NUREG-1767, Vol. 2

Environmental Impact 

Statement on the Construction and

Operation of a Proposed Mixed 

Oxide Fuel Fabrication Facility at

the Savannah River Site, 

South Carolina

Appendices F through L

Final Report

 U.S. Nuclear Regulatory Commission

Office of Nuclear Material Safety and Safeguards

Washington, DC 20555-0001
 NUREG-1767, Vol. 2

Environmental Impact 

Statement on the Construction and

Operation of a Proposed Mixed 

Oxide Fuel Fabrication Facility at 

the Savannah River Site,

South Carolina

Appendices F through L

Final Report 

Manuscript Completed: January 2005

Date Published: January 2005

Division of Waste Management and Environmental Protection

Office of Nuclear Material Safety and Safeguards

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001
Appendix F

F-1

APPENDIX F:

AIR QUALITY IMPACT ASSESSMENT
Appendix F

F-2
Appendix F

F-3

APPENDIX F:

AIR QUALITY IMPACT ASSESSMENT

F.1 Introduction

Air quality impacts are generally assessed by determining the concentrations of pollutants in the

air caused by the major sources associated with an action. For an action proposed for the

future, the assessment is based on projected pollutant concentrations determined by computer

modeling. This projection involves three steps. First, the emissions of the sources are

calculated. Most frequently, this calculation requires knowing the activity level of the source

and applying an appropriate set of emission factors that specify the quantity of air pollutants

emitted per unit of activity.

In the second step, the pollutant concentrations in the air associated with these emissions are

determined for various locations (receptors) by using an air quality model. The model uses

information on the emissions along with meteorological conditions, source and receptor

elevations, and source characteristics to estimate concentrations. Meteorological conditions

included in these calculations are ambient temperature, wind speed and direction, mixing

heights, and atmospheric stability. Source characteristics include location, temperature,

diameter, exit velocity, and height for stacks; size and orientation for area sources; and initial

horizontal and vertical dispersions for volume sources.

Finally, the modeled concentrations are compared with standard measures of impact, typically

ambient air quality standards set by regulatory agencies, such as the National Ambient Air

Quality Standards (NAAQS) or state standards and Prevention of Significant Deterioration

(PSD) increments. The standards and increments depend on the averaging time, with periods

of 1, 3, 8, and 24 hours, and annual being specified in the NAAQS. The air quality model uses

hourly emissions and meteorological data and can be executed to produce concentrations for

periods corresponding to the selected impact measures.

For the Mixed Oxide Fuel Fabrication Facility (proposed MOX facility), the Pit Disassembly and

Conversion Facility (PDCF), and the Waste Solidification Building (WSB), air emissions from

construction activities and operations were estimated on the basis of standard references and

site-specific data or were taken from previous work on the facilities. Ambient concentrations

were then computed with a model recommended by the U.S. Environmental Protection Agency

(EPA). Five years of meteorological data taken at locations near the Savannah River Site

(SRS) were used in the modeling. Pollutant concentrations at the SRS boundary and at off-site

receptor locations were modeled. Section F.2 discusses estimating emissions associated with

the facility; Section F.3 discusses the air quality model, its data input, and modeling

assumptions.
Appendix F

F-4

F.2 Emission Estimates

This section discusses the methods used to calculate emissions projected to be associated with

construction and operation of the facility.

F.2.1 Construction Emissions

Construction fugitive dust, emissions from the concrete batch plant, and exhaust emissions

from construction equipment were modeled for the construction phase. Emissions from fuel

storage, refueling construction equipment, and worker and delivery vehicles were not modeled. 

Because of the low volatility of diesel fuel, emissions from storing diesel fuel and refueling

construction equipment would be negligible. Emissions from worker and delivery vehicles

would be dispersed along roadways around the site and would have lesser impacts than

emissions from the limited construction area.

The activity levels, associated emission factors, and other data used to calculate emissions for

the construction sources are shown in Table F.1. Construction of the proposed MOX facility is

expected to disturb about 39 ha (96 acres), of which 28 ha (69 acres) would be located on the

proposed MOX facility site itself, be contiguous to the site, or be used for fill on the PDCF site

during proposed MOX facility construction (DCS 2002a). The remaining 11 ha (27 acres) would

be used for ancillary activities, such as road work and utility corridors. Construction of the

concrete batch plant would disturb an additional 4.0 ha (10 acres). Only limited portions of

most of these areas would be disturbed at any time, and the disturbance of a given section

would last only a short time. It was assumed that 50% of the contiguous 28-ha (69-acre) area

would be disturbed at any one time and that heavy earth-moving activities would occur over a

6-month period. For the ancillary areas, emissions were estimated assuming that construction

would last 6 months and that only about 10% of the area would be disturbed at any time.

Modeling was carried out for the entire disturbed area. It was further assumed that 30% of the

construction fugitive emissions would be particulate matter with a diameter less than or equal to

10 m (PM10) (EPA 1988) and that 15% would be PM2.5 (Kinsey and Cowherd 1992). Disturbed

areas would be watered to control dust emissions, reducing emissions by 50% (EPA 2002).

Construction of the concrete batch plant would disturb 4.0 ha (10 acres) (DCS 2002a). The

entire disturbed area was assumed to be part of the contiguous site, and emissions calculation

and modeling used the same assumptions as were used for the proposed MOX facility

construction fugitive emissions.

Construction of the PDCF was assumed to disturb about 14 ha (35 acres) (DCS 2002b). The

contiguous site area was assumed to account for about two-thirds of the total and dispersed

ancillary activities the remainder. Emissions calculation and modeling used the same

assumptions as were used for modeling MOX facility construction fugitive emissions.

Construction of the WSB was assumed to disturb about 2 ha (5 acres) (DCS 2002a). The

entire disturbed area was assumed to be part of the contiguous site. Emissions calculations 
Appendix F

F-5

Table F.1. Emission factors, activity levels, and emissions for facility construction

Annual activity

Source Pollutanta Emission factor MOX PDCF WSB Batch plant

Construction

fugitivesb

PM 0.6 tons/acre/moc Site: 69 acres;

5 months

Ancillary:

35 acres;

6 months

Site: 23 acres;

12 months

Ancillary:

12 acres;

6 months

5 acres;

5 months

10 acres;

5 months

PM10 -

d

PM2.5 -

Batch plante PM 0.2 lb/yd3f NAg NA NA 62,500 yd3

/yrh

PM10 0.058f NA NA NA

PM2.5 NA NA NA NA

Equipment

exhausti CO 14.67 kg/103

 litersj 1,250,000 liters

diesel fuel/yrk 495,000 litersdiesel fuel/yrl 114,000liters/diesel

fuel/yrm

0n

VOCs 3.76 kg/103 litersj

NOx 38.75 kg/103 litersj

SOx 3.74 kg/103 litersj

PM 3.20 kg/103 litersj

PM10 3.20 kg/103 liters

PM2.5 3.20 kg/103

 liters

Annual emissions

(kg/yr)

Hourly emissions

(g/h)o

Source Pollutanta MOX PDCF WSB Batch plant MOX PDCF WSB Batch plant

Construction

fugitivesb PM 103,000 79,900 6,800 13,600 49,400 38,400 3,270 6,540

PM10 30,800 24,000 2,040 4,080 14,800 11,500 981 1,960

PM2.5 15,400 12,000 1,020 2,040 7,410 5,760 491 981

Batch plante PM NA NA —l 5,670 NA NA NA 2,730

PM10 NA NA —l 1,640 NA NA NA 790

PM2.5 NA NA —l 850 NA NA NA 409

Equipment

exhausti CO 18,300 7,260 1,670 —p 8,810 3,490 801 —p

VOCs 4,690 1,960 427 —p 2,260 894 205 —p

NOx 48,400 19,200 4,400 —p 23,300 9,220 2,120 —p

SOx 4,670 1,850 424 —p 2,240 889 204 —p

PM 4,000 1,580 363 —p 1,920 761 175 —p

PM10 4,000 1,580 363 —p 1,920 761 175 —p

PM2.5 4,000 1,580 363 —p 1,920 761 175 —p

a

PM = particulate matter with a diameter equal to or less than about 30 m; PM10 = particulate matter with a

diameter equal to or less than 10 m; PM2.5 = particulate matter with a diameter less than 2.5 m; CO = carbon

monoxide; VOC = volatile organic compound; NOx = nitrogen oxides; SOx = sulfur oxides.

b

PM10 taken as 30% of PM (EPA 1988); PM2.5 taken as 15% of PM (Kinsey and Cowherd 1992).

c

Source: EPA (2002, Section 13.2.3) and a 50% reduction in emissions due to watering used to control dust.

Footnotes continue on next page.
Appendix F

F-6

Table F.1. Continued

d

- indicates emissions calculated as percentage of PM.

e

PM2.5 taken as 15% of PM (EPA 2002, Category 3, Table B.2-2, Appendix B-2).

f

Source: EPA (2002, Section 11.12).

g

NA = not applicable. 

h

Source: DCS (2002a); includes concrete for both the proposed MOX facility and the WSB.

i

All emissions assumed to be PM2.5.

j

Source: EPA (1985, Table II-7.1).

k

Source: DCS (2002b, Table 5.5).

l

Source: DOE (1999, Table 5.5).

mSource: DCS (2002b, Table G-4).

n

Fuel use for construction of batch plant included in fuel use for the proposed MOX facility. 

o

Hourly emissions based on annual rates assuming construction activities occur 8 hours per day, five days

per week, 52 weeks per year.

p

Emissions included in emissions from the proposed MOX facility. 

and modeling used the same assumptions as were used for proposed MOX facility construction

fugitive emissions.

The concrete batch plant is expected to produce 47,800 m3

 (62,500 yd3) of concrete annually

(DCS 2002a). This amount would be sufficient for both proposed MOX facility and WSB

construction. The emission factors used in the modeling represent the total particulate matter

process emissions from concrete batching. PM2.5 was taken as 15% of the particulate matter,

on the basis of the cumulative weight-percent distribution for Category 3 in EPA (2002,

Table B.2-2).

Information on the mix of construction equipment types that would be used at the site was not

available. It was assumed that all construction equipment would be diesel powered. The

factors presented in Table F.1 are averages over the different types of equipment listed in EPA

(1985, Table II-7.1). Factors for off-highway trucks and the miscellaneous category were

excluded from the averages. Particulate emissions from diesel engines are expected to have

small diameters, so it was assumed that all particulate emissions would be in the PM2.5

category.

Hourly emission rates for all three sources were calculated from annual rates on the basis of a

construction schedule of 8 hours per day, 5 days per week, and 52 weeks per year. This

assumption leads to higher hourly emissions and thus is more conservative than assuming a

longer work day or a longer work week.
Appendix F

F-7

F.2.2 Emissions during Operation

Emissions from the facility processes and from operation of the emergency and standby

generators were modeled for the operation phase of the facilities. As for the construction

phase, emissions from worker and delivery vehicles were not included.

Table F.2 summarizes the activity levels and emissions from standby and emergency dieselpowered generators at the proposed MOX facility and WSB. There would be six engines at the

proposed MOX facility expected to operate a total of 804 h/yr. Each engine would use about

522 L (138 gal) of diesel fuel per hour or 418,477 L/yr (110,550 gal/yr) for all six engines

(DCS 2004a; DCS 2004b). Vendor-supplied emission factors were available for criteria

pollutants. The calculation of air toxic emissions used standard emission factors from EPA

(2002) and assumed a heating value of 137,000 Btu/gal for diesel fuel.

Detailed information on emergency generator use at the PDCF was unavailable. Total fuel use

during operation is expected to be 37,998 L (10,038 gal/yr) (DOE 1999, Table E-7). Table G-59

in DOE (1999) gives the annual emissions of criteria pollutants from the PDCF. Annual toxic

emissions from PDCF generators were estimated using standard emission factors from EPA

(2002) and assuming heating value of 137,000 Btu/gal for diesel fuel. Annual operating hours

were not available. Hourly emissions were calculated assuming 86 hours/yr of operation, the

same as the annual operating hours for the standby generators in the MOX facility (DCS

2004b). This procedure may overestimate the PDCF emissions, because the annual PDCF fuel

use includes diesel, fuel oil, and gasoline, not just fuel for the emergency generators.

The WSB is expected to have one emergency generator that will operate about 250 h/yr.

Engine-specific emission factors were available for criteria pollutants (DCS 2002a). Air toxic

emissions from proposed MOX facility emergency generators were scaled by the ratio of

proposed MOX facility and WSB annual hours of operation to estimate WSB emergency

generator emissions.

Table F.3 summarizes process emissions. The aqueous polishing process at the proposed

MOX facility would emit nitrogen dioxide. The chlorine would come from chloride in the

plutonium feedstock (DCS 2002b). Hourly emissions were based on 8,760 h/yr of continuous

operation.

The PDCF would have no process emissions (DOE 1999, Table G-59). The WSB would emit

particulates when the cement silo is operated and when cement is withdrawn into the weigh

hopper and mixed during the waste cementation process. Hourly emissions are based on the

assumption that silo operations, including cement delivery, would occur 12 times per year and

would be completed in less than one hour. The WSB would process about 25 batches of waste

per year. Each batch would require operating each of two hoppers for 1 hour and each of two

mixers for 12 hours (DCS 2002a). Depending on the final process design, evaporation of acidic

waste in the WSB could emit up to 9,175 kg/yr (20,230 lb/yr) of nitrogen dioxide. An amount of

acetone would also be emitted.
Appendix F

F-8

Table F.2. Emission factors, activity levels, and

emissions for emergency generators

Facility Pollutant

Emission

factor

(lb/106 Btu)b,c Activity

Emissionsa

 (kg)

Annual Hourly

MOX CO 6.43 6 engines; 804

engine-hours/yr

2,350 17.5

VOC 2.88 1,050 7.85

NOx 67.0 24,500 183

SOx 3.9 1,420 10.6

PM 0.63 230 1.72

PM10 0.52d 189 1.41

PM2.5 0.49e 177 1.32

Benzene 0.000776 5.33 0.0400

Toluene 0.000281 1.93 0.0144

Xylenes 0.000193 1.33 0.00990

Propylene 0.00279 19.1 0.143

Formaldehyde 0.0000789 0.543 0.00405

Acetaldehyde 0.0000252 0.173 0.00129

Acrolein 0.00000788 0.0542 0.000404

Naphthalenef 0.00013 0.894 0.00667

Total PAHsg <0.000212 1.46 0.01

PDCF CO 10,038 gal/yr fuel;

86 engine-hours/yr

520h 6.05

VOC 58h 0.674

NOx 2,000h 23.3

SOx 34h 0.395

PM 50h 0.581

PM10 41d 0.478

PM2.5 39e 0.448

Benzene 0.000776 0.485 0.00563

Toluene 0.000281 0.175 0.00204

Xylenes 0.000193 0.121 0.00140

Propylene 0.00279 1.74 0.0203

Formaldehyde 0.0000789 0.049 0.000573

Acetaldehyde 0.0000252 0.016 0.000183

Acrolein 0.00000788 0.005 0.0000572

Naphthalenef 0.00013 0.081 0.000944

Total PAHsg <0.000212 0.132 0.00154

WSBi CO 24.92 1 engine; 250

engine-hours/yr

575 2.30

VOC 5.07 50.0 0.20

NOx 1.62 2,830 11.3

SOx 0.44 184 0.735

PM 4.24 481 1.93

PM10 4.07d 462 1.85

PM2.5 3.81e 433 1.73

Benzene 1.66 0.0066

Toluene 0.601 0.0024

Xylenes 0.413 0.0017
Appendix F

F-9

Table F.2. Continued

Facility Pollutant

Emission

factor

(lb/106 Btu)b,c Activity

Emissionsa

 (kg)

Annual Hourly

Propylene 5.97 0.024

Formaldehyde 0.169 0.00068

Acetaldehyde 0.054 0.00022

Acrolein 0.017 0.00007

Naphthaleneg 0.278 0.0011

Total PAHsh 0.454 0.0018

a

If needed, a heating value of 137,000 Btu/gal was used for diesel fuel to calculate

emissions.

b

Source (unless otherwise specified): Criteria pollutants: DCS (2002a); Air toxics: 

EPA (2002, Section 3.4-5).

c

Units: Criteria pollutants = lb/(engine-hour). Air toxics = lb/106 Btu.

d

Based on a ratio of PM10/PM factor in Table 3.4-2, EPA (2002).

e

PM2.5 taken as 90/96 of PM10 (Category 1, Table B.2-2, Appendix B-2, EPA [2002]).

f

Included in total PAHs.

g

PAHs = polycyclic aromatic hydrocarbons.

h

Source: DOE (1999, Table G-59).

i

Annual emissions of air toxics at the WSB were calculated from those at the proposed MOX

facility based on the ratio of annual operating hours (= 250/804).

Storage of diesel fuel for use in emergency and standby generators would emit volatile organic

compounds (VOCs) at each facility. Emission estimates from DCS (2004b) were used to

estimate emissions from the other two facilities. Proposed MOX facility fuel storage emissions

were scaled by the ratio of proposed MOX facility and PDCF annual fuel uses to estimate

PDCF fuel storage emissions, and were scaled by the ratio of proposed MOX facility and WSB

annual hours of operation to estimate WSB emissions.

F.3 Air Quality Modeling

This section presents information on the air quality model and modeling assumptions,

meteorological data, source data, receptors, and terrain data used to estimate the air quality

impacts of the facility.
Appendix F

F-10

Table F.3. Process emissions during operations

Emissions

Facility Operation Pollutant Annual (kg/yr) Hourly (g/h)

MOXa Aqueous polishing NO2 4,480 511

Chlorine in Pu Chlorine 15 1.7

Diesel fuel storage VOC 1.03 0.12

PDCF Diesel fuel storage VOC 0.094 0.011

WSBb Silo operations PM 5.55 463

PM10 2.78 231

PM2.5 0.833 69.4

Cementation PM 0.450 5.14

PM10 0.225 2.57

PM2.5 0.068 70.2

Acetone 2.93 9.75

Acidic waste evaporation NO2 <9800 <30,600

Diesel fuel storage VOC 0.11 0.013

a

Source: DCS (2004b, Table 5-7).

b

Sources: DCS (2002a-c, 2004a,b).

F.3.1 Air Quality Model

Version 3 of the Industrial Source Complex Short-Term (ISCST3) model (EPA 1995) was used

to estimate potential impacts of facility construction and operation on ambient air quality. 

ISCST3 has numerous options that can be set to make the calculations conform to the actual

situation being modeled. The following options were used for the facility model runs: (1) the

regulatory default options, (2) building downwash, and (3) rural dispersion.

In its guideline on air quality modeling, the EPA (1999) specifies ISCST3 as the “guideline”

model for a wide variety of regulatory applications. The modeling guideline also specifies a set

of “regulatory options,” specific settings for some of the options included in the model. The

model was always run using the regulatory options.

In addition, as specified in the guideline, effective building widths were included in the operation

runs to account for building-induced downwash of pollutants released from the facility stack. 

These effective widths were calculated from the physical widths and heights by using EPA’s

Building Profile Input Program (BPIP) (EPA 1993). The physical dimensions for the proposed

MOX facility and nearby buildings were taken from DCS (2002a). No information was available

in the dimensions of the PDCF. Dimensions for the WSB were taken from DCS (2002a).
Appendix F

F-11

The way air pollutants disperse differs between predominantly urban and predominantly rural

areas. The SRS and the surrounding area are generally rural rather than urban in character, so

the model was run in the rural mode.

F.3.2 Meteorological Data

The ISCST3 code uses hourly surface data (wind speed, wind direction, ambient temperature,

and atmospheric stability) and twice-daily mixing-heights. Modeling for the facility used 5 years

of surface data collected at Columbia, South Carolina, for the period from 1990 through 1994. 

Mixing height data came from Athens, Georgia, for the period from 1990 through August 1994. 

The Athens site was moved to Atlanta, Georgia, in September 1994.

F.3.3 Source Data

The characteristics used to model the sources are listed in Table F.4. Volume source

dimensions were converted into the initial dispersion values in Table F.4 on the basis of the

suggestions in EPA (1995).

F.3.3.1 Construction

Construction fugitive emissions were modeled as square area sources centered on the

associated facility site and oriented with its sides parallel to the site’s side. It was assumed that

50% of the area would be disturbed at any time.

Thirty-nine ha (96 acres) of the 43 ha (106 acres) disturbed during construction of the proposed

MOX facility would be the site itself, contiguous areas, fill area on the PDCF site, and work on

roads and utilities (DCS 2002a). This 39-ha (96-acre) area was modeled to estimate the impact

of construction fugitives. One-half of this area corresponds to a square 441 m (1,450 ft) on a

side. The remaining 4.0 ha (10 acres) of the disturbed area would be the site of the batch plant

(whose construction fugitives were modeled as a square at the appropriate location). 

The total area disturbed during PDCF construction is expected to be 36 ha (90 acres)

(DOE 1996, Section 4). About two-thirds of this total, the same fraction as used for the

proposed MOX facility, was modeled. One-half of this area corresponds to a square about

344 m (1,140 ft) on a side. 

The modeled area for WSB construction was taken as one-half of the entire area of the site,

2.0 ha (5.0 acres), corresponding to a square about 101 m (330 ft) on a side.
Appendix F

F-12

Figure F.1. Receptor locations used in air quality modeling.
F-13

Appendix F Table F.4. Characteristics of modeled sources Source characteristics Initial dispersiona (m) Release characteristics

Source

Modeled

type

Release

height (m)

Length

(m) Horizontal Vertical

Temperature

(K)

Velocity

(m/s)

Diameter

(m)

Construction fugitivesproposed MOX facility Area 1 441 NAb NA NA NA NA

Construction fugitives-PDCF Area 344 344 NA NA NA NA NAConstruction fugitives-WSB Area 101 101 NA NA NA NA NAConstruction fugitives-batchplant 

Area 142 NA NA NA NA NA NA

Concrete batch plant Volume 4.6 NA 7.5 2.1 NA NA NAConstruction equipmentexhaust-proposed MOXfacility

Volume 3.1 NA 87 1.4 NA NA NA

Construction equipmentexhaust-PDCF 

Volume 3.1 NA 80 1.4 NA NA NA

Construction equipmentexhaust-WSB 

Volume 3.1 NA 23 1.4 NA NA NA

Proposed MOX facility stackc Point 36.6 NA NA NA 290.3 16.7 2.59

WSB silo stack Point 15.2 NA NA NA 290.3 0.031 0.457WSB mixer/hopper stack Point 12.2 NA NA NA 290.3 0.031 0.203WSB main stack Point 24.4 NA NA NA 290.3 3.0 1.52Emergency generators Point 14.3 NA NA NA 1180 98.5 0.204

aVolume source dimensions were converted into the initial dispersion values using the suggestions in EPA (1995).bNA = not applicable.cSource: DCS (2001).
Appendix F

F-14

During operations, the concrete batch plant was modeled as a volume source. In ISCST3,

volume sources are square in the horizontal plane. Batching activities were assumed to take

place in a square about 32 m (110 ft) on a side, corresponding to an area of about 0.10 ha

(0.26 acre). The plant structure was assumed to be about 9.1 m (30 ft) high. A release height

of 4.6 m (15 ft) was taken as representative of all batching activities.

Emissions from construction equipment exhaust would be released over the same area as the

construction fugitive emissions and were modeled as volume sources located at the center of 

the facility sites. An exhaust release height of 3.1 m (10 ft) was assumed for the construction

equipment.

For short-term averages, all construction sources were assumed to operate 8 hours per day — 

from 8:00 a.m. to 12 p.m. and from 1 p.m. to 5 p.m. Emissions were assumed to be zero

during other hours. Annual averages were calculated by assuming a construction schedule of

260 days per year as discussed in Section F.2.1.

F.3.3.2 Operation

Facility stacks were modeled as points (see Table F.4). There would be a single stack on the

proposed MOX facility and two on the WSB. One WSB stack would exhaust the silo, another

would exhaust hoppers and mixers, and the main stack would provide general building exhaust.

Emissions from the standby and emergency generators were modeled as points using

representative release characteristics.

Different approaches were used to estimate short-term impacts for periods of 24 hours and less

and annual impacts. The proposed MOX facility process was assumed to operate continuously,

and the same rate was used for estimating both short-term and annual impacts. The WSB

would operate in a batch mode, as discussed above. For short-term impacts, emissions were

assumed to occur during a 12-hour period from 6 a.m. to 6 p.m. at actual rates. Annual

impacts were estimated on the basis of 12 hours per day of operations at rates consistent with

the expected annual emissions. The emergency and standby generators would operate

intermittently for testing and for unscheduled emergencies. Short-term impacts were assessed

by assuming that the generators for all three facilities would operate 24 hours per day to

simulate an extended emergency. Annual impacts were assessed by assuming 8,760 hours

per year of operation at rates consistent with the expected annual emissions. 

F.3.4 Receptor Data

Two types of receptors were used in the analysis: boundary receptors and off-site receptors. 

The receptor network is shown in Figure F.1. The boundary receptors were located every

200 m (660 ft) along the SRS boundary. No boundary receptors were placed along the narrow

section of the SRS extending south and southwest along Lower Three Runs Creek to the

Savannah River. The off-site receptors consisted of two Cartesian grids oriented along the
Appendix F

F-15

north-south direction and extending 50 km (31 mi) in each direction from the facility site. From

the SRS boundary out to 20 km (12 mi), the grid spacing was 1.0 km (0.62 mi). Farther out, the

grid spacing was 5.0 km (3.1 mi).

F.3.5 Terrain Data

Terrain effects were included in all the modeling runs. Terrain data for sources and receptors

were taken from electronic data available from the U.S. Geological Survey (2001)

1:24,000 scale (7.5-minute series) digital elevation model. The grade level for the proposed

MOX facility was taken as 83 m (270 ft) above mean sea level (DCS 2002b).

F.4 References for Appendix F

DCS (Duke Cogema Stone, and Webster) 2001. Changes to Mixed Oxide Fuel Fabrication

Facility Environmental Report. Letter with attachments submitted by P. S. Hastings (DCS,

Charlotte, NC) to U.S. Nuclear Regulatory Commission (Washington, DC). Dec. 11.

DCS 2002a. Responses to the Request for Additional Information on the Environmental Report

Revisions 1 & 2. DCS-NRC-000116, Docket Number 070-03098. Charlotte, NC. Oct. 29.

DCS 2002b. Mixed Oxide Fuel Fabrication Facility Environmental Report Revision 1 & 2. 

Docket Number 070-03098. Charlotte, NC.

DCS 2002c. Corrections to Responses to the Request for Additional Information on the

Environmental Report Revisions 1 & 2. Letter with attachments from P. S. Hastings (DCS,

Charlotte, NC) to U.S. Nuclear Regulatory Commission (Washington, DC). Nov. 15.

DCS 2004a. Mixed Oxide Fuel Fabrication Facility Environmental Report, Revision 5. Docket

Number 070-03098. Charlotte, NC. June 10.

DCS 2004b. Mixed Oxide Fuel Fabrication Facility Environmental Report, Revision 5,

Responses to Request for Additional Information. Docket Number 070-03098. Charlotte,

NC. Sept. 17.

DOE (U.S. Department of Energy) 1996. Storage and Disposition of Weapons Usable Fissile

Materials Final Programmatic Environmental Impact Statement. DOE/EIS-0229. Office of

Fissile Materials Disposition, Washington, DC. Dec.

DOE 1999. Surplus Plutonium Disposition Final Environmental Impact Statement. 

DOE/EIS-0283. Office of Fissile Materials Disposition, Washington, DC. Nov.

EPA (U.S. Environmental Protection Agency) 1985. Compilation of Air Pollutant Emission

Factors, Vol. II: Mobile Sources. AP-42, Fourth Edition. Office of Air and Radiation, Office

of Mobile Sources, Test and Evaluation Branch, Ann Arbor, MI. Sept.

EPA 1988. Gap Filling PM-10 Emission Factors for Selected Open Area Dust Sources. 

EPA-450/B-88-003. Research Triangle Park, NC.

EPA 1993. User’s Guide to the Building Profile Input Program. EPA-454/R-93-038 (revised

Feb. 8, 1995). Office of Air Quality Planning and Standards, Research Triangle Park, NC. 

Oct.

EPA 1995. User’s Guide for the Industrial Source Complex (ISC3) Dispersion Models. 

EPA-44/B-95-003a. Office of Air Quality Planning and Standards, Research Triangle Park,

NC. Sept.
Appendix F

F-16

EPA 1999. Appendix W to Part 51 — Guideline on Air Quality Models. 40 CFR 51.

Washington, DC. July 1.

EPA 2002. Compilation of Air Pollutant Emission Factors, Vol. I: Stationary Point and Area

Sources, Supplements A-F and Updates 2001 and 2002. AP-42, Fifth Edition. Available at

http://www.eap.gov/ttn/chief/ap42.html.

Kinsey, J.S., and C. Cowherd, Jr. 1992. “Fugitive Dust.” In Air Pollution Engineering Manual. 

A.J. Bunicore and W.T. Davis (eds.). Van Nostrand Reinhold, New York, NY.

U.S. Geological Survey 2001. “7.5 Minute Digital Elevation Models (DEM).” Available at

http://edcwww.cr.usgs.gov/doc/edchome/ndcdb/7_min_dem/states.html.
Appendix G

G-1

APPENDIX G:

ADDITIONAL IMPACTS OF THE NO-ACTION ALTERNATIVE
Appendix G

G-2
Appendix G

1 Terms used to categorize impacts are defined in Section 2.4.

G-3

APPENDIX G:

ADDITIONAL IMPACTS OF THE NO-ACTION ALTERNATIVE

Appendix G includes impacts of the no-action alternative that are not addressed in Chapter 4.1

Technical areas included in the appendix are geology, seismology, and soils; noise; ecology;

land use; cultural and paleontological resources; infrastructure; socioeconomics; and esthetics. 

Other potential impacts are addressed in Chapter 4.

G.1 Geology, Seismology, and Soils

In general, continued storage of surplus plutonium at current storage locations would have no

impact on geology or seismology at the sites. If new construction was required to upgrade

storage facilities at any of the sites, there could be localized, small effects on soils, such as

compaction and erosion, as a result of construction activities.

G.2 Noise

The ongoing operations at the storage sites would result in no appreciable change from current

levels of traffic noise and on-site operational noise. Nontraffic noise sources are far enough

from off-site areas that the noise of operations would not be expected to cause annoyance to

the public. However, some noise sources could be close enough to on-site noise-sensitive

areas to result in impacts, such as the disturbance of wildlife. 

G.3 Ecology

No construction or demolition of buildings is planned under the continued storage option. If any

modifications were required to ensure safe storage, they would not result in appreciable change

to current conditions. Therefore, continued storage would have negligible impacts on ecological

resources. At Pantex, any upgrading of existing storage facilities would occur in an area that is

currently disturbed, so small impacts to biota would occur. Also, no impacts to threatened and

endangered species would be expected (DOE 1996, pg. 4-207). Regardless, the impacts of

new construction would be addressed under a separate environmental review conducted by the

U.S. Department of Energy (DOE).
Appendix G

G-4

G.4 Land Use

No new land use is planned in association with continued storage of surplus plutonium, except

possibly at the Pantex site. If upgrading of the storage facility at Pantex was required, it would

take place on previously disturbed land and would have minimal impacts on existing land use

plans.

G.5 Cultural and Paleontological Resources

No impacts on cultural or paleontological resources are expected from the continued storage of

surplus plutonium.

G.6 Infrastructure

Detailed data on infrastructure for the current storage sites are presented in the Storage and

Disposition Programmatic Environmental Impact Statement (S&D PEIS) (DOE 1996,

Section 4.2). The infrastructure of the sites would be capable of supporting all anticipated

missions and functions associated with continued storage.

G.7 Socioeconomics

As stated in the S&D PEIS (DOE 1996), under continued storage, the existing storage facilities

at the sites would remain operational. No new employment or in-migration of workers would be

required.

G.8 Aesthetics

Continued storage would not result in any adverse impacts to visual resources at the storage

sites.

G.9 Reference for Appendix G

DOE (U.S. Department of Energy) 1996. Storage and Disposition of Weapons-Usable Fissile

Materials Final Programmatic Environmental Impact Statement. DOE/EIS-0229. Office

of Fissile Materials Disposition, Washington, DC. Dec.
Appendix H

H-1

APPENDIX H:

ADDITIONAL IMPACTS OF THE PROPOSED ACTION
Appendix H

H-2
Appendix H

1 Terms used to categorize impacts are defined in Section 2.4.

H-3

APPENDIX H:

ADDITIONAL IMPACTS OF THE PROPOSED ACTION

Appendix H discusses impacts1 of constructing and operating the proposed Mixed Oxide (MOX)

Fuel Fabrication facility, the Pit Disassembly and Conversion Facility (PDCF), and the Waste

Solidification Building (WSB) that are not addressed in Chapter 4. Technical areas included in

the appendix are geology, seismology, and soils; noise; ecology; land use; cultural and

paleontological resources; infrastructure; and socioeconomics. Other impacts of construction

related to human health risk, air quality, hydrology, waste management, deactivation and

decommissioning, environmental justice, and cost benefit analysis are discussed in Chapter 4.

H.1 Geology, Seismology, and Soils

H.1.1 Construction

Construction activities for the proposed action would have no effects on geology or seismology

at the Savannah River Site (SRS). For example, no deep well injection of wastewater would

occur that could modify seismic activity.

The proposed facilities would be constructed entirely within F-Area on the SRS. F-Area

occupies about 160 ha (395 acres) of land within the 80,292-ha (198,400-acre) SRS. Activities

such as clearing, excavating, compacting, and grading during construction would physically

disturb a total of about 41.9 ha (103.5 acres) of land (DCS 2002). Of this disturbed area,

10.6 ha (26 acres) would be permanently altered by construction of buildings, roads, and paved

parking lots. Construction of the facilities would, therefore, disturb about 26% of the land in

F-Area (about 0.05% of the land area available at the SRS). This impact would be small and

temporary; remediation following construction would return about 60% of the disturbed land to

its original condition. The 10.6 ha (26 acres) of land permanently altered by construction would

represent about 7% of the land available in F-Area (0.01% of the land area at the SRS). 

Because the soils that would be affected by construction activities are not unique within the

SRS and the disturbed and permanently altered areas would represent a small percentage of

the land area available, physical impacts on soil would be small. 

In addition to physical disturbance, soils could be chemically impacted during construction of

the facility. For example, contaminated material from the construction site could be mobilized

by runoff water or transported by wind, and accidental releases of contaminated material could

adversely affect soils. However, because good engineering practices would be used during

construction, sediment detention basins would be constructed, and any accidental spills would
Appendix H

H-4

be promptly cleaned up as required by the DCS’s Spill Prevention Control and Countermeasures Plan, chemical impacts on soils would be small.

H.1.2 Operations

Normal operation of the proposed facilities would have no impact on geology or seismology at

the SRS (e.g., there are no planned deep well injections of effluents that could modify seismic

activity), but normal operation could have localized, minor effects on soil.

The 10.6 ha (26 acres) of land covered by buildings, roads, and parking lots (DCS 2002) would

remain physically altered. This land area would represent about 7% of the land area available

in F-Area (0.01% of the land area at the SRS). Because the soils that would be altered are not

unique within the SRS and the areas represent only a small percentage of the land available,

overall physical impacts of normal operations on soil would be localized and small.

In addition to the physical alteration of soil, soils in the vicinity of the facility could be chemically

impacted during normal operations. For example, contaminated material from the site might be

mobilized by runoff water or transported by wind. However, with the use of good engineering

practices during normal operations, chemical impacts on soils would be small.

H.2 Noise

H.2.1 Construction

Equipment and vehicle operation would be the primary sources of noise during construction. 

Soil movement, land clearing, and excavation activities typically generate noise levels in the

85- to 90-dBA range at a distance of 15 m (50 ft) from the source (EPA 1974). Noise levels

decrease 6 dB for each doubling of the distance from a point source (MPCA 2001). The

boundary closest to the proposed MOX facility site is about 8.7 km (5.4 mi) away. Thus,

construction of the proposed MOX facility would cause noise levels of about 30 to 35 dBA at the

closest boundary location. A second construction site for the PDCF and WSB would add at

most 3 dBA.

This noise estimate is likely to be an upper bound because it does not account for additional

attenuation due to noise absorption in the air and the effects of terrain and vegetation. The

33- to 38-dBA level is below the U.S. Environmental Protection Agency (EPA) guideline of

55 dBA for protection of the public and is less than the levels found along roadways around the

SRS by more than 17 dBA (Section 3.4.4). If two sound levels differ by 10 dBA or more, adding

the lower level contributes very little to the upper level. Thus potential noise impacts from

construction activities should be small at all off-site locations.
Appendix H

H-5

H.2.2 Operations

Noise sources during operation of the three facilities would include outdoor air conditioning

systems, transformers, fans, pumps, and vents for emergency and standby diesel generators. 

Noise levels from interior sources are expected to be damped to imperceptible levels outside

the proposed MOX facility buildings (DCS 2002). Employee vehicles, delivery trucks, and

material-handling equipment would also produce noise.

No measurements of noise associated with facility systems were available. As an example,

however, sound-level measurements taken during operation of a chemical weapons incinerator

in Toole, Utah, were less than 73 dBA within 30 m (100 ft) of the facility’s abatement equipment

(Andersen 2000). Noise levels decrease 6 dB for each doubling of the distance from a point

source (MPCA 2001). The closest boundary is about 8.7 km (5.4 mi) from the proposed MOX

facility. On the basis of the 73-dBA value for the Utah facility, operation of the proposed MOX

facility might result in noise levels of about 25 dBA at the closest boundary location. Operations

at the PDCF and WSB would add at most 4 dBA, giving a maximum noise impact of about

29 dBA. This estimate is likely to be an upper bound, because it does not account for additional

attenuation from absorption in the air and effects of terrain and vegetation. The 29-dBA level is

below the EPA guideline of 55 dBA for protection of the public and is more than 20 dBA less

than the noise levels occurring along roadways around the SRS (Section 3.4.4). As mentioned

above, if two sound levels differ by 10 dBA or more, adding the lower level contributes very little

to the upper level. Thus, potential noise impacts from operation of the facility should be small

at all off-site locations.

H.3 Ecology

H.3.1 Construction

H.3.1.1 Terrestrial

H.3.1.1.1 Vegetation

Impacts of facility construction to terrestrial resources would primarily result from the clearing

and grading of the land for new facilities and infrastructure. A total land area of up to 50.0 ha

(123.4 acres) would be affected by construction. About 26.2 ha (64.7 acres) would be cleared

and graded within the areas designated for the proposed facilities (see Figure H.1). These site

preparation activities would disturb 6.8 ha (16.9 acres) of pine forest, 1.4 ha (3.5 acres) of

mixed pine forest, 0.3 ha (0.8 acres) of mixed deciduous forest, 2.6 ha (6.3 acres) of upland

deciduous forest, 1.6 ha (4.0 acres) of grassland habitat, 1.1 ha (2.8 acres) of old field, 2.8 ha

(6.9 acres) of spoils, and 9.5 ha (23.5 acres) of “facility” lands. An additional 3.6 ha (8.9 acres)

would be graded around portions of the facility boundary. This grading would disturb mostly

woodland vegetation. About 11.9 ha (29.5 acres) of the area within the facility site boundaries
Appendix H

H-6

Figure H.1. Areas affected by facility construction activities.
Appendix H

H-7

would be developed with buildings, other facilities, and paving. The remainder of the areas

would be landscaped (e.g., with grass) (DCS 2002). Thus, after construction, the proposed

MOX and PDCF/WSB facility areas would be considered as part of the industrial/transportation

land cover type, as described by DOE (2000b).

The maximum of 14.7 ha (36.4 acres) of woodlands cleared for the proposed facilities would be

a comparatively small percentage of the 1,762 ha (4,350 acres) of timber harvested each year

at the SRS. Furthermore, this annual timber harvest is only about 1% of the standing volume of

commercial forest land at the SRS (DOE 2000b). 

New, widened, and realigned roadways would be required for the facilities. Most of the

roadways would be located within previously cleared road rights-of-way. However, about 2.0 ha

(5.0 acres) of new roads would be located in two areas of evergreen forest. The existing stormwater outfall and drainageways would need to be relocated. New storm-water basins would

likely be constructed southeast of the proposed MOX facility. The storm-water basin would be

located within the area cleared and graded for the proposed MOX and PDCF/WSB facilities. 

The existing 0.2-ha (0.6-acre) F-Area storm-water basin would be graded and resized to create

the new 0.6-ha (1.5-acre) MOX facility storm-water basin. Drainage from this storm-water basin

would flow toward an unnamed tributary of Upper Three Runs Creek (see Figure 3.3). This

storm-water basin would not be located within a designated wetland area. About 0.6 ha

(1.5 acres) would be disturbed for the waste pipeline to the WSB. The pipeline would be

located within the industrial/transportation land cover type. A portion of the 115-kV electric

transmission line would need to be relocated. This relocation may occur within the area

disturbed for the proposed MOX facility. Otherwise, an additional 4.5 ha (11.0 acres) may need

to be disturbed for the relocation. The area for this relocation has not been specified, but it

would probably be within upland wooded areas. Similarly, 4.0 ha (10 acres) could be disturbed

for the batch plant and less than 3.8 ha (9.5 acres) for miscellaneous utilities along the

perimeter road.

Other possible adverse construction effects to vegetation could include the localized deposition

of dust and other particulate matter from the operation of vehicles and machinery. This

deposition could inhibit photosynthesis and, if chronic, could kill affected plants. In addition, soil

compaction caused by heavy machinery could destroy the ground flora and indirectly damage

roots of trees (by reducing soil aeration and altering soil structure). These potential impacts

would be localized in the areas immediately outside the facility site boundary.

H.3.1.1.2 Wildlife

The primary construction impacts on terrestrial wildlife would result from the temporary to

permanent loss and alteration of up to 50.0 ha (123.4 acres) of habitat for the facilities and

associated infrastructure. Clearing and grading prior to actual construction would have

localized adverse effects on animal populations on the SRS. Less mobile animals (e.g., some

reptiles, amphibians, and small mammals) within the project area could be destroyed during

land-clearing operations. Before construction activities (including clearing) began, the site

would be surveyed for nests of migratory birds to ensure that such species would not be
Appendix H

H-8

affected (DCS 2002). Larger and more mobile wildlife in the area would be disturbed by these

activities and move to other available habitats.

Construction noise and human activity would cause additional impacts to wildlife. On the basis

of noise level information provided in Section H.2, construction noise levels at about 122 m

(400 ft) could still be as high as 80 dBA. This level of noise could startle or frighten birds and

small mammals (DOE 2000a). Although noise levels would be relatively low beyond this

distance, the occurrence of human activity could also displace some wildlife. Some wildlife

might be driven from the area permanently, while others might become accustomed to these

disturbances and return to the area. Generally, these disturbances would be short-term and

localized (DOE 2000a). Increased traffic could also increase the number of animals killed while

crossing roads.

Following construction, all but about 11.9 ha (29.5 acres) cleared and graded for the proposed

facilities would be landscaped (e.g., grass with scattered bushes and small trees). This

landscaping would provide habitat for some wildlife species (Mayer and Wike 1997). Clearing

of 2.0 ha (5.0 acres) of evergreen forest for roadways would eliminate a minimal amount of

wildlife habitat at the SRS. Overall, the adverse impacts of construction are expected to be

limited to the immediate project vicinity and should not affect the viability of any wildlife

populations at the SRS.

H.3.1.2 Aquatic

Construction of the facilities would eliminate a small storm-water basin located near the

southern boundary of the proposed MOX facility. This basin is shallow with little vegetation and

mostly bare shoreline, thus providing minimal value to wildlife. Its loss would not jeopardize any

species at the SRS. Additionally, this loss would be compensated for by construction of the

new storm-water basins. The new basins would potentially be a more viable aquatic habitat

than the existing storm-water basin. No direct impacts to streams (such as rerouting or

channelization) would result from facility construction. Water required for construction would be

drawn from existing groundwater wells in F-Area (Section 4.3.3.2.1). Indirect aquatic impacts

could occur if unprotected soils eroded into the unnamed tributary of Upper Three Runs Creek

that is located adjacent to the construction site. Such erosion could increase stream

sedimentation and turbidity, possibly degrading water quality and adversely affecting aquatic

organisms. However, use of standard erosion-control techniques as required by the South

Carolina Department of Health and Environmental Control (SCDHEC) would be implemented to

minimize erosion and subsequent potential increases in turbidity to the unnamed tributary of

Upper Three Runs (see Section 4.3.3.1.1).

H.3.1.3 Wetlands

Direct impacts (such as dredging or filling) to wetlands from facility construction would be small. 

Indirect impacts could occur if unprotected soils eroded into wetlands adjacent to the

construction site and adversely affected hydrological and ecological conditions there. However,
Appendix H

H-9

erosion control techniques would be implemented to prevent construction-related runoff of soils

(see Section 4.3.3.1.1). Careful attention to sediment and erosion control during site

preparation and construction would protect wetland resources near the facility site (Wike and

Nelson 2000). The impacts of construction on wetlands would be small.

H.3.1.4 Protected Species

Construction activities are not expected to have direct impacts on any of the federally listed

species on the SRS because they have not been reported to occur in the areas to be disturbed

by construction. Indirect impacts could occur to listed wildlife species from disturbance

(e.g., noise and human presence). Also, clearing would eliminate habitat that could provide

support to some of the species. In particular, the pine trees that would be removed could

provide forage habitat for the red-cockaded woodpecker. However, the pines to be removed

are a negligible portion of those present throughout the SRS. Also, the facility site is not

located within either the red-cockaded woodpecker management area or the supplemental

management area.

Transmission line rights-of-way provide suitable habitat for the smooth coneflower. Therefore,

the right-of-way for the proposed MOX facility was surveyed, and no smooth coneflowers were

observed. The U.S. Fish and Wildlife Service has concurred that the proposed action will not

affect any resources under their jurisdiction (Duncan 2001).

Implementation of standard erosion-control practices would prevent potential impacts (see

Section 4.3.3.1.1) to protected fish species (i.e., shortnose sturgeon) or wildlife species that

utilize or forage in aquatic habitats (e.g., wood stork and American alligator) in potential suitable

habitat in surface waters receiving runoff from the facility sites.

H.3.2 Operations

Within the facilities’ boundaries and in most associated infrastructure areas, vegetation would

be limited to landscaped lawns. A more diverse vegetation community (e.g., grassland/forb/

scrub-shrub land cover) would be maintained within the transmission line right-of-way.

Noise would probably be the most notable impact of routine operation of the facilities on wildlife

and would be localized to within a radius of about 61 m (200 ft) of the facility. Scrubbers and

filters would be used on the facilities, so no impacts to wildlife would be expected from airborne

releases of contaminants (DCS 2002). The presence of the facilities would increase the

potential of bird collisions with structures (Klem 1990). However, this source of bird mortality

would not cause impacts at the population level.

No liquid process effluents would be directly released by operation of the PDCF and the

proposed MOX facility. Liquid effluents would be treated at the WSB. There would be no

impacts to aquatic or wetland biota from these effluents. Storm water would be collected and

routed through the existing SRS NPDES-permitted outfall or new outfalls, and sanitary
Appendix H

H-10

wastewater would be treated in the sitewide treatment system (DCS 2002). Thus, adverse

impacts to aquatic or wetland biota would be small. Detention ponds and associated drainage

ditches would provide habitat that could support a number of wildlife species (Mayer and Wike

1997).

No adverse impacts to protected species would be expected from facility operations because of

the suitable habitats and minimal facility releases to the environment. Habitat suitable for the

smooth coneflower would develop within the rerouted segment of the transmission line right-ofway, but the potential for a population of that plant to develop in this area is remote.

H.4 Land Use

H.4.1 Construction

Up to 50 ha (123.4 acres) of F-Area would be disturbed during construction of the facilities. 

Land use of the entire F-Area at the SRS, including the areas of proposed construction for the

facilities, is classified as developed/industrial. Thus, the proposed use of the project area is

consistent with this classification and with the SRS Long Range Comprehensive Plan

(DOE 2000b). No adverse effect to land use would result from construction of the facilities.

H.4.2 Operations

The proposed facilities are industrial, and their operation would be consistent with the

classification of the F-Area land use as developed/industrial. Therefore, there would be no

adverse effect to land use as a result of routine operation of the facilities.

H.5 Cultural and Paleontological Resources

H.5.1 Construction

H.5.1.1 Archaeological Resources

Construction of the proposed facilities would directly affect two prehistoric archaeological sites

that are eligible for listing on the National Register of Historic Places (NRHP)

(Sites 38AK546/547 and 38AK757). Data recovery plans detailing the proposed mitigation for

the adverse impacts to Sites 38AK546/547 and 38AK757 have been prepared and accepted by

the South Carolina State Historic Preservation Office (SCSHPO) (Gould 2001; Marcil 2001).

Site 38AK546/547 was excavated according to the data recovery plan to mitigate the adverse

effects to that site from construction of the proposed MOX facility. Data recovery for Site
Appendix H

H-11

38AK546/547 was completed April 19, 2002. Site 38AK757 was excavated according to its

data recovery plan to mitigate the adverse effect to that site from construction of the PDCF. 

Data recovery for Site 38AK757 was completed September 15, 2002. Monitoring of fill removal

on the sites during construction is also expected to occur as part of the planned mitigation

(Gould 2002). Concurrence of the SCSHPO that these investigations have met the obligations

set forth in the data recovery plans was provided in November 2002 (Long 2002).

Five additional eligible sites are located in the vicinity of the construction area (Sites 38AK106,

38AK155, 38AK563, 38AK564, and 38AK581), but no direct impacts to these sites are

expected as a result of facility construction. Mitigation measures might be needed to avoid the

possibility of indirect effects to these sites. Such measures could include conducting

awareness training for workers so they would not inadvertently disturb the sites and possibly

imposing restrictions regarding where heavy machinery is allowed. Mitigation might also

include periodic monitoring to check for possible erosion caused by surface runoff during

construction or evidence of other impacts resulting from an increase in F-Area activities

(e.g., unauthorized pedestrian or vehicular activity at the archaeological sites). The potential

exists for erosion to occur along the current drainage at the outfall east-northeast of the

proposed facilities that may affect eligible sites (38AK106, 38AK563, and 38AK564). Minor

erosion potential at another small drainage may affect Site 38AK581. Although direct impacts

are not expected to Site 38AK155, the site is located very near an area previously identified as

grading area for the proposed MOX facility. Depending on the final footprint of the grading and

fill area for the proposed MOX facility, Site 38AK155 may require monitoring to ensure

avoidance of the site to prevent any direct or indirect impacts from construction activities. An

updated contour map of the proposed grading area was not available at the time this EIS was

being prepared. A memorandum of agreement with the SCSHPO stipulating avoidance of the

site and how it is to be implemented could be required. Specific mitigation measures would be

determined in consultation with the SCSHPO.

H.5.1.2 Historic Structures

No structures are located in the facility project area; therefore, no impacts to historic structures

would occur during the construction of the facilities.

H.5.1.3 Traditional Cultural Properties

No traditional cultural properties have been identified near the proposed facilities. Consultation

with appropriate Native American groups has been initiated to request information on any

concerns regarding the potential for the MOX facility to affect traditional cultural properties. 

Copies of the consultation letters are presented in Appendix B.
Appendix H

H-12

H.5.1.4 Paleontological Resources

No fossil-bearing strata are known to exist within the F-Area; therefore, no impacts to

paleontological resources are expected during construction.

H.5.2 Operations

Archaeological resources are unlikely to be affected by routine operation of the facilities. 

Ground disturbance and outdoor activities outside of the original construction footprint are not

part of routine operations.

Traditional cultural properties and paleontological resources are not known to be present in

F-Area, and, thus, none would be affected during routine facility operations.

H.6 Infrastructure

H.6.1 Construction

Construction activities are not expected to adversely impact current SRS infrastructure. The

maximum water and electrical power demands during construction of the facilities were

estimated by DOE in the Surplus Plutonium Disposition Environmental Impact Statement

(SPD EIS) (DOE 1999) and by DCS (DCS 2002). Electrical power needed during construction

of the facilities is estimated to be 17,700 MWh/yr. This power represents only about 3.7% of

the current electrical power available (482,700 MWh/yr) at the SRS (DOE 1999). Maximum

water requirements are not projected to exceed 139 million L/yr (37 million gal/yr), or about

3.3% of the A-Area loop excess capacity.

No new off-site roads would be constructed or improved to bring construction materials or

workers to the SRS from local communities. An additional 4.8 to 6.4 km (3 to 4 mi) of roadways

would be necessary to support facility construction activities within the F-Area.

The existing SRS road network plus the additional roads in F-Area needed for construction site

access can readily accommodate the additional traffic expected during construction of the

facilities. Some workers are expected to carpool during construction. During peak construction

and assuming all three facilities are constructed simultaneously, the increase in the number of

average daily one-way traffic on the roads leading to F-Area is expected to be about 30%.

The total diesel fuel required for a 5-year construction period is estimated to be about

7,624,000 L (1,960,000 gal). On-site storage of this volume of fuel is not anticipated because

the majority of diesel fuel would be used in construction equipment that would likely be refueled

each day by tanker trucks.
Appendix H

H-13

The surplus plutonium disposition program at the SRS would require a coordinated upgrading

of the infrastructure to support the proposed MOX facility, the PDCF, and the WSB (DCS

2002). A storm-water retention pond and a sedimentation basin will be developed to handle

runoff from all three of these facilities that are planned to be constructed in the same general

vicinity within the F-Area.

H.6.2 Operations

The SRS infrastructure would not be adversely affected by operations of the proposed facilities. 

Infrastructure for the facilities would be modified and upgraded before and during construction

to accommodate operational needs. Electrical power required during operation of the proposed

facilities is estimated to be 186,000 MWh/yr, or about 36.4% of the available electrical capacity

in the F-Area (DCS 2002).

Service and process water usage in the F-Area is currently about 374 million L/yr

(98.8 million gal/yr) (DCS 2002). The available capacity is 4.2 billion L/yr (1.1 billion gal/yr), 

and the annual water demand for facility operations would be about 76 million L/yr

(20.1 million gal/yr). Water needs for the proposed facilities would represent about 2% of the

excess A-Area loop capacity.

Fuel oil would be used to test the diesel generators that would provide emergency power for

operations in the event of a failure of the electrical supply system. An estimated 430,100 L/yr

(179,000 gal/yr) of diesel fuel would be needed for generator testing (DCS 2002; DOE 1999).

The traffic from 510 permanent workers traveling to and from the facility might cause some

impacts during peak travel periods. Local roads providing access to the SRS and on-site

roadways experience traffic congestion during peak commuter periods. If individuals elect to

participate in carpools, the impact on traffic flow and volume would tend to be reduced.

H.7 Socioeconomics

H.7.1 Construction

This section discusses the potential socioeconomic consequences from constructing the

proposed MOX facility, PDCF, and WSB at the SRS. The socioeconomic analysis includes the

effects on employment, income, and regional growth in a 15-county regional economic area

(REA) and on population, housing, and community resources in a 4-county region of influence

(ROI). Impacts on traffic are provided for the road network in the vicinity of the SRS in Aiken

County. Impacts from construction are summarized in Table H.1.

In addition to the impacts shown in the table, minor impacts would also occur to agriculture in

the REA and commercial fishing downstream of the SRS as demand for the products of these 
Appendix H

H-14

Table H.1. Effects of construction on socioeconomicsa

Impact category Impacts

Employment (number of jobs in REA)b

 Direct 1,010

 Indirect 810

 Total 1,820

Income (millions of 2003 $)

 Direct 51.0

 Indirect 40.9

 Total 91.9

Population (number of new ROI residents) 350

Housing (number of ROI units required) 130

Public Finances (% impact on fiscal balance)

 Cities in ROIc <1

 Counties in ROId <1

 Schools in ROIe <1

Public service employment (number of new employees in ROI)

 Police officers 1

 Firefighters 0

 General 2

 Physicians 1

 Teachers 1

Number of new staffed hospital beds in the ROI 1

Traffic (impact on current levels of service in Aiken County) None

a

Impacts are shown for the peak year of construction (2005).

b

Employment data based on DCS (2002) and NNSA (2002).

c

Includes impacts that would occur in the South Carolina cities of Aiken,

Jackson, New Ellenton, North Augusta, Wagener, Barnwell, Blackville,

Williston and the Georgia cities of Grovetown, Harlem, Augusta, Blythe,

and Hephzibah.

d

Includes impacts that would occur in Aiken and Barnwell Counties in

South Carolina and in Columbia and Richmond Counties in Georgia. 

e

Includes impacts that would occur in Aiken County, Barnwell

County #19, #29, #45, Columbia County, and Richmond County school

districts.
Appendix H

H-15

industries increases with the growth in REA payroll and salary expenditures resulting from the

construction of the facilities.

The potential socioeconomic impacts from constructing the facilities would be relatively small. 

Construction activities would create direct employment of approximately 1,010 people in the

peak construction year and an additional 810 indirect jobs in the REA (see Table H.1). 

Construction activities would increase the annual average employment growth rate by less than

0.1 of a percentage point over the duration of construction. Facility employment and associated

wages and salaries would also produce about $88 million of income in the peak year of

construction.

In the peak year of construction, about 350 people would move to the ROI (in-migrate)

(see Table H.1). However, in-migration would have only a marginal effect on population growth

and would require only 2% of the vacant rental housing in the ROI during the peak year. No

significant impact on public finances would occur as a result of in-migration, and five

additional local public service employees would be required to maintain existing levels of

service in the various local public service jurisdictions in the ROI. In addition, on-site employee

commuting patterns would have no impact on levels of service in the local transportation

network surrounding the site.

H.7.2 Operations

This section presents the potential socioeconomic consequences from operating the proposed

facilities at the SRS. As for the construction evaluation, the socioeconomic analysis for

operations covers the effects on employment, income, and regional growth in the 15-county

REA and on population, housing, and community resources in the four-county ROI. Impacts on

traffic are provided for the road network in the vicinity of the SRS in Aiken County. Impacts

from operation are summarized in Table H.2.

In addition to the impacts shown in the table, insignificant impacts would also occur to

agriculture in the REA and commercial fishing downstream of the SRS as demand for the

products of these industries increases with the growth in REA payroll and salary expenditures

resulting from the operation of the facilities. 

The potential socioeconomic impacts from operating the facilities would be relatively small. 

Operational activities would create about 490 direct jobs annually and an additional 780 indirect

jobs in the REA (see Table H.2). The facilities would produce $64 million in direct and indirect

income annually during operations.

About 180 people would move to the area at the beginning of facility operation (see Table H.2). 

However, in-migration would have only a marginal effect on population growth and would

require less than 1% of the vacant owner-occupied housing in the area during facility

operations. No significant impact on public finances would occur as a result of in-migration,

and two new local public service employees would be required to maintain existing levels of

service in the various local public service jurisdictions in the ROI. In addition, on-site employee 
Appendix H

H-16

Table H.2. Effects of operations on socioeconomicsa

Impact factor Impacts

Employment (number of jobs in REA)b

 Direct 490

 Indirect 780

 Total 1,270

Income (millions of 2003 $)

 Direct 24.6

 Indirect 39.6

 Total 64.2

Population (number of new ROI residents) 180

Housing (number of ROI units required) 70

Public finances (% impact on fiscal balance)

 Cities in ROIc <1

 Counties in ROId <1

 Schools in ROIe <1

Public service employment (number of new employees in ROI)

 Police officers 0

 Firefighters 0

 General 1

 Physicians 0

 Teachers 1

Number of new staffed hospital beds in the ROI 0

Traffic (impact on current levels of service in Aiken County) None

a

Impacts are shown for the first year of operations (2008).

b

Employment data taken from DCS (2002).

c

Includes impacts that would occur in the South Carolina cities of Aiken,

Jackson, New Ellenton, North Augusta, Wagener, Barnwell, Blackville,

Williston and the Georgia cities of Grovetown, Harlem, Augusta, Blythe and

Hephzibah.

d

Includes impacts that would occur in Aiken and Barnwell Counties in

South Carolina, and in Columbia and Richmond Counties in Georgia.

e

Includes impacts that would occur in Aiken County, Barnwell County

#19, #29, #45, Columbia County, and Richmond County school districts.
Appendix H

H-17

commuting patterns would have no impact on levels of service in the local transportation

network surrounding the site.

Any impacts that would occur with the transportation of MOX fuel, including impacts on property

values, would be minimal. This conclusion is reached because it is likely that the current

transportation of other hazardous materials and the risk of accidents involving those materials

are already captured in housing values in the vicinity of transportation routes. An accident

involving MOX fuel may only create significant additional impacts on the housing market if

residents were prevented from quickly returning to their homes.

H.8 Aesthetics

H.8.1 Construction

During construction of the proposed facilities, large construction cranes and fugitive dust

produced by earthmoving equipment may be visible to the general public from the nearest

publicly accessible viewpoint, located on State Highway 125 and SRS Road 1, both more than

6.5 km (4 mi) away. Once the proposed facilities were constructed, however, the height, size,

and appearance of the new structures would be similar to existing buildings adjacent to the

F-Area site and would therefore maintain the industrial nature of F-Area and be consistent with

the current VRM Class IV designation of the site. The newly constructed facilities themselves

would not generally be visible from off-site, with visibility restricted by the undulating terrain and

the forested nature of the landscape.

H.8.2 Operations

During operations, it is unlikely that any additional visual impacts would occur beyond those

resulting from the presence of the facilities. Exhaust stacks located on or near the proposed

facilities would not generally be visible to members of the public because of the undulating,

forested nature of the landscape. While any emissions from these stacks, as well as other

evidence of operations at each facility (such as area lighting), might be visible from the nearest

viewing point, these aspects of facility operation would be some distance away and therefore

would not affect the current VRM Class IV designation of the site.
Appendix H

H-18

H.9 Accident Impacts

H.9.1 Geology, Seismology, and Soils

Accidental releases of contaminated material might adversely affect soils. However, use of

good engineering practices and implementation of appropriate cleanup procedures following the

accident would result in small chemical impacts on soils.

H.9.2 Ecology

An operational accident at the facility could potentially impact biota in natural plant communities

and streams near the facility. The degree to which impacts would occur would depend on the

type of accident, kind and amount of contaminants released, and wind direction at the time of

release. Natural areas likely to experience the greatest impact would be those located

immediately north and northeast of the facility. Prompt action to clean up or otherwise mitigate

contaminants released during an accident would reduce the likelihood of contaminant

bioaccumulation and biomagnification in the food chain. No protected species are known to

occur within these areas (see Section 3.5.4 and Appendix A).

H.9.3 Land Use

An operational accident at the facility would be unlikely to affect land use within the F-Area, the

SRS, or the region. The entire F-Area would remain developed/industrial land use if an

operational accident were to occur. Access to the area might be temporarily restricted during

cleanup operations following an accident. Minor impacts to lands outside of the SRS might be

anticipated in the event of a worst-case accident, but most impacts would remain within the

SRS boundary. Future use of the central portion of the SRS, which includes the F-Area, is

expected to be maintained by the federal government as industrial (DOE 2000b).

H.9.4 Cultural and Paleontological Resources

An operational accident at the facilities might affect significant archaeological resources in the

vicinity of the project area by restricting access to sites that currently require regular monitoring. 

This impact would likely be temporary, depending on the duration of cleanup after the accident.

It is possible that important nuclear production facilities that have historic value related to

events during the Cold War could be temporarily affected during an operational accident. It is

also possible that traditional plant resources of concern to Native Americans could be affected

during an operational accident. No other traditional cultural properties that could be affected

have been identified to date but may be identified as a result of the ongoing consultation.

Paleontological resources are unlikely to be affected by an operational accident at the facilities.
Appendix H

H-19

H.9.5 Socioeconomics

An operational accident at the facilities could impact the workforce if the accident was severe

enough to result in lost work time. The extent of impacts to the local economy would depend on

employment income losses during closure of the facilities following an accident. An accident

involving fresh MOX fuel during transport might create significant additional impacts on the

housing market only if residents were evacuated and prevented from quickly returning to their

homes.

H.10 References for Appendix H

Andersen, P. 2000. Personal communication from Andersen (EG&G, Toole, UT) to

Y.-S. Chang (Argonne National Laboratory, Argonne, IL). Oct. 4.

DCS (Duke Cogema Stone & Webster) 2002. Mixed Oxide Fuel Fabrication Facility

Environmental Report, Revision 1 & 2. Docket Number 070-03098. Charlotte, NC.

DCS 2004. Mixed Oxide Fuel Fabrication Facility Environmental Report, Revision 5. Docket

Number 070-03098. Charlotte, NC. June 10.

DOE (U.S. Department of Energy) 1999. Surplus Plutonium Disposition Final Environmental

Statement. DOE/EIS-0283. Office of Fissile Materials Disposition, Washington, DC. 

Nov.

DOE 2000a. Savannah River Site High-Level Waste Tank Closure Draft Environmental Impact

Statement. DOE/EIS-0303D. Savannah River Operations Office, Aiken, SC. Nov.

DOE 2000b. Savannah River Site Long Range Comprehensive Plan. Savannah River Site,

Aiken, SC. Dec.

Duncan, L. 2001. Letter from Duncan (U.S. Fish and Wildlife Service, Charleston, SC) to 

A.B. Gould (U.S. Department of Energy, Aiken, SC), June 30.

EPA (U.S. Environmental Protection Agency) 1974. Information on Levels of Environmental

Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of

Safety. EPA-550/9-74-004. Washington, DC.

Gould, A.B. 2001. Letter from Gould (Director, Environmental Quality Management Division,

DOE, Savannah River Operations Office, Aiken, SC) to N. Brock (Review and

Compliance Coordinator, South Carolina Department of Archives and History, Columbia,

SC). March 12.

Gould, A.B. 2002. Letter from Gould (Director, Environmental Quality Management Division,

DOE, Savannah River Operations Office, Aiken, SC) to C. Long (South Carolina State

Historic Preservation Office, Columbia, SC). Oct. 24.

Klem, D., Jr. 1990. “Collisions between Birds and Windows: Mortality and Prevention.” Journal

of Field Ornithology 6(1):120-128.

Long, C.C. 2002. Letter from Long (South Carolina State Historic Preservation Office,

Columbia, SC) to A.B. Gould (Director, Environmental Quality Division, DOE, Savannah

River Operations Office, Aiken, SC). Nov. 21.

Marcil, V. 2001. Letter from Marcil (Staff Archaeologist, South Carolina State Historic

Preservation Office, Columbia, SC) to A.B. Gould (Director, Environmental Quality

Management Division, DOE, Savannah River Site, Aiken, SC). April 11.
Appendix H

H-20

Mayer, J.J., and L.D. Wike 1997. SRS Urban Wildlife: Environmental Information Document.

WSRC-TR-97-0093. Westinghouse Savannah River Company, Savannah River Site,

Aiken, SC. May.

MPCA (Minnesota Pollution Control Agency) 2001. An Introduction to Sound Basics. Available

at http://www.honoise.org/sndbasic/sndbasic.htm.

NNSA (National Nuclear Safety Administration) 2002. Report to Congress: Disposition of

Surplus Defense Plutonium at Savannah River Site. Office of Fissile Materials

Disposition, Washington, DC. Feb.

Wike, L.D., and E.A. Nelson 2000. Memo from Wike and Nelson to J.S. Roberts 

(Westinghouse Savannah River Company, Aiken, SC). March. 30.
Appendix I

I-1

APPENDIX I:

SCOPING SUMMARY REPORT
Appendix I

I-2

 
Appendix I

I-3
Appendix I

I-4
Appendix I

I-5

TABLE OF CONTENTS

ABBREVIATIONS ...................................................... 6

1. INTRODUCTION ............................................... 7

2. SCOPING COMMENT SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.1 INTRODUCTION ............................................... 9

2.2 SUMMARY of COMMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.2.1 NEPA Issues .......................................... 9

2.2.2 Policy Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

2.2.3 Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

2.2.4 Ecology, Air, and Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

2.2.5 Cultural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

2.2.6 Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

2.2.7 Human Health Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

2.2.8 MOX Fuel Processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

2.2.9 Transportation Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

2.2.10 Waste Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2.2.11 Socioeconomics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2.2.12 Security and Terrorism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.2.13 Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.2.14 Decommissioning vs. Deactivation . . . . . . . . . . . . . . . . . . . . . . . . . . 21

2.2.15 SRS Infrastructure and Existing Conditions . . . . . . . . . . . . . . . . . . . 21

2.2.16 Reactor Use Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

2.2.17 Lead Test Assemblies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

3. SCOPE OF THE EIS AND SUMMARY OF ISSUES TO BE ADDRESSED . . . 23

4. ISSUES CONSIDERED PERIPHERAL, OUTSIDE THE SCOPE OF

THE PROPOSED ACTION, OR COVERED BY PRIOR ENVIRONMENTAL

REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

4.1 PREVIOUS DOE DECISIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

4.2 INTERNATIONAL AGREEMENTS AND NATIONAL, STATE, OR

LOCAL LAWS, STATUTES, AND REGULATIONS . . . . . . . . . . . . . . . . . . . . . 28

4.3 REACTOR USE OF MOX FUEL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

4.4 COST AND READINESS TO RESPOND TO EMERGENCIES . . . . . . . . . . . . 29

4.5 POTENTIAL DELAYS IN DOE PROGRAMS . . . . . . . . . . . . . . . . . . . . . . . . . 29

4.6 IMPACTS FROM TERRORISM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

4.7 IMPACTS OF ACTIONS IN THE RUSSIAN FEDERATION . . . . . . . . . . . . . . 29

4.8 PROPRIETARY INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Attachment A

Preliminary Outline for the Mixed Oxide Fuel Fabrication Facility EIS . . . . . . . . . . . 31
Appendix I

I-6

ABBREVIATIONS

ADAMS Agency wide Document Access and Management System

CAR Construction Authorization Request 

DCS Duke Cogema Stone & Webster 

DOE U.S. Department of Energy 

EIS Environmental Impact Statement

EPA U.S. Environmental Protection Agency

ER Environmental Report 

H&S human health and safety 

HEPA high-energy particulate air

HLW high-level (radioactive) waste 

MINATOM Ministry for Atomic Energy of the Russian Federation

MOX mixed oxide

MOX FFF Mixed Oxide Fuel Fabrication Facility 

MT metric tons

NEPA National Environmental Policy Act 

NAACP National Association for the Advancement of Colored People

NMSS Nuclear Material Safety and Safeguards (part of the Nuclear Regulatory

Commission)

NRC U.S. Nuclear Regulatory Commission

NOI Notice of Intent

ROD Record of Decision 

SER Safety Evaluation Report 

SPD surplus plutonium disposition 

SRS Savannah River Site 

YMP Yucca Mountain Project
Appendix I

I-7

1. INTRODUCTION

On March 7, 2001, the United States Nuclear Regulatory Commission (NRC) issued a notice of

intent (NOI) in the Federal Register (66 FR 13794) to prepare an environmental impact

statement (EIS). As indicated in the NOI, the proposed major federal action requiring the EIS is

the construction and operation of a mixed oxide (MOX) fuel fabrication facility (MOX FFF) at the

Savannah River Site (SRS) near Aiken, South Carolina. If authorized under the requirements

of 10 CFR Part 70, Duke Cogema Stone & Webster (DCS), a contractor chosen by the United

States Department of Energy (DOE), would build and operate the proposed MOX FFF. The

EIS will examine the potential environmental impacts of manufacturing MOX fuel from surplus

weapons-grade plutonium. The potential impacts associated with processing 36.4 tons

(33 metric tons (MT)) of this surplus plutonium will be evaluated. The evaluation of these

impacts will be based on the proposed maximum annual MOX FFF capacity of 3.5 MT.

Under the present technical review schedule, the EIS will be used to support a decision in 2002

by the NRC whether or not to authorize construction of the proposed MOX FFF. The current

schedule is to publish the draft EIS in February 2002. Following a public comment period, the

draft EIS would be revised, and a final EIS would be published in September 2002. No

cooperating agencies have been identified during the scoping process. NRC, as the lead

agency, will prepare the EIS with the assistance of Argonne National Laboratory. 

In addition to the EIS for the MOX FFF, NRC will prepare two safety evaluation reports (SERs)

on health and safety issues raised by the proposed action. The first SER will evaluate such

issues raised by the construction authorization request submitted by DCS in February 2001. A

second SER will evaluate health and safety issues raised by the DCS request for authority to

operate the proposed MOX FFF, which DCS plans to submit in July of 2002. The SERs

document our evaluation of the safety of DCS’s applications and compliance with applicable

regulations. As discussed later in Section 3, the EIS will analyze both construction and

operation impacts.

In the NOI, NRC announced plans for two scoping meetings: one in North Augusta, South

Carolina, on April 17, 2001, and another scoping meeting in Savannah, Georgia, on April 18,

2001. In a second Federal Register notice on April 11, 2001 (66 FR 18223), NRC announced

that a third scoping meeting would be held in Charlotte, North Carolina, on May 8, 2001.

Announcements of the meetings were also made on the World Wide Web at the NRC MOX

FFF Information Home Page, (http://www.nrc.gov/NRC/NMSS/MOX), through an electronic

newsletter, through radio advertisements, through press releases, and through direct mailing to

individuals who had attended past meetings associated with MOX. Announcements of the

meetings were also made in the following local newspapers:

• The Augusta Chronicle (Thursday, April 12, & Sunday, April 15 )

• Aiken Standard (Thursday, April 12, & Sunday, April 15)

• North Augusta Star (Thursday, April 12, & Sunday, April 15)

• Savannah Morning News (Thursday, April 12, & Sunday, April 15)

• The State News, Columbia, SC (Sunday, May 6)

• The Charlotte Observer (Sunday, May 6)
Appendix I

I-8

The three scoping meetings were held as planned. At each meeting, the NRC staff distributed

background materials on the MOX fuel program and NRC’s plans for conducting licensing and

environmental reviews for the MOX FFF. An open house held before each meeting provided

attendees an opportunity to view informational materials and talk informally with NRC staff.

During the meeting, the NRC staff presented an overview of NRC’S role in the MOX FFF

licensing process and described NRC’S approach to meeting its obligations under the National

Environmental Policy Act (NEPA). The presentations were followed by a question and answer

period in which the NRC staff responded to questions from attendees. The majority of time at

the meetings was devoted to allowing individuals to express their views on the scope of the EIS.

Transcripts of the meetings can be viewed on the World Wide Web at the NRC MOX FFF

Information Homepage (http://www.nrc.gov/NRC/NMSS/MOX). 

A total of about 300 individuals attended the three scoping meetings, and about 80 of them

asked questions or provided oral comments at the meetings. In addition, approximately

60 individuals or organizations submitted written comments to NRC by regular mail, fax

transmittal, e-mail, or in person at the meetings. Some of the individuals who provided written

comments also spoke at the meetings. Some individuals attended and offered comments at

more than one meeting.

The public comments are discussed in Section 2 of this summary. All comments received

through May 21, 2001, the date announced in the NOI for closing of the scoping period, were

considered. Comments received after this date were considered to the extent possible in

preparing this report. The comments have been categorized by subject under the following

issue headings:

• NEPA Issues

• Policy Issues

• Alternatives

• Ecology, Air and Water

• Cultural Resources

• Cumulative Impacts

• Human Health Impacts

• MOX Fuel Processing

• Transportation Issues

• Waste Management

• Socioeconomics

• Security and Terrorism

• Environmental Justice

• Decommissioning vs. Deactivation

• SRS Infrastructure and Existing Conditions

• Reactor Use Issues

• Lead Test Assemblies

The scope of the EIS and summary of issues that will be addressed in the EIS are discussed in

Section 3. Although issues raised during the scoping period will be considered in the

preparation of the MOX FFF EIS, some of those issues will either be analyzed in less detail or

will not be analyzed at all, depending on their relevance to the proposed action and the

anticipated impacts. Issues that will be considered, but not analyzed in detail, are summarized

in Section 4. The preliminary outline for the EIS is included as Attachment A. 
Appendix I

I-9

2. SCOPING COMMENT SUMMARY

2.1 INTRODUCTION 

Several commenters voiced their support for the MOX fuel option, stating that it was the best

option for using excess plutonium. They cited the commercial MOX reactors in Europe along

with an experimental MOX program in the United States as evidence that MOX technology is

both safe and feasible. They also believed that converting the plutonium to MOX fuel would

make it more difficult to recover the plutonium for future use in nuclear weapons than if it were

disposed of by immobilization (i.e., conversion of surplus plutonium into plutonium oxide and

then into a ceramic or glass form suitable for disposal in a geologic repository). These

commenters also supported the SRS as the best location for the MOX FFF, citing experience,

expertise, and existing infrastructure. 

Although they were in favor of reducing quantities of weapons-grade plutonium, other

commenters felt that the MOX program was not the best method for addressing nonproliferation. These commenters preferred immobilization or continued storage to the MOX

alternative. These commenters believed that immobilization would offer the greatest deterrent

to terrorism and felt that proceeding with the MOX project would lead to widespread

reprocessing of spent nuclear fuel. Several commenters voiced their opposition to the project,

but did not provide any basis or provide comments on the scope of the EIS. 

Several commenters had specific questions or comments on the Environmental Report (ER)

and Construction Authorization Request (CAR) prepared by DCS. These comments will be

considered in NRC’s review of the ER and in the preparation of the EIS and Safety Evaluation

Report (SER).

The following summary groups the comments received during the scoping period, both at

scoping meetings and through written submittals to the NRC, by technical area and issue.

2.2 SUMMARY of COMMENTS

2.2.1 NEPA Issues

Consideration of Reactor Use Impacts: A few people commented that NRC should limit the

scope of the MOX FFF EIS to the environmental impacts of constructing, operating, and

deactivating the MOX FFF. They believed that analyzing impacts of the reactors using the MOX

fuel as part of the current MOX FFF EIS would create a “double jeopardy” for DCS in that the

company would have to provide data twice: now for MOX FFF licensing and again during the

license amendment process for the reactors in which the fuel was to be used. One commenter

noted that in order to avoid being accused of segmentation (not looking at the full

consequences of an action) the EIS must include reactor impacts in its analysis. Several

commenters wanted a supplemental EIS to be prepared for the reactor sites if reactor impacts

are not addressed in the MOX FFF EIS. Further discussion of reactor use impacts is provided

in Section 2.2.16.

NEPA Coverage for Actions in a Foreign Country: A few commenters believed that the link

between the U.S. and Russian programs is so strong that, under NEPA, the United States

would be obligated to consider environmental impacts of MOX in Russia. One organization

indicated that there was a precedent for conducting a NEPA analysis for a major federal action
Appendix I

I-10

having a significant impact in a foreign country. (No specific example was provided.) Another

commenter stated that environmental impacts occurring outside the United States and within

the borders of a sovereign nation are outside the scope of NEPA.

Supplemental EIS: Several commenters thought that DOE’s Surplus Plutonium Disposition

(SPD) EIS should be supplemented. They contended that the original EIS did not adequately

address the need for the action and the alternatives and that DOE did not conduct an adequate

life-cycle analysis of the all-MOX option and the all immobilization option. They maintained that

if DOE does not prepare a supplemental EIS, NRC needs to evaluate the full range of

alternatives related to the MOX program. 

Proprietary Information: A few commenters wanted NRC to evaluate the harm to the public

caused by withholding information labeled proprietary. They claimed that there was not enough

technical information to adequately evaluate the CAR, especially with respect to health and

safety. For example, a complete list of source terms was not available. They would also like to

examine the types of information that can be categorized as proprietary.

Use of Existing DOE Documentation and Decisions: A few commenters wanted NRC to

make full use of environmental documentation already prepared by DOE and avoid reevaluation 

of issues where DOE has already made a decision. This position includes adopting the DOE

decision that the need for the MOX FFF has been established. 

Additional Scoping Meetings: Several commenters asked for additional scoping meetings: 

at reactor sites, along transportation routes, and specifically at Columbia, South Carolina. In

addition, several commenters asked that the scoping period be extended beyond the May 21

deadline. 

Communicating Information to the Public: A number of people commented on NRC’s efforts

to communicate information to the public. There were complaints that ADAMS (Agency wide

Document Access and Management System), the system that NRC uses for viewing

documents, is not user friendly and that since it was implemented the local public reading

rooms at nuclear power plants were eliminated. These commenters felt NRC should provide a

computer at the NRC reading room and that the CAR and ER should be made available free of

charge. One commenter asked for more informational meetings before the draft EIS is issued. 

Another commenter wanted NRC to indicate how it will handle distribution of MOX information

to the public in the future. A request was made for NRC and DCS to define terms such as

“highly unlikely” and “unlikely” and to involve the public in determining the appropriateness of

these definitions.

2.2.2 Policy Issues

Price Anderson: The Price-Anderson Act limits the liability of organizations in the event of an

incident involving nuclear materials. A commenter asked NRC to put a license condition on the 

MOX fuel project that MOX fuel cannot be covered by Price-Anderson. A commenter wanted

the EIS to include a full disclosure of who is legally (and financially) responsible for MOX fuel

accidents, including transportation impacts and reactor accidents.

NRC’s Role as Lead Agency: A commenter stated that NRC was too closely tied to the

nuclear power industry to impartially evaluate the plutonium fuel project. A commenter stated

the belief that NRC receives funding from this regulated community and, at times, acts as an
Appendix I

I-11

advocate for nuclear power. A commenter asked that NRC support an independent review of

DOE’s plutonium work, as recommended by the National Research Council in March 1988.

NRC Experience and Precedent: Several commenters thought that NRC was not qualified to

regulate and oversee weapons-grade plutonium. They contended that there is no precedent for

NRC to analyze reactor impacts as part of a licensing action for a fuel fabrication facility. 

Conflict of Interest: A few commenters expressed concern that NRC may not be sufficiently

independent from DOE to review the DCS application. Another commenter asked if using

Argonne National Laboratory (a DOE Laboratory) as the contractor preparing the NRC EIS

represented a conflict of interest.

Agency Interactions: Some commenters thought that the interactions of NRC, DOE, SRS,

and DCS should be considered, particularly in terms of their regulatory roles. One commenter

thought the EIS should address the question of who owns the MOX fuel at each stage of the

process. Commenters were particularly concerned because both DOE and NRC have

regulatory roles related to waste disposal. A commenter wanted to know which agency would

have jurisdiction over the waste at each stage of the MOX process. Another commenter stated

that the commercial and military nuclear waste materials should remain separate.

Non-Proliferation: A comment was made that the United States should reevaluate its nonproliferation agreement with Russia. A commenter argued that MINATOM (Ministry for Atomic

Energy of the Russian Federation) intends to take money from the United States and other

western countries and build a plutonium fuel infrastructure and export plutonium fuel.

Another commenter thought that the EIS should consider the proliferation impacts of

constructing a MOX FFF, which (according to the commenter) violates a long-standing

U.S. policy of separating civilian use and military applications of nuclear technology. According

to this commenter, MOX would encourage other countries to develop reprocessing, which

would have serious non-proliferation consequences. The possible use of the .polishing. portion

of the facility for missions other than purifying plutonium for MOX use was also a concern.

Savannah River Site (SRS) Cleanup Funds: Some commenters wanted the EIS to consider

the impacts of recent cuts in cleanup and restoration funds to the SRS. One commenter

viewed this as the transfer of funds from the SRS cleanup to plutonium production. 

Changes in Project Direction: Some commenters wanted the EIS to consider the impacts

that would result if the proposed pit disassembly facility was canceled in favor of using existing

infrastructure at the SRS. Another commenter felt that this issue had been adequately explored

in the DOE SPD EIS and that NRC should be limited to evaluating the cumulative impacts of

this related action.

A commenter asked that the EIS consider the impacts of building a MOX facility and then

indefinitely suspending or canceling its use if the Russian political situation changes. Another

commenter wanted the EIS to determine the cost of the MOX project if the Russian program

were canceled.

Some commenters wanted the EIS to assess the impacts on the MOX program caused by

delaying immobilization, in particular the impacts of indefinitely storing the plutonium. 

Commenters were also concerned that delaying or canceling the immobilization project could

lead to greater quantities of MOX fuel.
Appendix I

I-12

A commenter thought the EIS should consider the environmental impacts of new reprocessing

missions at the SRS that could be triggered by the MOX project. A commenter noted that

commercial reprocessing is proposed in legislation in Congress and that the current ban is

being reviewed by the Bush administration.

International Implications/Treaties: A commenter pointed out that there were several

international treaties that must be identified and analyzed for impacts of MOX

commercialization in the United States, including the Nuclear Non-Proliferation Treaty of 1968,

the Stockholm Declaration on the Human Environment, and the Law of the Sea Convention. 

2.2.3 Alternatives

No-action - Continued Storage: Some commenters wanted NRC to fully develop and

advance the No-action Alternative. They pointed out that the Bush administration has

questioned the U.S. government’s commitment to a dual track approach to plutonium

disposition and that it is not clear that the MOX program will go forward in Russia. 

Furthermore, the immobilization program has been postponed. Given this situation, the MOX

program could be subject to continued review, making status quo (continued storage) a likely

No-action Alternative. Therefore, some commenters wanted the EIS to consider the

implications of the SRS becoming a long-term storage facility for the nation’s surplus plutonium

if the MOX program did not proceed. 

One commenter wondered if adopting the No-action Alternative would be a tacit (indirect) way

of saying that the MOX process cannot be done safely. Some commenters wanted NRC to

explore the effect the No-action Alternative would have on proliferation and acts of terrorism.

No-action - 100 Percent Immobilization: Several commenters wanted the EIS to consider the

costs and programmatic requirements of a 100 percent immobilization alternative. They

believed that this was a viable alternative if the MOX project was not licensed. A few

commenters specifically thought the EIS should consider (1) cost savings from not pursuing the

MOX program, (2) the short- and long-term storage and monitoring requirements of plutonium

pits and oxides until immobilization is complete, and (3) decreased waste volumes as compared

to the MOX process. Another commenter felt that considering a 100 percent immobilization

alternative would be inappropriate since DOE has already set surplus plutonium disposition

policy.

One commenter wanted the alternatives to include building an immobilization (vitrification) plant

at the Nevada Test Site to minimize transportation distances and maximize distances to

population centers. 

Conversion of All Surplus Plutonium to MOX Fuel: A few commenters wanted the EIS to

consider the impacts of an all-MOX alternative. Many commenters wanted the EIS to be very

specific in the quantity of plutonium that would be converted to MOX fuel. These commenters

believe that addressing the quantity generically or leaving it open ended could lead to

widespread reprocessing of spent nuclear fuel. A commenter wanted the EIS to consider a

range of plutonium quantities for processing, suggesting that the amount may ultimately be

greater than the 50 metric tons specified by the SPD EIS.

Range of Alternatives: A few commenters wanted to restrict the scope of the NRC EIS to the

Proposed Action, the No-action Alternative, siting alternatives within the F-Area, and a

reasonable range of MOX FFF design alternatives. They also stated that the official statement
Appendix I

I-13

of proposed action and no-action should be broadened to include the issuance of a license to

possess and use special nuclear material at the MOX Fuel Fabrication Facility. Other

commenters wanted to make sure that the no-action alternatives were considered viable

options. That is, the no-action alternatives should be defined so that the EIS could select a

no-action alternative and not just do an analysis because it was required by law. 

The Parallex Project: Some commenters stated that the No-action Alternative from NRC

could mean 100 percent immobilization and immobilization has already been delayed. These

commenters wanted the EIS to consider the possibility that DOE would export the surplus

plutonium to Canada under the Parallex Project. [Note: The Parallex (parallel experiment)

Project would be a joint agreement between Russia, Canada, and the United States to

demonstrate the feasibility of burning MOX fuel in a heavy-water-moderated reactor, located at

Chalk River, Ontario. The project would use MOX fuel made in the United States and Russia

from surplus weapons-usable plutonium out of both countries’ nuclear stockpiles.]

Aqueous vs. Dry Purification Process: Some commenters wanted NRC to evaluate both the

wet and the dry plutonium purification processes. The analysis should include a cost/benefit

analysis that weighs the effectiveness of the process against the costs, the effects the

impurities have on the MOX fuel use, waste streams, quantities of waste, etc. 

Contingency Issues: One commenter wanted to make sure that the impacts of unusable MOX

fuel were assessed, noting that historically MOX production has exceeded use and that if the

MOX fuel is stored too long, the plutonium converts to americium, which ruins the reactivity.

2.2.4 Ecology, Air, and Water

Surface Water Impacts: One commenter pointed out that the choice of F-Area for the MOX

facilities would probably hasten whatever impacts there would be to Upper Three Runs Creek. 

The commenter wanted the impact analysis to consider the current conditions of the F-Area,

pointing out that it was already contaminated.

Groundwater Quality: A number of commenters expressed concerns about potential

contamination of groundwater by plutonium, especially since there are a number groundwater

aquifers beneath the F-Area. The Floridian aquifer was specifically mentioned. The point was

made that there is already existing groundwater contamination from radioactive releases

(primarily tritium) from the SRS (communities downstream from the SRS in both South Carolina

and Georgia have already been affected; tritium has been found in wells and surface water). 

Commenters pointed out that there is the potential that liquid radioactive waste generated by

the MOX process, which would contain plutonium, would be stored in the same tanks that

“caused” the tritium releases. One commenter pointed out that plutonium studies at the

Nevada Test Site and at West Valley in New York have shown that plutonium has migrated

much faster than predicted. A commenter wondered if the contaminated water would move

between the soil and aquifers via the deep rock borings at the SRS.

Several commenters were concerned that any further contamination of the Savannah River

could push the ecosystems “over the edge” and cause serious long-term consequences for

human health and the economy that depends on resources from the river. They stated that

existing water quality in the Savannah River, and Georgia in general, is compromised and that

according to U.S. Environmental Protection Agency (EPA) data the Savannah River is already

among the 10 most contaminated rivers in the country.
Appendix I

I-14

One commenter wanted the EIS to look at the effects of radioactive storm-water runoff on the

ecology of the surrounding area. This commenter thought that storm-water runoff from

retention ponds should be captured, not released to creeks.

HEPA vs. Sand Filters: Several people commented on the decision to use high-efficiency

particulate air (HEPA) filters instead of sand filters for air filtration in the MOX facility. The point

was made that the SRS prefers sand filters which are more efficient, safer and more reliable

than HEPA filters. They wanted the EIS to consider the use of sand filters in its analysis.

Air Emissions: A commenter stated that the EIS should look at all air contaminants released

by the MOX process, how contaminants will be removed and scrubbed from the air stream, and

the probable path of contamination spread through the air. Other commenters noted that over

the years, tritium had been released through the air pollution stacks and had fallen back to

Earth as radioactive tritiated water, which contaminated the region’s well water and agricultural

products. One commenter questioned why the MOX FFF would be exempted from the National

Emission Standards for Hazardous Air Pollutants as was suggested in the ER prepared by

DCS. Another commenter stated that the EIS should consider air emissions from the

emergency generators and volatile organic compounds from diesel storage tanks.

Tidal Wetlands: Some commenters were concerned about impacts to tidal wetlands along the

Georgia coast, stating that they represent about one-third of the remaining tidal wetlands along

the Atlantic shore of the United States. A commenter noted that in addition to ecological

impacts, there is the potential for economic impacts to fisheries and other natural marine

resources, as high as $1 billion annually. 

General Ecological Impacts: Several commenters felt the ecological impacts were very

important and that the EIS should look at the ecological impacts of the proposed facility. One

commenter suggested using an ecological system upstream from the site as a benchmark;

other commenters stated the impacts to endangered species and habitat should be reevaluated given the changes to MOX design from what was presented in the DOE SPD EIS, in

particular the changes in the waste streams and incremental volumes of waste.

2.2.5 Cultural Resources 

One commenter thought the EIS should discuss the impacts of having deadly radioactive

wastes in proximity to ancient cultural archeological sites. Another commenter questioned how

cultural resources could be managed without a programmatic memorandum. 

2.2.6 Cumulative Impacts

Some commenters wanted cumulative impacts to consider all existing (baseline) contamination

and future actions at the SRS. Another commenter suggested that this should include all the

auxiliary facilities associated with the MOX project. Chemical as well as radiological impacts

should be evaluated. One commenter noted that any radioactive contamination of natural

resources could have a cumulative adverse effect on businesses that rely on natural resources. 

Another commenter noted that cumulative build up of contaminated sediments could directly

impact human health. It was noted that the Savannah River is currently among the 10 most

contaminated rivers in the country and that further contamination would “push the ecosystem

over the edge.” A commenter thought cumulative impacts would be the appropriate place to

consider the impacts on existing SRS infrastructure if construction of the pit disassembly facility

was canceled.
Appendix I

I-15

2.2.7 Human Health Impacts

Safety Record: Several people expressed concern that DCS did not have an environmental

and safety compliance record specific to DCS; there were only individual records for Duke,

Cogema, and Stone & Webster. Commenters thought that it was inappropriate for DCS to use

the safety data from the Westinghouse contract site. They pointed out that DCS has not

established a safety culture; probability assessments and reliance on the fact that nothing bad

has happened yet do not prove acceptability. Commenters wanted the EIS to evaluate

Cogema’s safety record in Canada and France.

Risk Determination: A commenter wanted the degree of uncertainty associated with the risk

calculations used in models to be included, especially when data used to support the models

were not based on weapons grade plutonium. Another commenter wanted the health-based

standards to be based on EPA’s 1 in 1 million accepted deaths rather than the 1 in 10,000

allowed by NRC.

Radiation Hazards: A commenter stated that in addition to looking at cancer fatalities, the EIS

should address noncancer effects resulting from ionizing radiation exposures, such as immune

deficiencies and genetic defects. A commenter thought that accident impacts should consider

radiation exposure impacts to all individuals (including children, the unborn, the sick, and the

elderly), not only the “standard man.”

A commenter wanted the EIS to assess the dose to workers that would result from the MOX

process. The analysis should include every worker involved: those at the MOX facility, workers

at nuclear laundries, workers at reactor sites, workers at waste disposal sites, etc. A few

commenters wanted to know what measures would be taken to protect MOX construction

workers from the existing contamination at the MOX site.

Chemical Hazards: A commenter wanted the EIS to include the health effects of chemical

exposure both during normal conditions and accident scenarios. The EIS should consider the

fact that there will be a radioactive component to the chemical exposure.

Emergency Preparedness: Several commenters were concerned that DCS had not prepared

an emergency management plan for the MOX facility. According to commenters, DCS claimed

that a plan was not needed because its models showed that the public radiation dose during a

major accident would be within regulatory limits. These commenters wanted the EIS to address

the implications of running the MOX program with and without an emergency management

plan. 

A few commenters wanted the EIS to address the SRS Emergency Management Plan. One

commenter expressed concern about impacts to the public from a rupture of a high-level waste

tank containing MOX waste. 

One commenter wanted to be assured that the SRS would communicate safety related

information to the public in a timely manner. According to this commenter, there had been a

situation where SRS had failed to warn the public about a tritium release that came downstream

from the site. 

Some commenters thought that the EIS should evaluate the impacts (costs) of having to

upgrade the emergency response equipment and train emergency responders in the

communities surrounding the SRS and the reactors and along transportation routes. One 
Appendix I

I-16

commenter made the point that many of the emergency responders are volunteers. Some

commenters wanted the EIS to identify the capabilities of local, regional, and national medical

facilities to manage acute and long-term casualties resulting from an accidental release. It was

noted that medical facilities along transport routes are seldom adequately equipped to treat

radiation victims.

A few commenters thought that using computer models to predict possible releases was

inadequate and wanted the EIS to include the costs of purchasing and maintaining monitoring

equipment on-site and off-site out to 40 miles. This would include monitoring of air, ground,

water, vegetation, and livestock. The instrumentation should cover all forms of radiation,

including alpha. A commenter stated that it was in the public’s interest to know the measured

amount of radiation as opposed to a calculated amount.

One commenter stated that an iodized prophylaxis, which could be used to prevent thyroid

damage (including cancer), had been approved by the NRC. This commenter wants sufficient

quantities to be in place in the event of an accidental release from the MOX FFF. (Note: An

iodized prophylaxis is a non-radioactive form of iodine that is administered before exposure to

saturate the thyroid and prevent the later uptake of any airborne radioactive iodine that might be

dispersed in a nuclear accident. Any additional iodine that is later inhaled or ingested is

eliminated by the kidneys.)

Accidents Related to the MOX Process: A commenter wanted the EIS to discuss the worstcase scenario for an accident related to plutonium processing and the safety factors that would

be used to protect the public. All the consequences, not just the probability-weighted risks from

accidents, need to be considered. Doses to populations as well as to individuals should be

provided. Another commenter thought that the EIS should analyze the impacts caused by a

criticality accident due to dust accumulation in the air ducts. There was a comment that the

accident analyses should include a plutonium fire, given that plutonium is highly flammable in

several of its states. A few commenters wanted the EIS to consider the impacts of accidents

involving ruptures or explosions of the tanks used to store liquid radioactive waste. One

commenter stated that power outages to the tanks could eventually lead to conditions that could

cause the tanks to explode.

Other Accident Issues: Some commenters felt that accident analyses in DOE’s EIS were

inadequate and that detailed accident analyses should be done for the MOX FFF EIS. 

Commenters expressed concern that the design basis earthquake assumed by DCS was not as

severe as the one normally assumed by DOE for the SRS; this could also be true for the high

winds or tornado design basis. A commenter felt that corners were being cut by using less

stringent parameters. 

A commenter wanted the EIS accident analyses to include scenarios like plane crashes, insider

sabotage, missile attacks, truck bombings, the facility dropping into a sinkhole (there are soft

zones near the MOX FFF location), and events happening in other nearby areas that could

cripple the facility. One commenter wanted the EIS to provide details on the most probable

accident. 

One commenter thought that human error should be considered in accident analysis, noting

that hazards in nuclear power plants are a combination of human and technical errors and that

human failings cannot be completely eliminated by using engineering controls.
Appendix I

I-17

2.2.8 MOX Fuel Processing

Concerns were raised about the safety of the proposed design for the MOX FFF, in particular

the sintering (baking) process that converts the MOX fuel pellets to a ceramic form. 

Commenters felt that the design for furnace confinement did not adequately protect the public

from a plutonium release. A commenter stated that heating the plutonium in an inert

atmosphere that contains some hydrogen could result in a hydrogen burn or an explosion if

certain controls were violated. Commenters pointed out that similar work at the SRS is carried

out in glove boxes, which provides additional containment in case of an accidental release.

A commenter wanted NRC (and the DOE) to conduct a thorough review of all MOX fuel

specifications and quality control procedures. This commenter stated that failure to do so

would compromise nuclear safety. In addition, the specifications and procedures must be

provided to the public.

2.2.9 Transportation Issues

General Transportation Issues: A commenter wanted to know what security measures will be

taken to protect the public during MOX fuel transport. In addition, the commenter also wanted

the EIS to look at the impacts of transporting the surplus plutonium and the uranium

hexafluoride gas to the SRS and of transporting the spent fuel to the storage facility. One

commenter asked if the current transportation casks would work for the MOX spent fuel rods. 

Some commenters wanted to know how the transport of nuclear materials related to the MOX

project would affect traffic and emergency vehicles and if certain highways (specifically

Highway 73) would be closed during transport. 

A commenter asked what corporate entity would be responsible for the transport of MOX fuel

through North and South Carolina and if they would be exempt from liability insurance for

transport as they are exempt from liability in operations under Price-Anderson. 

A few commenters believed it was not appropriate for NRC to rely on the DOE transportation

analyses.

One state agency wanted NRC to consider their comments on the DOE Surplus Plutonium

Disposition Final EIS (DOE/EIS-0283) when conducting the MOX FFF EIS analysis and safety

review, particularly with respect to transportation and emergency preparedness.

Risks from Transportation Accidents: Some commenters thought that the EIS should

evaluate the impacts of transportation accidents on communities in the transportation corridors.

Impacts from both truck and rail accidents should be included. In addition to human health

impacts, the effects on homes, schools, churches, etc. need to be considered. 

One commenter wanted to make sure the transportation risk analysis was put in the proper

perspective; for example, the exposure to the public in the event of an accident would be 

equivalent to that of a dental x-ray. Transportation risks should be compared to those of an

exploding gas truck (again, for perspective). DOE’s transportation statistics should be

compared to those from the Department of Transportation.
Appendix I

I-18

2.2.10 Waste Management

Wastes Associated with the MOX FFF: Several commenters expressed concerns about high

activity alpha liquid radioactive wastes resulting from the aqueous process that is proposed for

removing gallium and other unwanted material from the weapons-grade plutonium. 

Commenters wanted the EIS to look at the types of wastes produced by this process (solid,

liquid, and gaseous), waste storage, treatment, and ultimate disposal; they also wanted details

included on the radiological and chemical character of the waste. 

There were concerns that not enough waste tanks exist at the SRS to store the large quantities

(estimates were as high as 81,000 gallons annually) of liquid radioactive waste that would be

generated. One commenter suggested that the existing liquid waste (35 million gallons) be

vitrified. Another asked if there would be liquid waste storage tanks dedicated to the MOX FFF.

High-Level Waste: A few commenters raised concerns over waste material supposedly

leaking from high-level waste (HLW) storage tanks at the SRS. One commenter noted that 95

percent of the HLW generation from 2000 to 2070 would be from the SRS and wanted the EIS

to determine what percentage will be from the plutonium processing facilities.

Low-Level Waste: One commenter stated that NRC must consider the fact that North Carolina

will soon be excluded from using the Barnwell site for low-level waste disposal.

Wastes Associated with Converting DUF6 to DUO2: A commenter requested that the EIS

consider wastes associated with converting depleted uranium hexafluoride to depleted uranium

dioxide. 

Spent Fuel Storage: Several commenters were concerned that a final waste site for spent fuel

rods has not been determined and that reactor sites currently have spent fuel rods with no

place to go. The EIS should address the impacts from the storage of spent MOX fuel at the

reactor sites.

Secondary Wastes: A commenter wanted the EIS to include the chemical and radiological

character, quantities, treatment methods, and destination of waste produced by the treatment of

the original waste (secondary waste). The details should be comparable to those used for

primary waste.

2.2.11 Socioeconomics

Economic Effects of Radioactive Contamination on Natural Resources: Some

commenters wanted the EIS to assess the economic damage that would result from any

radioactive contamination of natural resources. They maintained that the contamination would

have a lasting, possibly cumulative, adverse effect on businesses that would not be solved by

“cleanup” alone. A commenter pointed out that the economy of the Savannah region was very

dependent on natural resources. According to this commenter, about one out of five jobs is 

related directly or indirectly to natural resources: commercial and recreational fishing, tourism,

and seafood processing. About $1 billion in business is associated with these industries; even

a reduction of 1 percent would be $10 million.
Appendix I

I-19

Cost/Benefit Analysis: Some commenters thought that a full cost/benefit analysis of the MOX

program should be conducted, including use of MOX as a fuel. The analysis should extend

beyond the usual “region of influence” to include national and international impacts as well. The

analysis should also be looked at from the perspective of the taxpayer. A national-scale study

of costs of the MOX program should be prepared as a report to the General Accounting Office. 

Several commenters wanted the EIS to consider the cost of using MOX fuel in a reactor. They

stated that Cogema in France recently admitted that the reactor fuel made with separated

plutonium was three to four times more expensive than the conventional fuel made with lowenriched uranium. They also pointed out that the cost of using blended highly enriched uranium

is lower, as would be the cost for mined uranium, and even uranium processed from the sea.

Costs of the MOX Program: A commenter noted that over the past four years, the estimated

cost of the MOX program has doubled. The concern was that in a risk/benefit culture the

environment is often compromised to keep expenses down. This commenter did not want the

environment to “take the hit” for higher costs.

Electricity Rates: A commenter wanted the EIS to assess costs associated with the MOX

program. There were concerns that project cost overruns would be passed on to consumers in

the form of rate increases, as has happened, according to the commenter, in the past with the

Vogtle nuclear power station. 

Government Subsidy of Nuclear Power: A commenter was concerned about the impacts

that “yet another” subsidy (funding) of nuclear power would have on the whole energy

economy. Would the utilities be paid twice for the same kilowatt hour, once by taxpayers and

again by ratepayers? That is, the taxpayers would be paying to produce the MOX fuel, and

ratepayers would still be charged the same for electricity from fuel paid for by them (taxpayers). 

This commenter thought that the plutonium fuel subsidy would give an unfair advantage to

nuclear energy suppliers in contrast to the nationwide effort to create a level playing field for

energy producers. Also, the subsidy would put other sustainable energy technologies (solar

and fuel cells) at a disadvantage. A comment was made that the MOX program no longer had

a non-proliferation mission; it was really a subsidy to build a fuel infrastructure in this country

using non-proliferation funds.

Land value: Some commenters wanted the EIS to consider the economic impacts on

landholders along transportation routes. This would include transportation during all phases: 

delivery of the surplus plutonium to the SRS; transport of the MOX fuel to the reactors; and

transport of the spent fuel to the repository.

2.2.12 Security and Terrorism

Many commenters were concerned about the increased threat of terrorism that would result

from the transport of weapons-grade plutonium. A comment was made that the MOX program

causes unnecessary transportation of nuclear material, thereby increasing the risk of accident

or interception by terrorists. Commenters suggested that both the Proposed Action and the

No-action Alternatives should look at the environmental and human impacts resulting from an

act of terrorism, including the detonation of a nuclear weapon. One commenter suggested that

the EIS should evaluate both foreign and domestic terrorism. Another felt that NRC regulations

governing security were inadequate.
Appendix I

I-20

Some people thought that immobilization was the best technology for making weapons-grade

plutonium less attractive to terrorists. Their arguments included the following: (1) immobilized

plutonium would still be highly radioactive, thus making it more theft proof; (2) MOX fuel is very

vulnerable to theft since it is not highly radioactive; the plutonium can be separated chemically

and is still weapons grade; and (3) plutonium processing cannot properly account for all the

plutonium that passes through the fuel cycle; incremental amounts can be systematically

removed and used to make terrorist weapons. Other commenters felt that converting the

surplus plutonium to MOX fuel was the more effective means of making it unavailable to

terrorists. 

2.2.13 Environmental Justice

General Comment: One commenter indicated that the National Association for the

Advancement of Colored People (NAACP) would be monitoring the environmental justice part

of the MOX project carefully. Another commenter pointed out that most African American

workers in the area are a captive workforce since few companies are willing to move near the

SRS; the same is true for poor whites. Some commenters suggested that the environmental

justice analysis in the EIS evaluate the decision making to locate the proposed MOX FFF in the

South.

Communicating Information: Concern was expressed that information related to the MOX

project was not reaching the African American community. It was suggested that information

be conveyed directly via their churches or the NAACP rather than expecting people to search

the Federal Register for information.

Applicable Geographic Area: One commenter stated that it was not clear how environmental

justice would be used in the decision making process. Some commenters thought that the

geographic area considered for environmental justice should include communities both

downwind and downstream of the MOX FFF. It should also include communities along

transportation routes and near reactors. One commenter questioned why NRC had changed

the region of analysis from a 4-mile radius to 50-mile radius from the MOX facility. Another

commenter encouraged NRC to apply the guidance of the NMSS Policy and Procedures

Letter 1-50, Rev 2, “Environmental Justice in NEPA Documents,” to its MOX FFF EIS. 

According to this commenter, the document recommends that a 4-mile radius be used for

evaluating Environmental Justice when a facility is in a rural area; evaluations beyond this

distance are not warranted.

Subsistence Fishing: A few commenters stated the EIS should consider the effects of

radioactive contamination on subsistence fishing. A commenter stated that people of modest

income often depend on fishing local rivers for a greater proportion of their nutrition. This could

lead to a situation where impacts to surface water could result in a greater than average risk to

those modest income individuals.

Civil Liberties: A commenter expressed a general concern about the effects that the use of

MOX fuel would have on civil liberties in local, regional, national, and international communities. 

Infringements on the civilian population due to the security necessary to guard the plutonium

was specifically mentioned. 
Appendix I

I-21

2.2.14 Decommissioning vs. Deactivation

Some commenters thought that the EIS should analyze the impacts of MOX FFF

decommissioning (not just deactivation) and any site remediation following decommissioning. 

Issues such as how the closure and removal will be funded need to be addressed. The

terminal facility condition should be compared to its present condition. The NRC should have

regulatory responsibility for the facility through the entire project life, including

decommissioning. One commenter felt that consideration of decommissioning impacts at this

time would be too remote and speculative, pointing out that since the CAR called for the MOX

facility to be turned over to DOE at the conclusion of the contract and prior to decommissioning,

decommissioning should not be within the scope of the MOX FFF EIS.

2.2.15 SRS Infrastructure and Existing Conditions

Infrastructure: Several people wanted the EIS to address MOX FFF impacts on existing

infrastructure. Some commenters wanted the EIS to consider the impacts of processing

weapons-grade plutonium at a 50-year-old site with reported cracks in the concrete. There

were also commenters who thought the EIS should compare the impacts of the MOX FFF being

a dedicated site (including waste storage tanks) to those associated with using existing SRS

infrastructure.

Existing Conditions: One commenter thought that the description of existing conditions at the

SRS should include the status of all nuclear materials on site, with a discussion of criticality

issues. 

2.2.16 Reactor Use Issues

General: A commenter noted that in order to avoid being accused of segmentation (not looking

at the full consequences of an action) the EIS must include reactor impacts in its analysis. 

Other commenters wanted assurance that the MOX FFF EIS would be specific to the reactors

actually designated to use the MOX fuel and would not ultimately be transferable to all United

States reactors. They indicated that, if reactor impacts are not specifically addressed in this

EIS, that EIS’s should be performed for each reactor site prior to allowing use of MOX fuel.

Another commenter stated the prospect of analyzing reactor impacts as part of the current

MOX FFF EIS would create a double jeopardy for DCS in that the company would have to 

provide data twice: now for MOX FFF licensing and then again during the license amendment

process for the reactor. 

Reactor Program Licensing and Implementation: A commenter wanted to know what the

impacts would be if the Duke reactor license expired before the MOX fuel was used, if the

reactors could not meet licensing requirements, or if Duke decided to shut its reactors down

early because they were too expensive to run. A commenter wanted the EIS to consider the

impacts that would result if the reactor portion of the MOX program was never implemented. 

Another commenter asked if the MOX FFF EIS would consider impacts of using MOX fuel and

the revisions to the existing operating licenses at the Catawba and McGuire plants. 
Appendix I

I-22

Plutonium Purification: A commenter asked that the EIS assess the impacts on the

environment from imperfect gallium removal and the potential of the fuel’s “falling apart in the

reactor.” This commenter noted that both the dry and the aqueous process for removing

impurities from the weapons-grade plutonium have their faults . the aqueous process is

environmentally destructive (it creates large quantities of high-level alpha liquid waste) and the

dry process does not remove gallium as effectively. The tolerance level for gallium in the fuel

should be determined. 

Use of MOX Fuel in Reactors: Many commenters wanted the EIS to include a thorough

investigation of the impacts of using weapons-grade plutonium in commercial reactors. 

Several commenters wanted the analyses to be specific to the reactor designs at the Catawba

and McGuire plants. Commenters contended that weapons-grade plutonium has never been

fabricated into fuel before and has never been used in a commercial reactor. They felt it was

inadequate to use the MOX program experience in Europe as an analog in safety and

performance analyses because the plutonium for MOX fuel in the European reactors comes

from spent fuel from nuclear reactors, not weapons-grade plutonium. It was pointed out that

the plutonium from dismantled weapons contains a different mix of isotopes than plutonium

obtained from reprocessing spent fuel. It was also stated that the experience with low-enriched

uranium fuel was not directly applicable because of the different mix of plutonium in that type of

fuel and because of differences in performance of the two fuels. The commenters wanted NRC

to evaluate the performance of the MOX fuel made specifically with weapons-grade plutonium

at the concentrations proposed by DCS.

A few commenters stated that the DOE SPD EIS had already specifically evaluated the use of

MOX fuel in the McGuire Nuclear Station and Catawba Nuclear Station reactors, which are the

proposed mission reactors. They stated additional evaluations would be more appropriately

made at the time of reactor operating license amendment application and that including reactor

impacts in the MOX FFF EIS would delay the MOX FFF licensing process, increasing

government costs with no commensurate benefit to public health and safety.

Thermal Pollution: Some commenters were concerned about the impacts of thermal pollution

from reactors using MOX fuel. They stated that since the temperature in MOX fuel will be

hotter, more ice and water will be needed for cooling and the temperature of water at Lake

Norman will increase. One commenter maintained that this hotter water is changing the

ecology, even down to the microscopic level of the food chain. This commenter stated that

even now Lake Norman is warm enough for at least one alligator to survive.

Evacuation Issues: Many commenters were concerned about whether the population could

be evacuated in time, should an accidental release occur. Traffic on the exits to Interstate 77

around Lake Norman was mentioned as being particularly bad; exit 28 was also mentioned. 

Another commenter felt that evacuation plans should go beyond the 10-mile radius that the

NRC mentions in its publications.

Risks from Reactor Accidents: Several commenters stated that DOE’s Surplus Plutonium

Disposition EIS addressed generic reactor impacts rather than those specific to the Duke Power

reactors that would be using the MOX fuel. They wanted reactor design-specific impacts to be

addressed, rather than addressing the accident impacts generically. 

Some commenters expressed concern that reactors used at Catawba and McGuire posed a

greater likelihood for an accident than did other types of reactors currently in use in this country. 

Of particular concern were safety issues related to the use of ice condensers for cooling and
Appendix I

I-23

the so-called “eggshell” containment at Catawba and McGuire. The point was made that ice

condenser reactors lack steel-reinforced containment domes. In addition, a commenter pointed

out that there had been violations involving Duke Power’s failure to ensure that ice condenser

inlet doors would be able to open if needed, and a forced outage could occur due to a blocked

flow channel in portions of the ice condenser.

Comments were made that the Duke Power reactors were already suffering from embrittlement

(a condition that causes materials to break without bending). There were concerns that the

MOX fuel would cause a higher rate of embrittlement because it burns at such high

temperatures. A more specific comment focused on analyzing accident consequences due to

loss of power (including backup power) at the reactors. 

One commenter pointed out that a severe accident at the Catawba reactors could result in a

25 percent increase in the latent cancer fatalities downwind of the reactor, resulting in anywhere

from hundreds to thousands of additional cancer deaths. Another commenter wanted the EIS

to consider the impacts of using plutonium fuel rather than uranium oxide fuel. A commenter

stated that even DOE has admitted that the operation of nuclear power plants with plutonium

fuel rather than uranium oxide fuel increases the deaths in certain accident scenarios. 

According to a commenter, one accident scenario had 8 percent more deaths from use of

plutonium fuels rather than uranium fuel; another had 14 percent.

2.2.17 Lead Test Assemblies

Some commenters wanted NRC to fully provide and review all procedures for the fabrication of

the lead test assemblies, including review of all the facilities involved, their records, quality

control procedures, and the transport implications.

3. SCOPE OF THE EIS AND SUMMARY OF ISSUES TO BE ADDRESSED

The NEPA (Public Law 91-90, as amended), and the NRC’s implementing regulations for NEPA

(10 CFR Part 51), specify in general terms what should be included in an EIS prepared by the

NRC. Regulations established by the Council on Environmental Quality (40 CFR Parts 1500-

1508), while not binding on the NRC, provide useful guidance. 

Pursuant to 10 CFR § 51.71(a), in addition to public comments received during the scoping

process, the contents of the draft EIS will depend in part on the December 2000 environmental

report submitted by DCS. Pursuant to 10 CFR § 51.71(b), the draft EIS will consider major

points of view and objections concerning the environmental impacts of the proposed action

raised by other Federal, State, and local agencies, and by any affected groups of Native

Americans. Pursuant to 10 CFR § 51.71(c), the draft EIS will list all Federal permits, licenses,

approvals, and other entitlements which must be obtained in implementing the proposed action,

and will describe the compliance status with these requirements. Any uncertainty as to the

applicability of these requirements will be reflected in the draft EIS. 

Pursuant to 10 CFR § 51.71(d), the draft EIS analysis will include a consideration of the

economic, technical, and other benefits and costs of the proposed action, and alternatives to

the proposed action. In the draft analysis, due consideration will be given to compliance with

environmental quality standards and regulations that have been imposed by Federal, State,

regional, and local agencies having responsibility for environmental protection, including any

applicable zoning and land-use regulations and water pollution limitations or requirements
Appendix I

I-24

established or imposed pursuant to the Federal Water Pollution Control Act. The environmental

impact of the proposed action will be considered in the draft analysis with respect to matters

covered by such standards and requirements regardless of whether a certification or license

from the appropriate authority has been obtained. Compliance with the environmental quality

standards and requirements of the Federal Water Pollution Control Act (imposed by the United

States Environmental Protection Agency or designated permitting states) is not a subject for

and does not negate the requirement for NRC to weigh all environmental effects of the

proposed action, including the degradation, if any, of water quality, and to consider alternatives

to the proposed action that are available for reducing adverse effects. While satisfaction of

NRC standards and criteria pertaining to radiological effects will be necessary to meet the

licensing requirements of the Atomic Energy Act, the draft analysis will, for the purposes of

NEPA, consider the radiological effects of the proposed action and alternatives. 

Pursuant to 10 CFR § 51.71(e), the draft EIS may include a preliminary recommendation by the

NRC staff respecting the proposed action. Any such recommendation would be reached after

considering the environmental effects of the proposed action and reasonable alternatives, and

after weighing the costs and benefits of the proposed action.

The scoping process summarized in this report helped to determine the scope of the MOX FFF

EIS and identified the significant issues to be analyzed in depth. For instance, in response to

comments received during the scoping process, the EIS will evaluate the potential impacts of

using sand filters instead of HEPA filters, and the potential impacts of using both wet and dry

plutonium purification processes in manufacturing MOX fuel. Other options may be identified

and analyzed. The EIS will also evaluate the degree to which impacts would vary depending on

where within the SRS F-Area the proposed MOX FFF may be located. This will include

consideration of surface water impacts as suggested by a commenter. Cumulative impacts of

the proposed action will be addressed in detail.

The No-action Alternative, not licensing the MOX FFF, was also refined through the scoping

process. In addition to the potential environmental impacts of the proposed action, the EIS will

evaluate two no-action alternatives: (1) continued storage of all of the surplus weapons-grade

plutonium at the present DOE sites in an unaltered form; and (2) immobilizing all of the surplus

weapons-grade plutonium at the SRS site. Other alternatives may be identified and analyzed

during the preparation of the draft EIS. 

Issues to be analyzed in depth pertain to the construction, operation, deactivation and

decommissioning of the MOX FFF, and transportation of fresh MOX fuel. Ordinarily, an NRC

environmental impact statement also discusses in detail the need for the proposed action. 

Here, however, DOE has already addressed the need for the MOX FFF (see Section 2.2 of the

DCS Environmental Report), and the EIS will reference the purpose and need analyses

performed by DOE pursuant to NEPA. Impacts associated with transportation of materials to

the SRS for the purpose of manufacturing MOX fuel, impacts of converting the depleted

uranium, impacts of reactor use of MOX fuel, and the transportation and disposal of spent MOX

fuel will be discussed. The EIS will recognize previous NEPA analyses performed by the DOE,

including (1) the Surplus Plutonium Disposition Final Environmental Impact Statement (SPD

EIS) (DOE/EIS-0283); (2) Final Programmatic Environmental Impact Statement for Alternative

Strategies for the Long-Term Management and Use of Depleted Uranium Hexafluoride

(DOE/EIS-0269); (3) Draft Environmental Impact Statement for a Geologic Repository for the

Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye 
Appendix I

I-25

County, Nevada (YMP EIS) (DOE/EIS-0250D); and (4) the Supplement to the Draft YMP EIS

(DOE/EIS-0250D-S). Discussion of impacts associated with the two No-action Alternatives will

be based largely on the SPD EIS.

Our goal in writing the EIS is to set forth the impact analyses in a manner which is readily

understandable by the public. Decisions and the rationale for those decisions will be described

in sufficient detail early in the EIS. Significant impacts will be discussed in greater detail in the

body of the EIS. Topical areas whose impacts are less significant will be discussed in

appendices to the EIS, with an explanation of why they were found to be less significant. This

should allow readers of the body of the EIS to focus on issues that were important in reaching

the conclusions of the EIS. The following topical areas and issues will be analyzed in the EIS:

• Geology and Seismicity. The EIS will describe the geologic and seismic

characteristics of the proposed site. Evaluation of the potential for earthquakes,

ground motion, soil stability concerns, surface rupturing, and any other major

geologic or seismic considerations that would affect the suitability of the

proposed site for the construction of the MOX FFF will be addressed primarily in

the construction SER and summarized in the EIS. The EIS will not, however,

evaluate the safety aspects associated with these site characteristics which will

be addressed in the SER.

• Hydrology. The EIS will assess the potential impacts of the proposed project on

surface water, storm-water runoff, and groundwater resources including the

Floridian aquifer. The assessment will consider water resources, water quality,

water use, flood plains, and the probable maximum flood (the largest flood that is

likely to occur). The environmental mobility of the significant radionuclides,

including plutonium, will be assessed. The EIS will not, however, evaluate the

safety aspects associated with these site characteristics which will be addressed

in the SER.

• Air Quality. Potential air quality impacts of the proposed project will be

evaluated in the EIS. The evaluation will include potential impacts resulting from

construction activities and operation (both with HEPA filters and sand filters) and

will compare the anticipated air quality impacts, if any, with relevant standards. 

• Ecology. The EIS will assess the potential environmental impacts of the

proposed facility on ecological resources, including wetlands, plant and animal

species, and threatened or endangered species and critical habitat that may

occur in the area. As appropriate, the assessment will include potential effects

on wildlife migration patterns; mitigation measures to address adverse impacts

will be analyzed.

• Land Use. An analysis of impacts of accidents on existing land use along

transportation corridors will be conducted. The EIS will also discuss the impacts

of the MOX FFF on future land use on the SRS.

• Cultural Resources. The EIS will assess potential impacts of the proposed

project on the historic and archaeological resources of the area. The EIS will

also describe the programmatic framework of how cultural resources are

evaluated at SRS and for the MOX FFF.
Appendix I

I-26

• Transportation. As discussed above, the transportation impacts of shipping

MOX feedstock to SRS and shipping spent MOX fuel to a geologic repository will

be discussed. The EIS will contain an analysis of potential impacts resulting

from the transportation of fresh MOX fuel, and will assume (for purposes of

ensuring that NEPA’s objectives are met) that one or more commercial power

reactors will later be authorized to use MOX fuel. Accordingly, the EIS will

consider relevant aspects of both rail and truck transport of the fuel from the

proposed MOX facility to the Catawba and McGuire reactors. The EIS will

discuss the number, type, and frequency of shipments, as well as routing

considerations and the quantities of MOX fuel being shipped. The impacts of

transportation will be evaluated primarily in terms of radiological exposure risk to

the population during normal transportation (including handling, transfer, and

inspection) and under credible accident scenarios. The non-radiological impacts

of transportation will also be identified and evaluated. The impacts on the

usability or level of service of the roads, particularly near the SRS (such as

Highway 73), will also be evaluated.

• Infrastructure. The EIS will address issues related to availability and adequacy

of the infrastructure at the SRS such as waste treatment, and utility services to

handle the needs of the proposed facility. The EIS will also consider impacts

from any upgrades to these infrastructure.

• Waste Management. Waste management was identified as a significant issue

by many commenters. The EIS will document the quantities, types, treatment,

and disposal of the various potential waste streams. The EIS will also consider

the impacts of storage of waste, such as the impacts on the existing high level

waste tanks at SRS. The EIS will analyze the incremental impacts of MOX FFF

wastes to existing facilities at SRS and at other DOE and non-DOE facilities. 

The EIS will evaluate the impacts of wastes generated at the MOX FFF either 

specifically or through incorporation of reference material from existing NEPA

documents that analyze the overall waste management impacts at the SRS. 

• Socioeconomics. The socioeconomic issues that fall within the scope of the

EIS include the direct and indirect economic impacts on city, county, and school

district revenues and expenditures, property values, residential and commercial

development, housing, and public services in a four county region surrounding

SRS. In addition, the economic effects on employment (including agricultural

employment), unemployment and income in a 15-county region will be evaluated.

These would include potential economic impacts to commercial fishing

downstream of SRS. The EIS will include an analysis of the impacts on these

resources that would result from the construction and operation of the proposed

facility. National level impacts will be discussed under cost-benefit analysis.

• Environmental Justice. Potential for disproportionately high or adverse human

health or environmental impacts on the minority and low-income populations will

be evaluated and discussed at the census block level. Environmental justice will

not be evaluated in detail along transportation routes because of the uncertainty

associated with routing. 

• Aesthetics. The EIS will analyze the visual impacts from the MOX facility being

constructed in the F-Area at the SRS.
Appendix I

I-27

• Human Health Impacts. The potential human health impacts of the proposed

facility on the workers and the general public will be evaluated for normal

operations (including handling, transfer, and inspection activities) and under

accident conditions. Potential exposures to radioactive elements and to

chemicals will be considered. Both cancer and non-cancer health effects will be

evaluated, as appropriate. Calculations for the general public account for

sensitive populations as well as normal healthy adults. Models, assumptions,

and supporting data used to develop the impacts from these potential exposures

will be clearly described. The SER will assess the impacts associated with all

credible accidents at the proposed facility, both from natural events and human

activities. The EIS will analyze the potential environmental impacts resulting

from bounding credible accidents at the proposed facility.

Emergency preparedness and environmental monitoring were raised as

significant issues by several commenters. The need and extent for emergency

preparedness and environmental monitoring, in context of the EIS, would be

considered as mitigation measures for potential impacts. These issues may be

discussed in the EIS to the extent that they are required as mitigation measures. 

Emergency preparedness and environmental monitoring will be addressed in

greater detail in the operation SER .

• Decommissioning. The December 2000 Environmental Report (ER) submitted

by DCS considered only deactivation. Evaluating the impacts of

decommissioning was identified during the scoping process as a significant issue

and is required by NEPA. The EIS will evaluate the impacts of deactivating and

decommissioning the proposed MOX FFF.

• Cumulative Impacts. The EIS will analyze the potential cumulative impacts of

the proposed facility when added to other past, present, and reasonably

foreseeable future actions. This will include impacts from auxiliary and

infrastructure facilities associated with the MOX project. It will also include

impacts to resources such as the Savannah River. 

• Unavoidable Adverse Environmental Impacts. A discussion will be provided

on the potential environmental impacts that could not be avoided if the proposed

action were to be implemented.

• Irreversible and Irretrievable Commitment of Resources. The irreversible

and irretrievable commitment of resources, including land use, materials, and

energy will be discussed. Potential waste minimization and pollution prevention

activities and mitigation measures will be discussed.

• Cost/Benefit Analysis. The EIS will include a cost/benefit analysis that

summarizes the environmental and other costs and benefits of the proposed

action. 

• Compliance with Applicable Regulations. The EIS will present a listing of the

relevant permits and regulations that are believed to apply to the proposed

facility.
Appendix I

I-28

Pertinent proprietary information, although not available to the public, will be reviewed by the

NRC in preparing the SERs and the EIS. As indicated above, all available documentation

generated by DOE and other agencies that is related to dispositioning of surplus weaponsgrade plutonium and MOX fuel production will be used, as appropriate. 

4. ISSUES CONSIDERED PERIPHERAL, OUTSIDE THE SCOPE OF THE PROPOSED

ACTION, OR COVERED BY PRIOR ENVIRONMENTAL REVIEW

Issues raised during the scoping period for the MOX FFF EIS are summarized in Section 2. 

Section 3 outlines the subjects and issues that will be addressed in depth in the EIS. Issues

raised during the scoping period have been considered in the preparation of this scoping report

and are reflected in Section 2. As discussed below, certain issues will not be addressed in

depth in the EIS. Major categories of these issues and the reasons for not analyzing them in

detail in the EIS are explained below. In general, these issues are not directly related to the

assessment of potential impacts from the proposed major federal action now under

consideration. The lack of in depth discussion in the EIS, however, does not imply that an issue

or concern lacks value. Issues beyond the scope of the EIS may be appropriately discussed

and decided in other venues. For example, many commenters were concerned about the lack

of a safety record for DCS. This issue will be addressed in the SERs. 

4.1 PREVIOUS DOE DECISIONS

A number of commenters requested that the SPD EIS prepared by DOE be supplemented and

many of the decisions already made by DOE be revisited. Because the scope of the MOX FFF

EIS is limited to the licensing action now under review by NRC, which is specific to the MOX

FFF, issues pertaining to decisions already made by DOE will be addressed by referencing the

appropriate DOE analysis.

4.2 INTERNATIONAL AGREEMENTS AND NATIONAL, STATE, OR LOCAL LAWS,

 STATUTES, AND REGULATIONS

Comments that seek to alter international treaties or affect national, state, or local laws,

statutes, or regulations (e.g., comments that asked to alter Price-Anderson Act limits) will not be

addressed, because they do not pertain to reasonably foreseeable impacts arising from the

proposed construction and operation of the MOX FFF.

4.3 REACTOR USE OF MOX FUEL

Comments on the scope of assessing reactor use impacts in the EIS for the MOX FFF were

varied (see Section 2.2.16). The NRC will consider the environmental impacts resulting from

the use of MOX fuel, pursuant to 10 CFR Part 51, if and when nuclear power plant operators

apply for a license amendment to use such fuel. Nevertheless, since a MOX FFF is expected

to fabricate fuel for use in one or more nuclear power reactors, it is reasonable to consider the

impacts of reactor use as an indirect impact in the EIS. At this time, NRC is aware that two

plants, McGuire and Catawba, are considering using MOX fuel under the DOE program. The

NRC is aware that DOE has analyzed the reactor use impacts of MOX fuel in its SPD EIS. 

Scoping comments related to reactor use impacts that were determined to be beyond the scope

of this EIS will be forwarded to the appropriate NRC offices.
Appendix I

I-29

4.4 COST AND READINESS TO RESPOND TO EMERGENCIES

A number of commenters requested that the MOX FFF EIS analyze the impacts of having to

upgrade the emergency response equipment and retrain emergency responders in the

communities around the SRS, at the reactors, and along transportation routes. Other

commenters requested that the EIS identify capabilities of local, regional, and national medical

facilities to manage the casualties resulting from potential accidental releases and assess the

readiness of communities to evacuate certain areas along the transportation routes in case of

an accident. The human health impacts of potential accidents will be analyzed in the EIS. 

However, the costs associated with emergency preparedness and capabilities of local, regional,

and national communities to respond to emergencies will not be analyzed, because such

impacts are not specific to the proposed action. It is not anticipated that activities related to the

proposed action will require any emergency response capabilities among communities beyond 

what they already have for similar purposes. Issues related to general emergency

preparedness of communities are outside the scope of this EIS. 

4.5 POTENTIAL DELAYS IN DOE PROGRAMS

Several commenters wanted to know what would happen if the DOE programs related to

weapons-grade plutonium disposition and the opening of the HLW repository were delayed. 

Any such potential delays are either speculative or do not clearly affect the licensing review of

the MOX FFF by the NRC. Unless it is reasonably foreseeable that a change in a DOE

program or that of any other federal agency (e.g., a formal decision either has been announced

or is expected to be announced soon) will have a substantive effect on the licensing of the MOX

FFF, the EIS process will continue as scheduled, and the impacts of potential delays will not be

analyzed in the EIS.

4.6 IMPACTS FROM TERRORISM

Many commenters raised a number of different issues concerning terrorism. However, the EIS

will not address the impacts of terrorism, because these impacts are not considered to be

reasonably foreseeable as a result of the proposed action.

4.7 IMPACTS OF ACTIONS IN THE RUSSIAN FEDERATION

All activities in the Russian Federation related to manufacture of MOX fuel from Russian-origin

weapons-grade plutonium as part of an agreement between that country and the United States

are being undertaken by the Russian authorities. They are not subject to NEPA and, therefore,

will not be analyzed in the EIS.

4.8 PROPRIETARY INFORMATION

NRC will evaluate all pertinent proprietary information in its decision to grant authorization to

construct the MOX FFF and to grant a license to DCS to possess special nuclear material. 

However, by law, NRC has to protect the proprietary information from public disclosure. 

Therefore, proprietary data will not be released to the public.
Appendix I

I-30
Appendix I

I-31

Attachment A

Preliminary Outline 

for the Mixed Oxide Fuel Fabrication Facility EIS

Summary

Table of contents, Glossary, and list of acronyms

1.0 Purpose of and Need for proposed action

1.1 Introduction

1.2 Description of the Proposed Action

1.3 Need for the Proposed Action

1.4 Scope of the EIS

1.5 Scoping Process

1.6 Cooperating Agencies

1.7 Other State and Federal Agencies

1.8 References

2.0 Proposed Action and Alternatives to the action

2.1 Proposed Action

2.2 No-action Alternative

2.2.1 Immobilization of all Surplus Plutonium

2.2.2 Continued Storage of Surplus Plutonium at Present DOE Sites

2.3 Proposed Action - Description of Mixed Oxide Fuel Fabrication Facilities and 

Processes

2.4 Comparison of Alternatives

2.5 References

2.6 Preferred Alternative

3.0 Affected Environment

3.1 General Site Description

3.2 Geology, Seismology, and Soils

3.2.1 Geology

3.2.2 Seismology

3.2.3 Soils

3.3 Hydrology

3.3.1 Surface Water

3.3.2 Groundwater

3.4 Meteorology, Emissions, Air Quality, and Noise

3.4.1 Meteorology

3.4.2 Emissions

3.4.3 Air Quality

3.4.4 Noise
Appendix I

I-32

3.5 Ecology

3.5.1 Terrestrial

3.5.2 Aquatic

3.5.3 Wetlands

3.5.4 Protected Species

3.6 Land Use

3.6.1 Savannah River Site Land Use

3.6.2 Off-Site Land Use

3.7 Cultural and Paleontological Resources

3.7.1 Archaeological Resources

3.7.2 Historical Structures

3.7.3 Traditional Cultural Properties

3.7.4 Paleontological Resources

3.8 Infrastructure

3.8.1 Electricity

3.8.2 Water

3.8.3 Fuel

3.8.4 Roads and Railroads

3.8.5 Site Safety Services

3.9 Waste Management

3.10 Human Health Risk

3.10.1 Background Radiological Characteristics

3.10.2 Chemical Exposure and Risk

3.11 Socioeconomics

3.11.1 Employment and Unemployment

3.11.2 Income

3.11.3 Population

3.11.4 Housing

3.11.5 Community Resources

3.11.6 Traffic

3.12 Environmental Justice

3.13 Aesthetics

3.13.1 General Site Description

3.13.2 Description of the Location of the Proposed Facility

3.14 References

4.0 Environmental Consequences and Mitigating Actions

4.1 Introduction

4.2 Proposed Action - Construction Impacts

4.2.1 Geology, Seismology, and Soils

4.2.2 Hydrology
Appendix I

I-33

4.2.3 Emissions, Air Quality, and Noise

4.2.4 Ecology

4.2.5 Land Use

4.2.6 Cultural and Paleontological Resources

4.2.7 Transportation

4.2.8 Infrastructure

4.2.9 Waste Management

4.2.10 Human Health Risk

4.2.10.1 Radiological Risk

4.2.10.2 Chemical Exposure and Risk

4.2.11 Socioeconomics

4.2.12 Environmental Justice

4.2.13 Aesthetics

4.3 Proposed Action - Operation Impacts

(Routine and Accident subheadings will be used where appropriate in the following

sections)

4.3.1 Geology, Seismology, and Soils

4.3.2 Hydrology

4.3.3 Emissions, Air Quality, and Noise

4.3.4 Ecology

4.3.5 Land Use

4.3.6 Cultural and Paleontological Resources

4.3.7 Transportation

4.3.8 Infrastructure

4.3.9 Waste Management

4.3.10 Socioeconomics

4.3.11 Human Health Risk

4.3.11.1 Radiological Risk

4.3.11.2 Chemical Exposure and Risk

4.3.12 Environmental Justice

4.3.13 Aesthetics

4.4 Transport of Fresh MOX Fuel 

(Routine and accident impact subheadings will be used as appropriate in the 

following sections; some topics may not require analysis)

4.4.1 Geology, Seismology, and Soils

4.4.2 Hydrology

4.4.3 Emissions, Air Quality, and Noise

4.4.4 Ecology

4.4.5 Land Use

4.4.6 Cultural and Paleontological Resources

4.4.7 Transportation

4.4.8 Infrastructure

4.4.9 Waste Management

4.4.10 Human Health Risk

4.4.10.1 Radiological Risk

4.4.10.2 Chemical Exposure and Risk

4.4.11 Socioeconomics

4.4.12 Environmental Justice

4.4.13 Aesthetics
Appendix I

I-34

4.5 No-action

(Routine and Accident impacts associated with the two No-action Alternatives will be

based on the results provided in the DOE SPD EIS and will be presented in summary

form)

4.5.1 Immobilization of All Surplus Plutonium

4.5.2 Surplus Plutonium Remains at DOE Sites

4.6 Indirect Effects

4.7 Deactivation and Decommissioning

4.8 Cumulative Impacts

4.9 Unavoidable Adverse Environmental Impacts

4.10 Irreversible and Irretrievable Commitments of Resources

4.10.1 Land Use

4.10.2 Materials

4.10.3 Energy

4.10.4 Waste Minimization and Pollution Prevention

4.11 Cost-Benefit Analysis

4.12 Mitigating Actions 

4.13 References

5.0 Environmental Regulations and Permits

6.0 List of Preparers

7.0 Substantive Comments on draft EIS and Staff Responses (to be included in final EIS)

8.0 Index

9.0 Appendices

Appendix A - Ecology

Appendix B - Consultation Letters

Appendix C - Transportation

Appendix D - Socioeconomics

Appendix E - Radiological Analysis
Appendix J

J-1

APPENDIX J:

PUBLIC COMMENTS ON THE DRAFT

ENVIRONMENTAL IMPACT STATEMENT AND NRC RESPONSES
Appendix J

J-2

 
Appendix J

J-3

APPENDIX J:

PUBLIC COMMENTS ON THE DRAFT ENVIRONMENTAL

IMPACT STATEMENT AND NRC RESPONSES

J.1 Overview

The U.S. Nuclear Regulatory Commission (NRC) issued the Draft Environmental Impact

Statement (DEIS) for public review and comment in February 2003 in accordance with Title 10,

Parts 51.73 and 51.74 of the Code of Federal Regulations (10 CFR 51.73 and 51.74) and 40

CFR 1503.1. The NRC provided a 75-day public comment period (which ended May 14, 2003)

on the DEIS. The length of the comment period exceeded the minimum of 45 days specified in

10 CFR 51.73.

During the comment period, the NRC held three public meetings to receive oral comments

regarding the contents of the DEIS. These public meetings were held on March 25, 2003, in

Savannah, Georgia; March 26, 2003, in North Augusta, South Carolina; and March 27, 2003, in

Charlotte, North Carolina. The NRC published notice of these meetings in the Federal

Register (68 Fed. Reg. 97208, February 28, 2003), on its Web site, and in local newspapers.

Approximately 45 people provided oral comments at the public meetings. A certified court

reporter recorded the oral comments and prepared written transcripts. The transcripts of the

public meetings are part of the public record for the proposed project and were used in

developing the comment summaries contained in this appendix. In addition to oral comments

received at the public meetings, the NRC received written comments, letters, facsimile

transmittals, and e-mails regarding the DEIS and associated issues. The written comments

and transcripts are reproduced in Appendix L. 

The NRC has reviewed each comment letter and all transcripts of the public meetings and has

grouped comments relating to similar issues and topics, as permitted by the Council on

Environmental Quality’s (CEQ’s) National Environmental Policy Act (NEPA) regulations and the

NRC regulations at 10 CFR 51.91 and 40 CFR 1503.4(b). Because the comments were

voluminous, this appendix provides summaries of all substantive comments received on the

DEIS. The NRC then prepared responses to each of the comments or summaries of

comments. Commenters are identified in each summary with a commenter number. 

Appendix K contains an index of commenter names, commenter numbers, and the Agencywide Documents Access and Management System (ADAMS) accession number. ADAMS is

the NRC’s document management system that is available through NRC’s Web site

(www.nrc.gov). The accession number would be used to locate specific documents in the

ADAMS system. 

Many of the comments specifically addressed the scope of the environmental review, analyses,

and issues contained in the DEIS, including existing conditions, potential impacts, proposed
Appendix J

J-4

mitigation, the NRC review process, and the public comment period. Detailed responses to

each of these comments are provided in this appendix.

Many comments addressed topics and issues that were not part of the environmental review

process for the proposed action. Those comments include questions about the NRC’s safety

evaluation of the proposed mixed oxide (MOX) fuel fabrication facility, general statements of

support or opposition to nuclear power, observations regarding past Savannah River Site (SRS)

activities, comments on the NRC regulatory process in general, and comments on policies of

the NRC and the U.S. Department of Energy (DOE). This appendix includes summaries of

these comments. It does not, however, include detailed responses to such comments because

they address issues that do not directly relate to the environmental effects of the proposed

action and are outside the scope of the NEPA review of the proposed action.

The following sections present the comments, or summaries of those comments, along with the

NRC’s responses to them. When comments have resulted in modification or supplementation

of information presented in the DEIS, those changes are noted. All changes made to the DEIS

are indicated by side bars in the margin of the Final Environmental Impact Statement (FEIS). In

some cases, the comments do not warrant a detailed response; in those cases, an explanation

is provided as to why no further response is necessary. In all cases, the NRC sought to

respond to all comments received during the public comment period. The sections referenced

in the comments pertain to the DEIS. In general, the term “EIS” is used to apply to both the

DEIS and FEIS. The term “FEIS” is used when noting that changes were made in the DEIS, or

where section numbers have changed from the DEIS to the FEIS. Similarly, the term “SER”

(safety evaluation report) is used to apply to both the SER for construction and the SER for

operations.

J.2 Noteworthy Changes from the Draft Environmental Impact

Statement

Several noteworthy changes have occurred since the issuance of the DEIS. Those changes

include revisions to the human health risk of the proposed action, environmental justice

impacts, and mitigation measures. These changes have resulted from (1) errors identified in

the DEIS, (2) resolution of open issues in the draft SER (DSER), (3) changes to the Duke

Cogema Stone & Webster (DCS) Environmental Report (ER), and (4) comments received on

the DEIS. Section J.2.1 summarizes each of these causes, and Section J.2.2 summarizes

changes in the human health risk, environmental justice, and mitigation sections of the FEIS.

J.2.1 Causes of Changes in the DEIS

J.2.1.1 Errors in the DEIS

After publishing the DEIS, the NRC identified an error in the accident analysis for the proposed

action. On March 6, 2003, the NRC sent a letter to stakeholders who were sent a copy of the 
Appendix J

J-5

DEIS to inform them of the calculational error. The NRC also published a notice of the error in

the Federal Register (68 FR 12720). This error was associated with a flaw in the tritium model

option in a computer code, GENII version 1.485, used by the NRC staff. The staff used the

tritium model in its analysis of a large accidental tritium release from the Pit Disassembly and

Conversion Facility (PDCF). During a review of this error, the NRC staff identified an additional

error in Table D-1 of the DCS ER. This table presents a statistical summary of meteorological

data over a 5-year period at the SRS. As part of this summary, wind speed ranges were

incorrectly labeled as “meters per second” instead of “miles per hour.” These errors affected

the radiological doses from normal operations and from potential accidents. The NRC

discussed these errors at the public meetings on the DEIS in March 2003. The NRC also

issued errata sheets to stakeholders and posted these data on its MOX Web site.

J.2.1.2 Resolution of Open Issues in the NRC’s Safety Review

Several open issues were identified in Appendix A of the DSER for construction of the proposed

MOX facility issued on April 30, 2003. These open issues were areas where the NRC staff

concluded that DCS had not met the requirements in 10 CFR 70.23(b). One of these issues

(open item VS-1) related to the use of a leak path factor for two banks of high-efficiency

particulate air (HEPA) filters under accident conditions. The leak path factor is an estimate of

the percentage of contamination that would pass through the confinement systems during an

accident. DCS had suggested using a leak path factor of 1 × 10-4. In the DEIS, the NRC used

a leak path factor of 1 × 10-2 in its accident analysis (see DEIS, Table E.12) for hypothetical

internal fire and explosion events. As discussed in the DSER for construction, the NRC staff

concluded that a leak path factor of 1 × 10-4 was appropriate for hypothetical internal fire and

explosion events.

J.2.1.3 Changes to the DCS Environmental Report

On June 20, 2003, DCS submitted Revision 3 of its ER, on August 13, 2003, DCS submitted

Revision 4 of its ER, and on June 10, 2004, DCS submitted Revision 5 of its ER. These

revisions are summarized in the following sections.

Revision 3 Updates 

The ER was updated in Revision 3 to include (1) responses to requests for additional

information, (2) corrections to Revisions 1 and 2, (3) corrections resulting from an error in

Table D-1 (see Section J.2.1), and (4) the latest design information for the Waste Solidification

Building (WSB). In addition, DCS provided confirmation from the South Carolina Department of

Health and Environmental Control that the proposed MOX facility does not need a Clean Water

Act 401 Certification. DCS had previously replied to NRC requests for additional information in

letters dated October 29, 2002, December 10, 2002, and December 12, 2002. The responses

to the request for additional information were considered in the preparation of the DEIS.
Appendix J

J-6

Corrections to ER Revisions 1 and 2 consisted of clarifying Table 3-3 on page 3-53 of the ER. 

That table presents the aqueous polishing waste streams. The first column lists the names of

several waste streams. The second column of the table originally showed a volume associated

with a waste stream and another volume that was noted as “(max).” The second column in

Revision 3 of the ER provides the same volumes; however, it has been clarified that the original

number in column 2 applies to waste that would be generated from plutonium coming from the

PDCF, and the “(max)” volume pertains to waste that would be generated from the alternate

feedstock plutonium (see Section 2.2.3.2.1 of the EIS). The volumes in the original and revised

Table 3-3 are the same, except that the high-alpha waste from PDCF plutonium changed from

54,135 L/yr to 58,136 L/yr (14,301 gal/yr to 15,358 gal/yr), and the liquid low-level (radioactive

waste) (LLW) to the effluent treatment facility (ETF) from PDCF plutonium changed from

1,280,340 L/yr to 1,105,340 L/yr (338,230 gal/yr to 292,000 gal/yr).

As discussed above (Section J.2.2), errors were identified in the wind data contained in

Table D-1 of the ER. The table has been corrected. These wind data were used in calculating

the radiation dose associated with normal operations. Subsequently, DCS corrected the normal

operational radiation doses of the ER (see pages 5-19 and 5-21, and Table 5-11 [page 5-85] of

the ER).

Appendix G of the ER was revised to reflect the information for the preliminary design of the

WSB. Appendix G of the ER Revisions 1 and 2 was based on conceptual design information. 

The following discusses noteworthy changes. The WSB will now process three waste streams

(i.e., high-alpha-liquid waste from the MOX facility, stripped uranium waste from the MOX

facility, and laboratory liquid waste from the PDCF). The WSB will no longer process the

laboratory concentrated liquid waste stream from the PDCF. This waste stream will be

processed at the PDCF. In evolution from conceptual design to preliminary design, the process

changed slightly, and some of the tank sizes and numbers of tanks changed. The maximum

capacity of high-alpha waste increased by 3,785 L (1,000 gal), and the maximum capacity of

low-activity waste increased by 11,356 L (3,000 gal). The size of the low-activity waste

evaporator capacity increased from 1,893 L to 2,271 L (500 gal to 600 gal). In addition, all

waste transfers between facilities (i.e., MOX facility to WSB and PDCF to WSB) via pipelines

would use a single flush of the pipeline instead of the two flushes originally proposed for

transfers from PDCF, and no flushes for transfers from the proposed MOX facility.

Some of the impacts estimated for the WSB were also revised. In some cases, the impacts

from the plutonium immobilization facility presented in the DOE Surplus Plutonium Disposition

Environmental Impact Statement (SPD EIS) were used as bounding estimates for impacts from

the WSB. The impacts for the WSB in the revised ER no longer reference the SPD EIS. In

other cases, the impacts have changed as a result of the evolution of the WSB design. The

water usage during construction was revised from 95 million L/yr to 1,968,414 L/yr (2.5 million

gal/yr to 520,000 gal/yr). The water usage during operation was revised from 110 million L/yr to

19 million L/yr (29 million gal/yr to 5 million gal/yr). Nonhazardous liquid waste generated

during construction was changed from 21 million L/yr to 240 million L/yr (6 million gal/yr to

63 million gal/yr). Air quality impacts were revised to eliminate the stand-by diesel generator

and fugitive emissions from fuel storage tanks and to add emissions from cement storage

tanks. Utility infrastructure demands (Table G-4 of the ER) were typically significantly lower. 
Appendix J

J-7

The americium quantity in the final Waste Isolation Pilot Plant (WIPP) waste container was

revised from 0.02 kg to 0.18 kg (20 g to 180 g).

The concentrations of various materials were also revised as a result of design changes and to

reflect a more accurate representation of waste expected to be received by the WSB. The

estimated concentration of PDCF laboratory liquids (Table G-8 of the ER) increased by

approximately 1.6 times. The estimated concentration of the MOX stripped uranium waste

stream (Table G-10 of the ER) increased by approximately 1.25 times, with the exception of

uranium-235. The concentration of uranium-235 decreased to account for the waste

acceptance requirement at the WSB that the uranium-235 percentage be less than 1% by

weight. The estimated concentration of the MOX high alpha waste stream (Table G-11 of the

ER) increased by approximately 3 times, with the exception of uranium-234 and uranium-235. 

The uranium-234 concentration increased by about 2 times, and the uranium-235 concentration

increased by about 4.6 times. The estimated concentration of waste being processed

(Table G-12 of the ER) varied slightly; however, the americium concentration increased by

about 3 times in the feed, 2 times in the bottoms concentration, and by about 1.5 times in the

overhead concentrations.

Radiation doses to the public from the WSB increased from 5 × 10-6 mSv/yr to 0.29 mSv/yr

(5 × 10-8 mrem/yr to 2.9 × 10-3 mrem/yr) for normal operations. Radiation doses for facility

workers were estimated as being below 2.0 person-Sv/yr (200 person-rem/yr), with a

commitment that the average annual dose to workers would be below 5.0 mSv/yr

(500 mrem/yr). The accident scenarios changed and the bounding accident also changed. 

Previously, three potential accidents at the WSB were considered: a fire in the low-activity area

of the building, an explosion in the high-activity evaporator, and a facilitywide loss of

confinement event caused by natural phenomena or an external event. The loss of

confinement and fire accident events were revised with changes in the volumes and

radionuclide concentrations of the waste streams involved in the accidents. This included the

release of approximately 2 Ci and 1 Ci of americium to the environment for the loss of

confinement and fire accidents, respectively. The original WSB explosion accident was

removed from consideration because sufficient controls were determined to be in place to

prevent such an occurrence. The postulated earthquake, previously considered to be a

potential cause of the loss of confinement accident discussed above, was revised to include a

fire event in conjunction with the loss of confinement. Thus, the postulated earthquake was

added as a separate evaluation, the impacts being the sum of those estimated for the loss of

confinement and fire accidents.

Revision 4 Updates

The ER was updated in Revision 4 to include revised design information for the WSB. These

updates included an increase in the volume of solid LLW from 175 m3

 (228 yd3) to 205 m3

(265 yd3). The volume of nonhazardous liquid waste was changed from 240 million L/yr to

21 million L/yr (63 million gal/yr to 6 million gal/yr). The annual consumption of cement at the

WSB increased from 227,000 kg to 340,000 kg (500,000 lb to 750,000 lb), and the on-site

inventory of nitric acid decreased from 8,000 L to 1,000 L (2,000 gal to 350 gal). The WSB

accident source terms were revised in Revision 4 of the ER. The changes in the WSB design
Appendix J

J-8

were made to preclude the release of americium to the environment. Tables G-13 and G-14

were added to provide the material released to the environment from a postulated accident. 

The consequences of the accident analysis are summarized in Table G-16. The maximum

estimated impact to a site worker changed from 0.788 Sv to 0.00529 Sv (78.8 rem to

0.529 rem). The maximum estimated impact to a member of the public at the SRS site

boundary changed from 1.35 × 10-3 Sv to 9.8 × 10-6 Sv (1.35 × 10-1 rem to 9.8 × 10-4 rem).

Revision 5 Updates

The updates in Revision 5 of the ER concerned modifications to the WSB facility design to

accommodate changes in waste volumes. Volume changes were primarily a result of the

impacts from process optimizations, the removal of the silver recovery process, and the

decision to route the liquid LLW streams to the WSB for treatment rather than the SRS Effluent

Treatment Facility. However, discharges of the treated liquid effluents to surface water for the

proposed action would remain approximately the same. Radiation doses to facility workers were

not affected because administrative limits were used to compute exposure. Waste volumes

during the 10-yr operation period were revised from: 23,500 m3

 to 20,800 m3 for liquid LLW,

3,900 to 6,468 m3

 for solid LLW, 1,030 to 120 m3 for hazardous/mixed waste, 5,180 to 4,431 m3

for TRU waste, 43,500,000 to 602,000 m3 for nonhazardous liquid waste, and 39,900 to

41,000 m3

 for nonhazardous solid waste.

Further information on TRU waste treatment plans was incorporated into Revision 5 of the ER.

Current plans call for volume reduction of the TRU waste before packaging and shipment to

WIPP. An upper bound of approximately 8,240 m3

 would be generated over the project lifetime

if volume reduction at the WSB were not considered. The bounding impacts for shipment of the

non-reduced TRU waste to WIPP were added to provide a potential range of transportation

impacts. The number of TRU waste shipments over the WSB operating lifetime ranged from

299 to 2,314. No accidental fatalities or latent cancer fatalities from radiation exposure were

estimated. Up to one latent fatality from vehicle emissions was estimated for the bounding

case.

Revision 5 of the ER also removed references to the controlled area boundary. No changes to

impacts presented in the EIS were required as a result of this administrative change.

J.2.1.4 Comments on the DEIS

Comments received in the areas of (1) accident scenario and assumptions, (2) mitigation

measures, (3) air quality, and (4) waste management resulted in noteworthy changes to the

DEIS. Specific comments are discussed below. A summary of all the comments is provided in

Section J.3.

Accident Scenario and Assumptions: Comments on the DEIS varied from stating that the

accidents analyzed were overly conservative to stating that the accidents underestimated the

potential impacts. Many commenters questioned the assumption in the 1-year exposure

scenario that people would be allowed to ingest contaminated crops. Questions were raised
Appendix J

J-9

regarding the computer code that was used to estimate the impacts from hypothetical

accidents. It was stated that the accident scenarios lacked realism.

Additional text was added to Section 4.3.5 to clarify the assumptions used in the accident

analysis. In addition, a third accident scenario was included. This scenario assumes a 1-year

exposure period; however, crop ingestion is not included. The inhalation pathway immediately

following the accident and direct radiation pathway from contaminates deposited on the ground

from the hypothetical plume are included. The NRC reviewed the comments concerning the

use of the GENII code and determined that using the code was appropriate for purposes of

estimating impacts in the EIS from hypothetical accidents. The results of the accident analysis

are discussed in Section J.2.2.1 below.

Mitigation: Comments on the DEIS varied from stating that the proposed mitigation measures

were overly prescriptive to stating that the proposed mitigation measures were inadequate and

lacked detail. Commenters stated that the NRC used an overly broad definition for mitigation

such as stating that compliance with regulations was considered mitigation. The mitigation,

measures proposed for the potential environmental justice impacts were viewed by some

commenters as being unacceptable or inadequate.

The NRC determined that applying a broad definition of mitigation was consistent with CEQ

regulations and guidance. The mitigation discussion (Chapter 5) was revised to better identify

the proponent of the mitigation. As noted above, the impacts resulting from potential accidents

has changed in the FEIS. The rationale for developing mitigation measures for potential

environmental justice impacts has been added to the FEIS.

Air Quality: The statements in the DEIS regarding existing exceedances of the PM2.5

(particulate matter with a diameter less than or equal to 2.5 micrometers) standard for both the

24-hour and annual averaging periods, and the adequacy of the air quality data used to

establish background values were questioned. The DEIS data were based in part on an air

quality monitoring station that was a source-oriented, special-purpose monitor and thus not

appropriate for developing a background value of PM2.5. Data from air quality monitoring

stations greater than 80 km (50 mi) from the SRS were also improperly used to establish

background values in the DEIS. 

The background data were reanalyzed using updated data (see Section 3.4.3 and Table 3.3 of

the FEIS). Table 3.3 in the FEIS presents the results of this update and includes both the

highest and lowest ambient levels; the DEIS presented only the highest level. The air quality

impact analysis in Sections 4.3.2.1 and 4.3.2.2 (Tables 4.6 and 4.8) were revised using the new

background values. The FEIS concludes in Section 4.3.2 that the PM2.5 standard levels would

not be exceeded in the vicinity of the proposed MOX facility.

Waste Management: Commenters felt that the waste management section was confusing and

difficult to follow. The DEIS reported liquid waste volumes in cubic meters (m3

) rather than

gallons (gal) or liters (L). The waste management section in the FEIS (Section 4.3.4) has been

revised to describe how the waste is generated from each facility, how the waste will be
Appendix J

J-10

processed or treated by the SRS, and what the overall impacts of the proposed action are to

SRS waste management capabilities.

J.2.2 Changes in the DEIS

J.2.2.1 Revisions to the Human Health Risk of the Proposed Action

Human health risk impacts are discussed in Section 4.3.1 of the EIS. In the DEIS, radiological

and chemical impacts from the construction and operation of the PDCF, the proposed MOX

facility, and the WSB were estimated to be well within regulatory limits for both workers and

members of the public. The same outcome was determined in the revised analysis, which used

the corrected wind speed data, resulting in an increase in impacts to SRS employees and the

public, and which used lower ingestion rates of root vegetables, fruit, and grain for a maximally

exposed member of the public for the radiological impacts, resulting in lower impacts.

The accident with the highest radiological impacts in the DEIS was the hypothetical explosion at

the proposed MOX facility, with up to 50 latent cancer fatalities (LCFs) in the collective

population estimated as a result of the short-term exposure, and up to 200 LCFs if all the

contaminated crops were assumed to be eaten. The NRC has since allowed more credit

(a factor of 100) to be given to the HEPA filtration system in the proposed MOX facility for the

reduction in the amount released in both the hypothetical explosion and fire accidents at the

proposed MOX facility. Thus, the impacts of these accidents were estimated to be a factor of

100 lower in the reanalysis for the FEIS. In the interim, the WSB accident analysis was revised

on the basis of new scenarios and/or source terms, resulting in lower impacts by a factor of 2 or

more. 

J.2.2.2 Revisions to the Environmental Justice Impacts

Environmental justice impacts are discussed in Section 4.3.7 of the EIS. The DEIS concluded

that the no-action alternative would have no disproportionately high and adverse effects on

minority and low-income populations. The DEIS concluded that construction and operation of

the proposed facilities would not result in disproportionately high and adverse effects on

minority and low-income populations. On the basis of the accident analysis in the DEIS, the

DEIS concluded that there was a potential for low-income or minority communities to be

disproportionately impacted. Mitigation measures were proposed in Section 5.2.12 of the DEIS.

As discussed above, the NRC revised its accident analysis based on several factors. On the

basis of the revised analysis and information in the ER, the NRC concludes that the impacts

from potential accidents to low-income and minority populations could be high and adverse. 

The NRC believes that it is appropriate to mitigate these potential impacts. The NRC has

revised the suggested mitigation measures for potential environmental justice impacts in

Chapter 5.
Appendix J

J-11

J.2.2.3 Revisions to Mitigation Measures

Mitigation measures are discussed in Chapter 5 of the EIS. The NRC revised the mitigation

discussion to state that mitigation measures for the PDCF were previously evaluated by the

DOE and are not discussed further by the NRC. Therefore, the mitigation discussion is limited

to the proposed MOX facility and WSB. Text has been added to clarify mitigation measures

that are required by laws and regulations, those that are suggested by DCS as good practices,

and those that were identified by the NRC. 

The NRC staff has reviewed the mitigation measures and has concluded that no additional

mitigation measures are required beyond the regulatory requirements and those measures

identified by DCS.

J.3 Public Comments and NRC Responses

Sections J.3.1 and J.3.2 discuss comments related to general opposition or general support for

the MOX project, respectively. Sections J.3.3 through J.3.11 cover policy issues, including

purpose and need (J.3.3), the NEPA process (J.3.4), and the NRC licensing process (J.3.5). 

Comments on the scope of the EIS are covered in Sections J.3.6 through J.3.9. Sections

J.3.10 and J.3.11 discuss the alternatives to the proposed action. Sections J.3.12 through

J.3.29 discuss pertinent comments on technical issues and follow the order that such issues are

discussed in the draft EIS. The last section (J.3.30) responds to editorial comments. 

Readers can use Appendix K to link comment numbers to commenters. For example, for the

comments number 10-002, the document number is 10 and the individual comment number

is 2. Appendix L prints each comment document and indicates comments and comment

numbers in the margin.

The following acronyms appear frequently and are not spelled out with each use:

DCS Duke Cogema Stone & Webster

DEIS draft environmental impact statement

EIS environmental impact statement

FEIS final environmental impact statement

MOX ER Mixed Oxide Fuel Fabrication Facility Environmental Report

MOX facility Mixed Oxide Fuel Fabrication Facility
Appendix J

J-12

J.3.1 General Opposition

J.3.1.1 Comments: 10-002 79-001 116-004

 44-002 83-001

Comment: Opposition to the proposed MOX project was expressed because it was viewed

as experimental. It was stated that, for experimental programs, prototype models are

usually developed before final designs. It was noted no similar facility exists in this country. 

Because of this, it was suggested that the Nuclear Regulatory Commission (NRC) proceed

with caution.

Response: The technology for the proposed MOX facility is based on two existing facilities

in France. This technology has been adapted to comply with U.S. requirements or

incorporate U.S. preferences. U.S. requirements include requirements in the areas of

contracts, regulatory compliance, quality, design codes and standards, site and utility

interface, security, and safety practices and principles. U.S. preferences refer to

differences in the U.S. MOX design compared to the French design, including different

throughputs, differences resulting from isotopic differences in the plutonium, component

selection, and maintenance and operation. The design has progressed from a conceptual

design, where differences in the U.S. and French technology were identified, to a

preliminary design. The NRC is reviewing the principal structures, systems and

components of the proposed MOX facility to assure that its design is adequately safe. The

NRC staff’s findings to date will be discussed in the safety evaluation report (SER) for

construction. The NRC will review the final design if and when DCS submits a license

application. The NRC’s review of the final design will be documented in the SER for

operations. For further information see Section 1.1.2 of the EIS.

J.3.1.2 Comments: 66-001

91-007

Comment: Opposition to the proposed MOX facility was expressed. It was believed that

the assumptions and critical aspects of the analysis in the DEIS were flawed. 

Immobilization was considered to be a legitimate alternative that should have been

assessed in more detail. 

Response: The Nuclear Regulatory Commission (NRC) acknowledges the concerns

expressed in the comments. The assumptions and critical aspects of the analysis for the

proposed MOX facility were based on sound engineering and scientific principles. 

Immobilization was considered (see Section 2.3.3 of the EIS) but was not considered a

reasonable alternative.

There the NRC sets forth two reasons why immobilization of plutonium is no longer a

reasonable alternative to the proposed action (building and operating the proposed MOX

facility). 
Appendix J

J-13

First, immobilization of the 34 MT (37.5 tons) of surplus plutonium would not meet a key

element of the purpose and need for the proposed action, as described in Section 1.3. Due

to budgetary constraints, the DOE decided to cancel the immobilization portion of the

surplus plutonium disposition program and adopt a MOX-only approach. The DOE

determined that in order to make progress with available funds, only one approach could be

supported. The DOE stated that after evaluating the feasibility of implementing two

disposition approaches, it believed that the best way to make the most progress with

available funds while maintaining Russian interest in and commitment to surplus plutonium

disposition was to pursue a MOX-only disposition strategy. The DOE further stated that

Russia does not consider immobilization alone to be an acceptable approach. In the DOE’s

judgment, reliance by the United States on immobilization would therefore cause Russia to

abandon its plutonium disposition efforts. Because immobilization fails to degrade the

isotopic composition of the plutonium, Russia distrusts the immobilization alternative as it

would leave open the possibility of future retrieval and reuse of the plutonium in nuclear

weapons. As discussed further in Section 1.1.1, the DOE therefore concluded that reliance

on a MOX-only approach is the key to successfully completing the September 2000

agreement between Russia and the United States.

The second reason that immobilization is no longer a reasonable alternative to the proposed

action is its connection with the conduct of United States foreign policy. Evaluating the

immobilization alternative now would involve the NRC in foreign policy matters that the DOE

has been conducting on behalf of the United States. In the NRC’s view, an alternative that 

would block the implementation of an agreement with another country involves foreign

policy matters that are outside NEPA’s scope. Therefore, the NRC concludes that

immobilization is not a reasonable alternative requiring detailed analysis in this FEIS.

J.3.1.3 Comments: 2-004 61-001 105-001

24-009 64-001

Comment: The Nuclear Regulatory Commission (NRC) should not approve the

construction and operation of the proposed MOX facility.

Response: The NRC acknowledges the concerns expressed in the comments. Section 1.3

of the EIS discusses the need for the proposed action, particularly as part of a larger

strategy for plutonium disposition. This strategy is intended to protect against the

proliferation of material capable of being used in weapons of mass destruction. 

J.3.1.4 Comments: 4-005 85-002

20-001 96-001

Comment: The proposed MOX project will contribute to the legacy of radioactive and

chemical contamination at the Savannah River Site (SRS). 

Response: The Department of Energy (DOE) is currently involved in treating and restoring

contaminated sites at the SRS. Section 3.9 of the EIS discusses the current waste

management program in place at the SRS. The program consists of waste minimization,
Appendix J

J-14

characterization, treatment, storage, transportation, and disposal. Section 4.3.4 of the EIS

discusses waste management associated with construction and operation of the proposed

MOX facility, the Pit Disassembly and Conversion Facility (PDCF), and the Waste

Solidification Building (WSB). All wastes associated with the project would be treated

and/or disposed of in accordance with applicable regulations. This issue is further

discussed in Comment J.3.7.4.

J.3.1.5 Comments: 8-001 30-001 46-001

12-001 32-004 99-001

Comment: Opposition was expressed for any activity that involves the manufacture,

processing, and transportation of radioactive materials. Local communities should not have

to be exposed to increased nuclear contamination or waste. 

Response: The Nuclear Regulatory Commission (NRC) acknowledges the commenters’

opposition to activities that involve the transportation, handling, and processing of nuclear

materials. The EIS describes the actions that would be undertaken to protect the safety of

both workers and the public. This includes following all applicable NRC regulations and

Department of Energy orders pertaining to the transport, storage, handling, and processing

of special nuclear materials. 

J.3.1.6 Comments: 10-006 69-001 90-001 106-001

10-022 71-004 98-001 109-001

22-003 77-009 98-010 110-001

44-006 84-001 104-001 112-001

Comment: Several commenters opposed the proposed project believing it to have an

unacceptable level of risk to humans and the environment. The safety of the proposed

MOX facility was questioned, particularly in regards to terrorist threats. Safety

considerations were also expressed concerning the transportation of special nuclear

materials. It was stated that the MOX facility would be counterproductive in reducing

nuclear risks because it would allow plutonium to enter civilian commerce and the

international marketplace. Instead of the proposed project, safer and cleaner alternatives

(i.e., immobilization or no action) should be pursued. 

Response: The Nuclear Regulatory Commission acknowledges the commenters’

opposition to the proposed action as a means of surplus plutonium disposition. The goal of

the surplus plutonium disposition program is to securely dispose of surplus plutonium and

thereby reduce the threat of nuclear weapons proliferation. 

The proposed action fulfills the goal of the surplus plutonium disposition program. The

design, construction, and operation of the proposed MOX facility are expected to be within

reasonable cost limits. Further, MOX fuel production benefits national security by reducing

plutonium supplies. National security would improve because the number of locations

where plutonium is currently stored would be reduced. Thus, converting surplus plutonium
Appendix J

J-15

to MOX fuel was viewed by the Department of Energy (DOE) as a means of ensuring that

the plutonium would not be obtained by rogue states and terrorist groups.

For a full discussion of the proposed action alternative and the immobilization alternative,

see Sections 2.2 and 2.3.3 of the EIS, respectively. The impacts of the proposed action

are discussed in Section 4.3 of the EIS.

Continuing research and development activities are expected to minimize technical risks of

the proposed action. Further, the MOX Facility would be contained within the SRS, which is

a secure DOE site. 

Transportation of nuclear materials to or from the MOX Facility would be done in

accordance with applicable orders and regulations. Couriers would be required to pass a

background investigation, receive DOE’s highest security clearance, be certified to operate

safe, secure trailer/Safeguards Transporter, possess mental alertness, and meet physical

performance requirements. Couriers are also trained in firearms, tactics, and driving. 

Furthermore, couriers receive specialized training in physical fitness, communications,

radiation, and hazards detection. Emergency management training for couriers includes the

above-mentioned areas, nuclear weapons safety, hazardous materials safety, emergency

response training, general firefighting, and fire prevention explosive hazards. Any licensee

seeking authority to use MOX fuel in a commercial reactor must apply to the NRC for a

license amendment. Any such use of MOX fuel would involve a once-through cycle with no

reprocessing of the spent MOX fuel.

J.3.1.7 Comment: 105-014

Comment: Stakeholders, who are concerned and alarmed by the proposed actions, are

supposed to be protected by an impartial, unbiased and fair assessment performed by our

government protectors (e.g., DOE, NRC, etc.). This DEIS fails to demonstrate that the

public will be protected. The DEIS is biased in favor of the proposed action. This is illegal

and fails the spirit of the laws meant to protect the citizens of this United States of America. 

It should be clear that the Nuclear Regulatory Commission (NRC) has good reasons to

reject the requested license. 

Response: The NRC has prepared this MOX facility EIS in accordance with the provisions

of the National Environmental Policy Act (NEPA) (42 U.S.C. 4321 et seq.) and the related

Council on Environmental Quality (CEQ) and NRC implementation regulations (40 CFR

1500 – 1508 and 10 CFR Part 51). As discussed in Section 1.1.2, this EIS is part of the

NRC’s decision making process regarding the potential licensing of the proposed MOX

facility. The primary objective of the EIS is to provide a comprehensive description of the

proposed action, alternatives, and the potential environmental impacts. Section 1.1.1 of the

EIS provides an overview of the Surplus Plutonium Disposition Program and the steps that

have led to the MOX fuel approach being selected as the preferred alternative by the DOE

in its program for reducing the supplies of weapons-grade plutonium. The previous EISs

evaluated relevant alternatives that resulted in the decision to proceed with the MOX facility

as the preferred alternative. Section 2.3 of the EIS explains why several alternatives were
Appendix J

J-16

not analyzed in detail in the current EIS. The no-action alternative, which is assessed in the

current EIS, is the continued storage of surplus plutonium at seven DOE facilities. This

alternative was analyzed in detail in the Surplus Plutonium Disposal EIS prepared by DOE

in 1999. 

J.3.2 General Support

Comments: 11-001 17-001 26-001 51-001 57-001 63-001

14-001 21-001 49-001 54-001 59-001 86-001

16-001 25-001 50-001 55-001 60-001

Comment: Commenters indicated general support for the proposed MOX facility, including

issuing the license for its construction and operation in a timely manner. The proposed

MOX facility will contribute to worldwide safety and security by making nuclear materials

unusable as weapons. Additionally, construction and operation of the proposed MOX

facility will provide benefits to the local economy. The proposed MOX facility will also

provide a source of clean fuel for generating electricity. It is believed that the proposed

MOX facility will operate safely. Confidence was also expressed in the technical abilities of

all parties involved with the proposed MOX facility.

Response: The Nuclear Regulatory Commission acknowledges the comments in support

of the proposed action and the agencies and organizations that are involved in the project.

J.3.3 Purpose and Need

J.3.3.1 Comments: 37-003

53-010

72-003

Comment: Reliance on the United States-Russia Agreement for the purpose and need

statement was questioned. This reliance has resulted in the dismissal of other alternatives. 

The statements made by the U.S. Department of Energy that Russia will only proceed with

the agreement if the United States disposes of its excess plutonium through MOX fuel

production are unsupported. The NRC’s reliance on the DOE’s statements, that MOX was

the only practical alternative that Russia would accept, limited the NRC’s detailed

consideration of other alternatives. The commenters questioned the NRC’s elimination of

other alternatives, solely to avoid violating the United States-Russia Agreement. The status

of the agreement should be addressed in the DEIS. It was felt that the NRC’s hiding behind

the United States-Russia Agreement was misleading because the United States does not

follow international nuclear treaties. The U.S. government has pulled out of several

international treaties. Therefore, stating that the United States does not want to interfere

with the United States-Russia Agreement is erroneous.
Appendix J

J-17

Response: Section 1.3 of the EIS discusses the purpose and need for the proposed NRC

licensing action (authorizing the construction and operation of a facility to make MOX fuel). 

This action is part of the larger surplus plutonium disposition program being implemented by

the U.S. Department of Energy (DOE). As described in Section 1.1.1 of the EIS, the DOE

program stems from decisions made by the United States and the Russian Federation to

mutually reduce each nation’s stockpiles of weapons-grade plutonium. In September 2000,

the United States and the Russian Federation agreed to disposition 34 metric tons

(37.5 tons) of surplus weapons-grade plutonium from each nation’s stockpiles. In

implementing its part of this agreement on behalf of the United States, the DOE in 2002

decided that for budgetary reasons it could no longer pursue its planned hybrid approach

under which part of the 37.5 tons of surplus weapons-grade plutonium would have been

immobilized. In addition, the DOE in its Amended Record of Decision (ROD) stated that a

MOX-only approach best ensures the joint reduction of existing plutonium stockpiles and is

the key to successfully completing the United States-Russia Agreement. Accordingly, the

DOE canceled its plans to build and operate a plutonium immobilization plant. Instead, the

proposed MOX facility – if it is built and operated – would convert the 34 metric tons

(37.5 tons) of surplus weapons-grade plutonium into MOX fuel. This fuel would then be

irradiated in nuclear reactors authorized to use such fuel, thereby making the plutonium

component of the fuel inaccessible for reuse as nuclear weapons material. As stated in

Section 1.3 of the EIS, the general purpose of and need for the proposed MOX facility is

thus to help reduce the threat of nuclear weapons proliferation by ensuring that surplus

weapons plutonium is converted to a proliferation resistant form. 

The statement of purpose and need is used to differentiate alternatives that should be

analyzed in detail from those that do not need to be analyzed in detail. While national

policy does not generally preclude alternatives that can be considered in an EIS, an EIS

need not consider alternatives that would change U.S. foreign policy. Therefore, the NRC

concluded that the proposed action to build and operate a MOX facility and any reasonable

alternatives to that proposed action should be consistent with the United States-Russia

Agreement and the goal of both the United States and Russia disposing of surplus

plutonium. The fact that the United States has, in some cases, withdrawn or not fulfilled

unrelated agreements or treaties in the past is not germane. 

Additional comments were received relative to the United States-Russia Agreement. These

comments and their responses can be found in Section J.3.7, Scope - DOE Policy and

J.3.11, Alternatives - Immobilization.

J.3.3.2 Comment: 96-022

Comment: Concern was expressed that a new plutonium pit disassembly and conversion

facility (PDCF) would be constructed at the Savannah River Site.

Response: The PDCF is needed to remove the plutonium from weapons pits and convert it

to a form that can enter the proposed MOX facility for conversion to reactor fuel.
Appendix J

J-18

J.3.4 NEPA Process

J.3.4.1 Comments: 5-002 32-001 46-002 96-009

 5-003 45-003 77-008 96-015

 7-003 45-002 96-004 96-015

Comment: The lack of influence of the general public opinion on the National

Environmental Policy Act (NEPA) process and Nuclear Regulatory Commission (NRC)

decision making was raised. It was stated that the NRC does not care about the more than

200,000 people living in Savannah and Chatham County or those Georgians and South

Carolinians living downwind and downstream of the Savannah River Site (SRS). Individuals

believed that everyone in Savannah could be opposed to the proposed MOX facility and this

issue would not affect the NRC’s decisions. Some comments indicated the decision was

already made and the NRC was just going through the motions. It was stated that the MOX

DEIS was a clear violation of NEPA. This raised the issue that the NRC licensing process

was not a democratic process. Furthermore, the decision of whether to move forward with

the proposed MOX facility would be decided by people who will not be living near the

proposed facility. It was also felt that the people who could be affected by the proposed

MOX facility should be notified and that additional outreach to disadvantaged or vulnerable

communities should be done. 

Response: The NRC has a well defined process for determining whether to grant a license

for the proposed MOX facility. The NRC follows a process required by federal regulations

and NEPA. For the proposed MOX facility, the NRC’s decision making process included the

preparation of an environmental impact statement (EIS) that seeks the opinions of affected

stakeholders. In determining the scope of the environmental review, the NRC contacted

affected communities, including disadvantaged and vulnerable communities, to determine

significant issues prior to conducting any analysis (See Section 1.4 of the EIS). Additional

meetings were held with stakeholders to inform them of the progress of the NRC’s

environmental review and to solicit comments on the DEIS after it was published. The NRC

advertised the availability of the DEIS and mailed copies of the DEIS to approximately 600

people. The NRC will take into consideration the FEIS findings and safety analyses before

any final decisions are made. 

J.3.4.2 Comments: 61-006 96-010 96-024

64-003 96-023 97-001

Comment: The timing of the environmental impact statement (EIS) in the overall licensing

process was questioned. It was suggested that the Nuclear Regulatory Commission (NRC)

should do another EIS because of the uncertainty about what the actual process,

parameters and scope will be. It was also suggested that the NRC extend the comment

period on this DEIS until the safety evaluation report (SER) for the operating license is

complete. It was stated that the NRC might need to redo its analysis as future decisions

unfold if the report is to be fully responsive to the proposed actions. In addition, there may

be a potential segmentation problem with regard to the way the NRC has chosen to

evaluate this particular action. Specifically, there was a concern about the adequacy of the
Appendix J

J-19

NRC’s evaluation of connected actions, such as the use of MOX fuel and the effects of

accident sequences at the McGuire and Catawba reactors.

Response: The EIS includes construction, operation and decommissioning impacts

associated with the proposed action. Impacts include those from connected actions as

discussed in Section 1.2.2 of the EIS. The connected actions included impacts from using

MOX fuel in reactors. As discussed in Section 4.4.3 of the EIS, the impacts from using

MOX fuel are presented in a generic fashion and include impacts from normal operations at

reactors as well as impacts from potential accidents. 

Although many of the design details for the proposed MOX facility have yet to be finalized,

the impacts associated with operating were analyzed based on experience from similar

facilities in France. The estimated impacts provided by DCS were reviewed and found to be

sufficient for purposes of preparing the EIS. If, later in the process, the impacts are greater

than those presented in the EIS, the NRC would determine whether a supplemental EIS

would be required.

J.3.4.3 Comments: 9-004

35-006

43-006

Comment: It was suggested that the Nuclear Regulatory Commission (NRC) conduct an

independent external review of the DEIS.

Response: Part of the National Environmental Policy Act (NEPA) process is a review of the

DEIS preliminary findings by the public and other stakeholders. The DEIS is published for

public comment, and comments received by the NRC are considered in finalizing the EIS. 

This process provides for independent external review by the public. In addition, there was

a concern raised during a scoping meeting regarding a potential conflict of interest because

the NRC is using Argonne National Laboratory to assist in preparing the EIS of a

Department of Energy (DOE) linked facility. To allay any concerns about the use of

Argonne, the NRC hired the Center for Nuclear Waste Regulatory Analysis (CNWRA) to

conduct an independent external review of the DEIS, the comment response document, and

the FEIS. The CNWRA is a non-profit, independent group that was established to assist

the NRC in reviewing high level waste documents prepared by the DOE and its contractors. 

The CNWRA has been shown to not have any conflicts of interest with respect to the DOE.

J.3.4.4 Comments: 10-007 66-006 97-001

44-007 96-008 97-006

Comment: An extension of the formal comment period beyond the adjusted May 14, 2003,

deadline was requested. The reasons for the requests included the timing of information

provided by the Nuclear Regulatory Commission (NRC) regarding two errors in the DEIS

and the complex nature of the DEIS. Also it was stated that the public should be given the

opportunity to compare the DEIS and the safety evaluation report (SER) together and be

allowed to have a 30-day overlapping period.
Appendix J

J-20

Response: The NRC considered the requests for extending the comment period and

determined that 75 days was adequate to allow stakeholder review and comment (10 CFR

51.73). Although the radiological dose values changed as a result of errors identified by the

NRC, the revised values did not change the conclusions and preliminary recommendation of

the DEIS.

J.3.4.5 Comments: 5-003 23-001 61-002 75-001

 7-001 45-003 62-001 96-023

13-002 47-003 62-003 96-024

19-001 55-002 66-006 96-028

Comment: In accordance with the National Environmental Policy Act (NEPA) process,

citizens must be informed of the proposed action and provided the opportunity to comment

when the DEIS is published. The citizens in the area surrounding the Savannah River Site

(SRS) felt the NRC did not sufficiently inform the local citizens about the public meetings. 

Some individuals believed the meetings were held only to tell the public what will be done

next, and the citizens had no input in the process. There were general requests to hold

additional meetings so citizens would not be rushed in reviewing the DEIS. There were also

requests to hold meetings in Columbia and Charleston, SC. Several individuals requested

additional meetings be held in North Augusta, which is in the area most highly affected by

the proposed MOX facility. Likewise, commenters indicated additional meetings should be

held in black communities, which also would likely be affected. It was recommended that

the Nuclear Regulatory Commission (NRC) delay its decision until environmental justice

communities’ input could be considered in the decision making process.

Response: The NRC acknowledges the concerns expressed by the commenters. The

NRC considers the distribution of the DEIS and the public meeting notification process to be

adequate.

In accordance with NRC regulations, the NRC staff published a notice of availability for the

DEIS in the Federal Register (68 Fed. Reg. 9728, February 28, 2003). In the notice, the

NRC staff provided information on how to obtain a free copy of the DEIS, listed contact

people, and listed information about the public meetings. From February 28, 2003, to

May 2003, the NRC distributed over 750 copies of the DEIS to state and local government

officials and to the general public. Due to the vast amount of material in the DEIS, the NRC

extended the comment period to May 14, 2003, and notified the public of the extension in

the Federal Register (68 Fed. Reg. 12720, March 17, 2003). 

During the comment period, the NRC held three public meetings regarding the DEIS

(March 25, 2003, Savannah, GA; March 26, 2003, North Augusta, SC; and March 27, 2003,

Charlotte, NC) to receive oral public comments on the DEIS. The NRC sent out invitation

letters to over 550 citizens informing them of the meetings. The NRC also advertised the

meetings in the local papers and on the local government television channels in Savannah,

North Augusta, and Charlotte. These meetings were held to give interested citizens an

opportunity to ask questions and to offer comments. Based on the number of commenters,

it was necessary to limit the length of each comment in order to provide as many people as
Appendix J

J-21

possible with an opportunity to speak. When announcing the time limitations, the agency

emphasized that detailed comments could be submitted in writing.

The NRC staff selected the meeting venues in an effort to reach those members of the

public who would most likely be affected by any impacts of the proposed action. The NRC

staff participated in one meeting hosted by the Imani Group and the Citizens for

Environmental Justice to provide additional project information to members of the

community concerned with environmental justice. Based on these public involvement

activities, the NRC considers the public meetings for the DEIS sufficient to fulfill its NEPA

requirements.

J.3.4.6 Comments: 8-002 96-008

46-003 96-031

95-001

Comment: It was stated that the DEIS was difficult to understand and form impressions

about. It was stated that the DEIS should be more “community and user friendly” by clearly

stating what is proposed, why, and potential real impacts on the environment, health,

economy, and ecology of the operation of the proposed MOX facility. A specific case was

mentioned with the use of the words significant and insignificant, indicating that a definition

of significant would be helpful.

Response: The Nuclear Regulatory Commission (NRC) staff notes the comments about

document readability and shares the commenters’ belief that an EIS should be written in

plain language. The NRC believes that the EIS is written in plain language. However, the

NRC recognizes that the EIS contains highly technical aspects that may be difficult to

understand. In preparing the EIS, the staff attempted to write to as broad and diverse an

audience as possible. The way impacts have been characterized has been changed from

significant or insignificant in the DEIS to small, moderate and high. Definitions for these

qualifiers are provided in Section 2.4 of the FEIS. 
Appendix J

J-22

J.3.4.7 Comments: 10-007 44-007 96-003 96-029

13-002 59-002 96-018

Comment: It was felt that the DEIS presented misleading information, particularly the

environmental impact portion of the DEIS. It was stated that documents must not be

published for comment with incorrect calculations, and if this occurs the process for

commenting must be extended. Given the errors in the DEIS, it was questioned how the

public could be sure that the information was correct. In addition it was stated that the

DEIS was published containing large computer errors miscalculating high death counts in

low income, minority communities. It was also stated that there may have been a number of

inadequacies found that causes even more concern about the concreteness of the data. It

was suggested that the Nuclear Regulatory Commission (NRC) did not adequately inform

local communities about the error or provide sufficient opportunity for them to comment on

these errors. It was suggested that additional public meetings needed to be held.

Response: The NRC shares the concern about having mistakenly published erroneous

information. The NRC identified the errors shortly after the DEIS was published. When the

NRC discovered the errors, it took steps to quickly notify stakeholders and provide

corrected information. Moreover, the NRC extended the comment period by 30 days. The

NRC published in the Federal Register (68 Fed. Reg. 12720, March 17, 2003) information

pertaining to the errors, explaining the errors and providing information on how to contact

the NRC staff for additional information. At the subsequent public meetings, the NRC

identified additional errors and informed the public that errata sheets would be mailed. The

NRC staff mailed over 700 copies of the errata sheets to the public after these meetings

were held. 

J.3.4.8 Comment: 116-001

Comment: Arbitrary deadlines appear to be the managing force behind the MOX safety

review. Deadlines should take a back seat to safety, so that the public develops confidence

that the Nuclear Regulatory Commission (NRC) is protecting them. 

Response: We agree with the commenter. The NRC’s primary mission is the protection of

public health and safety and the environment. As discussed in Section 1.1.2 of the EIS, the

NRC’s licensing decisions are based on an environmental review and a safety review. The

NRC does not permit regulated action to be taken until both reviews are completed and any

outstanding safety issues are satisfactorily resolved. While internal schedules must be

established to manage projects, the NRC’s decisions are not based on schedules. 

J.3.4.9 Comment: 116-018 

Comment: The terms “unlikely,” “highly unlikely,” and “incredible” should be associated

with quantitative criteria that meet some standard. 

Response: The Nuclear Regulatory Commission (NRC) has not associated quantitative

criteria with the terms “unlikely,” “highly unlikely” or “incredible.” The regulations in 10 CFR
Appendix J

J-23

Part 70 allow applicants to propose definitions for these terms, which may be qualitative or

quantitative. The applicant, DCS, has defined “unlikely” to mean events that are not

expected to occur during the lifetime of the facility but may be considered credible. “Highly

unlikely,” as defined by the applicant, means events originally classified as not unlikely or

unlikely to which sufficient principal structures, systems and components are applied to

further reduce their likelihood to an acceptable level. The applicant also defined “not

credible” events as those natural phenomena or external man-made events with an

extremely low initiating event frequency and process events that are not possible.

J.3.5 Licensing Process

J.3.5.1 Comments: 13-001 80-001 93-001

61-003 81-003 103-001

78-002 92-001

Comment: The use of a two part licensing process (construction and operation) for the

proposed MOX facility was of concern to stakeholders. Several comments indicated that

both construction and operation were not adequately addressed in the DEIS. The

comments reflected that the MOX application was split into two parts (construction and

operation), but the DEIS contained no review of the operations data. Separating these two

parts of the licensing process was considered irresponsible. It was felt that the

environmental impacts of operation must be considered before the DEIS process is

complete. Stakeholders felt that the Nuclear Regulatory Commission (NRC) was going to

sign off on the DEIS before operational plans were taken into consideration and

environmental impacts of operation were analyzed. 

Response: The ER submitted by DCS (as revised) contains sufficient information to

analyze the potential environmental impacts of constructing and operating the proposed

MOX facility. On the basis of this information, the EIS sets forth the NRC’s environmental

analysis. The NRC’s NEPA regulations do not call for delaying the NRC’s environmental

review until completion of its operational safety review. On the contrary, to meet its NEPA

obligations, the NRC must begin its environmental review early enough to allow completion

before any action is taken that would significantly affect the environment. With respect to

the proposed MOX facility, the environmental effects would begin with construction, and are

not confined to operation. Accordingly, the NRC has properly completed its environmental

review at the pre-construction stage.

J.3.5.2 Comment: 29-003

Comment: Questions were raised about the financial responsibility of the MOX project. A

question was raised about who would be responsible for the decontamination of the four

Duke reactors in the event of a financial collapse. In addition it was asked, whether the

Duke reactors provide enough spent fuel to make MOX fabrication economical if the

demand for electricity decreases. 
Appendix J

J-24

Response: The financial health of Duke Power has no bearing on whether DCS has

demonstrated that it will be able to obtain funds sufficient to build, operate, and

decontaminate the proposed MOX facility in accordance with Nuclear Regulatory

Commission (NRC) regulations on the environmental impacts of the proposed action’s 

costs or benefits. NRC regulations (10 CFR 50.75) require existing reactor licensees, such

as Duke Power, to provide financial assurance for decommissioning power reactors. The

amount is based on either a standard NRC formula provided in the regulation or a plant

specific cost estimate performed by the licensee. The funding must then be set aside as

prepayment or in an external sinking fund such as a trust or escrow account or by other

guaranteed method. The existing reactor licensee must report to the NRC every two years

on the status of the decommissioning fund (every year after decommissioning has begun)

and the NRC reviews these reports. Additionally, there are limitations on the amount of the

decommissioning funds which may be spent until the existing reactor licensee has

submitted a post-shutdown plant specific decommissioning cost estimate.

Although the rate has varied, the demand for electricity in the U.S. has steadily increased. 

The NRC expects that the Duke reactors will provide a reliable demand for the MOX reactor

fuel.

J.3.5.3 Comment: 76-001

Comment: The EIS addresses the question of cost versus benefits throughout the

document. Because of the consideration of cost and benefits, it raises the question of

whether the Nuclear Regulatory Commission (NRC) is not a promoter of nuclear energy. As

such, it was further questioned whether the NRC could act impartially and would act in the

public interest. 

Response: The Energy Reorganization Act of 1974 established the NRC as an

independent government agency whose mission is the protection of public health and safety

and the environment from the commercial uses of nuclear materials. Prior to 1974, the

Atomic Energy Commission, the predecessor agency to the NRC and the Department of

Energy, was criticized for both regulating and promoting nuclear energy. Therefore, the

NRC was established as an independent agency that reports to Congress rather than the

Executive Branch. 

J.3.5.4 Comment: 95-003

Comment: The Nuclear Regulatory Commission (NRC) should use its influence on other

policy-makers to review what is being proposed and redirect the surplus plutonium

disposition program in a way that addresses the legitimate concerns of those living

downstream of the Savannah River Site (SRS). 

Response: As discussed in Section 1.1.2 of the EIS, Congress gave the NRC licensing

and related regulatory authority over the proposed MOX facility. As part of its mission to

protect public health and safety and the environment, the NRC is preparing a safety review
Appendix J

J-25

and an environmental review of the proposed MOX facility, in accordance with NRC

regulations, the National Environmental Policy Act, and the Atomic Energy Act.

As noted in the comment, the NRC does not have jurisdiction over the SRS. However, part

of the EIS process includes consideration of alternatives and impacts that may be outside

an agency’s regulatory authority. As discussed in Section 1.2.2 of the EIS, the NRC has

included the impacts of connected DOE facilities. Furthermore, the existing environmental

conditions at the SRS have been presented in Chapter 3 of the EIS. Another part of the EIS

process is issuing the EIS in draft form for public comment. This includes seeking

comments from other federal and State agencies, such as the Department of Energy, the

Environmental Protection Agency, and the South Carolina Department of Health and

Environmental Control. In addition, the NRC has proposed mitigation measures in

Chapter 5 of the EIS to reduce potential impacts from the proposed action, including

connected DOE facilities.

J.3.5.5 Comment: 116-005

Comment: The Nuclear Regulatory Commission (NRC) is licensing the proposed MOX

facility and is not licensing the Waste Solidification Building (WSB) or the Pit Disassembly

and Conversion Facility (PDCF). The proposed MOX facility will generate chemical and

radioactive waste, which is then transferred to unlicenced facilities for disposal. Given the

polluting history of the Savannah River Site (SRS), it was suggested the NRC get involved

with the proper disposal of the wastes generated by MOX. Incineration, burial, and

transport of chemical and radioactive wastes require the NRC to become involved through

the EIS in a proper outcome. The NRC should reconsider the bounds of its EIS. 

Response: As noted in the comment, the NRC does not have regulatory (licensing)

authority over the Department of Energy's PDCF, WSB, or waste processing and disposal

facilities. Section 1.2.2 of the EIS discusses connected actions that are considered in the

EIS. These include impacts from the PDCF, WSB, and waste processing and disposal

facilities. Impacts for various resource areas from the PDCF and WSB are discussed in

Chapter 4 and Appendix H of the EIS. The impacts associated with waste management are

discussed in Section 4.3.4. Existing contamination at the SRS is discussed in the affected

environment portions of the EIS (Chapter 3). The impacts referenced by the commenter

are discussed in the EIS. Under NEPA, the NRC is obligated to consider impacts of

connected actions such as waste management. However, acting on the suggestion that the

NRC get involved with the DOE’s waste disposal efforts would be outside of the NRC's

regulatory authority. 
Appendix J

J-26

J.3.6 Scope – General

J.3.6.1 Comments: 5-004 32-002 56-005

19-008 45-004

Comment: The use of a 50-mile radius as a boundary to assess impacts was questioned. 

It was stated that a major accident could impact an area greater than 60 miles, and the

Chernobyl accident was cited as an example. The DEIS does not address the

environmental impacts on the Savannah area. It was suggested that the evaluation of

environmental justice impacts should be expanded to include impacts to downstream

communities regardless of their racial or income demographics. 

Response: The geographic area, in which impacts are assessed, varies depending on the

type of technical area being evaluated. For example, cultural resource impacts are

evaluated only in the vicinity of the site, because constructing and operating the proposed

MOX facility would not impact cultural resources at a great distance from the proposed

MOX site. But, air quality impacts are evaluated both on local and regional scales, and the

cost-benefit analysis evaluates impacts on national and regional scales. The geographic

area used to assess human health impacts to the public was selected to be a 50-mile radius

from the proposed MOX site. The estimated doses to the public would decrease with

distance from the site, because accident impacts to the public result from airborne plumes

and the concentration of the plume decreases significantly with distance. The 50-mile area

was considered sufficient to reasonably bound the impacts from a postulated accident

without diluting collective doses to the public. This 50-mile area was also used in assessing

the environmental justice impacts. 

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority

Populations and Low-Income Populations, issued in 1994, directs executive branch

agencies to address, as appropriate, any disproportionately high and adverse human health

or environmental effects of their actions, programs, or policies on minority populations and

low-income populations. Guidelines for performing environmental justice reviews are

described in the Nuclear Regulatory Commission’s NUREG-1748. The first step in the

process is to determine if a site has a potential environmental justice concern based on the

identification of low-income and minority populations that could be affected by the proposed

action. The next step is to determine whether possible impacts would disproportionately

impact these populations. Finally, if it is determined that there would be a potential impact,

as assessment would be made as to whether the impact of any aspect of the construction

or operations of the proposed facilities (including accidents) on low-income or minority

populations would be both “high and adverse.” (See Section 4.3.7.1 for a more detailed

description.)

As discussed above, the 50-mile area was considered sufficient to reasonably bound the

impacts to human health. Savannah, Georgia, is located just outside the 50-mile radius and

is not expected to be significantly impacted by airborne release from the most severe

accident evaluated. As discussed in Section 4.3.7.3, the EIS considered impacts to

downstream communities, including impacts to surface water quality of the Savannah River.
Appendix J

J-27

(Also, see Comment J.3.29.1 for further information.) The scope of the EIS is thus

considered sufficient.

J.3.6.2 Comments: 33-001 77-001

72-014 96-033

Comment: The scope of the DEIS and the range of impacts assessed was considered to

be too limited and not broad enough in scale. For example, an assessment of risk for

humans and the environment should be done to include all the processes involved in the

MOX production, in its transport, and in its use as a fuel. It was felt that the reactor use

evaluation should include impacts on affiliated nuclear services such as nuclear laundries,

component repair, decontamination services, and decommissioning. It was suggested that

a programmatic EIS must be conducted that considers and addresses all parts of the MOX

related activities which includes the current MOX EIS, supplemental EIS for the license

renewal for the four Duke nuclear power plants, the lead test assemblies, MOX use in

reactors and new plutonium processing. It was felt that the cost benefit analysis should

include other types of costs.

It was stated that information in the DEIS was presented in a fragmented manner and that it

is very difficult to see the whole picture. 

Response: The scope of the proposed action is described in Section 1.2 of the EIS. It

includes impacts for transportation of feedstock material, conversion of depleted uranium,

processing of metal plutonium into powder at the Pit Disassembly and Conversion Facility,

fabrication of MOX fuel at the proposed MOX facility, waste management, transport of

fresh, unirradiated fuel, use of MOX fuel in reactors, transportation of spent MOX fuel, and

decommissioning the surplus plutonium disposition facilities. This range of activities is

considered sufficient to reasonably bound the full range of impacts associated with the

potential construction and operation of the proposed MOX facility. The cost benefit analysis

is presented in Section 4.6 of the EIS and includes a variety of costs on both the national

and regional scale. It is not clear from the comments which other costs should be

considered. While the impacts associated with various resource areas are discussed in

detail in Chapter 4 of the EIS, a concise summary of the impacts of the proposed action and

no-action alternatives is provided in Section 2.4.

As discussed in Section 4.4.3, the impacts associated with using MOX fuel are discussed in

the Department of Energy’s (DOE) Surplus Plutonium Disposition (SPD) EIS. The DOE’s

analysis is provided in Section 4.28 and Appendix K.7 of the SPD EIS and includes the

areas of concern to the commenter. 

As discussed in Section 1.1 of the EIS, the DOE is responsible for the overall surplus

plutonium disposition program. Pursuant to Congressional mandate, the NRC is

responsible for only a small portion of the surplus plutonium disposition program, namely

regulatory authority over the proposed MOX facility. It would be inappropriate for the NRC

to conduct a programmatic EIS, duplicating analyses previously performed in the SPD EIS. 

The NRC is performing a separate National Environmental Policy Act (NEPA) review
Appendix J

J-28

pertaining to the pending license amendment request to use MOX lead test assemblies at

those reactors. 

J.3.6.3 Comments: 14-004 89-008

63-004 89-014

Comment: The inclusion of impacts from the Pit Disassembly and Conversion Facility

(PDCF) and Waste Solidification Building (WSB) was questioned. It was stated that the

DEIS places unwarranted emphasis on impacts associated solely with the PDCF. The

PDCF is not necessarily solely required to support the proposed MOX facility. The Nuclear

Regulatory Commission (NRC) creates the implication that impacts from the PDCF will not

occur if the MOX construction authorization is denied. PDCF and MOX are two separate

actions. The DOE has previously prepared an EIS for the PDCF, with the finding that the

facility provides adequate protection to the public and the environment. The NRC should

not subject the PDCF facility to National Environmental Policy Act (NEPA) double jeopardy. 

It was further stated that the NRC should not have re-analyzed impacts associated with the

PDCF, because the EIS is limited to the licensing action now under review. It was also

stated that the EIS presents the impacts associated with the WSB out of context. It was

stated that the WSB is part of the PDCF complex and should be discussed as such. Both

the proposed MOX facility and PDCF comprise major production buildings and several

smaller associated buildings. Similar waste from the PDCF and proposed MOX facility that

would have been processed separately is now processed in a single WSB, thereby reducing

the amount of space and equipment needed for both the proposed MOX facility and PDCF. 

The DEIS should be revised so as not to give the impression that the WSB is a major standalone facility.

Response: Section 1.1.2 of the EIS discusses connected actions to the proposed action

(i.e., potential licensing of the proposed MOX facility). In determining that the PDCF and

WSB are “connected actions,” the NRC found that in order for the proposed MOX facility to

fulfill its functions, the DOE would need to build and operate the proposed PDCF and WSB. 

As discussed in Section 1.4, the NRC concluded that because of the Department of

Energy’s (DOE’s) decision to pursue a MOX-only approach, the PDCF no longer had

independent utility apart from the proposed MOX facility. The impacts for the PDCF were

taken from the DOE Surplus Plutonium Disposition EIS, except where the impacts were

reanalyzed to be consistent with the methodology used by the NRC for the proposed MOX

facility. The NRC determined that presenting impacts derived from inconsistent

methodologies would not be helpful to the public in understanding the overall impacts

associated with the potential construction and operation of the proposed MOX facility. It is

recognized that the PDCF would be a DOE facility and as such could be used by the DOE

to perform other missions as appropriate. However, the PDCF impacts associated with the

proposed action have been appropriately included here to avoid an improper segmentation

of the potential impacts discussion. 

The NRC recognizes that waste processing at the proposed MOX facility and the PDCF was

included in previous DOE EISs. However, the previous DOE EISs did not consider the

WSB as a separate facility. Issues associated with waste management are a significant
Appendix J

J-29

concern to stakeholders. The NRC believes that presenting the impacts associated with the

WSB separately will add to the understanding of the overall impacts related to managing

wastes associated with the proposed action. The impacts of the WSB were provided by the

applicant in Appendix G of its ER. The WSB is discussed in the EIS in terms of being a

“support” facility to the proposed MOX facility and PDCF. Therefore, the scope of the EIS

appropriately includes impacts from the PDCF and the WSB.

J.3.6.4 Comment: 77-007

Comment: It was suggested that either the Department of Energy or the Nuclear

Regulatory Commission (NRC) should prepare an EIS on the waste management in the

manufacture and use of MOX fuel.

Response: The impacts on waste management associated with making MOX fuel are

discussed in Section 4.3.4 of the EIS. The EIS concludes that the waste management

capabilities at the Savannah River Site (SRS) and within the DOE complex (e.g., the Waste

Isolation Pilot Plant) are adequate to handle the estimated types and volumes of waste

associated with the proposed action. As discussed in Section 4.4.3 of the EIS, the impacts

associated with using MOX fuel in reactors are based on the Department of Energy’s

Surplus Plutonium Disposition (SPD) EIS. Section 4.28.2.2 of the SPD EIS states that the

volume of waste from reactors is not expected to increase as a result of reactors using MOX

fuel. It further states that waste handling processes at reactors would also not be expected

to change as a result of reactors using MOX fuel. The scope of the EIS is sufficient to

address this comment. 

J.3.6.5 Comment: 93-003

Comment: Concern was expressed that the DEIS will provide a substrate for future MOX

fuel fabrication facilities that the Nuclear Regulatory Commission (NRC) might license. As

such, it is important to note that the plutonium under consideration is from dismantled

warheads that were once from reprocessed irradiated fuel. The current proposal is not

representative of any other MOX fuel fabrication facility that might be licensed in the future

under Part 70, where waste reprocessing would be an integral part of the proposal and

need to be considered. In this case, the Pit Disassembly and Conversion radiation doses

and other impacts must be considered a part of the current process. 

Response: This EIS evaluates impacts of the proposed action (i.e., potential licensing of

the proposed MOX facility at the Savannah River Site) and alternatives to the proposed

action. The impacts of the proposed action are facility and site specific, and include, as the

commenter suggested, impacts from the Pit Disassembly and Conversion facility and other

impacts considered part of the current process. While some impacts such as MOX fuel

transport and MOX fuel use in reactors are presented on a generic basis, this EIS is not

considered to be broad enough in scope to be considered suitable to support any future

consideration of a generic MOX fuel fabrication. Further, as noted by the commenter, there

are significant isotopic differences in plutonium from surplus nuclear weapons and

plutonium derived from reprocessing spent nuclear fuel that would require substantial
Appendix J

J-30

design changes for any mixed oxide fuel fabrication facility that would use plutonium derived

from reprocessing. 

J.3.6.6 Comment: 97-013

Comment: The DEIS appears to use averages. Frequencies and likelihoods do not

appear to be incorporated. This DEIS pertains to a proposed facility that would be licensed

under 10 CFR Part 70, which included consequence and likelihood bins (e.g., see the

Construction Authorization Request and the safety evaluation report). The DEIS should

explicitly consider consequences and likelihoods. 

Response: In general, the EIS assumes that a potential consequence would occur (i.e., a

probability of one). Conservative models and parameters are used in estimating the

potential consequences. For example, meteorological data used in the air transport model

would only be exceeded 5% of the time. In evaluating the consequences of potential

accidents, the Nuclear Regulatory Commission assumed that accidents could be possible,

even though the applicant has proposed controls to reduce the likelihood and severity of

accidents. In other words, the impacts discussed in the EIS are based on radiation doses

and chemical exposures, were an accident to occur. No estimates of accident probability or

likelihood are used in the calculation of these doses and exposures. Therefore, no

consideration of probability or likelihood is required to estimate the environmental impacts

presented in the DEIS.

J.3.6.7 Comment: 98-009

Comment: The DEIS must address the full impacts of the proposed action including how it

is likely contributing to the eventual production of nuclear weapons components at the

Savannah River Site (SRS) and the use of the site for permanent nuclear waste burial. A

full accounting of what and how much plutonium is coming from where and being used for

what project when it arrives should be done and made available to the public. 

Response: The scope of the proposed action is described in Section 1.2 of the EIS. The

scope of the proposed action includes connected actions that are closely related to the

proposed action (i.e., potential licensing of the proposed MOX facility). The connected

actions include impacts from some Department of Energy activities at the SRS such as the

proposed construction and operation of the Pit Disassembly and Conversion Facility and the

Waste Solidification Building, and related infrastructure upgrades at the SRS. However, this

EIS does not address DOE activities that are not connected to the proposed action such as

consideration of facilities to produce nuclear weapons or waste disposal not directly related

to the proposed action. The consideration of actions suggested by the comment are

outside the scope of this EIS. Related issues are discussed in Comment J.3.7.6.
Appendix J

J-31

J.3.6.8 Comment: 86-007

Comment: Section 1.4.1, page 1-12 of the DEIS states “Because the scope of this DEIS is

limited to the licensing action now under review by the NRC, which is specific to the

proposed MOX facility, issues pertaining to decisions already made by the DOE are

addressed by referencing the appropriate DOE analysis.” The statement is misleading. 

Although the Nuclear Regulatory Commission (NRC) indicated that they would rely on the

appropriate Department of Energy (DOE) analyses, the NRC recalculated accident analyses

described in the DOE Surplus Plutonium Disposition (SPD) EIS using extremely

conservative models and assumptions resulting in significantly different impacts than in the

DOE SPD EIS.

Response: As discussed in Section 1.2.2 of the EIS, two DOE facilities (Pit Disassembly

and Conversion Facility and Waste Solidification Building) would support the proposed MOX

facility and are considered to be connected actions. The impact assessments and

information supporting the impact assessments from the DOE EISs were used in the

estimation of impacts in the DEIS. In some cases, the impact values used are taken directly

from the DOE EIS. In other cases, because the NRC used different codes, models and

scenarios in estimating the human health impacts (such as referred to in the comment) the

NRC used supporting data from the DOE EIS to estimate impacts from these facilities that

was consistent with the methodology used to estimate the impacts from the proposed MOX

facility.

J.3.6.9 Comments: 12-004 24-004 64-004 92-003

13-004 30-003 71-009 93-010

Comment: The use of a generic analysis was questioned, given the unique nature of the

proposed Catawba and McGuire candidate reactors ice condenser type containment and

the population surrounding these reactors. It was felt that the DEIS for the proposed MOX

facility both could and should include an analysis of the use of MOX fuel at the Catawba and

McGuire reactors. Concern was expressed that the MOX EIS may be the only opportunity

for the public to comment on using MOX fuel in reactors, unless interveners force the

Nuclear Regulatory Commission (NRC) to prepare an EIS when the NRC considers a

specific license amendment to use MOX fuel in a reactor. In that light, it was stated that the

DEIS fails to analyze weaknesses in Catawba and McGuire ice condenser type reactors. 

These reactors have thin containment which is more likely to rupture in case of a severe

accident. Issues related to reactor aging and MOX fuel use should be evaluated, including

the impact of large component replacement after using MOX fuel. Given the past drought

conditions in the south, thermal impacts of using MOX fuel should be evaluated for these

reactors, including impacts on Lake Wylie, the Catawba River, and Lake Norman. The

DEIS should acknowledge that Catawba and McGuire have higher latent cancer fatalities

from accidents compared with other reactor sites in the country. It was stated that the

Charlotte, North Carolina area could become a nuclear wasteland for decades if a worstcase accident happened.
Appendix J

J-32

Response: As discussed in Section 4.4.3 of the EIS, the generic analysis is based on an

assessment presented in the DOE’s Surplus Plutonium Disposition (SPD EIS) (Section 4.28

and Appendix K.7 of that document). In the SPD EIS three reactor stations (Catawba,

McGuire and North Anna) were evaluated. The reactor use impacts presented in the DEIS

present an aggregate of the range of impacts. Therefore, specific attributes and limitations

of these reactors were considered in determining the impacts of using MOX fuel. For

example, the impacts included projection of population growth surrounding these reactors. 

The text in Section 4.4.3 has been revised to reflect the basis of the generic impact

assessments. Impacts of thermal discharges to surface waters were not evaluated as part

of the generic analysis. These impacts are considered to be reactor site-specific, and

therefore, would be evaluated within the scope of the NRC consideration of site-specific

requests to use MOX fuel. The NRC staff believes that the impacts presented in the DEIS

are a reasonable estimate of the potential impacts of using MOX fuel in reactors. As

discussed in EIS Section 4.4.3, the NRC will perform its own site-specific National

Environmental Policy Act (NEPA) and safety review in evaluating whether any specific

reactor could use MOX fuel. Therefore, the scope of the EIS is considered adequate to

bound the impacts raised in the comments.

J.3.6.10 Comment: 77-003 

Comment: The use of lead test assemblies (LTA) was not addressed in the DEIS. This

would include impacts associated with transporting the lead test assemblies to the reactor

and using the lead test assembles in the reactor.

Response: The use of lead test assemblies was not specifically addressed in the DEIS. 

However, the Department of Energy assessed the impact of the LTA program in its Surplus

Plutonium Disposition EIS. The LTA program is considered to be independent of the

proposed action. Text as been added to Section 4.4.3 of the FEIS to clarify this point.

J.3.7 Scope – DOE Policy

J.3.7.1 Comments: 19-010 56-006

47-001 82-006

Comment: The surplus plutonium program in the United States is connected through

agreements to a similar program in the Russian Federation. The Russian MOX program is

not moving as quickly as the U.S. program. The question of whether the Russian

Federation was in violation of the United States-Russia Agreement was raised. It was felt

that the U.S. MOX program should be delayed until the Russian program was fully funded

and proceeding on track. Given the changes the Department of Energy (DOE) made in the

surplus plutonium disposition program and the uncertainties with the future of this program,

the timing of the Nuclear Regulatory Commission’s (NRC’s) action was questioned. It was

felt that the DOE should clearly state what is really going to be done with the surplus

plutonium and other facilities supporting this program before the NRC considers authorizing

Duke Cogema Stone & Webster (DCS) to construct the proposed MOX facility. It was also
Appendix J

J-33

felt that given the ongoing war and state of the world that the overall surplus plutonium

program and DEIS should be put on hold.

Response: As noted in Section 1.1.1 of the EIS, the MOX program is one part of the

overall U.S. surplus plutonium disposition program. The DOE is responsible for fissile

material in the United States including the disposition of surplus weapons plutonium. 

Coordination and implementation of the disposition agreement with Russia is the

responsibility of the DOE. Because the applicant, DCS, is a DOE contractor, any decision

by the DOE to delay or cancel the surplus plutonium disposition program would be relayed

to DCS as appropriate. The NRC does not have a role in establishing foreign policy or in

defining the surplus plutonium disposition program. Rather, the NRC deals with the

regulation of nuclear materials and facilities. With regard to the proposed MOX facility, the

NRC has received an application from DCS and has decided to prepare an EIS. The NRC

is required to review the application and make a decision regarding whether the proposed

facility can be constructed and operated safely. If DCS, as directed by the DOE, decides to

withdraw its application, the NRC would cease work. The NRC cannot unilaterally stop work

on a project based on international policy grounds that deal with issues outside the scope of

the NRC’s mission. Furthermore, if the DOE makes changes to the surplus plutonium

disposition program that would affect the impacts associated with the proposed MOX

facility, then the NRC would consider those changes when they occur and take appropriate

action. Therefore, these comments are considered beyond the scope of the EIS.

J.3.7.2 Comments: 48-001

61-008

93-008

Comment: The United States-Russia Agreement allows for immobilization. Specifically,

Article 3 of the agreement allows for disposition by one of the following methods: 

irradiation, immobilization, or any other method agreed to by the parties in writing. The

DEIS should acknowledge that the immobilization alternative is allowed under the United

States-Russia Agreement. It was stated that Russia declined immobilization for itself, but

would accept the U.S. immobilizing its plutonium. It was also stated that Russia should not

dictate how the U.S. disposes of its surplus plutonium and that the U.S. should select a

method that provides for environmental protection.

Response: The United States-Russia Agreement is discussed in Section 1.1.1 of the EIS. 

The EIS states that “Under this agreement, disposition may be accomplished either by

immobilization or by MOX fuel fabrication and subsequent irradiation.” Text in the FEIS has

been added to more accurately describe that immobilization of plutonium is allowed by the

United States-Russia Agreement.

The Department of Energy’s (DOE’s)surplus plutonium disposition program and the United

States-Russia Agreement are the basis for determining the purpose and need of the

proposed project. Once the purpose and need of the proposed project is established, the

Nuclear Regulatory Commission (NRC) must determine which alternatives are considered

reasonable and would accomplish the purpose and need of the project. 
Appendix J

J-34

Because the purpose and need is based on the DOE’s surplus plutonium disposition

program, the DOE’s amended Record of Decision (ROD) affected the purpose and need of

this EIS. In the amended ROD, the DOE stated that budgetary constraints no longer

allowed it to pursue the hybrid approach for disposition of surplus plutonium. The DOE

determined that for budgetary reasons it needed to select a single disposition approach. In

the DOE’s judgment, Russia did not consider immobilization alone to be an acceptable

approach for achieving joint disposition of excess plutonium. The DOE indicated that 

Russia may abandon its plutonium disposition efforts if the DOE selected an immobilization

only approach. Thus, the DOE selected the MOX-only approach because in the DOE’s

judgment it was the key to successfully completing the United States-Russia Agreement 

The DOE decided to pursue a MOX-only approach in its amended ROD, and the NRC has

no reason to question the validity of a DOE policy decision regarding a DOE project and

foreign policy matters. 

Additional comments were received relative to the purpose and need, and the

immobilization alternative. Responses to these comments are in Sections J.3.3 and J.3.11,

respectively.

J.3.7.3 Comments: 10-010 48-002 98-003

44-010 96-032

Comment: The status of the Department of Energy (DOE) National Environmental Policy

Act (NEPA) review for the Pit Disassembly and Conversion Facility (PDCF) and the Waste

Solidification Building (WSB) is not covered in the MOX DEIS in sufficient detail. 

Furthermore, legal issues may be raised if the MOX DEIS NEPA review is used by the DOE

for the WSB. Considering these issues and given all the changes in the Surplus Plutonium

Disposition (SPD) program, the DOE should supplement its NEPA analyses to include

consideration of the immobilization alternative, the PDCF and the WSB facilities. If the DOE

fails to supplement its NEPA analyses, the Nuclear Regulatory Commission (NRC) should

deny the application because the DOE did not comply with the NEPA requirements.

Response: NEPA requires federal agencies, including the DOE and the NRC, to consider

environmental impacts in their decision making processes. If an agency action is

considered to be a major federal action, the agency must prepare an environmental impact

statement. Each agency is responsible for its own NEPA documentation. 

The DOE has prepared two EISs for the surplus plutonium disposition program. The

impacts for the PDCF were covered in DOE’s Surplus Plutonium Disposition Final

Environmental Impact Statement (DOE/EIS-0283). The NRC used appropriate materials

from the DOE EISs in the preparation of its environmental impact statement. This is

discussed in Section 1.4.4 of this EIS.

As discussed in Sections 1.2.2 and 2.2 of the EIS, the WSB and PDCF are considered

connected actions to the licensing of the proposed MOX facility. Therefore, impacts

associated with those facilities are included in the discussion of impacts for the proposed
Appendix J

J-35

action. It is important to note that while there is an overlap in the consideration of

environmental impacts for the WSB and PDCF, the NRC does not have safety or licensing

authority over those proposed DOE facilities. The impacts of building and operating the

WSB were addressed in DCS’s Environmental Report and are covered in the MOX EIS. 

The NRC believes that the impacts associated with the WSB are sufficiently addressed in

its EIS to allow the NRC to make a decision as to whether construction of the proposed

MOX facility should be authorized. Whether the DOE performs an independent NEPA

analysis for its own project is not within the NRC’s discretion. Therefore, these comments

are beyond the scope of the NRC EIS. 

The DOE issued a Supplement Analysis (SA) on April 17, 2003, to its amended Record of

Decision (ROD) of April 19, 2002. This SA evaluated the changes to the surplus plutonium

disposition program announced in the amended ROD. The SA’s purpose was to determine

whether the SPD EIS, prepared by the DOE, should be supplemented, whether a new EIS

should be prepared, or whether the DOE found in the SA that no further NEPA

documentation on its part was required. The DOE concluded that changes in the surplus

plutonium disposition program do not result in impacts that are significantly different from

those evaluated in the SPD EIS; therefore, no further NEPA documentation is required.

J.3.7.4 Comments: 3-001 39-003 93-006

 5-006 45-006 114-006

38-001 48-005

Comment: Concerns were expressed about how the Department of Energy (DOE) should

best allocate funding for its various missions. The comments suggested using funding for

clean up activities at the Savannah River Site (SRS) in contrast with long-term funding for

the surplus plutonium disposition program. Funding clean up activities was preferred

because they would benefit the local Augusta and Aiken economies without subjecting

surrounding communities to toxic and nuclear waste generated by the surplus plutonium

disposition program. Concern was expressed regarding the availability of long-term funding

for the surplus plutonium disposition program and that lack of funding could result in

indefinite storage of the depleted uranium and surplus plutonium at the SRS. It was also

stated that the proposed MOX facility should not be built until nuclear material in Russia is

secured and that the limited funds should be used for that purpose. An additional concern

was the possible U.S. funding of the Russian plutonium disposition program.

Response: The costs of the NRC’s proposed action are discussed in the cost-benefit

analysis section of the EIS (Section 4.6). The DOE has budgetary responsibility for the

surplus plutonium disposition program, including any possible funding of the Russian MOX

program, as well as clean up activities at the SRS. Costs and funding issues other than

those associated with the NRC’s proposed action are beyond the scope of the EIS. 
Appendix J

J-36

J.3.7.5 Comments: 48-003 93-009 114-001

61-004 98-003 114-002

Comment: The quantity of surplus plutonium in the disposition program was questioned. 

The comment raised the legal basis for 34 metric tons (37.5 tons) of surplus plutonium

being considered in the MOX DEIS verses 27 metric tons (29.7 tons) of plutonium that has

been declared surplus by the Department of Energy (DOE). In addition, the quantity of

plutonium that would be shipped from DOE’s Rocky Flats site to the Savannah River Site

(SRS) was questioned. The Surplus Plutonium Disposition (SPD) EIS prepared by the DOE

evaluated the impacts of up to 50 metric tons (55 tons) of plutonium. The fate of the

remaining surplus plutonium was questioned. Concerns were expressed that this plutonium

would go to the SRS for long-term storage. In addition, because the Pit Disassembly and

Conversion Facility (PDCF) would not be operational at the start of the proposed MOX

facility, concern was expressed over what plutonium would be used initially by the proposed

MOX facility. It was further questioned on what basis the Nuclear Regulatory Commission

(NRC) assumes that there will be any surplus plutonium.

Response: The quantity of plutonium evaluated in the NRC DEIS is 34 metric tons

(37.5 tons). The quantity is based on the application submitted by DCS (Construction

Authorization Request and Environmental Report). The specific source and form of surplus

plutonium was not specified. General locations and quantities of surplus plutonium are

provided in Table 1.1 of the EIS. The plutonium may be in metal form that would be

processed by the PDCF prior to being received by the proposed MOX facility or it may be

alternative feed stock that could go directly to the proposed MOX facility. As discussed in

Section 1.2.2, the EIS assumes that 25.6 metric tons (28.2 tons) of plutonium that would be

used by the proposed MOX facility would be in the form of plutonium dioxide from the

PDCF. The remaining quantity of plutonium would be “alternate feedstock” that could be

used by the proposed MOX facility without being processed by the PDCF. The DOE will

determine which specific plutonium is used to obtain the 34 metric tons (37.4 tons) and how

any remaining surplus plutonium (i.e. 50 metric tons noted in the comment) will be handled. 

Additionally, at the Savannah public meeting, a representative from the Department of

Energy discussed the quantity of plutonium to be shipped from the Rocky Flats site to the

SRS. The DOE decided in its amended Record of Decision to transfer that material from

the Rocky Flats site to the SRS. This decision was independent of the proposed action.

J.3.7.6 Comments: 05-008 10-021 44-008 71-013 72-012 93-009

10-008 12-002 44-009 71-015 77-004 98-004

10-009 24-008 45-008 72-011 93-008 

Comment: The conflict in national policy between the consideration to build a modern pit

facility and the Surplus Plutonium Disposition program arose. It was stated that the surplus

plutonium disposition program is no longer swords into plow shares. It was also stated that

the U.S. has no cohesive surplus weapons disposition policy. The decisions in the DEIS

regarding which alternatives were evaluated were based on the desire to not conflict with

foreign policy. Given this apparent conflict, it was suggested that the Nuclear Regulatory
Appendix J

J-37

Commission (NRC) should delay its decision until the EIS on the modern pit facility is issued

and commented on.

There was concern about the amount of plutonium that would eventually be located at the

Savannah River Site (SRS ), the area of the country where it would be coming from, and

how the plutonium would be used (dispositioned as surplus or used to make new nuclear

weapons). The possibility that the proposed MOX facility could be used to produce new

plutonium for weapons or reprocessing existing commercial spent nuclear fuel was a

concern. This concern was tied with the Tennessee Valley Authority tritium production

program. There was also a concern that the Pit Disassembly and Conversion Facility

(PDCF) could be used for processing plutonium that would be used to make new nuclear

weapons. It was noted that the risk of an accident at the PDCF would increase by

processing more plutonium, thereby increasing exposure to workers and the public. It was

suggested that another Department of Energy (DOE) EIS is necessary for a complete

assessment of the plutonium missions at the SRS. The EIS for the proposed MOX facility

should include impacts associated with using the proposed facility as part of making new

nuclear weapons. 

Response: The DOE prepared a programmatic EIS for Stockpile Stewardship and

Management (SSM PEIS) in 1996. In September of 2002, the DOE National Nuclear

Security Administration (NNSA) issued a notice of intent to prepare a supplemental

programmatic EIS to the SSM PEIS regarding a modern pit facility. The new supplemental

programmatic EIS (SPEIS) is intended to support two NNSA decisions: (1) whether to

proceed with a modern pit facility, and (2) if so, where to locate it. The DOE recently

(May 30, 2003) issued the draft SPEIS for public comment. The draft SPEIS states that the

preferred alternative would be to construct and operate a new modern pit facility but did not

select a preferred host site. The preliminary project schedule indicates that the planning

and definition phase would continue through 2006 followed by an execution phase through

2016. The proposed modern pit facility would not start operating until 2018.

The concern that building a MOX facility to disposition surplus weapons plutonium conflicts

with building a modern pit facility to make new weapons pits is a national policy issue that

rests with the Department of Energy. Thus, the comments addressing the DOE decisions

are beyond the scope of this EIS. The concerns that the proposed MOX facility could be

used in the process of making new weapon pits is speculative at this point. Moreover, the

current plan presented by DCS, under review by the Nuclear Regulatory Commission

(NRC), is limited to making MOX fuel from 34 metric tons (37.5 tons) of surplus weapons

plutonium. Therefore, these comments are beyond the scope of this EIS.

J.3.7.7 Comments: 10-011 92-004 96-019 

13-005 96-019 114-003

44-011 98-005 

Comment: Four reactors at the Catawba and McGuire stations are potential candidates to

use (irradiate) MOX fuel. However, additional reactors, that have not been identified in the

surplus disposition program, will be required to use the remaining fuel. The DEIS fails to
Appendix J

J-38

acknowledge the possibility of insufficient reactor capacity to keep pace with the production

of MOX fuel. Concern was expressed regarding the impacts if the Vogtle Plant, which is

located near the Savannah River Site (SRS) and had previously expressed interest in using

MOX fuel, was selected to use MOX fuel in the future. The DEIS should state the

environmental risk, if there is one, from failure to promptly use the proposed quantity of

MOX fuel. Having an excess of MOX fuel at the SRS may also pose security risks.

Response: For the purpose of this EIS, it was assumed that the Department of Energy

(DOE) would identify additional reactors that would irradiate MOX fuel beyond that amount

which the four units at Catawba and McGuire nuclear power stations could accommodate. 

This bounds the environmental impacts of the proposed action, such as impacts resulting

from the transportation of feedstock to the proposed facilities, processing and

manufacturing activities at the proposed facilities, transportation of MOX fuel, and waste

generation. If the DOE does not later identify additional reactors to use MOX fuel and the

impacts were limited to those resulting from the disposition of only 25.6 metric tons

(28.2 tons) of surplus plutonium, environmental impacts would be lower. Before any

particular reactor (e.g., the Vogtle Plant) is authorized to use MOX fuel, the NRC would

perform a site-specific environmental review. Such site-specific impacts are outside the

scope of this EIS.

J.3.7.8 Comments: 2-002 71-011

24-005 72-004

Comment: Concerns were expressed that the proposed action would not eliminate the

plutonium. Instead, the use of MOX fuel in reactors would produce more plutonium. This

idea would be counter to the non-proliferation strategy of converting surplus plutonium into

MOX fuel. The availability of plutonium will increase as both the United States and Russia

use plutonium as reactor fuel. Placing the material in commercial power plants would

further nuclear weapons proliferation and not safeguard the plutonium from use in weapons

of mass destruction. Concerns were also expressed that MOX fuel will be irradiated in

reactors other than those in Russia and the United States. Specifically, MOX fuel may be

used in nuclear reactors of countries that trade with Russia and are viewed as “evil” or

“rogue” nations by the United States. The question was raised why the U.S. would accept a

program that would send weapons grade plutonium to other countries including Iran and

Syria if Russia will not accept alternatives that do not isotopically degrade weapons

plutonium.

Response: Irradiating MOX fuel in reactors would produce more plutonium. However, this

plutonium would be highly radioactive and thus unavailable for unauthorized use. This

would help reduce the threat of nuclear weapons proliferation by ensuring that surplus

plutonium is converted to proliferation-resistant forms. The Department of Energy (DOE)

decided, in previous National Environmental Policy Act (NEPA) documentation and based,

in part, on the recommendations of the National Academy of Sciences in the Management

and Disposition of Excess Weapons Plutonium (NAS 1994), that the manufacture and use

of MOX fuel poses an acceptable disposition approach that creates a proliferation-resistant

form of plutonium. Further consideration of the adequacy of this approach is beyond the
Appendix J

J-39

scope of the Nuclear Regulatory Commission’s environmental review (see EIS Appendix I,

Section 4.1).

J.3.7.9 Comments: 10-005

44-005

Comment: It has been the national policy to separate the military and civilian uses of

nuclear materials. The use of surplus weapons plutonium in civilian reactors blurs the

distinction between the military and civilian nuclear programs.

Response: This national policy (embodied in the Energy Reorganization Act of 1974)

remains the same. In 1974, Congress created the Energy Research and Development

Administration (which later became the Department of Energy [DOE]) to oversee the military

uses of nuclear materials, among other functions. The Energy Reorganization Act of 1974

also established the Nuclear Regulatory Commission (NRC) as an independent regulatory

agency that is separate from the DOE. The NRC was created to regulate the commercial

use of nuclear materials. The NRC does not view its licensing authority over the proposed

MOX facility as changing the above-described separation of functions enacted by Congress

in 1974.

J.3.7.10 Comments: 8-004 34-001 95-002

32-003 36-001 105-006

Comment: Several previous and future Department of Energy (DOE) decisions were

questioned. The question of locating the proposed MOX facility at the Savannah River Site

(SRS) was raised. It was felt that since most of the surplus plutonium is located in Texas

and Colorado that the proposed MOX facility should be located closer to these locations to

minimize transportation impacts. It was questioned if political or socioeconomic and

demographic characteristics were the reason for selecting the SRS. It was suggested that

the DOE should hold public meetings to answer questions relative to the surplus plutonium

disposition program that are outside of the Nuclear Regulatory Commission’s (NRC’s)

domain. Future decisions relative to the ultimate fate of the surplus plutonium disposition

facilities were questioned. It was stated that the DOE had sworn to decommission these

facilities at the end of the mission. It was questioned as to what guarantees the public has

that this is true. It was also stated that the facility should be located farther away from large

cities to reduce the risk to people from accidents.

Response: The DOE in its Surplus Plutonium Disposition (SPD) EIS looked at the impacts

of siting the surplus plutonium disposition facilities at numerous locations. The SPD EIS

concluded that the facilities should be located at the SRS. The basis of this decision is

presented in the SPD EIS. As discussed in the March 7, 2001, Notice of Intent to prepare

an EIS, issues pertaining to decisions already made by the DOE will not be revisited by the

Nuclear Regulatory Commission (NRC). Therefore, consideration of locating the proposed

MOX facility at another location is beyond the scope of the EIS.
Appendix J

J-40

The EIS includes the impacts of decommissioning the surplus plutonium disposition

facilities. As discussed in Section 4.3.6.1, the contract between DCS and the DOE calls for

DCS to deactivate the proposed MOX facility and place it in safe-shutdown once operations

have ended. The ultimate fate of the surplus disposition facilities would be the responsibility

of the DOE. NRC regulations require the facilities it licenses to be decommissioned in a

timely manner. DCS would be required to get an exemption or other waiver from the NRC

to transfer the facility to the DOE prior to decommissioning. Since this has not been

requested, the EIS includes impacts from decommissioning the facility.

J.3.7.11 Comment: 87-001

Comment: The Waste Solidification Building (WSB) is part of the Pit Disassembly and

Conversion Facility (PDCF), which will be constructed after the proposed MOX facility is

operational. The Department of Energy (DOE) has changed the design of the proposed

MOX facility, which was originally to include equipment to solidify radioactive liquid waste,

but now, according to the DOE’s Supplement Analysis and Amended Record of Decision of

April 2003, this equipment is to be located in the WSB. The DOE’s current schedule, laid

out in its February 15, 2002, Report to Congress, calls for construction of a MOX facility

2004-2007, once licensed by the Nuclear Regulatory Commission (NRC), with operations

beginning in 2007. The PDCF will be constructed from 2006-2009, with startup in 2009. 

Furthermore, it is unclear which DOE plutonium stocks would be processed at the proposed

MOX facility until the PDCF is completed. Clearly the DOE cannot use plutonium metal until

the PDCF is completed. The remaining plutonium stocks have a variety of impurities which

will require aqueous polishing which will create waste streams. The DEIS does not address

the issue of what will happen to these waste streams in the interim. The DEIS should

address the scheduling issues with regards to the treatment of radioactive waste. 

Response: As discussed in Section 1.2.2 of the EIS, the impacts of the proposed action

evaluated in the EIS are based on the assumption that approximately 25.6 metric tons

(28.2 tons) of the plutonium will be processed as plutonium dioxide from the PDCF. The

remaining 8.4 metric tons (9.4 tons) would be alternate feedstock. The NRC has evaluated

the impacts based on the applicant’s request of 34 metric tons (3.5 tons). Should the

quantity of pit and alternative feedstock plutonium change in the future, the NRC would

evaluate these possible changes on the environmental impacts and determine if additional

analyses were required. The current plan is that the proposed MOX facility and WSB would

be completed about the same time. Therefore, waste facilities would be operational prior to

processing any alternative feedstock. It is anticipated that the proposed MOX facility, if its

operation is authorized by the NRC, would begin processing alternative feedstock. The

PDCF does not need to be operational to process alternate feedstock. Therefore, the

scope of the EIS is considered adequate to address the issOctober 28, 2004ues raised in

the comment.
Appendix J

J-41

J.3.8 Scope – Safety Evaluation Report

J.3.8.1 Comments: 10-020 62-003 97-003 105-005

18-001 96-035 97-005

Comment: Concern was expressed that the distinction between the Safety Evaluation

Report (SER) SER and the Environmental Impact Statement (EIS) was confusing and

needed to be simplified. The DEIS does not discuss if the Nuclear Regulatory Commission

(NRC) finds the technical designs proposed by DCS to be adequate. It was suggested that

the DEIS should contain a detailed evaluation of the proposed facilities against guidance for

radiological facilities, including design criteria, technical specifications, and American

National Standards Institute (ANSI) standards. It was stated that compliance with NRC risk

goals and metrics should be provided in the DEIS. Furthermore, the DEIS lacks sufficient

information on design bases to judge the operability of the facilities, general safety, and

validity of projected off-site effects of accidents. Given the large number of process steps

and complexity to make MOX fuel, it was questioned if this could be done safely. It was

also stated that there must be no acceptance of any number of potential deaths. The DEIS

focuses on programmatic and administrative controls for many hazards including potential

accidents that could produce serious injuries and/or fatalities with relatively high likelihoods. 

The DEIS does not emphasize actual mitigation and/or prevention of the hazardous

phenomena.

Concern was also expressed about having the opportunity to comment on the SER. It was

suggested that comments or questions raised during the DEIS comment period pertaining

to the SER should be transferred to contacts within the NRC working on the SER. It was

further stated that the person who made the comment be included in a pool of participants

interested in the SER. In addition, the SER needed to be throughly studied by the NRC

before making any decisions.

Response: In evaluating applications, the NRC conducts an environmental review. An

environmental review is documented in the EIS, and a safety review is documented in the

safety evaluation report (SER). A discussion of the NRC’s decision making process

regarding the potential licensing of the proposed MOX facility is provided in Section 1.1.2 of

the EIS. Text has been added in the FEIS to better discuss the relationship between the

content of the SER and the EIS. The clarifying text describes the different purposes of an

SER and an EIS. Generally, the purpose of an SER is to evaluate the safety of an

applicant’s proposed action. The purpose of an EIS is to evaluate environmental impacts of

a proposed action and alternatives. 

Where safety measures proposed by an applicant would have no direct environmental

impact, the staff’s evaluation of such measures is set forth only in the SER. Similarly,

environmental issues carrying no safety significance (e.g., displacement or damage of

archeological resources) are only discussed in the EIS. However, if there is a nexus

between safety and potential environmental impacts, such as the human health and

environmental consequences of potential accidents, these issues are described in both the

SER and the EIS. 
Appendix J

J-42

The SER for the construction of the proposed MOX facility evaluates safety systems and

controls against the safety basis in NRC regulations. Many of the comments were general

in nature and pertained to the safety discussions in the SER. The NRC staff safety

evaluations are not repeated in the EIS. Some comments pertained to specific topics

discussed in the SER that are beyond the scope of the EIS (see below). As requested,

comments on the DEIS that pertain to the SER rather than the EIS have been forwarded to

appropriate NRC staff for consideration in preparing the SER. As discussed in

Section 1.1.2 of the EIS, the NRC takes into consideration findings in both the SER and EIS

prior to making any licensing decisions.

J.3.8.2 Comments: 4-004 74-001 96-012 116-011 

43-003 82-003 96-025

52-002 88-002 96-036

Comment: Concern was expressed about the adequacy of the emergency plans. 

Commenters indicated that an emergency plan for evacuating the Savannah and Chatham

area must be evaluated. Having a tested and certified evacuation plan, to include areas

downwind and downstream of the proposed facility, must be a prerequisite to going forward

with the licensing process. If there is no evacuation plan, then the Nuclear Regulatory

Commission (NRC) should deny the license. When the emergency plan is put into effect, it

was questioned whether the surrounding areas near the Savannah River would receive the

emergency plan after it is evaluated. The at-risk population should be educated about the

emergency plan, and this should include drills and exercises. Another area of concern was

the absence of an off-site emergency plan by DCS for any accident scenario. Concerns

were expressed that NRC had stated that general emergency preparedness of communities

is outside the scope of this EIS.

Response: The concerns expressed in the comments address safety issues that are

outside the scope of the EIS. The baseline design criteria for emergency capability are

stated in 10 CFR 70.64(a)(6). The design of the proposed MOX facility must provide for

emergency capability to maintain control of (1) licensed material and hazardous chemicals

produced from licensed material; (2) evacuation of on-site personnel; and (3) on-site

emergency facilities and services that facilitate the use of available off-site services. In

Chapter 14 of the applicant’s Construction Authorization Request, DCS committed to

providing an evaluation demonstrating that an off-site emergency plan is not required. Such

an evaluation will be part of the DCS application for a license to possess and use special

nuclear material, which has not yet been submitted. The NRC found this approach

acceptable. The NRC, as part of its review of any such license application, would evaluate

whether an off-site emergency plan is required. DCS has further committed to establish a

protocol with the DOE to integrate its emergency plans with the existing Savannah River

Site (SRS) emergency preparedness program. This protocol would be reviewed by the

NRC as part of its evaluation of any later DCS application for a license to possess and use

special nuclear material. The commitment by DCS to integrate its emergency plans with the

existing SRS emergency preparedness program has been identified as a mitigation

measure to mitigate potential impacts of a chemical accident. Mitigation of chemical

impacts is further discussed in Section 5.2.8 of the EIS.
Appendix J

J-43

J.3.8.3 Comments: 4-002 44-012 73-003

10-020 56-003 105-003

19-009 65-004

Comment: Concerns were raised about the safety and environmental record of entities

associated with the MOX project. Specifically, the involvement of COGEMA in the

consortium of DCS caused significant concern. It was stated that COGEMA is an

irresponsible company and should not be involved in the project because of sites like

La Hague that have had poor environmental and safety records. It was stated that it may

not be possible to get adequate information about COGEMA because France is far less

open than the United States about its nuclear operations. Furthermore, it will be difficult to

know if DCS will do it right, since it did not exist before the proposed plutonium fuel project.

Concern was expressed that our government is not concerned with the previous track

record of COGEMA, Stone & Webster, and Duke Energy in handling commercial plutonium

and nuclear waste. It was stated that evaluating issues associated with safety records in

the EIS is permitted under the National Environmental Policy Act (NEPA). It was felt the

DEIS should include background discussions on the entities composing DCS. Furthermore,

the DEIS should examine the entities financial stability and environmental and safety

records.

Response: These comments raise issues which are beyond the scope of the EIS. An

applicant is required to demonstrate its qualifications in a license application. Nuclear

Regulatory Commission (NRC) staff will document its evaluation of the applicant’s

qualifications in a safety evaluation report (SER). Related safety issues regarding the

applicant’s qualifications are discussed in Chapter 4 and 15 of the draft SER issued in

April 2003. NEPA and implementing regulations by the NRC (10 CFR Part 51) and the

Council on Environmental Quality ( 40 CFR Part 1500) do not require consideration of an

applicant’s qualifications in an EIS.

J.3.8.4 Comments: 67-003 96-021

 93-002 116-010

 93-015

Comment: Concerns were raised regarding the safeguarding of MOX material to prevent

theft or loss during its processing, use, and storage. The issue of safeguarding MOX

material was not addressed in the DEIS. Likewise, comments indicated concerns about

tracking the inventory of plutonium and any other radioactive materials involved in the

process. The DEIS did not reference problems in materials accounting at other U.S.

facilities such as Rocky Flats. The problems at Rocky Flats led to spontaneous plutonium

combustion. These safeguard issues are not addressed in the DEIS; and therefore, the

DEIS does not fully document all the environmental impacts of the proposed MOX facility. 

An additional concern involved who would be responsible for plutonium security at the

Savannah River Site.
Appendix J

J-44

Response: These comments raise issues which are beyond the scope of the EIS. The

issues referenced above would be addressed in an SER, if DCS later files an application for

a license to possess and use special nuclear material at the proposed MOX facility.

J.3.8.5 Comments: 18-001

116-012

Comment: The design bases and the analysis of criticality for the construction and

operation of the proposed MOX facility were not addressed in the DEIS. In terms of

accidents, only “generic accidents” were considered. Furthermore, “generic” was not

described. Pertinent descriptions of the “generic” accident should include the bounds and

bases for the assumed number of total fissions, peak pulse, and duration of the incident. A

discussion of the observed differences between solution and solid incidents should be

provided in the DEIS. It should be shown that the design provides criticality controls against

all foreseen accidents, but also will mitigate consequences for the types of incidents that

have occurred. Concern was expressed regarding a criticality event in pipes, especially

between facilities. It was questioned whether the Nuclear Regulatory Commission (NRC)

had complete jurisdiction to review these scenarios. 

Response: These comments raise issues which are generally beyond the scope of the

EIS. Nuclear criticality safety design issues, including the relevant bases, criticality analysis,

and differences between solution and solid incidents, are discussed in Chapter 6 of the draft

SER (safety evaluation report) issued in April 2003. The potential impacts of a criticality

accident are discussed in Section 4.3.5 and Appendix E of the EIS. The amount of special

nuclear material considered in the hypothetical accident is provided in Table E.12 of the

EIS. NRC regulations require that criticality events be made highly unlikely. As discussed

in Section 1.1.2 of the EIS, the NRC will prepare two safety evaluation reports. The SER for

construction evaluates the safety systems and controls. The detailed review of the criticality

safety program, which will include evaluating criticality in pipes, will be performed if and

when DCS submits an application for a license to possess and use special nuclear material

at the proposed MOX facility. Prior to authorizing construction or issuing an operating

license, NRC staff will determine if the criticality safety program meets the NRC regulations.

J.3.8.6 Comments: 100-001 111-001

105-003 113-001

Comment: The DEIS should include a containment chapter. This chapter would include a

discussion of the need for preventing the release of plutonium under all conceivable

conditions and the need for measures that maintain plutonium management under all

possible conditions. Given the hazardous nature of plutonium, precautions should be

specified to prevent inadvertent releases of plutonium. Inadvertent releases have occurred

in the past at the Kerr McGee Cimarron, Oklahoma site; the Nuclear Fuel Services West

Valley, New York site; the Midwest Fuel Recovery near Morris, Illinois; and at the LaHague

and Sellafield sites in Europe. 
Appendix J

J-45

Response: These comments raise issues which are generally beyond the scope of the

EIS. The applicant has proposed features in the MOX facility to both maintain confinement

of radioactive material and minimize contamination of the facility. These features are

designed with consideration of past experiences with handling plutonium. Some of these

features are reusable storage cans to transfer material between process areas, gloveboxes,

welded tank and piping in certain process areas, process cells with robust access controls,

and multiple ventilation confinement zones throughout the facility. The staff’s evaluation of

these features is described in Chapter 11 of the draft SER issued in April 2003. The

impacts of a loss of confinement accident are discussed in Section 4.3.5 and Appendix E of

the EIS. 

J.3.8.7 Comment: 116-014

Comment: DCS plans to use both preventive and mitigative measures in accident

evaluations. The EIS should have considered a more conservative approach that would

allow for the accident and mitigate the consequences while simultaneously designing to

prevent the accident.

Response: Nuclear Regulatory Commission (NRC) safety regulations require that the risk

of high and intermediate consequence events be limited. To meet these performance

requirements, applicants may either prevent such accidents or mitigate the consequences

of the accidents. Even though the probability of the accident occurring is unlikely or highly

unlikely, for the purposes of the EIS, it is assumed that the accidents will happen, and the

estimated consequences of the accidents are presented without taking credit for preventive

measures. Mitigation measures, including mitigation features for accidents, are presented

in Chapter 5 of the EIS. The principal structures, systems, and components (PSSCs),

including PSSCs to prevent accidents and mitigate consequences for the proposed MOX

facility, are evaluated in the draft SER issued in April 2003.

J.3.8.8 Comment: 116-020

Comment: It was questioned whether both off-site and on-site radiation monitors are

planned. Details on the types and capability of the monitors to measure the various types of

radiation (e.g., alpha, beta, gamma, and neutron) and the calibration frequency of the

monitors were requested.

Response: These comments raise issues which are beyond the scope of the EIS. As

discussed in Section 1.1.2 of the EIS, two safety evaluation reports will be issued by the

Nuclear Regulatory Commission (NRC) prior to making decisions on whether to authorize

construction and operation of the proposed MOX facility. Effluent and environmental

monitoring are discussed in Chapter 10 of the draft SER for construction issued in April

2003. Radiation monitoring was not identified by DCS as a principle safety system

component; and therefore, details requested in the comment have not been developed. 

Effluent and environmental monitoring are required by NRC regulation (10 CFR Part 20),

and the details and adequacy of such monitoring systems and programs would be
Appendix J

J-46

evaluated if and when the NRC receives a DCS application for a license to possess and use

special nuclear material.

J.3.8.9 Comments: 53-011

99-002

Comment: Concerns were expressed regarding the foreign ownership, control, and

influence in the MOX project. It was stated that this is a French project that primarily

benefits the French government. It was questioned whether a French company should be

involved with handling plutonium.

Response: These comments raise issues which are beyond the scope of the EIS. Related

safety issues regarding foreign influence and control are discussed in Chapter 1 of the draft

SER issued in April 2003.

J.3.9 Scope – Terrorism

J.3.9.1 Comments: 5-005 24-010 56-001 71-010 88-001 112-004

10-001 30-002 58-001 71-012 91-006 114-009

13-007 44-001 65-002 77-006 93-005 114-013

19-002 45-005 66-008 82-001 96-020 116-002

24-002 52-001 68-002 85-004 103-004

Comment: The treatment of terrorism or lack thereof in the DEIS was a significant concern

with many commenters. There was a concern with the Commission decision addressing

whether terrorism must be considered in an Environmental Impact Statement. It was stated

in the Commission decision (CLI-02-24, December 2002), that the Nuclear Regulatory

Commission (NRC) is not obligated to consider risks associated with terrorism in any

environmental impact statement. It was felt that this ruling sets a dangerous precedent and

that the NRC is ignoring the imminent danger of terrorism. 

Terrorism was not examined in the broad sense. It was stated that terrorist activities had

not been evaluated with regard to accident scenarios, latent cancer fatalities, and costs in

the DEIS. The comments stressed that the threat of terrorism cannot be ignored. Citizens

felt the DEIS did not address a terrorist attack on the proposed MOX facility to the extent

that it should have considered increased risk of terrorism in the world today. Citizens also

felt that the DEIS did not address environmental risk from sabotage or malevolent attacks. 

It was stated that not addressing terrorism was unacceptable. A question was raised about

how the terrorism issue was going to be addressed. It was stated that the issue of terrorism

is supposedly going to be addressed in agency reviews. 

The DEIS fails to acquaint the public with dangers associated with the possible impacts of

terrorist events. It was stated that recent simulations of terrorist attacks strongly suggest

that conventional methods for defending nuclear facilities are inadequate, and therefore it is

reasonable to conclude that risk assessment strategies are woefully insufficient as a basis
Appendix J

J-47

for making decisions such as those inherent to the proposed MOX facility. It was felt that

the public needs to be given information that will allow them to help themselves in case of a

terrorist event, because there is danger in ignorance. Concern was expressed in Charlotte

that with its large population and with it being a financial center, it may be even more of a

target, if the Duke reactors used MOX fuel. A question was also posed about who will

protect us if the NRC doesn’t take into consideration all the possible risks.

Response: These comments raise issues which are beyond the scope of the EIS. But, as

stated in CLI-02-24, although the NRC has declined to consider terrorism in the context of

NEPA, the NRC is devoting substantial time and attention to terrorism-related matters. For

example, as part of fulfilling its mission to protect public health and safety and common

defense and security pursuant to the Atomic Energy Act, the NRC staff is conducting

vulnerability assessments of commercial uses of radioactive material. The NRC has

assessed potential vulnerabilities of radioactive dispersal devices, dirty bombs, and other

diversion type activities. The NRC has issued interim compensatory measures and a

number of other orders imposing enhanced security requirements on its licensees. Also,

the NRC has acted to increase security awareness in its applicants. 

J.3.9.2 Comments: 2-001 19-004 41-001 58-002 71-012 114-011

 4-003 19-005 47-002 65-001 91-006

10-001 24-010 56-001 68-002 93-019

15-002 39-002 56-002 71-003 114-009

Comment: The proposed MOX facility would be the central point for storing uranium and

plutonium. Concern was expressed that having 100 percent of the plutonium in the U.S. in

one location, rather than spreading out the plutonium at numerous locations is a prime

situation for a terrorist attack. There was concern expressed about shipping of the

plutonium and uranium to the Savannah River Site (SRS) and the possibility of a terrorist

attack. It was felt that the risk of terrorism would be increased during the shipment process. 

A question was raised regarding the logic of the Nuclear Regulatory Commission (NRC)

stating in the DEIS that terrorism is not reasonably foreseeable and therefore would not be

analyzed. The comments indicated that the transportation, storage, and processing of 34

metric tons (37.5 tons) of plutonium makes the plutonium a target of terrorism. The logic of

shipping plutonium in the western part of the United States to the southeastern part of the

United States was also questioned. Concern was expressed as to whether there would be

protection during the transport of the plutonium. It was felt that the public outcry in the

Northeast, Southwest, Northwest, and West has managed to prevent a license being issued

for plutonium storage in those areas. Concern was also expressed about shipping the MOX

fuel to commercial reactors in the Southeast which would be an open invitation for terrorism.

Response: These comments raise issues which are beyond the scope of the EIS. As

discussed in Section 1.2.2 of the EIS, surplus weapons plutonium is currently stored at

seven Department of Energy (DOE) sites. It should be recognized that the DEIS discusses

DOE plutonium that has been declared as surplus for national defense and does not

address other plutonium stockpiles within the DOE complex. In its amended Record of
Appendix J

J-48

Decision, the DOE stated 6.6 metric tons (7.3 tons) of surplus plutonium would be shipped

from the Rocky Flats site to the SRS. 

The transport of the surplus plutonium and fresh, unirradiated MOX fuel would be

conducted by the DOE, and the DOE is responsible for ensuring its protection. This type of

transport has been used to ship nuclear weapons, nuclear components, and special nuclear

material for close to 50 years. This type of transport is discussed in Section 4.4.1 and

Appendix C of the EIS.

J.3.10 Alternatives – General

J.3.10.1 Comments: 5-009 72-002 73-002

45-009 72-015 105-009

Comment: The no-action alternative was supported over the preliminary recommendation

of the proposed action. The no-action alternative would save a great deal of money, not

result in transporting plutonium at this time of war, and get us back on the right track on how

to deal with dismantling weapons of mass destruction here in the United States. It was

suggested that Congressman Max Burns, and Congressman James Clyburn should

intervene and stop this project from proceeding forward. The $309 million in the 2004

budget appropriation for the plutonium disposition program could be much better spent in

some other area.

Response: Section 1.3 of the EIS discusses the need for the proposed action, particularly

as part of a larger strategy for plutonium disposition, under international agreements. The

strategy is intended to protect against proliferation of materials capable of making weapons

of mass destruction. The no-action alternative would not meet the purpose and need of this

project. The NRC staff’s NEPA recommendation regarding the proposed action is

discussed in Section 2.5.

J.3.10.2 Comments: 2-003 

87-004

Comment: Off-specification MOX and immobilization alternatives should be considered in

the DEIS. It was suggested that the off-specification MOX alternative could be expanded to

include using other materials as a radiation barrier other than spent nuclear fuel. Most

reactors do not have facilities to separate fuel pins from assemblies, which would be

required by countries that do not have large quantities of high-level waste waiting to be

vitrified. Instead of using spent fuel, one could adopt a variant of the can-in-canister

approach planned for the immobilization facility. One could emplace the pellets of off-spec

MOX into high-level waste glass, for instance. 

Response: In Section 2.3.4 of the EIS, the Nuclear Regulatory Commission (NRC)

considers the off-specification alternative and concludes that the direct radiation hazard to
Appendix J

J-49

workers and the public in implementing this alternative would be greater than the hazards of

the proposed action. For example, the activities associated with the off-specification fuel

alternative (fuel fabrication, MOX fuel transportation, and handling off-specification rods at

the reactor site and at a geologic repository or Independent Spent Fuel Storage Installation)

would result in greater direct radiation hazards. Also, the benefit of producing electricity

from MOX fuel would not occur with the production of off-specification fuel. Placing offspecification fuel in waste glass would result in an additional processing step compared to

production of MOX fuel. Worker risks from handling radioactive materials would be

increased, as would costs of vitrifying off-specification fuel. 

In Section 2.3.3 of the EIS, the NRC sets forth two reasons for not considering

immobilization of plutonium a reasonable alternative to the proposed action (building and

operating the proposed MOX facility). First, immobilization would not satisfy the purpose

and need of the proposed action, because Russia does not consider immobilization alone to

be an acceptable approach for achieving joint disposition of excess plutonium. The United

States-Russia Agreement (White House 2000) discusses several approaches including

immobilization. However, the Department of Energy (DOE) indicated that Russia would

abandon its plutonium disposition efforts if the DOE selected an immobilization-only

approach. Because of budget constraints, the DOE only had the ability to select one

method for disposal of surplus plutonium. The DOE selected the MOX-only approach

based on its judgment that it was the key to successfully completing the United StatesRussia Agreement.

The second reason for no longer considering immobilization to be a reasonable alternative

relates to the conduct of U.S. foreign policy. In the NRC’s view, an alternative that would

block the implementation of a foreign policy agreement between the U.S. and another

country involves matters outside the scope of the National Environmental Policy Act. 

J.3.10.3 Comments: 72-001 74-002

72-005 93-007

Comment: The Nuclear Regulatory Commission (NRC) could further point out to the

Department of Energy (DOE) that it could facilitate the isotopic degradation with no reactor

use and also reduce a proliferation threat by acquiring reactor grade plutonium from other

countries and mixing U.S. and Russian surplus plutonium with these stocks. At that point it

would be possible to immobilize or make off-spec MOX with this plutonium. Irradiated fuel

could be used as the radiation barrier for this waste form. 

Response: Text has been added in Section 2.3.6 of the FEIS to discuss the alternative

suggested in the comment.

J.3.10.4 Comment: 19-003

Comment: Under the National Environmental Policy Act (NEPA) a range of other options

including no action should be presented. This DEIS offers only the preferred option versus

no option. The same should be true for the choice of the F-Area.
Appendix J

J-50

Response: The commenter used the term “options” presumably referring to the number of

alternatives that are required by NEPA. The Nuclear Regulatory Commission (NRC) and

Council on Environmental Quality (CEQ) regulations for implementing the procedural

provisions of NEPA do not specify the number of alternatives that must be addressed in an

EIS. The NRC chose to evaluate, in detail, the no action alternative and the proposed

action. Section 2.3 of the EIS discusses a number of alternatives that were considered but

were not evaluated in detail for the reasons discussed in the individual subsections. DCS

conducted a siting study for the proposed MOX facility at the Savannah River Site (SRS)

and reported its methodology and basis for choosing F-Area for a MOX fuel fabrication

facility in Section 5.7.2.3 of the Environmental Report. The NRC evaluated the DCS Siting

Study and concluded that F-Area is the most suitable location on the SRS for the proposed

MOX facility.

J.3.10.5 Comments: 82-005

84-003

88-004

Comment: Cheaper and safer methods of achieving the same ends have not been

thoroughly explored. The DEIS should consider other alternatives that would less

negatively impact our environment.

Response: The Nuclear Regulatory Commission (NRC) considered other alternatives for

disposing of surplus weapons grade plutonium that may have been more cost beneficial but

they did not qualify as reasonable alternatives under the National Environmental Policy Act

(NEPA). Immobilization was considered but was not evaluated in detail for the reasons

discussed in EIS Section 2.3.3. The NRC also evaluated the no action alternative of leaving

the plutonium at existing Department of Energy installations. 

J.3.10.6 Comment: 116-006

Comment: The Nuclear Regulatory Commission (NRC) should alternatively consider a

self-sufficient MOX facility with a Waste Solidification Building (WSB) and Pit Disassembly

and Conversion Facility (PDCF) totally separate and independent of the remainder of the

Savannah River Site (SRS). The necessary design changes should be included and

reviewed at this time with a revised EIS. 

Response: The NRC has no legal basis to authorize the building and operation of an

independent WSB and PDCF. Moreover, such facilities would require separate support

services that would substantially increase the impacts (both environmental and monetary)

associated with the alternative without clear benefit over the proposed action. Therefore,

the suggested alternative is not considered to be a reasonable one under NEPA.
Appendix J

J-51

J.3.10.7 Comments: 14-002

63-002

Comment: The safety and environmental risks associated with the no action alternative

have been significantly understated. The no-action alternative assumes that the

Department of Energy’s (DOE’s) surplus plutonium would remain in storage at seven DOE

sites. The DEIS does not state the period of storage, and it appears that impacts are nearterm and based on maintaining the status quo. We believe current methods of storage are

only valid for a limited and finite time frame; storage without subsequent actions is not

realistic for time frames of 100 years plus. At some time in the future, actions will be

required to either repackage or disposition stored materials. The no-action alternative

should assess the incremental added risk resulting from (1) actions to periodically process

and repackage materials in long-term storage and (2) actions to eventually remove the

materials from storage and preparation for disposition. 

Response: The analysis of the no-action alternative impacts in the DEIS was based on all

ongoing activities at each of the storage sites (and thus, the impacts are likely

overestimated rather than underestimated for current storage activities). The impacts

associated with possible future repackaging of some containers to maintain their integrity

and with preparation of materials for disposition have not been included, since the extent of

these hypothetical future activities cannot be known at this time. However, these activities

would be conducted by radiation workers, with doses monitored to remain below DOE

administrative limits. (For example, rotation of workers could be employed to minimize

annual doses). All current storage locations are in secure areas without public access. By

maintaining and monitoring the inventory, any exposures of the general public would be

avoided. Therefore, it is not necessary to quantify the risk from repackaging and material

preparation for the no-action alternative. 

J.3.10.8 Comments: 10-016 97-017 115-002

73-005 97-018 116-013

Comment: It was recommended that both a sand filter and high-efficiency particulate air

(HEPA) filters be used to protect workers at the Savannah River Site (SRS). The validity of

the statement in the DEIS that the use of sand filters would not clearly result in lower net

environmental impacts as compared to the use of HEPA filters was questioned considering

that HEPA filters require administrative controls to maintain their efficiency. The brief

discussions in the DEIS regarding the use of sand and HEPA filters imply better

performance from sand filters, particularly during accidents. It is recommended that

approaches more consistent with Nuclear Regulatory Commission (NRC) and nuclear

industry practices in these areas, with reasonable mitigation, prevention and/or

conservatism, be endorsed by the DEIS. The DEIS should include references and

supporting information to support the conclusions regarding HEPA filters. Some individuals

felt that HEPA filters are an unreliable means of controlling radionuclide emissions.

Specifically, alpha emitters like plutonium can creep through multiple HEPA filters in

sequence. The HEPA filter efficiency for plutonium is not known because of alpha

migration, particle re-entrainment, and alpha recoil. A sand filter, unlike HEPA filters, is not
Appendix J

J-52

subject to deterioration from exposure to chemical emissions. The DEIS should include a

discussion of measures the applicant plans to use to protect HEPA filters from chemical

degradation. 

Response: Consistent with the NRC’s mission of protecting the public health and safety,

the NRC regulations require that workers at the SRS and other members of the public be

protected from routine facility emissions. The applicant has proposed using HEPA filters to

reduce radionuclide emissions to acceptable levels. The NRC, in the draft SER issued in

April 2003, has reviewed the use of HEPA filters and concluded that the proposed system

provides adequate assurance of safety to members of the public, including SRS workers. 

Therefore, using both filtration systems is not required to achieve adequate protection of the

public. 

The conclusions relative to the technology option to install a sand filter are presented in

Section 4.3.8 of the EIS. This section discusses administrative controls that are required to

maintain HEPA filter efficiency. The assumption is that the HEPA filters would be

maintained, similar to the assumption that a sand filter would be designed and constructed

properly. Reliance on commitments to maintain safety is considered sufficient for

estimating the environmental impacts from alternatives. Information used to support the

safety basis of these commitments is discussed in Chapter 11 of the draft SER and is not

repeated in the EIS. Text has been added to Section 4.3.8 of the FEIS to note the

differences in sand and HEPA filter degradation and response to chemicals. The EIS states

that by selecting sand filters, environmental impacts could be reduced in the specific areas

of human health risk to the facility worker and accident mitigation. However, the sand filter

option would not clearly result in lower net overall environmental impacts than the use of

HEPA filters. Therefore, using a sand filter is not a clearly superior option.

J.3.10.9 Comment: 86-016

Comment: Section 2.2.5, page 2-18, line 29 of the DEIS states “Large fans or blowers are

used to circulate the air through the sand filter media.” The sentence is misleading and

implies a re-circulating system rather than the “once through” system that is used. The

blowers are used to draw air through the sand filter media.

Response: The text in Section 2.2.5 of the FEIS has been revised per the comment.

J.3.10.10 Comment: 86-017

Comment: Section 2.2.5, page 2-19 of the DEIS states “The facility is designed into

numerous fire zones, in part to limit the exposure of individual banks of HEPA filters to

failure.” This sentence should read: “The facility is divided into numerous fire zones, to limit

the amount of combustibles involved in a single fire which reduces the amount of soot

reaching individual banks of HEPA filters and assures that the HEPA filters will not fail due

to excessive plugging.”

Response: The text in Section 2.2.5 of the FEIS has been revised per the comment.
Appendix J

J-53

J.3.11 Alternatives – Immobilization

J.3.11.1 Comments: 69-002

108-003

Comment: The immobilization of surplus weapons plutonium as a means of disposition

was supported. It was stated that immobilization was the best option, rather than making

MOX fuel.

Response: As stated in Section 1.1 of the EIS, the Department of Energy (DOE) is

responsible for the surplus plutonium disposition program in the United States. As such, it

is the DOE’s responsibility to determine how surplus plutonium is dispositioned. The DOE

has prepared two environmental impact statements for the surplus plutonium disposition

program that evaluated a number of alternatives at a number of different locations within the

DOE complex. The environmental impacts associated with immobilizing surplus plutonium

have been previously considered by the DOE. The DOE decided in its April 2002 amended

record of decision to pursue a MOX-only approach and to cancel plans to immobilize

surplus plutonium. For more information on the DOE’s decision to pursue a MOX-only

approach, see Section 2.3.3 of the EIS and Comment J.3.7.2.

J.3.11.2 Comments: 4-001 37-002 64-002 81-002 96-006 112-002

10-023 37-004 68-001 87-003 96-027 114-008

13-003 40-001 71-013 87-005 103-002

15-001 58-003 78-001 91-001 105-008

24-007 61-007 80-003 92-002 105-010

Comment: Failure to consider the immobilization alternative in detail, in the DEIS, was

questioned. It was stated the Department of Energy’s (DOE’s) decision to cancel

immobilization should not limit the Nuclear Regulatory Commission’s (NRC’s) analysis of the

alternative. The DOE’s decision was based on budget constraints not conflict with Russian

and United States policy. This decision was considered to be abysmal. It was also stated

that the DOE has additional surplus plutonium that it not suitable to be made into MOX fuel

and that the DOE may later decide to pursue immobilization in the future. It was stated that

the DEIS does not provide opportunity for stakeholders to comment on the immobilization

alternative as a viable and cost effective option.

Immobilization would effectively achieve the MOX program’s stated goal to safeguard

weapons grade plutonium. It was felt that the DOE should fund this alternative and support

it through further research and development to resolve outstanding technical issues with

immobilizing plutonium. Immobilization was viewed as being superior to the proposed

action (building and operating the proposed MOX facility) for a number of reasons. 

Immobilization was considered to be less costly and less risky while providing a large

number of jobs in the area. Because immobilization is faster than making MOX fuel,

immobilization was considered to be beneficial for limiting diversion, theft and accidents. 

Immobilization was considered to be more environmentally sound and safer to workers. 

Immobilization would help manage existing waste at the Savannah River Site while not
Appendix J

J-54

producing a significant amount of new waste. Immobilization, unlike storage, addresses

proliferation concerns and provides jobs. Immobilization would make the plutonium less

attractive to terrorists and saboteurs. For these reasons, it was felt that an in-depth

comparison of immobilization and the proposed action was required by the National

Environmental Policy Act (NEPA). It was also suggested because of the cost and

complexity of the proposed MOX facility that immobilization could be implemented as an

interim solution to allow for better science to be applied in the future.

It was stated that making MOX fuel would send the wrong message to the international

community by setting an example for the civilian use of plutonium and advance the

technology associated with using plutonium. Also, the MOX fuel program was seen as a

stepping stone for future reprocessing in the United States. In contrast, immobilization did

not have these perceived draw backs.

NRC solicited comments in the Spring of 2002 on whether the NRC should continue to

consider immobilization as an alternative in the DEIS. The question of who commented and

how those comments are considered was raised.

Response: The DOE is responsible for the surplus plutonium disposition program in the

United States. As such, it is the DOE’s responsibility to determine how surplus plutonium is

dispositioned. The DOE has prepared two environmental impact statements for the surplus

plutonium disposition program that evaluated a number of alternatives at a number of

different locations within the DOE complex. The comparison of the environmental impacts

between immobilization of surplus plutonium and making MOX fuel have been previously

considered by the DOE. Therefore, they do not need to be reiterated in the FEIS. 

Furthermore, as discussed in Section 2.3 of the EIS, the immobilization alternative is

considered by the NRC, but not evaluated in detail. The rationale for deciding not to

evaluate the immobilization alternative in detail is set forth in EIS Section 2.3.3. 

As noted in the comment, the NRC solicited stakeholder views on whether the NRC should

still consider immobilization as an alternative in the DEIS. This is discussed in Section 1.4.1

of the EIS. The NRC reviewed the written comments and oral comments made at three

public meetings and determined that no persuasive reasons were identified requiring a

detailed evaluation of the immobilization alternative.

Additional comments relative to the purpose and need can be found in Section J.3.3.

J.3.11.3 Comments: 5-001 58-003 93-004 105-012

45-001 72-013 98-002 114-007

Comment: The rationale for not considering the immobilization alternative to be reasonable

based on a desire to keep the Russians at the negotiating table was questioned. The fact

that Russia does not trust immobilization was not considered an acceptable reason to

eliminate consideration of immobilization as an alternative. Additional arrangements could

be made for Russia to verify the United States’ disposal of the surplus plutonium.
Appendix J

J-55

Response: As discussed in EIS Section 2.3.3, part of the reason for eliminating detailed

consideration of the immobilization alternative was based on the Nuclear Regulatory

Commission’s (NRC’s) view that given DOE’s 2002 amended ROD, a decision to consider

the immobilization alternative would involve the NRC in foreign policy matters that are

outside NEPA’s scope. The Department of Energy (DOE) is the lead federal agency

responsible for implementing national policy associated with the surplus plutonium

disposition program and in implementing related agreements with Russia. 

J.3.11.4 Comment: 86-002

Comment: The decision not to consider immobilization as an alternative to making MOX

fuel (the proposed action) was supported. It was recognized that the Department of Energy,

as the federal agency charged with developing the surplus plutonium disposition strategy,

has already eliminated immobilization as a viable alternative.

Response: This comment is consistent with the EIS. 

J.3.11.5 Comment: 105-002

Comment: The DEIS should select the cheapest disposition method as the preferred

alternative. The Department of Energy (DOE) has stated that the immobilization plan is less

expensive and has greater cost certainty. It was stated that the cost-benefit analysis

ignores the cost to taxpayers. The cancellation of immobilization was viewed as a cost

versus safety trade-off. 

Response: Issues associated with not considering immobilization in the EIS are discussed

in more detail in Comments J.3.11.1 and J.3.11.2. The decision on a preferred alternative

is based on many factors, including costs. Other factors such as benefits, safety, and

environmental harm are also considered. The cost-benefit analysis looks at both national

and regional costs. The cost to taxpayers is evaluated in Section 4.6.2 of the FEIS.

J.3.12 Human Health Risk

J.3.12.1 Comment: 10-013

Comment: The Nuclear Regulatory Commission’s (NRC’S) choice to use the lessprotective health standard of 1 in 10,000 “accepted deaths” in the DEIS rather than the

Environmental Protection Agency’s 1 in 1 million was questioned.

Response: The basis for the commenter’s view that the DEIS used a standard of 1 in

10,000 “accepted deaths” is not clear. In evaluating exposures to carcinogens, the

Environmental Protection Agency (EPA) does consider an increased risk range of from 1 in

1 million to 1 in 10,000 additional cancers as a guideline to determine whether mitigation

actions are needed. For example, mitigation actions are generally required if increased

risks are greater than 1 in 10,000; mitigation actions are generally not required if increased
Appendix J

J-56

risks are less than 1 in 1 million, and mitigation actions may be discretionary or limited if

they are within the risk range. 

In the EIS, radiological doses under both the no-action alternative and the proposed action

are compared with NRC standard and guideline levels. The NRC annual dose limit for

exposures of any individuals in the general public is 1 mSv (100 mrem), used with the

provision that doses should also be kept as far below these limits as is reasonably

achievable. For comparison, the annual average individual exposure in the U.S. is 3.6 mSv

(360 mrem) (3 mSv [300 mrem] from natural sources and 0.6 mSv [60 mrem] from manmade sources). The 1 mSv (100 mrem) per year dose limit corresponds to an increased

latent cancer fatality (LCF) risk of about 6 in 100,000 for an individual. Estimated risks from

radiological exposures for maximally exposed members of the general public under normal

operations were 4 in 1 million and 4 in 1 billion additional chance of an LCF for the no-action

alternative and the proposed action, respectively (see Table 2.1). 

For exposures to chemicals under the no-action alternative, the increased cancer risks to

the general public would be within the risk range of 1 in 1 million to 1 in 10,000 additional

probability of developing cancer for an individual (see Section 4.2.2.2). The risk under the

proposed action was not quantified, because the emissions would be small. 

The EIS cites the standards and guidelines to use for comparison with calculated doses and

risks, but the estimated values for both alternatives are meant to be compared with each

other to facilitate decision-making for the proposed project. 

J.3.12.2 Comments: 6-001

42-001

42-002

Comment: The proposed project has some risks associated with it. Safety and the health

of employees, the general public, and animals should be a number one priority at the

Savannah River Site (SRS).

Response: There is some level of human health risk associated with both the no-action

alternative of continued storage, and also with the proposed action of constructing and

operating the proposed MOX facility. Specifically, estimated risks from radiological

exposures for maximally exposed members of the general public under normal operations

were 4 in 1 million and 4 in 1 billion additional chance of a latent cancer fatality for the

no-action alternative and the proposed action, respectively (see Table 2.1 of the EIS). The

risks to the general public from exposures to chemicals under the no-action alternative were

not explicitly quantified for the DEIS, but the increased cancer risks to the general public

were estimated to be within the risk range of 1 in 1 million to 1 in 10,000 additional

probability of developing cancer for an individual (see Section 4.2.2.2). The chemical risk to

the general public under the proposed action was not quantified because the emissions

would be small. The chemical and radiological risks for workers under the proposed action

and the no-action alternative were within regulatory standard and guideline levels. Risks
Appendix J

J-57

from accidents are generally low, although some low probability accidents could result in

injuries to facility workers and SRS employees. 

J.3.12.3 Comment: 66-005

Comment: The data in the DEIS prevents corroboration of the human health impact

figures. The document is therefore deficient and suspect because these values can not be

corroborated and because of the inclusion of the Waste Solidification Building (WSB) and

the Pit Disassembly and Conversion Facility (PDCF). It was suggested that additional and

corrected data be provided so that the public can offer meaningful comments.

Response: It is unclear what the commenter means by “prevents corroboration of human

health impacts figures.” The intent of the document was to provide enough details on the

methods used to estimate health risks so that readers could understand those methods.

Details on the methods are discussed in Section 3.10 and in Appendix E of the EIS. Risks

associated with the WSB and PDCF were included in the analyses.

J.3.12.4 Comment: 52-003

Comment: The environmental impacts, human health risks, and waste management of the

Pit Disassembly and Conversion Facility (PDCF) and the proposed MOX facility must be

specifically evaluated. Latent cancer facilities associated with the proposed Waste

Solidification Building (WSB) and all substantial handling and transport are significant

portions of the real cost of this mission and are minimized in the DEIS. The DEIS should be

revised. 

Response: The radiological human health risks associated with normal operation of the

proposed MOX facility, PDCF, and WSB are evaluated in Section 4.3.1.1 of the EIS (see

Table 4.3 for a summary); the chemical risks are evaluated in Section 4.3.1.2. The

radiological risk estimates are based on estimated air emissions provided by the applicant,

DCS. The applicant stated that emissions to water would be small because any liquid

discharges from the WSB would be under the existing NPDES permit guidelines. 

Additionally, chemical emissions to air were stated to be small because process controls

limit the release of chemicals to the environment, and engineering controls and personal

protective equipment protect workers from significant exposures, as necessary. Therefore,

human health risk from chemical exposures would be small.

Because facility solid and liquid wastes would be treated and/or disposed of in accordance

with applicable Nuclear Regulatory Commission regulations and Department of Energy

Orders, significant exposure of workers or the public to chemical or radiological materials in

these wastes would not be expected to occur. The waste facilities to which these wastes

would be shipped are permitted facilities required to handle incoming wastes in ways which

minimize impacts to the environment (including minimizing the potential for human

exposures).
Appendix J

J-58

J.3.12.5 Comment: 53-005

Comment: The affected environment chapter should state what the impacts are from

chemicals released at the Savannah River Site (SRS), not which chemicals are being

released at a rate of more than one ton per year.

Response: The air quality section of the Affected Environment (Section 3.4.2 of the EIS)

discusses site emissions and gives the tons/year of toxic air pollutant emissions (Table 3.2).

The Human Health Risk section (3.10.4.2) discusses the baseline environment for chemical

exposures associated with the SRS site (for example, potential receptors, pathways of

exposure, and exposure sources). For chemical exposures, modeling results for the SRS

boundary ambient air concentration of toxic pollutants from SRS point sources are

summarized and compared with health-based guideline levels.

J.3.12.6 Comment: 66-003 

Comment: Any accident would not likely create a uniform offsite dispersion among the

population limited to a 160 pound man with effects stopping at one year. Using Federal

Guidance Report 13 (FGR 13), which does not consider gender, race, or age differences in

response to radiation exposure, results in cumulative errors in the DEIS. Further, an actual

accident may cascade into several of the scenarios illustrated in the EIS, compounding

health effects. The impacts of the proposed MOX facility were questioned because the

DEIS says that statistically no fatalities will occur during normal operations, while the figures

say that 50 people will die by latent cancer fatalities. The DEIS must be corrected to reflect

these concerns.

Response: The EIS provides a conservative estimate of accident impacts and an

independent review of previous accident analyses performed for the MOX facility, the Pit

Disassembly and Conversion Facility and the Waste Solidification Building. The accident

results presented were for a given direction from the SRS estimated to provide the largest

potential dose to the exposed population, with exposure decreasing as a function of

distance from the accident location. The largest exposure for most accidents occurs in the

short-term from inhalation. If ingestion is considered, the highest exposure also occurs in

the first year. In either case, the potential internal intake of the radioactive contamination

results in a long-term internal exposure that was taken into account by the 50-year dose

conversion factors used. 

The health risk conversion factor is not limited to a standard man. As discussed in EIS

Section 3.10.3, the FGR 13 health risk conversion factor of 0.06 fatal cancers per person-Sv

(0.0006 fatal cancers per person-rem) is from the latest available study that provides a

combined gender, age-averaged risk coefficient deemed to be representative of the public. 

It was estimated in the DEIS that up to 50 latent cancer fatalities (LCFs) from short-term

exposure could occur. In the FEIS, the LCF estimates for the public varied from 3 × 10-5 to 3

for the short-term exposure scenario, and from 0.0001 to 100 for the 1-year exposure

scenario (see Table 4.14 in the FEIS). However, conservative assumptions were used in
Appendix J

J-59

the analysis to provide an upper bound on the estimated consequences. In addition, the

likelihood of such an accident is very small. Thus, the overall risk (consequence times

probability of accident occurring) of anyone dying from LCFs related to potential MOX

facility accidents during its operational lifetime is much less than one (see Table 4.15 in the

FEIS). 

J.3.12.7 Comment: 86-033

Comment: In Sections 3.10.4.2 and 4.3.1.2.2, the DEIS uses data completely out of

context to reach erroneous conclusions on several points. The data presented in Table

3.11 for ‘SRS maximum modeled ambient concentration’ and ‘SCDHEC standard’ are

maximum 24-hour averages; i.e., the maximum value that occurred at the Savannah River

Site (SRS) boundary over a single 24-hour period for a one-year period of analysis.

Conversely, the Environmental Protection Agency (EPA) risk guideline levels assume a long

term exposure. Since the wind does not blow in the same direction all through the year, the

long term (e.g., annual) average concentration for a pollutant will be much less than the

maximum 24-hour average.

Table 3.11 and accompanying text should be revised to indicate clearly the context of the

information that is being presented (i.e., averaging period) and to remove any implication

that SRS air toxic emissions pose unacceptable risk to the public, or that (implicitly) the

South Carolina Department of Health and Environmental Control (SCDHEC) standards to

not adequately protect public health.

The DEIS is wrong to state (page 3-54, lines 24-25) that any of the modeled-estimated

concentrations (24- hour) from the 1998 submittal to the SCDHEC exceeds ambient

standards. The SCDHEC Air Pollution Control Regulation 61-62.5, Standard 8, states that

model estimated concentrations for pollutants with a zero standard are to be rounded to the

hundredths decimal place. By applying this guidance to the four pollutants for which the

SRS allegedly exceeds the standard (see Table 3.11), the maximum site boundary

concentration becomes 0.00. These pollutants, therefore, meet the SCDHEC standard of

0.00 in each case.

Response: The comparison of modeled ambient levels of toxic air pollutants (TAPs) at the

SRS with health-based guideline levels is appropriate and has been retained. However,

some of the revisions and qualifiers suggested have been added to the text, as detailed

below. Also, the comment was correct in stating that, when rounding is conducted in

accordance with SCDHEC instructions, no standards are exceeded. The suggested text

and table change to delete reference to exceeding SCDHEC standards has been made. 

The most recent available version of the SCDHEC Standard No. 8 for Toxic Air Pollutants

(dated Oct 26, 2001; available at http://www.scdhec.net/eqc/baq/html/regulatory.html), gives

no details on the criteria or methods used to develop the standard concentrations. Under

National Environmental Policy Act regulations, it is generally recognized that comparison

with regulatory standards is not sufficient to demonstrate the absence of adverse impacts,

because many criteria are considered in establishing regulations. For example, maximum
Appendix J

J-60

contaminant levels (MCLs) for drinking water are enforceable standards established with

consideration of adverse health impacts and best available treatment technology and cost

considerations. Therefore, it is appropriate to compare the modeled ambient air TAP levels

with levels known to be based only on the potential for adverse human health impacts. 

Furthermore, Standard No. 8 itself recognized the applicability of U.S. EPA reference

concentrations in evaluating ambient air levels; several of the standards have a footnote

that states “Verified reference concentration (RfC) established by the United States

Environmental Protection Agency.” However, there are many U.S. EPA RfC values that are

not reflected in the SCDHEC standards. No information is given in the standard to explain

this discrepancy. 

Text has been added to Section 3.10.4.2 of the FEIS to clarify that the modeled

concentrations are maximum 24-hour averages. The comment correctly pointed out that it

is overly conservative to compare maximum 24-hr averages with the EPA guidelines for

long-term exposures; however, it was deemed better to use a conversion factor of 0.2

(based on guidance in documentation for EPA’s SCREEN3 model) rather than the

suggested factor of 0.01. 

J.3.12.8 Comment: 86-034

Comment: In Section 3.10.4.2, page 3-54 of the DEIS, the statutory authority for the

statement “However, emissions of the pollutants listed in Table 3.11 may require further

investigation by the Savannah River Site to determine that ambient levels are not of concern

with respect to human health impacts” was questioned.

Response: The sentence referred to has been deleted from the text. 

J.3.12.9 Comments: 86-037

86-040

86-041

Comment: Reliance on Occupational Health and Safety Administration (OSHA) and South

Carolina Department of Health and Environmental Control (SCDHEC) regulations as

mitigation during construction and operation was questioned. On page 4-11,

Section 4.3.1.2.1, the DEIS discusses exposure to hazardous materials during construction. 

 Exposure to hazardous materials used during construction will be minimized by following

applicable OSHA regulations and precautions. No additional mitigations are necessary. 

Rather, the DEIS should state that exposure to hazardous materials used during

construction will be minimized by following applicable OSHA regulations and precautions. 

Similarly in Section 4.3.1.2.2, the DEIS states, “However, the workplace environment would

be monitored to ensure that airborne chemical concentrations were below applicable

occupation exposure limits.” Exposure to hazardous chemicals used during operations will

be minimized by following applicable OSHA regulations and precautions. No additional

mitigation measures are necessary. Rather, the DEIS should state that exposure to

hazardous materials used during operations will be minimized by following applicable OSHA
Appendix J

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regulations and precautions. In addition, hydrazine emissions from the proposed MOX

facility will be subject to South Carolina Department of Health and Environmental Control

regulations. No additional mitigations are necessary; DCS will comply with SCDHEC air

quality regulations.

Response: The text in Section 4.3.1.2.1 has been changed in the FEIS to indicate that

exposure to hazardous materials used during construction (e.g., paints, solvents) would be

limited by following applicable OSHA regulations and precautions, such as ensuring good

ventilation and cleaning up small chemical spills as soon as they occur.

As indicated in Chapter 5, the Nuclear Regulatory Commission considers complying with

OSHA regulations to be a form of mitigation. Following applicable OSHA regulations during

operations includes monitoring the workplace environment to ensure that airborne chemical

concentrations are within exposure limits. The text in Section 4.3.1.2.2 has also been

changed to note that DCS will demonstrate that operational hydrazine emissions would be

limited to levels that would not cause exceedance of the SCDHEC standards.

J.3.12.10 Comment: 86-038

Comment: In Section 4.3.1.2.1, page 4-12 of the DEIS, the statement, “The 29 October

2002 correspondence from DCS to NRC responding to requests for additional information

included the results of the ’further sampling’ referred to in the DEIS. The DEIS should have

included the results of this report which confirm the previous DCS conclusion that there are

no significant concentrations of radioisotopes or chemicals in the soil, that would be

hazardous to construction workers health” is incorrect.

Response: The referenced characterization report (Plutonium Disposition Program (PDP)

Preconstruction Environmental Monitoring Report [Fledderman 2002]) contained limited

data for nonradiological constituents in soil (e.g., only 10 metals analyzed, no organic

compounds analyzed), and only included shallow soil samples. The data from the report

have been summarized and added to the discussion in Section 4.3.1.2.1 of the FEIS, but

the conclusion that more testing may be required if evidence of possible contamination is

encountered during excavation is retained.

J.3.12.11 Comment: 89-039

Comment: In Section 3.10.5, the DEIS states that a rate of 3.3 fatalities/l000 full-time

equivalents (FTEs) and 4.6 injuries/100 FTEs is used based on Bureau of Labor

Statistics/National Safety Council data. National safety statistics are not appropriate to

represent baseline risks for estimating Savannah River Site (SRS) operations. There have

been no fatalities for over 200,000 FTEs of operations or construction since 1989. The lost

workday injury rate for SRS operations during the past 6 years (1997 – 2002) has averaged

0.38 cases per 200,000 hours (100 FTEs), less than 10% of the value cited in the DEIS.

Response: National statistics for physical hazards are used to estimate the risks from the

no-action alternative and the proposed action, so these national rates are used in the
Appendix J

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affected environment section (Section 3.10.5 of the EIS) to provide a baseline for

comparison. However, text has been added to this section to acknowledge that actual injury

rates at the SRS are lower than those predicted based on national averages. 

J.3.12.12 Comment: 89-045

Comment: In Section 4.3.1.2.2, page 4-13 of the DEIS, the discussion of mixing and

blanketing is unclear. A blanket of nitrogen above the hydrazine does not mix with the liquid

hydrazine that is forwarded to the process.

Response: The text in Section 4.3.1.2.2 has been changed in the FEIS to clarify that the

purpose of blanketing with nitrogen is to shield the liquid hydrazine from unwanted side

reactions.

J.3.12.13 Comment: 89-050

Comment: It is not appropriate to assume in the DEIS that 240 gal of chlorine would be

stored at the Pit Disassembly and Conversion Facility since the Surplus Plutonium

Disposition (SPD) EIS indicates that the quantities of hazardous chemicals are generally

small, and does not indicate that chlorine is an exception to that statement. The SPD EIS

Table E-7 indicates that chlorine will be used in the pit conversion facility, and the

discussion of the accident analysis on Page K-7 indicates that “On an industrial scale, the

quantities of hazardous chemicals are generally small — No substantial hazardous

chemical releases are expected.”

Response: The SPD EIS Table E-7 lists an annual operational resource requirement of

62 m3 of chlorine gas, which corresponds to approximately 240 gallons of liquid chlorine. 

The EIS accident analyses include all hazardous chemicals stored in any of the facilities in

quantities greater than 10 gallons (see EIS Appendix E). Chlorine was assumed to be

stored as a pressurized liquid, as is common in industrial facilities. The analyses showed

that an accidental chlorine release would not have adverse impacts for the general public at

the Savannah River Site (SRS) boundary, but that it could result in high adverse impacts for

workers. 

J.3.12.14 Comment: 97-009

Comment: A temperature of 25.8C (78.5F) is stated as an average. This is not a

reasonable average nor does it provide any margin. Temperatures in excess of this would

be anticipated to occur many times each year (i.e., an anticipated, annual event). In

addition, solar heating effects on the structure (the Reagent Storage Building is a metal

structure), other buildings and storage areas, and during deliveries could push local ambient

temperatures in excess of 120F. Thus, the assumed average temperature does not

address anticipated conditions that occur annually nor do they provide any margin or

conservatism. A higher temperature should be used for vapor pressures and release

calculations.
Appendix J

J-63

Response: The 25.8C (78.5F) 95th percentile nighttime temperature is representative of

conditions corresponding to the site-specific annual 95th percentile concentration

determined from the radiological accidental release modeling. Review and analysis of

on-site historical meteorological measurements taken at a nearby Savannah River Site

operated tower shows that this temperature is exceeded only 5% of the time during

nighttime low-wind speed conditions. The 95th percentile daytime temperature was found

to be 30.8C (87.5F). Therefore, use of a value representing the 95th percentile is

considered representative of a reasonable upper bound. These values were chosen to

maintain consistency with the radiological accident assessment, and with Nuclear

Regulatory Commission guidance. Details and rationale for the meteorological conditions

assumed for accident modeling are provided in Appendix E, Section E.1 of the EIS.

J.3.12.15 Comment: 97-012

Comment: Nitrogen tetroxide is a chemical that requires great care during handling and

use, as discovered from the space and missile programs. It boils at near ambient

conditions and significantly dissociates into nitrogen dioxide at temperatures slightly above

ambient, which greatly increases the effect of releases. It can also cause common mode

failures. In addition, the nitrogen tetraoxide would be pressurized in the proposed MOX

facility. The DEIS is not clear if this been accounted for in the analyses. The DEIS

indicates an estimated concentration of 1,600 mg/m3

 at 100 meters. This is a potentially

lethal concentration and would likely result in large numbers of serious injuries and fatalities

if the release occurred at the proposed MOX facility, and could negatively impact adequate

safeguarding of nuclear materials. The DEIS does not discuss adequate mitigation and/or

prevention of such events. The DEIS should acknowledge and address these concerns.

Response: In EIS analyses, the accidental release of nitrogen tetroxide is modeled as a

pressurized release. Nitrogen tetroxide is identified in the accident impacts, chemical

human health risks section of the EIS (4.3.5.3) as a chemical which, if accidentally released,

could cause high adverse impacts to workers. Nitrogen tetroxide would be regulated by the 

Occupational Health and Safety Administration (OSHA) under its Process Safety

Management Rule (29 CFR 1910.119). The Process Safety Rule contains requirements for

preventing or minimizing the consequences of catastrophic releases of toxic, reactive,

flammable, or explosive chemicals. Under this rule, DCS would perform a hazard analysis,

develop and implement written operating procedures that provide clear instructions for

safely conducting activities involving process chemicals covered by the rule, develop and

implement a training program, develop and implement an inspection and testing program,

and develop and implement an emergency planning and response program. Text has been

added to Table 5.1 to reflect these mitigation measures.
Appendix J

J-64

J.3.12.16 Comment: 107-002

Comment: The DEIS discusses the need to demonstrate that the offgas treatment system

will limit hydrazine, (listed as a hazardous air pollutant under the Clean Air Act), to very low

levels. The DEIS states that these levels would not cause adverse health impacts to

members of the public or employees. Information about plans for monitoring the offgas

treatment system for hydrazine should be included in the FEIS.

Response: During Clean Air Act permitting, it must be demonstrated that hydrazine

emissions will not cause exceedance of the South Caroline Department of Health and

Environmental Control ambient standard of 0.06 g/m3

 at the Savannah River Site

boundary. This may be demonstrated in a variety of ways. It is possible that mass balance

calculations based on the annual usage of hydrazine, coupled with conservative

assumptions on fugitive emissions and air dispersion modeling, would indicate that an

offgas treatment system is not necessary. These issues would be further investigated by

DCS during the permitting process. 

J.3.12.17 Comment: 85-003

Comment: Concern was express regarding the safety and health of all the individuals in

this area. Additional attention and study of these safety issues should be undertaken. The

DEIS does not provide conclusive evidence that this site is currently “safe” for the

community that lives around its borders, much less that the people will be safe when this

facility is built. 

Response: The methods used to estimate safety and health impacts in the EIS were

designed to ensure – through uniform and careful selection of assumptions, models, and

input parameters – that impacts would not be underestimated and that relative comparisons

among the alternatives would be meaningful. 

Based on these methods, the DEIS identified some level of human health risk to the off-site

public associated with both the no-action alternative of continued storage, and also with the

proposed action of constructing and operating the proposed MOX facility. Specifically,

estimated risks from radiological exposures for maximally exposed members of the general

public under normal operations were 4 in 1 million and 4 in 1 billion additional chance of a

latent cancer fatality for the no-action alternative and proposed action, respectively (see

Table 2.1 of the FEIS). For exposures to chemicals under the no-action alternative, the

estimated increased cancer risks to the general public were within the risk range of 1 in 1

million to 1 in 10,000 additional probability of developing cancer for an individual (see

Section 4.2.2.2 of the FEIS). The chemical risk under the proposed action was not

quantified, because the emissions would be small. Risks from accidents are generally low,

although some low probability accidents could result in increased cancer risks (from

radiological exposures) or injuries (from chemical exposures) for facility workers and

Savannah River Site employees. 
Appendix J

J-65

Investigation of the health records of the surrounding communities is beyond the scope of

the EIS. However, the human health impact assessment (discussed above) did not indicate

that the proposed action would result in an increase in adverse health effects in the

surrounding communities. 

J.3.12.18 Comment: 86-039

Comment: In Section 4.3.1.2.2, page 4-12, lines 19-21 of the DEIS, the list is missing

oxalic acid, sodium hydroxide, and sodium carbonate all of which were listed in MOX ER

Table 3-2. 

Response: The chemicals listed in the DEIS text were not intended to include all the

chemicals used in the process. The text has been revised in Section 4.3.1.2.2 of the FEIS

to add a reference to Appendix E, where all the chemicals used are listed. Appendix E also

explains why accidental releases of some of the chemicals were not modeled (i.e., some

were dropped because they would be stored in quantities of less than 10 gallons; some

were dropped because a temporary emergency exposure limit-1 (TEEL-1) value of greater

than 15 mg/m3

 indicated low toxicity). 

J.3.12.19 Comment: 86-060

Comment: Table 4.16 presents a larger volume of nitrogen tetroxide (i.e. 240 gallons or

912 liters) in a storage/transportation cylinder than is planned to be used at the proposed

MOX facility. DCS intends to use a storage/transportation cylinder containing 2000 lb

(907 kg) of nitrogen tetroxide. This corresponds to 630 liters of nitrogen tetroxide. 

Response: The assumed container sizes for accidental chemical releases were obtained

from the October 31, 2002, revision of the Construction Authorization Request (CAR). 

Table 8-2a of the CAR gives a container size of 240 gallons (1 ton) for nitrogen tetroxide. 

Although DCS may have now revised its plans for the nitrogen tetroxide cylinder size to be

used at the facility, the outcome of the assessment would not change if the storage volume

were reduced by approximately one third. That is to say, an unmitigated accidental release

of either volume would not cause adverse impacts for the off-site general public, but could

result in moderate to large adverse impacts for the Savannah River Site employee

population. Preventive planning and mitigation measures in case of spill are required when

extremely hazardous substances are in use at industrial facilities. 

J.3.12.20 Comment: 97-008

Comment: Section 4.3.5.3, page 4-42 of the DEIS discusses the potential effects from

chemical releases and accidents. The DEIS uses temporary emergency exposure limits

(TEELs) which are adopted by the Department of Energy Subcommittee on Consequence

Assessment and Protective Action (SCAPA). TEEL values also change frequently and may

underestimate potential concerns and required mitigative or preventative methods. It is

recommended that more conservative and regulator-endorsed values are used. This may
Appendix J

J-66

involve a methodology to select the lowest values from Acute Exposure Guideline Levels

(AEGLs), Immediately Dangerous to Life or Health ( IDLHs), Military Air Guidelines (MAGs),

and National Institute for Occupational Safety and Health (NIOSH)/Occupational Safety and

Health Administration (OSHA). 

Response: It is agreed that certain acute exposure guideline values have received a higher

level of research and peer review than others, and that those higher quality values should

be used if available. Acute Exposure Guideline Level (AEGL) values would be the most

preferable, because the AEGLs are derived by an independent panel of experts under the

auspices of the National Research Council’s Committee on Toxicology, and because the

criteria for AEGL derivation take into account sensitive individuals (i.e., they would be

protective for nearly all people). AEGL values are derived for three tiers of effects –

essentially a threshold level below which no adverse effects would be expected (AEGL-1), a

threshold level below which only minor adverse effects would be expected (AEGL-2), and a

threshold level below which life-threatening effects would not occur (AEGL-3). AEGL values

are currently available for only nine chemicals, and none of these are chemicals that would

be used in the proposed facilities. 

Of the 15 chemicals for which air dispersion modeling was conducted for the EIS accident

analysis, 12 have IDLH values and two have NIOSH/OSHA ceiling values. Acute exposure

guidelines not mentioned by the commenter are the Emergency Response Planning

Guidelines (ERPGs) developed by the American Conference of Governmental Industrial

Hygienists (ACGIH). These values are similar to the AEGL values in that three effect levels

are derived for each chemical (with definitions similar to those for the AEGL values). The

ERPG values are widely used for emergency response planning, because they are derived

by panels of toxicologists reviewing all available data, and because they are well

documented. ERPG values are available for about 100 chemicals. ERPG values were

available for 6 of the 15 chemicals in the EIS analysis. 

Temporary emergency exposure limit (TEEL) values are not intended to supercede values

derived more rigorously through critical review of all available toxicity literature for a

chemical. They are specifically “temporary emergency exposure limits” to be used only

when other values (that is, AEGLs or ERPGs) are not available. In fact, whenever ERPG

values are available for a given chemical, those values are adopted as the TEEL values. 

However, when data are lacking, the process of deriving TEELs is very similar to what the

commenter suggested; there is a hierarchy that uses IDLH values to approximate the

potentially life-threatening value (TEEL-3), uses IDLH/10 or ceiling values to approximate

the irreversible injury threshold, and uses occupational short-term exposure limits to

approximate the minor injury threshold. (Craig et al., 2000, “Derivation of Temporary

Emergency Exposure Limits (TEELs),” J. of Applied Toxicology, 20, 11-20). Modified values

from other countries, such as Germany’s maximum allowable concentrations (MAKs) for

occupational exposures, may also be used if no U.S. values are available. If none of these

data are available, other data such as (lethal concentration) LC50 values are used. TEELs

are now available for over 2000 substances. Because the TEEL values do incorporate

readily available regulatory and guideline values, they are the best alternative for use in

evaluating accidental exposures when AEGL or ERPG values are not available. 
Appendix J

J-67

In EIS Appendix E, Section E.1 (Accidents, Chemical Human Health Risk), text has been

added to explain the different acute emergency planning values that are available, and why

the ERPG and TEEL values were chosen. An additional change that has been incorporated

into the analysis is that the TEEL values used to evaluate the hypothetical hydrazine release

have been changed from those for hydrazine hydrate to those for hydrazine. ERPG values

are available for hydrazine (but not hydrazine hydrate), and the TEEL values are the same

as the ERPG values. These ERPG (also TEEL) values are considered to better represent

the toxicological database for hydrazine.

J.3.12.21 Comments: 86-114

86-115

Comment: In Table E.1 of the DEIS, the solution molecular weight (94 g/mole) and the

solution density (2.13 kg/l) for hydrazine/sodium hydroxide appear to be incorrect. 

Response: Table E.1 of the FEIS has been changed to reflect the correct molecular

weights and densities for hydrazine and sodium hydroxide.

J.3.12.22 Comment: 86-116

Comment: In Table E.3 of the DEIS, evaporation rates and vapor pressures of evaporating

chemicals appear to be incorrectly calculated for chemicals where mole fractions were used

to calculate the vapor pressures, which in turn were used to calculate the evaporation rates.

Response: Mole fractions were estimated based upon the data provided on storage and

process chemical compositions and concentrations. 

J.3.12.23 Comment: 97-010

Comment: The chemicals are used in processes within the proposed MOX facility. 

Process temperatures will likely exceed ambient temperatures considerably. For example,

solvent extraction processes routinely can exceed 50C (122F) , while evaporators can

exceed 100C (212F). These higher temperatures should be used as appropriate for

modeling the evaporation of process spills and may necessitate the use of other models

(e.g., flashing and bulk convection) for estimating release rates. 

Response: None of the bounding chemical accidents analyzed in the DEIS involved

process accidents (i.e., accidents that occur during aqueous polishing or fuel fabrication at

the proposed MOX facility). Therefore, the chemical accident analyses did not consider

temperatures of chemicals during processing. 

J.3.12.24 Comments: 86-058

89-049

Comment: The temporary emergency exposure limit (TEEL) values given for hydrazine

hydrate in Table 4.16 are the TEEL values for hydrazine hydrate, aqueous solutions. DCS
Appendix J

J-68

plans to use hydrazine monohydrate. The TEEL values for hydrazine monohydrate should

be used instead of hydrazine hydrate. 

Response: The MOX ER (Rev 3, June 2003), Table 3-2 (Chemical Consumption and

Onsite Inventory) lists hydrazine (35%) as a process chemical, with an annual usage of

530 gallons, and an onsite inventory of 126 gallons. The EIS uses the TEEL values for

hydrazine hydrate, aqueous solutions, to evaluate an accidental hydrazine release. The

assessment has been revised to evaluate an accidental release on the basis of comparison

with the TEEL values for hydrazine, which are the same as the Emergency Response

Planning Guideline (ERPG) values and have received thorough critical review. The ALOHA

model used to estimate the downwind hydrazine concentrations takes into account the

concentrations of the released chemical (in this case, 35%). The use of the peer-reviewed

ERPG values for evaluating the hydrazine release is preferable to using either the TEEL

values for hydrazine hydrate or for hydrazine monohydrate, which have not received the

same level of review and may be based on default data (see Comment J.3.12.20 for more

information).

J.3.12.25 Comments: 86-059

86-113

Comment: The DEIS appears to contain an erroneous calculation of solute mole fraction

and vapor pressure for hydrazine/sodium hydroxide, hydrazine/hydroxylamine nitrate,

hydrogen peroxide, hydroxylamine nitrate, nitric acid, which has resulted in significantly

larger estimates of the modeled airborne concentrations and distances to reach the

temporary emergency exposure limit (TEEL) limits. 

Response: The assumptions and calculations made to estimate spill evaporation rates

were based upon data supplied by DCS. The calculations were checked by the Nuclear

Regulatory Commission and are consistent with the chemical inventory data supplied and

the assumptions necessary to carry out the calculations. The commenter provided no

supporting data or calculations to substantiate an error in the mole fraction calculations.

J.3.13 Human Health – Radiological Risk

J.3.13.1 Comments: 24-003

71-008

Comment: It was suggested that long-term, well-controlled, epidemiologic studies of

workers and other potentially exposed populations be conducted by impartial, qualified

scientists. Such studies should have been conducted on populations which might have

been exposed through air, water and food ingestion. Such studies should not be prejudiced

by prior assumptions, such as extrapolating data derived from the flawed studies of

Hiroshima and Nagasaki, which were limited to the survivors of those acute massive

exposures. It is difficult to justify the absence of such studies and further how a DEIS can

be adequately carried out in the absence of such data. The DEIS would have more validity
Appendix J

J-69

if risk factors were based more upon such information. Effects of chronic low dose radiation

have been reported by scientists such as Drs. Alice Stewart and Dr. Steve Wing (UNC

Chapel Hill). Absent the use of such epidemiologic data, skepticism is warranted regarding

the estimated health risks presented in the DEIS.

Response: Health effects of low levels of radiation exposure are not determined solely on

the basis of the Hiroshima and Nagasaki studies. Other epidemiological studies are used

as well, such as those on patients exposed during medical treatment, occupational

exposures of workers in the nuclear industries, and exposures of people in high natural

background radiation areas. These studies have been ongoing for a long time, some for

close to half a century, and they have been periodically updated and reviewed by a number

of organizations, including the National Academy of Sciences. To date, no excess cancers

have been identified below a dose of about 5 rem that can be attributed to radiation

exposure. However, current understanding of the initiation and development of cancer, as

well as available data, do not support a reliable conclusion that there are no effects below

this level. It is therefore the cautious policy of the Federal Government to assume that the

risk of cancer at low-levels of radiation exposure increases linearly in proportion to the dose,

with no cut-off level below which there is no risk. This assumption is conservative in that it

is likely to overestimate the risks at low levels of radiation exposure, which may be zero, but

is not likely to underestimate such risks.

J.3.13.2 Comment: 37-001

Comment: It was stated that comparing human dosage that we receive from natural

sources and things that we cannot avoid or things that we choose to benefit our health,

such as radiation from the cosmic universe, medical exams, chest X-rays, with dosage from

harmful radioactive isotopes that we do not choose is an obfuscation of the impacts.

Response: The comparison of human dosage we receive from natural or medical sources

is intended to provide a unit of measure, a sense of scale, that the public may use to assess

the estimated risks presented in the EIS.

J.3.13.3 Comment: 53-004

Comment: The DEIS does not state what the radiological impacts are. It provides potential

radiological doses, but does not state what the impact is in terms of specific measurements

such as curies or becquerels. The DEIS should state the quantity of radioactive material

that is being released.

Response: Estimated releases of radioactivity for normal operations and accidents are

presented in Appendix E, in Tables E.5 (microcuries per year) and E.13 (curies),

respectively.
Appendix J

J-70

J.3.13.4 Comment: 53-006

Comment: The DEIS does not discuss the impacts of americium. Americium is significant

because it poses a risk that is disproportionate to the risk of plutonium and there will be

large waste streams of americium. It was suggested that the americium could be used or

recycled in smoke detectors or other commercial products. The DEIS should state the

hazards of americium.

Response: Americium is a hazardous radioactive material similar to plutonium that has

been accounted for in the impact analyses (See Tables E.5 and E.13). Americium is not

any different in its radiation effects from other radioactive materials of the same category,

namely alpha radiation emitters, and it poses the same types of hazards. The differences in

risk between americium and other alpha emitters such as plutonium is factored into, and

considered, in the calculation of dose. A given dose equivalent of radiation poses the same

risk, regardless of the source of the radiation that causes it. The amount of americium in a

smoke detector is very small, approximately 1 microcurie. The amount of americium

estimated to be separated from the plutonium is orders of magnitude larger than needed for

this application and must be disposed of properly.

J.3.13.5 Comments: 71-005

71-007

Comment: Building and operating the proposed MOX facility at the Savannah River Site

would place workers’ health at greater risk from unnecessarily increasing their plutonium

exposure. It places populations in nearby areas at increased risks of exposure to plutonium

and other byproducts of such a facility.

Response: All operations at the proposed MOX facility would be carried out in a manner

that reduces the risks to workers, the public, and the environment in accordance with

Nuclear Regulatory Commission regulations. The main difference between exposure to

plutonium and exposure to any other radioactive material is that, because plutonium often

produces higher doses from a given amount of material than many other radioactive

materials, it must be kept at low levels throughout the work areas. This is taken into

account in the design of the facility.

J.3.13.6 Comments: 71-001 86-069 94-001

72-009 86-112

86-056 93-014

Comment: Concern was expressed regarding the data and basis on which radiation

exposure and health risks were determined. The use of “standard man” does not

adequately reflect radiation impacts to young and old people that are at a much higher risk. 

It was stated that a millirem is not a millirem. The health risk depends on other factors such

as age and sex. It was suggested that the Nuclear Regulatory Commission (NRC) should

follow the Environmental Protection Agency (EPA) and adopt a separate set of evaluation
Appendix J

J-71

standards for childhood cancers. In addition, the use of the EPA Federal Guidance

Report 13 (FGR 13) health risk conversion factor was questioned. The FGR 13 risk factor

relies on studies not yet incorporated into international standards and is another overly

conservative assumption used in the risk assessment that results in an order of magnitude

higher risk.

Response: The effects of low dose radiation are still being debated in the international

scientific community after decades of study. The current approach attempts to ensure that

the assessed impacts do not underestimate any potential hazards. It is true that young

people tend to be more susceptible to radiation than adults. The use of FGR 13 data takes

this into account because these dose conversion factors consider exposure to all age

groups in a typical US population and calculates the average risk to such a population. 

These factors take into consideration the risk of exposure from childhood for a lifetime for

children, as well as lifetime exposure starting at adulthood. The FGR 13 health risk

conversion factor of 0.06 fatal cancers per person-Sv (0.0006 fatal cancers per person-rem)

used in the EIS is from the latest available study that provides a combined gender, ageaveraged risk coefficient deemed to be representative of the public.

The FGR 13 health risk conversion factor is based on U.S. population mortality statistics,

but incorporates many of the more recent recommendations from the International

Commission on Radiological Protection (ICRP), such as ICRP publications 66 and 67, since

ICRP Publication 60. ICRP Publication 60 recommended a factor of 0.05 fatal cancers per

person-Sv (0.0005 fatal cancers per person-rem; see Table 3 of that publication) for the

public. The FGR 13 value of 0.06 fatal cancers per person-Sv (the next possible higher

value considering the uncertainties involved) is only 20% higher, not an order of magnitude

higher as suggested in some comments. The use of the FGR 13 risk factor, rounded to one

significant figure, has been used by the NRC and other Federal agencies and is considered

to be an appropriate estimate of the risks associated with radiation dose.

J.3.13.7 Comments: 53-002

 73-001

105-004

Comment: The public health effects from radiation exposure in the DEIS are expressed in

terms of cancer effects. If that is the only health consequence that is going to be

addressed, at least say why other consequences are not being addressed, what you know

and what you don’t know about the impacts of ionizing radiation. It was suggested that,

based on research by Dr. John Gothman, ischemic heart disease should be considered. It

was stated that in Barnwell County there is a 15% elevated level of ischemic heart disease

above the average of the State of South Carolina. In addition, birth defects and mental

retardation (genetic damages) are more prevalent than cancer, but because they occur in

the children of the workers they are often overlooked. 

Response: The only effect of concern at the low levels of radiation considered in this EIS

are the development of cancer and possible genetic effects. Genetic effects have not been

demonstrated to occur in humans, and the only effect of concern here is cancer. Other
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radiation effects do occur, but at much higher doses than can arise in this case. Mental

retardation also does occur, but again, only at much higher radiation levels than those

considered here. To protect against these effects, female workers who are, or may be,

pregnant are given the option of requesting to be assigned duties that involve much

reduced radiation exposure levels, until the end of the pregnancy.

The extent to which low levels of radiation cause cancer is currently the subject of scientific

debate. The NRC used conservative assumptions and values to estimate potential LCFs

from hypothetical accidents so as not to underestimate potential impacts. Because

statistical data on low level radiation exposure and from previous accidents are inconclusive

as to the inducement of cancer, these assumptions were based on extrapolation of data

from exposure of humans to high levels of radiation, much higher than members of the

public would expect to receive if an accident occurred at any of the proposed facilities. 

Ischemic heart disease has a variety of causes as does cancer. To determine if the 15%

elevated level is even statistically significant, regardless of the cause, a detailed analysis of

the other counties in the area and potential confounding factors would first have to be

conducted. The text in Section 3.10.3 of the FEIS was revised to indicate that cancer is the

primary risk from radiation and that hereditary risks are also possible.

J.3.13.8 Comments: 73-004

115-001

Comment: The national emission standards for radionuclides, other than radon, from

Department of Energy facilities states that emissions of radio nuclides to the air shall not

exceed that which would cause any member of the public to receive a dose of ten millirems

per year. Emission measurements from the stacks are stipulated in the existing Title V

permit. But the millirem standard for the maximum allowable dose to the public is an

ambient standard, not an emission limit. The existing permit fails to require any direct

measurement of radioactive dose to the public, and cannot be enforced as a practical

matter. This is a serious problem for many of the radionuclide-emitting facilities, including

the proposed MOX facility. 

The Savannah River Site does not currently meet five Title V emission standards with the

existing operations. The addition of the Pit Disassembly and Conversion Facility (PDCF),

the Waste Solidification Building (WSB), proposed MOX facility, the potential the siting of

the Modern Pit Facility, and the potential use of the incinerator during the term of operation

of the proposed MOX facility may cause additional violations.

The EIS must show that any additional activities, and cumulative and additive activities

would not result in exceeding the National Emission Standards for Hazardous Air Pollutant

(NESHAPs) limit when combined with current operations. Further, the NESHAP is written in

millirems to individuals off site. There is no current monitoring done by the DOE, or

reported in the DEIS that can, in fact confirm public doses from all current sources of

radiation exposure to the public at the Savanna River Site. 
Appendix J

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Response: The primary restriction placed by NESHAPS is the 10-mrem/yr dose to any

member of the public from air emissions. Placing restrictions on emissions is an indirect

way of ensuring that this restriction is met. Whether the restriction is placed on the dose, or

on emissions, it is necessary to use dose models that allow calculation of the dose to the

public resulting from the emissions, to show that this 10-mrem/yr value is met. The main

aim, therefore, is to ensure that the total of all air emissions from the facility does not result

in a dose that exceeds this value. Emissions are monitored or estimated, and even though

direct limits may not be imposed on them in a manner similar to that in Title V, the

monitoring data are used to calculate the public doses to show compliance with all

applicable limits. If other facilities in the vicinity of the MOX facility also contribute to public

dose, adjustments will be made to ensure that the total dose does not exceed any

applicable limit.

Conservative assumptions in dose modeling are used to ensure that the calculated dose to

a maximally exposed member of the public is not underestimated. A maximally exposed

individual (MEI) of the public is expected to receive approximately 0.04 mrem per year as a

result of air emissions from SRS operations as presented in Table 3.10 in Section 3.10.3. 

Using conservative assumptions, the estimated exposure to a public MEI from operation of

the proposed MOX facility, PDCF, and WSB was 0.0025 mrem per year as presented in

Table 4.3 in Section 4.3.1.1.2. The combined exposure to current SRS activities and the

MOX facilities would be about 0.0425 mrem, or about 0.425% of the 10 mrem NESHAP

standard.

J.3.13.9 Comment: 86-117

Comment: In Section E.2.l.2, page E-17, line 32, the DEIS states that “To obtain

conservative estimates of potential exposure and doses, the SRS employees were assumed

to be exposed to radiation from airborne emissions without any shielding by buildings or

other structures.” If factors of 0.5 and 0.7 from U.S. NRC 1.109 were used as stated on the

next page, shielding was taken into account. 

Response: The sentence in Appendix E, Section E.2.1.2, was removed from the text.

J.3.13.10 Comment: 86-118

Comment: In Section E.2.1.2, page E-18, line 37, the DEIS states that the total time of

external exposure to a plume and contaminated soils for SRS employees was assumed to

be 0.5 year. This is an incorrect interpretation of the 0.5 factor in U.S. NRC 1.109. The

0.5 accounts for shielding while the individual is present. When the individual is present

approximately 23% of the time (2000/365/24), this factor is further reduced by 0.5.

Response: The factor of 0.5 does account for shielding while the individual is present.

However, the bulk of the emissions from the MOX-related facilities during operations would

occur while the Savannah River Site employees are present. Thus, it is not reasonable to

assume a further reduction in exposure.
Appendix J

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J.3.13.11 Comments: 86-119

86-120

Comment: In Section E.2.1.2, page E-18, line 45, the DEIS states that the total time of

external exposure to a plume and contaminated soils for a maximally exposed individual

was assumed to be 0.7 year. For the inhalation pathway, an exposure time of 1 year was

assumed. This is an incorrect interpretation of the 0.7 factor in U.S. NRC Regulatory

Guide 1.109. The 0.7 accounts for shielding while the individual is present. The individual

is present approximately 23% of the time (2000/365/24) and this factor is further reduced by

the 0.7 factor. 

Response: The factor of 0.7 does account for shielding while the individual is present.

However, the bulk of the emissions from the MOX-related facilities during operations will

occur while the Savannah River Site employees are present. Thus, it is not reasonable to

assume a further reduction in external exposure to the plume. The factor of 0.7 for external

exposure to contaminated soil was retained as a conservative assumption that does not

affect the estimated impacts. External exposure from the plume and soil was approximately

5 orders of magnitude less than the inhalation exposure. 

J.3.13.12 Comment: 89-044

Comment: In Section 4.3.1.1.1, the number of facility workers at the proposed MOX facility

should be stated as was done for the Pit Disassembly and Conversion Facility and the

Waste Solidification Building. 

Response: The number of facility workers at the proposed MOX facility was added to the

discussion in Section 4.3.1.1.2.

J.3.13.13 Comments: 52-004 93-018

92-006 114-002

Comment: The DEIS assumes a 10-year MOX program but DCS plans to apply for a

20-year license. This assumption would tend to underestimate the human health impacts. 

Given the uncertainty in operational periods for the Pit Disassembly and Conversion Facility,

the DEIS must analyze dose, risk and cost-benefit impacts of MOX production over 20-year

duration.

Response: The rationale for assessing the 10-year operational period impacts is presented

in Section 1.21 of the EIS (Proposed Action). As discussed, the minimum amount of time it

would take the facilities to process the plutonium under consideration would be

approximately 10 years, if the facilities were operated at their maximum design capacity. 

Thus, the highest human health impacts would occur on an annual basis as reported in EIS

Section 4.3.1 (Human Health Risks) because a 10-year operational period was assumed. 

The assumption of a longer operational period, such as 20 years, would be less

conservative because the annual impacts would be proportionately less since the impacts

would occur over a longer period of time.
Appendix J

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J.3.13.14 Comments: 1-001

116-017

Comment: The EIS estimates latent cancer fatalities (LCFs) from radiation exposure in a

deterministic fashion without regard to any uncertainty in the estimate. Indeed, the estimate

for the result of low doses should at least include the possibility of zero effect. The estimate

of LCFs in the DEIS has already been the subject of media reports and public concern. 

This is an important issue that must be resolved.

The LCFs currently calculated in DEIS should be listed as the “upper limit.” The number of

LCFs should be expressed as a range that includes zero effect. This opinion is supported

by the Health Physics Society position paper, Radiation Risk in Perspective, of January

1996, reaffirmed March 2001. The Society of Nuclear Medicine and the American College

of Nuclear Medicine voted unanimously to support that position. 

The potential for positive health benefits from radiation exposure should be included at least

as a note to the LCF discussion. There are ample references for the basis of this point.

The European Committee on Radiation Risk (ECRR) has published a 2003 set of

recommendations on health effects of ionizing radiation exposure at low doses for radiation

protection purposes. Regulator's Edition: Brussels, January 2003. This information should

be compared with the information the NRC uses and the NRC should indicate which is valid.

Response: The estimated risk of LCFs is likely to represent an upper limit, and it is

possible that there are no such risks at these low levels of exposure, which the proposed

action is expected to produce. However, current knowledge does not permit reaching such

a conclusion. It is therefore Federal policy, as well as the recommendations of all national

and international advisory organizations, to assume that there is a risk at any dose level,

and that this risk increases linearly with dose. The opinion expressed in the Health Physics

Society Position Paper appears to be reasonable, but it does not provide sufficient

supporting data to permit adoption of this position in Federal regulatory policy.

J.3.13.15 Comment: 27-009

Comment: The pathways discussed in Section 3.10.1.1 do not identify atmospheric

particulate matter that has settled on the ground and that can be introduced into

groundwater by recharging precipitation in a recharge area, or if the deposits are washed

into surface water by overland runoff in areas where the surface water is in hydraulic

connection with the ground water. It is suggested that the potential for groundwater

contamination from atmospheric particulate matter deposited on the land surface at the

MOX or F-Area sites be addressed in the DEIS.

Response: The potential impacts from the pathway suggested in the comment (i.e.,

airborne release to soil deposition to groundwater to humans) was not explicitly considered

in this EIS. There is the potential that contamination from atmospheric deposition could

reach groundwater; however, the contribution of this pathway to human exposure would be
Appendix J

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much less than the human health impacts presented in this EIS for several reasons. The

upper aquifer at the SRS is not used for drinking water, and significant dilution of any

contamination would occur before the groundwater exited the SRS. Therefore, any

contamination of this aquifer would not contribute significantly to human health impacts. A

detailed discussion of the many pathways from operations at the SRS is presented in the

SRS annual environmental report (Arnett and Mamatey 2001b) (see reference section for

Chapter 3). The pathway suggested by the commenter is not listed as a significant pathway

from airborne releases.

J.3.13.16 Comment: 53-003

Comment: The DEIS should state the value of natural background radiation at the

Savannah River Site (SRS), not the national level. Because of the lower elevation, the

lower radon levels, and the small number of basements, the natural background is different

from the national average. In addition, the harm and benefits caused by natural

background radiation needs to be presented in the DEIS. 

Response: Natural background radiation in the Savannah River Site area, which includes

consideration of the site’s elevation and radon levels, is expected to be near the national

average as presented in Chapter 7 of the Savannah River Site Environmental Report for

2000 (WSRC-TR-2000-00328). Natural background radiation has the potential to cause

latent cancer fatalities as does man-made radiation.

J.3.13.17 Comment: 86-035 

Comment: The requirement for additional soil sampling discussed in Section 4.3.1.1.1,

page 4-8 of the DEIS was questioned. The October 29, 2002, correspondence from DCS to

the Nuclear Regulatory Commission responding to requests for additional information

included the results of the ‘further sampling’ referred to in the DEIS. The DEIS should have

included the results of this report which confirm the previous DCS conclusion that there are

no significant concentrations of radioisotopes or chemicals in the soil, that would be

hazardous to construction workers’ health.

Response: Although no contamination is expected, further sampling may be necessary. 

The text was revised to include the reference to the sample results described in the

October 29, 2002, correspondence, but the results do not include samples to the depth that

will be required for building foundations in the area of the spoils pile. Samples were only

taken down to a depth of 12 inches. Samples were not taken at the depths required to

sample both the entire extent of the spoils pile and the ground underlying the spoils pile in

areas which could be disturbed by construction activities.

J.3.13.18 Comment: 86-036 

Comment: The DEIS (Section 4.3.1.1.2, page 4-8 and in Appendix E, page E-16) includes

internal exposures for workers from normal operations. Since internal exposures would only
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result from breaches of containment, these exposures should not be considered as part of

normal operations, but should be considered only in the accident impacts assessment.

Response: Ideally, internal exposures are not expected under a normal operating

environment. In practice, there will be some internal exposure during the course of normal

operations because of residual levels of contamination.

J.3.13.19 Comment: 86-123 

Comment: The values of ingestion parameters in Table E.9 for the maximally exposed

individual (MEI) and the general public were questioned. Each line repeats the same

number (276 kg/yr for the MEI and 163 kg/yr for the population), when this should be the

total for all three.

Response: The values used for ingestion parameters for root vegetables, fruit, and grain

were taken directly from Appendix D, Table D-4 (page D-20), of the MOX ER (Mixed Oxide

Fuel Fabrication Facility Report, Revision 1&2) submitted by DCS. The values have been

revised as suggested in the comment based on Savannah River Site data. 

J.3.13.20 Comment: 86-125 

Comment: Table E.13 does not include uranium-238, 99% of uranium inventory.

Response: The comment pertains to accidents and not normal operations. MOX ER

Table D-7 lists source terms for isotopes released during normal operations, not from

accidents as listed in Appendix E, Table E.13. Uranium-238 was not listed in DCS 2002b

(App. E reference) as a component of the waste streams involved in potential accidents at

the Waste Solidification Building.

J.3.13.21 Comment: 93-011

Comment: It is not acceptable to sign off on the environmental impacts of construction of

the proposed MOX facility without a more detailed explanation of the impact of bull dozer

activity on this contaminated site. The movement of soil that is contaminated will have an

impact not only on workers, but also on those off site because particulates will be lofted into

the atmosphere. The DEIS states on page 4-8 that any doses to workers from such

contamination would be assessed. The DEIS does not describe who will make this

assessment of workers and why the assessment would not include the off-site public. 

Response: Although no contamination is expected, further sampling may be necessary

because samples were only taken down to a depth of 12 inches. Samples were not taken

at the depths required to sample both the entire extent of the spoils pile and the ground

underlying the spoils pile in areas which could be disturbed by construction activities. It

would be the responsibility of DCS and the Department of Energy to assess the risks from

movement of contaminated soil if any were to be found. Any assessment of risks would

necessarily include impacts to the off-site population.
Appendix J

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J.3.13.22 Comments: 101-002 

102-002

Comment: An 11% increase in the cumulative and collective dose to workers at the

Savannah River Site (SRS) as a result of the proposed MOX facility, the Pit Disassembly

and Conversion Facility (PDCF), and Waste Solidification Building (WSB) operations, is

alarming and significant.

Response: The contribution of the MOX program to the cumulative collective dose to SRS

workers was revised from 11.4% to 9.3% in Table 4.25 in Section 4.5.1.1 of the FEIS. As

discussed in Section 4.3.1.1.2, each of the workers at the PDCF and the WSB was

assumed to receive less than the SRS guideline maximum exposure (0.5 rem/yr). Due to

lack of operational data and a desire not to understate potential risks, the cumulative

collective dose to SRS workers was based on this maximum exposure which resulted in the

contribution of 9.3% by the PDCF, the proposed MOX facility, and the WSB. However, the

average SRS worker involved in radiological operations receives approximately 0.048

rem/yr as presented in Section 3.10.3. This average dose is ten times less than the allowed

maximum. Thus, the contribution of the proposed MOX facility (15 person-rem) with a more

realistic estimate (10% of maximum allowed) for the PDCF and WSB (1.97 + 0.5

person-rem) would contribute about 17.5 person-rem (rather than 257 person-rem) to a

revised annual site total of 2,572.5 person-rem, or about 0.7%.

J.3.13.23 Comment: 105-013 

Comment: DCS uses data from the MELOX plant in Marcoule, France to estimate worker

radiation dose at 0.009 latent cancer fatalities (LCF) per year. There is no way to confirm

this data, and people who oppose the proposed action have no means to substantiate their

claims. The 0.009 LCF per year estimate is not accurate, but opponents have been unfairly

denied the means to prove it.

Response: The annual latent cancer fatality rate for MOX facility workers of 0.009 is a

reasonable estimate for the 400 workers expected at the proposed MOX facility. If the

average annual dose per worker at the Savannah River Site of 0.048 person-rem is

assumed (see Section 3.10.3), an annual collective worker dose of 19.2 person-rem

(0.01 LCF) is the result. Such a result is very close to the value of 0.009 LCFs.

J.3.14 Accidents

J.3.14.1 Comments: 10-012

64-006

Comment: The Nuclear Regulatory Commission (NRC) concluded that there are minimal

risks to human health if plutonium fuel is produced at the Savannah River Site (SRS). It

was noted that this project represents a real and unacceptable risk, especially to workers. 
Appendix J

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The report states that “credible” accidents will be studied in either the EIS or the safety

evaluation report (SER). The DEIS should define the term “credible accident” and state

what the impacts are for “non-credible accidents.”

Response: The NRC does not evaluate the impacts of worst-case or non-credible

accidents in its NEPA analyses. Credible accidents evaluated in the EIS include those

caused by natural phenomena hazards and other possible process hazards. For NRClicensed fuel-fabrication facilities, the risk of credible high and intermediate consequence

events will be limited in accordance with 10 CFR Part 70. The principal structures, systems

and components relied upon to reduce these risks are evaluated in the SERs.

J.3.14.2 Comment: 19-006 

Comment: This DEIS estimated 400 deaths in the minority community based on computer

modeling and is now coming back to revise that to 50. Although modeling is a valid

technique for estimating the unknown, it must be based on realistic choices of variables and

not too many of them. The assumptions need to be justified. A lot more information is

needed about how the number were obtained.

Response: All assumptions and sources of data input into the computer models for

radiological impacts were provided in Appendix E, Section E.2 of the EIS.

J.3.14.3 Comment: 53-008

Comment: Concern was expressed with a tritium accident. It was stated that there is not a

list of the number of curies that are postulated to be released in an accident. Also, the

routine releases at the pit disassembly and conversion facility were not documented. Three

years ago it was about 1000 curies per year tritium being released. Concern was

expressed regarding the amount of tritium already released by the Savannah River Site.

Response: The amount of tritium postulated to be released in the Pit Disassembly and

Conversion Facility (PDCF) tritium accident was listed in Table E.13 in Appendix E. The

amount of tritium assumed to be released from normal operations at the PDCF was listed in

Table E.5 in Appendix E of the EIS.

J.3.14.4 Comment: 116-007

Comment: Concern was expressed about how to deal with natural phenomenon such as

an earthquake. It is not obvious that the worst-case earthquake would not devastate the

current MOX design. If principal system and structure components (PSSCs ) survive an

earthquake, non-PSSC equipment and structures might not survive and their destruction

could have an adverse impact on the PSSCs. The worst-case earthquake could also cause

explosions, spills, criticality accidents, fires, and leaks of radioactive material. The DEIS

should review this worst-case scenario.
Appendix J

J-80

Response: The NRC does not evaluate worst-case scenarios in its NEPA analyses. But in

developing its seismic safety design for the proposed MOX facility, DCS was required to

consider the most severe documented earthquake for the site (the 1886 Charleston

earthquake). Moreover, EIS Section 4.3.5.1.1 provides a bounding NEPA analysis for

potential events up to and including design basis accidents. DCS has committed to design

the proposed MOX facility to ensure PSSCs survive the design basis earthquake without

subsequently exceeding the dose limits set forth in the 10 CFR Part 70 performance

requirements.

J.3.14.5 Comment: 116-008

Comment: It was suggested that the postulated accidents should be evaluated in

conjunction with a hurricane, when the winds are fiercest. 

Response: As stated in Section 4.3.5.1.1 of the EIS, hurricanes were evaluated as the

cause of accidents but were found not to be capable of causing a release of radioactive

material to the environment. Most major operations at the Savannah River Site such as

MOX operations would be expected to be shutdown or suspended pending the approach of

a hurricane due to the potential disruption of electricity and supplies. Small environmental

impacts might be expected if an accident were to occur simultaneously with a hurricane, but

the winds associated with the hurricane would be capable of diluting any releases to the

point where no appreciable dose to receptors more than a few hundred meters downwind

would be expected.

J.3.14.6 Comment: 116-019

Comment: The DEIS should include the impact of the worst-case hydrogen explosion.

Response: The NRC does not evaluate worst-case scenarios in its NEPA analyses. As

discussed in Section 4.3.5.1.1, the EIS attempted to provide a comprehensive, bounding

analysis for all potential events up to and including design basis accidents. Impacts of the

hypothetical hydrogen explosion accident postulated at the proposed MOX facility were

given in Section 4.3.5.2.

J.3.14.7 Comment: 3-002

Comment: Concern was expressed regarding the impacts resulting from serious accidents

in the area surrounding the Savannah River Site and in the Savannah area. 

Response: Pursuant to the requirements of 10 CFR Part 70, the risk of credible high and

intermediate consequence events at the proposed MOX facility must be reduced to

acceptable levels before operation of the MOX facility would be authorized. As described in

the draft SER for construction, DCS has identified principal structures, systems and

components (PSSCs) to prevent or mitigate these events, and will maintain these PSSCs in

accordance with an approved quality assurance program. To reduce the risk of accidents at

the Waste Solidification Building and the Pit Disassembly and Conversion Facility, these
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proposed Department of Energy facilities would have to meet the requirements of

10 CFR 830 for facility nuclear safety, 10 CFR 835 for worker protection, and other DOE

orders and regulations.

J.3.14.8 Comments: 14-003 63-003 86-051

50-002 86-003 86-052

Comment: The risk to offsite population in the hypothetical accident analysis is significantly

overstated. In analyzing the impact to off-site population from a hypothetical tritium release

from the Pit Disassembly and Conversion Facility, the DEIS assumes and calculates a dose

by ingestion during the one-year post-accident period. This scenario is simply not possible.

An assumption that the South Carolina Department of Health and Environmental Control

and the Georgia Environmental Protection Division would ignore contamination of

agricultural products for one year is incredulous and an insult to their training, demonstrated

performance and professional status. This impossible assumption must be eliminated and

the analysis revised.

Response: In Section 4.3.5.2, the EIS discusses the possibility that the 1-year exposure

accident consequences would be lower if contaminated food was not eaten. It further

discusses the Food and Drug Administration protective action guides for interventions. A

new 1-year exposure scenario without consideration of crop ingestion has been added to

Section 4.3.5.2. The Nuclear Regulatory Commission recognizes that some interdiction

would likely occur following a significant accident, even if contamination levels were below

the protective action guides. Additional text has been added to clarify the reasonableness

of the assumption regarding interdiction. Many stakeholders wanted to know what could

happen if no interdiction of crops occurred. Therefore, the accident analysis also reports

the 1-year exposure including the ingestion pathway. The 1-year exposure scenario

including the ingestion pathway is provided as an upper bound estimate of the impacts of a

potential significant accident. It should be recognized that many factors would result in a

more realistic (lower) estimate of potential accident consequences. These include the

selection of the computer code (See Comment J.3.13.16), and conservatism used in

defining the potential accident scenario (See Comment J.3.13.9). However, for purposes of

the National Environmental Policy Act, staff included a more realistic estimate of the

impacts from potential accidents and an estimate that bounds the potential accident

consequences. 

J.3.14.9 Comments: 17-002 86-066 89-006

50-002 89-001 94-001

60-002 89-005

Comment: The DEIS has considered worst-case scenarios in the accident analysis. The

likelihood of these accidents is extremely remote and cannot be considered “reasonably

foreseeable” as required for a National Environmental Policy Act (NEPA) analysis. 

Furthermore, the assumptions made in performing the accident analysis were overly

conservative by orders of magnitudes, leading to unrealistically high human health impacts. 

These assumptions include the use of the GENII code for performing the analysis as well as
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ignoring engineered safety features or procedures such as permitting the ingestion of

contaminated food.

Response: The NRC does not evaluate worst-case scenarios in its NEPA analyses. As

discussed in Section 4.3.5.2, the EIS attempted to provide a comprehensive, bounding

analysis for potential events up to and including design basis accidents. All accidents were

taken from either the Surplus Plutonium Disposition EIS for the Pit Disassembly and

Conversion Facility (PDCF) accidents or the MOX ER for the proposed MOX facility and

Waste Solidification Building (WSB) accidents. No beyond design basis accidents for the

PDCF were considered and no such accidents were considered in the MOX ER. However,

the leak path factors for the MOX explosion and fire accidents were revised from 0.01 to

0.0001 to give more credit to the high-efficiency particulate air (HEPA) filters in reducing the

amount of radioactivity released to the environment in the analyses as reported in

Section 4.3.5.2. 

The EIS provides a conservative estimate of accident impacts and an independent review of

previous accident analyses performed for the proposed MOX facility, the PDCF, and the

WSB. Concerns have been expressed about the use of the GENII code for accidents and

the inclusion of ingestion doses in the impacts. As discussed in more detail in

Comment J.3.14.20, the conservative nature of the GENII accident dispersion model was

tempered by the use of direction-specific 95th percentile meteorology rather than

99.5th percentile as suggested by Nuclear Regulatory Commission Regulatory Guide 1.145. 

The rational for inclusion of ingestion doses in the impacts is discussed further in the

response to Comment J.3.14.8. 

Thus, the accident impacts presented in this EIS are conservative in nature. The accidents

are reasonably foreseeable and not overly conservative by orders of magnitude. Additional

text was added to Section 4.3.5.2 of the FEIS to discuss the uncertainties involved in the

assumptions and calculations. 

As discussed in Section 2.5, it is estimated that the construction and operation of the

proposed MOX facility would have small radiological impacts on, and risk to, human health. 

This finding is borne out by the low impacts assessed while using conservative

assumptions. 

J.3.14.10 Comments: 22-001

53-002

Comment: Concern was expressed with the use of hypothetical rather than real data for

accidents. It was stated that the DEIS should have used the facts from real radioactive

accidents instead of hypothetical accidents. It was suggested that these accidents affected

generations of Americans not just the generation living when the accident occurred. The

DEIS should explain why the only health consequence that was considered was latent

cancer fatalities.
Appendix J

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Response: The accidents evaluated were those considered to be reasonably foreseeable 

given the processes and procedures needed at the proposed MOX facility, the Pit

Disassembly and Conversion Facility (PDCF), and the Waste Solidification Building (WSB).

Data based on actual accidents does not exist for many of the potential hazards evaluated

in the EIS.

Genetic effects and the development of cancer are the primary health concerns attributed to

radiation exposure. Latent cancer fatalities (LCFs) are the radiological health effect end

point used in this EIS as a measure of human health impacts. Although radiation-induced

genetic effects have been observed in laboratory animals (given very high doses of

radiation), no evidence of genetic effects has been observed among the children born to

atomic bomb survivors from Hiroshima and Nagasaki. Thus, there is no basis for estimating

genetic effects in descendants of persons exposed to high doses of ionizing radiation. 

The extent to which low levels of radiation cause cancer is currently the subject of scientific

debate. The Nuclear Regulatory Commission (NRC) used conservative assumptions and

values to estimate potential LCFs from hypothetical accidents so as not to underestimate

potential impacts. Because statistical data on low level radiation exposure and from

previous accidents are inconclusive as to the inducement of cancer, the NRC’s assumptions

were based on extrapolation of data from exposure of humans to high levels of radiation,

much higher than members of the public would expect to receive if an accident occurred. 

J.3.14.11 Comment: 25-002

Comment: The DEIS, which included both the MOX plant and the Pit Disassembly and

Conversion Facility (PDCF), did not contain sufficient detail to allow an independent

assessment of their analyses. However, its worse-case incident, which occurred in PDCF,

not the MOX plant, seems grossly exaggerated. A fire in a modern plutonium cabinet or

glove box would be unlikely to generate either the heat or the releases of plutonium and

tritium that was assumed. Any plutonium in such a fire, if it occurred, would not dissipate to

the public. The assumption was made that the government would not collect the

contaminated food to keep it from being eaten was questioned. Surely this hypothetical

incident scenario is supposed to be at least remotely possible. This draft EIS needs

significant revision.

Response: The accident scenarios evaluated in the EIS are based on information in the

MOX ER and the DOE’s SPD EIS. This included a fire in a glovebox that released

plutonium and tritium. All accident release source terms and site-specific input data

necessary to perform an independent assessment were provided in Appendix E of the EIS. 

As stated in response to many of the above comments, the accidents considered were not

worst-case accidents. The response to Comment J.3.14 8 discusses why the food

ingestion pathway was included. 
Appendix J

J-84

J.3.14.12 Comments: 62-002

116-003

Comment: The DEIS states that credible or reasonably foreseeable accidents are

considered. Several past accidents that were previously considered “incredible” including

Three Mile Island #2 in 1979; Chernobyl in 1986, the N.Y. City Twin Towers in 1993 and

again in 2001 were provided as examples. The probability that these events would happen

in the manner in which they occurred (before they occurred) is very, very small. Yet, the

incredible happened. The DEIS should also consider “incredible” events and worst-case

accidents.

Response: Worst-case accidents and specific terrorist initiated events are not considered

to be reasonably foreseeable and are therefore not considered in this EIS.

J.3.14.13 Comment: 97-004

Comment: The analyses in the DEIS do not appear to address uncertainties - including

uncertainties in design, uncertainties and inaccuracies in models, uncertainties in input

parameters, and excluded or overlooked effects. In addition, the sensitivity of the results to

changes in assumptions and parameters is unclear. It is recommended that uncertainty and

sensitivity be addressed and included in the DEIS. 

Response: The analyses in the EIS are based on the best, current information available. If

significant changes in design or function are made, a future supplement to the EIS might be

required. Furthermore, conservative assumptions and input parameter values were used so

as not to underestimate risks.

J.3.14.14 Comments: 97-007 101-001

97-015 102-001

96-017

Comment: Concern was expressed regarding the computer codes that were used to

estimate radiological impacts, including errors miscalculating the number of deaths in low

income, African American communities as a result of a severe MOX accident. It is not clear

if the computer codes are endorsed by Nuclear Regulatory Commission (NRC) regulations

and/or guidance, and if they meet NRC quality assurance requirements, including

verification and validation for the specific site and application. Concern was also expressed

regarding the uncertainty of additional errors in the DEIS.

Response: The computer codes selected for performing the analysis have a proven track

record in accident analysis and National Environmental Policy Act compliance. The

accident input parameters and assumptions provided by DCS for the MOX facility and

Waste Solidification Building accidents as well as those for the Pit Disassembly and

Conversion Facility accidents from the Surplus Plutonium Disposition EIS have been

carefully scrutinized by the NRC as part of the licensing process for appropriateness and

modified if necessary. The preparation of the EIS followed applicable NRC guidance and
Appendix J

J-85

regulations. The NRC reviewed analyses performed by the contractor, Argonne National

Laboratory (ANL). ANL does have a quality assurance program that was followed in the

preparation of the DEIS. In addition, the NRC retained the Center for Nuclear Waste

Regulatory Analysis to review the DEIS prior to publication. A discussion of the quality

assurance associated with the GENII code is provided in the response to

Comment J.3.14.16. 

J.3.14.15 Comments: 64-006

 86-003

86-051

Comment: The bounding accident for the Mixed Oxide Fuel Fabrication Facility – an

explosion in an aqueous polishing cell – was not properly characterized. The discussion

provided in Section 4.3.5.2 and Table 4.12 fails to explain that the accident is prevented. 

See Draft Safety Evaluation Report on the Construction Authorization Request for the Mixed

Oxide Fuel Fabrication Facility (SER for construction) Table 10.1-3, footnote b. The DEIS

should clearly state that an explosion in an aqueous polishing cell is provided for illustrative

purposes because, pursuant to NRC’s own regulations, the design safety features, will

prevent such an accident. The Draft EIS further fosters a misimpression on the public by

postulating that, once this hypothetical accident occurs, neither DCS, the Department of

Energy, the Nuclear Regulatory Commission, nor the States of South Carolina or Georgia

would take any intervention to protect the public by removing contaminated food or soil. 

See Draft EIS page 4-36, lines 8-18. In fact, the document further assumes that

contaminated food is distributed outside the immediate vicinity of the Savannah River Site. 

See Draft EIS page 4-41 lines 25-3 8. These assumptions are inconsistent with the NRC

guidance to use “reasonably foreseeable” accident evaluations that are coordinated with the

SER for construction. The DEIS should state the probability associated with the various

accidents.

Response: The explosion event at the proposed MOX facility was characterized according

to information in the MOX ER and considered to be “highly unlikely” because of the design

features of the facility. However, as noted in Section 1.1.2, the EIS is broader in scope than

the SER and has a different focus. The EIS assumes that an accident will occur and

estimates potential impacts to human health and the environment from the accident. The

likelihood of accident consequences is evaluated in describing the risk associated with a

postulated accident. The FSER is concerned with documenting the NRC staff’s safety

findings of an applicant’s application. As discussed in Section 1.1.2, information in the

SER, that is not germane to environmental impacts, is not repeated in the EIS. Although

conservative assumptions were applied to the source term and release fraction, the event

would have been classified as “not credible” if the initiation of the event was totally out of the

realm of possibility. 

See Comment J.3.14.8 for the response to removing the ingestion pathway.
Appendix J

J-86

J.3.14.16 Comments: 86-053 89-007

86-066 94-001

89-002

Comment: The GENII code is not an appropriate model for estimating accident impacts to

the collective public. A number of conservative assumptions compounded lead to

excessively conservative results. Of major concern are 1) the use of the plume centerline

air concentrations for the entire sector being analyzed, which results in unrealistically high

impacts, and 2) the modeling of crop harvest immediately following an accidental release

leads to excessive impacts from the food ingestion pathway.

Response: The GENII code was selected in order for the Nuclear Regulatory Commission

(NRC) to perform an independent analysis of proposed MOX facility, Pit Disassembly and

Conversion Facility (PDCF), and Waste Solidification Building (WSB) accidents. MACCS2

had been previously used to perform analyses for the proposed MOX facility and PDCF.

These two codes were the only codes recommended for the DOE Safety Analysis Toolbox

in the area of radiological dispersion and consequence analysis (WSRC-MS-2001-00091).

The GENII code was developed under software quality assurance guidelines based on the

American Society of Mechanical Engineers Nuclear Quality Assurance-1 (ASME NQA-1)

standard. As with all accident analysis codes, both GENII and MACCS2 have been cited for

problems with software quality assurance (WSRC-MS-2002-00118) which was an additional

reason for using GENII as a peer-reviewed alternative to MACCS2. The error in the GENII

tritium accident module regarding the use of the food grid was identified by the NRC during

development of the EIS and a workaround developed in consultation with the code

developer. 

The GENII code has also been used in numerous previous environmental impacts

statements in the analysis of accident impacts (e.g., DOE/EIS-0161, Final Programmatic

Environmental Impact Statement for Tritium Supply and Recycling; DOE/EIS-0200-F, Final

Waste Management Programmatic Environmental Impact Statement for Managing

Treatment, Storage, and Disposal of Radioactive and Hazardous Waste; DOE/EIS-0269,

Programmatic Environmental Impact Statement for Alternative Strategies for the Long-Term

Management and Use of Depleted Uranium Hexafluoride; DOE/EIS-0277, Final

Environmental Impact Statement on Management of Certain Plutonium Residues and Scrub

Alloy Stored at the Rocky Flats Environmental Technology Site). 

Due to the conservativism inherent in the GENII accident population dose model, the

direction-specific 95th percentile impacts were assessed rather than the direction-specific

99.5th percentile as suggested in Regulatory Guide 1.145. The response to

Comment J.3.14.20 provides more information on this subject. In addition, it is not always

apparent when the results from MACCS2 are conservative. For example, the site-wide 95th

percentile result from the PDCF tritium accident from the Surplus Plutonium Disposition EIS

(DOE/EIS-0283) was 110 person-rem in the short-term. Use of later 1987 weather data

(worst-case for 1987 through 1996 as used in the MOX ER and in this EIS) in MACCS2 for

the same accident results in a dose of approximately 70 person-rem, a 40% difference. 
Appendix J

J-87

The accident analysis performed using GENII provided ingestion impacts for four different

times during the year designated as “winter,” “spring,” “summer,” and “autumn” by the code. 

These four seasons represent different stages in the growth cycle of crops potentially

affected over the course of a year by an accidental release of radioactive material. The

impacts for “autumn,” representative of conditions immediately prior to harvest, were

chosen for presentation in the DEIS. Such impacts were included to provide perspective on

what could happen without the interdiction of crops or if contaminant levels fell below

protective action guidelines. 

In summary, the NRC performed an independent accident analysis with a computer code

with an established track record in the area of accident analysis. Conservative assumptions

were used but not to the extent that the analysis could be considered overly conservative. 

J.3.14.17 Comment: 86-057

Comment: In Section 4.3.5.2 of the DEIS, the meteorological conditions for the proposed

MOX facility hypothetical explosion involves winds directed to the west-northwest. The

meteorological conditions for the Pit Disassembly and Conversion Facility hypothetical

tritium release involves winds directed to the southwest. It is not intuitively obvious why

both accident evaluations do not have the same meteorological conditions. 

Response: As discussed in Section 4.3.5.2 of the EIS, the inhalation pathway dominates

the short-term exposure. Thus, the west-northwest sector has the highest impacts because

of the larger number of people in that direction. For the 1-year exposure, the ingestion

pathway dominates. Because more crops are grown in the southwest, the highest impacts

were estimated for this direction despite any differences in meteorological conditions such

as stability frequency and wind speed and direction.

J.3.14.18 Comments: 89-003

89-007

Comment: The results reported in the DEIS errata sheets are not physically possible. The

predicted doses for the explosion scenario for the proposed MOX facility would seem to

require more plutonium to be ingested than would be released in the postulated accident. 

To result in the number of latent cancer fatalities attributed to the ingestion pathway, the

calculations strongly suggest that the offsite population would be required to ingest

contaminated food containing almost twice the amount of plutonium postulated by the

Nuclear Regulatory Commission to have been released by this accident. In addition, DOE’s

experience indicates that the realistic fraction of released contamination to be inhaled or

ingested is several orders of magnitude less than these numbers indicate.

Response: The results reported in the errata sheets are physically possible. The claims of

excessive conservatism are exaggerated in the comment. The internal dose conversion

factors (DCFs) for ingestion and inhalation used by GENII and the DCFs in Federal

Guidance Report 11 for ingestion and inhalation, are based on International Commission on
Appendix J

J-88

Radiological Protection (ICRP) Reports 30 and 48. The “worst case” solubility library as

defined in GENII documentation (results in maximum dose) in GENII was used in the EIS

accident analysis. If the entire amount of radioactive material released for the MOX

explosion event (as reported in Table E.13 in the errata sheets) was assumed to be

ingested, a 30,000 person-Sv dose would be expected using the worst case solubility values

from Federal Guidance Report (FGR) 11 for each radionuclide. The dose reported in

Table 4.14 of the EIS, 2,700 person-Sv, is 9% of the 30,000 person-Sv. Therefore, more

plutonium is released than ingested. 

Similarly, for inhalation, if all radioactive material released from the explosion was inhaled, a

population dose of 3,650,000 person-Sv would result. Thus, the estimated dose in

Table 4.14 of 910 person-Sv is only 0.025% of that expected if all of the material was

inhaled, not 0.23% as suggested in the comment. 

Much of the plutonium might settle to the ground prior to reaching 20 miles from the release

point. However, under 95th percentile meteorological conditions, the contaminant plume will

be more narrow and concentrated, resulting in higher concentrations downwind than for

other conditions. 

Finally, ingestion doses are routinely a small fraction of inhalation doses if the crop density

ratio to population density is low in the areas considered or if direct deposition on crops is

not considered. Neither condition applies to the analysis performed for this EIS. 

J.3.14.19 Comment: 98-008

Comment: The original DEIS included significant errors in the calculation of latent cancer

fatalities if there were an explosion at the proposed MOX facility – estimating nearly

400 deaths; the new calculations result in less fatalities, but we still consider 100 deaths to

be significant and important enough to warrant denying approval. 

Response: The calculation of 100 latent cancer fatalities (LCFs) involved the ingestion of

all food crops that were assumed to be contaminated immediately prior to harvest. Text

was added to Section 4.3.5.2 of the FEIS to explain the reasons for including the food

pathway in the collective population 1-year exposure impacts. Impacts for the collective

population 1-year exposure without ingestion have also been added to the impacts

presented in Section 4.3.5.2. 

One reason for inclusion of the ingestion dose was for perspective if interdiction of crops

was not implemented. Because the Nuclear Regulatory Commission does expect

interdiction to occur if potential crop contamination results from an accidental release, the

primary focus is on the short-term exposures, which do not include ingestion, presented in

Section 4.3.5.2 and in Table 2.1 in Section 2.4 of the EIS. The maximum short-term

collective population exposure, assuming the accident occurs, results in approximately

3 LCFs. This estimate is the result of using conservative assumptions and represents small

doses to all individuals in a large population. Moreover, the LCF estimate is a consequence

of an accident with a very low probability.
Appendix J

J-89

J.3.14.20 Comments: 86-054

86-055

89-004

Comment: The use of the GENII computer code to calculate Chi/Q values in the DEIS for a

single specific direction, without consideration of any other directions, will not produce a

site-representative 95th percentile Chi/Q. Despite statements that population impacts in the

DEIS are based on meteorological conditions at the 95th percentile, they may actually be

based on conditions at the 99 to 99.5th percentile, leading to overly conservative collective

dose impacts.

Response: The collective dose results from GENII are not overly conservative. For

accident analyses, the Nuclear Regulatory Commission (NRC) accepts the maximum sector

air concentration value or the overall site 95th percentile value, whichever is larger

(Regulatory Guide 1.145). For this EIS, staff used the maximum sector value rather than

the overall site 95th percentile value as discussed in the comment. The maximum sector air

concentration value is determined by evaluating the impact in each of the 16 sectors. Using

the guidance of Regulatory Guide 1.145, the 99.5th percentile value would be determined

and the largest value for the 16 sectors selected. Because of the conservative nature of the

assumptions used in the accident analysis, the maximum sector results were determined

using the 95th percentile concentration values using GENII rather than the 99.5th percentile

values. Use of the 99.5th percentile values would have resulted in larger estimated

exposures that would have been overly conservative. Maximum short-term impacts were

found to be to the WNW of the SRS, because that sector has the largest off-site population

density. Maximum long-term exposures that included the ingestion pathway were found to

be primarily to the SW of the SRS because that sector contains the the largest amount of

crops in the area. Thus, accident impacts were assessed for all directions from the SRS. 

For each case, the impacts reported were for the sector with the largest impacts as

suggested by NRC guidance.

J.3.14.21 Comment: 105-015

Comment: Plutonium is not the same as uranium. No mention in this DEIS is made for

control of humidity, despite plutonium being much more reactive in a humid environment. 

Plutonium metal is also a concern in the Pit Disassembly and Conversion Facility (PDCF). 

From 6-1.3 of the Plutonium Handbook, “When a container is opened spontaneous ignition

may then occur, usually resulting in destruction of the container and the scattering of

metallic oxide (Pu) through the glove box train and the exhaust system.” The DEIS mentions

no precautions to prevent this. 

Response: Spontaneous ignition of plutonium (and alloys) requires plutonium to be in the

form of metal turnings or powder that have higher surface areas than monolithic pieces

(such as the plutonium pits). Spontaneous ignition is a result of the plutonium metal

reacting with oxygen and/or water in the air to form an oxide. Neither the PDCF or the

proposed MOX facility is expected to handle metal plutonium in powder form. The

plutonium pits that the PDCF is expected to receive are in a bulk metal form. The proposed
Appendix J

J-90

MOX facility will handle plutonium in the oxide form that does not have the potential for

spontaneous ignition.

J.3.14.22 Comment: 116-015

Comment: For airborne releases of radiation, in an accident, the maximally exposed

individual (MEI) is at the north Savannah River Site (SRS) boundary. Yet the 1 year

maximum dose is at the SSW boundary. It is not apparent why this is the case. For most

of the year there are no prevailing winds at the SRS. It appears there is no real “safe”

direction to evacuate to in the event of an accident.

Response: For accident releases, the MEI is located to the north-west of the proposed

facilities. As discussed in Section 4.3.5.2 of the EIS, the MEI is a hypothetical person who

is assumed to be located at the SRS and could receive the highest possible dose of

radiation or of a hazardous chemical from a given event or process. Because the site

boundary is closest to the proposed MOX facility on the north-west side of the SRS, as

shown in Appendix E (Table E.11 in the DEIS), the MEI is located to the north-west. The

maximum dose to the SSW is a 1-year collective population dose. It considers several

pathways of exposure including direct radiation, inhalation and ingestion. The SSW sector

has the highest crop production. As discussed in Section 4.3.5.2 of the EIS, the 1-year

exposure estimate assumes that all the contaminated crops are eaten. For this sector,

more crops are produced than could be eaten by the people living there. Therefore, it is

assumed that the crops are eaten by others, and the exposure to those people is included in

the 1-year exposure estimate for the SSW sector. 

As discussed in Section 4.3.5 of the EIS, impacts from accidents would depend on the wind

direction and speed following a hypothetical accident. Figure 3.5 presents the annual wind

rose for the SRS. The prevailing wind directions are W to S and NNE to ENE. The least

prevalent wind direction is to the N and NW. The SRS emergency response plan takes into

account the prevailing wind direction at the time of an accident. 

J.3.14.23 Comment: 86-122 

Comment: The GENII code is not an appropriate model for estimating accident impacts to

the collective public. A number of conservative assumptions compounded lead to

excessively conservative results. Of major concern are 1) the use of the plume centerline

air concentrations for the entire sector being analyzed which results in unrealistically high

impacts, and 2) the modeling of crop harvest immediately following an accidental release

leads to excessive impacts from the food ingestion pathway.

Response: The comment specifically references text in Section E.2.1.3 in Appendix E.

However, the discussion in Section E.2.1.3 discusses the use of the GENII code for normal

operations, not accident conditions. It is the same code used by DCS in their MOX ER for

assessing the risks from normal operations. The statements made in the comment do not

apply to the use of GENII for normal operations. A discussion on the appropriateness of

using GENII for accident analyses is presented in the response to Comment J.3.14.16.
Appendix J

J-91

J.3.14.24 Comment: 86-124

Comment: Table E.12 indicates that the Nuclear Regulatory Commission (NRC) used a

leak path factor of 0.01 for the internal fire and explosion events (See Section J.2.1.3 of the

EIS). DCS used a leak path factor of 0.0001 for these events. DCS is currently discussing

with the NRC safety analysis staff the appropriate leak path factor to use. If the NRC staff

ultimately agrees to a leak path factor of 0.0001, DCS assumes the EIS staff will reevaluate

the accident scenarios with this new leak path factor. 

Response: The NRC has accepted the leak path factor of 0.0001 for the MOX internal fire

and explosion events. The input data presented in Section E.2.2.1 in Appendix E and the

accident impacts as presented in Section 4.3.5.2 have been revised to incorporate the

change.

J.3.14.25 Comment: 97-011

Comment: The basis for uranium dioxide release estimates in Table 4.16 of the DEIS

needs to be explained. The Nuclear Regulatory Commission (NRC) staff’s Safety

Evaluation Report of April 2002 identified this as an open issue and implied higher potential

concentrations. 

Response: In Section 8.1.2.3.3 of the April 2003 draft SER, the NRC staff evaluated the

DCS’s proposal for safe storage of uranium dioxide and found it acceptable. The NRC

reviewed the risk of this event, and, as shown in Table 4.16 of the EIS, considers this a low

risk event.

J.3.15 Air Quality

J.3.15.1 Comments: 8-003 89-010

86-021 89-011

86-031

Comment: The proposed MOX facility will result in exceeding the air quality limits at the

Savannah River Site (SRS). The legality of the SRS exceeding the PM2.5 standard was

questioned. Also, in Table 2.1, it should be made clear that the PM2.5 is a 24-hour limit and

should not be compared to the annual standard.

The definition of ‘vicinity of SRS’ and the resulting selection of South Carolina Department

of Health and Environmental Control (SCDHEC) monitoring stations to characterize the

existing ambient air quality in Table 3.3 appears arbitrary and cannot support subsequent

statements regarding air quality compliance. Data in Table 3.3 suggest that local air quality

is not in compliance with the 24-hour and annual standards for PM10 and PM2.5. Most of

these noncompliant data are from the Cayce monitor located over 40 miles from the

proposed MOX facility which is classified as “commercial, urban-city center.” In contrast

PM10 monitors near the SRS boundary in more rural Jackson and Barnwell locations report
Appendix J

J-92

PM10 values in compliance. Table 3.3 also lists a value of 71 micrograms per cubic meter

from a rural monitor in Colleton County over 60 miles from SRS. This value was the

absolute maximum for 2001, but the 98th percentile value should be used to evaluate

compliance which was 27 micrograms per cubic meter for this monitor. Data for annual

PM2.5 in Table 3.3 is again from Cayce and exceeds the standard. In contrast, the Colleton

monitor saw an annual average below the PM2.5 standard.

As part of the discussion of environmental consequences in Chapter 4, Tables 4.6 and 4.8

use a more reasonable set of data for the existing ‘background’ air quality except for the

PM2.5 annual average. Again, the Cayce data are used to support the unwarranted

conclusion (page 4-1, lines 28-31, and page 4-18, lines 30-32 of the DEIS) that ‘measured

values in the vicinity of SRS already exceed the annual standard.’ This conclusion is

repeated several times in Section 4.7.

The DEIS should be revised throughout to present conclusions regarding PM2.5 that are

based on more representative data. In addition, Tables 3.3 and Tables 4.6 and 4.8 and

pages 3-22, 3-23, 4-11, 4-16 through 4-22, 4-89, and 4-90 should be revised to present

consistent and more representative information where possible.

Response: The air quality data presented in Chapters 3 and 4 of the EIS are used for

different purposes. Chapter 3 presents measured data chosen to establish the baseline the

air quality conditions in the area around the SRS site. The data in Chapter 4 are chosen to

estimate the background levels for use in modeling impacts of the proposed action. The

data provided in the air quality section is not intended to demonstrate compliance with air

quality standards. The air quality impacts assessment compares modeled air

concentrations of air pollutants with EPA and SCDHEC standards as a measure of the

magnitude of the potential impact. Under NEPA regulations, it is generally recognized that

comparison with regulatory standards is not sufficient to demonstrate the absence of

adverse impacts, because many criteria are considered in establishing regulations. In

addition, a direct comparison of measured levels of the criteria pollutants with those

specified in the standards do not necessarily constitute standards violations. 

The data in Chapter 3 presents air concentrations from monitoring stations around the

region. To reduce any problems associated with the choice of monitoring stations from the

surrounding counties, Chapter 3 and Table 3.3 of the FEIS have been changed to use

monitoring stations within 80 km (50 mi) of the proposed MOX facility site. This change

eliminates the Cayce and Irmo sites from those presented in the DEIS. To provide a more

comprehensive picture of air quality, both the minimum and maximum measured

concentrations have been presented in Table 3.3. 

As the comment noted, Table 3.3 might be interpreted as indicating that there are standard

violations. As discussed above, the data provided in the air quality section is not intended

to demonstrate compliance with air quality standards. The concentrations presented in

Table 3.3 have been changed to be more in line with that of the corresponding standard.

(For example, the 24-hr PM2.5 maximum and minimum are now 98th percentile values.) In

addition, attainment of the annual PM2.5 standard requires a 3-year average of annual
Appendix J

J-93

values. The PM2.5 standard has not yet been implemented and official determination of

compliance with this standard has not been made. Construction and operation of the

proposed facilities would increase PM2.5 levels by small amounts (<0.1% of the standard value).

Except for PM2.5, all the background values used in Chapter 4, came from SCDHEC’s

modeling summary for the SRS. As the comment noted, the Cayce monitor is not an

appropriate choice for PM2.5 background for use in the impact analysis in Chapter 4. A

closer look at the Cayce monitor showed that it is a source-oriented, special-purpose

monitor and hence not appropriate for presenting a general picture of air quality or for

picking a background. PM2.5 background levels were reassessed using monitors

designated by the state as background sites. New values were chosen as the maximum

concentrations measured in 2001 at the two rural background sites within 80 km (50 mi) of

the MOX facility site. These values are 13.6 μg/m3

 annual average and 27 μg/m3 24-hr

98th percentile value. Tables 4.6 and 4.8 and the associated discussion in the FEIS have

been updated using these values.

J.3.15.2 Comment: 47-004

Comment: The DEIS indicates that air flow is in a northeasterly direction. However, air

flow data, from air quality monitoring systems, was gathered from the northwestern section

of the Savannah River Site (SRS). It was questioned whether this was appropriate because

the air would not be affected by the proposed MOX facility.

Response: The SRS has an air quality monitoring system that is used to verify air effluents

are acceptable. This air quality monitoring system gathers data from all around the SRS. 

The data referred to in the comment is used for a different purpose than air quality

monitoring. The purpose of the wind data is to characterize the air flow in the vicinity of the

proposed MOX facility site. For modeling purposes, air flow data from the closest available

meteorological station is typically used for assessment purposes. Given the proximity of

H-Area to the proposed MOX facility site and the absence of significant terrain features,

data from the H-Area meteorological station is considered adequate to characterize winds

at the proposed site. 

J.3.15.3 Comment: 86-042

Comment: In Section 4.3.2.2, page 4-23, line 9 of the DEIS, the discussion omits NO2.

The sentence should read: “. . .increments for SO2, PM10 and NO2.”

Response: The text in the FEIS has been changed as suggested.
Appendix J

J-94

J.3.15.4 Comments: 19-007

56-004

Comment: Concern was expressed that the weather data used in the DEIS only covers a

five year period. It was felt that this short period of time would not take into account some

special South Carolina background. For example, it would not take into account effects of

hurricanes such as Hurricane Hugo. It was suggested that the EIS consider a more

expansive data set to cover weather patterns that have occurred in the Savannah River Site

area and in South Carolina.

Response: Five years of data are frequently used to provide an overall picture of wind

speed and direction. EIS Figure 3.5 presents such data. Five years of data are also

suggested by the U.S. Environmental Protection Agency as the basis for dispersion

modeling. Thus, the data set used is deemed adequate.

The time period for presenting extreme events such as hurricanes is longer because such

events occur infrequently . Section 3.4.1 of the DEIS discussed tropical storms and

hurricanes using data from 1700 to 1989. This has been supplemented with data for

17 storms from 1886 to the present.

J.3.15.5 Comments: 53-009

53-012

Comment: It was questioned whether the DEIS evaluated air quality impacts using actual

air emission data from existing Savannah River Site (SRS) facilities or air emissions based

on permit limits for those facilities. The consolidated incinerator facility is not currently

operating. When this facility is operational, air emissions will be higher than reported in the

DEIS. The DEIS should include emissions from the consolidated incinerator facility.

Response: As noted in Section 4.3.2, the air quality analysis adds the incremental impacts

caused by the proposed MOX facility to the impacts of other sources. The impacts of other

sources were taken into account by adding a maximum impact due to SRS sources and a

background concentration representing the impact of non-SRS sources. The SRS maxima

(See table 4.8) assume that all permitted sources, including the Consolidated Incineration

Facility, operate at their permitted levels.

J.3.15.6 Comment: 86-126

Comment: In Section F.2.2, page F-7, line 11 of the DEIS, the sentence should be revised

to read: “Engine-specific emission factors were not available for criteria pollutants.” 

Response: Vendor factors were provided by DCS for the emergency generators. The text

in the FEIS has been revised to reflect that vendor factors were used.
Appendix J

J-95

J.3.15.7 Comment: 107-001

Comment: The DEIS states that transuranic (TRU) and low-level radioactive wastes (LLW)

will be generated during operation of the proposed facility. Exhausts from the proposed

facility will be treated to remove radioactive materials before the exhaust is discharged to

the atmosphere. Please provide further information in the FEIS regarding frequency and

duration of air quality monitoring measures and monitoring of the facility’s emissions to the

atmosphere.

Response: DCS discusses air effluent monitoring in Section 10.2.1 of the Construction

Authorization Request. DCS notes that airborne releases are controlled by the building and

glovebox ventilation systems, process effluent offgas system, and stack high-efficiency

particulate air (HEPA) filters. DCS states that two redundant continuous air monitors and

two fixed airborne particulate samplers will monitor the stack effluents. In its later

application for a license to possess and use special nuclear material, DCS has committed to

providing (1) a description of the sampling, collection, and analysis procedures; (2) a

description of the proposed action levels and actions to be taken when action levels are

exceeded; and (3) a description of the recording and reporting procedures. As discussed in

Chapter 10 of the draft safety evaluation report for construction, the NRC has found this

acceptable for purposes of the construction authorization.

J.3.16 Hydrology

J.3.16.1 Comments: 7-004 43-001 99-003

10-018 98-007 101-003 

Comment: Currently, the Savannah River Site (SRS) requires enormous amounts of

surface and ground water, in the tens of billions of gallons, just to support currently

established operations. The DEIS does not clearly account for how much ground and

surface waters will be used additionally by the proposed MOX facility versus the proposed

no-action alternatives, including immobilization. Concern was expressed about maintaining

the aquifers beneath the SRS. 

The DEIS states that groundwater beneath the site is listed as a Class II drinking source by

the Environmental Protection Agency, meaning it has potential for existing and future

drinking water needs. It later states that contamination is present beneath the entire site. 

This should be clarified in the DEIS.

Response: Water use for the proposed action at the SRS is discussed in Section 4.3.3. 

Construction of the MOX building, the Pit Disassembly and Conversion Facility (PDCF), and

the Waste Solidification Building (WSB) would require 139 million L/yr (37 million

gallons/yr); operation of the MOX building would require 9.1 million L/yr (2.4 million gal/yr),

the PDCF would require 48 million L/yr (12.7 million gal/yr), and the WSB would require

19 million L/yr (5 million gal./yr). These volumes are much less (about 0.1% and 0.05%,

respectively) of the total water use at the SRS mentioned in Table 4.2. All of this water
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would be obtained from wells; no surface water would be used (Sections 4.3.1.3.2 and

4.3.2.3.2). 

Although the percentage of water needed for constructing and operating the proposed MOX

facility is small compared to total water use at the SRS, actual impacts to the groundwater

system were more conservatively evaluated for this EIS by comparing the predicted water

use to total water use for the A-Area loop and the groundwater capacity for the A-Area loop

wells. The evaluations made in this EIS were made using these values because

groundwater for constructing and operating the MOX facility would be obtained from a

combination of wells in the F Area and A-Area (i.e., the A-Area loop). 

Groundwater beneath the SRS is classified as Class II waters (i.e., a current and potential

source of drinking water). However, about 10% of the water beneath the site is known to be

contaminated. No direct releases of contaminants to the aquifer would occur during

construction or operation of the MOX facility (Section 4.3.3.2.1). No accident scenarios

have been identified that would directly or indirectly release plutonium to the groundwater. 

Thus, no changes to groundwater quality would be expected as the result of allowing the

proposed MOX facility to operate.

J.3.16.2 Comment: 27-003

Comment: Discharge information, including permitted and streamflow discharges, should

be described with the same units of measure as those for stream discharge. The use of

standard units of measure reduces confusion and facilitates comparison of values. For

example, using the same unit of measure to describe the magnitude of the Savannah River

Site (SRS) contribution to total streamflow in the two paragraphs above lines 39 and 40 on

page 3-9 of the DEIS would facilitate comparison. A standard unit of measure format

should be used throughout the document, such as describing discharge in millions of

gallons per day (MGD), cubic feet per second (cfs), or cubic meters per day (m3

/s). Options

include either following the standard unit of measure with equivalent measures in alternate

units in parentheses in the text, or adding an appendix with conversion tables, comparative

table, or equations to facilitate reader comparison between and among units of measure. 

The standard unit of measure format should be consistently applied for linear distances,

area, volume, and discharges. 

Response: In EIS Section 3.3.1, discharge for the National Pollutant Discharge Elimination

System (NPDES) permits has been changed to the same units as those used for reporting

flows in Upper Three Runs Creek. Permitted outfall F2, therefore, is 0.0048 m3

/s (0.17 cfs)

and permitted outfall F5 has a flow of 0.0013 m3

/s (0.046 cfs). 

J.3.16.3 Comment: 27-005

Comment: The description of aquifers in Section 3.3.2 of the DEIS should be expanded to

include aquifer properties, such as lithology, horizontal and vertical transmissivity, and

storage. This information would allow estimating the extent and timing of potential
Appendix J

J-97

groundwater contamination that could travel and impact nearby rural or municipal

groundwater users. 

Response: For the proposed action, there would be no discharges to groundwater during

construction or operation of the proposed MOX facility, Pit Disassembly and Conversion

Facility, and Waste Solidification Building, and there have been no accident scenarios

postulated that would release plutonium to the groundwater system. Because there would

be no direct discharges to groundwater, there would be no impacts to nearby municipal or

rural groundwater users. Indirect impacts to groundwater could occur during construction

and operation activities. These indirect impacts would be derived from surface spills and

subsequent mobilization by precipitation and infiltration of treated wastewater that would be

released to nearby surface water under appropriate surface water discharge guidelines. 

The impacts of these releases are expected to be small, based on adherence to best

management practices and prescribed surface release guidelines. Because there would be

no direct impacts to groundwater, and because indirect impacts would be small, including

detailed information on aquifer properties, such as lithology, horizontal and vertical

transmissivity, and storage, is deemed not to be necessary for this EIS. See

Comment J.3.16.6 for more information on aquifer properties and groundwater

contamination.

J.3.16.4 Comment: 27-006

Comment: The description of groundwater flow in F-Area provided in Section 3.3.2 of the

DEIS is incomplete. As written, the description is inadequate for estimating the likelihood of

potential contamination of underlying aquifers from the surface. Groundwater flows from

areas of recharge to areas of discharge; the report describes lateral flow direction and

identifies discharge areas but does not mention recharge areas or recharge rates. If the

F-Area is located on a groundwater divide and the top of the aquifer begins as close as

3 feet below land surface as described elsewhere in this section, it is probable that the

proposed MOX facility, the Pit Disassembly and Conversion Facility (PDCF), and the Waste

Solidification Building (WSB) are located in a recharge area. 

Surface contamination or spills occurring in a recharge area can easily be introduced into a

shallow aquifer, as indicated by the existence of contaminated groundwater from past

operations in F-Area (pages 3-11 through 3-13 of the DEIS). This section should be

expanded to provide information about recharge rates and location of recharge areas in

F-Area. 

Response: Text has been added to Section 3.3.2 that states that F-Area is in a region of

groundwater recharge from precipitation. Text has also been added to state that the

average recharge to the Upper Three Runs Aquifer is 35.6 cm (14 inches) per year. 

Text in Section 3.3.2 has been changed to give more local analysis of the depth to

groundwater at the location of the proposed MOX facility. Assuming 12.2 meters (40 ft) for

excavation, the shallowest depth to groundwater would be about 11 meters (36 ft). For
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J-98

these conditions, surficial spills would have little possibility for adversely affecting the

underlying groundwater, as discussed in Sections 4.4.3.3.2.1 and 4.3.3.2.2.

J.3.16.5 Comment: 27-007

Comment: The discussions in Section 3.3.2 of the DEIS indicate that the Upper Three

Runs Creek Aquifer is divided into two zones by the Tan Clay Confining Unit of the Dry

Branch Formation. The two zones and the Tan Clay Confining Unit, however, are not

depicted in Figure 3.4, “Underground Aquifers at the SRS.” Without this information, it is

not possible to visualize and understand the groundwater-flow system that underlies the

proposed MOX facility. Specifically, it is not clear how the two aquifer zones and the Tan

Clay Confining Unit within the Upper Three Runs Aquifer relate to the land-surface

topography (outcrop areas), the Gordon Confining Unit, the Gordon Aquifer, and the Steed

Pond Aquifer. Figure 3.4 should be redrawn or modified to reflect the text. 

Additionally, the discussion regarding the occurrence of a water table in the lower aquifer

zone beneath the Tan Clay Confining Unit is confusing. It raises the question whether there

is a water table in the upper aquifer zone. Subsection 3.3.2 should be rewritten to eliminate

the vague and incomplete description of the groundwater system underlying the proposed

MOX facility in F-Area. 

The text appears to refer to the Upper Three Runs Creek Aquifer and the Upper Three

Runs Aquifer interchangeably. This is confusing and should be clarified. If the two names

refer to a single geologic unit, then only one term should be used throughout the DEIS for

consistency. 

Response: Figure 3.4 is a generalized diagram of the groundwater system for the entire

Savannah River Site (NW to SE transect). The figure is provided for general, not specific,

information. The width of the figure, as shown at the top, is 70 miles. At this scale, F-Area

and the location of the proposed MOX facility are not readily distinguishable and accurately

splitting the Upper Three Runs Aquifer into two zones is not possible. 

The text in EIS Section 3.3.2 discusses groundwater conditions beneath the location for the

proposed MOX facility. The text states that the water table occurs in the lower aquifer unit

beneath the Tan Clay. This occurs because, as stated in the text, the topography drops off

sharply to the deeply incised Upper Three Runs Creek to the north (approximately

36.3 meters (120 ft) of incision) where the Upper Three Runs Aquifer discharges. 

All references to “Upper Three Runs Creek Aquifer” were replaced with “Upper Three Runs

Aquifer” as suggested in the comment.

J.3.16.6 Comment: 27-008

Comment: Section 3.3.2, page 3-13 of the DEIS indicates that groundwater in the Upper

Three Runs Aquifer beneath the proposed MOX facility is contaminated with various heavy

industrial and nuclear contaminants. Moreover, recent sampling indicates that groundwater
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contamination is absent above the Tan Clay Confining Unit but is present in the lower

aquifer zone beneath the confining unit. The discussion and analysis, as currently written,

are inadequate for an assessment of the potential for additional contamination at the site

relative to the contamination that already exists there, the spatial distribution of

contaminated zones in the underlying aquifer, and the potential direction of groundwater

movement and contribution to base flow in tributaries to the Savanna River near the F-Area. 

We recommend improving the discussion to support this assessment. An adequate

discussion should (1) explain why the upper aquifer zone is not contaminated, (2) identify

the locations of the wells recently sampled for groundwater contamination at the MOX site,

(3) identify the locations of sources that may have contaminated the lower aquifer zone, and

(4) explain how the topography and surficial geology of the MOX site relates to the outcrops

of the upper and lower aquifer zones. 

Response: As discussed in Section 3.3.2, the direction of groundwater flow in the Upper

Three Runs Aquifer is primarily to the north toward Upper Three Runs Creek, where it

discharges. Contamination does not occur above the Tan Clay layer in this area because

the groundwater table lies below the clay (the topography drops off sharply toward Upper

Three Runs Creek as stated in the text, and the lower aquifer unit is near or outcrops at the

base level of the creek). For clarity, reference to the Tan Clay confining layer was deleted. 

A description of the existing groundwater contamination is also provided in Section 3.3.2.

Contaminants of concern include gross alpha and beta activity, tritium, uranium, and

trichloroethylene (TCE). These results are based on sampling 9 wells in the proposed

location for the MOX facility. Text was added to Section 3.3.2 to state that 9 wells evenly

distributed across the site were included in the sampling. Their specific locations, however,

are not crucial to the argument presented. 

New text was also added to state that the contaminant plume appears to originate inside the

F-Area fence and is related to F-Area nuclear operations and waste management practices

at the Old F-Area Seepage Basin (OFASB).

Additional details on hydrogeological properties, such as lithology, horizontal and vertical

transmissivity, storage coefficient, effective porosity, and contaminant-specific distribution

coefficients needed to perform independent assessments for contaminant transport are not

included in this EIS because there would be no direct discharges to groundwater during

construction or operation of the proposed MOX facility and there have been no accident

scenarios postulated that would release plutonium to the groundwater system. Indirect

releases to groundwater derived from surface spills and subsequent mobilization by

precipitation could occur during construction and operation of the MOX facility. The impacts

of these spills are expected to be small based on adherence to best management practices. 

J.3.16.7 Comment: 27-010

Comment: Without further information in Section 4.3 about groundwater recharge and flow

paths, there is insufficient information to determine whether all or any contaminants in a
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hypothetical spill would be captured by base flow contributed to the Upper Three Runs

Creek, or whether some could pass in groundwater that flows under the creek and

continues downgradient. The DEIS should provide sufficient information to distinguish

between these possibilities. The DEIS should also provide information on the ultimate fate

of a hypothetical spill that is wholly or partly intercepted by the creek. We suggest that the

DEIS provide information on processes that affect the transport and fate of these potential

contaminants in the environment, for example, some forms of plutonium would be likely to

sorb onto clay particles in subsurface materials or streambed sediments rather than travel

with the water. 

Response: The average recharge rate from precipitation for the Upper Three Runs Aquifer

in the vicinity of the proposed MOX facility is 35.6 cm (14 inches) per year (WSRC 1997).

This information was added to Section 3.3.2.

As discussed in Section 3.3.2, groundwater in the vicinity of the proposed MOX facility flows

to the north toward the deeply incised Upper Three Runs Creek, where it discharges. On

the basis of site topography, it is unlikely that water would underpass the Upper Three Runs

Creek to any great extent because groundwater north of the creek is expected to flow to the

south and discharge to the creek. Because the possibility of underpass is very unlikely, no

additional text is required. 

Because no accidents have been identified that would release plutonium to the groundwater

and no direct or indirect releases of plutonium are planned, no additional discussion on its

fate and transport following discharge to surface water is required. 

Other surficial spills (e.g., oil) would have very little adverse impact on groundwater and

even less impact on surface water following mixing and dilution and adherence to good

engineering practices that would limit its initial mobilization and transport. Because the

concentrations in groundwater derived from a typical industrial surficial spill would be very

small and highly localized, there is no need to discuss the fate and transport of such

material in tertiary receiving waters. 

J.3.16.8 Comment: 43-005

Comment: The groundwater geology in this area is susceptible to variable conditions that

are site-specific and cannot be accurately predicted. The consequences for those factors

need to be taken into account in evaluating risk. 

Response: Groundwater hydrology for the SRS and the F-Area are described in

Section 3.3.2. Although groundwater hydraulic parameters are variable at the Savannah

River Site and in the vicinity of F-Area, impacts of construction and operation on

groundwater can be predicted with sufficient accuracy to ensure human and environmental

safety (Sections 4.3.3.2.1 and 4.3.3.2.2) because there would be no direct releases to the

groundwater. For such a situation, there would be no direct impacts. Indirect impacts to

groundwater quality could also occur due to surficial spills. While precise pathlines and

concentrations are difficult to predict accurately, their impacts are expected to be small
Appendix J

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based on adherence to best management practices that would limit the quantity of

contaminants reaching the groundwater system. 

J.3.16.9 Comment: 86-027

Comment: The MOX ER Rev 2 discusses more recent subsurface analyses presented in

WSRC 2002, Work Task Authorization 06: Summary of Groundwater Quality of the Mixed

Oxide Fuel Fabrication Facility Site. A copy of this document was provided to the NRC with

the references for the MOX ER Revision l & 2. The DEIS does not appear to account for

this information. It is suggested that the last two sentences on page 3-12, lines 36-40 of the

DEIS be deleted, and “Contaminated groundwater also exists beneath the Old F-Area

Seepage Basin (OFASB)” be inserted at the beginning of the next paragraph.

Response: The text in Section 3.3.2 was changed to state that the source of groundwater

contamination is from various heavy industrial and nuclear operations over the past

50 years in the F-Area. The contaminants plume appears to originate inside F Area and

extend beneath the proposed MOX facility site with movement in a fan-like direction of

groundwater flow under the proposed MOX facility site. Text was also added to state that

contaminated groundwater also exists beneath the Old F-Area Seepage Basin.

J.3.16.10 Comment: 86-028

Comment: It is suggested that the text on page 3-12, lines 40-45 of the DEIS be changed

to read: “The OFASB is located about 180 m (600 ft) north of F-Area, immediately adjacent

to the western boundary of the MOX site. The OFASB has been remediated by filling the

basin with clean soil, capping, and stabilizing the contaminated soil within the basin with

grout (WSRC 1997a). Groundwater contaminants of concern at the OFASB include iodine129, nitrate, strontium-90, tritium, and total uranium. Contaminants of interest include lead,

radium-226, and radium-228. A small component of the contaminant plume from OFASB

flows beneath the westernmost corner of the proposed MOX site. Groundwater is

monitored on a regular basis with 15 wells. Contaminant fate and transport models predict

that the aquifer is expected to return to an uncontaminated state (i.e., a condition in which

no maximum contaminant levels are exceeded) within 2 to 115 years, depending on the

specific contaminant.”

Response: The text in Section 3.3.2 was revised as suggested in the comment.

J.3.16.11 Comment: 86-029

Comment: It is suggested that the first sentence on page 3-13, lines 1-5 of the DEIS be

deleted. Change the next sentence to read: “The results of recent sampling in the

compliance wells for the OFASB indicated that concentrations of several target constituents

were above drinking water standards in several wells.” 

Response: The text in Section 3.3.2 was revised as suggested in the comment.
Appendix J

J-102

J.3.16.12 Comment: 86-030

Comment: It is suggested that the paragraph on page 3-13, lines 6-8 of the DEIS be

appended with the following text: “There is, however, some uncertainty about whether

these exceedances are related entirely to OFASB, to upgradient F-Area facilities, or to

both.” 

Append to this paragraph the following text: “There is, however, some uncertainty about

whether these exceedances are related entirely to OFASB, to upgradient F-Area facilities,

or to both.” 

Insert a new paragraph: “The results of recent groundwater sampling at the proposed MOX

facility site indicate that shallow groundwater (i.e., groundwater in the Upper Three Runs

Aquifer) is contaminated. Gross alpha and beta activity, tritium, uranium, and

trichloroethylene exceeded maximum contaminant levels for drinking water. Contamination

is present beneath the entire MOX site, but is greatest beneath the western edge of the site. 

The contaminant plume appears to originate inside the F-Area fence and was and is related

to F-Area nuclear operations and waste management practices at OFASB.” 

Make the following text the final paragraph of this section: “Groundwater in the Upper

Three Runs Aquifer beneath the MOX site is contaminated with various heavy industrial and

nuclear contaminants. The proposed construction activities will take place at least 9 m. 

(30 ft.) above the zone of contaminated groundwater.” 

Response: The text in Section 3.3.2 was changed as suggested in the comment.

J.3.16.13 Comment: 93-012

Comment: Page 4-18 of the DEIS states that water would be used to limit the amount of

fugitive dust.. This water will however interact with any radionuclides or other contamination

in the soil and contribute to the already acknowledged plume of contamination under the

site (page 4-7). No characterization of this plume is provided. How will it be possible to

determine in the future whether the proposed MOX facility has contributed to this problem

unless the current analysis includes a detailed characterization of what is currently in the

soil, in the vadose zone, in the groundwater, in the plume, and the direction and speed of

this plume’s movement. 

Response: The newly added discussion on soil quality (Section 3.2.3) indicates that metal

and radionuclide concentrations for near surface soils are well below the limits required by

applicable regulations. Adding water to limit fugitive dust during construction would

therefore have a small impact on groundwater resources. 

As discussed in Section 3.3.2, a plume of contamination exists beneath the proposed

location of the proposed MOX facility. This plume is moving north toward Upper Three

Runs Creek where it discharges to surface water. Contaminants within the plume include

iodine-129, nitrate, radium-226, radium-228, strontium-90, tritium, uranium (total), and lead. 
Appendix J

J-103

Groundwater velocities in the Upper Three Runs Aquifer are on the order of several

hundred feet per year. Due to sorption along the flow paths, however, contaminant

velocities could be substantially less, depending on the degree to which they are sorbed to

the surrounding material (contaminant-specific distribution coefficients). Because the

proposed MOX facility would not discharge any contaminants directly into the Upper Three

Runs Aquifer, it was determined that providing additional details on contaminant-specific

velocities in the Upper Three Runs Aquifer was not required. 

Surface spills could still lead to groundwater contamination. However, it is expected that the

impacts of such spills would be small, based on adherence to best management practices.

J.3.16.14 Comment: 43-001 

Comment: Concern was expressed about the quantity of surface and groundwater being

used by the Savannah River Site (SRS). DEIS page 4-6 shows the annual usage and

wastewater discharge for the sites of continued plutonium storage. The reported values for

the SRS are 127,000 million liters from surface water and 13,247 million liters from

groundwater. The discharge of liquid effluents is 700,000 million liters.

Response: As shown in Table 4.2, annual water use and wastewater discharges for the

SRS is 140,247 million L/yr and 700 million L/yr, respectively. This table lists the total

quantity of water used by the seven sites (Hanford, INEEL, Pantex, SRS, LLNL, LANL, and

RFETS) at which continued plutonium storage is possible. Because the volumes of water

are total quantities, they represent use from all ongoing activities at the sites. In all cases,

the amount of water required exceeds the volume of water discharged. This difference

occurs because water can be consumptively used by operations at the various sites that

consume water, not just activities associated with continued storage of surplus plutonium. 

Because the water volumes listed in Table 4.2 are totals for all operations, they do not

represent projected water use for constructing or operating the proposed MOX facility.

J.3.16.15 Comment: 86-099

Comment: The South Carolina Department of Health and Environmental Control

(SCDHEC) informed DCS that a 401 Water Quality Certification is only required if a

404 Permit is issued by the Corps of Engineers. SCDHEC does not anticipate any

requirement for a 401 Water Quality Certification for the proposed MOX facility. 

Response: The text in the Protection of Water Resources section of Table 6.1 in the FEIS

has been revised to indicate that the SCDHEC has notified DCS that a State Water Quality

Certification in accordance with SC regulation R.61-101 is not required.
Appendix J

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J.3.17 Waste Management

J.3.17.1 Comment: 86-045

Comment: The unit used in the DEIS on page 4-27, line 6 should be as follows: 

47,000 yd3

 per year (9.5 million gallons per year or 36,000 m3 per year). 

Response: The values in question have been corrected. The value should have been

47,000 yd3

/year as noted. This waste volume is converted to 36 million L/yr

(9.5 million gal/yr) for consistency.

J.3.17.2 Comment: 86-048

Comment: The footnotes for Table 4.10 (h) and Table 4.11 (i) should be deleted. 

Nonhazardous liquid waste (sanitary sewage) is not stored and is released to site streams

after treatment. 

Response: The footnotes have been deleted.

J.3.17.3 Comments: 67-001 108-001

 92-005 115-004

 93-016

Comment: The DEIS analysis of the large volume of liquid radioactive wastes to be 

generated in the MOX program is incomplete. There are already millions of gallons of

radioactive nuclear waste stored in this country. Liquid radioactive waste is highly corrosive,

and there have been problems with such wastes degrading their containment vessels. The

estimates of impacts for the liquid radioactive waste are baseless and therefore not

verifiable. The assumption that simply transferring this waste to the Savannah River Site

(SRS) and the Department of Energy (DOE) is an end-point when it comes to environmental

impacts is specious. For example, stating that the low-level wastes associated with the

proposed MOX facility is some percentage of the low-level waste at the SRS implies that the

proposed MOX facility is cleaning up the SRS. Any incremental increase to the radioactive

burden on the banks of the Savannah River is an unacceptable impact for the future

generations. The DEIS should state how much liquid waste is anticipated, how long it will

be necessary to store this waste, and what the long-term costs will be for storing this waste. 

Response: The discussions of the waste generation and further waste management have

been revised to more clearly show which processes are generating what types of wastes,

how those wastes will be treated, if necessary, and how those wastes will be disposed of.

Specific references have been added to show the source of the values used in the waste

management analysis. Text has also been added to discuss the human and environmental

impacts from waste management activities. 

The highly radioactive slurry (or liquid high alpha waste) that would be produced would be

transferred to a proposed facility (i.e., the Waste Storage Building [(WSB]) for further
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J-105

processing. This facility would be newly constructed with containment vessels designed for

the types of wastes planned to be generated by the proposed MOX facility and Pit

Disassembly and Conversion Facility (PDCF). The liquid waste would not go to the high

level waste tanks that have experienced corrosion problems noted in the comment. The

processing of the liquid high alpha waste would generate solid transuranic (TRU) waste and

solid low level radioactive waste (LLW) as its final waste forms. The TRU waste from the

proposed MOX facility would be handled at the SRS like other TRU waste generated from

other SRS activities. That is, the TRU waste would be packaged for disposal at the Waste

Isolation Pilot Plant (WIPP) consistent with the national policy for this particular type of TRU

waste in this country. Solid LLW is disposed of on-site [see revisions to the environmental

report] at the E-area waste vaults or off-site at an approved facility. Liquid LLW would be

treated and discharged to Upper Three Runs per permit. Environmental impacts associated

with existing waste management activities are presented in the Final Waste Management

Programmatic Environmental Impact Statement for Managing Treatment, Storage, and

Disposal of Radioactive and Hazardous Waste (DOE 1997a). Because the waste

generated from the proposed action would be managed by the SRS within its existing facility

capacities, the impacts from DOE 1997a are considered acceptable and are considered to

include and bound the impacts for managing wastes from the proposed action. Therefore,

comparing the capacities is considered a reasonable assessment method for assessing the

waste management impacts of the proposed action. The cost for implementing the waste

management activities has been included in the budget planned for managing the surplus

plutonium.

J.3.17.4 Comments: 10-003 44-003 71-014 96-007

10-017 66-007 79-002 96-016

24-006 71-006 90-003

Comment: Concern was expressed regarding the production of additional radioactive

waste at the Savannah River Site (SRS). The SRS is already plagued by enormous

quantities of dangerous waste and previous contamination. Waste impacts associated with

the proposed action were considered to only make the existing problems worse. The

proposed MOX facility will produce waste for which there is no satisfactory solution. 

Concerns were expressed that transuranic (TRU ) waste shipped to the SRS from other

Department of Energy sites would delay the treatment of waste generated from the

proposed MOX facility. The DEIS should include funds to address waste management. 

Response: Existing waste management activities at the SRS are discussed in Section 3.9. 

Human health risks associated with existing waste management activities are included in

the baseline human health risk discussed in Section 3.10. Environmental impacts

associated with existing waste management activities are presented in the Final Waste

Management Programmatic Environmental Impact Statement for Managing Treatment,

Storage, and Disposal of Radioactive and Hazardous Waste (DOE 1997a). 

Waste generated from the proposed action is evaluated in the FEIS in terms of how it is

going to be managed or handled (see Section 4.3.4), and what the impacts might be from

transporting them to other locations for disposal (see Section 4.4.1). The cumulative
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impacts associated with waste management activities are presented in Table 4.26 of the

FEIS (DEIS Table 4.25). These evaluations indicate that the SRS has the resources and

capacity for handling the additional waste. As discussed in Section 4.3.4 of the EIS and

summarized in Table 2.1, the wastes generated by the proposed action are estimated to

have a small to moderate impact on the waste management systems of SRS and WIPP.

The human health impacts from wastes are evaluated in terms of whether human exposure

to the waste products would occur. Data provided for the proposed facilities indicate that no

liquid discharges of waste would occur directly from the proposed MOX facility and the

PDCF. Liquid discharges from the WSB would follow the NPDES permit guidelines. Data

also indicate that air emissions impacts would be small . The waste streams generated

would be disposed of at facilities designed and operated in accordance with Department of

Energy (DOE) orders. Thus, disposal of these wastes is assumed to minimize human

exposures to the wastes and have small impacts or no impacts on human health.

The DOE has budgeted for the surplus plutonium disposition mission including managing

wastes from that mission. The cost of the proposed action discussed in Section 4.6 of the

EIS includes costs for waste management activities.

J.3.17.5 Comments: 10-017 61-005

53-007 66-007

Comment: The clarity of the information in the waste management analysis was

questioned. The DEIS does not adequately describe and track the various waste streams. 

A flow diagram would add to the clarity. The units in DEIS are not consistent. The liquid

radioactive waste stream should be reported in liters and gallons. The human health effects

associated with waste management activities are not addressed in the DEIS. 

Response: The discussions of the waste generation and further waste management have

been revised to more clearly show which processes are generating what types of wastes,

how those wastes will be treated, if necessary, and how those wastes will be disposed.

Specific references have been added to show the source of the values used in the waste

management analysis. Text has also been added to discuss the human and environmental

impacts from waste management activities. As suggested, Figure 4.1 has been added to

the FEIS to help in the understanding of the process as to when and what types of wastes

are generated and the ultimate disposition of these wastes. The FEIS has been revised to

report liquid radioactive waste volumes in gallons and liters. The DEIS presented these

volume in cubic meters for ease of comparison between various waste.
Appendix J

J-107

J.3.17.6 Comments: 13-006 103-003

 97-016 112-003

Comment: The DEIS evaluates a proposal by DCS for the Department of Energy (DOE) to

build a special waste building to handle the significant volume of highly radioactive liquid

MOX wastes. The DOE has not yet generated any records or budget requests indicating

acceptance of the MOX waste plan. The DEIS does not provide assurance that this can

and will occur in a reasonable manner due to available and planned capacity, utilization,

obligations, priorities, and acceptance criteria. The DEIS must discuss the environmental

risks and consequences of DOE failure to implement MOX waste management. The DEIS

should produce verifiable projections of waste volumes as well as discuss the environmental

risks and consequences of DOE failure to implement MOX waste management. 

Response: The DOE has included the construction and operation of the Waste Storage

Building (WSB) into their planning for the proposed fabrication of the MOX fuel. The WSB

is planned to be constructed and operated by the DOE to process the liquid high alpha

waste from the proposed MOX facility. Because the WSB is required to be operational at

the same time as the proposed MOX facility in order for the proposed MOX facility to

operate, it is not reasonable to evaluate an alternative where this is not the case. See

response to comment J.3.17.4 for additional information.

J.3.17.7 Comment: 116-016

Comment: The DEIS should clearly state how the high alpha waste will be treated and

whether it would be classified as high-level waste, low-level waste, or mixed waste.

Response: The proposed plan for handling the liquid high alpha waste calls for transferring

this waste stream from the proposed MOX facility to the Waste Solidification Building for

further processing via a double-walled pipeline. The processing of the liquid high alpha

waste would generate solid transuranic waste and low-level waste. 

J.3.17.8 Comments: 86-019 86-050

86-047 86-073 

Comment: The Savannah River Site (SRS) treatment capacity for nonhazardous liquid

waste reported in Tables 4.10, Table 4.11, Section 2.4, and Section 4.3.4.2 of the DEIS is

incorrect. The 35% value of the capacity of the Central Sanitary Waste Treatment Facility

(CSWTF) was apparently calculated using values in Table 4.11. This is incorrect because

treatment of waste from the proposed MOX facility, the Pit Disassembly and Conversion

Facility, and the Waste Solidification Building requires much less that 35% of capacity. The

correct value is closer to 10% (about half of the nonhazardous liquid waste from these

facilities consists of non-process utility waters that will be released directly to permitted

National Pollutant Discharge Elimination System (NPDES) outfalls). 

The treatment capacity of the CSWTF is provided in the MOX ER on page 4-43 (1.1 M

gals/day) or Table 5-6 (273M gal/yr). The permitted capacity is 1.05M gal/dy. The SPD EIS
Appendix J

J-108

(Table 3-41) reports CSWTF capacity as 1.45 Mm3/yr (383 Mgal./yr). It is recommended

that 273 Mgal/yr value be used in the DEIS. 

Response: The treatment capacity of the CSWTF has been changed to 273 Mgal/yr as

suggested by the comment. The percentage in question has been recalculated based on

the revised capacities of the CSWTF (from 73Mgal/yr to 273Mgal/yr). The value is now

approximately 6%. The MOX ER does not provide a breakdown as to how much of the

projected liquid nonhazardous waste is sanitary wastewater as opposed to process

wastewater; and therefore, as a conservative approach the evaluation of impact assumed

all of the projected volume to go to the CSWTF and calculations were performed

accordingly. 

J.3.17.9 Comment: 87-002

Comment: The DEIS discusses a number of the liquid waste streams to be dealt with

including chloride, americium, and uranium. However, the DEIS does not mention other

impurities that exist in some of the plutonium oxide stocks. The DEIS should address how

these wastes will be handled. 

Response: The impurities mentioned in the comment are present in very low

concentrations in the plutonium feedstock. The impurities would be removed as part of the

MOX plutonium polishing process and would become part of the liquid high alpha waste

stream. The processing of the liquid high alpha waste would generate solid TRU waste and

solid low level radioactive waste (LLW) as its final waste forms. These impurities would not

affect the classification of these final waste forms or the capability to properly dispose of

these waste forms.

J.3.17.10 Comment: 86-009

Comment: In EIS Section 2.2.4.1, page 2-14, the DEIS states that most of the solid waste

generated in the Waste Solidification Building (WSB) would be mixed with concrete and

poured into approved containers. This is an incorrect statement. The processed liquid

wastes will be mixed in the WSB with concrete and poured into containers to produce solid

waste. The solid waste will not be mixed with concrete. 

Response: The text in Section 2.2.4.1 has been revised as suggested to state that the

processed liquid waste will be mixed in the WSB with concrete and poured into containers

to produce solid waste.

J.3.17.11 Comment: 114-005

Comment: Hazardous and radioactive wastes are permitted to be burned in the H-Area

Consolidated Incinerator Facility (CIF) (Unit ID # H-010). Although South Carolina

Department of Health Environmental Control (SCDHEC) has stated that the CIF is not

currently in operation, it recently granted DOE-Westinghouse Savannah River Company a

new permit to operate the waste incinerator. The DEIS states that some waste will be sent
Appendix J

J-109

to other facilities at the Savannah River Site (SRS). The CIF is required to comply with

40 CFR 61 Subpart H, “National Emission Standards of Radionuclides Other Than Radon

From Department of Energy Facilities.” Although radionuclide emission rates from the

stacks of the CIF and other sources are measured, the millirem standard for maximum

allowable dosage to the public is an ambient standard, not an emission limit. Without

ambient measurements, neither DOE nor Westinghouse Savannah River Company can

assure that emissions of radionuclides are below 10 millirem per year to any member of the

public. Likewise, the DEIS fails to cite any direct ambient measurement as a basis for

estimates of radioactive dose to the public. 

Response: There are two separate issues: (1) radiation exposure; and (2) the ambient

levels of criteria pollutants. In Section 4.3.1.1.2 of the EIS, the exposure of the public

maximally exposed individual (MEI) at the Savannah River Site boundary to emissions of

radionuclides from the proposed facilities was estimated to be 0.0040 mrem/yr. This

exposure is less than 0.1% of the standard under Subpart H. The levels of criteria

pollutants have been reanalyzed and updated as discussed in response to

Comment J.3.15.1.

J.3.17.12 Comment: 97-014

Comment: The DEIS appears to use single tank or container quantities for a large number

of analyses. This does not seem reasonably prudent and conservative given that the facility

is still being designed and common mode failures cannot be discounted (e.g., multiple tanks

failed by the same event or leaks via common piping and valves). It is recommended that

larger inventories (up to and including the site inventory, as necessary) be used for releases

of chemicals from fluids. 

Response: The assumption that the contents of one container would be released is

generally conservative enough to bound potential accident impacts, because in general the

estimated spill volume (given in Table E-1) was about the same as the anticipated on-site

inventory (given in Table 3-2 of the June 2003 version of the DCS Environmental Report);

that is, for most process chemicals, there would only be one storage container at the facility

at a given time. The accident analyses also include other conservative assumptions, such

as that the releases would occur outdoors. Very stable meteorological conditions, leading

to high air concentrations, are also analyzed. 

One chemical which will have many containers present on the site is depleted uranium

oxide. Many drums of depleted uranium dioxide (UO2) will be in warehouse storage. The

accident assessment for uranium dioxide conservatively assumed partial release of material

from 200 drums during a fire. 

J.3.17.13 Comment: 86-043 

Comment: The DEIS incorrectly describes the treatment of nonhazardous wastewater.

Nonhazardous wastewaters, except for traditional sanitary wastewater, will either be sent to

an appropriate permitted treatment facility at the Savannah River Site, or, in the case of
Appendix J

J-110

runoff and uncontaminated heating, ventilation, and air conditioning (HVAC) condensate, be

discharged directly to a permitted National Pollutant Discharge Elimination System (NPDES)

outfall. Sanitary wastewater will be sent to the Westinghouse Savannah River Company

(WSRC) Central Sanitary Waste Treatment Facility.

Response: The text in Section 4.3.3.1.2 and Section 5.2.2 was changed to more

accurately describe the treatment of nonhazardous wastewater. 

J.3.18 Deactivation and Decommissioning

J.3.18.1 Comment: 86-062

Comment: Because the impacts of decommissioning the proposed MOX facility were

included in the MOX Environmental Report, Rev. 1 & 2, and responses to two request for

additional information (RAI) questions (July 12, 2001), it is suggested to delete the phrase

“Although impacts of decommissioning the facilities were not included in the ER (DCS

2002a)...” on line 1-3, page 4-48 of the DEIS.

Response: The text in Section 4.3.6.1 of the FEIS referring to the ER has been revised to

indicate that since the scoping process identified decommissioning as a significant issue,

the potential impacts of decommissioning the facilities is presented in the EIS.

J.3.18.2 Comments: 7-002

89-012 

Comment: It was questioned what would happen when the proposed MOX facility was

useless or not functional and how damage would be compensated. The DEIS should be

revised to indicate that the proposed MOX facility will not be decommissioned under its

Nuclear Regulatory Commission (NRC) license. Further, any analyses or discussions

relative to decommissioning, such as license termination and regulatory requirements,

should be revised as necessary to reflect the appropriate end state for the operating

license. 

Response: It is true that final disposition of the facility will be within the purview of the

Department of Energy (DOE), and the end state of the facility would not be determined until

the end of the operational period. However, for the sake of this impact analysis,

decommissioning for ultimate release for unrestricted use is assumed. This assumption is

made to bound potential impacts arising from the possible end uses of the facilities. For the

purpose of analysis, the appropriate NRC license termination and regulatory requirements

are assumed to apply. Furthermore, NRC regulations require NRC licensed facilities to be

decommissioned. To date, the applicant has not requested nor been granted an exemption

from this regulation.
Appendix J

J-111

J.3.18.3 Comment: 86-064

Comment: Although DCS is the licensee, the current contract calls for deactivation of the

facility and return to Department of Energy (DOE) for decommissioning or reuse. It is

improper to include the costs associated with borrowing funds to finance the project since

DOE is a government agency. 

Response: Section 4.3.6.3.2 of the FEIS has been changed to reflect the information

provided in the comment.

J.3.18.4 Comment: 86-063

Comment: There appears to be an inconsistency in the decommissioning waste section

and the costs section. Although the section on waste management indicates that the

quantities and classification of waste types cannot be determined at this time, the costs are,

nevertheless, based on “...the volumes and types of waste generated during the

decommissioning of those buildings... .”

Response: Although there is considerable uncertainty surrounding the waste types and

volumes that would be found in a MOX facility at the end of operations, the analysis was

able to estimate the direct decommissioning costs based on the costs of dealing with

broadly similar facilities in Colorado. These estimates are not based on projections of waste

types and volumes in a proposed MOX facility as is suggested in the comment.

J.3.19 Environmental Justice

J.3.19.1 Comment: 94-002

Comment: The Nuclear Regulatory Commission’s (NRC’s) evaluation of environmental

impacts in licensing actions is not consistent with the terms of Executive Order 12898. By

letter dated February 10, 2003, the Commission stated that it intended to reconsider its

policy concerning the application of Executive Order 12898. 

Response: The NRC has published its “Final Policy Statement on the Treatment of

Environmental Justice Matters in NRC Regulatory and Licensing Actions” on August 4, 2004

(69 FR 52040). The analysis in the EIS is consistent with the NRC’s Final Policy Statement

and is based on NRC’s current guidance.

J.3.19.2 Comment: 22-002

Comment: It was questioned about whether the Nuclear Regulatory Commission did an

environmental justice analysis of the area of “ethnic low-income groups” around Lake

Norman. 
Appendix J

J-112

Response: The analysis of environmental justice impacts of the use of MOX fuel in

commercial reactors is beyond the scope of the EIS, which analyzes the construction and

operation of the proposed MOX facility.

J.3.19.3 Comments: 28-001 64-007 79-003 88-003

28-002 70-001 81-001 93-017

39-004 78-003 82-004 96-011

Comment: It was stated that environmental justice impacts should be included in the EIS. 

The entire environmental justice section needs to be reviewed again, due in part to NRCacknowledged incorrect accident consequences. Concern was expressed regarding

potential impacts to environmental justice communities, which were viewed as unacceptably

high. It was suggested that the license should be denied based on the results of the

environmental justice analysis. 

Response: A discussion of the potential environmental justice impacts is provided in

Section 4.3.7 of the EIS. Estimates of latent cancer fatalities in the population as a whole in

the event of an accident have been revised since the DEIS was published (see

Section J.2.2.1). Accordingly, the analysis of potential accidents and their impact on lowincome and minority populations has also been revised in the FEIS. With respect to lowincome and minority populations around the SRS, the impacts from an accident at the

proposed MOX facility are not considered to be high and adverse. The impact analysis for

potential accidents at the Pit Disassembly and Conversion Facility and the Waste

Solidification Building indicate the potential for high and adverse impacts.

J.3.19.4 Comments: 9-001 35-002 35-006 93-017 96-026

 9-002 35-003 64-007 96-013 96-034

 9-003 35-004 80-002 96-014 96-038

 9-005 35-005 84-002 96-015

Comment: Concern was expressed regarding the appropriateness of proposed mitigation

measures associated with potential environmental justice impacts. It was stated that the

environmental justice mitigation measures were not adequate and should be stronger and

more detailed. Mitigation should be to provide compensation or incentives to environmental

justice communities. It was suggested that a health care center be built so that people who

suspect that they are adversely affected can receive medical treatment. It was felt that the

applicant should be made to meet and work with the environmental justice community. It

was stated that some in the environmental justice community lack understanding of the

proposed action. These communities should be educated and should be involved in

developing any environmental justice mitigation actions. 

Response: As discussed in Sections J.2.2.1 and J.2.2.2, the accident results have been

revised based on errors found in the DEIS and resolution of issues identified during NRC’s

safety review. As such, the environmental justice section has been revised to reflect these

changes. For environmental justice impacts from the proposed action, the FEIS concludes

that although low-income and minority populations may, depending on wind direction, be
Appendix J

J-113

disproportionately impacted, that those impacts are not considered to be high or adverse for

the proposed MOX facility. The impact analysis for potential accidents at the Pit

Disassembly and Conversion Facility and the Waste Solidification Building indicates the

potential for high and adverse impacts. Mitigation measures have been suggested to

reduce these potential impacts. 

In the event of an accident, general emergency response measures would occur at the

Savannah River Site to protect the surrounding public. These are outlined in the response

to Comment J.3.19.10.

J.3.19.5 Comments: 86-004 86-089

86-065 89-009

86-088

Comment: The accidents impacts presented in the DEIS that could cause a potential

environmental justice impact are prevented by design safety systems; and therefore, should

not be considered in the EIS. In addition, although these accidents may have significant

consequences, the likelihood of such accidents are at very low frequencies, and hence they

have minimal risk. The projection of an environmental justice impact and inclusion of these

mitigative action requirements are inappropriate and inconsistent with the goal of the

National Environmental Policy Act to provide the public with meaningful environmental

analyses, and should be removed from the DEIS. 

The DEIS provides no justification why DCS should provide local agencies or groups

representing environmental justice groups with “public information “ on existing soil or

groundwater contamination monitoring, or the nature, extent, or likelihood of surface

releases. Providing such information is not mitigation action related to the proposed MOX

facility, which has yet to be constructed. Similarly, the DEIS does not provide a justification

why DCS should take the unprecedented initiative to create a spatial database for use by

local authorities. In the event of any incident at the Savannah River Site, the authorities

would alert all potentially affected communities, not just minority communities. For the

Nuclear Regulatory Commission (NRC) to proscribe mitigative actions is beyond the

statutory authority of NRC. 

Although the DEIS states that the guidance in NUREG-1748 was followed, the DEIS, by

using a 50-mile radius for environmental justice impacts does not follow the guidance of

NUREG-1748, which proscribes a radius of 4 miles. Additionally the DEIS is directly

contrary to specific guidance provided by NRC to DCS in the 11 Dec. 2000 letter from

M. Galloway to R. Ihde. This guidance was that the 50-mile radius in NUREG-1718 was

incorrect and DCS should follow the Office of Nuclear Material Safety and Safeguards

(NMSS) Policy and Procedures letter proscribing a 4-mile radius. The DEIS should conform

to NRC guidance and only analyze environmental justice impacts within a 4-mile radius of

the proposed MOX Facility. If the FEIS will contain a larger area for environmental justice

analyses in an effort to be overly conservative, the DEIS should acknowledge this, but not

tie environmental justice mitigation to overly conservative analyses. 
Appendix J

J-114

Response: Comments regarding accidents and the bases of the accident analysis are

provided in Section J.3.14. In summary, the EIS attempted to provide a comprehensive,

bounding analysis for all potential events up to and including design basis accidents. The

EIS provides a conservative estimate of accident impacts and an independent review of

previous accident analyses performed for the proposed MOX facility, the Pit Disassembly

and Conversion Facility, and the Waste Solidification Building. The accident impacts

presented in this EIS are conservative in nature, but not unreasonably. 

The DEIS concluded that there was not an environmental justice concern for construction

and operation of the proposed MOX facility. The DEIS further stated that there was a

potential environmental justice concern, if an accident producing significant contamination

occurred. The environmental justice section (Section 4.3.7.3) states that the risk to any

population, including low-income and minority communities, is considered to be low. NRC

proposed mitigation measures to reduce the potential impacts to low-income and minority

communities. The mitigation measures proposed in the DEIS were based on the accident

results published in the DEIS. 

As discussed in Section J.2.2.1 and J.2.2, the accident results have been revised based on

errors found in the DEIS and resolution of issues identified during NRC’s safety review. As

such, the environmental justice section has been revised to reflect these changes. 

Under 40 CFR 1500.2 (f), federal agencies shall to the fullest extent possible use all

practical measures to avoid or minimize any possible adverse effects of their actions on the

quality of the human environment. Mitigation measures were proposed in the DEIS

consistent with the level of potential impact. 

Although NRC guidance provides for the analysis of environmental justice impacts within a

4-mile radius of nuclear materials facilities, the guidance does allow for consideration of

larger areas, as deemed appropriate. As discussed in the response to Comment J.3.6.1,

the geographic area, over which impacts are assessed, varies depending on the type of

resource. For human health risk, a radius of 50 miles was selected as appropriate to

consider health impacts from the proposed MOX facility. Given these considerations, and

the concern over environmental justice issues at the scoping meetings, it was decided to

take a conservative approach to measuring the potential impacts of an accident on low

income and minority populations by using a 80 km (50 mile) radius. 
Appendix J

J-115

J.3.19.6 Comments: 31-001 64-005

35-006 96-002

Comment: Concern was expressed regarding the level of detail in the environmental

justice analysis. It was stated that the environmental justice analysis is inadequate and

needed additional details and explanation. It was requested that the EIS provide a table

showing where low-income and minority people would die at the census block level. It was

stated that this would add to the transparency of the document. 

The data contained in the DEIS does not support the conclusion that there is an

environmental justice concern. An independent analysis was provided by a commenter

using a probabilistic approach and wind direction and probability (Figure 3.5), population by

sector (Table E.8), and areas with disproportionate minority or low income population

concentrations (Figures 4.1 and 4.2). For each sector, the number of low income and

minority people were compared with the total the number of people. The commenter’s

analysis concluded that, if offsite health impacts result from windborne contamination, then

there is no disproportionate impact on low income and minority populations. 

Response: The environmental justice analysis was performed in accordance with Nuclear

Regulatory Commission (NRC) guidelines (NUREG-1748). The analysis method is multistep and consists of first determining if a site has a potential environmental justice concern

based on demographics of low-income and minority populations. Next, the determination is

made whether the impacts disproportionately impact low-income or minority populations. In

cases where the environmental justice population is located next to the site, the impacts or

potential for impacts will likely be disproportionate. In other cases, specific behavior of

environmental justice populations, such as a greater portion of their diet consisting of crops

grown at home, may result in a disproportionate impact. Finally, if it is determined that there

is a disproportionate impact, the determination is made whether the impact to low-income or

minority populations is “high and adverse.” Additional text has been added to Section 4.3.6

to clarify the analysis method. 

Sufficient data is provided in Figures 4.1 and 4.2 of the FEIS to establish the general

distribution of the minority and low income population within a 50-mile radius of the

proposed facility. Specific information on health impacts on minority or low income

populations within any given block group cannot be provided as the actual distribution of

population within the block group is not taken into account in the analysis. Entire block

groups are simply classified according to the relevant minority and low income population

concentration thresholds. 

The analysis provided by the commenter is not consistent with NRC methodology. 

Disproportionate impacts are based on whether impacts are greater for environmental

justice populations or if they experience impacts that non-environmental justice populations

do not experience. Disproportionate impacts do not simply rely on the proportion of the total

population that is potentially minority or low income in the area covered by the plume as a

whole, as the commenter suggests. 
Appendix J

J-116

J.3.19.7 Comments: 72-007

115-003

Comment: Concern was expressed that the environmental justice analysis shows that

existing and past activities at the Savannah River Site (SRS) have impacted low income and

minority communities surrounding the site. 

Response: The DEIS concluded that there would not be an environmental justice concern

for construction and normal operations of the proposed action. The DEIS further stated that

there was a potential environmental justice concern, if an accident producing significant

contamination occurred. The analysis does not imply that existing operations at SRS have

caused environmental justice impacts. As discussed in Section 3.10, the human health

risks for the surrounding community for existing SRS activities is very low. One could

conclude that the impacts of existing SRS activities do not pose a high adverse impact; and

therefore, there have been no environmental justice impacts from existing activities.

J.3.19.8 Comment: 72-010

Comment: The evaluation in environmental justice does not consider the long-term

impacts of the waste from the proposed MOX facility. Although the NRC does not regulate

waste management activities at the Savannah River Site (SRS), the impact from these

activities will impact of these very same environmental justice communities. 

Response: At the end of operations at the MOX facility, all wastes produced by the

proposed facility would become the responsibility of the Department of Energy and would be

managed in accordance with guidelines and procedures for all other waste materials at the

SRS. EISs already completed by the DOE indicate that there are no significant human

health impacts of waste management operations. Therefore, no environmental justice

impacts would be associated with the management of the proposed MOX facility wastes

produced during the operating period or decommissioning period. Text has been added to

Section 4.3.7.3 of the FEIS to clarify this issue. 

J.3.19.9 Comments: 10-015

82-002

84-002

Comment: There seem to be numerous contradictions within the report of what will and

what will not be studied in terms of environmental justice. For instance, environmental

justice impacts apparently will not be studied along MOX transportation routes but

elsewhere in the document it states that transportation will be studied in terms of

environmental justice. Impacts to less fortunate communities were viewed to occur from

transportation activities. It was stated that the EIS should consider the environmental

justice impacts of the transportation. 

Response: The DEIS stated in Section 5.2.12 that mitigation measures would include

relevant risks associated with MOX-related transportation programs. However, as noted in
Appendix J

J-117

the scoping summary report (Appendix I), environmental justice impacts along

transportation routes were not included in the DEIS due to uncertainties surrounding the

transportation routes that would be used, and the timing and quantity of MOX shipments. 

The statements in Section 5.2.1.2 of the DEIS have been deleted to address this

contradiction, and text has been added to Section 4.3.7.1 of the FEIS to clarify the basis for

not considering environmental justice impacts along transportation routes. 

J.3.19.10 Comments: 77-005

96-030

Comment: The mitigation measures suggested are insufficient to achieve environmental

justice for the low-income populations in the area surrounding the Savannah River Site

(SRS). The mitigation measures should be revised to include: (1) warning sirens in the

area of the facility, (2) free health care for those with health risks elevated due to the

operation of the facility; and (3) an economic benefit for those who reside near the proposed

MOX facility to offset the economic and health disadvantages of living in the area. It was

suggested that the Nuclear Regulatory Commission (NRC) recommend that DCS work with

potentially impacted communities.

Response: The NRC does not believe that normal operations of the proposed MOX facility

increases health risks to the offsite public that warrants mitigation. In the case of an

accident, warning sirens at the proposed MOX facility and the SRS boundary would be

sounded as one means of alerting nearby residents. DCS and the SRS would follow

established emergency procedures to inform local and state officials of the nature and

extent of an accident and assist with appropriate actions to protect human health and

safety.

J.3.19.11 Comment: 96-005

Comment: The mitigation measures section addressing the disproportionate impact to

minority communities is totally unacceptable. The proposed mitigation measures place an

unfair burden on communities and local government. Education will not address impacts

described in the DEIS. Local governments and citizens should not bear the responsibility of

emergency preparedness and associated costs. 

Response: A reanalysis of impacts from accidents involving the MOX facility, the Pit

Disassembly and Conversion Facility and the Waste Solidification Building to low income

and minority populations has been conducted. Mitigation measures were revised to address

the results of the new accident analysis and are reported in Chapter 5 of the EIS. The

Nuclear Regulatory Commission does not intend for local communities to bear the full cost

associated with emergency preparedness in the event of a severe accident affecting the

local population. The DOE Emergency Preparedness Plan for the Savannah River Site

would be implemented in case of an accident resulting in offsite releases of radioactive or

chemical materials. 
Appendix J

J-118

J.3.20 Transportation

J.3.20.1 Comments: 29-001

85-001

Comment: The transport of spent fuel and unused nuclear weapons pits to and from the

proposed MOX facility was of concern. This presents a desirable target for terrorists. Many

local communities do have sufficient law enforcement and National Guard to meet these

challenges while many do not. It was suggested that costs for the law enforcement and

National Guard to protect the MOX materials was an unfunded federal mandate. The

Nuclear Regulatory Commission should address this unfunded federal mandate.

Response: The unfunded federal mandate comment raises issues that are outside the

scope of this EIS. The shipments would be treated as other shipments of special nuclear

materials under the protection of the U.S. Department of Energy Office of Transportation

Safeguards as discussed in Section C.2.3 of Appendix C in the EIS. The nuclear weapons

pits and MOX fuel would be shipped via the SafeGuards Transporter (SGT). The SGT is a

structurally reinforced vehicle operated by armed federal officers and travels with armed

escort vehicles.

J.3.20.2 Comment: 29-002

Comment: Although transportation casks have been looked at in regulation and testing for

many years, the form of the spent fuel and the nuclear weapons pits have taken a back

seat. The spent fuel has often failed in use and presents a peculiar problem in

transportation and decanting. The design of the transportation casks often does not

address the failures and the type of failures of the spent fuel. Any assumption that the fuel

will be in a form which does not complicate accidents and handling may be flawed and

needs to be addressed. 

Response: The U.S. Nuclear Regulatory Commission (NRC) has requirements in its

regulations in 10 CFR Part 71 that address the form of the radioactive fuel. The cask, also

referred to as packaging, must be able to protect the contents from being released to the

public and also must keep the dose to the public under specified limits for both routine and

accident conditions of transport. The NRC has conducted a number of risk studies

concerning the responses of spent fuel casks subjected to accident and severe accident

conditions. The expected response of casts to these conditions can be found in such

reports as Shipping Container Response to Severe Highway and Railway Accident

Conditions (NUREG/CR-4829) published in 1987 and Reexamination of Spent Fuel

Shipment Risk Estimates (NUREG/CR-6672) published in 2000. The NRC is currently

working on the Package Performance Study which is a new risk study in the planning stage. 

This research program proposes to test the full scale transport casks under conditions that

would exceed regulatory requirements. This type of information, including that used for

plutonium metal, was incorporated into the transportation risk analysis in this EIS.
Appendix J

J-119

J.3.20.3 Comment: 86-067

Comment: The impacts resulting from shipping 50 metric tons of surplus plutonium to the

Savannah River Site were covered in the DOE’s Surplus Plutonium Disposition (SPD) EIS. 

The Nuclear Regulatory Commission should have simply deferred to that analysis instead of

reanalyzing impacts already evaluated by another federal agency. 

Response: The transportation risks for shipping the 50 metric tons (55 tons) of surplus

plutonium were not presented separately from other transportation actions in the DOE’s

SPD EIS, making it impossible to extract the impacts directly associated with the plutonium

shipments. In addition, decisions regarding the source of the plutonium, such as the Rocky

Flats Environmental Technology Site (RFETS) shipments, were made after publication of

the SPD EIS. Thus, the re-analysis of impacts associated with the shipments of plutonium

provided more detailed information specific to the proposed action. 

J.3.20.4 Comment: 86-068 

Comment: The value for transuranic (TRU) waste on page 4-63, line 22 of the DEIS

appears to be a great deal higher than experience.

Response: The detailed design information on the internal configuration of the TRUPACTII containers, as it pertains to the Waste Solidification Building TRU waste shipments, is not

yet available. Therefore, a conservative assumption was made to use the highest estimated

dose rate for shipments expected to go to the Waste Isolation Pilot Plant (WIPP) as

provided in the WIPP transportation studies. As referenced on line 23 of page 4-63 and line

20 on page C-21 in Appendix C, the 0.040 mSv/h dose rate for TRU waste shipments was

taken from DOE's Waste Isolation Pilot Plant Disposal Final Supplemental Environmental

Impact Statement (DOE/EIS-026-S-2).

J.3.20.5 Comment: 86-100

Comment: On page C-6, lines 37-38 of the DEIS, perhaps it would be better to state “The

model allows the user to evaluate transportation risk, considering differences in the mode of

transport and package used. The user selects parameters to represent the probability of an

accident occurring and consequences of a spectrum of accident severities.” 

Response: The text in Section C.1.3.1 was revised in the FEIS to clarify that the model

takes into account the mode of transportation and the type of packaging through selection

of the appropriate accident probabilities and release fractions, respectively.

J.3.20.6 Comment: 86-102

Comment: A clarification should be made on page C-12, line 36 of the DEIS. The MOX

ER specifies a 55-gallon Industrial Type 1 drum for the shipment of uranium dioxide (UO2). 

The DEIS specifies a 30-gallon Type A drum size.
Appendix J

J-120

Response: The text has been revised in the FEIS to indicate that the uranium dioxide does

not require Type A packaging and is expected to be shipped in industrial packaging. Text

has been revised to indicate the use of a 55-gallon drum for uranium dioxide shipments. 

J.3.20.7 Comment: 86-103

Comment: Shipment routes were of concern in Section C.2.1.1 of the DEIS. It is important

to clarify that none of the shipments would meet highway route controlled quantity (HRCQ)

requirements. The uranium hexafluoride (UF6) and uranium dioxide (UO2) won’t meet

HRCQ requirements because of the material hazards; the plutonium metal and MOX will be

handled securely by DOE’s Office of Secure Transportation (OST), and the transuranic

(TRU) waste will follow Waste Isolation Pilot Plant (WIPP)-prescribed routes. 

Response: The plutonium metal and MOX fuel meet HRCQ requirements whether or not

they are handled by DOE’s OST. Routing of a HRCQ of material is determined according to

49 CFR 397.101, “Requirements for motor carriers and drivers.” Text has been added in the

FEIS to clarify that the TRU waste shipments will follow the designated WIPP routes.

J.3.20.8 Comment: 86-105 

Comment: It is suggested to provide a reference for how the number of shipments of

plutonium metal to the Pit Disassembly and Conversion Facility (PDCF) was determined,

since it differs from that used in the Surplus Plutonium Disposition EIS in Table C.2.

Response: The number of shipments was determined by the amount of plutonium metal

shipped from Pantex and Hanford to the PDCF and the amount of plutonium metal in each

shipment. As discussed in Section 4.4.1.1, 21.3 metric tons (23.4 tons) and 5.4 metric tons

(5.9 tons) of plutonium metal was assumed to be shipped from Pantex and Hanford,

respectively. The amount of plutonium metal in each shipment was determined from

Table 4 in Didlake (1998) that listed 33 MT of plutonium pits and metal destined for the

PDCF in 530 loads. Using the amounts to be shipped (21.3 and 5.4 metric tons) and the

amount per shipment (33 metric tons divided by 530 shipments) the number of shipments

were estimated to be 343 and 87 from Pantex and Hanford, respectively. 

J.3.20.9 Comment: 86-110

Comment: The assumption that stops of Safeguards Transporter (SGT) shipments of both

the fresh, unirradiated MOX fuel and the plutonium metal along the route would have the

same duration and public exposure as spent fuel truck shipments is overly conservative. 

Response: As discussed in Section 4.4.1.1 of the EIS a surrogate commercial nuclear

power plant at a Midwestern location was chosen for assessing the transportation risks of

the fresh, unirradiated MOX fuel. This conservative assumption was made to bound the

impacts for use of the MOX fuel by any power plant in the eastern to Midwestern portion of

the United States. In this case, rest stops would be needed over the 1,300-mile journey.
Appendix J

J-121

There is no reason to assume that the stop times used are specific to spent fuel shipments

because truck maintenance and crew rest conditions would be similar. 

The MOX ER assumed no stops for the MOX fresh, unirradiated fuel shipments because

these shipments were assumed to be between the Savannah River Site and the McGuire

and Catawba nuclear plants. These shipment distances are both on the order of 200 miles

which is easily traversed without the need for refueling or rest for the crew. 

J.3.20.10 Comment: 86-111

Comment: On page C-23, line 20 of the DEIS, units on this risk factor, based on the

subsequent text, should be “latent fatalities-km/person.”

Response: For a population density of 1 person/km2

, as mentioned in the text, the factor is

as written. When used to determine risks at other population densities the full set of units

must be used: 8.36E-10 latent fatalities/km per person/km2

 which reduces to the form

suggested in the comment.

J.3.20.11 Comment: 89-051

Comment: The values in the accompanying paragraph do not agree with the values

presented in Table 4.20 of the DEIS. This inconsistency should be reconciled.

Response: The text was revised to present the proper values as listed in Table 4.21 of the

FEIS (DEIS Table 4.20).

J.3.20.12 Comments: 24-001

71-002

Comment: The U.S. portion of the proposal involves shipment of plutonium from

dismantled nuclear weapons sites in western states, some likely via lnterstates 40 and 26

en route to South Carolina. The greatest transportation risk would be an accident in which

plutonium metal, which rapidly oxidizes when it comes into contact with air, would vaporize

or burn and disperse its deadly particles contaminating the air our citizens inhale, the water

upon which we depend and the soil upon which we grow crops and upon which animals

feed.

Response: The staff notes that the commenter assumes that an accident would cause a

release of a cask’s contents to the environment. The Nuclear Regulatory Commission

(NRC) regulations require that the transport release of a cask be designed to withstand a

sequence of four hypothetical accident conditions including drop, puncture, fire and

submersion and still be able to perform its safety functions of containment and shielding. 

Such design requirements make it very unlikely that an accident would result in the release

of the shipped material to the environment. The commenter should note, however, that the

plutonium that will be shipped will not be in powder form, and thus if in the unlikely event
Appendix J

J-122

that it were released to the environment, it would neither be easily inhaled nor would it be

easily vaporized or burned.

J.3.20.13 Comment: 86-101

Comment: In Section C.1.3.1, page C-7, lines 1-10 of the DEIS, the use of the ingestion

pathway resulting from the consumption of contaminated food is highly speculative. Public

policy and emergency response experiences from Three Mile Island in 1979 and Chernobyl

in 1986 indicate that, essentially all food (whether contaminated or not) was destroyed,

making the ingestion scenario not “reasonably foreseeable.”

Response: The ingestion of contaminated food is a potential exposure pathway for

transportation accidents as recognized by its incorporation into the RADTRAN

transportation risk code originally developed for the NRC when it produced NUREG-0170 in

1977, Final Environmental Impact Statement on the Transportation of Radioactive Materials

by Air and Other Modes. Since that time, radiological transportation risk assessments have

routinely included the ingestion pathway as a potential source of exposure (e.g., see A

Resource Handbook on DOE Transportation Risk Assessment, DOE/EM/NTP/HB-01). One

reason for this trend in conducting radiological transportation risk assessments is concern

by the public that appropriate actions to protect the public would not be carried out and the

desire to know what would happen in the absence of these actions (e.g., intervention or

interdiction of contaminated crops). 

The ingestion of contaminated food is not highly speculative. The Nuclear Regulatory

Commission recognizes that some interdiction would likely occur following a significant

accident, even if contamination levels were below the protective action guides. Such a

response occurred after Three Mile Island where no crop contamination was found. On the

other hand, some members of the public were found to return illegally to contaminated

areas near Chernobyl to live for various reasons (e.g., attachment to ancestral home/high

sense of displacement) that could easily result in the consumption of contaminated, locally

grown food. Thus, the inclusion of the ingestion pathway provides upper bound estimates

of the impacts of potential significant accidents. 

J.3.20.14 Comment: 86-108

Comment: Plutonium isotopic distribution is the same for plutonium metal, MOX fuel, and

transuranic (TRU) waste. The Curie content should be linear with mass of plutonium in

each stream. This should be reflected in Table C.3.

Response: The numerical values for the activity of plutonium in the MOX fuel and TRU

waste shipments were taken directly from the DCS references noted in Table C.3 without

any type of conversion. These values were preliminary estimates and are still subject to

small changes. No further action will be taken at this time.
Appendix J

J-123

J.3.20.15 Comment: 116-009

Comment: It was questioned whether the Nuclear Regulatory Commission considered both

fatal and non-fatal truck accidents. Also, it was questioned why the “neutral weather”

conditions and not the “worst case” weather conditions were considered in an transport

accident. Excluding the transportation risks on-site at the Savannah River Site was also

questioned.

Response: As discussed in Appendix C, Section C.1.1 of the EIS, both fatal and non-fatal

truck accidents were considered when assessing impacts from potential radioactive

releases. The vehicle-related fatalities reported were the direct result of physical trauma

related to potential accidents. As discussed in Appendix C, Section C.2.4.3, neutral

weather conditions were used for the transportation risk assessment because the exact

time and location of an accident cannot be known ahead of time and neutral weather

conditions prevail for more than 50% of the time in the United States where shipments may

occur. Because the shipment distances on-site are much shorter than the off-site routes,

low on-site speed limits, and the sparse population density, the transportation risks on-site

at the Savannah River Site for the material considered in the EIS are not significant

compared to the transportation risks presented in the EIS.

J.3.20.16 Comment: 114-012

Comment: Emergency response to rail or highway accidents must be well-prepared and

rapid. Delays in response to accidents which involve the release of radioactive material

would expose unknown numbers of people to negative health effects. In 1996, a

Department of Energy (DOE) Transport and Safeguards Division Safe Secure Transport

(SST) trailer carrying nuclear weapons slid off the road and rolled over in rural Nebraska.

Four hours elapsed before DOE headquarters was notified, and it was 20 hours before a

Radiological Assistance Program team determined there was no release. A similar delay in

response to a plutonium-MOX fuel accident could make effective emergency response

dangerous and clean-up impossible.

Response: Any accident scene involving vehicles containing plutonium or MOX fuel is

expected to be promptly closed to vehicle traffic. As discussed in Appendix C, Section

C.2.3 of the EIS, such shipments would be made using the SafeGuards Transporter (SGT)

with armed federal officers on-board as well as in escort vehicles. The SGT and escort

vehicles would contain advanced communications equipment and be monitored 24-hours-aday. Any accident would be identified in real-time and the federal officers at the scene

would be able to take appropriate measures to ensure the safety of the public as well as the

security of the shipment.
Appendix J

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J.3.21 MOX Fuel Use

J.3.21.1 Comments: 2-002 30-003 71-009 92-003

12-004 47-005 72-006 105-007

13-004 65-003 77-002 114-004

24-004 67-002 90-002 114-010

Comment: In general, using MOX fuel in reactors was considered to be experimental and

unsafe. Scientists are not in agreement as to the safety of this process. It was stated that

the use of MOX fuel in a reactor would result in a smaller safety margin and was difficult to

control which could result in serious accidents at a higher likelihood. Reactors were not

designed to handle MOX fuel. Specific technical concerns were raised which included the

lower delayed neutron fraction with plutonium, the reduced control rod effectiveness with

using MOX fuel, a positive moderator temperature coefficient, increased fission gas

production, twice the tritium production, lower melting temperature of MOX fuel, and

formation of hot spots within a mixed core of MOX fuel and low enriched uranium fuel. It

was noted that the first three issues were significant causes of the Chernobyl accident. It

was questioned how emergency crews could respond to a reactor accident involving MOX

fuel, given that plutonium is hotter than uranium. It was stated that the moderator

temperature coefficient of reactivity is an example where European MOX fuel experience

does not apply. Concern was expressed that modifications to reactors and increased

monitoring would be required if MOX fuel was used in reactors. The reactor use, MOX fuel

transportation, and spent fuel disposal impacts should assume the maximum throughput. It

was further suggested that the proposed MOX fuel fabrication facility should not be

authorized until problems with reactor use are resolved.

Response: All U.S. light water power reactors are designed to produce power from fuel

that includes plutonium. By the end of a fuel cycle, light water reactors burning low enriched

uranium (LEU) fuel produce a significant percentage of the energy in the reactor core from

the fissioning of plutonium that was produced during normal operation from the irradiation of

uranium-238. This is reflected in the design basis for the power plants. 

Moderator temperature coefficient (MTC) is more strongly influenced by the choice of

moderator (which is the same for MOX or LEU fuel) than the differences in the MOX and

LEU fuel types considered here. In any event, the delayed neutron fraction, control rod

worth, reactor vessel embrittlement, shielding analysis, MTC effects, fuel performance and

source terms issues are typical of the issues that will be addressed in the NRC staff’s safety

review of any future amendment request by a reactor licensee to use MOX fuel. The results

of the future site specific safety reviews will be considered, together with any future site

specific National Environmental Policy Act (NEPA) evaluations in determining whether to

authorize specific reactors to use 40% MOX fuel cores.

In planning for these reviews, the NRC has initiated a research program which includes

developing tools to evaluate the neutronic and material behavior of MOX fuel, and to

estimate source terms from potential accidents involving MOX fuel. Technical concerns,

such as those mentioned in the comments, would be evaluated during the site-specific
Appendix J

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safety review. Any modifications to the reactor, that would be required to ensure safety,

would be determined within the scope of the NRC staff’s future reviews of a specific request

to use MOX fuel. The NRC believes that analyses performed to date are sufficient to

reasonably estimate and bound the impacts of using MOX fuel. Reactor specific issues are

beyond the scope of this EIS. However, the NRC staff believes that analyses performed to

date are sufficient to reasonably estimate and bound the impacts of using MOX fuel for

purposes of making a decision whether to authorize construction of the proposed MOX

facility.

As discussed in Section 4.4.3 of the EIS, the impacts of using MOX fuel were tiered from an

assessment presented in the DOE’s Surplus Plutonium Disposition EIS (Section 4.28 and

Appendix K.7 of that document). While weapons grade plutonium MOX fuel has not been

used in reactors in the United States on a commercial scale, the impacts of doing so have

been estimated assuming MOX fuel replaces about 40 percent of the low-enriched uranium

(LEU) fuel. The DOE’s analysis of using MOX fuel in reactors concluded that the

operational safety would be essentially the same as using LEU fuel. The DOE determined

that, depending on the accident, the risk of a latent cancer fatality among the general public

associated with a potential accident, could decrease by up to 7% or increase by up to 14%.

J.3.21.2 Comments: 91-002

91-003

98-006

Comment: Water use issues relative to using MOX fuel were raised. Water would be used

in the MOX processing to make MOX fuel, but water would also be used at nuclear power

plants. Nuclear power plants were considered to be a water-intensive and toxic technology

that imposes major long-term social, environmental, and economic costs. For example, the

Hatch Plant withdraws 57 million gallons a day from the Altamaha River and returns only 24

million gallons a day. With ever-rising demands for water supply in this rapidly growing

state, particularly during extended drought, such water intensive practices are increasingly

unjustifiable, imposing avoidable burdens on many other sectors. Water resources are

limited and discussions on how this precious resource should be protected are currently

being debated in the Southeast. The link between energy and water resources is profound. 

At the national level, the electric industry follows closely on the heels of irrigation as the

largest water user in the U.S. Yet, there is no discussion in the DEIS on the impacts of

nuclear power production, which the MOX program will support the possible advancement

of, on the region’s water supply.

Response: Nuclear reactors use water, regardless of whether they use conventional lowenriched uranium (LEU) fuel or a combination of LEU fuel and MOX fuel. As discussed in

Section 4.4.3 of the EIS, the Department of Energy’s analysis of using MOX fuel in reactors

concluded that, during normal operations, the impacts would be the same as using LEU

fuel. Specific water use impacts at any particular reactor are beyond the scope of this EIS.
Appendix J

J-126

J.3.22 Cumulative Impacts

J.3.22.1 Comments: 72-008

39-001

Comment: There was concern about the decision to add new radioactive missions to the

Savannah River Site (SRS) which has already been weakened by previous and ongoing

exposures. It was stated that the SRS has the most radioactivity of any Department of

Energy site nationally and that millions of gallons of high level radioactive waste are stored

there. It was also stated that the proposed mitigation steps do not address the ongoing

routine and repeated exposure. It was felt that the Nuclear Regulatory Commission

analysis did not fully express the cumulative and synergistic nature of the situation.

Response: Cumulative radiological dose to the public and SRS workers from normal

operations of the proposed facilities, existing SRS operations, past operations, and

reasonably foreseeable future actions is presented in Section 4.5.1.1 of the EIS. This

analysis indicates that MOX operations would contribute a relatively small incremental dose

to the public and to workers and that the number of latent cancer fatalities that would result

from cumulative radiological dose is less than one for the public (including the maximally

exposed individual) and about 1 for workers.

J.3.22.2 Comment: 89-054

Comment: The DEIS references the Yucca Mountain environmental impact statement for

high latent cancer fatalities from “general transportation” when the historical results are low. 

However, this reference cannot be found. Please verify the numbers used.

Response: The numbers presented in the EIS are correct. Please see page 8-90 of the

Yucca Mountain environmental impact statement.

J.3.22.3 Comment: 89-055

Comment: Presuming the MOX shipments in line 16 of Table 4.27 of the DEIS are

supposed to be the same as the totals presented in Table 4.20, the numbers for the

population dose do not agree. If the information is supposed to be the same, it is

suggested that the category be relabeled to more accurately reflect the nature of the

information (e.g., All shipments for the MOX program). 

Response: The numbers in Table 4.27 in the DEIS (Table 4.28 in the FEIS) were correct.

The numbers have been revised in the FEIS to reflect changes made in the TRU waste

shipments in ER Revision 5. A footnote has been added for clarity as suggested by the

commenter.
Appendix J

J-127

J.3.22.4 Comment: 93-013

Comment: It is not correct to assume that the proposed MOX facility and Waste

Solidification Building construction are “bounding,” since the movement of contaminated

particulate off-site and movement of contamination from soil into ground water are both

cumulative, and construction of all three facilities will result in one or both of these events. It

should be necessary to assess the impacts of all three and look at them cumulatively, even

though the Pit Disassembly and Conversion Facility (PDCF) construction may lag behind

the other two.

Response: As discussed in Section 5.2.8 of the FEIS, the Nuclear Regulatory Commission

is concerned that the spoils pile currently located on the proposed MOX site may be

contaminated. Although DCS has conducted initial screening that does not indicate

contamination, removal of the spoils pile constitutes a significant earthmoving activity and a

potential source of exposure to construction workers. In contrast, significant earthmoving

operations are not anticipated for the PDCF and Waste Solidification Building sites. The

spoils pile is not considered a significant source of potential contamination to the

environment. Construction of the MOX and associated facilities would not be expected to

mobilize any contaminated particulates off-site. Dust control measures during construction

(Section 5.2.4 of the FEIS) would limit migration of any contaminated particulates. The

groundwater beneath the proposed MOX facility site is already contaminated. Past

activities at the Savannah River Site do not indicate that the area where the spoils pile soils

were excavated is a significant source of existing contamination; and therefore, would not

be expected to be a significant source of groundwater contamination.

J.3.22.5 Comment: 86-072

Comment: The “SRS baseline” concentrations summarized in Table 4-23 do not represent

regional air quality. They are only representative air monitoring data. The “SRS baseline”

data are a hypothetical set of values that are based on modeling maximum potential

emissions of Savannah River Site (SRS) sources and are applicable only as a screening

level for evaluating and managing Savannah River Site air permits. This section of text

must be revised accordingly. In addition, footnotes to the columns “SRS Maximum” in

Tables 4-6, 4-8 or the column “SRS Baseline” in Table 4-23 should be modified to state that

the listed values are hypothetical levels based on maximum potential (i.e., permitted)

emissions from SRS sources and do not necessarily quantify actual air quality conditions. 

Response: The text in Section 4.5 of the FEIS has been modified as suggested by the

commenter. In addition, the footnotes to Tables 4.6, 4.8, and 4.24 (DEIS Table 4.23) have

been modified.

J.3.22.6 Comment: 96-037

Comment: The cumulative impacts should be evaluated with respect to increasing or

decreasing existing inequities.
Appendix J

J-128

Response: The cumulative impacts associated with the construction and operation of the

proposed facilities are presented in Section 4.5 of the EIS. The impact evaluation

considered the effects of past, present, and reasonably foreseeable future actions in the

Savannah River Site region. High adverse impacts were not identified for any impact

category in this cumulative impact analysis. Accident impacts are not considered in the

cumulative impact assessment. Additional information regarding risks to low-income and

minority communities from accidents can be found in Comment J.3.19.5.

J.3.22.7 Comment: 89-053

Comment: It would be helpful to the reader in Table 4.25 of the DEIS to include capacities

of treatment facilities and storage capacities. The table provides no way to judge the

significance of these numbers. 

Response: Waste treatment and storage capacities have been added to Section 4.5 of 

the FEIS as suggested.

J.3.23 Cost-Benefit

J.3.23.1 Comments: 5-007 12-003 38-002 76-003

 8-005 30-004 44-004 79-004

10-004 32-005 45-007 108-002

10-019 35-001 76-002

Comment: The project will waste valuable tax dollars. It was questioned whether spending

money on upgrading nuclear reactors that would use MOX fuel was money well spent. It

was alleged that Duke was receiving a government subsidy (favoring nuclear energy) to

produce electricity. Duke would also be allowed to turn around and sell the electricity

generated in part from the subsidy, to the citizens of Georgia, South Carolina, and North

Carolina. It was argued that the citizens should receive the electricity for free.

There was disagreement about exactly who was bearing the costs of the proposed action

and who was receiving the benefits. It was stated that the citizens of Georgia and South

Carolina bear the environmental impacts, but others received the benefit of the electricity. 

Another point of view was expressed that the nation was bearing the financial costs of the

proposed action, while the local communities were receiving the economic benefit. 

Likewise, others indicated the nation was bearing the financial costs of the proposed action,

so that a small number of shareholders in the nuclear industry could receive a large benefit.

Response: There are both costs and benefits resulting from the proposed action to design,

construct, and operate a MOX Fuel Fabrication Facility. The benefits are experienced at

both the national and regional level. At the national level, the benefits include improving

security by reducing the risk of plutonium falling into the hands of terrorists. In addition,

processing plutonium into MOX fuel benefits the environment by reducing the risk of

contamination and it reduces the risk to human health and safety at the current storage
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sites. When presented with the cost of maintaining storage of plutonium, processing the

plutonium into MOX fuel results in a cost savings to the federal government. At the regional

level, the benefits include a boost to the local economy and employment opportunities

associated with the construction and operation of the MOX facility. 

As noted in the comments, benefits are also experienced in the private sector. After

determining that, to comply with the United States-Russia Agreement, excess plutonium

should be disposed of by making MOX fuel, the Department of Energy concluded that the

most cost effective means of implementing the program was to hire a contractor. The

contractor selected, DCS, was chosen from a series of competitive bids from qualified

companies and is being compensated according to the costs it will incur in constructing and

operating the proposed facility. Reactors irradiating MOX fuel will not receive the fuel for

free, as alleged in the comments. Rather, the reactors will purchase fuel from the

Department of Energy (DOE) at a set rate.

There are also costs at the national and regional level. The national costs are primarily the

cost of constructing and operating the proposed MOX facility. The overall cost of the

program is approximately $4.1 billion (2003 dollars). However, the DOE will receive a

monetary credit for the fuel sent to commercial reactors that would be used to generate

electricity. The fuel credits (or money paid by the reactors for fuel use) amount to $1.0

billion over the life of the project. Thus, the overall cost of the project is reduced from

approximately $4.1 billion to $3.1 billion. The regional costs include potential impacts that

an accident at the proposed facilities would produce. Additionally, routine operations of the

proposed facilities would produce an annual latent cancer risk of about 1 in 250 million for

the maximally exposed individual of the public. The environmental impacts, under normal

conditions, are considered to be small; therefore, they do not constitute a significant

regional cost.

For a full discussion of costs and benefits, see Section 4.6 of the EIS. 

J.3.23.2 Comment: 48-004

Comment: The cost information presented in the DEIS is very confusing and vague. The

cost of the MOX program is estimated to be $3.8 billion. However, the cost was not broken

down into research and development, construction cost, operation cost. It was suggested

that the cost should be clearly stated. The DEIS did elude to a discussion on the

decommissioning cost which gives a range. The fact the Department of Energy is trying to

get $415 million in fiscal year 2004 is going to draw some attention and requesting

$650 million for the overall program is going to get some scrutiny.

Response: Additional breakdown on the components of the costs can be found in Report

to Congress: Disposition of Surplus Defense Plutonium at Savannah River Site, produced

by the National Nuclear Security Administration (NNSA 2002), which provides more detail

on project cost. Decommissioning costs were estimated using data from a number of

studies of other large-scale nuclear fuel-cycle facilities. Details on how these estimates

were made can be found in Section 4.3.6.3 of the EIS.
Appendix J

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J.3.23.3 Comment: 89-056

Comment: The DEIS states that the benefits to national security are substantial but not

quantifiable. The costs associated with continued storage of this material are quantifiable;

avoiding these costs should be mentioned as a benefit in Section 4.6.1.

Response: Section 4.6.1 of the FEIS has been changed to reflect this comment.

J.3.23.4 Comment: 89-057

Comment: Section 4.6.3.2 of the DEIS discusses regional benefits in terms of money

entering the local economy for labor associated with the construction and operation of the

proposed facilities, and the multiplier effect this money has on the regional economy. The

same is true for the national economy but no mention is made of these effects in this

section. 

Response: Because of the preliminary nature of the data needed to calculate national

impacts, no quantitative estimate of the impacts of construction and operation of the

proposed MOX facility on the national economy was included in the EIS. The text in

Section 4.6.1 of the FEIS has been changed to provide a qualitative discussion of the

national economic benefits of the proposed action to clarify the issue.

J.3.23.5 Comment: 89-059

Comment: The DEIS references the costs of continued storage (i.e., no-action alternative)

from the Department of Energy’s Surplus Plutonium Disposition EIS. However, according to

the MOX ER, the National Nuclear Security Administration (NNSA 2002) estimated the

costs associated with continued storage to be approximately $246 million per year. One of

the national benefits associated with this program should be the avoided safeguard and

storage costs. If the no-action alternative were to store the plutonium for 50 years, the

estimated storage costs would exceed $12 billion while the cost of disposition is estimated

to be $3.85 billion as discussed in Section 4.6.2. 

Response: Estimates of the avoided cost of continued storage have been added to

Section 4.6.2 in the FEIS to reflect this comment.

J.3.23.6 Comment: 89-060

Comment: In the DEIS, it was mentioned that the Surplus Plutonium Disposition (SPD) EIS

was used as a reference for data pertaining to the proposed MOX facility. However, it is not

clear where the data is taken from in the SPD EIS. For the proposed MOX facility,

employment estimates would most likely have come from the MOX ER since this included

more recent information. 

Response: The SPD EIS was used to establish the relationship between direct (on-site)

and indirect (off-site) employment for the construction and operation of a MOX facility. This
Appendix J

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was because the MOX ER only calculated direct employment impacts, with a qualitative

description provided for the indirect socioeconomic impacts of the facility. As data on both

direct and indirect impacts of a MOX facility at the Savannah River Site were provided in the

SPD EIS, these data were used in this EIS to calculate indirect impacts. Text has been

added to Section 4.6.3.2 of the FEIS to clarify the issue.

J.3.23.7 Comment: 105-011

Comment: On page 4-83, line 30 & 31, the DEIS states that, “Therefore, continued storage

would result in higher annual impacts.” This statement appears incorrect considering the

activities of storing the plutonium in hardened bunkers without touching or processing it

when compared to all the plutonium transportation, processing, reactor use and removal to

Yucca Mountain associated with the proposed action.

Response: The impacts for the no-action alternative (i.e., continued storage of surplus

plutonium at existing DOE sites) were previously evaluated by the Department of Energy

(DOE) in the Surplus Plutonium Disposition (SPD) EIS. As discussed in Section 4.2.1 of the

EIS, the impacts in this EIS for the no-action alternative are essentially the same as those

evaluated by DOE. Some of the impacts for the no-action alternative presented in this EIS

represent impacts for the entire DOE site at which the surplus plutonium is currently stored. 

Text has been added to Sections 4.2.1 and 4.6.2 of the FEIS to clarify this point.

J.3.23.8 Comments: 87-006

89-058

Comment: The 2002 cost estimates do not reflect the costs of additional process time

needed for the 34 metric tons (37.5 tons) of plutonium compared to the 25.6 metric tons

(28.2 tons) the cost of handling additional purification of untreated plutonium from the

immobilization facility, and the cost of the additional waste streams from the proposed

facility. The discount rate used to normalize the costs in 2001 dollars was not specified in

the cost estimate report. 

Response: The NRC used cost estimates provided in the 2002 National Nuclear Security

Administration report which does reflect the costs associated with processing 34 metric tons

of plutonium, including the removal of impurities and treatment and disposition of associated

wastes. No information is presented in the report on the discount rate used to normalize the

costs in 2001 dollars. 

J.3.23.9 Comment: 66-004

Comment: The DEIS states that any impacts associated with the transportation of fresh,

unirradiated MOX fuel, including impacts on property values, will be minimal. The cost

associated with changes in property values does not appear to be well addressed in the

DEIS. 
Appendix J

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Response: The cost impacts of the transportation of MOX fuel, such as impacts on

property values, were not considered in the DEIS due to uncertainty surrounding the

transportation routes that would be used, and the timing and quantity of MOX shipments.

Text has been added to Section 4.6.3 of the FEIS to clarify the basis for not considering

impacts along transportation routes.

J.3.23.10 Comment: 43-004

Comment: The treatment of time line effects of costs and benefits in the DEIS was

questioned. Typical cost benefit analysis reduces the impact of future costs in proportion to

their distance away from the present time. It was suggested that environmental resources

will be worth more in the future, not less. If one considers the worth of environmental

resources in the present by applying a discount method, the worth of the environmental

resources would be very much reduced in value compared to what they are likely to actually

be worth in that future time. The DEIS needs to consider alternative methods for evaluating

costs and benefits.

Response: Cost benefit analysis typically uses a positive discount rate in order to include

the effects of time in the valuation of the overall costs and benefits of a project. This means

that the valuation of future costs and benefits would be larger the further away from the

present time these impacts occur. An estimation of the present value of all costs and

benefits is then made to establish the value of all future costs and benefits back in time by

expressing them in terms of their monetary value in the current year. As the measurable

impacts on the environment and human health during construction and normal operation of

the proposed MOX facility would be small, an estimation of the present value of these

impacts was not undertaken for the EIS. Annual monetary costs of facility construction and

operation are expressed in constant 2003 dollars, which takes into account the projected

impacts of inflation on total life-cycle project cost.

J.3.23.11 Comments: 53-001

58-004

66-002

Comment: The EIS does not include an analysis of the economic impacts of accidents. 

This would include costs associated with victim health recovery, costs to farmers from

interdiction of crops, and the costs of cleaning up contaminated lands.

Response: Human health risks associated with accidents are discussed in Section 4.3.5 of

the EIS. The socioeconomic impacts of accidents associated with the proposed MOX

facility were not estimated in the EIS, because accidents are not expected to have a

significant economic impact on the communities surrounding SRS. Emergency response

activities associated with a release from the facility would be handled by local emergency

response and health authorities already prepared for accidents at SRS, with no resulting

additional burden on local community financial resources. In the case of the most serious

accidents postulated for the proposed facilities, the amount of radioactive material

deposited per unit area would be relatively small and would be limited to the area under the
Appendix J

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plume. Any interdiction of crops as a result of the deposition of radioactive material would

be a limited, one-time event, and if it were to occur at all, would only affect a small number

of farm communities. Text has been added to Sections 4.6 and Appendix D in the FEIS to

clarify the issue. 

J.3.24 Mitigation

J.3.24.1 Comments: 86-005 89-064

89-013 89-066

89-063

Comment: The DEIS lists 43 highly specific mitigative actions. Many of these mitigation

measures simply duplicate state or federal agency regulations with which DCS is already

required to comply. Doing what is required by law or common practice is not mitigation. 

Mitigation occurs when, if there are significant impacts, an action is taken to lower those

impacts to a more acceptable level. The DEIS should be modified to state that DCS will

comply with the regulations of the appropriate regulatory agency. The mitigation measures

discussed in Chapter 5 and presented in Table 5.1 with the Nuclear Regulatory Commission

(NRC) as the proponent are in general excessive relative to the postulated impacts and may

not be necessary. Therefore, it was recommended that these proposed mitigation

measures be reconsidered. In addition, each mitigation measure should specify who is

responsible for taking action or assuring that action is taken. Clarifying language should

precede the table, or additional columns should be added to the table, to indicate which

entity is responsible for 1) implementation and 2) verification of completion, of the

mitigation.

Response: Under 40 CFR 1500.2(f), federal agencies shall to the fullest extent possible

use all practicable means consistent with the requirements of the National Environmental

Policy Act (NEPA) and other considerations of national policy to avoid or minimize any

possible adverse effects of their actions on the quality of the human environment. The

Council on Environmental Quality (CEQ) definition of mitigation is provided in EIS

Chapter 5. Mitigation includes measures that minimize impacts by limiting the magnitude of

the action, measures that rectify the impact of an action, measures that reduce or eliminate

the impact over time, and measures that compensate for the impact. In addition, CEQ’s 40

most asked questions states that all relevant, reasonable mitigation measures that could

improve the project are to be identified, even if they are outside the jurisdiction of the lead

agency, and thus would not be committed as part of the Record of Decision. Identifying the

full range of mitigation measures serves to alert agencies or officials who can implement

these extra measures, and will encourage them to do so. Therefore, the NRC believes it is

appropriate to include mitigation measures that are required by the regulations of the other

federal agencies. 

Text has been added to clarify mitigation measures that are required by laws and

regulations, those that are suggested by DCS as good practices, and those that are

suggested by the NRC. Generally, it is the position of the NRC that the applicant is
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responsible for assuring that all necessary mitigation measures are fully implemented and

completed. 

The NRC staff has reviewed the mitigation measures and has concluded that no additional

mitigation measures are required beyond the regulatory requirements and those measures

identified by DCS. 

J.3.24.2 Comment: 86-074

Comment: In Table 5-1 of the DEIS, grading the site to a uniform elevation is an inherent

aspect of the MOX facility design (the grading would be the same regardless of the MOX

facility location). Consequently, the grading is incorrectly identified as a “mitigation.” 

Response: The Nuclear Regulatory Commission disagrees with the comment. If the site

was not graded, extensive erosion is possible because of the relatively steep topography. 

Grading minimizes the potential for erosion and is thus a mitigation activity.

J.3.24.3 Comments: 86-075

86-076

86-077

Comment: DCS’s MOX ER (page 7-13, Table 7-I) specifically notes that a Stormwater

Pollution Prevention Plan will be developed for the proposed MOX facility, which is more

comprehensive and responsive to South Caroline Department of Health and Environmental

Control (SCDHEC) enabling regulations. The DEIS states that a Sediment Control Plan and

Spill Prevention Control and Countermeasures Plan would be developed prior to

construction. A Spill Prevention Control and Countermeasures Plan would be developed

prior to operating the proposed MOX facility. The correct title for the plan that would limit

sediment in the surface waters and control spills during construction is the Stormwater

Pollution Prevention Plan. The mitigative action identified by the DEIS should be limited to

implementation of a Stormwater Pollution Prevention Plan in compliance with SCDHEC

regulations. 

Response: The Nuclear Regulatory Commission staff reviewed the elements of the

Stormwater Pollution Prevention Plan and concluded that it would be sufficient to mitigate

potential spills during construction. A Stormwater Pollution Prevention Plan is required by

the South Carolina Department of Health and Environmental Control prior to construction. 

The Plan would minimize and avoid soil and surface water contamination from spills or other

accidental released during construction. The text in Chapter 5 of the FEIS has been revised

to delete reference to the Sediment Control Plan. Text has also been added to state that 

appropriate mitigation measures during construction would be chosen at the time of the spill

event or release in conjunction with the Stormwater Pollution Prevention Plan. 
Appendix J

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J.3.24.4 Comment: 86-090

Comment: Section 5.2.2, page 5-7, lines 18-27 of the DEIS speculates what resources

might be impacted if any MOX structures extended into groundwater. The fact is that the

structures do not extend to groundwater. Speculation about what might happen if the

structures should extend to groundwater should be removed from the DEIS. 

Response: The text in Section 5.2.1 (DEIS Section 5.2.2) was revised to include sand

filters as an example of structures that could impact groundwater.

J.3.24.5 Comment: 86-078

Comment: The South Carolina Department of Health and Environmental Control

(SCDHEC) does not specify requirements for reduction of fugitive construction dust. As

noted in the MOX ER, DCS will have a Construction Emissions Control Plan which will

implement a number of different good engineering practices to reduce fugitive dust

emissions. The MOX ER does not identify specific actions or emissions reductions. The

mitigative action specified in the DEIS Table 5-1 and ES-1 should be limited to compliance

with appropriate SCDHEC air quality regulations. 

Response: The text in Section 5.2.4 and Table 5.1 has been revised to state that DCS will

have a Construction Emissions Control Plan which will implement a number of good

engineering practices to reduce fugitive dust emissions.

J.3.24.6 Comment: 86-079

Comment: The statement in Table 5-1, page 5-2, lines 46-49 of the DEIS was questioned. 

The MOX ER identifies that the concrete batch plant will be subject to the provisions of a

South Carolina Department of Health and Environmental Control (SCDHEC) air quality

permit. The concrete batch plant will meet the conditions of that permit. The mitigative

action specified in the DEIS should be limited to compliance with appropriate SCDHEC air

quality regulations. 

Response: The cementation process would be part of the operation of the Waste

Solidification Building (WSB), not the construction of the WSB as indicated in the comment. 

The text in Section 5.2.4 and Table 5.1 has been corrected to note that the reduction would

occur during operation of the WSB. 

J.3.24.7 Comments: 86-085

86-097

Comment: The mitigation actions associated with National Historic Preservation Act

(NHPA) activities were questioned. Information provided by DCS to the Nuclear Regulatory

Commission (NRC) on December 12, 2002, demonstrated that the State Historic

Preservation Office (SHPO) has agreed that all mitigation action is complete. No monitoring

is required. Inadvertent discoveries will be handled in accordance with Federal Law and the
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Savannah River Site Programmatic Memorandum of Agreement (PMOA). Because the

NRC and the Department of Energy (DOE) have designated the DOE as the lead agency

for mitigation under the NHPA, NRC specified mitigation actions are not appropriate. The

mitigative action specified in the DEIS should be limited to compliance with DOE PMOA

policies for archaeological management of construction activities. 

Response: The NRC agrees with the comment that the DOE is responsible for compliance

with the PMOA for archaeological management during construction. However, past

experience at construction sites suggests that the mitigation actions identified by the NRC in

the EIS (e.g., periodic monitoring, awareness training) are potential means to ensure nearby

archaeological sites would not be adversely affected either indirectly from erosion or directly

from disturbance by the workforce. The comment correctly states that the letter from the

SHPO indicates mitigative action is complete for the two eligible archaeological sites;

however, the letter from the DOE to which the SHPO is responding, indicated that some

monitoring would occur during construction. The text has been revised in EIS Section 5.2.9

to reference both letters (Long 2002 and Gould 2002) and to specify that the monitoring

would focus on the removal of fill on the site areas. A similar text change on monitoring the

removal of fill has been made to Table 5.1, in addition to deleting the NRC as a proponent

for the monitoring of the two eligible sites. 

J.3.24.8 Comment: 10-014

Comment: The DEIS states that “issues related to general emergency preparedness of

communities are outside the scope of this EIS.” The DEIS also mentions that

“consequences on human health would be mitigated by following SRS emergency

procedures.” It was requested that a copy of the Savannah River Site (SRS) emergency

procedures be provided to citizens in Savannah and other communities throughout the

Savannah River corridor. Concerns was expressed that the SRS emergency procedures

would not be protective of the public. 

Response: The DOE is responsible for the SRS emergency response plan, and it is not a

publically available document. SRS coordinates its emergency preparedness with local and

State agencies, including conducting drill and community education. 

J.3.24.9 Comment: 89-065

Comment: The DEIS Section 5.2.2, page 5-8, lines 7-9 should be reworded as follows for

clarity: “Direct impacts to groundwater could occur if there were a failure in the

underground pipeline carrying the liquid high-alpha activity waste stream from the proposed

MOX facility’s ... .”

Response: The text in Section 5.2.1 of the FEIS (DEIS Section 5.2.2) has been modified

as suggested by the commenter. 
Appendix J

J-137

J.3.24.10 Comment: 89-067

Comment: In Section 5.2, the DEIS states that DCS shall add appropriate revisions of the

Savannah River Site (SRS) Emergency Response Plan for chemicals identified as

presenting moderate or high risks to workers. It is not clear that this measure is within the

jurisdiction of the Nuclear Regulatory Commission.

Response: Upgrading of the SRS Emergency Response Plan to include chemicals posing

moderate or high risks to workers is a mitigation action that is appropriate for protection of

DCS and SRS employees from an accidental release. DCS has committed to establishing a

protocol with the Department of Energy — to be submitted by DCS as part of any request

for a license to possess and use special nuclear material — to integrate DCS’s emergency

plans with the existing SRS emergency preparedness program. Because this is a

commitment made by DCS, relating to the proposed MOX facility, the Nuclear Regulatory

Commission does have regulatory authority to enforce this commitment. 

J.3.24.11 Comments: 86-080

86-093

Comment: Section 5.2.3 of the DEIS discusses mitigation measures for ecological

resources. The MOX ER 4.6 describes the ecological habitat and the habitat surveys

conducted prior to construction activities. MOX ER Appendix A, pages A-25 and A-26

provides letters of negative declaration from the U.S. Fish and Wildlife Service that the MOX

facility construction and operation will not affect resources under the jurisdiction of the

U.S. Fish and Wildlife Service. All necessary ecological surveys are complete. No sensitive

species or nests of migratory species are present. These precautionary and mitigative

actions presented in the DEIS are misleading and unnecessary.

Response: The U.S. Fish and Wildlife Service has raised no objections and has stated that

the proposed action will have no effect on resources under its jurisdiction (letter dated

June 20, 2001, from L. Duncan [U.S. Fish and Wildlife Service] to A.B. Gould [DOE]). The

mitigation commitment described in the DEIS for surveys of plants and nests of migratory

birds, sensitive species, and habitats has been deleted. 

J.3.24.12 Comments: 86-081

86-083

Comment: Statements in Section 5.2.1 and Table 5-1 of the DEIS that measures shall be

taken to protect trees not selected for removal, that any trees or other landscape features

accidentally scarred or damaged should be replaced and that environmental supervisors

shall be present during vegetation clearing to ensure that impacts are held to a minimum

are misleading.

As noted in DEIS 3.6.1 (pg.3-34) the Savannah River Site (SRS) forests are managed by

the U.S. Forest Service. The removal of trees and protection of trees not designated for

removal will be under the direction of the U.S. Forest Service. The mitigative action
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specified in the DEIS should be limited to compliance with appropriate U.S. Forest Service

regulations.

Response: Section 3.6.1 of the EIS states that the forests on the SRS are managed for

timber production and that the U.S. Forest Service harvests the trees. However, DCS

should still take action at the construction site to prevent the workforce from removing

vegetation in excess of that needed for construction clearing. 

J.3.24.13 Comment: 86-082

Comment: The statement in Section 5.2.1 and Table 5-1 of the DEIS that “The loss of the

existing storm-water basin near the southern boundary of the proposed site would be

compensated for by construction of a new basin that would provide more viable aquatic

habitat” is misleading. As noted in Attachment 14a of the letter from P. Hastings to the

Nuclear Regulatory Commission Document Control Desk, the U.S. Army Corps of

Engineers concluded that the existing storm-water basin is not part of the waters of the

United States. Consequently, it is not appropriate to specify any mitigative action.

Response: The staff agrees with the commenter that compensation for loss of the existing

stormwater basin is not an appropriate mitigative action. This action was addressed in

Section H.3.1.2 of the EIS simply to point out the small impacts that would occur to aquatic

ecological resources from construction. The mitigation measure to compensate for loss of

the stormwater basin has been deleted from the FEIS. 

J.3.24.14 Comment: 86-084

Comment: The statement in Section 5.2.1 and Table 5-1 of the DEIS that “Reclamation

plans shall be developed for laydown areas and other construction areas that will not be

occupied by structures, parking lots, or roads. Reclamation will include removal of all

temporary construction features, stabilization of soils, and reseeding with appropriate plant

species” is misleading. Property beyond the 41-acre proposed MOX facility site is managed

under the DOE jurisdiction for the Savannah River Site. Land reclamation will be in

accordance with DOE directives. The mitigative action specified in the DEIS should be

limited to compliance with appropriate DOE policies for reclamation of construction areas.

Response: The mitigation measure described in Table 5-1 and in Section 5.2.3 of the FEIS

(DEIS Section 5.2.1) has been revised to state that site restoration (e.g., stabilization of

soils and revegetation) shall be done in compliance with appropriate DOE policies for

reclamation of construction areas.

J.3.24.15 Comment: 86-092

Comment: The statement in Section 5.2.3, page 5-8 of the DEIS that “For example, a

portion of the construction activities for the proposed MOX facility would take place on a

former spoils pile used for previous F-Ares construction” is incorrect. The proposed MOX
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facility will not be constructed on a former spoils pile; the spoils pile will be removed prior to

construction.

Response: The text in Section 5.2.3 of the FEIS has been modified to indicate that a

portion of the proposed MOX facility site had been previously used for storage of spoils,

rather than implying that construction would occur on the spoils pile.

J.3.24.16 Comment: 86-086

Comment: The October 29, 2002, correspondence from DCS to the Nuclear Regulatory

Commission responding to requests for additional information included the results of the

Plutonium Project Pre-construction Environmental Report, including the results of soil

analyses at the proposed MOX facility site. The DEIS should have included the results of

this report which confirm the previous DCS conclusion in the MOX ER that there are no

significant concentrations of radioisotopes or chemicals in the soil that would be hazardous

to construction workers health. Consequently, the mitigative action is misleading and

unnecessary.

Response: Text has been added to section 4.3.1 of the FEIS to summarize the results of

the Preconstruction report. Although no significant contamination was detected, further

sampling may be necessary because the study did not include samples to the depth that will

be required for building foundations in the area of the spoils pile, and also did not include

testing for some chemical contaminants of potential concern. Therefore, the potential

mitigation action has been retained. 

J.3.24.17 Comment: 86-096

Comment: The word “on-site” should be removed from page 5-11, line 23-24 of the DEIS. 

Treatment can occur “off-site” as well. 

Response: The text in Section 5.2.7 of the FEIS was revised and the referenced word was

removed.

J.3.24.18 Comment: 86-098

Comment: The proposed MOX facility stack height is incorrect on page 5-14, line 7 of the

DEIS. The revised MOX ER increased the height of the structure to 120 feet. 

Response: The text in Section 5.2.10 of the FEIS has been revised to state that the height

of the tallest structure would be 120 ft (37 m) above the existing grade.

J.3.24.19 Comment: 27-001

Comment: In Section 2.2.4.2.3, the DEIS does not provide information regarding

monitoring buried and exposed pipes for leaks that could result in discharge of liquid waste
Appendix J

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to ground water. Monitoring/detection, response, and enforcement protocols related to pipe

integrity and leaks should be included in the DEIS. 

Response: Staff evaluated the impacts of an accidental release from liquid waste pipes in

Section 4.3.5.4 of the EIS. As described in this section, pipes carrying stripped uranium

and high alpha activity wastes would be double-walled stainless steel pipes designed to

withstand natural phenomena hazards, and for which the Savannah River Site Spill

Prevention Control and Countermeasures Plan applies. The text has been revised in the

FEIS to include the ability of the transfer lines to withstand external man-made hazards. 

The text has also been revised to include the applicant’s commitment to monitoring of the

annular space inside the pipes for leaks, as described in the Construction Authorization

Request.

J.3.24.20 Comment: 97-002

Comment: The DEIS indicates the proposed action (to build and operate the proposed

MOX facility) has some impacts but concludes that the impacts are acceptable regardless of

the severity of the impact. This comes across as a non-sequitur. The DEIS should be

extremely firm in its conclusions on the requirement of adequate safety and protection, as

this is the primary mission of the Nuclear Regulatory Commission (NRC). For example, the

DEIS should explicitly acknowledge which mitigation measures are required by the NRC,

with clear and objective criteria. In addition, the proposed MOX facility has not been fully

designed. However, the DEIS is not clear if reasonable conservatism has been

incorporated into the analyses due to the lack of design information or if ALARA (As Low As

Reasonably Achievable) considerations are included. 

Response: The impacts presented in the EIS are intended not to underestimate the

potential impacts of the proposed action. As discussed in responses to comments in the

human health risk sections (J.3.12 and J.3.13), conservatism is used in selecting models

and parameters used to estimate the impacts. In this way, the EIS should bound the actual

impacts and account for future design changes that may occur. Text has been added to

Chapter 5 (Mitigation) of the FEIS to clarify which mitigation measures are proposed by the

NRC and which mitigation measures would be required as part of any construction

authorization approval or operating license issuance. 

J.3.24.21 Comment: 10-024

Comment: Many of the mitigation procedures that are identified in the draft EIS seem

lacking in their ability to protect workers and surrounding communities. 

Response: The discussion of mitigation measures in Chapter 5 of the FEIS has been

revised. Text has been added to clarify which mitigation measures are required by laws and

regulations, which are suggested by DCS as good practices, and which are

recommendations by the Nuclear Regulatory Commission. As suggested by the

commenter, a discussion of mitigation measures for the proposed action, including the
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connected actions, has been added to more completely describe how workers and the

public would be protected if the proposed action is taken.

J.3.24.22 Comment: 86-087

Comment: Hydrazine emissions from the proposed MOX facility will be subject to South

Carolina Department of Health and Environmental Control (SCDHEC) regulations. The

mitigative action specified in Table 5.1 in the DEIS should be limited to compliance with

SCDHEC air quality regulations. 

Regarding potential accidents, the offgas treatment system (or any ventilation system at the

proposed MOX facility) is not required to be credited to reduce the hydrazine concentration

in air after a spill because calculations indicate that releases that originate indoors (inside

the reagent building or the MOX Building) do not result in concentrations that exceed any

temporary emergency exposure limits (TEELs) for the site worker or public. There appear

to be errors in the DEIS hydrazine airborne concentration calculation that leads to this

conclusion (see comments on Appendix E.1) and furthermore, crediting the release as an

indoor release, which reduces the air speed across the surface of the spilled solution,

provides sufficient reduction in the airborne concentration to result in acceptable

consequences without mitigation by any offgas treatment system. 

Response: The text in Table 5.1 and Section 5.2.8 of the FEIS has been revised to state

that DCS would limit operational hydrazine emissions to levels that do not cause

exceedance of the SCDHEC standard. With respect to accidental releases, the NRC

conservatively assumed that the accident would occur during chemical delivery, and that the

container contents would be spilled on an outdoor concrete surface (See EIS

Section 4.3.5.3). Therefore, modeled downwind air concentrations were not reduced by a

factor assuming indoor release. Chemical accidents are also discussed in

Comments J.3.12.9, J.3.12.21, J.3.12.22, and J.3.12.25.

J.3.24.23 Comment: 86-091

Comment: Section 5.2.2, page 5-7, lines 45-46 of the DEIS states, “Operation of a sand

filter would not directly impact groundwater because the filter would be covered to prevent

infiltration and it would have a concrete wall and bottom.” Because the proposed action

does not include a sand filter this statement is irrelevant. 

Response: The NRC disagrees with the comment. Sand filters are being considered as an

option for controlling air emissions from the proposed MOX facility, as part of the NRC’s

NEPA evaluation; the discussion presented in Section 5.2.1 of the EIS is therefore relevant.
Appendix J

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J.3.25 Unavoidable Impacts

J.3.25.1 Comment: 89-061

Comment: DEIS Section 4.7.1 reads as a summary of potential unavoidable impacts,

many of which are then dismissed if mitigation or good engineering practices are

implemented. It is recommended that the discussion be limited to only those areas where

unavoidable adverse impacts are certain to occur. 

Response: Mitigation measures and good engineering practices identified in Section 4.7.1

of the DEIS were included to provide the reader with a sense of the magnitude of the

unavoidable impacts. The NRC agrees that with appropriate mitigation some impacts can

be reduced, but also believes that some impacts cannot be avoided entirely even with good

engineering practices or other mitigation measures. This section of the FEIS has been

revised to eliminate mitigation actions if unavoidable impacts no longer occur, based on

revised impact conclusions presented in earlier sections of Chapter 4.

J.3.26 Geology and Soils

J.3.26.1 Comment: 89-031

Comment: In Section 3.2, page 3-1 of the DEIS, the statement that “prime farmland is

protected by the U.S. Department of Agriculture” is an oversimplification and technically

inaccurate. Although it is a moot point at the Savannah River Site, the Farmland Protection

Policy Act offers no absolute protection to important farmlands (i.e., prime, unique, or other

statewide or locally important farmlands). It was suggested that the text be changed to: 

“Certain soils are classified by the U.S. Department of Agriculture, Natural Resources

Conservation Service as prime farmland or other important farmlands. The Farmland

Protection Policy Act (7 U.S.C. 4201 et seq.) and its implementing regulations (7 CFR 658)

requires Federal agencies as part of the NEPA process to consider the extent to which

Federal projects and programs contribute to the unnecessary conversion of important

farmlands to nonagricultural uses.” 

Response: The text in Section 3.2 of the FEIS has been revised as suggested in the

comment.

J.3.26.2 Comment: 89-032

Comment: In Section 3.2.2, page 3-4 of the DEIS, a citation should be provided for the

estimated peak ground acceleration produced at the Savannah River Site from the

Charleston earthquake. If the citation for the information in the preceding paragraph is

USGS 2001, then this citation should be included at the end of the paragraph. 

Response: The citation is DCS Environmental Report (DCS 2002). This citation was

added to the text in Section 3.2.2 of the FEIS.
Appendix J

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J.3.26.3 Comment: 89-033

Comment: In Section 3.2.2, page 3-5 of the DEIS, the sentence referencing the Uniform

Building Code (UBC) should be deleted, as this Code was rendered obsolete with regard to

seismic design provisions with publication of the International Building Code (IBC) in 2000. 

The IBC replaces all national model building codes previously is use. Instead of seismic

zone designations, the IBC’s seismic design provisions are based on the USGS’ National

Earthquake Hazard Reduction Program maps that depict maximum considered earthquake

ground motions for the United States based on spectral response acceleration. 

Response: The text in Section 3.2.2 of the FEIS has been revised as suggested in the

comment. 

J.3.27 Cultural Resources

J.3.27.1 Comment: 89-038 

Comment: It was requested that in Section 3.7.1, the general location of site 38AK546/547

(as done for sites 38AK757, 38AK330, and 38AK548) be provided.

Response: The text in Section 3.7.1 of the FEIS has been revised to state the location of

38AK546/547 relative to the proposed MOX facility.

J.3.27.2 Comment: 86-022

Comment: To confirm Table 2.1, text should be added on page 2-34, lines 5-7 stating that

mitigation measures are being planned by DCS, in conjunction with the State Historic

Preservation Office, and the Savannah River Site cultural resources staff to mitigate any

potential impacts to archaeological sites before construction.

Response: Data recovery obligations for Sites 38AK546/547 and 38AK757 have been

completed. The text in the FEIS has been revised accordingly.

J.3.28 Ecology

J.3.28.1 Comments: 85-005

91-004

Comment: An area of concern about the Georgia coastal ecosystem was expressed. It

was stated that 90 percent of the fish originate in this ecosystem and that the marshes in

the costal area are dying. In addition, these marshes are a vital habitat for a diverse variety

of species that compose the food web for marine ecosystems. It was stated that the

marshes alone should warrant further study before proceeding with this expansion. It was

also felt that processing nuclear fuels seriously threatens these vital resources and could
Appendix J

J-144

contaminate groundwater, yet assessments such as this DEIS undervalues these risks and

their potential irreversibility. 

Response: Section 3.9 of the EIS discusses current waste management at the Savannah

River Site; Sections 4.3.3.1.2 and 4.3.3.2.2 address potential impacts of the proposed

action on surface water and ground water, respectively; and Section 4.3.4.2 discusses

waste disposal impacts associated with the proposed action. No wastes would be

discharged to groundwater. Only effluents from low-level waste and nonhazardous liquid

waste treatment would be eventually discharged to surface waters. The effluents of

treatment facilities are tested before release to ensure that discharges are consistent with

waste discharge limitations (e.g., radionuclide contaminants are removed before discharge). 

Therefore, no nuclear wastes associated with the proposed action would contaminate the

Savannah River or its associated marsh habitats. This issue is also discussed in

Comment J.3.29.1.

J.3.28.2 Comment: 86-127

Comment: In Section H.3.14 of the DEIS, it is suggested that the text be changed to reflect

that the transmission line area has been surveyed, that no smooth coneflowers were

observed, and that the U.S. Fish and Wildlife Service (USFWS) concurs that the proposed

action will not affect resources under their jurisdiction.

Response: The text of Section H.3.1.4 of the FEIS has been changed to reflect that the

transmission line area has been surveyed, that no smooth coneflowers were observed, and

that the USFWS concurs that the proposed action will not affect resources under their

jurisdiction. The letter response from Duncan (USFWS) to Gould (DOE) has also been

added to the reference list for Appendix H.

J.3.28.3 Comment: 89-035 

Comment: The bat species Myotis lucifugus and Myotis austroriparius are discussed

Section 5.5.4 of the DEIS but are not included in the companion list of protected species

presented in Appendix A, Table A.1. Please reconcile this inconsistency. Also, to be

consistent with the balance of the Ecology discussion, the common name of these two

species of bats should be presented in the text, followed by the Latin name in parentheses.

Response: The sentences pertaining to the bat species have been deleted from Section

3.5.4 of the FEIS to avoid confusion or inconsistencies with Appendix A, Table A.1. Neither

bat species has been reported for Aiken or Barnwell counties.

J.3.28.4 Comment: 89-036

Comment: In Section 3.5.4 of the DEIS, the common ground dove, loggerhead shrike, and

American sandburrowing mayfly are presented in this discussion of protected species but

are not included in the companion list of protected species presented in Appendix A,

Table A.1. This inconsistency should be reconciled.
Appendix J

J-145

Response: The text of Section 3.5.4 of the FEIS has been modified to avoid confusion or

inconsistencies with Appendix A, Table A.1. As the common ground dove is not currently

listed by the State of South Carolina, mention of it in Section 3.5.4 has been deleted. 

Similarly, the loggerhead shrike is not reported for Aiken or Barnwell counties. Thus,

mention of it has also been deleted. A text addition has been made that states that the

American burrowing mayfly is not currently listed by either the U.S. Fish and Wildlife Service

or the State of South Carolina.

J.3.28.5 Comment: 89-037 

Comment: In Section 3.5.4 of the DEIS, the majority of plant species discussed here are

either not listed in Appendix A, Table A.1 or are listed under a different common name. 

This inconsistency should be reconciled.

Response: The text of Section 3.5.4 of the FEIS pertaining to plant species has been

modified to make it consistent with Appendix A, Table A.1. This entailed either editing the

common and/or scientific names of the plants or deleting the names of those species that

are not listed for the counties of concern.

J.3.28.6 Comment: 89-026

Comment: The statement on page 2-30 of the DEIS, “No wetlands or

endangered/threatened species would be impacted” is too broad and not entirely consistent

with what is presented in Appendix H, pages H-7 through H-9. Based on what is presented,

it is difficult to state that no impacts would occur. Rather, it appears that it would be more

appropriate for lines 23 and 24 of page 2-30 to state that negligible impacts to wetlands,

aquatic habitat, and threatened/endangered species would be expected.

Response: The text in Table 2.1 of the FEIS on impacts to threatened species and

wetlands has been revised to be consistent with the discussion of impacts presented in

Appendix H. 

J.3.28.7 Comment: 89-029

Comment: It is suggested that Table 2.1, lines 23-27 and the text in Section 2.4, lines 2-4

be revised to have similar wording. 

Response: The text in Section 2.4 and Table 2.1 of the FEIS has been revised to state that

impacts to endangered or threatened species, wetlands, aquatic and terrestrial habitats

(including woodlands) would be small.
Appendix J

J-146

J.3.29 Socioeconomics

J.3.29.1 Comments: 43-002 

91-005

Comment: The impacts resulting from the loss of fresh water, or contamination of fresh

water, could have devastating adverse impacts on public health and the remaining

ecosystem functions in the lower reaches of Georgia’s five coastal rivers and the vast

estuaries and nature-based economy they support. This includes some 40,000 jobs in

coastal Georgia alone, about one out of five jobs in coastal Georgia, generating more than

$1 billion a year in revenue annually. Risks such as those linked to nuclear fuel processing,

storage, handling, transport, use, and conversion to electricity (each of which pose serious

threats to these resources and the businesses they support should) be included in the

DEIS. These impacts should be evaluated in the DEIS.

Response: The socioeconomic impacts of postulated accidents of the proposed facilities

on water and fish resources, and subsequently the economies of communities surrounding

the Savannah River Site (SRS), were not estimated in the EIS because it is expected that

such impacts, if any, would be small. In evaluation of postulated accidents, with potential

damage to crops under the plume in the event of an airborne release and subsequent

damage to water resources from the associated runoff, it was found that the amount of

radioactive material deposited per unit area would be relatively small. Dilution of runoff

would occur fairly rapidly in the affected rivers and streams and would not cause any

significant risk to the economies of the communities downstream of the location of the

proposed facility. 

Text has been added to Sections 4.6 and Appendix D in the FEIS to clarify the issue. 

The water resource impacts of the proposed action are discussed in Section 4.3.3 of the

EIS. Water would be used during construction and operation. However, this water would

come from deeper groundwater aquifers and would not significantly affect water flow in the

Savannah River. There would also be no direct discharges into surface water during

construction and discharges from the WSB during operation would have small impacts on 

surface water quality. Indirect discharges to the Savannah River would occur from treating

liquid waste from the proposed MOX facility. However, treating this waste is not anticipated

to significantly change the quantity or quality of the discharges for existing SRS waste

processing facilities. Because the impact to water resources is expected to be small,

alternatives to the proposed use of surface water to receive treated effluent are not

required. Mitigation measures to further minimize any possible impact on water resources

are discussed in Section 5.2.1 of the EIS. This issue is also discussed in

Comment J.3.28.1.
Appendix J

J-147

This page is being withheld pursuant to 10 CFR 2.390(a).
Appendix J

J-148

This page is being withheld pursuant to 10 CFR 2.390(a).
Appendix J

J-149

J.3.30.10 Comment: 89-024 

Comment: Revise page 2-25, line 36 of the DEIS to read “. . .was manufactured at the

DOE’s Los Alamos National Laboratory (LANL) and at the Bochvar Institute in Moscow,

Russia.” 

Response: The text in Section 2.3.5 of the FEIS has been modified to include the Bochvar

Institute.

J.3.30.11 Comment: 89-025 

Comment: In the Waste Management, Construction Section of Table 2.1 (page 2-29, lines

12-14 of the DEIS) both the liquid and solid wastes need to be labeled as “nonhazardous

waste” as done on lines 32 and 34. 

Response: The text was revised to include nonhazardous liquid and nonhazardous solid in

the Construction Waste portion of Table 2.1 of the FEIS.

J.3.30.12 Comment: 89-028 

Comment: In the infrastructure, normal operations section of Table 2.1 (page 2-31, line 21

of the DEIS), the percent of electric power capacity for operation (38.5%) does not agree

with the percentage presented in Section H.6.2 (p. H-13, line 6), 36.4%. 

Response: The percentage of electric power capacity in Table 2.1 of the FEIS was revised

to read “36.4%.”

J.3.30.13 Comment: 89-027

Comment: In Section 2.4, page 2-30 of the DEIS, the woodland habitat loss description

under the proposed action column is awkward. Suggest it be reworded for clarity as follows: 

“Up to 14.7 ha (36.4 ac) of woodlands would be cleared for the proposed facilities. This

would represent <1% of the annual timber harvest at SRS.”

Response: The suggested text revision has been made to Table 2.1 of the FEIS under the

heading of “Habitat Loss.” 

J.3.30.14 Comment: 89-048

Comment: In Table 4.13, the sixth column should be “Number of LCFs,” not “Chance of

LCF.”

Response: The heading for the sixth column in Table 4.13 of the FEIS has been corrected

to read “Fatalities (LCFs).”
Appendix J

J-150

J.3.30.15 Comment: 89-069

Comment: In Appendix F, page F-11, line 10 of the DEIS, “1900” should be “1990.”

Response: Text in the FEIS has been changed as suggested.

J.3.30.16 Comment: 86-008 

Comment: On page 2-13, line 42 of the DEIS, it is suggested to change to whenever

“practical” rather than whenever “possible.” 

Response: Section 2.2.3.3.3 of the FEIS has been revised to indicate that the Savannah

River Site is compacting solid waste whenever practical.

J.3.30.17 Comments: 86-010

86-015

Comment: On page 2-14, line 46 of the DEIS change “permitted” to “suitable.” 

Department of Energy low-level radioactive waste sites are neither permitted nor licensed

nor do they need to be. 

Response: The text in Section 2.2.4.1 of the FEIS has been revised to indicate that lowlevel radioactive waste would be sent to a suitable disposal site. 

J.3.30.18 Comments: 86-011

86-012

86-014

Comment: DEIS should not specify design details such as tank sizes. Otherwise, design

evolution might mandate DEIS revisions. Where necessary, bounding conditions can be

specified for impact projections; but these should be restricted to the discussions where

they are needed and not simply cast about in general descriptions of the facility. 

Response: The text in Section 2.2.4 of the FEIS has been revised to eliminate numerical

values on design capacity for tanks or containers, and waste volumes produced by

processing materials from the proposed MOX facility. Values on volumes of chemicals that

could be released during an accident are reported in Chapter 4 of the EIS in order to

provide the reader with a bounding estimate on the magnitude of impacts.

J.3.30.19 Comment: 86-018

Comment: In the chemical accident section of Table 2.1 (page 2-27, lines 52-53 of the

DEIS), the Nuclear Regulatory Commission should consider deleting reference to impact

from chemical spills on the general public. The DEIS contains no scenario of a release from

the MOX Facility, the Pit Disassembly and Conversion Facility, or the Waste Solidification

Building that results in any effect beyond the Savannah River Site boundary. 
Appendix J

J-151

Response: The commenter is correct. The reference to the general public has been

deleted from that section of Table 2.1.

J.3.30.20 Comment: 86-020

Comment: In the land use, accident section of Table 2.1 (page 2-31, lines 49-50 of the

DEIS), the use of the term “severe accident” is inappropriate. In 10 CFR Part 70

(see NUREG-1718), the appropriate terms are “likely, unlikely, high unlikely, and credible.”

Text should be changed to say “highly unlikely” (see DEIS page 2-37 which notes that a

severe accident is highly unlikely). 

Response: The phrase “severe accident” has been replaced with the phrase “highly

unlikely” in this section of Table 2.1. 

J.3.30.21 Comment: 86-013

Comment: Section 2.2.4.2.1, page 2-15 of the DEIS states that the acid bottoms collected

in the evaporator would be neutralized with sodium hydroxide in a neutralization tank. After

neutralization, the waste would be pumped to two 110-L (30-gal) cement head tanks. The

acidic bottoms will be collected in a bottoms tank where the solution will be sampled to

determine concentrations. Based on this sample, the solution would be metered to one of

three cement head tanks where neutralization would occur prior to transfer to the mixer. It

is suggested that the text be revised to state the following, “After collection, the waste would

be pumped into small batch cement head tanks to be neutralized.”

Response: The text in Section 2.2.4.2.1 of the FEIS has been revised to indicate that after

the acid bottoms collected in the evaporator were neutralized the material would be mixed

with cement and poured into approved containers.

J.3.30.22 Comment: 86-061

Comment: On page 4-47, line 16-17 of the DEIS, after “unrestricted use” add “or restricted

use.”

Response: The text in the FEIS has been changed to indicate that the property would be

released for unrestricted use or restricted used, under certain conditions. 

J.3.30.23 Comment: 86-121

Comment: Table E.6 in the DEIS needs a reference. 

Response: A reference has been added to Table E.6 in Appendix E, Section E.2.1.2 of the

FEIS.
Appendix J

J-152

J.3.30.24 Comment: 86-070

Comment: In Section 4.4.2, page 4-67, line 20-21 of the DEIS, the citation for the

environmental assessment for the conversion facility in Wilmington, NC, is incorrect.

Response: The commenter is correct that NUREG -0170 (NRC 1977) is not the

appropriate reference. The new reference for the environmental assessment GE fuel

fabrication facility in Wilmington, NC, will be added to the text in Section 4.4.2 of the FEIS.

J.3.30.25 Comment: 86-071

Comment: Inclusion of impacts from converting uranium hexafluoride to uranium dioxide

and impacts from transporting spent MOX fuel to the geologic repository was questioned. If

the Nuclear Regulatory Commission (NRC) feels compelled to retain these impacts, the

DEIS should note that these impacts replace similar avoided impacts from the conversion

and disposal of low enriched uranium fuel and that the net impact is zero. 

Response: Conversion of uranium hexafluoride to uranium dioxide at the Global Nuclear

Fuel-Americas, LLC Facility in Wilmington, North Carolina, is considered a connected action

that is required for the surplus plutonium conversion process at the Savannah River Site. 

The transport of spent MOX fuel to a geologic repository described in Section 4.4 would not

occur without production of MOX fuel. A brief discussion of impacts from transporting spent

MOX fuel thus seems appropriate. The NRC cannot conclude that the transportation

impacts presented in Section 4.4 of the EIS “replace similar avoided impacts from

conversion and disposal of low enriched uranium fuel and the net impact is zero” as stated

in the comment.

J.3.30.26 Comment: 86-032

Comment: Line 13 on page 3-41 of the DEIS should be corrected to note 24-hour shifts

rather than 12-hour shifts.

Response: The text in Section 3.8.5 of the FEIS was changed as suggested in the

comment.

J.3.30.27 Comment: 86-094

Comment: In line 3 on page 5-11 of the DEIS, the word “recycling” should be deleted.

Response: The word “recycling” was deleted from the FEIS text as suggested by the

commenter.
Appendix J

J-153

J.3.30.28 Comment: 86-095

Comment: It is suggested that line 18, page 5-11 of the DEIS be reworded to “A new tank

would be constructed within the WSB so that the high-alpha-activity waste can be

neutralized before being solidified to a TRU waste form.”

Response: The text in Section 5.2.7 of the FEIS has been revised and the text referenced

in the comment has been deleted. 

J.3.30.29 Comment: 89-040

Comment: The text on page 3-58, line 38 of the DEIS states that housing units are

expected to reach 35,400 in 2001. However, this is not consistent with Table 3.16 on

page 3-60, which states this estimate is for 2002. 

Response: Data shown are for 2002. The text in the FEIS has been changed to reflect the

comment.

J.3.30.30 Comment: 89-041

Comment: On page 3-59, lines 33 and 35 of the DEIS refer to housing units in the “county”

when it should be housing units in the “ROI.” 

Response: The data shown are for the region of influence (ROI). The FEIS has been

changed to reflect the comment.

J.3.30.31 Comment: 89-042 

Comment: In Table 3.16, the 2002 column of the table does not have a source footnoted

(as do the 1990 and 2000 columns). 

Response: A source has been added to the column showing the 2002 data.

J.3.30.32 Comment: 89-043 

Comment: State Route 781 is not shown in either Figure 3.1 or 3.8, as indicated in the

text. Also, the text refers to State Routes (SRs), while the Figure 3.8 refers to “SC.” 

Response: State Route 781 has been added to Figure 3.8, and the text and figure in the

FEIS have been made consistent with each other.
Appendix J

J-154

J.3.30.33 Comment: 89-068 

Comment: A reference should be provided for U.S. Census Bureau data used in

calculations in Appendix D, as well as for the sources provided in the appendix tables. 

Response: The relevant references have been added to Appendix D in the FEIS.

J.3.30.34 Comment: 89-070

Comment: The text on page H-15, lines 7 and 8 of the DEIS states that four additional

local public service employees would be required, while Table H.1 (p H-14) shows five

additional employees. Please reconcile this inconsistency. 

Response: The text in the FEIS has been changed to reflect the comment; the correct

number is five.

J.3.30.35 Comment: 86-104

Comment: On page C-10, line 19 of the DEIS an editorial change should be “0 to 139.”

Response: The text in Appendix C, Section C.2.1.2 of the FEIS has been corrected to

reflect this editorial change.

J.3.30.36 Comment: 86-106

Comment: In Table C.2, the per package quantities are not accurate. These may be more

accurate for a “per shipment” amount.

Response: These are per shipment quantities as noted in Section C.2.3 of the EIS. A

footnote will be added to the table in the FEIS for clarification.

J.3.30.37 Comment: 86-107

Comment: Page C-14 should be corrected to note that Transportation Safeguards Division

(TSD) is now called the Office of Secure Transportation, and the DOE Albuquerque Office

is now a National Nuclear Security Administration ( NNSA) Service Center. 

Response: The text in Section C.2.3 has been changed in the FEIS.
Appendix J

J-155

J.3.30.38 Comment: 86-109

Comment: There was concern about the footnote used in Table C.5. The footnote is

misleading as this footnote currently is used for the Type A packages as well as Type B. 

Type A packages are not used for plutonium metal shipments. The intent is to differentiate

between the Type B release fractions used for the plutonium metal shipments and those

used for the fresh, unirradiated MOX fuel shipments (Footnote “c”). 

Response: The footnotes in Table C.5 have been changed in the FEIS.

J.3.30.39 Comment: 89-052

Comment: On page 4-66, line 12 of the DEIS, it may be more clear to use the phrase

“from the PDCF” after “recovered HEU” so that it is not confused with waste uranium from

the proposed MOX facility. 

Response: The text in Section 4.4.1.3 has been changed in the FEIS.

J.3.30.40 Comment: 89-062

Comment: In Section 4.7.1, page 4-94 of the DEIS, the statement regarding proportionate

increase in amount of transuranic (TRU) waste (9%) is inconsistent with Section 4.5.1.2

(24%).

Response: The text in Section 4.5.1.1 has been revised in the FEIS. The TRU waste

generated would constitute 26% and 13% of the treatment and storage capacities

respectively.

J.3.30.41 Comments: 86-049

89-047

Comment: It is recommend that line 2 on page 4-29 of the DEIS be reworded to say the

process will produce a solid TRU waste “suitable” for disposal at WIPP. The use of the

word “similar” implies some differences and issues.

Response: The word “similar” has been changed in the FEIS to “suitable” as suggested. 

J.3.30.42 Comment: 86-044

Comment: On page 4-26, lines 37-40 of the DEIS the lists of hazardous “liquid” wastes

contains examples that are not liquids (i.e. batteries). 

Response: The text has been revised to delete the word “liquid.” 
Appendix J

J-156

J.3.30.43 Comment: 27-002 

Comment: Fourmile Branch appears to flow southwesterly in Figures 3.2 and 3.3, not

southeasterly as described in the text. This apparent discrepancy should be checked and

corrected, if warranted. 

Response: Section 3.3.1 was revised to state that Fourmile Branch flows southwesterly. 

J.3.30.44 Comment: 27-004

Comment: The first sentence in Section 3.2.2 of the DEIS reads, “Several underground

aquifers occur... .” The word “underground” is redundant and should be deleted; all aquifers

are below ground. 

Response: The word “underground” has been deleted.

J.3.30.45 Comment: 86-023

Comment: The typographical error on page 3-7, lines 23-24 of the DEIS should be

corrected to “Beaufort-Jasper.” 

Response: The typographical error for the Water Authority name in Section 3.3.1 was

changed to read “Beaufort-Jasper Water Authority.”

J.3.30.46 Comment: 86-024 

Comment: In Section 3.3.1, the DEIS refers to the S-Area sewage treatment plant. With

the opening of the Central Sanitary Waste Treatment Facility, the S-Area plant, and all other

area treatment plants at the Savannah River Site were closed. 

Response: The text in Section 3.3.1 was changed to indicate that discharge is received

from the Central Sanitary Waste Treatment Facility rather than the S-Area sewage

treatment plant.

J.3.30.47 Comment: 86-025 

Comment: In Section 3.3.2, page 3-11, line 3 of the DEIS delete the word “Creek.” The

aquifer is the Upper Three Runs Aquifer. 

Response: The name of the aquifer has been corrected. 
Appendix J

J-157

J.3.30.48 Comment: 86-026

Comment: It is suggested that “waste management facilities” be added to the lists for

facilities that could possibly contaminate groundwater on Section 3.3.2, page 3-12,

lines 27-29 of the DEIS. 

Response: The text in Section 3.3.2 has been revised as suggested in the comment.

J.3.30.49 Comment: 86-034 

Comment: On page 3-7, line 24 of the DEIS the correct spelling is Hardeevile (South

Carolina), not Hardeville. 

Response: The typographical error has been corrected.
Appendix J

J-158

 
Appendix K

K-1

APPENDIX K:

COMMENTER AND COMMENT DOCUMENT INDEX
Appendix K

K-2
Appendix K

K-3

APPENDIX K:

COMMENTER AND COMMENT DOCUMENT INDEX

K.1. Index by Comment Document Number

Comment

Document

Number

Accession

Numbera Commenter

0001 ml030660494 Mark Hogue

0002 Leah R. Karpen

0003 ml030940262 Pamela J. O’Brien

0004 ml031210403 Jody Lanier

0005 same Jody Lanier

0006 ml031210406 William D. Hooker, Sr.

0007 ml031210491 Whitney Erin Lamb

0008 ml031210487 Andre Entermann

0009 Vernell Cutter, Center for Environmental Justice

0010 ml031210428 Sara Barczak, Southern Alliance for Clean Energy

0011 ml031210434 Edwin S. Presnell, Augusta Metro Chamber of Commerce

0012 Scott Justice

0013 ml031210485 Glenn Carroll

0014 ml031210479 Ernest S. Chaput, Economic Development Partnership of Aiken and

Edgefield Counties

0015 ml031210451 Adele Kushner, Action for a Clean Environment

0016 ml031210483 Gresham Barrett, Congressman, 3rd District of South Carolina

0017 ml031210450 C. David Cowfer, Savannah River Site Retiree Association

0018 ml031210439 Donald A. Orth

0019 ml031210436 Mary T. Kelly, League of Women Voters of South Carolina

0020 ml031130034 Susan Cain Giusto

0021 ml030920471 Roy G. Hurni

0022 ml031130031 Linda Odom

0023 ml031210453 James E. Smith, Jr., State Representative, House of Representatives,

State of SC

0024 ml031080139 Lewis Patrie, Western N.C. Physicians for Social Responsibility

0025 ml031040250 William J. Mottel

0026 ml031130021 Camille Price, Augusta Tomorrow, Inc.

0027 ml031600204 Gregory Hogue, Department of the Interior

0028 Tom Clements

0029 Marvin I. Lewis

0030 Scott Justice
Appendix K

Comment

Document

Number

Accession

Numbera Commenter

K-4

0031 ml031200073 Ernest S. Chaput

0032 Kellie Gasink, Green Party

0033 Whitney Erin Lamb

0034 Kirk Cobb

0035 Vernell Cutter, Center for Environmental Justice

0036 Kelli Pearson

0037 Cheryl Jay

0038 Carol Cain

0039 Ellen O’Leary

0040 Bobbie Paul

0041 Victor Mereski

0042 Chester Dunham

0043 David Kyler, Center for a Sustainable Coast

0044 Sara Barczak, Southern Alliance for Clean Energy

0045 Jody Lanier

0046 Andre Entermann

0047 Peggy Roche, Carolina Peace Resource Center

0048 Tom Clements, Green Peace International

0049 Bill Robinson, Allendale County Council

0050 Mal McKibben, Citizens for Nuclear Technology Awareness

0051 Thomas Williams, Barnwell County Council

0052 William Hooker, Savannah River Group of the Sierra Club

0053 Don Moniak, Blue Ridge Environmental Defense League

0054 Ed Presnell, Augusta Metro Chamber of Commerce

0055 David Walker, Aiken Branch of the NAACP

0056 Mary Kelly, League of Women Voters of South Carolina

0057 Charles Weiss, Greater Aiken Chamber of Commerce

0058 Carolyn Betsy Rivard

0059 Brendolyn Jenkins, Imani Group

0060 David Cowfer, Savannah River Site Retiree Association

0061 Glenn Carroll, Georgians Against Nuclear Energy

0062 Ed Arnold, Physicians for Social Responsibility

0063 Ernest Chaput

0064 Robert Guild, South Carolina Chapter of the Sierra Club

0065 Darrell Watson

0066 Jen Kato, Georgia Chapter of the Sierra Club

0067 Tom Howell
Appendix K

Comment

Document

Number

Accession

Numbera Commenter

K-5

0068 Adele Kushner, Action for a Clean Environment

0069 Joanne Steele

0070 Charles Utley

0071 Lew Patrie, Western N.C. Physicians for Social Responsibility

0072 Mary Olson, Nuclear Information and Resource Service

0073 Lou Zeller, Blue Ridge Environmental Defense League

0074 Peter Sipp

0075 James E. Smith, State House of Representatives, South Carolina

0076 Gregg Jocoy, York County South Carolina Greens

0077 Judy Aulette, Charlotte Area Green Party

0078 ml031140007 Amanda Voss

0079 ml031130043 Linda Ewald

0080 ml031140009 Betsy Rivard, Women’s Action for New Directions

0081 ml031140008 Berta R. Laney, Women’s Action for New Directions

0082 ml031320272 Chris Miller

0083 ml031340393 Joan O. King

0084 ml031350217 Lauren Sorkin

0085 ml031400071 Adrienne Valentino

0086 ml031400084 Peter S. Hastings, Duke Cogema Stone & Webster 

0087 ml031400069 Allison Macfarlane

0088 ml031420049 Soumya Ganapathy

0089 ml031400037 Edward J. Siskin, U.S. Department of Energy, National Nuclear Security

Administration

0090 ml031400090 Rachel Western

0091 ml031400092 David Kyler, Center for a Sustainable Coast

0092 ml031400086 Glenn Carroll, Georgians Against Nuclear Energy

0093 ml031420683 Mary Olson, Nuclear Information and Resource Service

0094 Ralph L. Andersen, Nuclear Energy Institute

0095 ml031400083 Thomas R. Mott

0096 ml031400327 Mildred McClain, Citizens for Environmental Justice

0097 ml031420029 Alexander P. Murray

0098 ml031420055 Sara Barczak, Southern Alliance for Clean Energy

0099 ml031430074 Bev Baker

0100 ml031420021 Meira Warshauer

0101 ml031420042 Judy Ponder

0102 ml031420036 Bart Patton

0103 Terri Jagger Bline

0103 Emily B. Calhoun
Appendix K

Comment

Document

Number

Accession

Numbera Commenter

K-6

0103 Faye McKay-Clegg

0103 Eleanor L. Richardson

0103 Marguerite Sweet

0104 Petition (Don’’t brand the Southeast "Plutonium Alley"! We Don't waste

plutonium fuel)

0105 ml031400076 Robert B. Mills

0106 ml031400079 Diane F. Matesic

0107 ml031420017 Heinz J. Mueller, U.S. Environmental Protection Agency, Region 4

0108 ml031420019 Carolyn Cain

0109 ml031420011 Jennifer Zanck

0110 ml031420014 Mai Dang

0111 ml031480058 Ruth Thomas, Environmentalists, Inc.

0112 ml031600242 Ruth Sanford

0113 ml031620072 Dell Isham, South Carolina Chapter of the Sierra Club

0114 Louis Zeller, Blue Ridge Environmental Defense League

0115 Mary Olson, Nuclear Information and Resource Service

0116 ml031780008 Peter James Atherton

a A blank indicates no accession number available.
Appendix K

K-7

K.2. Index by Commenter/Organization

Commenter Name/Organization Accession

Numbera

Comment

Document

Number

Action for a Clean Environment (Adele Kushner) ml031210451 0015

Action for a Clean Environment (Adele Kushner) 0068

Allendale County Council (Bill Robinson) 0049

Andersen, Ralph L. (Nuclear Energy Institute) 0094

Arnold, Ed (Physicians for Social Responsibility) 0062

Atherton, Peter James ml031780008 0116

Augusta Metro Chamber of Commerce (Edwin S. Presnell) ml031210434 0011

Augusta Metro Chamber of Commerce (Ed Presnell) 0054

Augusta Tomorrow, Inc. (Camille Price) ml031130021 0026

Aulette, Judy (Charlotte Area Green Party) 0077

Baker, Bev ml031430074 0099

Barczak Sara (Southern Alliance for Clean Energy) ml031210428 0010

Barczak Sara (Southern Alliance for Clean Energy) 0044

Barczak Sara (Southern Alliance for Clean Energy) ml031420055 0098

Barnwell County Council (Thomas Williams) 0051

Barrett, Gresham (Congressman, 3rd District of South Carolina) ml031210483 0016

Bline, Terri Jagger 0103

Blue Ridge Environmental Defense League (Don Moniak) 0053

Blue Ridge Environmental Defense League (Louis Zeller) 0073

Blue Ridge Environmental Defense League (Louis Zeller) 0114

Cain, Carol 0038

Cain, Carolyn ml031420019 0108

Calhoun, Emily B. 0103

Carroll, Glenn (Georgians Against Nuclear Energy) ml031210485 0013

Carroll, Glenn (Georgians Against Nuclear Energy) 0061

Carroll, Glenn (Georgians Against Nuclear Energy) ml031400086 0092

Carolina Peace Resource Center (Peggy Roche) 0047

Center for a Sustainable Coast (David Kyler) 0043

Center for a Sustainable Coast (David Kyler) ml031400092 0091

Center for Environmental Justice (Vernell Cutter) 0009

Center for Environmental Justice (Vernell Cutter) 0035

Chaput, Ernest S.(Economic Development Partnership of Aiken and

Edgefield Counties) ml031210479 0014

Chaput, Ernest S.(Economic Development Partnership of Aiken and

Edgefield Counties) ml031200073 0031

Chaput, Ernest S.(Economic Development Partnership of Aiken and

Edgefield Counties) 0063
Appendix K

Commenter Name/Organization Accession

Numbera

Comment

Document

Number

K-8

Charlotte Area Green Party (Judy Aulette) 0077

Citizens for Environmental Justice (Mildred McCain) ml031400083 0096

Citizens for Nuclear Technology Awareness (Mal McKibben) 0050

Clements, Tom (Greenpeace International) 0028

Clements, Tom (Greenpeace International) 0048

Cobb, Kirk 0034

Cowfer, C. David (Savannah River Site Retiree Association) ml031210450 0017

Cowfer, C. David (Savannah River Site Retiree Association) 0060

Cutter, Vernell (Center for Environmental Justice) ml031210486 0009

Cutter, Vernell (Center for Environmental Justice) 0035

Dang, Mai ml031420014 0110

Department of Energy, National Nuclear Security Administration

(Edward J. Siskin) ml031400037 0089

Department of the Interior (Gregory Hogue) ml031600204 0027

Duke Cogema Stone & Webster (Peter S. Hastings) ml031400084 0086

Dunham, Chester 0042

Economic Development Partnership of Aiken and Edgefield Counties

(Ernest S. Chaput) ml03120479 0014

Economic Development Partnership of Aiken and Edgefield Counties

(Ernest S. Chaput) ml031200073 0031

Economic Development Partnership of Aiken and Edgefield Counties

(Ernest S. Chaput) 0063

Entermann, Andre ml031210487 0008

Entermann, Andre 0046

Environmentalists, Inc. (Ruth Thomas) ml031480058 0111

Ewald, Linda ml031130043 0079

Ganapathy, Soumya ml031420049 0088

Gasink, Kellie (Green Party) 0032

Georgians Against Nuclear Energy (Glenn Carroll) ml031210485 0013

Georgians Against Nuclear Energy (Glenn Carroll) 0061

Georgians Against Nuclear Energy (Glenn Carroll) ml031400086 0092

Giusto, Susan Cain ml031130034 0020

Greater Aiken Chamber of Commerce (Charles Weiss) 0057

Green Party (Kellie Gasink) 0032

Greenpeace International (Thomas Clements) 0028

Greenpeace International (Thomas Clements) 0048

Guild, Robert (South Carolina Chapter for the Sierra Club) 0064

Hastings, Peter S. (Duke Cogema Stone & Webster) ml031400084 0086
Appendix K

Commenter Name/Organization Accession

Numbera

Comment

Document

Number

K-9

Hogue, Mark ml030660494 0001

Hogue, Gregory (Department of the Interior) ml031600204 0027

Hooker, William D. (Savannah River Group of the Sierra Club) 0052

Hooker, William D. (Savannah River Group of the Sierra Club) ml031210406 0006

Howell, Tom 0067

Hurni, Roy G. ml030920471 0021

Imani Group (Brendolyn Jenkins) 0059

Isham, Dell (Sierra Club South Carolina Chapter) ml031620072 0113

Jay, Cheryl 0037

Jenkins, Brendolyn (Imani Group) 0059

Jocoy, Gregg 0076

Justice, Scott ml031210496 0012

Justice, Scott ml031130020 0030

Karpen, Leah R. ml03210482 0002

Kato, Jen (Georgia Chapter of the Sierra Club) 0066

Kelly, Mary T. (League of Women Voters of South Carolina) ml031210436 0019

Kelly, Mary T. (League of Women Voters of South Carolina) 0056

King, Joan O. ml031340393 0083

Kushner (Action for a Clean Environment) ml031210451 0015

Kushner (Action for a Clean Environment) 0068

Kyler, David (Center for a Sustainable Coast) 0043

Kyler, David (Center for a Sustainable Coast) ml031400092 0091

Lamb, Whitney Erin ml031210491 0007

Lamb, Whitney Erin 0033

Laney, Berta R. (Women’s Action for New Directions) ml031140008 0081

Lanier, Jody ml031210403 0004

Lanier, Jody ml031210403 0005

Lanier, Jody 0045

League of Women Voters of South Carolina (Vernell Cutter) 0009

League of Women Voters of South Carolina (Mary Kelly) 0056

Lewis, Marvin L. ml031210455 0029

Macfarlane, Allison ml031400069 0087

Matesic, Diane F. ml031400079 0106

McClain, Mildred ml031400327 0096

McKay-Clegg, Faye 0103

McKibben, Mal (Citizens for Nuclear Technology Awareness) 0050

Mereski, Victor 0041
Appendix K

Commenter Name/Organization Accession

Numbera

Comment

Document

Number

K-10

Miller, Chris ml031320272 0082

Mills, Robert B. ml031400076 0105

Moniak, Don (Blue Ridge Environmental Defense League) 0053

Mott, Thomas R. ml031400083 0095

Mottel, William J. ml031040250 0025

Mueller, Heinz J. ml031420017 0107

Murray, Alexander P. ml031420029 0097

NAACP, Aiken Branch (David Walker) 0055

Nuclear Energy Institute (Ralph L. Andersen) 0094

Nuclear Information Resource Service (Mary Olson) 0072

Nuclear Information Resource Service (Mary Olson) ml031420683 0093

Nuclear Information Resource Service (Mary Olson) 0115

O’Brien, Pamela J. ml030940262 0003

Odom, Linda ml031130031 0022

O’Leary, Ellen 0039

Olson, Mary (Nuclear Information Resource Service) 0072

Olson, Mary (Nuclear Information Resource Service) ml031420683 0093

Olson, Mary (Nuclear Information Resource Service) 0115

Orth, Donald A. ml031210439 0018

Patrie, Lewis (Western North Carolina Physicians for Social

Responsibility) ml031080139 0024

Patrie, Lewis (Western North Carolina Physicians for Social

Responsibility) 0071

Patton, Bart ml031420036 0102

Paul, Bobbie 0040

Pearson, Kelli 0036

Petition (Don’’t brand the Southeast "Plutonium Alley"! ) 0104

Physicians for Social Responsibility (Ed Arnold) 0062

Ponder, Judy ml031420042 0101

Presnell, Edwin S. (Augusta Metro Chamber of Commerce) ml031210434 0011

Presnell, Edwin S. (Augusta Metro Chamber of Commerce) 0054

Price, Camille (Augusta Tomorrow, Inc.) ml031130021 0026

Richardson, Eleanor L. 0103

Rivard, Carolyn Betsy 0058

Rivard, Betsy (Women's Action for New Direction) ml031140009 0080

Robinson, Bill (Allendale County Council) 0049

Roche, Peggy (Carolina Peace Resource Center) 0047
Appendix K

Commenter Name/Organization Accession

Numbera

Comment

Document

Number

K-11

Sanford, Ruth ml031600242 0112

Savannah River Site Retiree Association (C. David Cowfer) ml031210450 0017

Savannah River Site Retiree Association (Dave Cowfer) 0060

Sierra Club, Georgia Chapter (Jen Kato) 0066

Sierra Club, South Carolina Chapter (Robert Gould) 0064

Sierra Club, South Carolina Chapter (Dell Isham) ml031620072 0113

Sierra Club, Savannah River Group (William Hooker) 0052

Sierra Club, Savannah River Group (William Hooker) ml031210406 0006

Sipp, Peter 0074

Siskin, Edward J. ml031400037 0089

Smith, James E., Jr. (House of Representatives, State of South

Carolina) 0075

Smith, James E., Jr. (House of Representatives, State of South

Carolina) ml031210453 0023

Sorkin, Lauren ml031350217 0084

Southern Alliance for Clean Energy (Sara Barczak) ml031210428 0010

Southern Alliance for Clean Energy (Sara Barczak) 0044

Southern Alliance for Clean Energy (Sara Barczak) ml031420055 0098

Steele, Joanne 0069

Sweet, Marguerite 0103

Thomas, Ruth (Environmentalists, Inc.) ml031480058 0111

U.S. Environmental Protection Agency, Region 4 (Heinz Mueller) ml031420017 0107

Utley, Charles 0070

Valentino, Adrienne ml031400071 0085

Voss, Amanda ml031140007 0078

Walker, David (Aiken Branch of the NAACP) 0055

Warshauer, Meira ml031420021 0100

Watson, Darrell 0065

Weiss, Charles (Greater Aiken Chamber of Commerce) 0057

Western North Carolina Physicians for Social Responsibility (Lewis

Patrie) ml031080139 0024

Western North Carolina Physicians for Social Responsibility (Lewis

Patrie) 0071

Women’s Action for New Directions (Betsy Rivard) ml031140009 0080

Women’s Action for New Directions (Berta R. Laney) ml031140008 0081

Western, Rachel ml031400090 0090

Williams, Thomas (Barnwell County Council) 0051

Zanck, Jennifer ml031420011 0109
Appendix K

Commenter Name/Organization Accession

Numbera

Comment

Document

Number

K-12

Zeller, Louis (Blue Ridge Environmental Defense League) 0073

Zeller, Louis (Blue Ridge Environmental Defense League) 0114

a A blank indicates no accession number available.
Appendix K

K-13

K.3. Index by Comment Number

Commenta

Number

Section

Number Section Name Commenter

1-001 J.3.13.14 Human Health - Radiological Risk Mark Hogue

2-001 J.3.9.2 Scope - Terrorism Leah R. Karpen

2-002 J.3.7.8 Scope - DOE Policy

2-002 J.3.21.1 MOX Fuel Use

2-003 J.3.10.2 Alternatives

2-004 J.3.1.3 General Opposition

3-001 J.3.7.4 Scope - DOE Policy Pamela J. O’Brien

3-002 J.3.14.7 Accidents

3-003 J.3.1.3 General Opposition

4-001 J.3.11.2 Alternatives - Immobilization Jody Lanier

4-002 J.3.8.3 Scope - Safety Evaluation Report

4-003 J.3.9.2 Scope - Terrorism

4-004 J.3.8.2 Scope - Safety Evaluation Report

4-005 J.3.1.4 General Opposition

5-001 J.3.11.3 Alternatives - Immobilization Jody Lanier

5-002 J.3.4.1 NEPA Process

5-003 J.3.4.1 NEPA Process

5-003 J.3.4.5 NEPA Process

5-004 J.3.6.1 Scope - General

5-005 J.3.9.1 Scope - Terrorism

5-006 J.3.7.4 Scope - DOE Policy

5-007 J.3.21.1 Cost Benefit

5-008 J.3.7.6 Scope - DOE Policy

5-009 J.3.10.1 Alternatives

6-001 J.3.12.2 Human Health Risk William D. Hooker, Sr.

7-001 J.3.4.5 NEPA Process Whitney Lamb

7-002 J.3.18.2 Decommissioning

7-003 J.3.4.1 NEPA Process

7-004 J.3.16.1 Hydrology

8-001 J.3.1.5 General Opposition Andre Entermann

8-002 J.3.4.6 NEPA Process

8-003 J.3.15.1 Air Quality

8-004 J.3.7.10 Scope - DOE Policy

8-005 J.3.23.1 Cost Benefit

9-001 J.3.19.4 Environmental Justice Vernell Cutter

9-002 J.3.19.4 Environmental Justice

9-003 J.3.19.4 Environmental Justice
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-14

9-004 J.3.4.3 NEPA Process

9-005 J.3.19.4 Environmental Justice

10-001 J.3.9.1 Scope - Terrorism Sara Barczak

10-001 J.3.9.2 Scope - Terrorism

10-002 J.3.1.1 General Opposition

10-003 J.3.17.4 Waste Management

10-004 J.3.23.1 Cost Benefit

10-005 J.3.7.9 Scope - DOE Policy

10-006 J.3.1.6 General Opposition

10-007 J.3.4.4 NEPA Process

10-007 J.3.4.7 NEPA Process

10-008 J.3.7.6 Scope - DOE Policy

10-009 J.3.7.6 Scope - DOE Policy

10-010 J.3.7.3 Scope - DOE Policy

10-011 J.3.7.7 Scope - DOE Policy

10-012 J.3.14.1 Accidents

10-013 J.3.12.1 Human Health Risk

10-014 J.3.24.8 Mitigation

10-015 J.3.19.9 Environmental Justice

10-016 J.3.10.8 Alternatives

10-017 J.3.17.4 Waste Management 

10-017 J.3.17.5 Waste Management 

10-018 J.3.16.1 Hydrology

10-019 J.3.23.1 Cost Benefit

10-020 J.3.8.1 Scope - Safety Evaluation Report

10-020 J.3.8.3 Scope - Safety Evaluation Report

10-021 J.3.7.6 Scope - DOE Policy

10-022 J.3.1.6 General Opposition

10-023 J.3.11.2 Alternatives - Immobilization

10-024 J.3.24.21 Mitigation

11-001 J.3.2 General Support Edwin S. Presnell

12-001 J.3.1.5 General Opposition Scott Justice

12-002 J.3.7.6 Scope - DOE Policy

12-003 J.3.23.1 Cost Benefit 

12-004 J.3.6.9 Scope - General

12-004 J.3.21.1 MOX Fuel Use

13-001 J.3.5.1 Licensing Process Glenn Carroll

13-002 J.3.4.5 NEPA Process
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-15

13-002 J.3.4.7 NEPA Process

13-003 J.3.11.2 Alternatives - Immobilization

13-004 J.3.6.9 Scope - General

13-004 J.3.21.1 MOX Fuel Use

13-005 J.3.7.7 Scope - DOE Policy

13-006 J.3.17.6 Waste Management 

13-007 J.3.9.1 Scope - Terrorism

14-001 J.3.2 General Support Ernest S. Chaput

14-002 J.3.19.7 Alternatives

14-003 J.3.14.8 Accidents

14-004 J.3.6.3 Scope - General

15-001 J.3.11.2 Alternatives - Immobilization Adele Kushner

15-002 J.3.9.2 Scope - Terrorism

16-001 J.3.2 General Support Gresham Barrett

17-001 J.3.2 General Support C. David Cowfer

17-002 J.3.14.9 Accidents

18-001 J.3.8.1 Scope - Safety Evaluation Report Donald A. Orth

18-001 J.3.8.5 Scope - Safety Evaluation Report

19-001 J.3.4.5 NEPA Process Mary T. Kelly

19-002 J.3.9.1 Scope - Terrorism 

19-003 J.3.10.4 Alternatives

19-004 J.3.9.2 Scope - Terrorism

19-005 J.3.9.2 Scope - Terrorism

19-006 J.3.14.2 Accidents

19-007 J.3.15.4 Air Quality

19-008 J.3.6.1 Scope - General

19-009 J.3.8.3 Scope - Safety Evaluation Report

19-010 J.3.7.1 Scope - DOE Policy

20-001 J.3.1.4 General Opposition Susan Cain Guisto

21-001 J.3.2 General Support Roy G. Hurni

22-001 J.3.14.10 Accidents Linda Odom

22-002 J.3.19.2 Environmental justice

22-003 J.3.1.6 General Opposition

23-001 J.3.4.5 NEPA Process James E. Smith, Jr.

24-001 J.3.20.12 Transportation Lewis Patrie

24-002 J.3.9.1 Scope - Terrorism

24-003 J.3.13.1 Human Health - Radiological Risk

24-004 J.3.6.9 Scope - General
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-16

24-004 J.3.21.1 MOX Fuel Use

24-005 J.3.7.8 Scope - DOE Policy

24-006 J.3.17.4 Waste Management 

24-007 J.3.11.2 Alternatives - Immobilization

24-008 J.3.7.6 Scope - DOE Policy

24-009 J.3.1.3 General Opposition

24-010 J.3.9.1 Scope - Terrorism

24-010 J.3.9.2 Scope - Terrorism

25-001 J.3.2 General Support William J. Mottel

25-002 J.3.14.11 Accidents

26-001 J.3.2 General Support Camille Price

27-001 J.3.24.19 Mitigation Gregory Hogue

27-002 J.3.30.43 Editorial

27-003 J.3.16.2 Hydrology

27-004 J.3.30.44 Editorial

27-005 J.3.16.3 Hydrology

27-006 J.3.16.4 Hydrology

27-007 J.3.16.5 Hydrology

27-008 J.3.16.6 Hydrology

27-009 J.3.13.15 Human Health - Radiological Risk

27-010 J.3.16.7 Hydrology

28-001 J.3.19.3 Environmental Justice Tom Clements

28-002 J.3.19.3 Environmental Justice

29-001 J.3.20.1 Transportation Marvin I. Lewis

29-002 J.3.20.2 Transportation

29-003 J.3.5.2 Licensing Process

30-001 J.3.1.5 General Opposition Scott Justice

30-002 J.3.9.1 Scope - Terrorism

30-003 J.3.6.9 Scope - General

30-003 J.3.21.1 MOX Fuel Use

30-004 J.3.23.1 Cost Benefit

31-001 J.3.19.6 Environmental Justice Ernest S. Chaput

32-001 J.3.4.1 NEPA Process Kellie Gasink

32-002 J.3.6.1 Scope - General

32-003 J.3.7.10 Scope - DOE Policy

32-004 J.3.1.5 General Opposition

32-005 J.3.23.1 Cost Benefit

33-001 J.3.6.2 Scope - General Whitney Erin Lamb
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-17

34-001 J.3.7.10 Scope - DOE Policy Kirk Cobb

35-001 J.3.23.1 Cost Benefit Vernell Cutter

35-002 J.3.19.4 Environmental Justice

35-003 J.3.19.4 Environmental Justice

35-004 J.3.19.4 Environmental Justice

35-005 J.3.19.4 Environmental Justice

35-006 J.3.4.3 NEPA Process

35-006 J.3.19.4 Environmental Justice

35-006 J.3.19.6 Environmental Justice

36-001 J.3.7.10 Scope - DOE Policy Kelli Pearson

37-001 J.3.13.2 Human Health - Radiological Risk Cheryl Jay

37-002 J.3.11.2 Alternatives - Immobilization

37-003 J.3.3.1 Purpose and Need

37-004 J.3.11.2 Alternatives - Immobilization

38-001 J.3.7.4 Scope - DOE Policy Carol Cain

38-002 J.3.23.1 Cost Benefit

39-001 J.3.22.1 Cumulative Ellen O’Leary

39-002 J.3.9.2 Scope - Terrorism

39-003 J.3.7.4 Scope - DOE Policy

39-004 J.3.19.3 Environmental Justice

40-001 J.3.11.2 Alternatives - Immobilization Bobbie Paul

41-001 J.3.9.2 Scope - Terrorism Victor Mereski

42-001 J.3.12.2 Human Health Risk Chester Dunham

42-002 J.3.12.2 Human Health Risk

43-001 J.3.16.14 Hydrology David Kyler

43-002 J.3.29.1 Socioeconomics

43-003 J.3.8.2 Scope - Safety Evaluation Report

43-004 J.3.23.10 Cost Benefit

43-005 J.3.16.8 Hydrology

43-006 J.3.4.3 NEPA Process

44-001 J.3.9.1 Scope - Terrorism Sara Barczak

44-002 J.3.1.1 General Opposition

44-003 J.3.17.4 Waste Management 

44-004 J.3.23.1 Cost Benefit

44-005 J.3.7.9 Scope - DOE Policy

44-006 J.3.1.6 General Opposition

44-007 J.3.4.4 NEPA Process

44-007 J.3.4.7 NEPA Process
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-18

44-008 J.3.7.6 Scope - DOE Policy

44-009 J.3.7.6 Scope - DOE Policy

44-010 J.3.7.3 Scope - DOE Policy

44-011 J.3.7.7 Scope - DOE Policy

44-012 J.3.8.3 Scope - Safety Evaluation Report

45-001 J.3.11.3 Alternatives - Immobilization Jody Lanier

45-002 J.3.4.1 NEPA Process

45-003 J.3.4.1 NEPA Process

45-003 J.3.4.5 NEPA Process

45-004 J.3.6.1 Scope - General

45-005 J.3.9.1 Scope - Terrorism

45-006 J.3.7.4 Scope - DOE Policy

45-007 J.3.23.1 Cost Benefit

45-008 J.3.7.6 Scope - DOE Policy

45-009 J.3.10.1 Alternatives

46-001 J.3.1.5 General Opposition Andre Entermann

46-002 J.3.4.1 NEPA Process

46-003 J.3.4.6 NEPA Process

47-001 J.3.7.1 Scope - DOE Policy Peggy Roche

47-002 J.3.9.2 Scope - Terrorism

47-003 J.3.4.5 NEPA Process

47-004 J.3.15.2 Air Quality

47-005 J.3.21.1 MOX Fuel Use

48-001 J.3.7.2 Scope - DOE Policy Tom Clements

48-002 J.3.7.3 Scope - DOE Policy

48-003 J.3.7.5 Scope - DOE Policy

48-004 J.3.23.2 Cost Benefit

48-005 J.3.7.4 Scope - DOE Policy

49-001 J.3.2 General Support Bill Robinson

50-001 J.3.2 General Support Mal McKibben

50-002 J.3.14.8 Accidents

50-002 J.3.14.9 Accidents

51-001 J.3.2 General Support Thomas Williams

52-001 J.3.9.1 Scope - Terrorism William Hooker

52-002 J.3.8.2 Scope - Safety Evaluation Report

52-003 J.3.12.4 Human Health Risk

52-004 J.3.13.13 Human Health - Radiological Risk

53-001 J.3.23.11 Cost Benefit Don Moniak
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-19

53-002 J.3.13.7 Human Health - Radiological Risk

53-002 J.3.14.10 Accidents

53-003 J.3.13.16 Human Health - Radiological Risk

53-004 J.3.13.3 Human Health - Radiological Risk

53-005 J.3.12.5 Human Health Risk

53-006 J.3.13.4 Human Health - Radiological Risk

53-007 J.3.17.5 Waste Management 

53-008 J.3.14.3 Accidents

53-009 J.3.15.5 Air Quality

53-010 J.3.3.1 Purpose and Need

53-011 J.3.8.9 Scope - Safety Evaluation Report

53-012 J.3.15.5 Air Quality

54-001 J.3.2 General Support Ed Presnell

55-001 J.3.2 General Support David Walker

55-002 J.3.4.5 NEPA Process

56-001 J.3.9.1 Scope - Terrorism Mary Kelly

56-001 J.3.9.2 Scope - Terrorism

56-002 J.3.9.2 Scope - Terrorism

56-003 J.3.8.3 Scope - Safety Evaluation Report

56-004 J.3.15.4 Air Quality

56-005 J.3.6.1 Scope - General

56-006 J.3.7.1 Scope - DOE Policy

57-001 J.3.2 General Support Charles Weiss

58-001 J.3.9.1 Scope - Terrorism Carolyn Betsy Rivard

58-002 J.3.9.2 Scope - Terrorism

58-003 J.3.11.2 Alternatives - Immobilization

58-003 J.3.11.3 Alternatives - Immobilization

58-004 J.3.23.11 Cost Benefit

59-001 J.3.2 General Support Brendolyn Jenkins

59-002 J.3.4.7 NEPA Process

60-001 J.3.2 General Support David Cowfer

60-002 J.3.14.9 Accidents

61-001 J.3.1.3 General Opposition Glenn Carroll

61-002 J.3.4.5 NEPA Process

61-003 J.3.5.1 Licensing Process

61-004 J.3.7.5 Scope - DOE Policy

61-005 J.3.17.5 Waste Management

61-006 J.3.4.2 NEPA Process
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-20

61-007 J.3.11.2 Alternatives - Immobilization

61-008 J.3.7.2 Scope - DOE Policy

62-001 J.3.4.5 NEPA Process Ed Arnold

62-002 J.3.14.12 Accidents

62-003 J.3.4.5 NEPA Process

62-003 J.3.8.1 Scope - Safety Evaluation Report

63-001 J.3.2 General Support Ernest S. Chaput

63-002 J.3.10.7 Alternatives

63-003 J.3.14.8 Accidents

63-004 J.3.6.3 Scope - General

64-001 J.3.1.3 General Opposition Robert Guild

64-002 J.3.11.2 Alternatives - Immobilization

64-003 J.3.4.2 NEPA Process

64-004 J.3.6.9 Scoep - General

64-005 J.3.19.6 Environmental Justice

64-006 J.3.14.1 Accidents

64-006 J.3.14.16 Accidents

64-007 J.3.19.3 Environmental Justice

64-007 J.3.19.4 Environmental Justice

65-001 J.3.9.2 Scope - Terrorism Darrell Watson

65-002 J.3.9.1 Scope - Terrorism

65-003 J.3.21.1 MOX Fuel Use

65-004 J.3.8.3 Scope - Safety Evaluation Report

66-001 J.3.1.2 General Opposition Jen Kato

66-002 J.3.23.11 Cost Benefit

66-003 J.3.12.6 Human Health Risk

66-004 J.3.23.9 Cost Benefit

66-005 J.3.12.3 Human Health Risk

66-006 J.3.4.4 NEPA Process

66-006 J.3.4.5 NEPA Process

66-007 J.3.17.4 Waste Management 

66-007 J.3.17.5 Waste Management 

66-008 J.3.9.1 Scope - Terrorism

67-001 J.3.17.3 Waste Management Tom Howell

67-002 J.3.21.1 MOX Fuel Use

67-003 J.3.8.4 Scope - Safety Evaluation Report

68-001 J.3.11.2 Alternatives - Immobilization Adele Kushner

68-002 J.3.9.1 Scope - Terrorism
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-21

68-002 J.3.9.2 Scope - Terrorism

69-001 J.3.1.6 General Opposition Joanne Steele

69-002 J.3.11.1 Alternatives - Immobilization 

70-001 J.3.19.3 Environmental Justice Charles Utley

71-001 J.3.13.6 Human Health - Radiological Risk Lewis Patrie

71-002 J.3.20.12 Transportation

71-003 J.3.9.2 Scope - Terrorism

71-004 J.3.1.6 General Opposition

71-005 J.3.13.5 Human Health - Radiological Risk

71-006 J.3.17.4 Waste Management 

71-007 J.3.13.5 Human Health - Radiological Risk

71-008 J.3.13.1 Human Health - Radiological Risk

71-009 J.3.6.9 Scope - General

71-009 J.3.21.1 MOX Fuel Use

71-010 J.3.9.1 Scope - Terrorism

71-011 J.3.7.8 Scope - DOE Policy

71-012 J.3.9.1 Scope - Terrorism

71-012 J.3.9.2 Scope - Terrorism

71-013 J.3.11.2 Alternatives - Immobilization 

71-014 J.3.17.4 Waste Management

71-015 J.3.7.6 Scope - DOE Policy

72-001 J.3.10.3 Alternatives Mary Olson

72-002 J.3.10.1 Alternatives

72-003 J.3.3.1 Purpose and Need

72-004 J.3.7.8 Scope - DOE Policy

72-005 J.3.10.3 Alternatives

72-006 J.3.21.1 MOX Fuel Use

72-007 J.3.19.7 Environmental Justice

72-008 J.3.22.1 Cumulative Impacts

72-009 J.3.13.6 Human Health - Radiological Risk

72-010 J.3.19.8 Environmental justice

72-011 J.3.7.6 Scope - DOE Policy

72-012 J.3.7.6 Scope - DOE Policy

72-013 J.3.11.3 Alternatives - Immobilization 

72-014 J.3.6.2 Scope - General

72-015 J.3.10.1 Alternatives

73-001 J.3.13.7 Human Health - Radiological Risk Lou Zeller

73-002 J.3.10.1 Alternatives
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-22

73-003 J.3.08.3 Scope - Safety Evaluation Report

73-004 J.3.13.8 Human Health - Radiological Risk

73-005 J.3.10.8 Alternatives

74-001 J.3.8.2 Scope - Safety Evaluation Report Peter Sipp

74-002 J.3.10.3 Alternatives

75-001 J.3.4.5 NEPA Process James E. Smith

76-001 J.3.5.3 Licensing Process Gregg Jocoy

76-002 J.3.23.1 Cost Benefit

76-003 J.3.23.1 Cost Benefit

77-001 J.3.6.2 Scope - General Judy Aulette

77-002 J.3.21.1 MOX Fuel Use

77-003 J.3.6.10 Scope - General

77-004 J.3.7.6 DOE Policy

77-005 J.3.19.10 Environmental Justice

77-006 J.3.9.1 Scope - Terrorism

77-007 J.3.6.4 Scope - General

77-008 J.3.4.1 NEPA Process

77-009 J.3.1.6 General Opposition

78-001 J.3.11.2 Alternatives - Immobilization Amanda Voss

78-002 J.3.5.1 Licensing Process

78-003 J.3.19.3 Environmental Justice

79-001 J.3.1.1 General Opposition Linda Ewald

79-002 J.3.17.4 Waste Management

79-003 J.3.19.3 Environmental Justice

79-004 J.3.23.1 Cost Benefit

80-001 J.3.5.1 Licensing Process Betsy Rivard

80-002 J.3.19.4 Environmental Justice

80-003 J.3.11.2 Alternatives - Immobilization 

81-001 J.3.19.3 Environmental Justice Berta R. Laney

81-002 J.3.11.2 Alternatives - Immobilization 

81-003 J.3.5.1 Licensing Process

82-001 J.3.9.1 Scope - Terrorism Chris Miller

82-002 J.3.19.9 Environmental Justice

82-003 J.3.8.2 Scope - Safety Evaluation Report

82-004 J.3.19.3 Environmental Justice

82-005 J.3.10.5 Alternatives

82-006 J.3.7.1 Scope - DOE Policy

83-001 J.3.1.1 General Opposition Joan O. King
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-23

84-001 J.3.1.6 General Opposition Lauren Sorkin

84-002 J.3.19.4 Environmental Justice

84-002 J.3.19.9 Environmental Justice

84-003 J.3.10.5 Alternatives

85-001 J.3.20.1 Transportation Adrienne Valentino

85-002 J.3.1.4 General Opposition

85-003 J.3.12.17 Human Health Risk

85-004 J.3.9.1 Scope -Terrorism

85-005 J.3.28.1 Ecology

86-001 J.3.2 General Support Peter S. Hastings

86-002 J.3.11.4 Alternatives - Immobilization 

86-003 J.3.14.8 Accidents

86-003 J.3.14.16 Accidents

86-004 J.3.19.5 Environmental Justice

86-005 J.3.24.1 Mitigation

86-006 J.3.30.4 Editorial

86-007 J.3.6.7 Scope - General

86-008 J.3.30.16 Editorial

86-009 J.3.17.10 Waste Management

86-010 J.3.30.17 Editorial

86-011 J.3.30.18 Editorial

86-012 J.3.30.18 Editorial

86-013 J.3.30.21 Editorial

86-014 J.3.30.18 Editorial

86-015 J.3.30.17 Editorial

86-016 J.3.10.9 Alternatives

86-017 J.3.10.10 Alternatives

86-018 J.3.30.19 Editorial

86-019 J.3.17.8 Waste Management

86-020 J.3.30.20 Editorial

86-021 J.3.15.1 Air Quality

86-022 J.3.27.2 Cultural Resources

86-023 J.3.30.45 Editorial

86-024 J.3.30.46 Editorial

86-025 J.3.30.47 Editorial

86-026 J.3.30.48 Hydrology

86-027 J.3.16.9 Hydrology

86-028 J.3.16.10 Hydrology
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-24

86-029 J.3.16.11 Hydrology

86-030 J.3.16.12 Hydrology

86-031 J.3.15.1 Air Quality

86-032 J.3.30.26 Editorial

86-033 J.3.12.7 Human Health Risk

86-034 J.3.12.8 Human Health Risk

86-035 J.3.13.17 Human Health - Radiological Risk

86-036 J.3.13.18 Human Health - Radiological Risk

86-037 J.3.12.9 Human Health Risk

86-038 J.3.12.10 Human Health Risk

86-039 J.3.12.18 Human Health Risk

86-040 J.3.12.9 Human Health Risk

86-041 J.3.12.9 Human Health Risk

86-042 J.3.15.3 Air Quality

86-043 J.3.17.13 Waste Management

86-044 J.3.30.42 Editorial

86-045 J.3.17.1 Waste Management

86-046 J.3.17.1 Waste Management

86-047 J.3.17.8 Waste Management

86-048 J.3.17.2 Waste Management

86-049 J.3.30.41 Editorial

86-050 J.3.17.8 Waste Management

86-051 J.3.14.15 Accidents

86-052 J.3.14.8 Accidents

86-053 J.3.14.17 Accidents

86-054 J.3.14.20 Accidents

86-055 J.3.14.20 Accidents

86-056 J.3.13.6 Human Health - Radiological Risk

86-057 J.3.14.18 Accidents

86-058 J.3.12.24 Human Health Risk

86-059 J.3.12.25 Human Health Risk

86-060 J.3.12.19 Human Health Risk

86-061 J.3.30.22 Editorial

86-062 J.3.18.1 Decommissioning

86-063 J.3.18.4 Decommissioning

86-064 J.3.18.3 Decommissioning

86-065 J.3.19.5 Environmental Justice

86-066 J.3.14.9 Accidents
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-25

86-066 J.3.14.16 Accidents

86-067 J.3.20.3 Transportation

86-068 J.3.20.4 Transportation

86-069 J.3.13.6 Human Health - Radiological Risk

86-070 J.3.30.24 Editorial

86-071 J.3.30.25 Editorial

86-072 J.3.22.5 Cumulative Impacts

86-073 J.3.17.8 Waste Management

86-074 J.3.24.2 Mitigation 

86-075 J.3.24.3 Mitigation 

86-076 J.3.24.3 Mitigation 

86-077 J.3.24.3 Mitigation 

86-078 J.3.24.5 Mitigation

86-079 J.3.24.6 Mitigation

86-080 J.3.24.11 Mitigation 

86-081 J.3.24.12 Mitigation 

86-082 J.3.24.13 Mitigation

86-083 J.3.24.12 Mitigation

86-084 J.3.24.14 Mitigation 

86-085 J.3.24.7 Mitigation 

86-086 J.3.24.16 Mitigation

86-087 J.3.24.22 Mitigation 

86-088 J.3.19.5 Environmental Justice

86-089 J.3.19.5 Environmental Justice

86-090 J.3.24.4 Mitigation 

86-091 J.3.24.23 Mitigation

86-092 J.3.24.15 Mitigation

86-093 J.3.24.11 Mitigation 

86-094 J.3.30.27 Editorial

86-095 J.3.30.28 Editorial

86-096 J.3.24.17 Mitigation

86-097 J.3.24.7 Mitigation

86-098 J.3.24.18 Mitigation

86-099 J.3.16.15 Hydrology

86-100 J.3.20.5 Transportation

86-101 J.3.20.13 Transportation

86-102 J.3.20.6 Transportation

86-103 J.3.20.7 Transportation
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-26

86-104 J.3.30.35 Editorial

86-105 J.3.20.8 Transportation

86-106 J.3.30.36 Editorial

86-107 J.3.30.37 Editorial

86-108 J.3.20.14 Transportation

86-109 J.3.30.38 Editorial

86-110 J.3.20.9 Transportation

86-111 J.3.20.10 Transportation

86-112 J.3.13.6 Human Health - Radiological Risk

86-113 J.3.12.25 Human Health Risk

86-114 J.3.12.21 Human Health Risk

86-115 J.3.12.21 Human Health Risk

86-116 J.3.12.22 Human Health Risk

86-117 J.3.13.9 Human Health - Radiological Risk

86-118 J.3.13.10 Human Health - Radiological Risk

86-119 J.3.13.11 Human Health - Radiological Risk

86-120 J.3.13.11 Human Health - Radiological Risk

86-121 J.3.30.23 Editorial

86-122 J.3.14.23 Accidents

86-123 J.3.13.19 Human Health - Radiological Risk

86-124 J.3.14.24 Accidents

86-125 J.3.13.20 Human Health - Radiological Risk

86-126 J.3.15.6 Air Quality

86-127 J.3.28.2 Ecology

87-001 J.3.7.11 Scope - DOE Policy Allison Macfarlane

87-002 J.3.17.9 Waste Management

87-003 J.3.11.2 Alternatives - Immobilization 

87-004 J.3.10.2 Alternatives

87-005 J.3.11.2 Alternatives - Immobilization 

87-006 J.3.23.8 Cost Benefit

88-001 J.3.9.1 Terrorism Soumya Ganapathy

88-002 J.3.8.2 Scope - Safety Evaluation Report

88-003 J.3.19.3 Environmental justice

88-004 J.3.10.5 Alternatives

89-001 J.3.14.9 Accidents Edward J. Siskin

89-002 J.3.14.17 Accidents

89-003 J.3.14.18 Accidents

89-004 J.3.14.20 Accidents
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-27

89-005 J.3.14.9 Accidents

89-006 J.3.14.9 Accidents

89-007 J.3.14.16 Accidents

89-007 J.3.14.18 Accidents

89-008 J.3.6.3 Scope - General

89-009 J.3.19.5 Environmental Justice

89-010 J.3.15.1 Air Quality

89-011 J.3.15.1 Air Quality

89-012 J.3.18.2 Decommissioning

89-013 J.3.24.1 Mitigation

89-014 J.3.6.3 Scope - General

89-015 J.3.30.1 Editorial

89-016 J.3.30.2 Editorial

89-017 J.3.30.3 Editorial

89-018 J.3.30.4 Editorial

89-019 J.3.30.6 Editorial

89-020 J.3.30.5 Editorial

89-021 J.3.30.7 Editorial

89-022 J.3.30.8 Editorial

89-023 J.3.30.9 Editorial

89-024 J.3.30.10 Editorial

89-025 J.3.30.11 Editorial

89-026 J.3.28.6 Ecology

89-027 J.3.30.13 Editorial

89-028 J.3.30.12 Editorial

89-029 J.3.28.7 Ecology

89-030 J.3.30.3 Editorial

89-031 J.3.26.1 Geology and Soils

89-032 J.3.26.2 Geology and Soils

89-033 J.3.26.3 Geology and Soils

89-034 J.3.30.49 Editorial

89-035 J.3.28.3 Ecology

89-036 J.3.28.4 Ecology

89-037 J.3.2805 Ecology

89-038 J.3.27.1 Cultural Resources

89-039 J.3.12.11 Human Health Risk

89-040 J.3.30.29 Editorial

89-041 J.3.30.30 Editorial
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-28

89-042 J.3.30.31 Editorial

89-043 J.3.30.32 Editorial

89-044 J.3.13.12 Human Health - Radiological Risk

89-045 J.3.12.12 Human Health Risk

89-046 J.3.30.1 Editorial

89-047 J.3.30.41 Editorial

89-048 J.3.30.14 Editorial

89-049 J.3.12.24 Human Health Risk 

89-050 J.3.12.13 Human Health Risk

89-051 J.3.20.11 Transportation

89-052 J.3.30.39 Editorial

89-053 J.3.22.7 Cumulative Impacts

89-054 J.3.22.2 Cumulative Impacts

89-055 J.3.22.3 Cumulative Impacts

89-056 J.3.23.3 Cost Benefit

89-057 J.3.23.4 Cost Benefit

89-058 J.3.23.8 Cost Benefit

89-059 J.3.23.6 Cost Benefit

89-060 J.3.23.7 Cost Benefit

89-061 J.3.25.1 Unavoidable Impacts

89-062 J.3.30.40 Editorial

89-063 J.3.24.1 Mitigation

89-064 J.3.24.1 Mitigation

89-065 J.3.24.9 Mitigation

89-066 J.3.24.1 Mitigation

89-067 J.3.24.10 Mitigation

89-068 J.3.30.33 Editorial

89-069 J.3.30.15 Editorial

89-070 J.3.30.34 Editorial

90-001 J.3.1.6 General Opposition Rachel Western

90-002 J.3.21.1 MOX Fuel Use

90-003 J.3.17.4 Waste Management

91-001 J.3.11.2 Alternatives - Immobilization David Kyler

91-002 J.3.21.2 MOX Fuel Use

91-003 J.3.21.2 MOX Fuel Use

91-004 J.3.28.1 Ecology

91-005 J.3.29.1 Socioeconomics

91-006 J.3.9.1 Scope - Terrorism
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-29

91-006 J.3.9.2 Scope - Terrorism

91-007 J.3.1.2 General Opposition

92-001 J.3.5.1 Licensing Process Glenn Carroll

92-002 J.3.11.2 Alternatives - Immobilization 

92-003 J.3.6.9 Scope - General

92-003 J.3.21.1 MOX Fuel Use

92-004 J.3.7.7 Scope - DOE Policy

92-005 J.3.17.3 Waste Management

92-006 J.3.13.13 Human Health - Radiological Risk

93-001 J.3.5.1 Licensing Process Mary Olson

93-002 J.3.8.4 Scope - Safety Evaluation Report

93-003 J.3.6.5 Scope - General

93-004 J.3.11.3 Alternatives - Immobilization 

93-005 J.3.9.1 Scope - Terrorism

93-006 J.3.7.4 Scope - DOE Policy

93-007 J.3.10.3 Alternatives

93-008 J.3.7.2 Scope - DOE Policy

93-008 J.3.7.6 Scope - DOE Policy

93-009 J.3.7.5 Scope - DOE Policy

93-009 J.3.7.6 Scope - DOE Policy

93-010 J.3.6.9 Scope - General

93-011 J.3.13.21 Human Health - Radiological Risk

93-012 J.3.16.3 Hydrology

93-013 J.3.22.4 Cumulative Impacts

93-014 J.3.13.6 Human Health - Radiological Risk

93-015 J.3.8.4 Scope - Safety Evaluation Report

93-016 J.3.17.3 Waste Management

93-017 J.3.19.3 Environmental Justice

93-017 J.3.19.4 Environmental Justice

93-018 J.3.13.13 Human Health - Radiological Risk

93-019 J.3.9.2 Scope - Terrorism

94-001 J.3.13.6 Human Health - Radiological Risk Ralph L. Anderson

94-001 J.3.14.16 Accidents

94-001 J.3.14.9 Accidents

94-002 J.3.19.1 Environmental Justice

95-001 J.3.4.6 NEPA Process Thomas R. Mott

95-002 J.3.7.10 Scope - DOE Policy

95-003 J.3.5.4 Licensing Process
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-30

96-001 J.3.1.4 General Opposition Mildred McClain

96-002 J.3.19.6 Environmental Justice

96-003 J.3.4.7 NEPA Process

96-004 J.3.4.1 NEPA Process

96-005 J.3.19.11 Environmental Justice

96-006 J.3.11.2 Alternatives - Immobilization 

96-007 J.3.17.4 Waste Management

96-008 J.3.4.4 NEPA Process

96-008 J.3.4.6 NEPA Process

96-009 J.3.4.1 NEPA Process

96-010 J.3.4.2 NEPA Process

96-011 J.3.19.3 Environmental Justice

96-012 J.3.8.2 Scope - Safety Evaluation Report

96-013 J.3.19.4 Environmental justice

96-014 J.3.19.4 Environmental justice

96-015 J.3.4.1 NEPA Process 

96-015 J.3.19.4 Environmental Justice

96-016 J.3.17.4 Waste Management

96-017 J.3.14.15 Accidents

96-018 J.3.4.7 NEPA Process

96-019 J.3.7.7 Scope - DOE Policy

96-020 J.3.9.1 Scope - Terrorism

96-021 J.3.8.4 Scope - Safety Evaluation Report

96-022 J.3.3.2 Editorial

96-023 J.3.4.2 NEPA Process

96-023 J.3.4.5 NEPA Process

96-024 J.3.4.2 NEPA Process

96-024 J.3.4.5 NEPA Process

96-025 J.3.8.2 Scope - Safety Evaluation Report

96-026 J.3.19.4 Environmental Justice

96-027 J.3.11.2 Alternatives - Immobilization 

96-028 J.3.4.5 NEPA Process

96-029 J.3.4.7 NEPA Process

96-030 J.3.19.10 Environmental Justice

96-031 J.3.4.6 NEPA Process

96-032 J.3.7.3 Scope - DOE Policy

96-033 J.3.6.2 Scope - General

96-034 J.3.19.4 Environmental Justice
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-31

96-035 J.3.8.1 Scope - Safety Evaluation Report

96-036 J.3.8.2 Scope - Safety Evaluation Report

96-037 J.3.22.6 Cumulative Impacts

96-038 J.3.19.4 Environmental justice

96-039 J.3.1.3 General Opposition

97-001 J.3.4.2 NEPA Process Alexander P. Murray

97-001 J.3.4.4 NEPA Process

97-002 J.3.24.20 Mitigation

97-003 J.3.8.1 Scope - Safety Evaluation Report

97-004 J.3.14.14 Accidents

97-005 J.3.8.1 Scope - Safety Evaluation Report

97-006 J.3.4.4 NEPA Process

97-007 J.3.14.15 Accidents

97-008 J.3.12.20 Human Health Risk

97-009 J.3.12.14 Human Health Risk

97-010 J.3.12.23 Human Health Risk

97-011 J.3.14.25 Accidents 

97-012 J.3.12.15 Human Health Risk

97-013 J.3.6.6 Scope - General

97-014 J.3.17.12 Waste Management 

97-015 J.3.14.15 Accidents

97-016 J.3.17.6 Waste Management

97-017 J.3.10.8 Alternatives 

97-018 J.3.10.8 Alternatives 

98-001 J.3.1.6 General Opposition Sara Barczak

98-002 J.3.11.3 Alternatives - Immobilization 

98-003 J.3.7.3 Scope - DOE Policy

98-003 J.3.7.5 Scope - DOE Policy

98-004 J.3.7.6 Scope - DOE Policy

98-005 J.3.7.7 Scope - DOE Policy

98-006 J.3.21.2 MOX Fuel Use

98-007 J.3.16.1 Hydrology

98-008 J.3.14.19 Accidents

98-009 J.3.6.7 Scope - General

98-010 J.3.1.6 General Opposition

99-001 J.3.1.5 General Opposition Bev Baker

99-002 J.3.8.9 Scope - Safety Evaluation Report

99-003 J.3.16.1 Hydrology
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-32

100-001 J.3.8.6 Scope - Safety Evaluation Report Meira Warshauer

101-001 J.3.14.15 Accidents Judy Ponder

101-002 J.3.13.22 Human Health - Radiological Risk

101-003 J.3.16.1 Hydrology

102-001 J.3.14.15 Accidents Bart Patton

102-002 J.3.13.22 Human Health - Radiological Risk

103-001 J.3.5.1 Licensing Process Terri Jagger Bline

Emily B. Calhoun

Faye McKay-Clegg

Eleanor L. Richardson

Maruguerite Sweet

103-002 J.3.11.2 Alternatives - Immobilization Terri Jagger Bline

Emily B. Calhoun

Faye McKay-Clegg

Eleanor L. Richardson

Maruguerite Sweet

103-003 J.3.17.6 Waste Management Terri Jagger Bline

Emily B. Calhoun

Faye McKay-Clegg

Eleanor L. Richardson

Maruguerite Sweet

103-004 J.3.9.1 Scope - Terrorism Terri Jagger Bline

Emily B. Calhoun

Faye McKay-Clegg

Eleanor L. Richardson

Maruguerite Sweet

104-001 J.3.1.6 General Opposition Petition

105-001 J.3.1.3 General Opposition Robert B. Mills

105-002 J.3.11.5 Alternatives - Immobilization

105-003 J.3.8.3 Scope - Safety Evaluation Report

105-003 J.3.8.6 Scope - Safety Evaluation Report

105-004 J.3.13.7 Human Health - Radiological Risk

105-005 J.3.8.1 Scope - Safety Evaluation Report

105-006 J.3.7.10 Scope - DOE Policy

105-007 J.3.21.1 MOX Fuel Use

105-008 J.3.11.2 Alternatives - Immobilization

105-009 J.3.10.1 Alternatives

105-010 J.3.11.2 Alternatives - Immobilization 
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-33

105-011 J.3.23.7 Cost Benefit

105-012 J.3.11.3 Alternatives - Immobilization 

105-013 J.3.13.23 Human Health - Radiological Risk

105-014 J.3.1.7 General Opposition

105-015 J.3.14.21 Accidents

106-001 J.3.1.7 General Opposition Diane F. Matesic

107-001 J.3.15.7 Air Quality Heinz J. Mueller

107-002 J.3.12.16 Human Health - Gen

108-001 J.3.17.3 Waste Management Carolyn Cain

108-002 J.3.23.1 Cost Benefit

108-003 J.3.11.1 Alternatives - Immobilization 

109-001 J.3.1.6 General Opposition Jennifer Zanck

110-001 J.3.1.6 General Opposition Mai Dang

111-001 J.3.8.6 Scope - Safety Evaluation Report Ruth Thomas

112-001 J.3.1.6 General Opposition Ruth Sanford

112-002 J.3.11.2 Alternatives - Immobilization 

112-003 J.3.17.6 Waste Management

112-004 J.3.9.1 Scope - Terrorism

113-001 J.3.8.6 Scope - Safety Evaluation Report Dell Isham

114-001 J.3.7.5 Scope - DOE Policy Louis Zeller

114-002 J.3.7.5 Scope - DOE Policy

114-002 J.3.13.13 Human Health - Radiological Risk

114-003 J.3.7.7 Scope - DOE Policy

114-004 J.3.21.1 MOX Fuel Use

114-005 J.3.17.11 Waste Management

114-006 J.3.7.4 Scope - DOE Policy

114-007 J.3.11.3 Alternatives - Immobilization

114-008 J.3.11.3 Alternatives - Immobilization

114-009 J.3.9.1 Terrorism

114-009 J.3.9.2 Terrorism

114-010 J.3.21.1 MOX Fuel Use

114-011 J.3.9.2 Scope - Terrorism

114-012 J.3.20.16 Transportation

114-013 J.3.9.1 Scope - Terrorism

115-001 J.3.13.8 Human Health - Radiological Risk Mary Olson

115-002 J.3.10.8 Alternatives

115-003 J.3.19.7 Environmental justice

115-004 J.3.17.3 Waste Management
Appendix K

Commenta

Number

Section

Number Section Name Commenter

K-34

116-001 J.3.4.8 NEPA Process Peter James Atherton

116-002 J.3.9.1 Scope - Terrorism

116-003 J.3.14.12 Accidents 

116-004 J.3.1.1 General Opposition

116-005 J.3.5.5 Licensing Process

116-006 J.3.10.6 Alternatives

116-007 J.3.14.4 Accidents

116-008 J.3.14.5 Accidents

116-009 J.3.20.15 Transportation

116-010 J.3.8.4 Scope - Safety Evaluation Report

116-011 J.3.8.2 Scope - Safety Evaluation Report

116-012 J.3.8.5 Scope - Safety Evaluation Report

116-013 J.3.10.8 Alternatives

116-014 J.3.8.7 Scope - Safety Evaluation Report

116-015 J.3.14.22 Accidents

116-016 J.3.17.7 Waste Management

116-017 J.3.13.14 Human Health - Radiological Risk

116-018 J.3.4.9 NEPA Process

116-019 J.3.14.6 Accidents

116-020 J.3.8.8 Scope - Safety Evaluation Report

a Some comments are associated with more than one section.