26 

27 The proposed EREF design includes liquid waste processing to remove uranic material from the 

28 waste stream by precipitation, filtration, and evaporation. There would be no direct discharge of 

29 process liquid waste effluents onsite or offsite. Therefore, no sampling of liquid process waste 

30 effluents, beyond that described in Table 6-3, is planned. Potentially contaminated liquid 

31 wastes would be processed via the facility’s Liquid Effluent Collection and Treatment System. 

32 Uranic material would be removed from liquid waste effluents through two stages of precipitation 

33 and filtration. Liquid waste effluents would be sampled on an as-needed basis for isotopic 

34 analysis before being discharged to the Liquid Effluent Treatment System Evaporator. The final 

35 process stage of evaporation would release the resulting distillate steam directly to the 

36 atmosphere without condensing vapor out of the air stream. Since multiple stages of 

37 precipitation, filtration, and evaporation would be used to treat liquid effluents, no significant 

38 releases of uranic material to the environment would be expected. However, liquid condensate 

39 in the treatment system evaporator exhaust vent would be sampled periodically as part of the 

40 proposed site’s radiological monitoring program to confirm that no uranic releases have 

41 occurred (Table 6-3). The composition of the sediment layer of the Liquid Effluent Treatment 

42 System Evaporator would also be characterized periodically by isotopic analysis. This data 

43 would be evaluated along with nearby air monitoring data to identify any potential resuspension 

44 of particles in the air (AES, 2010a). 

45 

46 The Domestic Sanitary Sewage Treatment Plant would receive only domestic sanitary wastes. 

47 No plant process-related effluents would be introduced and no releases of uranic material to the 

48 environment would be expected. However, sampling of liquid sanitary waste effluents for 
 6-8 

Table 6-3 Radiological Sampling and Analysis Program for Liquid Waste Effluents 

Sample Type Location Sampling Frequency Type of Analysis 

Wastewater 

Discharge

 

Liquid effluent Collection tanks TBDa; liquid Isotopic analysisb

Liquid condensate Treatment system 

evaporator exhaust vent 

Weekly Gross alpha/beta 

 Treatment system 

evaporator exhaust vent 

Quarterly; composite sample Isotopic analysisb

Sediment Evaporator TBDa 1 to 2 kg (2.2 to 4.4 lb) 

sediment 

Isotopic analysisb

Treated domestic 

sanitary 

wastewater 

TBDc Semiannually; 1 to 2 kg (2.2 to 

4.4 lb) solid fraction 

Isotopic analysisb

Stormwater and 

Basin Sediment

 

Stormwater Once from each of the 

three stormwater basins 

Quarterly; 4-L (1.1-gal) samples Isotopic analysisb

Sediment One from each of three 

stormwater basins 

Quarterly; 1 to 2 kg (2.2 to 

4.4 lb) sediment 

Isotopic analysisb

Groundwater 

Groundwater Nine deep wells and 

one shallow well located 

downgradient, cross 

gradient, and 

upgradient of proposed 

EREF 

Semiannually; 4-L (1.1-gal) 

samples 

Isotopic analysisb

a

 TBD = to be determined, as needed. 

b

 Isotopic analysis for 234U, 235U, 236U, and 238U. c

 TBD = to be determined (but prior to discharge to retention basin). 

Source: AES, 2010a.

1 

2 isotopic analysis prior to discharge (to the Cylinder Storage Pads Stormwater Retention Basins) 

3 is planned as part of the proposed site’s radiological monitoring program to confirm that no 

4 uranic releases have occurred (AES, 2010a). 

5 

6 6.1.4 Stormwater and Basin Sediment Monitoring 

7 

8 Three stormwater basins would collect stormwater runoff at the proposed EREF: one Site 

9 Stormwater Detention Basin, which would receive general site runoff, and two Cylinder Storage 

10 Pads Stormwater Retention Basins, which would receive stormwater runoff from the Cylinder 

11 Storage Pads and treated discharge from the Domestic Sanitary Sewage Treatment Plant. All 

12 three basins would be included in the proposed site’s radiological monitoring program for liquid 

13 waste effluents (AES, 2010a). 

14 
 6-9 

1 Discharge from the Site Stormwater Detention Basin would occur only by evaporation and 

2 infiltration into the ground. Although the basin would be designed to have an outlet structure for 

3 overflow, if needed during a storm event exceeding the design basis, it is not expected that 

4 runoff from this overflow would reach surface water bodies offsite (AES, 2010a). Therefore, no 

5 sampling of stormwater effluents other than for the stormwater basins listed in Table 6-3 is 

6 planned. Since the Site Stormwater Detention Basin would only receive stormwater runoff from 

7 paved surfaces (not including the Cylinder Storage Pad area), building roofs, and landscaped 

8 areas, no significant releases of uranic material to the environment would be expected. 

9 However, stormwater and sediment from the basin (when present) would be sampled 

10 periodically as part of the proposed site’s radiological monitoring program to confirm that no 

11 uranic releases have occurred (Table 6-3). 

12 

13 Discharge from the Cylinder Storage Pads Stormwater Retention Basins would occur only by 

14 evaporation. Although the basin would collect treated sanitary effluents and stormwater runoff 

15 from the concrete-paved areas in the cylinder storage areas, it would not receive process16 related effluents. Therefore, no significant releases of uranic material to the environment would 

17 be expected. However, stormwater and sediment from these basins (when present) would be 

18 sampled periodically as part of the proposed site’s radiological monitoring program to confirm 

19 that no uranic releases have occurred (Table 6-3). 

20 

21 6.1.5 Groundwater Monitoring 

22 

23 Groundwater samples from onsite monitoring wells would be collected semiannually for isotopic 

24 analysis as part of the proposed site’s radiological monitoring program (AES, 2010a). 

25 Section 3.7.2.4 discusses the baseline monitoring for groundwater currently taking place on the 

26 proposed EREF property (baseline monitoring characterizes groundwater prior to construction 

27 and provides a basis for comparison once the plant becomes operational). The locations of the 

28 groundwater monitoring wells are shown in Figure 6-1. Monitoring well locations are based on 

29 the predominant direction of groundwater flow under the proposed EREF site, which is from the 

30 northeast to the southwest, and their proximity to key facility structures. During operation, 

31 samples would be collected twice a year from the same eight monitoring wells that were used 

32 for baseline monitoring and two new deep aquifer wells, which would be installed to the west 

33 and south of the facility footprint. These 10 wells would be used to characterize groundwater 

34 downgradient, cross gradient, and upgradient of the proposed EREF. Groundwater samples 

35 would be analyzed for uranium isotopes (Table 6-3). The minimum detectable concentrations 

(MDCs) for uranium analysis would be 1.1  10-4 becquerel per milliliter (3.0  10-9 36 microcuries 

per milliliter), a value representing less than 2 percent of the annual limit of 3.0  10-7 37 

38 microcuries per milliliter for uranium isotopes in groundwater set by the NRC in 10 CFR Part 20, 

39 Appendix B, Table 2 (AES, 2010a). 

40 

41 The Idaho Department of Environmental Quality (IDEQ) has a statewide network of wells it 

42 monitors to evaluate the overall quality of groundwater throughout the State to meet the 

43 objectives of the State’s Ground Water Quality Protection Act. Any monitoring outside of the 

44 proposed EREF property boundary, therefore, would occur under the aegis of the State’s 

45 groundwater quality monitoring program. 

46 

47 
 6-10 

1 6.1.6 Soil and Vegetation Sampling 

2 

3 Prior to the startup of operations at the proposed EREF, baseline vegetation and soil sampling 

4 would be conducted for the REMP. Samples would be collected quarterly from each sector at 

5 locations near the Owner Controlled Area fence line. The sectors, shown on Figure 6-1, are the 

6 areas identified with the 16 compass directions centered on the proposed EREF. Following the 

7 commencement of facility operations, sampling would be conducted semiannually from nine 

8 sample locations. One sample would be collected from each of eight sectors, three of which 

9 would be those with the highest predicted atmospheric deposition (see Figure 6-1). Samples 

10 would also be collected from an offsite control location. Vegetation and soil samples would be 

11 collected in the same vicinity. Vegetation samples may include vegetable crops and grass, 

12 according to availability. Vegetation and soil samples would each consist of 1–2 kilograms 

13 (2.2–4.4 pounds) of the sampled materials and would undergo isotopic analysis for uranium 

14 (AES, 2010a). 

15 

16 6.1.7 Direct Gamma Radiation Monitoring 

17 

The only significant sources of gamma emitting radionuclides would be due to the decay of 235 18 U 

and 238 19 U progeny associated with the stored UF6 cylinders. Thermoluminescent dosimeters 

20 (TLDs) combined with computer modeling would be used to extrapolate dose from direct 

21 gamma radiation. The environmental TLDs would be placed along the Owner Controlled Area 

22 fence line. In addition, two TLDs would be placed at offsite locations for control purposes 

23 (AES, 2010a). 

24 

25 The offsite TLD control samples would provide information on regional changes of the 

26 background radiation levels. The TLDs along the fence line would provide a combined reading 

27 of background as well as above background readings associated with the UF6 cylinders. The 

28 dosimeters would be analyzed quarterly. The offsite dose equivalent associated with direct 

29 gamma radiation would be estimated through extrapolation of the TLD data using the Monte 

30 Carlo N-Particle (MCNP) (X5 Monte Carlo Team, 2003) or similar computer program 

31 (AES, 2010a). 

32 

33 6.1.8 Monitoring Procedures and Laboratory Standards 

34 

35 The monitoring procedures implemented in the radiological monitoring program would conform 

36 with the guidance found in NRC Regulatory Guide 4.15, “Quality Assurance for Radiological 

37 Monitoring Programs (Inception through Normal Operations to License Termination) – Effluent 

38 Streams and the Environment” (NRC, 1979). 

39 

40 The monitoring procedures would employ well-known and acceptable sampling and analytical 

41 methods. Instrument maintenance and calibration programs would be developed on the basis 

42 of the given instrument in accordance with the manufacturers’ recommendations. Sampling and 

43 measuring equipment would be properly maintained and calibrated at regular intervals. These 

44 maintenance and calibration procedures would include ancillary equipment such as airflow 

45 meters. The radiological monitoring program implementation procedures would include 

46 functional testing and routine checks to demonstrate that monitoring and measuring instruments 

47 are in working condition. 

48 
 6-11 

1 AES would periodically audit the effluent monitoring program. Quality assurance procedures 

2 would be implemented to ensure representative sampling, proper use of appropriate sampling 

3 methods and equipment, proper locations for sampling points, and proper handling, storage, 

4 transport, and analyses of effluent samples. 

5 

6 Regulatory Guide 4.15 calls for the use of established standards such as those provided by the 

7 National Institute of Standards and Technology (NIST) as well as standard analytical 

8 procedures such as those provided by the National Environmental Laboratory Accreditation 

9 Conference (NELAC). 

10 

11 The proposed EREF would ensure that the onsite laboratory and any contractor laboratory 

12 participate in third-party intercomparison programs such as the Mixed Analyte Performance 

13 Evaluation Program (MAPEP), U.S. Department of Energy (DOE) Quality Assurance Program 

14 (DOEQAP), and the Analytics Inc. Environmental Radiochemistry Cross-Check Program. The 

15 proposed EREF would require that all radiological vendors are certified by the National 

16 Environmental Laboratory Accreditation Program (NELAP) or an equivalent State laboratory 

17 accreditation agency for the analytes being tested. 

18 

19 6.1.9 Reporting 

20 

21 As required by 10 CFR 70.59, the proposed EREF would submit a semiannual summary report 

22 of the environmental sampling program to the NRC with all associated data. The report would 

23 include: 

24 

25 • types of samples obtained 

26 

27 • quantities of samples 

28 

29 • frequency of environmental measurements 

30 

31 • radionuclide identities of facility-related radionuclides 

32 

33 • radionuclide activity concentrations of facility-related radionuclides obtained from 

34 environmental sample 

35 

36 Also, the semiannual report would publish the minimal detectable concentrations for the 

37 analyses and the error associated with each measurement. Significant positive trends in activity 

38 concentrations would be presented in the report as well as potential adjustments to the 

39 sampling program, unavailable samples, and deviations to the sampling program. 

40 

41 6.2 Nonradiological Measurements and Monitoring Program 

42 

43 Monitoring and measurement of nonradiological effluents would be conducted under the 

44 proposed facility’s Physiochemical Monitoring Program to verify the effectiveness of effluent 

45 control measures. Nonradiological monitoring encompasses physiochemical measurements in 

46 general, as well as a number of specific monitoring programs. Physiochemical monitoring 

47 would routinely sample chemical contaminants in effluent streams and environmental media. 
 6-12 

1 Specific monitoring programs would address liquid effluents, stormwater, environmental media, 

2 meteorology, and biota. These topics are summarized in the following sections. 

3 

4 6.2.1 Physiochemical Monitoring 

5 

6 A physiochemical monitoring program would be conducted during the operation of the proposed 

7 EREF as part of an environmental protection program to control chemical and other 

8 nonradiological emissions and effluent discharges from the proposed facility. This monitoring 

9 program would confirm that effluent controls are working properly and would alert operators 

10 when they are not, so that corrective measures can be taken. Controls for gaseous and liquid 

11 effluents that would be in place in the proposed facility are discussed in Sections 4.2.4 and 

12 4.2.6, respectively. 

13 

14 Physiochemical monitoring would be conducted by sampling stormwater, soil, sediment, surface 

15 water (if present in intermittent drainages), vegetation, and groundwater as defined in Table 6-4. 

16 Sampling locations are shown in Figure 6-2. Physiochemical monitoring would include effluent 

17 streams directly, as well as potentially affected environmental media, including soil, sediments, 

18 groundwater, surface water, and biota. Specific parameters monitored would include heavy 

19 metals, industrial organic compounds, and pesticides. Water effluents would also be sampled 

20 for fluoride, while gaseous effluents would be also sampled for HF as the fluoride ion. 

21 Additional chemicals may also be monitored, as required by permits, regulations, or other 

22 requirements. 

23 

24 Sampling would be conducted on a routine basis, such as monthly or quarterly, while provisions 

25 would be in place to respond to emergency situations, accidents, or increased emission levels 

26 found in routine sampling. Sampling frequency and locations would be determined by the 

27 proposed EREF environmental staff in accordance with any permit requirements, such as an 

28 NPDES permit for industrial stormwater (Section 6.2.1.2), to demonstrate compliance. All liquid, 

29 solid, and gaseous wastes from enrichment-related processes and decontamination operations 

30 would be analyzed for chemical and radiological properties to determine appropriate disposal 

31 methods or treatment requirements (AES, 2010a). In the event of any accidental release from 

32 the proposed EREF, sampling protocols would be initiated immediately and on a continuing 

33 basis to document the extent and impact of the release until conditions are abated and mitigated 

34 (AES, 2010a). 

35 

36 Effluent compliance levels would be set primarily in the respective permits issued and 

37 administered by U.S. Environmental Protection Agency (EPA) Region 10 and the Idaho 

38 Department of Environmental Quality (IDEQ), namely the NPDES permits issued under 

39 provisions of the Clean Water Act. In order to ensure meeting these levels, administrative 

40 action levels set below permitted levels would be established for all measured parameters prior 

41 to starting operations. Response actions for elevated measurements would be set at three 

42 levels of priority: (1) sample value exceeds three times normal background level, (2) sample 

43 value exceeds any administrative action level, and (3) sample value exceeds any regulatory 

44 limit. Appropriate response actions would be conducted accordingly, ranging from increasing 

45 monitoring frequency to performing corrective actions to prevent exceeding regulatory 

46 compliance levels. 

47 
 6-13 

Table 6-4 Physiochemical Sampling and Analysis Program 

Media Number of Locations Monitoring 

Frequency 

Sample 

Type 

Monitored 

Parametersa

Groundwater Nine deep wells and one 

shallow well (for baseline 

monitoring) 

Semiannually for 

deep wells and for 

shallow wells when 

water is present 

Grab Metals, organics, and 

pesticides; water level 

elevations 

Soil/sediment Three minimum soil 

samples at location to be 

determined; 1 soil/ 

sediment sample at the 

detention basin outfall 

Retention and detention 

basin sediments at 

discharge points to the 

basins 

Quarterly near 

vegetation sample 

locations; one 

sample at each 

location 

Quarterly; one 

sample at each 

location 

Surface 

grab 

Surface 

grab 

Metals, organics, 

pesticides, and 

fluoride uptake 

Metals, organics, 

pesticides, and 

fluoride uptake 

Surface water Potential location in 

intermittent drainages on 

southwestern corner of 

proposed property 

Quarterly, if water 

is present 

Grab Metals, organics, and 

pesticides 

Stormwater Retention and detention 

basins at locations to be 

determined 

Quarterly, if water 

is present 

Grab See Table 6-5 

Vegetationb Four minimum Quarterly, if present 

(i.e., during growing 

seasons); one 

sample at each 

location 

Surface 

grab 

Fluoride uptake 

Meteorology One onsite station 

augmented by records 

from nearby 

meteorological stations 

Daily Continuous Wind direction and 

speed, temperature, 

and humidity 

a

 Analyses would meet EPA lower limits of detection, as applicable, and would be based on the baseline surveys 

and the type of matrix (sample type). 

b

 Location to be established by AES’s Environmental, Health, Safety, and Licensing staff. 

Source: AES, 2010a.

1 

2 Samples would be analyzed mainly in an onsite laboratory in the Technical Services Building 

3 using methods and instrumentation specified in permits or otherwise meeting measurement 

4 quality and performance requirements. A laboratory quality control and quality assurance 

5 program would be implemented that would include written calibration and analysis procedures, 

6 use of laboratory quality control samples, and comparison studies with certified third-party 

7 laboratories. Some specialty analytical services, such as bioassays, may be contracted to an 

8 offsite laboratory as the need arises. 

9 
 6-14 

1 

2 Figure 6-2 Proposed Physiochemical Monitoring Locations (AES, 2010a) 

3 

4 During implementation of the monitoring program, some samples could be collected in a 

5 different manner than what is specified in Table 6-4. Reasons for these deviations could include 

6 severe weather events, changes in the length of the growing season, and changes in the 

7 amount of vegetation present. Under these circumstances, documentation would be prepared 

8 to describe how the samples were collected and the rationale for any deviations from normal 

9 monitoring program methods. If a sampling location has frequent unavailable samples or 

10 deviations from the schedule, then another location could be selected or other appropriate 

11 actions taken. Each year, the AES would submit a summary of the environmental program and 

12 associated data to the IDEQ and/or EPA Region 10, as required under its NPDES permits 

13 issued under IDAPA 58.01.16 and 40 CFR Part 122, respectively. This summary would include 

14 the types, numbers, and frequencies of samples collected (AES, 2010a). 

15 

16 The Potential to Emit (PTE) criteria and hazardous air pollutants of each of the proposed 

17 EREF’s stationary emission sources would be inconsequential with respect to impacts on 

18 ambient air quality, and no operating permits are expected to be necessary for those emission 

19 sources that would require monitoring for ambient air quality impacts. Official ambient air quality 

20 monitoring stations in Idaho Falls operated by the IDEQ would continue to operate. Given the 

21 expected minimal impact on ambient air quality from proposed EREF operations and the current 

22 attainment status of the area with respect to all NAAQS, no additional ambient air quality 
 6-15 

1 monitoring specific to proposed EREF operations and release of nonradioactive pollutants 

2 would be warranted during routine facility operation. 

3 

4 During preconstruction and construction, AES would establish and operate particulate 

5 monitoring stations at locations along the north, south, and east proposed boundaries. These 

6 locations would continue in use during proposed EREF operation to monitor for airborne 

7 radioactive particulates (see Figure 6-1). AES would also review particulate monitoring data 

8 from the State-run monitoring station 20 miles to the east in Idaho Falls to identify impacts from 

9 preconstruction and construction activities at the proposed EREF. No releases of hazardous air 

10 pollutants (HAPs) related to construction have been projected by AES. Based on AES’s 

11 description of the preconstruction and construction activities, NRC staff concurs that no HAPs 

12 would be released. Consequently, no monitoring programs have been suggested and the staff 

13 believes that no HAP monitoring during these phases is necessary. 

14 

15 6.2.1.1 Liquid Effluent Monitoring 

16 

17 Liquid effluent monitoring would be conducted at various locations throughout the proposed 

18 EREF to characterize potential releases other than those associated with wastewater discharge, 

19 which are covered in the radiological monitoring program (Section 6.1.3). Liquid effluent 

20 monitoring would involve both liquid (groundwater, surface water, and stormwater) and solid 

21 (soil or basin sediment) media (Table 6-4). Grab samples would be collected on a semiannual 

22 (groundwater) and quarterly (soil/sediment, surface water, and stormwater) basis and analyzed 

23 for metals, organics, and pesticides (and fluoride uptake in the case of soils and sediments). 

24 For groundwater, water level elevations would also be recorded for both deep wells and shallow 

25 wells (if water is present). Treated sanitary effluents would be sampled for isotopic analysis 

26 prior to being discharged to the retention basins (see Section 6.1.3; Table 6-3). Because 

27 treated sanitary wastewater discharges to the stormwater retention basins, nonradiological 

28 liquid effluent monitoring for sanitary discharge falls under the nonradiological (physiochemical) 

29 stormwater monitoring presented in Tables 6-4 and 6-5 and described in Section 6.2.1.2. 

30 

31 6.2.1.2 Stormwater Monitoring 

32 

33 A stormwater monitoring program would be initiated during preconstruction and construction of 

34 the proposed EREF. Data collected as part of the monitoring program would be used to 

35 evaluate the effectiveness of measures taken to prevent the contamination of stormwater and to 

36 retain sediments within property boundaries. A temporary detention basin would be used as a 

37 sediment control basin during preconstruction and construction as part of the proposed facility’s 

38 overall sedimentation erosion control plan. 

39 

40 During operation of the proposed EREF, the water quality of stormwater discharge would be 

41 typical of runoff from building roofs and paved areas. Except for small amounts of oil and 

42 grease typically found in runoff from paved roadways and parking areas, the discharge would 

43 not be expected to contain contaminants. Stormwater monitoring would continue with the same 

44 frequency upon initiation of operation. During plant operation, samples would be collected from 

45 the two Cylinder Storage Pads Stormwater Retention Basins and the Site Stormwater Detention 

46 Basin (used as a temporary detention basin during preconstruction and construction) to 

47 demonstrate that runoff would not contain any contaminants. Table 6-5 lists the parameters that 

48 would be monitored and their monitoring frequencies. The stormwater monitoring program 
 6-16 

Table 6-5 Stormwater Monitoring Program for Detention and Retention Basinsa

Monitored Parameter Monitoring Frequency Sample 

Type LLDb

Oil and grease Quarterly, if standing water exists Grab 0.5 ppm 

Total suspended solids Quarterly, if standing water exists Grab 0.5 ppm 

Five-day biological oxygen demand Quarterly, if standing water exists Grab 2 ppm 

Chemical oxygen demand Quarterly, if standing water exists Grab 1 ppm 

Total phosphorus Quarterly, if standing water exists Grab 0.1 ppm 

Total kjeldahl nitrogen Quarterly, if standing water exists Grab 0.1 ppm 

pH Quarterly, if standing water exists Grab 0.01 

Nitrate plus nitrite nitrogen Quarterly, if standing water exists Grab 0.2 ppm 

Metals Quarterly, if standing water exists Grab Varies by metal 

a

 Site Stormwater Detention Basin, Cylinder Storage Pads Stormwater Retention Basins, and any temporary 

basin(s) used during preconstruction and construction. 

b

 LLD = lower limit of detection; analyses would meet EPA LLDs, as applicable, and would be based on the baseline 

surveys and the type of matrix (sample type). 

Source: AES, 2010a. 

1 

2 would be refined to reflect the requirements of the NPDES Construction General Discharge 

3 Permit and the General Permit for Industrial Stormwater that AES would obtain from the EPA 

4 Region 10 (AES, 2010a). 

5 

6 6.2.1.3 Environmental Monitoring 

7 

8 An environmental surveillance sampling program would be implemented with the objective of 

9 detecting and monitoring any discernible and relevant effects of plant operations on the 

10 surrounding environment so that appropriate actions could be taken to mitigate effects if 

11 necessary. As noted above, the chemical constituents analyzed would be in accordance with 

12 permits and could include other process or site-related chemicals of interest. Soils, sediments, 

13 surface water, groundwater, and biota would be sampled in areas potentially impacted by 

14 process effluents or runoff from the proposed facility. Sampling would be conducted both onsite 

15 and offsite. 

16 

17 Sampling locations would be selected based on wind patterns, surface runoff patterns, and at, 

18 or down-gradient of, discrete discharge points, including the outfall at the Stormwater Detention 

19 Basin. Groundwater samples would be collected from a series of wells installed around the 

20 facility, as shown in Figure 6-2. Stormwater would be sampled from the Cylinder Storage Pads 

21 Stormwater Retention Basins and from the intermittent stream drainage at the southwest corner 

22 of the proposed property. 

23 

24 Vegetation sampling would include grasses and locally grown vegetable crops. Soils would be 

25 sampled at the same locations as vegetation, including at the outlet at the Stormwater Detention 

26 Basin described in Section 4.2.6. Sediment samples would be collected at the discharge points 

27 of the various collection basins that would exist onsite (AES, 2010a). 

28 
 6-17 

1 6.2.1.4 Meteorological Monitoring 

2 

3 Meteorological parameters of wind speed and direction, air temperature, and humidity would be 

4 continuously monitored at an onsite meteorological tower. Instruments would be located on the 

5 tower at an elevation of 40 meters (132 feet). The tower would be located such that the 

6 instruments would be at the same approximate elevation as effluent emission points and would 

7 be sufficiently distant from buildings and other structures so as not to be influenced by 

8 turbulence caused by those structures. The exact location of the meteorological tower has been 

9 withheld as security-related information. A “clear area” would be maintained for a distance of at 

10 least ten times the height of obstructions located within the prevailing wind directions from the 

11 tower. Quality control programs would use formalized procedures to provide for instrument 

12 calibrations, preventative maintenance and corrective actions, and redundant data capture and 

13 storage such that a data recovery rate of at least 90 percent would be maintained over time. 

14 Real-time meteorological data would be displayed in the Control Room where instrument 

15 malfunctions could be quickly identified and addressed. Real-time data would available for use 

16 in dispersion modeling for both routine and nonroutine (accident) conditions. 

17 

18 6.2.1.5 Local Flora and Fauna 

19 

20 The physiochemical monitoring program would include quarterly sampling of grasses and locally 

21 grown vegetable crops, which would be analyzed for fluoride uptake (Table 6-4). Sampling 

22 locations would be established by AES’s Environmental, Health, Safety, and Licensing staff. 

23 Section 6.2.2 provides a discussion of the monitoring of impacts to biotic communities. 

24 

25 6.2.1.6 Quality Assurance 

26 

27 The onsite analytical laboratory would implement a formal quality assurance/quality control 

28 program to monitor, assess, control, and report to the appropriate agencies the performance of 

29 chemical analyses so that they meet required performance standards specified in permits or 

30 within the standard procedures employed. Generally recognized good laboratory practices 

31 would be employed in all aspects of the analysis. The quality assurance program for 

32 nonradiological analyses would employ similar quality assurance principles as that for 

33 radiological analyses presented in Sections 6.1.8 and 6.1.9. Radiological and nonradiological 

34 programs have traditionally been administered separately at the laboratory level, owing to 

35 technical differences, laboratory access controls, analyst training, and to separate guidance 

36 from different Federal agencies providing technical oversight. Quality assurance programs for 

37 the two technical areas at the proposed EREF would be administered within a single 

38 overarching sampling and analysis organization. Different third-party laboratories would be 

39 involved in separate quality assurance measurement programs involving external parties. 

40 

41 The quality assurance program for both radiological and nonradiological measurements would 

42 be headed by a qualified quality assurance officer and would employ formal written procedures 

43 for all phases of method performance, from sample collection through data management and 

44 reporting. Recognized standard methods would be used that are known to produce results of 

45 the required quality. Chain-of-custody procedures would be followed during handling and 

46 transfer of samples and results. Both field samples and laboratory quality control samples 

47 would be analyzed, including appropriate blank, duplicate, and spiked samples, as well as 

48 laboratory calibration and sample recovery standards. Performance standards would be set to 
 6-18 

1 meet the requirements of the measurement program, and would include standards for lower 

2 limits of detection, sample recovery, and reproducibility of analysis. 

3 

4 Employed outside contract laboratories would have relevant EPA and Idaho certifications. Such 

5 laboratories would likewise follow a formal quality assurance program, including participation in 

6 third-party comparison studies, and would employ methods approved by the proposed EREF’s 

7 laboratory quality assurance officer. 

8 

9 6.2.2 Ecological Monitoring 

10 

11 The ecological monitoring program would characterize changes that may occur in the 

12 composition of biotic communities as a result of preconstruction, construction, and operation of 

13 the proposed EREF. 

14 

15 The program would focus on observable changes in habitat characteristics and wildlife 

16 populations. 

17 

18 The ecological monitoring program would be carried out in accordance with generally accepted 

19 monitoring practices and the requirements of the Idaho Department of Fish and Game and the 

20 U.S. Fish and Wildlife Service. Under the program, data would be collected, recorded, stored, 

21 and analyzed. Procedures would be established, as appropriate, for data collection, storage, 

22 analysis, reporting, and corrective actions. Actions would be taken as necessary to reconcile 

23 anomalous results (AES, 2010a). 

24 

25 6.2.2.1 Monitoring Program Elements 

26 

27 The elements that would be included in the ecological monitoring program are vegetation, birds, 

28 mammals, and herpetiles (reptiles and amphibians). There are currently no action levels or 

29 reporting levels for any of these elements. However, consultations would continue with all 

30 appropriate agencies, such as the U.S. Fish and Wildlife Service, Bureau of Land Management, 

31 and Idaho Department of Fish and Game. Agency recommendations, based on future 

32 consultations and reviews of monitoring program data, would be considered in the development 

33 of action levels and/or reporting levels for each element (AES, 2010a). 

34 

35 In addition, to reduce potential impacts on birds and other wildlife, AES would periodically 

36 monitor the proposed site during the preconstruction, facility construction, and operation 

37 phases, including sampling of detention-basin and retention-basin waters. Measures would be 

38 taken to release any entrapped wildlife. The monitoring program would include an assessment 

39 of the effectiveness of entry barriers and release features (AES, 2010a). In addition, for the first 

40 five years following the completion of the new transmission line, AES would conduct annual 

41 surveys of the transmission line route for avian mortalities, including sage-grouse, due to 

42 collision or electrocution (AES, 2010b). These surveys would consist of in-vehicle observations 

43 while driving along the transmission line right-of-way. Remedial measures, such as high-visibility 

44 line markers, would be considered if surveys indicate the need. If perching of raptors or corvids 

45 that would imperil sage-grouse populations is discovered, remedial measures, such as anti46 perching devices, would be considered. 

47 
 6-19 

1 6.2.2.2 Observations and Monitoring Program Design 

2 

3 The overall monitoring program would include preconstruction, construction, and operations 

4 monitoring programs. The preconstruction monitoring program would be conducted prior to the 

5 initiation of construction activities and would establish the baseline ecological conditions on the 

6 proposed EREF property. The monitoring procedures used to characterize the vegetation, bird, 

7 mammal, and herpetile communities during preconstruction monitoring would also be used for 

8 the construction and operations monitoring programs (AES, 2010a). 

9 

10 Surveys for the construction and operations monitoring program would use the same monitoring 

11 locations established for the preconstruction monitoring program. These surveys are designed 

12 to detect broad changes in the composition of the biotic communities that may be associated 

13 with the construction and operation of the proposed EREF. Changes resulting from natural 

14 succession processes would be considered in the interpretation of the results of the construction 

15 and operations monitoring program, because it is expected that plant communities on the 

16 proposed property would undergo successional changes, even in the absence of the proposed 

17 EREF project, with concomitant changes in the bird, mammal, and herpetile communities 

18 (AES, 2010a). 

19 

20 No specific monitoring equipment would be needed for the ecological monitoring, due to the 

21 type of monitoring proposed for the program as described above (AES, 2010a). Data collected 

22 for the ecological monitoring program would be recorded on paper and/or electronic forms. 

23 These data would be kept on file for the life of the proposed facility (AES, 2010a). 

24 

25 The monitoring program analyses would include descriptive statistics that would include the 

26 mean, standard deviation, standard error, and confidence interval for the mean. For each study, 

27 the sample size would be indicated. These standard descriptive statistics would be used to 

28 assess sample variability. For these studies, a significance level of 5 percent would be used, 

29 resulting in a 95 percent confidence level (AES, 2010a). 

30 

31 The data collected for the ecological monitoring program would be analyzed by the 

32 Environment, Health, and Safety Manager or a staff member reporting to the manager. 

33 A summary report would be prepared and would include spatial and temporal information 

34 regarding species composition and distribution and the relative abundance of key species 

35 (AES, 2010a). 

36 

37 Vegetation

38 

39 Monitoring plant communities would include estimates of ground cover at about 20 permanent 

40 monitoring locations. The establishment of permanent monitoring locations would allow for the 

41 long-term evaluation of vegetation trends and characteristics of the proposed EREF property. 

42 Monitoring would be conducted annually in June, coinciding with the flowering period of the 

43 dominant perennial species. The selected monitoring locations would be positioned within the 

44 proposed EREF property, outside the proposed facility footprint. Global Positioning System 

45 coordinates would be recorded and used to identify and relocate the monitoring points 

46 (AES, 2010a). Figure 6-3 shows the positions of the monitoring locations. 

47 
 6-20 

1 

Figure 6-3 Vegetation Sampling Locations (AES, 2010a) 2 
 6-21 

1 Using the point-transect method, monitoring data would be collected from the sagebrush steppe 

2 and disturbed sagebrush steppe habitats. Two 50-meter (164-foot) transect lines would extend 

3 from a randomly selected point at each monitoring location, one transect oriented to the east 

4 and the other to the south. Observation data would be collected at points located at intervals 

5 along the transect lines. Ground surface data (e.g., bare soil, leaf litter) on overstory and 

6 understory species that are intersected by the data points would be recorded. Data analysis 

7 would determine species composition and ground surface characteristics. In addition to 

8 preconstruction and construction monitoring, operations monitoring would initially be conducted 

9 through at least the first 3 years of plant operation. Subsequently, changes to the monitoring 

10 program may be initiated based on operational experience (AES, 2010a). 

11 

12 Wildlife

13 

14 Wildlife monitoring surveys would be conducted to record the presence of mammals, birds, and 

15 herpetiles in the vicinity of the proposed EREF site. Wildlife monitoring would be designed to 

16 identify species and provide estimates of abundance. The surveys would be conducted 

17 annually in late spring/early summer and late fall/early winter. Data recorded each sampling 

18 day would include weather conditions (e.g., temperature, wind speed and direction, humidity, 

19 cloud cover). Changes in weather conditions during sampling would also be recorded. No 

20 surveys would be conducted when weather conditions (e.g., rain, heavy snow, high winds) 

21 reduce the likelihood of wildlife observations due to reduced animal activity or reduced visibility 

22 (AES, 2010a). 

23 

24 Permanent parallel transects, 1.6 kilometers (1.0 mile) in length and separated by 0.4 to 

25 0.8 kilometers (0.25 to 0.50 miles), would be located in the sagebrush steppe and disturbed 

26 sagebrush steppe habitats. Transects would be walked from 30 minutes before sunrise to 

27 1.5 hours after sunrise and 1.5 hours before sunset to 30 minutes after sunset. Data collected 

28 would include visual observations of animals, signs (e.g., tracks, droppings, feathers, nests, 

29 burrows), and calls. Species composition and relative abundance would be determined. 

30 Gender and age (e.g., juvenile, adult) would be recorded when possible. Data would also 

31 include behavior (flight, singing, territory establishment, nesting, perching). In addition to 

32 preconstruction and construction monitoring, operations monitoring would initially be conducted 

33 through at least the first 3 years of plant operation. Subsequently, changes to the monitoring 

34 program may be initiated based on operational experience (AES, 2010a). 

35 

36 Birds

37 

38 Surveys of bird populations would be conducted twice each year, in late spring during breeding, 

39 nesting, and brood rearing seasons, and also during the winter. Recorded data would include 

40 species and numbers of individuals observed, as well as behavior. Data would be compared to 

41 information regarding birds listed in Table 6-6 as potentially using the proposed EREF property 

42 (AES, 2010a). 

43 

44 Mammals

45 

46 Surveys of mammal populations would be conducted twice each year, in late spring during 

47 breeding and nursing season and during late fall/winter during migration and movements to 

48 winter range. Recorded data would include species and numbers of individuals observed, as 
 6-22 

Table 6-6 Birds Potentially Using the Proposed EREF Property 

Common Name Scientific Name Summer 

Breeder Wintering Resident Migrant 

Turkey vulture Cathartes aura Ua U −a Aa

Osprey Pandion haliaetus – − − Ra

Bald eagle Haliaeetus leucocephalus − U − R 

Northern harrier Circus cyaneus − − Ca −

Sharp-shinned hawk Accipiter striatus R R − R 

Cooper’s hawk Accipiter cooperii U R − R 

Swainson’s hawk Buteo swainsoni U R − U 

Red-tailed hawk Buteo jamaicensis U R − R 

Ferruginous hawk Buteo regalis U R − R 

Rough-legged hawk Buteo regalis C A − C 

Golden eagle Aquila chrysaetos U C − U 

American kestrel Falco sparverius C U − C 

Merlin Falco columbarius − − R −

Peregrine falcon Falco peregrinus − − R −

Gyrfalcon Falco rusticolus − − − A 

Prairie falcon Falco mexicanus − − U −

Chukar Alectoris chukar − − U −

Greater sage-grouse Centrocercus urophasianus − − C −

Kildeer Charadrius vociferus C − − C 

Long-billed curlew Numenius americanus U − − U 

Franklin’s gull Larus pipixcan U − − U 

Ring-billed gull Larus delawarensis U − − U 

California gull Larus californicus R − − U 

Herring gull Larus argentatus U − − U 

Mourning dove Zenaida macroura C R − C 

Great horned owl Bubo virginianus − − U −

Burrowing owl Athene cunicularia U A − U 

Short-eared owl Asio flammeus U − − U 

Northern sawwhet owl Aegolius acadicus − A − A 

Common nighthawk Chordeiles minor C − − U 

Horned lark Eremophila alpestris C C − C 

Black-billed magpie Pica pica − − C −

American crow Corvus brachyrhynchos − − U −
 6-23 

Table 6-6 Birds Potentially Using the Proposed EREF Property (Cont.) 

Common Name Scientific Name Summer 

Breeder Wintering Resident Migrant 

Common raven Corvus corax − − U −

Rock wren Salpinctes obsoletus U − − U 

Canyon wren Catherpes mexicanus R − − R 

House wren Troglodytes aedon U U − U 

Western bluebird Sialia mexicana U − − U 

American robin Turdus migratorius C − − C 

Sage thrasher Oreoscoptes montanus C − − C 

Northern shrike Lanius excubitor − R − U 

Loggerhead shrike Lanius ludovicianus − − U −

European starling Sturnus vlugaris − − C −

Black-headed grosbeak Pheucticus melanocephalus R − − R 

Green-tailed towhee Pipilo chlorurus U − − U 

Rufous-sided towhee Pipilo erythrophthalmus U − − U 

Brewer’s sparrow Spizella breweri C − − C 

Lark sparrow Chondestes grammacus U − − R 

Black-throated sparrow Amphispiza bilineata R − − R 

Sage sparrow Amphispiza belli C − − C 

Lark bunting Calamospiza melanocorys R − − R 

White-crowned sparrow Zonotrichia leucophrys − − − R 

Vesper sparrow Pooecetes gramineus U − − U 

Chipping sparrow Spizella passerina − − − R 

Grasshopper sparrow Ammodramus savannarum U − − U 

Brown-headed cowbird Molothrus ater − − − U 

Snow bunting Plectrophenax nivalis − R − R 

Red-winged blackbird Agelaius phoeniceus U − − U 

Western meadowlark Sturnella neglecta C U − C 

Brewer’s blackbird Euphagus cyanocephalus C R − C 

Rosy finch Leucosticte arctoa − R − R 

House sparrow Passer domesticus C U − C a

 U = Species likely would be uncommon onsite if observed at all; C = Species likely would be common onsite; R = Species likely 

would be rare onsite if observed at all; A = Accidental occurrence; – = Not applicable. 

Source: AES, 2010a.

1 
 6-24 

1 well as behavior (e.g., fleeing, feeding, or resting). Data would be compared to information 

2 regarding mammals listed in Table 6-7 as potentially using the proposed EREF property 

3 (AES, 2010a). 

4 

5 Herpetiles

6 

7 Surveys of reptile and amphibian populations would be conducted once each year, during the 

8 summer when these species are most active. Recorded data would include species and 

9 numbers of individuals observed, as well as behavior (e.g., breeding, display, feeding, resting, 

10 or thermoregulating). Data would be compared to information regarding reptiles and 

11 amphibians listed in Table 6-8 as potentially using the proposed EREF property (AES, 2010a). 

12 

13 6.3 References 

14 

15 (AES, 2010a) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

16 Environmental Report, Rev. 2.” Bethesda, Maryland. April. 

17 

18 (AES, 2010b) AREVA Enrichment Services, LLC. Letter from J.A. Kay (Licensing Manager, 

19 AES) to Sharon W. Kiefer (Assistant Director-Policy, IDFG) dated December 7, 2010, “Subject: 

20 Response to IDFG Comments to NRC Related to the EREF Transmission Line.” ADAMS 

21 Accession No. ML103420579. 

22 

23 (NRC, 1979) U.S. Nuclear Regulatory Commission. “Quality Assurance for Radiological 

24 Monitoring Programs (Normal Operations) – Effluent Streams and the Environment.” 

25 Regulatory Guide 4.15, Rev. 1. February. 

26 

27 (NRC, 1985) U.S. Nuclear Regulatory Commission. “Monitoring and Reporting Radioactivity in 

28 Releases of Radioactive Materials in Liquid and Gaseous Effluent from Nuclear Fuel Processing 

29 and Fabrication Plants and Uranium Hexafluoride Production Plants.” Regulatory Guide 4.16, 

30 Rev. 1. December. 

31 

32 (NRC, 1991) U.S. Nuclear Regulatory Commission. “Offsite Dose Calculation Manual 

33 Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors.” NUREG-1302. 

34 Generic Letter 89-01, Supplement No. 1. 

35 

36 (X5 Monte Carlo Team, 2003) X5 Monte Carlo Team. “MCNP – A General Monte Carlo 

37 N-Particle Transport Code, Version 5.” LA-UR-0301987. April 24. 

38 
 6-25 

Table 6-7 Mammals Potentially Using the Proposed EREF Property 

Common Name Scientific Name Preferred Habitat Probable 

Occurrence 

Little brown 

myotis 

Myotis lucifugus Coniferous forest, riparian areas in the 

mountains and lower valleys, woodlots, 

shelterbelts, and urban areas. 

Unlikely to occur 

due to lack of 

suitable habitat. 

Townsend’s 

bigeared bat 

Plecotus 

townsendii

Desert scrub, mixed conifer forest, and 

piñon-juniper habitat. Specifically 

associated with limestone caves, 

mines, lava tubes. 

Unlikely to occur 

due to lack of 

suitable habitat. 

White-tailed jack 

rabbit 

Lepus townsendii Found in open grasslands and 

montane shrublands generally above 

shrub steppe. 

Probably occurs at 

the property in 

limited numbers due 

to lack of habitat. 

Black-tailed jack 

rabbit 

Lepus californicus A habitat generalist, primarily found in 

arid regions supporting shortgrass 

habitats. 

Likely occurs at the 

property. 

Mountain 

cottontail 

Sylvilagus nattallii Brushy, rocky areas in dense 

sagebrush and streamside thickets and 

forest edges. 

Likely occurs at the 

property. 

Yellow-bellied 

marmot 

Marmota 

flaviventris 

Prefers montane meadows adjacent to 

talus slopes or rock outcrops; avoids 

tall vegetation. 

Unlikely to occur 

due to lack of 

suitable habitat. 

Pygmy rabbit Brachylagus 

idahoensis 

Big sagebrush habitat and secondarily 

in communities dominated by 

rabbitbrush. 

Potentially occurs at 

the property. 

Townsend’s 

ground squirrel 

Spermophilus 

townsendii 

Arid environments with deep, friable, 

well-drained soils. 

Likely occurs at the 

property. 

Least chipmunk Eutamias minimus Sagebrush, bitterbrush, and other 

Great Basin shrub habitats. 

Likely occurs at the 

property. 

Northern pocket 

gopher 

Thomomys 

talpoides 

Mountain meadows, tundra, 

grasslands, sagebrush steppe, and 

agricultural fields – habitats lacking 

canopy cover but having abundant 

ground cover. 

Probably occurs at 

the property in 

limited numbers due 

to lack of habitat. 

Great basin 

pocket mouse 

Perognathus 

parvus 

Arid, sparsely vegetated plains and 

brushy areas. 

Likely occurs at the 

property. 

Ord’s kangaroo 

rat 

Dipodomys ordii Semiarid, open habitats. Big 

sagebrush/crested wheatgrass range; 

disturbed sites. 

Likely occurs at the 

property. 

Beaver Castor 

canadensis 

Stable aquatic habitats providing 

adequate water, channel gradient of 

less than 15 percent, and quality food 

species. 

Unlikely to occur 

due to lack of 

suitable habitat. 

1 
 6-26 

Table 6-7 Mammals Potentially Using the Proposed EREF Property (Cont.) 

Common Name Scientific Name Preferred Habitat Probable 

Occurrence 

Western harvest 

mouse 

Reithrodontomys 

megalotis 

Open areas, including grasslands, 

prairies, meadows, and arid areas 

including deserts, sand dunes, and 

shrublands. 

Likely occurs at the 

property. 

Deer mouse Peromyscus 

maniculatus 

Most common habitats are prairies, 

bushy areas, and woodlands. 

Likely occurs at the 

property. 

Coyote Canis latrans Extremely adaptable; uses a wide 

range of habitats, including forests, 

grasslands, deserts. 

Likely occurs at the 

property. 

Long-tailed 

weasel 

Mustela frenata Upland brush, grasslands and woods 

to subalpine rock slides and semi-open 

forest areas. 

Probably occurs at 

the property in 

limited numbers due 

to lack of habitat. 

Badger Taxidea taxus Occurs primarily in grasslands, 

shrublands, and other treeless areas 

with friable soil and a supply of rodent 

prey. 

Likely occurs at the 

property. 

Canada lynx Lynx canadensis Canada lynxes require early, mid- and 

late-successional forests. 

Unlikely to occur 

due to lack of 

suitable habitat. 

Bobcat Lynx rufus Adapted to a wide variety of habitats, 

including canyons, deserts, and 

mountain ranges. Bobcats are found 

in desert environments if shade is 

available. 

Probably occurs at 

the property in 

limited numbers due 

to lack of habitat. 

Elk Cervus elaphus Found mostly in mountain or foothill 

areas; prefer alpine meadows in 

summer and then move to lower, 

wooded slopes or sagebrush steppe in 

winter. 

Likely occurs at the 

property. 

Mule deer Odocoileus 

hemionus 

Coniferous forests, shrub steppe, 

chaparral, and grasslands, from dry, 

open country to dense forests. Prefer 

arid open areas and rocky hillsides. 

Probably occurs at 

the property in 

limited numbers due 

to lack of habitat. 

Pronghorn Antilocapra 

americana 

Open plains and semi-deserts; often 

found on low, rolling, expansive lands 

with less than 30 percent slope. 

Likely occurs at the 

property. 

Source: AES, 2010a. 

1 
 6-27 

Table 6-8 Amphibians and Reptiles Potentially Using the Proposed EREF Property 

Common Name Scientific Name Preferred Habitat Probable 

Occurrence 

Great Basin 

spadefoot toad 

Spea intermontana Sagebrush communities below 

6,000 feet in elevation having loose 

soil in which to burrow. Breeding 

habitat is aquatic. 

Unlikely to occur due 

to lack of aquatic 

habitat. 

Long-nosed 

leopard lizard 

Gambelia wislizenii Arid and semi-arid plains with 

sagebrush, grass, and other low 

scattered vegetation. Prefers flat 

areas with open space for running, 

avoiding densely vegetated areas. 

Probably occurs at 

the property in 

limited numbers due 

to lack of habitat. 

Short-horned 

lizard 

Phrynosoma 

douglassi 

Open pine forests, pinion-juniper 

forests, shortgrass prairies, and 

sagebrush desert. 

Likely occurs at the 

property. 

Sagebrush lizard Sceloporus 

graciosus 

Sagebrush and other types of 

shrublands, in open areas with 

scattered low bushes and lots of sun. 

Likely occurs at the 

property. 

Western skink Eumeces 

skiltonianus 

Piñon-juniper forests, grassy areas, 

desert shrub, talus slopes, and canyon 

rims; often found in areas associated 

with water. 

Unlikely to occur due 

to lack of suitable 

habitat. 

Rubber boa Charina bottae Desert shrub to open pine forest. 

Often near water and near rocks, 

woody debris, or leaf litter that are 

used for cover. 

Unlikely to occur due 

to lack of suitable 

habitat. 

Desert striped 

whipsnake 

Masticophis 

taeniatus 

Occurs in open brushy country-desert 

scrub, sagebrush flats, and mixed 

woodlands. Often found along the 

edges of rivers or ponds. 

Probably occurs at 

the property in 

limited numbers due 

to lack of habitat. 

Gopher snake Pituophis catenifer Grassland, sagebrush, agricultural 

lands, riparian areas, woodlands, 

desert. 

Likely occurs at the 

property. 

Western 

terrestrial garter 

snake 

Thamnophis 

elegans 

Found statewide in habitats ranging 

from desert riparian areas to mountain 

lakes and meadows. 

Probably occurs at 

the property in 

limited numbers due 

to lack of habitat. 

Western 

rattlesnake 

Crotalus viridis Drier regions with sparse vegetation, 

usually with a rocky component. 

Likely occurs at the 

property. 

Source: AES, 2010a.

1 

 7-1 

1 7 BENEFIT-COST ANALYSIS 

2 

3 A benefit-cost analysis can provide a rationale for deciding whether a project is likely to have a 

4 net positive economic impact, by aggregating each of the costs and benefits resulting from the 

5 project. A benefit-cost analysis involves valuing the benefits and costs associated with projects 

6 in monetary terms, to the extent possible. Depending on the extent of the data available, 

7 benefit-cost analyses may rely entirely or partially on qualitative data to assess the various costs 

8 and benefits, with the methodology employed for a benefit-cost analysis usually being 

9 dependent on the specific issues involved in a project. Costs and benefits are often separated 

10 into two categories, private and societal. Private costs and benefits are those that impact the 

11 owner of a project or facility, in this case AREVA Environmental Services, LLC (AES), while 

12 societal costs and benefits are those that impact society as a whole. Much of the data 

13 associated with preconstruction, construction, and operation of the proposed Eagle Rock 

14 Enrichment Facility (EREF) in Bonneville County, Idaho, that would be used to assess the 

15 private costs of the proposed EREF, the costs of constructing and operating the facility, are 

16 proprietary commercial information, withheld in accordance with Title 10, “Energy,” of the 

17 U.S. Code of Federal Regulations (10 CFR 2.390). These costs are presented in a proprietary 

18 appendix to this Environmental Impact Statement (EIS), Appendix H, and are not discussed in 

19 this chapter. As such, Appendix H is not included in the publicly available version of this EIS. 

20 Additional data associated with operation of the facility, regarding annual revenues from the sale 

21 of enriched uranium, was not available, meaning that no estimate of the private benefits of the 

22 facility can be made. 

23 

24 As a result of the lack of data that can be publicly disclosed or is otherwise available, the 

25 analysis in this chapter focuses on the various societal costs and benefits associated with 

26 preconstruction, the proposed action, and the no-action alternative using data provided by AES 

27 in its license application and Environmental Report (AES, 2010a). These data include the 

28 economic and fiscal benefits of preconstruction, facility construction, and operation to the region 

29 of influence (ROI) (defined in Section 7.1) in which the plant would be located, and to the Idaho 

30 State economy. Also discussed are the benefits of the plant in fulfilling the need for enriched 

31 uranium to meet domestic electricity requirements, for domestic supplies of enriched uranium 

32 for national energy security, and for upgraded uranium enrichment technology in the 

33 United States for energy generation with fewer emissions of criteria pollutants and carbon. 

34 Societal costs considered include those related to impacts on land use, historical and cultural 

35 resources, visual and scenic resources, air quality, geology and soil, water resources, ecological 

36 resources, environmental justice, noise, transportation, public and occupational health, waste 

37 management, and accidents. 

38 

39 The chapter compares the societal benefits and costs both quantitatively, in monetary terms 

40 where possible, and qualitatively. Section 7.1 weighs the costs and benefits associated with 

41 preconstruction and the proposed action. Section 7.2 then compares the costs and benefits for 

42 preconstruction and the proposed action relative to those of the no-action alternative. 

43 Section 7.3 combines these two sections in forming overall conclusions. Alternatives that have 

44 previously been ruled out for failing to meet the proposed project’s technical and policy 

45 objectives are described in Section 2.2.4 and are not revisited in this chapter. 

46 
 7-2 

1 7.1 Costs and Benefits of Preconstruction and the Proposed Action 

2 

3 The proposed action is for AES to construct, operate, and decommission a gas centrifuge 

4 uranium enrichment facility in Bonneville County, Idaho. To allow the proposed action to take 

5 place, the NRC would issue a license for AES under the provisions of the Atomic Energy Act. 

6 The license would authorize AES to possess and use special nuclear material, source material, 

7 and byproduct material at the proposed EREF for a period of 30 years, in accordance with the 

8 NRC’s regulations in 10 CFR Parts 70, 40, and 30, respectively. The proposed EREF would be 

9 constructed over an eleven-year period. Enrichment operations would begin in 2014, continuing 

10 until 2041, when production would gradually decrease as decommissioning begins. 

11 

12 As discussed in Section 3.12 of this EIS, the principal socioeconomic benefit of the proposed 

13 EREF would be an increase in employment and income in the ROI, defined as the 11-county 

14 area in which workers at the proposed facility would live and spend their wages and salaries. 

15 Although the majority of the costs, and most of the socioeconomic impacts, of the various 

16 phases of development of the proposed EREF would occur in the 11-county ROI, the majority of 

17 the economic and fiscal benefits would occur in a 2-county ROI consisting of Bingham and 

18 Bonneville Counties. The uranium enrichment technology and energy security benefits of the 

19 facility would occur at the national level. 

20 

21 This section describes the costs and benefits of construction and operation of the proposed 

22 EREF and those associated with preconstruction. Quantitative estimates (in terms of dollars) 

23 are provided where possible. Other costs and benefits are described in qualitative terms. 

24 

25 7.1.1 Costs of Preconstruction and the Proposed Action 

26 

27 The direct costs associated with the proposed action may be categorized by the following life28 cycle stages: 

29 

30 • facility construction 

31 

32 • facility operation 

33 

34 • depleted uranium disposal 

35 

36 • decommissioning 

37 

38 In addition to the costs of the proposed action, costs would be incurred for preconstruction 

39 under both the proposed action and the no-action alternative. 

40 

41 As the monetary costs associated with the preconstruction, construction, and operations phases 

42 of the proposed EREF are withheld under the provisions of 10 CFR 2.390, the costs associated 

43 with each of these life-cycle stage are discussed and summarized in a proprietary appendix, 

44 Appendix H, and summarized in Table H-1. As decommissioning activities for the proposed 

45 EREF are anticipated to occur more than 20 years in the future, costs associated with this 

46 phase of the proposed action cannot be estimated with any certainty at this time. It is expected, 

47 however, that annual decommissioning costs would be less than the annual costs of operating 

48 the facility. 

49 
 7-3 

1 In addition to monetary costs, preconstruction and the proposed action would result in impacts 

2 on various resource areas, which are considered “costs” for the purpose of this analysis. The 

3 resource areas and corresponding impacts are summarized below and described in more detail 

4 in Chapter 4 of this EIS. As summarized below, the impacts of preconstruction and the 

5 proposed action on the various resource areas would be mostly SMALL, with MODERATE 

6 impacts in a few cases. Any LARGE impacts would generally be very temporary and 

7 intermittent in nature, or would be reduced to MODERATE with the appropriate mitigation 

8 measures. 

9 

10 • Land Use. As described in Section 4.2.1, the proposed EREF would be located entirely on 

11 private land. The operation of a uranium enrichment facility is consistent with the county’s 

12 zoning. Current agricultural uses of the proposed EREF property would be curtailed, but 

13 similar activities would continue over large land areas surrounding the proposed EREF 

14 property and vicinity. For example, it is not anticipated that preconstruction, construction, 

15 and operation of the proposed EREF would have any effect on current land uses found on 

16 the surrounding Federal lands administered by the U.S. Bureau of Land Management. Land 

17 use impacts resulting from preconstruction, construction, and operation would be SMALL. 

18 

19 • Historic and Cultural Resources. As described in Section 4.2.2, there are 13 cultural 

20 resource sites in the immediate vicinity of the proposed EREF. Only one of these sites is 

21 eligible for listing on the National Register of Historic Places, the John Leopard Homestead 

22 (site MW004). This site is within the construction footprint of the proposed EREF. 

23 Preconstruction activities would destroy site MW004 and the resulting impacts would be 

24 LARGE, but were considered MODERATE because the appropriate mitigation, involving 

25 professional excavation of, and data recovery at, site MW004 was implemented by AES and 

26 other homestead sites of this type exist in the region (WCRM, 2010; Idaho, SHPO 2010b; 

27 Gilbert, 2010). Other than for site MW004, the impacts of the proposed project on historic 

28 and cultural resources would be SMALL. 

29 

30 • Visual and Scenic Resources. As described in Section 4.2.3, preconstruction and 

31 construction equipment and the industrial character of the proposed EREF buildings would 

32 create significant contrast with the surrounding visual environment of the primarily 

33 agricultural and undeveloped rangeland. The proposed facility would be about 

34 2.4 kilometers (1.5 miles) from public viewing areas such as US 20 and the Hell’s Half Acre 

35 Wildlife Study Area (WSA); thus, the impact on views would be SMALL to MODERATE. 

36 

37 • Air Quality. As described in Section 4.2.4, preconstruction and construction traffic and 

38 operation of construction equipment are projected to cause a temporary increase in the 

39 concentrations of particulate matter. These impacts would be SMALL. However, fugitive 

40 dust from land clearing and grading operations could result in large releases of particulate 

41 matter for temporary periods of time. Such impacts would be MODERATE to LARGE during 

42 certain preconstruction periods and activities. Facility operations could produce small 

43 gaseous releases associated with operation of the process that could contain uranium 

44 compounds and hydrogen fluoride. Small amounts of nonradioactive air emissions would 

45 consist of carbon monoxide (CO), nitrogen oxides (NOx), particulate matter (PM), volatile 

46 organic compounds (VOCs), and sulfur dioxide (SO2). Air quality impacts during operations 

47 would be SMALL. 

48 
 7-4 

1 • Geology and Soil. As described in Section 4.2.5, impacts could result primarily during 

2 preconstruction and construction from surface grading and excavation activities that loosen 

3 soil and increase the potential for erosion by wind and water. Soil compaction as a result of 

4 heavy vehicle traffic could also increase the potential for soil erosion by increasing surface 

5 runoff. Spills and inadvertent releases during all project phases could contaminate site 

6 soils. Implementation of mitigation measures would ensure that these impacts would be 

7 SMALL. 

8 

9 • Water Resources. As described in Section 4.2.6, the water supply for the proposed facility 

10 would be from onsite wells, and water usage would be well within the water appropriation for 

11 the proposed property. Also, the plant would have no discharges to surface water or 

12 groundwater. Thus, water resource impacts would be SMALL. 

13 

14 • Ecological Impacts. As described in Section 4.2.7, impacts would occur primarily as a result 

15 of preconstruction and construction activities, which would mean the removal of shrub 

16 vegetation and the relocation and displacement of wildlife presently on the proposed site as 

17 a result of noise, lighting, traffic, and human presence. Collisions with vehicles, construction 

18 equipment, and fences may cause some wildlife mortality. No rare or unique communities 

19 or habitats or Federally listed threatened or endangered species have been found or are 

20 known to occur on the proposed site. The impact of the proposed EREF on ecological 

21 resources would be SMALL to MODERATE. 

22 

23 • Noise. As described in Section 4.2.8, increased noise associated with the operation of 

24 construction machinery is expected during preconstruction and construction, with noise 

25 levels of between 80 to 95 dBA at the highway entrances, access roads, and the Visitor 

26 Center. Construction noise would be temporary and would be reduced to about 51 to 

27 66 dBA at the nearest hiking trail point on the Hell’s Half Acre WSA. Impacts would be 

28 SMALL. Impacts during the operation of the facility itself would also be SMALL. 

29 

30 • Transportation. As described in Section 4.2.9, the primary impact of preconstruction, 

31 construction, and operation on transportation resources is expected to be increased traffic 

32 on nearby roads and highways due to truck shipments and site worker commuting. 

33 Transportation impacts during preconstruction, construction, and facility operation would be 

34 SMALL to MODERATE on adjacent local roads (due to the potentially significant increase in 

35 average daily traffic), but regional impacts would be SMALL. 

36 

37 • Public and Occupational Health. As described in Section 4.2.10, the analysis of 

38 nonradiological impacts during preconstruction and construction includes estimated 

39 numbers of injuries and illnesses incurred by workers and an evaluation of impacts due to 

40 exposure to chemicals and other nonradiological substances, such as particulate matter 

41 (dust) and vehicle exhaust. All such potential nonradiological impacts would be SMALL. No 

42 radiological impacts are expected during preconstruction and initial facility construction, prior 

43 to radiological materials being brought onsite. Operation of the proposed EREF could result 

44 in release of small quantities of UF6 during normal operations. Total uranium released to the 

45 environment via airborne effluent discharges is anticipated to be less than 10 grams 

46 (6.84 μCi or 0.253 MBq) per year. No liquid effluent wastes are expected from facility 

47 operation. For a hypothetical member of the public at the proposed property boundary, the 

48 annual dose was estimated to be approximately 0.014 millisievert per year (1.4 millirem per 
 7-5 

1 year). Doses attributable to normal operation of the proposed EREF facility would be small 

2 compared to the normal background dose range of 2.0 to 3.0 millisievert (200 to 

3 300 millirem). Radiological impacts during operations would be SMALL. 

4 

5 • Waste Management. As described in Section 4.2.11, small amounts of hazardous waste 

6 and approximately 6116 cubic meters (8000 cubic yards) of nonhazardous and 

7 nonradioactive wastes would be generated during preconstruction and construction 

8 activities. During operations, approximately 75,369 kilograms (165,812 pounds) of solid 

9 nonradioactive waste would be generated annually, including approximately 5062 kilograms 

10 (11,136 pounds) of hazardous wastes. Approximately 146,500 kilograms (322,300 pounds) 

11 of radiological and mixed waste would be generated annually, of which approximately 

12 100 kilograms (220 pounds) would be mixed waste. All wastes would be transferred offsite 

13 to licensed waste facilities with adequate disposal capacity for the wastes from the proposed 

14 EREF. Overall, impacts would be SMALL. 

15 

16 • Socioeconomics. As described in Section 4.2.12, there would be increases in regional 

17 employment, income, and tax revenue during preconstruction, construction, and operation. 

18 Although these impacts would be SMALL compared to the 11-county economic baseline, 

19 they are generally considered to be positive. Impacts on housing and local community 

20 services, which could be negative if significant population in-migration were to occur, would 

21 also be SMALL. 

22 

23 • Environmental Justice. As described in Section 4.2.13, the majority of the environmental 

24 impacts associated with preconstruction, construction, and operation of the proposed EREF 

25 that would affect the population as a whole would be SMALL, and generally would be 

26 mitigated if they were negative. Environmental impacts are primarily those affecting 

27 historical and cultural resources, visual and scenic resources, air quality, transportation, and 

28 facility accidents. However, as there are no minority or low-income populations defined 

29 according to CEQ guidelines within the 4-mile area around the proposed facility, there would 

30 be no disproportionate impacts on these populations as a result of this proposed project. 

31 

32 • Accidents. As described in Section 4.2.15, six accident scenarios were evaluated in this EIS 

33 as a representative selection of the types of accidents that are possible at the proposed 

34 EREF. The representative accident scenarios selected vary in severity from high- to 

35 intermediate-consequence events and include accidents initiated by natural phenomena 

36 (earthquakes), operator error, and equipment failure. The consequence of a criticality 

37 accident would be high (fatality) for a worker in close proximity. Worker health 

38 consequences are low to high from the other five accidents that involve the release of UF6. 

39 Radiological consequences to a maximally exposed individual (MEI) at the Controlled Area 

40 Boundary (proposed EREF property boundary) are low for all six accidents including the 

41 criticality accident. Uranium chemical exposure to the MEI is high for one accident and low 

42 for the remainder. For HF exposure to an MEI at the proposed property boundary, the 

43 consequence of three accidents is intermediate, with a low consequence estimated for the 

44 remainder. All accident scenarios predict consequences to the collective offsite public of 

45 less than one lifetime cancer fatality. Impacts from accidents would be SMALL to 

46 MODERATE. 

47 
 7-6 

1 7.1.2 Benefits of the Proposed Action 

2 

3 The proposed action would result in the annual production of up to a maximum of 6.6 million 

4 separative work units (SWUs) of enriched uranium between 2022 and 2041. As discussed in 

5 Section 1.3 of this EIS, this level of production would represent an augmentation of the domestic 

6 supply of enriched uranium and would meet the need for increased domestic supplies of 

7 enriched uranium for national energy security. Under the proposed action, enriched uranium 

8 production would be undertaken with the latest enrichment technology, and would facilitate the 

9 generation of electricity with lower emissions of criteria pollutants and carbon. 

10 

11 The proposed action would also result in small positive socioeconomic impacts in the 11-county 

12 ROI, as described in Section 4.2.12. Table 7-1 presents the estimated employment and tax 

13 revenue benefits associated with the proposed action. Employment in the 11-county ROI as a 

14 result of preconstruction activities is estimated at 308 full-time jobs. In addition, State income 

15 tax revenues would be $0.1 million, and State sales and use tax receipts would be $0.9 million 

16 during preconstruction. Average employment in the 11-county ROI during construction is 

17 estimated at 947 full-time jobs, with $0.4 million in State income tax revenues and $2.7 million in 

18 State sales taxes. During the construction/operations overlap period between 2014 and 2021, 

19 1645 jobs would be created in the first year, lasting throughout the startup period; $0.7 million in 

20 income taxes would be generated annually for the State of Idaho; and $1.8 million in property 

21 taxes would be collected annually by Bonneville County. During the operations phase between 

22 2022 and 2040, 3289 jobs would be created in the first year, lasting throughout the operating 

23 period, with fewer positions required in the last year of operations, 2041. During the operating 

24 period, the State of Idaho would benefit from $1.3 million annually in income taxes, while 

25 Bonneville County would collect $3.5 million annually in property tax receipts (AES, 2010a). 

26 

27 As the decommissioning phase of the proposed EREF would occur more than 20 years in the 

28 future, decommissioning costs cannot be estimated with any certainty at this time. 

29 Decommissioning impacts would be SMALL, with impacts likely to be less than the impacts of 

30 operating the facility. 

31 

32 Construction of an electrical transmission line to support the proposed EREF facility would 

33 produce 57 jobs, $0.1 million in direct sales taxes, and $0.1 million in direct income taxes. 

34 

35 Although it can be assumed that some portion of State sales and income taxes paid would be 

36 returned to the 11-county ROI under revenue-sharing arrangements between each county and 

37 State government, the exact amount that would be received by each county cannot be 

38 determined. 

39 

40 Beyond the economic and fiscal benefits of the proposed EREF in the 11-county ROI, the facility 

41 would also create fiscal benefits in the nation as a whole, primarily in the form of Federal income 

42 taxes on employee wages and salaries. Based on the distribution of employees in each salary 

43 category at the proposed facility, and current Federal marginal income tax rates, it is estimated 

44 that annual individual Federal income taxes during the peak year of facility construction would 

45 be $15.5 million, with $7.2 million produced annually during startup and $14.5 million generated 

46 annually during facility operations. Federal income taxes would amount to $2.8 million during 

47 preconstruction activities. 

48 
 7-7 

Table 7-1 Socioeconomic Benefits Associated with the Proposed EREF 

in the 11-County ROI 

Project Phase 

Annual 

Average 

Direct and 

Indirect Jobs 

Created (fulltime jobs) 

Direct 

Annual State 

Income Tax 

Revenues 

($ million, 

2008 $) 

Direct 

Annual State 

Sales Tax 

Revenues 

($ million, 

2008 $) 

Annual Local 

Government 

Property Tax 

Revenues 

($ million, 

2008 $) 

Preconstruction 308 0.1 0.9 NAa

Construction 947 0.4 2.7 NA 

Construction/Operations 

Overlap Period 

1645 0.7 NA 1.8

Operation 3289 1.3 NA 3.5 

Transmission Line 57 0.1 0.1 <0.1 

a

 NA = not applicable. 

Source: AES, 2010a.

1 

2 7.1.3 Summary Regarding the Proposed Action 

3 

4 This analysis shows that although there are economic and fiscal benefits associated with 

5 preconstruction, construction, and operation of the proposed EREF in the ROI, these impacts 

6 would be SMALL. There would also be costs resulting from impacts on various resource areas, 

7 which are not possible to quantify. For the majority of these resource areas, impacts would be 

8 SMALL or SMALL to MODERATE in magnitude. 

9 

10 7.2 Comparative Benefit-Cost Analysis of Proposed Action Relative to 

11 No-Action Alternative 

12 

13 This section compares selected costs and benefits of the proposed action to those of the 

14 no-action alternative. This comparison focuses on the tradeoffs between constructing the 

15 proposed EREF compared to not constructing the facility. Other possible actions involving other 

16 domestic and foreign uranium enrichment suppliers at existing and proposed new facilities both 

17 in the United States and elsewhere are likely to be similar under the two alternatives, and are 

18 therefore not considered in the comparison. 

19 

20 As a result of the lack of data that can be publicly disclosed or is otherwise available on private 

21 benefits (facility revenues) and costs (preconstruction, facility construction, and operating costs), 

22 the analysis focuses on the societal benefits and costs of the facility, including the impacts on 

23 employment, income, and tax revenues during the construction and operations phases in the 

24 region of influence around the proposed site, and the contribution of the proposed facility to 

25 meeting policy and technical objectives. 

26 

27 
 7-8 

1 7.2.1 No-Action Alternative 

2 

3 The proposed EREF would not be constructed, operated, and decommissioned under the no4 action alternative; preconstruction activities at the proposed site that are not part of the 

5 proposed action could still take place (see Section 4.4). Preconstruction activities would include 

6 the disturbance of land associated with site clearing and preparation activities and the 

7 construction of ancillary facilities, meaning that some ecological, natural, and socioeconomic 

8 impacts would therefore occur. For the purposes of the no-action alternative, all potential local 

9 environmental impacts during the construction, operations, and decommissioning phases would 

10 be avoided. Similarly, all socioeconomic impacts related to employment, economic activity, 

11 population, housing, and community resources during the construction, operations, and 

12 decommissioning phases would not occur. 

13 

14 7.2.2 The Proposed Action 

15 

16 The benefits of preconstruction, construction, and operation of the proposed EREF on the 

17 economy in the 11-county ROI in which the plant is located, and on the State economy are 

18 described in Sections 4.2 and 7.1.2. Societal costs and impacts on land use, historical and 

19 cultural resources, visual and scenic resources, air quality, geology and soils, water resources, 

20 ecological resources, noise, transportation, public and occupational health, waste management, 

21 and environmental justice are described in Sections 4.2 and 7.1.1. In all cases, the impacts are 

22 too small to materially affect the comparative benefit-cost analysis. 

23 

24 Other non-monetary cost areas described in Section 7.1.1 are not included as part of this 

25 comparison because the effect of these impacts is assumed to be either (1) approximately equal 

26 for the proposed action and the no-action alternative as defined above or (2) too small in 

27 differential impact to materially affect the comparative benefit-cost analysis. 

28 

29 This analysis does not attempt to estimate the economic effects of a cheaper source of enriched 

30 uranium for nuclear power plants, or estimate the impact of lower enriched uranium prices on 

31 the ratio of nuclear and non-nuclear power in the domestic economy (1) on overall power 

32 demand and price and (2) on the potential economic benefits to consumers and suppliers. 

33 

34 7.2.3 Compliance with Policy and Technical Objectives 

35 

36 The following policy and technical objectives are relevant to the choice of an enrichment 

37 technology: 

38 

39 • the need for enriched uranium to fulfill domestic electricity requirements 

40 

41 • the need for domestic supplies of enriched uranium for national energy security 

42 

43 • the need for upgraded uranium enrichment technology in the United States 

44 

45 • the need for energy generation with fewer emissions of criteria pollutants and carbon 

46 

47 The following sections compare the proposed action and the no-action alternative in terms of 

48 how well they meet each of these objectives. 

49 
 7-9 

1 7.2.3.1 Meeting Demand for Enriched Uranium 

2 

3 Currently, the demand for enriched uranium in the United States for domestic electricity 

4 production is met from two categories of sources: 

5 

6 • domestic production of enriched uranium 

7 

8 • other foreign sources 

9 

10 The current 5-year average U.S. demand for enriched uranium is 14 million SWUs per year 

11 (EIA, 2010). From 2005 through 2009, the United States Enrichment Corporation delivered 

12 approximately 10 to 13.5 million SWUs to customers annually, of which 5.5 million SWUs per 

13 year were from the Megatons to Megawatts Program. Of the remaining 4.5 to 7.5 million 

14 SWUs, an average of approximately 2 million SWUs were sold for use in the United States and 

15 the balance exported (USEC, 2010). Therefore, of the amount sold for use in the United States, 

16 approximately 2 million SWUs (about 15 percent of U.S. demand) come from enrichment at the 

17 Paducah Gaseous Diffusion Plant (PGDP) and 5.5 million SWUs (about 38 percent of 

18 U.S. demand) come from downblending at the Megatons to Megawatts Program, which 

19 depends on deliveries from Russia (EIA, 2010; USEC, 2010). Capacity at the proposed EREF 

20 could theoretically be sold only to the U.S. market, thus reducing the overall foreign dependence 

21 to approximately 6 million SWUs (43 percent of U.S. demand). 

22 

23 7.2.3.2 National Energy Security 

24 

25 Currently, foreign sources supply as much as 85 percent of the U.S. demand for enriched 

26 uranium. The primary domestic production of enriched uranium currently takes place at a single 

27 plant – the Paducah Gaseous Diffusion Plant. The heavy dependence on foreign sources and 

28 the lack of diversification of domestic sources of enriched uranium represent a potential 

29 reliability risk for the domestic nuclear energy industry, which supplies 20 percent of national 

30 energy requirements. Interagency discussions led by the National Security Council have 

31 concluded that the United States should maintain a viable and competitive domestic uranium 

32 enrichment industry for the foreseeable future (DOE, 2002). The U.S. Department of Energy 

33 (DOE) has noted the importance of promoting the development of additional domestic 

34 enrichment capacity to achieve this objective (DOE, 2002). 

35 

36 It is anticipated that all gaseous diffusion enrichment operations in the United States will cease 

37 in 2012 due to the higher cost of aging facilities (DOE, 2007). Furthermore, the Megatons to 

38 Megawatts Program is scheduled to expire in 2013. As noted above, these two sources meet 

39 more than half of the current U.S. demand for low-enriched uranium (LEU). As a result, new 

40 domestic sources of enriched uranium are needed to reliably provide fuel to both the existing 

41 and future nuclear power plants in the United States. Thus, projected 6 million SWUs 

42 production from the proposed EREF has the potential to be crucial to meeting the nuclear power 

43 industry’s needs and to increasing the nation’s energy security. This benefit is potentially 

44 LARGE. 

45 

46 
 7-10 

1 7.2.3.3 Technology Upgrade 

2 

3 A DOE–USEC agreement in 2002 regarding the proposed American Centrifuge Plant in 

4 Piketon, Ohio, was intended to “facilitate the deployment of new, cost-effective advanced 

5 treatment technology in the U.S. on a rapid scale” (NRC, 2006). Similarly, the proposed action 

6 represents the implementation of a technology that is contemporary, cost-effective, and reliable 

7 (such as the gas centrifuge technology to be used in the proposed EREF). The proposed action 

8 is therefore better able to address the objective of upgraded domestic uranium enrichment 

9 technology than the no-action alternative, in which no technology is implemented. 

10 

11 7.2.3.4 Energy Generation with Fewer Emissions of Criteria Pollutants and Carbon 

12 

13 Production of enriched uranium at the proposed EREF would support an increase in electricity 

14 production using nuclear technology. Compared to the most likely alternative, coal-fired power 

15 plants, nuclear electricity generation results in fewer emissions of criteria pollutants such as 

16 nitrogen oxides, sulfur dioxide, and particulate matter, as well as reduced emissions of carbon. 

17 In addition, the gas centrifuge technology being chosen for the proposed EREF is less energy18 intensive than the existing gaseous diffusion technology. Therefore, regional air quality and 

19 environmental impacts would be further reduced. On a national basis, these environmental 

20 benefits of the proposed action would be MODERATE. 

21 

22 7.2.4 Conclusions Regarding the Proposed Action versus the No-Action Alternative 

23 

24 Based on consideration of local and national socioeconomic benefits, and the costs of 

25 preconstruction, construction, and operation of the proposed EREF on a range of environmental 

26 resources, and on public and occupational health, the proposed action is preferable relative to 

27 the no-action alternative in the following respects: 

28 

29 • The proposed action better satisfies DOE’s policy and technical objectives for meeting future 

30 demand, national energy security, technological upgrades, and reducing emissions of 

31 criteria pollutants and carbon; and 

32 

33 • The proposed action would have positive impacts in the 11-county ROI on employment, 

34 income, and tax revenues during the preconstruction, construction, operations, and 

35 decommissioning phases. 

36 

37 7.3 Overall Benefit-Cost Conclusions 

38 

39 While there are national energy security and fiscal benefits associated with the proposed action, 

40 and local socioeconomic benefits in the 11-county ROI in which the proposed EREF would be 

41 located, there are also direct costs associated with the preconstruction, construction, and 

42 operation phases of the proposed project, as well as impacts associated with the proposed 

43 action on various resource areas. However, these impacts are estimated to be small in 

44 magnitude and small in comparison to the local and national benefits of the proposed action. 

45 

46 Although the no-action alternative would include the continuation of enriched uranium 

47 production using gaseous diffusion technology and imported enriched uranium supplies, in order 

48 to satisfy domestic demand, the proposed action better satisfies DOE’s policy and technical 
 7-11 

1 objectives. These objectives require meeting future demand for enriched uranium and improved 

2 national energy security with the desired technology upgrades. Also, under the proposed 

3 action, there would be fewer emissions of criteria pollutants and carbon. The staff concludes 

4 that in comparison to the no-action alternative, the proposed action is associated with significant 

5 net positive benefits. 

6 

7 7.4 References 

8 

9 (AES, 2010a) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

10 Environmental Report, Rev. 2.” April. 

11 

12 (AES, 2010b) AREVA Enrichment Service, LLC. Letter from J.A. Kay (Licensing Manager, 

13 AES) to U.S. Nuclear Regulatory Commission dated February 19. “Subject: Treatment Plan for 

14 Historic Site MW004 and Analysis of Obsidian Artifacts.” ADAMS Accession 

15 No. ML100540684. 

16 

17 (DOE, 2002) U.S. Department of Energy. Letter from W.J. Magwood, IV (U.S. Department of 

18 Energy) to M.J. Virgilio (U.S. Nuclear Regulatory Commission) dated July 25. ADAMS 

19 Accession No. ML022350130. 

20 

21 (DOE, 2007) U.S. Department of Energy. “Uranium Enrichment Decontamination & 

22 Decommissioning Fund 2007 Report to Congress.” Oak Ridge Office and Portsmouth/Paducah 

23 Project Office. <http://www.em.doe.gov/pdfs/5th_triennial_report_final.pdf> (Accessed April 16, 

24 2010). ADAMS Accession No. ML103490664. 

25 

26 (EIA, 2010) Energy Information Administration, U.S. Department of Energy. “Uranium 

27 Marketing Annual Report.” Washington, D.C. August. <http://www.eia.doe.gov/cneaf/ 

28 nuclear/umar/umar.html> (Accessed November 15, 2010). ADAMS Accession 

29 No. ML103480604. 

30 

31 (Gilbert, 2010) Personal communication from H. Gilbert (Idaho National Laboratory) to 

32 D. O’Rourke (Argonne National Laboratory) dated April 26, 2010. “Subject: Uniqueness of Late 

19th 33 Century Homestead Sites in the General Vicinity of the EREF Property.” 

34 

35 (Idaho SHPO, 2010b) Idaho State Historic Preservation Office. Letter from S. Pengilly (Idaho 

36 Deputy SHPO) to J. Kay (AREVA) dated November 26, 2010. “Re: Geotechnical Borings at the 

37 Proposed Twin Buttes Substation within Cultural Resource Site 10BV246 (MW004), Eagle Rock 

38 Enrichment Facility, Bonneville County, Idaho.” ADAMS Accession No. ML110240061. 

39 

40 (NRC, 2006) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for the 

41 Proposed American Centrifuge Plant in Piketon, Ohio.” NUREG-1834. Office of Nuclear 

42 Material Safety and Safeguards, Washington, D.C., April. <http://www.nrc.gov/reading-rm/doc43 collections/nuregs/staff/sr1834/> (Accessed October 7, 2009). 

44 

45 (USEC, 2010) USEC, Inc. “Annual Report Pursuant to Section 13 or 15(d) of the Securities 

46 Exchange act of 1934 for the Fiscal Year Ended December 31, 2009.” March 1. 

47 <http://phx.corporate-ir.net/External.File?item=UGFyZW50SUQ9MzcxMTE0fENoaWxk 

48 SUQ9MzY4MDY0fFR5cGU9MQ==&t=1> (Accessed December 9, 2010). ADAMS Accession 

49 No. ML103480637. 

50 
 7-12 

1 (WCRM, 2010) Western Cultural Resources Management, Inc. Letter from J. Sigler (WCRM) to 

2 K. Reid (Idaho Deputy SHPO) dated November 17, 2010. “To Summarize Western Cultural 

3 Resource Management’s Data Recovery Activities for the Eagle Rock Enrichment Facility 

4 Project Located in Bonneville County, Idaho.” ADAMS Accession No. ML103280087. 

5 
 8-1 

1 8 SUMMARY OF ENVIRONMENTAL CONSEQUENCES 

2 

3 On December 30, 2008, AREVA Enrichment Services, LLC (AES) submitted an application to 

4 the U.S. Nuclear Regulatory Commission (NRC) for a license to construct, operate, and 

5 decommission the proposed Eagle Rock Enrichment Facility (EREF) (AES, 2008). AES 

6 proposes to locate the facility in Bonneville County, Idaho, approximately 32 kilometers 

7 (20 miles) west of Idaho Falls. Revisions to the license application were submitted on April 23, 

8 2009 (Revision 1) (AES, 2009a) and April 30, 2010 (Revision 2) (AES, 2010a). If licensed, the 

9 proposed EREF would enrich uranium for use in commercial nuclear fuel for power reactors. 

10 Feed material would consist of non-enriched uranium hexafluoride (UF6). AES would employ a 

11 gas centrifuge-based enrichment process to enrich uranium to up to 5 percent uranium-235 by 

12 weight, with a planned maximum target production of 6.6 million separative work units (SWUs) 

13 per year. The proposed EREF would be licensed in accordance with the provisions of the 

14 Atomic Energy Act. Specifically, an NRC license under Title 10, “Energy,” of the U.S. Code of 

15 Federal Regulations (10 CFR) Parts 30, 40, and 70 would be required to authorize AES to 

16 possess and use byproduct material, source material, and special nuclear material at the 

17 proposed EREF. 

18 

19 AES expects to begin preconstruction in late 2010. If the license application is approved, AES 

20 expects to begin facility construction in 2011, which would continue for 11 years. AES 

21 anticipates commencing initial production in 2014 and reaching full production in 2022. Prior to 

22 license expiration in 2041, AES would decide to seek to renew its license to continue operating 

23 the facility or plan for the decontamination and decommissioning of the facility per the applicable 

24 licensing conditions and NRC regulations. 

25 

26 Section 102 of the National Environmental Policy Act of 1969, as amended (NEPA) (Public 

27 Law 91-190; Title 42, Section 4321 et seq., United States Code [42 U.S.C. 4321 et seq.]), 

28 directs that an Environmental Impact Statement (EIS) is required for major Federal actions that 

29 significantly affect the quality of the human environment. Section 102(2)(C) of NEPA requires 

30 that an EIS include information about the following: 

31 

32 • the environmental impacts of the proposed action 

33 

34 • any adverse environmental effects that cannot be avoided, should the proposal be 

35 implemented 

36 

37 • alternatives to the proposed action 

38 

39 • the relationship between local short-term uses of the environment and the maintenance and 

40 enhancement of long-term productivity 

41 

42 • any irreversible and irretrievable commitments of resources that would be involved if the 

43 proposed action is implemented 

44 

45 NRC’s regulations under 10 CFR Part 51 implement the requirements of NEPA. In particular, 

46 10 CFR 51.20(b)(10) states that issuance of a license for a uranium enrichment facility requires 

47 the NRC to conduct an environmental review and prepare an EIS. As part of its license 

48 application and two license application revisions, AES submitted an Environmental Report (ER) 
 8-2 

1 and ER Revisions 1 and 2. Information in the ERs and supplemental environmental 

2 documentation provided by AES has been reviewed and independently verified by the NRC and 

3 used, in part, by the NRC in preparing the EIS. ER Revision 2 (AES, 2010b) incorporates the 

4 supplemental environmental documentation provided by AES subsequent to the submittal of ER 

5 Revision 1, with the exception of some responses to requests for additional information 

6 (AES, 2009b) and supplemental information provided subsequent to ER Revision 2 (North 

7 Wind, 2010) that were also used in the preparation of this EIS. 

8 

9 The April 23, 2009, Revision 1 to the AES license application provided details on an expansion 

10 of the maximum annual production of the proposed EREF from 3.3 to 6.6 million SWUs per 

11 year. On June 17, 2009, AES submitted a request for an exemption from certain NRC 

12 regulations to allow commencement of certain preconstruction activities (e.g., site preparation) 

13 prior to issuance of the NRC license (AES, 2009c). On October 15, 2009, AES provided 

14 information that distinguishes between the environmental impacts of the preconstruction 

15 activities specified in its exemption request and those of NRC-authorized construction activities 

16 that will not be undertaken unless a license is granted (AES, 2009d). Supplemental information 

17 on the proposed transmission line required to power the proposed EREF was submitted by AES 

18 on February 18, 2010 (AES, 2010c). On March 17, 2010, the NRC granted an exemption 

19 (NRC, 2010) authorizing AES to conduct the preconstruction activities on the proposed EREF 

20 site, which AES had requested in its June 17, 2009, exemption request. 

21 

22 Upon acceptance of the ER, the NRC began the environmental review process described in 

23 10 CFR Part 51 by publishing, on May 4, 2009, in the Federal Register (74 FR 20508) a Notice 

24 of Intent to prepare an EIS and conduct scoping. The purpose of the EIS scoping process was 

25 to assist in determining the range of actions, alternatives to the proposed action, and potential 

26 impacts to be considered in the EIS, and to identify significant issues related to the proposed 

27 action. Comments and information from the public and government agencies were obtained 

28 during the scoping period. As part of the scoping process, the NRC staff held a public scoping 

29 meeting on June 4, 2009, in Idaho Falls, Idaho. NRC staff considered the public comments 

30 received during the scoping process for preparation of this EIS; the summary of the EIS scoping 

31 process is provided in Appendix A (the September 2009 Scoping Summary Report). 

32 

33 In addition to reviewing AES’s ER and supplemental documentation, the NRC staff consulted 

34 with appropriate Federal, State, and local agencies and Tribal organizations. On June 2–4, 

35 2009, the NRC staff met with officials of a number of these agencies and organizations and also 

36 conducted a site visit and technical meetings with AES. 

37 

38 Further comments from the public and government agencies were received after the NRC staff 

39 issued a Draft EIS for public review and comment on July 21, 2010, and announced its 

40 availability in the Federal Register (75 FR 4266) in accordance with 10 CFR 51.73, 51.74, and 

41 51.117. The public comment period ended on September 13, 2010. During the public comment 

42 period, the NRC staff held two public meetings – in Boise, Idaho, on August 9, 2010, and in 

43 Idaho Falls, Idaho, on August 12, 2010 – where oral comments from members of the public 

44 were received on the Draft EIS. In addition to oral comments received at the public meetings, 

45 the NRC staff received written comments on the Draft EIS at the public meetings and by postal 

46 mail and email during the public comment period. The transcripts of the public meetings and 

47 the written comments received are part of the public record for the proposed project and were 

48 considered by the NRC staff in preparing this EIS. Comment summaries and the NRC staff’s 

49 responses are contained in Appendix I of this EIS. 

50 
 8-3 

1 Included in this EIS are (1) the results of the NRC staff’s analyses, which consider and weigh 

2 the environmental effects of preconstruction and the proposed action; (2) mitigation measures 

3 for reducing or avoiding adverse effects; (3) the environmental impacts of alternatives to the 

4 proposed action; and (4) the NRC staff’s recommendation regarding the proposed action based 

5 on its environmental review. 

6 

7 Potential environmental impacts are evaluated in this EIS using the three-level standard of 

8 significance – SMALL, MODERATE, or LARGE – developed by the NRC using guidelines from 

9 the Council on Environmental Quality (CEQ) (40 CFR 1508.27). Table B-1 of 10 CFR Part 51, 

10 Subpart A, Appendix B, provides the following definitions of the three significance levels: 

11 

12 • SMALL – Environmental effects are not detectable or are so minor that they would neither 

13 destabilize nor noticeably alter any important attribute of the resource. 

14 

15 • MODERATE – Environmental effects are sufficient to alter noticeably, but not to destabilize, 

16 important attributes of the resource. 

17 

18 • LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

19 important attributes of the resource. 

20 

21 8.1 Unavoidable Adverse Environmental Impacts 

22 

23 Section 102(2)(c)(ii) of NEPA requires that an EIS include information on any adverse 

24 environmental effects that cannot be avoided, should the proposed action be implemented. 

25 Unavoidable adverse environmental impacts are those potential impacts of the NRC action that 

26 cannot be avoided and for which no practical means of mitigation are available. 

27 

28 The environmental impacts associated with the proposed action and with the no-action 

29 alternative are described in detail in Chapter 4 for each resource area. The impacts of these 

30 two alternatives are summarized and compared in Section 2.4. Chapter 4 also discusses the 

31 mitigation measures that AES proposed in its ER to mitigate the potential impacts of the 

32 proposed action and the mitigation measures identified by the NRC. These two sets of 

33 mitigation measures are summarized in Chapter 5, Tables 5-1 and 5-2 and Tables 5-3 and 5-4, 

34 respectively. The cumulative impacts on the environment that would result from the proposed 

35 action when added to other past, present, and reasonably foreseeable future actions, regardless 

36 of what agency or person undertakes such actions, are described in Section 4.3. 

37 

38 As discussed in Chapter 4, the environmental impacts that would result if the proposed action 

39 were to be implemented as proposed by AES would mostly be SMALL and would, in most 

40 cases, be mitigated by the methods proposed by AES. The only resource areas in which 

41 certain impacts would be classified as SMALL to MODERATE would be visual and scenic 

42 resources, ecological resources, and transportation. In addition, impacts on historic and cultural 

43 resources as a result of preconstruction activities would be MODERATE with appropriate 

44 mitigation, and air quality impacts from fugitive dust would be MODERATE to LARGE on a 

45 temporary basis during preconstruction and construction activities. 

46 

47 The primary impact on historic and cultural resources would result from the destruction during 

48 EREF preconstruction activities of site MW004, the John Leopard Homestead, which has been 
 8-4 

1 recommended as eligible for listing in the National Register of Historic Places. However, the 

2 mitigation of this site by AES prior to its disturbance results in a MODERATE level for this 

3 impact. 

4 

5 The proposed EREF would create a significant contrast with the surrounding visual 

6 environment, presenting a MODERATE impact to visual and scenic resources. The extent of 

7 the proposed EREF and the industrial nature of its buildings are not in character with the 

8 surrounding viewshed, which includes the surrounding grazing and agricultural lands and the 

9 Hell’s Half Acre Wilderness Study Area/National Natural Landmark approximately 2.4 kilometers 

10 (1.5 miles) to the south. 

11 

12 The impact level on ecological resources has been classified as MODERATE during 

13 preconstruction and construction activities because these activities would result in the removal 

14 of sagebrush steppe and nonirrigated pasture vegetation. Indirect impacts of preconstruction 

15 and construction would include the generation of fugitive dust, erosion of disturbed areas, and 

16 potential sedimentation of downgradient habitats. Also, preconstruction and construction 

17 activities would result in some wildlife mortality and cause other wildlife to relocate as a result of 

18 noise, lighting, traffic, and human presence. Collisions with vehicles or construction equipment 

19 may cause some wildlife mortality as well. 

20 

21 The transportation impacts on US 20 in the immediate vicinity of the proposed EREF would be 

22 SMALL to MODERATE due to increases in traffic density (primarily from commuting workers) 

23 during preconstruction and facility construction, and when facility construction and initial 

24 operations overlap. 

25 

26 The ground-disturbing activities during preconstruction and construction would result in 

27 increased fugitive dust emissions and cause MODERATE to LARGE air quality impacts. 

28 However, air quality impacts would be at the MODERATE to LARGE level only temporarily. 

29 The majority of the time, these impacts would be SMALL. 

30 

31 8.2 Relationship between Local Short-Term Uses of the Environment and the 

32 Maintenance and Enhancement of Long-Term Productivity 

33 

34 Consistent with the CEQ definition in 40 CFR 1502.16 and the definition provided in Section 5.8 

35 of NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS 

36 Programs (NRC, 2003), this EIS defines short-term uses and long-term productivity as follows: 

37 

38 • Short-term uses generally affect the present quality of life for the public (i.e., the 30-year 

39 license period for the proposed EREF). 

40 

41 • Long-term productivity affects the quality of life for future generations on the basis of 

42 environmental sustainability (i.e., long-term is the period after license termination for the 

43 proposed EREF). 

44 

45 Preconstruction, construction, and operation of the proposed EREF would necessitate short46 term commitments of resources. The short-term commitment of resources would include the 

47 use of materials required to construct new buildings and operation support facilities, 

48 transportation resources, and other materials and disposal resources for operations at the 
 8-5 

1 proposed EREF. Preconstruction, construction, operations, and decommissioning of the 

2 proposed EREF would also require the permanent commitment of energy and water resources. 

3 The short-term use of resources would result in potential long-term socioeconomic benefits to 

4 the local area and the region, such as improvements to the local economy and infrastructure 

5 supported by worker income and tax revenues and the maintenance and enhancement of a 

6 skilled worker base. 

7 

8 Workers, the public, and the environment would be exposed to increased amounts of 

9 radioactive and hazardous materials over the short term from the operation of the proposed 

10 EREF and the associated materials, including process emissions and the handling of waste. 

11 Construction and operation of the proposed EREF would require a long-term commitment of 

12 terrestrial resources, such as land, water, and energy. Impacts would be minimized by the 

13 application of proper mitigation measures and resource management. In closing the EREF, 

14 AES would decontaminate and decommission the buildings and equipment and restore them for 

15 unrestricted use. This work would make the buildings and the site available for other uses. The 

16 use of the site and the buildings for other industrial purposes would constitute a long-term 

17 benefit to the community and would increase long-term productivity. Continued employment, 

18 expenditures, and tax revenues generated during preconstruction, construction, and operation 

19 of the proposed EREF and from future site uses after the EREF is decommissioned would 

20 directly benefit the local, regional, and State economies and would be considered a long-term 

21 benefit. 

22 

23 8.3 Irreversible and Irretrievable Commitment of Resources 

24 

25 Irreversible commitment of resources refers to resources that are destroyed and cannot be 

26 restored, whereas an irretrievable commitment of resources refers to material resources that 

27 once used cannot be recycled or restored for other uses by practical means (NRC, 2003). 

28 The implementation of the proposed action as described in Section 2.1 would include the 

29 commitment of land, water, energy, raw materials, and other natural and manmade resources. 

30 About 240 hectares (592 acres) on the 1700-hectare (4200-acre) property to be purchased by 

31 AES would be used for the preconstruction, construction, and operation of the proposed EREF. 

32 AES has stated that following decontamination and decommissioning, all parts of the plant and 

33 site would be available for unrestricted use (AES, 2010b). Therefore, if the license is granted, 

34 the 240-hectare (592-acre) parcel of land would likely remain in industrial use beyond license 

35 termination. 

36 

37 Preconstruction, construction, and operation of the proposed EREF would use groundwater 

38 resources from the Eastern Snake River Plain (ESRP) aquifer. The proposed EREF is a 

39 consumptive water-use facility, meaning all water would be used and none would be returned to 

40 its original source. Although the amount of water from the ESRP aquifer that would be used by 

41 the proposed EREF represents a small percentage of the total capacity of the facility’s water 

42 right appropriation, this water would be lost in three ways: (1) the water would evaporate from 

43 the liquid effluent treatment system evaporator and the two Cylinder Storage Pads Stormwater 

44 Retention Basins; (2) the water would evaporate or infiltrate into the ground from the Site 

45 Stormwater Retention Basin; and (3) infiltrated groundwater would undergo evapotranspiration. 

46 It is unlikely that any of the water used by the proposed EREF would replenish the ESRP 

47 aquifer or reach adjacent properties. 

48 
 8-6 

1 Energy expended would be in the form of fuel (gasoline and diesel) for equipment and electricity 

2 for facility preconstruction, construction, and operations. There are no plans to use natural gas 

3 at the proposed EREF. The electrical energy requirement for EREF operation would represent 

4 a small increase in the electrical energy demand of the area. Improvements in the local area’s 

5 electrical power capacity to support the proposed EREF (i.e., the upgrade/addition of an 

6 electrical transmission line and substations) would contribute to a slight increase in the 

7 irreversible and irretrievable commitment of resources because of the dedication of a small 

8 portion of land and material that would be needed for such improvements and the expansion of 

9 services. 

10 

11 Resources that would be committed irreversibly or irretrievably during preconstruction, 

12 construction, and operation of the proposed EREF include materials that could not be recovered 

13 or recycled and materials that would be consumed or reduced to unrecoverable forms. 

14 Preconstruction and construction of the proposed EREF would involve the commitment of 

15 varying amounts of building materials. During operation, the proposed EREF would generate a 

16 small amount of nonrecyclable waste streams, such as hazardous and radiological wastes. 

17 Generation of these waste streams would represent an irreversible and irretrievable 

18 commitment of material resources. 

19 

20 Even though the land used to construct the proposed EREF would be returned to other 

21 productive uses after the facility is decommissioned, there would be some irreversible 

22 commitment of land at some offsite locations used to dispose of solid wastes generated at the 

23 proposed EREF. In addition, wastes generated during the conversion of depleted UF6 produced 

24 at the proposed EREF and the depleted uranium oxide conversion product from the depleted 

25 UF6 conversion would be disposed of at an offsite location (see Section 2.1.5). The land used 

26 for the disposal of these materials would also represent an irreversible commitment of land. No 

27 solid wastes or depleted uranium oxide conversion product originating from the proposed EREF 

28 would be disposed of on the EREF property. 

29 

30 When the facility is decommissioned, some of the materials used in its construction, such as 

31 concrete, steel, other metals, plastics, and other materials, would be recycled and reused. 

32 Other materials would be disposed of in licensed and approved offsite locations. The amount of 

33 land used to dispose of these materials would also be an irretrievable land resource. 

34 

35 During the operation of the proposed EREF, natural UF6 would be used as the feed material. 

36 This would require the mining of uranium (not licensed by the NRC) and other operational steps 

37 in the front end of the uranium fuel cycle (licensed by the NRC) that result in the production of 

38 UF6. The use of uranium minerals would be an irretrievable resource commitment. There 

39 would also be other irreversible and irretrievable commitments of resources during uranium fuel 

40 cycle operations that result in the production of natural UF6 feed. As shown in Figure 1-2, there 

41 are several fuel cycle operations leading up to the production of the natural UF6 that feed 

42 enrichment operations. These steps include the mining and processing of uranium ore, which 

43 result in the production of natural triuranium octaoxide (U3O8) and conversion of natural U3O8 to 

44 UF6. All materials and energy used in the construction and operation of the facilities used to 

45 mine and process the uranium ore and convert natural U3O8 to natural UF6 would constitute an 

46 irreversible and irretrievable commitment of resources. 

47 
 8-7 

1 8.4 References 

2 

3 (AES, 2008) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility, Application 

4 for a Uranium Enrichment Facility License Under 10 CFR 70, ‘Domestic Licensing of Special 

5 Nuclear Material.’” December. <http://adamswebsearch2.nrc.gov/idmws/doccontent. 

6 dll?library=PU_ADAMS^PBNTAD01&ID=090770339> (Accessed August 18, 2009). ADAMS 

7 Accession No. ML090300656. 

8 

9 (AES, 2009a) AREVA Enrichment Services, LLC. Letter from Sam Shakir (President and CEO, 

10 AES) to the U.S. Nuclear Regulatory Commission dated April 23, 2009. “Subject: Revision 1 to 

11 License Application for the Eagle Rock Enrichment Facility.” ADAMS Accession 

12 No. ML091210638. 

13 

14 (AES, 2009b) AREVA Enrichment Services, LLC. Letter from Jim Kay (Licensing Manager, 

15 AES) to the U.S. Nuclear Regulatory Commission dated September 9, 2009. “Subject: 

16 Response to Requests for Additional Information – AREVA Enrichment Services LLC 

17 Environmental Report for the Eagle Rock Enrichment Facility.” ADAMS Accession 

18 No. ML092530636. 

19 

20 (AES, 2009c) AREVA Enrichment Services, LLC. Letter from Sam Shakir (President and CEO, 

21 AES) to the U.S. Nuclear Regulatory Commission dated June 17. “Subject: Request for 

22 Exemption from 10 CFR 70.4, 10 CFR 70.23(a)(7), 10 CFR 30.4, 10 CFR 30.33(a)(5), 

23 10 CFR 40.4, and 10 CFR 40.32(e) Requirements Governing ‘Commencement of 

24 Construction.’” ADAMS Accession No. ML091770390. 

25 

26 (AES, 2009d) AREVA Enrichment Services, LLC. Letter from Jim Kay (Licensing Manager, 

27 AES) to the U.S. Nuclear Regulatory Commission dated October 15. “Subject: Response to 

28 Request for Additional Information – AES Eagle Rock Enrichment Facility Exemption Request 

29 Related to Commencement of Construction (TAC L32730).” ADAMS Accession 

30 No. ML092920169. 

31 

32 (AES, 2010a) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility, Revision 2 

33 to License Application.” Bethesda, Maryland. April. ADAMS Accession No. ML101610549. 

34 

35 (AES, 2010b) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

36 Environmental Report, Rev. 2.” Bethesda, Maryland. April. ADAMS Accession 

37 No. ML101610549. 

38 

39 (AES, 2010c) AREVA Enrichment Services, LLC. Letter from Jim Kay (Licensing Manager, 

40 AES) to the U.S. Nuclear Regulatory Commission dated February 18. “Subject: Environmental 

41 Report for the Eagle Rock Enrichment Facility; Supplemental Information - Revised Appendix H, 

42 EREF 161-KV Transmission Line Project.” ADAMS Accession No. ML100540134. 

43 

44 (North Wind, 2010) North Wind, Inc. “Sage Grouse Survey Report, Eagle Rock Enrichment 

45 Facility.” May 13. ADAMS Accession No. ML101390471. 

46 

47 (NRC, 2003) U.S. Nuclear Regulatory Commission. “Environmental Review Guidance for 

48 Licensing Actions Associated with NMSS Programs.” NUREG-1748. August. 

49 
 8-8 

1 (NRC, 2010) U.S. Nuclear Regulatory Commission. Letter from D. Dorman (U.S. Nuclear 

2 Regulatory Commission) to G. Harper (AREVA Enrichment Services, LLC) dated March 17. 

3 “Subject: Approval of AREVA Enrichment Services LLC Exemption Request Related to 

4 Requirements Governing Commencement of Construction (TAC L32730).” 

5 
 9-1 

1 9 AGENCIES AND ORGANIZATIONS CONTACTED 

2 

3 The following sections list the agencies and organizations contacted by the U.S. Nuclear 

4 Regulatory Commission to discuss the Eagle Rock Enrichment Facility project and/or obtain 

5 comments, information, and data for use in preparing this Environmental Impact Statement. 

6 Position titles/functions of agency/organization personnel are included where known. 

7 

8 9.1 Federal Agencies 

9 

10 Advisory Council on Historic Preservation, Washington, D.C. 

11 Reid Nelson, Director, Office of Federal Agency Programs 

12 Tom McCulloch, Archaeologist 

13 Raymond V. Wallace, Historic Preservation Technician 

14 

15 U.S. Department of Energy (DOE), Headquarters, Washington, D.C. 

16 Carol Borgstrom, Director, Office of NEPA Policy and Compliance 

17 

18 U.S. Department of Energy, Idaho National Laboratory (INL), Idaho Falls, Idaho 

19 Bruce Angle, Environmental Management System Manager 

20 Miriam Taylor, Transportation Specialist 

21 

22 U.S. Department of Energy, Idaho Operations Office, Idaho Falls, Idaho 

23 Jack Depperschmidt, NEPA Compliance Officer 

24 Richard Kauffman, Interim NEPA Compliance Officer 

25 

26 U.S. Department of Energy, Loan Programs Office, Washington, D.C. 

27 Matthew McMillen, Director, Environmental Compliance Division 

28 Patrick Gorman, Environmental Specialist 

29 Joseph Montgomery, Consultant 

30 

31 U.S. Department of the Interior, Washington, D.C. 

32 Director, Office of Environmental Policy and Compliance 

33 

34 U.S. Department of the Interior, Bureau of Land Management, Idaho Falls District, Idaho Falls, 

35 Idaho 

36 Joe Kraayenbrink, District Manager 

37 Karen Rice, Associate District Manager 

38 

39 U.S. Department of the Interior, Bureau of Land Management, Upper Snake River Field Office, 

40 Idaho Falls, Idaho 

41 Wendy Reynolds, Upper Snake Field Manager 

42 Rebecca Lazdauskas, Realty Specialist 

43 Mark Ennes, District NEPA Coordinator 

44 Mark Kennison, District NEPA Coordinator 

45 Stephanie Balbarini, Solicitor 

46 William Boggs, Visual Resource Management Coordinator 

47 
 9-2 

1 U.S. Department of the Interior, Fish and Wildlife Service, Eastern Idaho Field Office, 

2 Chubbuck, Idaho 

3 Damien Miller, Supervisor 

4 Gary Burton, Acting Supervisor 

5 Ty Matthews, Fish and Wildlife Biologist 

6 

7 U.S. Department of the Interior, National Park Service, Craters of the Moon National Monument 

8 & Preserve, Arco, Idaho 

9 Doug Neighbor, Superintendent 

10 

11 U.S. Department of the Interior, National Park Service, National Natural Landmarks Program, 

12 Sedro Woolley, Washington 

13 Steve Gibbons, Coordinator 

14 

15 U.S. Department of the Interior, National Park Service, Pacific West Region, Seattle, 

16 Washington 

17 Rory Westberg, Acting Regional Director 

18 Keith Dunbar, Chief of Park Planning and Environmental Compliance 

19 Kelly Powell, Realty Specialist 

20 

21 U.S. Environmental Protection Agency, Region 10, Seattle, Washington 

22 Christine B. Reichgott, Manager, Environmental Review & Sediment Management Unit 

23 Theogene Mbabaliye, Environmental Scientist 

24 

25 9.2 Federally Recognized Indian Tribes 

26 

27 The Shoshone-Bannock Tribes, Fort Hall Indian Reservation, Idaho 

28 

29 Nathan Small, Chairman, Fort Hall Business Council (FHBC) 

30 Alonzo Coby, Former Chairman, FHBC 

31 Willie Preacher, Tribal DOE Program Director 

32 Carolyn Smith, Cultural Resource Coordinator 

33 Tino Batt, Member, FHBC 

34 Devon Boyer, Member, FHBC 

35 Blaine Edmo, Member, FHBC 

36 Glenn Fisher, Member, FHBC 

37 Ann Lindroth, Member, FHBC 

38 Lee Juan Taylor, Member, FHBC 

39 LaRae Buckskin, Cultural Resources Research 

40 Camille Carter, Emergency Response 

41 Christina Cutler, Tribal DOE Environmental Specialist 

42 Wes Jones, Emergency Response 

43 Patrick Teton, Chief of Police 

44 Mel Timbana 

45 Roger Turner, Program Manager 

46 

47 
 9-3 

1 9.3 State Agencies 

2 

3 Idaho Department of Environmental Quality (IDEQ), Headquarters Office, Boise, Idaho 

4 Toni Hardesty, Director 

5 

6 Idaho Department of Environmental Quality, IDEQ State Office, Technical Services Division, 

7 Boise, Idaho 

8 Mark Dietrich, Division Administrator and State Response Program Manager 

9 Orville Green, Waste Program Administrator 

10 Craig Halverson 

11 

12 Idaho Department of Environmental Quality, Idaho Falls Regional Office, Idaho Falls, Idaho 

13 Erick Neher, Regional Administrator 

14 Lezlie Aller, INL Oversight Manager 

15 David Jones, Senior Health Physicist 

16 Bruce LaRue 

17 

18 Idaho Department of Fish and Game, Headquarters Office, Boise, Idaho 

19 Cal Groen, Director 

20 Sharon W. Kiefer, Assistant Director – Policy 

21 Lance Hebdon, Inter-Governmental Policy Coordinator

22 Tom Hemker, Wildlife Program Coordinator 

23 Don Kemner, Wildlife Program Coordinator 

24 

25 Idaho Department of Fish and Game, Upper Snake River Region, Idaho Falls, Idaho 

26 Gary Vecellio, Environmental Review and Coordination 

27 

28 Idaho Department of Water Resources, Eastern Regional Office, Idaho Falls, Idaho 

29 Ernest Carlsen, Water Rights Supervisor 

30 

31 Idaho State Historical Society, State Historic Preservation Office, Boise, Idaho 

32 Janet Gallimore, Executive Director 

33 Susan Pengilly, Deputy State Historic Preservation Officer 

34 Ken Reid, State Archaeologist and Deputy State Historic Preservation Officer 

35 

36 Idaho Transportation Department, District 6, Rigby, Idaho 

37 Timothy Cramer, Senior Environmental Planner 

38 Matthew Davison, District 6 Traffic Engineer 

39 Ken Hahn, District Maintenance Engineer 

40 Blake Rindlisbacher, District 6 Engineer 

41 Bill Shaw, District Planner 

42 David Walrath, Project Development Engineer 

43 

44 Idaho Office of Energy Resources, Boise, Idaho 

45 Paul Kjellander, Administrator 

46 

47 
 9-4 

1 9.4 Local Governments and Agencies 

2 

3 Bingham County Commissioners, Blackfoot, Idaho 

4 A. Ladd Carter, Commissioner – District 3 

5 Donavan Harrington, Commissioner – District 2 

6 Cleone Jolley, Commissioner – District 1 

7 W. Brower, Former Commissioner 

8 

9 Bonneville County Commissioners, Idaho Falls, Idaho 

10 Roger Christensen, Commissioner – District 1 

11 Dave Radford, Commissioner – District 2 

12 Lee Staker, Commissioner – District 3 

13 

14 Bonneville County Planning and Zoning Department, Idaho Falls, Idaho 

15 Steven Serr, Planning and Zoning Director 

16 

17 Bonneville County Public Works Department, Idaho Falls, Idaho 

18 Kevin Eckersell, Public Works Director 

19 

20 Bonneville Metropolitan Planning Organization, Idaho Falls, Idaho 

21 Darrell West, Director 

22 

23 City of Blackfoot, Idaho 

24 Mike Virtue, Mayor 

25 

26 City of Boise, Office of the Mayor, Boise, Idaho 

27 Ross Borden, Director of Intergovernmental Affairs) 

28 Cece Gassner, Economic Development 

29 Paul Woods, Environmental Division Manager, Public Works Department 

30 

31 City of Idaho Falls, Idaho 

32 Jared Fuhriman, Mayor 

33 Ruby Taylor, Assistant to Mayor 

34 Ida Hardcastle, City Council President 

35 Karen Cornwell, City Councilmember 

36 Michael Lehto, City Councilmember 

37 Sharon Parry, City Councilmember 

38 Ken Taylor, City Councilmember 

39 

40 9.5 Other Organizations 

41 

42 Grow Idaho Falls, Idaho Falls, Idaho 

43 Linda Martin, Chief Executive Officer 

44 

45 
 9-5 

1 Snake River Alliance 

2 Andrea Shipley, Executive Director 

3 Beatrice Brailsford, Program Director 

4 Ken Miller, Clean Energy Program Director 

5 Liz Woodruff, Energy Policy Analyst 

 10-1 

1 10 LIST OF PREPARERS 

2 

3 10.1 U.S. Nuclear Regulatory Commission Contributors 

4 

5 Philip Brandt: Air Quality, Ecological Resources, Geology and Soils, Historic and Cultural 

6 Resources, Land Use, Noise, Public and Occupational Health, Visual and Scenic Resources, 

7 Waste Management, and Water Resources Reviewer 

8 3 years Post Grad, Terrestrial Ecology, University of Connecticut, 1975–1978 

9 B.S., Wildlife and Fisheries Biology, Texas A&M University, 1975 

10 Years of Experience: 32 

11 

12 Oleg Bukharin: Terrorism Consideration Reviewer 

13 Ph.D., Physics, Moscow Institute of Physics and Technology, 1989 

14 M.S., Physics, Moscow Institute of Physics and Technology, 1986 

15 Years of Experience: 20 

16 

17 Gregory Chapman: Accident Analysis 

18 M.E., Health Physics, University of Florida, 1993 

19 B.S., Electrical Engineering, Georgia Tech, 1987 

20 Years of Experience: 17 

21 

22 Diana Diaz-Toro: Chief, Environmental Review Branch-A; General EIS Reviewer 

23 B.S., Chemical Engineering, University of Puerto Rico, 2002 

24 M.B.A., American University, 2008 

25 Years of Experience: 9 

26 

27 Mathews George: Historic and Cultural Resources, Socioeconomics, and Visual and Scenic 

28 Resources Reviewer 

29 M.B.A., Concentration in Finance, Loyola College of Maryland, 1998 

30 B.S., Electrical Engineering, State University of New York, 1991 

31 Years of Experience: 19 

32 

33 Kellee Jamerson: Ecological Resources, Geology and Soils, and Water Resources Reviewer 

34 B.S., Environmental Science, Tuskegee University, 2006 

35 Years of Experience: 2 

36 

37 Stephen Lemont: EIS Project Manager; General EIS Reviewer 

38 Ph.D., Chemistry, Columbia University, 1976 

39 B.S., Chemistry, Brooklyn College, 1971 

40 Years of Experience: 29 

41 

42 Asimios Malliakos: Accident Analysis, Air Quality, Benefit-Cost Analysis, Environmental Justice, 

43 Greenhouse Gases, Public and Occupational Health, Socioeconomics, Terrorism 

44 Consideration, and Water Resources Reviewer 

45 Ph.D., Nuclear Engineering with a Minor Degree in Probability and Statistics, University 

46 of Missouri-Columbia, 1980 

47 M.S., Nuclear Engineering, Polytechnic Institute of New York, 1977 

48 B.S., Physics, University of Thessaloniki, Greece, 1975 

49 Years of Experience: 29 

50 
 10-2 

1 M. Breeda Reilly: Licensing Project Manager 

2 M.P.P., Environmental Policy, University of Maryland, 1995 

3 B.E., Chemical Engineering, The Cooper Union, 1985 

4 Years of Experience: 25 

5 

6 Ashley Riffle: Public Involvement 

7 B.S. Biology, Frostburg State University, 2009 

8 Years of Experience: 2 

9 

10 10.2 Argonne National Laboratory Contributors 

11 

12 Tim Allison: Socioeconomics; Environmental Justice; Benefit-Cost Analysis 

13 M.S., Mineral and Energy Resource Economics, West Virginia University, 1990 

14 M.S., Geography, West Virginia University, 1987 

15 B.A., Economics and Geography, Portsmouth Polytechnic (Great Britain), 1982 

16 Years of Experience: 25 

17 

18 Georgia Anast: Scoping Summary Report 

19 B.A., Mathematics and Biology, North Central College, 1973 

20 Years of Experience: 20 

21 

22 John Arnish: Public and Occupational Health; Accident Impacts 

23 M.S., Nuclear Engineering, University of Tennessee, 1994 

24 B.S., Physics, Southern Illinois University, 1992 

25 Years of Experience: 15 

26 

27 Bruce Biwer: Argonne Project Manager; Proposed Action; Purpose and Need; Scope; 

28 Alternatives 

29 Ph.D., Chemistry, Princeton University, 1985 

30 M.S., Chemistry, Princeton University, 1983 

31 B.A., Chemistry, St. Anselm College, 1980 

32 Years of Experience: 20 

33 

34 Brian Cantwell: Spatial Data Analysis and Presentation 

35 B.S., Forestry, Southern Illinois University, 1979 

36 Years of Experience: 26 

37 

38 Vic Comello: Lead Technical Editor 

39 M.S., Physics, University of Notre Dame, 1970 

40 B.S., Physics, DePaul University, 1962 

41 Years of Experience: 33 

42 

43 Karl Fischer: Transportation; Waste Management 

44 M.Eng., Radiological Health Engineering, University of Michigan, 1996 

45 B.S.E., Nuclear Engineering, University of Michigan, 1995 

46 Years of Experience: 12 

47 

48 
 10-3 

1 Liz Hocking: Regulatory Requirements 

2 J.D., Washington College of Law, 1991 

3 M.A., Guidance and Counseling, University of Wisconsin – Oshkosh, 1973 

4 B.A., English and Psychology, University of Wisconsin – Eau Claire, 1971 

5 Years of Experience: 18 

6 

7 Ron Kolpa: Climatology, Meteorology and Air Quality; Noise 

8 M.S., Inorganic Chemistry, Iowa State University, 1972 

9 B.S., Chemistry, St. Procopius College, 1969 

10 Years of Experience: 32 

11 

12 Michele Nelson: Graphics 

13 Certificate of Design, Harrington Institute of Interior Design, 1974 

14 Years of Experience: 35 

15 

16 Dan O’Rourke: Land Use; Historic and Cultural Resources; Visual and Scenic Resources 

17 M.S., Industrial Archaeology, Michigan Technological University, 1997 

18 B.A., History and Anthropology, Michigan State University, 1991 

19 Years of Experience: 17 

20 

21 Terri Patton: Geology, Minerals, and Soils; Water Resources 

22 M.S., Geology, Northeastern Illinois University, 1989 

23 B.S., Geology, Southern Illinois University, 1982 

24 Years of Experience: 20 

25 

26 Kurt Picel: Public and Occupational Health; Accident Impacts; Cumulative Impacts 

27 Ph.D., Environmental Health Sciences, University of Michigan, 1985 

28 M.S., Environmental Health Sciences, University of Michigan, 1979 

29 B.S., Chemistry, Western Michigan University, 1976 

30 Years of Experience: 30 

31 

32 Robert Van Lonkhuyzen: Proposed Action; Purpose and Need; Scope; Alternatives; Ecological 

33 Resources; Mitigation 

34 B.A., Biology, Trinity Christian College, 1990 

35 Years of Experience: 20 

7. PERIOD COVERED (Inclusive Dates)

5. AUTHOR(S) 6. TYPE OF REPORT

Technical

See Chapter 10

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (tf NRC. provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

provide name and maifing address.)

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental Management Programs

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC. type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission.

and mailing address.)

Same as 8 above

10. SUPPLEMENTARY NOTES

Docket No. 70-7015

11. ABSTRACT (200 words or less)

AREVA Enrichment Services LLC (AES) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for

a license to construct, operate, and decommission the proposed Eagle Rock Enrichment Facility (EREF) near Idaho Falls

in Bonneville County, ldaho. If licensed, the proposed facility would enrich uranium for use in commercial nuclear fuel for

power reactors. Feed material would be non-enriched uranium hexafluoride (UF6). AES would employ a gas centrifuge

process to enrich uranium up to 5 percent uranium-235 by weight, with a planned maximum target production of 6.6

million separative work units (SWUs) per year. The proposed EREF would be licensed in accordance with the provisions

of the Atomic Energy Act. Specifically, an NRC license under Title 10, "Energy," of the U.S. Code of Federal Regulations

(10 CFR) Parts 30, 40, and 70 would be required to authorize AES to possess and use special nuclear material, source

material, and byproduct material at the proposed EREF site.

This Environmental Impact Statement (EIS) was prepared in compliance with the National Environmental Policy Act

(NEPA) and the NRC regulations for implementing NEPA (10 CFR Part 51). This EIS evaluates the potential

environmental impacts of the proposed action and its reasonable alternatives.

12. KEY WORDS/DESCRIPTORS (Ust words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT

unlimited I

EIS for the Proposed Eagle Rock Enrichment Facility in Bonneville County, Idaho

Uranium Enrichment Facility

NUREG-1945

National Environmental Policy Act

NEPA

EREF

AREVA Enrichment Services LLC

AES

AREVA

14. SECURITY CLASSIFICATION

I

(This Page)

unclassified

I

(This Report)

unclassified

15. NUMBER OF PAGES

116. PRICE

I

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER


UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

--------------------

OFFICIAL BUSINESS