Draft Environmental Impact 

Statement for the Proposed 

GE-Hitachi Global Laser 

Enrichment LLC Facility in 

Wilmington, North Carolina 

Draft Report for Comment 

Office of Federal and State Materials and 

Environmental Management Programs 

NUREG-1938

Draft Environmental Impact 

Statement for the Proposed 

GE-Hitachi Global Laser 

Enrichment LLC Facility in 

Wilmington, North Carolina 

Draft Report for Comment 

Manuscript Completed: June 2010 

Date Published: June 2010 

 

Office of Federal and State Materials and 

 Environmental Management Programs 

NUREG-1938 
COMMENTS ON DRAFT REPORT

Any interested party may submit comments on this report for consideration by the NRC staff. 

Comments may be accompanied by additional relevant information or supporting data. Please 

specify the report number NUREG-1938, draft, in your comments, and send them by August 9, 

2010 to the following address:

Chief, Rulemaking and Directives Branch 

Division of Administrative Services 

U.S. Nuclear Regulatory Commission 

Mail Stop TWB-05-B01M 

Washington, DC 20555-0001 

Electronic comments may be submitted to the NRC by e-mail at GLE.EIS@nrc.gov.

 

For any questions about the material in this report, please contact: 

Jennifer Davis 

TWFN T8 F-5 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Phone: 301-415-3835 

E-mail: Jennifer.Davis@nrc.gov 

NUREG-1938, has been reproduced from 

the best available copy. 
 

iii 

1 ABSTRACT 

2 

3 On January 30, 2009, General Electric (GE)-Hitachi Global Laser Enrichment LLC (GLE) 

4 submitted an environmental report to the U.S. Nuclear Regulatory Commission (NRC) for a 

5 license to construct, operate, and decommission the GLE Global Laser Enrichment Facility. 

6 The proposed GLE Facility would be located in the North-Central Sector of the existing GE 

7 property near Wilmington, North Carolina. The proposed GLE Facility, if licensed, would enrich 

8 uranium for use in commercial nuclear fuel for power reactors. Feed material would be 

9 comprised of non-enriched uranium hexafluoride (UF6). GLE would employ a laser-based 

10 enrichment process to enrich uranium to up to eight percent uranium-235 by weight, with an 

11 initial planned maximum target production of six million separative work units (SWUs) per year. 

12 GLE expects to begin preconstruction activities in 2011. If the license is approved, GLE would 

13 expect to begin facility construction in 2012, and continue some construction activities through 

14 2017. GLE anticipates commencing initial production in 2013 and reaching peak production in 

15 2017. Prior to license expiration in 2052, GLE would seek to renew its license to continue 

16 operating the facility, or plan for the decontamination and decommissioning of the facility per the 

17 applicable licensing conditions and NRC regulations. The proposed GLE Facility would be 

18 licensed in accordance with the provisions of the Atomic Energy Act. Specifically, an NRC 

19 license under Title 10, “Energy,” of the U.S. Code of Federal Regulations (10 CFR) Parts 30, 40, 

20 and 70 would be required to authorize GLE to possess and use special nuclear material, source 

21 material, and byproduct material at the proposed GLE site. 

22 

23 This draft Environmental Impact Statement (EIS) was prepared in compliance with the National 

24 Environmental Policy Act and the NRC regulations for implementing the Act (10 CFR Part 51). 

25 This draft EIS evaluates the potential environmental impacts of the proposed action and 

26 reasonable alternatives. This draft EIS also describes the environment potentially affected by 

27 GLE’s proposal, presents and compares the potential environmental impacts resulting from the 

28 proposed action and alternatives, and describes GLE’s environmental monitoring program and 

29 mitigation measures. 

30 

31 

32 

33 

34 

35 Paperwork Reduction Act Statement 

36 

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

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

39 approved by the Office of Management and Budget, approval number 3150-0009. 

40 

41 

42 Public Protection Notification 

43 

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

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

46 currently valid OMB control number. 

47 

48 
 

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v 

1 CONTENTS 

2 

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

4 

5 EXECUTIVE SUMMARY ....................................................................................................... xxv 

6 

7 ACRONYMS AND ABBREVIATIONS.................................................................................... xlv 

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.......................................................... 1-4

14 1.3.1 Need for Enriched Uranium to Fulfill Electricity Requirements................. 1-6

15 1.3.2 Need for Domestic Supplies of Enriched Uranium 

16 for National Energy Security..................................................................... 1-8

17 1.4 Scope of the Environmental Analysis.................................................................... 1-9

18 1.4.1 Scope of the Proposed Action.................................................................. 1-9

19 1.4.2 Scoping Process and Public Participation Activities................................. 1-12

20 1.4.3 Issues Studied in Detail............................................................................ 1-12

21 1.4.4 Issues Eliminated from Detailed Study..................................................... 1-13

22 1.4.5 Issues Outside the Scope of the EIS........................................................ 1-13

23 1.4.6 Related NEPA and Other Relevant Documents ....................................... 1-13

24 1.5 Applicable Statutory and Regulatory Requirements.............................................. 1-15

25 1.5.1 Federal Laws and Regulations ................................................................. 1-15

26 1.5.1.1 National Environmental Policy Act of 1969, 

27 as amended (42 U.S.C. 4321 et seq.)....................................... 1-15

28 1.5.1.2 Atomic Energy Act of 1954, as amended 

29 (42 U.S.C. 2011 et seq.), and the Energy 

30 Reorganization Act of 1974 (42 U.S.C. 5801 et seq.) ............... 1-15 

31 1.5.1.3 Clean Air Act of 1970, as amended 

32 (42 U.S.C. 7401 et seq.)............................................................ 1-15

33 1.5.1.4 Clean Water Act of 1977 (amending the Federal Water 

34 Pollution Control Act of 1948), as amended 

35 (33 U.S.C. 1251 et seq.)............................................................ 1-16

36 1.5.1.5 Resource Conservation and Recovery Act of 1976 

37 (amending the Solid Waste Disposal Act of 1965), 

38 as amended (42 U.S.C. 6901 et seq.)....................................... 1-16

39 1.5.1.6 Low-Level Radioactive Waste Policy Act of 1980, 

40 as amended (42 U.S.C. 2021 et seq.)....................................... 1-16

41 1.5.1.7 Emergency Planning and Community Right-to-Know Act 

42 of 1986 (42 U.S.C. 11001 et seq.)............................................. 1-17

43 1.5.1.8 Safe Drinking Water Act of 1974, as amended 

44 (42 U.S.C. 300f et seq.)............................................................. 1-17
 

vi 

1 CONTENTS (Cont.) 

2 

3 1.5.1.9 Noise Control Act of 1972, as amended 

4 (42 U.S.C. 4901 et seq.)............................................................ 1-17

5 1.5.1.10 National Historic Preservation Act of 1966, as amended 

6 (16 U.S.C. 470 et seq.).............................................................. 1-17

7 1.5.1.11 Endangered Species Act of 1973, as amended 

8 (16 U.S.C. 1531 et seq.)............................................................ 1-18

9 1.5.1.12 Coastal Zone Management Act of 1972, as amended 

10 (16 U.S.C. 1451 et seq.)............................................................ 1-18 

11 1.5.1.13 Magnuson-Stevens Fishery Conservation and Management 

12 Reauthorization Act of 2006, as amended 

13 (16 U.S.C. 1801 et seq.)............................................................ 1-18 

14 1.5.1.14 Occupational Safety and Health Act of 1970, 

15 as amended (29 U.S.C. 651 et seq.)......................................... 1-18

16 1.5.1.15 Hazardous Materials Transportation Act of 1975 

17 (49 U.S.C. 1801 et seq.)............................................................ 1-19 

18 1.5.1.16 United States Enrichment Corporation Privatization 

19 Act of 1996 (42 U.S.C. 2011 et seq.) ........................................ 1-19 

20 1.5.1.17 Environmental Standards for the Uranium Fuel Cycle 

21 (40 CFR Part 190, Subpart B)................................................... 1-19

22 1.5.2 Applicable Executive Orders .................................................................... 1-19

23 1.5.3 Applicable State of North Carolina Requirements .................................... 1-19

24 1.5.4 Permit and Approval Status...................................................................... 1-20

25 1.5.5 Cooperating Agencies .............................................................................. 1-20

26 1.5.6 Consultations............................................................................................ 1-20

27 1.5.6.1 Endangered Species Act of 1973 Consultation......................... 1-23

28 1.5.6.2 National Historic Preservation Act of 1966 

29 Section 106 Consultation .......................................................... 1-23

30 1.5.6.3 Fish and Wildlife Coordination Act of 1934 ............................... 1-27

31 1.6 Organizations Involved in the Proposed Action..................................................... 1-27

32 1.7 References ............................................................................................................ 1-28

33 

34 2 ALTERNATIVES .............................................................................................................. 2-1 

35 

36 2.1 Proposed Action .................................................................................................... 2-1

37 2.1.1 Location and Description of Proposed Site .............................................. 2-2

38 2.1.2 Description of the Proposed GLE Facility................................................. 2-3

39 2.1.2.1 Primary Facilities....................................................................... 2-4

40 2.1.2.2 Other Facility Buildings and Supporting Infrastructure.............. 2-8

41 2.1.2.3 Process Description .................................................................. 2-8

42 2.1.2.4 Waste Management Systems ................................................... 2-10

43 2.1.2.5 Liquid and Air Effluents ............................................................. 2-13

44 2.1.3 Depleted Uranium Management............................................................... 2-14

45 2.1.3.1 Conversion of Depleted UF6...................................................... 2-15
 

vii 

1 CONTENTS (Cont.) 

2 

3 2.1.3.2 Disposal of Depleted Uranium................................................... 2-15

4 2.1.4 Decontamination and Decommissioning .................................................. 2-16

5 2.1.5 Description and Anticipated Schedule for the Phases 

6 of the Proposed Action ............................................................................. 2-17

7 2.2 No-Action Alternative............................................................................................. 2-20

8 2.3 Alternatives Considered but Not Analyzed in Detail.............................................. 2-43

9 2.3.1 Alternative Sites........................................................................................ 2-43

10 2.3.1.1 Alternative Sites Outside of the Wilmington Site....................... 2-43

11 2.3.1.2 Alternative Locations at the Wilmington Site............................. 2-50

12 2.3.2 Alternative Sources of Low-Enriched Uranium......................................... 2-50

13 2.3.2.1 Re-Activate the Portsmouth Gaseous Diffusion 

14 Facility at Piketon ...................................................................... 2-50

15 2.3.2.2 Downblending Highly Enriched Uranium................................... 2-51

16 2.3.2.3 Purchase Low-Enriched Uranium from Foreign Sources.......... 2-51

17 2.3.3 Alternative Technologies for Enrichment.................................................. 2-52

18 2.3.3.1 Electromagnetic Isotope Separation Process ........................... 2-52

19 2.3.3.2 Liquid Thermal Diffusion............................................................ 2-52

20 2.3.3.3 Gaseous Diffusion Process....................................................... 2-53

21 2.3.3.4 Atomic Vapor Laser Isotope Separation.................................... 2-53

22 2.3.3.5 Molecular Laser Isotope Separation.......................................... 2-54

23 2.3.4 Gas Centrifuge ......................................................................................... 2-54

24 2.4 Staff Recommendation Regarding the Proposed Action....................................... 2-65

25 2.5 References ............................................................................................................ 2-65

26 

27 3 AFFECTED ENVIRONMENT........................................................................................... 3-1

28 

29 3.1 Site Location and Description................................................................................ 3-1

30 3.2 Land Use ............................................................................................................... 3-2

31 3.2.1 Proposed GLE Facility Site....................................................................... 3-2

32 3.2.2 New Hanover County ............................................................................... 3-4

33 3.2.3 Brunswick County..................................................................................... 3-4

34 3.2.4 Pender County.......................................................................................... 3-5

35 3.3 Historic and Cultural Resources............................................................................ 3-5

36 3.3.1 Prehistoric................................................................................................. 3-5

37 3.3.1.1 Paleo-Indian Period................................................................... 3-5

38 3.3.1.2 Archaic Period........................................................................... 3-6

39 3.3.1.3 Woodland Period....................................................................... 3-6

40 3.3.2 Ethno-Historic........................................................................................... 3-7

41 3.3.3 Historic Euro-American............................................................................. 3-7

42 3.3.4 Historic and Archaeological Resources at the Proposed GLE Site .......... 3-8

43 3.4 Visual and Scenic Resources................................................................................ 3-8
 

viii 

1 CONTENTS (Cont.) 

2 

3 3.5 Climatology, Meteorology, and Air Quality ............................................................ 3-14

4 3.5.1 Regional Climatology................................................................................ 3-14

5 3.5.2 Site and Regional Meteorology ................................................................ 3-15

6 3.5.2.1 Temperature.............................................................................. 3-15

7 3.5.2.2 Precipitation and Relative Humidity........................................... 3-16

8 3.5.2.3 Winds, Atmospheric Stability, and Temperature Inversions...... 3-16

9 3.5.2.4 Mixing Heights........................................................................... 3-20

10 3.5.2.5 Severe Weather Conditions ...................................................... 3-21

11 3.5.3 Air Quality................................................................................................. 3-23

12 3.5.3.1 Current Emissions at the Wilmington Site................................. 3-25

13 3.5.3.2 Current Air Quality Conditions................................................... 3-27

14 3.6 Geology, Minerals, and Soil................................................................................... 3-30

15 3.6.1 Regional Geology, Structure, and Seismicity ........................................... 3-30

16 3.6.1.1 Regional Earthquakes............................................................... 3-32

17 3.6.1.2 Mineral Resources .................................................................... 3-32

18 3.6.2 Site Geology............................................................................................. 3-33

19 3.6.3 Site Soils................................................................................................... 3-33

20 3.7 Water Resources................................................................................................... 3-33

21 3.7.1 Surface Water Features and Quality ........................................................ 3-34

22 3.7.2 Floodplains ............................................................................................... 3-38

23 3.7.3 Wetlands................................................................................................... 3-38

24 3.7.4 Groundwater............................................................................................. 3-38

25 3.7.4.1 Site and Regional Hydrogeology............................................... 3-38

26 3.7.4.2 Groundwater Use ...................................................................... 3-39

27 3.7.4.3 Groundwater Quality ................................................................. 3-40

28 3.8 Ecological Resources............................................................................................ 3-42

29 3.8.1 Vegetation ................................................................................................ 3-42

30 3.8.1.1 Pine Forest................................................................................ 3-43

31 3.8.1.2 Pine-Hardwood Forest .............................................................. 3-45

32 3.8.1.3 Pine Plantation .......................................................................... 3-45

33 3.8.2 Wetlands................................................................................................... 3-48

34 3.8.3 Environmentally Sensitive Areas .............................................................. 3-50

35 3.8.4 Wildlife...................................................................................................... 3-54

36 3.8.5 Aquatic Biota ............................................................................................ 3-55

37 3.8.6 Threatened, Endangered, and Other Special Status Species.................. 3-57

38 3.8.6.1 Federally Listed Species ........................................................... 3-57

39 3.8.6.2 State-Listed Species ................................................................. 3-72

40 3.9 Noise ..................................................................................................................... 3-85

41 3.10 Transportation ....................................................................................................... 3-90

42 3.10.1 Roads and Highways................................................................................ 3-90

43 3.10.2 Rail Network ............................................................................................. 3-93

44 3.10.3 Water........................................................................................................ 3-94

45 3.10.4 Air ............................................................................................................. 3-94
 

ix 

1 CONTENTS (Cont.) 

2 

3 3.11 Public and Occupational Health ............................................................................ 3-94

4 3.11.1 Background Radiological Exposure.......................................................... 3-94

5 3.11.1.1 General Background Radiation ................................................. 3-95

6 3.11.1.2 Radiological Exposure from GNF-A Operations........................ 3-95

7 3.11.2 Background Chemical Exposure .............................................................. 3-98

8 3.11.3 Public Health Studies ............................................................................... 3-100

9 3.11.3.1 Regulatory Requirements for Public and 

10 Occupational Exposure ............................................................. 3-100

11 3.11.3.2 Health Effects from Radiological Exposure............................... 3-101

12 3.11.3.3 Health Effects from Chemical Exposure.................................... 3-102

13 3.11.3.4 Health Study of Mercury Emissions .......................................... 3-103

14 3.11.4 Occupational Injury and Illness Rates ...................................................... 3-104

15 3.12 Waste Management .............................................................................................. 3-104

16 3.12.1 Current Waste Management Program...................................................... 3-104

17 3.12.2 Wastewater Treatment ............................................................................. 3-105

18 3.12.2.1 Sanitary Wastewater ................................................................. 3-105

19 3.12.2.2 Process Wastewater ................................................................. 3-105

20 3.12.3 Other Liquid Waste................................................................................... 3-106

21 3.12.4 Solid Waste .............................................................................................. 3-109

22 3.12.4.1 Municipal Solid Waste and Nonhazardous 

23 Industrial Wastes....................................................................... 3-109

24 3.12.4.2 Low-Level Radioactive Waste................................................... 3-109

25 3.13 Socioeconomics .................................................................................................... 3-110

26 3.13.1 Population Characteristics........................................................................ 3-110

27 3.13.1.1 Major Population Centers.......................................................... 3-110

28 3.13.1.2 Population Growth Trends......................................................... 3-110

29 3.13.1.3 Transient and Special Populations............................................ 3-112

30 3.13.2 Economic Trends and Characteristics...................................................... 3-112

31 3.13.2.1 Employment .............................................................................. 3-112

32 3.13.2.2 Unemployment .......................................................................... 3-112

33 3.13.2.3 Income ...................................................................................... 3-114

34 3.13.3 Housing Resources and Community and Social Services ....................... 3-114

35 3.13.3.1 Housing ..................................................................................... 3-114

36 3.13.3.2 Schools ..................................................................................... 3-116

37 3.13.3.3 Public Safety ............................................................................. 3-116

38 3.13.4 Tax Structure and Distribution .................................................................. 3-118

39 3.14 Environmental Justice ........................................................................................... 3-118

40 3.14.1 Minority Populations ................................................................................. 3-119

41 3.14.2 Low-Income Populations .......................................................................... 3-121

42 3.14.3 Resource Dependencies and Vulnerabilities of Minority 

43 and Low-Income Populations ................................................................... 3-123

44 3.15 References ............................................................................................................ 3-124

45 
 

x 

1 CONTENTS (Cont.) 

2 

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

4 

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

6 4.2 Preconstruction Activities and the Proposed Action.............................................. 4-2

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

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

9 4.2.1.2 Facility Operations..................................................................... 4-4

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

11 4.2.2 Historic and Cultural Resources Impacts ................................................. 4-5

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

13 4.2.2.2 Facility Operations..................................................................... 4-6

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

15 4.2.3 Visual and Scenic Impacts ....................................................................... 4-7

16 4.2.3.1 Preconstruction and Construction Activities.............................. 4-7

17 4.2.3.2 Facility Operations..................................................................... 4-8

18 4.2.3.3 Mitigation Measures .................................................................. 4-8

19 4.2.4 Air Quality Impacts ................................................................................... 4-8

20 4.2.4.1 Access Road Construction, Land Clearing, and 

21 Construction ............................................................................................. 4-9

22 4.2.4.2 Facility Operations..................................................................... 4-16 

23 4.2.4.3 Mitigation Measures .................................................................. 4-18 

24 4.2.5 Geology and Soil Impacts......................................................................... 4-20

25 4.2.5.1 Preconstruction and Construction Activities.............................. 4-20

26 4.2.5.2 Facility Operations..................................................................... 4-21

27 4.2.5.3 Mitigation Measures .................................................................. 4-21

28 4.2.6 Surface Water Resources Impacts........................................................... 4-22

29 4.2.6.1 Preconstruction and Construction Activities.............................. 4-23

30 4.2.6.2 Facility Operations..................................................................... 4-24

31 4.2.6.3 Mitigation Measures .................................................................. 4-25

32 4.2.7 Groundwater Resources Impacts ............................................................. 4-27

33 4.2.7.1 Preconstruction and Construction Activities.............................. 4-27

34 4.2.7.2 Facility Operations..................................................................... 4-27

35 4.2.7.3 Mitigation Measures .................................................................. 4-28

36 4.2.8 Ecological Impacts.................................................................................... 4-29

37 4.2.8.1 Preconstruction and Construction Activities.............................. 4-30

38 4.2.8.2 Operations and Maintenance .................................................... 4-48

39 4.2.8.3 Mitigation Measures .................................................................. 4-54

40 4.2.9 Noise Impacts........................................................................................... 4-58

41 4.2.9.1 Preconstruction and Construction Activities.............................. 4-58

42 4.2.9.2 Facility Operations..................................................................... 4-61

43 4.2.9.3 Mitigation Measures .................................................................. 4-62

44 4.2.10 Transportation Impacts............................................................................. 4-63

45 4.2.10.1 Preconstruction and Construction Activities.............................. 4-63
 

xi 

1 CONTENTS (Cont.) 

2 

3 4.2.10.2 Facility Operations..................................................................... 4-64

4 4.2.10.3 Mitigation Measures .................................................................. 4-72

5 4.2.11 Public and Occupational Health Impacts from Normal Operations .......... 4-73

6 4.2.11.1 Preconstruction and Construction Activities.............................. 4-73

7 4.2.11.2 Facility Operations..................................................................... 4-77

8 4.2.11.3 Mitigation Measures .................................................................. 4-89

9 4.2.12 Waste Management Impacts.................................................................... 4-92

10 4.2.12.1 Preconstruction and Construction Activities.............................. 4-93

11 4.2.12.2 Facility Operations..................................................................... 4-93

12 4.2.12.3 Mitigation Measures .................................................................. 4-100

13 4.2.13 Socioeconomic Impacts............................................................................ 4-102

14 4.2.13.1 Preconstruction and Construction Activities.............................. 4-104

15 4.2.13.2 Facility Operations..................................................................... 4-106

16 4.2.13.3 Mitigation Measures .................................................................. 4-108

17 4.2.14 Environmental Justice Impacts................................................................. 4-108

18 4.2.15 Accident Impacts ...................................................................................... 4-109

19 4.2.15.1 Accidents Considered ............................................................... 4-110

20 4.2.15.2 Accident Consequences............................................................ 4-110

21 4.2.15.3 Mitigation Measures .................................................................. 4-114

22 4.2.16 Separation of Preconstruction and Construction Impacts ........................ 4-115

23 4.2.17 Impacts from Decontamination and Decommissioning ............................ 4-115

24 4.2.17.1 Land Use................................................................................... 4-117

25 4.2.17.2 Historic and Cultural Resources................................................ 4-117

26 4.2.17.3 Visual and Scenic Resources.................................................... 4-117

27 4.2.17.4 Air Quality.................................................................................. 4-117

28 4.2.17.5 Geology and Soils ..................................................................... 4-118

29 4.2.17.6 Water Resources....................................................................... 4-118

30 4.2.17.7 Ecological Resources................................................................ 4-118

31 4.2.17.8 Noise ......................................................................................... 4-121

32 4.2.17.9 Transportation ........................................................................... 4-121

33 4.2.17.10 Public and Occupational Health ................................................ 4-121

34 4.2.17.11 Waste Management .................................................................. 4-122

35 4.2.17.12 Socioeconomics ........................................................................ 4-122

36 4.2.17.13 Environmental Justice ............................................................... 4-123

37 4.2.17.14 Summary................................................................................... 4-124

38 4.2.18 Carbon Dioxide and Other Greenhouse Gas Impacts.............................. 4-124

39 4.2.18.1 Greenhouse Gases ................................................................... 4-124

40 4.2.18.2 Greenhouse Gase Emissions and Sinks in the United States .. 4-125

41 4.2.18.3 Greenhouse Gas Emissions and Sinks in North Carolina......... 4-126

42 4.2.18.4 Projected Impacts from the Construction, Operation, 

43 and Decommissioning of the Proposed GLE Facility.............. 4-127 

44 
 

xii 

1 CONTENTS (Cont.) 

2 

3 4.3 Cumulative Impacts............................................................................................... 4-132

4 4.3.1 Land Use .................................................................................................. 4-133

5 4.3.2 Historic and Cultural Resources ............................................................... 4-134

6 4.3.3 Air Quality................................................................................................. 4-134

7 4.3.4 Geology and Soils .................................................................................... 4-135

8 4.3.5 Water Resources...................................................................................... 4-136

9 4.3.6 Ecology..................................................................................................... 4-137

10 4.3.7 Transportation .......................................................................................... 4-138

11 4.3.8 Public and Occupational Health ............................................................... 4-139

12 4.3.8.1 Preconstruction and Construction Activities.............................. 4-139

13 4.3.8.2 Operations................................................................................. 4-140

14 4.3.9 Waste Management ................................................................................. 4-141

15 4.3.10 Socioeconomics ....................................................................................... 4-143

16 4.3.11 Environmental Justice .............................................................................. 4-145

17 4.4 Impacts of the No-Action Alternative ..................................................................... 4-145

18 4.4.1 Land Use .................................................................................................. 4-146

19 4.4.2 Historic and Cultural Resources ............................................................... 4-146

20 4.4.3 Visual and Scenic Resources................................................................... 4-147

21 4.4.4 Air Quality................................................................................................. 4-147

22 4.4.5 Geology and Soils .................................................................................... 4-147

23 4.4.6 Water Resources...................................................................................... 4-147

24 4.4.7 Ecological Resources............................................................................... 4-148

25 4.4.8 Noise ........................................................................................................ 4-148

26 4.4.9 Transportation .......................................................................................... 4-148

27 4.4.10 Public and Occupational Health ............................................................... 4-149

28 4.4.11 Waste Management ................................................................................. 4-149

29 4.4.12 Socioeconomic Impacts............................................................................ 4-149

30 4.4.13 Environmental Justice .............................................................................. 4-150

31 4.5 References ............................................................................................................ 4-150

32 

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

34 

35 5.1 Mitigation Measures Proposed by GLE................................................................. 5-1

36 5.2 Potential Mitigation Measures Identified by NRC .................................................. 5-13

37 5.3 References ............................................................................................................ 5-18

38 

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

40 

41 6.1 Radiological Measurements and Monitoring Program........................................... 6-4

42 6.1.1 Air Monitoring ........................................................................................... 6-5
 

xiii 

1 CONTENTS (Cont.) 

2 

3 6.1.2 Direct Radiation Monitoring ...................................................................... 6-5

4 6.1.3 Wastewater and Stormwater Discharge Monitoring ................................. 6-6

5 6.1.4 Surface Water and Sediment Monitoring.................................................. 6-7

6 6.1.5 Groundwater Monitoring........................................................................... 6-7

7 6.1.6 Soil Sampling............................................................................................ 6-8

8 6.2 Nonradiological Measurements and Monitoring Programs.................................... 6-8

9 6.2.1 Physiochemical Monitoring....................................................................... 6-8

10 6.2.1.1 Effluent Monitoring .................................................................... 6-9

11 6.2.1.2 Stormwater Monitoring .............................................................. 6-10

12 6.2.2 Ecological Monitoring ............................................................................... 6-10 

13 6.2.3 Industrial Health and Safety Monitoring.................................................... 6-10 

14 6.2.4 Cylinder Surveillance and Monitoring ....................................................... 6-10 

15 6.3 Quality Assurance ................................................................................................. 6-11 

16 6.4 Reporting............................................................................................................... 6-11 

17 6.5 References ............................................................................................................ 6-12 

18 

19 7 COST-BENEFIT ANALYSIS ............................................................................................ 7-1 

20 

21 7.1 The No-Action Alternative...................................................................................... 7-2

22 7.2 Costs and Benefits of the Proposed Action........................................................... 7-2

23 7.2.1 Costs of the Proposed Action................................................................... 7-3

24 7.2.2 Benefits of the Proposed Action ............................................................... 7-5

25 7.2.3 Summary .................................................................................................. 7-7

26 7.3 Comparative Cost-Benefit Analysis of Proposed Action Relative 

27 to No-Action Alternative......................................................................................... 7-7

28 7.3.1 Methodology............................................................................................. 7-7

29 7.3.2 Compliance with Policy and Technical Objectives ................................... 7-8

30 7.3.2.1 Meeting Future Demand............................................................ 7-8

31 7.3.2.2 National Energy Security........................................................... 7-9

32 7.3.2.3 Technology Upgrade................................................................. 7-9

33 7.3.3 Impacts and Value Analysis ..................................................................... 7-9

34 7.3.4 Summary Regarding the Proposed Action versus 

35 the No-Action Alternative.......................................................................... 7-10

36 7.4 Overall Cost-Benefit Conclusions.......................................................................... 7-10

37 7.5 References ............................................................................................................ 7-10

38 

39 8 SUMMARY OF ENVIRONMENTAL CONSEQUENCES ................................................. 8-1 

40 

41 8.1 Unavoidable Adverse Environmental Impacts....................................................... 8-3

42 8.2 Relationship between Local Short-Term Uses of the Environment 

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

44 8.3 Irreversible and Irretrievable Commitment of Resources ...................................... 8-5
 

xiv 

1 CONTENTS (Cont.) 

2 

3 8.4 References ............................................................................................................ 8-6

4 

5 9 AGENCIES AND PERSONS CONSULTED .................................................................... 9-1 

6 

7 9.1 Federal Agencies................................................................................................... 9-1

8 9.2 Indian Tribes and Organizations............................................................................ 9-1

9 9.3 State Agencies ...................................................................................................... 9-2

10 9.4 Local Agencies ...................................................................................................... 9-3

11 

12 10 LIST OF PREPARERS .................................................................................................... 10-1 

13 

14 10.1 U.S. Nuclear Regulatory Commission (NRC) Contributors ................................... 10-1

15 10.2 Argonne National Laboratory (Argonne) Contributors........................................... 10-1

16 

17 APPENDIX A SCOPING FOR THIS ENVIRONMENTAL IMPACT STATEMENT .............. A-1

18 

19 APPENDIX B CONSULTATION LETTERS......................................................................... B-1

20 

21 APPENDIX C RADIOLOGICAL AND CHEMICAL IMPACT ASSESSMENT 

22 METHODOLOGY AND IMPACTS ................................................................ C-1

23 

24 APPENDIX D TRANSPORTATION METHODOLOGY, ASSUMPTIONS, 

25 AND IMPACTS ............................................................................................. D-1

26 

27 APPENDIX E AIR QUALITY ANALYSIS ............................................................................. E-1

28 

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

30 

31 APPENDIX G ENVIRONMENTAL JUSTICE DATA ............................................................ G-1

32 

33 APPENDIX H PROPRIETARY AND SECURITY-RELATED INFORMATION..................... H-1

34 

35 APPENDIX I GLOSSARY .................................................................................................. I-1

36 

37 FIGURES 

38 

39 1-1 Location of the Proposed GLE Facility....................................................................... 1-2

40 

41 1-2 Wilmington Site and Vicinity....................................................................................... 1-3

42 

43 1-3 Nuclear Fuel Cycle..................................................................................................... 1-5

44 

45 2-1 Schematic of the Existing Wilmington Site................................................................. 2-3

46 
 

xv 

1 FIGURES (Cont.) 

2 

3 2-2 Location of Proposed GLE Facility at the Wilmington Site......................................... 2-4

4 

5 2-3 Anticipated Timeline for the Proposed GLE Facility................................................... 2-19

6 

7 2-4 GLE Site-Selection Results Summary ....................................................................... 2-45

8 

9 2-5 Candidate Sites for the Proposed GLE Facility.......................................................... 2-46

10 

11 2-6 Electromagnetic Isotopic Separation Process............................................................ 2-52

12 

13 2-7 Liquid Thermal Diffusion Process .............................................................................. 2-53

14 

15 2-8 Gaseous Diffusion Stage ........................................................................................... 2-53

16 

17 2-9 Atomic Vapor Laser Isotope Separation Process ...................................................... 2-53

18 

19 2-10 Schematic of a Gas Centrifuge Enrichment Process ................................................. 2-54

20 

21 3-1 Land Use within 8 kilometers of the Project Area ...................................................... 3-3

22 

23 3-2 South Entrance from Castle Hayne Road to the Wilmington Site .............................. 3-9

24 

25 3-3 Existing Site Water Tower Viewed from South of I-140 ............................................. 3-10

26 

27 3-4 Closest Residence to the Proposed GLE Facility Site Viewed from the 

28 North Access Road .................................................................................................... 3-10

29 

30 3-5 Wind Rose for the Wilmington/New Hanover County Airport, 2004 to 2008.............. 3-18

31 

32 3-6 Distribution of Stability Classes for the Wilmington/New Hanover 

33 County Airport, 1984 to 1992 ..................................................................................... 3-20

34 

35 3-7 Mean Morning and Afternoon Mixing Heights for the Wilmington Site, 

36 North Carolina ............................................................................................................ 3-21

37 

38 3-8 Surface Water Features at the Wilmington Site ......................................................... 3-35

39 

40 3-9 Groundwater Monitoring at the Wilmington Site......................................................... 3-41

41 

42 3-10 Level IV Ecoregions Located within the Wilmington Site Area................................... 3-44

43 

44 3-11 Plant Communities Located within the Wilmington Site ............................................. 3-46

45 
 

xvi 

1 FIGURES (Cont.) 

2 

3 3-12 Age and Management of Pine-Dominated Plant Communities 

4 on the Wilmington Site ............................................................................................... 3-49 

5 

6 3-13 Wetlands Located within the Wilmington Site ............................................................ 3-51 

7 

8 3-14 Wetlands Located within the Corridor for the Proposed Access Road 

9 to the Proposed GLE Facility ..................................................................................... 3-53

10 

11 3-15 Locations of Sound Measurements Conducted from October 30 

12 to November 1, 2007, at the Wilmington Site............................................................. 3-89

13 

14 3-16 Map of the Wilmington Region ................................................................................... 3-91

15 

16 3-17 Local Map of the Wilmington Area ............................................................................. 3-92

17 

18 3-18 Percentage Contribution to the Effective Dose in the U.S. Population for 2006 ........ 3-96

19 

20 3-19 Onsite Ambient Air Monitoring Locations for Gross Alpha 

21 and Uranium Isotopes ................................................................................................ 3-97

22 

23 3-20 Existing Wastewater Treatment Facilities and Discharge Points 

24 at the Wilmington Site ................................................................................................ 3-107

25 

26 3-21 Region of Influence for the Proposed GLE Facility .................................................... 3-111

27 

28 3-22 Census Block Groups within a 6.4-kilometer Radius of the Proposed 

29 GLE Facility with Minority Populations that Exceed 50 Percent of 

30 Total Population or Exceed State and County Averages by More than 

31 20 Percentage Points................................................................................................. 3-120

32 

33 3-23 Census Block Groups within a 6.4-kilometer Radius of the Proposed 

34 GLE Facility with Low-Income Populations that Exceed 50 Percent 

35 of the Total Population or Exceed State and County Averages by More 

36 Than 20 Percentage Points........................................................................................ 3-122 

37 

38 4-1 Planned Projects at the Wilmington Site .................................................................... 4-133

39 

40 6-1 GLE Air Monitoring Locations .................................................................................... 6-6

41 

42 D-1 Schematic of a Type 48Y Cylinder............................................................................. D-12

43 

44 D-2 Schematic of a Type 30B Cylinder............................................................................. D-13

45 
 

xvii 

1 FIGURES (Cont.) 

2 

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

4 for Truck Accidents .................................................................................................... D-15

5 

6 E-1 Wind Rose for the Horticultural Crops Research Station in Castle Hayne, 

7 North Carolina, 2005–2008 ....................................................................................... E-34 

8 

9 TABLES 

10 

11 1-1 Licensed and Proposed Domestic Sources of Uranium Enrichment.......................... 1-8

12 

13 1-2 State of North Carolina Environmental Regulations................................................... 1-20

14 

15 1-3 Potentially Applicable Permit and Approval Requirements for the 

16 Construction and Operation of the Proposed GLE Facility......................................... 1-24

17 

18 2-1 Management of Wastewater Generated by Proposed GLE Facility Operations ........ 2-11

19 

20 2-2 Management of Solid Waste Generated at Proposed GLE Facility During 

21 Operations.................................................................................................................. 2-12 

22 

23 2-3 Summary of Environmental Impacts for the Proposed GLE Facility 

24 and the No-Action Alternative .................................................................................... 2-21

25 

26 2-4 Candidate Sites Considered for the Proposed GLE Facility ...................................... 2-47

27 

28 2-5 Ranking Results for the Sites in Morris, Illinois, and Wilmington, North Carolina ...... 2-51

29 

30 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology 

31 and Centrifuge Technology ........................................................................................ 2-56

32 

33 3-1 Explanation of Scenic Quality Rating Criteria ............................................................ 3-12

34 

35 3-2 Scenic Quality Inventory and Evaluation Chart.......................................................... 3-13

36 

37 3-3 Monthly Average and Daily Extreme Temperatures at the 

38 Wilmington/New Hanover County Airport, North Carolina ......................................... 3-15

39 

40 3-4 Monthly Mean and Extreme Precipitation and Snowfall at the 

41 Wilmington/New Hanover County Airport, North Carolina ......................................... 3-17

42 

43 3-5 National Ambient Air Quality Standards and North Carolina State 

44 Ambient Air Quality Standards for Criteria Pollutants ................................................ 3-24
 

xviii 

1 TABLES (Cont.) 

2 

3 3-6 Annual Point Source Emissions of Criteria Pollutants and VOCs in 

4 New Hanover County, Neighboring Brunswick and Pender Counties 

5 for 2007, and at the Wilmington Site for 2004............................................................ 3-26

6 

7 3-7 Annual Emissions for Large Point Sources in New Hanover County 

8 and Neighboring Brunswick and Pender Counties for 2007....................................... 3-28

9 

10 3-8 Annual Toxic Air Pollutant Emissions at the Wilmington Site in 2004........................ 3-29

11 

12 3-9 Highest Background Concentrations at Monitoring Stations in 

13 New Hanover County, North Carolina, during the Period 2004 to 2008 .................... 3-31

14 

15 3-10 Geologic Units at the North–Central Sector of the Wilmington Site ........................... 3-32

16 

17 3-11 Level IV Ecoregions within the Wilmington Site ......................................................... 3-45

18 

19 3-12 Plant Communities That Occur on the Wilmington Site ............................................. 3-47

20 

21 3-13 Wetlands That Occur on the Wilmington Site ............................................................ 3-52

22 

23 3-14 Federally Threatened, Endangered, and Special Concern Species 

24 Reported from New Hanover County, North Carolina................................................ 3-58

25 

26 3-15 State Rare Species Reported from New Hanover County, North Carolina................ 3-73

27 

28 3-16 Summary of Noise Levels Identified as Requisite to Protect Public 

29 Health and Welfare with an Adequate Margin of Safety ............................................ 3-87

30 

31 3-17 Annual Average Daily Traffic on Major Roads near the Wilmington Site ................... 3-93

32 

33 3-18 Occupational Dose Limits for Adults Established by 10 CFR Part 20........................ 3-102

34 

35 3-19 Cancer Incidence and Death Rates for all Cancers for 2000 to 2005........................ 3-103

36 

37 3-20 Wastewater Streams Generated by Current Operations 

38 at the Wilmington Site ................................................................................................ 3-106

39 

40 3-21 Solid and Liquid Wastes Generated by Current Operations 

41 at the Wilmington Site ................................................................................................ 3-108

42 

43 3-22 Population in the ROI and North Carolina.................................................................. 3-112

44 

45 3-23 ROI Employment in 2006 ........................................................................................... 3-113
 

xix 

1 TABLES (Cont.) 

2 

3 3-24 ROI Unemployment Rates ......................................................................................... 3-114

4 

5 3-25 ROI and State Personal Income ................................................................................ 3-115

6 

7 3-26 ROI Housing Characteristics...................................................................................... 3-117

8 

9 3-27 School District Data for the ROI in 2007 .................................................................... 3-118

10 

11 3-28 Public Safety Employment in the ROI in 2009 ........................................................... 3-118

12 

13 3-29 Minority and Low-Income Populations within a 6.4-kilometer 

14 Radius of the Proposed GLE Site .............................................................................. 3-121

15 

16 3-30 Selected Health Statistics for Counties near the Proposed GLE Facility ................... 3-124

17 

18 4-1 Estimated Air Emissions of Criteria Pollutants and VOCs from Construction 

19 and Operation of the Proposed GLE Facility.............................................................. 4-12

20 

21 4-2 Maximum Air Quality Impacts Due to Emissions Associated with 

22 Road Construction and Land Clearing Activities for the Proposed GLE Facility........ 4-14

23 

24 4-3 Maximum Air Quality Impacts Due to Emissions Associated 

25 with Building Construction Activities for the Proposed GLE Facility........................... 4-15

26 

27 4-4 Impacts on Plant Communities Due to Preconstruction and Construction 

28 Activities for the Proposed GLE Facility ..................................................................... 4-31

29 

30 4-5 Significance Levels of Potential Impacts on Vegetation, Wetlands, 

31 and Environmentally Sensitive Areas from the Proposed GLE Facility...................... 4-34

32 

33 4-6 Significance Levels of Potential Impacts on Wildlife from the 

34 Proposed GLE Facility ............................................................................................... 4-38

35 

36 4-7 Significance Levels of Potential Impacts on Aquatic Biota 

37 from the Proposed GLE Facility ................................................................................. 4-40

38 

39 4-8 Assumed Number of Noise Sources for Use in Sound Propagation Modeling .......... 4-59

40 

41 4-9 Estimated Cumulative Sound Levels at the Fenceline Receptor 

42 Nearest to the Wooden Shoe Residential Subdivision............................................... 4-60

43 

44 4-10 Estimated Traffic Generated by Construction, Operation, 

45 and Decommissioning of the Proposed GLE Facility ................................................. 4-65
 

xx 

1 TABLES (Cont.) 

2 

3 4-11 Estimated External Dose Rates for Radioactive Material Shipments......................... 4-68

4 

5 4-12 Estimated Collective Population Proposed GLE Facility Single Shipment 

6 Transportation Risks .................................................................................................. 4-69

7 

8 4-13 Estimated Annual Collective Population Proposed GLE Facility Transportation 

9 Risks .......................................................................................................................... 4-70

10 

11 4-14 Maximally Exposed Individual Routine Dose from Radioactive 

12 Material Shipments .................................................................................................... 4-71

13 

14 4-15 Health and Safety Statistics for Estimating Industrial Safety Impacts 

15 Common to the Workplace and Total Incidents for Preconstruction 

16 and Construction Activities......................................................................................... 4-75

17 

18 4-16 Health and Safety Statistics for Estimating Industrial Safety Impacts 

19 Common to the Workplace and Total Incidents for Facility Operations ..................... 4-78

20 

21 4-17 Predicted Airborne Concentrations of Uranium and Hydrogen Fluoride from 

22 the Proposed GLE Facility Stack Releases at Different Receptor Locations............. 4-81

23 

24 4-18 Proposed GLE Facility Stack/Vent Characteristics, Site Characteristics, and Stack 

25 Releases Used in Modeling ....................................................................................... 4-83

26 

27 4-19 Annual Effective Dose from Proposed GLE Facility Stack Releases 

28 at Different Receptor Locations ................................................................................. 4-85

29 

30 4-20 Estimated Doses for Liquid Effluent Releases from the Proposed GLE Facility ........ 4-88

31 

32 4-21 Annual CEDE and TEDE for Fuel Cycle Facilities 

33 within the United States for 2003–2007 ..................................................................... 4-90

34 

35 4-22 Estimated Construction Hazardous Wastes for the Proposed GLE Facility............... 4-94

36 

37 4-23 Wastewater Volume Estimates for the Proposed GLE Facility .................................. 4-95

38 

39 4-24 Operations Waste Estimates for the Proposed GLE Facility...................................... 4-97

40 

41 4-25 Effects of the Proposed GLE Facility on ROI Socioeconomics.................................. 4-105

42 

43 4-26 Definition of High- and Intermediate-Consequence Events ....................................... 4-111
 

xxi 

1 TABLES (Cont.) 

2 

3 4-27 Summary of Health Effects Resulting from Accidents................................................ 4-112

4 

5 4-28 Summary of Anticipated Impacts from Preconstruction and Construction 

6 Activities ..................................................................................................................... 4-116

7 

8 4-29 Annual CO2 Emissions from Access Road Construction, Land Clearing, Building 

9 Construction, Start-up and Final Construction, and Operation of the Proposed 

10 GLE Facility................................................................................................................ 4-129

11 

12 4-30 Cumulative Wastewater Generation at the Wilmington Site ...................................... 4-142

13 

14 5-1 Summary of Mitigation Measures Proposed by GLE ................................................. 5-2

15 

16 5-2 Summary of Potential Mitigation Measures Identified by NRC................................... 5-14

17 

18 6-1 Summary of GLE Environmental Monitoring Program ............................................... 6-2

19 

20 6-2 Guidance Documents That Apply to the Radiological Monitoring Program ............... 6-4 

21 

22 7-1 Socioeconomic Benefits Associated with the Proposed GLE Facility ........................ 7-6 

23 

24 B-1 Consultations with Government Agencies Related to Threatened and 

25 Endangered Species and Critial Habitats .................................................................. B-3 

26 

27 B-2 NRC Correspondence with American Indian Tribes and Organizations .................... B-96 

28 

29 B-3 Section 106 Correspondence with the North Carolina SHPO 

30 and the Advisory Council on Historic Preservation ................................................... B-97 

31 

32 B-4 Additional Consultations with Government Agencies................................................. B-109 

33 

34 C-1 Radionuclide-Specific Parameters Used in the RESRAD Code 

35 for Radiological Impact Assessment .......................................................................... C-17

36 

37 C-2 FMO and GLE Emissions and Site Characteristics Used in Modeling....................... C-17 

38 

39 C-3 Receptor Location for Radiation Dose and Chemical Toxicity Estimation 

40 from GLE Stack Releases.......................................................................................... C-19

41 

42 C-4 Agricultural Input Parameters Used in the Radiological Impact Assessment............. C-20

43 

44 C-5 Radionuclide-Specific Inputs Used in the Radiological Impact Assessment.............. C-21
 

xxii 

1 TABLES (Cont.) 

2 

3 C-6 Estimated Radionuclide Concentrations in Surface Water 

4 at Exposure Locations................................................................................................ C-22

5 

6 C-7 Estimated Number of People Involved in Different Recreational Activities ................ C-23

7 

8 C-8 Radionuclide-Specific Parameters Used in the GENII-Code 

9 for Radiological Impact Assessment .......................................................................... C-24

10 

11 C-9 Exposure Parameters for Different Activities ............................................................. C-25

12 

13 C-10 Annual Effective Dose from Proposed GLE Facility Stack Releases

14 at Different Receptor Locations.................................................................................. C-26

15 

16 C-11 Predicted Airborne Concentrations of Uranium and HF from the Proposed 

17 GLE Facility Stack Releases at Different Receptor Locations ................................... C-27

18 

19 C-12 Estimated Doses from Cylinder Storage Pad............................................................. C-28

20 

21 C-13 Estimated Doses for Liquid Effluent Releases from the Proposed GLE Facility ........ C-29

22 

23 C-14 Annual CEDE and TEDE for Fuel Cycle Facilities within the 

24 United States for 2003–2007 ..................................................................................... C-32

25 

26 D-1 Summary Route Data................................................................................................. D-10

27 

28 D-2 Radioactive Material Shipment Information ............................................................... D-12

29 

30 D-3 Single-Shipment Radionuclide Inventories ................................................................ D-13

31 

32 D-4 Fractional Occurrences for Truck Accidents by Severity Category 

33 and Population Density Zone ..................................................................................... D-16

34 

35 D-5 Estimated Release Fractions for Type A and Type B packages 

36 under Various Accident Severity Categories.............................................................. D-16

37 

38 D-6 External Dose Rates and Package Sizes Used in RADTRAN................................... D-18

39 

40 D-7 General RADTRAN Input Parameters ....................................................................... D-18

41 

42 E-1 General Assumptions for Estimating Air Emissions Associated 

43 with Construction and Operation of the Proposed GLE Facility ................................. E-12 

44 
 

xxiii 

1 TABLES (Cont.) 

2 

3 E-2 Input Parameters Used for Estimating Air Emissions at the Proposed 

4 GLE Facility: Road Construction Followed by Land Clearing .................................... E-14

5 

6 E-3 Input Parameters Used for Estimating Air Emissions at the Proposed 

7 GLE Facility: Building Construction............................................................................ E-17

8 

9 E-4 Input Parameters Used for Estimating Air Emissions at the Proposed 

10 GLE Facility: Start-up and Final Construction ............................................................ E-19

11 

12 E-5 Input Parameters Used for Estimating Air Emissions at the Proposed 

13 GLE Facility: Operations ............................................................................................ E-21

14 

15 E-6 Estimated Average Daily Criteria Air Pollutant and VOC Emissions 

16 at the Proposed GLE Facility During Road Construction and Land Clearing............. E-24

17 

18 E-7 Estimated Average Annual Criteria Air Pollutant and VOC Emissions 

19 at the Proposed GLE Facility During Road Construction and Land Clearing............. E-26

20 

21 E-8 Estimated Average Daily Criteria Air Pollutant and VOC Emissions 

22 at the Proposed GLE Facility During Building Construction....................................... E-27

23 

24 E-9 Estimated Average Annual Criteria Air Pollutant and VOC Emissions 

25 at the Proposed GLE Facility During Building Construction....................................... E-28

26 

27 E-10 Estimated Average Daily Criteria Air Pollutant and VOC Emissions 

28 at the Proposed GLE Facility During Start-up and Final Construction ....................... E-29

29 

30 E-11 Estimated Average Annual Criteria Air Pollutant and VOC Emissions 

31 at the Proposed GLE Facility During Start-up and Final Construction ....................... E-30

32 

33 E-12 Estimated Average Daily Criteria Air Pollutant and VOC Emissions 

34 at the Proposed GLE Facility During the Operations ................................................. E-31

35 

36 E-13 Estimated Average Annual Criteria Air Pollutant and VOC Emissions 

37 at the Proposed GLE Facility During Operations ...................................................... E-32

38 

39 E-14 Meteorological Data Information Used for AERMET.................................................. E-33

40 

41 G-1 State and County Minority Population Totals ............................................................. G-4

42 

43 G-2 Census Block Group Minority Population Totals........................................................ G-5
 

xxiv 

1 TABLES (Cont.) 

2 

3 G-3 State and County Low-Income Population Totals ...................................................... G-6

4 

5 G-4 Census Block Group Low-Income Population Totals................................................. G-7

6 
 

xxv 

1 EXECUTIVE SUMMARY 

2 

3 BACKGROUND 

4 

5 Pursuant to Title 10 of the U.S. Code of Federal Regulations (10 CFR) Parts 30, 40, and 70, the 

6 U.S. Nuclear Regulatory Commission (NRC) is considering whether to issue a license that 

7 would allow General Electric (GE)-Hitachi Global Laser Enrichment LLC (GLE) to possess and 

8 use special nuclear material, source material, and byproduct material at a proposed laser-based 

9 uranium enrichment facility near Wilmington, North Carolina. The scope of activities to be 

10 conducted under the license would include the construction, operation, and decommissioning of 

11 the proposed GLE Facility. GLE submitted its Environmental Report (GLE, 2008) to the NRC 

12 on January 30, 2009, and the license application was submitted on June 26, 2009. To support 

13 its licensing decision on the proposed GLE Facility, the NRC’s implementing regulations in 

14 10 CFR Part 51 for the National Environmental Policy Act (NEPA) require the preparation of an 

15 Environmental Impact Statement (EIS). The development of this draft EIS is based on the NRC 

16 staff’s review of information provided by GLE, the NRC staff’s independent analyses, and 

17 consultation with other Federal agencies, American Indian tribes and organizations, State 

18 agencies, and local agencies. 

19 

20 The enriched uranium produced at the proposed GLE Facility would be used to manufacture 

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

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

23 usually contains approximately 0.72 percent uranium-235 by weight. To be useful in nuclear 

24 power plants as fuel for electricity generation, uranium must be enriched to approximately 

25 3–5 percent uranium-235 by weight. 

26 

27 THE PROPOSED ACTION 

28 

29 The proposed action considered in this draft EIS is for GLE to construct, operate, and 

30 decommission a laser-based uranium enrichment facility, the proposed GLE Facility, at a site 

31 near Wilmington, North Carolina. If the NRC would issue a license to GLE, the license would 

32 authorize GLE to possess and use special nuclear material, source material, and byproduct 

33 material at the proposed GLE Facility for a period of 40 years. If the license is granted, the 

34 proposed GLE Facility would be located in the North-Central Sector of the existing GE property 

35 near Wilmington, North Carolina. 

36 

37 The proposed GLE Facility would employ a laser-based enrichment process to enrich uranium 

38 to up to 8 percent uranium-235 by weight (although nuclear power reactors normally require 

39 three to five percent uranium-235 by weight), with an initial planned maximum target production 

40 of 6 million separative work units (SWUs) per year. GLE expects to begin preconstruction 

41 activities in 2011. If the license is approved, GLE would expect to begin facility construction in 

42 2012, and continue construction activities though 2017. GLE anticipates commencing initial 

43 production in 2013 and reaching peak production in 2017. Prior to license expiration in 2052, 

44 GLE would decide to either seek to renew its license to continue operating the facility, or plan 

45 for the decontamination and decommissioning of the facility per the applicable licensing 

46 conditions and NRC regulations. 

47 
 

xxvi 

1 PURPOSE OF AND NEED FOR THE PROPOSED ACTION 

2 

3 The purpose of the proposed action is for GLE to construct and operate a facility to enrich 

4 uranium up to 8 percent uranium-235 by weight, with a production capacity of 6 million SWU per 

5 year, using laser-based technology at the proposed GLE Facility near Wilmington, 

6 North Carolina. This facility would provide an additional domestic source of low-enriched 

7 uranium to be used in commercial nuclear power plants. 

8 

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

10 United States Enrichment Corporation (USEC) is currently the sole U.S. supplier of low-enriched 

11 uranium for nuclear fuel in the United States. However, the National Enrichment Facility (NEF) 

12 near Eunice, New Mexico and the American Centrifuge Plant (ACP) in Piketon, Ohio, both 

13 currently under construction, would also be expected to provide enrichment services in the 

14 future. USEC has one operating enrichment plant near Paducah, Kentucky, which supplies 

15 approximately 10–15 percent of the current U.S. demand for low-enriched uranium. USEC also 

16 imports downblended (diluted) weapons-grade uranium from Russia to supply an additional 

17 38 percent of the U.S. demand. The remaining 47–52 percent is imported from foreign 

18 suppliers. The current dependence on a single U.S. supplier and foreign sources for low19 enriched uranium imposes reliability risks for the nuclear fuel supply to U.S. nuclear power 

20 plants. The production of enriched uranium at the proposed GLE Facility would be equivalent to 

21 about 40 percent of the current and projected demand (16 million SWU) for enrichment services 

22 within the United States. 

23 

24 ALTERNATIVES 

25 

26 The NRC staff considered a reasonable range of alternatives, including the no-action 

27 alternative, in this draft EIS. Two of the alternatives, the proposed action and the no-action 

28 alternative, were analyzed in detail. Under the no-action alternative, the proposed GLE Facility 

29 would not be constructed, operated, and decommissioned. Enrichment services would continue 

30 to be performed by existing domestic and foreign uranium enrichment suppliers. However, the 

31 NEF and ACP, and potentially another enrichment facility that is currently under NRC review 

32 (AREVA’s proposed Eagle Rock Enrichment Facility [EREF]), would also be expected to provide 

33 enrichment services in the future. 

34 

35 GLE considered 22 sites throughout the United States, evaluating them based on various 

36 technical, safety, economic, and environmental criteria. GLE concluded that the site considered 

37 in the proposed action met all of the criteria and none of the other candidate sites were 

38 obviously superior to the preferred site near Wilmington, North Carolina. The NRC staff has 

39 reviewed the GLE site selection process and determined that it is rational and objective, and 

40 that its results are reasonable. Therefore, no other site was analyzed further in this draft EIS. 

41 

42 The NRC staff examined three alternatives to satisfy domestic enrichment needs, including 

43 (1) reactivation of the Portsmouth Gaseous Diffusion Plant near Piketon, Ohio, 

44 (2) downblending of high-enriched uranium, and (3) purchase of low-enriched uranium from 

45 foreign sources. These alternatives were eliminated from further consideration based on 

46 reliability, excessive energy consumption, national energy policy objectives, and national energy 

47 security concerns. 

48 
 

xxvii 

1 The NRC staff also evaluated several alternative technologies to the laser-based enrichment 

2 process, including electromagnetic isotope separation, liquid thermal diffusion, gaseous 

3 diffusion, atomic vapor laser isotope separation, molecular laser isotope separation, and gas 

4 centrifuge. All of these technologies, except gas centrifuge, were eliminated from further 

5 consideration based on the technologies’ maturity and economic viability. The environmental 

6 impacts of gas centrifuge technology were qualitatively evaluated, relative to those of the 

7 proposed laser-based technology. Although gas centrifuge is a technologically and 

8 economically viable alternative, it is not obviously superior to the laser-based technology that 

9 GLE has chosen to pursue for the proposed action. 

10 

11 The NRC staff also evaluated alternative conversion and disposition methods for depleted 

12 uranium hexafluoride (UF6), including (1) beneficial use of depleted UF6 and (2) conversion at 

13 facilities other than the new facilities that the U.S. Department of Energy (DOE) is constructing 

14 at Portsmouth, Ohio, and Paducah, Kentucky. For the purposes of this analysis, because the 

15 current available inventory of depleted uranium exceeds the current and projected future 

16 demand for the material, the depleted UF6 generated by the proposed GLE Facility was 

17 considered a waste product, and disposition alternatives involving its use as a resource were 

18 not further evaluated. Existing fuel fabrication facilities have not expressed an interest in 

19 performing depleted UF6 conversion services, and the cost for the services would be difficult to 

20 estimate. Therefore, this alternative was eliminated from further consideration. However, 

21 International Isotopes, Inc., submitted a license application to the NRC on December 31, 2009, 

22 to construct and operate a depleted UF6 conversion facility near Hobbs, New Mexico. On 

23 February 23, 2010, the NRC staff accepted the license application. NRC staff has initiated a 

24 formal safety and environmental review. 

25 

26 NRC EXEMPTION TO CONDUCT CERTAIN PRECONSTRUCTION ACTIVITIES 

27 

28 The NRC has approved an exemption request from GLE to conduct certain preconstruction 

29 activities prior to NRC’s decision to issue a license for the construction and operation of the 

30 proposed GLE Facility. The exemption covers the following activities and facilities: 

31 

32 • Clearing of 47 hectares (117 acres) for the proposed GLE Facility; 

33 

34 • Site grading and erosion control; 

35 

36 • Installing a stormwater retention system; 

37 

38 • Constructing main access roadways and guardhouse(s); 

39 

40 • Installing utilities (electricity, potable water, process water, water for fire suppression, 

41 sanitary sewer, and natural gas); 

42 

43 • Constructing parking lots and minor roadways; and 

44 

45 • Constructing administrative building(s). 

46 

47 The NRC granted the exemption on May 8, 2009. This exemption authorizes GLE to conduct 

48 the stated activities, provided that none of the facilities or activities subject to the exemption 
 

xxviii 

1 would be components of GLE’s Physical Security Plan or its Standard Practice Procedures Plan 

2 for the Protection of Classified Matter, or otherwise be subject to NRC review or approval. 

3 These activities are assumed to occur prior to NRC’s decision to grant a license to GLE, and 

4 therefore, are assumed to occur under both the proposed action and no-action alternatives. 

5 

6 POTENTIAL ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION 

7 

8 This draft EIS evaluates the potential environmental impacts of the proposed action, which are 

9 summarized below. The anticipated environmental impacts from the proposed action are 

10 SMALL or SMALL to MODERATE. 

11 

12 The NRC defines three significance levels for rating impacts on a resource: 

13 

14 • Small impact: Environmental effects are not detectable or are so minor that they will neither 

15 destabilize nor noticeably alter any important attribute of the resource. 

16 

17 • Moderate impact: Environmental effects are sufficient to alter noticeably, but not destabilize, 

18 important attributes of the resource. 

19 

20 • Large impact: Environmental effects are clearly noticeable and are sufficient to destabilize 

21 important attributes of the resource. 

22 

23 Land Use 

24 

25 Small Impact. The project area is owned by GE, contains mostly mixed pine forest, and is 

26 bordered by existing GE facilities, the Northeast Cape Fear River, and residential development. 

27 The project area is zoned for heavy industrial use, and an enrichment facility is consistent with 

28 current zoning. Construction will alter the current land use of undeveloped forest but is not 

29 expected to affect surrounding land use. 

30 

31 Operation of a uranium enrichment facility will affect land use and could affect nearby residential 

32 developments. However, operation of such a facility is consistent with existing industrial 

33 developments at the Wilmington Site. 

34 

35 Historical and Cultural Resources 

36 

37 Small to Moderate Impact. The study area comprises 106 hectares (263 acres). Construction 

38 would take place on ground previously disturbed by preconstruction. No construction activities 

39 are expected to occur in the portion of the Wilmington Site where historic and cultural resources 

40 are known to exist. 

41 

42 Facility operation has the potential to affect historic and cultural resources. Operational impacts 

43 depend largely on procedures employed to protect historic and archaeological resources. 

44 Resources could be affected if expansion of the facility is deemed necessary and occurs in 

45 areas that contain these resources. No facility activities are expected that would affect Middle 

46 Woodland archaeological site 31NH801. However, the North Carolina State Historic 

47 Preservation Office (SHPO) has requested that GLE develop procedures to protect site 

48 31NH801. These procedures have not been finalized and consultation between GLE and the 
 

xxix 

1 North Carolina SHPO is ongoing. Impact levels could be reduced if a plan for the site is 

2 developed and implemented. 

3 

4 Visual and Scenic Resources 

5 

6 Small Impact. The project area has low scenic quality and the environment in the project area is 

7 not unique for the area. The proposed facility site is adjacent to other industrial developments 

8 and will not alter a pristine environment. Likewise, the project area is not in a location that is 

9 sensitive to visual intrusions. There is limited expectation that the area would be kept in a 

10 wilderness condition. 

11 

12 Construction activities would be concentrated on the Wilmington Site. The greatest visual 

13 impacts would result from increased truck and worker traffic, but these impacts would be 

14 temporary. The main project area is surrounded by a vegetation barrier, so construction 

15 activities would be largely screened. Construction cranes would be visible from greater 

16 distances, but this impact would be temporary. 

17 

18 During operation, the two most visible (i.e., tallest) features of the proposed facility would be the 

19 water tower and a portion of the operations building referred to as the operations building tower. 

20 The operations building tower will have front and side profiles of 37 meters (120 feet) by 200 

21 meters (660 feet), and could reach up to 49 meters (160 feet) above grade. The proposed 

22 water tower is the same height as the existing Wilmington Site water tower, the top of which is 

23 visible from south of Interstate 140 (I-140). Although the operations building tower could be 10 

24 meters (30 feet) taller than the existing water tower, it would be visible primarily from Castle 

25 Hayne Road and the residential subdivision to the northeast because it would be further from I26 140 than the existing water tower. The intrusion of the water tower, facility, and operations 

27 building tower would not represent a major alteration of the existing visual environment. 

28 Portions of the proposed facility may be visible from I-140, and the planting of additional 

29 vegetation may minimize visual impacts. 

30 

31 Air Quality 

32 

33 Small to Moderate Impact. Potential air quality impacts would be the highest during 

34 preconstruction activities (which are not a part of the proposed action) and the initial two years 

35 of construction. Air emissions of criteria pollutants, volatile organic compounds (VOCs), 

36 greenhouse gases, and hazardous air pollutants (HAPs) would include primarily fugitive dust 

37 emissions and engine exhaust emissions. Potential impacts of sulfur dioxide (SO2), nitrogen 

38 dioxide (NO2), and carbon monoxide (CO) emissions on ambient air quality would be SMALL 

39 (well below applicable standards), and construction activities would have SMALL impacts on 

40 ambient air quality for all criteria pollutants. Lead emissions are expected to be negligible and 

41 potential carbon dioxide (CO2) emissions would be SMALL. 

42 

43 Total 24-hour concentrations of particulate matter equal to or smaller than 10 micrometers 

44 (PM10) and particulate matter equal to or smaller than 2.5 micrometers (PM2.5), mostly resulting 

45 from fugitive dust emissions, are predicted to exceed the standards during the preconstruction 

46 and construction phases. In addition, high PM10 and PM2.5 concentrations could result from 

47 fugitive dust emissions from vehicle traffic on the unpaved access road during preconstruction 

48 activities. Since preconstruction and construction activities would last about nine months and 
 

xxx 

1 two years, respectively, the potential air quality impacts during the preconstruction phase are 

2 expected to be MODERATE but temporary in nature. To minimize the impacts on air quality 

3 from fugitive dust, aggressive dust control measures would be implemented during the 

4 preconstruction and construction phases. While the impacts of fugitive dust emissions are 

5 expected to be MODERATE, these impacts would be temporary and appropriately mitigated. 

6 

7 Because the proposed facility will not employ any continuous combustion activities during 

8 operation, criteria pollutant and HAP emission rates are expected to be SMALL. Uranium9 related and/or hydrogen fluoride (HF) stack emissions would be minimal. Fugitive air emissions 

10 from diesel fuel handling would be very low. Vehicles using onsite roads would contribute 

11 emissions, but these would decrease with time. Fugitive dust emissions during operation would 

12 be minimal, as most working areas and roads would be paved. Ozone precursor emissions 

13 would be relatively small, so the potential impacts on regional ozone would be SMALL. 

14 

15 Geology and Soils 

16 

17 Small Impact. Approximately 91 hectares (226 acres) of land would be disturbed under the 

18 proposed action, including the proposed facility site, support structures, and road construction. 

19 Construction vehicles and equipment could potentially leak fuel, oil, or grease to site soils. 

20 Soil-related aspects of construction would include soil excavation, soil storage and removal, and 

21 stormwater management. Construction would not impact site geologic resources because the 

22 site lacks significant geologic resources. 

23 

24 Soil disturbance during operations would occur at a reduced level, as some construction 

25 projects would be completed, while others are ongoing. Restoration and seeding would limit 

26 erosion due to stormwater. Roads, parking lots, and roofs would create impervious surfaces 

27 and increase runoff, increasing the erosion potential. Large storm events could create erosion 

28 along drainages or at culverts, requiring maintenance or drainage system improvement. 

29 Vehicles and equipment used in unpaved areas could potentially leak fuel, oil, or grease to site 

30 soils. Groundwater pumping is expected to have a minimal effect on groundwater levels, and 

31 the associated degree of subsidence is expected to be negligible. Other geologic hazards to 

32 the site are not anticipated. 

33 

34 Surface Water Resources 

35 

36 Small Impact. Excavations during construction would lead to possible short-term soil erosion 

37 with impacts on surface water quality. The proposed access road would have a new stream 

38 crossing and possibly change a jurisdictional channel, which could lead to erosion and 

39 increased sediment load. Construction vehicles and equipment pose the possibility of leaks or 

40 spills of fuels, oil, or grease, which could run off and impact nearby surface water. However, it 

41 is unlikely that a minor spill would reach the Northeast Cape Fear River or Prince George 

42 Creek. Infiltration into site soil would likely eliminate runoff. 

43 

44 Process wastewater effluent would be discharged at an existing outfall during operation, 

45 increasing the site’s process wastewater volume by about 7 percent. Liquid radioactive waste 

46 would be pretreated to reduce uranium to acceptable levels before transfer to the existing 

47 wastewater treatment facility. Treatment would produce an effluent similar to current process 

48 wastewaters. Treated sanitary wastewater effluent would be reused in site cooling towers. 
 

xxxi 

1 

2 No consumption of surface water use would take place during operation. Stormwater runoff 

3 would collect in a State-permitted detention basin before discharge and would be regulated by a 

4 National Pollutant Discharge Elimination System (NPDES) permit. Stormwater runoff from the 

5 UF6 cylinder storage pads would collect in a lined retention pond. If monitoring demonstrates a 

6 lack of radioactivity, pond effluent would be discharged to the stormwater detention basin and 

7 ultimately, to the effluent channel. Any increase in turbidity and sediment loading to streams as 

8 a result of construction would subside during operation. Oil, grease, metals, and other 

9 automotive-related contaminants would be present in limited quantities due to general traffic. 

10 The use of herbicides in landscaped areas would be similar to their use elsewhere at the 

11 Wilmington Site. 

12 

13 Groundwater Resources 

14 

15 Small Impact. Construction equipment poses the potential for leaks of fuel, oil, and grease to 

16 soil and groundwater; implementation of best management practices (BMPs) would reduce 

17 these impacts. The use of portable toilets during construction would eliminate sanitary system 

18 impacts on groundwater. Potable and nonpotable construction water requirements would be 

19 met by transport of offsite water by tanker truck. 

20 

21 During operation, the stormwater collected from the UF6 cylinder storage pad is expected to 

22 have no more than trace amounts of radiological contaminants, and the liner is expected to limit 

23 infiltration to groundwater. Discharge at site outfalls would be from process and sanitary 

24 wastewater. Some portion of these effluents may potentially infiltrate the Peedee sand aquifer. 

25 However, treatment and monitoring are expected to result in no significant contaminant 

26 concentrations in the effluent channel. The proposed facility will obtain additional groundwater 

27 for potable purposes from the Wilmington Site’s existing production wells. Water level data 

28 show these wells to be cross-gradient of the overall Wilmington Site, and they do not result in 

29 significant drawdown. Groundwater will also be needed as a source of process water. A small 

30 amount of increased drawdown is expected, without significant effect on flow directions, water 

31 quality, or availability for offsite users. Diesel tanks at the facility would have appropriate leak 

32 detection equipment. A groundwater monitoring plan would be developed after the facility is 

33 constructed. 

34 

35 Ecological Resources 

36 

37 Small to Moderate Impact. Construction activities that could impact ecological resources at the 

38 Wilmington Site include constructing the UF6 storage pads, constructing the operations building, 

39 and adding a fence around the proposed facility. Most construction activities would occur in 

40 areas that would have already been disturbed by preconstruction activities. Impacts on 

41 vegetation would occur primarily from vegetation clearing, habitat fragmentation, alteration of 

42 topography, changes in drainage patterns, and soil compaction. Remaining potential impacts 

43 on vegetation include decline or mortality of trees near the construction boundary, effects 

44 related to hydrologic changes, deposition of dust and other particulate matter, introduction of 

45 invasive plant species, and accidental releases of hazardous materials (e.g., fuel spills). 

46 

47 Wetlands could be impacted by alteration of surface water runoff patterns, soil compaction, or 

48 groundwater flow. No wetlands would be directly impacted by construction of the proposed 
 

xxxii 

1 facility, but three jurisdictional wetlands and one isolated wetland occur within the corridor for 

2 the revised entrance and roadway. It is probable that the isolated wetland would be directly 

3 impacted, resulting in a wetland loss. However, impacts on, or loss of, this wetland would not 

4 be significant, given the apparent low value of the wetland under State rating guidelines. 

5 Indirect impacts on wetlands could occur from increased stormwater runoff, decreased 

6 groundwater recharge, disconnected hydrologic conductivity, or changes in groundwater or 

7 surface water flow patterns. Impacts from increased or decreased runoff are expected to be 

8 negligible. 

9 

10 Except for the probable impact on wetlands, no environmentally sensitive areas would be 

11 directly impacted by construction. Only minor, localized indirect impacts on environmentally 

12 sensitive areas may occur from erosion and sedimentation or from changes in drainage 

13 patterns. 

14 

15 Impacts on wildlife from construction would include habitat disturbance, wildlife disturbance, and 

16 injury or mortality of wildlife. Habitats within the footprint disturbed by construction would be 

17 reduced or altered, and construction activities would result in habitat fragmentation. 

18 Construction would cause a loss of habitat, which could result in a long-term reduction in wildlife 

19 abundance and richness. Although habitats adjacent to the proposed facility site would mostly 

20 remain unaffected, wildlife might make less use of these areas due to disturbance (indirect 

21 habitat loss). Habitat disturbance, including roads, could facilitate the spread and introduction of 

22 invasive plant species. Wildlife habitat could be adversely affected if invasive vegetation 

23 became established in the disturbed areas and adjacent offsite habitats. If exposure of wildlife 

24 to fugitive dust was of sufficient magnitude and duration, the effects could be similar to those on 

25 humans. A more probable effect would be the dusting of plants, which could make forage less 

26 palatable. Construction activities could cause wildlife disturbance, including interference with 

27 behavioral activities. Wildlife could respond in various ways, including attraction, habituation, 

28 and avoidance. Principal sources of noise would include vehicle traffic and operation of 

29 machinery. Regular or periodic noise could cause adjacent areas to be less attractive to wildlife 

30 and result in a long-term reduction in use. Construction activities could result in the direct injury 

31 or death of certain wildlife species. Wildlife could also be exposed to accidental fuel spills or 

32 releases of other hazardous materials. 

33 

34 No aquatic habitats are located within the footprint of the areas that will be cleared for the 

35 proposed facility, and no significant adverse impacts on aquatic biota are expected from 

36 construction activities. 

37 

38 No impacts would be expected on any Federally listed threatened, endangered, or other special 

39 status species from construction activities. Similarly, no impacts would be expected on any 

40 State-listed species. 

41 

42 During operation, impacts on vegetation would include moving, hand-cutting, and chemical 

43 control of vegetation around the proposed facility, support facilities, utility corridors, and access 

44 road. No effects on vegetation would be expected from the cooling tower or air emissions, 

45 wastewaters, and solid wastes generated during operation. It is unlikely that radionuclide 

46 releases would have adverse effects on ecological resources. Facility operation would not 

47 encroach upon or have any other adverse effect on wetlands. Impervious surfaces generally 

48 result in increased runoff and reduced infiltration, but routing drainage to the stormwater 
 

xxxiii 

1 detention and retention basins would minimize the potential for wetland water-level fluctuations. 

2 No environmentally sensitive areas would be impacted by operations. Potential impacts on 

3 wildlife from operations would include ongoing habitat disturbance (i.e., reduction, alteration, 

4 and fragmentation of habitat), and wildlife injury or mortality. 

5 

6 No natural water bodies occur within the immediate area of the proposed facility. During 

7 operations, aquatic habitats and biota could be affected by continued erosion and sedimentation 

8 and exposure to contaminants. Increased liquid effluent discharges could increase turbidity and 

9 sedimentation until the stream channel adjusts. Wastewater would be treated to meet NPDES 

10 permit requirements, so aquatic biota would not be adversely impacted. The potential exists for 

11 toxic materials (e.g., fuel, lubricants, and herbicides) to be accidentally introduced into aquatic 

12 habitats, but an uncontained spill would probably affect only a limited area, and lubricants and 

13 fuel would not be expected to enter wetlands or waterways (due to soil infiltration and the 

14 distance from the main work area to drainages). Only trace levels of radiological contamination 

15 would be released to surface waters during operation, so adverse radiological impacts on 

16 aquatic biota would not be expected. 

17 

18 No adverse impacts on threatened, endangered, or other special status species would be 

19 expected from facility operations due to the lack of suitable habitats within the immediate project 

20 area. 

21 

22 Noise 

23 

24 Small to Moderate Impact. During construction, vehicular traffic around the proposed facility 

25 and along nearby traffic routes would generate intermittent noise, but the noise contribution from 

26 these sources would be limited to the immediate vicinity of the traffic routes and would be minor 

27 in comparison with the contribution from continuous sources used during construction. Noise 

28 levels from planned construction activities would be comparable to those from other 

29 construction sites of similar size. The dominant noise source for most construction equipment is 

30 the diesel engine without sufficient muffling. Major construction activities would include building 

31 erection and electrical and mechanical installation, and some activities would occur inside the 

32 structures. Typically, heavy equipment with lower noise levels than used during road 

33 construction would be employed. Traffic accessing the site would increase but would largely 

34 consist of smaller passenger vehicles, vans, and pickup trucks. Potential noise impacts on the 

35 nearest subdivision would be moderate but temporary in nature when road construction (which 

36 is a preconstruction activity and therefore not a part of the proposed action) occurs in the 

37 proximity of the site boundary. Potential noise impacts during subsequent additional 

38 preconstruction activities would be SMALL. 

39 

40 During facility operation, noise sources would be primarily enclosed within buildings. Various 

41 outbuildings are planned with exterior equipment, such as pumps, heat pumps, transformers, 

42 and cooling towers. Other noise sources would include vehicular traffic on the proposed access 

43 road, as well as hauling vehicles around the proposed facility. Noise levels at the fenceline 

44 receptor closest to the Wooden Shoe residential subdivision are estimated to be below the day 

45 and night equivalent sound level for the local noise ordinance and the U.S. Environmental 

46 Protection Agency (EPA) noise guideline. 

47 
 

xxxiv 

1 Transportation 

2 

3 Small to Moderate Impact. Construction involves the movement of personnel and equipment to 

4 and from the site, the delivery of materials and supplies, and the removal of construction debris 

5 and waste. The number and type of truck shipments will vary over the course of construction. 

6 Construction activities are estimated to add an average of approximately 35 trucks per day, with 

7 a small impact on local traffic. Prior to start-up, an average increase of up to 815 daily trips by 

8 construction personnel is anticipated, with the heaviest traffic occurring in the immediate vicinity 

9 of the site entrance. Impacts on the local site vicinity could be SMALL to MODERATE; regional 

10 impacts are expected to be SMALL. Impacts would be reduced if shift changes did not coincide 

11 with local peak road usage times. 

12 

13 Facility operations would overlap with the construction period for five years, during which time 

14 vehicular traffic from commuting operations personnel will add to increased local traffic from 

15 construction workers and shipments. The remaining years of operation will involve vehicular 

16 traffic from operations personnel, occasional visitors, incoming truck shipments for materials 

17 and supplies, and outgoing shipments of product materials and wastes. An average of 

18 approximately six additional heavy haul truck shipments per day to and from the Wilmington Site 

19 would occur during operations. The average number of workers (construction and operations 

20 personnel) on a daily basis during start-up and construction completion is anticipated to be 743, 

21 with about 350 permanent operations personnel employed over the remainder of the operational 

22 period. The average number of additional daily vehicle trips from facility activities will increase 

23 by about 1560 at the Wilmington Site during joint construction and operations activities. Once 

24 construction is complete, the average number of daily trips associated with operations 

25 personnel is estimated to be approximately 740. The range of additional daily vehicle trips from 

26 facility activities (740 to 1560) would have a MODERATE impact on the local road network. The 

27 impact on regional traffic flow is expected to be SMALL. 

28 

29 Operations of the proposed facility will require the shipment (by truck) of various radioactive 

30 materials to and from the facility, with multiple origins or destinations. Vehicle-related risks 

31 result from moving from one location to another (independent of cargo characteristics), while 

32 cargo-related risk refers to that attributable to the cargo being shipped. In the case of the 

33 uranium, cargo-related risks include exposure to ionizing radiation during normal transportation 

34 and accident conditions, as well as chemical hazards during accident conditions. Less than one 

35 latent cancer fatality is anticipated for the public and transportation crews from all shipments on 

36 an annual basis. No latent fatalities from vehicle emissions are anticipated on an annual basis, 

37 so impacts on the public from vehicle emissions would be SMALL. 

38 

39 Annual transportation accident impacts from the proposed action are anticipated to be SMALL. 

40 Chemical impacts would be negligible, as past analyses of depleted UF6 shipments have shown 

41 the estimates of irreversible adverse effects to be approximately 1 to 3 orders of magnitude 

42 lower than the estimates of public latent cancer fatalities from radiological accident exposure. 

43 No fatalities are expected from accidents (direct physical trauma) on an annual basis. 

44 

45 Public and Occupational Health 

46 

47 Small Impact. Impacts on occupational safety from construction would be SMALL. 

48 Occupational exposures during construction would be minor and minimized using work 
 

xxxv 

1 practices and personal protective equipment. Impacts on air quality during construction would 

2 be SMALL. Construction activities are not expected to cause any exceedances of ambient air 

3 quality criteria, with the possible exception of short-term criteria for particulate matter from 

4 fugitive dust. 

5 

6 Radiological impacts during construction would be accrued primarily to construction workers. 

7 Offsite exposures would not be expected. Construction activities would not generate 

8 radiological contamination but could disturb areas previously contaminated by past and current 

9 operations at the Wilmington site. Construction workers could also be exposed to emissions 

10 from the proposed facility during the overlap of construction and early operation. The maximum 

11 possible dose would be a small fraction of background radiation exposure and less than the 

12 10 CFR 20.1301(a)(1) limit of 1 millisievert per year. Impacts on construction workers from 

13 radiological exposure would be SMALL. Dose to the offsite public would be significantly less, as 

14 they have no potential for measurable exposure from existing site contamination. Impacts on 

15 the offsite public from construction would be SMALL. 

16 

17 A total of 450 total recordable incidents, 247 lost workday incidents, and less than one fatal 

18 injury are projected for 38 years of facility operation. Impacts on occupational health and safety 

19 during facility operation would be SMALL. 

20 

21 The greatest potential for occupational exposure in the main process building would be from 

22 connecting and disconnecting UF6 cylinders. Airborne concentrations of HF and uranyl fluoride 

23 inside facilities are expected to be insignificant, and workers would use ventilation equipment to 

24 minimize exposures. Concentrations near the release point could be as high as 10 percent of 

25 the Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit and 

26 would be limited by ventilation equipment. Impacts associated with routine occupational 

27 exposures to HF and UF6 in the workplace would be SMALL. Large volumes of UF6 would be 

28 present as feed and product material, but there would be no routine exposures to solid or liquid 

29 UF6. Exposure to industrial chemicals would be limited by minimizing airborne releases and use 

30 of protective equipment. Non-radiological impacts on workers from operations would be 

31 SMALL. 

32 

33 Lasers would normally be operated within enclosures, equipped with interlocks to prevent 

34 inadvertent worker exposure. With laser protections in place, impacts of lasers on worker health 

35 would be SMALL. 

36 

37 Public health impacts associated with non-radiological liquid effluent releases would be SMALL. 

38 Potential long-term, low-level HF and uranium exposure to the public would be the primary 

39 offsite chemical exposures of concern. However, public health impacts from such exposures 

40 would be SMALL. Only minor quantities of UF6 or HF would escape the facility ventilation 

41 system, and the quantity of HF passing through the emissions control devices would be below 

42 levels established in the facility air permit and protective of public health. The estimated HF and 

43 uranium concentrations at onsite exposure locations are orders of magnitude below safe levels 

44 established by OSHA. UF6 and HF levels at the site boundary and the location of the nearest 

45 resident would be lower than onsite levels. HF concentrations at all exposure locations are far 

46 below the most stringent state or Federal ambient air quality standards for the general public. 

47 No criteria air pollutants would be produced by the enrichment process. 

48 
 

xxxvi 

1 Facility operation could result in radiation exposure to the public via uranium releases or direct 

2 external radiation exposure. UF6 gas released in the main process building would pass through 

3 a ventilation system to minimize external release. Liquid effluents would be treated and 

4 sampled to limit releases. Direct exposure to the public could occur from onsite uranium and 

5 transportation both onsite and offsite. Direct radiation and skyshine from airborne releases 

6 would be undetectable at offsite areas. The main process building would release small amounts 

7 of airborne uranium during operation, but impacts on members of the public from air emissions 

8 would be SMALL. The NRC public release limits for uranium in air and liquid effluents (i.e., 

9 10 CFR Part 20 Appendix B limits) would be met. 

10 

11 Radioactive materials at the proposed facility would present the possibility for onsite members 

12 of the public to receive a direct radiation dose. Only depleted uranium would be continuously 

13 present in sufficient quantity to represent a potential source of direct radiation dose. 

14 Measurements from existing sources at the Wilmington Site were used to estimate the public 

15 dose from direct radiation. Site dosimetry indicated no readings above background at the site 

16 boundary. Because of cylinder shielding and the distance to receptors, stored cylinders are 

17 expected to have only a minor effect on the exposure rate at the site boundary. Therefore, the 

18 impact from direct exposure to the public is expected to be SMALL. 

19 

20 The proposed GLE Facility would generate process and sanitary liquid effluent streams. Liquid 

21 radioactive wastewater would be collected and sampled before routing to a liquid effluent 

22 treatment system. Treated effluent would be discharged to the existing final process lagoon 

23 facility, and cooling tower blowdown would be sent directly to the final process lagoon facility. 

24 Water from the lagoon facility would be discharged through a permitted outfall to the site effluent 

25 channel. Sanitary wastewater would be treated in the existing sanitary wastewater treatment 

26 facility, and treated effluent would replace cooling tower blowdown. Stormwater runoff would 

27 drain into a stormwater wet detention basin before being discharged. A separate holding pond 

28 would collect stormwater runoff from the UF6 storage pads, where the runoff would be monitored 

29 before discharge to the wet detention basin. Discharges from all liquid effluent streams would 

30 be released into the Wilmington Site effluent channel and flow to the Northeast Cape Fear River 

31 through Unnamed Tributary #1. 

32 

33 There are no public water intakes on the Northeast Cape Fear River downstream of the 

34 discharge point, so the only exposure pathways of concern are fish ingestion and those relating 

35 to recreational water use. The maximum dose that a member of the public could receive from 

36 liquid effluent releases would occur just south of the Wilmington Site boundary. Calculated 

37 doses to a maximally exposed individual (MEI) and the surrounding population from liquid 

38 effluent releases are well below the 10 CFR 20.1301(a)(1) limit of 1 millisievert per year. 

39 Impacts on members of the public from liquid effluent releases from the proposed GLE Facility 

40 would be SMALL. 

41 

42 Impacts of normal operations on public health and occupational exposure would be SMALL. 

43 

44 Waste Management 

45 

46 Small Impact. Solid nonhazardous wastes generated during construction would be similar to 

47 wastes from other industrial construction sites and transported offsite to an approved local 

48 landfill. Construction activities would generate less than two percent of the waste that the New 
 

xxxvii 

1 Hanover County Landfill receives annually from all other sources. Small quantities of organic 

2 solvent-based residuals could be used and may require management as hazardous waste. 

3 Hazardous wastes from construction would be packaged and shipped offsite to licensed 

4 facilities. Impacts from construction-generated hazardous and nonhazardous waste would be 

5 SMALL. 

6 

7 Facility operations would result in the generation of wastewaters that would be treated onsite 

8 before discharge and solid wastes that would be treated (onsite or offsite) and shipped for 

9 disposal offsite. Sanitary wastewater would be collected by a sewer system connected to the 

10 existing Wilmington Site sanitary wastewater treatment facility, increasing the load on the 

11 existing system by about one-third. Treated sanitary wastewater effluent could be used as 

12 makeup water in onsite cooling towers. Should discharges to surface waters be necessary, the 

13 existing NPDES discharge permit would be adequate to cover the additional effluent volume. 

14 Impacts from sanitary wastewater would be SMALL. Cooling tower blowdown would be sent to 

15 the Wilmington Site’s final process lagoons, and impacts from cooling tower blowdown would be 

16 SMALL. Radioactive process wastewater from facility operations would be collected and 

17 treated to remove uranium, other metals, and fluoride. The treated effluent would be discharged 

18 to the process wastewater aeration basin and final process lagoon facility. Impacts from 

19 process wastewater would be SMALL. Impacts from radiological exposure to depleted UF6 in 

20 the cylinder storage pad would be SMALL, and impacts from the conversion of depleted UF6

21 generated by the proposed GLE Facility would be SMALL. 

22 

23 Socioeconomics 

24 

25 Small Impact. Socioeconomic impacts are calculated for the region in which the majority 

26 workers at the proposed GLE Facility are expected to live and spend their wages and salaries. 

27 This region of influence (ROI) covers three counties in North Carolina – Brunswick County, New 

28 Hanover County, and Pender County. These three counties cover an area that extends up to 

29 approximately 80 kilometers (50 miles) from the site. Construction activities in the peak year 

30 (2012) would create 680 direct jobs at the facility site and an additional 3131 indirect jobs in the 

31 ROI. In 2012, construction would produce $139.8 million in income in the ROI, $1.7 million in 

32 direct State income taxes, and $1.2 million in direct State sales taxes. In-migration of workers 

33 and their families from outside the ROI would be likely. Although in-migration may potentially 

34 impact local housing markets, the relatively small number of in-migrants (between 299 and 

35 598 persons) and the availability of temporary accommodations would limit the impact on the 

36 number of vacant rental housing units. In-migration would affect local–community educational 

37 and medical services employment to maintain existing levels of service. Approximately one 

38 additional police officer and one additional firefighter would be required in the peak construction 

39 year. Between 84 and 169 additional school-age children would be expected in the ROI in 

40 2012, requiring approximately one additional teacher to maintain existing student-teacher ratios. 

41 

42 Facility start-up activities would create 200 direct jobs and an additional 218 indirect jobs in the 

43 ROI. In 2013, start-up would produce $28.0 million in income in the ROI, $1.3 million in direct 

44 State income taxes, and $0.92 million in direct State sales taxes. In-migration of workers and 

45 their families from outside the ROI would be likely. Although in-migration may potentially impact 

46 local housing markets, the relatively small number of in-migrants (92 to 120) and the availability 

47 of temporary accommodations would limit the impact of start-up on the number of vacant rental 

48 housing units. In-migration would affect local–community educational and medical services 
 

xxxviii 

1 employment to maintain existing levels of service. Less than one additional police officer and 

2 less than one additional firefighter would be required in the start-up year. Between 26 and 

3 40 additional school-age children would be expected in the ROI in 2013, requiring one additional 

4 teacher to maintain existing student-teacher ratios. 

5 

6 Facility operations in 2017 would create 350 direct jobs and an additional 382 indirect jobs in the 

7 ROI. In 2017, operations would produce $51.5 million in income in the ROI, $2.3 million in 

8 direct State income taxes, and $1.7 million in direct State sales taxes. Corporate income taxes 

9 would also be collected by the State during the operating period, totaling $49.2 million annually. 

10 In-migration of workers and their families from outside the ROI would be likely. Although 

11 in-migration may potentially impact local housing markets, the relatively small number of 

12 in-migrants (161 to 210) and the availability of temporary accommodations would limit the 

13 impact of facility operation on the number of vacant owner-occupied housing units. In-migration 

14 would affect local-community educational and medical services employment to maintain existing 

15 levels of service. Less than one additional police officer and less than one additional firefighter 

16 would be required in the peak operations year. Between 46 and 70 additional school-age 

17 children would be expected in the ROI in 2017, meaning less than one additional teacher would 

18 be required to maintain existing student-teacher ratios. 

19 

20 Environmental Justice 

21 

22 Small Impact. Although the NRC staff has concluded that potential impacts could be SMALL to 

23 MODERATE in a number of resource areas during construction and operation of the proposed 

24 facility, the impacts on each resource area would not appear to be disproportionately high and 

25 adverse for minority or low-income populations. 

26 

27 The majority of environmental impacts associated with construction and operation of the 

28 proposed facility are SMALL to MODERATE and would generally be mitigated. Any remaining 

29 environmental impacts would affect primarily residents in the immediate vicinity. The 

30 neighborhood immediately surrounding the proposed facility site includes a mix of minority and 

31 nonminority residents, as well as a mix of low-income and more affluent residents. Because 

32 impacts on the general population are generally SMALL to MODERATE, and because the 

33 greatest impact is expected to occur in the immediate vicinity (and in an area with a mix of 

34 ethnicities and income levels), the various phases of facility development would not be expected 

35 to result in disproportionately high or adverse impacts on low-income or minority residents, and 

36 would not, therefore, produce any environmental justice concerns. 

37 

38 Even when environmental impacts are anticipated to be SMALL, the behaviors of some 

39 population groups, such as higher participation in outdoor recreation, home gardening, or 

40 subsistence fishing, may lead to disproportionate exposure. One Census block group with a 

41 high percentage of low-income and minority residents is located downstream of the proposed 

42 facility on the Northeast Cape Fear River. If radioactive contaminants were released, these 

43 residents could face increased risk of exposure. However, air and liquid releases of total 

44 uranium and UF6 are projected to be extremely low, and indirect exposure through fish 

45 consumption would be even lower. 

46 
 

xxxix 

1 Accidents 

2 

3 Small Impact. The consequence of a criticality accident would be high for a worker in close 

4 proximity (less than 15 feet). Worker health consequences are Low to Intermediate from four 

5 scenarios involving the release of UF6. Worker health consequences are Low to High from four 

6 scenarios involving HF exposure. Worker health consequences are Low to Intermediate from 

7 four scenarios involving uranium chemical exposure. Radiological consequences to a 

8 maximally exposed individual at the Controlled Area Boundary are Low for the criticality 

9 accident, Low for all four UF6 release scenarios, Low to High for the four HF exposure 

10 scenarios, and Low to Intermediate for the four scenarios involving uranium chemical exposure. 

11 Risk to the offsite public in the direction of highest exposure is estimated to be less than one 

12 lifetime cancer fatality for all accident scenarios. Plant design, passive and active engineered 

13 controls, and administrative controls would reduce the likelihood of accidents. Therefore, 

14 impacts from accidents are expected to be SMALL. 

15 

16 POTENTIAL ENVIRONMENTAL IMPACTS OF THE NO-ACTION ALTERNATIVE 

17 

18 This draft EIS also considers the potential environmental impacts of the no-action alternative, 

19 which are summarized below. As described in Chapter 4, the anticipated environmental 

20 impacts from the no-action alternative are SMALL. It is assumed that preconstruction activities 

21 take place under the no-action alternative. 

22 

23 Should the nation’s need for enriched uranium continue to increase and necessitate the 

24 construction and operation of another domestic enrichment facility at an alternate location, 

25 impacts could occur for each resource area and could range from SMALL to LARGE. The 

26 nature and scale of these impacts could be similar to those of the proposed action, but would 

27 depend on several facility- and site-specific factors. Consequently, these impacts would be 

28 addressed by the NRC at that time. 

29 

30 Should uranium enrichment activities not be undertaken at alternative locations or through 

31 expansion of planned and existing enrichment facilities, the national enrichment capacity would 

32 be diminished. This could lead to curtailment of planned new or expanded nuclear power 

33 plants, necessitating the generation of electricity to meet current and future demands through 

34 the application of other energy technologies featuring a different set of impacts. 

35 

36 Land Use 

37 

38 Small Impact. Under the no-action alternative, other uses of the land would not be precluded. 

39 

40 Historical and Cultural Resources 

41 

42 Small Impact. Under the no-action alternative, additional land disturbance at the Wilmington 

43 Site may or may not occur, depending on future plans for the project site. Procedures to 

44 address unexpected discoveries that could occur during normal operations are currently in 

45 place. 

46 
 

xl 

1 Visual and Scenic Resources 

2 

3 Small Impact. Under the no-action alternative, additional ground-disturbing activities (clearing) 

4 may or may not occur. Should the site not be developed, the vegetation screen that surrounds 

5 the proposed facility site would be intact and no additional visual disturbance at the Wilmington 

6 Site would be introduced. 

7 

8 Air Quality 

9 

10 Small Impact. Under the no-action alternative, existing air emission sources at the Wilmington 

11 Site would continue to operate. Point source emissions from current operations are negligible 

12 compared to the annual total emissions in New Hanover County. 

13 

14 Geology and Soils 

15 

16 Small Impact. Under the no-action alternative, additional ground-disturbing activities may or 

17 may not occur, depending on future plans for the project site. 

18 

19 Surface Water Resources 

20 

21 Small Impact. Under the no-action alternative, no changes to surface water quality would be 

22 expected. 

23 

24 Groundwater Resources 

25 

26 Small Impact. Under the no-action alternative, additional water use may or may not occur, 

27 depending on future plans for the project site. Groundwater quality would not be reduced at the 

28 proposed facility site, but would gradually improve. No adverse changes in groundwater quality 

29 would be expected. 

30 

31 Ecological Resources 

32 

33 Small Impact. Most impacts on ecological resources would occur prior to the no-action 

34 alternative (i.e., during preconstruction). Under the no-action alternative, impacts on wetlands, 

35 environmentally sensitive areas, and aquatic biota would be SMALL. Impacts on Federally 

36 threatened and endangered species would be SMALL, and impacts on the Federal species of 

37 concern or State-listed species that occur within New Hanover County would be SMALL (i.e., no 

38 adverse impacts on these species would result from the no-action alternative). 

39 

40 Noise 

41 

42 Small Impact. Noise associated with construction would not occur and additional noise from 

43 operations at the existing Wilmington Site would not likely change, depending on future plans for 

44 the project site. 

45 
 

xli 

1 Transportation 

2 

3 Small Impact. Under the no-action alternative, increased construction and operations traffic 

4 would not occur and there would not likely be any additional local transportation impacts at the 

5 Wilmington Site, depending on future plans for the project site. There would be no additional 

6 traffic entering and leaving the Wilmington Site, and additional national impacts from the 

7 transportation of radioactive materials to and from the Wilmington Site would not occur in the 

8 short term. 

9 

10 

11 Public and Occupational Health 

12 

13 Small Impact. Under the no-action alternative, impacts on construction workers would not 

14 occur. Exposure to the public outside the Wilmington Site boundary would remain unchanged, 

15 depending on future plans for the project site. 

16 

17 Waste Management 

18 

19 Small Impact. Under the no-action alternative, there may or may not be any additional waste 

20 management impacts at the Wilmington Site, depending on future plans for the project site. 

21 There would be no additional waste generated at the Wilmington Site beyond that generated by 

22 existing activities. 

23 

24 Socioeconomics 

25 

26 Small Impact. Under the no-action alternative, any positive or adverse consequences of the 

27 proposed action would not occur. Population and employment in the ROI would be expected to 

28 grow in accordance with current projections. Activities completed prior to the no-action 

29 alternative (i.e., preconstruction activities) would not expected to have a noticeable effect on 

30 these trends or on county services, and the no-action alternative would not directly result in 

31 changes to current county services or growth projections. 

32 

33 Environmental Justice 

34 

35 Small Impact. The no-action alternative would not be expected to cause any significant and 

36 adverse impacts. 

37 

38 Accidents 

39 

40 Small Impact. Under the no-action alternative, potential accidents and accident consequences 

41 from construction and operation of the proposed GLE Facility would not occur. 

42 

43 COSTS AND BENEFITS OF THE PROPOSED ACTION 

44 

45 While there are national energy security and fiscal benefits associated with the proposed action, 

46 and local socioeconomic benefits in the ROI in which the proposed GLE Facility would be 

47 located, there are also direct costs associated with the construction and operation phases of the 

48 proposed action, as well as impacts associated with the proposed action on various resource 
 

xlii 

1 areas. However, these impacts are estimated to be small in magnitude and small in comparison 

2 to the local and national benefits of the proposed action. In addition, many of the impacts on 

3 environmental resources associated with the proposed action relate to preconstruction activities 

4 at the proposed site, and would also occur under the no-action alternative. The principal 

5 socioeconomic impact or benefit of the proposed GLE Facility would be an increase in 

6 employment and income in the ROI. Although the majority of the costs, and most of the 

7 socioeconomic impacts, of the various phases of GLE Facility development would occur in the 

8 ROI, there would be economic, fiscal, and, in particular, energy security benefits, which would 

9 occur at both the local and national levels. 

10 

11 Employment created in the ROI in the peak construction year (2012) is estimated at 3811 direct 

12 and indirect jobs, and State income tax revenues would be $1.7 million per year during 

13 construction. During the GLE operations phase (2017 to 2051), 732 direct and indirect jobs 

14 would be created. During this period, the State would benefit from $2.3 million in income taxes 

15 and $49.2 million annually in property taxes. Although it can be assumed that some portion of 

16 State sales and income taxes paid would be returned to the ROI under revenue-sharing 

17 arrangements between each county and State government, the exact amount that would be 

18 received by each county cannot be determined. Although there are economic and fiscal 

19 benefits associated with the proposed action in the ROI, these beneficial impacts are expected 

20 to be SMALL. 

21 

22 The direct costs associated with the proposed action may be categorized by the following life23 cycle stages: construction, facility operation, depleted uranium disposal, and decommissioning. 

24 In addition to the costs of the proposed action, costs would be incurred for preconstruction 

25 activities under both the proposed action and no-action alternatives. In addition to monetary 

26 costs, the proposed action would result in impacts on various resource areas, which are 

27 summarized above. For all resource areas, the impact of the proposed action is estimated to be 

28 SMALL or SMALL to MODERATE. 

29 

30 The proposed action would result in the annual production, in peak years, of six million SWU of 

31 enriched uranium, which would augment the supply of enriched uranium and, along with other 

32 planned new enrichment facilities, would meet the national energy security need for increased 

33 domestic supplies of enriched uranium. Thus, the proposed action would generate national and 

34 regional benefits and costs. The national benefit would be an increase in domestic supplies of 

35 enriched uranium that would assist the national energy security need. The regional benefits 

36 would be increased employment, economic activity, and tax revenues in the ROI. Costs 

37 associated with the proposed project are, for the most part, limited to the resource areas in the 

38 ROI. 

39 

40 COMPARISON OF ALTERNATIVES 

41 

42 Under the no-action alternative, the proposed GLE Facility would not be constructed, operated, 

43 and decommissioned near Wilmington, North Carolina. However, preconstruction activities, 

44 such as land clearing, grading, and construction of support structures, would occur on the 

45 proposed site even under the no-action alternative. The Paducah Gaseous Diffusion Plant in 

46 Paducah, Kentucky, and the downblending of highly enriched uranium under the “Megatons to 

47 Megawatts” program would remain the sole sources of domestically generated low-enriched 

48 uranium for U.S. commercial nuclear power plants. The NEF and ACP would also be expected 
 

xliii 

1 to provide enrichment services in the future. The license application for an additional proposed 

2 enrichment facility (the EREF) is also currently under review by the NRC. Foreign enrichment 

3 sources would be expected to continue to supply more than 85-90 percent of U.S. nuclear 

4 power plants’ demand until new domestic enrichment facilities are constructed and operated. 

5 

6 The no-action alternative would have SMALL local impacts on current land use, historic and 

7 cultural resources, visual and scenic resources, air quality, geology and soils, water resources, 

8 ecological resources, socioeconomics, environmental justice, noise, transportation, public and 

9 occupational health, and waste management. The costs and benefits of constructing and 

10 operating the proposed GLE Facility would not occur. Additional domestic enrichment facilities 

11 could be constructed in the future with impacts expected to be SMALL to LARGE, depending on 

12 the site-specific conditions. 

13 

14 In comparison to the no-action alternative, the proposed action would also have SMALL impacts 

15 on land use, visual and scenic resources, geology and soils, water resources, socioeconomics, 

16 environmental justice, noise, public and occupational health, and waste management. The 

17 proposed action would have SMALL to MODERATE impacts on historical and cultural 

18 resources, air quality, ecological resources, and transportation. The proposed action would 

19 have positive impacts in the ROI on employment, income, State tax revenues, and Federal 

20 income tax revenues. Impacts from the most serious accidents that might occur are expected to 

21 be SMALL. 

22 

23 CUMULATIVE IMPACTS 

24 

25 This draft EIS also considers cumulative impacts that could result from the proposed action 

26 when added to other past, present, and reasonably foreseeable future actions (Federal, non27 Federal, or private). Identified activities include planned facilities and new processes at the 

28 Wilmington Site, as well as offsite industrial development. Impacts from preconstruction 

29 activities for the proposed GLE Facility are addressed as cumulative impacts in this draft EIS, as 

30 these actions are not part of the proposed action. In general, the anticipated cumulative 

31 impacts from the proposed action are SMALL or SMALL to MODERATE. With the exception of 

32 socioeconomic impacts (i.e., local job creation), cumulative impacts associated with the no33 action alternative would generally be less than those for the proposed action. 

34 

35 SUMMARY OF ENVIRONMENTAL CONSEQUENCES 

36 

37 Preconstruction activities and the proposed action would result in unavoidable adverse impacts 

38 on the environment. These impacts would generally be small, and would, in most cases, be 

39 mitigated. The disturbed area would be cleared of vegetation and would lead to the 

40 displacement of some local wildlife populations. There would be temporary impacts from the 

41 construction of new facilities, including increased fugitive dust, increased potential for soil 

42 erosion and stormwater pollution, and increased vehicle traffic and emissions. Water 

43 consumption from onsite wells during the proposed action would be relatively small and the risk 

44 for significant adverse impacts on neighboring residential wells or public supply wells is 

45 expected to be small. During operations, workers and members of the public could be exposed 

46 to radiation and chemicals. 

47 
 

xliv 

1 This draft EIS defines short-term uses as generally affecting the present quality of life for the 

2 public (i.e., the 40-year license period for the proposed GLE Facility); and long-term productivity 

3 as affecting the quality of life for future generations on the basis of environmental sustainability. 

4 The proposed action would necessitate short-term commitments of resources and would 

5 permanently commit certain other resources (such as energy and water). The short-term use of 

6 resources would result in potential long-term socioeconomic benefits to the local area and the 

7 region. 

8 

9 Workers, the public, and the environment would be exposed to increased amounts of hazardous 

10 and radioactive materials over the short term from operations of the proposed GLE Facility. 

11 Construction and operation would require a long-term commitment of terrestrial resources, such 

12 as land, water, and energy. Short-term impacts would be minimized by the application of 

13 appropriate mitigation measures. Upon the closure of the proposed GLE Facility, GLE would 

14 decontaminate and decommission the buildings and equipment and restore them for 

15 unrestricted use. Continued employment, expenditures, and tax revenues generated during the 

16 proposed action would directly benefit the local, regional, and State economies. 

17 

18 Irreversible commitment of resources refers to resources that are destroyed and cannot be 

19 restored, whereas an irretrievable commitment of resources refers to material resources that 

20 once used cannot be recycled or restored for other uses by practical means. The proposed 

21 action would include the commitment of land, water, energy, raw materials, and other natural 

22 and human-generated resources. Following decommissioning, the land occupied by the 

23 proposed facility would likely remain industrial beyond license termination. Water required 

24 during preconstruction and the proposed action would be obtained from existing wells at the 

25 Wilmington Site and would be replenished through natural mechanisms. Wastewaters would be 

26 treated to meet applicable standards and released to local receiving surface waters. Energy 

27 used in the form of electricity, natural gas, and diesel fuel would be supplied through existing 

28 systems in the Wilmington area. The specific types of construction materials and the quantities 

29 of energy and materials used cannot be determined until final facility design is completed, but it 

30 is not expected that these quantities would strain the availability of these resources. 

31 

32 Even though the land used to construct the proposed GLE Facility would be returned to other 

33 productive uses after the facility is decommissioned, there would be some irreversible 

34 commitment of land at offsite locations used to dispose of solid wastes generated by the facility. 

35 In addition, wastes generated during the conversion of depleted UF6 produced by the facility 

36 and the depleted uranium oxide conversion product from the conversion of depleted UF6 would 

37 be disposed at an offsite location. Land used for disposal of these materials would represent an 

38 irreversible commitment of land. No solid wastes or depleted uranium oxide conversion product 

39 originating from the proposed GLE Facility would be disposed of at the Wilmington Site. When 

40 the facility is decommissioned, some building materials would be recycled and reused. Other 

41 materials would be disposed of in a licensed and approved offsite location, and the amount of 

42 land used to dispose of these materials would be an irretrievable land resource. 

43 

44 During operation of the proposed GLE Facility, natural UF6 would be used as feed material, 

45 requiring the mining of uranium and several other operational steps in the uranium fuel cycle. 

46 This use of uranium would be an irretrievable resource commitment. 

47 
 

xlv 

1 ACRONYMS AND ABBREVIATIONS 

2 

3 AADT annual average daily traffic 

4 AAL Acceptable Ambient Level 

5 ACHP Advisory Council on Historic Preservation 

6 ACP American Centrifuge Plant 

7 ADAMS Agencywide Documents Access and Management System 

8 ADT average daily vehicle trips 

9 AE/SCO Aircraft Engines/Services Components Operation 

10 AEA Atomic Energy Act 

11 AEGL Acute Exposure Guideline Level 

12 AES AREVA Enrichment Services, LLC 

13 ALARA As Low As Reasonably Achievable 

14 AMA American Medical Association 

15 ANSI American National Standards Institute 

16 AQRV air quality-related value 

17 ASA Acoustical Society of America 

18 ATC II Advanced Technology Center 

19 ATSDR Agency for Toxic Substances and Disease Registry 

20 AVLIS atomic vapor laser isotope separation 

21 

22 BLM U.S. Bureau of Land Management 

23 BLS Bureau of Labor Statistics 

24 BMP best management practice 

25 BOD biochemical oxygen demand 

26 

27 C Celsius 

28 CAA Clean Air Act 

29 CAB Controlled Area Boundary 

30 CAL/EPA California Office of Environmental Health Hazard Assessment 

31 CAMA Coastal Area Management Act 

32 CaOH lime 

33 CAS Chemical Abstracts Service 

34 CAST Horticultural Crops Research Station (Castle Hayne, NC) 

35 CBA cost-benefit analysis 

36 cDCE cis-1,2 dichloroethylene 

37 CDC Centers for Disease Control and Prevention 

38 CaF2 calcium fluoride 

39 CEDE committed effective dose equivalent 

40 CEQ Council on Environmental Quality 

41 CFC chlorofluorocarbon 

42 CFR U.S. Code of Federal Regulations 

43 CH4 methane 

44 Ci Curie 

45 CO carbon monoxide 

46 CO2 carbon dioxide 

47 CO2e carbon dioxide equivalent 

48 CPC Center for Plant Conservation 
 

xlvi 

1 ACRONYMS AND ABBREVIATIONS (Cont.) 

2 

3 CSC Coastal Services Center 

4 CWA Clean Water Act 

5 

6 D&D decontamination and decommissioning 

7 dB decibel 

8 dBA A-weighted decibel 

9 DCE dichloroethylene 

10 DCF dose conversion factor 

11 DCP dry conversion process 

12 DDE deep dose equivalent 

13 DFP decommissioning funding plan 

14 DMT Dundalk Marine Terminal 

15 DNA deoxyribonucleic acid 

16 DNFSB Defense Nuclear Facilities Safety Board 

17 DNL day-night average noise level 

18 DOE U.S. Department of Energy 

19 DOI U.S. Department of Interior 

20 DOL U.S. Department of Labor 

21 DOT U.S. Department of Transportation 

22 DU depleted uranium 

23 DUF4 depleted uranium tetrafluoride 

24 DUF6 depleted uranium hexafluoride 

25 

26 EA environmental assessment 

27 EAC Early Action Compact 

28 EF Enhanced Fujita 

29 EHS Environmental, Health, and Safety 

30 EIA Energy Information Administration 

31 EIS environmental impact statement 

32 EMF electromagnetic field 

33 EPA U.S. Environmental Protection Agency 

34 ER Environmental Report 

35 EREF Eagle Rock Enrichment Facility 

36 ESA Endangered Species Act 

37 ESI Environmental Services, Inc. 

38 

39 F Fahrenheit; Fujita 

40 FAA Federal Aviation Administration 

41 FCO Fuel Components Operation 

42 FBI Federal Bureau of Investigation 

43 FEMA Federal Emergency Management Agency 

44 FLM Federal Land Manager 

45 FMO/FMOX Fuel Manufacturing Operation 

46 FPLTF Final Process Lagoon Treatment Facility 

47 FR Federal Register 

48 ft foot/feet 
 

xlvii 

1 ACRONYMS AND ABBREVIATIONS (Cont.) 

2 

3 FTE full-time equivalent 

4 FWS U.S. Fish and Wildlife Service 

5 

6 GDP Gaseous Diffusion Plant 

7 GE General Electric 

8 GEH General Electric-Hitachi 

9 GHG greenhouse gas 

10 GLE GE-Hitachi Global Laser Enrichment LLC 

11 GNEP Global Nuclear Energy Partnership 

12 GNF-A Global Nuclear Fuels-Americas 

13 gpd gallons per day 

14 GWh gigawatt-hour 

15 GWP global warming potential 

16 

17 H2O water vapor 

18 HAP hazardous air pollutant 

19 HDDV heavy-duty diesel vehicle 

20 HEGA high-efficiency gas absorption 

21 HEPA high-efficiency particulate air 

22 HEU highly enriched uranium 

23 HF hydrogen fluoride or hydrofluoric acid 

24 HFC hydrofluorocarbon 

25 HFC-23 trifluoromethane 

26 HMTA Hazardous Materials Transportation Act 

27 HNO3 nitric acid 

28 HVAC heating, ventilation, and air conditioning 

29 HUD U.S. Department of Housing and Urban Development 

30 Hz hertz 

31 

32 I Interstate 

33 ICRP International Commission of Radiological Protection 

34 IDLH Immediately Dangerous to Life and Health 

35 IMPLAN Impact Analysis for Planning 

36 in. inch(es) 

37 IROF item relied upon for safety 

38 ISA integrated safety analysis 

39 ITE Institute of Transportation Engineers 

40 

41 kHz kilohertz 

42 km kilometer 

43 

44 LCF latent cancer fatality 

45 LDGV light-duty gasoline vehicle 

46 Ldn day-night maximum average sound level 

47 Leq equivalent sound level 

48 Leq(24) 24-hour equivalent sound level 
 

xlviii 

1 ACRONYMS AND ABBREVIATIONS (Cont.) 

2 

3 LES Louisiana Energy Services, LLC 

4 LEU low-enriched uranium 

5 LLRW low-level radioactive waste 

6 lpd liters per day 

7 LSA low specific activity 

8 

9 m meter 

10 MDC minimum detectable concentration 

11 MEI maximally exposed individual 

12 mg milligram 

mg/m3 13 milligrams per cubic meter 

14 MLIS molecular laser isotope separation 

15 MMt million metric tons 

16 MNA monitored natural attenuation 

17 MOX mixed oxide fuel 

18 mph miles per hour 

19 mrem millirem 

20 m/s meters per second 

21 MSA Metropolitan Statistical Area 

22 MSL mean sea level 

23 mSv millisievert 

24 MSW municipal solid waste 

25 MT/yr metric tons per year 

26 MWe megawatt electric 

27 MWh megawatt-hour 

28 

29 N2O nitrous oxide 

30 NAAQS National Ambient Air Quality Standards 

31 NaOH sodium hydroxide 

32 NC North Carolina 

33 NCAC North Carolina Administrative Code 

34 NCDAQ North Carolina Division of Air Quality 

35 NCDC National Climatic Data Center 

36 NCDENR North Carolina Department of Environment and Natural Resources 

37 NCDEHNR North Carolina Department of Health, Environment, and Natural Resources 

38 NCDMF North Carolina Division of Marine Fisheries 

39 NCDOT North Carolina Department of Transportation 

40 NCDWQ North Carolina Division of Water Quality 

41 NCES National Center for Education Statistics 

42 NCGS North Carolina General Statutes

43 NCNHP North Carolina Natural Heritage Program 

44 NCOSBM North Carolina Office of State Budget and Management 

45 NCRP National Council on Radiation Protection and Measurements 

46 NCWRC North Carolina Wildlife Resources Commission 

47 NEF National Enrichment Facility 

48 NELAC National Environmental Laboratory Accreditation Conference 
 

xlix 

1 ACRONYMS AND ABBREVIATIONS (Cont.) 

2 

3 NEMA National Electric Manufacturers Association 

4 NEPA National Environmental Policy Act

5 NERC North American Reliability Corporation 

6 NESHAPs National Emission Standards for Hazardous Air Pollutants 

7 NHC National Hurricane Center 

8 NHPA National Institute for Occupational Safety 

9 NIOSH National Institute for Occupational Safety and Health 

10 NIST National Institute of Standards and Technology 

11 NLCD92 National Land Cover Data 1992 archives 

12 NMFS National Marine Fisheries Service 

13 NMSS Office of Nuclear Materials Safety and Safeguards 

14 NMTOC nonmethane total organic compound 

15 NMVOC nonmethane volatile organic compound 

16 NO2 nitrogen dioxide 

17 NOx nitrogen oxide, oxide of nitrogen 

18 NOAA National Oceanic and Atmospheric Administration 

19 NOI Notice of Intent 

20 NOV Notice of Violation 

21 NPCR National Program of Cancer Registries 

22 NPDES National Pollutant Discharge Elimination System 

23 NRC U.S. Nuclear Regulatory Commission 

24 NRCS U.S. Natural Resources Conservation Service 

25 NRHP National Register of Historic Places 

26 NSSL National Severe Storms Laboratory 

27 NWS National Weather Service 

28 

29 O3 ozone 

30 OSHA Occupational Safety and Health Administration 

31 OSTV onsite transfer vehicle 

32 

33 PAH polycyclic aromatic hydrocarbon 

34 Pb lead 

35 PFC perfluorocarbon 

36 PM particulate matter 

37 PM2.5 particulate matter equal to or smaller than 2.5 micrometers in diameter 

38 PM10 particulate matter equal to or smaller than 10 micrometers in diameter 

39 PMT Portsmouth Marine Terminal 

40 ppm parts per million 

41 PSD Prevention of Significant Deterioration 

42 PWR pressurized water reactor 

43 

44 RAI Request for Additional Information 

45 RCRA Resource Conservation and Recovery Act

46 rem roentgen equivalent man 

47 RLETS Radiological Liquid Waste Treatment System 

48 ROI region of influence 
 

l 

1 ACRONYMS AND ABBREVIATIONS (Cont.) 

2 

3 ROW right-of-way 

4 RPS North Carolina Radiation Protection Section 

5 RSL Regional Screening Level 

6 RTI Research Triangle Institute 

7 RVP Reid vapor pressure 

8 

9 SAAQS State Ambient Air Quality Standards 

10 SAM Social Accounting Matrix 

11 SCONC State Climate Office of North Carolina 

12 SER Safety Evaluation Report 

13 SF6 sulfur hexafluoride 

14 SHPO State Historic Preservation Office(r) 

15 SILEX separation of isotopes by laser excitation 

16 SNF spent nuclear fuel 

17 SO2 sulfur dioxide 

18 SOx sulfur oxide 

19 SPCC Spill Prevention Control and Countermeasure 

20 SUV sport-utility vehicle 

21 Sv Sievert 

22 SVOC semivolatile organic compound 

23 SWU separative work unit 

24 

25 TAP toxic air pollutant 

26 TCE tricholorethylene 

27 TEDE total effective dose equivalent 

28 Tg teragram 

29 TLD thermoluminescent dosimeter 

30 TSDF treatment, storage, and disposal facility 

31 TSP total suspended particulates 

32 TSS total suspended solids 

33 TWA time-weighted average 

34 

35 U3O8 triuranium octaoxide 

36 UO2 uranium dioxide 

37 UO2F2 uranyl fluoride 

38 UF6 uranium hexafluoride 

39 UNFCCC United Nations Framework Convention on Climate Change 

40 USACE U.S. Army Corps of Engineers 

41 U.S.C. United States Code 

42 USCB U.S. Census Bureau 

43 USDA U.S. Department of Agriculture 

44 USEC U.S. Enrichment Corporation 

45 USGCRP United States Global Change Research Program 

46 USGS U.S. Geological Survey 

47 UV ultraviolet 

48 
 

li 

1 ACRONYMS AND ABBREVIATIONS (Cont.) 

2 

3 VC vinyl chloride 

4 VMT vehicle miles traveled 

5 VOC volatile organic compound 

6 VRM visual resource management 

7 

8 WFSC Wilmington Field Services Center 

9 WMA Wildlife Management Area 

10 WSA Wilderness Study Area 

11 WWTF Wastewater Treatment Facility 

12 

13 μm micrometer 
 

lii 

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15 
 

1-1 

1 1 INTRODUCTION 

2 

3 1.1 Background 

4 

5 The U.S. Nuclear Regulatory Commission (NRC) prepared this draft Environmental Impact 

6 Statement (EIS) in response to an application submitted by General Electric-Hitachi Global 

7 Laser Enrichment LLC (GLE), for a license that would allow the construction, operation, and 

8 decommissioning of a laser-based uranium enrichment facility near Wilmington, North Carolina 

9 (Figures 1-1 and 1-2). The proposed facility is called the Global Laser Enrichment (GLE) 

10 Facility. 

11 

12 The NRC’s Office of Federal and State Materials and Environmental Management Programs 

13 prepared this draft EIS as required by Title 10, “Energy,” Part 51, of the U.S. Code of Federal 

14 Regulations (10 CFR Part 51). In particular, 10 CFR 51.20 (b)(10) states that issuance of a 

15 license for a uranium enrichment facility requires the NRC to prepare an EIS or a supplement to 

16 an EIS. NRC’s regulations under 10 CFR Part 51 implement the requirements of the National 

17 Environmental Policy Act of 1969, as amended (Public Law 91-190). The Act requires Federal 

18 agencies to assess the potential impacts of their actions affecting the quality of the human 

19 environment. 

20 

21 1.2 The Proposed Action 

22 

23 The proposed action is for GLE to construct, operate, and decommission a laser-based uranium 

24 enrichment facility near Wilmington, North Carolina. If the NRC issues a license to GLE under 

25 the provisions of the Atomic Energy Act, the license would authorize GLE to possess and use 

26 special nuclear material, source material, and by-product material at the proposed GLE Facility 

27 for a period of 40 years, in accordance with the NRC’s regulations in 10 CFR Parts 70, 40, and 

28 30, respectively. The scope of activities to be conducted under the license would include the 

29 construction, operation, and decommissioning of the proposed GLE Facility. 

30 

31 GLE has proposed to build the GLE Facility on existing General Electric Company (GE) property 

32 near Wilmington, North Carolina. Two of GE’s principal manufacturing operations – the Global 

33 Nuclear Fuel-Americas (GNF-A) Fuel Manufacturing Operation (FMO) facility and the GE 

34 Aircraft Engines/Services Components Operation (AE/SCO) facility – are already located at the 

35 Wilmington Site. The proposed GLE Facility would be a new facility constructed in the North36 Central Sector of the site. Some of the existing infrastructure at the site, such as the waste 

37 treatment facilities, would also be used by the proposed facility. 

38 

39 Preconstruction and construction of the proposed GLE Facility would take place from 2011 to 

2017, with commencement of facility operations in 2013.1 40 A four-year start-up period would run 

41 concurrently with construction activities, with the facility expected to reach full production 

42 capacity in 2017. Decommissioning or potential license renewal activities would begin in 

43 advance of scheduled license expiration (anticipated to be 2052).

 

1

 As described in Section 1.4.1, certain activities, referred to as ”preconstruction” activities in this 

document, are explicitly excluded from the definition of construction in 10 CFR 51.4. Preconstruction 

activities are not considered a part of the proposed action. 
 

1-2 

Figure 1-1 Location of the Proposed GLE Facility (GLE, 2008a) 
 

1-3 

Figure 1-2 Wilmington Site and Vicinity (GLE, 2008a) 
 

1-4 

1 GLE intends that the proposed GLE Facility help fulfill needs for domestic enriched uranium 

2 capacity for nuclear electrical generation requirements and contribute to national energy 

3 security, as well as contribute to deployment of advanced uranium enrichment technologies 

4 (GLE, 2008a). This purpose and need are discussed in greater 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 1-3) before it can be used in most commercial 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 Through its license application, GLE is seeking NRC authorization to produce enriched uranium 

15 up to eight percent by weight of uranium-235. Although there is currently no demand for 

16 enrichment greater than five percent (enrichment would normally be three to five percent to 

17 meet the needs of nuclear power plants), GLE believes that there is potential for future demand 

18 to change (GLE, 2009j). Enriched uranium from the proposed GLE Facility would be used in 

19 commercial nuclear power plants and is called low-enriched uranium (LEU). Uranium used in 

20 military reactors and nuclear weapons has a much greater percentage of uranium-235 by weight 

21 and is called high-enriched uranium (HEU). 

22 

23 GLE has requested a license for a production capacity of 6 million separative work units 

(SWUs)2 24 per year. An SWU represents the level of effort or energy required to raise the 

25 concentration of uranium-235 to a specified level. 

26 

27 1.3 Purpose and Need for the Proposed Action 

28 

29 As discussed in Section 1.2, the proposed action is for GLE to construct and operate a 

30 commercial facility to enrich uranium up to eight percent by weight of uranium-235, with an initial 

31 planned maximum target annual production capacity of six million SWUs. The proposed facility 

32 would use the GLE laser-based technology and would be constructed on the existing GE 

33 property near Wilmington, North Carolina. The proposed action is intended to satisfy the need 

34 for an additional economical domestic source of enriched uranium. 

35 

 

2

 A separative work unit (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. Given 100 kilograms (220 pounds) of natural uranium, it takes about 60 SWU 

to produce 10 kilograms (22 pounds) of uranium enriched to 4.5 percent uranium-235. It takes on the 

order of 100,000 SWU of enriched uranium to fuel a typical 1000-megawatt commercial nuclear 

reactor for a year (USEC, 2001).
 

1-5 

1 

2 Note: Reprocessing of high-level waste is currently not done in the United States. Neither a reprocessing facility nor 

3 a Federal waste repository is currently approved (licensed) in the United States, and spent fuel is in interim storage. 

4 Figure 1-3 Nuclear Fuel Cycle (NRC, 2008) 

5 

6 In this draft EIS, the need for the proposed GLE Facility is organized by: 

7 

8 • the need for enriched uranium to fulfill electricity generation requirements 

9 

10 • the need for domestic supplies of enriched uranium for national energy security 

11 

12 The purpose of the proposed action is to fulfill these needs. The following sections discuss 

13 these needs and how each is addressed by the proposed action. 

14 
 

1-6 

How Much Is a Megawatt? 

One megawatt roughly provides enough 

electricity for the demand of 400 to 900 homes. 

The actual number is based on the season, 

time of day, region of the country, power plant 

capacity factors, and other factors. 

Source: Bellemare, 2003.

1 1.3.1 Need for Enriched Uranium to Fulfill Electricity Requirements 

2 

3 Enriched uranium from the proposed GLE Facility would be used in U.S. commercial nuclear 

4 power plants. Nuclear power plants currently supply approximately 20 percent of the nation’s 

5 electricity requirements (EIA, 2009a). As future demand for electricity increases, the need for 

6 enriched uranium to fuel nuclear power plants is also expected to increase (EIA, 2009a). 

7 

9 In the Annual Energy Outlook for 2009, for the 

11 case based on established policies and 

13 current trends (the reference case), the 

15 Energy Information Administration (EIA) 

17 estimates that nuclear capacity in the 

19 United States will increase from 

21 100,500 megawatts in 2007 to 

23 112,600 megawatts by 2030, including 

25 3,400 megawatts of expansion at existing 

27 plants, 13,100 megawatts of new capacity, 

29 and 4,400 megawatts of retirement 

30 (EIA, 2009a). Nuclear generation in the United States is estimated to increase from 806 billion 

31 kilowatt hours in 2007 to between 822 and 1,170 billion kilowatt hours in 2030, depending on 

32 the low- or high-growth scenarios. From 2007 to 2009, the NRC received 18 applications to 

33 build 28 new nuclear power plants. More applications are expected in coming years. The EIA 

34 forecasts of nuclear generating capacity, combined with applications from the industry for 

35 construction and operation of new plants, suggest a continuing, if not increasing, demand for 

36 enriched uranium. The EIA forecast shows that the annual demand for enrichment services 

37 may vary between 12.9 million and 15.7 million SWUs from 2006 through 2025 (EIA, 2003). 

38 

39 The demand for enriched uranium in the United States is currently being fulfilled by three main 

40 categories of supply: 

41 

42 • Domestic production of enriched uranium provides about 10−15 percent of U.S. demand

43 (EIA, 2008; EIA, 2009b). The only uranium enrichment facility currently operating in the 

44 United States is the Paducah Gaseous Diffusion Plant, run by USEC’s subsidiary, the 

45 United States Enrichment Corporation. One other enrichment facility presently exists in the 

46 United States, the Portsmouth Gaseous Diffusion Plant; it ceased production in May 2001, 

47 however, and will no longer produce enriched uranium since the plant has been placed in 

48 cold shutdown (a condition whereby the plant is undergoing preparation for 

49 decommissioning and decontamination) (DOE, 2010a). 

50 

51 • The Megatons-to-Megawatts Program provides about 38 percent of U.S. demand 

52 (EIA, 2009b). Under this program, the United States Enrichment Corporation implements 

53 the 1993 government-to-government agreement between the United States and Russia that 

54 calls for Russia to convert 500 metric tons (550 tons) of HEU from dismantled nuclear 

55 warheads into LEU (DOE, 2010b). This is equivalent to about 20,000 nuclear warheads. 

56 The United States Enrichment Corporation purchases the enriched portion of the 

57 “downblended” material, tests it to make sure it meets specifications, adjusts the enrichment 

58 level if needed, and then sells it to its electric utility customers for fuel in commercial nuclear 
 

1-7 

1 power plants. All program activities in the United States now take place at the Paducah 

2 plant (NRC, 2006). This program is scheduled to expire in 2013. 

3 

4 • Other foreign sources provide about 47−52 percent of U.S. demand. Other countries that 

5 produce and export enriched uranium to the United States include France, Germany, the 

6 Netherlands, and the United Kingdom (EIA, 2009b). 

7 

8 The current U.S. demand for enriched uranium is approximately 13−14 million SWUs per year 

9 (EIA, 2008; EIA, 2009b). As noted, recent forecasts indicate that this demand could reach 

10 15 million to 16 million SWUs by 2025, depending on the rate of nuclear generation growth in 

11 the United States (EIA, 2008). Between 2005 and 2009, the United States Enrichment 

12 Corporation supplied between 10 and 13 million SWUs annually to the global market (USEC, 

13 2010). Of this supply, 5.5 million SWUs annually came from downblending under the 

14 Megatons-to-Megawatts Program (USEC, 2010), which depends on deliveries from Russia. 

15 The remaining 4.5–7.5 million SWUs were produced domestically at the Paducah Gaseous 

16 Diffusion plant. Theoretically, all of Paducah’s enrichment capacity could be sold to the U.S. 

17 market, and the overall foreign dependence could be reduced to 5.5–9.5 million SWUs of the 

18 13–14 million SWU total annual demand (42–68 percent of the U.S. demand). 

19 

20 It is anticipated that gaseous diffusion enrichment operations in the United States will cease to 

21 exist in the near future because of the higher cost of aging facilities (DOE, 2007). The 

22 Megatons-to-Megawatts Program is scheduled to expire in 2013 (DOE, 2010b). As noted 

23 above, these two sources meet about half (48−53 percent) of the current U.S. demand for LEU. 

24 

25 To help fill the anticipated supply deficit, other potential future domestic sources of supply have 

26 emerged in recent years. The National Enrichment Facility (NEF) and American Centrifuge 

27 Plant (ACP) have already received construction and operating licenses from the NRC after NRC 

28 consideration of the environmental impacts of those projects (NRC, 2005; 2006), and AREVA 

29 applied for a license in 2008 (AES, 2008). If licensed and constructed, all three of these 

30 facilities would (or plan to) employ gaseous centrifuge technology. Louisiana Energy Services, 

31 LLC (LES) recently announced a potential plan to expand the annual capacity of the NEF from 

32 3 million to 5.9 million SWUs in response to customer expressions of the need for additional 

33 enrichment services (Urenco, 2008). Such an expansion requires NRC review and approval. 

34 With the initial target capacity of 6 million SWUs per year for the proposed GLE Facility, and if 

35 all of the proposed facilities were constructed and operated at their rated capacities, enrichment 

36 capacity in the United States would exceed the projected annual demand (approximately 

37 16 million SWUs) by about 6 million SWUs (assuming NEF is authorized to operate at 

38 5.9 million SWUs and the Paducah Gaseous Diffusion Plant is shut down). However, given the 

39 uncertainties in future development and potential expansion of the proposed projects, this 

40 projected level of extra capacity would provide needed assurance that enriched uranium would 

41 be reliably available when needed for domestic nuclear power production. These three facilities 

42 and the proposed facility are summarized in Table 1-1. 
 

1-8 

Table 1-1 Licensed and Proposed Domestic Sources of Uranium Enrichment 

Facility Location Owner Production Capacity 

(million SWUs/year) 

Current Status 

National Enrichment 

Facility (NEF) 

Lea County, 

New Mexico 

Louisiana Energy 

Services, LLC (LES) 

3.0a Licensed June 23, 2006; 

under construction 

American Centrifuge 

Plant (ACP) 

Piketon, Ohio USEC, Inc. 3.8 Licensed April 13, 2007; 

under construction 

Eagle Rock 

Enrichment Facility 

(EREF) 

Bonneville 

County, Idaho 

AREVA Enrichment 

Services, LLC (AES) 

6.6 Application submitted 

December 30, 2008; 

under review 

Global Laser 

Enrichment Facility 

(GLE) 

Wilmington, 

North Carolina 

General ElectricHitachi Global Laser 

Enrichment, LLC 

6.0 Application submitted 

June 26, 2009; under 

review a

 The NRC expects to receive a request to increase licensed NEF production to 5.9 million SWUs.

1 

2 1.3.2 Need for Domestic Supplies of Enriched Uranium for National Energy Security 

3 

4 All domestic production of enriched uranium currently originates from a single gaseous diffusion 

5 plant at Paducah, Kentucky. This situation creates a reliability risk in U.S. domestic enrichment 

6 capacity. Any disruption in the supply of enriched uranium for domestic commercial nuclear 

7 reactors could have a detrimental impact on national energy security because nuclear reactors 

8 supply approximately 20 percent of the nation’s electricity requirements. The proposed GLE 

9 Facility could play an important role in assuring the nation’s ability to maintain a reliable and 

10 economical domestic source of enriched uranium. 

11 

12 In a letter to NRC regarding general policy issues raised by the LES license application, DOE 

13 stated that uranium enrichment is a critical step in the production of nuclear fuel and noted the 

14 decline in domestic enrichment capacity (DOE, 2002). In its 2002 letter, DOE also referenced 

15 comments made by the U.S. Department of State indicating that “Maintaining a reliable and 

16 economical U.S. uranium enrichment industry is an important U.S. energy security objective” 

17 (DOE, 2002). The proposed GLE Facility could contribute to the attainment of national energy 

18 security policy objectives by providing an additional domestic source of enriched uranium. This 

19 additional capacity would lessen U.S. dependence on foreign sources of enriched uranium. 

20 

21 At present, gaseous diffusion is the only technology in commercial use in the United States. 

22 Gaseous diffusion technology has relatively large resource requirements that make it less 

23 attractive than gas centrifuge technology, from both an economic and environmental 

24 perspective (NRC, 2006). Gas centrifuge technology, which will be used at the NEF, ACP, and 

25 proposed EREF, is known to be more efficient and substantially less energy-intensive than 

26 gaseous diffusion technology. The GLE laser-based technology that would be deployed at the 

27 proposed GLE Facility is newer than gas centrifuge technology and, according to the proponent 

28 of the technology (GE-Hitachi Nuclear Energy [GEH]), offers certain advantages over both the 

29 gaseous diffusion and gas centrifuge processes (GLE, 2008a). For example, GEH considers 

30 laser-based technology to have lower operating costs and lower capital costs than either the 

31 gaseous diffusion or the gas centrifuge technology. GLE further projects the GLE laser-based 

32 technology to have advantages of two earlier-generation laser-excitation technologies in terms 

33 of anticipated high separation factors, low energy intensity, low cooling water requirements, 
 

1-9 

1 small footprint, and low capital and operating costs (GLE, 2008a). Section 2.3.3 provides 

2 information about earlier-generation laser-excitation technologies, as well as competing 

3 technologies. 

4 

5 1.4 Scope of the Environmental Analysis 

6 

7 To fulfill its responsibilities under the National Environmental Policy Act, the NRC has prepared 

8 this draft EIS to analyze the potential environmental impacts (i.e., direct, indirect, and 

9 cumulative impacts) of the proposed GLE Facility as well as reasonable alternatives to the 

10 proposed action. The scope of this draft EIS includes consideration of both radiological and 

11 nonradiological (including chemical) impacts associated with the proposed action and the 

12 reasonable alternatives. In addition, this draft EIS identifies resource uses, monitoring, potential 

13 mitigation measures, unavoidable adverse environmental impacts, the relationship between 

14 short-term uses of the environment and long-term productivity, and irreversible and irretrievable 

15 commitments of resources. 

16 

17 The development of this draft EIS is the result of the NRC staff’s review of the GLE license 

18 application (GLE, 2009a) and its supporting Environmental Report (GLE, 2008a), Environmental 

19 Report supplements (GLE, 2009b,c), and responses to the Request for Additional Information 

20 (RAI) (GLE, 2009d–i), as well as public and agency comments received during the scoping 

21 period. This review is being closely coordinated with the development of the Safety Evaluation 

22 Report being prepared by the NRC to evaluate, among other aspects, the radiological health 

23 and safety impacts of the proposed action. The Safety Evaluation Report is the outcome of the 

24 NRC safety review of the GLE license application. 

25 

26 1.4.1 Scope of the Proposed Action 

27 

28 On December 8, 2008, GLE submitted a request for exemption (GLE, 2008b) from specific NRC 

29 requirements governing “Commencement of Construction” as specified under 10 CFR 70.4, 

30 10 CFR 70.23(a)(7), 10 CFR 30.4, 10 CFR 30.33(a)(5), 10 CFR 40.4, and 10 CFR 40.32(e). 

31 This exemption was approved by the NRC on May 8, 2009 (NRC, 2009c). The exemption 

32 allows GLE to proceed with certain activities that are considered outside of NRC regulatory 

33 purview (they are not related to radiological health and safety or the common defense and 

34 security) without an NRC license to construct and operate the GLE Facility (the proposed 

35 action). These activities, discussed further in Section 2.1.5, are referred to as “preconstruction” 

36 activities, as they are not considered construction activities under the definition of construction 

37 currently provided in 10 CFR 50.2 and10 CFR 51.4. Specifically, 10 CFR 51.4 states, in 

38 relevant part, that “construction” does not include the following activities: 

39 

40 i. Changes for temporary use of the land for public recreational purposes; 

41 

42 ii. Site exploration, including necessary borings to determine foundation conditions or other 

43 preconstruction monitoring to establish background information related to the suitability 

44 of the site, the environmental impacts of construction or operation, or the protection of 

45 environmental values; 

46 
 

1-10 

1 iii. Preparation of a site for construction of a facility, including clearing of the site, grading, 

2 installation of drainage, erosion and other environmental mitigation measures, and 

3 construction of temporary roads and borrow areas; 

4 

5 iv. Erection of fences and other access control measures; 

6 

7 v. Excavation; 

8 

9 vi. Erection of support buildings (such as construction equipment storage sheds, 

10 warehouse and shop facilities, utilities, concrete mixing plants, docking and unloading 

11 facilities, and office buildings) for use in connection with the construction of the facility; 

12 

13 vii. Building of service facilities, such as paved roads, parking lots, railroad spurs, exterior 

14 utility and lighting systems, potable water systems, sanitary sewerage treatment 

15 facilities, and transmission lines; 

16 

17 viii. Procurement or fabrication of components or portions of the proposed facility occurring 

18 at other than the final, in-place location at the facility; 

19 

20 ix. Manufacture of a nuclear power reactor under a manufacturing license under Subpart F 

21 of Part 52 of this chapter to be installed at the proposed site and to be part of the 

22 proposed facility; or 

23 

24 x. With respect to production or utilization facilities, other than testing facilities and nuclear 

25 power plants, required to be licensed under Section 104.a or Section 104.c of the Act, 

26 the erection of buildings which will be used for activities other than operation of a facility 

27 and which may also be used to house a facility (e.g., the construction of a college 

28 laboratory building with space for installation of a training reactor). 

29 

30 As indicated in (iii) of the list above, site preparation is one component of preconstruction. As 

31 used in this document, the term “site preparation” includes the items specifically listed in (iii) 

32 above (i.e., clearing of the site, grading, installation of drainage, erosion and other 

33 environmental mitigation measures, and construction of temporary roads and borrow areas). 

34 

35 The NRC’s decision to grant the exemption request to GLE was based on the NRC staff finding 

36 that the request to perform certain preconstruction activities is authorized by law, will not 

37 endanger life or property or common defense and security, and is in the public interest 

38 (NRC, 2009b). The exemption covered the following activities and facilities: 

39 

• clearing of approximately 40 hectares (100 acres)3 40 

41 

42 • site grading and erosion control 

 

3

 Due to minor adjustments in the facility layout, the proposed GLE Facility is currently estimated to 

encompass approximately 47 hectares (117 acres). For consistency within this draft EIS and with the 

GLE Environmental Report (GLE, 2008), it continues to be referred to as the approximately 40-hectare 

(100-acre) proposed GLE Facility. However, the impact analyses performed in this draft EIS consider 

the larger area. 
 

1-11 

1 • stormwater retention ponds 

2 

3 • main access roadways and guardhouses 

4 • utilities 

5 

6 • parking lots 

7 

8 • administrative buildings not used to process, handle, or store classified information 

9 

10 The authorization to conduct the listed activities or construct the listed facilities prior to the NRC 

11 licensing decision was based on the condition that none of the facilities or activities subject to 

12 the exemption will be, at a later date, a component of GLE’s Physical Security Plan or its 

13 Standard Practice Procedures Plan for the Protection of Classified Matter or otherwise subject 

14 to NRC review or approval. Approval of the exemption request does not indicate that a 

15 licensing decision has been made by the NRC. Preconstruction activities would be completed 

16 by GLE with the risk that a license may not be issued. 

17 

18 GLE indicated that the activities it undertakes under the exemption request may include all of 

19 the above-listed activities (GLE, 2009d). GLE also indicated that the actual work to be 

20 completed and the schedule are uncertain at this time, due to various business factors. In its 

21 RAI response, GLE stated that some of the activities could be up to 75 percent complete, 

22 whereas others maybe only 10 percent complete by the time the NRC decides whether or not to 

23 grant a license. Thus, although the activities covered by the NRC’s May 8, 2009 exemption 

24 (NRC, 2009c) are referred to in this document as “preconstruction” activities, some of these 

25 activities may continue after the commencement of construction, if a license is issued. In 

26 addition, GLE indicated that if for any reason the proposed GLE Facility project does not reach 

27 fruition, the decision to continue to develop the area referred to as the 40-hectare (100-acre) 

28 proposed GLE Facility would be made by GE senior management. GE may continue to develop 

29 the land to construct administrative facilities (i.e., office space) if there is a future expansion of 

30 the Wilmington Site workforce. If the land would not be used in the immediate future following 

31 the decision to cancel the proposed GLE Facility project, GE would consider replanting all or a 

32 portion of the area with native trees, in accordance with then-current Wilmington Site forest 

33 management activities (GLE, 2009d). 

34 

35 The activities authorized under the exemption are expected to occur whether or not the license 

36 is granted. As a result, the NRC does not consider these activities as part of the proposed 

37 action or the no action alternative. However, because they are related to the construction of the 

38 proposed GLE Facility, NRC staff analyzed their impacts in Chapter 4 as part of the impacts 

39 considered under “Preconstruction and Construction.” However, the staff also attempted, to the 

40 extent possible, to separate the impacts from site preparation and construction activities into 

41 those that would occur as a result of preconstruction activities and those that would occur as a 

42 result of construction activities as defined in 10 CFR 50.2 and 10 CFR 51.4. The staff also 

43 considered all of the impacts that would be expected to occur under preconstruction and 

44 construction in evaluating the cumulative impacts of the proposed action. 

45 

46 In addition to construction, the scope of the proposed action also includes the activities 

47 associated with the operation and decontamination and decommissioning of the proposed GLE 

48 Facility. These impacts are discussed in Chapter 4. 
 

1-12 

1 

2 1.4.2 Scoping Process and Public Participation Activities 

3 

4 The NRC regulations in 10 CFR Part 51 contain requirements for conducting a scoping process 

5 prior to the preparation of an EIS. Scoping was used to help identify the relevant issues to be 

6 discussed in detail and to help identify issues that are beyond the scope of this draft EIS, which 

7 do not warrant a detailed discussion, or are not directly relevant to the assessment of potential 

8 impacts from the proposed action. 

9 

10 On April 9, 2009, the NRC published a Notice of Intent (NOI) in the Federal Register 

11 (74 FR 16237) to prepare an EIS for the construction, operation, and decommissioning of the 

12 proposed GLE Facility and to conduct the scoping process for the EIS. The NOI summarized 

13 the NRC’s plans to prepare the EIS and presented background information on the proposed 

14 GLE Facility. For the scoping process, the NOI invited comments on the proposed action and 

15 announced a public scoping meeting to be held concerning the project. 

16 

17 On July 14−17, 2008, and May 18−20, 2009, the NRC staff met with State and local officials and 

18 toured the proposed GLE Facility site. On July 17, 2009, NRC staff held a public information 

19 meeting to provide background information about the NRC’s safety and environmental review 

20 processes and to notify the public to the upcoming public scoping period. On May 19, 2009, the 

21 NRC held two public scoping meetings in Wilmington, North Carolina. During the scoping 

22 meetings, a number of individuals provided oral comments to the NRC concerning the proposed 

23 GLE Facility and the development of the draft EIS. In addition, the NRC received written 

24 comments during the public scoping period that was to end on June 8, 2009. The NRC 

25 subsequently extended the scoping period to August 31, 2009, to allow members of the public 

26 to examine GLE’s license application, which was submitted on June 26, 2009. The NRC 

27 reviewed and identified substantive scoping comments (both oral and written). These 

28 comments were then consolidated and categorized by topical areas. 

29 

30 After the scoping period, the NRC issued the Environmental Scoping Summary Report: 

31 Proposed GE-Hitachi Global Laser Enrichment Facility in Wilmington, North Carolina in 

32 November 2009 (see Appendix A). The report identifies categories of issues to be analyzed in 

33 detail and issues determined to be beyond the scope of the EIS. 

34 

35 1.4.3 Issues Studied in Detail 

36 

37 As stated in the NOI, the NRC identified issues to be studied in detail as they relate to 

38 implementation of the proposed action. The public identified additional issues during the 

39 subsequent public scoping process. Issues identified by the NRC and the public that could 

40 have short- or long-term impacts from the potential construction and operation of the proposed 

41 GLE Facility include: 

42 

43 • need for the facility • air quality 

44 • compliance with applicable regulations • noise 

45 • alternatives • historic and cultural resources 

46 • decommissioning • visual and scenic resources 

47 • cumulative impacts • socioeconomic impacts 

48 • land use • public and occupational health 
 

1-13 

1 • transportation • waste management 

2 • accidents • depleted uranium disposition 

3 • geology and soils • environmental justice 

4 • water resources • costs and benefits 

5 • ecological resources • resource commitments 

6 

7 1.4.4 Issues Eliminated from Detailed Study 

8 

9 No issues were eliminated from detailed study as a result of the public scoping process. 

10 However, some issues are analyzed in detail in the NRC’s Safety Evaluation Report and are 

11 only summarized in the draft EIS. For example, within the area of safety and security, the 

12 Safety Evaluation Report analyzes the probabilities and consequences of various accidents at 

13 the proposed GLE Facility, as well as measures to prevent those accidents and mitigate their 

14 effects. This draft EIS does not go into the same level of detail, but summarizes, in 

15 Section 4.2.15, the accident analysis from the Safety Evaluation Report for the purpose of 

16 assessing the potential environmental impacts of accidents. Alternatives considered but not 

17 analyzed in detail are discussed in Section 2.3. 

18 

19 1.4.5 Issues Outside the Scope of the EIS 

20 

21 The following issues raised during the scoping process have been determined to be outside the 

22 scope of the EIS (see Appendix A): 

23 

24 • nonproliferation 

25 

26 • GE’s pursuit of boiling water reactors 

27 

28 • terrorism 

29 

30 1.4.6 Related NEPA and Other Relevant Documents 

31 

32 The following NEPA documents were reviewed as part of the development of this draft EIS. 

33 

34 • Environmental Impact Statement for the Proposed American Centrifuge Plant in Piketon, 

35 Ohio, Final Report, NUREG-1834, Office of Nuclear Material Safety and Safeguards, 

36 U.S. Nuclear Regulatory Commission, April, 2006. This EIS analyzes the potential 

37 environmental impacts of the proposed siting, construction, operation, and decommissioning 

38 of a gas centrifuge uranium enrichment facility at the existing DOE reservation in Piketon, 

39 Ohio. Its description of the purpose of and need for the proposed action, as well as its 

40 review of alternatives to the proposed action, are highly relevant to the proposed GLE 

41 Facility analysis. The environmental impacts discussed for the proposed ACP are also 

42 relevant to the impact analysis for the proposed GLE Facility, especially the analysis of 

43 cumulative impacts associated with the management of depleted uranium hexafluoride (UF6) 

44 generated by the ACP and NEF, and the proposed GLE Facility and EREF as well as the 

45 existing DOE inventory of depleted UF6. 
 

1-14 

1 • Environmental Impact Statement for the Proposed National Enrichment Facility in Lea 

2 County, New Mexico, Final Report, NUREG-1790, Office of Nuclear Material Safety and 

3 Safeguards, U.S. Nuclear Regulatory Commission, June, 2005. This EIS analyzes the 

4 potential environmental impacts of the proposed siting, construction, operation, and 

5 decommissioning of a gas centrifuge uranium enrichment facility near Eunice, New Mexico. 

6 Its description of the purpose of and need for the proposed action, as well as its review of 

7 alternatives to the proposed action, are highly relevant to the proposed GLE Facility 

8 analysis. The environmental impacts discussed for the proposed NEF are also relevant to 

9 the impact analysis for the proposed GLE Facility, especially the analysis of cumulative 

10 impacts associated with the management of depleted UF6 generated by the ACP and NEF, 

11 and the proposed GLE Facility and EREF as well as the existing DOE inventory of 

12 depleted UF6. 

13 

14 • Final Environmental Impact Statement for the Construction and Operation of a Depleted 

15 Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio, Site, DOE/EIS-0360, 

16 Oak Ridge Operations, Office of Environmental Management, U.S. Department of Energy, 

17 June, 2004. This site-specific EIS analyzes the impacts associated with the construction, 

18 operation, and decommissioning of a depleted UF6 conversion facility at the Portsmouth, 

19 Ohio, site. The EIS also evaluates the impacts of transporting cylinders (depleted UF6, 

20 enriched uranium, and empty) that used to be stored at the East Tennessee Technology 

21 Park near Oak Ridge, Tennessee, to Portsmouth. Transportation of depleted UF6

22 conversion products and waste materials to a disposal facility, transportation and sale of the 

23 hydrogen fluoride produced as a conversion co-product; and neutralization of hydrogen 

24 fluoride to calcium fluoride and its sale or disposal in the event that the hydrogen fluoride 

25 product is not sold are also evaluated. The results presented in the EIS are relevant to the 

26 management, use, and potential impacts associated with the depleted UF6 that would be 

27 generated at the proposed GLE Facility and the cumulative impacts of depleted UF6 from 

28 the ACP and NEF, and the proposed GLE Facility and EREF as well as the existing DOE 

29 inventory of depleted UF6. 

30 

31 • Final Environmental Impact Statement for the Construction and Operation of a Depleted 

32 Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky, Site, DOE/EIS-0359, 

33 Oak Ridge Operations, Office of Environmental Management, U.S Department of Energy, 

34 June, 2004. This site-specific EIS is very similar to the EIS for the Portsmouth, Ohio, site, 

35 except that the conversion facility is at the Paducah, Kentucky, site. 

36 

37 • Environmental Assessment: Disposition of Russian Federation Titled Natural Uranium. 

38 DOE/EA-1290, Office of Nuclear Energy, Science and Technology, U.S. Department of 

39 Energy, June 1999. This Environmental Assessment (EA) analyzed the environmental 

40 impacts of transporting natural UF6 from the gaseous diffusion plants to the Russian 

41 Federation. Transportation by rail and truck within the United States were considered. The 

42 EA addresses both incident-free transportation and transportation accidents. The results 

43 presented in this EA are relevant to the transportation of UF6 for the proposed GLE Facility. 

44 

45 • Final Programmatic Environmental Impact Statement for Alternative Strategies for the Long46 Term Management and Use of Depleted Uranium Hexafluoride, DOE/EIS-0269, Office of 

47 Nuclear Energy, Science and Technology, U.S. Department of Energy, April 1999. This EIS 

48 analyzes strategies for the long-term management of the depleted UF6 inventory that was 
 

1-15 

1 stored at three DOE sites near Paducah, Kentucky; Portsmouth, Ohio; and Oak Ridge, 

2 Tennessee at the time the EIS was prepared. This EIS also analyzes the potential

3 environmental consequences of implementing each alternative strategy for the period 1999

4 through 2039. The results presented in this EIS are relevant to the management, use, and 

5 potential impacts associated with the depleted UF6 that would be generated at the proposed 

6 GLE Facility and the cumulative impacts of depleted UF6 from the ACP and NEF and the 

7 proposed GLE Facility and EREF as well as the existing DOE inventory of depleted UF6. 

8 

9 1.5 Applicable Statutory and Regulatory Requirements 

10 

11 This section provides a summary assessment of the major environmental requirements, 

12 agreements, Executive Orders, and permits relevant to the construction, operation, and 

13 decommissioning of the proposed GLE Facility. 

14 

15 1.5.1 Federal Laws and Regulations 

16 

17 1.5.1.1 National Environmental Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.) 

18 

19 The National Environmental Policy Act (NEPA) establishes national environmental policy and 

20 goals for the protection, maintenance, and enhancement of the environment to ensure for all 

21 Americans a safe, healthful, productive, and aesthetically and culturally pleasing environment. 

22 The Act provides a process for implementing these specific goals within the Federal agencies 

23 responsible for the action. This draft EIS has been prepared in accordance with NEPA

24 requirements and NRC regulations (10 CFR Part 51) for implementing NEPA. 

25 

26 1.5.1.2 Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.), and the Energy 

27 Reorganization Act of 1974 (42 U.S.C. 5801 et seq.) 

28 

29 The Atomic Energy Act (AEA), as amended, and the Energy Reorganization Act of 1974 

30 (Title 42, Section 5801 et seq. of the United States Code [42 U.S.C. 5801 et seq.]) give the NRC 

31 the licensing and regulatory authority for nuclear energy uses within the commercial sector. If 

32 the license application for the proposed GLE Facility is approved, the NRC would license and 

33 regulate the possession, use, storage, and transfer of special nuclear, source, and by-product 

34 materials to protect public health and safety as stipulated in 10 CFR Parts 30, 40, and 70. 

35 

36 1.5.1.3 Clean Air Act of 1970, as amended (42 U.S.C. 7401 et seq.) 

37 

38 The Clean Air Act (CAA) establishes regulations to ensure air quality and authorizes individual 

39 States to manage permits. The CAA requires (1) the U.S. Environmental Protection Agency 

40 (EPA) to establish National Ambient Air Quality Standards as necessary to protect the public 

41 health, with an adequate margin of safety, from any known or anticipated adverse effects of a 

42 regulated pollutant (42 U.S.C. 7409 et seq.); (2) the establishment of national standards of 

43 performance for new or modified stationary sources of atmospheric pollutants (42 U.S.C. 7411); 

44 (3) specific emission increases to be evaluated so as to prevent a significant deterioration in air 

45 quality (42 U.S.C. 7470 et seq.); and (4) specific standards for releases of hazardous air 

46 pollutants (including radionuclides) (42 U.S.C. 7412). These standards are implemented 

47 through plans developed by each State and approved by the EPA. The CAA requires sources 

48 to meet standards and obtain permits to satisfy those standards. The North Carolina 
 

1-16 

1 Department of Environment and Natural Resources (NCDENR) Division of Air Quality 

2 implements the CAA in the State. Construction and operating permits are required for the 

3 proposed GLE Facility but emissions during operation will not rise to the CAA’s major source 

4 threshold. 

5 

6 1.5.1.4 Clean Water Act of 1977 (amending the Federal Water Pollution Control Act of 

7 1948), as amended (33 U.S.C. 1251 et seq.) 

8 

9 The Clean Water Act (CWA) requires the EPA to set national effluent limitations and water 

10 quality standards and establishes a regulatory program for enforcement. Specifically, 

11 Section 402(a) of the Act establishes water quality standards for contaminants in surface 

12 waters. The CWA requires a National Pollutant Discharge Elimination System (NPDES) permit 

13 before discharging any point source pollutant into surface waters of the United States. The 

14 NPDES permit program contains a program applicable to discharges of stormwater to waters of 

15 the United States from construction and industrial operations. Section 404 of the CWA 

16 authorizes the U.S. Army Corps of Engineers (USACE) to issue permits for the discharge of 

17 dredged or fill material into the waters of the United States. The Section 401 water quality 

18 certification and NPDES provisions of the CWA have been delegated to the NCDENR Division 

19 of Water Quality. The proposed GLE Facility will require a Section 404 permit. Existing NPDES 

20 permits for Wilmington Site operations will require modification to incorporate the proposed GLE 

21 Facility; a new NPDES permit for construction of the facility will be required. 

22 

23 1.5.1.5 Resource Conservation and Recovery Act of 1976 (amending the Solid Waste 

24 Disposal Act of 1965), as amended (42 U.S.C. 6901 et seq.) 

25 

26 The Resource Conservation and Recovery Act (RCRA), as amended, requires the EPA to 

27 define and identify hazardous waste; establish standards for its transportation, treatment, 

28 storage, and disposal; and require permits for persons engaged in hazardous waste activities. 

29 Section 3006 (42 U.S.C. 6926) allows States to establish and administer these permit programs 

30 with EPA approval; the NCDENR Division of Waste Management has received that approval. 

31 EPA regulations implementing RCRA are found in 40 CFR Parts 260 through 283. Regulations 

32 imposed on a generator or on a treatment, storage, and/or disposal facility vary according to the 

33 type and quantity of material or waste generated, treated, stored, and/or disposed. The method 

34 of treatment, storage, and/or disposal also affects the extent and complexity of the 

35 requirements. A RCRA treatment, storage, or disposal permit will not be required for the 

36 proposed GLE Facility due to the amount of hazardous waste generated and the stated plans 

37 for the wastes to be shipped to a RCRA-permitted facility within the 90-day accumulation period. 

38 A hazardous waste generator number will be required. 

39 

40 1.5.1.6 Low-Level Radioactive Waste Policy Act of 1980, as amended 

41 (42 U.S.C. 2021 et seq.) 

42 

43 The Low-Level Radioactive Waste Policy Act of 1980 amended the AEA to specify that the 

44 Federal Government is responsible for disposal of low-level radioactive waste generated by its 

45 activities and that States are responsible for disposal of other low-level radioactive waste 

46 (LLRW). The Low-Level Radioactive Waste Policy Act of 1980 provides for and encourages 

47 interstate compacts to carry out the State responsibilities. The LLRW generated at the 

48 proposed GLE Facility is Class-A waste; this class has the lowest concentration of radioactive 
 

1-17 

1 material and poses the least potential hazard of the LLRW classes. Plans call for shipment of 

2 the LLRW to the EnergySolutions disposal facility in Clive, Utah. 

3 

4 1.5.1.7 Emergency Planning and Community Right-to-Know Act of 1986 

5 (42 U.S.C. 11001 et seq.) (also known as Superfund Amendments 

6 and Reauthorization Act of 1986 [SARA] Title III) 

7 

8 The Emergency Planning and Community Right-to-Know Act of 1986, which is the major 

9 amendment to the Comprehensive Environmental Response, Compensation, and Liability Act 

10 (42 U.S.C. 9601), establishes the requirements for Federal, State, and local governments; 

11 Indian tribes; and industry regarding emergency planning and “Community Right-to-Know” 

12 reporting on hazardous and toxic chemicals. The “Community Right-to-Know” provisions 

13 increase the public’s knowledge and access to information about chemicals at individual 

14 facilities, their uses, and releases into the environment. States and communities working with 

15 facilities can use the information to improve chemical safety and protect public health and the 

16 environment. The Act requires emergency planning and notice to communities and government 

17 agencies concerning the presence and release of specific chemicals. The EPA implements this 

18 Act under regulations found in 40 CFR Parts 355, 370, and 372. The Act requires the proposed 

19 GLE Facility to provide the State Emergency Planning Committee and local fire departments 

20 with information on the storage and use of chemicals above certain threshold levels and comply 

21 with toxic chemical reporting requirements if thresholds for chemical releases are exceeded. 

22 

23 1.5.1.8 Safe Drinking Water Act of 1974, as amended (42 U.S.C. 300f et seq.) 

24 

25 The Safe Drinking Water Act was enacted to protect the quality of public water supplies and 

26 sources of drinking water through establishing minimum national standards for public water 

27 supply systems. The Act includes the Sole Source Aquifer Program and provisions for the 

28 protection of public drinking water systems. The NCDENR Division of Environmental Health, 

29 Public Water Supply Section enforces the Safe Drinking Water Act. The proposed GLE Facility 

30 would use groundwater for industrial process water and drinking water from wells on the 

31 Wilmington Site. North Carolina requires the registration of water withdrawals above certain 

32 thresholds; the Wilmington Site registers its withdrawals with the State. 

33 

34 1.5.1.9 Noise Control Act of 1972, as amended (42 U.S.C. 4901 et seq.) 

35 

36 The Noise Control Act delegates the responsibility of noise control to State and local 

37 governments. Commercial facilities are required to comply with Federal, State, interstate, and 

38 local requirements regarding noise control. New Hanover County enacted a noise ordinance 

39 pursuant to the authority granted it by a North Carolina law. The noise ordinance established 

40 decibel levels for areas zoned nonresidential with which the proposed GLE Facility must 

41 comply. 

42 

43 1.5.1.10 National Historic Preservation Act of 1966, as amended (16 U.S.C. 470 et seq.) 

44 

45 The National Historic Preservation Act was enacted to create a national historic preservation 

46 program, including the National Register of Historic Places (NRHP) and the Advisory Council on 

47 Historic Preservation (ACHP). Section 106 requires Federal agencies to take into account the 

48 effects of their undertakings on historic properties. The ACHP regulations implementing 
 

1-18 

1 Section 106 of the Act are found in 36 CFR Part 800. The regulations call for public 

2 involvement in the Section 106 consultation process, including American Indian tribes and other 

3 interested members of the public, as applicable. The NRC has initiated the Section 106 

4 consultation process (see Section 1.5.6.2 and Appendix B). 

5 

6 1.5.1.11 Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.) 

7 

8 The Endangered Species Act (ESA) was enacted to prevent the further decline of endangered 

9 and threatened species and to restore those species and their critical habitats. Section 7 of the 

10 Act requires consultation with the U.S. Fish and Wildlife Service (FWS) of the U.S. Department 

11 of the Interior or the National Marine Fisheries Service of the U.S. Department of Commerce to 

12 determine whether endangered and threatened species or their critical habitats are known to be 

13 in the vicinity of the proposed action, and to determine whether the proposed Federal action 

14 may affect listed species or critical habitat. The NRC has initiated the ESA consultation process 

15 (see Section 1.5.6.1 and Appendix B). 

16 

17 1.5.1.12 Coastal Zone Management Act of 1972, as amended (16 U.S.C. 1451 et seq.) 

18 

19 The Coastal Zone Management Act (CZMA) provides for management of the nation's coastal 

20 resources and balances economic development with environmental conservation. It encourages 

21 States and tribes to voluntarily preserve, protect, develop, and where possible, restore or 

22 enhance valuable natural coastal resources such as wetlands, floodplains, estuaries, beaches, 

23 dunes, barrier islands, and coral reefs, as well as the fish and wildlife using those habitats. The 

24 Act makes federal financial assistance available to any coastal State, tribe, or territory that is 

25 willing to develop and implement a comprehensive coastal management program. The CZMA is 

26 implemented by the North Carolina Division of Coastal Management through the state’s Coastal 

27 Area Management Act.

28 

29 1.5.1.13 Magnuson-Stevens Fishery Conservation and Management Reauthorization 

30 Act of 2006, as amended (16 U.S.C. 1801 et seq.) 

31 

32 The Magnuson-Stevens Fishery Conservation and Management Reauthorization Act provides 

33 for a national program for the conservation and management of the fishery resources of the 

34 United States. The purposes of the program are to prevent overfishing, rebuild overfished 

35 stocks, ensure conservation, facilitate long-term protection of essential fish habitats, and realize 

36 the full potential of the nation's fishery resources. The Act establishes regional fishery 

37 management councils which can develop fishery management plans; North Carolina is a 

38 member of the South Atlantic Council. 

39 

40 1.5.1.14 Occupational Safety and Health Act of 1970, as amended (29 U.S.C. 651 et seq.) 

41 

42 The Occupational Safety and Health Act establishes standards to enhance safe and healthy 

43 working conditions in places of employment throughout the United States. The Act is 

44 administered and enforced by the Occupational Safety and Health Administration (OSHA), a 

45 U.S. Department of Labor agency. The identification, classification, and regulation of potential 

46 occupational carcinogens are found in 29 U.S.C. 1910.101, while the standards pertaining to 

47 hazardous materials are listed in 29 U.S.C. 1910.120. The Occupational Health and Safety 
 

1-19 

1 Administration regulates mitigation requirements and mandates proper training and equipment 

2 for workers. The proposed GLE Facility would be required to comply with these regulations. 

3 

4 1.5.1.15 Hazardous Materials Transportation Act of 1975 (49 U.S.C. 1801 et seq.) 

5 

6 The Hazardous Materials Transportation Act regulates transportation of hazardous material 

7 (including radioactive material) in and between States. According to the Act, States may 

8 regulate the transport of hazardous material as long as they are consistent with the Act or the 

9 U.S. Department of Transportation regulations provided in 49 CFR Parts 171 through 177. 

10 49 CFR Part 173, Subpart I, contains other regulations regarding packaging for transportation of 

11 radionuclides. The transport of radioactive materials to and from the proposed GLE Facility 

12 would be required to comply with these regulations. 

13 

14 1.5.1.16 United States Enrichment Corporation Privatization Act of 1996

15 (42 U.S.C. 2011 et seq.) 

16 

17 The United States Enrichment Corporation Privatization Act establishes a disposal option for 

18 depleted uranium if it is determined to be low-level radioactive waste; the NRC made that 

19 determination in 2005. The Act allows any person licensed by the NRC to operate a uranium 

20 enrichment facility to request that the U.S. Department of Energy accept for disposal as low21 level radioactive waste depleted uranium it generated. GLE thus has the option of requesting 

22 that its depleted uranium be accepted by the Department of Energy for disposal. 

23 

24 1.5.1.17 Environmental Standards for the Uranium Fuel Cycle (40 CFR Part 190, 

25 Subpart B) 

26 

27 These regulations establish maximum doses to the body or organs of members of the public as 

28 a result of operational normal releases from uranium fuel cycle activities, including uranium 

29 enrichment. These regulations were promulgated by the EPA under the authority of the AEA, 

30 as amended, and have been incorporated by reference in the NRC regulations in 

31 10 CFR 20.1301(e). The proposed GLE Facility would be required to comply with these 

32 regulations for releases from normal operations. 

33 

34 1.5.2 Applicable Executive Orders 

35 

36 • Executive Order 11988 (Floodplain Management) directs Federal agencies to establish 

37 procedures to ensure that the potential effects of flood hazards and floodplain management 

38 are considered for any action undertaken in a floodplain and that floodplain impacts be 

39 avoided to the extent practicable. 

40 

41 • Executive Order 11990 (Protection of Wetlands) directs Federal agencies to avoid new 

42 construction in wetlands unless there is no practicable alternative and unless the proposed 

43 action includes all practicable measures to minimize harm to wetlands that might result from 

44 such use. 

45 

46 • Executive Order 12898 (Environmental Justice) calls for Federal agencies to address 

47 environmental justice in minority and low-income populations, and directs Federal agencies 

48 to identify and address, as appropriate, disproportionately high and adverse health or 
 

1-20 

1 environmental effects of their programs, policies, and activities on minority and low-income 

2 populations. In response to this Executive Order, the NRC issued a final policy statement 

3 on the “Treatment of Environmental Justice Matters in NRC Regulatory and Licensing 

4 Actions” (69 FR 52040; August 24, 2004) and environmental justice procedures to be 

5 followed in NEPA documents prepared by the NRC’s Office of Nuclear Material Safety and 

6 Safeguards (NRC, 2003). 

7 

8 1.5.3 Applicable State of North Carolina Requirements 

9 

10 Certain environmental requirements, including some discussed earlier, have been delegated to 

11 State authorities for implementation, enforcement, or oversight. Table 1-2 lists the State of 

12 North Carolina environmental requirements. 

13 

14 1.5.4 Permit and Approval Status 

15 

16 Several construction and operating permits must be prepared and submitted, and regulatory 

17 approval and/or permits must be received prior to construction or operation of the proposed 

18 GLE Facility. Table 1-3 lists the Federal, State, and local permits that may be required and their 

19 present status. 

20 

21 1.5.5 Cooperating Agencies 

22 

23 No Federal, State, or local agencies are cooperating agencies in the preparation of this draft 

24 EIS. 

25 

26 1.5.6 Consultations 

27 

28 As a Federal agency, the NRC is required to comply with the consultation requirements of the 

29 Endangered Species Act of 1973, the National Historic Preservation Act of 1966, and the Fish 

30 and Wildlife Coordination Act of 1934. 

31 

Table 1-2 State of North Carolina Environmental Regulations 

Law/Regulation Citation Requirements 

Air Pollution Control 

Requirements 

15A North Carolina 

Administrative Code (NCAC) 

02D, authorized by North 

Carolina General Statutes

(NCGS) 143, Article 21B, Air 

Pollution Controla

Establishes a system for classifying 

air pollution sources which the 

Environmental Management 

Commission uses to classify air 

pollution sources it believes to be of 

sufficient importance to justify 

classification or control. 

Air Quality Permit Procedures 15A NCAC 02Q, authorized 

by NCGS 143, Article 21B, 

Air Pollution Control 

Establishes the requirements and 

procedures for applying for 

construction and operation air 

quality permits and exceptions to 

them; incorporates 40 CFR 

Parts 61 to 80 by reference. 
 

1-21 

Table 1-2 State of North Carolina Environmental Regulations (Cont.) 

Law/Regulation Citation Requirements 

Archaeology and Historic 

Preservation Section 

07 NCAC 04R, authorized 

by multiple NCGS 

Establishes the role of the State 

Historic Preservation Officer 

(SHPO), the procedures for 

archaeological review, and the 

process for making nominations to 

the NRHP. 

Coastal Management 15A NCAC 07, authorized 

by NCGS 113A, Article 7, 

Coastal Area Management 

Requires a permit before 

undertaking any development in 

any area of environmental concern. 

Establishes a cooperative program 

of coastal area management 

between local and State 

governments. 

Discharges to Isolated 

Wetlands and Isolated Waters 

15A NCAC 02H.1300, 

authorized by NCGS 143, 

Article 21, Water and Air 

Resources 

Defines the terms “discharge” and 

“isolated wetlands” and requires an 

Individual Permit or a Certificate of 

Coverage to operate under a 

General Permit for any regulated 

discharges to isolated wetlands. 

Endangered and Threatened 

Species

15A NCAC 10I , authorized 

by NCGS 113, Article 24, 

Endangered and Threatened 

Wildlife and Wildlife Species 

of Special Concern

Bans open seasons for taking any 

of the species listed as endangered 

or threatened; establishes permit 

protocols for taking or possessing 

an endangered, threatened, or 

special concern species. 

Hazardous Waste 

Management 

15A NCAC 13A, authorized 

by NCGS 130A, Article 9, 

Solid Waste Management 

Establishes the general 

requirements for the State’s 

hazardous waste management 

program and permit program; 

adopts applicable RCRA 

regulations by reference. 

Hazardous Waste Permit 

Program 

15A NCAC 13A.0113, 

authorized by NCGS 130A, 

Article 9, Solid Waste 

Management 

Establishes the procedures and 

requirements for hazardous waste 

permits; incorporates 40 CFR 270.1 

through 270.6 by reference. 

Historic Sites Regulation 07 NCAC 04N authorized by 

NCGS 121, Article 1, 

General Provisions 

Itemizes activities banned from 

state historic site properties unless 

specifically authorized via a written 

work order or permit; describes the 

permit process. 
 

1-22 

Table 1-2 State of North Carolina Environmental Regulations (Cont.) 

Law/Regulation Citation Requirements 

Human Skeletal Remains NCGS 70, Article 3, 

Unmarked Human Burial 

and Human Skeletal 

Remains Protection Act

Requires cessation of activities 

disturbing unmarked human burials 

or human skeletal remains when 

they are encountered as a result of 

construction until authorization to 

resume the activity is received 

either from the county medical 

examiner or the State 

Archaeologist. 

Noise New Hanover County Code 

of Ordinances, Chapter 23, 

Article II, authorized by 

GS 153A-133, Noise 

Regulation 

Establishes the lawful decibel 

levels and corresponding time 

periods for non-residentially zoned 

districts. 

Point Source Discharges to 

the Surface Waters 

15A NCAC 02H.0100, 

authorized by NCGS 143, 

Article 21, Water and Air 

Resources 

Provides the requirements and 

procedures for application and 

issuance of State NPDES permits 

for discharges from outlets, point 

sources, or disposal systems 

discharging to the surface waters of 

the State. 

Radiation Protection 15A NCAC 11 authorized by 

NCGS 104E, North Carolina 

Radiation Protection Act

Regulates the use of source 

material, by-product material, and 

special nuclear material in 

quantities not sufficient to form a 

critical mass for the protection of 

public health, safety, or property. 

Requires a specific or general 

license to receive, possess, use, 

transfer, own, or acquire 

radioactive material. 

Surface Water and Wetland 

Standards 

15A NCAC 02B, authorized 

by NCGS 143, Article 21, 

Water and Air Resources 

Establishes the rules for the series 

of State classifications and water 

quality standards applicable to 

surface waters and wetlands. 

Waste Not Discharged to 

Surface Waters 

15A NCAC 02T, authorized 

by NCGS 143, Article 21, 

Water and Air Resources, 

and NCGS 130A, Article 11, 

Wastewater Systems 

Establishes the requirements and 

procedures for application and 

issuance of permits for systems 

such as sewer systems, disposal 

systems, and treatment works that 

do not discharge to surface waters 

of the State. 
 

1-23 

Table 1-2 State of North Carolina Environmental Regulations (Cont.) 

Law/Regulation Citation Requirements 

Water Quality Certification 15A NCAC 02H.0500, 

authorized by NCGS 143, 

Article 21, Water and Air 

Resources 

Outlines the application and review 

procedures for activities requiring 

water quality certifications because 

they involve discharges into 

navigable waters. 

Water Use Registration and 

Allocation 

15A NCAC 02E, authorized 

by NCGS 143, Article 21, 

Water and Air Resources 

Establishes the requirements and 

procedures for registering water 

withdrawals above certain 

thresholds and periodic updates of 

the registration. a

 15A = Title; NCAC = North Carolina Administrative Code; 02 = Chapter; D = Subtitle. The number following 

NCGS is the chapter number. 

1 

2 1.5.6.1 Endangered Species Act of 1973 Consultation 

3 

4 The Endangered Species Act was enacted to prevent the further decline of endangered and 

5 threatened species and to restore those species and their critical habitats. Section 7 of the Act 

6 requires consultation with the FWS of the U.S. Department of the Interior or the NMFS of the 

7 U.S. Department of Commerce to determine whether endangered and threatened species or 

8 their critical habitats are known to be in the vicinity of the proposed action, and to determine 

9 whether the proposed Federal action may affect listed species or critical habitat. On May 1, 

10 2009, the NRC staff sent a letter to the FWS Raleigh Field Office describing the proposed action 

11 and requesting a list of threatened and endangered species and critical habitats that could 

12 potentially be affected by the proposed action (NRC, 2009b). A similar letter was sent to the 

13 NMFS Southeast Regional Office (NRC, 2009d). By letter dated June 8, 2009, the FWS 

14 Raleigh Field Office indicated that nine listed species are present in New Hanover County and 

15 that several of the species may occur in the area of the Wilmington Site (FWS, 2009). The FWS 

16 wanted those species to be considered in the draft EIS. By e-mail sent August 3, 2009, the 

17 NMFS sent information on the protected species under its purview that may occur in the area of 

18 the Wilmington Site (NOAA, 2009). 

19 

20 1.5.6.2 National Historic Preservation Act of 1966 Section 106 Consultation 

21 

22 The National Historic Preservation Act was enacted to create a national historic preservation 

23 program, including the National Register of Historic Places (NRHP) and the Advisory Council on 

24 Historic Preservation (ACHP). Section 106 requires Federal agencies to take into account the 

25 effects of their undertakings on historic properties. The ACHP regulations implementing 

26 Section 106 of the Act are found in 36 CFR Part 800. The regulations call for public 

27 involvement in the Section 106 consultation process, including American Indian tribes and other 

28 interested members of the public, as applicable. In response to an April 29, 2009, letter from 

29 the NRC (NRC, 2009a), the North Carolina Department of Cultural Resources confirmed via a 

30 letter dated June 2, 2009, that an archeological site was eligible for listing on the NRHP 

31 (NCDCR, 2009). On September 2, 2009, the NRC sent letters to 16 American Indian tribes 
 

1-24 

Table 1-3 Potentially Applicable Permit and Approval Requirements for the 

Construction and Operation of the Proposed GLE Facility 

License, Permit, or 

Other Required 

Approval 

Responsible 

Agency Authority Relevance and Status 

Federal 

Rules of General 

Applicability to Domestic 

Licensing of By-product 

Material, Domestic 

Licensing of Source 

Material, and Domestic 

Licensing of Special 

Nuclear Material 

NRC 10 CFR Parts 30, 40, and 

70, authorized by the AEA 

The proposed GLE Facility 

must obtain a license to 

possess and use source 

material, special nuclear 

material, and by-product 

material; an application for 

the required license has been 

submitted. 

Section 404 Permit USACE 40 CFR Part 230, 

authorized by the CWA 

The discharge of dredged or 

fill material into the waters of 

the United States will be 

associated with the proposed 

GLE Facility; an application 

for the permit allowing such 

discharge will be made. 

Endangered Species Act 

Consultation 

FWS 50 CFR Part 402, 

authorized by the ESA 

Formal consultation will be 

required if a listed species will 

be affected. 

National Historic 

Preservation Act 

Consultation

ACHP 36 CFR Part 800, 

authorized by the 

National Historic 

Preservation Act 

Consultation regarding 

possible inclusion of a site on 

the NRHP 

State 

Construction and 

Operating Permit 

North Carolina 

Division of Air 

Quality 

15A NCAC 02Q.0300, 

Construction and 

Operation Permits; 

authorized by NCGS 143, 

Article 21B, Air Pollution 

Control 

Air emissions from the 

construction phase of the 

proposed GLE Facility are 

expected to be minimal and 

will not rise to the level of 

meeting the threshold for a 

major source when 

operations commence. 

Application will be made for a 

construction and operating 

permit. 

 
 

1-25 

Table 1-3 Potentially Applicable Permit and Approval Requirements for the 

Construction and Operation of the Proposed GLE Facility (Cont.) 

License, Permit, or 

Other Required 

Approval 

Responsible 

Agency Authority Relevance and Status 

State (Cont.) 

Section 401 Water 

Quality Certification 

North Carolina 

Division of 

Water Quality 

15A NCAC 02H.0500, 

authorized by NCGS 143, 

Article 21, Water and Air 

Resources 

The proposed GLE Facility 

will require a CWA 

Section 404 permit, which is 

dependent on issuance of a 

water quality certification; the 

certification will be sought. 

NPDES Individual 

Permit for Construction 

Stormwater 

Management 

North Carolina 

Division of 

Water Quality 

15A NCAC 2H.0100, 

authorized by NCGS 143, 

Article 21, Water and Air 

Resources 

Stormwater discharge will be 

associated with construction 

of the proposed GLE Facility; 

an application will be made 

for an NPDES permit. 

NPDES Individual 

Permit for Stormwater 

Management 

(Operations) 

North Carolina 

Division of 

Water Quality 

15A NCAC 2H.0100, 

authorized by NCGS 143, 

Article 21, Water and Air 

Resources 

The existing Wilmington Site 

permit, NCS000022, will be 

modified to accommodate 

anticipated increased 

stormwater discharge 

associated with operation of 

the proposed GLE Facility. 

NPDES Individual 

Permit for Industrial and 

Sanitary Waste 

Treatment 

North Carolina 

Division of 

Water Quality 

15A NCAC 02T.0100, 

authorized by NCGS 143, 

Article 21, Water and Air 

Resources 

The existing Wilmington Site 

final process lagoon and 

sanitary wastewater treatment 

facilities will be used to 

process wastewater and 

sanitary wastewater from the 

proposed GLE Facility. The 

existing Wilmington Site 

permit, NC0001228, will be 

modified. 

Isolated Wetlands 

Permit 

North Carolina 

Division of 

Water Quality 

15 NAC 02H.1300, 

authorized by NCGS 143, 

Article 21, Water and Air 

Resources 

A permit will be requested if 

impacts on isolated wetlands 

will result from construction or 

operations as apparent from 

the final facility design. 

Hazardous Waste 

Generator Identification 

Number 

North Carolina 

Division of 

Waste 

Management 

15A NCAC 13A.0107(a), 

authorized by 

NCGS 130A, Article 9, 

Solid Waste Management 

The proposed GLE Facility 

will produce hazardous waste 

at volumes requiring a 

generator identification 

number; application for the 

number will be made. 
 

1-26 

Table 1-3 Potentially Applicable Permit and Approval Requirements for the 

Construction and Operation of the Proposed GLE Facility (Cont.) 

License, Permit, or 

Other Required 

Approval 

Responsible 

Agency Authority Relevance and Status 

State (Cont.) 

Radioactive Materials 

License 

North Carolina 

Radioactive 

Materials 

Branch 

15A NCAC 11, authorized 

by NCGS 104E, North 

Carolina Radiation 

Protection Act

The use of radioactive 

materials at the proposed 

GLE Facility will require a 

license from the State; the 

license will be requested. 

Coastal Area 

Management Act Permit 

North Carolina 

Division of 

Coastal 

Management 

15A NCAC 7, authorized 

by NCGS 113A, Article 7, 

Coastal Area 

Management 

A preliminary review revealed 

that a coastal area 

management permit was not 

necessary; however, the 

project could be subject to 

additional review and a 

possible permit depending on 

the status of the USACEgranted Section 404 permit. 

Driveway and Right-ofWay Permits North Carolina 

Department of 

Transportation

19A NCAC 02B.0602, 

authorized by NCGS 136, 

Article 6D, Controlled 

Access Facilities 

An entrance off NC 133 

(Castle Hayne road) to the 

proposed GLE Facility is 

planned requiring a driveway 

permit; the permit will be 

requested. 

Local Agencies 

Tree Removal Permit or 

Letter of Exemption 

New Hanover 

County 

Zoning Ordinance, 

Article VI, Supplementary 

District Regulations 

If the final design for the 

proposed GLE Facility 

requires the removal of 

significant or regulated trees, 

a tree removal permit or a 

letter of exemption from the 

County Zoning Administrator 

will be required; if required, it 

will be requested. 

Land-Disturbing Permit New Hanover 

County 

Chapter 23, Article VI, 

Erosion and 

Sedimentation 

The proposed GLE Facility 

will disturb more than 

0.4 hectare (1 acre) of land, 

thereby triggering the need 

for an approved erosion and 

sedimentation control plan 

and permit; a permit will be 

requested. 
 

1-27 

Table 1-3 Potentially Applicable Permit and Approval Requirements for the 

Construction and Operation of the Proposed GLE Facility (Cont.) 

License, Permit, or 

Other Required 

Approval 

Responsible 

Agency Authority Relevance and Status 

Local Agencies (Cont.) 

Stormwater Permit New Hanover 

County 

Chapter 23, Article VII, 

Stormwater Management 

The proposed GLE Facility 

must comply with the county 

stormwater ordinance; the 

permit will be requested. 

Floodplain Development 

Permit 

New Hanover 

County 

Chapter 29, Article II, 

Flood Hazard Reduction 

If the final facility design 

includes development of the 

proposed GLE Facility within 

areas of special flood hazard 

lying within the regulatory 

jurisdiction of the county, a 

permit may be required. 

1 

2 inquiring if the tribes believed the site under consideration had any traditional cultural or 

3 religious significance (see Section 9.2 for a list of the tribes that were contacted, and 

4 Appendix B for copies of the communications). None of the tribes indicated that they had any 

5 concerns. Consultation between the NRC and the North Carolina State Historic Preservation 

6 Office (SHPO) has been ongoing. At the request of the SHPO, the NRC has contacted the 

7 ACHP concerning the GLE project. 

8 

9 1.5.6.3 Fish and Wildlife Coordination Act of 1934

10 

11 The consultation component of the Fish and Wildlife Coordination Act requires that “whenever 

12 the waters of any stream or other body of water are proposed or authorized to be impounded, 

13 diverted, the channel deepened, or the stream or other body of water otherwise controlled or 

14 modified for any purpose whatever, including navigation and drainage, by any department or 

15 agency of the United States, or by any public or private agency under Federal permit or license, 

16 such department or agency first shall consult with the U.S. Fish and Wildlife Service, 

17 Department of the Interior, and with the head of the agency exercising administration over the 

18 wildlife resources of the particular State wherein the impoundment, diversion, or other control 

19 facility is to be constructed, with a view to the conservation of wildlife resources by preventing 

20 loss of and damage to such resources as well as providing for the development and 

21 improvement thereof in connection with such water-resource development.” Because the 

22 proposed action does not involve such modifications to a stream or other body of water, the 

23 NRC is not implementing consultations under the Fish and Wildlife Coordination Act. The NRC 

24 is consulting with the FWS and the State agency that exercises administrative control over the 

25 wildlife resources under the ESA as noted in Section 1.5.6.1. 

26 

27 1.6 Organizations Involved in the Proposed Action 

28 

29 Two organizations have specific roles in the implementation of the proposed action: 
 

1-28 

1 GE-Hitachi Global Laser Enrichment LLC (abbreviated as GLE for the purposes of this draft 

2 EIS) is the NRC license applicant. If the license is granted, GLE would be the holder of an NRC 

3 license for the possession and use of special nuclear, source, and by-product material at the 

4 proposed GLE Facility. GLE would be responsible for constructing, operating, and 

5 decommissioning the proposed facility in compliance with that license and applicable NRC 

6 regulations. 

7 

8 GLE is a Delaware limited liability company. It currently is the only subsidiary of majority owner 

9 GE-Hitachi (GEH) Nuclear Energy Americas, LLC, a global supplier of nuclear energy-related 

10 equipment and services. GEH, also a Delaware limited liability company, is a wholly owned 

11 subsidiary of GE-Hitachi Nuclear Energy Holdings LLC (Holdings). Holdings is a subsidiary of 

12 majority owner GENE Holding LLC (GENE), a Delaware limited liability company wholly owned 

13 by GE, a U.S. corporation, and of minority owner Hitachi America, Ltd., which is a wholly owned 

14 subsidiary of Hitachi Ltd., a Japanese corporation. Cameco Enrichment Holdings, LLC 

15 (“Cameco Enrichment”), has a 24 percent ownership interest in GLE, and GENE owns 

16 13.5 percent of GLE. Cameco Enrichment is a Delaware limited liability company wholly owned 

17 by Cameco U.S. Holdings, Inc., a Nevada corporation, which is in turn wholly owned by Cameco 

18 Corporation, a Canadian corporation (GLE, 2009a). The foreign ownership, control, and 

19 influence issue is beyond the scope of this EIS but will be addressed by the NRC. 

20 

21 The NRC is the licensing agency. The NRC has the responsibility to evaluate the license 

22 application for compliance with the NRC regulations associated with uranium enrichment 

23 facilities. These include standards for protection against radiation in 10 CFR Part 20 and 

24 requirements in 10 CFR Parts 70, 40, and 30 that would authorize GLE to possess and use 

25 special nuclear material, source material, and by-product material, respectively, at the proposed 

26 GLE Facility. The NRC is responsible for regulating activities performed within the proposed 

27 GLE Facility through its licensing review process and subsequent inspection program. To fulfill 

28 the NRC responsibilities under NEPA, the environmental impacts of the proposed action are 

29 evaluated in accordance with the requirements of 10 CFR Part 51 and documented in this 

30 draft EIS. 

31 

32 1.7 References 

33 

34 (AES, 2008) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility, 

35 Application for a Uranium Enrichment Facility License under 10 CFR 70, ‘Domestic Licensing 

36 of Special Nuclear Material.’” December. NRC ADAMS Accession No. ML090300656. 

37 

38 (AES, 2009) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

39 Environmental Report.” December. 

40 

41 (Bellemare, 2003) Bellemare, B. “What Is a Megawatt?” UtiliPoint International Inc. June 24. 

42 <http://www.utilipoint.com/issuealert/article.asp?id=1728> (Accessed August 21, 2009). 

43 

44 (DOE, 2001) U.S. Department of Energy. “Effect of U.S./Russia Highly Enriched Uranium 

45 Agreement.” Report to Congress. Washington, D.C. December. <http://www.ne.doe.gov/ 

46 pdfFiles/HEUAgreement2001.pdf> (Accessed March 29, 2009). 

47 
 

1-29 

1 (DOE, 2002) U.S. Department of Energy. Letter from W.J. Magwood, IV (U.S. Department of 

2 Energy) to M.J. Virgilio (U.S. Nuclear Regulatory Commission), dated July 25. “Subject: DOE 

3 Comments on General Policy Issues Raised by Louisiana Energy Services (LES) in Preparation 

4 for Enrichment Plant License Application.” ADAMS Accession No. ML022350130. 

5 

6 (DOE, 2007) U.S. Department of Energy. “Uranium Enrichment Decontamination & 

7 Decommissioning Fund 2007 Report to Congress.” Washington, D.C. 

8 

9 (DOE, 2010a) U.S. Department of Energy. “Portsmouth Plant History.” Portsmouth/Paducah 

10 Project Office. January. <http://www.pppo.energy.gov/port_history.html> (Accessed 

11 January 28, 2010). 

12 

13 (DOE, 2010b) U.S. Department of Energy. “U.S.-Russian Highly Enriched Uranium 

14 Purchase Agreement.” National Nuclear Security Administration. January. 

15 <http://www.nnsa.energy.gov/nuclear_nonproliferation/highly_enriched_uranium_disposition.ht

16 m> (Accessed January 28, 2010). 

17 

18 (EIA, 2003) Energy Information Administration, U.S. Department of Energy. “U.S. Nuclear Fuel 

19 Cycle Projections 2000-2025.” January. <http://www.eia.doe.gov/cneaf/nuclear/page/forecast/ 

20 projection.html> (Accessed March 23, 2009). 

21 

22 (EIA, 2008) Energy Information Administration, U.S. Department of Energy. “2007 Uranium 

23 Marketing Annual Report.” May. <http://tonto.eia.doe.gov/FTPROOT/nuclear/umar2007.pdf> 

24 (Accessed March 26, 2009). 

25 

26 (EIA, 2009a) Energy Information Administration, U.S. Department of Energy. “Annual Energy 

27 Outlook 2009 with Projections to 2030.” March. <http://www.eia.doe.gov/oiaf/archive/ 

28 aeo09/pdf/0383(2009).pdf> (Accessed August 21, 2009). 

29 

30 (EIA, 2009b) Energy Information Administration, U.S. Department of Energy. “Uranium 

31 Marketing Annual Report 2008.” May 26. <http://tonto.eia.doe.gov/FTPROOT/nuclear/ 

32 umar2008.pdf> (Accessed February 5, 2010). 

33 

34 (FWS, 2009) U.S. Fish and Wildlife Service. Letter from H. Hall (U.S. Fish and Wildlife Service) 

35 to A. Kock (U.S. Nuclear Regulatory Commission) dated June 8. “Subject: Docket No. 70-7016; 

36 General Electric-Hitachi Global Laser Enrichment Facility, New Hanover County, North 

37 Carolina.” ADAMS Accession No. ML091700024. 

38 

39 (GLE, 2008a) GE-Hitachi Global Laser Enrichment LLC. “Environmental Report for the 

40 GLE Commercial Facility, Revision 0.” December. ADAMS Accession No. ML090910573. 

41 

42 (GLE, 2008b) GE-Hitachi Global Laser Enrichment LLC. Letter from T.G. Orr (GE-Hitachi 

43 Global Laser Enrichment LLC) to M. Weber (U.S. Nuclear Regulatory Commission) dated 

44 December 8. “Subject: Request for Exemption from 10 CFR §§70.4 and 70.23(a)(7) 

45 Requirements Governing ‘Commencement of Construction.” ADAMS Accession 

46 No. ML090350201. 

47 
 

1-30 

1 (GLE, 2009a) GE-Hitachi Global Laser Enrichment LLC. Letter from T.G. Orr (GE-Hitachi 

2 Global Laser Enrichment LLC) to M. Weber (U.S. Nuclear Regulatory Commission) dated 

3 June 26. “Subject: GE-Hitachi Global Laser Enrichment LLC License Application Submittal.” 

4 ADAMS Accession No. ML091870998. 

5 

6 (GLE, 2009b) GE-Hitachi Global Laser Enrichment LLC. “Global Laser Enrichment 

7 Environmental Report Supplement 1 – Early Construction.” July. ADAMS Accession 

8 No. ML092100528. 

9 

10 (GLE, 2009c) GE-Hitachi Global Laser Enrichment LLC. “Global Laser Enrichment 

11 Environmental Report Supplement 2.” November. ADAMS Accession No. ML093240935. 

12 

13 (GLE, 2009d) GE-Hitachi Global Laser Enrichment LLC. Letter from A. Kennedy (GE-Hitachi 

14 Global Laser Enrichment LLC) to A. Kock (U.S. Nuclear Regulatory Commission) dated 

15 November 5. “Subject: GE-Hitachi Global Laser Enrichment Response to Request for 

16 Additional Information Related to NRC Review of GLE Environmental Report.” ADAMS 

17 Accession No. ML093170517. 

18 

19 (GLE, 2009e) GE-Hitachi Global Laser Enrichment LLC. Letter from A. Kennedy (GE-Hitachi 

20 Global Laser Enrichment LLC) to A. Kock (U.S. Nuclear Regulatory Commission) dated 

21 November 5. “Subject: GE-Hitachi Global Laser Enrichment Response to Request for 

22 Additional Information (Security-Related Information) Related to NRC Review of GLE 

23 Environmental Report.” ADAMS Accession No. ML093200138. 

24 

25 (GLE, 2009f) GE-Hitachi Global Laser Enrichment LLC. Letter from A. Kennedy (GE-Hitachi 

26 Global Laser Enrichment LLC) to A. Kock (U.S. Nuclear Regulatory Commission) dated 

27 November 11. “Subject: GE-Hitachi Global Laser Enrichment Response (#2) to Request for 

28 Additional Information Related to NRC Review of GLE Environmental Report.” ADAMS 

29 Accession No. ML093220060. 

30 

31 (GLE, 2009g) GE-Hitachi Global Laser Enrichment LLC. Letter from A. Kennedy (GE-Hitachi 

32 Global Laser Enrichment LLC) to A. Kock (U.S. Nuclear Regulatory Commission) dated 

33 November 11. “Subject: GE-Hitachi Global Laser Enrichment Response (#2 Proprietary 

34 Information) to Request for Additional Information Related to NRC Review of GLE 

35 Environmental Report.” ADAMS Accession No. ML093220067. 

36 

37 (GLE, 2009h) GE-Hitachi Global Laser Enrichment LLC. Letter from J. Olivier (GE-Hitachi 

38 Global Laser Enrichment LLC) to J. Davis (U.S. Nuclear Regulatory Commission) dated 

39 November 23. “Subject: Submittal of Corrected Response to RAI 4-1-A.” ADAMS Accession 

40 No. ML093270378. 

41 

42 (GLE, 2009i) GE-Hitachi Global Laser Enrichment LLC. Letter from J. Olivier (GE-Hitachi 

43 Global Laser Enrichment LLC) to A. Kock (U.S. Nuclear Regulatory Commission) dated 

44 November 24. “Subject: Submittal of Air Quality Responses from October 7, 2009 Request for 

45 Additional Information.” ADAMS Accession Nos. ML093280887 and ML093280889. 

46 
 

1-31 

1 (GLE, 2009j) GE-Hitachi Global Laser Enrichment LLC. Letter from A.E. Kennedy (GE-Hitachi 

2 Global Laser Enrichment LLC) to B. Smith (U.S. Nuclear Regulatory Commission) dated 

3 December 28. “Subject: Response to Request for Additional Information Dated November 19, 

4 2009 for Global Laser Enrichment License Application – Public Responses.” ADAMS Accession 

5 Nos. ML093620823 and ML093620841. 

6 

7 (NRC, 2003) U.S. Nuclear Regulatory Commission. “Environmental Review Guidance for 

8 Licensing Action Associated with NM55 Programs.” NUREG-1748. August. 

9 <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1748/sr1748.pdf> 

10 (Accessed January 29, 2010). 

11 

12 (NRC, 2005) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for the 

13 Proposed National Enrichment Facility in Lea County, New Mexico.” NUREG-1790. June. 

14 <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1790/> (Accessed March 26, 

15 2009). 

16 

17 (NRC, 2006) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for the 

18 Proposed American Centrifuge Plant in Piketon, Ohio.” NUREG-1834. April. 

19 <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1834/> (Accessed March 26, 

20 2009). 

21 

22 (NRC, 2008) U.S. Nuclear Regulatory Commission. “Typical Stages of the Nuclear Fuel Cycle.” 

23 November 21. <http://www.nrc.gov/materials/fuel-cycle-fac/stages-fuel-cycle.html> (Accessed 

24 August 18, 2009). 

25 

26 (NRC, 2009a) U.S. Nuclear Regulatory Commission. Letter from A. Kock (U.S. Nuclear 

27 Regulatory Commission) to P. Sandbeck (North Carolina State Historic Preservation Office) 

28 dated April 29. “Subject: Initiation of the National Historic Preservation Act Section 106 Process 

29 for General Electric-Hitachi Global Laser Enrichment Uranium Enrichment Facility (State 

30 Historic Preservation Office Tracking Number ER 07-2157).” ADAMS Accession 

31 No. ML91100104. 

32 

33 (NRC, 2009b) U.S. Nuclear Regulatory Commission. Letter from A. Kock (U.S. Nuclear 

34 Regulatory Commission) to P. Benjamin (U.S. Fish and Wildlife Service, Raleigh Field Office) 

35 dated May 1. “Subject: Request for Information Regarding Endangered Species and Critical 

36 Habitats for General Electric-Hitachi Global Laser Enrichment Proposed Uranium Enrichment 

37 Facility in New Hanover County, North Carolina.” ADAMS Accession No. ML091100107. 

38 

39 (NRC, 2009c) U.S. Nuclear Regulatory Commission. Letter from D.H. Dorman (U.S. Nuclear 

40 Regulatory Commission) to A.E. Kennedy (GE-Hitachi Global Laser Enrichment LLC) dated 

41 May 8. “Subject: Approval of GE-Hitachi Exemption Request Related to Commencement of 

42 Construction.” ADAMS Accession No. ML083510647. 

43 

44 (NRC, 2009d) U.S. Nuclear Regulatory Commission. Letter from A. Kock (U.S. Nuclear 

45 Regulatory Commission) to D. Bernhart (National Oceanic and Atmospheric Administration 

46 Fisheries) dated June 18. “Subject: Request for Information Regarding Endangered or 

47 Threatened Species and Critical Habitat Relevant to the Proposed General Electric-Hitachi 

48 Global Laser Enrichment (GLE) Commercial Facility.” ADAMS Accession No. ML091660481. 
 

1-32 

1 (NOAA, 2009) National Oceanic and Atmospheric Administration, National Marine Fisheries 

2 Service. E-mail from A. Herndon (National Marine Fisheries Service) to A. Kock (U.S. Nuclear 

3 Regulatory Commission) dated August 3. “NOAA Fisheries Protected Species Information.” 

4 ADAMS Accession No. ML092170775. 

5 

6 (Urenco, 2008) URENCO. “National Enrichment Facility expansion.” Press Release. 

7 December 12. <http://www.urenco.com/content/169/National-Enrichment-Facility8 expansion.aspx> (Accessed February 1, 2010). 

9 

10 (USEC, 2010) USEC, Inc. “Annual Report Pursuant to Section 13 or 15(d) of the Securities 

11 Exchange act of 1934 for the Fiscal Year Ended December 31, 2009.” March 1. 

12 <http://phx.corporate-ir.net/External.File?item= 

13 UGFyZW50SUQ9MzcxMTE0fENoaWxkSUQ9MzY4MDY0fFR5cGU9MQ==&t=1> (Accessed 

14 June 4, 2010).
2-1 

1 2 ALTERNATIVES 

2 

3 This chapter describes and compares the proposed action and alternatives. As discussed in 

4 Chapter 1, the proposed action is for General Electric (GE)-Hitachi Global Laser Enrichment, 

5 LLC (GLE) to construct and operate a laser-based uranium enrichment facility near Wilmington, 

6 North Carolina. To allow the proposed action, the U.S. Nuclear Regulatory Commission (NRC) 

7 would need to grant GLE a license to possess and use special nuclear material, source 

8 material, and byproduct material at the proposed Global Laser Enrichment Facility. The NRC 

9 staff also evaluated the no-action alternative in this draft EIS. Under the no-action alternative, 

10 GLE would not construct, operate, or decommission the proposed GLE Facility. Therefore, the 

11 no-action alternative provides a basis for evaluating and comparing the potential impacts of the 

12 proposed action. In addition to the proposed action and alternatives to the proposed action, 

13 alternatives for the disposition of depleted uranium hexafluoride (UF6) resulting from enrichment 

14 operations over the lifetime of the proposed GLE Facility are analyzed. 

15 

16 Section 2.1 presents technical details of the proposed action and connected actions, including 

17 descriptions of the proposed site, laser enrichment technology, facilities to be constructed, and 

18 the activities at the proposed GLE Facility. The activities are grouped under preconstruction 

19 and construction, operation, and decontamination and decommissioning. Section 2.2 describes 

20 the no-action alternative and provides a comparison of predicted environmental impacts for the 

21 proposed action and no-action alternatives. Section 2.3 discusses alternatives to the proposed 

22 action that were considered but not analyzed in detail, including alternative sites, enrichment 

23 technologies other than the proposed laser technology, and use of alternate sources of enriched 

24 uranium. Gas centrifuge technology is discussed in Section 2.3.4, along with a comparison of 

25 the potential impacts of the laser-based and gas centrifuge technologies. The chapter 

26 concludes with a preliminary recommendation from NRC staff regarding the proposed action 

27 (Section 2.4). 

28 

29 2.1 Proposed Action 

30 

31 The proposed action is for GLE to construct and operate a laser-based uranium enrichment 

32 facility near Wilmington, North Carolina. To allow the proposed action, NRC would need to 

33 grant GLE a license to possess and use special nuclear material, source material, and 

34 byproduct material. The initial NRC license, if granted, would be for a period of 40 years, after 

35 which GLE would request renewal of the license or begin decommissioning of the facility. GLE 

36 plans to start preconstruction activities for the proposed GLE Facility in early 2011, under an 

37 exemption granted by NRC (see Section 1.4.1). If NRC grants the license, GLE would begin 

38 construction of the proposed GLE Facility (anticipated in 2012), commence commercial 

39 enrichment operations in 2013, and increase to the initial maximum target production capacity of 

6 million separative work units1 40 (SWU) by 2017, at an enrichment of up to 8 percent 

 

1

 A separative work unit (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. Given 100 kilograms (220 pounds) of natural uranium, it takes about 60 SWU 

to produce 10 kilograms (22 pounds) of uranium enriched to 4.5 percent uranium-235. It takes on the 

order of 100,000 SWU of enriched uranium to fuel a typical 1000-megawatt commercial nuclear 

reactor for a year (USEC, 2001). 
2-2 

1 uranium-235 by weight. Although there is currently no demand for enrichment greater than 

2 5 percent, GLE believes that there is potential for future demand to change (GLE, 2009c). 

3 

4 Section 2.1.1 describes the location of the proposed site. The proposed facility and GLE’s 

5 laser-based enrichment process are described in Section 2.1.2 and the management options for 

6 management of the depleted UF6 tails generated at the proposed facility are reviewed in 

7 Section 2.1.3. Section 2.1.4 describes the anticipated decontamination and decommissioning 

8 activities at the proposed facility and Section 2.1.5 provides the projected timelines for the three 

9 phases of the proposed action. 

10 

11 2.1.1 Location and Description of Proposed Site 

12 

13 The GE property, on which the proposed GLE Facility would be sited, is located in an 

14 unincorporated area of New Hanover County, North Carolina, the most populated of three 

15 counties that comprise the Wilmington Metropolitan Statistical Area. The site is located 

16 approximately 10 kilometers (6 miles) north of Wilmington, North Carolina, and is hereafter 

17 referred to as the Wilmington Site. Figures 1-1 and 1-2 show the location of the Wilmington Site 

18 in relation to the surrounding counties and municipalities. 

19 

20 The Wilmington Site consists of approximately 656 hectares (1621 acres), and GE owns an 

21 additional 10 hectares (24 acres) to the east of the site. Figure 2-1 shows the Wilmington Site 

22 and the location of GE’s existing principal manufacturing facilities (namely, the Global Nuclear 

23 Fuels-Americas [GNF-A] Fuel Manufacturing Operation [FMO] facility and the GE Aircraft 

24 Engines/Services Components Operation [AE/SCO] facility). The land to the west of the 

25 Wilmington Site (across the Northeast Cape Fear River) is dominated by industrial use, and the 

26 area to the north and northwest is privately owned and used for timber management and private 

27 hunting. The areas to east and south of the site are dominated by residential development. 

28 The southeast corner of the site borders Interstate 140 (I-140) (GLE, 2008). 

29 

30 The proposed GLE Facility would occupy approximately 40 hectares (100 acres) of the North31 Central Site Sector. A North access road would be built along the northeast portion of the 

32 Eastern Site Sector to connect the proposed GLE Facility to NC Route 133, using existing site 

33 road service where practical (Figure 2-2). 

34 

35 The nearest major population center is Skippers Corner, approximately 1 kilometer (0.6 mile) 

36 northeast of the site boundary on NC Route 133 (Castle Hayne Road). The distance from the 

37 proposed GLE Facility to the nearest member of the public (i.e., actual permanent residence) is 

38 about 1352 meters (0.84 mile). The environmental characteristics of the proposed site and 

39 surrounding areas are described in detail in Chapter 3 of this draft EIS. 

40 

41 The Wilmington Site is served by two of southeastern North Carolina’s major highway systems: 

42 Interstate 40 (I-40) (“Outer Loop Freeway”) and U.S. Route 17 (see Figure 1-2). The site can be 

43 accessed by two access roads (south access road and north access road) from Castle Hayne 

44 Road (NC Route 133) just north of the junction of I-140 and Castle Hayne Road (GLE, 2008). 

45 
2-3 

1 

2 Figure 2-1 Schematic of the Existing Wilmington Site (GLE, 2008) 

3 

4 The Wilmington Site does not have rail access (and GLE does not anticipate the use of freight 

5 rail for shipping needs), but freight service to the region is provided by CSX Transportation, Inc.; 

6 the primary rail service foci are the Port of Wilmington and Military Ocean Terminal Sunny Point 

7 (MOTSU). 

8 

9 2.1.2 Description of the Proposed GLE Facility 

10 

11 Figure 2-2 shows the location of the GLE study area, which includes the proposed GLE Facility 

12 site and the areas that would be disturbed by preconstruction and construction activities. The 

13 proposed facility would comprise various buildings and areas that house systems and 

14 equipment necessary to support the uranium enrichment process. These buildings and areas 

15 would include the operations building and UF6 storage areas. UF6 would be stored temporarily 

16 onsite as normal feed material to the enrichment process and as depleted UF6 and enriched 

17 product UF6 after the enrichment process. There would be other ancillary and support buildings 

18 and areas onsite. 

19 

20 Primary facilities are those critical to the enrichment process, while secondary facilities provide 

21 indirect support to the process. These facilities are described in Sections 2.1.2.1 and 2.1.2.2, 

22 respectively. These sections are followed by summary descriptions of the laser-based 
2-4 

1 

2 Figure 2-2 Location of Proposed GLE Facility at the Wilmington Site (GLE, 2009b) 

3 

4 enrichment process proposed by GLE (Section 2.1.2.3), Waste Management Systems 

5 (Section 2.1.2.4), and Liquid and Air Effluents (Section 2.1.2.5). 

6 

7 2.1.2.1 Primary Facilities 

8 

9 The primary facilities include an operations building and six cylinder storage pads where 

10 licensed material would be used or stored; these are considered to be key facilities in support of 

11 the uranium enrichment process. The primary facilities are located or would be constructed 

12 adjacent to each other in the North-Central Site Sector. Technical details regarding primary 

13 facilities are presented in Appendix H. This information is considered proprietary and contains 

14 security-related information and will not be disclosed in this draft EIS. 

15 

16 Operations Building

17 

18 The primary purpose of the operations building would be to house the laser equipment and 

19 support systems necessary to perform the actual enrichment process. The Operations Building 

20 would include the following process and support areas:

21 

22 • Cylinder Shipping and Receiving Area 

23 
2-5 

1 • UF6 Feed and Vaporization Area 

2 

3 • Product Withdrawal Area 

4 

5 • Tails Withdrawal Area 

6 

7 • Cascade/Gas Handling Area 

8 

9 • Blending Area 

10 

11 • Sampling Area 

12 

13 • Radioactive Waste Area 

14 

15 • Heating, Ventilation, and Air Conditioning (HVAC) Equipment Area 

16 

17 • Decontamination/Maintenance Area 

18 

19 • Laboratory Area 

20 

21 • Laser Area 

22 

23 The functional descriptions of these areas are summarized below, based on the information 

24 provided in Chapter 1 of the License Application (GLE, 2009a). 

25 

26 Cylinder Shipping and Receiving Area

27 

28 The operations performed in this area would include: 

29 

30 • receipt of feed UF6 cylinders from offsite 

31 

32 • weighing the feed cylinders and performing other material control functions 

33 

34 • providing interim storage of feed, product, and depleted UF6 cylinders 

35 

36 • preparing the product and full depleted UF6, and empty cylinders for transfer to other 

37 locations onsite such as the UF6 Cylinder Pads or offsite 

38 

39 Feed and Vaporization Area

40 

41 The UF6 Feed and Vaporization Area would contain the necessary equipment to perform the 

42 following operations: 

43 

44 • receive UF6 feed cylinders from the Cylinder Shipping and Receiving Area 

45 

46 • vaporize the UF6 contained within the feed cylinders 

47 
2-6 

1 • feed the vaporized UF6 to the feed header between the Vaporization Area and 

2 the Cascade/Gas Handling Area within the Operations Building 

3 

4 The UF6 feed rates to the feed header would be maintained within the design basis temperature 

5 and pressure range. The residual UF6 from the emptied feed cylinders (known as heels) would 

6 be sufficiently recovered to meet U.S. Department of Transportation (DOT) offsite cylinder 

7 shipping requirements for empty cylinders. 

8 

9 Product Withdrawal Area

10 

11 In the Product Withdrawal Area, the empty to-be-filled cylinders would be received from interim 

12 storage within the Cylinder Shipping and Receipt Area and would be filled with the enriched UF6

13 product. 

14 

15 Tails Withdrawal Area

16 

17 This area would be used to receive empty cylinders from interim storage within the Cylinder 

18 Shipping and Storage Area, and fill them with the tails (depleted UF6) for interim storage and 

19 later disposition. 

20 

21 Cascade/Gas Handling Area

22 

23 The Cascade/Gas Handling Area is where the enrichment process would occur. The UF6 gas 

24 would be exposed to laser-emitted light and two process streams are generated; one enriched 

25 in uranium-235 and one depleted in uranium-235. The enriched stream would go to the Product 

26 Withdrawal Area and the depleted stream would be sent to the Tails Withdrawal Area. 

27 

28 Blending Area

29 

30 The Blending Area is where the product cylinders that meet the customer specifications would 

31 be filled. This would be accomplished by mixing the right quantities of enriched product at 

32 different enrichment levels to produce the exact enrichment level required by customers. The 

33 76- or 122-centimeter (30- or 48-inch) cylinders that would contain the original product (called 

34 donor cylinders) would be received from interim storage within the Cylinder Shipping and 

35 Receiving Area. The UF6 within the donor cylinders would be vaporized and fed into the 

36 receiver cylinders that would be sent to customers. 

37 

38 Sampling Area

39 

40 In the Sampling Area, the receiver cylinders would be sampled to assure that the enrichment 

41 level of UF6 in the filled cylinders meets the customer specifications. The cylinders would be 

42 heated and the UF6 would be liquefied before samples were taken. This would be the only 

43 place in the proposed GLE Facility where conversion of solid UF6 to liquid UF6 would take place. 

44 

45 Liquid and Solid Radioactive Waste Areas

46 

47 The various processes and operations that would take place in the proposed GLE Facility would 

48 likely generate quantities of radiologically contaminated, potentially contaminated, and 
2-7 

1 non-contaminated liquid and solid waste streams. The equipment and processes used to 

2 temporarily store, treat as appropriate, and prepare for offsite shipment of liquid and solid 

3 wastes are described in Section 2.1.2.4. Section 2.1.2.5 discusses the systems used to control 

4 liquid emissions from the proposed GLE Facility. 

5 

6 HVAC Equipment Areas

7 

8 Various heating and ventilation systems throughout the operations building would be used to 

9 control the environmental conditions such as the pressure, temperature, humidity, and airflow in 

10 different parts of the building to meet requirements for personnel, process equipment, and 

11 supporting systems and utilities. The systems used to control atmospheric air emissions are 

12 discussed in Section 2.1.2.5. 

13 

14 Decontamination/Maintenance Area

15 

16 The Decontamination/Maintenance Area would provide a place for personnel to remove 

17 contamination from, and make repairs to, equipment and process components used in various 

18 parts of the GLE Facility. 

19 

20 Laboratory Area

21 

22 The Laboratory Area would contain the various onsite laboratories used to analyze the samples 

23 taken at the proposed GLE Facility. The analyses performed would include wet chemistry and 

24 safety and regulatory testing and analysis. 

25 

26 Laser Area

27 

28 All necessary equipment needed to operate the laser systems that are part of the GLE laser29 based enrichment technology would be located in this area. 

30 

31 UF6 Cylinder Pads

32 

33 There would be three UF6 Cylinder Pads at the proposed GLE Facility: 

34 

35 • The Product Pad, which would occupy approximately 4462 square meters (48,000 square 

36 feet) and be used to store enriched product in 76-centimeter (30-inch) cylinders. 

37 

38 • The In-Process Pad, which would occupy approximately 12,084 square meters 

39 (130,000 square feet) and be used to store feed material and cylinders emptied on site (with 

40 or without heels). 

41 

42 • The Tails Pad, which would occupy approximately 43,224 square meters (465,000 square 

43 feet) and be designed to store 122-centimeter (48-inch) cylinders containing tails (depleted 

44 UF6). This pad would be sized to accommodate the tails cylinders resulting from ten years 

45 of facility operation (9000 cylinders). 

46 

47 All of the pads would be constructed to provide for rainwater drainage to the edges of the pads. 

48 Saddles would be used to store the cylinders and, except for the tails cylinders, the cylinders 
2-8 

1 would not typically be stacked. Stormwater collected from the cylinder pads would be directed 

2 to a new holding pond specifically constructed for the cylinder pads and then to a new onsite 

3 wet detention basin. 

4 

5 2.1.2.2 Other Facility Buildings and Supporting Infrastructure 

6 

7 New facility buildings and supporting infrastructure would include three administrative buildings, 

8 waste storage buildings, an electrical substation, backup diesel generators, potable and process 

9 water systems, a holding pond for cylinder storage pad stormwater, a stormwater wet detention 

10 basin, parking areas, and roads. 

11 

12 The new potable and process water supply lines to the GLE Facility would be connected to the 

13 existing Wilmington Site water supply infrastructure. Sanitary waste, process wastewater, and 

14 treated liquid radiological wastewater that would be generated at the proposed GLE Commercial 

15 Facility would be routed to the existing facilities at the Wilmington Site via underground lines for 

16 final processing and disposition. In particular, the sanitary wastewaters would be routed to the 

17 existing Site Sanitary Waste Water Treatment Facility, and the process and treated wastewaters 

18 would be sent to the existing Final Process Lagoon Treatment Facility. 

19 

20 Two detention basins (one new and one existing) would receive stormwater runoff from the GLE 

21 Facility. An existing collection basin on the Wilmington Site would receive the majority of the 

22 runoff from the GLE Facility, including the Operations Building. The remaining runoff, including 

23 runoff from the UF6 Cylinder Pads, would drain to a new GLE site wet detention basin. 

24 

25 In addition, there would be a new water tower and a firewater retention basin located on the 

26 proposed GLE Facility site. The water in the tower would be used for process water at the 

27 proposed GLE Facility, but it would be designed to always maintain a reserved level for 

28 firefighting. The firewater retention basin and associated diesel-powered firewater pumps would 

29 be designed as a backup source for fire protection systems. 

30 

31 The proposed GLE Facility would be served by two main roads on the Wilmington Site. The first 

32 road would connect the proposed GLE Facility to Castle Hayne Road and would serve as the 

33 main entrance to the facility. The other road would lead to the GNF-A Fuel Manufacturing 

34 Operation (FMO) Facility and would be used mainly for transport of enriched product to the 

35 FMO facility for fuel manufacturing. 

36 

37 2.1.2.3 Process Description 

38 

39 The proposed GLE Facility would employ the Separation of Isotopes by Laser Excitation 

40 (SILEX) process, a third-generation laser-based technology for enriching natural uranium that 

41 was developed by Silex Systems Ltd, in partnership with GLE (and formerly, the 

42 U.S. Enrichment Corporation [USEC]). Isotopes of the same element, though chemically 

43 identical, have different electronic energies and absorb different colors of laser light. The 

44 isotopes of most elements can be separated by a laser-based process if they can be vaporized 

45 efficiently into individual atoms. In laser excitation enrichment, UF6 vapor is illuminated with a 

46 tuned laser of a specific wavelength that is absorbed only by uranium-235 atoms while leaving 

47 other isotopes unaffected. 

48 
2-9 

1 Given below is an overview of the GLE laser-based enrichment process. A more detailed 

2 description of the process is provided in the license application (GLE, 2009a). However, the 

3 technical details of the GLE laser-based enrichment process are proprietary, subject to export 

4 control, and in many cases, may also fall into the categories of security-related, safeguards, or 

5 classified information, to which access is limited by U.S. laws and regulations. As such, the 

6 details of this process are not contained in this draft EIS. 

7 

8 The proposed GLE Facility is designed to separate a feed stream of UF6 containing the naturally 

9 occurring proportions of uranium isotopes (approximately 0.7 percent uranium-235, 99.3 percent 

10 uranium-238, and 0.0055 percent uranium-234) into a product stream (enriched in the 

11 uranium-235 isotope) and a tails stream (depleted in the uranium-235 isotope). Except for the 

12 actual step in the enrichment process that involves the use of lasers, the processes that would 

13 be used for receipt and handling of the feedstock and the enriched and depleted UF6 streams 

14 are very similar to those used at other enrichment facilities. The cylinders that would be used 

15 for transportation and storage of UF6 are industry-standard containers. The proposed GLE 

16 Facility is designed to produce an enriched UF6 stream that is up to eight percent uranium-235 

17 with a nominal capacity of six million SWUs per year. 

18 

19 The four major processing steps involved in enriching the natural UF6 at the proposed GLE 

20 Facility would be (1) UF6 Feed and Vaporization, (2) Cascade/Gas Handling, (3) Product 

21 Withdrawal, and (4) Tails Withdrawal. 

22 

23 The UF6 Feed Vaporization System would provide a continuous supply of gaseous UF6 from the 

24 feed cylinders to the Cascade/Gas Handling Area (where the enrichment takes place). 

25 Approximately nine hundred 122-centimeter (48-inch) cylinders would be processed annually. 

26 Feed cylinders would be loaded into solid feed stations; vented for removal of light gases 

27 (primarily air and hydrogen fluoride); and heated to sublime the UF6 (converting it directly from 

28 solid to gas phase without going through the liquid phase). The light gases and UF6 gas 

29 generated during feed purification would be routed to the Feed Purification Subsystem, where 

30 the UF6 would be desublimed (converted directly from gas to solid phase without passing though 

31 the liquid phase). The Feed Purification Subsystem would remove any light gases such as air 

32 and hydrogen fluoride from UF6 prior to introduction into the Cascade/Gas Handling Area. 

33 

34 After purification, UF6 from the solid feed stations would be routed to the Cascade/Gas Handling 

35 Area. The UF6 in gaseous form would be exposed to laser-emitted light and separated into two 

36 streams (one enriched in uranium-235 and one depleted in uranium-235). Enriched UF6 from 

37 the Cascade/Gas Handling Area would be transported to the Product Withdrawal Area, where it 

38 would be placed in the product cylinders and desublimed. The heat from desublimation of the 

39 UF6 would be removed by air. Filling of product cylinders would be monitored, and filled 

40 cylinders would be transferred to the Sampling Area for sampling and sent to the Blending Area 

41 or put into interim storage on the Product Pad. 

42 

43 The enriched UF6 in product cylinders forwarded to the Blending Area would be vaporized and 

44 pumped into receiver cylinders. During this process, the enrichment level of UF6 put into the 

45 receiver cylinders would be carefully controlled to meet the customer specifications as well as 

46 transportation standards. 

47 
2-10 

1 As a final step, the receiver cylinders would be sent back to the Sampling Area, where the UF6

2 would be liquefied to create a homogenous mixture of UF6 and would be sampled to make sure 

3 that it meets the applicable requirements. A cylinder to be sampled would be moved into an 

4 autoclave with heating and cooling capability, where the UF6 in the cylinder would be liquefied 

5 by electrically heated air, to homogenize the liquefied UF6, and a representative sample of the 

6 contents would be taken. The UF6 in the cylinder would then be solidified in the autoclave using 

7 cold air before removing the cylinder from the autoclave. The autoclaves would be designed to 

8 contain a UF6 release in the autoclave. 

9 

10 Depleted UF6 from the Cascade/Gas Handling Area would be transported to the Tails 

11 Withdrawal Area, where it would be placed in the tails cylinders and desublimed. The heat of 

12 desublimation of the UF6 would be removed by air. Filling of tails cylinders would be monitored, 

13 and filled cylinders would be transferred to the Tails Pad. 

14 

15 2.1.2.4 Waste Management Systems 

16 

17 This section describes the systems used to treat and disposition the liquid and solid wastes 

18 generated at the proposed GLE Facility. The quantities of waste generated and the waste 

19 management impacts are discussed in Section 4.2.12. 

20 

21 Liquid Wastes

22 

23 GLE provided a summary of the systems and operations that would be used to manage the 

24 wastewater generated at the proposed GLE Facility, as shown in Table 2-1 (GLE, 2009a). 

25 Liquid radioactive wastes generated in the Operations Building would be collected in closed26 drain systems that discharge to an accumulator tank. Subsequently, the liquid would be treated 

27 in the Radiological Liquid Waste Treatment System (RLETS) at the proposed GLE Facility to 

28 remove uranium through precipitation and fluoride through evaporation. The resulting solids 

29 would be dried and disposed of as low-level radioactive waste (LLRW). 

30 

31 The treated wastewaters from the RLETS would meet discharge requirements in 

32 10 CFR Part 20, Appendix B (GLE, 2009c), before discharge to the Final Process Lagoon 

33 Treatment Facility (FPLTF). The FPLTF is an existing facility at the Wilmington Site that is 

34 currently used to treat liquid effluents from existing industrial operations. It would also be used 

35 to treat the effluents from the proposed GLE Facility. The treated effluent from the FPLTF is 

36 currently discharged via National Pollutant Discharge Elimination System (NPDES)-permitted 

37 Outfall 001 to the Wilmington Site effluent channel, where it is combined with stormwater, 

38 discharging groundwater, and treated sanitary wastewater effluent. The effluent channel flows 

39 to the Unnamed Tributary #1, which drains to the Northeast Cape Fear River. GLE has stated 

40 that these operations would continue in the same mode when the proposed GLE Facility 

41 becomes operational. 

42 

43 A new cooling tower would be constructed for the proposed GLE Facility. The cooling tower 

44 would use a closed-loop system that does not contact any uranium materials or uranium45 contaminated wastewater streams. To minimize the amount of dissolved solids and other 

46 impurities in the circulating water, a portion of the circulating water from the cooling tower loop 

47 (called blowdown) would be regularly removed from the cooling tower loop and discharged to 
2-11 

Table 2-1 Management of Wastewater Generated by Proposed GLE Facility Operations 

Wastewater Type Onsite Waste Management Offsite Waste 

Treatment/Disposal 

Process liquid 

radiological waste 

Wastewaters collected in closed drain 

system connected to Radiological 

Liquid Waste Treatment System 

(RLETS). Treated radiological waste 

effluent is discharged to existing 

Wilmington Site process wastewater 

aeration basin and Final Process 

Lagoon Treatment Facility (FPLTF). 

Treated effluent from the 

Wilmington Site FPLTF is 

discharged at National Pollution 

Discharge Elimination System 

(NPDES)-permitted Outfall 001 to 

the onsite effluent channel. 

Cooling tower blowdown Blowdown is pumped from cooling 

tower to existing Wilmington Site 

FPLTF. 

Treated effluent from the 

Wilmington Site FPLTF is 

discharged at NPDES-permitted 

Outfall 001 to the onsite effluent 

channel. 

Sanitary waste Sanitary waste is collected in sewer 

system connected to existing 

Wilmington Site Sanitary Wastewater 

Treatment Plant. Waste stream is 

treated by activated sludge aeration 

process. 

Treated effluent from the 

Wilmington Site Sanitary 

Wastewater Treatment Plant is 

discharged at NPDES-permitted 

Outfall 002 to the onsite effluent 

channel. 

Stormwater Stormwater runoff is collected in 

drainage conduits and channels 

flowing to onsite retention basins. 

Stormwater from onsite retention 

basins is discharged per 

requirements of NPDES storm 

water permit. 

Source: GLE 2009a

1 

2 the existing Wilmington Site FPLTF. Fresh water or treated sanitary wastewater effluent would 

3 be added to the cooling tower loop to make up for the water loss. 

4 

5 The sanitary wastes generated at the proposed GLE Facility would be collected in a sewer 

6 system connected to the existing Wilmington Site Sanitary Wastewater Treatment Facility 

7 (WWTF), which employs an Activated Sludge Aeration Process. The treated effluent from the 

8 WWTF could be reused as makeup water in cooling towers at the Wilmington Site or discharged 

9 at NPDES-permitted Outfall 002 to the onsite effluent channel. 

10 

11 Stormwater runoff from outdoor impervious surfaces within the GLE Facility site would be 

12 collected in drainage conduits and channels flowing into detention basins used for collection of 

13 runoff. The detention basins would be routed to one of the unnamed tributaries on the 

14 Wilmington Site that flow into the Northeast Cape Fear River. Stormwater collected from the 

15 cylinder storage pads would be directed to a new holding pond and from there to a new wet 

16 detention basin on the proposed GLE Facility site. 
2-12 

1 Solid Wastes

2 

3 Solid wastes that would be generated by the proposed GLE Facility include municipal solid 

4 waste, nonhazardous industrial wastes, wastes designated as Resource Conservation and 

5 Recovery Act (RCRA) hazardous wastes, and LLRW. No high-level radioactive wastes would 

6 be generated by the proposed GLE Facility operations. GLE provided a summary of the 

7 methods used to manage these wastes onsite and for offsite treatment and disposal, as shown 

8 in Table 2-2 (GLE, 2009a). 

9 

Table 2-2 Management of Solid Waste Generated at Proposed GLE Facility During 

Operations 

Solid Waste Source Onsite Waste Management Offsite Waste 

Treatment/Disposal 

Municipal solid waste (MSW) Collected and temporarily stored 

in rolloff containers 

Filled rolloff containers are 

transported by commercial 

refuse collection service to an 

approved disposal site 

Non-hazardous wastes from 

operations equipment cleaning 

and maintenance activities that 

are recyclable or not accepted by 

MSW landfill 

Collected and temporarily stored 

in containers 

Filled containers are transported 

by truck to an approved disposal 

sitea

Wastes designated RCRA 

hazardous wastes 

Collected and temporarily stored 

in containers 

Filled containers are transported 

by truck to an approved disposal 

siteb

Laboratory waste from UF6 feed 

sampling and analysis 

Collected and temporarily stored 

in containers 

Either transported by truck to an 

approved disposal site or 

transported to an approved 

uranium recovery vendor 

Combustible used or spent 

uranium-contaminated materials 

Collected and temporarily stored 

in containers 

Either transported by truck to an 

approved disposal site or 

transported to an approved 

uranium recovery vendor 

Non-combustible used or spent 

uranium-contaminated materials 

Collected and temporarily stored 

in boxes 

Filled boxes are transported by 

truck to an approved disposal 

sitec

 

Liquid Radiological Waste 

Treatment System filtrate/sludge 

Collected and temporarily stored 

in metal cans 

Filled cans are transported by 

truck to an approved disposal 

site a

 Licensed RCRA Subpart D landfill. 

b

 Licensed RCRA Subpart C Treatment, Storage, and Disposal Facility (TSDF). 

c

 Licensed Low-Level Radioactive Waste Disposal Facility. 

Source: GLE 2009a 
2-13 

1 The municipal solid waste would be collected and placed in rolloff-type containers. A 

2 commercial refuse collection service would regularly collect the filled containers and transport 

3 the waste to a RCRA-permitted Subtitle D landfill for disposal. The nonhazardous industrial 

4 waste, such as spent coolant and used filter media, would be collected and temporarily stored in 

5 containers appropriate for the waste type. Depending on their composition, these wastes would 

6 either be shipped directly to a permitted RCRA Subpart D landfill for treatment and burial, or 

7 routed to other approved facilities for reuse, reclamation, or treatment. The RCRA hazardous 

8 waste would be collected, packaged in DOT-approved shipping containers, and temporarily 

9 stored onsite for shipment to a RCRA-permitted Subtitle C treatment, storage, and disposal 

10 facility. LLRW would be collected in containers and shipped by truck to an approved disposal 

11 facility. 

12 

13 2.1.2.5 Liquid and Air Effluents 

14 

15 This section discusses the potential liquid and air effluents from the proposed GLE Facility. The 

16 impacts associated with these effluents are discussed in Section 4.2.11. 

17 

18 Liquid Effluents

19 

20 Uranium enrichment operations performed at the proposed GLE Facility would generate 

21 process wastewater that would contain small concentrations of uranium and fluoride. This 

22 wastewater would be generated from decontamination operations, cleaning wash water, and 

23 laboratory wastes, and is collectively referred to as liquid radioactive waste. 

24 

25 The process wastewater would be treated to remove the uranium and the fluoride. The treated 

26 wastewater would meet the discharge requirements in 10 CFR Part 20, Appendix B, before 

27 discharge to the existing Wilmington Site FPLTF (GLE, 2009c). This facility currently receives 

28 Wilmington Site process wastewater, including the treated effluent from the GNF-A FMO Facility 

29 Radiological Waste Treatment System. The treated effluent from the FPLTF is discharged via 

30 NPDES-permitted Outfall 001 to the Wilmington Site effluent channel, where it is combined with 

31 stormwater, discharging groundwater, and treated sanitary wastewater effluent. The effluent 

32 channel flows to the Unnamed Tributary #1, which flows into the Northeast Cape Fear River. 

33 

34 As discussed in Section 2.1.2.4 and in Table 2-1, there would be three other liquid effluents 

35 from the proposed GLE Facility. These effluents would not contain radioactive constituents. 

36 The cooling tower blowdown effluent would be discharged to the effluent channel at Outfall 001 

37 along with the process wastewater from the FPLTF. Treated sanitary wastewater would either 

38 be reused as makeup water for cooling towers or released to the effluent channel at Outfall 002. 

39 The stormwater overflow from the onsite wet detention basins would be discharged to one of the 

40 unnamed tributaries to the Cape Fear River. 

41 

42 Air Effluents

43 

44 Because the laser-based enrichment process proposed by GLE is a closed process, no routine 

45 venting of process gases would occur during operations. However, some short-term gaseous 

46 releases could occur inside the Operations Building during certain operations, such as the 

47 connection/disconnection of UF6 cylinders to process equipment and process equipment 
2-14 

1 maintenance. These gaseous releases would be routed through the building’s ventilation 

2 system. 

3 

4 The ventilation system air stream would pass through a series of emissions-control devices, 

5 consisting of high-efficiency particulate air (HEPA) filters and high-efficiency gas absorption 

6 (HEGA) filters. The exhaust air stream from these emission controls would be vented to the 

7 atmosphere and would meet the discharge requirements in 10 CFR Part 20, Appendix B 

8 (GLE, 2009c). 

9 

10 2.1.3 Depleted Uranium Management 

11 

12 The term “depleted uranium” refers to any 

13 chemical form of uranium (e.g., UF6 and 

14 U3O8) that contains uranium-235 in 

15 concentrations less than the 0.7 percent 

16 found in natural uranium. As discussed in 

17 Section 2.1.2.3, the uranium enrichment 

18 process would generate a depleted UF6

19 stream (also called tails). In contrast to the 

20 uranium in the enriched UF6 produced by the 

21 enrichment facility, the uranium in the 

22 depleted UF6 stream would be depleted in 

23 uranium-235 isotope of uranium. At full 

24 production, the proposed GLE Facility would 

25 generate 900 full 122-centimeter (48-inch) 

26 cylinders of depleted UF6 per year. Initially, 

27 the depleted UF6 would be stored on Tails 

28 Storage Pad (GLE, 2009a). Each 

29 122-centimeter (48-inch) cylinder would hold 

30 approximately 12.5 metric tons (13.8 tons), 

31 which means that at full production, the site 

32 would generate approximately 11,250 metric 

33 tons (12,375 tons) of depleted UF6 every 

34 year. During the operation of the facility, the 

35 plant could store up to 9000 cylinders 

36 (10 years worth of generation) of depleted 

37 UF6 (GLE, 2009a). GLE would own the depleted UF6 and maintain the cylinders while they are 

38 in storage. Maintenance activities would include periodic inspections for corrosion, valve 

39 leakage, or distortion of the cylinder shape, and touch-up painting as required. Problem 

40 cylinders would be removed from storage and the material transferred to another storage 

41 cylinder. The proposed storage area would be kept neat and free of debris, and all stormwater 

42 or other runoff would be routed to the onsite holding pond for monitoring and evaporation. 

43 

44 The Defense Nuclear Facilities Safety Board (DNFSB) has reported that long-term storage of 

45 depleted UF6 in the UF6 form represents a potential chemical hazard if not properly managed 

46 (DNFSB, 1995). For this reason, the strategic management of depleted uranium includes the 

47 conversion of depleted UF6 stock to a more stable uranium oxide (e.g., triuranium octaoxide 

48 [U3O8]) form for long-term management (OECD, 2001). The U.S. Department of Energy (DOE) 

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. 
2-15 

1 also evaluated multiple disposition options for depleted UF6 and agreed that conversion to U3O8

2 was preferable for long-term storage and disposal of the depleted uranium in its oxide form, due 

3 to the chemical stability of U3O8 (DOE, 2000). Therefore, the disposal option considered in the 

4 draft EIS is the conversion of the depleted UF6 to U3O8 at either a DOE-owned or commercial 

5 conversion facility followed by disposal as U3O8. Direct disposal of depleted UF6 was ruled out 

6 because of its chemical reactivity (DOE, 1999). 

7 

8 2.1.3.1 Conversion of Depleted UF6

9 

10 Section 3113 of the 1996 USEC Privatization Act (42 U.S.C. 2297h-11), states that DOE “shall 

11 accept for disposal low-level radioactive waste, including depleted uranium if it were ultimately 

12 determined to be low-level radioactive waste, generated by ... any person licensed by the 

13 Nuclear Regulatory Commission to operate a uranium enrichment facility under [Sections 53, 

14 63, and 193 of the Atomic Energy Act of 1954 (42 U.S.C. 2073, 2093, and 2243)].” As a result, 

15 unless GLE finds a beneficial use for its inventory of depleted UF6 generated at the proposed 

16 GLE Facility or makes alternate arrangements for conversion to another chemical form 

17 elsewhere, GLE would send it to DOE for conversion to the oxide form for disposal. On 

18 January 18, 2005, the Commission issued its ruling that depleted uranium is considered a form 

19 of low-level radioactive waste (NRC, 2005a). The Commission also stated that, pursuant to 

20 Section 3113 of the USEC Privatization Act, disposal by DOE at an approved facility represents 

21 a ‘plausible strategy’ for the disposition of depleted uranium tails (NRC, 2005a). 

22 

23 DOE is currently constructing two conversion plants to convert the depleted UF6 now in storage 

24 at Portsmouth, Ohio, and Paducah, Kentucky, to U3O8 and hydrofluoric acid. GLE would 

25 transport the depleted UF6 generated by the proposed GLE Facility to either of these new 

26 facilities and pay DOE to convert and dispose of the material. The proposed GLE Facility would 

27 generate approximately 450,000 metric tons (495,000 tons) in total over its 40-year operating 

28 lifetime. The depleted UF6 would be processed in a DOE-operated conversion facility and then 

29 shipped offsite for disposal. 

30 

31 In addition to the DOE disposition option for depleted UF6, one or more NRC-licensed 

32 commercial depleted UF6 conversion facilities may become available during the proposed 

33 GLE Facility’s operational lifetime. At least one private entity (International Isotopes, Inc.) has 

34 announced plans to construct and operate a new depleted UF6 conversion facility in Hobbs, 

35 New Mexico (GLE, 2008). International Isotopes submitted a license application on 

36 December 31, 2009, and the NRC staff is currently reviewing this application (NRC, 2010). If a 

37 commercial facility performs the conversion to U3O8, DOE is still obligated to accept the U3O8 for 

38 disposal if requested by GLE, per Section 3113 of the USEC Privatization Act. 

39 

40 2.1.3.2 Disposal of Depleted Uranium 

41 

42 The Commission stated that transfer of depleted uranium tails to DOE for disposal represents a 

43 plausible alternative for disposition, and that depleted uranium is considered a form of low-level 

44 waste (NRC, 2005a). Disposal of U3O8 at a commercial low-level waste disposal facility would 

45 also be a viable option, if the commercial waste disposal facility could satisfy the requirements 

46 of 10 CFR Part 61. 

47 
2-16 

1 2.1.4 Decontamination and Decommissioning 

2 

3 At the end of useful plant life, the proposed GLE Facility would be decontaminated and 

4 decommissioned in accordance with applicable NRC license termination requirements. 

5 Decontamination and decommissioning of the proposed GLE Facility would be funded in 

6 accordance with the Decommissioning Funding Plan (DFP) for the proposed GLE Facility 

7 (GLE, 2008). The DFP, prepared by GLE in accordance with 10 CFR 70.25(a), provides 

8 information required by 10 CFR 70.25(e) regarding GLE’s plans for funding the 

9 decommissioning of the proposed GLE Facility and the disposal of depleted uranium tails 

10 generated as a result of plant operations. Funding would be provided by GLE in accordance 

11 with NRC regulations in 10 CFR Part 70 and guidance in NUREG-1757 (NRC, 2003). 

12 

13 The intent of decommissioning is to return the proposed GLE Facility site to a state that meets 

14 NRC requirements for release for unrestricted use after decontamination and decommissioning 

15 is completed (GLE, 2008). It is anticipated that at the end of the useful life of the plant, some of 

16 the support buildings and outdoor areas would already meet NRC requirements for unrestricted 

17 use in accordance with 10 CFR 20.1402. Any buildings, outdoor areas, or equipment that do 

18 not already meet the NRC requirements at the time the GLE Facility ceases operations would 

19 be decontaminated and decommissioned in accordance with NRC regulations at 10 CFR 70.38. 

20 

21 Decontamination and decommissioning activities for the proposed GLE Facility are anticipated 

22 to occur approximately 40 years in the future, and therefore, only a general description of the 

23 activities that would be conducted for the proposed GLE Facility can be developed for this draft 

24 EIS. The proposed facility would follow NRC decommissioning requirements in 10 CFR 70.38.

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. 

Sources: DOE, 2004a,b. 
2-17 

1 The NRC anticipates that decontamination and decommissioning will involve the following 

2 activities: 

3 

4 • installation of decontamination facilities 

5 

6 • purging of process systems and equipment 

7 

8 • dismantling and removal of facilities and equipment 

9 

10 • decontamination and destruction of confidential materials 

11 

12 • decontamination of equipment, facilities, and structures 

13 

14 • survey and spot decontamination of outdoor areas 

15 

16 • removal and sale of any salvaged materials 

17 

18 • removal and disposal of wastes 

19 

20 • management and disposal of depleted uranium 

21 

22 • final radiation survey to confirm that the release criteria have been met 

23 

24 2.1.5 Description and Anticipated Schedule for the Phases of the Proposed Action 

25 

26 As discussed previously, the proposed action would be conducted in three phases starting with 

27 (1) preconstruction and construction, (2) facility operation, and (3) decontamination and 

28 decommissioning. Each of these phases is described briefly and the anticipated schedule of 

29 activities under each phase is provided below. 

30 

31 As discussed in Section 1.4.1, NRC has approved an exemption request from GLE for GLE to 

32 conduct certain preconstruction activities prior to NRC issuing a license to GLE for the 

33 construction and operation of the proposed GLE Facility (NRC, 2009a). Pre-construction 

34 activities covered by the exemption include the following activities and facilities: 

35 

36 • clearing of approximately 40 hectares (100 acres) for the proposed GLE Facility 

37 (e.g., removal of trees and vegetation) 

38 

39 • site grading and erosion control (e.g., leveling, installation of physical barriers, and 

40 construction of drainages and culverts) 

41 

42 • installing stormwater retention system (e.g., including a holding pond for the cylinder storage 

43 pads, wet detention basin, and associated drainage ditches) 

44 

45 • constructing main access roadways and guardhouse(s) (e.g., North access road) 

46 
2-18 

1 • installing utilities (electricity, potable water, process water, water for fire suppression, 

2 sanitary sewer, and natural gas) (e.g., aboveground electrical lines, electrical substation, 

3 wastewater lift stations, and new water tower) 

4 

5 • constructing parking lots and minor roadways (e.g., employee and visitor parking lot and 

6 connections to site access roads) 

7 

8 • constructing administrative building(s) (e.g., office space and personnel Entry Control 

9 Facility) 

10 

11 GLE estimates that it will begin the preconstruction activities in early 2011 (Figure 2-3), and 

NRC’s licensing decision is anticipated to take place by June 2012.1 12 If the license is granted, 

13 GLE would begin the actual construction activities at that time. As discussed in Section 1.4.1, 

14 GLE has indicated that the schedule for preconstruction activities is uncertain at this time. 

15 Therefore, some of the preconstruction activities could still be ongoing after the construction 

16 starts. However, for the purposes of the analyses in this draft EIS (and as indicated in 

17 Figure 2-3), it has been assumed that the preconstruction phase of the project will be completed 

18 before the construction phase begins (anticipated to be in 2012). 

19 

20 GLE anticipates that the construction would take place over an approximately six-year period 

21 starting in 2012 and would be completed in 2017 or earlier. This would include construction of 

22 the Operations Building, cylinder storage pads, holding pond for cylinder storage pad 

23 stormwater runoff, wet detention basin, and security buffer area. Construction would be phased 

24 in such a way that the operations would begin in 2013, while the rest of the facility is being 

25 constructed. When the construction is fully completed (in late 2017), the facility would begin 

26 operating at its rated capacity of six million SWUs per year. 

27 

28 GLE is seeking a license for the proposed facility for a period of 40 years. Assuming it is 

29 granted in 2012, the license would expire in 2052. Prior to 2052, GLE would decide to either 

30 seek a new license to continue to operate the facility or plan for the decontamination and 

31 decommissioning of the facility per the applicable licensing conditions and NRC rules and 

32 regulations. As discussed in Section 2.1.4, decontamination and decommissioning activities 

33 would entail installation of decontamination facilities; purging of process systems and 

34 equipment; dismantling and removal of facilities and equipment; decontamination and 

35 destruction of confidential materials; decontamination of equipment, facilities, and structures; 

36 survey and spot decontamination of outdoor areas; removal and sale of any salvaged materials; 

37 removal and disposal of wastes; management and disposal of depleted uranium; and final 

38 radiation survey to confirm that the release criteria have been met. 

39 

 

1

 The analyses in this draft EIS, are based on the assumption that a licensing decision would be made 

in late 2011, construction (if authorized) would start in 2011, and license termination would occur in 

2051. Subsequently, the Commission’s Notice of Hearing and Commission Order (75 FR 1819) 

specified that a licensing decision be made within 30 months of the Order (i.e., June 2012). The NRC 

staff expects that any resulting changes in the licensing and construction schedule would cause slight 

changes to certain analyses (e.g., air quality, socioeconomics, and cost–benefit) but would not affect 

the conclusions regarding impacts on these resource areas. Any necessary changes to the analyses 

will be reflected in the final EIS. 
2-19 

1 

2 Figure 2-3 Anticipated Timeline for the Proposed GLE Facility 

3 

4 During operations, GLE intends to use natural uranium in the form of UF6 for the proposed 

5 GLE Facility. The UF6 would be transported to the plant in 122-centimeter (48-inch) cylinders 

6 that are designed, fabricated, packaged and shipped in accordance with American National 

7 Standards Institute (ANSI) N14.1, “Uranium Hexafluoride-Packaging for Transport” 

8 (ANSI, 1990). Feed cylinders are expected to be transported to the site by truck. It is 

9 anticipated that approximately 900 shipments of feed cylinders per year would arrive at the 

10 proposed GLE Facility. Expected feed suppliers include the Cameco Corporation (Port Hope, 

11 Ontario, Canada), Honeywell Specialty Chemical Plant (Metropolis, Illinois), and possibly foreign 

12 sources (through ports at Baltimore, Maryland, and Portsmouth, Virginia). 

13 

14 The uranium enrichment process as described in Section 2.1.2.3 would occur within the 

15 Operations Building. Enrichment would normally be three to five percent by weight of 

16 uranium-235, although GLE’s license application indicates GLE seeks authorization to produce 

17 enriched uranium up to 8 percent by weight of uranium-235 (GLE, 2008). 

18 

19 Filled customer product cylinders (Type 30B) would be transported to customers (nuclear fuel 

20 fabrication facilities), while empty feed cylinders would be returned to the customers for refilling. 

21 All cylinders would be prepared for shipment and shipped in accordance with the applicable 

22 NRC and DOT regulations. 

23 

24 All product cylinders shipped from the proposed GLE Facility would be transported by truck. 

25 These cylinders would be designed, fabricated, and shipped in accordance with the ANSI 

26 standard for packaging and transporting UF6 cylinders, ANSI N14.1. An average product 

27 shipment frequency of six cylinders per day is anticipated at full production capacity, with an 

28 annual total of approximately 2100 shipments. Some of these cylinders would be transported to 

29 the FMO on the Wilmington Site for fabrication into nuclear fuel. 

30 

31 All wastes generated by the GLE facility would be treated onsite or shipped offsite for treatment 

32 and/or disposal. The non-hazardous solid wastes would be disposed of in a local landfill or 

33 shipped to an offsite treatment and disposal or reuse facility. The low-level radioactive waste 

34 would be collected in appropriate containers and shipped by truck to a licensed disposal facility 

35 (EnergySolutions) in Clive, Utah. RCRA waste would be appropriately packaged and 

36 temporarily stored onsite for quarterly shipment (with RCRA waste generated by existing site 
2-20 

1 facilities) to a RCRA-permitted treatment, storage, and disposal facility (Heritage Environmental 

2 Services) in Indianapolis, Indiana. 

3 

4 Approximately 900 Type 48Y or 48G cylinders of depleted UF6 tails are expected to be 

5 generated by the GLE Facility per year during full operation. There are no plans for onsite 

6 processing or disposal of depleted UF6, so the cylinders would be stored on the Tails Storage 

7 Pad and monitored until they are ready to be shipped offsite. The planned storage pad will have 

8 sufficient capacity to store 9000 double-stacked cylinders, with approximately 24 hectares 

9 (60 acres) available for expansion of storage capacity. However, GLE anticipates the 

10 availability of at least one offsite UF6 disposition option, enabling the offsite shipment of 

11 depleted UF6 cylinders prior to reaching the 9000-cylinder capacity. Should the 9000-cylinder 

12 capacity be reached during facility operation, GLE would evaluate available options, including 

13 expansion of onsite storage capacity. 

14 

15 2.2 No-Action Alternative 

16 

17 Under this alternative, GLE would not construct, operate, or decommission the proposed 

18 GLE Facility at the Wilmington Site. Under the no-action alternative, the uranium fuel fabrication 

19 facilities in the United States would continue to obtain low-enriched uranium from the currently 

20 available sources or potential new sources. As described in Section 1.3.1, the only domestic 

21 source of low-enriched uranium currently available to fuel fabricators is from production of the 

22 Paducah Gaseous Diffusion Plant (GDP). Foreign sources are currently supplying as much as 

23 85–90 percent of U.S. nuclear power plant demand (EIA, 2009). 

24 

25 Currently, the “Megatons to Megawatts” program will expire in 2013, potentially eliminating 

26 downblending as a source of low-enriched uranium (DOE, 2010). The Paducah GDP, which 

27 opened in 1952, uses gaseous diffusion technology, a process that is more energy-intensive 

28 than newer technologies such as gas centrifuge. The NRC has already granted licenses to two 

29 commercial entities to construct and operate gas centrifuge enrichment facilities: the Louisiana 

30 Energy Services (LES) National Enrichment Facility (NEF) in New Mexico, and the USEC 

31 American Centrifuge Plant (ACP) in Ohio. These two facilities are currently under construction 

32 and designed to produce 3.0 million and 3.5 million SWUs per year, respectively, when 

33 complete and generating at full capacity. In addition, the NRC is currently reviewing an 

34 application from AREVA Enrichment Services, LLC (AES) to construct and operate the Eagle 

35 Rock Enrichment Facility (EREF), a proposed gas centrifuge facility that would be located in 

36 Idaho. If the EREF is licensed and constructed, it would produce enriched uranium with annual 

37 production levels of up to 6.6 million SWU annually. If the three facilities begin operations, this 

38 would represent a more efficient and less costly means of producing low-enriched uranium than 

39 the current gaseous diffusion technology at the Paducah GDP. 

40 

41 Chapter 4 of this draft EIS presents a more detailed evaluation of the environmental impacts of 

42 the proposed action and the no-action alternative. Table 2-3 summarizes the environmental 

43 impacts for the proposed and the no-action alternative. A common element between the two 

44 alternatives is the occurrence of preconstruction activities. It is assumed that preconstruction 

45 activities take place under both alternatives and therefore, the impacts associated with 

46 preconstruction activities take place regardless of which alternative is selected. As a result, the 

47 comparison of alternatives presented in Table 2-3 is intended primarily to highlight the 

48 differences between the two alternatives after preconstruction activities have occurred. 
2-21 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action 

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Land Use SMALL. The project area is owned by GE, contains mostly mixed 

pine forest, and is bordered by existing GE facilities, the Northeast Cape Fear River, and residential development. The project area is zoned for heavy industrial use, and an enrichment facility is consistent with current zoning. Construction will alter the current land use of undeveloped forest but is not expected to affect surrounding land use. Operation of a uranium enrichment facility will affect land use and could affect nearby residential developments. However, operation of such a facility does not represent a significant departure from existing industrial developments at the Wilmington Site. 

SMALL. Under the no-action alternatthe land would not be precluded. Lanwould be SMALL. Should another domestic enrichment constructed at an alternate location, lcould occur and could range from SM

Historic and Cultural Resources 

SMALL to MODERATE. The study area comprises 106 hectares (263 acres). Construction would take place on ground previously disturbed by preconstruction, activities and most impacts on historic or archaeological resources would occur prior to construction. While there is potential for ground disturbance in previously undisturbed areas during construction, no construction activities are expected to occur in the portion of the Wilmington Site, where historic and cultural resources are known to exist. Facility operation has the potential to affect historic and cultural resources, but impacts are not expected. Operational impacts are possible and depend largely on procedures for protecting historic and archaeological resources. Resources could be affected if expansion of the facility is deemed necessary and occurs in areas that contain these resources. No facility activities are expected that would affect site 31NH801, but no plan to protect the site has been disclosed. 

SMALL. Under the no-action alternatdisturbance at the Wilmington Site wodepending on future plans for the proimpacts on historic and cultural resouHanover County would be SMALL. Should another domestic enrichment constructed at an alternate location, h

resource impacts could occur and couSMALL to LARGE. These impacts cothose of the proposed action but wouthe NRC at that time. Consideration cultural resources at the alternate locreviewed in consultation with the appHistoric Preservation Officer (SHPO). 
2-22 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Visual and Scenic Resources 

SMALL. The project area has low scenic quality and the environment in the project area is not unique for the area. The proposed facility site is adjacent to other industrial developments and will not alter a pristine environment. Likewise, the project area is not in a location that is sensitive to visual intrusions. There is limited expectation that the area would be kept in a wilderness 

condition. Construction activities would be concentrated on the Wilmington Site. The greatest visual impacts would result from increased truck and worker traffic, but these impacts would be temporary. The main project area is surrounded by a vegetation barrier, so construction activities would be largely screened. Construction cranes would be visible from greater distances, but this impact would be temporary. During operation, the two most visible (i.e., tallest) features of the 

proposed facility would be the water tower and the operations building tower. The operations building tower will have front and side profiles of 37 meters (120 feet) by 200 meters (660 feet), and could reach up to 49 meters (160 feet) above grade. The 

proposed water tower is the same height as the water tower that currently exists on the Wilmington Site, the top of which is only visible from south of I-140. Although the operations building tower 

could be approximately 10 meters (30 feet) taller than the existing water tower, it would be visible primarily from Castle Hayne Road and the residential subdivision to the northeast because it would be further from I-140 than the existing water tower. The intrusion of these features would not represent a major alteration of the 

existing visual environment. Portions of the proposed facility may 

be visible from I-140, and the planting of additional vegetation may minimize visual impacts. 

SMALL. Under the no-action alternatscreen that surrounds the proposed fremain intact, and no additional visuabe introduced at the Wilmington Site. impacts would be SMALL. Should another domestic enrichment constructed at an alternate location, vresource impacts could occur and couSMALL to LARGE. These impacts cothose of the proposed action but wou

the NRC at that time. 
2-23 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Air Quality SMALL to MODERATE. Potential air quality impacts from 

construction activities would be the highest during this initial three-year period of construction (i.e., MODERATE, but temporary 

in nature). Air emissions of criteria pollutants, volatile organic 

compounds (VOCs), greenhouse gases, and hazardous air pollutants (HAPs) would include primarily fugitive dust emissions and engine exhaust emissions. Potential impacts of SO2, NO2, 

and CO emissions on ambient air quality would be well below applicable standards, and construction activities would have small impacts on ambient air quality for all criteria pollutants. Lead emissions are expected to be negligible and potential CO2

emissions would be small. Because the proposed facility will not employ any continuous combustion activities during operation, criteria pollutant and HAP emission rates are expected to be small. Uranium-related and/or hydrogen fluoride (HF) stack emissions would be minimal. Fugitive air emissions from diesel fuel handling would be very low. Vehicles using onsite roads would contribute emissions, but these would decrease with time. Fugitive dust emissions during operation would be minimal, as most working areas and roads would be paved. Ozone precursor emissions would be relatively small, so the potential impacts on regional ozone would not be of concern. Potential air quality impacts from facility operations are anticipated to be SMALL. 

SMALL. Under the no-action alternatemission sources at the Wilmington Sto operate according to the allowable emission control requirements set forpermits issued by the North Carolina Quality (NCDAQ). Point source emisoperations are negligible compared wemissions in New Hanover County. Should another domestic enrichment constructed at an alternate location, acould occur and could range from SMThe nature and scale of air impacts reoperation of similar enrichment technlocations would be similar to those prproposed action, but the impacts on tenvironments of such alternative facildependent on extant local conditions predicted at this time. In the event that uranium enrichment undertaken at alternative locations or of planned and existing enrichment faenrichment capacity would be diminislead to curtailment of planned new or power plants, necessitating the genermeet current and future demands throof other energy technologies, some osignificant air impacts. A precise anaimpacts associated with such scenarithis time. 
2-24 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Geology and Soil Resources 

SMALL. Approximately 91 hectares (226 acres) of land would be disturbed under the proposed action, including the proposed facility site, support structures, and road construction. Construction vehicles and equipment could potentially leak fuel, oil, or grease to site soils. Soil-related aspects of construction would include soil excavation, soil storage and removal, and stormwater management. Construction would not impact site geologic resources because the site lacks significant geologic resources. Soil disturbance during operations would occur at a reduced level, as some construction projects would be completed while others are ongoing. Restoration and seeding would limit erosion due to stormwater. Roads, parking lots, and roofs would create impervious surfaces and increase runoff, increasing the erosion potential. Large storm events could create erosion along drainages or at culverts, requiring maintenance or drainage system improvement. Vehicles and equipment used in unpaved areas could potentially leak fuel, oil, or grease to site soils. Groundwater pumping is expected to have a minimal effect on the potentiometric surface, and the associated degree of subsidence 

is expected to be negligible. Other geologic hazards to the site are not anticipated. 

SMALL. Under the no-action alternatground-disturbing activities may or mdepending on future plans for the prono additional land disturbance is anticno-action alternative would have SMAimpacts. Should another domestic enrichment constructed at an alternate location, gimpacts could occur and could range LARGE, depending on the design of tconstruction and operations methods geology and soils conditions. These similar to those of the proposed actioscale of these impacts would be assethat time. 
2-25 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Surface Water Resources 

SMALL. Excavations during construction would lead to possible short-term soil erosion with impacts on surface water quality. The proposed North access road would have a new stream crossing and possibly change a jurisdictional channel, which could lead to erosion and increased sediment load. Construction vehicles and equipment pose the possibility of leaks or spills of fuels, oil, or grease, which could run off and impact nearby surface water. 

However, it is unlikely that a minor spill would reach the Northeast 

Cape Fear River or Prince George Creek. Infiltration into site soil would likely eliminate runoff. Process wastewater would be discharged at an existing outfall during operation, increasing the site’s process wastewater volume by about seven percent. Liquid radioactive waste would be pretreated to reduce uranium to acceptable levels before transfer to the existing wastewater treatment facility. Treatment would produce an effluent similar to current process wastewaters. Treated sanitary wastewater effluent would be reused in site cooling towers. No consumption of surface water would take place during operation. Stormwater runoff would collect in a State-permitted detention basin before discharge and would be regulated by a National Pollutant Discharge Elimination System (NPDES) permit. Stormwater runoff from the UF6 cylinder storage pads would 

collect in a lined holding pond. If monitoring demonstrates a lack of radioactivity, basin effluent would be discharged to the stormwater detention basin, and ultimately, to the effluent channel. Any increase in turbidity and sediment loading to streams as a result of construction would subside during operation. Oil, grease, metals, and other automotive-related contaminants would be 

SMALL. Under the no-action alternatsurface water quality would be expecon surface water is expected to be SMShould another domestic enrichment constructed at an alternate location, simpacts could occur and could range LARGE. These impacts could be simproposed action, but the nature and simpacts would be assessed by the NR
2-26 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 present in limited quantities due to general traffic. The use of 

herbicides in landscaped areas would be similar to their use elsewhere at the Wilmington Site. 

Groundwater Resources 

SMALL. Construction equipment poses the potential for leaks of fuel, oil, and grease to soil and groundwater; implementation of best management practices (BMPs) would reduce these impacts. The use of portable toilets during construction would eliminate sanitary system impacts on groundwater. Potable and nonpotable construction water requirements would be met by transport of offsite water by tanker truck. During operation, the stormwater collected from the cylinder 

storage pad is expected to have no more than trace amounts of radiological contaminants, and the liner is expected to limit infiltration to groundwater. Discharge at site outfalls would be from process and sanitary wastewater. Some portion of these effluents may potentially infiltrate the Peedee sand aquifer. However, treatment and monitoring are expected to result in no significant contaminant concentrations in the effluent channel. The proposed facility will obtain additional groundwater from the Wilmington Site’s production wells for potable purposes. Water level data show these wells to be cross-gradient of the overall Wilmington Site, and they do not result in significant drawdown. Groundwater will also be needed as a source of process water. A small amount of increased drawdown is expected, without significant effect on flow directions, water quality, or availability for offsite users. Diesel tanks at the facility would presumably be of proper construction and have adequate leak detection equipment. A groundwater monitoring plan would be developed after the facility is constructed. 

SMALL. Under the no-action alternatuse may or may not occur, depending the project site. Groundwater quality reduced at the proposed facility site, improve sitewide through continued uof site remediation systems and due tattenuation. Because no additional gadverse changes to groundwater quaexpected, the impact on groundwater expected to be SMALL. Should another domestic enrichment constructed at an alternate location, gcould occur and could range from SMThese impacts could be similar to thoaction, but the nature and scale of thebe assessed by the NRC at that time
2-27 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Ecological Resources 

SMALL to MODERATE. Construction activities that could impact ecological resources at the Wilmington Site include constructing the UF6 storage pads, constructing the operations building, and 

adding security fencing around the proposed facility. Most construction activities would occur in areas that would have already been disturbed by preconstruction activities. Impacts on vegetation would occur primarily from vegetation clearing, habitat fragmentation, alteration of topography, changes in drainage patterns, and soil compaction. Remaining potential impacts on vegetation include decline or mortality of trees near the construction boundary, effects related to hydrologic changes, deposition of dust and other particulate matter, introduction of invasive plant species, and accidental releases of hazardous materials (e.g., fuel spills). Wetlands could be impacted by alteration of surface water runoff patterns, soil compaction, or groundwater flow. No wetlands would be directly impacted by construction of the proposed facility, but three jurisdictional wetlands and one isolated wetland occur within the corridor for the revised entrance and roadway. It is probable that the isolated wetland would be directly impacted, resulting in a wetland loss. However, impacts on, or loss of, this wetland would not be significant. Indirect impacts on wetlands could occur from increased stormwater runoff, decreased groundwater recharge, disconnected hydrologic conductivity, or changes in groundwater or surface water flow patterns. Impacts from increased or decreased runoff are expected to be negligible. Except for the probable impact on wetlands, no environmentally sensitive areas would be directly impacted by construction. Only minor, localized indirect impacts on environmentally sensitive 

SMALL. Most impacts on ecological occur during the preconstruction phaschanging the license would not result disturbance on the Wilmington Site, aon ecological resources from the no-aexpected to be SMALL. Should another domestic enrichment constructed at an alternate location, ecould occur and could range from SMThese impacts could be similar to thoaction. However, the nature and scadepend on the resources present and would be assessed by the NRC at tha
2-28 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 areas may occur from erosion and sedimentation or from changes 

in drainage patterns. Impacts on wildlife from construction would include habitat disturbance, wildlife disturbance, and injury or mortality of wildlife. Habitats within the footprint disturbed by construction would be 

reduced or altered, and construction activities would result in habitat fragmentation. Construction would cause a loss of habitat, 

which could result in a long-term reduction in wildlife abundance and richness. Although habitats adjacent to the proposed facility 

site would mostly remain unaffected, wildlife might make less use of these areas due to disturbance (i.e., indirect habitat loss). Habitat disturbance, including roads, could facilitate the spread and introduction of invasive plant species. Wildlife habitat could be adversely affected if invasive vegetation became established in the disturbed areas and adjacent offsite habitats. If exposure of 

wildlife to fugitive dust was of sufficient magnitude and duration, the effects could be similar to those on humans. A more probable effect would be the dusting of plants, which could make forage less palatable. Construction activities could cause wildlife disturbance, including interference with behavioral activities. Wildlife could respond in various ways, including attraction, habituation, and avoidance. Principal sources of noise would include vehicle traffic and operation of machinery. Regular or periodic noise could cause adjacent areas to be less attractive to wildlife and result in a long-term reduction in use. Construction activities could result in the direct injury or death of certain wildlife species. Wildlife could also be exposed to accidental fuel spills or releases of other hazardous materials. 
2-29 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 No aquatic habitats are located within the footprint of the areas 

that will be cleared for the proposed facility, and no significant adverse impacts on aquatic biota are expected from construction activities. No population-level impacts would be expected on any Federally listed threatened, endangered, or other special status species from construction activities. Similarly, no population-level impacts would be expected to any State-listed species. During operation, impacts on vegetation would include moving, hand-cutting, and chemical control of vegetation around the proposed facility, support facilities, utility corridors, and access road. No effects on vegetation would be expected from the cooling tower or air emissions, wastewaters, and solid wastes generated during operation. It is unlikely that radionuclide releases would have adverse effects on ecological resources. Facility operation would not encroach upon or have any other adverse effect on wetlands. Impervious surfaces generally result in increased runoff and reduced infiltration, but routing drainage to the stormwater detention and retention basins would minimize the potential for wetland water-level fluctuations. No environmentally sensitive areas would be impacted by operations. Potential 

impacts on wildlife from operations would include ongoing habitat 

disturbance (i.e., reduction, alteration, and fragmentation of habitat), and wildlife injury or mortality. 
2-30 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 No natural water bodies occur within the immediate area of the 

proposed facility. During operations, aquatic habitats and biota 

could be affected by continued erosion and sedimentation and exposure to contaminants. Increased liquid effluent discharges 

could increase turbidity and sedimentation until the stream 

channel adjusts. Wastewater would be treated to meet NPDES permit requirements, so aquatic biota would not be adversely impacted. The potential exists for toxic materials (e.g., fuel, lubricants, and herbicides) to be accidentally introduced into aquatic habitats, but an uncontained spill would probably affect only a limited area and lubricants and fuel would not be expected to enter wetlands or waterways. Only trace levels of radiological contamination would be released to surface waters during operation, so adverse radiological impacts on aquatic biota would not be expected. No adverse impacts on threatened, endangered, or other special status species would be expected from facility operations due to 

the lack of suitable habitats within the immediate project area. 
2-31 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Noise SMALL to MODERATE. During construction, vehicular traffic 

around the proposed facility and along nearby traffic routes would generate intermittent noise, but the noise contribution from these sources would be limited to the immediate vicinity of the traffic routes and would be minor in comparison with the contribution from continuous sources used during construction. Noise levels from planned construction activities would be comparable to those from other construction sites of similar size. The dominant noise source for most construction equipment is the diesel engine without sufficient muffling. Major construction activities would 

include building erection and electrical and mechanical installation, and some activities would occur inside the structures. Typically, heavy equipment with lower noise levels than used during road construction would be employed. Traffic accessing the site might increase but would largely consist of smaller passenger vehicles, vans, and pickup trucks. Potential construction noise impacts on the nearest subdivision would be anticipated to be SMALL, except during road construction (when potential noise impacts on the surrounding community could be MODERATE but temporary in nature). During facility operation, noise sources would be primarily enclosed within buildings. Various outbuildings are planned with exterior equipment, such as pumps, heat pumps, transformers, and cooling towers. Other noise sources would include vehicular traffic on the proposed north access road, as well as hauling vehicles around the proposed facility. Noise levels at the fenceline receptor closest to the Wooden Shoe residential subdivision are estimated to be below the day and night equivalent sound level for the local noise ordinance and the EPA noise guideline. Potential noise impacts on the subdivision are anticipated to be SMALL. 

SMALL. Noise associated with constoccur and additional noise from operaWilmington Site would not likely chanfuture plans for the project site. Becasources would not be created, noise surrounding communities would be SShould another domestic enrichment constructed at an alternate location, noccur and could range from SMALL to impacts could be similar to those of thHowever, impacts would be dependefactors and would be addressed by th
2-32 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Transportation SMALL to MODERATE. Construction involves the movement of 

personnel and equipment to and from the site, the delivery of materials and supplies, and the removal of construction debris and waste. The number and type of truck shipments will vary over the course of construction. Construction activities are estimated to add an average of approximately 35 trucks per day, with a small impact on local traffic. Prior to start-up, an average increase of up to 815 daily trips by construction personnel is anticipated, with the heaviest traffic occurring in the immediate vicinity of the site entrance. Impacts would be lessened if shift changes did not coincide with local peak road usage times. Impacts could be SMALL to MODERATE in the vicinity of the site; regional impacts are expected to be SMALL. Facility operations would overlap with the construction period for five years, during which time vehicular traffic from commuting operations personnel will add to increased local traffic from construction workers and shipments. The remaining years of 

operation will involve vehicular traffic from operations personnel, occasional visitors, incoming truck shipments for materials and supplies, and outgoing shipments of product materials and wastes. An average of approximately six additional heavy haul truck shipments per day to and from the Wilmington Site would occur during operations. The average number of workers (construction and operations personnel) on a daily basis during start-up and construction completion is anticipated to be 743, with about 350 permanent operations personnel employed over the remainder of the operational period. The average number of additional daily vehicle trips from facility activities will increase by about 1560 at the Wilmington Site during joint construction and operations activities. Once construction is complete, the average 

SMALL. Under the no-action alternatconstruction and operations traffic wothere would not likely be any additiontransportation impacts at the Wilmingon future plans for the project site. Tadditional traffic entering and leaving and additional national impacts from tradioactive materials to and from the would not occur in the short term. Bealternative would not directly result in the site, potential impacts on transpornear the Wilmington Site are expecteShould another domestic enrichment constructed at an alternate location, timpacts could occur and could range LARGE. These impacts could be simproposed action, depending on the exand traffic patterns. National impacts material transportation would likely inwould also the potential for increased and from the Wilmington Site to suppuranium demands of the existing FMO 
2-33 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 number of daily trips associated with operations personnel is 

estimated to be approximately 740. The range of additional daily vehicle trips from facility activities (740 to 1560) could have a SMALL to MODERATE impact on the local road network. The impact on regional traffic flow is expected to be SMALL. Operations of the proposed facility will require the shipment (by truck) of various radioactive materials to and from the facility, with multiple origins or destinations. Vehicle-related risks result from moving from one location to another (independent of cargo characteristics), while cargo-related risk refers to that attributable to the cargo being shipped. In the case of the uranium, cargorelated risks include exposure to ionizing radiation during normal transportation and accident conditions, as well as chemical hazards during accident conditions. Less than one latent cancer fatality is anticipated for the public and transportation crews from all shipments on an annual basis. No latent fatalities from vehicle emissions are anticipated on an annual basis, so impacts on the public from vehicle emissions would be SMALL. Annual transportation accident impacts from the proposed action are anticipated to be SMALL. Chemical impacts would be negligible, as past analyses of depleted UF6 shipments have 

shown the estimates of irreversible adverse effects to be approximately 1 to 3 orders of magnitude lower than the estimates of public latent cancer fatalities from radiological accident exposure. No fatalities are expected from accidents (direct physical trauma) on an annual basis. 
2-34 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Public and Occupational Health 

SMALL. Impacts on occupational safety from construction would be SMALL. Occupational exposures during construction would be minor and minimized using work practices and personal protective equipment. Impacts on air quality during construction would be SMALL. Construction activities are not expected to cause any exceedances of ambient air quality criteria, with the possible exception of short-term criteria for particulate matter from fugitive dust. Radiological impacts during construction would be primarily accrued to construction workers. Offsite exposures would not be expected. Construction activities would not generate radiological contamination but could disturb previously contaminated areas. Construction workers could also be exposed to emissions from the proposed facility during the overlap of construction and early operation. The maximum possible dose is a small fraction of background radiation exposure and less than the 10 CFR 20.1301(a)(1) limit of 1 millisievert per year. Impacts on construction workers from radiological exposure would be SMALL. Dose to the offsite public would be significantly less, as they have no potential for measurable exposure from existing site contamination. Impacts on the offsite public from construction would be SMALL. A total of 450 total recordable incidents, 247 lost workday incidents, and less than one fatal injury are projected for 38 years of facility operation. Impacts on occupational health and safety during facility operation would be SMALL. 

Under the no-action alternative, impaworkers would not occur. Exposure tthe Wilmington Site boundary would rdepending on future plans for the prothe public and occupational health imaction alternative would be SMALL. Should another domestic enrichment constructed at an alternate location, poccupational health impacts could ocfrom SMALL to LARGE. These impato those of the proposed action but wby the NRC at that time. 
2-35 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 The greatest potential for occupational exposure in the main 

process building would be from connecting and disconnecting UF6

cylinders. Airborne concentrations of HF and uranyl fluoride inside facilities are expected to be insignificant, and workers would use ventilation equipment to minimize exposures. Concentrations near the release point could be as high as 10 percent of the Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit and would be limited by ventilation equipment. Impacts associated with routine occupational exposures to HF and UF6 in the workplace would be SMALL. 

Large volumes of UF6 would be present as feed and product 

material, but there would be no routine exposures to solid UF6. 

Exposure to industrial chemicals would be limited by minimizing airborne releases and use of protective equipment. Nonradiological impacts on workers from operations would be SMALL. Lasers would normally be operated within enclosures, equipped with interlocks to prevent inadvertent worker exposure. With laser protections in place, impacts of lasers on worker health would be SMALL. Public health impacts associated with non-radiological liquid effluent releases would be SMALL. Potential long-term, low-level HF and uranium exposure to the public would be the primary offsite chemical exposures of concern. However, public health impacts from such exposures would be SMALL. Only minor quantities of UF6 or HF would escape the facility ventilation 

system, and the quantity of HF passing through the emissions control devices would be below levels established in the facility air permit and protective of public health. The estimated HF and uranium concentrations at onsite exposure locations are orders of 
2-36 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 magnitude below safe levels established by OSHA. UF6 and HF 

levels at the site boundary and the location of the nearest resident would be lower than onsite levels. HF concentrations at all exposure locations are far below the most stringent state or federal ambient air quality standards for the general public. No criteria air pollutants would be produced by the enrichment process. Facility operation could result in radiation exposure to the public via uranium releases or direct external radiation exposure. UF6

gas released in the main process building would pass through a ventilation system to minimize external release. Liquid effluents would be treated and sampled to limit releases. Direct exposure to the public could occur from onsite uranium and transportation both onsite and offsite. Direct radiation and skyshine from airborne releases would be undetectable at offsite areas. The main process building would release small amounts of airborne uranium during operation, but impacts on members of the public from air emissions would be SMALL. Radioactive materials at the proposed facility would present the possibility for onsite members of the public to receive a direct radiation dose. Only depleted uranium would be continuously present in sufficient quantity to represent a potential source of direct radiation dose. Measurements from existing sources at the Wilmington Site were used to estimate the public dose from direct radiation. Site dosimetry indicated no readings above background at the site boundary. Because of cylinder shielding and the distance to receptors, stored cylinders are expected to have only a minor effect on the exposure rate at the site boundary. 
2-37 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 Therefore, the impact from direct exposure to the public is 

expected to be SMALL. The proposed facility would generate process and sanitary liquid effluent streams. Radioactive wastewater would be collected, sampled, and routed to a treatment system. Treated effluent and cooling water blowdown would be discharged to the final process lagoon facility, and water from the lagoon facility would be discharged through an NPDES-permitted outfall. Sanitary wastewater would be treated in the existing sanitary wastewater treatment facility and used to replace cooling tower blowdown. Stormwater runoff would drain to a detention basin before discharge, and a holding pond would collect stormwater runoff from the cylinder storage pad. Monitoring would be conducted before discharge of the holding pond to the detention basin. 

Impacts of normal operations on public health and occupational exposure would be SMALL. 

Waste Management SMALL. Solid nonhazardous wastes generated during 

construction would be similar to wastes from other industrial construction sites and transported offsite to an approved local landfill. Construction activities would generate less than two percent of the waste that the New Hanover County Landfill receives annually from all other sources. Small quantities of 

SMALL. Under the no-action alternatlikely be any additional waste manageWilmington Site, depending on future site. There would be no additional wathe Wilmington Site beyond that geneactivities. 
2-38 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 organic solvent-based residuals could be used and may require 

management as hazardous waste. Hazardous wastes from construction would be packaged and shipped offsite to licensed facilities. Impacts from construction-generated hazardous and nonhazardous waste would be SMALL. Facility operations would result in the generation of wastewaters that would be treated onsite before discharge and solid wastes that would be treated (onsite or offsite) and shipped for disposal offsite. Sanitary wastewater would be collected by a sewer system connected to the existing Wilmington Site sanitary wastewater treatment facility, increasing the load on the existing system by about one-third. Treated sanitary wastewater effluent could be used as makeup water in onsite cooling towers. Should discharges to surface waters be necessary, the existing NPDES discharge permit would be adequate to cover the additional effluent volume. Impacts from sanitary wastewater would be SMALL. Cooling tower blowdown would be sent to the Wilmington Site’s final process lagoons, and impacts from cooling tower blowdown would be SMALL. Radioactive process wastewater from facility operations would be collected and treated to remove uranium, other metals, and fluoride. The treated effluent would be discharged to the process wastewater aeration basin and final process lagoon facility. Impacts from process wastewater would be SMALL. 

Should another domestic enrichment constructed at an alternate location, wimpacts could occur and could range LARGE. These impacts could be simproposed action but would be addresthat time. 
2-39 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

Accidents SMALL. The consequence of a criticality accident would be high 

for a worker in close proximity (less than 6 meters [15 feet]). Worker health consequences are Low to Intermediate from four scenarios involving the release of UF6. Worker health 

consequences are Low to High from four scenarios involving HF exposure. Worker health consequences are Low to Intermediate from four scenarios involving uranium chemical exposure. Radiological consequences to a maximally exposed individual at the Controlled Area Boundary are Low for the criticality accident, Low for all four UF6 release scenarios, Low to High for the four HF 

exposure scenarios, and Low to Intermediate for the four scenarios involving uranium chemical exposure. Risk to the offsite public in the direction of highest exposure is estimated to be less than one lifetime cancer fatality for all accidence scenarios. Plant design, passive and active engineered controls, and administrative controls would reduce the likelihood of accidents. Therefore, impacts from accidents are expected to be SMALL. 

SMALL. Under the no-action alternataccidents and accident consequenceand operation of the proposed GLE Foccur. Should another domestic enrichment constructed at an alternate location, acould occur and could range from SMThese impacts could be similar to thoaction but would be addressed by the 

Socioeconomics SMALL. Construction activities in the peak year (2012) would 

create 680 direct jobs at the facility site and an additional 3131 indirect jobs in the region of interest (ROI). Construction would produce $139.8 million in income in the ROI in 2012, $1.7 million in direct State income taxes, and $1.2 million in direct State sales taxes. Given the scale of construction and the likelihood of local worker availability, in-migration of workers and their families from outside the ROI would be required. Although in-migration may potentially impact local housing markets, the relatively small number of in-migrants (between 299 and 598 persons) and the availability of temporary accommodations would limit the impact on the number of vacant rental housing units. In-migration would affect local–community educational and 

SMALL. Under the no-action alternatadverse consequences of the proposoccur. Population and employment in expected to grow in accordance with Activities completed prior to the no-ac(i.e., preconstruction) would not expenoticeable effect on these trends or oand the no-action alternative would nchanges to current county services oSocioeconomic impacts would be SMShould another domestic enrichment constructed at an alternate location, s
2-40 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 medical services employment to maintain existing levels of 

service. Approximately one additional police officer and one additional firefighter would be required in the peak construction year. Between 84 and 169 additional school-age children would be expected in the ROI in 2012, requiring approximately one additional teacher to maintain existing student-teacher ratios. Facility start-up activities would create 200 direct jobs and an additional 218 indirect jobs in the ROI. Start-up would produce $28.0 million in income in the ROI in 2013, $1.3 million in direct State income taxes, and $0.9 million in direct State sales taxes. Given the scale of start-up activities and the likelihood of local 

worker availability, in-migration of workers and their families from outside the ROI would be required. Although in-migration may potentially impact local housing markets, the relatively small number of in-migrants (92 to 120) and the availability of temporary accommodations would limit the impact of start-up on the number of vacant rental housing units. In-migration would affect localcommunity educational and medical services employment to maintain existing levels of service. Less than one additional police officer and less than one additional firefighter would be required in the start-up year. Between 26 and 40 additional school-age children would be expected in the ROI in 2013, requiring one additional teacher to maintain existing student-teacher ratios. Facility operations in 2017 would create 350 direct jobs and an additional 382 indirect jobs in the ROI. Operations would produce $51.5 million in income in the ROI in 2017, $2.3 million in direct State income taxes, and $1.7 million in direct State sales taxes. 

Corporate income taxes would also be collected by the State during the operating period, totaling $49.2 million annually. Given the scale of operations and the likelihood of local worker availability, facility operation would require in-migration of workers 

impacts could occur and could range LARGE. These impacts could be simproposed action but would be addresthat time. 
2-41 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 (161 to 210) and the availability of temporary accommodations 

would limit the impact of facility operation on the number of vacant owner-occupied housing units. In-migration would affect local–community educational and medical services employment to maintain existing levels of service. Less than one additional police officer and less than one additional firefighter would be required in the peak operations year. Between 46 and 70 additional school age children would be expected in the ROI in 2017, meaning less than one additional teacher would be required to maintain existing student-teacher ratios. 

Environmental Justice 

Although the NRC staff has concluded that potential impacts could be SMALL to MODERATE in a number of resource areas during construction and operation of the proposed facility, the impacts in each resource area would not appear to be disproportionately high and adverse for minority or low-income populations. The majority of environmental impacts associated with construction and operation of the proposed facility are SMALL to MODERATE and would generally be mitigated. Any remaining environmental impacts would affect primarily residents in the immediate vicinity. The neighborhood immediately surrounding the proposed facility site includes a mix of minority and nonminority residents, as well as a mix of low-income and more affluent residents. Because impacts on the general population are generally SMALL to MODERATE, and because the greatest impact is expected to occur in the immediate vicinity (and in an area with a mix of ethnicities and income levels), the various phases of facility development would not be expected to result in disproportionately high or adverse impacts on low-income or minority residents, and would not, therefore, produce any environmental justice concerns. 

SMALL. The no-action alternative woto cause any high and adverse impacjustice impacts would be SMALL. Should another domestic enrichment constructed at an alternate location, eimpacts could occur and could range LARGE. These impacts could be simproposed action but would be addresthat time. 
2-42 

Table 2-3 Summary of Environmental Impacts for the Proposed GLE Facility and the No-Action Alt

Affected 

Environment 

Proposed Action: 

GLE would construct, operate, and decommission the 

proposed GLE Facility in Wilmington, North Carolina 

No-Action Alternat

The proposed GLE Facility would n

operated, and decommissioned. E

would continue to be met with ex

future domestic and foreig

 Even when environmental impacts are anticipated to be SMALL, 

the behaviors of some population groups, such as higher participation in outdoor recreation, home gardening, or subsistence fishing, may lead to disproportionate exposure. One Census block group with a high percentage of low-income and minority residents is located downstream of the proposed facility on the Northeast Cape Fear River. If radioactive contaminants were released, these residents could face increased risk of exposure. However, air and liquid releases of total uranium and UF6 are projected to be extremely low, and indirect exposure 

through fish consumption would be even lower. 
2-43 

1 2.3 Alternatives Considered but Not Analyzed in Detail 

2 

3 As required by NEPA and NRC regulations, the NRC staff has considered other alternatives to 

4 the construction, operation, and decommissioning of the proposed GLE Facility, and the 

5 disposition of UF6. The range of alternatives was determined by considering the underlying 

6 purpose and need for the proposed action. Specifically, the range of alternatives was 

7 determined by considering other ways to provide enriched uranium to fulfill electricity generation 

8 requirements and provide reliable and economic domestic supplies of enriched uranium for 

9 national energy security. This analysis led to the following set of alternatives: 

10 

11 • alternative sites outside of the Wilmington Site 

12 

13 • alternative sites within the Wilmington Site 

14 

15 • alternative sources of low-enriched uranium 

16 

17 • alternative technologies available for uranium enrichment 

18 

19 These alternatives – with the exception of gas centrifuge – were considered but eliminated from 

20 further analysis due to economic, environmental, national security, or technological maturity. 

21 The following sections discuss these alternatives and the reasons NRC staff eliminated them 

22 from further consideration. The gas centrifuge alternative is discussed in Section 2.3.4. 

23 

24 2.3.1 Alternative Sites 

25 

26 This section discusses GLE’s site-selection process, identifies the candidate sites for the 

27 proposed GLE Facility, and discusses the criteria used in the selection process. GLE undertook 

28 a site-selection process to identify viable locations for the proposed GLE Facility (GLE, 2008), 

29 which yielded one alternate candidate site in addition to the proposed site. The details of these 

30 two alternative sites are discussed below. 

31 

32 Since many environmental impacts can be avoided or significantly reduced through proper site 

33 selection, the NRC staff reviewed the GLE site-selection process to determine if a site 

34 considered by GLE was obviously superior to the proposed site in Wilmington, North Carolina 

35 (NRC, 2002). The NRC staff has determined that the process used by GLE is rational and 

36 objective, and that its results are reasonable. None of the candidate sites was obviously 

37 superior to the GLE preferred site in Wilmington, North Carolina. 

38 

39 2.3.1.1 Alternative Sites Outside of the Wilmington Site 

40 

41 GLE considered two approaches for the examination of alternate candidate sites: (1) the 

42 purchase of undeveloped land (i.e., an undisturbed “greenfield” site) and (2) colocation at an 

43 existing nuclear facility site or at a site that has been previously considered for a nuclear facility 

44 (including sites where planning and construction of a nuclear facility were halted). Due to the 

45 environmental advantages, and for commercial reasons (including scheduling considerations), 

46 GLE focused on the second approach (GLE, 2008). 

47 
2-44 

1 GLE Site-Selection Process

2 

3 GLE evaluated 22 sites throughout the eastern United States. The site-selection process, used 

4 to locate a suitable site for construction and operation of the proposed GLE Facility, was based 

5 on various technical, safety, economic, and environmental factors. A multi-attribute utility6 analysis methodology was used for site selection that incorporated all of these factors to assess 

7 the relative benefits of a site with multiple, often competing, objectives or criteria. Figure 2-4 

8 shows the site-selection process used by GLE and the results from the application of the 

9 process (GLE, 2008). 

10 

11 The GLE multi-step site-selection process consisted of: 

12 

13 • identification of candidate sites 

14 

15 • initial screening 

16 

17 • coarse screening 

18 

19 • site-reconnaissance visits 

20 

21 • fine screening 

22 

23 • qualitative cost-benefit analysis 

24 

25 Because most of the fuel-cycle facilities and ports of entry for feed material are located in the 

26 eastern United States or Ontario, Canada, and because the material would be transported by 

27 truck within the borders of the United States, GLE chose its region of interest for the purposes of 

28 site selection to be the area inside a 600-mi radius that encompasses the locations of the 

29 operating fuel-cycle facilities in the eastern United States (Figure 2-5). It follows, for GLE’s 

30 analysis, that the Richland, Washington, facility was excluded due to its distant location. 

31 

32 The 22 candidate sites considered by GLE are listed in Table 2-4. Initial screening included 

33 evaluation of “Go/No Go” criteria, including the impacts and hazards from seismic zones, 

34 proximity to Quaternary fault zones, and flood potential. This initial screening resulted in 

35 elimination of three sites from further consideration: Westinghouse Electric Company 

36 (Columbia, South Carolina); Honeywell Specialty Chemicals/ConverDyn (Metropolis, Illinois); 

37 and the DOE site in Paducah, Kentucky. 

38 

39 Coarse screening criteria – also “Go/No Go” – included sufficient land availability, government 

40 ownership, potential litigation or political opposition, and Comprehensive Environmental 

41 Response, Compensation, and Liability Act (CERCLA) Superfund or RCRA Corrective Action 

42 status. Application of the coarse screening criteria resulted in the elimination of 16 sites; one 

43 due to insufficient land availability, ten due to government ownership, four due to potential 

44 litigation or political opposition, and four due to CERCLA Superfund or RCRA Corrective Action 

45 status (three of which are also government-owned). At the conclusion of the coarse screening 

46 evaluation, three sites remained: the GE site in Wilmington, North Carolina (the proposed site); 

47 the GE-owned site in Morris, Illinois; and the Duke Energy site in Cherokee, South Carolina. 

48 
2-45 

Figure 2-4 GLE Site-Selection Results Summary (GLE, 2008) 
2-46 

Figure 2-5 Candidate Sites for the Proposed GLE Facility (GLE, 2008) 

1 As indicated in Figure 2-3, GLE evaluated the three remaining sites in a subsequent site2 reconnaissance step. The GLE team visited all three sites to identify potential issues that 

3 contributed to the “Go/No Go” decision. Among the factors considered were additional planned 

4 land use, physical layout of existing facilities and infrastructure, current and future plans at the 

5 site, and potential complications related to properties adjacent to the site. Based on these 

6 considerations, GLE determined that Duke Energy’s plans for the Cherokee site (specifically, 

7 the construction and operation of a new nuclear power plant) were not compatible with GLE’s 

8 plans and needs for the construction and operation of an enrichment facility. Therefore, the 

9 Cherokee site was eliminated from further consideration. 

10 

11 GLE evaluated the final two candidate sites (the Wilmington Site and the 889-acre [356 hectare] 

12 Morris site), including multi-attribute decision analysis based on a set of fine screening criteria 

13 and a cost-benefit analysis. The fine screening criteria were grouped around four general 

14 clusters as shown below. Weighting factors were derived by a panel of experts considering a 

15 set of subcriteria for each of the four clusters. These subcriteria are listed below under each 

16 cluster. In most cases, the subcriteria are further subdivided into finer criteria. For example, the 

17 subcriterion listed as water resources under the “Impacts to the Environment” cluster was 

18 divided into physical surface water impacts, water quality impacts, and water quantity impacts 

19 (GLE, 2008). 

20 
2-47 

Table 2-4 Candidate Sites Considered for the Proposed GLE Facility 

Site Name 

Existing 

Nuclear 

Facility 

Description Owner/Operator 

Bailly, IN No The site had a construction permit to build 

a nuclear power plant, which was 

cancelled in 1981. After long delays and 

growing local opposition, the Northern 

Indiana Public Service Company (NIPSC) 

ended the controversy by canceling plans 

to build the nuclear plant at the Bailly Site. 

Northern Indiana Public 

Service Company 

(NIPSC) 

Barnwell, SC Yes Low-level waste disposal facility. State of South Carolina/

Energy Solutions 

Bellefonte, AL Yes Uncompleted nuclear power plant (in the 

Final Environmental Assessment, the 

Tennessee Valley Authority (TVA), in 

2006, reported that it approved the 

cancellation of the BLN construction 

project pending NRC notification). The 

BLN plant site now is under consideration 

as the location of an advanced boiling 

water reactor. In October 2007, TVA 

submitted a combined license application 

for proposed Bellefonte Nuclear Station 

Units 3 and 4. 

Tennessee Valley 

Authority 

Cherokee, SC No The site had a construction permit under 

review, which was cancelled 1982–1983. 

In December 2007, Duke Energy filed a 

combined license application for proposed 

Units 1 and 2 at the William States Lee III 

Nuclear Site (formerly called the Cherokee 

Site). 

Duke Energy 

Clinch River 

Industrial Site, TN 

No Clinch River Breeder Reactor project was 

cancelled in 1983. The 687-hectare 

(1700-acre) area is adjacent to the Clinch 

River, approximately 21 kilometers 

(13 miles) west of Oak Ridge, and is 

partially developed and for sale by the 

TVA. 

Tennessee Valley 

Authority 

Columbia, SC Yes Active uranium fuel-fabrication facility. Westinghouse Electric 

Company 

Erwin, TN Yes Active uranium fuel-fabrication facility. Nuclear Fuel Services, 

Inc. 

 
2-48 

Table 2-4 Candidate Sites Considered for the Proposed GLE Facility (Cont.) 

Site Name 

Existing 

Nuclear 

Facility 

Description Owner/Operator 

Forked River, NJ No The site had a construction permit, which 

was cancelled in 1980. The 266-hectare 

(657-acre) area is adjacent to the Oyster 

Creek Nuclear Generating Station 

(OCNGS). 

AmerGen Energy 

Company, LLC 

Hartsville, TN No The site had a construction permit, which 

was cancelled in 1982–1984. In August 

2003, Louisiana Energy Services, L.P. 

(LES) ended efforts to build a uraniumenrichment facility in Tennessee (zoning 

approval issues due to local opposition to 

proposed facility). 

Tennessee Valley 

Authority 

Lynchburg, VA Yes Active uranium fuel-fabrication facilities. 

The Mount Athos site consists of the 

following facilities: the BWXT Nuclear 

Products Division (NPD) and AREVA NP. 

The NPD is a manufacturer of nuclear 

components for government agencies and 

the DOE. In addition, the NPD operates a 

uranium-recovery facility and a uraniumdownblending facility. 

AREVA NP, Inc./BWX 

Technologies, Inc. 

Marble Hill, IN No The site had a construction permit, which 

was cancelled in 1985 due to cost 

overrun. In 1998, PSI Energy sold the 

property to Debbie and Dean Ford, who 

sold some buildings to a Michigan 

company in 2005. 

Debbie and Dean Ford 

Metropolis, IL Yes Active uranium hexafluoride production 

(conversion) facility. 10-year license 

renewal was issued in May 2007. 

Honeywell Specialty 

Chemicals/ConverDyn 

Midland, MI No The site had a construction permit, which 

was cancelled in 1986. The unfinished 

Midland Nuclear Power Plant was 

converted to a combined-cycle, naturalgas-fired cogeneration facility. 

MCV Power Partners, 

Inc. 

Morris, IL Yes Spent-fuel storage facility. Near Dresden 

Reactors. 

GE Company 

Oak Ridge, TN Yes Nuclear research facility. DOE 

Paducah, KY Yes Gaseous-diffusion plant. DOE/U.S. Enrichment 

Corporation 

 
2-49 

Table 2-4 Candidate Sites Considered for the Proposed GLE Facility (Cont.) 

Site Name 

Existing 

Nuclear 

Facility 

Description Owner/Operator 

Phipps Bend, TN No The site had a construction permit, which 

was cancelled in 1982. The reactor was 

demolished. 

Tennessee Valley 

Authority 

Portsmouth/Piketon, 

OH 

Yes Existing gaseous-diffusion plant; gas 

centrifuge plant under construction. 

DOE 

Savannah River, SC Yes Nuclear materials processing center. DOE 

Sterling, NY No The site had a construction permit, which 

was cancelled in 1980. Adjacent to 

operational nuclear power plant 

(FitzPatrick, Oswego, NY). Cayuga 

County purchased the property in 1994 

and opened the Sterling Nature Center. 

Cayuga County 

Wilmington, NC Yes Active uranium fuel-fabrication facility. GE Company 

Yellow Creek, MS No The site had a construction permit, which 

was cancelled in 1984. 

Tennessee Valley 

Authority 

Source: GLE, 2008.

1 

2 1. Impacts to the Environment (weighting factor = 0.27) 

3 • public health and safety 

4 • socioeconomic impacts 

5 • ecology 

6 • water resources 

7 • air quality 

8 • noise 

9 • historic and archeological sites 

10 • visual impacts 

11 

12 2. Impacts to the Facility (weighting factor = 0.25) 

13 • geologic hazards 

14 • colocated or nearby hazardous land uses 

15 • meteorology and climatology 

16 • wildfires 

17 

18 3. Impacts to Time and Cost (weighting factor = 0.24) 

19 • contamination 

20 • existing infrastructure 

21 • colocation 

22 • site physical characteristics 

23 • site development 

24 
2-50 

1 4. Employment and Stakeholders (weighting factor = 0.24) 

2 • stakeholder support 

3 • labor force 

4 

5 Using site-specific data, GLE ranked the two sites based on the above criteria and weighting 

6 factors. The results of this evaluation are discussed below and shown in Table 2-5. The 

7 Wilmington Site ranked more favorably in the “Impacts to the Environment,” “Impacts to Time 

8 and Cost,” and “Employment and Stakeholders” clusters, whereas the Morris site ranked more 

9 favorably in the “Impacts to Facility” category (GLE, 2008). Overall, the weighted scores for the 

10 Wilmington and Morris sites were 0.525 and 0.475, respectively. 

11 

12 GLE performed a qualitative cost-benefit analysis between the two sites, which indicated that 

13 the net benefits of locating the proposed GLE Facility at the Wilmington Site were slightly higher 

14 than those associated with locating the same facility at the Morris site (GLE, 2008). GLE 

15 determined that its costs would be somewhat less at the Wilmington Site than at the Morris site. 

16 This was due to lower labor cost in the Wilmington area and the fact that the colocated 

17 GE/GNF-A conversion and fuel fabrication facility would be one of the primary customers of the 

18 proposed GLE Facility, thus reducing transportation costs (GLE, 2008). 

19 

20 Based on the above assessment, the NRC staff has determined that the GLE site selection 

21 process has a rational, objective structure and is reasonable. None of the candidate sites was 

22 obviously superior to the GLE preferred site in Wilmington, North Carolina; therefore, no other 

23 site was selected for further analysis. 

24 

25 2.3.1.2 Alternative Locations at the Wilmington Site 

26 

27 GLE evaluated alternative locations at the Wilmington Site in North Carolina and selected the 

28 proposed location because, compared to other potential onsite locations, GLE found the 

29 proposed location to be most suitable for accommodating the footprint (construction and 

30 laydown areas) of the proposed GLE Facility. GLE found that the proposed location would 

31 result in fewer environmental impacts – specifically, to the floodplain of the North Cape Fear 

32 River – than other available areas of the Wilmington Site. The proposed site also minimizes 

33 impacts on or avoids streams, wetlands, and rare ecological resources. GLE eliminated 

34 alternative locations at the Wilmington Site from further evaluation for the reasons specified 

35 above. 

36 

37 2.3.2 Alternative Sources of Low-Enriched Uranium 

38 

39 NRC staff examined three alternatives to fulfill U.S. domestic enrichment needs (as summarized 

40 below). These alternatives were eliminated from further consideration for reasons summarized 

41 below. 

42 

43 2.3.2.1 Re-Activate the Portsmouth Gaseous Diffusion Facility at Piketon 

44 

45 USEC closed the Portsmouth GDP (in Piketon, Ohio) in 2001 to reduce operating costs 

46 (DOE, 2003). USEC cited long-term financial benefits, more attractive power price 

47 arrangements, operational flexibility for power adjustments, and a history of reliable operations 

48 as reasons for choosing to continue operations at the Paducah GDP. In a June 2000 press 
2-51 

Table 2-5 Ranking Results for the Sites in Morris, Illinois, and 

Wilmington, North Carolina 

Criterion Morris, IL, Site Wilmington, NC, Site 

Intermediate Unweighted Scores: 

Impacts to Environment 0.484 0.516 

Impacts to the Facility 0.592 0.408 

Impacts to Time and Cost 0.378 0.622 

Employment and Stakeholders 0.439 0.561 

Final Weighted Score 0.475 0.525 

1 

2 release, USEC explained that it “clearly could not continue to operate two production facilities.” 

3 Key business factors in USEC’s decision to reduce operations to a single production plant 

4 included long-term and short-term power costs, operational performance and reliability, design 

5 and material condition of the plants, risks associated with meeting customer orders on time, and 

6 other factors relating to assay levels, financial results, and new technology issues 

7 (USEC, 2000). 

8 

9 The NRC staff does not believe that there has been any significant change in the factors that 

10 were considered by USEC in its decision to cease uranium enrichment at the Portsmouth GDP. 

11 In addition, the gaseous diffusion technology is substantially more energy-intensive than other 

12 enrichment technologies. The higher energy consumption results in larger indirect impacts, 

13 especially those impacts that are attributable to significantly higher electricity usage (e.g., air 

14 emissions from coal-fired electricity generation plants) (DOE, 1995). The age of the existing 

15 plant also calls into question its overall reliability. Furthermore, plans are now underway to 

16 decommission the plant with a draft request being issued for a proposal for decommissioning 

17 work (DOE, 2009). Therefore, this proposed alternative was eliminated from further 

18 consideration. 

19 

20 2.3.2.2 Downblending Highly Enriched Uranium 

21 

22 Under this alternative, a domestic uranium enrichment plant would not be constructed to replace 

23 existing production. Instead, an equivalent amount of SWU would be obtained from 

24 downblending highly enriched uranium from either United States or Russian nuclear warheads. 

25 This alternative was eliminated because U.S. reliance on foreign sources of enrichment 

26 services, as an alternative to the proposed action, would not meet the national energy policy 

27 objective of a “viable, competitive, domestic uranium enrichment industry for the foreseeable 

28 future” (DOE, 2000). Also, it does not meet the need for a reliable source of enriched uranium, 

29 as discussed in Section 1.3. Furthermore, the Megatons to Megawatts downblending 

30 agreement is set to expire in 2013. 

31 

32 2.3.2.3 Purchase Low-Enriched Uranium from Foreign Sources 

33 

34 There are several potential sources of enrichment services worldwide. However, U.S. reliance 

35 on foreign sources of enrichment services, as an alternative to the proposed action, would not 
2-52 

1 meet the national energy policy objective of a “viable, competitive, domestic uranium enrichment 

2 industry for the foreseeable future” (DOE, 2000). For this reason, NRC staff does not consider 

3 that this alternative meets the need for the proposed action, and therefore, has eliminated it 

4 from further study. 

5 

6 2.3.3 Alternative Technologies for Enrichment 

7 

8 A number of different processes have been invented for enriching uranium; only three (gaseous 

9 diffusion, gas centrifuge, and laser excitation) are considered candidates for commercial use, 

10 and of those, only the gaseous diffusion and gas centrifuge technologies have been deployed 

11 for large-scale industrial use. Other technologies – namely, electromagnetic isotope separation, 

12 liquid thermal diffusion, and early-generation laser enrichment – have proven too costly to 

13 operate, remain at the research and laboratory developmental scale, or in the case of laser14 enrichment have been superseded by a more advanced technology. All of these technologies 

15 are discussed below. 

16 

17 2.3.3.1 Electromagnetic Isotope Separation Process 

18 

19 Figure 2-6 shows a sketch of the electromagnetic isotope separation process. In this process, a 

20 monoenergetic beam of ions of normal uranium travels between the poles of a magnet. The 

21 magnetic field causes the beam to split into several streams according to the mass of the 

22 isotope. Each isotope has a different radius of curvature and follows a slightly different path. 

23 Collection cups at the ends of the semicircular trajectories catch the homogenous streams. 

24 Because the energy requirements for this process proved very high – in excess of 3000 kilowatt 

25 hours per SWU – and production was very slow (Heilbron et al., 1981), electromagnetic isotope 

26 separation was not considered viable and has been removed from further consideration. 

27 

28 2.3.3.2 Liquid Thermal Diffusion 

29 

30 Figure 2-7 is a diagram of the liquid thermal diffusion process, which was investigated in the 

31 1940s. It is based on the concept that a temperature gradient across a thin layer of liquid or gas 

32 causes thermal diffusion that separates isotopes of differing masses. When a thin, vertical 

33 column is cooled on one side and heated on the other, thermal convection currents are 

34 generated and the material flows upward along the 

35 heated side and downward along the cooled side. 

36 Under these conditions, the lighter UF6 molecules 

37 diffuse toward the warmer surface and heavier UF6

38 molecules concentrate near the cooler side. The 

39 combination of this thermal diffusion and the thermal 

40 convection currents causes the lighter uranium-235 

41 molecules to concentrate on top of the thin column 

42 while the heavier uranium-238 goes to the bottom. 

43 Taller columns produce better separation. 

44 Eventually, a facility using this process was designed 

45 and constructed at Oak Ridge, Tennessee, but it was 

46 closed after about a year of operation because of 

47 cost and maintenance concerns (Settle, 2004). 

48 Based on high operating costs and high 

Figure 2-6 Electromagnetic Isotopic 

Separation Process (Milani, 2005) 
2-53 

1 maintenance requirements, the liquid thermal 

2 diffusion process has been eliminated from further 

3 consideration. 

4 

5 2.3.3.3 Gaseous Diffusion Process 

6 

7 The gaseous diffusion process is based on molecular 

8 effusion, a process that occurs whenever a gas is 

9 separated from a vacuum by a porous barrier. The 

10 gas flows from the high-pressure side to the low11 pressure side. The rate of effusion of a gas through 

12 a porous barrier is inversely proportional to the 

13 square root of its mass. Thus, lighter molecules pass 

14 through the barrier faster than heavier ones. 

15 Figure 2-8 is a diagram of a single gas diffusion 

16 stage. The gaseous diffusion process consists of 

17 thousands of individual stages connected in series to 

18 multiply the separation factor. 

19 

20 Gaseous diffusion is the only enrichment technology 

21 in commercial use in the United States, but it has 

22 relatively large resource requirements. The Paducah 

23 GDP contains 1760 enrichment stages and is 

24 designed to produce UF6 enriched up to 5.5 percent 

25 uranium-235. The design capacity of the Paducah 

26 GDP is approximately 8 million SWUs per year, but 

27 it has never operated at greater than 5.5 million 

28 SWUs. Paducah consumes approximately 2200 

29 kilowatt hours per kilogram of SWU (DOE, 2000). 

30 DOE anticipates “the inevitable cessation of all 

31 domestic gaseous diffusion enrichment operations” 

32 due to the higher cost of aging diffusion facilities 

33 (DOE, 2001). Therefore, GDP has been eliminated 

34 from further consideration. 

35 

36 2.3.3.4 Atomic Vapor Laser Isotope Separation 

37 

38 The Atomic Vapor Laser Isotope Separation (AVLIS) 

39 process, shown in Figure 2-9, is based on the 

40 circumstance that different isotopes of the same 

41 element, though chemically identical, have different 

42 electronic energies and absorb different colors of laser 

43 light. The isotopes of most elements can be 

44 separated by a laser-based process, if they can be 

45 efficiently vaporized into individual atoms or 

46 molecules. In AVLIS, uranium metal is vaporized, and 

47 the vapor stream is illuminated with a laser light of a 

48 specific wavelength that is absorbed only by 

Figure 2-7 Liquid Thermal Diffusion 

Process (NRC, 2005b) 

Figure 2-8 Gaseous Diffusion Stage 

(NRC, 2009b) 

Figure 2-9 Atomic Vapor Laser 

Isotope Separation Process 

(Hargrove, 2000) 
2-54 

1 uranium-235. The laser selectively adds enough energy to ionize or remove an electron from 

2 uranium-235 atoms, while leaving the other isotopes unaffected. The ionized uranium-235 

3 atoms are then collected on negatively charged surfaces inside the separator unit. The 

4 collected material (enriched product) is condensed as a liquid on the charged surfaces and then 

5 drains to a caster, where it solidifies as metal nuggets. 

6 

7 The high separation factor in AVLIS means fewer stages to achieve a given enrichment, lower 

8 energy consumption, and smaller waste volume. However, budget constraints compelled USEC 

9 to discontinue development of the U.S. AVLIS program in 1999 (USEC, 1999). Because 

10 development of the AVLIS process was not continued, and the technology has been 

11 superseded by the laser-based technology proposed by GLE, it has been eliminated from 

12 further consideration. 

13 

14 2.3.3.5 Molecular Laser Isotope Separation 

15 

16 Like AVLIS, the Molecular Laser Isotope Separation (MLIS) process uses a tuned laser to excite 

17 uranium-235 molecules in the UF6 feed gas. A second laser then dissociates excited molecules 

18 into UF5 and free fluorine atoms. The enriched UF5 then precipitates and is filtered as a powder 

19 from the feed gas. Each stage of enrichment requires conversion of enriched UF5 back to UF6. 

20 The advantages of MLIS include low power 

21 consumption and the use of UF6 as a process gas. 

22 However, it is less efficient and up to four times more 

23 energy-intensive than AVLIS. Therefore, all countries 

24 except Japan have discontinued development of 

25 MLIS. Because development of the MLIS process 

26 was not continued, and the technology has been 

27 superseded by the laser-based technology proposed 

28 by GLE, it has been eliminated from further 

29 consideration. 

30 

31 2.3.4 Gas Centrifuge 

32 

33 Figure 2-10 shows the basic components of the gas 

34 centrifuge enrichment process, which is a second35 generation mechanical technology. A centrifuge 

36 consists of a large rotating cylinder (rotor) with piping 

37 to feed UF6 gas into the centrifuge, and then withdraw 

38 enriched and depleted UF6 gas streams. The rotor 

39 spins at high speed inside a protective casing, which 

40 maintains a vacuum around the rotor and provides 

41 physical containment of the rotor in the event of a 

42 major machine failure (NRC, 2006). 

43 

44 The enrichment level achieved by a single centrifuge 

45 is not sufficient to obtain the desired concentration of 

46 uranium-235 in a single step; therefore, a number of 

47 centrifuges are connected in series to increase the 

48 concentration of the uranium-235 isotope. 

Figure 2-10 Schematic of a Gas 

Centrifuge (NRC, 2009b) 
2-55 

1 Additionally, a single centrifuge (or series of centrifuges) cannot process a sufficient volume for 

2 commercial production, which makes it necessary to connect multiple centrifuges in parallel to 

3 increase the volume flow rate. The arrangement of centrifuges connected in series to achieve 

4 higher enrichment and in parallel for increased volume is known as a “cascade” (NRC, 2006). 

5 

6 As discussed in Section 2.2, three other commercial entities are pursuing the gas centrifuge 

7 technology for enrichment of uranium in the United States. GLE has selected the laser-based 

8 technology and eliminated the gas centrifuge technology from consideration based on the 

9 reasons described in Section 1.3.3. These reasons relate primarily to GLE’s belief that the 

10 proposed technology will result in lower cost and smaller environmental impacts when 

11 compared to the gas centrifuge technology (GLE, 2008). 

12 

13 The NRC staff recognizes that the gas centrifuge technology is commercially viable and is a 

14 reasonable alternative to the proposed laser-based technology. The impacts associated with 

15 the construction, operation, and decommissioning of a gas centrifuge enrichment facility were 

16 analyzed by NRC in two previous EISs (NRC, 2005b; NRC, 2006). In those EISs, the NRC staff 

17 concluded that the impacts associated with the construction, operation, and decommissioning of 

18 the NEF in Lea County, New Mexico, and the ACP in Piketon, Ohio, were acceptable for 

19 licensing those facilities, unless safety issues mandated otherwise. Based on NRC’s safety and 

20 environmental reviews, both facilities were granted licenses and are currently under 

21 construction. In addition, NRC is currently reviewing another application to build and operate a 

22 uranium enrichment plant based on the gas centrifuge technology in Bonneville County, Idaho 

23 (AES, 2008). 

24 

25 The National Environmental Policy Act requires Federal agencies to analyze and disclose the 

26 impacts of the proposed action and reasonable alternatives to the proposed action. Therefore, 

27 NRC has provided a comparative analysis of the environmental impacts of gas centrifuge and 

28 laser technologies (see comparison in Table 2-6). The comparison is necessarily qualitative 

29 because, in order to compare the two technologies in a quantitative sense, comparable designs 

30 at the same site and with the same throughput would be required. There is no comparable 

31 design for a gas centrifuge facility at the Wilmington Site. 

32 

33 The sources of information used by NRC to generate Table 2-6 include Table 2-3 (which 

34 includes a more detailed summary of impacts for each resource area for the proposed GLE 

35 Facility) and the environmental reports submitted by GLE (GLE, 2008) and AREVA 

36 (AES, 2009). The application submitted by AREVA for the proposed EREF is currently under 

37 review and thus, only high-level factual information (e.g., facility footprint size) is used from the 

38 EREF environmental report. This information is relevant because the proposed EREF and the 

39 proposed GLE Facility have about the same output (design capacities of 6.6 million SWUs per 

40 year and 6 million SWUs per year, respectively). The NRC staff also used information from the 

41 NEF and ACP environmental reviews (LES, 2005; USEC, 2005; NRC, 2005b; NRC, 2006), 

42 along with professional judgment, in preparing the comparison table. Comparing the 

43 environmental impacts of different facilities with different designs and different throughputs built 

44 at different sites that have varying degrees of pre-existing infrastructure carries a high level of 

45 uncertainty. As a result, Table 2-6 is intended to identify potential differences in environmental 

46 impacts that may occur if an enrichment facility based on the gas centrifuge technology were to 

47 be constructed at GE’s Wilmington, North Carolina, site instead of the proposed laser-based 

48 technology. 
2-56 

Table 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology and Centrifu

Resource Area Laser-Based Technology (proposed action) Gas Centrifuge Technology 

Land Use The fenced-in area would be approximately 100 acres (40 hectares). 

The disturbed area (roads, parking lots, utilities, etc.) would be approximately 226 acres (91 hectares). 

The area occupied by a gas centrifuge with the same production capacity wougreater than the area occupied by the proposed GLE Facility. It is not clear wthe increase in area would be. Howevbased on a review of the designs and requirements of plants that use the gas centrifuge technology, it appears that tarea required for a centrifuge plant at tWilmington Site could be 2 to 3 times lthan the area occupied by the proposeFacility. Similarly, the disturbed area fgas centrifuge plant could be approximtwo times greater. 

Historic and Cultural Resources 

Most impacts would occur prior to construction. While there is potential for ground disturbance in previously undisturbed areas, no construction activities are expected to occur in areas where historic and cultural resources are known to exist. Facility operation has the potential to affect historic and cultural resources, but impacts are not expected. Resources could be 

affected if expansion of the facility is necessary and occurs in areas that contain these resources. 

Most impacts would occur prior to construction. However, because of the footprint and larger disturbed area for centrifuge facility, the potential for impsignificant resources due to constructiowould be greater. The determination oadverse impacts (and the differences between the two technologies) would ldepend on where on the Wilmington Sfacility would be constructed (or expanduring operations) and if any significanhistoric and cultural resources would bpresent. 

Visual and Scenic Resources 

The project area, which is adjacent to other industrial developments, has low scenic quality and the environment in the project area is not unique for the area. During construction, the greatest visual impacts (from increased vehicle traffic) would be temporary. During operation, intrusion of the two most visible features would not represent a major alteration of the existing visual environment. 

Impacts on the visual and scenic resouduring the construction and operation two facilities would be similar. 
2-57 

Table 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology and Centrifu

(Cont.) 

Resource Area Laser-Based Technology (proposed action) Gas Centrifuge Technology 

Air Quality Potential air quality impacts from construction activities would be 

highest during the initial three-year period and would primarily include fugitive dust and engine exhaust emissions. Potential impacts of SO2, 

NO2, and CO emissions would be well below applicable standards, 

and construction activities would have small impacts on ambient air quality for criteria pollutants. Because continuous combustion activities will not be employed during operation, criteria pollutant and 

HAP emission rates would be small. Uranium and HF emissions would be minimal. 

The same types of emissions to air (e.g., emissions from construction equvehicular traffic, emergency diesel generators, and fossil fuel heating equipment) would be expected regardwhich facility would be constructed. However, because of the larger footprithe gas centrifuge facility, the impacts construction would be expected to be for the centrifuge facility assuming the construction period would be the same laser facility. On the other hand, durinoperations, the emissions (e.g., uraniuHF) and impacts would be expected to similar and negligibly small with either technology. 

Geology and Soil Resources 

Approximately 91 hectares (226 acres) of land would be disturbed. Construction would not impact site geologic resources. Vehicles and equipment could potentially leak fuel, oil, or grease to site soils during construction and operation. Roads, parking lots, and roofs would create impervious surfaces and increase runoff, increasing the 

erosion potential. 

The types of impacts on site soils (e.g., impacts of spills from vehicles anequipment and runoff from impervious surfaces) would be similar. Because olarger land area requirements and consequently greater disturbance of sothe centrifuge technology, the impacts geology and soil resources would also expected to be larger during both construction and operation. 
2-58 

Table 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology and Centrifu

(Cont.) 

Resource Area Laser-Based Technology (proposed action) Gas Centrifuge Technology 

Surface Water Resources 

Construction excavations could lead to short-term soil erosion with impacts on surface water quality. Vehicles and equipment pose the possibility of leaks or spills of fuels, oil, or grease, which could run off 

and impact nearby surface water, but infiltration into site soil would likely eliminate runoff. Process wastewater discharge would increase 

site process wastewater volume. Liquid radioactive waste would be treated before transfer to the existing wastewater treatment facility. Treated sanitary effluent would be reused in site cooling towers. No consumption of surface water would occur during operation. Stormwater runoff would collect in a wet detention basin before regulated discharge to the site effluent channel. Stormwater runoff from the UF6 cylinder storage pads would collect in a lined holding 

pond prior to monitoring and discharge to the stormwater wet detention basin. 

The types of impacts from construction (e.g., short-term erosion, runoff of spillvehicles) and operations (e.g., discharprocess wastewater, treated liquid radwaste, and treated sanitary wastewateexpected to be similar to the impacts fconstruction and operation of a laser-bfacility. Although there may be differenbetween the liquid effluent emissions otwo types of facilities when they are budifferent locations, significant differencthe construction or operational impacts surface water resources would not be expected if the two facilities are assumbe constructed on the Wilmington Site

Groundwater Resources 

Construction equipment poses the potential for leaks of fuel, oil, and grease to groundwater. Potable and nonpotable construction water requirements would be met by transport of offsite water by tanker truck. Stormwater collected from the UF6 cylinder storage pad would 

be expected to have no more than trace amounts of radiological contaminants, and the lined holding pond would limit infiltration to groundwater. A portion of discharged liquid effluents may infiltrate the Peedee sand aquifer. No significant contaminant concentrations are expected in the effluent channel. Additional groundwater will be obtained from existing production wells for process water and potable purposes. A small amount of drawdown would be expected, without significant effect on flow directions, water quality, or availability for offsite users. 

The impacts on groundwater resourceduring construction (e.g., the potential construction equipment leaks, water uswould be about the same with either technology. Similarly, the types of impon groundwater resources that would oduring operations are expected to be s(e.g., stormwater from cylinder pads, infiltration of discharged liquid effluentsgroundwater use). However, the operwater requirements of a gas centrifuge with the same production capacity appbe greater than those of the proposed Facility. Because the groundwater use during operations could be as much as factor of four greater for a gas centrifufacility on the Wilmington Site, the impgroundwater are expected to be larger
2-59 

Table 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology and Centrifu

(Cont.) 

Resource Area Laser-Based Technology (proposed action) Gas Centrifuge Technology 

Ecological Resources 

Most impacts would occur prior to construction. Construction could impact ecological resources (including vegetation), although most construction would occur in areas previously disturbed by preconstruction activities. No wetlands or environmentally sensitive areas would be directly impacted by construction, but wetlands occur in the roadway corridor (possibly resulting in wetland loss). Minor, localized indirect impacts on wetlands and environmentally sensitive areas may occur. No aquatic habitats are located within the areas that will be cleared, and no significant adverse impacts on aquatic 

biota are expected. Construction activities (and noise) would result in 

wildlife injury/mortality, wildlife disturbance, and a loss of habitat. 

Habitat disturbance could facilitate the spread and introduction of invasive plant species. No population-level impacts would be expected on any Federally listed threatened, endangered, or other 

special status species, or on any State-listed species. No operational effects on vegetation would be expected from the cooling tower, air emissions, wastewaters, or solid wastes. Operation would not adversely affect wetlands or environmentally sensitive areas. Potential impacts on wildlife would include ongoing habitat disturbance and wildlife injury/mortality. Aquatic habitats and biota could be affected by erosion, sedimentation, and exposure to contaminants, but aquatic biota would not be adversely impacted by treated effluents or trace contamination released to surface waters. No adverse impacts on threatened, endangered, or other special 

status species would be expected from operations. 

Most impacts would occur prior to construction. The types of impacts froconstruction (e.g., potential wetland lowildlife injury/mortality, impacts of noiswildlife, habitat disturbance) and opera(e.g., habitat disturbance, wildlife injury mortality, impacts on aquatic habitat by erosion, sedimentation, and exposure contaminants) are expected to be simithe impacts of a laser-based facility. However, because of the larger footprilarger disturbed area for a gas centrifufacility with the same production capacimpacts on ecological resources are estimated to be proportionately larger. impacts (and relative differences betwtwo technologies) would depend on whthe Wilmington Site the facility would bconstructed or expanded during operaand the existence of ecological resourthe affected areas. 
2-60 

Table 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology and Centrifu

(Cont.) 

Resource Area Laser-Based Technology (proposed action) Gas Centrifuge Technology 

Noise During construction, vehicular traffic would generate intermittent noise 

that would be limited to the immediate vicinity and minor in comparison to other continuous sources. Potential construction noise impacts on the adjacent residential subdivision are anticipated to be small. During operation, noise sources would be primarily enclosed within buildings, and other sources would include vehicular traffic. Noise levels at the site boundary closest to the adjacent residential subdivision are estimated to be below the day and night equivalent sound level for the local noise ordinance and the EPA noise guideline. 

Noise sources during construction (e.g., vehicular traffic, construction equipment) and operations (e.g., vehictraffic, sources within buildings) would similar to noise sources during construand operation of a laser-based facility. impacts during construction would be temporary and could be mitigated for etechnology. Similarly, noise impacts doperations would not be expected to dsignificantly, regardless of which technwould be employed. 

Transportation The number and type of truck shipments will vary during construction, 

with the heaviest traffic occurring near the site entrance. Operations would overlap construction for five years, during which commuting operations personnel would add to increased local traffic from construction workers and shipments. Remaining operations would involve traffic from personnel, visitors, and incoming and outgoing truck shipments. The range of additional daily vehicle trips from operation would have a similar effect on the local road network as the increase due to construction traffic. Operations would require the shipment of radioactive materials to and from the facility. Cargo-related risks include exposure to ionizing radiation during normal transportation and accident conditions, as well as chemical hazards during accident conditions. Less than one latent cancer fatality (annually) would be anticipated for the public and transportation crews from all shipments. No latent fatalities from vehicle emissions would be anticipated, annually. No fatalities are expected from accidents (direct physical trauma), annually. 

The types of transportation impacts froconstruction (e.g., traffic from construcequipment, material shipments, and commuting construction workers) and operations (e.g., impacts of radioactive material shipments, traffic due to commoperational workers) would be expectesimilar for both types of facilities. Diffein transportation requirements for mateand labor during construction and opefor the two types of facilities are not significant. Therefore, the transportatiimpacts would be expected to be similduring both construction and operation
2-61 

Table 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology and Centrifu

(Cont.) 

Resource Area Laser-Based Technology (proposed action) Gas Centrifuge Technology 

Public and Occupational Health 

Occupational exposures during construction would be minor, as construction would not be expected to cause any exceedances of ambient air quality criteria (with the possible exception of fugitive 

dust). Construction activities could disturb previously contaminated 

areas, and construction workers could be exposed to emissions during the overlap of construction and operation. The maximum 

possible dose would be a small fraction of background radiation exposure. Dose to the offsite public would be significantly less, as 

they have no potential for measurable exposure from existing site contamination. A total of 450 total recordable incidents, 247 lost workday incidents, 

and less than one fatal injury are projected for 38 years of operation. Lasers would be operated within enclosures, equipped with interlocks to prevent inadvertent exposure. The greatest potential for occupational exposure would be from UF6

cylinders, although airborne concentrations of HF and uranyl fluoride inside the facility are expected to be insignificant. The estimated HF and uranium concentrations at onsite locations would be orders of magnitude below safe levels, and UF6 and HF levels at the site 

boundary (and the nearest resident) would be even lower. Operation could result in exposure to the public via uranium releases or direct external radiation exposure. UF6 would pass through a ventilation system to minimize external release and liquid effluents would be treated and sampled to limit releases. Radioactive materials would present the potential for onsite members of the public to receive a direct radiation dose, but measurements from existing sources indicate no readings above background at the site boundary. Skyshine from airborne releases would be undetectable at offsite areas. The maximum dose to a member of a public from liquid effluent releases would occur just south of the site boundary and would be well below the applicable regulatory limit. 

The types of impacts from construction (e.g., fugitive dust exposure, exposure disruption of previously contaminate aexposures during the overlap of constrand operations) and operations (e.g., wplace injuries, potential UF6 exposure, 

potential public exposure to air and liqeffluent releases) are expected to be sexcept that there would be no potentiaworker injury due to laser accidents. Although the estimated air emissions foperation of a gas centrifuge facility co5 to 10 times higher than those of the proposed GLE Facility, the releases wsmall enough that the impacts on publoccupational health from either technowould be well below all applicable regulimits and standards. No difference in rate or total number of occupational inand injuries would be expected, given similar-sized workforce. Therefore, the impacts on the public and occupationawould be about the same with either technology during both construction anoperation. 
2-62 

Table 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology and Centrifu

(Cont.) 

Resource Area Laser-Based Technology (proposed action) Gas Centrifuge Technology 

Waste Management 

Solid nonhazardous wastes generated during construction would be similar to wastes from other industrial construction sites. Construction activities would generate less than two percent of the waste that the local landfill receives annually. Hazardous wastes from construction would be packaged and shipped offsite to licensed facilities. Operations would generate wastewaters that would be treated onsite 

prior to discharge and solid wastes that would be treated (onsite or offsite) and shipped offsite for disposal. Sanitary wastewater would be treated at the existing site treatment facility, increasing the load by about one-third. Treated sanitary wastewater effluent could be used as makeup water in onsite cooling towers, and cooling tower blowdown would be sent to the existing final process lagoon facility. The existing discharge permit would be adequate to cover the additional effluent discharge to surface waters. Radioactive process wastewater would be collected and treated to remove uranium, metals, and fluoride. Treated effluent would be discharged to the final process lagoon facility. 

The types of waste generated during construction (e.g., hazardous and nonhazardous solid waste) and operations (e.g., solid waste, process wastewatersanitary wastewater) would be expectebe treated and disposed of similarly fotypes of facilities. Because of the largfootprint of the gas centrifuge facility, tquantities of waste generated during construction would likely be somewhat greater for gas centrifuge than for lasetechnology. However, the amount of wgenerated by a gas centrifuge facility doperations is estimated to be considerless than the proposed GLE Facility. Tpotential difference could be on the ordfactor of two for LLW and hazardous wand a factor of five or six for solid nonradioactive/nonhazardous waste. 

Accidents The consequence of a criticality accident would be High for a worker 

in close proximity. Worker health consequences are Low to Intermediate for scenarios involving the release of UF6, Low to High 

for scenarios involving HF exposure, and Low to Intermediate for scenarios involving uranium chemical exposure. Radiological consequences to a maximally exposed individual at the Controlled Area Boundary are Low for the criticality accident, Low for UF6

release scenarios, Low to High for HF exposure scenarios, and Low to Intermediate for scenarios involving uranium chemical exposure. Risk to the offsite public in the direction of highest exposure would be less than one lifetime cancer fatality for all accident scenarios. 

The potential for criticality accidents anrelease of UF6 would be expected to b

similar at both types of facilities. The consequences of accidents taking placgas centrifuge facility for workers and foffsite members of the public would noexpected to differ significantly from thothe proposed GLE Facility. Consequethe accident impacts in the region wouexpected to be similar. 
2-63 

Table 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology and Centrifu

(Cont.) 

Resource Area Laser-Based Technology (proposed action) Gas Centrifuge Technology 

Socioeconomics Construction activities in the peak year would create 680 direct jobs at 

the facility site and an additional 3131 indirect jobs in the region of interest (ROI). Construction would produce $139.8 million in income in the ROI in 2012, $1.7 million in direct State income taxes, and $1.2 million in direct State sales taxes. Start-up activities would 

create 200 direct jobs and an additional 218 indirect jobs in the ROI. Start-up would produce $28.0 million in income in the ROI in 2013, $1.3 million in direct State income taxes, and $0.9 million in direct State sales taxes. Operations would create 350 direct jobs and an additional 382 indirect jobs in the ROI. Operations would produce $51.5 million in income in the ROI in 2017, $2.3 million in direct State income taxes, and $1.7 million in direct State sales taxes. Corporate income taxes would also be collected by the State during the operating period, totaling $49.2 million annually. In-migration would affect local-community educational and medical services employment to maintain existing levels of service during three periods. 

The estimated direct employment numfor construction and operation of a gas centrifuge facility would be expected to about the same as for the proposed GFacility. Consequently, the socioeconimpacts in the region during both consand operation would be expected to be similar. 
2-64 

Table 2-6 Comparison of Environmental Impacts of the GLE Laser-Based Technology and Centrifu

(Cont.) 

Resource Area Laser-Based Technology (proposed action) Gas Centrifuge Technology 

Environmental Justice 

Although potential impacts could be SMALL to MODERATE in a number of resource areas during construction and operation, the 

impacts would not appear to be disproportionately high and adverse for minority or low-income populations. The majority of environmental impacts would be mitigated and any remaining environmental impacts would primarily affect residents in the immediate vicinity. The neighborhood immediately surrounding the site includes a mix of minority and nonminority residents, as well as a mix of low-income 

and more affluent residents. Because impacts on the general population are SMALL to MODERATE, and because the greatest 

impact would be expected to occur in the immediate vicinity (and in an area with a mix of ethnicities and income levels), construction and operation are not expected to result in disproportionately high or adverse impacts on low-income or minority residents. Even when environmental impacts are anticipated to be SMALL, the behaviors of some population groups may lead to disproportionate exposure. However, air and liquid releases are projected to be extremely low, and indirect exposure through fish consumption would be even lower. 

The types of potential environmental juconcerns for a gas centrifuge facility wexpected to be the same as the potentenvironmental justice impacts of a lasebased facility. Because of the mix of residents in the area surrounding the Wilmington Site, and because impacts each resource area are expected to be SMALL to MODERATE, there would nany expected environmental justice imof the gas centrifuge technology, if emat the Wilmington Site, during either construction or operation. 
2-65 

1 The impacts presented in Table 2-6 are based on the assumption that an exemption request 

2 would be granted if a gas centrifuge facility were to be constructed at the Wilmington Site, 

3 similar to the exemption request granted for the proposed GLE Facility. Therefore, most 

4 construction would take place on ground previously disturbed by preconstruction activities. 

5 

6 2.4 Staff Recommendation Regarding the Proposed Action 

7 

8 After weighing the impacts of the proposed action and comparing alternatives, the NRC staff, in 

9 accordance with 10 CFR 51.71(f), sets forth its preliminary NEPA recommendation regarding 

10 the proposed action. 

11 

12 The NRC staff preliminarily recommends that, unless safety issues mandate otherwise, the 

13 proposed license be issued to GLE. In this regard, the NRC staff has concluded that 

14 environmental impacts are generally SMALL, and taken in combination with the applicable 

15 environmental monitoring program described in Chapter 6 and the proposed mitigation 

16 measures discussed in Chapter 5, would eliminate or substantially lessen any potential adverse 

17 environmental impacts associated with the proposed action. 

18 

19 The NRC staff has preliminarily concluded the overall benefits of the proposed GLE Facility 

20 outweigh the environmental disadvantages and costs based on consideration of the following: 

21 

22 • The need for an additional, economical, domestic source of enrichment services; and 

23 

24 • The environmental impacts from the proposed action are generally SMALL, although they 

25 could be as high as MODERATE in the areas of historic and cultural resources, ecological 

26 resources, and transportation. 

27 

28 2.5 References 

29 

30 (AES, 2008) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility, 

31 Application for a Uranium Enrichment Facility License under 10 CFR 70, ‘Domestic Licensing 

32 of Special Nuclear Material.’” December. <http://adamswebsearch2.nrc.gov/idmws/ 

33 doccontent.dll?library=PU_ADAMS^PBNTAD01&ID=090770339> (Accessed 8/18/09). 

34 ADAMS Accession No. ML090300656. 

35 

36 (AES, 2009) AREVA Enrichment Services, LLC. “Eagle Rock Enrichment Facility 

37 Environmental Report.” December. 

38 

39 (ANSI, 1990) American National Standards Institute. (ANSI) N14.1, “Uranium Hexafluoride40 Packaging for Transport ANSI N14.1 Standard for Packaging of Uranium Hexafluoride for 

41 Transport,” 1971, 1982, 1987, and 1990 Editions. 49 CFR 171.7; 173.417; 173.420. 1990. 

42 

43 (Brown et al., 1997) Brown, C., et al. “Beneficial Uses of Depleted Uranium.” Beneficial Re-Use 

44 Conference. Knoxville, Tennessee. August 5–7. 

45 

46 (DNFSB, 1995) U.S. Defense Nuclear Facilities Safety Board. “Integrity of Uranium 

47 Hexafluoride Cylinders.” Technical Report DNFSB/TECH-4. May 5.

48 
2-66 

1 (DOE, 1995) U.S. Department of Energy. “Electricity Generation and Environmental 

2 Externalities: Case Studies.” DOE/EIA-0598. Energy Information Administration, Office of Coal, 

3 Nuclear Electric, and Alternative Fuels, Coal and Electric Analysis Branch. September. 

4 <http://www.eia.doe.gov/cneaf/electricity/external/external.pdf> (Accessed January 29, 2010). 

5 

6 (DOE, 1999) U.S. Department of Energy. “Final Programmatic Environmental Impact Statement 

7 for Alternative Strategies for the Long-Term Management and Use of Depleted Uranium 

8 Hexafluoride.” DOE/EIS-0269. Volume 1. Office of Nuclear Energy, Science, and Technology. 

9 Washington, D.C. April. 

10 

11 (DOE, 2000) U.S. Department of Energy. “Report to Congress on Maintenance of Viable 

12 Domestic Uranium, Conversion and Enrichment Industries.” December. 

13 

14 (DOE, 2001) U.S. Department of Energy. “Effect of U.S./Russia Highly Enriched Uranium 

15 Agreement.” December. 

16 

17 (DOE, 2003) U.S. Department of Energy. “Cold Standby Program at the Portsmouth Gaseous 

18 Diffusion Plant.” DOE-0634. Audit Report. Office of Inspector General, Office of Audit 

19 Services. December. <http://ig.energy.gov/documents/CalendarYear2003/ig-0634.pdf> 

20 (Accessed April 28, 2010). 

21 

22 (DOE, 2004a) U.S. Department of Energy. “Final Environmental Impact Statement for 

23 Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

24 Paducah, Kentucky Site.” DOE/EIS-0359. Office of Environmental Management. June. 

25 <http://www.sc.energy.gov/NEPA/finalEIS-0359.htm> (Accessed January 29, 2010). 

26 

27 (DOE, 2004b) U.S. Department of Energy. “Final Environmental Impact Statement for 

28 Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

29 Portsmouth, Ohio, Site.” DOE/EIS-0360. Office of Environmental Management. June. 

30 <http://www.sc.energy.gov/NEPA/finalEIS-0360.htm> (Accessed January 29, 2010). 

31 

32 (DOE, 2004c) U.S. Department of Energy. “Record of Decision for Construction and Operation 

33 of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio, Site.” July 20. 

34 

35 (DOE, 2009) U.S. Department of Energy. “D&D Planning and Future Vision.” Portsmouth 

36 Paducah Project Office. <http://www.pppo.energy.gov/D&D_Planning_and_Future_ 

37 Vision.html> (Accessed August 31, 2009). 

38 

39 (DOE, 2010) U.S. Department of Energy, National Nuclear Security Administration. 

40 “U.S.-Russian Highly Enriched Uranium Purchase Agreement.” January. 

41 <http://www.nnsa.energy.gov/nuclear_nonproliferation/highly_enriched_uranium_disposition. 

42 htm> (Accessed January 28, 2010). 

43 

44 (EIA, 2009) Energy Information Administration, U.S. Department of Energy. “Uranium 

45 Marketing Annual Report.” U.S. Department of Energy. May 26. <http://www.eia.doe.gov/ 

46 cneaf/nuclear/umar/umar.html> (Accessed October 22, 2009). 

47 
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1 (GLE, 2008) GE-Hitachi Global Laser Enrichment. “Environmental Report for the GLE Facility.” 

2 December 2008. ADAMS Accession No. ML090910573. 

3 

4 (GLE, 2009a) GE-Hitachi Global Laser Enrichment LLC. "GE-Hitachi Global Laser Enrichment 

5 LLC Commercial Facility, Wilmington, North Carolina: License Application April 2009." April 30. 

6 ADAMS Accession No. ML091871003. 

7 

8 (GLE, 2009b) GE-Hitachi Global Laser Enrichment LLC. “Global Laser Enrichment 

9 Environmental Report Supplement 2.” November. ADAMS Accession No. ML093240935. 

10 

11 (GLE, 2009c) GE-Hitachi Global Laser Enrichment LLC. Letter from A.E. Kennedy (GE-Hitachi 

12 Global Laser Enrichment LLC) to B. Smith (U.S. Nuclear Regulatory Commission) dated 

13 December 28. “Subject: Response to Request for Additional Information Dated 

14 November 19, 2009 for Global Laser Enrichment License Application – Public Responses.” 

15 ADAMS Accession Nos. ML093620823 and ML093620841. 

16 

17 (Hargrove, 2000) Hargrove, Steven. “Laser Technology Follows in Lawrence’s Footsteps.” 

18 Science and Technology Review. May 2000. Lawrence Livermore National Laboratory. 

19 <http://www.llnl.gov/str/Hargrove.html> (Accessed March 31, 2009). 

20 

21 (Heilbron et al., 1981) Heilbron, et al. “Lawrence and His Laboratory-A Historian’s View of 

22 History.” June. 

23 

24 (LES, 2005) Louisiana Energy Services. “National Enrichment Facility Environmental Report.” 

25 Revision 4. NRC Docket No. 70-3103. April 2005. <http://www.nrc.gov/materials/fuel-cycle26 fac/licapp-envir-rpts.html> (Accessed February 4, 2010). 

27 

28 (Milani, 2005) Milani, Kevin. “The Scientific History of the Atomic Bomb.” Hibbing Community 

29 College. <http://www.hcc.mnscu.edu/chem/abomb/page_id_4755.html> (Accessed 

30 December 3, 2009). 

31 

32 (NRC, 1991) U.S. Nuclear Regulatory Commission. Policy Issue “Disposition of Depleted 

33 Uranium Tails from Enrichment Plant.” SECY-91-019. January 25. 

34 

35 (NRC, 1995) U.S. Nuclear Regulatory Commission. Letter from R.M. Bernero, Director, Office 

36 of Nuclear Materials Safety and Safeguards (NMSS), to C.E. Bradley, DOE Office of Uranium 

37 Programs, Office of Nuclear Energy. January 3. 

38 

39 (NRC, 2002) U.S. Nuclear Regulatory Commission. “Denial of Petition for Rulemaking to 

40 Eliminate Review of Alternative Sites, Alternative Energy Sources, and Need for Power in 

41 Nuclear Power Reactor Siting and Licensing Reviews (PRM-52-2).” SECY-02-0175. 

42 September 27. 

43 

44 (NRC, 2003) U.S. Nuclear Regulatory Commission. NUREG-1757. “Consolidated NMSS 

45 Decommissioning Guidance, Volume 3, Financial Assurance, Recordkeeping, and Timeliness.” 

46 September. <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1757/v3/ 

47 sr1757v3.pdf> (Accessed January 29, 2010). 

48 
2-68 

1 (NRC, 2005a) U.S. Nuclear Regulatory Commission. “Memorandum and Order.” CLI-05-05. 

2 NRC Docket No. 70-3103. January 18. <http://www.nrc.gov/reading-rm/doc3 collections/commission/orders/2005/2005-05cli.html> (Accessed January 29, 2010). 

4 

5 (NRC, 2005b) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for the 

6 Proposed National Enrichment Facility in Lea County, New Mexico.” NUREG-1790. Office of 

7 Nuclear Material Safety and Safeguards, Washington, D.C. June. <http://www.nrc.gov/reading8 rm/doc-collections/nuregs/staff/sr1790/> (Accessed March 26, 2009). 

9 

10 (NRC, 2006) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for the 

11 Proposed American Centrifuge Plant in Piketon, Ohio, Final Report.” NUREG-1834. April. 

12 <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1834/> (Accessed March 26, 

13 2009). 

14 

15 (NRC, 2009a) U.S. Nuclear Regulatory Commission. Letter from D.H. Dorman (U.S. Nuclear 

16 Regulatory Commission) to A.E. Kennedy (GE-Hitachi Global Laser Enrichment LLC) dated 

17 May 8. “Subject: Approval of GE-Hitachi Exemption Request Related to Commencement of 

18 Construction.” ADAMS Accession No. ML083510647. 

19 

20 (NRC, 2009b) U.S. Nuclear Regulatory Commission. “Enrichment Processes.” 

21 <http://www.nrc.gov/images/reading-rm/photo-gallery/20080922-013.jpg> (Accessed 

22 August 20, 2009). 

23 

24 (NRC, 2010) U.S. Nuclear Regulatory Commission, Press Release “NRC to Hold Public 

25 Meeting Jan. 14 in Hobbs, N.M., to Discuss License Review of Proposed Uranium 

26 De-Conversion Plant.” http://www.nrc.gov/reading-rm/doc-collections/news/2010/10-002.html> 

27 (Accessed January 25, 2010). 

28 

29 (OECD, 2001) Organization for Economic Co-Operation and Development. “Management of 

30 Depleted Uranium.” A joint report by the OECD Nuclear Energy Agency and the International 

31 Atomic Energy Agency. 

32 

33 (Settle, 2004) Settle, F. “Nuclear Chemistry, Uranium Enrichment.” Kennesaw State University. 

34 <http://chemcases.com/nuclear/nc-07.htm> (Accessed March 31, 2009). 

35 

36 (USEC, 1999) United States Enrichment Corporation. “USEC Inc. Suspends AVLIS Technology 

37 Development.” News Release. June 9, 1999. <http://www.usec.com/NewsRoom/ 

38 NewsReleases/USECInc/1999/1999-06-09-USEC-Inc-Suspends-AVLIS.htm> (Accessed 

39 December 3, 2009). 

40 

41 (USEC, 2000) United States Enrichment Corporation. “USEC to Cease Uranium Enrichment at 

42 the Portsmouth, Ohio, Facility in June 2001.” News Release. June 21, 2000. 

43 <http://www.usec.com/NewsRoom/NewsReleases/USECInc/2000/2000-06-21-USEC-To44 Cease-Uranium.htm> (Accessed December 3, 2009). 

45 

46 (USEC, 2001) United States Enrichment Corporation. “What’s a SWU?” 

47 <http://www.usec.com/whatisaswu.htm> (Accessed December 3, 2009). 

48 
2-69 

1 (USEC, 2005) USEC Inc. “Environmental Report for the American Centrifuge Plant in Piketon, 

2 Ohio.” Revision 6. NRC Docket No. 70-7004. November 2005. <http://www.nrc.gov/materials/ 

3 fuel-cycle-fac/usec-american-cent-plant-lic-app.html> (Accessed February 4, 2010). 
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3-1 

1 3 AFFECTED ENVIRONMENT 

2 

3 This chapter describes the existing conditions at and near the site of the proposed General 

4 Electric (GE)-Hitachi Global Laser Enrichment LLC (GLE) Facility in Wilmington, North Carolina 

5 (Figure 2-1), prior to the proposed action and before any preconstruction activities are 

6 performed. After an initial overview of the site location and activities, information is presented 

7 on surrounding 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 levels; transportation systems; public and occupational health 

10 conditions; current waste generation and management practices; socioeconomic conditions; 

11 and environmental justice considerations. This information forms the basis for assessing the 

12 potential impacts (see Chapter 4) of the proposed action. 

13 

14 3.1 Site Location and Description 

15 

16 The proposed GLE Facility would be located approximately 10 kilometers (6 miles) north of the 

17 City of Wilmington in New Hanover County, North Carolina, on the General Electric Company 

18 (GE)/Global Nuclear Fuel Americas (GNF-A), property also referred to as the Wilmington Site 

19 (Section 2.1.1). The site is bordered on the east by North Carolina Highway 133 (NC 133) 

20 (Castle Hayne Road), on the southeastern corner by U.S. Interstate Highway 140 (I-140), on the 

21 southwestern perimeter by the Northeast Cape Fear River, and for most of the north and south 

22 property lines by undeveloped forestlands. A small segment of the north property line borders a 

23 residential subdivision. The Wilmington International Airport is located approximately 

24 5.2 kilometers (3.5 miles) southeast of the Wilmington Site (Figure 1-2). 

25 

26 The Wilmington Site occupies approximately 656 hectares (1621 acres). The proposed GLE 

27 Facility site comprises 106 hectares (263 acres) of the Wilmington Site (GLE, 2009e). It 

28 includes approximately 40 hectares (100 acres) for the proposed GLE Facility in the North29 Central Site Sector, approximately 5 hectares (13 acres) for support structures to the east, and 

30 approximately 12 hectares (29 acres) for the North access road (Figure 2-2). 

31 

32 Nuclear fuel assemblies for commercial light water-cooled nuclear power reactors are currently 

33 fabricated at the Wilmington Site. The fuel manufacturing complex includes the Fuel 

34 Manufacturing Operation (FMO/FMOX) buildings, the Dry Conversion Process (DCP) building, 

35 the Waste Treatment Facility, process basins, and other support facilities. Other existing 

36 facilities on the Wilmington Site include the GE Aircraft Engines/Service Component Operation 

37 (AE/SCO) facility, the Fuel Components Operation (FCO) facility, and the Wilmington Field 

38 Services Center (WFSC). Nonradioactive reactor components are manufactured in the SCO 

39 facility, and nonradioactive components for reactor fuel assemblies are manufactured in the 

40 FCO facility. In the WFSC, equipment used at reactor sites is cleaned and refurbished. Fuel 

41 manufacturing operations are not conducted at the AE facility. The existing facilities are in the 

42 eastern portion of the Wilmington Site (Figure 2-1). 

43 

44 The proposed GLE Facility would occupy approximately 40 hectares (100 acres) within the main 

45 portion of the site (Figure 2-2). The proposed GLE Facility would include the main GLE 

46 operations building, several administrative and other facility-support buildings, a parking lot, 

47 natural and depleted uranium hexafluoride (UF6) storage areas, and maintained landscaped 

48 areas. The proposed GLE Facility would be connected to NC 133 and existing GNF-A facilities 
3-2 

1 either by improving the existing roads or by building a new road segment within the proposed 

2 GLE Facility site (GLE, 2008). 

3 

4 3.2 Land Use 

5 

6 This section describes the land uses on and near the proposed GLE Facility site. The 

7 discussion covers the region within 8 kilometers (5 miles) of the proposed GLE Facility site, 

8 which includes New Hanover, Brunswick, and Pender Counties. 

9 

10 3.2.1 Proposed GLE Facility Site 

11 

12 The location of the proposed GLE Facility is part of the 656-hectare (1,621-acre) Wilmington 

13 Site, which is owned by GE. The proposed GLE Facility site is undeveloped and is currently 

14 covered by mixed pine forest. The western boundary of the Wilmington Site is the Northeast 

15 Cape Fear River. The southern boundary is I-140. Residential developments are found to the 

16 northeast and south of the Wilmington Site. The closest residence to the proposed GLE Facility 

17 site is northeast of the proposed facility on Dekker Road in the Wooden Shoe Subdivision. East 

18 of the Wilmington Site across Castle Hayne Road is the North Carolina State University 

19 Horticultural Crops Research Station, which has existed in this location since 1947. Several 

20 mobile homes are located north of the Wilmington Site along Castle Hayne Road. None of the 

21 Wilmington Site is designated prime farmland. No properties listed on the National Register of 

22 Historic Places (NRHP) are located within 8 kilometers (5 miles) of the proposed GLE Facility 

23 site. 

24 

25 The proposed GLE Facility site is located in an unincorporated portion of New Hanover County, 

26 North Carolina. The proposed GLE Facility site is 10.4 kilometers (6.5 miles) north of 

27 Wilmington, North Carolina, and on the eastern bank of the Northeast Cape Fear River. The 

28 zoning of the proposed GLE Facility site is under the jurisdiction of the New Hanover County 

29 Planning Board. The proposed GLE Facility site is zoned I-2, heavy industrial zone (New 

30 Hanover County, 2009b). This zoning class is the least restrictive, in that it allows the widest 

31 range of land uses. Examples of current industries within this zoning are the BASF Corporation 

32 and the Elementis Chromium manufacturing plants, and the L.V. Sutton Steam Electric Plant to 

33 the west. Several sand and gravel quarries are northeast of the proposed GLE Facility site, 

34 including the Martin Marietta Materials operation, which is a crushed stone mining and 

35 processing facility. The area to the southwest is also zoned I-2 (Figure 3-1). The area 

36 immediately to the south of the proposed GLE Facility site is zoned PD, planned development 

37 district. This designates an area with mixed uses, including residential, commercial, industrial, 

38 office, and institutional. The entire area north of the proposed GLE Facility site is zoned RA, 

39 rural agriculture, which allows for low-density residential with an emphasis on farming and open 

40 space. The areas to the east and southeast are zoned R-20, which indicates low-density 

41 residential (New Hanover County, 2009b). 

42 

43 Several residential developments are proposed in the vicinity of the Wilmington Site. These 

44 include a 600-lot residential development called Rose Hill Plantation south of the Wilmington 

45 Site, which would include a nursing home. Other proposals are for the Sunset Reach 53-lot 

46 residential development, the Blue Clay Farms development of 1800 units, and Parson’s Mill with 

47 300 lots for residential development (New Hanover County, 2009c). In addition, a new 
3-3 

Figure 3-1 Land Use within 8 kilometers (5 miles) of the Project Area 
3-4 

1 elementary school and middle school are in the process of being completed in the Castle Hayne 

2 community to the northeast of the proposed GLE Facility site (Figure 1-1). 

3 

4 To implement the Federal Coastal Zone Management Act (CZMA), North Carolina passed a 

5 Coastal Area Management Act (CAMA) in 1974 that requires coastal counties to develop land 

6 use plans. New Hanover County and the City of Wilmington chose to develop a joint land use 

7 plan. The Wilmington−New Hanover County Joint Coastal Area Management Plan 2006 

8 Update was approved in May 2006 by the North Carolina Coastal Resources Commission. This 

9 update identifies the proposed GLE Facility site as a Wetland Resource Protection Area, with 

10 the eastern portion of the proposed GLE Facility site in an Aquifer Resource Protection Area 

11 (City of Wilmington and New Hanover County, 2006). The purpose of the Wetland Resource 

12 Protection Area is to minimize the loss or degradation of wetlands. The Aquifer Resource 

13 Protection Area is intended to protect areas from diminished recharge of the aquifer and to 

14 prevent contamination of the aquifer. The area north and northwest of the proposed GLE 

15 Facility site was designated a Conservation Area by the 2006 Wilmington−New Hanover Plan. 

16 The purpose of the conservation class is to provide long-term management and protection of 

17 significant natural resources, taking into consideration the rights of property owners. 

18 

19 3.2.2 New Hanover County 

20 

21 New Hanover County is a coastal county in the southeastern portion of North Carolina. The 

22 county is bordered on the east and south by the Atlantic Ocean, on the southwest by Brunswick 

23 County, and on the north by Pender County. The Cape Fear River forms the boundary between 

24 New Hanover and Brunswick Counties. The proposed GLE Facility site is located in the 

25 northwestern corner of the county. The largest municipality in the county is Wilmington, which 

26 has a population of 97,135 (City of Wilmington and New Hanover County, 2006) and serves as 

27 the county seat. The next three largest communities are Carolina Beach (population 4701; 

28 31 kilometers [19 miles] from the proposed GLE Facility site), Kure Beach (population 1507; 

29 32 kilometers [20 miles] from the proposed GLE Facility site), and Wrightsville Beach 

30 (population 2593; 18 kilometers [11 miles] from the proposed GLE Facility site) (USCB, 2000). 

31 

32 Land cover in New Hanover County is primarily developed land (35 percent), followed by 

33 wetlands (26 percent), forest (16 percent), and grassland/cultivated fields (15 percent). The 

34 remaining 8 percent is comprised of open water (EPA, 2001). 

35 

36 Four State-designated use areas are within 8 kilometers (5 miles) of the proposed GLE Facility 

37 site. Two of these areas are the Cape Fear River Wetlands Game Land and the Sutton Lake 

38 Game Land, which are leased by the North Carolina Wildlife Resources Commission from 

39 Progress Energy. These areas are managed for the benefit of hunters. The other two areas 

40 are the North Chase Bottomlands Preserve and the Cape Fear Royal Tracts, which are 

41 maintained by the North Carolina Land Trust (Figure 3-1). The land trust manages its properties 

42 to retain their natural qualities. 

43 

44 3.2.3 Brunswick County 

45 

46 Brunswick County is located west of the proposed GLE Facility site. The county’s population in 

47 2000 was 73,141 (Brunswick County, 2006). The county’s population concentrates in the 

48 eastern portion of the county along the Cape Fear River and along the Atlantic shoreline to the 
3-5 

1 south. The major municipalities in Brunswick County are Oak Island (population 6571; 

2 51 kilometers [31 miles] from the proposed GLE Facility site), Southport (population 2351; 

3 47 kilometers [29 miles] from the proposed GLE Facility site), Leland (population 1938; 

4 13 kilometers [8 miles] from the proposed GLE Facility site), and Boiling Spring Lakes 

5 (population 3866; 37 kilometers [23 miles] from the proposed GLE Facility site) (USCB, 2000). 

6 The county seat is Bolivia. The county has developed a CAMA plan that was approved in 2007. 

7 Several of the municipalities in the county have chosen to develop their own CAMA plans, 

8 including Bald Head Island, Calabash, Caswell Beach, Holden Beach, Shallotte, Southport, 

9 Sunset Beach, and Varnamtown (NCDCM, 2010). 

10 

11 Land cover in Brunswick County is primarily forest (35 percent), wetlands (32 percent), and 

12 grassland/cultivated fields (23 percent). The remaining land cover is split between development 

13 (8 percent) and open water (2 percent) (EPA, 2001). 

14 

15 3.2.4 Pender County 

16 

17 Pender County is located north of the proposed GLE Facility site and covers roughly 241 square 

18 kilometers (93 square miles). The total population is 48,724. Development in Pender County is 

19 concentrated in the center of the county along I-40 and in the southeast along the coast. The 

20 county seat for Pender County is Burgaw (23 kilometers [14 miles] from the Wilmington Site). 

21 The closest Pender County municipality is St. Helena (19 kilometers [11.8 miles] to the 

22 Wilmington Site). The portion of Pender County nearest the Wilmington Site is zoned as 

23 conservation area, rural, and rural clusters (Pender County, 2006). 

24 

25 The land cover in Pender County is primarily wetlands (41 percent), forests (27 percent), and 

26 grassland/cultivated fields (27 percent). The remaining land covers are development 

27 (4 percent) and open water (1 percent) (EPA, 2001). 

28 

29 3.3 Historic and Cultural Resources 

30 

31 This section discusses the cultural background and the known historic and cultural resources at 

32 the proposed GLE Facility and in the surrounding area. 

33 

34 3.3.1 Prehistoric 

35 

36 Prehistory in North America ranges from roughly 10,000 B.C. to A.D. 1500. Prehistory is 

37 divided into several periods that are marked by changes in technology (e.g., projectile point 

38 shapes, pottery types) and changes in subsistence patterns, which often reflect wider changes 

39 in the environment. The following is a description of the various prehistoric periods found in 

40 southeastern North America. 

41 

42 3.3.1.1 Paleo-Indian Period 

43 

44 The Paleo-Indian period (10,000 B.C. to 8000 B.C.) contains the first confirmed evidence of 

45 people in southeastern North America. The Paleo-Indian period is poorly understood. The 

46 Paleo-Indian period was a time of climatic change and of glacial retreat. Large mammals that 

47 were adapted to the colder climate were plentiful but in decline. The overall climate was cooler 

48 than today, with ocean levels more than 61 meters (200 feet) lower because of the water 
3-6 

1 trapped in the glaciers. Intact evidence of these early people in North America is scarce. It is 

2 theorized that much of the evidence of human activity from this period is now submerged under 

3 the ocean. Human activity tended to concentrate in coastal regions. The coastal shoreline 

4 during the Paleo-Indian period was much farther out than the modern coast. Once the glaciers 

5 retreated, sea levels rose and inundated the sites. On the basis of variations observed in 

6 projectile point types, there appears to have been some societal shift as the Paleo-Indian period 

7 progressed. All projectile points found in the Paleo-Indian period are of the spear or lance type 

8 and include the Clovis, Cumberland, Suwanee, Simpson, Dalton, and Hardaway point types 

9 (ESI, 2008). 

10 

11 3.3.1.2 Archaic Period 

12 

13 The Archaic period (8000 B.C. to 1000 B.C.) covers the period following the end of the glacial 

14 retreat. During this period, the climate began stabilizing, modern flora and fauna were 

15 developing, and populations across North America were increasing. Subsistence strategies 

16 expanded to include capturing smaller game, such as rabbits, than was seen in the big game 

17 hunting cultures of the Paleo-Indian period. A greater reliance on gathering nuts and seeds also 

18 is evident during the Archaic period. These adaptations suggest a more intensive use of the 

19 landscape, which may have been a result of greater population sizes. These adaptations are 

20 significant since the Paleo-Indian cultures were largely homogeneous across North America. 

21 

22 The Archaic period is divided into Early, Middle, and Late periods. The Early Archaic period 

23 (8000 B.C. to 6000 B.C.) saw the continuation of the trends established during the Paleo-Indian 

24 period. Glacial retreat, sea level rise, and a moderating of the climate are all indicative of the 

25 Early Archaic period. A change in projectile points and other stone (lithic) artifacts led to the 

26 defining of an Archaic period. A significant climatic shift to drier and warmer weather 

27 accompanies the Middle Archaic period (6000 B.C. to 3000 B.C.). In North Carolina, there 

28 appears to have been a shift away from the subsistence use of the higher elevations of the 

29 Appalachians and Piedmont region to the lower coastal plain and major river valleys 

30 (ESI, 2008). The first widespread evidence of shellfish use is noted during the Middle Archaic 

31 period. Regional adaptations become evident during the Middle Archaic period. The modern 

32 climate develops in the Late Archaic period (3000 B.C. to 1000 B.C.). Temperatures moderate 

33 and rainfall increases during the Late Archaic period. Ocean levels stabilized and wetlands 

34 increased significantly (ESI, 2008). The first ceramics appear toward the latter half of the Late 

35 Archaic period. Evidence of long-distance trade also is evident in the Late Archaic period. Site 

36 types include villages, short-term use sites, resource procurement camps, and cemeteries. 

37 

38 3.3.1.3 Woodland Period 

39 

40 The Woodland period (1000 B.C. to A.D. 1000) in Eastern North America is usually associated 

41 with three major technological innovations – horticulture, pottery, and the bow and arrow. Along 

42 with the development of horticulture comes a more sedentary way of life. In the Southeastern 

43 portion of North America, reliance on horticulture came late in the Woodland period, roughly 

44 around A.D. 200 to A.D. 400 and was not widespread until around A.D. 1000 (ESI, 2008). 

45 Pottery use began in the Late Archaic period but became widespread during the Woodland 

46 period. Pottery styles are used to differentiate between the Early, Middle, and Late Woodland 

47 periods in the region. Another defining factor for the Woodland period was burial practices. 

48 Burials become more elaborate during the Woodland period and involve mounds and in some 
3-7 

1 cases ceramic ossuaries. Most Native groups encountered by Europeans practiced Woodland 

2 cultural patterns (Claggett, 1996). 

3 

4 A group known as the Mississippian Culture (A.D. 1000 to A.D. 1650) was also found in North 

5 Carolina in the late prehistoric period. Mississippian cultural groups engaged in many of the 

6 practices associated with the Woodland period; however, there is evidence for a higher level of 

7 social and political hierarchy. Mississippian cultural groups were living in North Carolina 

8 alongside Woodland peoples. 

9 

10 3.3.2 Ethno-Historic 

11 

12 Information on the native populations preceding European contact is poor for several reasons. 

13 Native groups from this part of North Carolina left or were removed shortly after European 

14 contact. Early European records provide an inaccurate description of the native groups that 

15 were encountered. Through research and archaeological excavation, some information is 

16 available. The groups living in south-central North Carolina fell between two well-defined 

17 cultural traditions, those of the southeast and the northeast. Cultural traditions in the region 

18 appear to be consistent with Woodland cultures. Mississippian influences are possible but are 

19 not easily identifiable in the archaeological record. Excavation in the Cape Fear River area 

20 suggests that there may be ties to the Piedmont region and the tribes that resided there (Russ 

21 and Postlewaite, 2008). Modern tribal organizations that claim ancestral ties to North Carolina 

22 include the Indians of Persons County, Haliwa-Saponi, Coharie, Cumberland County 

23 Association of Indian People, Lumbee, Waccamaw-Siouan, Guilford Native American 

24 Association, Metrolina Native American Association, and the Eastern Band of Cherokee Indians 

25 (NCCIA, 2004). 

26 

27 3.3.3 Historic Euro-American 

28 

29 European presence in the North American southeast began in 1524 when Giovanni da 

30 Verrazano traveled along the coast of what would become North Carolina. Spanish and English 

31 exploration of the area continued throughout the latter half of the sixteenth century. The English 

32 attempted to establish a colony on Roanoke Island in 1587; the colony failed within three years. 

33 The first successful European settlement in the region was the English colony of Jamestown in 

34 1607. The first settlement on the Cape Fear River came in the 1660s by English settlers; 

35 however, the settlement only lasted a few years. Permanent settlement on the Cape Fear River 

36 did not occur until the eighteenth century. The town of Brunswick was established at the mouth 

37 of the Cape Fear River in 1726. New Hanover County was created in 1729. In the 1730s, the 

38 town of Newton was settled at the juncture of the Northeast and Cape Fear Rivers. In 1740, the 

39 town of Newton was incorporated as Wilmington. Once Wilmington was established, the town 

40 of Brunswick deteriorated and was eventually abandoned after 1781. Wilmington became an 

41 important town for supplying the shipping trade. During the American Revolution, the British 

42 commander Lord Cornwallis occupied Wilmington for three weeks in 1781. After the revolution, 

43 an agrarian economy based on plantations flourished along the Cape Fear River. Wilmington 

44 became one of the major ports along the eastern seaboard. Railroads were built to the city in 

45 the 1840s. Wilmington served as a key part of the Confederate supply line during the American 

46 Civil War. Fort Fisher protected the port, but Union troops took it in the winter of 1864 to 1865. 

47 Union troops took possession of Wilmington in February 1865. After the Civil War, Wilmington 

48 became a major textile port. Several textile factories operated in Wilmington. In the 
3-8 

1 twentieth century, the economy diversified further to include large shipyards. The shipyards 

2 expanded during World War II (ESI, 2008). 

3 

4 The region containing the proposed GLE Facility site was once part of the Rose Hill plantation, 

5 which was first established in 1736. Other nearby plantations included Castle Hayne, The 

6 Hermitage, Point Pleasant, Rocky Run, and Rock Hill. The first major structure built at the 

7 plantation was constructed in 1769. Indications are that the plantation focused mainly on rice 

8 production. The property remained intact until after the American Civil War. With the abolition 

9 of slavery, the property was eventually sold off in 20-hectare (50-acre) plots. The land was 

10 owned by Gore Estate Corporation in the 1920s and is currently owned by GE (ESI, 2008). 

11 

12 3.3.4 Historic and Archaeological Resources at the Proposed GLE Site 

13 

14 There are 799 archaeological sites recorded in New Hanover County, North Carolina. Fifteen 

15 archaeological sites and one shipwreck are within 500 meters (1640 feet) of the proposed GLE 

16 Facility site. Archaeological surveys conducted in 1978 and 1994 examined areas in the vicinity 

17 of the proposed GLE Facility site and identified numerous prehistoric archaeological sites. The 

18 1978 research conducted by Wilde-Ramsing identified numerous archaeological sites; however, 

19 the methods used during the survey make the findings difficult to verify (Wilde-Ramsing, 1978). 

20 The 1994 survey (Klein et al., 1994) was undertaken for the construction of a Wilmington 

21 Bypass and reinvestigated some of the sites identified in 1978 that are in close proximity to the 

22 proposed GLE Facility site. The 1994 survey identified a cluster of Middle Woodland 

23 archaeological sites that the authors recommended as an archaeological district (Klein et al., 

24 1994). The district, which consists of 11 sites, is partially located on the Wilmington Site. 

25 

26 Archaeological surveys conducted for the proposed action identified three archaeological sites 

27 (ESI, 2008). The surveys relied on a combination of pedestrian investigation of exposed soils 

28 and shovel testing at 30-meter (100-foot) intervals with 15-meter (50-foot) intervals used for 

29 archaeological site investigations. The three discovered sites, 31NH800, 31NH801, and 

30 31NH804, are the remains of two historic-age sites and a prehistoric site. Site 31NH800 

31 appears to be the remains of a farmstead, consisting of artifacts from the eighteenth to 

32 twentieth centuries. Site 31NH801 is the remains of a Middle Woodland prehistoric site. 

33 Artifacts recovered from the site include ceramics, lithic tools, and animal bone fragments. Site 

34 31NH804 is a historic site dating to the late 19th to mid-20th century. In consultation with the 

35 North Carolina State Historic Preservation Office (SHPO), it was determined that sites 31NH800 

36 and 31NH804 are not eligible for listing on the NRHP, while site 31NH801 is eligible for listing. 

37 

38 3.4 Visual and Scenic Resources 

39 

40 Visual impacts occur when contrasts are introduced into the existing environment. 

41 Consideration when determining visual or scenic effects from a project are its proximity to 

42 viewing locations and the number of people expected to view the project. The proposed GLE 

43 Facility site is within the boundaries of GE’s existing Wilmington Site. The existing GE facilities 

44 (GNF-A FMO and GE AE/SCO) are most visible from the east and southeast near the 

45 I-140/Castle Hayne Road interchange. Figure 3-2 shows one of the two entrances to the 

46 Wilmington Site (North Entrance) from Castle Hayne Road just north of the I-140 interchange. 

47 The tallest existing site feature is a water tower that is 39.6 meters (130 feet) tall (Figures 3-2 
3-9 

1 

2 Figure 3-2 South Entrance from Castle Hayne Road to the Wilmington Site (GLE, 2008) 

3 

4 and 3-3). The closest residences are located northeast of the site and back to Sledge Road, 

5 which forms the northeastern boundary of the Wilmington Site (Figure 2-1). Existing vegetation 

6 largely blocks the view to Sledge Road from these locations (Figure 3-4). At the closest visible 

7 point, features of the site that are perceivable can only be seen from the rear of the residences. 

8 The GE facilities are not visible from Dekker Road. A stand of pine trees lies between Sledge 

9 Road and the main portion of the existing Wilmington Site and largely screens the existing 

10 facilities from these residences. 

11 

12 The proposed GLE Facility would be located to the west-northwest of the existing Wilmington 

13 Site. The facility would be visible from the residences along the south side of Dekker Road and 

14 from I-140 to the south. The entrance to the facility would be visible along Castle Hayne Road. 

15 However, the bulk of the proposed GLE Facility would be blocked from view by existing site 

16 structures. 

17 

18 The topography of the Wilmington Site is relatively flat. The area gently slopes down toward the 

19 Cape Fear River. The existing site is visually screened on the north and west by a pine 

20 plantation. Since the trees are evergreens, there is no seasonal variation in the visual screen 

21 surrounding the site. However, the understory does change in the winter months. 

22 

23 To the west of the Wilmington Site lies the Northeast Cape Fear River. The L.V. Sutton Steam 

24 Electric Plant is on the western bank of the Northeast Cape Fear River across from the site. 

25 Portions of the power plant are visible from the river. The existing Wilmington Site is not visible 

26 from the Cape Fear River because of vegetation and the change in elevation.
3-10 

Figure 3-3 Existing Site Water Tower Viewed from South of I-140 (GLE, 2008) 

Figure 3-4 Closest Residence to the Proposed GLE Facility Site Viewed from the 

North Access Road (GLE, 2008)
3-11 

1 The U.S. Department of the Interior’s (DOI’s) Bureau of Land Management (BLM) has 

2 developed a process for considering visual resources (BLM, 2009). While the BLM’s Visual 

3 Resource Management system is officially only applicable to BLM land, it provides a useful 

4 framework for considering visual resources. The BLM process involves conducting an inventory 

5 of the visual landscape to determine the sensitivity of the location to visual intrusions, the scenic 

6 qualities of a location, and the distance from which the location would be viewed. Sensitivity 

7 refers to the public’s concern or expectation for scenic quality. Sensitivity is based on the types 

8 of users that would view the location (e.g., recreational users, commuters, and workers), the 

9 amount of use, public interest, and adjacent land uses. Scenic quality is a subjective rating of 

10 the visual setting. The scenic quality criteria applied to a landscape are presented and 

11 described in Table 3-1. Examples of how to apply the criteria are presented in Table 3-2. 

12 Distance considerations are a factor primarily when considering large vistas. It is not expected 

13 that any portion of the proposed GLE Facility would be perceivable beyond 8 kilometers 

14 (5 miles) (BLM, 2009). 

15 

16 Sensitivity is the main factor to be considered, because it addresses the expectation for pristine 

17 environments. The Wilmington Site is located in an industrialized area and is adjacent to a 

18 power plant, existing manufacturing facilities, and quarries. The expectation for a pristine 

19 natural viewshed would be low for such an area. Most users of the area would be commuters 

20 and workers, neither of which would be very sensitive to alterations to the visual quality of the 

21 area. The closest recreational users would be those using the Northeast Cape Fear River. 

22 Because of the vegetation cover and sloping topography, the proposed GLE Facility site would 

23 not visible from the river. The users most affected would be homeowners along Dekker Road. 

24 While the changes would be most evident for these residential viewers, they represent a very 

25 small fraction of users. The sensitivity of the proposed GLE Facility site is low. 

26 

27 The scenic quality of the area is determined through application of the scenic quality rating 

28 criteria, which include landform, vegetation, water, color, adjacent scenery, scarcity, and cultural 

29 modification. These criteria are explained in Table 3-1. Table 3-2 explains how numerical 

30 ratings are assigned for each criterion. For the proposed GLE Facility site, the landform is 

31 gently sloping river floodplain that does not contain any dramatic elements (Rating = 1). The 

32 vegetation is uniformly pine trees with leafy understory (Rating = 1). The closest water to the 

33 proposed GLE Facility site is the Northeast Cape Fear River. However, the river is not visible 

34 from the proposed GLE Facility site because of slope and vegetation cover (Rating = 0). The 

35 color range in the proposed GLE Facility site is uniform and consists entirely of evergreen trees 

36 (Rating = 1). Adjacent scenery is similar to that found in the proposed GLE Facility site and 

37 does not influence the visual quality (Rating = 0). There are no rare features associated with 

38 the proposed GLE Facility site; it is consistent with much of the surrounding region (Rating = 1). 

39 Cultural modifications would alter the view but are consistent with what is found in the 

40 surrounding area (Rating = −2). The overall scenic quality rating (i.e., the sum of the ratings for 

41 each criterion) is 2, which would make the scenic quality a C or lower. This rating, which is the 

42 lowest relative scenic quality rating, indicates that the project area has little scenic quality 

43 compared to other locations in the region. The sum would need to be 12 or more for a scenic 

44 quality rating of B, and 19 or more for a scenic quality rating of A. 

45 
3-12 

Table 3-1 Explanation of Scenic Quality Rating Criteria 

Landform Topography becomes more interesting as it gets steeper or more massive, or more severe

sculptured. Outstanding landforms may be monumental, as the Grand Canyon, the Sawto

Range in Idaho, the Wrangell Mountain Range in Alaska, or they may be exceedingly artis

certain badlands, pinnacles, arches, and other extraordinary formations. 

Vegetation Give primary consideration to the variety of patterns, forms, and textures created by plant l

short-lived displays when they are known to be recurring or spectacular. Consider also smvegetational features which add striking and intriguing detail elements to the landscape (e.

windbeaten trees and joshua trees). 

Water That ingredient which adds movement or serenity to a scene. The degree to which water d

scene is the primary consideration in selecting the rating score. 

Color Consider the overall color(s) of the basic components of the landscape (e.g., soil, rock, veg

they appear during seasons or periods of high use. Key factors to use when rating “color” 

contrast, and harmony. 

Adjacent Scenery Degree to which scenery outside the scenery unit being rated enhances the overall impres

scenery within the rating unit. The distance which adjacent scenery will influence scenery 

unit will normally range from 0 to 8 kilometers (0 to 5 miles), depending upon the charactertopography, the vegetative cover, and other such factors. This factor is generally applied twould normally rate very low in score, but the influence of the adjacent unit would enhance quality and raise the score. 

Scarcity This factor provides an opportunity to give added importance to one or all of the scenic fea

appear to be relatively unique or rare within one physiographic region. There may also be separate evaluation of each of the key factors does not give a true picture of the overall sc

area. Often it is a number of not so spectacular elements in the proper combination that pmost pleasing and memorable scenery – the scarcity factor can be used to recognize this t

give it the added emphasis it needs. 

Cultural Modifications Cultural modifications in the landform/water, vegetation, and addition of structures should b

and may detract from the scenery in the form of a negative intrusion or complement or impquality of a unit. Rate accordingly. 

Source: BLM, 2009.
3-13 

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 size and shape of landforms; or detail features which are interesting though not dominant or exceptional. (3) 

Low rolling hflat valley bono interestinfeatures. (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 vin vegetation

Water Clear and clean appearing, still, or 

cascading white water, any of which are a dominant factor in the landscape. (5) 

Flowing, or still, but not dominant in the landscape. (3) 

Absent, or pnoticeable. 

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 contrast of the soil, rock and vegetation, but not a dominant scenic element. (3) 

Subtle color contrast, or imute tones. 

Adjacent Scenery 

Adjacent scenery greatly enhances visual quality. (5) 

Adjacent scenery moderately enhances overall visual quality. (3) 

Adjacent sceno influence 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, though somewhat similar to others within the region. (3) 

Interesting wbut fairly comregion. (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 introduce no discordant elements. (0) 

Modifications are very discpromote stro(-4) 

Source: BLM, 2009.
3-14 

1 3.5 Climatology, Meteorology, and Air Quality 

2 

3 This section describes the climatology, meteorology, and air quality in the area surrounding the 

4 proposed GLE Facility in Wilmington, North Carolina. This information provides general 

5 background conditions and would be used as baseline conditions for the potential impact 

6 analysis under various alternatives in Chapter 4. 

7 

8 3.5.1 Regional Climatology 

9 

10 With its nearly 2042-meter (6700-foot) range in elevation and 483-kilometer (300-mile) range in 

11 distance from the ocean, North Carolina experiences one of the most diverse climates of any 

12 eastern State (NCDC, 2009a). The climate of North Carolina varies from the Atlantic Coast in 

13 the east to the Appalachian Range in the west. The mountain range in the west often blocks 

14 cold temperatures and storms from the Midwest and Canada. Most of the State has a humid 

15 subtropical climate (Cfa) by Koppen climate classification, except higher elevations in the west 

16 (University of Idaho, 2009). 

17 

18 Warm and humid maritime tropical air from the Gulf of Mexico flows into North Carolina during 

19 all seasons, while cold and dry continental polar air masses from Canada penetrate into the 

20 area but rarely in summer (Robinson, 2005). These air masses, the jet stream and its 

21 accompanying polar front, and the Bermuda High pressure system influence the weather 

22 system in North Carolina, depending on their relative positions and intensities. In the summer, 

23 the jet stream is situated near the United States−Canadian border, while the Bermuda High is 

24 mostly centered over Bermuda. Accordingly, North Carolina is more affected by the Bermuda 

25 High than the polar front. In some summers, the Bermuda High expands or moves westward 

26 and sits on the Coastal Plain, causing drought there. In the winter, the Bermuda High weakens 

27 as it shrinks south and east. This allows the jet stream to push far south well into the east28 central United States, which causes the polar front to move into a position to directly influence 

29 weather in the Carolinas with deep lows and extensive frontal systems. In addition, the warm 

30 Gulf Stream and cold Labrador Current play a pivotal role in the weather of coastal 

31 North Carolina (NCDC, 2009a). The confluence of two opposite currents at the north of the 

32 Outer Banks of North Carolina produces a wide variety of weather, including the development of 

33 major storms, which cause rains along the coast and inland areas as well. At the Outer Banks, 

34 the Labrador Current passes between the Gulf Stream lying 80 kilometers (50 miles) offshore 

35 and the coast, which offsets most of the general warming effect that the Gulf Stream might 

36 otherwise have on coastal temperatures. 

37 

38 The proposed GLE Facility would be located in the tidewater section of southeastern 

39 North Carolina, near the Atlantic Ocean, which is located about 16 kilometers (10 miles) to the 

40 southeast. Because of its proximity to the Atlantic Ocean, the area experiences an unusually 

41 mild climate and small diurnal and seasonal temperature ranges, compared with a continental 

42 type of climate at a comparable latitude. In general, the summers are quite warm and humid 

43 with rare excessive heat. During the winter, numerous polar air masses can penetrate the 

44 Atlantic Coast and result in abrupt drops in temperatures (NCDC, 2009b). However, these cold 

45 outbreaks are considerably moderated by long trajectories from the source regions, the effects 

46 of passing over the Appalachian Range, and the moderating effects of the ocean air in the area. 

47 Accordingly, most winters in the area are short and quite mild. 
3-15 

1 3.5.2 Site and Regional Meteorology 

2 

3 Real-time meteorological data (e.g., wind speed and direction, barometric pressure) are 

4 collected by GNF-A at a level of 6.1 meters (20 feet) for emergency response purposes, but 

5 these data are not recorded. In view of the longer period of record available at the 

6 Wilmington/New Hanover County Airport, the NRC staff used that data to assess the 

7 meteorological and climatological conditions representative of the general region surrounding 

8 the proposed GLE Facility. The airport is located approximately 8 kilometers (5 miles) 

9 southeast of the proposed GLE Facility. The general topography of the Wilmington area is flat, 

10 with little to no change in elevation. 

11 

12 3.5.2.1 Temperature 

13 

14 Table 3-3 presents monthly average and daily extreme temperatures at the Wilmington/New 

15 Hanover County Airport, North Carolina. Compared with farther inland stations, temperatures 

16 around the proposed GLE Facility are moderate because of proximity to the Atlantic Ocean. For 

17 the 1971 to 2000 period, the annual average temperature was 17.7° Celsius (63.8° Fahrenheit), 

18 ranging from 11.9 to 23.3° Celsius (53.5° Fahrenheit to 74.0° Fahrenheit) (NCDC, 2009b). 

19 

Table 3-3 Monthly Average and Daily Extreme Temperatures 

at the Wilmington/New Hanover County Airport, North Carolina

 Monthly Averagesa

 Daily Extremesb

 Mean Minimum Maximum Lowest Minimum Highest Maximum 

Month ° Celsius 

(° Fahrenheit) 

° Celsius 

(° Fahrenheit)

° Celsius 

(° Fahrenheit)

° Celsius 

(° Fahrenheit) Year ° Celsius (° Fahrenheit) Year

Jan. 7.8 (46.1) 2.1 (35.8) 13.5 (56.3) -15.0 ( 5) 1985 27.8 ( 82) 1975

Feb. 9.2 (48.5) 3.1 (37.5) 15.3 (59.5) -11.7 (11) 1996 29.4 ( 85) 1962

Mar. 12.8 (55.0) 6.5 (43.7) 19.0 (66.2) -12.8 ( 9) 1980 31.7 ( 89) 1974

Apr. 17.1 (62.7) 10.7 (51.2) 23.4 (74.1) -1.7 (29) 2007 35.0 ( 95) 1967

May 21.2 (70.2) 15.4 (59.8) 27.0 (80.6) 3.3 (38) 1989 36.7 ( 98) 1953

June 25.0 (77.0) 19.8 (67.6) 30.2 (86.4) 8.9 (48) 1983 40.0 (104) 1952

July 27.3 (81.1) 22.4 (72.3) 32.2 (89.9) 12.8 (55) 1988 38.9 (102) 1977

Aug. 26.5 (79.7) 21.7 (71.0) 31.3 (88.3) 12.8 (55) 2004 39.4 (103) 1999

Sept. 23.9 (75.0) 18.8 (65.9) 28.9 (84.1) 6.7 (44) 1981 36.7 ( 98) 1975

Oct. 18.2 (64.8) 12.2 (53.9) 24.2 (75.6) -2.8 (27) 1962 35.0 ( 95) 1986

Nov. 13.6 (56.5) 7.3 (45.1) 19.9 (67.8) -6.7 (20) 1970 30.6 ( 87) 1974

Dec. 9.4 (48.9) 3.4 (38.1) 15.3 (59.6) -17.8 ( 0) 1989 27.8 ( 82) 1998

Annual 17.7 (63.8) 11.9 (53.5) 23.3 (74.0) -17.8 ( 0)

Dec. 

1989 40.0 (104) 

June 

1952 a 1971 to 2000 climate normals. 

b

 Period of record is 57 years (1952 to 2008). 

Source: NCDC, 2009b.
3-16 

1 January is the coldest month, averaging 7.8° Celsius (46.1° Fahrenheit) with temperature 

2 ranging from 2.1° Celsius to 13.5° Celsius (35.8° Fahrenheit to 56.3° Fahrenheit), and July is 

3 the warmest month, averaging 27.3° Celsius (81.1° Fahrenheit) with temperature ranging from 

4 22.4° Celsius to 32.2° Celsius (72.3° Fahrenheit to 89.9° Fahrenheit). During the last 57 years, 

5 the lowest temperature, −17.8° Celsius (0° Fahrenheit), was reached in December 1989, and 

6 the highest, 40.0° Celsius (104° Fahrenheit), in June 1952. About 46.3 days have a maximum 

7 temperature greater than or equal to 32.2° Celsius (90° Fahrenheit), while 39.3 days have a 

8 minimum temperature less than or equal to 0° Celsius (32° Fahrenheit). 

9 

10 3.5.2.2 Precipitation and Relative Humidity 

11 

12 Generally, precipitation in North Carolina is relatively ample in most parts of the State (greater 

13 than 102 centimeters [40 inches]). The mean annual precipitation is heaviest in the 

14 southeastern corner of the State, which includes the proposed GLE Facility, and gradually 

15 decreases toward the north and west. Table 3-4 presents summaries of monthly mean and 

16 extreme precipitation and snowfall at the Wilmington/New Hanover County Airport. Annual 

17 precipitation averages about 145.0 centimeters (57.07 inches) (NCDC, 2009b). Precipitation in 

18 the area is well distributed throughout the year; it is driest in April and wettest in July. By 

19 season, precipitation is the highest in summer, accounting for about 36 percent of the annual 

20 total, and precipitation is comparable in other seasons. Summer rainfall is associated primarily 

21 with thunderstorms, and is therefore usually of a short duration, but often heavy and unevenly 

22 distributed. Minimum and maximum monthly precipitations are 0.4 centimeters (0.16 inches) 

23 and 59.5 centimeters (23.41 inches), respectively. The highest 24-hour precipitation was 

24 37.7 centimeters (14.84 inches) in September 1999. Measurable precipitation of 

25 0.025 centimeters (0.01 inches) or more occurred about one-third of the time (118.1 days 

26 per year). 

27 

28 Appreciable wintry precipitation, such as snow, sleet, or freezing rain, is a rarity and, when it 

29 occurs, remains on the ground for a short time. Light snow typically occurs from December 

30 through March, and the annual average snowfall in the area is about 5.3 centimeters 

31 (2.1 inches). The greatest amounts of snow reported in a single month and in a 24-hour period 

32 were 38.9 centimeters (15.3 inches) in December 1989, and 29.7 centimeters (11.7 inches) in 

33 February 1973, respectively (NCDC, 2009b). 

34 

35 Because of the proximity to the Atlantic Ocean, Wilmington experiences higher relative humidity 

36 and smaller monthly variations than farther-inland locations at a comparable latitude. The 

37 annual average relative humidity is about 74 percent, with the lowest monthly average of 

38 68 percent in April and the highest monthly average of 80 percent in August (NCDC, 2009b). 

39 During the day, the lowest annual-average relative humidity of 57 percent occurs in the early 

40 afternoon and the highest of 85 percent in the early morning and the middle of the night. 

41 

42 3.5.2.3 Winds, Atmospheric Stability, and Temperature Inversions 

43 

44 Figure 3-5 presents a wind rose at the 10-meter (33-foot) level of Wilmington/New Hanover 

45 County Airport based on 2004 to 2008 wind data. The average annual wind speed is about 

46 3.4 meters per second (7.6 miles per hour), and calm winds are recorded about 18 percent of 

47 the time (NCDC, 2009c). Albeit not prominent, the prevailing wind direction is from the 

48 southwest (about 9.7 percent of the time) and secondarily from the north-northeast (9.0 percent) 
3-17 

Table 3-4 Monthly Mean and Extreme Precipitation and Snowfall 

at the Wilmington/New Hanover County Airport, North Carolina

Precipitation Snowfall

Meana Minimumb Maximumb Maximum 24-hourb Meana Maximumb M

Month cm (in.) cm (in.) Year cm (in.) Year cm (in.) Year cm (in.) cm (in.) Year 

Jan. 11.5 (4.52) 1.7 (0.68) 2001 26.0 (10.22) 1991 7.8 (3.08) 1982 1.5 (0.6) 15.5 (6.1) 2000 Feb. 9.3 (3.66) 2.6 (1.01) 1976 28.5 (11.22) 1998 12.7 (5.00) 1998 1.3 (0.5) 31.8 (12.5) 1973 Mar. 10.7 (4.22) 2.4 (0.93) 1967 21.0 (8.27) 1994 12.2 (4.81) 1994 1.0 (0.4) 16.8 (6.6) 1980 Apr. 7.5 (2.94) 0.4 (0.16) 1995 20.9 (8.21) 1961 8.9 (3.52) 1961 0.0 Trace 1996 May 11.2 (4.40) 2.4 (0.95) 1987 23.2 (9.12) 1956 12.8 (5.02) 1999 0.0 Trace 1998 June 13.6 (5.36) 2.3 (0.89) 1984 32.7 (12.87) 1962 19.6 (7.73) 1966 0.0 Trace 1995 July 19.4 (7.62) 4.2 (1.65) 1961 38.4 (15.12) 1966 16.7 (6.58) 1988 0.0 0.0 NAc Aug. 18.6 (7.31) 4.2 (1.66) 1968 47.8 (18.83) 2006 24.3 (9.56) 2006 0.0 0.0 NA Sept. 17.2 (6.79) 1.8 (0.70) 1986 59.5 (23.41) 1999 37.7 (14.84) 1999 0.0 0.0 NA Oct. 8.2 (3.21) 0.4 (0.17) 1953 38.3 (15.07) 2005 20.7 (8.15) 2005 0.0 0.0 NA Nov. 8.3 (3.26) 1.2 (0.49) 1973 20.0 (7.87) 1972 12.2 (4.82) 1969 0.0 Trace 1976 Dec. 9.6 (3.78) 1.2 (0.48) 1955 17.9 (7.06) 1989 9.9 (3.88) 1980 1.5 (0.6) 38.9 (15.3) 1989 Annual 145.0 (57.07) 0.4 (0.16) 

Apr. 

1995 59.5 (23.41)

Sep. 

1999 37.7 (14.84)

Sep. 

1999 5.3 (2.1) 38.9 (15.3)

Dec. 

1989 

a 1971 to 2000 climate normals. b Period of record is 57 years (1952 to 2008). c NA = not applicable. 

Source: NCDC, 2009b.
3-18 

Figure 3-5 Wind Rose (10-meter [33-foot] level) for the Wilmington/New Hanover 

County Airport, 2004 to 2008 (NCDC, 2009c)
3-19 

1 and south-southwest (8.8 percent). Wind speed tends to be relatively higher in spring and lower 

2 in summer and fall (NCDC, 2009b). The reverse is true for calm winds. In general, 

3 southwesterly winds prevail in spring and summer, while northerly winds prevail in fall and 

winter. The southwesterly winds are strongly influenced by general synoptic-scale1 4 wind 

5 patterns of the Bermuda High. In contrast, northerly winds reflect the influences of penetrating 

6 polar air masses and changes in global circulation (Robinson, 2005). 

7 

8 Atmospheric stability affects the extent to which gases or particulates are dispersed. Vertical 

9 motions and pollution dispersion are enhanced in an unstable atmosphere, while suppressed in 

10 a stable atmosphere. Stability is usually classified by Pasquill stability, ranging from Class A 

11 through F (Turner and Schulze, 2007), which depends on solar insolation (the amount of solar 

12 radiation energy received by a given area in a given time), wind speed, and cloud cover. Class 

13 A stability (most unstable) conditions occur in low winds with high incoming levels of solar 

14 radiation typically during the daytime. Class E stability (slightly stable) and Class F stability 

15 (moderately stable) conditions arise on clear nights with little wind. Class D stability (neutral) 

16 conditions occur with higher wind speeds and/or greater cloud cover, irrespective of day or 

17 night. Figure 3-6 presents the frequency distribution of stability classes for a nine-year period 

18 (1984 to 1992) at the Wilmington/New Hanover County Airport (EPA, 2009a). The neutral 

19 (Class D) condition is most prevalent, which accounts for about 43.2 percent of the time. The 

20 unstable conditions (Class A to Class C) occur approximately 20.1 percent of the time, while the 

21 stable conditions (Class E and Class F) occur about 36.7 percent of the time. 

22 

23 Normally, the temperature in the atmosphere decreases with height above the ground. A 

24 temperature inversion occurs when there is an increase in temperature with height above the 

25 ground. An inversion suppresses convection, which can lead to air pollutants being trapped 

26 close to the ground, thereby causing possible adverse health effects. The length of time an 

27 inversion lasts (its persistence) is an important factor for determining its impact on air 

28 dispersion. One type of inversion is “surface inversion,” which is due primarily to a loss of long29 wave radiation near the surface and common over land prior to sunrise and in winter. On the 

basis of Class E and Class F stability,2 30 surface inversion occurs frequently in the Wilmington 

31 area, about 36.7 percent of the time. After sunrise, the temperature surface inversion breaks up 

32 due to the sun’s heating the ground on a time scale of hours. 

33 

34 Another type of inversion is the “subsidence inversion,” which can develop aloft as a result of air 

35 gradually sinking over a wide area and being warmed by adiabatic compression, usually 

36 associated with subtropical high-pressure systems. Subsidence inversions are principal causes 

37 of air stagnation, which is characterized by poor ventilation due to persistent light and calm 

38 winds, and by the presence of inversions. Stagnant air could accumulate air pollutants and 

39 cause poor air quality over a wide area for a prolonged period, resulting in what is called an “air 

 

1

 The synoptic scale is the scale of high- or low-pressure systems in the lower atmosphere as seen on 

weather maps; typically with a horizontal scale on the order of 1000 kilometers (620 miles) or more. 

2

 The Pasquill stability classes presented here are based on solar insolation, wind speed, and cloud 

cover, not temperature gradients at two different heights. Temperature gradients are −0.5 to 

1.5° Celsius (−0.9 to 2.7° Fahrenheit) per 100 meters (328 feet) for Class E and >1.5° Celsius 

(2.7° Fahrenheit) per 100 meters (328 feet) for Class F. Accordingly, the frequency of surface 

inversion presented here, defined as temperature increase with height (i.e., >0° Celsius 

(0° Fahrenheit) per 100 meters [328 feet]), might be overestimated. 
3-20 

1 

2 

3 Figure 3-6 Distribution of Stability Classes for the Wilmington/New Hanover County 

4 Airport, 1984 to 1992 (EPA, 2009a) 

5 

6 pollution episode.” An air pollution episode may adversely affect the health of individuals at 

7 higher risk (e.g., the young, elderly, or those with respiratory or cardiovascular diseases). The 

8 Wilmington area has a mean of 10 to 20 air stagnation days per year and of 2 to 4 air stagnation 

9 episodes per year (Wang and Angell, 1999). On average, stagnation episodes last about five 

10 days. 

11 

12 3.5.2.4 Mixing Heights 

13 

14 The mixing height is defined as the height above the ground surface through which relatively 

15 vigorous vertical mixing occurs, primarily through the action of atmospheric turbulence. All other 

16 parameters being equal, ground-level (at the surface) concentrations of emitted pollutants under 

17 low mixing height will be relatively high because pollutants are prevented from dispersing 

18 upward. Mixing heights commonly go through large diurnal variations because of solar heating 

19 and surface cooling. Mixing heights are generally lowest late at night or early morning and 

20 highest during mid to late afternoon. At the locations near large water bodies (e.g., Wilmington), 

21 diurnal and seasonal mixing heights show little difference, compared with considerable differences 

22 at inland stations because of the moderating effects of the large water bodies. Seasonal 

23 variations of morning mixing heights are generally not large. However, afternoon mixing heights 

24 display a large seasonal variation, and mixing heights in summer are typically higher than those 

25 in winter. 

26 

27 Mixing heights are not measured directly but calculated approximately from routine surface and 

28 upper air observations. Holzworth (1972) developed mean seasonal and annual mixing heights 

29 throughout the contiguous United States by using 1960 to 1964 observation data. No site30 specific mixing height data are available for the Wilmington Site. Thus, mean seasonal and 
3-21 

1 annual data were taken from the isopleths of mixing heights in Holzworth (1972). As shown in 

2 Figure 3-7, the mean annual morning and afternoon mixing heights for the Wilmington Site are 

3 approximately 540 meters (1770 feet) and 1160 meters (3810 feet), respectively. As mentioned 

4 previously, because of the moderating effects of the Atlantic Ocean, seasonal variations in 

5 mixing heights are small, and differences between morning and afternoon mixing heights are 

6 not considerable compared with farther inland stations. 

7 

8 3.5.2.5 Severe Weather Conditions 

9 

10 In common with most Atlantic coastal localities, the area is subject to the effects of coastal 

11 tropical storms and occasional hurricanes causing high winds, above-normal tides, heavy rains, 

12 and even tornadoes (NCDC, 2009b). In addition, thunderstorms in the area are associated with 

13 large-scale synoptic fronts approaching from the north and west. Thunderstorms are the most 

14 active during the summer months, occurring about one out of three days from June through 

15 August. The Wilmington area experiences about four days per year of damaging severe 

16 thunderstorms with straight winds greater than 50 knots (NSSL, 2009). Another hazard of 

17 thunderstorms is lightning, which can strike up to 16 kilometers (10 miles) away from the rain of 

18 a thunderstorm. Some lightning strikes have caused either numerous injuries, including 

19 fatalities, or property damage such as disruption of electric circuits and wildfires. From 1996 

20 through 2005, the Wilmington area experienced about four to eight lightning flashes per square 

21 kilometer per year (NOAA, 2009). 

900

1350 1300

1100 1160

0

500

1000

1500

2000

Winter Spring Summer Fall Annual

Mixing Height (m)

520 560 580

500 540

0

250

500

750

1000

Winter Spring Summer Fall Annual

Mixing Height (m)

Morning

Afternoon

Figure 3-7 Mean Morning and Afternoon Mixing Heights for the 

Wilmington Site, North Carolina (Holzworth, 1972) 
3-22 

1 Tornadoes are rare in the area surrounding the proposed GLE Facility, and are less frequent 

2 and destructive than those in the “tornado alley” of the central United States. For the period 

3 1950 to 2008, 1126 tornadoes were reported in North Carolina, with an average of 

4 19.1 tornadoes per year (NCDC, 2009d). For the same period, a total of 16 tornadoes with an 

5 average of 0.3 tornadoes per year were reported in New Hanover County. Six of the 

6 16 tornadoes that hit New Hanover County occurred during a two-year period (1998 to 1999). 

7 However, most tornadoes occurring in New Hanover County between 1950 and 2008 were 

relatively weak; that is, all F0 or F1, except one F2 on the Fujita tornado scale,1 8 and caused five 

9 injuries and no fatalities in total. 

10 

11 Most hurricanes form over warm ocean waters near the equator and usually travel west and 

12 slightly north while strengthening. Many storms curve to the northeast near the Florida 

13 peninsula. Hurricanes are sustained and strengthened by energy from warm waters (water 

14 temperature higher than 27° Celsius [80° Fahrenheit]). Because of the proximity of New 

15 Hanover County to the Gulf Stream, this area has a high potential for hurricanes advancing from 

16 the tropics to sustain or intensify their strengths. Hurricanes come close enough to affect 

17 North Carolina about twice in an average year (NCDC, 2009a). Most storms that hit most or 

18 part of the State do little damage, but some storms are powerful enough to cause extreme 

19 damage and loss of life. Coastal properties occasionally suffer severe damage from associated 

20 high tides. The area of New Hanover County could expect the following return periods for each 

category of hurricanes passing within 75 nautical miles (139 kilometers [86 miles]): Category 1,2 21 

22 10 years; Category 2, 24 years; Category 3, 43 years; Category 4, 96 years; and Category 5, 

23 250 years (NHC, 2009). Between 1950 and 2007, many tropical storms have passed within 

24 75 nautical miles of the proposed GLE Facility and 15 of them were classified as hurricanes 

25 (CSC, 2009). Ten hurricanes made landfall along the stretch of the coastline within 

26 75 nautical miles (139 kilometers [86 miles]) of the proposed GLE Facility. The strongest of the 

27 10 hurricanes recorded since 1950 were Category 3 storms Hazel (1954) and Fran (1996), 

28 which caused mass destruction along the coast. Category 4 Hurricane Helene (1958) was 

29 within 75 nautical miles (139 kilometers [86 miles]) but did not make landfall and moved 

30 northeastward along the Atlantic Coast. Hurricane Diana (1984) approached offshore of New 

31 Hanover County as a Category 4 hurricane but made landfall as a Category 1 hurricane after 

32 making one full turn offshore; it was then downgraded to a tropical storm while advancing 

33 inland. The southern coastline in North Carolina was affected by more hurricanes than any 

34 other State bordering the Atlantic Ocean and the Gulf of Mexico between 1996 and 1999. 

35 

 

1

 The Fujita tornado scale is classified with the fastest 0.40-km (0.25-mi) wind speeds: 18−32 m/s 

(40−72 mph) for F0 (gale); 33−50 m/s (73−112 mph) for F1 (moderate); 51−70 m/s (113−157 mph) for 

F2 (significant); 71−92 m/s (158−207 mph) for F3 (severe); 93−116 m/s (208−260 mph) for F4 

(devastating); and 117−142 m/s (261−318 mph) for F5 (incredible). The new Enhanced Fujita (EF) 

scale based on 3-second wind gusts was implemented on February 1, 2007. Since that date, all 

tornadoes in the United States have been rated by using EF categories. Similar to the original Fujita 

scale, the ratings are from EF0 to EF5. However, historical tornadoes recorded on or before 

January 31, 2007, are still categorized with the original Fujita scale. 

2

 Maximum sustained surface (10-m [33 ft]-level) wind speeds are 33−42 m/s (74−95 mph) for 

Category 1, 43−49 m/s (96−110 mph) for Category 2, 50−58 m/s (111−130 mph) for Category 3, 

59−69 m/s (131−155 mph) for Category 4, and greater than 69 m/s (155 mph) for Category 5. 
3-23 

1 3.5.3 Air Quality 

2 

3 Regulations governing air pollution sources at the Wilmington Site have been promulgated by 

4 the U.S. Environmental Protection Agency (EPA) per the Federal Clean Air Act (CAA). These 

5 regulations are implemented through several EPA programs. The North Carolina Division of Air 

6 Quality (NCDAQ) under the North Carolina Department of Environment and Natural Resources 

7 (NCDENR) has authority, as delegated by the EPA, to administer these regulatory programs in 

8 the State. The major programs are summarized below. 

9 

10 The EPA has set National Ambient Air Quality Standards (NAAQS) for six criteria pollutants: 

11 sulfur dioxide (SO2), nitrogen dioxide (NO2), carbon monoxide (CO), ozone (O3), particulate 

matter (PM; PM10 and PM2.5),3 12 and lead (Pb), as shown in Table 3-5 (EPA, 2010). Primary 

13 NAAQS specify maximum ambient (outdoor air) concentration levels of the criteria pollutants 

14 with the aim of protecting public health with an adequate margin of safety. Secondary NAAQS 

15 specify maximum concentration levels with the aim of protecting public welfare, including 

16 protection against decreased visibility and damage to animals, crops, vegetation, and buildings. 

17 The NAAQS specify different averaging times as well as maximum concentrations. Some of the 

18 NAAQS for averaging times of 24 hours or less allow the standard values to be exceeded a 

19 limited number of times per year; others specify other procedures for determining compliance. 

20 

21 North Carolina has its own State Ambient Air Quality Standards (SAAQS) (Title 15A, Chapter 2, 

22 Subchapter D of the North Carolina Administrative Code [15A North Carolina (NC) 

23 Administrative Code 02D.0401-410]), which are almost the same as the NAAQS, as shown in 

24 Table 3-5. Currently, the State has the standard for total suspended particulates (TSP), which 

25 used to be one of the criteria pollutants but was replaced by PM10 in 1987. If a State has no 

26 standard corresponding to one of the NAAQS, the NAAQS apply. 

27 

28 An area where air quality is above NAAQS levels is called a nonattainment area. Previously, 

29 nonattainment areas where air quality has improved to meet the NAAQS were redesignated 

30 maintenance areas, subject to an air quality maintenance plan. None of the coastal counties in 

31 North Carolina, including New Hanover County (where the proposed GLE Facility will be 

32 located) and two neighboring counties, are nonattainment or maintenance areas for criteria 

33 pollutants (EPA, 2009b). Several inland counties are nonattainment areas for 8-hour O3 and 

34 PM2.5, and maintenance areas for CO. 

35 

36 In areas with pollutant levels below the NAAQS (i.e., attainment areas), the Federal Prevention 

37 of Significant Deterioration (PSD) program places limits on the total increase in ambient 

38 pollutant levels above established baseline levels for SO2, NO2, and PM10 (40 CFR 51.166.). 

39 This prohibits “polluting up to the limits” specified in the NAAQS for these pollutants. Under 

40 these regulations, the allowable increases are smallest in Class I areas (e.g., national parks and 

41 wilderness areas). The rest of the country is subject to larger Class II increments. Most areas, 

 

3

 Particulate matter (PM) is dust, smoke, and other solid particles and liquid droplets in the air. The size 

of the particulate is important and is measured in micrometers (μm). A micrometer is 1 millionth of a 

meter (0.000039 in.). PM10 is PM with an aerodynamic diameter less than or equal to 10 μm and can 

reach the lower sections of the respiratory system. PM2.5 is PM with an aerodynamic diameter less 

than or equal to 2.5 μm and is small enough to penetrate deep into the lower, most sensitive parts of 

the lung. 
3-24 

Table 3-5 National Ambient Air Quality Standards (NAAQS) and North Carolina 

State Ambient Air Quality Standards (SAAQS) for Criteria Pollutants 

 NAAQSb

Pollutanta Averaging Time Value Typec

North Carolina SAAQS 

SO2 3-hour 0.5 ppm (1,300 μg/m3) S 1300 μg/m3 (0.5 ppm) 

 24-hour 0.14 ppm P 365 μg/m3 (0.14 ppm) 

 Annual 0.03 ppm P 80 μg/m3

 (0.03 ppm) 

NO2 1-hour 0.100 ppmd

 P NSe 

 Annual 0.053 ppm (100 μg/m3) P, S 0.053 ppm (100 μg/m3) 

CO 1-hour 35 ppm (40 mg/m3) P 35 ppm (40 mg/m3) 

 8-hour 9 ppm (10 mg/m3) P 9 ppm (10 mg/m3) 

O3 1-hour 0.12 ppmf

 P, S NS 

 8-hour 0.075 ppm (2008 standard) P, S 0.075 ppm 

 8-hour 0.08 ppm (1997 standard)g

 P, S NS 

TSP 24-hour NS NS 150 μg/m3

 Annual (geometric) NS NS 75 μg/m3

PM10 24-hour 150 μg/m3

 P, S 150 μg/m3

PM2.5 24-hour 35 μg/m3 P, S 35 μg/m3

 Annual 15.0 μg/m3 P, S 15.0 μg/m3

Lead Rolling 3-month 0.15 μg/m3 h P, S 0.15 μg/m3

 Calendar quarter 1.5 μg/m3 P, S NS a

 CO = carbon monoxide, NO2 = nitrogen dioxide, O3 = ozone, PM2.5 = particulate matter ≤ 2.5 μm, 

PM10 = particulate matter ≤ 10 μm, SO2 = sulfur dioxide, and TSP = total suspended particulates. b

 NAAQS, other than those for NO2, O3, PM10, and PM2.5 and those based on annual averages, are not to be 

exceeded more than once per year. The 1-hour NO2 standard is attained when the 3-year average of the 98th 

percentile of the daily maximum 1-hour average at any monitor within an area must not exceed 0.100 ppm The 

1 hour O3 standard is attained when the expected number of days per calendar year with maximum hourly average 

concentrations above the standard is <1. The 8-hour O3 standard is attained when the 3-year average of the 

fourth-highest daily maximum 8-hour average concentrations measured at each monitor within an area over each 

year does not exceed the standard. The 24-hour PM10 standard is not to be exceeded more than once per year on 

average over 3 years. The 24-hour PM2.5 standard is attained when the 3-year average of the 98th percentile of 

24-hour concentrations at each population-oriented monitor within an area does not exceed the standard. The 

annual PM2.5 standard is attained when the 3-year average of the weighted annual mean concentrations from 

single or multiple community-oriented monitors does not exceed the standard. Refer to Title 40, Part 50 of the 

Code of Federal Regulations (40 CFR Part 50) for detailed information on attainment determination and reference 

method for monitoring. 

c

 P = primary standard whose limits were set to protect public health; S = secondary standard whose limits were set 

to protect public welfare. 

d

 Effective January 22, 2010. 

e

 NS = no standard exists. 

f

 As of June 15, 2005, the EPA revoked the 1-hour O3 standard in all areas except 8-hour O3 nonattainment Early 

Action Compact (EAC) areas. 

g

 The 1997 standard – and the implementation rules for that standard – will remain in place for implementation 

purposes as the EPA undertakes rulemaking to address the transition from the 1997 O3 standard to the 2008 O3

standard. 

h

 Final rule signed October 15, 2008. 

Sources: EPA, 2010a; 15A NC Administrative Code 02D.0401-410. 
3-25 

1 including the proposed GLE Facility and its vicinity, are classified as Class II areas. EPA 

2 typically recommends that the permitting authority notify the Federal Land Managers (FLMs) 

3 when a proposed PSD source would locate within 100 kilometers (62 miles) of a Class I area 

4 (EPA, 2010b). If the source’s emissions are considerably large (subjective), EPA recommends 

5 that sources beyond 100 kilometers (62 miles) be brought to the attention of the FLMs. The 

6 FLMs then become responsible for demonstrating that the source’s emissions could have an 

7 adverse effect on air quality-related values (AQRVs), such as scenic, cultural, biological, and 

8 recreational resources (EPA, 2010b). The nearest Class I areas are the Swanquarter 

9 Wilderness Area in North Carolina and Cape Romain Wilderness Area in South Carolina, both 

10 of which are beyond 177 kilometers (110 miles) from the proposed facility (40 CFR 81.422 and 

11 40 CFR 81.426) (FWS, 1998). 

12 

13 Section 112 of the CAA specified a list of hazardous air pollutants (HAPs), also called air toxics. 

14 Unlike criteria air pollutants, no Federal ambient air quality standards have been established for 

15 air toxics. Rather, the EPA has issued National Emission Standards for Hazardous Air 

16 Pollutants (NESHAPs) requiring control of sources of these pollutants. These standards are 

17 based on a technology, rather than a health-based approach, but still require an assessment of 

18 the residual health risk remaining after the controls are in place. 

19 

20 North Carolina has its own “risk-based” regulatory program, independent of the Federal 

21 program, designed to protect the public health by limiting emissions of toxic air pollutants 

22 (TAPs). Many chemicals on the State TAPs list overlap with those on the Federal hazardous air 

23 pollutants (HAPs) list, but the State includes additional substances not on the Federal list. As 

24 part of its program, North Carolina has also developed Acceptable Ambient Levels (AALs) for 

25 97 TAPs, “above which the substance may be considered to have an adverse effect on human 

26 health” (15A NC Administrative Code 02D.1104). In contrast to the NAAQS, which are applied 

27 to outdoor air throughout the country, the AALs are applied on a much smaller scale. North 

28 Carolina’s AALs are used in air permitting to ensure that TAPs from new or modified facilities do 

29 not cause or contribute beyond the premises (adjacent property boundaries) to any significant 

30 concentration levels that may adversely affect human health, on a case-by-case basis. 

31 Generally, monitoring for TAPs is limited to specific areas and specific pollutants. 

32 

33 3.5.3.1 Current Emissions at the Wilmington Site 

34 

35 Air quality permits are legally binding documents that include enforceable conditions with which 

36 the source owner/operator must comply. As discussed in Section 3.5.3, depending on the air 

37 regulatory program, the State has both independent authority and authority delegated from the 

38 EPA to issue these permits. The NCDAQ issues the permits to source owners/operators for the 

39 construction and operation of air emission sources in the State. Construction permits ensure 

40 that proposed projects can meet air pollution standards before construction. Operating permits

41 set emission limits and establish monitoring, record-keeping, and reporting requirements. For 

42 air permitting purposes, a source is classified as one of three categories: “major,” “synthetic 

43 minor,” and “small.” A facility that has the potential to emit 91 metric tons (100 tons) or more per 

44 year for one or more of the criteria pollutants, or 9.1 metric tons (10 tons) or more per year of 

45 any of the listed HAPs, or 23 metric tons (25 tons) or more per year of an aggregate total of 

46 HAPs is defined as a “major” source. Major sources are subject to Title V of the Clean Air Act

47 (42 U.S.C. 7401 et seq.), which standardizes air quality permits and the permitting process 

48 across the United States. A “synthetic minor” (or “conditional major”) source has the potential 
3-26 

1 for exceeding major source emission thresholds but is the one that avoids major source 

2 requirements by accepting permit conditions that limit emissions below major source thresholds. 

3 The “small” (or “minor”) source has no potential for exceeding major source emission 

4 thresholds. 

5 

6 Currently, the Wilmington Site has two active “synthetic minor” operating permits. 

7 Permit 1161R19 was issued to GE to operate air emission sources associated with the AE 

8 operations and one air emission source related to the SCO (NCDAQ, 2004a). The primary 

9 emission is PM10 from metal cleaning systems. Permit 1756R17 was issued to GNF-A to 

10 operate air emission sources associated with the FMO facility and the FCO (NCDAQ, 2004b). 

11 Primary emission sources include a natural gas-fired chambered incinerator for combustible 

12 LLRW, three natural gas or No. 2 fuel oil-fired boilers, and one emergency and two load13 shedding generators burning diesel fuel. 

14 

15 Table 3-6 presents annual point source emissions of criteria pollutants and volatile organic 

16 compounds (VOCs) for New Hanover County, neighboring Brunswick and Pender Counties, and 

17 for the Wilmington Site (NCDAQ, 2009a). Annual point source emissions for New Hanover 

18 County are the highest among the three counties, about 2 to 7 times higher than for Brunswick 

19 County. Pender County, with the lowest population among the three counties and no major 

20 industries, has negligible point source emissions. Point source emissions from current 

21 operations at the Wilmington Site are well below the major source threshold of 91 metric tons 

22 (100 tons) per year for one or more of the criteria pollutants, and are insignificant compared with 

23 the annual total emissions in New Hanover County and the three counties combined. 

24 

Table 3-6 Annual Point Source Emissions of Criteria 

Pollutants and VOCs in New Hanover County, Neighboring 

Brunswick and Pender Counties for 2007, and at the 

Wilmington Site for 2004 

 Annual Emission Rates (tons/yr)a

Pollutant Brunswick 

County 

New Hanover 

County 

Pender 

County 

Wilmington 

Siteb

SO2 7407 26,055 NAc 0.2 

NOx 2612 7170 NA 7 

CO 6299 12,156 NA 3.5 

VOC 1426 2371 NA 0.4 

TSP 292 1790 6.4 0.4 

PM10 201 1328 2.6 0.4 

PM2.5 134 782 NA 0.1 a

 To convert tons to metric tons, multiply by 0.9072. 

b

 Point source emissions reported to and accepted by NCDAQ for compliance 

with current site permits. 

c

 NA = not available. 

Source: NCDAQ, 2009a. 
3-27 

1 Annual emissions in 2007 for large point sources with any one of the criteria pollutants and/or 

2 VOCs of greater than 91 metric tons (100 tons) per year in New Hanover County and 

3 neighboring Brunswick and Pender Counties are presented in Table 3-7. Many large point 

4 source emitters are in operation in Wilmington, New Hanover County, while no large emitters 

5 exist in Pender County. A coal-fired electric plant owned by Carolina Power and Light Company 

6 in Wilmington, New Hanover County, accounts for more than half of the three-county total point 

7 source emissions of SO2, NOx, and all PMs (TSP, PM10, and PM2.5). Invista, S.a.r.l., a 

8 manufacturer of industrial organic chemicals, is a primary contributor to emissions of CO and 

9 VOCs and a secondary contributor to emissions of all PMs. Invista, S.a.r.l. is also a secondary 

10 contributor to SO2, along with a coal-fired cogeneration plant in Southport, Brunswick County, 

11 owned by EPCOR USA. DAK Americas LLC, a manufacturer of organic fibers in Leland, 

12 Brunswick County, is a secondary contributor to NOx, CO, and VOC emissions. 

13 

14 As shown in Table 3-8, nitric acid, at 178 kilograms (393 pounds), was the highest among the 

15 air toxics emitted from the Wilmington Site in 2004, followed by ammonia at 108 kilograms 

16 (237 pounds). The Wilmington Site also emitted about 27 kilograms (60 pounds) of total 

17 fluorides and 15 kilograms (32 pounds) of hydrogen fluoride. Total air toxic emissions from the 

18 Wilmington Site in 2004 were about 546 kilograms (1203 pounds). Accordingly, toxic emissions 

19 from the Wilmington Site are well below the major source thresholds of 9.1 metric tons per year 

20 (10 tons per year) for a single HAP and 23 metric tons (25 tons per year) for any combination of 

21 listed HAPs. 

22 

23 No total greenhouse gas (GHG) emissions data are available at the county level in 

24 North Carolina. Greenhouse gas emissions and sinks in North Carolina are presented in 

25 Section 4.2.18.4. 

26 

27 Facilities in North Carolina are encouraged by the NCDAQ to report their GHG emissions 

28 voluntarily. No facilities in New Hanover County have voluntarily reported their GHG emissions 

29 to date. On October 30, 2009, the EPA promulgated the Mandatory Greenhouse Gases 

30 (GHGs) Reporting Rule (74 FR 56260). This rule mandates the reporting of annual GHG 

31 emissions for over 10,000 facilities that account for 85 percent of the national GHG emissions. 

32 The rule, which became effective on December 29, 2009, focuses on large emitters of GHGs, 

33 including power generation facilities, and other industrial entities. Facilities that emit GHGs from 

34 certain sources – such as the production of cement, aluminum, and lime – are required to 

35 comply with the rule regardless of emission rate. Other GHG sources must be reported only if 

36 the facility's GHG emissions exceed 25,000 metric tons (MT) of carbon dioxide equivalent 

37 (CO2e). Combustion units are included in the sources which must report if aggregate emissions 

38 exceed this level. At this time, no action other than reporting must be taken. 

39 

40 3.5.3.2 Current Air Quality Conditions 

41 

42 Currently, three State monitoring sites as part of the North Carolina Ambient Monitoring 

43 Program are operating in New Hanover County; no monitoring sites are in operation in 

neighboring Brunswick and Pender Counties. Three criteria pollutants (O3, PM10,

4 44 and PM2.5) 

 

4

 The NCDAQ began manual one-in-six-day PM10 monitoring at the Castle Hayne site in February 2008 

to provide the necessary PM10 data for PSD modeling associated with industrial expansion in the 

coastal area, because it shut down the PM10 monitoring site in Jacksonville, Onslow County, on 

December 31, 2007. 
3-28 

Table 3-7 Annual Emissions for Large Point Sources in New Hanover County and Neighboring B

Pender Counties for 2007 (tons)a,b,c

Facility Name County City SO2 NOx CO VOC TSP PM10 PM2.5 Indu

DAK Americas LLC Brunswick Leland 3254 1409 5955 1112 121 76 49.4 2824 – 

noncel

EPCOR USA North Carolina LLC – Southport Plant 

Brunswick Southport 4113 1144 266 15.2 73.5 72.7 50.7 4911 – 

Technical Coating International, Inc. 

Brunswick Leland NRd 0.3 0 170 0 0 0 3089 – 

NECe

Carolina Power and Light Company 

New Hanover Wilmington 20,393 5358 343 40.5 1161 827 445 4911 – 

Corning Incorporated New Hanover Wilmington 0.1 213 3.7 62.8 16.7 9.1 NR 3229 – 

blown g

Elementis Chromium New Hanover Castle Hayne 534 414 14.6 55.1 140 103 75.4 2819 – 

inorgan

Invista, S.a.r.l. New Hanover Wilmington 4107 924 11,701 1151 326 285 196 2869 – 

chemic

MeadWestvaco Packaging Systems, LLC 

New Hanover Wilmington NR 1 0.8 664 0.2 0.2 0.2 2671 – 

laminat

a Presented large point sources with any one of the criteria pollutants and/or VOCs of greater than 100 tons per year. b None of the point sources in Pender County generate emissions of any one of the criteria pollutants and/or VOCs of greater than 100 tons per yc To convert tons to metric tons, multiply by 0.9072. d NR = not reported. e NEC = not elsewhere classified. 

Source: NCDAQ, 2009a. 
3-29 

Table 3-8 Annual Toxic Air Pollutant Emissions 

at the Wilmington Site in 2004 

 Annual Emissions 

Pollutanta CASb Code kg lb 

Acetaldehyde 75-07-0 0.5 1.1 

Acrolein 107-02-8 0.05 0.1 

Ammonia (as NH3) 7664-41-7 108 237 

Benzene 71-43-2 0.7 1.5 

Butadiene, 1,3- 106-99-0 0.05 0.1 

Chromic acid (VI) (component of SolCR6 and 

CRC) 

7738-94-5 0.001 0.002 

Chromium (VI) soluble chromate compounds 

(component of CRC) 

SolCR6 0.001 0.002 

Chromium — all/total (includes chromium (VI) 

categories, metal and others) 

CRC 0 0 

Fluorides (sum of all fluoride compounds as mass 

of F ion) 

16984-48-8 27 60 

Formaldehyde 50-00-0 3.2 7 

Hydrogen chloride (hydrochloric acid) 7647-01-0 2.7 6 

Hydrogen fluoride (hydrofluoric acid as mass of 

HF) (component of 16984488/fluorides) 

7664-39-3 15 32 

MEK (methyl ethyl ketone, 2-butanone) 78-93-3 0.5 1 

Methylene diphenyl diisocyanate (MDI) 

(component of 83329/POMTV) 

101-68-8 0.05 0.1 

Nitric acid 7697-37-2 178 393 

Polycyclic organic matter (includes PAH, dioxins, 

etc., NC & AP 42 historic) 

POM 0.1 0.3 

Polycyclic organic matter (specific compounds 

from OAQPS for Title V) 

83329/POMTV 0.05 0.1 

Sulfuric acid 7664-93-9 1.8 4 

Toluene 108-88-3 1.4 3 

Trichloroethane, 1,1,2- 79-00-5 29 63 

Xylene (mixed isomers) 1330-20-7 0.2 0.4 

Total 546 

(0.60 tons) 

1,203 

a

 SolCR6 = soluble chromium (VI) compounds; CRC = total chromium compounds; POMTV = polycyclic 

organic matter for Title V; PAH = polycyclic aromatic hydrocarbon; AP 42 = EPA emission factor database; 

QAQPS = EPA Office of Air Quality Planning and Standards. 

b

 Chemical Abstract Service. 

Source: NCDAQ, 2009a. 
3-30 

1 are currently measured at Castle Hayne station located about 10 kilometers (6 miles) northeast 

2 of the Wilmington Site, while only SO2 is measured at the New Hanover County monitoring 

3 station located about 10 kilometers (6 miles) south of the Wilmington Site. The Battleship 

4 monitoring station, located about 10 kilometers (6 miles) south of the Wilmington Site, began 

5 collecting HAPs/TAPs in 2004. The Oleander & College monitoring station, located about 

6 13 kilometers (8 miles) south–southeast of the Wilmington Site, was shut down in 2005 because 

7 consistently low CO concentrations (well below the NAAQS) had been collected. Currently, the 

8 NCDAQ is monitoring NO2 at two urban centers in North Carolina (Charlotte and Winston9 Salem), but is not monitoring lead in the statewide compliance monitoring network because of 

10 consistently low readings Statewide. 

11 

12 Table 3-9 gives the highest background concentrations for SO2, CO, O3, PM10, and PM2.5 

13 collected at monitoring stations in New Hanover County, along with ambient air quality 

14 standards (EPA, 2009c). Because New Hanover County is in attainment for criteria pollutants 

15 (see Section 3.5.3), ambient air quality is considered relatively good. Monitoring data for SO2, 

16 CO, and PM10 are well below the applicable standards (less than or equal to 30 percent of the 

standard), while data for 1-hour O3 and PM2.5 17 levels are around 70 percent of their respective 

standards.7 18 However, monitoring data for 8-hour O3, which is of regional concern, has ranged 

19 from 84 to 100 percent of the standard. 

20 

21 3.6 Geology, Minerals, and Soil 

22 

23 This section describes regional and local geology and soils, seismicity, geologic hazards, and 

24 mineral resources. Detailed safety analyses relative to seismicity are not presented here, but 

25 rather, are part of the NRC staff’s Safety Evaluation Report (SER). 

26 

27 3.6.1 Regional Geology, Structure, and Seismicity 

28 

29 The Wilmington Site is located in the Atlantic Coastal Plain physiographic province. Generally, 

30 this low-relief province has a subsurface that is composed of unconsolidated sediments (layers 

31 of sand, silt, marl, and clay) and limestone that rest on a crystalline basement. The sediments 

32 dip and thicken toward the east. 

33 

34 Site stratigraphy comprises Quaternary sediments over Cretaceous sediments over crystalline 

35 basement rock (Table 3-10). Detailed surficial mapping is not available, but examples of the 

36 types of uppermost Quaternary deposits include beach, sand dune, tidal marsh, swamp, and 

37 alluvium. Because of nearshore depositional environments and changing sea level, the 

38 unconsolidated sediments are variable areally and vertically. The Cretaceous formations at the 

39 site are considered to include the Peedee, Black Creek, and Cape Fear formations. The 

40 Peedee is a silty, fine to very fine-grained sand with traces of oyster shells and pyrite 

41 (Lautier, 1998). It overlies the Black Creek formation, which is approximately 300 feet of 

 

7

 The highest 24-hour PM2.5 concentration recorded in 2008 was 41.6 μg/m3, primarily due to a forest 

fire. PM monitors were removed in April 2008 and never started back (NCDAQ, 2009b). Only 

16 measurements were made in 2008, and thus, this value falls in the 98th percentile concentration. 

This reading, considered to be an exceptional event, is not a representative 98th percentile 

concentration for 2008. The second-highest concentration recorded in 2008 was 15.2 μg/m3

, which is 

well below the standard of 35 μg/m3

. 
3-31 

Table 3-9 Highest Background Concentrations at Monitoring Stations 

in New Hanover County, North Carolina, during the Period 2004 to 2008 

Monitored Background Concentrationsa

Pollutant Averaging 

Time 

NAAQS/ 

SAAQS Data Format 2004 2005 2006 2007 2008 

3-hour 0.5 ppm 2nd maximum 0.072 

(14%)b

0.061 

(12%) 

0.065 

(13%) 

0.082 

(16%) 

0.069 

(14%) 

24-hour 0.14 ppm 2nd maximum 0.022 

(16%) 

0.022 

(16%) 

0.030 

(21%) 

0.027 

(19%) 

0.028 

(20%) 

SO2

Annual 0.03 ppm Annual average 0.005 

(17%) 

0.003 

(10%) 

0.005 

(17%) 

0.006 

(20%) 

0.006 

(20%) 

1-hour 35 ppm 2nd maximum 3.3c

(9.4%) 

NAd CO NA NA NA 

8-hour 9 ppm 2nd maximum 2.3c

(26%) 

NA NA NA NA 

1-hour 0.12 ppm 2nd maximum 0.081 

(68%) 

0.088 

(73%) 

0.085 

(71%) 

0.083 

(69%) 

0.082 

(68%) 

O3

8-hour 0.075 ppm 4th highest 

daily maximum 

0.070 

(93%) 

0.075 

(100%) 

0.072 

(96%) 

0.071 

(95%) 

0.063 

(84%) 

PM10 24-hour 150 μg/m3 2nd maximum NA NA NA NA 20e

(13%) 

24-hour 35 μg/m3 98th percentile 22.8 

(65%) 

25.0 

(71%) 

25.8 

(74%) 

25.4 

(73%) 

41.6e,f

(119%) 

PM2.5

Annual 15.0 μg/m3

 Annual average 10.5 

(70%) 

10.3 

(69%) 

9.8 

(65%) 

9.0 

(60%) 

10.4e

(69%) a

 The NCDAQ monitors NO2 at two urban centers (Charlotte and Winston-Salem), for which the highest annual 

average concentration is 0.015 ppm, about 28 percent of the NAAQS of 0.053 ppm. However, the NCDAQ does 

not monitor Pb in the State of North Carolina because statewide attainment with applicable ambient air quality 

standards has been demonstrated. 

b

 Values in parentheses are monitored concentrations as a percentage of NAAQS or SAAQS. 

c

 CO monitoring was discontinued from 2005 due to consistently low CO concentrations. 

d

 NA = no measurement data are available. 

e

 Because of a prolonged fire, the PM monitors were removed in April 2008 and never started back 

(NCDAQ, 2009b). On the basis of monitoring data in Wilmington for the 1998 to 2002 period, the highest 

background 24-hour and annual average concentrations were 45 and 20 μg/m3

, respectively. f

 This concentration is the highest (also falls in the 98th percentile) out of only 16 measurements recorded in 2008. 

This reading, which was primarily caused by a forest fire and considered to be an exceptional event, is not the 

representative 98th percentile in 2008. The second highest in 2008 was 15.2 μg/m3

. 

Source: EPA, 2009c. 
3-32 

1 

2 alternating beds of fine-grained sands and clays with organic matter (Harden et al., 2003). 

3 Clayey sand lenses are present that contain shells, glauconite, and organic material. In the 

4 lower portion of the formation, kaolinitic clay and cross-bedded sand, silty clay, channel sands, 

5 and laminated beds of sand and clay of a nonmarine river-delta environment are present. The 

6 Cape Fear formation comprises about 400 feet of clays interbedded with clayey sand to sandy 

7 clay. These materials were deposited in shallow seas and in deltaic and estuarine settings. 

8 The basement rock elevation is approximately 1050 feet below ground surface (bgs) 

9 (Harden et al., 2003). 

10 

11 3.6.1.1 Regional Earthquakes 

12 

13 Most North Carolina earthquakes have taken place in the western portion of the State. The site 

14 vicinity does not have a significant seismic hazard. Crone and Wheeler (2000) assessed the 

15 Cape Fear Arch, a regional structural feature, approximately located along the Cape Fear River, 

16 and noted the lack of evidence for Quaternary faulting. The peak acceleration at the site is 3 to 

17 4 percent of gravity (Frankel, 2005), which is relatively low. 

18 

19 Because of the geologic and seismic setting of the site and its low relief, natural hazards such 

20 as volcanism, tsunamis, and landslides are not considered to be relevant. 

21 

22 3.6.1.2 Mineral Resources 

23 

24 Regional mineral resources include sand and gravel, clay, limestone, phosphate, and peat. The 

25 U.S. Geological Survey (USGS) notes the location of several active or former sandpits, a clay 

26 pit, and a quarry for crushed stone within 10 miles of the site (USGS, 2005). Fluorine and 

27 titanium operations occur outside of northern New Hanover County. At the site area, mineral 

28 resources have not been extracted, and significant economic value is not likely. 

29 

Table 3-10 Geologic Units at the North–Central Sector of the Wilmington Site 

Formation Geologic 

Age Description 

Approx. 

Thickness 

(ft)a

Approx. 

Depth 

to Top 

(ft) 

Surficial sediments Quaternary Beach, sand dune, tidal marsh, 

swamp, and alluvial deposits 

10–30 0 

Peedee Cretaceous Mainly silty fine-grained sand 330 10–30 

Black Creek Cretaceous Mainly alternating fine-grained 

sand and clay, clay lenses, 

variable sands 

300 350 

Cape Fear Cretaceous Clay interbedded with clayey 

sand and sandy clay 

400 650 

Crystalline basement Pre-Mesozoic Igneous and metamorphic rocks Large 1050 

a

 To convert feet to meters, multiply by 0.305. 

Sources: Lautier, 1998; Harden et al., 2003.
3-33 

1 3.6.2 Site Geology 

2 

3 Across the Wilmington Site, Quaternary sediments blanket the surface. These deposits vary in 

4 texture and include silty fine sands, silty fine clayey sands, fine sandy silts, and fine sandy clays. 

5 The Peedee clay is present in the eastern portion of the proposed GLE site, while the underlying 

6 Peedee sands are present across the Wilmington Site. A total of ten soil borings were drilled in 

7 1980 and 2007 at or near the North–Central Site Sector to provide preliminary geotechnical 

8 information for a proposed landfill and for foundation design, respectively (GLE, 2008). The 

9 depths of the borings were roughly 35 to 60 feet. These drilling data indicate that the Peedee 

10 Clay has been eroded (GLE, 2008). Here, the Peedee Formation’s sandy material is found at a 

11 depth of roughly 10 to 30 ft. Farther to the west, at the Northwest Site Sector, a drilling program 

12 showed that no clay is present to a depth of at least 60 feet (RTI, 1997). 

13 

14 Carbonate bedrock is present elsewhere in New Hanover County and in adjoining Pender and 

15 Brunswick Counties (NCGS, 2007). In a karst terrain, dissolution of carbonate bedrock such as 

16 limestone leads to sinkholes and ground collapse. The site, however, is not underlain by the 

17 limestone formations that are susceptible to karst (NCGS, 2007; Lautier, 1998; GLE, 2008). 

18 

19 3.6.3 Site Soils 

20 

21 Soils in the region have developed on the recent Quaternary sediments. The North-Central Site 

22 Sector, as well as most of the Wilmington Site, has soils of the Meggett-Johnston-Dorovan 

23 association. Typical characteristics are very poorly drained, very little slope, high flooding 

24 frequency due to poor drainage, and moderate permeability (GLE, 2008). Most of the North25 Central Site Sector is mapped as the Murville fine sand and the Leon sand soil types. The 

26 Murville is formed in sandy marine and fluvial sediments on broad interstream uplands or in 

27 interstream areas. Slopes are less than two percent, drainage is very poor, and permeability is 

28 high in the surface layer and moderately high in the subsoils. The seasonal high water table is 

29 at or near the surface. The soil is strongly to extremely acidic. The Leon sand is found in 

30 various settings, including uplands and stream terraces. It is deep, with high permeability at the 

31 surface, moderate to moderately high permeability in the subsoil, and very high permeability at 

32 depth. The seasonal high water table is at or near the surface. 

33 

34 Differential settlement of foundations occurs in clayey soils with particular properties. The 

35 potential for differential settlement at the proposed construction site is not a concern because of 

36 the sandy soils. 

37 

38 Section 3.7.4.3 provides information on historical releases to site groundwater at various 

39 facilities at the Wilmington Site. These have included historical VOCs, calcium fluoride, 

40 uranium, nitrate, and metals. Remediation has been conducted or is being conducted in 

41 response to these contaminants. Residual contaminants are presumably present in the 

42 unsaturated or saturated site soils. 

43 

44 3.7 Water Resources 

45 

46 This section discusses both surface water and groundwater, including descriptions of the 

47 resources, their use, and natural and anthropogenic quality issues. 

48 
3-34 

1 3.7.1 Surface Water Features and Quality 

2 

3 The Wilmington Site is in the Northeast Cape Fear River subbasin of the Cape Fear River basin. 

4 The Northeast Cape Fear River is the nearest named surface water body to the Wilmington 

5 Site. It forms the southwestern border of the Wilmington property, where it is 600 to 1300 feet 

6 wide. The river is tidally influenced (Weaver and Pope, 2001). Flow measurements of the river 

7 in the immediate vicinity of the Wilmington Site are unavailable. The nearest flow monitoring 

8 stations for the Northeast Cape Fear River are upstream from the Wilmington Site. At Burgaw 

9 (approximately 18 miles north of the site), limited data provide an average flow of 620 cubic feet 

10 per second in 2005 (USGS, 2010a). Farther upstream at Chinquapin (approximately 34 miles 

11 north of the site), data from 1941 to 2009 indicate an annual average flow of 712 cubic feet per 

12 second (USGS, 2010b). The 2005 average, for comparison with the Burgaw data, was 

13 423 cubic feet per second. The Northeast Cape Fear River basin comprises more than 

14 1740 square miles, while the overall Cape Fear River basin covers 9090 square miles and is the 

15 largest watershed in North Carolina (Weaver and Pope, 2001). There are no dams (other than 

16 the site dam on the effluent channel), reservoirs, or surface water intakes within the Northeast 

17 Cape Fear watershed. 

18 

19 Surface water is used in the region for various purposes; the predominant use is 

20 nonconsumptive cooling water for thermoelectric power generation. In New Hanover, Pender, 

21 and Brunswick Counties, there are no public supply intakes; however, the Wilmington area is 

22 served by an intake on the Cape Fear River in Bladen County. In New Hanover, Pender, and 

23 Brunswick Counties, the dominant surface water uses are irrigation and industry (USGS, 2009). 

24 Groundwater is the water source for domestic, municipal, and industrial users. 

25 

26 The site is drained by several small streams and an effluent channel (Figure 3-8). The effluent 

27 channel begins in the Eastern Site Sector and flows to the site dam west and then connects to 

28 an unnamed perennial tributary to the Northeast Cape Fear River. Another tributary to the 

29 same river drains portions of the western and northwestern site sectors. Two unnamed streams 

30 flow north from the property to Prince George Creek, a tributary to the Northeast Cape Fear 

31 River. One of these originates in the Eastern Site Sector and receives site stormwater; the 

32 other has headwaters just north of the Northwestern Site Sector. 

33 

34 The effluent channel receives treated process wastewater effluent subject to NPDES water 

35 quality standards. It also receives stormwater runoff from the developed Eastern Site Sector. 

36 

37 Other onsite natural surface water bodies include three ephemeral woodland ponds. Created 

38 features include two active final process lagoons, their associated aeration basin, four inactive 

39 wastewater treatment facility lagoons, one firewater pond, and two stormwater wet detention 

40 basins. 

41 

42 The process lagoons and aeration basin are for the treatment of process wastewater from the 

43 FMO facility. Adjustment of wastewater pH causes precipitation of chemicals and the resulting 

44 floc is disposed of as low-level waste. The lagoons are periodically dredged and inspected. 

45 The water discharged from the lagoons is cooled to ambient air temperature prior to discharge 

46 to Outfall 001 (Figure 3-20). 

47 
3-35 

1 

2 Figure 3-8 Surface Water Features at the Wilmington Site (Modified from GLE, 2008) 

3 

4 Dredging of stormwater ponds and the effluent channel are not covered under the Clean Water 

5 Act (CWA) because they are created features for industrial purposes. Large trees along the 

6 banks of the effluent channel suggest that dredging is not frequent and has not taken place for 

7 many years. 

8 

9 The wastewater lagoons are being decommissioned because wastewater is being reused at the 

10 facility, as described later in this section. 

11 

12 The State classifies surface waters and wetlands to specify the required types of protection 

13 (15A NC Administrative Code 2B.0101). The Northeast Cape Fear River near the Wilmington 

14 Site is State-designated as Class C swamp water. A Class C designation means that the water 

15 is protected for secondary recreation (boating, but not swimming), fishing, and wildlife. The 

16 supplemental classification “swamp water” describes water of low velocity, low pH, and low 

17 dissolved oxygen. The tributaries draining the site are also considered Class C swamp water. 

18 The lower portions of these tributaries, as well as the Northeast Cape Fear River near the site, 

19 are tidally influenced and therefore contain some saltwater. The balance of fresh and saltwater 

20 is dynamic and dependent on the tide and the flow of freshwater from upstream. 

21 

22 The North Carolina Division of Water Quality (NCDWQ) maintains two monitoring stations along 

23 the Northeast Cape Fear River. One station is about 17 miles upstream of the Wilmington Site; 

24 another is 6 miles downstream. The GLE Environmental Report (GLE, 2008; Table 3.4-6) 

25 contains tabulated summaries of water quality monitoring results from these stations. Results 
3-36 

1 include the chloride mean and maximum values exceeding the evaluation limit at the 

2 downstream location, the copper and zinc maximum values exceeding the evaluation limit at 

3 both the upstream and downstream locations, the iron maximum value exceeding the evaluation 

4 limit at the upstream location, the minimum pH below the evaluation limit at the downstream 

5 location, and the minimum dissolved oxygen below the evaluation limit at both the upstream and 

6 downstream locations. A third station is located at the GE dock near the Wilmington Site’s 

7 south border, less than 2500 feet downstream of the tributary fed by the effluent channel. This 

8 station is monitored by the Lower Cape Fear River Program, a collaborative effort among 

9 academia, government, industry, and the public. The GLE Environmental Report (GLE, 2008; 

10 Table 3.4-7) contains a tabulated summary of water quality monitoring results from this station. 

11 Of the water quality parameters listed, the minimum dissolved oxygen is the only one outside 

12 the evaluation limit. 

13 

14 GE-Hitachi Nuclear Energy (GEH) monitors water quality, gross alpha, gross beta, and uranium 

15 concentrations in the effluent channel at the site dam, the Northeast Cape Fear River 

16 significantly upstream of the Wilmington Site (at a location consistent with the upstream 

17 NCDWQ station), and the Northeast Cape Fear River at the GE dock. These three surface 

18 water stations are also monitored by the North Carolina Radiation Protection Section (NCRPS) 

19 through monthly sampling. Summary data from 1997 to 2006 are presented for water quality 

20 parameters, total uranium, gross alpha, and gross beta (GLE, 2008; Tables 3.4-8 and 3.4-9). 

21 

22 Non-radiological results include the copper mean and maximum values exceeding the 

23 evaluation limit at both the upstream location and the GE dock, the fecal coliform maximum 

24 exceeding the evaluation limit at the upstream location, and the dissolved oxygen minimum 

25 value below the evaluation limit at both the upstream location and the GE dock. Evaluation 

26 limits are not applied to the site dam data because it is an industrial waterway not subject to 

27 15A NC Administrative Code 02B.0211. Although a segment of the Northeast Cape Fear River 

28 (ending approximately 8.5 miles upstream of the Wilmington Site) is listed by the State as 

29 mercury-impaired, the segment of the river contiguous to and immediately downstream of the 

30 Site is not listed as mercury-impaired. GEH does not monitor the effluent channel or the 

31 Northeast Cape Fear River for mercury. 

32 

33 Radiological results at the site dam include mean total uranium concentration of 

34 0.024 milligrams per liter, maximum total uranium concentration of 0.13 milligrams per liter, 

35 mean gross alpha of 49.9 picocuries per liter, maximum gross alpha of 329 picocuries per liter, 

36 mean gross beta of 58.7 picocuries per liter, and maximum gross beta of 330 picocuries per 

37 liter. State standards are annual averages of 15 picocuries per liter for gross alpha and 50 

38 picocuries per liter for gross beta (15A NC Administrative Code 02B.0211); however, these 

39 standards do not apply to an industrial waterway such as the effluent channel. Results on the 

40 upstream and downstream river stations are significantly lower and often below detection limits, 

41 and the annual averages are below the standards for gross alpha and gross beta. NCRPS data 

42 with detailed monthly summary tables for 2000, 2002, and 2006 were obtained for comparison 

43 with GE and NCRPS results for gross alpha and gross beta (NCDENR, 2009b). These 

44 comparisons showed NCRPS results to be generally higher than the GE results, and the 

45 difference in many cases was significant. No NCRPS data were available for total uranium. 

46 North Carolina does not have a water quality standard for uranium in 15A NC Administrative 

47 Code 02B.0211. 

48 
3-37 

1 The Wilmington Site has two National Pollutant Discharge Elimination System (NPDES) 

2 permits: one for wastewaters (process and sanitary) and another for stormwater. 

3 

4 The process and sanitary wastewater permit (Klimek, 2004) expired February 28, 2009. The 

5 Wilmington Site operates under a renewal draft permit (NCDENR, 2009d), which allows the Site 

6 to continue operating under the conditions of the previous permit. A renewal draft permit is an 

7 interim permit issued by the State that allows a permittee to operate under the previous permit 

8 (the terms of which may be modified by the State) until the final draft permit is issued. The 

9 permit addresses two outfalls. Outfall 001 (Figure 3-20) is for process wastewater. It is 

10 monitored prior to discharge to the effluent channel for various parameters and has limitations 

11 on total suspended solids (TSS), total nitrogen, fluoride, cyanide, pH, metals (total cadmium, 

12 lead, chromium, copper, nickel, silver, zinc), oil and grease, and total toxic organics. The permit 

13 lists a number of equipment systems that contribute flow to the outfall, including treatment 

14 tanks, lime slurry system, hydrofluoric acid equipment, etc. The permitted maximum flow at the 

15 outfall is 1.8 million gallons per day. Outfall 002 (Figure 3-20) was used for treated domestic 

16 (sanitary) wastewater until April 2008. Permit limitations included biochemical oxygen demand 

17 (BOD), TSS, and fecal coliform, and a maximum allowed flow of 75,000 gallons per day 

18 (Klimek, 2004). 

19 

20 The current sanitary wastewater treatment facility is a new system that does not release 

21 effluent. The Wilmington Site obtained a permit for the construction and operation of a 

22 75,000-gallons-per-day reverse osmosis water treatment facility to treat the wastewater prior to 

23 reuse (Klimek, 2007a). This system’s treated sanitary effluent is routed to the FMO facility for 

24 industrial process use and to Wilmington Site cooling towers (for the SCO heating, ventilation 

25 and air-conditioning, the FCO facility, and the FMO facility). Effluent limits for both monthly 

26 average and daily maximum values include turbidity, nitrogen, BOD, TSS, and fecal coliform. 

27 

28 The NCDWQ web site does not list NPDES-related Notices of Violation (NOVs) at facilities. At 

29 the site audit, representatives described the history of NOVs for discharges. From 

30 approximately 1995 to 1997, the site received several NOVs for BOD. GLE had two reporting 

31 violations (one for weekly ammonia, one for weekly coliform) but could not provide written 

32 documentation from the State regarding these occurrences (GLE, 2009a). None of the NOVs 

33 have recurred. 

34 

35 The effluent channel receives effluent from the final process lagoons, which receive alkaline 

36 water from the alkaline cleaners used in processing at the FCO facility (GLE, 2009a). The 

37 optimum pH of the lagoons is 8 to 10 to facilitate the settling of solids. The permit for the 

38 process wastewater limits pH to a minimum of 6.0 and a maximum of 9.0 at Outfall 001 

39 upstream of the site dam (Klimek, 2004). The adjustment is made using sulfuric acid prior to 

40 release at the outfall (GLE, 2009a). The site dam has a monitoring station for pH. A gate can 

41 be closed to stop flow through the dam if there is an alarm caused by pH outside the range of 

42 6 to 9. GE data for 1997 to 2006 include statistics for 874 pH samples: a minimum pH of 6.10, a 

43 maximum pH of 12.50, and an average pH of 7.31 determined by using the hydrogen ion 

44 concentrations (GLE, 2008). In the last 10 years, the dam has had no reportable pH excursions 

45 (GLE, 2009a). The pH may exceed the range of 6 to 9 for 60 minutes in one event or 7.2 hours 

46 in a month (Klimak, 2004). If the pH alarm at the dam sounds, GLE implements a procedure to 

47 investigate (GLE, 2009a). An operator closes the dam within five minutes and manually checks 

48 the pH at the outfall with pH paper and a handheld pH meter. If the pH is not within the 
3-38 

1 allowable range, the operator closes the final process lagoons and the pH is retested within 

2 60 minutes. If the pH were still not within the allowable range, the cause would be investigated 

3 and a remediation plan would be developed to adjust the pH. The pH alarms have been 

4 attributed to an error with the probe at the dam or the system has recovered within 60 minutes. 

5 

6 Overflow at a closed dam could occur if the effluent channel receives more than 8.6 million 

7 gallons of water, which would be expected with a 25-year storm event (GLE, 2009b). During dry 

8 conditions, the retention capacity at the dam would allow time for pH adjustments. Dilution of 

9 out-of-specification pH would occur during large rainfall events. 

10 

11 The NPDES stormwater permit (Klimek, 2007b) requires a stormwater pollution prevention plan, 

12 with components that include a description of site operations such as storage and waste 

13 disposal, a list of spills or leaks in the prior three years, secondary containment information, a 

14 description of best management practices with regard to controlling pollutants in stormwater 

15 discharge, and a spill prevention and response plan. The Wilmington Site has three stormwater 

16 outfalls: two discharge to the Northeast Cape Fear River (Figure 3-20), and one discharges to 

17 the Prince George Creek. Semiannual sampling is required during a storm event, with analysis 

18 for lead, oil and grease, pH, and TSS. The 2007 results were within the allowable ranges, with 

19 the exception of a TSS value that was driven high because of construction activities. Quarterly 

20 stormwater sampling took place during 2003 and included analyses for ammonia, combined 

21 nitrite and nitrate, fluoride, uranium (up to 9.9 picocuries per liter), dichloroethylene (DCE), 

22 trichloroethylene (TCE), and vinyl chloride (VC) (GLE, 2008). The VOCs were at very low or 

23 nondetectable levels. In the current stormwater permit (Klimek, 2007b), uranium has been 

24 dropped as a monitoring requirement. 

25 

26 3.7.2 Floodplains 

27 

28 The North-Central Site Sector, the location of the proposed GLE Facility, is above the 100-year 

29 and 500-year floodplains of the Northeast Cape Fear River. Employees at the Wilmington Site 

30 did not observe flooding in 1999 during Hurricane Floyd (GLE, 2008). 

31 

32 3.7.3 Wetlands 

33 

34 Several small wetlands have been identified (GLE, 2008) and were visited during the site audit. 

35 Section 3.8.2 describes these features in detail. 

36 

37 3.7.4 Groundwater 

38 

39 3.7.4.1 Site and Regional Hydrogeology 

40 

41 The geologic units discussed in Section 3.6 comprise the aquifers and aquitards of the site 

42 vicinity. Table 3-10 gives the thicknesses and approximate contact elevations. The discussion 

43 below focuses on the Quaternary sediments and the Peedee and Black Creek aquifers because 

44 they represent the near-surface flow system and because fresh water is present in the 

45 Quaternary and portions of the Peedee. 

46 

47 The unconfined surficial aquifer consists of the Quaternary sediments, which vary greatly in 

48 texture and permeability over short lateral or vertical distances. Well yields are limited and 
3-39 

1 usually are sufficient only for domestic wells. The aquifer’s groundwater is generally fresh, 

2 away from coastal barrier islands (Lautier, 1998). Regional hydraulic conductivity 

3 measurements range between 18.2 and 607 feet per day, with an average of 130 feet per day 

4 (Lautier, 1998). 

5 

6 The Peedee aquifer is an important regional water source and is the water source for the 

7 Wilmington Site (see Section 3.7.4.2). Its hydraulic conductivity varies spatially but is generally 

8 high. Regional hydraulic conductivity measurements range between 1.02 and 243 feet per day 

9 with an average of 38.26 feet per day (Lautier, 1998). Its groundwater is generally transitional 

10 between freshwater and saltwater, though at the Wilmington Site, the shallow Peedee 

11 groundwater is fresh. Recharge may occur from the surficial aquifer and as upward leakage 

12 from the Black Creek aquifer (Harden et al., 2003). In the eastern GLE property, the overlying 

13 Peedee clay is of variable thickness and functions as a semiconfining unit, but it thins to the 

14 west. Site drilling logs (GLE, 2008) indicate that the Peedee clay is not present at the proposed 

15 GLE site. 

16 

17 The underlying Black Creek aquifer at the site is nonpotable because of saltwater content, and 

18 is therefore not relied on as a water resource in the Wilmington Site vicinity. A confining unit of 

19 clay, silt, and thin sand beds separates the Black Creek aquifer from the overlying Peedee 

20 aquifer. Below the Black Creek formation is the Cape Fear formation, which contains upper and 

21 lower aquifers. Both are nonpotable due to salt content. 

22 

23 At the proposed GLE Facility site, the surficial aquifer discharges to surface water bodies, 

24 including streams, drainage canals, and swamps. It also leaks groundwater into the underlying 

25 upper Peedee aquifer. Potentiometric mapping of the surficial aquifer (GLE, 2008) indicates a 

26 water table mound centered on the north-central site sector, with shallow groundwater 

27 discharging directly toward the surrounding low areas in all directions. Flow to the east 

28 eventually diverts to the north or south. Water levels generally fluctuate over a range of several 

29 feet in response to seasonal changes or precipitation events. 

30 

31 Water level data from the upper portion of the Peedee sand at the proposed GLE site support 

32 flow patterns similar to those of the surficial aquifer. A mound is present at the north-central site 

33 sector, with flow toward the surface water bodies on the north, west, and south. To the east, 

34 however, flow is captured by remediation/containment wells and process water wells in the 

35 central GLE property (GLE, 2008). 

36 

37 3.7.4.2 Groundwater Use 

38 

39 Much of the regional groundwater withdrawal for public systems and private users is from the 

40 Peedee aquifer. 

41 

42 For potable water supply, the Wilmington Site has three production wells completed in the 

43 Peedee aquifer. They are located east of the site and NC 133 (Castle Hayne Road) on a 

44 separate GE property. The average pumping rate from this system is approximately 

45 47,000 gallons per day (GLE, 2008). In comparison, the rate of groundwater usage for public 

46 supply in New Hanover County in 2000 was nearly 8 million gallons per day, while the overall 

47 groundwater withdrawal was about 17 million gallons per day, with the main categories of public 
3-40 

1 supply, domestic wells, industrial wells, and irrigation (USGS, 2009). Much of the regional 

2 groundwater withdrawal is from the Peedee aquifer. 

3 

4 Approximately 15 extraction wells and two sumps are at the site. They are located within the 

5 eastern site sector and are used for remediation, specifically hydraulic containment. Extracted 

6 groundwater is treated and used as the process water at Wilmington facilities, with an average 

7 pumping rate of approximately 565,000 gallons per day (GLE, 2008). 

8 Together, the potable and remedial/process pumping systems withdraw a combined 

9 612,000 gallons per day of groundwater. Nonagricultural users of more than 100,000 gallons 

10 per day of groundwater are required to register with the North Carolina Environmental 

11 Management Commission, and to update their registrations every five years thereafter, under 

12 North Carolina General Statutes 143-215.22H. GE operations have been registered under this 

13 program (GLE, 2008). 

14 

15 3.7.4.3 Groundwater Quality 

16 

17 Natural groundwater quality varies with location and depth. While the surficial and Peedee 

18 aquifers are generally of good quality in the Wilmington region, the lower portion of the Peedee 

19 in eastern areas has a high chloride concentration because of saltwater intrusion and is 

20 consequently nonpotable (Lautier, 1998). The deeper Black Creek aquifer and underlying units 

21 are generally nonpotable due to saltwater intrusion. 

22 

23 Groundwater monitoring takes place at the Wilmington Site to assess groundwater 

24 contamination, which may be any combination of organic, inorganic, radiological, or water 

25 quality parameters. Figure 3-9 shows the locations of monitoring areas and wells. The GLE 

26 Environmental Report gives a tabular summary of monitoring results based on historical site 

27 databases and identifies exceedances, which have included chromium, fluoride, nitrate, nitrite, 

28 various organic compounds, gross alpha, and high pH (GLE, 2008; Tables 3.4-3, 3.4-4, and 

29 3.4-5). The impacted groundwater does not flow offsite, given proper functioning of the 

30 groundwater extraction systems that provide hydraulic containment and route the extracted 

31 water to site industrial uses. 

32 

33 Groundwater impacts are present at several distinct areas of the Wilmington Site, as described 

34 below. These areas are shown in Figure 3-9. The Northwest Site Area is located in the 

35 Northwest Site Sector, adjacent to the northwestern edge of the current proposed GLE site. It 

36 was a lubricant disposal area, and its groundwater contains TCE and its breakdown products, 

37 cis-1,2 dichloroethylene (cDCE), and VC. Calcium fluoride, which typically contains traces of 

38 uranium, was stored here. Excavation of contaminated soil took place in 1996 (RTI, 2006). A 

39 corrective action plan for the groundwater proposed monitored natural attenuation (MNA) on the 

40 basis of a lack of downgradient receptors, sampling results, and model calculations 

41 (RTI, 1999a). Fluoride and uranium are included in the MNA assessment. Concentrations were 

42 stable or decreasing for TCE, cDCE, VC, uranium, and fluoride as of 2005 (RTI, 2006). 

43 

44 The other monitored locations are in the Eastern Site Sector (Figure 2-1). The Waste 

45 Treatment Area has nitrate impacts in the surficial and Peedee aquifers (RTI, 1999b). The 

46 facility is no longer used for storing nitrate-containing liquids. Monitoring has not indicated 

47 impact from fluoride or uranium. MNA is taking place, and the nitrate plume is stable in extent. 

48 
3-41 

1 

2 Figure 3-9 Groundwater Monitoring at the Wilmington Site (Modified from GLE, 2008) 

3 

4 The FCO Cleanroom Area is monitored to address a release of acid process solutions. A 

5 breach in an acid tank containment was identified and repaired in September 1996 

6 (RTI, 1998b). Shallow wells were installed and monitored from January to May 1997, and, 

7 following a dry period, monitoring continued in January 1998. Excavation and offsite disposal of 

8 72 cubic feet of soil took place in 1999 (GLE, 2009b). The affected area is beneath the active 

9 FCO building, and monitoring is focused on pH, fluoride, nitrate, and five indicator metals 

10 (chromium, zirconium, tin, nickel, and copper). 

11 

12 The Aeration Basin/Process Lagoon Area is an active treatment facility for process wastewater. 

13 Shallow groundwater in this area has occasionally shown shallow inorganic and radiological 

14 impacts. GNF-A performs groundwater monitoring in this area as a condition of NRC Materials 

15 License SNM-1097 (GLE, 2008). 

16 

17 The FMO/FMOX Facility Area has been affected by a 1991 release of process liquid. Well 

18 installation and groundwater sampling took place immediately, and the fluoride and nitrate 

19 values were above the standard in all wells (NCDEHNR, 1991b). Uranium was also detected, 

20 with a maximum of 387 parts per million. Soil excavation took place, and a sump system (the 

21 Horizontal Collection System) was installed to remove groundwater from the shallow surficial 

22 aquifer. Another sump (SD-1SW) was installed in a former storm drain to collect shallow 

23 groundwater. Groundwater monitoring has taken place since 1992 in the shallow surficial 

24 aquifer, deep surficial aquifer, and Peedee sand aquifer. Exceedances have included fluoride, 
3-42 

1 nitrate, and uranium in the upper surficial aquifer beyond the perimeter of the FMOX building 

2 (RTI, 1998a). 

3 

4 In 1991, the State issued an NOV regarding TCE and other organic compounds present in site 

5 water wells at levels above the standard (NCDEHNR, 1991a). The wells included five process6 water extraction wells and nine monitoring wells. In the NOV, the North Carolina Department of 

7 Environment, Health, and Natural Resources (NCDEHNR) required determination and 

8 elimination of the source of contamination, assessment of the extent of contamination, and 

9 submission of a remedial action plan. In 2009, the State transferred the GE site to its Inactive 

10 Hazardous Waste Sites Priority List, a list of sites where uncontrolled disposal, spills, or 

11 releases of hazardous substances have been identified. Listed sites are required to take action 

12 to control the contaminated discharge and mitigate hazards. Many other monitoring wells are 

13 located in or near the eastern site sector and are used to monitor VOC concentrations from 

14 various historic releases of solvents (RTI, 1992; RTI, 1994; RTI, 1996). VOCs across the entire 

15 Wilmington Site are addressed in comprehensive annual reports updating the ongoing site 

16 investigation (e.g., RTI, 2008). In general, the concentrations of VOCs have been stable or 

17 decreasing; this is attributed to natural attenuation (RTI, 2008). 

18 

19 3.8 Ecological Resources 

20 

21 This section describes the terrestrial, wetland, and aquatic ecological resources in the area of 

22 the proposed GLE Facility, with emphasis on the components that could be affected by the 

23 construction and operation of the facility, ancillary facilities, and the onsite access road to the 

24 facility. Particular attention is given to species protected by the Federal government under the 

25 Endangered Species Act (ESA), as well as species and habitats of special concern listed by the 

26 State of North Carolina. Unless otherwise cited, the information presented in this section has 

27 been adapted from the GLE Environmental Report (GLE, 2008), with additional information 

28 supplied by GLE (GLE, 2009b; GLE, 2009c). To the extent practicable, the information was 

29 verified independently by the NRC staff through a review of references provided by GLE; a site 

30 visit to observe habitats at the Wilmington Site; discussions with GLE and their consultants; and 

31 use of geographic information tools. Ecological field surveys were conducted during six days in 

32 July 2007, four days in September 2007, and from September 1 through September 30, 2009, 

33 to identify biotic communities and characterize the natural and anthropogenic communities on 

34 the Wilmington Site. The emphasis of the field surveys was on the area that encompasses the 

35 proposed GLE Facility and the area for the revised entrance and roadway (GLE, 2008, 2009c). 

36 

37 3.8.1 Vegetation 

38 

39 Ecoregions are designed to provide a spatial framework for the research, assessment, 

40 management, and monitoring of ecosystems and ecosystem components (EPA, 2007a). An 

41 ecoregion is an area having a general similarity in ecosystems and is characterized by the 

42 spatial patterning and composition of biotic and abiotic features, including vegetation, wildlife, 

43 geology, physiography (patterns of terrain or land forms), climate, soils, land use, and 

44 hydrology, such that within an ecoregion, there is a similarity in the type, quality, and quantity of 

45 environmental resources present (EPA, 2007b). The Wilmington Site is located within the 

46 Middle Atlantic Coastal Plain Level III Ecoregion. This ecoregion is characterized by low-level 

47 flat plains with many swamps, marshes, and estuaries. The ecoregion’s forest cover was once 

48 dominated by longleaf pine (Pinus palustris), but is now dominated by loblolly pine (P. taeda) 
3-43 

1 and some shortleaf pine (P. echinata), with patches of oaks (Quercus spp.), sweetgum 

2 (Liquidamber styraciflora), and cypress (Taxodium spp.) near major streams. Pine plantations 

3 are common, and there are some areas of cropland. 

4 

The Wilmington Site is located within the border of two Level IV ecoregions.8 5 The eastern 

6 portion of the Wilmington Site, including most of the existing facilities, is located within the 

7 Carolina Flatwoods Level IV Ecoregion; while the western portion of the site, including the 

8 proposed GLE Facility, is located within the Mid-Atlantic Floodplains and Low Terraces Level IV 

9 Ecoregion (Figure 3-10). Table 3-11 summarizes the vegetation and the land use and land 

10 cover within these Level IV ecoregions. 

11 

12 Three general vegetation cover types dominate the Wilmington Site: (1) upland forested 

13 vegetation (mostly in sandy, well-drained to excessively well-drained soils that are never or 

14 rarely flooded for any significant period of time); (2) wetland vegetation (mostly in soils saturated 

15 at all times or for a significantly long period of time throughout the year); and (3) anthropogenic 

16 vegetation (occurring under various hydrologic regimes and soils with the type of vegetation 

17 cover primarily resulting from human occupation or intervention) (DuMond, 1984). The 

18 anthropogenic vegetation cover type occurs within the operations area, utility corridors, along 

19 roadsides, and also includes pine plantations. 

20 

21 Plant community mapping of the Wilmington Site was conducted on the basis of true-color 

22 orthophotography and field surveys conducted in July and September 2007 (GLE, 2008). 

23 Thirteen plant communities, including eight natural and five anthropogenically influenced 

24 communities, were identified on the Wilmington Site (Figure 3-11). Table 3-12 summarizes 

25 information on these communities. The proposed GLE Facility would be located within areas 

26 now occupied by pine forest, pine-hardwood forest, and pine plantation communities. These 

27 communities are described in more detail below. The ages of these pine-dominated plant 

28 communities are shown in Figure 3-12. 

29 

30 3.8.1.1 Pine Forest 

31 

32 Pine forest communities primarily occur within the north-central portion of the Wilmington Site, 

33 and within the upland area surrounded by the old oxbow of the Northeast Cape Fear River in 

34 the western portion of the site. Several small stands of pine forest are also scattered throughout 

35 the rest of the Wilmington Site. Most pine forest stands on the Wilmington Site, including those 

36 within and immediately adjacent to the proposed GLE Facility site, vary from less than 20 years 

37 old to 20 to 29 years old (Figure 3-12). A total of 123 hectares (304 acres) of pine forest occur 

38 on the Wilmington Site. Canopy species include loblolly, longleaf, and/or pond pines (Pinus

39 serotina). Subcanopy species can include sweetgum, white oak (Quercus alba), southern red 

40 oak (Q. falcata), water oak (Q. nigra), red maple (Acer rubrum), loblolly bay (Gordonia

41 lasianthus), flowering dogwood (Cornus florida), and tulip tree (Liriodendron tulipifera). Shrub 

42 species include coast pepper-bush (Clethra alnifolia), red bay (Persea borbonia), sweetbay 

43 magnolia (Magnolia virginiana), southern bayberry (Morella cerifera), sassafras (Sassafras

44 albidum), horsesugar (Symplocos tinctoria), farkleberry (Vaccinium arboreum), and southern 

 

8

 Level IV ecoregions are further subdivisions of a Level III ecoregion. Level IV ecoregions are based 

on physiography, geology, soils, climate, potential natural vegetation, land use, and land cover 

differences within a Level III ecoregion (Omernik et al., 2000). 
3-44 

Figure 3-10 Level IV Ecoregions Located within the Wilmington Site Area (Griffith et al., 
3-45 

Table 3-11 Level IV Ecoregions within the Wilmington Site 

Level IV Ecoregion Potential Natural Vegetation Land Use and Land Cover 

Carolina Flatwoods Longleaf pine (Pinus palustris) and 

Carolina wiregrass (Aristida stricta); 

xeric sandhill scrub (longleaf pine, 

turkey oak [Quercus laevis], and 

Carolina wiregrass); pond pine 

(P. serotina) forest and woodland; 

some oak-hickory and mixed forest. 

Pine plantations, mixed forest; 

forested wetlands; cropland (cotton, 

corn, soybeans, wheat, peanuts, 

tobacco, and blueberries); 

production of hogs, broiler 

chickens, and turkeys; some public 

lands; and wildlife habitat. 

Mid-Atlantic Floodplains 

and Low Terraces 

Southern floodplain forests, including 

cypress-gum swamps (water-tupelo 

[Nyssa aquatica], swamp tupelo 

[N. biflora], bald cypress [Taxodium

distichum], and pond cypress 

[T. ascendens]) and bottomland 

hardwood forests (bottomland oaks, 

red maple [Acer rubrum], sweetgum 

[Liquidambar styraciflua], green ash 

[Fraxinus pensylvanica], and 

bitternut hickory [Carya cordiformis]). 

Forested wetlands, deciduous 

forests, and some croplands on 

larger terraces. 

Source: Griffith et al., 2002.

1 

2 highbush blueberry (V. formosum). A number of vines also occur within the pine forest. These 

3 include Virginia creeper (Parthenocissus quinquefolia) and eastern poison-ivy (Toxicodendron

4 radicans). The herbaceous layer includes slender spikegrass (Chasmanthium laxum), ebony 

5 spleenwort (Asplenium platyneuron), cinnamon fern (Osmunda cinnamomea), bracken fern 

6 (Pteridium aquilinum), and narrowleaf silk grass (Pityopsis graminifolia var. graminifolia). 

7 

8 3.8.1.2 Pine-Hardwood Forest 

9 

10 The pine-hardwood forest community is similar to the pine forest community except that 

11 hardwood trees tend to co-dominate. Pine-hardwood forests occur in the north-central and 

12 south-central portions of the Wilmington Site. Scattered stands also occur in the eastern portion 

13 of the site. The pine-hardwood forest stands located within and immediately adjacent to the 

14 proposed GLE Facility site are approximately 20 to 29 years of age (Figure 3-12). The age of 

15 the other pine-hardwood forest stands on the Wilmington Site (e.g., in the south-central portion 

16 of the site) are not known (GLE, 2009b). A total of 93 hectares (231 acres) of pine-hardwood 

17 forests occur on the Wilmington Site. Sweet-gum, tulip tree, water oak, post oak (Quercus

18 stellata), white oak, red maple, blackgum (Nyssa sylvatica), and southern red oak are gradually 

19 replacing many of the pines within the forest canopy. Vine and herbaceous species are similar 

20 to those found in the pine forest communities. 

21 

22 3.8.1.3 Pine Plantation 

23 

24 Pine plantations on the Wilmington Site consist of loblolly or longleaf pines that are planted in 

25 rows. These plant communities are maintained by manual thinning and prescribed burns to 

26 clear understory plants. The 126 hectares (312 acres) of pine plantations occur in large stands 
3-46 

Figure 3-11 Plant Communities Located within the Wilmington Site (GLE, 2008) 
3-47 

Table 3-12 Plant Communities That Occur on the Wilmington Site 

Plant Community 

Acresa

(% of 

Site) 

Characteristic Plant Species 

Natural Communities 

Longleaf pine/scrub 

forest 

39 

(2.4) 

Longleaf pine (Pinus palustris) 

Pine forest 304 

(18.7) 

Loblolly pine (P. taeda), longleaf pine, and pond pine 

(P. serotina) 

Pine-hardwood forest 231 

(14.3) 

Pines: loblolly pine, longleaf pine, and pond pine 

Hardwoods: sweetgum (Liquidambar styraciflua), tulip tree 

(Liriodendron tulipifera), water oak (Quercus nigra), post oak 

(Q. stellata), white oak (Q. alba), red maple (Acer rubrum), 

blackgum (Nyssa sylvatica), and southern red oak (Q. falcata) 

Hardwood forest 10 

(0.6) 

Sweetgum, water oak (Q. nigra), and southern red oak 

Alluvial forest 4 

(0.2) 

Red maple and sweetgum 

Pocosin/bay forest 52 

(3.2) 

Loblolly pine and scattered pond pine intermixed with red bay 

(Persea borbonia), loblolly bay (Gordonia lasianthus), 

blackgum sand, pond cypress (Taxodium ascendens), and 

laurel oak (Q. hemisphaerica), with an isolated stand of Atlantic 

white cedar (Chamaecyparis thyoides) 

Swamp forest 325 

(20.0) 

Loblolly pine, tulip tree, blackgum, pumpkin ash (Fraxinus

profunda), red maple, sweetgum, and pond cypress 

Ephemeral pond 4 

(0.3) 

New Jersey blueberry (Vaccinium caesariense), swamp titi 

(Cyrilla racemiflora), red bay, red maple, and blackgum among 

other species 

Anthropogenically Influenced Communities 

Pine plantation 312 

(19.2) 

Loblolly pine and longleaf pine 

Field 2 

(0.1) 

Bahia grass (Paspalum notatum) 

Canal corridor 19 

(1.2) 

Various woody and herbaceous species, including Bahia grass, 

prickly Florida blackberry (Rubus argutus), Chinese bushclover 

(Lespedeza cuneata), northern dewberry (R. flagellaris), 

winged sumac (Rhus copallinum), broom-sedge (Andropogon

virginicus), small dog-fennel thoroughwort (Eupatorium

capillifolium), black willow (Salix nigra), Carolina willow 

(S. caroliniana), broadleaf cattail (Typha latifolia), common reed 

(Phragmites australis), and loblolly pine 

Power line corridor 16 

(1.0) 

Primarily shrub and herbaceous species that occur in adjacent 

plant communities 
3-48 

Wetlands 

Wetlands are areas that are inundated or 

saturated by surface water or groundwater at a 

frequency and duration sufficient to support, and 

that under normal circumstances do support, a 

prevalence of vegetation adapted for life in 

saturated soil conditions (EPA, 2009f).

Table 3-12 Plant Communities That Occur on the Wilmington Site (Cont.) 

Plant Community 

Acresa

(% of 

Site) 

Characteristic Plant Species 

Operations area 303 

(18.6) 

Mowed areas of Bahia grass and centipede grass (Eremochloa

ophiuroides) with ornamental and planted trees and shrubs 

Total: 1621 

(100.0) a

 To convert acres to hectares, multiply by 0.4047. 

Source: GLE, 2008. 

1 

2 throughout the Wilmington Site. Most pine plantation stands on the Wilmington Site, including 

3 those within and immediately adjacent to the proposed GLE Facility site, vary from less than 

4 20 years old to 20 to 29 years old (Figure 3-12). Sweetgum, red maple, water oak, red bay, 

5 loblolly bay, and sweetbay magnolia can also be present in the early stages of development of 

6 the pine plantation stands. These species become components of the understory as the 

7 plantation ages. Common shrub species include inkberry (Ilex glabra), American French 

8 mulberry (Callicarpa americana), fetterbush (Leucothoe racemosa), southern bayberry, and 

9 switch cane (Arundinaria gigantea ssp. tecta). Herbaceous species include broomsedge 

10 (Andropogon virginicus), American burnweed (Erechtites hieracifolia var. hieracifolia), small 

11 dog-fennel thoroughwort (Eupatorium capillifolium), flat-top fragrant goldenrod (Euthamia

12 graminifolia var. graminifolia), and eastern milkpea (Galactia regularis). 

13 

14 3.8.2 Wetlands 

15 

16 Wetlands on the Wilmington Site are 

17 extremely varied and include a number of 

18 wetland types such as marshes, pocosins, 

19 and forested wetlands (swamps). Wetland 

20 areas are typically inundated or have 

21 saturated soils for a portion of the growing 

22 season and support plant communities that 

23 are adapted to saturated soil conditions. 

24 Streambeds and mudflats are among the 

25 wetland areas that may not be vegetated 

26 (Cowardin et al., 1979). While surface flows provide the water source for some wetlands, 

27 others, such as springs and seeps, are supported by groundwater discharge. Wetlands are 

28 often associated with perennial water sources, such as springs, perennial segments of streams, 

29 or lakes and ponds. However, some wetlands have seasonal or intermittent sources of water. 

30 

31 Wetlands can perform one or more of the following functions: groundwater recharge and 

32 discharge, flood storage and desynchronization, shoreline anchoring and dissipation of erosive 

33 forces, sediment trapping, nutrient retention and removal, food chain support, and fish and 

34 wildlife habitat (Whigham and Brinson, 1990). 

35 
3-49 

Figure 3-12 Age and Management of Pine-Dominated Plant Communities on the Wilmington Site 
3-50 

1 Figure 3-13 shows the wetlands that occur on the Wilmington Site; Table 3-13 provides the 

2 acreages and descriptions of these wetlands. Nearly 308 hectares (760 acres) of wetlands 

3 occur within the Wilmington Site. More than 121 hectares (298 acres) of the forested wetlands 

4 within the North-Central and Eastern Site Sectors (where the proposed GLE Facility, ancillary 

5 facilities, and north access road would be located) were drained prior to 1963 (GLE, 2008). This 

6 area (shown as “PFO4Bd” in Figure 3-13) no longer meets the conditions necessary to be 

7 classified for regulatory purposes as a wetland (i.e., hydric soils, hydrophytic vegetation, and 

8 hydrological conditions that provide a temporary to permanent source of water to cause soil 

9 saturation) (EPA, 2009d). 

10 

11 Several jusridictional and isolated wetlands (wetlands with and without connections to surface 

12 waters, respectively) occur within the corridor for the proposed access road to the proposed 

13 GLE Facility (Figure 3-14). These would include jurisdictional wetlands WD, WF, and WG and 

14 isolated wetland WA. Wetland WD is a forested wetland that abuts Unnamed Tributary #1 to 

15 Prince George Creek. Only 0.0008 hectare (0.002 acre) of wetland WD occurs within the 

16 proposed access road corridor (GLE, 2009c). Wetland WF is an herbaceous wetland located in 

17 the upstream reach of Unnamed Tributary #1 to Prince George Creek. About 0.012 hectare 

18 (0.03 acre) of this wetland occurs within the access road corridor (GLE, 2009c). Wetland WG is 

19 a forested wetland that occurs along Jurisdictional Channel #2. About 0.08 hectare (0.02 acre) 

20 of this wetland occurs within the access road corridor (GLE, 2009c). Isolated wetland WA is a 

21 forested wetland that is contained entirely within the proposed access road corridor. The area 

22 of the wetland is 0.02 hectare (0.06 acre) (GLE, 2008). 

23 

24 3.8.3 Environmentally Sensitive Areas 

25 

Environmentally sensitive areas9 26 include conservation areas or other areas of ecological 

27 importance. Areas of outstanding natural significance in New Hanover County have been 

28 inventoried by LeBlond and Grant (2003). These are areas within the county that contain the 

29 best examples of natural habitats and/or are locations where rare biota or rare natural 

30 communities occur. 

31 

32 The southwestern portion of the Wilmington Site, which does not include the proposed 

33 GLE Facility site, occurs within the Northeast Cape Fear River Floodplain. The Northeast Cape 

34 Fear River Floodplain is considered to be a natural area of national significance. This means 

35 that the area is considered to contain examples of natural communities, rare plant or animal 

36 populations, or other significant ecological features that are among the highest quality or best 

37 examples of their kind in the nation (LeBlond and Grant, 2003). The Northeast Cape Fear River 

38 Floodplain natural area is located along the Northeast Cape Fear River from its confluence with 

39 Smith Creek in New Hanover County to its confluence with Holly Shelter Creek in Pender 

40 County. It encompasses 10,392 hectares (25,679 acres), 3572 hectares (8827 acres) of which 

 

9

 While environmentally sensitive areas do not have an official definition, they can be defined basically 

as natural features such as habitats or rare species that may be protected by government regulation. 

Jennings and Reganold (1989) defined environmentally sensitive areas as landscape elements or 

places that are crucial to the long-term maintenance of biological diversity, soil, water, and other 

natural resources, especially as they relate to human health, safety, and welfare, both at a local and 

regional context. 
3-51 

Figure 3-13 Wetlands Located within the Wilmington Site (GLE, 2008) 
3-52 

Table 3-13 Wetlands That Occur on the Wilmington Site 

Wetland 

Typea

Area 

(acres)b Wetland Characteristics 

PFO1/2F 235.3 Palustrine, forested, broad-leaved deciduous/needle-leaved 

deciduous, semipermanently flooded 

PFO1/4A 64.8 Palustrine, forested, broad-leaved deciduous/needle-leaved 

evergreen, temporarily flooded 

PFO1C 7.4 Palustrine, forested, broad-leaved deciduous, seasonally flooded 

PFO1Cdc 24.0 Palustrine, forested, broad-leaved deciduous, seasonally flooded, 

partially drained/ditched 

PFO4/1A 61.4 Palustrine, forested, needle-leaved evergreen/broad-leaved 

deciduous, temporarily flooded 

PFO4Bdc 274.4 Palustrine, forested, needle-leaved evergreen, saturated, partially 

drained/ditched 

PSS1/4A 1.9 Palustrine, scrub-shrub, broad-leaved deciduous/needle-leaved 

evergreen, temporarily flooded 

PSS1/4B 26.9 Palustrine, scrub-shrub, broad-leaved deciduous/needle-leaved 

evergreen, saturated 

PSS1A 0.1 Palustrine, scrub-shrub, broad-leaved deciduous, temporarily flooded 

PSS4/1B 32.9 Palustrine, scrub-shrub, needle-leaved evergreen/broad-leaved 

deciduous, saturated 

PUB3Hx 0.5 Palustrine, unconsolidated bottom, mixohaline, permanently flooded, 

excavated 

PUBGxc 13.3 Palustrine, unconsolidated bottom, intermittently flooded, excavated 

PUBKr 15.4 Palustrine, unconsolidated bottom, artificially flooded, artificial 

substrate 

Total: 758.3 

a

 Refer to Figure 3-13 for wetland locations. 

b

 To convert acres to hectares, multiply by 0.4047. 

c

 Limited wetland hydrology remains in the area. 

Sources: GLE, 2008; FWS, 1990. 
3-53 

Figure 3-14 Wetlands Located within the Corridor for the Proposed Access Road to the Proposed GLE 
3-54 

1 are within New Hanover County. It is one of the nation’s best examples of a tidal cypress-gum 

2 swamp community (LeBlond and Grant, 2003). 

3 

4 Most of the Northeast Cape Fear River, including the reach along the southwestern portion of 

5 the Wilmington Site, is considered a primary nursery area for shellfish and fish (NCDMF, 2006). 

6 Primary nursery areas are located in the upper portions of creeks and bays and are usually 

7 shallow with soft muddy substrates and are surrounded by marshes and other wetlands. The 

8 low salinity and abundance of food items make these areas ideal for young fish and shellfish. 

9 Many commercial fishing activities (e.g., use of trawl nets, seine nets, dredges, or any 

10 mechanical means used to collect clams and oyster) are prohibited in primary nursery areas 

11 (NCDMF, 2009). Areas designated as primary nursery areas by the North Carolina Division of 

12 Marine Fisheries would also be considered to be essential fish habitat. Essential fish habitat are 

13 defined as those waters and substrate necessary for Federally managed marine and 

14 anadromous fish species and Federally managed shellfish species for spawning, breeding, 

15 feeding, or growth to maturity (Magnuson-Stevens Fishery Conservation and Management Act, 

16 16 U.S.C. 1801 Section 3). 

17 

18 On a more localized scale, environmentally sensitive area features can include floodplains, 

19 wetlands, unstable soils, and steep slopes. The 100-year floodplain within the Wilmington Site 

20 occurs along the Northeast Cape Fear River, while the 500-year floodplain occurs within the 

21 forested wetland areas in the western portion of the Wilmington Site (GLE, 2008). Wetlands on 

22 the Wilmington Site are discussed in Section 3.8.2. About 30 hectares (74 acres) of unstable 

23 soils occur on the Wilmington Site, all at or within the vicinity of four former borrow pits. One of 

24 the areas of unstable soils occurs in the northwestern portion of the Wilmington Site, while the 

25 other three areas are located within the south–central and southern portion of the site 

26 (GLE, 2008). Gradients greater than 10 percent are considered steep slopes. Most areas of 

27 steep slopes on the Wilmington Site are contained along the remnant oxbow of the Northeast 

28 Cape Fear River and along the banks of existing stream banks and the effluent channel. Some 

29 steep slopes also occur in the area of the former borrow pits. 

30 

31 Except for drained forested wetlands, none of these sensitive area features occur within the 

32 proposed GLE Facility area. Small wetland areas that occur within the corridor for the access 

33 road were discussed in Section 3.8.2. 

34 

35 3.8.4 Wildlife 

36 

37 Although the Wilmington Site has been subjected to varying degrees of environmental 

38 disturbances from silviculture, agriculture, industrial operations, residential developments, and 

39 roads, the habitats within the Wilmington Site and surrounding areas support a relatively high 

40 diversity of wildlife species. Nearly 370 species of mammals, birds, reptiles, and amphibians 

41 potentially occur on the Wilmington Site. Wildlife species that could occur within the proposed 

42 GLE Facility area are primarily those that inhabit forested habitats. 

43 

44 About 40 mammal species could occur in the area. These include white-tailed deer (Odocoileus

45 virginianus), American black bear (Ursus americanus), bobcat (Lynx rufus), gray fox (Urocyon

46 cinereoargenteus), raccoon (Procyon lotor), eastern cottontail (Sylvilagus floridanus), marsh 

47 rabbit (S. palustris), eastern gray squirrel (Sciurus carolinensis), and striped skunk (Mephitis

48 mephitis). In addition, a number of bat, shrew, and small rodent (e.g., mice and voles) species 
3-55 

1 are likely to occur in the proposed GLE Facility area. These would include the short-tailed 

2 shrew (Blarina brevicauda), eastern red bat (Lasiurus borealis), hoary bat (L. cinereus), golden 

3 mouse (Ochrotomys nuttallii), and woodland vole (Microtus pinetorum). 

4 

5 More than 100 bird species could occur within the proposed GLE Facility area. Widespread and 

6 common species include wild turkey (Meleagris gallopavo), northern bobwhite (Colinus

7 virginianus), mourning dove (Zenaida macroura), red-eyed vireo (Vireo olivaceus), northern 

8 cardinal (Cardinalis cardinalis), tufted titmouse (Baeolophus bicolor), eastern towhee (Pipilo

9 erythrophthalmus), wood thrush (Hylocichla mustelina), summer tanager (Piranga rubra), blue10 gray gnatcatcher (Polioptila caerulea), hooded warbler (Wilsonia citrina), and Carolina wren 

11 (Thryothorus ludovicianus). No sites on or near the Wilmington Site are recognized as 

Important Bird Areas (National Audubon Society, 2009a).10 12 

13 

14 Nearly 40 reptile species could occur within the habitat types found in the proposed GLE Facility 

15 area. Included among these would be the eastern box turtle (Terrapene carolina), green anole 

16 (Anolis carolinensis), ground skink (Scincella lateralis), six-lined racerunner (Aspidoscelis

17 sexlineata), eastern kingsnake (Lampropeltis getula getula), racer (Coluber constrictor), and 

18 red-bellied snake (Storeria occipitomaculata). Several species of rattlesnakes (Crotalus spp.) 

19 and the copperhead (Agkistrodon contortrix) could also occur within the upland forested habitats 

20 of the proposed GLE Facility area. Fewer than 10 amphibian species would be expected to 

21 occur within the proposed GLE Facility area. These could include the redback salamander 

22 (Plethodon cinereus), Fowler’s toad (Bufo fowleri), southern toad (B. terrestris), and several 

23 species of treefrogs (Hyla spp.). These reptile and amphibian species could occur within 

24 suitable habitat types throughout the Wilmington Site. 

25 

26 The developed portions (operations area) of the Wilmington Site include buildings, parking lots, 

27 infrastructure, and landscaped areas. Nevertheless, a number of wildlife species occur in these 

28 areas. However, the densities of most wildlife species are higher in undeveloped areas than in 

29 developed areas. Exceptions include species such as house sparrow (Passer domesticus), 

30 house finch (Carpodacus mexicanus), rock pigeon (Columba livia), house mouse (Mus

31 musculus), and Norway rat (Rattus norvegicus). Other common bird species within the 

32 operations area include the killdeer (Charadrius vociferus), American crow (Corvus

33 brachyrhynchos), northern mockingbird (Mimus polyglottos), American robin (Turdus

34 migratorius), and European starling (Sturnus vulgaris). Other mammal species include Virginia 

35 opossum (Didelphis virginiana), eastern cottontail, striped skunk, and raccoon. Generally, it 

36 would be expected that wildlife use of the operational areas would primarily be for foraging, 

37 while the least frequent type of use would be for reproductive activities. 

38 

39 3.8.5 Aquatic Biota 

40 

41 The Northeast Cape Fear River (at River Mile 6.1 to 6.7 [river kilometer 9.8 to 10.7]) borders the 

42 southwestern portion of the Wilmington Site. Aquatic habitats within the Wilmington Site include 

 

10 Important Bird Areas are sites that provide essential habitat for one or more species of birds that are 

species of conservation concern, species with restricted ranges, species that are vulnerable because 

their populations are concentrated in one general habitat type or biome, or species (or groups of 

similar species) that are vulnerable because they occur at high densities because of congregatory 

behavior (National Audubon Society, 2009b). 
3-56 

1 Unnamed Tributary #1 to the Northeast Cape Fear River, an industrial effluent channel that 

2 flows into Unnamed Tributary #1, Unnamed Tributary #2 to the Northeast Cape Fear River, 

3 several other smaller tributaries to the Northeast Cape Fear River, and an Unnamed 

4 Tributary #1 to Prince George Creek. An Unnamed Tributary #2 to Prince George Creek occurs 

5 just north of the Wilmington Site and receives drainage from the northern portion of the site. 

6 The lower portions of the tributaries to the Northeast Cape Fear River, as well as the Northeast 

7 Cape Fear River in the area of the Wilmington Site, are tidally influenced. Water quality 

8 characteristics of these water bodies are discussed in Section 3.7.1. 

9 

10 In addition to the onsite streams, several impoundments and ponds on the Wilmington Site 

11 provide aquatic habitat. These include two active final process lagoons and their associated 

12 aeration basin (which are part of the Wilmington Site’s treatment system for process 

13 wastewater), four inactive wastewater treatment facility lagoons, one firefighting water supply 

14 pond, two stormwater wet detention basins, and three ephemeral woodland ponds. These 

15 impoundments and ponds would provide habitat for aquatic invertebrates, waterfowl and 

16 shorebirds, and amphibians. No aquatic habitats occur within the area proposed for the 

17 GLE Facility. More detailed information on the surface waters of the Wilmington Site were 

18 presented in Section 3.7. 

19 

20 Nearly 110 species of freshwater, marine, and migratory fish are reported from the Northeast 

21 Cape Fear River. About 40 fish species plus sunfish hybrids have been collected from the 

22 Northeast Cape Fear River near the Wilmington Site (NCWRC, 2007). About 50 of the species 

23 from the Northeast Cape Fear River are considered freshwater species. These include gars, 

24 suckers, minnows, catfish, sunfish, bass, crappie, perch, and darters. The anadromous species 

25 (species that migrate to freshwaters to spawn) include the blueback herring (Alosa aestivalis), 

26 hickory shad (A. mediocris), alewife (A. pseudoharengus), American shad (A. sapidissima), 

27 striped bass (Morone saxatilis), and shortnose sturgeon (Acipenser brevirostrum); the American 

28 eel (Anguilla rostrata) is the only catadromous species (species that migrate to marine waters to 

29 spawn). The Federally endangered shortnose sturgeon is discussed in more detail in 

30 Section 3.8.6.1. The blueback herring spawns in Prince George Creek, while the American shad 

31 and striped bass use the creek as nursery grounds. Atlantic sturgeon (Acipenser oxyrhynchus) 

32 and American eel are also present in the area of Prince George Creek (NOAA, 2002). 

33 

34 During periods of drought and elevated salinities, the fish community in the Northeast Cape 

35 Fear River near the Wilmington Site could shift to more estuarine species (NCWRC, 2007). 

36 About 50 marine and estuarine fish species ascend into the Northeast Cape Fear River. These 

37 include the bay anchovy (Anchoa mitchilli), gobies, striped mullet (Mugil cephalus), and pipefish. 

38 Marine and estuarine gamefish include the tarpon (Megalops atlanticus), crevalle jack (Caranx

39 hippos), common snook (Centropomus undecimalis), spotted seatrout (Cynoscion nebulosus), 

40 black drum (Pogonias cromis), and red drum (Sciaenops ocellatus). 

41 

42 Commercial and recreational fishing occur in the Northeast Cape Fear River, although most 

43 commercial fishing occurs downstream of the Wilmington Site (e.g., in the Cape Fear River 

44 Estuary). Commercial fishing for American shad and striped bass occurs in the Northeast Cape 

45 Fear River near the Wilmington Site, while recreational fishing occurs for these species plus 

46 blueback herring, hickory shad, alewife, largemouth bass (Micropterus salmoides), bluegill 

47 (Lepomis macrochirus), redear sunfish (L. microlophus), redbreast sunfish (L. auritus), 

48 pumpkinseed (L. gibbosus), warmouth (L. gulosus), black crappie (Pomoxis nigromaculatus), 
3-57 

1 channel catfish (Ictalurus punctatus), blue catfish (I. furcatus), chain pickerel (Esox niger), redfin 

2 pickerel (E. americanus), and yellow perch (Perca flavescens) (Ashley and Rachels, 2005). 

3 Sport fishing within the Cape Fear River Basin also occurs for the introduced spotted bass 

4 (M. punctulatus) and flathead catfish (Pylodictis olivaris) (Ashley and Rachels, 2005). 

5 

6 No major studies of fish species within the Wilmington Site have been conducted. During the 

7 onsite biological surveys for the Environmental Report, the eastern mosquitofish (Gambusia

8 halbrooki) and a blue crab (Callinectes sapidus) were observed in the Unnamed Tributary #1 to 

9 the Northeast Cape Fear River (GLE, 2008). In addition to being an important nursery area for 

10 a number of fish species, the Northeast Cape Fear River is also used as a nursery area by 

11 shrimp, blue crabs, and other shellfish. 

12 

13 The Federally endangered West Indian manatee (Trichechus manatus), a marine mammal, may 

14 also occur within the Northeast Cape Fear River and the lower portions of its tributaries near the 

15 Wilmington Site. Information on the West Indian manatee is presented in Section 3.8.6.1. 

16 

17 The major factor limiting fisheries resources within the Cape Fear River Basin is the impedance 

18 to fish migrations by locks and dams. Additional factors include degraded water quality, 

19 sedimentation and turbidity, and loss of wetlands and riparian areas resulting from agricultural 

20 and forestry operations, increased development, unstable shorelines, and road construction 

21 (Ashley and Rachels, 2005). 

22 

23 3.8.6 Threatened, Endangered, and Other Special Status Species 

24 

25 Because of the diversity of species, habitats, and other influences (e.g., convergence of inland 

26 sandhill habitat with coastal areas), a large number of rare plants and animals are native to 

27 New Hanover County (LeBlond and Grant, 2003). The National Marine Fisheries Service 

28 (NMFS) and U.S. Fish and Wildlife Service (FWS) are responsible for listing aquatic and 

29 terrestrial species as threatened and endangered at the Federal level, as delegated by the 

30 Endangered Species Act (ESA), as amended (16 U.S.C. 573, et seq.). NRC consultations with 

the FWS and NMFS have been conducted to comply with Section 7 of the ESA.11 31 The State of 

32 North Carolina lists additional species that are regionally threatened, endangered, or rare. The 

33 North Carolina Wildlife Resource Commission within the Department of Environment and 

34 Natural Resources has regulatory authority over animals (except insects), while the Plant 

35 Conservation Program within the North Carolina Department of Agriculture has regulatory 

36 authority over plants and insects. 

37 

38 3.8.6.1 Federally Listed Species 

39 

40 Nine Federally threatened or endangered species known to occur in New Hanover County 

41 (FWS, 2009a). No critical habitat for any of the nine species occurs in the area of the 

42 Wilmington Site (FWS, 2009a). In addition to the threatened and endangered species, a 

43 number of Federal species of concern occur within New Hanover County. Table 3-14 lists the 

44 Federally threatened or endangered species and species of special concern that are known to 

45 occur or likely to occur within New Hanover County, along with their State status (as applicable). 

 

11 Letters of consultation can be found in Appendix B. 
3-58 

1 

Table 3-14 Federally Threatened, Endangered, and Special Concern Species Reporte

from New Hanover County, North Carolina 

Scientific Name Common Namea Status Federal/Stateb Record Statusc Habitat 

Plants Amaranthus pumilus Seabeach amaranth T/T Current Upper beaches, foredunes, overw

flats and sand/shell replenishmenand dredge spoils. 

Amorpha georgiana var. 

confusa

Georgia indigobush FSC/T Historic Dry savannas and riverbanks. 

Astragalus michauxii Sandhills milkvetch FSC/T Historic Longleaf pine/scrub oak woodlandDionaea muscipula Venus’ flytrap FSC/SR-L Current Bogs and perennially wet areas. Hypericum adpressum Creeping St. John’swort FSC/NL Historic Shores, shallow waters of freshwa

ponds. 

Litsea aestivalis Pondspice FSC/SR-T Current Margins of swamps, cypress pond

and sandhill depression ponds. 

Ludwigia ravenii Raven’s seedbox FSC/SR-T Historic Swamps, bogs, ponds. Lysimachiaasperulaefolia

Roughleaf loosestrife E/E Current Edges between longleaf pine upla

and pond pine pocosins on moist seasonally saturated sands or shallow organic soils overlying sa

Pteroglossaspis ecristata Giant orchid FSC/SR-T Historic Pine savannas, scrub oaks. Ptilimnium ahlesii Carolina bishopweed FSC/SR-L Current Tidal freshwater marshes. Rhynchospora pleiantha Brown beakrush FSC/T Current Sands and peat of pond shores a

moist pine savannas. 

Sagittaria graminea var. weatherbiana

Grassleaf arrowhead FSC/SR-T Current Swamps. 
3-59 

Table 3-14 Federally Threatened, Endangered, and Special Concern Species Reporte

from New Hanover County, North Carolina (Cont.) 

Scientific Name Common Namea Status Federal/Stateb Record Statusc Habitat 

Sideroxylon tenax Tough bumelia FSC/SR-P Historic Maritime forests and scrub. Solidago verna Spring-flowering 

goldenrod 

FSC/T Current Pine savannas, pocosins, pine 

barrens, open woods, fields, dry bogs, and disturbed roadsides. 

Solidago villosicarpa Coastal goldenrod FSC/E Historic Mesic, hardwood forests with den

canopies and sparse understories and areas of disturbance. 

Stylisma pickeringii var. pickeringii

Pickering’s morningglory FSC/E Current Scrub habitats with sandy soils, minimal litter accumulation, spars

ground cover, and little canopy coof scattered scrubby oaks and pin

Thalictrum cooleyi Cooley’s meadowrue E/E Historic Wet savannas. Thalictrum macrostylum Small-leaf meadowrue FSC/SR-L Current Bogs, wet woods, and cliffs. Trichostema sp. 1 Dune blue curls FSC/SR-L Current Maritime grasslands behind 

foredunes, maritime scrub. 

Invertebrates Agrotis buchholzi Buchholz’s dart moth FSC/NL Current Pine plains. Atrytone arogos arogos Eastern arogos 

skipper 

FSC/SR Obscure Savannas, open pinewoods, and 

other relatively undisturbed grasslands. 

Atrytonopsis loammi Loammi skipper FSC/SR Obscure Barrier islands. Helisoma eucosmium Greenfield ramshorn 

snail 

FSC/E Historic Shallow creek beds, marshes, and 

swamps. 
3-60 

Table 3-14 Federally Threatened, Endangered, and Special Concern Species Reporte

from New Hanover County, North Carolina (Cont.) 

Scientific Name Common Namea Status Federal/Stateb Record Statusc Habitat 

Planorbella magnifica Magnificent rams-horn FSC/E Historic Ponds. Problema bulenta Rare skipper FSC/SR Current Brackish water marshes, abandon

rice paddies. 

Triodopsis soelneri Cape Fear threetooth FSC/T Current Savannas, flatwoods, and swamp

Fishes Acipenser brevirostrum Shortnose sturgeon E/E Current Downstream reaches of large rive

and Atlantic coastal waters. It predeep water with soft substrate and vegetated bottoms. 

Anguilla rostrata American eel FSC/NL Current Matures in fresh or brackish wate

spawns in the Sargasso Sea. 

Amphibians Rana capito capito Carolina gopher frog FSC/T Current Sandhills, pine and turkey oak 

woodlands; breeds in wetlands antemporary ponds. 

Reptiles Alligator mississippiensis American alligator T(S/A)/T Current Freshwater swamps and marshes

but can also be found in rivers, lakand other bodies of water. 

Caretta caretta Loggerhead T/T Current Open seas. Chelonia mydas Green turtle T/T Current Open seas. Heterodon simus Southern hog-nosed 

snake 

FSC/SC Current Mature pine forests and sandhills. 
3-61 

Table 3-14 Federally Threatened, Endangered, and Special Concern Species Reporte

from New Hanover County, North Carolina (Cont.) 

Scientific Name Common Namea Status Federal/Stateb Record Statusc Habitat 

Ophisaurus mimicus Mimic glass lizard FSC/SC Historic Sandhills, pine and turkey oak 

woodlands. 

Pituophis melanoleucus

melanoleucus

Northern pinesnake FSC/SC Current Woodlands. 

Birds Charadrius melodus Piping plover T/T Current Nests in barrier island beaches; 

sandy beach shoals used during migration and winter. 

Passerina ciris ciris Eastern painted 

bunting 

FSC/SR Current Woodlands. 

Picoides borealis Red-cockaded 

woodpecker 

E/E Current Open stands of mature pine trees 

>60 years old for nesting and roosting; pine and pine/hardwood stands >30 years old for foraging. 

Mammals Corynorhinus rafinesquii Rafinesque’s bigeared bat FSC/T Current Riparian woodlands, hardwood forests. Myotis austroriparius Southeastern myotis FSC/SC Current Nests in snags and hollow trees in 

conifer and hardwood forests. Forages in riparian areas and uplands. 

Trichechus manatus West Indian manatee E/E Current Shallow coastal bays, lagoons, 

estuaries, and inland rivers. 

Footnotes on following page. 1 
3-62 

Table 3-14 Federally Threatened, Endangered, and Special Concern Species Reporte

from New Hanover County, North Carolina (Cont.) 

a Common names follow those used in NatureServe, 2009. b E = endangered; FSC = Federal species of concern; SC = special concern; SR = significantly rare; SR-L = significantly rare – lim

SR-P = significantly rare – peripheral; SR-T = significantly rare – throughout; T = threatened; T(S/A) = threatened due to similarity NL = not listed. 

c Current: the species has been observed in the county within the last 50 years; Historic: the species was last observed in the cou

50 years ago; Obscure: the date and/or location of observation is uncertain. 

d WS = Wilmington Site, GLEF = proposed GLE Facility site. 

Sources: Buchanan and Finnegan, 2008; FWS, 2009a; Jordan, 1998; LeGrand et al., 2008; NatureServe, 2009; NCNHP, 2001; P

GLE, 2008; FWS, 2008a; 2003a,b. 
3-63 

1 While several listed species exist or may exist in the Wilmington Site area, no listed species 

2 have been reported from the area proposed for the GLE Facility. 

3 

4 The following definitions are applicable to the species categories for listing under the ESA 

5 (FWS, 2008d): 

6 

7 • Endangered: any species that is in danger of extinction throughout all or a significant portion 

8 of its range. 

9 

10 • Threatened: any species that is likely to become endangered within the foreseeable future 

11 throughout all or a significant part of its range. 

12 

13 • Threatened due to similarity of appearance: a taxon that is threatened due to similarity of 

14 appearance with another listed species and is listed for its protection. Taxa listed as 

15 “threatened due to similarity of appearance” are not biologically endangered or threatened 

16 and are not subject to Section 7 consultation. 

17 

18 • Proposed for listing: species that have been formally proposed for listing by the FWS or 

NMFS by notice in the Federal Register.

12, 19 

20 

21 • Candidate: species for which the FWS or NMFS has sufficient information on their biological 

22 status and threats to propose them as threatened or endangered under the ESA but for 

23 which development of a proposed listing regulation is precluded by other higher priority 

24 listing actions. 

25 

26 • Federal species of concern: species under consideration for listing, for which there is 

27 insufficient information to support listing at this time. These species may or may not be 

28 listed in the future, and many of these species were formally recognized as Category 2 (C2) 

candidate species.13 29 

30 

31 • Critical habitat: specific areas within the geographical area occupied by the species at the 

32 time it is listed, on which are found physical or biological features essential to the 

33 conservation of the species and which may require special management considerations or 

34 protection. Except when designated, critical habitat does not include the entire geographical 

35 area that can be occupied by the threatened, endangered, or other special status species. 

36 

 

12 Within one year of a listing proposal, the FWS or NMFS must take one of three possible courses of 

action: (1) finalize the listing rule (as proposed or revised); (2) withdraw the proposal if the biological 

information on hand does not support the listing; or (3) extend the proposal for up to an additional 

six months because, at the end of one year, there is substantial disagreement within the scientific 

community concerning the biological appropriateness of the listing. After the extension, the FWS or 

NMFS must decide whether to list the species on the basis of the best scientific information available. 

13 Category 2 (C2) species are species for which information in the possession of the FWS indicated that 

proposing to list the species as endangered or threatened was possibly appropriate, but for which 

persuasive evidence on biological vulnerability and threat was not available to support the listing. 

Thus, the FWS concluded that these species might be threatened or endangered, but more 

information was necessary before a final conclusion could be reached. 
3-64 

1 Among the Federally listed threatened or endangered species that occur within New Hanover 

2 County, the seabeach amaranth (Amaranthus pumilus), Cooley’s meadowrue (Thalictrum

3 cooleyi), green turtle (Chelonia mydas), loggerhead (Caretta caretta), and piping plover 

4 (Charadrius melodus) do not occur within the Wilmington Site area. The following paragraphs 

5 describe the Federally listed threatened or endangered species and Federal species of concern 

6 that exist or may exist in the Wilmington Site area. Unless otherwise referenced, the 

7 information on each species is adapted from NatureServe (2009), with species status provided 

8 by Buchanan and Finnegan (2008) for plants and LeGrand et al. (2008) for animals. 

9 

10 Plants

11 

12 Carolina bishopweed (Ptilimnium ahlesii)

13 

14 The Carolina bishopweed, an erect annual herb, is a Federal species of concern and is 

considered to be significantly rare – limited by the State14 15 . The plant inhabits freshwater tidal 

16 marshes (Weakley, 2008). Threats to the Carolina bishopweed include invasion by common 

17 reed (Phragmites australis) and water pollution (NatureServe, 2009; Weakley, 2008). No 

18 occurrences of the Carolina bishopweed have been recorded within 3.2 kilometers (2 miles) of 

19 the Wilmington Site (NCNHP, 2009). 

20 

21 Coastal goldenrod (Solidago villosicarpa)

22 

23 The coastal goldenrod, a perennial herb, is a Federal species of concern and is State listed as 

24 endangered. It occurs in a wide variety of wooded habitats, occurring in areas associated with 

25 natural or human-caused disturbance (CPC, 2008a). Canopy closure is a threat to the coastal 

26 goldenrod. Invasive species also present a minor threat to the species. An occurrence was 

27 recorded within 3.2 kilometers (2 miles) of the northern boundary of the Wilmington Site, but 

28 more than that distance from the proposed GLE Facility area (NCNHP, 2009). Habitat 

29 potentially suitable for the coastal goldenrod occurs in the pine-hardwood forests in the north30 central and south-central portions of the Wilmington Site (GLE, 2008). 

31 

32 Grassleaf arrowhead (Sagittaria graminea var. Weatherbiana)

33 

34 The grassleaf arrowhead is a Federal species of concern and is considered significantly rare – 

35 throughout by the State. It is a perennial herb that inhabits shallow water and wet shores of 

36 ponds, marshes, and ditches. Threats to the species include drainage and other habitat 

37 modification that causes excessive drying of wetland habitat (Burns and Cusick, 1983). No 

38 occurrences of the grassleaf arrowhead have been recorded within 3.2 kilometers (2 miles) of 

39 the Wilmington Site (NCNHP, 2009). 

40 

41 Pickering’s morning-glory (Stylisma pickeringii var. pickeringii)

42 

43 The Pickering’s morning-glory (also known as Pickering’s dawnflower) is a Federal species of 

44 concern and is State-listed as endangered. The species is a perennial, creeping vine that 

45 occurs in dry to extremely dry, nutrient-poor, well-drained, coarse sandy soils. Tree cover, 

46 ground cover, and litter accumulation are generally sparse (Patrick et al., 1995). It generally 

 

14 The North Carolina status definitions are provided at the end of Section 3.8.6.2. 
3-65 

1 forms large mats or clumps in dry, barren, deep sand areas such as the edge of Carolina bays 

2 and relic riverine dunes (CPC, 2008b; Weakley, 2008). Preferred locations include frequently 

3 burned or clear-cut areas with little or no competing vegetation (CPC, 2008b). Threats to the 

4 Pickering’s morning-glory include habitat loss and modification and disruption of natural fire 

5 regimes. There is a 1958 occurrence record for the Pickering’s morning-glory within 

6 3.2 kilometers (2 miles) of the proposed GLE Facility area (NCNHP, 2009). The Operations 

7 Area in the northwestern portion of the Wilmington Site contains deep sands that are 

8 periodically disturbed and may provide suitable habitat for the Pickering’s morning-glory 

9 (GLE, 2008). 

10 

11 Pondspice (Litsea aestivalis)

12 

13 Pondspice is a Federal species of concern and is considered significantly rare – throughout by 

14 the State. It is a deciduous shrub that inhabits the margins of swamps; cypress ponds; low wet 

15 woodlands; and sandhill depressions on wet, sandy or peaty, acidic soils. It may form thickets 

16 and be locally abundant. Pondspice is threatened by hydrological alterations (e.g., ditching and 

17 draining of wetland habitat and lowering of the water table) and suppression of natural fire 

18 regimes. It may be potentially threatened by red bay (or laurel wilt) disease, an emerging fungal 

19 disease for which the pondspice is a documented host. There is a 1977 occurrence record for 

20 the pondspice within 3.2 kilometers (2 miles) of the proposed GLE Facility area around the 

21 perimeter of an ephemeral pond within the north-central portion of the Wilmington Site 

22 (GLE, 2008; NCNHP, 2009). However, hydrological conditions of this pond have been altered 

23 and do not appear to support recruitment of the species. During field surveys for the 

24 Environmental Report, the existing plants appeared stressed (GLE, 2008). The location of the 

25 proposed GLE Facility is more than 150 meters (500 feet) southeast of the ephemeral pond 

26 (GLE, 2008). 

27 

28 Raven’s seedbox (Ludwigia ravenii)

29 

30 Raven’s seedbox, a perennial herb, is a Federal species of concern and is considered 

31 significantly rare – throughout by the State. It is an obligate wetland species that inhabits open, 

32 wet, peaty areas such as ditches and the margins of swamps, ponds, and bogs. Threats to the 

33 Raven’s seedbox include excavation and deepening of ditches, road widening and paving, and 

34 herbicide use. The Raven’s seedbox does not have any occurrence record within 

35 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). 

36 

37 Roughleaf loosestrife (Lysimachia asperulaefolia)

38 

39 The roughleaf loosestrife, an erect perennial herb, is both Federally and State-listed as 

40 endangered. It occurs in grass-shrub ecotones (transition areas between two habitats that can 

41 contain characteristic species from both) adjacent to longleaf pine/scrub oak, pine savanna, 

42 flatwoods, and pond pine pocosins (evergreen shrub bogs). It prefers full sunlight and is shade 

43 intolerant (CPC, 2008c; NCNHP, 2001). It grows on moist, seasonally saturated sands or 

44 shallow organic soils overlying sands. The roughleaf loosestrife has been found in roadside 

45 depressions, firebreaks, seeps, and power rights-of-way (ROWs) (NCNHP, 2001). The 

46 roughleaf loosestrife flowers from mid-May through June, with fruits present from July through 

47 October. Habitats within which the species occur are fire-maintained. Threats to the roughleaf 

48 loosestrife include drainage and development of habitat, land conversion, and suppression of 
3-66 

1 natural fire regimes (CPC, 2008c). Suppression of naturally occurring fires within ecotones 

2 allows shrubs to increase in density and height, which eliminates the open edges required by 

3 the species (FWS, 2009a). No occurrences for the roughleaf loosestrife have been recorded 

4 within 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). Some areas of pocosin 

5 habitats that support the species have been drained from the Wilmington Site. Also, fire 

6 regimes necessary for maintaining the species habitat do not occur on the site (GLE, 2008). 

7 

8 Sandhills milkvetch (Astragalus michauxii)

9 

10 The sandhills milkvetch, an erect perennial herb, is a Federal species of concern and is State11 listed as threatened. It inhabits longleaf pine/scrub oak woodlands. It grows best in disturbed 

12 or fire-prone open understory areas (e.g., xeric to dry-mesic, nutrient poor soils, thickets, field 

13 edges, and road banks). Threats to the sandhills milkvetch include suppression of natural fire 

14 regimes, land conversion, and habitat fragmentation. There is a 1946 occurrence record for the 

15 sandhills milkvetch southwest of the Wilmington Site near the intersection of US 421 and I-140, 

16 which is within 3.2 kilometers (2 miles) of the proposed GLE Facility site (NCNHP, 2009; 

17 GLE, 2008). The longleaf pine/scrub forest in the northwestern portion of the Wilmington Site 

18 and the pine plantation in the north-central portion of the site could provide suitable habitat for 

19 the species. 

20 

21 Small-leaf meadowrue (Thalictrum macrostylum)

22 

23 The small-leaf meadowrue, an erect herb, is a Federal species of concern and is considered 

24 significantly rare – limited by the State. Habitat for the species includes swampy woodlands, 

25 slopes, and limestone cliffs. Threats to the small-leaf meadowrue include land use alteration, 

26 habitat fragmentation, silviculture practices, and changes in hydrology. No occurrences of the 

27 small-leaf meadowrue have been recorded within 3.2 kilometers (2 miles) of the Wilmington Site 

28 (NCNHP, 2009). 

29 

30 Spring-flowering goldenrod (Solidago verna)

31 

32 The spring-flowering goldenrod, an erect perennial herb, is a Federal species of concern and is 

33 State listed as threatened. It inhabits a wide variety of habitats such as pine savannas, 

34 pocosins, pine barrens, open woods, fields, dry bogs, and disturbed roadsides (CPC, 2008d). 

35 Threats to the spring-flowering goldenrod include alteration and destruction of habitat for 

36 development, pine plantations, and agriculture. No occurrences of the spring-flowering 

37 goldenrod have been recorded within 3.2 kilometers (2 miles) of the Wilmington Site 

38 (NCNHP, 2009). Pocosin/bay and pine forests potentially provide limited habitat for the spring39 flowering goldenrod on the Wilmington Site (GLE, 2008). 

40 

41 Venus’ flytrap (Dionaea muscipula)

42 

43 The Venus’ flytrap, an insectivorous herb, is a Federal species of concern and is considered 

44 significantly rare – limited by the State. It inhabits bogs and perennially wet areas, often located 

45 between longleaf pine savannas and pocosins (shrub bogs) on the coastal plains of the 

46 Carolinas (Floridata, 2003). Threats to the Venus’ flytrap include habitat conversion and 

47 suppression of natural fire regimes. Some collecting from natural populations can also affect 

48 the species. Two occurrences of the Venus’ flytrap have been recorded within 3.2 kilometers 
3-67 

1 (2 miles) of the Wilmington Site, one of which is also within 3.2 kilometers (2 miles) of the 

2 proposed GLE Facility area (NCNHP, 2009). Suitable habitat for the Venus’ flytrap occurs 

3 within the western portion of the Wilmington Site, where pine forest and pocosin habitats are 

4 adjacent to each other. 

5 

6 Invertebrates

7 

8 Cape Fear threetooth (Triodopsis soelneri)

9 

10 The Cape Fear threetooth is a Federal species of concern and is listed as threatened by the 

11 State. It is a terrestrial snail that occurs on logs and under litter in swamps and under trash in 

12 pine woods (Hubricht, 1985). The main threat to the species is presumed to be habitat loss. No 

13 occurrences of the Cape Fear threetooth have been recorded within 3.2 kilometers (2 miles) of 

14 the Wilmington Site (NCNHP, 2009). 

15 

16 Eastern arogos skipper (Atrytone arogos arogos)

17 

18 The eastern arogos skipper is a Federal species of concern, and the butterfly is considered 

19 significantly rare by the State. It inhabits native grasslands and savannas. Individuals are 

20 capable of dispersing several miles. The known North Carolina site for the species contains 

21 habitats that are mesic to boggy, sometimes ecotonal, pinebarrens reedgrass (Calamovilfa

22 brevipilis) savanna. The pinebarrens reedgrass is a foodplant for eastern arogos skipper larvae. 

23 Adults obtain nectar from a variety of flowers. Threats to the eastern arogos skipper include 

24 habitat loss and fragmentation and fire (including prescribed burns). No occurrences of the 

25 eastern arogos skipper have been recorded within 3.2 kilometers (2 miles) of the Wilmington 

26 Site (NCNHP, 2009). 

27 

28 Greenfield ramshorn snail (Helisoma eucosmium)

29 

30 The Greenfield ramshorn snail is a Federal species of concern and is listed as endangered by 

31 the State. Within New Hanover County, this freshwater snail is only known from Greenfield 

32 Lake in Wilmington. It is also known from Town Creek in Brunswick County and from the 

33 Wisconsin River in the northeastern portion of the State. Specimens from Town Creek 

34 inhabited densely vegetated areas in water less than 3 meters (10 feet) deep. Threats to the 

35 species include habitat degradation and, possibly, invasive plant species. No occurrences of 

36 the Greenfield ramshorn snail have been recorded within 3.2 kilometers (2 miles) of the 

37 Wilmington Site (NCNHP, 2009). 

38 

39 Rare skipper (Problema bulenta)

40 

41 The rare skipper is a Federal species of concern and the butterfly is considered significantly rare 

42 by the State. Although nonmigratory, the rare skipper is a strong flier that can fly over forests or 

43 fly up to 0.5 kilometer (0.3 mile) to find nectar. They inhabit marshes along tidal rivers. Adults 

44 are usually viewed while feeding on the nectar of roadside flowers. Threats to the rare skipper 

45 include habitat loss and, probably, biocides used to control mosquitoes. No occurrences of the 

46 rare skipper have been recorded within 3.2 kilometers (2 miles) of the Wilmington Site 

47 (NCNHP, 2009). 

48 
3-68 

1 Fishes

2 

3 American eel (Anguilla rostrata)

4 

5 The American eel is a Federal species of concern but has no State listing status. It spawns in 

6 the Sargasso Sea and matures in fresh or brackish waters (estuaries, rivers, streams, ponds, 

7 and lakes), spending 4 to 10 years in these habitats until they return to sea to spawn 

8 (FWS, 2009b). Upstream migration can occur from March through October, while downstream 

9 migration begins in summer or fall. Threats to the American eel include barriers to migration, 

10 habitat loss and alteration, turbine mortalities, overfishing, and pollution. No occurrences of the 

11 American eel have been recorded within 3.2 kilometers (2 miles) of the Wilmington Site 

12 (NCNHP, 2009). However, the American eel is expected to occur in the Northeast Cape Fear 

13 River near the Wilmington Site (NCDENR, 2008c). The river’s tributaries on the site could also 

14 provide suitable habitat for the American eel. 

15 

16 Shortnose sturgeon (Acipenser brevirostrum)

17 

18 The shortnose sturgeon is both Federally and State-listed as endangered. Federal protection of 

19 the species is under the jurisdiction of the NMFS. The shortnose sturgeon inhabits the lower 

20 reaches of large rivers and Atlantic coastal waters. It primarily occurs in brackish and salt 

21 waters of lower coastal river reaches and river estuaries. Shortnose sturgeon seldom venture 

22 into the Atlantic Ocean (Ozier et al., 1999). The shortnose sturgeon ascends into the 

23 freshwaters of larger coastal rivers to spawn. Spawning occurs from April through June in swift 

24 waters over gravel or coarse substrates such as submerged logs (NCNHP, 2001; 

25 Ozier et al., 1999). Juveniles may remain in rivers for up to 5 years before migrating to 

26 estuarine waters (NCNHP, 2001). Larvae and juveniles may prefer deep river channels. The 

27 shortnose sturgeon feeds upon invertebrates and aquatic plants (FWS, 2003a). It is very rare in 

28 the Cape Fear River drainage. The absence of juvenile shortnose sturgeon within the Cape 

29 Fear River drainage indicates that the species may not be spawning because of blockage of 

30 upstream migration by adults at Lock and Dam 1 at River Mile 60 (river kilometer 96). In other 

31 river systems, spawning takes place 100 to 300 kilometers (62 to 186 miles) upstream of the 

32 mouth of the river (Moser and Ross, 1995). Threats to the shortnose sturgeon include habitat 

33 alteration, barriers to upstream movement, pollution, and overfishing (including poaching) 

34 (NCNHP, 2001). They are also susceptible to gill nets set for striped bass and American shad 

35 (Moser and Ross, 1995). There is a 1993 occurrence record for the shortnose sturgeon within 

36 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). It may occur in the Northeast 

37 Cape Fear River and the lower portions of its unnamed tributaries that occur on the Wilmington 

38 Site. It does not ascend into smaller tributaries such as the Prince George Creek 

39 (NOAA, 2002).

40 

41 Amphibians

42 

43 Carolina gopher frog (Rana capito capito)

44 

45 The Carolina gopher frog is a Federal species of concern and is listed as threatened by the 

46 State. Adults inhabit primarily xeric uplands, especially longleaf pine-turkey oak sandhill 

47 associations. They also occur in xeric to mesic longleaf pine flatwoods, sand pine scrub, and 

48 xeric oak hammocks. Burrows of gopher tortoises (Gopherus polyphemus) and rodents are 
3-69 

1 used for shelter. They will also hide in sewers, under logs, and in or under stumps. Breeding 

2 habitat includes ephemeral to semipermanent graminoid (grass or grass-like) dominated 

3 wetlands that lack large predatory fishes. Breeding generally occurs between mid-January and 

4 April. The larval period lasts about four months; individual adults spend less than four weeks in 

5 breeding ponds. Threats to Carolina gopher frogs include habitat loss and degradation caused 

6 by logging and fire suppression, introduction of predatory fishes into breeding ponds, and 

7 declines in gopher tortoises. No occurrences of the Carolina gopher frog have been recorded 

8 within 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). 

9 

10 Reptiles

11 

12 American alligator (Alligator mississippiensis)

13 

14 The American alligator is Federally listed as threatened because its appearance is similar to the 

15 American crocodile (Crocodylus acutus); it is State listed as threatened. From a Federal 

16 perspective, the American alligator is not biologically threatened and does not have protection 

17 under the ESA (FWS, 2009a). It inhabits slow-moving coastal rivers, canals, lakes, 

18 impoundments, marshes, cypress ponds, and estuaries. Its tolerance to salinity increases with 

19 age (NCNHP, 2001). The minimum home range averages 1255 hectares (3100 acres) for 

20 males and 8 hectares (21 acres) for females (NCNHP, 2001). Past threats to the American 

21 alligator included overharvest and habitat loss (FWS, 2008c). Current threats include loss and 

22 degradation of habitat due to recreational use and development. The American alligator has 

23 been recorded from various localities near the Wilmington Site, including the Prince George 

24 Creek at its confluence with its Unnamed Tributary #1; the Northeast Cape Fear River at its 

25 confluence with Prince George Creek upstream of the Wilmington Site in Turkey Creek, Morgan 

26 Creek, and Long Creek; and south of the Wilmington Site in Ness Creek (GLE, 2008). 

27 Occurrences of the American alligator have been reported within 3.2 kilometers (2 miles) of the 

28 proposed GLE Facility area (NCNHP, 2009). At the Wilmington Site, potential breeding habitat 

29 occurs along the Northeast Cape Fear River and its tributaries, and small alligators may occur 

30 within the streams and swamp forest habitats of the site. 

31 

32 Mimic glass lizard (Ophisaurus mimicus)

33 

34 The mimic glass lizard, a legless lizard, is a Federal and a State species of concern. It inhabits 

35 longleaf pine savannas and conifer and mixed woodlands where it burrows in the soil or inhabits 

36 fallen logs and woody debris. Threats to the mimic glass lizard include habitat loss, conversion 

37 of preferred habitat to pine plantations, and road mortality. No occurrences of the mimic glass 

38 lizard have been reported within 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). 

39 

40 Northern pinesnake (Pituophis melanoleucus melanoleucus)

41 

42 The northern pinesnake is a Federal and a State species of concern. It inhabits xeric pine forest 

43 uplands. Threats to the northern pinesnake include logging, habitat modification and 

44 fragmentation, and direct mortality by humans (e.g., deliberate killing and road mortality). A pre45 1927 occurrence record exists for the northern pine snake within 3.2 kilometers (2 miles) of the 

46 proposed GLE Facility area (NCNHP, 2009).

47 
3-70 

1 Southern hog-nosed snake (Heterodon simus)

2 

3 The southern hog-nosed snake is a Federal and a State species of concern. It inhabits mature 

4 pine forests and sandhill habitats (Jordan, 1998) and spends most of its time buried in soil. It 

5 primarily eats toads, but also preys on frogs, lizards, and small mammals. Habitat loss is the 

6 primary threat to the southern hog-nosed snake (Jordan, 1998). Sightings of the southern hog7 nosed snake have been made southwest of the Wilmington Site between the Northeast Cape 

8 Fear River and the Cape Fear River (GLE, 2008). No occurrences of the southern hog-nosed 

9 snake have been recorded within 3.2 kilometers (2 miles) of the Wilmington Site 

10 (NCNHP, 2009). Within the Wilmington Site, the snake could occur within the pine forests, 

11 longleaf pine/scrub forests, hardwood forests, and fields. The xeric, sandy soils in the 

12 northwestern portion of the site may also be suitable habitat. 

13 

14 Birds

15 

16 Eastern painted bunting (Passerina ciris ciris)

17 

18 The eastern painted bunting is a Federal species of concern and is considered significantly rare 

19 by the State. Habitat includes partly opened areas with scattered trees and brush, riparian 

20 thickets and brush, weedy and shrubby areas, woodland edges, yards, and gardens. Salt 

21 marsh/forest edges are preferred over interior forests. Eggs are laid in March through July 

22 (mostly May through June) in bushes or vine tangles at heights of 1 to 2 meters (3 to 6 feet) or 

23 at greater heights in thick Spanish moss (Tillandsia usneoides) in trees. It winters in Mexico. 

24 The major threat to the eastern painted bunting is loss of breeding habitat. No occurrences of 

25 the eastern painted bunting have been recorded within 3.2 kilometers (2 miles) of the 

26 Wilmington Site (NCNHP, 2009). 

27 

28 Red-cockaded woodpecker (Picoides borealis)

29 

30 The red-cockaded woodpecker is both Federally and State-listed as endangered. No critical 

31 habitat has been designated for the species (FWS, 2008b). Coastal Plain longleaf pine forests 

32 maintained by frequent fires probably supported the highest population levels 

33 (Ozier et al., 1999). It requires open stands of mature pine (more than 60 years old) for nesting 

34 and roosting habitat. Nesting and roosting occur in cavities of live trees that range in age from 

35 63 to more than 300 years old for longleaf pine, or 62 to more than 200 years old for loblolly and 

36 other pines. An aggregate (cluster) of 1 to 20 cavity trees is used on an area of 1 to 24 hectares 

37 (3 to 60 acres) (FWS, 2003b; NatureServe, 2009). The red-cockaded woodpecker generally 

38 chooses trees that are infected with red heart disease, which is caused by a fungus (Phellinus

39 pini) that attacks the heartwood (the older, nonliving central wood of a tree), thereby making it 

40 softer and pithy, which aids in the bird being able to excavate the cavity. Suitable habitat 

41 surrounding a cluster of cavity trees contains open, park-like conditions. Often, the breeding 

42 pair and up to nine “helpers” (usually four or less) form a family unit called a group. The helpers 

43 assist in incubating the eggs, feeding nestlings and fledglings, and defending territories. Each 

44 member of a group usually has an exclusive roost cavity. Egg-laying generally occurs between 

45 April and early May. A group may not nest every year. Incubation lasts 10 to 12 days, and 

46 nestlings remain in the nest for nearly a month. 

47 
3-71 

1 The diet of red-cockaded woodpeckers primarily consists of invertebrates found on and within 

2 pine bark (Ozier et al., 1999). Stands of pine or mixed pines and hardwoods that are more than 

3 30 years old are used for foraging. A group requires at least 32 to 51 hectares (80 to 125 acres) 

4 of foraging habitat. The territory for a group averages about 81 hectares (200 acres) but can 

5 range from 24 to 243 hectares (60 to more than 600 acres) (FWS, 2003b). Most suitable 

6 nesting habitat in the southeastern United States occurs on public lands. Threats to the 

7 red-cockaded woodpecker include habitat loss and fragmentation, short-term timber rotation 

8 (e.g., <45 years), fire suppression (and subsequent encroachment of hardwood midstory trees 

9 that reach the heights of the cavity entrance), and competition for cavity space. When foraging 

10 habitat is cleared, groups may have difficulty raising young. Juveniles dispersing from isolated 

11 clusters of cavity trees seldom encounter suitable habitat, and much less other individuals. 

12 Once a breeding female dies, it is highly unlikely that a replacement will immigrate to the group 

13 (Ozier et al., 1999). 

14 

15 An active red-cockaded woodpecker group occurs within 8 kilometers (5 miles) northeast of the 

16 Wilmington Site. It is located just north of the Northeast Cape Fear River along NC 117 in 

17 Pender County (GLE, 2008). Several occurrences of the red-cockaded woodpecker have been 

18 recorded within 3.2 kilometers (2 miles) of the western border of the Wilmington Site 

19 (NCNHP, 2009). No cavity trees were observed on the Wilmington Site during field surveys 

20 conducted in support of the Environmental Report (GLE, 2008). The forested habitats on the 

21 Wilmington Site meet the minimum area requirements needed for foraging habitat. However, 

22 the lack of mature forests would limit the value of the Wilmington Site as foraging habitat. Only 

23 the longleaf pine/scrub plant community located in the northwest corner of the Wilmington Site 

24 is estimated to be over 40 years of age (Figures 3-11 and 3-12). Thinning of forested areas has 

25 increased habitat potentially suitable for the red-cockaded woodpecker on the Wilmington Site 

26 (GLE, 2009c). The Sledge Forest, a property containing more than 1619 hectares (4000 acres) 

27 of high-quality forest directly adjacent to and north of the Wilmington Site, does contain loblolly 

28 and longleaf pine trees that are more than 300 years old. This area would be suitable as 

29 nesting and roosting habitat for the red-cockaded woodpecker. It is possible that woodpeckers 

30 that forage in the Sledge Forest could occasionally forage within the western forested portion of 

31 the Wilmington Site. 

32 

33 Mammals

34 

35 Rafinesque’s big-eared bat (Corynorhinus rafinesquii)

36 

37 The Rafinesque’s big-eared bat is a Federal and a State species of concern. The species 

38 occurs in forested areas. Summer roosts include hollow trees, loose bark, or abandoned 

39 buildings in or near wooded areas. Bridges are also used as day roosts and as maternity 

40 roosts. Foraging habitat is primarily among the canopies of mature upland and lowland forests 

41 (Ozier et al., 1999). While most bats become active before dark, the Rafinesque’s big-eared bat 

42 does not emerge from its roost until it is completely dark (Ozier et al., 1999). In the Coastal 

43 Plain, they are assumed to use hollow trees during cold weather and possibly as winter roosts. 

44 It roosts singly, in small clusters, or in groups of more than 100 individuals. During the nursing 

45 season, males are generally solitary. The species is considered nonmigratory, having only 

46 short-distance movements between summer and winter roosting sites. Threats to the species 

47 include habitat loss (e.g., forest destruction, removal of hollow trees, removal of abandoned 

48 buildings, and vandalism or destruction of mines and caves), insecticide applications, and 
3-72 

1 disturbance at roost sites. There is a pre-2006 occurrence record for the Rafinesque’s big2 eared bat within 3.2 kilometers (2 miles) of the proposed GLE Facility area (NCNHP, 2009). 

3 

4 Southeastern myotis (Myotis austroriparius)

5 

6 The southeastern myotis bat is a Federal and a State species of concern. It nests in caves, 

7 buildings, and snags and hollow trees of pine and hardwood forests; and it primarily forages in 

8 riparian areas, but also in various upland habitats. Threats to the southeastern myotis include 

9 human disturbance and physical alteration of caves used for hibernacula and maternity sites. 

10 Clearing and draining of bottomland hardwood forest wetlands also have reduced summer 

11 roosting and foraging habitat. There is a 1986 occurrence record for the southeastern myotis 

12 within 3.2 kilometers (2 miles) of the proposed GLE Facility area from floodplains north of the 

13 Wilmington Site near the confluence of the Northeast Cape Fear River and Prince George 

14 Creek (NCNHP, 2009; GLE, 2008). The riparian habitats and pine and hardwood forests on the 

15 Wilmington Site provide suitable foraging and breeding habitat for the southeastern myotis. It 

16 may also forage in the Operations Area and transmission line ROWs. 

17 

18 West Indian manatee (Trichechus manatus)

19 

20 The West Indian manatee is both Federally and State-listed as endangered. It inhabits shallow 

21 coastal bays, lagoons, estuaries, and rivers. The manatee usually inhabits waters with a depth 

22 of 1 to 6 meters (3.3 to 20 feet) (FWS, 2009a; NatureServe, 2009). Much of their time is spent 

23 submerged or partly submerged. Manatees feed on aquatic vegetation. It is a seasonal 

24 inhabitant of North Carolina, being present mainly from June through October. They migrate 

25 south (e.g., to Florida) when water temperatures fall below about 21° Celsius (70° Fahrenheit). 

26 Manatees often return to the same winter and summer habitats every year (Ozier et al., 1999). 

27 Threats to the West Indian manatee include collisions with boats, habitat loss and degradation, 

28 entrapment and/or crushing in water control structures, entanglement in fishing gear, hunting 

29 and fishing, red tide poisoning, and exposure to cold temperatures. No occurrences of the West 

30 Indian manatee have been recorded within 3.2 kilometers (2 miles) of the Wilmington Site 

31 (NCNHP, 2009). However, the Northeast Cape Fear River and some of its tributaries in the 

32 area of the Wilmington Site may provide suitable habitat for the manatee (FWS, 2009a). 

33 

34 3.8.6.2 State-Listed Species 

35 

36 In addition to the Federally threatened or endangered species and Federal species of concern 

37 identified in Table 3-14, there are additional State-rare species that are known to occur within 

38 New Hanover County (Buchanan and Finnegan, 2008; LeGrand et al., 2008). These are 

identified in Table 3-15.15 39 Some of these species may occur on or near the Wilmington Site. 

40 Continued declines in some of these species could be expected in the future, which may lead to 

41 their becoming upgraded to State threatened or endangered or possibly as Federally listed 

42 species. 

43 

 

15 County distributions for “watch list” animal species were not provided by LeGrand et al., 2008; 

therefore, these species are not included in Table 3-15. The State status of the Federally threatened 

or endangered species and Federal species of concern is provided in Table 3-15. These species are 

also discussed in Section 3.8.6.1. 
3-73 

1 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa

Scientific Name Common Name State Statusb Habitat 

Lichens Cladonia evansii Powder-puff lichen W Sandhills (primarily near the coast), usually 

associated with sand live oak. 

Liverworts Cephalozia connivens var. 

bifida

A liverwort SR-T* Moist riverbanks. 

Metzgeria uncigera A liverwort W* On bark in maritime forests or on rhododendron i

mountain forests. 

Mosses Fissidens elegans A plume moss W* Sandy and clayey soils along roadsides and 

streams, on trees or stumps. 

Weissia muehlenbergiana A moss W* Soil among grasses, roadsides. Vascular Plants Adiatium capillus-veneris Venus hair fern E Coquina limestone (marl) outcrops, adventitious o

mortar of old stone walls. 

Agalinis aphylla Scale-leaf gerardia W* Wet savannas and sandhills streambed pocosin 

ecotones. 

Agalinis linifolia Flaxleaf gerardia W Savannas, clay-based carolina bays, depression 

ponds, and other open habitats. 

Agalinis virgata Branched gerardia SR-P Savannas and depression pond shores. Anthaenantia rufa Purple silkyscale W* Savannas. Aristida condensata Big three-awn grass SR-P Bay rims with xeric pine-oak scrub. 
3-74 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Asclepias pedicellata Savanna milkweed SR-P Dry savannas and moist flatwoods. Baccharis angustifolia Saltwater false-willow W Brackish marshes, sandhill seeps, and other ope

wet areas. 

Bacopa caroliniana Blue water-hyssop SR-P* Shallow ponds, marshes, natural lakes, and tidal 

creeks. 

Bacopa innominata Tropical water-hyssop SR-P* Tidal freshwater marshes. Bartonia paniculata ssp. 

paniculata

Twining screwstem W Wet savannas, sandhill seeps, and other open w

areas. 

Boltonia asteroides White doll’s-daisy SR-O Clay-based Carolina bays, marshes, and savannBurmannia biflora Northern bluethreads W Limesinks, cypress savannas, and sandhill seepsCalamovifa brevipilis Pinebarren sandreed W Savannas and sandhill seeps. Cardamine longi Long’s bittercress SR-T Tidal marshes and tidal cypress-gum forests. Carex chapmanii Chapman’s sedge W* Moist bottomlands and slopes, perhaps associate

with marl. 

Carex mitchelliana Mitchell’s sedge W Swampy woodlands and forests. Carex decomposita Cypress knee sedge SR-T* Beaver ponds and old millponds. Carex vericosa Warty sedge SR-P* Savannas and pinelands. Cirsium lecontei Le Conte’s thistle SR-P* Savannas. Cladium mariscoides Twig-rush SR-O Bogs, fens, brackish marshes, and sandhill seepa

bogs. 

Chrysopogon pauciflorus Goldenbeard W* Sandhills. 
3-75 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Chrysopsis trichophylla Naked golden-aster W Xeric sandhills and sandhill scrub. Cleistes bifaria Small spreading pogonia W Savannas, dry meadows. Coelorachis rugosa Wrinkled jointgrass W Limesink ponds, clay-based Carolina bays, and w

savannas. 

Corallorhiza odontorhiza Autumn coral-root W* Harwood forests. Corallorhiza visteriana Spring coral-root SR-O Nutrient-rich forests, especially over limestone, 

mafic rocks, or shell-rich sands. 

Crinum americanum Swamp-lily SR-P* Tidal swamp forests and tidal marshes. Crocanthemum carolinianum Carolina sunrose SR-P Sandhills, pinelands, and dry savannas. Crocanthemum georgianum Georgia sunrose SR-P Maritime forests. Crocanthemum nashii Florida scrub frostweed E Coastal fringe sandhill. Cyperus distans A flatsedge W* Marshes. Cyperus lecontei Leconte’s flatsedge SR-P* Limesink ponds. Cyperus tetragonus Four-angled flatsedge SR-P+ Maritime forests and barrier island grasslands. Dicanthelium aciculare spp. neuranthum

Nerved witch grass SR-D Maritime wet grasslands. 

Dicanthelium sp. 9 A witch grass SR-L* Wet streamhead pocosin openings, including utili

clearings. 

Dichanthelium erectifolium Erectleaf witch grass W Pond shores. Dryopteris ludoviciana Southern woodfern W* Acid swamps. Eleocharis equisetoides Horsetail spikerush W* Limesink ponds. 
3-76 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Eleocharis melanocarpa Blackfruit spikerush W Clay-based Carolina ponds. Eleocharis robbinsii Robbins’ spikerush SR-P Limesink ponds, clay-based Carolina bays, peatburn lakes, millponds, beaver ponds, and artificia

lakes. 

Eleocharis tricostata Three-angle spikerush W Bogs and savannas. Epidendrum magnoliae Green fly orchid SR-P Epiphytic on trees in blackwater river swamps. Erythrina herbacea Coralbean SR-P Maritime forests. Eupatorium leptophyllum Limesink dog-fennel SR-P Limesink ponds and clay-based Carolina bays. Gaylussacia nana Confederate huckleberry E Coastal fringe sandhill. Gelsemium rankinii Swamp jessamine SR-P Floodplains of blackwater rivers and streams. Habenaria repens Water-spider orchid W* Stagnant blackwater pools and impoundments. Helenium pinnatifidum Dissected sneezeweed SR-P* Savannas and open, wet, and mucky sites. Hibiscus aculeatus Comfortroot SR-P Bay forests, sand ridges, and roadsides. Hypericum fasciculatum Peelbark St. John’s-wort SR-L* Beaver ponds, low pinelands, and pools. Ilex cassine var. cassine Dahoon W Blackwater swamps and pocosins. Iresine rhizomatosa Rootstock bloodleaf W Low, wet places, interdune swales, damp woods, 

edges of brackish marshes. 

Lachnocaulon minus Brown bogbutton SR-P Depression ponds and ditches. Liatris secunda Sandhill blazing-star W Sandhills. Lilaeopsis carolinensis Carolina grasswort T Freshwater marshes, pools, and tidal marshes. Lophiola aurea Golden-crest E Very wet, mucky habitats in pine savannas. 
3-77 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Ludwigia alata Winged seedbox SR-P* Interdune ponds and marshes. Ludwigia lanceolata Lanceleaf seedbox SR-P Interdune ponds and open wet areas. Ludwigia linifolia Flaxleaf seedbox SR-P Limestone ponds. Ludwigia sphaerocarpa Globe-fruit seedbox SR-P Bogs, pools, and lake shores. Ludwigia suffruticosa Shrubby seedbox SR-P Limesink ponds and clay-based Carolina bays. Magnolia grandiflora Southern magnolia W* Mainland forests with maritime influence. Nuphar sagittifolia Narrowleaf cowlily W Blackwater streams, rivers, and lakes. Oenothera riparia Riverbank eveningprimrose SR-L Tidal marshes. Panicum tenerum Southeastern panic 

grass 

W Wet savannas, sandhill seeps, and limesink pond

Parietaria floridana Florida pellitory W* Shell middens, disturbed sites, and maritime forePaspalum praecox Early crown grass W Limesink ponds and savannas. Parietaria praetermissa Large-seed pellitory SR-P* Shell middens, disturbed sites, and maritime forePeltandra sagittifolia Spoonflower SR-P Pocosins and other wet, peaty sites. Persea borbonia Red bay W Sandy upland soils in maritime forests. Physalis lanceolata Sandhill ground cherry W* Sandhills. Phytolacca rigida Maritime pokeweed W Dunes, edges of brackish or salt marshes. Platanthera nivea Snowy orchid E Wet savannas. Polygala hookeri Hooker’s milkwort SR-D Savannas. 
3-78 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Polygonum glaucum Seabeach knotwood SR-T* Ocean and sound beaches. Ptelea trifoliata Wafer-ash W* Rich woods, cliffs, and rock exposures mainly ov

mafic or calcareous rocks. 

Ptilimnium costatum Ribbed bishop-weed SR-P Tidal swamps or marshes. Rhexia cubensis West Indies meadowbeauty W Limesink ponds. Rhynchospora careyana Carey’s beaksedge W Limesink ponds, and clay-based Carolina bays. Rhynchospora inundata Narrowfruit beaksedge W Limesink ponds, and clay-based Carolina bays. Rhynchospora pallida Pale beaksedge W Savannas, sandhill seeps, and pocosins. Rhynchospora scirpoides Long-beak baldsedge W Beaver ponds, limesink ponds, and wet savannasRhynchospora tracyi Tracy’s beaksedge SR-P Clay-based carolina bays, and limesink ponds. Sabatia dodecandra Large marsh pink W* Tidal, brackish, and freshwater marshes. Sagittaria isoetiformis Quillwort arrowhead SR-P Limesink ponds, clay-based Carolina bays, beave

ponds, and natural lakes. 

Salvia azurea Azure sage SR-P* Sandhills. Schizachyrium littorale Seaside little bluestem W Coastal dunes and maritime dry grasslands. Schoenoplectus americanus Olney threesquare W Tidal marshes. Schoenoplectus californicus California bulrush W* Tidal marshes. Scleria georgiana Georgia nutrush W Savannas. Scleria reticularis Netted nutrush SR-O Clay-based carolina bays and limesink ponds. Sesuvium portulacastrum Shoreline sea-purslane SR-P Ocean beaches. 
3-79 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Sideroxylon lycioides Buckthorn bumelia W Maritime forests, bluffs, or forests over calcareou

mafic rocks. 

Solidago tortifolia Twisted-leaf goldenrod SR-P* Dry savannas and mesic flats. Spiranthes laciniata Lace-lip ladies’-tresses SR-P Moist wet habitats. Symphyotrichum elliottii Elliot’s aster W* Freshwater or brackish marshes. Syngonanthus flavidulus Yellow hatpins W* Ditches, pocosin ecotones, and savannas. Trifolium carolinianum Carolina clover SR-O* Savannas and sandy open areas. Typha domingensis Southern cattail W* Brackish marshes. Utricularia cornuta Horned bladderwort SR-P* Bogs and limestone ponds. Utricularia olicacea Dwarf bladderwort T Limesink ponds and beaver ponds. Verbena scabra Sandpaper vervain W* Marsh edges and shell middens. Vigna luteola Wild cowpea W* Marsh edges and wet open areas. Viola villosa Carolina violet W* Moist places, especially pocosin edges. Xyris smalliana Small’s yellow-eyedgrass W Pineland pools, limesink ponds, and shores. Yucca aloifolia Aloe yucca W Dunes. Yucca gloriosa Moundlily yucca SR-P Dunes. Zizania aquatica Wild rice W Freshwater marshes. Invertebrates Amblyscirtes alternata Dusky roadside-skipper SR+ Open pine woods and savannas. 
3-80 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Anodonta couperiana Barrel floater E* Ponds or slow-flowing streams in soft substrates. Calephelis virginiensis Little metalmark SR Savannas and pine flatwoods. Catocala amestris Three-staff underwing SR Sand ridges and flatwoods with leadplant. Catocala jair Jair underwing SR Xeric pine-oak sandhills. Catocala marmorata Marbled underwing SR Swamp forests with swamp cottonwood. Catocala messalina Messalina underwing SR Maritime forests and mesic sandhills. Cerma cora A bird-dropping moth SR Levee forests with hawthorn. Chaetaglaea fergusoni A noctuid moth SR Sandhills. Cyclophora sp. 1 (culicaria) Sand-myrtle geometer SR Flatwoods with sand-myrtle. Datana ranaeceps A hand-maid moth SR Recently burned flatwoods and sandhills. Doryodes sp. 1 A noctuid moth SR Savannas, flatwoods, and sandhills. Drasteria graphica Graphic moth SR Maritime shrub thickets. Elliptio marsupiobesa Cape Fear spike SC Low-gradient creeks in variable substrates. Eupithecia peckorum An inchworm moth SR Sandhills and flatwoods. Heterocampa varia A prominent moth SR Xeric pine-oak sandhills. Lithophane laceyi A pinion moth SR Swamp forests. Lynceus gracilicornis Graceful clam shrimp SC Temporary ponds, pools, and ditches. Metarranthis sp. 1 An new inchworm moth SR Pocosins. Papilio cresphontes Giant swallowtail SR Primarily coastal in maritime forests or thickets. Procambarus plumimanus Croatan crayfish SR Rivers, ponds, ditches, and borrow pits. 
3-81 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Ptichodis bistrigata Southern ptichodis SR Xeric sandhills. Satyrium favonius favonius Southern oak hairstreak SR Maritime forests along the southern coast. Schizura apicalis Plain schizura SR Dry woodlands or scrub. Trichosilia manifesta An owlet moth SR Xeric oak woodlands. Zale declarans An owlet moth SR Maritime forests with live oak. Fishes Fundulus luciae Spotfin killifish SR Ponds and pools along the coast. Heterandria formosa Least killifish SC Streams and lakes near Wilmington. Amphibians Ambystoma mabeei Mabee’s salamander SR* Savannas, wet woods, and swamps. Pseudacris ornata Ornate chorus frog SR* Swamps, savannas, and wooded ponds and pooReptiles Crotalus adamanteus Eastern diamondback 

rattlesnake 

E Pine flatwoods, savannas, and pine-oak sandhills

Deirochelys reticularia Chicken turtle SR Quiet waters of ponds, ditches, and sluggish 

streams. 

Malaclemys terrapin

centrata

Carolina diamondback terrapin 

SC Salt or brackish marshes, estuaries. 

Masticophis flagellum Coachwhip SR Dry and sandy woods, mainly in pine/oak sandhilMicrurus fulvius Eastern coral snake E Pine-oak sandhills, sandy flatwoods, and maritim

forests. 
3-82 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Regina rigida Glossy crayfish snake SR* Marshes, cypress ponds, and other wetlands. Seminatrix pygaea Black swamp snake SR Lush vegetation of ponds, ditches, or sluggish 

streams. 

Sistrurus miliarius Pigmy rattlesnake SC Pine flatwoods, pine/oak sandhills, other pine/oak 

forests. 

Birds Charadrius wilsonia Wilson’s plover SC Beaches, island-end flats, and estuarine islands. Columbina passerina Common ground-dove SR Dunes, sandy fields, and margins of marine wood

and thickets. 

Egretta aerulea Little blue heron SC Forests or thickets on maritime islands. Egretta tricolor Tricolored heron SC Forests or thickets on maritime islands. Haematopus palliatus American oystercatcher SC Estuaries, oyster beds, and mudflats. Ixobrychus exilis Least bittern SC Fresh or brackish marshes. Lanius ludovicianus Loggerhead shrike SC Fields and pastures. Laterallus jamaicensis Black rail SC Brackish marshes, rarely freshwater marshes. Pelecanus occidentalis Brown pelican SR Maritime islands. Plegadis falcinellus Glossy ibis SC Forests or thickets on maritime islands. Rynchops niger Black skimmer SC Sand flats on maritime islands. Sterna hirundo Common tern SC Sand flats on maritime islands. Sternula antillarum Least tern SC Beaches, sand flats, and open dunes. 
3-83 

Table 3-15 State Rare Species Reported from New Hanover County, North Carolinaa (Co

Scientific Name Common Name State Statusb Habitat 

Mammals Condylura cristata pop. 1 Star-nosed mole – 

coastal plain population 

SC* Moist meadows, bogs, swamps, and bottomlands

Lasiurus intermedius Northern yellow bat SC Roosts in Spanish moss and other thick vegetatio

near water, often in longleaf pine habitats. 

Neotoma floridana floridana Eastern woodrat – 

coastal plain population 

T Forests, mainly in moist areas. 

Sciurus niger Eastern fox squirrel SR-G Open forests, mainly longleaf pine/scrub oak. a Excludes endangered, threatened, and special concern species previously listed in Table 3-14. b E = endangered; G = game animal that by law cannot be listed for State protection as endangered, threatened, or special conce

concern; SR = significantly rare; SR-D = significantly rare – disjunct; SR-L = significantly rare – limited; SR-O = significantly rare – 

SR-P = significantly rare – peripheral; SR-T = significantly rare – throughout; T = threatened; W = watch list; * = recorded occurreextirpated, have not been found in recent surveys, or have not been surveyed recently enough to be confident that it is still presen

obscure or undatable. 

c WS = Wilmington Site, GLEF = proposed GLE Facility site. d † = there is an occurrence record for the species within 3.2 kilometers (2 miles) of the Wilmington Site. 

Sources: Buchanan and Finnegan, 2008; LeGrand et al., 2008; NCNHP, 2009. 
3-84 

1 The following definitions are applicable for the State listed species (Buchanan and 

2 Finnegan, 2008; LeGrand et al., 2008): 

3 

4 • Endangered plant: any species or higher taxon of plant whose continued existence as a 

5 viable component of the State’s flora is determined to be in jeopardy. Endangered plants 

6 may not be removed from the wild except when a permit is obtained for research, 

7 propagation, or rescue that will enhance the survival of the species. 

8 

9 • Endangered animal: any native or once-native species of wild animal whose continued 

10 existence as a viable component of the State’s fauna is determined by the North Carolina 

11 Wildlife Resource Commission to be in jeopardy or any species of wild animal determined to 

12 be an “endangered species” pursuant to the ESA. 

13 

14 • Threatened plant: any resident species of plant that is likely to become an endangered 

15 species within the foreseeable future throughout all or a significant portion of its range. 

16 Threatened plants may not be removed from the wild except when a permit is obtained for 

17 research, propagation, or rescue that will enhance the survival of the species. 

18 

19 • Threatened animal: any native or once-native species of wild animal that is likely to become 

20 an endangered species within the foreseeable future throughout all or a significant portion of 

21 its range, or one that is designated as a threatened species pursuant to the ESA. 

22 

23 • Special concern plant: any species of plant that requires monitoring but which may be 

24 collected and sold under regulations adopted under the provisions of the Plant Protection 

25 and Conservation Act. 

26 

27 • Special concern animal: any native or once-native species of wild animal that is determined 

28 by the Wildlife Resources Commission to require monitoring but which may be taken under 

29 regulation. 

30 

31 • Significantly rare plant: any plant species not listed by the North Carolina Plant Conservation 

32 Program as endangered, threatened, or special concern species, which is rare in 

33 North Carolina, generally with 1 to 100 populations in the State, frequently substantially 

34 reduced in numbers by habitat destruction (and sometimes also by direct exploitation or 

35 disease). 

36 

37 • Significantly rare animal: any wild animal species not listed by the North Carolina Wildlife 

38 Resources Commission as an endangered, threatened, or special concern species, but 

39 which exists in the State in small numbers and has been determined by the North Carolina 

40 Natural Heritage Program to need monitoring. 

41 

42 • Watch list: any plant or animal species believed to be rare and of conservation concern in 

43 the State but not warranting active monitoring at this time. 

44 

45 Qualifying categories are also applied to some of the species that are considered significantly 

46 rare, as follows: disjunct – the species in North Carolina is separated from its main range in a 

47 different part of the country or world; limited – the range of the species is limited to North 

48 Carolina and adjacent states and the species may have only 20 to 50 populations in North 
3-85 

1 Carolina, but fewer than 100 populations rangewide; other – the range is sporadic or cannot be 

2 described by other significantly rare categories; peripheral – the species is at the periphery, or 

3 edge, of its range in North Carolina; and throughout – the species is rare throughout its entire 

4 range (i.e., fewer than 100 populations in total) 

5 

6 3.9 Noise 

7 

8 Any pressure variation that the human ear can detect is considered sound; noise is unwanted 

9 sound. Sound is described in terms of amplitude (perceived as loudness) and frequency 

10 (perceived as pitch). Sound pressure levels are typically measured on a logarithmic decibel 

11 (dB) scale. To account for human sensitivity to frequencies of sound (i.e., humans are less 

12 sensitive to lower and higher frequencies and most sensitive to sounds between 1 and 

13 5 kilohertz), A-weighting (denoted by dBA), which is correlated with a human’s subjective 

14 reaction to sound, is widely used (ASA, 1983; ASA, 1985). To account for variations of sound 

15 with time, the equivalent continuous sound level (Leq) is employed. Leq is the continuous sound 

16 level during a specific time period that would contain the same total energy as the actual time17 varying sound. For example, Leq (24) is the 24-hour equivalent continuous sound level. In 

18 addition, human responses to noise differ depending on the time of the day (e.g., there is more 

19 annoyance over noise during nighttime hours due to low background levels). The day-night 

20 average sound level (Ldn or DNL) provides an average of the level over a 24-hour period after 

21 the addition of 10 dB to noise during nighttime hours (from 10 p.m. to 7 a.m.) to account for the 

22 greater sensitivity of most people to it. Day-night average sound level is widely used for 

23 community noise and airport noise assessments. Generally, a 3-dB change is considered a just 

24 noticeable difference, and a 10-dB increase is subjectively perceived as a doubling in loudness 

25 and almost always causes an adverse community response. See the text box (next page) for 

26 the definition of noise-related technical terms and some simple rules governing sound levels. 

27 

28 The Noise Control Act of 1972, along with its subsequent amendments (Quiet Communities Act 

29 of 1978, 42 USC 4901 et seq.), delegates to the States the authority to regulate environmental 

30 noise and directs government agencies to comply with local community noise statutes and 

31 regulations. Many local noise ordinances are qualitative and prohibit excessive noise or noise 

32 that results in a public nuisance. Because of the subjective nature of such ordinances, they are 

33 often difficult to enforce. However, several States and counties have established quantitative 

34 noise level regulations, which typically specify environmental noise limits based on the land use 

35 of the property receiving the noise. 

36 

37 New Hanover County has established quantitative community noise limits set forth in 

38 Chapter 23, Environment, Article II, Noise, in the County Code of Ordinances (New Hanover 

39 County, 2009a), although the State of North Carolina has not. For nonresidentially zoned 

40 districts, any noise source should not produce noise levels exceeding 75 A-weighted decibels 

41 (dBA), combined with the ambient noise, during daytime hours, and no more than 70 dBA 

42 during nighttime hours. Residentially zoned districts have lower criteria of 65 dBA during the 

43 daytime and 50 dBA at night. If the ambient noise level already exceeds the criteria, a violation 

44 shall occur only when such sound exceeds the ambient noise level by 3 dBA. Noise 

45 measurements shall be made at the nearest corner of the primary structure or at the boundary 

46 of the public ROW that adjoins the property of interest. 
3-86 

Definition of Noise-Related Technical Terms 

Decibel (dB) A unit describing the amplitude of sound, equal to 20 times the 

logarithm to the base 10 of the ratio of the pressure of the sound 

measured to the reference pressure (typically 20 micropascals per 

square meter which is the lowest pressure level audible to humans), 

that is, 20 • log10(P/Pref). 

Frequency (Hz) The number of complete pressure fluctuations per second above and 

below atmospheric pressure. The normal hearing of a young healthy 

person ranges from 20 to 20,000 Hz. 

A-weighted sound level 

(dBA) 

The most common frequency weighting on a sound level meter in a 

manner similar to the frequency response of the human ear, that is, 

low sensitivity to the very low and high frequencies and high sensitivity 

to middle frequencies; correlates well with subjective reactions to 

noise. 

Equivalent continuous 

sound level (Leq) 

The sound level (in dBA) that, had it been a steady level during the 

measurement period, would represent the amount of energy present in 

the measured, fluctuating sound pressure level. 

Day-night average 

sound level (Ldn or DNL) 

The sound level (in dBA) over a 24-hour period that accounts for 

human sensitivity to noise during nighttime hours (10 p.m. to 7 a.m.) 

due to relatively low background noise. The 10-dB penalty, which 

means 10 times more sound energy (e.g., noise from one car at night 

corresponds to a combined noise from 10 cars during the day), is 

added to the sound level measured during nighttime hours to estimate 

the DNL. 

Loudness Subjective magnitude of sound. As a rule of thumb, an increase of 

10 dB is perceived to be approximately twice as loud. For example, 

65 dB is perceived as being twice as loud as 55 dB. 

Sound-Related Rules of Thumb 

• Sound pressure level decreases at a rate of 6 dB and 3 dB per doubling of distance for point 

source (e.g., diesel generator at a fixed location) and line source (e.g., road traffic), 

respectively. For example, if the sound level of a point source is 60 dB at 15 meters 

(50 feet), then it is 54 dB at 30 meters (100 feet) and 48 dB at 60 meters (200 feet). If the 

sound level of a line source is 60 dB at 15 meters (50 feet), then it is 57 dB at 30 meters 

(100 feet) and 54 dB at 60 meters (200 feet). 

• The doubling of sound energy increases the sound level by 3 dB. For example, if one source 

produces 80 dB, then the combined noise levels would be 83 dB for two identical sources 

and 86 dB for four identical sources. 

• If the sound levels from two sources differ by 10 dB, the louder source will predominate. 

Accordingly, background noise level should be more than 10 dB below the sound level of a 

source being monitored to have confidence in the accuracy of the measurement. 
3-87 

1 The EPA identified noise levels requisite to protect public health and welfare against hearing 

2 loss, annoyance, and activity interference (EPA, 1974), as shown in Table 3-16. The EPA 

3 recommends a day-night average sound level of 55 dBA, which is sufficient to protect the public 

4 health and welfare in sensitive areas (e.g., residences, schools, and hospitals) from the effect of 

5 broadband environmental noise. These levels are not regulatory goals but are “intentionally 

6 conservative to protect the most sensitive portion of the American population” with “an additional 

7 margin of safety.” To ensure adequate protection for indoor living, a day-night average sound 

8 level of 45 dBA is recommended. For protection against hearing loss in the general population 

9 from nonimpulsive noise, the EPA guideline recommends a 24-hour equivalent sound level of 

10 70 dBA or less over a 40-year period. 

11 

12 The Department of Housing and Urban Development (HUD) has developed regulations that are 

13 related to the overall community noise level. These regulations would only affect their own 

14 programs and are not binding on local communities; that is, HUD has no regulatory authority 

15 over noise sources. HUD considers day-night average sound levels from 65 to 75 dBA as 

16 “normally unacceptable [for housing]” and DNL levels above 75 dBA as “unacceptable” 

17 (24 CFR 51.103). Levels below 65 dBA are considered “acceptable.” 

18 

19 The Wilmington Site, including the proposed GLE Facility, is surrounded by a mix of land uses. 

20 The nearest sensitive receptors, areas of human habitation or use where the intrusion of noise 

21 has the potential to adversely impact the occupancy, use, or enjoyment of the environment, are 

22 located just next to the northeast site boundary and about 1.2 kilometers (0.8 mile) directly to 

23 the east of the proposed facility (GLE, 2008). Other land uses adjacent to the site include a 

24 hunting/recreational area to the north, the Northeast Cape Fear River to the southwest, I-140 to 

25 the south, and NC 133 (Castle Hayne Road) to the east. Highway I-140, which is elevated 

26 relative to the site, acts as a natural sound barrier and blocks noises from current site 

27 operations to the residences to the south. Industrial land uses are dominant on the west side of 

28 the Cape Fear River. No other residences and sensitive receptors (e.g., schools, hospitals, and 

29 nursing homes) are located in the immediate vicinity (within about 1.6 kilometers [1 mile]) of the 

30 Wilmington Site. 

31 

Table 3-16 Summary of Noise Levels Identified as Requisite to Protect Public 

Health and Welfare with an Adequate Margin of Safety 

Effect Levela Area 

Hearing Leq(24) ≤ 70 dB All areas (at the ear). 

Ldn ≤ 55 dB Outdoors in residential areas and farms and other outdoor 

areas where people spend widely varying amounts of time 

and other places in which quiet is a basis for use. 

Outdoor activity 

interference and 

annoyance 

Leq(24) ≤ 55 dB Outdoor areas where people spend limited amounts of time, 

such as school yards, playgrounds, etc. 

Indoor activity Ldn ≤ 45 dB Indoor residential areas. 

interference and 

annoyance 

Leq(24) ≤ 45 dB Other indoor areas with human activities such as schools, etc. 

a

 Ldn = day-night average sound level; Leq(24) = 24-hour equivalent continuous sound level; dB = decibels. 

Source: EPA, 1974. 
3-88 

1 Per New Hanover County zoning code, the entire Wilmington property (including industrial 

2 facilities, forest areas, and open-space areas) is currently zoned I-2 Industrial District 

3 (New Hanover County, 2009b). This zone is intended for heavy industrial uses, which allows 

4 the highest noise levels. Similar to those of any other industrial facilities, noise emission 

5 sources within the Wilmington Site are associated with various activities, including heavy 

6 equipment, mechanical systems, vehicular traffic, and public address system (GLE, 2008). 

7 

8 Natural sounds were observed during the baseline sound survey, including birds and insect 

9 noise, and leaf-rustling noise by wind. In particular, insect noises peaked at 4 kilohertz; they are 

10 typically overwhelmed by other created noises during the daytime but are prominent at night. 

11 Medium-density wooded areas and soft grounds could provide some attenuation for noise from 

12 the Wilmington Site to propagate to the neighboring areas. Noise sources outside the site 

13 boundary include local vehicular traffic on NC 133 and I-140, distant vehicular traffic on I-40, 

14 aircraft overflights, yard maintenance activities in the residential community, and gunshots from 

15 the hunting/recreation area. 

16 

17 The baseline sound survey was conducted from October 30 to November 1, 2007, to 

18 characterize the existing acoustic conditions (GLE, 2008). As shown in Figure 3-15, 

19 measurements were made at four onsite locations: northeastern property line near the 

20 residences in the Eastern Site Sector (position A); proposed GLE Facility (currently a tree farm) 

21 in the North-Central Site Sector (position B); northern edge of the existing GNF-A facility in the 

22 Eastern Site Sector (position C); and existing northern entrance roadway in the Eastern Site 

23 Sector (position D). Noise levels at the northern property line near the residences 

24 representative of community noise level (position A) ranged from 41 dBA (night) to 46 dBA (day) 

25 with a day-night average sound level of 48 dBA. These levels are well below the New Hanover 

26 County noise ordinance of 50 and 65 dBA, respectively, for residentially zoned districts and the 

27 EPA day-night average sound level guideline of 55 dBA. The noise levels at the proposed 

28 GLE Facility, which is currently wooded (position B), ranged from 40 dBA (night) to 48 dBA 

29 (day) with a day-night average sound level of 48 dBA. At the northern edge of the existing 

30 facility (position C), noise levels of 47 dBA (night) and 51 dBA (day) with a day-night average 

31 sound level of 54 dBA were recorded, which is characteristic of the noise levels from existing 

32 operations. The measurements at the northern entrance roadway (position D) were the highest 

33 among those at four measurement locations, ranging from 56 dBA (night) to 61 dBA (day) with a 

day-night average sound level of 63 dBA,16 34 which reflects existing traffic noise levels within the 

35 Wilmington Site. Comparisons of sound levels from field observations demonstrated that noise 

36 levels at the northeastern property line near the residences have little correlation with consistent 

37 noise levels from the existing facilities and the northern entrance roadways. This suggests that 

38 sound levels at the northern property line originate from activities in the surrounding community, 

39 rather than from activities at the existing Wilmington Site facilities. Noise measurements were 

40 conducted in mid-fall when some deciduous trees lose their leaves, which can otherwise 

41 attenuate sound propagation to some extent. Accordingly, noise levels during this survey are 

42 considered as median values over the year. To date, no noise complaints have been reported 

43 from neighboring communities due to noisier sources outside the Wilmington Site, for example, 

44 nearby roadways. 

45 

 

16 This location is inside the Wilmington Site, thus noise levels at this location are not subject to any 

noise guidelines or regulations. These noise levels are presented for informational purposes only. 
3-89 

Figure 3-15 Locations of Sound Measurements Conducted from October 30 to November 1

at the Wilmington Site (Modified from GLE, 2008; GLE, 2009c) 
3-90 

1 For the general area surrounding the proposed GLE Facility, the countywide day-night sound 

2 level based on population density for the New Hanover County was estimated to be 51 dBA, 

3 typical of “quiet suburban residential” areas (Miller, 2002; Eldred, 1982). 

4 

5 3.10 Transportation 

6 

7 The Wilmington, North Carolina, area is readily accessible by road, rail, air, and water. The 

8 road network includes an interstate highway and several major U.S. highways. Public 

9 transportation in the area includes fixed bus and shuttle routes as well as a trolley in downtown 

10 Wilmington. The area is home to a major deepwater seaport that is served by a rail network 

11 that handles the incoming and outgoing cargo. Commercial airline service is provided by a 

12 regional airport. 

13 

14 3.10.1 Roads and Highways 

15 

16 Wilmington serves as the eastern terminus of I-40 as shown in Figure 3-16. I-40 briefly runs 

17 northward upon leaving Wilmington, intersecting I-95, the major east coast north-south 

18 interstate, at a distance of about 160 kilometers (100 miles). Shortly thereafter, I-40 passes 

19 through Raleigh, North Carolina, and begins its westward trek to its western terminus near 

20 Los Angeles, California. Another major north-south transportation corridor through the area is 

21 U.S. Route 17 that runs along the North Carolina coast, linking North Carolina with Virginia and 

22 South Carolina. Other major roads in the area include I-140, U.S. 74, U.S. 76, U.S. 421, and 

23 NC 132. All routes are available for the transport of goods and materials. The State of 

24 North Carolina has not limited the transport of hazardous materials to specifically designated 

25 routes within its boundaries (see Transportation of Hazardous Materials; Designated, Preferred, 

26 and Restricted Routes, 65 FR 75771, 75802 [December 4, 2000]). 

27 

28 I-140, a four-lane interstate highway (two lanes in each direction), considered to be the 

29 Wilmington Outer Loop, is under construction (GLE, 2008). The northern portion has been 

30 completed and connects U.S. 421 in the west with I-40 and U.S. 17 in the east. The western 

31 section of I-140, which links U.S. 421 with U.S. 74-76, has been funded and is scheduled for 

32 construction in 2011, while the southern portion, which is intended to link U.S. 74-76 with 

33 U.S. 17, has not yet been funded. As shown in Figure 3-17, the completed portion of I-140 

34 passes directly south of the Wilmington Site and has an interchange with NC 133 (Castle Hayne 

35 Road). 

36 

37 Access to the Wilmington Site is gained from Castle Hayne Road immediately north of the 

38 I-140 interchange. Castle Hayne Road is a two-lane highway with an additional lane in each 

39 direction in the vicinity of the interchange with I-140 and the Wilmington Site. Table 3-17 

40 provides the annual average daily traffic (AADT) flow on major roads near the Wilmington Site 

41 entrances. The AADT refers to the average number of vehicles in all lanes in both directions 

42 passing a point on a given road during an average day in the year. The current site entrance 

43 serves approximately 2800 workers employed at the Wilmington Site (GLE, 2008). Peak traffic 

44 periods related to site access occur during shift changes, such as at 3:00 p.m., as noted during 

45 a site visit on July 24, 2007 (GLE, 2008). 

46 

47 A second entrance, located 0.04 kilometer (0.25 mile) north of the entrance at the intersection of 

48 Castle Hayne Road and I-140, is used for truck deliveries and shipments. About 
3-91 

Figure 3-16 Map of the Wilmington Region 
3-92 

Figure 3-17 Local Map of the Wilmington Area
3-93 

Table 3-17 Annual Average Daily Traffic (AADT) on Major Roads 

near the Wilmington Site 

Road General 

Direction Location AADT (Vehicles) 

South of Sonday Rd. 13,000 

North of McDougald 10,000 

North of I-140 near site entrance 12,000 

South of I-140 12,000 

North of Old Mill Rd. 14,000 

Castle Hayne Rd. North-South 

North of Kerr Ave. 17,000 

West of Castle Hayne Rd. 16,000 

East of Castle Hayne Rd., West of I-40 18,000 

I-140 East-West 

East of I-40 14,000 

I-40 North-South North of I-140 30,000 

South of I-140 27,000 

Source: NCDOT, 2006.

1 

2 1000 radioactive material shipments a year are made to and from the Wilmington Site 

3 (GLE, 2009a). Outbound radioactive material truck shipments enter I-140 from NC 133 on their 

4 way to I-40 and their interstate destinations. Similarly, inbound interstate shipments would take 

5 the reverse course, coming in through I-40 to I-140 and exiting at NC 133 near the Wilmington 

6 Site entrance. 

7 

8 Wave Transit, the operating name for the Cape Fear Public Transportation Authority, which 

9 provides services for the City of Wilmington and New Hanover County (Wave Transit, 2009), 

10 operates bus routes in the area around the Wilmington Site. The Castle Hayne route passes by 

11 the Wilmington Site entrance on Castle Hayne Road. Wave Transit also operates a trolley that 

12 serves the downtown Wilmington area and shuttle buses that serve the University of 

13 North Carolina – Wilmington campus approximately 3 kilometers (2 miles) west of downtown. 

14 

15 3.10.2 Rail Network 

16 

17 The CSX Corporation provides freight service to the Wilmington area with primary terminals at 

18 the Port of Wilmington and the U.S. Army Military Ocean Terminal at Sunny Point. Nearly all rail 

19 freight traffic to these two terminals is routed through Hamlet, 179 kilometers (111 miles) to the 

20 west (NCDOT, 2005). Currently, there is no passenger train service to Wilmington, but studies 

21 have been conducted to assess interest and feasibility (NCDOT, 2005). The Wilmington Site 

22 has no current plans for shipping by rail and no direct rail access, but it is within several miles of 

23 the freight terminal in Wilmington. 

24 
3-94 

1 3.10.3 Water 

2 

3 The Cape Fear River and the Intracoastal Waterway in and around Wilmington are maintained 

4 by the U.S. Army Corps of Engineers (USACE) to support commercial and recreational 

5 navigation. The southwestern portion of the Wilmington Site borders the Cape Fear River north 

6 of the city. 

7 

8 The Port of Wilmington is a major East Coast deepwater port near downtown. Direct rail access 

9 and easy access to I-40 are available for freight shipments. Approximately 3.6 million metric 

10 tons (4 million tons) of goods pass through the port annually in the form of containerized, bulk, 

11 and breakbulk cargoes. The top five imports in fiscal year 2006, in terms of tonnage, passing 

12 through the port were forest products, chemicals, cement, general merchandise, and coal 

13 (GLE, 2008). Wood pulp, forest products, general merchandise, food, and chemicals were the 

14 top five exports, in terms of tonnage, during the same period (GLE, 2008). 

15 

16 3.10.4 Air 

17 

18 The Wilmington International Airport provides regional passenger service to Charlotte, New 

19 York, Atlanta, and Philadelphia. The airport is serviced by two major domestic commercial 

20 airlines. International service is only provided by either corporate or personal aircraft. The 

21 nearest major airports are Raleigh-Durham International Airport (122 kilometers [145 miles] to 

22 the north-northwest) and Charlotte-Douglas International Airport (322 kilometers [200 miles] to 

23 the west-northwest). Several smaller municipal and private airports and heliports also serve the 

24 Wilmington area in New Hanover County (3), Brunswick County (7) and Pender County (4) 

25 (FAA, 2009). 

26 

27 3.11 Public and Occupational Health 

28 

29 As described in Sections 3.5 through 3.7, several different media in and around the Wilmington 

30 Site contain radionuclides and chemicals that are both naturally occurring and anthropogenic 

31 (i.e., resulting from human activity) from historical and current operations at the site. These 

32 media include soil, surface water, sediment, groundwater, and air. This section describes these 

33 radiological and chemical background and anthropogenic levels in terms of public and 

34 occupational exposure and health, as well as historical exposure levels for activities similar to 

35 the proposed action. It also summarizes the cancer incidence and death rates in the region, 

36 which were necessary to establish baseline information for the Chapter 4 analysis of impacts on 

37 public and worker health that may be due to the proposed action. 

38 

39 3.11.1 Background Radiological Exposure 

40 

41 Humans are exposed to ionizing radiation from many naturally occurring sources in the 

42 environment and created sources that include human enhancement of natural sources of 

43 radiation. The current sources of radiation at the proposed GLE site include natural background 

44 sources and created sources, including the GNF-A facility. Section 3.11.1.1 discusses the 

45 exposure from general background radiation that includes naturally occurring sources and 

46 created sources, excluding the exposure from GNF-A facility operations. Radiological 

47 exposures from the operation of the existing GNF-A facility are discussed in Section 3.11.1.2. 

48 
3-95 

1 3.11.1.1 General Background Radiation 

2 

3 Radioactivity from naturally occurring elements in the environment is present in soil, rocks, and 

4 living organisms. A major proportion of natural background radiation comes from naturally 

5 occurring airborne sources such as radon. The natural radiation sources contribute 

6 approximately 3.11 millisieverts per year (311 millirem per year) to the radiation dose that a 

7 member of the U.S. population receives annually. The majority of this exposure – 

8 approximately 2 millisieverts per year (200 millirem per year) – is from inhalation of naturally 

9 occurring radon gas from soil, rock, and water. The other sources of exposure include external 

10 exposure from terrestrial sources and natural radiation of cosmic origin and exposure from 

11 radionuclides that exist in the body. The radiation dose from natural sources of external gamma 

12 radiation in North Carolina is 1.2 millisieverts per year (120 millirem per year) (Kathren, 1984). 

13 

14 Created sources include computed tomography (CT scan) for medical purposes, nuclear 

15 medicine, interventional fluoroscopy for medical purposes, X-rays for medical purposes, 

16 consumer products, industrial, and occupational exposure. A person living in the United States 

17 received an average effective dose of about 6.2 millisieverts (620 millirem) in 2006 

18 (NCRP, 2009). Figure 3-18 shows the percentage contribution to the total dose from different 

19 sources. 

20 

21 3.11.1.2 Radiological Exposure from GNF-A Operations 

22 

23 The existing facilities on the Wilmington Site that can contribute to radiological exposure are the 

24 nuclear fuel complex and WFSC. The fuel complex includes the FMO/FMOX buildings, the 

25 DCP building, the Waste Treatment Facility, process basins, and other support facilities. The 

26 SCO and FCO facilities handle only nonradioactive components. Therefore, no radioactivity is 

27 released to the environment from SCO and FCO facilities. 

28 

29 Radiological Exposure to the General Public

30 

31 Airborne and liquid effluent releases of radionuclides from the existing operations of the nuclear 

32 fuel complex and WFSC at the Wilmington Site result in radiation exposure to people in the 

33 vicinity of the site. The most likely public exposure pathway is by inhalation of airborne 

34 effluents. 

35 

36 The gamma radiation exposure levels measured at the site boundary are at background levels 

37 (GLE, 2009a); therefore, direct radiation exposure is not a significant exposure pathway for the 

38 public from existing GNF-A operations. 

39 

40 The airborne effluent releases from the FMO facility vents are sampled continuously. For the 

41 period 1995 to 2005, the gross alpha activity released per year from the FMO facility vents 

ranged from 5.55 × 105

 to 7.29 × 106 42 becquerels (15 to 197 microcuries) (GLE, 2008). The 

43 maximum release was in 1997, the year in which the FMO facility switched from a wet process 

44 of converting uranium hexafluoride (UF6) to uranium dioxide (UO2) to a dry conversion process; 

45 a decreasing trend has been observed since then. 

46 

47 The airborne effluent from WFSC stacks is monitored for gross beta emissions. Cobalt-60 is the 

48 main source of beta emissions. For the period 2006 to 2008, the gross beta concentrations at 
3-96 

1 

2 Figure 3-18 Percentage Contribution to the Effective Dose 

3 in the U.S. Population for 2006 (NCRP, 2009) 

4 

the release points ranged from 6.7 × 10−5

 to 4.4 × 10−4 becquerels per cubic meter (1.8 × 10−15 5 

to 1.2 × 10−14 6 microcuries per cubic centimeter) (GLE, 2009a). 

7 

8 Continuous ambient air monitoring for gross alpha activity is conducted at six air sampling 

9 stations as shown in Figure 3-19. For the period 1995 to 2005, average gross alpha 

measurements from GNF-A ambient air samplers ranged from 8.1 × 10−5

 to 1.7 × 10−4 10 

becquerels per cubic meter (2.2 × 10−15 to 4.5 × 10−15 11 microcuries per cubic centimeter) 

12 (GLE, 2008). These levels are approximately one order of magnitude below the most restrictive 

maximum allowable uranium air concentration limit of 5 × 10−14 13 microcuries per cubic centimeter 

14 in 10 CFR Part 20, Appendix B. 

15 

16 Ambient air radiation levels are also monitored by the North Carolina Radiation Protection 

17 Section (RPS) of the NCDENR. There are two RPS air samplers located on the Wilmington 

18 Site. The first is at the fence near the southern boundary of the site, and the second is located 

19 at the site dock on the Cape Fear River. Both of these air samplers are colocated with GNF-A 

20 ambient air samplers. In 1995, GNF-A monitoring and the RPS onsite sampling results were 

21 comparable (NRC, 1997). The RPS also has two monitoring stations offsite. A comparison of 

22 the GNF-A onsite air sampling results with offsite samplers indicates that the measured 

23 concentrations are at background levels and do not indicate any elevated levels of alpha activity 

24 (NCDENR, 2009b). 

25 

26 On the basis of modeling of total radionuclide releases to the air for the years 1995 to 2005 from 

27 the FMO facility stacks, the estimated radiation dose to the nearest resident assumed to be at 
3-97 

Figure 3-19 Onsite Ambient Air Monitoring Locations for Gross Alpha and Uranium Isotopes (
3-98 

1 the site boundary (located 130 to 384 meters [427 to 1260 feet] south of the FMO facility stack) 

2 by using the COMPLY code, ranged from 0.00027 millisievert (0.027 millirem) in 2002 to 

3 0.0040 millisievert (0.40 millirem) in 1997 (GLE, 2008). These estimated doses to the nearest 

4 resident are well below the NRC limit of 1 millisievert per year (100 millirem per year) 

5 in 10 CFR 20.1301(a). 

6 

7 To confirm that air emissions are within regulatory requirements and are not harmful to human 

8 health, the dose to a hypothetical person living at the site boundary for 2006 to 2008 from FMO 

9 facility stack releases was also calculated. The yearly estimated doses from air effluent 

10 releases varied from 0.00035 to 0.00040 millisieverts per year (0.035 to 0.040 millirem 

11 per year). The distance to the nearest site boundary from different stacks varied from 130 to 

12 384 meters (427 to 1260 feet) (GLE, 2009a). The estimated doses are well below the EPA’s 

13 NESHAPs limit of 0.1 millisieverts per year (10 millirem per year), and the NRC total effective 

14 dose equivalent limit of 1 millisievert per year (100 millirem per year). 

15 

16 There are no liquid effluent releases from the WFSC, and the airborne effluent releases are 

17 about four orders of magnitude lower than the 10 CFR Part 20, Appendix B, Table 2 value for 

18 Cobalt-60 (GLE, 2009a). The concentrations at the site boundary would be much lower than 

19 the concentration at the release point. These concentrations would result in a yearly dose less 

20 than 0.0001 millisievert (0.01 millirem) at the site boundary. 

21 

22 Doses from the existing liquid effluent releases at the site were calculated from the liquid 

23 effluent flow concentrations from the Final Process Lagoon. The concentrations for 2003 to 

2007 varied from 2.0 × 103

 to 4.6 × 103 becquerels per cubic meter (5.44 × 10−8 to 1.25 × 10−7 24 

25 microcuries per milliliter) compared with the NRC uranium liquid effluent concentration limit of 

1.1 × 104

 becquerels per cubic meter (3 × 10−7 26 microcuries per milliliter) in 10 CFR Part 20, 

27 Appendix B, Table 2. Assuming that an individual continuously ingests this water for one year, 

28 this concentration would result in the total effective dose equivalent (TEDE) in the range 0.09 to 

29 0.21 millisieverts per year (9 to 21 millirem per year) (NRC, 2009). 

30 

31 Radiological Exposure to Occupational Workers

32 

33 The Wilmington Site’s occupational radiation exposure data for the last five years (FY 2003 to 

34 FY 2007) were reviewed (Burrows, 2004, 2005, 2006; Dickson, 2007; Lewis et al., 2008). The 

35 TEDE to the average worker during this period varied from 0.77 to 1.06 millisieverts 

36 (77 to 106 millirem). None of the workers received a dose greater than 7.5 millisieverts 

37 (750 millirem). These doses are well below the NRC limit of 50 millisieverts per year 

38 (5000 millirem per year) in 10 CFR 20.1201 and the Wilmington Site’s administrative limit of 

39 40 millisieverts per year (4000 millirem per year). Most of this exposure came from inhalation of 

40 uranium dust and direct contact with uranium. 

41 

42 3.11.2 Background Chemical Exposure 

43 

44 The existing FMO facility is the main source of potential airborne chemical exposures to either 

45 onsite or offsite populations in the vicinity of the proposed GLE Facility. UF6 and hydrogen 

46 fluoride (HF) are the primary chemicals of potential concern because of their toxicity and the fact 

47 that both may be emitted as gases or vapors. HF is formed from the conversion of UF6 to 

48 UO2F2 (uranyl fluoride) upon contact of UF6 emissions with water in air. Such conversion is the 
3-99 

1 source of HF emissions from the existing GNF-A facility as well as from the proposed GLE 

2 Facility. HF is a gas at ambient temperatures, while UF6 may be vaporized (sublimated) from a 

3 solid state upon heating and may be emitted as a vapor, before condensing (desublimating) 

4 back to solid form in air after release. Exposures to UF6 may occur in either its vapor or solid 

5 particulate form in air. However, the range of transport would be somewhat more limited in air 

6 than HF because of the precipitation of particulate UF6 or UO2F2. 

7 

8 HF and uranium have different modes of toxicity, as discussed in Section 3.11.3.3, while 

9 concentration levels of concern are at similar levels. Because the concentrations of the two 

10 chemicals are linked due to the production of HF from UF6 and because they have similar 

11 toxicity benchmark levels, which of the two governs exposure limits depends on the specific 

12 benchmark chosen. HF exposure may be limiting when using available limits for ambient air 

13 exposures, such as the California Reference Exposure Level of 14 micrograms per cubic meter 

14 (0.017 parts per million) for chronic exposures (Cal/EPA, 2003), or the State of Washington’s 

15 Acceptable Source Impact Level of 8.7 micrograms per cubic meter (0.011 parts per million) 

16 (ATSDR, 2003). 

17 

18 Comparable public health benchmarks for uranium air concentrations are not available as such, 

19 since uranium is not typically an air pollutant. Occupational exposure standards, on the other 

20 hand, may be a bit more restrictive for uranium than for HF. For example, the 50 micrograms 

21 per cubic meter (soluble uranium forms) National Institute for Occupational Safety and Health 

22 (NIOSH) Time-Weighted Average (TWA) Recommended Exposure Level and the equivalent 

23 50 micrograms per cubic meter Occupational Safety and Health Administration (OSHA) 

24 Permissible Exposure Limit (NIOSH, 1996, 2005) are more restrictive than OSHA’s Permissible 

25 Exposure Limit for HF of 2.5 milligrams per cubic meter (3.1 parts per million) in air averaged 

26 over eight hours. For further comparison, the NIOSH standard for uranium levels Immediately 

27 Dangerous to Life and Health (IDLH) is 10 milligrams per cubic meter over a one-hour 

28 exposure, while the NIOSH IDLH for HF is 30 parts per million (25 milligrams per cubic meter) 

29 (ATSDR, 2003). Thus, the two chemicals have similar exposure limits in the workplace. 

30 

31 HF is produced at the FMO facility in a dry conversion process used to convert UF6 to UO2. 

32 Extensive measures are taken to prevent any significant emissions of HF, including the use of 

33 high-efficiency particulate air (HEPA) filters on general circulation air vents, and HEPA filter and 

34 permitted scrubbers, where needed, on process off-gas ventilation systems (NRC, 1997; 

35 NRC, 2009). A continuous HF monitoring system is operated on all process vents that may 

36 emit HF. 

37 

38 In 2004, the Wilmington Site emitted about 27 kilograms (60 pounds) of total fluorides and 

39 15 kilograms (32 pounds) of hydrogen fluoride (Section 3.5.3.1), while in 2007, facility-wide 

40 fluoride emissions from the FMO and FCO complexes were 145 kilograms (320 pounds) 

41 (NRC, 2009). Current NCDENR Air Permit 1756R17 for the facility limits total HF emissions 

42 from the HF recovery building to no greater than 0.29 kilogram per day (0.63 pound per day) 

43 (24-hour period) and to no greater than 0.029 kilogram (0.063 pound) in any given hour and 

44 GNF-A facility-wide fluoride emissions to 9100 kilograms per year (20,000 pounds per year). As 

45 a “synthetic minor source,” the site is required to report air emissions data to the State every 

46 three years, while facilities undergo permit verification annually by the State inspector. 

47 
3-100 

1 Emissions of other criteria air pollutants and North Carolina TAPs from the FMO facility and 

2 other stationary sources near the Wilmington Site are discussed in Section 3.5.3.1. Among the 

3 TAPs, which include the Federal HAPs, the greatest emission quantities from the Wilmington 

4 Site for 2004 were for nitric acid (178 kilograms per year [393 pounds per year]) and ammonia 

5 (108 kilograms per year [237 pounds per year]). As noted in Section 3.5.3.1, these emissions 

6 rates are well below the major source thresholds of 9.1 metric tons per year (10 tons per year) 

7 for a single HAP and 23 metric tons per year (25 tons per year) for any combination of listed 

8 HAPs. Thus, emissions of TAPs are well below levels that would be of concern for health 

9 impacts, while those for HF and uranium are of relatively greater concern. Moreover, HF and 

10 uranium would be the main toxic air emissions of concern for the proposed GLE Facility. 

11 

12 UF6 will also be used in the proposed GLE Facility, while both UF6 and HF could be released 

13 from that facility under various accident scenarios. HF would be produced from the reaction of 

14 UF6 with water in air (humidity) under an accidental release of UF6. 

15 

16 Groundwater beneath the Wilmington Site has been affected by industrial operations at the site 

17 and is being actively remediated. Pollutants include VOCs, fluoride, nitrate, and uranium. 

18 Affected groundwater is not being used as a source of drinking water (Section 3.7.4.2). A 

19 network of groundwater monitoring wells is used to follow contaminant movements and to 

20 monitor the site perimeter. None of the surface water streams on the Wilmington Site are 

21 affected by chemical contamination. However, the Northeast Cape Fear River upstream of the 

22 site is listed as impaired because of mercury pollution, and a section of the river upstream is 

23 under a fish consumption advisory for mercury (NCDWQ, 2007). 

24 

25 GNF-A has discharge permits for treated process water and treated sanitary wastewater for an 

26 onsite effluent channel, which eventually empties into the Northeast Cape Fear River. The site 

27 is required to monitor wastewater discharges as well as stormwater surface runoff under its 

28 permits. Treated sanitary wastewater, however, is currently reused as cooling water onsite. 

29 Local surface water quality and the requirements of the Wilmington Site’s water quality permits 

30 are discussed in Section 3.7.1. 

31 

32 The WFSC produces no liquid effluents and no air emissions of chemicals at levels of public 

33 health concern. The facility is not listed on either the site’s air or water permit lists of site 

34 sources. 

35 

36 Hazardous chemical wastes produced at Wilmington Site facilities, the largest volume of which 

37 is etch-acid solution, are collected, packaged, temporarily stored on site, and periodically 

38 shipped to a Resource Conservation and Recovery Act (RCRA)-permitted facility in 

39 Indianapolis, Indiana (GLE, 2008). 

40 

41 3.11.3 Public Health Studies 

42 

43 3.11.3.1 Regulatory Requirements for Public and Occupational Exposure 

44 

45 NRC regulations in 10 CFR Part 20 identify maximum allowable concentrations of radionuclides 

46 in air and water above background at the boundary of unrestricted areas to control radiation 

47 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 48 microcuries per 
3-101 

1 cubic centimeter, respectively (10 CFR Part 20, Appendix B). Other 10 CFR Part 20 

2 requirements are that the sum of the external and internal doses (TEDE) for a member of the 

3 public may not exceed 1 millisievert per year (100 millirem per year) (10 CFR 20.1301(a)(1)), 

4 and the radiation levels at any unrestricted area should not exceed 0.02 millisievert (2 millirem) 

5 in any 1 hour and 0.5 millisievert (50 millirem) in a single year. (10 CFR 20.1301(a)(2)). 

6 

7 In addition to keeping within NRC requirements, releases to the environment must comply with 

8 EPA standards in 40 CFR Part 190, “Subpart B − Environmental Standards for the Uranium 

9 Fuel Cycle.” These standards specify limits on the annual dose equivalent from normal 

10 operations of uranium fuel-cycle facilities (except mining, waste disposal operations, 

11 transportation, and reuse of recovered special nuclear and by-product materials). The public 

12 dose limit for annual whole body and organ is 0.25 millisievert (25 millirem), and for the thyroid it 

13 is 0.75 millisievert (75 millirem). 

14 

15 10 CFR 20.1201 limits the TEDE of workers to ionizing radiation. Table 3-18 provides 

16 occupational dose limits for radiation workers who work at nuclear facilities. Public and 

17 occupational standards for chemical exposures to HF and uranium are presented in the 

18 previous section. 

19 

20 3.11.3.2 Health Effects from Radiological Exposure 

21 

22 Radiation interacts with the atoms that form cells. There are two mechanisms by which 

23 radiation affects cells: direct action and indirect action. In a direct action, the radiation interacts 

24 directly with the atoms of the deoxyribonucleic acid (DNA) molecule or some other component 

25 critical to the survival of the cell. Since the DNA molecules make up a small part of the cell, the 

26 probability of direct action is small. Because most of the cell is made up of water, there is a 

27 much higher probability that radiation would interact with water (NRC, 2010). In an indirect 

28 action, radiation interacts with water and breaks the bonds that hold the water molecule 

29 together, producing reactive free radicals that are chemically toxic and destroy the cell. The 

30 body has mechanisms to repair damage caused by radiation. Consequently, the biological 

31 effects of radiation on living cells may result in one of three outcomes: (1) injured or damaged 

32 cells repair themselves, resulting in no residual damage; (2) cells die, much like millions of body 

33 cells do every day, being replaced through normal biological processes and causing no health 

34 effects; or (3) cells incorrectly repair themselves, which results in damaging or changing the 

35 genetic code (DNA) of the irradiated cell (NRC, 2004b). Stochastic effects, that is, effects that 

36 may or may not occur according to probability, may occur when an irradiated cell is modified 

37 rather than killed. The most significant stochastic effect of radiation exposure is that a modified 

38 cell may, after a prolonged delay, develop into a cancer. 

39 

40 The biological effects on the whole body from exposure to radiation depend on many factors, 

41 such as the type of radiation, total dose, time interval over which the dose is received, and part 

42 of the body that is exposed. Not all organs are equally sensitive to radiation. The blood-forming 

43 organs are most sensitive to radiation; muscle and nerve cells are relatively insensitive to 

44 radiation (NRC, 2010). Health effects may be characterized according to two types of radiation 

45 exposure: (1) a single accidental exposure to high doses of radiation for a short period of time 

46 (acute exposure), which may produce biological effects within a short time after exposure, and 

47 (2) long-term, low-level overexposure, commonly called continuous or chronic exposure. High 

48 doses of radiation can cause death. Other possible effects of a high radiation dose include 
3-102 

Table 3-18 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 erythema, dry desquamation, moist desquamation, hair loss, sterility, cataracts, and acute 

3 radiation syndromes (NRC, 2010). Currently there are no data to unequivocally establish the 

4 occurrence of cancer following exposure to low doses and dose rates – below about 

5 100 millisieverts (10,000 millirem) (NRC, 2004b). 

6 

7 In estimating the health impacts from low dose or low dose rate exposure to occupational 

8 workers and the general public, the probability of a fatal cancer per unit of radiation exposure 

9 recommended by the International Commission on Radiological Protection (ICRP) was used. 

The estimated probability for workers is 4 × 10−2

 sievert−1 and for the public it is 5 × 10−2 sievert−1 10 

11 (ICRP, 1991). The estimated probability for the public is higher because it includes young 

12 people who are more sensitive to radiation (ICRP, 1991). 

13 

14 The National Program of Cancer Registries (NPCR) is the Centers of Disease Control and 

15 Prevention (CDC) State-based cancer control program. Under this program, States collect, 

16 manage, and analyze data about cancer incidence and mortality. The CDC and the National 

17 Cancer Institute release U.S. Cancer Statistics annually. Table 3-19 lists the cancer incidence 

18 and death rates for all cancers for 2000 to 2005 for North Carolina and the United States. 

19 

20 3.11.3.3 Health Effects from Chemical Exposure 

21 

22 Chemicals may enter the body through absorption through the skin, by inhalation, or by 

23 ingestion. Chemical exposure produces different effects on the body depending on the mode of 

24 action of the chemical and the amount of exposure. Some chemicals can cause cancer, affect 

25 reproductive capability, disrupt the endocrine system, or have other health effects. Acute 

26 effects from exposure to high levels of toxic chemicals occur immediately (e.g., when somebody 

27 inhales or ingests a poisonous substance such as cyanide). Chronic or delayed effects may be 

28 more subtle and are due to long-term, low-level exposure to toxic chemicals. 

29 

30 The primary chemicals of interest associated with the existing GNF-A facility, as well as the 

31 proposed GLE Facility, are uranium and HF associated with the UF6 reaction with moisture in 

32 air. HF is an irritant gas that causes eye, nose, and skin irritation. Breathing high levels can 

33 also harm the lungs and heart (ATSDR, 2003). Irritant effects in humans, including respiratory 

34 tract inflammation, begin to be observed in the range of 1 to 10 parts per million, similar to 

35 occupational exposure limits. Low-level exposure effects are reversible once the exposure is 

36 terminated. Members of the public are generally not exposed to levels that have observable 

37 health effects from routine industrial emissions. Various potentially relevant exposure 

38 benchmarks for the public and occupational exposure to HF are presented in Section 3.11.2. 
3-103 

Table 3-19 Cancer Incidence and Death 

Rates for all Cancers for 2000 to 2005a 

Area All Cancer 

Incidence Rate 

All Cancer 

Death Rate 

United States 467.6 189.8 

North Carolina 453.8 196.1 

a

 Per 100,000 persons and are age adjusted to the 2000 

U.S. standard population. 

Source: CDC, 2009. 

1 

2 Uranium exerts heavy metal toxicity, primarily to the kidney (ATSDR, 1999). Exposure to 

3 uranium may be via inhalation or ingestion. The degree of absorption of inhaled uranium from 

4 the lung or of ingested uranium into the bloodstream is greater for more soluble forms of 

5 uranium, such as UO2F2, which is formed from the reaction of UF6 and water. Little direct 

6 toxicological data are available on chemical toxicity in humans at low inhalation exposures. 

7 Standards are based mainly on tests in mammals, which show low-level systemic health effects 

8 beginning at inhalation exposures in the 0.1 to 1 milligram per cubic meter range for chronic 

9 exposures. These levels generally correspond to the occupational exposure standards 

10 discussed in Section 3.11.2. 

11 

12 The EPA is responsible for regulating most chemicals that can enter the environment. This 

13 authority is typically delegated to the States for implementation, as it is in North Carolina. 

14 

15 Disposal of the hazardous chemicals used at GNF-A is regulated via permits issued under 

16 RCRA, while discharges to waterways are regulated via NPDES permits issued under the CWA 

17 and air emissions via permits issued under the CAA. These permits are administered and 

18 enforced by the NCDENR, Division of Water Quality and Division of Air Quality, respectively. 

19 GNF-A is required by the NRC to operate in compliance with all of its permits, therefore 

20 minimizing the impact on the environment and on workers and the public. 

21 

22 3.11.3.4 Health Study of Mercury Emissions 

23 

24 In early 2009, Intertox of Seattle, Washington, completed an independent, peer-reviewed, study 

25 of potential health impacts from exposure to mercury emissions from the proposed Carolinas 

26 Cement plant in Castle Hayne, about 10 kilometers (6 miles) northeast of the proposed 

27 GLE Facility. The study concluded that exposures to plant emissions by residents of Castle 

28 Hayne and the greater Wilmington area would be minor and would not lead to any health 

29 effects, even in maximally exposed individuals, including those who subsisted mainly on fish 

30 from the river. The study found that greater than 98 percent of the estimated mercury exposure 

31 originating from the cement plant would be via consumption of fish from the Northeast Cape 

32 Fear River, which would bioconcentrate mercury transported to the river via the atmosphere. 

33 The study did find, however, that some individuals interviewed currently consumed fish from the 

34 river in excess of fish advisories in place as a result of existing mercury sources in the area, and 

35 thus, could benefit from reducing fish consumption (Intertox, 2009). 

36 
3-104 

1 Mercury in its various forms is a listed HAP. For New Hanover, Brunswick, and Pender 

2 Counties surrounding and including the Wilmington Site, the NCDAQ reported a total of 

3 135 kilograms (297 pounds) of mercury emissions of all forms from stationary sources in 2007 

4 (NCDAQ, 2007). Of the nine source facilities listed by the NCDAC in New Hanover County, 

5 none are associated with the Wilmington Site. Mercury fish advisories, such as those that apply 

6 to regions of the Northeast Cape Fear River, may be the result of non-point sources or distant 

7 sources combined with bioaccumulation processes in fish. 

8 

9 3.11.4 Occupational Injury and Illness Rates 

10 

11 OSHA is responsible for developing and enforcing workplace safety regulations. Occupational 

12 hazards can be minimized when workers adhere to safety standards and use appropriate 

13 protective equipment; however, fatalities and injuries from accidents can still occur. 

14 

15 No fatalities have occurred in the nuclear facilities on the Wilmington Site. The GNF-A 

16 maintains a log and summary of recordable occupational injuries and illnesses under the 

17 guidance of OSHA’s Occupational Injury and Illness Recording and Reporting Requirements in 

18 29 CFR Part 1904. On the basis of the information provided by GLE (GLE, 2008, 2009a), the 

19 annual recordable accidents at the site varied from 3 to 22 for fiscal years 2000 to 2008. The 

20 number of recordable injuries/illnesses per year per 100 workers varied from 0.46 to 1.64 over 

21 the years 2000 to 2006 (GLE, 2008). 

22 

23 The U.S. Department of Labor, Bureau of Labor Statistics compiles annual injury and illness 

24 data, including the incidence rates by industry (DOL, 2008). GNF-A manufactures fuel 

25 assemblies and intermediate fuel components for the nuclear power industry, and its operations 

26 may also be classified as chemical manufacturing. The Bureau of Labor Statistics’ national 

27 average incidence rate of nonfatal occupational injuries and illnesses for chemical 

28 manufacturing facilities for calendar year 2007 is 3.1, which is higher than the rates of 

29 0.46 to 1.64 for GNF-A. 

30 

31 3.12 Waste Management 

32 

33 This section describes the solid and liquid, nonhazardous, hazardous, and radioactive wastes 

34 currently generated and managed by GE at the Wilmington Site. No radioactive mixed waste is 

35 currently generated. This reflects the baseline condition and is aside from the wastes that the 

36 proposed GLE Facility would generate and manage under the proposed action, which are 

37 described in Chapter 2. This section also describes the existing waste management practices 

38 used at the Wilmington Site, most of which would also be used to manage wastes from the 

39 proposed GLE Facility. 

40 

41 3.12.1 Current Waste Management Program 

42 

43 The Wilmington Site generates a range of gaseous, liquid, and solid waste streams from its 

44 current manufacturing operations. The radioactive and nonradioactive air emissions are 

45 discussed in Section 3.5.3.1. The liquid and solid wastes generated are regulated by the EPA’s 

46 waste management and disposal programs implemented under RCRA Subtitle C (Hazardous 

47 Wastes) and Subtitle D (Nonhazardous Wastes). Wastewater treatment is discussed in 

48 Section 3.12.2. The treatment and disposal of solid waste generated from manufacturing 
3-105 

1 operations and wastewater treatment are covered in Section 3.12.4. The liquid and solid 

2 wastes currently generated at the Wilmington Site are summarized in Table 3-21 in 

3 Section 3.1.2.3. 

4 

5 3.12.2 Wastewater Treatment 

6 

7 Sanitary wastewater and process wastewater effluents are the largest liquid waste streams 

8 generated at the Wilmington Site. The process wastewater effluents are from the current 

9 manufacturing operations, and the sanitary wastewater effluents are from the existing building 

10 restrooms, cafeteria, and other sanitary facilities. The wastewater streams generated by current 

11 operations are summarized in Table 3-20. 

12 

13 3.12.2.1 Sanitary Wastewater 

14 

15 Sanitary wastes at the Wilmington Site are collected in a sewer system that routes the waste to 

16 an onsite, activated sludge-aeration, treatment plant that incorporates a membrane bioreactor 

17 (GLE, 2008; GNF-A, 2008). The activated sludge process is a biological wastewater treatment 

18 process in which wastewater is fed into an aerated tank where microorganisms feed on the 

19 waste organic material (the bioreactor). The activated sludge (the microorganisms) is 

20 subsequently separated from the treated wastewater along with waste by-products by an 

21 ultrafiltration membrane and disposed of. The current activated sludge–aeration treatment plant 

22 was commissioned in April 2008. At that time, a water reuse permit from the NCDENR 

23 (NCDENR, 2007) was obtained to allow the use of the treated sanitary wastewater effluent as 

24 makeup water for Wilmington Site cooling towers (GLE, 2008). All treated sanitary wastewater 

25 effluent is currently used as makeup water for the cooling towers. 

26 

27 Prior to 2008, the treated sanitary wastewater effluent was released to the effluent channel, 

28 which flows into Unnamed Tributary #1, which empties into the Northeast Cape Fear River 

29 (Waters of the United States). The NPDES discharge permit (NPDES Permit NC0001228) for 

30 this activity allows up to 283,906 liters per day (75,000 gallons per day) of sanitary wastewater 

31 effluent to be discharged from the Wilmington Site (GLE, 2008). Figure 3-20 shows the 

32 discharge location of the sanitary wastewater treatment facility (Discharge Location 002). Prior 

33 to facility upgrades, the 2006 average daily discharge from the sanitary wastewater treatment 

34 facility to the effluent channel through Outfall 002 on its way to Discharge Location 002 was 

35 124,919 liters per day (33,000 gallons per day) (Table 3-20). Sanitary wastewater must meet 

36 the monitoring requirements and effluent limitations as set forth in the NPDES permit from the 

37 NCDWQ. The sanitary wastewater effluent is monitored at Outfall 002, which is a location along 

38 the discharge pipe that drains from the sanitary wastewater treatment facility to the effluent 

39 channel just south of the treatment facility. Although GNF-A currently uses sanitary wastewater 

40 effluent for cooling tower makeup water, the NPDES discharge permit has been renewed. 

41 Therefore, discharge of treated sanitary wastewater to the effluent channel could be resumed, if 

42 necessary. 

43 

44 3.12.2.2 Process Wastewater 

45 

46 Current operations at the Wilmington Site include the combined GNF-A FMO facility, GNF-A 

47 FCO facility, GE AE operations, and GE SCO facility. These facilities all share a common 

48 wastewater treatment system designed to handle pre-treated process wastewater, nontreated 
3-106 

Table 3-20 Wastewater Streams Generated by Current Operations 

at the Wilmington Site 

Wastewater 

Stream

Generation 

Frequency NPDES Limita 2006 Average 

Daily Flow Rate Wastewater Treatment

Process 

wastewater 

Continuous 6,813,741 lpd 

(1,800,000 gpd) 

1,802,613 lpd 

(476,200 gpd) 

pH adjustment, settling, 

aeration 

Sanitary 

waste 

effluent 

Continuous 283,906 lpd 

(75,000 gpd) 

124,919 lpd 

(33,300 gpd) 

Dual-train, extended, activated 

sludge-aeration wastewater 

treatment facility with 

chlorination/dechlorinationb

a gpd = gallons per day; lpd = liters per day. 

b The Wilmington Site sanitary wastewater treatment facility has recently been upgraded to a single-train, 

extended aeration activated sludge wastewater treatment facility with membrane ultrafiltration and ultraviolet 

(UV) filtration (operational March 2008). 

Source: GLE, 2008. 

1 

2 process wastewater, filter backwash water, and noncontact cooling water (GLE, 2008). All 

3 treated wastewater is sent to the final process lagoon treatment facility (FPLTF), which 

4 discharges to the effluent channel (Discharge Location 001 in Figure 3-20). The 2006 average 

5 daily discharge from the final process lagoon facility was 1,802,613 liters per day 

6 (476,200 gallons per day) (see Table 3-21), approximately one quarter of the 6,813,741 liters 

7 per day (1.8 million gallons per day) of treated process wastewater allowed under the current 

8 NPDES discharge permit (NPDES Permit NC0001228) (GLE, 2008). 

9 

10 The FMO facility uses a DCP to convert its UF6 waste directly to the oxide (UO2). Two liquid 

11 waste streams are generated – one with a dilute HF concentration (approximately 1 to 2 percent 

12 HF), and a second with a higher concentration of HF (<50 percent). The dilute HF waste 

13 solution is mixed with lime (Ca(OH)2) to form calcium fluoride (CaF2) which is insoluble in water 

14 and precipitates out as a solid. The CaF2 solid phase is dewatered and sent to the 

15 EnergySolutions disposal facility in Clive, Utah, along with other wastes (see Section 3.12.4.2). 

16 The liquid phase from the dewatering unit is pH-adjusted and combined with other waste 

17 streams before any final treatment and discharge to the effluent channel. The more 

18 concentrated HF solution produced during the conversion of UF6 to UO2 is sold for industrial and 

19 commercial uses. Under safety condition S-2 of NRC license SNM-1097, GNF-A is granted the 

20 special authorizations stated in Section 1.3 of its license renewal application, including 

21 authorization to transfer liquid HF to commercial chemical companies or suppliers as long as the 

22 concentration of uranium is maintained below three parts per million by weight, uranium-235 

23 enrichment is less than five percent, and members of the general public are not exposed 

24 through any pathway to trace uranium concentrations higher than natural levels in products 

25 formed from its use (see Section 1.3.3.2 of [GNF-A, 2007]). 

26 

27 3.12.3 Other Liquid Waste 

28 

29 Aside from sanitary and process wastewater streams, other nonhazardous and hazardous liquid 

30 wastes are generated at the Wilmington Site. Nonhazardous industrial wastes, such as the 

31 1592 metric tons (1755 tons) of used oils are sent offsite to the FCC Environmental Treatment 

32 Facility in Concord, North Carolina, for recycling and reuse as shown in Table 3-21. The GNF-A 
3-107 

Figure 3-20 Existing Wastewater Treatment Facilities and Discharge Points at the Wilmington Sit
3-108 

Table 3-21 Solid and Liquid Wastes Generated by Current Operations 

at the Wilmington Site 

Waste Type

Waste 

Generation 

Source 

(Wilmington 

Site)

Waste Composition

Annuala 

Quantity 

Generated

Offsite Treatment or 

Disposal Facility (Type 

and Location)

Municipal solid 

waste 

GNF-A 

operations and 

GE AE/SCO 

• Refuse and other 

nonhazardous solid 

wastes accepted at landfill 

898 metric 

tons 

(990 tons) 

New Hanover County 

Landfill 

Wilmington, North Carolina 

Nonhazardous 

industrial 

wastes 

GNF-A 

operations 

• Used NaOH solutionb 

• Clean-room sludge 

• Spent coolant 

• Used tube reducer 

• Nonhazardous caustic 

• Filter medium 

97 metric 

tons 

(107 tons) 

Heritage Environmental 

Services RCRA Permitted 

TSDFc Indianapolis, 

Indiana, or other facilities 

depending on the 

composition of the wasted

 

 GE AE/SCO • Pre-rinse emulsifier 

• Spill cleanup adsorbent 

media 

• Mixed dry batteries 

• Metal chips 

• Process tank and drain 

cleanout sludges 

36 metric 

tons 

(40 tons) 

 GNF-A and GE 

AE/SCO 

• Used oilse 1592 metric 

tons 

(1755 tons) 

FCC Environmental 

Treatment Facility 

Concord, North Carolina 

Hazardous 

waste 

GNF-A and GE 

AE/SCO 

• HF/HNO3 wastef 

• Minor quantities of waste 

paints and solvents and 

X-ray wastes 

1973 metric 

tons 

(2175 tons)g

Heritage Environmental 

Services RCRA Permitted 

TSDFc Indianapolis, 

Indiana 

LLRW GNF-A 

operations 

• Metal parts, filters, and 

other noncombustible 

wastes 

• Dewatered CaF2

h solids 

• Waste incinerator ash 

188 metric 

tons 

(208 tons)i

EnergySolutions LLRW 

Disposal Facility Clive, 

Utah 

a

 Annual waste quantity records for existing Wilmington Site facilities operations for 2006, with the exception of LLRW. b

 Used NaOH solution manifested to Heritage Environmental Services is recycled and reused. In 2006, the quantity of 

recycled/reused NaOH was 70 metric tons (77 tons) of the total 97 metric tons (107 tons) of nonhazardous industrial waste 

manifested to Heritage Environmental Services from GNF-A operations. c

 TSDF = Treatment, storage, and disposal facility permitted under RCRA Subtitle C requirements to manage hazardous 

wastes. Also accepts nonhazardous wastes for treatment and recycling/reuse. d

 Depending on the composition of the nonhazardous waste, these materials are either shipped directly to the Heritage 

Environmental Services facility in Indianapolis, Indiana, for treatment and burial and/or routed through Heritage Environmental

Services for reuse, reclaim, or treatment at other GE-approved facilities. e

 Used oils manifested to FCC Environmental are recycled and reused. 

f

 HF/HNO3 waste = hydrofluoric acid (HF) and nitric acid (HNO3) wastes. g

 Hazardous waste predominately generated by GNF-A operation with a small quantity from the GE AE operation. h

 Calcium fluoride (CaF2). i

 The value for LLRW is an estimate of annual waste quantity for 2008 and future years to reflect the current LLRW 

management practices used by GNF-A operations, which reduce the quantity of LLRW shipped to EnergySolutions from the 

historical levels for 2006 and earlier. 

Source: GLE, 2008. 
3-109 

1 FCO facility also generates a sodium hydroxide (NaOH) waste solution and an etch-acid waste 

2 solution that are treated separately. The NaOH solution waste, 70 metric tons (77 tons) in 2006, 

3 is shipped to Heritage Environmental Services, Indianapolis, Indiana, for recycling (GLE, 2008). 

4 

5 The predominant hazardous waste generated at the Wilmington Site is the spent etch-acid 

6 solution (a solution containing HF and nitric acid [HNO3]) from GNF-A FCO activities. Minor 

7 quantities of hazardous waste paints and solvents are also generated. The hazardous wastes 

8 are collected and temporarily stored, less than 90 days, in U.S. Department of Transportation 

9 (DOT)-approved shipping containers before being shipped offsite to the Heritage Environmental 

10 Services RCRA-permitted Subtitle C treatment, storage, and disposal facility (TSDF) 

11 (GLE, 2008). 

12 

13 3.12.4 Solid Waste 

14 

15 The types of solid wastes generated currently at the Wilmington Site include municipal solid 

16 waste (MSW), nonhazardous industrial waste, and low-level radioactive wastes (LLRW). 

17 Table 3-21 summarizes the amounts generated and their offsite treatment or disposal. 

18 

19 3.12.4.1 Municipal Solid Waste and Nonhazardous Industrial Wastes 

20 

21 The GNF-A and GE AE/SCO facilities generated approximately 898 metric tons (990 tons) of 

22 MSW in 2006 (GLE, 2008). The waste is disposed of offsite at the RCRA-permitted Subtitle D 

23 New Hanover County municipal landfill, and constitutes less than one percent of the 

24 approximately 151,000 tons (approximately 210,000 cubic yards [compacted]) of waste received 

25 annually at the landfill (NCDENR, 2009). The county has recently permitted the expansion of 

26 the landfill from 1.5 million to 2.4 million tons (5.7 million to 8.9 million cubic yards) 

27 (NCDENR, 2008a,b). The permit allows for five years of operation with a renewal permit to 

28 continue operations required at the end of the five years. 

29 

30 As shown in Table 3-21, the miscellaneous nonhazardous industrial wastes generated at the 

31 Wilmington Site are shipped to the Heritage Environmental Services RCRA-permitted Subtitle C 

32 TSDF in Indianapolis, Indiana, or other approved treatment and disposal facilities. Industrial 

33 waste that is neither a RCRA MSW nor a RCRA hazardous waste under Federal or State laws 

34 is regulated under RCRA Subtitle D as nonhazardous waste. 

35 

36 3.12.4.2 Low-Level Radioactive Waste 

37 

38 No LLRW is generated by the GE/SCO operations. LLRW generated by GNF-A operations are 

39 segregated into uranium contaminated-combustible and noncombustible materials. The 

40 noncombustible materials are collected and stored onsite until a full shipment is ready and then 

41 sent to the EnergySolutions LLRW disposal facility in Clive, Utah. These materials are 

42 summarized in Table 3-21 and consist of the CaF2 generated from the conversion of UF6 to UO2

43 and of items from ongoing plant maintenance activities. 

44 

45 The combustible LLRW is incinerated in an onsite natural gas-fired, multiple-chamber waste 

46 incinerator. About 166,468 kilograms (367,000 pounds) of LLRW are burned per year in the 

47 incinerator; the remaining ash is sent to the EnergySolutions facility in Clive, Utah, for disposal 

48 (GLE, 2008). 

49 
3-110 

1 3.13 Socioeconomics 

2 

3 This section describes current socioeconomic conditions and local community services within 

4 the region surrounding the site of the proposed GLE Facility. This region is based on the area 

5 in which workers are expected to live and spend most of their salary, and in which a significant 

6 portion of site purchase and nonpayroll expenditures from the construction, manufacturing, 

7 operation, and decommissioning phases of the proposed GLE Facility are expected to occur 

8 (GLE, 2008). This region, referred to in this draft EIS as the region of influence (ROI), 

9 corresponds to the Wilmington Metropolitan Statistical Area (MSA), a three-county area 

10 comprising Brunswick, New Hanover, and Pender Counties. These three counties cover an 

11 area that extends up to approximately 80 kilometers (50 miles) from the Wilmington Site 

12 (Figure 3-21). 

13 

14 3.13.1 Population Characteristics 

15 

16 The population in the ROI is characterized in terms of the major population centers around the 

17 proposed site, population growth trends, and significant transient and special populations. 

18 Minority and low-income populations are discussed in Section 3.14. 

19 

20 3.13.1.1 Major Population Centers 

21 

22 Within the ROI, one city, Wilmington (the county seat) (estimated 2006 population 95,944), is 

23 located in New Hanover County; several small towns are located in the remainder of the ROI. 

24 In Pender County, Burgaw is the county seat and had an estimated 3904 residents in 2006. 

25 The largest town in Brunswick County is Oak Island, with 8152 residents in 2005 

26 (USCB, 2009a). Bolivia is the county seat. 

27 

28 Population density in the ROI is the highest in New Hanover County, with 358.5 persons per 

29 square kilometer (928.9 persons per square mile) in 2008. The remaining counties have more 

30 land area than New Hanover County, and have smaller populations, thus producing much lower 

31 population densities. In Brunswick County, there were 45.9 persons per square kilometer 

32 (119.1 persons per square mile), and 22.9 persons per square kilometer (59.5 persons per 

33 square mile) in Pender County (USCB, 2009b). 

34 

35 3.13.1.2 Population Growth Trends 

36 

37 Table 3-22 presents recent and projected populations in the ROI and State as a whole. As 

38 shown, population in the ROI stood at 346,990 in 2008, having grown at an average annual rate 

39 of 3.0 percent since 2000. This growth was higher than the growth rate for North Carolina as a 

40 whole, 1.7 percent, over the same period. 

41 

42 Each of the counties in the ROI experienced a growth in population since 2000. Brunswick 

43 County recorded a population growth rate of 4.4 percent between 2000 and 2008, while Pender 

44 County and New Hanover County grew by 2.9 and 2.3 percent, respectively, in the same 

45 decade. The ROI population is expected to increase to 386,954 by 2013, and to 418,832 by 

46 2017. Each of the counties in the ROI is projected to experience positive population growth 

47 between 2008 and 2017. 
3-111 

Figure 3-21 Region of Influence for the Proposed GLE Facility 
3-112 

Table 3-22 Population in the ROI and North Carolina 

Location 2000 2008 

Average Annual 

Growth (%) 

2000-2008 

2013 2017 

Brunswick County 73,143 102,877 4.4 121,417 136,247 

New Hanover County 160,307 192,279 2.3 205,450 215,986 

Pender County 41,082 51,834 2.9 60,087 66,599 

ROI 274,532 346,990 3.0 386,954 418,832 

North Carolina 8,049,313 9,227,016 1.7 10,088,393 10,768,013 

Sources: USCB, 2009a; NCOSBM, 2009.

1 

2 3.13.1.3 Transient and Special Populations 

3 

4 In addition to the permanent resident population, institutional, transient, and seasonal 

5 populations occur in the ROI, some of which are not included in the residential population. 

6 Institutional populations include school and hospital populations. The transient population 

7 consists of visitors participating in various seasonal, social, and recreation activities within the 

8 local area. Large increases in population occur in the ROI during the summer, with many 

9 tourists and families owning vacation homes; the seasonal population of the region has 

10 exceeded the off-season population by up to 47,100 people, or 14.9 percent. The ROI has a 

11 small number of temporary farmworkers (USDA, 2009) and also hosts temporary workers in the 

12 construction and hospitality sectors (Griffith, 2007). 

13 

14 3.13.2 Economic Trends and Characteristics 

15 

16 3.13.2.1 Employment 

17 

18 Employment in the ROI stood at 120,803 in 2006 (Table 3-23). Over the past decade, there has 

19 been a slight employment shift from the government, construction, and farm sectors toward the 

20 service, wholesale and retail trade, and manufacturing sectors within the ROI. Currently, the 

21 service sector provides the highest percentage of employment in the region, at 49.6 percent, 

22 followed by the wholesale and retail trade with 21.2 percent. Smaller employment shares are 

23 held by construction (9.5 percent), manufacturing (6.9 percent), and finance, insurance, and real 

24 estate (6.6 percent). Within the ROI, the distribution of employment across sectors is similar to 

25 that of the ROI as a whole, with higher shares of employment in agriculture (19.8 percent) and 

26 manufacturing (10.5 percent) in Pender County, in manufacturing in Brunswick County 

27 (8.3 percent), and in wholesale and retail trade (24.5 percent) and construction (11.8 percent) in 

28 Pender County. Brunswick County (40.9 percent) and Pender County (30.8 percent) have less 

29 service employment than in the ROI as a whole. 

30 

31 3.13.2.2 Unemployment 

32 

33 Unemployment rates have varied across the counties in the ROI (Table 3-24). Over the 10-year 

34 period 1999 to 2008, the average rates in Brunswick and Pender Counties were 5.4 percent and 

35 5.3 percent, respectively, with a lower rate of 4.5 percent in Hanover County. The average rate 
3-113 

Table 3-23 ROI Employment in 2006 

Industry Brunswick County % of Total New Hanover County % of Total Pender County % of Total Region of Influence % o

Tota

Agriculturea 710 3.0 232 0.3 1919 19.4 2861 2.4 Mining 60 0.2 60 0.1 60 0.6 180 0.1 Construction 3024 12.9 7314 8.3 1138 11.5 11,476 9.5 Manufacturing 1942 8.3 5424 6.2 1014 10.3 8380 6.9 Transportation and Public Utilities 

1749 7.5 2633 3.0 133 1.3 4515 3.7 

Wholesale and Retail Trade 

4387 18.7 18,883 21.5 2373 24.0 25,643 21.2 

Finance, Insurance, and Real Estate 

1984 8.5 5733 6.5 257 2.6 7974 6.6 

Services 9586 40.9 47,383 54.0 2982 30.2 59,952 49.6 Other 5 0.0 29 0.1 10 0.1 44 0.0 Total 23,446 (100) 87,679 (100) 9886 (100) 120,803 (100a Agricultural employment includes 2007 data for hired farmworkers. 

Sources: USCB, 2009c; USDA, 2009. 
3-114 

Table 3-24 ROI Unemployment Rates (percent) 

Location 1999−2008 2008 2009a

Brunswick County 5.4 6.6 12.1 

New Hanover County 4.5 5.3 9.2 

Pender County 5.3 6.2 11.7 

ROI 4.8 5.8 10.4 

North Carolina 5.2 6.3 6.3 

a

 Rates for 2009 are the average for January and February. 

Sources: DOL, 2009a−d). 

1 

2 in the ROI over this period was 4.8 percent, lower than the average rate for the State of 

3 5.2 percent. Unemployment rates for the first two months of 2009 contrast markedly with rates 

4 for 2008 as a whole; in Brunswick and Pender Counties, unemployment rates increased to 

5 12.1 and 11.7 percent, respectively, while in New Hanover County the rate reached 9.2 percent. 

6 The average rate for the ROI (10.4 percent) during this period was higher than the 

7 corresponding average rates for 2008, while the rate for the State (6.3 percent) remained the 

8 same. 

9 

10 3.13.2.3 Income 

11 

12 Personal income in the ROI stood at $10.8 billion in 2006 and has grown at an annual average 

rate of 3.5 percent over the period 1997 to 2006 (Table 3-25).17 13 ROI personal income per capita 

14 also rose over the same period, but at a slower rate of 1.0 percent, increasing from $29,783 to 

15 $32,897. Per capita incomes were higher in New Hanover County ($35,862) and in Brunswick 

16 County ($30,007) in 2006 than in Pender County ($25,361). Although personal income and per 

17 capita income growth rates in the ROI have been higher than for the State as a whole, personal 

18 income per capita was slightly higher in the State ($34,310) in 2006 than in the ROI. 

19 

20 The median value of owner-occupied housing in the three-county ROI over the period 

21 2006-2008 was $178,567 (USCB, 2009d). 

22 

23 3.13.3 Housing Resources and Community and Social Services 

24 

25 This section describes housing and social services in the ROI, including schools, hospitals and 

26 nursing homes, law enforcement, and firefighting.

27 

28 3.13.3.1 Housing 

29 

30 Between 2005 and 2007, nearly 196,000 housing units were located in the three counties on 

31 average, with more than half of these located in New Hanover County, and another third in 

32 Brunswick County (Table 3-26). The vast majority of housing units in the region are single33 family structures, but the number of multifamily structures is increasing as the region develops 

 

17 All direct income and direct sales tax impact estimates are provided in 2008 dollars.
3-115 

Table 3-25 ROI and State Personal Income 

Location 1997 2006 

Annual Average 

Growth, 1997-

2006 (%) 

Brunswick County 

 Total incomea 1.7 2.8 5.1 

 Per capita income 25,939 30,007 1.4 

 Median household income − 45,596b −

New Hanover County 

 Total incomea 5.0 6.7 3.1 

 Per capita income 32,406 35,862 1.0 

 Median household income − 49,068b −

Pender County 

 Total incomea 1.0 1.3 2.7 

 Per capita income 19,383 25,361 0.4 

 Median household income − 42,630b −

ROI 

 Total incomea 7.7 10.8 3.5 

 Per capita income 29,783 32,897 1.0 

 Median household income − 45,765b −

North Carolina 

 Total incomea 180.2 286.0 2.4 

 Per capita income 31,447 34,310 0.9 

 Median household income − 46,107b − a

 Billion 2008 dollars.

b

 2006−2008 three-year average 

Source: DOC, 2009; USCB, 2009d. 

1 

2 (GLE, 2008). Vacancy rates varied significantly across the three counties, from 42 percent in 

3 Brunswick County, which had 15,000 seasonal, recreational, or occasional-use units standing 

4 vacant at the time of the 2000 Census, 24 percent in Pender County, and 17 percent in New 

5 Hanover County. Owner-occupied units comprise 71 and 78 percent of the occupied units in 

6 Brunswick and Pender Counties, respectively, but only 63 percent of the occupied units in 

7 New Hanover County, reflecting the concentration of seasonal and recreational activities in the 

8 ROI. 

9 

10 Housing density in the ROI was 38.9 units per square kilometer (100.8 units per square mile) on 

11 average during the period 2005–2007, compared with 32.6 units per square kilometer 

12 (84.7 units per square mile) for the State. There were 182.1 units per square kilometer 
3-116 

1 (471.8 units per square mile) in New Hanover County, with lower densities in Brunswick County 

2 (32.6 units per square kilometer [84.5 units per square mile]) and Pender County (11.1 units per 

3 square kilometer [28.7 units per square mile]) (USCB, 2009a). 

4 

5 Housing stock in the ROI as a whole grew at an annual rate of 3.0 percent over the period 

6 2000 to 2005–2007, with 43,840 new units added to the existing housing stock in the ROI 

7 (Table 3-26). With an overall vacancy rate of 27 percent, there were 52,749 vacant housing 

8 units in the ROI in 2005–2007, of which 11,199 (5206 in Brunswick County, 5015 in 

9 New Hanover County, and 978 in Pender County) are expected to be rental units available to 

10 construction workers at the proposed GLE Facility. 

11 

12 New Hanover County has the highest housing values in the ROI, with a median value of 

13 $228,400 over the three-year period 2006-2008 for owner-occupied units (USCB, 2009d). The 

14 median values in Brunswick and Pender Counties were $178,100 and $129,200, respectively. 

15 

16 3.13.3.2 Schools 

17 

18 The ROI has a total of 90 public and private elementary, middle, and high schools, the majority 

19 of which are in the Brunswick County, New Hanover County and Pender County school districts. 

20 In addition, the University of North Carolina at Wilmington, Brunswick Community College, and 

21 Cape Fear Community College are located in the region (NCES, 2009). Table 3-27 provides 

22 summary statistics for the schools in the three county school districts, including enrollment, 

23 educational staffing and two indices of educational quality – student−teacher ratios and levels of 

24 service. Of the 90 schools in the region, only one is within a 6.4 kilometer (4-mile) radius of the 

25 proposed GLE site, the Wrightsboro Elementary School, while 21 schools are within a 

26 12.8-kilometer (8-mile) radius of the site (GLE, 2008). 

27 

28 3.13.3.3 Public Safety 

29 

30 The principal law enforcement agency in New Hanover County is the New Hanover County 

31 Sheriff’s Office, which in 2007 had 275 officers providing law enforcement services, including 

32 provision in the unincorporated areas in the vicinity of the proposed GLE Facility (Table 3-28). 

33 

34 Several State, county, and local police departments provide law enforcement in the ROI, 

35 including the City of Wilmington police department, which employs 252 law enforcement 

36 officers. Other counties in the region have a total of 157 full-time officers – 108 in Brunswick 

37 County and 49 in Pender County. 

38 

39 Two fire departments in the ROI, the Wilmington Fire Department and the New Hanover County 

40 Fire Department, have 228 career firefighters (Table 3-28). The firefighting service provider 

41 closest to the Wilmington Site is the Castle Hayne Volunteer Fire & Rescue, with one full-time 

42 firefighter and 10 volunteer firefighters equipped with two pumper trucks, two water trucks, 

43 one squad truck, and one heavy rescue truck (GLE, 2008). If the Castle Hayne Volunteer 

44 Fire & Rescue would need additional assistance in the event of an incident at the Wilmington 

45 Site, an existing mutual aid agreement among Castle Hayne Fire Volunteer Fire & Rescue 

46 (GLE, 2008) and the six other fire departments in the county would provide additional support. 
3-117 

Table 3-26 ROI Housing Characteristics 

Parameter 2000 2005–2007b

Brunswick County 

Owner-occupied 25,013 29,934 

Rental 5425 12,381 

Vacant units 20,993 30,703 

 Seasonal and recreational use 15,540 NAa

Total units 51,431 73,018 

Median Value of Owner-Occupied Units $178,100c

New Hanover County 

Owner-occupied 44,109 51,184 

Rental 24,074 30,330 

Vacant units 11,433 16,150 

 Seasonal and Recreational Use 4387 NAa

Total units 79,616 97,664 

Median Value of Owner-Occupied Units $228,400c

Pender County 

Owner-occupied 13,260 14,960 

Rental 2794 4147 

Vacant units 4744 5896 

 Seasonal and recreational use 2881 NAa

Total units 20,798 25,003 

Median Value of Owner-Occupied Units $129,200c

ROI Total 

Owner-occupied 82,382 96,078 

Rental 32,293 46,858 

Vacant units 37,170 52,749 

 Seasonal and recreational use 22,808 NAa

Total units 151,845 195,685 

Median Value of Owner-Occupied Units $178,567c

a

 NA = not available. 

b

 2005−2007, three-year average. c

 2006−2008, three-year average. 

Sources: USCB, 2009a,b,d. 
3-118 

Table 3-27 School District Data for the ROI in 2007 

Location Number of 

Students 

Number of 

Teachers 

StudentTeacher Ratio Level of 

Servicea

Brunswick County 11,749 836 14.1 9.5 

Hanover County 24,001 1763 13.6 9.7 

Pender County 7889 572 13.8 12.5 

ROI 43,639 3170 13.8 10.0 

a

 Number of teachers per 1000 population. 

Source: NCES, 2009. 

Table 3-28 Public Safety Employment in the ROI in 2009 

Location Number of 

Police Officers 

Level of 

Servicea

Number of 

Firefightersb

Level of 

Servicea

Brunswick County 108 1.2 206 2.3 

Hanover County 275 1.5 22 0.1 

Pender County 49 1.1 0 0.0 

ROI 432 1.4 228 0.7 

a

 Number per 1000 population. 

b

 Number does not include volunteers. 

Sources: FBI, 2009; FireDepartments.net, 2009. 

1 

2 3.13.4 Tax Structure and Distribution 

3 

4 The principal sources of tax revenues in the ROI are taxes on real estate and personal property 

5 and include taxes levied at the county and municipal level, with tax rates varying between taxing 

6 jurisdictions as a result (NCDOR, 2009). In 2009, county property tax rates for New Hanover 

7 County and Pender County were $0.45 and $0.65 per $100 of appraised valuation, respectively, 

8 while the rate in Brunswick County was $0.31. The municipal tax rate in Wilmington was $0.33 

9 per $100, levied in addition to county property taxes (NCDOR, 2009). Personal income taxes 

10 are levied by the State and vary depending on income. A corporate income tax rate of 

11 6.9 percent is levied by the State, which also collects sales and use tax of 4.25 percent of sales, 

12 in addition to local sales and use tax rates in most areas of 2.5 percent (NCDOR, 2009). 

13 

14 3.14 Environmental Justice 

15 

16 On February 11, 1994, the President signed Executive Order 12898 “Federal Actions to 

17 Address Environmental Justice in Minority Populations and Low-Income Populations,” which 

18 directs all Federal agencies to develop strategies for considering environmental justice in their 

19 programs, policies, and activities. Environmental justice is described in the Executive Order as 

20 “identifying and addressing, as appropriate, disproportionately high and adverse human health 

21 or environmental effects of its programs, policies, and activities on minority populations and 

22 low-income populations.” On December 10, 1997, the Council on Environmental Quality (CEQ) 
3-119 

1 issued “Environmental Justice Guidance under the National Environmental Policy Act” (NEPA) 

2 (CEQ, 1997). In addition to following general guidelines on the evaluation of environmental 

3 analyses set forth in the document Environmental Review Guidance for Licensing Actions 

4 Associated with NMSS Programs (NUREG-1748) (NRC, 2003), the NRC has issued a final 

5 policy statement on the “Treatment of Environmental Justice Matters in NRC Regulatory and 

6 Licensing Actions” (69 FR 52040; August 24, 2004) and environmental justice procedures to be 

7 followed in NEPA documents prepared by the NRC’s Office of Nuclear Material Safety and 

8 Safeguards (NRC, 2004a). 

9 

10 Data on minority and low-income populations within a 6.4-kilometer (4-mile) radius of the 

11 proposed GLE site were derived from the 2000 U.S. Census (see Appendix G). The 

12 6.4-kilometer (4-mile) radius is consistent with the NRC final policy statement on the treatment 

13 of environmental justice matters (69 FR 52040; August 24, 2004). This area includes a total of 

14 15 Census block groups, including one in Brunswick County, 10 in New Hanover County, the 

15 location of the proposed GLE Facility, and four in Pender County (USBC, 2009a). To determine 

16 whether environmental justice will have to be considered in greater detail, the NRC staff 

17 compared the percentage of minority and low-income populations in Census block groups in the 

18 area being assessed with the State and county percentages. If the minority or low-income 

19 population in a given tract exceeds 50 percent or is 20 percentage points or more greater than 

20 the State or county percentage, environmental justice will have to be considered in greater 

21 detail. Generally, the NRC staff considers differences greater than 20 percentage points to be 

22 significant. 

23 

24 3.14.1 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). Minority 

28 individuals are persons who identify themselves as members of the following population groups: 

29 Black or African American, American Indian or Alaska Native, Asian, Native Hawaiian or other 

30 Pacific Islander, some other race, and two or more races (meaning individuals who identified 

31 themselves on the 2000 Census form as being a member of two or more races, for example, 

32 White and Hispanic), and Hispanic or Latino. The 2000 Census allowed individuals the option 

33 of identifying themselves in one or more race categories, thereby creating the multiracial census 

34 category of “two or more races.” They are generally counted as part of the minority group they 

35 identified. 

36 

37 Minority populations can be determined by subtracting White, not Hispanic or Latino populations 

38 from the total population. Figure 3-22 identifies the three Census block groups within a 

39 6.4-kilometer (4-mile) radius of the proposed GLE site that contain minority populations. Two 

40 block groups had minority populations that were more than 20 percentage points higher than the 

41 respective county average, while one Census block group had a minority population that was 

42 also more than 20 percentage points higher than the State average. Two of these Census block 

43 groups also had a minority population that exceeded 50 percent of the total population. 

44 Table 3-29 presents data for minority populations for the 6.4-kilometer (4-mile) area, for each 

45 county, and for the State. Appendix G presents the data for the 15 Census block groups that 

46 completely or partially fall within the 6.4-kilometer (4-mile) radius. 
3-120 

Figure 3-22 Census Block Groups within a 6.4-kilometer (4-mile) Radius of the Proposed 

GLE Facility with Minority Populations that Exceed 50 Percent of Total Population or 

Exceed State and County Averages by More than 20 Percentage Points
3-121 

1 3.14.2 Low-Income Populations 

2 

3 Low-income populations are those that fall below the poverty level identified by the U.S. Census 

4 Bureau, including variations by family size and composition. If the total income for a family or 

5 unrelated individual falls below the relevant poverty threshold, then the family or unrelated 

6 individual is classified as being “below the poverty level.” For example, in 1999, the most recent 

7 year for which census block group data on poverty were available, the poverty threshold for a 

8 family of five with three children below the age of 18 was $19,882. For any given family below 

9 the poverty line, all family members are considered to be below the poverty line for the purposes 

10 of analysis 

11 

12 Figure 3-23 identifies Census block groups within a 6.4-kilometer (4-mile) radius of the 

13 proposed GLE site that contain low-income populations in excess of the threshold criteria. In 

14 one Census block group, the low-income population was more than 20 percentage points higher 

15 than both the State and county average. Table 3-29 presents data for low-income populations 

16 for the 6.4-kilometer [4-mile area]), for each county, and for the State. Appendix G presents the 

17 data for the 15 Census block groups that completely or partially fall within the 6.4-kilometer 

18 (4-mile) radius. 

19 

Table 3-29 Minority and Low-Income Populations within a 6.4-kilometer (4-mile) 

Radius of the Proposed GLE Site 

 4-mile Radius 

County Total 

Populationa

Minority 

Population 

Percent 

Minority 

County 

Percent 

Minority 

State 

Percent 

Minority 

Brunswick County 2030 926 45.6 20.4 

New Hanover County 15,725 3881 24.7 22.1 

Pender County 9044 2753 30.6 30.9 

32.6 

 4-mile Radius 

County Total 

Populationb

LowIncome 

Population 

Percent 

LowIncome 

County 

Percent 

Low-Income 

State 

Percent 

Low-Income 

Brunswick County 1952 283 14.5 12.6 

New Hanover County 15,217 1488 9.8 13.1 

Pender County 8948 1430 16.0 13.6 

12.3 

a

 2000 data. 

b

 1999 data. 

Source: USCB, 2009a. 
3-122 

Figure 3-23 Census Block Groups within a 6.4-kilometer (4-mile) Radius of the Proposed 

GLE Facility with Low-Income Populations that Exceed 50 Percent of the Total Population 

or Exceed State and County Averages by More Than 20 Percentage Points 
3-123 

1 3.14.3 Resource Dependencies and Vulnerabilities of Minority and Low-Income 

2 Populations 

3 

4 In some cases, minority and low-income groups may rely on natural resources for their 

5 subsistence and to support unique cultural practices. Differential patterns of consumption of 

6 natural resources should be considered (i.e., differences in rates and/or pattern of fish, 

7 vegetable, water, and/or wildlife consumption among groups defined by demographic factors 

8 such as socioeconomic status, race, ethnicity, and/or cultural attributes). 

9 

10 In some circumstances, these groups could be unusually vulnerable to impacts from the 

11 proposed action. In particular, higher participation in outdoor recreation, home gardening, and 

12 subsistence fishing may increase exposure risk to low-income and minority groups through 

13 inhalation or ingestion through various environmental pathways. 

14 

15 Potential resource dependencies were sought in the course of public meetings and other 

16 information supplied by the Hispanic/Latino and African American/Black communities in 

17 meetings with the NRC staff. Letters were also sent to local Federally recognized American 

18 Indian tribes determine any potential resource dependencies. These letters described the 

19 construction and operation of the proposed GLE Facility, solicited their concerns on the project, 

20 and inquired about whether the American Indian tribes desired to participate in the Section 106 

21 consultation process (see Appendix B). The Coharie Indian Tribe has indicated that there are 

22 no historic properties in the area of potential effects that could have cultural or religious 

23 significance to them. Currently, very few American Indians live in the vicinity of the Wilmington 

24 Site. 

25 

26 In addition, the NRC staff examined data provided by the State of North Carolina concerning the 

27 health status of the general population in Brunswick County, New Hanover County, and Pender 

28 County (Table 3-30). No exceptional health problems were found among residents in the 

29 Wilmington area. It was not possible to identify any unusual incidences of birth defects, chronic 

30 diseases, or cancer clusters at the county level, the smallest area for which published health 

31 information is available. Age-adjusted incidence of cancer is slightly lower in Pender County 

32 than elsewhere in the three-county area; rates in each county are lower than in North Carolina 

33 as a whole. The income and ethnicity of individuals with chronic diseases are not available. 

34 
3-124 

Table 3-30 Selected Health Statistics for Counties near the 

Proposed GLE Facility 

Brunswick 

County 

New Hanover 

County 

Pender 

County 

North 

Carolina 

Age-adjusted cancer Incidence rates 

(per 100,000 population), 2005 

474.0 491.4 432.0 511.8 

Age-adjusted cancer death rates, 

(per 10,000 population), 2002-2006 

196.8 197.6 217.5 195.8 

Age-adjusted major causes of death 

(per 100,000 population), 2006 

 

 Heart disease 194.0 203.0 215.8 198.7 

 Trachea, bronchus, or lung cancer 58.8 65.0 62.3 60.4 

 Cerebrovascular disease 56.8 40.8 46.1 53.2 

 Chronic lower respiratory diseases 66.4 37.1 35.7 46.4 

Source: NC-CATCH, 2009.

1 

2 3.15 References 

3 

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6 

7 (ASA, 1983) Acoustical Society of America. “American National Standard Specification for 

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9 

10 (ASA, 1985) Acoustical Society of America. “American National Standard Specification for 

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13 (Ashley and Rachels, 2005) Ashley, K.W., and R.T. Rachels. “Cape Fear River Basin 

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30 

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34 

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38 

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42 

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47 
3-126 

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4 

5 (Cowardin et al., 1979) Cowardin, L.M, V. Carter, F.C. Golet, and E.T. LaRoe. “Classification of 

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8 

9 (CPC, 2008a) Center for Plant Conservation. “CPC National Collection Plant Profile Solidago 

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12 

13 (CPC, 2008b) Center for Plant Conservation. “CPC National Collection Plant Profile Stylisma 

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29 (New Hanover County, 2009a) New Hanover County. “County Code of Ordinances, 

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36 (New Hanover County, 2009c) New Hanover County Planning Department. Letter from C. 

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40 (NHC, 2009) National Hurricane Center. “Hurricane Preparedness: Return Periods.” 

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17 (NRC, 2003) U.S. Nuclear Regulatory Commission. “Environmental Review Guidance for 

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22 

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26 

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35 

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43 (RTI, 2008) Research Triangle Institute. “2006-2007 Report of Organic Compounds in 

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26 

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29 

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34 format=US-25T > (Accessed January 26, 2010). 

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45 October 2, 2009). 

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10 Surrounding Areas.” Working draft of April 7, 2008. <http://www.herbarium.unc.edu/ 

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12 

13 (Whigham and Brinson, 1990). Whigham, D.F., and M.M. Brinson. “Wetland Value Impacts.” 

14 Wetlands and Shallow Continental Water Bodies 1:401−421. 

15 

16 (Wilde-Ramsing, 1978) Wilde-Ramsing, M. “A Report on the New Hanover County 

17 Archaeological Survey: A C.E.T.A. Project, August 1977-July 1978.” North Carolina Department 

18 of Cultural Resources, Office of Archives and History, Division of Historical Resources, 

19 North Carolina Office of State Archaeology. 
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15 
4-1 

1 4 ENVIRONMENTAL IMPACTS 

2 

3 4.1 Introduction 

4 

5 This chapter presents the potential impacts associated with the preconstruction activities, 

6 construction, operations, and decommissioning of the proposed General Electric (GE)-Hitachi 

7 Global Laser Enrichment LLC (GLE) Facility. For the proposed action, this draft Environmental 

8 Impact Statement (EIS) considers impacts from construction activities, normal operations, 

9 credible accidents, and cumulative impacts and resource commitments. The impacts 

10 associated with preconstruction activities are also discussed, although, as discussed in 

11 Section 4.2, preconstruction activities are not part of the proposed action. The chapter is 

12 organized by environmentally affected areas (i.e., air, water, noise, public and occupational 

13 health, etc.), based on the descriptions of preconstruction activities and the proposed action that 

14 are included in Section 2.1 of this draft EIS. Impacts on each environmentally affected area are 

15 divided into three categories: preconstruction and construction, operations, and 

16 decontamination and decommissioning. 

17 

18 Within each resource area, mitigation measures identified by GLE and U.S. Nuclear Regulatory 

19 Commission (NRC) staff are disclosed. While the NRC cannot impose mitigation outside its 

20 regulatory authority under the Atomic Energy Act, the NRC staff has identified mitigation 

21 measures within this chapter that could potentially reduce the impacts of the proposed action. 

22 For the purposes of the National Environmental Policy Act (NEPA) per the U.S. Code of Federal 

23 Regulations (CFR) Title 10, “Energy,” 10 CFR 51.71(d), and 51.80(a), the NRC is disclosing 

24 measures that could potentially reduce or avoid environmental impacts of the proposed action. 

25 These additional mitigation measures are not requirements being imposed upon GLE, and they 

26 are presented in Table 5-2. Any mitigation measures identified by GLE and proposed for 

27 implementation within the Environmental Report (ER) (GLE, 2008) were factored into the NRC 

28 staff’s environmental impact analysis and are presented in Table 5-1. 

29 

30 Section 4.2 discusses the preconstruction activities and the proposed action under 

31 consideration in this draft EIS – namely, the construction and operation of the proposed 

32 GLE Facility at the existing General Electric (GE) site in Wilmington, North Carolina. Because 

33 decommissioning is not expected to occur until 40 years after the license is issued, the 

34 decontamination and decommissioning impacts discussed in Section 4.2.17 are preliminary, or 

35 estimated, for the proposed GLE Facility. Within 12 months of its decision to cease enrichment 

36 activities, GLE will submit a decommissioning plan to the NRC in accordance with 10 CFR 

37 70.38, and would begin the activities described in the decommissioning plan after approval by 

38 the NRC. The proposed activities in the decommissioning plan will be subject to further NEPA 

39 review, as appropriate, at that time. 

40 

41 In addition, this chapter discusses the potential cumulative impacts (Section 4.3) and impacts of 

42 the no-action alternative (Section 4.4). For the purposes of this draft EIS, the assessment of the 

43 cumulative impacts of the no-action alternative assumes that certain preconstruction activities 

44 have occurred, because these preconstruction activities are expected to occur regardless of 

45 whether a license for construction and operation of the proposed facility is granted by the NRC. 
4-2 

1 

2 

3 Environmental impacts may be radiological or non-radiological. Radiological impacts include 

4 radiation doses to the public and workers from the routine operations, transportation, potential 

5 accidents, and decommissioning and environmental impacts from potential releases in the air, 

6 soil, or water. Non-radiological impacts include chemical hazards, emissions (e.g., vehicle 

7 fumes), occupational accidents and injuries (e.g., vehicle collisions), and workplace accidents. 

8 

9 The analyses in this chapter are based on the assumption that a licensing decision would be 

10 made in late 2011, construction (if authorized) would start in 2011, and license termination 

11 would occur in 2051. Subsequently, the Commission’s Notice of Hearing and Commission 

12 Order (75 FR 1819) specified that a licensing decision be made within 30 months of the Order 

13 (i.e., June 2012). Thus, the NRC staff currently expects that a licensing decision will be made in 

14 2012, construction will begin in 2012, and that termination of the 40-year license, if granted, will 

15 occur in 2052. The NRC staff expects that the dates for start-up and final construction 

16 (2013-2017) and full facility operations (2017) will remain unchanged. The NRC staff expects 

17 that any resulting changes in the licensing and construction schedule would cause slight 

18 changes to certain analyses (e.g., air quality, socioeconomics, and cost–benefit) but would not 

19 affect the conclusions regarding impacts on these resource areas. Any necessary changes to 

20 the analyses will be reflected in the final EIS. 

21 

22 4.2 Preconstruction Activities and the Proposed Action 

23 

24 As described in Section 2.1 of this draft EIS, the proposed action is the construction, operation, 

25 and decontamination and decommissioning of the proposed GLE Facility. Under the proposed 

26 action, the NRC would issue a license to GE-Hitachi Global Laser Enrichment LLC in 

27 accordance with the requirements of 10 CFR Parts 70, 40, and 30 to possess and use 

28 by-product source and special nuclear material. 

29 

30 The NRC has granted an exemption (NRC, 2009a) for GLE to conduct certain preconstruction 

31 activities without an NRC license to construct and operate the proposed GLE facility. The NRC 

32 staff concluded that the request to perform these activities is authorized by law, will not 

33 endanger life or property or common defense and security, and is in the public interest. The 

34 approved preconstruction activities include: 

35 

36 • Clearing of approximately 40 hectares (100 acres) for the proposed GLE Facility; 

37 

38 • Site grading and erosion control; 

The NRC defines three significance levels for rating impacts on a resource (NRC, 2003): 

• Small impact: Environmental effects are not detectable or are so minor that they will neither 

destabilize nor noticeably alter any important attribute of the resource. 

• Moderate impact: Environmental effects are sufficient to alter noticeably, but not to destabilize, 

important attributes of the resource. 

• Large impact: Environmental effects are clearly noticeable and are sufficient to destabilize 

important attributes of the resource. 
4-3 

1 • Installation of a storm retention system; 

2 

3 • Construction of main access roadway and guardhouse(s); 

4 

5 • Placement of utilities (electricity, potable water, process water, water for fire suppression, 

6 sanitary sewer, and natural gas); 

7 

8 • Construction of parking lots and minor roadways; and 

9 

10 • Construction of administrative building(s) (GLE, 2009b). 

11 

12 No core production facilities would be constructed as part of the preconstruction activities. 

13 Because preconstruction and construction activities are closely related, this section discusses 

14 impacts of preconstruction activities, construction, and operations, although preconstruction 

15 activities are not part of the proposed action. Because of the difficulty in separating the impacts 

16 of preconstruction and construction, these impacts are evaluated together and an estimate is 

17 provided regarding the apportionment of impacts between preconstruction activities (authorized 

18 under the exemption) and construction as defined in 10 CFR 51.4. Therefore, the impacting 

19 activities are organized into three phases: 

20 

21 • preconstruction and construction of new facilities 

22 

23 • facility operations 

24 

25 • decontamination and decommissioning 

26 

27 4.2.1 Land Use Impacts 

28 

29 Land use impacts occur when an area is committed in a way that precludes all other future land 

30 use or alters the land use of adjacent properties. Land use impacts can occur in the short term 

31 or in the long term. Land use impacts also occur when activities take place that are 

32 incompatible with the zoning designated by county or State officials. Most of the project area 

33 currently contains mixed pine forest. The project area is bordered to the east by GE’s Fuel 

34 Manufacturing Operation (FMO) plant and aircraft engine plant. To the west is the Northeast 

35 Cape Fear River. Residential developments are located to the northeast, east, and south. The 

36 project area under consideration is zoned by New Hanover County for heavy industrial use. 

37 West of the Northeast Cape Fear River is the L.V. Sutton Power Plant. The areas to the 

38 northeast, east, and south are zoned for residential development. The construction and 

39 operation of the proposed GLE Facility are consistent with current zoning. The entire project 

40 area is owned by GE. The following sections discuss land use impacts resulting from various 

41 phases of the project. 

42 

43 4.2.1.1 Preconstruction and Construction Activities 

44 

45 As described in Section 1.4.1, preconstruction activities include clearing and grading of the land, 

46 vegetation removal, improvement of existing roads, and construction of support structures, 

47 among other activities. Preconstruction activities will alter the current land use of undeveloped 

48 mixed pine forest. Workers will clear and haul the trees from the property. Modification of the 
4-4 

1 current land use resulting from preconstruction activities does not represent a major impact. 

2 Open undeveloped land is found in the immediate vicinity of the project. The alteration of the 

3 land use is consistent with current zoning. Preconstruction activities are not expected to affect 

4 surrounding land use. 

5 

6 Construction consists of erecting the main facilities at the proposed plant and installing the main 

7 plant components. Most activities would occur on the Wilmington Site, which has restricted 

8 access. Potential impacts outside of the property boundary could result from construction 

9 traffic. These impacts are discussed in Section 4.2.10. Construction activities will be temporary 

10 (see Section 2.1.5). The project area is identified in the Wilmington-New Hanover County 

11 Coastal Area Management Act (CAMA) as a wetland and aquifer resource protection area. The 

12 designation as a wetland resource protection area is intended to limit the destruction of 

13 wetlands. No wetlands remain within the footprint of the project. Additionally, the aquifer would 

14 not be affected by construction activities. County officials have agreed that the resources 

15 identified in the CAMA plan are being appropriately considered and that construction and 

16 operation of the facility are not expected to impact these resources (New Hanover 

17 County, 2009a). 

18 

19 For the reasons discussed above, land use impacts from preconstruction and construction 

20 activities would be considered to be SMALL. The estimated relative contributions to impacts are 

21 50 percent during preconstruction activities and 50 percent during construction. 

22 

23 4.2.1.2 Facility Operations 

24 

25 Operation of the proposed GLE Facility will affect land use. The operation of a uranium 

26 enrichment plant represents a departure from the current land use of undeveloped forest. The 

27 plant would operate on the existing Wilmington Site in an area that is zoned for heavy industrial 

28 use. No conflict exists between operation of an enrichment plant and the zoning. It is possible 

29 that operation of the plant could have an effect on the low-density residential use on properties 

30 to the north, east, and south. However, these residential developments already exist in close 

31 proximity to the FMO plant, the GE aircraft engine plant, and the L.V. Sutton Power Plant. The 

32 operation of these facilities has not altered or affected surrounding land use. Residential 

33 developments continue to be planned for the area (New Hanover County, 2009a). The greatest 

34 potential for impacts on land use would occur during operations because it would occur over the 

35 longest period of time. However, land use associated with operation of an enrichment facility is 

36 consistent with other industrial development in the immediate area, which has not altered the 

37 surrounding land use. Therefore, overall impacts on land use from operations are expected to 

38 be SMALL. 

39 

40 4.2.1.3 Mitigation Measures 

41 

42 To mitigate land use impacts, GLE proposes to use existing service road routes and utility 

43 rights-of-way (to the fullest extent practicable) to minimize the need for clearing additional 

44 wooded areas, and to use existing wastewater treatment and solid waste management 

45 infrastructure (to the fullest extent practicable) to reduce the total area required for the proposed 

46 GLE Facility. In addition, the New Hanover County Soil Erosion and Sedimentation Control 

47 Ordinance identifies best management practices (BMPs) for construction in New Hanover 

48 County (New Hanover County, 2007). The BMPs are discussed in detail in Section 4.2.5.3. 
4-5 

1 BMPs for construction would help moderate the short-term land use effects associated with 

2 preconstruction and construction activities. BMPs for controlling waste disposal, erosion, and 

3 runoff would help restrict the effect of facility operations on surrounding land use. 

4 

5 4.2.2 Historic and Cultural Resources Impacts 

6 

7 The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects 

8 of their undertakings on historic properties. Historic properties are defined as resources that are 

9 eligible for listing on the NRHP. The criteria for eligibility are listed in Title 36, “Parks, Forests, 

10 and Public Property,” Part 60, Section 4, “Criteria for Evaluation,” of the U.S. Code of Federal 

11 Regulations (36 CFR Part 60.4) and include (1) association with significant events in history; 

12 (2) association with the lives of persons significant in the past; (3) embodies distinctive 

13 characteristics of type, period, or construction, or (4) sites or places that have yielded or are 

14 likely to yield important information (ACHP, 2008). The historic preservation review process 

15 (Section 106 of the NHPA) is outlined in regulations issued by the Advisory Council on Historic 

16 Preservation (ACHP) in Title 36, “Parks, Forests, and Public Property,” Part 800, “Protection of 

17 Historic Properties,” of the U.S. Code of Federal Regulations (36 CFR Part 800). The NRC is 

18 coordinating its Section 106 review through NEPA per 36 CFR 800.8(c). The Area of Potential 

19 Effect for the project is defined as the 106-hectare (263-acre) study area. The NRC has 

20 consulted with the North Carolina State Historic Preservation Office (SHPO), the ACHP, and 

21 several American Indian tribes. 

22 

23 Section 106 of the NHPA identifies the process for considering whether a project will affect a 

24 significant cultural resource. The Section 106 process requires consultation between the lead 

25 Federal agency and the SHPO, which is the custodian of information on cultural resources for 

26 the state. The Section 106 process also requires that Native American groups who have 

27 aboriginal ties to the project area be consulted to determine if resources important to the tribe 

28 are present. 

29 

30 Cultural resources, especially archaeological sites, are sensitive to disturbance and are 

31 nonrenewable. Much of the information possessed in an archaeological site is derived from the 

32 spatial relationships between soil layers and artifacts. Once these spatial relationships are 

33 altered, they can never be reclaimed. As a result, the greatest threat to archaeological 

34 resources are ground-disturbing activities that will alter the spatial relationships. Most ground35 disturbing activities would occur during preconstruction activities, when the site is cleared and 

36 prepared for construction. 

37 

38 4.2.2.1 Preconstruction and Construction Activities 

39 

40 Preconstruction activities have the potential to impact historic and cultural resources. Ground41 clearing activities such as vegetation removal, grading and recontouring for drainage have the 

42 greatest potential for impacting historic and cultural resources. Much of the ground disturbance 

43 expected for the proposed GLE Facility would occur during preconstruction activities. The area 

44 that would be affected by preconstruction activities was surveyed for historic and cultural 

45 resources in 2008. Site 31NH801 was identified during the survey and was determined to be 

46 eligible for listing on the NRHP (GLE, 2008; NCDCR, 2009). The site is located adjacent to one 

47 of the access roads that was identified in the original construction designs. GLE has 

48 reconfigured the access roads needs for the plant and will no longer develop the road adjacent 
4-6 

1 to site 31NH801 (GLE, 2009b), therefore, no impacts are expected to site 31NH801 from 

2 preconstruction or construction activities. The newly defined areas were surveyed in 2009 and 

3 no additional NRHP-eligible cultural resources were identified (ESI, 2009). 

4 

5 The North Carolina SHPO requested that it be contacted in the event of an unanticipated 

6 discovery of cultural resources during the project. The SHPO also requested that, in the event 

7 that human remains are found during project activities, the applicable procedures in North 

8 Carolina General Statute 70 Article 3 be followed (NCDCR, 2009). The statute states that when 

9 unmarked remains are encountered, work cease immediately in the vicinity of the find and that 

10 work not be allowed to continue without authorization from either the county medical examiner 

11 or the State archaeologist (N.C. General Statute 70.3(b)). GLE has developed an unexpected 

12 discovery procedure, which has been reviewed by the North Carolina SHPO. The SHPO found 

13 the procedure to be adequate (NCDCR, 2010). 

14 

15 No NRHP-eligible cultural resources are expected to be directly impacted by preconstruction 

16 activities. Construction activities would take place on ground previously disturbed by 

17 preconstruction activities. Most impacts on historic or archaeological resources would occur 

18 prior to construction. No construction activities are expected to occur in the portion of the 

19 Wilmington Site where historic and cultural resources are known to exist. If the expected 

20 construction area for the project changes during licensing, GLE would submit a supplement to 

21 its license application so that the license would accurately address the proposed NRC-licensed 

22 activities. As one part of the evaluation of such a supplement, NRC would evaluate whether the 

23 change constituted a change in the area of potential effects, and NRC would reflect that 

24 determination in its ongoing consultation with the North Carolina SHPO. If, after facility 

25 licensing, additional NRC-licensed construction is to be performed, the licensee would be 

26 required to revise the applicable licensing documents, and, where required by applicable 

27 regulations, submit an application for a license amendment. For those changes requiring an 

28 application for a license amendment, the NRC would determine an area of potential effects for 

29 the Federal action of granting the license amendment, and would consult with the SHPO as 

30 appropriate regarding the proposed amendment. 

31 

32 Overall, the impacts on historic and cultural resources from both preconstruction and 

33 construction activities would be SMALL. While there is some potential for ground disturbance to 

34 occur in previously undisturbed areas during construction, most impacts on historic and cultural 

35 resources would be expected to occur during ground clearing. Therefore, the estimated relative 

36 contributions to impacts are 95 percent during preconstruction activities and five percent during 

37 construction. 

38 

39 4.2.2.2 Facility Operations 

40 

41 Facility operations have the potential to affect historic and cultural resources; however, impacts 

42 are not expected. Operations could affect resources if expansion of the plant was deemed 

43 necessary in areas that contain historic and archaeological resources. No facility activities are 

44 expected to affect site 31NH801. The North Carolina SHPO asked to review the measures that 

45 will be taken by GLE to ensure protection and preservation of site 31NH801 from future 

46 ground-disturbing activities (NCDCR, 2009). Consultation between the NRC, North Carolina 

47 SHPO, and GLE is ongoing. The expected impact level for operations ranges from SMALL to 
4-7 

1 MODERATE. Impact levels could be reduced if a plan for site 31NH801 is developed and 

2 implemented. 

3 

4 4.2.2.3 Mitigation Measures 

5 

6 No direct impacts on historic and cultural resources are currently expected. To protect site 

7 31NH801, GLE has posted signs stating that no unauthorized excavation is permitted. GLE 

8 also proposes to maintain the current graded and vegetated state of the bank at the side of the 

9 existing gravel road (GLE, 2008). GLE has also developed internal procedural guidance for 

10 unexpected archaeological discoveries and/or human remains (GLE, 2009h). In the event that 

11 new cultural resources are discovered in the area of potential effects, GLE would implement 

12 these procedures, which include notification of certain local and State agency representatives, 

13 including the State Archaeologist. 

14 

15 4.2.3 Visual and Scenic Impacts 

16 

17 The following section discusses the potential visual impacts that could result from 

18 preconstruction activities through operation of the proposed GLE Facility. Visual impacts 

19 anticipated from the project are primarily associated with preconstruction and construction 

20 activities. Construction crews, cranes, trucks loaded with building materials, and vegetation 

21 removal represent the greatest potential for visual impacts. 

22 

23 4.2.3.1 Preconstruction and Construction Activities 

24 

25 Impacts on visual resources are possible from preconstruction activities. Currently, the project 

26 area is a mixed pine forest. As described in Section 1.4.1, actions associated with 

27 preconstruction include vegetation removal, grading, installation of utilities, and construction of 

28 support buildings, among other activities. Most visual impacts would result from vegetation 

29 removal and the increased traffic to the northern portion of the site. The vegetation screen 

30 along the northern part of the site would not be altered by preconstruction activities. The 

31 greatest visual impacts would be experienced by the four properties along Dekker Road that 

32 back onto the Wilmington Site. The increased traffic on the site access road would not be 

33 visible from Dekker Road. Increased traffic along Castle Hayne Road from construction traffic 

34 would be noticeable to users of the Castle Hayne Road and potentially I-140. These impacts 

35 would be temporary. Activities occurring within the project area would be largely out of site from 

36 Castle Hayne Road and I-140. 

37 

38 Construction activities would be concentrated on the Wilmington Site. Truck and worker traffic 

39 would increase on the site access road during construction. Visual impacts could result from 

40 the increased traffic entering the site; however, the impacts would be temporary. The main 

41 project area is surrounded by a vegetation barrier. Therefore, construction activities would be 

42 largely screened even from the residences along Dekker Road. The greatest visual impact 

43 associated with construction would be from increased traffic. Construction cranes would be 

44 visible from greater distances. However, these would only be temporary impacts. The 

45 construction cranes would be visible from I-140 and likely south of I-140 as well as Castle 

46 Hayne Road. 

47 
4-8 

1 Both preconstruction and construction activities would result in visual impacts. The estimated 

2 relative contributions to impacts are 25 percent during preconstruction activities and 75 percent 

3 during construction. Overall, the visual and scenic impact from preconstruction and construction 

4 activities would be SMALL. 

5 

6 4.2.3.2 Facility Operations 

7 

8 There is the potential for visual impacts from operations. The two most visible features of the 

9 new plant would be the water tower at 39.6 meters (130 feet) tall and a portion of the operations 

10 building referred to as the operations building tower. The operations building tower would have 

11 front and side profiles of 37 meters (120 feet) by 200 meters (660 feet). The height of the 

12 operations building tower will depend on the final process design; however, it could reach up to 

13 49 meters (160 feet) above grade. The water tower would be visible from south of I-140 and 

14 from along Castle Hayne Road. The proposed water tower is the same height as the existing 

15 water tower, the top of which would be visible from south of I-140 (see Figure 3-3). Although 

16 the operations building tower could be approximately 10 meters 930 feet) taller than the water 

17 tower, it would be visible primarily from Castle Hayne Road and from the Wooden Shoe 

18 subdivision northeast of the Wilmington Site because the proposed facility is set back further 

19 within the Wilmington Site than the existing water tower. The new water tower and the 

20 operations building tower would not represent a major alteration of the existing visual 

21 environment. Portions of the new plant may be visible from I-140. The planting of additional 

22 vegetation on the perimeter of the plant after construction may minimize visual impacts. 

23 

24 In Section 3.4, the U.S. Bureau of Land Management (BLM) Visual Resource Inventory process 

25 was applied to the study area. Based on that review, the study area was found to have low 

26 scenic quality. The environment in the project area is not unique for the area. The site of the 

27 proposed GLE Facility is adjacent to other industrial developments and will therefore not alter a 

28 pristine environment. Likewise, the project area is not in a location that is sensitive to visual 

29 intrusions. There is limited expectation that the area would be kept in a wilderness setting. 

30 

31 Operations would be expected to have visual impacts, but these impacts would not represent a 

32 major alteration from the current setting. Operational visual impacts are expected to be SMALL. 

33 

34 4.2.3.3 Mitigation Measures 

35 

36 To mitigate impacts on visual and scenic resources, GLE proposes to locate the proposed GLE 

37 Facility away from site boundaries bordering on existing development along NC133 and I-140, 

38 maintain (to the fullest width practicable) the existing tree buffer along the northeast Wilmington 

39 Site boundary to limit visibility of the proposed GLE Facility structures and access road traffic 

40 from offsite, and use exterior building colors and landscaping that soften visual impacts. 

41 Additional mitigation measures identified by NRC staff could include the planting of additional 

42 vegetation on the perimeter of the facility site to help screen the study area. 

43 

44 4.2.4 Air Quality Impacts 

45 

46 This section describes potential air quality impacts associated with construction and operation of 

47 the proposed GLE Facility in Wilmington, North Carolina. Because certain activities that can 

48 cause air quality impacts may take place in more than one of the project phases described in 
4-9 

Section 4.2 the lifespan of the GLE project is considered in four separate phases1 1 for the air 

2 quality impacts analysis: 

3 

4 • access road construction and land clearing (does not include other preconstruction 

5 activities, such as ancillary building construction) 

6 

7 • building construction (including ancillary building construction that occurs as part of 

preconstruction activities)2 8 

9 

10 • start-up and final construction (includes concurrent indoor construction with staged testing 

11 and start-up of process units as completed) 

12 

13 • facility operations 

14 

15 Air emissions from these activities were estimated using the standard emission factor 

16 references followed by air dispersion modeling to estimate concentrations at and beyond the 

17 Wilmington Site boundaries. Potential impacts from access road construction, land clearing, 

18 building construction, and start-up and final construction are presented in Section 4.2.4.1, and 

19 those from facility operations are discussed in Section 4.2.4.2. Mitigation measures for these 

20 phases are presented in Section 4.2.4.3. Potential impacts from decontamination and 

21 decommissioning are discussed in Section 4.2.17.4. Greenhouse gas (GHG) emissions are 

22 addressed in Section 4.2.18. 

23 

24 During the access road construction, land clearing, and building construction phases, the main 

25 source of emissions would be fugitive dust from soil disturbances. During the start-up and final 

26 construction phase and the operations phase, all non-radiological emissions would be small 

27 because no fossil fuels would be burned for the processes. 

28 

29 4.2.4.1 Access Road Construction, Land Clearing, and Building Construction 

30 

31 Development of the proposed GLE Facility includes access road construction, land clearing, 

32 building construction activities (erection of main GLE buildings and ancillary buildings and 

33 structures), and start-up and final construction activities (concurrent indoor construction with 

 

1

 As discussed in Section 4.1, the air impacts analysis was based on the assumption that a licensing 

decision would be made in late 2011, construction (if authorized) would start shortly after the licensing 

decision was made, and license termination would occur in 2051. The analysis also was based on the 

assumption that initial operations would begin in 2013, final construction activities would continue from 

2013 to 2017, and that full operations would be achieved in 2017. Subsequently, the Commission’s 

Notice of Hearing and Commission Order (75 FR 1819) specified that a licensing decision be made 

within 30 months of the Order (i.e., June 2012). Thus, the NRC staff currently expects that a licensing 

decision will be made in 2012, construction will begin in 2012, and that termination of the 40-year 

license, if granted, will occur in 2052. The NRC staff expects that the dates for start-up and final 

construction (2013-2017) and full facility operations (2017) will remain unchanged. These schedule 

changes, which will be reflected in the final EIS, are expected to cause slight changes to the air impact 

analysis because of seasonal effects, but are not expected to change any of the impacts conclusions. 

2

 For the purposes of estimating emission inventories and air quality modeling, the construction of 

ancillary structures, which falls under preconstruction, is grouped into building construction. 
4-10 

1 staged testing and start-up of process units as completed). Construction would last almost 

2 seven years, but facility operations would begin in 2013. Potential air quality impacts from 

3 construction activities of the proposed GLE Facility would be the highest during this initial 

4 two-year period, which would include a high level of soil disturbance by heavy construction 

5 equipment. For air quality impact analysis, it is assumed that new onsite access road 

6 construction would begin in early 2011, followed by land clearing from mid- to late 2011. 

7 Because these activities have been authorized by exemption (see Section 1.4.1), changes in 

8 the licensing schedule discussed in Section 4.1 are not expected to change the schedule of 

9 these preconstruction activities. 

10 

11 During access road construction, land clearing, and building construction activities, air 

emissions of criteria pollutants,3 12 volatile organic compounds (VOCs), and a small amount of 

13 hazardous air pollutants (HAPs) (e.g., benzene) would include primarily fugitive dust emissions 

14 from soil disturbances and engine exhaust emissions from heavy equipment and commuter, 

15 delivery, and support vehicular traffic traveling within, to, and from the facility. Small quantities 

16 of additional VOCs and HAPs emissions would be released from the refueling and onsite 

17 maintenance of the off-road construction equipment, and from certain painting and other 

18 construction-finishing activities. 

19 

20 For road construction, land clearing, and building construction activities, the primary concern is 

21 the potential air impact of fugitive dust that results from soil disturbances, such as site clearing, 

22 bulldozing, compacting, grading, and vehicular traffic on unpaved roads or bare grounds. These 

23 activities would involve the intense use of heavy equipment over a short time period. Air 

24 emissions from building construction such as erection of structures and equipment installation 

25 would be typically lower than those from road construction and land clearing. Wind erosion from 

26 material stockpiles and disturbed areas are also fugitive dust sources, especially under 

27 relatively high-wind conditions. Engine exhaust emissions from heavy equipment and vehicles 

28 would release small amounts of particulate matter (PM), mostly fine particles (PM2.5), which are 

29 different from large particulate matter (PM10) from mechanical soil disturbances. Potential 

30 impacts of fugitive dust emissions on ambient air quality would be high because of near-ground31 level release, if there is a short-distance buffer to the site boundaries. 

32 

33 Typically, source types, air pollutants, and their levels of emissions into the atmosphere would 

34 vary over the life of the project. The level of fugitive dust emissions would vary from day to day 

35 and from location to location, depending on the specific type of operation involved, the level of 

36 activities, soil types, and prevailing meteorological conditions (e.g., wind speed and direction, 

37 atmospheric stability, recent precipitation). No information on the detailed time schedule, heavy 

38 equipment usage, and activity levels are available at this time. Detailed schedule, equipment 

39 usage, and activity levels typically become available when a construction contract is developed. 

40 General area-wide emission factors based on area of and duration of disturbances were used. 

41 A PM10 emission factor of 0.94 metric ton per hectare-month (0.42 ton per acre-month) was 

42 applied to large-scale earthmoving activities, such as road construction and land clearing, while 

 

3

 A list of six common air pollutants that are regulated by the U.S. Environmental Protection Agency 

(EPA) on the basis of certain criteria (i.e., information on human health and/or environmental effects of 

pollution). Criteria pollutants include sulfur dioxide (SO2), nitrogen dioxide (NO2), carbon monoxide 

(CO), ozone (O3), particulate matter (PM10 with an aerodynamic diameter of 10 micrometers or less 

and PM2.5 with an aerodynamic diameter of 2.5 micrometers or less), and lead (Pb). 
4-11 

1 a PM10 emission factor of 0.25 metric ton per hectare-month (0.11 ton per acre-month) was 

2 applied to building construction activities, such as erection of building structures and equipment 

3 installation (MRI, 1996). It is also assumed that 10 percent of PM10 emissions of fugitive dust is 

4 PM2.5 (Countess Environmental, 2006). For this analysis, a control efficiency of 74 percent is 

5 assumed during the road construction and land clearing phase (Countess Environmental, 2006). 

6 No dust control was assumed by GLE during the building construction phase. Dust emissions 

7 caused by wind erosion might be small at the Wilmington Site compared with other fugitive dust 

8 emissions and are not estimated. This is because of: (1) infrequent wind speeds high enough to 

9 trigger wind erosion; (2) natural mitigation due to a high number of precipitation days (over 118 

10 days per year with a precipitation ≥0.025 centimeter [0.01 inch]), and (3) tall trees surrounding 

11 the construction site acting as a wind barrier. 

12 

13 Engine exhaust emissions from on-road vehicles traveling to and from the Wilmington Site are 

14 estimated using emission factor motor vehicle model, MOBILE6.2 (EPA, 2003). Emission 

15 factors for off-road construction equipment were estimated using the U.S. Environmental 

16 Protection Agency’s (EPA’s) nonroad emission factor model (EPA, 2004). Daily and annual 

17 emissions for criteria pollutants and VOCs are presented in Table 4-1. During the construction 

18 phases, exhaust emissions from heavy equipment and vehicular traffic, including sulfur oxide 

19 (SOx), nitrogen oxide (NOx), carbon monoxide (CO), and VOCs are relatively small. However, 

20 as mentioned previously, fugitive dust emissions from soil disturbances, including particulate 

21 matter, are a major concern during the construction phase and are about an order of magnitude 

22 higher than other criteria pollutant and VOC emissions. Detailed information on underlying 

23 assumptions, emission factors, and emission estimation methodology are described in 

24 Appendix E of this draft EIS. 

25 

26 For the air quality modeling analysis, the latest version of the AERMOD model, Version 09292 

27 (EPA, 2009a), which is the EPA’s preferred or recommended model for a wide range of 

28 regulatory applications, was used to estimate concentration increments at receptors at and 

29 beyond Wilmington Site boundaries as a result of air emissions from the proposed GLE Facility. 

30 

31 Hourly surface and twice-daily upper sounding data from the nearest State Climate Office of 

32 North Carolina and National Weather Service (NWS) stations were used for the analysis. The 

33 nearest surface meteorological station is the Horticultural Crops Research Station, which is 

34 located about 3 kilometers (2 miles) directly east of the proposed GLE Facility. Surface 

35 characteristics for this station are representative of those for the proposed GLE Facility after 

36 tree removal, so this station is considered the primary meteorological station. Hourly surface 

37 meteorological data from Wilmington/New Hanover County Airport, which is located about 

38 8 kilometers (5 miles) southeast of the proposed GLE Facility, are used to supplement the 

39 missing onsite data and to estimate boundary layer parameters. Twice-daily upper sounding 

data from Charleston, South Carolina,4 40 which is located about 249 kilometers (155 miles) 

41 southwest of the proposed GLE Facility, are used for estimating the heights of the convective 

42 

 

4

 An upper air station at Morehead City, North Carolina, is about 113 kilometers (70 miles) northeast of 

the proposed GLE Facility, closer than Charleston, South Carolina. However, the latter was chosen 

considering the similarity of distance and orientation to the ocean. 
4-12 

Table 4-1 Estimated Air Emissions of Criteria Pollutants and VOCs 

from Construction and Operation of the Proposed GLE Facilitya,b

Average Daily Emissions (lbs/day) Phase Source 

Location SO2 NOx CO VOCs PM10 PM2.5

Early Construction 

 Road Construction Onsite 0.14 74.3 51.4 6.00 76.4 19.3 

 Land Clearing Onsite 0.14 74.3 51.4 6.00 1395.9 151.2 

Offsitec

 0.08 30.1 58.9 4.27 0.70 0.68 

Building Construction Onsite 0.10 41.2 99.4 5.56 867.9 92.8 

Offsite 0.60 186.5 401.0 28.0 4.99 4.84 

Start-up and Final Onsite 1.29 17.0 67.8 3.28 14.0 14.0 

Construction Offsite 0.66 132.2 388.7 25.1 5.45 5.28 

Operations Onsite 1.26 14.5 34.9 1.74 13.9 13.9 

Offsite 0.31 41.2 170.6 10.4 2.57 2.49 

Average Annual Emissions (tons/yr)d

Phase Source 

Location SO2 NOx CO VOCs PM10 PM2.5

Early Construction Onsite 0.02 10.0 6.94 0.81 168.7 18.4 

Offsite 0.01 4.07 7.95 0.58 0.09 0.09 

Building Construction Onsite 0.02 7.40 17.8 1.00 155.8 16.7 

Offsite 0.11 33.5 72.0 5.02 0.90 0.87 

Start-up and Final Onsite 0.16 2.48 12.1 0.57 2.52 2.51 

Construction Offsite 0.12 24.1 70.9 4.59 0.99 0.96 

Operations Onsite 0.15 2.01 6.11 0.29 2.50 2.50 

Offsite 0.06 7.51 31.1 1.90 0.47 0.45 a

 CO = carbon monoxide; NOx = nitrogen oxides; PM2.5 = particulate matter ≤2.5 μm; 

PM10 = particulate matter ≤10 μm; SO2 = sulfur dioxide, and VOCs = volatile organic 

compounds. 

b

 Detailed information on assumptions, emission factors, and calculations are described in 

Appendix E. 

c

 Offsite emission sources include vehicular traffic traveling on roadways to and from the 

proposed GLE Facility site. 

d

 Assume that construction and operations activities would occur on weekdays and 

weekends throughout the year, except no work schedule on six holidays (New Year’s Day, 

Memorial Day, Independence Day, Labor Day, Thanksgiving Day, and Christmas Day) 

during the construction phases. Annual emissions are not 365 times daily emissions due to 

the 9-month schedule of the road construction and land clearing phase and due to 

intermittently operating emergency diesel generators during start-up and final construction 

phase and operations phase. 
4-13 

boundary layer. Four years of meteorological data (2005 to 2008)5 1 were processed for input to 

2 the AERMOD. For the analysis, receptors at Wilmington Site boundaries are set densely (a few 

3 tens of meters) at northern boundaries where maximum concentrations of air pollutants are 

4 anticipated, and sparsely (a few hundreds of meters) at other site boundaries where lower 

5 concentrations of air pollutants are anticipated. Polar grid receptors are set up to 50 kilometers 

6 (31 miles) from the center of the proposed GLE Facility. Detailed information on assumptions, 

7 parameter selection, modeling inputs, and air dispersion modeling is available in Appendix E. 

8 

9 Estimated maximum pollutant concentrations during access road construction and land clearing 

10 are shown in Table 4-2 for criteria pollutants. Concentration increments for sulfur dioxide (SO2), 

11 nitrogen dioxide (NO2), and CO are predicted to be negligible. Predicted concentration 

12 increments for 24-hour and annual PM2.5 are less than 29 percent of their respective standards. 

13 However, the modeled 24-hour PM10 concentration increment would be above the standard 

14 (about 177 percent) during access road construction and land clearing activities. 

15 

16 To obtain the total concentrations for comparison to applicable air quality standards, modeled 

17 concentration increments were added to measured background concentrations representative of 

18 the Wilmington Site (Buckler, 2009). For SO2, NO2, and CO, background concentrations, not 

19 GLE sources, account for most of the total concentrations. The total concentrations would be 

20 less than 27 percent of their respective standards. The total concentration for annual PM2.5 is 

21 estimated to be 70 percent of its applicable standard. Total 24-hour PM2.5 concentrations would 

22 barely exceed the standard, but the contribution from background is much higher than from GLE 

23 emissions. Total 24-hour PM10 concentrations would be above the applicable standard, about 

24 195 percent. Note that the concentration increment causes 24-hour PM10 exceedances 

25 irrespective of background concentration, while the sum of background concentration and the 

26 project-related increment contributes to exceeding the 24-hour PM2.5 standard. Maximum PM10

27 and PM2.5 concentrations associated with road construction and land clearing activities are 

28 predicted to occur at the proximate northern boundary of the Wilmington Site near the proposed 

29 GLE Facility (less than 50 meters [164 feet] from the boundary) and would last for eight months. 

30 Comparably high PM10 and PM2.5 concentrations are also predicted at the northern Site 

31 boundary near the Wooden Shoe residential subdivision, close to which the North access road 

32 would be located (about 25 meters [82 feet] from the boundary). These high concentrations 

33 would result from fugitive dust emissions during road construction and vehicle traffic on unpaved 

34 roads during land clearing activities. 

35 

36 Estimated maximum pollutant concentrations during the building construction phase are 

37 presented in Table 4-3. Maximum concentration levels and patterns are similar to those for 

38 access road construction and land clearing activities. Concentration increments for SO2, NO2, 

39 and CO are predicted to be negligible and their total concentrations are well below their 

40 respective standards. Total annual PM2.5 concentration would be below its respective standard. 

 

5

 Per EPA’s Modeling Guidance (40 CFR Part 51, Appendix W), the most recent consecutive five years 

of meteorological data representative of the site of interest should be used when estimating 

concentrations with an air quality model. However, four years of data (2005−2008) were used for this 

analysis. A problem in wind direction measurements was found at the Horticultural Crops Research 

Station in 2004 and wind sensor was replaced in January, 2005. Wind roses for 2001−2004 at the 

station indicated that wind patterns vary significantly from the general patterns in the area, rendering 

data from this period unusable. 
4-14 

Table 4-2 Maximum Air Quality Impacts Due to Emissions Associated with Road 

Construction and Land Clearing Activities for the Proposed GLE Facility 

 Concentration (μg/m3)

b

 Percent of 

NAAQS/SAAQS 

Pollutanta Averaging 

Time 

Maximum 

Incrementc Backgroundd

 Total NAAQS/ 

SAAQS Increment Total 

SO2 3 hours 0.22 213.0 213.2 1300 0.017% 16.4% 

 24 hours 0.04 70.4 70.4 365 0.010% 19.3% 

 Annual 0.002 17.1 17.1 80 0.003% 21.4% 

NO2 Annual 1.10 26.1 27.2 100 1.10% 27.2% 

CO 1 hour 142.75 3543.0 3685.7 40,000 0.36% 9.2% 

 8 hours 27.68 2556.0 2583.7 10,000 0.28% 25.8% 

PM10 24 hours 264.80 27.0 291.8 150 176.5% 194.5% 

PM2.5 24 hours 10.03 25.4 35.4 35 28.7% 101.2% 

 Annual 1.54 9.0 10.5 15 10.3% 70.3% 

a CO = carbon monoxide; NO2 = nitrogen dioxide; PM2.5 = particulate matter ≤2.5 μm; PM10 = particulate 

matter ≤10 μm; and SO2 = sulfur dioxide. b To convert μg/m3

 to ppm for gaseous pollutants, such as SO2, NO2, and CO, divide values in μg/m3 by product of 

40.82 and molecular weight. 

c For short-term (≤ 24 hours) averages, second-highest modeled concentrations among site boundary and offsite 

receptors except 24-hour PM10 and PM2.5. For PM10, highest of the 5th-highest over 4 years (2005–2008) was 

presented. For PM2.5, the highest of the 4-year average of the 8th-highest concentration at each receptor is 

presented. For annual averages, highest annual average concentrations over four years are presented. d Source: Buckler, 2009. 

1 

2 However, total 24-hour PM10 and PM2.5 concentrations would be above their respective 

3 standards (about 201 percent and 123 percent, respectively). These exceedances would occur 

4 at the proximate northern boundary of the Wilmington Site near the proposed GLE Facility. 

5 Unlike impacts during access road construction and land clearing, concentrations at the 

6 northern Site boundary, near the North access road and Wooden Shoe residential subdivision, 

7 would be about an order of magnitude lower than at the northern Site boundary near the 

8 proposed GLE Facility. This is due to paving of the unpaved access road near the end of the 

9 road construction and land clearing phase. 

10 

11 During access road construction, land clearing, and building construction activities, potential 

12 impacts of SO2, NO2, and CO emissions from heavy equipment and vehicles on ambient air 

13 quality would be well below the applicable ambient air quality standards. These impacts on 

14 ambient air quality would be anticipated to be SMALL. However, total (background plus 

15 modeled) 24-hour PM10 and PM2.5 concentrations mostly resulting from fugitive dust emissions 

16 are predicted to exceed the standards at the proximate northern site boundaries near the 

17 proposed GLE Facility during land clearing and building construction activities. In addition, high 

18 PM10 and PM2.5 concentrations at the northern Site boundary near the Wooden Shoe residential 

19 subdivision result from fugitive dust emissions from vehicle traffic on the unpaved North access 
4-15 

Table 4-3 Maximum Air Quality Impacts Due to Emissions Associated with Building 

Construction Activities for the Proposed GLE Facility 

 Concentration (μg/m3)

b

 Percent of 

NAAQS/SAAQS 

Pollutanta Averaging 

Time 

Maximum 

Incrementc Backgroundd

 Total NAAQS/ 

SAAQS Increment Total 

SO2 3 hours 0.26 213.0 213.3 1300 0.020% 16.4% 

 24 hours 0.05 70.4 70.4 365 0.013% 19.3% 

 Annual 0.009 17.1 17.1 80 0.012% 21.4% 

NO2 Annual 1.31 26.1 27.4 100 1.31% 27.4% 

CO 1 hour 846.31 3543.0 4389.3 40,000 2.12% 11.0% 

 8 hours 192.74 2556.0 2748.7 10,000 1.93% 27.5% 

PM10 24 hours 274.63 27.0 301.6 150 183.1% 201.1% 

PM2.5 24 hours 17.64 25.4 43.0 35 50.4% 123.0% 

 Annual 2.40 9.0 11.4 15 16.0% 76.0% 

a CO = carbon monoxide; NO2 = nitrogen dioxide; PM2.5 = particulate matter ≤2.5 μm; PM10 = particulate 

matter ≤10 μm; and SO2 = sulfur dioxide. b To convert μg/m3

 to ppm for gaseous pollutants, such as SO2, NO2, and CO, divide values in μg/m3 by product of 

40.82 and molecular weight. 

c For short-term (≤ 24 hours) averages, second-highest modeled concentrations among site boundary and offsite 

receptors except 24-hour PM10 and PM2.5. For PM10, highest of the 5th-highest over 4 years (2005–2008) was 

presented. For PM2.5, the highest of the 4-year average of the 8th-highest concentration at each receptor is 

presented. For annual averages, highest annual average concentrations over four years are presented. d Source: Buckler, 2009. 

1 

2 road during land clearing activities. These exceedances would occur when the wind blows from 

3 the directions ranging from south to west. Most of these exceedances are associated with a 

4 couple of hours of high concentrations in the early morning in winter, typical of low wind speeds 

5 (about 1 meter per second) and stable conditions. The access road construction, land clearing, 

6 and building construction activities would last about nine months and two years, respectively. 

7 

8 Accordingly, potential air quality impacts during road construction, land clearing, and building 

9 construction activities are expected to be MODERATE but temporary in nature. Although 

10 natural mitigation of fugitive dust emissions is considerably high due to high rates of 

11 precipitation in the area, aggressive dust control measures should be implemented during road 

12 construction, land clearing, and building construction activities to minimize potential air quality 

13 impacts, as discussed in Section 4.2.4.3. 

14 

15 Estimated emissions from engine exhaust and vehicular traffic during the start-up and final 

16 construction phase, which would last for five years from 2013 to 2017, would be comparable to 

17 those during road construction, land clearing, and building construction activities. However, PM 

18 emissions are more than an order of magnitude lower than the previous two phases. 
4-16 

1 Accordingly, start-up and final construction activities would have SMALL impacts on ambient air 

2 quality for all criteria pollutants. 

3 

4 Concentration increments for the two remaining criteria pollutants, lead (Pb) and ozone (O3), 

5 were not modeled. As a direct result of the phase-out of leaded gasoline in automobiles, 

6 average lead concentrations in urban areas throughout the country have decreased 

7 dramatically. It is expected that emissions of lead from the proposed facility construction would 

8 be negligible and would therefore have no or SMALL impacts on surrounding areas. 

9 

10 The high ozone concentrations of regional concern are associated with precursor emissions 

11 (nitrogen oxides [NOx] and VOCs) locally and long-range transport of precursor-laden air 

12 masses from neighboring areas under favorable meteorological conditions, such as high 

13 temperatures, low wind speeds, intense solar radiation, and an absence of precipitation. The 

14 New Hanover County encompassing the proposed GLE Facility is currently in attainment for 

15 ozone (40 CFR 81.334) but monitored 8-hour ozone levels in the area approach or are just 

16 below the standard (see Table 3-9). Ozone precursor emissions during the three construction 

17 phases would be relatively small. As shown in Table 4-1, the highest emissions would occur 

18 during the building construction phase, about 37.1 metric tons per year (40.9 tons per year) for 

19 NOx and 5.4 metric tons per year (6.0 tons per year) for VOCs, which are about 0.6 percent and 

20 0.3 percent of total emissions in New Hanover County, respectively. These emissions would be 

much lower than those for the regional airshed6 21 in which emitted precursors are transported and 

22 formed into ozone. Accordingly, potential impacts of ozone precursor releases from all 

23 construction phases of the proposed GLE Facility on regional ozone would be SMALL. 

24 

25 4.2.4.2 Facility Operations 

26 

27 No criteria pollutants would be generated during operation of the proposed GLE Facility 

28 because no combustion is involved. A new operating permit would be required for the proposed 

29 GLE Facility. However, criteria pollutant and HAP emission rates are expected to be small 

30 during the operations phase, and thus, the proposed GLE Facility would not be a major source 

31 of air emissions as defined under the EPA and North Carolina Department of Air Quality 

32 (NCDAQ) air permit requirements. The laser uranium enrichment process would occur inside 

33 the main GLE building. Short-term uranium-related and/or hydrogen fluoride (HF) emissions 

34 would occur during the process and be drawn into the ventilation system with a series of 

35 emission control devices such as high-efficiency particulate air (HEPA) filters for ≥99.8 percent 

36 removal of PM, and activated carbon beds for ≥99 percent removal of HF. Then, the air stream 

37 would be released into the atmosphere through a single building roof stack; accordingly, air 

38 emissions through the stack would be minimal. Potential impacts associated with radiological 

39 and hazardous emissions are addressed in Section 4.2.11. No continuous combustion sources 

40 for space heating (such as boilers) would be needed, because most of the heat generated by 

41 the process lasers would be used for building space heating. The only stationary combustion 

42 sources at the proposed GLE Facility would be two 382-horsepower auxiliary emergency diesel 

43 generator units. These units will be operating on an intermittent basis to provide backup electric 

44 power to the proposed GLE Facility in the event of power outage or load-shedding, and to 

 

6

 A geographical area that shares the same air due to topography, meteorology, and climate. 
4-17 

conduct routine maintenance testing.7 1 Based on air permit conditions for the existing 

2 emergency diesel generators at the Wilmington Site, the permitted number of operating hours 

3 per year is 240. However, actual operating hours would vary depending on the number and 

4 duration of power disruptions. The other stationary sources are two mechanical-draft cooling 

5 towers, which will not be a source of the typical combustion-related criteria pollutants or other 

6 toxic emissions, but emit small amounts of particulate matter as drift. 

7 

8 Other onsite miscellaneous sources include uranium hexafluoride (UF6)-cylinder handling 

9 activities and routine equipment maintenance. Accidental releases associated with UF6-cylinder 

10 handling activities would be possible, and associated emissions could be much higher than 

11 those from a process building stack. Potential impacts of these releases are addressed in 

Sections 4.2.11 and 4.2.15. Dedicated onsite transfer vehicles (OSTVs)8 12 would be used to ferry 

13 the UF6 cylinders between the proposed GLE Facility’s main operations buildings and cylinder 

14 storage yards. Small quantities of organic solvents and lubricants would be used for process 

15 equipment and vehicle maintenance. 

16 

17 Mobile sources along the onsite roadways including commuting and delivery vehicles traveling 

18 to and from the proposed GLE Facility and existing FMO facility would also contribute 

19 emissions. Fugitive dust emissions from the disturbed areas during operations would be 

20 minimal because most working areas and roadways within the proposed GLE Facility would be 

21 paved. 

22 

23 As shown in Table 4-1, estimated emissions during the operations phase are presented for 

24 comparison along with construction emissions. Auxiliary diesel generator units account for most 

25 of SO2 and NOx emissions from onsite operations, while onsite gasoline-engine traffic is a 

26 primary contributor to CO and VOC emissions. Two mechanical-draft cooling towers account 

27 for most of the PM emissions. Emissions during the operations phase are lower than those 

28 during the start-up and final construction phase, and PM emissions are more than an order of 

29 magnitude lower than those during access road construction, land clearing, and building 

30 construction activities. Accordingly, potential air quality impacts of criteria pollutants resulting 

31 from operation of the proposed GLE Facility would be anticipated to be SMALL. Potential 

32 impacts of uranium and hydrogen fluoride emissions on public and occupational health 

33 associated with operation of the proposed GLE Facility are presented in Section 4.2.11. 

34 

35 As discussed in Section 4.2.4.1, lead emissions from proposed facility construction are 

36 expected to be negligible and would therefore have no adverse impacts on surrounding areas. 

37 

38 Ozone precursor emissions during operation of the proposed GLE Facility would be relatively 

39 small, about 8.6 metric tons per year (9.5 tons per year) for NOx and 2.0 metric tons per year 

40 (2.2 tons per year) for VOCs, which are less than 0.13 percent and 0.09 percent of total 

41 emissions in New Hanover County, respectively. These emissions would be much lower than 

42 those for the regional airshed in which emitted precursors are transported and formed into 

 

7

 A program to cut off the electric current on certain large industrial electricity users during times of peak 

demand under a prearranged agreement. 

8

 Diesel-powered forklifts are the primary option, but other options, such as propane- and electricpowered OSTVs are also under consideration. 
4-18 

1 ozone. Accordingly, potential impacts of O3 precursor releases from facility operations on the 

2 regional ozone would not be of concern. 

3 

4 4.2.4.3 Mitigation Measures 

5 

6 As discussed above, air quality impacts are generally expected to be SMALL. However, 

7 potentially MODERATE air quality impacts of short duration are possible during road 

8 construction, land clearing, and building construction activities. To minimize potential air quality 

9 impacts during the road construction, land clearing, building construction, start-up and final 

10 construction, and operations periods, the best available practices should be implemented as 

11 practically as possible. Air emissions would need to comply with applicable laws, ordinances, 

12 regulations, and standards. Fugitive dust emissions and other combustion-related emissions 

13 would need to be controlled through stipulations included in the permitting processes. Below 

14 are mitigation measures that GLE has committed to implementing (GLE, 2008) and additional 

15 mitigation measures identified by NRC staff that could potentially reduce or minimize impacts. 

16 

17 Mitigation Measures for Road Construction, Land Clearing, and Building Construction

18 

19 Mitigation Measures Identified by GLE

20 

21 • Water the facility site and unpaved roads to reduce dust. 

22 

23 • Remove dirt from truck tires by driving over a gravel pad prior to leaving the facility site or 

24 unpaved access road to avoid spreading sediments on paved roads. 

25 

26 • Cover trucks carrying soil and debris to reduce dust emissions from the back of trucks 

27 driving on roadways. 

28 

29 • Pave access road and parking lots as soon as practicable. 

30 

31 Additional Mitigation Measures Identified by NRC

32 

33 • Post speed limits (e.g., 10 miles per hour) visibly within the construction site, and enforce 

34 them to minimize airborne fugitive dust. 

35 

36 • Limit access to the construction site and staging areas to authorized vehicles only, through 

37 the designated treated roads. 

38 

39 • Stage construction to limit the exposed/disturbed area at any given time, when practical. 

40 

41 • Train workers to comply with the speed limit, use good engineering practices, minimize drop 

42 height of materials, minimize disturbed areas, and employ other BMPs as appropriate. 

43 

44 • To the extent practicable, conduct soil-disturbing activities and travel on unpaved roads 

45 during periods of favorable meteorological conditions, as conducting these activities during 
4-19 

periods of unfavorable meteorological conditions9 1 may result in exceedances of air quality 

2 standards. Unfavorable meteorological conditions are infrequent and include (1) periods of 

3 low winds and stable weather conditions (primarily encountered around sunrise in winter) 

4 and (2) periods of high winds. 

5 

6 • All heavy equipment should meet emission standards specified in the State Code of 

7 Regulations, and routine preventive maintenance, including tuneup to the manufacturer’s 

8 specification, should be implemented to ensure efficient combustion and minimum 

9 emissions. 

10 

11 • Fuel all diesel engines used in the facility and auxiliary diesel generator units with ultra-low 

12 sulfur diesel with a sulfur content of 15 parts per million or less. 

13 

14 • Limit idling of diesel equipment to no more than 10 minutes, unless idling must be 

15 maintained for proper operation; for example, drilling, hoisting, and trenching. 

16 

17 • Because GLE assumed a dust control efficiency of 55 percent (applying water twice per day 

18 for the unpaved North access road during land clearing), more aggressive dust control 

19 measures should be implemented (for the entire unpaved access road or for the segments 

20 that most contribute to exceedances) to minimize potential dust impacts at the Wilmington 

21 Site boundary and the nearby Wooden Shoe residential subdivision. Options include more 

22 frequent water spraying (e.g., at every 2-hour watering interval) and the application of a dust 

23 suppressant. Selection of the proper dust suppressant should be based on road conditions, 

24 environmental impacts (including surface and groundwater quality), and cost (Bolander and 

25 Yamada, 1999). 

26 

27 Mitigation Measures for Operation

28 

29 Mitigation Measures Identified by GLE

30 

31 • Conduct uranium-enrichment operations inside an enclosed building using a closed-system 

32 process with no routine venting of process gases. 

33 

34 • Install and operate leak-detection monitors for process equipment. In the event a leak is 

35 detected due to an equipment component malfunction or other reason, safety interlocks will 

36 isolate the section of the process where the leak is detected, limiting the potential quantity of 

37 gaseous material that could be released inside the proposed GLE Facility’s operations 

38 building. 

39 

40 • Maintain process areas inside the operations building under continuous negative pressure 

41 relative to atmospheric pressure. In the event of a gaseous release in one of these process 

42 areas, the negative pressure conditions would prevent outflow of the air from the process 

43 areas, effectively containing the released gaseous material to the affected process area. 

44 

 

9

 Stable meteorological conditions limit dilution of airborne pollutants, which can lead to potentially high 

pollutant concentrations at the ground level. High winds are unfavorable due to the increased 

potential for fugitive dust emissions. 
4-20 

1 • Ventilate the operations building with a high-efficiency, multi-stage air emissions control 

2 system. Components of the air emissions control system planned for the operations 

3 building consist of high-efficiency particulate arresting (HEPA) filters for removal of solid 

4 particulate matter and activated carbon beds for adsorption of HF. Exhaust gases from this 

5 emission-control system would be vented to the atmosphere through a single stack. 

6 

7 • Implement a periodic inspection and maintenance program for uranium hexafluoride (UF6) 

8 cylinders stored in outdoor areas. 

9 

10 • Burn low-sulfur fuel oil in the auxiliary diesel generators. 

11 

12 • Store organic solvents, paints, and other volatile organic compound–containing liquids in 

13 containers covered with tightly fitting lids. 

14 

15 Additional Mitigation Measures Identified by NRC

16 

17 No additional mitigation measures to minimize potential impacts on ambient air quality from the 

18 operation of the proposed GLE Facility are proposed by NRC. 

19 

20 4.2.5 Geology and Soil Impacts 

21 

22 This section discusses the assessment of potential environmental impacts on geologic 

23 resources and soils during preconstruction activities, construction, and operation of the 

24 proposed GLE Facility. Potential impacts include soil erosion due to ground disturbance and 

25 changes in drainage. Section 3.6 of this draft EIS provides a description of site soils and the 

26 geologic setting. 

27 

28 4.2.5.1 Preconstruction and Construction Activities 

29 

30 As described in Section 1.4.1, preconstruction activities would include clearing of about 

31 40 hectares (100 acres) at the proposed GLE site (GLE, 2009b), among other activities. 

32 Because the site is generally quite level, regrading would be minimal. Additional activities may 

33 include construction of two wet detention basins and topsoil stripping and stockpiling. These 

34 ground-disturbing activities would result in short-term soil erosion, which could be minimized by 

35 following BMPs, including but not limited to the use of silt fencing, reseeding of areas, and 

36 proper construction of drainages and culverts. These activities are controlled by the New 

37 Hanover County Erosion and Sedimentation Control Ordinance (New Hanover County, 2007), 

38 which authorizes permits as appropriate. 

39 

40 The heavy equipment used during preconstruction or construction activities could potentially 

41 leak fuel, oil, or grease to site soils. Following BMPs, as discussed in Section 4.2.5.3, would 

42 reduce the associated impacts. 

43 

44 Under the proposed action, approximately 91 hectares (226 acres) of land would be disturbed in 

45 the Wilmington Site’s North-Central and Eastern Site Sectors, including the approximately 

46 40 hectares (100 acres) described above for the proposed GLE site in the north-central site 

47 sector, plus about 5 hectares (13 acres) for support structures to the east and about 13 hectares 

48 (33 acres) associated with the North access road. 
4-21 

1 Soil-related aspects of the construction phase would include soil excavation for foundations and 

2 buried utility lines, soil storage and removal, and stormwater management. These activities are 

3 controlled by the New Hanover County Erosion and Sedimentation Control Ordinance 

4 (New Hanover County, 2007), which authorizes permits as appropriate. Most of the project area 

5 is Murville sand and Leon sand soil types, and their erodibility is slight (USMC, 2009; 

6 GLE, 2008). 

7 

8 Construction vehicles and equipment could potentially leak fuel, oil, or grease to site soils. 

9 Following BMPs, as discussed in Section 4.2.5.3, would reduce the associated impacts. 

10 

11 Preconstruction and construction activities would not impact site geologic resources because 

12 the site lacks significant geologic resources. Construction activities would involve acceptable 

13 amounts of crushed stone and/or sand and gravel from offsite sources for use in construction of 

14 roads and buildings. 

15 

16 Overall, the impact on geology and soil is considered SMALL. The estimated relative 

17 contributions to the soil-related impacts are 50 percent during preconstruction activities and 

18 50 percent during construction. These figures are estimated based on assumed similar 

19 disturbed land footprints and equipment use during both phases for similar durations. 

20 

21 4.2.5.2 Facility Operations 

22 

23 During operations, soil disturbance would take place at a reduced level, as some construction 

24 projects would be completed while others would be ongoing. Restoration and seeding of 

25 cleared land would need to occur to limit erosion due to stormwater. Roads, parking lots, and 

26 roofs would create impervious surfaces and increase runoff, consequently increasing the 

27 erosion potential. Large storm events could create erosion along drainages or at culverts, 

28 causing a need for maintenance or drainage system improvement. Proper site development 

29 and culvert design would limit this impact. The county notifies owners of deficient components 

30 of a stormwater system (New Hanover County, 2009c). Correction is the responsibility of the 

31 owner, otherwise the county would mitigate and recover costs from the owner. 

32 

33 Vehicles and equipment used in unpaved areas could potentially leak fuel, oil, or grease to site 

34 soils. Following BMPs, as discussed in Section 4.2.5.3, would reduce the associated impacts. 

35 

36 Groundwater extraction is expected to have a minimal effect on groundwater levels, and the 

37 associated degree of subsidence is expected to be negligible. Other geologic hazards to the 

38 site (e.g., volcano, tsunami, landslide, radon gas, methane gas, subsidence due to mining) are 

39 not anticipated. The overall impact on geology or soil during operations is expected to be 

40 SMALL. 

41 

42 4.2.5.3 Mitigation Measures 

43 

44 GLE proposes to employ a number of measures to mitigate impacts on soil and geological 

45 resources (GLE, 2008), including: 

46 

47 • minimization of the construction footprint to the extent possible 
4-22 

1 • minimization of soil disturbance 

2 

3 • use of soils from onsite borrow pits that are accessible via existing roadbeds if additional soil 

4 is needed 

5 

6 • management of construction activities so that only designated areas within the GLE study 

7 area are disturbed and no heavy equipment or construction operations are allowed to affect 

8 areas outside the study area unless specifically designated 

9 

10 • use of adequate containment methods during excavation 

11 

12 • use of site-stabilization practices (e.g., placing crushed stone on top of disturbed soil in 

13 areas of concentrated runoff) 

14 

15 • use of silt berms, dikes, and sediment fences 

16 

17 • stabilization of drainage culverts and ditches by lining with rock aggregate/rip-rap to reduce 

18 flow velocity and prohibit scouring 

19 

20 • reuse and/or appropriate placement of excavated materials to decrease exposed soil piles 

21 

22 • placement of gravel construction pads at the entrance/exits of construction areas 

23 

24 • stabilization of the site with low-maintenance landscaping and pavement 

25 

26 In addition, the New Hanover County Erosion and Sedimentation Control Ordinance (New 

27 Hanover County, 2007) contains BMPs for control of soil and sediment. For erosion control, 

28 BMPs include but are not limited to the use of silt fencing, reseeding of disturbed areas, 

29 minimizing soil disturbance during the construction phase through planning and engineering 

30 design, and proper construction of drainages and culverts. Implementation of BMPs would limit 

31 the impact of soil erosion and soil contamination. Soil-disturbing activities are controlled by the 

32 New Hanover County Erosion and Sedimentation Control Ordinance, which authorizes permits 

33 as appropriate. The county will periodically inspect land-disturbing activities at a site to ensure 

34 compliance with the permit. Failure to conform to the permit would lead to issuance of a Notice 

35 of Violation to GLE from New Hanover County, and continuing violations would lead to the 

36 imposition of penalties assessed against GLE (New Hanover County, 2007). Implementation of 

37 proper, generally accepted BMPs for storage, handling, spill prevention, and spill response 

38 would reduce the impact of contamination associated with fuels, oils, and grease from 

39 equipment used onsite (or from other chemicals or wastes managed onsite). 

40 

41 4.2.6 Surface Water Resources Impacts 

42 

43 This section discusses the assessment of potential environmental impacts on surface water 

44 during preconstruction activities, construction, and operation of the proposed GLE Facility. The 

45 discussion includes the potential impact due to turbidity from soil erosion and contaminants in 

46 runoff. 

47 
4-23 

1 4.2.6.1 Preconstruction and Construction Activities 

2 

3 Preconstruction activities are expected to include the construction of stormwater detention 

4 basins and the clearing of approximately 40 hectares (100 acres) of land at the GLE site. As 

5 discussed in Sections 4.2.5.1 and 4.2.5.3, BMPs would be implemented and the process would 

6 be inspected by the county so that soil erosion and the associated increase to turbidity would be 

7 minimized. Still, a short-term decrease in surface water quality in unnamed tributaries of Prince 

8 George Creek and the Northeast Cape Fear River and potentially the creek and river 

9 themselves may be realized due to sedimentation and turbidity associated with erosion during 

10 preconstruction and construction activities. 

11 

12 Currently, the North Carolina Department of Environmental and Natural Resources (NCDENR) 

13 requires the permittee to monitor daily rainfall, visually inspect runoff outfalls on a regular basis, 

14 and thoroughly document monitoring activities and data (NCDENR, 2009b). Recent EPA rules 

15 address stormwater runoff at construction sites (EPA 2009e). As of August 2011, all sites that 

16 disturb 20 or more acres will require self-monitoring on a regular basis and will need to meet the 

17 EPA’s effluent limitation guidelines for turbidity of 280 nephelometric turbidity units. The 

18 NCDENR issued a new general permit for construction activities, effective January 1, 2010 

19 (NCDENR, 2009b), but the turbidity monitoring requirements are not included. The NCDENR 

20 general permit will be updated before August 2011 to include those requirements. 

21 

22 Construction of the purposed facility would involve new buildings, parking lots, UF6 storage 

23 areas, and landscaping. Excavations for foundations or buried utility lines would lead to 

24 possible short-term soil erosion problems with associated impacts on surface water quality. 

25 Again, BMPs would be expected to minimize the impacts, as discussed in Section 4.2.5.3. 

26 

27 The proposed North access road would have a new stream crossing at a tributary of Prince 

28 George Creek and possibly change a jurisdictional channel. This could lead to erosion and 

29 increased sediment load. Following BMPs for this type of action would minimize the impact. 

30 

31 Use of construction vehicles and equipment during preconstruction or construction activities 

32 poses the possibility of leaks or spills of fuels, oil, or grease, which could run off and impact 

33 surface water in the unnamed tributaries of Prince George Creek and the Northeast Cape Fear 

34 River and potentially the creek and river themselves. As described in Section 4.2.6.3, BMPs for 

35 storing and handling these liquids and for dealing with such releases would limit or eliminate 

36 their effect on surface water quality. Because of the distance from the main work area to the 

37 drainages, it is unlikely that a minor spill would directly reach the Northeast Cape Fear River or 

38 Prince George Creek. Infiltration into site soil would likely eliminate runoff of the liquid. 

39 

40 Preliminary plans for the proposed GLE Facility include a runoff pond to receive water from the 

41 UF6 storage pads (tails), two State-permitted stormwater wet detention basins, a small cooling 

42 tower for heating, ventilation, and air conditioning (HVAC) equipment, a water tower for potable 

43 and perhaps process water, and a firewater pond. The design of the stormwater wet detention 

44 basins is not finalized, but they would be constructed according to State and County 

45 requirements (GLE, 2009f). They would likely have clay liners, and they would be designed for 

46 a 25-year storm event (GLE, 2009f). The runoff pond for the UF6 storage pad is anticipated to 

47 be approximately 3 acres, have a clay liner, and be designed in consultation with the State 
4-24 

1 Department of Water Quality (GLE, 2009f). Overflow from these basins would presumably be 

2 routed to the effluent channel or to the natural drainage fed by the effluent channel. 

3 

4 The overall impact on surface water quality during preconstruction and construction activities is 

5 expected to be SMALL due to the nature of the work activities, the site soil characteristics and 

6 slopes, and the use of generally implemented BMPs to negate the effect of potential problems 

7 from erosion, spills, etc. The estimated relative contributions of these impacts are 50 percent 

8 during preconstruction activities and 50 percent during construction. These figures are 

9 estimated based on assumed similar disturbed land footprints and equipment use during both 

10 phases for similar durations. 

11 

12 4.2.6.2 Facility Operations 

13 

14 A process wastewater effluent rate of about 35,000 gallons per day would result from the 

15 proposed action and be discharged at existing Outfall 001. The flow would include 5000 gallons 

16 per day of liquid radwaste (from decontamination, cleaning, and laboratory activities) and 

17 30,000 gallons per day of noncontact cooling tower blowdown. The liquid radwaste would be 

18 pretreated in the GLE liquid effluent treatment system before transfer to the existing Wilmington 

19 Site final process lagoon wastewater treatment facility. The treatment process is very similar to 

20 that already in use at the Wilmington Site (GLE, 2009f). Steps in the process would include pH 

21 adjustment to precipitate uranium, addition of a flocculent, filtering and drying of uranium floc 

22 (flakes of precipitate), and offsite disposal of the resulting solids. The site’s process wastewater 

23 volume would increase by seven percent over the 2006 level, which is the latest data available 

24 (GLE, 2008). Treatment steps would produce an effluent with concentrations similar to those of 

25 current process wastewaters (GLE, 2008; GLE 2009f). 

26 

27 The wastewater treatment and industrial reuse system already in place at the Wilmington Site 

28 would receive the sanitary effluent from the proposed GLE Facility for use in the cooling tower. 

29 The National Pollutant Discharge Elimination System (NPDES) discharge permit remains valid if 

30 discharge to Outfall 002 becomes necessary in the future (GLE, 2008). 

31 

32 Stormwater runoff would gather in wet detention basins before discharge to a stream. 

33 Stormwater during the operational phase would be regulated by a NPDES permit, which would 

34 include a stormwater pollution prevention plan. 

35 

36 If radioactivity were detected in the UF6 storage pad’s runoff pond, the contents would be 

37 allowed to settle and precipitate. Liquid would be pumped out and taken to the GLE liquid 

38 effluent treatment system. Residual solids would then be analyzed and, if necessary, disposed 

39 of as low-level radioactive waste (LLRW) at the EnergySolutions facility in Utah (GLE, 2008). 

40 When monitoring demonstrates a lack of radioactivity, the pond’s effluent would be discharged 

41 to the two stormwater ponds and ultimately to the effluent channel above the dam. 

42 

43 Following construction of the North Road, together with completion of associated stream 

44 crossings, any increase in turbidity and sediment loading to streams realized during the 

45 preconstruction and construction phases would subside during the operational phase. Oil, 

46 grease, metals, and other automotive-related contaminants would be present in limited 

47 quantities due to general traffic. 

48 
4-25 

1 The use of herbicides at the proposed facility’s landscaped areas would be similar to their use 

2 elsewhere at the Wilmington Site. BMPs regarding the use of such chemicals would limit their 

3 impact on surface water quality. 

4 

5 No consumptive surface water use would take place during the proposed action. 

6 

7 Watershed modeling suggests that runoff at the proposed GLE Facility would increase by 

8 36 percent over the current conditions in undeveloped land (GLE, 2008). This runoff would be 

9 detained in the wet detention pond designed for a 25-year storm. This pond would be designed 

10 during final design of the proposed GLE Facility, in compliance with State water quality 

11 treatment regulations and county regulations (GLE, 2009f). State regulations require treatment 

12 of the first 1.5 inches of rain to remove 85 percent of total suspended solids. New Hanover 

13 County (New Hanover County, 2009c) requires peak control of 2-, 10-, and 25-year storms to 

14 the predevelopment condition. 

15 

16 During operations, some construction projects would be completed while others would be 

17 ongoing. The potential increase in turbidity in site drainages would take place at a level 

18 proportional to the intensity and areal extent of soil disturbance. Restoration and seeding of 

19 cleared land would need to occur to limit erosion due to stormwater. Roads, parking lots, and 

20 roofs would create impervious surfaces and increase runoff, consequently increasing the 

21 erosion potential. Large storm events could create erosion along drainages or at culverts, 

22 causing a need for maintenance or drainage system improvement. 

23 

24 Overall, the impact on surface water during operations is anticipated to be SMALL due to 

25 planned systems for runoff, treatment, and monitoring and experience with the existing 

26 Wilmington Site facilities. 

27 

28 4.2.6.3 Mitigation Measures 

29 

30 GLE proposes to employ a number of measures to mitigate impacts on surface water resources 

31 (GLE, 2008), including: 

32 

33 • selection of a non-wetland, non-floodplain area for the proposed facility 

34 

35 • implementation of proper construction BMPs as specified by the New Hanover County 

36 Erosion and Sedimentation Control Ordinance (New Hanover County, 2007) 

37 

38 • construction of the access road perpendicular to Unnamed Tributary #1 to minimize the 

39 impacted area 

40 

41 • design and construction of the upgraded crossing following procedures required by the New 

42 Hanover County Flood Damage Prevention Ordinance (New Hanover County, 2006) 

43 

44 • limitation of cut/fill slopes to a horizontal-vertical ratio of three to one or less 

45 

46 • use of silt fencing and covering soil stockpiles to prevent sediment runoff 

47 

48 • suspension of general construction activities during storms and impending precipitation 
4-26 

1 • construction of stream crossings (i.e., installation of culverts) following at least 48 hours of 

2 dry weather 

3 

4 • diversion of stream flow during stream-crossing construction to minimize excavation in 

5 flowing water 

6 

7 • maintenance of construction equipment to avoid visible leaks of oil, greases, or hydraulic 

8 fluids 

9 

10 • restoration of disturbed areas to original surface elevations, where possible 

11 

12 • compliance with all NPDES stormwater and wastewater permit requirements 

13 

14 • routing of stormwater to a new stormwater wet detention basin, designed in accordance with 

15 the NCDENR Stormwater Best Management Practices Manual (NCDENR, 2007) 

16 

17 • onsite treatment of process and sanitary wastewaters to NPDES-permit limits before 

18 discharge to receiving waters 

19 

20 • routine monitoring and inspection of onsite liquid waste storage tanks and containers to 

21 detect any leaks or releases to the environment to ensure prompt correction action under 

the Spill Prevention Control and Countermeasure (SPCC) Plan10 22 

23 

24 • discharge of UF6 storage pads stormwater runoff to a holding pond for monitoring prior to 

25 discharge to the stormwater wet detention basin 

26 

27 • periodic visual inspection of the stormwater wet detention basin to verify proper function, at 

28 a frequency sufficient to allow for identification of basin high-water-level conditions and 

29 implementation of corrective actions to restore the water level prior to overflow 

30 

31 • construction of a stormwater wet detention basin and implementation of a Wilmington Site 

32 stormwater management plan to mitigate a portion of the increased floodwaters from 

33 extreme storm events and all stormwater from smaller storm events 

34 

35 • ensuring easy access to the stormwater wet detention basin to allow the prompt, systematic 

36 sampling of runoff 

37 

38 In addition, the New Hanover County Erosion and Sedimentation Control Ordinance (New 

39 Hanover County, 2007) contains BMPs for control of soil and sediment which relate closely to 

40 surface water quality due to sedimentation and turbidity. These are discussed in 

41 Section 4.2.5.3. The county notifies owners of deficient components of a stormwater system 

42 (New Hanover County, 2009c). Correction is the responsibility of the owner, otherwise the 

43 county will mitigate and recover costs from the owner. Implementation of BMPs for storage, 

44 handling, spill prevention, and spill response would reduce the impact of surface water 

 

10 SPCC plans are prepared to prevent the discharge of oil from a facility into navigable waters or 

adjoining shorelines. These plans require facilities to have adequate containment around oil tanks, 

such as berms and dikes, to protect soil and water in the event of a spill. 
4-27 

1 contamination associated with the runoff of fuels, oils, and grease from equipment used onsite 

2 (or from other chemicals or wastes managed onsite). Implementing these BMPs would also 

3 limit the impact of soil erosion and soil contamination, as discussed in Section 4.2.5.3. 

4 Mitigation measures with respect to surface water usage are not relevant because no 

5 consumptive surface water use is included in the proposed action. 

6 

7 4.2.7 Groundwater Resources Impacts 

8 

9 This section describes the potential impacts on groundwater resources, which generally are 

10 related to possible spills or leaks of fuels or other liquids and to the groundwater-surface water 

11 interaction. 

12 

13 4.2.7.1 Preconstruction and Construction Activities 

14 

15 Construction equipment used for clearing, excavating, and construction pose the potential for 

16 leaks of fuel, oil, and grease to the soil and ultimately to the groundwater. Following BMPs 

17 would reduce the impact to site groundwater. The use of portable toilets would eliminate 

18 sanitary system impacts on groundwater. Potable and nonpotable water requirements would be 

19 met by transport of offsite water by tanker trucks. These would include acceptable amounts of 

20 water for concrete-making and possibly for dust suppression. 

21 

22 Altogether, the impact of preconstruction and construction activities on groundwater use and 

23 quality would be SMALL. The estimated relative amounts of impact are 50 percent during 

24 preconstruction activities and 50 percent during construction due to use of similar equipment 

25 and fuel during these two phases. 

26 

27 4.2.7.2 Facility Operations 

28 

29 During the operational phase, stormwater would collect in a clay-lined wet detention basin and 

30 eventually drain to surface water bodies. The stormwater should be expected to have no more 

31 than trace amounts of radiological contaminants, and the clay liner (GLE, 2009f) should be 

32 expected to limit the amount of infiltration to groundwater. 

33 

34 Discharge at site Outfall 001 is and would continue to be from process wastewater. The effluent 

35 is and would continue to be received by the effluent channel, which may be locally incised 

36 through the semiconfining Peedee clay layer. Some portion of the effluent may therefore 

37 potentially infiltrate the Peedee sand aquifer, especially if its water level is drawn down by 

38 remedial extraction wells. This infiltration would be contained hydraulically by the site's 

39 groundwater remediation system. 

40 

41 Preliminary plans for the proposed GLE Facility include obtaining additional groundwater for 

42 potable purposes from the Wilmington Site’s existing production wells east of Castle Hayne 

43 Road. The estimated increase in potable water needs from the proposed facility is 

44 11,000 gallons per day. These wells draw from the regionally important Peedee sand aquifer. 

45 Water level data show them to be cross-gradient of the overall Wilmington Site, and they do not 

46 result in significant drawdown (GLE, 2008). Additional groundwater will also be needed as a 

47 source of process water at an estimated rate of 75,000 gallons per day. This groundwater 

48 would be purified to remove iron and manganese. Increased drawdown of up to 4 feet in offsite 
4-28 

1 areas is expected, without significant effect on flow directions, water quality, or availability of 

2 groundwater for offsite users, as calculated using a groundwater model that is included as an 

3 appendix to the Environmental Report (ER) (GLE, 2008). Increased pumping of the site 

4 remediation wells would maintain the hydraulic containment of contaminated groundwater. The 

5 projected water demand of the proposed GLE Facility is less than the Wilmington Site’s water 

6 needs in the 1990s, and no water supply issues were known during that period (GLE, 2008). 

7 

8 Two diesel tanks would be present at the GLE site to supply fuel for backup power generation. 

9 The North Carolina Administrative Code (Title 15A, Chapter 2, Subchapter N [15A N.C. Admin 

10 Code 02N]) would govern their construction, leak detection equipment, and operation. 

11 

12 A groundwater monitoring plan for the proposed GLE Facility has not yet been prepared, but it 

13 would be developed after the facility design is finalized (GLE, 2009f). 

14 

15 Effluent treatment and monitoring are expected to result in no significant contaminant 

16 concentrations in the effluent channel, which has the potential to interact with the Peedee sand 

17 aquifer. 

18 

19 Based on the proposed design of site facilities, the treatment and monitoring of effluent, review 

20 of local water levels, and model calculations, the overall impact of site operations on 

21 groundwater is expected to be SMALL. 

22 

23 4.2.7.3 Mitigation Measures 

24 

25 Although no significant impact on the flow field is anticipated, GLE proposes to employ a 

26 number of measures to mitigate impacts on groundwater resources (GLE, 2008), including: 

27 

28 • implementation of hazardous material and waste-handling procedures and secondary 

29 containment, as required by applicable laws and regulations 

30 

31 • providing necessary construction water via tanker truck from offsite potable water sources 

32 

33 • reuse of treated sanitary wastewater effluent as makeup water in Wilmington Site cooling 

34 towers 

35 

36 • routine monitoring of sitewide groundwater levels, and continued analysis of groundwater 

37 monitoring-well and pumping-well networks to confirm that changes in groundwater levels 

38 associated with the proposed action are minimal 

39 

40 • readjustment of pumping well rates and/or performance of well maintenance or 

41 rehabilitation, as appropriate, in the event of unexpected changes in groundwater levels 

42 

43 • use of low-water-consumption landscaping 

44 

45 • installation of low-flow toilets, sinks, and showers 

46 

47 • performance of localized floor washing using mops and self-contained cleaning machines to 

48 reduce water usage compared to conventional washing techniques 
4-29 

1 In addition, proper BMPs for storage, handling, spill prevention, and spill response would reduce 

2 the impact of groundwater contamination associated with the accidental release of fuels, oils, 

3 and grease from equipment used onsite (or from other chemicals or wastes managed onsite). If 

4 measurable onsite changes in groundwater levels occur as a result of the proposed action, 

5 groundwater level monitoring should be expanded to offsite areas. 

6 

7 4.2.8 Ecological Impacts 

8 

9 This section describes the potential impacts on ecological resources that could occur during 

10 preconstruction and construction activities (Section 4.2.8.1) and during operation 

11 (Section 4.2.8.2) of the proposed GLE Facility. Ecological resources that could be affected 

12 include vegetation; wetlands; environmentally sensitive areas; wildlife; aquatic biota; and 

13 threatened, endangered, or other special status species. Section 4.2.8.3 presents a list of 

14 mitigation measures to minimize impacts on ecological resources, including those that have 

15 been identified by the applicant and those that are recommended by the NRC. 

16 

17 Overall, impacts from the proposed GLE Facility (including ancillary facilities such as the access 

18 road and transmission line) on ecological resources would depend on: 

19 

20 • the type and amount of habitat that would be disturbed 

21 

22 • the nature of the habitat disturbance (e.g., long-term reduction because of project structure 

23 and access road placement or complete, long-term alteration due to the transmission line 

24 right-of-way [ROW]) 

25 

26 • the biota that occupy the proposed facility site and surrounding areas 

27 

28 • the timing of construction activities relative to the crucial life stages of biota (e.g., nesting or 

29 spawning season) 

30 

31 For the purposes of this assessment, impacts from the proposed GLE Facility on ecological 

32 resources were considered moderate or large if they would noticeably result in or contribute to 

33 any of the following: 

34 

35 • reduction of the quality and/or quantity of habitat for plants, wildlife, or aquatic biota 

36 

37 • an alteration in a species population that would either not destabilize the population 

38 (moderate impact) or would destabilize the population to below self-sustaining levels (large 

39 impact) 

40 

41 • establishment or increases of noxious weed populations 

42 

43 • interference with the movement of any resident or migratory fish or wildlife species 

44 

45 • violations of the Endangered Species Act, Bald and Golden Eagle Protection Act, Migratory 

46 Bird Treaty Act, or other applicable Federal and State laws 

47 
4-30 

1 The changes in any of these conditions must be clearly linked to the proposed GLE Facility and 

2 not the result of an unassociated activity. 

3 

4 4.2.8.1 Preconstruction and Construction Activities 

5 

6 This section evaluates the potential impacts of proposed GLE Facility preconstruction and 

construction activities on ecological resources.11 7 Preconstruction activities that could impact 

8 ecological resources at the Wilmington Site are listed in the introduction to Section 4.2. 

9 Construction activities that could impact ecological resources at the Wilmington Site include: 

10 adding the UF6 storage pads; constructing the operations building; and adding security fencing 

11 around the proposed GLE Facility. 

12 

13 More than 75 percent of direct impacts on ecological resources would occur during 

14 preconstruction activities. This conclusion is based on professional judgment considerations on 

15 the degree of impacts that could occur during preconstruction and construction activities 

16 (e.g., vegetation clearing, habitat fragmentation, and injury, mortality, or disturbance to wildlife). 

17 The impacts would result primarily from clearing and grading, coupled with the construction of 

18 various buildings, the access road, substation and transmission line, stormwater retention pond, 

19 and parking lots. Most of the construction activities would occur within areas that would have 

20 been disturbed during preconstruction activities (although some revegetation may occur before 

21 the operations building and UF6 storage pads are constructed). 

22 

23 Vegetation

24 

25 The plant communities that occur on the Wilmington Site are shown in Figure 3-11 and are 

26 tabulated in Table 3-12. Table 4-4 summarizes the impacts on plant communities that could 

27 occur from preconstruction and construction activities for the proposed GLE Facility, the 

28 proposed North access road, and proposed utility structures. 

29 

30 Plant communities affected by preconstruction and construction activities associated with the 

31 proposed GLE Facility could incur short- or long-term changes in species composition, 

32 abundance, and distribution. Direct impacts would be primarily associated with the loss of 

33 habitat within the 81.2 hectares (200.7 acres) disturbed during preconstruction activities for the 

34 proposed GLE Facility North access road, and utility structures (Table 4-4). The proposed GLE 

35 Facility would eliminate 19.4 hectares (48 acres) of pine plantation, 21 hectares (52 acres) of 

36 pine forest, and 6.5 hectares (16 acres) of pine-hardwood forest. The remaining 0.8 hectare 

37 (2 acres) would be gravel roads (e.g., a component of the “operational area” habitat) 

38 (GLE, 2009e). 

39 

40 Additional impacts would occur within the 11.7 hectares (29 acres) that would be occupied by 

41 utility structures (e.g., access driveways, sanitary and process wastewater lift stations, clearings 

42 for utility lines, a stormwater wet detention basin, and a fire suppression line) and the 

43 22.1 hectares (54.7 acres) for the proposed north access road (Table 4-4). About 13 hectares 

44 (33 acres) of this area would be the alteration of existing operations area to another type of 

45 operations area. This would have a small impact on vegetation on the Wilmington Site. The 

 

11 The significance level of impacts on vegetation, wetlands, wildlife, and aquatic biota from the 

preconstruction and construction of the GLE Facility are incorporated in Tables 4-5 through 4-7. 
4-31 

Table 4-4 Impacts on Plant Communities Due to 

Preconstruction and Construction Activities for the Proposed 

GLE Facility 

Proposed Action Plant Communitya Area 

(acres)b

Percent of Plant 

Community on 

Wilmington Site 

GLE Facility Operations area 2.0 --c

 Pine forest 51.0 17 

 Pine-hardwood forest 16.0 7 

 Pine plantation 48.0 15 

 Subtotal 117.0 

North access road Alluvial forest 0.6 15 

 Canal corridor 0.4 2 

 Operations area 25.8 -- 

 Pine forest 2.7 1 

 Pine-hardwood forest 4.4 2 

 Pine plantation 17.9 6 

 Pocosin/bay forest 2.3 5 

 Power line corridor 0.5 3 

 Swamp forest 0.1 0 

 Subtotal 54.7 

Utility structuresd Operations area 7.0 -- 

 Pine forest 5.0 2 

 Pine-hardwood forest 3.0 1 

 Pine plantation 12.0 3 

 Power line corridor 2.0 11 

 Subtotal 29.0 

 Total 200.7 

a

 Characteristic plant species in each community are listed in Table 3-12. 

b

 To convert to hectares multiply by 0.4047. 

c

 -- = no impact assumed from altering existing operations areas to another type of 

operations area. 

d

 Includes access driveways, sanitary and process wastewater lift stations, 

clearings for utility lines, a stormwater wet detention basin, and a fire suppression 

line. 

Source: GLE, 2009e. 
4-32 

1 clearing of 3.0 hectares (7.4 acres) of pine-hardwood forest, 3.1 hectares (7.7 acres) of pine 

2 forest, 12 hectares (3.0 acres) of pine plantation, and 1 hectare (2.3 acres) of pocosin/bay forest 

3 would have a more measurable impact on vegetation (Table 4-4). 

4 

5 Habitat fragmentation would also result from the clearing and grading activities conducted 

6 during preconstruction and construction activities. This would include the creation of isolated 

7 patches of forest habitat between utility structures. It is foreseeable that some of these patches 

8 could end up being cleared. Overall, this could impact an additional 4 to 6 hectares (10 to 

9 15 acres) of forest (GLE, 2009e). As the utility corridor is routed along the North access road, 

10 overall habitat fragmentation resulting from the project would be reduced. 

11 

12 Soil compaction caused by heavy machinery could destroy ground flora and indirectly damage 

13 roots of trees (by reducing soil aeration and altering soil structure). These potential impacts 

14 would be localized in the areas immediately outside the facility site boundary. Excess soil from 

15 preconstruction and construction activities would be deposited in existing operational area 

16 habitat in the northwestern portion of the Wilmington Site. 

17 

18 Changes in forest or woodland interiors from tree removal or clearing of adjacent areas could 

19 include increased light levels, reduced soil moisture, increased transpiration, introduction of 

20 shade-intolerant species, and increased access of herbivores. Additional decline or mortality of 

21 trees near the construction boundary may subsequently occur. However, the proposed 

22 GLE Facility would be located within an area that has been impacted from logging operations. 

23 

24 Plant communities near preconstruction and construction areas could be affected by hydrologic 

25 changes such as reduced infiltration, increased runoff from exposed or compacted soils, and 

26 alteration in flow patterns from grading of the proposed GLE Facility site. 

27 

28 Other possible adverse preconstruction and construction effects on vegetation could include the 

29 localized deposition of dust and other particulate matter from clearing and grading and from the 

30 operation of vehicles and machinery. Dust can physically affect a plant by shading, interference 

31 with gaseous diffusion, abrasion of leaf surfaces, and modification of leaf temperature by black 

32 deposits. Impacts on vegetation that may occur from dust deposition would be expected to be 

33 localized and short-term. 

34 

35 Establishment of the entranceway from Castle Hayne Road and upgrading of the existing 

36 access road to the proposed GLE Facility would result in loss of some vegetation along the 

37 roadway and could result in indirect impacts on nearby areas from altered drainage patterns, 

38 runoff, and sedimentation. The access road to the proposed GLE Facility would mostly involve 

39 upgrading of existing roadway. Therefore, vegetation disturbance, and particularly 

40 fragmentation of vegetation communities, would be limited in comparison to those that would 

41 occur from establishing a completely new access road. Upgrading the access road to the 

42 proposed GLE Facility and establishment of the new entranceway to the Wilmington Site would 

43 impact areas already considered to be operations area habitat (i.e., 10.5 hectares [26 acres] of 

44 the 22 hectares [54 acres]). However, 11 hectares (27 acres) of pine–hardwood forest, pine 

45 plantation, pine forest, and pocosin/bay forest along the access road corridor and within the 

46 proposed entranceway would also be affected (GLE, 2009e). 

47 
4-33 

1 Vehicle operation could promote the introduction and establishment of invasive plant species 

2 such as Japanese honeysuckle (Lonicera japonica), Chinese privet (Ligustrum sinense), and 

3 Japanese grass (Microstegium vimineum). These species can also become established in 

4 areas impacted by fragmentation and lead to limitations on the growth of native plants, 

5 disruption of natural succession, and limitations on species and structural diversity 

6 (Campbell and Johns, 2000). 

7 

8 Accidental releases of hazardous materials (e.g., fuels) could impact plant communities in the 

9 vicinity of the spills. Spills would only be expected within small, localized areas that have mostly 

10 been disturbed by clearing and grading. Potential adverse impacts from a spill would be 

11 minimized by taking corrective actions identified in the SPCC Plan. 

12 

13 In conclusion, MODERATE impacts on vegetation would occur from vegetation clearing, habitat 

14 fragmentation, alteration of topography, changes in drainage patterns, and soil compaction; 

15 remaining impacts would be SMALL (Table 4-5). Impacts considered MODERATE would occur 

16 primarily during preconstruction, as more than 75 percent of direct impacts would occur during 

17 this phase. Following preconstruction and construction activities, the proposed GLE Facility 

18 area, including the access road and utility structures, would be considered as part of an 

19 industrial land cover type on the Wilmington Site (i.e., be classified primarily as operations area 

20 habitat). 

21 

22 Wetlands

23 

24 Wetlands could be impacted by alteration of surface water runoff patterns, soil compaction, or 

25 groundwater flow, particularly where facilities are located immediately adjacent to wetland 

26 areas. Executive Order 11990, “Protection of Wetlands,” requires Federal agencies to minimize 

27 the destruction, loss, or degradation of wetlands, and to preserve and enhance the natural and 

28 beneficial uses of wetlands. Unavoidable impacts on wetlands within the jurisdiction of the 

29 U.S. Army Corps of Engineers (USACE) might require a Clean Water Act (CWA) Section 404 

30 Permit, which would trigger the need for a CWA Section 401 Water Quality Certification. An 

31 approved mitigation plan might be required prior to the initiation of preconstruction or 

32 construction activities. 

33 

34 No wetlands would be directly impacted by preconstruction or construction activities for the 

35 proposed GLE Facility. However, jurisdictional wetlands WD, WF, and WG, and one isolated 

36 wetland (Wetland WA) occur within the corridor for the revised entrance and roadway 

37 (GLE, 2009c). Jurisdictional wetlands have a connection to surface waters. The area of the 

38 three jurisdictional wetlands within the proposed access road is 0.021 hectare (0.052 acre). The 

39 width of disturbance during construction of the roadway would be 18 meters (60 feet); whereas 

40 the corridor analyzed for the access road was up to 61 meters (200 feet) wide. Therefore, it 

41 may be possible to avoid direct impacts on the jurisdictional wetlands during construction of the 

42 entrance and access road. 

43 

44 It is probable that Isolated Wetland WA would be directly impacted by construction of the access 

45 road, resulting in a wetland loss of 0.02 hectare (0.06 acre). Impacts on this wetland would 

46 require an Isolated Wetland Permit (GLE, 2008). Based on the North Carolina Division of 

47 Environmental Management (1995) guidance for evaluating North Carolina wetlands, the 
4-34 

Table 4-5 Significance Levels of Potential Impacts on Vegetation, 

Wetlands, and Environmentally Sensitive Areas from the Proposed 

GLE Facility 

Potential Significance of Impacts 

According to Habitat Typea

Impact Category Upland 

Vegetation Wetlands Environmentally Sensitive Areas 

Vegetation clearing Moderate Small Small 

Habitat fragmentation Moderate Small Small 

Alteration of topography Moderate Small Small 

Changes in drainage patterns Moderate Small Small 

Water depletions Small Small Small 

Erosion and sedimentation Small Small Small 

Contaminant spills Small Small Small 

Fugitive dust Small Small Small 

Soil compaction Moderate Small Small 

Disruption of groundwater flow patterns Small Small Small 

Spread of invasive plant species Small Small Small 

Vegetation maintenance Small Small Small 

Air emissions Small Small Small 

Radiological exposure Small Small Small 

a

 Small impact: environmental effects are not detectable or are so minor that they will neither 

destabilize nor noticeably alter any important attribute of the resource. Moderate impact: 

environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of 

the resource. All moderate impacts would occur during the preconstruction phase. 

1 

2 wetland had a rating of 6 (maximum rating is 100), indicating that the wetland is of low value 

3 (GLE, 2008). 

4 

5 Indirect impacts on wetlands could occur from increased stormwater runoff, decreased 

6 groundwater recharge, disconnected hydrologic conductivity, or changes in groundwater or 

7 surface water flow patterns. Impacts from increased or decreased runoff are expected to be 

8 negligible, as impacts on wetlands would be minimized by use of sediment and erosion control 

9 measures and wetland hydrology would be controlled by the tidal influence of the Northeast 

10 Cape Fear River (GLE, 2008). 

11 

12 A detailed construction design would be prepared prior to preconstruction activities. From this 

13 design, a more precise determination of the potential type and extent of impacts on wetlands 

14 can be determined; and the USACE and North Carolina Division of Water Quality would 

15 determine if wetland mitigation would be required (GLE, 2009e). In conclusion, impacts on 
4-35 

1 wetlands associated with preconstruction and construction activities for the proposed 

2 GLE Facility, including the utility structures and access road, would be SMALL (Table 4-5). 

3 

4 Environmentally Sensitive Areas

5 

6 As discussed in Section 3.8.3, the environmentally sensitive areas (i.e., landscape elements or 

7 places that are crucial to the long-term maintenance of biological diversity, soil, water, and other 

8 natural resources, especially as they relate to human health, safety, and welfare, both at a local 

9 and regional context [Jennings and Reganold 1989]) occurring on or near the Wilmington Site 

10 include the Northeast Cape Fear River Floodplain (includes the southwestern portion of the 

11 Wilmington Site); the primary nursery area for shellfish and fish within the Northeast Cape Fear 

12 River (adjacent to the Wilmington Site); and the floodplains, wetlands, unstable soils, and steep 

13 slopes on the Wilmington Site. Except for the probable impact on a 0.02-hectare (0.06-acre) 

14 isolated wetland and the possible impact on to up to 0.021 hectare (0.052 acre) of three 

15 jurisdictional wetlands, no environmentally sensitive areas would be directly impacted by 

16 preconstruction or construction activities. Only minor, localized, indirect impacts on 

17 environmentally sensitive areas may occur from erosion and sedimentation or from changes in 

18 drainage patterns. Overall, impacts from proposed GLE Facility preconstruction and 

19 construction activities on environmentally sensitive areas would be SMALL (Table 4-5). 

20 

21 Wildlife

22 

23 Impacts on wildlife from preconstruction and construction activities would include (1) habitat 

24 disturbance, (2) wildlife disturbance, and (3) injury or mortality of wildlife. 

25 

26 Habitat Disturbance

27 

28 Most impacts on wildlife from preconstruction and construction activities would occur from 

29 habitat disturbance (e.g., clearing and grading for the proposed GLE Facility). Habitats within 

30 the footprint disturbed by preconstruction and construction activities would be reduced or 

31 altered. Preconstruction and construction activities would also result in habitat fragmentation, 

32 particularly at the proposed GLE Facility. The use of an existing accessway for the new access 

33 road would minimize habitat fragmentation compared to what would otherwise be caused by 

34 creating a new access corridor. As the utility corridor is routed along the North access road, 

35 habitat fragmentation would be reduced. 

36 

37 Preconstruction and construction activities for the proposed GLE Facility and its ancillary 

38 facilities would cause a loss of habitat, which could result in a long-term reduction in wildlife 

39 abundance and richness within the project area. A species affected by habitat disturbance 

40 might be able to shift its habitat use for a short period. For example, the density of several 

41 forest-dwelling bird species has been found to increase within a forest stand soon after the 

42 onset of fragmentation as a result of displaced individuals moving into remaining habitat 

43 (Hagan et al., 1996). However, it is generally assumed that the habitat into which displaced 

44 individuals move would be unable to sustain an increased level of use over the long term. For 

45 example, an increased competition for resources in adjacent habitats would likely preclude the 

46 incorporation of the displaced individual into the resident populations. 

47 
4-36 

1 Habitat disturbance could facilitate the spread and introduction of invasive plant species. Roads 

2 (and other linear corridors) could facilitate the dispersal of invasive plant species by altering 

3 existing habitat conditions, stressing or removing native plant species, and allowing easier 

4 movement by wildlife or human vectors (Trombulak and Frissell, 2000). Wildlife habitat could 

5 also be adversely affected if invasive vegetation became established in the disturbed areas and 

6 adjacent offsite habitats. The establishment of invasive vegetation could reduce habitat quality 

7 for wildlife and locally affect wildlife occurrence and abundance. 

8 

9 Little information is available regarding the effects of fugitive dust on wildlife; however, if 

10 exposure was of sufficient magnitude and duration, the effects could be similar to those on 

11 humans (e.g., breathing and respiratory symptoms, including dust pneumonia). A more 

12 probable effect would be the dusting of plants, which could make forage less palatable. This 

13 localized effect would be short-term and would generally coincide with the displacement of and 

14 stress to wildlife from human activity. Fugitive dust is not expected to result in any long-term 

15 individual or population-level effects. 

16 

17 Wildlife Disturbance

18 

19 Activities associated with preconstruction and construction activities for the proposed 

20 GLE Facility could cause wildlife disturbance, including interference with behavioral activities. 

21 The response of wildlife to disturbances caused by noise and human presence would be highly 

22 variable and species-specific. Intraspecific responses could also be affected by the 

23 physiological or reproductive condition of individuals; distance from the disturbance; and type, 

24 intensity, and duration of the disturbance. Seasonal or daily time of noise events could also be 

25 a factor in how noise would impact wildlife. Wildlife could respond to a disturbance in various 

26 ways, including attraction, habituation, and avoidance (Knight and Cole, 1991). All three 

27 behaviors are considered adverse. For example, wildlife might cease foraging, mating, or 

28 nesting near areas where construction was occurring. In contrast, wildlife such as bears, foxes, 

29 and squirrels could readily habituate and might even be attracted to human activities, primarily 

30 when a food source was accidentally or deliberately made available. 

31 

32 Although habitats adjacent to the proposed GLE site would mostly remain unaffected, wildlife 

33 might tend to make less use of these areas (primarily because of the disturbance that would 

34 occur within the project site). This impact could be considered indirect habitat loss, and it could 

35 be of greater consequence than direct habitat loss. The loss of effective habitat (amount of 

36 habitat actually available to wildlife) due to roads was reported to be 2.5 to 3.5 times as great as 

37 the actual habitat loss (Reed et al., 1996). Many of the individuals that would make use of 

38 areas adjacent to a road or other development could be subjected to increased physiological 

39 stress as a result of complications from overcrowding (e.g., increased competition for space and 

40 food, increased vulnerability to predators, and increased potential for the propagation of 

41 diseases and parasites). This combination of avoidance and stress would reduce the capability 

42 of wildlife to use habitat effectively. 

43 

44 Principal sources of noise during preconstruction and construction activities would include 

45 vehicle traffic and operation of machinery. Regular or periodic noise could cause adjacent 

46 areas to be less attractive to wildlife and result in a long-term reduction in use by wildlife in 

47 those areas. Responses of birds to disturbance often involve activities that are energetically 

48 costly (e.g., flying) or affect their behavior in ways that might reduce food intake (e.g., shift away 
4-37 

1 from a preferred feeding site) (Hockin et al., 1992). A variety of adverse effects of noise on 

2 raptors have been demonstrated, but for some species, the effects were temporary, and the 

3 raptors became habituated to the noise (Brown et al., 1999; Delaney et al., 1999). A review of 

4 the literature by Hockin (1992) showed that the effects of disturbance on bird breeding and 

5 breeding success include reduced nest attendance, nest failures, reduced nest building, 

6 increased predation on eggs and nestlings, nest abandonment, inhibition of laying, increased 

7 absence from nest, reduced feeding and brooding, exposure of eggs and nestlings to heat or 

8 cold, retarded chick development, and lengthening of the incubation period. The most adverse 

9 impacts associated with noise could occur if critical lifecycle activities were disrupted 

10 (e.g., mating and nesting). For instance, disturbance of birds during the nesting season could 

11 result in nest or brood abandonment. The eggs and young of displaced birds would be more 

12 susceptible to cold or predators. 

13 

14 Overall, direct and indirect impacts from habitat and wildlife disturbance could potentially reduce 

15 the carrying capacity of a species range and result in reduced survival or reproduction. 

16 

17 Wildlife Injury or Mortality

18 

19 Clearing, grading, and other preconstruction and construction activities could result in the direct 

20 injury or death of those wildlife species that were not mobile enough to avoid impact areas 

21 (e.g., reptiles, small mammals), those that used burrows (e.g., ground squirrels), or those that 

22 defend nest sites (e.g., ground-nesting birds). If clearing or other construction activities 

23 occurred during the spring and summer, bird nests and eggs or nestlings could be destroyed 

24 and more mobile wildlife species, such as white-tailed deer (Odocoileus virginianus) and adult 

25 birds, might avoid the initial clearing activity by moving into habitats in adjacent areas. 

26 However, as previously mentioned, it is conservatively assumed that adjacent habitats are at 

27 carrying capacity for the species that live there and could not support additional biota from the 

28 construction areas. The subsequent competition for resources in adjacent habitats would likely 

29 preclude the incorporation of the displaced individuals into the resident populations. 

30 

31 Direct mortality from construction equipment would be low, as most equipment would be slow 

32 moving or stationary. Mortality from vehicle collisions would be expected to occur along the 

33 access road. 

34 

35 Wildlife could be exposed to accidental fuel spills or releases of other hazardous materials. 

36 Potential impacts on wildlife would vary according to the material spilled, volume of the spill, 

37 location of the spill, and the exposed species. A spill would be expected to have a population38 level adverse impact only if the spill was very large or if it contaminated a crucial habitat area 

39 where a large number of individual animals were concentrated. The potential for either event is 

40 very unlikely. In addition, use of the project area by wildlife during construction would be limited, 

41 since there would be construction-related disturbances, thus greatly reducing the potential for 

42 contaminant exposure. 

43 

44 In conclusion, impacts on some wildlife from vegetation disturbance, wildlife disturbance, and 

45 injury or mortality could be MODERATE for some groups of wildlife (Table 4-6). Over 

46 75 percent of the impacts would occur during preconstruction activities, when most of the 

47 physical disturbance to habitats would occur. Overall, the adverse impacts of preconstruction 

48 and construction activities are expected to be limited to the immediate vicinity of the proposed 
4-38 

Table 4-6 Significance Levels of Potential Impacts on Wildlife from the Proposed GLE Fa

 Potential Significance of Impacts According to Species Typ

Impact Category Amphibians and Reptiles Shorebirds, Waterfowl, and Waterbirds Landbirds Raptors Small Game and Nongame Mammals 

Vegetation clearing Moderate Small Moderate Moderate Moderate Habitat fragmentation Moderate Small Moderate Moderate Moderate Movement/dispersal blockage Moderate Small Small Small Moderate Alteration of topography Small Small Small Small Small Water depletions Small Small Small Small Small Erosion and sedimentation Small Small Small Small Small Contaminant spills Small Small Small Small Small Fugitive dust Small Small Small Small Small Injury or mortality Moderate Small Small Small Moderate Collection Small Small Small Small Small Human disturbance/harassment Small Small Moderate Moderate Moderate Increases in predation rates Small Small Small Small Small Noise Small Small Moderate Moderate Moderate Spread of invasive plant species Small Small Small Small Small Air pollution Small Small Small Small Small Radiological exposure Small Small Small Small Small a Small impact: environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter a

attribute of the resource. Moderate impact: environmental effects are sufficient to alter noticeably, but not to destabilize, impoof the resource. All moderate impacts would occur during preconstruction activities. 
4-39 

1 GLE Facility (within areas subjected to periodic logging or to routine disturbances within or near 

2 the operations area) and should not affect the viability of any wildlife populations. 

3 

4 Aquatic Biota

5 

6 No aquatic habitats are located within the footprint of the areas that will be cleared for the GLE 

7 Facility. Furthermore, no surface water withdrawals would be used during any phase of the 

8 project. However, portions of four jurisdictional channels, the effluent channel, and Unnamed 

9 Tributary #1 to Prince George Creek occur within the corridor for the new access road and 

10 entrance. Road-crossing construction over these channels could impact aquatic biota by direct 

11 disturbance, deposition of sediments, and degradation of water quality. 

12 

13 Vegetation clearing, grading, and other land-disturbing activities could increase sediment 

14 loadings to nearby water bodies (such as the four jurisdictional channels, the effluent channel, 

15 and Unnamed tributary # 1 to Prince George Creek listed above) and to Unnamed Tributary #1 

16 to Northeast Cape Fear River. These water bodies would ultimately receive stormwater runoff 

17 from the proposed GLE Facility. The effects of suspended sediments on aquatic biota include: 

18 (1) lethal effects (e.g., direct mortality of individuals, population reduction, or damage to the 

19 ecosystem that affects its capacity to produce biota); (2) sublethal effects (e.g., injury to the 

20 tissues or physiology of the organism, but not to the extent that death occurs); and 

21 (3) behavioral effects (e.g., alteration of activity patterns or types of activities that an organism 

22 would normally undertake in an unaffected environment) (Newcombe and MacDonald, 1991). 

23 Implementation of measures to control erosion and runoff into aquatic habitats (Section 4.2.6.3) 

24 would reduce the potential for impacts on aquatic biota. 

25 

26 Contaminants could be introduced into aquatic habitats as a result of the accidental release of 

27 fuels and lubricants used during preconstruction and construction activities. The level of 

28 impacts from releases of toxicants would depend on the type and volume of chemicals entering 

29 the waterway, the location of the release, the nature of the water body (e.g., size, volume, and 

30 flow rates), and the types and life stages of organisms present in the receiving waterway. In 

31 general, lubricants and fuel would not be expected to enter waterways in appreciable quantities 

32 as long as heavy machinery is not used in or near waterways, fueling locations for construction 

33 equipment are situated away from the waterway, and measures are taken to control spills that 

34 do occur. 

35 

36 No significant adverse impacts on aquatic biota (e.g., population-level effects) are expected 

37 from preconstruction and construction activities. All activities associated with preconstruction 

38 and construction activities would result in SMALL impacts on aquatic biota (Table 4-7). 

39 

40 Threatened, Endangered, and Other Special Status Species

41 

42 Tables 3-14 and 3-15 in Section 3.8.6 list the threatened, endangered, and other special status 

43 species reported from New Hanover County, and indicate which species have been reported or 

44 are potentially present on or near the Wilmington Site. The tables also indicate which species 

45 could potentially be present in the proposed GLE Facility area. The types of impacts that could 

46 affect species as a result of preconstruction and construction activities for the proposed 

47 GLE Facility would be fundamentally similar to or the same as those described above for 
4-40 

Table 4-7 Significance Levels of Potential Impacts on 

Aquatic Biota from the Proposed GLE Facility 

Impact Category Potential Significance of 

Impacts on Aquatic Biotaa

Sedimentation from runoff Small 

Water depletions Small 

Changes in drainage patterns Small 

Disruption of groundwater flow patterns Small 

Temperature increases in water bodies Small 

Contaminant spills Small 

Movement/dispersal blockage Small 

Increased human access Small 

Radiological exposure Small 

a

 Small impact: environmental effects are not detectable or are so minor that 

they will neither destabilize nor noticeably alter any important attribute of the 

resource. Impacts on aquatic biota would be small for all project phases 

(i.e., preconstruction, construction, and operations). 

1 

2 vegetation, wildlife, and aquatic biota. The most important difference from these impacts is the 

3 potential consequence of the impacts. Because of low population sizes, threatened, 

4 endangered, and other special status species are more vulnerable to impacts (e.g., habitat 

5 disturbance) than more common and widespread species. 

6 

7 A copy of the consultation letters received from the U.S. Fish and Wildlife Service (FWS) and 

8 National Marine Fisheries Service (NMFS) are provided in Appendix B. The FWS expressed 

9 potential concerns for those species that could occur on the Wilmington Site – the West Indian 

10 manatee (Trichechus manatus), roughleaf loosestrife (Lysimachia asperulaefolia), and, in 

11 particular, the red-cockaded woodpecker (Picoides borealis) (FWS, 2009). Information provided 

12 in the FWS correspondence has been incorporated into the evaluations below on Federally 

13 listed species and are listed as additional mitigation measures presented in Section 4.2.8.3. 

14 The NMFS provided various publications on the shortnose sturgeon (Acipenser brevirostrum). 

15 Information from these reports was considered in the assessment of potential impacts on the 

16 shortnose sturgeon presented below. 

17 

18 Federally Listed Species

19 

20 The following text provides an assessment of impacts from preconstruction and construction 

21 activities for the proposed GLE Facility on the Federally listed species (endangered, threatened, 

22 and species of concern) that exist or may exist in the Wilmington Site area. No impacts would 

23 be expected on any of the listed species. The significance level of impacts on all listed species 

24 would be SMALL. 

25 
4-41 

1 Carolina bishopweed (Ptilimnium ahlesii) 

2 

3 The Carolina bishopweed is a Federal species of concern that inhabits freshwater tidal marshes 

4 (Weakley, 2008). No occurrence records for the Carolina bishopweed occur within 

5 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). Tidal marshes would not be 

6 impacted by preconstruction and construction activities for the proposed GLE Facility; therefore, 

7 these activities would have no effect on the Carolina bishopweed. 

8 

9 Coastal goldenrod (Solidago villosicarpa) 

10 

11 The coastal goldenrod is a Federal species of concern. It occurs in a wide variety of wooded 

12 habitats, occurring in areas associated with natural or human-caused disturbance 

13 (CPC, 2008a). An occurrence record for the coastal goldenrod occurs within 3.2 kilometers 

14 (2 miles) of the northern boundary of the Wilmington Site (NCNHP, 2009). Habitat suitable for 

15 the coastal goldenrod occurs in the pine-hardwood forests in the north-central and south-central 

16 portions of the Wilmington Site (GLE, 2008). Preconstruction and construction activities for the 

17 proposed GLE Facility would disturb habitat that would be potentially suitable for the coastal 

18 goldenrod and may therefore also result in mortality to some individuals. Therefore, these 

19 activities may affect, but are unlikely to adversely affect, the species. Clearing and grading that 

20 would take place during preconstruction activities would account for nearly the entire amount of 

21 habitat disturbance that would occur. 

22 

23 Grassleaf arrowhead (Sagittaria graminea var. weatherbiana) 

24 

25 The grassleaf arrowhead is a Federal species of concern. It inhabits shallow water and wet 

26 shores of ponds, marshes, and ditches. There are no occurrence records for the grassleaf 

27 arrowhead within 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). 

28 Preconstruction and construction activities for the proposed GLE Facility would disturb habitat 

29 that would be potentially suitable for the grassland arrowhead (e.g., the jurisdictional channels 

30 and wetlands associated with the North access road.) Therefore, these activities may affect, but 

31 are unlikely to adversely affect, the species. Clearing and grading that would take place during 

32 preconstruction activities would account for nearly the entire amount of habitat disturbance that 

33 would occur. 

34 

35 Pickering’s morning-glory (Stylisma pickeringii var. pickeringii) 

36 

37 The Pickering’s morning-glory (also known as Pickering’s dawnflower) is a Federal species of 

38 concern. The species occurs in dry to extremely dry, nutrient-poor, well-drained, coarse sandy 

39 soils. Tree cover, ground cover, and litter accumulation are generally sparse 

40 (Patrick et al., 1995). It generally forms large mats or clumps in dry, barren, deep sand areas 

41 such as the edge of Carolina bays and relic riverine dunes (CPC, 2008b; Weakley, 2008). 

42 Preferred locations include frequently burned or clearcut areas with little or no competing 

43 vegetation (CPC, 2008b). There is a 1958 occurrence record for the Pickering’s morning-glory 

44 within 3.2 kilometers (2 miles) of the proposed GLE Facility area (NCNHP, 2009). The 

45 operations area in the northwestern portion of the Wilmington Site contains deep sands that are 

46 periodically disturbed, and may provide suitable habitat for the Pickering’s morning-glory 

47 (GLE, 2008). This area may be used as a source of fill or for the deposition of soils excavated 

48 during preconstruction and construction activities for the proposed GLE Facility; therefore, these 
4-42 

1 activities may affect, but are unlikely to adversely affect, the species. The need for or disposal 

2 of fill would primarily occur during preconstruction activities. 

3 

4 Pondspice (Litsea aestivalis) 

5 

6 Pondspice is a Federal species of concern. It inhabits the margins of swamps, cypress ponds, 

7 low wet woodlands, and sandhill depressions on wet, sandy or peaty, acidic soils. There is a 

8 1977 occurrence record for the pondspice around the perimeter of an ephemeral pond within 

9 the north-central portion of the Wilmington Site (GLE, 2008; NCNHP, 2009). However, 

10 hydrological conditions of this pond have since been altered and do not appear to support 

11 recruitment of the species. During field surveys for the ER, the existing plants appeared 

12 stressed (GLE, 2008). The location of the proposed GLE Facility is over 150 meters (500 feet) 

13 southeast of the ephemeral pond (GLE, 2008). Habitat suitable for the pondspice would not be 

14 impacted by preconstruction and construction activities for the proposed GLE Facility; therefore, 

15 these activities would have no effect on the species. 

16 

17 Raven’s seedbox (Ludwigia ravenii) 

18 

19 Raven’s seedbox is a Federal species of concern. It is an obligate wetland species that inhabits 

20 open, wet, peaty areas such as ditches and the margins of swamps, ponds, and bogs. There 

21 are no occurrence records for the Raven’s seedbox within 3.2 kilometers (2 miles) of the 

22 Wilmington Site (NCNHP, 2009). A minor amount of habitat potentially suitable for the Raven’s 

23 seedbox could not be impacted by preconstruction and construction activities for the proposed 

24 North access road. Therefore, these activities may affect, but are unlikely to adversely affect, 

25 the species. Clearing and grading that would take place during preconstruction activities would 

26 account for nearly the entire amount of habitat disturbance that would occur. 

27 

28 Roughleaf loosestrife (Lysimachia asperulaefolia) 

29 

30 The roughleaf loosestrife is a Federally endangered species. It occurs in grass–shrub ecotones 

31 adjacent to longleaf pine/scrub oak, pine savanna, flatwoods, and pond pine pocosins 

32 (evergreen shrub bogs). It prefers full sunlight and is shade intolerant (CPC, 2008c; 

33 NCNHP, 2001). It grows on moist, seasonally saturated sands or shallow organic soils 

34 overlying sands. The roughleaf loosestrife has been found in roadside depressions, firebreaks, 

35 seeps, and power ROWs (NCNHP, 2001). Habitats within which the species occurs are usually 

36 fire-maintained (i.e., areas where natural fires or controlled burns occur). There are no 

37 occurrence records for the roughleaf loosestrife within 3.2 kilometers (2 miles) of the Wilmington 

38 Site (NCNHP, 2009). Most pocosin habitat that could potentially support the species has been 

39 drained from the Wilmington Site and the fire regime necessary for maintaining the species 

40 habitat does not occur on the site. Also, habitat for the species is not present within the 

41 proposed GLE Facility area (GLE, 2008); therefore, preconstruction and construction activities 

42 would have no effect on the roughleaf loosestrife. 

43 

44 Sandhills milkvetch (Astragalus michauxii) 

45 

46 The sandhills milkvetch is a Federal species of concern. It inhabits longleaf pine/scrub oak 

47 woodlands, growing best in disturbed or fire-prone open understory areas (e.g., xeric to 

48 dry-mesic, nutrient-poor soils, thickets, field edges, and road banks). There is a 1946 
4-43 

1 occurrence record for the sandhills milkvetch within 3.2 kilometers (2 miles) of the proposed 

2 GLE Facility area (NCNHP, 2009; GLE, 2008). The longleaf pine/scrub forest in the 

3 northwestern portion of the Wilmington Site and the pine plantation in the north-central portion 

4 of the site could provide suitable habitat for the species. Preconstruction and construction 

5 activities for the proposed GLE Facility would disturb habitat that would potentially be suitable 

6 for the sandhills milkvetch; therefore, these activities may affect, but are unlikely to adversely 

7 affect, the species. Clearing and grading that would take place during preconstruction activities 

8 would account for nearly the entire amount of habitat disturbance that would occur. 

9 

10 Small-leaf meadowrue (Thalictrum macrostylum) 

11 

12 The small-leaf meadowrue is a Federal species of concern. Habitat for the species includes 

13 swampy woodlands, slopes, and cliffs. There are no occurrence records for the small-leaf 

14 meadowrue within 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). Habitat 

15 suitable for the small-leaf meadowrue would not be impacted by preconstruction and 

16 construction activities for the proposed GLE Facility; therefore, these activities would have no 

17 effect on the species. 

18 

19 Spring-flowering goldenrod (Solidago verna) 

20 

21 The spring-flowering goldenrod is a Federal species of concern. It inhabits a wide variety of 

22 habitats such as pine savannas, pocosins, pine barrens, open woods, fields, dry bogs, and 

23 disturbed roadsides (CPC, 2008d). There are no occurrence records for the spring-flowering 

24 goldenrod within 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). Pocosin/bay 

25 and pine forests potentially provide limited habitat for the spring-flowering goldenrod on the 

26 Wilmington Site (GLE, 2008). Preconstruction and construction activities for the proposed 

27 GLE Facility would disturb habitat that would potentially be suitable for the spring-flowering 

28 goldenrod; therefore, these activities may affect, but are unlikely to adversely affect, the 

29 species. Clearing and grading that would take place during preconstruction activities would 

30 account for nearly the entire amount of habitat disturbance that would occur. 

31 

32 Venus’ flytrap (Dionaea muscipula) 

33 

34 The Venus’ flytrap is a Federal species of concern. It inhabits bogs and perennially wet areas, 

35 often located between longleaf pine savannas and pocosins on the coastal plains of the 

36 Carolinas (Floridata, 2003). Two occurrence records of the Venus’ flytrap have been recorded 

37 within 3.2 kilometers (2 miles) of the Wilmington Site, one of which is also within 3.2 kilometers 

38 (2 miles) of the proposed GLE Facility area (NCNHP, 2009). Suitable habitat for the Venus’ 

39 flytrap occurs within the western portion of the Wilmington Site where pine forest and pocosin 

40 habitats are adjacent to each other. Habitat suitable for the Venus’ flytrap would not be 

41 impacted by preconstruction and construction activities for the proposed GLE Facility; therefore, 

42 these activities would have no effect on the species. 

43 

44 Cape Fear threetooth (Triodopsis soelneri) 

45 

46 The Cape Fear threetooth is a Federal species of concern. It is a terrestrial snail that occurs on 

47 logs and under litter in swamps and under trash in pine woods (Hubricht, 1985). There are no 

48 occurrence records for the Cape Fear threetooth within 3.2 kilometers (2 miles) of the 
4-44 

1 Wilmington Site (NCNHP, 2009). Preconstruction and construction activities for the proposed 

2 GLE Facility would disturb habitat that would be potentially suitable for the Cape Fear threetooth 

3 (pine woods); therefore, these activities may affect, but are unlikely to adversely affect, the 

4 species. Clearing and grading that would take place during preconstruction activities would 

5 account for nearly the entire amount of habitat disturbance that would occur. 

6 

7 Eastern arogos skipper (Atrytone arogos arogos) 

8 

9 The eastern arogos skipper is a Federal species of concern. It inhabits native grasslands and 

10 savannas. There are no occurrence records for the eastern arogos skipper within 

11 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). Habitat suitable for the eastern 

12 arogos skipper would not be impacted by preconstruction and construction activities for the 

13 proposed GLE Facility; therefore, these activities would have no effect on the species. 

14 

15 Greenfield ramshorn snail (Helisoma eucosmium) 

16 

17 The Greenfield ramshorn snail is a Federal species of concern. Within New Hanover County, 

18 this freshwater snail is only known from Greenfield Lake in Wilmington. It is also known from 

19 Town Creek in Brunswick County and from the Wisconsin River in the northeastern portion of 

20 the State. Specimens from Town Creek inhabit densely vegetated areas at depths less than 

21 3 meters (10 feet). There are no occurrence records for the Greenfield ramshorn snail within 

22 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). Habitat suitable for the 

23 Greenfield ramshorn snail would not be impacted by preconstruction and construction activities 

24 for the proposed GLE Facility; therefore, these activities would have no effect on the species. 

25 

26 Rare skipper (Problema bulenta) 

27 

28 The rare skipper is a Federal species of concern. It inhabits marshes along tidal rivers. There 

29 are no occurrence records for the rare skipper within 3.2 kilometers (2 miles) of the Wilmington 

30 Site (NCNHP, 2009). Habitat suitable for the rare skipper would not be impacted by 

31 preconstruction and construction activities for the proposed GLE Facility; therefore, these 

32 activities would have no effect on the species. 

33 

34 American eel (Anguilla rostrata) 

35 

36 The American eel is a Federal species of concern. It spawns in the Sargasso Sea and matures 

37 in fresh or brackish waters (estuaries, rivers, streams, ponds, and lakes (NatureServe, 2009). 

38 There are no occurrence records for the American eel within 3.2 kilometers (2 miles) of the 

39 Wilmington Site (NCNHP, 2009). However, the American eel is expected to occur in the 

40 Northeast Cape Fear River near the Wilmington Site (NCDENR, 2008). The river’s tributaries 

41 on the site could also provide suitable habitat for the American eel. Habitat suitable for the 

42 American eel would not be impacted by preconstruction and construction activities for the 

43 proposed GLE Facility; therefore, these activities would have no effect on the species. 

44 

45 Shortnose sturgeon (Acipenser brevirostrum) 

46 

47 The shortnose sturgeon is Federally listed as endangered. It inhabits the lower reaches of large 

48 rivers and Atlantic coastal waters. It primarily occurs in brackish and salt waters of lower 
4-45 

1 coastal river reaches and river estuaries. The shortnose sturgeon ascends into the freshwaters 

2 of larger coastal rivers to spawn. Larvae and juveniles prefer deep river channels. It is very 

3 rare in the Cape Fear River drainage. There is a 1993 occurrence record for the shortnose 

4 sturgeon within 3.2 kilometers (2 miles) of the Wilmington Site (NCNHP, 2009). It may occur in 

5 the Northeast Cape Fear River and the lower portions of its unnamed tributaries that occur on 

6 the Wilmington Site. It does not ascend into smaller tributaries such as the Prince George 

7 Creek (NOAA, 2002). Habitat suitable for the shortnose sturgeon would not be impacted by 

8 preconstruction and construction activities for the proposed GLE Facility; therefore, these 

9 activities would have no effect on the species. 

10 

11 Carolina gopher frog (Rana capito capito) 

12 

13 The Carolina gopher frog is a Federal species of concern. Adults primarily inhabit xeric 

14 uplands, especially longleaf pine-turkey oak sandhill associations. They also occur in xeric to 

15 mesic longleaf pine flatwoods, sand pine scrub, and xeric oak hammocks. Burrows of gopher 

16 tortoises (Gopherus polyphemus) and rodents are used for shelter. They will also hide in 

17 sewers, under logs, and in or under stumps. Breeding habitat includes ephemeral to 

18 semipermanent graminoid-dominated wetlands that lack large predatory fishes. There are no 

19 occurrence records for the Carolina gopher frog within 3.2 kilometers (2 miles) of the Wilmington 

20 Site (NCNHP, 2009). Habitat suitable for the Carolina gopher frog would not be impacted by 

21 preconstruction and construction activities for the proposed GLE Facility; therefore, these 

22 activities would have no effect on the species. 

23 

24 American alligator (Alligator mississippiensis) 

25 

26 The American alligator is Federally listed as threatened due to its similarity of appearance with 

27 the American crocodile (Crocodylus acutus). However, the American alligator is not biologically 

28 threatened and does not have protection under the Endangered Species Act in North Carolina 

29 (Hall, 2009). It inhabits slow-moving coastal rivers, canals, lakes, impoundments, marshes, 

30 cypress ponds, and estuaries. The American alligator has been recorded from various localities 

31 near the Wilmington Site, including the Prince George Creek at its confluence with its Unnamed 

32 Tributary #1; the Northeast Cape Fear River at its confluence with Prince George Creek; 

33 upstream of the Wilmington Site in Turkey Creek, Morgan Creek, and Long Creek; and south of 

34 the Wilmington Site in Ness Creek (GLE, 2008). Occurrences of the American alligator have 

35 been reported within 3.2 kilometers (2 miles) of the proposed GLE Facility area (NCNHP, 2009). 

36 At the Wilmington Site, potential breeding habitat occurs along the Northeast Cape Fear River 

37 and its tributaries, and small alligators may occur within the streams and swamp forest area of 

38 the site. Habitat suitable for the American alligator would not be impacted by preconstruction 

39 and construction activities for the proposed GLE Facility; therefore, these activities would have 

40 no effect on the species. 

41 

42 Mimic glass lizard (Ophisaurus mimicus) 

43 

44 The mimic glass lizard is a Federal species of concern. It inhabits longleaf pine savannas and 

45 conifer and mixed woodlands where it burrows in the soil or inhabits fallen logs and woody 

46 debris. There are no occurrence records for the mimic glass lizard within 3.2 kilometers 

47 (2 miles) of the Wilmington Site (NCNHP, 2009). Preconstruction and construction activities for 

48 the proposed GLE Facility would disturb habitat that would potentially be suitable for the mimic 
4-46 

1 glass lizard; therefore, these activities may affect, but are unlikely to adversely affect, the 

2 species. Clearing and grading that would take place during preconstruction activities would 

3 account for nearly the entire amount of habitat disturbance that would occur. 

4 

5 Northern pinesnake (Pituophis melanoleucus melanoleucus) 

6 

7 The northern pinesnake is a Federal species of concern. It inhabits xeric pine forest uplands. 

8 There is a pre-1927 occurrence record for the northern pine snake within 3.2 kilometers 

9 (2 miles) of the proposed GLE Facility area (NCNHP, 2009). Preconstruction and construction 

10 activities for the proposed GLE Facility would disturb habitat that would potentially be suitable 

11 for the northern pine snake; therefore, these activities may affect, but are unlikely to adversely 

12 affect, the species. Clearing and grading that would take place during preconstruction activities 

13 would account for nearly the entire amount of habitat disturbance that would occur. 

14 

15 Southern hog-nosed snake (Heterodon simus) 

16 

17 The southern hog-nosed snake is a Federal species of concern. It inhabits mature pine forests 

18 and sandhill habitats (Jordan, 1998) and spends most of its time buried in soil. Sightings of the 

19 southern hog-nosed snake have been made southwest of the Wilmington Site between the 

20 Northeast Cape Fear River and the Cape Fear River (GLE, 2008). There are no occurrence 

21 records for the southern hog-nosed snake within 3.2 kilometers (2 miles) of the Wilmington Site 

22 (NCNHP, 2009). Within the Wilmington Site, the snake could occur within the pine forests, 

23 longleaf pine/scrub forests, hardwood forests, and fields. The xeric, sandy soils in the 

24 northwestern portion of the site may also be suitable habitat. Preconstruction and construction 

25 activities for the proposed GLE Facility would disturb habitat that would potentially be suitable 

26 for the southern hog-nosed snake; therefore, these activities may affect, but are unlikely to 

27 adversely affect, the species. Clearing and grading that would take place during 

28 preconstruction activities would account for nearly the entire amount of habitat disturbance that 

29 would occur. 

30 

31 Eastern painted bunting (Passerina ciris ciris) 

32 

33 The eastern painted bunting is a Federal species of concern. Habitat includes partly opened 

34 areas with scattered trees and brush, riparian thickets and brush, weedy and shrubby areas, 

35 woodland edges, yards, and gardens. Salt marsh/forest edges are preferred over interior 

36 forests. There are no occurrence records for the eastern painted bunting within 3.2 kilometers 

37 (2 miles) of the Wilmington Site (NCNHP, 2009). Preconstruction and construction activities for 

38 the proposed GLE Facility would disturb habitat that would potentially be suitable for the eastern 

39 painted bunting; therefore, these activities may affect, but are unlikely to adversely affect, the 

40 species. Clearing and grading that would take place during preconstruction activities would 

41 account for nearly the entire amount of habitat disturbance that would occur. 

42 

43 Red-cockaded woodpecker (Picoides borealis) 

44 

45 The red-cockaded woodpecker is Federally listed as endangered. No critical habitat has been 

46 designated for the species (FWS, 2008). Habitat that probably supported the largest 

47 populations was Coastal Plain longleaf pine forests maintained by frequent fires 

48 (Ozier et al., 1999). It requires open stands of mature pine (over 60 years old) for nesting and 
4-47 

1 roosting habitat. Nesting and roosting occur in cavities of live trees that range in age from 63 to 

2 over 300 years old for longleaf pine or 62 to over 200 years old for loblolly and other pines. An 

3 aggregate (cluster) of 1 to 20 cavity trees are used on an area of 1.2 to 24.3 hectares (3 to 

4 60 acres) (FWS, 2003; NatureServe, 2009). Suitable habitat surrounding a cluster of cavity 

5 trees contains open, park-like conditions. Stands of pine or mixed pines and hardwoods that 

6 are over 30 years old are used for foraging. A group requires at least 32.4 to 50.6 hectares 

7 (80 to 125 acres) of foraging habitat. The territory for a group averages about 81 hectares 

8 (200 acres), but can range from 24.3 to over 243 hectares (60 to over 600 acres) (FWS, 2003). 

9 

10 An active red-cockaded woodpecker colony occurs within 8 kilometers (5 miles) northeast of the 

11 Wilmington Site. It is located just north of the Northeast Cape Fear River along NC 117 in 

12 Pender County (GLE, 2008). There are several occurrence records for the red-cockaded 

13 woodpecker within 3.2 kilometers (2 miles) of the western border of the Wilmington Site 

14 (NCNHP, 2009). No cavity trees were observed on the Wilmington Site during field surveys 

15 conducted in support of the ER (GLE, 2008). The forested habitats on the Wilmington Site meet 

16 the minimum area requirements needed for foraging habitat. However, the lack of mature 

17 forests would limit the value of the Wilmington Site as foraging habitat. The Sledge Forest, a 

18 property containing over 1619 hectares (4000 acres) of high-quality forests directly adjacent to 

19 and north of the Wilmington Site, does contain loblolly and longleaf pine trees that are over 

20 300 years old. This area would be suitable as nesting and roosting habitat for the red-cockaded 

21 woodpecker. It is possible that woodpeckers that forage in the Sledge Forest could occasionally 

22 forage within the western forested portion of the Wilmington Site. 

23 

24 No cavity trees or trees more than 30 years old were observed in the proposed GLE Facility 

25 area. Most of the area within which the proposed GLE Facility would be located has been 

26 logged within the last 20 years or less (GLE, 2008). It is not expected that habitat suitable for 

27 the red-cockaded woodpecker would be impacted by preconstruction and construction activities 

28 for the proposed GLE Facility; therefore, these activities would have no effect on the species. 

29 However, prior to preconstruction activities, GLE (in consultation with FWS) would conduct 

30 surveys for the presence of suitable foraging habitat. If foraging habitat is found, further surveys 

31 would be conducted to locate potential cavity trees (GLE, 2009f). 

32 

33 Rafinesque’s big-eared bat (Corynorhinus rafinesquii) 

34 

35 The Rafinesque’s big-eared bat is a Federal species of concern. The species occurs in forested 

36 areas. Summer roosts include hollow trees, loose bark, or abandoned buildings in or near 

37 wooded areas. Bridges are also used as day roosts and as maternity roosts. Foraging habitat 

38 is primarily among the canopies of mature upland and lowland forests (Ozier et al. 1999). There 

39 is a pre-2006 occurrence record for the Rafinesque’s big-eared bat within 3.2 kilometers 

40 (2 miles) of the proposed GLE Facility area (NCNHP, 2009). Preconstruction and construction 

41 activities for the proposed GLE Facility would disturb habitat that would potentially be suitable 

42 for the Rafinesque’s big-eared bat; therefore, these activities may affect, but are unlikely to 

43 adversely affect, the species. Clearing and grading that would take place during 

44 preconstruction activities would account for nearly the entire amount of habitat disturbance that 

45 would occur. 

46 
4-48 

1 Southeastern myotis (Myotis austroriparius) 

2 

3 The southeastern myotis is a Federal species of concern. It roosts in caves, buildings, and 

4 snags and hollow trees of pine and hardwood forests, and forages primarily in riparian areas, 

5 but also in various upland habitats. There is a 1986 occurrence record for the southeastern 

6 myotis within 3.2 kilometers (2 miles) of the proposed GLE Facility area from floodplains north of 

7 the Wilmington Site near the confluence of the Northeast Cape Fear River and Prince George 

8 Creek (NCNHP, 2009; GLE, 2008). The riparian habitats and pine and hardwood forests on the 

9 Wilmington Site provide suitable foraging and breeding habitat for the southeastern myotis. It 

10 may also forage in the operations area and transmission line ROWs. Preconstruction and 

11 construction activities for the proposed GLE Facility would disturb habitat that would potentially 

12 be suitable for the southeastern myotis; therefore, these activities may affect, but are unlikely to 

13 adversely affect, the species. Clearing and grading that would take place during 

14 preconstruction activities would account for nearly the entire amount of habitat disturbance that 

15 would occur. 

16 

17 West Indian manatee (Trichechus manatus) 

18 

19 The West Indian manatee is Federally listed as endangered. It inhabits shallow coastal bays, 

20 lagoons, estuaries, and rivers. The manatee usually inhabits waters with a depth of 1 to 

21 6 meters (3.3 to 20 feet) (Hall, 2009; NatureServe, 2009). Much of their time is spent 

22 submerged or partly submerged. Manatees feed on aquatic vegetation. It is a seasonal 

23 inhabitant of North Carolina, being present mainly from June through October. There are no 

24 occurrence records for the West Indian manatee within 3.2 kilometers (2 miles) of the 

25 Wilmington Site (NCNHP, 2009). However, the Northeast Cape Fear River and some of its 

26 tributaries in the area of the Wilmington Site may provide suitable habitat for manatee 

27 (Hall, 2009). Habitat suitable for the West Indian manatee would not be impacted by 

28 preconstruction and construction activities for the proposed GLE Facility; therefore, these 

29 activities would have no effect on the species. 

30 

31 State-Listed Species

32 

33 Based on the information provided in Table 3-15 (Section 3.8.6.2), a number of State rare 

34 species reported from New Hanover County could be impacted by preconstruction and 

35 construction activities for the proposed GLE Facility (i.e., those species listed as potentially 

36 present on or near the GLE Facility). Impacts on State-listed species would primarily be due to 

37 habitat disturbance that occurs from clearing and grading during preconstruction activities. No 

38 impacts would be expected to any of the State-listed species. The significance level of impacts 

39 on all State-listed species would be SMALL. 

40 

41 4.2.8.2 Operations and Maintenance 

42 

43 This section evaluates the potential impacts of the proposed GLE Facility’s operations on 

44 ecological resources. 

45 
4-49 

1 Vegetation

2 

3 No additional lands beyond those disturbed during preconstruction and construction activities 

4 would be affected by operation of the proposed GLE Facility. Activities associated with the 

5 operation and maintenance of the proposed GLE Facility would include mowing, hand-cutting, 

6 and chemical control of vegetation at the proposed GLE Facility, adjacent facilities 

7 (e.g., substation), utility corridors, and along the access road. The transmission line ROW 

8 would be maintained on a 3-year cycle, while cutting of danger trees would occur on a 7- to 

9 9-year cycle (GLE, 2009e). The diversity of plant species in these areas is generally kept at a 

10 reduced level. In addition to mowing or hand-cutting, herbicides may be used on a very limited 

11 basis to control vegetation within the transmission line ROW on a 5-year cycle (GLE, 2009e). 

12 Herbicide applications may result in impacts on nontarget species from herbicide drift during 

13 application. 

14 

15 Landscaping within the proposed GLE Facility area would be expected to be similar to other 

16 operations areas. Lawn areas would be planted in Bahia grass (Paspalum notatum) and 

17 centipede grass (Eremochloa ophiuroides) and various trees and shrubs (GLE, 2008). A 

18 cleared security buffer would be maintained around the GLE Facility (GLE, 2009e). 

19 

20 Due to the relatively small size of the cooling tower to be used at the proposed GLE Facility, 

21 humidity, fogging, or salt deposition would not be of concern to vegetation. At most, only a 

22 localized area of landscaped lawn near the cooling tower may be impacted. No apparent 

23 impacts on vegetation were observed near the similarly sized FMO cooling tower. 

24 

25 Normal operation of the proposed GLE Facility would result in the generation of air emissions, 

26 wastewaters, and solid wastes that would be treated onsite before being discharged or shipped 

27 for disposal offsite. Therefore, no impacts on vegetation due to GLE Facility operations would 

28 be anticipated. 

29 

30 The radiological exposures from the proposed GLE Facility’s operations would not adversely 

31 affect humans (Section 4.2.11.2). The level of radiological safety required for the protection of 

humans is considered adequate for other animals and plants.12 32 Therefore, normal operation of 

33 the proposed GLE Facility would not have adverse effects on ecological resources resulting 

34 from radionuclide releases. 

35 

36 Table 4-5 summarizes the significance levels of impacts on vegetation that could occur from the 

37 proposed GLE Facility. Impacts on vegetation related to the operation of the proposed 

38 GLE Facility would be SMALL. 

39 

 

12 Acute doses of 10 rad (0.1 gray) or less are very unlikely to produce persistent, measurable 

deleterious changes in populations or communities of terrestrial plants or animals. In addition, there is 

no convincing evidence from the scientific literature that chronic radiation dose rates below 0.1 rad per 

day (1.0 milligray per day) will harm animal or plant populations. These conclusions are based on 

population studies that were available at the time (IAEA, 1992; DOE, 2002). The International Atomic 

Energy Agency is continuing to review and discuss concepts for a radiological protection framework 

for the environment, to include appropriate effect levels and dose limits for biota. 
4-50 

1 Wetlands

2 

3 The operation of the proposed GLE Facility would not encroach upon or have any other adverse 

4 effect on wetlands. Impervious surfaces within a watershed generally result in increased runoff 

5 and reduced infiltration, causing changes in the frequency or duration of inundation or soil 

6 saturation and greater fluctuations in wetland water levels. However, the routing of GLE Facility 

7 drainage to the stormwater retention basin would minimize the potential for wetland water-level 

8 fluctuations. 

9 

10 Table 4-5 summarizes the significance levels of impacts on wetlands that could occur from the 

11 proposed GLE Facility. Impacts on wetlands related to the operation of the proposed 

12 GLE Facility would be SMALL. 

13 

14 Environmentally Sensitive Areas

15 

16 Other than the potentially minor impacts on wetlands discussed above, no environmentally 

17 sensitive areas would be impacted by operation of the proposed GLE Facility. Therefore, 

18 impacts on environmentally sensitive areas from operation of the proposed GLE Facility would 

19 be SMALL (Table 4-5). 

20 

21 Wildlife

22 

23 Potential impacts on wildlife from operation of the proposed GLE Facility would include: 

24 (1) ongoing habitat disturbance (i.e., reduction, alteration, and fragmentation of habitat due to 

25 the presence and maintenance of the proposed GLE Facility and support facilities such as the 

26 substation, the access road, and transmission line); (2) wildlife disturbance (e.g., from noise and 

27 the presence of workers); and (3) wildlife injury or mortality (e.g., from collisions with the water 

28 tower, transmission line, buildings, or vehicles, and from the exposure to contaminants). 

29 

30 Habitat Disturbance

31 

32 In general, the presence of the proposed GLE Facility (and associated maintenance) could 

33 result in areas that were once considered areas with a high probability of being used by wildlife 

34 becoming areas of lower habitat use. Maintenance of landscaped areas generally keeps wildlife 

35 diversity lower than surrounding habitats. Wildlife species occurring on sites within security 

36 areas are typically limited by low habitat quality and generally include common species adapted 

37 to industrial sites. The stormwater detention basin and associated drainage ditches could 

38 provide habitat capable of supporting some wildlife species (e.g., amphibians, waterfowl). 

39 Because the project area would be fenced, big game and other larger mammal species would 

40 be physically excluded from the proposed GLE Facility site. 

41 

42 Periodic maintenance of the transmission line ROW in forested areas would maintain the ROW 

43 in an early stage of plant community succession, which could benefit small mammals and their 

44 predators. Regrowth of trees following maintenance could benefit white-tailed deer that feed on 

45 the leaves, twigs, and young shoots of trees and shrubs. Conversely, habitat maintenance 

46 would have localized adverse effects on species that prefer late-successional or forested 

47 habitats. ROW vegetation maintenance would not be expected to occur more often than once 

48 every three years. This would lessen impacts on wildlife species that might use the ROW. No 
4-51 

1 distinct travel or migratory corridors for wildlife species occur on the Wilmington Site. Therefore, 

2 the presence of the proposed GLE Facility would not impact wildlife movement. As the 

3 proposed GLE Facility would not be located near stream corridors, species such as the 

4 American black bear (Ursus americanus) that tend to travel along densely vegetated stream 

5 banks would not be impacted. The edge habitat established between the existing forested 

6 areas and the proposed GLE Facility could attract species such as white-tailed deer and wild 

7 turkey (Meleagris gallopavo) (GLE, 2008). 

8 

9 Wildlife Disturbance

10 

11 During operation and maintenance of the proposed GLE Facility, wildlife could be disturbed by 

12 noise and the presence of workers. The activities associated with operation of the proposed 

13 GLE Facility that could generate noise include transmission lines (corona), vehicles, 

14 maintenance equipment, and plant operations. The response of wildlife to these disturbances 

15 would be highly variable and depend on the species; distance; timing; and the type, intensity, 

16 and duration of the disturbance. Disturbance impacts on wildlife during operations and 

17 maintenance would be similar to those discussed for preconstruction and construction activities 

18 (Section 4.2.8.1). For example, some individual wildlife might temporarily or permanently move 

19 from the project area. Wildlife permanently moving from the area might incur high mortality 

20 rates if the surrounding habitats were at or near carrying capacity or if the surrounding areas 

21 lacked habitat capable of supporting the displaced individuals. 

22 

23 During operations and maintenance, vegetation maintenance would be required (e.g., regularly 

24 within the landscaped project area and along the access road and about every three years 

25 within the transmission line ROW). Because of the temporary nature of maintenance activities, 

26 disturbance from noise and human presence would be localized and of short duration. During 

27 vegetation-clearing operations, wildlife would be displaced to adjacent undisturbed habitats; 

28 however, less mobile individuals could be destroyed. 

29 

30 Night lighting could also disturb wildlife in the project area. Lights can directly attract migratory 

31 birds (particularly in inclement weather and during low-visibility conditions) and can indirectly 

32 attract birds and bats by attracting flying insects. Attraction to lights can increase the potential 

33 for birds to collide with structures. 

34 

35 Wildlife Injury or Mortality

36 

37 Wildlife could be injured or killed by vehicle traffic along the access road to the proposed 

38 GLE Facility. Collisions with buildings, the water tower, and the transmission line also represent 

39 a potential hazard for birds. The relative abundance of a bird species does not predict the 

40 relative frequency of fatalities per species (Thelander and Rugge, 2000). However, resident 

41 birds may have a higher probability of collisions than migrants, given that residents tend to fly 

42 lower and spend more time in the area (Janss, 2000). Also, birds typically found within the 

43 operations area habitats of the Wilmington Site would be most likely to collide with structures 

44 due to their close proximity to them. 

45 

46 The potential for bird collisions with transmission lines depends on variables such as habitat, 

47 relation of the line to migratory flyways and feeding flight patterns, migratory and resident bird 

48 species, and structural characteristics of the lines (Beaulaurier et al., 1984). Birds that migrate 
4-52 

1 at night, fly in flocks, and/or are large and heavy with limited maneuverability are at particular 

2 risk (BirdLife International, 2003). Waterfowl, wading birds, shorebirds, and passerines are 

3 most vulnerable to colliding with transmission lines near wetlands, while in habitats away from 

4 wetlands, raptors and passerines are most susceptible (Faanes, 1987). Young, inexperienced 

5 birds, as well as migrants in unfamiliar terrain, appear to be more vulnerable to wire strikes than 

6 resident breeders. Also, many species appear to be most highly susceptible to collisions when 

7 alarmed, pursued, searching for food while flying, engaged in courtship, taking off, landing, or 

8 otherwise preoccupied and not attentive to where they are going, and during the night and 

9 inclement weather (Thompson, 1978). Mortality resulting from birds colliding with transmission 

10 lines is considered unavoidable. However, mortality levels are not anticipated to result in long11 term loss of population viability in any individual species or lead to a trend toward listing as a 

12 rare or endangered species, because it is expected that mortality levels would be low. 

13 

14 Except under unusual circumstances, no electrocution of raptors or other birds would be 

15 expected, because the spacing between the conductors or between a conductor and a ground 

16 wire or other grounding structure would exceed the wing span of the largest birds that occur in 

17 the region. Although a rare event, electrocution could occur during current arcing when flocks of 

18 small birds cross a line or when several roosting birds take off simultaneously. This is most 

19 likely to occur in humid weather conditions (Bevanger, 1995; BirdLife International, 2003). 

20 Arcing could also occur from the waste streamers of large birds roosting on the crossarms 

21 above insulators (BirdLife International, 2003). The electrocution of other wildlife from contact 

22 with electrical transmission lines is even less common. However, non-avian wildlife species that 

23 have been electrocuted include snakes, mice, squirrels, raccoons, bobcat (Lynx rufus), and 

24 American black bear (Ursus americanus) (EEI, 1980; Williams, 1990). Among the mammals, 

25 squirrels are among the most commonly reported species to be electrocuted because of their 

26 proclivity for chewing on electrical wires. Because of the relatively rare nature of electrocutions, 

27 they are not expected to adversely affect populations of wildlife species in the vicinity of the 

28 proposed GLE Facility. 

29 

30 The potential effects of electromagnetic field (EMF) exposure on animal behavior, physiology, 

31 endocrine systems, reproduction, and immune functions have been found to be negative, very 

32 minor, or inconclusive (WHO, 2007). Generally, these results are for exposures much higher 

33 and longer than would be encountered by wildlife under actual field conditions. Also, there is no 

34 evidence that EMF exposure alone causes cancer in animals, and the evidence that EMF 

35 exposure in combination with known carcinogens can enhance cancer development is 

36 inadequate (WHO, 2007). 

37 

38 During operation and maintenance of the proposed GLE Facility and its ancillary components, 

39 wildlife might be exposed to herbicides, fuel, or other hazardous materials. Potential exposure 

40 to hazardous materials would be most likely from a spill. A spill could result in direct 

41 contamination of individual animals, contamination of habitats, and contamination of food 

42 resources. Acute (short-term) effects generally occur from direct contamination; chronic 

43 (long-term) effects usually occur from factors such as the accumulation of contaminants from 

44 food items and environmental media (Irons et al., 2000). Moderate to heavy contaminant 

45 contact is most often fatal to wildlife. Chronic exposure can reduce reproduction, hatching 

46 success, and growth and cause a variety of pathological conditions. Contaminant ingestion 

47 during preening or feeding might impair endocrine and liver functions, reduce breeding success, 

48 and reduce growth of offspring. 
4-53 

1 The impacts on wildlife from a spill would depend on factors such as the time of year, volume of 

2 the spill, type and extent of habitat affected, and home range and density of the wildlife species. 

3 A population-level adverse impact would be expected only if the spill was very large or if it 

4 contaminated a crucial habitat area where a large number of individual animals were 

5 concentrated. The potential for either event would be unlikely. Because the amounts of most 

6 fuels and other hazardous materials are expected to be small, an uncontained spill would affect 

7 only a limited area. Also, the avoidance of contaminated areas by wildlife during spill response 

8 activities (due to disturbance from human presence) would minimize the potential for wildlife 

9 exposure. 

10 

11 Most herbicides used within the transmission line ROW would pose little or no risk to wildlife 

12 unless the animals were exposed to accidental spills or direct spray or drift or unless they 

13 consumed herbicide-treated vegetation. Herbicide applications would be conducted by 

14 following label directions and in accordance with applicable permits and licenses. Thus, any 

15 adverse toxicological threat from herbicides on wildlife would be unlikely. The response of 

16 wildlife to herbicide use would be attributable primarily to habitat changes resulting from 

17 treatment rather than toxic effects of the applied herbicide. However, accidental spills or 

18 releases of these materials could affect exposed wildlife. Effects could include organ damage, 

19 growth decrease, decrease in reproductive output, adverse impacts on the condition of 

20 offspring, and death (BLM, 2007). 

21 

22 As previously discussed, no impacts on ecological resources from operation of the proposed 

23 GLE Facility due to radiological exposure are expected. The highest exposures to wildlife would 

24 be to small animals occupying the UF6 storage pads. However, periodic surveys and other 

25 activities within the UF6 storage pads would discourage use of the storage pads by wildlife. 

26 Thus, the radiological exposures to local wildlife would be negligible. 

27 

28 Table 4-6 summarizes the significance levels of impact to wildlife that could occur from the 

29 proposed GLE Facility. Impacts on wildlife due to GLE Facility operations would be SMALL. 

30 

31 Aquatic Biota

32 

33 No natural water bodies occur within the immediate area of the proposed GLE Facility. The 

34 stormwater detention basin could support aquatic biota similar to other onsite stormwater wet 

35 detention basins. However, it is not likely that a diverse fish community would occur in the 

36 detention basin. More diverse aquatic communities on the Wilmington Site occur in the 

37 tributaries to the Northeast Cape Fear River and Prince George Creek, the effluent channel, and 

38 process and water treatment lagoons. The Northeast Cape Fear River supports a diverse 

39 aquatic community. 

40 

41 During the operations and maintenance phase, aquatic habitats and aquatic biota could be 

42 affected by continued erosion and sedimentation and exposure to contaminants. The rates of 

43 erosion and the resulting levels of turbidity and sedimentation to aquatic habitats would likely be 

44 less than during the preconstruction and construction phases because of the established ground 

45 cover and functioning of the stormwater wet detention basin. However, increased discharges to 

46 Unnamed Tributary #1 to Northeast Cape Fear River could increase turbidity and sedimentation 

47 until the stream channel adjusts to increased flows (GLE, 2008). Wastewater generated during 

48 operations would be treated to meet NPDES permit requirements. Therefore, it is not expected 
4-54 

1 that aquatic biota that inhabit Unnamed Tributary #1 to Northeast Cape Fear River, which would 

2 receive effluent from the proposed GLE Facility’s operations, would be adversely impacted. 

3 

4 The potential exists for toxic materials (e.g., fuel, lubricants, and herbicides) to be accidentally 

5 introduced into aquatic habitats during operation and maintenance of the proposed GLE Facility, 

6 access road, and transmission line. The level of impacts from releases of toxicants would 

7 depend on the type and volume of chemicals entering the waterway, the location of the release, 

8 the nature of the water body (e.g., size, volume, and flow rates), and the types and life stages of 

9 organisms present in the waterway. Because the amounts of most fuels and other hazardous 

10 materials are expected to be small, an uncontained spill would probably affect only a limited 

11 area. In general, lubricants and fuel would not be expected to enter wetlands or waterways as 

12 long as heavy machinery is not used near waterways, fueling locations for maintenance 

13 equipment are situated away from waterways, and measures are taken to control potential 

14 spills. Mitigation measures for maintenance of transmission line corridors generally restrict the 

15 use of machinery near waterways. Similarly, there are restrictions placed on the application 

16 methods, quantities, and types of herbicides that are used in the vicinity of wetlands and 

17 waterways in order to limit the potential for impacts on aquatic ecosystems. For example, 

18 herbicides would not be used directly along streams, ditches, or the stormwater wet detention 

19 basin (GLE, 2008). 

20 

21 Only trace levels of radiological contamination would be released to surface waters from 

22 operation of the proposed GLE Facility, with the discharges being within NPDES-permitted 

23 levels (Section 4.2.6.2). Therefore, adverse radiological impacts on aquatic biota from the 

24 operation of the proposed GLE Facility would not be expected. 

25 

26 Table 4-7 summarizes the significance levels of impacts on aquatic biota that could occur from 

27 the proposed GLE Facility. Impacts on aquatic biota from GLE Facility operations would be 

28 SMALL. 

29 

30 Threatened, Endangered, and Other Special Status Species

31 

32 No impacts on threatened, endangered, or other special status species would be expected from 

33 operation of the proposed GLE Facility because of the lack of suitable habitats within the 

34 immediate project area (in part due to habitat disturbance that would have occurred during 

35 preconstruction and construction activities [Section 4.2.8.1] and due to minimal contaminant 

36 releases to the environment). Therefore, impacts from GLE Facility operations to these species 

37 would be SMALL. 

38 

39 4.2.8.3 Mitigation Measures 

40 

41 This section presents mitigation measures to minimize impacts on ecological resources. 

42 Included are mitigation measures that GLE has committed to (GLE, 2008, 2009b) and mitigation 

43 measures identified during the NRC staff’s review. The mitigation measures are grouped by 

44 phase of development. Many of the mitigation measures are general in nature, being applicable 

45 to all phases of the project. These general mitigation measures are presented first, with more 

46 phase-specific mitigation measures following. A number of the mitigation measures designed to 

47 minimize impacts on air quality (Section 4.2.4.3), soils (Section 4.2.5.3), surface waters 
4-55 

1 (Section 4.2.6.3), noise (Section 4.2.9.3), and waste management (Section 4.2.12.3) would also 

2 minimize impacts on ecological resources, and are discussed in the referenced sections. 

3 

4 General Mitigation Measures

5 

6 Mitigation Measures Identified by GLE

7 

8 General mitigation measures that GLE has identified in order to minimize impacts on ecological 

9 resources include (GLE, 2008): 

10 

11 • Select a non-wetland, non-floodplain area for the proposed facility. 

12 

13 • Maintain the hydrological connectivity of wetlands to surface waters. 

14 

15 • Sod, seed, and/or landscape disturbed areas in accordance with the Sediment and Erosion 

16 Control Permit. 

17 

18 • Plant native plant species (i.e., not invasive species) to revegetate disturbed areas and for 

19 landscaping the proposed GLE Facility. 

20 

21 • Use nectar- and berry-producing plants for landscaping plants. 

22 

23 • Place bluebird boxes throughout the study area. 

24 

25 • Conduct site-stabilization practices to reduce the potential for erosion and sedimentation. 

26 

27 • Consider the recommendations made by appropriate Federal and State agencies, including 

28 the U.S. Fish and Wildlife Service (FWS) and the North Carolina Department of 

29 Environmental and Natural Resources (NCDENR). 

30 

31 Additional Mitigation Measures Identified by NRC

32 

33 • Reduce or prevent the collection, harassment, or disturbance of plants, wildlife, and their 

34 habitats (particularly threatened, endangered, and sensitive species) through employee and 

35 contractor education on applicable State and Federal laws. Additionally, implement the 

36 following measures: (1) instruct all personnel to avoid harassment and disturbance of local 

37 plants and wildlife; (2) make personnel aware of the potential for wildlife interactions around 

38 facility structures; and (3) ensure that food refuse and other garbage are not available to 

39 scavengers. 

40 

41 • Establish a trash abatement program focusing on containing trash and food in closed 

42 containers and removing them periodically to reduce their attractiveness to opportunistic 

43 species, such as bears, coyotes, and feral dogs. 

44 

45 • Avoid known locations of listed plant species and habitats of listed wildlife species and 

46 establish a setback distance (minimum 60 meters [200 feet]) to prevent any destructive 

47 impacts associated with construction and decommissioning activities. 

48 
4-56 

1 • Minimize the number of areas where wildlife could hide or be trapped (e.g., open sheds, 

2 pits, uncovered basins, and laydown areas). 

3 

4 • If any federally threatened or endangered species such as the roughleaf loosestrife or the 

5 red-cockaded woodpecker are encountered, consult the FWS as required by Section 7 of 

6 the Endangered Species Act, and determine an appropriate course of action to avoid or 

7 mitigate impacts. 

8 

9 • Observe all trees greater than 61 centimeters (24 inches) in diameter identified during GLE's 

10 surveys for potential compensatory tree plantings for the potential presence of red11 cockheaded woodpecker cavities. If any cavities are observed, consult the FWS as required 

12 by Section 7 of the ESA and determine an appropriate course of action to avoid or mitigate 

13 impacts. 

14 

15 • Develop an integrated vegetation management plan for the control of noxious weeds and 

16 invasive plant species. 

17 

18 Mitigation Measures for Preconstruction and Construction Activities

19 

20 Mitigation Measures Identified by GLE

21 

22 Mitigation measures that the applicant has identified in order to minimize impacts on ecological 

23 resources during preconstruction and construction activities include: 

24 

25 • Minimize the construction footprint to the extent possible and limit habitat disruption. 

26 

27 • Limit cut/fill slopes to a horizontal-vertical ratio of 3:1 or less. 

28 

29 • Use existing service road routes and utility ROWs to the fullest extent practicable to 

30 minimize the need for additional wetlands crossings. 

31 

32 • Construct access road perpendicular to wetlands to minimize the area impacted. 

33 

34 • Avoid temporary storage of materials in wetlands. 

35 

36 • Place fencing/barriers and use signs around wetland areas. 

37 

38 • Use silt fencing and cover soil stockpiles to prevent sediment runoff. 

39 

40 • Restore disturbed areas to original surface elevations. 

41 

42 • Perform surveys of trees greater than 61 centimeters (24 inches) in diameter before 

43 beginning preconstruction and construction activities. The impacts on each tree would be 

44 mitigated by the planting of one 61-centimeter (24-inch) diameter tree, two 30.5-centimeter 

45 (12-inch) diameter trees, or three 20.3-centimeter (8-inch) diameter trees elsewhere on the 

46 Wilmington Site. 

47 
4-57 

1 • Restrict preconstruction activities and the harvesting of trees to periods when the ground is 

2 dry. 

3 

4 • If trenches are necessary, ensure that they are closed overnight; inspect trenches that are 

5 left open overnight and remove animals prior to backfilling. In addition, place escape ramps 

6 at less than 45-degree angles in trenches to provide exit strategies for animals entering the 

7 trenches. 

8 

9 • Sod, seed, and/or landscape disturbed areas in accordance with the Sediment and Erosion 

10 Control Permit. 

11 

12 • Revegetate disturbed areas with native plant species. 

13 

14 • Install animal-friendly fencing around the proposed GLE Facility site so that wildlife cannot 

15 be injured by or entangled in the site’s security fence. 

16 

• Establish food plots along roadways and under power lines.13 17 

18 

19 Additional Mitigation Measures Identified by NRC

20 

21 • Minimize the area disturbed by preconstruction activities and the installation of facilities 

22 (pipelines, transmission towers, pump stations, substations, laydown areas, assembly 

23 areas) to retain native vegetation and minimize soil disturbance. 

24 

25 • Backfill open trenches as quickly as is reasonable. 

26 

27 • To the extent practicable, avoid the use of guy wires, as these pose a collision hazard for 

28 birds. 

29 

30 Mitigation Measures for Operations 

31 

32 Mitigation Measures Identified by GLE

33 

34 No specific mitigation measures to protect ecological resources from the operation of the 

35 proposed GLE Facility were identified by GLE (GLE, 2008). 

36 

37 Mitigation Measures Identified by NRC

38 

39 • Maintain areas left in a natural condition during construction (e.g., wildlife crossings) in as 

40 natural a condition as possible within safety and operational constraints. 

41 

42 • To minimize habitat loss and fragmentation, reestablish as much habitat as possible after 

43 construction is complete by maximizing the area reclaimed or vegetated during operations. 

44 

 

13 The NRC does not recommend that food plots be established along roadways, as this could increase 

the potential for wildlife being run over or hit by vehicles. 
4-58 

1 • Prevent the establishment and spread of invasive species and noxious weeds within the 

2 transmission line ROW, along the access road, and in associated areas of ground surface 

3 disturbance or vegetation cutting. Monitor the area regularly and eradicate invasive species 

4 immediately. 

5 

6 4.2.9 Noise Impacts 

7 

8 This section describes potential noise impacts of preconstruction activities, construction, and 

9 operation of the proposed GLE Facility on neighboring communities. Because the activities that 

10 may cause noise impacts do not correspond well to these three phases, in this analysis, noise 

11 impacts were organized into road construction, land clearing and grading, and operations 

12 activities. As explained further in Section 4.2.9.1, building construction was expected to cause 

13 much less noise impact than road construction and land clearing and grading, and was not 

14 modeled separately. 

15 

16 In this analysis, noise level data for stationary and mobile sources such as heavy equipment, 

17 various types of vehicles, and facility operating units to be used are estimated using standard 

18 references and then noise levels at receptors are estimated using sound propagation computer 

software Cadna/A® 19 developed by DataKustik. Potential impacts from road construction are 

20 presented in Section 4.2.9.1, and those from facility operations are discussed in Section 4.2.9.2. 

21 Mitigation measures during preconstruction activities, construction, and facility operations are 

22 presented in Section 4.2.9.3. 

23 

24 4.2.9.1 Preconstruction and Construction Activities 

25 

26 The commuter and delivery vehicular traffic around the proposed GLE Facility and along the 

27 traffic routes nearby would generate intermittent noise. However, the contribution to noise from 

28 these intermittent sources would be limited to the immediate vicinity of the traffic routes and 

29 would be minor in comparison to the contribution from continuous noise sources such as 

30 compressors or bulldozers during preconstruction and construction activities. Sources of noise 

31 during preconstruction and construction activities for the proposed GLE Facility would include 

32 standard construction activities for moving earth and erecting concrete and steel structures. 

33 Noise levels from these activities would be comparable to those from other construction sites of 

34 similar size. The noise levels would be highest during land clearing, grading, and road 

35 construction, when a large fleet of heavy equipment would be used to clear the site over a short 

36 time period. Typically, this phase would be one month of road construction followed by 

37 eight months of land clearing and grading. 

38 

39 In general, the dominant noise source for most construction equipment is the diesel engine 

40 without sufficient muffling. Pile driving or pavement breaking would normally dominate noise at 

41 a construction site, but neither of these activities is planned. During construction, a variety of 

42 heavy equipment would be used. Average noise levels for typical construction equipment range 

43 from 74 A-weighted decibels (dBA) for a roller to 101 dBA for a pile driver (impact) at the 

44 distance of 15 meters (50 feet) from a source (Hanson et al., 2006). During construction at the 

45 Wilmington Site, the noise level for any heavy equipment or traffic vehicle would be less than 

46 90 dBA at a 15-meter (50-foot) distance. 

47 
4-59 

1 Projected sound-level contours including average daytime A-weighted decibels and day-night 

2 average sound levels (Ldn, dBA) are estimated for road construction and land clearing and 

3 grading. The assumed numbers of heavy equipment and vehicle trips for use in sound 

4 propagation modeling are presented in Table 4-8. Background and modeled sound levels at the 

5 fenceline nearest to the Wooden Shoe residential subdivision are presented in Table 4-9. 

6 

7 The proposed north access road would be constructed to connect the NC 133 (Castle Hayne 

8 Road) to the proposed GLE Facility. Road construction 2.6 kilometers (1.6 miles) in distance 

9 would last about 1 month and progress westward from the NC 133 along 2.6 kilometers 

10 (1.6 miles) in the proposed access road. Predicted noise levels of 68 dBA equivalent sound 

11 level (Leq) and 66 dBA Ldn would temporarily exceed the daytime 65 dBA Leq for the 

12 New Hanover County Noise Ordinance (New Hanover County, 2009b) and the EPA guideline of 

13 

Table 4-8 Assumed Number of Noise Sources for Use in Sound 

Propagation Modeling 

Phase Assumed Value 

Road construction 4 

2 

4 

2 

1 

1 

bulldozers 

graders 

loaders 

rollers 

excavator 

water truck 

Land clearing and 

grading 

4 

2 

4 

2 

1 

1 

375 

35 

Bulldozers 

graders 

loaders 

rollers 

excavator 

water truck 

passenger vehicles (trips/day) 

hauling vehicles (trips/day) 

Operations 4 

2 

4 

1 

2 

2 

6 

2 

1 

375 

6 

cylinder hauling vehicles dedicated to proposed GLE Facility 

hauling vehicles using the western connector to existing facility 

air handling units 

scrubber exhausta 

cooling towers 

emergency diesel generators 

heat pumps (2 per service building) 

pump/lift stations (25 horsepower) 

electrical substation (60,000 kilovolt-amperes) 

passenger vehicles (trips/day) 

hauling vehicles (trips/day) a

 Scrubber exhaust noise is included in sound propagation modeling, but the scrubber has been 

removed from the proposed GLE Facility design. Results can be viewed as a conservative estimate 

during facility operations. 

Source: GLE, 2008. 
4-60 

1 

55 dBA Ldn (EPA, 1974)14 2 at the fenceline where the access road is the closest to the site 

3 boundary (not shown in the table). At the fenceline nearest to the Wooden Shoe residential 

4 subdivision, predicted noise levels of 61 dBA Leq and 59 dBA Ldn would be lower than the 

5 daytime equivalent continuous sound level for the New Hanover County Noise Ordinance but 

6 exceed the EPA guideline, as shown in Table 4-9. Road construction activities would be of very 

7 short duration (about one month). Potential noise impacts on the surrounding community would 

8 be MODERATE but temporary in nature when the road construction activities would occur in the 

9 proximity of the site property line near the Wooden Shoe subdivision. 

10 

11 Land clearing and grading activities, which would last for about eight months, follow road 

12 construction activities. Most land clearing and grading activities would occur away from the 

13 fenceline and far from the nearest residential subdivision (about 1.3 kilometers [0.8 mile]). 

14 Noise levels from commuting, delivery, and support vehicles traveling the access road would be 

15 lower than those during road construction. Predicted noise levels of 61 dBA Leq and 58 dBA Ldn

16 

Table 4-9 Estimated Cumulative Sound Levels (dBAs) at the 

Fenceline Receptor Nearest to the Wooden Shoe 

Residential Subdivision 

 Average Leq

a

 

Activity Item Day Night Ldn

b

 Background (measured) 46 41 48 

Road Construction Modeled 61 41c 58 

 Background+ modeled 61 41 59 

Land clearing and 

grading 

Modeled 42 41c

 40 

 Background+ modeled 48 41 49 

Facility Operations Modeled 38 34 42 

Background+ modeled 47 42 49 

 New Hanover County 

Ordinance (residential)d 65 50 NAe

 EPA guideline (residential)f NA NA 55 a

 Leq = equivalent continuous sound level. The “day” time period is 15 hours from 

7 a.m. to 10 p.m. and “night” time period is 9 hours from 10 p.m. to 7 a.m. 

b

 Ldn = day-night average sound level. c

 No modeling was performed because no activities would occur at night. This 

background value is used to calculate the Ldn. d

 Source: New Hanover County, 2009b. 

e

 NA = not applicable. 

f

 Source: EPA, 1974. 

 

14 This location is not a residence, and thus not subject to the New Hanover County Noise Ordinance or 

the EPA guideline. These noise levels are presented for informational purposes only. 
4-61 

1 at the fenceline nearest to the proposed GLE Facility would be lower than the daytime 

2 equivalent sound level for the New Hanover County Noise Ordinance but higher than the 

3 EPA guideline (not shown in the table). However, noise levels of 48 dBA Leq and 49 dBA Ldn at 

4 the fenceline receptor closest to the subdivision are predicted to be below the daytime 

5 equivalent continuous sound level for the New Hanover County Noise Ordinance and the 

6 EPA guideline; thus, potential noise impacts on the surrounding community would be SMALL 

7 and temporary in nature. 

8 

9 During the building construction phase, major activities would include building erection and 

10 electrical and mechanical installation, and some activities would occur inside the buildings. 

11 Typically, heavy equipment with lower noise levels than those during road construction or land 

12 clearing and grading would be employed. The start-up and final construction phase would 

13 include concurrent indoor construction activities along with staged testing and start-up of 

14 process units as completed. Traffic accessing the construction site might increase but the traffic 

15 would consist of smaller passenger vehicles, vans, and pickup trucks. Noise modeling was not 

16 performed for this building construction phase because noise levels would be expected to be 

17 lower than those for the road construction and land clearing and grading phase. Accordingly, 

18 potential noise impacts on the nearest Wooden Shoe subdivision would be anticipated to be 

19 SMALL during these phases. 

20 

21 In conclusion, road construction noise could temporarily exceed the EPA guideline at the 

22 nearest Wooden Shoe subdivision but not exceed the daytime New Hanover County Noise 

23 Ordinance level. During land clearing and grading, building construction, and start-up and final 

24 construction, noise levels at the nearest subdivision are well below the New Hanover County 

25 Noise Ordinance or the EPA guideline due to the distance (about 1.3 kilometers [0.8 mile]). 

26 

27 4.2.9.2 Facility Operations 

28 

29 During facility operations, noise sources would be primarily in enclosures within the main GLE 

30 operations buildings with limited rooftop equipment. Various outbuildings are planned with 

31 exterior equipment, such as diesel generators, pumps, heat pumps, transformers, and cooling 

32 towers. Other noise sources would include vehicular traffic such as commuting vehicles and 

33 material delivery vehicles on the proposed north access road, as well as hauling vehicles 

34 around the proposed GLE Facility and to and from the cylinder yards and the existing FMO 

35 facility (GLE, 2008). 

36 

37 The assumed numbers of stationary noise sources and vehicle trips are presented in Table 4-8. 

38 It is also assumed that the proposed GLE Facility is operating 24 hours per day, seven days per 

39 week (GLE, 2008). Sound propagation modeling indicates that noise levels of 47 dBA Leq (day), 

40 42 dBA Leq (night), and 49 dBA Ldn at the fenceline receptor closest to the Wooden Shoe 

41 residential subdivision are estimated to be below the day and night equivalent continuous sound 

42 level for the New Hanover County Noise Ordinance and the EPA guideline. These levels are 

43 only 1 decibel higher than existing ambient levels at this receptor, which is lower than a 

44 3-decibel change that is considered a barely discernable difference. Accordingly, potential 

45 noise impacts on the nearest Wooden Shoe subdivision during operations are anticipated to be 

46 SMALL. 

47 
4-62 

1 4.2.9.3 Mitigation Measures 

2 

3 As discussed above, potentially MODERATE noise impacts during access road construction of 

4 short duration (about one month) and SMALL impacts during land clearing and grading, 

5 construction, and facility operations are anticipated. All project-related activities should comply 

6 with applicable laws, ordinances, regulations, and standards. Mitigation measures during the 

7 life of the project are recommended as a means to reduce potential noise impacts on the 

8 neighboring communities. Below are mitigation measures that GLE has proposed (GLE, 2008). 

9 NRC staff has also identified additional measures that could potentially reduce impacts. 

10 

11 General Mitigation Measures

12 

13 Mitigation Measures Identified by GLE

14 

15 • When possible, use quiet equipment or methods to minimize noise emissions. 

16 

17 • For equipment with internal combustion engines, operate equipment at the lowest operating 

18 speed to minimize noise emissions, when possible and practical. 

19 

20 • Close engine-housing doors during operation of equipment to reduce noise emissions from 

21 the engine. 

22 

23 • Avoid equipment engine idling. 

24 

25 Additional Mitigation Measures Identified by NRC

26 

27 • Operate all vehicles traveling within and around the project area in accordance with posted 

28 speed limits. 

29 

30 • Post warning signs in high-noise areas and implement a hearing protection program for 

31 work areas in excess of 85 dBA. 

32 

33 • Project operators should realize that complaints about noise may still occur, even when the 

34 noise levels from the facility do not exceed regulatory or guideline levels. Implement a noise 

35 complaint process and hotline for the surrounding communities, including documentation, 

36 investigation, evaluation, and resolution of all legitimate project-related noise complaints. 

37 

38 Mitigation Measures for Preconstruction Activities and Building Construction 

39 

40 Mitigation Measures Identified by GLE

41 

42 • Prohibit heavy truck and earth-moving equipment usage after twilight and during early 

43 morning hours. 

44 

45 • Equip construction equipment with the manufacturer’s noise-control devices, and maintain 

46 these devices in effective operating condition. 

47 
4-63 

1 • Use quieter, less-tonal devices that comply with all applicable safety restrictions 

2 (e.g., Occupational Safety and Health Administration [OSHA] standards) on backup alarms 

3 for construction equipment. 

4 

5 Additional Mitigation Measures Identified by NRC

6 

7 • When possible, schedule different noisy activities to occur at the same time, since additional 

8 sources of noise generally do not significantly increase noise levels at the site. That is, less9 frequent but noisy activities would generally minimize overall noise disturbance than lower10 level noise occurring more frequently. 

11 

12 • Implement noise control measures (e.g., erection of temporary wooden noise barriers) if 

13 noisy activities would be expected near sensitive receptors. 

14 

15 Mitigation Measures for Operations

16 

17 Mitigation Measures Identified by GLE

18 

19 • Use a quieter, high-efficiency transformer to mitigate noise from the proposed electrical 

20 substation. 

21 

22 Additional Mitigation Measures Identified by NRC

23 

24 No additional mitigation measures to minimize potential noise impacts on neighboring 

25 communities from the operation of the proposed GLE Facility are proposed by NRC. 

26 

27 4.2.10 Transportation Impacts 

28 

29 This section addresses the potential impacts on the environment from transportation of workers 

30 and materials attributable to preconstruction activities, construction, and operation of the 

31 proposed GLE Facility. The main impact of these activities on transportation resources is 

32 expected to be increased traffic on nearby roads and highways. Impacts are expected to be 

33 SMALL to MODERATE on adjacent local roads, but regional impacts are expected to be 

34 SMALL. All incoming and outgoing shipments associated with the construction, operation, and 

35 decommissioning of the proposed GLE Facility are anticipated to be transported by truck. All 

36 motor vehicle traffic to the facility will use a new entrance, an extension of the existing North 

37 Entrance (GLE, 2009e), to the Wilmington Site off of North Carolina Route 133 (Castle Hayne 

38 Road). 

39 

40 4.2.10.1 Preconstruction and Construction Activities 

41 

42 Preconstruction and construction activities involve the movement of personnel and equipment to 

43 and from the site, the delivery of materials and supplies, and the removal of construction debris 

44 and waste. The number and type of truck shipments will vary over the course of the initial 

45 three-year preconstruction and construction period depending on the type and level of activity at 

46 the site. Truck types would vary from heavy haul tractor-trailer trucks and other heavy haul 

47 trucks, such as dump trucks and cement trucks, to light-duty delivery trucks. Site activities 

48 would include site clearing and grading, building construction (exterior and interior), installation 
4-64 

1 of process equipment, and utility installation. Preconstruction and construction activities are 

2 estimated to add approximately 35 trucks per day to local traffic on average over the 

3 construction period (GLE, 2008). This additional traffic load would have only a SMALL impact 

4 on local traffic. 

5 

6 The number of construction workers and visitors (e.g., regulatory inspectors, GLE staff) at the 

7 construction site would also vary widely over the three-year preconstruction and construction 

8 period, depending on progress at the site. During preconstruction and construction activities, 

9 prior to initial start-up of operations, an average increase of up to 815 daily trips by construction 

10 personnel is anticipated (GLE, 2009e) as shown in Table 4-10. Approximately 200 daily trips by 

11 workers are anticipated during preconstruction with an additional 615 daily trips at the onset of 

12 construction activities. The heaviest local traffic occurs in the immediate vicinity of the site 

13 entrance on Castle Hayne Road near the I-140 on- and off-ramps. With an annual average 

daily traffic (AADT)15 14 level ranging from about 10,000 to 12,000 on Castle Hayne Road, as 

15 discussed in Section 3.10.1, an additional 200 to 615 or more trips during peak commuting 

16 periods could have a SMALL to MODERATE impact at the local level. Impacts would be 

17 lessened if shift changes did not directly coincide with local peak road usage times, including 

18 shift changes at the existing Wilmington Site facilities. Because Castle Hayne Road is a major 

19 north-south thoroughfare and I-140 is in the immediate area to handle east-west traffic, traffic 

20 funnels to and from the site on these roads, keeping impacts limited to the local site vicinity, 

21 regional impacts are considered to be SMALL. 

22 

23 Approximately 200 daily trips by construction personnel are expected during preconstruction 

24 activities, which would result in SMALL to MODERATE impacts at the site entrance. During 

25 construction, approximately 615 to 815 daily trips by construction personnel are expected and 

26 would result in MODERATE impacts at the local level. 

27 

28 4.2.10.2 Facility Operations 

29 

30 The facility operations phase would overlap with the construction phase for five years 

31 (GLE, 2008). During this time period, vehicular traffic from operations personnel commuting to 

32 and from the proposed GLE Facility would add to the increased local traffic from construction 

33 workers and shipments, as discussed in Section 4.2.10.1. The remaining years of operations 

34 would continue to see vehicular traffic from permanent operations personnel staff, occasional 

35 visitors (e.g., regulatory inspectors), and incoming truck shipments for materials and supplies as 

36 well as outgoing shipments of product materials and wastes. 

37 

38 Transportation of Personnel, Materials, and Supplies

39 

40 In addition to the construction-related truck shipments, the natural uranium material used for 

41 feed to the enrichment process (i.e., UF6 feed) would be shipped to the Wilmington Site and 

42 enriched UF6 product, UF6 tails, empty cylinders, and LLRW, would be shipped from the site. 

43 However, the enriched UF6 product will be another source of material for the FMO facility, and 

44 thereby reduce the number of enriched UF6 shipments coming to the Wilmington Site. A 

45 conservative estimate of the annual number of additional heavy-haul truck shipments to and 

 

15 Annual average daily traffic (AADT) is a measure of the daily average number of vehicles that pass 

through a given segment of roadway. 
4-65 

Table 4-10 Estimated Traffic Generated by Construction, Operation, and 

Decommissioning of the Proposed GLE Facility 

Total Vehicle Tripsc,d

Phase

Schedule 

Assumed in 

Analysisa

Current 

Schedule

Average 

Annual 

Number of 

Employeesb

AM Peak 

Hour Trips 

Average Daily 

Trips (ADT)e

Preconstruction and 

initial construction 

activities 

2011–2012 2011–2012 388f 388g 815k

Start-up operation, 

overlapping with 1 year 

of initial construction 

(2013) and 4 years of 

final construction 

activities 

2013–2017 2013–2017 743h

 297 1,560 

Production operations 2018–2050 2018–2051 350 140 740 

Production operations 

and initial 

decommissioning 

activities 

2049-2050 2050–2051 400i

 190g,j 840 

Decommissioning 2051-2057 2052–2058 50i 50g 105 a

 As discussed in Section 4.1, certain impact analyses in this draft EIS are based on a slightly different licensing 

schedule than is currently expected. These schedule changes, which will be reflected in the final EIS, are expected to 

cause slight changes in the transportation impact analysis but are not expected to change any of the impact 

conclusions. 

b

Average annual number of employees during the specified years using annual employment estimates for the 

proposed GLE Facility. 

c

 Number of vehicle trips estimated using Institute of Transportation Engineers (ITE) standard trip generation rates for 

industrial manufacturing land use (ITE, 2004). The ITE defines manufacturing facilities as areas where the primary 

activity is the conversion of raw material or parts into finished products. The ITE trip generation rates are total vehicle 

rates that include trucks. Morning peak-hour trips = 0.4 per employee. d

 Assumed ITE ADT trip generation rates for industrial manufacturing land use for all phases. 

e

 Average daily trips (ADT) = 2.1 per employee. 

f

 Actual total number of construction workers onsite on a given day would vary depending on the project’s construction 

stage and required activities. On many days, fewer than 388 workers used for the ADT estimate are expected to be 

needed to perform the required daily construction activities. g

 Assumed construction and decommissioning activities conducted only during daylight hours on a Monday through 

Friday schedule. Therefore, morning peak-hour trip estimates conservatively assume that all workers work the same 

schedule and arrive at the Wilmington Site at the same time. 

h

 Start-up consists of a varying mix of onsite permanent operational workers and temporary engineering and 

construction workers. 

i

 The 50 workers included in the ADT estimate is anticipated to be an upper limit. Actual total number of 

decommissioning workers on-site on a given day could vary depending on the specific decommissioning-phase 

activities. 

j

 140 morning peak-hour trips for production workers + 50 morning peak-hour trips for decommissioning workers. k

 The number of vehicle trips associated with preconstruction and construction are estimated to be 200 and 615, 

respectively (GLE, 2009e). 

Source: Modified from GLE, 2008. 
4-66 

1 from the Wilmington Site from operation of the proposed GLE Facility, which does not account 

2 for the reduced number of enriched UF6 shipments arriving at the site, is 2100, approximately 

3 six trucks per day on average (GLE, 2008). Other supplies and equipment necessary for 

4 operations would also be delivered to the proposed GLE Facility on an as-needed basis. 

5 

6 Operations personnel would be expected to reside in the Wilmington Site regional area and 

7 commute from all directions, which is similar to current workers at the other site facilities and 

8 construction workers for the proposed GLE Facility. As shown in Table 4-10, the average 

9 number of workers (construction and operations personnel) at the proposed GLE Facility on a 

10 daily basis during operations start-up and construction completion would be approximately 

11 743 (GLE, 2008). About 350 permanent operations personnel would be employed over the 

12 30-year remainder of the operations period. The proposed GLE Facility would operate on a 

13 24-hour, multiple-shift schedule 7 days per week. Thus, not all employees would be arriving 

14 and departing at the same time in the morning and evening, respectively. 

15 

16 The number of additional daily vehicle trips resulting from operation of the proposed 

17 GLE Facility would increase by about 1560 at the Wilmington Site on average during joint 

18 construction and operations activities (see Table 4-10). Once preconstruction and construction 

19 activities have concluded, the average number of daily trips by operations personnel associated 

20 with the proposed GLE Facility is estimated to be approximately 740. The range of an 

21 additional 740 to 1560 daily trips would have a similar effect on the local road network as the 

22 increase due to construction traffic for the proposed GLE Facility discussed in Section 4.2.10.1. 

23 Traffic in the vicinity of Castle Hayne Road and I-140 near the site entrance may become more 

24 congested at times of peak travel associated with shift changes at the proposed GLE Facility 

25 resulting in a SMALL to MODERATE impact. Impacts would be lessened if shift changes did 

26 not directly coincide with local peak road usage times, including shift changes at the existing 

27 Wilmington Site facilities. The impact on regional traffic flow is expected to be SMALL. 

28 

29 Transportation of Radioactive Materials

30 

31 Operations of the proposed GLE Facility would require the shipment of various radioactive 

32 materials to and from the facility: 

33 

34 • natural UF6 (i.e., not enriched) feed to the facility 

35 

36 • enriched UF6 product from the facility to a fuel fabrication facility 

37 

38 • depleted UF6 to a conversion facility 

39 

40 • return of empty feed cylinders with residual contamination 

41 

42 • LLRW for disposal 

43 

44 All shipments are anticipated to occur via heavy-haul tractor trailer combination trucks. 

45 

46 A number of these shipments may have multiple origins or destinations. UF6 feed may be 

47 obtained from a U.S. facility (Honeywell International, Metropolis, Illinois), a Canadian source 

48 (Cameco, Port Hope, Ontario, Canada) or overseas sources arriving at U.S. seaports 
4-67 

1 (Portsmouth Marine Terminal [PMT], Portsmouth, Virginia; Dundalk Marine Terminal [DMT], 

2 Baltimore, Maryland). UF6 product may be used at the Wilmington Site or sent to other fuel 

3 fabrication facilities in Columbia, South Carolina (Westinghouse Electric), and Richland, 

4 Washington (AREVA NP). The depleted UF6 tails could be sent to facilities in either Paducah, 

5 Kentucky or Portsmouth, Ohio; both facilities are currently under construction for conversion of 

6 depleted UF6 to uranium oxide for disposal. In the case of the LLRW generated at the proposed 

7 GLE Facility, only one destination is planned, the EnergySolutions disposal facility in Clive, 

8 Utah. Single-shipment and annual impacts are evaluated for all potential shipment routes. 

9 Annual impacts are assumed based on all shipments of one material type over the same route 

10 (e.g., all depleted UF6 tails going to Paducah, Kentucky, or all going to Portsmouth, Ohio). 

11 

12 This assessment is based on the transportation assessment presented in the NRC’s 

13 NUREG-0170 report (NRC, 1977). Since that assessment was conducted, computer models 

14 and basic assumptions have been refined, but the overall approach to estimating transportation 

15 impacts has remained the same. The technical approach for estimating transportation risks 

16 involves use of several computer models and databases. For assessment of normal transport, 

17 risks were calculated for the collective populations of all potentially exposed individuals, as well 

as for a maximally exposed individual (MEI)16 18 receptor. Potentially exposed populations include 

19 those persons living and working along the transport route, those present at vehicle stops, and 

20 those on the road near the shipment. The accident assessment included consideration of the 

21 probabilities and consequences of a range of possible transportation-related accidents, 

22 including low-probability accidents that have high consequences and high-probability accidents 

23 that have low consequences. The details of the transportation analysis are provided in 

24 Appendix D. 

25 

26 For all shipments, risks were estimated for truck transport for both normal (incident-free) and 

27 accident conditions. In both cases, “vehicle-related” and “cargo-related” impacts were 

28 evaluated. 

29 

30 Vehicle-related risks result simply from moving any material from one location to another, 

31 independent of the characteristics of the cargo. For example, increased levels of pollution from 

32 vehicular emissions during normal conditions may affect human health. Similarly, accidents 

33 during transportation may cause fatalities from physical trauma. 

34 

35 Cargo-related risk, on the other hand, refers to risk attributable to the characteristics of the 

36 cargo being shipped. The radiological cargo-related risks from the transportation of uranium 

37 feed and product materials, depleted uranium tails, empty cylinders with residual heels, and 

38 LLRW would be caused by exposure to ionizing radiation. Exposures to radiation occur during 

39 both normal transportation and during accident conditions. In the case of the uranium materials 

40 considered, cargo-related risks also include chemical hazards during accident conditions. 

41 

42 The risks from exposure to hazardous chemicals during transportation-related accidents, which 

43 include consideration of the formation of HF from the reaction of UF6 with moisture in the air for 

44 this assessment, can be either acute (result in immediate injury or fatality) or latent (result in 

45 cancer that would present itself after a latency period of several years). However, none of the 

46 chemicals that might be released in any of the transportation accidents involving UF6 is 

 

16 A maximally exposed individual (MEI) is an individual that may be expected to receive the highest 

potential radiological dose for a given scenario. 
4-68 

1 carcinogenic. As a result, no excess chemically induced latent cancers would be expected from 

2 accidental chemical releases. The acute health end point − potential irreversible adverse 

3 effects − was considered for the assessment of cargo-related population impacts from 

4 transportation accidents. 

5 

6 Routine Transportation

7 

8 Radiological risks during routine transportation would result from the potential exposure of 

9 people to low levels of external radiation near a loaded shipment. U.S. Department of 

10 Transportation (DOT) and NRC regulations − 49 CFR 73.441 (Radiation Level Limitations) and 

11 10 CFR 1.47 (External Radiation Standards for All Packages) − were set to maintain these 

12 external radiation levels at a value considered to be protective of the public. The maximum 

13 allowable external dose rate is 0.1 millisievert per hour (10 millirem per hour) at 2 meters 

14 (6.5 feet) from the outer lateral sides of the transport vehicle. In this analysis, the external dose 

15 rates range from approximately 0.0015 millisievert per hour (0.15 millirem per hour to 

16 0.02 millisievert per hour (2.0 millirem per hour) as shown in Table 4-11, depending on the 

17 shipment type. Since the regulatory maximum is approximately 0.14 millisievert per hour 

18 (14 millirem per hour) at a distance of 1 meter (3.3 feet), the external dose rates from the 

19 GLE Facility shipments are expected to be approximately 20 percent or less than the regulatory 

20 maximum. 

21 

22 Single-shipment radiological impacts are presented in Table 4-12 for transportation of the UF6

23 feed material, the enriched uranium, the depleted UF6 tails, empty cylinders, and LLRW. 

24 Impacts on an annual basis are presented in Table 4-13 for all shipment types. The most 

25 conservative annual impacts can be estimated if the shipment option for each type of shipment 

26 with the greatest impacts are selected (i.e., UF6 feed material from Cameco in Port Hope, 

27 Ontario; enriched uranium sent to AREVA in Richland, Washington; depleted UF6 tails sent to 

28 the Paducah conversion facility; empty cylinders sent to Honeywell; and LLRW sent to 

29 EnergySolutions). 

30 

31 In the most conservative case, combined total doses of 11 person-rem and 6.0 person-rem 

32 were estimated for the public and the transportation crews, respectively, from all shipments on 

33 an annual basis. The resulting expected latent cancer fatalities (LCFs) are 0.007 and 0.004, 

34 respectively (see Table 4-13). These impacts on the public would be SMALL because the 

35 

Table 4-11 Estimated External Dose Rates for Radioactive 

Material Shipments 

Material Shipment Configuration Shipment External Dose 

Rate at 1 m (mrem/hr) 

UF6 feed 1-48Y cylinder 0.29 

UF6 product 5-30B cylinders 0.95 

Depleted UF6 tails 1-48Y cylinder 0.28 

Empty cylinders 2-48Y cylinders with residual heels 2.0 

LLRW 36-4 × 4 × 4 feet waste boxes 0.15 

Sources: GLE, 2008; GLE, 2009b.
4-69 

Table 4-12 Estimated Collective Population Proposed GLE Facility Single Shipment Transport

 Cargo-Relateda Radiological Impacts 

 Dose Risk (person-rem)b Routine Public 

Latent Cancer 

Fatalitiesd

Shipment 

Total 

Distance 

(km) Routine Crew Off-Link On-Link Stops Total Accidente Crew Public 

UF6 feed coming from:  Portsmouth Marine Terminal 463 8.3 × 10−4 2.2 × 10−5 8.5 × 10−5 7.3 × 10−4 8.3 × 10−4 1.9 × 10−6 5 × 10−7 5 × 10−7  Dundalk Marine Terminal 754 1.3 × 10−3 6.2 × 10−5 1.7 × 10−4 1.1 × 10−3 1.4 × 10−3 7.6 × 10−6 8 × 10−7 2 × 10−7  Honeywell International 1314 2.4 × 10−3 9.8 × 10−5 2.6 × 10−4 2.1 × 10−3 2.4 × 10−3 5.8 × 10−6 1 × 10−6 1 × 10−6  Cameco 1397 2.5 × 10−3 1.1 × 10−4 3.0 × 10−4 2.2 × 10−3 2.6 × 10−3 1.2 × 10−5 2 × 10−6 2 × 10−6 UF6 product going to:  Westinghouse Electric 479 2.1 × 10−3 2.5 × 10−4 8.9 × 10−4 7.3 × 10−3 8.5 × 10−3 6.6 × 10−6 1 × 10−6 5 × 10−6  AREVA NP 4786 2.1 × 10−2 2.0 × 10−3 8.7 × 10−3 7.5E × 10−2 8.6 × 10−2 9.6 × 10−6 1 × 10−5 5 × 10−5 Depleted UF6 tails going to:  Paducah conversion facility 1219 2.1 × 10−3 8.4 × 10−5 2.3 × 10−4 1.8 × 10−3 2.1 × 10−3 5.0 × 10−6 1 × 10−6 1 × 10−6  Portsmouth conversion facility 989 1.7 × 10−3 7.5 × 10−5 1.9 × 10−4 1.5 × 10−3 1.8 × 10−3 4.9 × 10−6 1 × 10−6 1 × 10−6 Empty 48Y cylinder return to:  Honeywell International 1314 1.6E × 10−2 1.4 × 10−3 3.6 × 10−3 2.9 × 10−2 3.4 × 10−2 2.1 × 10−8 1 × 10−5 2 × 10−5 LLRW going to:  EnergySolutions 3947 6.9 × 10−3 3.4 × 10−4 1.4 × 10−3 1.2 × 10−2 1.3 × 10−2 5.0 × 10−8 4 × 10−6 8 × 10−6 

a Cargo-related impacts are impacts attributable to the radioactive nature of the material being transported. b To convert person-rems to person-sieverts, divide by 100. c Vehicle-related impacts are impacts independent of the cargo in the shipment. d Latent cancer fatalities were calculated by multiplying the dose by the FGR 13 health risk conversion factors of 6 × 10−4 fatal cancers per person-rem. e Dose risk is a societal risk and is the product of accident probability and accident consequence. 
4-70 

1 

Table 4-13 Estimated Annual Collective Population Proposed GLE Facility Transportation 

 Cargo-Relateda Radiological Impacts  Dose Risk (person-rem)b Routine Public 

Latent Cancer

Fatalitiesd

Shipment 

Total 

Distance 

(km) Routine Crewe Off-Linkf On-Linkg Stopsh Total Accidenti Crew Public

E

F

UF6 feed coming from:  Portsmouth Marine Terminal 416,707 7.5 × 10−1 2.0 × 10−2 7.6 × 10−2 6.5 × 10−1 7.5 × 10−1 1.7 × 10−3 4 × 10−4 5 × 10−4  Dundalk Marine Terminal 679,014 1.2 5.6 × 10−2 1.5 × 10−1 1.0 1.2 6.8 × 10−3 7 × 10−4 2 × 10−4  Honeywell International 1,182,482 2.1 8.8 × 10−2 2.3 × 10−1 1.9 2.2 5.2 × 10−3 1 × 10−3 1 × 10−3  Cameco 1,257,364 2.3 9.8 × 10−2 2.7 × 10−1 2.0 2.3 1.1 × 10−2 1 × 10−3 1 × 10−3 UF6 product going to:  Westinghouse Electric 23,971 1.0 × 10−1 1.2 × 10−2 4.5 × 10−2 3.7 × 10−1 4.2 × 10−1 3.3 × 10−4 6 × 10−5 3 × 10−4  AREVA NP 239,277 1.0 1.0 × 10−1 4.4 × 10−1 3.8 4.3 4.8 × 10−4 6 × 10−4 3 × 10−3 Depleted UF6 tails going to:  Paducah conversion facility 975,262 1.7 6.7 × 10−2 1.8 × 10−1 1.4 1.7 4.0 × 10−3 1 × 10−3 1 × 10−3  Portsmouth conversion facility 791,411 1.4 6.0 × 10−2 1.5 × 10−1 1.2 1.4 3.9 × 10−3 8 × 10−4 8 × 10−4 Empty 48Y cylinder return to:  Honeywell International 65,693 8.1 × 10−1 6.9 × 10−2 1.8 × 10−1 1.4 1.7 1.0 × 10−6 5 × 10−4 1 × 10−3 LLRW going to:  EnergySolutions 142,095 2.5 × 10−1 1.2 × 10−2 5.0 × 10−2 4.2 × 10−1 4.8 × 10−1 1.8 × 10−6 1 × 10−4 3 × 10−4 a Cargo-related impacts are impacts attributable to the radioactive nature of the material being transported. b To convert person-rems to person-sieverts, divide by 100. c Vehicle-related impacts are impacts independent of the cargo in the shipment. d Latent cancer fatalities were calculated by multiplying the dose by the FGR 13 health risk conversion factors of 6 × 10−4 fatal cancers per person-rem. e Collective doses were calculated for truck transportation crew members involved in the actual shipment of material. Workers involved in loading or unloadf Dose to persons living or working within 0.8 kilometer (0.5 mile) of each side of a transportation route. g Dose to persons in all vehicles sharing the transportation route. This group includes persons traveling in the same or opposite directions as the shipment, 

vehicles passing the shipment. 

h Dose to persons who might be exposed while a shipment was stopped en route. For truck transportation, these stops include those for refueling, food, and i Dose risk is a societal risk and is the product of accident probability and accident consequence.
4-71 

1 exposure would be spread out among all people along the transportation routes. For example, 

2 50 annual shipments of the empty cylinders with tails to the Honeywell facility resulted in an 

3 estimated dose of 1.7 person-rem to 367,776 persons along the route, for an average individual 

4 dose of 0.0046 millirem. Thus, an average member of the public would receive only 

5 0.002 percent or less of the value for exposure to natural background radiation in one year. 

6 

7 For an MEI member of the public (defined as being located 30 meters [98 feet] away from a 

8 shipment passing at a speed of 24 kilometers per hour [15 miles per hour] [NRC, 1977]), the 

9 greatest radiological risk would be from the empty cylinders with heels shipments, as shown in 

10 Table 4-14. The remaining heels in the cylinders contain a concentration of residual daughter 

11 radionuclides that pose a greater external radiation hazard than present in full UF6 cylinders. In 

this case, a risk of 8 × 10−7 12 (a chance of less than 1 in 1.3 million) of contracting a fatal cancer is 

13 estimated and is 0.00004 percent of the value for an annual exposure to natural background 

14 radiation. However, the value for potential exposure to multiple shipments would be 

15 correspondingly higher. For example, if the same maximally exposed member of the public 

16 were present for three shipments of depleted UF6, that individual would receive a dose of 

approximately 2.6 × 10−5 17 millirem. 

18 

19 For transportation crew members, the largest estimated single shipment dose to one 

20 transportation crew member would be 11 millirem for shipments of the enriched product from 

21 the proposed GLE Facility to the AREVA facility in Richland, Washington. In this case, the risk 

22 of contracting a fatal cancer is 1 in 160,000. The transportation crew member dose of 

23 11 millirem is about 10 times lower than the estimated dose of 1.02 millisievert (102 millirem) if 

24 the dose rate in any normally occupied space in the vehicle was at the regulatory limit of 

25 0.02 millisievert per hour (2 millirem per hour) [10 CFR 71.47(b)(4)]. 

26 

27 No latent fatalities were estimated from vehicle emissions on an annual basis (risk < 0.5). In 

28 addition, the proposed action annual truck travel on U.S. highways for the most conservative 

29 case, 2,700,000 kilometers (1,700,000 miles) as shown in Table 4-13, is only 0.0012 percent of 

30 similar truck travel on an annual basis in the United States, 229,600,000,000 kilometers 

31 

Table 4-14 Maximally Exposed Individual 

Routine Dose from Radioactive 

Material Shipmentsa

Material Single Shipment Exposure 

(mrem)b

UF6 feed 9.1 × 10−6

UF6 product 9.2 × 10−5

Depleted UF6 tails 8.8 × 10−6

Empty cylinders 1.3 × 10−4

LLRW 1.7 × 10−5

a

 Individual is located 30 m from the passing shipment. 

Shipment is traveling at 24 km/hr. 

b

 To convert millirems to millisieverts, divide by 100. 
4-72 

1 (142,706,000,000 miles) (BTS, 2009). Thus, impacts on the public from vehicle emissions are 

2 considered to be SMALL. 

3 

4 Accident Impacts

5 

6 Overall annual transportation accident impacts from the proposed action are considered to be 

7 SMALL. The total annual radiological collective population accident dose risk to the public from 

all shipments for the most conservative case was estimated to be 1.6 × 10−2 8 person-rem. The 

resulting estimated LCFs are 1 × 10−5 9 annually. These impacts on the public would be SMALL 

10 because the exposure would be spread out among all people along the transportation routes. 

11 For example, 50 annual shipments of the empty cylinders with tails to the Honeywell facility 

resulted in an estimated accident dose risk of 1 × 10−6 12 person-rem to 367,776 persons along the 

route, for an average individual dose of 2.7 × 10−9 13 millirem. Thus, an average member of the 

14 public would receive a negligible percentage of the value for exposure to natural background 

15 radiation in one year. 

16 

17 Chemical impacts would be negligible; past analyses of depleted UF6 shipments have shown 

18 that the estimates of irreversible adverse effects to be approximately 1 to 3 orders of magnitude 

19 lower than the estimates of public LCFs from radiological accident exposure (DOE, 2004a and 

20 2004b; NRC, 2005a). In addition, only one percent or less of those persons experiencing 

21 irreversible adverse effects due to exposure to HF or uranium compounds actually results in 

22 fatality (Policastro, 1997). 

23 

24 Total fatalities from direct physical trauma as a result of accidents were estimated to be 

25 0.034 per year. Thus, no fatalities are expected from accidents on an annual basis. 

26 

27 4.2.10.3 Mitigation Measures 

28 

29 The major impact identified in Sections 4.2.10.1 and 4.2.10.2 was related to traffic congestion 

30 near the Wilmington Site entrance, primarily as a result of commuting construction and 

31 operations workers. Measures identified by GLE that would lessen such impacts include 

32 (GLE, 2008): 

33 

34 • Locate the proposed facility near an interstate highway interchange to facilitate employee 

35 commuter traffic and minimize the distance that truck traffic must travel on local surface 

36 streets. Selecting the Wilmington Site for the proposed action achieves this measure 

37 because of its proximity to I-140 on Castle Hayne Road. 

38 

39 • Increase the number of entry gates to the Wilmington Site from NC 133, including one 

40 dedicated to workers. The design for the Wilmington Site achieves this measure through 

41 the addition of a new, separate entrance dedicated to traffic destined for the proposed 

42 GLE Facility, thereby distributing the traffic load and reducing the impact on a single point of 

43 entry and exit. 

44 

45 • Implement roadway improvements such as deceleration lanes, turn lanes, and traffic control 

46 devices (e.g., traffic lights) to NC 133 as required by the North Carolina Department of 

47 Transportation (NCDOT) for issuance of a driveway permit for connecting the new entrance. 

48 
4-73 

1 • Work with the NCDOT to evaluate driveway- and roadway-improvement options to minimize 

2 impacts (and help regulate traffic flow in an orderly manner). 

3 

4 • Schedule/stagger worker shift changes for off-peak traffic periods, including those from shift 

5 changes for existing Wilmington Site facilities and other planned operations. 

6 

7 • Route truck shipments of radioactive materials around cities by using a U.S. Interstate 

8 Highway Systems bypass or beltway (when available). 

9 

10 • Schedule truck deliveries and shipments for off-peak traffic periods to reduce potential 

11 congestion on local roadways during peak worker commuting periods. 

12 

13 • Encourage carpooling for construction and operations workers. 

14 

15 4.2.11 Public and Occupational Health Impacts from Normal Operations 

16 

17 This section presents the environmental impacts on the surrounding public and on workers at 

18 the proposed GLE Facility from preconstruction activities, construction, and operation of the 

19 proposed facility for both radiological and non-radiological (i.e., hazardous chemical) exposures. 

20 For members of the public, this draft EIS considered the affected population within an 

21 80-kilometer (50-mile) radius of the proposed GLE Facility, with the primary exposure pathway 

22 being from gaseous effluents. Workers at the proposed GLE Facility could similarly be exposed 

23 to airborne or gaseous releases in addition to direct chemical and radiation exposures from 

24 handling UF6 cylinders, working near enrichment process equipment, or decontaminating 

25 cylinders and equipment. The analysis presented in this section is based on the assumptions 

26 that preconstruction and construction activities would start in 2011 and would continue until 

27 2017, operations would start in 2013, and there would be about four years of overlap between 

28 construction and operations of the proposed GLE Facility. NRC staff now expects that a 

29 licensing decision will be made in 2012 and that construction would begin at that time, but that 

30 the dates for initiation of preconstruction activities (2011), initial operations (2013), and full 

31 operations (2017) would remain unchanged. These schedule changes are not expected to 

32 affect the analysis of public and occupational health from normal operations. 

33 

34 4.2.11.1 Preconstruction and Construction Activities 

35 

36 This section evaluates the potential for occupational injuries and illnesses associated with the 

37 proposed preconstruction and construction activities. It also evaluates the potential public and 

38 occupational health impacts from non-radiological and radiological releases during 

39 preconstruction and construction activities. 

40 

41 Occupational Injuries and Illnesses

42 

43 The proposed action involves a major construction activity with the potential for industrial 

44 accidents related to construction vehicle accidents, material-handling accidents, and trips and 

45 falls. Resultant injuries could range from minor temporary injuries to long-term injuries and/or 

46 disabilities to fatalities. The proposed activities are not anticipated to be any more hazardous 

47 than those for a typical large industrial construction or demolition project. 

48 
4-74 

1 Non-radiological impacts associated with preconstruction and construction activities were 

2 estimated using annual injury and illness data for heavy construction compiled by the 

3 U.S. Department of Labor, Bureau of Labor Statistics (BLS). This bureau compiles statistics by 

4 the North American Industry Classification System, which replaced Standard Industrial 

5 Classification Codes in 2002. Preconstruction and construction activities for the proposed 

6 GLE Facility are classified under North American Industry Classification System Code 237, 

7 Other Heavy and Civil Engineering Construction. The most recent data available for incident 

8 rates for total recordable cases and lost workday cases, in units of incidents per 100 full-time 

9 equivalents, were obtained from the BLS publication “Table 1, Incident Rates of Nonfatal 

10 Occupational Injuries and Illnesses by Industry and Case Types 2007” (DOL, 2008a). The most 

11 recent data available for fatality incident rates for construction (North American Industry 

12 Classification System Code 237) for calendar year 2007, in units of incidents per 100,000 full13 time equivalents, were obtained from BLS publication “Table 2, Fatal occupational injuries by 

14 industry and selected event or exposure, 2007” (DOL, 2008b). The number of construction 

15 workers per year (full-time equivalents) and the duration of preconstruction and construction 

16 activities were obtained from the ER prepared to support the proposed action (GLE, 2008). The 

17 incident rates for total recordable cases, lost workday cases, and fatalities were applied to the 

18 projected number of construction worker-years for the seven-year project to estimate the total 

19 number of incidents. The incident rates, total full-time equivalents, and total incidents are 

20 summarized in Table 4-15. 

21 

22 Table 4-15 provides estimates of 95 lost work incidents of illness and injury to construction 

23 workers and less than one fatality over the approximately seven-year schedule. These totals 

24 include preconstruction impacts that are not part of the proposed action. Based on these 

25 estimates, impacts on occupational safety from preconstruction and construction activities would 

26 be SMALL. Assuming that preconstruction activities would be completed in the first year, about 

27 15 percent of these impacts, as well as those for non-radiological and radiological exposures 

28 discussed below, would occur during preconstruction activities. In estimating the impact from 

29 preconstruction activities, it is assumed that 290 full-time equivalents (FTEs) (GLE, 2008) would 

30 be involved compared to 1938 FTEs involved in total construction activities. 

31 

32 Non-Radiological Impacts

33 

34 Occupational exposures during preconstruction and construction activities would include 

35 exposure of construction workers to airborne fugitive dusts generated from vehicle traffic and 

36 heavy equipment use, exposure to pollutants emitted from diesel and gasoline powered 

37 equipment (e.g., carbon monoxide, nitrogen oxides, sulfur oxides, and particulate matter), and 

38 exposure to vapors from any fuels, paints, or solvents used during construction. Any such 

39 exposures would be expected to be minor and would be minimized using work practices and 

40 personal protective equipment specified in a construction health and safety plan. Construction 

41 activities would be subject to OHSA construction regulations (29 CFR Part 1926, Safety and 

42 Health Regulations for Construction). Such exposures would be typical of construction projects 

43 of industrial facilities. Worker exposure to low-level background emissions of uranium and HF 

44 from the existing FMO plant and from the proposed GLE Facility during the overlap period of its 

45 construction and early operation is discussed under cumulative impacts in Section 4.3.8 and 

46 under facility operations in Section 4.2.11.2. As noted in these sections, such exposures would 

47 be minor. 

48 
4-75 

Table 4-15 Health and Safety Statistics for Estimating Industrial Safety 

Impacts Common to the Workplace and Total Incidents for 

Preconstruction and Construction Activities

FTE Total Recordable Cases Lost Workday Cases Fatalities 

Average 

FTEs per 

year 

Total 

FTEsa

Incidents per 

100 FTEsb

Total 

Recordable 

Cases 

Incidents per 

100 FTEsb

Lost 

Workday 

Cases 

Incidents per 

1,000,000 FTEsc

Total 

Fatalities

277 1938 4.9 95 2.6 50 216 0.42 a

 FTEs (full-time equivalents) (GLE, 2008). b

 Source: DOL, 2008a. 

c

 Source: DOL, 2008b. 

1 

2 The estimated levels of air pollutants emitted during road construction, land clearing, and 

3 building construction activities are presented in Section 4.2.4. As indicated there, impacts on air 

4 quality during these preconstruction and construction activities would be SMALL. 

5 Preconstruction and construction activities are not expected to cause any exceedances of 

6 ambient air quality criteria, with the possible exception of minor exceedances of short-term 

7 criteria for particulate matter (PM2.5 and PM10) from fugitive dust emissions. Worker exposures 

8 would be limited through the use of dust masks or respirators, as appropriate. 

9 

10 Impacts on surface water and groundwater during preconstruction and construction activities 

11 have also been analyzed in this draft EIS in Sections 4.2.6 and 4.2.7, respectively. These 

12 analyses showed that surface water impacts would be minimized during these activities though 

13 the use of BMPs and engineering controls (see Section 4.2.5.3). Releases to surface water 

14 streams would be governed under an NPDES permit. Temporary increases in sedimentation 

15 and turbidity in streams may occur from stormwater runoff from soils disturbed by construction 

16 activities. As for surface waters, impacts on groundwater would be prevented using best 

17 practices and engineering controls to prevent or contain any spills of hazardous materials, 

18 including fuels for vehicles and equipment. 

19 

20 Radiological Impacts

21 

22 Radiological impacts during preconstruction and construction activities would be received 

23 primarily by the construction workers. Exposures to the offsite public would not be expected 

24 due to the distance from construction emission sources. Construction workers would not be 

25 monitored for radiation exposure by the onsite radiation exposure control program. Thus, the 

26 applicable dose limits for the construction workers would be as for the general public listed in 

27 10 CFR 20.1301(a)(1) (i.e., 0.1 sievert per year [100 millirem per year]). 

28 

29 Preconstruction and construction activities would not generate any radiological contamination, 

30 but they could disturb areas previously contaminated due to deposition of contaminated 

31 particulates on soil from air effluent releases of past FMO facility operations as well as to the 

32 current air emission from FMO facility operations. Preconstruction and construction workers 

33 would also be exposed to emissions from the proposed GLE Facility during the overlap period of 

34 construction and early operation. 

35 
4-76 

1 The primary exposure pathways for construction personnel would be: (1) inhalation of 

2 contaminated dust resuspended by construction activities in contaminated soils; (2) inhalation of 

3 air effluent releases from FMO operations; (3) inhalation of air effluent releases from the 

4 proposed GLE operations after 2013; (4) external exposure from previously contaminated 

5 ground; and (5) external exposure from onsite sources, such as the cylinder storage yards. The 

6 construction workers were not assumed to consume food grown at the Wilmington Site or 

7 consume water impacted by site contamination. Therefore, potential exposure from ingestion of 

8 food and drinking water was not included. The external exposure from the air submersion 

9 pathway was also ignored, as it would be small compared to direct external exposure. 

10 

11 For calculating the doses to workers from the various existing soil contamination, the RESRAD 

12 code Version 6.5 (Yu et al., 2001) was used in conjunction with contamination data from site 

13 environmental reports (GNF-A, 2007) and the environmental assessment for the license 

14 renewal for the Global Nuclear Fuels-Americas (GNF-A) (FMO) facility (NRC, 2009c). A 

15 description of the modeling approach in RESRAD code for this analysis is provided in 

16 Appendix C. The CAP88-PC computer code was used in estimating the internal dose from 

17 FMO and GLE air emissions (see Section 4.2.11.2). For estimating the external dose from the 

18 cylinder storage yard, the RESRAD-BUILD code Version 3.5 (Yu et al., 2003) was used. A 

19 description of the modeling approach in RESRAD-BUILD code and the CAP88-PC code’s 

20 modeling approach for this analysis are also provided in Appendix C. 

21 

22 The maximum estimated dose for each of the exposure pathways was calculated for an annual 

23 exposure period. These estimated doses are: 

24 

• internal dose from inhalation of resuspended contaminated soil: <6 × 10−5 25 millisievert per 

year (6 × 10−3 26 millirem per year) 

27 

• external dose from contaminated soil: <3.2 × 10−4

 millisievert per year (3.2 × 10−2 28 millirem 

29 per year) 

30 

• internal dose from inhalation of air emissions from FMO operations: <2.8 × 10−5 31 millisievert 

per year (2.8 × 10−3 32 millirem per year) 

33 

34 • internal dose from inhalation of air emissions from the proposed GLE operations: 

<3.2 × 10−7

 millisievert per year (3.2 × 10−5 35 millirem per year) (Section 4.2.11.2) 

36 

• external dose from the existing site sources: <1.05 × 10−1 37 millisievert per year (10.5 millirem 

38 per year) 

39 

40 The total maximum possible dose before and after the start of GLE operations is 

<1.05 × 10−1 41 millisievert per year (10.5 millirem per year). The dose is dominated by the 

42 external dose received from existing site sources. 

43 

The maximum dose to construction workers of 1.05 × 10−1 44 millisievert (10.5 millirem) is a very 

45 small fraction of background radiation exposure in the United States, which averages 

46 approximately 3.1 millisieverts per year (311 millirem per year) (Section 3.11.1). The estimated 

47 maximum yearly dose applies to workers in both the preconstruction and construction phases. 

48 
4-77 

1 The total maximum possible dose to construction workers from all pathways is less than the limit 

2 of 1 millisievert per year (100 millirem per year) in 10 CFR 20.1301(a)(1), even for estimates 

3 combining the most conservative analytical assumptions. This is a negligible dose, representing 

a lifetime excess cancer risk of less than 5 × 10−6 4 (less than a 5 in 1,000,000 chance of getting 

cancer) when using a risk coefficient of 5 × 10−2

 risk per sievert (5 × 10−4 5 risk per rem) 

6 (ICRP, 1991). Based on this assessment, the impact on workers from radiological exposure 

7 during preconstruction and construction is SMALL. 

8 

9 The dose to the offsite public will be significantly smaller than that for construction workers, as 

10 they will not have any potential for measurable exposure from the existing site contamination. 

11 The impact on the offsite public from preconstruction and construction is therefore SMALL. 

12 

13 4.2.11.2 Facility Operations 

14 

15 This section evaluates potential occupational injuries and illnesses, as well as public and 

16 occupational health impacts associated with non-radiological and radiological releases, from 

17 operation of the proposed GLE Facility. 

18 

19 Occupational Injuries and Illnesses

20 

21 The estimated rates and numbers of injuries to workers during operation of the proposed 

22 GLE Facility were determined from Bureau of Labor Statistics tables of rates and from numbers 

23 of expected workers in the same manner as for preconstruction and construction. For these 

24 estimates, operation of the proposed GLE Facility is classified under North American Industry 

25 Classification System Code 325, Chemical Manufacturing. The most recent data available for 

26 incident rates for total recordable cases and lost workday cases, in units of incidents per 

27 100 full-time equivalents, for North American Industry Classification System Code 325 were 

28 obtained from the BLS publication “Table 1, Incident Rates of Nonfatal Occupational Injuries 

29 and Illnesses by Industry and Case Types 2007” (DOL, 2008a). The most recent data available 

30 for fatality incident rates for Manufacturing (North American Industry Classification System 

31 Code 325) for calendar year 2007, in units of incidents per 100,000 FTEs, were obtained from 

32 the BLS publication “Table 2, Fatal Occupational Injuries by Industry and Selected Event or 

33 Exposure, 2007” (DOL, 2008b). 

34 

35 Incident rates for total recordable cases, lost workday cases, and fatalities were applied to the 

36 projected annual number of workers (GLE, 2008) over the years of the projected operation 

37 schedule to estimate the total number of incidents. The estimated total incidents of each type 

38 are presented in Table 4-16. For the first six years of operations, 550 workers would be 

39 required, and 350 workers would be required thereafter. A total of 14,500 FTEs were computed 

from a projected 38 years of operations.17 40 

 

17 The assumption that the proposed GLE Facility would operate for 38 years, if a license is granted, is 

based the assumption that operations would begin in 2013 and continue until 2050, with license 

termination occurring in 2051. As discussed in Section 4.2, the NRC staff still expects operations to 

begin in 2013, but a license, if issued, would be issued in 2012 and terminate in 2052. Thus, a slightly 

longer operational period may result in a slight difference in the total projected full-time equivalent 

employment during operations. This slight change is not expected to affect any of the impacts 

conclusions. 
4-78 

Table 4-16 Health and Safety Statistics for Estimating Industrial Safety Impacts 

Common to the Workplace and Total Incidents for Facility Operations

FTE Total Recordable Cases Lost Workday Cases Fatalities 

FTEs 

per 

Year 

Total 

FTEsa

Incidents per 

100 FTEsb

Total 

Recordable 

Cases 

Incidents per 

100 FTEsb

Lost 

Workday 

Cases 

Incidents per 

100,000 FTEsc Fatalities 

550 14,500 3.1 450 1.7 247 2.8 0.41 

a

 Full-time equivalents (FTEs) (GLE, 2008). 

b

 Source: DOL, 2008a. 

c

 Source: DOL, 2008b.

1 

2 A total of 450 total recordable incidents and 247 lost workday incidents are projected for 

3 38 years of operation of the proposed GLE Facility. Over the same period, less than one fatal 

4 injury is projected. According to the small number of projected non-fatal and fatal incidents, 

5 impacts on occupational health and safety during facility operations are expected to be SMALL. 

6 

7 Routine Non-Radiological Impacts

8 

9 Since the proposed GLE Facility would be based on a new, laser-based, technology, no 

10 historical data are available on workplace concentrations of toxic chemicals of concern, UF6 and 

11 HF. However, it is expected that the greatest potential for occupational exposures inside the 

12 GLE process building could be due to connecting and disconnecting of the UF6 cylinders during 

13 operations and repair activities, which are the processes that produce the highest potential 

14 emissions of UF6 at existing uranium enrichment facilities employing centrifuge technologies 

15 (GLE, 2008). GE-Hitachi experience in UF6 cylinder handling at its FMO facility would be useful 

16 in limiting exposures. Any released UF6 would react with ambient moisture to form HF and 

17 uranyl fluoride (UO2F2). Airborne concentrations of HF and UO2F2 inside facilities are expected 

18 to be insignificant with respect to general worker exposure. Workers would use ventilation 

19 equipment in the immediate vicinity of cylinder handling or similar operations with potential UF6

20 releases to minimize exposures. An analysis performed for the proposed American Centrifuge 

21 Plant (ACP) in Piketon, Ohio, found that workplace HF concentrations from these operations 

22 would be, on average, less than one percent of the Occupational Safety and Health 

23 Administration’s Permissible Exposure Limit of 2.5 milligrams per cubic meter of air over an 

24 8-hour averaging time. The Piketon facility is assumed to be an appropriate model for such 

25 exposures at the proposed GLE Facility, as exposures would most likely occur during the same 

26 kind of operations associated with the connecting and disconnecting of cylinders to and from 

27 process lines. Concentrations in the immediate vicinity of the release point could be briefly as 

28 high as 10 percent of the limit and would be limited by ventilation equipment. The 

29 corresponding analysis for UF6 at ACP found that maximum expected levels of 0.7 milligrams 

30 per cubic meter would be well below the relevant workplace one-hour standard of 10 milligrams 

31 per cubic meter of uranium (NRC, 2006). Based on this analysis, the impacts associated with 

32 routine occupational exposures to HF and UF6 in the workplace should be SMALL. 

33 

34 Large volumes of UF6 would be present at the proposed GLE Facility as feed material and 

35 product material as a consequence of the primary function of the facility − uranium enrichment. 

36 This material, which is solid at ambient temperatures, would be stored in appropriate steel 
4-79 

1 canisters in the feed storage and product storage areas. There would be no routine exposures 

2 to solid UF6. 

3 

4 Worker health and safety would be the focus of the GLE Nuclear Safety Program and the 

5 Industrial Safety Program administered by the Industrial Health and Safety manager at the 

6 Wilmington Site. Work practices at the proposed GLE Facility would be evaluated to assure that 

7 workers were protected through the implementation of appropriate safety measures, including 

8 the use of safety equipment and personal protective equipment (GLE, 2008). Worker exposure 

9 to industrial chemicals would be limited to safe levels though a combination of minimizing 

10 airborne releases within and outside of the proposed GLE Facility and use of appropriate 

11 protective equipment, such as fume hoods, in situations where elevated air concentrations could 

12 exist. Hazardous chemicals would be handled under written procedures administered by the 

13 Industrial Safety Program. Industrial activities would be subject to OSHA’s industrial regulations 

14 (29 Part CFR Part 1910, Occupational Safety and Health Standards), as well as site licenses 

15 and permits (GLE, 2008). 

16 

17 Because of the controls on chemical exposures that would be in place under an ongoing 

18 chemical safety program, non-radiological impacts on workers from routine operation of the 

19 proposed GLE Facility are expected to be SMALL. 

20 

21 The proposed GLE Facility would use banks of lasers to effect the enrichment of uranium. 

22 Thus, potential worker exposure to laser light would be a safety concern. Injuries to the eye 

23 would be the primary concern. Lasers would normally be operated within enclosures, while 

24 lasers would be equipped with interlocks to prevent inadvertent exposures from opening of 

25 enclosures. To ensure that protections are in place and to prevent any accidental exposures, a 

26 formal laser safety program would be implemented at the facility, headed by a Laser Safety 

27 Officer and employing a written laser safety protocol. The program would require laser safety 

28 training for all personnel working with or around laser equipment. Laser safety reviews would 

29 be conducted in advance of any maintenance, repair, or non-routine activity where exposures 

30 are possible. At the State level, laser safety would be overseen by the North Carolina 

31 Department of Labor, Division of Occupational Safety and Health. Applicable regulations 

32 relevant to laser safety would include Federal standards for ionizing and non-ionizing radiation, 

33 General Industrial Regulations for eye and face protection under 29 CFR 1910.132, and laser 

34 exposure limits under American National Standards Institute standard ANSI Z136.1. North 

35 Carolina Department of Environmental Health General Industry Standards (under 13 N.C. 

36 Admin Code 07F) would apply as well. With laser protections in place, laser impacts on worker 

37 health would be SMALL. 

38 

39 With respect to public health impacts, non-radiological releases from operation of the proposed 

40 GLE Facility to surface water and groundwater, including liquid waste effluents from 

41 decontamination, cleaning, and laboratory processes and from cooling tower blowdown, should 

42 be small and should not degrade existing water quality (Sections 4.2.6.2 and 4.2.7.2). 

43 Therefore, the public health impacts associated with such liquid releases would also be SMALL. 

44 

45 Potential long-term, low-level HF and uranium exposure to members of the public would be the 

46 primary offsite chemical exposures of concern. Public health impacts from such exposures are 

47 expected to be SMALL, however. The building housing the enrichment process would be 

48 operated under negative pressure. Any leaks, therefore, would exit the building only through 
4-80 

1 the ventilation system, which would be equipped with a HEPA filter to remove particulate matter 

2 and with carbon beds to remove gaseous contaminants (GLE, 2008). Only minor quantities of 

3 UF6 or HF would thus escape the system, as dictated by the efficiency of the filter devices. 

4 

5 As discussed in Section 4.2.4.2, carbon beds are expected to remove ≥99 percent of the HF in 

6 the gas vented through the operations building stack. The specific quantity of HF that would 

7 pass through the emissions control devices is not known at this time, but should be below levels 

8 established in a required air permit for the proposed GLE Facility and protective of public health 

9 (i.e., the facility would be assumed to meet its air permit requirements). Absent such estimates, 

10 onsite and offsite exposures were estimated using estimates for the National Enrichment Facility 

11 (NEF), a three million separative work unit (SWU) gas-centrifuge plant proposed to be built in 

12 New Mexico (NRC, 2005b). Most HF emissions would be expected to occur in feed and product 

13 ends of the operations at both types of plants, so similar emission levels would be expected for 

14 a given amount of UF6 processed. Since the proposed GLE Facility would have twice the output 

15 of this facility, twice its estimated discharge point (ventilation stack) concentration of 

16 3.9 micrograms per cubic meter, or 7.8 micrograms per cubic meter (0.0095 parts per million), 

17 was assumed to be the concentration at the proposed GLE Facility’s stack. Table 4-17 shows 

18 modeled HF concentrations at various onsite and offsite locations after dispersion. A maximum 

HF concentration of only 3.7 × 10−4

 micrograms per cubic meter (4.5 × 10−7 19 parts per million) is 

20 estimated at the location of an onsite member of the public or construction worker, which is far 

21 below the OSHA chronic (8-hour) exposure level of 2.5 milligrams per cubic meter (31 parts per 

22 million), while offsite locations would be far below public exposure standards discussed in 

23 Section 3.11.2. Given that the concentrations estimated for receptor locations would be far 

24 below levels of concern, the stated assumptions should be sufficiently accurate for the purposes 

25 of the analysis. 

26 

27 Uranium concentrations to which receptors could be exposured are shown in Table 4-17. 

28 These concentrations were based on GLE’s estimated emission rate for uranium isotopes, 

29 (GLE, 2008; Table S-2) after converting uranium activity to mass. The maximum uranium 

concentration is estimated to be 1.9 × 10−7 30 micrograms per cubic meter at the location of the 

31 onsite member of the public. 

32 

33 Both the estimated HF and uranium concentrations at onsite exposure locations are many 

34 orders of magnitude below safe levels established by the OSHA (2.5 milligrams per cubic meter 

35 for HF and 50 micrograms per cubic meter for uranium, each averaged over eight hours, 

36 see Section 3.11.2). Modeled UF6 and HF levels at the site boundary and at the location of the 

37 nearest resident given in Table 4-17 are even lower than onsite levels. HF concentrations at 

38 any exposure location, moreover, are far below the most stringent State or Federal ambient air 

39 quality standards for the general public, for example, Washington’s standard of 8.7 micrograms 

40 per cubic meter (0.011 parts per million) (ATSDR, 2003). Since these estimates are based on a 

41 continuous release, they represent a continuous exposure. Such chronic exposure modes are 

42 considered in the formulation of the aforementioned air quality standards. 

43 

44 HF emissions would be monitored in vent stacks (as fluoride) and would be limited by an air 

45 quality permit required for the operation of the proposed GLE Facility that would be issued by 

46 the NCDAQ and would be protective of public health. This permit would consider 

47 GLE emissions in combination with those from the existing FMO facility, which would be 
4-81 

Table 4-17 Predicted Airborne Concentrations of Uranium and Hydrogen 

Fluoride from Proposed GLE Facility Stack Releases at Different Receptor 

Locations 

Location Direction Distance 

Metersa 

Total 

Uranium 

(μg/m3

)

b

HFc

(μg/m3

) 

Site Boundary North 399 1.1 × 10−7 2.2 × 10−4

Site Boundary North–northwest 573 5.2 × 10−8 1.0 × 10−4

Site Boundary Northwest 924 2.7 × 10−8 5.3 × 10−5

Site Boundary West–northwest 1493 1.5 × 10−8 2.9 × 10−5

Site Boundary West 1717 2.2 × 10−8 4.4 × 10−5

Site Boundary West–southwest 2302 1.8 × 10−8 3.5 × 10−5

Site Boundary Southwest 1806 3.0 × 10−8 5.8 × 10−8

Site Boundary South–southwest 1892 2.9 × 10−8 5.7 × 10−5

Site Boundary South 1416 5.1 × 10−8 1.0 × 10−4

Site Boundary South–southeast 1708 1.9 × 10−8 3.7 × 10−5

Site Boundary Southeast 2664 1.1 × 10−8 2.1 × 10−5

Site Boundary East-southeast 1270 1.9 × 10−8 3.8 × 10−5

Site Boundary East 671 6.5 × 10−8 1.3 × 10−4

Site Boundary East–northeast 427 1.1 × 10−7 2.1 × 10−4

Site Boundary Northeast 353 1.5 × 10−7 3.0 × 10−4

Site Boundary North–northeast 346 1.2 × 10−7 2.4 × 10−4

Onsite Member of the Public South 250 1.9 × 10−7 3.7 × 10−4

Nearest Resident East–southeast 1352 1.8 × 10−8 3.6 × 10−5

a

 To convert meters to feet multiply by 3.28. 

b

 106 micrograms = 1 gram. c

 HF concentrations are based on dispersion of a release point concentration of 7.8 μg/m3, or twice 

that estimated for the 3 million SWU proposed National Enrichment Facility (NRC, 2005b). 

1 substantially higher because of the nature of the chemical processes conducted there 

2 (GLE, 2008). No criteria air pollutants (e.g., CO, NOx, SO2, or VOCs) would be produced by the 

3 GLE process, as discussed in Section 4.2.4.2. 

4 

5 Routine Radiological Impacts

6 

7 This section describes the potential routine radiological impacts on members of the public and 

8 workers from the proposed GLE Facility. Appendix C documents the methodology used in 

9 evaluating and reviewing project information and also includes the site-specific data used. 

10 

11 
4-82 

1 Public Health Impacts

2 

3 Operation of the proposed GLE Facility could result in radiation exposure to the public via intake 

4 (ingestion or inhalation) of uranium released from the facility or from direct external exposure to 

5 radiation emitted by the uranium present at the facility. The two potential pathways of concern 

6 potentially leading to public intake of uranium would be airborne releases and liquid releases. 

7 With respect to releases to air, any UF6 gas released inside the proposed GLE Facility’s 

8 operations building during operations and repair activities would be sent through a ventilation 

9 system employing a high-efficiency, multi-stage, emissions control system that incorporates 

10 HEPA filters for removal of particulate matter and activated carbon beds for gas absorption, 

11 minimizing outside releases. Liquid releases could result from decontamination, cleaning, and 

12 maintenance of failed equipment or equipment being serviced and any associated releases of 

13 radioactive liquids to surface water. However, these liquids would be treated and sampled to 

14 limit releases via a permitted outfall. Exposure of members of the public to direct external 

15 radiation could occur from emission of radiation from uranium in process lines, in cylinders in 

16 storage areas, and during handling, temporary storage, and transportation within and outside of 

17 the site. The direct radiation emitted by the uranium in the facility would be significantly 

18 absorbed by the walls of the storage cylinder, and building walls, process lines and equipment 

19 within the proposed GLE Facility. Additionally, any direct radiation would diminish with distance 

20 as it traveled over 1300 meters (0.8 miles) to reach the current nearest member of the public. 

21 Any direct radiation and skyshine (radiation reflected from the atmosphere) from uranium 

22 released to the air would be expected to be undetectable at offsite areas due to the very low 

23 concentrations of such releases. 

24 

25 Public Dose from Airborne Releases of Radioactive Materials 

26 

27 The proposed GLE Facility’s operations building would release small amounts of uranium to the 

28 atmosphere during operation through a single rooftop stack. The modeling performed by NRC 

29 for this analysis evaluated the impact of these releases to offsite populations and to onsite 

30 populations that are not included in the site’s radiological dose monitoring program 

31 (e.g., construction workers). Exposures in both of these groups would be subject to the 

32 1 millisievert per year (100 millirem per year) public exposure limits in 10 CFR 20.1301(a)(1) 

33 and the 0.1 millisieverts per year (10 millirem per year) airborne dose limits in 40 CFR Part 61, 

34 Subpart H, the EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAPs). 

35 

36 GLE laser-enrichment is a new technology and therefore, there are currently no test data to 

37 quantify the air emissions from the proposed GLE Facility. Monitoring data for the existing FMO 

38 facility vents that approximate the proposed GLE Facility’s operations were used to approximate 

39 the proposed GLE Facility’s emissions (GLE, 2008). Dispersion of uranium emitted at this 

40 estimated release rate was modeled from the design height of the rooftop vent of the proposed 

41 GLE Facility’s main operations building. Table 4-18 shows the stack and vent characteristics, 

42 site-specific parameters, and annual release rates assumed in dose modeling. The stack could 

43 be higher (21–27 meters [69–89 feet]) as reported by GLE (GLE, 2009a), but the lower value of 

44 15.24 meters (50 feet) (GLE, 2008) is used because it is conservative and the doses are small. 

45 
4-83 

Table 4-18 Proposed GLE Facility Stack/Vent 

Characteristics, Site Characteristics, and Stack 

Releases Used in Modeling 

Input Parameter Value 

Stack Diameter (m) 1.2 

Stack Release Height (m)a 15.24 

Velocity (m/s) 12.3 

Temperature Ambient 

Uranium-234 Emission Rate (Ci/sec)b 1.25 × 10−13

Uranium-235 Emission Rate (Ci/sec)b 4.88 × 10−15

Uranium-236 Emission Rate (Ci/sec)b 5.49 × 10−17

Uranium-238 Emission Rate (Ci/sec)b 1.77 × 10−14

Ambient Temperature (°C) 17.7 

Annual Precipitation (cm) 144.96 

a

 Stack could be higher (21–27 meters [69–89 feet]) as 

reported by GLE in June 2009 (GLE, 2009a), but the lower 

value (GLE, 2008) is used because it is conservative and the 

doses are small. 

b

 Emission rates are converted to Ci/yr by multiplying 

3.15 × 107

 sec/yr conversion factor for input in the CAP-88 

code. 

Source: GLE, 2008 (Tables S-1 and S-2). 

1 

2 EPA air modeling code CAP88-PC (Version 3) was used to assess the impacts from the 

3 proposed GLE Facility’s air emissions. This code is approved by the EPA for demonstrating 

4 compliance with NESHAPs. The code calculates radiation doses from a number of exposure 

5 pathways, including inhalation, submersion, groundshine, and ingestion of contaminated food 

6 following uranium deposition on the ground. A description of the modeling approach in the 

7 CAP88-PC code for this analysis is provided in Appendix C. 

8 

9 Data for wind speed and direction by stability classes were taken from the Wilmington 

10 International Airport meteorological station for the years 1988 through 1992 (Rosnick, 2007). 

11 The distances from the proposed GLE Facility stack to the receptor locations were measured to 

12 the Wilmington Site boundary in each of the 16 compass directions (GLE, 2009a). Receptor 

13 dose was also calculated at 250 meters (0.16 mile) to model the nearest onsite member of the 

14 public (e.g., a construction worker) and at 1350 meters (0.84 mile) to model the nearest 

15 resident. Separate runs for the onsite member of the public, site boundary, and nearest 

16 resident were made. 

17 

18 The onsite member of the public was assumed to consume foodstuff produced within an 

19 80-kilometer (50-mile) radius surrounding the proposed GLE Facility but not produced onsite 

20 (regional food pattern in the code). The rural food consumption pattern was used to estimate 

21 the dose at the site boundary and the nearest resident. The rural food consumption pattern 
4-84 

1 assumes a high percentage of the foodstuff is produced at home or at the point of exposure 

2 (70 percent vegetables, 40 percent milk, and 44 percent meat), and the remainder is produced 

3 within an 80-kilometer (50-mile) radius of the release point (proposed GLE Facility). These food 

4 assumptions are very conservative, because very few people actually consume 100 percent of 

5 their diet produced within 80 kilometers (50 miles) of their residence (Hill, 2008). 

6 

7 Table 4-19 shows the estimated dose to hypothetical receptors residing at the site boundary in 

8 each of the 16 directions modeled in CAP88-PC (Version 3). Information about doses from 

9 natural background radiation is provided in Section 3.11.1. Table 4-19 also includes the dose to 

10 the onsite member of the public and the nearest resident. The maximum dose to a hypothetical 

11 receptor at the Wilmington Site boundary is in the northeast direction (0.35 kilometers 

[0.22 miles]) of the proposed GLE Facility, estimated to be 1.1 × 10−6 12 millisievert per 

year (1.1 × 10−4 13 millirem per year). The estimated dose to the nearest resident located 

14 at 1.35 kilometers (0.84 miles) east-southeast of the proposed GLE Facility is 

1.4 × 10−7

 millisievert (1.4 × 10−5 15 millirem per year). The maximum estimated dose for the 

16 onsite member of the public assumed to be located 250 meters (0.16 mile) to the south of the 

GLE stack is 3.2 × 10−7

 millisievert per year (3.2 × 10−5 17 millirem per year). For calculating the 

18 dose for the onsite member of the public it was assumed that the member of the public was on19 site for 2000 hours in one year. All of these estimated doses are well below the 1 millisievert 

20 per year (100 millirem per year) public exposure limits in 10 CFR 20.1301(a)(1) and the 

21 0.1 millisievert per year (10 millirem per year) airborne dose limits in 40 CFR Part 61, Subpart H 

22 (NESHAPs). Therefore, impacts on members of the public from the air emissions of the 

23 proposed GLE Facility would be SMALL. 

24 

25 The CAP-88 PC code also calculates airborne concentrations in picocuries per cubic meter for 

26 each radionuclide at the user-defined locations. These concentrations can be converted to 

27 micrograms per cubic meter for the purpose of evaluating the chemical toxicity of uranium. 

28 Uranium exerts heavy metal toxicity, primarily to the kidney (Section 3.11.3.3). Table 4-17 

29 provides the calculated airborne uranium (and HF) concentrations at the same receptor 

30 locations as in Table 4-19. 

31 

32 In summary, airborne emission of uranium from the proposed GLE operations are predicted to 

33 cause radiation doses that are well below the 1 millisievert per year (100 millirem per year) 

34 public exposure limits in 10 CFR 20.1301(a)(1) and the 0.1 millisievert per year (10 millirem per 

35 year) airborne dose limits in 40 CFR Part 61, Subpart H, the EPA’s NESHAPs. The airborne 

36 concentration of uranium from the proposed GLE operations are also well below the toxicity 

37 limits established by the National Institute for Occupational Safety and Health and the American 

38 Conference of Industrial Hygienists. Therefore, the impacts from proposed GLE Facility air 

39 emission are expected to be SMALL. 

40 

41 
4-85 

Table 4-19 Annual Effective Dose from Proposed GLE Facility Stack 

Releases at Different Receptor Locations 

Location Direction Distance Metersb Dose mSv/yrc

Site Boundary North 399 8.5 × 10−7

Site Boundary North–northwest 573 6.2 × 10−7

Site Boundary Northwest 924 2.1 × 10−7

Site Boundary West–northwest 1493 4.7 × 10−8

Site Boundary West 1717 1.7 × 10−7

Site Boundary West-southwest 2302 1.4 × 10−7

Site Boundary Southwest 1806 2.3 × 10−7

Site Boundary South–southwest 1892 2.2 × 10−7

Site Boundary South 1416 3.9 × 10−7

Site Boundary South–southeast 1708 2.5 × 10−7

Site Boundary Southeast 2664 1.8 × 10−7

Site Boundary East–southeast 1270 1.5 × 10−7

Site Boundary East 671 4.9 × 10−7

Site Boundary East–northeast 427 8.3 × 10−7

Site Boundary Northeast 353 1.1 × 10−6

Site Boundary North–northeast 346 9.4 × 10−7

Onsite Member of the 

Publica

South 250 3.2 × 10−7

Nearest Resident East–southeast 1352 1.4 × 10−7

a

 Onsite member of the public in the south direction got the maximum dose. For calculating the 

dose for the onsite member of the public it was assumed that the member of the public was onsite 

for 2000 hours in one year. 

b

 To convert meters to feet multiply by 3.28. 

c

 To convert mSv to mrem multiply by 100. 

1 

2 Public Dose from Direct Gamma Radiation 

3 

4 The presence of radioactive materials at the proposed GLE Facility would present the possibility 

5 for onsite members of the public to receive a radiation dose directly from gamma rays (photons) 

6 emitted from these materials. Isotopes of uranium could be present in quantities large enough 

7 to provide the potential for onsite members of the public to receive a measurable external 

8 radiation dose. Of the uranium onsite, only that being stored as depleted uranium would be 

9 continuously present in sufficient quantity to represent a potential source of direct radiation dose 

10 to the onsite member of the public. However, as noted above, gamma emissions would be 

11 attenuated to a large degree by container walls, structures, and through distance to receptors. 

12 There would be small amounts of other gamma emitters present onsite as sealed sources and 

13 laboratory standards, but these are not detectable at any large distance. 
4-86 

1 The measured radiation dose at various locations of interest from existing radiation sources at 

2 the Wilmington Site was used to gauge the public dose from direct gamma radiation from the 

3 proposed GLE Facility. The site conducts external gamma radiation monitoring using a network 

4 of thermoluminescent dosimeters (TLDs) positioned at various locations both on and off the 

5 Wilmington Site. The TLD readings are inclusive of any exposure caused by the presence of 

6 existing radiation sources on the Wilmington Site, including direct radiation and skyshine from 

7 the existing cylinder storage yards. None of the TLDs showed readings above the background 

8 exposure rate of 5 microentgens per hour (GLE, 2009b) at the site boundary. The distance to 

9 the nearest site boundary from the additional storage yards planned for the proposed 

10 GLE Facility is greater than 350 meters (1148 feet). Because of the shielding and the distance 

11 to the receptors, it is expected to have only a minor effect on the direct radiation exposure rate 

12 at the site boundary. Therefore, the impact from direct exposure to the public is expected to be 

13 SMALL. 

14 

15 Public Dose from Liquid Releases of Radioactive Material 

16 

17 The proposed GLE Facility would generate process and sanitary liquid effluent streams. 

18 Process wastewater generated at the proposed GLE Facility is a combination of 5000 gallons 

19 per day (18,900 liters per day) of liquid radiological waste generated from decontamination, 

20 cleaning, and laboratory activities and 30,000 gallons per day (113,600 liters per day) of cooling 

21 tower blowdown that circulates in a closed-loop system and does not come in direct contact with 

22 uranium materials. Radioactive wastewater is collected via a closed-drain system and 

23 discharged to an accumulator tank. The closed-drain system allows the liquid radioactive 

24 wastewater generated from different activities involving radioactive material to be collected at 

25 one place instead of being discharged. Liquid radioactive wastewater in the tank would be 

26 sampled on a regular basis before routing to a liquid effluent treatment system. The treated 

27 effluent would be discharged to the final process lagoon facility. Blowdown from the cooling 

28 water system would be piped directly to the final process lagoon facility (GLE, 2008). The water 

29 from the lagoon facility would be discharged through an NPDES-permitted outfall (Outfall 001) 

30 to the effluent channel. The 10,500 gallons per day (40,000 liters per day) sanitary wastewater 

31 generated would be treated in the existing sanitary wastewater treatment facility. The treated 

32 sanitary wastewater effluent would be used to replace blowdown from the cooling towers. The 

33 stormwater runoff from the proposed GLE Facility would drain to a stormwater wet detention 

34 basin before being discharged. In addition, a holding pond would be placed near the UF6

35 storage pads to collect the stormwater runoff from these pads. Monitoring for gross alpha/beta 

36 activities, total uranium, and fluoride would be conducted at the holding pond before the water is 

37 discharged to the stormwater wet detention basin. If any unanticipated radioactivity is detected 

38 in the holding pond, radiological material would be allowed to settle and/or precipitate. The 

39 liquid then would be pumped from the holding pond and, if necessary, routed to the GLE liquid 

40 effluent treatment system. The effluent channel includes the discharges from all liquid effluent 

41 streams from the Wilmington Site and flows to the Northeast Cape Fear River through Unnamed 

42 Tributary #1. 

43 

44 For calculating the doses to the public from liquid effluent releases, the GENII code 

45 Version 2.06 (Napier, 2004) was used. The code has been developed by Pacific Northwest 

46 National Laboratory for the EPA for calculating dose and risk from radionuclide releases in the 

47 environment. GENII Version 2 incorporates internal dosimetry models recommended by the 

48 International Commission on Radiological Protection (ICRP), and the related risk factors 
4-87 

1 published in Federal Guidance Report 13 (EPA, 1999). The GENII code includes a set of 

2 programs for calculating radiation dose and risk from radionuclides released to the environment. 

3 GENII implements the NRC models in LADTAP code for surface water doses. 

4 

5 The Northeast Cape Fear River would receive the liquid effluent discharges from the proposed 

6 GLE Facility. There are no public water intakes on the river downstream of the discharge point, 

7 so only the fish ingestion and recreational water use-related exposure pathways were analyzed 

8 (GLE, 2009g). 

9 

10 The radionuclide concentration in surface water was calculated at three potential exposure 

11 locations from the uranium concentrations in liquid effluent releases from the proposed GLE 

12 Facility and the dilution factor in the receiving water body (GLE, 2009g). It was assumed that a 

13 member of the public was exposed to contaminated surface water from recreational activities 

14 and ingestion of fish grown in the contaminated surface water. The recreational activities 

15 considered were swimming, boating, and use of the shoreline. The following exposure 

16 pathways were included in the dose assessment: 

17 

18 • external exposure from swimming 

19 

20 • external exposure from boating 

21 

22 • external exposure from contaminated shoreline sediment 

23 

24 • inadvertent ingestion of contaminated surface water during swimming 

25 

26 • ingestion of fish grown in contaminated surface water 

27 

28 The surface water concentrations, estimated number of people involved, specific radiological 

29 parameters, and exposure parameters for different activities used in the GENII code for 

30 radiological impact assessment are provided in Appendix C. Table 4-20 provides the estimated 

31 dose for an exposed member of the public from different surface water exposure pathways, 

32 along with the estimated population doses. Information about doses from natural background 

33 radiation is provided in Section 3.11.1. 

34 

35 The maximum dose that a member of a public would receive from liquid effluent releases from 

36 the proposed GLE Facility would occur just south of the Wilmington Site boundary. The 

37 maximum estimated dose for the MEI from liquid effluent releases would be 

7.3 × 10−7

 millisievert per year (7.3 × 10−5 38 millirem per year). Total estimated population dose 

would be 2.7 × 10−3

 person-millisievert per year (2.7 × 10−1 39 person-millirem per year). These 

40 doses are well below the 1 millisievert per year (100 millirem per year) public exposure limits in 

41 10 CFR 20.1301(a)(1). Therefore, impacts on members of the public from liquid effluent 

42 releases from the proposed GLE Facility would be SMALL. 

43 

44 Summary of Public Dose 

45 

46 Based on these estimates, normal operations at the proposed GLE Facility would have SMALL 

47 impacts on public health. Results are based on conservative assumptions (see Appendix C), 

48 and it is anticipated that actual exposure levels would be less than presented here. The total 
4-88 

Table 4-20 Estimated Doses for Liquid Effluent Releases 

from the Proposed GLE Facility 

Exposure location Exposure Pathway 

Dose (mrem/yr) 

to a Member of 

Public 

Number of 

People 

Exposed 

Collective Dose 

(personmrem/yr) 

Fish ingestion 5.26 × 10−5 1414 7.44 × 10−2

Water ingestion during 

swimming 

4.37 × 10−7 1906 8.33 × 10−4

External exposure from 

swimming 

1.03 × 10−8 1906 1.96 × 10−5

External exposure from 

boating 

5.15 × 10−9 1244 6.41 × 10−6

External exposure from 

shoreline activities 

2.01 × 10−5 1231 2.47 × 10−2

Confluence with 

Unnamed Tributary #1 

to Northeast Cape Fear 

River 

Total for a member 

of public 

7.32 × 10−5 NA NA 

Fish ingestion 5.26 × 10−5 1414 7.44 × 10−2

Water ingestion during 

swimming 

4.37 × 10−7 1906 8.33 × 10−4

External exposure from 

swimming 

1.03 × 10−8 1906 1.96 × 10−5

External exposure from 

boating 

5.15 × 10−9 1244 6.41 × 10−6

External exposure from 

shoreline activities 

2.01 × 10−5 1231 2.47 × 10−2

Just South of GE 

Wilmington Site 

Boundary 

Total for a member 

of public 

7.32 × 10−5

 NA NA 

Fish ingestion 5.06 × 10−5 1414 7.15 × 10−2

Water ingestion during 

swimming 

4.21 × 10−7 1906 8.02 × 10−4

External exposure from 

swimming 

9.95 × 10−9 1906 1.90 × 10−5

External exposure from 

boating 

4.98 × 10−9 1244 6.20 × 10−6

External exposure from 

shoreline activities 

1.93 × 10−5 1231 2.38 × 10−2

NC 133 Bridge 

Total for a member 

of public 

7.03 × 10−5

 NA NA 

 Total population dose NA NA 2.72 × 10−1

a

 To convert millirem to millisievert, divide by 100. 

b

 NA = not applicable. 
4-89 

1 annual dose from all exposure pathways would be far less than the limit of 1 millisievert per year 

2 (100 millirem per year) established in the NRC’s regulations in 10 CFR 20.1301. All exposures 

3 are also expected to be significantly below the EPA limit of 0.25 millisievert per year (25 millirem 

4 per year) in 40 CFR Part 190 for dose to members of the public from uranium fuel-cycle 

5 facilities. 

6 

7 Occupational Exposure Impacts

8 

9 Under the proposed action, the most significant contributor to occupational radiation exposure 

10 would be direct radiation from the UF6. It is expected that the average occupational doses at 

11 the proposed GLE Facility would be similar to occupational doses at existing fuel cycle facilities 

12 in the United States. As is the case for such fuel cycle facilities, the most substantial sources of 

13 direct radiation would likely include both full Type 48Y cylinders containing either feed material 

14 or depleted UF6 and empty Type 48Y cylinders with residual material (NRC, 2005b). Table 4-21 

15 presents occupational doses at fuel cycle facilities within the United States for 2003–2007 

16 (Burrows, 2005; Burrows, 2006; Lewis et al., 2008). 

17 

18 The existing nuclear and industrial safety program at the Wilmington Site would be expanded to 

19 include operation of the proposed GLE Facility (GLE, 2008). The program would monitor the 

20 occupational workers at the proposed GLE Facility for internal exposure from intake of uranium 

21 as well as dose from external exposure to radiation. GLE would also apply an annual 

22 administrative limit of 40 millisieverts (4000 millirem), which is below the 10 CFR 20.1201 limit of 

23 50 millisieverts (5000 millirem) for radiation workers. 

24 

25 GNF-A has implemented a comprehensive exposure control program at the Wilmington Site to 

26 manage occupational radiation exposure and dose. The program maintains exposures “As Low 

27 As Reasonably Achievable” (ALARA) through the use of radiation monitoring systems, 

28 personnel dosimetry, and mitigation systems to reduce environmental concentrations of 

29 uranium. The average TEDE to workers from existing GNF-A operations at the Wilmington Site 

30 for 2003–2007 varied from 0.5–0.75 millisievert (50–75 millirem) and the maximum TEDE during 

31 the same time period varied from 4.7–5.6 millisieverts (470–560 millirem) (NRC, 2009c). 

32 

33 The occupational exposure analysis and the historical exposure data from the United States 

34 Enrichment Corporation facilities and the existing GNF-A operations at the Wilmington Site 

35 demonstrate that a properly administered radiation protection program at the proposed 

36 GLE Facility would maintain radiological occupational impacts below the regulatory limits of 

37 10 CFR 20.1201. Therefore, the impacts from occupational exposure at the proposed 

38 GLE Facility are expected to be SMALL. 

39 

40 4.2.11.3 Mitigation Measures 

41 

42 Facility design features and process controls would be incorporated into the proposed 

43 GLE Facility to minimize gaseous and liquid effluent releases, and to maintain the impacts on 

44 workers and the surrounding population below regulatory limits. An ALARA program would be 

45 implemented in addition to routine radiological surveys and personnel monitoring. Best 

46 management practices associated with compliance with 29 CFR Part 1910 regarding OSHA 

47 standards would be implemented. Worker health and safety would be protected under an 
4-90 

4-90 

Table 4-21 Annual CEDEa and TEDEb for Fuel Cycle Facilities within the United States for 20

Year 

Number of 

Monitored 

Individuals 

Workers 

with 

Measured 

TEDE 

Collective 

TEDE 

(personremc) 

Average 

Measured 

TEDE 

(rem) 

Workers 

with 

Measured 

DDE 

Collective 

DDEd

(personrem) 

Average 

Measured 

DDE (rem) 

Workers 

with 

Measured 

CEDE 

Collecti

CEDE 

(person

rem) 

2003 7738 3633 556 0.15 2815 258 0.09 2255 298 2004 7562 3814 514 0.13 2933 258 0.09 2327 256 2005 7699 3371 497 0.15 2385 238 0.10 2173 259 2006 7417 3413 522 0.15 2475 283 0.11 2131 238 2007 7536 3225 429 0.13 2254 230 0.10 1983 199 

 a Committed effective dose equivalent = total radiation dose received from ingestion or inhalation of radioactive material. b Total effective dose equivalent = CEDE plus DDE (deep dose equivalent from external radiation). c 1 rem = 1000 mrem. d To convert rems to sieverts, divide by 100. 

Sources: Burrows, 2005; Burrows, 2006; Lewis, et al. 2008. 
4-91 

1 expansion of the current GNF-A Nuclear Safety Program and the Industrial Safety Program that 

2 would comply with applicable State, NRC (10 CFR Part 20), and OSHA (29 CFR Part 1910) 

3 requirements. Appropriate safety controls would be implemented according to the nature of 

4 work and hazards presented to minimize exposure to chemicals and radionuclides. 

5 

6 Mitigation Measures Identified by GLE (GLE, 2008) 

7 

8 • Install a building ventilation system and maintain the majority of the process building under 

9 sub-atmospheric pressure to prevent any air effluent release inside the building from being 

10 directly vented outside the building. 

11 

12 • Install alarms in the Emergency Control Center to detect, alarm, and/or activate the 

13 automatic safe shutdown of process equipment in case of operational problems. 

14 

15 • Install radiation monitors in effluent stacks to detect, alarm, and activate the automatic safe 

16 shutdown of process equipment, should contaminants be detected in the system exhaust. 

17 

18 • Isolate leaks and shut down process lines to prevent damage to equipment. 

19 

20 • Vent exhaust-gases from the emission control system to the atmosphere through a single 

21 rooftop stack. The emission control system would have a design control efficiency of at 

22 least 99 percent for uranium particulates and UF6 and HF vapors. 

23 

24 • Employ fluoride monitors and radiation monitors in vent stacks to detect, alarm, and activate 

25 the automatic safe shutdown of process equipment. 

26 

27 • Perform environmental monitoring and sampling to ensure compliance with regulatory 

28 discharge limits. 

29 

30 • Route treated process wastewater effluents to the existing final process lagoon facility at the 

31 Wilmington Site for additional treatment. Treated sanitary wastewater effluent would be 

32 used to replace blowdown from the cooling towers. 

33 

34 The mitigation measures proposed by GLE for worker health and safety include: 

35 

36 • Comply with all applicable State, NRC, and OSHA regulations concerning worker health and 

37 safety, as well as the existing Wilmington Site Nuclear Safety Program and the Industrial 

38 Safety Program. 

39 

40 • Comply with the Site Radiation Protection Program, the Spill Prevention Control and 

41 Countermeasure Plan, and the GLE Environmental, Health, and Safety Program. 

42 

43 • Conduct routine facility radiation and radiological surveys to characterize and minimize 

44 potential radiological exposure. 

45 

46 • Monitor all radiation workers via dosimeters and area air sampling to ensure that radiological 

47 doses remain within regulatory limits and ALARA practices. 

48 
4-92 

1 • Conduct operations activities involving hazardous respirable effluents with ventilation control 

2 and/or respiratory protection, as required. 

3 

4 • Use personal protective equipment based on the nature of the work and chemical and/or 

5 radiological hazards present. 

6 

7 Additional Mitigation Measures Identified by NRC

8 

9 • Move UF6 cylinders only when cool and when UF6 is in solid form, to minimize the risk of 

10 inadvertent release due to mishandling. 

11 

12 • Direct process off-gas from UF6 purification and other operations through cold traps to 

13 solidify and reclaim as much UF6 as possible. Pass remaining gases through high-efficiency 

14 filters and chemical absorbers to remove HF and uranic compounds. 

15 

16 • Separate uranic compounds and various other heavy metals in waste material generated by 

17 decontamination of equipment and systems. 

18 

19 4.2.12 Waste Management Impacts 

20 

21 This section evaluates the potential environmental impacts related to operation of the solid, 

22 hazardous, and radioactive waste management program at the proposed GLE Facility, including 

23 impacts resulting from temporary storage, conversion, and disposal of the depleted UF6. No 

24 mixed waste (hazardous and radioactive) is expected to be generated at the proposed facility. 

25 

26 Due to the nature, design, and operation of a laser enrichment facility, the generation of waste 

27 materials can be categorized by three distinct facility operations: (1) preconstruction and 

28 construction, which generates typical construction wastes associated with an industrial facility; 

29 (2) enrichment process operations, which generate gaseous, liquid, and solid waste streams; 

30 and (3) generation and temporary storage of depleted UF6 (Section 4.2.17.11 of this chapter 

31 discusses decommissioning wastes). Waste materials include radioactive waste (i.e., depleted 

32 UF6 and material contaminated with UF6), listed or characteristic hazardous materials 

33 (as defined in 40 CFR Part 261), and nonhazardous materials (any other wastes not identified 

34 as radioactive or hazardous). Hazardous materials include any fluids, equipment, and piping 

35 contaminated as defined in 40 CFR Part 261, such as cleaning solvents and pesticides, that 

36 would be generated due to the construction, operations, and maintenance programs. 

37 

38 The handling and disposing of waste materials is governed by various Federal and State 

39 regulations. To satisfy the Federal and State regulations, GLE has implemented waste 

40 minimization and pollution-prevention practices associated with the generation, collection, 

41 removal, and proper disposal of waste materials. GLE’s waste management program is 

42 intended to minimize the generation of waste through reduction, reuse, or recycling 

43 (GLE, 2008). This program would assist in identifying methods to minimize the volume of 

44 regulated wastes through better segregation of materials and the substitution of nonhazardous 

45 materials as required under Resource Conservation and Recovery Act (RCRA) regulations. 

46 Using available information and waste data from similar facilities, the waste-management 

47 impacts at the proposed GLE Facility are assessed for preconstruction and construction, 

48 operations, and depleted UF6 disposition activities. 
4-93 

1 4.2.12.1 Preconstruction and Construction Activities 

2 

3 Solid nonhazardous wastes generated during the preconstruction and construction phases 

4 would be typical of those for construction of industrial facilities. These wastes would be 

5 transported offsite to an approved local landfill. Approximately 3058 cubic meters (4000 cubic 

6 yards) per year of non-compacted waste is anticipated to be generated (GLE, 2009a) and would 

7 include paper, plastic, cardboard, packaging materials, wood scraps, metal building material 

8 scraps, roofing and insulation material scraps, masonry and ceramic materials, and empty paint 

9 and coatings containers. Small quantities of organic solvent-based residuals remaining from 

10 application of specialty paints, architectural coatings, sealants, and adhesives, as well as 

11 wastes from certain other materials that possibly could be used for ancillary building 

12 construction, which is one aspect of preconstruction, or construction, may be required to be 

13 managed as hazardous waste. 

14 

15 Nonhazardous wastes would be transported to the New Hanover County Landfill for disposal. 

16 This landfill receives approximately 151,000 tons (approximately 210,000 cubic yards 

17 [compacted]) annually (NCDENR, 2009a). Thus, proposed GLE Facility preconstruction and 

18 construction activities would generate approximately two percent of the waste that the New 

19 Hanover County Landfill receives annually from all other sources. The generation of hazardous 

20 wastes (i.e., waste oil, greases, excess paints, and other chemicals) associated with the 

21 preconstruction and construction activities for the proposed facility due to the maintenance of 

22 construction equipment and vehicles, painting, and cleaning, would be packaged and shipped 

23 offsite to licensed facilities in accordance with Federal and State environmental and 

24 occupational regulations. Table 4-22 shows the hazardous wastes that would be expected from 

25 construction of the proposed GLE Facility. The quantity of all preconstruction- and construction26 generated hazardous and nonhazardous waste material would result in SMALL impacts that 

27 could be managed effectively. 

28 

29 Preconstruction activities such as land clearing, site grading and erosion control, installation of 

30 the stormwater system, utility placement, and parking lot and roadway construction, would 

31 account for less than two percent of the nonhazardous waste generated during preconstruction 

32 activities, with approximately 300 cubic meters (400 cubic yards) generated, compared to 

33 3058 cubic meters per year (4000 cubic yards per year) generated during each of the following 

34 six years of building construction (GLE, 2009f). Similarly, hazardous waste generated during 

35 preconstruction activities would be expected to account for approximately two percent of the 

36 hazardous waste generated during the ensuing six years of construction. These estimates are 

37 based on GLE’s assumption that construction of ancillary buildings, although authorized by the 

38 exemption allowing GLE to perform certain preconstruction activities prior to the NRC licensing 

39 decision, would not occur until after the NRC licensing decision (GLE, 2009f). Thus, the 

40 estimated volume of waste from ancillary building construction is included here in the estimated 

41 volumes of building construction waste. 

42 

43 4.2.12.2 Facility Operations 

44 

45 Normal operation of the proposed GLE Facility would result in the generation of wastewaters 

46 that would be treated onsite before discharge and solid wastes that would be treated onsite or 

47 offsite and shipped for disposal offsite. The systems used to manage the wastes generated 

48 during operations onsite are described in Section 2.1.2.4. 
4-94 

Table 4-22 Estimated Construction Hazardous Wastes 

for the Proposed GLE Facility 

Waste Annual Quantity 

Paints, solvents, thinners, organics 3000 gal (11,360 L) 

Petroleum products, oils, lubricants 3000 gal (11,360 L) 

Sulfuric acid (battery) 100 gal (379 L) 

Adhesives, resins, sealers, caulking 2000 lbs (910 kg) 

Lead (batteries) 200 lbs (91 kg) 

Pesticides 100 gal (379 L) 

Source: GLE, 2009a.

1 

2 

3 Wastewater

4 

5 Wastewater management systems are in place at the proposed GLE Facility site to handle 

6 sanitary wastewater, facility cooling tower water, stormwater, and process wastewater. The first 

7 three systems deal with nonradioactive effluents, while the last system is in place to remove any 

8 uranium or other metals left in the water as a result of the uranium enrichment process. 

9 Stormwater management is discussed in Sections 3.7.1 and 4.2.6.2. Table 4-23 summarizes 

10 the estimated quantities generated by the different systems. 

11 

12 Sanitary Wastewater

13 

14 Sanitary wastewater at the proposed GLE Facility would be collected by a sewer system 

15 connected to the existing Wilmington Site sanitary wastewater treatment facility discussed in 

16 Section 3.12.2.1. Approximately 39,747 liters per day (10,500 gallons per day) are estimated to 

17 be generated by the proposed GLE Facility, increasing the load on the existing treatment 

18 system by about one-third (GLE, 2008). Because the Wilmington Site has secured a reuse 

19 permit for treated sanitary wastewater effluent as makeup water in cooling towers onsite, the 

20 additional 39,747 liters per day (10,500 gallons per day) discharged could be used in the 

21 proposed GLE Facility cooling tower, which is estimated to have a blowdown of about 

22 113,562 liters per day (30,000 gallons per day) (GLE, 2008). Should discharges to surface 

23 waters be necessary in the future, the existing NPDES discharge permit of 283,906 liters per 

24 day (75,000 gallons per day) as discussed in Section 3.12.2.1 would be adequate to cover the 

25 additional volume of effluent. The NPDES discharge permit is half of the capacity of the existing 

26 treatment system. Therefore, impacts from sanitary wastewater from the proposed GLE Facility 

27 would be SMALL. 

28 

29 Cooling Tower Blowdown

30 

31 The water removed from a cooling tower loop is referred to as “blowdown.” Water in a cooling 

32 tower loop does not come in direct contact with wastes or hazardous materials, but a portion of 

33 the cooling water in a tower’s loop is replaced periodically to maintain the concentration of 

34 dissolved solids and other impurities within specific water quality limits. At the proposed 
4-95 

Table 4-23 Wastewater Volume Estimates for the Proposed GLE Facility 

Wastewater Type Wastewater Source 

Estimated Average 

Daily Quantity 

Generated 

Process liquid radwaste Wastewaters from proposed GLE Facility’s main 

operations building decontamination room; 

process area floor drains, sinks, sumps, and mop 

water; laboratory area floor drains, sinks, sumps, 

and mop water; change room showers and sink; 

and aqueous process liquids that have the 

potential to contain uranium 

18,927 lpd (5000 gpd) 

Cooling tower blowdown Proposed GLE Facility’s main operations building 

HVAC cooling tower 

113,562 lpd (30,000 gpd)

Sanitary waste Sanitary waste from building areas used by 

proposed GLE Facility workers (e.g., restrooms, 

break rooms) 

39,746 lpd (10,500 gpd) 

Stormwater runoff Stormwater runoff from proposed GLE Facility 

impervious surfaces (e.g., building roofs, parking 

lots, service roads, outdoor storage pads, and 

other maintained areas) 

Variable depending on 

local precipitation 

Source: GLE, 2008. 

1 

2 GLE Facility, approximately 113,562 liters per day (30,000 gallons per day) of blowdown would 

3 be sent directly to the Wilmington Site’s final process lagoons. This volume of water represents 

4 a six percent increase handled by the process lagoons in 2006, but is only two percent of the 

5 existing NPDES permit for treated process wastewater. The impacts from cooling tower 

6 blowdown are therefore expected to be SMALL. 

7 

8 Process Wastewater

9 

10 Daily operations at the proposed GLE Facility are estimated to generate approximately 

11 18,927 liters per day (5000 gallons per day) of radioactive wastewater from decontamination, 

12 cleaning, and laboratory activities within the proposed GLE Facility’s main operations building 

13 (GLE, 2008). This process wastewater would be collected in an accumulator tank. Uranium 

14 and other metals would be precipitated out of solution in the accumulator tank through a pH 

15 adjustment. The resulting precipitate slurry at the bottom of the tank would be isolated and 

16 disposed of as solid LLRW as discussed in the following section on Nonhazardous Solid 

17 Wastes. The resulting fluoride solution at the top of the tank would be treated to remove the 

18 fluoride also resulting in a solid waste form. The treated process wastewater effluent would 

19 then be discharged to the Wilmington Site process wastewater aeration basin and Final Process 

20 Lagoon Treatment Facility (FPLTF). Because the additional 18,927 liters per day (5000 gallons 

21 per day) from operation of the proposed GLE Facility would only be about an additional one 

22 percent over the volume treated by the FPLTF in 2006 (the latest data available) and less than 

23 0.3 percent of the NPDES permit, the impacts from GLE process wastewater would be SMALL. 

24 
4-96 

1 Nonhazardous/Nonradioactive Solid Wastes

2 

3 Operations at the proposed GLE Facility would generate approximately 345 metric tons per year 

4 (380 tons per year) of municipal solid waste (MSW) and an additional 97 metric tons per year 

5 (107 tons per year) of other nonhazardous industrial solid wastes. Table 4-24 provides a 

6 summary of the types of wastes anticipated. The MSW would be collected on a regular basis 

7 and sent to the local New Hanover Municipal Landfill, which receives about 137,000 metric tons 

8 per year (151,000 tons per year) (NCDENR, 2009a). Impacts on the landfill operations would 

9 be SMALL, as the MSW waste would contribute approximately an additional 0.3 percent to its 

10 current receipt rate. The other nonhazardous industrial waste would either be packaged and 

11 shipped directly to Heritage Environmental Services in Indianapolis, Indiana, or routed through 

12 Heritage Environmental Services for reuse, reclamation, or treatment. Impacts are considered 

13 to be SMALL because 97 metric tons per year (107 tons per year) represents less than 

14 0.1 percent of the waste received at Heritage Environmental in 2007 (the latest data available) 

15 (IDEM, 2008). 

16 

17 Hazardous Wastes

18 

19 As shown in Table 4-24, approximately 11 metric tons per year (12 tons per year) of RCRA 

20 hazardous waste would be expected to be generated by the proposed GLE Facility. The waste 

21 would be packaged and shipped to Heritage Environmental Services in Indianapolis, Indiana, a 

22 RCRA-permitted Subtitle C facility, for treatment, storage, and disposal. The impact would be 

23 expected to be SMALL because disposal of 11 metric tons per year (12 tons per year) 

24 represents approximately 0.01 percent of the amount of hazardous waste, 122,091 metric tons 

25 (134,610 tons), received by Heritage Environmental Services in 2007 (the latest data available) 

26 (IDEM, 2008). 

27 

28 Low-Level Radioactive Waste

29 

30 A variety of uranium-contaminated wastes would be expected to be generated from operation of 

31 the proposed GLE Facility, as shown in Table 4-24. With the exception of the depleted UF6

32 tails, the majority of the LLRW (312 metric tons per year [344 tons per year]) would be the 

33 combustible and non-combustible portions of contaminated used items, with an additional 

34 953 kilograms per year (2100 pounds per year) of sludge from the process wastewater 

35 treatment discussed in Section 4.2.12.2, followed by waste from feed sampling and analysis 

36 (44 kilograms per year [97 pounds per year]) (GLE, 2008). This LLRW would be packaged per 

37 DOT standards and shipped to EnergySolutions’ Clive, Utah, facility for disposal. The impact 

38 would be considered SMALL because approximately 312 metric tons per year (344 tons per 

39 year) of waste is less than 0.08 percent of the 500,000 metric tons per year (453,600 tons per 

40 year) permitted maximum of the disposal facility (UDRC, 2009). 

41 

42 Depleted UF6 Management

43 

44 As discussed in Chapter 2 of this draft EIS, depleted UF6-filled Type 48Y or 48G cylinders 

45 (depleted UF6 cylinders) would be temporarily stored on an outdoor cylinder storage pad on the 

46 facility grounds. Storage of depleted UF6 cylinders at the proposed GLE Facility would occur 

47 during the facility’s 40-year operating lifetime, with eventual removal of depleted UF6 from the 

48 site through one of the disposition options considered. The U.S. Department of Energy (DOE) 

49 is required by Section 311 of Public Law 108-447, which amended Section 3113 of the 
4-97 

Table 4-24 Operations Waste Estimates for the Proposed GLE Facility 

Waste Type Waste Source 

Estimated Average 

Annual Quantity 

Generated 

Municipal solid waste 

(MSW) 

General worker operations, maintenance, and 

administrative activities not involving the 

handling of or exposure to uranium 

345 Mt/yr (380 tons/yr) 

Nonhazardous industrial 

wastes 

Nonhazardous wastes from proposed 

GLE Facility equipment cleaning and 

maintenance activities (e.g., used coolant, 

non-hazardous caustic, and filter media) that 

are recyclable or not accepted by municipal 

solid waste (MSW) landfill 

97 Mt/yr (107 tons/yr) 

RCRA hazardous waste Wastes designated as RCRA hazardous 

wastes from proposed GLE Facility 

equipment and maintenance activities (e.g., 

used cleaning solvents, used solventcontaminated rags) 

11 Mt/yr (12 tons/yr) 

Laboratory waste from UF6 feed cylinder 

sampling and analysis 

44 kg/yr (97 lbs/yr) 

Combustible, uranium-contaminated used 

items (e.g., worker personal protection 

equipment, swipes, step off pads) 

93 Mt/yr (103 tons/yr) 

Noncombustible, uranium-contaminated used 

items (e.g., spent filters from HVAC systems, 

liquid effluent treatment system, and area 

monitors) and corrective maintenance items 

(e.g., defective pigtails, valves, other safety 

equipment that need replacement) 

219 Mt/yr (241 tons/yr) 

Liquid effluent treatment system 

filtrate/sludge 

953 kg/yr (2100 lbs/yr) 

Low–level radioactive 

waste (LLRW) 

Depleted UF6 (UF6 tails) 11,250 Mt/yr 

(12,400 tons/yr) 

Source: GLE, 2008.

1 

2 U.S. Enrichment Corporation (USEC) Privatization Act, to take title to and possession of the 

3 depleted uranium if requested. Furthermore, DOE provided GLE with a cost estimate for 

4 disposition of the depleted uranium and indicated that DOE would extend the operational period 

5 of its conversion plants to accommodate the additional material (GLE, 2008). 

6 

7 The current storage pad design is large enough (465,000 square feet) to accommodate up to 

8 9000 cylinders, the expected inventory from 10 years of operation. Additional area is available 

9 nearby for expansion, if room for more cylinders is required. If further expansion of the pad is 

10 necessary in the future, GLE would be required to prepare a license amendment and prepare 

11 the requisite safety, and environmental analyses at that time. 
4-98 

1 Temporary Onsite Storage Impacts

2 

3 Proper and active cylinder management, which includes routine inspections and maintaining the 

4 anti-corrosion layer on the cylinder surface, has been shown to limit exterior corrosion or 

5 mechanical damage to the degree necessary for the safe storage of depleted UF6

6 (DNFSB, 1995a; DNFSB, 1995b; DNFSB, 1999). DOE has stored depleted UF6 in Type 48Y or 

7 similar cylinders at the Paducah and Portsmouth Gaseous Diffusion Plants and the East 

8 Tennessee Technical Park in Oak Ridge, Tennessee, since approximately 1956. Cylinder leaks 

9 due to corrosion led DOE to implement a cylinder management program. Past evaluations and 

10 monitoring by the Defense Nuclear Facility Safety Board (DNFSB) of DOE’s cylinder 

11 maintenance program confirmed that DOE met all of the commitments in its cylinder 

12 maintenance implementation plan (DOE, 1995), particularly through the use of a systems 

13 engineering process to develop a workable and technically justifiable cylinder management 

14 program (DNFSB, 1999). Thus, similar active cylinder maintenance program by GLE would 

15 assure the integrity of the depleted UF6 cylinders for the period of time of temporary onsite 

16 storage of depleted UF6 on the cylinder storage pad. 

17 

18 The principal impacts from cylinder storage would be the radiological exposure resulting from 

19 depleted UF6 temporarily stored in 9000 depleted UF6 cylinders (the design capacity of the GLE 

20 full tails cylinder storage pad) under normal conditions and the potential release (slow or rapid) 

21 of depleted UF6 from the cylinders due to an off-normal event or accidents (operational, 

22 external, or natural hazard phenomena events). These radiation exposure pathways are 

23 analyzed in Sections 4.2.11.2 and 4.2.15.2, and based on these results, the impacts from 

24 temporary storage would be SMALL. The annual impacts from temporary storage would 

25 continue until the depleted UF6 cylinders are removed from the proposed GLE Facility site. 

26 

27 Offsite Disposal Impacts

28 

29 For the disposal of the depleted UF6, GLE has proposed that the Type 48Y cylinders would be 

30 transported from the proposed GLE Facility to either of the DOE’s conversion facilities at 

31 Paducah, Kentucky, or Portsmouth, Ohio, for conversion to triuranium octaoxide (U3O8). After 

32 being converted to uranium oxide (primarily dry U3O8), the waste would be further transported to 

33 a licensed disposal facility. The transportation of the Type 48Y cylinders from the proposed 

34 GLE Facility to either of the conversion facilities would have environmental impacts that are 

35 included in the transportation analysis presented in Section 4.2.10.2. 

36 

37 If the DOE conversion facility could not immediately process the depleted UF6 upon arrival, 

38 potential impacts would include radiological impacts proportional to the time of temporary 

39 storage at the conversion facility. DOE has previously assessed the impacts of depleted UF6

40 storage during the operation of a depleted UF6 conversion facility (DOE, 2004a and 2004b). At 

41 the Paducah and Portsmouth conversion facilities, the maximum collective dose to workers 

42 (i.e., workers at the cylinder yards) would be 0.055 person-sieverts (5.5 person-rem) per year 

43 and 0.03 person-sieverts (3 person-rem) per year, respectively, considering the existing stored 

44 inventories of depleted UF6. There would be negligible exposure to noninvolved workers or the 

45 public because of their distance from the cylinder yards and air emissions from the cylinder 

46 preparation and maintenance activities would be negligible (DOE, 2004a and 2004b). 

47 

48 The dose calculations presented throughout this EIS are based on the estimated composition of 

49 depleted UF6 generated by the proposed laser-based facility. The doses from external 
4-99 

1 exposure to containers of depleted uranium from the proposed facility (either as UF6 or U3O8) 

2 are expected to be very similar to the doses calculated by DOE (DOE 2004a and 2004b) (i.e., 

3 within 1%). However, under accident conditions at a potential DOE facility that converts UF6 to 

4 U3O8, if the depleted uranium is aerosolized and inhalation becomes the dominant pathway for 

5 exposure, the doses from depleted uranium from the proposed GLE Facility could be up to twice 

6 as large as doses calculated by DOE. Based on a comparison to doses from accidents 

7 considered by DOE (DOE, 2004a and 2004b), the resulting doses would still be well below 

8 levels that could cause acute fatalities from radiation exposure and below the levels that could 

9 cause acute radiation sickness. The lifetime increase in the probability of developing a fatal 

10 latent cancer would be less than 0.05 for the maximally exposed member of public or maximally 

11 exposed non-involved worker. For involved workers, DOE indicated that impacts under 

12 accident conditions would likely be dominated by physical forces from the accident itself. This 

13 conclusion would be the same for a potential accident with depleted uranium from the proposed 

14 GLE Facility at a potential DOE facility that converts UF6 to U3O8. 

15 

16 To assess the impacts of depleted UF6 generated by the proposed GLE Facility on DOE’s 

17 conversion facilities, one must understand the relative amount of additional material as 

18 compared to DOE’s existing depleted UF6 inventory. The Paducah conversion facility would 

19 operate for approximately 25 years to process 436,400 metric tons (481,000 tons) that were in 

20 storage prior to the anticipated facility start-up in 2006 (DOE, 2004a). The Portsmouth 

21 conversion facility would operate for 18 years to process 243,000 metric tons (268,000 tons) 

22 (DOE, 2004b). The projected maximum amount of depleted UF6 generated by the proposed 

23 GLE Facility (450,000 metric tons [496,000 tons]) would represent approximately 185 percent of 

24 the Portsmouth and approximately 103 percent of the Paducah starting inventories. The 

25 proposed GLE Facility would produce approximately 11,250 metric tons (12,401 tons) of 

26 depleted UF6 per year at full production capacity (GLE, 2008), which represents approximately 

27 62 percent of the annual conversion capacity of the Paducah facility (18,000 metric tons 

28 [20,000 tons]) and approximately 83 percent of the Portsmouth facility annual conversion 

29 capacity (13,500 metric tons [15,000 tons]). The proposed GLE Facility maximum depleted UF6

30 inventory could extend the time of operation by approximately 25 years for the Paducah 

31 conversion facility or 33 years for the Portsmouth conversion facility. 

32 

33 With routine facility and equipment maintenance, and periodic equipment replacements or 

34 upgrades, DOE indicated that the conversion facilities could be operated safely beyond their 

35 proposed operational lifetimes to process the depleted UF6 such as that originating at the 

36 proposed GLE Facility. In addition, DOE indicated that the estimated impacts that would occur 

37 from prior conversion facility operations would remain the same when processing depleted UF6

38 such as the proposed GLE Facility’s wastes. The overall cumulative impacts from the operation 

39 of the conversion facility would increase proportionately with the increased life of the facility 

40 (DOE, 2004a; DOE, 2004b). 

41 

42 Additional conversion processing capacity could also be achieved through increased efficiency 

43 of the Paducah and Portsmouth conversion plants and the possibility of a commercial 

44 conversion plant being constructed. International Isotopes, Inc., submitted a license application 

45 to the NRC on December 31, 2009, to construct and operate a depleted UF6 conversion facility 

46 near Hobbs, New Mexico; the NRC staff is currently conducting environmental and safety 

47 reviews of the application (NRC, 2010a). In either case, impacts are expected to be 
4-100 

1 comparable to those estimated for construction and operation of the Paducah and Portsmouth 

2 plants (DOE, 2004a; DOE, 2004b). 

3 

4 In order to keep up with increased demand for enriched uranium as discussed in Chapter 1, 

5 other uranium enrichment facilities are in the planning process or already under construction. 

6 These facilities would also generate depleted UF6, in addition to the currently operating gaseous 

7 diffusion enrichment plant at Paducah, that would require conversion and disposal. Should all 

8 such facilities (NEF, ACP, and Eagle Rock Enrichment Facility [EREF]) become operational, 

9 extended storage times for the depleted UF6 cylinders would be necessary and could result in 

10 the need for an additional conversion facility. 

11 

12 The above assumptions and data indicate that environmental impacts from the conversion of 

13 the depleted UF6 from the proposed GLE Facility at an offsite location such as Portsmouth or 

14 Paducah would be SMALL. 

15 

16 Impacts from the transportation of the converted depleted uranium oxide from the conversion 

17 facilities to potential disposal sites at locations such as a commercial facility, EnergySolutions in 

18 Utah, or a DOE facility, the Nevada Test Site in Nevada, have been previously evaluated for the 

19 depleted uranium stored at the Portsmouth and Paducah sites (DOE, 2004a; DOE, 2004b). 

20 Transportation impacts for shipment of depleted uranium oxide from the Paducah or Portsmouth 

21 conversion facility to either potential disposal site for similar volumes with origins traced back to 

22 the proposed GLE Facility discussed above would be SMALL. 

23 

24 Depleted uranium remains source material after it ceases to possess any value for uranium 

25 enrichment purposes. Thus, if no beneficial reuse can be identified, the depleted uranium could 

26 be considered as radioactive waste for disposal. Under the current provisions of 

27 10 CFR Part 61, depleted uranium can be considered as Class A low-level radioactive waste. 

28 The NRC is currently in the process of amending its regulations to establish new requirements 

29 for the disposal of some low-level radioactive wastes, including large quantities of depleted 

30 uranium. Considering the steps that are involved in this rulemaking, the NRC plans to publish a 

31 final rule in late 2012 (NRC, 2009d). While this rulemaking may result in additional 

32 requirements in the future, along with further restrictions that could be imposed by Agreement 

33 States, the disposal of depleted uranium, for the purpose of preparing this draft EIS, is assumed 

34 to remain within the current regulatory framework until such rulemaking actions have been 

35 finalized and the revised rules promulgated. As such, it is assumed that the DOE will transport 

36 the entire depleted uranium oxide inventory to a low-level waste disposal facility, such as 

37 EnergySolutions at Clive, Utah, for disposal as Class A low-level waste. 

38 

39 4.2.12.3 Mitigation Measures 

40 

41 Impacts from waste generation and management at the proposed GLE Facility would be 

42 minimized or eliminated by implementing a number of mitigation measures as proposed by 

43 GLE, which include (GLE, 2008): 

44 

45 • Select the laser enrichment process over current gaseous diffusion and gas centrifuge 

46 technologies, which would reduce the amount of waste generated for production of the 

47 same amount of enriched product. 

48 
4-101 

1 • Minimize the quantities of waste generated by the proposed facility by implementing a 

2 Waste Minimization Plan that considers all facility processes, entails input and responsibility 

3 at the worker level on up through all levels of management, and involves recurring review 

4 cycles to measure performance and investigate new reduction measures. The plan should 

5 include potential reuse and recycling, where possible. 

6 

7 • Perform an integrated safety analysis (ISA) for each onsite waste storage area to identify 

8 and prevent accidental releases to the environment. 

9 

10 • Pre-treat radioactive liquid wastewaters in a treatment system planned for the proposed 

11 facility before the wastewater effluent is pumped to the existing NPDES-permitted final 

12 process lagoon facility for further treatment. 

13 

14 • Conduct onsite treatment of process and sanitary wastewaters to NPDES permit limits 

15 before discharge to receiving waters. 

16 

17 • Ship each waste generated by the proposed facility that requires offsite storage, treatment, 

18 or disposal to a licensed facility (as appropriate for the waste type) in compliance with EPA 

19 and NRC requirements. 

20 

21 • Avoid and minimize potential hazardous and radiological waste impacts from the UF6

22 storage pads by implementing design elements and safety procedures during operations, 

23 including: 

24 

25 – use of a storage array that permits easy visual inspection (stacked no more than two 

26 cylinders high) 

27 

28 – segregation of storage pad areas from the rest of the enrichment facility by barriers 

29 (e.g., vehicle guardrails) 

30 

31 – inspection of cylinders for external contamination (i.e., a “wipe test”) prior to placing on 

32 the storage pads or transporting them offsite 

33 

34 – ensuring that UF6 cylinders are not equipped with defective valves 

35 

36 – allowing only designated vehicles with a limited amount of fuel in the storage pad area 

37 

38 – allowing only trained and qualified personnel to operate vehicles in the storage pad area 

39 

40 – monitoring the holding pond that collects stormwater from the cylinder pads 

41 

42 • Inspect cylinders of UF6 initially prior to placing a filled cylinder on a storage pad and, 

43 thereafter, inspect periodically for damage or surface coating defects. Inspection criteria 

44 would include ensuring that: 

45 

46 – lifting points are free from distortion and cracking 

47 

48 – cylinder skirts and stiffener rings are free from distortion and cracking 
4-102 

1 

2 – cylinder surfaces are free from bulges, dents, gouges, cracks, or significant corrosion 

3 

4 – cylinder valves are fitted with the correct protector and cap 

5 

6 – cylinder valves are straight and not distorted, two to six threads are visible, and the 

7 square head of the valve stem is undamaged 

8 

9 – cylinder plugs are undamaged and not leaking 

10 

11 • If inspections of a cylinder reveal significant deterioration or other conditions that may affect 

12 its safe use, transfer the contents of the cylinder to another cylinder and discard the 

13 defective cylinder. Investigate the cause of any significant deterioration, and if necessary, 

14 perform additional inspection of cylinders. 

15 

16 • Minimize onsite storage volumes and times and shipping waste destined for offsite 

17 treatment and disposal facilities as soon as practicable. 

18 

19 • Monitor and inspect onsite liquid waste storage tanks and containers on a periodic schedule 

20 to detect leaks or releases to the environment due to equipment malfunctions so that actions 

21 identified in the SPCC plan or other appropriate corrective action can be taken promptly. 

22 

23 • Conduct continuous or periodic monitoring of waste management processes and storage 

24 facilities for the detection of non-intentional releases to the environment, so that corrective 

25 actions would be taken to minimize adverse impacts on the environment. For example, 

26 directing stormwater runoff from the UF6 storage pads to a holding pond, where it would be 

27 monitored to ensure that unexpected radioactive material releases to the wet detention 

28 basin did not occur. 

29 

30 • Use the existing Wilmington Site onsite wastewater treatment facilities within current 

31 regulatory permit limits to avoid the need to add new onsite waste treatment and disposal 

32 facilities for the proposed facility. 

33 

34 4.2.13 Socioeconomic Impacts 

35 

36 This section provides an analysis of the socioeconomic impacts of preconstruction activities and 

37 the proposed action, including construction activities, start-up, facility operations, and 

decommissioning phases.18 38 Wage and salary spending and expenditures associated with 

 

18 As discussed in Section 4.1, the socioeconomic impacts analysis was based on the assumption that a 

licensing decision would be made in late 2011, construction (if authorized) would start shortly after the 

licensing decision was made, and license termination would occur in 2051. The analysis was also 

based on the assumption that initial operations would begin in 2013, final construction activities would 

continue from 2013 to 2017, and that full operations would be achieved in 2017. Subsequently, the 

Commission’s Notice of Hearing and Commission Order (75 FR 1819) specified that a licensing 

decision be made within 30 months of the Order (i.e., June 2012). Thus, the NRC staff currently 

expects that a licensing decision will be made in 2012, construction will begin in 2012, and that 

termination of the 40-year license, if granted, will occur in 2052. The NRC staff expects that the dates 

for start-up and final construction (2013–2017) and full facility operations (2017) will remain 
4-103 

1 materials, equipment, and supplies during each phase would produce income and employment 

2 and local and State tax revenue, while the migration of workers and their families into local 

3 communities would affect housing availability and local public services such as healthcare, 

4 schools, and law enforcement. The impacts are evaluated for the region surrounding the 

5 proposed GLE Facility. This region is based on the area in which workers are expected to live 

6 and spend most of their salaries, and in which a significant portion of site purchase and 

7 nonpayroll expenditures from the construction, manufacturing, operations, and 

8 decommissioning phases of the proposed GLE Facility are expected to occur (GLE, 2008). This 

9 region, referred to in this draft EIS as the region of influence (ROI), corresponds to the 

10 Wilmington Metropolitan Statistical Area (MSA), a three-county area comprising Brunswick, 

11 New Hanover, and Pender Counties. These three counties cover an area that extends up to 

12 approximately 80 kilometers (50 miles) from the Wilmington Site. 

13 

14 This analysis of socioeconomic impacts includes impacts on employment, income, State tax 

15 revenues, population, housing community, and social services. 

16 

17 Employment impacts are evaluated by estimating the level of direct and indirect employment 

18 associated with the proposed GLE Facility; direct employment is created at the Wilmington Site 

19 during preconstruction activities, construction activities, start-up, facility operations, and 

20 decommissioning phases, while indirect employment is created in the ROI, to support the needs 

21 of the workers directly employed by the proposed GLE Facility and jobs created to support site 

22 purchase and non-payroll expenditures. The number of direct jobs created in each stage is 

23 estimated based on anticipated labor inputs for various engineering and construction activities. 

24 Impacts of preconstruction are separated from GLE construction impacts using payroll 

25 expenditure data provided by GLE (GLE, 2009g). Indirect employment is estimated using 

26 economic multipliers from the IMPLAN input-output model (MIG, 2009), which account for inter27 industry relationships within regions. 

28 

29 State income tax revenue impacts are estimated by applying State income tax rates to 

30 GLE project-related construction and operations earnings. State and local sales tax revenues 

31 are estimated by applying appropriate State and local sales tax rates to after-tax income 

32 generated by construction and operations employees, spent within the ROI. Impacts of the 

33 proposed GLE Facility on State corporate income taxes were estimated by applying current 

34 State tax rates to projected annual facility operating revenues. 

35 

36 Impacts on population characteristics are evaluated by estimating the fraction of direct and 

37 indirect jobs that will be filled by in-migrating workers from outside the ROI. The average family 

38 size and age profiles of migrating families are estimated using appropriate demographic 

39 assumptions based on U.S. Census Bureau statistics. Impacts on area housing resources are 

40 estimated by comparing rental and owner-occupied vacancy statistics with estimated population 

41 in-migration into the ROI during the construction and operations phases of the project. 

42 

43 In addition to State income and sales taxes, tax incentives were provided to GE by the State of 

44 North Carolina and by New Hanover County. It is anticipated that these would amount to up to 

 

unchanged. These schedule changes, which will be reflected in the final EIS, are expected to cause 

slight changes to the socioeconomic impacts analysis because of seasonal effects, but are not 

expected to change any of the impact conclusions. 
4-104 

1 $26.6 million from the State, most of which would be payable over a 12-year period, and up to 

2 $10 million from the county, payable over a 10-year period. Both incentives are contingent on 

3 GE reaching specified investment and employment levels at the plant (GLE, 2009f). 

4 

5 Impacts on community and social services are assessed by estimating the number of additional 

6 local community service employees that would be required to maintain existing levels of service 

7 or education, law enforcement, and fire services, given the number of in-migrating workers 

8 expected into the ROI during the various phases of the project. Although the ROI corresponds 

9 to the Wilmington Metropolitan Statistical Area (MSA), which is expected to be the primary 

10 source of labor for the proposed GLE facility, some labor in-migration is expected during each 

11 phase of the proposed project. The number of in-migrating workers was based on interviews 

12 with local economic development officials, with estimates used in the analysis assumed to be a 

13 range. Sixty-five percent of in-migrating workers were assumed to be accompanied by their 

14 families, which would consist of an additional adult and one school-age child (GLE 2009a). 

15 

16 There are large differences between the indirect (offsite) impact of the proposed GLE facility 

17 during the construction phase and during other phases of the project. These differences are 

18 due to the relative magnitude of expenditures during the construction phase compared to the 

19 other phases of the project, and the important role in the economy of the ROI of suppliers of 

20 capital equipment and other materials and services provided to the project during the 

21 construction phase. 

22 

23 4.2.13.1 Preconstruction and Construction Activities 

24 

Preconstruction and construction activities in the peak year (2012)19 25 would create 680 direct 

26 jobs at the facility site itself. An additional 3131 indirect jobs would be created in the ROI with 

27 the procurement of material and equipment and the spending of direct worker wages and 

28 salaries (Table 4-25). Facility construction would produce $139.8 million in income in the ROI in 

2012.20 29 Construction would produce $1.7 million in direct State income taxes and $1.2 million in 

30 direct State sales taxes. Peak year construction activities would constitute approximately 

31 2.5 percent of total ROI employment in 2012; the economic impact of constructing the proposed 

32 GLE Facility would, therefore, be SMALL. 

33 

34 Although a large proportion of construction workers are expected to come from within the three35 county region, given the scale of construction activities and the likelihood of local worker 

36 availability in the required occupational categories, construction of the proposed GLE Facility 

37 would require some in-migration of workers and their families from outside the ROI, with 

38 between 299 and 598 persons in-migrating into the ROI during the peak year of construction. 

39 Although in-migration may potentially impact local housing markets, the relatively small number 

40 of in-migrants and the availability of temporary accommodation (hotels, motels, and mobile 

41 home parks) would mean that the impact of facility construction on the number of vacant rental 

42 housing units is not expected to be large, with between 87 and 173 rental units expected to be 

43 occupied in the ROI during construction. These occupancy rates would represent less than 

 

19 The socioeconomic impacts analysis is based on the assumption that the peak construction year will 

be 2012, if a license is granted. The NRC staff expects this assumption remains accurate despite the 

six-month schedule adjustment discussed in Section 4.1. 

20 All direct income and direct sales tax impact estimates are provided in 2008 dollars.
4-105 

Table 4-25 Effects of the Proposed GLE Facility on ROI Socioeconomicsa

Parameter Preconstruction 

and Construction Start-up Operations Decommissioning 

Employment (number of 

jobs) 

 

 Direct 680 200 350 50 

 Indirect 3131 218 382 33 

 Total 3811 418 732 83 

Income ($m 2007) 

 Direct 26.0 19.2 33.3 5.1 

 Indirect 113.8 8.7 15.1 1.0 

 Total 139.8 28.0 51.5 6.1 

Direct tax revenues 

 Income taxes ($m 2007) 1.7 1.3 2.3 0.3 

 Sales taxes ($m 2007) 1.2 0.9 1.7 0.2 

Population (number of new 

residents) 

299–598 92–120 161–210 115–120 

Housing (number of units 

required) 

87–173 27–47 47–61 33–35 

Community service 

employment (number of 

individuals) 

 

 Police officers 1 <1 <1 <1 

 Firefighters 1 <1 <1 <1 

Education (number of 

individuals) 

 

 School-age children 84–169 26–40 46–70 38–40 

 Teachers 1 <1 <1 <1 

a

 Impacts are shown for the peak year of construction (2012), the first year of start-up activities (2013), the 

first complete year of full operations (2018), and the first year of decommissioning (2051). Although full 

operations are expected to begin in 2017, the first complete year of full operations is expected to be 2018. 

Source: Modified from GLE, 2008. 
4-106 

1 one percent of the vacant rental units expected to be available in the ROI in 2012; the impact 

2 from construction of the proposed GLE Facility on housing would, therefore, be SMALL. 

3 

4 In addition to the potential impact on housing markets, in-migration would also affect local5 community educational and medical services employment to maintain existing levels of service. 

6 With between 299 and 598 in-migrants expected in the ROI during preconstruction and 

7 construction activities, and existing levels of service (see Section 3.13), approximately one 

8 additional police officer and approximately one additional firefighter would be required in the 

9 peak construction year, 2012. Assuming that a certain number of workers are accompanied by 

10 their families during construction, between 84 and 169 school-age children would be expected 

11 in the ROI in 2012, meaning approximately one additional teacher would be required to maintain 

12 existing student-teacher ratios in the local school system. These staffing increases would 

13 represent less than one percent of community service employment in each employment 

14 category expected in the ROI in 2012; the impact of construction of the proposed GLE Facility 

15 on community educational and medical service employment would, therefore, be SMALL. 

16 

17 Based on payroll expenditure data for the two phases of the project, preconstruction activities 

18 (2011) would contribute five percent of the impacts during preconstruction and construction 

19 activities, and construction activities (2012−2017) would contribute 95 percent (GLE 2009g). 

20 

21 4.2.13.2 Facility Operations 

22 

23 Start-up

24 

25 Start-up activities in 2013 would create 200 direct jobs at the proposed GLE Facility site. An 

26 additional 218 indirect jobs would be created in the ROI with the procurement of material and 

27 equipment and the spending of direct worker wages and salaries (Table 4-25). Facility start-up 

28 would produce $28.0 million in income in the ROI in 2013, and would produce $1.3 million in 

29 direct State income taxes paid by GLE employees and $0.92 million in direct State sales taxes. 

30 Start-up activities would constitute less than one percent of total ROI employment in 2013; the 

31 economic impact of start-up the proposed GLE Facility would, therefore, be SMALL. 

32 

33 Given the scale of start-up activities and the likelihood of local worker availability in the required 

34 occupational categories, start-up of the proposed GLE Facility would mean that some in35 migration of workers and their families from outside the ROI would be required, with between 92 

36 and 120 persons in-migrating into the ROI during the peak year of start-up. Although in37 migration may potentially impact local housing markets, the relatively small number of in38 migrants and the availability of temporary accommodation (hotels, motels, and mobile home 

39 parks) would mean that the impact of facility start-up on the number of vacant rental housing 

40 units is not expected to be large, with between 27 and 47 rental units expected to be occupied 

41 in the ROI during start-up. These occupancy rates would represent less than 0.1 percent of the 

42 vacant rental units expected to be available in the ROI in 2013; the impact of the proposed 

43 GLE Facility’s start-up on housing would, therefore, be SMALL. 

44 

45 In addition to the potential impact on housing markets, in-migration would also affect local46 community educational and medical services employment to maintain existing levels of service. 

47 With between 92 and 120 in-migrants expected in the ROI during start-up activities and existing 

48 levels of service (see Section 3.13), less than one police officer and less than one firefighter 
4-107 

1 would be required in the peak start-up year, 2013. Assuming that a certain number of workers 

2 are accompanied by their families during start-up, between 26 and 40 school-age children would 

3 be expected in the ROI in 2013, meaning one additional teacher would be required to maintain 

4 existing student-teacher ratios in the local school system. These staffing increases would 

5 represent less than 0.1 percent of community service employment in each employment category 

6 expected in the ROI in 2013; the impact of the proposed GLE Facility’s start-up on community 

7 educational and medical service employment would, therefore, be SMALL. 

8 

9 Operations

10 

11 Operations activities in 2017 would create 350 direct jobs at the facility site itself. An additional 

12 382 indirect jobs would be created in the ROI with the procurement of material and equipment 

13 and the spending of direct worker wages and salaries (Table 4-25). Facility operations would 

14 produce $51.5 million in income in the ROI in 2017. Operations would produce $2.3 million in 

15 direct State income taxes paid by GLE employees and $1.7 million in direct State sales taxes. 

16 Corporate income taxes would also be collected by the State during the facility operating period, 

17 and would total $49.2 million annually. Operations activities would constitute less than 

18 one percent of total ROI employment in 2017; the economic impact of operating the proposed 

19 GLE Facility would, therefore, be SMALL. 

20 

21 Given the scale of operations activities and the likelihood of local worker availability in the 

22 required occupational categories, operation of the proposed GLE Facility would mean that some 

23 in-migration of workers and their families from outside the ROI would be required, with between 

24 161 and 210 persons in-migrating into the ROI during the first year of operation. Although in25 migration may potentially impact local housing markets, the relatively small number of in26 migrants and the availability of temporary accommodation (hotels, motels, and mobile home 

27 parks) would mean that the impact of facility operations on the number of vacant owner28 occupied housing units is not expected to be large, with between 47 and 61 rental units 

29 expected to be occupied in the ROI during operations. These occupancy rates would represent 

30 less than 0.1 percent of the vacant owner-occupied units expected to be available in the ROI in 

31 2017; the impact of the proposed GLE Facility’s operations on housing would, therefore, be 

32 SMALL. 

33 

34 In addition to the potential impact on housing markets, in-migration would also affect local35 community educational and medical services employment to maintain existing levels of service. 

36 With between 161 and 210 in-migrants expected in the ROI during operations and existing 

37 levels of service (see Section 3.13), less than one police officer and less than one firefighter 

38 would be required in the peak operations year, 2017. Assuming that a certain number of 

39 workers are accompanied by their families during operations, between 46 and 70 school age 

40 children would be expected in the ROI in 2017, meaning less than one additional teacher would 

41 be required to maintain existing student-teacher ratios in the local school system. These 

42 staffing increases would represent less than 0.1 percent of community service employment in 

43 each employment category expected in the ROI in 2017; the impact of the proposed 

44 GLE Facility’s construction on community educational and medical service employment would, 

45 therefore, be SMALL. 

46 

47 

48 
4-108 

1 4.2.13.3 Mitigation Measures 

2 

3 Because the socioeconomic impacts of the proposed GLE Facility, notably the impact of 

4 in-migrating workers on local housing markets and on local community service employment, are 

5 expected to be SMALL, it is unlikely that any specific mitigation measure would be necessary. 

6 

7 4.2.14 Environmental Justice Impacts 

8 

9 As described in Sections 4.2.1 through 4.2.13, the impacts of preconstruction activities and the 

10 proposed action, including construction activities and facility operations, are expected to be 

11 SMALL for most of the resource areas evaluated. The NRC staff has concluded that potential 

12 impacts could be SMALL to MODERATE in a number of resource areas during preconstruction 

13 activities, construction, and operations, and could potentially affect environmental justice 

14 populations. However, in each of these resources areas, the impacts would not appear to be 

15 disproportionately high and adverse for minority or low-income populations. A brief description 

16 of potential impacts on the general population follows: 

17 

18 • As described in Section 4.2.4, preconstruction and construction traffic, and operation of 

19 construction equipment are projected to cause a temporary increase in the concentrations of 

20 particulate matter having a mean diameter of 10 micrometers or less (PM10) in the ambient 

21 air that slightly exceed the air quality standard, primarily to the north of the proposed site. 

22 These impacts are anticipated to be SMALL to MODERATE. 

23 

24 • As described in Section 4.2.13, the impacts on regional employment of preconstruction and 

25 construction activities would be considered SMALL. Similarly, the impacts of facility 

26 operations on regional employment would be considered SMALL. These impacts are 

27 generally considered positive. 

28 

29 • As described in Section 4.2.9, MODERATE impacts of increased noise would be associated 

30 with the operation of preconstruction and construction machinery, and SMALL impacts 

31 would be expected to result from operation of the proposed GLE Facility. 

32 

33 • As described in Section 4.2.10, increased truck and car traffic associated with 

34 preconstruction and construction activities, and with transportation of materials and product 

35 as well as employees, to and from the proposed GLE Facility, could produce SMALL to 

36 MODERATE increases in traffic congestion in the local road network. 

37 

38 • As described in Section 4.2.6, indirect surface water quality impacts caused by stormwater 

39 runoff from the GLE Facility site would occur, together with treated wastewater effluent 

40 discharges to the effluent channel. These impacts are anticipated to be SMALL. 

41 

42 • As described in Section 4.2.11, there may be trace radiological releases during facility 

43 operations. These impacts are anticipated to be SMALL. 

44 

45 • As described in Section 4.2.10, the probability of a severe transportation accident that 

46 releases sufficient quantities of UF6 that could pose a health risk is low. The consequences 

47 of such an accident, should it occur, would be high. Based on this analysis, the public 
4-109 

1 health impacts associated with such an accident as part of the proposed action are 

2 anticipated to be SMALL. 

3 

4 • As described in Section 4.2.15, accidents associated with proposed GLE operations could 

5 result in SMALL impacts on the surrounding public. 

6 

7 The majority of the environmental impacts associated with construction and operation of the 

8 proposed GLE Facility would be SMALL to MODERATE, and generally would be mitigated. The 

9 neighborhood immediately surrounding the proposed GLE Facility includes a mix of minority and 

10 nonminority residents, as well as a mix of low-income and more affluent residents. Specifically, 

11 the Census block group in which the proposed GLE Facility would be located has minority 

12 residents comprising 18.3 percent of its population, while low-income residents account for 

13 seven percent of its population. Because impacts on the general population would be generally 

14 SMALL to MODERATE, and because the greatest impact would be expected to occur in the 

15 immediate vicinity of the proposed GLE Facility in an area with a mix of races, ethnicities, and 

16 income levels, the various phases of facility development would not be expected to result in 

17 disproportionately high or adverse impacts on low-income or minority residents. 

18 

19 Even where environmental impacts would be generally SMALL, the behaviors of some 

20 population groups, such as higher participation in outdoor recreation, home gardening, or 

21 subsistence fishing, could lead to disproportionate exposure through inhalation or ingestion. 

22 One Census block group, which has a high percentage of low-income and minority residents, is 

23 located downstream of the proposed GLE Facility on the Northeast Cape Fear River. If 

24 radiation was released, residents there could face increased risk of exposure due to their fish25 consumption patterns; however, the releases of total uranium and UF6 are projected to be 

26 extremely low (see Section 4.2.11.2), and indirect exposure through fish consumption would be 

27 even lower. 

28 

29 Soil and vegetation samples from the existing site and from 1.6 kilometers (1 mile) away show 

30 no impact from current operations. As discussed in Section 4.2.11.2, the radiological doses to 

31 the nearest residents resulting from operation of the proposed GLE Facility and current 

32 operations are projected to be well below the EPA 10 millirem (0.1 millisieverts) per year 

33 standard (20 CFR Part 190) and the NRC total effective dose equivalent (TEDE) limit of 1 

34 millisievert (100 millirem) per year (10 CFR Part 20). 

35 

36 Overall, therefore, the proposed GLE Facility would not be expected to result in 

37 disproportionately high or adverse impacts on minority or low-income populations. 

38 

39 4.2.15 Accident Impacts 

40 

41 The operation of the proposed GLE Facility would involve risks to workers, the public, and the 

42 environment from potential accidents. The regulations in 10 CFR Part 70, Subpart H, 

43 “Additional Requirements for Certain Licensees Authorized to Possess a Critical Mass of 

44 Special Nuclear Material,” require that each applicant or licensee evaluate, in an Integrated 

45 Safety Analysis (ISA), its compliance with certain performance requirements. The Safety 

46 Evaluation Report (SER) for the proposed facility will include a more detailed analysis of the 

47 potential accidents identified in the GLE license application (GLE, 2009c). The accidents 
4-110 

1 evaluated in this document are a representative selection of the types of accidents that are 

2 possible at the proposed GLE Facility. 

3 

4 The analytical methods used in this consequence assessment are based on NRC guidance for 

5 analysis of nuclear fuel-cycle facility accidents (NRC, 1990, 1991, 1998, 2001). With the 

6 exception of the criticality accident, the hazards evaluated involve the release of UF6 vapor from 

7 process systems that are designed to confine UF6 during normal operations. As described 

8 below, UF6 vapor poses a chemical and radiological risk to workers, the public, and the 

9 environment. GLE has committed to various preventive and mitigative measures to significantly 

10 reduce these risks. 

11 

12 4.2.15.1 Accidents Considered 

13 

14 The GLE License Application (GLE, 2009c) describes potential accidents that could occur at the 

15 proposed GLE Facility. GLE provided accident descriptions according to facility node or 

16 operational unit, and further subdivided them by consequence, according to the severity of the 

17 accident. 

18 

19 The NRC staff selected, for detailed evaluation, a subset of the potential accident scenarios that 

20 is intended to encompass the range of possible accidents. The accident sequences the staff 

21 selected were all high-consequence, except for one. The representative accident scenarios 

22 selected vary in severity from high- to intermediate-consequence events and include accidents 

23 initiated by natural phenomena, operator error, and equipment failure. The accident scenarios 

24 evaluated are as follows: 

25 

26 • liquid fuel fire outside (Node 4100 cylinder storage and handling) 

27 

28 • system breach inside a low-temperature take-off system (Node 4200 feed and vaporization) 

29 

30 • small UF6 release due to operator error (Node 4400 tails withdrawal) 

31 

32 • system breach inside a low-temperature take-off station (Node 4800 sampling) 

33 

34 • criticality due to uranium accumulated in decontamination and maintenance equipment 

35 (Node 5200 decontamination/maintenance) 

36 

37 The accident analysis does not include an estimate of the probability of occurrence of accidents, 

38 which, in combination with consequences, would reflect the overall risks of accident types; 

39 rather, analyzed accidents are assumed to occur. 

40 

41 4.2.15.2 Accident Consequences 

42 

43 Accidents involving release of UF6 liquids or vapors were analyzed, in general, by identifying the 

44 quantity of a containerized material at risk inside the facility, the amount of material released 

45 into a room as vapor or particulates under the accident scenario, the fraction of released 

46 material that is of respirable size, and the fraction of material exhausted to the atmosphere 

47 through an available pathway, typically a building ventilation system. The dispersion of released 

48 material in the atmosphere and transport to onsite and offsite locations was then analyzed using 
4-111 

1 the GENII code (Napier, 2004) with conservative inputs for release and atmospheric transport 

2 factors. The model estimated direct exposures to members of the public from an airborne 

3 plume, as well as exposures over a year’s time from deposited uranium materials, to determine 

4 accident consequences to the public. Impacts on the public from a criticality accident were 

5 analyzed similarly, but for radioactive gases that would be released from a criticality event in a 

6 vessel inside the facility, including fission products and radioiodine. 

7 

8 The NRC performance requirements in Part 70, Subpart H, define acceptable levels of risk of 

9 accidents at nuclear fuel cycle facilities, such as the proposed facility. The regulations in 

10 Subpart H require that the applicant reduce the risks of credible high-consequence and 

11 intermediate-consequence events, and assure that under normal and credible abnormal 

12 conditions, all nuclear processes are subcritical. Threshold consequence values that define the 

13 high- and intermediate-consequence events, except for criticality events, are indicated in 

14 Table 4-26. The values in Table 4-26 are based on the requirements of 10 CFR 70.61 and the 

15 EPA’s Acute Exposure Guideline Levels for chemical exposure to HF (EPA 2009f, EPA 2009g). 

16 

17 Receptors located at the Restricted Area Boundary within the site and at the Controlled Area 

18 Boundary represent worst-case exposures to non-radiological workers at the facility and 

19 members of the public, respectively. The NRC staff also evaluated accident consequences for 

20 releases of UF6 for the general public offsite of the facility. 

21 

22 Table 4-27 summarizes the consequences from the hypothetical accidents. Consequences 

23 were evaluated against the above criteria. For the Criticality Accident at Node 5200, previous 

24 experience with this type of criticality accident indicates that a worker in close proximity (less 

25 than 4.5 meters [15 feet]) is unlikely to survive. With the increasing distance from the accident, 

26 

Table 4-26 Definition of High- and Intermediate-Consequence Events 

Receptor Intermediate Consequence High Consequence 

Worker – Radiological >25 rem (0.25 Sv) >100 rem (1 Sv) 

Worker – Chemical 

(10-minute exposure) 

>19 mg U/m3

>78 mg HF/m3

 (95 ppm) 

(>AEGL-2 valuesa

) 

>147 mg U/m3

>139 mg HF/m3

 (170 ppm) 

(>AEGL-3 values) 

Individual at the 

Controlled Area 

Boundary - Radiological 

> 5 rem (0.05 Sv) > 25 rem (0.25 Sv) 

30 mg soluble uranium intake 

Individual at the 

Controlled Area 

Boundary - Chemical 

(30 minute) 

>2.4 mg U/m3

>0.8 mg HF/m3

 (0.98 ppm) 

(>AEGL-1 values) 

>13 mg U/m3

>28 mg HF/m3

 (34 ppm) 

(>AEGL-2 values) 

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 uCi/mL) 

N/A 

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. 

Sources: EPA, 2009f; EPA, 2009g.
4-112 

1 the radiation dose would be lower. Therefore, the NRC staff has qualitatively evaluated the 

2 accident as a high-consequence event for the worker. However, GLE has committed to various 

3 preventive and mitigative measures to significantly reduce these risks (GLE, 2008). A 

4 maximally exposed individual at the Controlled Area Boundary (CAB) would receive a radiation 

5 dose of 1.1 millisievert (0.11 roentgen equivalent man [rem]) total effective dose equivalent, 

6 which represents a Low consequence to an individual (<0.05 sievert [<5 rem]). The collective 

7 dose to the offsite population in the east–southeast direction, as determined using GENII 

8 (Napier, 2004), is estimated to be 0.6 person-sievert (60 person-rem). This population dose 

9 would cause an estimated 0.0007 lifetime cancer fatalities, or less than one fatality. Moreover, 

10 GLE would be required to maintain all processes non-critical thereby reducing the risk to the 

11 public from this type of accident. Thus, the risk of health effects to the offsite public from this 

12 accident would be SMALL 

13 

14 The consequences of the four accident scenarios involving a release of UF6 vary widely, as 

15 shown in Table 4-27. Worker radiological consequences are Low (<25 rem [<0.25 sievert]) for 

16 

Table 4-27 Summary of Health Effects Resulting from Accidents

 Workera Environment 

at CAB 

Individual at CAB Collective Dose 

Accident 

(Node) 

[U], mg/m3

(rem)b

[HF], 

mg/m3 

(ppm) 

uCi/mL [U], mg/m3

(rem) 

[HF], 

mg/m3 

(ppm) 

Direction Personrem LCFs 

Inadvertent 

Nuclear Criticality 

(5200) 

(Highc) NA 6.96d (0.110)e NA ESE 60 7 × 10-4

Liquid Fuel Fire 

Outside (Cylinder)f

(4100) 

327 

(76.6) 

274 

(335) 

4.23 × 10-12 25 

(0.1) 

450 

(550) 

ESE 1298 1.5 × 10-2

System Breach 

(Feed and 

Vaporization) 

(4200) 

450 

(1.2) 

1595 

(1950) 

1.28 × 10-10 52 

(0.39) 

41.1 

(50.2) 

ESE 264 3 × 10-3

Small UF6 Release 

(operator error) 

(4400) 

11 

(9 × 10-3) 

1.35 

(1.65) 

2.57 × 10-14 6 

(5 × 10-3) 

0.74 

(0.90) 

ESE 52 6 × 10-4

System Breach 

(sampling) 

(4800) 

33 

(0.09) 

327 

(400) 

2.85 × 10-12 55 

(0.15) 

531 

(649) 

ESE 1648 2 × 10-2

a

 Worker exits after 5 minutes in all cases. 

b To convert rem to sievert, multiply by 0.01. 

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 cylinder would be HIGH, sloped cylinder storage areas and combustible 

controls would make this event highly unlikely to occur. 

CAB – Controlled Area Boundary; HF – hydrogen fluoride; LCF – latent cancer fatalities; mg/m3 – milligrams per cubic meter; ppm – 

parts per million. 
4-113 

1 three of the four analyzed scenarios involving a UF6 release and Intermediate (>25 rem 

2 [0.25 sievert] and <100 rem [1 sievert]) for the accident involving a liquid fuel fire outside 

3 (Node 4100). Worker health consequences from HF exposure are Low for the accident 

4 scenario at Node 4400, and are High for scenarios at Node 4100, Node 4200, and Node 4800. 

5 Worker consequences for uranium chemical exposure would be Low for the accident scenario 

6 at Node 4400, Intermediate for the scenario at Node 4800, and High for scenarios at Node 4100 

7 and Node 4200. 

8 

9 Radiological consequences (30-minute exposure) to the maximally exposed individual at 

10 the CAB would be Low for all four UF6 release scenarios and the criticality accident 

11 (<0.05 sievert [<5 rem]). 

12 

13 Uranium exposure consequences (30-minute exposure) would be Intermediate (>2.4 and 

<13 milligrams uranium per cubic meter [>1.5 × 10–7 and <8.1 × 10–7 14 pounds uranium per cubic 

15 foot]) for the accident scenario at Node 4400 and High (>13 milligrams uranium per cubic meter 

[>8.1 × 10–7 16 pounds uranium per cubic foot]) for the scenarios at Node 4100, Node 4200 and 

17 Node 4800. HF exposure consequences (30-minute exposure) would be Low (<0.8 milligrams 

18 HF per cubic meter [0.98 parts per million]) for the accident scenario at Node 4400 and High 

19 (>28 milligrams HF per cubic meter [34 parts per million]) for scenarios at Node 4100, 

20 Node 4200, and Node 4800. 

21 

22 Total consequences to the public in terms of radiation dose to the population in the ESE 

23 direction and resultant total lifetime cancer fatalities are given under Collective Dose in 

24 Table 4-27 Accident scenarios at all nodes predict less than one lifetime cancer fatality in this 

25 population. 

26 

27 Of the accident scenarios analyzed by the NRC staff, the most significant accident 

28 consequences to a worker would be those from scenarios involving a nuclear criticality 

29 (Node 5200), a system breach at a low-temperature takeoff station (Node 4200), and a liquid 

30 fuel fire outside resulting in a cylinder rupture and UF6 release (Node 4100). The accident 

31 scenarios with the highest potential consequences to the public would be a system breach at a 

32 low-temperature takeoff station during sampling (Node 4800), a liquid fuel fire outside resulting 

33 in a cylinder rupture and UF6 release (Node 4100), and a system breach at a low-temperature 

34 takeoff system (Node 4200). The potential consequences to the public from all three of these 

35 accidents would be potentially high due primarily to exposure to HF. 

36 

37 The NRC staff selected and evaluated a representative subset of the potential accidents that 

38 could occur at the proposed facility. The accident consequences vary in magnitude, and 

39 demonstrate that HF release is the predominant concern. The design of the proposed facility 

40 minimizes the likelihood of accidents occurring, while the facility Emergency Plan addresses all 

41 identified potential Low- to High-consequence events. The NRC staff concludes that, through 

42 the combination of plant design, passive and active engineered controls (items relied on for 

43 safety, or IROFs), and administrative controls, accidents at the proposed facility pose an 

44 acceptably low risk to workers, the environment, and the public. Thus, impacts from accidents 

45 are expected to be SMALL. 

46 
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1 4.2.15.3 Mitigation Measures 

2 

3 NRC regulations (10 CFR Part 70, Subpart H) and GLE’s operating procedures (GLE, 2008) for 

4 the proposed GLE Facility are designed to ensure that the high and intermediate accident 

5 scenarios would be highly unlikely. The NRC staff’s SER assesses the safety features and 

6 operating procedures required to reduce the risks from accidents. The combination of 

7 responses by IROFs that mitigate or prevent emergency conditions, and the implementation of 

8 emergency procedures and protective actions in accordance with the proposed GLE Emergency 

9 Plan, would limit the consequences and reduce the likelihood of accidents that could otherwise 

10 extend beyond the proposed GLE boundaries. 

11 

12 Specifically, preventive and mitigative measures within the proposed facility relevant to a 

13 fire/explosion scenario would include (GLE, 2008): 

14 

15 • fire alarm and detection systems, possibly including a fire suppression system 

16 

17 • fire barriers preventing propagation of fires into and out of areas holding quantities of 

18 uranium materials 

19 

20 • system features that isolate combustible (process) materials and/or shut down processes to 

21 prevent or mitigate a fire 

22 

23 • continuous detection of a flammable gas in the laser system, with automatic isolation of 

24 process piping exceeding set limits 

25 

26 • structures designed to ensure that peak explosive blast loads would minimize intrusion of 

27 structural materials into UF6 process or handling areas 

28 

29 • limiting combustibles in outside areas where cylinders are stored 

30 

31 Mitigative measures proposed by GLE relevant to radiological accidents would include 

32 (GLE, 2008): 

33 

34 • radiation detection and criticality monitoring systems to alert workers and isolate systems 

35 when parameters exceed set limits 

36 

37 • physical separation of areas within the facility designed to prevent or reduce exposure 

38 

39 • controlled positive or negative air pressures within designated areas to control air flow and 

40 prevent or maintain leakage between facility areas 

41 

42 • carbon absorbers, HEPA filters, and automatic trips on ventilation systems to prevent 

43 releases outside of affected areas 

44 

45 • limited building leakage paths to the outside environment through appropriate door and 

46 building design 

47 
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1 These features are designed to contain UF6 vapors within specified building areas and 

2 attenuate any release to the environment. Preventive controls for a nuclear criticality accident 

3 would include maintaining a safe geometry of all vessels, containers, and equipment that 

4 contain fissile material, and ensuring that the amount of such material in these vessels does not 

5 exceed set limits. Mitigative controls would include criticality monitoring and alarm systems and 

6 emergency response training (GLE, 2008). 

7 

8 4.2.16 Separation of Preconstruction and Construction Impacts 

9 

10 As described in Section 4.2, the NRC has granted an exemption (NRC, 2009a) for GLE to 

11 conduct certain preconstruction activities, and Sections 4.2.1 through 4.2.14 have provided 

12 estimates of the fraction of impacts that are attributable to preconstruction activities (conducted 

13 as part of the exemption granted by the NRC) and the fraction attributable to NRC-licensed 

14 construction activities. Table 4-28 provides a summary of the anticipated impacts for each 

15 resource area, along with the fractions of these impacts that would be attributable to 

16 preconstruction and construction activities, respectively. 

17 

18 4.2.17 Impacts from Decontamination and Decommissioning 

19 

20 This section summarizes the potential environmental impacts of decontamination and 

21 decommissioning of the site through comparison with facility construction and normal 

22 operational impacts. Decontamination and decommissioning would involve the removal and 

23 disposal of all operating equipment while leaving the structures and most support equipment 

24 decontaminated to free-release levels in accordance with 10 CFR Part 20 (since GLE does not 

25 plan to demolish the buildings). These activities would include the cleaning and removal of 

26 materials, equipment, and structures that are contaminated with radioactive and/or hazardous 

27 wastes. As discussed in Chapter 2 of this draft EIS, decommissioning activities are estimated to 

28 require 3.5 years, shorter than construction (6 years) or operations activities (40 years). 

29 

30 Decommissioning activities anticipated to be conducted for the proposed GLE Facility include 

31 purging and draining of process systems, dismantling and removal of equipment, 

32 decontamination of equipment and structures, waste disposal, and final radiological surveys 

33 (GLE, 2009c). GLE has also indicated that it plans to sell salvaged materials (GLE, 2009c). 

34 However, a complete description of actions taken to decommission the proposed GLE Facility at 

35 the expiration of its NRC license period cannot be determined fully at this time. In accordance 

36 with 10 CFR 70.38, GLE must prepare and submit a Decommissioning Plan to the NRC at least 

37 12 months prior to the expiration of the NRC license for the proposed GLE Facility. GLE would 

38 submit a final decommissioning plan to the NRC prior to the start of decommissioning 

39 (GLE, 2008). This plan would be the subject of further NEPA review, as appropriate, at the time 

40 the Decommissioning Plan is submitted to the NRC. Decontamination and decommissioning 

41 activities would be conducted to comply with all applicable Federal and State regulations in 

42 effect at the time of these activities. 

43 

44 Depleted UF6 (tails) that remains after the operational phase would be sold, sent to a DOE 

45 depleted UF6 conversion facility, and/or sent to other licensed facilities for conversion. These 

46 facilities would convert the tails into a stable, non-volatile uranium compound for disposal in 

47 accordance with regulatory requirements. Low-level radioactive wastes produced during the 
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Table 4-28 Summary of Anticipated Impacts from 

Preconstruction and Construction Activities 

Resource Area Impact Preconstruction 

(%) 

Construction 

(%) 

Land Use SMALL 50 50 

Historic and Cultural SMALL to MODERATEa 95 5 

Visual and Scenic SMALL 25 75 

Air Quality SMALL to MODERATEb 75 25 

Geology and Soil SMALL 75 25 

Surface Water SMALL 75 25 

Groundwater SMALL 50 50 

Ecology SMALL to MODERATEa 75 25 

Noise SMALL to MODERATEb 75 25 

Transportation SMALL to MODERATE NAc NAc

Occupational and Public Health SMALL 15 85 

Waste Management SMALL 2 98 

Accidents SMALL NAc NAc

Socioeconomic SMALL 5 95 

Environmental Justice SMALL NAc NAc

a

 The majority of impacts on this resource occur during preconstruction. Therefore, the anticipated impacts 

from preconstruction activities are SMALL to MODERATE, and the anticipated impacts from construction 

activities are SMALL. 

b

 Although the majority of overall impacts on this resource occur during preconstruction activities, the impacts 

vary on a daily basis, depending on the types of activities performed. Therefore, the anticipated impacts are 

SMALL to MODERATE for both preconstruction and construction activities. 

c

 Quantitative separation of preconstruction and construction impacts is either not applicable or not appropriate 

for this resource. 

1 

2 decontamination and decommissioning process would be disposed of in a licensed low-level 

3 waste disposal facility. Hazardous wastes generated during the decontamination and 

4 decommissioning process would be treated or disposed of in permitted hazardous waste 

5 facilities. Releases to the atmosphere would be expected to be minimal. The final step in the 

6 decontamination and decommissioning process, the radiation survey, does not involve adverse 

7 environmental impacts. The proposed GLE Facility would be released for unrestricted use as 

8 defined in 10 CFR 20.1402. 

9 

10 The primary environmental impacts of the decontamination and decommissioning of the 

11 proposed GLE Facility include changes in releases to the atmosphere and surrounding 

12 environment, and disposal of industrial trash and decontaminated equipment. The types of 

13 impacts that may occur during decontamination and decommissioning would be similar to many 

14 of those that would occur during the initial construction of the proposed facility. Some impacts, 
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1 such as water usage and the number of truck trips, could increase during the decontamination 

2 and disposal phase of the decommissioning, but would be less than the construction phase. 

3 The impacts on different resource areas from decontamination and decommissioning are 

4 discussed in detail in the following subsections. 

5 

6 4.2.17.1 Land Use 

7 

8 The location of the proposed GLE Facility is zoned for heavy industrial uses. The 

9 decontamination and decommissioning of an enrichment facility would not be expected to alter 

10 the zoning of the property or other adjacent properties. Impacts on land use from 

11 decontamination and decommissioning are expected to be SMALL. 

12 

13 4.2.17.2 Historic and Cultural Resources 

14 

15 It is unlikely that decontamination and decommissioning of an enrichment plant would have an 

16 effect on historic and cultural resources. Impacts on historic and cultural resources occur 

17 primarily during ground-disturbing activities; if decontamination and decommissioning activities 

18 require the disturbance of previously undisturbed land, then impacts could result. The need to 

19 clear previously undisturbed land is not expected as part of decontamination and 

20 decommissioning activities. The NHPA can also consider project effects on items of unique 

21 engineering. If, at the time of decommissioning, the technologies employed at the plant are 

22 considered significant to the nation for understanding nuclear technologies, some record of the 

23 plant may be required to mitigate the removal of the plant. It is not expected that this situation 

24 would arise. Therefore, the impacts on historic and cultural resources resulting from 

25 decontamination and decommissioning are expected to be SMALL. 

26 

27 4.2.17.3 Visual and Scenic Resources 

28 

29 Decontamination and decommissioning activities have the potential to impact visual and scenic 

30 resources, however, all impacts would be expected to be minimal and of short duration. Visual 

31 and scenic impacts associated with decontamination and decommissioning would result from 

32 the use of heavy equipment to dismantle the facilities and the increase in worker traffic. Once 

33 the decommissioning was complete, most of the visual impacts would cease. The vegetation 

34 screen surrounding the plant would remain, thus making changes to the plant unperceivable to 

35 all but the closest residences. Visual and scenic impacts from decontamination and 

36 decommissioning are expected to be SMALL. 

37 

38 4.2.17.4 Air Quality 

39 

40 Large-scale soil disturbances that would occur during the preconstruction phase would not be 

41 likely. Most decontamination activities would occur inside the buildings, for which emission 

42 controls would be in place to minimize atmospheric releases of radioactive materials. If 

43 decommissioning activities would include demolition of buildings, structures, and hard surface 

44 areas, heavy construction equipment, such as bulldozers, scabblers, or front-end loaders, would 

45 be used for demolishing and loading debris onto trucks. For these activities, fugitive dust 

46 emissions, potentially contaminated, would be a primary concern, and would be controlled using 

47 standard dust suppression techniques, e.g., water spraying. By employing dust suppression 

48 techniques, the demolition activities would be unlikely to violate the permit conditions. If 
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1 necessary, work areas would be monitored for airborne dust, and respiratory protection may be 

2 used or a small, temporary shelter or tent with portable HEPA filtration may be used to minimize 

3 potential contaminated dust emissions. Salvaged materials for sale and wastes and debris for 

4 disposal would be hauled offsite. The number of workers during this phase would be fewer than 

5 those during construction or operations, but hauling truck traffic on the North access road would 

6 be comparable to that during construction phase. The GLE license, if issued, is expected to 

7 terminate in 2052. Around 2051, when decommissioning is expected to begin, more stringent 

8 exhaust standards may be applied to onroad and offroad engines, and zero-emission cars 

9 (e.g., electric or hydrogen fuel cell cars) may be more common. Overall, decontamination and 

10 decommissioning activities at the proposed GLE Facility would be considered comparable to or 

11 less than those during construction phase in terms of air emission rates and associated impacts. 

12 Therefore, potential impacts of decontamination and decommissioning activities on ambient air 

13 quality would be anticipated to be SMALL. 

14 

15 4.2.17.5 Geology and Soils 

16 

17 During decontamination and decommissioning of the proposed GLE Facility, the foundations, 

18 roads, and utility lines would likely be undisturbed. Erosion may increase, as portions of the site 

19 are disturbed by heavy equipment. BMPs would reduce the impact of the erosion, as discussed 

20 in Section 4.2.6.3 related to mitigation measures for surface water. Impacts on geology or soil 

21 during decontamination and decommissioning are expected to be SMALL. 

22 

23 4.2.17.6 Water Resources 

24 

25 During decontamination and decommissioning, the process wastewater flow would cease, but 

26 decontamination effluent would be generated. If sanitary discharge from the proposed 

27 GLE Facility could not be received by the Wilmington treatment and industrial reuse facility, then 

28 presumably, portable toilets would be required for the decommissioning workers. The 

29 collection, treatment, monitoring, and discharge of decontamination water would be expected to 

30 be designed to avoid significant environmental impact. 

31 

32 Erosion may increase, as portions of the site are disturbed by heavy equipment. BMPs would 

33 reduce the impact of the erosion, as discussed in Section 4.2.6.3 related to mitigation measures 

34 for surface water. Stormwater would continue to be gathered in a wet detention basin. 

35 

36 The removal of structures, utilities, materials, and products would not be expected to have an 

37 impact on site groundwater resources. 

38 

39 The overall impact on water resources from decontamination and decommissioning is 

40 anticipated to be SMALL. 

41 

42 4.2.17.7 Ecological Resources 

43 

44 This section evaluates the potential impacts of GLE Facility decontamination and 

45 decommissioning on ecological resources. Large-scale ecological resource impacts would not 

46 be likely, as most decontamination activities would occur inside the buildings. If 

47 decommissioning activities would include demolition of buildings, structures, or hard surface 
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1 areas (e.g., cylinder storage pads and parking lots), the activities that could affect ecological 

2 resources include: 

3 

4 • the dismantling process 

5 

6 • generation of waste materials 

7 

8 • regrading of project areas 

9 

10 • revegetation activities 

11 

12 • accidental releases (spills) of potentially hazardous materials 

13 

14 Vegetation

15 

16 Removal of facilities could impact vegetation adjacent to the facilities and cause offsite erosion 

17 and sedimentation. Landscaped areas used for staging of equipment or temporary storage of 

18 materials could also be impacted. Fill may be required following the removal of facilities. If 

19 Wilmington Site areas are used to supply the fill, any vegetation established at the source area 

20 would be destroyed. Following decontamination and decommissioning, affected areas would be 

21 revegetated (GLE, 2008). The plant community established where facilities are removed would 

22 depend on subsequent use of the project area. 

23 

24 Accidental spills of hazardous materials during decontamination and decommissioning could 

25 impact plant communities in the vicinity of the spill. Impacts would be similar to those discussed 

26 for preconstruction and construction (Section 4.2.8.1). 

27 

28 Wetlands

29 

30 As no wetlands occur within the proposed GLE Facility area, decontamination and 

31 decommissioning activities would not directly impact wetlands. 

32 

33 Environmentally Sensitive Areas

34 

35 As no environmentally sensitive areas occur within the proposed GLE Facility area, 

36 decontamination and decommissioning activities would not directly impact environmentally 

37 sensitive areas. 

38 

39 Wildlife

40 

41 As decontamination and decommissioning activities would be restricted primarily to within the 

42 proposed GLE Facility, only landscaped areas and maintained lawn areas adjacent to the 

43 impervious storage pad areas would be impacted. During the decontamination and 

44 decommissioning phase, there would be a temporary increase in noise and visual disturbance 

45 to wildlife associated with vehicle, equipment, and worker activities. 

46 

47 Other potential environmental concerns resulting from decontamination and decommissioning 

48 would include the disposal of solid wastes and hazardous materials and the remediation of any 
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1 contaminated soils. Some fuel and chemical spills could also occur, but these would be 

2 generally confined to the access road and project site area. The probability that wildlife would 

3 be exposed to such spills would be small and limited to a few individuals. After decontamination 

4 and decommissioning activities were complete, there would be no fuel or chemical spills 

5 associated with the proposed GLE Facility. 

6 

7 Impacts on wildlife from decontamination and decommissioning activities would be somewhat 

8 similar to those that occurred during the construction phase, but the extent of impacts would be 

9 less, as the operations building is not expected to be demolished. Minimal wildlife habitat would 

10 exist on the storage pads. If they would be removed as part of decontamination and 

11 decommissioning, their removal would have negligible direct impacts on wildlife. There would 

12 be an increase in noise and visual disturbance associated with the removal and subsequent 

13 restoration of facilities. Most wildlife would avoid the area while decontamination and 

14 decommissioning activities were taking place. Increased traffic levels during decommissioning 

15 could result in increased roadkills, but injury and mortality rates of wildlife would probably be 

16 lower than they would be during construction. 

17 

18 Revegetation of the removed facility areas could increase wildlife habitat diversity. 

19 Revegetation of the pad areas would probably result in habitat similar to that on other 

20 operational areas of the Wilmington Site (i.e., landscaped lawns). Wildlife species that would 

21 inhabit these areas would be the same as those that occur on other developed locations of the 

22 Wilmington Site (Section 3.8.4). 

23 

24 Aquatic Biota

25 

26 Removal of the impervious areas, coupled with the cessation of the proposed GLE Facility’s 

27 operations, would lower the amount of runoff and discharge to the stormwater detention basin 

28 and water treatment facilities. Therefore, what minimal impacts occur to water quality and thus, 

29 aquatic biota during operations, would cease. The potential would exist for fuel and chemical 

30 spills to occur. These would be confined to the access road and the proposed GLE Facility area 

31 and would not be expected to enter waterways. Once decontamination and decommissioning 

32 activities were completed, there would be no spills associated with the proposed GLE Facility. 

33 

34 Threatened, Endangered, and Other Special Status Species

35 

36 As no threatened, endangered, or other special status species would be expected to inhabit the 

37 proposed GLE Facility, decontamination and decommissioning activities would not directly 

38 impact listed species. 

39 

40 Summary

41 

42 In the long-term, decommissioning and reclamation would increase species diversity and habitat 

43 quality within the project area compared to that which would exist during operations. 

44 
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1 4.2.17.8 Noise 

2 

3 Large-scale soil disturbances that would occur during preconstruction activities would not be 

4 likely during decontamination and decommissioning. Most decontamination activities would 

5 occur inside the buildings. If decommissioning activities would include demolition of buildings, 

6 structures, and hard surface areas, heavy construction equipment, such as bulldozers, 

7 scabblers, or front-end loaders would be used for demolishing and loading debris onto trucks. 

8 Salvaged materials for sale and wastes and debris for disposal would be hauled offsite. The 

9 number of workers during decommissioning would be fewer than those during construction or 

10 operations, but hauling truck traffic on the North access road would be expected comparable to 

11 that during construction. Due to the proximity, primary noise sources that could have impact on 

12 the nearest Wooden Shoe residential subdivision would be hauling trucks along the North 

13 access road. As discussed in Section 4.2.9, potential noise impacts on the nearest subdivision 

14 during the entire life of the project, except during the road construction phase of short duration 

15 (one month), are predicted to be SMALL. Even though cylinder pads would be removed and 

16 noisier heavy equipment would be used, noise levels at the nearest Wooden Shoe subdivision 

17 would be less than the New Hanover County Noise Ordinance and EPA guideline. Therefore, 

18 potential impacts from decontamination and decommissioning activities on the nearest Wooden 

19 Shoe residential subdivision would be expected to be SMALL. 

20 

21 4.2.17.9 Transportation 

22 

23 The initial decontamination and decommissioning activities during the last year of operations 

24 would increase the total number of workers at the proposed GLE Facility to approximately 400, 

25 a level similar to that during the construction period, with similar impacts. Approximately 

26 50 workers are estimated to be needed during decommissioning (GLE, 2008) as shown in 

27 Table 4-10. An upper limit of fifty workers would be expected, though day-to-day numbers 

28 would vary depending on the scheduled activities as decontamination and removal of equipment 

29 and other materials progresses. The corresponding number of truck shipments to offsite 

30 locations during this time period is anticipated to be approximately the same as during 

31 construction, an average of about 35 trucks per day (GLE, 2008). Local and regional 

32 transportation impacts would be SMALL after operations are complete because of the decrease 

33 in workers from approximately 388 during construction, 350 during operations, 400 during 

34 operations and initial decontamination and decommissioning, to 50 during decommissioning. 

35 

36 Radioactive waste from decontamination and decommissioning would be sent to the appropriate 

37 storage, treatment, and disposal facilities as appropriate for the waste type as authorized by the 

38 NRC. Suitable disposal facilities would be identified at the time of decommissioning. All 

39 shipments would comply with existing NRC and DOT regulations. Impacts from radioactive 

40 waste shipments would be SMALL because of the low levels of external radiation and the low 

41 number of shipments. 

42 

43 4.2.17.10 Public and Occupational Health 

44 

45 The anticipated decontamination and decommissioning plans call for cleaning structures and 

46 selected facilities to free-release levels and allowing them to remain in place for future use. 

47 Allowing the buildings to remain in place would minimize the potential number of workers 

48 required for decontamination and decommissioning, which would reduce the number of injured 
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1 workers compared to building removal. Occupational injuries would be of similar nature to those 

2 incurred during construction of the facility (Section 4.2.11.1), but would be reduced in number in 

3 accordance with the reduced effort required for decontamination and decommissioning. 

4 According to current estimates, such efforts would require about 23 percent of the worker level 

5 for construction: 450 FTEs versus 1938 FTEs for construction (GLE, 2008, Table 4.10-3). If 

6 residual contamination is discovered, it would be decontaminated to free-release levels or 

7 removed from the site and disposed of in a low-level radioactive waste facility. 

8 

9 It is estimated that the annual occupational dose during decontamination and dismantling 

10 activities would be in the range of 5–150 millirem (GLE, 2009a). The dose estimate is based on 

11 the time spent at different work locations and the dose rates in the non-affected and major 

12 processing areas. The dose rate assumed in the non-affected areas was 0.01 millirem per 

13 hour, and in the major processing areas it was up to 0.5 millirem per hour (GLE, 2009a). The 

14 highest dose is comparable to the average dose from the operating fuel facilities of 

15 130-150 millirem (Table 4-21). Therefore, it is expected that the occupational dose during 

16 decontamination and decommissioning would be bounded by potential exposures during 

17 operations. Similar uranium handling would be involved (i.e., UF6 in Type 48Y cylinders and 

18 UF6 in the laser-enrichment lines) during the portion of operations that purges the laser19 enrichment lines. Although purging operation is different from the normal operation, the number 

20 of UF6 workers would be exposed in the laser-enrichment lines would not be much different. 

21 Once this decontamination operation is completed, the remaining quantity of UF6 would be 

22 residual and significantly less than handled during operations. Because systems containing 

23 residual UF6 would be opened, decontaminated (with the removed radioactive material 

24 processed and packaged for disposal), and dismantled, an active environmental monitoring and 

25 dosimetry (external and internal) program would be conducted to maintain ALARA doses to 

26 workers and to individual members of the public as required by 10 CFR Part 20. Chemical 

27 exposures would be similarly limited. Therefore, the impacts on public and occupational health 

28 would be SMALL. 

29 

30 4.2.17.11 Waste Management 

31 

32 The waste management facilities used during operations would be used during decontamination 

33 and decommissioning. With the ongoing drop in workers from operations to decommissioning, 

34 the sanitary wastewater treatment volumes would decline. Materials and equipment eligible for 

35 recycling or nonhazardous disposal would be sampled or surveyed to ensure that contaminant 

36 levels are below release limits. Buildings and other structures would be decontaminated and 

37 the debris shipped offsite for disposal. Radioactive material from decontamination and 

38 contaminated equipment would be packaged and shipped offsite to an appropriately licensed 

39 facility. Staging and laydown areas would be segregated and managed to prevent 

40 contamination of the environment and creation of additional wastes. Waste management 

41 impacts are expected to be SMALL. 

42 

43 4.2.17.12 Socioeconomics 

44 

45 Decontamination and decommissioning activities in the first year would create 50 direct jobs at 

46 the facility site. An additional 23 indirect jobs would be created in the ROI with the procurement 

47 of material and equipment and the spending of direct worker wages and salaries (Table 4-25). 

48 Decontamination and decommissioning of the proposed GLE Facility would produce $6.1 million 
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1 in income in the ROI in the first year of decommissioning. Facility decommissioning would 

2 produce less than $0.3 million in direct State income taxes and less than $0.2 million in direct 

3 State sales taxes. With decommissioning activities constituting less than one percent of total 

4 ROI employment in the first year, the economic impact of decommissioning the proposed 

5 GLE Facility would be SMALL. 

6 

7 Given the scale of decommissioning activities and the likelihood of local worker availability in the 

8 required occupational categories, decontamination and decommissioning of the proposed 

9 GLE Facility would require some in-migration of workers and their families from outside the ROI, 

10 with between 115 and 120 persons in-migrating into the ROI during the first year of 

11 decommissioning. Although in-migration may potentially impact local housing markets, the 

12 relatively small number of in-migrants and the availability of temporary accommodation (hotels, 

13 motels, and mobile home parks) would mean that the impact of facility decommissioning on the 

14 number of vacant rental housing units is not expected to be large, with between 33 and 

15 35 rental units expected to be occupied in the ROI during decommissioning. These occupancy 

16 rates would represent less than one percent of the vacant rental units expected to be available 

17 in the ROI; the impact of the proposed GLE Facility’s decontamination and decommissioning on 

18 housing would, therefore, be SMALL. 

19 

20 In addition to the potential impact on housing markets, in-migration would also affect local 

21 community, education, and medical services employment to maintain existing levels of service. 

22 Accordingly, less than one police officer and less than one firefighter would be required in the 

23 peak decommissioning year. Assuming that a certain number of workers are accompanied by 

24 their families during decommissioning, between 38 and 40 school-age children would be 

25 expected in the ROI, meaning less than one additional teacher would be required to maintain 

26 existing student-teacher ratios in the local school system. These staffing increases would 

27 represent less than one percent of community service employment in each employment 

28 category expected in the ROI; the impact of the proposed GLE Facility’s decontamination and 

29 decommissioning on community, educational, and medical service employment would, 

30 therefore, be SMALL. 

31 

32 4.2.17.13 Environmental Justice 

33 

34 As described in Sections 4.2.17.1 through 4.2.17.12, the potential impacts of the proposed 

35 action during decontamination and decommissioning are expected to be SMALL for all of the 

36 resource areas evaluated. Impacts would affect primarily residents in the immediate vicinity of 

37 the proposed GLE Facility, which would include a mix of minority and nonminority residents, as 

38 well as a mix of low-income and more affluent residents. Specifically, the Census block group in 

39 which the proposed GLE Facility is located has minority residents comprising 18.3 percent of its 

40 population, while low-income residents account for seven percent of its population. These 

41 percentages are below both county and State percentages for the same population groups. 

42 Because impacts on the general population are expected to be SMALL, and because the 

43 greatest impact is expected to occur in the immediate vicinity of the proposed GLE Facility in an 

44 area with a mix of ethnicities and income levels, the various phases of facility development 

45 would not be expected to result in disproportionately high or adverse impacts on low-income or 

46 minority residents, and would not, therefore, produce any environmental justice concerns. 

47 
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1 Even where environmental impacts are generally SMALL, the behaviors of some population 

2 groups, such as higher participation in outdoor recreation, home gardening, or subsistence 

3 fishing, may lead to disproportionate exposure through inhalation or ingestion. One Census 

4 block group, which has a high percentage of low-income and minority residents, is located 

5 downstream of the proposed GLE Facility on the Northeast Cape Fear River. If radiation was 

6 released, residents there could face increased risk of exposure due to their fish-consumption 

7 patterns; however, the releases of total uranium and UF6 are projected to be extremely low 

8 (see Section 4.2.11.2), and indirect exposure through fish consumption would be even lower. 

9 

10 Soil and vegetation samples from the existing site and from a mile away show no impact from 

11 current operations. As discussed in Section 4.2.11, the radiological doses to the nearest 

12 residents resulting from operations of the proposed GLE Facility and the current operations are 

13 projected to be well below the EPA 10 millirem (0.1 millisievert) per year standard 

14 (20 CFR Part 190) and the NRC total effective dose equivalent (TEDE) 100-millirem 

15 (1-millisievert) per year limit (10 CFR Part 20). 

16 

17 Overall, therefore, the proposed GLE Facility is not expected to result in disproportionately high 

18 or adverse impacts on minority or low-income populations. 

19 

20 4.2.17.14 Summary 

21 

22 For most resource areas, the adverse environmental impacts of decontamination and 

23 decommissioning of the proposed GLE Facility could be SMALL to MODERATE; similar to the 

24 construction impacts, except in reverse order. The notable exception would be cultural 

25 resources, where the impacts of preconstruction and construction activities would be significant 

26 in comparison to those of decontamination and decommissioning. The facilities and land could 

27 be released for restricted or unrestricted use, and releases to the environment from the 

28 proposed GLE Facility would stop. In addition, depending on the future use of the site, 

29 consumption of water and electricity and vehicular traffic to and from the site could be reduced. 

30 Decommissioning impacts would be localized in the immediate proposed GLE Facility31 developed site. No disposal of waste, including radioactive waste, would occur at the proposed 

32 GLE Facility site. 

33 

34 4.2.18 Carbon Dioxide and Other Greenhouse Gas Impacts 

35 

36 This section presents an assessment of the effect construction, operations, and 

37 decommissioning activities for the proposed GLE Facility would be expected to have on carbon 

38 dioxide and greenhouse gas emissions. 

39 

40 4.2.18.1 Greenhouse Gases 

41 

42 Greenhouse gases include those gases, such as water vapor (H2O), carbon dioxide (CO2), 

43 methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and 

44 sulfur hexafluoride (SF6), that are transparent to incoming short-wave radiation from the sun but 

45 opaque to outgoing long-wave (infrared) radiation from the earth’s surface. The net effect over 

46 time is a trapping of absorbed radiation and a tendency to warm the planet’s surface and the 

47 boundary layer of the earth’s atmosphere, which constitute the “greenhouse effect.” Some 

48 direct GHGs (CO2, CH4, and N2O) are both naturally occurring and the product of industrial 
4-125 

1 activities, while others such as the hydrofluorocarbons are created and are present in the 

2 atmosphere exclusively due to human activities. Each GHG has a different radiative forcing 

3 potential (the amount of thermal energy [in watts] trapped by the gas per square meter of the 

4 earth’s surface). The radiative efficiency of a GHG is directly related to its concentration in the 

5 atmosphere. As a way to compare the radiative forcing potentials of various GHGs without 

6 directly calculating changes in their atmospheric concentrations, an index known as the Global 

7 Warming Potential (GWP) has been established with carbon dioxide, the most abundant of 

GHGs released to the atmosphere (after water vapor),21 8 established as the reference point. 

9 

10 GWPs are calculated as the ratio of the radiative forcing that would result from the emission of 

11 1 kilogram (2.2 pounds) of a GHG to that which would result from the emission of 1 kilogram 

12 (2.2 pounds) of CO2 over a fixed period of time. GWPs represent the combined effect of the 

13 amount of time each GHG remains in the atmosphere and its ability to absorb outgoing thermal 

14 infrared radiation. As the reference point in this index, CO2 has a GWP of 1. On the basis of 

15 100-year time horizon, GWPs for other key GHGs are as follows: 21 for CH4, 310 for N2O, 

16 11,700 for trifluoromethane (HFC-23), and 23,900 for SF6 (IPCC, 2007).

17 

18 Indirect GHGs, including CO, NOx, nonmethane volatile organic compounds (NMVOCs), and 

19 SO2, indirectly affect terrestrial solar radiation absorption by influencing the formation and 

20 destruction of tropospheric and stratospheric ozone or, in the case of SO2, by affecting the 

21 absorptive characteristics of the atmosphere. 

22 

23 4.2.18.2 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 

26 Greenhouse Gas Emissions and Sinks to comply with existing commitments under the United 

27 Nations Framework Convention on Climate Change (UNFCCC). GHG emissions are reported 

28 in sectors, using the GWPs established in the Second Assessment Report of the 

Intergovernmental Panel on Climate Change (IPCC).22 29 

30 

 

21 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 4 percent by volume. 

Compared to natural processes, human activities are not believed to have a significant direct effect on 

the average global concentration of water vapor; however, increased concentrations of other 

greenhouse gases released, in part, through human activities may indirectly affect the hydrologic 

cycle. Despite its substantial radiative forcing potential (primarily through the formation of clouds 

which can both absorb and reflect solar and terrestrial radiation), water vapor is not typically included 

in GHG inventories. 

22 IPCC assessment reports are a compilation of separate reports of the various working groups that are 

established by the Panel. IPCC 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. 
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In 2007, total GHG emissions in United States were 7150.1 teragrams CO2 equivalent,23 1 an 

2 increase of 17 percent from 1990 (EPA, 2009c). In 2007, CO2 emissions in U.S. were about 

3 20 percent of worldwide emissions (EIA, 2009b). However, net emissions (considering sources 

4 and sinks) were estimated to be 6087.5 teragrams CO2 equivalent. The primary GHG sinks 

5 functional in 2007 included carbon sequestration in forests, trees in urban areas, agricultural 

6 soils, and landfilled yard trimmings and food scraps, all of which, in aggregate, offset 

7 14.9 percent of the total GHG emissions in 2007. The primary GHG emitted by human activities 

8 in the United States was CO2, representing approximately 85.4 percent of the total GHG 

9 emissions (6103.4 teragrams CO2 equivalent). The largest source of CO2 for 2007 was the 

10 result of fossil fuel combustion (80.2 percent of total GHG emissions), primarily electricity 

11 generation (33.5 percent), transportation (26.4 percent), industrial applications (11.8 percent), 

12 residential heating (4.8 percent), and commercial applications (3.0 percent). Methane 

13 emissions in 2007, which declined from 1990 levels, were about 585.3 teragrams CO2

14 equivalent, which represented about 8.2 percent of total GHG emissions. Major contributors to 

15 CH4 emissions included enteric fermentation associated with domestic livestock, decomposition 

16 of wastes in landfills, and natural gas systems. Emissions of N2O in 2007 were about 

17 311.9 teragrams CO2 equivalent (4.4 percent of total GHG emissions), for which agricultural soil 

18 management accounts for two-thirds of total N2O emissions, followed by mobile fuel combustion 

19 (about 10 percent of total N2O emissions). Emissions of HFCs in 2007 were 125.5 teragrams 

20 CO2 equivalent (about 1.8 percent of total GHG emissions), most of which was associated with 

21 substitution of ozone-depleting substances. PFC and SF6 emissions in 2007 were a small 

22 fraction of total GHG emissions (about 0.1 and 0.2 percent, respectively). Contributions to PFC 

23 emissions were comparable between aluminum production and semiconductor manufacturing, 

24 while three-quarters of SF6 emissions in 2007 resulted from electrical transmission and 

distribution.24 25 Albeit small emissions relative to other principal GHG emissions, emissions of 

26 HFCs, PFCs, and SF6 were significant because many of them have extremely high GWPs and, 

27 in case the of PFCs and SF6, long atmospheric lifetimes (e.g., PFC-14 with about 50,000 years). 

28 

29 Emissions of indirect GHGs in 2007 included about 14.25 teragrams for NOx, 63.88 teragrams 

30 for CO, 13.7 teragrams for NMVOCs, and 11.73 teragrams for SO2. Mobile fossil fuel 

31 combustion accounted for half of total NOx emissions, followed by stationary fossil fuel 

32 combustion. CO emissions resulted primarily from mobile fossil fuel combustion, while SO2

33 emissions resulted primarily from stationary fossil fuel combustion (e.g., coal-fired power 

34 plants). Mobile fossil fuel combustion and solvent use accounted for about 41 and 28 percent of 

35 NMVOCs emissions, respectively. 

36 

37 4.2.18.3 Greenhouse Gas Emissions and Sinks in North Carolina 

38 

39 Among States, North Carolina ranks 12th with respect to emissions of GHGs and 11th in 

40 population (based on 2003 data) (NextGenerationEarth, 2009). In 2005, North Carolina 

41 produced about 192 teragrams CO2 equivalent gross emissions, an amount equal to 2.7 percent 

42 of total gross U.S. GHG emissions (Peterson et al., 2007). The principal source of North 

 

23 GHG emissions are expressed as CO2 equivalent (or CO2 Eq.), which is the product of the mass of a 

gas and its associated GWP. One teragram is equal to 1012 grams, or one million metric tons 

(1.12 million tons). 

24 SF6 is a gas at standard conditions and is used as a dielectric medium in high-voltage electrical 

equipment. 
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1 Carolina’s GHG emissions is consumption-based electricity use (electricity production netting 

2 out electricity exports), accounting for 39.5 percent of total State gross GHG emissions in 2005. 

3 The next largest contributors to total gross GHG emissions are the transportation sector 

4 (30.9 percent) and residential, commercial, and industrial fossil fuel combustion (16.6 percent). 

5 Note that electricity production is predominated by coal, which accounted for over one-third of 

6 State gross GHG emissions in 2005. Typically, coal-fired power plants produce as much as 

7 twice the CO2 emissions per kilowatt-hour of electricity as natural gas-fired power plants. As a 

8 result of these factors, North Carolina’s power plants are the greatest single source of GHG 

9 emissions in the State. Agricultural activities, industrial processes, and waste management 

10 account for the remainder of State GHG emissions (about 13 percent). Considering carbon 

11 sequestered and released from biomass throughout the State, net emissions would be about 

12 169 teragrams CO2 equivalent, an amount equal to 2.8 percent of total net U.S. GHG emissions. 

13 During the period 1990 to 2005, gross and net GHG emissions in North Carolina increased by 

14 about 42 and 57 percent, respectively, while gross and net national GHG emissions increased 

15 by only 17 and 14 percent, respectively. 

16 

17 4.2.18.4 Projected Impacts from the Construction, Operation, and Decommissioning of 

18 the Proposed GLE Facility on Carbon Dioxide and Other GHG Emissions 

19 

20 Construction and operation of the proposed GLE Facility can be expected to contribute to CO2

21 and other GHG emissions through various mechanisms, primarily from combustion of fossil 

22 fuels in both mobile and stationary sources during construction, operations, and 

23 decommissioning. Individual contributions are discussed below. Regional transportation 

24 volumes used in the analysis below were established in Section 4.2.10. 

25 

26 Gasoline combustion is expected to occur at 99 percent efficiency, each gallon releasing 

27 8.8 kilograms (19.4 pounds) of CO2 (EPA, 2005). Likewise, diesel fuel burned at the same 

28 combustion efficiency would release 10.1 kilograms (22.2 pounds) of CO2 per gallon. In this 

29 analysis, only CO2 emissions were estimated. Gasoline and diesel engine combustion also 

30 generate small amounts of other GHG emissions, such as CH4, N2O, and HFCs. However, CO2

31 emissions account for about 93−94 percent of total GHG emissions for automobiles and about 

32 99 percent for heavy-duty trucks on a CO2 equivalent basis (EPA, 2009c). Accordingly, 

33 estimation of CO2 emissions only could underestimate total GHG emissions by a few percent. 

34 

35 CO2 emissions source categories are similar during access road construction, land clearing, and 

36 building construction activities. The final start-up and final construction phase would include 

37 concurrent indoor construction activities with staged testing and start-up of process units as 

38 completed. Accordingly, CO2 emission source categories during this phase are similar to those 

39 during operations. This discussion addresses these two phases together. 

40 

41 Impacts During Access Road Construction, Land Clearing, and Building Construction

42 

43 Access road construction and land clearing activities were assumed in this analysis to include 

44 road construction for one month, followed by land clearing for eight months, and building 

45 construction for two years. During these activities, GHG emission sources would include heavy 

46 construction equipment, as well as commuting to and from the site by the construction 

47 workforce, and locally by delivery vehicles bringing materials and equipment to the site and 

48 removing construction-related non-radiological wastes from the site to area landfills and 

49 treatment/disposal facilities. Annual total fuel consumption for offroad heavy construction 
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1 equipment is estimated using a fuel consumption rate of 0.065 gallons per horsepower-hour 

2 (SME, 1992). During access road construction and land clearing activities, an estimated 

3 95 workers would work onsite, while during the building construction phase, an estimated 

4 680 workers would work onsite. For onroad vehicles, a total of 200 daily local trips for access 

5 road construction and land clearing activities and 1428 daily local trips for building construction 

6 activities are assumed, 90 percent of which are from gasoline engine automobiles and 

7 10 percent of which are from heavy-duty diesel trucks. Average vehicle miles traveled (VMT) 

8 offsite per trip by automobiles and trucks are assumed 10 and 100 miles, respectively. In 

9 addition, these vehicles would travel another 1.64 miles onsite from the gate to the proposed 

10 GLE Facility. Fuel economy factors of 24.1 and 7.2 miles per gallon were assumed for 

11 automobiles and trucks, respectively. 

12 

13 Annual total fuel consumption and CO2 emissions are estimated, as shown in Table 4-29. 

14 During access road construction and land clearing activities, annual total CO2 emissions would 

15 be around 3281 metric tons (3617 tons), which accounts for about 0.0017 percent of North 

16 Carolina GHG emissions in 2005 and 0.00005 percent of U.S. GHG emissions in 2007 (the 

17 most recent publically reviewed data). During the building construction phase, annual total 

18 emissions are estimated to be about 10,525 metric tons (11,602 tons), about 0.0055 percent of 

19 North Carolina GHG emissions and 0.00015 percent of U.S. GHG emissions. CO2 emissions 

20 during this period are over three times more than those for access road construction and land 

21 clearing activities due to increased workforce and delivery activities. 

22 

23 Impacts During Start-up and Final Construction, and Operations 

24 

25 Start-up and final construction activities would occur for five years from 2013 to 2017, and 

26 operations would continue until 2051. During start-up and final construction, an estimated 

27 743 workers would work onsite, while during the operations phase, an estimated 350 workers 

28 would work onsite. For onroad vehicles, a total of 1559 daily local trips for start-up and final 

29 construction and 735 daily local trips for operations are assumed. Compared with the previous 

30 two phases, auxiliary diesel generators, onsite transfer vehicles (OSTVs), possibly diesel31 powered forklifts, and onsite diesel trucks used for cylinder transfer are added instead of offroad 

32 heavy construction equipment. To support facility operations, regional deliveries would be 

33 anticipated: UF6 feedstock coming to the proposed GLE Facility and UF6 product, depleted UF6

34 tails, empty 48Y cylinders, and LLRW leaving the facility. Detailed discussion including the 

35 destination and total distance traveled by delivery trucks is available in Section 4.2.10. It is 

36 assumed that separate shipments would be initiated to return empty cylinders and waste 

37 containers to their points of origin. It is further assumed that, during start-up and final 

38 construction, the production level on average would be 50 percent of that during operations. 

39 

40 During start-up and final construction, the proposed GLE Facility is estimated to release 

41 12,852 metric tons (14,166 tons) of CO2, which is equivalent to 0.0067 percent of North Carolina 

42 GHG emissions and 0.00018 percent to U.S. GHG emissions in 2007. During operations, CO2

43 emissions are projected to be 9934 metric tons (10,950 tons), approximately 0.0052 percent of 

44 the North Carolina Statewide output in 2005 or 0.00014 percent of nationwide emissions 

45 in 2007. The start-up and final construction phase would release the highest CO2 emissions 

46 during the lifespan of the GLE project, followed by building construction and operations. During 

47 start-up and final construction, CO2 emissions from local traffic are predicted to predominate 
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Table 4-29 Annual CO2 Emissions from Access Road Construction, Land Clearing, 

Building Construction, Start-up and Final Construction, and Operation of the 

Proposed GLE Facility 

Fuel CO2 Emissions 

Phase Air Emission 

Source Type Consumption 

rate (gals/yr)a

CO2

Emission 

Factor 

(lbs/gal)b (tons/yr) (MTs/yr)c

Offroad construction 

equipment 

Diesel 229,249 22.2 2546.0 2309.7 

Automobiles (local) Gasoline 23,415 19.4 226.6 205.6 

Access Road 

Construction and 

Land Clearing 

Diesel trucks (local) Diesel 76,039 22.2 844.5 766.1 

 Total 3617.1 3281.4 

Offroad construction 

equipment 

Diesel 126,744 22.2 1407.6 1277.0 

Automobiles (local) Gasoline 222,844 19.4 2156.8 1956.6 

Building 

Construction 

Diesel trucks (local) Diesel 723,694 22.2 8037.1 7291.3 

 Total 11,601.5 10,524.9 

Auxiliary diesel 

generator unitsd

Diesel − − 10.4 9.4 

OSTVs used for 

cylinder transfer 

Diesel 6299 22.2 70.0 63.5 

Onsite diesel truck used 

for cylinder transfer 

Diesel 29 22.2 0.3 0.3 

Automobiles (local) Gasoline 247,426 19.4 2394.7 2172.5 

Diesel trucks (local) Diesel 803,525 22.2 8923.7 8095.6 

Start-up and Final 

Construction 

Diesel trucks (regional)e Diesel 249,175 22.2 2767.3 2510.5 

 Total 14,166.4 12,851.7 

Auxiliary diesel 

generator unitsd

Diesel − − 10.4 9.4 

OSTVs used for 

cylinder transfer 

Diesel 6299 22.2 70.0 63.5 

Onsite diesel truck used 

for cylinder transfer 

Diesel 29 22.2 0.3 0.3 

Automobiles (local) Gasoline 116,616 19.4 1128.7 1023.9 

Diesel trucks (local) Diesel 378,715 22.2 4205.9 3815.6 

Diesel trucks (regional)e Diesel 498,349 22.2 5534.5 5020.9 

Operations 

Total 10,949.8 9933.6 a

 See Appendix E for detailed information on underlying assumptions. 

b

 Source: EPA, 2005. 

c

 MTs/yr = metric tons/year. To convert to tons/year, divide by 0.9072. 

d

 Emissions are estimated using the NCDENR calculator spreadsheet (NCDENR, 2010). e

 Includes UF6 feed coming to proposed GLE Facility and UF6 product, depleted UF6 tails, empty 48Y cylinders, and LLRW leaving 

the facility. 
4-130 

 over regional traffic. However, during operations, CO2 emissions from local and regional traffic 

would be comparable. 

Impacts During Decommissioning

As discussed in Section 4.1, because decommissioning will take place well in the future, 

detailed plans for decommissioning the proposed GLE Facility are not known at this time. 

Consequently, the impacts of decommissioning are discussed qualitatively in this document. 

The main sources of CO2 and other GHG emissions during the decommissioning phase are 

expected to be shipment of waste (LLRW and nonhazardous/nonradioactive waste) to 

appropriate disposal facilities and shipment of any remaining depleted UF6 on site to a 

conversion facility. In addition, heavy equipment use at the site and travel to and from the site 

by the decommissioning workers would contribute to CO2 and other GHG emissions during 

decontamination and decommissioning. 

The emissions from shipments of waste and depleted UF6 would depend on the locations of 

selected disposal and conversion facilities. Because GLE does not plan to demolish buildings 

during decommissioning (see Section 4.2.17), the quantity of nonhazardous/nonradioactive 

waste generated during this phase of the project would be relatively small as compared to the 

quantity generated during operations. With respect to LLRW, GLE estimates that it would 

generate approximately 18,800 cubic meters (664,000 cubic feet) of LLRW during the entire 

decommissioning period (GLE, 2009c). Assuming that LLRW generated during 

decommissioning has a density of 2 kilograms per liter (125 pounds per cubic foot), GLE would 

generate approximately three times more LLRW, by mass, during decommissioning than it 

would during operations. Assuming LLRW is disposed of in the same facility during 

decommissioning as it is during operations, this difference would represent approximately 3,000 

more shipments of approximately 3,940 kilometers (2,450 miles) during the entire 

decommissioning period as compared to the operations period. However, the emissions from 

these LLRW shipments would be less than the emissions from other shipments that would occur 

during operations but not during decommissioning, including approximately 900 shipments per 

year of unenriched UF6 feed to the facility (470 to 1400 kilometers [290 to 870 miles]), 50 

shipments per year of enriched UF6 product (480 to 4780 kilometers [300 to 2970 miles]), and 

50 shipments per year to return empty depleted UF6 cylinders (1320 kilometers [820 miles]). 

Available storage space on the cylinder storage pads would limit the number of depleted UF6

cylinders that could be stored on site at any one time to 9,000. Upon cessation of facility 

operations, it is likely that less than 9,000 cylinders would be stored on-site. However, 

assuming 9,000 cylinders would be stored on site and awaiting shipment to a conversion facility 

during decommissioning, there would be approximately three times as much depleted UF6

shipped to a conversion facility during operations as there would be during decommissioning. 

As a result, CO2 emissions associated with shipments of materials, including LLRW, 

nonhazardous/nonradioactive waste, and depleted UF6, during decontamination and 

decommissioning would be less than the 221,000 tons (200,000 metric tons) of CO2 emissions 

that are associated with use of diesel trucks at the regional scale during 40 years of facility 

operations (see Table 4-29). 
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As discussed in 4.2.17.4, large-scale soil disturbances are not likely during decommissioning. 

In addition, GLE does not currently plan to demolish buildings associated with the proposed 

GLE Facility during decommissioning. Therefore, significantly less heavy equipment use would 

be expected during decontamination and decommissioning than during access road 

construction and land clearing, and the CO2 emissions from heavy equipment use during 

decontamination and decommissioning would be bounded by the offroad construction vehicle 

CO2 emissions during access road construction and land clearing listed in Table 4-29. Similarly, 

because the number of employees during operations is significantly greater than during 

decontamination and decommissioning, the GHG emissions associated with employee traffic 

during decontamination and decommissioning would be bounded by the emissions provided in 

Table 4-29 for local automobile use during operations. 

Based on the considerations of the expected CO2 emissions attributable to shipment of depleted 

UF6 to a conversion facility, shipment of LLRW for disposal, heavy equipment use, and 

employee traffic as described in this section, the total quantity of GHGs emitted during 

decontamination and decommissioning is expected to be less than the amount emitted during 

operations. 

Indirect Positive Impacts from Operation of the Proposed GLE Facility

Nuclear power generation with fuel fabricated from the proposed GLE Facility would indirectly 

displace GHG emissions that would otherwise be released from fossil-fuel power plants. 

Accordingly, enriched UF6 produced at the proposed GLE Facility can be thought of as an 

indirect GHG sink. It is estimated that, at full production, the proposed GLE Facility would 

produce approximately 2047 metric tons (2257 tons) of enriched UF6 annually, which would be 

equivalent to 1570 metric tons (1731 tons) of uranium dioxide (UO2) fuel.25 A typical 

1100-megawatt pressurized water reactor (PWR) would have approximately 98 metric tons 

(108 tons) of UO2 in its core (Nero, 1979). Thus, annual production of the proposed GLE 

Facility could replace the fuel cores of 16 PWRs. Operating at a capacity factor of 95 percent, 

each PWR would be capable of producing 9154 gigawatt-hours per year, so the total amount of 

power associated with GLE-enriched UF6 production would be 146,654 gigawatt-hours per year. 

Carbon Dioxide and Other GHG Emissions Summary

In summary, over the lifespan of construction and operation of the proposed GLE Facility, the 

start-up and final construction phase was projected to generate the highest emissions. These 

direct emissions would be about 0.0067 percent of North Carolina GHG emissions in 2005 and 

0.00018 percent of U.S. GHG emissions in 2007 (the most recent publicly reviewed data). The 

NRC staff concludes that potential impacts from the construction, operation, and 

decommissioning of the proposed GLE Facility on climate change would be SMALL. 

 

25 AREVA Enrichment Services, LLC, (AES) estimated that, at full production, EREF would produce 

approximately 2252 metric tons (2482 tons) of enriched UF6 annually, which would be equivalent to 

1727 metric tons (1904 tons) of UO2 fuel (NRC, 2010b). The capacity of the proposed GLE Facility 

would be 6 million SWU and the total production volume of enriched UF6 annually is estimated in 

proportion to production capacity of EREF (6.6 million SWU). 
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4.3 Cumulative Impacts 

The Council on Environmental Quality regulations implementing NEPA define cumulative effects 

as “the impact on the environment which results from the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (Federal or nonFederal) or person undertakes such other actions” (40 CFR 1508.7). Cumulative impacts are 

presented below for resource areas in which there are anticipated changes related to other 

activities that may arise from single or multiple actions and may result in additive or interactive 

effects (e.g., other new facilities that are planned at the Wilmington Site). 

Impacts from preconstruction activities for the proposed GLE Facility are addressed as 

cumulative impacts in this draft EIS, as these actions are not part of the proposed action. These 

impacts are discussed within the various resource area discussions in Section 4.2 so that they 

can be presented alongside similar impacts from construction of the facility that are included in 

the proposed action. In Section 4.2.16, impacts resulting from preconstruction are identified as 

a percentage of total impacts estimated to occur prior to facility operations. In this sense, site 

preconstruction activities would be considered past activities for the purposes of cumulative 

impacts. 

Consultation with local development boards and agencies with which proposed new projects are 

filed identified other actions or activities in the area that could affect the same resources as the 

proposed GLE Facility, contributing to cumulative effects. 

Identified activities include several that exist or will exist at the Wilmington Site. Onsite and 

adjacent offsite activities are summarized below: 

• Existing facilities on the Wilmington Site. These include the existing FMO facility and other 

existing facilities. 

• Facilities planned for the Wilmington Site. Two new facilities, which could contribute to 

cumulative effects, are planned for the Wilmington Site – the Advanced Technology 

Center (ATC) II complex and the Tooling Development Center (see Figure 4-1). In addition, 

it is reasonably foreseeable that a security-related feature, independent of security 

measures specific to the proposed facility, may be developed on the Wilmington Site 

(GLE, 2009d). Additional information about this feature and the cumulative impacts of the 

proposed action in combination with this feature are provided in Appendix H. 

• New processes planned for the Wilmington Site. Sanitary wastewater from the existing 

FMO facility is currently treated for reuse for industrial purposes. This process would be 

expanded to include similar sanitary wastewater from the proposed GLE Facility for 

industrial reuse. 

• Offsite industrial development. (1) The Carolinas Cement Company has submitted an 

application for an air permit to construct a new cement manufacturing plant in northeastern 

Hanover County, roughly six miles northeast of the proposed GLE Facility. (2) The River 

Bluffs residential development has been proposed to be built on 95 hectares (237 acres) 

adjacent to the southern boundary of the Wilmington Site. 
4-133 

• Offsite UF6 transportation and local traffic increases. Increased transport of UF6 feed and 

waste materials could increase doses to the public over those from current transport of such 

materials from operation of the FMO facility. Increased traffic from workers at the proposed 

GLE Facility would contribute to traffic congestion on local roads and highways. 

The following sections present assessments of the potential cumulative impacts of the proposed 

action in combination with above activities by resource area. Cumulative impacts associated 

with the no-action alternative on the various resource areas would be generally less than those 

for the proposed action, except in terms of local job creation. Therefore, except for 

socioeconomic impacts, the cumulative impacts of the no-action alternative are not discussed in 

detail. 

4.3.1 Land Use 

Cumulative impacts on land use would result if the proposed action in combination with other 

projects prohibited other land uses from occurring or were incompatible with current zoning. 

The proposed GLE Facility site is located on property currently owned by GE. The eastern 

portion of the property already contains the GNF-A and GE AE/SCO plant. The proposed 

GLE Facility is consistent with the current zoning. Additional industrial development is expected 

Figure 4-1 Planned Projects at the Wilmington Site (Modified from GLE, 2008)
4-134 

1 in the area including the Titan Cement plant. Other developments include several new housing 

2 complexes. The construction and operation of the plant would alter the current land use of 

3 mixed pine forest, however, it would not be expected to affect land use in the surrounding area. 

4 Therefore, cumulative impacts on land use are expected to be SMALL. 

5 

6 4.3.2 Historic and Cultural Resources 

7 

8 The NRC has concluded that the impacts of constructing and operating the proposed 

9 GLE Facility could range from SMALL to MODERATE on historic and cultural resources. 

10 Cumulative impacts on historic and cultural resources can result from the incremental loss of 

11 unique site types. It is unclear what, if any, historic and cultural resource types would be 

12 affected by the proposed action. Site types known to exist in the vicinity of the project area 

13 contain evidence of Middle Woodland Cultures as well as other prehistoric sites of unknown 

14 age. Historic remains are also found in the vicinity dating to the colonial periods as well as later 

15 American era sites. Without knowing the full range of sites that could be impacted by the 

16 proposed action, it is unclear if cumulative impacts could result. However, most impacts on 

17 cultural resources would occur during preconstruction activities, because the majority of ground18 disturbing activities would occur at this time. The security-related feature discussed in Appendix 

19 H could impact several NRHP-eligible sites. However, because the proposed action is situated 

20 in a different location and is not expected to affect the NRHP-eligible sites that could be affected 

21 by the security-related feature, the proposed action is expected to have little incremental impact 

22 in combination with the security-related feature. In the event that sites are found, proper 

23 mitigation would be developed by GLE in consultation with the North Carolina SHPO. 

24 Cumulative impacts could range from SMALL to MODERATE. 

25 

26 4.3.3 Air Quality 

27 

28 As discussed in Section 3.5.3, New Hanover County, in which the proposed GLE Facility would 

29 be located, and neighboring Brunswick and Pender Counties, are currently designated as being 

30 in attainment for all criteria pollutants (40 CFR 81.334). 

31 

32 As discussed in Section 4.2.4.2, potential incremental air quality impacts of the proposed 

33 GLE Facility would be SMALL and localized. Accordingly, the proposed GLE Facility operations 

34 would make a small contribution to cumulative impacts for other actions planned in the 

35 New Hanover County. In addition to the proposed GLE Facility, a number of onsite and offsite 

36 projects are planned in the New Hanover County as discussed below (GLE, 2008). 

37 

38 Additional projects planned at the Wilmington Site include the Advanced Technology Center 

39 (ATC) II complex and the Tooling Development Center. These projects would not use 

40 radioactive materials or include manufacturing operations. Neither of the projects would be a 

41 major source of air emissions as defined under EPA or NCDAQ air permit requirements. 

42 Emission sources for these projects would be limited to small natural gas-fired boilers for space 

43 heating, emergency diesel generators, and other small operating units. 

44 

45 As an offsite industrial development, the Carolinas Cement Company LLC, has submitted an air 

46 permit application to construct a new Portland cement manufacturing plant on 757-hectare 

47 (1868-acre) parcel, which is located about 10 kilometers (6 miles) east-northeast of the 

48 proposed GLE Facility (EQM, 2008). Per the “potential to emit” section in the air permit 
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1 application, the facility can be classified as a major source. This plant would also emit toxic air 

2 pollutants (TAPs) including a trace amount of fluorides. Air dispersion modeling indicated that 

3 maximum concentrations are less than applicable ambient air quality standards and all 

4 maximum impacts occurred within a few kilometers of the facility boundaries. Potential 

5 cumulative impacts in public health associated with fluoride emissions are discussed in 

6 Section 4.3.8. 

7 

8 Another offsite development is new River Bluffs residential and mixed-use project planned on 

9 96 hectares (237 acres) bounded by the Wilmington Site’s southern boundary, I-140, and 

10 Northeast Cape Fear River. This project would not include any large stationary sources, and 

11 thus, would not be considered as a major source of criteria pollutants under EPA or NCDAQ air 

12 permit requirements. This project along with three proposed projects at the Wilmington Site 

13 could draw more automobiles and trucks on Castle Hayne Road (NC 133) and I-140, and thus 

14 increase air emissions along these routes. 

15 

16 Overall, all of these projects planned in the New Hanover County would increase air emissions 

17 over the current levels. However, incremental impacts of individual projects would be predicted 

18 to be limited to the immediate vicinity of their property lines, and thus, would not be additive due 

19 to the distances between them. It is unlikely that potential impacts from all of these projects 

20 combined would be high enough to significantly deteriorate ambient air quality or reverse 

21 current attainment status. Accordingly, potential cumulative impacts on ambient air quality in 

22 New Hanover County would be expected to be SMALL. 

23 

24 4.3.4 Geology and Soils 

25 

26 Two other construction projects planned for the Wilmington Site could result in 60 additional 

27 acres of disturbed land. These projects are the ATC II complex and the Tooling Development 

28 Center. Construction impacts would involve activities similar to those of the proposed 

29 alternative, namely clearing, grading, and excavation for building foundations and a stormwater 

30 detention pond. Best management practices would avoid or limit the impact on soil. 

31 Operational impacts on soil would be negligible. Preconstruction activities at the proposed GLE 

32 Facility site would create a similar situation in terms of disturbed land, with approximately 

33 91 hectares (226 acres) of cleared, regraded land. Proposed developments in the Wilmington 

34 area include a cement plant 32 kilometers (20 miles) upstream of the site, and several 

35 residential developments, including a 600-lot development with nursing home facilities, 

36 proposed for siting adjacent to the Wilmington Site’s south boundary (New Hanover 

37 County, 2009a). A speculative possibility is 1000 acres of mixed development near the 

38 Wilmington Site, east of Castle Hayne Road (New Hanover County, 2009a). In these offsite 

39 areas, BMPs are expected to be required by New Hanover County to control soil erosion (New 

40 Hanover County, 2007). 

41 

42 Geologic resources are not expected to be impacted by Wilmington-area activities. Cumulative 

43 impacts on soil from the proposed action and the additional construction projects are expected 

44 to be SMALL due to county involvement, presumed BMPs, and schedules that likely are not all 

45 simultaneous. 

46 
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1 4.3.5 Water Resources 

2 

3 Other facilities in New Hanover County are permitted to discharge to the Northeast Cape Fear 

4 River or the tributary Prince George Creek (EPA, 2009b). These include municipal wastewater 

5 treatment plants and various industries. Discharges from these facilities have State oversight 

6 through the NPDES permitting system and reporting of monitoring results. 

7 

8 Two other new facilities at the Wilmington Site, the ATC II and the Tooling Development Center, 

9 would convey stormwater to wet detention basins en route to discharge to surface water bodies. 

10 These basins, as with the proposed facility’s basin, would have clay liners to limit the infiltration 

11 of stormwater to the groundwater system. The construction of the ATC II would not coincide 

12 with the proposed GLE Facility, so impacts that arise from disturbed ground, such as turbidity 

13 and sediment loading, would not occur from both sites simultaneously. The Tooling 

14 Development Center’s construction runoff would run through wooded land, which would provide 

15 sediment attenuation beyond that provided by following BMPs. 

16 

17 As described in Section 4.3.4, offsite development for residential and industrial purposes is 

18 expected to occur, resulting in additional disturbed land. The timing of possible construction is 

19 unknown, but it could provide cumulative detrimental effect of turbidity and sediment load to the 

20 Northeast Cape Fear River. Wastewater effluent and stormwater effluent flowing to the river 

21 would increase once any residential community or industrial facility was built. Surface water 

22 monitoring stations in between the Wilmington Site and the proposed cement facility would 

23 provide a basis for determining the relative impact of the site. Enforced adherence to county24 level ordinances regarding erosion control and stormwater management (e.g. New Hanover 

25 County, 2007; New Hanover County, 2009c) would limit the impact of new developments. 

26 

27 Effective in April 2008, the Wilmington Site’s treated sanitary wastewater is used in processes 

28 and as makeup water for its cooling tower systems, rather than discharged at Outfall 002. After 

29 reuse, wastewater is treated at the Wilmington Site’s final process lagoon, and the effluent is 

30 discharged to the effluent channel at Outfall 001. The low hardness of the treated sanitary 

31 wastewater increases the efficiency of Wilmington Site cooling towers. This reuse of water 

32 decreases the need for pumping of groundwater for process needs. The relative increase in 

33 groundwater pumping for the proposed GLE Facility includes 11,000 gallons per day additional 

34 for potable water and 75,000 gallons per day additional for process water (GLE, 2008). 

35 However, the net cumulative amounts of groundwater pumping, including proposed site facilities 

36 ATC II and Tooling Development Center, and also factoring in the reuse of treated sanitary 

37 effluent, are an increase of 29,500 gallons per day for potable water, and a decrease of 

38 44,600 gallons per day for process water (GLE, 2008). While appreciable, the potable water 

39 need is small compared to the current groundwater withdrawal at the site of 656,640 gallons per 

40 day (see Section 3.7.4.2), a rate that has been sustained over a long period of time. 

41 

42 Based on the potential impacts on surface water that are controlled by the NPDES permitting 

43 and county ordinances, and based on anticipated groundwater withdrawals that are not 

44 significant, the overall cumulative impact on water resources is anticipated to be SMALL. 

45 
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1 4.3.6 Ecology 

2 

3 Many of the natural terrestrial and wetland habitats of New Hanover County have been 

4 modified, fragmented, or replaced by commercial, residential, and industrial developments 

5 (including silviculture and agriculture) (LeBlond and Grant, 2003). Similarly, extensive areas of 

6 natural upland and wetland forests on the Wilmington Site have been modified to pine 

7 plantations and operational (industrial) areas. The proposed GLE Facility, other projects to be 

8 developed on the Wilmington Site (i.e., the ATC II complex, the Tooling and Development 

9 Center, and a security-related feature discussed in Appendix H), and unrelated projects to be 

10 constructed near the Wilmington Site (e.g., residential, industrial, and commercial 

11 developments) would contribute to the cumulative impact to ecological resources of the county 

12 (GLE, 2008; New Hanover County, 2009a). Overall, cumulative impacts on ecological 

13 resources from the proposed action in combination with the security-related feature discussed in 

14 Appendix H are SMALL. Impacts from the other projects to be developed on or near the 

15 Wilmington Site are discussed in the following paragraphs. 

16 

17 Impacts on ecological resources from construction of the ATC II complex and the Tooling and 

18 Development Center projects would result from activities similar to those for preconstruction and 

19 construction activities for the proposed GLE Facility, namely site clearing and grading. The 

20 ATC II complex has impacted about 8.4 hectares (20.8 acres) of pine forest and less than 

21 0.01 hectare (0.01 acre) of pine-hardwood forest; while the Tooling and Development Center 

22 would impact about 0.1 hectare (0.3 acre) of pine forest, 2.9 hectares (7.2 acres) of pine23 hardwood forest, and 2.6 hectares (6.4 acres) of pine plantation forest (GLE, 2009e). As 

24 discussed in Section 4.2.8.1, about 81 hectares (201 acres) of habitat would be impacted by 

25 preconstruction and construction activities for the proposed GLE Facility. The majority of this 

26 (65 hectares [160 acres]) would be pine plantation, pine forest, or pine-hardwood forest. 

27 Overall, these three projects would change over 79 hectares (195 acres) of these forest habitat 

28 types on the Wilmington Site to operations area habitat (e.g., buildings, other facilities, and 

29 landscaped lawns). An additional 1.2 hectares (3 acres) of alluvial, pocosin/bay, and swamp 

30 forest would be impacted by the proposed project (Table 4-4, Section 4.2.8.1). The loss of 

31 forested habitat from the three construction projects within the Wilmington Site would be more 

32 than 20 percent greater than from the proposed GLE Facility alone; and would total about 

33 15.5 percent of the forest habitat on the Wilmington Site. Overall, the cumulative impacts on 

34 vegetation on the Wilmington Site from preconstruction activities for the proposed GLE Facility 

35 and construction of the ATC II complex and the Tooling and Development Center would be 

36 MODERATE. The contribution to cumulative impacts from the remaining construction of the 

37 proposed GLE Facility and operation of the three facilities would be SMALL. 

38 

39 Negligible direct impacts on wetlands within New Hanover County in general or specifically on 

40 the Wilmington Site are expected from any of the proposed construction projects on the 

41 Wilmington Site (the access road to the proposed GLE Facility may cause the loss of up to 

42 0.021 hectare (0.052 acre) of jurisdictional wetlands and 0.02 hectare (0.06 acre) of an isolated 

43 wetland); while indirect (but mitigable) impacts on wetlands from erosion and sedimentation may 

44 occur from the proposed GLE Facility and the ATC II complex (GLE, 2008; GLE, 2009e; 

45 GLE, 2009f). Past drainage of over 120 hectares (298 acres) of wetlands occurred on the 

46 Wilmington Site; while over 198 hectares (490 acres) of wetlands would be impacted by the 

47 proposed cement manufacturing plant and quarry to be located east of the Town of Castle 

48 Hayne (Benjamin, 2008). The contribution of the proposed GLE Facility, ATC II Complex, and 
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1 the Tooling and Development Center to cumulative impacts on wetlands within New Hanover 

2 County and on the Wilmington Site would be SMALL. 

3 

4 No environmentally sensitive areas occur within the proposed GLE Facility area. Any indirect 

5 impacts on environmentally sensitive areas from preconstruction activities, construction, and 

6 operation of the proposed GLE Facility would be SMALL (Section 4.2.8). Therefore, any 

7 cumulative impacts on environmentally sensitive areas due to the proposed GLE Facility would 

8 be SMALL. 

9 

10 Impacts on wildlife from construction and operation of the ATC II complex and the Tooling and 

11 Development Center would be similar to those discussed for the proposed GLE Facility 

12 (Section 4.2.8). The main impacts on wildlife that occur from a construction project are habitat 

13 disturbance (i.e., habitat loss, alteration, and fragmentation). Habitat fragmentation would be 

14 potentially less for the ATC II complex and Tooling and Development Center, as they would be 

15 more closely situated within the main operations area in the Eastern Site Sector of the 

16 Wilmington Site than would the proposed GLE Facility. Past actions that have impacted wildlife 

17 habitat on the Wilmington Site have involved primarily the drainage of over 120 hectares 

18 (298 acres) of forested wetlands, and alteration of natural habitats (e.g., pine and pine19 hardwood forests) for pine plantations, power line corridors, or operations areas. These habitat 

20 alterations have affected 255 hectares (631 acres), nearly 39 percent, of the Wilmington Site 

21 (GLE, 2008). Overall, the cumulative impacts on wildlife on the Wilmington Site from 

22 preconstruction activities for the proposed GLE Facility and construction of the ATC II complex 

23 and the Tooling and Development Center would be MODERATE. The contribution to 

24 cumulative impacts from the remaining construction of the proposed GLE Facility and operation 

25 of the three facilities would be SMALL. 

26 

27 As discussed in Section 4.3.5, cumulative impacts on water resources are expected to be 

28 SMALL. As a result, cumulative impacts on aquatic biota due to the proposed GLE Facility 

29 would also be SMALL. 

30 

31 Federally threatened and endangered species are not known to occur in the area of the 

32 proposed ATC II complex and the Tooling and Development Center (GLE, 2008). Therefore, 

33 cumulative impacts on Federally threatened and endangered species from these facilities and 

34 the proposed GLE Facility would be SMALL. Similarly, cumulative impacts on a number of the 

35 Federal species of concern or State-listed species that occur within New Hanover County would 

36 be SMALL, because they are not expected to inhabit the areas within which these three facilities 

37 would occur. For those species that may be present within areas that would be impacted by 

38 one or more of these facilities (i.e., those species assessed in Section 4.2.8.1), cumulative 

39 impacts from preconstruction activities for the proposed GLE Facility and/or construction of the 

40 other two facilities would be SMALL to MODERATE, depending on how many individuals could 

41 be impacted and possible mitigation measures that would be undertaken to protect those 

42 individuals. Cumulative impacts from remaining GLE construction and from the operation of all 

43 three projects to those species would be SMALL. 

44 

45 4.3.7 Transportation 

46 

47 The additional 300 to 400 workers for the proposed GLE Facility are about a 10 percent to 

48 15 percent increase from the 2800 workers currently employed at the Wilmington Site. 
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1 Furthermore, approximately 1000 more employees (GLE, 2008) may be added to the site with 

2 the addition of the ATC II complex and the Tooling Development Center noted in Section 4.3. 

3 However, the additional 1000 workers would be using the existing site entrances, not the one to 

4 be dedicated for GLE Facility use. 

5 

6 A foreseeable event in the vicinity of the site is a planned retirement community project that 

7 would use Chair Road, which intersects Castle Hayne Road about one-quarter mile south of the 

8 I-140 interchange (GLE, 2008). This project is anticipated to generate 3700 average daily trips 

9 in the local area. Combined with the increased employment at the Wilmington Site, the local 

10 incremental transportation impacts associated with the construction and operation of the 

11 proposed GLE Facility are anticipated to be MODERATE as the annual average daily trips could 

12 increase approximately 50 percent (about 1000 from GLE; 2000 from ATC II and the TDC; 

13 3700 from the retirement community) from the current value of 12,000 on Castle Hayne Road 

14 near the site entrance. 

15 

16 Approximately 2086 radioactive material shipments annually to or from the Wilmington Site 

17 would be added in support of the proposed GLE Facility (GLE, 2008). These shipments would 

18 roughly triple the number of radioactive material shipments occurring at the site, with about 996 

19 annual shipments currently supporting site activities (GLE, 2009a). The additional radiological 

20 impact on those in the vicinity of the additional shipments would be SMALL. If the same person 

21 were to be present for all current shipments, that person would receive approximately 

22 0.01 millisievert per year (1 millirem per year) from these shipments if they were by the road 

23 (such as a security guard) 2 meters (6.6 feet) from the side of each shipment as it passed by at 

24 a speed of 24 kilometers per hour (15 miles per hour). That same person would only receive 

25 approximately 0.002 millisievert per year (0.2 millirem per year) from the GLE shipments 

26 because the expected external dose rates are much lower on average than those from current 

27 operations at the site. Thus, any expected exposure would only increase approximately 

28 20 percent at the most over current conditions, despite three times the number of current 

29 shipments. 

30 

31 4.3.8 Public and Occupational Health 

32 

33 This section describes the cumulative impacts on public and occupational health associated 

34 with preconstruction activities, construction, and operation of the proposed GLE Facility on the 

35 Wilmington Site in combination with other past, present or foreseeable actions in the region that 

36 may affect the same resources as the proposed facility. The focus of the discussion is on 

37 radiological cumulative effects, and when appropriate, cumulative non-radiological effects are 

38 described. 

39 

40 4.3.8.1 Preconstruction and Construction Activities 

41 

42 The cumulative impacts associated with preconstruction and construction activities on public 

43 and occupational health could be received by some workers during the four-year overlap of the 

44 six-year construction period and the first years of operations. Accordingly, the potential annual 

radiological exposure to an onsite construction worker (3.85 × 10−4 45 millisievert per year 

[3.85 × 10−2 46 millirem per year]) would be well below the applicable dose limits for the general 

47 public of 1 millisievert per year (100 millirem per year) limit listed at 10 CFR 20.1301(a)(1). 
4-140 

1 During the preconstruction and construction activities, the potential dose to offsite personnel 

2 would not increase. 

3 

4 4.3.8.2 Operations 

5 

6 The cumulative radiological and non-radiological impact of uranium emissions from the 

7 proposed GLE Facility and existing FMO facility at the Wilmington Site were evaluated. 

8 

9 The yearly average TEDE to involved workers for 2003–2007 at the Wilmington Site from FMO 

10 operations varied from 0.50−0.75 millisievert per year (50−75 millirem per year), which is less 

11 than the applicable dose limits for the general public of 1 millisievert per year (100 millirem per 

12 year) limit listed in 10 CFR 20.1301(a)(1) and well below the 10 CFR 20.1201 limit of 

13 50 millisieverts (5000 millirem) for involved workers (i.e., workers in radiologically controlled 

14 areas) (NRC, 2009c). The average estimated dose to involved workers at the proposed 

15 GLE Facility is expected to be less than 1.5 millisieverts per year (150 millirem per year), which 

16 is well below the regulatory thresholds. Because the workers at the FMO facility and the 

17 proposed GLE Facility would not be working at both facilities, there would not be a cumulative 

18 exposure and even considering the overall collective dose to workers from existing conditions, 

19 and ongoing and anticipated operations at the Wilmington Site, the cumulative radiological 

20 impacts on workers from existing conditions and ongoing and anticipated site operations will be 

21 SMALL. 

22 

23 To assess the cumulative impacts on public health, the potential cumulative impacts of 

24 radiological air emissions from the existing FMO facility and the proposed GLE Facility were 

25 analyzed. Radiological releases to air from both facilities would be routinely monitored to 

26 ensure that releases are at or below the expected and regulated levels. In addition, the North 

27 Carolina Division of Radiation Protection collects data from a monitoring network of six ambient 

28 air samplers (GLE, 2008). The monitoring network is intended to assess whether the 

29 radiological air emissions from the FMO facility affect air quality in the surrounding area. Data 

30 are collected both onsite and in the area surrounding the Wilmington Site. A background 

31 ambient air monitoring station is located approximately 1.6 kilometers (1 mile) west of the site. 

32 The analytical results from air sampling stations closer to the plant are compared to background 

33 measurements (GLE, 2008). Based on the predicted emission rates associated with the FMO 

34 facility and the proposed GLE Facility, and on current data from the comprehensive site 

35 monitoring program, the cumulative radiological emissions would result in a SMALL impact on 

36 air quality. 

37 

38 Currently there is an insignificant contribution to direct radiation exposure at the site boundary 

39 from FMO facility operations. None of the TLDs used to monitor such exposures showed 

40 readings above the background exposure rate of 5 microroentgens per hour at the site 

41 boundary (GLE, 2009b). The additional storage planned for the proposed GLE Facility is 

42 expected to have a similar minor effect on the direct radiation exposure rate at the site 

43 boundary. Therefore, the cumulative impact from direct exposure to the public is expected to be 

44 SMALL. 

45 

46 The cumulative effect of operating the existing FMO facility and the proposed GLE Facility may 

47 result in some increase of dose at the fenceline of the Wilmington Site from air emissions. The 

48 estimated maximum dose due to air emissions from the FMO facility at the fenceline is 
4-141 

approximately 4 × 10−4

 millisievert per year (4 × 10−2 1 millirem per year) (Section 3.11.1.2). The 

2 operation of the proposed GLE Facility would introduce new source of radiological emissions. 

3 The estimated maximum dose due to air emissions from the proposed GLE Facility at the 

fenceline is 1.4 × 10−6

 millisievert per year (1.4 × 10−4 4 millirem per year) (Section 4.2.11.2). The 

5 estimated doses from both the FMO facility and proposed GLE Facility are far less than the 

6 applicable dose limits for the general public of 1 millisievert per year (100 millirem per year) limit 

7 listed at 10 CFR 20.1301(a)(1) and would result in a SMALL cumulative impact. 

8 

9 Non-radiological cumulative impacts on occupational and public health could accrue from the 

10 airborne emissions of UF6 and HF from the proposed GLE Facility (Section 4.2.11.2) in 

11 combination with those from the adjacent FMO facility. However, as noted in Section 4.2.11.2, 

12 the estimated emissions of these chemicals from the proposed GLE Facility would be well below 

13 levels of concern. Fluoride emissions from the FMO facility between 1995 and 2005 were 

14 typically a fraction of their permitted levels of 0.29 kilograms per day (0.63 pounds per day), 

15 while measured air concentrations were a small fraction of the recommended workplace 

16 exposure limit of 2.5 milligrams per cubic meter (NRC, 2009c). Additional fluoride emissions 

17 from the proposed GLE Facility are expected to be much lower than those from the FMO facility 

18 and would not materially increase the total levels of fluorides in the air onsite or at the site 

19 boundary. Fluoride emissions from the proposed Carolinas Cement facility, the only other 

20 significant potential source of fluoride emissions in the region, which would be located about six 

21 miles to the north, would not adversely impact ambient air quality outside the boundary of that 

22 plant, according to analysis prepared to support its permit application (EQM, 2008). Impacts 

23 from mercury emissions from the same facility would be minor and would not contribute to 

24 adverse health effects in the region, as discussed in Section 3.11.3.4. In addition, health 

25 impacts from mercury, a neurological toxin, would not combine cumulatively with those from HF, 

26 a respiratory irritant. Given the distance between the contributing facilities, the required fluoride 

27 emission permits for the facilities, and the relatively minor contributions of the proposed 

28 GLE Facility, the cumulative impacts of fluoride and other toxic chemical emissions in the region 

29 would be SMALL. 

30 

31 Uranium emissions, as UF6, from the FMO facility, evaluated in terms of radiological effects, 

32 were estimated be a tiny fraction of the applicable dose limit for members of the public 

33 (GLE, 2008). Because predicted uranium and HF emissions would produce air concentrations 

34 that are far below levels of health concern, it is expected that effects of chemical toxicity of 

35 uranium and HF from the facility would also be minor. Thus, the expected low-level uranium 

36 and HF emissions from the proposed GLE Facility would not contribute to material increases in 

37 public or worker exposure, while the cumulative effects of both uranium and HF emissions 

38 would be SMALL. 

39 

40 4.3.9 Waste Management 

41 

42 Potential average daily process and sanitary wastewater flow rates from existing facilities, the 

43 proposed GLE Facility, and potential future facilities at the Wilmington Site are summarized in 

44 Table 4-30. As shown in the table, the total site process and sanitary wastewater flow rates, 

45 without taking credit for reuse in the site cooling towers, are approximately 1,956,000 liters per 

46 day (516,200 gallons per day) and 236,000 liters per day (62,300 gallons per day), respectively, 

47 which are well below the NPDES permit levels of 6.8 million liters per day (1.8 million gallons 

48 
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Table 4-30 Cumulative Wastewater Generation at the Wilmington Site 

Total Average Daily Wastewater Flow 

Rate (gpd) 

Wilmington Site Wastewater Source Process 

Wastewater 

Sanitary 

Wastewater 

Combined 

Wastewater 

Flow Rate 

Existing Wilmington Site facilitiesa 476,200 33,300 509,500 

Proposed GLE Facilityb 35,000 10,500 45,500 

Other planned onsite projectsc 5000 18,500 23,500 

Total projected treated wastewater effluent 

(not including industrial reuse of treated 

sanitary wastewater effluent) 

516,200 62,300 578,500 

Effects of industrial reuse of treated effluent 

from the Wilmington Site sanitary 

wastewater treatment facilityd

−62,300e −62,300f −124,600 

Projected NPDES-permitted discharges of 

wastewaters to the onsite effluent channel 

453,900e 0f 453,900 

a

 Total averaged daily volumes based on measured flow for 2006. 

b

 Total averaged daily volumes based on estimated flow rates for GLE operations (see Table 4-23). 

c

 Total averaged daily volumes based on estimated flow rates for ATC II complex and Tooling 

Development Center. 

d

 Although the reuse of treated sanitary wastewater effluent from the Wilmington Site sanitary 

wastewater treatment facility as Site process water commenced in April 2008, it is included in the 

cumulative impacts assessment because it postdates the 2006 baseline set of conditions. e

 Because the treated sanitary wastewater effluent has such low hardness, its addition to the 

Wilmington Site cooling towers increases efficiencies. Each gallon of reuse water introduced into a 

cooling tower offsets 2 gallons of process makeup water, which reduces the amount of process water 

to be treated in the final process lagoons and discharged to the effluent channel. 

f

 The effluent reuse process water resulted in a switch away from discharge of treated sanitary 

wastewater effluent to the effluent channel, which flows to Unnamed Tributary #1 to Northeast Cape 

Fear River (Waters of the United States). The NPDES discharge permit remains valid should 

discharges of treated sanitary wastewater become necessary in the future. The effluent reuse process 

also reduces the requirement to withdraw groundwater to meet the Wilmington Site process-water 

requirement. 

Note: Total wastewater quantities presented in this table are lower than the process-water and potablewater demands due to consumptive losses. To convert gallons to liters, multiply by 3.8. 

Source: GLE, 2008. 

1 

2 per day) and 284,000 liters per day (75,000 gallons per day), respectively. Thus, cumulative 

3 impacts from wastewater generation would be SMALL. 

4 

5 Current disposal of hazardous and solid wastes from the Wilmington Site is expected to 

6 continue, and disposal of hazardous, nonhazardous solid, and solid LLRW from the proposed 

7 GLE Facility at appropriate facilities is shown in Section 4.2.12.2 to comprise a small fraction of 

8 the disposal rates and capacities at these disposal facilities. The majority of waste expected 

9 from the future ATC II complex and the Tooling Development Center at the Wilmington Site 
4-143 

1 would be municipal solid waste destined for disposal at the New Hanover County Landfill 

2 (GLE, 2008). Based on available capacities at LLRW and hazardous waste treatment and 

3 disposal sites in conjunction with the anticipated expansion of the New Hanover County Landfill 

4 (see Section 3.12.4.1), the cumulative impacts from hazardous and solid waste generation are 

5 anticipated to be SMALL. 

6 

7 4.3.10 Socioeconomics 

8 

9 Preconstruction and construction activities in the peak year would create 680 direct jobs at the 

10 facility site itself. An additional 3131 indirect jobs would be created in the ROI with the 

11 procurement of material and equipment and the spending of direct worker wages and salaries 

12 (Table 4-25). Facility construction would produce $139.8 million in income in the ROI. 

13 Beginning in 2013, start-up activities would create 200 direct jobs annually at the facility itself, 

14 with an additional 218 indirect jobs created in the ROI, producing $28.0 million in income in the 

15 ROI. During the period 2013 to 2016, construction and start-up activities would occur at the 

16 same time. Direct construction impacts during this period would vary from 485 direct workers, 

17 2718 indirect workers and $99.7 million in income in 2013, to 155 direct workers, 869 indirect 

18 workers and $31.9 million in income in 2016. The cumulative impact of construction and start19 up during this period would range from the creation of 685 direct and 2936 indirect jobs and 

20 $127.7 million in income in 2013, to 355 direct and 1087 indirect jobs and $59.9 million in 

21 income in 2016. 

22 

23 Operations activities beginning in 2017 would create 350 direct jobs at the facility site, with an 

24 additional 382 indirect jobs created in the ROI, and would constitute less than one percent of 

25 total ROI employment. Facility operations would produce $51.5 million in income in the ROI in 

26 2017. During 2017, construction and operations activities would occur at the same time. 

27 Facility construction would produce 136 direct, 762 indirect jobs and $28.0 million in income. 

28 The cumulative impact of construction and operations in 2017 would create 486 direct and 

29 1144 indirect jobs and $79.5 million in income. Compared to existing employment levels in the 

30 ROI, the economic impact of construction and operations activities associated with the proposed 

31 GLE Facility would be SMALL. 

32 

33 Construction would produce $1.7 million in direct State income taxes and $1.2 million in direct 

34 State sales taxes in the peak construction year, while start-up activities would produce 

35 $1.3 million in income taxes and $0.9 million in sales taxes annually, beginning in 2013 and 

36 continuing through 2017. During the period 2013 to 2016, construction and start-up activities 

37 would occur at the same time. Income taxes associated with construction activities during this 

38 period would range from $0.4 million to $1.2 million, while sales taxes would range from $0.3 

39 million to $0.9 million. The cumulative impact of construction and start-up activities between 

40 would therefore range from $1.7 million and $2.5 million in income taxes, and between 

41 $1.2 million and $1.8 million in sales taxes. Operations would produce $2.3 million in direct 

42 State income taxes and $1.7 million in direct State sales taxes. During 2017, construction and 

43 operations activities would occur at the same time, with a total of $2.6 million in income taxes 

44 and $1.9 million in sales taxes produced by the proposed GLE Facility. Compared to current 

45 State total income and sales tax revenues, the impact of constructing and operating the 

46 proposed GLE Facility on sales and income taxes would be SMALL. 

47 
4-144 

1 Given the duration and scale of activities and the likelihood of local worker availability in the 

2 required occupational categories, construction of the proposed GLE Facility would require some 

3 in-migration of workers and their families from outside the ROI, with between 299 and 

4 598 persons moving into the ROI during the peak year of construction (2012) and between 

5 92 and 120 persons migrating into the area during start-up activities. During the period 2013 to 

6 2016, construction and start-up activities would occur at the same time. In-migration associated 

7 with construction activities during this period would vary from 207 and 304 in 2013 and between 

8 141 and 172 in 2016. Cumulatively, between 99 and 424 persons would move into the ROI in 

9 2013 and between 233 and 292 persons in 2016. Between 161 and 210 persons would move 

10 into the ROI during the first year of full operations (2017). During 2017, construction and 

11 operations activities would occur at the same time, with a total of between 167 and 194 persons 

12 in-migrating into the ROI in that year. Although in-migration may potentially impact local 

13 housing markets, the relatively small number of in-migrants and the availability of temporary 

14 accommodation (hotels, motels, and mobile home parks) would mean that the impact of facility 

15 construction on the number of vacant rental housing units is not expected to be large. Between 

16 87 and 173 rental units in the ROI would be required during construction and between 27 and 

17 47 rental units would be required during start-up activities. During the period 2013 to 2016, 

18 construction and start-up activities would occur at the same time. The cumulative demand for 

19 rental housing during the period 2013 to 2016, when construction and start-up activities would 

20 occur at the same time, would range between 99 and 424 units in 2013 and between 233 and 

21 292 units in 2016. Between 47 and 61 owner-occupied units would be required during 

22 operations. These occupancy rates would represent less than one percent of the vacant rental 

23 units expected to be available in the ROI; the impact of GLE Facility construction and operations 

24 on housing would, therefore, be SMALL. 

25 

26 In addition to the potential impact on housing markets, in-migration would also affect local27 community educational and medical services employment to maintain existing levels of service. 

28 These staffing increases would represent less than one percent of community service 

29 employment in each employment category expected in the ROI; the impact of GLE Facility 

30 construction and operations on community educational and medical service employment would, 

31 therefore, be SMALL. 

32 

33 Two other projects are currently under construction or planned at the Wilmington Site, in 

34 addition to the proposed GLE Facility (GLE, 2008). The ATC II complex is anticipated to employ 

35 approximately 500 workers once in operation. The Tooling Development Center, construction of 

36 which is projected to occur in 10 years, would employ approximately 500 workers annually when 

37 operational. Construction of the ATC II complex will be completed before construction of the 

38 proposed GLE Facility is under way, while the timing, workforce requirements, and worker 

39 residential locations of the Tooling Development Center would overlap with the operation of the 

40 proposed GLE Facility. 

41 

42 Elsewhere in the ROI area, additional projects anticipated include the Carolinas Cement 

43 Company LLC, proposal to construct a cement plant in New Hanover County, which would 

44 employ approximately 800 workers. Operations are expected to begin in 2013 (GLE, 2008), 

45 overlapping slightly with the construction phase of the proposed GLE Facility. Assuming 

46 in-migration of workers for this project would occur at the same level as would likely occur with 

47 the proposed GLE Facility, relatively SMALL annual increases are expected in ROI population, 

48 and would not significantly increase employment in medical services and public safety. Housing 
4-145 

1 growth trends in New Hanover County and plans for new school construction suggest that 

2 additional demands on these resources in the ROI resulting from the Carolinas Cement project 

3 construction would be SMALL. The cumulative socioeconomic impact of the construction of the 

4 proposed GLE Facility and the Carolinas Cement Company plant are anticipated to be SMALL 

5 to MODERATE. 

6 

7 4.3.11 Environmental Justice 

8 

9 Although minority and low-income populations occur in the vicinity of the Wilmington Site (see 

10 Section 3.14), construction and operation of the proposed GLE Facility and other proposed 

11 projects onsite and offsite would not affect such populations disproportionately. Accordingly, 

12 there would be no cumulative impacts on minority and low-income populations. 

13 

14 4.4 Impacts of the No-Action Alternative 

15 

16 As presented in Section 2.2 of this draft EIS, the no-action alternative would be to not construct, 

17 operate, and decommission the proposed GLE Facility in Wilmington, North Carolina. As 

18 discussed in Section 1.4.1 and the introduction to Section 4.2, the NRC has granted an 

19 exemption for GLE to conduct certain preconstruction activities in advance of a formal licensing 

20 decision. If the NRC does not grant a construction and operating license for the proposed 

21 GLE Facility, approximately one year of preconstruction activities will likely have already 

22 occurred (preconstruction activities are expected to begin in early 2011, but construction cannot 

23 begin until a licensing decision is made, which is not expected to occur until June 2012). It 

24 follows that the impacts associated with these preconstruction activities, as described in 

25 Section 4.2, will also have occurred. There may be additional activities occurring at the site in 

26 the future under the no-action alternative that may have adverse or beneficial impacts on the 

27 environment. The impacts associated with these activities would depend on what GLE would 

28 decide to do with the site or any administrative buildings already constructed on the site. 

29 However, the impact conclusions presented in this section address the impacts of denying the 

30 license and do not include the impacts of preconstruction activities. 

31 

32 Utility customers would continue to depend on existing suppliers (e.g., existing uranium 

33 enrichment facilities, foreign sources, and the “Megatons to Megawatts” program) to fulfill 

34 uranium enrichment needs. In addition, new domestic supply sources are currently under 

35 construction (NEF and ACP) or planned and seeking a license from NRC (EREF). Current 

36 U.S. demand for low-enriched uranium is about 12 to 14 million SWU annually (EIA, 2008; 

37 EIA, 2009a). USEC is currently the only domestic supplier of enrichment services, providing 

38 enriched uranium to both domestic and foreign users. Existing USEC enrichment activities 

39 include operation of the aging Paducah Gaseous Diffusion Plant (GDP), the downblending of 

40 highly enriched uranium under the “Megatons to Megawatts” program that is managed by USEC 

41 and scheduled to expire in 2013, and the import of foreign-enriched product. By combining its 

42 domestic enrichment facilities and the downblending of foreign highly enriched uranium, USEC 

43 can provide for approximately 56 percent of the U.S. enrichment market needs (USEC, 2004) 

44 while foreign suppliers provide the remaining 44 percent. 

45 

46 As discussed in Section 1.3.1 of this draft EIS, three future domestic sources of enriched 

47 uranium supply are planned, and all three have applied to NRC for a license to construct and 

48 operate. The efforts by these prospective suppliers for technology research and development, 
4-146 

1 licensing, construction, and operation of their facilities are unrelated to the proposed 

2 GLE Facility. 

3 

4 Under the no-action alternative, there is only one currently operating domestic enrichment 

5 facility, the Paducah GDP, which could continue to serve as a source of low-enriched uranium 

6 into the foreseeable future or until replaced by one the new or planned facilities. The “Megaton 

7 to Megawatts” program managed by USEC would continue to provide low-enriched uranium 

8 until 2013. After cessation of this program in 2013 – if not renewed by the United States and 

9 Russia – the availability of low-enriched uranium through the downblending of highly enriched 

10 uranium is uncertain. Reliance on only one domestic source for enrichment services could 

11 result in disruptions to the supply of low-enriched uranium, and consequently, to reliable 

12 operation of U.S. nuclear energy production, should there be any disruptions to foreign supplies 

13 and/or the operations of domestic suppliers (i.e., failure to construct and operate the ACP, NEF, 

14 or EREF and failure to extend the “Megatons to Megawatts” program beyond 2013). 

15 

16 If the license is denied, nuclear electricity generation using the enriched uranium from the 

17 proposed GLE Facility could be replaced with other power generation sources (e.g., fossil-fuel 

18 plants), or enriched uranium could be provided by sources constructed at other locations 

19 (such as ACP, NEF, or EREF). Therefore, impacts similar to those quantified in this draft EIS 

20 would simply occur at a different location. 

21 

22 4.4.1 Land Use 

23 

24 Under the no-action alternative, preconstruction activities would have occurred. The discussion 

25 of impacts from preconstruction activities for land use is presented in Section 4.2.1.1. The 

26 baseline for the no-action assessment is a cleared property with utilities and administrative 

27 structures extant. 

28 

29 Under the no-action alternative, the proposed GLE Facility would not be licensed, and therefore, 

30 not constructed on the land that was cleared and prepared for the facility. Because denying the 

31 license would not preclude other uses of the land, the land use impacts would be SMALL. 

32 

33 4.4.2 Historic and Cultural Resources 

34 

35 Under the no-action alternative, preconstruction activities would have occurred, but the 

36 proposed GLE Facility would not be constructed or operated. The discussion of the impacts 

37 resulting from preconstruction activities on historic and cultural resources is provided in 

38 Section 4.2.2.1. 

39 

40 Because denying the license would not result in additional land disturbance at the Wilmington 

41 Site, anticipated impacts on historic and cultural resources in New Hanover County from the no42 action alternative are expected to be SMALL. If an alternate site was chosen for construction of 

43 the enrichment plant, a consideration of the historic and cultural resources at the alternate 

44 location would be reviewed in consultation with the appropriate SHPO. 

45 
4-147 

1 4.4.3 Visual and Scenic Resources 

2 

3 Under the no-action alternative, preconstruction activities would have occurred. The baseline 

4 for the no-action alternative is a property cleared of vegetation with utilities and support 

5 structures in place. A discussion of the impacts of preconstruction activities on visual resources 

6 is provided in Section 4.2.3.1. 

7 

8 The vegetation screen that surrounds the property would be intact under the no-action 

9 alternative. Because denying the license would not introduce any additional visual disturbance 

10 at the Wilmington Site, local visual impacts of the no-action alternative are expected to be 

11 SMALL. 

12 

13 4.4.4 Air Quality 

14 

15 Under the no-action alternative, air emission sources for the existing Wilmington Site would 

16 continue to operate according to the allowable emission limits and emission control 

17 requirements set forth in the current two “synthetic minor” operating permit issued by the 

18 North Carolina Division of Air Quality (NCDAQ). As discussed in Section 3.5.3.1, point source 

19 emissions from current operations at the Wilmington Site are negligible compared with the 

20 annual total emissions in New Hanover County. 

21 

22 If the license is denied, nuclear electricity generation using the enriched uranium from the 

23 proposed GLE Facility would be replaced with other power generation sources, e.g., fossil-fuel 

24 plants. This could increase a substantial amount of criteria pollutants, and HAPs, emissions 

25 elsewhere and contribute to air pollution, acid rain, and visibility degradation. Use of power 

26 generation sources could also lead to GHG emissions elsewhere. 

27 

28 Because denying the license would not directly result in local air quality impacts from additional 

29 vehicle emissions, land disturbance, or facility emissions, potential impacts of no-action 

30 alternative on ambient air quality would be expected to be SMALL. 

31 

32 4.4.5 Geology and Soils 

33 

34 Under the no-action alternative, preconstruction activities such as grading, wet retention basin 

35 construction, and drainage changes would have occurred at the proposed GLE Facility site and 

36 along site roads. If a no-action alternative is selected, additional ground-disturbing activities, 

37 such as excavation for foundations and for buried infrastructure may or may not take place 

38 (depending on GLE’s future plan for the site). Erosion control measures on the land disturbed 

39 during preconstruction (such as seeding) would limit soil loss due to erosion. 

40 

41 Because denying the license would not lead to additional land disturbance, the no-action 

42 alternative would be expected to have SMALL geological or soil impacts. 

43 

44 4.4.6 Water Resources 

45 

46 As described in Section 4.4.5, preconstruction would require measures for control of soil erosion 

47 on land disturbed during preconstruction activities. By taking steps to minimize erosion, the 
4-148 

1 impact on turbidity of surface water can likewise be limited. Additional water use may or may 

2 not occur under the no-action alternative (depending on GLE’s future plan for the site). 

3 

4 Under the no-action alternative, and assuming another site development is not pursued, 

5 groundwater use would not increase. Groundwater quality would not be reduced at the 

6 GLE site, but rather, would be gradually improved sitewide due to continued use and 

7 improvement of the site remediation systems and also due to some degree of natural 

8 attenuation. 

9 

10 Because denying the license would not directly result in additional water use or changes to 

11 surface or groundwater quality, the overall impact of the no-action alternative on water 

12 resources is expected to be SMALL. 

13 

14 4.4.7 Ecological Resources 

15 

16 Under the no-action alternative, preconstruction activities would have occurred. The discussion 

17 of impacts on ecological resources resulting from preconstruction activities is presented in 

18 Section 4.2.8.1. The baseline for the no-action alternative is an area cleared of vegetation with 

19 administrative structures, utilities, and north access road in place. 

20 

21 Because denying the license would not result in additional land disturbance on the Wilmington 

22 Site, anticipated impacts on ecological resources from the no-action alternative are expected to 

23 be SMALL. If an alternative site was chosen for construction and operation of the enrichment 

24 plant, impacts on ecological resources at the alternative site would be evaluated in a separate 

25 NEPA document. 

26 

27 4.4.8 Noise 

28 

29 Under the no-action alternative, noise levels associated with operations at the existing 

30 Wilmington Site would be expected to remain unchanged. As discussed in Section 3.9, a sound 

31 survey indicated that noise levels at the nearest residences were well below the New Hanover 

32 County Noise Ordinance and EPA guideline. 

33 

34 Because denying the license would not directly result in additional noise sources on the site, 

35 potential noise impacts of no-action alternative on surrounding communities would be expected 

36 to be SMALL. 

37 

38 4.4.9 Transportation 

39 

40 Under the no-action alternative, preconstruction activities would have occurred and there would 

41 be no additional traffic entering and leaving the Wilmington Site from operation of the proposed 

42 GLE Facility. Additional national impacts from the transportation of radioactive materials to and 

43 from the Wilmington Site would also not occur in the short term. 

44 

45 Should the nation’s need for enriched uranium continue to increase, the demand would need to 

46 be satisfied using existing or new capacity. In such a case, local traffic impacts at a similar 

47 existing facility may increase, or additional traffic similar to that estimated for the proposed 

48 GLE Facility would be added to another area, which may or may not have the same impacts 
4-149 

1 depending on the existing road network and traffic patterns. National impacts from radioactive 

2 material transportation would also increase, depending on the nation’s demand for additional 

3 enriched product. There is also the potential for increased traffic supporting the FMO facility, 

4 should additional enriched product be needed to satisfy increased demand for reactor 

5 assemblies. 

6 

7 Because denying the license would not directly result in additional traffic on the site, potential 

8 impacts of the no-action alternative on transportation resources near the Wilmington Site are 

9 expected to be SMALL. 

10 

11 4.4.10 Public and Occupational Health 

12 

13 Under the no-action alternative, impacts on workers associated with preconstruction activities 

14 (as discussed in Section 4.2.11.1) would have occurred, while impacts due to construction 

15 would not occur. Exposure to the public outside the site boundary would remain the same as 

16 described in Section 3.11. Any additional impacts from the use of the site by GLE after denial of 

17 a license would not be part of the proposed action. 

18 

19 Other domestic enrichment capacity might be constructed instead of the proposed GLE Facility 

20 to meet national needs. The public and occupational health impacts of any new facility would 

21 be expected to be appropriately controlled through engineering design, best management 

22 practices, and regulatory controls similar to those described in this draft EIS for the proposed 

23 GLE Facility. Therefore, the public and occupational health impacts of the no-action alternative 

24 would be expected to be SMALL. 

25 

26 4.4.11 Waste Management 

27 

28 Under the no-action alternative, preconstruction activities would have occurred, the proposed 

29 GLE Facility would not be constructed or operated, and there would be no additional waste 

30 generated at the Wilmington Site beyond the waste generated by ongoing activities. 

31 

32 Should the nation’s need for enriched uranium continue to increase (e.g., at the FMO facility) 

33 due to increased demand for nuclear fuel assemblies, waste management impacts at 

34 enrichment facilities and the FMO facility would increase. Waste management impacts at new 

35 or existing facilities may be expected to be SMALL to MODERATE, depending on the amount of 

36 demand and the facility in question. 

37 

38 4.4.12 Socioeconomic Impacts 

39 

40 Under the no-action alternative, population and employment in the ROI (Brunswick County, 

41 New Hanover County, and Pender County) are expected to grow in accordance with current 

42 projections. Total population in the region is projected to be approximately 368,000 in 2010 and 

43 444,000 in 2020 (NCOSBM, 2009). Employment in Brunswick, Columbus, New Hanover, and 

44 Pender counties is projected to grow approximately 1.7 percent per year, from 150,648 workers 

45 in 2004 to 178,714 workers in 2014. Assuming growth continues at this rate after 2014, total 

46 employment would reach 198,005 by the year 2020 (NCOSBM, 2009). As discussed in 

47 Section 4.2.13, completion of preconstruction activities is not expected to have a noticeable 

48 effect on these trends or on county services. 
4-150 

1 

2 Because denying the license would not directly result in changes to current county services or 

3 growth projections, the socioeconomic impact of the no-action alternative is expected to be 

4 SMALL. 

5 

6 4.4.13 Environmental Justice 

7 

8 Under the no-action alternative, preconstruction activities with associated land clearing, 

9 equipment noise, and traffic impacts would occur. These effects are expected to be limited to 

10 the immediate vicinity of the proposed GLE Facility site. These impacts would not be 

11 disproportionately high and adverse to minority and low-income populations. 

12 

13 4.5 References 

14 

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44 

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24 

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36 

37 (DNFSB, 1999) Defense Nuclear Facility Safety Board. Letter from J. Conway to 

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6 

7 (DOE 2004b) U.S. Department of Energy. “Final Environmental Impact Statement for 

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11 

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16 

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20 

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23 

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27 

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31 

32 (EIA, 2009b) Energy Information Administration. “Frequently Asked Questions – Environment.” 

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34 

35 (EPA, 1974) U.S. Environmental Protection Agency. “Information on Levels of Environmental 

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39 

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44 

45 (EPA, 2003) U.S. Environmental Protection Agency. “User’s Guide to MOBILE6.1 and 

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17 

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21 

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28 

29 
5-1 

1 5 MITIGATION 

2 

3 This chapter addresses potential means to mitigate adverse environmental impacts from the 

4 proposed action as required by Appendix A of Title 10, Part 51, of the U.S. Code of Federal 

5 Regulations (10 CFR Part 51). Under Council on Environmental Quality regulation 

6 40 CFR 1500.2(f), Federal agencies shall, to the fullest extent possible, “use all practicable 

7 means consistent with the requirements of the National Environmental Policy Act (NEPA) and 

8 other essential considerations of national policy to restore and enhance the quality of the human 

9 environment and avoid or minimize any possible adverse effects of their actions on the quality of 

10 the human environment.” The Council on Environmental Quality regulations defines mitigation 

11 to include activities that (1) avoid the impact altogether by not taking a certain action or parts of 

12 an action; (2) minimize impacts by limiting the degree or magnitude of the action and its 

13 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 This definition has been used in identifying potential mitigation measures. As such, mitigation 

17 measures are those actions or processes (e.g., process controls and management plans) that 

18 would be implemented to control and minimize potential adverse impacts from construction and 

19 operation activities for the proposed Global Laser Enrichment (GLE) Facility. 

20 

21 General Electric (GE)-Hitachi Global Laser Enrichment LLC (GLE) must comply with applicable 

22 laws and regulations, including obtaining all appropriate construction and operating permits. A 

23 complete discussion of applicable laws and regulations is included in Chapter 1 of this draft 

24 Environmental Impact Statement (EIS). The mitigation measures proposed by GLE, many of 

25 which are compliance related, are discussed in Section 5.1 (GLE, 2008). 

26 

27 Based on the potential impacts identified in Chapter 4 of this draft EIS (Environmental Impacts), 

28 the U.S. Nuclear Regulatory Commission (NRC) staff has identified additional potential 

29 mitigation for the proposed GLE Facility. These mitigation measures are described in 

30 Section 5.2. 

31 

32 The proposed mitigation measures provided in this chapter do not include environmental 

33 monitoring activities. Environmental monitoring activities are described in Chapter 6 of this draft 

34 EIS. 

35 

36 5.1 Mitigation Measures Proposed by GLE 

37 

38 GLE identified mitigation measures in its Environmental Report (ER) (GLE, 2008) that would 

39 reduce the environmental impacts associated with preconstruction activities and the proposed 

40 action. Table 5-1 lists the mitigation measures proposed for each impact area. Because many 

41 of GLE’s proposed mitigation measures apply to preconstruction and construction activities as 

42 well as facility operation, they are listed together in the table. 
5-2 

Table 5-1 Summary of Mitigation Measures Proposed by GLE 

Impact Area Activity Proposed Mitigation Measures 

Land Use Land disturbance Use existing service road routes and utility rights-of-way 

(ROWs) to the fullest extent practicable to minimize the 

need for clearing additional wooded areas. 

Use existing wastewater treatment and solid waste 

management infrastructure to the fullest extent 

practicable to reduce the total area needed for 

construction and operation of the proposed facility. 

Historic and 

Cultural 

Resources 

Disturbance of 

prehistoric 

archaeological sites 

eligible for listing on 

the National Register 

of Historic Places

To prevent disturbance of site 31NH801, maintain 

conditions of the bank at the side of the existing gravel 

road unchanged from its current graded and vegetated 

state. 

Signs are posted to prevent unauthorized excavation. 

Visual and Scenic 

Resources 

Potential visual 

intrusions in the 

existing landscape 

character 

Locate the proposed facility in a sector of the Wilmington 

Site away from site boundaries bordering existing 

development along NC 133 and I-140. 

To the fullest width practicable, maintain the existing tree 

buffer along the northeast Wilmington Site boundary to 

limit visibility of the proposed facility structures and 

access road traffic from offsite viewpoints in nearby 

residential neighborhoods. 

Use exterior building colors and landscaping that would 

soften the visual impact of the proposed facility. 

Air Quality Fugitive dust and 

construction 

equipment emissions 

Water the facility site and unpaved roads to reduce dust. 

Remove dirt from truck tires by driving over a gravel pad 

prior to leaving the facility site or unpaved access road to 

avoid spreading sediments on paved roads. 

Cover trucks carrying soil and debris to reduce dust 

emissions from the back of trucks driving on roadways. 

Pave access road and parking lots as soon as 

practicable. 

Conduct uranium-enrichment operations inside an 

enclosed building using a closed-system process with no 

routine venting of process gases. 

Install and operate leak-detection monitors for process 

equipment. In the event a leak is detected due to an 

equipment component malfunction or other reason, 

safety interlocks will isolate the section of the process 

where the leak is detected, limiting the potential quantity 

of gaseous material that could be released inside the 

proposed facility operations building. 
5-3 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Air Quality (Cont.) Fugitive dust and 

construction 

equipment emissions 

(Cont.) 

Maintain process areas inside the operations building 

under continuous negative pressure relative to 

atmospheric pressure. In the event of a gaseous 

release in one of these process areas, the negative 

pressure conditions would prevent outflow of the air from 

the process areas, effectively containing the released 

gaseous material to the affected process area. 

Ventilate the operations building with a high-efficiency, 

multi-stage air emissions control system. Components 

of the air emissions control system planned for the 

operations building consist of high-efficiency particulate 

arresting (HEPA) filters for removal of solid particulate 

matter and activated carbon beds for adsorption of HF. 

Exhaust gases from this emission-control system would 

be vented to the atmosphere through a single stack. 

Implement a periodic inspection and maintenance 

program for uranium hexafluoride (UF6) cylinders stored 

in outdoor areas. 

Burn low-sulfur fuel oil in the auxiliary diesel generators. 

Store organic solvents, paints, and other volatile organic 

compound–containing liquids in containers covered with 

tightly fitting lids. 

Geology and Soil 

Resources 

Soil disturbance and 

contamination 

Minimize the construction footprint to the extent possible. 

Engineer design plans that minimize soil disturbance 

during construction activities. 

If additional soil is necessary for construction purposes, 

use soils from onsite borrow pits that are accessible via 

existing roadbeds, to minimize disturbance to other 

areas of the Wilmington Site outside of the GLE study 

area. 

Manage construction activities so that only designated 

areas within the GLE study area are disturbed and so 

that no heavy equipment or construction operations are 

allowed to affect areas outside the study area unless 

specifically designated, such as potential use of existing 

onsite borrow areas. 

Use adequate containment methods during excavation 

and/or similar operations. 

 
5-4 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Geology and Soil 

Resources (Cont.) 

Soil disturbance and 

contamination (Cont.) 

Use site-stabilization practices (i.e., placing crushed 

stone on top of disturbed soil in areas of concentrated 

runoff). 

Use silt berms, dikes, and sediment fences. 

Stabilize drainage culverts and ditches by lining surface 

with rock aggregate/rip-rap to reduce flow velocity and 

prohibit scouring. 

Reuse and/or appropriately place excavated materials to 

decrease exposed soil piles. 

Place gravel construction pads at the entrances/exits of 

construction acres. 

Stabilize site with low-maintenance landscaping and 

pavement. 

Surface Water 

Resources 

Runoff Select a non-wetland, non-floodplain area for the 

proposed facility. 

Follow proper construction Best Management Practices 

(BMPs) as specified by the New Hanover County 

Erosion and Sedimentation Control Ordinance 

(New Hanover County, 2007). 

Construct an access road perpendicular to the Unnamed 

Tributary #1 to minimize the area impacted. 

Design and construct the upgrade of the crossing over 

Unnamed Tributary #1 following procedures required by 

the New Hanover County Flood Damage Prevention 

Ordinance (New Hanover County, 2006). 

Limit cut/fill slopes to a horizontal-vertical ratio of 3:1 or 

less. 

Use silt fencing and covering of soil stockpiles to prevent 

sediment runoff. 

Suspend general construction activities during storms 

and impending precipitation. 

Construct stream crossings (i.e., installation of culverts) 

following at least 48 hours of dry weather. 

Divert stream flow during stream-crossing construction 

to minimize excavation in flowing water. 

Maintain construction equipment so that equipment is in 

good repair and without visible leaks of oil, greases, or 

hydraulic fluids. 

Restore disturbed areas to original surface elevations, 

where possible. 
5-5 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Surface Water 

Resources (Cont.) 

Runoff (Cont.) Comply with all National Pollutant Discharge Elimination 

System (NPDES) stormwater and wastewater permit 

requirements. 

Route stormwater from the proposed facility to a new 

stormwater wet detention basin, designed in accordance 

with the North Carolina Department of Environment and 

Natural Resources (NCDENR) Stormwater Best 

Management Practices Manual (NCDENR, 2007). 

Perform onsite treatment of process and sanitary 

wastewaters to NPDES-permit limits before discharge to 

receiving waters. 

Routinely monitor and inspect onsite liquid waste 

storage tanks and containers to detect any leaks or 

releases to the environment due to equipment 

malfunctions to ensure that actions according to the Spill 

Prevention Control and Countermeasure (SPCC) plan or 

other appropriate corrective action can be taken 

promptly. 

Discharge stormwater runoff from UF6 storage pads area 

to a holding pond for monitoring prior to discharge to the 

stormwater wet detention basin. 

Perform periodic visual inspections of the stormwater 

wet detention basin to verify proper function, at a 

frequency sufficient to allow for identification of basin 

high-water-level conditions and implementation of 

corrective actions to restore the water level prior to 

overflow. 

Ensure easy access to the stormwater wet detention 

basin to allow the prompt, systematic sampling of runoff. 

 Floodplain 

disturbance 

Construct a stormwater wet detention basin and 

implement a Wilmington Site stormwater management 

plan to mitigate a portion of the increased floodwaters 

from extreme storm events and all stormwater from 

smaller storm events. 

Groundwater 

Resources 

Infiltration Implement hazardous material and waste-handling 

procedures and secondary containment, as required by 

applicable laws and regulations. 

Water use Provide water necessary during construction via tanker 

truck from off-site potable water sources. 

Reuse treated sanitary wastewater effluent as makeup 

water in Wilmington Site cooling towers. 
5-6 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Groundwater 

Resources (Cont.) 

Water use (Cont.) Routinely monitor sitewide groundwater levels, and 

continue to analyze the groundwater monitoring-well and 

pumping-well networks to confirm that changes in 

groundwater levels associated with the proposed action 

are minimal. 

Readjust pumping well rates and/or perform well 

maintenance or rehabilitation, as appropriate, in the 

event of unexpected changes in groundwater levels. 

Use low-water-consumption landscaping. 

Install low-flow toilets, sinks, and showers. 

Perform localized floor washing using mops and selfcontained cleaning machines to reduce water usage 

compared to conventional washing techniques. 

Ecological 

Resources 

Disturbance of 

habitats 

Minimize the construction footprint to the extent possible 

and limit habitat disruption. 

Perform surveys of trees greater than 61 centimeters 

(24 inches) in diameter before beginning preconstruction 

and construction activities, and plant one 61-centimeter 

(24-inch) diameter tree, two 30.5-centimeter (12-inch) 

diameter trees, or three 20.3-centimeter (8-inch) 

diameter trees elsewhere on the Wilmington Site. 

Restrict preconstruction activities and the harvesting of 

trees to periods when the ground is dry. 

If trenches are necessary, ensure that they are closed 

overnight; inspect trenches left open overnight and 

remove animals prior to backfilling. Place escape ramps 

in trenches at less than 45-degree angles to provide exit 

strategies for animals. 

Sod, seed, and/or landscape disturbed areas of the 

study area in accordance with the Sediment and Erosion 

Control Permit. 

Install animal-friendly fencing around the proposed 

facility site so that wildlife cannot be injured by or 

entangled in the site’s security fence. 

Plant native plant species (i.e., not invasive species) to 

revegetate disturbed areas and for landscaping. 

Use nectar- and berry-producing plants for landscaping 

plants. 

Conduct site-stabilization practices to reduce the 

potential for erosion and sedimentation. 
5-7 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Ecological 

Resources (Cont.) 

Disturbance of 

habitats (Cont.) 

Place bluebird boxes throughout the study area. 

Establish food plots along roadways and under power 

lines. 

Consider the recommendations of appropriate State and 

Federal agencies, including the U.S. Fish and Wildlife 

Service (FWS) and NCDENR. 

Wetland disturbance Select a non-wetland, non-floodplain area for the 

proposed facility. 

Use existing service road routes and utility ROWs to the 

fullest extent practicable to minimize the need for 

additional wetlands crossings. 

Construct access road perpendicular to wetland to 

minimize the area impacted. 

Limit cut/fill slopes to a horizontal-vertical ratio of three to 

one or less. 

Avoid temporary storage of materials in wetlands during 

construction. 

Maintain the hydrological connectivity of wetlands to 

surface waters. 

Place fencing/barriers and use signs around wetland 

areas. 

Use silt fencing and cover soil stockpiles to prevent 

sediment runoff. 

Restore disturbed areas to original surface elevations. 

Revegetate disturbed areas with native plant species. 

Noise Exposure of workers 

and the public to 

noise 

Prohibit heavy truck and earth-moving equipment usage 

after twilight and during early morning hours. 

Equip construction equipment with the manufacturer’s 

noise-control devices, and maintain these devices in 

effective operating condition. 

When possible, use quiet equipment or methods to 

minimize noise emissions. 

For equipment with internal combustion engines, operate 

equipment at the lowest operating speed to minimize 

noise emissions, when possible and practical. 

Close engine-housing doors during operation of 

equipment to reduce noise emissions from the engine. 

Avoid equipment engine idling. 
5-8 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Noise (Cont.) Exposure of workers 

and the public to 

noise (Cont.) 

Use quieter, less-tonal devices that comply with all 

applicable safety restrictions (e.g., Occupational Safety 

and Health Administration [OSHA] standards) on backup alarms for construction equipment. 

Use a quieter, high-efficiency transformer to mitigate 

noise from the proposed electrical substation. 

Transportation Traffic volume Locate the proposed facility near an interstate highway 

interchange to minimize the distance that truck traffic 

must travel on local surface streets and to facilitate 

employee commuter traffic. 

Increase the number of entry gates onto the Wilmington 

Site from NC 133 (Castle Hayne Road), including one 

dedicated to worker entrance/exit. 

Add roadway improvements (e.g., a turn lane) to NC 133 

as required by the North Carolina Department of 

Transportation (NCDOT) for issuance of a driveway 

permit for connections of the new entrance. 

Work with NCDOT to evaluate driveway- and roadwayimprovement options to minimize impacts. 

Schedule worker shift intervals so that shift start and end 

times are staggered from peak periods of workercommuting traffic for existing site facilities and other 

planned operations. 

Promote carpooling among construction and operations 

workers to help reduce congestion by minimizing the 

additional number of vehicle trips necessary during peak 

commuting periods. 

Route truck shipments of radioactive materials around 

cities by using a U.S. Interstate Highway System bypass 

or beltway (when available). 

Schedule truck deliveries and shipments for off-peak 

traffic periods to reduce potential congestion on local 

roadways during peak worker commuting periods. 

Encourage carpooling for construction workers and 

employees commuting to the proposed facility. 

Public and 

Occupational 

Health 

Effects from facility 

operation 

Install a building ventilation system to maintain the 

majority of the interior of the process building under subatmospheric pressure. 

Install alarms in the Emergency Control Center to detect, 

alarm, and/or activate the automatic safe shutdown of 

process equipment in the event of operational problems. 
5-9 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Public and 

Occupational 

Health (Cont.) 

Effects from facility 

operation (Cont.) 

Isolate leaks and shut down process lines to prevent 

damage to equipment. 

Vent exhaust gases from the emission control system to 

the atmosphere through a single rooftop stack. 

Install radiation monitors in effluent stacks to detect, 

alarm, and activate the automatic safe shutdown of 

process equipment, should contaminants be detected in 

the system exhaust. 

Comply with all applicable State, NRC, and OSHA 

regulations concerning worker health and safety, as well 

as the existing Wilmington Site Nuclear Safety Program 

and the Industrial Safety Program. 

Comply with the Site Radiation Protection Program, the 

SPCC plan, and the GLE Environmental, Health, and 

Safety Program. 

Conduct routine radiological surveys to characterize and 

minimize potential radiological exposure. 

Monitor all radiation workers via the use of dosimeters 

and area air sampling to ensure that radiological doses 

remain within regulatory limits and As Low As 

Reasonably Achievable (ALARA). 

Conduct operations activities involving hazardous 

respirable effluents with ventilation control and/or 

respiratory protection, as required. 

Use personal protective equipment based on the nature 

of the work and chemical and/or radiological hazards 

present. 

Perform environmental monitoring and sampling to 

ensure compliance with regulatory discharge limits. 

Route treated process wastewater effluents to the 

existing final process lagoon facility for additional 

treatment. 
5-10 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed 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 

Groundwater and 

Surface Water 

Resources) 

Select the laser enrichment process to reduce the 

amount of waste generated for production of the same 

amount of enriched product. 

Minimize the quantities of waste generated by the 

proposed facility by implementing the Waste 

Minimization Plan. 

Perform an integrated safety analysis (ISA) for each 

onsite waste storage area to identify and prevent 

accidental releases to the environment. 

Monitor and inspect onsite liquid waste storage tanks 

and containers on a periodic schedule to detect leaks or 

releases to the environment due to equipment 

malfunctions so that actions identified in the SPCC plan 

or other appropriate corrective action can be taken 

promptly. 

Use the existing Wilmington Site onsite wastewater 

treatment facilities within current regulatory permit limits 

to avoid the need to add new onsite waste treatment and 

disposal facilities for the proposed facility. 

Pre-treat radioactive liquid wastewaters in a treatment 

system planned for the proposed facility before the 

wastewater effluent is pumped to the existing NPDESpermitted final process lagoon facility for further 

treatment. 

Ship each waste generated by the proposed facility that 

requires offsite storage, treatment, or disposal to a 

licensed facility (as appropriate for the waste type) in 

compliance with U.S. Environmental Protection Agency 

(EPA) and NRC requirements. 

Minimize onsite storage volumes and times and shipping 

waste destined for offsite treatment and disposal 

facilities as soon as practicable. 

Conduct onsite treatment of process and sanitary 

wastewaters to NPDES permit limits before discharge to 

receiving waters. 
5-11 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Waste 

Management 

(Cont.) 

Generation of 

industrial, 

hazardous, 

radiological, and 

mixed wastes (Cont.) 

Avoid and minimize potential hazardous and radiological 

waste impacts from the UF6 storage pads by 

implementing design elements and safety procedures 

during operation, including: 

– Use of a storage array that permits easy visual 

inspection (stacked no more than two cylinders high); 

– Segregation of storage pad areas from the rest of the 

enrichment facility by barriers (e.g., vehicle guardrails); 

– Inspection of cylinders for external contamination 

(i.e., a “wipe test”) prior to placing on the storage pads 

or transporting them offsite; 

– Ensuring that UF6 cylinders are not equipped with 

defective valves; 

– Allowing only designated vehicles with a limited 

amount of fuel in the storage pad area; 

– Allowing only trained and qualified personnel to 

operate vehicles in the storage pad area; and 

– Monitoring the holding pond that collects stormwater 

from the cylinder pads. 

Inspect cylinders of UF6 initially prior to placing a filled 

cylinder on a storage pad and, thereafter, inspect 

periodically for damage or surface coating defects. 

Inspection criteria would include ensuring 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; 

– Cylinder valves are straight and not distorted, two to 

six threads are visible, and the square head of the 

valve stem is undamaged; and 

– Cylinder plugs are undamaged and not leaking. 
5-12 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Waste 

Management 

(Cont.) 

Generation of 

industrial, 

hazardous, 

radiological, and 

mixed wastes (Cont.) 

If inspections of a cylinder reveal significant deterioration 

or other conditions that may affect its safe use, transfer 

the contents of the cylinder to another cylinder and 

discard the defective cylinder. Investigate the cause of 

any significant deterioration, and if necessary, perform 

additional inspection of cylinders. 

Conduct continuous or periodic monitoring of waste 

management processes and storage facilities for the 

detection of non-intentional releases to the environment, 

so that corrective actions would be taken to minimize 

adverse impacts on the environment. For example, 

directing stormwater runoff from the UF6 storage pads to 

a holding pond, where it would be monitored to ensure 

that unexpected radioactive material releases to the wet 

detention basin did not occur. 

Accidents Accident prevention 

and consequence 

management 

Incorporate the following features into facility design to 

mitigate fire and explosion accidents: 

– Fire alarm and detection systems, including 

suppression capability; 

– Fire barriers to prevent propagation of fire in and out of 

areas containing uranic material; 

– System and component design features that isolate 

combustible material and/or shut down affected 

systems; 

– Continuous detection of a flammable gas in the laser 

systems, for automatic isolation in the event of high 

readings; 

– Structural design features that ensure peak explosive 

blast loads and eliminate or minimize propagation of 

structural material into a UF6 process or handling area; 

and 

– Limit combustibles in outside areas where cylinders 

are stored. 
5-13 

Table 5-1 Summary of Mitigation Measures Proposed by GLE (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Accidents (Cont.) Accident prevention 

and consequence 

management (Cont.) 

Incorporate the following features into facility design and 

operating procedures to mitigate criticality accidents, and 

to contain UF6 gas within specified building areas and 

attenuate any release to the environment: 

– Maintain safe geometry of all vessels, containers, and 

equipment containing fissile material and ensure that 

the concentration and/or mass of fissile material is 

limited to a specified amount; 

– Install radiation detection and criticality monitoring 

systems to quickly alert personnel and isolate systems 

when parameters exceed expected limits; 

– Physically separate areas within the facility to prevent 

or reduce exposure; 

– Control positive or negative air pressures within 

designated areas to prevent or maintain leakage 

between facility areas; 

– Install carbon adsorbers, HEPA filters, and, where 

necessary, automatic trips for ventilation systems to 

help minimize the potential for a release outside the 

affected area; and 

– Implement appropriate door and building design 

features to limit leakage paths to the outside 

environment. 

1 

2 

3 5.2 Potential Mitigation Measures Identified by NRC 

4 

5 The NRC staff has reviewed the mitigation measures proposed by GLE and has identified 

6 additional mitigation measures that could potentially reduce impacts (Table 5-2). While the 

7 NRC cannot impose mitigation outside its regulatory authority under the Atomic Energy Act, the 

8 NRC staff has identified mitigation measures in Table 5-2 that could potentially reduce the 

9 impacts of the proposed action. These additional mitigation measures are not requirements 

10 being imposed upon GLE. For the purposes of NEPA per 10 CFR 51.71(d) and 51.80(a), the 

11 NRC is disclosing measures that could potentially reduce or avoid environmental impacts of the 

12 proposed action.
5-14 

Table 5-2 Summary of Potential Mitigation Measures Identified by NRC 

Impact Area Activity Proposed Mitigation Measures 

Land Use Land disturbance Construction BMPs required under the New Hanover 

County Soil Erosion and Sedimentation Ordinance are 

listed under Geology and Soil. Following those 

measures would help moderate the short-term land use 

effects associated with preconstruction and construction 

activities. 

Use BMPs to control waste disposal, erosion, and runoff 

to help restrict the effect of facility operation on 

surrounding land use. 

Historic and 

Cultural 

Resources 

Disturbance of 

prehistoric 

archaeological sites 

and sites eligible for 

listing on the 

National Register of 

Historic Places

Follow internal procedural guidance for unexpected 

archaeological discoveries, including the unexpected 

discovery of human remains. The procedures include 

notification of certain local and state agency 

representatives, including the State Archaeologist. 

Visual and Scenic 

Resources 

Potential visual 

intrusions in the 

existing landscape 

character 

Plant additional vegetation on the perimeter of the facility 

site to help screen the study area. 

Air Quality Fugitive dust and 

construction 

equipment emissions 

Post speed limits (e.g., 10 miles per hour) visibly within 

the construction site, and enforce them to minimize 

airborne fugitive dust. 

Limit access to the construction site and staging areas to 

authorized vehicles only, through the designated treated 

roads. 

Stage construction to limit the exposed/disturbed area at 

any given time, when practical. 

Train workers to comply with the speed limit, use good 

engineering practices, minimize drop height of materials, 

minimize disturbed areas, and employ other BMPs as 

appropriate. 

To the extent practicable, conduct soil-disturbing 

activities and travel on unpaved roads during periods of 

favorable meteorological conditions, as conducting these 

activities during periods of unfavorable meteorological 

conditions may result in exceedances of air quality 
5-15 

Table 5-2 Summary of Potential Mitigation Measures Identified by NRC (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Air Quality (Cont.) Fugitive dust and 

construction 

equipment emissions 

(Cont.) 

standards. Unfavorable meteorological conditions are 

infrequent and include 1) periods of low winds and stable 

weather conditions (primarily encountered around 

sunrise in winter) and 2) periods of high winds. 

All heavy equipment should meet emission standards 

specified in the State Code of Regulations, and routine 

preventive maintenance, including tuneup to the 

manufacturer’s specification, should be implemented to 

ensure efficient combustion and minimum emissions. 

Fuel all diesel engines used in the facility and auxiliary 

diesel generator units with ultra-low sulfur diesel with a 

sulfur content of 15 parts per million or less. 

Limit idling of diesel equipment to no more than 

10 minutes, unless idling must be maintained for proper 

operation; for example, drilling, hoisting, and trenching. 

Implement more aggressive dust control measures 

during road construction and land clearing, such as more 

frequent water spraying and the application of an 

appropriate dust suppressant. 

Geology and Soil Soil disturbance and 

contamination 

Implement erosion control BMPs by following the 

New Hanover County Erosion and Sedimentation 

Control Ordinance. 

Implement BMPs for storage, handling, spill prevention, 

and spill response to reduce the impact of soil 

contamination associated with fuels, oils, and grease 

from equipment used onsite or from other chemicals or 

wastes managed onsite. 

Surface Water 

Resources 

Runoff Implement BMPs for storage, handling, spill prevention, 

and spill response to reduce the impact of surface water 

contamination associated with the runoff of fuels, oils, 

and grease from equipment used onsite or from other 

chemicals or wastes managed onsite. 

Groundwater 

Resources 

Infiltration Implement BMPs for storage, handling, spill prevention, 

and spill response to reduce the impact of groundwater 

contamination associated with the accidental release of 

fuels, oils, and grease from equipment used onsite or 

from other chemicals or wastes managed onsite. If the 

proposed action results in measurable onsite changes in 

groundwater levels, expand groundwater level 

monitoring to appropriate offsite areas. 

If the proposed action results in measurable onsite 

changes in groundwater levels, expand groundwater 

level monitoring to appropriate offsite areas. 
5-16 

Table 5-2 Summary of Potential Mitigation Measures Identified by NRC (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Ecological 

Resources 

Disturbance of 

habitats 

Reduce or prevent the collection, harassment, or 

disturbance of plants, wildlife, and their habitats 

(particularly threatened, endangered, and sensitive 

species) through employee and contractor education on 

applicable State and Federal laws. Additionally, instruct 

all personnel to avoid harassment and disturbance of 

local plants and wildlife; make personnel aware of the 

potential for wildlife interactions around facility 

structures; and ensure that food refuse and other 

garbage are not available to scavengers. 

Establish a trash abatement program that focuses on 

containing trash and food in closed containers and 

removing them periodically to reduce their attractiveness 

to opportunistic species, such as bears, coyotes, and 

feral dogs. 

Avoid known locations of listed plant species and 

habitats of listed wildlife species and establish a setback 

distance (minimum 60 meters [200 feet]) to prevent any 

destructive impacts associated with construction and 

decommissioning activities. 

Minimize the number of areas where wildlife could hide 

or be trapped (e.g., open sheds, pits, uncovered basins, 

and laydown areas). 

If any Federally threatened or endangered species such 

as the roughleaf loosestrife or the red-cockaded 

woodpecker are encountered, consult with FWS (as 

required by Section 7 of the Endangered Species Act

[ESA]) and determine an appropriate course of action to 

avoid or mitigate impacts. 

Observe all trees >61 centimeters (24 inches) identified 

during GLE’s surveys for potential compensatory tree 

plantings for the potential presence of red-cockaded 

woodpecker cavities. If any cavity trees are observed, 

consult the FWS (as required by Section 7 of the ESA) 

and determine an appropriate course of action to avoid 

or mitigate impacts. 

Develop an integrated vegetation management plan for 

the control of noxious weeds and invasive plant species. 

Minimize the area disturbed by preconstruction activities 

and the installation of facilities (pipelines, transmission 

towers, pump stations, substations, laydown areas, 

assembly areas) to retain native vegetation and minimize 

soil disturbance. 
5-17 

Table 5-2 Summary of Potential Mitigation Measures Identified by NRC (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Ecological 

Resources (Cont.) 

Disturbance of 

habitats (Cont.) 

Backfill open trenches as quickly as is reasonable. 

To the extent practicable, avoid the use of guy wires, 

which pose a collision hazard for birds. 

Maintain areas left in a natural condition during 

construction (e.g., wildlife crossings) in as natural a 

condition as possible within safety and operational 

constraints. 

To minimize habitat loss and fragmentation, reestablish 

as much habitat as possible after construction is 

complete by maximizing the area reclaimed or revegetated during operations. 

Prevent the establishment and spread of invasive 

species and noxious weeds within the transmission line 

ROW, along the access road, and in associated areas of 

ground surface disturbance or vegetation cutting. 

Monitor the area regularly and eradicate invasive 

species immediately. 

Noise Exposure of workers 

and the public to 

noise 

When possible, schedule different noisy activities to 

occur at the same time. Less-frequent but noisy 

activities would generally minimize overall noise 

disturbance than lower-level noise occurring more 

frequently. 

Implement noise control measures (e.g., erection of 

temporary wooden noise barriers) if noisy activities 

would be expected near sensitive receptors. 

Operate all vehicles traveling within and around the 

project area in accordance with posted speed limits. 

Post warning signs in high noise areas and implement a 

hearing protection program for work areas in excess of 

85 dBA. 

Because complaints about noise may occur even when 

noise levels from the facility do not exceed regulatory or 

guideline levels, implement a noise complaint process 

and hotline for the surrounding communities, including 

documentation, investigation, evaluation, and resolution 

of all legitimate project-related noise complaints. 
5-18 

Table 5-2 Summary of Potential Mitigation Measures Identified by NRC (Cont.) 

Impact Area Activity Proposed Mitigation Measures 

Public and 

Occupational 

Health 

Effects from facility 

operation 

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 

hydrogen fluoride and uranic compounds. 

Separate uranic compounds and various other heavy 

metals in waste material generated by decontamination 

of equipment and systems. 

1 

2 No additional mitigation measures were identified for the resource areas of: 

3 

4 • Transportation 

5 

6 • Waste Management 

7 

8 • Accidents 

9 

10 • Decontamination and Decommissioning 

11 

12 • Socioeconomics 

13 

14 • Environmental Justice 

15 

16 5.3 References 

17 

18 (APLIC, 2006) Avian Power Line Interaction Committee. “Suggested Practices for Avian 

19 Protection on Power Lines: The State of the Art in 2006.” <http://www.aplic.org/Suggested 

20 Practices2006(LR).pdf> (Accessed March 25, 2008). 

21 

22 (APLIC and FWS, 2005) Avian Power Line Interaction Committee and U.S. Fish and Wildlife 

23 Service. “Avian Protection Plan (APP) Guidelines.” April. <http://www.eei.org/ourissues/ 

24 TheEnvironment/Land/Documents/AvianProtectionPlanGuidelines.pdf> (Accessed 

25 March 7, 2007). 

26 

27 (GLE, 2008) GE-Hitachi Global Laser Enrichment LLC. “Environmental Report for the GLE 

28 Commercial Facility, Revision 0.” December. ADAMS Accession No. ML090910573. 

29 

30 (NCDENR, 2007) North Carolina Department of Environment and Natural Resources, Division 

31 of Water Quality. “Stormwater Best Management Practices Manual.” <http://h2o.enr.state.nc. 

32 us/su/documents/BMPManual_WholeDocument_CoverRevisedDec2007.pdf> (Accessed 

33 November 18, 2009). 
5-19 

1 (New Hanover County, 2006) New Hanover County. New Hanover County Flood Damage 

2 Prevention Ordinance. Adopted by the New Hanover County Board of County Commissioners 

3 on June 5, 2006. <http://www.nhcgov.com/AgnAndDpt/PLNG/Documents/Ordinance/ 

4 Floodplain_Ord_New_Cover.pdf> (Accessed November 18, 2009). 

5 

6 (New Hanover County, 2007) New Hanover County. County Code of Ordinances Chapter 23, 

7 Article VI: Erosion and Sedimentation Control. <http://www.municode.com/resources/ 

8 gateway.asp?pid=11337&sid=33> (Accessed November 18, 2009). 
5-20 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 [This page intentionally left blank] 
 

6-1 

1 6 ENVIRONMENTAL MEASUREMENT AND MONITORING PROGRAMS 

2 

3 This chapter describes the proposed environmental measurements and monitoring program to 

4 characterize the effect of radiological and nonradiological releases from the proposed General 

5 Electric (GE)-Hitachi Global Laser Enrichment LLC (GLE) Facility in New Hanover County, 

6 North Carolina, on human health and environment. The proposed monitoring program includes 

7 monitoring of radiological and physiochemical gaseous and liquid effluents from facility 

8 operations, and monitoring and measurement of ambient air, surface water, groundwater, 

9 stormwater, soil, sediment, and direct radiation in the vicinity of the proposed GLE Facility. 

10 

11 The proposed GLE Facility would be located on the existing Wilmington Site that currently 

12 includes the Global Nuclear Fuels-America (GNF-A) Fuel Manufacturing Operation (FMO) 

13 facility, Wilmington Field Services Center (WFSC), and the GE Aircraft Engines/Services 

14 Components Operation (AE/SCO) facility. For the last 40 years, the FMO facility possessed 

15 nuclear materials for the conversion of low-enriched uranium hexafluoride (UF6) to uranium 

16 dioxide (UO2). The FMO facility fabricates and constructs nuclear assemblies for commercial 

17 light water reactors. There is an existing monitoring program for the Wilmington Site. The 

18 environmental monitoring program for the proposed GLE Facility is based on the experience 

19 and data accumulated at the Wilmington Site. The existing monitoring program would be 

20 expanded to include and account for the proposed GLE Facility (GLE, 2008); this program is 

21 referred to throughout this chapter as the Expanded Monitoring Program. The existing 

22 monitoring program would provide the baseline for air quality, surface water, sediment, treated 

23 sanitary wastewater effluent, and treated process wastewater effluent (GLE, 2008). The 

24 baseline data for groundwater and soil would be collected before the proposed GLE Facility 

25 becomes operational. The baseline uranium concentration in shallow soil across the 100-acre 

26 (40-hectare) proposed GLE Facility site would be established through statistical sampling 

27 program before the construction of the proposed GLE Facility (GLE, 2008). Table 6-1 

28 (GLE, 2008) provides a summary of the proposed monitoring program for the proposed GLE 

29 Facility, including the types, frequency, and sampling locations in addition to locations currently 

30 monitored by GNF-A. 

31 

32 In addition to routine sampling, provisions would be in place to respond to emergency situations, 

33 accidents, or increased emission levels found in routine sampling. Sampling frequency and 

34 locations would be determined by GLE environmental staff in accordance with the permit 

35 requirements, to demonstrate compliance. All liquid and solid hazardous and radioactive 

36 wastes related to operation of the proposed GLE Facility would be analyzed for chemical and 

37 radiological properties to determine appropriate disposal methods or treatment requirements. 

38 

39 Effluent compliance levels would be set primarily in the respective permits issued and 

40 administered by the North Carolina Division of Air Quality (NCDAQ) and under National 

41 Pollutant Discharge Elimination System (NPDES) permits. To ensure that the permit 

42 requirements are met, administrative action levels would be established at levels below 

43 compliance levels for all measured parameters. Response actions for elevated measurements 

44 would be set in documented procedures at increasing levels of priority, ranging from 

45 (1) increasing monitoring frequency, (2) to adjusting operations, and (3) performing corrective 

46 actions to prevent exceedances of regulatory compliance levels. 

47 
6-2 

Table 6-1 Summary of GLE Environmental Monitoring Program

Medium Additional Sample Locationsa Sample Type Analyte/Parameter 

Personnel dosimetry Continuous film badges, TLDs, 

and pocket dosimeters 

Direct radiation • Gamma and neutron a

UF6 storage pads area and other 

outdoor storage areas 

Continuous film badges or TLDs • Gamma and neutron a

Main GLE process building stack (see Figure 6-1) 

Continuous air particulate filter • Gross alpha activity − 

• Fluoride − Weekly 

Air 

Around the proposed GLE Facility. Site boundary point of highest potential impact, and ambient (background) (see Figure 6-1) 

Continuous air particulate filter • Gross alpha activity − 

• Uranium isotopes − W

Surface Water None in addition to the current effluent 

channel location at the Site dam and Northeast Cape Fear River locations upstream and downstream of the Site 

Grab sample • Gross alpha/beta activ

• Total uranium − Month

• LCFRP physical, chem

biological monitoring 

Treated process wastewater effluent 

None in addition to the current monitoring at the wastewater treatment and reclamation facility 

Continuous, composite, or grab samples, per permit 

• Total uranium − Daily 

• Gross alpha/beta activ

composite 

• Technetium-99 − Qua• NPDES permit require

Treated sanitary wastewater effluent 

None in addition to the current monitoring at NPDES Outfall 002 

Continuous proportional sample of liquid effluent 

• NPDES permit require

Groundwater 21 monitoring wells Grab sample after typical 3-well 

purge 

• Total uranium − Quart• Gross alpha/beta activ

total uranium concentsample >0.02 mg/L 

• Fluoride − Quarterly 
6-3 

Table 6-1 Summary of GLE Environmental Monitoring Program (Cont.) 

Medium Additional Sample Locationsa Sample Type Analyte/Parameter 

Stormwater Stormwater wet detention basin Stormwater grab samples • NPDES permit require

UF6 storage pads area holding pond Stormwater grab sample • Gross alpha/beta activ

transfer of held water 

• Total uranium − Befor

water to detention pon

• Fluoride − Before tran

to detention pond 

Soil 4 locations Shallow soil grab sample • Total uranium − SemiaSediment None in addition to current monitoring 

locations 

Sediment grab sample • Total uranium − Semia

a Sampling locations for the proposed action in addition to locations currently monitored by GNF-A (GNF-A, 2007). b Initial monitoring frequencies may be evaluated and adjusted. UF6 = uranium hexafluoride; TLDs = thermoluminescent dosimeters; LCFRP = 

River Program; NPDES = National Pollutant Discharge Elimination System. Source: Adapted from GLE, 2008. 
6-4 

1 The following sections describe the monitoring program in detail. 

2 

3 6.1 Radiological Measurements and Monitoring Program 

4 

5 The U.S. Nuclear Regulatory Commission (NRC) requires that the proposed GLE Facility 

6 establish a radiological monitoring and measurement program to monitor and report quantities 

7 of the radionuclides released to the environment from gaseous and liquid effluents. These 

8 requirements are specified in Title 10, "Energy," of the U.S. Code of Federal Regulations 

9 (10 CFR) Part 20 Appendix B and 10 CFR 70.59. The U.S. Environmental Protection Agency 

10 (EPA) specifies additional monitoring requirements for air and liquid (40 CFR 70.6(a)(3), 

11 40 CFR 122.48, and 40 CFR 123.25). The corresponding requirements from the State of North 

12 Carolina are specified in 15A North Carolina (NC) Administrative Code 02Q.0508 and 15A NC 

13 Administrative Code 2B.0500. The radiological monitoring and measurement program for the 

14 proposed GLE Facility was developed based on the above regulatory requirements, the existing 

15 GNF-A monitoring program, and NRC guidance documents listed in Table 6-2. 

16 

17 The expanded monitoring program at the proposed GLE Facility would demonstrate compliance 

18 with effluent release requirements in 10 CFR Part 20 Appendix B, and would be implemented by 

19 the GNF-A and GLE Environmental, Health, and Safety (EHS) functions. The expanded 

20 radiological monitoring program would start when the proposed GLE Facility begins operation 

21 and would remain operational during the decommissioning phase. The monitoring during the 

22 decommissioning phase may be reduced as the contaminants are removed from the site. 

23 

24 The following sections describe radiological air monitoring, direct radiation monitoring, 

25 radiological sampling and monitoring for wastewater and stormwater discharge, surface water 

26 and sediment monitoring, groundwater monitoring, and soil sampling. 

27 

Table 6-2 Guidance Documents That Apply to the Radiological Monitoring Program 

Document Applicable Guidance 

Regulatory Guide 4.15a

“Quality Assurance for Radiological 

Monitoring Programs (Inception through 

Normal Operations to License Termination) 

– Effluent Streams and the Environment.” 

This guide describes a method acceptable to the 

NRC 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 4.16b

“Monitoring and Reporting Radioactivity in 

Releases of Radioactive Materials in Liquid 

and Gaseous Effluents from Nuclear Fuel 

Processing and Fabrication Plants and 

Uranium Hexafluoride Production Plants.” 

This guide describes a method acceptable to the 

NRC for submitting semiannual reports that specify 

the quantity of each principal radionuclide released 

to unrestricted areas to estimate the maximum 

potential annual dose to the public resulting from 

effluent releases. a

 NRC, 2007. 

b

 NRC, 1985. 
6-5 

1 6.1.1 Air Monitoring 

2 

3 Radioactive airborne releases from the proposed GLE Facility would be discharged primarily 

4 from the stack on the main process building. Figure 6-1 shows the proposed location of the 

5 stack, which would be about 21.3 meters (70 feet) above the ground. Airborne release 

6 monitoring procedures for this source would be designed in a manner to determine the 

7 quantities and concentrations of radionuclides discharged to the environment, in accordance 

8 with 10 CFR 70.59. Uranium isotopes anticipated to be released as airborne emissions would 

9 include uranium-234, uranium-235, uranium-236, and uranium-238. The stack would be 

10 sampled continuously. During initial operation, the collection filter would be removed daily and 

11 analyzed for gross alpha activity. If, during normal operations, the monitoring results show 

12 continued low alpha activity, the removal frequency for the collection filter would eventually be 

13 decreased to weekly. 

14 

15 In addition to stack monitoring for compliance with regulatory requirements, ambient air 

16 monitoring for radioactive emissions would take place around the proposed GLE Facility, to 

17 ensure that the facility is operating properly. A total of 11 active air monitors would be used for 

18 analysis of a weekly composite sample for gross alpha activity and concentrations of uranium 

19 isotopes, resulting primarily from the GLE stack emissions and activities from UF6 cylinder pads. 

20 As shown in Figure 6-1, nine monitors would be placed around the proposed GLE Facility. 

21 Considering prevailing wind directions, three monitors each would be placed to the north and 

22 south. Three monitors to the south would be placed to monitor for levels of radioactive material 

23 from the UF6 storage pads and the stack under prevailing northerly winds. Three monitors 

24 would be placed to the north and northeast to monitor levels of radioactive materials under 

25 prevailing southwesterly winds. Additionally, one monitor would be placed to the east of the UF6

26 storage pads, and two monitors would be placed on the western side of the facility to cover 

27 potential impacts from all wind directions. Finally, one monitor would be placed where the 

28 highest potential impact was predicted to occur, on the Wilmington Site property boundary about 

29 0.5 kilometers (0.3 miles) to the northeast of the proposed GLE Facility stack. 

30 

31 An active air monitor would be placed approximately 0.8 kilometers (0.5 miles) to the west–

32 northwest of the proposed GLE Facility stack. The monitor is located in the least-prevailing 

33 wind direction from the proposed GLE Facility and thus, considered as an onsite background 

34 monitor associated with the operation of the proposed GLE Facility. 

35 

36 6.1.2 Direct Radiation Monitoring 

37 

38 Direct radiation monitoring would be conducted to demonstrate compliance with the NRC 

39 requirements in 10 CFR Part 20 and North Carolina State requirements for radiation protection 

40 (GLE, 2008). Direct gamma radiation in offsite locations from processes inside the proposed 

41 GLE Facility main process building would be expected to be minimal, because the low-energy 

42 gamma radiation associated with uranium would be shielded by the building structure, process 

43 piping, and equipment. Personal dosimetry would be used to evaluate the dose to the workers. 

44 Thermoluminescent dosimeters (TLD) or film badges would be used for direct radiation 

45 monitoring for the cylinder pads and other outdoor storage areas and would be placed at 

46 strategic locations along the boundaries of the cylinder storage pads. TLDs would be placed at 

47 locations where there is higher employee traffic, such as near the access gates for each 

48 cylinder storage pad. TLDs would also be placed on the three fencelines that do not have 
6-6 

1 

Figure 6-1 GLE Air Monitoring Locations1 2 (GLE, 2008) 

3 

4 access gates. TLDs would be replaced and analyzed every six months. Periodic surveys using 

5 portable survey meters would be performed monthly in the general storage pad area and along 

6 the boundary of the storage pads (GLE, 2009a). 

7 

8 6.1.3 Wastewater and Stormwater Discharge Monitoring 

9 

10 The proposed GLE Facility would generate and treat liquid process wastewater containing 

11 uranium and fluoride. A treatment process would remove uranium through pH adjustment and 

12 fluoride through addition of a salt to precipitate the fluoride (GLE, 2008). Either filtration or 

13 evaporation would then take place on the fluoride precipitate. The treatment process would be 

14 very similar to what is currently in effect at the FMO facility, and effluent concentrations of 

15 uranium are expected to be similar or lower compared to the existing process (GLE, 2009b). 

16 The treated wastewater would be conveyed to the existing Wilmington Site final process lagoon 

17 facility for further treatment. From the lagoon, treated effluent is discharged under NPDES 

18 permit to the effluent channel via Outfall 001. Continuous proportional samples of the treated 

19 wastewater are collected at Outfall 001 (see Figure 3-20). The monitoring would include daily 

20 composite samples for uranium; weekly composite samples of the daily samples for gross alpha 

 

1

 The locations shown are approximate. 
6-7 

1 and gross beta activity; and quarterly composite samples of the weekly composites for 

2 technetium-99. 

3 

4 Stormwater runoff from the UF6 storage area would travel to a new holding pond for monitoring 

5 for uranium, gross alpha, and gross beta (GLE, 2008, 2009b). Afterwards, the stormwater 

6 would be released to a stormwater wet detention basin. The purpose of the holding pond would 

7 be to detain stormwater from the UF6 storage area in the event of an incident involving the 

8 release of uranium on the storage pad. Treatment of the stormwater would not, therefore, 

9 normally take place. If such an incident occurred, water in the holding pond would be retained 

10 and monitored until uranium stabilized through precipitation or was subjected to active 

11 treatment. Afterwards, the holding pond liner would be sampled to assess the need for 

12 remediation (GLE, 2009b). 

13 

14 Wilmington Site stormwater basins are not currently monitored during rainfall events. The 

15 NPDES stormwater permit states that no analytical sampling is required if a basin is designed to 

16 discharge only in response to a 10-year storm (GLE, 2009b). 

17 

18 GLE intends to consult with the North Carolina Division of Water Quality (NCDWQ) to develop a 

19 monitoring plan for the UF6 storage area stormwater holding pond (GLE, 2009b). Per 

20 10 CFR Part 70 Appendix A(c), any release that is reportable to the State would also be 

21 reported to NRC. 

22 

23 6.1.4 Surface Water and Sediment Monitoring 

24 

25 The current monitoring program would be expanded to account for the proposed GLE Facility 

26 (GLE, 2008). As part of this Expanded Monitoring Program, GLE would continue the surface 

27 water monitoring activities that are currently conducted under the GNF-A monitoring program at 

28 the Wilmington Site. Gross alpha, gross beta, and uranium are monitored in the effluent 

29 channel, the Northeast Cape Fear River 27 kilometers (17 miles) upstream of the Wilmington 

30 Site, and the Northeast Cape Fear River at the Wilmington Site dock, which is downstream of 

31 the discharge of the effluent channel to the river (via a tributary), as described in Section 3.7.1. 

32 Monitoring consists of monthly grab samples. 

33 

34 Current sediment sampling under the GNF-A Environmental Monitoring Program includes 

35 semiannual uranium samples in the effluent channel downstream of Outfall 001 (GLE, 2008). 

36 Because the proposed GLE Facility's process wastewater would follow the same route, the 

37 current sediment sampling program would provide relevant samples. 

38 

39 6.1.5 Groundwater Monitoring 

40 

41 Current groundwater monitoring for radiological contaminants involves monitoring wells across 

42 the Wilmington Site. Thirteen more wells would be installed at the proposed location to 

43 complement the existing eight wells already in the North-Central Site Sector (GLE, 2008). This 

44 set of 21 wells would become part of the Expanded Monitoring Program. They would be 

45 arranged in seven clusters with wells installed at three depths in each cluster (at or near the 

46 water table in the surficial aquifer, in the upper portion of the Peedee Sand, and in the 

47 intermediate Peedee Sand). 

48 
6-8 

1 Quarterly sampling for uranium would take place from the 21 wells. If a result exceeded 

0.02 milligrams per liter (1.7 × 10–7 2 pounds per gallon), then subsequent quarterly samples from 

3 that well would also include analysis for gross alpha and gross beta activity (GLE, 2008). After 

4 sufficient data were gathered for a statistical trend analysis, the sampling frequency for each 

5 well would be reviewed, and adjusted if necessary. Quarterly monitoring would begin prior to 

6 GLE operations to establish baseline conditions, and the Expanded Monitoring Program would 

7 continue through the operations and decommissioning phases. 

8 

9 6.1.6 Soil Sampling 

10 

11 The existing soil sampling and analysis program at the Wilmington Site would be supplemented 

12 with four additional sampling locations; two to the north and two to the south of the proposed 

13 GLE Facility (GLE, 2008). The sampling at these new locations would begin before startup of 

14 the proposed GLE Facility to establish the baseline condition. In addition, uranium baseline 

15 concentration in shallow soil across the 100-acre (40-hectare) proposed GLE Facility site would 

16 be established before preconstruction and construction of the proposed GLE Facility 

17 (GLE, 2008). 

18 

19 6.2 Nonradiological Measurements and Monitoring Program 

20 

21 This section describes the proposed physiochemical, ecological, and industrial health and safety 

22 monitoring for the proposed GLE Facility. Discussions of physiochemical monitoring cover 

23 effluent monitoring of chemical constituents to meet permit requirements, and environmental 

24 media sampling to detect impacts from site operations. 

25 

26 6.2.1 Physiochemical Monitoring 

27 

28 A physiochemical monitoring program would be conducted during the construction and 

29 operation of the proposed GLE Facility as part of an environmental protection program to control 

30 chemical and other nonradiological exposures to workers, the public, and the environment. 

31 During the preconstruction and construction phases, worker and public exposure to dust would 

32 be monitored as required under GNF-A’s Industrial Safety Program and Occupational Safety 

33 and Health Administration (OSHA) requirements. Stormwater would be monitored during 

34 construction under the provisions of an NPDES General Permit for Construction Stormwater. 

35 The specific monitoring requirements under the permit would be specified in an Erosion and 

36 Sedimentation Control Plan submitted to and approved by the North Carolina Division of Land 

37 Resources. 

38 

39 During facility operation, the primary objective of monitoring would be to confirm that effluent 

40 controls for gaseous and liquid effluents are working properly, and if not, to alert operators when 

41 actions, including corrective measures, need to be taken. Physiochemical sampling of effluent 

42 streams and of environmental media potentially affected by the effluents, including soil, 

43 sediments, groundwater, surface water, and biota would be conducted. Specific parameters 

44 monitored would include uranium, fluoride, and any other chemicals or parameters specified in 

45 facility or site permits. 

46 

47 In addition, environmental media samples would be collected periodically and analyzed for 

48 chemicals present in effluents. Much of this sampling is already conducted for the existing 
6-9 

1 facilities at the Wilmington Site, including sampling of uranium at various surface water 

2 locations; uranium and fluoride in groundwater at 21 site perimeter monitoring wells, and in 

3 sediments at various site locations. In addition to current sampling, four new soil sampling 

4 locations would be sampled near the boundaries of the proposed GLE Facility (GLE, 2008). 

5 Soil and sediment samples would be collected semiannually. 

6 

7 Groundwater sampling would be performed quarterly as described in Section 6.1.5, and would 

8 include analysis for fluoride and measurements of pH, temperature, and specific conductance. 

9 Water levels would be measured at each sampling event and in semiannual comprehensive 

10 measurement events across the Wilmington Site. 

11 

12 6.2.1.1 Effluent Monitoring 

13 

14 Hydrogen fluoride (HF), as fluoride ion, would be collected continuously on particulate filters in 

15 vent stacks and analyzed weekly in accordance with an NCDAQ air permit that would be 

16 required for the facility. Uranium isotopes would be collected continuously on particulate filters 

17 in air samplers located around the proposed GLE Facility. These filters would likewise be 

18 analyzed weekly. Fluoride and uranium would be monitored in liquid effluents along with any 

19 other chemicals required under the Wilmington Site’s NPDES permits. Effluents would be 

20 sampled at outfalls from treatment systems for process wastewater and sanitary wastewater 

21 and in stormwater retention basins, including the holding pond for UF6 storage pads. 

22 

23 The Expanded Monitoring Program would include continued monitoring at effluent outfalls under 

24 the current NPDES permit as described in Section 3.7.1. 

25 

26 Outfall 001 (Figure 3-20) is for process wastewater. It is monitored prior to discharge to the 

27 effluent channel for various parameters and has limitations on total suspended solids (TSS), 

28 total nitrogen, fluoride, cyanide, pH, metals (total cadmium, lead, chromium, copper, nickel, 

29 silver, zinc), oil and grease, and total toxic organics. The permit lists a number of equipment 

30 systems that contribute flow to the outfall, including treatment tanks, lime slurry system, 

31 hydrofluoric acid equipment, etc. The permitted maximum flow at the outfall is 6.8 million liters 

32 per day (1.8 million gallons per day). 

33 

34 Outfall 002 (Figure 3-20) was used for treated domestic (sanitary) wastewater until April 2008. 

35 Permit limitations included biochemical oxygen demand (BOD), TSS, and fecal coliform, and a 

36 maximum allowed flow of 280,000 liters per day (75,000 gallons per day). Because the new 

37 sanitary wastewater treatment facility does not release effluent, the outfall is unused; however, 

38 the permit is in place if discharge is necessary in the future. Effluent limits for both monthly 

39 average and daily maximum values include turbidity, nitrogen, BOD, TSS, and fecal coliform. 

40 

41 Monitoring of pH at the site dam is also described in Section 3.7.1. 

42 

43 Surface water monitoring would continue to be monitored by GLE, the NCDWQ, and the Lower 

44 Cape Fear River Program, as described in Section 3.7.1 of this draft EIS. The NCDWQ 

45 maintains two monitoring stations along the Northeast Cape Fear River; one is 27 kilometers 

46 (17 miles) upstream of the site and the other is 10 kilometers (6 miles) downstream. A third 

47 station near the Wilmington Site’s south border is monitored by the Lower Cape Fear River 

48 Program. GE monitors water quality parameters along with gross alpha, gross beta, and 
6-10 

1 uranium concentrations in the effluent channel at the Wilmington Site dam, the Northeast Cape 

2 Fear River significantly upstream of the Wilmington Site, and the Northeast Cape Fear River just 

3 downstream of the Wilmington Site. 

4 

5 6.2.1.2 Stormwater Monitoring 

6 

7 A stormwater permit would be required for the proposed GLE Facility (GLE, 2008). Stormwater 

8 would be monitored, as described in Section 6.1.3. 

9 

10 6.2.2 Ecological Monitoring 

11 

12 The current ecological monitoring program for the Wilmington Site consists of a forestry 

13 management plan to improve natural habitats on the Wilmington Site. This program would also 

14 provide appropriate monitoring and habitat management for the proposed GLE Facility. 

15 Monitoring would include ecological surveys to identify potential issues and habitat areas that 

16 need improvement. GLE would consider survey recommendations made by appropriate 

17 Federal and State agencies (e.g., U.S. Fish and Wildlife Service and the North Carolina 

18 Department of Environment and Natural Resources) (GLE, 2008). Such actions could include 

19 surveys for listed species or their suitable habitat, particularly the roughleaf loosestrife 

20 (Lysimachia asperulaefolia) and red-cockaded woodpecker (Picoides borealis) (FWS, 2009). 

21 

22 To mitigate losses of more mature trees, GLE would conduct surveys for trees >61 centimeters 

23 (24 inches) in diameter in areas that would be affected by preconstruction activities and 

24 construction of the proposed GLE Facility, in order to determine compensatory requirements for 

25 tree plantings that would be performed elsewhere on the Wilmington Site. If trenches are 

26 required, any that would be left open overnight would be inspected for animals prior to 

27 backfilling. 

28 

29 Any nonradiological ecological monitoring prescribed through the various environmental permits 

30 for the preconstruction, construction, and operation of the proposed GLE Facility are expected 

31 to be sufficient to evaluate any nonradiological ecological impacts. 

32 

33 6.2.3 Industrial Health and Safety Monitoring 

34 

35 The existing industrial health and safety program at the Wilmington Site would be expanded to 

36 include the activities of the proposed GLE Facility (GLE, 2008). This would include monitoring 

37 of indoor air quality and noise in work places. It would also include training of workers in safe 

38 work practices and monitoring of workplace safety-related occurrences and taking appropriate 

39 corrective actions. An ergonomic program would also be included as part of the industrial 

40 health and safety program to reduce or eliminate worker injuries (GLE, 2008). 

41 

42 6.2.4 Cylinder Surveillance and Monitoring 

43 

44 Surveillance and monitoring of depleted UF6 cylinders would be conducted prior to placement 

45 on the storage pad (and periodically thereafter, including prior to transportation) to ensure 

46 cylinder integrity and prevent or minimize the potential release of UF6 (GLE, 2008). GLE’s 

47 cylinder monitoring program would include inspection criteria to ensure that lifting points, skirts, 

48 and stiffener rings are free from distortion and cracking; surfaces are free from bulges, dents, 
6-11 

1 gouges, cracks, and significant corrosion; valves are fitting with correct protector and cap; 

2 valves are not distorted and valve stems are undamaged; and cylinder plugs are undamaged 

3 and not leaking. If inspections reveal significant deterioration or other conditions that may affect 

4 safe use of a cylinder, the contents of the affected cylinder would be transferred to another 

5 cylinder and the defective cylinder would be discarded. Investigation of the cause of the 

6 deterioration would be performed, and if necessary, additional cylinder inspections would be 

7 performed (GLE, 2008). In addition, radiological surveys would be conducted to ensure that 

8 cylinders are not externally contaminated and to help ensure that radiation exposures during 

9 cylinder handling and storage comply with the regulatory limits in 10 CFR Part 20 (GLE, 2008). 

10 

11 6.3 Quality Assurance 

12 

13 The Expanded Monitoring Program (which would incorporate the proposed GLE Facility) would 

14 fall under the oversight of the Wilmington Site Quality Assurance Program and would be 

15 managed by a qualified quality assurance officer. The program would employ written 

16 procedures for the collection of representative environmental samples, appropriate sampling 

17 methods and equipment, selection of sampling points, and sample preservation, transport, 

18 handling, storage, and custody. Additional written procedures would be used to ensure that 

19 sampling and monitoring equipment is properly maintained, calibrated, and is in good working 

20 order. 

21 

22 Onsite and contractor analytical laboratories would similarly implement a formal quality 

23 assurance/quality control program to monitor, assess, and control the performance of 

24 radiological and chemical analysis so that required performance standards specified in permits 

25 and within the standard analytical procedures are met. Good laboratory practices would be 

26 employed in all aspects of analysis. Laboratories would participate in third-party comparison 

27 studies to validate their performance. 

28 

29 Quality assurance measures employed in sampling and analysis would be adequate to produce 

30 valid analytical results. Procedures would require the use of calibration standards traceable to a 

31 primary National Institute of Standards and Technology (NIST) standard, as appropriate. 

32 Industry-accepted, regulatory agency-approved sampling, analysis, and reporting methods 

33 would be employed, such as those endorsed by the National Environmental Laboratory 

34 Accreditation Conference (NELAC). 

35 

36 The quality assurance program would specify an adequate set of quality assurance samples to 

37 validate field samples. Both field and laboratory quality control samples would be analyzed, 

38 including appropriate blank, duplicate, and spiked samples, as well as laboratory calibration and 

39 sample recovery standards. Performance standards would be set to meet the requirements of 

40 specific measurement programs, and would include standards for minimum detectable 

41 concentrations (MDCs), sample recovery, and analysis reproducibility. MDCs would be 

42 sufficient to meet action level, regulatory, and permit requirements, as well as the requirements 

43 of environmental media monitoring programs. 

44 

45 6.4 Reporting 

46 

47 Reporting would comply with the requirements of 10 CFR 70.59 and the guidance specified in 

48 NRC Regulatory Guide 4.16 (NRC, 1985) It is expected that a single semiannual report for the 
6-12 

1 Wilmington Site (that would include the proposed GLE Facility) would be submitted to the NRC. 

2 The semiannual report would include the quantities of the radionuclides released in the 

3 unrestricted area and other information necessary to evaluate the radiation dose from effluent 

4 releases to the public (GLE, 2008). The NRC would place this report (and all other relevant 

5 information pertaining to environmental sampling) on the NRC’s web site to make it available to 

6 the public. 

7 

8 6.5 References 

9 

10 (FWS, 2009) U.S. Fish and Wildlife Service. Letter from H. Hall (U.S. Fish and Wildlife Service) 

11 to A. Kock (U.S. Nuclear Regulatory Commission) dated June 8. “Subject: Docket No. 70-7016; 

12 General Electric-Hitachi Global Laser Enrichment Facility, New Hanover County, North 

13 Carolina.” ADAMS Accession No. ML091700024. 

14 

15 (GLE, 2008) GE-Hitachi Global Laser Enrichment LLC. “Environmental Report for the GLE 

16 Commercial Facility, Revision 0.” December. ADAMS Accession No. ML090910573. 

17 

18 (GLE, 2009a) GE-Hitachi Global Laser Enrichment LLC. “GE-Hitachi Global Laser Enrichment 

19 Submittal of Additional Information Related to NRC Review of GLE Environmental Report,” 

20 Letter number GLEL-09-004, submitted by GE-Hitachi Nuclear Energy, Global Laser 

21 Enrichment, LLC, to Division of Waste Management and Protection, Office of Federal 

22 U.S. Nuclear Regulatory Commission. June 8. ADAMS Accession No. ML092110764. 

23 

24 (GLE, 2009b) GE-Hitachi Global Laser Enrichment LLC. Letter from A. Kennedy 

25 (Environmental Health and Safety Manager, GLE) to A. Kock (Chief, Environmental Review 

26 Branch, U.S. Nuclear Regulatory Commission) dated November 5. “Subject: GE-Hitachi Global 

27 Laser Enrichment Response to Request for Additional Information Related to NRC Review of 

28 GLE Environmental Report.” ADAMS Accession No. ML093170517. 

29 

30 (GNF-A, 2007) Global Nuclear Fuel-Americas LLC. “Site Environmental Report Supplement for 

31 the Period 1995–2005.” March 30. 

32 

33 (NRC, 1977) U.S. Nuclear Regulatory Commission. “Calculation of Annual Doses to Man from 

34 Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 

35 10 CFR Part 50, Appendix I.” Regulatory Guide 1.109, Revision 1. October. 

36 <http://www.nrc.gov/reading-rm/doc-collections/reg-guides/power-reactors/active/01-109/01-

37 109.pdf> (Accessed January 29, 2010). 

38 

39 (NRC, 1985) U.S. Nuclear Regulatory Commission. “Monitoring and Reporting Radioactivity in 

40 Releases of Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel 

41 Processing and Fabrication Plants and Uranium Hexafluoride Production Plants.” Regulatory 

42 Guide 4.16, Revision 1. December. ADAMS Accession No. ML003957058. 

43 

44 (NRC, 1988) U.S. Nuclear Regulatory Commission. “Onsite Meteorological Measurement 

45 Program for Uranium Recovery Facilities—Data Acquisition and Reporting.” Regulatory 

46 Guide 3.63. March. ADAMS Accession No. ML003969813. 

47 
6-13 

1 (NRC, 2007) U.S. Nuclear Regulatory Commission. “Quality Assurance for Radiological 

2 Monitoring Programs (Inception through Normal Operation to License Termination) – Effluent 

3 Streams and the Environment.” Regulatory Guide 4.15, Revision 2. July. ADAMS Accession 

4 No. ML072070314. 

5 

6 
6-14 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 [This page intentionally left blank] 
7-1 

1 7 COST-BENEFIT ANALYSIS 

2 

3 The costs and benefits of the proposed action and no-action alternative are considered in this 

4 chapter as an aid in evaluating environmental consequences. Costs and benefits are 

5 presented, to the extent possible, in monetary terms. Important costs and benefits that cannot 

6 be quantified in monetary terms, such as environmental impacts, are presented qualitatively. 

7 

8 Cost-benefit analysis can provide a rationale for deciding whether a project is likely to have a 

9 net positive impact by aggregating each of the costs and benefits resulting from the project. 

10 Cost-benefit analysis involves valuing the benefits and costs associated with a project in 

11 monetary terms, to the extent possible. Depending on the extent of the data available, cost12 benefit analyses may rely partially on qualitative data to assess the various costs and benefits; 

13 the methodology employed for a cost-benefit analysis is usually dependent on the specific 

14 issues involved in a project. Costs and benefits are often separated into two categories – 

15 private and societal. Private costs and benefits are those that impact the owner of a project or 

16 facility, in this case General Electric (GE)-Hitachi Global Laser Enrichment LLC (GLE), while 

17 societal costs and benefits are those that impact society as a whole. Much of the data 

18 associated with the construction and operation of the proposed GLE Facility that would be used 

19 to assess private costs (i.e., the costs of constructing and operating the proposed facility) are 

20 proprietary commercial information, withheld in accordance with 10 CFR 2.390. Although these 

21 costs are presented in Appendix H, they cannot be discussed in this section of this draft 

22 Environmental Impact Statement (EIS). 

23 

24 The analysis focuses on the various private and societal costs and benefits associated with the 

25 proposed action and the no-action alternative using data provided by GLE (GLE, 2008; 

26 GLE, 2009a). These data include the economic and fiscal benefits of facility construction and 

27 operation to the region in which the plant is located, and to the North Carolina state economy. 

28 As described in Section 3.13, the area in which workers are expected to live and spend most of 

29 their salary is referred to as the region of influence (ROI) for the analysis of socioeconomic 

30 impacts. The ROI corresponds to the Wilmington Metropolitan Statistical Area (MSA), a 

31 three-county area comprising Brunswick, New Hanover, and Pender Counties. Although the 

32 majority of the costs and most of the socioeconomic impacts of the various phases of the 

33 proposed GLE Facility development would occur in the ROI, there would be economic, fiscal, 

34 and, in particular, energy security benefits that would occur at both the local and national level. 

35 Therefore, the cost-benefit analysis addresses a larger area than the ROI that was considered 

36 in the analysis of socioeconomic impacts. Also discussed are the benefits of the proposed GLE 

37 Facility at the national level in fulfilling the need for enriched uranium to fulfill domestic electricity 

38 requirements, for domestic supplies of enriched uranium for national energy security, and for 

39 upgraded uranium enrichment technology in the United States. Societal costs considered 

40 include those related to impacts on land use, historical and cultural resources, visual resources, 

41 air quality, geology and soils, water resources, ecological resources, environmental justice, 

42 noise, transportation, public and occupational health, and waste management. 

43 

44 This chapter analyzes the costs and benefits both quantitatively, in monetary terms where 

45 possible, and qualitatively. Section 7.1 addresses the no-action alternative. Section 7.2 weighs 

46 the costs and benefits associated with the proposed action. Section 7.3 compares the costs 

47 and benefits for the proposed action to those of the no-action alternative. Section 7.4 combines 

48 these sections into overall conclusions. Alternatives that have previously been ruled out for 
7-2 

1 failing to meet the project's technical and policy objectives are described in Section 2.3 of this 

2 draft EIS and are not revisited in this chapter. 

3 

4 7.1 The No-Action Alternative 

5 

6 Although the proposed GLE Facility would not be constructed or operated under the no-action 

7 alternative, preconstruction activities that are not covered under the scope of the NRC review 

8 could still take place (see Section 1.4.1 of this draft EIS). These activities would involve the 

9 disturbance of land associated with site clearing and the construction of ancillary facilities, in 

10 addition to other preconstruction activities, meaning that some ecological, natural, and 

11 socioeconomic impacts would therefore occur. All potential local environmental impacts related 

12 to water use, land use, groundwater contamination, ecology, air emissions, human health and 

13 occupational safety, waste storage and disposal, disposition of depleted uranium, and 

14 decommissioning projected to occur during construction, operations, and decommissioning 

15 phases would be avoided. Similarly, all socioeconomic impacts related to employment, 

16 economic activity, population, housing, and community resources during construction, 

17 operations, and decommissioning phases would not occur. 

18 

19 7.2 Costs and Benefits of the Proposed Action 

20 

21 Under the proposed action, GLE would construct, operate, and decommission the proposed 

22 GLE Facility in Wilmington, North Carolina. In support of this proposed action, the U.S. Nuclear 

23 Regulatory Commission (NRC) would grant a license to GLE to possess and use source 

24 material, byproduct, and special nuclear material in accordance with the requirements of 

25 Title 10, “Energy,” Parts 40, 30, and 70 of the U.S. Code of Federal Regulations (10 CFR), 

26 respectively. The proposed GLE Facility would be constructed from 2012–2017, with 

27 preconstruction activities beginning in 2011. The start-up activities would begin in 2013 and 

28 continue until 2017. Full production would be achieved in 2017, and continue through 2051, 

followed by license termination in 2052 and decommissioning.1 29 

30 

31 The principal socioeconomic impact or benefit from the proposed GLE Facility would be an 

32 increase in employment and income in the ROI. Although the majority of the costs and most of 

 

1

 As discussed in Section 4.1, the cost-benefit analysis was based on the assumption that a licensing 

decision would be made in late 2011, construction (if authorized) would start shortly after the licensing 

decision was made, and license termination would occur in 2051. The analysis was also based on the 

assumption that initial operations would begin in 2013, final construction activities would continue from 

2013 to 2017, and that full operations would be achieved in 2017. Subsequently, the Commission’s 

Notice of Hearing and Commission Order (75 FR 1819) specified that a licensing decision be made 

within 30 months of the Order (i.e., June 2012). Thus, the NRC staff currently expects that a licensing 

decision will be made in 2012, construction will begin in 2012, and that termination of the 40-year 

license, if granted, will occur in 2052. The NRC staff expects that the dates for start-up and final 

construction (2013-2017) and full facility operations (2017) will remain unchanged. The NRC staff 

expects that any resulting changes in the licensing and construction schedule would cause slight 

changes to cost–benefit analysis but would not affect the conclusions regarding impacts presented in 

this chapter. Any necessary changes to the analysis will be reflected in the final EIS.
7-3 

1 the socioeconomic impacts of the various phases of GLE facility development would occur in 

2 the ROI, there would be economic, fiscal, and, in particular, energy security benefits, which 

3 would occur at both the local and national level. Therefore, the cost-benefit analysis addresses 

4 a larger area than the ROI, which was considered in the analysis of socioeconomic impacts. 

5 

6 This section describes the costs and benefits of each life-cycle stage of preconstruction and the 

7 proposed action. Quantitative estimates (in terms of dollars) are provided where possible. 

8 Other costs and benefits are described in qualitative terms. 

9 

10 7.2.1 Costs of the Proposed Action 

11 

12 The direct costs associated with the proposed action may be categorized by the following life13 cycle stages: 

14 

15 • construction 

16 

17 • start-up activities 

18 

19 • facility operation 

20 

21 • depleted uranium disposal 

22 

23 • decommissioning 

24 

25 In addition to the costs of the proposed action, costs would be incurred for preconstruction 

26 activities that occur under both the proposed action and no-action alternatives. Because the 

27 monetary costs associated with preconstruction, construction, operations, and decommissioning 

28 phases of the proposed GLE Facility are withheld under the provisions of 10 CFR 2.390, the 

29 costs associated with each of these life-cycle stages are discussed in the proprietary appendix 

30 (Appendix H of this draft EIS) and summarized in Table H-1. 

31 

32 An additional element of the development of the proposed GLE Facility in the Wilmington area 

33 would be the tax incentives provided to GLE by the State of North Carolina and New Hanover 

34 County. It is anticipated that these incentives would amount to up to $26.6 million from the 

35 State, most of which would be payable over a 12-year period; and up to $10 million from the 

36 county, payable over a 10-year period. Both incentives are contingent upon GLE reaching 

37 specified investment and employment levels at the proposed GLE Facility (GLE, 2009b). In the 

38 cost-benefit calculation, the analysis reduced the total cost of construction of the proposed 

39 facility by the amount of these tax incentives, and reduced the county and State tax benefits 

40 from the proposed GLE Facility. 

41 

42 In addition to monetary costs, the proposed action would result in impacts on various resource 

43 areas, which can also be considered “costs” for the purpose of this analysis. The resource 

44 areas and corresponding impacts are summarized below and described in more detail in 

45 Chapter 4 of this draft EIS. The impact of the proposed action is estimated to be SMALL or 

46 SMALL to MODERATE for all resource areas. 

47 
7-4 

1 • Land Use. As described in Section 4.2.1, preconstruction and construction activities 

2 associated with the proposed GLE Facility would include construction of the proposed 

3 facility and associated buildings, storage areas, and parking areas. Impacts during 

4 preconstruction and construction, and operations and decommissioning phases are 

5 expected to be SMALL. 

6 

7 • Historical and Cultural Resources. As described in Section 4.2.2, no direct impacts on 

8 historic and cultural resources are currently expected. However, operations at the proposed 

9 GLE Facility could affect a historic site that was identified on the Wilmington Site if 

10 expansion of the proposed facility was deemed necessary in the future. Because of this 

11 potential impact on one historic site, the overall impacts on the historic and cultural 

12 resources have been categorized as SMALL to MODERATE. However, consultation 

13 between the NRC, the North Carolina State Historic Preservation Office (SHPO), and GLE is 

14 ongoing, and impact levels could be reduced if a plan to mitigate impacts on the identified 

15 historic site is developed and implemented. 

16 

17 • Visual and Scenic Resources. As described in Section 4.2.3, temporary visual impacts may 

18 result from the use of construction cranes during preconstruction and construction activities, 

19 with impacts expected to be SMALL. 

20 

21 • Air Quality. As described in Section 4.2.4, road construction, land-clearing, and building 

22 construction activities are projected to cause a temporary increase in the concentrations of 

23 particulate matter having a mean diameter of 10 micrometers or less (PM10) in the ambient 

24 air that slightly exceed the air quality standard, primarily to the north of the proposed GLE 

25 Facility site. These impacts are expected to be SMALL to MODERATE. 

26 

27 • Geology and Soils. As described in Section 4.2.5, preconstruction activities would require 

28 clearing and grading of approximately 58 hectares (143 acres). Although terrain changes 

29 would be minimal, a short-term increase in soil erosion would occur. Impacts on soils and 

30 geology are expected to be SMALL. 

31 

32 • Surface Water Resources. As described in Section 4.2.6, indirect surface water quality 

33 impacts caused by stormwater runoff from the proposed GLE Facility site would occur, 

34 together with treated wastewater effluent discharges to the effluent channel. These impacts 

35 are expected to be SMALL. 

36 

37 • Groundwater Resources. As described in Section 4.2.7, groundwater used for operations of 

38 the proposed GLE Facility would come from existing groundwater supplies at the site and 

39 would be offset by the industrial reuse of treated sanitary wastewater effluent as process 

40 water. Groundwater flow patterns would remain unchanged, with only a small change in 

41 groundwater elevations. These impacts are expected to be SMALL. 

42 

43 • Ecological Resources. As described in Section 4.2.8, although construction and operation 

44 of the proposed facility would alter the composition of habitat on the site, it would not 

45 destabilize the existence of forested habitats or wildlife communities. Impacts would be 

46 SMALL to MODERATE. 

47 
7-5 

1 • Noise. As described in Section 4.2.9, MODERATE impacts of increased noise are 

2 associated with the operation of preconstruction and construction machinery, and SMALL 

3 impacts are expected from the operation of the proposed GLE Facility itself. 

4 

5 • Traffic. As described in Section 4.2.10, increased truck and car traffic associated with 

6 preconstruction and construction activities, and with transportation of materials, product, and 

7 employees, to and from the proposed GLE Facility could produce SMALL to MODERATE 

8 increases in traffic congestion in the local road network. 

9 

10 • Transportation Accidents. As described in Section 4.2.10, the probability of a severe 

11 transportation accident that releases sufficient quantities of uranium hexafluoride (UF6) that 

12 could pose a health risk is low. The consequences of such an accident, should it occur, are 

13 high. Based on this analysis, the public health impacts associated with such an accident as 

14 part of the proposed action are expected to be SMALL. 

15 

16 • Waste Management. As described in Section 4.2.12, there may be trace radiological 

17 releases from waste streams, primarily during operation of the proposed GLE Facility. In 

18 addition, UF6 tails may remain onsite for an extended period due to inadequate conversion 

19 capacity. These impacts are expected to be SMALL. 

20 

21 • Socioeconomics. As described in Section 4.2.13, employment and income would be 

22 created in the ROI around the proposed GLE Facility site. In-migration into the ROI would 

23 result in socioeconomic impacts, including impacts to housing resources, community, and 

24 social services. These impacts are estimated to be SMALL. 

25 

26 • Environmental Justice. As described in Section 4.2.14, the area surrounding the proposed 

27 GLE Facility site includes a mixture of low-income and minority residents. In these areas, 

28 any adverse environmental impacts from the proposed GLE Facility are not expected to 

29 disproportionately impact low-income or minority populations. Impacts are expected to be 

30 SMALL. 

31 

32 • Facility Accidents. As described in Section 4.2.15, accidents associated with operation of 

33 the proposed GLE Facility could result in SMALL impacts on the workers and the 

34 surrounding public. 

35 

36 7.2.2 Benefits of the Proposed Action 

37 

38 The proposed action would result in an annual peak capacity of 6 million separative work units 

39 (SWU), producing approximately 2.5 million pounds of enriched uranium per year from 2017 

40 through 2051. The benefits to the company will depend on the market price of natural uranium, 

41 the cost to enrich the uranium, and the market price of enriched uranium. 

42 

43 As discussed in Section 1.3, the level of production expected by the proposed GLE facility 

44 would augment the domestic supply of enriched uranium and would assist in meeting the need 

45 for increased domestic supplies of enriched uranium for national energy security. Under the 

46 proposed action, enriched uranium production would be undertaken with the latest enrichment 

47 technology. 

48 
7-6 

1 The proposed action would also result in small positive socioeconomic impacts in the ROI, as 

2 described in Section 4.2.13. Table 7-1 presents the estimated employment and tax revenue 

3 benefits associated with the proposed action. Between 2012 and 2017, average annual direct 

4 employment at the site as a result of construction activities would be 1552 jobs; State direct 

5 income tax revenues would be $0.7 million per year, and State sales tax receipts would be 

$0.5 million per year during construction on average.2,3 6 Start-up activities from 2013 to 2017 are 

7 expected to create 200 annual direct jobs in the ROI, provide $1.3 million to the State in income 

8 tax revenues, and provide $0.9 million in sales tax revenues. During the GLE operations phase 

9 between 2017 and 2051, 350 direct jobs would be created annually. The State would benefit 

10 from $2.3 million in additional income tax, and $1.7 million in sales tax receipts. The 

11 decommissioning phase of the proposed action is expected to create a total of 50 annual direct 

12 jobs, with annual State income and sales tax revenues of $0.3 million and $0.2 million, 

13 respectively. 

14 

15 During the preconstruction phase, 119 jobs would be created; State direct income tax revenues 

16 would be $0.3 million and State sales tax receipts would be $0.2 million. 

17 

18 Between approximately 20 percent and 30 percent of direct State income taxes from the 

19 construction and operation of the proposed GLE Facility would be generated as a result of 

20 wages and salaries paid to GLE employees moving into the ROI from elsewhere. Procurement 

21 of equipment, materials, and services, and the spending of wages and salaries associated with 

22 

Table 7-1 Socioeconomic Benefits Associated with the Proposed GLE Facility 

Project Phase 

Direct and Indirect 

Jobs Created 

(Annual, Full-Time 

Jobs) 

Direct Annual State 

Income 

Tax Revenues 

($ 2008 m)a

Direct Annual State 

Sales Tax 

Revenues 

($ 2008 m) 

Proposed Action 

 Construction 1550b 1.4 1.0 

 Start-up 418 1.3 0.9 

 Facility operation 732 2.3 1.7 

 Decommissioning 83 0.3 0.2 

Preconstruction 119 0.3 0.2 

a

 Includes individual and corporate income taxes. 

b

 Chapter 4 lists 3811 preconstruction and construction jobs, which is the peak number of workers; 1552 

represents the average number of construction jobs. 

Sources: GLE, 2008; 2009b. 

 

2

 All direct income and direct sales tax impact estimates are provided in 2008 dollars. 

3

 The socioeconomic impacts analysis is based on the assumption that the peak construction year will 

be 2012, if a license is granted. The NRC staff expects this assumption would remain accurate 

despite the six-month schedule adjustment discussed in Section 7.2. 
7-7 

1 the construction and operation of the proposed GLE Facility would generate less than one 

2 percent of annual State sales taxes. Corporate income taxes would also be collected by the 

3 State during the facility operational period, and would total an estimated $52.7 million annually. 

4 

5 Although it can be assumed that some portion of State sales and income taxes paid would be 

6 returned to the ROI under revenue-sharing arrangements between each county and the State 

7 government, the exact amount that would be received by each county cannot be determined. 

8 

9 In addition to sales and income taxes, the proposed GLE Facility would also be subject to 

10 property taxes levied by New Hanover County, which were $0.45 per $100 of assessed 

11 valuation in 2009, and by the City of Wilmington, which would levy $0.33 per $100 in addition to 

12 the County tax (see Section 3.13.4). Assuming that assessed valuation equals total capital 

13 investment cost of the proposed GLE Facility, then GLE would pay total property taxes of 

14 $8.7 million annually during the period 2017 to 2051. 

15 

16 Beyond the economic and fiscal benefits of the proposed GLE Facility in the ROI, the proposed 

17 facility would also create fiscal benefits in the nation as a whole, primarily in the form of Federal 

18 income taxes on employee wages and salaries. Based on the distribution of employees in each 

19 salary category at the proposed facility, it is estimated that annual direct individual Federal 

20 income taxes during facility construction would be $1.4 million, with $6.4 million generated 

21 annually during facility operations. Although, as was the case with State taxes, some portion of 

22 Federal income taxes paid by GLE workers would become part of expenditures by various 

23 Federal government programs occurring in the ROI, the exact amount that would be received by 

24 each county cannot be determined. 

25 

26 7.2.3 Summary 

27 

28 This analysis shows that although there are economic and fiscal benefits associated with the 

29 proposed action, these impacts are expected to be SMALL. There would also be costs resulting 

30 from impacts associated with the proposed action on various resource areas that cannot be 

31 expressed in dollar terms. For the majority of these resource areas, impacts are estimated to 

32 be SMALL, or SMALL to MODERATE in magnitude. 

33 

34 7.3 Comparative Cost-Benefit Analysis of Proposed Action Relative to No-Action 

35 Alternative 

36 

37 This section compares the costs and benefits of the proposed action to those of the no-action 

38 alternative. This comparison focuses on the tradeoffs between the proposed GLE Facility 

39 compared to not building the facility. 

40 

41 7.3.1 Methodology 

42 

43 The proposed action and the no-action alternative are first assessed in Section 7.3.2 for 

44 compliance with various policy and technical objectives. The proposed action and the no-action 

45 alternative are then analyzed in Section 7.3.3 for impacts and values across the following 

46 impact areas or attributes: 
7-8 

1 • construction costs 

2 

3 • operating costs 

4 

5 • depleted uranium disposal costs 

6 

7 • decommissioning costs 

8 

9 Costs associated with preconstruction activities were not included in the analysis, as they are 

10 likely to be similar for both the proposed action and the no-action alternative. 

11 

12 The other non-monetary cost areas described in Section 7.2.1 are not included in this 

13 comparison because the effect of these impacts is assumed to be either: (1) approximately 

14 equal for the proposed action and the no-action alternative as defined above or (2) too small of 

15 a differential impact to materially affect the comparative cost-benefit analysis. The NRC staff 

16 assessed impacts and values for these criteria using either: (1) estimated dollars or (2) ordinal 

17 ratings based on expert judgment where quantification is regarded as inappropriate or 

18 unnecessary. This approach is consistent with NRC guidance and is well suited to the current 

19 analysis. 

20 

21 This analysis does not attempt to estimate the economic effects of a cheaper source of enriched 

22 uranium for nuclear power plants, or to estimate the impact of lower enriched uranium prices on 

23 the ratio of nuclear and non-nuclear power in the domestic economy, on overall power demand 

24 and price, and on the potential economic benefits to consumers and suppliers. 

25 

26 7.3.2 Compliance with Policy and Technical Objectives 

27 

28 The following policy and technical objectives are relevant to the choice of an enrichment 

29 technology: 

30 

31 • the need for enriched uranium to fulfill domestic electricity requirements 

32 

33 • the need for domestic supplies of enriched uranium for national energy security 

34 

35 • the need for upgraded uranium enrichment technology in the United States 

36 

37 The following sections compare the proposed action and the no-action alternative in terms of 

38 how well they meet each of these objectives. 

39 

40 7.3.2.1 Meeting Future Demand 

41 

42 As indicated in Section 1.3.1, the demand for enriched uranium in the United States is currently 

43 being met from two categories of sources: 

44 

45 • domestic production of enriched uranium 

46 

47 • foreign sources 

48 
7-9 

1 The current U.S. demand for enriched uranium is 13−14 million SWU per year (EIA, 2008; 

2 EIA, 2009). This demand could reach 15 million to 16 million SWUs by 2025, depending on the 

3 rate of nuclear generation growth in the United States (EIA, 2008). Currently, as much as 

4 85−90 percent of the U.S. demand is supplied by foreign sources. The construction and 

5 operation of the proposed GLE Facility would contribute to reliable domestic supply of enriched 

6 uranium to meet the increased demand for nuclear fuel from the nuclear power industry. This 

7 benefit could potentially be SMALL to MODERATE. 

8 

9 7.3.2.2 National Energy Security 

10 

11 Foreign sources currently supply as much as 85−90 percent of the U.S. demand for enriched 

12 uranium, and all of the domestic production of enriched uranium currently takes place at a single 

13 facility – the Paducah Gaseous Diffusion Plant. It is anticipated that all gaseous diffusion 

14 enrichment operations in the United States will cease in the near future due to the higher cost of 

15 aging facilities (DOE, 2007). Furthermore, the Megatons-to-Megawatts Program is scheduled to 

16 expire in 2013 (DOE, 2010). As noted in Section 1.3.1, these two sources meet approximately 

17 half of the current U.S. demand for low-enriched uranium (LEU). As a result, new domestic 

18 sources of enriched uranium are needed to reliably provide fuel to both existing and future 

19 nuclear power plants in the United States. Therefore, the projected 6 million SWU production 

20 capacity resulting from the proposed action could be important for increasing the nation’s 

21 energy security. This benefit could potentially be SMALL to MODERATE. 

22 

23 7.3.2.3 Technology Upgrade 

24 

25 The proposed action represents the implementation of a new uranium enrichment technology, 

26 with gaseous diffusion technology currently the only technology in commercial use in the 

27 United States. Gas centrifuge technology, which will be used at the National Enrichment Facility 

28 (NEF), American Centrifuge Plant (ACP), and proposed Eagle Rock Enrichment Facility 

29 (EREF), is known to be more efficient and substantially less energy-intensive than gaseous 

30 diffusion technology. The GLE laser-based technology that would be deployed at the proposed 

31 GLE Facility is newer than gas centrifuge technology, and GE-Hitachi expects it to offer certain 

32 advantages over both the gaseous diffusion and gas centrifuge processes (GLE, 2008). This 

33 could potentially result in a SMALL to MODERATE impact. 

34 

35 7.3.3 Impacts and Value Analysis 

36 

37 A comparison of the impacts and values of the proposed action and the no-action alternative 

38 would include the following cost and categories: 

39 

40 • construction costs 

41 

42 • operating costs 

43 

44 • depleted uranium disposal costs 

45 

46 • decommissioning costs 

47 
7-10 

1 As the monetary costs associated with preconstruction, construction, operations, and 

2 decommissioning phases of the proposed GLE Facility are proprietary and withheld under the 

3 provisions of 10 CFR 2.390, the costs associated with each of these life-cycle stages are 

4 discussed in a proprietary appendix (Appendix H) and summarized in Table H-1. 

5 

6 7.3.4 Summary Regarding the Proposed Action versus the No-Action Alternative 

7 

8 Based on consideration of local and national socioeconomic benefits, the costs of construction 

9 and operation of the proposed GLE Facility on a range of environmental resources, and on 

10 public and occupational health, the proposed action is preferable relative to the no-action 

11 alternative in the following respects: 

12 

13 • The proposed action would contribute to meeting future demand from domestic sources and 

14 increase national energy security. It would also introduce a newer technology with potential 

15 to have smaller resource requirements and environmental impacts in the United States to 

16 fulfill these needs. 

17 

18 • The proposed action would have positive impacts in the ROI on employment, income, and 

19 tax revenues during the construction, operations, and decommissioning phases (as 

20 discussed in Sections 4.2.13 and 4.2.17.12), and on State and Federal income tax 

21 revenues. 

22 

23 7.4 Overall Cost-Benefit Conclusions 

24 

25 While there are national energy security and fiscal benefits associated with the proposed action, 

26 and local socioeconomic benefits in the ROI, there are also direct costs associated with the 

27 construction and operation phases of the proposed action, as well as impacts associated with 

28 the proposed action on various resource areas. However, these impacts are estimated to be 

29 SMALL to MODERATE in magnitude and small in comparison to the local and national benefits 

30 of the proposed action. In addition, many of the impacts on environmental resources associated 

31 with the proposed action relate to preconstruction activities at the proposed facility site, and 

32 would also occur under the no-action alternative. 

33 

34 Although the no-action alternative would include the continuation of uranium enrichment using 

35 gaseous diffusion, the development of new facilities based on gas centrifuge technology, and 

36 imported enriched uranium supplies, the proposed action would better satisfy the objectives to 

37 meet future demand for enriched uranium and improve national energy security. It is therefore 

38 apparent that in comparison to the no-action alternative, the proposed action would be 

39 associated with net positive benefits. 

40 

41 7.5 References 

42 

43 (DOE, 2002) U.S. Department of Energy. Letter from W.J. Magwood, IV (U.S. Department of 

44 Energy) to M.J. Virgilio (U.S. Nuclear Regulatory Commission) dated July 25. ADAMS 

45 Accession No. ML022350130. 

46 
7-11 

1 (DOE, 2007) U.S. Department of Energy. “Uranium Enrichment Decontamination & 

2 Decommissioning Fund: 2007 Report to Congress.” <http://www.em.doe.gov/pdfs/5th_ 

3 Triennial_Report_Final.pdf> (Accessed October 30, 2009). 

4 

5 (DOE, 2010) U.S. Department of Energy, National Nuclear Security Administration. 

6 “U.S.-Russian Highly Enriched Uranium Purchase Agreement.” January. 

7 <http://www.nnsa.energy.gov/nuclear_nonproliferation/highly_enriched_uranium_disposition. 

8 htm> (Accessed January 28, 2010). 

9 

10 (EIA, 2008) Energy Information Administration, U.S. Department of Energy. “2007 Uranium 

11 Marketing Annual Report.” May. <http://tonto.eia.doe.gov/FTPROOT/nuclear/umar2007.pdf> 

12 (Accessed October 9, 2009). 

13 

14 (EIA, 2009) Energy Information Administration, U.S. Department of Energy. “Uranium 

15 Marketing Annual Report 2008.” May 26. <http://tonto.eia.doe.gov/FTPROOT/nuclear/ 

16 umar2008.pdf> (Accessed February 5, 2010). 

17 

18 (GLE, 2008) GE-Hitachi Global Laser Enrichment LLC. “Environmental Report for the GLE 

19 Commercial Facility, Revision 0.” December. ADAMS Accession No. ML090910573. 

20 

21 (GLE, 2009a) GE-Hitachi Global Laser Enrichment LLC. “GE-Hitachi Global Laser Enrichment 

22 LLC Commercial Facility, Wilmington, North Carolina: License Application April 2009.” April 30. 

23 ADAMS Accession No. ML091871003. 

24 

25 (GLE, 2009b) GE-Hitachi Global Laser Enrichment LLC. Letter from A. Kennedy (GE-Hitachi 

26 Global Laser Enrichment LLC ) to A. Kock (U.S. Nuclear Regulatory Commission) dated 

27 November 5. “Subject: GE-Hitachi Global Laser Enrichment Response to Request for 

28 Additional Information Related to NRC Review of GLE Environmental Report.” ADAMS 

29 Accession No. ML093200137. 

30 

31 (NRC, 2006) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for the 

32 Proposed American Centrifuge Plant in Piketon, Ohio.” NUREG-1834. April. 

33 <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1834> (Accessed 

34 October 9, 2009). 

35 
7-12 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 [This page intentionally left blank] 
8-1 

1 8 SUMMARY OF ENVIRONMENTAL CONSEQUENCES 

2 

3 On January 30, 2009, General Electric (GE)-Hitachi Global Laser Enrichment LLC (GLE) 

4 submitted an environmental report (GLE, 2008) to the U.S. Nuclear Regulatory Commission 

5 (NRC) in anticipation of its application for a license to construct, operate, and decommission the 

6 GLE Commercial Facility near Wilmington, North Carolina. If licensed, the proposed GLE 

7 Facility would enrich uranium for use in commercial nuclear fuel for power reactors. Feed 

8 material would be comprised of non-enriched uranium hexafluoride (UF6). GLE would employ a 

9 laser-based enrichment process to enrich uranium to up to 8 percent uranium-235 by weight 

10 with an initial planned maximum target production of 6 million separative work units (SWUs) per 

11 year. The proposed GLE Facility would be licensed in accordance with the provisions of the 

12 Atomic Energy Act. Specifically, an NRC license under Title 10, "Energy," of the U.S. Code of 

13 Federal Regulations (10 CFR) Parts 30, 40, and 70 would be required to authorize GLE to 

14 possess and use byproduct material, source material, and special nuclear material at the 

15 proposed GLE Facility. 

16 

17 GLE expects to begin preconstruction activities in 2011. If the license application is approved, 

18 facility construction would begin in 2012 and continue for six years. GLE anticipates 

19 commencing initial production in 2013 and reaching full production in 2017. Prior to license 

20 expiration in 2052, GLE would decide to seek to renew its license to continue operating the 

21 facility, or plan for the decontamination and decommissioning of the facility per the applicable 

22 licensing conditions and NRC regulations. 

23 

24 Section 102 of the National Environmental Policy Act (NEPA) of 1969, as amended (42 USC 

25 4321 et seq.), directs that an environmental impact statement (EIS) is required for major Federal 

26 actions that significantly affect the quality of the human environment. Section 102(2)(C) of 

27 NEPA requires that an EIS include information about the following: 

28 

29 • the environmental impacts of the proposed action; 

30 

31 • any adverse environmental effects that cannot be avoided should the proposal be 

32 implemented; 

33 

34 • alternatives to the proposed action; 

35 

36 • the relationship between local short-term uses of the environment and the maintenance and 

37 enhancement of long-term productivity; and 

38 

39 • any irreversible and irretrievable commitments of resources that would be involved if the 

40 proposed action is implemented. 

41 

42 NRC’s regulations under 10 CFR Part 51 implement the requirements of the NEPA, as 

43 amended (Public Law 91-190). In particular, 10 CFR 51.20 (b)(10) states that issuance of a 

44 license for a uranium enrichment facility requires the NRC to prepare an EIS. 

45 

46 GLE submitted a license application for the proposed GLE Facility on June 26, 2009. GLE 

47 proposes to co-locate the facility on the existing General Electric Company (GE)/Global Nuclear 

48 Fuel-Americas (GNF-A) site near Wilmington, North Carolina. On May 8, 2009, the NRC 
8-2 

1 granted an exemption authorizing GLE to conduct preconstruction activities on the Wilmington 

2 Site. Subsequently, GLE submitted Supplement 1 to its environmental report on July 13, 2009 

3 (GLE, 2009a), which distinguishes between the environmental impacts of preconstruction 

4 activities and those of NRC-licensed construction activities, which cannot be undertaken unless 

5 a license is granted. On November 13, 2009, GLE submitted Supplement 2 to its environmental 

6 report (GLE, 2009b), which provides information describing the environmental impacts 

7 associated with revising the location of the Wilmington Site entrance and roadway to the 

8 proposed GLE site. 

9 

10 Upon acceptance of the environmental report, the NRC began the environmental review 

11 process described in 10 CFR Part 51 by publishing, on April 9, 2009, a Notice of Intent to 

12 prepare an EIS and conduct scoping (Volume 74, page 45075, of the Federal Register 

13 [74 FR 16237]). The NRC staff held two public scoping meetings on May 19, 2009. The NRC 

14 also met with local officials and conducted a site visit and technical meetings with GLE on 

15 May 18–20, 2009. Due to a delay in submission of the license application, the NRC extended 

16 the conclusion of the public scoping comment period from June 8, 2009, to August 31, 2009 

17 (74 FR 36781). 

18 

19 The NRC staff reviewed GLE’s environmental report and supplemental documentation, and 

20 consulted with other Federal, State, and local agencies, and Tribal organizations. The NRC 

21 staff also considered the public comments received during the scoping process for preparation 

22 of this draft EIS; these comments are provided in Appendix A. The NRC staff issued a Scoping 

23 Summary Report in November 2009. 

24 

25 Included in this draft EIS are (1) the results of the NRC staff’s preliminary analyses, which 

26 consider and weigh the environmental effects of the proposed action; (2) mitigation measures 

27 for reducing or avoiding adverse effects; (3) the environmental impacts of alternatives to the 

28 proposed action; and (4) the NRC staff’s preliminary recommendation regarding the proposed 

29 action based on its environmental review. 

30 

31 The NRC defines three significance levels for rating impacts on a resource (10 CFR Part 51, 

32 Subpart A, Appendix B): 

33 

34 • SMALL – Environmental effects are not detectable or are so minor that they will neither 

35 destabilize nor noticeably alter any important attribute of the resource. 

36 

37 • MODERATE – Environmental effects are sufficient to alter noticeably, but not to destabilize, 

38 important attributes of the resource. 

39 

40 • LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

41 important attributes of the resource. 

42 

43 Mitigation measures were considered for each environmental issue and are discussed in 

44 Chapters 4 and 5 of this draft EIS. During its environmental review, the NRC considered 

45 planned activities and actions that GLE indicates it and others would likely take should GLE 

46 receive a license. In addition, GLE provided estimates of the environmental impacts resulting 

47 from construction and operation of the proposed GLE Facility at the Wilmington Site. 

48 
8-3 

1 In a final rule dated October 9, 2007 (72 FR 57416), the Commission limited the definition of 

2 “construction” to those activities that fall within its regulatory authority (10 CFR 51.4). Many of 

3 the activities required to build a proposed nuclear facility are not part of the NRC action to 

4 license the facility. Activities associated with construction of a facility that are not within the 

5 purview of the NRC action are grouped under the term “preconstruction.” Preconstruction 

6 activities include clearing and grading, excavating, erection of support buildings and 

7 transmission lines, and other associated activities. Although preconstruction activities are not 

8 part of the NRC action, they support or are requisite to the NRC action. In addition, certain 

9 preconstruction activities require permits from other Federal, State, and local agencies. 

10 

11 8.1 Unavoidable Adverse Environmental Impacts 

12 

13 Section 102(2)(C)(ii) of NEPA requires that an EIS include information about any adverse 

14 environmental effects that cannot be avoided should the proposal be implemented. 

15 Unavoidable adverse environmental impacts are those potential impacts of the NRC action that 

16 cannot be avoided and for which no practical means of mitigation are available. 

17 

18 The environmental impacts associated with the proposed action and the no-action alternative 

19 are described in detail for each resource area in Chapter 4. The impacts of the two alternatives 

20 are summarized and compared in Section 2.4. Brief summaries of the impacts are also 

21 provided in Chapter 7 under the Cost-Benefit Analysis and in the Executive Summary. 

22 Chapter 4 discusses the mitigation measures that GLE proposed in its environmental report to 

23 mitigate the potential impacts from the proposed action and the measures that NRC 

24 recommends to further reduce the potential impacts on the affected environment. These two 

25 sets of mitigation measures are summarized in Tables 5-1 and 5-2, respectively. The 

26 cumulative impacts on the environment that would result from the proposed action when added 

27 to other past, present, and reasonably foreseeable future actions, regardless of what agency or 

28 person undertakes such action, are described in Section 4.3. As discussed in Chapter 4, the 

29 environmental impacts that would result if the proposed action were to be implemented as 

30 proposed by GLE would generally be SMALL, and would, in most cases, be mitigated by the 

31 methods proposed by GLE. The only impacts that could potentially be classified as 

32 MODERATE would be in the following resource areas: historic and cultural resources, 

33 ecological resources, and transportation. In addition, air quality and noise impacts could be 

34 MODERATE on a temporary basis during preconstruction and construction activities. 

35 

36 The impact level on historic and cultural resources has been classified as SMALL to 

37 MODERATE because operations at the proposed GLE facility could affect the historic site 

38 31NH801 on the Wilmington Site if expansion of the plant was deemed necessary in the future. 

39 The North Carolina State Historic Preservation Office (SHPO) asked to review the measures 

40 that will be taken by GLE to ensure protection and preservation of site 31NH801 from future 

41 ground-disturbing activities (NCDCR, 2009). Consultation between the NRC, North Carolina 

42 SHPO, and GLE is ongoing. Impact levels could be reduced if a plan for site 31NH801 is 

43 developed and implemented. 

44 

45 The impact level on ecological resources has been classified as SMALL to MODERATE, mainly 

46 due to clearing of land that would occur during preconstruction activities. 

47 
8-4 

1 The transportation impacts on local roads in the immediate vicinity of the Wilmington Site could 

2 be SMALL to MODERATE due to increases in traffic density during certain phases of the 

3 proposed action (e.g., during construction and when the construction and operations overlap 

4 during late 2013 to 2017) and due to other reasonably foreseeable actions (e.g., the 

5 development of a retirement community to the south of the Wilmington Site). The regional 

6 transportation impacts would be classified as SMALL. 

7 

8 The ground-disturbing activities during preconstruction and construction activities could result in 

9 increased fugitive dust emissions and cause MODERATE air quality impacts. Similarly, noise 

10 generated by ground-clearing and construction equipment could raise the noise levels to a 

11 range considered to be MODERATE impact. However, both the air quality and noise impacts 

12 would be at the MODERATE level only temporarily. The majority of the time, these impacts 

13 would be considered to be SMALL. 

14 

15 8.2 Relationship between Local Short-Term Uses of the Environment and the 

16 Maintenance and Enhancement of Long-Term Productivity 

17 

18 Consistent with the Council on Environmental Quality (CEQ) definition and the definition 

19 provided in Section 5.8 of NUREG-1748 (NRC, 2003), this draft EIS defines short-term uses 

20 and long-term productivity as follows: 

21 

22 • Short-term uses generally affect the present quality of life for the public (i.e., the 40-year 

23 license period for the proposed GLE Facility). 

24 

25 • Long-term productivity affects the quality of life for future generations on the basis of 

26 environmental sustainability (i.e., the period after license termination for the proposed GLE 

27 Facility). 

28 

29 The construction and operation of the proposed GLE Facility would necessitate short-term 

30 commitments of resources and would permanently commit certain other resources (such as 

31 energy and water). The short-term use of resources would result in potential long-term 

32 socioeconomic benefits to the local area and the region. The short-term commitments of 

33 resources would include the use of materials required to construct new buildings, the new 

34 operations support facilities, transportation, and other disposal resources and materials for 

35 proposed GLE Facility operations. 

36 

37 Workers, the public, and the environment would be exposed to increased amounts of hazardous 

38 and radioactive materials over the short term from operations of the proposed GLE Facility and 

39 the associated materials, including process emissions and the handling of waste and depleted 

40 uranium hexafluoride (UF6) cylinders. Construction and operation of the proposed GLE Facility 

41 would require a long-term commitment of terrestrial resources, such as land, water, and energy. 

42 Short-term impacts would be minimized by the application of proper mitigation measures and 

43 resource management. Upon the closure of the proposed GLE Facility, GLE would 

44 decontaminate and decommission the buildings and equipment and restore them for 

45 unrestricted use. This work would make the site available for other uses. The use of the site 

46 and the buildings for other industrial purposes would constitute a long-term benefit to the 

47 community and would increase long-term productivity. Continued employment, expenditures, 
8-5 

1 and tax revenues generated during the implementation of the proposed action would directly 

2 benefit the local, regional, and state economies and would be considered a long-term benefit. 

3 

4 8.3 Irreversible and Irretrievable Commitment of Resources 

5 

6 Irreversible commitment of resources refers to resources that are destroyed and cannot be 

7 restored, whereas an irretrievable commitment of resources refers to material resources that 

8 once used cannot be recycled or restored for other uses by practical means (NRC, 2003). 

9 The implementation of the proposed action as described in Section 2.1 would include the 

10 commitment of land, water, energy, raw materials, and other natural and manmade resources. 

11 About 40 hectares (100 acres) on the 656-hectare (1621-acre) site would be used for the 

12 construction and operation of the proposed GLE Facility. The applicant stated in its ER that 

13 it plans to decontaminate and decommission the proposed facility for unrestricted use 

14 (GLE, 2008). Given the Wilmington Site’s current land use zoning, the 40-hectare (100-acre) 

15 parcel of land would likely remain industrial beyond license termination. Water required during 

16 the entire proposed action, including preconstruction and construction, operation, and 

17 decontamination and decommissioning, would be obtained from the existing wells at the 

18 Wilmington Site and would be replenished through natural mechanisms. The wastewaters that 

19 are generated would be treated to meet applicable standards and would be released to local 

20 receiving surface waters. The energy used in the form of electricity, natural gas, and diesel fuel 

21 would be supplied through existing systems in the Wilmington area. The specific types of 

22 construction materials and the quantities of energy and materials used cannot be determined 

23 with certainty until the final facility design is completed. However, it is not expected that the 

24 quantities required would put any strains on the availability of these resources. 

25 

26 Even though the land on the Wilmington Site used to construct the proposed GLE Facility would 

27 be returned to other productive uses after the facility is decommissioned, there would be some 

28 irreversible commitment of land at some offsite locations used to dispose of solid wastes 

29 generated at the proposed GLE Facility. In addition, wastes generated during the conversion of 

30 depleted UF6 produced at the proposed GLE Facility and the depleted uranium oxide 

31 conversion product from the depleted UF6 conversion would be disposed of at an offsite location 

32 (see Section 2.1.3). The land used for the disposal of these materials would also represent an 

33 irreversible commitment of land. No solid wastes or depleted uranium oxide conversion product 

34 originating from the proposed GLE Facility would be disposed of at the Wilmington Site. 

35 

36 When the facility is decommissioned, some of the materials used in its construction, such as 

37 concrete, steel, other metals, plastics, and other materials, would be recycled and reused. 

38 Other materials would be disposed of in a licensed and approved offsite location. The amount 

39 of land used to dispose of these materials would also be an irretrievable land resource. 

40 

41 During the operation of the proposed GLE Facility, natural UF6 would be used as the feed 

42 material. This would require the mining of uranium and several other operational steps in the 

43 uranium fuel cycle that result in the production of UF6. The use of uranium minerals would be 

44 an irretrievable resource commitment. There would also be other irreversible and irretrievable 

45 commitments of resources during uranium fuel cycle operations that result in the production of 

46 natural UF6 feed. As shown in Figure 1-3, there are several fuel cycle operations leading up to 

47 the production of the natural UF6 that feeds enrichment operations. These steps include the 

48 mining and processing of uranium ore, which results in the production of natural triuranium 
8-6 

1 octaoxide (U3O8), and conversion of natural U3O8 to UF6. All the materials and energy used in 

2 the construction and operation of the facilities used to mine and process the uranium ore, and 

3 convert natural U3O8 to natural UF6, would constitute irreversible and irretrievable commitment 

4 of resources. 

5 

6 8.4 References 

7 

8 (GLE, 2008) GE-Hitachi Global Laser Enrichment LLC. “Environmental Report for the 

9 GLE Commercial Facility, Revision 0.” December. ADAMS Accession No. ML090910573. 

10 

11 (GLE, 2009a) GE-Hitachi Global Laser Enrichment LLC. “Environmental Report Supplement 1 

12 – Early Construction.” July. ADAMS Accession No. ML092100528. 

13 

14 (GLE, 2009b) GE-Hitachi Global Laser Enrichment LLC. “Global Laser Enrichment 

15 Environmental Report Supplement 2.” November. ADAMS Accession No. ML093240935. 

16 

17 (NRC, 2003) U.S. Nuclear Regulatory Commission. “Environmental Review Guidance for 

18 Licensing Actions Associated with NMSS Programs.” NUREG-1748. August. 

19 <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1748.pdf> (Accessed 

20 January 29, 2010). 

21 

22 (NCDCR, 2009) North Carolina Department of Cultural Resources, State Historic Preservation 

23 Office. Letter from P. Sandbeck to (NCDCR) A. Kock (U.S. Nuclear Regulatory Commission) 

24 dated June 2. ADAMS Accession No. ML091630258. 

25 
9-1 

1 9 AGENCIES AND PERSONS CONSULTED 

2 

3 The following sections list the agencies and persons consulted for information and data for use 

4 in the preparation of this draft Environmental Impact Statement (draft EIS): 

5 

6 9.1 Federal Agencies 

7 

8 U.S. Army Corps of Engineers, Wilmington Regulatory Office, Wilmington, North Carolina 

9 Keith Harris, Chief 

10 Jennifer Frye, Project Manager 

11 

12 U.S. Fish and Wildlife Service, Raleigh Field Office, Raleigh, North Carolina 

13 Howard Hall, Fish and Wildlife Biologist 

14 John Hannon, Fish and Wildlife Biologist 

15 

16 9.2 Indian Tribes and Organizations 

17 

18 Coharie Indian Tribe, Clinton, North Carolina 

19 Gene Faircloth, Chief 

20 Elizabeth Maynor, Executive Director 

21 

22 Cumberland County Association for Indian People, Fayetteville, North Carolina 

23 Roy Maynor, Chairman 

24 Gladys Hunt, Executive Director 

25 

26 Eastern Band of Cherokee, Cherokee, North Carolina 

27 Leon Jones, Principal Chief 

28 

29 Guilford Native American Association, Greensboro, North Carolina 

30 Rick Oxendine, Executive Director 

31 

32 Haliwa-Saponi Indian Tribe, Hollister, North Carolina 

33 Ruth Ealing, Chairperson 

34 Archie Lynch, Tribal Administrator 

35 

36 Sappony, Roxboro, North Carolina 

37 Dante Desiderio, Executive Director 

38 

39 Lumbee Indian Tribe, Pembroke, North Carolina 

40 Milton Hunt, Chairman 

41 Darlene Jacobs, Tribal Administrator 

42 

43 Meherrin Indian Tribe, Winton, North Carolina 

44 Denyce Hall, Executive Director 

45 

46 Metrolina Native American Association, Charlotte, North Carolina 

47 Letha Strickland, Executive Director 

48 
9-2 

1 Triangle Native American Society, Raleigh, North Carolina 

2 Brett Locklear, President 

3 

4 Waccamaw Siouan Indian Tribe, Bolton, North Carolina 

5 Sabrina Jacobs, Executive Director 

6 

7 Eastern Band of Cherokee Indian, Cherokee, North Carolina 

8 Russ Townsend, Tribal Historic Preservation Officer 

9 

10 Catawba Indian Tribe, Catawba, South Carolina 

11 Wenonah Haire, Tribal Historic Preservation Officer 

12 

13 United Keetoowah Band of Cherokee, Tahlequah, Oklahoma 

14 Lisa C. Stopp, Tribal NAGPRA Point of Contact 

15 

16 Cherokee Nation of Oklahoma, Tahlequah, Oklahoma 

17 

18 Tuscarora Nation, Lewiston, New York 

19 Leo Henry, Chief 

20 

21 9.3 State Agencies 

22 

23 North Carolina Department of Administration, State Environmental Review Clearinghouse, 

24 Raleigh, North Carolina 

25 Valeria McMillan, Director 

26 

27 North Carolina Department of Environment and Natural Resources, Raleigh, North Carolina 

28 Melba McGee, Environmental Review Coordinator 

29 

30 North Carolina Department of Environment and Natural Resources, Division of Air Quality 

31 Dean Carroll, Permit Coordinator 

32 

33 North Carolina Department of Environment and Natural Resources, Division of Coastal 

34 Management, Morehead City, North Carolina 

35 Steven Everhart, District Manager 

36 Stephen Rynas, Federal Consistency Coordinator 

37 

38 North Carolina Department of Environment and Natural Resources, Division of Environmental 

39 Health, Radiation Protection Section, Emergency Response and Environmental Branch, 

40 Raleigh, North Carolina 

41 Dale Dusenberry, Manager 

42 

43 North Carolina Department of Environment and Natural Resources, Division of Inactive 

44 Hazardous Sites 

45 Ginny Henderson, Hydrogeological Technician 

46 
9-3 

1 North Carolina Department of Environment and Natural Resources, Division of Water Quality, 

2 Basinwide Planning Unit and SEPA Program, Raleigh, North Carolina 

3 Hannah Stallings, SEPA Coordinator 

4 

5 North Carolina Department of Environment and Natural Resources, Division of Surface Water 

6 Protection 

7 Rhonda Hall, Environmental Engineer 

8 Linda Willis, Environmental Engineer 

9 

10 North Carolina Department of Environment and Natural Resources, Division of Waste 

11 Management, Eastern Region Compliance Branch 

12 Ted Cashion, Supervisor 

13 

14 North Carolina Department of Environment and Natural Resources, Division of Waste 

15 Management, Solid Waste Section 

16 Dennis Shackelford, Central District Supervisor 

17 

18 North Carolina Department of Environment and Natural Resources, Division of Waste 

19 Management, Superfund Section 

20 S. Franch, Environmental Chemist 

21 

22 North Carolina Department of Environment and Natural Resources, One-Stop/Express 

23 Permitting 

24 Cameron Weaver, Coordinator 

25 

26 North Carolina Department of Labor 

27 Kevin O’Barr, Standards Supervisor 

28 Jennifer Chrisohon, Deputy General Counsel 

29 Ric Schumann, Industrial Hygienist 

30 Wanda Lagoe, Bureau Chief, Education, Training, and Technical Assistance 

31 Lafayette Atkinson, District 10 Supervisor, Compliance Bureau 

32 

33 North Carolina Division of Historical Resources, Raleigh, North Carolina 

34 

35 North Carolina Department of Cultural Resources, State Historic Presentation Office, Raleigh, 

36 North Carolina 

37 Renee Gledhill-Early, Environmental Review Coordinator 

38 Dolores Hall, Deputy State Archaeologist 

39 

40 North Carolina Wildlife Resources Commission, Raleigh, North Carolina 

41 Molly Ellwood, Southeastern Permit Coordinator 

42 

43 9.4 Local Agencies 

44 

45 Cape Fear River Watch, Wilmington, North Carolina 

46 Doug Springer, Executive Director/Riverkeeper 

47 
9-4 

1 New Hanover County, Wilmington, North Carolina 

2 David F. Weaver, Assistant County Manager 

3 

4 New Hanover County Soil and Water Conservation District, Wilmington, North Carolina 

5 Jennifer Braswell, Director, Community Conservation 

6 

7 New Hanover County Planning Department, Wilmington, North Carolina 

8 Sam Burges, Principal Development Planner 

9 Wanda B. Coston, Community Development Planner 

10 Jane Daughtridge, Senior Planner 

11 Chris B. O’Keefe, Planning Director 

12 Shawn Ralston, Senior Environmental Planner 

13 

14 New Hanover County Engineering Department, Wilmington, North Carolina 

15 James P. Iannucci, Chief Project Engineer 

16 Dennis Ihnat, Director 

17 Beth E. Wetherill, Erosion Control Engineer 

18 
10-1 

1 10 LIST OF PREPARERS 

2 

3 10.1 U.S. Nuclear Regulatory Commission (NRC) Contributors 

4 

5 Jennifer A. Davis 

6 B.A., Historic Preservation and Classical Civilization (Archaeology), Mary Washington 

7 College, 1996 

8 Years of Relevant Experience: 8 

9 

10 A. Christianne Ridge 

11 B.A., Physics, Drew University, 1996 

12 M.S., Environmental Engineering, Cornell University, 1999 

13 Ph.D., Environmental Engineering, University of California-Berkeley, 2004 

14 Years of Relevant Experience: 6 

15 

16 Behram Shroff 

17 M.C.P., City/Regional Planning, Georgia Tech, 1973 

18 M.S., Electrical Engineering, University of California-Berkeley, 1966 

19 Years of Relevant Experience: 2 

20 

21 Haimanot Yilma 

22 B.S., Chemical Engineering, University of Maryland-College Park, 1998 

23 M.B.A., University of Maryland at College Park, 2010 

24 Years of Relevant Experience: 1 

25 

26 10.2 Argonne National Laboratory (Argonne) Contributors 

27 

28 Tim Allison: Socioeconomics, environmental justice, cost-benefit analysis 

29 B.A., Economics and Geography, Portsmouth Polytechnic, (U.K.), 1982 

30 M.A., Geography, West Virginia University, 1987 

31 M.S., Mineral and Energy Resource Economics, West Virginia University, 1990 

32 Years of Relevant Experience: 25 

33 

34 Halil Avci: Argonne Project Team Lead 

35 B.S., Nuclear Engineering, University of Wisconsin-Madison, 1973 

36 M.S., Nuclear Engineering, University of Wisconsin-Madison, 1975 

37 Ph.D., Nuclear Engineering, University of Wisconsin-Madison, 1978 

38 Years of Relevant Experience: 24 

39 

40 Bruce Biwer: Transportation, waste management, accidents 

41 B.A., Chemistry, St. Anselm College, 1980

42 M.S., Chemistry, Princeton University, 1983 

43 Ph.D., Chemistry, Princeton University, 1985 

44 Years of Relevant Experience: 19

45 
10-2 

1 Young-Soo Chang: Air quality, noise 

2 B.S., Chemical Engineering, Seoul National University, Korea, 1977 

3 M.S., Chemical & Materials Engineering, University of Iowa, 1984 

4 Ph.D., Chemical & Materials Engineering, University of Iowa, 1987 

5 Years of Relevant Experience: 21 

6 

7 Victor Comello, Technical editing 

8 B.S., Physics, DePaul University, 1962 

9 M.S., Physics, University of Notre Dame, 1970 

10 Years of Relevant Experience: 33 

11 

12 Karl Fischer: Argonne Deputy Team Lead, Document Manager 

13 B.S.E., Nuclear Engineering, University of Michigan, 1995 

14 M.Eng., Radiological Health Engineering, University of Michigan, 1996 

15 Years of Relevant Experience: 12 

16 

17 Elizabeth Hocking: Environmental regulations/permits 

18 B.A., Psychology and English, University of Wisconsin-Eau Claire, 1971 

19 M.A., Guidance and Counseling, University of Wisconsin-Oshkosh, 1973 

20 J.D., Washington College of Law, American University, 1991 

21 Years of Relevant Experience: 19 

22 

23 Pat Hollopeter: Technical editing 

24 B.A., Religion, West Virginia Wesleyan College, 1970 

25 M.A., Philosophy, University of Chicago, 1979 

26 Years of Relevant Experience: 25 

27 

28 Sunita Kamboj: Health physics, decommissioning, accidents 

29 B.Sc., Science, Rajasthan University, 1972 

30 M.Sc., Physics, Rajasthan University, 1974 

31 M.S., Health Physics, Georgia Institute of Technology, 1990 

32 Ph.D., Health Physics, Georgia Institute of Technology, 1994 

33 Years of Relevant Experience: 15 

34 

35 Dan O’Rourke: Cultural resources, land use 

36 B.A., History, Michigan State University, 1991 

37 M.S., Industrial Archaeology, Michigan Technological University, 1997 

38 Years of Relevant Experience: 17 

39 

40 Kurt Picel: Chemical risks and accidents, and cumulative impacts 

41 B.S., Chemistry, Western Michigan University, 1976 

42 M.S., Environmental Health Sciences, University of Michigan, 1979 

43 Ph.D., Environmental Health Sciences, University of Michigan, 1985 

44 Years of Relevant Experience: 24 

45 
10-3 

1 John Quinn: Hydrology, geology and soils 

2 B.S., Geosciences, Purdue University, 1987 

3 B.S.E., Geo-Engineering, Purdue University, 1988 

4 M.S., Hydrogeology, University of Minnesota, 1992 

5 Ph.D., Hydrogeology, University of Minnesota, 2009 

6 Years of Relevant Experience: 19 

7 

8 William Vinikour: Ecology 

9 B.S., Biology, Northern Illinois University-DeKalb, 1971 

10 M.S., Biology with Environmental Emphasis, Northern Illinois University-DeKalb, 1977 

11 Years of Relevant Experience: 34 

12 

13 Suzanne Williams: Technical editing (Lead Editor) 

14 B.S., Communication Studies w/concentration in English, 

15 Northwestern University, 1980 

16 Years of Relevant Experience: 25 
10-4 

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3 

4 

5 

6 

7 

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11 

12 

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15 
A-1 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 APPENDIX A 

15 SCOPING FOR THIS ENVIRONMENTAL IMPACT STATEMENT 
A-2 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 [This page intentionally left blank] 

15 
A-3 
A-4 
A-5 
A-6 
A-7 
A-8 
A-9 
A-10 
A-11 
A-12 
A-13 
A-14 
A-15 
A-16 

1 

2 

3 

4 

5 

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7 

8 

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14 [This page intentionally left blank] 

15 
B-1 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 APPENDIX B 

15 CONSULTATION LETTERS 
B-2 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 [This page intentionally left blank] 
B-3 

1 B.1 Endangered Species Act Consultation Letters 

2 

3 The U.S. Nuclear Regulatory Commission (NRC) sent coordination letters to the U.S. Fish and 

4 Wildlife Service (Raleigh Field Office) and the National Marine Fisheries Service (Southeast 

5 Regional Office) related to threatened and endangered species and critical habitats. All of the 

6 NRC letters and agency responses can be accessed via NRC’s online document retrieval 

7 system (ADAMS) using the accession numbers in Table B-1. 

8 

Table B-1 Consultations with Government Agencies Related to Threatened and 

Endangered Species and Critical Habitats 

Agency (Date) ADAMS Accession Number(s) 

U.S. Fish and Wildlife Service, Raleigh Field Office (May 1, 2009) ML091100107 

Response from U.S. Fish and Wildlife Service, Raleigh Field 

Office (June 8, 2009) 

ML091700024 

U.S. Fish and Wildlife Service, Raleigh Field Office (August 10, 

2009) 

ML092030404 

National Oceanic and Atmospheric Administration (NOAA) 

Fisheries, Southeast Regional Office (June 18, 2009) 

ML091660499 

Response from NOAA Fisheries, Southeast Regional Office 

(August 3, 2009) 

ML092170775 
B-4 

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3 

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12 

13 

14 [This page intentionally left blank] 
B-5 
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B-16 

1 From: Andrew.Herndon [mailto:Andrew.Herndon@noaa.gov] 

2 Sent: Monday, August 03, 2009 8:33 AM 

3 To: GLE_EIS Resource 

4 Subject: NOAA Fisheries Protected Species Information 

5 

6 To Whom it May Concern, 

7 

8 Per your request, attached and included here is information on the protected 

9 species under NOAA Fisheries' purview that may by affected by the proposed 

10 project. 

11 

12 Attachment 1: List of all Endangered Species Act (ESA)-listed species known 

13 to occur off North Carolina. 

14 Attachment 2-4: Information on Shortnose Sturgeon. Additional information on 

15 shortnose sturgeon can be found in its recovery plan at: 

16 http://www.nmfs.noaa.gov/pr/pdfs/recovery/sturgeon_shortnose.pdf

17 Attachment 5: A guide to how best analyze potential impacts to ESA-listed 

18 species. 

19 

20 Below are links to information on the species of sea turtles that may be 

21 affected by the project. The first link to the NOAA Fisheries-Protected 

22 Resources webpage for each species, the second link is to the most recent 

23 version of the recovery plan for each species. Please note links to other 

24 useful documents may be available on each species' webpage. 

25 

26 Loggerhead: 

27 http://www.nmfs.noaa.gov/pr/species/turtles/loggerhead.htm; 

28 http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_loggerhead_atlantic.pdf

29 Leatherback: 

30 http://www.nmfs.noaa.gov/pr/species/turtles/leatherback.htm; 

31 http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_leatherback_atlantic.pdf

32 Hawksbill: http://www.nmfs.noaa.gov/pr/species/turtles/hawksbill.htm; 

33 http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_hawksbill_atlantic.pdf

34 Green: http://www.nmfs.noaa.gov/pr/species/turtles/green.htm; 

35 http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_green_atlantic.pdf

36 Kemp's ridley: 

37 http://www.nmfs.noaa.gov/pr/species/turtles/kempsridley.htm; 

38 http://www.nmfs.noaa.gov/pr/species/turtles/kempsridley.htm

39 

40 Please remember that providing your determination of why an ESA-listed 

41 species may or may not be affected by the proposed action with your request 

42 for consultation will increase the speed with which it can be processed. 

43 

44 Feel free to contact this office at any time if you have additional 

45 questions. 

46 

47 Andy 
B-17 
B-18 
B-19 

[Attachment 1 of e-mail from Andrew Herndon] 
B-20 

1 [Attachment 2 of e-mail from Andrew Herndon] 

2 

3 Moser, M.L., and S.W. Ross. “Habitat Use and Movements of Shortnose and Atlantic 

4 Sturgeons in the Lower Cape Fear River, North Carolina.” T AM Fish Soc 124:225−234, 1995. 

5 ADAMS Accession No. ML092170775 
B-21 

[Attachment 3 of e-mail from Andrew Herndon] 
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[Attachment 4 of e-mail from Andrew Herndon]
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[Attachment 5 of e-mail from Andrew Herndon]
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1 B.2 Section 106 Consultation Letters 

2 

3 On September 2, 2009, the U.S. Nuclear Regulatory Commission (NRC) sent letters to 

4 16 American Indian tribes and organizations. The list of tribes and organizations 

5 (see Section 9.2) was provided by the North Carolina State Historic Preservation Office (SHPO). 

6 This section contains a sample of the outgoing NRC letter; the remaining NRC letters can be 

7 accessed via NRC’s online document retrieval system (ADAMS) using the accession numbers 

8 in Table B-2. The two responses received by the NRC are also shown in the table, and copies 

9 of the response letters are included in this section. 

10 

11 Also included in this section are copies of Section 106 correspondence involving the North 

12 Carolina SHPO and the Advisory Council on Historic Preservation. Dates and accession 

13 numbers are shown in Table B-3.

Table B-2 NRC Correspondence with American Indian Tribes and Organizations 

Tribe ADAMS Accession Number(s) 

Catawba Indian Nation ML092120329 

Cherokee Nation of Oklahoma ML092120524 

Coharie Indian Tribe ML092150041 

Cumberland County Association for Indian People ML092150248 

Eastern Band of Cherokee Indians ML092150452 

Guilford Native American Association ML092160204 

Haliwa-Saponi Indian Tribe ML092160271, ML092160427 

Lumbee Indian Tribe ML092160427 

Meherrin Indian Tribe ML092160461 

Metrolina Native American Association ML092160756 

Occaneechi Band of the Saponi Nation ML092230748 

Sappony Nation ML092160873 

Triangle Native American Society ML092160934 

Tuscarora Nation ML092170004 

United Keetoowah Band of Cherokee Indians ML092170014 

Waccamaw Siouan Indian Tribe ML092170017 

Response from Coharie Indian Tribe ML092600484 

Response from United Keetoowah Band of Cherokee Indians ML093570295 
B-97 

Table B-3 Section 106 Correspondence with the North Carolina SHPO and the 

Advisory Council on Historic Preservation 

Correspondence ADAMS Accession Number 

NRC to SHPO (April 29, 2009) ML091100104 

SHPO to NRC (June 2, 2009) ML091630258 

NRC to Advisory Council on Historic Preservation 

(September 1, 2009) 

ML092380591 
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2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

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1 B.3 Other Consultation Letters 

2 

3 The U.S. Nuclear Regulatory Commission (NRC) sent consultation letters to several Federal, 

4 State, and local government agencies. This section contains copies of several of these letters. 

5 The North Carolina Department of Labor responded in a teleconference on July 14, 2009. The 

6 North Carolina Department of Environmental and Natural Resources (Radiation Protection 

7 Section) sent requested data on September 1, 2009; this data is not provided in this appendix 

8 but can be accessed via NRC’s online document retrieval system (ADAMS). All of the NRC 

9 letters and agency responses can be accessed via ADAMS using the accession numbers in 

10 Table B-4. 

Table B-4 Additional Consultations with Government Agencies 

Agency (Date) ADAMS Accession Number(s) 

United States Army Corps of Engineers (August 13, 2009) ML092160036 

Response from United States Army Corps of Engineers 

(November 23, 2009) 

ML093570306 

North Carolina Department of Administration, State 

Environmental Review Clearinghouse (May 14, 2009) 

ML091330018 

Response 1 from North Carolina Department of Administration, 

State Environmental Review Clearinghouse (June 22, 2009) 

ML091730327 

Response 2 from North Carolina Department of Administration, 

State Environmental Review Clearinghouse (June 24, 2009) 

ML091760350 

Response 3 from North Carolina Department of Administration, 

State Environmental Review Clearinghouse (July 15, 2009) 

ML091960418 

North Carolina Department of Labor (June 15, 2009) ML091620188 

North Carolina Department of Environment and Natural 

Resources, Radiation Protection Section (July 28, 2009) 

ML091960499 

Responses from North Carolina Department of Environment 

and Natural Resources, Radiation Protection Section 

(September 1, 2009) 

ML100630876 

ML100630877 

ML100630880 

ML100630887 

ML100630890 

ML100630893 

ML100630907 

New Hanover County Planning Department (June 22, 2009) ML091630272 

Response from New Hanover County Planning Department 

(received August 20, 2009) 

ML092360197 
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C-1 

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2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 APPENDIX C 

15 RADIOLOGICAL AND CHEMICAL IMPACT ASSESSMENT METHODOLOGY AND IMPACTS 

16 
C-2 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

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14 [This page intentionally left blank] 
C-3 

1 APPENDIX C 

2 RADIOLOGICAL AND CHEMICAL IMPACT ASSESSMENT METHODOLOGY AND IMPACTS 

3 

4 C.1 Introduction 

5 

6 This appendix discusses the methodology, data, and results for the potential impacts to workers 

7 as well as members of the general public resulting from preconstruction and construction 

8 activities, and normal operations of the proposed General Electric (GE)-Hitachi Global Laser 

9 Enrichment LLC (GLE) Facility. 

10 

11 Radiological impacts during preconstruction and construction activities would be accrued 

12 primarily to the workers. Exposures to the offsite public would not be expected due to the 

13 distance from construction emission sources. However, the public would be exposed to 

14 emissions from the proposed GLE Facility during the overlap period of construction and early 

15 operations. 

16 

17 Preconstruction and construction activities would not generate any radiological contamination, 

18 but they could disturb areas previously contaminated due to deposition of contaminated 

19 particulates on soil from air effluent releases of past operation of the Fuel Manufacturing 

20 Operation (FMO) Facility as well as to the current air emissions from FMO facility operations. 

21 Preconstruction and construction workers could also be exposed to external gamma radiation 

22 from stored depleted uranium (DU) cylinders, low-enriched uranium (LEU) product cylinders, 

23 natural feed cylinders and empty cylinders relating to the existing FMO operations. 

24 Construction workers would also be exposed to air effluent releases from the proposed 

25 GLE Facility and external radiation from cylinder storage (DU, LEU, etc.) during the period when 

26 construction and early operation overlap. 

27 

28 Radiation impacts to members of the general public would result from the atmospheric release 

29 of uranium from normal operations as well as external gamma radiation associated with stored 

30 cylinders. Potential long-term, low-level, hydrogen fluoride (HF) and uranium exposures to 

31 members of the public would be the primary offsite chemical exposures of concern. 

32 

33 Potential radiation impacts to GLE radiation workers include internal exposures associated with 

34 uranium enrichment operations, external exposures to DU and LEU product cylinders, as well 

35 as external exposures associated with process operations. Radiation dosimetry associated with 

36 similar operational facilities will be used to assess operational worker doses at the proposed 

37 GLE Facility. 

38 

39 C.2 Pathway Assessment Methodology 

40 

41 For calculating the doses to workers from existing soil contamination, the RESRAD code 

42 Version 6.5 (Yu et al., 2001) was used in conjunction with contamination data from site 

43 environmental reports (GNF-A, 2007) and the environmental assessment for the license 

44 renewal for the Global Nuclear Fuels-Americas (GNF-A) FMO Facility (NRC, 2009). The 

45 CAP88-PC computer code was used to estimate the dose from existing FMO operations and air 

46 effluent releases from the proposed GLE Facility. The CAP88-PC code also calculates airborne 

47 concentrations in picocuries per cubic meter for each radionuclide at user-defined locations. 

48 These concentrations can be converted to micrograms per cubic meters for the purpose of 
C-4 

1 evaluating the chemical toxicity of uranium. Similarly, the chemical toxicity from HF emissions 

2 can be evaluated. For estimating the external dose from the cylinder storage yard, the 

3 RESRAD-BUILD code Version 3.5 (Yu et al., 2003) was used. The GENII Version 2 computer 

4 code was used to estimate the doses for the public from liquid effluent releases (Napier, 2007). 

5 

6 C.2.1 Construction Workers 

7 

8 The primary exposure pathways for construction workers from existing soil contamination are: 

9 

10 • inhalation of contaminated dust resuspended by construction activities in contaminated soils 

11 

12 • external exposure from previously contaminated soils 

13 

14 The primary exposure pathways for construction workers from existing FMO operations are: 

15 

16 • external radiation from stored DU tails, LEU product, and natural feed and empty cylinders 

17 from FMO operations 

18 

19 • external gamma radiation due to plume submersion 

20 

21 • external gamma radiation due to deposition 

22 

23 • inhalation of uranium compounds due to plume passage 

24 

25 • inhalation of uranium compounds due to resuspension 

26 

27 The additional exposure pathways for construction workers associated with continued 

28 construction operations while the proposed GLE Facility is operational include: 

29 

30 • external radiation from stored DU tails, LEU product, and natural feed and empty cylinders 

31 from operation of the proposed GLE Facility 

32 

33 • external gamma radiation due to plume submersion 

34 

35 • external gamma radiation due to deposition 

36 

37 • inhalation of uranium compounds due to plume passage 

38 

39 • inhalation of uranium compounds due to resupension 

40 

41 C.2.2 Members of the General Public 

42 

43 Radiological impacts to members of the general public from air effluent releases were estimated 

44 for the following receptors: 

45 

46 • nearest resident 

47 

48 • hypothetical persons residing outside the Wilmington Site boundary 
C-5 

1 The following exposure pathways were included in the dose assessment: 

2 

3 • external gamma radiation due to plume submersion 

4 

5 • external gamma radiation due to deposition 

6 

7 • inhalation of uranium compounds due to plume passage 

8 

9 • inhalation of uranium compounds due to resuspension 

10 

11 • ingestion of plant foods grown onsite and/or within the region of the proposed GLE Facility 

12 

13 • ingestion of meat products raised onsite and/or within the region of the proposed GLE 

14 Facility 

15 

16 • ingestion of milk produced onsite and/or within the region of the proposed GLE Facility 

17 

18 Radiological impacts to the public were also estimated from liquid effluent releases. It was 

19 assumed that a member of the public was exposed to contaminated surface water from 

20 recreational activities and from ingestion of fish grown in the contaminated surface water. The 

21 recreational activities considered were swimming, boating, and use of shoreline. The following 

22 exposure pathways were included in the dose assessment: 

23 

24 • external exposure from swimming 

25 

26 • external exposure from boating 

27 

28 • external exposure from contaminated shoreline sediment 

29 

30 • inadvertent ingestion of contaminated surface water during swimming 

31 

32 • ingestion of fish grown in contaminated surface water 

33 

34 C.2.3 GLE Radiation Workers 

35 

36 Radiological impacts to GLE radiation workers were estimated on the basis of dosimetry records 

37 from historical operations from similar facilities. The GLE radiation workers will be monitored 

38 under a radiation dosimetry program that measures both external and internal radiation doses. 

39 

40 C.2.4 Dose Assessment Methodology for Existing Soil Contamination 

41 

42 For calculating the doses to workers from the existing soil contamination, the RESRAD code 

43 Version 6.5 (Yu et al., 2001) was used. RESRAD incorporates pathway analysis models to 

44 evaluate the dose from direct exposure, inhalation of particulates and radon, and ingestion of 

45 plant foods, meat, milk, aquatic foods, water, and soil. Preconstruction and construction 

46 workers were assumed not ingest any foods grown onsite; therefore, only doses from direct 

47 external exposure and inhalation pathways were considered. The contamination in RESRAD 
C-6 

1 changes are due to soil erosion, leaching, and in-growth and decay of radionuclides in the 

2 decay chain. 

3 

4 The external pathway dose for an outside receptor in the RESRAD code is calculated as: 

5 

= ∑

n

i n DCFext nFCDnFAnFSn D t F C t , 6 ( ) ( ) (Eq. 1) 

7 

8 where 

9 

10 Fi = fraction of time spent outside near the source 

11 Cn(t) = yearly average concentration of radionuclide n present at time t (picocuries per 

12 gram) 

13 DCFext,n = external dose conversion factor for infinite volume source for radionuclide n 

14 (millirems per year per picocuries per gram) 

15 FCDn = depth-and-cover factor that corrects for the depth of contamination and any cover on 

16 top of contamination of radionuclide n

17 FAn = area factor corrects for the area of contamination for radionuclide n

18 FSn = shape factor corrects for the irregular shape of the contaminated area for 

19 radionuclide n

20 

21 In the RESRAD code for external pathway dose estimation, the depth-and-cover factor is 

22 calculated from the thickness of contamination and the thickness of cover material. The area 

23 factor is calculated from the contaminated area, and the shape factor is calculated if the 

24 contamination is not circular. All three factors are radionuclide-dependent. 

25 

26 The inhalation pathway dose for an outside receptor in the RESRAD code is calculated as: 

27 

= ∑

n

i n inh n D(t) F *C (t) * DCF * FCD * FA* ASR* FI , 28 (Eq. 2) 

29 

30 where 

31 

32 Fi = fraction of time spent outdoors 

33 Cn(t) = yearly average concentration of radionuclide n present at time t (picocuries per 

34 gram) 

35 DCFinh,n = inhalation dose conversion factor for radionuclide n (millirems per picocurie) 

36 FCD = depth-and-cover factor that corrects for the depth of contamination and any cover on 

37 top of contamination 

38 FA = area factor corrects for the area of contamination 

39 ASR = average mass loading of airborne contaminated soil particles (grams per cubic 

40 meter 

41 FI = annual intake of air (cubic meters per year) 

42 

43 In the RESRAD code for inhalation pathway dose estimation, the depth-and-cover factor is 

44 calculated from the thickness of contamination and the thickness of cover material. The area 

45 factor is calculated from the size of the contaminated area. Both parameters are radionuclide-
C-7 

1 independent. The detailed discussion on yearly average concentration calculations and these 

2 pathways can be found in the RESRAD manual (Yu et al., 2001). 

3 

4 C.2.5 Dose Assessment Methodology for Air Effluent Releases 

5 

6 The CAP88-PC code (Version 3) was used to estimate the radiological impacts associated with 

7 the atmospheric transport of uranium isotope air emission during normal operations 

8 (Rosnick, 2007). CAP88-PC estimates the total effective dose associated with the external, 

9 inhalation, and ingestion pathways. Version 3 of the code has incorporated dose conversion 

10 and risk factors from Federal Guidance Report Number 13 (FGR-13) (EPA, 1999), which utilized 

11 dose conversion factors from the International Commission on Radiological Protection (ICRP) 

12 publication Number 72 (ICRP-72) (ICRP, 1996). 

13 

14 The CAP88-PC code incorporates a modified version of the AIRDOS-EPA program to calculate 

15 the environmental transport of radionuclides. Relevant sections of the CAP88-PC Version 3 

16 user guide are reproduced in this section as referenced. 

17 

18 At the center of the atmospheric transport model is the Gaussian plume model of Pasquill as 

19 modified by Gifford: 

20 

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

⎥

⎥

⎦

⎤

⎢

⎢

⎣

⎡

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ +

+ − ⎥

⎥

⎦

⎤

⎢

⎢

⎣

⎡

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ − − ⎥

⎥

⎦

⎤

⎢

⎢

⎣

⎡

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ = −

2 2 2

2

1

exp 2

1

exp 2

1

exp 2 y z y z z

Q y z H z H

πσ σ μ σ σ σ

21 χ (Eq. 3) 

22 

23 where 

24 

25 χ = concentration in air (chi) at x meters downwind, y meters crosswind and z meters above 

26 ground (curies per cubic meter) 

27 Q = Release rate from stack (curies per second) 

28 μ = wind speed (meters per second) 

σ y 29 = horizontal dispersion coefficient (meters) 

σ z 30 = vertical dispersion coefficient (meters) 

31 H = effective stack height (meters) 

32 y = crosswind distance (meters) 

33 z = vertical distance (meters) 

34 

35 The effective release height used in Equation 3 considers the buoyant plume rise due to 

36 compounds being released above ambient temperatures. For the proposed GLE Facility, any 

37 released uranium compounds are assumed to be at ambient temperatures and the effective 

38 stack height is assumed to be the height of the release point. 

39 

40 Annual average meteorological data sets usually include frequencies for several wind-speed 

41 categories for each wind direction and Pasquill atmospheric stability category. The CAP88-PC 

42 code uses reciprocal averaged wind speeds in the atmospheric dispersion equations that permit 

43 a single calculation for each wind speed category. Equation 3 is applied to ground-level 

44 concentrations in the air at the plume centerline by setting y and z to zero, which results in: 

45 
C-8 

⎥

⎥

⎦

⎤

⎢

⎢

⎣

⎡

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ = −

2

2

1

exp

y z z

Q H

πσ σ μ σ

1 χ (Eq. 4) 

2 

3 The average ground-level concentration in air over a sector of 22.5° can be approximated by: 

4 

⎥

⎥

⎦

⎤

⎢

⎢

⎣

⎡

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

∗ −

⎥

⎥

⎦

⎤

⎢

⎢

⎣

⎡

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

−

=

∫

∞

2

o

0

2

2

2

1

exp tan(11.25 )

0.5

exp

y z z

y

avg

Q H

x

y dy

πσ σ μ σ

σ

5 χ (Eq. 5) 

6 

7 which can be reduced further to: 

8 

⎥

⎥

⎦

⎤

⎢

⎢

⎣

⎡

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ = −

2

2

1

exp 0.15871 z z

avg

H

x

Q

π σ μ σ

9 χ (Eq. 6) 

10 

11 The CAP88-PC code considers both dry and wet deposition as well as radioactive decay. 

12 Plume depletion is accounted for by substituting a reduced release rate Q’ for the original 

13 release rate for each downwind distance x (Slade, 1968). The ratio of the reduced release rate 

14 to the original is the depletion fraction. The overall depletion fraction used in CAP88-PC is the 

15 product of the depletion fractions for precipitation, dry deposition, and radioactive decay. 

16 

17 Ground surface soil concentrations are calculated on an annual basis, with in-growth and decay 

18 of progeny radionuclides calculated using Bateman’s equations for the entire decay chain. 

19 Radionuclide concentrations in meat, milk, and vegetables are calculated using elemental 

20 transfer factors from Report 123 of the National Council on Radiation Protection and 

21 Measurements (NCRP, 1996). The concentration in soil for each isotope is multiplied by the 

22 appropriate elemental transfer factor to generate a concentration in each of the ingestion 

23 pathway media for that isotope in that sector. 

24 

25 C.2.6 Dose Assessment Methodology for External Dose from Cylinder Storage Yard 

26 

27 For estimating the external dose from the cylinder storage yard, the RESRAD-BUILD code 

28 Version 3.5 (Yu et al., 2003) was used. RESRAD-BUILD is a pathway analysis model 

29 developed to evaluate the potential radiation dose incurred by an individual who works or lives 

30 in a building contaminated with radioactive material. The code includes seven exposure 

31 pathways: 

32 

33 • external exposure directly from the source 

34 

35 • external exposure to the material deposited on the floor 

36 

37 • external exposure due to air submersion 

38 

39 • inhalation of airborne radioactive particulates 
C-9 

1 • inhalation of aerosol indoor radon progeny 

2 

3 • inadvertent ingestion of radioactive material directly from the sources 

4 

5 • inadvertent ingestion of materials deposited on the surfaces 

6 

7 For estimating the dose from the cylinder storage yard, a preconstruction and construction 

8 worker working outside is assumed to have been exposed directly to a large uniformly 

9 contaminated line source. Since the receptor is outside, only the dose from the direct external 

10 pathway was calculated. 

11 

12 The yearly average external dose at any time t from a contaminated line source is calculated as: 

13 

A

( E ) D (t)= ED F C t y E B( t d L en nj

air

nj nj a a

j

n i n ⎥

⎦

⎤ ⎢

⎣

⎡ ∑ ρ

μ 24 ( ) μ )

' 14 (Eq. 7) 

15 

16 AL is given as, 

17 

dx 4 ( x +t )

e A = e 2

a 2

- x +t

line

- t L

2

a 2 a

c c

π

μ

μ

∫ 18 (Eq. 8) 

19 

20 where 

21 

22 24 = time conversion factor (h/d) 

23 ED = exposure duration (d) 

μ a = attenuation coefficient in air (cm−1 24 ) 

25 B = buildup factor 

Fi 26 = fraction of time spent near the source 

C (t) n 27 = average line source concentration of radionuclide n at time t (pCi/m) 

ynj 28 = yield for gamma j from radionuclide n

Enj 29 = energy for gamma j from radionuclide n (MeV) 

30 d = unit dose rate per energy absorption. 

μ c = attenuation coefficient in shielding material (cm−1 31 ) 

⎥

⎦

⎤ ⎢

⎣

⎡

ρ

μ ( E ) en nj

air

 = mass energy absorption coefficient in air (cm2 32 /g) 

t 33 a = perpendicular distance to receptor 

at ′ 34 = distance from the receptor to the midpoint of the line source 

35 

36 A detailed discussion on calculating the external dose from line sources is provided in the 

37 RESRAD-BUILD user’s manual (Yu et al., 2003). 

38 

39 C.2.7 Liquid Effluent Dose Assessment Methodology 

40 

41 For calculating doses to the public from liquid effluent releases, the GENII code Version 2.06 

42 (Napier, 2007) was used. The code has been developed by Pacific Northwest National 
C-10 

1 Laboratory for the U.S. Environmental Protection Agency (EPA) for calculating dose and risk 

2 from radionuclide releases in the environment. GENII Version 2 incorporates internal dosimetry 

3 models recommended by the International Commission on Radiological Protection (ICRP), and 

4 the related risk factors published in FGR-13 (EPA, 1999). The GENII code includes a set of 

5 programs for calculating radiation dose and risk from radionuclides released to the environment. 

6 GENII implements the U.S. Nuclear Regulatory Commission (NRC) models in the LADTAP 

7 computer code for surface water doses. The Northeast Cape Fear River would receive the 

8 liquid effluent discharges from the proposed GLE Facility. There are no public water intakes on 

9 the river downstream of the discharge point, so only the fish ingestion and recreational water 

10 use-related exposure pathways were analyzed (GLE, 2009b). 

11 

12 The GENII code calculates the average media concentration at the exposure location, the 

13 pathway-specific intake parameter, and the pathway dose. The following equations for dose 

14 estimations from different applicable pathways used in this analysis are taken directly from the 

15 GENII User’s Guide (Napier, 2007). 

16 

17 C.2.7.1 Swimming Exposure 

18 

19 The evaluation of the recreational swimming immersion intake parameter is performed as 

20 follows: 

21 

wrig T Cwri T FEwrg TEwrg TCs 22 I ( ) = ( )× × × (Eq. 9) 

23 

24 where 

25 

26 Iwrig(T) = average exposure factor over time period T for radionuclide i from swimming at 

27 recreational swimming location r for individuals in age group g (Bq/L) 

28 Cwri(T) = average water concentration over time period T for radionuclide i in surface water at 

29 the recreational swimming location r (Bq/L) 

30 FEwrg = frequency of swimming events at recreational swimming location r for individuals in 

31 age group g (events/day) 

32 TEwrg = duration of an average swimming event at recreational swimming location r for 

33 individuals in age group g (hours/event) 

34 Twrg = annual exposure factor for swimming at recreational swimming location r for 

35 individuals in age group g (days) 

36 TCs = time correction set equal to Twrg/8760 hours/year 

37 

38 For this pathway, the daily exposure factor may be represented as the product of the event 

39 frequency, FEwrg, and the event duration, TEwrg. 

40 

41 The effective dose from external exposure to swimming in contaminated water is calculated in 

42 the GENII code as follows (Napier, 2007): 

43 

7 44 IEwrig (T) = Iwrig (T)× Eiaw ×TEw × 3.15×10 (Eq. 10) 

45 
C-11 

1 where 

2 

3 IEwrig(T) = effective dose from external exposure to radionuclide i in contaminated water at 

4 recreational water usage location r for an individual in age group g (Sv) 

5 Iwrig(T) = external exposure average water concentration for radionuclide i for recreational 

6 water usage location r for individuals in age group g (Bq/L) 

7 Eiaw = effective dose equivalent factor for external exposure from water immersion (w) for 

8 radionuclide i for an adult (Sv-L per Bq-s) 

9 TEw = time of exposure (year) 

3.15 × 107 10 = units correction (seconds/year) 

11 

12 C.2.7.2 Boating Exposure 

13 

14 The evaluation of the recreational boating exposure intake parameter is performed as follows: 

15 

brig T Cbri T SB FEbrg TEbrg TCb 16 I ( ) = ( )× × × × (Eq. 11) 

17 

18 where 

19 

20 Ibrig(T) = average exposure factor over the period T for radionuclide i from boating at 

21 recreational boating location r for individuals in age group g (Bq/L) 

22 Cbri(T) = average water concentration of radionuclide i at recreational boating location r

23 (Bq/L) 

24 SB = shielding factor for boating exposures (dimensionless) 

25 FEbrg = average frequency of daily boating events at recreational boating location r for 

26 individuals in age group g (events/day) 

27 TEbrg = duration of an average boating event at recreational boating location r for 

28 individuals in age group g (hours/event) 

29 TCb = time correction set equal to Tbrg/8760 hours/year 

30 Tbrg = annual exposure factor for boating at recreational boating location r for individuals 

31 in age group g (days) 

32 

33 For this pathway the daily exposure factor may be represented as the product of the event 

34 frequency, FEbrg, and the event duration, TEbrg. 

35 

36 The effective dose from external exposure to boating in contaminated water is calculated in the 

37 GENII code as follows (Napier, 2007): 

38 

( ) ( ) 3.15 10 / 2 7 39 IEbrig T = Ibrig T × Eiaw ×TEb × × (Eq. 12) 

40 

41 where 

42 

43 IEbrig(T) = effective dose from external exposure to radionuclide i from boating in 

44 contaminated water at recreational water usage location r for an individual in age 

45 group g (Sv) 

46 Ibrig(T) = external exposure average water concentration for radionuclide i for recreational 

47 water usage location r for individuals in age group g (Bq/L) 
C-12 

1 Eiaw = effective dose equivalent factor for external exposure from water immersion (w) for 

2 radionuclide i for an adult (Sv-L per Bq-s) 

3 TEb = time of exposure (year) 

4 2 = factor to account for being at the water surface rather than immersed 

5 (dimensionless) 

3.15 × 107 6 = units correction (seconds/year) 

7 

8 C.2.7.3 External Exposure to Shoreline Sediment 

9 

10 The sediment concentration at the end of a year is calculated in the GENII code as follows 

11 (Napier, 2007): 

12 

i

T

ri yr

sri yr

i yr TC C T e

C T

λ

λ ( ) (1 ) ( )− × × − 13 = (Eq. 13) 

14 

15 where 

16 

17 Csri(Tyr) = concentration of radionuclide i in sediment after one year of accumulation, from 

deposition on the shoreline at recreational water usage location r (Bq/m2 18 ) 

TC = transfer rate constant from water to sediment (L/m2 19 /year) 

20 Cri(Tyr) = average (constant) annual water concentration for radionuclide i at recreational water 

21 usage location r (Bq/L) 

22 Tyr = one year integrating period for deposition to sediments (year) 

23 

24 The external exposure parameter is evaluated by determination of the average sediment 

25 concentration during a year, as follows: 

26 

∫ × × =

Tyr

yr sed sed

ri

sri yr T d

C t dt C T

0

( ) ( )

ρ

27 (Eq. 14) 

28 

29 where 

30 

31 Csri(Tyr) = shoreline sediment time integral of exposure for radionuclide i evaluated at the 

32 recreational usage location r (Bq/kg) 

33 dsed = thickness of shoreline sediments (meters) 

ρsed = density of shoreline sediments (kg/m3 34 ) 

35 Tyr = one year exposure period (year) 

36 

37 The evaluation of the recreational shoreline exposure intake parameter is performed as follows: 

38 

39 Isrig (T) = Csri(T)× SWr × FEsrg ×TEsrg ×Tsrg /8760 (Eq. 15) 

40 

41 where 

42 

43 Isrig(T) = average exposure factor over the period T for radionuclide i from shoreline exposure 

44 at recreational shoreline location r for individuals in age group g (Bq/kg) 
C-13 

1 Csri(T) = average shoreline sediment concentration of radionuclide i at recreational shoreline 

2 location r (Bq/kg) 

3 SWr = shoreline width factor for the recreational shoreline location r (dimensionless) 

4 FEsrg = shoreline use event frequency at recreational shoreline location r for individuals in 

5 age group g (events/day) 

6 TEsrg = duration of each shoreline exposure event at recreational shoreline location r for 

7 individuals in age group g (hours/event) 

8 Tsrg = annual exposure factor for shoreline exposure at recreational shoreline location r for 

9 individuals in age group g (days) 

10 8760 = unit correction (hours/year) 

11 

12 For this pathway, the daily exposure factor may be represented as the product of the event 

13 frequency, FEsrg, and the event duration, TEsrg. 

14 

15 The effective dose from external exposure to shoreline sediment is calculated in the GENII code 

16 as follows (Napier, 2007): 

17 

srig srig T ECiag TEs s ds IE T = I × × × × ×ρ × 7 18 ( ) ( ) 3.15 10 (Eq. 16) 

19 

20 where 

21 

22 IEsrig(T) = effective dose from external exposure to radionuclide i in shoreline sediment at 

23 recreational water usage location r for an individual in age group g (Sv) 

24 Isrig(T) = external exposure average shoreline sediment concentration for radionuclide i for 

25 recreational water usage location r for individuals in age group g (Bq/kg) 

26 ECiag = effective dose equivalent factor for external exposure from contaminated soil (g) 

for radionuclide i for an adult (Sv-m2 27 per Bq-s) 

28 TEs = time of exposure, Tyr (years) 

ρs = surface soil bulk density (kg/m3 29 ) 

30 ds = thickness of surface soil layer (meter) 

3.15 × 107 31 = units correction (seconds/year) 

32 

33 C.2.7.4 Water Ingestion Pathway 

34 

35 The water concentration at the point of consumption is evaluated as follows: 

36 

3 2.74 10 ( ) ( ) − − × × × = × × i Thw dwi yr wi yr i C T C T TF e

λ 37 (Eq. 17) 

38 

39 where 

40 

41 Cdwi(Tyr) = concentration of radionuclide i in water at water usage location w at the time of 

42 consumption (Bq/L) 

43 TFi = water treatment purification factor giving the fraction of radionuclide i remaining in 

44 the water after treatment (dimensionless) 

λi = radiological decay constant for radionuclide i (year–1 45 ) 

46 Thw = holdup time between the water intake plant and the water point of water use 

47 (days) 
C-14 

2.74 × 10−3 1 = units conversion factor (years/day) 

2 

3 Evaluation of the drinking water intake parameter is performed as follows: 

4 

dwig Cdwi T Udw Tdwg TCw EDdwg 5 I = ( )× × × × (Eq. 18) 

6 

7 where 

8 

9 Idwig(T) = total intake of radionuclide i from drinking water ingestion over the period T at water 

10 usage location w for individuals in age group g (Bq) 

11 Cdwi(T) = average concentration of radionuclide i in drinking water at water usage location 

12 w (Bq/L) 

13 Udw = drinking water ingestion rate (L/d) 

14 Tdwg = annual intake factor giving days per year that water is consumed (days/year) 

15 TCw = time correction equal to EDdwg

16 EDdwg = exposure duration for the drinking water pathway at usage location w for individuals in 

17 age group g (years) 

18 

19 The effective dose from ingestion of drinking water is calculated in the GENII code as follows 

20 (Napier, 2007): 

21 

dwig dwig T ECigoc 22 IE (T) = I ( )× (Eq. 19) 

23 

24 where 

25 

26 IEdwig(T) = effective dose from ingestion intake of radionuclide i in drinking water at water 

27 usage location w for an individual in age group g for exposure over time period T

28 (Sv) 

29 Idwig(T) = ingestion intake of radionuclide i in drinking water at water usage location w for 

30 individuals in age group g for exposure over time period T (Bq) 

31 ECigoc = effective dose coefficient for ingestion intake of radionuclide i of class c for an 

32 individual in age group g (Sv/Bq) 

33 

34 C.2.7.5 Fish Ingestion Pathway 

35 

36 Aquatic food products may become contaminated when grown in contaminated surface waters. 

37 The concentration in an aquatic food is based on the average surface water concentration for 

38 the current year, as follows: 

39 

Chqi Tyr = Cwi Tyr × Bqi 40 ( ) ( ) (Eq. 20) 

41 

42 where 

43 

44 Chqi(Tyr) = concentration of radionuclide i in aquatic food type q at time of harvest (Bq/kg) 

45 Bqi = bioaccumulation factor for radionuclide i in the edible portions of aquatic food type q

46 (Bq/kg wet fish per Bq/L water) 

47 
C-15 

1 The concentration at the start of the consumption period is evaluated accounting for decay 

2 during holdup as follows: 

3 

3 2.74 10 ( ) ( ) − − × × × = × i Thq

fwi yr hqi yr C T C T e

λ 4 (Eq. 21) 

5 

6 where 

7 

8 Cfwi(Tyr) = concentration of radionuclide i in aquatic food type q at water location w the time 

9 of consumption (Bq/kg wet weight) 

10 Thq = holdup delay time between harvest and consumption for aquatic food type q

11 (days) 

λi = radiological decay constant for radionuclide i (year–1 12 ) 

2.74 × 10−3 13 = units conversion factor (years/day) 

14 

15 The evaluation of the aquatic food intake parameter is performed as follows: 

16 

fwig C fwi T U fwg T fwg ED fwg 17 I = ( ) × × × (Eq. 22) 

18 

19 where 

20 

21 Ifwig(T) = total intake of radionuclide i from ingestion of aquatic food f over the period T at 

22 aquatic food location w for individuals in age group g (Bq) 

23 Cfwi(T) = average concentration in aquatic food f at aquatic food location w for radionuclide 

24 i (Bq/kg) 

25 Ufwg = ingestion rate of aquatic food f at aquatic food location w by an individual in age 

26 group g (kg/day) 

27 Tfwg = annual intake factor giving the days per year that aquatic food f is eaten at aquatic 

28 food location w by individuals in age group g (days/year) 

29 EDfwg = exposure duration for consumption of aquatic food f at aquatic food location w for 

30 individuals in age group g (years) 

31 

32 The effective dose from ingestion of aquatic foods is calculated in the GENII code as follows 

33 (Napier, 2007). 

34 

fwig wfig T ECigoc 35 IE (T) = I ( )× (Eq. 23) 

36 

37 where 

38 

39 IEfwig(T) = effective dose from ingestion intake of radionuclide i in aquatic food f at water usage 

40 location w for an individual in age group g for exposure over time period T (Sv) 

41 Ifwig(T) = ingestion intake of radionuclide i in aquatic food f at water usage location w for 

42 individuals in age group g for exposure over time period T (Bq) 

43 ECigoc = effective dose coefficient for ingestion intake of radionuclide i of class c for an 

44 individual in age group g (Sv/Bq) 

45 

46 In this analysis, effective dose for the adult member of the public is calculated. 
C-16 

1 C.3 Impact Assessment Input 

2 

3 The data and results of the radiological impacts are provided below for the following groups: 

4 

5 • preconstruction and construction workers 

6 

7 • nearest resident 

8 

9 • persons residing adjacent to the site boundary 

10 

11 • persons that use the Northeast Cape Fear River near the Wilmington Site for fishing or other 

12 recreational activities. 

13 

14 Inputs required are for the RESRAD code to evaluate the dose from existing soil contamination, 

15 for the CAP88-PC code to model the air effluent releases from operations of the existing FMO 

16 Facility and the proposed GLE Facility, for the RESRAD-BUILD code to model the dose from 

17 the uranium hexafluoride (UF6) cylinder storage pads, and for the GENII code to model doses 

18 from the liquid effluent releases. 

19 

20 C.3.1 RESRAD Inputs 

21 

22 To estimate the external and inhalation pathway doses using the RESRAD code, it was 

23 assumed that a 1-hectare (2.5-acre) area of soil was contaminated to a depth of 15 centimeters 

24 (6 inches) and that preconstruction and construction workers would spend 2000 hours in 

25 one year onsite. The inhalation rate of the construction worker was assumed to be 1.4 cubic 

26 meters per hour (1.8 cubic yards per hour), which is characteristic for a worker (EPA, 1997). 

27 The mass loading for respirable particulates due to construction activity was assumed to be 

1 × 10–4 grams per cubic meter (1.7 × 10–7 28 pounds per cubic yard), and the most restrictive lung 

29 clearance class was used for inhalation dose conversion factors. Table C-1 lists the 

30 radionuclide-specific parameters used in the radiological impact assessment. The rest of the 

31 parameters were RESRAD default values. 

32 

33 C.3.2 CAP-88 Code Inputs 

34 

35 This section provides the parameters used in dose estimations for preconstruction and 

36 construction workers and for the hypothetical receptor at the site boundary and the nearest 

37 resident. Parameters provided include Wilmington Site characteristics, emission characteristics 

38 of the existing FMO facility and proposed GLE Facility, receptor time fractions and locations, 

39 agricultural input parameters, and radionuclide-specific inputs. For chemical toxicity 

40 calculations from HF emissions, it was assumed that the concentration at the GLE stack is 

7.8 micrograms per cubic meter (1.3 × 10–8 41 pounds per cubic yard) (see Section 4.2.11.2). The 

42 dimension of the stack diameter and exit velocity were used to calculate the HF release rate. 

43 

44 C.3.2.1 FMO and GLE Stack Characteristics and Releases 

45 

46 Table C-2 includes the stack and vent characteristics, site-specific parameters, and annual 

47 release rates assumed in dose modeling (GLE, 2008). For FMO operations, actual air effluent 

48 releases for 2007 were used (GLE, 2009a). There are multiple release points for FMO 
C-17 

Table C-1 Radionuclide-Specific Parameters Used in the RESRAD Code 

for Radiological Impact Assessment 

 Radionuclide 

Parameter Name Uranium-234 Uranium-235 Uranium-236 Uranium-238 

Lung clearance class S S S S 

Inhalation dose conversion factor 

(mrem/pCi)a,b 

3.48 × 10–2 3.15 × 10–2 3.22 × 10–2 2.96 × 10–2 

External dose conversion factor 

(mrem/yr per pCi/g)a,b 

3.44 × 10–4 6.60 × 10–1 1.78 × 10–4 7.96 × 10–5 

Soil concentration (pCi/g)b,c 3.21 1.25 × 10–1 1.40 × 10–3 4.57 × 10–1 

a The latest dose factors from Federal Guidance Report 13 (EPA, 1999) and ICRP 72 (ICRP, 1996) were 

used. 

b

 To convert millimeters to millisieverts, divide by 100. To convert picocuries to becquerels, multiply by 0.037. c Soil concentration is calculated from the site environmental reports (GNF-A, 2007) and environmental 

assessment for the license renewal for the GNF-A (NRC, 2009). 

Table C-2 FMO and GLE Emissions and Site Characteristics Used in Modeling 

Input Parameter FMO GLE 

Stack diameter (meters)a NR 1.2 

Stack release height (meters)b NR 15.24 

Velocity (meters per second) NR 12.3 

Source area (square meters)a 2500 

Temperature Ambient Ambient 

234U emission rate 1.86 × 10–5 (curies per year)a

 1.25 × 10–13 (curies per second)c

Uranium-235 emission rate 7.27 × 10–7 (curies per year) 4.88 × 10–15 (curies per second)c 

Uranium-236 emission rate 8.20 × 10–9 (curies per year) 5.49 × 10–17 (curies per second)c 

Uranium-238 emission rate 2.65 × 10–6 (curies per year) 1.77 × 10–14 (curies per second)c 

Ambient temperature (°C) 17.7 17.7 

Annual precipitation 

(centimeters)d

144.96 144.96 

a

 To convert meters to feet, multiply by 3.28. To convert square meters to square feet, multiply by 10.76. 

To convert curies to becquerels, multiply by 3.7 × 1010. b

 Stack could be higher (21–27 meters) (GLE, 2009a), but the lower value (GLE, 2008) was used because it 

is conservative. 

c Emission rates are converted to curies per year by multiplying 3.156 × 107

 seconds per year conversion 

factor for input in the CAP88-PC code. 

d 100 centimeters = 1 meter. 

Sources: GLE, 2008, 2009a. 
C-18 

1 operations, the heights of the release points are all different, and the CAP88-PC code does not 

2 account for building wake effects. Therefore, releases were assumed to occur at ground level, 

3 resulting in larger air concentrations of radionuclides for receptors near the source than for 

4 elevated releases. The GLE stack could be higher (21–27 meters [69–89 feet]) (GLE, 2009a), 

5 but the lower value (GLE, 2008) was used because it is conservative. For conservatism, the 

6 same quantity of uranium release from the GLE stack was assumed to be released during the 

7 combined construction and operational phase in order to estimate the maximum dose potential 

8 construction workers would incur. 

9 

10 C.3.2.2 Exposure Time Fractions and Receptor Locations 

11 

12 The CAP88-PC code assumes that the individual spends an entire year at the locations 

13 provided. The assumption that the individual spends 8760 hours at the job site is overly 

14 conservative when it comes to evaluating the construction worker dose, since on average, a 

15 worker is assumed to spend approximately 2000 hours per year at a job site. In order to 

16 account for this limitation, construction worker doses were scaled down by a factor of 4.38 

17 (24 × 365.25/2000). The preconstruction and construction workers would be located, on 

18 average, a distance no less than 250 meters (820 feet) from the stack release points. The 

19 construction workers would be closest to the FMO stack releases during the construction of the 

20 access road (average distance greater than 250 meters [820 feet]) (Figure 2-2), for a period of 

21 about one month. For GLE stack releases, construction workers would be beyond the 

22 controlled area fence (average distance greater than 250 meters [820 feet] from the GLE stack 

23 release) (Figure 6-1). For the purposes of analyses, these workers were conservatively 

24 assumed to be at 250 meters (820 feet) from the release point. 

25 

26 The hypothetical site boundary receptor was chosen so that a person would receive the 

27 maximum dose and this individual could be considered a maximally exposed individual. The 

28 dose was modeled in 16 compass directions at the site boundary. The dose was also 

29 calculated for the nearest resident from the proposed GLE Facility stack. A hypothetical 

30 receptor and a resident are assumed to be at that location for an entire year. Table C-3 

31 provides a listing of the locations used to estimate the radiological impacts to the nearest 

32 resident and the hypothetical receptor at the site boundary from operation of the proposed 

33 GLE Facility. 

34 

35 C.3.2.3 Agricultural Productivity 

36 

37 The ingestion of vegetables, meat and milk was considered in the radiological impact 

38 assessment for the hypothetical receptor and for the nearest resident. The EPA rural food 

39 source scenario option within CAP88-PC was selected in the assessment for the hypothetical 

40 receptor and the nearest resident. For preconstruction and construction workers the EPA 

41 regional food source option within CAP88-PC was used. Preconstruction and construction 

42 workers are not expected to consume any food grown onsite. On the basis of regional food 

43 production, estimates were derived for the beef cattle density, milk cattle density, and land 

44 fraction cultivated by vegetables. Table C-4 provides a listing of the agricultural parameters 

45 used in CAP88-PC for the radiological impact assessment. 

46 
C-19 

Table C-3 Receptor Location for Radiation 

Dose and Chemical Toxicity Estimation 

from GLE Stack Releases 

Location Direction Distance 

(meters) 

Site boundary North 3.99 × 102

Site boundary North-northwest 5.73 × 102

Site boundary Northwest 9.24 × 102

Site boundary West-northwest 1.49 × 103

Site boundary West 1.72 × 103

Site boundary West-southwest 2.30 × 103

Site boundary Southwest 1.81 × 103

Site boundary South-southwest 1.89 × 103

Site boundary South 1.42 × 103

Site boundary South-southeast 1.71 × 103

Site boundary Southeast 2.66 × 103

Site boundary East-southeast 1.27 × 103

Site boundary East 6.71 × 102

Site boundary East-northeast 4.27 × 102

Site boundary Northeast 3.53 × 102

Site boundary North-northeast 3.46 × 102

Nearest resident East-southeast 1.35 × 103

1 

2 C.3.2.4 Radionuclide-Specific Input 

3 

4 The radiological impacts were estimated using the CAP88-PC Version 3.0 computer code. This 

5 code uses the newer FGR-13/ICRP-72-based dose conversion factors. The most restrictive 

6 “slow” lung clearance classes were assigned to each uranium isotope. 

7 

8 Radionuclide transfer factors were used to model the update of radionuclides by plants and 

9 animals. The transfer factors are element-dependent rather than radionuclide-dependent. The 

10 

11 default vales for uranium found in CAP88-PC were used for the radiological impact assessment. 

12 A listing of the elemental and radionuclide-specific factors used for all radiological impact 

13 modeling is provided in Table C-5. 

14 

15 C.3.3 RESRAD-BUILD Code Inputs 

16 

17 For estimating the external dose from the cylinder storage yard, RESRAD-BUILD code 

18 Version 3.5 (Yu et al., 2003) was used. Preconstruction and construction workers initially would 

19 only be exposed to the dose from the stored cylinders from the existing FMO facility and during 
C-20 

Table C-4 Agricultural Input Parameters Used in the Radiological 

Impact Assessment 

Parameter Vegetable Meat Milk Scenario 

Fraction from assessed area 1.0 1.0 1.0 Preconstruction and 

construction worker 

Fraction home produced 0.0 0.0 0.0 Preconstruction and 

construction worker 

Fraction from assessed area 0.7 0.44 0.4 Hypothetical receptor 

and nearest resident 

Fraction home produced 0.3 0.56 0.6 Hypothetical receptor 

and nearest resident 

Cattle density (number/km2) NAa 0.102 0.0126 All scenarios 

Land fraction cultivated for 

vegetables 

0.00632 NA NA All scenarios 

a

 NA = not applicable. 

Source: Rosnick, 2007. 

1 

2 

3 the overlap period would be additionally exposed to the dose from the cylinders stored at the 

4 proposed GLE Facility. Natural uranium cylinders, natural uranium heel cylinders, tails 

5 cylinders, tails heel cylinders, and product cylinders are typically stored at a uranium enrichment 

6 site. The external dose depends on the number and type of cylinders stored, shielding, and the 

7 distance to the receptor. The dose does not depend on the facility that generated the cylinders. 

8 Typically, more tails cylinders are present compared to other types of cylinders. 

9 

10 

11 Following are the inputs used in the code: 

12 

13 • source location, x = 0, y = 0, z = 0 

14 

15 • source direction, x

16 

17 • source length, 300 meters (984 feet) (estimated from the tails pad length) 

18 

19 • receptor location, x = 0, z = 1, y = 100 meters (328 feet) (this parameter was varied 

20 depending on the distance of the receptor from the source) 

21 

• source shielding thickness = 1.59 centimeters, shielding density = 7.8 g/cm3 22 , material = iron, 

23 and time onsite = 2000 hours 

24 

25 • The shielding thickness was estimated from actual Type 48Y cylinders. The line source 

26 concentration was estimated from actual uranium concentration in the cylinders. 

27 
C-21 

Table C-5 Radionuclide-Specific Inputs Used in the Radiological Impact Assessment 

 Radionuclide 

Parameter Name Uranium-234 Uranium-235 Uranium-236 Uranium-238 

Element

Uranium 

Lung clearance class S S S S NAa

Inhalation dose conversion 

factor (millirems per picocurie)b

3.48 × 10–2 3.14 × 10–2 3.23 × 10–2 2.97 × 10–2 NA 

Ingestion dose conversion factor 

(millirems per picocurie) 

1.83 × 10–4 1.73 × 10–4 1.73 × 10–4 1.65 × 10–4 NA 

Immersion dose conversion 

factor (mrem cm3

/μCi-yr)b,c

7.14 × 105 7.55 × 108 4.51 × 105

 2.92 × 105 NA 

Ground surface dose conversion 

factor (mrem cm2

/μCi-yr) 

6.83 × 102 1.63 × 105 5.86 × 102

 4.94 × 102 NA 

Deposition velocity 

(meters per second)b

1.8 × 10–3 1.8 × 10–3 1.8 × 10–3 1.8 × 10–3 NA 

Particle size (micrometers)d 1 1 1 1 

Milk transfer factor NA NA NA NA 4 × 10–4 

Meat transfer factor NA NA NA NA 8 × 10–4 

Forage uptake factor (pCi/kg dry 

forage/pCi/kg dry soil)b

NA NA NA NA 0.1 

Edible update factor (pCi/kg wet 

weight per pCi/kg dry soil) 

NA NA NA NA 0.002 

a

 NA = not applicable. 

b

 To convert millirems to millisieverts, divide by 100. To convert picocuries to becquerels, multiply by 0.037. To convert 

microcuries to becquerels, multiply by 3.7 × 104

. To convert meters to feet, multiply by 3.28. To convert kilograms to pounds, 

multiply by 2.2. 

c

 100 centimeters = 1 meter. 

d

 106 micrometers = 1 meter. 

Source: Rosnick, 2007.

1 

2 

3 C.3.4 GENII Code Inputs 

4 

5 The radionuclide concentration in the surface water was calculated at three potential exposure 

6 locations from the uranium concentrations in the liquid effluent releases from the proposed GLE 

7 Facility and the dilution factor in the receiving water body (GLE, 2009b). Table C-6 shows the 

8 estimated radionuclide concentrations in the surface water at three exposure locations. 

9 Table C-7 lists the estimated number of people involved in recreational activities, which was 

10 estimated based on regional recreational activity data (GLE, 2009b). It is expected that the 

11 same number of people would be involved at all three exposure locations. Table C-8 lists the 

12 radionuclide-specific parameters used in the GENII code for radiological impact assessment. 

13 

14 Dose conversion factors (DCFs) based on ICRP 60 methodology (ICRP, 1991) were used to 

15 estimate effective dose. Table C-9 lists other exposure parameters used in estimating the 

16 doses from different exposure pathways. Since the surface water concentrations were known, 
C-22 

Table C-6 Estimated Radionuclide Concentrations in Surface Water at Exposure Locati

Radionuclide concentration (pCi/L)a Exposure Location 

Uranium-238 Uranium-235 Uranium-234 Thorium-234 Protactinium-234 Protactinium-23

Confluence with Unnamed Tributary #1 to Northeast Cape Fear River 1.08 × 10−3 9.38 × 10−5 1.01 × 10−6 1.08 × 10−3 3.55 × 10−6 1.07 × 10−3 Just South of GE Wilmington Site Boundary 1.08 × 10−3 9.38 × 10−5 1.01 × 10−6 1.08 × 10−3 3.55 × 10−6 1.07 × 10−3 NC 133 Bridge 1.04 × 10−3 9.06 × 10−5 9.76 × 10−7 1.04 × 10−3 3.43 × 10−6 1.04 × 10−3 a To convert picocuries (pCi) to becquerels (Bq), multiply by 0.037. 

Note: Isotopic weight fractions used were: Uranium-234: 8.64 × 10−4, Uranium-235: 8.02 × 10−2, and Uranium-238: 9.19 × 10−1. Short-lived progeny 

(thorium-234, protactinium-234, and protactinium-234m) and uranium-235 (thorium-231) are assumed to be in equilibrium with the parent radionuclidSource: GLE, 2009b. 
C-23 

Table C-7 Estimated Number of People Involved 

in Different Recreational Activitiesa 

Recreational Activity Number of People Involved 

Fish ingestion 1414 

Swimming 1906 

Boating 1244 

Shoreline 1231 

a Recreational survey data representative of the southeast 

United States were used to estimate the number of people 

involved in different recreational activities at each exposure 

location (GLE, 2009c). People involved in swimming that would 

spend a significant amount of time in shoreline activities are 

assumed to be counted in shoreline activities. Recreational 

activities such as sunbathing and fishing result in external 

exposure from sediment contamination while onshore. The 

pathways considered during swimming were external exposure 

from water immersion and water ingestion. The pathway 

considered during boating was water exposure at the surface. 

Source: GLE, 2009c.

1 

2 the surface water dissolved module in GENII code (WCF) was used in estimating the public 

3 dose. 

4 

5 C.4 Results of the Radiological and Chemical Impact Analyses 

6 

7 This section provides the results of the radiological impact analyses. Radiological impacts were 

8 estimated for the following: 

9 

10 • GLE Facility preconstruction and construction workers 

11 

12 • nearest resident 

13 

14 • hypothetical receptor at the site boundary 

15 

16 • member of the public and population that uses northeast Cape Fear River for recreational 

17 activities 

18 

19 • GLE Facility operational workers 

20 

21 Table C-10 provides the estimated annual effective dose from the air emissions due to the 

22 proposed GLE Facility at different receptor locations. The estimated annual effective dose for a 

23 preconstruction and construction worker from the air emissions associated with the existing 

FMO operation was 2.8 × 10–5 millisievert per year (2.8 × 10–3 24 millirem per year). For calculating 

25 this dose, it was assumed that the worker was onsite for 2000 hours in one year. 

26 
C-24 

Table C-8 Radionuclide-Specific Parameters Used in the GENII Code for Radiological Impact A

Parameter Uranium-238 Uranium-235 Uranium-234 Thorium-234 Protactinium-234 Protactinium-2

Ingestion dose conversion factor, (rem/pCi) 

1.65 × 10−7 1.73 × 10−7 1.83 × 10−7 1.26 × 10−8 1.94 × 10−9 0.00 × 100 

External exposure from contaminated soil dose conversion factor, (Sv/s per Bq/m2) 

4.24 × 10−19 1.40 × 10−16 5.86 × 10−19 7.50 × 10−18 1.80 × 10−15 1.08 × 10−16 

External exposure from water immersion dose conversion factor, (Sv/s per Bq/m3) 

7.79 × 10−14 1.90 × 10−10 1.85 × 10−13 8.75 × 10−12 2.52 × 10−9 2.64 × 10−11 

Fish bioaccumulation factor, (Bq/kg wet fish per Bq/L water) 

1.00 × 101 1.00 × 101 1.00 × 101 1.00 × 102 1.00 × 102 1.00 × 101 

Source: Napier, 2007.
C-25 

Table C-9 Exposure Parameters for Different Activities 

Parameter Shoreline 

Use Boating Swimming Fish Ingestion 

Frequency, events/day 1 1 1 NA 

Duration of event, hours 2 2 2 NA 

Event days, days 50 50 50 NA 

Shielding factor NA 1 NA NA 

Ingestion of water while swimming, L/hour NA NA 0.021 NA 

Shoreline width factor 0.2 NA NA NA 

Shoreline sediment density, kg/m2 15 NA NA NA 

Transfer rate constant from water to 

sediment, L/m2

/yr 25,400 NA NA NA 

Soil layer thickness, cm 35 NA NA NA 

Fish ingestion rate, grams/day NA NA NA 44 

Fish consumption period, days NA NA NA 365 

Fish holdup time, days NA NA NA 1 

1 

2 Table C-11 shows modeled uranium and HF concentrations at various onsite and offsite 

3 locations after dispersion. For calculating the total uranium concentrations, individual isotope 

4 concentrations were multiplied by the specific activities and added together. 

5 

6 Table C-12 shows the estimated doses at various distances from the storage pad, assuming 

7 that the receptor was at the location for 2000 hours in one year. In actuality, construction 

8 workers would be at many different locations and distances from the cylinder storage pads. 

9 Based on the locations of the FMO facility and the proposed GLE Facility, it is highly unlikely 

10 that the same construction workers would be close to the storage pads from both facilities when 

11 onsite. Table C-12 demonstrates that the external dose decreases rapidly with distance, and it 

12 is expected that the dose would be even smaller at longer distances. The construction workers 

13 would be closest to the existing FMO facility storage pads during construction of the access 

14 road (average distance greater than 250 meters [820 feet]) (Figure 2-2) for a period of about 

15 one month. The entire perimeter of the storage pad constructed for the proposed GLE Facility 

16 would be fenced (GLE, 2008) and construction workers are assumed to be located beyond the 

17 controlled area boundary and would not spend significant time near it. For conservatism, 

18 construction workers are assumed to be located at the minimum distance of 250 meters 

19 (820 feet) from the cylinder storage pads for all 2000 hours in one year. 

20 

21 The maximum dose that a member of a public would receive from liquid effluent releases from 

22 the proposed GLE Facility would occur just south of the Wilmington Site boundary. Table C-13 

23 provides the estimated annual effective dose for an exposed member of the public from different 

24 surface water exposure pathways, along with the estimated annual effective population doses.
C-26 

Table C-10 Annual Effective Dose from Proposed GLE Facility Stack 

Releases at Different Receptor Locations 

Location Direction Distance 

(meters)b 

Dose (millirems 

per year)c 

Site boundary North 399 8.5 × 10–5

Site boundary North-northwest 573 6.2 × 10–5

Site boundary Northwest 924 2.1 × 10–5

Site boundary West-northwest 1493 4.7 × 10–6

Site boundary West 1717 1.7 × 10–5

Site boundary West-southwest 2302 1.4 × 10–5

Site boundary Southwest 1806 2.3 × 10–5

Site boundary South-southwest 1892 2.2 × 10–5

Site boundary South 1416 3.9 × 10–5

Site boundary South-southeast 1708 2.5 × 10–5

Site boundary Southeast 2664 1.8 × 10–5

Site boundary East-southeast 1270 1.5 × 10–5

Site boundary East 671 4.9 × 10–5

Site boundary East-northeast 427 8.3 × 10–5

Site boundary Northeast 353 1.1 × 10–4

Site boundary North-northeast 346 9.4 × 10–5

Onsite construction workera South 250 3.2 × 10–5

Nearest resident East-southeast 1352 1.4 ×10−5

a Onsite construction worker in the south direction got the maximum dose. For calculating the 

dose for the onsite construction worker, the worker was assumed to be onsite for 2000 hours 

in one year. 

b

 To convert meters to feet, multiply by 3.28. 

c

 To convert millirems to millisieverts, divide by 100. 

 
C-27 

Table C-11 Predicted Airborne Concentrations of Uranium and HF from the Proposed 

GLE Facility Stack Releases at Different Receptor Locations 

Location Direction Distance 

Metersa

Uranium234 

(pCi/m3

)

b

Uranium235 

(pCi/m3

)

b

Uranium236 

(pCi/m3

)

b

Uranium238 

(pCi/m3

)

b

Total 

Uranium 

(μg/m3

)

c

HFd

(μg/m3

) 

Site boundary North 4.0 × 102 2.6 × 10−7 1.0 × 10−8 1.1 × 10−10 3.6 × 10−8 1.1 × 10−7 2.2 × 10−4

Site Boundary Northnorthwest 5.7 × 102 1.2 × 10−7 4.6 × 10−9 5.1 × 10−11 1.7 × 10−8 5.2 × 10−8 1.0 × 10−4

Site boundary Northwest 9.2 × 102 6.1 × 10−8 2.4 × 10−9 2.7 × 10−11 8.6 × 10−9 2.7 × 10−8 5.3 × 10−5

Site boundary Westnorthwest 1.5 × 103 3.3 × 10−8 1.3 × 10−9 1.5 × 10−11 4.7 × 10−9 1.5 × 10−8 2.9 × 10−5

Site boundary West 1.7 × 103 5.0 × 10−8 2.0 × 10−9 2.2 × 10−11 7.1 × 10−9 2.2 × 10−8 4.4 × 10−5

Site boundary Westsouthwest 2.3 × 103 4.1 × 10−8 1.6 × 10−9 1.8 × 10−11 5.7 × 10−9 1.8 × 10−8 3.5 × 10−5

Site boundary Southwest 1.8 × 103 6.7 × 10−8 2.6 × 10−9 2.9 × 10−11 9.5 × 10−9 3.0 × 10−8 5.8 × 10−5

Site boundary Southsouthwest 1.9 × 103 6.6 × 10−8 2.6 × 10−9 2.9 × 10−11 9.4 × 10−9 2.9 × 10−8 5.7 × 10−5

Site boundary South 1.4 × 103 1.2 × 10−7 4.5 × 10−9 5.1 × 10−11 1.6 × 10−8 5.1 × 10−8 1.0 × 10−4

Site boundary Southsoutheast 1.7 × 103 4.2 × 10−8 1.7 × 10−9 1.9 × 10−11 6.0 × 10−9 1.9 × 10−8 3.7 × 10−5

Site boundary Southeast 2.7 × 103 2.5 × 10−8 9.6 × 10−10 1.1 × 10−11 3.5 × 10−9 1.1 × 10−8 2.1 × 10−5

Site boundary Eastsoutheast 1.3 × 103 4.4 × 10−8 1.7 × 10−9 1.9 × 10−11 6.2 × 10−9 1.9 × 10−8 3.8 × 10−5

Site boundary East 6.7 × 102 1.5 × 10−7 5.8 × 10−9 6.5 × 10−11 2.1 × 10−8 6.5 × 10−8 1.3 × 10−4

Site boundary Eastnortheast 4.3 × 102 2.5 × 10−7 9.7 × 10−9 1.1 × 10−10 3.5 × 10−8 1.1 × 10−7 2.1 × 10−4

Site boundary Northeast 3.5 × 102 3.4 × 10−7 1.3 × 10−8 1.5 × 10−10 4.8 × 10−8 1.5 × 10−7 3.0 × 10−4

Site boundary Northnortheast 3.5 × 102 2.8 × 10−7 1.1 × 10−8 1.2 × 10−10 4.0 × 10−8 1.2 × 10−7 2.4 × 10−4

Onsite member 

of the public 

South 2.5 × 102 4.3 × 10−7 1.7 × 10−8 1.9 × 10−10 6.1 × 10−8 1.9 × 10−7 3.7 × 10−4

Nearest 

resident 

Eastsoutheast 1.4 × 103 4.2 × 10−8 1.6 × 10−9 1.8 × 10−11 5.9 × 10−9 1.8 × 10−8 3.6 × 10−5

a

 To convert meters to feet, multiply by 3.28. 

b

 To convert picocuries to becquerels, multiply by 0.037. 

c

 106 micrograms = 1 gram. d

 HF concentrations are based on dispersion of a release point concentration of 7.8 μg/m3, or twice that estimated for the 

3-million-separative work unit (SWU) proposed National Enrichment Facility (NRC, 2005). 
C-28 

Table C-12 Estimated Doses from 

Cylinder Storage Pad 

Receptor Distance 

(meters) 

External Dose 

(millirems per 

year)a

50 218 

100 83.5 

150 40.3 

200 19.8 

250 10.5 

500 0.721 

1000 7.67 × 10-3

a

 To convert millirems to millisieverts, divide 

by 100. 

1 

2 C.4.1 GLE Preconstruction and Construction Workers 

3 

4 The maximum estimated dose for each of exposure pathway was calculated for an annual 

5 exposure period. These estimated doses are: 

6 

• internal dose from inhalation of resuspended contaminated soil: <6 × 10–5 7 millisievert per 

year (6 × 10–3 8 millirem per year) 

9 

• external dose from contaminated soil: <3.2 × 10–4 millisievert per year (3.2 × 10–2 10 millirem 

11 per year) 

12 

• estimated dose from air emissions associated with FMO operations: <2.8 × 10–5 13 millisievert 

per year (2.8 × 10–3 14 millirem per year) 

15 

16 • estimated dose from air emissions associated with proposed GLE operations: 

<3.2 × 10–7 millisievert per year (3.2 × 10–5 17 millirem per year) (see Table C-10) 

18 

• external dose from the existing site sources: <1.05 × 10–1 19 millisievert per year 

20 (10.5 millirems per year) 

21 

22 The total maximum estimated dose before and after the start of GLE operations is 

<1.05 × 10–1 23 millisievert per year (10.5 millirems per year). The maximum dose is dominated by 

24 the external dose received from existing sources. 

25 

The maximum dose to construction workers of 1.05 × 10–1 26 millisievert (1.05 millirem) is a very 

27 small fraction of background radiation exposure in the United States, which averages 

28 approximately 3.11 millisieverts per year (311 millirems per year) (see Section 3.11.1). The 

29 estimated maximum annual dose applies to workers in both the preconstruction and 

30 construction phases. 

31 
C-29 

Table C-13 Estimated Doses for Liquid Effluent Releases from the Proposed 

GLE Facility 

Exposure location Exposure Pathway 

Dose (mrem/yr)a

to a Member of 

Public 

Number 

of People 

Exposed 

Collective Dose 

(personmrem/yr)a

Fish ingestion 5.26 × 10−5 1414 7.44 × 10−2

Water ingestion during 

swimming 

4.37 × 10−7 1906 8.33 × 10−4

External exposure from 

swimming 

1.03 × 10−8 1906 1.96 × 10−5

External exposure from 

boating 

5.15 × 10−9 1244 6.41 × 10−6

External exposure from 

shoreline activities 

2.01 × 10−5 1231 2.47 × 10−2

Confluence with 

Unnamed Tributary #1 

to Northeast Cape 

Fear River 

Total for a member of 

public 

7.32 × 10−5

 NAb NAb

Fish ingestion 5.26 × 10−5 1414 7.44 × 10−2

Water ingestion during 

swimming 

4.37 × 10−7 1906 8.33 × 10−4

External exposure from 

swimming 

1.03 × 10−8 1906 1.96 × 10−5

External exposure from 

boating 

5.15 × 10−9 1244 6.41 × 10−6

External exposure from 

shoreline activities 

2.01 × 10−5 1231 2.47 × 10−2

Just South of GE 

Wilmington Site 

Boundary 

Total for a member of 

public 

7.32 × 10−5 NA NA 

Fish ingestion 5.06 × 10−5 1414 7.15 × 10−2

Water ingestion during 

swimming 

4.21 × 10−7 1906 8.02 × 10−4

External exposure from 

swimming 

9.95 × 10−9 1906 1.90 × 10−5

External exposure from 

boating 

4.98 × 10−9 1244 6.20 × 10−6

External exposure from 

shoreline activities 

1.93 × 10−5 1231 2.38 × 10−2

NC 133 Bridge 

Total for a member of 

public 

7.03 × 10−5

 NA NA 

 Total population dose NA NA 2.72 × 10−1

a

 To convert millirems to millisieverts, divide by 100. 

b

 NA = not applicable. 
C-30 

1 The total maximum possible dose to construction workers from all pathways is less than the 

2 10 CFR 20.1301(a)(1) limit of 1 millisievert per year (100 millirems per year) for members of the 

3 general public, even for estimates combining the most conservative analytical assumptions. 

This is a negligible dose, representing a lifetime excess cancer risk of less than 5 × 10–6 4 (less 

5 than 5 chances in 1,000,000 of contracting a fatal cancer) when using a risk coefficient of 

5 × 10–2 risk/sievert (5 × 10–4 6 risk/rem) (ICRP, 1991). 

7 

A maximum HF concentration of 3.7 × 10–4 micrograms per cubic meter (4.5 × 10–7 8 parts per 

9 million) is estimated at the location of the onsite member of the public (e.g., construction 

worker). Uranium emissions would result in a maximum uranium concentration of 1.9 × 10–7 10 

11 micrograms per cubic meter at the location of the onsite construction worker (Table C-11). Both 

12 the estimated HF and uranium concentrations at onsite exposure locations are orders of 

13 magnitude below safe levels established by the Occupational Safety and Health Administration 

14 (2.5 micrograms per cubic meter for HF [3.1 parts per million] and 50 micrograms per cubic 

15 meter for uranium, each averaged over eight hours; see Section 3.11.2). 

16 

17 C.4.2 Hypothetical Receptor at the Site Boundary and Nearest Resident 

18 

19 Table C-11 shows the estimated dose to hypothetical receptors residing at the site boundary in 

20 each of the 16 directions modeled in CAP88-PC Version 3.0 computer code. It also includes 

21 the dose to the nearest resident. The maximum dose to a hypothetical receptor at the 

22 Wilmington Site boundary (0.35 kilometers [0.22 miles] in the northeast direction) due to 

operation of the proposed GLE Facility is estimated to be 1.1 × 10–6 23 millisievert per 

year (1.1 × 10–4 24 millirem per year). The dose to the nearest resident located at 1.35 kilometers 

(0.84 miles) east-southeast of the proposed GLE Facility is estimated to be 1.4 × 10–7 25 

millisievert per year (1.4 × 10–5 26 millirem per year). These estimated doses are well below the 

27 10 CFR 20.1301(a)(1) limit of 1 millisievert (100 millirems) per year for members of the public 

28 and the 40 CFR Part 61, Subpart H (NESHAPs) airborne dose limit of 0.1 millisievert 

29 (10 millirems) per year. 

30 

31 The estimated uranium and HF levels at the site boundary and at the location of the nearest 

32 resident given in Table C-11 are lower than onsite levels. HF concentrations at any exposure 

33 location, moreover, are far below the most stringent State or Federal ambient air quality 

34 standards for the general public (e.g., the State of Washington’s standard of 8.7 micrograms per 

35 cubic meter (0.011 parts per million); see Section 3.11.2). 

36 

37 C.4.3 Estimated Doses from Liquid Effluent Releases 

38 

39 Table C-13 shows the estimated dose to a member of the public involved in recreational 

40 activities at three potential exposure locations, as calculated using the GENII Version 2.06 

41 computer code. The maximum dose is to a member of the public due to operation of the 

proposed GLE Facility is estimated to be 7.3 × 10–7 millisievert per year (7.3 × 10–5 42 millirem 

43 per year). 

44 

45 The estimated doses for the liquid effluent releases from the proposed GLE Facility are well 

46 below the 10 CFR 20.1301(a)(1) limit of 1 millisievert (100 millirems) per year for members of 

the public. The population dose is estimated to be 2.7 × 10–3 47 person-millisievert per year 

(2.7 × 10–1 48 person-millirem per year). 
C-31 

1 C.4.4 Operational Worker Doses 

2 

3 The existing nuclear and industrial safety program at the Wilmington Site would be expanded to 

4 include operations of the proposed GLE Facility. The program would monitor the occupational 

5 workers at the proposed facility for internal exposure from intake of uranium as well as the dose 

6 from external exposure to radiation. GLE would also apply an annual administrative limit of 

7 40 millisieverts (4000 millirems), which is below the 10 CFR 20.1201 annual limit of 

8 50 millisieverts (5000 millirems) for radiation workers. 

9 

10 GNF-A has implemented a comprehensive exposure control program at the Wilmington Site to 

11 manage occupational radiation exposure and dose. The program maintains exposures “As Low 

12 As Reasonably Achievable” (ALARA) through the use of radiation monitoring systems, 

13 personnel dosimetry, and mitigation systems to reduce environmental concentrations of 

14 uranium. The average total effective dose equivalent (TEDE) to workers from existing GNF-A 

15 operations at the Wilmington Site for 2003–2007 varied from 0.5 to 0.75 millisievert (50 to 

16 75 millirems), and the maximum TEDE during the same period varied from 4.7 to 

17 5.6 millisieverts (470 to 560 millirems) (NRC, 2009). 

18 

19 From operations of the proposed GLE Facility, the most significant contributor to occupational 

20 radiation exposure would be direct radiation from uranium hexafluoride (UF6). It is expected that 

21 the average occupational doses at the proposed GLE Facility would be similar to occupational 

22 doses at existing fuel cycle facilities in the United States. For such facilities, the most 

23 substantial sources of direct radiation would likely include full Type 48Y cylinders containing 

24 feed material or depleted UF6 and empty Type 48Y cylinders containing residual material 

25 (NRC, 2005). Table C-14 presents occupational doses at fuel cycle facilities within the 

26 United States for 2003–2007 (Burrows, 2005; Burrows; 2006; Lewis et al., 2008). 

27 

28 The occupational exposure analysis and the historical exposure data from the United States 

29 Enrichment Corporation facilities and the existing GNF-A operations at the Wilmington Site 

30 demonstrate that a properly administered radiation protection program at the proposed GLE 

31 Facility would maintain radiological occupational impacts below the regulatory limits of 

32 10 CFR 20.1201. 

33 
C-32 

Table C-14 Annual CEDEa and TEDEb for Fuel Cycle Facilities within the United States for 20

Year 

Number of 

Monitored 

Individuals 

Workers 

with 

Measured 

TEDE 

Collective 

TEDE 

(personrem)c,d

Average 

Measured 

TEDE 

(rem) 

Workers 

with 

Measured 

DDE 

Collective 

DDE 

(personrem) 

Average 

Measured 

DDE (rem) 

Workers 

with 

Measured 

CEDE 

Colle

CE

(per

re

2003 7738 3633 556 0.15 2815 258 0.09 2255 22004 7562 3814 514 0.13 2933 258 0.09 2327 22005 7699 3371 497 0.15 2385 238 0.10 2173 22006 7417 3413 522 0.15 2475 283 0.11 2131 22007 7536 3225 429 0.13 2254 230 0.10 1983 1a Committed effective dose equivalent = total radiation dose received from ingestion or inhalation of radioactive material. b Total effective dose equivalent = CEDE plus DDE (deep dose equivalent from external radiation). c 1 rem = 1000 mrem. d To convert rems to sieverts, divide by 100. 

Sources: Burrows, 2005; Burrows, 2006; Lewis, et al. 2008. 
C-33 

1 C.5 References 

2 

3 (Burrows, 2005) Burrows, S., and D.A. Hagemeyer. “Occupational Radiation Exposure at 

4 Commercial Nuclear Power Reactors and Other Facilities 2004.” NUREG-0713, Volume 26. 

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7 

8 (Burrows, 2006) Burrows, S., and D.A. Hagemeyer. “Occupational Radiation Exposure at 

9 Commercial Nuclear Power Reactors and Other Facilities 2005.” NUREG-0713, Volume 27. 

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12 

13 (EPA, 1997) U.S. Environmental Protection Agency, Office of Research and Development, 

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18 (EPA, 1999) U.S. Environmental Protection Agency. “Cancer Risk Coefficients for Exposure to 

19 Radionuclides: Federal Guidance Report No. 13.” EPA 402-R-99-001. Prepared by Oak Ridge 

20 National Laboratory. September. <http://www.epa.gov/rpdweb00/docs/federal/402-r-99-

21 001.pdf> (Accessed March 2, 2010). 

22 

23 (GLE, 2008) GE-Hitachi Global Laser Enrichment LLC. “Environmental Report for the GLE 

24 Commercial Facility, Revision 0.” December. ADAMS Accession No. ML090910573. 

25 

26 (GLE, 2009a) GE-Hitachi Global Laser Enrichment LLC. Letter from A. Kennedy (GE-Hitachi 

27 Global Laser Enrichment LLC) to A. Kock (U.S. Nuclear Regulatory Commission) dated June 8. 

28 “Subject: GE-Hitachi Global Laser Enrichment Submittal of Additional Information Related to 

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31 

32 (GLE, 2009b) GE-Hitachi Global Laser Enrichment LLC. Letter from A. Kennedy (GE-Hitachi 

33 Global Laser Enrichment LLC) to A. Kock (U.S. Nuclear Regulatory Commission) dated 

34 November 11. “Subject: GE-Hitachi Global Laser Enrichment Response (#2) to Request for 

35 Additional Information Related to NRC Review of GLE Environmental Report.” ADAMS 

36 Accession No. ML093220060. 

37 

38 (GLE, 2009c) GE-Hitachi Global Laser Enrichment LLC. Letter from J. Olivier (GE-Hitachi 

39 Global Laser Enrichment LLC) to J. Davis (U.S. Nuclear Regulatory Commission) dated 

40 November 23. Subject: Submittal of Corrected Response to RAI 4-1-A. ADAMS Accession 

41 No. ML093270378. 

42 

43 (GNF-A, 2007) Global Nuclear Fuels-Americas LLC. “Site Environmental Report Supplement 

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45 

46 (ICRP, 1991) International Commission on Radiological Protection. “1990 Recommendations of 

47 the International Commission on Radiological Protection.” ICRP Publication 60. April. 

48 
C-34 

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4 

5 (Lewis et al., 2008) Lewis, D.E., E. Dickson, and D.A. Hagemeyer. “Occupational Radiation 

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9 

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13 (NCRP, 1996) National Council on Radiation Protection and Measurements. “Screening Models 

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16 

17 (NRC, 2005) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for 

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21 

22 (NRC, 2009) U.S. Nuclear Regulatory Commission. “Environmental Assessment for the 

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25 

26 (Rosnick, 2007) Rosnick, R. “CAP88-PC Version 3.0 Users Guide.” December 9. 

27 <http://www.epa.gov/rpdweb00/docs/cap88/userguide_120907.pdf> (Accessed January 29, 

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29 

30 (Slade, 1968) Slade, D.H. (ed.). “Meteorology and Atomic Energy – 1968.” USAED, 

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32 

33 (Yu et al., 2001) Yu, C., et al. “User’s Manual for RESRAD Version 6.” ANL/EAD/04. Argonne 

34 National Laboratory. July. <http://web.ead.anl.gov/resrad/documents/resrad6.pdf> (Accessed 

35 October 29, 2009). 

36 

37 (Yu et al., 2003) Yu, C., et al. “User’s Manual for RESRAD-BUILD Version 3.” ANL/EAD/03-1. 

38 Argonne National Laboratory. June. <http://web.ead.anl.gov/resrad/documents/ 

39 ANL-EAD-03-1.pdf> (Accessed October 29, 2009). 
D-1 

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14 APPENDIX D 

15 TRANSPORTATION METHODOLOGY, ASSUMPTIONS, AND IMPACTS 

16 
D-2 

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D-3 

1 APPENDIX D 

2 TRANSPORTATION ANALYSIS METHODOLOGY, ASSUMPTIONS, AND IMPACTS 

3 

4 D.1 Introduction 

5 

6 This appendix provides the detailed methodology, input parameters and assumptions, and 

7 results for the transportation risk analysis performed in this draft Environmental Impact 

8 Statement (EIS) for the proposed General Electric (GE)-Hitachi Global Laser Enrichment (GLE) 

9 Facility near Wilmington, North Carolina. The analysis evaluates transportation of: 

10 

11 • natural uranium hexafluoride (UF6) (i.e., not enriched) feed to the GLE Facility 

12 

13 • enriched UF6 product from the GLE Facility to a fuel fabrication facility 

14 

15 • depleted UF6 to a conversion facility 

16 

17 • return of empty feed cylinders with residual contamination 

18 

19 • low-level radioactive waste (LLRW) for disposal 

20 

21 All domestic shipments are anticipated to occur via heavy haul tractor-trailer combination trucks. 

22 A number of these shipments may have multiple origins or destinations. UF6 feed may be 

23 obtained from a U.S. facility (Honeywell International, Metropolis, Illinois), a Canadian source 

24 (Cameco, Port Hope, Ontario, Canada) or overseas sources arriving at U.S. seaports 

25 (Portsmouth Marine Terminal [PMT], Portsmouth, Virginia; Dundalk Marine Terminal [DMT], 

26 Baltimore, Maryland). UF6 product may be used at the Wilmington Site or sent to other fuel 

27 fabrication facilities in Columbia, South Carolina (Westinghouse Electric) and Richland, 

28 Washington (AREVA NP). The depleted UF6 tails could be sent to facilities in either Paducah, 

29 Kentucky or Portsmouth, Ohio, both facilities currently under construction for conversion of 

30 depleted UF6 to uranium oxide for disposal. In the case of the low-level radioactive waste 

31 (LLRW) generated at the proposed GLE Facility, only one destination would be planned, the 

32 EnergySolutions disposal facility in Clive, Utah. Single shipment and annual impacts are 

33 evaluated for all potential shipment routes. Annual impacts are assumed based on all 

34 shipments of one material type over the same route (e.g., all depleted UF6 tails going to 

35 Paducah, Kentucky or all going Portsmouth, Ohio). 

36 

37 D.2 Methodology 

38 

39 D.2.1 Overview 

40 

41 The transportation risk assessment considers human health risks from routine transport 

42 (normal, incident-free conditions) of hazardous materials and from potential accidents. In both 

43 cases, risks associated with the nature of the cargo itself, or “cargo-related” impacts, and those 

44 related to the transportation vehicle (regardless of type of cargo), or “vehicle-related” impacts, 

45 are considered. 

46 
D-4 

1 D.2.1.1 Routine Transportation Risk 

2 

3 The radiological risk associated with routine transportation is cargo-related and results from the 

4 potential exposure to low levels of external radiation near a loaded shipment. It is assumed that 

5 there are no cargo-related risks posed by incident-free transport of hazardous chemicals. No 

6 direct chemical exposure to radioactive material will occur during routine transport because, as 

7 discussed in Section D.3.2, these materials will be in packages that are designed and 

8 maintained to ensure that they will contain and shield their contents during normal transport. 

9 Any leakage or unintended release would be considered under accident risks. 

10 

11 Vehicle-related risks during routine transportation are caused by potential exposure to increased 

12 vehicular emissions. These emissions include diesel exhaust, tire and brake particulate 

13 emissions, and fugitive dust raised from the roadbed by passing vehicles. 

14 

15 D.2.1.2 Accident Transportation Risk 

16 

17 The cargo-related radiological risk from transportation-related accidents lies in the potential 

18 release and dispersal of radioactive material into the environment during an accident and the 

19 subsequent exposure of the nearby population through multiple exposure pathways, such as 

20 exposure to contaminated soil, inhalation, or the ingestion of contaminated food. Cargo-related 

21 hazardous chemical accident impacts to human health during transportation come from 

22 immediate inhalation exposure resulting from container failure and chemical release during an 

23 accident. 

24 

25 Vehicle-related accident risks refer to the potential for transportation-related accidents that 

26 result in fatalities caused by physical trauma unrelated to the cargo. 

27 

28 D.2.2 Routine Risk Assessment Methodology 

29 

30 The RADTRAN 5 computer code (Neuhauser and Kanipe, 2003; Weiner et al., 2006) was used 

31 in the routine and accident cargo-related risk assessments to estimate the radiological impacts 

32 to collective populations. RADTRAN 5 was developed by Sandia National Laboratories to 

33 calculate population risks associated with the transportation of radioactive materials by truck, 

34 rail, air, ship, or barge. The code has been used extensively for transportation risk assessments 

35 since it was originally issued in the late 1970s as RADTRAN (RADTRAN 1) and has been 

36 reviewed and updated periodically. RADTRAN 1 was originally developed to facilitate the 

37 calculations presented in NUREG-0170 (NRC, 1977). 

38 

39 D.2.2.1 Collective Population Risk 

40 

41 The radiological risk associated with routine transportation results from the potential exposure to 

42 low-level external radiation in the vicinity of loaded shipments. Even under routine 

43 transportation, some radiological exposure could occur. Because the radiological 

44 consequences (dose) would occur as a direct result of normal operations, the probability of 

45 routine consequences is taken to be 1 in the RADTRAN 5 code. Therefore, the dose risk is 

46 equivalent to the estimated dose. 

47 
D-5 

1 For routine transportation, the RADTRAN 5 computer code considers major groups of 

2 potentially exposed persons. The RADTRAN 5 calculations of risk for routine highway 

3 transportation include exposures of the following population groups: 

4 

5 • Persons along the Route (Off-Link Population). Collective doses were calculated for all 

6 persons living or working within 0.8 kilometer (0.5 mile) of each side of a transportation 

7 route. The total number of persons within the 1.6-kilometer (1-mile) corridor was calculated 

8 separately for each route considered in the assessment. 

9 

10 • Persons Sharing the Route (On-Link Population). Collective doses were calculated for 

11 persons in all vehicles sharing the transportation route. This group includes persons 

12 traveling in the same or opposite directions as the shipment, as well as persons in vehicles 

13 passing the shipment. 

14 

15 • Persons at Stops. Collective doses were calculated for people who might be exposed while 

16 a shipment was stopped en route. For truck transportation, these stops include those for 

17 refueling, food, and rest. 

18 

19 • Crew Members. Collective doses were calculated for truck transportation crew members 

20 involved in the actual shipment of material. Workers involved in loading or unloading were 

21 not considered in the transportation analysis because they are considered to be facility 

22 workers. 

23 

24 The doses calculated for the first three population groups were summed to yield the collective 

25 dose to the public; the dose calculated for the fourth group represents the collective dose to 

26 workers. 

27 

28 The RADTRAN 5 calculations for routine dose generically compute the dose rate as a function 

29 of distance from a point source (Neuhauser and Kanipe, 2003). Associated with the calculation 

30 of routine doses for each exposed population group are parameters such as the radiation field 

31 strength, the source-receptor distance, the duration of exposure, vehicular speed, stopping time, 

32 traffic density, and route characteristics (such as population density). The RADTRAN manual 

33 contains derivations of the equations used and descriptions of these parameters 

34 (Neuhauser and Kanipe, 2003). 

35 

36 D.2.2.2 Maximally Exposed Individual Risk 

37 

38 In addition to the assessment of the routine collective population risk, the risk to a maximally 

39 exposed individual (MEI) was estimated. In RADTRAN 5, the MEI is assumed to be located 

40 30 meters (100 feet) from the transport route as the radioactive shipment passes at a speed of 

41 24 kilometers per hour (15 miles per hour). 

42 

43 D.2.2.3 Vehicle-Related Risk 

44 

45 Vehicle-related health risks resulting from routine transportation are associated with the 

46 generation of air pollutants by transport vehicles during shipment and would be independent of 

47 the radioactive or chemical nature of the shipment. The health endpoint assessed under routine 

48 transportation conditions was the excess latent mortality from inhalation of vehicular emissions. 
D-6 

1 These emissions consist of particulate matter in the form of diesel engine exhaust, tire and 

2 brake particulates, and fugitive dust raised from the roadway by the transport vehicle. Risk 

3 factors for pollutant inhalation in terms of latent mortality have been used in this analysis. 

4 Vehicle-related risks from routine transportation were calculated for each shipment by 

5 multiplying the total distance traveled by the appropriate risk factor. 

6 

7 D.2.3 Accident Assessment Methodology 

8 

9 The risk analysis for potential accidents differs fundamentally from the risk analysis for routine 

10 transportation because occurrences of accidents are statistical in nature. The accident risk 

11 assessment is treated probabilistically. Accident risk is defined as the product of the accident 

12 consequence (dose or exposure) and the probability of the accident occurring. In this respect, 

13 the analysis estimates the collective accident risk to populations by considering a spectrum of 

14 transportation-related accidents. The spectrum of accidents was designed to encompass a 

15 range of possible accidents, including low-probability accidents that have high consequences, 

16 and high-probability accidents that have low consequences (such as “fender benders”). For 

17 radiological risk, the results for collective accident risk can be directly compared with the results 

18 for routine collective risk because the latter results implicitly incorporate a probability of 

19 occurrence of 1 if the shipment takes place. 

20 

21 D.2.3.1 Radiological Accident Risk Assessment 

22 

23 The RADTRAN 5 calculation of collective accident risk uses models that quantify the range of 

24 potential accident severities and the responses of transported packages to accidents. The 

25 spectrum of accident severity is divided into several categories, each of which is assigned a 

26 conditional probability of occurrence – that is, the probability that if an accident does occur, it will 

27 be of a particular severity. Release fractions, defined as the fraction of the material in a 

28 package that could be released in an accident, are assigned to each accident severity category 

29 on the basis of the physical and chemical form of the material. The model takes into account 

30 the mode of transportation and the type of packaging through selection of the appropriate 

31 accident probabilities and release fractions, respectively. The accident rates, the definition of 

32 accident severity categories, and the release fractions used in this analysis are discussed 

33 further in Sections D.3 and D.4. 

34 

35 For accidents involving the release of radioactive material, RADTRAN 5 assumes that the 

36 material is dispersed in the environment according to standard Gaussian diffusion models. For 

37 the risk assessment, default data for atmospheric dispersion were used, representing an 

38 instantaneous ground-level release and a small-diameter source cloud (Neuhauser and Kanipe, 

39 2003). The calculation of the collective population dose following the release and dispersal of 

40 radioactive material includes the following exposure pathways: 

41 

42 • external exposure to the passing radioactive cloud 

43 

44 • external exposure to contaminated ground 

45 

46 • internal exposure from inhalation of airborne contaminants 

47 

48 • internal exposure from the ingestion of contaminated food 
D-7 

1 For the ingestion pathway, the fraction of farmland in each state traversed was used as input to 

2 the RADTRAN code. Doses of radiation from external exposure and the ingestion or inhalation 

3 of radionuclides were calculated by applying standard dose conversion factors (Eckerman and 

4 Ryman, 1993; ICRP, 1996). 

5 

6 D.2.3.2 Chemical Accident Risk Assessment 

7 

8 The risks from exposure to hazardous chemicals during transportation-related accidents, which 

9 includes consideration of the formation of hydrogen fluoride (HF) from the reaction of UF6 with 

10 moisture in the air for this assessment, can be either acute (result in immediate injury or fatality) 

11 or latent (result in cancer that would present itself after a latency period of several years). 

12 However, none of the chemicals that might be released in any of the transportation accidents 

13 involving UF6 are carcinogenic. As a result, no excess chemically induced latent cancers would 

14 be expected from accidental chemical releases. 

15 

16 The acute effects considered were assumed to exhibit a threshold nonlinear relationship with 

17 exposure; that is, some low level of exposure can be tolerated without inducing a health effect. 

18 To estimate risks, chemical-specific concentrations were developed for potential irreversible 

19 adverse effects. All individuals exposed at these levels or higher following an accident were 

20 included in the transportation risk estimates. 

21 

22 The primary exposure route of concern with respect to accidental release of hazardous 

23 chemicals would be inhalation. Although direct exposure to hazardous chemicals via other 

24 pathways such as ingestion or absorption through the skin (dermal absorption) would also be 

25 possible, these routes would be expected to result in much lower exposure than the inhalation 

26 pathway doses for the uranium compounds. The likelihood of acute effects would be much less 

27 for the ingestion and dermal pathways than for inhalation. 

28 

29 The acute health endpoint – potential irreversible adverse effects – was considered for the 

30 assessment of cargo-related population impacts from transportation accidents. However, 

31 chemical impacts would be negligible; past analyses of depleted UF6 shipments have shown 

32 that the estimates of irreversible adverse effects to be approximately 1 to 3 orders of magnitude 

33 lower than the estimates of public latent cancer fatalities from radiological accident exposure 

34 (DOE, 2004a; DOE, 2004b; NRC, 2005a). In addition, no more than one percent of cases 

35 involving irreversible adverse effects due to exposure to HF or uranium compounds result in 

36 fatalities (Policastro, 1997). Thus, no further analysis of chemical hazards posed by transport 

37 was conducted for this draft EIS as radiological accident impacts are shown to be SMALL and 

38 the relative chemical hazards would be less. 

39 

40 D.2.3.3 Vehicle-Related Accident Risk Assessment 

41 

42 The vehicle-related accident risk refers to the potential for transportation accidents that could 

43 result directly in fatalities not related to the nature of the cargo in the shipment. This risk 

44 represents fatalities from physical trauma. State-average rates for transportation fatalities are 

45 used in the assessment. Vehicle-related accident risks are calculated by multiplying the total 

46 distance traveled by the rates for transportation fatalities. In all cases, the vehicle-related 

47 accident risks are calculated on the basis of distances for round-trip shipment since the 

48 presence or absence of cargo would not be a factor in accident frequency. 
D-8 

1 D.3 Input Parameters and Assumptions 

2 

3 The principal input parameters and assumptions used in the transportation risk assessment are 

4 discussed in this section. Where appropriate, applicable government regulations are 

5 referenced. Transportation of hazardous chemical and radioactive materials is governed by 

6 U.S. Department of Transportation (DOT), U.S. Nuclear Regulatory Commission (NRC), and 

7 U.S. Environmental Protection Agency (EPA) regulations, and by the Hazardous Materials 

8 Transportation Act (HMTA) (49 U.S.C. 5101 et seq.). These regulations may be found in the 

9 U.S. Code of Federal Regulations (CFR) at 49 CFR Parts 171−178, 49 CFR Parts 383−397, 

10 10 CFR Part 71, and 40 CFR Parts 262 and 265, respectively. State agencies are also involved 

11 in regulating such transport within their borders. All transportation-related activities must be in 

12 accordance with applicable regulations of these agencies. However, the DOT and NRC have 

13 primary regulatory responsibility for shipment of radioactive materials. Those regulations most 

14 pertinent to this risk assessment can be found in 49 CFR Part 173, 49 CFR Part 397, and 

15 10 CFR Part 71. 

16 

17 D.3.1 Route Characteristics 

18 

19 The transportation route selected for a shipment determines the total potentially exposed 

20 population and the expected frequency of transportation-related accidents. For truck 

21 transportation, the route characteristics most important to the risk assessment include the total 

22 shipping distance between each origin and destination and the population density along the 

23 route. 

24 

25 D.3.1.1 Route Selection 

26 

27 The DOT routing regulations concerning radioactive materials on public highways are 

28 prescribed in 49 CFR 397.101. The objectives of the regulations are to reduce the impacts of 

29 transporting radioactive materials, to establish consistent and uniform requirements for route 

30 selection, and to identify the role of state and local governments in routing radioactive materials. 

31 The regulations attempt to reduce potential hazards by prescribing that populous areas be 

32 avoided and that travel times be minimized. In addition, the regulations require that the carrier 

33 of radioactive materials ensure that the vehicle is operated on routes that minimize radiological 

34 risks, and that accident rates, transit times, population density and activity, time of day, and day 

35 of week are considered in determining risk. However, the final determination of the route is left 

36 to the discretion of the carrier, such as for shipments of UF6 (depleted or enriched to 

37 five percent uranium-235). 

38 

39 For this analysis, representative shipment routes were identified using the WebTRAGIS 

40 (Version 1.5.4) routing model (Johnson and Michelhaugh, 2003) for the truck shipments. The 

41 routes were selected to be reasonable and consistent with routing regulations and general 

42 practice, but they are considered only representative because the actual routes used would be 

43 chosen in the future and are often determined by the shipper. At the time of shipment, route 

44 selection would reflect current road conditions, including road repairs and traffic congestion. 

45 

46 The HIGHWAY data network in WebTRAGIS is a computerized road atlas that includes a 

47 complete description of the interstate highway system and of all U.S. highways. In addition, 

48 most principal state highways and many local and community highways are identified. The 
D-9 

1 code is periodically updated to reflect current road conditions and has been compared with 

2 reported mileages and observations of commercial trucking firms. 

3 

4 Routes are calculated within the model by minimizing the total impedance between origin and 

5 destination. The impedance is a function of distance and driving time along a particular 

6 segment of highway. The population densities along a route are derived from 2000 Census 

7 data from the U.S. Census Bureau. 

8 

9 The WebTRAGIS database version used was Highway Data Network 4.0. Summary route 

10 information on the truck routes used in the analysis is provided in Table D-1. 

11 

12 D.3.1.2 Population Density 

13 

14 Three population density zones – rural, suburban, and urban – were used for the population risk 

15 assessment. The fractions of travel and average population density in each zone were 

16 determined with the WebTRAGIS routing model. Rural, suburban, and urban areas are 

17 characterized according to the following breakdown: rural population densities range from 0 to 

18 54 persons per square kilometer (0 to 139 persons per square mile); suburban densities range 

19 from 55 to 1284 persons per square kilometer (140 to 3326 persons per square mile); and urban 

20 covers all population densities greater than 1284 persons per square kilometer (3326 persons 

21 per square mile). Use of these three population density zones is based on an aggregation of 

22 the 12 population density zones provided in the WebTRAGIS model output. For calculation 

23 purposes, information about population density was generated at the state level and used as 

24 RADTRAN input for all routes. Route average population densities and other route 

25 characteristics are given in Table D-1. 

26 

27 D.3.1.3 Accident and Fatality Rates 

28 

29 For calculating accident risks, vehicle accident involvement and fatality rates are taken from 

30 data provided in Saricks and Tompkins (1999). For each transport mode, accident rates are 

31 defined generically as the number of accident involvements (or fatalities) in a given year per unit 

32 of travel by that mode in the same year. Therefore, the rate is a fractional value – the accident33 involvement count is the numerator, and vehicular activity (total traveled distance) is the 

34 denominator. Accident rates are derived from multiple-year averages that automatically account 

35 for such factors as heavy traffic and adverse weather conditions. For assessment purposes, the 

36 total number of expected accidents or fatalities is calculated by multiplying the total shipping 

37 distance for a specific route by the appropriate accident or fatality rate. 

38 

39 For truck transportation, the rates presented by Saricks and Tompkins are specifically for heavy 

40 combination trucks involved in interstate commerce. Heavy combination trucks are rigs 

41 composed of a separable tractor unit containing the engine and one to three freight trailers 

42 connected to each other and the tractor. Heavy combination trucks are typically used for 

43 shipping radioactive wastes. Truck accident rates are computed for each state on the basis of 

44 statistics compiled by the DOT Office of Motor Carriers for 1994 to 1996. Saricks and Tompkins 

45 
D-10 

Table D-1 Summary Route Data 

 Total distance Fraction of travel Average population de

[persons/km2 (persons

Route [km (mi)] Rural Suburban Urban Rural Suburban 

UF6 feed coming from:  Portsmouth Marine Terminal 463 (288) 70.0 28.2 1.8 16.3 (42.2) 296.4 (767.7)  Dundalk Marine Terminal 754 (467) 50.1 42.0 8.0 18.2 (47.2) 369.7 (957.5)  Honeywell International 1313 (816) 55.2 42.3 2.5 19.1 (49.4) 332.2 (860.5)  Cameco 1397 (868) 52.6 41.7 5.8 18.9 (49.1) 351.1 (909.3) UF6 product going to:  Westinghouse Electric 479 (298) 65.0 33.6 1.3 16.6 (43.0) 276.0 (714.8)  AREVA NP 4785 (2973) 75.0 23.0 2.0 11.2 (28.9) 325.0 (841.8) Depleted UF6 tails going to:  Paducah conversion facility 1316 (818) 55.4 42.2 2.4 19.1 (49.6) 331.9 (859.5)  Portsmouth conversion facility 989 (615) 55.3 41.3 3.4 18.3 (47.5) 359.6 (931.4) Empty 48Y cylinder return to:  Honeywell International 1313 (816) 55.2 42.3 2.5 19.1 (49.4) 332.2 (860.5) LLRW going to:  EnergySolutions 3947 (2452) 73.0 24.6 2.5 11.4 (29.6) 335.0 (867.7) 
D-11 

1 present accident involvement and fatality counts, estimated kilometers of travel by state, and the 

2 corresponding average accident involvement and fatality rates for the three years investigated. 

3 Fatalities (including of crew members) are deaths that are attributable to the accident and that 

4 occurred within 30 days of the accident. 

5 

6 The truck accident assessment presented in this draft EIS uses accident (fatality) rates for travel 

7 on interstate highways. The total accident risk for a case depends on the total distance traveled 

8 in various states and does not rely on national average accident statistics. However, for 

9 comparative purposes, the national average truck accident rate on interstate highways 

presented in Saricks and Tompkins is 3.15 × 10–7 10 accidents per truck-kilometer 

(5.07 × 10–7 11 accidents per mile). Note that the accident rates used in this assessment were 

12 computed using all interstate shipments, regardless of the cargo. 

13 

14 D.3.2 Packaging 

15 

16 Shipment packaging for radioactive materials must be designed, constructed, and maintained to 

17 ensure that it will contain and shield the contents during normal transportation. For more highly 

18 radioactive material, the packaging must contain and shield the contents in severe accidents. 

19 The type of packaging used is determined by the radioactive hazard associated with the 

20 packaged material. The basic types of packaging required by the applicable regulations are 

21 designated as Type A, Type B, or industrial packaging (generally for low-specific activity [LSA] 

22 material). Table D-2 summarizes the shipment packaging for the shipments considered. 

23 

24 The LLRW and the feed and tails UF6 shipments would use Type A packaging. This type of 

25 packaging must withstand the conditions of normal transportation without the loss or dispersal of 

26 the radioactive contents. “Normal” transportation refers to all transportation conditions except 

27 those resulting from accidents or sabotage. Approval of Type A packaging is obtained by 

28 demonstrating that the packaging can withstand specified testing conditions intended to 

29 simulate normal transportation. Type A packaging usually does not require special handling, 

30 packaging, or transportation equipment. The UF6 feed and depleted tails would be shipped in 

31 Model 48Y cylinders (USEC, 1999). LLRW would be shipped in 4 × 4 × 4-foot waste boxes. 

32 The dimensions of the Model 48Y cylinder are shown in Figure D-1. 

33 

34 The enriched product would be shipped in Model 30B cylinders (USEC, 1999) in Type B 

35 overpacks. Figure D-2 displays the dimensions of the 30B cylinder. In addition to meeting all 

36 the Type A standards, Type B packaging must also provide a high degree of assurance that the 

37 package integrity will be maintained even during severe accidents, with essentially no loss of 

38 the radioactive contents or serious impairment of the shielding capability. Type B packaging 

39 must satisfy stringent testing criteria (as specified in 10 CFR Part 71) that were developed to 

40 simulate conditions of severe hypothetical accidents, including impact, puncture, fire, and 

41 immersion in water. The most widely recognized Type B packagings are the massive casks 

42 used to transport highly radioactive spent nuclear fuel from nuclear power stations. For 

43 shipping the Model 30B cylinders, a UX-30 overpack would be used. The UX-30 has a diameter 

44 of 1.10 meters (43.5 inches) and a 2.44 meters (96 inches) length (NRC, 2009).
D-12 

Table D-2 Radioactive Material Shipment Information 

Material Shipment Configuration 

Annual Average 

Number of 

Shipments 

UF6 feed 1-48Y cylinder 900 

UF6 product 5-30B cylinders 50 

Depleted UF6 tails 1-48Y cylinder 800 

Empty cylinders 2-48Y cylinders with residual heels 50 

LLRW 36-4 × 4 × 4-foot waste boxes 36 

Sources: GLE, 2008; GLE, 2009.

Figure D-1 Schematic of a Type 48Y Cylinder (USEC, 1995) 
D-13 

Figure D-2 Schematic of a Type 30B Cylinder (USEC, 1995) 

Table D-3 Single-Shipment Radionuclide Inventories (Curies)a

Isotopes UF6 Feed Enriched 

UF6

Depleted UF6

(tails) 

Empty 

Cylinders LLRW 

Uranium-234 2.8 22.6 0.509 9.0 × 10–4 0.027 

Uranium-235 0.13 0.830 0.037 1.0 × 10–4 0.0012 

Uranium-238 2.8 2.46 2.835 0.0051 0.027 

a

 Source: GLE, 2009. 

1 

2 D.3.3 Shipment Configurations and Number of Shipments 

3 

4 The anticipated shipment information for the proposed action is summarized in Table D-2. 

5 Table D-3 lists the radionuclide inventory for each shipment type. Uranium feed and depleted 

6 tails shipments would consist of one Type 48Y cylinder per truck. Each cylinder would contain 

7 about 12.4 metric tons (13.7 tons) of natural or depleted UF6. Enriched UF6 product would be 

8 shipped in Type 30B cylinders in UX-30 overpacks, five cylinders to a truck. Each 30B cylinder 

9 would contain approximately 2.3 metric tons (2.5 tons) of product. LLRW would be shipped in 

10 4 × 4 × 4-foot waste boxes, 36 to a truck. The types and amounts of LLRW to be shipped are 

11 discussed in Section 4.2.12.2. 

12 
D-14 

1 D.3.4 Accident Characteristics 

2 

3 Assessment of transportation accident risk takes into account the fraction of material in a 

4 package that would be released or spilled to the environment during an accident, commonly 

5 referred to as the release fraction. The release fraction is a function of the severity of the 

6 accident and the material packaging. For instance, a low-impact accident, such as a “fender7 bender,” would not be expected to cause any release of material. Conversely, a very severe 

8 accident would be expected to release nearly all of the material in a shipment into the 

9 environment. The method used to characterize accident severities and the corresponding 

10 release fractions for estimating both radioactive and chemical risks are described below. 

11 

12 D.3.4.1 Accident Severity Categories 

13 

14 A method to characterize the potential severity of transportation-related accidents has been 

15 described in NUREG-0170, Final Environmental Statement on the Transportation of Radioactive 

16 Material by Air and Other Modes (NRC, 1977). The NRC method divides the spectrum of 

17 transportation accident severities into eight categories. Other studies have divided the same 

18 accident spectrum into six categories (Wilmot, 1981), 20 categories (Fischer et al., 1987), or 

19 more (Sprung et al., 2000); however, these latter studies focused primarily on accidents 

20 involving shipments of spent nuclear fuel (SNF). In this analysis, the NUREG-0170 scheme 

21 was used for all shipments. 

22 

23 The NUREG-0170 scheme for truck transportation accident classification is shown in 

24 Figure D-3. Severity is described as a function of the magnitudes of the mechanical forces 

25 (impact) and thermal forces (fire) to which a package may be subjected during an accident. 

26 Because all accidents can be described in these terms, severity is independent of the specific 

27 accident sequence. In other words, any sequence of events that results in an accident in which 

28 a package is subjected to forces within a certain range of values is assigned to the accident 

29 severity category associated with that range. The scheme for accident severity is designed to 

30 take into account all credible transportation-related accidents, including those accidents with low 

31 probability but high consequences and those with high probability but low consequences. 

32 

33 Each severity category represents a set of accident scenarios defined by a combination of 

34 mechanical and thermal forces. A conditional probability of occurrence C that is, the probability 

35 that if an accident occurs, it is of a particular severity C is assigned to each category. The 

36 fractional occurrences for accidents by accident severity category and population density zone 

37 are shown in Table D-4 and are used for estimating the radioactive risks. 

38 

39 Category I accidents are the least severe but the most frequent; Category VIII accidents are 

40 very severe but very infrequent. To determine the expected frequency of an accident of a given 

41 severity, the conditional probability in the category is multiplied by the baseline accident rate. 

42 Each population density zone has a distinct distribution of accident severities related to 

43 differences in average vehicular velocity, traffic density, location (rural, suburban, or urban), and 

44 other factors. 

45 
D-15 

VII

VI VII

VIII

V VI VII

IV V VI VII

III IV V VI VII

II III IV

I III IV

0.5 1 1.5 2

0

6.7

22

89

220

440

1330

2220

1300° Kelvin Fire Duration (hours) 1 

2 Figure D-3 Scheme for NUREG-0170 Classification by Accident 

3 Severity Category for Truck Accidents (NRC, 1977) 

4 

5 

6 D.3.4.2 Package Release Fractions 

7 

8 In NUREG-0170, radiological and chemical consequences are calculated by assigning package 

9 release fractions to each accident severity category. The release fraction is defined as the 

10 fraction of the material in a package that could be released from the package as the result of an 

11 accident of a given severity. Release fractions take into account all mechanisms necessary to 

12 create release of material from a damaged package to the environment. Release fractions vary 

13 according to the type of package and the physical form of the material. 

14 

15 Representative release fractions for accidents involving all shipments were taken from 

16 NUREG-0170 (NRC, 1977). The recommendations in NUREG-0170 are based on best 

17 engineering judgments and have been shown to provide conservative estimates of material 

18 releases following accidents. The release fractions used are those reported in NUREG-0170 for 

19 both Type A and Type B packages. Release fractions for accidents of each severity category 

20 are given in Table D-5. As shown in that table, the amount of material released from the 

21 package ranges from zero for minor accidents to 100% for the most severe accidents. 

22 
D-16 

Table D-4 Fractional Occurrences for Truck Accidents 

by Severity Category and Population Density Zone 

 Fractional occurrence by 

population density zone 

Severity 

Category 

Fractional 

Occurrence Rural Suburban Urban 

I 0.55 0.1 0.1 0.8 

II 0.36 0.1 0.1 0.8 

III 0.07 0.3 0.4 0.3 

IV 0.016 0.3 0.4 0.3 

V 0.0028 0.5 0.3 0.2 

VI 0.0011 0.7 0.2 0.1 

VII 8.5 × 10–5 0.8 0.1 0.1 

VIII 1.5 × 10–5 0.9 0.05 0.05 

Source: NRC, 1977.

1 

2 

3 Also important for the purposes of risk assessment are the 

4 fraction of the released material that can be entrained in an 

5 aerosol (part of an airborne contaminant plume) and the 

6 fraction of the aerosolized material that is also respirable 

7 (of a size that can be inhaled into the lungs). These 

8 fractions depend on the physical form of the material. 

9 Most solid materials are difficult to release in particulate 

10 form and are, therefore, relatively nondispersible. 

11 Conversely, liquid or gaseous materials are relatively easy 

12 to release if the container is breached in an accident. 

13 

14 The aerosolized fraction for the UF6 shipments was taken 

15 to be 0.01, except in the case of higher severity accidents 

16 (Categories VI through VIII) involving fire, for which it was 

17 taken to be 0.33 (NRC, 2005a). The respirable fraction 

18 was taken to be 1 for all accidents. For LLRW, which was 

19 assumed to behave as a loose powder, the aerosolized 

20 fraction was set to 0.1, with a respirable fraction of 0.05 

21 (Neuhauser and Kanipe, 2003). 

22 

23 D.3.4.3 Atmospheric Conditions During Accidents 

24 

25 Hazardous material released to the atmosphere is 

26 transported by the wind. The amount of dispersion, or 

27 dilution, of the contaminant material in the air depends on 

28 the meteorologic conditions at the time of the accident. 

Table D-5 Estimated Release 

Fractions for Type A and 

Type B packages under 

Various Accident Severity 

Categories 

 Release fractiona

Severity 

Category Type A Type B 

I 0 0 

II 0.01 0 

III 0.1 0.01 

IV 1 0.1 

V 1 1 

VI 1 1 

VII 1 1 

VIII 1 1 

a

 Values are for total material release 

fraction (the fraction of material in a 

package released to the environment 

during an accident). 

Source: NRC, 1977. 
D-17 

1 Because predicting the specific location of an offsite transportation-related accident and the 

2 exact meteorologic conditions at the time of the accident is impossible, generic atmospheric 

3 conditions were selected for the accident risk assessment. Neutral weather conditions were 

4 assumed. These conditions were represented by Pasquill atmospheric stability Class D with 

5 a wind speed of 4 meters per second (9 miles per hour). Because neutral meteorological 

6 conditions are the most frequently occurring atmospheric stability condition in the United States, 

7 these conditions are most likely to be present in the event of an accident involving a hazardous 

8 material shipment. Observations at National Weather Service surface meteorological stations at 

9 more than 300 U.S. locations indicate that on a yearly average, neutral conditions (represented 

10 by Pasquill Classes C and D) occur about half (50 percent) the time; stable conditions (Pasquill 

11 Classes E and F) occur about one-third (33 percent) of the time; and unstable conditions 

12 (Pasquill Classes A and B) occur about one-sixth (17 percent) of the time (Doty et al., 1976). 

13 The neutral category predominates in all seasons, but it is most prevalent (nearly 60 percent of 

14 the observations) during winter. 

15 

16 D.3.5 Radiological Risk Assessment Input Parameters and Assumptions 

17 

18 The dose (and, correspondingly, the risk) to populations during routine transportation of 

19 radioactive materials is directly proportional to the assumed external dose rate from the 

20 shipment. The actual dose rate from the shipment is a complex function of the composition and 

21 configuration of shielding and containment materials used in the packaging, the geometry of the 

22 loaded shipment, and the characteristics of the radioactive material itself. 

23 

24 Table D-6 lists the external dose rates used for this analysis that were adapted from Table D-7 

25 of NUREG-1790, Environmental Impact Statement for the Proposed National Enrichment 

26 Facility in Lea County, New Mexico (NRC, 2005b) and used in this transportation analysis. The 

27 dose rates are presented in terms of the transport index (TI), which is the dose rate at 1 meter 

28 (3 feet) from the lateral sides of the transport vehicle. The regulatory limit established in 

29 49 CFR 173.441 and 10 CFR 71.47 to protect the public is 0.1 millisievert per hour (10 millirem 

30 per hour) at 2 meters (6 feet) from the outer lateral sides of the transport vehicle. 

31 

32 Note that in Table D-6, the external radiation levels for an empty cylinder are approximately 

33 double those for a full cylinder. This occurs for two reasons. First, after UF6 is vaporized and 

34 removed from a cylinder, the radioactive uranium daughter products that build up due to the 

35 radioactive decay of uranium collect at the bottom and form what is known as a “heel.” The 

36 nature of the radiation emitted from the uranium daughter products results in a greater release 

37 of gamma radiation than occurs from just uranium. Second, uranium is also a good shield 

38 material for gamma radiation. When the cylinder is full of UF6, the uranium daughters are 

39 distributed throughout the cylinder and emitted radiation must pass through a significant amount 

40 of uranium (and thus, can be stopped or absorbed by the uranium). It is only gamma radiation 

41 from the uranium daughters near to the inner surface of the cylinder that can penetrate the 

42 cylinder and contribute to a nearby person’s radiation exposure. Because the empty cylinder no 

43 longer has the high shielding capability of the UF6 versus the remaining vapor, and the heel 

44 concentrates the more highly radioactive uranium daughters right next to the inner cylinder 

45 surface, the radiation levels of the empty UF6 cylinder are higher than those for a full UF6

46 cylinder.
D-18 

Table D-6 External Dose Rates and Package Sizes Used in 

RADTRAN 

Material Vehicle Size 

(m) 

Crew View 

(m) 

Shipment External Dose 

Rate at 1 m (mrem/hr)a

UF6 feed 3.73 1.23 0.29 

UF6 product 12 0.76 0.95 

Depleted UF6 tails 3.73 1.23 0.28 

Empty cylindersb 8 1.23 2.0 

LLRW 14 2.44 0.15 

a

 Sources: GLE, 2008; GLE, 2009; NRC, 2005b. 

b

 Contains residual material. See text for discussion.

Table D-7 General RADTRAN Input Parametersa

Parameter Truck 

Number of crew members 2 

Distance from source to crew (m) 3.1 

Average vehicular speed (km/h)b

 Rural 

 Suburban 

 Urban 

88.49 

88.49 

88.49 

Number of people per vehicle sharing route 2 

Population density along routes (persons/km2)

c

 Route-specific 

One-way traffic count (vehicles/h)d

 Rural 

 Suburban 

 Urban 

530 

760 

2400 

Stop time (h/km)e 0.0014 

Population density at stops (persons/km2)

f

 

 1 to 10 m from vehicle 

 10 to 800 m from vehicle 

30,000 

340 a

 Accident conditional probabilities are listed by severity category in 

Table D-4; accident release fractions are given in Table D-5. 

b

 Fraction of rural and suburban travel on freeways was set to 1 in 

RADTRAN. Thus, the rural speed was used for both urban and 

suburban zones. 

c

 Route-specific population densities are listed in Table D-1. 

d

 DOE, 2002. 

e

 Hostick et al., 1992. Equivalent to 30 minutes for every 4 hours of 

driving at 88.49 km/hr (55 mph). 
D-19 

1 In addition to the specific parameters discussed previously, values for a number of general 

2 parameters must be specified within the RADTRAN code to calculate radiological risks. These 

3 general parameters define basic characteristics of the shipment and traffic and are specific to 

4 the mode of transportation. The RADTRAN user manual (Neuhauser and Kanipe, 2003) 

5 contains derivations and descriptions of these parameters. The general RADTRAN input 

6 parameters used in the radiological transportation risk assessment are summarized in 

7 Table D-7. 

8 

9 D.3.6 Routine Nonradiological Vehicle Emission Risks 

10 

11 Vehicle-related risks during incident-free transportation include incremental risks caused by 

12 potential exposure to airborne particulate matter from fugitive dust and vehicular exhaust 

13 emissions. The health endpoint assessed under routine transport conditions is the excess 

14 (additional) latent mortality caused by inhalation of vehicular emissions. These emissions occur 

15 primarily in the form of diesel exhaust and fugitive dust (resuspended particulates from the 

16 roadway). Strong epidemiological evidence exists suggesting that increases in ambient air 

17 concentrations of PM10 (particulate matter with a mean aerodynamic diameter less than or equal 

18 to 10 microns) lead to increases in mortality (EPA, 1996a; EPA, 1996b). Currently, it is 

19 assumed that no threshold exists and that the dose-response functions for most health effects 

20 associated with PM10 exposure, including premature mortality, are linear over the concentration 

21 ranges investigated (EPA, 1996a). Over both the short and long terms, fatalities (mortality) may 

22 result from life-shortening respiratory or cardiovascular diseases (EPA, 1996a; Ostro and 

23 Chestnut, 1998). The long-term fatalities also are assumed to include those from cancer. 

24 

25 The increased ambient air particulate concentrations caused by the transport vehicle, due to 

26 fugitive dust and diesel exhaust emissions, were related to premature latent fatalities in the form 

27 of risk factors for transportation risk assessments (Biwer and Butler, 1999). Thus, a value of 

8.36 × 10–10 28 latent fatalities per kilometer for truck transport was used in this assessment. This 

29 value is for heavy combination trucks (truck class VIIIB) and for areas with an assumed 

30 population density of one person per square kilometer (2.6 persons per square mile). One-way 

31 shipment risks are obtained by multiplying the appropriate risk factor by the average population 

32 density along the route and the route distance. The risks reported for routine vehicle risks in 

33 this analysis are for round-trip travel of the transport vehicle. 

34 

35 The vehicle risks reported here are estimates based on the best available data. However, as is 

36 true for the radiological risks, there is a large and not readily quantifiable degree of uncertainty 

37 in the vehicle emission risk factors. For example, large uncertainties exist as to the extent of 

38 increased mortality with an incremental rise in particulate air concentrations and as to whether 

39 there are threshold air concentrations that are applicable. Also, estimates of the particulate air 

40 concentrations caused by transport vehicles are dependent on location, road conditions, vehicle 

41 conditions, and weather. 

42 

43 As discussed by Biwer and Butler (1999), there are large uncertainties in the human health risk 

44 factors used to develop the emission risks. In addition, because of the conservatism of the 

45 assumptions made to reconcile results with those presented by EPA (EPA, 1993), latent fatality 

46 risks estimated with the above risk factor may be considered to be near an upper bound. Use of 

47 this risk factor for truck class VIIIB will give estimated fatalities comparable to those from 

48 accident fatalities in some cases. In addition, the question as to what exactly constitutes a 
D-20 

1 fatality as a direct consequence of increased PM10 levels from vehicle emissions has not been 

2 answered definitively, but long-term fatalities have been associated with increased levels of 

3 PM10 (Biwer and Butler, 1999). 

4 

5 D.4 Transportation Impacts 

6 

7 Single shipment transportation impacts are presented in Table 4-12 of Section 4.2.10.2. Total 

8 collective population transportation impacts are presented in Table 4-13. 

9 

10 D.5 References 

11 

12 (Biwer and Butler, 1999) Biwer, B.M. and J.P. Butler. “Vehicle Emission Unit Risk Factors for 

13 Transportation Risk Assessments.” Risk Analysis 19:1157–1171. 

14 

15 (DOE, 2002) U.S. Department of Energy. “A Resource Handbook on DOE Transportation Risk 

16 Assessment.” DOE/EM/NTP/HB-01. July. <http://www.doeal.gov/SWEIS/DOEDocuments/ 

17 089%20transrisk_handbook.pdf> (Accessed January 29, 2010). 

18 

19 (DOE, 2004a) U.S. Department of Energy. “Final Environmental Impact Statement for 

20 Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

21 Paducah, Kentucky, Site.” DOE/EIS-0359. June. <http://www.gc.energy.gov/NEPA/ 

22 finalEIS-0359.htm> (Accessed January 29, 2010). 

23 

24 (DOE 2004b) U.S. Department of Energy. “Final Environmental Impact Statement for 

25 Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the 

26 Portsmouth, Ohio, Site.” DOE/EIS-0360. June. <http://www.gc.energy.gov/NEPA/ 

27 finalEIS-0360.htm> (Accessed January 29, 2010). 

28 

29 (Doty et al., 1976) Doty, S.R., et al. “A Climatological Analysis of Pasquill Stability Categories 

30 Based on STAR Summaries.” National Oceanic and Atmospheric Administration, National 

31 Climatic Center. April. 

32 

33 (Eckerman and Ryman, 1993) Eckerman, K.F. and J.C. Ryman. “External Exposure to 

34 Radionuclides in Air, Water, and Soil: Federal Guidance Report No. 12.” EPA 402-R-93-081. 

35 Prepared by Oak Ridge National Laboratory for U.S. Environmental Protection Agency, Office of 

36 Radiation and Indoor Air. September. <http://www.epa.gov/rpdweb00/docs/federal/402-r-93-

37 081.pdf> (Accessed January 29, 2010). 

38 

39 (EPA, 1993) U.S. Environmental Protection Agency. “Motor Vehicle-Related Air Toxics Study.” 

40 EPA 420-R-93-005. Office of Mobile Sources. April. <http://www.epa.gov/otaq/regs/toxics/ 

41 tox_archive.htm#2> (Accessed March 3, 2010). 

42 

43 (EPA, 1996a) U.S. Environmental Protection Agency. “Review of the National Ambient Air 

44 Quality Standards for Particular Matter: Policy Assessment of Scientific and Technical 

45 Information.” EPA-452/R-96-013. Office of Air Quality Planning and Standards. July. 

46 

47 (EPA, 1996b) U.S. Environmental Protection Agency. “Air Quality Criteria for Particulate 

48 Matter.” EPA-600/P-95-001aF, Vols. 1–3. Office of Air Quality Planning and Standards. April. 
D-21 

1 (Fischer et al., 1987) Fischer, L.E., et al. “Shipping Container Response to Severe Highway 

2 and Railway Accident Conditions.” NUREG/CR-4829, UCID-20733. Prepared by Lawrence 

3 Livermore National Laboratory for U.S. Nuclear Regulatory Commission, Division of Reactor 

4 System Safety, Office of Nuclear Regulatory Research. <http://www.nrc.gov/reading-rm/doc5 collections/nuregs/contract/cr4829> (Accessed March 3, 2010). 

6 

7 (GLE, 2008) GE-Hitachi Global Laser Enrichment LLC. “Environmental Report for the 

8 GLE Commercial Facility, Revision 0.” December. ADAMS Accession No. ML090910573. 

9 

10 (GLE, 2009) GE-Hitachi Global Laser Enrichment LLC. Letter from A. Kennedy (GE-Hitachi 

11 Global Laser Enrichment LLC) to A. Kock (U.S. Nuclear Regulatory Commission) dated June 8. 

12 “Subject: GE-Hitachi Global Laser Enrichment Submittal of Additional Information Related to 

13 NRC Review of GLE Environmental Report.” ADAMS Accession No. ML092110764. 

14 

15 (Hostick et al., 1992) Hostick, C.J., et al. “Time/Motion Observations and Dose Analysis of 

16 Reactor Loading, Transportation, and Dry Unloading of an Overweight Truck Spent Fuel 

17 Shipment.” PNL-7206. Pacific Northwest Laboratory. <http://www.osti.gov/bridge/ 

18 product.biblio.jsp?osti_id=10142255> (Accessed January 29, 2010). 

19 

20 (ICRP, 1996) International Commission on Radiological Protection. “Age-Dependent Doses to 

21 the Members of the Public from Intake of Radionuclides Part 5, Compilation of Ingestion and 

22 Inhalation Coefficients.” ICRP Publication 72. September. 

23 

24 (Johnson and Michelhaugh, 2003) Johnson, P.E., and R.D. Michelhaugh. “Transportation 

25 Routing Analysis Geographic Information System (TRAGIS) User’s Manual.” ORNL/NTRC-006. 

26 Prepared by Oak Ridge National Laboratory for U.S. Department of Energy, National 

27 Transportation Program. June. <https://tragis.ornl.gov/TRAGISmanual.pdf> (Accessed 

28 January 29, 2010). 

29 

30 (Neuhauser and Kanipe, 2003) Neuhauser, K.S., and Kanipe, F.L. “RADTRAN 5 User Guide.” 

31 SAND2003-2354. Sandia National Laboratories. July. <http://www.doeal.gov/SWEIS/ 

32 OtherDocuments/392%20RADTRAN-2003.pdf> (Accessed January 29, 2010). 

33 

34 (NRC, 1977) U.S. Nuclear Regulatory Commission. “Final Environmental Statement on the 

35 Transportation of Radioactive Material by Air and Other Modes.” NUREG-0170. December. 

36 

37 (NRC, 2005a) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement on the 

38 Construction and Operation of a Proposed Mixed Oxide Fuel Fabrication Facility at the 

39 Savannah River Site, South Carolina.” NUREG-1767. January. <http://www.nrc.gov/reading40 rm/doc-collections/nuregs/staff/sr1767> (Accessed March 3, 2010). 

41 

42 (NRC, 2005b) U.S. Nuclear Regulatory Commission. “Environmental Impact Statement for 

43 the Proposed National Enrichment Facility in Lea County, New Mexico.” NUREG-1790. 

44 June. <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1790/> (Accessed 

45 March 26, 2009). 

46 

47 (NRC, 2009) U.S. Nuclear Regulatory Commission. “Directory of Certificates of Compliance for 

48 Radioactive Materials Packages.” NUREG-0383, Rev. 27, Vol. 2. 
D-22 

1 (Ostro and Chestnut, 1998) Ostro, B. and L. Chestnut. “Assessing the Health Benefits of 

2 Reducing Particular Matter Air Pollution in the United States.” Environmental Research A

3 76:94–106. 

4 

5 (Policastro, 1997) Policastro, A.J., et al. “Facility Accident Impact Analyses in Support of the 

6 Depleted UF6 Programmatic Environmental Impact Statement.” Environmental Assessment 

7 Division, Argonne National Laboratory. June. 

8 

9 (Saricks and Tompkins, 1999) Saricks, C. and M. Tompkins. “State-Level Accident Rates of 

10 Surface Freight Transportation: A Re-Examination.” ANL/ESD/TM-150. Argonne National 

11 Laboratory. <http://www.doeal.gov/SWEIS/OtherDocuments/442%20ANL%20ESD%20TM12 150%20state%20lvl%20accdnt%20rat.pdf> (Accessed January 29, 2010). 

13 

14 (Sprung et al., 2000) Sprung, J.L., et al. “Reexamination of Spent Fuel Shipment Risk 

15 Estimates.” NUREG/CR-6672, SAND2000-0234. Prepared by Sandia National Laboratories for 

16 the U.S. Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards. 

17 ADAMS Accession No. ML003698324. 

18 

19 (USEC, 1995) United States Enrichment Corporation. “Uranium Hexafluoride: A Manual of 

20 Good Handling Practices.” USEC-651, Rev. 7. January. <http://www.osti.gov/bridge/servlets/ 

21 purl/205924-LzIkaU/webviewable/205924.pdf> (Accessed October 22, 2009). 

22 

23 (USEC, 1999) United States Enrichment Corporation. “The UF6 Manual: Good Handling 

24 Practices for Uranium Hexafluoride.” USEC-651, Rev. 8. January. 

25 

26 (Weiner et al., 2006) Weiner, R.F., et al. “RadCat 2.3 User Guide.” SAND2006-6315. Sandia 

27 National Laboratories. September. <https://radtran.sandia.gov/docs/RadCat2_3UserGuide_ 

28 Rev1.pdf> (Accessed January 29, 2010). 

29 

30 (Wilmot, 1981) Wilmot, E.L. “Transportation Accident Scenarios for Commercial Spent Fuel.” 

31 SAND80-2124. Sandia National Laboratories. 

32 
E-1 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 APPENDIX E 

15 AIR QUALITY ANALYSIS 
E-2 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 [This page intentionally left blank] 
E-3 

1 APPENDIX E 

2 AIR QUALITY ANALYSIS 

3 

4 This appendix discusses detailed information on assumptions, emission factors, and emission 

5 calculations for criteria air pollutants. Detailed information on assumptions, parameter selection, 

6 and air dispersion modeling is also presented. For the air quality analysis, the lifespan of the 

7 GLE project is considered in four phases: 

8 

9 • Access road construction and land clearing (does not include other elements of 

10 preconstruction, such as ancillary building construction) 

11 

12 • Building construction (including ancillary building construction that occurs as part of 

preconstruction)1 13 

14 

15 • Start-up and final construction (includes concurrent indoor construction with staged testing 

16 and start-up of process units as completed) 

17 

18 • Facility operation 

19 

20 The analyses in this appendix are based on the assumption that a licensing decision would be 

21 made in late 2011, construction (if authorized) would start shortly after a licensing decision was 

22 made, and license termination would occur in 2051. Subsequently, the Commission’s Notice of 

23 Hearing and Commission Order (75 FR 1819) specified that a licensing decision be made within 

24 30 months of the Order (i.e., June 2012). Thus, the NRC staff currently expects that a licensing 

25 decision will be made in mid-2012, NRC-licensed construction will begin in mid-2012 (although 

26 the building construction phase, which includes ancillary building construction, may begin before 

27 NRC-licensed construction starts), and that termination of the 40-year license, if granted, will 

28 occur in 2052. The NRC staff expects that the dates for start-up and final construction (2013–

29 2017) and full facility operations (2017) will remain unchanged. The NRC staff expects that any 

30 resulting changes in the licensing and construction schedule would cause slight changes to the 

31 air quality analysis but would not affect the resulting conclusions. Any necessary changes will 

32 be reflected in the final EIS. 

33 

34 E.1 Emissions Estimation Associated with Construction and Operation of the 

35 Proposed GLE Facility 

36 

37 For convenience in emission inventories and air quality modeling, road construction is assumed 

38 to begin in April 2011, followed by land clearing for the remainder of 2011, and building 

39 construction, including ancillary building construction, which is part of preconstruction, for all of 

40 2012. Table E-1 presents general assumptions for estimating air emissions associated with 

41 construction and operation of the proposed General Electric (GE)-Hitachi Global Laser 

42 Enrichment LLC (GLE) Facility. Tables E-2 through E-5 discuss input parameters and activity43 specific assumptions used for estimating air emissions at the proposed GLE Facility. 

 

1

 For the purposes of estimating emission inventories and air quality modeling, the construction of 

ancillary structures, which is part of preconstruction, is grouped into building construction. 
E-4 

1 Tables E-6 through E-13 present average daily and annual emissions based on emission 

2 factors and activity levels (e.g., area disturbed, total vehicle miles traveled). 

3 

4 During access road construction and land clearing as well as building construction, air 

5 emissions would include fugitive dust from soil disturbances caused by heavy equipment and by 

6 truck traffic on unpaved roads, and engine exhaust emissions from off-road construction 

7 equipment and motor vehicles, such as commuting, visiting, support, and delivery traffic in and 

8 around the proposed GLE Facility. These activities would generate air emissions of criteria 

9 pollutants (sulfur dioxide [SO2], nitrogen oxides [NOx], carbon monoxide [CO], particulate matter 

10 equal to or smaller than 10 micrometers [PM10] and particulate matter equal to or smaller than 

11 2.5 micrometers [PM2.5]), volatile organic compounds (VOCs), greenhouse gases (GHGs) 

12 (e.g., carbon dioxide [CO2]), and a small amount of hazardous air pollutants (HAPs) 

13 (e.g., benzene). VOCs are organic compounds that easily volatize or evaporate and can break 

14 down through photochemical reactions, contributing to air pollution, especially the generation of 

15 tropospheric ozone (O3). GHGs are gases that absorb outgoing infrared radiation emitted by 

16 the earth’s surface and trap heat in the atmosphere. HAPS are a group of 188 chemicals 

17 identified in the 1990 Clean Air Act Amendments, exposure to which can cause or contribute to 

18 cancer, birth defects, genetic damage, and other adverse health effects. Small quantities of 

19 additional VOC and HAP emissions would be released from the refueling and onsite 

20 maintenance of the off-road construction equipment, and from painting and other construction21 finishing activities. 

22 

23 Fugitive Dust: No detailed information on the time schedule, heavy equipment usage, and 

24 activity levels is available at this time. General area-wide emission factors based on the area 

25 and duration of disturbances were used. As shown in Tables E-2 and E-3, it is assumed that an 

26 uncontrolled emission factor of 0.94 metric tons per hectare-month (0.42 tons per acre-month) 

27 was applied to large-scale earthmoving activities, such as road construction and site 

28 preparation, while that of 0.25 metric tons per hectare-month (0.11 tons per acre-month) was 

29 applied to construction activities, such as erection of building structures and equipment 

30 installation (MRI, 1996). It is also assumed that 10 percent of PM10 emissions of fugitive dust is 

31 PM2.5 (Countess Environmental, 2006). For this analysis, an emission control efficiency of 

32 74 percent is assumed during the early construction phase. 

33 

34 Off-Road Construction Equipment: Composite emission factor for off-road construction 

35 equipment was estimated based on assumed mix of heavy equipment types and pieces of 

36 heavy equipment, load factor, and equipment-specific emission factors (EPA, 2004a,b). 

37 

38 Onroad Motor Vehicles: Commuting, visitor, support, and delivery traffic, ranging from small 

39 passenger cars to heavy-duty tractor trailers, would travel within and to and from the Wilmington 

40 Site. Emission factors by vehicle classification are estimated using the EPA’s MOBILE6.2 

41 mobile source emission factor model (EPA, 2003). 

42 

43 The GLE Facility operation generates a small amount of criteria pollutants and HAP emissions 

44 because of no combustion being involved. During facility operation, primary emission sources 

45 include minimal PM emissions from the GLE Facility building stack, PM emissions as drift from 

46 mechanical-draft cooling towers, auxiliary diesel generator units operating on an intermittent 

47 basis, onsite transfer vehicles (OSTVs) for moving cylinders to and from the cylinder pads, and 

48 heavy-duty trucks transferring product cylinders to the onsite Fuel Manufacturing Operations 
E-5 

1 (FMO) facility. During the facility operation phase, commuting, visiting, support, and local 

2 delivery traffic in and around the proposed GLE Facility are also emission sources. To support 

3 facility operation, regional deliveries would be anticipated: UF6 feedstock coming to the GLE 

4 Facility and UF6 product, depleted UF6 tails, empty 48Y cylinders, and low-level radioactive 

5 waste (LLRW) going out from the proposed GLE Facility. But these emissions would have 

6 minimal impacts on the surrounding area of the proposed GLE Facility because they are 

7 released along the long roadways. Although criteria pollutants and VOCs from regional 

8 deliveries are not included, greenhouse gas emissions (such as CO2) are included in the 

9 analysis. Overall, non-particulate matter (PM) emissions are comparable to but PM emissions 

10 are far lower than those for access road construction and land clearing as well as building 

11 construction. 

12 

13 E.2 Air Quality Modeling Analysis 

14 

15 Air dispersion modeling was performed to estimate ambient air concentration increments at the 

16 site boundary and offsite receptors as a result of air emissions during access road construction 

17 and land clearing as well as building construction at the proposed GLE Facility. Air quality 

18 modeling was performed for criteria air pollutants including SO2, NO2, CO, and PM (PM10 and 

19 PM2.5). Air quality modeling for ozone and lead was not performed. Ozone is of a regional 

20 concern and is formed by highly complex and nonlinear reactions that involve VOC and nitrogen 

21 oxide (NOx) precursors. Air dispersion modeling for ozone requires intensive meteorological 

22 and emissions data processing and computing resources. However, emissions from 

23 construction and operation at the proposed GLE Facility would not be high enough to influence 

24 regional ozone levels, and thus, no ozone modeling is warranted. Air quality modeling for lead 

25 (Pb) was not performed because its emissions and associated ambient impacts would be 

26 minimal due to the phasing out of leaded gasoline in the 1970s. The following sections include 

27 brief descriptions of the air dispersion model, meteorological data processing, receptor data, 

28 and modeling assumptions. 

29 

30 E.2.1 Selection of Air Dispersion Model 

31 

32 For this modeling analysis, the latest version of the AMS/EPA Regulatory MODel (AERMOD) 

33 modeling system (version 09292) (EPA, 2009) was used, which is the U.S. Environmental 

34 Protection Agency’s (EPA’s) preferred or recommended model for a wide range of regulatory 

35 applications. AERMOD is a refined, steady-state plume model that incorporates air dispersion 

36 based on state-of-the-art planetary boundary layer turbulence structure and scaling concepts, 

37 and building wake effects and plume downwash for point sources. It includes treatment of both 

38 surface and elevated sources (including multiple point, area, and volume sources), and both 

39 simple and complex terrain, and can be applied to rural and urban areas. The model uses 

40 hourly sequential preprocessed meteorological data to estimate not only airborne 

41 concentrations, but also dry and wet deposition fluxes for both particulate and gaseous 

42 emissions of nonreactive pollutants for averaging times, ranging from one hour to the period 

43 (one year or multiple years). 

44 

45 AERMOD is a modeling system that contains three major separate components: 

46 

47 • AERMET – meteorological data preprocessor that incorporates air dispersion based on 

48 planetary boundary layer turbulence structure and scaling concepts; 
E-6 

1 

2 • AERMAP – terrain data preprocessor that incorporates complex terrain using digital 

3 elevation data; and 

4 

5 • AERMOD – air dispersion model that estimates airborne concentrations and dry/wet 

6 deposition fluxes. 

7 

8 In addition, supporting programs for the AERMOD modeling system include: 

9 

10 • AERSURFACE – surface characteristics preprocessor that estimates surface characteristics 

11 including surface roughness length, albedo, and Bowen ratio for input to the AERMET; 

12 

13 • BPIPPRIME – a tool that calculates building parameters to account for building downwash 

14 effects of point source(s) for input to the AERMOD; and 

15 

16 • AERSCREEN – a screening model for AERMOD that produces estimates of regulatory 

17 design concentrations without the need for meteorological data and is designed to produce 

18 more conservative results than AERMOD. EPA is currently working on a beta version of the 

19 code. 

20 

21 E.2.2 Determination of Surface Characteristics 

22 

23 For use in the computation of the fluxes and stability of the atmosphere, meteorological data 

24 preprocessor AERMET needs surface characteristics parameters, including surface roughness 

25 length, albedo, and the Bowen ratio. The surface roughness length is a measure of 

26 irregularities at the surface, including vegetation, topography, and structures, which influence 

27 the near-surface wind stress. Surface roughness length plays the most crucial role in 

28 determining the magnitude of mechanical turbulence and the stability of the boundary layer. 

29 The typical values range from 0.001 meter (0.003 feet) over calm water surfaces and 1 meter 

30 (3.3 feet) or more over a forest or urban area. Albedo is the fraction of the amount of radiation 

31 reflected from the surface to the amount of radiation incident on the surface. Typical values 

32 range from 0.1 for thick deciduous forests to 0.9 for fresh snow. The Bowen ratio, indicator of 

33 surface moisture, is the ratio of sensible heat flux to the latent heat flux. The Bowen ratio is 

34 used to determine the planetary boundary layer parameters for convective conditions. The 

35 typical values range from 0.1 over water to 10 over desert at midday. 

36 

37 Surface characteristics should represent the meteorological data at the application site. 

38 However, such data may not be available and data from a nearby representative measurement

39 site must be used. In particular, the Wilmington/Hanover County Airport is exposed to open 

40 areas, while the proposed GLE Facility is surrounded by wooded area. Although the Wilmington 

41 Airport is only about 8 kilometers (5 miles) from the proposed GLE Facility, its meteorological 

42 parameters and surface characteristics are not representative of those for the proposed GLE 

43 Facility. In this case, the AERMOD Implementation Guide (EPA, 2009) recommends finding 

44 another nearby measurement site representative of both meteorological parameters and surface 

45 characteristics of the site of interest. Failing that, it is likely that site-specific meteorological data 

46 will be required. 

47 
E-7 

1 The AERSURFACE tool has been developed to aid users in obtaining realistic and reproducible 

2 surface characteristic values, which is, in turn, input to the meteorological data preprocessor 

3 AERMET. AERSURFACE requires land cover data from the U.S. Geological Survey (USGS) 

4 National Land Cover Data 1992 archives (NLCD92) (USGS, 2009). These data are used to 

5 determine the land cover types around the user-defined location. 

6 

7 The Horticultural Crops Research Station (CAST) in Castle Hayne operated by the State 

8 Climate Office of North Carolina (SCONC), which is located less than 3 kilometers (2 miles) 

9 directly east of the proposed GLE Facility, was selected for the AERSURFACE analysis. The 

10 elevation and terrain features (mostly flat) surrounding the CAST station are comparable to 

11 those of the proposed GLE Facility. Surface characteristics for the CAST station are 

12 representative of those for the proposed GLE Facility, once trees are removed for construction. 

13 Accordingly, the CAST station is considered adequately representative of the proposed GLE 

14 Facility and was used as the source of onsite meteorological data for this assessment. 

15 

16 Seasonal surface characteristics were determined for each of twelve 30-degree sectors. A 

17 default domain defined by 10 kilometers by 10 kilometers (6 miles by 6 miles) centered on the 

18 measurement site is used for determination of albedo and Bowen ratio. A radius of 1 kilometer 

19 (0.6 mile) from the measurement site was used to determine the surface roughness values per 

20 recommendation in EPA’s AERMOD Implementation Guide (EPA, 2009). To determine the 

21 Bowen ratio, surface moisture conditions around the site are needed to characterize the area 

22 relative to climate normals. Surface moisture conditions for Bowen ratio were determined by 

23 year, based on the 30-year (1971–2000) annual precipitation record at the Wilmington Airport 

24 (NCDC, 2009a; NCDC 2009b). If annual precipitation for the year of interest is within the lower30th percentile or the upper-30th 25 percentile of the 30-year record, dry or wet conditions, 

26 respectively, are assigned. Otherwise, average conditions were assigned. For this analysis, 

27 wet conditions were selected for 2005 and 2006, dry conditions for 2007, and average 

28 conditions for 2008. Additional user inputs to affect surface characteristic values include 

29 whether the site is an airport or an arid region, and the amount of continuous snow cover 

30 through most of the winter. 

31 

32 E.2.3 Meteorological Data Processing 

33 

34 The meteorological data preprocessor (AERMET) requires three types of data: National 

35 Weather Service (NWS) hourly surface observations; NWS twice-daily upper air soundings; and 

36 data collected from an onsite measurement tool such as an instrumented tower, if available. No 

37 onsite meteorological data are available, so hourly surface and twice-daily upper sounding data 

38 from the nearest CAST station and NWS stations were used for the analysis. As discussed, the 

39 CAST station represents onsite data for this assessment. Meteorological data at the CAST 

40 station have been collected at 10-meter (33-foot) height, which include wind speed and 

41 direction, ambient temperature, standard deviation of horizontal wind direction (missing from the 

42 second half of 2006 to 2008), and solar radiation. Site-specific surface characteristics influence 

43 plume dispersion in the boundary layer, associated parameters for which are typically derived 

44 using the surface measurement data from a nearby airport. Hourly surface meteorological data 

45 at the Wilmington Airport, which is located about 8 kilometers (5 miles) southeast of the 

46 proposed GLE Facility, are used to supplement the missing onsite data and to estimate 

47 boundary layer parameters (NCDC, 2009c). Twice-daily upper sounding data from Charleston, 
E-8 

S.C.,2 1 which is located about 249 kilometers (155 miles) southwest of the GLE Facility, are used 

2 for estimating the heights of convective boundary layer (NOAA, 2009). Using the AERMET 

preprocessor, the most recent four years of meteorological data (2005 to 2008)3 3 were 

4 processed for input to the AERMOD model. Table E-14 presents detailed information on 

5 surface, upper air, and onsite meteorological stations, data file formats, anemometer heights, 

6 and distance and direction from the proposed GLE Facility. 

7 

8 Figure E-1 presents a wind rose at 10-meter (33-foot) level of CAST station on 2005–2008 wind 

9 data (Frazier, 2009). The average annual wind speed is about 2.1 meters per second (4.7 miles 

10 per hour) and relatively higher calm winds are recorded about one-fourth of the time. The 

11 prevailing wind directions are from the southwest and northeast (about 8.7 percent of the time 

12 each), and secondarily from west–southwest (8.2 percent). Wind speed tends to be relatively 

13 higher in spring and lower in summer. The reverse is true for calm winds. In general, 

14 southwesterly winds prevail in spring and summer, while northerly winds prevail in fall and 

winter. The southwesterly winds are strongly influenced by general synoptic-scale4 15 wind 

16 patterns of the Bermuda High. In contrast, northerly winds reflect the influences of penetrating 

17 polar air masses and changes in global circulation (Robinson, 2005). Compared to wind 

18 directions at the Wilmington Airport (see Figure 3-5), prevailing wind directions at the CAST 

19 station are a little different, but general wind patterns are similar. Average wind speed at the 

20 CAST station is about two-thirds of that at the Wilmington Airport, even though the two stations 

21 are only 6 kilometers (4 miles) apart. This can be explained by differences in surface 

22 roughness, because the CAST site is surrounded by tall trees, but the Airport is surrounded by 

23 open areas. 

24 

25 E.2.4 Terrain Data Processing 

26 

27 Areas are relatively flat within a 50-kilometer (31-mile) radius from the proposed GLE Facility, 

28 with approximately 20-meter (66-foot) variances in elevation, and no significant topographic 

29 features. For the modeling analysis, it is assumed that the terrain is flat, and thus, no AERMAP 

30 processing has been performed. 

31 

 

2

 An upper air station at Morehead City, North Carolina is about 113 kilometers (70 miles) northeast of 

the proposed GLE Facility, closer than Charleston, South Carolina. However, the former is located in 

the barrier island and thus, is more affected by the marine boundary layer of Atlantic Ocean than 

Charleston and the proposed GLE Facility, which are more than 16 kilometers (10 miles) from the 

Atlantic Ocean. Accordingly, the Charleston was chosen for the analysis, considering the similarity of 

distance and orientation to the Atlantic Ocean. 

3

 Per EPA’s Modeling Guidance (40 CFR Part 51 Appendix W), most-recent consecutive five years of 

meteorological data representative of the site of interest should be used when estimating 

concentrations with an air quality model. However, four years of data (2005–2008) were used for this 

analysis. A problem in wind direction measurements was found at the Horticultural Crops Research 

Station in 2004 and wind sensor was replaced in January, 2005. Wind roses for 2001–2004 at the 

station indicated that wind patterns are totally off from the general patterns in the area and thus, wind 

data during this period are not useable. 

4

 The scale of high- or low-pressure systems in the lower atmosphere seen on weather maps, in which 

the typical horizontal dimension is on the order of 1000 kilometers (621 miles) or more. 
E-9 

1 E.2.5 Receptor Location Data 

2 

3 For the analysis, a modeling domain of 50-kilometer (31-mile) radius centered on the proposed 

4 GLE Facility was developed. In doing so, two sets of receptor networks were developed: 

5 (1) fenceline receptors and (2) regularly spaced polar receptor grids. For the analysis, discrete 

6 receptors at Wilmington Site boundaries are set densely (few tens meters) at northern 

7 boundaries, where maximum concentration are anticipated, and sparsely (few hundred meters) 

8 at other site boundaries. Regularly spaced polar receptor grids were placed at 31 rings outward 

9 ranging from 50 meters (164 feet) to 50 kilometers (31 miles) along sixteen 22.5-degree radials. 

10 A total of 557 receptors consists of 61 fenceline receptors and 496 regularly spaced polar 

11 receptor grids. Although air quality impact analysis was performed at site boundaries and 

12 beyond, irrespective of human residence, modeling calculations for onsite receptors were made 

13 to provide maximum onsite concentrations for worker health hazards and to analyze 

14 concentration contour patterns. 

15 

16 E.2.6 Modeling Assumptions 

17 

18 The following assumptions are for air quality modeling and modeling result interpretations: 

19 

20 • Construction activities would occur seven days per week (359 days per year) for nine hours 

21 per day, from 7 a.m. to 4 p.m, while operation activities would occur seven days per week 

22 (365 days per year) for 24 hours per day. 

23 

24 • Dry and wet deposition mechanisms are uncertain and are not included in EPA’s regulatory 

25 option, and thus, it is not recommended to use them for typical applications except in special 

26 cases (e.g., deposition impacts on vegetation). Accordingly, no dry and wet depositions for 

27 construction-related PM modeling were assumed (i.e., all PMs are airborne as a 

28 conservatism). 

29 

30 • During site preparation and construction phases, fugitive dust emissions resulting from soil 

31 disturbances by heavy construction equipment or vehicles are typically released at the top of 

32 the wheel/tire, with initial dispersion corresponding to the volume size of the equipment or 

33 truck. Engine exhaust emissions from heavy construction equipment or vehicles are 

34 released at some height along with plume rise induced by momentum and buoyancy. 

35 However, for this analysis, it is conservatively assumed that emissions are released at the 

36 ground level without vertical dimension. 

37 

38 • For purposes of modeling demonstrations of compliance with the National Ambient Air 

39 Quality Standards (NAAQS), the following modeled concentrations were used for 

40 comparison with the NAAQS as recommended by EPA. The highest of the second-highest 

41 modeled concentrations over four years were presented for 3-hour and 24-hour SO2, and 

42 1-hour and 8-hour CO. The highest of the annual averages over four years were presented 

for annual average for SO2 and NO2. For PM10, high-5th 43 -high over four years (2005–2008) 

was presented. For PM2.5, the highest of the four-year average of the high-8th 44 -high 

45 concentration at each receptor was presented. The highest of four-year averaged annual 

46 means across the receptors for PM2.5 were presented. 

47 
E-10 

1 • Air dispersion modeling results, which are concentration increments over the background, 

2 and total concentrations are presented. To obtain total concentrations for comparison with 

3 applicable air quality standards, these modeled concentration increments were added to 

4 measured background concentrations representative of the Wilmington Site (Buckler, 2009). 

5 Detailed discussion regarding modeling results can be found in Section 4.2.4 of this draft 

6 EIS. 

7 

8 REFERENCES 

9 

10 (Buckler, 2009) Buckler, C. Personal communication from C. Buckler (North Carolina 

11 Department of Environment and Natural Resources) to Y.-S. Chang (Argonne National 

12 Laboratory). September 4. 

13 

14 (Countess Environmental, 2006) Countess Environmental. “WRAP Fugitive Dust Handbook.” 

15 Prepared by Countess Environmental for Westerns Governors’ Association. September 7. 

16 <http://www.wrapair.org/forums/dejf/fdh/content/FDHandbook_Rev_06.pdf> (Accessed 

17 August 24, 2009). 

18 

19 (EPA, 1995) U.S. Environmental Protection Agency. Compilation of Air Pollutant 

20 Emission Factors, Volume 1: Stationary Point and Area Sources, AP-42, Fifth Edition. 

21 <http://www.epa.gov/ttn/chief/ap42> (Accessed January 19, 2010). 

22 

23 (EPA, 2003) U.S. Environmental Protection Agency. “User’s Guide to MOBILE6.1 and 

24 MOBILE6.2, Mobile Source Emission Factor Model.” EPA420-R-03-010. August. 

25 <http://www.epa.gov/OMS/models/mobile6/420r03010.pdf> (Accessed December 14, 2009). 

26 

27 (EPA, 2004a) U.S. Environmental Protection Agency. “Median Life, Annual Activity, Load 

28 Factor Values for Nonroad Engine Emissions Modeling.” EPA420-P-04-005. April. 

29 <http://www.epa.gov/OMS/models/nonrdmdl/nonrdmdl2004/420p04005.pdf> (Accessed 

30 February 6, 2010). 

31 
E-11 

1 (EPA, 2004b) U.S. Environmental Protection Agency. “Exhaust and Crankcase Emission 

2 Factors for Nonroad Engine Modeling—Compression-Ignition.” EPA420-P-04-009. April. 

3 <http://www.epa.gov/oms/models/nonrdmdl/nonrdmdl2004/420p04009.pdf> (Accessed 

4 December 14, 2009). 

5 

6 (EPA, 2009) U.S. Environmental Protection Agency. “Preferred/Recommended Models – 

7 AERMOD Modeling System.” <http://www.epa.gov/scram001/dispersion_prefrec.htm> 

8 (Accessed November 8, 2009). 

9 

10 (Frazier, 2009) Frazier, A. Personal communication from A. Frazier (State Climate Office of 

11 North Carolina) to Y.-S. Chang (Argonne National Laboratory). October 9. 

12 

13 (MRI, 1996) Midwest Research Institute. “Improvement of Specific Emission Factors (BACM 

14 Project No. 1), Final Report.” Prepared for South Coast AQMD. March 29. 

15 

16 (NCDC, 2009a) National Climatic Data Center. “1999 Local Climatological Data Annual 

17 Summary with Comparative Data, Wilmington North Carolina (KILM).” <http://www1.ncdc. 

18 noaa.gov/pub/orders/222E2A57-4057-4CC7-5E66-0DD2B2C7BE64.PDF> (Accessed August 1, 

19 2009). 

20 

21 (NCDC, 2009b) National Climatic Data Center. “2008 Local Climatological Data Annual 

22 Summary with Comparative Data, Wilmington North Carolina (KILM).” <http://www1.ncdc. 

23 noaa.gov/pub/orders/B9C3E52A-D4FF-99A0-FC44-BBAC3F4939A1.PDF> (Accessed 

24 August 1, 2009). 

25 

26 (NCDC, 2009c) National Climatic Data Center. “Integrated Surface Hourly Data.” 

27 <ftp://ftp3.ncdc.noaa.gov/pub/data/noaa/> (Accessed August 1, 2009). 

28 

29 (NOAA, 2009) National Oceanic and Atmospheric Administration. “NOAA/ESRL Radiosonde 

30 Database Access.” <http://esrl.noaa.gov/raobs/> (Accessed August 1, 2009). 

31 

32 (NCDENR, 2000) North Carolina Department of Environment and Natural Resources, Division 

33 of Air Quality. “Large Diesel and All Dual-Fuel Engines Emissions Calculator Spreadsheet 

34 (LGD2009 Revision A).” March 27, 2000. <http://daq.state.nc.us/cgi-bin/permit_forms.cgi?id= 

35 intlarge&type=sheets> (Accessed January 19, 2010). 

36 

37 (Robinson, 2005) Robinson, P.J. North Carolina Weather & Climate. The University of North 

38 Carolina Press. Chapel Hill, N.C. 

39 

40 (USGS, 2009) U.S. Geological Survey. “The National Map Seamless Server.” 

41 <http://seamless.usgs.gov/index.php> (Accessed October 11, 2009). 

42 
E-12 

Table E-1 General Assumptions for Estimating Air Emissions Associated with Construc

and Operation of the Proposed GLE Facility 

Phase Activity 

Schedule 

Assumed 

in 

Analysisa

Current 

Schedule 

Workdays 

per year 

Work 

Schedule 

Area 

Disturbed 

(acres) 

A

W

Early Construction  Road Construction Onsite access road 

construction 

April 

2011d

April 

2011d

30 8.65f

 Land Clearing Preparation of site for 

erection of buildings and structures 

May-Dec 

2011d

May–Dec 

2011d

240e

7 days/week 

7 a.m.–4 p.m. 

148.7 

Building Construction Erection of main GLE 

Facility building and ancillary buildings and structures 

2012–2013 Mid-2012 

through 

2013 

360g 7 days/week 

7 a.m.–4 p.m. 

117.4 

Start-up and Final Construction 

Concurrent indoor construction activities with staged testing and start-up of process units as completed 

2013–2017 2013–2017 365h 7 days/week 

24 hours/day 

NAi 

Operation Full capacity fuel 

enrichment operations 

2018–2050 2018–2051 365h 7 days/week 

24 hours/day 

NA 
E-13 

a As discussed in the introduction of this Appendix, the Air Quality analysis was based on a slightly different schedule than currently is expected. T

differences are expected to cause slight changes in the air quality analysis, but are not expected to change any of the impacts conclusions. The u

be reflected in the Final EIS.

b Each trip is a one-way trip, including onsite road from the proposed GLE Facility to the entrance on Castle Hayne Road (2.64 km [1.64 mi]) and o

[10 mi] for automobiles and 161 km [100 mi] for heavy-duty trucks). 

c Average daily traffic consists of gasoline engine automobiles of 90 percent and heavy-duty diesel trucks of 10 percent. d As discussed in Section 2.1.5, the schedule for preconstruction activities, including road construction and land clearing, is uncertain. The chang

licensing date discussed in the introduction to Appendix E is not expected to affect the schedule for preconstruction activities. 

e No work schedule on five holidays (Memorial Day, Independence Day, Labor Day, Thanksgiving Day, and Christmas Day). f Total length of the onsite access road to the proposed GLE Facility (2.64 km [1.64 mi]) consists of existing paved road (0.72 km [0.45 mi]) and un

[1.19 mi]). Road construction would occur on unpaved road segment only with an assumed 18.3-meter (60-foot) width. 

g No work schedule on six holidays (New Year’s Day, Memorial Day, Independence Day, Labor Day, Thanksgiving Day, and Christmas Day). h 366 for leap years. i NA = not applicable. 
E-14 

Table E-2 Input Parameters Used for Estimating Air Emissions at the Proposed GLE F

Road Construction Followed by Land Clearing 

Air Emission Source Parameter Parameter Value Refere

PM10 uncontrolled emission 

factor 

0.42 ton/acre/month MRI, 1996 

PM2.5 to PM10 ratio 0.1 Countess Enviro

(Section 3.3.1) 

Fugitive dust emissions from soil disturbances at construction sites 

Dust control efficiency 74 percent Countess Enviro

(Section 3.6); 2.

Unpaved road segment 1.19 miles See note d in TaSurface silt content 18.9 percent Weighted-avera

soils on onsite rof road for Murv(0.6% silt) and 0Pantego loam s

Average vehicle weight 9700 lb (4.85 ton) Weighted avera

90% daily trips f3000 lb and 10% duty diesel truck

Average vehicle speed 15 miles per hour Assumed as pa

control mitigatio

PM10 uncontrolled emission 

factor 

2.81 lb/VMT EPA, 1995 (Sec

PM2.5 uncontrolled emission 

factor 

0.28 lb/VMT EPA, 1995 (Sec

Fugitive dust emissions from vehicular travel on unpaved onsite access road 

Dust control efficiency 55 percent Countess Enviro

(Section 6.5); w
E-15 

Table E-2 Input Parameters Used for Estimating Air Emissions at the Proposed GLE F

Road Construction Followed by Land Clearing (Cont.) 

Air Emission Source Parameter Parameter Value Refere

Equipment 

Type (Number) 

Engine 

Horsepower 

(hp) 

Load 

Factor 

Bulldozer (4) 175 0.59 Loader (4) 175 0.59 Grader (2) 175 0.59 Compactor/Roller (2) 120 0.59 Excavator (1) 175 0.59 Water truck (1) 175 0.59 

Engine exhaust emissions from offroad dieselpowered heavy construction equipment 

Average equipment mix 

Paver (1) 120 0.59 

Assumed mix of equipment Load factor from 

Pollutant lb/hr 

PM10 1.48 

PM2.5 1.44 

NOx 8.16 

SO2 0.02 

VOC 0.62 

 Site-specific composite 

emission factors 

CO 4.75 

EPA, 2004b Weighted averafactor for each eeach equipment
E-16 

Table E-2 Input Parameters Used for Estimating Air Emissions at the Proposed GLE F

Road Construction Followed by Land Clearing (Cont.) 

Air Emission Source Parameter Parameter Value Refere

PM2.5 to PM10 ratio 0.97 EPA, 2004b 

Pollutant g/mi 

PM10 0.025 

PM2.5 0.024 

NOx 0.549 

SO2 0.007 

VOC 0.656 

Automobile emission factors 

CO 13.080 

Pollutant g/mi 

PM10 0.136 

PM2.5 0.132 

NOx 6.360 

SO2 0.013 

VOC 0.381 

Engine exhaust emissions from automobile and truck traffic 

Truck emission factors 

CO 1.627 

EPA, 2003 Estimated using  Calendar year Minimum/max 2.1°C/13.5° (January)  Fuel RVP: 9.0  in attainme Carolina) Used default va parameters anUse light-duty gemission factor heavy-duty diestrucks 
E-17 

Table E-3 Input Parameters Used for Estimating Air Emissions at the Proposed GLE F

Building Construction 

Air Emission Source Parameter Parameter Value Refere

PM10 uncontrolled emission 

factor 

Fugitive dust emissions 0.11 ton/acre/month MRI, 1996 from soil disturbances at construction sites PM2.5 to PM10 ratio 0.1 Countess Enviro

(Section 3.3.1) 

Equipment 

Type (Number) 

Engine 

Horsepower 

(hp) 

Load 

Factor 

Crane (2) 175 0.43 Tractor/backhoe (4) 100 0.21 Forklift (4) 75 0.59 Aerial lift (4) 75 0.21 

Engine exhaust emissions from offroad dieselpowered heavy construction equipment 

Average equipment mix 

Air compressor (4) 75 0.43 

Assumed mix of equipment Load factor from 

Pollutant lb/hr 

PM10 0.75 

PM2.5 0.73 

NOx 4.01 

SO2 0.01 

VOC 0.29 

 Site-specific composite 

emission factors 

CO 4.47 

EPA, 2004b Weighted averafactor for each eeach equipmen
E-18 

Table E-3 Input Parameters Used for Estimating Air Emissions at the Proposed GLE F

Building Construction (Cont.) 

Air Emission Source Parameter Parameter Value Refere

PM2.5 to PM10 ratio 0.97 EPA, 2004b 

Pollutant g/mi 

PM10 0.025 

PM2.5 0.024 

NOx 0.498 SO2 0.007 

VOC 0.597 

Automobile emission factors 

CO 12.590 

Pollutant g/mi 

PM10 0.136 

PM2.5 0.132 

NOx 5.481 SO2 0.013 

VOC 0.352 

Engine exhaust emissions from automobile and truck traffic 

Truck emission factors 

CO 1.418 

EPA, 2003 Estimated using  Calendar yea Minimum/max 2.1°C/13.5°

 (January)  Fuel RVP: 9.0  In attainmen Carolina)  Used default v parameters Use light-duty gemission factor heavy-duty diestrucks 
E-19 

Table E-4 Input Parameters Used for Estimating Air Emissions at the Proposed GLE Fac

Start-up and Final Construction 

Air Emission Source Parameter Parameter Value Reference and/o

Fugitive dust emissions from soil disturbances 

Assumed no emissions because activities would occur mostly inside buildings 

GLE Preliminary design informaNovember 2009 

Drift PM emissions from mechanical-draft cooling towers Engine exhaust emissions from auxiliary diesel generator units Engine exhaust emissions from onsite transfer vehicles (OSTVs) used for moving UF6 cylinders to 

and from cylinder pads 

Engine exhaust emissions from heavy-duty truck used for transfer of product cylinders to onsite Fuel Manufacturing Operations (FMO) facility 

See parameter and parameter data for the operation phase in the below 

Production will be incrementally production over the 5-year perio

(final construction) phase. Conassumed the same parameter voperation phase. 
E-20 

Table E-4 Input Parameters Used for Estimating Air Emissions at the Proposed GLE Fac

Start-up and Final Construction (Cont.) 

Air Emission Source Parameter Parameter Value Reference and/o

PM2.5 to PM10 ratio 0.97 EPA, 2004b 

Pollutant g/mi 

PM10 0.025 

PM2.5 0.024 

NOx 0.379 

SO2 0.007 

VOC 0.475 

Automobile emission factors 

CO 11.640 

Pollutant g/mi 

PM10 0.136 

PM2.5 0.132 

NOx 3.507 

SO2 0.013 

VOC 0.304 

Engine exhaust emissions from automobile and truck traffic 

Truck emission factors 

CO 0.840 

EPA, 2003 Estimated using MOBILE6.2 wi Calendar year: 2015  Minimum/maximum temperat 2.1°C/13.5°C (35.8°F/56.3°

 Fuel RVP: 9.0 (maximum RV attainment areas in North C Used default values for other  parameters and assumptioUse light-duty gasoline vehicle factor for automobiles and heavvehicle (HDDV) for trucks. 
E-21 

Table E-5 Input Parameters Used for Estimating Air Emissions at the Proposed GLE Fac

Operations

Air Emission Source Parameter Parameter Value Reference and/o

Number of cooling towers 2 Number of cells per cooling tower 8 Water flow rate per cell 22,500 gal/hr 

GLE Preliminary design informaNovember 2009 

Total dissolved solids (TDS) concentration 

858 ppm Based on cooling towers opera

manufacturing facilities at the W

Total liquid drift factor 1.7 lb/1000 gal EPA, 1995 (induced draft coolin

Section 13.4, 1/95) 

PM10 emission factor per cell 0.0015 lb/1000 gal Calculated 

Drift PM emissions from mechanical-draft cooling towers 

PM2.5 to PM10 ratio 1 Assumed based on typical drift 

distribution for cooling towers 

Number of units 2 Engine rating 382 hp 

GLE Preliminary design informaNovember 2009 

Diesel fuel sulfur content 0.2 percent Annual operation 240 hours per year per unit 

Based on NCDAQ air permit coexisting emergency diesel gene

Wilmington Site 

Pollutant lb/hr 

PM10 0.27 

PM2.5 0.27 

NOx 5.0 

SO2 0.62 

VOC 0.25 

Engine exhaust emissions from auxiliary diesel generator units 

Emission factors 

CO 2.1 

NCDENR, 2000 Assume VOC is the non-methacompound (NMTOC) rate provispreadsheet 
E-22 

Table E-5 Input Parameters Used for Estimating Air Emissions at the Proposed GLE Fac

Operations (Cont.) 

Air Emission Source Parameter Parameter Value Reference and/o

Number of OSTVs 2 GLE Preliminary design informa

November 2009 

Engine rating 75 hp Assume based on engineering Operating hours per day 3 GLE Preliminary design informa

November 2009 

Pollutant g/hp-hr 

PM10 0.6496 

PM2.5 0.6301 

NOx 3.1450 

SO2 0.0049 

VOC 0.1980 

Engine exhaust emissions from onsite transfer vehicles (OSTVs) used for moving UF6 cylinders to 

and from cylinder pads 

Emission factors 

CO 4.1657 

EPA, 2004b 

Number of vehicles 1 Operating interval 1 round trip per week 

GLE Preliminary design informaNovember 2009 

Distance traveled 2 miles One-way distance between the 

Facility and FMO facility 

Engine exhaust emissions from heavy-duty diesel truck used for transfer of product cylinders to onsite Fuel Manufacturing Operations (FMO) facility Emission Factors See below 
E-23 

Table E-5 Input Parameters Used for Estimating Air Emissions at the Proposed GLE Fac

Operations (Cont.) 

Air Emission Source Parameter Parameter Value Reference and/o

PM2.5 to PM10 ratio 0.97 EPA, 2004b 

Pollutant g/mi 

PM10 0.025 

PM2.5 0.024 

NOx 0.300 

SO2 0.007 

VOC 0.403 

Automobile emission factors 

CO 11.060 

Pollutant g/mi 

PM10 0.136 

PM2.5 0.132 

NOx 2.272 

SO2 0.013 

VOC 0.279 

Engine exhaust emissions from automobile and truck traffic 

Truck emission factors 

CO 0.585 

EPA, 2003 Estimated using MOBILE6.2 wi Calendar year: 2018  Minimum/maximum temperat 2.1°C/13.5°C (35.8°F/56.3°

 Fuel RVP: 9.0 (maximum RV attainment areas in North C Used default values for other  parameters and assumptionUse light-duty gasoline vehicle factor for automobiles and heavvehicle (HDDV) for trucks. 
E-24 

Table E-6 Estimated Average Daily Criteria Air Pollutant and VOC Emissions at the Proposed G

During Road Construction and Land Clearing 

Average Daily Onsite Air Emissions Associated with Onsite Access Road Construction Activities 

 Average Daily Emissions (

Air Emission Source PM10 PM2.5 NOx SO2 

Fugitive dust emissions from onsite access road construction 63.0 6.30 NAa NA Engine exhaust emissions from offroad diesel-powered heavy construction equipment 13.4 13.0 73.5 0.14 Engine exhaust emissions from onsite gasoline engine automobile traffic 0.02 0.02 0.36 0.004 Engine exhaust emissions from onsite diesel engine truck traffic 0.01 0.01 0.46 0.001 TOTAL 76.4 19.3 74.3 0.14 Average Daily Onsite Air Emissions Associated with Land Clearing 

 Average Daily Emissions (

Air Emission Source PM10 PM2.5 NOx SO2 

Fugitive dust emissions from site preparation 1082.5 108.3 NA NA Fugitive dust emissions from construction vehicle traffic on unpaved onsite access road 

300.0 30.0 NA NA 

Engine exhaust emissions from offroad diesel-powered heavy construction equipment 13.4 13.0 73.5 0.14 Engine exhaust emissions from onsite gasoline engine automobile traffic 0.02 0.02 0.36 0.004 Engine exhaust emissions from onsite diesel engine truck traffic 0.01 0.01 0.46 0.001 TOTAL 1395.9 151.2 74.3 0.14 a NA = not applicable. 
E-25 

Table E-6 Estimated Average Daily Criteria Air Pollutant and VOC Emissions at the Proposed G

During Road Construction and Land Clearing (Cont.) 

Average Daily Offsite Air Emissions from Vehicle Traffic Traveling on Roadways to and from the Proposed GLE Facility 

with Road Construction and Land Clearing 

 Average Daily Emissions (

Air Emission Source PM10 PM2.5 NOx SO2 

Gasoline engine automobile traffic 0.10 0.10 2.17 0.03 Diesel engine truck traffic 0.60 0.58 27.9 0.06 TOTAL 0.70 0.68 30.1 0.08 
E-26 

Table E-7 Estimated Average Annual Criteria Air Pollutant and VOC Emissions at the Proposed 

During Road Construction and Land Clearing 

Average Annual Onsite Air Emissions Associated with Road Construction and Land Clearing 

Average Annual Emissions 

Air Emission Source PM10 PM2.5 NOx SO2 

Fugitive dust emissions from onsite access road construction 0.95 0.09 NAa NA Fugitive dust emissions from site preparation 129.9 13.0 NA NA Fugitive dust emissions from construction vehicle traffic on unpaved onsite access road 

36.0 3.60 NA NA 

Engine exhaust emissions from offroad diesel-powered heavy construction equipment for access road construction 

0.20 0.19 1.10 0.002 

Engine exhaust emissions from offroad diesel-powered heavy construction equipment for site preparation 

1.60 1.55 8.82 0.02 

Engine exhaust emissions from onsite gasoline engine automobile traffic 0.002 0.002 0.05 0.001 Engine exhaust emissions from onsite diesel engine truck traffic 0.001 0.001 0.06 0.0001 TOTAL 168.7 18.4 10.0 0.02 Average Annual Offsite Air Emissions from Vehicle Traffic Traveling on Roadways to and from the Proposed GLE Faciwith Road Construction and Land Clearing 

 Average Annual Emissions 

Air Emission Source PM10 PM2.5 NOx SO2 

Gasoline engine automobile traffic 0.01 0.01 0.29 0.004 Diesel engine truck traffic 0.08 0.08 3.77 0.01 TOTAL 0.09 0.09 4.07 0.01 a NA = not applicable.
E-27 

Table E-8 Estimated Average Daily Criteria Air Pollutant and VOC Emissions at the Proposed G

During Building Construction 

Average Daily Onsite Air Emissions Associated with Building Construction Activities 

 Average Daily Emissions (

Air Emission Source PM10 PM2.5 NOx SO2 

Fugitive dust emissions from proposed GLE Facility building construction activities 860.9 86.1 NAa NA Engine exhaust emissions from offroad construction equipment used for building construction 

6.77 6.56 36.1 0.06 

Engine exhaust emissions from onsite gasoline engine automobile traffic 0.12 0.11 2.31 0.03 Engine exhaust emissions from onsite diesel engine truck traffic 0.07 0.07 2.83 0.01 TOTAL 867.9 92.8 41.2 0.10 Average Daily Offsite Air Emissions from Vehicle Traffic Traveling on Roadways to and from the Proposed GLE Facility 

Building Construction Activities 

 Average Daily Emissions (

Air Emission Source PM10 PM2.5 NOx SO2 

Gasoline engine automobile traffic 0.71 0.69 14.1 0.19 Diesel engine truck traffic 4.28 4.15 172.4 0.41 TOTAL 4.99 4.84 186.5 0.60 a NA = not applicable.
E-28 

Table E-9 Estimated Average Annual Criteria Air Pollutant and VOC Emissions at the Proposed 

During Building Construction 

Average Daily Onsite Air Emissions Associated with Building Construction Activities 

Average Annual Emissions 

Air Emission Source PM10 PM2.5 NOx SO2 

Fugitive dust emissions from proposed GLE Facility building construction activities 154.5 15.5 NAa NA Engine exhaust emissions from offroad construction equipment used for building construction 

1.21 1.18 6.48 0.01 

Engine exhaust emissions from onsite gasoline engine automobile traffic 0.02 0.02 0.42 0.01 Engine exhaust emissions from onsite diesel engine truck traffic 0.01 0.01 0.51 0.001 TOTAL 155.8 16.7 7.40 0.02 Average Daily Offsite Air Emissions from Vehicle Traffic Traveling on Roadways to and from the Proposed GLE Facility 

Building Construction Activities 

 Average Annual Emissions 

Air Emission Source PM10 PM2.5 NOx SO2 

Gasoline engine automobile traffic 0.13 0.12 2.53 0.03 Diesel engine truck traffic 0.77 0.75 30.9 0.07 TOTAL 0.90 0.87 33.5 0.11 a NA = not applicable.
E-29 

Table E-10 Estimated Average Daily Criteria Air Pollutant and VOC Emissions at the Proposed 

During Start-up and Final Construction 

Average Daily Onsite Air Emissions Associated with Start-up and Final Construction Activities 

 Average Daily Emissions (lb

Air Emission Source PM10 PM2.5 NOx SO2 

Stationary source emissions from main GLE Facility operations building stack vent 

~0 ~0 0 0 

Stationary source emissions from mechanical-draft cooling towers 12.6 12.6 NAa NA Stationary source emissions from auxiliary diesel generator unit exhaust stacks 0.54 0.54 10.0 1.24 Engine exhaust emissions from onsite transfer vehicles (OSTVs) used for transfer of cylinders to and from the outdoor cylinder storage pads 

0.64 0.62 3.12 0.00 

Engine exhaust emissions from diesel engine truck used to transfer product cylinders to onsite Fuel Manufacturing Operations (FMO) facility 

0.001 0.001 0.03 0.0001 

Engine exhaust emissions from onsite gasoline engine automobile traffic 0.13 0.12 1.92 0.03 Engine exhaust emissions from onsite diesel engine truck traffic 0.08 0.07 1.98 0.01 TOTAL 14.0 14.0 17.0 1.29 Average Daily Offsite Air Emissions from Vehicle Traffic Traveling on Roadways to and from the Proposed GLE Facility 

Start-up and Final Construction Activities 

 Average Daily Emissions (lb

Air Emission Source PM10 PM2.5 NOx SO2 

Gasoline engine automobile traffic 0.77 0.75 11.7 0.21 Diesel engine truck traffic 4.67 4.53 120.5 0.45 TOTAL 5.45 5.28 132.2 0.66 a NA = not applicable.
E-30 

Table E-11 Estimated Average Annual Criteria Air Pollutant and VOC Emissions at the Proposed 

During Start-up and Final Construction 

Average Annual Onsite Air Emissions Associated with Start-up and Final Construction Activities 

 Average Annual Emissions 

Air Emission Source PM10 PM2.5 NOx SO2 

Stationary source emissions from main GLE Facility operations building stack vent ~0 ~0 0 0 Stationary source emissions from mechanical-draft cooling towers 2.3 2.3 NAa NA Stationary source emissions from auxiliary diesel generator unit exhaust stacks 0.06 0.06 1.20 0.15 Engine exhaust emissions from onsite transfer vehicles (OSTVs) used for transfer of cylinders to and from the outdoor cylinder storage pads 

0.12 0.11 0.57 0.001 

Engine exhaust emissions from diesel engine truck used to transfer product cylinders to onsite Fuel Manufacturing Operations (FMO) facility 

~0 ~0 ~0 ~0 

Engine exhaust emissions from onsite gasoline engine automobile traffic 0.02 0.02 0.35 0.01 Engine exhaust emissions from onsite diesel engine truck traffic 0.01 0.01 0.36 0.001 TOTAL 2.52 2.51 2.48 0.16 Average Daily Offsite Air Emissions from Vehicle Traffic Traveling on Roadways to and from the Proposed GLE Facility 

Start-up and Final Construction Activities 

 Average Annual Emissions 

Air Emission Source PM10 PM2.5 NOx SO2 

Gasoline engine automobile traffic 0.14 0.14 2.14 0.04 Diesel engine truck traffic 0.85 0.83 22.0 0.08 TOTAL 0.99 0.96 24.1 0.12 a NA = not applicable.
E-31 

Table E-12 Estimated Average Daily Criteria Air Pollutant and VOC Emissions at the Proposed 

During Operations 

Average Daily Onsite Air Emissions Associated with Operations 

 Average Daily Emissions (

Air Emission Source PM10 PM2.5 NOx SO2 

Stationary source emissions from main GLE Facility operations building stack vent ~0 ~0 0 0 Stationary source emissions from mechanical-draft cooling towers 12.6 12.6 NAa NA Stationary source emissions from auxiliary diesel generator unit exhaust stacks 0.54 0.54 10.0 1.24 Engine exhaust emissions from onsite transfer vehicles (OSTVs) used for transfer of cylinders to and from the outdoor cylinder storage pads 

0.64 0.62 3.12 0.00 

Engine exhaust emissions from diesel engine truck used to transfer product cylinders to onsite Fuel Manufacturing Operations (FMO) facility 

0.001 0.001 0.03 0.0001 

Engine exhaust emissions from onsite gasoline engine automobile traffic 0.06 0.06 0.72 0.02 Engine exhaust emissions from onsite diesel engine truck traffic 0.04 0.04 0.60 0.003 TOTAL 13.9 13.9 14.5 1.26 Average Daily Offsite Air Emissions from Vehicle Traffic Traveling on Roadways to and from the Proposed GLE Facility A

Operations 

 Average Daily Emissions (

Air Emission Source PM10 PM2.5 NOx SO2 

Gasoline engine automobile traffic 0.36 0.35 4.37 0.10 Diesel engine truck traffic 2.20 2.14 36.8 0.21 TOTAL 2.57 2.49 41.2 0.31 a NA = not applicable.
E-32 

Table E-13 Estimated Average Annual Criteria Air Pollutant and VOC Emissions at the Proposed 

During Operations 

Average Daily Onsite Air Emissions Associated with Operations 

 Average Annual Emissions 

Air Emission Source PM10 PM2.5 NOx SO2 

Stationary source emissions from main GLE Facility operations building stack vent ~0 ~0 0 0 Stationary source emissions from mechanical-draft cooling towers 2.30 2.30 NAa NA Stationary source emissions from auxiliary diesel generator unit exhaust stacks 0.06 0.06 1.20 0.15 Engine exhaust emissions from onsite transfer vehicles (OSTVs) used for transfer of cylinders to and from the outdoor cylinder storage pads 

0.12 0.11 0.57 0.001 

Engine exhaust emissions from diesel engine truck used to transfer product cylinders to onsite Fuel Manufacturing Operations (FMO) facility 

~0 ~0 ~0 ~0 

Engine exhaust emissions from onsite gasoline engine automobile 0.01 0.01 0.13 0.00 Engine exhaust emissions from onsite diesel engine truck traffic 0.01 0.01 0.11 0.001 TOTAL 2.50 2.50 2.01 0.15 Average Daily Offsite Air Emissions from Vehicle Traffic Traveling on Roadways to and from the Proposed GLE Facility 

Operations 

 Average Annual Emissions 

Air Emission Source PM10 PM2.5 NOx SO2 

Gasoline engine automobile traffic 0.07 0.06 0.80 0.02 Diesel engine truck traffic 0.40 0.39 6.71 0.04 TOTAL 0.47 0.45 7.51 0.06 a NA = not applicable.
E-33 

Table E-14 Meteorological Data Information Used for AERMET 

Station Name Station ID Location (lat/long) Elevation (meters) File Format Anemometer Height (meters) Distance & Direction from the Proposed GLE Facilitya 

Surface

Wilmington/ Hanover County Airport 

ILM 

USAF: 723013 

WBAN: 13748 

34.267N 

77.900W 

9 ISD 

(DS3505) 

10 5 miles southeast 

Upper AirCharleston, SC 

CHS 

WBAN: 13880 

WMO: 72208 

32.90N 

80.03W 

15 FSL NA 155 miles southwest 

Onsite

Horticultural Crops Research Station 

CAST 34.321N 

77.916W 

13 NA 10 2 miles east 

thre

a Longitude, latitude, and elevation for the center of the proposed GLE Facility are: 34.335N, 77.947W, and 7 meters. b NA = not applicable. 

Sources: Frazier, 2009; NCDC, 2009c; NOAA, 2009. 
E-34 

Figure E-1 Wind Rose (10-meter [33-foot] Level) for the Horticultural Crops Research 

Station (CAST) in Castle Hayne, North Carolina, 2005–2008 (Frazier, 2009) 
F-1 

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14 APPENDIX F 

15 SOCIOECONOMIC ANALYSIS METHODS 

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1 APPENDIX F 

2 SOCIOECONOMIC ANALYSIS METHODS 

3 

4 This appendix describes the methods used to estimate the socioeconomic impacts of 

5 preconstruction and construction, operations, and decommissioning of the proposed General 

6 Electric (GE)-Hitachi Global Laser Enrichment LLC (GLE) Facility. Impacts are evaluated for 

7 the area in which the majority of the proposed GLE Facility permanent employees are expected 

8 to live and spend their wages and salaries. This area, referred to as the region of influence 

9 (ROI) in this appendix, includes New Hanover County, Brunswick County, and Pender County. 

10 The ROI corresponds to the Wilmington Metropolitan Statistical Area (MSA), which is expected 

11 to be the primary source of labor for each phase of the proposed GLE Facility (GLE, 2008).. 

12 

13 The socioeconomic analysis was divided into four main areas of impact: (1) site employment 

14 data during preconstruction and construction, start-up, operations, and decommissioning were 

15 used to estimate direct and indirect economic impacts; (2) the impact on direct State and local 

16 tax revenues was considered; (3) the number of in-migrating workers required to fill onsite job 

17 positions during each project phase, and associated family members, was estimated based on 

18 information gathered from local economic development agencies; and (4) the resulting housing 

19 and local community service employment impacts were estimated. 

20 

21 F.1 Economic and Fiscal Impacts 

22 

23 Employment and income impacts include both direct and indirect employment and income 

24 associated with the various phases of GLE Facility development. Direct employment and 

25 income are created by onsite employment at the facility, while indirect employment and income 

26 are created in the ROI as workers directly employed by the proposed GLE Facility spend their 

27 wages and salaries, and as jobs are created with the purchase of materials, equipment, and 

28 services and other non-payroll expenditures. Direct employment and income created during 

29 each phase of the proposed action are estimated based on anticipated labor inputs and salaries 

30 for the various engineering and construction activities associated with each phase. The indirect 

31 impact of the proposed GLE Facility on regional employment and income is based on the use of 

32 regional economic multipliers. Multipliers capture the indirect (offsite) effects of onsite activities 

33 associated with construction and operation of an activity or event. 

34 

35 Multipliers were taken from the Impact Analysis for Planning (IMPLAN) input-output model. 

36 These multipliers take into account the flow of commodities to industries from producers and 

37 institutional consumers in the various sectors in the economy of the ROI. Input-output accounts 

38 also show consumption activities by workers, owners of capital, and imports from outside the 

39 region. The IMPLAN model contains 528 sectors representing industries in agriculture, mining, 

40 construction, manufacturing, wholesale and retail trade, utilities, finance, insurance and real 

41 estate, and consumer and business services. The model also includes information for each 

42 sector on employee compensation, proprietary and property income, personal consumption 

43 expenditures, Federal, State, and local expenditures, inventory and capital formation, imports, 

44 and exports. 

45 

46 Estimates of the indirect impacts used Type Social Accounting Matrix (SAM) IMPLAN 

47 multipliers, which measure the total (direct plus indirect) impact of direct facility employment 

48 on ROI output, income, and employment. Type II multipliers associated with each major 
F-4 

1 expenditure category (for example, separator equipment, process building and offices, laser 

2 equipment, utilities, spare parts, construction payroll) were taken from the IMPLAN model and 

3 multiplied by the relevant direct employment number, with the resulting total impacts in each 

4 category aggregated to produce the overall impact of each phase of the proposed facility. 

5 

6 State income tax revenue impacts are estimated by applying State income tax rates to 

7 construction and operations earnings related to the proposed GLE Facility. State and local 

8 sales tax revenues are estimated by applying appropriate State and local sales tax rates to 

9 after-tax income generated by construction and operations employees, spent within the ROI. 

10 

11 F.2 Impacts on Population 

12 

13 With preconstruction, construction, and operation of the proposed GLE Facility, a number of 

14 workers, families, and children would migrate into the ROI, either temporarily or permanently. 

15 The capacity of regional labor markets to produce sufficient numbers of workers in the 

16 appropriate occupations required for facility construction and operation is closely related to the 

17 occupational profile of the ROI and occupational unemployment rates. Although the ROI 

18 corresponds to the Wilmington MSA, which is expected to be the primary source of labor for the 

19 proposed GLE Facility, some labor in-migration of workers, families, and children into the ROI, 

20 either temporarily or permanently, is expected during each phase of the proposed GLE Facility. 

21 The capacity of regional labor markets to produce sufficient numbers of workers in the 

22 appropriate occupations required for facility construction and operation is closely related to the 

23 occupational profile of the ROI and occupational unemployment rates. The number of 

24 in-migrating workers was based on interviews with local economic development officials, and 

25 was based on estimates of available labor in each direct labor category. With some uncertainty 

26 in labor availability estimates, the analysis used a range for in-migration during each phase of 

27 the proposed project. Sixty-five percent of in-migrating workers were assumed to be 

28 accompanied by their families, which would consist of an additional adult and one school-age 

29 child (GLE, 2008), based on the national average household size. The national average 

30 household size is used to calculate the number of additional family members that would 

31 accompany direct and indirect in-migrating workers. 

32 

33 F.3 Impacts on Local Housing Markets 

34 

35 The in-migration of workers has the potential to substantially affect the housing market in the 

36 ROI. The analysis considered these impacts by estimating the increase in demand for rental 

37 housing units in the peak year of construction and for owner-occupied units in the first year of 

38 operation, resulting from the in-migration of both direct and indirect workers to the ROI. The 

39 impacts on housing were described in terms of the number of rental units required in the peak 

40 year of construction, and the number of owner-occupied units required in the first year of 

41 operation. The relative impact on existing housing in the ROI was estimated by calculating the 

42 impact of GLE-related housing demand on the forecasted number of vacant rental housing units 

43 in the peak year of construction, and the forecasted number of vacant owner-occupied units in 

44 the first year of operations. Forecasts are based on data provided by the U.S. Census Bureau. 

45 
F-5 

1 F.4 Impacts on Community Services 

2 

3 The impacts of GLE Facility in-migration on community service employment are estimated for 

4 the core ROI counties in which the majority of new workers would locate. Using the estimates 

5 of the number of in-migrating workers and families, the analysis calculates the number of new 

6 sworn police officers, firefighters, and general government employees required to maintain the 

7 existing levels of service for each community service. Calculations were based on the existing 

8 number of employees per 1000 population for each community service. The analysis of the 

9 impact on educational employment estimated the number of teachers in each school district 

10 required to maintain existing teacher-student ratios across all student age groups. Information 

11 on existing employment and levels of service was collected from the individual jurisdictions 

12 providing each service. 

13 

14 Reference 

15 

16 (GLE, 2008) GE-Hitachi Global Laser Enrichment LLC. “Environmental Report for the 

17 GLE Commercial Facility, Revision 0.” December. ADAMS Accession No. ML090910573. 

18 
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14 APPENDIX G 

15 ENVIRONMENTAL JUSTICE DATA 
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1 APPENDIX G 

2 ENVIRONMENTAL JUSTICE DATA 

3 

4 This appendix contains a brief description of methods and definitions, and provides the data 

5 used in the assessment of the potential for disproportionately high and adverse human health or 

6 environmental effects on minority and/or low-income populations resulting from the 

7 preconstruction and construction, operation, and decommissioning of the proposed General 

8 Electric (GE)-Hitachi Global Laser Enrichment LLC (GLE) Facility. 

9 

10 The assessment method consists of three parts: (1) the geographic distribution of low-income 

11 and minority populations in the affected area is described using data from the 2000 U.S. 

12 Census; (2) based on data provided on the health and environmental impacts of the proposed 

13 facility presented in Sections 4.2.1 through 4.2.18, an assessment is made as to whether the 

14 impacts of facility construction and operation would produce impacts that are high and adverse; 

15 and (3) if impacts are high and adverse, a determination is made as to whether these impacts 

16 disproportionately affect minority and low-income populations. 

17 

18 The Council on Environmental Quality (CEQ) provides definitions of disproportionality in 

19 Environmental Justice: Guidance Under the National Environmental Policy Act (CEQ, 1997). 

20 

21 Disproportionately High and Adverse Human Health Effects. Adverse health effects are 

22 measured in risks and rates that could result in latent cancer fatalities, as well as other fatal or 

23 nonfatal adverse impacts on human health. Adverse health effects may include bodily 

24 impairment, infirmity, illness, or death. Disproportionately high and adverse human health 

25 effects occur when the risk or rate of exposure to an environmental hazard for a minority or low26 income population is significant (as defined by NEPA [National Environmental Policy Act]) and 

27 appreciably exceeds the risk or exposure rate for the general population or for another 

28 appropriate comparison group (CEQ, 1997). 

29 

30 Disproportionately High and Adverse Environmental Effects. A disproportionately high 

31 environmental impact that is significant (as defined by NEPA) refers to an impact or risk of an 

32 impact on the natural or physical environment in a low-income or minority community that 

33 appreciably exceeds the environmental impact on the larger community. Such effects may 

34 include ecological, cultural, human health, economic, or social impacts. An adverse 

35 environmental impact is an impact that is determined to be both harmful and significant (as 

36 defined by NEPA). In assessing cultural and aesthetic environmental impacts, impacts that 

37 uniquely affect geographically dislocated or dispersed minority or low-income populations or 

38 American Indian tribes are considered (CEQ, 1997). 

39 

40 Construction and operation of the proposed GLE Facility could impact environmental justice if 

41 any adverse health and environmental impacts resulting from either phase of development are 

42 significantly high, and if these impacts would disproportionately affect minority and low-income 

43 populations. If the analysis determines that health and environmental impacts are not 

44 significant, there can be no disproportionate impacts to minority and low-income populations. In 

45 the event impacts are significant, disproportionality would be determined by comparing the 

46 proximity of any high and adverse impacts to the location of low-income and minority 

47 populations. 

48 
G-4 

1 Tables G-1 through G-4 present detailed Census data for the environmental justice analysis at 

2 the State, county, and Census block group level for 2000 (USCB, 2009). Minority and lowincome populations are defined in Sections 3.14.1 and 3.14.2. ArcView® 3 geographic 

4 information system software was used to determine minority and low-income characteristics by 

5 block group. Minority and low-income data are shown for all block groups that lay partially or 

6 completely within 6.4 kilometers (4 miles) of the proposed GLE Facility site. Census block 

7 groups exceeding minority or low-income criteria are shown in bold.

Table G-1 State and County Minority Population Totals 

Location Total 

Population 

Minority 

Population 

Percent 

Minority 

North Carolina 8,049,313 2,623,620 32.6 

Brunswick County 73,143 14,903 20.4 

New Hanover County 160,307 35,485 22.1 

Pender County 41,082 12,696 30.9 

Source: USCB, 2009.
G-5 

Table G-2 Census Block Group Minority Population Totals 

Location County Total 

Population 

Minority 

Population 

Percent 

Minority 

Census Tract 020100, 

Census Block Group 1 

Brunswick 2030 926 45.6 

Census Tract 011500, 

Census Block Group 1 

New Hanover 2172 404 18.6 

Census Tract 011500, 

Census Block Group 2 

New Hanover 1699 182 10.7 

Census Tract 011500, 

Census Block Group 3 

New Hanover 495 47 9.5 

Census Tract 011500, 

Census Block Group 4 

New Hanover 974 98 10.1 

Census Tract 011500, 

Census Block Group 5 

New Hanover 1985 1219 61.4 

Census Tract 011603, 

Census Block Group 1 

New Hanover 1076 389 36.2 

Census Tract 011603, 

Census Block Group 2 

New Hanover 3286 616 18.7 

Census Tract 011603, 

Census Block Group 3 

New Hanover 1429 547 38.3 

Census Tract 011604, 

Census Block Group 1 

New Hanover 134 39 29.1 

Census Tract 011604, 

Census Block Group 2 

New Hanover 2475 340 13.7 

Census Tract 980500, 

Census Block Group 4 

Pender 1949 683 35.0 

Census Tract 980600, 

Census Block Group 1 

Pender 800 404 50.5 

Census Tract 980600, 

Census Block Group 2 

Pender 4981 1235 24.8 

Census Tract 980600, 

Census Block Group 3 

Pender 1271 431 33.9 

Source: USCB, 2009.
G-6 

Table G-3 State and County Low-Income Population Totals 

Location Total 

Population 

Low-Income 

Population 

Percent 

Low-Income 

North Carolina 8,049,313 958,667 12.3 

Brunswick County 73,143 9095 12.6 

New Hanover County 160,307 20,445 13.1 

Pender County 41,082 5429 13.6 

Source: USCB, 2009.
G-7 

Table G-4 Census Block Group Low-Income Population Totals 

Location County Total 

Population 

Low-Income 

Population 

Percent 

LowIncome 

Census Tract 020100, 

Census Block Group 1 

Brunswick 1952 283 14.5 

Census Tract 011500, 

Census Block Group 1 

New Hanover 2168 146 6.7 

Census Tract 011500, 

Census Block Group 2 

New Hanover 1665 139 8.3 

Census Tract 011500, 

Census Block Group 3 

New Hanover 494 8 1.6 

Census Tract 011500, 

Census Block Group 4 

New Hanover 957 79 8.3 

Census Tract 011500, 

Census Block Group 5 

New Hanover 2016 324 16.1 

Census Tract 011603, 

Census Block Group 1 

New Hanover 1054 76 7.2 

Census Tract 011603, 

Census Block Group 2 

New Hanover 3285 258 7.9 

Census Tract 011603, 

Census Block Group 3 

New Hanover 1012 171 16.9 

Census Tract 011604, 

Census Block Group 1 

New Hanover 155 29 18.7 

Census Tract 011604, 

Census Block Group 2 

New Hanover 2411 258 10.7 

Census Tract 980500, 

Census Block Group 4 

Pender 1932 231 12.0 

Census Tract 980600, 

Census Block Group 1 

Pender 826 302 36.6 

Census Tract 980600, 

Census Block Group 2 

Pender 4958 789 15.9 

Census Tract 980600, 

Census Block Group 3 

Pender 1232 108 8.8 

Source: USCB, 2009. 
G-8 

1 G.1 References 

2 

3 (CEQ, 1997) Council on Environmental Quality. Environmental Justice: Guidance Under the 

4 National Environmental Policy Act. December 10. 

5 <http://ceq.hss.doe.gov/nepa/regs/ej/justice.pdf> (Accessed January 26, 2010). 

6 

7 (USCB, 2009) U.S. Census Bureau. “American Fact Finder.” <http://factfinder.census.gov> 

8 (Accessed September 18, 2009). 

9 
 

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14 APPENDIX H 

15 PROPRIETARY AND SECURITY-RELATED INFORMATION 
 

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15 GLOSSARY 
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1 APPENDIX I 

2 GLOSSARY 

3 

4 

5 Air pollutant: Any substance in the air which could, if in high enough concentration, harm 

6 humans, other animals, vegetation, or material. Pollutants may include almost any natural or 

7 artificial composition of matter capable of being airborne. 

8 

9 Air quality: A measure of the quantity of pollutants, measured individually, in the air. These 

10 levels are often compared to regulatory standards. 

11 

12 ALARA: Acronym for “As Low As (is) Reasonably Achievable.” An approach to keep radiation 

13 exposures (both to the workforce and the public) and releases of radioactive material to the 

14 environment at levels that are as low as social, technical, economic, practical, and public policy 

15 considerations allow. ALARA is not a dose limit; it is a practice whose objective is the 

16 attainment of dose levels as far below applicable limits as possible. 

17 

18 Alluvium: Loose gravel, sand, silt, or clay deposited by streams or running water. 

19 

20 Alpha particle: A positively charged particle ejected spontaneously from the nuclei of some 

21 radioactive elements. It is identical to a helium nucleus that has a mass number of 4 and an 

22 electrostatic charge of +2. It has low penetrating power and a short range (a few centimeters in 

23 air). 

24 

25 Ambient Air Quality Standards: Standards established on a State or Federal level, that define 

26 the limits for airborne concentrations of designated “criteria” pollutants (sulfur dioxide, nitrogen 

27 dioxide, carbon monoxide, ozone, particulate matter [PM10 and PM2.5], and lead), to protect 

28 public health with an adequate margin of safety (primary standards) and to protect public 

29 welfare, including plant and animal life, visibility, and materials (secondary standards). 

30 

31 Aquifer: A permeable body of rock capable of yielding quantities of groundwater to wells and 

32 springs. 

33 

34 Archaeology: The science devoted to the study of historic or prehistoric peoples and their 

35 cultures by analysis of their artifacts, inscriptions, monuments, and other such remains. 

36 

37 Area of potential effects: The geographic area or areas within which an undertaking may 

38 directly or indirectly cause alterations in the character or use of historic properties, if any such 

39 properties exist. The area of potential effects is influenced by the scale and nature of an 

40 undertaking and may be different for different kinds of effects caused by the undertaking 

41 (see 36 CFR 800.16). 

42 

43 Assay: The qualitative or quantitative analysis of a substance, often used to determine the 

44 proportion of isotopes in radioactive materials. 

45 

46 Attainment area: A region that meets the U.S. Environmental Protection Agency National 

47 Ambient Air Quality Standards (NAAQS) for a criteria pollutant under the Clean Air Act. 

48 
I-4 

1 Background radiation: Radiation from cosmic sources, naturally occurring radioactive 

2 materials, including radon (except as a decay product of source or special nuclear material), 

3 and global fallout as it exists in the environment from the testing of nuclear explosive devices. It 

4 does not include radiation from source, byproduct, or special nuclear materials regulated by the 

5 Nuclear Regulatory Commission. The typically quoted average individual exposure from 

6 background radiation is 3.6 millisieverts per year (360 millirems per year). 

7 

8 Becquerel (Bq): A unit used to measure radioactivity. One Becquerel is that quantity of a 

radioactive material that will have one transformation in one second. There are 3.7 × 1010 9 Bq in 

10 one curie (Ci). 

11 

12 Best Management Practices (BMPs): Structural, nonstructural, and managerial techniques 

13 recognized to be the most effective and practical means to reduce surface water and 

14 groundwater contamination while still allowing the productive use of resources. 

15 

16 Beta particle: A charged particle emitted from a nucleus during radioactive decay, with a mass 

17 equal to 1/1837 that of a proton. A negatively charged beta particle is identical to an electron. 

18 A positively charged beta particle is called a positron. Beta particles may be stopped by thin 

19 sheets of metal or plastic. 

20 

21 Bound: To estimate or describe a lower or upper limit on a potential environmental or health 

22 consequence when uncertainty exists. 

23 

24 Buffer area: A designated area of land that is designed to permanently remain vegetated in an 

25 undisturbed and natural condition in order to protect an adjacent aquatic or wetland site from 

26 upland impacts and to provide habitat for wildlife. 

27 

28 Byproduct material: The tailings or wastes produced by the extraction or concentration of 

29 uranium or thorium from any ore processed primarily for its source material content. See also, 

30 Source Material. 

31 

32 Carbon monoxide (CO): An odorless, colorless, poisonous gas produced by incomplete 

33 burning of carbon in fuels. 

34 

35 Census tract: An area usually containing between 2500 and 8000 persons that is used for 

36 organizing and monitoring census data. The geographic dimensions of Census tracts vary 

37 widely, depending on population density. Census tracts do not cross county borders. 

38 

39 Climatology: The science devoted to the study of the conditions of the natural environment 

40 (rainfall, daylight, temperature, humidity, air movement) prevailing in specific regions of the 

41 earth. 

42 

43 Contamination: Undesired radioactive material that is deposited on the surface of, or inside 

44 structures, areas, objects, or people. 

45 

46 Cooling water: Water circulated through a nuclear reactor or processing plant to remove heat. 

47 
I-5 

1 Cost-benefit analysis: A formal quantitative procedure comparing costs and benefits of a 

2 proposed project or act under a set of preestablished rules. 

3 

4 Criteria pollutants: Common air pollutants for which National Ambient Air Quality Standards 

5 have been established by the U.S. Environmental Protection Agency under Title I of the Clean 

6 Air Act (42 U.S.C. 7401 et seq.). Criteria pollutants include sulfur dioxide, nitrogen oxides, 

7 carbon monoxide, ozone, particulate matter (PM10 and PM2.5), and lead. Standards for these 

8 pollutants were developed on the basis of scientific knowledge about their health effects. 

9 

10 Critical habitat: Specific areas within the geographical range of an endangered species that is 

11 formally designated by the U.S. Fish and Wildlife Service under the Endangered Species Act 

12 (16 U.S.C. 1531 et seq.) as essential for conservation. 

13 

14 Cumulative impacts: Potential impacts when the proposed action is added to other past, 

15 present, and reasonable foreseeable future actions. Cumulative impacts can result from 

16 individually minor but collectively significant actions taking place over a period of time. 

17 

18 Curie (Ci): The basic unit used to describe the intensity of radioactivity in a sample of material. 

The curie is equal to 37 billion (3.7 × 1010 19 ) disintegrations per second, which is approximately 

20 the activity of 1 gram (0.035 ounces) of radium. A curie is also a quantity of any radionuclide 

21 that decays at a rate of 37 billion disintegrations per second. 

22 

23 Day-Night Average Sound Level (DNL or Ldn): DNL is a noise metric combining the levels and 

24 durations of noise events and the number of events over an extended time period. It is a 

25 cumulative average computed over a set of 24-hour periods to represent total noise exposure. 

26 DNL also accounts for more intrusive night time noise, adding a 10 decibel penalty for sounds 

27 after 10:00 p.m. and before 7:00 a.m. 

28 

29 Decibel (dB): A standard unit for measuring sound-pressure levels based on a reference sound 

30 pressure of 0.0002 dyne per square centimeter. This is the smallest sound a human can hear. 

31 In general, a sound doubles in loudness with every increase of about 10 decibels. 

32 

33 Decibel, A-weighted (dBA): A number representing the sound level which is frequency34 weighted according to a prescribed frequency response established by the American National 

35 Standards Institute and accounts for the response of the human ear. 

36 

37 Decommissioning: The process of closing down a facility followed by reducing residual 

38 radioactivity to a level that permits the release of the property for unrestricted use 

39 (see 10 CFR 20.1003). 

40 

41 Decontamination: The reduction or removal of contaminating radioactive material from a 

42 structure, area, object, or person. Decontamination may be accomplished by (1) treating the 

43 surface to remove or decrease the contamination, (2) letting the material stand so that the 

44 radioactivity is decreased as a result of natural radioactive decay, or (3) covering the 

45 contamination to shield or attenuate the radiation emitted (see 10 CFR 20.1003 and 20.1402). 

46 
I-6 

1 Depleted uranium: Uranium having a percentage of uranium-235 smaller than the 0.7 percent 

2 found in natural uranium. It is obtained from spent (used) fuel elements or as byproduct tails, or 

3 residues, from uranium isotope separation. 

4 

5 Depleted uranium hexafluoride (depleted UF6): Uranium hexafluoride from which most of the 

6 uranium-235 isotope has been removed. 

7 

8 Direct jobs: The number of workers required at a site to implement an alternative. 

9 

10 Dose: The absorbed dose, given in rads (or in the International Systems of Units [SI], grays), 

11 that represents the energy absorbed from the radiation in a gram of any material. Furthermore, 

12 the biological dose or dose equivalent, given in rem or sieverts, is a measure of the biological 

13 damage to living tissue from radiation exposure. 

14 

15 Dosimetry: The theory and application of the principles and techniques involved in the 

16 measurement and recording of radiation doses. Its practical aspect is concerned with the use of 

17 various types of radiation instruments with which measurements are made (i.e., film badge, 

18 thermoluminescent dosimeter, and Geiger counter). 

19 

20 Ecological resources: Terrestrial, wetland, and aquatic resources that could be affected, with 

21 particular attention to species protected by the Federal government and State-listed species and 

22 habitats of special concern. 

23 

24 Ecoregion: An area having a general similarity in ecosystems and characterized by the spatial 

25 patterning and composition of biotic and abiotic features, including vegetation, wildlife, geology, 

26 physiography (patterns of terrain or land forms), climate, soils, land use, and hydrology, such 

27 that within an ecoregion, there is a similarity in the type, quality, and quantity of environmental 

28 resources present. 

29 

30 Effluent: A gas or fluid discharged into the environment, treated or untreated. Most frequently, 

31 the term applies to wastes discharged to surface waters. 

32 

33 Emissions: Substances that are discharged into the air. 

34 

35 Endangered species: Any species (plant or animal) that is in danger of extinction throughout 

36 all or a significant part of its range. Requirements for determining whether a species is 

37 endangered are found in the Endangered Species Act (16 U.S.C. 1531 et seq.). 

38 

39 Erosion: The wearing away of the land surface by wind, water, ice, or other geologic agents. 

40 Erosion occurs naturally from weather or runoff but is often intensified by human land use 

41 practices. 

42 

43 Exposure: Being exposed to ionizing radiation or to radioactive material. 

44 

45 Exposure pathways: A route or sequence of processes by which a radioactive or hazardous 

46 material may move through the environment to humans or other organisms. Each exposure 

47 pathway includes a source or release from a source, an exposure point, and an exposure route. 

48 
I-7 

1 Fissile: A radionuclide that is capable of undergoing fission after capturing low-energy thermal 

2 (slow) neutrons. The three primary fissile materials are uranium-233, uranium-235, and 

3 plutonium-239. 

4 

5 Floodplain: Low-lying areas adjacent to rivers and streams that are subject to natural 

6 inundations typically associated with precipitation. 

7 

8 Fuel cycle: The series of steps involved in supplying fuel for nuclear power reactors. It can 

9 include mining, milling, isotopic enrichment, fabrication of fuel elements, use in a reactor, 

10 chemical reprocessing to recover the fissionable material remaining in the spent fuel, 

11 reenrichment of the fuel material, refabrication into new fuel elements, and waste disposal. 

12 

13 Fugitive Dust: Any solid particulate matter (PM) that becomes airborne, other than that emitted 

14 from an exhaust stack, directly or indirectly as a result of the activities of man. Fugitive dust 

15 may include emissions from haul roads, wind erosion of exposed soil surfaces, and other 

16 activities in which soil is either removed or redistributed. 

17 

18 Geology and soils: Those earth resources that may be described in terms of landforms, 

19 geology, and soil conditions. 

20 

21 Gray (Gy): The international system (SI) unit of absorbed dose. One gray is equal to an 

22 absorbed dose of 1 Joule/kilogram (one gray equals 100 rads) (see 10 CFR 20.1004). 

23 

24 Greenhouse gases (GHGs): Gases that absorb outgoing infrared radiation emitted by the 

25 earth’s surface and trap heat in the atmosphere. 

26 

27 Groundwater: Water, both fresh and saline, that is stored below the earth’s surface in pores, 

28 cracks, and crevices below the water table. 

29 

30 Hazardous Air Pollutants (HAPs): A group of 188 chemicals identified in the 1990 Clean Air 

31 Act Amendments (42 U.S.C. 7401 et seq.).

32 

33 Hazardous waste: As defined in the Resource Conservation and Recovery Act

34 (42 U.S.C. 6901 et seq.), is “a solid waste, or combination of solid wastes, which, because of its 

35 quantity, concentration, or physical, chemical, or infectious characteristics, may (A) cause, or 

36 significantly contribute to an increase in mortality or an increase in serious irreversible, or 

37 incapacitating reversible illness, or (B) pose a substantial present or potential hazard to human 

38 health or the environment when improperly treated, stored, transported, or disposed of, or 

39 otherwise managed.” 

40 

41 Hectare (ha): Metric unit of surface or land, equivalent to 10,000 square meters or 2.471 acres. 

42 

43 Heels: In the uranium enrichment process, heels refers to the residual solid uranium 

44 hexafluoride left after the feed rate declines to a predetermined level. 

45 

46 Highly enriched uranium (HEU): Uranium enriched in the isotope uranium-235 to 20 percent 

47 or above. 

48 
I-8 

1 Holding ponds: Engineered depressions in the land that contain storm-water runoff until it can 

2 slowly seep back into the ground or evaporate. 

3 

4 Hydrogen fluoride (HF): Chemical compound formed from the conversion of uranium 

5 hexafluoride (UF6) to uranyl fluoride (UO2F2) upon contact of UF6 emissions with water vapor in 

6 air. 

7 

8 Hydrology: The science devoted to the study of the occurrence, circulation, distribution, and 

9 properties of the waters of the earth and its atmosphere. 

10 

11 Impacts: An assessment of the meaning of changes in all attributes being studied for a given 

12 resource, usually measured using a qualitative and nominally subjective technique. 

13 

14 Indirect jobs: Jobs generated or lost in related industries within a regional economic area as a 

15 result of a change in direct employment. 

16 

17 Ingestion: To take in by mouth. Material that is ingested enters the digestive system. 

18 

19 Inhalation: To take in by breathing. Material that is inhaled enters the lungs. 

20 

21 Isotope: Any two or more forms of an element having identical or very closely related chemical 

22 properties and the same atomic number but different atomic weights or mass numbers. 

23 

24 Land Use: The way land is developed and used in terms of the kinds of human-related activities 

25 that occur (e.g., agriculture, residential areas, industrial areas). 

26 

27 Lead (Pb): A naturally occurring heavy metal element formerly added to gasoline and paint for 

28 improved performance characteristics. Lead can be inhaled and ingested in food, water, soil, or 

29 dust. 

30 

31 Low-enriched uranium (LEU): Uranium enriched in the isotope uranium-235, greater than 

32 0.7 percent but less than 20 percent of the total mass. Naturally occurring uranium contains 

33 about 0.7 percent uranium-235, almost all the rest is uranium-238. 

34 

35 Low-level mixed waste: Low-level radioactive waste that also contains hazardous chemical 

36 components regulated under the Resource Conservation and Recovery Act

37 (42 U.S.C. 6901 et seq.). 

38 

39 Low-level radioactive waste (LLRW): As defined in the Low-Level Radioactive Waste Policy 

40 Act, as amended (42 U.S.C. 2021 et seq.), low-level radioactive waste means radioactive 

41 material that is “not high-level radioactive waste, spent nuclear fuel, or byproduct material” as 

42 byproduct material is defined in the Atomic Energy Act (42 U.S.C. 2011 et seq.) 

43 

44 Maximally exposed individual (MEI): A hypothetical person who – because of proximity, 

45 activities, or living habits – could receive the highest possible dose of radiation or of a 

46 hazardous chemical from a given event or process. 

47 
I-9 

1 Mercury (Hg): A naturally-occurring heavy metal element found in air, water, and soil. Mercury 

2 is listed as a hazardous air pollutant (HAP). 

3 

4 Meteorology: The science dealing with the atmosphere and its phenomena, especially as they 

5 relate to weather. 

6 

7 Microcurie (μCi): One millionth of a curie. That amount of radioactive material that 

8 disintegrates (decays) at the rate of 37 thousand atoms per second. 

9 

10 Mitigation: A series of actions implemented to ensure that projected impacts will result in no net 

11 loss of habitat value or wildlife populations. The purpose of mitigative actions is to avoid, 

12 minimize, rectify, or compensate for any adverse environmental impact. 

13 

14 Millirem (mrem): One thousandth of a rem (0.001 rem). 

15 

16 Millisievert (mSv): One thousandth of a sievert (0.001 Sv); equivalent to 100 millirem. 

17 

18 Mixing height: The height above the earth’s surface through which relatively strong vertical 

19 mixing of the atmosphere occurs. 

20 

21 Nitrogen dioxide (NO2): A brownish, highly reactive gas that is present in all urban 

22 atmospheres. The major mechanism for the formation of nitrogen dioxide in the atmosphere is 

23 the oxidation of the primary air pollutant nitric oxide. 

24 

25 Nitrogen oxides (NOx): Nitrogen oxides form when fuel is burned at high temperatures. 

26 

27 Nonattainment Areas: An area that has been designated by the Environmental Protection 

28 Agency, or the appropriate state air quality agency, as exceeding one or more national or State 

29 Ambient Air Quality Standards. 

30 

31 Normal operations: Conditions during which facilities and processes operate as expected or 

32 designed. In general, normal operations include the occurrence of some infrequent events that, 

33 although not considered routine, are not classified as accidents. 

34 

35 Ozone (O3): A photochemical (formed in chemical reactions between volatile organic 

36 compounds and nitrogen oxides in the presence of sunlight) oxidant. 

37 

38 Outfall: The place where effluent is discharged into receiving waters. 

39 

40 Particulate matter (PM): Materials such as dust, dirt, soot, smoke, and liquid droplets that are 

41 emitted into the air by sources such as factories, power plants, cars, construction activity, fires, 

42 and natural windblown dust. Commonly expressed as PM10 or PM2.5, signifying particles with 

43 aerodynamic diameter of less than 10 micrometers and 2.5 micrometers, respectively. 

44 

45 Personnel monitoring: The use of portable survey meters to determine the amount of 

46 radioactive contamination on individuals; or, the use of dosimetry to determine an individual’s 

47 occupational radiation dose. 

48 
I-10 

1 Point source: A source of effluents that is small enough in dimension that it can be treated as if 

2 it were a point. A point source can be either a continuous source or a source that emits 

3 effluents only in puffs for a short time. 

4 

5 Pollutant: Any material entering the environment that has undesired effects. 

6 

7 Pollution: The addition of an undesirable agent to the environment in excess of the rate at 

8 which natural processes can degrade, assimilate, or disperse it. 

9 

10 Pollution prevention: The use of any process, practice, or product that reduces or eliminates 

11 the generation and release of pollutants, hazardous substances, contaminants, and wastes, 

12 including those that protect natural resources through conservation or more efficient utilization. 

13 

14 Prime farmland: Land with the best combination of physical and chemical characteristics for 

15 economically producing high yields of food, feed, forage, fiber, and oilseed crops with minimum 

16 inputs of fuel, fertilizer, pesticides, and labor. Prime farmland includes cropland, pastureland, 

17 rangeland, and forestland. 

18 

19 Rad: The traditional (English) unit for radiation absorbed dose, which is the amount of energy 

20 from any type of ionizing radiation (e.g., alpha, beta, gamma, neutrons, etc.) deposited in any 

21 medium (e.g., water, tissue, air). A dose of one rad means the absorption of 100 ergs (a small 

22 but measurable amount of energy) per gram of absorbing tissue (100 rad = 1 gray). 

23 

24 Radiation (ionizing radiation): Alpha particles, beta particles, gamma rays, x-rays, neutrons, 

25 high-speed electrons, high-speed protons, and other particles capable of producing ions. 

26 Radiation, as used in 10 CFR Part 20, does not include non-ionizing radiation, such as radio- or 

27 microwaves, or visible, infrared, or ultraviolet light (see 10 CFR 20.1003). 

28 

29 Radiation standards: Exposure standards, permissible concentrations, rules for safe handling, 

30 regulations for transportation, regulations for industrial control of radiation, and control of 

31 radioactive material by legislative means. 

32 

33 Radioactivity: The spontaneous decay or disintegration of unstable atomic nuclei, 

34 accompanied by the emission of radiation. Eventually the unstable nuclei reach a stable state. 

35 

36 Radionuclide: An atom that exhibits radioactive properties. Radionuclides can be man-made 

37 or naturally occurring, can have a long life, and can have potentially mutagenic or carcinogenic 

38 effects on the human body. 

39 

40 Region of influence (ROI): The geographic region based on the area in which workers are 

41 expected to live and spend most of their salaries, and in which a significant portion of site 

42 purchase and nonpayroll expenditures from the construction, manufacturing, operation, and 

43 decommissioning phases are expected to occur. In this draft EIS, this region corresponds to the 

44 Wilmington Metropolitan Statistical Area (MSA), a three-county area comprising Brunswick, 

45 New Hanover, and Pender Counties. These three counties cover an area that extends up to 

46 approximately 80 kilometers (50 miles) from the Wilmington Site. 

47 
I-11 

1 Rem: The acronym for roentgen equivalent man, is the traditional (English) unit that measures 

2 the effects of ionizing radiation on humans. The dose equivalent in rems is equal to the 

3 absorbed dose in rads multiplied by the quality factor of the type of radiation 

4 (see 10 CFR 20.1004). 

5 

6 Remediation: Action taken to permanently remedy a release, or threatened release, of a 

7 hazardous or radioactive substance to the environment, instead of or in addition to removal. 

8 

9 Restricted area: Any area to which access is controlled for the protection of individuals from 

10 exposure to radiation and radioactive materials. 

11 

12 Roentgen: A traditional (English) unit of exposure to ionizing radiation. It is the amount of 

13 gamma or x-rays required to produce ions resulting in a charge of 0.000258 coulombs/kilogram 

14 of air under standard conditions. 

15 

16 Runoff: The portion of rainfall that is not absorbed by soil, evaporated, or transpired by plants, 

17 but finds its way into streams directly or as overland surface flows. 

18 

19 Sanitary/industrial waste: Nonhazardous, nonradioactive liquid and solid waste generated by 

20 normal housekeeping activities. 

21 

22 Sediment: Eroded soil particles that are deposited downhill or downstream by surface runoff. 

23 

24 Separative Work Unit (SWU): A separative work unit (SWU) is a unit of measurement used in 

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

26 power plants. It describes the effort needed to separate uranium-235 and uranium-238 atoms in 

27 natural uranium to create a final product that is richer in uranium-235 atoms. 

28 

29 Shielding: Any material or obstruction that absorbs radiation and thus tends to protect 

30 personnel or materials from the effects of ionizing radiation. 

31 

32 Sievert (Sv): The metric unit of radiation dose used to express a quantity called equivalent 

33 dose. This relates the absorbed dose in human tissue to the effective biological damage of the 

34 radiation by taking into account the kind of radiation received, the total amount absorbed by the 

35 body, and the tissues involved. Not all radiation has the same biological effect, even for the 

36 same amount of absorbed dose. One sievert is equivalent to 100 rem. 

37 

38 Site characterization: An onsite investigation at a known or suspected contaminated waste or 

39 release site to determine the extent and type(s) of contamination. 

40 

41 Source material: Uranium or thorium ores containing 0.05 percent uranium or thorium 

42 regulated under the Atomic Energy Act (42 U.S.C. 2011 et seq.). In general, this includes all 

43 materials containing radioactive isotopes in concentrations greater than natural and the 

44 byproduct (tailings) from the formation of these concentrated materials. 

45 

46 Special nuclear material: Plutonium, uranium-233, or uranium enriched in the isotopes 

47 uranium-233 or uranium-235. 

48 
I-12 

1 Subsidence: The process of sinking or settling of a land surface due to natural or artificial 

2 causes. 

3 

4 Sulfur dioxide (SO2): A gas emitted largely from stationary sources such as coal and oil 

5 combustion, steel and paper mills, and refineries. 

6 

7 Surface water: Water located on the surface of the Earth in water bodies such as lakes, rivers, 

8 streams, ponds, wetlands, and the ocean. 

9 

10 Tails: In the uranium enrichment process, tails refers to gas with a reduced concentration of the 

11 uranium-235 isotope. 

12 

13 Toxic air pollutants (TAPs): Toxic air pollutants from created sources. Many chemicals on a 

14 State TAPs list may overlap those on the Federal HAPs list, but the State list may include 

15 additional substances. 

16 

17 Threatened species: Plant and wildlife species that are likely to become endangered in the 

18 foreseeable future. 

19 

20 Total effective dose equivalent (TEDE): The sum of deep-dose equivalent (for external 

21 exposures) and the committed effective dose equivalent (for internal exposures). 

22 

23 Uranium: A radioactive element with the atomic number 92 and, as found in natural ores, an 

24 atomic weight of approximately 238. The two principal natural isotopes are uranium-235 

25 (0.7 percent of natural uranium) and uranium-238 (99.3 percent of natural uranium). Naturally 

26 occurring uranium also includes a minute amount of uranium-234. 

27 

28 Uranium enrichment: The process of increasing the percentage of the naturally occurring and 

29 fissile uranium-235 isotope and decreasing the percentage of uranium-238. 

30 

31 Uranium Hexafluoride (UF6): The chemical form of uranium used during the uranium 

32 enrichment process consisting of one atom of uranium and six atoms of fluorine. 

33 

34 Visual Resource Management (VRM): A process devised by the Bureau of Land Management 

35 to assess the aesthetic quality of a landscape and to design proposed activities in a way that 

36 would minimize their visual impact on that landscape. The process consists of a rating of site 

37 visual quality followed by a measurement of the degree of contrast between the proposed 

38 development activities and the existing landscape. 

39 

40 Visual and scenic resources: Natural or developed landscapes that provide information for an 

41 individual to develop their perceptions of the area. The size, type, gradient, scale, and 

42 continuity of landforms, structures, land use patterns, and vegetation are all contributing factors 

43 to an area’s visual character and how it is perceived. 

44 

45 Volatile Organic Compounds (VOCs): Organic compounds that easily evaporate and can 

46 break down through photochemical reactions. 

47 
I-13 

1 Waste management: The planning, coordination, and direction of functions related to 

2 generation, handling, treatment, storage, transportation, and disposal of waste. It also includes 

3 associated pollution prevention and surveillance and maintenance activities. 

4 

5 Waste minimization: An action that economically avoids or reduces the generation of waste by 

6 source reduction and recycling; or reduces the toxicity of hazardous waste, improving energy 

7 usage. 

8 

9 Water resources: This term includes both freshwater and marine systems, wetlands, 

10 floodplains, and groundwater. 

11 

12 Well field: Area containing one or more wells that produce usable amounts of water. 

13 

14 Wetlands: Land or areas exhibiting the following characteristics: hydric soil conditions; 

15 saturated or inundated soil during some part of the year and plant species tolerant of such 

16 conditions; also, areas that are inundated or saturated by surface or groundwater at a frequency 

17 and duration sufficient to support, under normal circumstances, a prevalence of vegetation 

18 typically adapted for life in saturated soil conditions. Wetlands generally include swamps, 

19 marshes, bogs, and similar areas. 

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