NUREG-1834

Environmental Impact

Statement for the Proposed

American Centrifuge Plant

in Piketon, Ohio

Draft Report for Comment

U.S. Nuclear Regulatory Commission

Office of Nuclear Material Safety and Safeguards

Washington, DC 20555-0001 1l to
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NUREG-1834

Environmental Impact

Statement for the Proposed

American Centrifuge Plant

in Piketon, Ohio

Draft Report for Comment

Manuscript Completed: August 2005

Date Published: August 2005

Division of Waste Management and Environmental Protection

Office of Nuclear Material Safety and Safeguards

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

*O REG&4

4.

4-; I
COMMENTS ON DRAFT REPORT

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

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

specify the report number NUREG-1834, in your comments, and send them by October 24,2005 to

the following address:

Chief, Rules Review and Directives Branch

U.S. Nuclear Regulatory Commission

Mail Stop T6-D59

Washington, DC 20555-0001

Electronic comments may be submitted to the NRC by e-mail at NRCREPnanrc.2ov.

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

Matthew Blevins

TWFN 7 J-8

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Phone: 301-415-7684

E-mail: MXB6(5inrc.gov

NUREG-1834 has been reproduced

from the best available copy.

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ABSTRACT

USEC Inc. (USEC) has submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for a

license to construct, operate, and decommission the American Centrifuge Plant (ACP), a gas centrifuge

uranium enrichment facility located on the U.S. Department of Energy (DOE) reservation in Piketon,

Ohio. The American Centrifuge Plant, if licensed, would enrich uranium for use in commercial nuclear

fuel for power reactors. Feed material would be comprised of non-enriched uranium hexafluoride (UF6).

USEC proposes to enrich uranium up to 10 percent by weight of uranium-235. The initial license

application is for a 3.5 million separative work unit' (SWU) per year facility. Because USEC indicated

the potential for future expansion to 7.0 million SWU per year, the environmental review looks at the

impacts from a 7.0 million SWU per year facility. The proposed ACP would be licensed in accordance

with the provisions of the Atomic Energy Act. Specifically, an NRC license under Title 10, "Energy," of

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

USEC to possess anid use special nuclear material, source material, and byproduct material at the

proposed ACP site.

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

Environmental Policy Act and the NRC regulations for implementing the Act. This Draft EIS evaluates

the potential environmental impacts of the proposed action and its reasonable alternatives. This Draft EIS

also describes the environment potentially affected by USEC's proposal, presents and compares the

potential environmental impacts resulting from the proposed action and its alternatives, and describes

USEC's environmental monitoring program and mitigation measures.

'SWU relates to a measure of the amount of enriched uranium produced.

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I TABLE OF CONTENTS

2 Page

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

4 TABLE OF CONTENTS. v

5 LIST OF FIGURES . xiii

6 LIST OF TABLES .xv

7 EXECUTIVE SUMMARY ............................ xix

8 ACRONYMS AND ABBREVIATIONS .xxix

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

10 1.1 Background .1-1

11 1.2 The Proposed Action .1-1

12 1.3 Purpose and Need for the Proposed Action .1-3

13 1.3.1 The Need for Enriched Uranium to Fulfill Electricity Requirements .1-3

14 1.3.2 The Need for Domestic Supplies of Enriched Uranium for National Energy Security . . 1-5

15 1.3.3 The Need for Upgraded Uranium Enrichment Technology in the U.S. . 1-6

16 1.4 Scope of the Environmental Analysis . 1-6

17 1.4.1 Scoping Process and Public Participation Activities .7. 1-7

18 1.4.2 Issues Studied in Detail . 1-8

19 1.4.3 Issues Eliminated from Detailed Study . 1-8

20 1.4.4 Issues Outside the Scope of the EIS . 1-9

21 1.4.5 Related National Environmental Policy Act and Other Relevant Documents . 1-9

22 1.5 Applicable Regulatory Requirements . 1-11

23 1.5.1 Federal Laws and Regulations .. ........................................... 1-11

24 1.5.1.1 National Environmental PolicyAct of 1969, as amended (42 U.S.C. §4321

25 et seq.) .1-11

26 1.5.1.2 Atomic Energy Act of1954, as amended (42 U.S.C. §2011 et seq.)

27..........1-1127 ~~~~~~~~~~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......... ............

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28 1.5.1.3 Clean AirAct, as amended (42 U.S.C. §7401 et seq.) . 1-11

29 1.5.1.4 Clean WaterAct, as amended (33 U.S.C. §1251 et seq.) . 1-12

30 1.5.1.5 Resource Conservation and Recovery Act, as amended (42 U.S.C. §6901

31 et seq.) ........ 1-12

32 1.5.1.6 Low-Level Radioactive Waste Policy Act of.1980, as amended (42 U.S.C.

33 §2021 etseq.) . 1-12

34 1.5.1.7 Emergency Planning and Community Right-to-Know Act of 1986.

35 (42 U.S.C. § i o 0i et seq.) (also known as SARA Title III) . 1-13

36 1.5.1.8 Safe Drinking Water Act, as amended (42 U.S.C. §300fet seq.) . 1-13

37 1.5.1.9 Noise ControlAct of 1972, as amended (42 U.S.C. §4901 et seq.) . 1-13

38 1.5.1.10 NationalHistoricPreservationAct of1966, as amended (16 U.S.C. §470

39 etseq.) . 1-13

40 1.5.1.11 Endangered Species Act of 1973, as amended (16 U.S.C. §1531 et seq.) ... 1-14

41 1.5.1.12 Occupational Safety and Health Act of.1970, as amended (29 U.S.C. §651

42 et seq.) . 1-14

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1.5.1.13 Hazardous Materials Transportation Act (49 U.S.C. § 1 801 et seq.) ...... 1-14

1.5.1.14 Environmental Standards for Uranium Fuel Cycle (40 CFR Part 190,

SubpartB) .................................................... 1-14

1.5.2 Applicable Executive Orders ............................................. 1-14

1.5.3 Applicable State of Ohio Requirements ..................... 1-15

1.5.4 Permit and Approval Status ............................................. 1-19

1.5.5 Cooperating Agencies ............................ 1-19

1.5.6 Consultations ................................ 1-19

1.5.6.1 Endangered Species Act of 1973 Consultation .. ....................... 1-29

1.5.6.2 National Historic Preservation Act of 1966 Section 106 Consultation .1..... -30

1.5.6.3 Fish and Wildlife Coordination Act of 1934 Consultation . ............... 1-31

1.5.6.4 Farmland Protection Policy Act of 1981 Consultation .. ................ 1-32

1.6 Organizations Involved in the Proposed Action .................................... 1-32

1.7 References ................................................................ 1-33

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

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

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

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

2.1.3 Description of the Proposed American Centrifuge Plant ........ .. .............. 2-5

2.1.3.1 Primary Facilities . ................................................ 2-7

2.1.3.2 Secondary Facilities ............................................. 2-13

2.1.3.3 Operational Systems . ............................................ 2-15

2.1.3.4 Procured Utilities and Other Services ................................ 2-16

2.1.3.5 Local Road and Rail Network ..................................... 2-17

2.1.4 Description of the Phases of the Proposed Action ........... .. ............... 2-17

2.1.4.1 Refurbishment, Site Preparation, and Construction ... .................. 2-18

2.1.4.2 Manufacturing and Equipment Assembly ............................ 2-19

2.1.4.3 Facility Operation . .............................................. 2-21

2.1.4.4 Decontaminationand Decommissioning ............................. 2-34

2.1.4.5 Ceasing Operations at Paducah .................................... 2-35

2.2 No-Action Alternative ....................................................... 2-35

2.3 Alternatives Considered but Eliminated .... ...................................... 2-36

2.3.1 Construction and Operation of the ACP at the Paducah Gaseous Diffusion Plant in

Paducah, Kentucky ......................... ........................... 2-37

2.3.2 Other Alternative Sites ................................................. 2-42

2.3.3 Alternate Sources from Down Blending Highly Enriched Uranium ...... ......... 2-44

2.3.4 Alternative Sources of Low-Enriched Uranium .............................. 2-44

2.3.5 Alternative Technologies for Enrichment ................................... 2-45

2.3.6 Depleted UF6 Management Alternatives ............... .. ................... 2-48

2.4 Comparison of Predicted Environmental Impacts .................. ... ............. 2-49

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1 2.5 Staff Preliminary Recommendation Regarding the Proposed Action ...... ............. 2-61

2 2.6 References .. ............................. 2-62

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4 3. AFFECTED ENVIRONMENT .............................. 3-1

5 3.1 Site Location and Description ............................... 3-1

6 3.2 Land Use ............................... - 3-3

7 3.3 Historic and Cultural Resources ............... ................ 3-5

8 3.3.1 Historical Setting ..... .......................... 3-6

9 3.3.2 Methods ............. .. 3-7

10 3.3.3 Results of Document Review ................... 3-77............. 

I 1 3.3.4 Information from the Interested Public .. ............................... 3-10

12 3.3.5 Information from Indian Tribes .......................... 3-10

13 3.3.6 Historic Properties and Potential Historic Properties' ............................. 3-10

14 3.4 Visual and Scenic Resources ............................... 3-11

15 3.5 Climatology, Meteorology, and Air Quality ................. ..................... 3-14

16 3.5.1 Regional Climatology ............................................... 3-14

17 3.5.2 Site and Regional Meteorology .......................................... 3-14

18 3.5.2.1 Severe Weather Conditions . ...................................... 3-15

19 3.5.2.2 Mixing Heights ............................................... 3-15

20 3.5.3 Air Quality ............................................... 3-17

21 3.5.3.1 Current Emissions at the DOE Reservation ........ .................... 3-19

22 3.5.3.2 Current Air Quality Conditions .................................... 3-21

23 3.6 Geology, Minerals, and Soil ............................... .........-.-.-.. 3-22

24 3.6.1 Regional Geology, Structure, and Seismicity .................................. 3-22

25 3.6.2 Soils ....................................... 3-24

26 3.7 Water Resources ....................................... 3-25

27 3.7.1 Surface Water Features ..... .......... 3-25

28 3.7.1.1 SurfaceWaterQuality .- ;. 3-29

29 3.7.2 Floodplains . ....................................... 3-32

30 3.7.3 Groundwater ....................................... 3-34

31 3.8 Ecological Resources ................. 3-36

32 3.8.1 Flora ................. 3-36

33 3.8.2 Fauna ................. 3-38

34 3.8.3 Rare, Threatened, and Endangered Species ................................. 3-39

35 3.8.4 Wetlands .................................. 3-41

36 3.8.5 Environmentally Sensitive Areas . .................................. 342

37 3.9 Socioeconomic Conditions and Local Community Services .......................... 342

38 3.9.1 Population Characteristics .342-42...................... ... l

39 3.9.1.1 Major Population Centers .......................................... 343

40 3.9.1.2 Population Growth Trends .......................... 3-46

41 3.9.1.3 Residential Locations of Workers .346-46...................... ... |

42 3.9.1.4 Significant Transient and Special Populations ........................... 3-46

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3.9.2 Economic Trends and Characteristics ................................ 3-47

3.9.2.1 Employment in the Region of Influence ..... ......................... 3-47

3.9.2.2 Reservation Employment ........................................ 3-50

3.9.2.3 Income ...................................................... 3-50

3.9.3 Housing Resources and Community and Social Services .... .................. 3-51-

3.9.3.1 Housing ...................................................... 3-52

3.9.3.2 Schools ....................................................... 3-52

3.9.3.3 Hospitals and Nursing Homes ..................................... 3-53

3.9.3.4 Law Enforcement, Fire Fighting, and Other Public Services .............. 3-54

3.9.3.5 Infrastructure and Utilities ........................................ 3-54

3.9.4 Tax Structure and Distribution ........................................... 3-55

3.10 Environmental Justice ...................................................... 3-55

3.10.1 Minority Populations ................................................. 3-56

3.10.2 Low-Income Populations .............................................. 3-58

3.11 Noise ....................................................... 3-60

3.12 Transportation ....................................................... 3-61

3.12.1 Roads ....................................................... 3-61

3.12.2 Rail ....................................................... 3-63

3.12.3 Water ................................... 3-63

3.12.4 Air ................................. ........... 3-63

3.13 Public and Occupational Health ............................................ 3-63

3.13.1 Background Radiological Exposure ...................................... 3-64

3.13.2 Background Chemical Exposure ......................................... 3-65

3.13.3 Public Health Studies ............................................ 3-66

3.13.4 Occupational Injury and Illness Rates ..................................... 3-68

3.14 Waste Management ............................................ 3-70

3.14.1 Current Waste Management Program ..................................... 3-70

3.14.2 Baseline Waste Generation ............................................ 3-70

3.14.3 Current Waste Streams and Management Practices .......................... 3-71

3.14.3.1 Depleted Uranium ............................................ 3-71

3.14.3.2 Low-Level Radioactive Waste .................................. 3-72

3.14.3.3 Hazardous Waste ............................................ 3-73

3.14.3.4 Low-Level Mixed Waste ........................................ 3-74

3.14.3.5 Recyclable Waste ............................................ 3-74

3.14.3.6 Classified/Sensitive Waste . ..................................... 3-75

3.14.3.7 Sanitary/Industrial Waste . ..................................... 3-75

3.15 References ................................. ........... 3-75

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

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

4.2 Impacts of the Proposed Action ............................................ 4-2

4.2.1 Land Use Impacts ............................................ 4-2

4.2.1.1 Site Preparation and Construction . ................................... 4-2

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4.2.1.2 Facility Operation .................. .. . 44

4.2.1.3 Ceasing Operations at Paducah ................................ 4-4

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

4.2.2.1 Site Preparation and Construction ................................ 4-5

4.2.2.2 Facility Operation .................... 4-6

4.2.2.3 Ceasing Operations at Paducah . ................................-. 4-7

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

4.2.3.1 Site Preparation and Construction ................................ 4-8

4.2.3.2 Facility Operation ... ............. 4-8

4.2.3.3 Ceasing Operations at Paducah ................................ 4-8

4.2.4 Air Quality Impacts ................................ 4-9

4.2.4.1 Site Preparation and Construction ................................ 4-9

4.2.4.2 Facility Operation .................... 4-12

4.2.4.3 Ceasing Operations at Paducah ......................... 4-15

4.2.5 Geology and Soil Impacts ................... . 4-15

4.2.5.1 Site Preparation and Construction ........................... 4-16

4.2.5.2 Facility Operation ............... ... ......... 4-17

4.2.5.3 Ceasing Operations at Paducah ........................... 4-17

4.2.6 Water Resources Impacts ................................. 4-18

4.2.6.1 Site Preparation and Construction ................................ 4-18

4.2.6.2 Facility Operation ... ............. 4-20

4.2.6.3 Ceasing Operations at Paducah ......................... 4-25

4.2.7 Ecological Impacts . . . ............ 4-25

4.2.7.1 Site Preparation and Construction ........................... 4-26

4.2.7.2 Facility Operation .......................... 4-28

4.2.7.3 Ceasing Operations at Paducah ................ .. 4-29

4.2.8 Socioeconomic Impacts .................... ...... 4-29

4.2.8.1 Methodology .................. ........ 4-29

4.2.8.2 Site Preparation and Construction .......................... 4-30

4.2.8.3 Facility Operation .... ................. 4-33

4.2.8.4 Ceasing Operations at Paducah . . .... .................. 4-35

4.2.9 Environmental Justice Impacts ........................ 4-37

4.2.10 Noise Impacts ............. - - 4-39

4.2.10.1 Site Preparation and Construction ..............................-. 4-39

4.2.10.2 Facility Operation ............................. 4-39

4.2.10.3 Ceasing Operations at Paducah ............................. 440

4.2.11 Transportation Impacts .. 4-40 4.................... 

4.2.11.1 Site Preparation and Construction .................. 440 4-............-- 

4.2.11.2 Facility Operation ................................. 445 '- 

4.2;11.3 Ceasing Operations at Paducah .4-................................ 448

4.2.12 Public and Occupational Health Impacts ................................ 4-48

4.2.12.1 Transportation ................................ 4-48

4.2.12.2 Site Preparation and Construction ................................. 4-58

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4.2.12.3 Facility Operation ..............

4.2.12.4 Ceasing Operations at Paducah .....

4.2.13 Waste Management Impacts ..............

4.2.13.1 Site Preparation and Construction ...

4.2.13.2 Facility Operation ..............

4.2.13.3 Ceasing Operations at Paducah .....

4.2.14 Impacts from Centrifuge Manufacturing .....

4.2.14.1 Land Use Impacts ................

4.2.14.2 Historic and Cultural Impacts .......

4.2.14.3 Visual and Scenic Impacts .........

4.2.14.4 Air Quality Impacts ..............

4.2.14.5 Geology and Soils Impacts .........

4.2.14.6 Water Resources Impacts ..........

4.2.14.7 Ecological Impacts ...............

4.2.14.8 Socioeconomic Impacts ...........

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4.2.14.9 Environmental Justice Impacts ...... ................... 4-88

4.2.14.10 Noise Impacts ... .......... ............ 4-88

4.2.14.11 Transportation Impacts ............. ............ 4-88

4.2.14.12 Public and Occupational Health Impacts .......... .. ............... 4-88

4.2.14.13 Waste Management Impacts ................. .................... 4-89

4.2.15 Decontamination and Decommissioning ...................... ............. 4-89

4.2.15.1 Land Use Impacts .......... .................................... 4-91

4.2.15.2 Historical and Cultural Impacts ................................... 4-91

4.2.15.3 Visual and Scenic Impacts ....................................... 4-91

4.2.15.4 Air Quality Impacts ......... ................................... 4-91

4.2.15.5 Geology and Soils Impacts ....................................... 4-92

4.2.15.6 Water Resources Impacts ........................................ 4-92

4.2.15.7 Ecological Impacts ............................................. 4-93

4.2.15.8 Socioeconomic Impacts ......................................... 4-93

4.2.15.9 Environmental Justice Impacts .................................... 4-96

4.2.15.10 Noise Impacts ........................... 4-96

4.2.15.11 Transportation Impacts ................... ...................... 4-97

4.2.15.12 Public and Occupational Health Impacts .......... .. ............... 4-97

4.2.15.13 Waste Management Impacts ................. ................... 4-100

4.3 Cumulative Impacts ........................................................ 4-100

4.3.1 Land Use ........................................................... 4-103

4.3.2 Climatology, Meteorology, and Air Quality ............. .. ................. 4-104

4.3.3 Geology and Soils .................................................... 4-105

4.3.4 Water Resources .............................. 4-105

4.3.5 Ecology (Flora, Fauna, Wetlands, and Threatened and Endangered Species) ...... 4-108

4.3.6 Socioeconomic and Local Community Services ........... .. ................ 4-109

4.3.7 Environmental Justice ............................ 4-109

4.3.8 Transportation ....................................................... 4-109

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1 4.3.9 Public and Occupational Health .......................................... 4-110

2 4.3.9.1 Transportation ................ ................................. 4-110

3 4.3.9.2 Site Preparation and Construction Activities ......................... 4-111

4 4.3.9.3 Operations ...................................................... 4-112

5 4.3.10 Waste Management ................. ................................. 4-113

6 4.4 Impacts of the No-Action Alternative ... ....................................... 4-114

7 4.4.1 Land Use Impacts . ................................................... 4-115

8 4.4.2 Historic and Cultural Impacts ........... ................................ 4-116

9 4.4.3 Visual and Scenic Impacts ............. ................................. 4-116

10 4.4.4 Air Quality Impacts . ................................................... 4-116

11 4.4.5 Geology and Soils Impacts ................ .............................. 4-117

12 4.4.6 Water Resources Impacts ............................................... 4-117

13 4.4.7 Ecological Impacts ................... 4-117

14 4.4.8 Socioeconomic Impacts ................... 4-117

15 4.4.9 Environmental Justice Impacts .......................................... 4-118

16 4.4.10 Noise Impacts . ..................................................... 4-118

17 4.4.11 Transportation Impacts .... .......................................... 4-118

18 4.4.12 Public and Occupational Health Impacts ................................. 4-118

19 4.4.13 Waste Management Impacts ........... ................................. 4-119

20 4.5 References ................................................................ 4-119

21

22 5. MITIGATION ........................................................... ... 5-1

23 5.1 Mitigation Measures Proposed by USEC .......................................... 5-1

24 5.2 Potential Mitigation Measures Identified by NRC .................................... 5-4

25 5.3 References . ........................................................... 5-4

26

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

28 6.1 Radiological Measurements and Monitoring Program ................................ 6-1

29 6.1.1 Air Emissions Monitoring . .......................................... 6-3

30 6.1.2 Ambient Air Quality Monitoring .............................. ........ 6-5

31 6.1.3 Wastewater and Stormwater Discharge Monitoring .............................. 6-6

32 6.1.4 Surface Water and Sediment Monitoring ..................................... 6-7

33 6.1.5 Groundwater Monitoring ............................................. 6-9

34 6.1.6 Soil and Vegetation (Biota) Sampling ........................................ 6-9

35 6.1.7 Direct Gamma Radiation Monitoring ............................ 6-11

36 6.1.8 Laboratory Standards .................. ; .;................ 6-11

37 6.2 Nonradiological Measurements and Monitoring Program ............................ 6-12

38 6.3 References ........... 6-12

39

40 7.0 COST BENEFIT ANALYSIS ........... 7-1

41 7.1 Costs and Benefits of the Proposed Action ........... 7-1

42 7.1.1 Costs of the Proposed Action . ........... 7-1

43 7.1.2 Benefits of the Proposed Action ............................................ 7-4

xi
U- I

1 7.1.3 Conclusions Regarding the Proposed Action ................................. 7-5

2 7.2 Comparative Cost Benefit Analysis of Proposed Action Relative to No-Action Alternative . . 7-5

3 7.2.1 Methodology . .......................................................... 7-6

4 7.2.2 Compliance with Policy and Technical Objectives ............................. 7-6

5 7.2.2.1 Meeting Future Demand ........................................... 7-7

6 7.2.2.2 National Energy Security .......................................... 7-7

7 7.2.2.3 Technology Upgrade ............................................. 7-7

8 7.2.3 Impacts and Value Analysis ........... ................................... 7-8

9 7.2.3.1 Construction and Manufacturing Costs ............................... 7-8

10 7.2.3.2 Operating Costs ............. .................................... 7-8

11 7.2.3.3 Decommissioning Costs ........................................... 7-9

12 7.2.3.4 Environmental and Public and Occupational Health Impacts .... .......... 7-9

13 7.2.4 Conclusions Regarding the Proposed Action Versus the No-Action Alternative ..... 7-10

14 7.3 Overall Cost Benefit Conclusions ........... ................................... 7-10

15 7.4 References ................................................................ 7-10

16

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

18 8.1 Unavoidable Adverse Environmental Impacts ...................................... 8-1

19 8.2 Relationship Between Local Short-Term Uses of the Environment and the Maintenance and

20 Enhancement of Long-Tenn Productivity .......................................... 8-3

21 8.3 Irreversible and Irretrievable Commitment of Resources ......... ..................... 8-4

22 8.4 References .............................................. 8-5

23

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

25 9.1 Federal Agencies .............................................. 9-1

26 9.2 State Agencies .............................................. 9-1

27 9.3 Local Agencies .............................................. 9-1

28 9.4 Indian Tribes .............................................. 9-1

29

30 10. LIST OF PREPARERS .............................................. 10-1

31 10.1 U.S. Nuclear Regulatory Commission (NRC) Contributors ........... .............. 10-1

32 10.2 ICF Consulting Contributors .............................................. 10-1

33

34 Appendix A: Environmental Scoping Summary Report ........... ...................... A-l

35 Appendix B: Consultation Letters .............................................. B-l

36 Appendix C: Radiological Dose Analytical Methodology .......... ...................... C-l

37 Appendix D: Transportation Analysis Methodology, Assumptions, and Impacts .... ........ D-l

38 Appendix E: Air Quality Analysis . ................................................... E-l

39 Appendix F: Environmental Justice Analysis .......... ................................ F-I

40 Appendix G: Cost Benefit Analysis . ................................................. G-1

41 Appendix H: Accident Analysis for the Proposed ACP .................................. H-i

42 Appendix I: Glossary .......................................................... I-l

xii

I . Il
1 LIST OF FIGURES - -

2 -Pace

3

4 1-1 Location of the Proposed American Centrifuge Plant ................................... 1-1

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

6

7 2-1 Location of the Proposed ACP Site ........................... 2-3

8 2-2 Schematic of a Gas Centrifuge .............................. ;: 2-4

9 2-3 Locations of Proposed ACP Facilities ............................. 2-7

10 2-4 Locations of Process Buildings and other Primary Facilities .............................. 2-8

11 2-5 Locations of Cylinder Storage Yards ............................................... 2-13

12 2-6 Incoming UF6 Feed Material ................ ..................................... 2-23

13 2-7 Enrichment Operations Flow ................ ..................................... 2-24

14 2-8 Destination of Outgoing Customer Product ........................................... 2-26

15 2-9 Example of Depleted UF6 Cylinders ............ .................................... 2-32

16 2-10 Location of the Paducah Gaseous Diffusion Plant in Paducah, Kentucky ..... ............. 2-37

17 2-11 Altemative Sites at the DOE Reservation for the Proposed ACP ........................ 2-43

18 2-12 Electromagnetic Isotopic Separation Process ........................................ 2-45

19 2-13 Liquid Thermal Diffusion Process ............ .................................... 246

20 2-14 Gaseous Diffusion Stage ........................................................ 246

21 2-15 Atomic Vapor Laser Isotope Separation Process ...................................... 2-47

22

23 3-1 Proposed ACP Site and Surrounding Areas ........................................... 3-2

24 3-2 Land Use Surrounding the DOE Reservation at Piketon ................................. 3-4

25 3-3 Quadrants Investigated at the DOE Reservation at Piketon ............................... 3-8

26 3-4 View of the X-7725 and X-7727H Facilities [Looking East] ............................. 3-12

27 3-5 View of the X-7725 Facility [Looking Southwest] .................................... 3-13

28 3-6 View of the X-3001 and X-3002 Process Buildings [Looking Northeast] ..... .............. 3-13

29 3-7 Site of X-3346A Feed and Product Shipping and Receiving Building [Looking South] .... .... 3-14

30 3-8 Wind Rose at 30 Meters (98 feet) from the Onsite Meteorological Tower, 1998-2002 ......... 3-16

31 3-9 Site Geology in the Vicinity of the DOE Reservation at Piketon .......................... 3-23

32 3-10 Surface Water Features at the DOE Reservation at Piketon ............................. 3-26

33 3-11 United States Enrichment Corporation National Pollution Discharge Elimination System

34 Outfalls at the DOE Reservation at Piketon ......................................... 3-29

35 3-12 Floodplains at the DOE Reservation at Piketon ...................................... 3-33

36 3-13 Well Fields at the DOE Reservation at Piketon ...................................... 3-35

37 3-14 Habitat Areas and Wetlands on and Near the Proposed ACP Site ........................ 3-38

38 3-15 Population Centers in the Vicinity of the DOE Reservation ............................ 344

39 3-16 Population Density Surrounding the DOE Reservation at Piketon ....................... 3-45

40 3-17 Social Service Centers within 8 Kilometers (5 Miles) of the DOE Reservation at Piketon ..... 3-51

xiii
-

1 3-18 Census Tracts with Minority and Low-Income Populations within a 80-Kilometer

2 (50-Mile) Radius of the Proposed ACP Site ......................................... 3-57

3 3-19 Transportation Routes In and Out of the DOE Reservation ......... .................... 3-62

4

5 6-1 United Stated Enrichment Corporation National Pollutant Discharge Elimination System

6 Outfalls at the DOE Reservation at Piketon ........................................... 6-7

7 6-2 Locations of Routine Surface Water Sampling Locations ............. ................... 6-8

8 6-3 Locations of Stream Sediment Sampling Points ........................................ 6-9

9 6-4 Locations of Soil and Vegetation Sampling Points ................... ................. 6-10

xiv

Il
I 'LIST OF TABLES

2 Page

3

4 1-1 Projected Uranium Enrichment Demand in the U.S. for 2002-2025 in Million SWUs . 1-4

5 1-2 State of Ohio Environmental Requirements ................................. 1-15

6 1-3 Potentially Applicable Requirements for the Construction and Operation of the American

7 Centrifuge Plant .......... 1-20

8

9 2-1 American Centrifuge Plant Facilities ............................. 2-6

10 2-2 Refurbishment Activities for the Proposed ACP . ............................ 2-18'

11 2-3 Waste Generation during Refurbishment and Construction .; 2-20

12 2-4 Solid Waste Generation during Manufacturing .......... .................. 2-22

13 2-5 Expected Product Recipients ...................................... 2-27

14 2-6 Solid Waste Generated during Facility Operations ....................................... 2-32

15 2-7 Comparison of Environmental Impacts at Alternative Site Locations .......................... 2-38

16 2-8 Summary of Environmental Impacts for the Pioposed ACP and the No-Action Alternative .... 2-49

17-

18 3-1 Percentage of Different Land Uses in the Region of Influence in 2000 ...... ................ 3-4

19 3-2 Average Morning and Afternoon Mixing Heights for Huntington, West Virginia ..... ......... -3-17

20 3-3 National Ambient Air Quality Standards ................................ ;.-.3-17

21 3-4 Nonradiological Air Emissions from United States Enrichment Corporation and DOE Sources

22 at the DOE Reservation in 2001 .................. 3-20

23 3-5 United States Enrichment Corporation's Non-Radiological Airborne Emissions .3-21

24 3-6 Background Air Concentrations .. ................................... I ' 3-22

25 3-7 Results of Baseline Soil Samples, 1998-2002 .................................... 3-24 '.. 

26 3-8 National Pollutant Discharge Elimination System Permit Operator, Description,

27 and Receiving Water Body . 3-28

28 3-9 National Pollutant Discharge Elimination System Permit and Monitoring

29 Parameters ...... 3-30

30 3-10 Terrestrial Habitat Types at the DOE Reservation at Piketon ................ 3-37

31 3-11 Federal and State Listed Endangered, Potentially Threatened, and Special Concern Species

32 near the DOE Reservation at Piketon ..... ' .................. 3-40

33 3-12 Wetlands on the DOE Reservation Associated with the Proposed Action . . ' 341

34 3-13 Population in the Proposed ACP Region of Influence and Ohio in 1990, 2000, and 2010 ..... 3-46

35 3-14 Employment in Pike County by Industry in 1990 and 2000 ............................... 3-47

36 3-15 Employment in Scioto County by'Industry in 1990 and 2000 ............... ............. 3-48

37 3-16' Employment in Jackson'County by Industry in 1990 and 2000.3-48

38 3-17 Employment in Ross County by Industry in 1990 and 2000 ................. ............... 3-49

39 3-18 Unemployment Rates (%) ...................... ';.;.'.'.-...3-49

40 3-19 Personal Income'in the Region of Influence, 1990, 2000, and 2002 .............. I ........ 3-50

41 3-20 Region of Influence Housing Characteristics, 2000 ..................................... 3-52

42 3-21 School District Data for the Region of Influence in 2000 ................................ .3-53 .

43 3-22 Physicians and Hospitals in the Region of Influence in 2000 ........... ' . ' .. 3-54

xv
1 3-23 Capacity of Landfills in the Region of Influence ..................................... 3-55

2 3-24 Census Tracts Exceeding Minority Criteria ......................................... 3-58

3 3-25 Poverty Thresholds in 2004 (Annual Income in $) .................................... 3-59

4 3-26 Census Tracts Exceeding Low-Income Criteria ...................................... 3-60

5 3-27 U.S. Department of Housing and Urban Development Land Use Compatibility Guidelines

6 for Noise ................................................................ 3-61

7 3-28 Death Rate/Trend Comparison, All Cancers, Death Years Through 2001 ..... ............. 3-68

8 3-29 Age-Adjusted Mortality Rates for Renal Failure .......... ........................... 3-69

9 3-30 Projected Waste Generation Volumes for the DOE Reservation at Piketon ..... ........... 3-71

10 3-31 DOE-Managed Depleted Uranium Hexafluoride Cylinders at the DOE

11 Reservation at Piketon .............. 3-72

12

13 4-1 Predicted Property Boundary Air Concentrations from Site Preparation and Construction Activities

14 and Applicable National Ambient Air Quality Standards ................................ 4-11

15 4-2 Predicted Property Boundary Air Concentrations from Operation of 26 Emergency Diesel

16 Generators and Applicable National Ambient Air Quality Standards ...................... 4-13

17 4-3 Anticipated Radionuclide Concentrations in Liquid Effluents from Normal Operations ........ 4-23

18 44 2004 Traffic Conditions on Routes Adjacent to the Proposed ACP ........................ 4-41

19 4-5 Highways Trips Generated by Proposed ACP Site Preparation and Construction ..... ........ 4-42

20 4-6 Transportation Requirements During Site Preparation and Construction ..... .............. 4-44

21 4-7 Injury and Fatality Rates Per Vehicle Mile Traveled ................................... 4-44

22 4-8 Transportation Impacts From Site Preparation and Construction .......................... 4-45

23 4-9 Highways Trips Generated by Operation of the Proposed ACP .......................... 446

24 4-10 Transportation Requirements During Facility Operations .............................. 4-47

25 4-11 Transportation Impacts Per Year From Facility Operations ............................. 4-47

26 4-12 2010 U.S. Long- and Medium-Haul Heavy-Duty Trucks, Light-Duty Trucks, and Light-Duty

27 Vehicles Fleet Average Emission Factors ............................ 4-50

28 4-13 Vehicle Emissions Associated with Construction-Related Traffic at the DOE Reservation Entrance

29 (in 2010) ...... 4-51

30 4-14 Vehicle Emissions Associated with Operations-Related Traffic at the DOE Reservation Entrance

31 (in 2010) ..... 4-52

32 4-15 Estimated Latent Cancer Fatalities from the Transportation of Radioactive Materials for One Year

33 of Operation ....... 4-56

34 4-16 Potential Chemical Consequences to the Population from Severe Transportation Accidents ... 4-57

35 4-17 Health and Safety Statistics for Estimating Industrial Safety Impacts Common to the Workplace

36 and Total Incidents for Site Preparation and Construction .............. ................ 4-58

37 4-18 Health and Safety Statistics for Estimating Industrial Safety Impacts Common to the Workplace

38 and Total Incidents for Facility Operation .......................................... 4-61

39 4-19 Airborne Release Rates Assuming Enrichment of 5 Weight Percent of Uranium-235 .... .... 4-63

40 4-20 Annual Total Effective Does Equivalent from Air Releases During Operation Assuming

41 Enrichment of 5 Weight Percent of Uranium-235 ................................. 4-66

42 4-21 Predicted Airborne Concentrations of Uranium and Hydrogen Fluoride at Receptor Locations . 4-67

43 4-22 Thermoluminescent Dosimeter Gamma Radiation Readings for the Year 2003 ..... ........ 4-68

xvi

Il
1 4-23 Estimated Latent Cancer Fatalities from the Transportation of Decontamination and

2 Decommissioning Waste . ...................................................... 4-99

3 4-24 Other Activities Considered for Cumulative Impacts ................................. 4-102

4 4-25 Water Withdrawal and Discharge Rates ........................................... 4-107

5

6 5-1 Summary of Preliminary Mitigation Measures Proposed by USEC for Construction ..... ...... 5-2

7 5-2 Summary of Preliminary Mitigation Measures Proposed by USEC for Operation ..... ........ 5-3

8 5-3 Summary of Potential Mitigation Measures Identified by NRC for Construction ..... ......... 5-4

9

10 6-1 Guidance Documents that Apply to the Radiological Monitoring Program ..... .............. 6-1

11 6-2 Radiological Environmental Measurement and Monitoring Program Sampling Locations

12 Parameters and Frequency . ................................................. 6-2

13

14 7-1 Direct Costs Associated with Proposed Action Life-Cycle Stages ........ .................. 7-2

15 7-2 Socioeconomic Benefits Associated with the Proposed Action ........ .................... 7-5

xvii
1

2

EXECUTIVE SUMMARY

3 BACKGROUND

4

5 The U.S. Nuclear Regulatory Commission (NRC) is considering whether to issue a license, pursuant to

6 Title 10 of the U.S. Code of Federal Regulations (10 CFR) Parts 30,'40, and 70, that would allow USEC

7 Inc. (USEC) to possess and use byproduct material, source material, and special nuclear material at a

8 proposed gas centrifuge uranium enrichment facility near Piketon, Ohio. The scope of activities to be

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

10 proposed plant, which is called the Americarf Centrifuge Plant (ACP). This licensing action would be

II taken in response to an application filed with-the NRC by USEC by letter dated August 23, 2004. To

12 support its licensing decision on the proposed ACP, the NRC determined that an Environmental Impact

13 Statement (EIS) is required by the NRC's implementing regulations in 10 CFR Part 51 for the National

14 Environmental Policy Act (NEPA).

15 ;

16 The enriched uranium produced at the proposed ACP would be used to manufacture nuclear. fuel for

17 commercial nuclear power reactors. Enrichment is the process of increasing the concentration of the

18 naturally occurring and fissionable uranium-235 isotope. Uranium ore usually contains approximately

19 - 0.72 weight percent uranium-235. In order to be useful in nuclear power plants as fuel for electricity

20 generation, the uranium must typically be enriched up to 5 weight percent.

21

22 - THE PROPOSED ACTION

23

24 The proposed action considered in this Draft EIS is for the NRC to issue a license that would authorize

25 USEC to possess and use special nuclear material, source material, and byproduct material at the ACP, a

26 gas centrifuge uranium enrichment facility proposed to be located on the U.S. Department of Energy

27 (DOE) reservation near Piketon, Ohio. Piketon is between Chillikothe and Portsmouth, Ohio,

28 approximately 113 kilometers (70 miles) south of Columbus, Ohio. If a license is issued, USEC would

29 construct, operate, and decommission the proposed ACP. The ACP would be located at the same site as

30 DOE's Portsmouth Gaseous Diffusion Plant, which has been shut down'sirice May 2001. The ACP

31 would consist of refurbished existing buildings, newly constructed facilities, and adjacent grounds owned

32 by DOE and leased by USEC.

33

34 In its license application, USEC indicated that the proposed ACP would utilize centrifuge technology to

35 enrich uranium-235 up to 10 weight percent, although enrichment would typically be between 2.5 and 5

36 weight percent uranium-235. The license application is for a 3.5 million separative work'units (SWU) per

37 year facility. However, because USEC indicated the potential for future expansion to 7 million SWU per

38 year, this Draft EIS examines the potential impacts of a full 7-million SWU facility. Depending on the

39 timing of the NRC licensing process and other factors, USEC plans to start construction of the proposed

40 ACP in 2007, begin commercial centrifuge operations in 2009, and ramp up to the 3.5 million SWU

41 design capacity by 2011. The NRC license, if granted, would be for 'a period of 30 years. After the

42 proposed ACP becomes operational, production of enriched uranium would ultimately cease at the

43 gaseous diffusion plant in Paducah, Kentucky and be replaced by the proposed new gas centrifuge

44 process at Piketon.

Xix
I PURPOSE AND NEED FOR THE PROPOSED ACTION

2

3 The purpose of the proposed action would be to allow USEC to construct and operate a plant to enrich

4 uranium up to 10 percent by weight of uranium-235, with an initial production capacity of 3.5 million

5 SWU per year potentially expandable to 7 million SWU per year, using gas centrifuge technology at the

6 DOE reservation in Piketon, Ohio. The proposed action is intended to satisfy the overall need for an

7 additional reliable and economical domestic source of enriched uranium and to replace existing aging and

8 less efficient uranium enrichment facilities.

9

10 For the purpose of this Draft EIS, the need for the proposed ACP can be organized more specifically into:

11 (1) the need for enriched uranium to fulfill electricity requirements; (2) the need for domestic supplies of

12 enriched uranium for national energy security; and (3) the need for upgraded uranium enrichment

13 technology in the U.S. The proposed action fulfills each of these needs as explained below.

14

15 By 2020, the U.S. is estimated to need about 393 gigawatts or 393,000 megawatts of new generating

16 capacity. To meet this growing demand, installed nuclear-generating capacity in the U.S. is projected to

17 increase from approximately 98 gigawatts (98,000 megawatts) in 2001 to about 103 gigawatts (103,000

18 megawatts) in 2025, which is the equivalent of about five large nuclear power reactors. While this

19 demand for enriched uranium is going up, the supplies of enriched uranium currently used in the U.S. are

20 on the decline. In particular, the Megatons-to-Megawatts program, which currently supplies

21 approximately 42 percent of the U.S.'s enriched uranium needs by "down blending" uranium from

22 dismantled nuclear warheads from Russia, is only planned to continue until 2013. Enriched uranium will

23 have to come from one or more new sources, such as the proposed ACP, to fulfill the shortfall in supply

24 that may exist after that time.

25

26 Foreign sources currently provide as much as 86 percent of U.S. enriched uranium needs. This includes

27 42 percent from the Megatons-to-Megawatts program with Russia as noted above, along with 44 percent

28 from other countries that produce and export enriched uranium to the U.S., including China, France,

29 Germany, the Netherlands, and the United Kingdom. The only uranium enrichment facility currently

30 operating in the U.S. is the Paducah Gaseous Diffusion Plant. A supply disruption with the Paducah plant

31 production could impact national energy security because domestic commercial reactors, which currently

32 supply approximately 20 percent of the nation's electricity requirements, would be fully dependent on

33 foreign sources for enriched uranium. The proposed ACP, therefore, would help decrease this

34 dependence on foreign sources and improve the nation's national energy security.

35

36 In addition to advancing national energy security goals, development of the proposed ACP would help

37 accomplish the goals of the June 17, 2002 DOE-USEC Agreement to "facilitate the deployment of new,

38 cost effective advanced enrichment technology in the U.S. on a rapid schedule." It would enable USEC

39 to construct and operate a modern, more efficient, less costly enrichment plant to supplement and replace

40 its more than 50-year old gaseous diffusion plants. .Gas centrifuge technology represents a more efficient

41 and less energy intensive uranium enrichment technology than the gaseous diffusion technology currently

42 in use. According to USEC, the energy requirements of a gas centrifuge plant are about five percent of

43 that required by a comparably sized gaseous diffusion plant, resulting in considerably lower operating

44 cost. Moreover, increasing production levels at the Paducah Gaseous Diffusion Plant to meet growing

45 needs for domestic supplies of enriched uranium may not even be technically feasible given the maturity

46 of the plant and its dated technology.

xx

I'
I 'ALTERNATIVES

2

3 This Draft EIS evaluates the potential environmental impacts of several alternatives, including the no4 action alternative. Under the no-action alternative, the proposed ACP would not be constructed, operated,

5 and decommissioned at the DOE reservation in Piketon, Ohio. Enriched uranium needs would continue

6 ''to be met'with existing domestic and foreign uranium enrichment suppliers. Any future uses of facilities

7 and grounds currently proposed for the ACP would be up to USEC and DOE, but would be expected to

8 include similar activities within the nuclear fuel cycle, consistent with USEC's and the reservation's

9 history and mission.

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

The NRC staff considered several alternatives to fulfill domestic enrichment needs:

(1) Construct and operate the'ACP at the Paducah Gaseous Diffusion Plant in Paducah, Kentucky;

(2) Construct and operate the ACP at alternative locations at the DOE reservation in Piketon, Ohio;

(3) Down blend highly enriched uranium instead of constructing a domestic uranium enrichment plant;

(4) Re-activate the Gaseous Diffusion Plant at the DOE reservation in Piketon; and

(5) Purchase low-enriched uranium from foreign sources.

These alternatives were eliminated from further consideration in this Draft EIS because they either did not

offer any environmental advantage over the proposed action, or did not meet the need for a reliable,

- economical source of domestic uranium enrichment.

The NRC staff also considered alternative technologies to the proposed gas centrifuge process. These

technologies included the electromagnetic isotope separation process, liquid thermal diffusion, atomic

vapor laser isotope separation, and the separation of isotopes by laser excitation. These technologies,

however, are not economically viable or remain at the research developmental scale and were thus

eliminated from further consideration.

POTENTIAL ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION

- Potential environmental impacts of the proposed action are evaluated in Chapter 4 of this Draft EIS and

summarized below. The environmental impacts from the proposed action are generally SMALL,

although they could be as high as MODERATE in the areas of air quality, socioeconomics, and

transportation. Methods for mitigating the potential impacts are described in Chapter 5. Environmental

monitoring methods are described in Chapter 6.

Land Use

Small Impact. Site preparation and construction activities would occur on approximately 22 hectares (55

acres) of land, which comprises about one percent of the total 1,497 hectare (3,700 acre) POE

reservation. These changes would convert previously disturbed land (e.g., managed lawns, fields, and

forests) on the DOE reservation to developed areas. The land is not considered prime farmland, and

changes would be consistent with current land use. It is anticipated that after decommissioning activities

xxi
I are completed, existing buildings and structures

2 would remain onsite and the site would remain Determination of the Significance of Potential

3 categorized for industrial use. Environmental Impacts

4

5 Historic and Cultural Resources A standard of significance has been established

6 for assessing environmental impacts. Based on

7 Small Impact. NRC identified the Portsmouth the Council of Environmental Quality's

8 Gaseous Diffusion Plant historic district, thirteen regulations, each impact is to be assigned one of

9 historic farmsteads, and one prehistoric lithicthe following three signi cance levels:

10 scatter as being potentially eligible for inclusion

11 on the National Register of Historic Places. In * Small: The environmental effects are not

12 addition, NRC included three properties located detectable or are so minor that they would

13 around the perimeter in its consideration of neither destabilize nor noticeably alter any

14 potential effects. There would be no adverse important attribute of the resource.

15 indirect or direct effect on these sites. In * Moderate: The environmental effects are

16 addition, construction of new buildings and sufficient to noticeably alter but not

17 refurbishment of existing buildings would result destabilize important attributes of the

18 in buildings of design, size, and function similar resource.

19 to the existing buildings, and therefore would not clearly noticeable and are sufficient to

20 alter the historic setting of the existing Gaseous destabilize important attributes of the

21 Diffusion Plant.

22 resource.

23 Any additional disturbance of the site during

24 decommissioning is not anticipated to have

25 impacts to historic and cultural resources that exceed those associated with construction of the proposed

26 ACP. Any changes to or demolition of buildings or structures proposed to be conducted during

27 decommissioning would be evaluated for historic and cultural resources impacts prior to any

28 implementation.

29

30 Visual and Scenic Resources

31

32 Small Impact. Construction of the proposed ACP would not alter the site's Bureau of Land Management

33 Visual Resources Management rating system classification of Class III or IV (moderate to little scenic

34 value). There are no scenic rivers, nature preserves, or unique visual resources in the proposed project

35 area. While not anticipated, any changes to, or demolition of, buildings or structures proposed during

36 decommissioning would be evaluated for visual and scenic resource impacts prior to. any implementation.

37

38 Air Quality

39

40 Small to Moderate Impact. Airborne emissions from site preparation and construction should not result in

41 exceedances of air quality standards, with the possible exception of short-termn increases in particulate

42 matter that could exceed the applicable standard up to a distance of 1,000 meters (3,280 feet) beyond the -

43 fenceline. Radiological releases from soil disturbances and from activities to refurbish existing buildings

44 that would be used for the ACP would be small and controlled. Emissions from diesel generators would

45 not cause air quality problems, and maximum predicted concentrations of hydrogen fluoride resulting

46 from ACP operations are below safe levels. Based on the maximum radiological emission rates for the

47 ACP, and the comprehensive site monitoring program, the expected impact to air quality from the plant's

48 radiological emissions during operations is also expected to be small. The air quality impacts associated

xxii

Il
I with decontamination and decommissioning are expected to be less than the air quality impacts associated

2 with site preparation and construction and proposed ACP operations; however, there is the potential for

3 emission of solvents during the decontamination phase if solvent cleaning methods are used. These

4 emissions would be of short duration (i.e., a few weeks) and would probably involve small amounts of

5 solvent.

6

7 Geology and Soils

8

9 Small Impact. Most of the site is an existing industrial facility with altered natural soils. The soils are

10 cohesive and over-consolidated and have low potential for liquefaction. There is little likelihood of

11 impact from soil compaction or subsidence and there are no unique mineral deposits or geologic resources

12 that stand to be affected.' The flat terrain where the ACP buildings would be located, and the dense soil,

13 low moisture contenit, and vegetative cover in the area of a new 10 hectare (24 acre) cylinder storage yard

14 to be located in another spot on the reservation make landslides unlikely. Construction activities would

15 not alter current drainage and would not disturb any soils that qualify for protection as prime farmland.

16 There would be a potential for increased erosion and siltation of streams near the'construction site of the

17 new large cylinder storage yard, but both of these potential impacts should be minimized by the use of

18 standard best management practices. Likewise, the potential for soil contamination resulting from ACP

19 operations would be small. A plan would be in place to address any spills that might occur.

20

21 - Impacts to geology and soils associated with the decommissioning of the proposed ACP are not

22 anticipated to exceed the geology and soils impacts associated with construction of the ACP. There is

23 potential for additional removal of contaminated surface soils from the site during decontamination and

24 decommissioning; however, any such surface removal is anticipated to be' limited in scope and not

25 anticipated to affect the site terrain or the subsurface.

26

27 Water Resources

28

29 Small Impact. Potential stream sedimentation from construction activities would be minimized by the use

30 of silt fences and other best management practices. Any impacts to stream water quality would be of

31 short duration. None of the proposed site preparation and construction activities would occur within a

32 100-year floodplain. Groundwater withdrawals would increase by 10 percent over current usage rates,

33 but would still be only 31 percent of the total design capacity of the site's well fields, would not affect

34 groundwater availability, and would not pose an increased risk of subsidence. Wastewater would

35 continue to discharge from permitted National Pollutant Discharge Elimination System outfalls and

36 discharge rates, though increased above current levels, would represent only 75 percent of the existing

37 system's design capacity. USEC does not anticipate any liquid discharges of radioactive materials from

38 the proposed ACP (i.e., from cooling water, storm water runoff, or sanitary water). The poten tial for

39 leaks or spills that could contaminate water resources would be limited by an approved Spill Prevention

40 Control and Countermeasures Plan.

41

42 Ecological Resources -

43

44 Small Impact. Construction of the new large cylinder storage yard referenced above in the section on

45 geology and soils would result in increased erosion, stormwater runoff, and loss of 10 hectares (24 acres)

46 of vegetation, but with planned best management practices, would result in small impacts to the flora and

47 fauna in and around the tributaries of Little Beaver Creek. That same cylinder storage yard would also be

48 located within 500 meters (1,640 feet) of suitable summer habitat for the endangered Indiana bat,

xxiii
l 1

1 although studies have not documented the presence of this bat species on the DOE reservation. None of

2 the site construction activities would occur in wetlands. However, some construction would occur

3 adjacent to small wetlands, and standard erosion control measures would be used to limit sedimentation in

4 these areas. Areas of reestablished vegetation may need to be cleared during site decommissioning (e.g.,

5 to conduct surface soil removal for site remediation). Any areas cleared of vegetation during

6 decommissioning are anticipated to be small and vegetation could reestablish itself in cleared unpaved

7 areas after decommissioning activities are completed.

8

9 Socioeconomics

10

11 Small Moderate to tmpact Ineachyear between 200 6 and 2010 , average annual employment as a result

12 of site preparation, refurbishment, and construction activities is estimated at 3,362 full-time jobs in the

13 region of influence. During the ACP operations phase between 2010 and 2040 1 , ,500 jobs would be

14 created in the region of influence. These impacts to regional employment are considered moderate, based

15 on existing employment levels in the region. All other socioeconomic impacts from site preparation and

16 construction and ACP operations are estimated to be small. This includes a small increase in regional tax

17 revenues as well as small impacts to population characteristics, housing resources, community and social

18 services, and public utilities.

19

20 Cessation of operations at the Paducah enrichment plant (assumed to occur with start-up of operations at

21 the ACP) would result in direct and indirect socioeconomic impacts associated with the termination of the

22 operations workforce at the plant and associated reduction in payroll. The impacts to regional

23 employment around the Paducah site are estimated to be moderate, but all other socioeconomic impacts in

24 the region are expected to be small.

25

26 Decontamination and decommissioning of the proposed ACP also would generally have small impacts.

27 As a result of such activities, an average of 841 direct and indirect jobs are expected to be created, of

28 which 407 would be new (the others would be filled by transitioned USEC workers). It is unlikely that

29 State income tax, State sales tax, and county-level tax revenues would significantly increase as a result of

30 the decontamination and decommissioning phase of the proposed action. Likewise, decontamination and

31 decommissioning activities are not expected to lead to a large influx of workers that could cause housing

32 shortages or increases in rental rates in the region. The small influx of workers would also have a small

33 effect on public utilities, fire, law enforcement, healthcare, and administrative levels of service.

34

35 Environmental Justice

36

37 Small Impact. The environmental justice analysis focused on an area within 80 kilometers (50 miles)

38 around the proposed ACP site. The analysis found that, within this area, there are 18 Census tracts that

39 have populations qualifying as low-income and two Census tracts that have populations qualifying as

40 minority. The closest of these tracts is 28 kilometers (17 miles) from the proposed site. Although the

41 impacts to the general population were small to moderate as summarized elsewhere in this section, an

42 examination of the various environmental pathways by which low-income and minority populations could

43 be affected found no disproportionately high or adverse impacts from construction, operation, or

44 decommissioning on any of these populations.

xxiv

l
I Noise

2

3 Small Impact. Site preparation and construction activities are expected to generate a 53 day-night average

4 noise level, which is below applicable land use compatibility guidelines. No adverse noise impacts from

5 routine ACP operations are expected at the closest residence due to low operational noise,'the attenuation

6 provided by the building facade, and distance attenuation of over 900 meters (3,000 feet). 'Catastrophic

7 failure of a centrifuge could cause a sudden but brief loud noise, due to the high rotational speed of the

8 centrifuge. However, the likelihood of a single centrifuge catastrophically failing is very low. Noise

9 levels during decontamination and decommissioning'are also anticipated to be small and similar to those

10 generated during construction of the proposed ACP.

11. , .* - .

12 Transportation

13

14 Small to Moderate Non-radioloeical Impacts from Routine Transportation. Increased truck and vehicle

15 traffic associated with proposed ACP operations should result in small changes in current levels of

16 congestion and delays on U.S. Route 23 and Ohio State'Road 32. Traffic associated with proposed

17 operations should also result in small increases in the number of traffic accidents resulting in injuries or

18 fatalities.

1 9

20 Substantially greater transportation requirements during the construction phase could result in moderate

21 impacts during the five-year period in which most of the proposed construction activity is projected to

22 occur. The NRC estimates that increased traffic during construction would temporarily decrease the level

23 of service on U.S. Route 23 and, to a lesser extent, on Ohio State Road 32. The changes on U.S Route 23

24 would temporarily increase traffic density, affect the ability to maneuver within the traffic stream, and

25 reduce travel speeds somewhat. It is also expected that construction traffic accidents would result in

26 about 18 injuries a year involving employees traveling to and from theirjobs, and 'one fatality over the

27 entire construction period. These same injury and fatality rates would be expected if the same employees

28 were driving to different employers.

29

30 Small Radiological Impacts from Routine Transportation and Transportation Accidents. The

31 transportation of materials containing radionuclides would result in some increased risk of cancer to both

32 the occupational workers transporting and handling the material and to members of the public driving

33 along the roads or living along the transportation routes. The transport of all materials is estimated to

34 result in approximately 0.013 latent cancer fatalities per year of operation from exposure to direct

35 radiation during "incident-free" transport (i.e.,shipping that does not involve the breach of a shipping

36 container and subsequent release of radioactive material), and an additional 0.008 latent cancer fatalities

37 per year from accidents that result in the release of radioactive material into the environment. The total

38 latent cancer fatalities is estimated to be 0.02 per year of operation or less than one cancer fatality over the

39 30 years of operation.

40

41 Moderate Non-Radiolopical Impacts from Transportation Accidents. Transportation accidents involving

42 the release of uranium hexafluoride (UF6), which is the form of uranium that would be transported the

43 most to and froni the proposed ACP, could also result in chemical impacts to drivers and the surrounding

44 public., When released'from'a shipping cylinder, UF6 reacts with the moisture in the atmosphere to form

45 hydrogen fluoride and uranyl fluoride, both of which can cause adverse effects due to chemical toxicity

46 (as opposed to radiation hazards) if exposures are high enough. The analysis in Section 4.2.11.1 of this

47 Draft EIS shows that the probability of a severe transportation accident that releases sufficient quantities

48 of U16 that could pose a health risk is low, but that the consequences of such an accident, should it occur,

xxv
I are high. Based on this analysis, the impacts associated with such an accident as part of the proposed

2 action are considered moderate.

3

4 Small Impact During Decontamination and Decommissioning. Traffic associated with material and

5 equipment transportation to the site during this phase would be much lower than that during site

6 preparation and construction. Decontamination and decommissioning activities, including waste

7 generation and handling, would require almost 5,000 truck shipments for offsite disposal over the five8 year decommissioning period proposed by USEC. Because this volume of truck traffic is far less than the

9 estimated 17,870 truck trips needed during the five-year proposed ACP construction period, the

10 transportation impacts associated with the decommissioning truck traffic should be far less than that

11 described for site preparation and construction. The number of latent cancer fatalities from the incident12 free transportation of all decontamination and decommissioning waste is estimated to be less than one,

13 and there are no projected deaths resulting from the release of radioactive material as a result of accidents

14 during such shipments.

15

16 Public and Occupational Health and Safety

17

18 Small Timpact. The proposed action would result in small increases in the current number of occupational

19 injuries and illnesses at the site, though still less than historical levels. Construction and process areas

20 would be segregated, and personnel monitoring programs would be implemented, to minimize worker

21 exposures to annual radiation doses of less than the 10 CFR § 20.1201 limit of 50 millisieverts (5,000

22 millirem). All routine radiation exposures to members of the public are expected to be significantly

23 below the 10 CFR Part 20 regulatory limit of I millisievert (100 millirem) and 40 CFR Part 190

24 regulatory limit of 0.25 millisieverts (25 millirem) for uranium fuel-cycle facilities. Analytical results

25 also indicate that plausible radiological accidents at the proposed ACP pose acceptably low risks. In

26 addition, public and occupational exposures to non-radiological contaminants are projected to be less than

27 applicable limits.

28

29 Occupational exposures during onsite decontamination and decommissioning would be bounded by the

30 potential exposures during operation. At the end of plant life, gas centrifuges containing residual uranium

31 would be purged, leaving radioactive material in amounts significantly less than handled during

32 operations. Because systems containing this residual contamination would be opened, decontaminated

33 (with the removed radioactive material processed and packaged for disposal), and dismantled, an active

34 environmental and dosimetry (external and internal) program would be conducted to maintain as low as

35 reasonably achievable doses to workers and doses to individual members of the public as required by 10

36 CFR Part 20.

37

38 Waste Management

39

40 Small Impact. Site preparation, construction, and operations would generate varying amounts of low41 level radioactive, low-level mixed, hazardous, sanitary/industrial, and recyclable wastes. All of these

42 wastes would be managed in accordance with existing procedures for controlling contaminant releases

43 and exposures. With the exception of the depleted uranium, all of the wastes would also be generated at

44 volumes that are well within existing management capacities. The ACP would generate approximately

45 42,800 cylinders of depleted UF6, containing approximately 571,000 metric tons (630,000 tons) of

46 material. Production of depleted UF6 for the 10 percent enrichment scenario would be less than this

47 amount. All of this depleted UF6 could be converted to a more stable form at a new conversion facility

48 that DOE is constructing at Piketon, which would require DOE to significantly extend the life of this

xxvi

Il
I facility. The converted material would then be shipped by rail to an acceptable western disposal site,

2 where sufficient capacity exists and where the disposal impacts should be small. The waste management

3 and recycling programs used during operations would also apply to decontamination and

4 decommissioning.

5

6 SUMMARY OF THE COSTS AND BENEFITS OF THE PROPOSED ACTION

7

8 The proposed action would result in both direct and indirect costs. The direct costs can be categorized by

9 facility life-cycle stages:

10

11 * Site preparation and construction is estimated to incur costs of $1,449 million (nominal dollars, i.e.,

12 dollars that are not adjusted for inflation) between calendar years 2006 and 2010;

13

14 * Centrifuge manufacturing and assembly is estimated to cost $1,423 million (nominal dollars) between

15 calendar years 2004 and 2013; and

16

17 * Decontamination and decommissioning is estimated to cost $435 million (2004 real dollars, i.e.,

18 dollars stated in year 2004 price levels) over a period of six years, which are expected to begin 30

19 years after the commencement of ACP operations and are expected to occur from 2040 through 2045.

20

21 Indirect costs include the environmental impacts that are expected to be caused by the proposed action.

22 As summarized in the preceding section, these impacts are generally considered small, although they

23 could be as high as moderate in a few resource areas.

24

25 The primary benefit of the proposed action is that it would result in the production of 3.5-7 million SWUs

26 of enriched uranium between 2010 and 2040. The ACP operating costs per SWU would be

27 . approximately 20 percent of the operating costs per SWJU of a gaseous diffusion plant. .This level of

28 production would represent an augmentation of the domestic supply of enriched uranium and would meet

29 the following needs:

30

31 * The need for enriched uranium to fulfill domestic electricity requirements and replace the shortfall in

32 supply created by the end of the Megatons-to-Megawatts program planned in 2013;

33

34 * The need for domestic supplies of enriched uranium for national energy security; and

35

36 * The need for upgraded uranium enrichment technology in the United States to replace the existing

37 aging and less efficient gaseous diffusion plants.

38

39 At the same time, the proposed action would result in positive socioeconomic impacts in the region

40 around Piketon. During the site preparation and construction phase between 2006 and 2010, these

41 impacts include the creation of 3,362 full-time jobs, an increase of $2.3 million in annual state income tax

42 revenues, and an increase in $3.7 million in annual state sales tax receipts. During the ACP operations

43 phase between 2010 and 2040, 1500 jobs would be created in the region and the State would benefit from

44 $1.8 million and $2.4 million in additional annual income and sales tax receipts, respectively.

45

46 Overall, the costs of the proposed action are estimated to be small in comparison to the benefits fo the

47 proposed action. Therefore, the benefits of the proposed action are believed to outweigh the costs of the

48 proposed action.

xxvii
I COMPARISON OF ALTERNATIVES

2

3 The no-action alternative would consist of USEC not constructing, operating, or decommissioning the

4 proposed ACP at Piketon. The buildings and land proposed to be used for the ACP at the DOE

5 reservation in Piketon would therefore be available for some other use. At the same time, the uranium

6 fuel fabrication facilities in the United States would continue to obtain low-enriched uranium from

7 currently available sources, including the Paducah Gaseous Diffusion Plant and the down blending of

8 highly enriched uranium under the Megatons to Megawatts program. In order to meet growing demands

9 for enriched uranium, additional domestic enrichment facilities utilizing a more efficient technology in

10 the future could be constructed. This could include the gas centrifuge facility proposed by Louisiana

11 Energy Services near Eunice, New Mexico, as well as other possible facilities. The associated impacts

12 associated with the existing uranium fuel cycle activities in the United States would continue as expected

13 today if the proposed ACP is not constructed, operated, or decommissioned.

14

15 The no-action alternative would have small local impact on historic and cultural resources; visual and

16 scenic resources; air, water, and ecological resources; geology and soils; environmental justice;

17 transportation; public and occupational health; and waste management. For land use, the facilities

18 currently leased to USEC for the ACP would remain leased to USEC. Some of these facilities would

19 likely continue to be used for the Lead Cascade Demonstration Facility, which is currently scheduled to

20 operate until the middle of 2008 in order to continue to provide a demonstration of the gas centrifuge

21 enrichment process. Any future uses of the facilities currently proposed for the ACP would be up to

22 USEC and DOE, but would be expected to include similar activities within the nuclear fuel cycle, not

23 completely different uses. Nevertheless, the current program for examining and implementing

24 reindustrialization alternatives at the DOE reservation would remain in place under the no-action

25 alternative.

26

27 Adverse socioeconomic effects of the no-action alternative to the Piketon region would include a missed

28 opportunity for approximately 1,500 direct and indirect jobs during the 30-year operations phase, 3,362

29 direct and indirect jobs during the five-year construction phase, and 2,130 direct and indirect jobs during

30 the 10-year manufacturing phase that would have been created by the proposed action. The cessation of

31 enrichment operations at Paducah and the corresponding socioeconomic impacts in that region would be

32 postponed, but would likely occur sometime later when new enrichment facilities are expected to be built

33 to meet the nation's growing demand for enriched uranium. Depending on the construction methods,

34 design of any new facilities, and local demographics, the likely socioeconomic impacts would be similar

35 to the proposed action, but at an alternate location.

36

37 In comparison to the no-action alternative, the proposed action would also have small impacts on land

38 use; historical and cultural resources; visual and scenic resources; geology and soils; water resources;

39 ecological resources; environmental justice; noise; public and occupational health; and waste

40 management. Air quality impacts could be small to moderate due to short-term increases in particulate

41 matter emissions from dust during construction. Transportation impacts of the proposed action are

42 expected to be small to moderate, accounting for increased traffic during construction and the possibility

43 of a severe accident releasing significant quantities of UF6, as described above.

xxviii

1l
I ACRONYMS AND ABBREVIATIONS

3 ACP American Centrifuge Plant

4 CFR Code of Federal Regulations

5 DOE Department of Energy

6 EIS Environmental Impact Statement

7 EPA Environmental Protection Agency

8 HF hydrogen fluoride

9 NEPA National Environmental Policy Act

10 NPDES National Pollutant Discharge Elimination System

11 NRC Nuclear Regulatory Commission

12 OAC Ohio Administrative Code

13 RCRA Resource Conservation and Recovery Act

14 SWU Separative Work Unit

15 UF6 uranium hexafluoride

16 U3 08 triuranium octaoxide

17 U02 uranium dioxide

18 USEC USEC Inc.

XXix
1

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8

9

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I11

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15

16

17

18

19

20

1. INTRODUCTION

1.1 Background

The U.S. Nuclear Regulatory Commission (NRC) prepared this Draft Environmental Impact Statement

(EIS) in response to an application submitted by USEC Inc. (USEC) for a license that would allow the

construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility in Piketon,

Ohio (Figure 1-1). The proposed facility is called the American Centrifuge Plant (ACP).

0 25 50 75 100MOKftM

0 25 50 75 tOO M"s

[MJ State Boundary

=l_ County Boundary

Figure 1-1 Location of the Proposed American Centrifuge Plant

The NRC's Office of Nuclear Material Safety and Safeguards prepared this Draft EIS as required by Title

10, "Energy," of the US. Code-of Federal Regulations (10 CFR) Part 51. These regulations implement

the requirements of the National Environmnental Policy Act of 1969, as amended (Public Law 91-190).

The Act requires the Federal Government to assess the potential environmental impacts of its proposed

actions.

1.2 The Proposed Action

The proposed action is the issuance of an NRC license for USEC under the provisions of the Atomic

Energy Act. The license would authorize USEC to possess and use' special nuclear material, source

material, and byproduct material at the proposed ACPjin accordance with the NRC's regulations in

1-I
ll r U-.

1 10 CFR Parts 70, 40, and 30, respectively. The scope of activities to be conducted under the license

2 would include the construction, operation, and decommissioning of the proposed plant.

3

4 USEC has proposed that the ACP be located in leased portions of the U.S. Department of Energy (DOE)

5 reservation in Piketon, Ohio. The Portsmouth Gaseous Diffusion Plant, which has been shut down since

6 May 2001, is also located on the DOE reservation in Piketon. The ACP would consist of refurbished

7 existing buildings, newly constructed facilities, and adjacent areas at the Portsmouth plant.

8

9 The proposed ACP is intended to help fulfill the terms of a DOE-USEC Agreement signed on June 17,

10 2002. Among other requirements, this agreement calls for USEC to deploy an advanced technology

11 enrichment plant, meet the need for lower cost production of enriched uranium, and replace the aging

12 gaseous diffusion technology formerly used at the Portsmouth plant and currently used to enrich uranium

13 at the Paducah Gaseous Diffusion Plant in Paducah, Kentucky. Both the Portsmouth and Paducah plants

14 are owned by DOE but operated by USEC's wholly owned subsidiary, the United States Enrichment

15 Corporation. After the proposed ACP becomes operational, production of enriched uranium would

16 ultimately cease at the Paducah plant and be replaced by the proposed new gas centrifuge process at the

17 Portsmouth site. Decontamination and decommissioning of facilities at Paducah currently leased to the

18 United States Enrichment Corporation would begin once the Paducah Gaseous Diffusion Plant ceases

19 operation (USEC, 2005).

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

Uranium ore usually contains

approximately 0.72 weight percent

uranium-235, and this percentage is

significantly less than the 3 to 5

weight percent uranium-235 required

by nuclear power plants as fuel for

electricity generation. Therefore,

uranium must be enriched in one of

the steps of the nuclear fuel cycle

(Figure 1-2) so it can be used in

commercial nuclear power plants.

Enrichment is the process of

increasing the percentage of the

naturally occurring and fissile

uranium-235 isotope and decreasing

the percentage of uranium-238.

Enriched U0 2 Fu e Fabricati

Tails | h

Proposed ACP: Enrichment

ion

Ught Water

Power Reactors

Reprocessing Federal

Waste

Repository

Uranium Mines & Mills

38 USEC's license application seeks Figure 1-2 Nuclear Fuel Cycle (NRC, 2004a)

39 authorization to produce enriched

40 uranium up to 10 percent by weight of uranium-235, although enrichment would normally be less than

41 5.5 percent by weight of uranium-235 to meet the needs of most power plants. Enriched uranium from

42 the proposed ACP would be used in commercial nuclear power plants, and is termed low-enriched

43 uranium in contrast to highly enriched uranium used in military reactors and nuclear weapons. The

44 proposed ACP would not alter the total amount of enriched uranium used in the U.S. nuclear fuel cycle

45 because the amount of enriched uranium produced at the proposed ACP would only substitute for

46 enriched uranium from other sources, as discussed further in this document.

47

48 USEC has requested a license for a production capacity of 3.5 million separative work units (SWUs) per

49 year. A SWU is a measure of enrichment in the uranium enrichment industry; it represents the level of

50 effort or energy required to raise the concentration of uranium-235 to a specified level, and is an indicator

51 of the amount of enriched uranium. Because USEC has indicated a potential for future expansion to 7.0

1-2

Il
I million SWU, this Draft EIS also examines the impacts of the additional construction and operations that

2 would increase the plant's production capacity to approximately 7 million SWUs annually.

3

4 1.3 Purpose and Need for the Proposed Action

5

6 The purpose of the proposed action would be to allow USEC to construct and operate a plant to enrich

7 uranium up to 10 percent by weight of uranium-235, with an initial production capacity of 3.5 million

8 SWUs potentially expandable to 7 million SWUs, using gas centrifuge technology at the DOE reservation'

9 in Piketon, Ohio. The proposed action is iniended to satisfy the overall need for an additional reliable and

10 economical domestic source of enriched uranium and to replace existing aging and less efficient

11 production facilities.

12

13 For the purpose of this Draft EIS, the need for the proposed ACP is organized by:

14

15 * The need for enriched uranium to fulfill electricity requirements;

16

17 * The need for domestic supplies of enriched uranium for national energy security; and

18

19 * The need for upgraded uranium enrichment technology in the U.S.

20

21 The following sections discuss each of these needs and how they are addressed by'the proposed action.

22

23 1.3.1 The Need for Enriched Uranium to Fulfill Electricity Require ments

24

25 Enriched uranium from the proposed ACP would be used in commercial nuclear power plants. Such

26 plants are currently supplying approximately 20 percent of the nation's electricity requirements (EIA,

27 2005). 'As the demand for electricity increase in the future, the need for enriched uranium to fuel nuclear '

28 -power plants is also expected to increase.

29

30 By 2020, the U.S. is estimated to need about

31 393 gigawatts or 393,000 miegawatts of new How Much Is A Megawatt?

32 generating capacity (DOE, 2003). To meet this

33 growing demand, installed nuclear-generating One megawvatt roughly provides enough

34 capacity in the U.S. is projected to increase frmhomes.

35 approximately 98 gigawatts (98,000 megawatts) The actual number is based on the season, time

36 in 2001 to about 103 gigawatts (103,000 -of day, region of the country, power plant

37 megawatts) in 2025. This amounts to an increase capacityfactors, and otherfactors.

38 in U.S. nuclear capacity of more than 5 gigawatts Source: Bellemare, 2003.

39 (5,000 megawatts), which is the equivalent of * _Source: ____________2003._,

40 adding about five large nuclear power reactors.

41 In'actuality, approximately 3.5 gigawatts

42 (3,500 megawatts) of the new capacity is projected to come from the uprating of existing plants, rather

43 than constructing new facilities (EIA, 2005).' As of June 2004, the NRC had granted 102 uprates and was

44 reviewing 10 uprate applications (NRC, 2004b). As a further indicator of the growth in nuclear45 generating capacity, domestic nuclear facilities reported a record high median three-year design electrical

46 rating capacity factor1 of 89.7 percent for the period 2001-2003 as compared to 70.8 percent for the

47 period 1989-1991 (Blake, 2004).

' This factor reflects the amount of energy a facility generates in one year divided by the total amount it could

generate if it ran at full capacity.

1-3
1 These forecasts of nuclear power generating

2 capacity suggest a continuing, if not

3 increasing, demand for enriched uranium.

4 Table 1-1 shows uranium enrichment

5 requirements in the U.S. for the next two

6 decades as forecasted by the Energy

7 Information Administration. The Energy

8 Information Administration forecast shows a

9 growth in demand from 11.5 SWUs in 2002 to

10 14.2 SWUs in 2025.

11

12 The demand for enriched uranium in the U.S.

13 is currently being fulfilled by three main

14 categories of supply:

15

16 * Domestic production of enriched uranium.

17 The only uranium enrichment facility

18 currently operating in the U.S. is the

in >lehGn~iCnfienn lnnt-6 ()N_

Table 1-1 Projected Uranium Enrichment

Demand in the U.S. for 2002-2025

in Million SWUs

Year Forecast2002 * 11.5 (actual) b _ .. _.........._ ... _.. _.._ . . ........... .

2003 12.0 (actual) b _ .. __ .............. . . . . . .. _. _._....

2005 * 14.6 ..... . ....... . .. . ..... . ...... ..... .... ._.

2010 12.9 ....................... ........ ............. _._ .. ___

2015 15.4 . . ..... ... . . . .... _. ..........

2020 13.5 ........ . ......................... 24 . ............................. 2

2025 .14.2

1Y

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49

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51

rauuuL~u1 'aauu. L/I1EU IUU rla. ''l' Notes:

other enrichment facility presently exists EIA - Energy Information Administration.

in the U.S., the Portsmouth Gaseous - EIA, 2003.

Diffusion Plant, but it ceased production in b EIA, 2004a.

May 2001 and is in cold standby (a

condition under which the plant could be returned to a portion of its previous production capacity in

approximately 18-24 months).

* The Meizatons-to-Megawatts program. Under this program, the United States Enrichment

Corporation implements the 1993 government-to-government agreement between the U.S. and Russia

that calls for Russia to convert 500 metric tons (550 tons) of highly enriched uranium from

dismantled nuclear warheads into low-enriched uranium. This is the equivalent of about 20,000

nuclear warheads. The United States Enrichment Corporation purchases the enriched portion of the

"down blended" material, tests it to make sure it meets specifications, adjusts the enrichment level if

needed, and then sells it to its electric utility customers for fuel in commercial nuclear power plants.

The activities in the United States all now take place at the Paducah plant. (USEC, 2004a)

* Other foreian sources. Other countries that produce and export enriched uranium to the U.S. include

China, France, Germany, the Netherlands, and the United Kingdom.

The Paducah facility and Russian highly enriched uranium supply via the United States Enrichment

Corporation provide approximately 56 percent of the U.S. enrichment market needs (USEC, 2004b), with

the remaining 44 percent supplied by other foreign sources. Of the 56 percent supplied by the United

States Enrichment Corporation, approximately 14 percent comes from the Paducah Gaseous Diffusion

Plant (EIA, 2004a) and the remainder comes from the highly enriched uranium agreement, which is itself

dependent on deliveries from Russia. Taken together, this means that foreign sources presently provide

as much as 86 percent of U.S. enriched uranium needs (EIA, 2004a). Moreover, DOE anticipates "the

inevitable cessation of all domestic gaseous diffusion enrichment operations" due to the higher cost of

aging diffusion facilities like Paducah relative to new centrifuge technology (DOE, 2001a).

Existing U.S. sources will not be able to provide a dependable and economical domestic supply to meet

the continuing U.S. demand for enriched uranium in the future. The Megatons-to-Megawatts program is

only planned to be available until 2013, after which the nation could have a significant shortfall in supply

1-4

11
1 if the agreement is not renewed. Therefore, new domestic sources of enriched uranium are needed to

2 replace the aging, energy-intensive Paducah gaseous diffusion facility even if the Megatons-to-Megawatts

3 program is extended beyond 2013. The ACP proposed by USEC is one such facility. At a capacity of 3.5

4 million SWUs, the proposed ACP would provide roughly 25 percent of the projected U.S. enrichment

5 needs and allow the Paducah plant to be retired.- The National Enrichment Facility that Louisiana Energy

6 Services has proposed to build near Eunice, New Mexico, could provide another 3 million SWUs per

7 year. The NRC is evaluating the National Enrichment Facility as part of a separate proposed action

8 (NRC, 2005), and the combined output from the proposed ACP and National Enrichment Facility would

9 roughly offset the current output from the aging Paducah, Kentucky gaseous diffusion plant.

10

II Although the U.S. is a substantial net importer of enriched uranium, the United States Enrichment

12 Corporation also provides enriched uranium to foreign customers, which is indicative of utility customer

13 preferences for multiple suppliers. An exclusive focus on domestic supply and demand projections

14 clearly indicates a need for the ACP facility, but the reality of global trade in enriched uranium also

15 provides another context for assessing the significance of any potential domestic supply shortfall, because

16 global enrichment forecasts indicate that international supply and demand will be in very close balance

17 after 2010 (ERI, 2004; Grigoriev, 2002; NUKEM, 2002; DOE, 2001a; Combs, 2004). These enrichment

18 demand forecasts reflect global nuclear generation capacity forecasts and the Energy Information

19 Administration has subsequently increased its forecast for 2020 world nuclear generation capacity by

20 about 5 percent (EIA, 2004b), indicating that earlier enrichment demand forecasts were conservative.

21 Supply forecasts reflect current sources of enriched uranium, the anticipated loss of supply from diffusion

22 technology facilities like Paducah, new supply from the proposed National Enrichment Facility and the

23 proposed ACP, and continuation of current levels of supply from the Russian highly enriched uranium

24 agreement. -The current Russian highly enriched uranium agreement actually expires in 2013, and while

25 an extension of that agreement through 2020 is a reasonable assumption, any reduction in Russian highly

26 enriched uranium supply after 2013 could shift the close balance after 2010 to a supply shortfall. -The

27 .-U.S. market would be especially vulnerable to any unforeseen global supply shortfall if the Paducah

28 facility closes, as expected, without an offsetting increase in supply from the combined output of the ACP

29 and the National Enrichment Facility.

30

31 1.3.2 The Need for Domestic Supplies of Enriched Uranium for National Energy Security

32

33 With all domestic production now coming from a single plant-the aging gaseous diffusion plant in

34 Paducah-there is some reliability risk of U.S. domestic enrichment capability. A supply disruption

35 associated with the Paducah plant production or the Megatons-to-Megawatts deliveries could impact

36 national energy security because domestic commercial reactors,-which supply approximately 20 percent

37 of the nation's electricity requirements (EIA, 2005), would be fully dependent on foreign sources for

38 enrichment services.

39

40 In a 2002 letter to the NRC, DOE indicated that domestic uranium enrichment had fallen from a capacity

41 greater than domestic demand to a level that was less than half of domestic requirements (DOE, 2002a).

42 In this letter, DOE:

43

44 * Referenced interagency discussions led by the National Security Council where there was a clear

45 determination that the U.S. should maintain a viable and competitive domestic uranium enrichment

46 industry for the foreseeable future;

47

48 * Estimated that 80 percent of projected demand for nuclear power in 2020 could be fueled from -

49 foreign sources;

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I * Noted the importance of promoting the development of additional domestic enrichment capacity to

2 maintain a viable and competitive domestic uranium enrichment industry for the foreseeable future;

3

4 * Noted that there was sufficient domestic demand to support multiple uranium enrichment facilities

5 and that competition is important to maintain a healthy industry, and encouraged the private sector to

6 invest in new uranium enrichment capacity; and

7

8 * Indicated its support for the deployment of the proposed National Enrichment Facility gas centrifuge

9 technology by expressing its support for Urenco to partner with a U.S. company or companies,

10 transferring Urenco's technology to new U.S. commercial uranium enrichment facilities.

11

12 DOE's 2002 letter reinforces the Administration's energy policy, which was released in May 2001 (NEP,

13 2001). This policy called the expansion of nuclear energy dependence "a major component of our

14 national energy policy."

15

16 The proposed ACP would contribute to the attainment of these national energy security policy objectives

17 by helping maintain a reliable and economical domestic source of enriched uranium. Beginning

18 production in 2009 and achieving an annual production capacity of 3.5 million SWUs by 2011, the

19 proposed ACP would provide roughly 25 percent of the projected U.S. enrichment services demand (EIA,

20 2003).

21

22 1.3.3 The Need for Upgraded Uranium Enrichment Technology in the U.S.

23

24 In addition to advancing national energy security goals, the proposed ACP would help accomplish the

25 goals of the June 17, 2002 DOE-USEC Agreement to "facilitate the deployment of new, cost effective

26 advanced enrichment technology in the U.S. on a rapid schedule." It would enable USEC to operate a

27 modem, more efficient, and less costly enrichment plant to supplement and replace its more than 50-year

28 old gaseous diffusion plants (USEC, 2004c).

29

30 Gaseous diffusion technology has relatively large resource requirements that make it less attractive than

31 gas centrifuge technology, from both an economical and environmental perspective. Most importantly,

32 gaseous diffusion plants require large amounts of power. USEC reports that the cost for electricity to run

33 such plants represents approximately 60 percent of the total production cost. Two coal-fired power plants

34 routed through four switchyards provide the electrical supply necessary to operate the gaseous diffusion

35 process at Paducah. In addition to being energy-intensive, a plant using the gaseous diffusion process

36 requires large-scale use of Freon and non-contact cooling water. (USEC, 2005)

37

38 The gas centrifuge technology is known to be more efficient and require less energy to operate than the

39 gaseous diffusion technology currently in use. According to USEC, the energy requirements of a gas

40 centrifuge plant are about five percent of that required by a comparably sized gaseous diffusion plant,

41 resulting in a considerably lower operating cost. At the same time, the gas centrifuge technology does not

42 require such large-scale use of Freon and requires much less use of cooling water. The gas centrifuge

43 technology is also modular, allowing production capacity to be easily geared up or down in response to

44 market demands. (USEC, 2005)

45

46 1.4 Scope of the Environmental Analysis

47

48 To fulfill its responsibilities under the National Environmental Policy Act, the NRC has prepared this

49 Draft EIS to analyze the environmental impacts (i.e., direct, indirect, and cumulative impacts) of the

50 proposed ACP as well as reasonable alternatives to the proposed action. The scope of this Draft EIS

51 includes consideration of both radiological and nonradiological (including chemical) impacts associated

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I with the proposed action and the reasonable alternatives. The Draft EIS also addresses the potential

2 environmental impacts relevant to transportation.

3 --

4 In addition, this Draft EIS identifies resource uses, monitoring, potential mitigation measures;

5 unavoidable'adverse environmental impacts, the relationship between short-term uses of the environment

6 and long-term productivity; and irreversible and irretrievable commitments of resources.

7

8 The development of this Draft EIS is the result of the NRC staff's review of the USEC license application

9 (USEC, 2004c) and its supporting Environmental Report (USEC, 2005). This review has been closely

10 coordinated with the development of the Safety Evaluation Report being prepared by the NRC to

11 evaluate, among other aspects, the health and safety impacts of the proposed action. The Safety

12 Evaluation Report is the outcome of the NRC safety review of the USEC license application.

13

The NRCEnvironmental and Safety Reviews

The focus of an EIS is a public review and presentation of the environmental impacts of a proposed

action.

In addition to meeting its responsibilities under the National Environmental Policy Act, the NRC

prepares a Safety Evaluation Report to analyze the safety of the proposed action and assess its

compliance with applicable NRC regulations.

The safety and environmental reviews are conducted in parallel. Although there is some overlap

between the content of a Safety Evaluation Report and EIS, the intent of the documents is different.

To aid in the decision process, the EIS summarizes some of the more detailed analyses included in

the Safety Evaluation Report. For example, the EIS does not address how accidents are prevented;

rather, it addresses the environmental impacts that would result, should an accident occur.

Much of the information describing the affected environment in the EIS also is applicable to the

Safety Evaluation Report (e g., demographics, geology, meteorology).

Source: NRC, 2003; NRC, 2002.

14 1.4.1 Scoping Process and Public Participation Activities

15

16 The NRC regulations in 10 CFR Part 51 contain requirements for conducting a scoping process prior to

17 the preparation of an EIS. Scoping was used to help identify the relevant issues to be discussed in detail

18 and to help identify issues that are beyond the scope of this EIS, that do not warrant a detailed discussion,

19 or that are not directly relevant to the assessment of potential impacts from the proposed action.

20 - ;

21 On October 15, 2004, the NRC published in the Federal Register (69 FR 61268) a Notice of Intent to

22. prepare an EIS for the construction, operation,:and decommissioning of the proposed ACP and to conduct

23 the scoping process for the EIS. The Notice of Intent summarized the NRC's plans to prepare the EIS and

24 presented background information on the proposed ACP. For the scoping process, the Notice of Intent

25 invited comments on the proposed action and announced a public scoping meeting to be held concerning

26 the project. -

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I On November 8, 2004, the NRC published a notice in the Federal Register (69 FR 64794) postponing the

2 public scoping meeting for the proposed ACP. The NRC took this step in order to allow members of the

3 public adequate access to USEC's license application and Environmental Report before the scoping

4 meeting. These documents had been temporarily unavailable to the public due to a security review, by

5 agency experts, of NRC's Agencywide Documents Access and Management System. After the

6 documents were made publically available, the NRC published another notice in the Federal Register

7 (69 FR 78058; December 29, 2004) announcing a new date, January 18, 2005 for the public scoping

8 meeting.

9

10 On January 18, 2005, the NRC staff toured the proposed ACP site and held the public scoping meeting in

11 Piketon, Ohio. During the scoping meeting, a number of individuals offered oral and written comments

12 and suggestions to the NRC concerning the proposed ACP and the development of the EIS. In addition,

13 the NRC received written comments from various individuals during the public scoping period that ended

14 on February 1, 2005. The NRC carefully reviewed and identified substantive scoping comments (both

15 - oral and written). These comments were then consolidated and categorized by topical areas.

16

17 After the scoping period, the NRC issued the Environmental Scoping Summary Report: Proposed USEC

18 Inc. American Centrifuge Plant in Piketon, Ohio in April 2005 (see Appendix A). The report identifies

19 categories of issues to be analyzed in detail and issues determined to be beyond the scope of the EIS.

20

21 1.4.2 Issues Studied in Detail

22

23 As stated in the Notice of Intent, the NRC identified issues to be studied in detail as they relate to

24 implementation of the proposed action. The public identified additional issues during the subsequent

25 public scoping process. Issues identified by the NRC and the public that could have short- or long-term

26 impacts from the potential construction and operation of the proposed ACP include:

27

28 * Need for the facility; * Air quality;

29 * Compliance with applicable regulations; * Noise;

30 * Alternatives; * Historic and cultural resources;

31 * Decommissioning; * Visual and scenic resources;

32 * Cumulative impacts; * Socioeconomic impacts;

33 * Land use; Public and occupational health;

34 * Transportation; * Waste management;

35 * Accidents; * Depleted uranium disposition;

36 * Geology and soils; * Environmental justice;

37 * Water resources; * Costs and benefits; and

38 * Ecological resources; * Resource commitments.

39 1.4.3 Issues Eliminated from Detailed Study

40

41 The NRC has determined that detailed analysis for mineral resources is not necessary because there are no

42 known nonpetroleum mineral resources at the proposed site that would be affected by any of the

43 alternatives being considered. In addition, detailed analysis of the impact of the proposed ACP on

44 connected actions that include the overall nuclear fuel cycle activities were not considered. The proposed

45 ACP would not measurably affect the mining and milling operations and the demand for enriched

46 uranium (it would instead provide a replacement supply to meet current and projected demands, as

47 discussed in Section 1.3). The amount of mining and milling is dependent upon the stability of market

48 prices for uranium balanced with the concern of environmental impacts associated with such operations

49 (NRC, 1980). The demand for enriched uranium in the U.S. is primarily driven by the number of

50 commercial nuclear power plants and their operation. The proposed ACP would only result in the

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I creation of new transportation routes within the fuel cycle to and from the enrichment facility. The

2 existing transportation routes between the other facilities are not expected to be-altered. Because the

3 environmental impacts of all of the transportation routes other than those to and from the proposed ACP

4 have been previously analyzed, they are eliminated from further study (NRC, 1980; NRC, 1977).

5

6 1.4.4 Issues Outside the Scope of the EIS

7

8 The following'issues raised during the scoping process have been determined to be outside the scope of

9 the EIS:

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11 -* Nonproliferation;

12 * Safety and security;

13 * Credibility; and

14 Terrorism'.

15

16 As noted in Section 1.4, some of these issues are analyzed in detail in the NRC's Safety Evaluation

17 Report, and are only summarized in the Draft EIS. For example, within the area of safety and security,

18 the Safety Evaluation Report analyzes the probabilities and consequences of various accidents at the

19 ACP, as well as measures to prevent those accidents and mitigate their effects. This Draft EIS does not

20 go into the same level of detail, but summarizes, in Section 4.2.12.3 and Appendix H,'the accident

21 analysis from the Safety Evaluation Report for the purpose of assessing the potential environmental

22 impacts of accidents.

23

24 1A.5 Related National Environmental Policy Act and Other Relevant Documents -

25

26 The following National Environmental Policy Act documents were reviewed as part of the development

27 of this Draft EIS.

28

29 * Environmental Impact Statementfor the ProposedNational Enrichment Facility in Lea County, New

30 Mexico, Final Report, NUREG-1 790, Office ofNuclear Material Safety and Safeguards, U.S. Nuclear

31 Regulatory Commission, June, 2005. This EIS analyzes the potential environmental impacts of the

32 proposed siting, construction, operation, and decommissioning of a gas centrifuge uranium

33 enrichment facility near Eunice, New Mexico. Its description of the purpose and need 'of the

34 proposed action, as well as its review of alternatives to the proposed action, are highly relevant to the

35 proposed ACP analysis, because the technologies and production capacities being proposed at the

36 ACP and the National Enrichment Facility are similar. The environmental impacts discussed for the

37 proposed National Enrichment Facility are also relevant to the impact analysis for the proposed ACP,

38 especially the analysis of cumulative impacts' associated with the management of wastes from the two

39 facilities.

40

41 * Final Environmental Impact Statement for the Construction and Operation of a Depleted Uranium

42 Hexafluoride Conversion Facility at the Portsmouth, Ohio, Site. DOE/EIS-0360, Oak Ridge

43 Operations, Office of Environmental Management, U.S. Department of Energy, June, 2004. This

44 site-specific EIS analyzes the construction, operation, maintenance, and decommissioning of the

45 proposed depleted uranium hexafluoride (UF6) conversion facility at three alternative locations within

46 the Portsmouth,' Ohio, site; transportation of all cylinders (depleted UF6, enriched uranium,- and

47 empty) currently stored at the East Tennessee Technology Park near Oak Ridge, Tennessee, to

48 Portsmouth; construction of a new cylinder storage yard at Portsmouth (if required) for cylinders

49 from the East Tennessee Technology Park; transportation of depleted UF6 conversion products and

so waste materials to a disposal facility; transportation and sale of the hydrogen fluoride produced as a

51 conversion co-product; and neutralization of hydrogen fluoride to calcium fluoride and its sale or

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I disposal in the event that the hydrogen fluoride product is not sold. The affected environment

2 characterized in this EIS is the same as the environment at the proposed ACP, because the two

3 facilities would be near each other on DOE's Portsmouth Reservation. In addition, the results

4 presented in this EIS are relevant to the management, use, and potential impacts associated with the

5 depleted UF6 that would be generated at the proposed ACP.

6

7 * Final Environmental Impact Statement for the Construction and Operation of a Depleted Uranium

8 Hexafluoride Conversion Facility at the Paducah, Kentucky, Site. DOE/EIS-0359, Oak Ridge

9 Operations, Office of Environmental Management, U.S. Department of Energy, June, 2004. This

10 site-specific EIS considers the construction, operation, maintenance, and decommissioning of the

11 proposed depleted U16 conversion facility at three locations within the Paducah, Kentucky site, which

12 is a DOE facility; transportation of depleted UF6 conversion products and waste materials to a

13 disposal facility; transportation and sale of the hydrogen fluoride produced as a conversion

14 co-product; and neutralization of hydrogen fluoride to calcium fluoride and its sale or disposal in the

15 event that the hydrogen fluoride product is not sold. The results presented in this EIS are relevant to

16 the management, use, and potential impacts associated with the depleted UF6 that would be generated

17 at the proposed ACP.

18

19 * Environmental Assessment of the USEC Inc. American Centrifuge Lead Cascade Facility in Piketon,

20 Ohio, Offce of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission,

21 January, 2004. This Environmental Assessment supported the NRC's decision to issue Material

22 License No. 70-7003 to authorize USEC to possess and use source and special nuclear material at the

23 Lead Cascade Demonstration Facility. Beginning in late 2005, this facility will provide a real-time

24 demonstration of the basic building block for the commercial-scale gas centrifuge process proposed at

25 the ACP and will provide information on the reliability, performance, and cost of the centrifuge

26 machines and auxiliary systems. The Lead Cascade facility will have up to 240 operable centrifuges

27 for testing, and will recycle tails and product with no product withdrawals except for sampling. It

28 will be located within some of the same buildings proposed to be used by the proposed ACP. Many

29 aspects of this Environmental Assessment relate directly to the commercial-scale plant now being

30 proposed by USEC, assuming the Lead Cascade facility tests prove successful.

31

32 * Environmental Assessment for the Leasing of Facilities and Equipment to USEC Inc. DOEIEA-1451,

33 U.S. Department of Energy, October 2002. This Environmental Assessment analyzed the

34 environmental impacts of leasing facilities and equipment to USEC that would be used in its Gas

35 Centrifuge Research and Development Project at East Tennessee Technology Park. The purpose of

36 this research and development project was to develop an economically attractive gas centrifuge

37 machine and process using DOE's centrifuge technology. This Environmental Assessment includes

38 an analysis of potential impacts associated with the fabrication, assembly, and testing of centrifuge

39 components, which is relevant to the proposed manufacturing and assembly of centrifuges for the

40 ACP.

41

42 * Environmental Assessment: Disposition of Russian Federation Titled Natural Uranium.

43 DOE/EA -1290, Offi ce of Nuclear Energy, Science and Technology, US. Department of Energy, June

44 1999. This Environmental Assessment analyzed the environmental impacts of transporting natural

45 UF6 from the gaseous diffusion plants to the Russian Federation. Transportation by rail and truck

46 were considered. The Environmental Assessment addresses both incident-free transportation and

47 transportation accidents. The results presented in this Environmental Assessment are relevant to the

48 transportation of UF6 for the proposed ACP.

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* Final Programmatic Environrmental Impact Statement for Alternative Strategies for the Long-Term

Management and Use of Depleted Uranium Hexafluoride. DOE/EJS-0269, Office ofNuclear Energy,

Science and Technology, U.S. Department ofEnergy, April 1999. This EIS analyzes strategies for the

long-term management of the DUF6 inventory currently stored at three DOE sites near Paducah,

Kentucky; Portsim6uth,' Ohio; and Oak Ridge, Tennessee. This EIS also analyzes the potential

environmental consequences of implementing each alternative strategy for the period from 1 999

through 2039. The results presented in 'this EIS are relevant to the management, use, and potential

impacts associated with the depleted UF6 that would be generated at the proposed ACP.

* EnvironmentalAssessmentfor the Reindustrialization Program at the Portsmouth Gaseous Diffusion

Plant, Piketon, Ohio. DOE/EA-1346, Oak Ridge Operations Office, U.S. Department of Energy, May

2001. This environmental assessment evaluated the potential impacts of transferring by lease and/or

disposal, land and facilities located on the DOE reservation in Piketon,'OH, as part of a

reindustrialization program. Under the proposed action DOE would transfer land and facilities to a '

community reuse organization, the Southern Ohio Diversification Initiative, or other entities, should

DOE determine them suitable.

* Environmental Assessmentfor the Winterization Activities in Preparation for Cold Standby at the

Portsmouth Gaseous Diffusion Plant, Piketon, Ohio. DOE/EA-1392, Oak Ridge Operations Office,

U.S. Department of Energy, June 2001. This environmental assessment evaluated the potential

impacts of winterizing activities to include the installation and operation of a hot water heating

facility and associated recirculating pipes and gas lines, as well as ongoing cold standby operations.

1.5 Applicable Regulatory Requirements'

This section provides a summary of major environmental requirements, agreements, Executive Orders,

and permits relevant to the construction, operation, and decommissioning of the proposed ACP.

1.5.1 Federal Laws and Regulations

1.5.1.1 NationalEnvironmentalPolicyAct of 1969, as amended (42 U.S.C.'§4321 et seq.)'

The National Environmental Policy'Act establishes national environmental policy and goals for the

protection, maintenance, and enhancement of the environment to ensure for all Americans a safe,

healthful, productive;'aind aesthetically and culturally pleasing environmennt. 'The Act provides a process

' for implementing these specific goals'within the Federal agencies responsible for the action. This Draft

EIS has been prepared in'accordance-with National Environmental Policy Act requirements and NRC

regulations (10 CFR Part '51) for implementing the National Environmental Policy Act.

1.5.1.2 Atomic Energy Act of 1954, as amended (42 U.S.C. §2011 et seq.)

The Atomic Energy Act, as amended, and the Energy Reorganizaition Act of 1974 (42 U.S.C. §5801 et

seq.) give the NRC the licensing and regulatory authority for nuclear energy uses within the commercial

sector. If the license application for the proposed ACP is approved, the NRC would license and regulate

the possession, use, storage, and transfer of byjioduct, source, and special nucleai materials to protect

public health and safety as stipulated in 10 CFR Parts 30, 40, and 70.

1.5.1.3 Clean AirAct, as amended (42 U.S.C. '§7401 et seq.)

The Clean Air Act establishes regulations to ensure air quality and authorizes individual States to manage

permits. The Clean AirAct: (1) requires the U.S. Environmental Protection Agency (U.S. EPA) to

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I establish National Ambient Air Quality Standards as necessary to protect the public health, with an

2 adequate margin of safety, from any known or anticipated adverse effects of a regulated pollutant (42

3 U.S.C. §7409 et seq.); (2) requires establishment of national standards of performance for new or

4 modified stationary sources of atmospheric pollutants (42 U.S.C. §7411); (3) requires specific emission

5 increases to be evaluated so as to prevent a significant deterioration in air quality (42 U.S.C. §7470 et

6 seq.); and (4) requires specific standards for releases of hazardous air pollutants (including radionuclides)

7 (42 U.S.C. §7412). These standards are implemented through plans developed by each State and

8 approved by the U.S. EPA. The Clean AirAct requires sources to meet standards and obtain permits to

9 satisfy those standards. The proposed ACP may be required to comply with the Clean Air Act Title V,

10 Sections 501-507, for sources subject to new source performance standards or sources subject to National

11 Emission Standards for Hazardous Air Pollutants.

12

13 1.5.1.4 Clean WaterAct, as amended (33 U.S.C. §1251 et seq.)

14

15 The Clean Water Act requires the U.S. EPA to set national effluent limitations and water-quality

16 standards, and establishes a regulatory program for enforcement. Specifically, Section 402(a) of the Act

17 establishes water-quality standards for contaminants in surface waters. The Clean Water Act requires a

18 National Pollutant Discharge Elimination System permit before discharging any point source pollutant

19 into U.S. waters. The Ohio EPA administers this program in Ohio, with review and support from U.S.

20 EPA Region 5. The National Pollutant Discharge Elimination System General Permit for Industrial

21 Storm Water is required for point source discharge of storm water runoff from industrial or commercial

22 facilities to State waters. Construction of the proposed ACP would require a National Pollutant

23 Discharge Elimination System Construction Storm Water General Permit from the Ohio EPA. Section

24 401(a)(1) of the Clean Water Act requires States to certify that the permitted discharge would comply

25 with all limitations necessary to meet established State water-quality standards, treatment standards, or

26 schedule of compliance.

27

28 1.5.1.5 Resource Conservation and RecoveryAct, as amended (42 U.S.C. §6901 et seq.)

29

30 The Resource Conservation and RecoveryAct, as amended, requires the U.S. EPA to define and identify

31 hazardous waste; establish standards for its transportation, treatment, storage, and disposal; and require

32 permits for persons engaged in hazardous waste activities. Section 3006 (42 U.S.C. §6926) allows States

33 to establish and administer these permit programs with U.S. EPA approval. U.S. EPA Region 5 has

34 delegated regulatory jurisdiction to the Ohio EPA for nearly all aspects of permitting as required by the

35 Resource Conservation and Recovery Act. U.S. EPA regulations implementing the Resource

36 Conservation and Recovery Act are found in 40 CFR Parts 260 through 283. Regulations imposed on a

37 generator or on a treatment, storage, and/or disposal facility vary according to the type and quantity of

38 material or waste generated, treated, stored, and/or disposed. The method of treatment, storage, and/or

39 disposal also impacts the extent and complexity of the requirements. The proposed ACP would be

40 classified as a large quantity generator of hazardous waste (meaning it is expected to generate more than

41 1,000 kilograms (2,200 pounds) of such waste per month) (USEC, 2005). Hazardous wastes would not

42 be treated or disposed onsite; instead, USEC plans to store such wastes onsite for less than 90 days and

43 then transfer them to appropriately permitted treatment, storage, and disposal facilities.

44

45 1.5.1.6 Low-Level Radioactive Waste Policy Act of 1980, as amended (42 U.S.C. §2021 et seq.)

46

47 The Low-Level Radioactive Waste Policy Act of 1980 amended the Atomic Energy Act to specify that the

48 Federal Government is responsible for disposal of low-level radioactive waste generated by its activities

49 and that States are responsible for disposal of other low-level radioactive waste. The Low-Level

50 Radioactive Waste Policy Act of 1980 provides for and encourages interstate compacts to carry out the

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I State responsibilities. Low-level radioactive waste would be generated from activities conducted from the

2 proposed ACP. The State of Ohio is a member of the Midwest Compact.

3

4 1.5.1.7 Emergency Planning and Community Right-to-KnowAct of 1986 (42 U.S.C. §11001 et seq.)

5 (also known as SARA Title II)

6

7 The Emergency Planning and Community Right-to-Know Act of 1986, which is the major amendment to

8 the'Comprehensive EnvironmentalResponse, Compensation, and LiabilityAct (42 U.S.C. §9601),

9 establishes the requirements for Federal, State, and local governments; Indian tribes; and industry

10 regarding emergency planning and "Community Right-to-Know" reporting on hazardous and toxic

11 chemicals. The "Community Right-to-Know" provisions increase the public's knowledge and access to

12 information on chemicals at individual facilities, their uses, and releases into the environment. States and

13 communities working with facilities can use the information to improve chemical safety and protect

14 public health and the environment; This Act requires emergency planning and notice to communities and

15 government agencies concerning the presence and release of specific chemicals. The U.S. EPA:

16 - ' implements this Act under regulations found in 40 CFR Parts 355, 370, anid 372. This Act would require

17 the'proposed ACP to'report on hazardous and toxic'chemicals used and produced at the facility, and to

18 'establish emergency planning procedures in coordination with the local communities and government

19 -''''agencies. ;

20

21 1.5.1.8 SafeDrinking WaterAct, as amended (42 U.S.C. §300f et seq.)

22

23 The Safe Drinking Water Act was enacted to protect the quality of public water supplies and sources of

24 drinking water. The Ohio EPA, under 42 U.S.C. §300g-2 of the Act, established standards applicable to

25 public water systems. These regulations include maximum contaminant levels (including those for

26 radioactivity) in public water systems. Other programs established by the Safe Drinking. Water Act

27 include the Sole Source Aquifer Program', the Wellhead Protection'Program, and the Underground

28 Injection Control Program. 'In addition, the Act provides underground sources of drinking water with

29 protection from contaminated releases and spills. The proposed ACP would not use onsite ground-water

30 or surface-water supplies, but rather would obtain potable water from a nearby municipal water supply

31 system and non-potable cooling water (primarily for tower water cooling and a lesser amount for machine

32 cooling water) from a nearby water treatment facility.

33

34 1.5.1.9 Noise ControlAct of 1972, as amended (42 U.S.C. §4901 et seq.)

35

36 The Noise Control Act delegates the responsibility of noise control to'State and local governments.

37 Commercial facilities are required to comply with Federal, State, interstate, and local requirements

38 regarding noise control. The-proposed ACP would be located in Pike County,' which does not have a

39 local noise control ordinance.

40

41 1.5.1.10 National Historic Preservation Act of1966, as amended (16 U.S.C. §470 et seq.)

42

43 The National Historic Preservation Act was enacted to create a national historic preservation program,

44 including the National Register of Historic Places and the Advisory Council on Historic Preservation.

45 -Section 106 of the Act requires Federal agencies to take into account the effects of their undertakings on

46 historic properties. The Advisory Council on Historic Preservation regulations implementing Section 106

47 'of the Act are fournd in 36 CFR Part 800. These regulations were revised on July 6, 2004 (69 FR 40544)

48 and became effective on August 5, 2004. The regulations call for public involvement in the'Section 106

49 consultation process, including Indian tribes arid other interested members of the public,' as applicable.

50 The NRC has initiated the Section 106 consultation process and entered into consultation with the Ohio

51 Historic Preservation Office and interested Indian tribes (see Section 1.5.6 and Appendix B). -

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1 1.5.1.11 Endangered Species Act of 1973, as amended (16 U.S.C. §1531 et seq.)

2

3 The Endangered Species Act was enacted to prevent the further decline of endangered and threatened

4 species and to restore those species and their critical habitats. Section 7 of the Act requires consultation

5 with the U.S. Fish and Wildlife Service of the U.S. Department of the Interior or the National Marine

6 Fisheries Service of the U.S. Department of Commerce to determine whether endangered and threatened

7 species or their critical habitats are known to be in the vicinity of the proposed action, and to determine

8 whether the proposed Federal action may affect listed species or critical habitat. The NRC has initiated

9 the consultation process with the U.S. Fish and Wildlife Service for the proposed ACP (see Section 1.5.6

10 and Appendix B).

11

12 1.5.1.12 Occupational Safety and Health Act of 1970, as amended (29 U.S.C. §651 et seq.)

13

14 The Occupational Safety and Health Act establishes standards to enhance safe and healthy working

15 conditions in places of employment throughout the U.S. The Act is administered and enforced by the

16 Occupational Safety and Health Administration, a U.S. Department of Labor agency. The identification,

17 classification, and regulation of potential occupational carcinogens are found in 29 CFR § 1910.101, while

18 the standards pertaining to hazardous materials are listed in 29 CFR § 1910.120. The Occupational Health

19 and Safety Administration regulates mitigation requirements and mandates proper training and equipment

20 for workers. The proposed ACP would be required to comply with the requirements of these regulations.

21

22 1.5.1.13 Hazardous Materials Transportation Act (49 U.S.C. §1801 et seq.)

23

24 The Hazardous Materials Transportation Act regulates transportation of hazardous material (including

25 radioactive material) in and between States. According to the Act, States may regulate the transport of

26 hazardous material as long as they are consistent with the Act or the U.S. Department of Transportation

27 regulations provided in 49 CFR Parts 171 through 177. 49 CFR Part 173, Subpart I contains other

28 regulations regarding packaging for transportation of radionuclides. Transportation of the depleted

29 uranium cylinders from the proposed ACP would require compliance with the U.S. Department of

30 Transportation regulations.

31

32 1.5.1.14 Environmental Standards for Uranium Fuel Cycle (40 CFR Part 190, Subpart B)

33

34 These regulations establish maximum doses to the body or organs of members of the public, as a result of

35 operational normal releases from uranium fuel cycle activities, including uranium enrichment. These

36 regulations were promulgated by U.S. EPA under the authority of the Atomic Energy Act of 1954, as

37 amended, and have been incorporated by reference in the NRC regulations in 10 CFR §20.1301(e). The

38 proposed ACP would be required to comply with these regulations for its releases from normal

39 operations.

40

41 1.5.2 Applicable Executive Orders

42

43 * Executive Order 11988 (Floodplain Management) directs Federal agencies to establish procedures to

44 ensure that the potential effects of flood hazards and floodplain management are considered for any

45 action undertaken in a floodplain and that floodplain impacts be avoided to the extent practicable.

46

47 * Executive Order 12898 (Environmental Justice) calls for Federal agencies to address environmental

48 justice in minority populations and low-income populations (59 FR 7629), and directs Federal

49 agencies to identify and address, as appropriate, disproportionately high and adverse health or

50 environmental effects of their programs, policies, and activities on minority populations and low51 income populations. In response to this Executive Order, the NRC has issued a final policy statement

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on the "Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions" (69

FR 52040; August 24,2004) and environmental justice procedures to be followed in NEPA .

documents prepared by the NRC's Office of Nuclear Material Safety and Safeguards (NRC, 2003).

1.5.3 Applicable State of Ohio Requirements - - -

Certain environmental requirements, including some discussed earlier, have been delegated to State

authorities for implementation, enforcement, or oversight. Table 1-'2 provides a list of State

environmental requirements.

Table 1-2 State of Ohio Environmental Requirements

Law/Regulation Citation Requirements

Air Quality Protection

Title V Permit Rules ORC, Title 37, Chapter Establishes the policies and procedures by which the

I3704 "Air Pollution . Ohio EPA will administer the Title V permit program

Control," and under the Clean AirAct. Requires Title V sources, as

implementing defined by OAC 3745-77-02, to apply for and obtain a

regulations in OAC, Title V permit prior to operation of the source facility.

Chapter 3745-77 _._ _._._____ _ 4.._........_...._....._ . .... . ... ...... . ............ _.____.

Permits to Install New ORC, Title 37, Chapter Requires a permit prior to the installation of a new source

Sources of Pollution 3704 "Air Pollution of air pollutants, or the modification of an air

IControl," and contaminant source. Discusses exemptions and

implementing conditions undeiwhich approval will be granted. Also

regulations in OAC requires an impact analysis to determine if the air

3745-31 contaminant source will cause or contribute to violations

of the National Ambient Air Quality Standards. ... ........ . __... _._ ... A....._ _ .... . _. ...... _. .... _ . ._;......_ . .. . __.. .... _. _____.....__...... _._..... . ..

Air Permits to Operate ORC, Title 37, Chapter I Requires a permit prior to the operation or use of any air

and Variances 3704 "Air Pollution contaminant source in violation of any applicable air

Control," and pollution control law, unless a variance has been applied

implementing for and obtained from the Director of Environmental

regulations in OAC Protection.

. 3745-35 - __._._ _---- __ -- -. -_ _-_ -- - ----- .~ .... _..-.-.-.-----_

20 Accidental Release

21 Prevention Program

___.__..................._....

22 General Conformity

23 Rules

ORC, Title 37, Chapter

3704 "Air Pollution

Control," and

implementing - -

regulations in OAC

3745-104

Establishes the policies and procedures by which the

Ohio EPA will administer the Accidental Release

Prevention Program, or Risk Management Plan program

under the Clean AirActAmendments of 1990. Requires

the owner or operator of a stationary source that has more

than a threshold quantity of a regulated substance to

comply with all the provisions of the rule, including

creating a hazard assessment, risk management plan, a

prevention program, and an emergency response

program.

Establishes Ohio's rules on "general conformity," a

process mandated by the Clean Air Act to ensure that

Federal actions uphold the State Implementation Plan and

do not contribute to air quality violations within the State.

Discusses which Federal actions are subject to the

conformity requirements, the procedures for conformity

analysis, public participation/consultation, and the final

*conformity determination.

~._._.:..__. . _..,.

ORC, Title 37, Chapter

3704 "Air Pollution I

Control," and- - implementing

regulations in OAC

3745-102

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Law/Regulation Citation Requirements

Water Resources Protection

Ohio National Pollutant * ORC Title 61, Chapter Initiates plans and programs for the prevention, control,

Discharge Elimination 6111 ,"Water Pollution * and abatement of new or existing pollution of the waters

System Permits Control" and of the State of Ohio. Requires an Ohio individual or

implementing general permit prior to any discharge of sewage,

regulations in OAC Iindustrial waste, or other waste as defined by divisions

3745-33 and 3745-38 (B) to (D) of Section 6111.01 of the Ohio Revised Code.

Requires the compliance of each point source with

authorized discharge levels, monitoring requirements,

and other appropriate requirements. ........ ~~~~ . ................................. . .....-- ................. - . ..... ...... ..... ............

Permits to Install New ORC Title 61, Chapter Requires a permit prior to the installation of a new source

Sources of Pollution 6111 :Water Pollution Iof water pollutants, or the modification of any pollutant

Control" and discharge source.

implementing

regulations in OAC

. 3745-31 .... . . ............ . ................... ..... . ...... . ...... . .. . . ......... ........ i_. _._ ................. . ..... ......... ............ . ...... .. .............. . ...

Water Quality Standards ORC Title 61, Chapter IEstablishes water quality standards for surface waters in

6111 ,"Water Pollution the State of Ohio, including beneficial use designations,

I Control" and numeric water quality criteria, and the anti-degradation

implementing waterbody classification system.

regulations in OAC

3745-1 . ............. .. . ......... . .......... . ... . . _..... .... ...... . ... . .. ............. _ ..... ....... . . .... . ..... ...................................

Section 401 Water ORC Title 61, Chapter IRequires a Section 401 water quality certification and

Quality Cerfifications 6111 ,"Water Pollution payment of applicable fees before the issuance of any

Control" and IFederal permit or license to conduct any activity that may

implementing result in any discharge to waters of the State.

regulations in OAC

* 3745-32 and 374545 . ........ . ............ . ................. .. ........... . .......... ... ................ ............................ . . .......... .. . ........... _..........i_. _. ... _........

Public Water Systems ORC Title 61, Chapter IRequires a public water systems license prior to operating

Licenses to Operate 6109, "Safe Drinking or maintaining a public water system.

I Water" and

implementing

regulations in OAC

. 3745-84 ....................... ...... ... .. . ......... . ......... ....................................... _._. . ...... . ............. ... .. . .................... _._..... _._._..... ..

Design, Construction, ORC Title 37, Chapter Establishes performance standards and upgrading

Installation, and 3737, "Underground requirements for USTs containing petroleum or other

Upgrading for Storage Tanks" and regulated substances. Requires an installation or

Underground Storage implementing upgrading permit for each location where such

Tank systems regulations in OAC installation or upgrading is to occur prior to beginning

1301: 7-9-06 either an installation or upgrading of a tank or piping

comprising an underground storage tank system. ........... ........................... _ ....... ...... .........................._.. ___ ._..._._

Registration of ORC Title 37, Chapter Establishes annual registration requirements for

Underground Storage . 3737, "Underground * underground storage tanks containing petroleum or other

Tank System . Storage Tanks" and . regulated substances.

implementing

. regulations in OAC

* 1301: 7-9-04 ............................................ ..... ........................ ......... . . ..........................................

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Table 1-2 State of Ohio Environmental Requirements (continued)

Law/Regulation Citation | Requirements

Flammable and ORC Title 37, Chapter * Requires a permit to install, remove, repair, or alter a

Combustible Liquids . 3737, "Fire Marshal; stationary tank for the storage of flammable or

Fire Safety" and combustible liquids or modify or replace any line or

implementing dispensing device connected thereto.

regulations in OAC.

1301: 7-7-28 . -,

Waste Management and Pollution Prevention

Generator Standards ORC Title 37, Chapter Requires any person who generates a waste in the State

3734, "Solid and of Ohio, as defined in rule 3745-51-02 of the

Hazardous Waste" and Administrative Code, to determine if that waste is a

* implementing hazardous waste. Requires a generator identification

. regulations in OAC number from U.S. EPA or Ohio EPA prior to treatment,

3745-52-11 and storage, disposal; transport, or offer for transport of

.. 3745-52-12 * hazardous waste. .............. ...... . ... _ ...... . . . ..... . .... .... _:... _._...... . .. :_... _ . ._. _._. _. _. _....

Licensing Requirements ORC Title 37, Chapter Requires an annual license for any municipal solid waste

for Solid Waste, I 3734, "Solid and landfill, industrial solid waste landfill, residual solid

Construction, and Hazardous Waste" and waste landfill, compost facility, transfer facility,

Demolition Debris . implementing infectious waste treatment facility, or solid waste

Facilities regulations in OAC I incineration facility prior to operation. New facilities

3745-37 and 3745-29 must obtain a permit to install prior to construction.

Also, requires a license to establish, modify, operate, or

maintain a construction and demolition debris facility. __.. ..... ... _ _.. . _... _......_ ._;._._..._ ...._._. ..__ _

Radiation Generator and I OAC 3701: 1-54-02 I Requires completion of a low-level radioactive waste

Broker Reporting generator report within 60 days of beginning to generate

Requirements low-level waste in Ohio. Additionally, requires each

generator to submit an annual report on the state of lowlevel waste activities in their facility and pay applicable

fees. ... ~~~~~~~~~~~. . __.__...................... _ __ . ....... ....__........ _._ __ :........_ _ ___ .__.........._

Hazardous Waste ORC Title 37, Chapter Requires operation permits for any new or existing

Management System, 3734, "Solid and * hazardous waste facility.

Permits - Hazardous Waste" and . implementing

. regulations in OAC

. 3745-5040

Emergency Planning and Response

Hazardous Chemical ORC Title 37, Chapter Requires the submission of Material Safety Data Sheets

Reporting 3750, "Emergency and an annual Emergency and Hazardous Chemical

- Planning" and Inventory to local emergency response officials for any

implementing hazardous chemicals that are produced, used, or stored at

regulations in OAC the facility in an amount that equals or exceeds the

3750-30 I threshold quantity. A.. .. ._....... . ....... ._....... _._. .... ........ . _.. . ..... . ..... _. ....

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Table 1-2 State of Ohio Environmental Requirements (continued)

Law/Regulation Citation [ Requirements

Emergency Planning * ORC Title 37, Chapter Requires any facility having an extremely hazardous

Requirements of Subject * 3750, "Emergency . substance present in an amount equal to or exceeding the

Facilities I Planning" and threshold planning quantity to notify the emergency

implementing response commission and the local emergency planning

regulations in OAC committee within 60 days after onsite storage begins.

3750-20 Also, requires the designation of a facility representative

who will participate in the local emergency planning

process as a facility emergency coordinator. _ . __..... .. . ..... __.._.. ........... . _..... . .. _._ ...... _.......... ......... ... ..... ..... ......... _. _..... _.....___.........

Toxic Chemical Release ORC Title 37, Chapter IEstablishes reporting requirements and schedule for each

Reporting 3751, "Hazardous toxic chemical known to be manufactured (including

Substances" and imported), processed, or otherwise used in excess of an

. implementing applicable threshold quantity. Applies only to facilities

regulations in OAC of a certain classification.

3745-100

Biotic Resources Protection

State Endangered Plant ORC Title 15, Chapter Establishes criteria for identifying threatened or

Species Protection 1518, "Endangered endangered species of native Ohio plants and prohibits

Species" injuring or removing endangered species without

. permission. . _.._. . .. ............ _ __ ._ .........._ ..... ... . . . ........... __ ..................... . ....

State Endangered Fish ORC Title 15, Chapter Grants the Chief of the Division of Wildlife with the

and Wildlife Species 1531, "Division of approval of the Wildlife Council, the power to adopt,

Protection Wildlife," Section modify, and repeal rules to restrict the taking or

1531.25 and possession of native wildlife, or any eggs or offspring

implementing thereof, that he/she finds to be threatened with statewide

regulations in OAC extinction. Establishes and requires periodic update to a

1501:31-23-01 list of endangered fish and wildlife species native to

Ohio. .- -.--........ .---.................--.... ---............-........-.....--.....--......-.............--... i---------------------- i-------*------------*----------------------------------- --- ..-*-*--

Permits for Impacts to ORC Title 61, Chapter Requires a general or individual State isolated wetland

Isolated Wetlands 6111 ,"Water Pollution permit prior to engaging in an activity that involves the

I Control" Ifilling of an isolated wetland.

Cultural Resources Protection

Ohio Historical Society ORC Title 1, Chapter Creates the Ohio Historical Society and Advisory Board.

149, Section 149.30 Outlines the Society's duties for the preservation of

Ohio's designated or potentially designated historic and

archaeological objects, sites, and properties.

State Registry of ORC Title 1, Chapter *Directs the Ohio Historical Society to maintain a State

Archaeological I 149, Section 149.51 Registry of Archaeological Landmarks. Prohibits any

Landmarks person from excavating or destroying such land, or from

removing skeletal remains or artifacts from any land

5 placed on the registry without first notifying the Director

5 of the Historical Society. .... . ....................... ........ . .. . _:_............................. ....... . ..... _._.._............. .........

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Table 1-2 State of Ohio Environmental Requirenients (continued)

Law/Regulation Citation - Requirements

Survey and Salvage; . ORC Title 1, Chapter Directs all State departments, agencies, and political

Discoveries; 149, Section 149.53 -. subdivisions to cooperate with the Ohio Historical

Preservation Society in the preservation of archaeological and historic

sites and the recovery of scientific information from such

sites. Also, requires State agencies and contractors

performing work on public improvements to cooperate

with archaeological and historic survey and salvage

efforts and to notify the Society or the Board about

*._ . .archaeological discoveries.

Sources: http://www.epa.state.oh.us/dapc/regs/regs.html and http://onlinedocs.andersonpublishine.com.

1.5.4 Permit and Approval Status

Several construction and operating permit applications would be prepared and submitted, and regulator

approval and/or permits would be received prior to construction or facility operation. Table 1-3 lists the

required Federal, State, and local permits and their status.

1.5.5 Cooperating Agencies

During the scoping process, no Federal, State, or local agencies were identified as potential cooperating

agencies in the preparation of this Draft EIS.

1.5.6 Consultations

As a Federal agency, the NRC is required to comply with the consultation requirements in the

Endangered Species Act of 1973, as amended, and the National Historic Preservation Act of 1966, as

amended. For this proposed action, the NRC conducted these consultations as well as consultations in

accordance with the Fish and Wildlife Coordination Act of 1934 and the Farmland Protection Policy Act

of 1981. All consultation letters related to each of these laws are presented in Appendix B of this Draft

EIS and are summarized below.

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Table 1-3 Potentially Applicable Requirements for the Construction and Operation of the

American Centrifuge Plant

License, Permit, or Other Responsible

Required Approval Agency Authority Relevance and Status

Air Quality Protection

Title V Operating Permit: * Ohio EPA; Clean Air Act . United States Enrichment

Required for sources that are not U.S. EPA . (CAA), Title V, Corporation is the holder of a

exempt and are major sources, Sections 50 1-507 I final Title V Operating Permit

affected sources subject to the (US. Code, Title (Facility ID 0666000000) with an

Acid Rain Program, sources 42, Sections issue date of July 31, 2003 and

subject to new source performance 7661-7661 f [42 effective date of August 21, 2003.

standards, or sources subject to USC 7661- 7661 f);) The plant is subject to 40 CFR

National Emission Standards for Ohio Administrative Part 61, Subpart H (40 CFR Part

Hazardous Air Pollutants. Code (OAC) 61, Subpart H), "National

3745-77-02 Emissions Standards for

Emissions of Radionuclides,"

which is included in the terms

and conditions of the Title V

Operating Permit . ........................ ..... *..*..... ...... ..... . .. _ _ ; ................................. . . . .... .. .... __

Ohio Permit to Install: Required . Ohio EPA CAA, Title 1, USEC has determined that the

for (I) any source to which one or Sections 160-169 prevention of significant

more of the following CAA (42 USC deterioration, nonattainment area,

programs would apply: prevention 7470-7479); OAC and NSPS programs do not apply

of significant deterioration, 3745-31-02 to the proposed ACP. However,

nonattainment area, New Source air emission sources at the

Performance Standards, and/or proposed ACP would require an

National Emission Standards for Ohio Permit to Install and USEC

Hazardous Pollutants; and (2) any would submit a timely application

source to which one or more of the . to the Ohio EPA.

following State air quality

programs would apply: Gasoline

Dispensing Facility Permit, Direct

Final Permit, and/or Small

Maximum Uncontrolled Emissions

Unit Registration................ _..... ._......_......._..... _ _:....................._......:......_.... : _.........

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Table 1-3 Potentially Applicable Requirements for the Construction and Operation of the

American Centrifuge Plant (continued)

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License, Permit, or Other | Responsible | I . Required Approval - | Agency | . Authority Relevance and Status

Ohio Permit to Operate: _ Ohio EPA . 5 CAA, Title 1, - * United States Enrichment

Required for (1) any source to Sections 160-169 I Corporation is the holder of a

which one or more of the I (42 USC . final Title V Operating Permit

following CAA programs would 7470-7479); OAC . (Facility ID 0666000000) with an

apply: prevention of significant 3745-35-02 issue date of July 31, 2003 and

deterioration, nonattainment area, effective date of August 21, 2003.

New Source Performance New sources at the proposed

Standards, National Emission ACP requiring a Permit to Install

Standards for Hazardous Air would be incorporated in the Title

Pollutants; and (2) any source to V Operating Permit.

!which one or more of the

following State air quality

programs would apply: State

Permit to Operate and/or

registration of operating unit with

potential air emissions of an

amount and type considered

minimal. This permit is not

required, however, for any facility

that must obtain a Title V

Operating Permit. _ _ .. ..... .... ....... ... ........

Risk Management Plan: U.S. EPA;: CAA, Title I, USEC has determined that no

Required for any stationary source Ohio EPA Section 112(R)(7) regulated substances would be

that has a regulated substance (42 USC 7412); 40 stored at the proposed ACP in

(e.g., chlorine, hydrogen fluoride, CFR Part 68; OAC . quantities that exceed the

nitric acid) in any process a 3745-104 threshold levels. Accordingly, a

(including storage) in a quantity Risk Management Plan would not

that is over the threshold level. be required. .i.-..-._. -.-.-.... . _.__*- ----.--.---..... . -. . . .. ....

CleanAirActConformity * Ohio EPA CAA, Title 1, Pike County, Ohio has been

Determination: Required for Section 176(c) (42 designated as "Cannot be

each criteria pollutant (i.e., sulfur USEC 7506); 40 :'Classified or Better Than

dioxide, particulate matter, carbon I CFR Part 93; OAC Standard" for criteria pollutants.

monoxide, ozone, nitrogen,. 3745-102 Because the county is in

dioxide, and lead) where the total attainment with National Ambient

of direct and indirect emissions in Air Quality Standards for criteria

a nonattainment or maintenance pollutants and contains no

area caused by a Federal action . maintenance areas, no Clean Air

would equal or exceed threshold Act conformity determination is

rates. required for any criteria pollutant

that would be emitted as a result

of the Proposed Action. Existing

air quality on the site is in

attainment with National Ambient

Air Quality Standards for the

criteria pollutants. ... _..__._............... ... .... .. .... ....... .. . ...... ._ .. ... ._ ............... . _:..... ........ .. _....._. .......

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UTable 1-3 Potentially Applicable Requirements for the Construction and Operation of the

American Centrifuge Plant (continued)

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License, Permit, or Other Responsible | |

Required Approval l Agency I Authority Relevance and Status

Water Resources Protection

National Pollutant Discharge Ohio EPA * Clean [Mater Act * Construction of the proposed

Elimination System Permit: I (CWA) (33 USC ACP and new cylinder storage

Construction Site Storm Water. * 1251 et seq.); 40 yards would require a permit for

Required before making point CFR Part 122; the construction site storm water

source discharges into waters of OAC-3745-33-02, Idischarges. United States

the State of storm water from a 3745-38-02, and Enrichment Corporation is the

construction project that disturbs 3745-38-06 holder of Permit number

more than 2 hectares (5 acres) of 01S00023AD. If requested, a

land. Storm Water Pollution Prevention

Plan would be submitted to the

Ohio EPA at the appropriate time.

Storm water would discharge

through existing outfalls covered

by a permit.

National Pollutant Discharge Ohio EPA CWA (33 USC Storm water would be discharged

Elimination System Permit: 1251 et seq.); 40 from the proposed ACP site

Industrial Facility Storm Water. CFR Part 122; during operations. Storm water

Required before making point OAC-3745-33-02, would discharge through existing

source discharges into waters of 3745-38-02, and outfalls covered by a permit.

the State of storm water from an 3745-38-06

industrial site. '..... -*-- . . . ... * . . . ---- - ......- . .. . . ........................... ................... ................ .................-.. ....

National Pollutant Discharge Ohio EPA CWA (33 USC The proposed ACP would process

Elimination System Permit: 1251 et seq.); 40 industrial wastewater through an

Process Water Discharge: CFR Part 122; existing permitted facility and

Required before making point I OAC-3745-33-02, through existing outfalls covered

source discharges into waters of 3745-38-02, and by the permit.

the State of industrial process 3745-38-06

wastewater.

Ohio Surface Water Permit to Ohio EPA OAC-3745-31-02 If required, before construction of

Install: Required before sewer lines and pump stations at

constructing sewers or pump the proposed ACP, a Permit to

stations. IInstall to modify the existing

National Pollutant Discharge

Elimination System permit would

Ibe submitted to the Ohio EPA at

the appropriate time. ......................................... ........................................................ _ . . _.... _ . .... ......-.

Ohio Surface Water Permit to I Ohio EPA I OAC-3745-31-02 If required, a Permit to Install to

Install: Required before modify the existing National

constructing any wastewater Pollutant Discharge Elimination

treatment or collection system or System permit would be

disposal facility. submitted to the Ohio EPA at the

appropriate time. ................................. . . .......... . ....... ............. _._._.......... _._ ..................... .............. . . .........

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Table 1-3 Potentially Applicable Requirements for the Construction and Operation of the

American Centrifuge Plant (continued)

License, Permit, or Other ResponsibleI

Required Approval. Agency Authority Relevance and Status

Spill Prevention Control and U.S. EPA,' I CWA (33 USC A Spill Prevention Control and

Countermeasures Plan: * . 1251 et seq.); 40 Countermeasures plan would be

Required for any facility that could CFR Part 112 ' required. The United States

discharge oil in harmful quantities Enrichment Corporation's plan is

into navigable waters or onto currently being revised to

adjoining shorelines. I incorporate changes in plant

operation and to reflect new

requirements mandated in the

Federal Regisier on July 17,

2002. The U.S. EPA requires

plan approval by August 17, 2005

and implementation by February

18, 2006. USEC would revise the

plan to include proposed ACP

operations at the appropriate time. ....... 4.. ......... ............... .. .............. 4. . ............. ......... ......

Clean WaterAcd Section 401 I Ohio EPA CWA, Section 401 USEC believes that it would not

Water Quality Certification: I (33 USC 1341); I be required to obtain a'Clean

Required to be submitted to the ORC Chapters 119 Water Act Section 401 Water

agency responsible for issuing any and 6111; OAC Quality Certification for

Federal license or permit to Chapters 3745-1, construction or operation of the

conduct an activity that may result 3745-32, and . proposed ACP or new cylinder

in a discharge of pollutants into 3745-47 storage yards. If USEC

waters of a state. determines that a Federal license

or permit is required (e.g., a

Clean Water Act Section 404

Permit), a Clean Water Act

Section 401 Water Quality

Certification would be requested

from the Ohio EPA at the-

. - - '. ~ *appropriatetime. ... ..... . .... . ... . .. . ......

Public Water System: A Ohio EPA OAC-3745-84-01 USEC Would procure water from

completed application for an initial (B)(b) a qualified vendor, which draws

public water system license is *. water from groundwater wells

required prior to the operation of . sunk near the Scioto River.

the public water system. . . USEC would not operate a

public water system subject to

I these requirements. ' .. _ . _._........_:___..........._ .... _._ .... . . . _._.:.................. ._ ........ . .................. . ..... ... ..... . _._ ....... . .

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Table 1-3 Potentially Applicable Requirements for the Construction and Operation of the

American Centrifuge Plant (continued)

License, Permit, or Other Responsible

Required Approval Agency Authority Relevance and Status

Underground Storage Tank * Ohio . OAC Two existing UST systems are

Installation Permit: Required Department of 1301:7-9-06(D) anticipated to be used by the

before beginning installation of an I Commerce, proposed ACP.

underground storage tank system Ohio Bureau Registration number

(i.e., a tank and/or piping of which of 66005107-R00010.

10 percent or more of the volume Underground I Tank Numbers: T00007 and

is underground and that contains Storage Tank T00016.

petroleum products or substances I Regulations

defined as hazardous by the

Comprehensive Environmental

Response, Compensation, and

Liability Act, except those

hazardous substances that are also

defined as hazardous waste by the

Resource Conservation and

Recovery Act). ........................ . .... .............. .. ............... .... . ...... . ........ ......... ........ . . . . _.__ ............. . .... .. . .....

New Underground Storage U.S. EPA; RCRA, as amended, If new underground storage tank

Tanks System Registration: Ohio Bureau Subtitle 1 (42 USC systems would be installed at the

Required within 30 days of of I 6991 a-699 1 i); 40 proposed ACP the Registration

bringing a new underground Underground CFR §280.22; OAC would be filed at the appropriate

storage tank system into service. Storage Tank 1301:7-9-04 time. No new systems are

Regulations currently planned. ........... ................... . .... ............ . . .................................

Above Ground Storage Tank: A I Ohio OAC . New Above ground Storage fuel

Permit to Install required to install, Department of 1301:7-7-28(A)(3) storage tanks would be required

remove, repair or alter any Commerce, 40 CFR § 112.8 for the proposed ACP. Permits to

stationary tank for the storage of State Fire * . install would be filed at the

flammable or combustible liquids. Marshal appropriate time.

Waste Management and Pollution Prevention

Submit Determination Results: Ohio EPA OAC 3745-52-11 Upon characterization of newly

Required when a person who generated waste streams from the

generates waste in the State of proposed ACP, notification

Ohio or a person who generates would be made to the Ohio EPA.

waste outside the State that is

managed inside the State

determines that the waste he/she

generates is hazardous waste............................ ................ . ..... _._._.......................... .::_ . _.:.....___.........

Registration and Hazardous U.S. EPA; RCRA, as amended United States Enrichment

Waste Generator Identification Ohio EPA (42 USC 6901 et I Corporation has Hazardous

Number: Required before a seq.), Subtitle C; Waste Generator Identification

person who generates over 100 kg OAC 3745-52-12 Number OHD987054723.

(220 lb) per calendar month of

hazardous waste ships the

hazardous waste off-reservation. .. . ................................ . . .................................. ............... ..... .............. . ....................... .... .: .. ..................... . .........

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Table 1-3 Potentially Applicable Requirements for the Construction and Operation of the

American Centrifuge Plant (continued)

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License, Permit, or Other | Responsible '

Required Approval | Agency Authority | Relevance and Status

Construction and Demolition Ohio EPA or OAC 3745-37-01 . Construction debris would not be

Debris Facility License: . Pike County I disposed of onsite at the proposed

Required before establishing, . Board of . . ACP. Therefore, no Construction

modifying, operating, or Health and Demolition Debris Facility

maintaining a facility to dispose of License would be required.

debris from the alteration,

construction, destruction, or repair

of a man-made physical structure;

however, the debris to be disposed

of must not qualify as solid or

hazardous waste; also, no license

is required if debris from site . *-

clearing is used as fill material on .:

the same-site. . ._.._._...--..- . ................... .-... 

Low-Level Radioactive Waste Ohio OAC 3701:1-54-02 USEC would file a Low-Level

Generator Report: Required Department of I Radioactive Waste Generator

within 60 days of commencing the I Health Report with the Ohio Department

generation of low-level waste in of Health at the appropriate time.

Ohio. ODH ID Number 52-2109255. .. _. ....... _ . . . . ;............ . ... _._. _. ..... . ..... ;...... .. .............. .... - - - - - - -

Hazardous Waste Facility I U.S. EPA; I RCRA, as amended Hazardous waste would not be

Permit: Required if hazardous Ohio EPA (42 USC 6901 et disposed of onsite at the proposed

waste will undergo nonexempt seq.), Subtitle C; ACP. Also, USEC does not plan

treatment by the generator, be OAC 3745-50-40 to store any hazardous wastes that

stored onsite for longer than 90 are generated onsite for more than

days by the generator of 1 ,000 kg 90 days. However, should waste

(2,205 lb) or more of hazardous . require storage onsite for greater

waste per month, be stored onsite Ithen 90 days for characterization,

for longer than 180 days by the profiling, or scheduling for

generator of between 100 and treatment or disposal, a

1,000 kg (220 and 2,205 lb) of I Hazardous Waste Facility Permit

hazardous waste per month, would be required and submitted

disposed of onsite, or be received . at the appropriate time.

from off-reservation for treatment

or disposal. .. . . : : ...... . .. A_. .......... ... ....... ...... . _..... _._ ... ,.._ ........ _. . _ . . .. _ __......._.._....._..

Depleted UF, Management Ohio EPA OAC 3745-266; 40 .USEC would manage the

Measures: Establishes CFR Part 266, depleted UF6 tails cylinders in

requirements for management, Subpart N accordance with 40 CFR Part

inspection, testing, and - I 266, Subpart N and Ohio

maintenance associated with the I Administrative Code Chapter

depleted UF6 storage yards and 3745-266 while in storage.

cylinders owned by USEC at the ---

DOE reservation as stipulated in

the ACP License Application. ............ .... --------- .............. . .. ...... . ....................... _._............. . ... . _:.... . .... . .... . ... . .. . . . ...

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Table 1-3 Potentially Applicable Requirements for the Construction and Operation of the

American Centrifuge Plant (continued)

License, Permit, or Other | Responsible | l

Required Approval Agency Authority Relevance and Status

Low-Level Mixed Waste: Low- * Ohio EPA * OAC 3745-266; 40 * USEC would manage low-level

level mixed waste is a waste that I CFR Part 266, mixed waste in compliance with

contains both low-level radioactive Subpart N 40 CFR Part 266, Subpart N and

waste and RCRA-regulated Ohio Administrative Code

hazardous waste. Chapter 3745-266. ............... ............. ............................ ._.._. ............. . ............. ............... _.. . .... ........ ...... .. .. .......

Industrial Solid Waste Landfill Ohio EPA OAC 3745-29-06 IIndustrial solid waste would not

Permit to Install: Required be disposed of onsite at the

before constructing or expanding a proposed ACP. Therefore, no

solid waste landfill facility in Industrial Solid Waste Landfill

Ohio. * I Permit to Install would be . required.

Emergency Planning and Response

List of Material Safety Data . Local Emergency USEC would prepare and submit

Sheets: Submission of a list of IEmergency Planning and a List of Material Safety Data

material Safety Data Sheets is Planning I Community Sheets at the appropriate time.

required for hazardous chemicals Commission; Right-to-Know Act

(as defined in 29 CFR Part 1910) Ohio State of 1986 (EPCRA),

that are stored onsite in excess of Emergency Section 311 (42

their threshold quantities. Response USC 11021); 40

Commission I CFR §370.20; OAC

3750-30-15 *---------........ . ...... .. . .. . ........ ..........----- i.................. . .......................... .................................... -. ...........................---------------------------------------

Annual Hazardous Chemical ILEPC; Ohio EPCRA, Section United States Enrichment

Inventory Report: Submission of IState 312 (42 USC ICorporation would prepare and

the report is required when Emergency 11022); 40 CFR submit an Annual Hazardous

hazardous chemicals have been Response I §370.25; OAC IChemical Inventory Report each

stored at a facility during the Commission; 3750-30-01 year. United States Enrichment

preceding year in amounts that local fire Corporation Facility ID Number

exceed threshold quantities. department 45661NTDST3930U. .............. . ........ .... ............ ............... ._ ....... . . ...... . ......... ..

Notification of On-Site Storage Ohio State EPCRA, Section IUnited States Enrichment

of an Extremely Hazardous IEmergency I 304 (42 USC Corporation would prepare and

Substance: Submission of the Response 11004); 40 CFR submit the Notification of

notification is required within 60 Commission I §355.30; OAC On-Site Storage of an Extremely

days after on-site storage begins of 3750-20-05 Hazardous Substance at the

an extremely hazardous substance . appropriate time, if such

in a quantity greater than the substances are determined to be

threshold planning quantity. stored in a quantity greater than

the threshold planning quantity at

the proposed ACP. Facility ID

I Number45661NTDST3930U. ........ . . .............................. .. .. ................... 

Annual Toxics Release Inventory U.S. EPA; EPCRA, Section IUnited States Enrichment

Report: Required for facilities I Ohio EPA 313 (42 USC Corporation would prepare and

that have 10 or more full-time 11023); 40 CFR submit a Toxics Release

employees and are assigned certain Part 372; OAC Inventory Report to the U.S.

Standard Industrial Classification * 3745-100-07 EPA each year. Facility ID

codes. Number45661NTDST3930U. .............. ................... _... .. .............. .. ......... :.. ............... ... :. ....... . : _.......................

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Table 1-3 Potentially Applicable Requirements for the Construction and Operation of the

Airierican Centrifuge Plant (continued)

License, Permit, or Other Responsible : A a

.---Required Approval |gny|- Authority-| Relevance and Status

Transportation of Radioactive . U.S. . Hazardous . United States Enrichment

Wastes and Conversion Products Department of .Materials ICorporation Certificate of

Certificate of Registration: Transportation Transportation Act Registration Number

Required to authorize the (HMTA), as - 052803005022LN.

registrant to transport hazardous amended by the

material or cause a hazardous Hazardous

material to be transported or Materials

shipped. Transportation

* UnIfonnSafetyAct

of 1990 and other

acts (49 USC 1501

et seq.); 49 CFR

* .. §107.608(b) ..... _._ ...... __ .... __.. __ ..... .. ......... ;_ ..... . _ . ....... . ... .. . ..... ..... . .. _ . ..... . ... . .....

Transportation of Radioactive U.S. I HMTA (49 USC When shipments of radioactive

Wastes and Conversion Products Department of 1501 et seq.); materials are made, USEC would

Packaging, Labeling, and Transportation Atomic Energy Act - comply with U.S. Department of

Routing Requirements for * (AEA), as amended Transportation packaging,

Radioactive Materials: Required I (42 USC 2011 et Iabeling, and routing

for packages containing seq.); 49 CFR Parts requirements.

radioactive materials that will be 172,173, 174,177,

shipped by truck or rail. and 397

Land Resource Protection

Farmland Protection and Policy U.S. IFarmland Protection IConsultation letters are included

Act: Prime farmland is land that Department of- and Policy Act Iin Appendix B of this Draft EIS

has the best combination of Agriculture (FPPA) of 1981 and summarized in Section

physical and chemical . Public Law 97-98; 7 1.5.6.4. -The Natural Resources

characteristics for producing crops * . USC 4201 [b]; 7 Conservation Service has

of statewide or local importance. CFR Part 7 concluded that the proposed site

Prime farmland is protected by the does not contain prime soils, so

Farmland Protection and Policy the Farmland Protection and

Act of 1981 which seeks to Policy Act does not apply.

minimize the extent to which

Federal programs contribute to the

unnecessary and irreversible .

conversion of farmlands to *

nonagricultural uses..." . * .

. .. ..... ._ ...... _._ ......... :_ .... . .. . _._ ..... _...... _. ..... ._._._..... . ..... .... ....... ___.....

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Table 1-3 Potentially Applicable Requirements for the Construction and Operation of the

American Centrifuge Plant (continued)

License, Permit, or Other IResponsible Required Approvalth Agency Authority Relevance and Status

Biotic Resource Protection

Threatened and Endangered U.S. Fish and Endangered Species Consultation letters are included

Species Consultation: Required Wildlife Act of 1973, as Iin Appendix B of this Draft EIS

between the responsible Federal Service amended (16 USC and summarized in Section

agencies and affected states to (FWS); Ohio 1531 et seq.); ORC . 1.5.6.1. NRC's review and

ensure that the project is not likely Department of 1531.25-26 and subsequent analysis of the

to: (I)jeopardize the continued Natural 1531.99 information provided by the FWS

existence of any species listed at Resources and the Ohio Department of

the Federal or State level as Natural Resources has concluded

endangered or threatened; or (2) that threatened or endangered

result in destruction of critical species or their critical habitat are

habitat of such species. not likely to be adversely

affected. ................. . . ................ . ...... ............. .. _._ .................... .__ .. _. .... ..................

Clean Water Act Section 404 U.S. Army CWA (33 USC Construction of the proposed

(Dredge and Fill) Permit: I Corps of 1251 et seq.); 33 ACP would not result in dredging

Required to place dredged or fill Engineers CFR Parts 323 and Ior placement of fill material into

material into waters of the U.S., 330 wetlands within the jurisdiction

including areas designated as of the U.S. Army Corps of

wetlands, unless such placement is Engineers.

exempt or authorized by a

nationwide permit or a regional

permit; a notice must be filed if a

nationwide or regional permit

applies. ..... ........... ......... . .. _.._.. ................ ._. . . ............. 4........ ._ .. . .. _.... ........ . . ._ . ... ..........

Ohio General Permit for Filling Ohio EPA Ohio Revised Code Construction of the proposed

Category 1 and Category 2 I (ORC) Sections ACP would not result in dredging

Isolated Wetlands: Required 6111.021-6111.029 or placement of fill material into

where the proposed project wetlands within the jurisdiction

involves the filling or discharge of of the Ohio EPA isolated

dredged material into Category I wetlands program.

and Category 2 isolated wetlands,

causing impacts that total 0.20

hectares (0.5 acres) or less.

Ohio Individual Isolated Ohio EPA I ORC Sections . Construction of the proposed

Wetland Permit: Required where 6111.021-6111.029 ACP would not result in dredging

the proposed project involves the or placement of fill material into

filling or discharge of dredged wetlands within the jurisdiction

material into Category I and of the Ohio EPA isolated

Category 2 isolated wetlands, wetlands program.

causing impacts that total greater

than 0.20 hectares (0.5 acres) for

Category I isolated wetlands

and/or greater than 0.20 hectares

(0.5 acree) but not exceeding 1.21

hectares (3 acres) for Category 2

isolated wetlands. .. . _.._. . . ...... ................................................ ...... .... . ..................... . ....... . .

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License, Permit, or Other j Responsible |

Required Approval Agency Authority | Relevance and Status

Cultural Resources Protection

Archaeological and Historical Ohio State * National Historic NRC has consulted with the Ohio

Resources Consultation: Historic . Preservation Act of State Historic Preservation

Required before a Federal agency . Preservation . 1966, as amended 1Officer and Indian tribes

approves a project in an area Officer (16 USC 470 et regarding previous archaeological

where archaeological or historic seq.); and architectural surveys at the

resources might be located. 1 Archaeological and DOE reservation. Consultation

Historical letters are included in Appendix

. Preservation Act of 13 of this Draft EIS and

1974 (16 USC summarized in Section 1.5.6.2.

469469c-2);- In consultation with the Ohio

Antiquities Act of State Historic Preservation

1906 (16 USC 431 Officer and the Indian tribes,

. et seq.); INRC has concluded that the

Archaeological proposed action would have no

Resources effect (direct or indirect) on the

1 Protection Ac: of eligible or potentially eligible

1979, as amended properties on or immediately

(16 USC . adjacent to the DOE reservation.

470aa-mm)

Source: USEC, 2005.

1.5.6.1 EndangeredSpeciesActof1973 Consultation

The Endangered Species Act was enacted to prevent the further decline of endangered and threatened

species and to restore those species and their critical habitats. Section 7 of the Act requires consultation

with the U.S. Fish and Wildlife Service and/or the National Marine Fisheries Service to ensure that -

actions they fund, authorize, permit, or otherwise carry out will not jeopardize the continued existence of

any listed species or adversely modify designated critical habitats.

NRC initiated consultation with the U.S. Fish and Wildlife Service in September 2004 by reviewing the

information that the FWS submitted to USEC on June 21, 2004 regarding the threatened, endangered,

proposed, and candidate species, and designated critical habitats that may be present in the project area.

In a phone conversation on September 23, 2004 between the NRC and the U.S. Fish and Wildlife Service,

the U.S. Fish and Wildlife Service indicated that the information presented in the letter was still current

and accurate.

The U.S. Fish and Wildlife Service letter dated June 21, 2004, states that the proposed project lies within

the range of the Federally endangered Indiana bat (Myotis sodalis), and within the range of timber

rattlesnake (Crotalus horridus), a species of concern and Ohio-listed endangered species. After the

issuance of the Draft EIS, NRC will continue consultations with the U.S. Fish and Wildlife Service.

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L]

1 1.5.6.2 National Historic Preservation Act of 1966 Section 106 Consultation

2

3 To comply with Federal historic preservation laws and regulations as well as mandates of the National

4 Environmental Policy Act, the NRC is required to identify historic properties in the area potentially

5 affected by its actions and to consider potential effects on those properties. The principal driver for this

6 process is Section 106 of the National Historic Preservation Act, as amended (16 U.S.C. 470 et seq.), and

7 implementing regulations at 36 CFR Part 800, as amended through August 2004. Under Section 106,

8 Federal agencies are required to consider the effects of their undertakings on historic properties; 36 CFR

9 Part 800 spells out the process by which this is done in consultation with the State Historic Preservation

10 Officer. The National Historic Preservation Act and 36 CFR Part 800 also require that consultation in the

1 1 Section 106 process should provide Indian tribes the opportunity to identify concerns about historic

12 properties on or off Tribal lands, present views about an undertaking's effects on such properties, and

13 participate in the resolution of adverse effects.

14

15 This Draft EIS process has offered State agencies, Federally recognized Indian tribes, and other

16 organizations that may be concerned with the possible effects of the proposed action on historic properties 17 an opportunity to participate in the consultation process required by Section 106. The following

18 subsections summarize the consultations with the various agencies, tribes, and organizations contacted

19 during the ongoing consultation process.

20

21 Advisory Council on Historic Preservation

22

23 By letter dated May 20, 2005, the NRC notified the Advisory Council on Historic Preservation, Office of

24 Federal Agency Programs of their proposed licensing activity and intent to use the NRC's National

25 Environmental Policy Act review process to satisfy the Section 106 requirements as specified at 36 CFR

26 §800.8. NRC provided the Advisory Council on Historic Preservation a review of the current

27 consultation activities with the Ohio State Historic Preservation Officer and the Indian tribes and

28 indicated that the Draft EIS will be provided to the Advisory Council on Historic Preservation for review.

29

30 Ohio Historic Preservation Office

31

32 By letter dated December 28, 2004, the NRC initiated the Section 106 consultation process with the Ohio

33 State Historic Preservation Officer. This letter requested information on other parties that may be entitled

34 to be consulting parties by the proposed action, as well as notified the office of NRC's intent to use the

35 EIS process for Section 106 purposes as described in 36 CFR §800.8. The letter included portions of the

36 Environmental Report prepared by USEC that indicated that the proposed action would not have adverse

37 effects on historical resources included or eligible for inclusion in the National Register of Historic

38 Places, should not impact the historical integrity of the Portsmouth reservation, and should not result in

39 any impact to Native American Indian tribal, religious, or cultural sites.

40

41 The Ohio State Historic Preservation Officer responded by letter dated February 2, 2005 stating that the

42 proposed project would not adversely affect the Portsmouth Gaseous Diffusion Plant historic property;

43 however, it recommended that the NRC provide a more detailed discussion of the previous studies that

44 occurred on the DOE reservation and recommended that the NRC consider notifying Native American

45 Federally Recognized Tribal Authorities that were historically associated with the area. A listing of

46 potentially interested Federally Recognized Tribal Authorities was included to the letter to the NRC, as

47 well as a point of contact at the Pike County Commissioners.

48

49 The NRC will continue to consult with the Ohio State Historic Preservation Officer. Through the Section

50 106 consultation process and through the publication of this Draft EIS, NRC will provide the Ohio State

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Historic Preservation Officer an opportunity to comment on the area of potential effect and on the NRC's

review of potential adverse effects.

Federally Recognized Indian Tribes

Based on information found in'the Tribal Leaders Directory issued by the Bureau of Indian Affairs, the

information provided by the Ohio State Historic Preservation Officer, and information from the National

Park Service, National Center for Cultural Resources, NRC has identified 17 Federally recognized Indian

tribes with ties to the region that may be interested in being a consulting party. NRC submitted the letters

on March 14 and 18, 2005, and provided the Indian tribes with a brief description of the proposed action,

the initial cultural resource review information, inquired if the Indian tribe had any information regarding

historic sites or cultural resources in the area. -The letters also notified the Indian tribes of NRC's intent to

use the EIS process for Section 106 purposes as described in 36 CFR §800.8. To date, NRC has

confirmed that one Indian tribe, the Absentee Shawnee Tribe of Oklahoma, identified cultural ties to the

area. -The Tribe considers that it is descendant from the people of the Hopewell culture who built the

many earthwork sites in the region. The Tribe refers to "the Barnes Works in Scioto Township" (a

reference to the Scioto Township Works) as "one of the largest sacred sites in North America" (see

Appendix B).

The NRC will continue to consult with the Indian tribes. Through the Section 106 consultation process

and through the publication-of this Draft EIS, NRC will provide the Indian tribes who express an interest

and are considered consulting parties an opportunity to comment on the area of potential effect and on the

NRC's review of potential adverse effects. -

Other Organizations

By letter dated March 14, 2005, the NRC contacted the Pike County Commissioners and provided the

County with a brief description of the proposed action, the initial cultural resource review information,

and inquired if the County had any information regarding historic sites or cultural resources in the area.

The NRC will continue to consult with the Pike County Commissioners, and through the Section 106

consultation process and through the publication of the Draft EIS, NRC will provide the County with an

opportunity to comment on the area of potential effect, and on NRC's review of potential adverse effects.

Interested Members of the Public

Through the NRC's scoping process, additional information about cultural resources in the area was

obtained from interested members of the public- -Additionally, information was also received through the

adjudicatory hearing that is taking place on this license application.' This information is considered in

preparation of the Draft EIS. --

Through publication of the Draft EIS the NRC will provide interested members of the public with an

opportunity to comment on the areas of potential effect and on NRC's review of potential adverse effects.

1.5.6.3 Fish and WVidlife Coordination Act of1934 Consultation

The consultation component of the Fish and Wildlife Coordination Act, requires that "whenever the

waters of any stream or other body of water are proposed or authorized to be impounded, diverted, the

channel deepened, or the stream or other body of water otherwise controlled or modified for any purpose

whatever, including navigation and drainage, by any department or agency of the U.S., or by any public

or private agency under Federal permit or license, such department or agency first shall consult with the

U.S. Fish and Wildlife Service, Department of the Interior, and with the head of the agency exercising

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I administration over the wildlife resources of the particular State wherein the impoundment, diversion, or

2 other control facility is to be constructed, with a view to the conservation of wildlife resources by

3 preventing loss of and damage to such resources as well as providing for the development and

4 improvement thereof in connection with such water-resource development." Because the proposed action

5 does not involve such modifications to a stream or other body of water, the NRC is not implementing

6 consultations under the Fish and Wildlife Coordination Act. The NRC is consulting with the U.S. Fish

7 and Wildlife Service and the State agency that exercises administrative control over the wildlife resources

8 under the Endangered Species Act.

9

10 1.5.6.4 Farmland Protection Policy Act of 1981 Consultation

11I

12 This Act requires consultation with the U.S. Department of Agriculture, Natural Resources Conservation

13 Service, to determine if the proposed action would convert protected farmland to non-agricultural use.

14 For lands protected by the Act, scoring the relative value of the land for preservation is performed by the

15 Natural Resources Conservation Service and the project proponent on a "Form AD-1006." If the

16 Farmland Conversion Impact Rating is below 160, no further analysis is necessary. Scores between 160

17 and 200 may have potential impacts and require additional review and further consideration of

18 alternatives that would avoid or lessen the conversion and lower the impact rating score.

19

20 NRC reviewed the correspondence from the District Conservationist of the Natural Resources

21 Conservation Service in Waverly, Ohio. This letter, dated December 5, 2003, indicates that all of the

22 proposed ACP facilities in the southwest quadrant of the central area would be located on noni-prime soils

23 (Borchelt, 2003). For the cylinder storage yard (X-745H) in the northern portion of the reservation, NRC

24 consulted with the Pike Soil and Water Conservation District and the District Conservationist of the U.S.

25 Department of Agriculture and found that the yard would also be located on non-prime soils (Yost, 2005).

26 Because the proposed activities would be conducted on non-prime soils, the Farmland Protection Policy

27 Act would not apply.

28

29 1.6 Organizations Involved in the Proposed Action

30

31 Two organizations have specific roles in the implementation of the proposed action:

32

33 * USEC Inc. (abbreviated as USEC for the purpose of this Draft EIS) is the NRC license applicant. If

34 the license is granted, USEC would be the holder of an NRC license for the possession and use of

35 special nuclear material, source material, and byproduct material at the proposed ACP. USEC would

36 be responsible for constructing, operating, and decommissioning the proposed facility in compliance

37 with that license and applicable NRC regulations. USEC is a global energy company and its wholly

38 owned subsidiary, the United States Enrichment Corporation, is the world's leading supplier of

39 enriched uranium fuel for commercial nuclear power plants. The NRC has issued Certificates of

40 Compliance for that subsidiary to operate the Paducah and Portsmouth Gaseous Diffusion Plants.

41 More recently, the NRC has issued a license to USEC to construct and operate the Lead Cascade

42 Demonstration Facility described above. Consistent with the requirements in 10 CFR §76.22 and in

43 connection with the issuance of these Certificates and the Lead Cascade license, the NRC has

44 determined that USEC is neither owned, controlled, or dominated by an alien, a foreign corporation,

45 or a foreign government. All of the principal officers of USEC are citizens of the U.S. USEC,

46 including its wholly owned subsidiaries, was organized under Delaware law in connection with the

47 privatization of the United States Enrichment Corporation. It is listed on the New York Stock

48 Exchange, and private and institutional investors own the outstanding shares of USEC. USEC's

49 principal office is located in Bethesda, Maryland. (USEC, 2004c)

1-32

1l
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I * The NRC is the licensing agency. The NRC has the responsibility to evaluate the license application

2 for compliance with the NRC regulations associated with uranium enrichment facilities. These

3 include standards for protection against radiation in 10 CFR Part 20 and requirements in 10 CFR

4 Parts 30, 40, and 70 that would authorize USEC to possess and use special nuclear material, source

* 5 material, and byproduct material, respectively,'at the proposed ACP. The NRC is responsible for

6 -regulating activities performed within the proposed ACP through its licensing review process and

7 subsequent inspection program. To fulfill the NRC responsibilities under the National Enivironmental

8 Policy Act, the environmental impacts of the proposed action are evaluated in accordance with the

9 requirements of 10 CFR Part 51 and documented in this Draft EIS.

10

11 1.7 References

12

13 - (Bellemare, 2003) Bellemare, B. "What Is a Megawatt?" UtiliPoint International Inc. June 24, 2003.

14 http://www.utilipoint.com/issuealert/article.asp?id= 1728> (Accessed 4/15/05).

15

16 (Blake, 2004) Blake, M.E. "U.S. Capacity Factors: Still on the Rise." Nuclear News, pp. 25-29.

17 American Nuclear Society. May 2004.

18

19 (Combs, 2004) Combs, J., Ux Consulting. "Full Review: Enrichment - Facing New Challenges.",

20 Nuclear Engineering International, pp. 20-25. September 2004.

21

22 (DOE, 1999a) U.S. Department of Energy. "Environmental Assessment: Disposition of Russian

23 Federation Titled Natural Uranium." DOE/EA-1290. Office of Nuclear Energy, Science and Technology.

24 June 1999.

25

26 (DOE, 1999b) U.S. Department of Energy. "Final Programmatic Environmental Impact Statement for

27 Alternative Strategies for the Long-Temn Management and Use of Depleted Uranium Hexafluoride."

28 DOE/EIS-0269. Office of Nuclear Energy, Science and Technology. April 1999..

29

30 (DOE, 2001 a) U.S. Department of Energy. "Effect of U.S./Russia Highly Enriched Uranium Agreement."

31 December2l,2001.

32

33 (DOE, 2001b) U.S. Department of Energy. "Environmental Assessment for the Reindustrialization

34 Program at the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOE/EA-1346. Oak Ridge -

35 Operations Office. May 2001.

36

37 (DOE, 2001c) U.S. Department of Energy. "Environmental Assessment for the Winterization Activities in

38 Preparation for Cold Standby at the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOE/EA-1392.

39 Oak Ridge Operations Office. June 2001.

40

41 (DOE, 2002a) U.S. Department of Energy. Letter from W.D. Magwood to M. Virgilio, U.S. Nuclear

42 Regulatory Commission. Uranium Enrichment. July 25, 2002.

43 -

44 (DOE, 2002b) U.S. Department of Energy. "Environmental Assessment for the Leasing of Facilities and

45 Equipment to USEC Inc." DOE/EA-1451. October 2002.

46 -

47 (DOE, 2003) U.S. Department of Energy. "Nucleir Power 2010 (NP 2010)." Office of Nuclear Energy,

48 Science and Technology. January 2003. <http://www.nuclear.gov/infosheets/NP20l0factmarch2003.pdf>

49 (Accessed 4/15/05).

- 1-33
II I

1 (DOE, 2004a) U.S. Department of Energy. "Final Environmental Impact Statement for the Construction

2 and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio, Site."

3 DOE/EIS-0360. Oak Ridge Operations, Office of Environmental Management. June 2004.

4

5 (DOE, 2004b) U.S. Department of Energy. "Final Environmental Impact Statement for the Construction

6 and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky, Site."

7 DOE/EIS-0359. Oak Ridge Operations, Office of Environmental Management. June 2004.

8

9 (EIA, 2003) Energy Information Administration. "U.S. Nuclear Fuel Cycle Projections 2000-2025." U.S.

10 Department of Energy. January 2003. <http://www.eia.doe.gov/cneaf/nuclear/page/forecast/

11 projection.html> (Accessed 4/15/05).

12

13 (EIA, 2004a) Energy Information Administration. "Uranium Marketing Annual Report." U.S. Department

14 of Energy. (Released May 28, 2004; last modified June 30, 2004). <http://www.eiadoe.gov/cneaf/

15 nuclear/umar/umar.html> (Accessed 4115105).

16

17 (EIA, 2004b) Energy Information Administration. "Appendix E: Projections of Nuclear Generating

18 Capacity." International Energy Outlook 2004. DOE/EIA-0484(2004). U.S. Department of Energy.

19 April 2004. <http:llwww.eia.doe.gov/oiaf/ieo/> (Accessed 5/17/05).

20

21 (EIA, 2005) Energy Information Administration. "Annual Energy Outlook 2005 With Projections to

22 2025." U.S. Department of Energy. February 2005. <http:/lwww.eia.doe.gov/oiaf/aeo/> (Accessed

23 4/15/05).

24

25 ((Grigoriev, 2002) Grigoriev, A. "Techsanabexport, Techsnabexport-Russian Enrichment Overview,"

26 presented at Nuclear Energy Institute International Uranium Fuel Seminar 2002. October 1, 2002.

27

28 (NEP, 2001) National Energy Policy Development Group. "National Energy Policy." May 2001.

29

30 (NFS, 2005) Nuclear Fuel Services. "The Smart Alternative for LEU with a Special Twist - NFS."

31 <http://www.nuclearfuelservices.com> (Accessed 7/27/05).

32

33 (NRC, 1977) U.S. Nuclear Regulatory Commission. "Final Environmental Statement on the

34 Transportation of Radioactive Material by Air and Other Modes." NUREG-0 170, Vol 1. December 1977.

35

36 (NRC, 1980) U.S. Nuclear Regulatory Commission. "Final Generic Environmental Impact Statement on

37 Uranium Milling Project -25." NUREG- 0706. Office of Nuclear Material Safety and Safeguards.

38 September 1980.

39

40 (NRC, 2002) U.S. Nuclear Regulatory Commission. "Standard Review Plan for the Review of a License

41 Application for a Fuel Cycle Facility." NUREG-1520. March 2002.

42

43 (NRC, 2003) U.S. Nuclear Regulatory Commission. "Environmental Review Guidance for Licensing

44 Actions Associated with NMSS Programs." NUREG-1748. August 2003.

45

46 (NRC, 2004a) U.S. Nuclear Regulatory Commission. "Typical Stages of the Nuclear Fuel Cycle."

47 November 29, 2004. <http://www.nrc.gov/materials/fuel-cycle-fac/stages-fuel-cycle.html> (Accessed

48 4/15105).

1-34

* I 11
I (NRC, 2004b) U.S. Nuclear Regulatory Commission. "Fact Sheet on Power Uprates for Nuclear Plants."

2 Washington, D.C. July 2004. <http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/

3 power-uprates.html> (Accessed 7/27/05).

4

5 (NRC, 2004c) U.S. Nuclear Regulatory Commission. "Environmental Assessment of the USEC Inc.

6 American Centrifuge Lead Cascade Facility in Piketon, Ohio." Office of Nuclear Material Safety and

7 Safeguards. January 2004.

8

9 (NRC, 2005) U.S. Nuclear Regulatory Commission. "Environmental Impact Statement for the Proposed

10 National Enrichment Facility in Lea County, New Mexico, Final Report." NUREG- 1790. Office of

11 Nuclear Material Safety and Safeguards. Division of Waste Management and Environmental Protection.

12 June 2005.

13

14 (NUKEM, 2002) RWE NUKEM Group. "The Future of SWU." NUKEMMarket Report. July 2002.

15

16 (USEC, 2004a) United States Enrichment Corporation. "Megatons to Megawatts."

17 <http://www.usec.com/v2001 O2fHTML/megatons.asp> (Accessed 7/27/05).

18

19 (USEC, 2004b) United States Enrichment Corporation. "Investor Fact Sheet." Spring 2004.

20 <http://media.corporate-ir.net/mediafiles/NYS/USU/presentations/Spring 2004.pdfP (Accessed

21 4/15/05).

22

23 (USEC, 2004c) United States Enrichment Corporation. "License Application for the American

24 Centrifuge Plant in Piketon, Ohio." Revision 0. NRC Docket No. 70-7004. August 2004.

25

26 (USEC, 2005) United States Enrichment Corporation. "Environmental Report for the American

27 Centrifuge Plant in Piketon, Ohio." Revision 3. NRC Docket No. 70-7004. July 2005.

28

29 (Yost, 2005) Yost, Kevin, (Pike Soil and Water Conservation District). Personal communication, RE:

30 Prime Farmlands on the DOE Reservation. June 17, 2005.

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2. ALTERNATIVES

This chapter describes the proposed action of issuing a U.S. Nuclear Regulatory Commission (NRC)

license to USEC Inc. (USEC) to possess and use special nuclear material, source material, and byproduct

material at the proposed ACP, and alternatives.; Also, alternatives for the disposition of depleted uranium

hexafluoride (UF6) resulting from enrichment operations over the lifetime of the proposed ACP are

analyzed. As required by the National Environmental PolicyAct, this chapter also presents a no-action

alternative. Under the no-action alternative USEC would not construct, operate, or decommission the

ACP. The no-action alternative provides a basis for comparing and evaluating the potential impacts of

the'proposed action: ; '

-Section 2.1 presents technical details of the proposed action and connected actions, including descriptions'

of the proposed site, gas centrifuge enrichment technology, and the activities at the proposed ACP:

refurbishment and construction; manufacturing and assembly; operation; and decontamination and

deconmmissioning. It also describes the related action of ceasing 'uranium enrichment operationsi at the

Paducah Gaseous Diffusion Plant. Section 2.2 describes the no-action altermative. Section 2.3 discusses

alternatives to the proposed action that were considered but eliminated, including alternative sites,

*enrichment technologies other than the proposed centrifuge technology, and sources for enriched product.

The chapter concludes with a comparison of predicted environmental impacts for each alternative and a

preliminary recommnendation from NRC staff regarding the proposed action.

2.1 Proposed Action

The proposed action is the issuance of an NRC license for USEC to possess and use special nuclear

material, source material, and byproduct material at the proposed ACP in Piketon, Ohio. The NRC

license, if granted, would be for a period of 30 years. If an NRC license is issued, USEC plans to start

construction of the ACP in 2007, begin commercial centrifuge operations in 2009, and ramp up to the 3.5

million separative work unit (SWU) design capacity by 2011.

Although the proposed action is the issuance of a license to possess and use nuclear material, this Draft

Environmental Impact Statement (EIS) analyzes activities that would occur as the result of the license

because these activities'-construction, operation, and decommissioning of the proposed ACP - may have :

the potential for environmental impacts. For purposes of this analysis, these activities are organized into

four phases:

(1) Refurbishment, site preparation, and construction of new facilities;

(2) Centrifuge manufacture and equipment assembly;

(3) Facility operation; and

(4) Decontamination and decommissioning.

In addition, USEC indicates in its Environmental Report (USEC, 2005b) that subsequent to beginning

operations at the ACP, the uranium enrichment operations currently taking'place at the Paducah Gaseous

Diffusion Plant in Kentucky would cease. Therefore, the impacts of ceasing operations at the Paducah,

Kentucky plant are also analyzed in this Draft EIS. For the purpose of this analysis, cessation of uranium

enrichment operations at Paducah would include stopping uranium enrichment plant operations, but

would not include decommissioning of the Paducah Gaseous Diffusion Plant, changes to any other

activities at that site, or any alternate uses of the site in the future. Those other actions at Paducah would

be the subject of other decisions and other environmental reviews.

2-1
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1 2.1.1 Location and Description of Proposed Site

2

3 The U.S. Department of Energy (DOE) reservation, on which the proposed ACP would be sited, is

4 located in Pike County, Ohio, one of the State's less populated counties. The reservation is located in the

5 town of Piketon, between Chillicothe and Portsmouth, Ohio, approximately 113 kilometers (70 miles)

6 south of Columbus, Ohio. Figure 2-1 shows the location of the DOE reservation within the surrounding

7 county.

8

9 The DOE reservation consists of approximately 1,497 hectares (3,700 acres), which includes a 526

10 hectare (1,300 acre) central area surrounded by a perimeter road. The proposed ACP would be located in

II the southwest quadrant of this central area approximately 2.5 kilometers (1.5 miles) east of U.S. Route 23.

12 The land surrounding the reservation is sparsely populated, with the nearest residential center, Jasper,

13 located approximately 1.9 kilometers (1.2 miles) to the northwest of the proposed site. The nearest major

14 population center is Piketon, located approximately 6.4 kilometers (4 miles) north of the DOE reservation

15 on U.S. Route 23. The land outside the Perimeter Road but still within the reservation is used for a

16 variety of purposes, including a water treatment plant, lagoons for the process wastewater treatment plant,

17 sanitary and inert landfills, and open and forested buffer areas. Most site developments are located within

18 the fenced central area, which is largely devoid of trees, with grass and paved roadways dominating the

19 open space. The proposed ACP would be situated on approximately 81 hectares (200 acres) of the

20 southwest quadrant of the central area. The proposed ACP site boundary would lie along the Perimeter

21 Road on the western edge of the central area, approximately 568 meters (1,865 feet) from the closest

22 DOE reservation boundary. The distance from the ACP to the nearest member of the public (i.e., actual

23 permanent residence) is about 914 m (3,000 ft) (USEC, 2005b). The environmental characteristics of the

24 proposed site and surrounding areas are described in detail in Chapter 3 of this Draft EIS.

25

26 2.1.2 Gas Centrifuge Enrichment Process

27

28 The proposed ACP would employ a gas centrifuge technology for enriching natural uranium. Figure 2-2

29 shows the basic components of a gas centrifuge. A centrifuge consists of a large rotating cylinder (rotor)

30 and piping to feed uranium hexafluoride (UF6) gas into the centrifuge, and then withdraw enriched and

31 depleted UF6 gas streams. The rotor spins at a high rate of speed inside a protective casing, which

32 maintains a vacuum around the rotor and provides physical containment of the rotor in the event of a

33 major machine failure (USEC, 2004).

34

35 The UF6 gas enters the centrifuge through a fixed pipe. The centrifugal force produced by the spinning

36 rotor creates radial separation, in which the heavier uranium-238 hexafluoride molecules concentrate near

37 the rotor wall and the lighter uranium-235 hexafluoride molecules collect closer to the axis of the rotor

38 (USEC, 2004). In addition to the radial separation of isotopes, separation along the vertical axis (axial) is

39 also induced in response to a thermal gradient along the length of the rotor (Green, 2003). The hotter gas

40 stream rises, while the relatively cooler gas stream flows downward. Figure 2-2 shows the components of

41 a gas centrifuge, including the flow of UF6 gas. The combination of radial and axial separation results in

42 a relatively large assay change between the top and bottom of the centrifuge. Enriched UF6 is extracted

43 by a scoop at the top of the centrifuge while depleted material is removed from a scoop at the bottom

44 (USEC, 2004).

2-2

Il
jChaff . Nw

mb_ us I-

.~~~P ose ACP Loca'tion~y > e

J. - Me.'

aa11

-.. ,k , \ ,; na~

-0 10t 20 50 40 Ilorneters

- [C| State Boundary ° 0I 10 20 0 4OMiles

-- G-

_j County Boundary

Figure 2-1 .Location Of the Proposed ACP Site

1. --

.... Co ny..nd r .. 

2-3
LLI

ur. oulPur LINE

VACUUM SYSTEM TO DIFFUSION PUMP

Figure 2-2 Schematic of a Gas Centrifuge

(USEC, 2005b)

2

2

Enriching Uranium

Uranium is a naturally occurring radioactive element. In its natural state, uranium contains

approximately 0.72 percent by weight of the uranium-235 isotope, which is thefissile isotope of

uranium. There is a very small (0. 0055 percent) quantity of the uranium-234 isotope, and most of the

remaining mass (99.27 percent) is the uranium-238 isotope. All three isotopes are chemically

identical and only differ slightly in their physical properties. The most important difference between

the isotopes is their mass. This small mass difference allows the isotopes to be separated and makes

it possible to increase (i.e., "enrich") the percentage of uranium-235 in the uranium to levels

suitable for nuclear power plants.

Most civilian nuclear power reactors use low-enriched uranium fuel containing 3 to 5 percent by

weight of uranium-235. Uranium for most nuclear weapons is enriched to greater than 90 percent.

To start the enrichment process, the UF6 is heated, which causes the material to sublime (change

directly from a solid to a gas). The UF6 gas is then fed into the enrichment cascade where it is

processed to increase the concentration of the uranium-235 isotope.

Source: VWNA, 2003.

3 The enrichment level achieved by a single centrifuge is not sufficient to obtain the desired concentration

4 of up to 10 percent by weight of uranium-235 in a single step; therefore, a number of centrifuges are

5 connected in series to increase the concentration of the uranium-235 isotope (USEC, 2004). Additionally,

6 a single centrifuge cannot process a sufficient volume for commercial production, which makes it

2-4
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I necessary to connect multiple centrifuges in parallel to increase the volume flow rate. The arrangement of

2 centrifuges connected in series to achieve higher enrichment and in parallel for increased volume is

3 known as a "cascade."

4

5 The centrifuge technology to be used at the proposed ACP is modular by design; the basic building block

6 of enrichment capacity is a cascade of centrifuge machines. Once a complete cascade of centrifuge

7 machines has been installed, the equipment would be placed into service producing enriched material.

8 USEC would construct and install centrifuge machines in subsequent phases until it reaches a capacity of

9 3.5 million separative work units per year by 2011. As needed, enrichment capacity could continue to be

10 increased up to 7 million separative work units per year.

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What is a Separative Work Unit?

A separative work unit is a unit of measurement used in the nuclear industry, just as the units of a

calorie, watt, decibel, ampere, volt, etc., are used in other industries. A separative work unit pertains

to the process ofenriching uranium so it -can be used as fuelfor nuclear power plants.

A separative work unit is a unit oftneasurement of the effort needed to separate uranium-235 and -

238 atoms in natural uranium in order to create afinalproduct that is richer in uranium-235 atoms.

It is calculated by a standardformula. For example, ifyou begin with 100 kilograms (220 pounds) of

natural uranium, it takes about 60 separative work units to produce 10 kilograms'(22 pounds) of

uranium enriched in uranium-235 content to 4.5 percent. It takes on the order of 100,000 separative

work units ofenriched uranium tofuel a typical 1,000 megawatt commercial nuclear reactorfor a

year. A 1,000 megawatt plant can supply the electricity needsfo'ra city of about 600,000 p'eople."

Source: USEC, 2001.

2.1.3 Description of the Proposed American Centrifuge Plant

The proposed ACP would be comprised of various buildings and areas that house systems and equipment

necessary to support the uranium enrichment process. Table 2-1 shows the existing buildings and new

buildings that would be built as part of the proposed action. Figure 2-3 shows the locations of proposed

ACP facilities on the DOE reservation. For their analysis, the NRC staff reviewed figures that included

the building numbers of the proposed locations of the ACP facilities; however, the figures shown in this

Draft EIS have had the building numbers removed pursuant to 10 CFR 2.390.

Primary facilities are those critical to the enrichment process, while secondary facilities provide indirect

support to the process. These facilities are described in Sections 2.1.3.1 and 2.1.3.2. These sections are

followed by summary descriptions of Proposed Operational Systems (Section 2.1.3.3) and Utilities and

Other Services (Section 2.1.3.4).

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Table 2-1 American Centrifuge Plant Facilities

Existing Facilities Approx. Size (ml2 )' JPrimary [Secondary

X.3001 Process Building 28,242 1 X .

................. .................... .... ................... ... ..... .... 4............... .............. 

X-3002 Process Building 28,242 x ............... ...................... t................. .......... 4 ............ ..............

X-3012 Process Support Building -4,482 X .... .......... . .............. ..... . ........... ........ ..... ...... . ... ..... ......

X-3346 Feed and Customer Services - 14,307 -

X-7726 Centriug -Training and Testing ~X .

........................................ ........ .... ... .... .... ..... 4. ......... ....

X-7725 Recycle/Assembly Facility 41,136 X ................... . ..................... .* . 4...----- .....

X-7727H- Interplant Transfer Corridor 2,090 X .... ........ ...................................... .. ........ ....... ....... .***.......,... .........

X-2232C Interconnecting Process Piping 762 mbP X .

.............. ......... ............................. ..........................

X-745G-2 Cylinder Storage Yard 12,542 X .-

X-7725A Waste Accountabilit Fcility2,3.. ........................................... ...... ....... . ............. ..............

X-1 12 Data Processing Building.- 2,787 X

X- 1020 Emergency Operations Center - 667 .X

.. ................... .. ... ............................. ................

X-6000 Pumphouse and Air Plant 1,657.x -

X-6002 Boiler System and Oil Storage Facility - 16,187 . . X .... .............. ... . ...... ... .... . ..... ...

X-7721 Mi-iaintenance, Stores and Training Building 2,731 X .--.------------.... .................... *.......~. ..... ....... . .... .... g......... .

X-7745R Recycle/Assemibly Storage Area 19,992 X ....... ... ........................ . .................. ;...............

Total Area for Existing Facilities . 1 8 2 ,3 9 1 _______ _______

New Facilities Approx. Size Primary Secondary

X.3003 Process Building 28,242 X .

.. ........................................................... *. *........4............... ..... . ... .........

X-3004 Process Building 28,242 X .... .. ...... . .. ........ ........... .............. .............. .......... .. ............ .....

X-3034 Process Support Building 4,5 X

X-3346A Feed and Product Shipping and Receiving 2,118 X . .... ---------.. . ............ ............ .......... ... ......... -44....... .............

X-3356 Product & Tails Withdrawal Building 3,930 .i

X-3366 Product & Tails Withdrawal Building 3,930 X ...... ..................... *................... .. . ...... ....... .....-- .4-----------.. ...............

X-7727H Interplant Transfer Corridor Extension 2,415 X ..... .. ......... ............ -..... ..................... ............... ...-

X-2232C Interconnecting Process Piping Addition i610 m bx .~~. - ... *.................. . ........ . . .................------------- -----...........-

X-76Eyliinder Storage Yard 1,301 X

X-7746W Cylinder Storage Yard.12,263 X ................ . ..................

X-7746E Cylinder Storage Yard 6,968 ..

. .... ........ ................... . . ........... 4.......... ............

X-7746S Cylinder Storage Yard 12,0634 X .

............. ....... .............. .............. ... ------------- --

X-745H Cylinder Storage Yard 98,474 X .

X-7766S Cylinder Storage Y7ard ....... .. 1. 301 X

X-2215SA Power Ductbank Trench System 1,519 I X ......... ... ......... ...................... .......................................... ......... ---- ---.-

X-2220D Communications Ductbank Trench System 922 x .. ..... ................................. ........... , ....... .. ............ ..... .... ... 4...........

X-7725B Chemical Storage Building 1,394 - .

Total Area ror New Facilities .213, 1 7 5b

Notes:

a n = square meters; ft2 = square feet.

To convert from m2 to ft multiply by 10.76. b Interconnecting Process Piping is linear, not in2 . This piping is also not included in the totals.

Sources: USEC, 2004; USEC, 2005b; USEC 2005c.

a,

2-6

11
-

.7_

...... ._ 

-7,

R .__,,, , . ...

, ~ ~ ~ _ ._' .I ,1

DiG &XP FrS.Cl

Figure 2-3 Locations of Proposed ACP Facilities (USEC, 2005b)

Building numbers have been withheld pursuant to 10 CFR 2.390.

2 2.1.3.1 Primary Facilities

3

4 Primary facilities are those where licensed material would be found and are considered to be key facilities

5 in support of the uranium enrichment process. The primary facilities are located or would be constructed

6 adjacent to each other in the southwest quadrant of the central area of the DOE reservation, as shown in

7 Figure 2-4. The only exceptions are the X-745G-2 and X-745H cylinder storage yards, which are located

8 in the northeast part of the DOE reservation just north of the Perimeter Road.

9

10 Process Buildinas

11

12 The primary purpose of the process buildings would be to house the centrifuge machines and support

13 systems necessary to perform the actual enrichment process. The X-3001 and X-3002 Process Buildings

14 are existing facilities that are similar in construction, layout, and design. Each building has a large high

15 bay process area and two utility areas. The height of each building is approximately 27 meters (87 feet)

16 in the high bay area and 15 meters (49 feet) in the utility areas. A transfer aisleway provides access

17 between the two buildings. The nearest reservation boundary is 794,meters (2,606 feet) to the west of the

18 X-3001 Process Building. (USEC, 2004)

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ll

Figure 24 Locations of Process Buildings and other Primary Facilities (USEC, 2005d)

Building numbers have been withheld pursuant to 10 CFR 2.390.

I

2-8

Il
I At the north and south ends of the X-3001and X-3002 Process Buildings are equipment/utility bays and

2 mezzanines where auxiliary equipment is housed.' Items in these areas consist of heating and ventilation

3 . equipment, cooling water pumps, vacuum pumps, electrical switchgear, and standby electrical equipment

4 (i.e., diesel generators, battery rooms, and uninterruptible power supply systems). Building vents for the

5 purge and evacuation vacuum systems are also located in the buildings. The vents are monitored and are

6 permitted through the Ohio Environmental Protection Agency (Ohio EPA).!. (USEC, 2004)

7-

8 The centrifuge machines would be installed in the high bay area in a cascade arrangement. The cascades

9 would be supplied UF6 feed via a header from the X-3346 Feed and Customer Services Building. The

10 machines in each cascade would be grouped into stages that are connected in series. The feed, product,

11 and tails lines to and from each centrifuge within a stage would connect into stage headers that convey the

12 . UF6 streams between stages. The -depleted material from the bottom stage would be piped to the X-3356

13 Product and Tails Withdrawal Building to be withdrawn as tails. The enriched material from the top stage

14 would be piped to the X-3356 building to be withdrawn as product.: The cascade enrichment would

15 -normally be less than 5 percent uranium-235 by weight, but enrichment levels up to 10 percent uiranium16 235 by weight would be allowed. (USEC, 2004)

17

18 Two new process buildings, X-3003 and X-3004, would be constructed as part of the proposed ACP. The

19 layout, design, and purpose of these new facilities would be identical to that of the 'existing process

20 buildings. The proposed location for the X-3003 and X-3004 Process Buildings is directly south of the

21 . X-3001 and X-3002 Process Buildings. (USEC, 2004)

22

23 Process Support Buildin's

24

25 The X-3012 Process Support Building is an existing facility that would house' the equipment and

26 personnel in support of operations in the X-3001 and X-3002 Process Buildings. The X-3012 building is

27 located between the X-3001 and X-3002 buildings. The nearest reservation boundary is 922 meters

28 (3,024 feet) to the west of the X-3012 Process Support Building. (USEC, 2004)

29

30 'The X-3012 Process Support Building is divided into an operational area and a maintenance area by a

31 machine transfer aisleway. The operational area is located in the north section of the building and

32 includes the Area Control Room for the X-3001 and X-3002 Process Buildings. The Area Control Room

33 would provide the central operating functions to monitor and control both the X-3001 and X-3002

34 Process Building machines and processes. Other features of the operational area include staff offices and

35 amenities, a battery room, a switchgear room, and heating, ventilation, and air conditioning rooms. A

36 mezzanine above the north section contains the mechanical equipment room for the building. The

37 maintenance area, located in the south section of the building, includes maintenance shops, storage areas,

38 a battery charging room, staff offices and amenities, and a mezzanine area with additional office areas,

39 and heating, ventilation, and air conditioning rooms. (USEC, 2004)'

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41 A new X-3034 Process Support Building would be constructed as part of the proposed action. This

42 facility would be adjacent to and would serve to support the new X-3003 'and X-3004 Process Buildings.

43 (USEC, 2004)

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45 Feed and Customer Services BuildinE

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47 The X-3346 Feed and Customer Services Building isflocated approximately 305 meters (1,000 feet)

48 south-southwest of the X-3001 Process Building. The X-3346 building is connected to the X-3001 and

49 X-3002 buildings by the X-2232C Interconnecting Process Piping. The nearest reservation boundary is

50 568 meters (1,865 feet) to the west of the X-3346 building. (USEC, 2004)

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I The X-3346 building has two distinct areas of operation to meet process feed, sampling, and transfer

2 requirements. The first area, referred to as the Feed Area, would support the front end of the overall

3 enrichment process by housing the equipment necessary to provide UF6 feed (e.g., electrically heated feed

4 ovens). UF6 feed would be processed to purify the gas before being fed into the process piping. There

5 are separate manifolds that direct each stream to the X-3001 and X-3002 Process Buildings. The Feed

6 Area has scales for weighing the feed cylinders. The location of the feed oven would provide the crane

7 sufficient room to transport the UF6 cylinders between rows of ovens. Cylinders would be placed on rail

8 carts that move the cylinders into and out of the feed ovens without lifting them up and moving them over

9 feed ovens, autoclaves, or other cylinders. (USEC, 2005c)

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11 The second area, referred to as the Customer Services Area, would house the sampling equipment

12 necessary to ensure that customer products meet specifications and to transfer enriched UF6 material to

13 customer product cylinders. The 48X source cylinders filled with enriched product would be transferred

14 from the X-3356 Product and Tails Withdrawal Building to the Customer Services Area. Cylinder

15 sampling and transfer of enriched product would be the only operation at the proposed ACP that would

16 require the handling of liquid UF6 (to ensure a homogenized sample); therefore, the Customer Services

17 Area would be the only location at the proposed ACP where liquid UF6 may be present. Cylinder

18 sampling and transfer operations involving liquid UF6 would occur entirely within containment

19 autoclaves, which are pressure vessels designed to contain a UF6 release should an accident occur during

20 sampling and transfer activities. (USEC, 2004)

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22 The basic approach to sampling and transfer operations would be as follows. The containment autoclaves

23 would be electrically heated to liquefy the UF6 contained in the 48X source cylinders. Any approved UF6

24 container may be heated for sampling and transfer purposes. The liquid would then be sampled and

25 transferred to 30B customer product cylinders (typically three to four). The receiving UF6 cylinder lines

26 and valves would be kept warm during the transfer. The customer product cylinders are then cooled until

27 the UF6 has re-solidified. The autoclaves are supplied with cooling capability to expedite the cylinder

28 heel cool-down process and shorten the cycle time. (USEC, 2004)

29

30 The X-3346 building is equipped with specialized support systems to allow the purge and evacuation of

31 indoor air in the event of liquid UF6 releases. Local area gulper (vacuum) systems are used to collect any

32 small releases of UF6 that might occur during operations. The purge and evacuation vents are monitored

33 and permitted through the Ohio EPA. Other major support equipment includes refrigeration units,

34 precision scales, and cranes. (USEC, 2004)

35

36 Centrifuge Traininz and Test Facilitv

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38 The X-7726 Centrifuge Training and Test Facility is connected and adjacent to the northwest corner of

39 the X-7725 Recycle/Assembly Facility. The nearest reservation boundary is 741 meters (2,431 feet) to

40 the west of the facility. (USEC, 2004)

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42 The X-7726 facility was originally built to support training of plant personnel for centrifuge assembly and

43 testing. Under the proposed action, this facility may initially be used for centrifuge component

44 manufacturing and centrifuge machine assembly. Specific activities that would occur in the X-7726

45 facility include receiving material and centrifuge components, inspecting and testing components or

46 subassemblies, assembling the components into centrifuge machines, evacuating and leak-checking the

47 final assembly, and repairing any machine or subassemblies as needed. There are various support areas

48 throughout the building to provide the necessary ancillary support for the centrifuge assembly operations

49 and personnel. These areas include mechanical equipment rooms, electrical equipment rooms, freight and

50 personnel elevators, HVAC equipment rooms, maintenance areas, and staff offices and amenities. In

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I addition, an overhead crane system traverses the length of the X-7726 facility for movement of centrifuge

2 machines and other large components. (USEC, 2004)

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After the X-7725 Recycle/Assembly Facility becomes available for use, these activities would be;

performed there and the X-7726 Centrifuge TraiAing and Test Facility would become a machine

component preparation area and a training' area for centrifuge subassembly preparation, column assembly,

and machine assembly. The X-7726 facility may also be used for select repair of failed centrifuge

machines or for disassembly of failed machines for failure analysis. (USEC, 2004)

Recycle/Assembly Facility

The X-7725 Recycle/Assembly Facility is connected to the X-7726 Centrifuge Training and Test Facility

and the X-7727H Interplant Transfer Corridr. 'It is located just to the'north'of the X-3001 and X-3002

Process Buildings and the nearest reservation boundary is 741 meters (2,431 feet) to' the'west. (USEC,

2004)

The X-7725 facility provides an area for the manufacture, assembly, testing, and maintenance of

centrifuge machines. Two dedicated rooms are located in the southwest corner to support the

maintenance and operation of the centrifuge transporters and other mobile equipment. Other support

areas include mechanical equipment rooms, electrical equipment rooms, a battery charging room, HVAC

equipment rooms,' maintenance areas, and staff offices and amenities. An overhead crane system

traverses the buffer storage area and assembly' area for movement of centrifuge machines and other large

components. (USEC, 2004)

The assembly of centrifuge machines would begin with receipt of centrifuge machine components. These

components would then be stored and staged for assembly. Centrifuge components and subassemblies

would be assembled into a complete centrifuge machine on one of the machine assembly stands.

Depending on the speed of assembly, completed centrifuges would either be'transported for installation or

stored in the buffer storage area for'later installation. Some completely assembled centrifuge machines

would undergo LTF 6 testing in the Gas Test Stands to verify the correct placement of machine components

and the proper operation of the centrifuge' machine. The Gas Test would be performned prior to moving

the centrifuge machines' to the process building for installation.' (USEC, 2004)

Intermlant Transfer Corridor

The X-7727H Interplant Transfer Corridor is an elongated structure that c6nnects the X-7725

Recycle/Assembly Facility and X-3001 Process Building. It provides a protected pathway to transport

centrifuge machines between the X-7725 Recycle/Assembly Facility or X-7726 Centrifuge Trainingkand

Testing Facility and the Process Buildings. The X-7727H corridor also serves as a shipping and receiving

area for equipment and components during construction and operation activities.' The nearest reservation

boundary is 756 meters (2,480 feet) to the west of the X-7727H corridor. Under the proposed action, the

corridor would be extended, involving minor excavation and construction of an additional 2,423 square

meters (26,078 square feet) of corridor, extending from the X-3001 Process Building to the X-3003

Process Building. (USEC, 2004)

-

Interconnectine Process Pinin!

The X-2232C Interconnecting Process Piping is the piping that connects the X-3346 building to the X3001 and X-3002 buildings, and connects the X-3001 and X-3002 buildings to the'adjacent X-3356

building. The nearest reservation boundary is 678 meters (2,225 feet) to the west of the X-2232C piping.

An additional 1,555 meters (5,100 ft) of X-2232C Interconnecting Process piping would be constructed

' 2-11
I under the proposed action to provide service to the X-3003 and X-3004 Process Buildings and the X-3366

2 Product and Tails Withdrawal Building. (USEC, 2004)

3

4 This piping is typically located in a series of elevated enclosures or modules that run from the X-3346

5 building to the X-3001 building valve house (approximately 518 meters [1,700 feet]) and then to the X6 3002 valve house (approximately 224 additional meters [800 feet]). The standard X-2232C piping

7 module is approximately 12 meters (40 feet) long, but non-standard pipe lengths and shapes may also be

8 used to give extra clearance across roadways. The X-2232C piping enclosures are insulated to minimize

9 heat loss and heated to prevent the freeze-out of UF6 (USEC, 2004)

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11 Feed and Product Shipping and Receiving Building

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13 The X-3346A Feed and Product Shipping and Receiving Building would be constructed approximately

14 91 meters (300 feet) south of the existing X-3346 Feed and Customer Services Building. The proposed

15 facility would contain the operations associated with receiving full UF6 feed cylinders and returning

16 empty feed cylinders to vendors, as well as the receipt of empty customer product cylinders and shipment

17 of full customer product cylinders to customers. The nearest reservation boundary would be 555 meters

18 (1,820 feet) to the west of the X-3346A building. (USEC, 2004)

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20 The X-3346A building would be connected to the X-3346 Feed and Customer Services Building by a

21 crane rail system that serves both facilities. X-3346A would have doors on the north and south sides for

22 either tractor-trailer trucks, straddle carriers, or cranes utilized for movement of cylinders. The building

23 would also contain a large shipping and receiving area, cylinder staging area, offices, and a trucker's rest

24 area. (USEC, 2004)

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26 Product and Tails Withdrawal Buildings

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28 The X-3356 and X-3366 Product and Tails Withdrawal Buildings would be constructed to house the UF6

29 and depleted UF6 withdrawal equipment. The X-3356 facility would be located between the X-3001 and

30 X-3002 Process Buildings, next to the X-3012 Process Support Building. Similarly, the X-3366 facility

31 would be located between the new X-3003 and X-3004 Process Buildings. The nearest reservation

32 boundary would be 918 meters (3,010 feet) to the west of the X-3356 building. (USEC, 2004)

33

34 Both buildings would have two distinct areas of operation to meet process withdrawal requirements, one

35 for product withdrawal and the other for depleted UF6 tails withdrawal. Product withdrawal would use

36 cold traps to desublime the enriched product from a gas phase directly to a solid phase. The enriched

37 product would then be transferred to 48X source cylinders, which are kept in interim storage until shipped

38 to the X-3346 Feed and Customer Services Building for sampling. The west side of the X-3356 building

39 would house the tails withdrawal equipment. Tails withdrawal would be performed via compression and

40 direct desublimation of the UF6 gas. The process is designed so that two uranium assays may be

41 simultaneously withdrawn. The solid tails would then be transferred into tails cylinders. (USEC, 2004)

42

43 Cylinder Storage Yards

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45 The uranium enrichment process relies on the use of cylinders to allow movement and storage of UF6

46 material outside of the enrichment process. The cylinder yards would provide this storage for natural feed

47 uranium, depleted uranium (tails), and enriched (product) uranium awaiting shipment. The yards are

48 constructed with sealed airport runway-quality concrete. UF6 cylinders may be stored in any storage

49 yard, although cylinders of a certain type may be routinely stored in a particular yard. All of the cylinder

50 storage yards are designed primarily for storage of 2.5, 10, and 14-ton UF6 cylinders. (USEC, 2004)

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The X-745G-2 Cylinder Storage Yard is located outside the Perimeter Road to the north of the GDP X344 UF6 Sampling Facility. The X-745G-2 is the only yard that does not require new construction.

Seven new cylinder storage yards, X-7766S, X-7746W, X-7746E, X-7746S, X-7746N, X-745H, and

X-7756S would be constructed to support the proposed ACP. The locations of all the cylinder storage

yards are provided in Figure 2-5. With the exception of the X-745H Cylinder Storage Yard, all new

construction would occur within the proposed ACP site, adjacent to the X-3346 Feed and Customer

Services and X-3356 Product and Tails Withdrawal buildings. The X-745H Cylinder Storage Yard

would be located to the northeast of the existing X-745G-2 Cylinder Storage Yard, outside the Perimeter

Road. The nearest reservation boundary is to the west approximately 604 meters (1,982 feet) from the

proposed X-7746N, S,.E, and W Cylinder Storage Yards; 918 meters (3,010 feet) from the proposed X7756S Cylinder Storage Yard; and 862 meters (2,827 feet) from the existing X-745G-2 Cylinder Storage

Yard. (USEC, 2004)

.

Figure 2-5 Locations of Cylinder Storage Yards (USEC, 2005b)

2.1.3.2 Secondary Facilities

In addition to the primary facilities, there are a number of secondary facilities and areas that would

provide indirect support to the ACP enrichment process. No special nuclear material, depleted uranium,

or other radiological materials would be found in these facilities and areas (USEC, 2004). The secondary

facilities include a waste facility, storage facilities, and various support buildings and infrastructure for

utilities and services. Some of these utilities and support services would be procured and others would be

provided by USEC. The secondary facilities and areas leased to USEC to support the proposed ACP

would include the following:

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I * Waste Accountability Facility - The X-7725A facility is located in the southwest quadrant of the DOE

2 reservation north of the X-7725 facility. This facility serves as a storage area for equipment and parts

3 necessary for the maintenance and repair of the process and process support equipment. (USEC,

4 2004)

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6 * Data Processing Building - The X-1 12 Data Processing Building, located east of the X-3002 Process

7 Building, provides secure housing for the data systems and personnel required to support ACP data

8 processing. (USEC, 2004)

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10 * Emergency Operations Center - The X-1020 EOC, located east of the X-3002 Process Building,

11 serves as a central location to coordinate any emergencies that occur on the DOE reservation.

12 (USEC, 2004)

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14 * Pumphouse andAir Plant, and Cooling Tower - The X-6000 Pumphouse and Air Plant, located east

15 of the X-3002 building, contains: the Cooling Tower Pump House and the Air Generation Plant. The

16 building contains the necessary equipment and systems to distribute dry compressed air to the

17 proposed ACP and to provide the requisite water to the X-6001 Cooling Towers for the removal of

18 heat from the process buildings. The X-6001 tower also contains the necessary equipment, systems,

19 fans, piping, and hardware structures to satisfy the necessary cooling requirements for the process

20 buildings. (USEC, 2004)

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22 * Boiler System and Oil Storage Facility - The X-6002 system is a gas-fired boiler system located

23 northeast of the X-3002 Process Building. The boiler system provides recirculating hot water for

24 building and process heat. The boiler normally is operated on natural gas, but it can also use fuel oil

25 (USEC, 2004). The X-6002A Oil Storage Facility is located east of the X-3002 building and supplies

26 fuel oil to the X-6002 system when required. It is expected that natural gas would be used

27 approximately 90 percent of the time and fuel oil for approximately 10 percent of the time. (USEC,

28 2005c)

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30 * Maintenance, Stores, and Training Building - The X-7721 building, located northeast of the X-3002

31 Process Building, provides areas for maintenance shops, stores and receiving activities, and training

32 (USEC, 2004).

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34 * Recycle/Assembly Storage - The X-7745R storage area is a concrete pad immediately adjacent to and

35 east of the X-7725 facility. This area is used mainly for clean, non-contaminated, outside, horizontal

36 rack storage of centrifuge casings before they are moved inside the building for machine assembly.

37 Other centrifuge components and miscellaneous items may also be temporarily stored in this area.

38 (USEC, 2004)

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40 * Power Ductbank Trench System - This system includes 18 concrete vaults and an underground trench

41 that provides supporting infrastructure to the electrical system. (USEC, 2005c)

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43 * Communications Ductbank Trench System - This system includes four concrete vaults and an

44 underground trench that provides supporting infrastructure to the communications system. (USEC,

45 2005c)

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47 * Chemical Storage Building - The X-7725B building, located north of the X-3001 Process Building,

48 provides a clean, non-contaminated, and protected storage area for manufacturing chemicals. (USEC,

49 2004)

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* Aboveground and Underground Storage Tanks - Aboveground and underground storage tanks would

be installed at various locations within the immediate vicinities of the four process buildings and

support facilities. The size, location, and contents type of each aboveground storage tank would vary

according to operational needs. Tanks would be constructed of materials compatible with the product

to be stored and the conditions of storage (e.g., pressure and temperature), and will meet operational

regulatory requirements. A secondary means of containment for tanks storing petroleum products, as

required by 40 CFR 112.8, would provide for the entire capacity of the aboveground storage tank and

any precipitation that might accumulate. Fuel would be transferred from fuel-bearing aboveground

storage tanks to a 100 gallons per day (approximate) tank inside the process buildings to supply

standby generators in case of power failures. (USEC, 2004)

* The fuel would be fed via aboveground and underground piping. The piping system would conform

to standards for fuel distribution pressure piping, would be designed to minimize abrasion and

corrosion,-and would allow for expansion and contraction. Fuel lines and tanks would be labeled in

accordance with regulatory standards. Spill cleanup materials, such as absorbent pads and/or spill

pallets, would be available at hose connections. In accordance with Federal and State laws, proper

safety procedures, spill prevention plans, and spill response plans would be used to minimize impacts

from accidental discharges. (USEC, 2004)

2.1.3.3 Operational Systems

The DOE reservation has several operational systems in place to ensure security of the facilities and to

respond to emergencies. The proposed ACP would utilize these existing systems, which include:

* Evacuation Public Address System - The Evacuation Public Address system provides instructions or

notification in the event of an incident requiring evacuation or sheltering of reservation or plant

personnel. The X-1020 Emergency Operations Center Public Address system control console is

continuously manned. During emergencies, the Public Address system is not used for routine traffic.

The Public Address system serves most occupied plant facilities. (USEC, 2004)

* Public Warning Siren System -The Public Warning Siren System is used to provide notification to

the public within a two-mile radius of the DOE reservation in the event of an incident requiring

evacuation or sheltering of the public. The system is comprised of sirens on poles/towers around a

two-mile radius and an electronic siren controller at the X-1 020 Emergency Operations Center and

local sheriff's department. (USEC, 2004)

* Security Access Control and Alarm System - Due to the classified and proprietary nature of the ACP

activities and equipment, access to areas classified as Limited Security Areas, Exclusion Area(s), and

Vault-type Room(s) would be controlled utilizing a Security Access Control and Alarm System. The

system consists of an Intrusion Detection System to provide interior protection and an Access Control

System to provide high-security entry controls. The two subsystems report to a single operator's

workstation forming a single security system. (USEC, 2004)

Security Fencing and Portals - The ACP would be within a securely fenced area consisting of

approximately three and a half miles of eight foot high chain-linked fence and barbed wire

encompassing approximately 81 hectares (200 acres) of the southwest quadrant of the central area

described in Section 2.1.1 above. Various gates support normal operation and provide emergency

exits. The fence is routinely patrolled and maintained. (USEC, 2004)

Access to the central area would consist of portals and gates at specific locations. When in use,

portals would be staffed and gates (when open) would be under surveillance by Guard Force

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I personnel with communications equipment. Alternatively, the portals would be equipped with

2 rotogates with an electronic badge reader. Portals would be secured with high security locks when

3 not in use. Signs would be posted at the access portals and gates identifying contraband items that are

4 not permitted without specific approval. Existing lighting at the portals and gates would assist Guard

5 Force personnel and building or plant personnel in detecting unauthorized persons. Standby light

6 would be available in the event of an extended power outage. (USEC, 2004)

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8 2.1.3.4 Procured Utilities and Other Services

9

10 Some of the utilities and support services necessary for the operation of the proposed ACP would be

1 1 procured and provided through existing buildings and services. Utilities procured include high voltage

12 electrical power, water for fire-fighting, sanitary water, sanitary sewer, communications, and non-potable

13 cooling water. Support services procured would include emergency response, training, maintenance,

14 environmental management, and administrative support. Agreements, including performance

15 requirements, have been established for those services not self-performed by USEC to help ensure they

16 are available and reliable. The electrical, water, and sewage systems that would be procured are:

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18 * Electrical Distribution Systems - Electrical power is supplied from the external 345 kilovolts power

19 grid at 345 kilovolts through the X-530A Switch yard to the X-5001 Substation. At the X-5001

20 Substation, the electrical power is stepped down in voltage to 13.8 kilovolts then supplied through the

21 X-5000 Switch House to the various centrifuge process buildings and other centrifuge support

22 buildings. The distribution voltages are further stepped-down as necessary, depending on the facility

23 requirements. (USEC, 2004)

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25 . * Water Systems- Water used at the reservation is supplied by a vendor from wells sunk into the Scioto

26 River alluvium (see Chapter 3 for more detail). The raw water is pumped from wells at three

27 locations along the Scioto River. There is also a backup system that can draw directly from the

28 Scioto River when the wells are unable to produce sufficient water to meet the reservation demand.

29 No known public or private water is withdrawn from the Scioto river downstream of the ACP. The

30 well fields and pump house are located where flooding is anticipated, so the equipment is designed

31 and installed to operate without adverse effect (i.e., the well pumps can operate under water). (USEC,

32 2004)

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34 * Sewage Treatment- The X-6619 Sewage Treatment Plant services the entire DOE reservation and

35 currently operates under the United States Enrichment Corporation National Pollutant Discharge

36 Elimination System (NPDES) permit. Sewage from the reservation facilities is fed into a series of

37 underground sanitary sewers. The plant's sanitary sewers feed into one of several lift stations located

38 around the DOE reservation. From the lift stations, the sewage is pumped to the X-6619 facility. In

39 accordance with the United States Enrichment Corporation National Pollutant Elimination Discharge

40 System permit, the design capacity of the Sewage Treatment Plant is 2,275,032 liters per day

41 (601,000 gallons per day) and is currently operating at 40 percent of that capacity. (USEC, 2005c)

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43 The X-6619 is an activated-sludge facility utilizing the plug flow process, aerobic digestion,

44 secondary clarification, and granular-media filtration for effluent polishing (tertiary treatment). Post45 chlorination followed by de-chlorination with sulfur dioxide is used to meet National Pollutant

46 Elimination Discharge System effluent standards. The treated effluent is discharged to the Scioto

47 River via an underground pipeline to a permitted outfall. An automated sampler collects a weekly

48 composite sample of the liquid effluent for radiological analysis and other required analyses. This

49 existing monitoring system and resulting data would be available as a means of assuring that no

50 unanticipated discharge of licensed material occurred. (USEC, 2005b)

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1 2.1.3.5 Local Road and Rail Network

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3 Intranlant Roadways

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5 The DOE reservation is accessed by small roads that intersect with the Perimeter Road from four

6 directions. The area of the reservation where the proposed ACP would be located has an extensive

7 roadway system. The buildings/facilities on the reservation are serviced with a system of roads, which as

8 a rule generally follow a north-south grid. The system is in generally good condition due to road

9 repaving projects.* Except during shift changes, traffic levels on the site access roads and Perimeter Road

10 are low. Peak traffic flows occur at shift changes and the principal traffic areas during peak,.

11 :morning/aftemoon traffic are at locations where parking lot access roads meet the Perimeter Road. JThe

12 DOE reservation has 12 parking lots varying in capacity from approximately 50 to 800 vehicles. Total

13 parking capacity is approximately 4,400 vehicles. (USEC, 2004) Under the proposed action,

14 approximately 10,033 square meters (108,000 square feet) of new roads and parking areas would be

15 constructed to support the ACP (USEC, 2005b).

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17 Offsite Road Network

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19 The DOE reservation is served by two of southern Ohio's major highway systems: U.S. Route 23 and

20 Ohio SR 32/124. The DOE reservation can be accessed by the Main Access Road, a four-lane

21 interchange with U.S. Route 23. This access route accommodates the plant traffic flow. (USEC, 2005b)

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23 The DOE reservation is 5.6 kilometers (3.5 miles) from the intersection of the U.S. Route 23 and Ohio SR

24 32/124 interchange. Both routes are four lanes with U.S. Route 23 traversing north-south and Ohio SR 32

25 traversing east-west. Approximately 113 kilometers (70 miles) north of the plant, U.S. Route 23

26 intersects 1-270,1-70, and I-71. Trucks also may access 1-64 approximately 32.2 kilometers (20 miles)

27 southeast of Portsmouth. (USEC, 2005b)

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29 SR 32/124/50 runs 298 kilometers (185 miles) east-west from Cincinnati, and through Piketon to

30 Parkersburg, West Virginia. To the west, SR 32 provides access to Cincinnati's three interstate highways,

31 I-71, 1-74, and 1-75. To the east, SR 32/50 is linked with 1-77. (USEC, 2005b)

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33 Rail

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35 The proposed site has rail access, and several track configurations are possible within the site. -The

36 Norfolk Southern rail line is connected to the CSX Transportation Inc. line via a rail spur entering the

37 northern portion of the site. This onsite'system is currently used infrequently. Track in the vicinity of

38 Piketon, Ohio allows a maximum speed of 96.6 kilometers per hour (60 miles per hour). The CSX

39 Transportation Inc. line also provides access to other rail carriers. (USEC, 2005b)

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41 2.1.4 Description of the Phases of the Proposed Action

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43 Activities'at the proposed ACP would be comprised of four distinctive phases starting with refurbishment,

44 site preparation, and construction, and ending with decontamination and deconmmissioning. Each of these

45 phases is described in separate sections below, followed by a fifth section that describes the cessation of

46 uranium enrichment operations at the Paducah Gaseous'Diffusion Plant, which, while not part of the

47 proposed action, would likely result from start-up of operations at the proposed ACP. (USEC, 2005b)

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1 2.1.4.1 Refurbishment, Site Preparation, and Construction

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3 Prior to operation, a number of activities would be required to refurbish, prepare, and construct facilities

4 necessary for uranium enrichment at the proposed site.

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6 Refurbishment Activities

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8 A number of existing facilities at the proposed ACP have already undergone preliminary refurbishment to

9 build the USEC American Centrifuge Lead Cascade facility. The environmental impacts of the Lead

10 Cascade facility were analyzed in an Environmental Assessment published by NRC in January 2004

11 (NRC, 2004). Refurbishment of the existing facilities in the proposed ACP would continue as part of the

12 proposed action. Specific refurbishment activities that would be completed are listed in Table 2-2.

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Table 2-2 Refurbishment Activities for the Proposed ACP

Refurbishment Activity Location

Preliminary facility repairs and modifications; X-7726 Centrifuge Training and Test Facility, Xmaintenance servicing of support equipment 7727H Interplant Transfer Corridor, X-3012 Process

. Support Building, X-3346 Feed and Customer Services

Building, X-2232C Interconnecting Process Piping,

XT-847 Waste Management Staging Facility, and the

. X-710 Technical Services Facility.

Partial relocation of DOE operations and office space I X-3012 Process Support Building ....... . . .. _......... ..... - -------- -_------------ . _. _.._..... ........ . .......

Partial or complete clean out and disposal of material X-3001 and X-3002 Process Buildings

(e.g., old centrifuges associated with the Gas

Centrifuge Enrichments Plant built onsite in the early

1980s, parts, classified material, records, miscellaneous

equipment) ............... ... ........ . . .............................. ........ ......... . ........ ...................... . .......... ......... _. ... .. ___._.._

Disposal of stored hazardous waste and subsequent . X-7725 Recycle/Assembly Building

modification of the RCRA Part B permit to reflect a

new storage area for the proposed ACP . ....... .... ...................... ...... ................... . .... . ............. . ... . ..... . .. . ..... ... _

Relocation of the X-6002 Heat Plant I From X-3002 building to an area adjacent to X-6002A

Sources: NRC, 2004; USEC, 2005b

31 The relocation of the X-6002 Heat Plant would consist of the removal and relocation of system

32 components and piping. Construction would take place between the X-6002A Oil Storage Facility and

33 the X-7721 Maintenance, Stores, and Training Building, located northeast of the X-3002 building.

34 Approximately four acres of soil disturbance is anticipated, but appropriate design reviews would be

35 performed prior to construction to identify the detailed scope of the project effort. The DOE air permits

36 would be transferred to USEC and incorporated in the site's Clean AirAct Title V air permit. USEC

37 would also utilize applicable erosion control measures and storm water run off controls to minimize these

38 effects during the relocation and removal effort (USEC, 2005b).

39

40 Site Preparation and Construction Activities

41

42 As part of the proposed ACP, eight primary facilities, three secondary facilities, and seven cylinder

43 storage yards would be constructed. These facilities and their approximate sizes are listed in Table 2-1

44 and described in Sections 2.1.3.1 and 2.1.3.2.

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4 -

I With the exception of the X-745H Cylinder Storage Yard, the proposed construction areas were

2 -previously graded and improved during the construction phase of the former DOE Gas Centrifuge

3 Enrichment Plant in the early 1980's (USEC, 2004). Some additional site preparation would be

4 necessary, however, and an estimiited 146,865 6ubic meters (192,099 cubic-yards) of earth would be -

5 excavated, with 37,385 cubic meters (48,899 cubic yards) of that being backfilled. An estimated 109,480

6 cubic meters (143,200 cubic yards) of earth would be placed in a borrow area on the DOE reservation for

7 future use (USEC, 2005b).

8

9 Soil disturbance from project activities would occur in construction lay-down areas, altering the sciil

10 profile and leading to a possible temporary increase in erosion because of storm"water runoff and wind.

11 Engineering controls and best management and construction practices would be implemented to ninimize

12 removal and erosion of soils. Physical barriers, such as silt fences and temporary berms would be utilized

13 to reduce impacts on surface water quality from silt and erosion (USEC,-2005b). '

14

15 Construction activities would comply with all applicable permits. Best management practices would be

16 followed to minimize solid waste and hazardous material generation during construction. A minimal

17 amount of oils or solvents would be used during construction to decrease potential leakage to

18 groundwater. If a spill occurs, trained, qualified professionals would promptly deploy spill cleanup -

19 materials. Affected soils would be sampled, analyzed, and managed according to appropriate procedures

20 that encompass State and Federal requirements. -

21 !

22 Dust suppression techniques would be used to mitigate excessive releases of fugitive dust and particulate

23 matter during site preparation activities, although the site is located in a county that is exempt from the

24 restrictions on emissions for fugitive dust specified in Ohio Administrative Code 3745-17-08.

25

26 Management of Wastes from Refurbishment, Site Preparations. and Construction

27

28 -Refurbishment and construction activities would generate solid sanitary/industrial waste, low-level

29 radioactive waste from the former Gas Centrifuge Enrichment Plant, hazardous waste regulated under the

30 Resource Conservation and Recovery Act, and recyclables. Sanitary/industrial waste would include

31 normal building construction materials such as steel beams, plywood and concrete, and general building

32 trash such as paper and packing products, wood, and cement. Sanitary/industrial waste from maintenance

33 of support equipment would be non-regulated lubricants, cleaning materials, and general maintenance

34 debris. Incandescent and fluorescent light bulbs, lead acid and non-lead acid batteries, aerosol cans, etc.

35 would be generated throughout the project and would be handled in accordance with established recycling

36 and hazardous waste management programs. Low level radioactive wasteand hazardous and non37 hazardous wastes would be handled according to procedures that comply with NRC, State, and Federal

38 requirements. As previously mentioned, reasonable efforts would be taken to minimize the amount of

39 waste generated during this phase using USEC-approved waste minimization and pollution prevention

40 policies. The majority of the wastes generated during the refurbishment phase would occur in the X41 3001, X-3002, and X-3346 buildings. Table 2-3 presents a summary of the major sources of waste and

42 projected annual rates of waste generation from this life-cycle phase. -

43

44 2.1.4.2 Manufacturing and Equipment Assembly

45

46 This section summarizes the proposed activities for manufacturing and assembling centrifuges for the

47 proposed ACP. A description of airborne emissions, liquid wastes, and solid wastes expected to be

48 generated from these activities is also provided.

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Table 2-3 Waste Generation during Refurbishment and Construction

Material/Activity | Type of Waste | Projected Annual Rate

Centrifuge parts, piping, and excess

equipment from the former Gas Centrifuge * Low-level radioactive waste 7,793-8,509 m3 '

Enrichment Plant . ................................... .................. ................................ .................... ................... . .................... ............................ ............... +_. .......

Rags, wipes, and aerosol cans RCRA-regulated * 3-17 m3

............................................ ..... ...................... ............. . .............................. . ..... . .......

Paper, construction debris, wood, etc. Sanitary/industrial 1,270 t . --.... ....... ........................... . . ................. .

Circuit boards, bulbs, lead parts . Recyclables* 144-184 m3

Notes:

' This waste will only be generated one-time during refurbishment and construction. It is not a waste generated annually.

In = cubic meters; t = metric tons; RCRA = Resource Conservation and Recovety Act.

To convert in3 to ft3 multiply by 35.31.

To convert t to tons multiply by 1.1.

Source: USEC, 2005b.

Manufacturing and Assembly Activities

New centrifuges and related components would be manufactured onsite at the proposed ACP or at a

commercial manufacturing plant located off the DOE reservation. For offsite manufacturing, USEC is

contemplating three different candidate locations in different States across the country. Centrifuge

components from an offsite manufacturing plant would be transported by truck to the proposed ACP for

assembly and installation.

Centrifuge manufacturing features a filament winding process. This process typically materials such as

carbon fibers, resin systems (resins, hardeners, and modifiers), prepregs (fiberstresin system), and other

chemicals for cleaning parts and for support of the manufacturing process. Final curing of the resulting

parts occurs in a curing oven or hood. Solvents are used to clean the produced parts and manufacturing

equipment.

Control of combustible materials used in the manufacture of centrifuge components includes storage in

National Fire Protection Association 30-approved flammable storage cabinets or areas and the use of local

ventilation. The approved storage areas and flammable storage cabinets would be located away from

licensed material. Back-up power ensures continued ventilation in the event of loss of power. Inadequate

ventilation flow from the hoods and cabinets triggers an alarm.

Onsite centrifuge manufacturing, assembly, testing, and maintenance operations would occur primarily in

the X-7725 Recycle/Assembly facility, which would house up to six centrifuge assembly positions and

six column assembly stands. The X-7726 Centrifuge Training and Test facility would have two

centrifuge assembly positions and one column assembly stand and would be used initially for centrifuge

component manufacturing and machine assembly, then for assembly training and machine component

preparation only. These locations would also receive and store parts for the centrifuge machine assembly.

The assembly and testing of sub-assemblies and assemblies would be an ongoing activity through the

production of approximately 24,000 completed centrifuges and sufficient spares to operate the enrichment

plant at the potential capacity of 7 million separative work units annually (USEC, 2005b). Each of the

manufacturing and assembly areas would have multiple workstation and equipment sets to allow for the

production of up to 16 machines per day (USEC, 2005b). Overhead cranes, fork trucks, and parts

elevators would deliver material to the assembly stands. Lifting fixtures and other assembly tooling

would be required during the assembly of the centrifuges. Completed machines may be moved via crane

2-20
.

I to an adjacent storage location until they can be moved again by crane or moved directly to a transporter

2 for movement to the process buildings. - :

3

4 Gross leak testing of the machines using UF6 may be performed in the X-7725 Recycle/Assembly facility

5 Gas Test Stands or in the process buildings after installation prior to being placed into service. No

6 process gas (UF6) testing of the machines would take place in the assembly areas. The Gas Test Stands

7 would be in a separate room within the X-7725 facility, which has its own ventilation and emission

8 control system. UF6 for the test stands would be supplied from a small cylinder within this room. Testing

9 activities could also include mechanical testing and planned failure testing of smaller parts or sub10 assemblies.

11 . . 12 Manauement of Wastes from Manufacturine and Eguipment Assembly

13

14 The common chemicals that may be used and released are acetone, alcohols, carbon dioxide, ethanol,

15 Freon 134, resin products, solvent vapors, and n-methylpyrrolidone. The airborne emissions generated by

16 the processes would be confined and captured by the use of hoods or local ventilation capture systems

17 that divert emissions to permitted vents. Where required (e.g. for volatile organic vapors), emission

18 control equipment, such as air flow monitored hoods and local exhaust systems, would be used as part of

19 the permitted emission vent system. Airflow from the hoods would be monitored to ensure adequate flow

20 and alarm if a reduced flow is detected so that operations can be curtailed (USEC, 2005b).

21

22 Exhaust from the test stands would pass through alumina traps to a continuously monitored vent. The

23 vent would be equipped with continuous gas flow monitoring instrumentation with local readout, as well

24 as the analytical instrumentation required to continuously sample, monitor, and alarm UF6 breakthrough

25 in the effluent gas stream (USEC, 2005b).

26

27 Some hazardous wastes would be generated through the use of solvents and would be in the form of

28 excess spent solvent, rags, wipes and other material that come into contact with the spent solvents.

29 Wastes would be stored in approved storage areas in flammable storage cabinets/areas according to

30 National Fire Protection Association 30 requirements prior to removal for disposal. Excess fibers, reacted

31 resins, and curing agents would be considered sanitary/industrial waste. Solvents for cleaning would be

32 used during assembly of parts (either sub-assembly or final assembly), which would generate some air

33 emissions, a small quantity of sanitary waste (dry wipes, rags, etc.), and hazardous wastes from the

34 solvent cleaning (USEC, 2005b). Table 2-4 provides a summary of solid waste expected to be generated

35 during the manufacturing phase.

36

37 2.1.43 Facility Operation

38 s

39 This section provides an overview of the production activities that would be carried out to operate the

40 proposed ACP. The overall process of uranium enrichment at the proposed ACP can be divided into six

41 basic operations: (1) receipt of UF6 feed material; (2) feeding UF6 into the enrichment process; (3)

42 enrichment, where the UF6 assay is increased to its desired uranium-235 content; (4) material withdrawal,

43 where enriched UF6 and depleted UF6 is removed from the enrichment process; (5) UF6 sampling and

44 transfer, where enriched UP6 is sampled to ensure it meets customer specifications and the enriched UF6

45 product material is transferred to customer product cylinders; and (6) shipment of UF6 cylinders to

46 customers. -

47

48 Each of these operations is briefly described below, followed by a discussion of waste management and

49 the activities associated with conversion and disposal of depleted UF6.

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Table 24 Solid Waste Generation during Manufacturing

NMaterial/Activity J Type of Waste Projected Annual Rate

Spent solvent rags, wipes from parts cleaning * RCRA-regulated 9-11 m3

operations in support of start-up and testing *

activities

. , ._ . . . ...... _ _. .... . .......................... .....

General maintenance and proposed ACP Non-regulated' * 5-6 03

materials in support of start-up and testing

activities

........... ............ ..... .. .............. ................................ ...................... ........ ....... ..................................... . . ......... ............ .......................... ............................l...

Packing material, paper, wood, etc. in support * Sanitary/industrial . 392-490 t

of start-up and testing activities

Notes:

' A Non-Regulated Waste is any discarded material that is excluded under the Ohio Administrative Code - OAC 3745-51-04,

does not exhibit a characteristic of a hazardous waste under OAC 3745-51-20 to 3745-51-24, or does not meet any of the

listing descriptions in OAC 3745-51-31 to 3745-51-33.

m3 = cubic meters; t = metric tons; RCRA = Resource Conservation and Recovery Act

To convert m' to ft' multiply by 35.31.

To convert t to tons multiply by 1.1.

Source: USEC, 2005b.

Receipt of UF, Feed Material

Uranium feed for the proposed ACP would be natural uranium in the form of UF6. The UF6 would be

transported to the plant in 48-inch (48X or 48Y), 10-ton or 14-ton cylinders that are designed, fabricated,

packaged and shipped in accordance with American National Standards Institute N14. 1, Uranium

Hexafluoride-Packaging for Transport (ANSI, 1990). Feed cylinders would be typically transported to

the site by 18-wheeled tractor-trailer trucks. It is anticipated that approximately 1,100 shipments of feed

cylinders per year would arrive at the proposed ACP (USEC, 2005b). Expected feed suppliers include the

Cameco Corporation (Ontario, Canada) and Honeywell Specialty Chemical Plant (Metropolis, Illinois), as

shown in Figure 2-6.

Feed Operations

UF6 feed cylinders would be transported to the feed area of the X-3346 Feed and Customer Services

building and placed inside feed ovens. Feed ovens are not pressurized, but do restrict air-leakage to

provide efficient heating of the cylinders. Each feed oven is equipped with a UF6 leak detector. The

ovens would heat the cylinders utilizing electrically heated air at a constant temperature of approximately

85 degrees Celsius (185 degrees Fahrenheit). (USEC, 2004)

The feed process has several stages. UF6 is sublimed from the solid phase into the gas phase and

monitored for the presence of light gases (e.g., nitrogen oxide, oxygen, hydrogen fluoride, etc.). It is then

purified, held, mixed, and pressure-controlled before entering the process buildings. There are two feed

headers located in the feed area that direct each stream to the X-3001 and X-3002 Process Buildings via

the X-2232C Interconnecting Process Piping. Any solid UF6 left in the cylinder after the feed rate

declines to a predetermined level goes to a freezer-desublimer in a process called "heeling." This process

removes residual UF6 "heels" from a cylinder when it can no longer be used to feed material into the

cascade. The emptied feed cylinder would then be placed into storage. (USEC, 2004)

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0 310 620

I . 0 . - - . - - I 0' - -- 300

930 1.240 Kiloleters

600 900 1200 Miles -

Figure 2-6 Incoming UF6 Feed Material

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Enrichment Operations

The uranium enrichment process as described in Section 2.1.2 would occur within the X-3001, X-3002,

X-3003, and X-3004 Process Buildings. Each building would contain multiple cascades to optimize

operating costs and production flexibility. Each cascade would be capable of enriching UF6 gas to the

desired product assay. Enrichment would normally be less than 5.5 percent by weight of uranium-235,

although USEC's license application seeks authorization to produce enriched uranium up to 10 percent by

weight of uranium-235. (USEC, 2004)

Figure 2-7 shows the proposed flow of feed, enriched, and depleted UF6 material and cylinders during full

operation of the ACP. Incoming UF6 feed gas would be distributed to the feed control systems for each

cascade. The feed flow rates to each cascade would be automatically adjusted to ensure the desired feed

is added to the cascade to support the production rate. As the feed enters the cascade, it mixes with

material already in the cascade and separates into enriched and depleted material streams. The proportion

of feed that becomes enriched product is controlled by the stage control valves, which would be adjusted

to provide the desired product and tails assays. This process would continue until the material exits the

top of the cascade as enriched product or the bottom of the cascade as depleted tails material, and is sent

to the X-3356 Product and Tails Withdrawal building. (USEC, 2004)

UF&

Freezer Sublimer

Compressor (cold trap)

1

Enriched UF6 [ Ij

Cold box with cylinder

/.\'with enriched UF6

Separation in centrifuge cascades

IDepleted UF6

Autoclave with Pressure

UF6 transport reduction

container

Compressor

Cold box with cylinder

with depleted UF6

Figure 2-7 Enrichment Operations Flow

20 Product and Tails Withdrawal

21

22 Product withdrawal would occur in the X-3356 and X-3366 Product and Tails Withdrawal buildings. As

23 many as three different product assays can be fed from the process buildings to the X-3356 and X-3366

24 buildings. Product material first transitions from the gas to the solid phase via cold traps, with the off-gas

2-24
1 passing through backup traps and vented through an evacuation system. From the cold traps, the enriched

2 product is transferred into 48X source cylinders located in cold boxes. The filled 48X source cylinders

3 are then moved to interim storage and subsequently moved to the X-3346 building sampling and transfer

4 area. (USEC, 2004)

5

6 Tails withdrawal would occur in the same buildings and would be accomplished through compression and

7 direct deposition of UF6 material into tails cylinders. This process does not involve UF6 pressures above

8 atmospheric pressure, which helps to prevent gas leakage. The tails withdrawal design incorporates the

9 capability for simultaneously withdrawing two uranium assays (USEC, 2004). The compression train

10 consists of centrifugal compressors arranged in series with coolers and with recycle capability. Tails

11 withdrawal can also be used for emergency inventory removal.

12

13 The major components that would support the withdrawal operations are withdrawal (compression) trains,

14 cold boxes, cold traps, assay spectrometers, and vents. The Area Control Room within the X-3356 and

15 the X-3366 buildings would house the assay spectrometers for monitoring tails and product withdrawal,

16 control equipment, and alarms associated with the withdrawal operation.

17

18 Samplin2 and Transfer Operations

19

20 UF6 sampling and transfer operations for UF6 product material would be carried out in the product

21 operations area of the X-3346 Feed and Customer Services building. Autoclaves with heating and

22 cooling capability liquefy UF6 in the source cylinder in order to obtain a homogenized sample, as

23 mandated by the AM erican Society for Testing and Materials sampling standards. Liquid UF6 would then

24 be transferred into customer product cylinders and the autoclave would cool the remaining UF6 heels in

25 the source cylinders until they are solid (USEC, 2004). The autoclaves are pressure vessels and are

26 designed to contain a UF6 release. Electrically heated hot air is the heating medium and cold air is used

27 for cooling.

28.

29 The major components that comprise the sampling and transfer operations are autoclaves, cold traps, and

30 vents. The Area Control Room within the X-3346 building would house the monitoring, control, and

31 alarm equipment associated with the feed operations and sampling and transfer operations.

32

33 Shipment of Enriched Product to Customers

34

35 The X-3346A Shipping and Receiving building would be the shipping point for all cylinders leaving the

36 ACP. Filled customer product cylinders (30-inch, 2.5-ton cylinders) would be transported to customers

37 (nuclear fuel fabrication facilities), while emptied feed cylinders would be returned to vendors. All

38 cylinders would be prepared for shipment and shipped in accordance with NRC and U.S. Department of

39 Transportation regulatory requirements (USEC, 2004). Figure 2-8 shows the destinations of outgoing

40 enriched uranium customer product cylinders.

41

42 All cylinders from the proposed ACP would be transported by 18-wheeled tractor-trailer trucks. These

43 cylinders would be designed, fabricated, and shipped in accordance with the American National

44 Standards Institute standard for packaging and transporting UF6 cylinders, ANSI N 14.1 (USEC, 2005b).

45 A shipment frequency of 1-20 cylinders per five days is typical, with an annual total of approximately

46 1,200 cylinders. Table 2-5 shows the expected recipients of product and the average number of customer

47 product cylinders they would receive yearly.

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l IIsJU

0 300 600 900 1.200 Kilometers

0 310 620 930 1.240 Miles

Figure 2-8

Destination of Outgoing Customer Product

I

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I Approximately 50 30-inch heel cylinders would be shipped to vendors monthly for cleaning and

2 recertification, or washing only (USEC, 2005b): These cylinders have'heel weights 6f less thian'

3 25 pounds. The planned vendors are Westinghouse (Columbia, SC), and Framatome (Richland,'

4 Washington).

5

6 Table 2-5 Expected Product Recipients

7

8

9 - .

10

11

12

13

- Company Location Yearly Average

Framatome ANP Inc. . Richland, Washington . 300 cylinders . ....... _. _..... . _......... ..... ......... . .... .....

:.Global Nuclear Fuel - Americas I Wilmington, North Carolina 400 cylinders .... -....... ----.............-....-- 

Westinghouse Electric Corporation . Columbia, South Carolina 350 cylinders ........... --..... T.

Korea Nuclear Fuel Company - I Korea ; 70 cylinders

M .N.u.lea .e ... b .. ..... . _-----. --.------ ' - I--- .- :.... ...... *' ........- 7- --- -

Mitsubishi Nuclear Co., Ltd. ' aa -. -Fuel -75Japan s

14 Source: USEC, 2005b.

15

16 Manaaement of Wastes from Facility Operation

17

18 Waste generated by the proposed ACP would be collected, handled, packaged, segregated, stored, and

19 shipped for offsite treatment and disposal in accordance with plant procedures and applicable State and

20 Federal regulations. The regulatory requirements associated with waste management are described in

21 Chapter 1, Section 1.5. The proposed ACP would obtain waste management services from a qualified

22 provider licensed by the NRC or an Agreement State. Potential waste streams generated include low

23 level mixed waste, low level radioactive waste, hazardous waste regulated under the Resource

24 Conservation and Recovery Act, sanitary/industrial waste, recyclable waste, and classified waste. The

25 proposed ACP is not projected to generate any polychlorinated biphenyls or asbestos-containing waste

26 that would be regulated under the Toxic Substances ControlAct. Activities would be evaluated for waste

27 minimization opportunities to reduce the volume and toxicity of waste generated to the degree determined

28 to be economically practicable. Waste products would be classified based upon various factors, which

29 includes laboratory analysis, radiological assessment, process knowledge, material safety data sheets, and

30 non-destructive analysis.

31

32 The proposed ACP would also maintain and use gaseous and liquid effluent treatment systems, as -

33 appropriate, to maintain releases of radioactive material to unrestricted areas below the limits specified in

34 10 CFR 20.1301 and 40 CFR Part 190, and in accordance with its "As Low As Reasonably Achievable"

35 policy. These treatment systems are described below.

36 -

37 Air Emissions Monitoring and Treatment Systems

38

39 The primary facilities described in Section 2.1.3 would be equipped with various air emissions

40 monitoring and treatment systems. Since there is potential for the release of hydrofluoric acid gas during

41 operation of the ACP, the vent systems in each primary facility would have gas flow monitoring

42 instrumentation with local readouts. They would also contain analytical instrumentation to continuously

43 sample, monitor, and to alarm if UF6 should escape in the effluent gas stream. Gases evacuated from

44 process systems would pass through cold traps to desublime the potentially high concentrations of UF6

45 and separate it from the non-U16 gases. Residual gases leaving the cold trap would pass through a set of

46 alumina traps to remove any trace quantities of UF6 prior to the gases being vented to atmosphere. When

47 an evacuation system cold trap becomes full, it would be valved off from the vent and its contents.

48 desublimed to a drum so the material could be fed back into the enrichment plant. The cold traps can be

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I bypassed to allow rapid evacuation of a volume not containing radioactive material. The alumina traps

2 cannot be bypassed. In compliance with the policies of USEC's Radiation Protection Program, the

3 ventilation air in the primary facilities would be continuously monitored and the data would be verified

4 quarterly to enure that ventilation exhausts are less than 11 x I O0 becquerel per milliliter (3 x 10-13

5 microcuries per milliliter) uranium (USEC, 2005b).

6

7 A portable gulper (vacuum) system would be used for localized exhaust on applications ranging from

8 pigtail operations to small-scale maintenance tasks. The gulper inlet duct or hose would be placed near

9 the work area. Any escaping airborne contamination would be removed from the source and passed

10 through the duct or hose and into the filter bank, where, depending on the operation, gases are neutralized

II and the particulates removed. The resultant exhaust would be clean air that would typically be discharged

12 into the work area.

13

14 Based on historic experience and operating plans, the radionuclides anticipated to be present in gaseous

15 effluents are uranium-234, -235, and -238. The intention is to not introduce feedstock contaminated with

16 significant concentrations of other nuclides into the process. Feed material that meets the American

17 Standards for Testing and Materials specification for recycled feed may be used, and may contain

18 radionuclides such as uranium-236 and technetium-99. Based on experience at the Portsmouth Gaseous

19 Diffusion Plant, technicium-99 may eventually appear in some ACP gaseous emissions. Consequently,

20 ACP emissions would be analyzed for these four nuclides routinely. The "As Low As reasonably

21 Achievable" goal for airborne radioactive releases from the ACP is 5 percent (5.0 x I 06 sievert per year

22 [0.5 millirem per year]) of the NRC 10 CFR 20.1101 constraint of 0.0001 sievert per year (10 millirem

23 per year) for the most exposed member of the public. This is less than the 10 millirem per year goal

24 recommended in NRC Regulatory Guide 8.37, Regulatory Position C. 1.2 (USEC, 2005b).

25

26 Liquid Effluent Collection and Treatment Systems

27

28 The proposed ACP would be equipped with various liquid effluent collection and treatment systems. The

29 centrifuges and other support equipment are cooled by a closed-loop Machine Cooling Water system to

30 minimize the amount of water potentially contaminated by uranium. There would be no routine

31 blowdown from the Machine Cooling Water system. Waste heat from the Machine Cooling Water

32 system would be discharged via heat exchangers to the Tower Water Cooling system, which would be

33 cooled by a single cooling tower. Waste heat from the cold trap refrigeration systems in X-3346 Feed and

34 Customer Services and X-3356 Product and Tails Withdrawal buildings would also be discharged to the

35 Tower Water Cooling system. Currently, the Tower Water Cooling system discharges its blowdown to

36 the Portsmouth Gaseous Diffusion Plant Recirculating Cooling Water system under a service agreement,

37 which in turn discharges its blowdown directly to the Scioto River via an underground pipeline (permitted

38 outfall 004). The Recirculating Cooling Water system does not provide any treatment of the Tower

39 Water Cooling system blowdown; it simply provides a convenient pathway to a suitable permitted

40 discharge point. At some point in the future, the Tower Water Cooling system blowdown will likely be

41 modified to bypass the Recirculating Cooling Water system and discharge directly to the Recirculating

42 Cooling Water discharge pipeline. No licensed material is anticipated in the Tower Water Cooling

43 system blowdown (USEC, 2005b).

44

45 In the interim, the Portsmouth Gaseous Diffusion Plant Recirculating Cooling Water system has ample

46 capacity to accept the Tower Water Cooling system effluent without either physical modification or

47 adjustment to its discharge limits. Discharges from the Recirculating Cooling Water system are

48 monitored by an automated sampler, which collects a weekly composite sample of the liquid effluent for

49 radiological analysis as well as sample(s) for other required analyses. Historical data indicate that there is

50 reasonable assurance that no unanticipated discharge of licensed material has occurred (USEC, 2005b).

2-28
1 Leakage from the Machine Cooling Water system and incidental spills of water elsewhere in the ACP

2 would be collected by the Liquid Effluent Collection system. The proposed collection system consists of

3 a set of drains and underground collection tanks for the collection and containment of leaks and spills of

4 chemically treated water. The drains are located throughout the DOE reservation. The tanks have a

5 capacity of 550 gallons (gal) each and would be monitored by liquid level gauges mounted above grade

6 on pipe stands. Water accumulated in the tanks would be sampled and analyzed prior to disposal. If the

7 contents meet the requirements of 10 CFR 20.2003, they may be pumped to the reservation sanitary sewer

8 - system. Otherwise the tank contents would be containerized for off-site disposal. An integrity assurance

9 plan would assure that the tanks are not leaking as the ACP takes possession of them. Following

10 completion of this integrity assurance plan, inventory monitoring of the tank contents would be used to

11 detect leaks from the Liquid Effluent Collection System (USEC, 2004).

12 -

13 Storm water runoff from the proposed ACP, along with some once-through cooling water, would drain to

14 a pair of existing holding ponds, the X-2230N West Holding Pond and the X-2230M Southwest Holding

15 Pond. These ponds provide an area for settling suspended solids, dissipation of chlorine, and oil

16 diversion and containment before discharging to unnamed tributaries of the Scioto River. An automated

17 sampler collects a weekly composite sample of the liquid effluent for radiological analysis as well as

18 other required analyses (USEC, 2005b).

1 9

20 An inspection and maintenance program would be conducted for the proposed ACP's UF6 cylinders to

21 ensure that no licensed material is released to the storagepads (USEC, 2005b). Cylinder storage yards

22 would have flat airport runway-quality concrete and would be sealed. The pad would be designed so that

23 spills of liquids could be promptly contained and cleaned up, limiting decontamination of areas to the pad

24 surfaces. Si'milarly, the floor designs in the process buildings would ensure that any spills of liquids can

25 be contained and cleaned up, limiting decontamination of areas to floor surfaces (USEC, 2005b).

26

27 The radionuclides anticipated to be present in ACP liquid effluents are uranium-234, -235, -238, and

28 technicium-99, due to historic contamination of the DOE reservation. Technicium-99 is a fission product

29 that has contaminated much of the national fuel cycle and is present on the Piketon site. Measured

30 technicium-99 concentrations in site outfalls have been falling for several years, but are still sometimes

31 detected. Consequently, effluents from the proposed ACP would be analyzed for these four nuclides

32 routinely. The "As Low As Reasonably Achievable" goal for liquid effluent radioactive releases from the

33 ACP is 5 percent '(5.0 x 1046 sievert per year [0.5 milllirem per year]) 'of the NRC 10 CFR 20.1101

34 constraint of 0.0001 sievert per year (10 millirem per year) for the most exposed member of the public.

35 This is less than the 10 milllirem per year goal recommended in NRC Regulatory Guide 8.37, Regulatory

36 Position C.1.2 (USEC, 2005b).

37

38 Solid Waste Handline, Storage, and Transport

39

40 Waste accumulation areas, such as the XT-847 Waste Preparation Facility, would be established

41 throughout the proposed ACP as necessary to support waste handling, storage, and transport activities.

42 Waste would be sampled and measured to assist in determining the proper waste characterization and

43 disposal or treatment method. -'

44

45 Operations for long-term storage and preparation of waste for off-reservation shipment include sampling,

46 batching, blending, glove box operations, nondestructive assay measurements, dry active waste and

47 contaminated metal sorting, repackaging, and overpacking (USEC, 2005b).' Sampling and batching of

48 some solid waste, especially that with airborne potential, would be performed within a glove box

49 enclosure. Sampling and batching of some liquid waste would be performed by utilizing a blending unit

50 system that is specifically designed for liquid waste collection and sampling. Sampling, batching, and

51 repackaging may also be performed elsewhere on-site, as necessary. The nondestructive assay equipment

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lo l

I located within the XT-847 facility includes a low density waste assay monitor and box monitor. This

2 equipment is utilized to measure the activity of waste in a variety of containers including small diameter

3 containers, drums, and boxes (USEC, 2005b).

4

5 Waste could also be repackaged and/or overpacked within the XT-847 facility. Prior to off-reservation

6 shipment or upon discovery, damaged containers would be repackaged using either a similar container or

7 an 85 or I 10-gallon overpack. The contents of a leaking or damaged waste container may be repackaged

8 by hand, or by utilizing a barrel lift, forklift, forklift rotator attachment, pump, or other means of transfer.

9 Waste would be containerized and labeled in accordance with applicable U.S. Department of

10 Transportation regulations and site procedures. Some general types of waste packaging include:

I I

12 * Solid Waste 5, 30, 55, or 110 gallon drums; small diameter containers

13 * Liquid Waste polybottles; 5, 30, or 55 gallon drums

14 * Corrosives, Acids polybottles or polydrums

15 * Scrap Metal/Dry Active Waste B25 boxes or other similar boxes; various drums

16

17 Contaminated scrap metal, dry active waste, and other boxed waste may be stored outside. Typically,

18 these B25 boxes would be stored on the XT-847 facility west pad; however, they may be stored outside

19 elsewhere on the DOE reservation. If outdoor storage of waste is necessary in other than B25 boxes,

20 radioactive wastes with removable contamination are packaged in containers, wrapped, or covered to

21 prevent the release of radioactivity (USEC, 2005b).

22

23 Waste would be typically removed from the generating facilities and transferred to the XT-847 Waste

24 Preparation facility prior to final disposal; however, in some instances, waste may be shipped off25 reservation directly from other on-site areas. Sanitary/industrial waste would be transported to the USEC26 approved onsite landfill. Hazardous waste would be stored on-site for up to 90 days prior to

27 off-reservation shipment. Classified wastes' would be stored in accordance with the appropriate security

28 and regulatory requirements and would be disposed at an appropriate site in accordance with regulatory

29 requirements. Low level mixed waste and low level radioactive waste would be stored on-site in

30 compliance with NRC, Federal, and State regulatory requirements until shipped off-reservation to a

31 licensed Treatment, Storage, Disposal, Recycling facility. Shipments of low level mixed waste would

32 occur approximately every 90 days. The low level mixed waste is exempted from the storage

33 requirements of the Resource Conservation and Recovery Act as defined in OAC 37455-103. Low level

34 mixed waste is eligible for this conditional exemption as it is a hazardous waste and would be generated

35 and managed by USEC as described in 40 CFR Part 266, Subpart N and OAC 3745-266 (USEC, 2005b).

36

37 Low level radioactive waste and low level mixed waste generated at the proposed ACP would be

38 containerized and given a unique identification number. The identification numbers would be entered

39 and maintained in a computer-based database, and the database would be regularly updated to reflect

40 location, characterization, treatment data, and waste.disposal information. Table 2-6 presents a summary

41 of solid waste generated during the operations phase.

42

43 Management and Disposal of Depleted UF, from Facility Operation

44

45 Approximately 42,800 Type 48G cylinders of depleted UF6 would be generated by the 7 million SWU

46 plant operating full time for 30 years (USEC, 2005a). These cylinders would contain approximately

47 571,000 metric tons (630,000 tons) of depleted U16. The depleted UF6 would be stored onsite in

48 cylinders prior to management or disposal in accordance with USEC's disposal strategy and applicable

' A waste that is classified because of its configuration, composition, contamination, or contained information.

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1

2

3

4

5

6

7

regulations under 40 CFR Part 266 and OAC 3745-266 (USEC, 2004). Figure 2-9 shows some example

depleted UF6 cylinders. Cylinders would be managed in accordance with NRC, U.S. EPA and Ohio EPA

rules for storage, treatment, transportation and disposal of mixed wastes. These requirements include

waste storage compatibility, personnel training, emergency planning, and full compliance with the NRC

-license. - :

.. ~ , ~ - I ~ I .

- w .

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2

3

4

5

6

7

8

9

10

1

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

Table 2-6 Solid WVaste Generated during Facility Operations

Material/Activity Type of Waste Projected Annual Rate

Paper, office waste, bathroom supplies Sanitary/industrial 227-272 t .... 4......................................... ...... ..

Classified Waste Non-regulated, 9-11 m3

..... . ................. ................................................................ ............................................................. ............ ................

Classified Waste' , Low-level radioactive waste 12-15 m3

...... ........................................ ..... ........... A..........................................

General maintenance, plant materials,

laboratory, lubricants, vacuum system Mixed/RCRA 9-11 m3

components, etc.

General maintenance, plant materials,

laboratory, lubricants, vacuum system RCRA-regulated 2-3 m3

components, etc. .............. . ................... . ......... . .............. .................................................. . .............................

General maintenance, plant materials,

laboratory, lubricants, vacuum system Non-regulated. 5-6 in3

components, etc. ... ......... ... ... . ..... ............ . . _.......... . _............... A.......................... ......... ... . . ... .............. ..................... ._..... .....

General maintenance, plant materials,

laboratory, lubricants, vacuum system Low-level radioactive waste 170-340 m3

components, etc.

._...... . ..... . ... . . ............... . ........................... . ................................ ....... ..

Polychlorinated biphenyl waste TSCA-regulated none projected ....... ... ............... ....... ,.... ....... ..

Asbestos waste * TSCA-regulated none projected ................................................. . ......... 4...........

fluorescent bulbs, circuit boards, lead-acid R .

batteries, used oil

Notes:

'A Classified Waste is a waste that is classified because of its configuration, composition, contamination, or

contained information.

'A Non-Regulated Waste is any discarded material that is excluded under the Ohio Administrative Code - OAC 3745-51-04,

does not exhibit a characteristic of a hazardous waste under OAC 3745-51-20 to 3745-51-24, or does not meet any of the

listing descriptions in OAC 3745-51-31 to 3745-51-33.

m3 = cubic meters; t = metric tons; RCRA = Resource Conservation and RecoveryAct; TSCA = Toxic Substances Control

Act.

To convert m' to III multiply by 35.31.

To convert t to tons multiply by 1. 1.

Source: USEC, 2005b.

Figure 2-9 Example of Depleted UF6

Cylinders (Urenco, 2003)

36

2-32
1 The cylinders primarily used for storage of tails Depleted UF6 Conversion Process

2 are known as Model 48G cylinders. These

3 cylinders are made of carbon steel and are about 4 Depleted UF6 conversion is a continuous.

4 feet in diameter, 12 feet long, and weigh about process in which depleted UF6 is vaporized and

5 30,000 pounds when full (USEC, 2005b). While converted to triuranium octaoxide (U 3 02) by

6 a cylinder is being filled, it is cooled so that the reaction with steam and hydrogen in a

7 gaseous depleted UF6 is solidified. Once the fluidized-bed conversion unit. The hydrogen is

8 depleted UF6 is solidified, a filled cylinder is then generated using anhydrous ammonia, although

9 moved to a cylinder yard where it is stacked in an option of using natural gas is being

10 place. The cylinders would be inspected and -investigated. Nitrogen is also used as an inert

11 maintained while being stored onsite. purging gas and is released to the atmosphere

12 Maintenance activities would include periodic through the building stack as part of the clean

13 inspection for corrosion, valve leakage, or off-gas stream. The depleted powder is collected

14 distortion of cylinder shape. Repainting of the andpackagedfor disposition. The process

15 cylinders would be conducted as indicated by the' equipment would be arranged in parallel lines.

16 inspections. Depleted UF6 may be transferred Each line would consist of two autoclaves, two

17 into new cylinders during plant operation in the conversion units, a hydrofluoric acid recovery

18 event that cylinder inspection indicates potential system, andprocess off-gas'scrubbers.

19 loss of cylinder containment. Equipment would also be installed to collect the

20 hydrofluoric acid co-product andprocess it into

21 DOE has decided to construct and operate a new any combination ofseveral marketable

22 UF6 conversion facility at the DOE reservation in products. A backup hydrofluoric acid

23 Piketon (DOE, 2004b). The facility will convert neutralization system would beprovided to

24 DOE's inventory of depleted UF6 now located at convert up to 100 percent of the hydrofluoric

25 the Piketon reservation and at the East Tennessee acid to calcium fluoride for storage and/or sale

26 'Technology Park in Oak Ridge, Tennessee to a in theJfutre, ifnecessary.

27 more stable chemical form (triuranium octaoxide Source: (DOE, 2004a: DOE 2004b).

28 [U308] or uranium dioxide [UOJ]) acceptable for _

29 transportation, beneficial use/reuse, and/or

30 disposal. A related objective is to provide

31 cylinder surveillance and maintenance of the DOE inventory of depleted UF6, low-enrichment UF6,

32 natural assay UF6, and empty and heel cylinders. The location of this conversion facility on the

33 reservation property is directly north of the proposed ACP. The facility will have a construction period of

34 two years, an operational period of 18 years, and a decontamination and decommissioning period of three

35 years. Construction began in the summer of 2004. The environmental impacts of the proposed UF6

36 conversion facility are addressed in detail in a separate EIS published by DOE in June 2004 (DOE,

37 2004b).

38

39 USEC proposes to transport the depleted UF6 generated at the proposed ACP to this new UF6 conversion

40 facility on the DOE reservation in Piketon. This plan is based on Section 3113 of the 1996 United States

41 Enrichment Corporation Privatization Act that states the DOE "shall accept for disposal low-level

42 radioactive waste, including depleted uranium if it were ultimately'determined to be low-level radioactive

43 waste, generated by [ ...] any person licensed by the Nuclear Regulatory Commission to operate a uranium

44 enrichment facility under Sections 53, 63, and 193 of the Atomic Energy Act of 1954 (42 U.S.C.2073,

45 2093, and 2243)." On January 18, 2005, the Commission issued its ruling that-depleted uranium is

* 46 considered a form of low-level radioactive waste (NRC, 2005). The Commission'also stated that disposal

47 of depleted uranium tails at a DOE facility represents a plausible strategy for the disposition of depleted

48 uranium tails (NRC, 2005).

49

50 Once converted to U3 0 or U0 2, the depleted uranium from the proposed ACP -would be temporarily

51 stored onsite and then shipped offsite for disposal. During its evaluation of disposal of depleted uranium

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I in a licensed low-level radioactive waste disposal facility, the NRC staff determined that at least one

2 facility (the Envirocare facility in Clive, Utah) is currently licensed to accept the material. Other disposal

3 facilities, such as the DOE-operated Nevada Test Site facility, may also be able to accept this material and

4 additional evaluations of these facilities may be required prior to disposal (DOE, 2004b).

5

6 2.1.4.4 Decontamination and Decommissioning

7

8 At the end of useful plant life, the proposed ACP would be decontaminated and decommissioned such

9 that the facilities would be returned to DOE in accordance with the requirements of the Lease Agreement

10 with DOE and in accordance with applicable NRC license termination requirements. Decontamination

11 and decommissioning of the proposed ACP would be funded in accordance with the Decommissioning

! 12 Funding Plan for the proposed ACP (USEC, 2005a). The Decommissioning Funding Plan, prepared by

13 USEC in accordance with 10 CFR 70.25(a), provides information required by 10 CFR Part 70 regarding

14 USEC's plans for funding the decommissioning of the proposed ACP and the disposal of depleted

15 uranium tails generated as a result of plant operations. Funding would be provided by USEC by means of

16 a surety bond or alternate financial assurance mechanism in accordance with NRC guidance in 10 CFR 70

17 and NUREG-1757 (NRC, 2003).

18

19 The intent of decommissioning is to return the proposed ACP site to a state that meets NRC requirements

20 for release for unrestricted use after decontamination and decommissioning is completed (USEC, 2004).

21 It is anticipated that at the end of the useful life of the plant, most of the buildings and outdoor areas of

22 the plant would already meet NRC requirements for unrestricted use in accordance with 10 CFR 20.1402.

23 Any buildings, outdoor areas, or equipment that do not already meet the NRC requirements at the time the

24 ACP ceases operations would be decontaminated and decommissioned in accordance with the

25 Decommissioning Plan for the site. The site decommissioning costs estimated in the Decommissioning

26 Funding Plan are based on decontamination of the plant to the radiological criteria for unrestricted use in

27 10 CFR 20.1402. The total estimated cost of decommissioning a 7 million SWU plant in 2004 dollars is

28 currently $435 million, not including the cost of disposal of depleted uranium tails generated by plant

29 operations, which will be funded separately by USEC (USEC, 2005a). The surety bond or other financial

30 mechanism would be updated throughout the operating life of the ACP in accordance with 10 CFR

31 70.25(e).

32

33 It is anticipated that the proposed ACP would generate approximately 19,040 metric tons (21,000 tons)

34 per year of depleted UF6. In total, approximately 42,800 cylinders containing more than 571,200 metric

35 tons (630,000 tons) of depleted UF6 would be generated by the 7 million separative work unit plant

36 operating full time for 30 years (USEC, 2005b). USEC has assumed that the depleted UP6 would be

37 processed in a DOE-operated conversion facility and then shipped offsite for disposal. Based on the

38 amount of depleted UF6 anticipated to be generated over the operating life of the proposed ACP, the

39 estimated financial liability for depleted UF6 disposal is approximately $1,433 million in 2004 dollars.2

40 This financial liability would be incrementally funded by USEC over the course of plant operating life as

41 the depleted UF6 is generated. The Decommissioning Funding Plan cost estimate for depleted UF6

42 disposal is based on the assumption that the depleted UF6 would be converted to a stable form (U308 or

43 U02) and disposed of in accordance with the USEC Privatization Act, other applicable statutory'

44 requirements, and requirements applicable to DOE-operated depleted UF6 conversion facilities and/or

45 other licensed facilities.

2 USEC's estimate for depleted UF6 disposal was based on a 1998 agreement. USEC has not yet updated this

cost for tails disposition and as a result, the final cost for tails disposition is not available.

2-34
I Decontamination and decommissioning activities for the proposed ACP are anticipated to occur

2 approximately 30 years in the future, and therefore only a general description of the activities that would

3 be conducted for the proposed ACP can be developed at this time for the Draft EIS. The facility will

4 follow NRC decommissioning requirements in 10 CFR 70.38.

5

6 The NRC anticipates that decontamination and decommissioning will involve the following activities:

7

8 * Installation of decontamination facilities;

9 * Purging of process systems and equipment;

10 * Dismantling and removal of facilities and equipment;

11 * Decontamination and destruction of confidential materials;

12 * Decontamination of equipment, facilities, and structures;

13 * Survey and spot decontamination of outdoor areas;

14 * Removal and sale of any salvaged materials;

15 * Removal and disposal of wastes;

16 * Management and disposal of depleted uranium; and

17 * Final radiation survey to confirm that the release criteria have been met.

18

19 2.1.4.5 Ceasing Operations at Paducah

20

21 Enrichment operations at the Paducah Gaseous Diffusion Plant will ultimately cease after the ACP

22 becomes operational. The control and categorization of the land for industrial use within the boundaries of

23 the Paducah site would not change as a result of cessation of enrichment plant operations.

24

25 Decommissioning of the Paducah Gaseous Diffusion Plant and any other future use of the enrichment

26 plant buildings, structures, or land are not considered part of the proposed action considered in this Draft

27 EIS. Decisions concerning decommissioning and any other future use of the enrichment plant would be

28 the subject of other decisions and other environmental reviews.

29

30 2.2 No-Action Alternative

31

32 Under this alternative, the NRC would not approve the license application for the proposed ACP. The no33 action alternative would result in USEC not constructing, operating, or decommissioning the proposed

34 ACP at the DOE reservation in Piketon, Ohio. Under the no-action alternative, the uranium fuel fabrication

35 facilities in the United States would continue to obtain low-enriched uranium from the currently available

36 sources. Currently, the only domestic source of low-enriched uranium available to fuel fabricators is from

37 production of the Paducah Gaseous Diffusion Plant and the down blending of highly enriched uranium

38 under the "Megatons to Megawatts" program, as described in Section 1.3.1 of this Draft EIS. Foreign

39 enrichment sources are currently supplying as much as 86 percent of the U.S. nuclear power plants'

40 demand (EIA, 2004).

2-35
. I

I Currently, the "Megatons to Megawatts" program will expire by 2013, potentially eliminating down

2 blending as a source of low-enriched uranium. Opened in 1952, the Paducah Gaseous Diffusion Plant

3 utilizes gaseous diffusion technology, a process that is more energy intensive and requires higher energy

4 consumption than the newer gas centrifuge technology. Additional domestic enrichment facilities utilizing

5 a more efficient technology in the future could be constructed. In 2003, Louisiana Energy Services

6 submitted a license application to the NRC to construct, operate, and decommission a gas centrifuge

7 uranium enrichment facility near Eunice, New Mexico. The proposed facility, called the National

8 Enrichment Facility, would produce enriched uranium-235 up to 5 weight percent with an annual

9 production level of 3 million separative work units. If the proposed National Enrichment Facility begins

10 operations, this would represent a more efficient and less costly means of producing low-enriched uranium

11 than the current gaseous diffusion technology at the Paducah Gaseous Diffusion Plant.

12

13 Another aspect of the no-action alternative specific to the DOE Portsmouth Reservation is that the

14 buildings and land proposed to be used for the ACP would not be available for reindustrialization. The

15 DOE evaluated the land, buildings, and facilities at the DOE Portsmouth Reservation for potential

16 reindustrialization as well as the potential impacts of various reindustrialization programs at the reservation

17 in DOE/EA-1346 (DOE, 2001). DOE concluded that approximately 526 hectares (1,300 acres) or about

18 35 percent of the reservation is available for transfer and that the facilities that are under lease to USEC are

19 not available for reindustrialization, as such activities are crucial to fulfilling DOE's nuclear energy

20 mission. Appendix C of DOE/EA-1346 contains a list of all the buildings and facilities on the reservation

21 and whether or not they are available for the reindustrialization program. Once the USEC lease would

22 expire, DOE would re-evaluate its mission needs and other considerations (e.g., contamination) and would

23 determine which facilities would become available for the reindustrialization program and which would

24 remain under DOE control. Because for the foreseeable future the buildings and land proposed to be used

25 for the ACP currently are leased by USEC for the development and operation of the Lead Cascade Facility

26 and the impacts associated with reindustrialization have been evaluated in DOEIEA-1346, no

27 reindustrialization activities are associated with the no-action alternative.

28

29 2.3 Alternatives Considered but Eliminated

30

31 As required by NRC regulations, the NRC staff has considered other alternatives to the construction,

32 operation, and decommissioning of the proposed ACP. The range of alternatives was determined by

33 considering the underlying need and purpose for the proposed action. This analysis led to the following

34 set of reasonable alternatives:

35

36 * An alternative of constructing the ACP at the existing Paducah Gaseous Diffusion Plant;

37 * Alternative sites within the DOE reservation at Piketon;

38 * Alternative sources from down blending highly enriched uranium;

39 * Alternative sources of low-enriched uranium;

40 * Alternative technologies available for uranium enrichment; and

41 * Alternative conversion and disposition methods for depleted UF6.

42

43 These alternatives were considered but eliminated from further analysis due to economic, environmental,

44 national security, or technological maturity reasons. The following sections discuss these alternatives and

45 the reasons the NRC staff eliminated them from further consideration.

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I
1 23.1 Construction and Operation of the ACP at the Paducah Gaseous Diffusion Plant in Paducah,

2 Kentucky

3

4 The construction and operation of the ACP at the Paducah Gaseous Diffusion Plant was considered as a

5 reasonable alternative to the proposed action. Figure 2-10 shows the location of the Paducah Gaseous

6 Diffusion Plant in relation to the DOE reservation in Piketon, Ohio.

7

8

9

10

11

12

13

14

15

16

17

18

19

ante Bade

* P asjc Gasom Diftunio Pint Loeadon * 1 X0 2D o

_ W "a 2- MV

Figure 2-10 Location of the Paducah Gaseous Diffusion Plant

NRC staff concludes that while both sites are suitable on the basis of environmental, socioeconomic, and

regulatory factors, the site in Paducah, Kentucky had a number of disadvantages. For example, seismic

factors at Paducah would increase the cost of construction, could make the engineering effort more

complex, and could make the plant safety considerations more uncertain. Overall, the NRC staff found

that the selection of the Paducah site would result in somewhat greater environmental impacts due

primarily to the need for construction of all new buildings, and the attendant excavation and land

disturbance.

Table 2-7 provides a comparative analysis of the key environmental factors of the Piketon site versus the

Paducah site. Based on this comparison, the NRC staff concludes that the Paducah site offers no

environmental advantages and can be dropped from more detailed consideration in this Draft EIS.

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4

5

6

7

8

9

10

Table 2-7 Comparison of Environmental Impacts at Alternative Site Locations

Resource Area Greater

Piketon' Paducah Impact

Land Use * The ACP would refurbish and use * All primary and secondary facilities

existing buildings and utilities. for the ACP would be newly

Some new process buildings, constructed and would disturb

support facilities, and cylinder previously undeveloped and

yards would be constructed on uncontaminated areas of the

previously disturbed land. Paducah DOE reservation (managed

lawns and fields). Utilities are

already available onsite. _ ..... ..........------- .......... . . . . . . . .... . .... . .. ... . ... .. . . . .. ......... . ... . ...

Historic and The impacts to historic and The State Historic Preservation

Cultural cultural resources identified onsite Officer would be consulted prior to

Resources j and around the site's perimeter construction at Paducah; however, Unknown

would be small. potential impacts to historic and

cultural resources are unknown. ........................ _.... . ..... . ......... _ .. .. _ _. .......... . _ ........ .

Visual/Scenic * Changes to existing facilities and * Architectural consistency would be

Resources construction of new buildings maintained to ensure blending of the

would be consistent with existing ACP construction with existing

site architectural features. Neither facilities.

these changes nor the new There are no existing State nature

construction would alter the preserves or scenic rivers at Same

existing visual characteristics of Paducah.

the site.

There are no existing State nature

preserves or scenic rivers at

Piketon. ............. _ ...... ....... _................_... ........ . . .... ........... ;....... . .. .......... . .... _...... ........... 4........ ............. .... .. .

Air Quality Pike County and the proposed McCracken County is in NAAQS

ACP site are in National Ambient non-attainment for 8-hr ozone. The

Air Quality Standard (NAAQS) Paducah Gaseous Diffusion Plant

attainment for criteria pollutants. site itself, however, is in attainment

Air quality impacts associated for all criteria pollutants.

with construction will have no Air quality impacts associated with

lasting significant impacts on air construction will have no lasting

quality. significant impacts on air quality.

The average calculated hydrogen * The average calculated HF a

fluoride (HF) concentration is concentration is 2.27x I0-'

2.35x 10 micrograms per cubic micrograms per cubic meter at the

meter at the location of the location of the Maximally Exposed

Maximally Exposed Individual. Individual.

The maximum emission rate The projected maximum emission

anticipated under normal rate for the ACP is 1.86 millicuries

operations is 1.1 millicuries of per week, or 0.097curies per year of

uranium per week, or up to 0.057 total uranium.

curies per year. _ . .......... . ...... . .. :............. ............... . ............. ............ . ................. ... ..... .... ................. ...................... . . ..... .... _.._

2-38

I
Table 2-7 Comparison of Environmental Impacts at Alternative Site Locations (continued)

Resource Area | | I Greater

j -PiketonX ] iaducah | Impact

Geology and * Soil disturbance from project . The nature of the impacts would be

Soils activities would occur in the same as that for Piketon, except

construction lay-down areas, they would be more extensive due to

destroying the soil profile and the need for all new construction.

leading to a possible temporary

increase in erosion due to storm

water runoff and wind. Paducah

Engineering controls and best

management and construction

practices would be implemented

to minimize the extent of

excavation, erosion, and sediment

runoff. .~~~~. _ _,_........... _. _ ._ .. . .... __ ._ . ;_... _.. .............. ... __........ ... .. _.;_._....._..

Water Best management and * Best management and construction

Resources construction practices and erosion practices and erosion controls would

controls would minimize potential minimize potential impacts to

impacts to surface and ground surface and ground water during

water during construction. construction.

The Liquid Effluent Collection Safety procedures, spill prevention I

system, monitoring of liquid plans, and spill response plans Same

release points, and complying would avoid impacts from accidental

with all NPDES permitting discharges during plant operation.

requirements would minimize

potential impacts to surface and

ground water during plant

operation. ..-......- .... . .. ......... . .- ... t ..- .. .......... ... .-.... .... . .-.

Ecological . * Some threatened or endangered . * Some threatened or endangered

Resources species, including the Indiana bat species including the Indiana bat

(Myotis sodalis), Virginia (Myotis sodalis), the tiberculedmeadow-beauty (Rhexia blossom pearly mussel (Epioblasmna

virginica), and Carolina torulora), pink-mucket pearly

yellow-eyed grass (Xyris mussel (Lampsilis orbiculata), and

difformis) are present or the orange-footed pearly mussel

potentially located in the (Plethobasus cooperrianus) are

surrounding region. None of the present or potentially located in the

proposed site preparation and surrounding region. Wetlands are in

construction activities would the area, but are not located in the

occur in any of the jurisdictional immediate vicinity of the proposed

or nonjurisdictional wetlands on construction area.

the DOE reservation. ..... _._ ...... .. . _.__ . ............ . .. . .. . .... . _._.. . ....... .. _._._..__. . .. .. . .......... . ..... . ......... __ ..... . ....... . .......... .

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2

3

Table 2-7 Comparison of Environmental Impacts at Alternative Site Locations (continued)

Resource Area | I | Greater

Piketon' Paducah Impact

Socioeconomic * * 3,362 direct and indirect jobs per . 3,899 direct and indirect jobs per

year are expected during the year are expected during the

construction phase. construction phase.

Facility operations are expected to * Facility operations are expected to

create 1,500 direct and indirect create 1,860 direct and indirect jobs.

jobs. No significant impacts to tax Paducah

No significant impacts to tax revenue, population characteristics,

revenue, population housing availability, or community

characteristics, housing are expected.

availability, or community are

expected. ....... -. .. . _._._L. _ ...... ................. ... ........ ..... . .... _._ . ..... .. _ .... .. . ....... ;....

Environmental . * No disproportionately high and . No disproportionately high and

Justice adverse impacts to minority or adverse impacts to minority or

low-income populations within an low-income populations within an Same

80-kilometer (50-mile) radius of 80-kilometer (50- mile) radius of the

the Piketon site. . Paducah site (DOE, 2004a). ............ ........ _. 4. ... _..... . _ . ... ...... .......... .. . ...... ..... _ ._

Noise Impacts * Construction noise levels are * Noise associated with the

estimated to reach a 53 day-night construction phase would be

average noise level, which meets temporary and not expected to

the standards for community noise * significantly increase overall noise

levels at the nearest residence. levels at the Paducah site.

No adverse impacts from Operation of the centrifuge system is S

operational noise are expected at not expected to increase the noise

the closest residential receptor levels outside the proposed facilities.

due to low operational noise,

attenuation from the building, and

i distance attenuation of over 914

meters (3,000 feet). _._ ..... _ _....._ .............. _. ___...... ............... .. ._. _ ............. ._.. ......... . ......... ......... ............ _..... .......... _._ ... __ .... ____._

4

2-40
Table 2-7 Comparison of Environmental Impacts at Alternative Site Locations (continued)

Resource Area Greater

Piketon' Paducah Impact

Transportation The proposed action will not * Transportation impacts during site

significantly change the Level of preparation and construction would

Service classifications for U.S. be approximately double that of

Route 23 or SR 32. Piketon due to the need for all new

During site preparation and facility construction.

construction, the expected number All other transportation impacts

of injuries to workers is 93 and would be approximately the same.

expected number of fatalities is

1.03. For drivers transporting

material and equipment to and

from the site, the expected

number of injuries is 3.61and Paducah

expected number of fatalities is

0.10.

During facility operation, the

expected number of injuries to

workers is 7.9 and expected

number of fatalities is 0.09. For

drivers transporting material and

equipment to and from the site,

the expected number of injuries is

0.19 and expected number of

fatalities is 0.01.

Public and * Construction and industrial Construction and industrial activities

Occupational activities would be managed would be managed under the OSHA

Health under the OSHA industrial industrial regulations (29 CFR 1910)

regulations (29 CFR 1910) and in and in compliance with site licenses

compliance with site licenses and and permits.

permits. The use of spill response plans,

The use of spill response plans, safety procedures, spill controls, -i

safety procedures, spill controls, countermeasures plans, and spill

countermeasures plans, and spill response equipment in accordance Same

response equipment in accordance i with Federal and State laws, would

with Federal and State laws, 'minimize the likelihood and severityi

would minimize the likelihood of potential impacts from accidental

and severity of potential impacts discharges.

from accidental discharges. * The radiological risk for all receptor

The radiological risk for all *groups is below applicable criteria.

receptor groups is below

i applicableiteria. . i; .._. ....... .. cr.i.t. ..........._.......plial. ..... ....... ... ...... ............ ._ ........... . _ . . ...... _

* .:

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Resource Area Greater

Piketon' Paducah Impact

Waste * The projected annual rate of Quantities of waste are assumed be

Management sanitary/industrial waste is 2,240 the same as the proposed Piketon

tons * site for all activities except

I The projected annual rate of . construction, which would generate

RCRA and MixedIRCRA waste is more at Paducah.

1,510 cubic feet. Sanitary/industrial waste in the

The projected annual rate of construction phase at Paducah is

LLRW is 313,020 cubic feet. projected to be double that of

The projected annual rate of non- Piketon, due to the need for all new Paducah

regulated waste is 800 cubic feet. buildings.

The project annual rate of

recyclables is 6,500 cubic feet.

The proposed ACP is expected to

generate approximately 571,200

metric tons (630,000 tons) of tails

over its 30-year license period

(about 42,800 tails cylinders). . *.

4 2.3.2 Other Alternative Sites

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USEC used a site-selection process to identify viable alternative sites for the construction, operation, and

decommissioning of the proposed ACP. The NRC staff has evaluated that process and determined that it is

rational and objective, and that its results are reasonable. The candidate sites and the reasons they were not

chosen as the preferred site location are described in the following sections.

Alternative Locations at the DOE Reservation in Piketon, Ohio

The DOE reservation in Piketon was evaluated to identify alternative locations for the ACP and three

possible sites were identified, as shown in Figure 2-11. Location A is the preferred location for the ACP

and is discussed in detail as the proposed action. This location is within the existing footprint of the DOE

Gaseous Diffusion Plant facility and would be classified as a "brownfield" site. Further, compared to the

other potential site locations, this location is the most isolated from the property boundary, which would

likely result in a lower potential dose to the general public from any accidental or operational releases

during construction, operation, and decommissioning of the proposed ACP.

Location B is located in the southeast portion of the site. This location consists of a level to very gently

rolling grass field to a rolling forested hill. The level area was graded during the construction of the

Gaseous Diffusion Plant in the 1950s and has been maintained as grass fields.

Location C is located in the northeast portion of the site and, like Location B, consists of a level to very

gently rolling grass field to a rolling forested hill. It too was graded during the construction of the Gaseous

Diffusion Plant and has been maintained as grass fields.

Locations B and C were not selected as the preferred alternative primarily due to the lack of existing

buildings, extensive site preparation that would be needed, lack of access to utility services, and new

construction that would be required. Neither location B or C had an environmental advantage over

Location A or afforded the advantages offered by Location A, which is the site of the former Gas

Centrifuge Enrichment Plant buildings.

2-42
Figure 2-11 Alternative Sites at the DOE Reservation for the Proposed ACP

I Construct and Operate the ACP at a Non-Gaseous Diffusion Plant Location

2

3 This alternative involves constructing and operating the ACP at an undisturbed "green field" site, or a

4 disturbed site other than one of the existing Gaseous Diffusion Plants in Piketon, Ohio or Paducah,

5 Kentucky. This alternative was not selected as the preferred alternative because it is inconsistent with the

6 DOE-USEC Agreement and because the Gaseous Diffusion Plant sites provide schedule, regulatory, and

7 cost advantages over other sites. The DOE-USEC Agreement stipulates that USEC deploy the ACP at

8 either the DOE reservation in Piketon or Paducah. Also, no other sites offered the unique combination of

9 (1) readily accessible environmental data; (2) past history and experience in uranium enrichment; and (3)

10 the availability of skilled labor with uranium enrichment industry experience. A "green field" situation

11 would not have readily accessible environmental data for the purpose of impact assessment and

12 performance monitoring. Without available skilled labor with uranium enrichment experience, USEC

13 would have to either provide training or relocate trained personnel at added expense. The environmental

14 impact of this alternative would be either to disturb a "green field" site or to possibly introduce emission

15 and effluents associated with uranium enrichment to an existing industrial site.

16

17 None of the alternatives considered would be obviously superior to the proposed location for the ACP at

18 the DOE reservation in Piketon, Ohio.

2-43
II

1 2.3.3 Alternate Sources from Down Blending Highly Enriched Uranium

2

3 This alternative involves not constructing a domestic uranium enrichment plant to replace existing Gaseous

4 Diffusion Plant production. Instead, an equivalent amount of separative work units would be obtained

5 from down blending highly enriched uranium from either United States or Russian nuclear States or

6 Russian nuclear warheads, or from the Nuclear Fuel Services facility in Erwin, Tennessee.

7

8 This alternative was not selected as the preferred alternative because it does not meet the commitments in

9 the DOE-USEC Agreement, which requires that an ACP be constructed and operated. This alternative was

10 also eliminated since it would be contrary to Congressional intent and common defense and security and

11 does not meet the need as discussed in Section 1.3. USEC is the Executive Agent for a U.S. Government

12 agreement that purchases low-enriched uranium that is derived from down blending of highly enriched

13 uranium from Russian warheads. In February 1993, the U.S. Government agreed to purchase from Russia

14 500 metric tons (492 tons) of highly enriched uranium extracted from dismantled nuclear weapons over a

15 20-year period, which expires in 2013 (USEC, 2005b). It is uncertain whether this agreement will be

16 extended beyond 2013.

17

18 Currently, the equivalent separative work units from down blended highly enriched uranium complements

19 domestic separative work unit production at the Paducah Gaseous Diffusion Plant. While the U.S.

20 Government may wish to extend this arrangement to continue the reduction of the number of nuclear

21 weapons in the world, it is doubtful that the agreement would replace rather than complement domestic

22 separative work unit production. As discussed in Section 1.3, it is a national priority to increase domestic

23 supplies of enriched uranium to improve national energy security.

24

25 2.3.4 Alternative Sources of Low-Enriched Uranium

26

27 The NRC staff examined two alternatives to fulfill U.S. domestic enrichment needs. These alternatives,

28 for reasons summarized below, were eliminated from further consideration.

29

30 Re-Activate the Portsmouth Gaseous Diffusion Facility at Piketon

31

32 United States Enrichment Corporation closed the Portsmouth Gaseous Diffusion Plant (located in Piketon)

33 in May 2001 to reduce operating costs (DOE, 2003). United States Enrichment Corporation cited

34 long-term financial benefits, more attractive power price arrangements,' operational flexibility for power

35 adjustments, and a history of reliable operations as reasons for choosing to continue operations at the

36 Paducah Gaseous Diffusion Plant. In a June 2000 press release, United States Enrichment Corporation

37 explained that they "...clearly could not continue to operate two production facilities." Key business

38 factors in United States Enrichment Corporation's decision to reduce operations to a single production

39 plant included long-term and short-term power costs, operational performance and reliability, design and

40 material condition of the plants, risks associated with meeting customer orders on time, and other factors

41 relating to assay levels, financial results, and new technology issues (USEC, 2000).

42

43 The NRC staff does not believe that there has been any significant change in the factors that were

44 considered by United States Enrichment Corporation in its decision to cease uranium enrichment at

45 Piketon. In addition, the gaseous diffusion technology is more substantially energy intensive than gas

46 centrifuge. The higher energy consumption results in larger indirect impacts, especially those impacts

47 which are attributable to significantly higher electricity usage (e.g., air emissions from coal-fired electricity

48 generation plants) (DOE, 1995). The age of the existing Gaseous Diffusion Plant also calls into question

49 its overall reliability. Therefore, this proposed alternative was eliminated from further consideration.

2-44
1 Purchase Low-Enriched Uranium From Foreign Sources

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There are several potential sources of enrichment services worldwide. However, United States reliance on

foreign sources of enrichment services, as an alternative to the proposed action, would not meet the

national energy policy objective of a "...viable, competitive, domestic uranium enrichment industry for the

foreseeable future" (DOE, 2000). For this reason, the NRC staff does not consider this alternative to meet

the purpose and need for the proposed action, and eliminated it from further study.

2.35 Alternative Technologies for Enrichment

A number of different processes have been invented for enriching uranium, but only two have been proven

suitable for commercial and economic use. Only the gaseous diffusion process and the gas centrifuge

technology have reached the maturity needed for industrial use. Other technologies-namely the

Electromagnetic Isotope Separation Process, Liquid Thermal Diffusion, and a laser enrichment

process-have proven too costly to operate or remain at the research and laboratory developmental scale

and have yet to prove themselves to be economically viable.

Electromagnetic Isotope Separation Process

Figure 2-12 shows a sketch of the

Electromagnetic Isotope Separation Process. In

this process, a monoenergetic beam of ions of

normal uranium travels between the poles of a

magnet. The magnetic field causes the beam to

split into several streams according to the mass

of the isotope. Each isotope has a different

radius of curvature and follows a slightly

different path. Collection cups at the ends of the

semicircular trajectories catch the homogenous

streams. Because the energy requirChnents for

this process proved very high-in excess of

3,000 kilowatt hour per separative work

unit-and the production was very slow

(Heilbron et al., 1981), electromagnetic isotope

separation was removed from further

consideration.

Cher~ed r t

Electron Sun

Figure 2-12 Electromagnetic Isotopic Separation - - Process (Milani, 2005)

245
I Liquid Thermal Diffusion

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The liquid thermal diffusion process was

investigated in the 1940s. Figure 2-13 is a

diagram of this process. It is based on the concept

that a temperature gradient across a thin layer of

liquid or gas causes thermal diffusion that

separates isotopes of differing masses. When a

thin, vertical column is cooled on one side and

heated on the other, thermal convection currents

are generated and the material flows upward along

the heated side and downward along the cooled

side. Under these conditions, the lighter UF6 Cool Exterior 130 OFmolecules diffuse toward the warmer surface and

heavier UF6 molecules concentrate near the cooler

side. The combination of this thermal diffusion

and the thermal convection currents causes the

lighter uranium-235 molecules to concentrate on

top of the thin column while the heavier uranium238 goes to the bottom. Taller columns produce

better separation. Eventually, a facility using this liquid UF

process was designed and constructed at Oak

Ridge, Tennessee, but it was closed after about a

year of operation because of cost and maintenance Figure 2-13 Liquid The

concerns (Settle, 2004). Based on high operating (Milan

costs and high maintenance requirements, the

liquid thermal diffusion process has been eliminated from further consideration.

Pressure Steam 400 'F

ermal Diffusion Process

i, 2005)

Gaseous Diffusion Process

The gaseous diffusion process is based on

molecular effusion, a process that occurs Endched

whenever a gas is separated from a vacuum by High Pressure Stream

a porous barrier. The gas passes through the Feed Stream

holes because there are more "collisions" with

holes on the high-pressure side than on the

low-pressure side (i.e., the gas flows from the 'I-.,- U Depleted

high-pressure side to the low-pressure side).

The rate of effusion of a gas through a porous

barrier is inversely proportional to the square Figure 2-14 Gaseous Diffusion Stage (FAS, 2000)

root of its mass. Thus, lighter molecules pass

through the barrier faster than heavier ones. Figure 2-14 is a diagram of a single gas diffusion stage. The

gaseous diffusion process consists of thousands of individual stages connected in series to multiply the

separation factor. The gaseous diffusion plant in Paducah, Kentucky, contains 1,760 enrichment stages

and is designed to produce UF6 enriched up to 5.5 percent uranium-235. The design capacity of the

Paducah Gaseous Diffusion Plant is approximately 8 million separative work units per year, but it has

never operated at greater than 5.5 million separative work units. Paducah consumes approximately 2,200

kilowatt hours per kilogram of separative work unit, which is less than the electromagnetic isotopic

separation process or liquid thermal diffusion process but still higher than the 40 kilowatt hours per kilogram of separative work unit possible in modem gas centrifuge plants (DOE, 2000; Urenco, 2004).

2-46
I The gaseous diffusion process is a 50-year-old technology that is energy intensive and has been eliminated

2 from further consideration.

3

4 Laser SeDaration Technologv

5

6 Laser separation technology encompasses two known developmental technologies that have yet to reach

7 the maturity stage for industrial use. These are the Atomic Vapor Laser Isotope Separation and the

8 Separation of Isotopes by Laser Excitation processes.

9

10 TheAtomic Vapor Laser Isotope Separation

11 process, diagrammued in Figure 2-15, is based on AVuSP-oc Law Sy-sm

12 different isotopes of the same element. The ge We

13 isotopes, though chemically identical, have c1.11 E:

14 different electronic energies and absorb different taor

15 colors of laser light. The isotopes of most r

16 elements can be separated by a laser-based process U r A / 

17 if they can be efficiently vaporized into individual - Npofow Produ

18 atoms. In Atomic Vapor Laser Isotope Separation e'uj Vapor

19 enrichment, uranium metal is vaporized and the

20 vapor stream is illuminated with a laser light of a

21 specific wavelength that is absorbed only by - Figure 2-15 Atomic Vapor Laser Isotope

22 uranium-235. The laser selectively adds enough Separation Process (Hargrove, 2000)

23 energy to ionize or remove an electron from

24 uranium-235 atoms while leaving the other isotopes unaffected. The ionized uranium-235 atoms are then

25 collected on negatively charged surfaces inside the separator unit. The collected material (enriched

26 product) is condensed as liquid on the charged surfaces and then drains to a caster where it solidifies as

27 metal nuggets. In June 1999, citing budget constraints, USEC stopped further development of the Atomic

28 Vapor Laser Isotope Separation program (USEC, 1999).

29

30 The Separation of Isotopes by Laser Excitation technology, developed by Silex Systems Ltd., uses a

31 similar process to the Atomic Vapor Laser Isotope Separation process; The Separation of Isotopes by

32 Laser Excitation process uses UF6 vapor that passes through a tuned laser and an electromagnetic field to

33 separate the isotopes of UF6. The process is still under development and will not be ready for field trials

34 for several years. USEC ended its support of the Separation of Isotopes by Laser Excitation program on

35 April 30,2003, in favor-of the proposed American Centrifuge Plant (USEC,'2003).

36

37 Because neither the Atomic Vapor Isotope Separation process nor the Separation of Isotopes by Laser

38 - Excitation process is ready for commercial production of low-enriched uranium, these processes have been

39 -eliminated from further consideration.

40

41 Conclusion

42

43 The NRC considered the feasibility of utilizing alternative methods for producing low-enriched uranium.

44 Gaseous diffusion and liquid thermal diffusion technology would be far more costly then the centrifuge

45 technology proposed. The other technologies reviewed: the electromagnetic isotope separation jirocess;

46 and the laser separation technology, have not been sufficiently developed for commercial application.

47 Accordingly, these technologies were not considered reasonable alternatives.

2-47
llILLJ

1 2.3.6 Depleted UF6 Management Alternatives

2

3 DOE has evaluated the potential impacts of various disposition options in its "Final Programmatic 4 Environmental Impact Statement for Alternative Strategies for the Long-Term Management and Use of

5 Depleted Uranium Hexafluoride" (DOE, 1999). These include (1) storage as depleted U16 for up to 40

6 years, (2) long-term storage as depleted U30., (3) use of depleted U303, and (4) use of uranium metal. The

7 Programmatic EIS also evaluated the potential environmental impacts of disposal in shallow earthen

8 structures, below-grade vaults, and underground mines.

9

10 For the proposed ACP, NRC considered as reasonable alternatives for depleted UF6 disposition the

11 (1) onsite storage in anticipation of future use as a resource, and (2) conversion at facilities other than the

12 new facility that DOE is now building at Piketon. These alternatives and the reasons they are not

13 evaluated in detail in this Draft EIS are presented in the following subsections.

14

15 Use of Depleted UF_

16

17 DOE has evaluated a number of alternatives and potentially beneficial uses for depleted UF6, and some of

18 these applications have the potential to use a portion of the existing depleted UP6 inventory (DOE, 1999;.

19 Brown et al., 1997). However, the current depleted UF6 consumption rate is low compared to the depleted 20 UF6 inventory (DOE, 1999b), and the NRC has assumed that excess DOE and commercial inventory of

21 depleted UF6 would be disposed of as a waste product (NRC, 1995).

22

23 The NRC staff has determined that unless USEC can demonstrate a use for uranium in the depleted tails as

24 a potential resource, the depleted UF6 generated by the proposed ACP should be considered a waste

25 product. Because the current available inventory of depleted uranium in the form of metal (UF6 and U3O0)

26 is in excess of the current and projected future demand for the material, this Draft EIS will not further

27 evaluate depleted UF6 disposition alternatives involving its use as a resource, including continued storage 28 at the proposed ACP site for more than 30 years in order to be used in the future.

29

30 If storage of depleted UF6 beyond 30 years occurs, then the impacts described in Chapter 4 of this Draft

31 EIS would be extended for that storage period. If a use for depleted UF6 is found, it could reduce the

32 environmental impacts associated with its disposition. However, the likelihood of a significant

33 commercial market for the depleted UP6 generated by the proposed ACP is considered to be low.

34

35 Conversion at Alternate Sites

36

37 Other depleted UF6 management alternatives include conversion at the DOE conversion facility in

38 Paducah, Kentucky, or at an existing fuel fabrication facility. DOE has issued a Final EIS to construct and

39 operate a conversion facility at Paducah (DOE, 2004a; DOE, 2004b). Additionally, DOE has issued its

40 Record of Decision and construction of the Paducah conversion facility began in July 2004 (DOE, 2004c;

41 DOE, 2004d). Since the shipment of the ACP's depleted UF6 to Paducah for treatment offers no

42 environmental advantage over onsite conversion at the Piketon facility, this alternative will not be

43 analyzed further in this Draft EIS.

44

45 Another potential strategy would be to perform the conversion of depleted UF6 to U303 at an existing fuel

46 fabrication facility. The existing fuel fabrication facilities are Global Nuclear Fuel-Americas, LLC, in

47 Wilmington, North Carolina; Westinghouse Electric Company, LLC, in Columbia, South Carolina; and

48 Framatome ANP, Inc., in Richland, Washington. These facilities have existing processes and conversion

49 capacities and also use Type 30B cylinders. Therefore, the existing fuel-fabrication facilities would need

50 to install new equipment to handle the larger Type 48G cylinders. The facilities would probably need to

51 install separate capacity to process the depleted UF6 to avoid quality control issues related to processing

2-48

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enriched UF6. The facilities would also need to manage and dispose of the hydrofluoric acid that would be

generated from the conversion process. Furthermore, these existing facilities have not expressed an

interest in performing these services, and the cost for the services would be difficult to estimate. For these

reasons, this alternative is eliminated from further consideration in this Draft EIS.

2.4 Comparison of Predicted Environmental Impacts

Chapter 4 of this Draft EIS presents a more detailed evaluation of the environmental impacts of the

proposed action and the no-action alternative. Table 2-8 summarizes the environmental impacts for the

proposed and the no-action alternative.

Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative

Affected Proposed Action: - No-Action Alternative:

Environment

USEC would construct, operate, and The proposedACP would not be constructed,

decommisison the proposedACPin Piketon, operated, and decommissioned Enrichment

Ohio. services would continue to be met with

existing domestic and foreign uranium

enrichment suppliers.

Land Use * SMALL. Site preparation and construction * SMALL. Under the no-action alternative, no . activities would occur on approximately 22' local impact would occur because the proposed

hectares (55 acres) of land, which' comprises' * ACP would not be constructed or operated.

about I percent of the total 1,497 hectare ' Existing land use would continue and the

(3,700)-acre DOE reservation. The changes * property would be available for alternative use.

would occur on previously disturbed land that There also would be no land disturbances.

is not considered prime farmland, and would

be consistent with current land use. Existing activities such as enrichment services

from existing uranium enrichment facilities

(including the possible re-opening of the

gaseous diffusion plant at the Piketon site),

from foreign sources, and from the "Megatons

to Megawatts" program would have impacts as

previously analyzed in their respective NEPA

documentation and historical environmental

monitoring.

Additional domestic enrichment facilities could

be constructed in the future and would have

land use impacts similar to those of the

proposed action, depending onsite conditions

either at a new location or an existing industrial

site. Impacts to land use would be expected to

_ be SMALL.

2-49
It I

1

2

3

Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

Affected Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and The proposedACP would not be constructed,

decommisison the proposed A CP in Piketon, operated, and decommissioned. Enrichment

Ohio. services would continue to be met with

existing domestic andforeign uranium

enrichment suppliers.

Historical and 1SMALL. Within and adjacent to the area of . SMALL. Under the no-action alternative, the

Cultural potential effect (the DOE reservation . site would continue to be used for commercial

Resources boundary), there would be no indirect or industrial purposes and historical and cultural

direct effect on the eligible or potentially resources would be unaffected.

eligible sites for the National Register of

Historic Places. Also, construction of new The existing activities such as enrichment

.buildings and refurbishment of existing services from existing uranium enrichment

buildings would result in buildings of design, facilities (including the possible re-opening of

size, and function similar to the existing the gaseous diffusion plant at the Piketon site),

buildings, and therefore would not alter the .from foreign sources, and from the "Megatons

historic setting of the existing Gaseous to Megawatts" program would have impacts as

Diffusion Plant district. Additional previously analyzed in their respective NEPA

disturbance of the site is not anticipated documentation and historical environmental

during decommissioning. Any such changes monitoring.

to buildings or structures would be evaluated

by the appropriate agency for historic and Additional domestic enrichment facilities could

cultural resources impacts prior to any be constructed in the future and could have

implementation. potential impacts to historical and cultural

resources if at a new location. Impacts to

.historical and cultural resources at these other

sites would have to be controlled in accordance

with applicable Federal and State historic

preservation laws and regulations. The impacts

would be expected to be SMALL if built and

operation at an exisiting industrial site. The

. impacts could be SMALL to MODERATE if

additional domestic enrichment facilities were

located at a new site, depending on specific site

conditions.

2-50

I I
Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

2

2

3

Affected - Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and The proposedACP would not he constructed,

decommisison the proposedACP in Piketon, operated, and decommissioned Enrichment

Ohio. services would continue to he met with

existing domestic and foreign uranium

enrichment suppliers.

Visual and SMALL. The Bureau of Land Management SMALL. Under the no-action alternative, the

Scenic . Visual Resources Management rating system visual and scenic resources would remain the

Resources classifies the proposed ACP site as Class III same as described in the affected environment

or IV, meaning it has moderate to little scenic . section.

value. Construction of the ACP would not

- alter the site's classification. No scenic The existing activities such as enrichment

rivers, nature preserves, or unique visual services from existing uranium enrichment

- resources exist in the project area: No facilities (including the possible re-opening of

impacts are expected from decommissioning. the gaseous diffusion plant at the Piketon site),

Any such changes would be evaluated by the from foreign sources, and from the "Megatons

appropriate agency prior to implementation. to Megawatts" program would have impacts as

previously analyzed in their respective NEPA

documentation and historical environmental

monitoring.

Additional domestic enrichment facilities could

be constructed in the future with a possible

impact on visual and scenic resources similar to

that of the proposed action, depending onsite

conditions either at a new location or an

existing industrial site. Impacts to visual and

scenic resources would be expected to be

* SMALL. ~~~~~~~~~~~~~~. ........... ................. __....._ . ... _ _._.._ ............ . _:.... .. . . . _._. ....... _........_......._.._

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Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

Affected Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and TheproposedACP would not be constructed,

decommisison the proposed A CP in Piketon, operated, and decommissioned Enrichment

Ohio. services would continue to be met with

existing domestic andforeign uranium

enrichment suppliers.

Air Quality . SMALL to MODERATE. Airborne . SMALL. Under the no-action alternative, air

emissions from site preparation and quality in the general area would remain at its

construction should not result in exceedances current levels described in the affected

of air quality standards, with the possible environment section.

exception of short-term increases in

particulate matter. Radiological releases The existing activities such as enrichment

from soil disturbances and decommissioning services from existing uranium enrichment

of the Gas Centrifuge Enrichment Plant facilities (including the possible re-opening of

would be small and controlled. Emissions ,the gaseous diffusion plant at the Piketon site),

from diesel generators would not cause air from foreign sources, and from the "Megatons

quality problems and maximum predicted Ito Megawatts" program would have impacts as

concentrations of hydrogen fluoride resulting .previously analyzed in their respective NEPA

from ACP operations are below safe levels. documentation and historical environmental

s Based on the maximum radiological emission Imonitoring.

rates for the ACP and the comprehensive site

monitoring program, the expected impact to Additional domestic enrichment facilities could

I air quality from the plant's radiological be constructed in the future. Depending on the

emissions is also expected to be SMALL. construction methods and design of these

Impacts from decommissioning could result Ifacilities, the likely impact on air quality would

I in the emission of solvents, but in small be similar to that of the proposed action.

amounts and only for a short period of time. Impacts to air quality would be expected to be

SMALL. _ ...... ........... . . _.:.._. .................. . . . _. ......... . . _._... . ...... _._ . ............ . .......... . .

2-52

i I
Table 2-8 Sumnmiary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

2

2

Affected Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and TheproposedACP would not be constructed,

decommisison theproposedACPin Piketon, operated, and decommissioned. Enrichment

Ohio. services would continue to be met with

existing domestic andforeign uranium

enrichment suppliers.

Geology and SMALL. Most of the site is an existing : SMALL. Under the no-action alternative,'

Soils industrial facility with altered natural soils. existing land use would remain intact.- The

The soils are cohesive and over-consolidated 1 geology and soils of the proposed site would

and have low potential for liquefaction. remain unaffected because no land disturbance

There is little likelihood of impact from soil * would occur. Natural events such as wind and

compaction or subsidence. The flat terrain water erosion would remain as the most

where the ACP buildings would be located, significant variable associated with the geology

and the dense soil, low moisture content, and and soils of the site.

vegetative cover in the area of a new large

cylinder storage yard (X-745H), make The existing activities such as enrichment

landslides unlikely. Construction activities services from existing uranium enrichment

would not alter current drainage and would facilities (including the possible re-opening of

not disturb any soils that qualify for the gaseous diffusion plant at the Piketon site),

protection as prime farmland. There would . from foreign sources, and from the "Megatons

be a potential for increased erosion and to Megawatts" program would have impacts as

siltation of streams near the construction site previously analyzed in their respective NEPA

of the new large cylinder storage yard, but documentation and historical environmental

both of these potential impacts should be monitoring.

minimized by the use of standard best

management practices. The potential for soil Additional domestic enrichment facilities could

contamination during operations would be be constructed in the future with a likely impact

- SMALL. Impacts from decommissioning on geology and soils similar to that of the

would not exceed those identified for site, proposed action, depending on site conditions

preparation and construction. Any removal 5 either at a new location or an existing industrial

of contaminated soils would be limited in 5 site. Impacts to geology and soils would be

scope and the impact would be SMALL. 5 expected to be SMALL.

-..... . .. . -. ...... ..... .....-

: l ;-.-.

2-53
ll

Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

Affected Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and The proposed ACP would not be constructed,

decommisison the proposed ACP in Piketon, operated, and decommissioned Enrichment

Ohio. services would continue to be met with

existing domestic and foreign uranium

enrichment suppliers

I Water

2 Resources

SMALL. Potential stream sedimentation from

construction activities would be minimized

by the use of silt fences and other best

management practices. Any impacts to

stream water quality would be of short

duration. None of the proposed site

preparation and construction activities would

occur within a 1 00-year floodplain.

Groundwater withdrawals would increase by

12 percent over current usage rates, but

would still be only 31 percent of the total

design capacity of the site's well fields,

would not affect groundwater availability,

and would not pose an increased risk of

subsidence. Wastewater would continue to

discharge from permitted NPDES outfalls

and would not alter the current water quality

of the discharge. In addition, the water

quality at NPDES outfalls would continue to

be monitored. The additional sanitary waste

water treated at the onsite water treatment

plant would represent up to a 90 percent

increase in the volume of sanitary water

treated at the plant, but would only increase

the total volume up to 75 percent of the

plant's design capacity. The potential for

.leaks or spills that could contaminate water

resources would be limited by (1) the leak

collection system associated with the ACP;

(2) implementation of best management

practices; and (3) an approved Spill

Prevention Control and Countermeasures

.Plan. During decontamination and

decommissioning, smaller ground water

withdrawals needed to support these

activities (compared to withdrawals during

operations), would cause a SMALL impact.

With continued controls in place, the impacts

associated with liquid discharges, and the

likelihood and severity of potential spills

during decontamination and

decommissioning would be minimized and

any resulting impacts should be SMALL.

SMALL. Under the no-action alternative,

water resources would remain the same as

described in the affected environment section.

Water supply and demand would continue at

current rates. The existing flow of stormwaters

on the site would continue, and existing

potential groundwater contamination pathways

would remain the same.

The existing activities such as enrichment

services from existing uranium enrichment

facilities (including the possible re-opening of

the gaseous diffusion plant at the Piketon site),

from foreign sources, and from the "Megatons

to Megawatts" program would have impacts as

previously analyzed in their respective NEPA

documentation and historical environmental

monitoring.

Additional domestic enrichment facilities could

be constructed in the future. Depending on the

construction methods, design, and location of

these facilities, the likely impact on water

resources (including water usage) would be

similar to that of the proposed action. Impacts

to water resources would be expected to be

SMALL.

_. . . ...... ..................__. . ... _... . .. ... ........................ .. ... . ............. ........... . ... . .. . ..... . . . .. . ..... . .. ..... . .... . .. . .....

2-54
Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

Affected Proposed Action: No-Action Alternative:

Environment

-USEC would construct, operate, and The proposedACP would not be constructed,

decommisison the proposed A CP in Piketon, operated, and decommissioned. Enrichment

Ohio. services would continue to be met with

existing domestic andforeign uranium

enrichment suppliers.

I Ecological

2 Resources

SMALL. Construction of the X-745H

Cylinder Storage Yard would result in

increased erosion, stormwater runoff,'and

loss of 25 acres of managed grassland and

old fields, but would not require the removal

of any upland or riparian forests.

Implementation of the best management

practices described in section 4.2.5.1 on soil

impacts together with the fact that the upland

mixed hardwood forest and the riparian forest

adjacent to the managed field and old field.

would not be disturbed would reduce a

potentially moderate impact to a SMALL

impact. Such measures would reduce erosion

and ensure that the existing forested buffer

area between the proposed cylinder storage

.yard and the riparian areas associated with

the tributaries and Little Beaver Creek would

be preserved. Such measures would reduce

*the level and amount of sedimentation and

erosion that would occur in the adjacent

surface waters, and would preserve the

existing forested buffer areas.

The X-745H Cylinder Storage Yard is

*located approximately 500 meters (1,640

.feet) from suitable summertime habitat for

the Indiana bat, although studies have not

documented the presence of the bat on the

DOE reservation. Because the existing

buffer area (upland and riparian forests)

would not be removed and it is only

considered potential summertime habitat, the

* impact would be SMALL.

.Ecological impacts associated with ACP

decommissioning are anticipated to be

bounded by the ecological impacts associated

with ACP site preparation and construction.

SMALL. Under the no-action alternative, the

land use would continue as it is currently, and

the ecological resources would remain the same

as described in the affected environment

section. Land disturbances would also be

avoided.

The existing activities such as enrichment

services from existing uranium enrichment

facilities (including the possible re-opening of

the gaseous diffusion plant at the Piketon site),

from foreign sources, and from the "Megatons

to Megawatts" program would have impacts as

previously analyzed in their respective NEPA

documentation and historical environmental

monitoring.

Additional domestic enrichment facilities could

be constructed in the future and would have

impacts similar to those of the proposed action,

depending on the site conditions either at a new

location or an existing industrial site. Impacts

to ecological resources would be expected to be

SMALL.

-__.....-...__ ._ ... ._..... ._ -...... . _ ..... ....... .. ._ ........... . ...... . . .... _.......__..... . . .. A..... .... _.... .. . ....... . ... . ........ .

2-55
llL] 1.

Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

1

2

Affected Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and The proposedACP would not be constructed,

decommisison the proposedACP in Piketon, operated, and decommissioned. Enrichment

Ohio. services would continue to be met with

existing domestic andforeign uranium

enrichment suppliers.

Socio- SMALL to MODERATE. ACP construction . SMALL to MODERATE. Under the no-action

economics and operation would result in a MODERATE alternative, sociocconomics in the local area

increase in regional employment and a would continue as described in the affected

SMALL increase in regional tax revenues. environment section.

Impacts to population characteristics, housing

resources, community and social services, The existing activities such as enrichment

and public utilities are projected to be services from existing uranium enrichment

SMALL. facilities (including the possible re-opening of

the gaseous diffusion plant at the Piketon site),

Decontamination and decommissioning of from foreign sources, and from the "Megatons

1the proposed ACP also would generally have to Megawatts" program would have impacts as

SMALL impacts. An average of 841 direct previously analyzed in their respective NEPA

and indirect jobs are expected to be created. documentation and historical environmental

State income tax, State sales tax, and county- * monitoring.

level tax revenues would significantly

increase as a result of decontamination and Additional domestic enrichment facilities could

decommissioning. Likewise, be constructed in the future. Depending on the

decontamination and decommissioning construction methods, design of the facilities,

activities are not expected to lead to housing and local demographics, the likely

shortages or increases in rental rates in the socioeconomic impact would be similar to that

region. The small influx of workers would of the proposed action. Socioeconomic impacts

also have a small effect on public utilities, would be expected to be SMALL to

fire, law enforcement, healthcare, and MODERATE. Long-term uncertainty in future

administrative levels of service. supplies of low-enriched uranium could be

affected without replacement enrichment

capacity for the existing U.S. enrichment

facility or from the potential ending of the

.'Megaton to Megawatts" program in 2013. . .. ._........_. .... ........ _. . . ....... . .. .. ....... . . . ..... . . __....... . ._ .......... .....

2-56
- -

1

2

Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

Affected Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and The proposed ACP would not be constructed,

decommisison the proposedACP in Piketon, operated, and decommissioned. Enrichment

Ohio. services would continue to be met with

existing domestic and foreign uranium

enrichment suppliers.

Environmental *. SMALL. Within an 80-kilometer (50-mile) ' SMALL. Under the no-action alternative, no

Justice radius around the proposed ACP site, there changes would occur to environmental justice

are 18 Census tracts that have populations issues, other than those that already may exist

qualifying as low-income and two Census in the community. No disproportionately high

tracts that have populations qualifying as and adverse impacts would be expected.

minority. The closest of these tracts is 28

kilometers (17 miles) from the proposed site. The existing activities such as enrichment

The proposed action would not result in services from existing uranium enrichment

disproportionately high and adverse impacts facilities (including the possible re-opening of

to any of these populations. the gaseous diffusion plant at the Piketon site),

from foreign sources, and from the "Megatons

2 to Megawatts" program would have impacts as

previously analyzed in their respective NEPA

documentation and historical environmental

monitoring.-

Additional domestic enrichment facilities could

be constructed in the future, and environmental

justice concerns would need to be evaluated on

a site-specific basis. The impacts could be

similar to those of the proposed action if the

location has a similar population distribution or

is located at a similar industrial site.

Environmental justice impacts would be

expected to be SMALL under most likely

circumstances. ........ . . .... . ..... . _.. __._ ........... . ......... . .... .__ .... .. ............ . .. . . _. ......... . .. _._ ........ . .__.......

2-57
III n

Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

I

Affected Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and TheproposedACP would not be constructed,

decommisison theproposedA CP in Piketon, operated, and decommissioned Enrichment

Ohio. services would continue to be met with

existing domestic andforeign uranium

enrichment suppliers.

Noise SMALL. Estimated construction noise levels SMALL. Under the no-action alternative, there

at the site are below acceptable guidelines. would be no construction or operational

No adverse noise impacts from ACP activities or processes that would generate

operations are expected at the closest noise. Noise levels would remain as is

residence due to low operational noise, the 1 currently observed at the site.

attenuation provided by the building faiade,

and distance attenuation of over 900 meters The existing activities such as enrichment

(3,000 feet). services from existing uranium enrichment

facilities (including the possible re-opening of

I Noise during decommissioning would be the gaseous diffusion plant at the Piketon site),

generated from operation of heavy from foreign sources, and from the 'Megatons

construction equipment and vehicles needed to Megawatts" program would have impacts as

to move equipment, scrap metal, and waste. previously analyzed in their respective NEPA

These noise levels are anticipated to be documentation and historical environmental

similar to those generated during construction . monitoring.

of the proposed ACP. These noise level is

within acceptable guidelines and would cause Additional domestic enrichment facilities could

a SMALL impact. 1 be constructed in the future. Depending on the

construction methods, design of these facilities,

and surrounding land uses, the likely noise

impact would be similar to that of the proposed

action. Noise impacts would be expected to be

SMALL. ....................... ..... . ........... ........ ......... ... . .. . .... . .... .. . _. _:......... . .... . _........ . _.........

2-58
I

Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

Affected Proposed Action: No-Action Alternative:'

Environment

USEC would construct, operate, and The proposedACP would not be constructed,

decommisison the proposed A CP in Piketon, operated, and decommissioned. Enrichment

Ohio. services would continue to be met with

existing domestic andforeign uranium

- enrichment suppliers.

Transportation * SMALL to MODERATE. Increased truck - SMALL to MODERATE. Under the no-action

* and vehicle traffic should result in SMALL alternative, traffic volumes and patterns would

changes in current levels of congestion and remain as described in the affected environment

delays on U.S. Route 23 and Ohio State Road . section. The current volume of radioactive

32, and MODERATE increases in the material and chemical shipments would not

number of traffic accidents resulting in increase.

. injuries or fatalities. Radiation exposures

resulting from the planned shipments of The existing activities such as enrichment

radioactive materials are estimated to cause services from existing uranium enrichment

0.02 o latent cancer fatalities per year of facilities (including the possible re-opening of

operation or about one cancer fatality over the gaseous diffusion plant at the Piketon site),

thirty years of operation. The probability of a from foreign sources, and from the "Megatons

severe transportation accident that releases to Megawatts" program would have impacts as

sufficient quantities of UF6 that could pose a previously analyzed in their respective NEPA

1 health risk is low, but that the consequences documentation and historical environmental

of such an accident, should it occur, are high monitoring.

(resulting in an overall MODERATE rating).

Impacts associated with decommissioning Additional domestic enrichment facilities could

I should be far less than that for site 1 be constructed in the future, with a likely

preparation and construction. 1 impact on transportation similar to that of the

proposed action, depending on site conditions

at either a new location or an existing industrial

' ' facility. Impacts to transportation would be

I expected to be SMALL to MODERATE. . . . ......... . ...................... .. . ......

2-59
ali

1

2

3

Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

Affected Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and The proposed ACP would not be constructed,

decommisison the proposed A CP in Piketon, operated, and decommissioned. Enrichment

Ohio. services would continue to be met with

existing domestic andforeign uranium

enrichment suppliers.

Public and SMALL. Occupational injuries and illnesses SMALL to MODERATE. Under the no-action

Occupational associated with the proposed site preparation alternative, the public and occupational health

Health and construction are estimated to be 11.7 would remain as described in the affected

incidents per 100,000 full-time equivalents environment section. No additional

(the number of workers per year) and 0.59 radiological exposures are estimated to the

fatalities. The total maximum possible dose general public other than from background

to construction workers is approximately 0.22 radiation levels.

millisieverts per year (22 millirem), which is

less than the 10 CFR Part 20 regulatory limit The existing activities such as enrichment

of I millisievert (100 millirem). services from existing uranium enrichment

facilities (including the possible re-opening of

Airborne emissions of uranium from the the gaseous diffusion plant at the Piketon site),

proposed ACP are predicted to cause from foreign sources, and from the "Megatons

radiation doses to the public and airborne to Megawatts" program would have impacts as

concentrations of uranium that are well below I previously analyzed in their respective NEPA

applicable National Emission Standards for documentation and historical environmental

Hazardous Air Pollutants standards. Impacts monitoring.

from direct gamma radiation exposure above

the background to a member of the public are Additional domestic enrichment facilities could

expected to be SMALL, approximately 1 be constructed in the future. Depending on the

milliRoentgen per year. construction methods and design of these

facilities, the likely public and occupational

Occupational injuries and illnesses associated . health impacts from normal operations and

with the proposed facility operation are accidents would be similar to the proposed

estimated to be 2.5 incidents per 100,000 . action. Public and occupational health impacts

full-time equivalents (the number of workers for additional domestic enrichment facilities

per year) and 0.41 fatalities. The uranium would be expected to be SMALL to

concentration in workplace air is estimated to MODERATE.

be approximately 0.7 milligram per cubic

meter, which is less than the National

Institute of Occupational Safety and Health

standard. Occupational radiation exposure is

expected to meet USEC's annual

administrative limit of 10 millisieverts (1,000

millirem), which is well below the 10 CFR

Part 20.1201 limit of 50 millisieverts (5,000

8 millirem). ._ ........ _._._ . .......... ........... ..................... . .. . . ... . ... _ ............ . ...... . .. . .. _ ..... . ... . __.__._.._...

2-60
Table 2-8 Summary of Environmental Impacts for the Proposed ACP

and the No-Action Alternative (continued)

Affected Proposed Action: No-Action Alternative:

Environment

USEC would construct, operate, and The proposedACP would not be constructed,

decommisison the proposed A CP in Piketon, operated, and decommissioned. Enrichment

Ohio. - services would continue to be met with

existing domestic and foreign uranium

enrichment suppliers.

Waste SMALL. Site preparation, construction, and SMALL. Under the no-action alternative, new

Management operations would generate varying amounts . wastes including sanitary, hazardous, low-level

of low-level radioactive, low-level mixed,' radioactive wastes, or mixed wastes would not

. hazardous, sanitary/industrial, and recyclable be generated that would require disposition.

wastes All of these wastes would be - Local impacts from waste management would

managed in accordance with existing be expected to remain SMALL.

procedures for controlling contaminant

releases and exposures. With the exception 1 The existing activities such as enrichment

of the depleted uranium, all of the wastes services from existing uranium enrichment

would also be generated at volumes that are facilities (including the possible re-opening of

well within existing management capacities. the gaseous diffusion plant at the Piketon site),

Over its 30-year lifetime, the ACP would from foreign sources, and from the "Megatons

: generate approximately 42,800 cylinders of . to Megawatts" program would have impacts as

depleted UF6, containing approximately previously analyzed in their respective NEPA

571,000 metric tons (630,000 tons) of documentation and historical environmental

material. All of this UF6 could be converted * monitoring.

to a more stable form at the new DOE

conversion facility at Piketon, which would * Additional domestic enrichment facilities could

require DOE to significantly extend the life be constructed in the future. Depending on the

of this facility. The converted material would construction methods, design of these facilities,

then be shipped by rail to an acceptable and the status of depleted UF6 conversion

western disposal site, where sufficient facilities, the likely waste management impacts

capacity exists and where the disposal would be similar to that of the proposed action.

impacts should be SMALL. For additional domestic enrichment facilities,

* impacts from waste management would be

expected to be SMALL to MODERATE. __...__:__ .............. ____................ _._._. .__.__... .___......__..._.......ae@_....

2.5 Staff Preliminary Recommendation Regarding the Proposed Action

7 After weighing the impacts of the proposed action and comparing alternatives, the NRC staff, in

8 accordance with 10 CFR § 51.71(e), sets forth its NEPA recommendation regarding the proposed action.

9 The NRC staff recommends that, unless safety issues mandate otherwise, the proposed license be issued to

10 USEC. In this regard, the NRC staff has 'concluded that environmental impacts are generally small, aind

11 taken in combination with the applicable envirdiimental monitoring program described in Chapter 6 and

12 the proposed mitigation measures discussed in Chapter 5, would eliminate or substantially lessen any

13 potential adverse environiental irmpacis associated with the proposed action.

14

15 The NRC staff has concluded the overall benefits of the proposed ACP outweigh the environmental

16 disadvantages and costs based on consideration of the following:

2-61
AlL11

1 * The need for an additional, reliable, economical, domestic source of enrichment services; and

2

3 * The environmental impacts from the proposed action are generally SMALL, although they could be as

4 high as MODERATE in the areas of air quality, socioeconomics, and transportation.

5

6 2.6 References

7

8 (ANSI, 1990) American National Standards Institute. (ANSI) N14. 1, "Uranium Hexafluoride-Packaging

9 for Transport ANSI N14.1 Standard for Packaging of Uranium Hexafluoride for Transport," 1971, 1982,

10 1987, and 1990 Editions. 49 CFR 171.7; 173.417; 173.420. 1990.

11

12 (Brown et al., 1997) Brown, C., et al. "Beneficial Uses of Depleted Uranium." Beneficial Re-Use

13 Conference, Knoxville, Tennessee, August 5-7,1997.

14

15 (DOE, 1995) U.S. Department of Energy. "Electricity Generation and Environmental Externalities: Case

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18

19 (DOE, 1999) U.S. Department of Energy. "Final Programnmatic Environmental Impact Statement for

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22 April 1999.

23

24 (DOE, 2000) U.S. Department of Energy. "Report to Congress on Maintenance of Viable Domestic

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26

27 (DOE, 2001) U.S. Department of Energy. "Environmental Assessment for the Reindustrialization

28 Program at the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOE/EA-1346, Oak Ridge

29 Operations Office, U.S. Department of Energy. May 2001

30

31 (DOE, 2003) U.S. Department of Energy. "Cold Standby Program at the Portsmouth Gaseous Diffusion

32 Plant." DOE-0634. Audit Report. Office of Inspector General, Office of Audit Services. December 2003.

33

34 (DOE, 2004a) U.S. Department of Energy. "Final Environmental Impact Statement for Construction and

35 Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky Site." DOE

36 EIS-0359. Office of Environmental Management. June 2004.

37

38 (DOE, 2004b) U.S. Department of Energy. "Final Environmental Impact Statement for Construction and

39 Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio, Site." DOE

40 EIS-0360. Office of Environmental Management. June 2004.

41

42 (DOE, 2004c) U.S. Department of Energy. "Record of Decision for Construction and Operation of a

43 Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio, Site." July 20, 2004.

44

45 (DOE, 2004d) U.S. Department of Energy. "Record of Decision for Construction and Operation of a

46 Depleted Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky, Site." July 20, 2004.

47

48 (EIA, 2004) Energy Information Administration. "Uranium Marketing Annual Report." U.S. Department

49 of Energy. (Released May 28, 2004; last modified June 30, 2004). <http://www.eia.doe.gov/

50 cneaf/nuclear/umar/umar.html> (Accessed 7/11/04).

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1 (FAS, 2000) Federation of American Scientists. "Uranium Production." June 24, 2000.

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3

4 (Green, 2003) Green, Ron. "Back to the Future: American Centrifuge." Nuclear Engineering

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7

8 (Hargrove, 2000) Hargrove, Steven. "Laser Technology Follows in Lawrence's Footsteps." Science and

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11

12 (Heilbron et al., 1981) Heilbron, et al. "Lawrence and His Laboratory-A Historian's View of History."

13 June 1981.

14

15 (Milani, 2005) Milani, Kevin. "The Scientific History of the Atomic Bomb." Hibbing Community

16 College. -<http://www.hibbing.tec.mn.us/programs/dept/chem/abomb/index.html> (Accessed 4/7/2005).

17

18 (NRC, 1991) U.S. Nuclear Regulatory Commission. Policy Issue. "Disposition of Depleted Uranium

19 Tails from Enrichment Plant." SECY-91-019. January 25, 1991.

20

21 (NRC, 1995) U.S. Nuclear Regulatory Commission. Letter from Robert M. Bernero, Director, Office of

22 Nuclear Materials Safety and Safeguards (NMSS), to Charles E. Bradley, DOE Office of Uranium

23 Programs, Office of Nuclear Energy. January 3, 1995.

24

25 (NRC, 2003) U.S. Nuclear Regulatory Commission. NUREG-1 757, "Consolidated NMSS

26 Decommissioning Guidance, Volume 3, Financial Assurance, Recordkeeping, and Timelines." September

27 2003.

28

29 (NRC, 2004) U.S. Nuclear Regulatory Commission. "Environmental Assessment of the USEC, Inc.

30 American Centrifuge Lead Cascade Facility at Piketon, Ohio." January 2004.

31

32 (NRC, 2005) U.S. Nuclear Regulatory Commission. "Memorandum and Order." CLI-05-05. NRC

33 Docket No. 70-3103. January 18, 2005.

34

35 (Settle, 2004) Settle, F. "Nuclear Chemistry, Uranium Enrichment." Kennesaw State University.

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37

38 (Urenco, 2003) The Urenco Group. "Uranium Enrichment" Brochure. June 2003.

39 <http://www.urenco.com/im/uploaded/1086887106.pdfP (Accessed 5/4/2005)

40

41 (Urenco, 2004) The Urenco Group. "National Enrichment Facility Overview and Update." April 1, 2004.

42 <http://www.urenco.com/nim/uploaded/11 09246264.pdfP (Accessed 5/4/2005).

43

44 (Urenco, 2005) The Urenco Group. "The Enrichment Process." <http://www.urenco.com/index.php?id=

45 192&cid=263&gcid=275&pagename=The+Enrichment+Process> (Accessed 5/4105).

46

47 (USEC, 1999) United States Enrichment Corporation. "USEC Inc. Suspends AVLIS Technology

48 Development." News Release. June 9, 1999. <http://www.usec.com/v2001_02/Content/News/

49 NewsTemplate.asp?page=/v200 1_02/ContentlNews/NewsFiles/06-09-99b.htm> (Accessed 4/7/2005).

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aL

1 (USEC, 2000) United States Enrichment Corporation. "USEC to Cease Uranium Enrichment at the

2 Portsmouth, Ohio, Facility in June 2001." News Release. June 21, 2000. <http://www.usec.comn/

3 v2001 02/Content/News/NewsTemplate.asp?page=/v2001_02/Content/News/NewsFiles/06-2I -0O.htm>

4 (Accessed 4/7/2005).

5

6 (USEC, 2001) United States Enrichment Corporation. "What's a SWU?" <http://www.usec.coml

7 v2001_02/html/Aboutuse swu.asp> (Accessed 6/15/2005)

8

9 (USEC, 2003) United States Enrichment Corporation. "USEC Ends Funding of Research on SILEX

10 Process." News Release. April 30, 2003. <http://www.usec.com/v2001_02lContent/News/

11 NewsTemplate.asp?page=/v2001_02/Content/News/NewsFiles/04-30-03.htm> (Accessed 4/7/2005).

12

13 (USEC, 2004) United States Enrichment Corporation. "License Application for the American Centrifuge

14 Plant in Piketon, Ohio." NRC Docket No. 70-2004. August 2004.

15

16 (USEC, 2005a) United States Enrichment Corporation. "Decommissioning Funding Plan for the American

17 Centrifuge Plant in Piketon, Ohio." Revision 1. NRC Docket No. 70-2004, NR-3605-0006. March 2005.

18

19 (USEC, 2005b) United States Enrichment Corporation. "Environmental Report for the American

20 Centrifuge Plant in Piketon, Ohio." NRC Docket No. 70-2004. Revision 3. July 2005.

21

22 (USEC, 2005c) United States Enrichment Corporation. "Responses to Request for Additional Information

23 on the Environmental Report, AET-05-0010." March 25, 2005.

24

25 (USEC, 2005d) United States Enrichment Corporation. "Responses to Request for Additional Information

26 on the Environmental Report, AET-05-0013." April 15, 2005.

27

28 (WNA, 2003) World Nuclear Association. "Uranium Enrichment." June 2003. <http://www.world29 nuclear.org/info/inf28.htm> (Accessed 4/7/2005).

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1 3. AFFECTED ENVIRONMENT

2

3 This chapter describes the existing conditions at and near the proposed American Centrifuge Plant (ACP)

4 site in Piketon, Ohio (see Figure 3-1). After an initial overview of the site location and activities, the

5 chapter presents information on surrounding land use; historic and cultural resources; visual and scenic

6 resources; climatology, meteorology, and air quality; geology, minerals, and soils; water resources;

7 ecological resources; socioeconomic conditions; environmental justice considerations; noise levels;

8 transportation systems; public and occupational health conditions; and current waste generation and

9 management practices. This information forms the basis for assessing the potential impacts (see

10 Chapter 4) of the proposed action (see Chapter 2).

11

12 3.1 Site Location and Description

13

14 The proposed ACP would be located within the confines of the U.S. Department of Energy (DOE)

15 reservation in Pike County, Ohio, as described in Section 2.1.1. The DOE reservation is approximately

16 35 kilometers (22 miles) north of the Kentucky/Ohio State line and 113 kilometers (70 miles) southeast of

17 Columbus, Ohio. The largest cities within an' approximately 80-kilometers (50-rile) radius are

18 Portsmouth, Ohio, located approximately 43 kilometers (27 miles) to the south; and Chillicothe, Ohio,

19 located approximately 43 kilometers (27 miles) to the north. The reservation occupies approximately 304

20 security-fenced hectares (750 acres) and is located about 2.4 kilometers (1.5 miles) east of U.S. Route 23,

21 3.2 kilometers (2 miles) south of Ohio State Road 32, and 3.2 kilometers (2 miles) east of the Scioto

22 River.

23

24 Within the DOE reservation, the Portsmouth Gaseous Diffusion Plant occupies approximately 223

25 hectares (550 acres) of the central area surrounded by the Perimeter Road, as described in Section 2.1.1.

26 This plant began operations in the mid-I 950s using gaseous diffusion technology to produce enriched

27 uranium for government and commercial use. In the late 1970s, DOE selected the plant as the site for a

28 new enrichment facility using gas centrifuge technology. Construction of this facility, called the Gas

29 Centrifuge Enrichment Plant, began in 1979, but was halted in 1985 because the projected demand for

30 enriched uranium decreased. In 1991, DOE suspended the production of highly enriched uranium at the

31 Portsmouth plant, but continued to produce low-enriched uranium for use by commercial nuclear power

32 plants. (USEC, 2005)

33

34 In accordance with the Energy Policy Act of 1992,'the United States Enrichment Corporation, a subsidiary

35 of USEC Inc. (USEC), assumed full responsibility for uranium enrichment operations at the Portsmouth

36 Gaseous Diffusion Plant on July 1, 1993. Since that time, DOE has leased the uranium enrichment

37 production and operations facilities to the United States Enrichment Corporation, while retaining certain

38 responsibilities for decontamination and decommissioning, waste management, depleted uranium

39 hexafluoride (UF6) storage, and environmental remediation. In May 2001, the United States Enrichment

40 Corporation ceased uranium enrichment operations at the Portsmouth plant and consolidated its i

41 enrichment operations at the Paducah Gaseous Diffusion Plant in Paducah, Kentucky. The United States

42 Enrichment Corporation continued to operate its transfer and shipping activities at the DOE reservation

43 until July 2002 in support of its enrichment business. At the request of DOE, the gaseous diffusion plant

44 was placed in cold standby, a nonoperational condition in which the plant retains the ability to resume

45 operations within 18 to 24 months. Currently, in accordance with a U.S. Nuclear Regulatory Commission

46 (NRC) Certificate of Compliance, the United States Enrichment Corporation maintains the gaseous

47 diffusion plant in cold standby status, performs uranium deposit removal activities in the cascade

48 facilities;and removes technetium-99 from potentially contaminated uranium feed (USEC, 2005) from

49 fuel reprocessing plants transferred to the United States Enrichment Corporation by DOE prior to

50 privatization.

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EJ State Boundary

L i] County Boundary

0 10 20 30 40 Kilomtefs

0 10 20 30 40 MNhs

Figure 3-1 Proposed ACP Site and Surrounding Areas

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I The proposed ACP would be situated on approximately 81 hectares (200 acres) of the southwest quadrant

2 of the controlled access area. In addition to this space, two UF6 cylinder storage yards (the existing X3 745G-2 and proposed X-745H), occupying a total of 11 hectares (27 acres), would be located in the

4 northeast part of the DOE reservation just north of the Perimeter Road. The proposed ACP would consist

5 of refurbished existing buildings and land formerly used for the Gas Centrifuge Enrichment Plant, as well

6 as newly constructed facilities in that same area. This is the same location as the Lead Cascade

7 Demonstration Facility, a test and demonstration facility designed to provide information on the

8 reliability, performance, and cost of the gas centrifuge technology that will be used in the proposed ACP.

9 In accordance with an NRC license issued to USEC on February 24, 2004, the Lead Cascade

10 Demonstration Facility is presently under construction and scheduled to begin operation in late 2005.

11--

12 The DOE reservation is not listed on the Comprehensive Environmental Response, Compensation, and

13 LiabilityAct National Priorities List (also known as the Superfund List). Investigation and cleanup of

14 hazardous substances (as defined in the Comprehensive Environmental Response, Compensation, and

15 LiabilityAct) and hazardous wastes (as defined in the Resource Conservation andRecoveryAct) that have

16 been released to air, surface water, groundwater, soils, and solid waste management units as a result of

17 past operational activities at the DOE reservation are being conducted under the provisions of the

18 Resource Conservation and RecoveryAct; the Comprehensive Environmental Response, Compensation,

19 and Liability Act; and/or Ohio State law. The United States Enrichment Corporation maintains permits

20 for the storage, handling, and use of hazardous materials and effluent discharges (air and water), as

21 described in Section 1.5.4.

22

23 3.2 Land Use

24

25 The DOE reservation is located in Scioto Township of Pike County in south central Ohio. The region is

26 characterized by steep to gently rolling hills in the general range of 130 to 250 meters (427 to 820 feet)

27 above the Scioto River valley. Pike County is one of the State's lesser populated counties, with a

28 population density of 24 people per square kilometer (63 people per square mile). Towns in the vicinity

29 of the reservation include Piketon (6.4 kilometers [4 miles] north), Waverly (13 kilometers [8 miles]

30 north), Jasper (1.9 kilometers [1.2 miles] northwest), and Wakefield (13 kilometers [8 miles] south).

31 Brush Creek State Forest (8 kilometers [5 miles] southwest) and Lake White State Park (9.7 kilometers [6

32 miles] north) are two public recreational areas located in the vicinity 'of the reservation.

33

34 The general land use adjacent to the DOE reservation includes residential homes, private and commnercial

35 farms, light industry, and transportation corridors (rail and highway). Figure 3-2 presents a general land

36 use map for the area surrounding and including the DOE reservation. :Land within 8 kild eiers'(5 miles)

37 of the reservation is used primarily for farms, pastures, forests, and rural residences. Dominant land use

38 within an 8-kilometer (5-mile) radius includes about 10,291 hectares (25,430 acres) of farmland

39 (including cropland, wooded lot, and pasture) and 9,874 hectares (24,400 acres) of forest (including

40 commercial woodlands and recreational forest) (USEC, 2005).-There are no State or national parks,

41 conservation areas, or designated wild and scenic rivers within the immediate vicinity of the reservation

42 (DOE, 2001a). Greater regional land use in the counties surrounding the DOE reservation is depicted in

43 Table 3-1.

44

45 Farmland that qualifies for protection'under the Farmland Protection and PolicyAct of 1981 (prime

46 farmland) is located in Pike County, primarily along the floodplain of the Scioto River. Marginal quality

47 farmland is located within and adjacent to the DOE eiseivation, aind does not quialify as prirne farhiland

48 under the Farmland Protection and PolicyAct of 1981 (Borchelt, 2003; and Yost, 2005). The Soil

49 Survey for Pike County, Ohio indicates that the soil within and adjacent to the reservation is of low

50 fertility and does not qualify as prime farmland (USDA, 1990).

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Figure 3-2 Land Use Surrounding the DOE Reservation at Piketon

Table 3-1 Percentage of Different Land Uses in the Region of Influence in 2000

County Total Hectares' Urban % Agriculture % Wood % Other % b

Jackson 109,126 2 32 60 6 A_. ....... _... .. .~_......... . _...... _ .. _.......,... ;_... . _... -...... ...

Pike 114,917 I 27 66 6 ._.. ^_......... _;....... ......... . ..... ; _..... - --------- ..... . ;_. _........... . A.....--_.---.------ . ....

Ross 179,348 .I * 48 45 6

Scioto 159,755 . 2 21 72 _.__

Notes:

'To convert hectares to acres multiply by 2.471.

b Other Watcr/barren/scrub.

Source: ODOD, 2003.

34
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A: -:j

I The DOE reservation is situated on an approximately 1,497-hectare (3,700-acre) parcel of DOE-owned

2 land in Scioto Township. Perimeter Road surrounds a 526-hectare (1,300-acre) central area, which

3 includes a 320-hectare (800-acre) fenced area. Approximately 150 buildings, trailers, and sheds are

4 located within the central area, with the gaseous uranium enrichment facilities (now in cold standby) in

5 the fenced area. The central area is largely devoid of trees except for ornamental trees, with managed

6 lawns, parking lots, and paved roadways dominating the open space. The portion of the reservation land

7 outside of the Perimeter Road, consisting of 1,017 hectares (2,514 acres), is used for a variety of purposes

8 including a water treatment plant, holding ponds, sanitary and inert landfills, cylinder storage yards,

9 parking areas, and open fields and forested buffer areas.

10

11 The limited activities that occur on the DOE reservation include the cold standby management of the

12 uranium enrichment facilities, ongoing remediation and waste management activities, the development of

13 the DOE uranium conversion facility (described in the section on Management and Disposal of depleted

14 UF6 from Facility Operation, within Section 2.1.4.3), and general up-keep and security activities. In

15 addition, DOE leases portions of the reservation to the United States Enrichment Corporation and the

16 Ohio National Guard. The United States Enrichment Corporation also maintains office space at the

17 facility. . The Ohio National Guard uses the facility for classroom training/meeting activities and does not

18 store weapons onsite. There are no other military installations located near the DOE reservation at

19 Piketon. Other activities on the reservation that are managed by DOE's contractor, Bechtel Jacobs

20 Company LLC, include environmental remediation, waste management, and management of depleted

21 UF6. (USEC, 2005)

22

23 3.3 Historic and Cultural Resources

24

25 "Cultural resources" include any prehistoric or historic district, site, building, structure, or object resulting

26 from, or modified by, human activity. Under Federal regulation (Title 36 of the Code ofFederal

27 Regulations (36 CFR) Part 800), cultural resources designated as "historic properties" must be considered

28 in assessing impacts of proposed Federal actions. "Historic properties" are cultural resources listed in, or

29 eligible for listing in, the National Register of Historic Places because of their significance, as defined in

30 36 CFR § 60.4:

31

32 The quality ofsignificance in American history, architecture, archeology, engineering, and culture

33 is present in districts, sites, buildings, structures, and objects that possess integrity of location,

34 design, setting, materials, workmanship, feeling, and association, and that (a) are associated with

35 events that have made a signifi cant contribution to the broad patterns ofour history; or (b) that are

36 associated with the lives of persons significant in our past; or (c) that embody the distinctive

37 characteristics of a type, period, or method of construction, or that represent the work of a master,

38 or that possess high artistic values, or that represent a significant distinguishable entity whose

39 components may lack individual distinction; or. (d) that have yielded or may be likely to yield

40 information important in history orprehistory.

41

42 To comply with Federal historic preservation laws and regulations as well as mandates of the National

43 Environmental Policy Act, the NRC is required to identify historic properties in the area potentially

44 affected by its-actions and to consider potential effects on those properties. The principal driver for this

45 process is Section 106 of the National Historic Preservation Act, as amended (16 U.S.C. 470 et seq.), and

46 implementing regulations at 36 CFR Part 800, as amended through August 2004. Under Section 106,

47 Federal agencies are required to consider the effects of their undertakings on historic properties; 36 CFR

48 Part 800 describes the process by which this is done in consultation with the State Historic Preservation

49 Officer. The National Historic Preservation Act and 36 CFR Part 800 also require that consultation in the

50 Section 106 process should provide Indian tribes the opportunity to identify concerns about historic

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I properties on or off Tribal lands, present views about an undertaking's effects on such properties, and

2 participate in the resolution of adverse effects.

3

4 The regulation (36 CFR § 800.16) defines the concept of "area of potential effect:"

5

6 (a Area ofpotential effects means the geographic area or areas within which an undertaking may

7 directly or indirectly cause alterations in the character or use ofhistoric properties, ifany such

8 properties exist. The area of potential effects is influenced by the scale and nature of an

9 undertaking and may be differentfor different kinds of effects caused by the undertaking.

10

II Historic properties could potentially be affected directly or indirectly by construction or operation of the

12 proposed ACP. In accordance with 36 CFR Part 800, NRC defined the area of potential direct effects to

13 include the footprint of all ground-disturbing activities and the perimeter of all buildings to be refurbished

14 plus a 100-meter (328-foot) buffer around all such areas to account for heavy equipment operations,

15 workers, and temporary staging of construction materials adjacent to the proposed work sites. NRC

16 defined the area of potential indirect effects to include all area within the property boundary of the DOE

17 reservation. This conservative area for indirect impacts accounts for potential indirect impacts, such as

18 vandalism of historic properties or alterations of the setting or other qualities that contribute to the

19 significance of historic properties, that could occur beyond the area of construction disturbance.

20

21 As a result of scoping comments that indicated concern that pumping from water supply wells might have

22 an effect on prehistoric earthworks, NRC considered including the supply well locations within the area

23 of potential effects, even though they are not contiguous DOE property. Because there will be no

24 construction activity, increased vehicle traffic, nor subsidence associated with pumping that could directly

25 or indirectly cause alterations in the character or use of prehistoric earthworks that may be located in the

26 vicinity, NRC did not include the well locations within the area of potential effects for historic and

27 cultural resources. Water resource impacts and ground subsidence impacts of pumping from the well

28 locations are considered in Section 4.2.6.

29

30 As a result of scoping comments, NRC evaluated the historic properties (eligible or potentially eligible

31 sites, structures or buildings) that are adjacent to the property boundary of the DOE reservation. NRC

32 considers such properties to be outside of the area of potential effects (direct or indirect), but they were

33 reviewed because they are adjacent to the boundary of indirect effects.

34

35 3.3.1 Historical Setting

36

37 Southern Ohio, where the DOE reservation is located, contains evidence of human presence dating back

38 more than 10,000 years. Archaeologically, the area is best known for the Adena and Hopewell Indian

39 mounds (elaborate geometric earthworks, enclosures, and mounds) that were constructed during the

40 Woodland Period (900 B.C. to A.D. 900) (DOE, 2004a). During the early historic period (A.D. 1500),

41 the Shawnee Indians had villages within the Scioto Valley, in the general area of Portsmouth. There is

42 evidence of European presence in the region around A.D. 1550. European settlement in the region began

43 in the late 1700s, with the first permanent Euro-american settlers arriving in Pike County in 1796

44 (Schweikert, 1997). The early development and economy in the region was almost entirely based on

45 agriculture. The populations in the Portsmouth region grew slowly, with the growth of the transportation

46 routes in the Scioto Valley as the primary impetus. During the 19th and early 20th centuries, several

47 canals, roads, and, finally, railroads were constructed in the Scioto Valley region, and rural development

48 of the area continued.

49

50 Large-scale industrial development began in 1952, when the Atomic Energy Commission, the present day

51 DOE and NRC, selected a 9.3-square kilometer (5.8-square mile) tract of land in the Ohio Valley along

52 the Scioto River in Pike County as the location for the Portsmouth Gaseous Diffusion Plant, to

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1 complement gaseous diffusion facilities at Oak Ridge, Tennessee, and Paducah, Kentucky. Construction

2 of the Portsmouth Gaseous Diffusion Plant began in 1952 and was completed in 1956. During

3 construction, more than 486 hectares (1,200 acres) were cleared and more than 3.44 million cubic meters

4 (4.5 million cubic yards) of earth were removed. The majority of the clearing, grading, and soil removal

5 occurred within the central area of the Portsmouth Gaseous Diffusion Plant within the Perimeter Road

6 (Schweikert, 1997). Since the initial development of the Portsmouth Gaseous Diffusion Plant in the

7 1950s, other construction activities have been initiated on the reservation to include additional

8 administrative offices, warehouses, and the development of the Gas Centrifuge Enrichment Process

9 facilities from 1979 to 1985 in the southwest portion of the reservation.

10

11 3.3.2 Methods

12

13 To identify the cultural resources present in and around the DOE reservation, NRC reviewed existing

14 environmental documentation, including documents prepared under the National Environmental Policy

15 Act, archaeological and architectural studies, and the National Register of Historic Places. The NRC

16 initiated consultation with the State Historic Preservation Officer and with Indian tribes with possible ties

17 to the reservation vicinity.- The NRC also reviewed information about local cultural resources provided

18 by the public. Copies of the consultation letters are provided in Appendix B.

19

20 3.3.3 Results of Document Review

21

22 An initial survey of the DOE reservation was completed in July and August of 1952, before construction

23 of the facility began. The survey, under the supervision of Dr. Raymond S. Baby, Curator of

24 Archaeology, the Ohio State Historical Society, reportedly found no evidence of archaeological materials

25 within the reservation boundary (ERDA, 1977). In 1996, the DOE initiated additional studies, including

26 an architectural survey and an archeological survey (Coleman, 1997; Schweikert, 1997). Figure 3-3

27 shows the four quadrants of the DOE reservation that were investigated as part of these surveys. In 2003,

28 test excavations were conducted at one archaeological site (DuVall & Associates, 2003).

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Figure 3-3 Quadrants Investigated at the DOE Reservation at Piketon

2 As reported by Schweikert (1997), a literature review of the following sources at the Ohio Historical

3 Society and the Genealogy Section of the Pike County Public Library was conducted prior to the

4 archaeological survey: United States Geological Survey 7.5' and 15' series topographic maps, Ohio

5 Historic Preservation Office Archaeological Inventory files, National Register of Historic Places file,

6 Ohio Historical Society Archaeological and Architectural Information files, Ohio Archaeological Council

7 Report files, Pike County maps and histories, and Archaeological Atlas of Ohio (Mills, 1914). In

8 addition, aerial photographs from 1939 and 1951 flights (predating construction of the Portsmouth

9 Gaseous Diffusion Plant) were reviewed. The review focused on an area centered on the reservation,

10 extending out 6.5 kilometers (4 miles) from the center of the reservation.

11

12 The search found no sites within reservation boundaries recorded in the State archaeological inventory, 13 although 71 prehistoric sites were recorded within the study area (an area extending 6.5 kilometers [4 14 miles] from the center of the reservation). Likewise, no buildings within the reservation were listed on

15 the Ohio Historic Inventory. Three buildings were listed within the study area. Of the three, only the

16 Bailey Chapel is directly adjacent to the reservation boundary. The other two, former residences, are

17 located in Seal township north of the reservation. Although not listed in the inventory, 49 other historic

18 structures were observed on maps and photographs.

19

20 Three properties within 6.5 kilometers (4 miles) of the reservation are listed on the National Register of

21 Historic Places. The Piketon Mounds (33 Pk 1), located 3.2 kilometers (2 miles) north of the boundary, 22 consist today of a single large mound and two smaller mounds that are the remnants of a mound complex 23 and series of graded ways that descended from one terrace to another and ran towards the banks of the

24 Scioto River (Squire and Davis, 1848, as referenced in Schweikert, 1997).

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The Scioto Township Works (33 Pk 22) are' located to the southwest of the DOE reservation,

approximately 250 meters (820 feet) from the boundary and approximately 1 kilometer (0.6 mile) from

the Perimeter Road. The Scioto Township Works:

consisted ofa circle andsquare works with gates on the northwestandsoutheastsides, parallel walls

running out from two gateways, and a single mound just north of the works. This complex was

surveyed by Squier and Davis in 1847, and excavations were conducted by the Bureau ofAmerican

Ethnology before 1891. According to Fowke (1902) the square measiured 260.3 meters (854 feet)

perside east to west and 259.6 meters (852fet) per side north to south. The parallel walls were

20.7 meters (68 feet) apart and extended 130 meters (427 feet) for the eastern wall and 122 meters

(400 feet) for the western wall. Even by 1902, the large circle to the north had been all but

obliterated (Fowke 1902). Recentgravel Quarrying and cultivation has destroyed virtually all ofthis

earthworkcomplex. (Schweikert, 1997)

Currently, the Scioto Township Works (33 Pk 22) consists of two separate areas that have been heavily

disturbed adjacent to Route 23 (DuVall & Associates, 2003).

The Van Meter Stone House and Outbuildings, located at a road intersection approximately 3.2

kilometers (2 miles) north of the boundary, dates from the early 1800s, is associated with one of the early

farming families in the county, and includes-what is thought to be the first school in the county

(Schweikert, 1997).

An intensive archaeological reconnaissance was performed in September 1996, April 1997, and May

1997 on the entire DOE reservation, with the exception of areas occupied by plant-related buildings or

structures, sanitary landfills, or lagoons. The archaeologist noted that buildings represented a small

percentage of the overall reservation area outside of the Perimeter Road, although the Don Marquis' power

station and sanitary landfills and sludge lagoons outside the Perimeter Road were relatively large areas

that were not surveyed because the original ground surface was not accessible. Techniques included

overall visual inspection, with some surface collection and shallow shovel probes (to 12.5 centimeters [5

inches]) or tests (to 30 centimeters [12 inches]). (Schweikert, 1997)

The surveys resulted in the identification of 36 previously undocumented archaeological sites within the

boundary of theDOE reservation. These were recorded in the Ohio Archaeological Inventory as sites 33

Pk 184 through 33 Pk 219. The 36 sites included 13 remnants of historic farmsteads; seven historic

scatters or open refuse dumps; two historic isolated finds; four DOE reservation plant-related structural

remnants; one historic cemetery; five prehistoric isolated finds, two prehistoric lithic scatters; ahd two

sites that contained both prehistoric and historic temporal components: an historic cemetery with a

prehistoric isolated find, and a prehistoric lithic scatter on a historic farmstead.

-Investigators determined that 22 of the sites did not meet National Register eligibility criteria, although

the two historic cemeteries within this class were recommended for preservation. One prehistoric lithic

scatter (33 Pk 210) and 13 historic farmsteads were found to be potentially eligible for listing on the

National Register under Criterion D, "have yielded, or may be likely to yield information important in

prehistory or history." All of these sites are located outside the Perimeter Road.

In response to a request after State Historic Preservation Officer review of the 1997 survey report, DOE

conducted archaeological testing at the prehistoric lithic scatter, 33 Pk 210. Results indicated that the site

-is not Register-eligible (DuVall & Associates, 2003; DOE, 2003a), although there is no record of State

Historic Preservation Officer concurrence with this finding.

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Coleman's 1997 architectural survey report states that the State Historic Preservation Officer indicated in

1994 that the Portsmouth Gaseous Diffusion Plant was eligible for inclusion on the National Register as a

historic district because of its association with important events in history, even though it had achieved

significance within fewer than 50 years (OHPO, 1994). (Normally, historic properties must be more than

50 years old.) In 1995, the State Historic Preservation Officer added the clarification that the district was

eligible because of its exceptional significance in the history of post-World War II U.S., in particular, in

U.S. development of nuclear energy (OHPO, 1995). In 1996, DOE initiated an architectural survey of all

the architectural locations (buildings and structures) on the reservation to evaluate which might be

contributing elements to the historic district. Coleman's survey identified a total of 160 architectural

locations that were identified and documented on Ohio Historic Inventory forms.

Coleman evaluated each architectural location against its place in historic periods and thematic groups

that characterize the historic district. Historic periods include the following: (1) the period prior to the

construction of the DOE reservation; (2) the original reservation period; (3) the DOE reservation facility

additions period; and (4) the Gas Centrifuge Enrichment Process period. Five thematic groups were

identified: gaseous diffusion process, portals for the gaseous diffusion facility, cooling structures,

warehouses, and facilities owned by the Ohio Valley Electric Corporation. This information was used to

define the contributing and non-contributing architectural resources of the Portsmouth Gaseous Diffusion

Plant historic district. Of the 160 architectural locations, 132 were recommended as contributing

resources of the historic district and 28 were recommended as non-contributing resources. All of the

structures associated with the Gas Centrifuge Enrichment Process facility, (the buildings to be refurbished

under the proposed action) were found to be contributing resources of the historic district. The cylinder

storage yards (some of which would be refurbished under the proposed action) were not included in the

survey because such features do not contain architectural elements that warranted recording (Coleman,

1997).

3.3.4 Information from the Interested Public

The Barnes House, located adjacent to the southwestern boundary of the reservation, 800 meters (2,625

feet) from the Perimeter Road, may be eligible for listing on the National Register of Historic Places. The

property includes or is near the location where the last passenger pigeon was reportedly killed, and the

preserved body of that specimen was exhibited for some time in the Barnes House. The Ohio Historic

Preservation Office has encouraged the property owner to submit a National Register nomination

addressing Criterion A for the historical significance associated with the Sargent's Passenger Pigeon and

Criterion C for the property's architectural significance (OHPO, 2004).

3.3.5 Information from Indian Tribes

The Absentee Shawnee Tribe of Oklahoma has identified a number of village sites in its ancestral

homelands in the Ohio Valley, including some along the Scioto River. The Tribe considers that it is

descendant from the people of the Hopewell culture who built the many earthwork sites in the region.

The Tribe refers to "the Barnes Works in Scioto Township" (a reference to the Scioto Township Works,

near the Barnes property mentioned above) as "one of the largest sacred sites in North America" (see

Appendix B).

3.3.6 Historic Properties and Potential Historic Properties

Based on the results of the information review, one historic property, the Portsmouth Gaseous Diffusion

Plant Historic District, is present within the reservation boundary. The State Historic Preservation Officer

indicated the eligibility of the district under Criterion A ("associated with events that have made a

significant contribution to the broad patterns of our history"). The specific buildings and other elements

that contribute to the district's eligibility under Criterion A and the precise boundaries of the district have

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1 not been defined. However, the report by Coleman recommended 132 architectural locations as

2 contributing resources and 28 architectural locations as non-contributing resources.

3

4 Outside of the reservation, but near the southwestern boundary, is one historic property, the Scioto

5 Township Works, which today cohsists of two separate areas that have been heavily disturbed adjacent to

6 Route 23 (DuVall & Associates, 2003). In addition to the archaeological values for which the site was

7; listed on the National Register under Criterion D ("have yielded or may be likely to yield information

8 important to history or prehistory"), the Absentee Shawnee Tribe has indicated that this site has cultural

9 values.

10

11 Sites that have not received formal State Historic Preservation Officer concurrence as National Register

12 eligible will be treated as if they are eligible for the purposes of this impact assessment. These include 13

13' historic farmstead sites within the reservation boundary that were identified by archaeologists as

14 potentially eligible for listing on the National Register under Criterion D, although there is no record of

15 State Historic Preservation Officer concurrence with the finding. In addition, prehistoric lithic scatter 33

16 Pk 210 will be treated as eligible under Criterion D in the absence of State Historic Preservation Officer

17 concurrence with the finding that it is ineligible.

18

19 Adjacent to the reservation boundary is the Barnes House and property, which for the purpose of this

20 review is considered potentially eligible for listing under Criteria A and C, although the State Historic

21 Preservation Officer is awaiting submission of a formal nomination before making a determination.

22

23 Another cultural resource of local architectural and historical significance, the Bailey Chapel, is adjacent

24 to the southeast boundary. The building is listed on the Ohio Historic Inventory, though not listed on the

25 National Register.

26

27 3.4 Visual and Scenic Resources

28

29 The proposed ACP would be located within an existing industrial facility, close to existing production

30 and support facilities, transmission lines, and vacant lots. The facilities are generally not visible off the

31 reservation property or from the highway. Open areas within the facility are maintained as lawns and

32 fields. Open and forested buffer areas, agricultural areas, limited residential areas, and densely forested

33 hills are located adjacent to the proposed site. Rolling hills and small open farmlands dominate the

34 nearby landscape.

35

36 The U.S. Bureau of Land Management developed criteria to assist in the protection of visual and scenic

37 resources. Four Visual Resource Classes are used to represent the value of the visual resource, with Class

38 1 and II being the most valued, Class III having moderate value, and Class IV being the least valued. The

39 proposed ACP site would be consistent in terms of scenic attractiveness and visual resources when

40 compared with surrounding land within the DOE property, maintaining a Visual Resources Management

41 Class III or IV designation both inside and outside the fenced area. Photographs of the proposed ACP site

42 (existing buildings and future building locations) are shown in Figures 3-4 through 3-7.

3-11
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Figure 34 View of the X-7725 and X-7727H Facilities [Looking Easti (USEC, 2005)

3-12
r, Wlt--1- 7-sw

Figure 3-5 View of the X-7725 Facility

[Looking Southwest] (USEC, 2005)

2

2

i

Figure 3-6 View of the X-3001 and X-3002 Process Buildings ILooking Northeast] (USEC, 2005)

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AT

Figure 3-7 Site of X-3346A Feed and Product Shipping and Receiving Building [Looking South] (USEC, 2005)

1 3.5 Climatology, Meteorology, and Air Quality 2

3 This section describes the climatology, meteorology, and air quality in the area surrounding the DOE 4 reservation. This reflects the baseline condition for the Chapter 4 analysis of USEC's emissions under the 5 proposed action.

6

7 3.5.1 Regional Climatology

8

9 The DOE reservation is located in south-central Ohio, west of the Appalachian Mountains. The area's 10 climate is continental and moist and is characterized by moderate extremes of heat and cold. Summers 11 are warm and humid with about 20 days per year reaching temperatures in excess of 32.2- Celsius (90' 12 Fahrenheit), and winters are cold, with temperatures dipping below -17.7 Celsius (0 Fahrenheit) about 13 two days a year. Precipitation averages about 7.5 to 10 centimeters (3 to 4 inches) per month; the fall 14 months having slightly less precipitation than other months, in the range of 5 to 7.5 centimeters (2 to 3 15 inches) per month.

16

17 3.5.2 Site and Regional Meteorology

18

19 For the period 1961 through 1990 in Waverly, Ohio (about 16 kilometers [10 miles] to the north of the 20 site), the mean annual temperature was about 1 1.6' Celsius (53 Fahrenheit). Average summer and winter 21 temperatures are 23.4- Celsius (74 Fahrenheit) and -1.8- Celsius (29- Fahrenheit), respectively. 22 Recorded extreme maximum and minimum temperatures are 39 Celsius (102- Fahrenheit) and -31 23 Celsius (-24- Fahrenheit). Moisture in the area is predominantly supplied by air moving northward from 24 the Gulf of Mexico. The average amount of precipitation is about 102 centimeters (40 inches) per year 25 and is usually well distributed throughout the year (DOE, 2001 b). Occasionally, heavy amounts of rain

3-14
I associated with strong thunderstorms or intense low pressure systems will fall in a short periods of time

2 (USEC, 2003). Fall is the driest season. Although snowfall occurrence varies annually, snow is common

3 from November through March, averaging approximately 52 centimeters per year (20 inches per year)

4 (DOE, 2001b).

5 s

6 Surface meteorological data, including wind data, have been collected at the onsite meteorological tower

7 at the 10-, 30-, and 60-meter (33-, 98-, and 197-foot) levels. The tower is in the southern part of the DOE

8 reservation. A comparison of annual wind roses for the period 1995 through 2001 indicates that wind

9 patterns at the 10-meter (33-foot) level are different from those at the 30-meter and 60-meter (98- and

10 197-foot) levels (DOE, 2002a). Winds at the 10-meter (33-foot) level appear to be influenced by local

11 topographical and/or vegetative features, while wind data at the 30-meter (98-foot) level are believed to

12- be more representative of the site. Accordingly, a wind rose at the 30-meter (98-foot) level is presented in

13 Figure 3-8, which was prepared on the basis of data from the onsite tower from 1998 through 2002

14 (USEC, 2005). About a third of the time the wind blew from the south-southwest, with the prevailing

15 wind blowing from the south. Average wind speed was about 2.7 meters per second (6.3 miles per hour).

16 Directional wind speed was highest from the south at 3.6 meters per second (8.1 miles per hour), while

17 lowest values were recorded in winds blowing from the east at 1.8 meters per second (4.0 miles per hour).

18

19 3.5.2.1 Severe Weather Conditions

20

21 According to weather observations from Columbus, thunderstorms occur an average of 35 days per year.

22 Thunderstorms are most frequent during the period May through August, averaging 29 days per year, and

23 the least frequent in winter, averaging only 2.5 days per year. (National Climatic Data Center, 2004)

24

25 Tornadoes are rare in the area surrounding the DOE reservation, and those that do occur are less

26 destructive in this region than those occurring in other parts of the Midwest. For the period 1950 through

27 1995, 656 tornadoes were reported in Ohio, with an average of 14 tornadoes per year (Storm Prediction

28 Center, 2002). Tornadoes are classified using the Fujita scale (F-scale) with classifications ranging from

29 FO to F5 (Fujita, 1971). FO-classified tornadoes have winds of 64 to 116 kilometers per hour (40 to 72

30 miles per hour) and F2-classified tornadoes have wind speeds of 182 to 253 kilometers per hour (113 to

31 157 miles per hour). While three tornadoes were reported in Pike County during the 1950-1995 period,

32 most of these fell below the F2 level of the Fujita tornado scale (Storm Prediction Center, 2002).

33

34 3.5.2.2 Mixing Heights

35

36 Mixing height is defined as the height above the earth's surface through which relatively strong vertical

37 mixing of the atmosphere occurs. Holzworth (1972) developed mean annual morning and afternoon

38 mixing heights for the contiguous U.S. based on daily upper-air and surface climatological data.

39 According to Holzworth's calculations, the mean annual morning and afternoon mixing heights at the

40 DOE reservation at Piketon are approximately 510 meters (1,673 feet) and 1,700 meters (5,575 feet),

41 respectively. Table 3-2 shows the average morning and afternoon mixing heights for Huntington,West

42 Virginia, where the air station nearest to the DOE reservation is located.

3-15
llL

I

VftV RO. PLOT

X-120H Meteorological Tower- 30 meters 1998-2002

-- -- -- - |M6I' - --.

-II

I I _ _ 

I I

I I I I -- 4-- ft

* I

* II -,

ft S S

I p ft ft

* ft Is - -

* ft I 1 ft ft

V ft ft ft p ft ft ft

ft ft ft

ft ft I

ft ft *

* ft ft

ft ft ft

ft ft ft

ft ft

ft ft

ft S

* ft ft ft

I ft

b%

.t....

I wI - - - - Ii

\+ ,, w II

I ,

"- 120A

I

" 15%

ft *z

9% * ft

S ft

* ft S

F t -t -f AT

,/ ft /t

ft f

,tftf

5 ft J

ft

S

I I

, I

,,

I

..

...-...- -

IJOCCLER CATE COWANY. t

Y gd U USEC W 26 USEC

v I10.C0 C'fP.AY UNfT COMIMTS

9 x.1or* WInd Sped "Vs Nom

a 00- a 00 AVG VaC S*tD O CALM S%**C0

4 4L27is t6c 0.05P%

200.4 C 'CtXNTAT*H PLOT ft-ArATE-Tft-e PROLCTP.OTtfoo

Direction 1 m 1999 2000 2001 2002 o oo . no lovAing from) Jan I - - 31 arn CwPtf Tt

111d - 1

Figure 3-8 Wind Rose at 30 Meters (98 Feet) from

the Onsite Meteorological Tower, 1998-2002 (USEC, 2005)

3-16

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Table 3-2 Average Morning and Afternoon Mixing Heights for Huntington, West Virginia

Average Mixing Heights Time Frame _77 T Units Winter -Spring Summer Fall Annual

* meters * 634 * 721 * 338 403 * 524

Morning ....------------------------. - feet . 2,080 * 2,365 . 1,109 - 1,322 1,719 -_ ;. ..... . ... .-.... ------- ------- .... -...-... -- .............. ___._ .............-.. -

- meters 1,079 1,986 . 1,641 - 1,340 - 1,511

Afternoon i.-.-. ....... .. .*....--i m -- --- .. -.----.. 4...... . -------- -.-------- . _.-..- 1 feet . 3,540 6,516 . 5,384 4,396 4,957

Source: Holzworth, 1972.

3.5.3 Air Quality

To assess air quality, the U.S. Environmental Protection Agency (EPA) has established maximum

concentrations for pollutants that are referred to as the National Ambient Air Quality Standards (EPA,

2004). Table 3-3 presents a list of the National Ambient Air Quality Standards; Ohio State Ambient Air

Quality Standards are identical. Six "criteria pollutants" are used as indicators of air quality: ozone,

carbon monoxide, nitrogen dioxide, sulfur dioxide, particulate matter, and lead (see Criteria Pollutants

text box). The U.S. EPA has designated areas around the country that do not meet these standards as

"nonattainrnent areas." Areas are designated as attainnent/nonattaimnent for each criteria pollutant. Pike

County is in attainment for all criteria pollutants (40 CFR § 81.336). However, nearby Scioto County (5

kilometers [3 miles] from the DOE reservation's southern boundary) has been designated as a

nonattainmrent area for the PM23 standard (40 CFR § 81.336).

Table 3-3 National Ambient Air Quality Standards

Primary Standard Secondary Standard

(to Protect Public Health) -- (to Protect Public Welfare)

Level Form Averaging Level ' - T ieraging Form

More than

0.12 ppm One-hour I three days over

. . ;threeyears ; . _.. . .............

Ozone IThree-year * Same as primary standard

average of

0.08 ppm Eight-hour Iannual fourth

highest daily

maximum

Three-year

Pa.150gm' .24-hour .average of Particulate Matter 1urlP99"'

10 microns or I : ; e Same as primary standard

smaller (PM1I) i -- --.--- --;;

1 .Not to be 50 pg&3 Annual Iexceeded .. _._... _. .. .. .~ ... _ _~.: ......... .. ..... . :.___ .... . ...... ............ ........ ...._ :_ ._ - __ .. _~ .. .... __.

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Table 3-3 National Ambient Air Quality Standards

(continued)

Primary Standard Secondary Standard

(to Protect Public Health) (to Protect Public Welfare) Pollutant

Level * A ing Form Level * Timn Form _ _ _ _ _ Tim e __Time

Three-year

i * * average of i

: 65 tig/ 3 * 24-hour a o

Particulate Matter annual

2.5 microns or E averages Same as primary standard .... ... ;-_- ---- _- - - -------- _-_-- smaller (PM2.

5) Three-year

i15,ug/r 3 iAnnual averageof98dl

percentile . . ... .. ... -. - . g - . . . . . - 4 . . - . - - - . - .........- . . . .. -..... .. .. . -.. ........... ..

3 O i More than once i

35ppm Onehu ryear

Carbon Monoxide i.. - -- --------- No secondary standard More than once 9 ppm . Eight-hour Iper year

More than once 0. 14 ppm i 24-hour eMorethan

per year Sulfur Dioxide -- ------ - -- 0.55 ppm Three-hour once per :*:Not to be y ear 0.03 ppm i Annual i Nxcoed i

...... . ......... . .. .... _ _ ........... Not to be Nitrogen Dioxide 0.053 ppmi Annual exceeded Same as primary standard

. .. .. .g.._. ........................ _......... .......... .... ..

N ot to be S m s p i a y s a d r

Lead j 1.5 pgWrn Quarterly j exceeded asprimarystandard

Notes:

a ppm = parts per million; jig/r 3 = micrograms per cubic meter.

Source: 40 CFR Part 50.

3-18

I .
Criteria Pollutants

Nitrogen dioxide is a brownish, highly reactive gas that is present in all urban atmospheres. Nitrogen dioxide

can irritate the lungs, cause bronchitis andpneumonia, and lower resistance to respiratory infections. The

major mechanismfor theformation of nitrogen dioxide in the atmosphere is the oxidation of the primary air

pollutant nitric oxide. Nitrogen oxides play a major role,-together with volatile organic carbons, in the --

atmospheric reactions that produce ozone. Nitrogen oxidesform when fuel is burned at high temperatures.

The two major emissions sources are transportation and stationaryfuel combustion sources such as electric

utility and industrial boilers.

Ozone is aphotochemical (formed in chemical reactions between volatile organic compounds and nitrogen

oxides in the presence of sunlight) oxidant and the major component of smog. Exposure to ozoneforseveral

hours at low concentrations has been shown to significantly reduce lungfunction and induce respiratory

inflammation in normal, healthy people during exercise. Other symptoms include chest pain, coughing,

sneezing, and pulmonary congestion.

Lead can be inhaled and ingested in food, water, soil, or dust. High exposure to lead can cause seizures,

mental retardation, and/or behavioral disorders, and/or premature death. Low exposure to lead can cause

central nervous system damage.

Carbon monoxide is an odorless, colorless, poisonous gas produced by incomplete burning of carbon in fuels.

Exposure to carbon monoxide reduces the delivery of oxygen to the body's organs and tissues. Elevated levels

can cause impairment of visualperception, manual dexterity, learning ability, andperformance of complex

tasks.

Particulate matter such as dust, dirt, soot, smoke, and liquid droplets are emitted into the air by sources such

as factories, power plants, cars, construction activity, fires, and natural windblown dust. 'Exposure to high

concentrations ofparticulate matter can affect breathing, aggravate existing respiratory and cardiovascular

disease, alter the body's defense systems againstforeign materials, and damage lung tissue.

Sulfuir dioxide results largely from stationary sources such as coal and oil combustion, steel and paper mills,

and refineries. -It is a primary contributor to acid rain and contributes to visibility impairments in large parts

of the country. Erposure to sulfur dioxide can affect breathing and may aggravate existing respiratory and

cardiovascular disease.

Source: EPA, 2004.

1 -

I 3.5.3.1 Current Emissions at the DOE Reservation

2

3 Non-Radioloeical Emissions

4

5 Nonradiological air emissions from the DOE reservation are predominant sources in Pike County (EPA

6 2003a). Currently, the United States Enrichment Corporation has three Ohio EPA operating permits. The

7 Title V permit issued for current operations was effective as of August 21, 2003, and is a sitewide,

8 Federally enforceable operating permit to cover emissions of all regulated air pollutants at the facility.

9 The United States Enrichment Corporation has identified the following criteria pollutant emissions for the

10 year 2001 (see Table 3-4): 54.30 metric tons (59.86 tons) of particulate matter with a mean diameter of

11 10 micrometers or less, 1.29 metric tons (1.42 tons) of volatile organic compounds, 2,474 metric tons

12 (2,628 tons) of sulfur dioxide, and 328 metric tons (362 tons) of nitrogen oxides. These emissions are

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Table 3-4 Nonradiological Air Emissions from United States Enrichment Corporation

and DOE Sources at the DOE Reservation in 2001

Major Emission Units Emission Rate'

Source So 2 NO. co VOCs PM,, PMLS

metric Nott

United States 2384 328 13 543 Not tons/year 'I Available I Available

Enrichment --- ------------------ -------..... ....

Corporation facilities tons/year 2 628 362 No 1N4 599

Available 1 4 * Available ... . .... ...... ..... -.. ........- . ---------- *- -- - -*-.-----. -..-. - ------ -.- -.- ----.-.---.--

DOE facilities'b metric 20 85 53 5.2 4.8 Nt tons/year Available ------------ ........... ....... . . .... ~... 4 ------------ . -...... ..... -.......

tons/year I 22 94 59 5.7 5.3

Available

Notes:

a SO2 = sulfur dioxide; NOx = nitrogen oxides; CO = carbon monoxide; VOCs = volatile organic compounds; PM,, =

particulate matter with a mean diameter of 10 micrometers or less; PM2, = particulate matter with a mean diameter of 2.5

micrometers or less.

S source: DOE, 2001c.

Proposed maximum annual emissions based on the assumption that two boilers would operate full time.

Source: Bechtel Jacobs Company, 2003.

associated primarily with the boilers at the X-600 Steam Plant (that provides steam for the DOE

reservation), a boiler at the X-6 11 Water Treatment Plant, an emergency generator, and a trash

punip(DOE, 2001c). DOE operates numerous small sources that release criteria pollutants and volatile

organic compounds. In November 2001, DOE began operation of the X-6002 Recirculating Hot Water

Plant to provide heat for the DOE facilities that were formerly heated by hot water from the gaseous

diffusion process. Maximum annual emissions from plant operations account for most of the DOE

emissions (Bechtel Jacobs Company, 2003; see Table 3-4). Other DOE emissions, including two landfill

venting systems, two glove boxes (not used in 2001), two aboveground storage tanks in the X-6002A

Fuel Oil Storage Facility, and two groundwater treatment facilities, emit less than 0.9 metric tons (I ton)

per year of conventional air pollutants (on an individual basis).

a

The largest non-radiological airborne emissions from the DOE reservation are from the coal-fired boilers

at the X-600 Steam Plant. These emissions are shown in Table 3-5. The boilers are permitted by Ohio

EPA with opacity, particulate, and sulfur dioxide limits. Electrostatic precipitators on each of the boilers

control opacity and particulate emissions. In addition, the boilers emit nitrogen dioxide and carbon

monoxide. There are also minor contributions of these pollutants from oil-fired heaters, stationary diesel

motors, and mobile sources (e.g., cars and trucks). Other air pollutants emitted from the DOE reservation

in Piketon, Ohio, include gaseous fluorides, water treatment chemicals, cleaning solvent vapors, and

process coolants. (USEC, 2005)

Radiological Emissions

42 Airborne discharges of radionuclides from the DOE reservation are regulated under the Clean Air Act,

43 40 CFR Part 61, Subpart H, National Emission Standards for Hazardous Air Pollutants. Currently, the

44 United States Enrichment Corporation is responsible for most of the sources that emit radionuclides

45 because DOE leases the production facilities to it. In 2001, United States Enrichment Corporation and

46 DOE reported emissions of 7.40 x I09 and 2.33 x I0' becquerels (0.2 and 0.00063 curies) from their

47 radionuclide emission sources, respectively. (DOE, 2004a)

3-20
I Table 3-5 United States Enrichment Corporation's Non-Radiological Airborne Emissions

2

3

4

5

6

7

Total Particulate Matter | Air Permit Limit' Stack Test Results &.b

BoilerNumber I -0.19 lbs/mmbtu - 0.04 lbs/nmmbtu .-. -. . .....--.......... .._

Boiler Number 2 0.19lbs/mmbtu - 0.05 lbs/mrnbtu _ ._._... ............................... . . . - - _._ .... -

Boiler Number 3 0.19 Ibs/mbtu* 0.05 lbs/mmbtu

Sulfur Dioxide Air Permit Limit . Analytical Results '

8 Boiler Number I 6.16 lbs/mmbtu

..... _ ._. . ..............

9 -_ BoilerNumber2 6.16 lbs/mmbtu 4.72 lbs/mnmbtu

10 - - BoilerNumber3 .6.16 lbs/nmubtu * _-_.

11 Notes:

12 ' lbs/mmbtu = pounds per million British thermal unit.

13 b Boilers I and 2 tested in April 2003. Boiler 2 tested in November 2003.

14 Steam plant total for 2002.

15 Source: USEC, 2005.

16

17 3.5.3.2- Current Air Quality Conditions

18

19 Non-Radiological Emissions

20

21 Ambient concentration data are not available for criteria pollutants around the site. The nearest

22 monitoring site is in the City of Portsmouth, approximately 43 kilometers (27 miles) to the south of the

23 reservation. On the basis of 1998 through 2003 monitoring data, the highest concentrations for sulfur

24 dioxide, nitrogen dioxide, carbon monoxide, particulate matter with a mean diameter of 10 micrometers

25 or less, and lead are less than 64 percent of their respective National Ambient Air Quality Standards listed

26 in Table 3-3 (EPA, 2003b). It is expected that levels at the DOE reservation are equal to or lower than

27 these reported concentrations. The highest concentrations of ozone and particulate matter with a mean

28 diameter of 2.5 micrometers or less are approaching or are somewhat higher than the applicable standards.

29 These high concentrations are of regional concern and are associated with high precursor emissions from

30 the Ohio Valley region and long-range transport from southern States.

31

32 Radiological Emissions

33

34 Although not used to measure criteria pollutants, there is a network of 15 air samplers in and around the

35 DOE reservation that primarily collect data on radionuclide concentrations at the site.' Thesedata'are

36 used to assess whether air emissions from the DOE reservation affect air quality in the surrounding area.

37 In addition to radionuclides, samples for fluorideare collected weekly from 15 ambient monitoring

38 stations in and around the reservation. With only one exception, the'average ambient concentrations

39 measured at these stations in 2001 were similar to or less'than those'collected at a background station

40 located approximately 21 kilometers (13 miles) southwest of the'reservation (see Table 3-6). The

41 exception was for the network station that is located within the process area immediately east of the X42 326 building.'

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Table 3-6 Background Air Concentrations

Chemical . Number of Samples I Maximum' A

Radionuclide Units (Measurement) b inimum Magmu

Americium-241 . pCirn 1 12 (12) ND 1.5 x 1045 -.- 4-..... -.---.--------- . -- ..- -----.-.-.-.... - - _4 --.- .....

Fluoride . tgm3 . 52(8) .2 x 10" *.1.9 X I04 I 6.3 x 10l ....I* ._ . ... . .., ...... ...... ._....... .... .. .- _ _ .. - . ._ _..- .

Neptunium-237 * pCi/r 3 . 12(12) ND 5.9x IO-' * .. . .. ... . ... . .. . . . .. 4 . . ... . . . . . . . . . I , . . . . . . . . . . . . . . . -.-.-. - -.-.-. - -. . g . . ..-- . . . .. . ... . . . . .... . . . .... ... ... .

Plutonium-238 . pCi/m3 * 12 (12) . ND 1.2 x 1045 - -- -- - -- -- - - -- -- -- - . . . .. . .. .... .... . . . ........ 4. . . . . .. . . . . . . . . . . . . . . . .... ..... . . .... . .......

Plutonium-239/240 . pCi/r 3 . 12(12) . ND 8.0x 104I ... _..._ . .. ...... __ ,....... ........ ... _ ...... .-------- _. . _ .4 _ -.... 

Technetium-99 . pCi/r 3 12 (12) . ND 9x 1043 . ....................... ,. _ 4 __ _ .................... . ................. . .

Uranium * pg/M3 * 12 (1) 4.6 x 1044 1.2x 10- 7.5. x .. .. ............... .............. *,........ ...................... _--......-....................... --..... .... ._.... .........

Uranium-233/234 .pCi/m 3 . 12 (0) 1.4 x 104' * 4.6x 104' * 2.8x 104' . ....................... ... . .. ....... . .. . .... .. . ......... ...... _ ... .

Uranium-235 pCi/M3 . 12(6) . ND 1.5x 1045' ...... ............ 

Uranium-236 pCi/r 3 . 12(12) ND 6.0x 1046 . . . ........ ...... . . ........ . ..... ................

Uranium-238 pCi/m3 . 12 (1) 1.5 x 104' 3.9 x 104' 2.5 x 104'

Notes:

pCi/m' = picoCuries per cubic meter, ,pgrnm = micrograms per cubic meter.

b Radiological samples are analyzed monthly, samples for fluoride are analyzed weekly. Number in parentheses is the

number of samples that were below the detection limit.

' ND = Not detected above method detection limit. Results above the detection limit are provided in scientific notation.

d For radionuclides, averages are not calculated for locations that had greater than 15 percent of the results below the

detection limit. If the analytical result for a sample was below the detection limit, the ambient air concentration was

calculated based on the detection limit for the sample. Averages were calculated for fluoride at all sampling locations.

Source: DOE, 2002b.

3.6 Geology, Minerals, and Soil

This section provides a brief description of the regional and local geology, including bedrock and soil

characteristics and seismicity. There are not any economically valuable mineral resources, including oil

and gas resources, that could be recovered from the potentially affected area.

3.6.1 Regional Geology, Structure, and Seismicity

The DOE reservation is situated within the Appalachian Plateau Physiographic Province of the

Appalachian Highland region near its northwestern terminus at the Central Lowlands Province. The

Appalachian Plateau is characterized by deeply dissected valleys and even crested ridge tops. Just east of

the Scioto River, the summits of the main ridges rise to an altitude of more than 355 meters (1,160 feet)

above mean sea level, with relief of up to 150 meters (490 feet) from the bottom of the valleys. The

proposed ACP site would be situated at an elevation of approximately 205 meters (670 feet).

Surface and near-surface geology at the site have been heavily influenced by glaciation and the associated

meltwaters. The DOE reservation is located in an abandoned river valley that was later filled with lake

sediments deposited during the existence of prehistoric Lake Tight (Rogers et al., 1988). Bedrock at the

site is composed of sedimentary rocks, primarily shale and sandstone, deposited in a broad shallow sea

during the Paleozoic Era more than 230 million years ago. The rock units of interest at the site are, in

ascending order, Ohio Shale, Bedford Shale, Berea Sandstone, Sunbury Shale, Cuyahoga Shale, Gallia

Sand, and Minford Clay. Figure 3-9 shows the relationship of the geologic units to the site and region.

3-22
Figure 3-9 Site Geology in the Vicinity of the DOE Reservation at Piketon

(NRC, 2004a)

2 The Ohio Shale is 90 to 120 meters (300 to 400 feet) thick at the site. It is black and thinly bedded and

3 may contain noncommercial quantities of natural gas or oil. The Bedford Shale consists of interbedded

4 thin sandstone and shale. The Berea Sandstone has a larger sand content than the Bedford Shale but is

5 otherwise similar. At the proposed site, the Berea Sandstone forms an aquifer that has an average

6 thickness of about 9 meters (30 feet). The Sunbury Shale is a black carbonaceous shale; this-unit thins

7 fromneast to west and may be completely absent in western portions of the site (DOE, 2004a)). The Teays

8 Formation overlies the Sunbury Shale and is made up of Gallia Sand and Minford Clay, in ascending

9 order. These unconsolidated deposits have a fluvial origin and occupy ancient channels of the Teays

10 River System. The Gallia'Sand member is a silty to clayey, coarse to fine-grained sand with a pebble

11 base. The Minford Clay member contains interbedded silts and clays and is divided into two zones: an

12 upper zone of clay and a lower zone of silty clay.

13

14 There are no major faults at the site. The nearest fault zone is the Kentucky River Fault Zone located

15 approximately 40 kilometers (25 miles) south of the site. No seismic events have been associated with it.

16 There have been no historical earthquakes within 40 kilometers (25 miles) of the site.

17

18 The largest recorded seismic event in the area was the Sharpsburg, Kentucky, earthquake of July 1980.

19 Sharpsburg is located approximately 115 kilometers (70 miles) south of the DOE reservation.- That

20 earthquake registered a magnitudebof 5.3 on the Richter Scale and a Modified Mercalli intensity of VII.

21

22 Ground motion from earthquakes causes damage to buildings and structures. Ground motion is measured

23 as a percent of the acceleration of gravity. At 10 percent gravity (0.lg) some damage may occur in poorly

24 constructed buildings. At 0.1 g to 0.2g most people have trouble keeping their footing. In the 1980's DOE

25 studied the historical seismicity of the areas surrounding the Portsmouth plant.' Data were developed on

26 probable seismic activity and the intensity levels were converted into acceleration values. They

27 determined that the maximum earthquake likely to occur would produce a ground motion equal to 0.15

3-23
al

L]

I gravity, and a recurrence of 1,000 years. The GCEP and ACP were designed based on the Design Basis

2 Earthquake of 0.15 gravity and 1,000 year recurrence. (DOE, 1980 and DOE, 1982)

3

4 3.6.2 Soils

5

6

7

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10

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47

A majority of the soils at the DOE reservation are formed on ancient river or lake deposits. Other

important soil-forming materials are parent material from the underlying shale bedrock, colluvium, and

loess (windblown material) (DOE, 2004a). Approximately 600 hectares (1,500 acres) of the site consist

of moderately drained soils of the Urban Land-Omulga silt loam complex. The Omulga soil at the site is

a dark grayish brown silt loam about 25 centimeters (10 inches) thick. Beneath this layer is about 137

centimeters (54 inches) of yellowish-brown subsoil. This material is characterized by a friable silt loam, a

silty clay fragipan (low-permeability layer), and, near the bottom, a friable silt loam. Within the fragipan,

the subsoil has low permeability. Other soils of the reservation include the Clifty and Wilbur silt loams,

which occur in stream valleys. The upland areas contain a mixture of Coolville, Blairton, Latham,

Princeton, Shelocta, and Wyatt soils. A description of these soils is provided in Hendershot et al. (1990).

Soil samples are collected semianually from nine onsite locations, six off-site locations within 5

kilometers (3 miles) of the site, and 12 remote locations 5 to 16 kilometers (3 to 10 miles) from the site.

Samples are analyzed for total uranium, technecium-99, gross-alpha activity, and gross-beta activity.

Table 3-7 summarizes the data from 1998 to 2002 and shows that the results from the different sampling

locations are not significantly different. There are no soil data specifically from the proposed ACP site.

Table 3-7 Results of Baseline Soil Samples, 1998-2002 '

I Total Uranium Technetium 1 Gross Alpha | Gross Beta

mglg pCilg pCi/g pCil/g

Reservation (9 Soil Sampling Locations)

No. of Samplesb . 117 (0) 117 (93) 117 (59) 117 (64) ._.--. - ...... ...... . . ........ ..-..-.....

Average * . 2.8 <0.2 <8 <14 ------- . .... _ .....__................... _._ . __..-............_........ ._ .. ... .... ....._ _

Minimum o6.<0. 1 <2 8

Maximum 4.4 1.5 21 36

Off Reservation (6 Soil Sampling Locations)

No. of Samplesb 74 (0) 74 (32) 74 (38) 74 (41) _....._.-..............._.. ...... .... ............ ............... ......... .................

Average 2.9 <0.2 . <7 <14 ....... __ .............. _._............... . .. _ _ .. .... .-. ...................... .......... ........... 

Minimum i 0.7 . <0.1 * . <2 <8 _..._._....._._ ... . .. _ .. . .__............._.. ......_ ........... _. . _._._........ _..._............ __

Maximum 1 4.6 3.8 14 47

Remote (12 Soil Sampling Locations)

No. of Samples'b 139 (0) 139-(133) 139 (73) * 139 (77) .. .....-............................... ....... .................................

Average 3.0 * <0.2..2 .. <14 ------------ ........... ...... __.... _._ A.___..._ ...... _. ___._._.......... ....... _ .. ...... __

Minimum 0.7 <0.1 <3 <7

Maximum * . 5.9 0.8 16 22

Notes:

a mg/g = milligrams per gram; pCi/g = picoCuries per gram.

' The 'number of samples" shows the total number of samples collected, including replicate and duplicate samples collected

for quality assurance purposes, followed by the number of samples that were lower than the Minimum Detectable

Concentration in parentheses.

Source: USEC, 2004a.

3-24
1 3.7 Water Resources

2

3 This section presents a discussion of the surface water and its associated resources (floodplains) and

4 groundwater in the vicinity of the DOE reservation, including the regional and local surface water

5 features (riveis/streams and lakes/ponds) surrounding the reservation, as well as the floodplains located

6 on the reservation. The discussion of surface water describes the existing features, 'summarizes the

7 existing National Pollutant Discharge Elimination System permitted outfalls from the reservation to such

8 features, and concludes with a discussion of water quality and its designated uses. The discussion of

9 floodplains present the location and attributes of such features on the reservation. The groundwater

10 discussion describes the regional groundwater aquifers, the groundwater well fields associated with the

11 DOE reservation, and the onsite groundwater conditions and remediation activities.

12

13 3.7.1 Surface Water Features

14

15 The DOE reservation is within the Lower Scioto River watershed, U.S. Geological Survey Cataloging

16 Unit: 05060002. The reservation occupies an upland area at an elevation of 200 meters (670 feet) above

1 7 mean sea level and is bordered by ridges of low-lying hills. Surface waters drain from the DOE

18 reservation via a network of tributaries to the Scioto River located approximately 3.2 kilometers (2 miles)

19 to the west (Rogers et al., 1988). The average flow in the Scioto River measured at Higby (approximately

20 32 kilometers [20 miles] northeast and upstream of the reservation) is 133 cubic meters per second (2.1 x

21 106 gallons per minute). The 10-year low-flow discharge at Higby is 8.58 cubic metes per second (1.4 x

22 105 gallons per minute). The Scioto River discharges into the Ohio River approximately 40 kilometers

23 (25 miles) south and downstream of the reservation. There are no known public or private water supplies

24 draw from this section of the Scioto River (USEC, 2005).

25

26 Surface water features on the DOE property include streams, ditches, holding ponds, and lagoons as

27 shown on Figure 3-10. There are four lagoons, eight holding ponds, several unnamed tributaries and

28 drainage pathways, and four named streams and ditches on the DOE reservation. The four streams

29 include Little Beaver Creek, Big Run Creek, the West Ditch, and the DOE Piketon'Tributary. Little

30 Beaver Creek drains the northern portion of the reservation, Big Run Creek drains the east-central and

31 southern portions of the reservation, the West Ditch drains the west-central portion of the reservation, and

32 the DOE Piketon Tributary drains the south-western portion of the reservation. Storm water at the DOE

33 reservation is collected by a series of storm water sewers and open culverts. The reservation has eight

34 specific storm water collection areas, which transmit the storm water flow to one of the onsite streams or

35 ditches. All of the streams and ditches transport the surface water;- including storm water, from the

36 reservation to the Scioto River.

37

38 The largest stream on the DOE reservation is Little Beaver Creek, which discharges into Big Beaver

39 Creek, which then discharges into the Scioto River. Upstream of the plant, Little Beaver Creek flows

40 intermittently during the year.- Onsite, it receives treated proces's wastewater from a holding pond (via the

41 east drainage ditch) and stormi water runoff from the northwestern and northern sections of the reservation'

42 via several storm sewers, water coiirses, and the north holding pond. The average release to Little Beaver

43 Creek for 1993 was 0.06 cubic meter per second (951 gallons per minute).

44

45 The next largest stream, Big Run Creek, receives effluent from the South Holding Pond (X-230K), and

46 ' flows offsite to the southwest where'it joins the Scioto River approximately 6.4 river-kilometers (4 river47 miles) from the reservation. Storm sewers in the southern end of the reservation discharge to the South

48 Holding Pond. The DOE Piketon Tributary, is a small intermittent watercourse leading from Holding

49 Pond No. I (X-2230M, National Pollutant Discharge Elimination System permit number 612) to the

- 3-25
HI1,

Figure 3-10 Surface Water Features at the DOE Reservation at

Piketon (USEC, 2005)

I Scioto River, 1.6 stream-kilometers (1 stream-mile) downstream. The West Ditch receives surface water

2 from existing open drainage swales and from Holding Pond No. 2, X-2230N and flows for 6.4 stream3 kilometers (4 stream-mile) before discharging into the Scioto River.

4

5 The Ohio Administrative Code (3745-1-09) for the Scioto river drainage basin classifies the designated

6 uses of the surface waters within and surrounding the DOE reservation. The aquatic life habitat, water

7 supply, and recreational use designations are defined in rule 3745-1-07 of the Ohio Administrative Code.

8 The State resource water use designation is defined in rule 3745-1-05 of the Ohio Administrative Code.

9 The most stringent criteria associated with any one of the use designations assigned to a water body will

10 apply to that water body.

11

12 The surface water features that drain the DOE reservation as well as the Scioto River and their designated

13 uses are as follows:

14

15 * Little Beaver Creek: State Resource Water, Warm Water Habitat; Agricultural Water Supply;

16 Industrial Water Supply; and Primary Contact Recreation.

3-26
I * Big Run Creek: Warm Water Habitat; Agricultural Water Supply; Industrial Water Supply; and

2 Primary Contact Recreation.

3

4 - DOE Piketon Tributary: Limited Resource Water; Agricultural Water Supply; Industrial Water

5 Supply; and Secondary Contact Recreation.

6

7 * West Ditch: Warm Water Habitat; Agricultural Water Supply; Industrial Water Supply; Secondary

8 Contact Recreation.

9

10 * Scioto River: Warm Water Habitat; Public Water Supply; Agricultural Water Supply; Industrial

11 Water Supply; Primary Contact Recreation.-

12

13 The designated uses of the rivers, streams,- and ditches aid in defining the parameters associated with the

14 National Pollutant Discharge Elimination System permits issued by the State of Ohio. Currently, the

15 DOE reservation maintains a total of 19 permits, which are managed by both DOE and the United States

16 Enrichrnent Corporation. DOE is responsible for eight of the 19 permits, including:

17

18 * Three DOE outfalls that discharge directly to surface water (to the DOE Piketon Tributaiy, the West

19 Ditch, and Little Beaver Creek).

20

21 * Three outfalls discharge to USEC building X 6619, Sewage Treatment Plant, which are subsequently

22 discharged through a permit issued to USEC for Outfall 003. These three are Outfalls 608,610, and

23 611.

24

25 * Two outfalls discharge to holding ponds.

26

27 The United States Enrichment Corporation is responsible for 11 of the 19 National Pollutant Discharge

28 Elimination System permits, including:

29

30 * Eight outfalls that discharge directly to surface water (DOE Piketon Tributary, West Ditch, Little

31 Beaver Creek, Big Run Creek, and the Scioto River).

32

33 * Two outfalls that discharge to the X-6619 Sewage Treatment Plant (Outfall 003).

34

35 * One outfall that discharges to the X-230K South Holding Pond (Outfall 002). (USEC, 2003)

36

37 Table 3-8 lists the 19 outfalls by permit number and includes information on the operator (DOE or the

38 United States Enrichment Corporation), a description of the outfall, and the ultimate receiving water

39 body. These United States Enrichment Corporation outfalls are illustrated in Figure 3-11.

40

41 The domestic wastewater generated by the offices and change houses is treated on the reservation at the

42 sewage treatment plant. The design capacity of the sewage treatment plant is 2,275,032 liters per day

43 (601,000 gallons per day), and in 2003, the facility operated at 27 percent of that capacity (USEC,-2003).

44 The discharge from the sewage treatment plant is within its National Pollutant Discharge Elimination

45 System peirmit criteria.

3-27
II I

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Table 3-8 National Pollutant Discharge Elimination System

Permit Operator, Description, and Receiving Water Body

Operator Outfall Description I Receiving Water Body

United States Enrichment 1I X-23 037 - East Holding Pond ITributary of Little Beaver Creek

Corporation - . . . . .

United States Enrichment 2 X-230K - South Holding Pond Big Run

Corporation - .. -

United States Enrichment 0.125 Building X-6619, sewage Scioto River

Corporation treatment plant ............................ 4......... .4....... ......... ................... ~........

United States Enrichment 4 Cooling tower blowdown Scioto River

Corporation

United States Enrichment 5 X-611IB - lime sludge lagoon Little Beaver Creek

Corporation

United States Enrichment 0.375 X-230L - North Holding Pond Tributary to Little Beaver Creek

Corporation .- -. . - - .... . 4 .... . . ......... . . . ... ....... .............. ...... ... . .

United States Enrichment 0.4167 X-23 035 - Northwest Holding West ditch

Corporation Pond

United States Enrichment 11I X-23 016 - Northeast Holding Tributary to Little Beaver Creek

Corporation Pond

DOE 0 X-2230M pond DOE Piketon Tributary

DOE 0.042 X-2230N pond West ditch . . ...... ..... . .....---.---.----------- I ....----- . .------ .- - .----.-..........-... ..

DOE 0.125 IGroundwater treatment facility Tributary to LittleBeaver Creek - ............. . ... . ..... .......... --------------.-........ .......-.... I..... ..........

DOE .608 SIGroundwater treatment plant Sewage treatment plant ............ ........- ....... ....-- . ...-----------.--------.--- .... . ......

DOE 610' IGroundwater treatment plant ISew age treatment plant . . .................... . .... . . .... ............ *.......... . ......... . ... ................

DOE .61 1 Groundwater treatment plant Sewage treatment plant . .............. . ..... 4,.. . ... 4.........-----------------------. .... -....... .

DOE 612 Groundwater treatment plant DOE Piketon Tributary -

discharging to X-2230M pond inactive

DOE 613 Particulate separator Not applicable

United States Enrichment 602 X-621 coal pile runoff Big Run Creek

Corporation treatment facility

United States Enrichment 604 X-700 bio-nitrification facility Sewage treatment plant

Corporation . .. . ..

United States Enrichment 1605 1X-705 decontamination Sewvage treatment plant

Corporation _____Imicrofiltration facility ______________

35 Notes:

36

37

38

39

Discharging to receiving waters downstream of the surface water runoff pathway associated with the proposed action.

Note: DOE internal Outfalls 608, 610, and 611 discharge to United States Enrichment Corporation Outfall 003 (X-6619

Sewage Treatment Pant). DOE internal Outfall 612 discharges to DOE OutfallI012.

3-28
.

WAC *M -- - --

0! - DUMA Ku6tws

rMC-VV Omwesft

I"? 0 Vuas ups e ra.c

"a W r., JWn.

Figure 3-11 United States Enrichment Corporation National Pollutant Discharge Elimination

System Outfalls at the DOE Reservation at Piketon

1 3.7.1.1 Surface Water Quality

2 -

3 At the DOE reservation at Piketon, DOE is responsible for eight permitted outfalls and the United States

4 Enrichment Corporation is responsible for 11 permitted outfalls, as discussed earlier (DOE, 2002c). In

5 addition to monitoring the water quality parameters required by Ohio EPA, DOE monitors radionuclides

6 contained in the discharges. Ohio EPA selects the chemical parameters that must be monitored at each

7 outfall based on the chemical characteristics of the water that flows into the outfall. Table 3-9 lists the

8 parameters required by Ohio EPA for the outfalls that may be used for the development and operation of

9 the proposed ACP.

10

11 Permitted outfalls managed by the United States Enrichment Corporation were in compliance with

12 contaminant concentration discharge limits in 2002 (DOE, 2003b; NRC, 2004a). Permitted outfalls

13 managed by DOE were in compliance with contaminant concentration discharge limits in 2003 (DOE,

14 2004a).

3-29
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Table 3-9 National Pollutant Discharge Elimination System

Permit and Monitoring Parameters

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31

32

33

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41

Operator [ Outfall j Parameters

U Ammonia-nitrogen, biochemical oxygen demand, chlorine,

Coporation . 003 . copper, fecal coliform (May-October only), mercury, nitratenitrogen, oil and grease, silver, suspended solids, zinc .... _..._.................. _ ........... .. ..-..

United States Enrichment 009 Fluoride, manganese, oil and grease, suspended solids, zinc

Corporation ... __~~ .- __._ ..-..--.-... ._ ~ . .... ..-..-.. ___ __. ...... _._ _. -....- _. _.... ....-... _.... ..... __.-..-... _____

United States Enrichment 010 Fluoride, manganese, oil and grease, suspended solids, zinc

Corporation

Chlorine, iron, oil and grease, suspended solids, total PCBs, and

DE 02 trichloroethene ...... . . . ...... . ........ ... ... . ...........-- .. .........--...... . ...................

DOE 5 013 Chlorine, oil and grease, suspended solids, and total PCBs .-..... .. . ..... .. ..... . ...... ............... ................ . . .. ......... . . . ...... 

DOE . 608 ' Trichloroethene and trans-l,2-dichloroethene *....-. --- - ..-.----.-.-...-.-. . ..... . .-. .... ....-... ..........

DOE . 610 * * Trichloroethene and trans-1,2-dichloroethene

DOE * 611 ' Trichloroethene

Source: DOE, 2002b.

In addition to the characteristics of the water the flows into the outfall, the National Pollutant Discharge

Elimination System permits consider the designated use and the associated water quality of the receiving

water body. The following uses have been designated for one or more of the surface water features that

drain the DOE Reservation:

* Warm Water Habitat. Exhibits typical assemblages of fish and invertebrates belonging to any other

than cold or cool water species. Warn water habitats are waters capable of supporting and

maintaining a balanced, integrated, adaptive community of warmn water aquatic organisms having a

diverse species composition and functional organization.

* Limited Resource Water. These are waters that have been the subject of a use attainability analysis

and have been found to lack the potential for any resemblance of any other aquatic life habitat as

determined by the biological criteria in Table 7-15 of Ohio Administrative Code 3745-1-07. The use

attainability analysis must demonstrate that the extant fauna is substantially degraded and that the

potential for recovery of the fauna to the level characteristic of any other aquatic life habitat is

realistically precluded due to natural background conditions or irretrievable human-induced

conditions.

* Agricultural Water Supply. These are waters suitable for irrigation and livestock watering without

treatment.

* Primary Contact Recreation. These are waters that, during the recreation season, are suitable for fullbody contact recreation such as, but not limited to, swimming, canoeing, and scuba diving with

minimal threat to public health as a result of water quality.

3-30
1 * Secondary Contact Recreation. These are waters that, during the recreation season, are suitable for

2 partial body contact recreation such as, but not limited to, wading with minimal threat to public health

3 as a result of water quality.

4

5 The specific water quality conditions and parameters associated with each designated use can be found in

6 Ohio Administrative Code 3745-1-07 (water use designations and Statewide criteria).

7

8 With the exception of DOE outfall 613, a weekly composite water sample is collected from DOE external

9 outfalls and analyzed for total uranium, uranium isotopes (uranium-233/234, uranium-235, uranium-236,

10 and uranium-238), technetium-99, and transuranic radionuclides (americium-241, neptunium-237,-

11 plutonium-238, and plutonium-239/240). Outfall 613 is not monitored for radionuclides because there is

12 no source for radiological contamination of the water discharged from this outfall. A weekly composite

13 water sample is collected from all external United States Enrichment Corporation outfalls and analyzed

14 for total uranium, technetium-99, and transuranic radionuclides (americium-241, neptunium-237,

15 plutonium-238, and plutonium-239/240). (DOE; 2004c)

16

17 Total radioactivity released from the DOE external outfalls was 0.0049 curie of uranium isotopes and

18 0.00004 curie of technetium-99. These values were calculated u'sing monthly monitoring data fr6m the

19 DOE NPDES outfalls. Neptunium-237 was detected at 0.04637 picocurie per liter (pCi/L) in the sample

20 collected from DOE Outfall 015 in the fourth quarter of 2003. Neptunium-237 was not detected at

21 Outfall 015 in the other three quarterly samples collected in 2003. Amrericium-241, plutonium-238, and

22 plutonium-239/240 were not detected in samples collected from any of the DOE outfalls in 2003. (DOE,

23 2004c). Total radioactivity released from the United States Enrichment Corporation external outfalls was

24 1.1 x 109 bequerels (0.0296 curies) of uranium and 1.2 x 109 bequerels (0.0335 curies) of technetium-99.

25 Transuranic radionuclides (americium-241, neptunium-237, plutonium-238, and plutonium-239/240)

26 were not detected in any of the samples collected from USEC NPDES outfalls in 2003. (DOE, 2004c)

27

28 In 2003,-an estimated 4.3 kilograms (9.5 pounds) of uranium were discharged from DOE National

29 Pollution Discharge Elimination System outfalls and 21 kilograms (46 pounds) were discharged from

30 United States Enrichment Corporation outfalls, for a total of 25.3 kildgrams (55.5 pounds)! (DOE,'

31 2004c)

32

33 The analytical results were compared to the standards included in DOE Order 5400.5, Radiation

34 Protection of the Public and the Environment. DOE Order 5400.5 provides guidance and establishes

35 radiation protection' standards and control practices designed to protect the public and the environment

36 from' undue radiological risk from operations of DOE and DOE contractors. The order requires that

37 off-site radiation doses do not exceed 100 millirem/year above background for all exposure pathways.

38

39 The derived concentration guide for each radionuclide as defined in DOE Order 5400.5 includes the

40 following concentrations (in picocuries per liter):

41

42 * Americium-241 = 30

43 * Neptunium-237 = 30

44 * Plutonium-238 =40

45 * Plutonium-239/240 = 30

46 * Technetium-99 = 100,000

47 * Uranium-233/234 = 500

48 * Uranium-235 = 600

49 * Uranium-236 = 500

3-31
1 * Uranium-238 = 600

2 * No derived concentration guide is available for total uranium.

3

4 All analytical results from the external NPDES outfalls are well below these DOE standards.

5

6 In addition to the external NPDES outfalls, the surface waters are monitored for radioactive

7 contamination at 14 locations, including locations upstream and downstream from the DOE reservation.

8 The surface water monitoring results for 2001 indicated that the measured radioactive contamination was

9 consistently less than the applicable drinking water standards (DOE, 2002b and 2002c). Uranium

10 concentrations were detected at levels similar to those that occurred naturally in the Scioto River.

11 Technetium-99 was detected at 1,591 becquerels per cubic meter (43 picocuries per liter) in a sample

12 collected downstream of Little Beaver Creek; this level is well below the DOE-derived concentration

13 guide of 3.7 x 106 becquerels per cubic meter (100,000 picocuries per liter) (DOE, 2002c). The DOE

14 derived concentration guide values given in DOE Order 5400.5 are reference values for radiological

15 protection programs at operational DOE facilities (DOE, 1993b). In addition, in 2001, surface water

16 samples were collected monthly from five locations at the DOE cylinder storage yards and analyzed for

17 total uranium, uranium isotopes, transuranics, and technetium-99. The maximum detected concentration

18 of uranium in these samples was 14 micrograms per liter, which is less than the drinking water Maximum

19 Contaminant Level of 30 micrograms per liter, the maximum technetium-99 concentration was 370

20 becquerels per cubic meter (10 picocuries per liter), well below the DOE-derived concentration guide of

21 3.7 x 106 becquerels per cubic meter (100,000 picocuries per liter).

22

23 Sediment samples are also collected at the locations where surface water samples are collected by the

24 United States Enrichment Corporation, and at the permitted outfalls on the east and west sides of the DOE

25 reservation (DOE, 2002c). In 2001, the maximum uranium concentration in sediment was 5.6

26 micrograms per gram, at background sampling location (RM-IOW). The maximum technetium-99

27 concentration was 592 becquerels per kilogram (16 picocuries per gram), at location RM-7 downstream

28 on Little Beaver Creek. Several inorganic substances and polychlorinated biphenyls are also monitored;

29 results of the monitoring indicate no major difference between upstream and downstream concentrations.

30 Polychlorinated biphenyls were not detected in sediments.

31

32 3.7.2 Floodplains

33

34 Floodplains are land areas adjacent to streams or rivers susceptible to being inundated by stream-derived

35 waters. The Federal Emergency Management Agency Flood Insurance Rate Map indicates that the 100-

36 year floodplain for Little Beaver Creek extends from the confluence with the Big Beaver Creek upstream

37 to the rail spur near environmental sampling point X-230J9. This is within the northwestern portion of

38 the DOE reservation. No portion of the floodplain for Big Beaver Creek is located within the reservation

39 boundary, as shown in Figure 3-12.

40

41 The DOE reservation has not been affected by flooding of the Scioto River. The highest recorded flood

42 elevation of the Scioto River in the vicinity of the site was 174 meters (570 feet) above mean sea level in

43 January 1913. The reservation occupies an upland area at an elevation of 200 meters (670 feet) above

44 mean sea level.

3-32
: i - -- '- .- s 7- tI

. : :. ' j '

Figure 3-12 Floodplains at the DOE Reservation at Piketon (ODNR, 2005).

- 3-33
ILI

1 3.7.3 Groundwater

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Five hydrogeological units are important for groundwater flow and contaminant migration beneath the

DOE reservation. These units are: Minford Clay, Gallia Sand, Sunbury Shale, Berea Sandstone, and

Bedford Shale. The upper two units form an aquifer in unconsolidated Quaternary aged deposits; the

lower three units form a Mississippian-aged bedrock aquifer. At the site, the hydraulic conductivities of

all of the units are very low (Geraghty & Miller, Inc., 1989). The most conductive unit is Gallia Sand

with a mean hydraulic conductivity of I meter per day- (3.4 feet per day) and a range of 0.03 to 46 meters

per day (0.1 IIto 150 feet per day); the Gallia Sand acts as the principal conduit for contaminant transport.

The next most permeable unit is the Berea Sandstone with a mean hydraulic conductivity of 0.05 meter

per day (0. 16 foot per day) and a range of 0.00 13 to 4.6 meters per day (0.0045 to 15 feet per day). The

average conductivity of Minford Clay, the shallowest unit, is estimated to be 7.0 x 10' meter per day

(0.00023 foot per day) in the upper zone', while the conductivity of the lower zone is about 0.0013 meter

per day (0.0042 foot per day). Average groundwater elevation is 196 meters (646 feet) above mean sea

level, which is approximately 7.3 meters (24 feet) below ground surface.

Within the upper portion of the bedrock aquifer, permeability is primarily produced by fractures. As

depth increases, the presence of fractures decreases, and permeability depends more on porosity, grain

size and shape, and packing arrangement (MMES, 1993). At greater depth, the Berea Sandstone is

probably more permeable than the shale units, which act as confining layers. The direction of

groundwater flow beneath the site is controlled by a complex interaction between the Gallia and Berea

units (Geraghty & Miller, Inc., 1989). The flow patterns are also affected by the presence of storm sewer

drains and by the reduction in recharge caused by the presence of buildings and paved areas. Groundwater

flow patterns in both the Gallia and Berea units are characterized by an east-west-trending groundwater

divide. The direction of groundwater flow is generally to the south in the southern sections of the DOE

reservation and to the north in the northern sections.

Vertical groundwater flow is generally downward from the Gallia to the Berea. In places where the

Sunbury Shale is absent, upward vertical gradients are observed.. The extent of the gradient is influenced

by the thickness of the Sunbury Shale. Where the Sunbury Shale is thick, the gradient is large. Three

main discharge areas exist for the groundwater system beneath the DOE: Little Beaver Creek to the north

and east, Big Run Creek to the south, and two unnamed drainages to the west (Geraghty & Miller, Inc.,

1989).

The DOE reservation draws its water from three well fields located along the Scioto River (see Figure

3-13). The well fields draw groundwater from the Scioto River buried aquifer and are located in the

Scioto River alluvium within the Scioto River floodplain. Recharge of the aquifer occurs from river and

stream flow as well as precipitation (annual average rainfall is 103 centimeters [40.7 inchesl). The

maximum potential production associated with the well fields is 49,000 cubic meters per day (1 3 million

gallons per day). The current production is approximately 19,000 cubic meters per day (5 million gallons

per day).

Groundwater quality has been studied extensively as part of DOE's environmental restoration activities.

Groundwater quality is monitored for radioactive and nonradioactive constituents in I I areas at and near

the facility using more than 400 wells. For monitoring and treatment purposes, the site was divided into

four quadrants roughly corresponding to groundwater flow patterns. The primary facilities for the

proposed ACP site are located in Quadrant I; two of the cylinder storage yards are in Quadrant IV. In

Quadrant I, groundwater discharges to Big Run Creek and to an unnamed Southwest drainage ditch. In

Quadrant IV, groundwater discharges to the Little Beaver Creek and to the East and North drainage

ditches.

3-34
Figure 3-13 Well Fields at the DOE Reservation at Piketon (USEC, 2005)

I Onsite, several areas of groundwater contamination have been identified. The main contaminants are

2 volatile organic compounds (mostly trichloroethylene) and radionuclides (e.g., uranium, technetium-99)

3 (DOE, 2002c). Data from the 2000 annual groundwater monitoring showed that five contaminants

4 exceeded primary drinking water standards at the DOE reservation: beryllium, chloroethane, americium,

5 trichloroethylene, and uranium. Alpha and beta activity also exceeded the standards (DOE, 2001 a, b).

6 The concentration of contaminants and the lateral extent of the plume did not significantly increase in

7 2001 (DOE, 2002c).

8

9 The primary facilities for the proposed ACP site are iocated approximately 60'to 90 meters (200 to 300

10 feet) north of the northern edge of the X-749 trichloroethylene plume. The proposed location for the new

11 cylinder storage yards north of Perimeter Road is between three groundwater monitoring areas: X-533

12 switchyard, X-734 landfills, and X-735 landfills. Based on 2002 monitoring results, the proposed ACP

13 facilities do not overlie contaminated groundwater. Various monitoring wells are located in the vicinity

14 of the proposed ACP facilities; however, no groundwater extraction wells, phytoremediation areas, or

15 groundwater treatment facilities are located within the footprint of the proposed ACP facilities.

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1 3.8 Ecological Resources

2

3 This section describes the ecological resources, including terrestrial resources (flora and fauna); rare,

4 threatened, and endangered species; wetlands; and other environmentally sensitive areas within the DOE

5 reservation at Piketon.

6

7 3.8.1 Flora

8

9 The vegetative cover in surrounding Pike County consists mostly of hardwood forests and field crops

10 (USEC, 2005). The terrestrial habitat types at the DOE reservation include (DOE, 1997a):

11

12 * Old field areas: Early successional stage of disturbed areas dominated by tall weeds, shade-intolerant

13 trees, and shrubs.

14

15 * Scrub thicket: Later successional stage covering old field areas dominated by dense thickets of small

16 trees.

17

18 * Managed grassland: Open areas actively maintained and dominated by grasses.

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20 * Upland mixed hardwood forest: Mesic to dry upland areas dominated by black walnut, black locust,

21 honey locust, black cherry, and persimmon.

22

23 * Pine forest: Advanced successional stage following scrub thicket. The overstory is dominated by

24 Virginia pine.

25

26 * Pine plantation: Nearly pure stands of Virginia pines.

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28 * Oak-hickory forest: Well-drained upland soils. White oak and shagbark hickory are the most

29 dominant of the oaks and hickories.

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31 * Riparian forest: Periodically flooded, low areas associated with streams. Dominated by cottonwood,

32 sycamore, willows, silver maple, and black walnut.

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34 * Beech-maple forest: Undisturbed areas dominated by American beech and sugar maple.

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36 * Maple forest: Dominated by sugar maple and other shade-tolerant species.

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38 The habitat types covering the largest area on the reservation are managed grassland (30 percent of total

39 area), oak-hickory forest (17 percent), and upland mixed hardwood forest (11 percent). The areas

40 covered by each habitat type are listed in Table 3-10 and shown in Figure 3-14. Several species of

41 animals have been observed within the DOE reservation property boundary.

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2 .

Table 3-10 Terrestrial Habitat Types at the DOE Reservation at Piketon

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Approximate Total Approximate No. Percent of -- - Habitat Type Area (hectares) of Communities Total Area

Managed grassland 446 Numerous b 30 _ ..__~.._........ .. _ _ ......... _._......... _ ........ _, ........... . _. .-. -; ..... -- _.;-- ---._-----.- -_.._4.____ _

Oak-hickory forest 256 14 17.2 ___ ... _._...__._....._._._._ .... ... .. . ....... ._ ..... 4......_ ..... ......... . ... ......... 

Old field 170 10 .1.4 ........................ _.; ..................................... 4.......... . .......

Upland mixed hardwood forest * - 162 20 10.9 _..__ ... ;.__;..____ .

Riparian forest .762 * . 10 . 4.2 _~~~~~~. ___...._ _ .. __.._..... _._..__....._ .......... ... _._ .... _ __._4._...____.... _._

Maple forest - * 52 7 3.5 . . . _. . _._. .__._..*. *...*.. __......_;.__._._ _ 4 _ _... _._..... __*._.,4. ........ ___.___. .

Scrub thicket 32 10 2.2

Pine forest 28 10 1.9 _~~~~~~~. __ . .... ..... _ A..__......; .. _-._.--____ ____ _-...... __ .. 4___._.___

Beech-maple forest 38,387 * I 0.1

Old white pine plantation with mixed 38,387 I 0.1

hardwoods . . *.

Notes:

' Total site area is 1,486 hectares (3,714 acres). Approximately 252 hectares (629 acres, 16.9 percent) of the total area are

covered by buildings, parking lots, and roads. The remainder of the total site area contains aquatic habitat.

b This habitat is present in many areas interspersed between buildings and paved areas across the plant site.

To convert hecatares to acres multiply by 2.47.

Source: DOE, 1997b.

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III

- 0 1'42 ACRES

I 0.31 ACRES 0.012 ACR I 0.031 RES CR

0.44? ACRES 2 34 Atom 0 \a40 ACRES 014 AtR £5 uI ( ' 

0.16 AC IR 4 ar;A\

\n \AO. T AACRES

0 NEWE FAIIS AC|tS

.22

IAT .. A A E f 40ACRES 0.O25 ACRES 02ASS

Ml WETLANDS

M NEW FACILITIESL

E EXISTING ACP FACILITIES

Figure 3-14 Habitat Areas and Wetlands on and Near the Proposed ACP Site (USEC, 2005)

1 The most common types of vegetation on the DOE reservation include managed grassland, followed by

2 oak-hickory forests, old field communities, and upland mixed hardwood forest, the sum of which make up

3 more than 69 percent of the total area of the reservation. The area in the southwest quadrant of the central

4 area, where the majority of the proposed ACP facilities would be located, is dominated by existing

5 infrastructure (buildings, structures, roads, and parking lots) and managed grasslands. Several wetland

6 communities are also present in the southwest quadrant (see Section 3.8.4). The area where the 745-H

7 Cylinder Storage Yard would be constructed contains managed grasslands, old fields, upland mixed

8 hardwood forest, and riparian forest. Wetlands are also located around the proposed 745-H Cylinder

9 Storage Yard and are associated with the tributaries bf Little Beaver Creek.

10

11 The flora associated with the wetlands adjacent to the activities associated with the proposed action

12 includes emergent vegetation including sedges, rushes, cat-tails, and various woody species (trees and

13 shrubs) tolerant of the saturated conditions of wetlands.

14

15 3.8.2 Fauna

16

17 A relatively high diversity of fauna (terrestrial and aquatic species) utilize the various terrestrial and

18 aquatic habitats at the DOE reservation. The reservation is within the home range of approximately 49

19 mammals, 114 bird species (year-round residents, winter residents, and migratory species), 11 reptile

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species, and six amphibian species (USEC, 2005). The most abundant mammals include the white-footed

mouse (Peromyscus leucopus), short-tailed shrew (Blarina brevicauda), opossum (Didelphis virginiania),

eastern cotton tail rabbit (Sylvilagusfloridanus), and white-tailed deer (Odocoileus virginianus).

Common birds found at the reservation include year-round residents, winter residents, and migratory

species. The species include red-tailed hawk (Buteojamaicensis); water birds such as the mallard (Anas

platrynchos) and wood duck (Aix sponsa); game birds such as wild turkey (Meleagris gallopavo); and

non-game birds such as nuthatches (Sitta sp.) and wrens (Troglodytes sp.). The most common of the 11

reptile'species and six species of amphibianis observed on the-site include the'ea'ster boxiturtle'

(Terrapene carolina), black rat snake (Elaphe obsolete), northern black racer (Coluber constrictor

constrictor), Anierican toad (Bufo americanus) and northern dusky salamander (Desmognathusfuscus)

(DOE, 1996a).

Common species occurring in open grassland areas like those at the proposed ACP site include eastern

cottontail (Lagomorpha Leporidae), meadow vole (Rodentia muridae), and eastern meadowlark

(Sturnella magna). Small wooded areas, such as those in the vicinity of the proposed ACP site, support

numerous woodland and forest edge species such as raccoon (Procyon rotor), gray squirrel (Sciurus

c'arolinensis), red-headed woodpecker (Melanerpes erythrocephalus), cardinal (Cardinalis cardinalis),

white-breasted nuthatch (Sitta carolinensis), and yellow-rumped warbler (Dendroica coronata). Species

that occur in the open grasslands and forest edges that are either actively managed (mowed) or'adjacent to

developed areas are tolerant of human activities and disturbances.

The aquatic habitats on the DOE reservation include the various holding ponds, intermittent streams, and

streams that flow from or through the reservation. The aquatic habitats downgradient of the activities

associated with the proposed action include Little Beaver Creek, the West Ditch, and the DOE Piketon

Tributary, all of which discharge into the Scioto River. Little Beaver Creek and the West Ditch are

designated warm water habitats. Warm water habitats are capable of supporting and maintaining a

balanced, integrated, adaptive community of warm water aquatic organisms having a diverse species

composition and functional organization. The aquatic habitat associated with Little Beaver Creek

supports good to exceptional fish communities downstream of the X-230-47 discharge fromr the DOE

reservation, and fair fish communities upstream due to intermittent stream flow (OEPA, 1998). The most

common of the 34 total fish species and four hybrids found in Little Beaver Creek are the Bluntnose

Minnow (Pimephales notatus), Central Stoneroller (Campostoma anomalum), Creek Chub (Semotilus

atromaculatus), Rainbow Darter (Etheostoma caeruleum), Spotfin Shiner (Cyprinella spiloptera), and

Striped Shiner (Luxilus chrysocephalus). The aquatic habitat associated with the DOE Piketon Tributary

is a limited resource water, which does not meet one or more of the warm water habitat characteristics.

and provides limited aquatic habitat.

3.8.3 Rare, Threatened, and Endangered Species

The potential existence of Federal and State rare, threatened, and endangered species as 'well as candidate

species in the vicinity of the DOE reservation was determined through a review of previously prepared

National Environmental Policy Act documents, reviewing the results of previous site-specific studies, and

through consultation with the Ohio Department'of Natural Resources, Division of Wildlife and Division

of Natural Areas and Preserves, and the U.S. Fish and Wildlife Service.

The review of the previous'documents 'and site-specific studies, as well as the consultations indicated that

the Indiana bat (Myotis sodalis) a Federally listed endangered species; the Carolina yellow-eyed grass

(Xyris diformis) and the sharp-shinned hawk (Accipiterstriatus), both Ohio State-listed endangered

species; the Virginia meadow-beauty (Rhexia virginica), an Ohio State-listed potentially threatened plant;

and the rough green snake (Opheodrys aestivus), an Ohio State-listed special interest species may occur

or have been found on the DOE reservation. Other species that have been identified in the region, but not

3-39
.~ Il

I on the DOE reservation include the Timber rattlesnake (Crotalus horridus), and the long-beaked

2 arrowhead (Sagittaria australis). Table 3-11 lists the threatened, endangered, rare, and species of concern

3 in the vicinity of the DOE reservation.

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Table 3-11 Federal and State Listed Endangered, Potentially Threatened,

and Special Concern Species near the DOE Reservation at Piketon

Status ' Category and Scientific Name Common Name Statu _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ F e d e r a l S t a t e

Mammals

Myotis sodalis * Indiana bat * E * E ..... _....... . ........ _.... ... ........ .... ........ _......... ... _.............. _................... . ..... .........

Birds

Accipiterstriatus Sharp-shinned hawk NL E ..... ........___ ..-....--. . -.-...-.- .__.-.. . ..- -.. -.- _. t. ....... _... I. -. -. .-1. ... *.i- ---- i--

Reptiles

Crotalus horridus horridus b Timber rattlesnake NL E

Opheodrys aestivus Rough green snake NL S _. . . ..... _..... .... .. ......... . . ....... _ ..~ _.... ._...... .. ... ...... ........_...._..

Plants

Rhexia virginica Virginia meadow-beauty NL P

Xyris diformis Carolina yellow-eyed grass NL . E

Sagittaria australis b Long-beaked arrowhead NL * T

Notes:

E = endangered; P = potentially threatened; S = special concern; T = threatened, NL = not listed.

b Not located on the DOE reservation; located in the region.

Source: DOE, 1993a; DOE, 1996b.

Past and current consultations with the U.S. Fish and Wildlife Service indicate that some of the riparian

areas on the DOE reservation may be suitable summer habitat for the Indiana bat. In 1994 and 1996,

DOE conducted an onsite surveys to identify suitable habitat and then conducted mist netting in those

areas to determine if Indiana bats were present. The surveys identified two potential riparian areas for

Indiana bats and the mist netting results documented four different species of bats in the two riparian

areas, but no Indiana bats were identified.

Past isolated sightings of State-listed species on the DOE reservation include the sharp-shinned hawk and

the rough green snake, but no recent sightings have been reported (DOE, 1993a; DOE, 1996b).

The Virginia meadow-beauty has been found near X-61 I a, a former sludge lagoon, and the Carolina

yellow-eyed grass has been tentatively identified at the X-61 lb sludge lagoon. The Virginia meadowbeauty is associated with the wetlands of the former sludge lagoon and its preferred habitat is on wet,

sandy soils, particularly in sandy swamps. The Carolina yellow-eyed grass was observed in 1994;

however, formal documentation of the species could not be performed as the grass was not in fruit or

flower. Carolina yellow-eyed grass prefers wet peaty or sandy soils typically found in marshes or bogs.

The Ohio EPA determined that two State endangered fish species and four State threatened fish species

exist near the DOE reservation, but are restricted to the Scioto River. Little Beaver Creek, the main body

of water running through the site, does not provide sufficient habitat to support threatened or endangered

species of fish. (OEPA, 1997)

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3.8.4 Wetlands

Wetlands are areas that are inundated or saturated by surface or groundwater at a frequency and duration

sufficient to support, and under normal circumstances do support, a prevalence of vegetation typically

adapted for life in saturated soil conditions (U.S. ACE, 1987). Wetlands generally include swamps,

marshes, bogs, and similar areas. The DOE reservation contains 45 wetlands (41 jurisdictional and 4 nonjurisdictional wetlands) totaling 14 hectares (34 acres), excluding retention ponds and streams (DOE,

2003b). Jurisdictional wetlands fall under the protection of Section 404 of the Clean Water Act, while

non-jurisdictional wetlands do not fall under Federal protection. The locations of these onsite wetlands

are shown in Figure 3-14. The majority of the wetlands are associated with wet fields, areas of previous

disturbance, drainage ditches, or wet areas along roads and railway tracks. Wetlands on the proposed site

primarily support emergent vegetation like cattail, great bulrush, and rush. Palustrine forested wetlands

occur along Little Beaver Creek (DOE, 1996c). Table 3-12 lists the jurisdictional wetlands, their size,

current status and location in relation to the activities associated with the proposed action.

Table 3-12 Wetlands on the DOE Reservation Associated with the Proposed Action

Hectares Location Associated With

Wetlands in proximity to proposed primary facilities

0.13 I West Perimeter Road Drainage swale __ ............. S............ ................ . . ............. ... _ .....

0.44 * West Perimeter Road . - Drainage swale _._ . . . . . . - - _._._-- .............. . ... ..... __..........__ . _ ...... .

0.78 I West Perimeter Road Drainage swale

0.11 X-2207 Parking Drainage ditch

_o rm e r_ G . s_ C e n t--fu g e s it e - ----- _._d W e t _ _ 01.3 Former Gas Centrifuge Enrichment Process site Wet field

0.115 * Former Gas Centrifuge Enrichment Process site Wet field

0.15 . Former Gas Centrifuge Enrichment Process site . Wet field ...... . . ...... ... . .... .... ........... .... .................. 

0.05 1 Former Gas Centrifuge Enrichment Process site I Wet field

19 .Fonner Gas Centrifuge Enrichment Process site *Wet field __ __ ------- ------------ _._.-_ . ...... __. _...... _. _ . .. _. ....... _.. _. .. ..___.. .____._._..__.

-0.10 *.Former Gas Centrifuge Enrichment Process site -- *Wefield . . _.__ ........... 4. _ ...... _.___ ...... .. _. _ .... _._ .... _._..._4.. _. _ ..... ...._ . .

0.10 .Former Gas Centrifuge Enrichment Process site -I -. Wet field

Wetlands in proximity to the two proposed cylinder storage yards

0.13 * North Access Road Drainage ditch - - . _..... .......... _4 ........ .

0.01 X-7456 Cylinder Yard - , Drainage ditch

0.07 . X-752 Warehouse . Man-made ditch

0.08 * X-747H landfill - . Radioactive area

Notes:

QI corresponds to the southwest quadrant of the DOE reservation; Q4 corresponds with the northwest quadrant of the

reservation.

To convert hectares to acres multiply by 2.47.

Although there are wetlands directly south and west of the proposed ACP site, as shown in Figure 3-14,

there are no wetlands directly on the proposed ACP site where there would be new construction and

operations. The wetlands near the proposed ACP site have poorly drained soils from previous grading

activities and receive the surface runoff from the surrounding landscape. Along the southern border of

the proposed ACP site is a large palustrine emergent wetland (1.3 hectares [3.2 acres]), composed

3-41
1 primarily of cattails, and one small wetland (0.12 hectare (0.3 acre)). To the west of the proposed ACP

2 site, across the Perimeter Road are six additional wetland areas, each with an area of approximately 0.5

3 hectare (I acre) or less. One extremely small wetland (0.05 hectare [0.13 acre]) is located farther to the

4 north of the proposed ACP site. As discussed above, drainage from the proposed site would exit via the

5 southwest drainage ditch via the Southwest Holding Pond in the vicinity of the wetlands to the south of

6 the proposed ACP.

7

8 The proposed ACP site in the southwest quadrant of the reservation includes five of the seven proposed

9 cylinder storage yards that would support the ACP. The remaining two proposed cylinder storage yards,

10 X-745G-2 and X-745H, would be located just north of the Perimeter Road. X-745G-2 is an existing yard,

11 while X-745H would require new construction prior to its use. Three isolated wetlands, each less than 0.5

12 hectare (I acre) and a number of small tributaries to Little Beaver Creek are located in the vicinity of

13 these two proposed cylinder storage yards. Drainage from these yards would exit via the X-230L North

14 Holding Pond, which discharges into Little Beaver Creek.

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3.8.5 Environmentally Sensitive Areas

There are no State or national parks, conservation areas, wild and scenic rivers, or other areas of

recreational, ecological, scenic, or aesthetic importance at the proposed ACP site or within a 1.6-

kilometer (I-mile) radius of the DOE reservation (ODNR, 2003)

3.9 Socioeconomic Conditions and Local Community Services

This section describes current socioeconomic conditions and local community services within the region

of influence of the proposed action. The region of influence is defined as a four-county area in southern

Ohio comprising Jackson, Pike, Ross, and Scioto counties. This region encompasses the area in which

workers are expected to spend most of their salary, and in which a significant portion of site purchase and

non-payroll expenditures from the construction, manufacturing, operation, and decontamination and

decommissioning phases of the proposed ACP are expected to take place. The counties included in the

region of influence were selected primarily on the basis of the current residential locations of United

States Enrichment Corporation and USEC workers at the DOE reservation in Pike County, where the

proposed ACP would be located. Currently, approximately 92 percent of these workers reside in the four

selected counties (USEC, 2005). Geographically, Ross, Jackson, and Scioto counties bound Pike County

to the North, East and South, respectively (see Figure 3-1).

3.9.1 Population Characteristics

The population in the region of influence is characterized in terms of the major population centers around

the proposed site, population growth trends, residential locations of current workers on the DOE

reservation, and significant transient and special populations. The extent to which surrounding

populations qualify as minority or low-income is discussed in the environmental justice evaluation in

Section 3.10.

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1 3.9.1.1 Major Population Centers

2

3 The major population centers in the region of influence are as follows (see Figure 3-15):

4

5 Piketon is the nearest residential center to the DOE reservation. Located in Pike County, this town is

6 approximately 6.4 kilometers (4 miles) north of the DOE reservation on U.S. Route 23. In 2000, the

7 population of Piketon was 1,907 (ODOD, 2003).

8

- 3-43
r- State Boundary

0 Population Centers

0 4 8 12 15 Kilometers

o 4 8 12 GMiesn

Figure 3-15 Population Centers in the Vicinity of the DOE Reservation

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* Waverly is the largest town in Pike County. Located 13 kilometers (8 miles) north of the DOE

reservation, the population of Waverly was 4,433 in 2000 (ODOD, 2003).

* The largest population center in the region of influence is Chillicothe, which is located in Ross

County. Chillicothe is 43 kilometers (27 miles) north of the DOE reservation, and had a population

of 21,796 in 2000 (ODOD, 2003).

* Other surrounding population centers include Portsmouth, which is in Scioto County and is 43

kilometers (27 miles) south of the DOE reservation. The population of Portsmouth was 20,909. in

2000 (ODOD, 2003).

* The town of Jackson is located in Jackson County and is 42 kilometers (26 miles) east of the DOE

reservation. In 2000, Jackson's population was 6,184 (ODOD, 2003).

- Figure 3-16 shows the population density surrounding the DOE reservation... . ., : . .I

'.'

Figure 3-16 Population Density Surrounding the DOE Reservation at Piketon (USEC, 2004a)

17

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1 3.9.1.2 Population Growth Trends

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3 Table 3-13 presents historic and projected populations in the region of influence and State as a whole. As

4 shown, the population of the region of influence was 212,876 people in 2000, having grown 4.3 percent

5 since 1990 (ODOD, 2003). This growth was marginally lower than the Ohio population growth rate of

6 4.7 percent in the same decade.

7

8 Table 3-13 Population in the Proposed ACP Region of Influence and Ohio in 1990, 2000, and 2010

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Average

Annual

Percent Percent

Growth Percent Growth

Rate 2010 Growth 2000-2010

Location 1990 2000 1990-2000 (Projected) 1990-2000 (projected)

Pike County 24,249 27,695 1.3 29,766 14.2 7.5 . . -. ------ .- .- ----------------. ........

Scioto County 80,327 * 79,195 1 -0. 1 78,823 -1.4 -0.5

Jackson County 30,230 32,641 0.8 34,022 8 4.2 _. _._._..-...... -..-. ,4_ ...... 4 .__. ..... _.... . _. .... __ .... ;_.._.4.. __.. _; __._.

Ross County 69,330 73,345 0.6 78,380 5.8 6.9 ---------------- *---t-------*---- *4. --------- *--t~-------------t-*--------------------------------*---- --------

Region of Influence 204,136 212,876 0.4 220,991 4.3 3.8

Ohio 10,847,120 11,353,140 0.5 1 11,666,850 1 4.7 . 2.8

17 Source: ODOD, 2003.

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During the 1990s, each of the counties in the region of influence, with the exception of Scioto County,

experienced a growth in population. Pike County recorded a population growth rate of 14.2 percent

between 1990 and 2000, while Jackson and Ross counties grew by 8 percent and 5.8 percent,

respectively, in the same decade. The growth rates for these three counties exceeded Ohio's overall

growth rates in that period. In contrast, Scioto County registered a marginal decline (-1.4 percent) in

population between 1990 and 2000.

The area population is expected to increase by 3.8 percent by the year 2010, compared to a projected

overall Ohio growth rate of 2.8 percent in the same period. All counties in the region of influence, except

for Scioto County, are projected to experience positive population growth between 2000 and 2010.

3.9.1.3 Residential Locations of Workers

In January 2004, there were 1,223 United States Enrichment Corporation and USEC workers employed at

the DOE reservation (reflecting the current cold standby status) (USEC, 2005). Of these workers,

49 percent live in Scioto County, 22 percent live in Pike County, 12 percent live in Ross County, and

10 percent live in Jackson County (USEC, 2005). The remaining eight percent of United States

Enrichment Corporation and USEC workers live outside the region of influence (USEC, 2005j.

3.9.1.4 Significant Transient and Special Populations

In addition to the residential population, there are institutional, transient, and seasonal populations in the

area. Institutional populations include school and hospital populations and are described in Sections

3.9.3.2 and 3.9.3.3.

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The transient population consists of visitors participating in various seasonal, social, and recreation

activities within the local area. Seasonal populations are also present. For example, usage of Lake White

State Parrk, located approximately 9.7 kilometers (6 miles) north of the DOE reservationi, is occaisionally

heavy and concentrated on the 37 hectares (92 acres) of land closest to the lake. Most of the land

surrounding the lake is privately owned. The 136-hectare (337-acre) Lake White offers recreation (i.e.,

boating, fishing, water skiing, and swimming). There are 10 non-electric campsites for primitive

overnight camping (USEC, 2005). These populations are likely to be unaffected by the proposed action

due to the distance from the proposed ACP.

3.9.2 Economic Trends and Characteristics

This section describes employment in the region of influence, and at the DOE reservation in particular. It

also describes per capita income in the region.

3.9.2.1 Employment in the Region of Influence

The past decade has seen a slight employment shift from the government, construction, and farm sectors

towards the service, wholesale and retail trade, and manufacturing sectors within the region of influence.

The service sector provides the highest percentage of employment in the region, at 24.7 percent, followed

closely by the wholesale and retail trade with 21.7 percent, manufacturing with 17.9 percent, and

government enterprises with 16.6 percent (BEA, 2002a).

Tables 3-14 through 3-17 summarize county-specific trends in employment in the region of influence.

Pike County shows a substantially higher rate of manufacturing employment than other counties; and

Scioto County shows the highest rate of services employment.

--Table 3-14 Employment in Pike County by Industry in 1990 and 2000

T Y l

No. of People

Employed

in 1990

Percentage

of County

Total -

No. of People.

Employed

in 2000 -

Percentage

of County

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Sector -

Growth Rate

1990-2000

Services 1,666 16.5 2,410 16.1 44.7

Wholesale and Retail 1,498 15.6 2,450 164 55.3

Trade

Government and 1,556 15.4 1,859 12.4 19.5

Government Enterprises __ _ _____ -~~.---.-.4.-............... .-.-- 4''' '-----4. -Ae-''-^-'' '-''

Manufacturing 3,567 35.3 5,748 38.5 61.1

Construction 483 4.8 869 5.8 79.9

Finance, Insurance, and 244 24 556 3.7 127.9

Real Estate ___..._.;_. . ....... 4,_ ._... .. ..... +.; ~ ._.*.** ... ~* * * . ____.... 4** .. *___. _._;...........__. __

Transportation and Public 365 3.6 501 - 3A 4 37.3

Utilities . . . . . .............. ....

Farm Employment * 548 54 . 551 37 0.5 ... _.___..______ ---------... _._.... .. . ... _.._._._....;_.._...........

Mining - - * 32 0.3 Not Available Not Available Not Available . ..... .... ................. ........................

Other Sectors 52 0.5 - Not Available Not Available Not Available ------ --------- . ..... . .. -- - -- - -- . . .......... . .............. __. ................ ....

Total . - 10,091 100 14,944 100 . 8.1

Source: BEA, 2002a.

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Table 3-15 Employment in Scioto County by Industry in 1990 and 2000

fPercent

No. of People Percentage No. of People Percentage Growth

Employed of County Employed of County Rate

Sector [ in 1990 Total in 2000 Total j1990-2000

Services 7,810 28.2 10,134 1 31.1 1 29.8 . ..................................... 4,....... - . .....-----------.. 4..- .. .........

an FealTrade 6,739 2437,816 24 1

Government and Government 5,370 19.4 1 6,120 18.8 14

Enterprises .-.-.-.-..-.--------. * 4- - - . --.- -- ...... ............ ..... ...... . ... . - .. .. . *. ............. .

Manufacturing 2,299 8.3 2,714 I 8.3 1 18.1

C. onstruction . 1,640 5.9 1,861 5.7 13.5

Finance, Insurance, and Real 1,333 4.8 1,367 4.2 2.6

Estate

Tasortation and Public 1,443 5.2 1,390 4.3 -3.7

Utilities .-.-. .--------......... .-.-. ............ ................. ............ ... 

Farm Employment 844 3. 823... 2.5 -2.5

Mining 43 0.2 23 0.1-4. . . ..... .. ... . .. . . . . . .. 4 . .. . . - ---- . ---- .. --.. . ~ .. . . .. . . .. . . .. 4 . .. . . .

Other Sectors . 189 0.7 1 289 I 0.9 1 52.9 T .. ...- .......................-..- ,-...- .---- .----- .--- - .--- --- - ..... I ... ..-. ..... . .. , ....---- - - .-.--------- .

Toai7,710 100 32,537 100 17.4

Source: BEA, 2002a.

Table 3-16 Employment in Jackson County by Industry in 1990 and 2000

1 Percent

No. of People Percentage No. of People Percentage Growth

Employed of County Employed of County Rate

Sector in 1990 Total j in 2000 Total 1990 2000

Services 2,481 21.6 2,867 20.4 15.6

WhZolesal and Retail 2,472 21.5 3,196 22.7 29.3

Trade

Government and 1,455 12.7 1,585 11.3 8.9

Government

Enterprises .~. . ..... .... . ... . .... . ... . - - - ------- ..........

Manufacturing 26123.2 4,027 28.6 51.3 -----.--- --. . . . . ... .. 4 . . . .

Cntuton 5648 Not Available Not Available Not Available .. . . .. ... . . .. ... . . .. ... . ... ... . . ...- ..- ----.. .. --. ---- ---.. -. . . .. .... .. . . . . .

Finance, Insurance, 467 4.1 714 5.1 52.9

and Real Estate

Transportation and 500 4.4 570 4.1 14

Public Utilities 0 . ........ .. i. .... .... ......... ....... ........... . ......... - - --.----.-.----------.-.--

F yr e E t6 m l 46 736 5.2 6.1 .. . .. .. . . . . . . . . . . 4 . . . . . . . . . . . . . . .4 . ..* ... . . ... . ..- .- .---- 9 ,-.--.-..-----.------------.4 .-----

Mining 149 1.3 362 2.6 143 ............... . ...... . . . ..... - ---------.......... . ............... *.... . ..........

Other Sectors 48 0.4 Not Available Not Available Not Available . .............-...... .. ...... ...........------------------------------.------ - ------ - .

Total 11,483 100 14,057 100 22.4

Source: BEA, 2002a.

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Table 3-17 Employment in Ross County by Industry in 1990 and 2000

j T ~Percent

No. of People Percentage No. of People Percentage Growth

Employed of County Employed of County Rate

Sector in 1990 Total in 2000 Total 1990-2000

Services 6,191 21.7 8,763 25.2 41.5 go...~~~. ..... ._ ........ _._ .......... _. _--__----------------_-- .... _. ........ _. .A__.__,...

Wholesale and ' . - 5,998- 21 7,855 . 22.6 31

Retail Trade

Government and 6,052 21.2 6,762 194 11.7

Government

Enterprises

Manufacturing 5,395 18.9 5,119 147 -5.1

Construction 1,401 4 9 1,728 5 23.3 .. .. -..... .-.---.....

Finance, Insurance * 1,001 3 5 1,378 4 37.7

and Real Estate _.__ .......... . ___ ..... _ . ........ ...... _______ _.. _._

Transportation and 1,055 3.7 1,978 5.7 87.5

Public Utilities

Farm Employment 1,218 4.3 1,226 3.5 0.7 __ ... _._.............. . ..............

Mining 40 0.1 Not Available . Not Available Not Available .. _ , . . t , . - .-.-.. _.__..._----------a---- -*--tOther Sectors 170 0.6 Not Available Not Available I Not Available

Total 28,521 100 34,809 -100 22.1

Source: BEA, 2002a.

The unemployment rate in the region of influence is higher than for the State as a whole. The regional

unemployment rate, which was 7.8 percent in 1998, was 7.7 percent as of 2002, as shown in Table 3-18.

*The average unemployment rate for the State of Ohio was 5.7 percent in 2002, up from 4.3 percent in

1998 (ODOD, 2003).

Table 3-18 Unemployment Rates (percent)

Area | 1998 | 2002

Jackson County 7 7.9 ---

Pike County 8.8 * 8.9

Ross County 5.8 6.2 ,,,__......._... 4.............. -....... --'

Scioto County 9.5 7.8

Region of Influence Total,: - : * 7.8 - * 7.7 _. ..... _ ..._......_w_._ ... _z_....... ..

Ohio - __- : '4.3 : 5.7-

Source: ODOD, 2003.

The region of influence experienced stable growth in employment levels in recent years. Employment

growth outpaced labor force growth, increasing from 86,900 in 1998 to 88,500 in 2002, for a growth rate

of 1.8 percent forthat period (ODOD, 2003). The labor force grew from 94,100 in 1998 to 95,500 in

2002, for a growth rate of 1.5 percent for that period (ODOD, 2003).

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I Although the overall region of influence unemployment rate decreased between 1998 and 2002, there are

2 cross-county differences in employment trends within the region. Only Scioto County experienced a

3 decline in unemployment levels between 1998 and 2002. Jackson, Pike, and Ross counties registered

4 increases in unemployment rates in the same period.

5

6 3.9.2.2 Reservation Employment

7

8 As reported in Section 3.9.1.3, United States Enrichment Corporation and USEC employed a total of

9 1,223 workers at the site, as of January 2004. This number is approximately I I percent of the total

10 individuals working within Pike County. In addition, the DOE Bechtel Jacobs Company, LLC,

11 subcontractors, and the Ohio Army National Guard employ an additional 374 workers at the DOE

12 reservation (USEC, 2005).

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3.9.2.3 Income

Table 3-19 summarizes personal income data for the region of influence for the years 1990, 2000, and

2002.

Table 3-19 Personal Income in the Region of Influence 1990, 2000, and 2002

Percent Nominal

Income

Growth Rate

Location and Type of Income 1990 2000 1990-2000 2002

Jackson County . .3. . __. _._.__._.......... .... .... .......... . .... _....1. ......... . ... _.._..._.. ....... . .... ;._..... ........ . ... .___._

Total Personal Income (thousands of 2002S) 385,323 632,003 64 663,557

Personal per Capita Income (2002$) 12,743 19,362 52 20,112

Pike County~~~~~...... . _._.__ . ............ _....... ._ ...... .. _.. ..... . ._._.... . ...... _._; ...... ........ . ...... ..... . . ... . . ......... __..... _. _ __

Total Personal Income (thousands of 2002$) * 300,851 3 547,173 82 574,226

Personal per Capita Income (2002$) 12,355 19,714 60 20,491

Ross County _ _. .. _._ ..... _ _..... ... . ..... ____... . _;.. __ ... _. ,....... _ ._ . _. _ ....... ....... __

Total Personal Income (thousands of 2002$) 977,594 , 1,631,847 67 1,711,909

Personal per Capita Income (2002$) 14,086 22,219 58 23,015

Scioto County . .

_.............. ..._ ___ .... . _*-----------.--. ............ t- - - . . ... .-..-.-

Total Personal Income (thousands of 2002$) , 1,030,961 , 1,558,985 51 * 1,631,353

Personal per Capita Income (2002$) 12,827 . 19,716 54 20,890

Total Region of Influence .. ~. . _._..... __. _ ._._........ ....... . ....... .... _. _..._ _.............. __ .. _;.... _..._; _......_

Total Personal Income (thousands of 2002$) , 2,694,729 4,370,008 62 4,581,045

Average Personal per Capita Income (2002$) . 13,003 20,252 . 56 21,127

Source: BEA, 2002b.

Key conclusions that can be drawn from these data include:

* Per capita income in the region was $20,255 in 2000. This is 28.2 percent lower than the State of

Ohio's average per capita income of $28,208 in the same year (BEA, 2002b).

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* Per capita income in 2000 in the region of influence recorded a 56 percent nominal increase (not

adjusted for inflation) from the 1990 level of $13,003 (BEA, 2002b). After adjusting for inflation,

this equates to a 26.6 percent increase in real income in the region over that period.

* Per capita incomes in the region of influence vary significantly from one county to the next, ranging

from a low of $20,449 in Jackson County to a high of $23,123 in Ross County in 2002 (BEA, 2002b).

For the purposes of quantifying socioeconomic impacts in Section 4.2.10, the analysis uses an average per

capita income estimate of $25,317 (2004$) (USEC, 2005).

- 3.9.3 Housing Resources and Community and Social Services

This section describes housing and social services in the region, including: schools; hospitals and nursing

homes; law enforcement, fire fighting, and other public services; and infrastructure and utilities. The

social service centers located within 8 kilometers (5 miles) of the DOE reservation are shown in Figure

3-17.

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Figure 3-17 Social Service Centers within

8 Kilometers (5 Miles) of the DOE Reservation

at Piketon (USEC, 2005)

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1 3.9.3.1 Housing

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3 Detailed housing characteristics for the region of influence are presented in Table 3-20. Between 1990

4 and 2000, all four counties registered an increase in the total number of owner-occupied and rental

5 housing units (ODOD, 2003). Vacancy rates among rental units rose in each county during this period.

6 As of 2000, there was an 8.6 percent vacancy rate among rental units (amounting to 1,963 vacant rental

7 units) and an 1.8 percent vacancy rate among owner occupied units (amounting to 1,048 vacant owner8 occupied units) in the region (U.S. Bureau of the Census, 2000). Housing density in the region of

9 influence averages 106.7 units per square kilometer (41.2 units per square mile), and the median value is

10 $74,550 (ODOD, 2003). In contrast, the Ohio State average housing density is 302.5 units per square

11 kilometer (116.8 units per square mile), and the median value is $103,700 for the State (ODOD, 2003).

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13 Table 3-20 Region of Influence Housing Characteristics, 2000

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Percent

Vacancy Percent

Number of Rate Vacancy Housing Density

Owner- Owner- Number of Rate (units per square Median

Occupied Occupied Rental Rental kilometer/units Value

Location Units Units Units Units per square mile) (2000S)

Jackson County 9,328 1.7 3,291 8.6 85.7/33.1 $70,400 .._......._.......__... ...... ---------------- . _ _ ._............ ----------------- ------------ .......... ........... _......... ... _...._......

Pike County 7,314 2 3,130 . 8.5 68.1/26.3 $77,400 ... ~~~~~~~~~~~~~~~~~. . __.....__ ..... _......... _...._. _ . .__..._.. _ ..... . ..... _.. _...._. _._._...._.

Ross County 19,958 1.8 7,178 7.5 109.6/42.3 $87,000 .. _ __ . _._ . _ 4~~~~ -.---.---- *-o---*-*-*- *-+----* *t

Scioto County 21,646 1.9 9,225 9.5 144.0/55.6 $63,400 - ---------------------------- ..... ...... ........................ 

Region of

nfeneTtl 58,246 1.8 22,824 8.6 106.7/4 1.2 $74,550

22 Source: U.S. Bureau of the Census, 2000 and ODOD, 2003.

23

24 3.9.3.2 Schools

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26 The two school systems in the area are the Pike County Schools and the Scioto County Schools.

27 However, only Pike County has school facilities within 8 kilometers (5 miles) of the DOE reservation:

28 one private school that includes preschool through grade 12; two elementary schools, both of which

29 include a preschool program; one junior high school; and one high school. The combined enrollment for

30 the school year 2003-2004 is approximately 2,437 (USEC, 2004b). The total school population within 8

31 kilometers (5 miles), including faculty and staff, is 2,718 (USEC, 2005). The proximity of these schools

32 to the DOE reservation and their enrollments are shown in Figure 3-17.

33

34 Four facilities within 8 kilometers (5 miles) of the DOE reservation provide daycare or schooling for

35 preschool-aged children and after-school care for school-aged children. One facility has 114 registered

36 children and is located in Piketon. The children in the remaining three facilities are consolidated in the

37 numbers provided in the above paragraph (USEC, 2004b). The locations of these facilities are shown in

38 Figure 3-17.

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40 Table 3-21 presents school district data for the region of influence (ODOD, 2003). It is apparent that the

41 student-to-teacher ratio in Jackson, Ross, and Pike counties is higher than the Ohio average.

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Table 3-21 School District Data for the Region of Influence in 2000

Location Number of Teachers - Student-to-Teacher Ratio

Jackson County 330 17.1

Pike County 364 15

Ross County 828 15.1

Scioto County 895 -. 14.8 Sto...... ___. . ..... . ...... 

State of Ohio . 117,955 . 14.8

Source: ODOD, 2003.

3.9.3.3 Hospitals and Nursing Homes

Pike Community Hospital is the hospital closest to the DOE reservation, and is located approximately 12

kilometers (7.5 miles) north of the DOE reservation on State Route 104 south of Waverly. USEC's onsite

health protection program provides services for individuals to meet regulatory requirements and to

maintain a high level of employee health. The X-1007 Fire Station maintains a first aid room and

provides ambulance service for emergency conditions. Pike Community Hospital will provide healthcare

services to ACP workers (USEC, 2005). The facility has 66 licensed beds. No other acute care facilities

are located in Pike County. Adena Health Center operates as an urgent care facility, located

approximately 12 kilometers (7.5 miles) north of the DOE reservation. Piketon and Waverly Family

Health Centers, both located north of the DOE reservation, are also available during working hours for

minor emergencies. The locations of these facilities are shown in Figure 3-17.

Three licensed nursing homes are located in the Piketon area, an additional one is in Wakefield, and

another in Beaver. Four of these five nursing homes are located within 8 kilometers (5 miles) of the DOE

reservation. The largest of these facilities is a 193-bed facility in Piketon. The combined licensed

capacity of the facilities neighboring the DOE reservation is approximately 375. Figure 3-17 depicts

these facilities and shows the number of beds per facility.

Table 3-22 provides data on the number of physicians, level of service (number of physicians per 1,000

persons), and hospitals in the region of influence counties in the year 2000. These data indicate that all

counties in the region had a lower level of service than the Ohio average, which is 3.3 physicians per

1,000 persons (ODOD, 2003).

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I Table 3-22 Physicians and Hospitals in the Region of Influence in 2000

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Physicians Hospitals

County Number of | Level of Number of Number of

CnPhysicians | Service Registered Beds _ _ _ _ _ __ _ _ _ _ _H ospitals B d

Jackson 27 0.83 1 I 24 ..... ....................... .............. .................................. .

.Pike. ... 28 .ik 28 .:9 ............ .. . .... ...... .0.99............ . ...... ----------- ------- I . .. ..... : 66-

Ross 135 1.84 . . I . 262 . ._.__..................... ............. 4.**........*. .. 4... . .. .. 4 **~~~*.*.** *........_. ...... _ .................

Scioto 139 1.76 1 421

Notes:

' Level of service denotes the number of physicians per 1,000 persons.

Source: ODOD, 2003.

3.9.3.4 Law Enforcement, Fire Fighting, and Other Public Services

Several State, county, and local police departments provide law enforcement in the region of influence.

Pike County, which is where the DOE reservation is located, has 19 officers and will provide law

enforcement services to the site. Other counties in the region have a total of 101 full-time officers, 16 in

Jackson, 32 in Ross, and 53 in Scioto (FBI, 2000).

According to the U.S. Fire Administration's National Fire Department Census Database, there are 43

career and volunteer fire departments in the region of influence (USFA, 2005). The career fire

departments include Portsmouth Fire Department, which has three engine houses comprising four

engines, two ladders, and one rescue vehicle (PFD, 2005). In addition, the Chillicothe Fire Department

consists of three units, each with 13 firefighters; three emergency medical service vehicles; and one 100-

foot platform (CFD, 2005).

3.9.3.5 Infrastructure and Utilities

Historically, there has been very little overlap between utilities providing services to communities in the

region of influence and those supporting the Portsmouth Gaseous Diffusion Plant. With the exception of

natural gas and landfill services, dedicated utilities were developed to support the needs of the Portsmouth

Gaseous Diffusion Plant. These dedicated utilities are expected to have more than adequate capacity to

continue serving the ACP under the proposed action. Currently, there is a 5-centimeter (2-inch) diameter

natural gas supply line to the Portsmouth Gaseous Diffusion Plant; the proposed action will not require

augmentation of this supply line. For most utilities, therefore, the communities in the region of influence

and the proposed action draw on a mutually exclusive set of suppliers. For this reason, no further details

are provided on the capacity and structure of utility markets in the region of influence.

The proposed action is likely to share landfill facilities with the communities in the region of influence.

The Pike County landfill is expected to be the primary endpoint for sanitary/industrial waste disposal and

the Rumpke Beach Hollow landfill will be an alternative destination for these wastes. The project

capacities and use of each are presented in Table 3-23.

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Table 3-23 Capacity of Landfills in the Region of Influence

Landfill | Capacity | Space Municipalities Using Landfill

Pike County Landfill 1,800 metric tons/day :i 34 more years Jackson, Scioto, Pike, Lawrence, Adams, - Brown, Highland and Ross

-Runpke Beach Hollow' 240 metric tons/day: 82 more years Jackson, Wellston and Oak Hill

Landfill

Notes:

To convert metric tons to tons multiply by 1.1.

Source: USEC, 2005.

3.9.4 Tax Structure and Distribution

The average property tax rates for Ohio cities are divided into three separate classifications: Class I Real

(residential and agricultural), Class 11 Real (commercial, industrial, mineral, and public utility), and Class

m Tangible Personal (general and public utility). For Waverly, in Pike County, the rate is $0.074i2 per

$1,000 for all three classifications; for Portsmouth, in Scioto County, the rate is $0.06663 per $ 1,000 for

all three classifications; for Jackson, in Jackson County, the rate is $0.04864 per $1,000 for all three

classifications; and in Chillicothe, in Ross County, the Class I rate is $0.05401, the Class II rate is

$0.05386,- and the Class III rate is $0.05405 per $ 1,000 (Ohio Department of Taxation, 2003).

The State of Ohio has a graduated personal income tax. For example, thetax rate for incomes ranging

from $20,000 to $40,000 is $445.80 plus 4.5 percent of excess over $20,000. For incomes ranging from

$40,000 to $80,000, the tax rate is $1,337.20 plus 5.2 percent of excess over $40,000. And for incomes

ranging from 80,000 to 100,000, the tax rate is $3,417.60 plus 5.943 percent of excess over $80,000.

Ohio also has a 6.0 percent sales tax rate that was raised temporarily from 5.0 percent on July 1, 2003,

with the present rate authorized until June 30, 2005 (Ohio Department of Taxation, 2003). In addition to

the State sales tax, each county in Ohio has a county sales tax. Jackson, Ross, and Scioto Counties have a

county sales tax rate of 1.5 percent and Pike County has a county sales tax rate of 1.0 percent (Ohio

Department of Taxation, 2003).

3.10 Environmental Justice

On February 11, 1994, the President signed Executive Order 12898 "Federal Actions to Address

Environmental Justice in Minority Populations and Low-Income Populations," which directs all Federal

agencies to develop strategies for considering environmental justice in their programs, policies, and

activities. Environmental justice is described in the Executive Order as "identifying and addressing, as

appropriate, disproportionately high and adverse human health or environmental effects of its programs,

policies, and activities on minority populations and low-income populations." On December 10,1997,

the Council on Environmental Quality issued "Environmental Justice Guidance Under the National

Environmental Policy Act" (CEQ, 1997). The Council developed this guidance to "...further assist

Federal agencies with their National Environmental PolicyAct procedures." As an independent agency,

the Council's guidance is not binding on the NRC; however, the NRC has committed to evaluate

environmental justice issues as part of its National Environmental Policy Act reviews. To guide such

evaluations, the NRC has issued a final policy statement on the "Treatment of Environmental Justice

Matters in NRC Regulatory and Licensing Actions" (69 FR 52040; August 24, 2004) and environmental

justice procedures to be followed in NEPA documents prepared by the NRC's Office of Nuclear Material

Safety and Safeguards (NRC, 2003).

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I This section summarizes data from the 2000 U.S. Census (specifically the 2000 decennial U.S. Census

2 Summary File 3) on minority and low-income populations within an 80-kilometer (50-mile) radius of the

3 proposed ACP site. This area includes a total of 191 census tracts, including 139 in Ohio, 38 in

4 Kentucky, and 14 in West Virginia.

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6 To determine if environmental justice will have to be considered in greater detail, the NRC staff

7 compared the percentage of minority and low-income populations in Census tracts in the area being

8 assessed to the State and county percentages. If the minority or low-income population in a given tract

9 exceeds 50 percent or is significantly greater than the State or county percentage, environmental justice

10 will have to be considered in greater detail. Generally, the NRC staff considers differences greater than

11 20 percentage points to be significant. The following sections summarize the results of this analysis

12 within 80 kilometers (50 miles) of the proposed ACP, first for minority populations, and then for low13 income populations. This summary is supported by detailed tables that provide the results for each

14 Census tract in Appendix F.

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16 3.10.1 Minority Populations

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18 The Council on Environmental Quality guidelines on environmental justice recommend "minority" being

19 defined as members of American Indian or Alaska Native, Asian or Pacific Islander, Black non-Hispanic,

20 and Hispanic populations (CEQ, 1997). The 2000 Census includes the data necessary to identify minority

21 populations, according to both race and Hispanic origin (U.S. Census Bureau, 2002), and identifies

22 individuals claiming multiple racial identities, up to six races. To remain consistent with the Council's

23 guidelines and NUREG-1748, the phrase "minority population" in this Draft EIS refers to persons who

24 identified themselves in the 2000 Census as follows:

25

26 * Partially or totally Black (including Black or Negro, African American, Afro-American, Black Puerto

27 Rican, Jamaican, Nigerian, West Indian, or Haitian);

28 * American Indian or Alaska Native;

29 * Asian;

30 * Native Hawaiian or other Pacific Islander;

31 * Multiple Races; or

32 * Other Race.

33

34 In accordance with NUREG-1748, individuals identifying themselves as White and a minority were

35 counted as that particular minority group. In addition, for the purpose of this Draft EIS, minority

36 populations were taken to include White individuals of Hispanic origin. To avoid double counting,

37 tabulations include only White Hispanics since the above racial groups already account for non-White

38 Hispanics. Therefore, the minority population considered in this environmental justice evaluation

39 consists of all non-White persons (including those of multiple racial affiliations) plus White persons of

40 Hispanic origin.

41

42 Figure 3-18 identifies Census tracts within a 80-kilometer (50-mile) radius of the proposed ACP site that

43 contain minority populations in excess of the criteria outlined above. As shown in the figure, there are

44 two Census tracts in which minority populations either exceed 50 percent and/or are significantly greater

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=1

= State Boundary

= Census Tract Boundary

= Minority Census Tract

1 Low Incorne Census Tract

o 1O 20 30 40 Klometrs

0 10 20 30 40MWes

Figure 3-18 Census Tracts with Minority and Low-Income Populations within an 80-Kilometer

(50-Mile) Radius of the Proposed ACP Site

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than the State or county percentage. These tracts and their locations relative to the proposed ACP site are

detailed in Table 3-24.

4 3.10.2 Low-Income Populations

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In accordance with the Council on Environmental Guidelines and NUREG-1748, this environmental

justice analysis identifies low-income populations as those falling below the statistical poverty level

identified annually by the U.S. Census Bureau in its Series P-60 reports on income and poverty (NUREG1748, Appendix C, p. C4). Following the Office of Management and Budget's Statistical Policy

Directive 14 (OMB, 1978), the U.S. Census Bureau uses a set of income thresholds that vary by family

size and composition to define who falls below the poverty threshold. If the total income for a family or

unrelated individual falls below the relevant poverty threshold, then the family or unrelated individual is

classified as being "below the poverty level."

Table 3-25 shows the Poverty Thresholds in 2004 by family size and number of related children under 18.

For example, in 2004, the poverty threshold for a family of three with one related child younger than 18

was an annual income of $15,205, while the poverty threshold for a family of five with one related child

younger than 18 was an annual income of $23,838.

Table 3-24 Census Tracts Exceeding Minority Criteria

Census Tract C s cn County, SApproximate Distance and Direction State fo h O eevto from the DOE Reservation

39141955602 Ross, Ohio * 40 kilometers to the north _ __~~~~ . *-------t.-.....-.-.. -.........-.---.- .. - _j_.-. -_._..__.- .__...._____ ..

39145993700 * Scioto, Ohio * 28 kilometers to the south

Notes:

I See Appendix F for more detail.

km = kilometer

To convert kilometers to miles multiply by 0.62.

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Table 3-25 Poverty Thresholds in 2004 (Annual Income in $)

- _Related Children Under 18 years

- Weight td - - Eight

Size of Family Average | - or

Unit Threshold None One -Two Three Four Five Six Seven More

One person 96,43

Under 65 years . 9,827 9,827

65 years and over 9,060 9,060

Two people 12,335

Householder under

65 y 12,714 12,649 13,020

Householder 65 H 11 429 11,418 12,971

years and over

Three people 15,071 14,776 15,205 15,219 _ -. ---------------- ---- --- - - - -.. __.._..----

Fourpeople 19,311 19,484 19,803 19,157 19,223

Fivepeople -. 22,837 23,497 23,838 23,108 22,543 22199

Sixpeople 25,791 27,025 27,133 26,573 26037 25,241 24768

Sevenpeople 29,304 31,096 31,290 30,621 30,154 29,285 28,271 27,159. . ...... ___.._____t~~~~~~~~~- -*- ---- ---*-------t-- ...........-.-.- e-- -----^-------- ---------- ----- -- -------.... _ _A__

Eightpeople 32,430 34,778 35,086 34,454 33,901 3311 32119 31,082 30,818 ...____....,_.____._.....I'.___.;.._.__;.1._.__4...-I...........-*;.*..-.-*.-.4.;.*-.-.*-4..4--*---;--------------.

Nineormore 38,659 41,836 42,039 41480 41,010 40,240 39,179 38,220 37,983 36,520

people _ . . . '_..

21 Source: U.S. Census Bureau, 2005a, b.

22

23 Figure 3-18 identifies Census tracts within an 80-kilometer (50-mile) radius of the proposed ACP site that

24 contain low-income populations in excess of the threshold criteria. There are 18 Census tracts in which

25 low-income populations either exceed 50 percent and/or are significantly greater than the State or county

26 percentage. These 16 tracts and their locations relative to the proposed ACP site are detailed in Table

27 3-26.

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Table 3-26 Census Tracts Exceeding Low-Income Criteria a

Cess rctCuny SaeApproximate Distance and Direction Censs Tr ct ount, Sttefrom the DOE Reservation

21019030300 Boyd, Kentucky 66 kmn to the southeast .... ... ... --..- ------- --.-----.... .. . -...-... . .... . .- ...... ....................-. .. .. -...........

21690400 1 Fleming, Kentucky 78 km to the southwest . - . ---------- --- --------.. . . .. . - . .. . . - . . . . . . . . . . . . . . . . . . .. . . . . . . ....... ... ..* . .. . . . . . .

21135990100 1 Lewis, Kentuck 32 kmn to the southwest2113599.. I i~ 0200 1 Lewis, Kentucky . 50 km to the southwest .------.... .. ..- ... .... ..-....... -... ....... . . . -........... .... . .. ..-. -.. .......

21135990400 -: Lewis, Kentucky - 62 kmn to the southwest

211619T60200 Mason, Kentucky 75 kmn to the southwest -- - - - -- - - - -- - . .. ... -. .... . -. . . . . . - - - . . . - . - - . - . - . . .

39009972800 Athens, Ohio 75 km to the northeast 9 ------------ -- -------.... ....... -... . . .... . .- ..........-.-. .... - - .. ........

309972900 Athens, Ohio 80 km to the northeast . .--. .-- -- -------- ------------ --------- ,. ... -........ ....... .~. ......... .- . .. . - .. - ... . -....

39053953700 Gallia, Ohio 40 kmn to the southeast

39800300 Lawrence, Ohio 60 kmn to the southeast ........ .------- ...... - -. . - . ------- . . ------------.. d . .---. ......- . . . . -.. .

39105964400 : Meigs, Ohio 80kma to the east

39......T 145-9.93 2__0_0------ Scioto, Ohio 28 kmn to the south

39145993600 Scioto, Ohio 34 kmn to the south

5F4011000600 : Cabell, West Virginia 80 kmn to the southeast

5 9 4 0 0 0. 11 0 0 0 b e. s t V ir g i.a .. . .Ca . .,. .We 8 k m t o t h s o u t h ..e .a .s t ... . ... .

540110010900 : Cabell, West Virginia 80 km to the southeast -------- -.------------ ......... ........... .. ..-...... ..

401001100 1 Cabell, West Virginia 80 km to the southeast . .- ..- .-- . .. - . ... -. . . . ... . . .- ..-..-... ..... ..... ...... - - . .-.........

5405---T 3954900 1Mason, WVest Virginia 77 km to the east

Notes:

See Appendix F for more detail.

km = kilometer, mi mile.

To convert km to mi multiply by 0.62.

3.11 Noise

As described earlier, the proposed ACP site is located in an industrial area within the DOE reservation in

Piketon. The nearest actual resident that may hear noise from the site is currently 914 meters (3,000 feet)

away to the southwest.

The DOE EIS (DOE, 2004a) for the depleted UF6 conversion facility being constructed on the reservation

just north of the proposed ACP site determined that ambient noise levels in this area would be

approximately 40 day-night average noise level. However, construction of the conversion facility is now

underway, so the existing noise environment at the proposed ACP would include this construction noise.

The same EIS estimates noise levels from the construction of the depleted U1F6 conversion facility to be

91.5 decibels at 15 meters (50 feet). Because noise from a point source, such as a single piece of

construction equipment, drops off at 6 decibels per doubling of distance, construction noise would be

approximately 50 decibels at the closest residence. This assumes distance attenuation from the

conversion facility to the residence closest to the proposed ACP. The distance from the conversion

facility to this residence is approximately 1,829 meters (6,000 feet). The noise level would be 45

day-night average noise level if construction activities were limited to an eight-hour daytime shift.

Consequently, the existing ambient noise level at the nearest residence would be 45 day-night average

noise level during the conversion facility construction period and would drop back to 40 day-night

average noise level after completion of construction. This noise level estimate is probably an upper

bound since it does not account for other types of attenuation, such as air absorption and ground effects

due to terrain and vegetation.

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The U.S. Department of Housing and Urban Development has standards for community noise levels. It

also has developed land use compatibility guidelines (HUD, 2002) for acceptable noise levels versus the

specific land use. Table 3-27 shows these guidelines. The estimated ambient noise level of 45 day-night

average noise level at the site is below these guidelines.

Table 3-27 U.S. Department of Housing and Urban Development

Land Use Compatibility Guidelines for Noise

-- - . Sound Pressure Level (dBA) *

LandUseCatego | Clearly - Normally Normally - Clearly

j Acceptable Acceptable Unacceptable Unacceptable

Residential l <60 60-65 65-75 >75 A~~~~~~~~~.. _......... _ .............. ._ ....... .... . . _ ;..... ._ . ......... _ .. ;....._..;. ...... _

Livestock Fanning <60 60-65 - 75-80 >80

Office Buildings <65 65-75 75-80 >80 __. . i. ....... .... .......... .. ... .... ..... _ . .... ...- - - -..

Wholesale, Industrial,

M anufacturing & U tilities . ' 7 0 -_. _70-80 _ . _80-85 _. __ _____- _>85

Notes:

' dBA = decibels, A-weighted; DNL = day-night average noise level.

DNL is a 24 hour average with a 10 dBA nighttime penalty. DNL is measured in dBA, which is A-weighted decibels.

Source: HUD, 2002.

3.12 Transportation .13

The DOE reservation is served directly by road and rail. Nearby air and water transportation routes also

serve the site area. Figure 3-19 shows the various transportation routes for roads, rail, water,'and air.

3.12.1 Roads

The site is 5.6 kilometers (3.5 miles) south of the intersection of the U.S. Route 23 and Ohio SR 32

interchange. Both routes are four lanes with U.S. Route 23 traversing north-south and Ohio SR 32

traversing east-west (USEC, 2005). Principal access to the proposed ACP site area is by the Main Access

Road (also called the West Access Road), a security-controlled access, four-lane road connecting with

U.S. Route 23. The Main Access Road is closed to general public access and connects to the Perimeter

Road that encircles the fenced portion of the DOE facility. Employees of the proposed ACP would utilize

the Main Access' Road for access from and traveling to U.S. Route 23. USEC anticipates that:

construction workers and delivery of construction material will use the Southwest Access Road to U.S.

Route 23 or the North Access Road to Ohio SR 32.

U.S. Route 23 intersects I-270, 1-70,;and 1-71 approximately 113 kilometers (70 miles) north of the site.

Trucks also may access 1-64 approximately 32.2 kilometers (20 miles) southeast of Portsmouth. SR 32

runs east-west from Cincinnati and through Piketon to Parkersburg, West Virginia. To the west, SR 32

provides access to Cincinnati's three interstate highways, I-71, I-4, and 1-75. To the east, SR 32 is linked

with 1-77. (USEC, 2005)

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Figure 3-19 Transportation Routes In and Out of the DOE Reservation

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I U.S. Route 23 has an average daily traffic volume of 13,990 vehicles, while Ohio SR 32 has an average

2 daily volume of 7,420 vehicles (traffic in both directions is included in these values). U.S. Route 23 is at

3 60 percent of design capacity with Ohio SR 32 at 40 percent of design capacity. The Ohio Department of

4 Transportation supplied these data from a 1999 traffic study. Load limits on these routes are controlled

5 by the Ohio Revised Code (38,556 kilograms [85,000 pounds]) gross vehicle weight. Special overload

6 permitting is available. (USEC, 2005)

7

8 The DOE reservation road system is in generally good condition due to road repaving projects. -Except

9 during shift changes, traffic levels on the site access roads and Perimeter Road are low. Peak traffic flows

10 occur at shift changes, and the principal traffic problem areas during peak moming/afternoon traffic are at

11 locations where parking lot access roads meet the Perimeter Road. The site has 12 parking lots varying in

12 capacity from approximately 50 to 800 vehicles. Total parking capacity is for approximately 4,400

13 vehicles. (USEC, 2005)

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15 3.12.2 Rail

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17 A rail system is located on the site with several track configurations possible. Two rail carriers, CSX and

18 Norfolk Southern, service Pike County. The Norfolk Southern rail line is connected to the CSX

19 Transportation Inc. line via a rail spur entering the northern portion of the site. The onsite system is used

20 infrequently. The primary facilities for the proposed ACP site are connected to the existing rail

21 configuration. Rail access is also available near the cylinder storage areas that would be located to the

22 north, just outside the Perimeter Road. Track in the vicinity of Piketon allows a maximum speed of 96.6

23 kilometers per hour (60 miles per hour). The CSX Transportation Inc. line also provides access to other

24 rail carriers. (USEC, 2005)

25

26 3.12.3 Water

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28 The site can be served by barge transportation via the Ohio River at the ports of Wheelersburg,

29 Portsmouth, and New Boston. The Portsmouth barge terminal bulk-materials-handling facility is

30 available for bulk materials and heavy unit loads. All heavy unit loading is by mobile crane or barge31 mounted crane at an open-air terminal. The Ohio River provides barge access to the Gulf of Mexico via

32 the Mississippi River or the Tennessee-Tombigbee Waterway. Travel time to New Orleans is 14 to 16

33 days; to St. Louis, seven to nine days; and to Pittsburgh, three to four days. The U.S. Army Corps of

34 Engineers maintains the Ohio River at a minimum channel width of 243.8 meters (800 feet) and a depth

35 of 2.74 meters (9 feet). (USEC, 2005)

36

37 3.12A Air

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39 The nearest airport is the Greater Portsmouth Regional Airport located approximately 24 kilometers (15

40 miles) south of the site. The airport has dual runways and T-hangars, and is operated by Chasteen

41 Aviation, Inc. The airport serves mostly private aircraft owners and business travelers. There are no

42 regularly scheduled commercial flights; however, charter service is available. (Scioto County

43 Government, 2005) Another nearby airport, the Pike County Airport, is located just north of Waverly.

44 This facility is similar in size and makeup to the Greater Portsmouth Regional Airport. In addition, three

45 international airports are within a two-hour drive of the site: Cincinnati/Northem Kentucky International

46 Airport, Dayton International Airport, and Port Columbus International Airport. (USEC, 2004a)

47

48 3.13 Public and Occupational Health

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50 As described in Sections 3.5 through 3.7, several different media in and around the DOE reservation

51 contain radionuclides and chemicals that are both naturally occurring and anthropogenic (i.e., human

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made) from historical and current operations at the site. These media include soil, surface water,

sediment, groundwater, and air. This section describes these radiological and chemical background and

anthropogenic levels in terms of public and occupational exposure and health, as well as historical

exposure levels for activities similar to the proposed action. It also summarizes public health studies

performed in the region which were sufficient to establish baseline information for the Chapter 4 analysis

of impacts to public and worker health that may be due to the proposed action.

3.13.1 Background Radiological Exposure

Humans are exposed to ionizing radiation from many naturally occurring and anthropogenic sources in

the environment. Radioactivity from naturally occurring elements in the environment is present in soil,

rocks, and living organisms. A major proportion of natural background radiation comes from naturally

occurring airborne sources such as radon. Such natural radiation sources contribute approximately 3

millisieverts per year (300 millirem per year) to the radiation dose that a member of the U.S. population

receives annually. The majority of this exposure - approximately 2 millisieverts per year (200 millirem

per year) - is from naturally occurring radon gas from soil, rock, and water. Anthropogenic sources not

attributable to the DOE reservation also contribute to the average amount of dose a member of the U.S.

population receives. These sources include X-rays for medical purposes (0.39 millisieverts per year (39

millirems per year)), nuclear medicine (0.14 millisieverts per year (14 millirems per year]), and consumer

products (0.05 to 0.13 millisieverts per year [5 to 13 millirems per year]) (e.g., smoke detectors). A

person living in the U.S. receives a current average dose of about 3.6 millisieverts per year (360 millirems

per year) (NRC, 2004b).

Air releases of radionuclides from current operations at the DOE reservation result in radiation exposures

to people in the vicinity of the site. Both air monitoring and modeling data have been examined in detail.

In terms of air monitoring, DOE collected data from a network of 15 air samplers in 2002 (DOE, 2003b).

Data were collected both onsite and in the area surrounding the reservation. The monitoring network is

intended to assess whether air emissions from the reservation affect air quality in the surrounding area. A

background ambient air monitoring station is located approximately 21 kilometers (13 miles) southwest

of the site. The analytical results from air sampling stations closer to the plant are compared to

background measurements. Uranium-233/234 and uranium-238 were routinely detected at the stations

and in most of the samples collected from each station. Uranium-235 was detected in slightly less than

half of the samples collected in 2002. Uranium-236 was detected in one or two samples at eight of the 15

stations. Americium-241, neptunium-237, and plutonium-238 were detected once each at stations A28,

A36, and A24, respectively. Technetium-99 was detected once at three sampling stations in 2002.

Detections of the transuranic radionuclides, technetium-99 and uranium-236 were usually near the

detection limit for the analytical method.

To confirm that air emissions are within regulatory requirements and are not harmful to human health,

ambient air monitoring data were used in a separate study to calculate a dose to a hypothetical person

living at the monitoring station. The highest net dose calculation is 1.9 x 10-5 millisieverts per year

(0.0019 millirem per year) (Station A9), which is well below the U.S. EPA National Emissions Standards

for Hazardous Air Pollutants limit of 0.1 millisieveits per year (10 millirem per year), and the NRC total

effective dose equivalent limit of I millisievert per year (100 millirem per year) (DOE, 2003b).

Based on modeling of total radionuclide releases to the air for the year 2002 from United States

Enrichment Corporation operations at the site, the estimated radiation dose to the maximum exposed

individual-a hypothetical individual who is assumed to reside at the most exposed point on the plant

boundary-is 2.60 x 10' millisieverts per year (0.026 millirem per year) (USEC, 2005). DOE operations

contributed an additional 4.20 x 1 O millisieverts per year (0.0042 millirem per year) to the maximum

exposed individual, resulting in a combined dose of 3.10 x I04 millisieverts per year (0.031 millirem per

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I year). These estimated maximum exposed individual doses are well below the U.S. EPA limit of 0.1

2 millisieverts per year (10 millirem peryear) and the NRC limit of I millisievert per year (100 millirem

3 per year). These results also are comparable to those estimated in an EIS for the affected environment of

4 a separate, depleted uranium conversion facility proposed on the DOE reservation (DOE, 2004a). That

5 EIS reports a combined dose (USEC and DOE sources) of 6 x 104 millisieverts per year (0.060 millirem

6 per year) for air, which also is well below the U.S. EPA limit of 0.1 millisieverts per year (10 millirem per

7 year) and the NRC limit of 1 millisievert per year (100 millirem per year). Note that while this

8 conversion facility dose estimate is approximately double the dose estimated for the proposed ACP's

9 affected environment, this can be explained by the different location that was evaluated on'the DOE

10 reservation.

11..--..-....

12 The depleted uranium conversion EIS (DOE, 2004a) also states that the maximum radiation dose to an

13 offsite member of the public as a result'of current onsite facility operations is estimated to'b'e 2.0 millirem

14 per year. This dose, while still lower than the U.S. EPA and NRC standards,-ircludes several 'other

15 exposure pathways as part of the assessment: waterborne (drinking, swimming, fishing), at 0.00039

16 millisieverts per year (0.039 millirem per year); ingestion (sediment, soil, locally produced vegetation and

17 crops), at 0.0088 millisieverts per year (0.88 millirem per year); and direct gamma radiation, at 0.0098

18 nillisieverts per year (0.98 millirem per year). This latter exposure, direct radiation, was estimated for a

19 person driving slowly on the Perimeter Road and passing close to the edge of the cylinder yards two times

20 a day for 185 days per year. This road, however, was closed to the public after September 11, 2001 and

21 thus this exposure is a significant over-estimate of actual doses if the road remains closed.

22

23 According to USEC (USEC, 2005), on-reservation worker average whole body dose is less than 0.1

24 'millisieverts per year (10 millirem per year). In the depleted uranium conversion facility EIS cylinder

25 yard worker exposure is estimated (from monitored external radiation) at 0.64 millisieverts per year (64

26 millirem per year) (DOE, 2004a). Both estimates are significantly less than the NRC and DOE worker

27 dose standards of 50 millisieverts per year (5,000 millirem per year).

28

29 3.13.2 Background Chemical Exposure

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31 As discussed in Section 3.5.3, existing air quality on and around the site is in attainment with the criteria

32 pollutants under the National Ambient Air Quality Standards and the standards adopted by the State of

33 Ohio. These pollutants include particulate matter less than 10 microns (3.94 x 1 0 4 inches) in diameter,

34 sulfur dioxide, carbon monoxide, nitrogen dioxide, lead, and ozone.

35 - -

36 For other non-radiological pollutants and other possible exposure pathways, the depleted uranium

37 conversion EIS (DOE, 2004a), specifically Section 3.1.7.2, provides a useful summary of health

38 indicators using estimated hazard quotients (a comparison of estimated maximum potential human intake

39 levels with intake levels below which adverse effects are very unlikely to occur). In all media assessed,

40 air, soil, surface'water, sediment, and groundwater, the hazard quotients are less than one, meaning

41 adverse effects are very unlikely to occur as a result of no'n-radiological chemicals present in the'.

42 environinent around the site. Furthermrbie,'only groundwater has a hazard quotient approaching one (i.e.,

43 0.26), yet the monitoring wells resulting in this valueare onsite wells that are not used for drinking water.

44

45 Regarding occupational exposure, DOE recently- authorized Bechtel Jacobs Company, LLC to initiate

46 characterization of potential beryllium contamination at the Portsmouth Gaseous Diffusion Plant. In

47 December 2003, under contract to Bechtel Jacobs Company, LLC, the United States Enrichment

48 Corporation began performing surface wipes,'surface bulk, and destructive analysis sampling in various

49 locations throughout the plant. Low levels of beryllium have been found in aluminum parts machined

50 and used in several facilities, and these levels are significant based on initial surface characterization

51 results in comparison with DOE beryllium contamination limits in 10 CFR Part 850. At least one credible

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I exposure pathway has been identified with machining of aluminum parts, and several more have been

2 suggested by professionals within the beryllium processing industry; these include grinding, buffing,

3 welding, and chemical treatment/cleaning of beryllium-containing materials.

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The Occupational Safety and Health Administration has issued permissible exposure limits for chemicals

emitted into the air at this site (some of these limits are final, while others have only been proposed).

Two of the key chemicals of concern-soluble and insoluble uranium compounds and hydrogen

fluoride-are below those limits (DOE, 2004a). Other chemicals have been measured over the years at

various levels at the Portsmouth Gaseous Diffusion Plant. Some of these levels have approached or

exceeded occupational health benchmarks. For example, arsenic levels ranged up to 2.1 milligrams per

cubic meter, which is higher than the permissible exposure limit of 0.01 milligrams per cubic meter, and

lead levels ranged up to 19.5 milligrams per cubic meter, which is higher than the permissible exposure

limit of 0.050 milligrams per cubic meter. Several other such examples exist. The measured levels were

at the upper ends of the relevant ranges and the permissible exposure limits for eight-hour time weighted

averages.

Another occupational health issue is the potential risk from exposure to chemicals in the onsite subsurface

soil, groundwater, and surface water. Estimates of excess lifetime cancer risks to hypothetical workers

range as high as 1.5 x 10.2, and estimates of hazard quotients for noncarcinogens range as high as eight

(DOE, 2004b). Note that these exposures are hypothetical and are based on unmitigated risks.

One final issue regarding occupational health is the potential for large quantities of highly hazardous

material to be stored onsite. No threshold quantities, however, are present at the proposed ACP site,

based on the Occupational Safety and Health Administration Process Safety Management Standard (29

CFR § 1910.119) and the U.S. EPA Risk Management Program Standard (40 CFR Part 68).

3.13.3 Public Health Studies

In 1992, Pike and Scioto County residents petitioned the Centers for Disease Control and Prevention to

conduct an epidemiological health study. Residents expressed their desire for a health study on radiationrelated diseases, and they raised questions about excessive cancer rates in Scioto County (which is south

of the site), excessive birth defects, and other adverse health effects (such as heavy metal toxicity)

believed to be related to environmental releases from the site. The petition was forwarded to the Agency

for Toxic Substances and Disease Registry with a request to perform a public health assessment to

determine what follow-up health activities, such as a health study (designed to evaluate whether disease in

the community could be associated with exposure to site contaminants), were appropriate.

The public health assessment included an analysis of mortality data obtained specifically for the

assessment from the Centers for Disease Control and Prevention's National Center for Health Statistics,

Office of Analysis and Epidemiology and an analysis of I 1 other sets of data or studies (ATSDR, 1996).

The National Center for Health Statistics' data that were examined were from the Wide-ranging ONline

Data for Epidemiologic Research Database for the years 1979 to 1991. A detailed look at all causes of

death for Pike, Ross, and Scioto counties in Ohio shows significantly higher rates of cardiovascular

disease for Pike County. The age-adjusted rate for childhood cancer mortality in Pike County was found

to be roughly twice the national and State rates, but the number was too small to give a statistically

reliable result. For example, this rate is based on only five cancer deaths for the 13-year period from

1979 to 1991, and none of the childhood cancers were of the same type and therefore could not be related

to a common cause, both statistically and because different cancers suggest different causes.

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1 The public health assessment also noted that if there were significant uranium exposure in the community

2 surrounding the plant, a measurable increase in the rate of renal failure would be expected. No increase in

3 the renal failure rate was identified in surrounding communities, and no other trends were found for the

4 area for the years 1979 to 1991.

5

6 One of the 11 other data sets or studies analyzed in the public health assessment was the National Cancer

7 Institute Report "Cancer in Populations Living Near Nuclear Facilities. Volume 2: Individual Facilities

8 Before and After Startup" (1953-1984). Among the facilities examined in this report was the Portsmouth

9 Gaseous Diffusion Plant. Relative risks (i.e., the ratio of the risk of a disease in an exposed person

10 compared to the risk in an unexposed person) for a number of types of cancer-including bladder and

11 stomach cancer, which were mentioned as cancers of concern by a member of the public during the July

12 9,2004 public meeting in Piketon, Ohio, on the proposed ACP-all clustered around one, thus indicating

13 that the populations living near the Portsmouth facility were at approximately the same risk of developing

14 these cancers as populations not living nearby.

15

16 The Agency for Toxic Substances and Disease Registry concluded, through its public health assessment

17 process, that exposure data could not be fouund to support a health study, and fuithermore, available

18 information about health outcomes did not suggest any adverse health impact from site operation

19 (ATSDR, 1996). Because the Agency for Toxic Substances and Disease Registry's public assessment

20 was published in-1996, however, more recent data regarding cancer mortality were compiled for this

21 Draft EIS using the Wide-ranging ONline Data for Epidemiologic Research Database (the same database

22 used for the public health assessment).

23

24 The new cancer data compiled for this Draft EIS are shown in Table 3-28. These data indicate that Pike

25 County is similar to the rest of Ohio and the U.S. in terms of overall cancer mortality. New data also

26 were sought for three specific cancers of interest- childhood cancer, stomach cancer, and bladder

27 cancer-either because they were of interest in the public health assessment or a subsequent public

28 meeting.' The annial imortality counts from these cancers, however, were five or fewer for both Pike

29 County and the nearby Ross and Scioto Counties and thus are not reported due to patient confidentiality

30 concerns. Had they been available, the low rates also would have rendered them statistically unreliable.

31

32 New data also were compiled (Table 3-29) for mortality due to renal failure, a health endpoint of interest

33 in the public health assessment because of uranium metal's role as a heavy metal in renal toxicity. The

34 new data cover two date ranges: 1995 to 1998 and 1999 to 2001.1 As seen by these data, there may have

35 been an increase subsequent to the public health assessment in renal failure rates in the selected counties,

36 particularly Pike County, when compared to all of Ohio or the U.S.; however, it cannot be concluded that

37 this rise was solely due to uranium toxicity. While high levels of uranium can be' a risk factor for renal

38 failure, other risk factors, such as diabetes and hypertension, may be' even more important. For 1999 to

39 2001, the Centers for Disease Control and Prevention's Wide-ranging ONline Data for Epidemiologic

40 Research data show that age-adjusted annual mortality per 100,000 from diabetes in Pike County was 51

41 while in Ohio this rate was only 31 and in the U.S. was 25.' -

'The beginning year of the first range, 1995, was selected rather than 1992 (i.e., the year that would have

followed the end of the original public health assessment date range of 1979 to 1991) because most of the gross

annual mortality counts from 1992 to 1994 were five or fewer and thus not reported due to patient confidentiality

concerns. Also, the cutoff between 1998 and 1999 is due to changes in the international classification of diseases

codes (see Footnote 3 of Table 3-29).

. 3-67
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Al llLJ

1 3.13.4 Occupational Injury and Illness Rates

2

3 There have been no industrial fatalities on the DOE reservation. Nevertheless, the National Institute for

4 Occupational Safety and Health conducted an epidemiologic study at the reservation to examine the

5 causes of death among workers employed by the facility between September 1, 1954 and December 31,

6 1991. Deaths among the workers were compared with rates for the general U.S. population. Possible

7 relationships were evaluated for deaths from several types of cancer and exposures to ionizing radiation

8 and certain chemicals (fluoride, uranium metal, and nickel). Based upon previous health studies of

9 nuclear facility workers, including an earlier National Institute for Occupational Safety and Health

10 investigation at the DOE facility, deaths from cancers of the stomach, lung, and the lymphatic and the

11 hematopoietic systems including leukemia, were evaluated in more detail. The announcement of findings

12 by the National Institute for Occupational Safety and Health, published in October 2001, stated that

13 overall cohort mortality was significantly less than that of the U.S. population, as was mortality from all

14 cancers. (USEC, 2005)

15

16 Table 3-28 Death Rate/Trend Comparison, All Cancers, Death Years Through 2001

17

18

19

20

21

Lower Upper Recent

Death Annual 95% 95/ Annual

Rate Death Confidence Confidence Rate Percent Recent

Compared Rate Interval Interval Ratio (2) Change (3) Recent Trend

to US over rate for for County In Death Trend Period

Area Rate (1) period Death Rate Death Rate Rate Period to US Rates (4) (3,4)

United - . 199.8 199.6 . 200 11997-2001 1 - -1.1 1falling* 1993-2001

States . . . _- ........ ---. . ....... . .... .. _4........ . . .... .......... .. *------'-'-4 ............. .... . .. 4_...._

Ohio * similar * 212.4 * 211.2 1 213.6 11997-2001 * 1.1 * -1.2 *falling' 1995-2001 ... .... .. ....... 4.... *.----4----- ........- ---. 

Pike County . similar * 200.5 * 177.9 * 225.2 *1997-2001 1 0.7 * stable *1977-2001

22 Notes:

23 All rates are per 100,000 persons.

24 When the population size for a denominator is small, the rates may be unstable. A rate is unstable when a small change in the

25 numerator (eg., only one or two additional cases) has a dramatic effect on the calculated rate. Suppression is used to avoid

26 misinterpretation when rates are unstable.

27 (1) Rate Comparison

28 "above" = when 95% confident the rate is above and Rate Ratio > 1.10.

29 "similar" = when unable to conclude above or below with confidence.

30 "below" = when 95% confident the rate is below and Rate Ratio < 0.90.

31 (2) Rate ratio is the county rate divided by the US rate.

32 (3) Recent trend in death rates were calculated using the Joinpoint Regression Program and are expressed as the annual percent

33 change over the recent trend period. Recent trend period is the period since last change in trend as determined by Joinpoint.

34 (4) Trend

35 "rising" = when 95% confidence interval of annual percent change is above 0.

3 6 "stable" = when 95% confidence interval of annual percent change includes 0.

37 "falling" = when 95% confidence interval of annual percent change is below 0.

38 Source: Death data provided by the National Vital Statistics System public use data file. Death rates calculated by the National

39 Cancer Institute using SEER*Stat. Death rates are age-adjusted to the 2000 US standard population by 5-year age groups.

40 Population counts for denominators are based on Census populations as modified by NCI.

41

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Table 3-29 Age-Adjusted Mortality Rates for Renal Failure

Year Range United States | State of Ohio 'Pike County Ross County | Scioto County

1979 to 1991 . 8.3 * 8.4 6.4U(1) * 8.8U(1) 8.8U(l) ......-.....-.-.- -t. . ..... ........

1995 to 1998 8.8 11.2 32.2U * 14.3U(2) 14.2U ............ *........................

1999 to 2001(3) . 13.2 15.3 . 43.7U 14.6U(4) . 12.9U

Notes:

All Rates are per 100,000 persons. "U" indicates the data are statistically unreliable because they are based on fewer than 20 deaths.

(1) These rates are from ATSDR (1996), though the original source is as described below. They were not previously applied

the "IY' designation but they appear to require it based on the definition above. Furthermore, these exact numbers could not

be duplicated from the source below and are slightly lower than the recalculated numbers. This discrepancy may be due to

factors such as updated data or the year that was selected for the standard population used for the age-adjustment (the year

2000 for the new date range).

(2) The years averaged are 1994, 1997, and 1998 because the data for 1995 and 1996 are suppressed for confidentiality (i.e.,

deaths are five or fewer).

(3) Beginning in 1999, cause of death in the data source (below) is specified with the International Classification of Diseases

10th Revision rather than 9th revision codes. The two revisions differ substantially, which may account for some or all of the

difference seen between the 1999 to 2001 group and the previous groups. This difference should have no effect, holwiever,

between the different locations or areas within the same year range group. *

'(4) The years averaged are 1999 and 2001 because the data for 2000 are suppressed for confidentiality (i.e., deaths are five or

fewer).

Source: CDC, 2004.

The lower mortality among these workers is consistent with the "healthy work effect," which is found in

most occupational epidemiologic studies. No statistically significant excesses in mortality from any

specific cause were identified. Analyses of possible relationships between causes of death and the

identified exposures failed to reveal any dose-response trends. For leukemia, no effect of cumulative

exposure to either external or internal radiation was identified. Additionally, no dose-response

relationships were observed for cancers of the stomach, lung, Hodgkin's disease, lymphoreticulosarcoma,

and all cancers combined. Workers deaths from cancers of the Iympho-hematopoietic tissue, including

leukemia, equaled U. S. rates of matched controls. Stomach cancer deaths were greater than expected, but

this difference was not statistically significant. Deaths from these cancers had been found to be slightly

elevated in a previous National Institute for Occupational Safety and Health study of the site.

The Department of Labor has documented eight cases of beryllium sensitization and 14 cases of Chronic

Beryllium Disease among current and former workers at the Portsmouth Gaseous Diffusion Plant. It has

been estimated that about 1,200 of a total of 28,000 personnel (including subcontractors) who have

worked at the DOE reservation have received a medical test to determine beryllium sensitivity. Likely

exposure pathways are being or recently have been identified by Bechtel Jacobs Company, LLC, as

authorized by DOE.

The United States Enrichment Corporation maintains a log and summary of recordable occupational

injuries and illnesses under the guidance of the Occupational Safety and Health Administration's 29 CFR

Part 1910, Part 1904, Recording & Reporting Occupational Injuries & Illnesses. The proposed ACP

Environmental Report summarizes a comparison of year-to-date monthly Recordable Injury/Illness rates

per 100 full-time workers for fiscal years 2002 and 2003. Calendar year 2002 and 2003 Recordable

Injury/Illness rates are 2.95 and 1.94. For comparison, the U.S. Department of Labor, Bureau of Labor

Statistics compiles annual injury and illness data including the incidence rates by industry. United States

Enrichment Corporation standard industrial classification is 2819, "Industrial Inorganic Chemicals, not

elsewhere classified." Calendar year 2003 Bureau of Labor Statistics' average incidence rate of nonfatal

occupational injuries and illnesses are not currently published. The Bureau of Labor Statistics' national

. 3-69
I

1 average incidence rate of nonfatal occupational injuries and illnesses for standard industrial classification

2 2819 for calendar year 2002 is 3.4, which is higher than the rates of 2.95 and 1.94 for the United States

3 Enrichment Corporation.

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3.14 Waste Management

This section describes the solid, hazardous, radioactive, and mixed (i.e., hazardous plus radioactive)

wastes currently generated and managed by the United States Enrichment Corporation at the DOE

reservation in Piketon. This reflects the baseline condition and is in contrast to the wastes that USEC

would generate and manage under the proposed action, which are described in Chapter 2. This section

also describes the existing waste management practices used by the United States Enrichment Corporation

at the DOE reservation, most of which would also be used to manage wastes from the proposed ACP.

3.14.1 Current Waste Management Program

The United States Enrichment Corporation's Waste Management Program directs the storage, treatment,

and disposal of waste generated by its operations at the DOE reservation at Piketon. The company must

satisfy NRC, U.S. EPA, Ohio EPA, and Ohio Department of Health regulations as part of these activities.

Waste generated by United States Enrichment Corporation operations at the DOE reservation and then

transferred to DOE for storage, treatment, or disposal is subject to DOE Orders. Additional policies have

been implemented by the United States Enrichment Corporation for management of radioactive,

hazardous, and mixed wastes generated at the site. The United States Enrichment Corporation is

currently operating in accordance with an NRC Certificate of Compliance issued under 10 CFR Part 76.

Waste collection and segregation activities are completed in accordance with applicable State and Federal

rules and regulations and site procedures (see Table 1-3 in Chapter 1). Wastes are collected and

packaged, where feasible, at the location where the waste is generated. Wastes are also segregated into

the various waste streams and handled accordingly to minimize the generation of hazardous, low-level

mixed waste, and low-level radioactive waste.

3.14.2 Baseline Waste Generation

Table 3-30 summarizes the projected baseline waste generation for the DOE reservation at Piketon, as

reported in DOE's EIS supporting the proposed depleted UF6 conversion facility at the reservation (DOE,

2004a). Volumes include operational and environmental restoration (i.e., cleanup) wastes projected from

2002 to 2025, not including the proposed ACP.

The waste volumes generated and managed by the United States Enrichment Corporation at the DOE

reservation are much smaller than those reported above for operational and cleanup activities for the

reservation as a whole. During 2003, the United States Enrichment Corporation disposed of

approximately 0.1 cubic meter (3.5 cubic feet) of low-level radioactive waste and 15 cubic meters

(530 cubic feet) of low-level mixed waste, and recycled approximately 76 cubic meters (2,684 cubic feet)

of non-hazardous waste. The projected annual waste generation rates range from 182 to 355 cubic meters

(6,420 to 12,520 cubic feet) of low-level radioactive waste and from 8 to II cubic meters (300 to

400 cubic feet) of low-level mixed waste (USEC, 2005).

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Table 3-30 Projected Waste Generation Volumes for the DOE Reservation at Piketon '

Waste Category Waste Treatment Volume, m3/yr b

Low-level radioactive waste .- 73,000--

Low-level mixed waste 5,600

Transuranic waste -none projected

Hazardous waste 110

Non-hazardous waste b

Solids 3,200

Wastewater 145,000

Notes:

Volumes include operational and environmental restoration wastes projected from FY 2002 to FY 2025. b m3/yr = cubic meters per year; ft'/yr = cubic feet per year.

To convert mr/yr to ft3/yr multiply by 35.3.

Source: DOE, 2004a.

3.14.3 Current Waste Streams and Management Practices

Wastes generated by existing United States Enrichment Corporation operations at the DOE reservation at

Piketon and/or managed onsite at the reservation include:

* Depleted uranium;

* Low-level radioactive waste;

* Non-radioactive hazardous waste;

* Low-level mixed waste;

Recyclable waste;

Classified/sensitive waste; and

* Sanitary/industrial waste.

The following sections summarize each of these waste streams from United States Enrichment

Corporation activities at the DOE reservation along with the current facilities and procedures for

managing these wastes.

3.14.3.1 Depleted Uranium

Regulatory Framework

Approximately 177,600 metric tons (195,800 tons (16,190 containers)) of depleted UF6 were being stored

at the DOE reservation as of June 2004 (DOE, 2004a). .All of the depleted uranium is the responsibility

of DOE under signed memoranda of agreement between the United States Enrichment Corporation and

DOE. The depleted UF6 stored at the reservation is managed in accordance with 40 CFR Part 266 and

Ohio Administrative Code 3745-266. Section 3113(a) of the USEC Privatization Act (Public Law

104-134) requires DOE to accept low-level radioactive waste, including depleted uranium that has been

determined to be low-level waste, for disposal, upon the request of, and reimbursement of costs by, the

United States Enrichment Corporation. To date, this provision has not been invoked, and the form in

which the depleted uranium would be transferred to DOE has not been specified. Depleted UF6 has been

classified by the NRC as a Low-Level Radioactive Waste (NRC, 2005). It is assumed that depleted

uranium from the proposed ACP that is transferred under this provision of law in the future would be in

.3-71
I the form of Depleted UF

2 conversion facility, as di

3

4 Waste Management Fv

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6 The DOE reservation ha

7 approximately 177,627 i

8 storage yards that have

9 Nuclear Facility Safety:.

10 stored in these yards has

11 concrete saddles with su

12 inspection of cylinders.

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14 Ta

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F6. This would add to the inventory needing conversion at the depleted UF6

iscussed further in Section 4.2.12.3.

icilities and Practices

as a total of 16,109 DOE-managed cylinders containing depleted UF6 equivalent to

metric tons (195,800 tons) (see Table 3-3 1). The cylinders are located in two

concrete bases. The cylinders are stacked two high to comply with Defense

Board recommendations. All 9- and 13-metric ton (10- and 14-ton) cylinders

ie been, or are being, inspected and repositioned. They have been placed on new

ifficient room between cylinders and cylinder rows to permit adequate visual

(DOE, 2004a)

ble 3-31 DOE-Managed Depleted Uranium Hexafluoride

Cylinders at the DOE Reservation at Piketon

Cylinder Type Number of Cylinders

Full 16,018 . . ........ _ ........ .. _ 

Partially Full . 42 - . - . .... -..... - .-.-.-- . ... ...

Heel 49

Total 16,109

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Source: DOE, 2004a.

The cylinder storage yards at the DOE reservation are sources of only a very small amount of waste

compared with the volume of waste generated from ongoing plant operations. Cylinder yard waste

consists of small amounts of metal, scrapings from cylinder maintenance operations, potentially

contaminated soil, and miscellaneous items.

3.14.3.2 Low-Level Radioactive Waste

Waste Characteristics

Low-level radioactive waste is radioactively contaminated waste that is not classified as high-level

radioactive waste, transuranic waste, spent nuclear fuel, or byproduct materials as defined in Section

l le(2) of the Atomic Energy Act. Low-level radioactive wastes have radionuclide concentrations that

typically range from the minimum detectable activity of 0.2 to 0.5 micrograms per gram for total uranium

and 37 becquerels per kilogram (I picoCurie per gram) for technetium up to 0.5 milligram per gram for

total uranium and 1,110 becquerels per kilogram (30 picoCuries per gram) for technetium. Higher

concentrations do occasionally occur. Low-level radioactive waste includes dry active waste,

radioactively contaminated metal, trap material, and used oil. Trap material consists of alumina,

magnesium, and sodium fluoride pellets. Activities in trap material will typically range from the

minimum detectable activity of 0.2 to 0.5 micrograms per gram for total uranium and 37 becquerels per

kilogram (I picoCurie per gram) for technetium up to 10.0 milligrams per gram for total uranium and 3.7

x 106 becquerels per kilogram (100,000 picoCuries per gram) for technetium. Magnesium trapping

material from the feed stock decontamination project at the reservation has had technetium levels of up to

1.77 x 108 becquerels per kilogram (4.78 microCurie per gram). Depleted UF6 is also considered a

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I category of low-level radioactive waste, but is considered a separate waste stream for the purposes of this

2 Draft EIS, as discussed above.

3

4 Waste Management Facilities and Practices

5

6 Low-level radioactive wastes generated by United States Enrichment Corporation operations-at the DOE

7 reservation are generally transferred to the XT-847 Waste Management Staging Facility for temporary

8 storage pending shipment to offsite treatment and disposal facilities. Such waste is stored onsite until

9 shipment to an offsite treatment, storage, and disposal facility can be scheduled. During 2003, offsite

10 treatment, storage, and disposal facilities that managed low-level radioactive waste generated by United

11 States Enrichment Corporation operations at the DOE reservation included Envirocare, DSSI, and GTS

12 Duratek. During 2003, approximately twice as much low-level radioactive waste was generated (283

13 cubic meters (10,016 cubic feet)) as was shipped offsite for disposal (155 cubic meters (5,465 cubic

14 feet)).

15

16 The XT-847 facility consists of a steel structure with concrete floors and is divided into three storage

17 areas, including a 90-day hazardous waste storage area. The XT-847 Facility is used to accumulate,

18 stage, and prepare hazardous waste, radioactive and hazardous mixed waste, low level radioactive waste,

19 and non-hazardous recyclable material prior to shipment off the reservation. The XT-847 Facility is

20 equipped with truck and rail loadingunloading facilities. The facility also supports nuclear measuring

21 activities.

22

23 3.14.3.3 Hazardous Waste

24

25 Waste Characteristics

26

27 The hazardous waste category is comprised of: (1) Resource Conservation and Recovery Act waste listed

28 in 40 CFR Part 261, Subpart D or exhibits any hazardous waste characteristics reported in 40 CFR Part

29 261, Subpart C; (2) Toxic Substances ControlAct waste; or (3) any waste defined as hazardous under

30 equivalent State regulations. Hazardous wastes currently generated by the United States Enrichment

31 Corporation at the DOE reservation include aerosol cans, solvents, and laboratory waste.

32

33 Waste Management Facilities and Practices

34 -

35 Hazardous wastes generated by the United States Enrichment Corporation at the DOE reservation are

36 stored at the XT-847 Waste Management Staging Facility prior to transfer offsite for treatment and

37 disposal. The company does not store hazardous waste for periods greater than 90 days. All hazardous

38 waste is transferred to a Resource Conservation and Recovery Act Part B permitted "greater than-90-day"

39 storage facility operated by DOE at the reservation within 90 days of generation in accordance with the

40 Ohio EPA Director's Final Findings and Orders, issued to the United States Enrichment Corporation on

41 October 5, 1995. The DOE reservation then provides long term onsite storage for hazardous waste at the

42 X-7725 and X-326 hazardous waste storage areas. Several additional 90-day satellite storage areas are

43 available for temporary storage of hazardous waste. Hazardous wastes are stored onsite at the reservation

44 under DOE control until shipment to an offsite treatment, storage, and disposal facility can be scheduled.

45 In 2003, offsite treatment, storage, and disposal facilities used for management of hazardous waste

46 included LWD, DSSI, and Perma-Fix.

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1 3.14.3.4 Low-Level Mixed Waste

2

3 Waste Characteristics

4

5 Low-level mixed waste is a waste that contains both low-level radioactive waste and Resource

6 Conservation and Recovery Act hazardous waste, as defined in Ohio Administrative Code 3745-266-210.

7 Such waste currently generated by the United States Enrichment Corporation at Piketon includes

8 laboratory waste, solvents, and decontamination solutions.

9

10 Waste Manazement Facilities and Practices

11

12 Low-level mixed waste generated by the United States Enrichment Corporation at the DOE reservation is

13 generally transferred to the XT847 facility for temporary storage prior to transfer off site for treatment

14 and disposal. Such waste is exempted from the storage requirements for hazardous waste as defined in

15 Ohio Administrative Code 3745-51-03, since it is a hazardous waste and is generated and managed by the

16 United States Enrichment Corporation, as described in 40 CFR Part 266, Subpart N and Ohio

17 Administrative Code 3745-266.

18

19 All low-level mixed waste generated from United States Enrichment Corporation operations at the site is

20 transferred to a Resource Conservation and Recovery Act Part B permitted "greater than-90-day" storage

21 facility operated by DOE at the reservation in accordance with the Ohio EPA Director's Final Findings

22 and Orders, issued to the United States Enrichment Corporation on October 5, 1995. The wastes are

23 stored onsite until shipment to an offsite treatment, storage, and disposal facility can be scheduled. In

24 2003, mixed wastes were shipped offsite to facilities managed by LWD, DSSI, and Perma-Fix.

25

26 3.14.3.5 Recyclable Waste

27

28 Waste Characteristics

29

30 Recyclable waste includes waste that is:

31

32 * Not radioactively contaminated;

33 * Not regulated as hazardous under the Resource Conservation and Recovery Act;

34 * Not regulated under the Toxic Substances Control Act;

35 * Not categorized as classified/sensitive; and

36 * Is not acceptable for disposal at a sanitary landfill.

37

38 Some examples of recyclable waste currently generated by the United States Enrichment Corporation at

39 Piketon include used oil, fluorescent bulbs, incandescent bulbs, High Intensity Discharge bulbs, circuit

40 boards, and scrap metal.

41

42 Waste Management Facilities and Practices

43

44 Recyclable wastes generated by existing United States Enrichment Corporation operations at the DOE

45 reservation are segregated and stored onsite until off-reservation shipment to a treatment, storage, and

46 disposal facility can be scheduled. In 2003, offsite facilities that were used for recycling such waste

47 included AERC, DOE-Run, and Safety-Kleen.

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1 3.14.3.6 Classified/Sensitive Waste

2

3 Waste Characteristics

4

5 Classified/sensitive waste is any waste considered as such for security reasons. These materials may be

* 6 classified due to configuration, composition, contamination, or contained information. Classified waste

7 may be categorized as non-hazardous waste or as low-level radioactive depending upon its point of and

8 method of generation.

9

10 Waste Management Facilities and Practices

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12 Classified waste is stored onsite prior to disposal in classified offsite disposal facilities.

13

14 3.14.3.7 SanitarylIndustrial Waste

15

16 Waste Characteristics

17

18 Sanitary/industrial waste includes non-hazardous solid waste generated by industrial processes and

19 manufacturing and conventional waste material that is no longer usable for plant operations. Some

20 examples of sanitary/industrial waste generated by the United States Enrichment Corporation at the DOE

21 reservation include sludge from wastewater treatment, alkaline batteries, trash, paper, wood, metal, glass,

22 and cafeterialoffice refuse.

23

24 Waste Management Facilities and Practices

25

26 Sanitary/industrial solid wastes generated by existing United States Enrichment Corporation operations at

27 the DOE reservation are disposed at the offsite Pike Sanitary Landfill. Sanitary wastewater (e.g., from

28 showers and toilets) generated at the site are discharged to the plant sanitary sewer system and ultimately

29 to the X-6619 sewage treatment plant. Treated sanitary wastewaters are discharged from X-6619 directly

30 to the Scioto River through an underground pipeline via a permitted outfall. As discussed in Section 3.7,

31 storm water runoff from the proposed ACP area drain to a pair of holding ponds (X-2230N West Holding

32 Pond and X-2230M Southwest Holding Pond) to allow settling of suspended solids, dissipation of

33 chlorine, and oil diversion and containment prior to discharge to unnamed tributaries of the Scioto River.

34 The only intentional process wastewater discharge resulting from plant operations is blow down from the

35 Tower Cooling Water system.

36

37 3.15 References

38

39 (ATSDR, 1996) Agency for Toxic Substances and Disease Registry. "Public Health Assessment, US

40 DOE Portsmouth Gaseous Diffusion Plant, Piketon, Pike County, Ohio." November 20,1996.

41 <http:/www.atsdr.cdc.gov/HAC/PHA/portsmouthgas/pgd_toc.html> (Accessed I 1/16/2004).

42

43 (BEA, 2002a) U.S. Bureau of Economic Analysis. "Total full-time and part-time employment by

44 industry." U.S. Department of Commerce, Bureau of Economic Analysis. 2002.

45 <http://www.bea.gov/bea/regional/reis/>. -:

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I (BEA, 2002b) U.S. Bureau of Economic Analysis. "Per capita personal income." U.S. Department of

2 Commerce, Bureau of Economic Analysis. 2002. <http:/lwww.bea.doc.gov/bea/regional/reis/>.

3

4 (Bechtel Jacobs Company, 2003) Bechtel Jacobs Company. Personal communication from Richmond

5 (Bechtel Jacobs Company LLC, Piketon, Ohio) to Y.-S. Chang (Argonne National Laboratory, Argonne,

6 Illinois). February 24, 2003.

7

8 (Borchelt, 2003) Borchelt, as cited in "Environmental Report for American Centrifuge Lead Cascade

9 Facility at USEC's Facilities in Piketon, Ohio." LA-2605-0002. Natural Resource Conservation Service.

10 February 2003.

I1I

12 (CDC, 2004) Centers for Disease Control and Prevention. "Compressed Mortality Data File, 1979-1998."

13 National Center for Health Statistics, Office of Analysis and Epidemiology, Wide-ranging ONline Data

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15

16 (CEQ, 1997) Council of Environmental Quality. "Environmental Justice Guidance under the National

17 Environmental Policy Act." Executive Office of the President. December 1997.

18

19 (CFD, 2005) Chillicothe Fire Department, Department Structure. 2005.

20 <http://www.chillicothefd.com/structure.htm> (Accessed 5/20/2005).

21

22 (Coleman, 1997) Coleman, K, Dobson-Brown, D., and Herr, D. "Phase I Architectural Survey for the

23 Portsmouth Gaseous Diffusion Plant (PORTS Facility) in Scioto and Seal Townships, Pike County,

24 Ohio" (submitted to, and copies available from, the U.S. Department of Energy). ASC Group. 1997.

25

26 (DOE, 1993a) U.S. Department of Energy. Referenced as "DOE, 1993" in U.S. Department of Energy,

27 "Environmental Assessment Reindustrialization Program at the Portsmouth Gaseous Diffusion Plant,

28 Piketon, Ohio," DOE/EA-1346, May 2001.

29

30 (DOE, 1993b) U.S. Department of Energy. "Radiation Protection of the Public and the Environment,"

31 DOE Order 5400.5, Change 2. January 1993.

32

33 (DOE, 1996a) U.S. Department of Energy. "Baseline Ecological Risk Assessment, Portsmouth Gaseous

34 Diffusion Plant, Piketon, Ohio." DOE/ORI Il-1316/VI&D2. 1996.

35

36 (DOE, 1996b) U.S. Department of Energy. Referenced as "DOE, 1996" in U.S. Department of Energy,

37 "Environmental Assessment Reindustrialization Program at the Portsmouth Gaseous Diffusion Plant,

38 Piketon, Ohio," DOE/EA-1346, May 2001.

39

40 (DOE, 1996c) U.S. Department of Energy. "Wetland Survey Report for the Portsmouth Gaseous

41 Diffusion Plant." POEF-LMES-106. Prepared by Lockheed Martin Energy Systems, Inc. As referenced in

42 U.S. Department of Energy, "Environmental Assessment Reindustrialization Program at the Portsmouth

43 Gaseous Diffusion Plant, Piketon, Ohio,"DOE/EA-1346, May 2001.

44

45 (DOE, 1997a) U.S. Department of Energy. Referenced as "DOE, 1997a" in U.S. Department of Energy,

46 "Environmental Assessment Reindustrialization Program at the Portsmouth Gaseous Diffusion Plant,

47 Piketon, Ohio," DOE/EA-1346, May 2001.

48

49 (DOE, 1997b) U.S. Department of Energy. "Final Threatened and Endangered Species

50 Report-Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOE/OR/ 1-1668&DO. Lockheed Martin

51 Energy Systems, Inc. 1997.

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I (DOE, 1980) U.S. Department of Energy. "Preliminary Safety Analysis Report for the Gas Centrifuge

2 Enrichment Plant," Portsmouth, Ohio. ORO-EP-123. Oak Ridge Operations Office. July 1980.

3

4 (DOE, 1982) U.S. Department of Energy. "Recommended Seismic Hazard Levels for Oak Ridge,

S Tennessee; Paducah, Kentucky; Fernald, Ohio; and Portsmouth, Ohio." KIBD-1025/Rl. Union Carbide

6 Corporation - Nuclear Division, Oak Ridge, TN. December 1982.

7

8 (DOE, 2001a) U.S. Department of Energy. "Environmental Assessment Reindustrialization Program at

9 the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOE/EA-1346. May 2001.

10

11 (DOE, 2001b) U.S. Department of Energy. "Environmental Assessment: Winterization Activities in

12 Preparation for Cold Standby at the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOE/EA-1392.

13 June 2001.

14

15 (DOE, 2001c) U.S. Department of Energy. "Portsmouth Annual Environmental Data for 2000, Piketon,

16 Ohio." DOE/OR/11-3077&DI. Prepared by EQ Midwest. December 2001.

17

18 (DOE, 2002a) U.S. Department of Energy. Data transmittal from Takacs (U.S. Department of Energy,

19 Oak Ridge Operations Office, Piketon, Ohio) to H. Hartmann (Argonne National Laboratory, Argonne,

20 Illinois). June. 2002.

21

22 (DOE,-2002b) U.S. Department of Energy. "U.S. Department of Energy Portsmouth Annual

23 Environmental Report for 2001 Piketon, Ohio." DOE/OR/I 1-3106&D I. EQ Midwest, Inc. November

24 2002.

25

26 (DOE, 2002c) U.S. Department of Energy. "Environmental Assessment Quadrant II Corrective Measures

27 Implementation at the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOEIEA-1459. December

28 2002.

29

30 (DOE, 2003a) U.S. Department of Energy. Letter from Mr. R. J. Vranicar (Portsmouth Site Office) to

31 Mr. D. Snyder (Ohio Historic Preservation Office), RE: Phase II Archaeological Testing Report at Site

32 33PK210. September 19,2003.

33

34 (DOE, 2003b) U.S. Department of Energy. "Portsmouth Annual Environmental Report for 2002."

35 DOE/OR/I 1-3132 & Dl. EQ Midwest, Inc. October 2003.

36 <http://www.bechteljacobs.com/ports-reports.shtml> (Accessed 11/15/2004).

37

38 (DOE, 2004a) U.S. Department of Energy. "Final Environmental Impact Statement for Construction and

39 Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio Site."

40 DOE/EIS-0360. June 2004. <http://www.eh.doe.gov/nepaleis/eisO360/> (Accessed 11/15/2004).

3-77
I (DOE, 2004b) U.S. Department of Energy. "Risk-Based End State Vision and Variance Report for the

2 Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOE/ORI1 1-3137&DI. May 2004.

3 <http:llwww.bechteljacobs.com/ports-reports.shtml> (Accessed 11/15/2004).

4

5 (DOE, 2004c) U.S. Department of Energy. "Portsmouth Annual Environmental Report for 2003."

6 DOE/OR] 11-3152 & Dl. EQ Midwest, Inc. November 2004.

7 <http://www.bechteljacobs.com/ports-reports.shtml>

8

9 (DuVall & Associates, 2003) DuVall & Associates. "Phase II Archeological Testing at Site 33PK210,

10 Scioto Township, Pike County, Ohio." July 2003.

11

12 (EPA, 2003a) U.S. Environmental Protection Agency. "AirData: NET Facility Emissions Report." 2003.

13 <http://www.epa.gov/air/data/index.html> (Accessed 2/2003).

14

15 (EPA, 2003b) U.S. Environmental Protection Agency. "National Ambient Air Quality Standards

16 (NAAQS)." 2003. <http://www.epa.gov/air/criteria.html> (Accessed 6/7/2005).

17

18 (EPA, 2004) U.S. Environmental Protection Agency. "Green Book Nonattainment Areas for Criteria

19 Pollutants." 2004. <http://www.epa.gov/oar/oaqpslgreenbk/o3co.html> (Accessed 6/7/2005).

20

21 (ERDA, 1977) Energy Research and Development Administration. "Final Environmental Impact

22 Statement: Portsmouth Gaseous Diffusion Plant Site, Piketon, Ohio," Vol. 2. ERDA-1555. 1977.

23

24 (FBI, 2000) Federal Bureau of Investigation. "Section VI Law Enforcement Personnel," Crime in the

25 United States 2000 Uniform Crime Reports. 2000. <http://www.fbi.gov/ucr/cius_00/00crime6.pdf>

26 (Accessed 4/11/2003).

27

28 (Fujita, 1971) Fujita. "Proposed Characterization of Tornadoes and Hurricanes by Area and Intensity."

29 Satellite and Meteorology Research Paper, 91, The University of Chicago, Chicago, IL 42 pp. 1971.

30

31 (Geraghty & Miller, Inc., 1989) Geraghty & Miller, Inc. "Ground-Water Quality Assessment of Four

32 RCRA Units, Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." May 1989.

33

34 (Hendershot et al., 1990) Hendershot et al. "Soil Survey of Pike County, Ohio." U.S. Department of

35 Agriculture, Soil Conservation Service, Ohio Department of Natural Resources, Division of Soil and

36 Water Conservation, Ohio Agricultural Research and Development Center. 1990.

37

38 (Holzworth, 1972) Holzworth, G.C. "Mixing Heights, Wind Speeds, and Potential for Urban Air

39 Pollution Throughout the Contiguous United States." EPA, AP-101. RTP, North Carolina. January 1972.

40

41 (HUD, 2002) U.S. Department of Housing. "The Noise Guidebook," Community Planning and

42 Development. June 5, 2002.

43

44 (Mills, 1914) Mills. As referenced in Schweikert, 1997.

45

46 (MMES, 1993) Martin Marietta Energy Systems, Inc. "Portsmouth Gaseous Diffusion Plant,

47 Environmental Report for 1992." ES/ESH-37 (POEF-3030). Prepared by Martin Marietta Energy

48 Systems, Inc. for U.S. Department of Energy. September 1993.

49

50 (National Climatic Data Center, 2004) National Climatic Data Center. "Normals, Means and Extremes,

5 1 Climatological Normals: 1941-2000." U.S. Climate Statistics. 2004.

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1 (NRC, 2003) U.S. Nuclear Regulatory Commission. "Environmental Review Guidance for License

2 Actions Associated with NMSS Programs." NUREG-1748. Final Report. August 2003.

3

4 (NRC, 2004a) U.S. Nuclear Regulatory Commission. "Environmental Assessment of the USEC Inc.

5 American Centrifuge Lead Cascade Facility in Piketon, Ohio." Office of Nuclear Material Safety and

6 Safeguards. January 2004.

7

8 (NRC, 2004b) U.S. Nuclear Regulatory Commission. "How Does Radiation Affect the Public." 2004.

9 <http://www.nrc.gov/what-we-do/radiation/affect.html> (Accessed 11/9/2004).

10

11 (NRC, 2005) U.S. Nuclear Regulatory Commission. "Memorandum and Order." CLI-05-05. NRC

12 Docket No. 70-3103. January 18, 2005.

13

14 (ODNR, 2003) Ohio Department of Natural Resources. Letter from Ms. D. Woischke (OHNR) to Mr. P.

15 Miner (USEC), RE: Natural Heritage Maps and Files. December 1, 2003.

16

17 (ODNR, 2005. Ohio Department of Natural Resources. "100-Year Flood Hazard Areas - Pike County."

18 2005. <http://www.dnr.state.oh.us/gims/report.asp> (Accessed 6/8/2005).

19

20 (ODOD, 2003) Ohio Department of Development. "Ohio County Profiles." Office of Strategic Research.

21 September 2003.

22

23 (OEPA, 1998) Ohio Environmental Protection Agency. "Biological and Water Quality Study of Little

24 Beaver and Big Beaver Creek-1997, Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." June 4, 1998.

25

26 (Ohio Department of Taxation, 2003) Ohio Department of Taxation. "Annual Report. October 2003.

27 <http://tax.ohio.gov/divisions/communicationslpublications/annualreports/publications annual report_2

28 003.stm>.

29

30 (OHPO, 1994) Ohio Historic Preservation Office. Letter from Mr. D. Snyder (OHPO), to Mr. R. Meehan

31 (U.S. Department of Energy), RE: Cultural Resource Management Plan, Portsmouth Gaseous Diffusion

32 Plant. January 10, 1994.

33

34 (OHPO, 1995) Ohio Historic Preservation Office. Letter from Ms. M. Raymond (OHPO), to Ms. D.

35 Perkins (U.S. Department of Energy), RE: X-7725A Building Modification, Portsmouth Gaseous

36 Diffusion Plant. July 17, 1995.

37

38 (OHPO, 2004) Ohio Historic Preservation Office. Letter from Ms. B. Powers (OHPO) to Mr. G. Sea, RE:

39 Barns House, Piketon, Pike County, Ohio. December 22, 2004.

40

41 (OMB, 1978) Office of Management and Budget. "Statistical Policy Directive No. 14: Definition of

42 Poverty for Statistical Purposes." May 1978.

43 <http://www.census.gov/hhes/poverty/povmeas/ombdirl4.html> (Accessed 6/7/2005).

44

45 (PFD, 2005) Portsmouth Fire Department Website. 2005.

46 <http://www.ci.portsmouth.oh.us/departments/fire/index.html> (Accessed 5/20/2005).

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I II

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2 (Schweikert, 1997) Schweikart, J.F., Coleman, K., and Church, F. "Phase I Archaeological Survey for the

3 Portsmouth Gaseous Diffusion Plant (PORTS Facility) in Scioto and Seal Townships, Pike County,

4 Ohio" (submitted to, and copies available from, the U.S. Department of Energy). ASC Group. 1997.

S

6 (Scioto County Government, 2005) Scioto County Government. "Greater Portsmouth Regional Airport."

7 2005. <http://www.sciotocountyohio.com/airport.htm> (Accessed 6/13/2005).

8

9 (Squier and Davis, 1848) Squier and Davis. As referenced in Schweikert 1997, p. 7.

10

11 (Storm Prediction Center, 2002) "Historical Tornado Data Archive." Storm Prediction Center. 2002.

12 <http://www.spc.noaa.gov/archive/tomadoes/index.html> (Accessed 6/2002).

13

14 (U.S. ACE, 1987) U.S. Army Corps of Engineers. "Corps of Engineers Wetlands Delineation Manual."

15 Technical Report Y-87-1. Department of the Army. 1987.

16

17 (U.S. Census Bureau, 2000) U.S. Census Bureau. "Profiles of General Demographic Characteristics:

18 2000 Census of Population and Housing, Ohio. U.S. Department of Commerce. 2000.

19 <http://www.census.gov/prod/cen2000/dp 1/2kh39.pdf (Accessed 5/24/2004).

20

21 (U.S. Census Bureau, 2002) U.S. Census Bureau. "Census 2000 Summary File 3." 2002.

22 <http://www.census.gov/Press-Release/www/2002/sumfile3.html> (Accessed 6/10/2005).

23

24 (U.S. Census Bureau, 2005a) U.S. Census Bureau. "Preliminary Estimate of Weighted Average Poverty

25 Thresholds for 2004." January 24, 2005.

26 <http://www.census.gov/hhes/www/poverty/threshld/04prelim.html> (Accessed 6/10/2005).

27

28 (U.S. Census Bureau, 2005b) U.S. Census Bureau. "Poverty Thresholds 2004." January 28, 2005.

29 <http://www.census.gov/hhes/poverty/threshld/threshO4.html> (Accessed 6/7/2005).

30

31 (USDA, 1990) U.S. Department of Agriculture. "Soil Survey of Pike County, Ohio." 1990.

32

33 (USEC, 2003) United States Enrichment Corporation. "Environmental Report for American Centrifuge

34 Lead Cascade Facility at USEC's Facilities in Piketon, Ohio." LA-2605-0002. February 2003.

35

36 (USEC, 2004a) United States Enrichment Corporation. "License Application for the American

37 Centrifuge Plant in Piketon, Ohio." Revision 0. NRC Docket No. 70-7004. August 2004.

38

39 (USEC, 2004b) USEC Inc. E-mail correspondence entitled "Data on Surrounding Areas." February 9,

40 2004.

41

42 (USEC, 2005) United States Enrichment Corporation. "Environmental Report for the American

43 Centrifuge Plan in Piketon, Ohio." Revision 3. Docket No. 70-7004. July 2005.

44

45 (USFA, 2005) U.S. Fire Administration. National Fire Department Census Database. 2005.

46 <http://www.usfa.fema.gov/applications/census/> (Accessed 5/20/2005).

47

48 (Yost, 2005) Yost, Kevin, (Pike Soil and Water Conservation District). Personal communication, RE:

49 Prime Farmlands on the DOE Reservation. June 17, 2005.

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4. ENVIRONMENTAL IMPACTS

4.1 Introduction

This chapter evaluates the potential environmental impacts of the proposed action and the no-action

alternative. Other reasonable alternatives that have been considered, including the construction and

operation of the American Centrifuge Plant (ACP) at the Paducah Gaseous Diffusion Planit in Paducah,

Kentucky, have been eliminated from detailed study for reasons explained in Chapter 2 and are not

evaluated further in this chapter.

The chapter analyzes the four ACP life-cycle stages, as well as the corresponding cessation of uranium

enrichment operations at the Paducah Gaseous Diffusion Plant, as described in Section 2.1 Even though

the cessation of operations at Paducah is not part of the U.S. Nuclear Regulatory Commission's (NRC's)

proposed action, it is evaluated in this Draft Environmental Impact Statement (EIS) because it would

eventually result from the proposed action (USEC, 2005a). For the purpose of this analysis, 'cessation of

uranium enrichment operations at Paducah would include stopping uranium enrichment plant operations,

but would not include decommissioning of the Paducah Gaseous Diffusion Plant, changes to any other

activities at that site, or any alternate uses of the site in the future. Those other actions at Paducah would

be the subject of subsequent decisions and environmental reviews.

Section 4.2 analyzes the proposed action, which would include construction, operation, and

decommissioning of the proposed ACP in Piketon, Ohio. This section starts with 13 different sections

that evaluate the potential impacts to different resource areas (land use, transportation, geology and soils,

water resources, etc.). Within each of these resource areas, potential impacts are evaluated for: (1) ACP

site preparation and construction; (2) ACP operation; and (3) cessation of uranium enrichment operations

at the Paducah Gaseous Diffusion Plant.

Determination of the Signifi cance of Potential Environmental Impacts

A standard of significance has been establishedfor assessing environmental impacts. Based on the

Council of Environmental Quality's regulations, each impact is to be assigned one of thefollowing

three significance levels:

* Small: The environmental effects are not detectable or are so minor that they would neither

destabilize nor noticeably alter any important attribute of the resource.

* Moderate: The environmental effects are sufficient to noticeably alter but not destabilize

important attributes of the resource.

* Large: The environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

Source: NRC, 2003.

28 Section 4.2 also evaluates the potential impacts associated with the proposed manufacturing of centrifuges

29 necessary for the ACP, much of which'is expected to occur offsite. The impacts associated with shipping

30 centrifuges or centrifuge components into the U.S. Department of Energy(DOE) reservation by truck are

31 evaluated in different parts within Section 4.2 dealing with transportation (see Sections 4.2.2 and

32 4.2.11.1). However, because many of the details of the proposed centrifuge manufacturing process itself

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I are either proprietary or controlled for security reasons, this phase of the proposed action is discussed

2 more generally in this Draft EIS at the end of the 13 resource areas evaluated for site preparation and

3 construction and facility operation (see Section 4.2.14).

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The last part of Section 4.2 (Section 4.2.15) provides an initial evaluation of the potential environmental

impacts of the decontamination and decommissioning of the ACP. Because decommissioning would take

place well in the future, it is not possible to predict exactly how the plant would be decommissioned. For

this reason, the NRC staff requires that an applicant for decommissioning of a uranium enrichment

facility submit a License Termination Application and Decommissioning Plan to the NRC at least 12

months prior to the expiration of the NRC license (Title 10 of the Code of Federal Regulations [10 CFR]

§ 70.38). The staff will conduct a separate and more detailed review of the potential environmental

impacts associated with the ACP decommissioning at that time, in support of its review of the applicant's

submittal, and before making any decisions regarding license termination.

Section 4.3 evaluates anticipated cumulative impacts associated with the proposed action. It recaps the

specific impacts of the proposed action as presented in Section 4.2, describes past, present, and

reasonably foreseeable future actions that relate to the proposed action, and evaluates the magnitude and

significance of potential "cumulative effects," meaning effects of the proposed action combined with

effects of reasonably foreseeable future actions.

Finally, Section 4.4 evaluates the potential impacts of the no-action alternative, which would involve

continuing to operate the Paducah Gaseous Diffusion Plant and not developing the ACP at any site. This

evaluation serves as a baseline for comparison to the potential impacts of the proposed action.

4.2 Impacts of the Proposed Action

Under the proposed action, USEC, Inc. (USEC) would construct and operate the ACP at Piketon and

cease uranium enrichment plant operations at the Paducah Gaseous Diffusion Plant. At the end of its life,

the ACP would be decontaminated and decommissioned. The potential environmental impacts of this

proposed action are evaluated below for each of the potentially affected environmental resources.

4.2.1 Land Use Impacts

This section reviews the potential land use impacts associated with site preparation and construction

activities, facility operation, and ceasing operations at the Paducah Gaseous Diffusion Plant.

4.2.1.1 Site Preparation and Construction

As described in Section 2. 1, the majority of the site preparation and construction activities associated with

the proposed ACP would occur within the 526-hectare (1,300-acre) central area of the DOE reservation.

The proposed ACP would be situated on approximately 81 hectares (200 acres) in the southwest quadrant

of the central area. The only facilities associated with the ACP that would be outside the central area

would be a newly constructed 10-hectare (24-acre) cylinder storage yard (X-745H) and an existing 1.3-

hectare (3-acre) cylinder storage yard (X-745G-2) located in the northern portion of the reservation, just

outside of Perimeter Road. In addition to these facilities, approximately 1 hectare (2.5 acres) of new

roads and parking areas would be constructed. Figure 2-5 in Chapter 2 presents the location of the

proposed primary and secondary new facilities and proposed primary and secondary refurbished facilities

associated with the proposed ACP. As discussed in Section 2.1.3, primary facilities are those that are

critical to the enrichment process, while secondary facilities provide indirect support to the process. As

shown in Table 2-1, 18 new facilities (including buildings and cylinder storage yards) and 16 existing or

refurbished facilities would be associated with the proposed ACP.

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I All of the proposed ACP facilities in the southwest quadrant of the central area would be located adjacent

2 to each other, and the X-745G-2 and X-745H Cylinder Storage Yards would be located adjacent to one

3 another in the northern portion of the reservation. The total footprint for the proposed new and

4 refurbished facilities in the southwest quadrant of the central area of the reservation would occupy

5 approximately 24 hectares (60 acres). The remaining 57 hectares (140 acres) occupied by the proposed

6 ACP in this area would be maintained as lawn or open space. Site preparation and construction activities

7 within this central area would result in a small impact on land use because there would be no change in

8 the'overall land use of the central area. In addition, the soil types present in the southwest quadrant are

9 non-prime soils, so this construction would not affect prime farmland (Borchelt, 2003).

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11 The construction of the X-745H Cylinder Storage Yard in the northern part of the reservationjust north of

12 Perimeter Road would remove 10 hectares (25 acres) of managed grassland and old fields and convert it

13 into part of the developed infrastructure associated with the DOE reservation (USEC, 2005a). This

14 cylinder storage yard would be located approximately 600 meters (1,969 feet) southeast from the nearest

15 reservation boundary and would be surrounded by existing forested land to the north,' east, and west, and

16 by the central area to the south. The conversion of 10 hectares (25 acres) of managed grassland and old

17 fields into a paved cylinder storage yard would result in a small impact on land use at the reservation

18 because approximately one percent of the area outside of Perimeter Road (10 hectares [25 acres]) would

19 change from its current land use.

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21 The proposed location of the X-745H Cylinder Storage Yard contains two soil types, Urban land-Omulga

22 complex and Omulga silt loam.' While some Omnulga soils are considered prime'farmland, the soils at this

23 'location do not qualify as such because of the slope and because Urban land-Omulga complex s'oils in

24 particular are not prime farmland. Therefore, construction of the new X-745H Cylinder Storage Yard

25 would not affect prime farmland (Yost, 2005).'

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27 The other cylinder storage yard north of Perimeter Road, X-745G-2 consisting of 1.3 hectares (3 acres),

28 already exists but might require some minor refurbishment for use by the proposed ACP. Because this

29 yard is already paved and intended for this purpose, any minor refurbishment for the proposed ACP

30 should result in no new land use impacts.

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32 The proposed action would not impact land use outside of the DOE reservation at Piketon. The nearest

33 reservation boundary is approximately 800 meters (2,625 feet) to the west of the X-3001 Building, and

34 600 meters (1,969 feet) from the proposed cylinder storage yard. The site preparation and construction

35 activities would not preclude or alter any of the existing land uses outside of the reservation. Because

36 there are no State parks or national parks, conservation areas, or designated wild and scenic rivers within

37 the immediate vicinity of the reservation, such areas would not be affected. Moreover, during

38 construction of the proposed ACP, all equipment, supplies, temporary structures (construction trailers),

39 and staging and storage areas would be located on previously disturbed land (parking lots or managed

40 lawns) and would not require the removal or modification of any buffer areas or structures (USEC,

41 2005a).

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43 In total, site preparation and construction would physically change approximately 22 hectares (55 acres)

44 of land on the DOE reservation. These physical changes would be'minor, because: (1) the area to be

45 occupied by the proposed ACP would be only a small portion of the 1,497-hectare (3,700-acre)

46 reservation; (2) the majority of the proposed land has been previously disturbed; (3) no prime farmland

47 would be affected; and (4) site preparation and construction would not affect or preclude any existing

48 land uses on the property that surrounds the DOE reservation. The changes would simply convert the

49 land use on the DOE reservation from managed lawns, fields, and limited forest buffer to developed

50 areas, resulting in an overall SMALL impact.

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4.2.1.2 Facility Operation

The operation of the proposed ACP, including the new cylinder storage yards, would not result in any

additional changes in land use on the DOE reservation, would not preclude any foreseeable land uses on

the reservation, and would not affect or preclude any existing land uses on the property that surround the

reservation. A recent DOE Environmental Assessment, which considered the land use impacts of the

proposed ACP, found that the new facility would present no land use conflicts with any proposed future

land use planning efforts on the DOE reservation or the surrounding area (DOE, 2001 a). Therefore, the

land use impacts of facility operation would be SMALL.

4.2.1.3 Ceasing Operations at Paducah

Ceasing enrichment plant operations at Paducah would not result in any change in land use. It is

anticipated that after the Paducah enrichment plant is shut down, the existing buildings and structures

would remain on the site and the site would remain categorized for industrial use, pending any later

decisions on decommissioning and future use. Therefore, land use impacts associated with ceasing

operations at Paducah would be SMALL.

4.2.2 Historic and Cultural Resources Impacts

The NRC staff evaluated potential effects of the proposed action on historic and cultural resources in

accordance with the Advisory Council on Historic Preservation Regulations (specifically 36 CFR Part

800) (see Appendix B, Consultation Letters). As defined in 36 CFR § 800.16(i), "Effect means alteration

to the characteristics of a historic property qualifying it for inclusion in or eligibility for the National

Register." This may include direct effects such as disturbance or destruction of buildings or

archaeological deposits; as well as indirect effects such as alteration of setting or vandalism of buildings

and sites by workers.

Under 36 CFR § 800.4, once a Federal agency identifies and evaluates properties to determine whether

they are eligible, it considers project effects. It may determine that there are "no historic properties

affected" if there are no historic properties present or there are historic properties present but the

undertaking will have no effect upon them as defined in 36 CFR § 800.16(i). If an adverse effect is found

that will be resolved by redesign or mitigation measures, the agency may determine that there is "no

adverse effect." In considering effect, the agency applies the criteria of adverse effect to historic

properties within the area of potential effects (see text box in this subsection). The criteria of adverse

effect are defined at 36 CFR § 800.5(a):

An adverse effect isfound when an undertaking may alter, directlyor indirectly, any ofthe characteristics

of a historic property that qualify the propertyfor inclusion in the National Register in a manner that

would diminish the integrity of the property's location, design, setting, materials, workmanshipfeeling,

or association. Consideration shall be given to all qualifying characteristics of a historic property,

including those that may have been identified subsequent to the original evaluation of the property's

eligibilityfor the National Register. Adverse effects may include reasonablyforeseeable effects caused

by the undertaking that may occur later in time, befarther removed in distance or be cumulative.

4-4

11
Properties within the Area of Potential Effect

The area ofpotential effect for direct effects includes thefootprint of all ground disturbing activities

and the perimeter of all buildings to be refurbished plus a 100-meter (328-foot) buffer around such

areas (see Chapter 3for more discussion). There is one historic property within the area ofpotential

effect for direct effects, the Portsmouth Gaseous Diffusion Plant historic district considered by the

State Historic Preservation Officer to be eligible under Criterion Afor listing on the National

Register. There are no otherproperties within the area ofpotential effectfor direct effects that were

identified as potentially eligible for listing on the National Register.

The area ofpotential effectfor indirect effects includes all lands and structures within the reservation

boundary (see Chapter 3for more discussion). In addition to the Register-eligible historic district,

there are 13 historic farmsteads and one prehistoric lithic scatter within the area ofpotential effect

for indirect effects that the NRC staff considered as potentially eligible for listing under Criterion D,

although State Historic Preservation Officer concurrence has not been received on their status as

historic properties. In addition, the NRC staff included in the consideration of effect three properties

located outside the area ofpotential effectfor.indirect effects, but close to its boundary. One is the

Scioto Township Works site that is listed on the National Register under Criterion D and that has

cultural value to the Absentee Shawnee Tribe. This site extends to within 250 meters (820feet) of the

area ofpotential effect boundary. A second property, the Barnes House, which may be eligiblefor

listing under Criteria A and C, is immediately adjacent to the area ofpotential effect boundary. A

ihirdproperty, the Bailey Chapel, listed on the Ohio Historic Inventory but not the National Register,

is also adjacent to the area ofpotential effect boundary.

I The following sections evaluate potential effects for site preparation and construction activities for the

2 -proposed ACP operations, and for the corresponding cessation of uranium enrichment activities at the

3 Paducah Gaseous Diffusion Plant.

4

5 4.2.2.1 Site Preparation and Construction

6

7 Site preparation and construction activities have the potential to directly affect the Portsmouth Gaseous

8 Diffusion Plant historic district by destroying or altering contributing elements. If not properly

9 controlled, these activities could indirectly affect the district by altering the setting, feeling, orfassociation

10 of the district. However, in consultation with the State Historic Preservation Officer, the NRC staff has

11 determined that the construction of new buildings and refurbishment of the existing buildings under the

12 proposed action would result in'buildings of design, size, and function similar to the existing buildings

13 (OHPO, 2004; OHPO, 2005). While there might be a short-term alteration in the feeling of the district

14 during site preparation and construction, the net result would be no effect on the historic property.

15

16 Site preparation and construction activities also have the potential to indirectly affect the 14 potentially

17 Register-eligible sites within the area of potential effect for indirect effects by exposing them to

18 vandalism by workers that might remove information important to history or prehistory. However,-

19 because the surface materials on these'sites were recorded and portable artifacts were collected during

20 prior study, and because workers would be expected to remain within designated work areas, the NRC

21 staff considers that the likelihood of damage from vandalism would be small. Based on these factors, the

22 NRC staff concludes that there would be no effect on these properties. However, USEC may elect to

23 provide education programs and implement formal constraints on worker movements that would further

24 minimize the likelihood of vandalism affecting a potentially register-eligible site.

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1 Because the Scioto Township Works site is located one kilometer (0.62 mile) from the construction area

2 and outside the fenced reservation boundary' vandalism from project construction workers would be even

3 less likely than for sites within the area of potential effect. Consequently, the NRC staff considers that

4 there would be no project effect on the information values that make the site eligible under Criterion D.

5 The setting and feeling of the site that may contribute to its cultural importance to the Shawnee have been

S 6previously affected by agricultural activities, quarrying, and construction and use of U.S. Route 23. The

7 appearance of the proposed ACP complex on the DOE reservation as viewed from the site would not

8 change substantially as a result of construction; as indicated above and discussed in more detail in Section

9 4.2.3, the new and refurbished buildings would be similar to existing buildings. Thus, the proposed

10 action would not change the existing setting or feeling of the site, and the NRC staff finds that the

I I proposed construction activities on the reservation would have no effect on the Scioto Township Works.

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The NRC staff also finds that there would be no effect on the potentially eligible Barnes House. Given its

location approximately 800 meters (2,600 feet) from Perimeter Road and the closest construction

activities, site preparation and construction would not directly affect attributes of the property that may

contribute to its architectural significance under Criterion C. Because the appearance of the industrial

complex on the reservation would not be altered substantially by the construction, the project would not

alter the existing setting, feeling, or association of the site that may contribute to its historic significance

under Criterion A.

The Bailey Chapel is located even farther from the proposed site preparation and construction activities

than the Barnes House, well away from any potential direct effect on the chapel building. The new

construction would not change the character of the industrial complex or its current contribution to the

existing setting. Thus, NRC finds no effect associated with the proposed action on this property.

In the unlikely event that human remains are encountered during site preparation and construction

activities (excavation), USEC would comply with the Native American Graves Protection and

Repatriation Act regulations. This includes up to a 30-day work stoppage, notice to management, and

screening of the find by a qualified archaeologist. If determined to be necessary, work would be stopped

until completion of consultations that may be required under the National Historic Preservation Act or the

Native American Graves Protection and Repatriation Act. (USEC, 2005a)

Based on this evaluation and the procedures that USEC would implement, the effects of proposed site

preparation and construction activities on historic and cultural resources would be SMALL.

4.2.2.2 Facility Operation

Facility operation would involve the regular presence of personnel on the DOE reservation and movement

of trucks in and out and within the reservation. These activities would be consistent with the activities

that characterized the Portsmouth Gaseous Diffusion Plant historic district during earlier operations, as

well as current site activities to a more limited extent. In consultation with the State Historic Preservation

Officer, the NRC staff has determined that these proposed new activities for the ACP would have no

effect on the historic district (Epstein, 2004).

Operations could have an indirect effect if workers vandalized the potentially eligible farmstead sites and

lithic scatter sites outside of Perimeter Road. However, as with the potential effects of site preparation

and construction, the NRC staff considers that the likelihood of damage from vandalism would be small,

should it occur, because the surface materials on these sites were recorded and portable artifacts were

collected during prior study and because workers would be expected to remain within designated work

areas. Based on these factors, the NRC staff concludes that there would be no adverse effect on these

properties from facility operation.

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1 Because the Scioto Township Works site is located outside the fenced reservation boundary, vandalism

2 from operations workers would be even less likely than for sites within the area of potential effect.

3 Consequently, the NRC staff considers 'that there would be no effect on the information values that make

4 the site eligible under Criterion D. Operation of the proposed facility would cause no change in existing

5 setting or feeling of the site. The NRC staff thus finds that the operation of the new and refurbished

6 facilities on the reservation would have no effect on the Scioto Township Works.

7

8 Operation of the facility also would cause no change in the existing setting or feeling of either the Bames

9 House or Bailey Chapel. Facility operation would involv'e the regular presence of personnel on the DOE

10 reservation and movement of trucks in and out and within the reservation. These activities would be

11 consistent with the current operations on the reservation. Consequently, NRC finds that the operation of

12 'the new and refurbished facilities on the reservation would have no effect on these properties.

13

14 The NRC staff also finds that there would be no effect on potential earthworks located near the DOE

15 wellfields.' As indicated in Section 4.2.6.2, additional pumping from water supply wells is not expected to

16 cause subsidence for several reasons:

17

18 * The increase in consumption would be only 10 percent higher than current withdrawal rates and

19 would represent only 31 percent of the total design capacity (and currently permitted rate) -of the well

20 field groundwater withdrawal system.

21

22 * The three well fields are located approximately 8, 11, and 24 kilometers (5, 7, and 15 miles) from the

23 DOE reservation boundary along the Scioto River, and are spaced between 16 to 24 kilometris (10 to

24 15 miles) apart. The wells within each well field (between 4 and 15 individual wells) are located

25 within 2 to 6 kilometers (I to 3 miles) of each other. Therefore, the increased withdrawals will come

26 from several spaced-out locations, rather than being all concentrated in one location.

27

28 * The wells produce water from the shallow saturated sand and gravel layers adjacent to the Scioto

29 River. The sand and gravel layers are recharged from water in the river. Computer models have

30 shown that 50 to 88 percent of the water drawn from the wells is from the river, and the chemical

31 ' character of the groundwater is influenced by the river (Nortz et al., 1994). Therefore, any water

32 withdrawn from the ground would be replaced by water from the river, and there would not be a

33 decline in groundwater levels.

34

35 * Conversations with the Ohio EPA have confirned that subsidence and sink holes from groundwater

36 withdrawal are not an issue in the region, as water would be drawn down from the Scioto River,

37 rather than create a void (Ohio EPA, 2005).

38

39 Based on this evaluation, the effects of proposed ACP operations on historic and cultural resources are

40 expected to be SMALL.

41

42 4.2.2.3 Ceasing Operations at Paducah

43

44 Cessation of operations at the Paducah enrichment plant would not involve any excavation or disturbance

45 of soils or the subsurface, or removal or external modification of buildings or structures. There would

46 generally be a decrease in airborne emissions, a decrease in liquid and solid wastes generated and

47 disposed, a decrease in the onsite workforce, and a decrease in surrounding traffic. Therefore, 'the impacts

48 on historic or cultural resources associated with ceasing operations at Paducah would be SMALL.

4-7
1 4.2.3 Visual and Scenic Impacts

2

3 As described in Section 3.4, the DOE reservation currently has a Class III or IV designation under the

4 U.S. Bureau of Land Management's classification system. This means that the existing scenic value of

5 the reservation is moderate to low, as the dominant viewshed consists of buildings, cylinder storage yards,

6 transmission lines, and open and forested buffer areas. No scenic rivers, nature preserves, or unique

7 visual resources exist in the project area.

8

9 4.2.3.1 Site Preparation and Construction

10

11 About half of the facilities needed for the proposed ACP, including two of the four large process

12 buildings (28,242 square meters [304,000 square feet]), already exist in the southwest quadrant of the

13 reservation's central area. While the new buildings and cylinder storage yards needed in this area would

14 result in the loss of approximately 12 hectares (30 acres) of fields and lawns, the new facilities would be

15 architecturally similar and would blend in with the existing facilities at this location. When driving on

16 Perimeter Road surrounding the central area, the proposed ACP facilities in the southwest quadrant would

17 be difficult to discern and would not in any way change the existing industrial setting of the site.

18 Moreover, the existing and new facilities would generally not be visible from off the DOE reservation,

19 because views along the property line are limited by distance, rolling terrain, and heavy forests and

20 vegetation. Therefore, the proposed ACP facilities in the southwest quadrant of the reservation's central

21 area would cause SMALL impacts on visual and scenic resources.

22

23 Site preparation and construction activities needed for the new 10-hectare (25-acre) cylinder storage yard

24 (X-745H) north of Perimeter Road would occur within managed grasslands and old fields adjacent to

25 tributaries of Little Beaver Creek. As described in Section 4.2.7.1, USEC would convert managed

26 grasslands and old fields to a flat paved surface and would not remove any of the adjacent upland mixed

27 hardwood forest or riparian forest. This would change the visual and scenic quality of this particular

28 location, but it would not substantially alter the present look and feel of the area or of the reservation as a

29 whole. The area in the vicinity of the new cylinder storage yard already contains other storage yards that

30 are smaller but look the same (including the roughly 2.6-hectare [6.2-acre] X-745G Cylinder Storage

31 Yard, half of which would be used for the proposed ACP). The new cylinder storage yard also would be

32 right across the Perimeter Road from the reservation's industrialized central area and would not be visible

33 from off the reservation, for reasons stated above. Therefore, although a more noticeable change than the

34 new facilities within the central area, the new yard would also cause SMALL impacts to visual and scenic

35 resources.

36

37 4.2.3.2 Facility Operation

38

39 All operations would be conducted within the proposed ACP buildings, at the cylinder storage yards, and

40 along the existing roadway network. These operations would not create any new visual impacts (e.g.,

41 they would not result in the release of a visible plume to the air) and would not generate much new or

42 different looking activity than already exists. Therefore, the impacts of facility operations on visual and

43 scenic resources would be SMALL.

44

45 4.2.33 Ceasing Operations at Paducah

46

47 Cessation of operations at the Paducah enrichment plant would not involve any excavation or disturbance

48 of soils, or removal or external modification of buildings or structures. Therefore, the impacts on visual

49 or scenic resources would be SMALL.

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1 4.2.4 Air Quality Impacts

2

3 This section analyzes airborne emissions of non-radiological and radiological contaminants and compares

4 those emissions to air permit limits and/or air quality standards. The public and occupational exposures

5 and health impacts associated with these emissions are addressed in Section 4.2.12.

6

7 4.2.4.1 Site Preparation and Construction

8

9 The following subsections discuss the non-radiological emissions and the radiological emissions

10 associated with the site preparation and construction phase of the proposed action.

11.-,.-. ..

12 Non-Radiological Emissions

13

14 Table 2-1 in Chapter 2 of this Draft EIS identifies the primary facilities that would be constructed to

1 5 '-support the proposed ACP at the 7 million separative work unit (SWU) capacity. That construction'

16 would disturb a footprint of approximately 21 hectares (52 acres). In addition to the area needed for

17 buildings and cylinder storage yards reported in Table 2-1, another I hectare (2.5 acres) of earth would be

18 disturbed in preparation for roads and parking areas. Taken together, site preparation and construction

19 activities would disturb approximately 22 hectares (55 acres).

20

21 Estimates of fugitive dust that would be emitted from land disturbance over this area were determined

22 based on information using AP-42 emission factors (EPA, 1995a) for construction or, where more

23 - detailed information was available, by using fugitive dust emission factors based on the 2004 KWAP

24 Fugitive Dust Handbook (WRAP, 2004) as appropriate for a mid-west based location. Fugitive dust

25 emissions were estimated for construction and demolition, materials handling, and traffic along paved

26 roads. Because the new buildings identified in Table 2-1 previously had their foundations prepared, soil

27 disturbance was assumed to be limited to construction activities associated with the installation of the

28 utilities.

29

30 Exhaust emissions associated with heavy earth-moving equipment would also result in short-term

31 increases in the release of nitrogen oxides, sulfur oxides, carbon monoxide, and particulates, including

32 particulate matter equal to or less than 10 micrometers in diameter and equal to or less than 2.5

33 micrometers in diameter.1 The NRC staff estimated these emissions by using information provided in the

34 Environmental Report (USEC, 2005a) on the estimated total fuel consumption for construction activities,

35 the anticipated diesel and gas powered construction equipment and the estimated daily fuel consumption,

36 and reasonable assumptions made by USEC that influence the amount of fuel that would have to be used -

37 during construction (see Tables 4.6.3.1-2,4.6.3.1-3, and 4.6.3.1-4 in USEC, 2005a). This information

38 was used in combination'with the U.S. Environmental Protection Agency's (EPA's) Non-Road emission

39 factors from EPA's NR-009c, 0O1d, 012b (EPA, 2004a; EPA, 2004b; EPA, 2004c) to develop exhaust

40 emissions estimates, assuming use of "Tier I equipment" (typically late 1990s to early 2000s model-year

41 equipment depending on 'engine horsepower rating). -Also included in the emission estimates were the

42 emissions associated with construction crew trips to and from the facility each day. As estimated by

43 USEC in its Environmental Report (USEC; 2005a), those trips include 2,612 one-way construction

44 worker trips (1,306 commuting round trips) and an average of approximately 10 round trips of heavy-duty

45 delivery trucks associated with construction material and building supplies. USEC assumed that each

In evaluating impacts relating to the criteria pollutants, the NRC staff did not review potential impacts relating

to ozone, including emissions of volatile organic compounds that are precursors to the production of ozone. Pike

County is in attainment for ozone, which is generally recognized as a regional-scale air quality problem; therefore,

the potential site-specific increases in the emission of volatile organic compounds would not affect regional ozone

concentrations.

4-9
I worker would arrive as a single-occupant vehicle and that half the vehicles would be light-duty trucks and

2 half would be light-duty vehicles.

3

4 Once the estimates of airborne emissions were developed, the NRC staff then input those values into an

5 air dispersion model to estimate the air quality impacts from the proposed site preparation and

6 construction activities. The Industrial Source Complex Long-Term (EPA, 1995b) air dispersion model

7 was used to estimate quarterly and annual average air concentrations at the facility boundary. Short term

8 peak concentrations were then estimated by using scaling factors based on the maximum modeled

9 concentration (EPA, 1992). In developing these estimates, the NRC staff used meteorologic data

10 obtained from the 30-meter (98-foot) tower at the DOE reservation at Piketon as inputs to the model,

11 combined with selected other meteorological data from the nearest archived meteorological data locations

12 (in Waverly, Ohio and Huntington, West Virginia). Additional modeling details included the following:

13 emission sources were modeled as uniform area sources at their site-specific locations; emissions were

14 assumed to occur eight hours per day, 250 days per year; and emissions were estimated on a quarterly

15 basis for each of the five years needed for the majority of the proposed site preparation and construction

16 activities.

17

18 The results from this analysis are summarized in Table 4-1. This table shows predicted concentrations of

19 the criteria pollutants over different time frames at the reservation property boundary. These predicted

20 concentrations are added to concentrations measured at the nearest air quality monitoring station, which

21 are reported in Table 4-1 as "background" values. Since ambient air quality data for the pollutants

22 reported in Table 4-1 are not measured at the proposed ACP site, the NRC staff used monitoring data

23 from the nearest monitoring site, located in Portsmouth, Ohio, as representative background values. The

24 table then compares the sum of the maximum modeled and measured concentrations to the National

25 Ambient Air Quality Standards.

26

27 As shown in Table 4-1, all modeled concentrations from site preparation and construction activities are

28 below the National Ambient Air Quality Standard for each criteria pollutant with the exception of the

29 annual average concentration of particulate matter with a mean diameter of 2.5 micrometers or less. The

30 predicted annual average concentration of particulate matter with a mean diameter of 2.5 micrometers or

31 less is 16.1 micrograms per cubic meter, which slightly exceeds the National Ambient Air Quality

32 Standard of 15 micrograms per cubic meter up to a distance of 1,000 meters (3,280 feet) beyond the

33 fenceline. While emissions from soil disturbance and burning of fossil fuel associated with proposed

34 ACP site preparation and construction contribute to this exceedance, the vast majority of the exceedance

35 is the result of high background concentrations for particulate matter with a mean diameter of 2.5

36 micrometers or less in the area. The site is located in a county that is exempt from restrictions on

37 emissions for fugitive dust specified in Ohio Administrative Code 3745-17-08. However, to avoid

38 nuisance conditions and particulate matter concerns, USEC intends to use dust suppression techniques

39 (e.g., water sprays and speed limits on dirt roadways) to mitigate releases of dust during excavation under

40 dry conditions (USEC, 2005a). As a result, the non-radiological air quality impacts from site preparation

41 and construction of the proposed ACP facility are considered MODERATE.

42

43 The NRC staff recommends additional mitigation measures to reduce the predicted impacts associated

44 with particulate matter emissions. The staff's modeling results indicate that the majority of emissions are

45 expected to come from construction vehicle exhaust, rather than automobile (worker vehicle) exhaust or

46 fugitive dust from land disturbance activities. To reduce particulate emissions from construction vehicle

47 exhaust, the NRC staff recommends that USEC: (1) use Tier 2 construction-related vehicles (2001 to

48 2006-model year equipment), which would reduce diesel particulate matter emissions by about 40

49 percent; and (2) use ultra-low sulfur diesel fuel (15 parts per million versus the current typical fraction of

50 500 parts per million), which would reduce particulate matter emissions by about 20 percent. If USEC

51 implements these two additional mitigation measures, the NRC expects that the non-radiological air

52 quality impacts from site preparation and construction would be reduced to SMALL.

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Table 4-1 Predicted Property Boundary Air Concentrations from Site Preparation and

Construction Activities and Applicable National Ambient Air Quality Standards (pg/m3 ) s

Species b Value ' | 1-hr 3-hr 8-hr 24-hr Annual

Modeled 262 . 236 * 184 . 105 26 ;___.__ .............. .. __.......4 __. _ _._ _ ......... . ..;__._ .. ..._ ___._4_........ ..._

Background 8,360 6,070 *

Model + Background 8,622 6,254 F _ .._.---------------- . _...4 .... _ . _ _ .......... __ ..... _...... .._..____.......

- NAAQS I 40,000 10,000 -

A Modeled 36.5 32.9 25.6 14.6 3.7

i_. ------------- - ----------- . ~. ... ._ .. 4. .... .... . ....-.- .Z...... . . -.... . ... ... -_... ._

Background 177 5 - 32

N 02 ;- - ---*-- - --- --.----.--.-.. I-*-------- .... .... . ... ._ _.__.. Model + Background 214 . . -. -- 36 ... _ *--*----4 4--4 _ _ . .. ......I.... .... ...

NAAQS 100

Modeled 23 21 16 9.2. 2.3 ._ _. ........ ......-..-........ ..... .. _...; .... .

Background 49 19.7 ...................... .............................. . ............ ...- ....... Model + Background 58 22 ._._._--..----___ .. 4.......

NAAQS . - ._-_*_- _._ 150 50

Modeled 23 20 16 9.1 - 2.3 - ._ _._.___ -..... -- _-. ___ . __ -.. -- .----------- . _ d_....__ ..... __._ ...... . . ._.... ------- --- _._--_

Background 41.3 13.8

PM2M

Model + Background 50.4 16.1 ;. _._ . . .. __........- __-.-;- . ___-.._... _ -._ . .. __....__ ..... .......__

.5 NAAQS - 5 -_5_--_5_' _ 65 15

Modeled 4.2 I 3.8 I 3 1.7 04 ' ' ~ r - - ~ ~- -~ ----------- -- --------- - --- -- - ----------- 

so2 . Background 5 - 5 309 5 - 5 110 10

S_2._... __....- .. -'-....... 4 -- *--*----*--- .......... 

Model+Background - 5 313 112 5 10.4 - - 4 -. ------ '-----------------''------'---'''-'--......

5 ' NAAQS - 5 1,300 5 - 365 80

Notes:

mpgm =icrogram per cubic meter.

b CO = carbon monoxide; NO2 = nitrogen dioxide; PM,, = particulate matter with a mean diameter of 10 micrometers or less;

PM2, = particulate matter with a mean diameter of 2.5 micrometers or less; S2 = sulfur dioxide.

' NAAQS - National Ambient Air Quality Standard.

Radioloeical Emissions

Airborne radiological emissions from the proposed ACP would be regulated by the U.S. EPA under 40

CFR Part 61 Subpart H, the National Emissions Standards for Hazardous Air Pollutants. The limits

imposed by these standards are based upon the estimated radiation dose to the public, not the quantity of

material released.

During site preparation and construction activities, the decontamination and decommissioning of the

existing Gas Centrifuge Enrichment Plant enrichment train could result in the release of airborne

contamination. The residual contamination level in these old enrichment centrifuges is low, and two

levels -of airborne contamination control would be applied to minimize releases. First, best management

practices would be employed, including temporary containment structures and localized air filtration to

minimize the consequence of any release. Second,'the buildings in which the work would be performed

utilize air filtration and trapping systems in order to capture any releases. This dual containment system

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I combined with the small quantity of uranium present in the Gas Centrifuge Enrichment Plant train ensure

2 that any air quality impact from decontamination and decommissioning of the existing gas centrifuge

3 facilities would be SMALL.

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Radiological emissions could also occur during construction activities when soil is excavated. If the soil

contains radioactive material, this material could be included in any dust suspended during construction.

USEC plans to excavate approximately 146,956 cubic meters (192,099 cubic yards) of soil; the low

concentration of radioactive materials in the soil to be excavated could result in a maximum expected

release of radionuclides from this excavation of 2,760 grams of uranium-238, 6.7 grams of uranium-235,

0.038 grams of uranium-234, and 0.014 grams of technetium-99. Based on these small expected releases,

the air quality impact of any radiological dust emissions during construction is expected to be SMALL.

Based on this analysis, the radiological impacts to air quality from site preparation and construction

would be SMALL. The public health impacts of these radiological emissions are examined in Section

4.2.12.2.

4.2.4.2 Facility Operation

Non-Radioloeical Emissions

During routine operation of the proposed ACP, principal non-radiological pollutants would come from

the exhaust of stationary diesel generators used for emergency power if supplied power is lost. Each of

the 26 aboveground fuel storage tanks proposed for the proposed ACP would have a 900-horsepower,

600-kilowatt emergency diesel generator. These generators would be operated periodically for testing

purposes and for scheduled preventive maintenance. Because the emergency diesel generators are

expected to operate for less than 500 hours per year, they are exempt from Federal and Ohio air

permitting. Airborne emissions are also possible from the 26 aboveground tanks themselves, each of

which would have the capacity to store up to 4 cubic meters (1,000 gallons) of fuel except for two tanks

that would have a capacity of 151 cubic meters (40,000 gallons) each. Emissions from these tanks,

however, would be very small because they would hold diesel and No. 2 fuel oil, which are not significant

sources of volatile organic emissions (emissions from the tanks should be less than the emissions

associated with the firing of the diesel generators).

The NRC staff's quantitative analysis, therefore, focused on the long-term and short-term air quality

impacts from the operation of the 26 generators. This analysis used emissions estimated by USEC

assuming the generators were operated at full power, consuming 0.19 cubic meter per hour (50 gallons

per hour) of low sulfur number two diesel (0.05 percent sulfur) (USEC, 2005a). These emissions

estimates were then input into the same air dispersion model by using the same meteorological data:

described in Section 4.2.4.1. Modeling was performed for continuous operation and then scaled using a

factor of 500/8760. Short-term concentrations were based on continuous operations. Emissions were

modeled as point sources using stack parameters from a 1,109 horsepower diesel generator described in

Appendix 7 of the California Air Resources Board's Diesel Risk Reduction Plan (CARB, 2000), except

that a 10-meter (33-foot) stack was used to minimize any building downwash effects.

Table 4-2 shows the results of this modeling analysis, including the modeled concentrations expected to

result from the generator operations plus representative background values compared to the National

Ambient Air Quality Standard (as in Table 4-1 in Section 4.2.4.1). As presented in Table 4-2, all air

concentrations expected to result from the operation of the 26 emergency diesel generators are well below

the National Ambient Air Quality Standard for each criteria pollutant. Therefore, the non-radiological air

quality impacts from operation of the proposed ACP are expected to be SMALL.

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Table 4-2 Predicted Property-Boundary Air Concentrations from Operation of 26

Emergency Diesel Generators and Applicable National Ambient Air Quality Standards (pg/mr3)

Species b Value' 1-hr 3-hr 8-hr | 24-hr J Annual

Modeled 142 1 128 99 57 1 0.3 -****-4**.*..** ***I'***-------------.-. -

Background 8,360 - 6,070

Co i...-.- --- , .....-..-----.......... . .....- *-- --.----.....---

Model + Background . 8,502 -- 6,169 - . --

i __._ _- ----.- 4------- .. *-3 .----_---- ... . .. . . .......... _ 4 .... ... _4- -- -.-----. 4..... . .

*. NAAQS 40,000 *. - . 10,000 . - -. --

Modeled 204 184 143 82 1.2 -_ - .---- - - ----- -_ - - ----- - _-_-_- . __ ....... .-------------. 4 -.---.----- __-----------_

NO Background 177 32 2 i_ --.-.- *-*- -@-- ---- ~~~~~~--*-- 4--*----------*;*-.. ---.-*-- ----. * *;- ;..

Model + Background 381 34

*_--_NAAQS .- 100

Modeled 3.7 * 3.3 2.6 1.5 <0.1 ...... .. ........................... . . . ... ......................... 

M Background ---.- - . 49 * 19.7

Model + Background *50.5 * 19.8 _._ _._... -. ____ . _ - ...... . ..... ....... ...._.... . ..... _. ...... 

*NAAQS * - * - . -- * 150 * 50

Modeled 3.5 3.2 2.5 1.4 <0.1

PM25

__ __ .... _ ._.... _ ...... __ 4_. ..... .. _ ... 4._._ . .....- 1.... . 4__... . .... . __4__....._--- --

Background - - - * 41.3 I 13.8

4..,.__....._._ ...... -.-- .- _4 ........... .... 4 .....-.... -. -

Model + Background *. --- - -- 42.7 * 13.9 .. ..---- , -.----. __ _....._ 4 ---- -_- - - --- 4...._ . ..... .__...... .... .

NAAQS 65 15

Modeled 3.2 . 2.9 2.2 1.3 <0.1

Background 309 - : 110 10 S O2 .................. -------.------------------ *....................... ...........

Model + Background - 312 . - 11 10.1

NAAQS - 1,300 . -- 365 80

* pgfn9 = micrograms per cubic meter. b CO = carbon monoxide; NO2 = nitrogen dioxide; PM,, - particulate matter with a mean diameter of 10 micrometers or less;

PM,, = particulate matter with a mean diameter of 2.5 micrometers or less; SO2 = sulfur dioxide.

NAAQS = National Ambient Air Quality Standard.

The primary non-radiological air pollutant associated with the operation of the proposed ACP is hydrogen

fluoride (HF). When UF6 is released to the air, it reacts with atmospheric moisture to form particulate

uranium (in the form of uranyl fluoride) and HF fumes. For this Draft EIS, airborne concentrations of HF

at various downwind locations were modeled using the stoichiometry of the UF6 reaction with

atmospheric moisture, as described in Section 4.2.12.3 on the public dose from routine airborne releases

of radioactive material. As shown in Table 4-21 in that section, the maximum predicted HF concentration

is 2.35 x I O' microgram per cubic meter at the Ohio National Guard building located onsite 555 meters

(1,820 feet) east of the proposed ACP buildings. This concentration is more than six orders of magnitude

below the Occupational Safety and Health Administration Permissible Exposure Limit (as an eight-hour

average) of 2,500 micrograms per cubic meter for HF. Therefore, the impacts associated with anticipated

HF concentrations in the air resulting from proposed ACP operations should be SMALL

4-13
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4

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6

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12

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50

Radiological Emissions

Potential sources of airborne radiological releases for the proposed ACP are:

* X-3346 Feed and Customer Services Building;

* X-3001, X-3002, X-3003, and X-3004 Process Buildings;

* X-3356 Product and Tails Withdrawal Building;

* X-3012 Process Support Building;

* X-7725 Recycle/Assembly Facility;

* X-7726 Centrifuge Training and Test Facility;

* X-7 10 Laboratory; and

* X-7727H Interplant Transfer Corridor.

Ventilation air from the first seven locations listed above would be monitored under the site Radiation

Protection Program. Environmental Compliance personnel would review summaries of the monitoring

data at least quarterly to verify that ventilation exhausts are insignificant as defined in NUREG-1520,

Standard Review Planfor the Review of a License Application for a Fuel Cycle Facility, which is a value

less than 1.11 x 10' becquerels per milliliter (3 x 10-' microcuries per milliliter) of uranium.

The eighth location listed above, the X-7727H Interplant Transfer Corridor, would never be exposed to

open centrifuges or components, but does have some air transfer from the process buildings and X-7725

Facility. At worst, the airborne uranium concentration in the X-7727H Corridor would not eiceed that in

the process buildings or X-7725 Facility.

Each process vent in the X-3001, X-3002, X-3003, X-3004, X-3346, X-3356, and X-7725 Buildings

would have gas flow monitoring instrumentation with local readout as well as analytical instrumentation

to continuously sample, monitor, and alarm UF6breakthrough in the effluent gas stream. The continuous

vent sampler would draw a flow proportional sample of the vent stream through two alumina traps in

series by way of an isokinetic probe. Both vent and sampler flows would be monitored by the sampler's

electronic controller. The controller adjusts a control valve in the sample line to maintain a constant ratio

between the vent and sample flows. The flow instruments would be calibrated at least annually. The

primary sample trap would be equipped with an automated radiation monitor to continuously monitor the

accumulation of uranium in the sampler.

Detailed emission calculations would be based on laboratory analysis of the collected samples. Each vent

sampler would have two traps permanently dedicated to each trap position, with one in-service and the

other either being processed or standing by to replace the in-service trap. Normally, the primary sample

trapsiwould be replaced weekly and the secondary traps replaced quarterly. In the event of an unplanned

or seriously elevated release, the involved sampler traps would be collected for immediate analysis as

soon as the situation has stabilized. Alternatively, the sampling period may be extended, provided the

sampler is operating continuously while the vent is operating. A hydrated alumina would be used in the

vent samplers to convert absorbed UF6 to uranyl fluoride for laboratory analysis.

Vent samples would be analyzed for uranium-234, uranium-235, uranium-238, and technetium-99

(technetium-99 is a fission product that has contaminated much of the fuel cycle as a result of past

recycling of reprocessed uranium). Experience at the gaseous diffusion plant has shown that these three

uranium isotopes account for more than 99 percent of the public dose due to uranium emissions. Feed

material that meets the'Amierican Society of Testing and Materials specification for recycled feed may be

used in the proposed ACP, which may contain additional radionuclides (i.e., uranium-236 and

technetium-99). The proposed ACP would monitor process vent samples for technetium as a

4-14

Il
I precautionary measure since experience at the gaseous diffusion plant indicates the potential for

2 technetium-99 to eventually appear in some gaseous effluents.

3

4 The maximum gaseous effluent anticipated under normal operations is 9.6 x 1 O' becquerels (0.003 curies)

5 of uranium over a week, or up to 5.1 x I09 becquerels per year (0.14 curies per year) (USEC, 2005a). The

6 NRC staff estimated that the projected maximum airborne concentration of total uranium due to proposed

7 ACP operations is only 2.0 x 10. becquerels per milliliter (5.4 x I O-` microcuries per milliliter). This

8 uranium concentration is less than one percent of the applicable concentration limit in 10 CFR Part 20,

9 Appendix B, Table 2. Average emission rates are expected to be much lower.

10

11 Radiological releases to air would be routinely monitored to ensure that releases are at or below the

12 expected quantities. DOE collects data from a monitoring network of 15 ambient air samplers; this

13 network is described in the DOE site environmental report for 2002 (DOE, 2003), among other places.

14 The monitoring network is intended to assess whether radiological air emissions from the DOE

15 reservation affect air quality in the surrounding area. Data are collected both onsite and in the area

16 surrounding the DOE reservation. A background ambient air monitoring station is located approximately

17 21 kilometers (13 miles) southwest of the site. The analytical results from air sampling stations closer to

18 the plant are compared to background measurements (DOE, 2003).

19

20 Based on the maximum radiological emission rates for the proposed ACP and the comprehensive site

21 monitoring program, the expected impact on air quality from radiological emissions is expected to be

22 SMALL.

23

24 4.2.4.3 Ceasing Operations at Paducah

25

26 Ceasing operations at Paducah would decrease airborne emissions from those associated with current

27 operation of the Paducah enrichment plant. Air quality impacts fromrnon-radiological and radiological

28 process and fugitive air emissions sources would be largely eliminated after cessation of operations. Air

29 emissions after enrichment operations are shut down would be limited to combustion emissions from

30 onsite utilities (e.g., boilers), combustion emissions from the operation of vehicles and equipment by the

31 maintenance and security workforce, and fugitive particulate emissions from plant property and operation

32 of vehicles on paved roads.

33

34 Fugitive particulate emissions would not be directly affected by cessation of enrichment plant operations.

35 Existing fugitive dust management systems and procedures would be maintained after cessation of plant

36 operations. Other than fugitive dust potentially containing radionuclides, no radiological air emissions

37 are anticipated to occur once the enrichment operations are ceased. Air emissions of hazardous air

38 pollutants could potentially result from maintenance activities, but such emissions would be lower than

39 those associated with current plant operations.

40

41 Based on this analysis, the air quality impacts associated with the cessation of operations at Paducah are

42 expected to be SMALL.

43

44 4.2.5 Geology and Soil Impacts

45

46 This section assesses potential impacts on geologic resources and soils during site preparation and

47 construction and operation of the proposed ACP,-along with the corresponding impacts associated with

48 the cessation of gaseous diffusion operations at Paducah (centrifuge manufacturing and decommissioning

49 of the proposed ACP are discussed separately in Sections 4.2.14 and 4.2.15, respectively). Impacts could

50 result from planned excavation activities for the proposed ACP or spills that could cause soil

5 1 contamination. There are no known mineral deposits on the proposed ACP site; therefore, there would be

4-15
1 no impacts to mineral resources. Chapter 3 describes site soil, which is heavily altered due to past

2 construction activities. The soils at and nearby the site are not considered prime farmland due to low

3 fertility, previous disturbance, and slope (Borchelt, 2003; Yost, 2005).

4

5 4.2.5.1 Site Preparation and Construction

6

7 Site preparation and construction activities for the proposed ACP would occur primarily within the

8 southwest quadrant of the DOE reservation's central area, as described in Section 2.1. In total, activities

9 needed to construct new facilities in the central area would disturb approximately 12 hectares (30 acres).

10 All of these activities would occur within an existing industrial facility with natural soils already altered

11 as a result of mixing from previous cut and fill activities. The terrain in this area is flat and the new

12 construction would not alter existing drainage patterns. Soils exposed during construction would be

13 temporarily susceptible to increased erosion caused by wind or rain, but any such erosion would be very

14 minor and short lived.

15

16 Cylinder Storage Yard X-745H, occupying 10 hectares (25 acres), would be constructed just north of

17 Perimeter Road in an area containing managed grasslands and old fields with a small portion of upland

18 forest. It has approximately 15 meters (50 feet) of topographical expression and is located between two

19 tributaries to Little Beaver Creek. The majority of the topography and soils in this area have been

20 previously disturbed and altered (USEC, 2005a). Construction of this yard would include cut and fill of

21 approximately 10,000 cubic yards during a construction period of 24 months. During excavation and

22 grading, the steep slopes would be more susceptible to soil erosion and the streams at the bottom of the

23 slopes may receive an increased amount of silt. Engineering controls and best management practices

24 would be implemented to minimize the extent of excavation. Disturbed areas would, to the extent

25 practicable, be controlled to minimize erosion and sediment runoff; for example, USEC would implement

26 best management practices, such as minimizing the area of disturbance, erosion control ditches,

27 temporary vegetation seeding, and silt fencing, during construction to minimize erosion and siltation of

28 streams (USEC, 2005a).

29

30 Site preparation and construction activities could also result in spills of oils, lubricants, and other

31 materials from construction equipment. USEC would take precautions in accordance with applicable

32 laws and best management practices to avoid accidental releases to the environment; this would include

33 the use of liquid effluent tanks, holding ponds with oil diversion devices, and spill response equipment

34 and procedures (USEC, 2005a). In addition, in accordance with best management practices, all USEC

35 employees would be provided with required training to ensure that personnel adequately understand the

36 hazards associated with the materials they are handling and understand procedures for spill response

37 (USEC, 2005b). Spill response equipment, such as patch kits, sewer plugs, vacuum trucks, storage

38 tankers, oil skimmers, spill response trailers, portable pumps, and portable lighting would also be

39 maintained onsite (USEC, 2005b). Because of such precautions, spills should be small and occasional,

40 and the response to such spills would be prompt and would contain and remove material that had been

41 released or contaminated.

42

43 In summary, most of the site is an existing industrial facility with altered natural soils. Natural soils are

44 cohesive and over-consolidated and have low potential for liquefaction. There is little likelihood of

45 impact from soil compaction or subsidence. The flat terrain in the central area, and the dense soil, low

46 moisture content, and vegetative cover in the majority of the X-745H Cylinder Yard Area make landslides

47 unlikely. Construction activities would not alter current drainage and would not disturb any soils that

48 qualify for protection as prime farmland (Yost, 2005). There would be a potential for increased erosion

49 and siltation of streams near the construction site of Cylinder Storage Yard X-745H, as well as the

50 potential for soil contamination from spills or leaks from construction equipment, but both of these

51 potential impacts should be minimized by the use of standard best management practices, such as

4-16

1l
1 minimizing the area of disturbance, erosion control ditches, temporary vegetation seeding, and silt

2 fencing, during construction to minimize erosion and siltation of streams (USEC, 2005a). The overall

3 impacts on soils during'site preparation and construction activities would therefore be SMALL.

4

5 4.2.5.2 Facility Operation

6

7 Operations potentially impacting soils include spills from production activities in the Feed and Customer

8 Services Building and the Product and Tails Withdrawal Building, both of which would be located within

9 the central area of the DOE reservation. Floors inside these buildings would be sealed and spill

10 containment systems would be in place. Gaseous releases associated with cylinder connections and

11 equipment upsets would quickly convert to solid uranyl fluoride, which typically would be collected via a

12 gulper system that filters out the particulates; however, some uranyl fluoride may settle onto the floor

13 (USEC, 2004c). Any such contamination would be collected in the liquid effluent collection system,

14 which would consist of a series of tanks located throughout the ACP. Because the building construction

15 and spill control systems make it unlikely that any spills inside these buildings will reach outside soils,

16 the potential for soil impacts from this scenario is SMALL.

17

18 Normal operations would also release small amounts of uranium and fluoride to the air, which may be

19 deposited onto soils'downwind of the facility. Section 4.2.4.2 describes the potential releases from'

20 facility operations to air. Because these anticipated release and deposition rates are expected to be very

21 minor, the potential for soil contamination at downwind locations would be SMALL.

22

23 UF6 transfer and storage activities would occur at cylinder storage yards within the central area of the

24 reservation and at the X-745G-2 and X-745H Cylinder Storage Yards north of Perimeter Road. These

25 storage yards would be constructed of thick high-pressure concrete with a smooth troweled surface. The

26 surface of the concrete would be sealed to prevent infiltration of materials. Cylinders in the storage yards

27 would contain solid UF6; therefore, there is no potential for liquid UF6 release. Spills of other hazardous

28 material, such as oils or lubricants from the cylinder handling equipment, would be isolated and cleaned

29 up using spill containment and control equipment located at the storage pads. Because the yards are flat,

30 any spilled liquids or any contamination suspended in storm water runoff could travel to the edge of the

31 pad and migrate onto adjacent soil. If such contamination -did reach the soil, mitigation measures would

32 consist of delineating the extent of the contamination and removing it. Therefore, any resulting soil

33 impacts would be temporary, localized, and SMALL.

34

35 There are no major geologic faults in the vicinity of the proposed ACP and there have been no historical

36 earthquake epicenters within 40 kilometers (25 miles) of the site. For the Gas Centrifuge Enrichment

37 Plant design in the 1980s, the maximum earthquake was defined as one with a mean recurrence interval of

38 1,000 years. The general design-basis earthquake for the proposed ACP is also based on a 1,000-year

39 return period. Building X-3346A was designed at a higher safety margin with a design basis earthquake

40 of 10,000-year return period. As a result of the probability of an event occurring and the large distance of

41 a potential event to the site, any potential impacts from seismicity are expected to be SMALL.

42

43 4.2.5.3 Ceasing Operations at Paducah

44

45 Ceasing operations at the Paducah enrichment plant would not involve any excavation or disturbance of

46 soils or the subsurface. Therefore, the impacts to geology and soils associated with this action would be

47 SMALL.

4-17
1 4.2.6 Water Resource Impacts

2

3 This section assesses potential impacts of the proposed action on water resources, not including wetlands.

4 Potential impacts to wetlands are covered in the ecological impact assessment included in Section 4.2.7.

5

6 4.2.6.1 Site Preparation and Construction

7

8 The following subsections discuss the potential impacts on surface water, floodplains, and groundwater

9 associated with the site preparation and construction phase of the proposed action.

10

11 Surface Water

12

13 During the site preparation and construction activities, 15 buildings and one cylinder storage yard would

14 be refurbished, and a total of 12 hectares (30 acres) of new buildings, facilities, and storage yards would

15 be constructed within the southwest quadrant of the central area. In addition to these facilities, a new 10-

16 hectare (25-acre) cylinder storage yard would be constructed outside of the central area, just north of

17 Perimeter Road, in the northern portion of the DOE reservation. Because land disturbance activities

18 would involve more than 2 hectares (5 acres), a National Pollutant Discharge Elimination System permit

19 that would specify and regulate the quality of storm water runoff would need to be issued by the Ohio

20 EPA. The site preparation and construction activities within the central area would drain to the DOE

21 Piketon Tributary and the West Ditch, as those two surface water features are downgradient from the

22 proposed land disturbing areas. The site preparation and construction activities associated with the 10-

23 hectare (25-acre) X-745H Cylinder Storage would drain to two unnamed tributaries as well as Little

24 Beaver Creek, which are immediately downgradient of the proposed storage yard. All of these surface

25 waters discharge into the Scioto River.

26

27 Site preparation and construction activities in the southwest quadrant of the central area would involve

28 land clearing, excavation, and minimal additional grading (the land in this area has already been leveled

29 as part of earlier site preparation and construction activities). Such disturbances would result in a

30 temporary increase in soil erosion and sedimentation in adjoining ditches during the 24-month

l 31 construction period, which could increase turbidity and alter other water quality parameters (e.g.,

32 dissolved oxygen, pH, hardness levels, and chemical concentrations). However, because the onsite runoff

33 and associated sediments would discharge into holding ponds, which have been designed to reduce such

34 impacts, and would then discharge into the regulated portion of the West Ditch and the DOE Piketon

35 Tributary, such impacts would be considered SMALL. The erosion and resulting sedimentation would

36 not alter or preclude the designated uses of the West Ditch or Piketon Tributary, as presented in Section

37 3.7, nor would it affect the designated use and associated water quality criteria of the Scioto River.

38

39 Site preparation and construction activities for X-745H Cylinder Storage Yard outside of the Peri 'meter

40 Road in the northern portion of the reservation would result in more extensive soil disturbances, as

41 described in Section 4.2.5.1. The X-745H Cylinder Storage Yard would be located on a relatively flat

42 grasslands and old fields bounded on the south by the Perimeter Road; on the east by an unnamed

43 tributary to Little Beaver Creek (adjacent to the North Access Road); on the west by the eastern drainage

44 channel to, and the discharge from, the X-230L North Holding Pond; and on the north by the valley of

45 Little Beaver Creek. The proposed cylinder storage yard would be located in an upland area at

46 approximately 660 feet above mean sea level at its southern end dipping to 640 feet above mean sea level

47 at the northern elevation. While this area is adjacent to riparian and upland forests and wetland areas of

48 the Little Beaver Creek and its tributaries, the proposed construction would not require removal of or

49 disturbance in those areas (USEC, 2005c).

4-18

II
1 Nevertheless, site preparation and construction activities for the new cylinder storage yard would result in

2 a temporary increase in erosion and sedimentation during the 24-month construction period. The runoff,

3 if not controlled, would directly enter the unnamed tributaries as well as Little Beaver Creek. Because of

4 the size of the area to be disturbed (10 hectares' [25 acres]), the steep topography, the extent of cut and fill

5 activities needed, and the proximity to Little Beaver Creek, which is a State Resource Water that exhibits

6 exceptional ecological values and/or exceptional recreational values (as defined in OAC 3745-1-09 for

7 the Scioto River Drainage Basin), the erosion and sediments that could enter the creek could result in a

8 MODERATE impact. Implementation of the best management practices described in Section 4.2.5.1 on

9 soil impacts, together with USEC's plan to not disturb-the upland mixed hardwood forest and the'riparian

10 forest adjacent to the managed field and old field (USEC, 2005c), would reduce this potentially

11 MODERATE impact to a SMALL impact. Such measures would reduce the level and amount of erosion

12 and sedimentation that would occur in the adjacent surface waters. With the implementation of these

13 mitigation measures, the site preparation and construction activities needed for X-745H Cylinder Storage

14 Yard also would not affect the designated use and associated water quality criteria'of the Scioto River.

15

16 Sanitary wastewater associated with the site preparation and construction activities (up to 814 cubic:

17 meters per day [215,000 gallons per day]) would be treated at the Sewage Treatment Plant (Building X18 6619). Currently, this plant treats approximately 909 cubic meters per day (240,000 gallons per day) and

19 has a design capacity of 2,275 cubic meters per day (601,000 gallons per day). Effluent from the sewage

20 treatment plant would discharge directly to the Scioto River via a pipeline that is regulated under a

21 National Pollutant Discharge Elimination System permit. The additional 814 cubic meters per day

22 (215,000 gallons per day) would represent a 90 percent increase in the wastewater currently processed at

23 the sanitary treatment plant; however, the total processed wastewater would represent 75 percent of the

24 plant's total design capacity (USEC, 2005a). The additional wastewater would not affect the status or

25 water quality criteria of the permit. As a result, the additional wastewater discharge during site

26 preparation and construction activities would cause an overall SMALL impact on surface water resources.

27

28 Finally, small and occasional spills or leaks of petroleum-based products (e.g., diesel fuel or oil) or

29 hazardous materials associated with construction equipment could cause SMALL impacts to surface

30 waters adjacent to site preparation and construction activities. To prevent such impacts, all temporary

31 storage tanks or sheds that contain such material would have secondary containment features (berms or

32 dikes to contain spilled contents), and would have appropriate spill response equipment appropriate for

33 the materials present. In addition, trained and qualified spill response and clean-up professionals would

34 respond to incidental or accidental releases of petroleum-based products or hazardous materials in

35 accordance with the United States Enrichment Corporation's Spill Prevention Control and

36 Countermeasures Plan and best management practices (United States Enrichment Corporation, 2004; and

37 USEC, 2005b). The Spill Prevention Control and Countermeasures Plan would be revised to explicitly

38 address the proposed ACP (USEC, 2005a).

39

40 Floodplains

41

42 None of the proposed site preparation and construction activities would occur within a 100-year

43 floodplain. The clearing of 22 hectares (55 acres) of managed lawns, fields, and forested areas would

44 result in increased storm water runoff; however, the DOE reservation has a storm water management

45 system of open and closed culverts and ditches, as well as a series of holding ponds that have been

46 designed to control storm water runoff (USEC, 2005a; USEC, 2004c). Because none of the proposed site

47 preparation and construction' activities would occur within a 100-year floodplain, and the DOE

48 reservation has an existing storm water management system, the impacts on floodplains would be

49 SMALL.

- 4-19
I Groundwater

2

3 Groundwater is approximately 9 meters (30 feet) below ground surface within the proposed site

4 preparation and construction areas. Because this depth would be well below the depth of excavation

5 needed for the proposed new facilities, groundwater would not be directly impacted during site

6 preparation or construction activities. As presented in Section 3.7.3, the proposed site preparation and

7 construction activities would not occur in areas directly overlying contaminated groundwater.

8

9 If they occur, spills or leaks of petroleum-based products (e.g., diesel fuel or oil) or hazardous materials

10 associated with construction equipment could be potential sources of groundwater contamination.

11 Implementation of the best management practices described in Section 4.2.5.1 on soil impacts, as well as

12 providing for secondary containment features for all temporary storage tanks or sheds, and maintaining

13 spill response equipment appropriate for the materials present, would reduce the potential impact of a

14 release. In addition, trained and qualified spill response and clean-up professionals would respond to

15 incidental or accidental releases of petroleum-based products or hazardous materials in accordance with

16 the site's Spill Prevention Control and Countermeasures Plan and best management practices (United

17 States Enrichment Corporation, 2004; USEC, 2005b).

18

19 The water that would be used during site preparation and construction activities would be drawn from

20 water supply lines present on the DOE reservation, which is drawn from a series of well fields located

21 along the Scioto River. The increased use of water during site preparation and construction

22 (approximately 814 cubic meters per day [215,000 gallons per day]) would be less than that during

23 facility operation (up to 1,995 cubic meters per day [527,000 gallons per day]) and would not impact the

24 regional groundwater supply (see Section 4.2.6.2 for additional information).

25

26 In summary, groundwater would not be directly encountered during excavation activities, should not be

27 contaminated by any new spills or leaks, and should not be depleted as a supply. As a result, any impacts

28 to groundwater caused by site preparation and construction activities are expected to be SMALL.

29

30 4.2.6.2 Facility Operation

31

32 The following subsections discuss the potential impacts on surface water, floodplains, and wetlands

33 associated with the proposed ACP operations.

34

35 Surface Water

36

37 The liquid discharges associated with operation of the proposed ACP facility include sanitary wastewater,

38 discharge from the tower water cooling system, storm water runoff, and any incidental leaks or spills.

39 The centrifuges used in the proposed ACP would be cooled via a closed-loop machine cooling water

40 system and would not result in any discharges. The heat from the machine cooling water system would

41 be transferred via a heat exchanger to the tower water cooling system. USEC does not anticipate any

42 liquid discharges of licensed radioactive materials from the proposed ACP (i.e., from sanitary wastewater,

43 cooling water, or storm water runoff). Any effluents potentially containing radioactive material would

44 have to meet the NRC standards in 10 CFR Part 20 (Standards for Protection Against Radiation) prior to

45 being discharged or would have to be disposed at a licensed facility (USEC, 2004c).

46

47 The flow from sanitary wastewater during facility operation (approximately 361 cubic meters per day

48 [95,400 gallons per day]) would feed into the onsite sewage treatment plant, which in turn discharges to

49 the Scioto River. This additional flow would represent a 40 percent increase in wastewater currently

50 processed at the plant; however, the total processed wastewater would still represent only 56 percent of

51 the plant's total design capacity (USEC, 2005a). This additional wastewater would not affect the status or

4-20

Il
1 water quality criteria of the National Pollutant Discharge Elimination System permit and would represent

2 a SMALL impact on surface water quality.

3

4 The tower water cooling system would discharge approximately 273 cubic meters per day (72,000 gallons

5 per day) of wastewater to the DOE reservation recirculating cooling water system,'which discharges to

6 the Scioto River in accordance with a National Pollutant Discharge Elimination System permit (United

7 States Enrichment Corporation Outfall 004) (see Figure 3-11 in Chapter 3). This wastewater from the

8 proposed ACP would be non-contact cooling water and would not alter the properties or quality of the

9 current wastewater discharge. The volume would be the only attribute of the wastewater that would be

10 altered relative to the current recirculating cooling water system discharge. Currently, 4,543 cubic meters

11 per day (1.2 million gallons per day) are discharged from the cooling system, so the proposed additional

12 discharge would represent a less than six percent increase in discharge rates. As such, the tower water

13 cooling discharges associated with the proposed ACP would have a SMALL impact on surface water

14 quantity and quality.

1 5

16 Storm water runoff from the ACP area would drain to a pair of existing holding ponds: the X-2230N

17 West Holding Pond (National Pollutant Discharge Elimination System Outfall 012) and the X-2230M

18 Southwest Holding Pond (National Pollutant Discharge Elimination System Outfall 013) (see Figure 3-11

19 in Chapter 3). Both of these ponds provide a quiescent zone for settling suspended solids, dissipation of

20 chlorine, and oil diversion containment. The ponds discharge to an unnamed tributaries to the Scioto

21 River. An automated sampler currently collects a weekly composite sample of the liquid effluent for

22 radiological analysis as well as samples for the National Pollutant Discharge Elimination System23 mandated analyses (USEC, 2005a). Because discharges through these ponds would continue to be

24 regulated under the National Pollutant Discharge Elimination System, and because the existing

25 monitoring systems would continue to be implemented once the ACP becomes operational, storm water

26 discharges associated with ACP operations should result in a'SMALL impact on surface water quality.

27

28 Any leakage from the machine cooling water system and incidental spills of water elsewhere in the ACP

29 would be collected by the Liquid Effluent Collection system. This system would consists of a set of

30 drains and underground collection tanks for the collection and containment of leaks and spills of

31 chemically treated water. The drains would be located throughout the ACP. The tanks would have a

32 capacity of 550 gallons each and would be monitored by liquid level gauges mounted above grade on

33 pipe stands. USEC would sample and analyze the water accumulated in the Liquid Effluent Collection

34 tanks prior to disposal. If the contents meet the requirements of 10 CFR 20.2003 (which include

35 concentration limits specified in Table 3 of Appendix B to 10 CFR Part 20), they may be pumped to the

36 reservation sanitary sewer system. Otherwise the tank contents would be containerized for offsite

37 disposal. An integrity assurance plan developed by USEC would assure the integrity of the tanks and

38 inventory monitoring of the tank contents would be used to detect leaks from the Liquid Effluent

39 Collection System. (USEC, 2004c)

40

41 A total of 26 aboveground fuel supply tanks with a total capacity of 394 cubic meters (104,000 gallons)

42 would be installed to support backup generators and boilers. These tanks would be constructed of

43 materials compatible with the product to be stored and with the conditions of storage (e.g., pressure and

44 temperature), and would meet all operational regulatory requirements, including those outlined in the

45 Spill Prevention Control and Countermeasures Plan (United States Enrichment Corporation, 2004). A

46 secondary means of containment for tanks storing petroleum products, as required by 40 CFR § 112.8,

47 would provide for the entire capacity of each aboveground storage tank, with sufficient freeboard to

48 contain precipitation in addition to any spilled fuel. All associated piping systems would conform to

49 standards for fuel distribution pressure piping, would be designed to minimize abrasion and corrosion,

50 and would allow for expansion and contraction. (USEC, 2005a)

4-21
I Special precautions would also be taken to make sure fuel is transferred into the tanks in a way that

2 minimizes the potential for accidental spills. For example, all fuel lines and tanks would be labeled in

3 accordance with regulatory standards. Spill cleanup materials, such as absorbent pads and/or spill pallets,

4 would be available at all hose connections. Standard fuel-oil delivery procedures would be followed by

5 truck drivers and receiving personnel during unloading operations at each tank. Precautions also would

6 be taken to avoid impacts from accidental releases, such as the use of safety procedures, spill prevention

7 plans, and spill response plans in accordance with Federal and State laws. Drainage from the area of the

8 aboveground tanks also runs directly to the X-2230M and X-2230N Holding Ponds, which are equipped

9 with diversion systems to prevent spilled material from reaching the Scioto River (USEC, 2005a). These

10 systems aid in preventing degradation of the overall water quality of the Scioto River because of the DOE

11 reservation activities. Based on all of these measures, the likelihood and severity of potential impacts

12 from accidental releases from the aboveground storage tanks would be minimized, and any resulting

13 impact should be SMALL.

14

15 In addition to possible releases from the storage tanks described above, incidental spills and accidental

16 releases associated with operation of the proposed ACP facility have the potential to adversely impact

17 surface waters. Such spills or releases within a building would be contained within the building via the

18 Liquid Effluent Collection system, and would be cleaned up before escaping outside. Likewise, any such

19 spills or releases outside of a building (e.g., at a cylinder storage yard) are expected to be infrequent and

20 small, would be contained within the area, and would be managed in accordance with applicable Federal

21 and State regulations. In addition, any contaminated storm water runoff would be diverted to holding

22 ponds and released through outfalls controlled under the National Pollutant Discharge Elimination

23 System. Therefore, any impacts to surface waters caused by incidental spills and accidental releases

24 should be SMALL.

l 25

26 As stated at the beginning of this section, USEC does not anticipate any liquid discharges of licensed

27 radioactive materials from the proposed ACP. Such releases would be controlled through plant design,

28 operations, and monitoring. Based on historical operating experience at the Portsmouth reservation,

29 USEC has established maximum effluent concentrations expected under normal operations of the ACP.

30 Table 4-3 lists these anticipated concentrations along with the corresponding release limits from 10 CFR

31 Part 20 for comparison. As discussed above, the Liquid Effluent Collection system contents will be

32 sampled and compared to the Table 3 limits prior to discharge. As shown, the anticipated radionuclide

33 releases are well below the NRC's limits.

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I Table 4-3 Anticipated Radionuclide Concentrations in Liquid Effluents

2 from Normal Operations

3 ._

4

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Total Uranium' Technetium

Effluent Source _ICi/mL pICmL

Liquid Effluent Control System Dischargeb <0.0000003 and <0.1 Ci/yr 1 <0.00000002 (<MDA) _ - - A...___....._...-.------- .... . ............ -----------

Tower Water Cooling System Blowdown . <0.00000003 <0.00000002 (<MDA)

X-2230N West Holding Pond <0.00000001 <0.00000002 (<MDA)

(NPDES Outfall 012)' . - ....... ... ......... _ _...... _s-._ ...........~~.

X-2230M Southwest Holding Pond <0.00000001 <0.00000002 (<MDA)

(NPDES Outfall 013)'

Sanitary wastewater (excluding discharge from the <0.00000003 <0.00000002 (<MDA)

Liquid Effluent Control System).. .. .. ... .

North Cylinder'Pad Runoff <0.00000001 i <0.00000002 (<MDA)

10 CFR Part 20, App. B, Table 2 limits ' 0.0000003 i 0.00006

10 CFR Part 20, App. B, Table 3 limits 0.000003 i 0.0006

Notes:

MDA = Minimum detectable activity; liCi/mL = microcurie per milliliter, Ci/yr = curies per year.

' Since uranium isotopes present at the ACP would have the same discharge limit, uranium isotope activities are combined

into a Total Uranium activity to simplify comparison to the Table 2 limits.

b Liquid Effluent Control effluents are characterized prior to discharge. The single Ci/yr limit reported in the table applies to

combined uranium and technetium activities.

'Anticipated concentrations are annual averages based on monthly grab samples from 1995 through 2000.

Source: USEC, 2004c.

If there are any spills or leaks containing licensed radioactive material at the ACP, they would be

collected in the Liquid Effluent Control system. If the -effluent concentration is below the 10 CFR Part

20, Appendix B requirements, as anticipated as shown in Table 4-3, then the effluent could be discharged

into the Scioto River with no significant adverse consequences. If the effluent concentration does not

meet the Part 20 requirements, then the effluent would be containerized for offsite disposal.' Any

discharges to the Scioto River would be well below regulatory'limits prior to any dilution provided by the

river.

In addition, with the exception of DOE outfall 613,'a weekly composite water sample would be collected

from all DOE National Pollutant Discharge Elimination System outfalls discharging to offsite waters and

analyzed for total uranium, uranium isotopes (uranium- 233/234, uranium-235, uranium-236, and

uranium-238), technetium-99, and transuranic radionuclides (americiumI-241, neptunium-237,

plutonium-238, and plutonium-239/240). Outfall 613 would not be monitored for radionuclides because

there is no potential source for radiological contamination of the water'discharged from this outfall. A

weekly composite water sample is also currently collected from all United States Enrichment Corporation

outfalls discharging to offsite waters 'and analyzed for total uranium, technetium-99,and transuranic

radionuclides; uranium isotopes are not analyzed (DOE, 2004b). All of this existing monitoring would

continue once the ACP becomes operational.

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I Based on this analysis, the potential surface water impacts associated with ACP effluent containing

2 radioactive material would be SMALL. Plant design, operation, and monitoring would ensure that any

3 such discharge would meet the 10 CFR Part 20 requirements, and the current and future monitoring (all

4 DOE and United States Enrichment Corporation outfalls) would ensure that such levels would be

5 maintained.

6

7 Floodplains

8

9 The operation of the proposed ACP would not impact floodplains, as none of the operations would be

10 located in a floodplain or would alter the characteristics of the floodplain.

11

12 Groundwater

13

14 The DOE reservation draws its potable and process water from three well fields in the Scioto River

15 Valley Aquifer. The maximum potential water production from the well fields is 76,000 cubic meters per

16 day (20 million gallons per day), which is also the permitted withdrawal volume. Current water use, in

17 the gaseous diffusion plant's standby mode, is less than 21,000 cubic meters per day (5.5 million gallons

18 per day). The proposed ACP would require an additional 2,500 cubic meters per day (0.65 million

19 gallons per day) for drinking, hygiene, and tower water cooling makeup (non-contact cooling water)

20 (USEC, 2005a). This additional groundwater withdrawal would result in a SMALL impact on the

21 availability of groundwater in the Scioto River Aquifer and a corresponding small risk of subsidence

22 caused by depressed groundwater levels. This conclusion is based on the following four reasons:

23

24 * The increase in consumption would be only 10 percent higher than current withdrawal rates and

25 would represent only 31 percent of the total design capacity (and currently permitted rate) of the well

26 field groundwater withdrawal system.

27

28 * The three well fields are located approximately 8, 11, and 24 kilometers (5, 7, and 15 miles) from the

29 DOE reservation boundary along the Scioto River, and are spaced between 16 to 24 kilometers (10 to

30 15 miles) apart. The wells within each well field (between 4 and 15 individual wells) are located

31 within 2 to 6 kilometers (I to 3 miles) of each other. Therefore, the increased withdrawals will come

32 from several spaced-out locations, rather than being all concentrated in one location.

33

34 * The wells produce water from the shallow saturated sand and gravel layers adjacent to the Scioto

35 River. The sand and gravel layers are recharged from water in the river. Computer models have

36 shown that 50 to 88 percent of the water drawn from the wells is from the river, and the chemical

37 character of the groundwater is influenced by the river (Nortz et al., 1994). Therefore, any water

38 withdrawn from the ground would be replaced by water from the river, and there would not be a

39 decline in groundwater levels.

40

41 * Conversations with the Ohio EPA have confirmed that subsidence and sink holes from groundwater

42 withdrawal are not an issue in the region, as water would be drawn down from the Scioto River,

43 rather than create a void (Ohio EPA, 2005).

44

45 DOE is currently performing groundwater remediation activities at the X-749/X-l20/Peter Kiewit

46 Landfill area approximately 152 meters (500 feet) south of the proposed ACP site. As a result of previous

47 landfill operations, the groundwater in the Gallia aquifer is contaminated with trichloroethene. A

48 horizontal groundwater extraction well was installed between the proposed ACP site and the Peter Kiewit

49 landfill to collect and treat contaminated groundwater. The groundwater remediation activities are not

50 located within the construction or operational footprint of the proposed ACP or its associated utilities;

51 therefore, the proposed action would not impact the ongoing groundwater remediation activities. Two

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monitoring wells are located between the contaminated area and the proposed ACP site. The wells are

monitored annually and did not show trichloroethene contamination in 2002.

Two existing underground fuel storage tanks with a total capacity of under 42 cubic meters (11,000

gallons) would be used in addition to the aboveground tanks described above. These tanks are currently

in compliance with all applicable regulations covering leak detection, corrosion protection, and

spill/overflow prevention. Therefore, any future impacts associated with the continued use of the

underground storage tanks are expected to be SMALL.'

'Spills and accidental releases associated with other operations of the proposed ACP facility 'also have the

potential to adversely'impact groundwater. Any spills'or releases within a building would be contained

within the building and would be cleaned up before' escaping'outside. Likewise, any such spills or

releases outside of a building (e.g., at a cylinder storage yard or an aboveground tank) are expected to be

infrequent and small, would be contained within the area, and would be managed in accordance with

applicable Federal and State regulations, as described in preceding sections. Therefore,' any impacts on

groundwater caused by other potential spills and accidental releases should be SMALL.

4.2.6.3 Ceasing Operations at Paducah

Ceasing'operations at Paducah would decrease impacts to water resources from those associated with

op eration of the Paduca enrichment plant. Impacts to water resources from potable water utilization and

impacts to water quality from wastewater discharges would be largely eliminated after cessation of

operations. The enrichment plant operations consume approximately 98,000 cubic meters (26 million

gallons) of potable water per day. After cessation of operations,'potable water utilization at the site would

be limited to domestic and sanitary'water use by the maintenance and security workforce and use of water

in onsite utility systems. Therefore, potable water use and associated impacts to water resources would

decrease.

Wastewater discharges and associated impacts to water quality would also decrease upon cessation of

Paducah enrichment plant operations. Wastewater discharges would be limited to sanitary wastewater

discharge associated with the maintenance and security workforce, as well as potential discharge of

blowdown of heating and cooling water from onsite utility systems. These should be far less than current

discharge levels.

Potential impacts to water quality from storm water runoff to surface water from plant property would not

be directly affected by cessation of enrichment plant operations. Existing storm water management

systems and procedures would be maintained in 'operation after cessation of plant operations.

Based on this analysis, the water resource impacts of ceasing operations at Paducah are expected to be

SMALL.

4.2.7 Ecological Impacts'

This section evaluates the potential impacts of site preparation and construction activities, facility'

operations, and ceasing operations at Paducah on fior'a and fauna; rare, threatened, and endangered

species; and wetlands. Impacts on environmentally sensitive areas are not evaluated because such areas

are not located within a one-mile radius of the reservation and are not expected to be impacted (see

Section 3.8.5).

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1 4.2.7.1 Site Preparation and Construction

2

3 The following subsections discuss the potential impacts of the proposed site preparation and construction

4 activities on flora and fauna; rare, threatened, and endangered species; and wetlands.

5

6 Flora and Fauna

7

8 Site preparation and construction for the proposed ACP facilities in the central area of the DOE

9 reservation would be adjacent to existing structures. The proposed new buildings in this area would result

10 in the loss of approximately 12 hectares (30 acres) of landscaped area (fields and lawns). Such areas

11 provide habitat for a limited number of wildlife species that are tolerant of active human disturbance and

12 would result in SMALL impacts on flora and fauna.

13

14 Site preparation and construction activities for X-745H Cylinder Storage outside of the Perimeter Road in

15 the northern portion of the reservation would result in more extensive soil disturbances, as described in

16 Section 4.2.5.1. This cylinder storage yard would be bounded on the south by the Perimeter Road; on the

17 east by an unnamed tributary to Little Beaver Creek (adjacent to the North Access Road); on the west by -

18 the eastern drainage channel to and the discharge from the X-230L North Holding Pond; and on the north

19 by the valley of Little Beaver Creek. The yard would be located in a relatively flat upland area made up

20 of grasslands and old fields adjacent to riparian and upland forests and wetland areas of the Little Beaver

21 Creek and its tributaries. However, the site preparation and construction activities would not require

22 removal of, or disturbance of, vegetation in these adjacent areas (USEC, 2005c). The site preparation and

23 construction activities within the grassland and old field area would result in a temporary increase in

24 erosion and sedimentation during the 24-month construction period. The runoff, if not controlled, would

25 directly enter the unnamed tributaries as well as Little Beaver Creek. Because of the size of the area to be

26 disturbed (10 hectares [25 acres]), the steep topography, the extent of cut and fill activities needed, and

27 the proximity to Little Beaver Creek, which is a State Resource Water that exhibits exceptional ecological

28 values and/or exceptional recreational values (as defined in OAC 3745-1-09 for the Scioto River

29 Drainage Basin), the erosion and sediments that could enter the creek could result in a MODERATE

30 impact.

31

32 Implementation of the best management practices described in Section 4.2.5.1 on soil impacts, together

33 with USEC's plan not to disturb the upland mixed hardwood forest and the riparian forest adjacent to the

34 managed field and old field (USEC, 2005c), would reduce this potentially MODERATE impact to a

35 SMALL impact. Such measures would ensure that the existing forested buffer area between the proposed

36 cylinder storage yard and the riparian areas associated with the tributaries and Little Beaver Creek would

37 be preserved. Such measures would also reduce the level and amount of sedimentation and erosion that

38 would occur in the adjacent surface waters.

39

40 Rare. Threatened, and Endangered Species

41

42 Table 3-11 in Chapter 3 of this Draft EIS lists the Federal and State Listed endangered, potentially

43 threatened, and special concern species near the DOE reservation. Of the wildlife species, none would be

44 impacted by the proposed site preparation and construction activities in the central area. The central area

45 of the DOE reservation is a highly disturbed and managed area that does not provide suitable habitat for

46 any of the species, and the nearest suitable habitats are over 1.5 kilometers (0.9 mile) away (USEC,

47 2005a).

48

49 Activities associated with the two cylinder storage yards outside of the central area would not impact the

50 birds, reptiles, or plants listed in Table 3-1 1. The sharp-shinned hawk and the rough green snake have not

51 been observed on the reservation for several years, and the timber rattlesnake has never been documented

4-26

II
I on the reservation. The plant species located on the reservation are associated with lagoon systems

2 located more than I kilometer (0.6 mile) from all the proposed site preparation and ground disturbing

3 activities (USEC, 2005a)

4

5 There is a small potential for site preparation and construction activities at the cylinder storage yards

6 outside of the central area to affect the potential summertime habitat for the Indiana bat. Previous studies

7 have not documented the presence of the Indiana bat on the DOE reservation at Piketon, but have

8 identified suitable summertime habitat on the reservation (USEC, 2005a). The proposed site preparation

9 and construction activities for X-74H Cylinder Storage Yard, and any refurbishment activities needed at

10 the X-745G-2 Cylinder Storage Yard, would be located approximately 500 meters (1,640 feet) from the

11 suitable summer habitat for the Indiana bat. The construction noise, up to 94 decibels, could temporarily

12 disrupt the activities or preclude Indiana bats from their potentially suitable habitat. However, the

13 construction of the proposed X-745H Cylinder Storage Yard would only remove grassland and old field

14 habitats and would preserve the existing upland mixed hardwood and riparian forests that act as a buffer

15 between the proposed storage yard and the potential summertime habitat (USEC, 2005c). In addition,

16 USEC may implement the following mitigation measures:

17

18 * If trees (either live or dead) with exfoliating bark are encountered in the construction area, they

19 should be saved if possible to avoid destroying potential habitat for the Indiana bat. If necessary,

20 trees should be cut before April 15 or after September 15.

21

22 * Flexible construction schedules should be followed to avoid sensitive wildlife breeding or rearing

23 periods.

24

25 * Temporarily disturbed areas should be revegetated with native vegetation.

26

27 * Bat habitat should be enhanced by installing bat houses.

28

29 * Natural material should be used for slope stabilization instead of engineered materials (concrete

30 retaining walls). (USEC, 2005a)

31

32 The potential impacts on the Indiana bat and its potential habitat would be SMALL because, in addition

33 to the potential mitigation measures, the Indiana bat habitat is only potential summertime bat habitat

34 located approximately 500 meters (1,640 feet) away, and USEC would preserve the existing upland

35 mixed hardwood and riparian forests around the proposed Cylinder Storage yard X-745H, which would

36 act as a buffer. Because the Indiana bat habitat is only potential summertime bat habitat and is located

37 approximately 500 meters (1,640 feet) away, because no forested habitat would be removed, and because

38 USEC may implement the other mitigation measures listed above, the potential impact on the Indiana bat

39 and its potential habitat would be SMALL.

40

41 Wetlands

42

43 None of the proposed site preparation and construction activities would occur in any of the jurisdictional

44 or nonjurisdictional wetlands on the DOE reservation; however, such activities would be adjacent to

45 jurisdictional wetlands regulated by the U.S. Army Corps of Engineers. -The proposed site preparation

46 and construction activities would not require'the dredging or filling of any wetlands, but as discussed in

47 the surface water section above, a temporary increase in erosion and sedimentation associated with

48 construction would increase the turbidity for a short time and would alter water quality parameters of the

49 surface flow that may enter wetlands adjacent to the land disturbing activities. Because no wetlands

50 acreage would be lost and no Section 404 permit would be required, there is no need to develop a

51 mitigation plan to enhance or replace any wetlands. However, standard erosion control best management

- 4-27
I practices would be implemented, as described in Section 4.2.5.1 on soils, and existing upland vegetative

2 buffers would be maintained, as described in the immediately preceding section on rare, threatened, and

3 endangered species. With these mitigation measures, the impacts on wetlands would be SMALL.

.4

5

6

7

8

9

4.2.7.2 Facility Operation

This section evaluates the potential impacts of proposed ACP operations on flora and fauna; rare,

threatened, and endangered species; and wetlands.

10 Flora and Fauna

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Operation of the proposed ACP would result in an increase in personnel traveling to and from the facility

and in minor increases in noise emitted from the facility. Because the active operation of the proposed

ACP is within an existing highly industrialized area with ongoing activities, the additional personnel and

noise would result in a SMALL impact on the flora and fauna in the area, to the limited extent they are

present in this area.

The proposed ACP operations would also result in minor increases in air emissions and point source

water discharges. The additional air emissions and liquid discharges (effluent), as described in Sections

4.2.4 and 4.2.6, respectively, would result in SMALL impacts on the flora and fauna downwind or

downstream of the facility. In terms of radiological air emissions and effluent releases, the small

discharge rates from the proposed ACP are projected to result in ambient concentrations of radionuclides

that are safe for humans (see Section 4.2.12). Since the level of radiation safety required for the

protection of humans is adequate for other animals and plants (IAEA, 1992), no additional mitigation

efforts would be necessary beyond those required to protect humans.

In terms of nonradiological releases, the primary pollutant of potential concern is HF in surrounding air.

The chemical toxicity of airborne uranium (as opposed to its radiological hazard) is also of possible

interest. As presented in Section 4.2.12.3, routine airborne emissions from the proposed ACP are

projected to result in a maximum HF concentration of 2.35 x 1O- micrograms per cubic meter and a

maximum uranium concentration of 6.09 x 1 O- micrograms per cubic meter, both at the point of the Ohio

National Guard building located onsite 555 meters (1,820 feet) from the proposed ACP buildings. No

criteria exist to evaluate safe levels of HF and uranium exposures of plants and animals, but these

predicted concentrations are orders of magnitude below criteria designed to ensure safe human exposures.

Therefore, any impacts to flora and fauna are also expected to be SMALL.

Rare. Threatened. and Endangered Species

Normal operations for the proposed commercial centrifuge project would not affect any Federally listed

threatened and endangered animal and plant species or critical habitat. The closest identified Indiana bat

habitats on the DOE reservation is approximately 1,700 meters (5,600 feet) from the proposed ACP

process facilities in the central area and is approximately 500 meters (1,640 feet) from the cylinder

storage yards outside of Perimeter Road. During the summer months, airborne emissions from facility

operations would be occurring at the same time when Indiana bats may be present. However, because of

the distance from the actively used ACP facilities in the central portion of the facility, the low ambient

levels of HF and total uranium as discussed above, and limited activity that would occur at the cylinder

storage yards outside of the central area but closer to suitable summer habitat, the operation of the

proposed ACP would not affect a listed species or critical habitat. Therefore, there would be a SMALL

impact.

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Wetlands

The operation of the proposed ACP would not encroach on wetlands. The operations would not involve

activities in, releases to, or filling of wetlands. Therefore, the impacts would be SMALL.

4.2.7.3 Ceasing Operations at Paducah -

Cessation of operations at the Paducah enrichment plant would not involve any excavation or disturbance

of habitat. Potential impacts to ecological resources from storm water runoff to surface water from plant

property would not be directly affected by cessation of enrichment plant operations. Existing storm water

management systems and procedures would be-maintained in operation after operations ceased. For the

reasons, the impacts to ecological resources would be SMALL.

4.2.8 Socioeconomic Impacts

Major industrial projects have the potential to affect the socioeconomic dynamics of the'communities in

or around which they are situated. Capital expenditures and the migration of workers'and their families

into a community may influence factors such as regional income; employment levels; local tax revenue;

housing availability; area community services such as healthcare, schools, and law enforcement; and the

availability and cost of public utilities such as electricity, water, sanitary services, and roads. The

objective of a socioeconomic impact analysis is to assess the likely beneficial and adverse impacts of a

project on these and other factors important to the social and economic well-being of local communities,

and to suggest measures to mitigate potentially adverse impacts if necessary.

'This section provides a detailed analysis of the socioeconomic impacts of the proposed action. The

impacts are evaluated over a region of influence covering four counties in southern Ohio:- Pike, Scioto,

Ross, and Jackson Counties. As described in Section 3.9 of this Draft EIS, this region encompasses the

area in which workers employed by the project are expected to live and spend most of their salary, and in

which a significant portion of site purchase and non-payroll expenditures are expected to occur.

4.2.8.1 Methodology

This analysis examines the socioeconomic impacts of the proposed site preparation and construction

activities at Piketon, the proposed ACP operations, decommissioning of the ACP, and the cessation of

uranium enrichment activities at Paducah. Each of these activities is assessed for its potential impact on

the following socioeconomic factors- (1) regional employment; (2) tax revenues; (3) population

characteristics; (4) housing; (5) community and social services (including education, healthcare, law

enforcement, and fire services); and (6) public utilities (including electricity, water, sanitary wastewater,

and solid waste disposal).

Employment impacts are evaluated by estimating the level of direct and indirect employment created by

the proposed action. Direct employment refers to jobs created by the proposed site preparation and

construction activities and facility operations. Indirect employment refers to jobs created in the region of

influence to support the needs of the workers directly employed by the proposed action and jobs created

to support site purchase and non-payroll expenditures. The number of direct jobs created in each stage is

estimated based on anticipated labor inputs for various engineering and construction activities. Indirect

employment is estimated using an economic model known as an input-output model. This analysis uses

RIMS-II, an input-output model developed by the Bureau for Economic Analysis, t6 estimate the indirect

employment impacts of the proposed action. Input-output models such as RIMS-II rely on regional

input-output multipliers to account for inter-industry relationships within regions. Inputs into the model

include information on the initial changes in output, earnings, or employment that are associated with the

4-29
I project. A detailed description of the impact analysis methodology is provided in USEC's Environmental

2 Report (USEC, 2005a). The relative magnitude of the impact on regional employment is assessed by

3 comparing total project-generated employment to current regional employment levels.

4

5 Impacts to State income tax revenues are estimated by assuming appropriate remuneration rates for

6 project-related jobs and applying Ohio State income tax rates. Sales tax revenues are estimated by

7 applying appropriate assumptions about the fraction of after-tax income generated by construction-phase

8 jobs that will be spent within the region of influence and applying Ohio sales tax rates. Impacts to local

9 tax revenues are estimated by applying appropriate assumptions about the fraction of after-tax income

10 generated by project-related jobs that will be spent within each county and applying county-specific sales

11 tax rates. The relative magnitude of the impact on regional tax revenues is assessed by comparing total

12 project-generated tax revenues to current regional tax revenues.

13

14 Impacts to population characteristics are evaluated by estimating the fraction of direct and indirect jobs

15 that will be filled by migration of workers from outside the region of influence. The average family size

16 and age profiles of migrating families are estimated using appropriate demographic assumptions based on

17 U.S. Census Bureau statistics. These estimates of potential migration are compared to existing regional

18 population levels to assess the relative magnitude of impacts to population characteristics.

19

20 Impacts to area housing resources are estimated by a quantitative comparison of current housing vacancy

21 statistics for rental and owner-occupied houses to the estimated population influx into the region of

22 influence.

23

24 Impacts to community and social services are estimated using a level-of-service assessment approach.

25 Level-of-service indicators typically measure the ratio of service providers to the recipient population for

26 a particular service; examples include the student-to-teacher ratio for educational services and the number

27 of physicians per 1,000 people for healthcare services. The most recent data on existing levels-of-service

28 for education, healthcare, law enforcement, and fire services in the region of influence, if available, are

29 combined with estimates of population influx and standard demographic assumptions to derive expected

30 new levels-of-service. These are compared to State average levels-of-service for each community service

31 to identify potentially adverse impacts.

32

33 Impacts to public utilities (such as water, sanitary wastewater, solid waste, and transportation and road

34 services) are estimated by identifying any stages of the proposed action that would procure utilities from

35 offsite vendors that service communities in the region of influence. Where applicable, the levels of

36 potential procurement under the proposed action are compared to the existing capacities of the utilities

37 and existing demand levels to assess whether the procurements are likely to affect the availability and

38 pricing of services to local communities.

39

40 4.2.8.2 Site Preparation and Construction

41

42 As described in Chapter 2, several existing buildings from the former Gas Centrifuge Enrichment Plant

43 would be refurbished. In addition, two new process buildings and associated feed, withdrawal, and

44 customer service facilities, and several cylinder storage yards, would be built. All of these site

45 preparation and construction activities for the 7 million SWU plant would occur between calendar years

46 2006 and 2010, and are estimated to cost $1.45 billion.

47

48 Impacts to Regional Employment

49

50 In each year between 2006 and 2010, average annual employment as a result of site preparation,

51 refurbishment, and construction activities is estimated at 3,362 full-time jobs. This estimate includes both *

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1l
1 direct and indirect employment. Thus, the total number of full-time worker-years of employment

2 generated as a result of site preparation, refurbishment, and construction activities is estimated as the

3 product of 3,362 full-time workers multiplied by a total of five years, resulting in 16,810 full-time worker

4 years of employment. USEC developed this estimate from the RIMS-II model using appropriate

5 assumptions about the number of direct jobs created, construction-related expenditures, and regional

6 input/output multipliers. (USEC, 2005a).

7

8 The total number of persons employed in the four counties of the region of influence in the year 2000 was

9 96,347 (BEA, 2002a). The total number of persons employed in Pike County, the site of the proposed

10 action, in the year 2000 was 14,944 (BEA, 2002a). The employment expected to be generated by the site

11 preparation and construction phase of the proposed action therefore represents 3.5 percent of the total

12 employment in the region of influence and 22.5 percent of Pike County employment at the year 2000

13 levels.

14

15 Based on these figures, the impacts to regional employment of the site preparation and construction

16 activities are considered MODERATE.

17

18 Impacts to Tax Revenue

19

20 Impacts to regional tax revenues'are calculated by using per capita income levels in the region of

21 influence as an estimate of the average salary associated with jobs created by the site preparation and

22 construction phase of the proposed action. USEC estimates that the region's per capita income in 2004

23 dollars is $25,317 (USEC, 2005a).

24

25 Ohio State income tax rates for incomes between $20,000 and $40,000 are structured as a flat payment of

26 $445.80 plus 4.5 percent of income over $20,000 (Ohio Department of Taxation, 2003). The State

27 income tax payable by a worker earning $25,317 (the per capita income in the region of influence) at

28 these rates would be $685.07. The proposed action would create 3,362 jobs each year during' the site

29 preparation and construction phase; this level of employment remunerated at the per capita income in the

30 region translates to State income tax revenues of $2.3 million per year for each year of the 5-year

31 construction phase. Ohio's cumulative individual State income tax revenues for fiscal year 2003 were

32 $8.3 billion (Ohio Department of Taxation, 2003). Income tax revenues resulting from the incomes

33 generated by'the site preparation and construction phase can therefore be expected to account for

34 approximately 0.03 percent of Ohio's cumulative annual individual income tax receipts at fiscal year

35 2003 levels.

36

37 Ohio State sales tax revenues are estimated to rise by $3.7 million (2004 dollars) per year for the site

38 preparation and construction phase of the proposed action, using the current six percent sales tax rate.

39 The estimate is based on the assumption that 75 percent of earnings after State income taxes are spent in

40 State. Federal income taxes are not considered in computing disposable income; if Federal income taxes

41 were included, it is likely that sales tax revenues would be lower than estimated here. Ohio's cumulative

42 State sales and use tax revenues for calendar year 2003 were $6.7 billion. Sales tax revenues resulting

43 from incomes generated by the construction phase of the proposed action can therefore be expected to

44 account for approximately 0.06 percent of cumulative Ohio annual sales tax receipts at calendar year 2003

45 levels.

46

47 Pike County's annual sales tax revenues, derived from the county's one percent sales tax rate, are

48 expected to rise by approximately $414,000 as'a result of the new employment generated by the proposed

49 site preparation and construction phase. This estimate is based on the assumption that half the after-tax

50 income arising from jobs generated is spent on transactions within Pike County. This amount represents

51 less than nine percent of Pike County's'general fund budget in 2005 (Pike County Auditor, 2005).

4-31
I

1 As demonstrated above, it is unlikely that State income tax, State sales tax, and county-level tax revenues

2 would significantly increase as a result of the site preparation and construction phase of the proposed

3 action. Overall, the impacts to regional tax revenues may therefore be considered SMALL.

4

5 Impacts to Population Characteristics

6

7 Of the 3,362 estimated jobs that are expected to be created during the site preparation and construction

8 phase, a total of 900 direct jobs are expected to be filled by USEC employees transitioned from the

9 Portsmouth Gaseous Diffusion Plant; these jobs are to support management, design, licensing, assembly,

10 testing and evaluation, quality assurance, nuclear and radiological safety, and operational readiness

11 assessments. An estimated 2,088 indirect jobs are expected to support the 900 positions filled by

12 transitioned USEC workers. Thus,'a total of 2,988 jobs generated through construction activities

13 represent jobs that are a continuation of already existing jobs generated or supported by current USEC

14 activities. These jobs are therefore expected to be filled from within the region. (USEC, 2005a)

15

16 Using these numbers, 374 new jobs (direct and indirect) are expected to be created through construction17 related activities between the years 2006 and 2010. Conmmonly, an average of 75 percent of construction18 related employment derives from within the region of influence (DOE, 1999a). If 25 percent of the 374

19 construction-related jobs are filled from outside the region, a total of 94 workers may be expected to

20 move into the region. If all workers are assumed to move in as family households, and the average

21 national family household size is assumed to be 3.13 (U.S. Census Bureau, 2003), the population influx

22 into the region of influence would be 293 persons. This represents 0.13 percent of the region population

23 in the year 2000 (U.S. Census Bureau, 2000). The estimate used for household size is conservative

24 because it represents the average size of a family household (3.13), rather than the average size of all

25 households (2.57). This conservative assumption may result in an overestimate of the impacts on social

26 services.

27

28 Based on this analysis, the impacts to population characteristics of the site preparation and construction

29 activities are expected to be SMALL.

30

31 Impacts to Area Housing Resources

32

33 The average rental vacancy rate in the region of influence is 8.6 percent for rental property and there are

34 approximately 22,824 rental units in all. This equates to an availability of approximately 1,963 rental

35 housing units, based upon 2000 census data. Of the additional 374 jobs created by the site preparation

36 and construction phase of the proposed action, only 25 percent are expected to be filled by migration from

37 outside the community. Therefore, site preparation and construction activities are likely to increase the

38 demand for rental housing by only 94 units out of a total of 1,963 rental units. Even accounting for

39 seasonal increases in the demand for housing created by recreational activities, this influx of workers is

40 not likely to cause housing shortages or increases in rental rates.

41

42 Therefore, the impacts to area housing resources of the site preparation and construction phase may be

43 considered SMALL.

44

45 Impacts to Community and Social Services

46

47 A total of 94 family households may be expected to migrate to the region of influence as a result of

48 employment opportunities generated in the site preparation and construction phase of the proposed action,

49 as discussed above. According to the U.S. Census Bureau (2003), the average national family household

50 size is 3.13 with an average of 0.95 individuals under the age of 18. Thus, the maximum influx of school51 aged children is not expected to exceed 89, which is 0.24 percent of the region of influence school

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Il
1 population in the year 2000. The region contains 24 public school districts with a total of 95 schools

2 serving approximately 37,000 students (ODOD, 2003). The region's student-to-teacher ratio stood at

3 15.3 in 2000 (ODOD, 2003). This ratio would not change after the expected influx of school-age children

4 into the region resulting from cositiuction-phase employment. Thei aeiage student-to-teacher ratio in the

5 State of Ohio was only slightly lower at 14.8 in the year 2000. As a result, the impacts to education

6 services in the region may be considered SMALL.

7

8 Levels of service of fire, law enforcement, healthcare, and administrative services in the region of

9 influence are lower than the State average, but are consistent with those typical in rural counties. -The

10 influx of 293 persons represents an augmentation of the region's population of 0.13 percent and will have

11 a SMALL effect on fire, law enforcement, healthcare, and administrative levels of service.

12

13 Impacts to Public Utilities

14

15 As described in Section 3.9.3.5, there has historically been very little overlap between utilities providing

16 services to communities in the region of influence and those supporting the Portsmouth Gaseous

17 Diffusion Plant. Dedicated utilities were constructed in the 1950s solely to support the needs of the

18 Portsmouth Gaseous Diffusion Plant. The communities in the region of influence have never had access

19 to these utilities. Under the proposed action, utilities would continue to be procured through existing

20 resources. With the exception of natural gas and landfill services, these dedicated utilities are expected to

21 have more than adequate capacity to continue serving the ACP under the proposed action. Historically,

22 the Portsmouth Gaseous Diffusion Plant has had no impact on the availability or cost of these utilities to

23 communities in the region. -It is therefore unlikely that the proposed action would affect the cost or

24 availability of public utility supplies in the region of influence.

25

26 With regard to natural gas usage, the proposed action would not require any more natural gas than can be

27 supplied through the existing two-inch diameter supply line. The proposed action is expected to have no

28 impact on the offsite availability or cost of natural gas.

29

30 The Pike County landfill would be the primary endpoint for sanitary/industrial waste disposal and the

31 Rumpke Beach Hollow landfill is an alternative. The projected capacities and use of each are described

32 in Section 3.9.3.5. As is apparent from Table 2-3 and Table 3-23, industrialsanitary wastes from the

33 construction phase of the proposed action will account for a minor fraction of the capacity of these

34 facilities:

35

36 Although the site preparation and construction phase of the proposed action may result in migration of

37 people into the region, the level of migration is expected to be well below the rental vacancy rate in the

38 area, as discussed in the preceding section on housing resources. Therefore, the population influx due to

39 construction phase jobs is not expected to affect either the pricing or availability of public utilities in the

40 region.

41

42 Considering all of these factors, the impacts to public utilities caused by the proposed site preparation and

43 construction activities would be SMALL.

44

45 4.2.8.3 Facility Operation

46

47 Depending on the timing for NRC licensing and other factors, USEC is proposing to begin commercial

48 centrifuge plant operations in 2009 and to reach the 3.5 million SWU annual capacity by 2011.

49 Expansion to the 7 million SWU per year capacity would not occur until sometime after 2011, likely

50 around 2013. The overall period of operation for the proposed ACP is projected to be 30 years.

4-33
1 Impacts to Regional Employment

2

3 The operations phase of the proposed ACP is expected to create 600 full-time jobs and 900 indirect jobs

4 in the region of influence (USEC, 2005a). The total number of persons employed in the four counties of

5 the region in the year 2000 was 96,347. The total number of persons employed in Pike County, the site of

6 the proposed ACP, in the year 2000 was 14,944. The employment expected to be generated by the

7 operations phase therefore represents 1.6 percent of the total employment in the region and 10 percent of

8 Pike County employment. Given these results, the impacts to regional employment of the facility

9 operation phase are considered MODERATE.

10

11 Impacts to Tax Revenue

12

13 USEC estimates that the average income in 2013 dollars will be $36,226 per year for 900 directjobs and

14 600 indirect jobs, the operations phase of the proposed action would generate $54.3 million in income

15 (USEC, 2005a).

16

17 Income from these jobs will generate $1.8 million (2013 dollars) in State income tax revenue at the Ohio

18 State income tax rates described in Section 4.2.8.2. Ohio's cumulative State income tax revenues for

19 2003 were $8.3 billion. Income tax revenues resulting from incomes generated by the proposed ACP

20 operations phase can therefore be expected to account for less than 0.02 percent of Ohio's annual

21 individual income tax receipts at 2003 levels.

22

23 Ohio State sales tax revenues are estimated to rise by $2.4 million (2013 dollars) per year as a result of

24 the new income generated by 1,500 jobs during the operations phase of the proposed action, assuming a

25 six percent rate of sales tax. This estimate is based on the assumption that 75 percent of earnings after

26 State income taxes are spent in State. Federal income taxes are not considered in computing disposable

27 income; if Federal income taxes were included, it is likely that sales tax revenues resulting from the

28 proposed action would be lower than estimated here. Ohio State's sales and use tax revenues for 2003

29 were $6.7 billion. Incremental sales tax revenues resulting from incomes generated by the operations

30 phase of the proposed action can therefore be expected to account for less than 0.04 percent of Ohio's

31 annual sales tax receipts at 2003 levels.

32

33 Pike County's annual sales tax revenues are expected to rise by approximately $263,000 as a result of the

34 new employment generated by the proposed ACP operations phase, based on a county sales tax of one

35 percent. This estimate is based on the assumption that half of the after-tax income from jobs generated by

36 the operations phase is spent on transactions within Pike County. This amount represents less than six

37 percent of Pike County's general fund budget in 2005 (Pike County Auditor, 2005).

38

39 As demonstrated above, it is unlikely that State income tax, State sales tax, and county-level tax revenues

40 would significantly increase as a result of the operations phase of the proposed action. Therefore, the

41 impacts to area tax revenues of the proposed ACP operation phase are considered SMALL.

42

43 Impacts to Population Characteristics

44

45 Most of the direct and indirect jobs resulting from operations at the proposed ACP are expected to be

46 filled from within the region of influence (USEC, 2005a). No substantial population influx is expected

47 during the operations phase of the proposed action. Therefore, the impacts to regional population

48 characteristics of the operations phase are considered SMALL.

4-34

I II
I Impacts to Area Housing Resources

2

3 As previously mentioned, most of the direct and indirect jobs resulting from operations at the proposed

4 ACP are expected to be filled from within the region of influence (USEC, 2005a). No substantial

5 population influx is expected during the operations phase. Therefore, the impacts to area housing

6 resources of proposed ACP operations are also considered SMALL.

7.

8 Impacts to Community and Social Services

9

10 Since most of the direct and indirect jobs resulting from proposed ACP operations are expected to be

11 filled from within the region, no substantial population influx is expected during the operations phase

12 (USEC, 2005a). The impacts to community and social services of the facility operation phase are

13 therefore be considered SMALL.

14

15 Impacts to Public Utilities

16

17 As described in Section 3.9.3.5, there has historically been very little overlap between utilities providing

18 services to communities in the region of influence and those supporting the Portsmouth Gaseous

19 Diffusion Plant. The communities in the region have never had access to dedicated utilities that were

20 constructed in the 1950s solely to support the needs of the Portsmouth reservation. For the proposed ACP

21 operations, utilities would continue to be obtained through these existing resources. -With the exception

22 of natural gas and landfill services, these dedicated utilities are expected to have more than adequate

23 capacity to continue serving the proposed ACP operations. Historically, the Portsmouth Gaseous

24 Diffusion Plant has had no impact on availability or cost of these utilities to communities in the region. It

25 is therefore unlikely that the proposed action would affect the cost or availability of public utility supplies

26 in the region.

27

28 With regard to natural gas usage, the proposed ACP operations would not require any more natural gas

29 than can be supplied through the existing two-inch diameter supply line. The proposed operations are

30 expected to have no impact on the offsite availability or cost of natural gas.

31

32 The Pike County landfill will be the primary endpoint for sanitary/industrial waste disposal and the

33 Rumpke Beach Hollow landfill is an alternative. The projected capacities and use of each are described

34 in Section 3.9.3.5. Based on a comparison of the existing landfill capacities reported in Table 3-23 and

35 the anticipated volumes of sanitary/industrial waste from proposed ACP operations reported in Table 2-6,

36 sanitary/industrial wastes from the operations phase of the proposed action would account for a minor

37 fraction of the capacity of these facilities.

38

39 Most of the direct and indirect jobs resulting from proposed ACP operations are expected to be filled

40 from within the region of influence. No substantial population influx is expected during the operations

41 phase. Therefore, the population influx on account of proposed ACP operations is not expected to affect

42 either the pricing or availability of public utilities in the region.

43

44 For all of these reasons, the impacts to public utilities of the operations phase of the proposed action are

45 expected to be SMALL.

46

47 4.2.8.4 Ceasing Operations at Paducah

48

49 The socioeconomic region of influence for the Paducah site is identified in the Programmatic

50 Environmental Assessmentfor Disposition of Potentially Reusable Uranium Materials (DOE, 1999a).

-4-35
I This region includes McCracken County, Kentucky, where the Paducah Gaseous Diffusion Plant is

2 located. McCraken County had a population of 64,407, per capita personal income of $23,227, and a

3 total person income of $1.8 billion in 1999 (BEA, 2002b). Wage and salary employment for the region

4 was more than 41,859 in 2000 (BEA, 2002a). Total site employment in 1998 was 2,209 (DOE, 2001a).

5

6 Decommissioning of the Paducah Gaseous Diffusion Plant and any other further use of the enrichment

7 plant buildings, structures, or land are not considered part of the proposed action considered in this Draft

8 EIS. Decisions concerning decommissioning and any other future use of the enrichment plant would be

9 the subject of other decisions and other environmental reviews.

10

II Cessation of operations at the Paducah enrichment plant would result in direct and indirect socioeconomic

12 impacts associated with the termination of the operations workforce at the plant and associated reduction

13 in payroll. It also would result in the loss of local expenditures for goods and services associated with

14 current plant operations. The anticipated impacts of these changes are assessed below.

15

16 Impacts to Regional Employment

17

18 After cessation of operations, the workforce would be reduced to a smaller maintenance and security

19 workforce, which would substantially reduce the number of full-time workers employed from current

20 levels of 1,868 full-time employees. Also, the average wage of the workers once operations have ceased

21 would decrease from that under plant operations, as the required skill level of the operations workers

22 would generally be greater than that of the maintenance and security workers when there are no plant

23 operations.

24

25 For the purpose of this Draft EIS, the NRC staff did not perform comprehensive economic input-output

26 modeling to estimate indirect jobs associated with employment and expenditures for operations at the

27 Paducah facility. However, in the most conservative assessment, all the operations phase jobs and

28 associated indirect jobs at the Paducah facility would be terminated. These losses would be temporarily

29 mitigated to some extent by hiring of decommissioning workers in the event that the Paducah plant was to

30 be decontaminated and decommissioned. In the event that the plant was decommissioned and then

31 refurbished for future economic use, impacts to regional employment from the shutdown of the plant

32 would be further mitigated. Based on this analysis, the impacts to regional employment of cessation of

33 operations at the Paducah facility may be considered MODERATE.

34

35 Impacts to Tax Revenue

36

37 The cessation of operations at the Paducah facility is likely to have a negligible impact on Kentucky State

38 income and State sales tax based on the fact that employment levels associated the facility account for a

39 small fraction of total State employment. The impact on local tax revenues are also likely to be small but

40 could be as high as moderate. The overall impacts to tax revenues are therefore expected to be SMALL.

41

42 Impacts to Population Characteristics

43

44 The loss ofjobs associated with the Paducah Gaseous Diffusion Plant operations may result in migration

45 out of the community. In the most conservative estimate, all the direct and indirect jobs associated with

46 the Paducah facility would terminate after cessation of operations. However, not all of the indirect jobs

47 associated with the facility are likely to terminate after direct employment at the Paducah facility ceases.

48 Some of the indirect employment would continue through servicing other members of the region of

49 influence and neighboring communities, and by diversifying into other lines of business. Furthermore,

50 some direct jobs would continue at the Paducah facility, such as the jobs associated with maintaining the

51 site in cold stand-by status. In the event that the plant was decommissioned and then refurbished for

4-36

Il
I some other future economic use, impacts to population characteristics in the region from the shutdown of

2 the plant would be further mitigated.

3

4 Based on these considerations, and the phased nature of any likely migration trends, the impacts to

5 population characteristics of the cessation of operations at the Paducah facility may be considered

6 SMALL.

7

8 Impacts to Area Housing Resources

9

10 Loss of employment and migration out of the region of influence resulting from cessation of operations at

I I the Paducah facility are likely to increase vacancy rates in the rental market and increase the number of

12 houses for sale. This could potentially lead to a downward trend in rents and housing values. However,

13 these trends could be mitigated by the possible creation of new economic opportunities in the area such as

14 if the plant was decommissioned and then refurbished for future economic use. -Based on these

15 considerations, and the phased nature of any likely migration trends, the impacts to area housing

16 resources may be considered SMALL.

17

18 Impacts to Community and Social Services

19

20 The demand for community and social services is likely to decline following the potential loss of

21 employment and migration out of the region resulting from cessation of operations at the Paducah facility.

22 This may result in a temporary improvement in levels of service followed by a correction in the level of

23 supply of community and social services. The levels of potential migration out of the region of influence

24 are not considered significant enough to affect the viability of any community or social services. Based

25 on these considerations, and the phased nature of any likely migration trends, the impacts to community

26 and social services of the cessation of operations at the Paducah facility may be considered SMALL.

27

28 Impacts to Public Utilities

29

30 The demand for public utilities is also likely to decline following the potential loss of employment and

31 migration out of the region of influence resulting from cessation of operations at the Paducah facility.

32 This would potentially create some small level of overcapacity for certain services; however, most

33 utilities are likely to employ any redundant capacities in servicing regional markets. The levels of

34 potential migration out of the region are not considered significant enough to affect the viability or price

35 structure of any public utilities. Based on these considerations, and the phased nature of any likely

36 migration trends, any impacts to public utilities from the cessation of uranium enrichment activities at

37 Paducah are also expected to be SMALL. - :

38

39 4.2.9 Environmental Justice Impacts

40

41 As described in Sections 4.2.1 through 4.2.8 and Sections 4.2.10 through 4.2.15, the impacts of the

42 proposed action are expected to be SMALL for almost all of the resource areas evaluated. In these cases,

43 the impacts to all human populations would be small, so there would not be any disproportionately high

44 and adverse impacts to minority or low-income populations.

45

46 The NRC staff has concluded that potential impacts could be as high as MODERATE in eight cases.

47 However, in each of these cases, the impacts would not appear to be disproportionately high and adverse

48 for minority or low-income populations, for reasons outlined below.

49

50 * As described in Section 4.2.4.1, site preparation and construction activities are projected to cause a

51 temporary increase in the concentrations of particulate matter with a mean diameter of 10

4-37
11

I micrometers or less in the ambient air that slightly exceed the air quality standard up to a distance of

2 1,000 meters (3,280 feet) beyond the fenceline. However, there are no populations that qualify as

3 minority or low-income this close to the site.

4

5 * As described in Section 4.2.8.2, the impacts to regional employment of the site preparation and

6 construction activities are considered MODERATE. These impacts are generally considered positive.

7

8 * Similarly, as described in Section 4.2.8.3, the impacts to regional employment of the facility

9 operation phase are considered MODERATE. These impacts are generally considered positive.

10

11 * As described in Section 4.2.8.4, the impacts to regional employment of cessation of operations at the

12 Paducah Gaseous Diffusion Plant are considered MODERATE. In this case, the employment impacts

13 would be adverse, and while they would not be so high as to significantly affect employment in the

14 region, the impacts would be high to affected individuals. Because the demographics of the existing

15 workforce that could be downsized at Paducah have not be studied in detail for this Draft EIS, it is not

16 clear that the impacts would disproportionately affect low-income or minority populations. It is

17 likely that the potentially affected workforce at Paducah does not qualify as low-income, assuming

18 that the average annual income level of $36,226 for operations workers at the proposed ACP

19 reasonably represents the income of current employees at Paducah (for comparison, the per capita

20 income for workers in the region surrounding Paducah is $23,227). Although the minority

21 percentage in McCracken County where the Paducah Gaseous Diffusion Plant is located is more than

22 25 percent higher than the minority percentage in the State of Kentucky as a whole, the minority

23 status of workers potentially downsized at Paducah is not known.

24

25 * As described in Section 4.2.11.1, the substantially greater transportation requirements during the

26 construction phase could result in MODERATE impacts during the five-year period in which most of

27 the construction activity is projected to occur. These impacts could include an increase in traffic

28 congestion on U.S. Route 23 and, to a lesser extent, on Ohio State Road 32 in the vicinity of the ACP.

29 It is also expected that construction traffic accidents would result in about 18 injuries a year on these

30 roads, but only one fatality over the entire construction period. These impacts would be experienced

31 by everyone traveling on U.S. Route 23 and Ohio State Road 32 and would not disproportionately

32 affect minority or low-income populations.

33

34 * As described in Section 4.2.12.1, the probability of a severe transportation accident that releases

35 sufficient quantities of UF6 that could pose a health risk is low, but the consequences of such an

36 accident, should it occur, are high. Based on this analysis, the public health impacts associated with

37 such an accident as part of the proposed action are considered MODERATE. Such an accident could

38 occur anywhere along the proposed routes for shipping UF6 feed to Piketon (from Metrolpolis,

39 Illinois; Port Hope, Ontario, Canada; and Wilmington, Delaware) and the proposed routes for'

40 shipping UF6 product from Piketon to customers or other distribution points (to Richland,

41 Washington; Columbia, South Carolina; Wilmington, North Carolina; and Seattle, Washington).

42 Since these transportation routes cover an extremely broad area that includes much of the United

43 States as well as parts of Canada, and since all populations along these transportation routes would be

44 subject to the same risk, no disproportionately high and adverse effects are expected for any particular

45 segment of the population, including minority and low-income populations that could live along the

46 proposed transportation routes.

47

48 * As described in Section 4.2.12.3, accidents associated with proposed ACP operations could result in

49 SMALL to MODERATE impacts to the surrounding public. However, the impacts of such accidents

50 are not expected to extend as far away as 28 kilometers (17 miles), where the closest minority and

4-38

I I l All
I low-income Census tracts are located. Therefore, populations in those Census tracts are not expected

2 to experience disproportionately high and adverse effects.

3

4 * As described in Section 4.2.13.2, the added inventory of depleted UF6 coming from the proposed

5 ACP should not change the nature or magnitude of the impacts from the DOE conversion facility

6 operations; however, it would extend those impacts for several additional years, resulting in overall

7 MODERATE impacts to DOE conversion facility operations. The DOE EIS for the conversion

8 facility at Piketon concluded that the operations of that facility should not result in any environmental

9 justice impacts because of a lack of high and adverse impacts (DOE, 2004a). Therefore, extending

10 those operations for additional years should also not result in any disproportionately high and adverse

11 impacts.

12

13 4.2.10 Noise Impacts

14

15 This section analyzes the potential noise impacts from proposed ACP site preparation, construction, and

16 operation, along with the noise impacts associated with the corresponding cessation of enrichment plant

17 operations at Paducah.

18

19 4.2.10.1 Site Preparation and Construction

20

21 USEC's Environmental Report (USEC, 2005a) estimates that construction noise levels would be around

22 73 to 94 A-weighted decibels (dBA) at 15 meters (50 feet). Assuming a drop-off rate of 6 decibels per

23 doubling of distance, which is typical for construction noise equipment, the noise level at the nearest

24 residence (914 meters [3,000 feet] from the proposed ACP) would be 58 dBA. This level would be 53

25 day-night average noise level (DNL), recognizing that most construction activities would occur during the

26 day (USEC, 2005a).

27

28 The U.S. Department of Housing and Urban Development has standards for community noise levels. It

29 has developed land use compatibility guidelines (HUD, 2002) for acceptable noise levels versus the

30 specific land use (see Table 3-27 in Section 3.11 of this Draft EIS). Because the estimated construction

31 noise level of 53 DNL at the site is below these guidelines, the noise impacts from proposed site

32 preparation and construction activities are expected to be SMALL.

33

34 4.2.10.2 Facility Operation

35

36 Once in operation, the centrifuges themselves would be very quiet since the centrifuge "floats" on a

37 magnetic bearing and spins within a vacuum. Noise generation occurs when moving metal parts are in

38 contact with each other, and when air molecules are available to transmit sound. Some noise occurs upon

39 centrifuge start up and shut down, which are assumed to be infrequent and brief activities sirice USEC

40 plans to run the centrifuges continuously.

41

42 Catastrophic failure of the centrifuges could cause a sudden but brief loud noise, due to the high rotational

43 speed of the centrifuge. However, the likelihood of a single centrifuge catastrophically failing is very

44 low.

45

46 No adverse noise impacts are expected at the closest residential receptor due to low operational noise, the

47 attenuation provided by the building facade, and the distance attenuation of over 914 meters (3,000 feet).

48 Therefore, the noise impacts from the proposed ACP operations are expected to be SMALL.

4-39
U

1 4.2.10.3 Ceasing Operations at Paducah

2

3 Ceasing operations at Paducah would decrease noise levels from those associated with current operation

4 of the Paducah enrichment plant. Noise associated with the operation of enrichment plant equipment

S would be largely eliminated after cessation of operations. Remaining noise sources would be limited to

6 operation of equipment (e.g., boilers, pumps, compressors) associated with onsite utilities, operation of

7 vehicles and equipment by the maintenance and security workforce, and the conduct of maintenance

8 activities. These activities are anticipated to be intermittent and of short duration as compared to the

9 those associated with continuous operation of enrichment plant equipment.

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I1 4.2.11 Transportation Impacts

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13 Transportation impacts of interest are the potentials for delays, accidents, injuries, or fatalities associated

14 with the movements of people and goods into and out of the proposed ACP. These impacts may occur

15 during site preparation and construction, facility operations, and cessation of activities and

16 decommissioning in the future. In each of these stages, raw materials and equipment would be brought to

17 the site, wastes of various types would leave the site, and workers would travel back and forth to their

18 places of residence. During facility operations, enriched UF6 would also leave the site.

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20 The sections below analyze two main categories of transportation impacts associated with site preparation

21 and construction, facility operation, and cessation of operations at Paducah. The first is the potential for

22 the proposed action to affect the "level of service" of- or cause traffic congestion and delays on - local

23 roadways. 2 The second is the potential for traffic accidents and resulting injuries and fatalities. The

24 potential injuries and fatalities that are estimated below would arise from traffic accidents in which there

25 are no releases of radioactive materials. The additional impacts associated with the small fraction of

26 accidents that might yield some level of release, as well as radiological exposures that are not associated

27 with accidents, are presented in the analysis of public and occupational health impacts in Section 4.2.12.

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29 4.2.11.1 Site Preparation and Construction

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31 The following sections analyze the level of service impacts and the non-radiological accident impacts

32 associated with increased road traffic from the proposed site preparation and construction activities.

33 Impacts associated with rail, water, and air transport are not reviewed because the proposed site

34 preparation and construction activities would not affect such modes of transportation.

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36 Level of Service Impacts

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38 This section forecasts the traffic impacts of the proposed construction of the proposed ACP, including the

39 shipment of centrifuges and other required equipment into the site. The primary impact considered is the

40 effect of vehicle trips generated by the facility on the level of service provided by U.S. Route 23 and Ohio

41 State Road 32.

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43 The proposed ACP would generate vehicle trips during site preparation and construction both through the

44 movement of materials and through workers traveling to and from the site. This analysis starts with

45 current traffic volumes and estimates the impact of the incremental change in traffic volume to the level

2 The concept of level of service is a qualitative measure that describes operational conditions with a traffic

stream and their perception by motorists. A level-of-service definition describes these conditions in terms of such

factors as speed and travel time, freedom to maneuver, traffic interruptions, comfort, convenience, and safety. The

Highway Capacity Manual defines six levels of service, designated A through F.

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of service of the roadways. The Highway Capacity Software from McTrans (McTrans Center, 2003) was

used to estimate the effect of new traffic generated by the proposed ACP on the roadway level of service

during peak conditions. This software uses a number of planning data inputs to calculate the level of

service for a given road. These inputs include roadway characteristics and the following factors:

* The "average annual daily traffic," which provides an estimate of the typical daily volume of vehicles

on a particular road segment.

* The "K factor," which measures what proportion of daily traffic occurs during the "design hour." The

design hour values used for this analysis are the 30' highest traffic volume hour of the year.3 For

instance, if the K factor is 10.1, this means that for the 30' highest volume hour in the year, 10.1

percent of the traffic for the day occurred during that hour.

* The "D factor," which measures what percent of the traffic is moving in the peak direction during the

design hour.

* The "30-hour volume of the roadway," which is obtained by multiplying the K factor by the average

annual daily traffic.

The NRC staff obtained data on the 2004 traffic volumes for U.S. Route 23 and State Road 32 from the

Ohio Department of Transportation Traffic Survey Reports (Ohio DOT, 2004a). Values for the K and D

factors and 30-hour volume were obtained from the Ohio Department of Transportation's K and D factors

report (Ohio DOT, 2004b). The data used to characterize current traffic conditions are shown in

Table 4-4.

Table 44 2004 Traffic Conditions on Routes Adjacent to the Proposed ACP

Volume Characteristic - U.S. Route 23 J State Road 32

Average annual daily traffic (number of vehicles) 15,110 8,830

Percent commercial truck 16% 19% _ .. . . .... _____... .... . ....... ........... . ...... . 4. .......

K factor 10.1% 10.1% . ._...... _....__ ...... .. .... _. ..... _..... ._....; . _. ........... _. _ ._ __. ;....... .. _.._...

D factor. 62.3% * 62.3%

30-hour volume (number of vehicles) 1,526 892 . _ ....... ._ .. ...... ...... . .......................... . ........

-Hour of the day for the 30-hour volume * 4:00 PM * 4:00 PM

Sources: Ohio DOT, 2004a; Ohio DOT, 2004b.

Current traffic conditions are not congested for the design hour. Ohio State Road 32 operates at Level of

Service A, while U.S. Route 23 operates at Level of Service B (McTrans Center, 2003). For reference,

these and the other four levels of service defined by the Highway Capacity Manual can be described as

follows:

* Level of Service A describes completely free-flow conditions. Individual users are virtually

unaffected by the presence of others in the traffic stream.

3The Highway Capacity Manual suggest the use of the 30" highest hour as the design hour for rural highways.

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I * Level of Service B also indicates free flow, but the presence of other vehicles becomes more

2 noticeable. Freedom to select desired speeds is relatively unaffected, but there is a slight decline in

3 the freedom to maneuver within the traffic stream from Level of Service A.

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5 * Level of Service C is in the range of stable flow, but marks the beginning of the range of flow in

6 which operation of individual users becomes significantly affected by interactions with others in the

7 traffic stream. The selection of speed is now affected by others, and maneuvering requires substantial

8 vigilance on the part of the user.

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10 * Level of Service D represents high density but stable flow. Speed and freedom to maneuver are

11 severely restricted, and the driver experiences a generally poor level of comfort and convenience.

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13 * Level of Service E represents operating conditions at or near capacity level. All speeds are reduced to

14 a low but relatively uniform value.

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16 * Level of Service F is used to define forced or breakdown flow. This condition exists wherever the

17 amount of traffic approaching a point exceeds the amount which can traverse the point. Queues form

18 behind such locations. Operations within the queue are characterized by stop-and-go waves, and they

19 are extremely unstable.

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21 The NRC staff estimated potential impacts of proposed ACP site preparation and construction to these

22 baseline traffic conditions. The staff estimated the volume of daily and peak hour trips that would be

23 generated during site preparation and construction using information submitted by USEC in its

24 Environmental Report (USEC, 2005a). Table 4-5 shows the results of this analysis.

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26 Table 4-5 Highway Trips Generated by Proposed ACP Site Preparation and Construction

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T TNumber of Daily Number of Peak Hour Trip Tye Vehicle Trips Vehicle Trips

Centrifuges, equipment, materials, etc. 27 3 .. .-. . _ ........... _ _-...-.... _ _ ............... ._._ . ............ __......... . ....

Workers . 2,612 1,306

Total . 2,639 . 1,309

Source: USEC, 2005a.

The NRC staff estimates that the movement of centrifuges, equipment, and other materials needed for the

proposed ACP would require no more than 17,870 truckloads, which would result in about 27 trips per

day and approximately three trips during peak hours (assuming each truckload generates two trips). This

estimate is based on information provided by USEC in its Environmental Report that indicates that site

preparation and construction would occur over a period as long as six years (USEC, 2005a). For the

purpose of this analysis, however, the NRC staff assumed that the period would be only five years, since

the proposed construction schedule shows peak activity over a five-year period. Using five years rather

than six years in this analysis provides a reasonable upper-bound estimate of likely traffic impacts.

USEC's Environmental Report also provides a yearly breakout of the centrifuge components to be

shipped to the proposed ACP site. To be conservative, the NRC staff used the highest number of

shipments reported for any single year, which was 2,286 truckloads, to estimate the number of trips

needed to transport centrifuges and related components to the site. Since the total volume of materials

needed is relatively large, the staff assumed that shipments would be spread out over 261 business days

within a year, and within an 8-hour business day.

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1 USEC's Environmental Report indicates that as many as 1,306 construction workers may be required to

2 build the proposed ACP (USEC, 2005a). Using this peak number of workers to be conservative, rather

3 than the average number of 900 workers per year over the entire construction period, the NRC staff

4 assumed that as many as 1,306 commuting trips could occur during the peak hour and twice as many trips

5 (to account for round trips) could occur each day. As shown in Table 4-5, these commuter trips are

6 estimated to have the largest traffic impact.

7

8 Based on these estimated increases in traffic volumes, the NRC staff calculated the effect on the roadway

9 level of service during peak hour traffic for site preparation and construction. The staff estimated the

10 level of service impacts for both Ohio State Road 32 and U.S. Route 23 assuming that all of the new trips

11 generated by the project would occur on both roads, although the actual traffic volumes produced on these

12 roads are likely to be lower. For U.S. Route 23, site preparation and construction traffic would

13 temporarily change the level of service from B to C. In Level of Service C, the influence of traffic

14 density on operations becomes marked, the ability to maneuver within the traffic stream is affected by

15 other vehicles, and the travel speeds reduce somewhat. Also, minor disruptions in Level of Service C can

16 cause serious local deterioration in service and queues could form behind any significant traffic

17 disruption. For State Road 32, the staff estimated that site preparation and construction would

18 temporarily change the level of service of the roadway from A to B, which still represents uncongested

19 roadway conditions. These changes would last only as long as the construction period (peak period

20 limited to five years). However, because the increased traffic would be sufficient to noticeably change

21 the level of service for this timeframe, the NRC concludes that the impacts would be MODERATE.

22

23 Non-Radiological Accident Impacts

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25 Motor vehicle safety is typically measured through accident rates, whether for trucks or passenger

26 vehicles. To obtain estimates of injuries or fatalities associated with the movement of workers, materials

27 and equipment needed for site preparation and construction, NRC staff gathered information on all the

28 trips that would need to occur for this phase of the project, including the number of trips and the overall

29 distance traveled.

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31 Based on the information provided by USEC in its Environmental Report (USEC, 2005a), the overall

32 results shown in Table 4-6 were compiled. In some instances, only total kilometers are presented in order

33 to preserve the proprietary nature of certain information on quantities of equipment or preferred suppliers.

34 The number of shipments listed includes all those made during the five-year preparation and construction

35 phase, with one- or two-way trips considered as specified in the Environmental Report (USEC, 2005a).

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Table 4-6 Transportation Requirements During Site Preparation and Constructions

ITotal Number Distance in 1 Total

Item or Material of Shipments I Kilometers | Kilometers Comments

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ o r T r ip s_ _ _ _ _ _ 1

Building Materials * 12,105 45 545,456 Trucks; one-way trips . ............... ........ . .. .... .. ........

Electrical Materials . 245,405 I Trucks __.. _ . . ..... ... ........... ... ...... .. . . . ...

Process Materials 2,515,029 .Trucks; one-way trips . ...... . *----.-**-i------- -. ........ __ . .... . ... _... ............

Trucks; the number of miles from Feed/Withdrawal 382 4,001 . 1,528,275 USEC's "Scenario 3" was used

Equipment .for conservatism.

. --- ------- -i-- . ....... .. .....----... ...... _..... Trucks; the number of miles from

Machines 10,884 4,001 . 43,543,834 1 USEC's "Scenario 3" was used

*. . conservatism. .for ....... ____._._.. ;._ -. ---- -............... -; -.. ------ - . .. . _ ; ........ _._ ...... _ ...... ;__......._ ..... ._...._.

Balance Stands *. 86,426 Trucks; three separate supply locations combined ..... .... .................... ..... .......

Total Truck Kilometers . 48,464,425 . ..... . . ... .......... .... . ......... . . ,_.............. . .... . .... . ..

Cars; 40 kilometers estimated

Workers . 3,408,660 40 * 137,138,913 o travel

Notes:

8 Some cells are left blank to preserve the proprietary nature of certain information.

To convert kilometers to miles multiply by 0.62.

Source: USEC, 2005a.

Given the variety of routes traveled and the number of States involved, national injury and fatality rates

were applied. As demonstrated by data from the Insurance Infornation Institute (HI, 2005) and from the

National Highway Traffic Safety Administration (NHTSA, 2005), fatal accident rates for Ohio have been

slightly lower than the national average in recent years, making this a slightly conservative approach for

travel within the State.

The National Highway Traffic Safety Administration's Traffic Safety Facts 2003 (NHTSA, 2005) give

the injury and fatality rates per vehicle mile traveled shown in Table 4-7. Such rates per vehicle mile

traveled reflect the activity levels of a project better than those that are per vehicle or per registered

driver.

Table 4-7 Injury and Fatality Rates Per Vehicle Mile Traveled

Type of Vehicle Injury Rate Fatality Rate

Large Trucks 12/100 million vehicle miles traveled , 0.33/100 million vehicle miles traveled ................. _._.............................................

Light Trucks . 85/100 million vehicle miles traveled * 1.18/100 million vehicle miles traveled ~~~...~...-.-.. _.-__... --......... .--.-.. _._.-....-. ...- ... __...._........ ._.. _.._......_. _

Passenger Cars 109/100 million vehicle miles traveled * 1.21/100 million vehicle miles traveled

Source: NHTSA, 2005.

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I Given the similarity between light trucks and passenger cars, it was assumed that all workers use

2 passenger cars. Large trucks are defined by the National Highway Traffic Safety Administration as those

3 over 4,536 kilograms (10,000 pounds), so all material and equipment deliveries or shipments were

4 assumed to be in large trucks.

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6 Combining the total mileage data with these accident rates gives the estimated nuiibers of fatalities and

7 injuries shown in Table 4-8. Over the course of the work to prepare the site and construct the necessary

8 facilities, it is expected that there would be slightly less than one injury per year associated with the

9 drivers bringing materials and equipment onto the site and about 18 injuries a year involving employees

10 traveling to or from their jobs. If employees travel less than 40 kilometers (25 miles) each way, this

11 estimate would decrease accordingly. These same impacts would be expected if the same employees

12 were driving to different employers. The overall injury impact is therefore considered MODERATE.

13

14 Table 4-8 Transportation Impacts From Site Preparation and Construction

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Itemor Injury Rate Fatality Rate 1 Number or Number of

Material TtlMiles per Vehicle per Vehicle Mile Injuries IFatalities -I __ ______ _____ M ile T raveled T raveled _ _ _ _ _ _ _ _ I _ _ _ _ _ _ _ _

Materials and 1. X1-. Eipent i 30,115,220 i 1.2x 1 j 0- 0.33x io . 3.61 1 0.10 Equipment.*..... . . -.......... - - ------ .__---------- 4. ............. .. . . ....... .. . .. ..... . .....

Workers . 8,521,650 1.09x 104 * 1.21 x 10' 93 1.03

Notes:

To convert miles to kilometers multiply by 1.61.

In terms of fatalities, only one fatality is expected for all the workers over the full site preparation and

construction period. For drivers transporting material and equipment to and from the site, the expected

number of fatalities is less than one. The overall fatality impact is therefore considered SMALL.

4.2.11.2 Facility Operation

The following sections describe the level of service impacts and non-radiological accident impacts

associated with increased road traffic during ACP operations. Impacts on water and air transport are not

reviewed because the proposed facility operation would not affect such modes of transportation. Impacts

on rail transport are also not reviewed because facility. operations are estimated to require only one train

every three months to ship converted depleted uranium to an offsite disposal facility (see Section 4.2.12).

This small increase in train traffic should not cause any impacts.

Level of Service Impacts

This section forecasts the traffic impacts of the proposed ACP operations. The primary impact analyzed

is the effect of an increase in the number of vehicle trips on the level of service provided by U.S. Route

23 and Ohio State Road Route 32, using the same basic approach as described above for level of service

impacts during site preparation and construction. The proposed ACP would generate vehicle trips during

operations through new workers employed at the site, through the movement of supplies to the site, and

through the movement of product and waste from the site.

This analysis starts with current traffic volumes and estimates the impact of an incremental change in

traffic volume on the level of service of the two roadways. The Highway Capacity Software from

McTrans (McTrans Center, 2003) was used to estimate level of service impacts. Section 4.2.11.1 on site

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1 preparation and construction impacts contains a description of the current traffic conditions that were used

2 as inputs to the software.

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4 The NRC staff estimated the volume of daily and peak hour trips that proposed ACP operations would

5 generate, using information submitted by USEC in its Environmental Report (USEC, 2005a). Table 4-9

6 shows the estimated increases in traffic volumes.

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8 Table 4-9 Highway Trips Generated by the Operation of the Proposed ACP

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T * Tye Number of Daily | Number of Peak Hour

rip yp Vehicle Trips Vehicle Trips

Materials, wastes, etc. 24 3 ... . ..... . ........... . .............................. _.._. . .............. . ........................... . ........... ...... .

Workers 1,113 199 ....... ........ . ............... ._.... ........... ......

Total 1,137 202

The staff conservatively assumed that the movement of materials and wastes due to the operation of the

facility would be spread throughout the 216 business days of the year and across eight hours of the day.

USEC's Environmental Report estimated that there would be approximately 3,134 truckloads associated

with the movement of feed material, product, heels, and waste (USEC, 2005a). The staff assumed that

each truckload generates a delivery trip and a return trip. This results in 24 trips per day and three trips

during the peak hour.

In addition to shipments for materials and wastes, a peak of 795 employees would be needed to operate

the proposed ACP (USEC, 2005a). Of these, 75 percent, or 596, would be shift workers with rotating

7:00 AM-7:00 PM shifts, spread across five shift schedules. For any given day, three of the five shifts

would be working and two shifts would be off, meaning that 358 of these shift employees would work on

any particular day. In addition, 25 percent of the employees required for proposed ACP operations (or

199 people) would be administrative employees, working a 7:30 AM to 4:00 PM shift. Each of these

employees would generate two trips per day. Taken together, these employees would generate 1 ,113 trips

during a typical day, but only 199 trips would be likely to occur during the peak hours, from 4:00 PM to

6:00 PM.

Based on these estimated increases in traffic volumes, the NRC staff calculated the effect on the roadway

level of service during peak hour traffic. The staff estimated the level of service impacts for both Ohio

State Road 32 and U.S. Route 23 assuming that all of the new trips generated by the project would occur

on both roads, although the actual traffic volumes produced on these roads are likely to be lower. This

analysis showed no level of service impacts from the operation of the facility to either State Road 32 or

Route 23.4 As a result, excess capacity presently exists on these roadways and the traffic impacts due to

proposed ACP operations are considered to be SMALL.

4 There would be some overlap in the proposed ACP site preparation and construction activities and the facility

operations activities, but site preparation and construction activities would be slowly phased out as operations are

brought online. This Draft EIS assesses the traffic impacts from site preparation and construction separately from

those impacts from facility operation, but the NRC staff also estimated the effect of simultaneous construction a'nd

operation to provide an upper bound of possible traffic impacts. Considering both impacts together did not change

the results of the analysis.

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Non-Radiological Accident Impacts

Table 4-10 shows the overall transportation requirements for the proposed ACP operations phase,-based '

on information provided by USEC in its Environmental Report (USEC, 2005a). 'The number of

shipments listed are made annually for as long as facility'operations are underway, and represent one- or

two-way trips as specified in the Environmental Report (USEC, 2005a). ' ' '

Table 4-10 Transportation Requirements During Facility Operations

I Number of Item or or Distance Total Comments

Material ShTipmentsoar |in Kilometers| Kilometers | ;

Uranium Fted S t1,300 . 789 to 896 1,133,317 . Trucks; three locations .. _ __~~~~~~ ...... __..... ...... ,4 ...... __........ _ _...... . _...... _ ;__.... _............_. ;._..I...... _.. ..__.... ~_.__... ._...._.

Heeled Cylinders 600 . 782 and 3,837 . 1,385,628 . Trucks; two locations ..... _.._. .... _4._.._._..__ _._._ ._ ._.. ...... _

Radiological Waste 22 1,344 to 3,355 62,611 Trucks; three locations

Various Supplies 216 a a No sources indicated ... ... ..... **.................. ........ ........ .... ................ ............ .........

Total Truck Kilometers (Miles) 2,581,556 ~~~~~~~.. _. ._... _.... _..._._.. ....... *.......... __........ ........ _.,_ ...... .... ... __........... 4 .._. _....._........__..... ....___

Workers 290,493 40 * 11,687,260 * ;40kilometers(25mi estimated one-way travel

Notes:

To convert kilometers to miles multiply by 0.62.

*This text is withheld pursuant to 10 CFR 2.390(a)(4).

Source: USEC, 2005a.

Table 4-11 combines the total mileage data with historical accident rates to estimate the numbers of

fatalities and injuries. During facility operations, it is expected that there would be about eight injuries

per year associated with employees traveling to or from their jobs. If employees travel less than 40

kilometers (25 miles) each way, this estimate would decrease accordingly. These same impacts would be

expected if the same employees were driving to different employers. In addition, there would be another

injury roughly every five years involving the trucks transporting materials to and from the site: The

overall injury impact is therefore considered SMALL.

Table 4-11 Transportation Impacts Per Year From Facility Operations

Injury Rate Fatality Rate -i

Item or Material Total Miles per Vehicle per Vehicle Mile Number of Number of

-Mile Traveled Traveled Injures Fatalities

Materals and 1,604,149 . 1.2 x 107 j 0.33 x 10- . 0.19 . . 0.01

Equipmentt

Workers 7,262,325 1 1.09x 104 . 1.21x l0- 7.9 . 0.09

Notes:

To convert miles to kilometers multiply by 1.61.

In terms of fatalities, one fatality would be expected every 10 years for the combination of the trucks

transporting materials and workers traveling to'and from the site. The overall fatality impact is therefore

considered SMALL.

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4.2.11.3 Ceasing Operations at Paducah

Ceasing operations at Paducah would decrease transportation impacts from those associated with current

operation of the Paducah enrichment plant. Transportation impacts would be largely eliminated upon

cessation of operations, as there would be no transportation of raw materials to the plant, of products from

the plant, or routine operations wastes from the plant. Also, the workforce at the plant would be greatly

reduced and the number of workers commuting to and from the site would decrease accordingly, thereby

reducing traffic. A smaller workforce would remain after cessation of operations to secure and maintain

the buildings and structures pending a decision on decommissioning and future site use. This workforce

would continue commuting to and from the site. However, this traffic would be much lower than that

associated with the existing operations workforce, resulting in an overall decrease in transportation

impacts.

Short-term transportation impacts may result from transportation of ancillary equipment into the plant that

is needed to shut the plant down. Any such impacts are anticipated to be small and of short duration.

Based on this analysis, the transportation impacts associated with ceasing operations at Paducah are

expected to be SMALL.

4.2.12 Public and Occupational Health Impacts

This section evaluates the potential public and occupational health impacts associated with all of the

transportation needed to bring people and materials in and out of the proposed ACP site. It also evaluates

the public and occupational health impacts associated with the proposed site preparation and construction

activities and the proposed ACP operations, separate from the transportation associated with those

activities.

4.2.12.1 Transportation

Potential public and occupational health impacts could arise from airborne emissions from routine

transportation associated with the proposed action, from radiation emitted during routine transportation,

and from postulated transportation accidents resulting in the release of radiological and non-radiological

materials. Each of these potential impacts is addressed below.

Airborne Emissions from Routine Transportation

Incoming and outgoing shipments associated with site preparation and construction activities, centrifuge

manufacturing, and facility operation would result in increased emissions of vehicle exhaust to the air.

This section evaluates the potential impacts of these emissions, based on the following assumptions.

Site Preparation and Construction. Transportation associated with site preparation and construction

(including the refurbishment of existing facilities) includes incoming truck shipments of building

supplies and concrete, all of which were assumed to originate within 80 kilometers (50 miles) of the

Piketon site. Incoming truck shipments of other equipment, such as electrical equipment, process

equipment, and feed and withdrawal equipment, are also included in the site preparation and

construction phase, but are assumed to originate at distances greater than 80 kilometers (50 miles). In

addition, site preparation and construction shipments are assumed to include the truck shipment of

wastes generated from the cleanup of the former Gas Centrifuge Enrichment Plant to an offsite

disposal facility more than 80 kilometers (50 miles) from Piketon.

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I Centrifuge Manufacturing. For the purpose of this analysis, centrifuge components and centrifuge

2 stands were assumed to be manufactured offsite, at a distance more than 80 kilometers (50 miles)

3 away, and shipped to Piketon by truck. Annual average emission rates were estimated assuming a

4 centrifuge assembly rate of 16 centrifuges per day (USEC, 2005a).

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6 Facility Operation. Transportation associated with facility operation was assumed to include the

7 transportation of natural UF6 feed material to the proposed ACP, enriched UF6 product from the

8 proposed ACP, radioactive waste to various disposal sites, and "heeled cylinders" (cylinders

9 containing small quantities of UF6 left after being emptied) to two possible vendor sites. This

10 analysis includes the offsite shipment of depleted uranium that is generated from facility operations

I I and converted in DOE's onsite conversion facility, but not the voluminous other wastes that would be

12 generated during facility decontamination and decommissioning (those shipments are considered

13 separately in Section 4.2.15). The analysis also includes shipments of assorted chemicals used for

14 operations, solid (non-hazardous waste), and hazardous waste. All impacts were assessed assuming a

15 plant capacity of 7 million SWUs per year and assuming all shipments would be by truck, except for

16 the offsite shipment of converted depleted uranium, which is assumed to occur by rail.

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18 Site Preparation and Construction and Centrifuge Manufacturing

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20 Because some centrifuge manufacturing is likely to occur at the same time as site preparation and

21 construction activities, the analysis combines these two activities to determine maximum potential impact.

22 In all cases, the incremental increase in average daily traffic emissions was estimated for two types of

23 trucks: long-haul and medium-haul. The trucks'associated with the building supplies and concrete were

24 assumed medium-haul and all others long-haul. The number of truck trips was taken from USEC's

25 Environmental Report (USEC, 2005a). In addition to emissions from the trucks, emissions would also

26 increase as a result of the construction workers' personal vehicles. As many as 1,306 construction

27 workers may be required to build the facility (USEC, 2005a). USEC assumed that each worker would

28 arrive as a single-occupant vehicle and that half the vehicles would be light-duty trucks and half would be

29 light-duty vehicles. Emissions were determined near the beginning of the active site preparation and

30 construction period, since heavy-duty truck emissions are expected to be substantially reduced over the

31 next ten years starting in 2007 with the introduction of catalyst-equipped and particulate trap heavy-duty

32 diesel trucks (see 40 CFR Parts 80 and 86). Emission factors used in this analysis for the heavy-duty

33 trucks, light-duty trucks, and light-duty vehicles are shown in Table 4-12.

4-49
a

I Table 4-12 2010 U.S. Long- and Medium-Haul Heavy-Duty Trucks, Light-Duty Trucks, and

2 Light-Duty Vehicles Fleet Average Emission Factors 'b

3

4

5

6

7

8

9

10

21

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Truck Type RoadType VOC CO 1 NOx | PM, 1 SO1

ruck T(ype (Road Ty (glmi) (g/mi) | (glmi)

Arterial/ Long-Haul Heavy-Duty * 0.36 1.25 I 5.61 0.11 0.011 LongHaulHea'.Dur i Highway 0.6.

Arterial/

Medium-Haul Heavy Duty I 0.44 1.85 . 8.32 0.16 0.011

H. . . . ....... . .

Light-Duty Trucks . Arterial . 0.91 I 11.7 . 0.78 0.025 . 0.0089 .----------- *. - --- ------------------ --- --- --- -

Light-Duty Vehicles I Arterial 0.74 . 9.49 * 0.54 * 0.025 * 0.011

Notes:

VOC = volatile organic compound; CO = carbon monoxide; NOx nitrogen oxides; PM,, = particulate matter with a mean

diameter of 10 micrometers or less; SO2 = sulfur dioxide. b gtmi = grams per mile.

To convert miles to kilometers multiply by 1.61.

Source: EPA, 2003.

The NRC staff compared the estimated incremental emissions from the trucks and construction worker

trips to the current annual average emissions associated with all vehicles along U.S. Route 23 near the

DOE reservation entrance. The current (2004) average 24-hour traffic volume near the entrance is 15,110

vehicles (average daily traffic), with 16 percent of the vehicles classified as heavy-duty trucks (Federal

Highway Administration Class 5-13), as reported in the Ohio Department of Transportation's Traffic

Survey Report (Ohio DOT, 2004a). Construction activity was assumed to occur over a five-year period.

The increase in emissions associated with this increase in traffic volume was then calculated for each

criteria pollutant and is reported in Table 4-13 on a grams per day basis near the entrance to the facility.

The results reported in Table 4-13 are for 2010, which is the year expected to have the greatest volume of

traffic coming in and out of the proposed site.

4-50

11
1 Table 4-13 Vehicle Emissions Associated with Construction-Related Traffic

2 at the DOE Reservation Entrance (in 2010) "bI3

4

5

6

7

8

9

10

I1I

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29'

30

31

32

33

34

35

36

37

38

39

40

41

42

| VOC | CO | NOx | PM,, | SO2

- (glmi/day) j (gliIlday) (g/milday) (glmilday) (glmilday)

Current Baseline

2004 Traffic 12,088 * 145,623 19,482 . 704 . 137

Increment

Long-Haul 3.1 10.6 47.6 1.0 0.1

Medium-Haul - 8.4 35.2 158.8 . 3.0 0.2 .. _._........ _._.._._._._........ .. 4 ... 4......__... 4^.__.. 4.........*..... .. _..,.. ..... *.._._....... ___

Worker Vehicles 2,160 27,648 1,725 65 26 ... - ...- .. . .... . -----. . -.- - ---- - - - - -- -- - -- -- - -.--- - ---- -- -- -- -

Total Emissions 2,172 27,694 1,932 69 . 26

PercentChangeoverBaseline 18% 19% 10% 10% 19%

Notes:

* Includes incoming shipments of centrifuge components. b VOC = volatile organic compound; CO = carbon monoxide; NOx = nitrogen oxides; PM,, = particulate matter with a mean

diameter of 10 micrometers or less; SO2 = sulfur dioxide.

X glmi = grams per mile.

To convert miles to kilometers multiply by 1.61. -

As shown in Table 4-13, the largest estimated impact is a 19 percent increase in carbon monoxide and

sulfur dioxide emissions, while the smallest estimated impact is a 10 percent increase for nitrogen oxides

and particulate matter with a mean diameter of 10 micrometers or less. These changes are likely to be

-sufficiently large to be detected through ambient air quality monitoring. However, they would occur only

temporarily during the construction phase and are unlikely to be large enough to cause an exceedance of

the National Ambient Air Quality Standards. Because the National Ambient Air Quality Standards are

designed to protect human health, the changes are unlikely to cause any adverse health impacts within the

surrounding population. Therefore, for the purpose of this analysis, the potential health impacts

associated with increased emissions from construction-related traffic are expected to be SMALL.

Facility Operation

The analysis of facility operations was similar to that described above for site preparation and -

construction and centrifuge manufacturing. Emission estimates were developed for truck activity

associated with all incoming and outgoing materials, and for the rail shipments of depleted uranium to a

suitable offsite disposal facility, after being converted to a non-reactive form in DOE's onsite conversion

facility at Piketon. The number of truck trips was taken from USEC's Environmental Report (USEC,

2005a). Estimates of emissions from the rail shipments of converted depleted uranium were developed

based on an estimate of approximately 42,800 cylinders of depleted uranium being generated over the 30-

year license period.5 Approximately one train with 100 railcars would be needed every three months to

ship this depleted uranium to an offsite disposal facility. In addition to increased emissions from the

truck and rail shipments, emissions would increase from the proposed ACP workers' personal vehicles.

As discussed in Section 4.2.11.2, workers needed to support proposed ACP operations would on average

5 USEC estimates that approximately 42,800 cylinders of depleted uranium tails would be generated if product

is enriched to 5 percent by weight of uranium-235, as is expected most of the time. If the ACP were to produce

enriched uranium at the maximum licensed assay of 10 weight percent of uranium-235, the tails generation rate

would be about 87 percent of the rate analyzed in this Draft EIS (USEC, 2005a).

4-51
l |

I generate 1,113 trips per day. USEC assumed that each worker would arrive in a single-occupant vehicle

2 and that half the vehicles would be light-duty trucks and half would be light-duty vehicles. As in the

3 preceding section, emissions were estimated starting in 2010, since heavy-duty truck emissions are

4 expected to have substantially reduced emissions over the next ten years starting in 2007 (see 40 CFR

5 Parts 80 and 86). Emission factors used in this analysis were the same as reported in Table 4-12. Rail

6 emission factors were based on EPA's Regulatory Support Document, Appendix 0, line-haul fleet

7 average emission factor for 2010 (EPA, 1998).

8

9 Table 4-14 compares the incremental increase in emissions from the combined truck, rail, and employee

10 trips during proposed ACP operation to the current annual average emissions associated with all vehicles

11 along U.S. Route 23 near the DOE reservation entrance. The largest impact is an estimated 11 percent

12 increase in sulfur dioxide emissions, while the smallest impact is an estimated increase of almost five

13 percent for nitrogen oxides and particulate matter with a mean diameter of 10 micrometers or less. These

14 changes are highly unlikely to be large enough to cause an exceedance of ambient air quality standards

15 and are sufficiently small that the change would be difficult to detect through ambient air quality

16 monitoring. As a result, the health impacts associated with vehicle traffic during the proposed ACP

17 operations phase are expected to be SMALL.

18

19 Table 4-14 Vehicle Emissions Associated with Operations-Related Traffic

20 at the DOE Reservation Entrance (in 2010) Fb

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

I VOC | CO NOx PM,, SO. _ (g/mi/day) I (g/mi/day) (glmilday) (glmi/day) |(gtmi/day)

Current Baseline

2004 Traffic * 12,088 145,623 19,482 704 137

Increment

Train Activity 2.1 6.8 . 37.2 . 1.4 * 4.2 ~~~~.... ._._......_ __.~._.............4........... ... ... ___......_ . ._.._...*. *..... ._... _..*....... . ...... ..... _..............._. ._. __.-..... ..

Long-Haul * 8.7 30.2 * 135.2 2.7 * 0.3 . .... . .. .... . - - - .. . - . ... - . - . ... - -.... --.-.---------.-.- .. 4 --- - ---. ..... . .. .. ... . .. 4.-.. ..... ....

Worker Vehicles . 920.5 1 11,781.1 * 735.1 27.9 . 11.1 ................... . .... .-.. ......-- *-.. ........ .... ....

Total Emissions . 931.3 . 11,818.1 . 907.5 * 32.0 . 15.5

Percent Change over Baseline 7.7% 1 8.1% * 4.7% 4.5% 1 11.4%

Notes:

* VOC = volatile organic compound; CO carbon monoxide; NOx = nitrogen oxides; PM,= particulate matter with a mean

diameter of 10 micrometers or less; SO2 = sulfur dioxide. b g/mi/day = grams per mile per day.

To convert miles to kilometers multiply by 1.61.

4-52

I1I
I Radiological Impacts from Routine Transportation and Transportation Accidents

2

3 Transportation of radiological materials would include shipments of feed material to the proposed ACP,

4 shipments of product materials (enriched UF6) from the proposed ACP, and shipments of radioactive

5 waste from the proposed ACP. Depleted UF6 is assumed to be' stored onsite until it is converted from UF6

6 to triuraniumroctaoxide (U30g), a more stable chemical form,' at the'new DOE conversion facility at

7 Piketon and then transported by railcar to a low-level waste disposal site. According'to USEC's'

8 Environmental Report (USEC, 2005a), feed materials would be transported from Metropolis, Illinois; Port

9 Hope,'Ontario, Canada; and Wilmington, Delaware in Type 48Y, Type 48X, and Type 30B cylinders,

10 respectively. Product materials would be shipped to Richland, Washington; Columbia, South Carolina;

11 Wilmington, North Carolina; and Seattle, Washington in Type 30B cylinders if the product is enriched to

12 5 percent or less, or another suitable 2.5-ton cylinder if the product is enriched to a higher percent.6

13 Wilmington, Delaware is the shipping port for feed materials from Russia, while Seattle is the port for

14 product shipments to Korea and Japan. Low-level radioactive waste would be shipped to Gainsville,

15 Florida; Clive, Utah; and/or the Nevada Test Site. The transportation of radiological materials is subject

16 to NRC regulations (10 CFR Par 71) and U.S. Department of Transportation regulations (49 CFR Parts

17 171-180). All the materials shipped to or from the proposed ACP would be shipped in Type A

18 containers. The product material is regulated by the NRC as fissile material and would require additional

19 fissile packaging considerations such as using an overpack surrounding the shipping container.

20

21 Exposure to radiation from radioactive shipments is assumed to result in an increased risk of latent cancer

22 to crews operating the truck or train, persons sharing the route with the shipment (on-link public), persons

23 living alongside the route (off-link public), and persons at rest stops and inspection stops. These latent

24 cancers do not occur immediately after exposure, but instead occur a number of years after the exposure.

25 The radiological impacts to occupational workers and the general public from the transport of the above26 mentioned radioactive materials were estimated using RADTRAN 5, a computer code for analyzing the

27 consequences and risks of radioactive material transportation. RADTRAN 5 estimates the number of

28 latent cancer fatalities from accidents and the incident free transport of the materials, where the term

29 "incident-free" means that no traffic accident or other incident resulted in the release of radioactive

30 material to the surrounding environment. In this context, accidents refer only to incidents that result in

31 the release of radioactive material.

32

33 NRC classifies accidents into eight severity categories, based on the mechanical (impact) and thermal

34 (fire) forces involved (NRC, 1977). Category I is the least severe and Category VIII is the most severe.

35 Less severe accidents occur more frequently, but have relatively mild consequences. More severe

36 accidents happen less frequently, but have more significant consequences, including the release of some

37 or all of the radioactive material in the shipment. For this Draft EIS, the NRC staff has estimated the

38 fraction of accidents for truck and rail transport that fall within each category. Additionally, the staff has

39 estimated the fraction of accidents in each category that occur in rural, suburban, and urban areas. Less

40 severe accidents are most likely to occur in urban areas, where driving speeds are typically lower, while

41 more severe accidents are more likely to occur in rural areas where driving speeds are higher (NRC,

42 1977). These estimates when combined with average accident rates are used to estimate the number of

43 latent cancer fatalities due to exposure to radiation and radioactivity from transportation accidents. For

6 No 2.5-ton cylinder is currently certified to ship uranium enriched to higher than 5 weight percent of uranium235. Although it is currently believed to be unlikely, USEC may enrich product up to 10 weight percent of uranium235. In the event this higher enrichment occurs, USEC would have to gain the appropriate certification before it

shipped 10 percent product in either an existing 2.5-ton cylinder or in a new 2.5-ton cylinder. This Draft EIS's

analysis of direct radiation surrounding Type 30B cylinders containing enriched product is considered reasonable for

shipping scenarios involving higher-enriched product in another type of approved 2.5-ton cylinder (i.e., direct

radiation levels for such alternate containers are expected to be similar).

4-53
I purposes of this analysis, all releases of material are assumed to be airborne and respirable, which is very

2 conservative. Fatalities due to chemical effects and bodily injury are addressed separately.

3

4 The RADTRAN 5 results presented in Table 4-15 are based on a number of input parameters, including

5 the number of trips per year, the quantity of material transported per trip, the route used, the average

6 accident rates for the route, and the population density along the route. The results in Table 4-15 are also

7 based on the most likely scenario in which the enriched product contains approximately 5 percent by

8 weight of uranium-235. Routes and population densities were determined using the Transportation

9 Routing Analysis Geographic Information System model developed by Oak Ridge National Laboratory

10 for the Department of Energy's National Transportation Program. Radioactive shipments were treated as

11 Highway Route Controlled Quantities for route determination. More detail on the methods and inputs

12 used for this analysis are provided in Appendix D of this Draft EIS.

13

14 As shown in Table 4-15, the transportation of feed material, product, heel cylinders, radioactive waste,

15 and the converted depleted uranium results in some increased risk of cancer to both the occupational

16 workers transporting and handling the material and to members of the public driving on the roads or

17 living along the transportation routes. The transport of all materials is estimated to result in

18 approximately 0.014 latent cancer fatalities per year of operation from exposure to direct radiation during

19 incident-free transport, and an additional 0.008 latent cancer fatalities per year from accidents that result

20 in the release of radioactive material into the environment. The total latent cancer fatalities is estimated to -

21 be 0.02 per year of operation or less than one cancer fatality over 30 years of operation.

22

23 The results presented above are for product materials enriched to approximately 5 weight percent of

24 uranium-235. Although it is currently believed to be unlikely, USEC may in the future enrich product up

25 to 10 weight percent of uranium-235. There are currently no 2.5-ton cylinders certified for the shipment

26 of this higher enriched material. In the event this higher enrichment occurs, USEC would have to gain

27 the appropriate certification before it shipped 10 product in either an existing 2.5-ton cylinder or in a new

28 2.5-ton cylinder. External exposure rates surrounding such a cylinder would likely be similar to those

29 around the 30B cylinders presently used to ship 5 percent product and less than the external dose

30 equivalent rates used in this assessment. For this reason, the risks associated with the incident-free

31 transport of the 10 percent enriched product would not be significantly different than that of the 5 percent

32 enriched product.

33

34 However, the accident-related radiological risks associated with the transport of the 10 percent enriched

35 product would be somewhat greater than that of the 5 percent enriched product. This is primarily due to

36 the higher activity of uranium-234 in the 10 percent enriched product. Uranium-234 does not contribute

37 significantly to the external dose rate, but is an inhalation hazard if released. Table D-16 in Appendix D

38 shows the calculated latent cancer fatalities from the transport of the higher enriched product for the same

39 routes analyzed previously. The number of expected latent cancer fatalities associated with accidents

40 involving only the transport of the 10 percent enriched product - not considering the other materials that

41 would also be shipped - would be approximately three times greater than that for the 5 percent enriched .

42 product (i.e., 0.0087 latent cancer fatalities per year rather than the 0.0029 latent cancer fatalities per year

43 reported in Table 4-15). When this higher number is added to the risks reported in Table 4-15 for

44 incident-free shipping and transportation accidents involving the other materials, the total estimated latent

4-54

Il
1 cancer fatalities becomes 0.03 per year of operation, which still equates to less than one cancer fatality

2 over 30 years of operation. It should be noted that this analysis for 10 percent enriched product is

3 conservative in that it assumes all the product material is enriched to 10 percent and it does not account

4 for the decreased accident risks associated with the corresponding lower activities of uranium-234 in

5 shipments of the conversion products (since uraniumn-234 activity would be higher in the 10 percent

6 product it would be lower in the accompanying tails).

7

8 Based on these results, the public and occupational health impacts associated with the proposed transport

9 of radioactive materials are expected to be SMALL.

4-55-
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2

3

4

5

6

7

8

9

10

I11

12

13

14

Table 4-15 Estimated Latent Cancer Fatalities from the Transportation of Radioactive Materials for One Year of Operation

Incident Free

lIaterial General Population Occupational Workers I Maximally Accidents 1lnspection Loading Total Exposed Off-Link J On-Link Rest Stops Crew Stops Crew Individual

Feed Material 2.3 x 103 1.7 x 10 3 I 2.3 x I' 2.9 x 10 3 i 2.0 x 10'3 9.1 x 104 1.0 x 10.2 9.4 x 10'9 4.2 x 10'3

.4....................................................... . ..... ... .............. 4 . . .............. ..... .~6

Product' I 4.5x10'5 i 3.3x 10 i 7.0x 104 i 7.6x IO' 3.3x 10 4 2.7x 104 4 2.4x l0 i 6.7xl10"' 2.9xl03 ........................ 4.4.......---------------........--. ----

Heels I 3.6x 104 1 2.7x10'5. 3.6xIO0 I 6.4xl0'5 3.0xl0I' I 9.7xl05 i 2.7x 104 I 8.9x 10'" . 1.6x 10O' ......................... .................. 4 ... . 4 .......... ....

Radioactive Waste 1.3 x 10-5 1.1 x l0-4 1.3 x i` | 3.1 x104 9.3xl 0 - 1 l04 x 8.9x104 3 3.5 x10-'0 1.2x10' ............................. ................................................ ....- -.

Converted Products t i

(Depleted Uranium and 7.3 x 10- 7.3x 104 7.3x 10' 2.2 x 107 0.0 x 100 0.0x 10° 2.8 x 10 3.2x 10"- 1 7.Sxl0'

Calcium Fluoride) I.. ' i

Total , 2.9x10-7 2.2x 104 ' 3.3xl10-7 4.0 x 10-3 2.4x10-3 . 1.4x10-3 1.4x 102 9.4x10 i' 7.8 x 103

Notes:

*Assuming the most likcly scenario involving product enriched to 5 percent by weight of uranium-235.

4-56
I Non-Radiological Impacts from Transportation Accidents

2

3 In addition to the radiological impacts during transportation described above, chemical impacts from a

4 transportation accident involving uranium could also affect the surrounding public. Uranium compounds,

5 in addition to being radioactive, can have toxic chemical effects (primarily on the kidneys) if inhaled or

6 ingested.' The operation of the ACP would result in the truck transport of UF6 as feed and product

7 material to and from the ACP, as well as the rail transport of U30, as a conversion product for offsite

8 disposal. Calcium'fluoride, another conversion product, contains small amounts of uranium as a

9 contaminant.

10

11 When released from a shipping cylinder, UF6 reacts with the moisture in the atmosphere to form HF and

12 uranyl fluoride. HF is extremely corrosive and can damage the lungs and cause death if inhaled at high

13 'enough concentrations. Irreversible adverse effects resuilting from sufficiently high concentrations of

14 these chemicals include permanent organ damage, or the impairment of everyday functions, and death.

15 Adverse effects from exposure to lower concentrations include skin rash and respiratory irritation. The

16 number of deaths resulting from the chemical effects of HF and uranyl fluoride is estimated to be I

17 percent of those experiencing irreversible effects (Policastro et al., 1997)

18

19 To estimate the chemical effects of an accident involving the transport of UF6 and U30., DOE modeled

20 the dispersion of chemical emissions released into the environment from' a transportation accident

21 involving a fire (ANL, 2001; DOE, 2004a). The results were used to determine the number of people

22 whose exposure would exceed the threshold for adverse effects and irreversible adverse effects. DOE

23 estimated the chemical effects for accidents in rural, suburban, and urban areas. Table 4-16 shows the

24 potential chemical impacts to the public from a hypothetical severe transportation accident that involves a

25 fire. The assumptions supporting the impacts summarized in this table are provided in Appendix D.'

26

27 Table 4-16 Potential Chemical Consequences to the Population

28 from Severe Transportation Accidents

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

Number of Persons with

Number of Persons with Potential Irreversible Adverse

Material Potential Adverse Health Effects Health Effects

Mode Rural - Suburban Urban Rural Suburban Urban

UF,. Truck * 6i. 760 * 1,700 .3 . .................... *-.----- ---------.---------- ---......_

U303 : .Rail * 0 . 47 103. 0 17 38

Source: DOE, 2004a.

Based on the total number of trips, the length of the trips, and the mean accident rate, the estimated

number of accidents involving shipments of UF6 is 0.5 accidents per year or an average of one accident

every two years. This would translate into a total of 15 potential accidents over the 30-year operating life

of the proposed ACP. Of these accidents, approximately 55 percent would not result in the release of any

UF6, and another 43 percent would result in a release of no more than 10 percent of the UF6 . About two

percent of all accidents are expected to be severe enough to result in the release of all the UF6 present.

The probability of one or more of the 15 expected accidents being this severe is about 26 percent. Such

an accident is most likely to occur in a rural or suburban area. The shipment of U308 would likely

involve no more than four trainloads per year, making an accident unlikely.

These results indicate that the probability of a severe transportation accident that releases sufficient

quantities of uranium that could pose a health risk is low, but that the consequences of such an accident,

4-57
1.

i

I

I

1 should it occur, are high. Based on this analysis, the public health impacts associated with such an

2 accident as part of the proposed action are considered MODERATE.

3

4 4.2.12.2 Site Preparation and Construction

5

6 This section evaluates the potential for occupational injuries and illnesses associated with the proposed

7 site preparation and construction activities. It also evaluates the potential public and occupational health

8 impacts from non-radiological and radiological releases during site preparation and construction.

9

10 Occupational Iniuries and Illnesses

11

12 Non-radiological occupational injuries and illnesses associated with site preparation and construction

13 were estimated using annual injury and illness data for heavy construction compiled by the U.S. Bureau

14 of Labor Statistics. This Bureau compiles statistics by the North American Industry Classification

15 System, which replaced Standard Industrial Classification Codes in 2000. Site preparation and

16 construction of the proposed ACP is classified under North American Industry Classification System

17 Code 2379, Other Heavy and Civil Engineering Construction. Incident rates for Total Recordable Cases

18 and Lost Workday Cases for calendar year 2003, in units of incidents per 100 full-time equivalents, were

19 obtained from the Bureau of Labor Statistics Publication Table 1, Incident Rates of Nonfatal

20 Occupational Injuries and Illnesses by Industry and Case Types 2003 (BLS, 2004a). Fatality incident

21 rates for Construction (North American Industry Classification System Code 23) for calendar year 2003,

22 in units of incidents per 100,000 full-time equivalents, were obtained from Bureau of Labor Statistics

23 Publication National Census of Fatal Occupational Injuries in 2003 (BLS, 2004b).

24

25 The number of construction workers per year (full-time equivalents) and the duration of construction

26 were obtained from USEC's Environmental Report (USEC, 2005a). The incident rates for Total

27 Recordable Cases, Lost Workday Cases, and Fatalities were applied to the number of construction

28 workers per year and the construction schedule to estimate the total number of incidents. The incident

29 rates, total full-time equivalents, and total incidents are summarized in Table 4-17. Based on the total

30 number of incidents estimated for site preparation and construction, impacts to occupational safety from

31 site preparation and construction would be SMALL.

32

33 Table 4-17 Health and Safety Statistics for Estimating Industrial Safety Impacts Common to the

34 Workplace and Total Incidents for Site Preparation and Construction

Ii

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I.

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35

36

37

38

39

40

41

42

43

44

45

46

47

48

FTEs * Total Recordable Cases Lost Workday Cases Fatalities

FTEs Total Incidents Total Incidents Lost Incidents per Total

per year FTEs per 100 Recordable per 100 Workday I100,000 FEs Fatalities

FrEs Cases FrTEs Cases

1,013 5,065 4.3 218 1.9 . 96 . 11.7 . 0.59

Notes:

a FTEs = full-time equivalents.

Source: USEC, 2005a; BLS, 2004a; BLS, 2004b.

Non-Radioloeical Impacts

During the site preparation and construction phase, there may be occupational exposures to fugitive dust

kicked up from land disturbances and to pollutants exhausted from vehicles and earth-moving equipment,

including particulate matter, nitrogen oxides, sulfur oxides, and carbon monoxide. For this Draft EIS, the

4-58

11
I NRC staff predicted the following maximum (one-hour) airborne concentrations in workplace

2 environments: 0.31 milligrams per cubic meter of particulate matter, 0.50 milligrams per cubic meter of

3 nitrogen oxides, 0.06 milligrams per cubic meter of sulfur oxides, and 0.14 milligrams per cubic meter of

4 'carbon monoxide (see Section 4.2.4.1). All of these concentrations are substantially lower than

5 workplace exposure limits, so the occupational health impacts would be SMALL.

6

7 Both the water and air exposure pathways are of interest for the public. As discussed in Section 4.2.6.1,

8 the potential impacts to surface water and groundwater quality due to site preparation and construction

9 activities are'expected to be small, because releases to surrounding ditches, tributaries, and creeks would

10 be controlled under the National Pollutant Discharge Elimination System and through the use of'

11 engineering controls and best management practices. The primary threat to water quality would be a

12 temporary increase in sedimentation and turbidity, as a result of storm water runoff from soils exposed

13 during the construction-phase, but this potential impact is not a hurnan health concern. Therefore, the

14 public health impacts associated with any non-radiological water contamination would be SMALL.

15

16 As discussed in Section 4.2.4.1 (see Table 4-1), site preparation and construction activities are predicted

17 to result in airborne concentrations of criteria pollutants at the reservation boundary that are below the

18 National Ambient Air Quality Standards, except for a slight exceedance of the standard for particulate

19 matter with a mean diameter of 2.5 micrometers or less out to a distance of 1,000 meters (3,280 feet)

20 beyond the southern fenceline. While emissions from site activities contribute to this exceedance, the

21 -vast majority of it is the result of high background concentrations of 13.8 micrograms per cubic meter for

22 particulate matter with a mean diameter of 2.5 micrometers or less in the area. Overall, this exceedance

23 would be small in magnitude (the predicted concentration is 16.1 grams per cubic meter relative to the

24 standard of 15 grams per cubic meter), temporary, confined to a limited area, and a public health threat

25 only if somebody were to'move to the affected area near the fenceline. Therefore, the anticipated public

26 health impacts are expected to'be SMALL.

27

28 Radiological Impacts

29

30 Radiological impacts'during site preparation and construction would be primarily to the construction

31 workers performing those activities. Exposures to offsite personnel are greatly below those of the

32 construction workers themselves because of atmospheric dispersion of airborne material and increased

33 distance from external exposure sources. The construction workers are assumed to be an unmonitored

34 population, meaning that they are not monitored for radiation exposure by the onsite radiation exposure

35 - control program. Because the workers are not considered "radiation workers," the applicable dose limits

36 for the construction workers are those for the general public listed in 10 CFR § 20.1301 (a)(1).

37

38 'Site preparation and construction activities would not generate any radiological contamination,'but they

39 would disturb areas contaminated by pievious site-activities, including operation of the Gas Centrifuge

40 Enrichment Plant, operation of the Gaseous Diffusion Plant, and storage of previously accumulated

41 cylinders of uranium-bearing material. Therefore, the primary modes of exposure for construction

42 personnel would be: (1) inhalation of previously existing radiological contamination that are in the dust

43 suspended by construction activities; (2) external exposure from radionuclides contained in contaminated

44 soil suspended in the air; (3) external exposure from radionuclides previously deposited in the soil on the

45 ground; and (4) external exposure from existing sources nearby on the site such as the cylinder storage

46 yards. Internal exposure from ingestion of food and drinking water is not considered a potential exposure

47 mode for the construction workers.

48

49 The method for estimating the radiation dose received by the construction personnel from each of these

50 exposure modes is given in Appendix C. Dose from inhalation of radioactive material suspended in the

51 air, external exposure from radioactive material suspended in the air, and external exposure from

4-59
1 radioactive material in the surrounding soil was calculated using data from site environmental reports and

2 dose factors from Federal Guidance Report 13 (the latest dose conversion factors published by the U.S.

3 EPA) (EPA, 1999). The dose from external exposure to existing sources of radiation at the site was

4 estimated using information from the thermoluminescent dosimeters located at various locations within

5 the site boundary. Many of these thermoluminescent dosimeters are located near the locations where

6 construction work is expected to be performed, making them the best available data on ambient radiation

7 fields in the vicinity of the work activities.

8

9 The maximum estimated dose for each of the exposure modes was calculated for an annual exposure

10 period. These estimated doses are:

11

12 * Internal dose from inhalation - less than I x. IO- millisieverts per year (0.1 millirem per year);

13 * External dose from submersion - less than I x 1O' millisieverts per year (0.1 millirem per year);

14 * External dose from radionuclides in soil - less than I x IO-' millisieverts per year (0.1 millirem per

15 year);

16 * External dose from existing sources - 0.88 millisieverts per year (88 millirem per year); and

17 - Total maximum possible dose - 0.89 millisieverts per year (89 millirem per year).

18

19 The maximum dose is dominated by the external dose received from existing external sources. As

20 described in Appendix C, the 0.88-millisieverts (88-millirem) dose from existing external sources is

21 derived from a worst-case exposure analysis for a worker employed for a full year at the location of the

22 highest reading thermoluminescent dosimeters near the proposed X-745H Cylinder Storage Yard. The

23 most likely dose to construction workers from existing external sources is 0.20 millisieverts per year (20

24 millirem per year) based on the nearest thermoluminescent dosimeter readings, which would provide for a

25 total maximum possible dose approximately 0.22 millisieverts per year (22 millirem per year) (DOE,

26 2003). A dose of 0.20 millisieverts (20 millirem) is on the same scale as the variations in individual

27 annual dose caused by the fluctuation in natural background. Background radiation exposure in the U.S.

28 averages approximately 3.6 millisieverts per year (360 millirem per year) (NRC, 2005a).

29

30 The total maximum possible dose to construction workers from all four pathways is less than the I

31 millisievert per year (100 millirem per year) limit in 10 CFR § 20.1301(a)(1), even for estimates

32 combining the most conservative analytical assumptions. This is a negligible dose, representing a lifetime

33 excess cancer risk of less than 5 x 10-5 (less than a 5 in 100,000 chance of getting cancer) when using a

34 risk coefficient of 5 x Io-2 risk per sievert (5 x I0O risk per rem) (EPA, 1994). Based on this assessment,

35 the impact on workers from radiological exposure during site preparation and construction is SMALL.

36

37 The dose to offsite personnel will be significantly smaller than that for construction workers, particularly

38 since offsite personnel will not have any potential for measurable exposure from the cylinder storage

39 yards. As described in Appendix C, the maximum exposure to offsite personnel is estimated to be less

40 than I x 10' millisieverts per year (0.1 millirem per year). The impact on offsite personnel from site

41 preparation and construction is therefore SMALL.

42

43 4.2.12.3 Facility Operation

44

45 This section evaluates potential occupational injuries and illnesses, as well as public and occupational

46 health impacts associated with non-radiological and radiological releases, from the proposed ACP

47 operations. It also evaluates the potential impacts of plausible accident scenarios.

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Occupational Injuries and Illnesses

As for site preparation and construction, non-radiological occupational injuries and illnesses associated

with facility operation were estimated using annual injury and illness data from the U.S. Bureau of Labor

Statistics. Operation of the proposed ACP is classified under North American Industry Classification

System Code 325188, All Other Basic Inorganic Chemical Manufacturing. Incident rates for Total

Recordable Cases and Lost Workday Cases for calendar year 2003, in units of incidents per 100 full-time

equivalents, for North American Industry Classification System Code 325188 were obtained from the

Bureau of Labor Statistics Publication Table 1. Incident Rates of Nonfatal Occupational Injuries and

Illnesses by Industry and Case Types 2003 (BLS, 2004a). Fatality incident rates for Manufacturing

(North American Industry Classification System Code 325) for calendar year 2003, in units of incidents

per 100,000 full-time equivalents, were obtained from Bureau of Labor Statistics Publication National

Census of Fatal Occupational Injuries in 2003 (BLS, 2004b).

The number of operations workers per year (full-time equivalents) and the duration of facility operation

were obtained from USEC's Environmental Report (USEC, 2005a). The incident rates for Total -

Recordable Cases, Lost Workday Cases, and Fatalities were applied to the number of operations workers

per year and the operation schedule to estimate the total number of incidents. The estimated incident

rates, total full-time equivalents, and total incidents are presented in Table 4-18. Based on the small total

number of incidents reported in this table, impacts to occupational safety from facility operation should

be SMALL.

Table 4-18 Health and Safety Statistics for Estimating Industrial Safety Impacts Common to the

Workplace and Total Incidents for Facility Operation

FTEs * Total Recordable Cases Lost Workday Cases Fatalities

Incidents Total Incidents Lost n ;er .

per year Total per Recordable per Workday Inc dents per Fatalities

pe ya}F~ 100 FTs Cases 100 FTEs Cases 1000F~

600 16,2001 2.8 454 1.3 211 2.5 0.41

Notes:

' FTEs = full-time equivalents.

Source: USEC, 2005a; BLS, 2004a; BLS, 2004b.

Routine Non-Radioloiical Impacts

The greatest potential for occupational exposures is in the product and tails withdrawal buildings, where

cylinder connections and disconnections have' the potential to release small amounts of UF6'into the

workplace environment. Any released UF6 would react with ambient moisture to form HF and uranyl

fluoride. Gulper systems, utilizing a flexible hose or ventilation hood, would be used to evacuate any

such releases from the workplace. Airborne concentrations of HF and uranyl fluoride are expected to be

insignificant with respect to worker exposure except in the area in the immediate vicinity of the release

area and the gulper. Based on historical monitoring results and the anticipated amount of UF6 released,

USEC estimates that workplace concentrations of HF would be less than one percent of the Occupational

Safety and Health Administration's Permissible Exposure Limit of 2.5 milligrams per cubic meter over an

eight-hour averaging te. Concentrations of HF in the immediate vicinity of the UF6 release point could

be briefly higher, but are still expected to be less than 10 percent of the Permissible Exposure Limit

(USEC, 2005a). Based on this analysis, the impacts associated with occupational exposures to HF in the

workplace should be SMALL.

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I The NRC staff estimates that uranium concentrations in the workplace air could be as high as 0.7 -

2 milligram per cubic meter. This concentration was estimated using USEC's reported maximum short3 term concentration of HF and then using the stoichiometry of the UF6 reaction with atmospheric moisture

4 to form uranyl fluoride and HF fumes. The staff expects that concentrations this high would represent

5 short-term peaks in the immediate vicinity of "puff releases" of UF6. For such short-term exposures, a

6 relevant standard is the National Institute of Occupational Safety and Health's Immediately Dangerous to

7 Life and Health level of 10 milligrams per cubic meter of uranium over a one-hour period. Since the

8 staff's predicted concentration is below this standard, the impacts associated with occupational exposures

9 to uranium in the workplace air are also likely to be SMALL.

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In addition to the HF and uranyl fluoride, workers could be exposed to airborne concentrations of criteria

pollutants emitted from the operation of the proposed ACP's emergency diesel generators. The NRC staff

predicted that these emissions would result in the following maximum (one-hour) airborne concentrations

in workplace environments: 0.006 milligrams per cubic meter of particulate matter, 0.34 milligrams per

cubic meter of nitrogen oxides, 0.005 milligrams per cubic meter of sulfur oxides, and 0.09 milligrams

per cubic meter of carbon monoxide (see Section 4.2.4.2). All of these concentrations are substantially

lower than workplace exposure limits, so the occupational health impacts associated with exposures to

criteria pollutants would be SMALL.

With respect to public health impacts, Section 4.2.6.2 concludes that non-radiological releases from

proposed ACP operations to surface water and groundwater should be small and should not degrade

existing water quality. Therefore, the public health impacts associated with such liquid releases would

also be SMALL.

Public health impacts associated with non-radiological releases to the air are also expected to be SMALL.

As detailed in Section 4.2.12.3, routine airborne emissions from the proposed ACP are projected to result

in a maximum HF concentration of 2.35 x 10-3 micrograms per cubic meter and a maximum uranium

concentration of 6.09 x IO-' micrograms per cubic meter, both at the point of the Ohio National Guard

building located onsite 555 meters (1,820 feet) from the proposed ACP buildings. Both of these

concentrations are orders of magnitude below safe levels established by the Occupational Safety and

Health Administration (2,500 micrograms per cubic meter for HF and 50 micrograms per cubic meter for

uranium, both averaged over eight hours). Similarly, as discussed in Section 4.2.4.2, the predicted

concentrations of criteria pollutants in air at the property boundary are well below the National Ambient

Air Quality Standards.

Routine Radiological Impacts

This section describes the potential radiological impacts to members of the public and workers from the

proposed ACP operations. Appendix C documents the methodology used in evaluating and reviewing

information and site-specific data provided by USEC. Technical reports and safety analyses related to the

potential hazards, and other independent information sources, were also reviewed.

Public Health Impacts

Radiation exposure to the public is possible via intake of uranium released from proposed ACP operations

or from direct external exposure to the radiation emitted by the uranium. The two potential pathways of

concern leading to public intake of uranium are airborne releases and liquid releases. Airborne releases

may occur from routine operations or from small controlled releases to the atmosphere from the uranium

enrichment process lines, specifically at the feed, withdrawal, sampling, and analysis points. Liquid

releases may result from decontamination and maintenance of failed equipment or equipment being

serviced and any associated releases of radioactive liquids to surface water. Direct external exposure

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I could occur from emission of radiation from the process lines, storage and handling of UF6, and the

2 collection, management, temporary storage, and transportation of other low-level radioactive or low-level

3 mixed waste. -Direct radiation and skyshine (radiation reflected from the atmosphere) originating from

4 operations inside the facility would be expected to be undetectable at offsite areas. The direct radiation

5 emitted by the uranium in the'facility would be significantly absorbed by the heavy process lines, walls,

6 equipment, and tanks at the proposed ACP. Additionally, any direct radiation would have to travel over

7 900 meters (3,000 feet) to reach the current nearest member of the public.

8

9 Public Dose From Airborne Releases of Radioactive Materials

10

11 The proposed ACP would release small amounts of uranium to the atmosphere during operation. The

12 modeling performed for this analysis evaluated the impact of these releases to offsite populations and to

13 onsite populations that are not included in the site's radiological dose monitoring program. Both of these

14 groups are considered to be limited by the 1 millisievert per year (100 millirem per year) public exposure

15 limits in 10 CFR § 20.1301(a)(1) and by the 0.1 mnillisieverts per year (10 millirem per year) airborne

16 dose limits in 40 CFR Part 61, Subpart H, the U.S. EPA's National Emissions Standards for Hazardous

17 Air Pollutants.

18

19 This analysis modeled releases from five release sources: (1) stacks on the process buildings (X-3001, X20 3002, X-3003, and X-3004); (2) the product and tails withdrawal buildings (X-3356 and X-3366); (3) the

21 analytical laboratory (X-710); (4) the feed component of Building X-3346; and (5) the customer services

22 component of Building X-3346. The feed, withdrawal, and product operations uranium-235 design assay

23 may range from approximately 1.6 percent to 10 percent. The customer product range is typically from

24 approximately 2.4 percent to 5 percent, although it may occasionally be as high as 10 percent; Table 4-19

25 shows the annual release rates modeled for each of the locations using a customer product assay of 5

26 percent by weight of uranium-235. The values in this table represent the maximum of the typical

27 customer assay range and should provide a reasonably high estimate of the most likely potential dose

28 received from airborne releases of uranium from the ACP. In order to bound the infrequent and less

29 likely possibility of product being enriched to 10 weight percent of uranium-235, this analysis also

30 calculated the potential annual dose from airborne emissions assuming the maximum customer assay

31 allowable under the NRC license.

32

33 Table 4-19 Airborne Release Rates Assuming Enrichment of

34 5 Weight Percent of Uranium-235

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L| Uranium-234 Uranium-235 | Uranium-238

Locat __n Bqlyr Bq/yr j Bqlyr

Feed (X-3346) 2.89 x 107 1.27x 106 * 2.76x 107 ......... ........... -.. -.... .

Analytical Lab (X-710) . 2.33 x lO . 1.07 x 17 * 8.14x 107 ._...........-.-... .......-.. ---.-...- .............................

Process Buildings (X-3001through X-3004) 2.21 x 109 1.02 x lOs' , 7.70 x IO' _. ... _._...... _..........____......__..... ___;...................4,._..._._.;. __.......*......_._.... .. _. ; __......_._._........._._ _......

Withdrawal (X-3356 and X-3366) 8.29 x 10 3.81 x 106 2.89x 107 .. . ..*.. .......... . . - - - - -------- - ---.--- - -------------. -----.------ T.. ... ........

Customer Services (X-3346) '* 5.07 x i . 1.79 x 106 * 5.37x 106 ........ .. .... ................ ................. ...................

Total Plant . 2.60 x 109 1.19x IO, 9.14 x lO

Notes:

Bq/yr = becquerels per year

I curie (Ci) = 3.7 x 10o0 becquerels

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1.

1 Version 3 of the U.S. EPA air modeling code CAP88-PC was used to assess the impacts from proposed

2 ACP emissions of uranium. The CAP88-PC model analyzes radiation dose from a number of exposure

3 pathways. These include inhalation, submersion (external dose from a cloud of airborne radioactive

4 material), grounidshine, and ingestion of foodstuffs containing radioactive material propagated into the

5 foodchain following deposition on the ground. CAP88-PC is approved by U.S. EPA for demonstrating

6 compliance with the National Emission Standards for Hazardous Air Pollutants; version 3 is the latest

7 update that includes the most recent dose and risk conversion factors. A description of the modeling

8 approach in CAP88-PC Version 3, together with the compiled outputs from CAP88-PC for this analysis,

9 are provided in Appendix C.

10

11 As shown in Table 4-19, the feed operation's emissions would derive from natural uranium. The process,

12 withdrawal, and analytical laboratory buildings are assumed to have an average 2 percent uraniuni-235

13 assay, and the customer services building emissions would derive from material having an average 5

14 percent uranium-235 assay based on typical customer orders. The process building vent characteristics

15 were based on the existing process vents in X-3001 and X-3002 where the vent height is 23 meters (75

16 feet) above grade and the vent diameter is 0.05 meter (2 inches). The vent heights for the feed,

17 withdrawal, and customer services buildings are 12 meters (39 feet) above grade. The analytical

18 laboratory vent height is 9 meters (30 feet) above grade. The model assumed a zero height plume rise for

19 all atmospheric stability categories.

20

21 Although CAP88-PC has allowance for up to six independent stacks, all stacks modeled in any given case

22 are assumed to be co-located. In most assessments this does not present a problem since vents that are

23 physically offset by distances that are small relative to the downwind area being assessed can be safely

24 assumed to be co-located. In this analysis, four of the vents are located in close proximity relative to the

25 assessment distances being modeled. The only exception is the X-710 Laboratory Facility; this facility is

26 treated as if it were co-located with the other vents in the model. In reality this facility is approximately

27 850 meters (2,800 feet) upwind from the critical receptor location relative to the other vents. The

28 modeling ignores this difference in distance, which should result in a small overestimation of the dose at

29 the critical receptor location.

30

31 Wind velocities used in the model were from the onsite meteorological station and represent

32 measurements collected at 30 meters (98 feet) above grade from 1998 to 2002. The prevailing winds at

33 the proposed ACP site blow from the southwest toward the northeast with a secondary frequency in the

34 opposite direction towards the southwest. Although the primary direction is from the southwest, the DOE

35 reservation has its greatest extent towards the northeast, resulting in greater dispersion of emissions in that

36 direction prior to the emissions reaching any receptor locations at or beyond the northeast corner. Also,

37 the proposed ACP would be located in the' southwest corner of the reservation thus maximizing the

38 possible dispersion prior to any emissions from the proposed ACP reaching receptors located in the

39 direction of the prevailing winds.

40

41 For modeling purposes the distances from the proposed ACP stacks to the receptor locations were

42 measured from the center point between the four process buildings to the DOE reservation boundary in

43 each of the 16 compass directions. The model also evaluated the two onsite tenant organizations, the

44 Ohio National Guard at the X-751 Mobile Equipment Maintenance Shop and the Ohio Valley Electric

45 Cooperative office building on the Main Access Road, as the nearest members of the public. Distances

46 were scaled from a blueprint-size site map with the Universal Transverse Mercator grid (100-meter [328-

47 foot] increments) overlaid.

48

49 The model used a rural food consumption pattern to estimate the dose to an assumed critical receptor

50 location at the DOE reservation boundary and the collective population dose for an 80-kilometer (50-

51 mile) radius around the proposed ACP. The rural food consumption pattern assumes a high percentage of

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I foodstuffs are produced at home or at the point of exposure (70 percent vegetables, 40 percent milk, and

2 44 percent meat), with the remainder produced within an 80-kilometer (50-mile) radius. Onsite tenants

3 were also assumed to consume foodstuffs produced within the 80-kilometer (50-mile) radius surrounding

4 the proposed ACP, but not food products raised on the DOE reservation. These food consumption

5 assumptions provide for an assessment that calculates a'dose from ingestion representing the upper end of

6 those doses expected to be reasonably possible, since few people actually 'cbonsume a diet produced

7 exclusively within 80 kilometers (50 miles) of their residence.

8

9 Table 4-20 shows the estimated dose to receptors residing at the site boundary in each of the 16 directions

10 modeled in CAP88, along with the estimated dose to the two onsite tenant organizations. The estimated

11 doses shown' in this table are for the highest typical customer product assay of 5 weight percent of

12 uranium-235. The maximum exposure is to the critical receptor residing on the DOE reservation

13 boundary 1.1 kilometers (0.68 mile) south-southwest of the proposed ACP. The maximum individual 50-

14 year total effective dose equivalent rate at thi's location from air emissions is modeled to be 2.10 x I 0-

15 millisieverts per year (0.21 millirem per year). The Ohio National Guard X-751 Mobile Equipment

16 Maintenance Shop received the maximum individual total effective dose equivalent rate for the onsite

17 tenant organizations at 0.003 millisieverts per year (0.30 millirem per year). These estimated doses are

18 well below the U.S. EPA National Emission Standards for Hazardous Air Pollutant limit of 0.1

19 millisieverts'per year (10 millirem per year) and the NRC total effective dose equivalent limit of 1

20 millisievert per year (100 millirem per year).

21

22 For the 10 weight percent customer assay scenario, which is expected to be much less frequent than the 5

23 weight percent scenario presented above, the maximum fenceline dose is estimated to be 3.3 x I 0-

24 millisieverts per year (0.33 millirem per year) and the dose at the Ohio National Guard location is25 1.1 x 10-2 rmillisieverts per year (1.1 millirem peryear). Although the 10 weight percent scenario was

26 analyzed for the purpose of bounding the possible dose, the results are not considered reasonable for an

27 annual exposure because of the low probability and infrequent occurrence of that product assay. Table 4-

28 20 reports the results for a full year of operation at a product assay of 5 percent by weight of uranium29 235, which represents a reasonable maximum given the expected ACP customers. Nevertheless, even at

30 the 10 percent assay, the predicted doses are well below the U.S. EPA National Emission Standards for

31 Hazardous Air Pollutant limit and the NRC total effective dose equivalent limit noted above.

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Table 4-20 Annual Total Effective Dose Equivalent from Air Releases During Operation Assuming

Enrichment of 5 Weight Percent of Uranium-235,

Location Direction I Distance IDose

nmeters" millisievert/yearb

Site Boundary North 3,350 1.0 x 10- -

SieBoundary North-northwest 2,012 1.2 x IO-' .--.. . . --.. ~...,.. -.. ........ ... ..... c,............ .......... .. ..............

Site Boundary j Northwest j 1,344 1.6 x iO-1 .-. - -----. --------.... -. . - .......-. ....... ......

_~ite ----S Boundary West-northwest j 1,062 1.7 x IO-' .....-....... . -. ..--.. . .-........ . .........-... ..... ....-.. .--. .

Site Boundary West j 950 1.6 x IO-' .. ..........-. . .-...... .... I .....-..... _ite S...... Boundary 3 West-southwest 1,062 1.4 x 1 o'

Site Boundary Southwest 1,308 1.4 x10

Site Boundary South-southwest ! 1,118 2.1 x 10"

Site Boundary South 1,050 1.8 x IO- ......................... Site 'Boundary South-southeast 1,230 1.2 x o ......-. . ..- . -. - ----.------.....- . . .............--....

Site Boundary Southeast 1,344 1.2 x 1O0'

S~ite Boundary East-southeast 1,342 1.3 xiO

Site Boundary East 1,875 1.1 X IO-,

Site Boundary East-northeast 2,404 1.2 xl0

Site-Boundary-Nrthe.st.4,137.... 8.0.. .lO.... .... Site Boundary North-oteast 4,813 7.0 x 10-4 .. .--.- .. -.---.-.---.--------. ..... .~. -....... .....-.-....-.-.. ....

National Guard Eastt 555 3.0 x IO-'.....

Ohi Valy Electric

CoetieNorth-northwest 1,526 1.6 x iO0

Notes:

'To convert meters to feet multiply by 3.28.

'oconvert millisievert to millirem multiply by 100.

CAP88-PC output includes a table of calculated airborne concentrations, in units of microcuries per cubic

meter, for each radionuclide at each location defined by the user in the model's input file. These

concentrations can then be converted from microcuries per cubic meter to micrograms per cubic meter for

the purpose of evaluating the potential chemical toxicity of uranium rather than its radiation hazard. The

uranium concentrations are not expected to be noticeably different in the case of a customer assay of 10

weight percent of uranium-235 rather than 5 weight percent of urnium-235. Changes in assay do not

significantly affect the total uranium release, only the isotopic makeup of the uranium in the release.

Table 4-21 provides the calculated airborne uranium and corresponding HF concentrations at the identical

receptor locations listed in Table 4-20.' The maximum fenceline airborne uranium concentration is

predicted to be 0.005 micrograms per cubic meter along the south property line. The maximum airborne

uranium concentration modeled for an onsite location is 0.006 micrograms per cubic meter at the Ohio

National Guard X-75 1 Mobile Equipment Maintenance Shop. These estimated concentrations are well

below the National Institute for Occupational Safety and Health Time-Weighted Average Recommended

Exposure Level and the American Conference of Industrial Hygienists Threshold Limiting Value for

uranium of 200 micrograms per cubic meter (NIOSH, 1996; NIOSH, 2005).

7Average HF concentrations can be estimated using the stoichiometry of the UF, reaction wvith atmospheric

moisture to form uranyl fluoride (a solid particulate) and HF flumes. Four molecules of HF are generated for each

molecule of UF, released.

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Table 4-21 Predicted Airborne Concentrations of Uranium

and Hydrogen Fluoride at Receptor Locations

LoainDrcin I Distance fTotal Uranium 1Hydrogen Fluoride _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _m ete rs ' j p Im 3 b (P g /rn 3

)

Site Boundary. ! North 3,350 1.73 x 10-3 6.69 x 10'

Sit BonaNorth-northwest 2,012 2.29 x lO0- 8.84 x10

Site Boudry I Northwest 1,344 3.03 x 10O3 1.17 x 1-

Site Boundary West-northwest 1,062 3.45 x lIP 1.33 x 10-3

Site Boundary West 950 3.09 x1IO' 1.19 x10-3

Site Boundary West-southwest 1,062 2.61 x 10-3 1.01 x i0'

Site Boundary Southwest 1,308 1 2.59 x 10-3.0 0

Site Boundary Su-sthet1,118 1 4.09 x 1073 1.58 x 10O3

Site Boudry South 1,050 1 5.21 x 10 ~ 2.01 x 10'

Site Boundary South-southeast 1,230 2.30 x 10 ~ 8.88 x 10'

Site arySou-east1,34-2.1-x----.53- Boun 1I

Site Boundary ESt-outheast 1,342 2.321 x 10-3 8.96 x 10'

Site Boundary Eatsotest 1,875 2.05 x 1O0 7:.94 x iO'

* Site Boundary - East-northeast 2,404 2.12 x IO' 8.20 x10

Site Boundary. Northeast 4,137 1.23 x 10-3 4.75 x IF~ .-.-.- - .. -. ...........

Site Boundary North-northeast 1 4,891 1.13l~. .90 x104'

National Guard East 55 609xI' 2.35 x10 3

*Ohio Valley Electric Cpeave .North-northwest 1 1,526 3.15 x jo1 0-3I.22 x IO'

Notes:

*To convert meters to feet multiply by 3.28.

pig/n= micrograms per cubic meter.

In summary, airborne emissions of uranium from proposed ACP operations are predicted to cause

radiation doses to the public that are well below EPA's National Emission Standards for Hazardous Air

Pollutants, as well as airborne concentrations of uranium that are well below toxicity limits established by

the National Institute for Occupational Safety and Health and the American Conference of Industrial

Hygienists. Therefore, the impacts from such emissions are expected to be SMALL.

Public Dose From'Direct Gamma Radiation

The presence of radioactive materials in quantities above natural background provides the possibility for

members of the public to receive radiation dose' from gamma photons emitted from these materials. At

the proposed ACP, only isotopes of uranium would be present in quantities large enough to provide the

potentia forffiember~s of the public to receive measrable external radiation-dose. Of the uranium onsite,

only that being stored as depleted uranium would be continuously present in sufficient quantity to

-. represent a potential source of direct radiation dose to the public. There would be small amounts of other

gamma emitters present onsite as sealed sources and laboratory standards, but these are not detectable at

any large distance.

Using a model to predict radiation dose to the public from a site like the proposed ACP always yields

uncertain estimates, given the lack of knowledge of the locations of the receptors as a function of time

relative to the location of the source, and the associated shielding and distances involved. The best

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I approach for developing estimates of radiation dose in these situations is to use measured radiation dose

2 at various locations of interest. The site conducts external gamma radiation monitoring using a network

3 of lithium fluoride thermoluminescent dosimeters positioned at various locations both on and off the DOE

4 reservation. There are nine thermoluminescent dosimeters spaced around the perimeter of the limited5 access area of the DOE reservation including cylinder storage yards; eight dosimeters spaced around the

6 DOE reservation boundary; and two dosimeters located off-reservation. Each of these dosimeters are

7 collected and analyzed quarterly. Thermoluminescent dosimeter processing and evaluation is performed

8 by a facility having current accreditation from the National Voluntary Laboratory Accreditation Program

9 of the National Institute of Standards and Technology.

10

11 The thermoluminjescent dosimeters of interest in this assessment are those at the reservation boundary,

12 near the National Guard and Ohio Valley Electric Cooperative locations, the thermoluminescent

13 dosimeter in Piketon, and the thermoluminescent dosimeter on Camp Creek Road near the Pike

14 County/Scioto County line. The gamma radiation levels recorded by these thermoluminescent dosimeters -

15 can be used to determine if the existing depleted uranium storage yards are generating any noticeable

16 increase in gamma radiation levels above ambient background at the potential locations of receptor

17 populations. Table 4-22 shows the measured gamma radiation reading at the thermoluminescent

18 dosimeters of interest for the four quarters in the year 2003.

19

20 Table 4-22 Thermoluminescent Dosimeter Gamma Radiation Readings for the Year 2003 ib

1Z 

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

11

Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total 2003

Dosimeter Location 2003 2003 2003 2003 mR

mR mR mR mR

1404A C Road * 22 * 24 * 25 * 18 * 89 ..............

862 A Road * 26 . 31 31 21 . 109 _._ ................. ___ ................. __................................. __ .... _.._.. . ............

A12 Boundary East . 22 . 25 . 26 18 . 91 -..------ ._-. ,-.-.....-...-...-..-..-..--- . . ... 4-.-.-e. - -.. e - .. ..

A15 BoundarY * 24 16 27 19 86 . ... ~Southeast I-- . .~

*--------------------------e-- -.......-.- ,, ... .*---e---*_--x------------m.........-....

A23 ouaY 23 27 26 20 . 96 Northeast ...... ......._....... . ........ ........ ..... 4...._. .. 4.......*4 - ---- _ _._ . _........-

A24 Boundary North 1 24 27 27 l lost TLD * N/A --.------------------------... 4 .... . ... . . . ....... .. . . . . ...... . ... ..

A28 C Cree 22 25 26 18 91 Road *.* -- . .... ..... --- ..----- ...... _...4.._. ... . ...... ...... ..... . . ... .....

A29 Boundary West 23 27 28 19 97 ... __ ....... .----- ------ ------- ....... .__.. ..... _ _ __._;.. __.;_. -------------- . _ .. _... _ ......._.__. .. . .... _.....

A3 Boundary South 22 25 25 18 90 .... __..__; ....__ ....__ __._.;_ ..........__ _; ._..__;_.__. _.._4 ___...__

A6 Piketon 22 25 26 18 91 ..... ..... 4. ..-------- - -- . . . ; _;_......_.. ---- . . ... - 4,_-.._._-.._..;-._._.__--- _ -. . . _..__._

A8 iBoundary North 28 1 28 1 28 1 21 1 105 ..... * ..... . ........... * ...... , * .... . ... ~... . . .... . . . ........ 4.... .... .. .. . . . . 4 . . . . . . . . . I . . . . . . . . . . .

A9 . Soutdaes 24 27 28 19 98 _ _ _ _ _ _ _ _ _ _ S o u th w e s t I _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Notes:

' TLD = thermoluminescent dosimeter.

b mR = milliRoentgens; I milliRoentgen of exposure produces approximately 8.7 x I0l millisieverts (0.87 millirem) of dose.

Thermoluminescent dosimeters 1404A and 862 are included to provide an estimate of potential exposures

at the National Guard facility and the Ohio Valley Electric Cooperative office, respectively. The

thermoluminescent dosimeters on the boundary provide an indication of the maximum radiation exposure

4-68

4

II
I that an offsite receptor located full time at the boundary could receive over the course of a year. The

2 Camp Creek and Piketon thermoluminescent dosimeters indicate whether any exposure above ambient

3 background is being detected in those locations.'

4

5 The ambient background exposure rate in the region is approximately 90-95 milliRoentgens per year

6 (approximately 0.8 millisieverts or 80 millirem). None of the thermoluminescent dosimeters show

7 significantly elevated exposure rates above this ambient level. The only thermoluminescent dosimeters

8 with readings above the ambient background are thermoluminescent dosimeters 862 and A8, the two'

9 ' thermoluminescent dosimeters in the group nearest the cylinder storage yards. Even in those instances the

10 maximum amount of radiation exposure above the ambient background amounts over the course of a year

11 to less than 15 milliRoentgens (0.13 millisieverts or 13 millirem) for an unshielded receptor spending 100

12 percent of the year standing at that location. An actual resident at that location would receive on the order

13 of 1 milliRoentgen (0.0087 millisieverts or 0.87 millirem) per year additional exposure when the effects

14 of shielding and residence time are included. This dose is not expected to increase should the ACP

15 product change from the expected 5 weight percent of uranium-235 to the less likely 10 weight percent of

16 uranium-235; The number of tails cylinders is expected to be less in a 10 percent'scenario and the

17 ' isotopic content of each tails cylinder will not change unless the tails assay'changes.'-Accordingly, the

18 'estimated dose at 5 percent should be equal to or higher than that for the 10 percent product scenario.

19

20 The thermoluminescent dosimeter readings are inclusive of any exposure caused by the presence of

21 existing radiation sources on the DOE reservation, including direct radiation and skyshine.' Even for'

22 those thermoluminescent dosimeters of interest nearest the existing cylinder storage yards, which are the

23 largest potential sources of direct radiation, there is only a minimal increase in the annual exposure rate.

24 According to the 2003 thermoluminescent dosimeter data, the presence of the existing storage yards has a

25 minimal effect, if any, on the exposure rate at the site boundary. The additional storage yards planned for

26 the proposed ACP are also expected to have a minor effect on the radiation exposure rate at the site

27 boundary. USEC is stationing four additional thermoluminescent dosimeters near the planned X-745H

28 Storage Yard, and one additional thermoluminescent dosimeter near the proposed ACP to the southwest

29 (USEC, 2004c). Should either the X-745H Yard or the proposed ACP produce unexpected increases in

30 the environmental expo'sure rate, that increase will be detected by both the new and existing

31 thermoluminescent dosimeters, giving USEC the information needed to correct a potentially harmful

32 situation. Therefore, the impact from direct exposure is expected to be SMALL.

33

34 Public Dose From Liquid Releases of Radioactive Material

35

36 The dose to the public from water-bome releases of radioactive material from the proposed ACP are

37 expected to be negligible. As discussed in Section 4.2.6.2, USEC does not anticipate any liquid

38 discharges of licensed radioactive materials from the proposed ACP. Any effluents potentially containing

39 radioactive material would have to meet the NRC standards in 10 CFR Part 20 (Standards for Protection

40 Against Radiation) prior to being discharged or would have to be disposed at a licensed facility (USEC,

41 2004c). The most likely pathway for release of uranium from the process facilities would by through the

42 cooling water system, which is an isolated closed loop system. The only routine intentional wastewater

43 discharge from plant operation will be blowdown water from the tower water cooling system, which does

44 not come into contact with the main"cooling system. Fluids from maintenance and cleaning activities are

45 captured in dedicated drains to elirninate uncontrolled releases of potentially contaminated liquids.

46 Accordingly, the impact from water-bome releases of radioactive materials is expected to be SMALL.

4-69
1 Summary of Public Dose

2

3 Based on these estimates, normal operations at the proposed ACP would have SMALL impacts to public

4 health. The most significant impact would be from direct radiation exposure to receptors close to the

5 cylinder storage yards (containing filled and empty Type 48Y cylinders). Members of the public who are

6 nearest to the cylinder storage yards would have annual direct radiation exposures combined with

7 exposure through inhalation. This potential combined exposure would result in annual doses of less than

8 0.05 millisieverts (5 millirem). These results are based on conservative assumptions (see Appendix C),

9 and it is anticipated that actual exposure levels would be less than presented here. The total annual dose

10 from all exposure pathways would be less than the limit of I millisievert per year (100 millirem per year)

11 established in the NRC's regulations in 10 CFR § 20.1301. All exposures are also expected to be

12 significantly below the U.S. EPA limit of 0.25 millisieverts per year (25 millirem per year), as set in 40

13 CFR Part 190 for uranium fuel-cycle facilities.

14

15 These conclusions are valid even in the event that the ACP operates at product enrichments of 10 weight

16 percent uranium-235. The maximum dose from airborne releases of uranium, liquid releases, and direct

17 external exposure from the cylinder storage yards will not be significantly affected by enrichment up to

18 10 percent. Only the airborne exposures are expected to potentially increase, but the maximum dose from

19 air releases is still only about 0.011 millisieverts per year (1.1 millirem per year). No increase in dose

20 from direct external exposure or liquid releases is expected in the event of enrichment to 10 weight

21 percent uranium-235.

22

23 Occupational Exposure Imnacts

24

25 Under the proposed action, the most significant contributor to occupational radiation exposure would be

26 direct radiation from the UF6. The most substantial sources of direct radiation include: the empty Type

27 48Y cylinders with residual material; full Type 48Y cylinders containing either feed material or depleted

28 UF6; Type 30 product cylinders; and various traps that help minimize UF6 losses from the cascade while

29 simultaneously concentrating it. The occupational doses received by personnel involved even with these

30 higher sources is traditionally low; the average dose to cylinder workers at the Portsmouth reservation in

31 2003 was 0.29 millisieverts (29 millirem) (DOE, 2004b).

32

33 The United States Enrichment Corporation has implemented a comprehensive exposure control program

34 at the site to manage occupational radiation exposure and dose. The program maintains exposures "As

35 Low As Reasonably Achievable" through the use of radiation monitoring systems, personnel dosimetry,

36 and mitigation systems to reduce environmental concentrations of uranium. USEC would adapt and

37 apply a similar program specifically for the ACP. The proposed ACP personnel monitoring program

38 would monitor for internal exposure from intake of uranium as well as dose from external exposure to

39 radiation. USEC would also apply an annual administrative limit of 10 millisieverts (1,000 millirem),

40 which is well below the 10 CFR § 20.1201 limit of 50 millisieverts (5,000 millirem).

41

42 The occupational exposure analysis and the historical exposure data from the United States Enrichment

43 Corporation facilities demonstrate that a properly administered radiation protection program at the;

44 proposed ACP would maintain the radiological occupational impacts below the regulatory limits of 10

45 CFR § 20.1201. Therefore, the impacts from occupational exposure at the proposed ACP are expected to

46 be SMALL.

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II
I Impacts from Plausible Accidents

2

3 Operation of the proposed ACP would involve risks to workers, the public, and the environment from

4 potential accidents. The NRC's regulations in 10 CFR Part 70, Subpart H, (Additional Requirements for

5 Certain Licensees Authorized to Possess a Critical Mass of Special Nuclear Material), require that each

6 applicant or licensee evaluate, in an Integrated Safety Analysis, its compliance with certain performance

7 requirements. Appendix H of this Draft EIS summarizes the methods and results used by NRC staff to

8 independently evaluate the consequences of potential accidents identified in USEC's Integrated Safety

9 Analysis. The accidents evaluated by the staff are a representative selection of the types of accidents that

10 are possible at the proposed ACP.

11 -

12 The analytical methods used in this consequence assessment are based on NRC guidance for analysis of

13 nuclear fuel-cycle facility accidents (NRC, 1990; NRC, 1991; NRC, 1998; NRC, 2001). With the

14 exception of the criticality accident, the hazards evaluated involve the release of UF6 vapor from process

15 systems that are designed to confine UF6 during normal operations. As described below, UF6 vapor poses

16 a chemical and radiological risk to workers, the public, and the environment.

17

18 Selection of Representative Accident Scenarios

19

20 The Integrated Safety Analysis Summary and Emergency Plan (USEC, 2004a; USEC, 2004b) describe

21 potential accidents that could occur at the proposed ACP. Accident descriptions are provided by USEC

22 for two groups according to the severity of the accident consequences: high-consequence events and

23 intermediate-consequence events.

24

25 In this Draft EIS, a range of possible accidents was selected for detailed evaluation to bound the potential

26 human health impacts associated with accidents.' The accident sequences selected vary'in severity from

27 high- to low-consequence events, and include accidents initiated by operator error and equipment failure.

28 The accident sequences evaluated by NRC staff were as follows:

29

30 Explosion from wrecked centrifuge(s) following backfill with air;

31 Process building construction fire;

32 Cold trap shell structure failure;

33 * Breach of over-pressurized liquid cylinder, and

34 - Generic inadvertent nuclear criticality.

35

36 Accident Consequences

37

38 Table H-l in Appendix H presents the predicted consequences from the'selected accident scenarios,

39 assuming such accidents occur. The analytical results indicate the accidents at the proposed ACP pose

40 acceptably low risks. The most significant accident consequences are those associated with the release of

41 UF6 caused by a breach of an over-pressurized cylinder. The proposed ACP design reduces the likelihood

42 of this event by having automatic high temperature and high pressure trips. -

43

44 More generally, NRC regulations and USEC's operating procedures for the proposed ACP are designed

45 to ensure that the high and intermediate accident scenarios would be highly unlikely. The NRC staff's

46 Safety Evaluation Report assesses the safety features and operating procedures required to reduce the

47 risks from accidents. The combination of Items Relied on for Safety that mitigate emergency conditions,

48 and the implementation of emergency procedures and protective actions in accordance with the proposed

49 Emergency Plan for the ACP, would limit the impacts of accidents that could otherwise extend beyond

50 the proposed ACP boundaries. The Items Relied on for Safety include such measures as active and

51 passive engineered controls.

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30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

Based on this analysis, accidents at the proposed ACP would result in SMALL to MODERATE impacts

to workers, the environment, and the public.

4.2.12.4 Ceasing Operations at Paducah

Cessation of enrichment plant operations at Paducah would reduce radiological occupational exposures.

Upon shutdown, no additional uranium would be transported to the plant for enrichment, and no

additional depleted uranium would be generated by enrichment operations. Depleted uranium contained

in process equipment would eventually be purged from the equipment. Some radiological occupational

exposure would result from the purging, but such exposure would be short term and controlled to within

regulatory limits. After purging of equipment, however, potential radiological exposure associated with

handling of uranium raw material, operation of enrichment plant equipment, and generation of depleted

uranium would be eliminated. Also, the operations workforce would be reduced to a much smaller

maintenance and security workforce, which would reduce the number of workers potentially exposed to

radiation as well as the level of radiation exposure for each worker. Therefore, radiological occupational

health impacts associated with cessation of Paducah enrichment plant operations would be lower than that

associated with plant operations.

Non-radiological occupational health impacts would also be reduced by cessation of Paducah operations.

There would be a temporary increase in the number of plant workers and an increase in the person-hours

worked as the plant is shut down. Some potential non-radiological occupational health impacts could

result from these increased activities, but any such increase would be temporary. After the plant ceases

operations, the number of workers and the associated annual person-hours worked would be reduced,

thereby reducing potential non-radiological occupational health impacts. The potential for such impacts

would also be reduced because the more potentially hazardous occupational activities associated with

enrichment plant operations would be eliminated. Therefore, non-radiological occupational health

impacts associated with cessation of Paducah enrichment plant operations would be lower than that

associated with plant operations.

Cessation of Paducah enrichment plant operations would also reduce public health impacts. Air

emissions, wastewater effluents, and waste generated by enrichment plant operations would be reduced,

thereby reducing associated radiological and non-radiological public health impacts. Ongoing public

health impacts associated with historical radiological releases from Paducah enrichment plant operations

(e.g., historical deposition of particulate radionuclides to soils and sediments) would not be affected by

cessation of operations.

Based on this analysis, the cessation of operations at the Paducah Gaseous Diffusion Plant would be

expected to cause SMALL impacts to public and occupational health.

4.2.13 Waste Management Impacts

This section describes potential impacts associated with the generation, management, and disposal of

radioactive and non-radioactive wastes generated from the proposed action. It includes an analysis of the

management and disposal of depleted uranium expected to be generated by proposed ACP operations.

However, the management and disposal of decontamination and decommissioning wastes are assessed

separately in Section 4.2.15.

4-72

I I 11
1 4.2.13.1 Site Preparation and Construction

2

3 Site preparation and construction would include refurbishment of existing facilities, including dismantling

4 of the former Gas Centrifuge Enrichment Plant, and construction of the proposed ACP. The types and

5 quantities of wastes anticipated to be generated during site preparation and construction are summarized

6 in Table 2-3 in Chapter 2 of this Draft EIS. These include centrifuge parts and other low-level radioactive

7 waste; rags, wipes, aerosol cans, and other hazardous wastes; paper, construction debris, wood, and other

8 sanitary/industrial waste; and circuit boards, bulbs, lead parts~, and other recyclables. The major portion

9 of the wastes generated from site preparation and construction activities would be from refurbishment of

10 the X-3001, X-3002, and X-3346 Buildings. It is anticipated that only'sanitary/industrial wastes would be

11 generated during proposed ACP construction activities. Management procedures for Wastes generated

12 from refurbishment, site preparation, and construction activities are summarized in Section 2.1.4.1. The

13 potential impacts associated with these management procedures are discussed below.

14

15 Low-Level Radioactive Waste

16

17 The only significant amounts of radioactive waste'generated during site preparation and construction

18 would result from the removal of the 720 centrifuges that were part of the prototype Gas Centrifuge

19 Enrichment Plant built at the'reservation in the'early 1980s. Removing these centrifuges and their

20 associated piping and equipment would produce between 7,787 and 8,495 cubic meters (275,000 and

21 300,000 cubic feet) of low-level radioactive waste.' The centrifuges and the associated systems contain

22 only very small amounts of residual uranium, resulting in a very low activity per cubic foot of material.

23 The low activity should remain contained and produce no measurable dose hazard to the public.

24 Occupational exposures would also be low because the low specific activities would produce only small

25 external dose'rates,-and because airborne activities would be controlled by using air monitoring and

26 ventilation systems during removal operations. Occupational doses would also be controlled and

27 monitored through the site radiation exposure control program.

28

29 No long term storage or disposal of the Gas Centrifuge Enrichment Plant equipment would occur onsite.

30 After removal from the X-3001 and X-3002 Process Buildings, the equipment will be shipped to a

31 licensed low-level radioactive waste disposal facility, such as the EnviroCare facility in Utah, which is

32 subject to regulatory controls to limit radiological releases and exposures. As a result, the impacts

33 associated with the management of this wastestream should be SMALL.

34

35 Low-Level Mixed Waste

36

37 Hazardous wastes generated from site preparation and construction activities would in general be

38 collected and packaged by the waste generator. All such wastes would be considered as potentially

39 radioactive until characterized. Hazardous wastes that are ultimately categorized as low-level mixed

40 waste based on the radionuclide content would be segregated and managed separately from strictly

41 Resource Conservation and Recovery Act hazardous wastes. Waste generation and management

42 procedures would be implemented to minimize the generation of any low-level mixed waste, and in fact

43 none is currently anticipated.' Therefore, the impacts associated with the management of this wastestream

44 should be SMALL.

45

46 Hazardous Waste

47

48 Hazardous wastes generated from'site preparation and construction activities would be accumulated and

49 staged at the XT-847 Facility prior to'shipment off reservation for treatment and disposal. The XT-847

50 Facility is equipped with concrete flo6rs, four-hour rated fire walls, and fire doors, and is divided into

51 three 'staging areas. The XT-847 Facility also includes a Resource Conservation and Recovery Act 90-

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. ' l1

1 day storage facility. Hazardous wastes may be further characterized at this facility and would be

2 packaged and labeled in accordance with Resource Conservation and Recovery Act regulations and U.S.

3 Department of Transportation regulations. The waste containers would be subject to periodic inspection,

4 and any leaking containers would be transferred to other containers or overpacked prior to shipment

5 offsite to a hazardous waste treatment, storage, or disposal facility. Hazardous waste would not be stored

6 at the XT-847 Facility for more than 90 days prior to transfer offsite, and hazardous wastes would be

7 determined to meet the waste acceptance criteria of the receiving offsite treatment, storage, or disposal

8 facility prior to shipment. All such shipments would be made only to USEC-approved treatment, storage

9 and disposal facilities. All hazardous wastes (and other wastes) generated from site preparation and

10 construction activities would be tracked through a Request for Disposal system and assigned a unique

11 identification number. Waste shipments offsite for treatment and disposal would be tracked by this

12 identification number with respect to location, characterization, and other factors.

13

14 As shown in Table 2-3, up to approximately 17 cubic meters (600 cubic feet) of Resource Conservation

15 and Recovery Act hazardous waste per year would be generated during site preparation and construction

16 activities. Onsite waste management capacity at the XT-847 Facility is adequate to manage this amount

17 of waste, and this amount of waste would not exceed the capacity of hazardous waste treatment, storage,

18 and disposal facilities. Waste management procedures are in place for Resource Conservation and

19 RecoveryAct hazardous wastes generated from existing operations, as described above and in Section

20 2.1.4.1 and Section 3.14 of this Draft EIS, and would be applied to hazardous wastes generated from site

21 preparation and construction activities for the proposed ACP. Such procedures would serve to minimize

22 onsite releases and ensure offsite treatment and disposal in accordance with Resource Conservation and

23 Recovery Act regulations and other applicable regulations. Therefore, impacts associated with the

24 management of hazardous wastes from site preparation and construction activities would be SMALL.

25

26 Recyclable Waste

27

28 As shown in Table 2-3, up to approximately 184 cubic meters (6,500 cubic feet) of recyclables would be

29 generated from site preparation and construction activities. Potentially recyclable materials would be

30 considered as such until characterized. Potentially recyclable materials that are categorized as low-level

31 radioactive waste, low-level mixed, or hazardous waste would be segregated and managed separately

32 from recyclables. Reasonable efforts would be taken using USEC waste minimization and pollution

33 prevention policies and established recycling procedures to minimize the amount of waste generated.

34

35 Recyclable wastes generated from site preparation and construction activities would generally be

36 transferred offsite to local recycling firms. Such firms have adequate capacity to manage the anticipated

37 volumes of such materials. Therefore, the impacts of managing recyclables from site preparation and

38 construction activities would be SMALL.

39

40 Classified/Sensitive Waste

41

42 It is not anticipated that any classified waste would be generated from the proposed site preparation and

43 construction activities.

44

45 Sanitarvy/ndustrial Waste

46

47 Sanitary/industrial waste generated from site preparation and construction would be disposed of primarily

48 at the Pike County Landfill. The Rumpke Beach Hollow Landfill is also available for the disposal-of such

49 waste. Both of these landfills are used by local municipalities and are subject to State and local

50 environmental protection regulations. The capacity of the Pike County Landfill is 1,814 metric tons per

51 day (2,000 tons per day) and that of the Rumpke Beach Hollow Landfill is 240 metric tons per day (264

4-74

I I 1l
1 tons per day). At current disposal rates, the Pike County Landfill has sufficient disposal capacity for 34

2 years and the Rumpke Beach Hollow has sufficient disposal capacity for 82 years. As shown in Table 2-

3 3, approximately 1,270 metric tons (1,400 tons) of sanitary/industrial waste would be generated during

4 site preparation and construction, which would not significantly affect the disposal capacity of the local

5 landfills. Therefore, the impact of sanitary/industrial waste generated from site preparation and

6 construction activities would be SMALL.

7

8 4.2.13.2 Facility Operation

9

10 Section 2.1.4.3 of this Draft EIS summarizes the types and quantities of wastes anticipated to be

11 generated from facility operations over the 30-year license period, along with the proposed practices for

12 managing each wastestream. These wastes include depleted uranium; other low-level radioactive waste;

13 low-level mixed waste; hazardous waste; recyclable waste; classified waste; and paper, office waste, and

14 other sanitary/industrial wastes. The potential impacts associated with the generation, storage, treatment,

15 and disposal of each wastestream are assessed in turn below.

16

17 Depleted Uranium

18 - -

19 Up to approximately 42,800 Type 48G cylinders of depleted UF6 would be generated by the 7 million

20 SWU plant operating full time for 30 years (USEC, 2005a). This is the most likely estimate of the

21 amount of tails to be produced assuming USEC enriches product to the expected average of

22 approximately 5 percent by weight of uranium-235. It is also a reasonably conservative estimate, as

23 production of more highly enriched product at the same tails assay results in lower rates of tails

24 generation. If the ACP were to generate product at the maximum licensed assay of 10 weight percent of

25 uranium-235, the tails generation would be about 87 percent of the amount reported above (USEC,

26 2005a).

27

28 These cylinders would contain a total of approximately 571,000 metric tons (629,420 tons) of depleted

29 UF6. Each individual cylinder would contain the following amounts of radioactivity: 1.92 x 1010

30 becquerels (0.52 curies) of uranium-234, 1.48 x IO' becquerels (0.04 curies) of uranium-235, and 9.25 x

31 10'0 becquerels (2.5 curies) of uranium-238.

32

33 USEC currently manages depleted UF6 at the DOE reservation in accordance with 40 CFR Part 266 and

34 Ohio Administrative Code 3745-266, and these same management procedures would be used for the new

35 depleted UF6 cylinders produced by the proposed ACP. Ohio EPA establishes requirements for

36 management, inspection, testing, and maintenance associated with the depleted UF6 storage yards and

37 cylinders owned by USEC at the DOE reservation, as stipulated in Section 9 of the ACP License

38 Application.

39

40 The need for a long-term disposal path for depleted UF6 has become clear; the current practice of storing

41 the depleted UF6 in cylinders on pads at the enrichment facility has been successful as an intermediate

42 practice, but viable uses for large amounts of depleted uranium have not materialized. DOE has

43 recognized that long-term disposal of the depleted uranium will require conversion to a non-reactive form

44 such as U30 and has begun construction of a depleted UF6 conversion facility at Piketon in order to

45 convert the depleted uranium owned by DOE into a more non-reactive form suitable for long-term

46 disposal.

4-75
1.

I Impact on DOE Conversion Facility Operation

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Section 3113(a) of the USEC Privatization Act (Public Law 104-134) requires DOE to accept low-level

waste, including depleted uranium that has been determined to be low-level waste, for disposal upon the

request and reimbursement of costs by USEC. Section 3113 was recently amended (by HR4818,

Omnibus Appropriations bill) to add the following new paragraph to subsection (a):

(4) In the event that a licensee requests the Secretary to accept for disposal depleted

uranium pursuant to this subsection, the Secretary shall be required to take title to and

possession of such depleted uranium at an existing depleted UF6 storage facility.

To date, this provision has not been invoked and the form in which the depleted uranium would be

transferred to DOE has not been specified. However, it is likely that depleted uranium from the proposed

ACP transferred under this provision of law in the future would be in the form of depleted UF6, thus

adding to the inventory of material needing conversion at the Piketon depleted UF6 conversion facility.

DOE is aware of the possibility that the conversion facility being constructed at Piketon may need to

operate longer than initially planned in order to process waste transferred to DOE from the proposed

ACP. DOE acknowledges in its EIS for the conversion facility that "...it is reasonable to assume that the

conversion facilities could be operated longer than specified in the current plans in order to convert this

material." (DOE, 2004a)

The Piketon conversion facility is planned to operate for 18 years beginning in 2006. The existing

inventory planned for conversion is 243,000 metric tons (267,862 tons) of depleted UF6 (DOE, 2004a).

The projected maximum amount of 571,000 metric tons (629,420 tons) of depleted UF6 generated by the

proposed ACP represents a significant increase in this existing inventory. Converting the depleted UF6

from the proposed ACP would require DOE to significantly extend the life of the conversion facility, or

to construct a second conversion facility on the site. DOE has maintained that, with routine facility and

equipment maintenance, periodic equipment replacements, or upgrades, the conversion facility could be

operated safely beyond the 18-year planned life-time period to process the additional depleted UF6 from

the proposed ACP. In addition, DOE indicates the estimated impacts that would occur from prior

conversion facility operations would remain the same when processing the proposed ACP wastes. The

overall cumulative impacts from the operation of the conversion facility would extend proportionately

with the increased life of the facility (DOE, 2004a).

Based on this analysis, the added inventory of depleted UF6 coming from the proposed ACP should not

change the nature or magnitude of the impacts from the DOE conversion facility operations, but it would

extend those impacts for several additional years. As a result, the overall impacts to DOE conversion

facility operations are considered MODERATE.

Transportation Impacts

Once the depleted UP6 cylinders are filled at the proposed ACP and then cooled so that the gaseous

depleted UF6 is solidified, they would be transported onsite to one of two cylinder storage yards located

north of Perimeter Road (the existing X-745G-2 Yard would support the first five years of operation and

the new X-745H Yard would support the remaining 25 years of operation). They would then be

transported back for processing in the onsite DOE conversion facility, located just north of the proposed

ACP in the southwest quadrant of the reservation's central area. This onsite handling and movement of

solidified depleted UP6 cylinders would be in accordance with all applicable NRC requirements and

standard operating procedures, and would be conducted in a manner designed to minimize risks to

workers, the public, and the environment.

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1 1 11
I Consistent with assumptions made in the DOE EIS for the conversion facility at Piketon (DOE, 2004a),

2 the NRC staff assumes that the depleted U308 from the conversion facility would be loaded into empty

3 cylinders or bulk bags, which would be loaded onto railcars for shipment for disposal at either the,;

4 Envirocare facility in Clive, Utah (the proposed DOE disposition site) or the DOE facility at the Nevada

5 Test Site (the optional DOE disposition site). The calcium fluoride generated from the conversion

6 process is also assumed to be packaged and shipped in this same manner. Given the quantities of material

7 generated, the NRC staff estimates that approximately one train with 100 railcars would be needed every

8 three months to ship the U3O and calcium fluoride to an offsite disposal facility.

9

10 The impacts associated with this rail shipment are assessed in Section 4.2.12.1. As shown in Table 4-15,

11 this shipment is estimated to result in 2.8 x 1O- latent cancer fatalities per year of operation from

12 exposure to direct radiation during incident-free transport, and an additional 7.5 x 104 latent cancer

13 fatalities per year from accidents that result in the release of radioactive material to the environment. The

14 total latent cancer fatalities per year is estimated to be approximate 8 x I 0' or less than one cancer fatality

15 over 30 years of operation. Based on this analysis, the impacts associated with the offsite shipment of

16 materials from the conversion facility are expected to be SMALL.

17

18 Disposal Impacts

19

20 DOE has analyzed the human health impacts from long-term disposal of uranium oxides in their

21 Programmatic Environmental Impact Statement on disposal of depleted uranium (DOE, 1999b). Four

22 forms of depleted uranium waste were examined in the study: disposal of U30, in either a grouted or

23 ungrouted form, or disposal of uranium dioxide in either a grouted or ungrouted form. Ungrouted waste

24 is typically in a powder or pellet form, while grouted waste is the material resulting from mixing the

25 uranium oxide material with cement and repackaging in drums. Grouting the waste is intended to

26 increase the waste's structural strength and reduce the leaching rate of the waste to water.

27

28 DOE's analysis determined that the long-term disposal of depleted uranium in the form of U30, at a

29 "generic dry location" is expected to produce zero dose to the maximally exposed individual at a time of

30 1,000 years from disposal. The maximally exposed individual in this case is considered to be an

31 individual living at the boundary of the disposal site who uses a well at the site boundary as a water

32 source. In the DOE analysis, the critical pathway is groundwater transport to the well; however, in the

33 dry site environment, uranium is not able to migrate to groundwater in the 1,000-year time period, and

34 thus there is no calculated dose.

35

36 In a subsequent National Environmental PolicyAct analysis, DOE proposed disposing the depleted

37 uranium at Envirocare (i.e., "generic dry location") (DOE, 2004a). However, the Envirocare sites does

38 not have potable groundwater sources under the disposal facility, so the groundwater pathway is not a

39 concern even when the analysis is extended out to 10,000 years. Thus when applying the DOE analysis

40 scenario to such a site, there would be no dose to the maximally exposed individual even in a 10,000-year

41 analysis.

42

43 NRC staff also reviewed the Waste Acceptance Criteria for the Envirocare site which allows for the

44 disposal of depleted uranium with no volume restrictions. During this review, NRC staff contacted the

45 Division of Radiological Control of the State of Utah to discuss the Envirocare Waste Acceptance Criteria

46 and performance assessment (NRC, 2005b). From this review and discussion it is apparent that the

47 Division of Radiological Control has considered the disposal of depleted uranium at the Envirocare site.

48 Several site-specific factors contribute to the acceptability of depleted uranium disposal at Envirocare,

49 including a lack of potable groundwater, extremely low annual precipitation, and land use controls by

50 Tooele County. As Utah is an NRC Agreement State, and Envirocare has met Utah's licensing

51 requirements, the impacts from disposal of depleted uranium at the Envirocare facility would be SMALL.

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Capacity Impacts

In a Memorandum and Order (CLI-05-05, Docket No. 70-3103-ML) dated January 18, 2005, the

Commission concluded that depleted uranium is properly considered a form of low-level radioactive

waste ("regardless of which form it may take," as stated in the Commission Order). Additionally, as

described in 10 CFR § 61.55(a)(6), depleted uranium is Class A waste.

The quantity of depleted uranium potentially requiring disposition could affect the available disposal

capacity for low-level waste. A June 2004 General Accounting Office report concluded there is sufficient

disposal capacity for current volumes of Class A low-level radioactive waste to last for more than 20

years (GAO, 2004).

Further, access to the existing low-level waste disposal facilities is limited by certain agreements and is

potentially subject to change. The Barnwell, South Carolina disposal facility currently accepts waste

from all U.S. generators except those in Rocky Mountain and Northwest compacts. Beginning in 2008,

however, the Barnwell facility will only accept waste from the Atlantic Compact States, which are limited

to Connecticut, New Jersey, and South Carolina. The Richland, Washington disposal facility currently

accepts waste only from the Northwest and Rocky Mountain Compacts, which together comprise

Washington, Oregon, Idaho, Montana, Utah, Wyoming, Nevada, Colorado, New Mexico, Alaska, and

Hawaii. Therefore, for the converted depleted uranium from the proposed ACP, the only viable existing

disposal options are the Envirocare facility in Clive, Utah or the DOE-operated Nevada Test Site facility.

The remaining estimated capacity for the Envirocare facility is approximately 2.1 million cubic meters

(2.7 million cubic yards). Assuming a waste density 0.39 cubic meter per metric ton (0.46 cubic yard per

ton), the total amount of depleted UF6 estimated to be generated by the proposed ACP equates to

approximately 222,485 cubic meters (291,000 cubic yards), which would take up approximately 11

percent of the remaining Envirocare capacity. Considering this small fraction, along with the fact that

some of the proposed ACP's converted depleted uranium could go to the Nevada Test Site if needed, the

impacts on available disposal capacity are expected to be SMALL.

Low-Level Radioactive Waste

Operation of the proposed ACP would result in generation of relatively small amounts of low-level

radioactive waste in addition to the depleted uranium tails. These wastes include classified waste (failed

centrifuges), heeled cylinders, and assorted other wastestreams. Much of this waste would be typically

transferred to the XT-847 Facility, where the waste may be further sampled/measured to assist in

determining the proper waste characterization and proper disposal/treatment. After containerization,

characterization, labeling/marking, and other processing, the waste would be scheduled for off-reservation

disposal/treatment at a Treatment, Storage, Disposal, Recycling Facility. Such offsite facilities to be used

by the proposed ACP include the Envirocare facility in Utah for low-level radioactive waste and the

Nevada Test Site in Nevada for classified waste. These are licensed facilities for the type of waste

intended to be shipped to them from the proposed ACP. Handling of low-level radioactive wastes will be

by workers monitored as part of the site radiological control program.

Failed Centrifuees

Centrifuges that fail during operation would be maintained onsite to be crushed and disposed during

decommissioning. The rate of centrifuge failures is expected to be very low, so this waste stream is

expected to be small in volume (12-15 cubic meters per year [420-520 cubic feet per year]) (USEC,

2005a). The radiological activity in the failed centrifuge waste is expected to be low, since the

centrifuges hold only a small amount of uranium at any given time.

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I The overall activity and volume of this waste would be small in comparison to the expected volume of

2 decommissioning wastes. Storage of the failed centrifuges should present no significant hazard as the

3 material is low in activity and relatively small in volume. The impact of managing and disposing the

4 failed centrifuges is therefore expected to be SMALL.

5

6 Heeled Cylinders

7

8 Approximately 50 76-centimeter (30-inch) heel cylinders would be shipped to vendors monthly for

9 cleaning and recertification or washing only; these cylinders would contain heel weights of less than 11

10 kilograms (25 pounds) (USEC, 2005a). The cleaning and recertification vendors would be Westinghouse

11 in Columbia, South Carolina and Framatome in Richland, Washington. The 76-centimeter (30-inch) heel

12 cylinders would be shipped in an array of 25 cylinders per shipment. Approximately 50 clean/recertified

13 cylinders would be received in return at the proposed ACP monthly (USEC, 2005a).

14

15 The low numbers and small activities in the heeled cylinders represent no measurable risk to public health

16 and safety. The impact of managing and disposing of the heeled cylinders is therefore expected to be

17 SMALL.

18

19 Other Low-Level Radioactive Waste

20

21 The largest other low-level radioactive waste stream by volume expected to be generated by proposed

22 ACP operations would be dry active waste, at between 170 to 340 cubic meters per year (6,000 to 12,000

23 cubic feet per year). This would include radioactively contaminated metal. Uranium concentrations in

24 this waste would range from the lower limit of detection for the analytical method used up to

25 approximately 200 parts per million total uranium. The maximum technetium-99 activity expected to be

26 seen in this waste is 37,000 becquerels per kilogram (1,000 picocuries per gram).8 Some small volume

27 low-level radioactive waste streams with higher radionuclide concentrations would also be generated

28 from operation of the alumina, magnesium, and sodium fluoride chemical traps. Total uranium in these

29 small volume streams may approach 0.1 gram per gram, with technetium-99 activities up to 1 microcurie

30 per gram.

31

32 Based on the quantities generated, the radiological characteristics of the waste, and the fact that the low33 level radioactive waste would be ultimately treated and disposed in facilities licensed for that purpose, the

34 impact of these wastes is expected to be SMALL.

35

36 Low-Level Mixed Waste

37

38 Examples of low-level mixed waste may include laboratory waste, decontamination solutions, and

39 solvents that also contain radiological contaminants. Radiological contaminants in such wastes are

40 expected to have concentrations similar to that in the dry active waste described above. Operation of the

41 proposed ACP would generate small amounts of low-level mixed waste, about 8 to 11 cubic meters per

42 year (300 to 400 cubic feet per year). USEC would manage low-level mixed waste generated by the

43 proposed ACP, using workers monitored as part of the site radiological control program, in accordance

44 with the requirements of 40 CFR Part 266, Subpart N and Ohio Administrative Code 3745-266. These

45 regulations constrain the storage, handling, and treatment of low-level mixed waste in order to keep them

46 segregated from other wastes and to minimize the potential for releases until their ultimate disposal.

47 Mixed wastes that cannot be treated onsite would be stored until they can be shipped to a commercial

s Technetium-99 is a fission product that has contaminated much of the fuel cycle as a result of past recycling of

reprocessed uranium. It would not be newly generated as a contaminant from ACP operations.

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1 treatment or disposal facility licensed under 10 CFR Part 61. The offsite mixed waste disposal facility

2 proposed for the ACP is the Perma-Fix facility in Florida.

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Based on the quantities generated, the characteristics of the waste, and the fact that low-level mixed waste

would be ultimately treated and disposed in a facility licensed for that purpose, the impact of such waste

management and disposal is expected to be SMALL.

8 Hazardous Waste

9

10 The proposed ACP would be categorized as a large-quantity generator of hazardous waste regulated

11 under the Resource Conservation and Recovery Act. However, the proposed ACP would not be

12 categorized as a greater than 90-day storage facility, and hazardous waste generated from facility

13 operations would have to be transferred offsite to an approved greater than 90-day storage facility within

14 90 days of generation. Procedures and facilities for managing hazardous wastes generated from facility

15 operations activities are described in Section 4.2.12.2, Section 2.1.4.3, and Section 3.14.

16

17 As shown in Table 2-6, up to approximately 3 cubic meters (110 cubic feet) of hazardous waste per year

18 would be generated during facility operations. Onsite waste management capacity at the XT-847 Facility

19 is adequate to manage this amount of waste, and this amount of waste would not exceed the capacity of

20 permitted treatment, storage, and disposal facilities. Management procedures in place for hazardous

21 wastes generated from existing operations, as described in the above-referenced sections, would also be

22 used for newly generated wastes from proposed ACP operations. Such procedures would minimize the

23 potential for onsite releases and ensure offsite treatment and disposal in accordance with applicable

24 Federal and State requirements. Therefore, the impacts associated with the management and disposal of

25 hazardous wastes from facility operation would be SMALL.

26

27 Recyclable Waste

28

29 Up to approximately 57 cubic meters per year (2,000 cubic feet per year) of recyclables would be

30 generated from proposed ACP operations. This could include used oil, circuit boards, fluorescent bulbs,

31 and lead-acid batteries. As described in Section 4.2.13.2, Section 2.1.4.3, and Section 3.14, recyclable

32 wastes would generally be transferred offsite to local recycling firms. Management of the wastes would

33 be unlikely to result in harmful releases to the environment and the offsite recycling firms are expected to

34 have adequate capacity to manage the small additional volumes of material from the proposed ACP.

35 Therefore, the impacts of managing recyclable waste from proposed ACP operations would be SMALL.

36

37 Classified/Sensitive Waste

38

39 Classified waste is waste that is classified because of its configuration, composition, contamination, or

40 contained information. One classified wastestream - failed centrifuges - is discussed in the preceding

41 section on low-level radioactive waste. In addition to those wastes, proposed ACP operations would

42 generate another 8 to 11 cubic meters per year (300 to 400 cubic feet per year) of other "non-regulated"

43 classified waste. Such non-regulated waste would be any discarded material that is excluded under the

44 Ohio Administrative Code and does not exhibit a characteristic of a hazardous waste regulated under the

45 Resource Conservation and RecoveryAct. Such waste may remain on the reservation or transferred off46 reservation to a classified disposal facility. The practices for managing the waste would be in accordance

47 with all applicable Federal and State requirements, would follow standard operating procedures, and

48 would minimize the potential for releases to the environment and for human exposures. Therefore, the

49 impacts associated with these wastes from proposed ACP operations are expected to be SMALL.

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I Sanitarvylndustrial Waste

2

3 Sanitary/industrial waste generated from proposed ACP operations would be disposed primarily at the

4 Pike County Landfill, with the Rumpke Beach Hollow Landfill being available as an alternate. As shown

5 in Table 2-6, approximately 227-272 metric tons per year (250-300 tons per year) of sanitary/industrial

6 waste would be generated from facility operations, which would not significantly change the nature of

7 wastes currently handled or affect the disposal capacity at the local landfills. Therefore the impact of

8 sanitary/industrial waste generated from facility operations would be SMALL.

9

10 4.2.13.3 Ceasing Operations at Paducah

11

12 - Cessation of enrichment plant operations at Paducah would reduce current waste generation and disposal

13 activities. Upon shutdown, no additional uranium would be transported to the plant for enrichment, and

14 no additional depleted uranium would be generated by enrichment operations. A variety of radioactive

15 wastes would ultimately be generated as part of activities to prepare the plant for cold standy status (e.g.,

16 -depleted uranium contained in process equipment would be purged from the equipment), but no such

17 wastes would be generated by the simple act of ceasing operations. Therefore, radioactive waste

18 management impacts associated with cessation of Paducah enrichment plant operations would be lower

19 than that associated with existing plant operations.

20

21 Non-radiological waste management impacts would also be reduced by cessation of Paducah operations.

22 Once the plant is shut down, non-radiological wastes would be reduced to essentially sanitary wastes

23 from workers and routine maintenance activities. Preparing the plant for cold standby status would

24 generate some non-radiological wastes, but those activities are not considered within the scope of this

25 Draft EIS (preparing the plant for cold standby status would be subject of a separate environmental

26 review). Therefore, non-radiological waste management impacts associated with cessation of Paducah

27 enrichment plant operations would be reduced compared to those from current plant operations.

28

29 4.2.14 Impacts from Centrifuge Manufacturing

30

31 As discussed in Section 2.1.4.2, the proposed action would include the manufacturing of centrifuge

32 components and the assembly and testing of centrifuges to be used in the ACP. Most of the proposed

33 machining and fabrication activities, and most of the specific parts to be manufactured, are typical of the

34 precision machine shop and fabrication industry throughout the U.S., are not unique to the proposed

35 action, and are not analyzed in this Draft EIS. However, some parts are unique and would not be

36 manufactured if not for the proposed ACP. The manufacturing and assembly process would be an

37 ongoing activity through the production of approximately 24,000 machines for the 7 million SWU plant

38 (USEC, 2005a). The production rate capability would be developed to ramp up to approximately 16

39 completed centrifuges per day (USEC, 2005a).

40

41 USEC has not yet selected the location(s) for this proposed manufacturing, but is considering either onsite

42 at the DOE reservation in Piketon, three existing manufacturing facilities located off the DOE reservation,

43 or some combination of these locations. If onsite, the centrifuge manufacturing and assembly operation

44 would be conducted in either the X-7725 building or another comparable site building. USEC is

45 considering three alternate locations in different States for the offsite manufacturing. All options under

46 consideration are existing manufacturing facilities and work would be conducted inside existing facilities

47 (USEC, 2005d).

48

49 The following sections evaluate the potential environmental impacts of the proposed centrifuge

50 manufacturing process, focusing on each of the 13 resource areas in the same order as discussed above.

51 Because some of the manufacturing details are propriety and export controlled information, and because

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1.

I USEC has not yet selected the proposed manufacturing location(s), some aspects of the following analysis

2 are more generalized than the analysis of proposed site preparation and construction activities and

3 proposed ACP operations presented in prior sections.

4

5 4.2.14.1 Land Use Impacts

6

7 No new manufacturing facilities would have to be constructed to accommodate the proposed action, since

8 all centrifuge manufacturing would occur inside existing buildings. The level and nature of activities

9 within these buildings would change somewhat, but this would not affect existing land uses either onsite

10 or in surrounding areas. Likewise, the increased truck and commuter traffic needed to move materials

II and workers in and out of the manufacturing site(s) would be accommodated on existing roadways, so no

12 land would have to be taken for new road right-of-way. Because all the potential manufacturing locations

13 are in industrial areas, the increased truck and commuter traffic would not preclude or affect the

14 surrounding land uses. As discussed in more detail below, the proposed centrifuge manufacturing also

15 would not result in substantially new or more hazardous airborne emissions or liquid or solid waste

16 streams that could affect surrounding areas or local waste management capabilities. As a result, the land

17 use impacts of the proposed centrifuge manufacturing activities are expected to be SMALL.

18

19 4.2.14.2 Historic and Cultural Impacts

20

21 If all the centrifuge manufacturing occurs onsite at the DOE reservation in Piketon, there should not be

22 any greater impacts to historic and cultural resources than that described in Section 4.2.2 for the proposed

23 site preparation and construction activities and proposed ACP operations. The manufacturing and

24 assembly would take place in the existing X-7725 building or other comparable building, with no new

25 excavation or soil disturbance. In consultation with the State Historic Preservation Officer, the NRC staff

26 has determined that these manufacturing activities would have no effect on the Portsmouth Gaseous

27 Diffusion Plant historic district (Epstein, 2004). The manufacturing activities also have little potential to

28 indirectly affect the 14 potentially Register-eligible sites within the area of potential effect, since the

29 increased workforce needed to support onsite manufacturing activities would be expected to remain

30 within designated work areas and since the surface materials on these sites were recorded and portable

31 artifacts were collected during prior study.

32

33 The NRC staff also believes that the potential for historic and cultural resource impacts would be low if

34 manufacturing were to occur at one or more of the alternate offsite locations. There would not be any

35 new ground-disturbing activities in areas that have not been previously disturbed, and there would not be

36 any removal or external modification of buildings or structures, at any of these alternate sites. Moreover,

37 all of the planned activities would occur within existing buildings and would be consistent with existing

38 site activities. For all of these reasons, the NRC staff would not expect the proposed offsite

39 manufacturing to result in direct or indirect effects to historic properties, to the extent any such properties

40 exist at these sites.

41

42 Based on this analysis, the impacts to historic and cultural resources of the proposed centrifuge

43 manufacturing activities are expected to be SMALL.

44

45 4.2.14.3 Visual and Scenic Impacts

46

47 The visual and scenic impacts of the proposed centrifuge manufacturing are also expected to be SMALL.

48 Since the manufacturing would occur entirely within existing buildings at existing manufacturing

49 facilities, there will be no new construction or activities that will change existing views. There would be

50 an increase in vehicle traffic around the manufacturing site(s), but it would all occur along existing roads

51 and should not substantially change the present look and feel of the area(s).

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1 4.2.14.4 Air Quality Impacts

2

3 Centrifuge manufacturing would include a filament winding process that requires a combination of resins,

4 curing agents, or hardeners and filaments. Final curing of the resulting parts would occur in curing ovens

5 or hoods. Solvents would be used to clean the produced parts and manufacturing equipment. Airborne

6 emissions from these activities would be confined and captured by the use of hoods or local ventilation

7 capture systems that vent the emissions. All emission sources would be permitted in accordance with

8 Federal and State requirements (USEC, 2005d). Where required (e.g., for volatile organic vapors),

9 emission control equipment would be used as part of the permitted emission vent system (USEC, 2005a).

10 Airflow from the hoods would also be monitored to ensure adequate flow and alarm if a problem is

II detected so that operations can be curtailed (USEC, 2005a).

12

13 To assess potential air quality impacts for this Draft EIS, the NRC staff modeled pollutant emissions from

14 centrifuge manufacturing and their associated air quality impacts. This analysis assumed that all of the

15 proposed manufacturing occurs at the reservation in Piketon, which may be conservative because some of

16 the manufacturing could also occur at one or more of the alternate offsite locations. Assuming all of the

17 manufacturing takes place at Piketon also allowed the NRC to use available site-specific details on

18 meteorology and distances to fencelines and receptors in the modeling.

19

20 The modeling approach focused on solvents and the primary ingredients of proposed curing agents and

21 resins, which would not be released to the air if it were not for the proposed centrifuge manufacturing

22 activities. Because the specific identity of these chemicals is propriety and/or export controlled, those

23 details are withheld from this summary but can be found in Appendix E (this appendix is being withheld

24 pursuant to 10 CFR 2.390). Other emissions would consist of carbon dioxide and water, and these

25 emissions were not assessed because the anticipated emission levels are well below existing levels in the

26 ambient atmosphere. All production emissions were modeled as a point source from the center of the X27 7725 building. Emissions were assumed to be vented to the atmosphere through a 3.3-meter (10-foot)

28 stack above the roofline with a release velocity of 15 meters per second (3,000 feet per minute), in

29 compliance with Occupational Safety and Health Administration Standards.

30

31 As presented in more detail in Appendix E, this analysis predicted property-boundary maximum air

32 -concentrations of air toxics that are several orders of magnitude below applicable Short-Term Exposure

33 - Limits and Permissible Exposure Limits established by the Occupational Safety and Health

34 Administration. For one curing agent ingredient that does not have a Permissible Exposure Limit, the

35 NRC's predicted maximum concentration at the property boundary was below a safe level recommended

36 by the manufacturer.

37

38 The NRC believes that these modeled results for Piketon should reasonably represent the situation if

39 manufacturing took place at one of the proposed offsite facilities. While these other sites are already

40 conducting similar manufacturing activities that may release some of the same pollutants associated with

41 centrifuge manufacturing, the incremental emissions and air quality impacts caused by the proposed

42 centrifuge manufacturing for the ACP are estimated to be very small. The differences in site-specific

43 meteorology and distances to property boundaries at these other sites versus those details at Piketon

44 should not materially affect this conclusion.. -

45 -

46 In addition to the airborne emissions from the manufacturing process, there would be increased emissions

47 from the new vehicle traffic associated with the manufacturing activities. For the purpose of this Draft

48 EIS, the NRC considered the air quality. impacts associated with this additional traffic by conservatively

49 assuming that all of the manufacturing activity took place at one of the candidate offsite locations,

50 resulting in all the centrifuge components being shipped into Piketon by truck for assembly. This

51 assumption maximizes the amount of vehicle traffic coming into Piketon. The manufacturing-related

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I truck traffic was evaluated over a period that overlaps (at least in part) with the proposed site preparation

2 and construction activities and ACP operations at Piketon, in order to consider the maximum cumulative

3 traffic and associated air quality effects. The results of this analysis, presented in Section 4.2.12.1 in the

4 section titled "Airborne Emissions from Routine Transportation," show that the added vehicle traffic is

5 not likely to significantly degrade air quality or cause an exceedance of air quality standards. This

6 manufacturing-related truck traffic was evaluated over a period that overlaps (at least in part) with the

7 proposed site preparation and construction activities and ACP operations at Piketon, in order to consider

8 the maximum cumulative traffic and associated air quality effects. The results of this analysis, presented

9 in Section 4.2.12.1 in the section titled "Airborne Emissions from Routine Transportation," show that the

10 added vehicle traffic is not likely to significantly degrade air quality or cause an exceedance of air quality

11 standards.

12

13 Based on this analysis, the air quality impacts of the proposed centrifuge manufacturing activities are

14 expected to be SMALL.

15

16 4.2.14.5 Geology and Soils Impacts

17

18 The geology and soils impacts associated with the proposed centrifuge manufacturing should be SMALL.

19 There would not be any new excavation required or any other new disturbance of soils or the subsurface.

20 All of the proposed activities would take place within existing buildings at existing manufacturing

21 facilities.

22

23 4.2.14.6 Water Resources

24

25 The manufacturing process associated with the proposed action would require process water and suitable

26 wastewater discharge capacity. All of the potential locations where manufacturing would occur are

27 industrial manufacturing areas with suitable infrastructure (water supply and wastewater treatment

28 capacity). The manufacturing process would not require the development of new water supply sources or

29 the development of additional wastewater treatment capacity.

30

31 In addition, there would be no projected chemical liquid effluents discharged from the manufacturing

32 process. Liquid effluents would be limited to once-through cooling water and a cleaning water that would

33 contain small concentrations of an industrial detergent. According to USEC, neither of these wastewaters

34 would qualify as hazardous waste and would be released to the local sanitary treatment system.

35 Alternatively, the once-through cooling water may be released directly to natural waterways, if permitted

36 under the National Pollutant Discharge Elimination System. (USEC, 2005d)

37

38 Based on this analysis, the impacts to water resources caused by the proposed centrifuge manufacturing

39 activities are expected to be SMALL.

40

41 4.2.14.7 Ecological Impacts

42

43 The proposed centrifuge manufacturing is expected to cause SMALL ecological impacts. Because no

44 new construction would be required and all manufacturing activities would be confined to existing

45 industrial facilities, there would be no new direct impacts to flora and fauna; rare, threatened, and

46 endangered species; or wetlands. The proposed manufacturing operations would result in minor and

47 controlled increases in air emissions, liquid discharges, and solid waste disposal, all of which-would add

48 incrementally to existing levels at the candidate manufacturing sites without significant potential for

49 ecological impacts.

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1 4.2.14.8 Socioeconomic Impacts

2

3 In order to reasonably bound the potential socioeconomic impacts of the proposed action,'the NRC

4 assumed that all manufacturing and assembly activities would occur in the Piketon region of influence,

5 -even though some or all of the activities may actually occur at another site. This phase of the proposed

6 action is estimated to cost $1.4 billion and would be completed between 2004 and 2013 (USEC, 2005a).

7 Its potential impacts to regional employment, tax revenue, population characteristics, housing resources,

8 community and social services, and public utilities are assessed in turn below.

9

10 Impacts to Regional Employment

12 In each year between 2004 and 2013, average annual employment as a result of centrifuge manufacturing

13 and assembly activities is estimated at 2,130 full-time jobs. This estimate includes both direct and

14 indirect employment. Thus, the total number of full-time worker-years of employment generated as a

15 result of centrifuge manufacturing and assembly activities is estimated as the product of 2,130 full-time

16 workers multiplied by a total of ten years, resulting in 21,300 full-time worker years of employment.

17 USEC developed this estimate from the RIMS-II model using appropriate assumptions about the number

18 of direct jobs created, construction-related expenditures, and regional input/output multipliers.

19

20 As a result of manufacturing and assembly activities, an average of 2,130 direct and indirect jobs per year

21 are expected to be created between the years 2004 and 2013 (USEC, 2005a). USEC developed this

22 estimate with the RIMS-II model using appropriate assumptions about the number of direct jobs created,

23 manufacturing-related expenditures, and regional input-output multipliers.

24

25 The total number of persons employed in the four counties of the region of influence in the year 2000 was

26 96,347 (BEA, 2002b). The total number of persons employed in Pike County, where the proposed action

27 would located, was 14,944 in the year 2000 (BEA, 2002b). The employment expected to be generated by

28 the manufacture and assembly activities therefore represents 2.2 percent of the total employment in the

29 region and 14.3 percent of Pike County employment at the year 2000 levels.

30

31 Based on these figures, the impacts to regional employment of the manufacturing phase may be

32 considered MODERATE.

33

34 Impacts to Tax Revenue

35

36 Impacts to regional tax revenues were estimated by USEC using per capita income levels in the region of

37 influence as an estimate of the average salary associated with jobs created by the manufacturing activities.

38 USEC estimates that the region's per capita income in 2004 dollars is $25,317 (USEC, 2005a).

39

40 Ohio State income tax rates for incomes between' $20,000 and $40,000 are structured as a flat 'payment of

41 $445.80 plus 4.5 percent of income over $20,000 (Ohio Department of Taxation, 2003). The State

42 income tax payable by a worker earning $25,317 (the per capita income in the region) at these rates would

43 be $685. The proposed action would create 2,130 jobs each year during the manufacturing phase; this

44 level of employment remunerated at the per capita income in the region of influence translates to State

45 income tax revenues of $ 1.5 million per year' for each'year of the rmanufacturing phase.' Ohio's

46 cuiiiulative individual State income tax revenues for fiscal year 2003 were $8.3 billion (Ohio Department

47 of Taxation, 2003). Income tax revenues resulting from the incomes generated by the centrifuge

48 manufacturing' phase can therefore be expected to account for approximately 0.02 percent of Ohio's

49 cumulative annual individual income tax receipts at fiscal year 2003 levels.

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I Ohio State sales tax revenues are estimated to rise by $2.4 million (2004 dollars) per year for the

2 manufacturing phase of the proposed action, assuming a 6 percent rate of sales tax. The estimate is based

3 on the assumption that 75 percent of earnings after State income taxes are spent in State. Federal income

4 taxes are not considered in computing disposable income; if Federal income taxes were included, it is

5 likely that sales tax revenues would be lower than estimated here. Ohio's cumulative State sales and use

6 tax revenues for calendar year 2003 were $6.7 billion. Sales tax revenues resulting from incomes

7 generated by the centrifuge manufacturing activities can therefore be expected to account for

8 approximately 0.04 percent of Ohio's annual sales tax receipts at calendar year 2003 levels.

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Pike County's annual sales tax revenues, derived from a I percent county sales tax rate, are expected to

rise by approximately $262,000 as a result of the new employment generated by the manufacturing phase

of the proposed action. This estimate is based on the assumption that half the after-tax income arising

from jobs generated by the manufacturing phase is spent on transactions within Pike County. This

amount represents less than 6 percent of Pike County's general fund budget in 2005 (Pike County

Auditor, 2005).

As demonstrated above, it is unlikely that State income tax, State sales tax, and county-level tax revenues

would significantly increase as a result of the centrifuge manufacturing phase of the proposed action.

Overall, the impacts to regional tax revenues of the manufacturing activities may therefore be considered

SMALL.

Tmpacts to Population Characteristics

Of the 2,130 estimated jobs that are expected to be created during the centrifuge manufacturing phase, a

total of 30 direct jobs are expected to be filled by USEC employees transitioned from the Portsmouth

Gaseous Diffusion Plant (these jobs are to conduct the centrifuge manufacturing activities). An estimated

45 indirect jobs are expected to support the 30 positions filled by transitioned USEC workers. Thus, a

total of 75 jobs generated through manufacturing and assembly activities represent jobs that are a

continuation of already existing jobs that would be filled from within the region.

Therefore, 2,055 new jobs (direct and indirect) are expected to be created through manufacturing-related

activities between the years 2004 and 2013. Commonly, an average of 75 percent of construction-related

employment derives from within the region of influence (DOE, 1999). If 25 percent of the 2,055

manufacturing-related jobs are filled from outside the region, a total of 514 workers may be expected to

move into the region. If all workers are assumed to move in as family households, and the average

national family household size is assumed to be 3.13 (U.S. Census Bureau, 2003), the population influx

into the region would be 1,608 persons. This represents 0.76 percent of the region population in the year

2000 (U.S. Census Bureau, 2000).

The impacts to population characteristics of the manufacturing and assembly phase may therefore be

considered SMALL.

Impacts to Area Housing Resources

The average rental vacancy rate in the region is 8.6 percent for rental property and there are

approximately 22,824 rental units in all (USEC, 2005a). This equates to an availability of approximately

1,963 rental housing units, based upon 2000 census data. Of the additional 2,055 jobs created by the

centrifuge manufacturing phase, only 25 percent are expected to be filled by migration from outside the

community. Therefore, the manufacturing phase is likely to increase the demand for rental housing by

only 514 units out of a total of 1,963 rental units. Even accounting for seasonal increases in the demand

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1 for housing created by recreational activities, the influx of workers during centrifuge manufacturing

2 activities is not likely to cause housing shortages or increases in rental rates.

3

4 The impacts to area housing resources of the centrifuge manufacturing and assembly activities may

5 therefore be considered SMALL.

6

7 Impacts to Community and Social Services

8

9 A total of 514 family households' may be expected to migrate to the region as a result of employment

10 opportunities generated in the manufacturing phase of the proposed action, as discussed above. According

11 to the U.S. Census Bureau (2003), the average national family household size is 3.13 with an average of

12 0.95 individuals under the age of 18. Thus, the maximum influx of school-aged children is not expected

13 to exceed 488, which represents 1.3 percent of the regional school population in the year 2000. The

14 'region contains 24 public school districts with a total of 95 schools serving approximately 37,000 students

15 (Ohio Office of Strategic Research, 2003). The region student-to-teacher ratio stood at 15.3 in 2000

16 (Ohio Office of Strategic Research, 2003). This ratio would be 15.5 after the expected influx of school17 age children into the region resulting from manufacturing-phase employment. The average student-to18 teacher ratio in the State of Ohio was only slightly lower at 14.8 in the year 2000. The impacts to

19 education services in the region of influence may therefore be considered SMALL.

20

21 Levels of service of fire, law enforcement, healthcare and administrative services in the region are lower

22 than the State average, but are consistent with those typical in rural counties. The influx of 1,608 persons

23 represents an augmentation of the region population of 0.76 percent and would have a minimal effect on

24 fire, law enforcement, healthcare, and administrative levels of service. The impacts to community and

25 social services may therefore be considered SMALL.

26

27 Impacts to Public Utilities

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29 As described in Section 3.9.3.5, there has historically been very little overlap between utilities providing

30 services to communities in the region of influence and those supporting the Portsmouth Gaseous

31 Diffusion Plant. Dedicated utilities were constructed in the 1950s solely to support the needs of the

32 Portsmouth Gaseous Diffusion Plant. The communities in the region have never had access to these'

33 utilities. Under the 'proposed action, utilities would continue to be procured through existing resources.

34 With the exception of natural gas and landfill services, these dedicated utilities are expected to have more

35 than adequate capacity to continue serving the ACP under the proposed action, including the proposed

36 centrifuge manufacturing. Historically, the Gaseous Diffusion Plant has had no impact on availability or

37 cost of these utilities to communities in the region. It is therefore unlikely that the proposed action would

38 affect the cost or availability of public utility supplies in the region of influence.

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40 With regard to natural gas usage, the proposed action would not require any more natural gas than can be

41 supplied through the existing two-inch diameter supply line. The proposed action is expected to have no

42 impact on the offsite availability or cost of natural gas.

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44 The Pike County landfill would be the primary endpoint for sanitary/industrial waste disposal and the

45 Rumpke Beach Hollow landfill is an alternative. The projected capacities and use'of each are described

46 in Section 3.9.3.5. As apparent from Table 2-3 and Table 3-23, industrial/sanitary wastes from the

47 centrifuge manufacturing and assembly activities would account for a minor fraction of the capacity of

48 these' facilities.

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50 Although the manufacturing phase of the proposed action may result in migration of people into the

51 region, the level of migration is expected to be well below the rental vacancy rate in the area, as discussed

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in the preceding section on housing resources. Therefore, the population influx due to manufacturing

phase jobs is not expected to affect either the pricing or availability of public utilities in the region.

Considering all these factors, the impacts to public utilities of the centrifuge manufacturing phase of the

proposed action are expected to be SMALL.

4.2.14.9 Environmental Justice Impacts

As discussed in the other sections within Section 4.2.14, the proposed centrifuge manufacturing and

assembly activities are'expected to cause SMALL impacts to all of the resource areas considered, except

for the potential impacts to regional employment, which may be as large as MODERATE. These impacts

to regional employment are generally considered positive.

The overall transportation impacts at the Piketon site, due to centrifuge manufacturing combined with the

proposed site preparation and construction activities and the proposed ACP operations, would also be

MODERATE (see Section 4.2.11.1). These impacts, including an increase in traffic congestion and an

increase in injuries due to traffic accidents on U.S. Route 23 and Ohio State Road 32, would equally

affect all populations driving on those.

Based on this analysis, the environmental justice impacts of the proposed centrifuge manufacturing and

assembly activities would be SMALL because the activities would not cause any disproportionately high

and adverse impacts to minority or low-income populations.

4.2.14.10 Noise

Manufacturing of centrifuges would not involve any forging or impact noise. The main manufacturing

activity would involve winding of magnetic coils, which will not produce substantial noise levels.

Although actual noise estimates for the centrifuge manufacturing activities are not available, USEC

asserts that they can be approximated by the noise levels around an automobile assembly plant. These

noise levels are 55 to 60 dBA at about 60 meters (200 feet) from the plant property (USEC, 2005a).

Given these low levels, the attenuation expected to be provided by the building facade and likely distance

to receptors (over 900 meters or 3,000 feet to the nearest residence at Piketon), and the current

background levels of noise at the proposed manufacturing sites, the noise impacts of the proposed

centrifuge manufacturing are expected to be SMALL.

4.2.14.11 Transportation Impacts

The analysis of transportation impacts associated with the proposed site preparation and construction

activities in Section 4.2.11.1 considers the impacts associated with the shipment of centrifuges and other

equipment into the site at Piketon, together with other transportation impacts associated with the proposed

action. That analysis concludes that the cumulative transportation impacts at the site would be

MODERATE. This includes a decrease in the level of service of U.S. Route 23 and Ohio State Road 32,

as well as increase in injuries resulting from the increase in vehicle traffic (see Section 4.2.11.1).

4.2.14.12 Public and Occupational Health Impacts

The principal public health threat associated with the proposed centrifuge manufacturing is associated

with the release of airborne pollutants that may migrate offsite to where people might be exposed.

However, as discussed in Section 4.2.14.4 on air quality, modeling conducted by the NRC staff predicted

property-boundary maximum air concentrations of air toxics that are several orders of magnitude below

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I applicable Short-Term Exposure Limits and Permissible Exposure Limits established by the Occupational

2 Safety and Health Administration. Therefore, the public health impacts are expected to be SMALL.

3

4 The occupational health impacts of the proposed centrifuge manufacturing are also expected to be

5 SMALL. For the most part, the proposed manufacturing materials and process would be similar to those

6 currently used at the candidate sites, so the centrifuge manufacturing would be adding only incrementally

7 to existing worker risks. There is the potential for workspace air to be contaminated with volatile organic

8 material from the curing operations, but these emissions are supposed to be confined and captured by the

9 use of hoods to protect the workers. Similarly, certain component cleaning processes could emit solvent

10 vapors, but these processes would be performed under hoods and/or in clean rooms to control worker

11 exposures (USEC, 2005d). Finally, the filament winding process that is unique to centrifuge

12 manufacturing would present some added risk for worker accidents and injuries, but it would not be much

13 different or greater than that currently associated with the precision machine shop and fabrication

14 industry.

15

16 4.2.14.13 Waste Management Impacts

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18 Some Resource Conservation andRecovery4Act hazardous waste would be generated from the solvents

19 used to clean the produced centrifuge parts and manufacturing equipment. This waste would be in the

20 form of excess spent solvents, rags, wipes, and other material that came into contact with the spent

21 solvent. Excess fibers, reacted resins, and curing agents would be non-hazardous waste. (USEC, 2005d)

22

23 The impacts associated with the management and disposal of these waste streams are expected to be:

24 SMALL. Both the hazardous and non-hazardous wastes would be handled and disposed in accordance

25 with all local, State, and Federal requirements. Releases of potentially harmful contaminants that could

26 pose a significant public health or environmental threat are not expected, and the character and volume of

27 wastes generated are not expected to pose a problem for existing waste management capabilities and

28 capacities.

29

30 4.2.15 Decontamination and Decommissioning

31..-

32 At the end of useful plant life, the proposed ACP would be decontaminated and decommissioned such

33 that the facilities would be returned to DOE in accordance with the requirements of the Lease Agreement

34 with DOE and applicable NRC license termination requirements. The intent of these activities is to return

35 the ACP site to a state that meets NRC requirements for release for unrestricted use. It is anticipated that

36 at the end of the useful life of the plant, most of the buildings and outdoor areas of the plant would

37 already meet NRC requirements for unrestricted use in accordance with 10 CFR § 20.1402. Buildings,

38 outdoor areas, and equipment that do not meet these requirements would be decontaminated and

39 decommissioned in accordance with the Decommissioning Plan for the site.

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Overview ofDecontamination and Decommissioning Activities and Process

Decontamination and decommissioning would involve the removal and disposal of all operating

equipment and waste materials associated with the proposedACP with the exception of the plant

infrastructure and equipment that existed onsite at the time the initiation of the Lease Agreement with

DOE. Enrichment equipment and associated plant equipment would be removed, leaving only the

building shells of the leasedfacilities and the plant infrastructure, including equipment that existed

when the Lease Agreement with DOE was initiated (e.g., rigid mast crane, plant utilities, etc.). Items

removedfrom the ACP would be categorized as potentially reusable equipment or waste. Waste

materials, including wastes remaining onsite when the A CP ceases operations and wastes generated

during the decontamination and decommissioning process, would be removedfrom the site as part of

the decommissioning process. Any remaining depleted UF6 would be converted to a more stable

form in the onsite DOE conversionfacility and the disposed offsite, as described in Section 4.2.12.2.

Facilities leasedfrom DOE would be decontaminated to applicable NRC criteriafor unrestricted'

use. Following decommissioning activities, the leasedfacilities would be returned to DOE in

accordance with the requirements of the Lease Agreement. The Centrifuge Assembly Area within the

X-7725 Facility would be used as the Decontamination Service Area throughout this process and

would handle disassembly and decontamination ofACP equipment. The Decontamination Service

Area would be configured into a disassembly area, buffer stock area, decontamination area, and

scrap storage area.

Because these decontamination and decommissioning activities are anticipated to occur

approximately 30 years in thefuture, only a general description of the activities that would be

conductedfor the proposedACP can be developed at this time for the Draft EIS. In accordance with

10 CFR § 70.38(d) and 10 CFR § 70.38(g)(1), the licensee would be required to prepare and submit

a Decommissioning Plan to the NRC at least twelve months prior to the expiration of the NRC

license, and would begin the decontamination and decommissioning activities upon approval of the

final Decommissioning Plan by the NRC. Under 10 CFR § 70.38(g)(4), the Decommissioning Plan

would include a description of the planned decommissioning activities, including: site

characterization information and site remediation plan; a description of the methods us to ensure

protection of workers and the environment against radiation hazards during decommissioning; a

description of the plannedfinal site radiation survey; an updated detailed cost estimate for the

activities; and a description of the physical security plan and the material control and accounting

plan for the decommissioning. The Decommissioning Plan would be subject to National

Environmental Policy Act review, as applicable, at the time the Plan is submitted to the NRC.

I Decontamination and decommissioning activities anticipated to be conducted for the proposed ACP are

2 described in Section 10 of the USEC License Application. These activities include purging of equipment,

3 dismantling and removal of equipment, decontamination of equipment and structures, salvage and sale of

4 equipment, waste disposal, and final radiological survey. Decontamination and decommissioning

5 activities are anticipated to begin 30 years after the commencement of operations and, for the purpose of

6 this analysis, are estimated to occur over a period of six years from 2040 through 2045.

7

8 This section summarizes potential environmental impacts associated with the decontamination and

9 decommissioning of the proposed ACP, addressing each of the different resource areas in the same order

10 as discussed above. It does not assess potential impacts of decontaminating and decommissioning other

11 parts of the reservation at Piketon or any part of the Paducah facility. Potential impacts of ceasing

12 operations at the Paducah facility are discussed for the different resource areas in prior sections in Section

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1 4.2. Potential impacts associated with the management of depleted uranium generated from proposed

2 ACP operations, including any depleted uranium remaining onsite or contained within plant equipment at

3 the time the proposed ACP ceases operations, are discussed in Section 4.2.13.2 (Waste Management), and

4 are not discussed again here. Potential effects of ACP decontamination and decommissioning activities

5 on the broader decontamination and decommissioning activities for other parts of the Piketon reservation

6 are discussed in Section 4.3, Cumulative Impacts.

7

8 4.2.15.1 Land Use Impacts

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10 Because the proposed ACP site within the Piketon reservation would be leased from DOE, the intent

11 would be to return it to DOE control upon termination of the lease. It is anticipated that after

12 decommissioning activities are completed, existing buildings and structures would remain onsite and the

13 site would remain categorized for industrial use. Therefore, anticipated land use impacts from the

14 decontamination and decommissioning of the proposed ACP would be SMALL.

15

16 At the time the reservation at Piketon as a whole is decommissioned, the categorization and control of the

17 land formerly occupied by the ACP could change and the land use could change accordingly. Potential

18 cumulative land use impacts from decommissioning the Piketon reservation as a whole are discussed in

19 Section 4.3, Cumulative Impacts.

20

21 4.2.15.2 Historical and Cultural Resource Impacts

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23 Decommissioning activities will be conducted in areas known to be devoid of cultural and historical.

24 resources; therefore, no projected impacts as a result of the decontamination and decommissioning are

25 expected (USEC, 2005a). Any changes to or demolition of buildings or structures proposed to be

26 conducted during decommissioning would be evaluated for historic and cultural resources impacis prior

27 to any implementation. Therefore, anticipated impacts to historical and cultural resources from

28 decontamination and decommissioning of the proposed ACP are SMALL.

29

30 4.2.15.3 Visual and Scenic Resource Impacts

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32 Decontamination and decommissioning of the ACP is not anticipated to result in demolition of the

33 buildings and structures leased from DOE. Therefore potential visual and scenic impacts associated with

34 the site would be similar to those described in Section 4.2.3. Any changes to or demolition of buildings

35 or structures that are proposed to be conducting during decommissioning would be evaluated for visual

36 and scenic resource impacts prior to any implementation. Therefore, the anticipated visual impacts from

37 decontamination and decommissioning of the proposed ACP would be SMALL.

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39 4.2.15.4 Air Quality Impacts

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41 Decontamination and decommissioning of the proposed ACP would involve operation of vehicles

42 transporting workers, materials, and wastes, and 'operation of heavy construction equipment (e.g., cranes).

43 Operation of such equipment would produce combustion (gasoline and diesel engine) exhaust emissions,

44 including nitrogen oxides, sulfur oxides, carbo'n monoxide, and particulate matter. Combustion exhaust

45 emissions from vehicle and equipment operations aie anticipated to be lower in both quantity and

46 duration than emissions from vehicle and equipment operations during construction of the proposed ACP.

47

48 Decontamination and decommissioning activities are also anticipated to generate fugitive dust from

49 re-entrainment of dust from paved roads; potential excavation of surface soils, and transportation of

50 wastes and materials. The Portsmouth facility is located in an Ohio county that is exempt from fugitive

51 dust emissions regulations'specified in Ohio Administrative Code 3745-17-08. However, dust

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1 suppression techniques would be used to control fugitive dust emissions from these activities during dry

2 conditions. Overall, fugitive dust emissions during decontamination and decommissioning are anticipated

3 to be lower in both quantity and duration than those associated with construction of the proposed ACP.

4

5 The current state-of-the-art technologies in decontamination and decommissioning of radiologically

6 contaminated equipment require the use of a limited amount of solvents to fully clean some metallic and

7 nonmetallic equipment. The quantity of solvents required has dramatically reduced in recent years and,

l 8 assuming a similar trend, should be minimized when the proposed ACP undergoes decontamination and

9 decommissioning. Nevertheless, there is the potential for emission of solvents during the

10 decontamination phase if solvent cleaning methods are used. These emissions would be of short duration

11 (i.e., a few weeks).

12

13 Based on this analysis, the air quality impacts associated with decontamination and decommissioning are

14 expected to be less than those impacts associated with site preparation and construction and proposed

1 5 ACP operations, as described in Section 4.2.4. Therefore, the impacts would be SMALL.

16

17 4.2.15.5 Geology and Soils Impacts

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19 Impacts to geology and soils associated with the decommissioning of the proposed ACP are not

20 anticipated to exceed the geology and soils impacts associated with construction of the ACP (as discussed

21 in Section 4.2.5). Building shells and plant infrastructure leased from DOE are anticipated to remain

22 onsite after decommissioning is completed, so there should be a minimal amount of new soil disturbance

23 or site excavation. Disturbed areas would be controlled through application of engineering controls and

24 best management practices to minimize erosion and sediment runoff. Any such areas would also be

25 restored upon completion of decommissioning, to the extent practicable. The floors of the proposed ACP

26 process buildings and support facilities consist of troweled-surface and sealed concrete, and any spills that

27 may occur during decommissioning would be subject to implementation of spill cleanup response and

28 area decontamination protocols. Therefore, any radioactive material or hazardous material spills indoors

29 are not anticipated to reach the underlying soils. As any spills that occur during plant operation would be

30 remediated during plant operation, most outdoor areas of the proposed ACP site are anticipated to meet

31 NRC unrestricted release requirements at the time the plant ceases operations. There is potential for

32 additional removal of contaminated surface soils from the site during decontamination and

33 decommissioning; however, any such surface removal is anticipated to be limited in scope and not

34 anticipated to affect the site terrain or the subsurface. For all of these reasons, anticipated impacts to

35 geology and soils from the decommissioning of the proposed ACP would be SMALL.

36

37 4.2.15.6 Water Resource Impacts

38

39 Although potable water use is expected to increase during part of the decommissioning phase due to the

40 increased use of water for equipment decontamination and rinsing, the overall water use during

41 decontamination and decommissioning would be less than or equal to water consumption during

42 operations. As discussed in Section 4.2.6.2, the groundwater withdrawals needed to support proposed

43 ACP operations would be well within permitted levels and would result in a small impact on the

44 availability of groundwater. Therefore, even smaller withdrawals needed to support decontamination and

45 decommissioning activities would also cause a SMALL impact.

46

47 Decontamination operations are anticipated to involve operation of degreasers, wet blast cabinets, citric

48 acid baths, demineralized water baths, scrubbing facilities, and other equipment potentially generating

49 radionuclide-cohtaining wastewater requiring monitoring and discharge. Decontamination and

50 decommissioning operations would also involve releases of sanitary wastewater and storm water runoff.

51 The sanitary water and sewage treatment systems that would be used for the proposed ACP operations are

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1 existing plant infrastructure that would continue to operate throughout decontamination and

2 decommissioning. The plant infrastructure would be used to treat decontamination process wastewater

3 and sanitary wastewater prior to discharge. Sanitary wastewater generated during decontamination and

4 decommissioning would be discharged to the plant sanitary sewer system. It is not anticipated that any

5 licensed materials would enter the sanitary sewer system during this phase. Storm water runoff from the

6 ACP site during decontamination and decommissioning would continue to be managed through

7 application of engineering controls and best management practices, and would continue to drain to the

8 West Central Holding Pond (Permitted Outfall 012) and Southwest Holding Pond (Permitted Outfall

9 013). Automated samplers would continue to collect weekly composite samples from the holding ponds

10 for radiological and National Pollutant Discharge Elimination System-mandated analyses, as described in

11 Section 4.2.6. With all of these continued controls, the impacts associated with liquid discharges should

12 remain SMALL during the decontarnination and decommissioning phase.

13

14 Finally, precautions would also continue to be taken to avoid impacts from accidental releases of fuel,

15 waste, sewage, or chemicals used during decontamination activities. These precautions would include the

16 use of spill response plans, safety procedures, spill control and countermeasure plans, and spill response

17 equipment, as described in Section 4.2.6. With these controls, the likelihood and severity of potential

18 - spills during decontamination and decommissioning would be minimized and any resulting impacts

19 should be SMALL.

20

21 4.2.15.7 Ecological Impacts

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23 Ecological impacts associated with ACP decommissioning are anticipated to be bounded by the

24 ecological impacts associated with ACP site preparation and construction, which are described in Section

25 4.2.7.1. During operation of the proposed ACP, some of the vegetation may reestablish itself in areas that

26 were cleared during construction but not paved. Areas of reestablished vegetation may need to be cleared

27 during site decommissioning (e.g., to conduct surface soil removal for site remediation). Any areas

28 cleared of vegetation during decommissioning'are anticipated to be small and vegetation could reestablish

29 itself in cleared unpaved areas after decommissioning activities are completed. Therefore, anticipated

30 ecological impacts from the decommissioning of the proposed ACP would be SMALL.

31

32 4.2.15.8 Socioeconomic Impacts

33

34 The following sections evaluate potential impacts of the proposed decontamination and decommissioning

35 activities to regional employment, tax revenue, population characteristics, area housing resources,

36 community and social services, and public utilities.

37

38 Impacts to Regional Employment

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40 After the cessation of operations, decontamination and decommissioning activities, will generate an

41 average of 841 direct and indirect jobs per year. This estimate is derived from'the RIMS-II model using

42 appropriate assumptions about the number of direct jobs created, decontamination and decommissioning43 related expenditures, and regional input-output multipliers.

44

45 The total number of persons employed in the four counties of the region of influence in the year 2000 was

46 96,347 (BEA, 2002a). The total number of persons employed in Pike County, where the proposed ACP

47 would be located, in the year 2000 was 14,944 (BEA, 2002a). The employment expected to be generated

48 by the decontamination and decommissioning phase of the proposed action therefore represents 0.9

49 percent of the total employment in the region and 5.6 percent of Pike County employment at the year

50 2000 levels.

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1 Based on these figures, the impacts to regional employment of the decontamination and decommissioning

2 phase may be considered SMALL.

3

4 Impacts to Tax Revenue

5

6 Impacts to regional tax revenues are calculated by using per capita income levels in the region of

7 influence as an estimate of the average salary associated with jobs created by the decontamination and

8 decommissioning phase of the proposed action. USEC estimates that the region's per capita income in

9 2004 dollars is $25,317 (USEC, 2005a).

I 10

11 Ohio State income tax rates for incomes between $20,000 and $40,000 are structured as a flat payment of

12 $445.80 plus 4.5 percent of income over $20,000 (Ohio Department of Taxation, 2003). The State

13 income tax payable by a worker earning $25,317 (the per capita income in the region) at these rates would

14 be $685.07. The proposed action would create 841 jobs each year during the decontamination and

15 decommissioning phase; this level of employment remunerated at the per capita income in the region

16 translates to State income tax revenues of $576,000 per year for each year of the decontamination and

17 decommissioning phase. Ohio's cumulative individual State income tax revenues for fiscal year 2003

18 were $8.3 billion (Ohio Department of Taxation, 2003). Income tax revenues resulting from the incomes

19 generated by decontamination and decommissioning activities can therefore be expected to account for

20 less than one percent of Ohio's cumulative annual individual income tax receipts at fiscal year 2003

21 levels.

22

23 Ohio State sales tax revenues are estimated to rise by $932,000 (2004 dollars) per year for the

24 decontamination and decommissioning phase, assuming a six percent rate of sales tax. This estimate is

25 based on the assumption that 75 percent of earnings after State income taxes are spent in State. Federal

26 income taxes are not considered in computing disposable income; if Federal income taxes were included,

27 it is likely that sales tax revenues would be lower than estimated here. Ohio's cumulative State sales and

28 use tax revenues for calendar year 2003 were $6.7 billion. Sales tax revenues resulting from incomes

29 generated by decontamination and decommissioning activities can therefore be expected to account for

30 less than one percent of Ohio's annual sales tax receipts at calendar year 2003 levels.

31

32 Pike County's annual tax revenues are expected to rise by approximately $103,000 as a result of the new

33 employment generated by decontamination and decommissioning activities, based on a county sales tax

34 - of one percent. This estimate is based on the assumption that half the after-tax income arising from jobs

35 generated by the decontamination and decommissioning phase is spent on transactions within Pike

36 County. This amount represents less than 2.5 percent of Pike County's general fund budget in 2005 (Pike

37 County Auditor, 2005).

38

39 As demonstrated above, it is unlikely that State income tax, State sales tax, and county-level tax revenues

40 would significantly increase as a result of the decontamination and decommissioning phase of the

41 proposed action. The impacts to regional tax revenues are therefore considered SMALL.

42

43 Impacts to Population Characteristics

44

45 Of the 841 estimated jobs that are expected to be created during the decontamination and

46 decommissioning phase (after the cessation of operations), a total of 148 direct jobs are expected to be

47 filled by USEC employees transitioned from their positions at the proposed ACP; these jobs are to

48 support management, design, licensing, planning, demolition, reuse, evaluation, quality assurance,

49 nuclear and radiological safety, and operational readiness. An estimated 286 indirect jobs are expected to

50 support the 148 positions filled by transitioned USEC workers. Thus, a total of 434 jobs generated

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1 through decontamination and decommissioning activities represent jobs that are a continuation of already

2 existing jobs that will be filled from within the region.

3

4 Based on these figures, a total of 407 new jobs (direct and indirect) per year is expected to be created

5 through decontaminiation and decommissioning-related activities. Commonly, an average of 75 percent

6 of construction-related employment derives from within the region of influence (DOE, '1999a). If 25

7 percent of the 407 jobs are filled from outside the region, a total of 102 workers may be expected to move

8 into the region. If all workers are assumed to move in as- family households, and the average national

9 family household size is assumed to be 3.13 (U.S. Census Bureau, 2003), the population influx into the

10 region' would be 318 persons. This represents 0.15 percent of the region Population in the year 2000 (U.S.

11 Census Bureau, 2000). The impacts to population characteristics of the decontamination and

12 decommissioning phase may therefore be considered SMALL.

13

14 Impacts to Area Housing Resources

15

16 The average rental vacancy rate in the region of influence is 8.6 percent for rental property and there are

17 approximately 22,824 rental units in all. 'This equates to an availability of approximately 1,963 rental

18 housing units, based upon 2000 Census data. Of the additional 407 jobs created by the decontamination

19 and decommissioning phase, only 25 percent is' expected to be filled by migration from outside the',.

20 community. Therefore, the decontamination and decommissioning phase is likely to increase the demand

21 for rental housing by only 102 units out of a total of 1,963 rental units. Even accounting for seasonal

22 increases in the demand for housing created by recreational activities, the influx of workers 'during the

23 decontamination and decommissioning phase is not likely to cause housing shortages or increases in

24 rental rates. The impacts to area housing resources are therefore considered SMALL.

25

26 Impacts to Community and Social Services

27

28 Impacts to housing availability and community and social services have been estimated using baseline

29 data from the year 2000. It is possible that these data may not be applicable during the decontamination

30 and decommissioning period (2040 through 2045). However, the number ofjobs created in this phase is

31 small compared to the region of influence population; it is therefore likely that any effects on housing and

32 community and social services would be proportionally SMALL.

33

34 As discussed above, a total of 102 family households may be expected to migrate to the region as a result

35 of employment opportunities generated in the decontamination and decommissioning phase.' According

36 to the U.S. Census Bureau (2003), the average national family household size is 3.13 Lwith an average of

37 0.95 individuals under the age of 18. Thus, the maximum influx of school-aged children is not 'expected

38 to exceed 97, which is 0.26 percent of the regional school population in the year 2000. The region of

39 influence contains 24 public school districts with a total of 95 schools serving approximately 37,000

40 students (ODOD, 2003). The student-to-teacher ratio stood at 15.3 in 2000 (ODOD, 2003). This ratio

41 would not change after the expected influx of school-age children into the'region resulting from

42 decontamination and decommissioning employment. The average student-to-teacher'ratio in'the State of

43 Ohio was only slightly lower at 14.8 in'the year 2000. Based on this analysis, the impacts to education

44 services in the region of influence would be SMALL.

45

46 Levels of service of fire, law enforcement, healthcare, and administrative services in the region of

47 influence are lower than the state average, but are consistent with those typical in rural counties. The

48 influx of 318 persons represents an augmentation of the region population of 0.15 percent and will have a

49 SMALL effect on fire, law enforcement, healthcare, and administrative levels of service.

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I Impacts to Public Utilities

2

3 As described in Section 3.9.3.5, there has historically been very little overlap between utilities providing

4 services to communities in the region of influence and those supporting the Portsmouth Gaseous

5 Diffusion Plant. Dedicated utilities were constructed in the 1950s solely to support the needs of the

6 Portsmouth Gaseous Diffusion Plant. The comnmunities in the region have never had access to these

7 utilities. Under the proposed action, utilities would continue to be procured through existing resources,

8 with the exception of natural gas and landfill services. These dedicated utilities are expected to have ;

9 more than adequate capacity to continue serving the ACP under the proposed action, including during the

10 decontamination and decommissioning phase. Historically, the Gaseous Diffusion Plant has had no

11 impact on availability or cost of these utilities to communities in the region. It is therefore unlikely that

12 the proposed action would affect the cost or availability of public utility supplies in the region.

13

14 With regard to natural gas usage, the proposed action would not require any more natural gas than can be

15 supplied through the existing two-inch diameter supply line. Decontamination and decommissioning are

16 expected to have no impact on offsite availability or cost of natural gas.

17

18 The Pike County landfill would be the primary endpoint for sanitary/industrial waste disposal, with the

19 Rumpke Beach Hollow landfill as an alternative. The projected capacities and use of each are described

20 in Section 3.9.3.5. Given the substantial remaining capacities shown in Table 3-23 in that section,

21 combined with the relatively small amount of sanitary/industrial waste expected to be generated from

22 decontamination and decommissioning activities, a capacity shortfall is not expected.

23

24 Although the decontamination and decommissioning phase may result in migration into the region of

25 influence, the level of migration is expected to be well below the rental vacancy rate in the area, as

26 described above. Therefore, the population influx due to decontamination and decommissioning jobs is

27 not expected to affect either the pricing or availability of public utilities in the region.

28

29 Based on this analysis, the impacts to public utilities of the decontamination and decommissioning phase

30 would be SMALL.

31

32 4.2.15.9 Environmental Justice Impacts

33

34 Based on the potential impacts described above, there are no disproportionate high and adverse impacts to

35 either low-income or minority populations associated with the decontamination and decommissioning of -

36 the proposed ACP. Therefore, the environmental justice impacts would be SMALL.

37

38 4.2.15.10 Noise Impacts

39

40 Noise during decommissioning would be generated from operation of heavy construction equipment and

41 vehicles needed to move equipment, scrap metal, and waste. Noise levels generated during

42 decommissioning are anticipated to be similar to those generated during construction of the proposed

43 ACP. As described in Section 4.2.10, these levels are estimated to be around 73 to 94 decibels at 15

44 meters (50 feet), which would drop off to 58 decibels at the nearest residence or 53 day-night average

45 noise level if decommissioning activities were limited to an eight-hour daytime shift. This noise level is

46 within acceptable guidelines and would cause a SMALL impact.

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1 4.2.15.11 Transportation Impacts

2

3 Transportation impacts associated with decontamination and decommissioning include impacts associated

4 with transportation of the workforce to and from the site, transportation of materials to the site, and

5 transportation of materials and wastes from the site.

6

7 The workforce for decontamination and decommissioning would average 287 employees at the site each

8 year for a period of six years (USEC, 2005a). This can be compared to the average construction

9 workforce of approximately 1,013 workers each year over a period of five years. Therefore, traffic

10 associated with workforce transportation during decommissioning would be lower than workforce

1I transportation impacts during construction. The amount of equipment and materials transported to'the

12 site during decommissioning also would be negligible compared to the quantities of equipment and

13 materials transported to the site during construction. Therefore, traffic associated with materials and

14 equipment transportation to the site would be much lower than that during site preparation and

15 construction (as discussed in Section 4.2.11.1).

16

17 Decontamination and decommissioning would generate substantial quantities of wastes and other

18 materials that would need to be transported offsite, not even counting the converted depleted uranium

19 discussed in Section 4.2.13.2. This would include all 24,000 centrifuges; substantial quantities of piping,

20 pumps, and other equipment; general trash; and citric cake, which consists of uranium and metallic

21 compounds precipitated from citric acid decontamination solutions. Some of this waste may be crushed

22 and subject to further volume reduction prior to disposal. The Environmental Report estimates that

23 approximately 1.8 million cubic feet of radioactive waste would be generated during decontamination and

24 decommissioning operations (USEC, 2005a). This would require almost 5,000 truck shipments for offsite

25 disposal over the five-year decommissioning period, most of which are currently planned to go to the

26 DOE facility at the Nevada Test Site or the Envirocare facility in Clive, Utah (USEC, 2005a). Because

27 this volume of truck traffic is far less than the estimated 17,870 truck trips needed during the five-year

28 proposed ACP construction period, the transportation impacts associated with the decommissioning truck

29 traffic should be far less than that described for site preparation and construction in Section 4.2.11.1.

30

31 Based on this analysis, the amount vehicle traffic (including worker vehicles and trucks carrying materials

32 and wastes) during decontamination and decommissioning would be lower than the amount of traffic

33 during site preparation and construction. Since the transportation impacts associated with site preparation

34 and construction are projected to be small, such impacts associated with decontamination and

35 decommissioning should also be SMALL.

36

37 4.2.15.12 Public and Occupational Health Impacts

38

39 The current decontamination and decommissioning plans call for cleaning the structures and selected

40 facilities to free-release levels and allowing them to remain in place for future use. Allowing the

41 buildings to remain in place would reduce the potential number of workers required for decontamination

42 and decommissioning, which would reduce the number of injured workers. If residual contamination is

43 discovered, it would be decontaminated to free-release levels or removed from the site and disposed in a

44 licensed low-level radioactive waste facility. Occupational exposures during onsite decontamination and

45 decommissioning would be bounded by the potential exposures during operation (10 millisieverts [1,000

46 millirem] or less, as discussed in Section 4.2.12.3) because standard quantities of uranium (i.e., UF6 in

47 Type 48Y cylinders) could be handled, at least during the portion of the decontamination and

48 decommissioning operations that purges the gas centrifuge cascades of UF6. Once this decontamination

49 operation is completed, the quantity of UF6 would be residual amounts and significantly less than handled

50 during operations. Because systems containing residual UF6 would be opened, decontaminated (with the

51 removed radioactive material processed and packaged for disposal), and dismantled, an active

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1 environmental monitoring and dosimetry (external and internal) program would be conducted to maintain

2 "As Low As Reasonably Achievable" doses and doses to individual members of the public as required by

3 10 CFR Part 20.

4

5 One aspect of the potential decontamination and decommissioning impacts that is not bounded by the

6 above analysis of proposed ACP operations impacts is the potential public and occupational health

7 impacts associated with the transport of radioactive materials generated during decontamination and

8 decommissioning. For purposes of this analysis, it is assumed that there will be 5,100 shipments to the

9 Nevada Test Site, 105 shipments to Clive, Utah, and 60 shipments to Kingston, Tennessee. The number

10 of latent cancer fatalities, summarized in Table 4-23, from the transportation of all decontamination and

II decommissioning waste is estimated to be 0.3, including 0.005 deaths resulting from the release of

12 radioactive material as a result of accidents.

13

14 Based on these analyses, the public and occupational health impacts associated with decontamination and

15 decommissioning would be SMALL.

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3

4

5

6

7

8

9

10

I1I

Table 4-23 Estimated Latent Cancer Fatalities from the Transportation of

Decontamination and Decommissioning Waste

Incident Free

Material General Population Occupational Workers Maximally Accidents

Off-LRestStops Stops Crew Individual

Classified' 5.1103 * 4.8x10 2 | 12x101 . 8.9x10- 2 i 3.l1x0:2 2.1xl0- 2 . 3.x1100i 2.0x1O-7 i 4.7x 10'3 ............................... - - . - .4----------..........................I......................-..4...4.....................4 .---------------....-.....----------------------- . .-- ---------------.-- - - -----

Unclassified ; 8.6 x I0' j 7.4 x 104 i 2.2 x I0'3 1.4 x I0 i 1.9 x IO'i 4.7 x 104 I 6.8 x IO"' i 4.1 x 1 0 9 5

Liquid .5x 10-' 11.Ox IO-' 1.2x IO-' I 2.7 x10- l.Ox i0-5 l.1 x 10*4 17x0 l.8xl0"' 1.7x 10- .......... L............................. . .1 ...............---.-----------.................................

Total I 5.2x I0" ; 4.9x 1IO - 1.2x 10.1 9.1 x 10.2 i 3.2x 10.2 j 2.1 x 10- . 3.2x i0 i 2.Ox 10'7 i 4.8x 10i

Notes:

'A waste that is classified because of its configuration, composition, contamination, or contained information.

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1 4.2.15.13 Waste Management Impacts

2

3 The waste management and recycling programs used during operations would apply to decontamination

4 and decommissioning. Materials eligible for recycling would be sampled or surveyed to ensure that

5 contamination levels would be below release limits. Staging and laydown areas would be segregated and

6 managed to prevent contamination of the environment and creation of additional wastes. Therefore, the

7 impacts would be SMALL.

8

9 4.3 Cumulative Impacts

10

11 Cumulative impacts are the impacts (effects) on the environment which result from the incremental

12 impact of the action when added to other past, present, and reasonably foreseeable future actions

13 regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative

14 impacts can result from individually minor but collectively significant actions taking place over a period

15 of time (40 CFR § 1508.7). This section defines the resources that may be subject to cumulative impacts,

16 defines the other past, present, and reasonably foreseeable future Federal and non-Federal actions that are

17 considered pertinent, and presents an analysis of the cumulative impacts. Cumulative impacts encompass

18 the following relative to this section:

19

20 * The action refers to the construction and operation of the proposed ACP on the DOE reservation.

21

22 * The direct and indirect impacts of the proposed action are a key criterion in determining if cumulative

23 effects on localized and regional environmental and natural resources need to be addressed (e.g., if

24 the proposed action has no effects on a given resource, it is not necessary to address the existing

25 cumulative effects that have occurred with respect to that resource).

26

27 * For those cumulative effects that need to be addressed, it is necessary to consider the direct and

28 indirect effects of past, present, and reasonably foreseeable future actions on the affected resources.

29

30 * Direct effects are those effects caused by the proposed action, past actions, present actions, or

31 reasonably foreseeable future actions, that occur at the same time and place as the respective actions

32 (40 CFR § 1508.8(a)); indirect effects are caused by the respective actions and are later in time or

33 farther removed in distance, but are still reasonably foreseeable (indirect effects may include:

34 growth-inducing effects; other effects related to induced changes in the pattern of land use,

35 population density, or growth rate; and related effects on air, water, and other natural systems,

36 including ecosystems) (40 CFR § 1508.8(b)).

37

38 * The respective actions may have been, or would be, the result of decisions made by various

39 governmental levels (Federal, State, or local) or the private sector, further, such actions may be on

40 DOE reservation lands or offsite (the key is that a common resource is affected).

41

42 * Cumulative impacts need to be analyzed relative to a place-based perspective (the situation for

43 activities occurring at the DOE reservation) as well as a national perspective (the situation for

44 proposed centrifuge manufacturing activities) on the specific resources affected.

45

46 * Each affected resource, ecosystem, and human community must be analyzed for its sustainability and

47 capacity to accommodate additional effects, based on its own time and space parameters (CEQ,

48 1997).

49

50 The affected environment, as described in Chapter 3, presents the baseline conditions against which the

51 cumulative impacts will be reviewed. Chapter 3 incorporates the effects of past actions on the various

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1 resources, as well as identifies trends (e.g., development, farming) that influences the various resources.

2 Such effects and trends were considered in evaluating cumulative impacts. Sections 4.2 and 4.4 present

3 the impacts associated with the proposed action aid the no-action alteimative, respectively, on each

4 resource area.

5

6 As presented in Sections 4.2 and 4.4 of this Draft EIS, implementation of the proposed action and no7 action alternative would not result in additional cumulative impacts on cultural resources, visual and

8 scenic resources, and noise. Under the proposed action and the no-action altemative, cultural resources

9 would not be affected; therefore, there would be no additional cumulative impacts. Cumulative effects on

10 visual and scenic resources and noise are not addressed because of the lack of visual intrusions from the

11 facility in relation to its adjoining location on the DOE reservation, and the temporary and localized

12 nature of the noise impacts. The proposed action and/or no-action alternative may affect the remaining

13 resource areas described in Chapter 3 and Sections 4.2 and 4.4. The potential impacts are described in

14 Sections 4.3.1 to 4.3.10.

15

16 To define the activities that would result in a cumulative impact on the various resources, other Federal

17 and non-Federal activities were reviewed on a placed-based perspective. Several activities occurring on

18 the DOE reservation as well as national activities were identified that may result in cumulative impacts on

19 local and national resources. The local activities include: (1) environmental restoration activities (DOE,

20 2004b); (2) industrial reuse of portions of the DOE reservation (DOE, 2001a); and (3) the development of

21 depleted UF6 conversion facilities at the DOE reservations located in Piketon and Paducah (DOE, 2004a;

22 DOE, 2004c). The national activities that may result in cumulative impacts on nationally-based resources

23 include the operation of the proposed National Enrichment Facility in New Mexico (NRC, 2004), and the

24 .'conversion of existing and future depleted UF6 (DOE, 2004a; DOE, 2004c). Such activities would result

25 in cumulatively more radioactive material being transported across the nation, and the generation of more

26 U 3 08 that would require disposal. Table 4-24 presents a description of the other activities considered in

27 this cumulative impact analysis.

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2

Table 4-24 Other Activities Considered for Cumulative Impacts

4

5

6

7

Activities Description

Local (Place-based) Activities

Environmental I DOE and USEC are responsible for implementing environmental compliance activities at

Restoration . the DOE reservation. DOE is responsible for environmental restoration, waste

Activities management, uranium programs, and long-term stewardship of nonleased facilities at the

Portsmouth Gaseous Diffusion Plant. USEC is responsible for cold standby operations,

removal of uranium deposits from process equipment, and winterization of the process

buildings.

Under the Environmental Restoration Program inactive sites are remediated through the

removal, containment, and treatment of contaminants. The DOE reservation has been

divided into quadrants (Quadrants I, II, III, and IV) to facilitate the cleanup process. The

Environmental Restoration Program was established to fulfill the requirements of the Ohio

Consent Decree and U.S. EPA Administrative Consent Order, both issued in 1989.

In addition to monitoring, other remedial actions include:

Actions required in Quadrant I for the X-749/X-120/PK Landfill and the Quadrant I

Groundwater Investigation Area.

Remedial actions in Quadrant II in the X-701B area to address contaminated soil,

installation of landfill caps, and groundwater (DOE, 2004b). Quadrant II also contains

"deferred units" that cannot be remediated while the reservation is operational. Such

areas must meet criteria that are protective of human health and the environment. DOE

performs annual reviews of all deferred units to confirm that the status has not changed.

Remedial activities in Quadrant III including phytoremediation of the groundwater

plume near the X-740 Waste Oil Handling Facility.

INo ongoing remedial actions (other than monitoring) occur in Quadrant IV (DOE, 2004b).

Reindustrialization Under its Reindustrialization Program, DOE would transfer real property (i.e.,

Program underutilized, surplus, or excess DOE reservation land and facilities) by lease and/or

disposal (e.g., sale, donation, transfer to another Federal agency, or exchange) to a

community reuse organization, to other Federal agencies, or to other interested persons and

entities. Such transfers would be subject to DOE and regulator approval. Approximately

526 hectares (1,300 acres) are currently available for transfer (DOE, 2001 a).

No current reindustrialization activities are under development or consideration for the

DOE reservation.

8

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Table 4-24 Other Activities Considered for Cumulative Impacts (continued)

Activities Description

I Development and Beginning in 2004, DOE began the construction of a conversion facility at the DOE

2 Operation of a reservation for conversion of the depleted UF6 cylinders at Portsmouth and the East

3 Depleted UF6 Tennessee Technology Park. DOE estimates that construction will last two years, the

4 Conversion operational period will last 18 years, and that decommissioning and decontamination will

5 Facility last three years. The conversion facility will be located in the west-central portion of the

reservation, and will encompass approximately 10 hectares (25 acres).

Conversion is a continuous process inwhich depleted UF6 is vaporized and converted to a

*.mixture of uranium oxides (primarily U3308) by reaction with steam and hydrogen ina

fluidized-bed conversion unit.- The resulting depleted U308 powder will be collected and

packaged for disposition. Equipment will also be installed to collect the hydrogen fluoride

* co-product and process it into any combination of several marketable products

(hydrofluoric acid or calcium fluoride) for storage, sale, or disposal in the future, if

necessary. The conversion facility will be designed to convert 13,500 metric tons (15,000 . tons) of depleted UF6 per year.

6 National Activities

7 Proposed National The proposed National Enrichment Facility in New Mexico and the handling of its

8 Enrichment associated wastestream of depleted UF6 cylinders, to include transportation to a conversion

9 Facility * facility and the ultimate disposal of the U30. .. _ ......._.__ ;........._......__......._... ...... ...... _. _........._ ....... _. _. _. __.........._

10 Conversion of * The existing depleted UF6 cylinders are located at DOE facilities in Paducah, Kentucky,

11 Existing and Portsmouth, Ohio, and the East Tennessee Technology Park. The potential future

12 Future depleted generation of depleted UF6 cylinders would be from the continued operation of the Paducah

13 UF6 Cylinders Gaseous Diffusion Plant, the potential operation of the proposed National Enrichment

14 Facility, or the potential operation of the proposed USEC ACP. The converted UF6 will be

15 disposed of at the Envirocare licensed disposal facility in Utah or the Nevada Test Site in

16 Nevada. DOE has identified the Envirocare facility as the "primary" disposal facility, and

the Nevada Test Site as the "secondary" disposal facility (DOE, 2004c).

17 Sources: DOE, 2001a; DOE, 2001b; DOE, 2004a; DOE, 2004b; DOE, 2004c; NRC, 2004.

18

19 The following sections present a discussion of the cumulative impacts, by resource. The discussion

20 focuses on the cumulative impacts associated with the proposed action. The cumulative impacts

21 associated with the no-action alternative would be less than the cumulative impacts on each resource

22 under the proposed action, except for the socioeconomic impacts, as there would be fewer jobs created

23 under the no action alternative. Therefore, except for socioeconomic impacts, the cumulative impacts

24 associated with the no-action alternative are not discussed in detail.

25

26 4.3.1 Land Use

27

28 Existing industrial development occupies approximately 40 percent (600 hectares [1,483 acres]) of a total

29 of 1,503 hectares (3,714 acres) of the DOE reservation. Implementation of all current and future actions,

30 as described in Table 4-24, as well as the proposed ACP, would lead to the conversion of an additional 10

31 hectares (25 acres) to industrial use, resulting in a small cumulative impact on land use.

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2

43.2 Climatology, Meteorology, and Air Quality

3 Site Preparation and Construction

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

Site preparation and construction activities associated with the depleted UF6 conversion facility at the

DOE reservation, the proposed ACP, and the ongoing environmental restoration program would result in

a cumulative impact on ambient air quality. Fugitive dust emissions, as well as particulate emissions

associated with construction vehicles and heavy equipment, would increase the concentrations of

particulate matter with a mean diameter of 2.5 micrometers or less. As presented in Section 4.2.6, the

DOE reservation is located in an attainment region, although measured concentrations for certain criteria

pollutants (ozone and particulate matter with a mean diameter of 2.5 micrometers or less) have been

above State and national air quality standards. The reservation is located in a county that is exempt from

the restrictions on emissions for fugitive dust specified in Ohio Administrative Code 3745-17-08.

Elevated ozone concentrations of regional concern are associated with high precursor emissions from the

Ohio Valley region and long-range transport from southern States. Because ozone formation is a regional

issue affected by emissions for an entire area, the small additional cumulative contribution to the county

total would be unlikely to substantially alter the ozone levels of the county (DOE, 2004a).

For fugitive dust emissions, the site preparation and construction phase of the depleted UF6 conversion

facility and the proposed ACP would result in the most particulate emissions, with the majority arising

from vehicle particulate emissions associated with the construction vehicles. Because the construction for

each facility would not overlap (the construction vehicle emissions would not overlap), the cumulative

impacts on air quality are anticipated to be MODERATE. To avoid nuisance conditions and particulate

matter concerns, USEC has proposed to use dust suppression techniques to mitigate dust release during

excavation under dry conditions.

Per the analysis in Section 4.2.4.1, the NRC-recommended mitigation measures to reduce the predicted

impacts associated with particulate matter emissions also would reduce the cumulative impacts to

SMALL. The combined use of use Tier 2 construction-related vehicles and ultra-low sulfur diesel fuel

would reduce particulate matter emissions by about 60 percent.

Transportation

The cumulative impacts of long- and medium-haul trucks, and worker vehicle emissions would include

increases in carbon monoxide and sulfur dioxide emissions in excess 19 percent of current 2004 county

baseline, and emissions of nitrogen oxides and particulate matter with a mean diameter of 10 micrometers

or less in excess of 10 percent of the current 2004 county baseline. These cumulative changes would

likely be sufficiently large to be detected through ambient air quality monitoring. However, they would

occur only temporarily during the construction phase (estimated to be five years), and would be unlikely

to be large enough to exceed National Ambient Air Quality Standards. The potential ambient air quality

impacts associated with increased emissions from construction-related traffic would be SMALL.

Cumulative impacts on ambient air quality during operation of the depleted UF6 conversion facility and

the proposed ACP, as well as the continued environmental restoration program, would not result in

substantial emissions of criteria air pollutants.

The potential cumulative impacts of radiological air emissions from the depleted UF6 conversion facility

and the proposed ACP, which would be regulated by the U.S. EPA under 40 CFR Part 61, Subpart H

(National Emissions Standards for Hazardous Air Pollutants) were also analyzed. Radiological releases

to air from both facilities would be routinely monitored to ensure that releases are at, or below, the

expected and regulated quantities. In addition, under the environmental restoration program, DOE

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I collects data from a monitoring network of 15 ambient air samplers-as described in the DOE site

2 environmental report for 2003 (DOE, 2004b). The monitoring network is intended to assess whether the

3 radiological air emissions from the DOE reservation, as a whole, affect air quality in the surrounding area.

4 Data are collected both onsite and in the area surrounding the DOE reservation. A background ambient

5 air monitoring station is located approximately 21 kilometers (13 miles) southwest of the site. Analytical

6 results from air sampling stations closer to the plant were compared to background measurements (DOE,

7 2004b), and based on the predicted emission rates associated with the depleted UF6 conversion facility

8 and the proposed ACP, and the comprehensive site monitoring program, the cumulative radiological air

9 emissions would result in a SMALL impact on air quality.

10

11 4.3.3 Geology and Soils

12

13 The proposed action and no action alternative would not impact geology; therefore, there would be a

14 SMALL cumulative impact.

15

16 For soils, the primary cumulative impacts resulting from past and present actions has been disturbance in

17 areas where the land use has been converted to industrial activities. Soil losses have occurred via erosion,

18 and some soils on the DOE reservation have become radiologically contaminated. Environmental

19 restoration activities would require some additional land disturbance, primarily in previously disturbed

20 areas. Specifically, the environmental restoration program would require soil removal and capping

21 activities associate with the X-749/X-120/PK Landfill in Quadrant I. Site preparation and construction of

22 the depleted UF6 conversion facility and the proposed ACP primarily would affect previously disturbed

23 soils on the industrialized portions of the reservation. The proposed ACP would impact approximate 6

24 hectares (15 acres) of relatively undisturbed soil, while the depleted UF6 conversion facility will be

25 constructed entirely within the industrial area; therefore, the cumulative impact on soils would result in a

26 SMALL cumulative impact.

27

28 4.3.4 Water Resources

29

30 Floodplains

31

32 Neither the proposed action or the no action alternative would affect any flood plains; therefore, there

33 would be a SMALL cumulative impact.

34

35 Surface Water and Groundwater

36

37 Site preparation and construction of the depleted UF6 conversion facility and the proposed ACP, as well

38 as the continued environmental restoration program, would result in a MODERATE short-term

39 cumulative impact on surface water quality. The cumulative construction time of the depleted UF6

40 conversion facility and the proposed ACP would be approximately 5.5 years, which would result in

41 increased erosion and storm water flows entering adjacent surface water features. The environmental

42 restoration program will require soil removal and capping activities associated with the X-749/X- 120/PK

43 Landfill in Quadrant I, that may result in increased erosion and storm water flows entering adjacent

44 surface water features. However, because the construction areas are greater than 2 hectares (5 acres),

45 DOE and USEC would be required to obtain NPDES permits for storm water discharge from the

46 construction sites, which would require the use of various best management practices to reduce or exclude

47 sediment transport into the surface water features, as presented in Section 4.2.5, Geology and Soil

48 Impacts. The cumulative impacts of the operational phases would be SMALL, as all discharges would

49 meet EPA and State NPDES standards, as well as DOE and NRC standards, which are designed to protect

50 human and environmental health.

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1 Site preparation and construction, and operation of the depleted UF6 conversion facility and the proposed

2 ACP, as well as the continued environmental restoration program, would also result in a small long-term

3 cumulative impact on groundwater. Table 4-25 presents the individual and cumulative withdrawal and

4 discharge rates for the DOE reservation.

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6

7

8

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10

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22

Table 4-25 Water Withdrawal and Discharge Rates '

G dwater - 2 0I8 d 20 d* 000 ' 4 Grounwater 20,8195 500,000' * 814 '215000 * 21 5472 1 835 220472 Withdrawal 757 d 20,000,000 d .1 .6. 3.187 i .27

*.................. ............. ----------------------------- t-------------------------i-..........................t.......................... ..--;;............ ..... I............. ... ...............

909' c 240,000' . ,.2

Wastewater !814 2 215000 | 21 5472 835 220472 j 92

Blowdown 4;603 ',d 1,1,000 'd 7 20 7 | 230 6 50

2 ,2 7 5 d 60_ _ _ _ _ _ _ _ '_ _ _ _ _ _ _ _ _ 77

Groundwater a s 20819: C rc Opedatiop 13

200 0 , d 2461 650000 1 342 1 90411 1 280374 11

Withdesrawalen current wihrwlo ishrerts

................ t. - -----. .......... .............. '.............. ------------ t.............. .. ..................

Wastewater d ' 10 361 1 9540 I: 30 I391 1 103400 1

d Va 6w 01, d ,. .. sn I I I 57

Cooling Water 40,603 2005 a. 1,216,000C 273 '72000 Blowdown .8 230 1 36

Notes:

8m/lday =cubic meters per day; gpd =gallons per day.

bCurrent withdrawals and discharges include those from the ongoing environmental restoration program.

Values represent current withdrawal or discharge rates.

dValues represent capacity and permitted withdrawal or discharge rate.

Sources: DOE, 2004c; USEC, 2005a.

4-107
1 During construction, additional groundwater withdrawal and wastewater discharges of up to 835 cubic

2 meters per day (220,472 gallons per day) would result in SMALL cumulative impacts. The wastewater

3 would feed into the onsite sanitary treatment plant and even though the additional wastewater represents a

4 92 percent change over the current volume, it would only represent a 77 percent change to the total

5 capacity of the facility. This additional wastewater would not affect the status or water quality criteria

6 contained in the existing permit and would represent a SMALL cumulative impact on surface water

7 quality. For groundwater, the additional withdrawal of 835 cubic meters (220,472 gallons) represents a

8 four percent increase over the current withdrawal rate, and would bring the total withdrawal rate to 27

9 percent of system capacity.

10

11 During operation, the additional wastewater discharge (391 cubic meters per day [103,400 gallons per

12 day]), groundwater withdrawal (2,803 cubic meters per day 740,411 gallons per day]), and cooling water

13 blowdown (360 cubic meters per day [95,000 gallons per day]) would result in SMALL cumulative

14 impacts. Wastewater would feed into the onsite sanitary treatment plant and even though the additional

15 wastewater represents a 43 percent change over the current volume, it would only represent 57 percent of

16 the total capacity of the facility. This additional wastewater would not affect the status or water quality

17 criteria contained in the existing permit and would represent a SMALL cumulative impact on surface

18 water quality. The additional groundwater withdrawal would represent a 13 percent increase over the

19 current withdrawal rate, and would bring the total withdrawal rate to 31 percent of the system capacity.

20 The associated tower water cooling system would discharge an additional 360 cubic meters per day

21 (95,000 gallons per day) to the DOE reservation recirculating cooling water system, which discharges to

22 the Scioto River. This represents an 8 percent increase over the current 4,603 cubic meters per day

23 (1,216,000 gallons per day). This discharge would be non-contact cooling water and would not alter the

24 properties or quality of the current discharge. The volume would be the only attribute of the wastewater

25 that would be altered relative to the current recirculating cooling water system discharge. As such, the

26 tower water cooling discharges would have a SMALL cumulative impact on surface water quantity and

27 quality.

28

29 4.3.5 Ecology (Flora, Fauna, Wetlands, and Threatened and Endangered Species)

30

31 For wetlands and threatened and endangered species, the proposed action and the no-action alternative

32 would not require the filling or dredging of any wetlands and would not affect any listed species;

33 therefore, there would be SMALL cumulative impacts on such resources.

34

35 The construction of the depleted UF6 conversion facility and the proposed ACP would result in a SMALL

36 short-term cumulative impact on the flora and fauna within the DOE reservation. Such impacts would

37 result from the increased human activity, dust associated with earth moving, noise from the operation of

38 the construction vehicles, and the removal of vegetation that acts as a buffer between the developed areas

39 and undisturbed forested and riparian areas of the reservation. Habitat disturbance would involve settings

40 commonly found in this part of Ohio, in many cases previously disturbed. The cumulative impact would

41 result in limited removal of undisturbed vegetation, less than 0.5 hectare (I acre).

42

43 The operation of the depleted UF6 conversion facility and the proposed ACP, as well as the continued

44 environmental restoration program would result in a SMALL long-term cumulative impact on flora and

45 fauna. The increased personnel and activities on the reservation associated with such operations and

46 programs would preclude wildlife sensitive to human activities from utilizing the managed areas of the

47 reservation.

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I I 1I1
1 4.3.6 Socioeconomic and Local Community Services

2

3 Site preparation and construction of the depleted UF6 conversion facility and the' proposed ACP would

4 not overlap, and other than the prolonged construction'activities that would occur on the DOE'

5 reservation, the construction jobs created would not result in an additional cumulative impact. The'

6 construction period and the associated increase'in workforce would last from approximately 2005 to

7 2010. This would result in approximately 4,000 direct and indirect jobs's No employment increase or

8 decrease is anticipated to be associated with the ongoing environmental restoration program. Based on

9 'the information presented in Section 4.2.10.2,- such an increase, over 3.5 percent of the total employment

10 in the region of influence and over 22.5 percent of Pike County employment at year 2000 levels, would

11 result in a MODERATE positive cumulative impact. The 4,000 direct and indirect jobs would result in a

12 SMALL cumulative impact on tax revenue, population characteristics, community and social services,

13 and public utilities, as the cumulative effects would not substantially alter the existing tax or population

14 characteristics and would not require any additional services.

15

16 The operation of the depleted UF6 conversion facility and the proposed ACP would result in

17 approximately 2,000 additional direct and indirect jobs. Based on the information presented in Section

18 4.2.10.3, such an increase, over 1.6 percent of the total employment in the region, and over 10 percent of

19 Pike County employment at year 2000 levels, would result in a MODERATE cumulative impact. The

20 4,000 direct and indirect Jobs would result in a SMALL cumulative impact on tax revenue, population

21 characteristics, community and social services, and public utilities, as the cumulative effects would not

22 substantially alter the existing tax or population characteristics and would not require any additional

23 services.

24

25 Under the no-action alternative, the conversion facility would still be built, resulting in short-term

26 (construction) and long-term (operations) SMALL cumulative socioeconomic impacts as presented above.

27 However, because the proposed ACP would not be constructed or operated, the short-term and long-term

28 employment opportunities would be less than those associated with the proposed action.

29

30 4.3.7 Environmental Justice

31

32 Although minority and low-income populations occur in the vicinity of the DOE reservation (see Section

33 4.2.9), construction and operation of the depleted UF6 conversion facility and the proposed ACP, as well

34 as the continued environmental restoration program,' would not affect such populations. Accordingly,

35 there would be no cumulative impacts on environmental justice populations.

36

37 4.3.8 Transportation

38

39 Site preparation and construction and operation of the depleted UF6 conversion facility and the proposed

40 ACP, as well as the continued environmental restoration program, would result in a MODERATE

41 cumulative impact on transportation. -Traffic associated with the ongoing environmental restoration

42 program is part of the existing traffic flow and is not expected to increase or decrease. The construction

43 periods of the depleted UF6 conversion facility and the proposed ACP would not overlap; however, the

44 level of increased construction worker commuter traffic would be extended. During site preparation and

45 construction of the proposed ACP, the level of service for-U.S. Route 23 would temporarily change from

46 B (i.e., free flow of traffic) to C (i.e., the influence of traffic density on operations becomes marked,

47 maneuverability is affected, and travel speeds are reduced).' For State Road 32, site preparation and

48 construction would temporarily change the level of service of the roadway from A to B, which is still

49 uncongested roadway conditions. The Highway Capacity Manual notes that speed remains relatively

50 constant across Levels of Service A through D.

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I Transportation associated with the operation of the depleted UF6 conversion facility is estimated to be

2 12,300 truck shipments and 6,800 rail shipments over 18 years, which equates to approximately three

3 truck shipments and two rail shipments per day (assuming a five-day work week). An estimated

4 workforce of 160 at the conversion facility would result in up to 320 daily vehicle trips. The additional

5 traffic associated with the operation of the depleted UF6 conversion facility would not further degrade the

6 level of service associated with the site preparation and construction activities of the proposed ACP;

7 therefore, the traffic impacts would be SMALL.

8

9 Operation of the depleted UF6 conversion facilities at Portsmouth, Ohio and Paducah, Kentucky, the

10 proposed ACP, as well at the operation of the National Enrichment Facility in New Mexico, would result

11 in some additional transportation of radioactive material. The cumulative impact from routine traffic

12 accidents associated with the additional transportation would be SMALL, as the increase would be a

13 fraction of one percent of the total truck volume in the U.S. Such a small increase in the overall truck

14 volume would result in a negligible change in the number of routine traffic accidents. The cumulative

15 impacts of non-routine traffic accidents associated with the transport of the radioactive material are

16 presented under Section 4.3.9.

17

18 4.3.9 Public and Occupational Health

19

20 This section describes the cumulative impacts to public and occupational health associated with

21 transportation to and from the DOE reservation, site preparation and construction activities on the DOE

22 reservation, and operation of the existing, planned, and proposed facilities on the DOE reservation. The

23 focus of the discussion is on radiological cumulative effects, and when appropriate, cumulative

24 nonradiological effects are described.

25

26 4.3.9.1 Transportation

27

28 As presented in Section 4.3.2, transportation activities associated with the depleted UF6 conversion

29 facility and the proposed ACP, as well as the ongoing environmental restoration program, would result in

30 additional air emissions.

31

32 The highest level of activity and emissions on the DOE reservation would occur during the cumulative

33 construction phase. Emissions of National Ambient Air Quality Standard-regulated pollutants during this

34 period would likely be small, and thus not cause an exceedance of the standard. Because the standards

35 are designed to protect human health, the change in emissions would be unlikely to cause any adverse

36 health impacts within the surrounding population. Therefore, the potential impacts on public and

37 occupational health related to the emission of National Ambient Air Quality Standard-regulated

38 pollutants would be SMALL.

39

40 The cumulative impacts of transporting radioactive material to and from the DOE reservation have been

41 analyzed in other National Environmental Policy Act documents, specifically the:

42

43 * Programmatic Environmental Impact Statementfor the U.S. Department of Energy, Oak Ridge

44 Operations Implementation of a Comprehensive Management Program for the Storage,

45 Transportation, and Disposition ofPotentially Reusable Uranium Materials (DOE, 1999a);

46

47 Transportation Impact Assessmentfor Shipment of Uranium Hexafluoride (UFd Cylindersfrom the

48 East Tennessee Technology Park to the Portsmouth and Paducah Gaseous Diffusion Plants (ANL,

49 2001); and

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1 * Final Environmental Impact Statementfor Construction and Operation of a Depleted Uranium

2 Hexafluoride Conversion Facility at the Portsmouth, Ohio Site (DOE, 2004a).

3

4 These previous studies did not identify any significant impacts to public and occupational health

5 associated with transportation to and from the DOE reservation. The analysis of potential environmental

6 impacts in Chapter 4, along with the results of these studies, indicates that the cumulative impacts on

7 public and occupational health would not substantially vary from the estimated latent cancer fatalities

8 presented in Section 4.2.11.1.

9

10 Ongoing and anticipated operations at the Padacah Gaseous Diffusion Plant involve truck and rail

11 transportation of radioactive materials, including raw materials, products, and wastes. Such shipments

12 would result in radiation dose to members of the public. Existing conditions at the Portsmouth Gaseous

13 Diffusion Plant involve approximately 35 truck shipments per year of low-level waste, resulting in an

14 estimated 7.4 x 104 millisieverts per year (7.4 x 104 millirem per year) dose to the maximum exposed

15 individual (DOE, 2004a). Operation of the'depleted UF6 conversion facility would involve approximately

16 435 truck shipments per year, including shipments of depleted UF6 from the East Tennessee Technology

17 Park to the DOE reservation, resulting in an estimated 2.8 x 1o- mullisieverts per year (2.8 x103 millirem

18 per year) dose to the maximum exposed individual, and an estimated 18 rail shipments per year, resulting

19 in an estimated 1.9 x IO'5 millisieverts per year (1.9 x 10-3 millirem per year) dose to the maximally20 exposed individual (DOE, 2004a). Other ongoing and anticipated actions, including existing depleted

21 UF6 management operations, site remediation activities, and standby and reindustrialization of the

22 Portsmouth Gaseous Diffusion Plant, would involve approximately 220 truck shipments per year and

23 approximately 200 rail shipments per year, resulting in an estimated 8.5 x 10- millisieverts per year (8.5 x

24 1 O' millirem per year) dose to the maximum exposed individual. The total dose to the maximum exposed

25 individual from'transportation tunder existing conditions, ongoing operations, and anticipated actions

26 other than the proposed ACP is 7.7 x 10-5 millisieverts per year (7.7 x l0- millirem per year) for truck

27 transportation and 6.2 x 105 millisieverts per year (6.2 x 1O0 millirem per year) for rail transportation.

28 (DOE, 2004a)

29

30 The dose to the maximum exposed individual from truck and rail transportation for proposed ACP facility

31 operations would be 9.4 x IO01 person-sieved per year (9.4 x 10-9 person-rem per year). Considering the

32 overall dose from transportation conducted under existing conditions, and ongoing and anticipated

33 operations, the cumulative radiological impacts to the public from transportation would be SMALL.

34

35 4.3.9.2 Site Preparation and Construction Activities

36

37 The cumulative' impacts associated with site preparation and construction activities on public and

38 occupational health would result from a longer construction period, up to six years, and the construction

39 schedules for the facilities would not overlap. 'Some of the 'same workers may be involved in the site

40 preparation and construction activities for the prdposed ACP as for the depleted UF6 conversion facility.

41 However, the potential annual radiological exposure to an onsite worker (0.88 millisieverts per year [88

42 millirem per year]) would not exceed the applicable dose limits for the general public of 1 millisievert per

43 year (100 millirem per year) limit listed at 10 CFR §'20.1301(a)(1). During the site preparation and

44 - construction activities, the potential dose to offsite personnel would not increase. The maximum

45 exposure to offsite personnel would be less than 0.001 millisieverts per year (0.1 millirem per year) (see

46 Appendix C).

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1 4.3.9.3 Operations

2

3 The ongoing environmental restoration program at the DOE reservation would not result in development

4 of new sources of radiation emission, therefore, the cumulative analysis focus on the depleted UF6

5 conversion facility and the proposed ACP.

6

7 The estimated dose to involved workers at the depleted UF6 conversion facility is 0.75 millisieverts per

8 year (75 millirem per year), which is less than the applicable dose limits for the general public of 1

9 millisieverts per year (100 millirem per year) limit listed at 10 CFR § 20.1301 (a)(1) and well below the

10 10 CFR § 20.1201 limit of 50 millisieverts (5,000 millirem) for involved workers (i.e., workers in

il radiologically controlled areas) (DOE, 2004b). The estimated dose to involved workers at the proposed

12 ACP facility is up to 0.29 millisieverts per year (29 millirem per year), which is.well below the regulatory

13 thresholds. Because the workers at depleted UF6 conversion facility and the proposed ACP would not be

14 working at both facilities, there would not be a cumulative exposure and even considering the overall

15 collective dose to workers from existing conditions, and ongoing and anticipated operations at the DOE

16 reservation, the cumulative radiological impacts to workers from existing conditions and ongoing and

17 anticipated site operations will be SMALL.

18

19 To assess the cumulative impacts on public health, the potential cumulative impacts of radiological air

20 emissions from the depleted UF6 conversion facility and the proposed ACP were analyzed. Radiological

21 releases to air from both facilities would be routinely monitored to ensure that releases are at or below the

22 expected and regulated quantities. In addition, under the environmental restoration program, DOE

23 collects data from a monitoring network of 15 ambient air samplers (DOE, 2004b). The monitoring

24 network is intended to assess whether the radiological air emissions from the DOE reservation, as a

25 whole, affect air quality in the surrounding area. Data are collected both onsite and in the area

26 surrounding the DOE reservation. A background ambient air monitoring station is located approximately

27 21 kilometers (13 miles) southwest of the site. The analytical results from air sampling stations closer to

28 the plant are compared to background measurements (DOE, 2004b).

29

30 Based on the predicted emission rates associated with the depleted UF6 conversion facility and the

31 proposed ACP, and the comprehensive site monitoring program, the cumulative radiological emissions

32 would result in a SMALL impact on air quality.

33

34 The cumulative effect of operating the depleted UF6 conversion facility and the proposed ACP may result

35 in the doubling of the radiation measured at the fence line of the DOE reservation. Current measurements

36 indicate that the maximum value is approximately 0.001 millisieverts per year (0.1 millirem per year), and

37 the operation of the depleted UF6 conversion facility and the proposed ACP would introduce new sources

38 of radiological emissions. The new emissions may increase to an average of 0.002 millisieverts per year

39 (0.2 millirem per year). The value of 0.002 millisieverts per year (0.2 millirem per year) would be far less

40 than the applicable dose limits for the general public of I millisievert per year (100 millirem per year)

41 limit listed at 10 CFR § 20.1301(a)(1) and would result in a SMALL cumulative impact.

42

43 The probability for cumulative impacts on public and occupational health resulting from accidents was

44 also analyzed. Such accidents could range from likely accidents (occurring an average of one or more

45 times in 100 years) to extremely rare (occurring an average of less than one time in a million years). Such

46 accidents are associated with the depleted UF6 conversion facility and the proposed ACP. Because of the

47 low probability of two accidents happening at the same time, the cumulative consequences of such an

48 event were not analyzed. The probability of two likely accidents occurring at the same time is very low,

49 the product of their individual probabilities being 0.0001. Moreover, in the event that two facility

50 accidents from the likely category occurred at the same time, the consequences for the public would still

51 be SMALL (DOE, 2004a).

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4.3.10 Waste Management

Sanitary and industrial waste generated from all operations and activities at the DOE reservation would be

disposed primarily at the Pike County Landfill, with the Rumpke Beach Hollow Landfill being available

as an alternate. The wastes generated and transferred to the landfills would not substantially change the

nature of wastes currently handled or affect the disposal capacity at the local landfills. Therefore the

impact of sanitary and industrial waste generated from facility operations would be SMALL.

Hazardous wastes would be generated by the depleted UF6 conversion facility, the Paducah Gaseous

Diffusion Plant, the ongoing environmental restoration activities, and the proposed ACP facility. -USEC

would manage its wastes with the intent to store onsite only as a last resort. DOE is decreasing its

permitted waste storage management areas in order to provide increased space available for USEC's

advanced technology centrifuge program. United States Enrichment Corporation would continue to

utilize DOE storage facilities for hazardous and mixed wastes that it must keep onsite for more than 90

days, but would continue to store its low-level waste independent of DOE, and ship as much of its waste

as possible offsite for recycling, treatment, and disposal.

'Potential cumulative effects from management of hazardous materials would be SMALL. The operation

of the depleted UF6 conversion facility and the proposed ACP, follow the same regulatory requirements,

perform required inspections, and manage hazardous materials in a manner that is protective of the

environment.

Section 3113(a) of the USEC Privatization Act (Public Law 104-134) requires DOE to accept low-level

waste, including depleted uranium that has been determined to be low-level waste, for disposal upon the

request and reimbursement of costs. DOE has stated that depleted uranium transferred under this

provision of law in the future, would most likely be in the form of depleted UF6, thus adding to the

inventory of material needing conversion at a depleted UF6 conversion facility. DOE stated that, "...it is

reasonable to assume that the conversion facilities could be operated longer than specified in the current

plans in order to convert this material" (DOE, 2004a).

To review the cumulative impacts on national waste disposal to include the conversion of depleted UF6

and the ultimate disposal of U30, produced from the depleted UF6 conversion facilities at Portsmouth,

Ohio, and Paducah, Kentucky, this Draft EIS analyzed the existing inventories of depleted UF6 as

presented in the Portsmouth Annual Environmental Reportfor 2003 (DOE, 2004b) and Final

Environmental Impact Statementfor Construction and Operation of a Depleted Uranium Hexafluoride

Conversion Facility at the Paducah, Kentucky Site (DOE, 2004c), and the production of depleted UF6

from the proposed ACP and the proposed National Enrichment Facility in Lea County, New Mexico. For

the purposes of this analysis, NRC assumed that ceasing operations at Paducah, resulting in no more

depleted UF6 generation at that site, and the start up of the proposed ACP and the resulting generation of

depleted UF6 would result in a "no-net increase" of depleted UF6.

The existing DOE inventory of depleted UF6 includes cylinders stored at the Paducah Site, the

Portsmouth Site, and the East Tennessee Technology Park. Approximately 440,000 metric tons (485,017

tons) of depleted UF6 are stored at the Paducah Site, 250,000 metric tons (275,578 tons) of depleted UF6

are stored at the Portsmouth Site, and approximately 75,000 metric tons (82,673 tons) at the East

Tennessee Technology Park (DOE, 2004b; DOE, 2004c). The proposed National Enrichment Facility

would generate approximately 197,000 metric tons (217,155 tons) of depleted UF6 (NRC, 2005). The

proposed ACP would generate approximately 571,000 metric tons (629,420 tons) of depleted UF6 (USEC,

2004c).

4-113
I The design capacity of the Portsmouth conversion facility is 13,500 metric tons per year (14,881 tons per

2 year) of depleted UF6, and would require 18 years of operation to convert the amount of depleted UF6 in

3 the Portsmouth and East Tennessee Technology Park inventories (DOE, 2004a). The design capacity of

4 the Paducah conversion facility is 18,000 metric tons per year (19,841 tons per year) of depleted UF6, and

5 would require 25 years of operation to convert the amount of depleted UF6 in the Paducah inventory

6 (DOE, 2004c).

7

8 The Paducah conversion facility would generate approximately 6,000 cubic meters or approximately

9 14,300 metric tons, (7,850 cubic yards or 15,763 tons) per year of depleted triuranium octaoxide over the

I10 25-year license period from converting the depleted UF6 that is stored at the Paducah Site (DOE, 2004c).

11 The Portsmouth conversion facility would generate approximately 3,570 cubic meters or approximately

12 10,800 metric tons (4,700 cubic yards or 11,905 tons) per year of depleted triuranium octaoxide over the

13 18-year license period from converting the depleted UF6 that is stored at the Portsmouth and East

14 Tennessee Technology Park sites (DOE, 2004a). This amounts to a total of 214,725 cubic meters

15 (280,850 cubic yards) of depleted triuranium octaoxide for disposal, representing approximately 10.3

16 percent of the available disposal capacity of the Envirocare facility.

17

18 The additional depleted UF6 generated by the proposed ACP and National Enrichment Facility would

19 generate an additional 768,000 metric tons (846,575 tons), which at the current processing rates would

20 require both conversion facilities to operate for an additional 24 years.

21

22 All of the depleted triuranium octaoxide produced from the depleted UF6 conversion facilities and all the

23 depleted U30s produced from the depleted UF6 that is stored at the Portsmouth and Paducah Sites could

24 be disposed of at the Envirocare facility in Utah. The available disposal capacity of the Envirocare

25 facility as of December 2002 was 2.07 million cubic meters (2.71 million cubic yards).

26

27 Overall the depleted triuranium octaoxide, that would be generated from converting the depleted UF6

28 produced by the proposed ACP, the depleted UF6 produced by the National Enrichment Facility, and the

29 depleted UF6 stored at the Portsmouth and Paducah sites would represent approximately 20 percent of the

30 available disposal capacity of the Envirocare facility.

31

32 The depleted U3O from the conversion facilities would be generated over a period of several decades of

33 operation, and over this period of time other licensees would also be generating low-level waste that

34 would also be required to be disposed of at licensed facilities. Ultimately the entire existing 2.1 million

35 cubic meters (2.7 million cubic yards) disposal capacity of the Envirocare facility would be utilized. The

36 depleted U30g generated by the conversion facilities would contribute approximately 20 percent of the

37 total capacity utilization. In order to address this circumstance, private entities could develop additional

38 low-level waste disposal capacity during that time frame, or DOE could decide to dispose of the depleted

39 triuranium octaoxide at the Nevada Test Site facility rather than at Envirocare. In either case, it is

40 anticipated that the cumulative effect of the generation and disposal of depleted U30 on licensed low41 level waste disposal capacity would be SMALL.

42

43 4A Impacts of the No-Action Alternative

44

45 As discussed in Section 2.2 of this Draft EIS, the no-action alternative would consist of USEC not

46 constructing, operating, or decommissioning the proposed ACP at Piketon. The buildings and land

47 proposed to be used for the ACP at the DOE reservation in Piketon would therefore be available for some

48 other use. At the same time, the uranium fuel fabrication facilities in the United States would continue to

49 obtain low-enriched uranium from currently available sources, including the Paducah Gaseous Diffusion

50 Plant, and the downblending of highly enriched uranium under the "Megatons to Megawatts" program.

51 In order to meet growing demands for enriched uranium, additional domestic enrichment facilities

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Il
.

I utilizing a more efficient technology in the future could be constructed. This could include the gas

2 centrifuge facility proposed by LUiiisiana Energy Services near Eun'ce, New Mexico, as well as other

3 possible facilities. The associated impacts associated with the existing uranium fuel cycle activities in the

4 U.S. would continue as expected today if the proposed ACP is not constructed, operated, or

5 decommissioned.

6

7 If any additional domestic enrichment facilities are proposed in the future, the environmental impacts at

8 any alternate site(s) would have to be assessed in a separate National Environmental PolicyAct review.

9 Impacts at any such alternate site(s) may be larger than'those associated with the proposed action

10 involving the ACP if all the facilities need to be built from scratch (about half of the proposed ACP

11 facilities already exist). The construction and operation of another enrichment facility in the United

12 States, needed to fulfill growing demands, could result in more or less impacts than the proposed action,

13 depending on the particulars of the proposed action and ecological conditions at any alternate site(s).

14 However,' those impacts would have to be evaluated in a separate National Environmental Policy Act

15 review and would likely be avoided or mitigated to the point where they are considered SMALL.

16 Assuming that review and associated consultations with preservation officials follow standard procedures,

17 impacts to any resources of concern should be avoided or mitigated to the point of being SMALL.

18 However, any alternative sites and facilities would be subject to a separate National Environmental Policy

19 Act review that would endeavor to avoid or mitigate potential visual and scenic impacts to the point that

20 they can be considered SMALL.

21

22 The following sections evaluate the potential impacts associated with this no-action alternative. Each of

23 -the same resource areas evaluated for the proposed action in Section 4.2 are briefly assessed here in the

24 same order as above.

25

26 4.4.1 Land Use Impacts

27

28 Under the no-action alternative, the facilities currently leased to USEC for the ACP would remain leased

29 to USEC. Some of these facilities would likely continue to be used for the Lead Cascade Demonstration

30 Facility, which is currently scheduled to operate until the middle of 2008 in order to continue to provide a

31 demonstration of the gas centrifuge enrichment process. Any future uses of the facilities currently

32 proposed for the ACP would be up to USEC and DOE, but would be expected to include similar activities

33 within the nuclear fuel cycle, consistent with USEC's and the reservation's history and mission.

34

35 If the buildings and grounds currently proposed for the ACP were in fact not used for that purpose, it is

36 very unlikely that those buildings and grounds would be available for completely different uses. In a

37 recent Environmental Assessment examining reindustrialization alternatives at Piketon (DOE, 2001a),

38 DOE concluded that property currently under lease by USEC would not be available for

39 reindustrialization, such as different kinds of light or heavy manufacturing.

40

41 Nevertheless, the current program for examining and implementing reindustrialization alternatives at the

42 reservation would remain in place under the no-action alternative, and this program would likely lead to

43 alternate uses of other property on the reservation just like it has in the past. Current and future

44 reindustrialization activities would be coordinated through the Southern Ohio Diversification Initiative,

45 the recognized community reuse organization for the DOE reservation at Piketon. DOE's Office of

46 Worker and Community Transition established community reuse organizations to minimize the adverse

47 effects of workforce restructuring at DOE facilities that have played an historic role in the nation's

48 defense. These organizations provide assistance to the neighboring communities negatively affected by

49 changes at these sites..

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I,

I The Southern Ohio Diversification Initiative actively promotes the reuse of DOE property by private

2 industry. The first lease between DOE and the Southern Ohio Diversification Initiative was signed on

3 April 1, 1998, for 2.4 to 3.2 hectares (6 to 8 acres) of land on the north side of the DOE reservation

4 property. The tract was used as a right-of-way for a railroad spur to connect with the existing DOE north

5 rail spur. A portion of this property was then subleased by the Southern Ohio Diversification Initiative to

6 the Mead Corporation for access to the rail line for a new wood grading operation. This action was

7 covered under National Environmental Policy Act Categorical Exclusion Number CX-POR-522,

8 completed in 1997. A second lease between DOE and the Southern Ohio Diversification Initiative was

9 signed on October 13, 2000, for 4.9 hectares (12 acres) of land adjacent to the area of the first lease. This

10 tract will be used for additional railroad spurs and use of existing rail facilities. This action was covered

11 under National Environmental Policy Act Categorical Exclusion Number CX-PORTS-538. (DOE,

12 2001a)

13

14 Other alternate uses of reservation property that have been approved and implemented in the recent past

15 include the following:

16

17 * Right-of-way easement for a waterline and sewer line;

18 * License for non-Federal use of property for concurrent road usage;

19 * Recreational license to Scioto Township for development of a community park;

20 * Greenway licenses to Scioto Township and Seal Township; and

21 * Lease/license (short-term) for use of parking lots by the Southern Ohio Diversification Initiative.

22

23 All of these efforts to find alternative uses of property on the Piketon reservation would continue under

24 the no-action alternative, but they would not be broadened to include the facilities and grounds currently

25 proposed for the ACP. The facilities and grounds proposed for the ACP are unavailable for

26 reindustrialization and would be expected to be used in some other way related to uranium enrichment, if

27 not used for the ACP. Therefore, the land use impacts of the no-action alternative would be SMALL.

28

29 4.4.2 Historic and Cultural Resources Impacts

30

31 The no-action alternative would involve no new construction or land disturbance activities that could

32 threaten historic and cultural resources of interest in the area of potential effect. Any alternate proposal

33 for additional domestic enrichment facilities would have to be examined to determine potential impacts to

34 historic and cultural resources.

35

36 4.4.3 Visual and Scenic Impacts

37

38 Under the no-action alternative, the proposed ACP facilities would not be constructed, and the DOE

39 reservation at Piketon would look just like it is presently planned to look. Any visual and scenic impacts

40 would be transferred to the site(s) of additional enrichment facilities built elsewhere, and would likely be

41 greater than those of the proposed action if that site is presently not as industrialized as the DOE

42 reservation at Piketon.

43

44 4.4.4 Air Quality Impacts

45

46 Under the no-action alternative, air quality in the general area would remain at its current levels described

47 in Section 3.5. The fugitive dust associated with the proposed ACP site preparation and construction

48 activities and the resulting temporary increase in particulate matter concentrations would be avoided. The

49 Paducah Gaseous Diffusion Plant would continue to operate at its current level with the existing

50 emissions associated with the coal combustion needed to support that technology. Additional domestic

51 enrichment facilities could be built at alternate sites in the future, with site-specific impacts that would

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Il
1 have to be assessed in a separate environmental review. Because it is likely that more construction would

2 be needed at sites other than Piketon (since half the facilities needed at Piketon already exist), the air

3 quality impacts associated with construction at alternate sites would likely be greater than those assessed

4 for the proposed action. However, any such construction-related impacts would be temporary and subject

5 to best management practices and air quality regulatory controls. Any air quality impacts associated with

6 operations at alternate sites would likely be small, assuming the use of gas centrifuge technology, which

7 does not emit substantial quantities of air pollutants. For these reasons, the air quality impacts of the no8 action alternative are expected to be SMALL.

9

10 4.4.5 Geology and Soils Impacts

11

12 Under the no-action alternative, no major new construction would be undertaken by the United States

13 Enrichment Corporation or USEC at the reservation in Piketon. Current industrial activities at the site

14 would continue, with the same level of disturbance to the land and the same threat of soil contamination.

15 The no-action alternative would not be expected to give rise to alternate activities at the reservation that

16 would substantially increase the potential for geology or soils impacts at Piketon.' If additional domestic

17 enrichment facilities are built in the future, the geology and soils impacts at any alternate site(s) may be

18 larger than those associated with the proposed action if all the facilities needed to be built from scratch

19 (about half of the proposed ACP facilities already exist). However, even in this case, limited impacts to

20 geology would be expected and any impacts to soils would likely be temporary and controlled.

21 Therefore, the impacts of the no-action alternative on these resources would be SMALL.

22

23 4.4.6 Water Resource Impacts

24

25 Under the no-action alternative, the small impacts to surface water and groundwater caused by the

26 proposed action would be avoided, and current activities at the reservation at Piketon and at the Paducah

27 Gaseous Diffusion Plant would continue with their same level of impacts. Water usage rates and

28 wastewater discharge rates at Piketon would continue to be well below system design capacities and

29 'historical operating levels. Additional domestic enrichment facilities could be built at alternate sites in

30 the future, and the impacts to water resources would likely be similar to those described in this Draft EIS

31 for the proposed action. Therefore, the water resource impacts associated with the no-action alternative

32 are expected to be SMALL.

33

34 4.4.7 Ecological Impacts

35

36 The no-action alternative would avoid the need to clear and grade the I 0-hectare (24-acre) area needed for

37 the X-745H Cylinder Storage Yard north of Perimeter Road, which has the potential for small impacts to

38 the local habitat and water quality in nearby tributaries leading to Little Beaver Creek. All activities at

39 Piketon would continue on their present course without any new or greater ecological impacts; If

40 additional domestic'enrichment facilities are built in the future, the ecological impacts at any'altemate

41 site(s) may be larger than those associated with the proposed action if all the facilities needed to be built

42 from scratch (about half of the proposed ACP facilities already. exist), and if the selected site(s) have more

43 pristine or sensitive ecological features. However, even in this case, ecological impacts would be

44 expected to be limited and mitigated. Therefore, the ecological impacts of the no-action alternative are

45 expected to be SMALL.

46

47 4.4.8 Socioeconomic Impacts

48

49 Under the no-action alternative, UF6 production would continue at the Paducah Gaseous Diffusion Plant,

50 avoiding the impacts to the Paducah region of influence that would arise from cessation of enrichment

51 operations at that site. The most significant avoided impact of the no-action alternative would be the

4-117
1 adverse effect to employment in the region surrounding Paducah, as described in Section 4.2.8.4. The

2 level of activity at Paducah would remain temporarily constant under the no-action alternative and those

3 jobs would not be lost.

4

5 On the other hand, the no-action alternative would also imply that none of the socioeconomic benefits

6 associated with the proposed action, including increased employment, income, and tax revenues described

7 in Sections 4.2.8.2 and 4.2.8.3, would accrue to the community in the Piketon region of influence..

8 Adverse effects to the Piketon region of influence would include the loss of approximately 1,500 direct

9 and indirect jobs during the 30-year operations phase, 3,362 direct and indirect jobs during the five-year

10 construction phase, and 2,130 direct and indirect jobs during the 10-year manufacturing phase that would

11 have been created by the proposed action.

12

13 Eventually, additional domestic enrichment facilities would likely be built in one or more other places in

14 order to meet the nation's growin'g demand for enriched uranium. This would be expected to result in the

15 same cessation of activities at Paducah as under the proposed action, and the same socioeconomic impacts

16 of the proposed action but an alternate location. Therefore, the socioeconomic impacts of the no-action

17 alternative are expected to be SMALL.

18

19 4.4.9 Environmental Justice Impacts

20

21 Since the no-action alternative would not be expected to cause any high and adverse impacts, it should

22 not raise any environmental justice issues. Therefore, any impacts would be SMALL.

23

24 4.4.10 Noise Impacts

25

26 Under the no-action alternative, the nature and scale of existing activities at Piketon and Paducah, and

27 their associated noise levels, would remain constant. Additional domestic enrichment facilities could be

28 constructed in the future. Depending on the construction methods and design of these facilities, the likely

29 noise impact would be similar to that described for the proposed action. Therefore, noise impacts would

30 be expected to be SMALL.

31

32 4.4.11 Transportation Impacts

33

34 Under the no-action alternative, traffic volumes and patterns would remain the same as described in

35 Sections 3.12 and 4.2.11. Transportation of materials to, from, and between the Paducah and Portsmouth

36 Gaseous Diffusion Plants would continue at present levels. Wastes resulting from United States

37 Enrichment Corporation activities at Piketon would continue to be shipped off the reservation to

38 treatment and disposal facilities, at rates and along routes similar to the current pattern. Additional

39 domestic enrichment facilities could be constructed in the future, with transportation impacts likely to be

40 similar to those described here for the proposed action. Overall, the transportation impacts of the no41 action alternative would be expected to be SMALL.

42

43 4.4.12 Public and Occupational Health Impacts

44

45 Under the no-action alternative, there would not be any new activities that would pose a risk of worker

46 injuries and illnesses and no new releases of non-radiological or radiological contaminants that could

47 result in greater public exposures and health risks. All levels of activities, releases, and health impacts

48 would remain constant and the subject of ongoing monitoring and assessment programs. The public and

49 occupational health impacts of any other domestic enrichment facilities that would need to be built

50 instead of the proposed ACP would also be expected to be appropriately controlled through engineering

4-118

1l
I design, best management practices, and regulatory controls. Therefore, the public and occupational

2 health impacts of the no-action alternative would be expected to be SMALL.

3

4 4.4.13 Waste Management Impacts

5

6 Under the no-action alternative, new wastes, including sanitary, hazardous, low-level radioactive, and

7 low-level mixed wastes, would not be generated, managed, and disposed. Additional domestic

8 enrichment facilities could be constructed in the future. Depending on the construction methods, the

9 design, and the location of these facilities relative to suitable waste management facilities, the likely waste

10 management impacts would be similar to the proposed action. A significant difference could exist if

11 another enrichment facility is not co-located with a depleted uranium conversion facility, like the ACP is

12 adjacent to the new DOE conversion facility at Piketon. This would create additional requirements to

13 transport the tails from the enrichment facility to a suitable conversion facility. That added transportation,

14 however, would be subject to all NRC and Department of Transportation requirements and should pose

15 only a small risk to workers and the public. Therefore, the impacts from waste management would likely

16 be SMALL.

17

18 4.5 References

19

20 (ANL, 2001) Argonne National Laboratory. "Transportation Impact Assessment for Shipment of

21 Uranium Hexafluoride (UF6) Cylinders from the East Tennessee Technology Park to the Portsmouth and

22 Paducah Gaseous Diffusion Plants" ANL/EAD/TM-1 12. Environmental Assessment Division. October

23 2001. <http://web.ead.anl.gov/uranium/pdf/ANL-EAD-TM-112.pdf> (Accessed 6/21/2005).

24

25 (BEA, 2002a) U.S. Bureau of Economic Analysis. "Total full-time and part-time employment by

26 - industry." U.S. Department of Commerce, Bureau of Economic Analysis. 2002.

27 <http://www.bea.gov/bealregional/reis/>.

28

29 (BEA, 2002b) U.S. Bureau of Economic Analysis. "Per capita personal income." U.S. Department of

30 Commerce, Bureau of Economic Analysis. 2002. <http://www.bea.doc.gov/bea/regionaVreis/>.

31

32 (BLS, 2004a) Bureau of Labor Statistics. "Table 1, Incident Rates of Nonfatal Occupational Injuries and

33 Illnesses by Industry and Case Types 2003." September 2004.

34 <http://www.bls.gov/iif/oshwc/osh/os/ostbl355.pdfP (Accessed 6/21/2005).

35

36 (BLS, 2004b) Bureau of Labor Statitics. "National Census of Fatal Occupational Injuries in 2003."

37 September 22,2004. <http://www.bls.gov/news.release/pdf/cfoi.pdf> (Accessed 6/21/2005). --

38

39 (Borchelt, 2003) Borchelt, as cited in "Environmental Report for American Centrifuge Lead Cascade

40 Facility at USEC's Facilities in Piketon, Ohio."' LA-2605-0002. Natural Resource Conservation Service.

41 February 2003.

42 - -

43 (CARB, 2000) California Air Resources Board. "Risk Reduction Plan to Reduce Particulate Matter from

44 Diesel-Fueled Engines and Vehicles," Appendix 7: Stationary Source Division and the Mobile Source

45 Control Division, Sacramento, CA. October 2000.

46

47 (CEQ, 1997) Council of Environmental Quality. "Environmental Justice Guidance under the National

48 Environmental Policy Act." Executive Office of the President. December 1997.

49

50 (DOE, 1999a) U.S. Department of Energy. "Programmatic Environmental Assessment for the U.S.

51 Department of Energy, Oak Ridge Operations Implementation of a Comprehensive Management Program

4-119
I it

I for the Storage, Transportation, and Disposition of Potentially Reusable Uranium Materials." DOE

2 EA-1393. 1999.

3

4 (DOE 1999b) U.S. Department of Energy. "Final Programmatic Environmental Impact Statement for

5 Alternative Strategies for the Long Term Management and Use of Depleted Uranium Hexaflouride."

6 DOE/EIS-0269. Office of Nuclear Energy, Science and Technology. April 1999.

7

8 (DOE, 2001a) U.S. Department of Energy. "Environmental Assessment Reindustrialization Program at

9 the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOE/EA-1346. May 2001.

10

11 (DOE, 2001b) U.S. Department of Energy. "Environmental Assessment: Winterization Activities in

12 Preparation for Cold Standby at the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio." DOE/EA-1392.

13 June 2001.

14

15 (DOE, 2003) U.S. Department of Energy. "Portsmouth Annual Environmental Report for 2002."

16 DOE/ORII 1-3132 & Dl. EQ Midwest, Inc. October 2003.

17 <http://www.bechteljacobs.com/ports-reports.shtml> (Accessed 11/15/2004).

18

19 (DOE, 2004a) U.S. Department of Energy. "Final Environmental Impact Statement for Construction and

20 Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio Site."

21 DOE/EIS-0360. Office of Environmental Management. June 2004.

22

23 (DOE, 2004b) U.S. Department of Energy. "Portsmouth Annual Environmental Report for 2003."

24 DOE/OR/ 1 -3153 & DI. Office of Environmental Management. November 2004.

25

26 (DOE, 2004c) U.S. Department of Energy. "Final Environmental Impact Statement for Construction and

27 Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky Site."

28 DOE/EIS-0359. June 2004.

29

30 (EPA, 1992) U.S. Environmental Protection Agency. "Screening Procedures for Estimating the Air

31 Quality Impact of Stationary Sources, Revised." EPA-454/R-92-019. October 1992.

32

33 (EPA 1994) U.S. Environmental Protection Agency. "Estimating Radiogenic Cancer Risks." EPA 402-R34 93-076. Office of Radiation and Indoor Air. June 1994.

35

36 (EPA, 1995a) U.S. Environmental Protection Agency. "Compilation of Air Pollution Emissions Factors."

37 AP-42. 1995.

38

39 (EPA, 1995b) U.S. Environmental Protection Agency. "User's Guide for the Industrial Source Complex

40 (ISC3) Dispersion Models." Volume 1. EPA-454/B-95-003a. September 1995.

41

42 (EPA, 1998) U.S. Environmental Protection Agency. "Locomotive Emission Standards, Regulatory

43 Support Document." Office of Mobile Sources. June 1998. <http://www.epa.gov/otaq/locomotv.htm>

44 (Accessed 6/20/2005).

45

46 (EPA, 1999) U.S. Environmental Protection Agency. "Cancer Risk Coefficients for Environmental

47 Exposure to Radionuclides, Federal Guidance Report No. -13." EPA 402-R-99-001. September 1999.

48 <http://www.epa.gov/radiation/docs/federaV402-r-99-00I.pdf> (Accessed on 6/20/2005).

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11
I (EPA, 2003) U.S. Environmental Protection Agency. "Users Guide to MOBILE6.1 and MOBILE6.2:

2 Mobile Source Emission Factor Model." EPA420-R-03-010. August 2003.

3

4 (EPA, 2004a) U.S. Environmental Protection Agency. "Exhaust and Crankcase Emission Factors for

5 Nonroad Engine Modeling." EPA, Report No. NR-009c, EPA42O-P-04-009. Compression-Ignition,

6 Assessment and Standards Division, Office of Transportation and Air Quality. 2004.

7 <http://www.epa.gov/otaq/nonrdmndl.htm#techrept> (Accessed 6/20/2005).

8

9 (EPA, 2004b) U.S. Environmental Protection Agency. "Exhaust Emission Factors for Nonroad Engine

10 Modeling." EPA, Report No. NR-01Od, EPA420-P-04-010. Spark-Ignition, Assessment and Standards

11 Division, Office of Transportation and Air Quality. April 2004.

12 <http://www.epa.gov/otaq/nonrdmdl.htm#techrept> (Accessed 6/20/2005). -

13

14 (EPA, 2004c) U.S. Environmental Protection Agency. "Basic Evaporative and Crankcase Emission Rates

15 for Nonroad Engine Modeling." EPA, Report No NR-012b, EPA420-P-04-012. Assessment and

16 Standards Division, Office of Transportation and Air Quality. April 2004.

17 <http://www.epa.gov/otaq/nonrdmdl.htmntftechrept> (Accessed 6/20/2005).

18

19 (GAO, 2004) U.S. General Accounting Office. "Low-Level Radioactie Waste: Disposal Availability

20 Adequate in the Short Term, But Oversight Needed to Identify Any Future Shortfalls," Report to the

21 Chairman, Committee on Energy and Natural Resources, U.S. Senate. GAO-04-604. June 2004.

22

23 (HUD, 2002) U.S. Department of Housing. "The Noise Guidebook," Community Planning and

24 Development. June 5, 2002.

25

26 (IAEA, 1992) International Atomic Energy Agency. "Effects of Ionizing Radiation on Plants and Animals

27 at Levels Implied by Current Radiation Protection Standards." Technical Report Series No. 332. 1992.

28

29 (III, 2005) Insurance Information Institute. "Motor Vehicle Traffic Deaths by State, 2002-2003." 2005.

30 <httpJ/www.iii.org/media/facts/statsbyissue/highway/> (Accessed 6/6/2005).

31

32 (McTrans Center, 2003) McTrans Center, University of Florida. "Highway Capacity Software." Version

33 4.le. 2003.

34

35 (NHTSA, 2005) National Highway Traffic Safety Administration. "Traffic Safety Facts 2003: A

36 Compilation of Motor Vehicle Crash Data from the Fatality Analysis Reporting System and the General

37 Estimates System." DOT HS 809 775. January 2005.:

38 <http://www-nrd.nhtsa.dot.gov/pdf/nrd-30/NCSA/TSFArin2003HTMLTSF/TSF2003.HTM> (Accessed

39 6/6/2005).

40

41 (NIOSH, 1996) National Inistitute for Occupational Health and Safety. "Docuumentation for Immediately

42 Dangerous to Life or Health Concentrations (IDLHs): Uranium." 1996. <http:/lwww.cdc.gov/niosh/idlW

43 uranium.html> (Accessed 6/20/2005).

44

45 (NIOSH, 2005) National Institute for Occupational Health and Safety. "NIOSH Pocket Guide to

46 Chemical Hazards: Uranium." 2005. <http://www.cdc.gov/niosh/npg/npgdO651.html> (Accessed

47 6/20/2005).

48

49 (Nortz et al., 1994) Nortz, Patrick E; Bair, E. Scott, Ward, Andrew, White, Dale. "Interactions Between

50 An Alluvial Aquifer Weilfield and the Scioto River, Ohio, USA." Hydrogeology Journal, Volume 2,

51 Issue 4, pp. 23-34. 1994.

4-121
l l

I (NRC, 1977) U.S. Nuclear Regulatory Commission. "Final Environmental Statement on the

2 Transportation of Radioactive Material by Air and Other Modes." NUREG-0 170. 1977.

3

4 (NRC, 1990) U.S. Nuclear Regulatory Commission. "Control Room Habitability System Review

5 Models." NUREG/CR-5659. December 1990.

6

7 (NRC, 1991) U.S. Nuclear Regulatory Commission. "Chemical Toxicity of Uranium Hexafluoride

8 Compared to Acute Effects of Radiation." NUREG-1391. February 1991.

9

10 (NRC, 1998) U.S. Nuclear Regulatory Commission. "Nuclear Fuel Cycle Facility Accident Analysis

11 Handbook." NUREG/CR-6410. March 1998.

12

13 (NRC, 2001) U.S. Nuclear Regulatory Commission. "RASCAL 3.0: Description of Models and

14 Methods." NUREG-1741. March 2001.

15

16 (NRC, 2003) U.S. Nuclear Regulatory Commission. "Environmental Review Guidance for Licensing

17 Actions Associated with NMSS Programs." NUREG-1748. August 2003.

18

19 (NRC, 2004c) U.S. Nuclear Regulatory Commission. "Environmental Impact Statement for the Proposed

20 National Enrichment Facility in Lea County, New Mexico, Draft Report for Comment." NUREG-1790.

21 Office of Nuclear Material Safety and Safeguards. Division of Waste Management and Environmental

22 Protection. September 2004.

23

24 (NRC, 2005a) U.S. Nuclear Regulatory Commission. "What Are Sources of Radiation." 2005.

25 <http://www.nrc.gov/what-we-do/radiation/sources.html> (Accessed 6/20/2005).

26

27 (NRC, 2005b) U.S. Nuclear Regulatory Commission. "Telephone Summary Regarding Depleted Uranium

28 Disposal," Memo from Blevins to Flanders. April 2005.

29

30 (ODOD, 2003) Ohio Department of Development. "Ohio County Profiles." Office of Strategic Research.

31 September 2003.

32

33 (Ohio Department of Taxation, 2003) Ohio Department of Taxation. "Annual Report. October 2003.

34 <http://tax.ohio.gov/divisions/communications/publications/annual reports/publicationsannual report 2

35 003.stm>.

36

37 (Ohio DOT, 2004a) Ohio Department of Transportation. "Traffic Survey Report."

38 <http:/lwww.dot.state.oh.us/techservsite/availpro/TrafficSurvey/TSR Report/default.htm.> (Accessed

39 6/1/2005).

40

41 (Ohio DOT, 2004b) Ohio Department of Transportation. "2004 K & D Factors Report."

42 <http://www.dot.state.oh.us/techservsite/offceorg/trafflnonit/trafflnonit.htm> (Accessed 6/1/2005).

43

44 (Ohio EPA, 1998) Ohio Environmental Protection Agency. "Biological and Water Quality Study of Little

45 Beaver and Big Beaver Creek, 1997." 1998.

46

47 (Ohio EPA, 2005) Ohio Environmental Protection Agency. Phone conversation between ICF Consulting

48 and Ohio EPA, RE: Groundwater withdrawal rates and subsidence. May 12, 2005.

4-122

11
1 (OHPO, 2004) Ohio Historic Preservation Office. Letter from Ms. M. Epstein (OHPO) to Mr. P. Miner

2 (USEC), RE: Installation and Operation of the American Centrifuge Commercial Plant, Portsmouth

3 Gaseous Diffusion Plant (PORTS), Pike County, Ohio. May 20,2004.

4

5 (OHPO, 2005) Ohio Historic Preservation Office. Letter from Mr. D. Snyder (OHPO to Mr. R. Linton

6 (NRC), Re: Docket No. 70-7004, American Centrifuge Commercial Plant, Portsmouth Gaseous

7 Diffusion Plant (PORTS), Pike County, Ohio. February 2, 2005.

8

9 (Pike County Auditor, 2005) Pike County Auditor. Telephone conversation. May 11, 2005.

10

11 (Policastro et al., 1997) Policastro, A.J., et al., 1997, Facility Accident Impact Analyses in Support of the

12 Uranium Hexafluoride Programmatic Environmental Impact Statement, attachment to intraoffice

13 memorandum from Policastro et al. to H.I. Avci (Argonne National Laboratory, Argonne, Ill.). May

14 1997.

15

16 (U.S. Census Bureau, 2000) U.S. Census Bureau. "Profiles of General Demographic Characteristics:

17 2000 Census of Population and Housing, Ohio. U.S. Department of Commerce. 2000.

18 <http://www.census.gov/prod/cen2000/dpl/2kh39.pdf (Accessed 5/24/2004).

19

20 (U.S. Census Bureau, 2003) U.S. Census Bureau. "Current Population Survey, 2003 Annual Social and

21 Economic Supplement." Internet Release Date: September 15, 2004.

22

23 (United States Enrichment Corporation, 2004) United States Enrichment Corporation. Spill Prevention

24 Control and Countermeasures Plan for the United States Enrichment Corporation, Portsmouth Gaseous

25 Diffusion Plant. June 2004.

26

27 (USEC, 2004a) USEC Inc. LA-3605-0003, "Integrated Safety Analysis Summary for the American

28 Centrifuge Plant in Piketon, Ohio." Revision 0. Docket No. 70-7004. August 2004.

29

30 (USEC, 2004b) USEC Inc. NR-3605-0008, "Emergency Plan for the American Centrifuge Plant in

31 Piketon, Ohio." Revision 0. August 2004.

32

33 (USEC, 2004c) USEC Inc. LA-3605-0001, "License Application for the American Centrifuge Plant in

34 Piketon, Ohio." Revision 0. NRC Docket No. 70-7004. August 2004.

35

36 (USEC, 2005a) USEC Inc. "Environmental Report for the American Centrifuge Plan in Piketon, Ohio."

37 Revision 3. Docket No. 70-7004. July 2005.

38

39 (USEC, 2005b) United States Enrichment Corporation. "Best Management Practices for the United

40 States Enrichment Corporation." March 2005.

41

42 (USEC, 2005c) USEC, Inc. "Submittal of Additional Information Regarding the Environmental Report

43 for the American Centrifuge Plant (TAC No. L32308)." AET 05-0059. Docket No. 70-7004. July 18,

44 2005.

45

46 (USEC, 2005d) USEC, , Inc. "Response to Request for Additional Information Regarding the

47 Environmental Report and Reference Documents (TAC No. L32307) - Proprietary and Export

48 Controlled Information." AET-05-0013. Docket Number 70-7004. April 15, 2005.

4-123
I - (WRAP, 2004) Western Regional Air Partnership. "WRAP Fugitive Dust Handbook." Prepared by

2 Countess Environmental, Westlake Village, CA. 2004.

3 <http:l/www.ndep.nv.gov/baqp/WRAP/INDEX.htrnl> (Accessed 6/20/2005).

4

S (Yost, 2005) Yost, Kevin, (Pike Soil and Water Conservation District). Personal communication, RE:

6 Prime Farmlands on the DOE Reservation. June 17, 2005.

4-124
I 5. MITIGATION

2

3 This chapter addresses potential means to mitigate adverse environmental impacts from the proposed

4 action as required by Appendix A of Title 1 0, Part 51, of the Code ofFederaiRegulations (I 0 CFR Part

5 51). Under Council on Environmental Quality regulation 40 CFR 1500.2(f), Federal agencies shall to the

6 fullest extent possible "use all practicable means consistent with the requirements of the National

7 Environmental Policy Act and other essential considerations of national policy to restore and enhance the

8 quality of the human environment and avoid or minimize any possible adverse effects of their actions on

9 the quality of the human environment." The Council on Environmental Quality regulations define

10 mitigation to include activities that (1) avoid the impact altogether by not taking a certain action or parts

11 of an action; (2) minimize impacts by limiting the degree or magnitude of the action and its

12 implementation; (3) repair, rehabilitate, or restore the affected environment; (4) reduce or eliminate

13 impacts over time by preservation or maintenance operations during the life of the action; or (5)

14 compensate for the impact by replacing or substituting resources or environments. This definition has

15 been used in identifying potential mitigation measures. As such, mitigation measures are those actions or

16 processes'(e.g., process controls and management plans) that would be implemented to control and

17 minimize potential impacts from construction and operation activities for the proposed American

18 Centrifuge Plant (ACP).

19

20 USEC Inc. (USEC) must comply with applicable laws and regulations, including obtaining all appropriate

21 - construction and operating permits. A complete discussion of applicable laws and regulations is included

22 in Chapter 1 of this Draft Environmental Impact Statement (EIS). The mitigation measures proposed by

23 USEC, many of which are compliance related are discussed in Section 5.1.

24

25 Based on the potential impacts identified in Chapter 4 (Environmental Impacts), the U.S. Nuclear

26 Regulato'ry 'Commission (NRC) staff has identified additional potential mitigation for the proposed ACP.

27 These mitigation measures are described in Section 5.2.

28

29 The proposed mitigation measures provided in this chapter do not include environmental monitoring

30 activities. Environmental monitoring activities are'described in Chapter 6 of this Environmental Impact

31 Statement.

32

33 5.1 Mitigation Measures Proposed by USEC

34

35 USEC identified mitigation measures in the Environmental Report (USEC, 2005a) that would reduce the

36 environmental impacts associated with the proposed action. Table 5-1 lists the mitigation measures

37 impact areas for the construction phase of the proposed action. Table 5-2 lists the mitigation measures

38 impact areas for operations.

5-1
Table 5-1 Summary of Preliminary Mitigation Measures Proposed by USEC for Construction

Impact Area' Activity Proposed Mitigation Measures

Geology and Soils Soil disturbance . Use best management and construction practices to minimize

the extent of excavation.

Install physical barriers such as silt fences and straw bales, and re-seed disturbed areas to minimize erosion and

sediment runoff.

I Soil contamination Implement a Spill Prevention, Control, and Countermeasures

Plan (SPCC).

- Sample, analyze and manage contaminated soils in

: accordance with NRC, State and other Federal requirements.

Water Resources . Runoff * Install physical barriers such as silt fences and straw bales, and re-seed disturbed areas to minimize erosion and

i sediment runoff.

: Use engineering controls, and best management and

construction practices to minimize the extent of excavation.

Implement an SPCC.

* Outside areas and the building roofs drain to the storm

sewer.

Water use I Implement a Pollution Prevention Plan to reduce or eliminate

discharge of waste.

Groundwater E Implement an SPCC.

* Sample, analyze and manage contaminated soils in

i accordance with NRC, State and other Federal requirements.

Ecological Resources Wetlands disturbance i Maintain a buffer near adjacent wetlands during construction

i and place temporary lay-down areas on previously disturbed

I areas.

I Institute compensatory mitigation if impacts to wetlands are

i unavoidable.

Air Quality i Fugitive dust i Use dust suppression techniques to reduce release of dust

i during excavation under dry conditions.

aD

8 Source: USEC, 2005a.

9

5-2

II
-

: . -1 I

l

2

Table 5-2 Summary of Preliminary Mitigation Measures Proposed by USEC for Operations

3 Impact Area

4 Geology and Soils

Activi

Cylinder stor.

Aboveground

ity Proposed Mitigation Measures

age Implement an SPCC.

Conduct routine visual inspections and preventive maintenance.

In the case of release of liquid effluent use absorbent spill equipment adjacent to the perimeter of the cylinder storage yards. Excavation of affected soils and implement confirmatory sampling to verify that there is no residual

contamination. Use clean fill soils in the excavated areas.

I storage Implement an SPCC.

Conduct routine visual inspections and preventive maintenance.

Construct above ground storage tanks of appropriate materials.

Sample accumulated water in tanks and manage according to

analytical results.

Use secondary containment for tanks storing petroleum products.

Maintain spill cleanup materials in the areas of fuel line and

tank hose connections.

Sample, analyze and manage contaminated soils in

accordance with NRC, State and other Federal requirements. ~~~~~~~~~~~~~~~~~~~~~~.... . ._.... _. _...._...__...__..___.. ......... _..._...__ .__...._____

Implement an SPCC.

Conduct routine visual inspections and preventive maintenance of tanks, impoundment dikes.

Use trained professionals to respond to any spills within

process buildings.

No wastewater would be discharged from the liquid effluent

tanks.

Implement a Pollution Prevention Plan to reduce or eliminate

discharge of waste.

Implement an SPCC.

Conduct routine visual inspections and preventive maintenance.

Sample, analyze and manage contaminated soils in

accordance with NRC, State and other Federal requirements.

Sample accumulated water in tanks and manage according to

analytical results.

r Implement a Hazardous Materials Policy to ensure proper tstes identification of hazardous materials provide training on job- specific hazards, emergency, rocedures, incident

management, medical surveillmce, and decontamination.

iseous Use alumina traps to collect solidified uranyl fluoride.

5 Water Resources - Runoff

Water use

Groundwater

6

7

8

9

10

__ .......... .__ ......... __........ _...... _.._

Public and Generation ol

Occupational Health hazardous wz

A ir Qu __ a lit y _ A c .. . ..

Air Quality Accidental g,

releases .. ___ __ .............. _ . _._. ......... __.__ A_..._.____._..................__....._........ . ......._._.

Waste Management Generation of Implement an SPCC.

industrial, hazardous, radiological, and Implement a Hazardous Materials Policy to eliminate or

mixed wastes reduce to levels as low as reasonably achievable, generation of hazardous wastes.

Implement a Pollution Prevention Program to reduce or

eliminate pollution.

Source: USEC, 2005a.

5-3
1

2

3

4

5

6

7

8

9

10

No mitigation measures were identified for the resource areas of:

* Land Use;

* Transportation;

* Noise;

* Historical and Cultural Resources;

* Visual/Scenic Resources;

* Socioeconomics;

* Public and Occupational Health; and

* Environmental Justice.

l11

12

l 13

14

!15

16

17

18

19

20

! 21

22

l 23

24

25

26

27

28

29

! 30

31

l 32

33

34

35

36

5.2 Potential Mitigation Measures Identified by NRC

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the mitigation measures proposed by

USEC for the proposed ACP and has identified additional potential mitigation measures in addition to

those proposed by USEC. Additional potential mitigation measures were only identified for

environmental resource areas for which analyses identified a potential for impacts and where the measure

would be sufficiently beneficial as to warrant implementation. Potential mitigation measures in addition

to those proposed by USEC were identified for air quality (Table 5-3).

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

Impact Area Activity Proposed Mitigation Measures

Air Quality IParticulate Matter . Use Tier 2 construction-related vehicles (2000 to 2005- model year equipment depending on engine horsepower rating) to reduce diesel emissions.

_I * Use ultra-low sulfur diesel.

No a miigaton ditona eas res wereide tifed y NR stff or acilty pertio s o

No additional mitigation measures were identified by NRC staff for facility operations or

decommissioning the proposed ACP.

53 References

(USEC, 2005a) United States Enrichment Corporation. "Environmental Report for the American

Centrifuge Plant in Piketon, Ohio." Revision 3. NRC Docket No. 70-7004. July 2005.

(USEC, 2005b) United States Enrichment Corporation. "POEF-EW-16, Revision 3, Best Management

Practices for the United States Enrichment Corporation, March 4." Responses to Request for Additional

Information on the Enviromnental Report, AET 05-0013. April 15, 2005.

5-4

11
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3

4

5

6

7

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9

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15

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19

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26

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28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

6. ENVIRONMENTAL MEASUREMENT AND MONITORING PROGRAMS

This chapter describes the proposed environmental measurements and monitoring program proposed to

characterize the effects of potential radiological and nonradiological releases from the proposed American

Centrifuge Plant (ACP) in Piketon, Ohio on human health and the environment. Measurement and

monitoring programs include direct monitoring of radiological and physiochemical gaseous and liquid

effluents from facility operations, and monitoring and measurement of ambient air, surface water,

sediment, groundwater, soils, biota, and direct [gamma] radiation in the vicinity of the proposed ACP.

The proposed ACP would be located contiguous to an existing uranium enrichment plant, the Portsmouth

Gaseous Diffusion Plant, at which uranium and UF6 have been managed for approximately 50 years. The

Portsmouth Gaseous Diffusion Plant was operated by the United States Enrichment Corporation, a

subsidiary of USEC, from 1993 until it was placed in cold standby in 2002, and by predecessor

organizations of the United States Enrichment Corporation prior to 1993. The environmental monitoring

system for the proposed ACP is based on the experience and data accumulated at the Portsmouth Gaseous

Diffusion Plant.

6.1 Radiological Measurements and Monitoring Program

The radiological monitoring and measurement program for the proposed ACP was developed in

accordance with NRC Regulatory Guidelines (see Table 6-1). The NRC requires that a radiological

monitoring program be established for the proposed ACP to monitor and report the release of radiological

air and liquid effluents to the environment.

Table 6-1 Guidance Documents that Apply to the Radiological Monitoring Program

Document I Applicable Guidance

Regulatory Guide 4.15' "Quality Assurance for Radiological Monitoring Programs (Normal Operations) -

Effluent Streams and the Environment." This guide describes a method acceptable to

. the NRC for designing a program to ensure the quality of the results of measurements

for radioactive materials in the effluents and the environment outside of nuclear

facilities duringa normal operatons

Regulatory Guide 4 162 "AMonitoring and Reporting Radioactivity in Releases of Radioactive Materials in

- Liquid and Gaseous Effluents from Nuclear Fuel Processing and Fabrication Plants

and Uranium Hexafluoride Production Plants." This guide describes a method

acceptable to the NRC for submitting semiannual reports that specify the quantity of

each principal radionuclide released to unrestricted areas to estimate the maximum

-__ _ * potential annual dose to the public resulting from effluent releases.

Notes:

'NRC, 1985.

2 NRC, 1979.

Compliance with Title 10, "Energy,"of the U.S. Code ofFederal Regulations (10 CFR) §20.1301 would

be demonstrated using a calculation of the total effective dose equivalent to the individual who would

likely receive the highest dose in accordance with 10 CFR § 20.1302(b)(1). Regulatory Guide 1.109,

"Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of

Evaluating Compliance with 10 CFR Part 50, Appendix I" describes the methodology for determining the

total effective dose equivalent to the maximum exposed individual (NRC, 1977). Administrative action

levels would be established for air emissions and Wastewater effluent samples and monitoring

instrumentation based on normal background radionuclide concentrations, existing administrative limits,

and regulatory limits.

6-1
1

2

3

4

5

6

18

9

10

21

122

13

14

1 9

21

122

23

24

Table 6-2 provides a summary of the environmental measurement and monitoring program sampling

locations, parameters, and frequency proposed for the ACP.

Table 6-2 Radiological Environmental Measurement and Monitoring Program

Sampling Locations, Parameters, and Frequency

Media | Sampling Locations Parameters Frequency

Surface Water 2 RW-2, RW-3, RW-5, RW-7, RW-12, . Total uranium, technicium-99, . Monthly

RW-13, RW-33, RW-ION, RW-IOS, . gross alpha/beta

RW-lOE,RW-lOW

*RW-i, RW-6, RW-8 . Total uranium, technicium-99, I Weekly

* gross alpha/beta, fluoride

phosphorous-total.. -. _. ____.-..-. -- .-..... -.. _

Sediments RM-6, RM-1, RM-12, RM-1 1, RM-7, I Metals (Al, Sb, As, Ba, Be, Cd, I Semi-annually

RM-8, RM-5, RM-13, RM-33, RM-3, Ca, Cr, Cu, Fe, Pb, Mg, Mn,

RM-2, RM-9, RM-I0, RM-ION, RM- . Ni, K, Se, Si, TI, Zn), Hg, Ag,

1.OE, RM-IOS, RM-1OW . PCBs, total uranium,

technicium-99, gross alpha/beta ._._...... -- -. -..... .... _.__...__......

Soils (RIS-1, 3, 5, 12, 15, 17, 19,22,25,26, Total uranium, technicium-99, Semi-annually

32, 33,34, 35,36) (SAS-1, 2, 3,4, 6, 8, gross alpha/beta

9,10,11,12,13,14,15,16,17,18,19,

. 20,21,22,23,24,25,26,27,28,29)

(RS-ION, 10S, IOE, lOW) *...... *.... ..... .. ...... .. ... . . ....... ....... . ......

Vegetation (RIV-1, 3, 5, 12, 15, 17, 19, 22,25,26, Total uranium, technicium-99, Semi-annually

. 32, 33, 34, 35, 36) (SAV-1, 2, 3, 4, 6, gross alpha (if total uranium

8, 9, 10, 11, 12,13, 14,15, 16, 17, 18, >0.1 ug/g), fluoride, gross

19, 20, 21, 22,23,24,25,26, 27, 28, alpha/beta

. 29) (RV-ION, IOS, IOE, IOW) _ ______.............. ..... ;..... _._ .... -. -.. __ -. - --------------- . ....... ....... _._....... ..... ____ _ _. ................ .. _ __ ....

Biota (fish) RW-1, RW-2, RW-6, RW-8 Total uranium, technicium-99, Annually

* gross alpha/beta, PCBs and Cr I _~~~~~~~~~~~~~~._... .. ___.....*......._._....._._....._._._.................. .. _........d. ...... ___.....____._.............___.____... ... ___

Wildlife (deer) I Onsite . Total uranium, technicium-99, :i Annually

I gross alpha/beta, fluoride,

PCBs (fat, fetus) ..................... __...____._... . ...... ...... .....

Crops . 5 to 6 locations I Total uranium, technicium-99, . Annually

gross alpha (if total uranium

>0.1 ug/g)

Notes:

ug/g = micrograms per gram.

Source: USEC, 2005.

Sampling and monitoring for radiological air emissions and ambient air quality are described in sections

6.1.1 and 6.1.2. Sampling and monitoring for radiological wastewater emissions and surface water and

sediment are described in sections 6.1.3 and 6.1.4. Groundwater monitoring (conducted by the U.S.

Department of Energy (DOE)), soils and vegetation sampling, and direct radiation monitoring are

described in sections 6.1.5, 6.1.6, and 6.1.7, and laboratory standards for the monitoring and measurement

program are described in Section 6.1.8.

6-2
1 6.1.1 Air Emissions Monitoring

2

3 Potentially radioactive airborne releases from the proposed ACP would be discharged through monitored

4 discharge points, including:

5

6 * X-3346 Feed and Customer Services Building;'

7 * X-3001 and X-3002 Process Buildings;

8 * X-3356 Product and Tails Withdrawal Building;'

9 * X-3012 Process Support Building;

10 * X-7725 Recycle/Assembly Facility;

11 * X-7726 Centrifuge Training and Test Facility; and

12 * X-7727H Interplant Transfer Corridor.

13

14 Airborne release monitoring procedures for these sources would be designed in a manner to determine the

15 quantities and concentrations of radionuclides discharged to the environment, in accordance with 10 CFR

16 Part 70. Uranium isotopes anticipated to be released as airborne emissions would include uranium-234,

17 uranium-235, uranium-236,and uranium-238. Specific compounds would include depleted hexavalent

18 chromium, triuranium octaoxide (U308) and uranyl fluoride (UF2). Ventilation air emissions from the

19 process buildings'would be monitored under the Radiation Protection Program. Environmental -

20 Compliance personnel would review summaries of the monitoring data at least quarterly to verify that

21 ventilation exhausts are insignificant as defined in NUREG-1 520, Standard Review Plan for the Review

22 of a License Applicationfor a Fuel Cycle Facility, i.e., less than 1.1 x 104 becquerels per milliliter (3 x

23 1i-'3 microcuries per milliliter) uranium (NRC, 2002).

24

25 Vent samples (i.e., activated alumina) would be analyzed for uranium isotopes (uranium-234, uranium26 235, and uranium-238) and technicium-99. Uranium isotope concentrations are determined using either

27 alpha spectrometry or inductively coupled plasma/mass spectrometry. Technetium concentfations'would

28 be determined using liquid scintillation counting. Analytical results wbuld be reported in micrograms of

29 analyte per gram of alumina. These results would then be converted to grams released using recorded

30 flow data and the measured weight of alumina in the sampler and to activity using published specific

31 activities for individual isotopes. Gaseous effluents equivalent to an annual public dose of less than 1.0 x

32 I0' sievert (0.1 millirem) are anticipated. Since the airborne concentrations in 10 CFR Part 20,

33 Appendix B, Table 2 are equivalent to an annual dose of 0.0005 sievert (50 'millirem), the minimum

34 detectible activity of these methods would be equivalent t6 less than 0.2 percent of the 10 CFR Part 20,

35 Appendix B, Table 2 values. -

36

37 Airborne release monitoring for proposed ACP air emissions sources would include the following.

38 buildings:

39

40 X-3346 Feed and Customer Services Building

41

42 The Feed Area of this building sublimes uranium hexafluoride (UF6) for feed to the enrichment process,

43 and contains a variety of potential sources for radioactive'air emissions, both as gaseous UF6 and

44 particulate uranyl fluoride. These sources would be vented to the atmosphere through an evacuation

45 system, which has separate sub-systems to control gaseous and airborne particulate emissions.? Both sub46 systems exhaust to a continuously monitored combined vent. -The Customer Services Area of this

47 building would liquefy UF6 for quality control sampling and transfer of UF6 material to customer

48 cylinders for shipment.: This area also would contain multiple potential sources for radioactive air

49 emissions, both as gaseous UF6 and particulate UF2.- These emissions sources would vent through a

50 similar evacuation system with another continuously monitored combined vent. Each vent would be

51 equipped with continuous gas flow monitoring instrumentation with local readout as well as the analytical

6-3
I instrumentation required to continuously sample, monitor, and to alarm UF6 breakthrough in the vent gas

2 stream.

3

4 X-3001 and X-3002 Process Buildings

5

6 The X-3001 and X-3002 process buildings would house the operating centrifuge machines that separate

7 the UF6 into enriched product and depleted tails, and contain a limited variety of potential sources for

8 radioactive air emissions, primarily as gaseous UF6. These sources would be vented to the atmosphere

9 through either the purge vacuum or evacuation vacuum systems, discharged through the X-3001 process

10 vent. Both systems would exhaust to a common continuously monitored vent. Each process building

11 vent would be equipped with continuous gas flow monitoring instrumentation with local readout, as well

12 as analytical instrumentation to continuously sample, monitor, and alarm UF6 breakthrough in the vent gas

13 stream.

14

15 A continuous vent sampler using alumina media would be used to monitor the purge vacuum and

16 evacuation vacuum system vents for UF6. Weekly primary sample traps would be analyzed for uranium17 234, uranium-235, uranium-238, and technetium-99. A secondary trap would be replaced quarterly.

18 USEC does not expect to detect technetium-99 in the proposed ACP, but all vent samplers at the

19 Portsmouth Gaseous Diffusion Plant, including those to be used at the proposed ACP, would be analyzed

20 for technetium-99. Uranium isotope concentrations would be determined using either alpha spectroscopy

21 or inductively coupled plasma/mass spectrometry, with minimum detectable activity of less than 0.2

22 percent of the 10 CFR 20, Appendix B, Table 2, values. A representative sample of air effluent would be

23 collected using an isokinetic probe and monitoring of both vent and sampler air flows.

24

25 X-3356 Product and Tails Withdrawal Building

26

27 The X-3356 building would withdraw and desublime both the product and tail streams from the

28 enrichment process, and would contain a variety of potential sources for radioactive air emissions, both as

29 gaseous UP6 and particulate uranyl fluoride. These sources would be vented to the atmosphere through

30 evacuation systems similar to the X-3346 building. There would be separate evacuation systems, with

31 separate monitored vents, for the tails withdrawal and the product withdrawal areas. The effluents from

* 32 both sub-systems would be combined and vented to the atmosphere through a common vent after each

33 sub-system has removed the uranium. Each vent would be equipped with continuous gas flow monitoring

34 instrumentation with local readout as well as the analytical instrumentation required to continuously

35 sample, monitor and to alarm UF6 breakthrough in the vent gas stream.

36

37 X-3012 Process Support Building

38

39 The X-3012 building provides process control functions and maintenance support. Contaminated

40 components may be serviced in the maintenance shops in the X-3012 building.: Components requiring

41 repair or examination that have been in service will be opened using appropriate personnel protective

42 equipment, and may also include engineered local ventilation systems to capture any residual uranium

43 ventilation air in the X-3012 building would be monitored under the Radiation Protection Program.

44

45 X-7725 Recycle/Assembly Facility: X-7726 Centrifuge Training and Test Facility: and

46 X-7727H Interylant Transfer Corridor

47

48 Centrifuges would be assembled and may be disassembled for repair or inspection in either the X-7725 or

49 X-7726 facilities. Assembled equipment may be tested in Gas Test Stands. Exhaust from the test stands

50 would pass through alumina traps to a continuously monitored vent. The vent would be equipped with

51 continuous gas flow monitoring instrumentation with local readout, as well as the analytical

64

Il
I instrumentation required to continuously sample, monitor, and to alarm UF6 breakthrough in the vent gas

2 stream. Ventilation air in both the X-7725 and X-7726 facilities would be monitored under a Radiation

3 Protection Program.

4

5 Fugitive emissions from the X-7726 static stand would be captured by local ventilation systems. USEC

6 does not expect measurable emissions from the X-7726 static stand as a result of opening centrifuges that

7 have operated on UF6 gas.

8

9 6.1.2 Ambient Air Quality Monitoring

10

11 Between 1980 and 2002, annual gaseous uranium air emissions from the Portsmouth Gaseous Diffusion

12 Plant ranged between 3.59 x 10"and 1.9 x I0O becquerel per year (0.97 and 0.005 curies per year).

13 Ambient air samples collected over this period by the Portsmouth Gaseous Diffusion Plant operators

14 showed that these levels of air emissions do not produce a quantifiable difference in ambient air

15 concentrations in unrestricted areas. Facility operations at the proposed ACP are not expected to exceed

16 the levels of gaseous uranium air emissions monitored for the Portsmouth Gaseous Diffusion Plant

17 between 1980 and 2002 (USEC, 2005).

18

19 In addition, experience at the Portsmouth Gaseous Diffusion Plant has shown that any unplanned air

20 emissions release of uranium large enough to produce high or intermediate consequences to human health

21 or the environment would first produce a large and very visible cloud of white smoke at the point of

22 release. USEC has written a procedure for the proposed ACP for dealing with unplanned releases that

23 includes immediate reporting of observed releases to the shift manager and evaluation by the

24 environmental professionals of available information concerning potential consequences of the release

25 (USEC, 2005). This approach is consistent with the guidance in NUREG-1520 (NRC, 2002). Ambient

26 air quality impacts of proposed ACP facility operations, including action levels, will be based on gaseous

27 air emissions monitoring of process vent emissions and other information and atmospheric dispersion

28 modeling.

29

30 The United States Enrichment Corporation ceased sampling ambient air and returned the Portsmouth

31 -Gaseous Diffusion Plant's network of permanent air samplers to DOE in 1999, which upgraded the

32 samplers for DOE use for ambient air quality monitoring. Based on the DOE annual environmental

33 reports published since 1999, average airborne uranium concentrations have been 1.1 x 1 0-15 micrograms

34 per milliliter (1.5 x 10-19 ounces per gallon) onsite (i.e., within the DOE reservation), 7.4 x 10-X6

35 micrograms per milliliter (9.9 x 10" ounces per gallon) in unrestricted areas offsite, and 5.5 x 10-.6

36 micrograms per milliliter (7.4 x 10-2° ounces per gallon) at the DOE background station (USEC, 2005).

37 These results are a minimum of three orders of magnitude less than the applicable discharge limits for

38 uranium isotopes in 10 CFR Part 20, Appendix B. Therefore, USEC does not anticipate conducting any

39 ambient air quality monitoring in addition to that conducted by DOE and reported in DOE annual

40 environmental reports.

41

42 The United States Enrichment Corporation maintains a meteorological tower that is located on the

43 southern section of the DOE reservation. The tower is equipped with instruments at the ground, 10-, 30-,

44 and 60-meter (32.8-, 98.4-, and 196.9-foot) levels. Among the parameters measured are air temperature,

45 wind speed, wind direction, relative humidity, solar radiation, barometric pressure, precipitation, and soil

46 temperature. Data from the National Weather Service or other local sources may be used in lieu of, or to

47 supplement, onsite data. The air emissions source monitoring data and meteorological data would be used

48 to calculate the environmental impacts of airborne emissions from the proposed ACP using U.S. EPA49 approved dispersion models.

6-5
I I

1 6.1.3 Wastewater and Stormwater Discharge Monitoring

2

3 There are four principal potential sources of radioactivity discharges to surface water from the proposed

4 ACP facility operations, including: (1) the X-6619 Sewage Treatment Plant identified as permitted outfall

5 003; (2) the Portsmouth Gaseous Diffusion Plant Recirculating Cooling Water System identified as:

6 permitted outfall 004; (3) the X-2230N West Holding Pond identified as permitted outfall 012; and (4) the

7 X-2230M Southwest Holding Pond identified as permitted outfall 013 (see Figure 6-1). The X-2230M

8 and X-2230N holding pond discharges would be equipped with automated samplers and continuous flow

9 measurement. The combined discharge of the recirculating cooling water system, the DOE reservation

10 sewage treatment plant discharge, and other reservation holding ponds would be also equipped with

11 automated samplers and continuous flow measurement. Outfalls with intermittent flows would be

12 monitored with grab samplers during periods of outfall flow. Water samples from the permitted outfalls

13 would be analyzed for gross alpha and gross beta activity, technetium beta activity, and total uranium

14 concentration. The gross activities would be determined by proportional counter and the technetium

15 activity by liquid scintillation.

16

17 The minimum detectable activities for water samples are 1.85 x 104 becquerels per milliliter (5 x 10'

18 microcuries per milliliter) for gross alpha, 5.55 x 10' becquerels per milliliter (1.5 x 10' microcuries per

19 milliliter) for gross beta, 7.4 x 10' becquerels per milliliter (2 x 10'8 microcuries per milliliter) for

20 technetium beta. The total uranium concentration would be determined by inductively coupled

21 plasma/mass spectrometry, with a minimum detectable concentration of 0.001 micrograms per milliliter

22 (1.35 x 10-7 ounces per gallon). The isotopic distribution of the total uranium would be estimated to

23 match the calculated uranium alpha activity to the measured gross alpha activity. The values for liquid

24 releases are .0111 becquerels per milliliter (3 x 10- microcuries per milliliter) for each of the uranium

25 isotopes and 2.22 becquerels per milliliter (6 x 10' microcuries per milliliter) for technetium.

26 Consequently, the Minimum Detectable Activities for liquid effluents would be less than two percent of

27 the applicable 10 CFR Part 20, Appendix B, Table 2 values.

28

29 The only underground tanks at the proposed ACP used to collect material that might contain

30 radionuclides are the liquid effluent control underground tanks located south of the X-3001 Process

31 Building. The liquid effluent control system consists of a set of drains and collection tanks primarily for

32 collecting leaks and spills of chemically treated water. The drains are located throughout the process

33 buildings. The tanks have a capacity of 2,082 liters (550 gallons) each. Liquid level gauges mounted

34 above grade on pipe stands monitor the tanks. Routine monitoring of the tanks' contents would be based

35 on observing and tracking the levels indicated on the gauges. USEC would use level gauges to detect any

36 unplanned releases to groundwater or soil from the liquid effluent control system inventory tracking

37 would be relied on to indicate any leaks from the tanks. The contents of the liquid effluent control system

38 will be sampled and analyzed for the same parameters as the continuous permitted outfalls prior to

39 disposal.

6-6
Figure 6-1 United States Enrichment Corporation National Pollutant

Discharge Elimination System Outfalls at the DOE Reservation at Piketon (USEC, 2005)

1 6.1.4 Surface Water and Sediment Monitoring

2

3 Between 1980 and 2002, annual radiological wastewater discharges to surface water from the Portsmouth

4 Gaseous Diffusion Plant have ranged between 2.63 x 1010 and 9.92 x lO' becquerel per year (0.71 and

5 0.026 curies per year) (USEC, 2005). Surface water samples collected over this period by Portsmouth

6 Gaseous Diffusion Plant operators show that these levels of wastewater discharges do not produce a

7 statistically significant difference in radionuclide concentrations in the Scioto River (USEC, 2005).

8 Facility operations at the proposed ACP are not expected to exceed the levels of wastewater discharge

9 monitored for the Portsmouth Gaseous Diffusion Plant between 1980 and 2002. Impacts to local

10 receiving waters from proposed ACP facility operation wastewater discharges, including action levels,

11 will be based on discharge monitoring (described above) and pathways modeling.

12

13 United States Enrichment Corporation maintains a surface water monitoring program designed to assess

14 the impacts to local receiving waters of wastewater discharges from DOE environmental remediation

15 projects or historical contamination. Radiological analyses would be performed on grab samples from

16 upstream and downstream locations in Little Beaver Creek, Big Beaver Creek, Big Run Creek, and the

17 Scioto River (see Figure 6-2). Surface water samples would be collected weekly from the Scioto River

18 and one location (RW8) in Little Beaver Creek. Other locations would be sampled monthly.

6-7
I I

1 Analysis of sediment samples collected between 1980 and 2002 by Portsmouth Gaseous Diffusion Plant

2 operators show that wastewater and stormwater discharges do not produce a statistically significant

3 difference in sediment radionuclide concentrations in the Scioto River (USEC, 2005). Impacts of facility

4 operations at the proposed ACP on sediment radionuclide concentrations in local receiving waters,

5 including action levels, will be based on wastewater discharge monitoring pathways modeling.

Locations of Routine Surface Water Sampling Points

Figure 6-2 Locations of Routine Surface Water

Sampling Locations (USEC, 2005)

6 Sediment sampling around the site would be conducted semiannually to assess potential radionuclide

7 accumulation in the surrounding receiving streams. The sediment sampling locations include both

8 upstream and downstream locations. Sample locations are described in Figure 6-3. Sediment sample

9 analyses include gross alpha activity, gross beta activity, technetium beta activity, and total uranium

10 concentration.

6-8
Locations of Stream Sediment Sampling Points.

Figure 6-3 Locations of Stream Sediment Sampling

Points (USEC, 2005)

1 6.1.5 Groundwater Monitoring -

2

3 Due to historical operations, the DOE reservation has multiple plumes of groundwater contamination.

4 The primary contaminant in the plumes is the halogenated solvent trichloroethylene, but limited areas of

5 technetium contamination also exist. DOE is conducting groundwater monitoring as part of a site-wide

6 environmental remediation program under an Agreed Order with the State of Ohio (USEC, 2005).

7

8 Groundwater monitoring data are reported as part of DOE's Annual Environmental Report for the DOE

9 reservation. All groundwater monitoring conducted on the site is under the control of the DOE. United

10 States Enrichment Corporation does not conduct a separate groundwater monitoring program.

12 6.1.6 Soil and Vegetation (Biota) Sampling

13

14 Between 1980 and 2002, annual uranium air emissions from the Portsmouth Gaseous Diffusion Plant

15 have ranged between 3.59 x 10 and 1.85 x 10 becquerel per year (0.97 and 0.005 curies per year)

16 (USEC, 2005). Soil and vegetation samples collected over this period by Portsmouth Gaseous Diffusion

17 Plant operators show that these levels of air emissions do not produce a statistically significant difference

18 in soil and vegetation concentrations in unrestricted areas. Wastewater and stormwater discharges from

6-9
I.

I the DOE reservation do not have a direct impact on soil and terrestrial vegetation around the DOE

2 reservation. Facility Operations at the proposed ACP are not expected to exceed the levels of air

3 emissions measured between 1980 and 2002. Therefore, impacts to soil and vegetation from ACP facility

4 operation, including action levels, will be based on air emissions monitoring and atmospheric dispersion

5 modeling.

6

7 United States Enrichment Corporation maintains a soil and vegetation monitoring program to assess the

8 long-term impacts of air emissions from proposed ACP facility operations and from DOE environmental

9 remediation projects, and to assess the impact of a high or intermediate consequence release that has

10 already been detected and controlled (USEC, 2005). Soil and vegetation (wide-blade grass, typical of

11 local cattle forage) samples would be collected semiannually. The sampling networks completely

12 surround the DOE reservation, including the predominant downwind directions, and would be

13 administratively divided into onsite, off-reservation (up to 5 kilometers [3.1 miles]) and remote (5 to 16

14 kilometers [3.1 to 10 miles] off-reservation). Figure 6-4 describes the sampling locations. Soil samples

15 would be analyzed for gross alpha activity, gross beta activity, technetium beta activity, and total uranium

16 concentration. Vegetation samples would be analyzed for technetium beta activity and total uranium

1 7 concentration.

Figure 64 Locations of Soil and Vegetation Sampling

Points (USEC, 2005)

18

6-10

II
I In addition to the semiannual vegetation samples, United States Enrichment Corporation also collects

2 annual crop samples from local gardeners and farmers on a voluntary basis. Because of the voluntary

3 nature of these samples, the sampling locations change from year to year. Crop samples would normally

4 be analyzed for technetium beta activity and total uranium concentration only. The analytical methods

5 would be the same as for the vegetation samples.

6

7 6.1.7 Direct Gamma Radiation Monitoring

8

9 The only significant sources of environmental gamma radiation on site are the uranium isotope uranium10 235 and the short-lived uranium-238 daughters; There would be small amounts of other gamma emitters

11 present on site as sealed sources and laboratory standards, but direct radiation from these sources would

12 benot detectable at any significant distance from the sources. Gamma radiation levels in unrestricted

13 areas around the proposed ACP are dominated by naturally occurring radioactive materials.

14

15 United States Enrichment Corporation conducts external gamma radiation monitoring consisting of

16 lithium fluoride thermoluminescence dosimeters positioned at various site locations and at locations off17 reservation. There are nine dosimeters spaced around the perimeter of the limited area of the DOE

18 reservation including cylinder storage areas-; eight dosimeters spaced around the DOE reservation

19 boundary; and two dosimeters located off-reservation. These dosimeters are collected and analyzed

20 quarterly. Processing and evaluation are performed by a processor holding current accreditation from the

21 National Voluntary Laboratory Accreditation Program of the National Institute of Standards and

22 Technology.

23

24 6.1.8 Laboratory Standards

25

26 A National Voluntary Laboratory Accreditation Program-certified vendor processes the environmental

27 thermoluminescence dosimeters. A laboratory licensed by the NRC or an Agreement State provides other

28 radiological and chemical analyses for the monitoring and measurement program. The following

29 description is based on current services provided by the onsite X-710 building laboratory, which is

30 licensed by the State of Ohio and certified by the NRC, but is not part of the proposed ACP or operated

31 by USEC. Off-reservation vendors providing analytical services for the proposed ACP will be required to

32 meet the equivalent standards as part of the contract.

33

34 Environmental samples would be analyzed for gross activities by proportional counter and technetium

35 activity by liquid scintillation. To accommodate a data sharing agreement with DOE, uranium

36 concentrations in environmental samples would be determined by alpha spectrometry. The minimum

37 detectable activities/concentrations would be comparable to those for effluent samples.

38

39 Laboratory quality control includes the use of a dedicated Chain of Custody system, formal written

40 procedures, National Institute of Standards and Technology-traceable standards, matrix spikes, duplicate,

41 and replicate samples, check samples, and blind and double-blind quality control samples.

42

43 Any laboratory providing analytical services to the proposed ACP will be required to participate in at

44 least one laboratory intercomparison program covering each type of analysis contracted for.

45 Intercomparison programs that the X-7 10 building laboratory currently participates in include:

46

47 * U.S. EPA Discharge Monitoring Report Study;

48 * National Institute of Occupational Safety and Health Proficiency Analytical Testing Program;

49 * U.S. EPA Water Pollution Performance Evaluation Study;

50 * U.S. EPA Water Supply Study;

6-11
I * National Institute of Occupational Safety and Health Environmental Lead Proficiency Analytical

2 Testing Program;

3 * Proficiency Environmental Testing program, a commercial program sponsored by the Analytical

4 Products Department of Belpre, Ohio;

5 * DOE Environmental Measurements Laboratory Radionuclide Quality Assessment Program; and

6 * DOE's Mixed Analyte Performance Evaluation Program.

7

8 6.2 Nonradiological Measurements and Monitoring Program

9

10 As discussed in this chapter and summarized in Chapter 4, nonradiological impacts to the environment

11 from the construction and operation of the proposed ACP are expected to be minimal. Consequently,

12 non-radiological environmental monitoring prescribed through the various environmental permits for the

13 construction and operation of the proposed ACP are expected to be sufficient to evaluate any

14 nonradiological environmental impacts.

1 5

16 6.3 References

17

18 (NRC, 1985) U.S. Nuclear Regulatory Commission. "Monitoring and Reporting Radioactivity in

19 Releases of Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel Processing and

20 Fabrication Plants and Uranium Hexafluoride Production Plants." Regulatory Guide 4.16, Revision 1,

21 1985.

22

23 (NRC, 1979) U.S. Nuclear Regulatory Commission. "Quality Assurance for Radiological Monitoring

24 Programs (Normal Operations) - Effluent Streams and the Environment." Regulatory Guide 4.15,

25 Revision 1, 1979.

26

27 (NRC, 1977) U.S. Nuclear Regulatory Commission. "Calculation of Annual Doses to Man from Routine

28 Releases of Reactor Effluents for the Purposes of Evaluating Compliance with 10 CFR Part 50, Appendix

29 I." Regulatory Guide 1.109, Revision 1, ML 003740384, October 1977.

30

31 (NRC, 2002) U.S. Nuclear Regulatory Commission. NUREG-1520, "Standard Review Plan for the

32 Review of a License Application for a Fuel Cycle Facility." May 2002.

33

34 (USEC, 2005) United States Enrichment Corporation. "Environmental Report for the American

35 Centrifuge Plant in Piketon, Ohio." Revision 3. Docket No. 70-7004. July 2005.

6-12
1 7. COST BENEFIT ANALYSIS

2 -

3 The potential environmental impacts of constructing and operating the proposed ACP at Piketon, Ohio are

4 discussed in Chapter 4 of this Draft EIS. This chapter summarizes those impacts alcing with other costs

5 -and benefits associated with the proposed action and the no-action altemative. The economic costs and

6 benefits provided by USEC in its License Application and Environmental Report are presented and

7 supplemented as necessary with additional assessments by the NRC staff.

8

9 Cost benefit analysis, also known as value impact analysis, provides a rationale for deciding whether an

10 industrial project is likely to have a net positive economic impact by aggregating each of the costs and

11 benefits resulting from the project. Cost benefit analysis may be used to compare alternative processes

12 for achieving the same goals and for developing an objective rationale for choosing between competing

13 ' processes'? Cost benefit analysis involves valuing the benefits and negative impacts associated with a

14 project in monetary terms, to the extent possible. The project with the highest net present value'in

15 discounted dollar terms is usually considered the best option. Alternatively, cost benefit analyses may

16 rely entirely or partially on qualitative or ordinal scales to rate impacts and values for each attribute or

17 impact area of concern (i.e., data can be ranked). Different weights may then be assigned to various

18 attributes or impact areas consistent with stakeholder preferences to determine the optimal project

19 alternative., The methodology employed for a cost benefit analysis usually depends on the specific issues

20 involved inma project..

21

22 To support the NRC's decisionmaking this chapter compares costs and benefits both quantitatively, in

23 monetary terms, and qualitatively. Section 7.1 weighs the costs and benefits associated with the proposed

24 action. Section 7.2 then compares the costs and benefits for the proposed action relative'to those of the

25 no-action alternative. Section 7.3 combines these other two sections into overall conclusions. All of

26 these sections draw heavily on the impacts discussion in Chapter 4 of this Draft EIS and in particular the

27 socioeconomic impact analyses in Sections 4.2.10 and 4.4.10. Altematives that have previously been

28 ruled out for failing to meet the project's technical and policy objectives are described in Section 2.2.4 and

29 are not revisited in this chapter.

30

31 7.1 Costs and Benefits of the Proposed Action

32

33 This section describes the costs and benefits of each life-cycle stage of the proposed action. Quantitative

34 estimates (in terms of dollars) are provided where possible. Other costs and benefits are described in

35 qualitative terms.

36

37 7.1.1 Costs of the Proposed Action

38

39 The direct costs associated with the proposed action may be categorized by the following life-cycle

40 stages.

41

42 * Site preparation and construction (including refurbishment of existing facilities);

43 * Centrifuge manufacturing and equipment assembly;

44 * Facility operation; and

45 * Decontamination and decommissioning.

46

47 Table 7-1 presents the direct costs associated with each of these life-cycle stages. Pursuant to 10 CFR

48 2.390, the cost associated with facility operation is withheld.

7-1
1

2

3

4

5

6

7

8

9

10

l 1

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

Table 7-1 Direct Costs Associated with Proposed Action Life-cycle Stages

Life-cycle Stage of the Proposed Action Cost

Site preparation and construction $1.449 billion (nominal dollars') between calendar years 2006

* and 2010 . -.--...--...- . .. . .. ..... _ ........ _._...........--. _ .....

Centrifuge manufacture and equipment * $1.423 billion (nominal dollars) between calendar years 2004

assembly * and 2013 __~~~~~~ ... __._._._ . ...... _ ... _. _ . ...._._. _............. _ .................. _..___

Facility operation I Costs accrue between calendar years 2010 and 2040; see

. Appendix G for costs . -.-.-.----....-.-. - . . -..-..... - ._._.- -- ....... ... . ...-.....-- -* - .

Decontamination and decommissioning . $435 million (2004S) between calendar years 2040 and 2045

Notes:

'Nominal dollars are not adjusted for inflation.

I Dollars stated in year 2004 price levels.

Source: USEC, 2005a.

The proposed action would also result in indirect costs to the economy. The socioeconomic impacts in

the region of influence would include impacts to area housing resources, community and social services,

and public utilities. As a result of the proposed action, the population in the region of influence is

expected to grow. With this population growth, there would be an expected increased demand for

housing, school populations may grow, and demand may increase for community services like fire

protection, law enforcement, and healthcare. As discussed in Section 4.2.10, these impacts are estimated

to be small.

Finally, the proposed action would result in impacts to various resource areas, which can also be

considered "costs" for the purpose of this analysis. The resource areas and corresponding impacts are

summarized below and described in more detail in Chapter 4 of this Draft EIS. The impact of the

proposed action is estimated to be small for all resource areas except air quality and transportation, which

may have small to moderate impacts.

* Land use - The impact of the proposed action on land use and values is expected to be small. Site

preparation and construction activities would occur on approximately 22 hectares (55 acres) of land,

which comprises about I percent of the total 1,500 hectare (3,700 acre)- DOE reservation. The

changes would occur on previously disturbed land that is not considered prime farmland, and would

be consistent with current land use.

* Historical and cultural resources - The impact of the proposed action on historical and cultural

resources is expected to be small. There would be no adverse indirect or direct effect on the 14 sites

potentially eligible for the National Register of Historic Places within the area of potential effect of

the project. Also, construction of new buildings and refurbishment of existing buildings would result

in buildings of design, size, and function similar to the existing buildings, and therefore would not

alter the historic setting of the existing Gaseous Diffusion Plant.

* Visual and scenic resources - The impact of the proposed action on visual and scenic resources is

expected to be small. The Bureau of Land Management Visual Resources Management rating system

classifies the proposed ACP site as Class III or IV, meaning it has moderate to little scenic value.

Construction of the ACP would not alter the site's classification. No scenic rivers, nature preserves,

or unique visual resources exist in the project area.

7-2
I * Air quality - The impact of the proposed action on air quality is expected to be small to moderate.

2 Airborne emissions from site preparation and construction should not result in exceedances of air

3 quality standards, with the possible exception of short-term increases in particulate matter.

4 Radiological releases from soil disturbances and decommissioning of the Gas Centrifuge Enrichment

5 Plant would be small and controlled. Emissions from diesel generators would not cause air quality

6 problems and maximum predicted concentrations of hydrogen fluoride resulting from ACP operations

7 are below safe levels. Based on the maximum radiological emission rates for the ACP and the

8 'comprehensive site monitoring program, the expected impact to air quality from the plant's

9 radiological emissions is also expected to be small.

10

11 * 'Geology and soils - The impact of the proposed action on site geology and soils is expected to be

12 small. Most of the site is an existing industrial facility with altered natural soils. The soils are

13 cohesive and over-consolidated and have low potential for liquefaction. There is little likelihood of

14 impact from soil compaction or subsidence. The flat terrain where the ACP buildings would be

15 located, and the dense soil, low moisture content, and vegetative cover in the area of a new large

16 cylinder storage yard (X-745H) make landslides unlikely. Construction activities would not alter

17 current drainage and would not disturb any soils that qualify for protection as prime farmland. There

18 would be a potential for increased erosion and siltation of streams near the construction site of the

19 new large cylinder storage yard, but both of these potential impacts should be minimized by the use

20 of standard best management practices;'

21

22 * 'Water resources - The impact of the proposed action on local water resources is expected to be

23 small. Potential stream sedimentation from construction activities would be minimized by the use of

24 silt fences and other best management practices. Any impacts to stream water quality would be of

25 short duration. None of the proposed site preparation and construction activities would occur within a':

26 100-year floodplain. Groundwater withdrawals would increase by 10 percent over current usage

27 rates, but would still be only 31 percent of the total design capacity of the site's well fields, would not

28 'affect groundwater availability, and would not pose an increased risk of subsidence. Wastewater

29 would continue to discharge 'from permitted NPDES outfalls and discharge rates, though increased

30 above current levels, would represent only 75 percent of the existing system's design capacity.

31 USEC does not anticipate any liquid discharges of radioactive materials from the proposed ACP (i.e.,

32 from cooling water, storm water runoff, or sanitary water). The potential for leaks or spills that could

33 contaminate water resources would be limited by an approved Spill Prevention Control and

34 Countermeasures Plan.-

35

36 * Ecological resources - The impact of the proposed action on ecological resources is expected to be

37 small. Construction of the X-745H Cylinder Storage Yard would result in increased erosion,

38 stormwater runoff, and loss of 24 acres of vegetation, but would result in small impacts to the flora

39 and fauna in and around the tributaries of Little Beaver Creek. -That same cylirider storage yard

40 would also be located within 500 meters of suitable summer habitat for the endangered Indiana bat,

41 although studies have not documented the presence of this bat species on the DOE reservation. None

42 - of the site construction activities would occur in 'wetlands. However, some' construction would occur

43 adjacent to small wetlands, and standard erosion control measures would be used to limit

44 sedimentation in these areas.

45

46 * Environmental justice - Within an 80-km (50-mile) radius around the proposed ACP site, there are

47 18 Census tracts that have populations qualifying as low-income and two Census tracts that have

48 populations qualifying as minority. The closest of these tracts is 28 km (17 miles) from the proposed

49 site. The proposed action would not result in disproportionately high or adverse impacts to any of

50 these populations.

7-3
I * Noise - Estimated construction noise levels at the site are below acceptable guidelines. No adverse

2 noise impacts from ACP operations are expected at the closest residence due to low operational noise,

3 the attenuation provided by the building fagade, and distance attenuation of over 900 meters (3,000

4 feet). For these reasons, noise impacts are expected to be small.

5

6 * Transportation - Increased truck and vehicle traffic should result in small changes in current levels

7 of congestion and delays on U.S. Route 23 and Ohio State Road 32, small increases in the number of

8 traffic accidents resulting in injuries or fatalities, and small increases in vehicle emissions that should

9 not degrade local air quality. Radiation exposures resulting from the planned shipments of

10 radioactive materials are estimated to cause 0.02 latent cancer fatalities per year of operation or about

11 one cancer fatality over thirty years of operation. The probability of a severe transportation accident

12 that releases sufficient quantities of UP6 that could pose a health risk is low, but the consequences of

13 such an accident, should it occur, are high. Weighing all of these considerations together, the

14 transportation impacts of the proposed action are expected to be small to moderate.

15

16 * Public and occupational health - The proposed action would result in small increases in the current

17 number of occupational injuries and illnesses at the site, though still less than historical levels.

18 Construction and process areas would be segregated, and personnel monitoring programs would be

19 implemented, to minimize worker exposures to annual radiation doses of less than the 10 CFR §

20 20.1201 limit of 50 millisieverts (5,000 millirem). All routine radiation exposures to members of the

21 public are expected to be significantly below the 10 CFR Part 20 regulatory limit of I millisievert

22 (100 millirem) and 40 CFR Part 190 regulatory limit of 0.25 millisieverts (25 millirem) for uranium

23 fuel-cycle facilities. Analytical results also indicate that plausible radiological accidents at the

24 proposed ACP pose acceptably low risks. In addition, public and occupational exposures to non25 radiological contaminants are projected to be less than applicable limits. Therefore, these impacts

26 associated with the proposed action are expected to be small.

27

28 * Waste management - Site preparation, construction, and operations would generate varying amounts

29 of low-level radioactive, low-level mixed, hazardous, sanitary/industrial, and recyclable wastes. All

30 of these wastes would be managed in accordance with existing procedures for controlling

31 contaminant releases and exposures. With the exception of the depleted uranium, all of the wastes

32 would also be generated at volumes that are well within existing management capacities. The ACP

33 would generate approximately 42,800 cylinders of depleted UF6, containing approximately 571,000

34 metric tons (630,000 tons) of material. All of this depleted UF6 could be converted to a more stable

35 form at the new DOE conversion facility at Piketon, which would require DOE to significantly extend,

36 the life of this facility. The converted material would then be shipped by rail to an acceptable western

37 disposal site, where sufficient capacity exists and where the disposal impacts should be small.

38

39 7.1.2 Benefits of the Proposed Action

40

41 The proposed action would result in the production of 3.5-7 million SWUs of enriched uranium between

42 2010 and 2040. As discussed in Section 1.3 of this Draft EIS, this level of production would represent an

43 augmentation of the domestic supply of enriched uranium and would meet the following needs:

44

45 * The need for enriched uranium to fulfill domestic electricity requirements and replace the shortfall in

46 supply created by the end of the Megatons-to-Megawatts program planned in 2013;

47

48 * The need for increased domestic supplies of enriched uranium for national energy security; and

49

50 * The need for upgraded uranium enrichment technology in the United States to replace the existing

51 aging and less efficient gaseous diffusion plants.

7-4

Il
I

I

I

I

I

I

I

I

I

I

I The proposed action would also result in small positive socioeconomic impacts in the region around

2 Piketon, as described in Section 4.2.10. Table 7-2 presents the employment and tax revenue benefits

3 associated with the proposed action. In each year between 2006 and 2010, average annual employment as

4 a result of site preparation, refurbishment, and construction activities is estimated at 3,362 full-time jobs.

5 In addition, state income tax revenues would increase by an estimated $2.3 million per year. State sales

6 tax receipts are estimated to increase by $3.7 million during site preparation and construction. Pike

7 County would also benefit from increased sales tax revenues. These revenues are estimated to increase

8 by $414,000.

9

10 During the ACP operations phase between 2010 and 2040, 1,500 jobs would be created in the region of

11 influence. The State would benefit from $1.8 million and $2.4 million in additional income and sales tax

12 receipts, respectively. Pike County would receive an estimated $263,000 in additional sales tax revenues.

13

14 The decontamination and decommissioning phase of the proposed action is expected to create a total of

15 841 annual, full-time jobs between 2040 and 2045, of which 407 would be new (the others would be

16 filled by transitioned USEC workers). The State would raise income and sales tax revenues by $576,000

17 and $932,000, respectively. Pike County's sales tax revenues would increase by an estimated $103,000.

18

19 Table 7-2 Socioeconomic Benefits Associated with the Proposed Action

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

Life-cycle Stage of the. Direct and Indirect State Income State Sales Tax Pike County Sales

Proposed Action Jobs Created Tax Revenues Revenues per Tax Revenues per

(Annual, Full-Time per Year Year Year

Jobs) -

Site preparation and . 3,362 * $2.3 million * $3.7 million $414,000

construction . - (2004$) (2004S) (2004S)

Facility operation 1,500 $1.8 million $2.4 million $263,000

(2013$) (2013S) (2013$)

Decontamination and 841 $576,000 $932,000 $103,000

decommissioning . (2004S) (2004$) (2004S)

Source: USEC, 2005a.

7.1.3 Conclusions Regarding the Proposed Action

This analysis demonstrates that there are significant economic and national energy benefits associated

with the proposed action. There are also employment benefits that would result in increases to State and

local tax revenues. In terms of costs, there are direct costs associated with the construction and operation

phases of the proposed action, as well as indirect costs resulting from impacts associated with the

proposed action on various resource areas. However, these impacts are estimated to be small in

magnitude and small in comparison to the benefits of the proposed action. Therefore, the benefits of the

proposed action are believed to outweigh the costs of the proposed action.

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

This section compares the costs and benefits of the proposed action to those of the no-action alternative.

This comparison focuses on the tradeoffs between the proposed ACP at Piketon versus continued

operation of the Paducah Gaseous Diffusion Plant, since these are the main features that distinguish the

proposed action from the no-action alternative. -Other possible actions involving other domestic and

7-5
I foreign uranium enrichment suppliers are likely to be similar under the two alternatives and are therefore

2 not considered in the comparison.

3

4 7.2.1 Methodology

5

6 The proposed action and the no-action alternative are first assessed in Section 7.2.2 for compliance with

7 various policy and technical objectives articulated by DOE. The proposed action and the no-action

8 alternative are then analyzed in Section 7.2.3 for impacts and values across the following impact areas or

9 attributes:

10

11 * Construction and manufacturing costs;

12 * Operating costs;

13 * Decommissioning costs; and

14 * Environmental and public and occupational health impacts.

15

16 The other indirect cost areas described in Section 7.1.1 are not included as part of this comparison

17 because the effect of these impacts is assumed to be either (1) approximately equal for the proposed

18 action and the no-action alternative as defined above; or (2) too small a differential impact to materially

19 affect the comparative cost benefit analysis.

20

21 The NRC staff assessed impacts and values for these criteria using either. (1) estimated dollars; or (2)

22 ordinal ratings based on expert judgment where quantification is regarded as inappropriate or

23 unnecessary. This approach is consistent with NRC guidance and is well suited to the current analysis.

24

25 This analysis does not attempt dynamic general equilibrium modeling of the economic effects of a

26 cheaper source of enriched uranium for nuclear power plants. No attempt is made to model the effects of

27 reduced enriched uranium prices on the ratio of nuclear and non-nuclear power in the domestic economy,

28 on overall power demand and price, and on the potential economic benefits to consumers and suppliers.

29 Instead, the analysis focuses on estimating the economic savings to society from replacing Paducah

30 Gaseous Diffusion Plant production by a cheaper and less resource-intensive source based on centrifuge

31 technology.

32

33 In addition, this analysis does not consider the costs and benefits associated with actions pertaining to the

34 Portsmouth Gaseous Diffusion Plant. The Portsmouth Gaseous Diffusion Plant was closed in May 2001

35 to reduce operating costs. The NRC staff does not believe that there has been any significant change in

36 the factors that were considered by USEC in its decision to cease uranium enrichment at Portsmouth. For

37 the purposes of this cost benefit analysis, actions pertaining to the Portsmouth Gaseous Diffusion Plant,

38 such as decontamination and decommissioning, are considered unrelated to the no-action alternative and

39 the proposed action.

40

41 7.2.2 Compliance with Policy and Technical Objectives

42

43 As stated in correspondence with the NRC and in an agreement with USEC (DOE, 2002 and USEC,

44 2005a), and as described in Section 1.3 of this Draft EIS, DOE has the following policy and technical

45 objectives that are relevant to the choice of an enrichment technology:

46

47 * The need for enriched uranium to fulfill domestic electricity requirements;

48

49 * The need for domestic supplies of enriched uranium for national energy security; and

50

51 * The need for upgraded uranium enrichment technology in the United States.

7-6
I The following sections compare the proposed action and the no-action alternative in terms of how well

2 they meet each of these objectives.

3

4 7.2.2.1 Meeting Future Demand

5

6 Currently, the demand for enriched uranium in the United States is met from three categories of sources:

7

8 * Domestic production of enriched uranium;

9 * The Megatons-to-Megawatts program; and

10 * Other foreign sources.

11

12 The Megatons-to-Megawatts program, which currently provides approximately 42 percent of the enriched

13 uranium purchased by commercial nuclear reactors in the U.S., is likely to be available only until 2013

14 (USEC,2005a). A significant shortfall in supply is therefore likely to arise after this date unless new

15 sources are developed. Increasing imports from foreign sources are inconsistent with domestic energy

16 security objectives. The only option is therefore to increase domestic production of enriched uranium.

17

18 Increasing production levels at the Paducah Gaseous Diffusion Plant may not be technically feasible

19 given the maturity of the plant and its dated technology. Under the proposed action, the initial capacity of

20 the ACP would be 3.5 million SWUs per year, which would provide roughly 25 percent of the projected

21 U.S. enrichment needs and allow the Paducah plant to be retired. This capacity would be further,

22 enhanced to 7 million SWUs per year by 2013.

23

24 The proposed action is therefore better able to meet the objective of fulfilling the increased demand for

25 enriched uranium than the no-action alternative.

26

27 7.2.2.2 National Energy Security

28

29 Currently, foreign sources supply as much as 86 percent of the U.S. demand for enriched uranium. All of

30 the domestic production of enriched uranium currently takes place at a single plant - the aging Paducah

31 Gaseous Diffusion Plant. The heavy dependence on foreign sources and the lack of diversification of

32 domestic sources of enriched uranium represents a potential reliability risk for the domestic nuclear

33 energy industry, which supplies 20 percent of national energy requirements. Interagency discussions led

34 by the National Security Council have concluded that the United States should maintain a viable and

35 competitive domestic uranium enrichment industry for the foreseeable future. DOE has noted the

36 importance of promoting the development of additional domestic enrichment capacity to achieve this

37 objective (DOE, 2002).

38

39 In this context, the proposed action offers a means of increasing domestic uranium enrichment capacity

40 beyond existing levels. Furthermore, in combination with other new facilities, such as the 3 million SWU

41 per year enrichment plant proposed by Louisiana Energy Services, the proposed action represents a

42 significant diversification of do miestic sources. As noted in the previous section, the no-action alternative

43 does not offer much scope' for increasing production levels 'and presents some degree of reliability risk.

44

45 : The proposed action is therefore better able to meet the objective of national energy security than the no46 action alternative.

47

48 7.2.23 Technology Upgrade

49

50 A DOE-USEC agreement in 2002 intended to "facilitate the deployment of new, cost effective advanced

51 treatment technology in the U.S. on a rapid scale" (USEC, 2005a). In this context, the proposed action

7-7
1 represents the implementation of a technology that is contemporary, cost-effective, and reliable. The no2 action alternative would involve continuation of a technology that is over 50 years old and that is, in

3 comparison, highly resource-intensive. Continued operation of the Paducah Gaseous Diffusion Plant

4 would involve high energy costs and high levels of water and Freon gas consumption (these differences in

5 operating costs and resource consumption are described in the following sections).

6

7 The proposed action is therefore better able to meet the objective of domestic uranium enrichment

8 technology upgrade than the no-action alternative.

9

10 7.2.3 Impacts and Value Analysis

111

12 This section compares the impacts and values of the proposed action and the no-action alternative over

13 the following cost and impact categories:

14

15 * Construction and manufacturing costs;

16 * Operating costs;

17 * Decommissioning costs; and

18 * Environmental and public and occupational health impacts.

19

20 Appendix G presents a quantitative net present value analysis of the two alternatives integrating

21 construction, manufacturing, operation, and decommissioning costs. Environmental and public and

22 occupational health impacts have been considered qualitatively.

23

24 7.2.3.1 Construction and Manufacturing Costs

25

26 The site preparation and construction phase of the proposed action is estimated to incur costs of $1,449

27 million (nominal dollars) between calendar years 2006 and 2010 (USEC, 2005a). The manufacturing

28 phase of the proposed action is estimated to cost $1,423 million (nominal dollars) between calendar years

29 2004 and 2013 (USEC, 2005a). These costs are for a plant capacity of 7 million SWUs per year and are

30 consistent with those used by USEC to estimate employment and other socioeconomic impacts.

31

32 By comparison, no construction costs are assumed to be associated with the no-action alternative.

33

34 7.2.3.2 Operating Costs

35

36 The operating costs per SWU associated with the proposed action and the no-action alternative are

37 discussed in Appendix G. These estimates, which are not presented here in order to preserve proprietary

38 information (pursuant to 10 CFR 2.390), are based on the Paducah Gaseous Diffusion Plant 2005 budget

39 and the proposed ACP estimated operation costs were provided by USEC (USEC, 2005b).

40

41 For the proposed action, the overall operating costs per SWU are approximately 20 percent of the

42 operating costs per SWU of the no-action alternative. The large difference in operating costs derives

43 from the lower resource consumption of the proposed action. The proposed action consumes only 5

44 percent as much electricity per SWU, 3 percent as much water per SWU, and 3.3 percent as much natural

45 gas per SWU as the no-action alternative. The proposed action has a slightly higher oil consumption per

46 SWU compared to the no-action alternative, but, unlike the no-action alternative, does not consume any

47 coal.

48

49 While many of the benefits of lower resource consumption are captured in the differential operating cost

50 estimates of the two alternatives, it is likely that significant potential benefits to the environment and to

51 public health - which can also be characterized as positive externalities - are not fully accounted for in

7-8
I the cost estimates. This issue is discussed in Section 7.2.3.4. Therefore, the overall operating cost

2 savings of the proposed action may be even higher from a social perspective than estimated here.

4 7.2.3.3 Decommissioning Costs

5

6 The decontamination and decommissioning phase of the proposed action (with a plant capacity of 7

7 million' SWUs per year) is estimated to incur costs of $435 million (2004$) over a period of six years

8 (USEC, 2005a). Decontamination and decommissioning activities are expected to begin 30 years after

9 the commencement of operations at the plant and are estimated in this analysis to occur from 2040

10 through 2045. The NRC evaluated the adequacy of USEC's proposed funding for these activities in the

11 Safety Evaluation Report on the proposed ACP.

12

13 The decommissioning schedule and costs of the no-action alternative are considered independent of the

14 proposed action and are not part of this analysis. 'Similarly, the decommissioning schedule and costs of

15 the Portsmouth Gaseous Diffusion Plant are considered independent of the proposed action and are not

16 part of this analysis.

17

18 The comparative cost benefit analysis also does not factor in costs associated with tails disposition. It is

19 assumed that for a given production level, the amount of tails generated by the ACP would be roughly

20 equivalent to the amount of tails that would have been generated using the Paducah Gaseous Diffusion

21 'Plant (USEC, 2005a). Therefore, no incremental costs result from the proposed action relative to the no22 action alternative.

23

24 7.2.3.4 Environmental and Public and Occupational Health Impacts

25

26 Both the proposed action and the no-action alternative present limited environmental and public and

27 occupational health impacts resulting from radiological and nonradiological releases.

28

29 The proposed action is likely to have much lower radiological releases than the no-action alternative

30 because the amount of piping and pumping is significantly smaller and there are consequently fewer

31 components that may leak. The smaller plant associated with the proposed action is likely to require less

32 maintenance, which implies lower dose to workers, and a cleaner plant means less ambient worker

33 exposure fewer radiation control areas.

34

35 The largest relative environmental and health impact is likely to derive from the much lower power

36 requirement for the proposed ACP compared to the Paducah Gaseous Diffusion Plant. As previously

37 mentioned, the proposed ACP is expected to consume only 4 percent as much electricity per SWU and

38 3.3 percent as much natural gas per SWU as the Paducah Gaseous Diffusion'Plant. The proposed ACP

39 would not consume any coal. This implies significantly lower emissions of gases associated with fossil

40 fuel combustion, some of which are known to have substantial environmental and public health impacts.

41

42 Therefore, the proposed action is likely to have a much lower environmental and public health impact

43 than the no-action alternative.

7-9
1 7.2.4 Conclusions Regarding the Proposed Action Versus the No-Action Alternative

2

3 Based on these considerations, the proposed action is preferable relative to the no-action alternative in the

4 following respects:

5

6 * The proposed action better satisfies DOE's policy and technical objectives for meeting future

7 demand, national energy security, and technological upgrades, relative to the no-action alternative.

8

9 * The proposed action would result in significant savings to the national economy, relative to the noI10 action alternative, even after accounting for the costs incurred during the construction, manufacturing,

l lIand decommissioning phases. These savings have been quantitatively estimated for different

l 12 scenarios in Appendix G.

l 13

14 * The proposed action would have a significantly lower public and occupational health impact relative

15 to the no-action alternative.

16

17 * The proposed action would have positive impacts on local employment, income and tax revenues

18 during the construction, manufacturing, and decommissioning phases, as discussed in Sections 4.2.8

19 and4.2.14.8.

20

21 This analysis therefore concludes that the proposed action definitively outranks the no-action alternative

22 on all substantive impact areas.

23

24 7.3 Overall Cost Benefit Conclusions

25

26 The analysis in Section 7.1 demonstrated that there are significant economic and national energy benefits

27 associated with the proposed action. There are also direct costs associated with the construction and

28 operation phases of the proposed action, as well as indirect costs resulting from impacts associated with

29 the proposed action on various resource areas. However, these impacts are estimated to be small in

30 magnitude and small in comparison to the benefits of the proposed action.

31

32 The analysis in Section 7.2 illustrated the significant net benefits of the proposed action in comparison to

33 the no-action alternative, in which there is continued uranium enrichment at the Paducah Gaesous

34 Diffusion Plant. The proposed action better satisfies DOE's policy and technical objectives for meeting

35 future demand for enriched uranium, improved national energy security, and desired technological

36 upgrades, relative to the no-action alternative.

37

38 It is therefore apparent that, either considered on its own or in comparison to the no-action alternative,

39 the proposed action is associated with significant net positive benefits.

40

41 7.4 References

42

43 (USEC, 2005a) United States Enrichment Corporation. "Environmental Report for the American

44 Centrifuge Plant in Piketon, Ohio." Revision 3. Docket No. 70-7004. July 2005.

45

46 (USEC, 2005b) United States Enrichment Corporation. "Additional Responses to Request for Additional

47 Information Regarding the Environmental Report (TAC No. L32307) - Proprietary Information." Dated

48 April 21, 2005.

49

50 (DOE, 2002) U.S. Department of Energy. Letter from W.D. Magwood to M. Virgilio, U.S. Nuclear

51 Regulatory Commission. Uranium Enrichment. July 25, 2002.

7-10
1 8. SUMMARY OF ENVIRONMENTAL CONSEQUENCES

2

3 8.1 Unavoidable Adverse Environmental Impacts

4

5 Information on the adverse impacts to the affected environment at the proposed ACP that cannot be

6 avoided for this proposed action is provided in Chapter 4 of this Draft EIS. The environmental impacts

7 from the proposed action are generally small and would, in most cases, be mitigated by methods

8 described in Chapter 5. Monitoring methods are described in Chapter 6. Table 2-8 compares the

9 potential impacts from the proposed action to those of the no-action alternative. Detailed analysis of the

10 potential impacts on public health and safety is provided in the safety evaluation report prepared by the

11 NRC. Following is a summary of the impacts presented in Chapter 4.

12

13 * Land Use - Site preparation and construction would physically change approximately 22 hectares (55

14 - acres) of land on the DOE reservation. These physical changes would be minor becaus6: (1) the area

15 to be occupied by the proposed ACP would be only a small portion of the 1,500-hectare (3,700-acre)

16 reservation; (2) the majority of the proposed land has been previously disturbed; (3) no prime

17 farmland would be affected; and (4) site preparation and construction would not affect or preclude

18 any existing land uses on the property that surrounds the DOE reservation; The changes would

19 simply convert the land use on the DOE reservation from managed lawns, fields, and limited forest

20 buffer to developed areas, resulting in an overall SMALL impact.

21

22 * Historic and Cultural Resources - There would be no adverse indirect or direct effect on the 14 sites

23 potentially eligible for the National Register of Historic Places within the area of potential effect of

24 the project. Also, construction of new buildings and refurbishment of existing buildings would result

25 in buildings of design, size, and function similar to the existing buildings, and would not alter the

26 historic setting of the existing Gaseous Diffusion Plant. Therefore, impacts on historic and cultural

27 resources should be SMALL.

28

29 * Visual and Scenic Resources - The Bureau of Land Management Visual Resources Management

30 rating system classifies the proposed ACP site as Class III or IV, meaning it has moderate to little

31 scenic value. Construction of the ACP would not alter the site's classification. No scenic rivers,

32 nature preserves, or unique visual resources exist in the project area. Therefore, impacts of the

33 proposed action on visual and scenic resources are expected to be SMALL.

34

35 * Air Quality - Airborne emissions from site preparation and construction should not result in

36 exceedances of air quality standards, with the possible exception of short-term increases in particulate

37 matter. Radiological releases from soil disturbances and decommissioning of the Gas Centrifuge

38 Enrichment Plant would bensmall and controlled. Emissions from diesel generators would not cause "

39 air quality problems and maximum predicted concentrations of hydrogen fluoride resulting from ACP

40 operations are below safe levels. Based on the maximum radiological emission rates for the ACP and

41 the comprehensive site monitoring program, the expected impact to air quality from the plant's

42 radiological emissions is also expected to be small. Considering all of these factors together, the air

43 quality impacts would be SMALL in every respect, except for potential short-term increases in

44 particulate matter during the site preparation and construction phase, which would result in

45 MODERATE impacts.

8-1
1 * Geology and Soils - Most of the site is an existing industrial facility with altered natural soils. The

2 soils are cohesive and over-consolidated and have low potential for liquefaction. There is little

3 likelihood of impact from soil compaction or subsidence. The flat terrain where the ACP buildings

4 would be located, and the dense soil, low moisture content, and vegetative cover in the area of a new

5 large cylinder storage yard (X-745H) make landslides unlikely. Construction activities would not

6 alter current drainage and would not disturb any soils that qualify for protection as prime farmland.

7 There would be a potential for increased erosion and siltation of streams near the construction site of

8 the new large cylinder storage yard, but both of these potential impacts should be minimized by the

9 - use of standard best management practices. For these reasons, the impacts to geology and soil are

10 expected to be SMALL.

11

12 * Water Resources - Potential stream sedimentation from construction activities would be minimized

13 by the use of silt fences and other best management practices. Any impacts to stream water quality

14 - would be of short duration. None of the proposed site preparation and construction activities would

15 occur within a 100-year floodplain. Groundwater withdrawals would increase by 10 percent over

16 current usage rates, but would still be only 31 percent of the total design capacity of the site's well

17 fields, would not affect groundwater availability, and would not pose an increased risk of subsidence.

18 Wastewater would continue to discharge from permitted NPDES outfalls and discharge rates, though

19 increased above current levels, would represent only 75 percent of the existing system's design

20 capacity. USEC does not anticipate any liquid discharges of radioactive materials from the proposed

21 ACP (i.e., from cooling water, storm water runoff, or sanitary water). The potential for leaks or spills

22 that could contaminate water resources would be limited by an approved Spill Prevention Control and

23 Countermeasures Plan. Therefore, impacts to water resources should be SMALL.

24

25 * Ecological Resources - Construction of the X-745H Cylinder Storage Yard would result in increased

26 erosion, stormwater runoff, and loss of 24 acres of vegetation, but with planned mitigation measures,

27 would result in small impacts to the flora and fauna in and around the tributaries of Little Beaver

28 Creek. That same cylinder storage yard would also be located within 500 meters of suitable summer

29 habitat for the endangered Indiana bat, although studies have not documented the presence of this bat

30 species on the DOE reservation. None of the site construction activities would occur in wetlands.

31 However, some construction would occur adjacent to small wetlands, and standard erosion control

32 measures would be used to limit sedimentation in these areas. For these reasons, impacts to

33 ecological resources are expected to be SMALL.

34

35 * Socioeconomics - ACP construction and operation would result in a moderate increase in regional

36 employment and a small increase in regional tax revenues (these impacts, however, are generally

37 considered positive, not adverse). Impacts to population characteristics, housing resources,

38 community and social services, and public utilities are projected to be small. Therefore, the

39 socioeconomic impacts of the proposed action are expected to range from SMALL to MODERATE.

40

41 * Environmental Justice - Within an 80-kilometer (50-mile) radius around the proposed ACP site,

42 there are 18 Census tracts that have populations qualifying as low-income and two Census tracts that

43 have populations qualifying as minority. The closest of these tracts is 28 km (17 miles) from the

44 proposed site. The proposed action would not result in disproportionately high or adverse impacts to

45 any of these populations. Therefore, the environmental justice impacts of the proposed action would

46 be SMALL.

8-2

Il I
I * Noise - Estimated construction noise levels at the site are below acceptable guidelines. No adverse

2 noise impacts from ACP operations are expected at the closest residence due to low operational noise,

3 the attenuation provided by the building facade, and distance attenuation of over 900 meters (3,000

4 feet). Therefore, noise impacii of the proposed action would be SMALL;

5

6 * Transportation - Increased truck and vehicle traffic should result in small changes in current levels

7 of congestion and delays on U.S. Route'23 and Ohio State Road 32, small increases in the number of

8 traffic accidents resulting in injuries or fatalities, and srnall increases in vehicle emissions that should

9 not degrade local air quality. Radiation exposures resulting from the planned shipments of

10 radioactive materials are estimated to cause'0.02 latent cancer fatalities per year of operation or about

I I one cancer fatality over thirty years of operation. The probability of a severe transportation accident

12 - that releases sufficient quantities of UF6 that could pose a health risk is low, but the consequences of

13 such an accident, should it occur, are high (resulting in an overall moderate rating). Considering all

14 of these factors together, the transportation impacts of the proposed action are expected to be SMALL

15 to MODERATE.

16

17 * Public and Occupational Health - The proposed action would result in small increases in the current

18 number of occupational injuries and illnesses at the site, though still less than historical levels.

19 Construction and process areas would be segregated, and personnel monitoring programs would be

20 implemented, to minimizeworker exposures to annual radiation doses of less than the 10 CFR §

21 20.1201 limit of 50 millisieverts (5,000 millirem). All routine radiation exposures to members of the

22 public are expected to be significantly below the 10 CFR Part 20 regulatory limit of I millisievert

23 (100 millirem) and 40 CFR Part 190 regulatory limit of 0.25 millisieverts (25 millirem) for uranium

24 fuel-cycle facilities. Analytical results also indicate that plausible radiological accidents at the

25 proposed ACP pose acceptably low risks. In addition, public and occupational exposures to non26 radiological contaminants are projected to be less than applicable limits. Therefore, these impacts

27 associated with the proposed action are expected to be SMALL.

28

29 * Waste Management - Site preparation, construction, and operations would generate varying amounts

30 of low-level radioactive, low-level mixed, hazardous, sanitary/industrial, and recyclable wastes. 'All

31 of these wastes would be managed in accordance' with existing procedures for controlling

32 contaminant releases and exposures. With the exception of the depleted uranium, all of the wastes

33 would also be generated at volumes that are well within existing management capacities. The ACP

34 would generate approximately 42,800 cylindersof depleted UF6 , containing approximately 571,000

35 metric tons of material. All of this UF6 would be converted to a more stable form at the new DOE

36 conversion facility at Piketon, which would require DOE to significantly extend the life of this

37 facility. The converted material would then be shipped by rail to an acceptable western disposal site,

38 where sufficient capacity exists and where the disposal impacts should be small. Based on this

39 analysis, the waste management impacts ofthe proposed action are 'expected to be SMALL.

40

41 8.2 Relationship Between Local Short-Term Uses of the Environment and the Maintenance and

42 Enhancement of Long-Term Productivity

43

44 The construction and operation of the proposed ACP would involve the short-term commitment of

45 resource and would permanently commit certain resources (e.g., land, water, electricity, fuel, other

46 construction raw materials) to the facility's construction and operation. The short-term use of such

47 resources would result in long-term socioeconomic benefits to the local area and the region through

48 continued (and increased) employment and expenditures, as described in Section 4.2.10. Long-term

8-3
U

I productivity would be facilitated by investments in dependent businesses in the local area and region and

2 would provide further socioeconomic benefits to the local area and region.

3

4 8.3 Irreversible and Irretrievable Commitment of Resources

S

6 Irreversible and irretrievable commitment of resources for the proposed ACP would include the

7 commitment of land, water, energy, raw materials, and other resources for the construction and operation

8 of the ACP. The impacts of commitment of such resources would be SMALL.

9

10 Existing structures at the DOE reservation would be refurbished to accommodate the proposed ACP

11 operations. Proposed changes made to existing facilities would be conducted on land that is already used

12 for industrial purposes. These include the X-3001, X-3002, X2232C, X-7726, X-7727H, X-3012, and X13 3324 buildings and facilities. Land in proximity to the X-3001 and X-3002 buildings would be disturbed

14 to construct two additional process buildings and associated support structures. These include two new

15 process buildings (each approximately 304,000 ft2); new roads and parking areas (108,000 ft2); and

16 several new cylinder storage yards (totaling approximately 2,268,400 ft2). (USEC, 2005)

17

18 Construction of the proposed ACP would use approximately 814 cubic meters per day (215,000 gallons

19 per day) of water, and operation of the proposed ACP would use up to 1,995 cubic meters per day

20 (527,000 gallons per day) of water (USEC, 2005). This water would be drawn from three existing well

21 fields in the Scioto River Valley Aquifer, which presently serve the DOE reservation, and most of it

22 would then be discharged through NPDES-permitted outfalls that eventually lead to the Scioto River.

23 The projected peak water usage rates represent an increase of approximately 10 percent over current water

24 use at the DOE reservation. Counting the new water demands created by the ACP together with the

25 reservation's current water usage rate, the combined new demand for water would represent only 31

26 percent of the permitted withdrawal volume from the three well fields.

27

28 Energy would be expended in constructing and operating the proposed ACP, including diesel and

29 gasoline fuel for vehicles to transport workers and construction materials to the site during site

30 preparation and construction. Approximately 3,200,000 gallons of diesel fuel and 327,000 gallons of

31 gasoline would be used in constructing the proposed ACP (USEC, 2005). NRC estimates that less than

32 650,000 gallons of diesel fuel would be used annually in facility operation.

33

34 Energy expended would also include electricity consumption for site preparation and construction and for

35 facility operation. Approximately 650,000 megawatt hours of electricity would be consumed during

36 facility operation (USEC, 2005).

37

38 The proposed ACP would generate recyclable and non-recyclable waste streams and depleted uranium, as

39 described in Sections 2.1.4 and 4.2.12 of this Draft EIS. Disposal of these wastes would require

40 irreversible and irretrievable commitment of land resources, fuel, and materials.

41

42 Additional resources anticipated to be consumed in site preparation and construction include 97,000 yards

43 of concrete, 1,000 yards of asphalt, 15,000 yards of gravel, and 34,000 yards of steel products (USEC,

44 2005).

8-4

~ I
1 8.4 References

2

3 (USEC, 2005) United States Enrichment Corporation. "Environmental Report for the American

4 Centrifuge Plant in Piketon, Ohio." Revision 3. Docket No. 70-7004. July 2005.

8-5
1 9. AGENCIES AND PERSONS CONSULTED

2

3 The following sections list the agencies and persons consulted for information and data for use in the

4 preparation of this Draft Environmental Impact Statement (Draft EIS):

5

6 9.1 Federal Agencies

7

8 Advisory Council on Historic Preservation, Office of Federal Agency Programs. Mr. Don Klima,

9 Director

10

11 U.S. Department of the Interior; U.S. Fish and Wildlife Service, Ecological Services, Reynoldsberg,

12 Ohio. Mr. Jeromy Applegate

13

14 U.S. Department of the Interior, National Park Service. Mr. Tim McKeown, Archeologist

15

16 9.2 State Agencies

17

18 Ohio Historic Preservation Office, Resource Protection and Review, Columbus, Ohio. Mr. Mark Epstein

19 and Mr. David Snyder

20

21 Ohio Environmental Protection Agency, Division of Ground Waters and Community Drinking Water,

22 Pike County. Mr. Randy Smith

23

24 Ohio Environmental Protection Agency, Portsmouth Reservation Inspector. Mr. Eric Hart

25

26 9.3 Local Agencies

27

28 Pike County Commissioners, Waverly, Ohio. President James Brushart

29

30 9.4 Indian Tribes

31

32 Absentee Shawnee Tribe of Oklahoma, Shawnee, Oklahoma. Tribal Secretary Kenneth Daughtery.

33

34 Cayuga Nation, Versailles, New York. Chief James Leaffe

35

36 Cherokee Nation of Oklahoma, Ada, Oklahoma.

37

38 Citizen Potawatomi Nation, Shawnee, Oklahoma. Chairperson John A. Barret

39

40 Deleware Tribe of Western Oklahoma, Anardarko, Oklahoma. President Bruce Gonzales

41

42 Eastern Shawnee Tribe of Oklahoma, Seneca, Missouri. Chief Charles D. Enyart

43

44 Forest County Potawatomi, Crandon, Wisconsin. Chairperson Harold Frank

45

46 Loyal Shawnee Tribe, Jay, Oklahoma. Mr. James Squirrel

47

48 Miami Tribe of Oklahoma, Miami, Oklahoma. Mr. John Pryor

49

50 Ottawa Tribe of Oklahoma, Miami, Oklahoma. Chief Charles Todd

9-1
I Peoria Tribe of Oklahoma, Miami Oklahoma. Chief John P. Froman

2

3 Prairie Band of Potawatomi Nation, Mayyetta, Kansas. Mr. Ray Kitchkumme

4

5 Seneca-Cayuga Tribe of Oklahoma, Miami, Oklahoma. Chief Jerry Dilliner

6

7 Seneca Nation of Indians, Salamanca, New York. President Calvin John

8

9 Shawnee Tribe, Miami, Oklahoma. Mr. Ron Sparkman

10

11 Turtle Mountain Band of Chippewa Indians, Belcourt, North Dakota. Mr. Kade M. Ferris

12

13 Wyandotte Nation, Wyandotte, Oklahoma. Chief Leaford Bearskin

9-2
1 10. LIST OF PREPARERS

2

3 10.1 U.S. Nuclear Regulatory Commission (NRC) Contributors

4

5 Matthew Blevins: EIS Project Manager

6 M.S., Environmental Systems Engineering, Clemson University, 1995

7 B.S., Chemistry, West Virginia University, 1993

8 Years of Experience: 10

9

10 Yawar H. Faraz: Licensing Project Manager

11 B.S., Nuclear Engineering, University of Maryland, 1982

12 Years of Experience: 23 --

13

14 F. Stanley Echols: Senior Project Manager

15 Ph.D., Environmental Engineering, University of Florida, 1973

16 J.D., Law, Georgetown University, 1978

17 B.S., Nuclear Engineering, University of Florida, 1969

18 Years of Experience: 30

19

20 Ron C. Linton: Project Manager

21 M.S., Geology, West Virginia University, 1992

22 B.S., Geology, James Madison University, 1984

23 Years of Experience: 17

24

25 B. Jennifer Davis: Environmental Review Section Chief

26 M.S., Materials Engineering, University of Maryland, 1995

27 B.S., Materials Engineering, Virginia Polytechnic Institute and State University, 1986

28 Years of Experience: 18

29

30 Cynthia S. Barr: Transportation Project Manager

31 M.S., Environmental Systems Engineering, Clemson University, 1998

32 B.S., Mathematics, College of Charleston, .1991

33 B.A., Political Science, College of Charleston, 1991

34 Years of Experience: 7

35

36 Alicia Mullins: Environmental Reviewer

37 B.A., Biology, Gallaudet University, 1990

38 Years of Experience: 14

39

40 10.2 ICF Consulting Contributors

41

42 Steve Wyngarden: ICF Consulting Project Manager.

43 M.S., Environmental Management, Duke University, 1982

44 B.S., Applied Biology, Georgia Institute of Technology, 1980

45 Years of Experience: 23

46

47 Don Hammer: ICF Consulting Deputy Project Manager

48 B.S., Geology, Colorado State University, 1983

49 Years of Experience: 22

10-1
I Lisa Bendixen: Transportation

2 M.S., Operations Research, Massachusetts Institute of Technology, 1980

3 B.S., Applied Mathematics, Massachusetts Institute of Technology, 1979

4 Years of Experience: 20

5

6 Mark Bethoney: Graphics

7 Somerville High School, 1986

8 Years of Experience: 13

9

10 Ed Carr- Air Quality

11 M.S., Atmospheric Science, University of Washington,1983

12 B.S., Meteorology, California State University, 1979

13 Years of Experience: 19

14

15 David Coate: Noise

16 M.S., Energy Technology, Massachusetts Institute of Technology, 1980

17 B.A., Mathematics, Westminster College, 1978

18 B.A., Physics, Westminster College, 1978

19 B.A., Chemistry, Westminster College, 1978

20 Years of Experience: 27

21

22 Ted Coogan: Environmental Justice, Graphics

23 B.S., Environmental Earth Science, Eastern Connecticut State University, 1986

24 Years of Experience: 22

25

26 Elizabeth Gormsen: Cost-Benefit

27 M.P.P., Goldman School of Public Policy, University of California, Berkeley, 2002

28 B.A., Economics with Honors, Colgate University, 1998

29 Years of Experience: 7

30

31 Lesley Jantarasami: Alternatives

32 B.A., Environmental Science and Policy, Duke University, 2004

33 Years of Experience: I

34

35 Robert Lanza: Waste Management, Decontamination and Decommissioning, Public and Occupational

36 Health

37 M.Eng., Chemical Engineering, Cornell University, 1982

38 B.S., Chemical Engineering, Cornell University, 1980

39 Years of Experience: 25

40

41 Jim Oliver: Public and Occupational Health

42 M.S., Nuclear Engineering, Georgia Institute of Technology, 1992

43 B.S., Mechanical Engineering, Georgia Institute of Technology, 1990

44 Years of Experience: 11

45

46 Larry O'Rourke: Transportation

47 M.A., Government, Johns Hopkins University, 1997

48 B.A., Political Science, Johns Hopkins University, 1992

49 Years of Experience: 8

10-2
I Polly Quick: Historic and Cultural Resources

2 Ph.D., Anthropology, Harvard University, 1976

3 M.A., Anthropology, Harvard University, 1970

4 B.A., Anthropology, Radcliffe College, 1968

5 Years of Experience: 30

6

7 Jim Rice: Geology and Soils, Water Resources

8 M.S., Geology, New Mexico Institute of Mining and Technology, 1985

9 B.S., Geology, New Mexico Institute of Mining and Technology, 1981

10 Years of Experience: 19

11

12 Maribelle Rodriguez: Purpose and Need, Affected Environment

13 M.S., Environmental Engineering, Johns Hopkins University, 1995

14 B.S., Chemical Engineering, Massachusetts Institute of Technology, 1994

15 Years of Experience: 10

16

17 Todd Stribley: Ecological Resources, Land Use, Historic and Cultural Resources

18 B.S., Biology, St. Lawrence University, 1992

19 Years of Experience: 12

20

21 David Stuenkel: Transportation

22 Ph.D., Nuclear Engineering, University of Michigan, 1997

23 M.S., Nuclear Engineering, University of Michigan, 1994

24 B.S., Nuclear Engineering, University of Illinois, 1992

25 Years of Experience: 5

26

27 Alan Surnmerville: Deputy Project Manager

28 M.A., City Planning, University of Pennsylvania, 1988

29 B.A., Economics and Political Science, University of Vermont, 1985

30 Years of Experience: 16

31

32 Arun Varghese: Socioeconomics, Cost-Benefit

33 M.Eng., Civil and Environmental Engineering, Massachusetts Institute of Technology, 2002

34 M.P.A., Economics and Public Policy, Princeton University, 2001

35 B.Eng., Chemical Engineering, Bombay University, 1994

36 Years of Experience: 8

37

38 Raymond Wood: Public and Occupational Health, Waste Management

39 Ph.D., Nuclear/Radiological Engineering, University of Cincinnati, 1994

40 B.S., Nuclear Engineering, University of Cincinnati, 1980

41 Years of Experience: 14

10-3
1 APPENDIX 

A

2 ENVIRONMENTAL SCOPING SUMMARY REPORT
Docket No. 70-7004

ENVIRONMENTAL IMPACT STATEMENT SCOPING PROCESS

ENVIRONMENTAL SCOPING SUMMARY REPORT

Proposed USEC Inc.

American Centrifuge Plant

Piketon, Ohio

April 2005

U.S. Nuclear Regulatory Commission

Rockville, MD

A-l
1. INTRODUCTION

On August 23, 2004, USEC Inc. (USEC) submitted an application to the U.S. Nuclear

Regulatory Commission (NRC) for a license to construct, operate, and decommission the

American Centrifuge Plant (ACP), a gas centrifuge uranium enrichment facility located on the

U.S. Department of Energy (DOE) reservation in Piketon, Ohio. The ACP, if licensed, would

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

comprised of non-enriched uranium hexafluoride (UF6). USEC proposes to use centrifuge

technology to enrich the isotope uranium-235 in the UF6 up to 10 percent. The initial license

application is for a 3.5 million separative work unit (SWU)' facility. Because USEC indicated

the potential for future expansion to 7.0 million SWU per year, the environmental review will

look at the impacts from a 7.0 million SWU per year facility.

In accordance with NRC regulations in 10 CFR Part 51, and the National Environmental Policy

Act (NEPA), the NRC is preparing an Environmental Impact Statement (EIS) for the proposed

facility as part of its decision-making process. The proposed action is the issuance of an NRC

license for USEC to possess and use special nuclear material, source material, and byproduct

material at the proposed ACP. The activities to be conducted under the license would include

the construction, operation and decommissioning of the proposed ACP. The EIS will examine

the potential environmental impacts associated with the proposed ACP in parallel with the

review of the license application. The EIS will be prepared by NRC staff with technical

assistance from ICF Consulting Inc. and Trinity Engineering Associates. The NRC has not

identified any cooperating agencies for the preparation of this EIS. In addition to the EIS, the

NRC will prepare a Safety Evaluation Report (SER) which will document the staff's review of

safety and security issues.

The NRC plans to operate on a 30-month licensing schedule with 19 months allocated for the

environmental review. The current schedule for publication of the draft EIS is in August 2005,

with a public meeting scheduled in September 2005 after publication of the draft EIS. The final

EIS is tentatively scheduled for publication in March, 2006.

As part of the NRC's environmental review, and to comply with 10 CFR 51.26 and 51.27,

scoping was initiated on October 15, 2004, with the publication in the Federal Register of a

Notice of Intent to prepare an EIS and to conduct a scoping process (69 Fed. Reg. 61268).

Scoping is an early and open part of the NEPA process designed to help determine the range

of actions, alternatives, and potential impacts to be considered in the EIS, and identify

significant issues related to the proposed action. The NRC solicits input from the public and

other agencies in order to focus on issues of genuine concern.

On January 18, 2005, the NRC staff held a public scoping meeting in Piketon, Ohio, to receive

both oral and written comments from interested parties. The public scoping meeting began with

NRC staff providing a description of the NRC's role, responsibilities, and mission. A brief

overview of the safety review process was followed by a description of the environmental review

process and a discussion of how the public can effectively participate. The majority of the

meeting was reserved for attendees to ask questions and make comments on the scope of the

environmental review. The NRC postponed the originally scheduled public scoping meeting in

Piketon, Ohio from November 15, 2004 until January 18, 2005 after removal of public

' SWU relates to a measure of the work used to enrich uranium.

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documents from the NRC public reading room and website for several weeks in November

2004 due to security concerns. Due to this delay, the public scoping comment period was

extended from December 6, 2004 until February 1, 2005.

As part of the environmental review, NRC has begun a consultation process with the Ohio State

Historic Preservation Officer (SHPO) as required by Section 106 of the National Historic

Preservation Act. In accordance with 36 CFR 800.3(f), NRC will consult with Native American

Tribal members identified by the SHPO and will consult with representatives of the Pike County

Commission. Other consultations will include the Fish and Wildlife Service as required by

Section 7 of the Endangered Species Act.

This report has been prepared to summarize the determinations and conclusions reached in the

scoping process as required in 10 CFR 51.29(b). After publication of the draft EIS, the public

will be invited to submit additional comments. Availability of the draft EIS, the dates of the

public comment period, and information about a public meeting to be held to discuss the draft

EIS will be announced in the Federal Register, on NRC's website

(http://www.nrc.xovlmaterials/fuel-cvcle-fac/usecfacility.html), and in the local news media when

the draft EIS is distributed. After evaluating comments on the draft EIS, the NRC staff will issue

a final EIS that will serve as the basis for the NRC's consideration of environmental impacts in

its decision on the proposed ACP.

This report is organized into four main sections. Section 1 provides an introduction and

background information on the environmental review process. Section 2 summarizes the

comments and concerns expressed by government officials, agencies, and the public:- Section

3 identifies the issues that the draft EIS will address and Section 4 describes those issues that

are not within the scope of the draft EIS. Where appropriate, Section 4 also identifies other

places in the decision-making process where issues that are outside the scope of the draft EIS

may be considered.

2. ISSUES RAISED DURING THE SCOPING PROCESS

2.1 OVERVIEW

Approximately 80 individuals not affiliated with the NRC attended the January 18, 2005 public

scoping meeting concerning the USEC license application for the ACP. During the meeting,'

five individuals asked specific questions about the scoping process. Sixteen individuals offered

specific oral comments related to th6 proposed ACP. In addition, 24 written comments,'

including :1 duplicate, were received from various individuals during the public scoping period,

which ended on February 1, 2005. The scoping meeting transcript (ML050590321) and the 24

written comments received by the NRC are available on the NRC website, electronic reading

room, at http://www.nrc.Qovlreadinq-rmladams/web-based.html.

The active participation of the public in the scoping process is an important component in

determining the major issues that the NRC should address in the draft EIS. Individuals

providing oral and written comments addressed several subject areas related to the proposed

USEC facility and the draft EIS development;' In addition to private citizens, the various

commenters included:

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* A representative of the Governor of Ohio.

* A local official from the Village of Piketon.

* Pike and Scioto County Commissioners.'

* Representatives of the Pike County Chamber of Commerce and the Chillicothe/Ross

County Chamber of Commerce.

* Representatives of State of Ohio agencies or departments.

* Representatives of local businesses.

* Representatives of other organizations including:

- Public Citizen

- Portsmouth/Piketon Residents for Environmental Safety

- National Nuclear Workers for Justice

- Paper, Allied-industrial, Chemical and Energy Workers International Union

- Sierra Club, Central Ohio Group and Appalachian Ohio Section

- Southern Ohio Diversification Initiative

The following general topics categorize the comments received during the public scoping

period:

* NEPA and public participation.

* Need for the proposed facility.

* Land use.

* Alternatives.

* Ecology, air quality, soil and water resources.

* Socioeconomics.

* Transportation.

* Waste management.

* Historic and cultural resources.

* Cumulative impacts.

* Decommissioning.

* Safety and risk.

* Nuclear nonproliferation and security.

* Terrorism.

* Credibility.

In addition to raising important issues about the potential environmental impacts of the

proposed facility, some commenters'offered opinions and concerns that typically would not be

included in the subject matter of an EIS - these include general opinions about nuclear

proliferation and the use'of nuclear energy. Comments of this type do not fall within the scope

of environmental issues to be analyzed. Other statements may be relevant to the proposed

action, but they have no direct bearing on the evaluation of alternatives or on the decisionmaking process involved in the proposed action. For instance, general statements of support'

for or opposition to the proposed action fall into this category. Again, comments of this type

have been noted but are not used in defining the scope and content of the draft EIS.

Section 2.2 summarizes the comments received during the public scoping period. Most of the

issues raised have a direct bearing on the NRC's analysis of potential environmental impacts.

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2.2 SUMMARY OF ISSUES RAISED

As noted above, a number of commenters expressed support for the'facility. 'Several

individuals, on the other hand; raised concerns regarding the construction and operation of the

proposed ACP. The following'summary groups the comments received during the scoping

period by technical area and issue.

2.2.1 NEPA and public participation

Several commenters expressed general support for the ACP stating that the facility would be

beneficial to the economy. One commenter questioned the role of membiers of the public not

located in the'Piketon area and their possible impact on the decision-making process. The

commenter stated that the f6cus'of public participation'should be on those members of the

public most directly affected by the proposed facility. However, another commenter'disagreed,

stating that because materials, including wastes, would be shipped from the facility to various

points around the country, everyone'who is potentially affected by the facility should be included

in the public participation process.

A number of commenters requested an'extension of the time period for submitting comments

on the scope of the draft EIS. These commenters cited several reasons for the extension

request, but the reason cited most often was the'lack of availability of documents on NRC's

website because of security concerns. Two'commenters noted that the public was not made

aware of a public meeting on November 9, 2004, where USEC's recorddof accidentsand

contamination releases was discussed. Several commenters also noted that some of the

information on NRC's website is not accessible, including information on reportable events such

as releases from the plant; One commenter also noted that answers' to questions that she

submitted to the NRC on December 2, 2004 had not yet been answered.

Several commenters raised concerns regarding the availability of information contained in-the

license application and the Environmental Report. One commenter stated that some of the

information related to the application has'been classified as confidential for security purposes

and therefore the public does not have'access'to it; Another commenter stated that the public

should have access to all the information it may reasonably be expected to have known about.

This commenter requested that NRC make all redactions in the ER available to the public,

including Appendices B, D, and E. If not, the commenter requested an explanation as to why

the information was redacted. Another commenter stated that restricting the public from

information for reasons other than security protection constitutes an infringement on the

democratic involvement of the people in the actions of its govemment. 'One commenter'noted

that an EIS had been completed for the Piketon site in the past, and that this document should

be reviewed to determine if any information contained in that report is relevant to the proposed

ACP.

Other comments included one person who indicated that she is entitled to a full copy of the

license application. Another commenter stated that scoping should include perspective of those

outside of the local community. AKcommenteralso'thought that it is important that impacts and

alternatives must be assessed before an action is taken, not to justify a decision' already made.

Another commenter stated that it is expected that NRC will provide regulatory guidelines that'

will allow USEC to operate a plant efficiently with protection for both workers and the

community.

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A commenter specifically stated that the draft EIS should carry out a comprehensive evaluation

that honestly takes into account the long-term environmental impacts of the proposed project.

This commenter noted that this type of evaluation is especially relevant to facilities involved in

the production of fuel for nuclear reactors because of the length of time the waste material is

dangerous and the need for containment and monitoring for the duration of that time. Finally,

two commenters requested waivers of fees for documents related to the licensing action.

2.2.2 Need for the proposed facility

A number of commenters raised concerns about the need for a uranium enrichment facility. One commenter argued that the public must agree on the need for the facility. Several

commenters stated that the draft EIS, must analyze the need for the proposed facility given the

existing enriched uranium stockpiles that could meet the needs for nuclear energy for several

years. A commenter also stated that the draft EIS should consider that the proposed LES

facility in New Mexico could actually start operations first, lessening the need for the ACP.

Commenters indicated that the potential for an international moratorium on uranium enrichment

exists, and the ramifications of this action should be accounted for in the analysis. Other

commenters indicated that recent budget cuts and uncertainty in energy policy lessen the need

for additional enriched uranium production. Specifically, one commenter stated that the draft

EIS should evaluate the potential for a pause in production of nuclear fuel, which would allow

the NRC and other agencies to focus resources in other areas such as cleaning up existing contamination, developing safe and permanent waste disposal options, lowering transportation risks, better documenting releases and events, and encouraging development of clean, safe,

well-paying jobs.

Another commenter stated, however, that there will be an increase in demand for electricity in

the future and that nuclear power will be critical to ensuring this supply and promoting energy- independence. The commenter noted that the ACP would play a key role in providing that

energy.

Other commenters stated that the draft EIS should evaluate the development of other less

expensive, renewable energy resources with less significant environmental impacts. Commenters also suggested that material from disassembled nuclear weapons could be used

as an alternate source for uranium enrichment.

A commenter stated that the draft EIS should address whether the operation of the ACP will

have a negative impact on the "Megatons to Megawatts" program, in which highly enriched

uranium from dismantled Russian nuclear weapons is down-blended and used as fuel in U.S.

nuclear power plants. Another commenter requested an explanation as to why USEC requires

a license for 10 percent assay when the license application states that USEC believes its

customers only require 5 percent assay UF6.

2.2.3 Land use

A commenter expressed concern that the increased safety and security restrictions

accompanying the proposed ACP would limit alternative use of the site. In addition, a

commenter stated that the proposed ACP would eliminate the opportunities for cleanup and

reuse of certain facilities on DOE's Portsmouth Reservation, beyond the scope of the USEC

license. Another commenter asked whether the existing contamination cleanup at the site is far

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enough along to ensure protection of site workers. The commenter wondered whether existing

contamination could be cleaned up prior to the start of operations at the ACP. Another

commenter was concerned that the ACP would restrict the possibility of public use of '

undeveloped parts-of the site. Another commenter asked how the proposed ACP will affect

farmland.

2.2.4 Alternatives

Several commenters noted that the draft EIS needs to address the full range of "reasonable

alternatives." Commenters stated that alternative uses for the site, including private leasing and

other governmental uses, must be developed and considered in the draft EIS. A commenter

also stated that the reasonable alternatives must encompass not only the centrifuge buildings,

but a "multiplicity of other uses" for other parts of the site. A commenter suggested instituting

accelerated site cleanup as an alternative to allow the facility to be used for nonnuclear industry

development. Another commenter suggested specifically that the draft EIS should analyze the

Southern Ohio Diversification Initiative suggestion to locate a truck manufacturing company in

one of the buildings. A commenter also suggested that the X-326 building could be entombed

as a National Monument. A commenter stated that the draft EIS should consider expanding the

"Megatons to Megawatts" program as an alternative to licensing the ACP. This commenter also

stated that a reasonable alternative would be to consider reviving the Atomic Vapor Laser

Isotope Separation process because the centrifuge technology concentrates uranium-234. A

commenter suggested moving the environmental cleanup research program located at Oak

Ridge National Laboratory to Piketon since the site will be the subject of ongoing environmental

cleanup.'

Another commenter stated that the cultural value of the Piketon site and the potential adverse

impacts to these resources that have not been studied indicates two alternatives that should be

considered including (1) moving the ACP to the Paducah site, -and (2) opening part of the

Piketon site as a cultural resource park with restoration of the earthworks.-

Commenters also suggested that the draft EIS should analyze scenarios under which the ACP

fails or the project is cancelled. A number of commenters stated that if the plant proceeds and

becomes operational, this will preclude the site from any future use because of security

restrictions and contamination, and will change or eliminate possibilities for reuse of certain

facilities. A commenter stated that the impacts of the no-action alternative should be

considered in terms of the site, not USEC's commitments to DOE to provide enriched uranium

for nuclear fuel. -

Another commenter stated that the draft EIS should focus on evaluating the impacts of a 3.5

million SWU per year plant and that any evaluation of impacts for a 7.0 million SWU per year

plant should be done separately under a different licensing action.

2.2.5 Ecology, air quality, soil and water resources

Ecology: Several commenters stated that the wildlife of the region, including deer and fish,

has been shown to be contaminated with radioactivity and expressed concern about the

migration of wildlife in and out of the plant boundaries. One commenter suggested that

procedures be put into place to ensure that wildlife that travel outside the plant boundaries will

not carry additional contamination into the greater community. Another commenter was

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concerned with the protection of birds and other animal species from future contamination.

One commenter expressed general concern over the impact of air and water emissions on:

wildlife. Another commenter expressed the specific concern that chemical and radioactive

leakage from DUF 8 cylinders might adversely affect fish downstream in the Scioto and Ohio

rivers.

Air Quality and Soil: A number of commenters were concerned about the release of

radioactive materials into air and soil. One commenter asked for a list of the kinds of air

emissions likely to be released from the plant and another thought that emissions should be

monitored by an independent agency.

Water Resources: A number of commenters were concerned with the plant's water usage,

specifically the source of water and estimated volumes that will be used. Many commenters

were concerned that chemical and radioactive leakage from plant operations and waste,

including DUFF cylinders, might adversely affect the groundwater and surface water quality of

the region. Several commenters asked for information about the kinds of contaminants likely to

be released into the water and about current and future stream protection measures. Another

stated that stream sediments have been found to have radioactivity five times the natural levels

as well as increased levels of arsenic, cadmium, chromium, and mercury. The same

commenter stated that Little Beaver Creek has a total uranium level nearly twice the level at

which corrective action would be required at civilian nuclear plants. A commenter asked for the

location of discharge points, any associated discharge standards (especially for radioactive

contaminants), and the consequences for exceeding release limits. Another commenter

requested information about radioactive concentration limits for discharges, and asked who was

responsible for monitoring water discharges. One commenter recommended that an

independent agency be in charge. A commenter recommended that storm-water analysis

include scenarios of extreme climate conditions (i.e., flooding, tomados, earthquakes) that may

be expected to occur over the projected lifetime of the plant. Another commenter stated that as

an alternative to releases in streams and rivers, USEC should consider a "closed lid" system for

managing effluents from plant operations.

2.2.6 Socloeconomics

A number of commenters expressed their support for the approximately 500 permanent highpaying, high-tech jobs and the hundreds of construction jobs that USEC expects to bring to the

region. One commenter was in support of USEC's 'long-term commitment to provide jobs to

this region" and thought that "the plant represents an investment in the future of southern Ohio."

Another expressed the desire to have future job opportunities in the area for his children and

grandchildren. Many commenters stated their belief that having a new $1.5 billion plant will

help boost the local economy. One commenter stated that the presence of a uranium

enrichment facility has not depressed land values or resulted in a decrease in population in Pike

County, like some have claimed. The commenter pointed to the existence of expensive

property values and a 12.5 percent population increase in the last decade.

One commenter stated that the proposed plant would be bad for the local economy. Another

said that the proposed ACP will inhibit the creation of thousands of jobs because a similar

investment of $1.5 billion by any other company should generate 7,000 or 8,000 jobs instead of

the 500 expected for the proposed facility.

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2.2.7 Transportation

A commenter expressed satisfaction with current transportation regulations and specifications

for the materials, construction, and procedures for containerizing/packaging contaminated

material. -The commenter stated that it would be "virtually impossible in a derailment scenario

for contaminated material to get out." Another commenter expressed no confidence that USEC

will actually meet the U.S. Department of Transportation's safety requirements when shipping

radioactive materials. Several commenters had concerns about the safety of road conditions

along the routes across Ohio and to other States like Tennessee, especially in regard to the

transport of radioactive waste. They asked for information regarding evaluations of the roads

for trucks and rail systems for trains and the standard procedures for transporting materials to

and from the facility.

2.2.8 Waste management

General Waste Management: Several commenters stated that waste management must be

analyzed in detail in the draft EIS. A commenter expressed concern that the Piketon site is

already a nuclear waste disposal site and that the ACP will only add to the problem. Another

commenter stated that DOE has already been shipping wastes to Piketon from other sites

including Fernald, Oak Ridge, and Paducah and that the transfers would not happen if the ACP

were not licensed. The commenter stated that there is a need to identify all the wastes that

have been shipped to the site and what will ultimately happen to these wastes. Another

commenter stated that all 'newly generated" waste streams associated with the ACP should be

fully characterized in the draft EIS.

Depleted UF6 Storage and Disposal: An issue raised by numerous commenters concerned

the plans for management of the DUF6 tails currently stored onsite from past operations, similar

wastes from other sites, and those tails expected to be generated as part of the ACP

operations. These commenters stated that the draft EIS must address how much waste will be

generated by the ACP, where the tails will ultimately go, and whether they could potentially be

left onsite for long-term storage. Several commenters indicated that long-term storage of DUF6

onsite at Piketon is not a reasonable waste management alternative. Two commenters noted

that the possible conversion of DUF6 by the DOE could take years (possibly up to 25 years),

with the material being stored onsite in the meantime. A commenter stated that there are

currently thousands of these waste cylinders at Piketon and they present a higher risk of

radiation contamination to the environment. Another commenter noted that the ACP will only

add to the amount of existing DUF6 that needs to be converted or disposed.

Commenters also stated that, prior to licensing, a contract should be in place describing how

and where DUF6 tails will be disposed. A commenter recommended that the draft EIS describe

in detail how much tails disposal will cost and consider the cost of disposal on USEC's ability to

pay for the ACP (including decommissioning). Another commenter asked what limitations

would be placed on the onsite storage of DUF6 and whether any fines for noncompliance would

be sufficient to motivate USEC to remove the wastes from the site for disposal.

2.2.9 Historic and cultural resources

Two commenters stated support for NRC to conduct a separate cultural resources assessment

under Sections 106 and 110 of the National Historical Preservation Act (NHPA) at the Piketon

site. These commenters indicated that DOE, which owns the site, has failed to conduct such

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reviews previously. One commenter indicated that DOE has never attempted to identify

properties that qualify for historic preservation on or near its land in Piketon.

A commenter stated that NRC must consider that in failing to conduct its own Section 106

review properly, DOE may have undermined the legal basis of its agreement with USEC to turn

over its facilities for USEC's use.

One commenter stated that omissions of known archaeological sites in the DOE 'Risk-Based

End-State" report has allowed DOE to avoid its obligation of conducting a thorough cultural

resource impact assessment of the site.

These same commenters indicated that the Piketon site has tremendous historical and

prehistorical value that has never been studied. One commenter indicated that Pike County

has two prehistoric sites (the Piketon Works and the Scioto Township Works), one on DOE's

property and the other extending onto it. The commenter noted a third site (the Barnes Home)

borders the proposed plant and once included land underneath the existing centrifuge plant.

The commenter stated that the Barnes Home is currently under consideration for listing on the

National Register of Historic Places, which qualifies it for full protection.

One commenter stated that the Piketon Works (National Register site 74001599) is located in

the area where DOE uses earthen embankments to shield its water wells, which provide water

to the site. The commenter indicated that pumping from these wells would resume with the

operation of the ACP, but the possible effects of the pumping on the Piketon Works have not

been studied. This same commenter stated that there has not been a recent survey of the

Scioto Township Works (National Register site 74001600).

A commenter stated that DOE should make public a report that was used by USEC to support

its contention that no important cultural resources survive on the site, so that the public can

evaluate its contents.

One commenter argued that claims by DOE, USEC, and NRC that responsibility for adverse

impacts extends only as far as the footprint of the proposed centrifuge plant is incorrect. This

commenter stated that DOE and NRC, as Federal agencies, have the following responsibilities

at the Piketon site:

- To assess the broad range of potential impacts of major Federal actions on

cultural resources as part of the environmental review under NEPA;

- To assess and mitigate adverse impacts of major federal actions on sites that

qualify for the National Register of Historic Places under Section 106 of the

NHPA; and

- To protect and steward any historic or prehistoric resources on federal land

under Section 110 of the NHPA.

The commenter went on to state that NRC must greatly expand the scope of its cultural

resource impact analysis as part of the draft EIS and must conduct its own Section 106 review

in compliance with NHPA. The commenter indicated that a review of the environmental impacts

under NEPA is not a substitute for a Section 106 review unless the agency follows the

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requirements of 36 CFR 800.8(c) regarding notifications, identification of historic properties and

effects, consultation, and resolution of adverse comments. The commenter requested that

NRC include in its review all kinds of effects on all kinds of properties, not simply direct effects

on historic buildings or specific archaeological sites. The commenter noted that it may also be

important for NRC to consider the possible need to address impacts on Native American graves

and cultural items under the Native American Graves Protection and Repatriation Act;

archaeological, historic, and scientific resources under the Archaeological and Historic

Preservation Act; and cultural resources under NEPA.

2.2.10 Cumulative impacts

A commenter expressed concern over the cumulative effect and long-term public health

impacts of building another uranium enrichment facility on the site of a retired one and stated

that the draft EIS should consider this issue with increased scrutiny. Another commenter asked

if the impact analysis considers that the site has existing contamination and that workers and

community members have already had exposure.

2.2.11 Decommissioning

Several commenters expressed concern over USEC's financial standing and whether or not

there was a funding plan for the plant's decontamination and decommissioning. There was

concern that if USEC goes bankrupt; by default, DOE and taxpayer money would be utilized. -

Several commenters pointed out the fact that in 2004, DOE spent almost $300 million in

taxpayer money for cleanup and that the same is projected for 2005. The commenters

recommend that NRC require USEC to create a performance bond, escrow account, or similar

fund sufficient to cover the facility's cleanup prior to issuing a license. One commenter

suggested that Pike County should possibly play a role in paying for the cleanup of the facility.

Others recommended that cleanup costs should be paid by USEC up-front. Commenters also

recommended that a study be done to assess total cleanup, waste storage, and

decommissioning costs. One commenter asked about the existence of monitoring plans for

radioactive landfills when the plant decommissions. The commenter recommended some kind'

of written agreement in advance to ensure that the DOE reservation does not become a waste

dump.

Another commenter requested a detailed account of how Paducah decontamination and

decommissioning operations would impact USEC's ability to pay for the development and

operation of the ACP.

2.2.12 Safety and risk

Plant Safety: A number of commenters expressed confidence in the safety of the ACP, citing

USEC's skilled, highly trained employees, strong employee safety programs and past safety

record, and formalized programs to mitigate potential impacts in the event of emergencies.

One commenter also noted that the likelihood of an accident that could affect the public is

extremely low. Another commenter expressed confidence that USEC will continue to

coordinate with the Ohio Environmental Protection Agency and the NRC, and will continue to

utilize the most sophisticated tools available to assure the safety of its workers and the

community. Another commenter requested information on noncritical, nonexplosive, and

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accidental events that are apparently not contained in USEC's Environmental Report. The

commenter indicated that information on the source of the-contamination and cleanup actions

for these releases should be made available and reviewed. The commenter also'asked for an

explanation of an apparent increase in worker exposure to UF6 over time as seen from the

Contaminated Feed Cleanup Project Dose Trend described in the Environmental Report.

One commenter noted that safety violations in earlier years were due in part to an incomplete

understanding of the technology, putting workers at unnecessary risk. As a result, the

community has taken a stronger interest in the safe operation of the plant. The commenter

noted that it is believed that centrifuge technology is a 'much safer and more efficient

technology." Several commenters highlighted the great improvement in plant safety and efforts

by both union and management working together as a team to ensure that workers and the

public are protected. One person commented that "this plant is one of the safest in the

country."

One commenter requested further information about the extent of personnel training to validate

USEC's statement that "continuing education of employees and a closer monitoring by

management can be used to help alleviate incidents." The commenter also asked about the

procedure for a public alert after accidental releases. Another commenter recommended that

NRC consider the effects of fire and ruptures in process piping in its safety analysis. A

commenter also requested that the draft EIS investigate the claim by USEC that no regulated substances will be stored on the site in excess of threshold levels.

One commenter suggested that USEC's training programs should be reviewed because they

are inadequate to the point where the plant would be unable to operate safely. The commenter

referred to a management culture that "drags its heels to cover up mistakes."

Worker Health and Safety: Several commenters expressed concern over the general health

of employees on the site. One commenter asked about the extent of worker monitoring

programs and if monitoring will be done by an independent entity. Another commenter stated

that 'health issues and premature deaths are not being considered." Another questioned how

occupational health and safety will be guaranteed and how it will be different from what was

previously done during operation of the gaseous diffusion plant. The commenter expressed

concern that USEC needs to be forthcoming and honest about the chemicals and substances

the workers will be exposed to. One cornmenter suggested that NRC take into account a 1985

General Accounting Office report that the Portsmouth Gaseous Diffusion Plant workers had the

highest exposure of any other gaseous diffusion plant. One commenter wanted assurance'

from NRC that USEC will always use the latest technology to enure best possible safety

practices to protect workers and the community.

A commenter also questioned the role of the Ohio Army National Guard workers at the site.

The commenter asked for information on how many of these workers are at the site, where they

are located, and what their role is, if any, in relation to the operation of the ACP.

2.2.13 Nuclear nonproliferation and security

Several commenters stated that operation of the ACP could have nonproliferation impacts. One of these commenters noted that the implications of the proposed ACP are international in

scope. Another commenter indicated that the Carnegie report, 'A Strategy for Nuclear

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Securityw states that production of even lower levels of enriched uranium than proposed at ACP

could have a destabilizing effect on nuclear treaties and initiate a stepped-up arms race.

Similarly, two commenters stated that initiatives such as operation of new uranium enrichment

facilities might actually risk rather than enhance our national security by encouraging other

countries' nuclear weapons initiatives.

In a separate but related comment, one person indicated that the draft EIS should model the

effect of security breaches by USEC.

2.2.14 Terrorism

Two cornmenters expressed concern that the ACP would present a significant risk as a terrorist

target, leading to increased terror alerts. Several commenters recommended studies to

consider scenarios involving terrorist attacks' and to assess security and terrorist risks. A

commenter requested information about measures that will be taken to increase security and

keep 'unauthorized people away from the plant.

2.2.15' Credibility

Several commenters indicated that USEC has a good record as'a corporate citizen and a good

safety record, and people trust that the licernsing process is fair and open. These commenters

stated that they believe the ACP will be operated in'a safe manner, protective of public healthand the environment.': One commenter noted that an important factor is USEC meeting

expectations. One commenter stated, however, that USEC has 16 violation notices, more than

any other NRC materials licensee. 'The bcommenter noted that USEC has been ordered by

NRC to pay civil penalties totaling $378,000. The commenter stated that these past violations

warrant exceptional scrutiny of the license application. A commenter stated that the draft EIS

should model the impacts associated with uranium enrichment in excess of 10 percent, given'

USEC's previous enforcement actions for exceeding its possession limit for such material.

Commenters also questioned the viability-of USEC to see the project through to completion.

Other commenters stated that the draft EIS should critically examine the relationship between '

DOE and USEC.

Other commenters questioned the credibility of past operators of the site, and indicated that this

lack of credibility should be considered when making a licensing decision. A few commenters

described the past practices at the site as an indication that safety during past operations was a

significant issue. For example, one commenter noted plutonium contamination at the site from

past operations, which resulted in monetary compensation for plant workers. Another

commenter noted that a 1985 GAO report states that workers at the Piketon Gaseous Diffusion

Plant had the highest exposures of all the gaseous diffusion plants. Another commenter

indicated that there had been several instances when apparent releases occurred at the site,

but no notification was made to the public regarding these releases. One commenter stated

that all indications point toward the operation'failing and that USEC's promises will not be

fulfilled.

3. SCOPE OF THE ENVIRONMENTAL IMPACT STATEMENT

The NEPA (Public Law 91-190, 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 staff. Regulations established by the Council on Environmental Quality (40 CFR

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I l

Parts 1500-1508), while not binding on NRC staff, provide useful guidance. Additional

guidance for meeting NEPA requirements associated with licensing actions can be found in

NUREG-1748, 'Environmental Review Guidance for Licensing Actions Associated with Office of

Nuclear Material Safety and Safeguards (NMSS) Programs."

Pursuant to 10 CFR 51.71 (a), in addition to public comments received during the scoping

process, the contents of the draft EIS will also address the matters discussed in the USEC

Environmental Report. In accordance with 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, by any affected Indian tribes, and by other

interested persons. Pursuant to 10 CFR 51.71(c), the draft EIS will list all Federal permits,

licenses, approvals, and other entitlements that must be obtained in implementing the proposed

action, and will describe the status of compliance with these requirements. Any uncertainty as

to the applicability of these requirements will be addressed in the draft EIS.

Pursuant to 10 CFR 51.71(d), the draft EIS will include a preliminary analysis that considers and

weighs the environmental effects of the proposed action; the environmental impacts of

alternatives to the proposed action; and alternatives available for reducing or avoiding adverse

environmental effects. 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 responsibilities for environmental protection. The

environmental impact of the proposed action will be evaluated in the draft EIS 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 applicable

environmental quality standards and requirements 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

EIS will also, for the purposes of NEPA, consider the radiological and nonradiological effects of

the proposed action and alternatives.

The following documents are environmental assessments and other ElSs which have been

prepared that are related to the action under consideration. The following list is not intended to

be a comprehensive list:

* Programmatic EIS for Alternative Strategies for the Long-Term Management and Use of

Depleted Uranium Hexafluoride (DOE/EIS-0269, March 1999)

* Environmental Assessment of the USEC Inc. American Centrifuge Lead Cascade

Facility at Piketon, Ohio (DOE/EA-1495, January 2004)

* Environmental Impact Statement for Construction and Operation of a Depleted Uranium

Hexafluoride Conversion Facility at the Paducah, Kentucky, Site (DOE/EIS-0359,

December 2003)

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* Environmental Impact Statement for Construction and Operati6n of a Depleted Uranium

Hexafluoride Conversion Facility at Portsmouth, Ohio Site (DOE/EIS-0360, December

2003)

Pursuant to 10 CFR 51.71(e), the draft EIS will include a preliminary recommendation by the

NRC staff with respect tothe proposed action. ZAny such recommendation would be reached

after considering the environmental effects of the proposed action and reasonable-altematives,

and after weighing the costs and benefits of the proposed action.

The scoping process-summarized in this report will help determine the scope'of the draft EIS for

the proposed facility. The draft EIS will contain a discussion of the cumulative impacts of the

proposed action as referenced in NUREG-1748. The development of the draft EIS will be

closely coordinated with the SER prepared by the NRC staff to evaluate the health and safety

impacts of the proposed action.'

One goal in writing the draft EIS is to present the impact analyses in a mnanner that makes it

easy for the public to understand. This draft EIS will provide the basis for the NRC decision

with regard to potential environmental impacts. Significant impacts will be discussed in greater

detail in the draft EIS, and explanations will be provided for determining the level of detail for

different impacts. This should allow readers of the draft EIS to focus on issues that were

determined to be important in reaching the conclusions supported by the draft EIS. The

following topical areas and issues will be contained within the draft EIS.

* Altematives. The draft EIS will describe and assess the no-action alternative and other

reasonable alternatives to the proposed action. Other altematives may include

alternative sites, enrichment sources, or technological alternatives to the proposed

centrifuge technology.

* 'Need for the Facility. The draft EIS will provide a discussion of the need for the

proposed ACP.

* Compliance with Applicable Regulations.- The draft EIS will present a listing of the

relevant permits and regulations that are believed to apply to the proposed ACP. These

would include air, water, and solid waste regulations and disposal permits.

* -Land Use. The draft EIS will discuss the potential land use impacts associated with the

proposed construction, manufacturing, and operating activities.

* Transportation. The draft EIS will discuss the impacts associated with the transportation

of construction materials, centrifuge parts, feed material,' product, and waste tails during

both normal transportation and under credible accident scenarios. The impacts on local

transportation routes due to workers, delivery vehicles, and waste removal vehicles will

be evaluated.

* Geology and Soils. The'draft EIS will assess the potential impacts to the geology and

soils of the proposed ACP site due to soil compaction, erosion, contamination,

landslides, and disruption of natural drainage patterns: Evaluation of the potential for

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- l lI

earthquakes or any other major ground motion considerations will be addressed mainly

in the SER and only in terms of possible environmental impacts in the draft EIS.

* Water Resources. The draft EIS will assess the potential impacts on surface water and

groundwater quality and water use due to the proposed action and alternatives.

* Ecological Resources. The draft EIS will assess the potential environmental impacts on

ecological resources including plant and animal species. Threatened and endangered

species and critical habitats will also be discussed, along with the appropriate

consultation as required by Section 7 of the Endangered Species Act (16 USC Section

1536(a)(2)). As appropriate, the assessment will include an analysis of mitigation

measures to address potential adverse impacts.

* Air Quality. The draft EIS will make determinations concerning the meteorological

conditions of the site location, the ambient air quality, and the contribution of other

sources. In addition, the draft EIS will assess the impacts of the ACP's refurbishment,

construction, and operation on local air quality.

* Noise. The draft EIS will discuss potential impacts associated with noise levels

generated from refurbishment, construction, and operation of the proposed ACP.

* Historic and Cultural Resources. The draft EIS will address the potential impacts of the

proposed ACP on the historic and archaeological resources of the area. Additionally, as

described in a letter dated December 28, 2004 to the Ohio State Historic Preservation

Officer, the EIS will also be used to fulfill NHPA Section 106 (36 CFR Part 800)

requirements. Potential impacts to the overall visual and scenic character of the facility

may also be addressed.

* Socioeconomics. The draft EIS will address the demography, economic base, labor

pool, housing, utilities, public services, education, and recreation as impacted by the

proposed action and alternatives. The hiring of new workers from the outside area

could lead to impacts on the regional housing, public infrastructure, and economic

resources. Population changes leading to changes to the housing market and demands

on the public infrastructure will be assessed.

* Costs and Benefits. The draft EIS will address the potential cost/benefits of constructing

and operating the ACP, and will discuss the cost/benefits of tails disposition options.

* Resource Commitments. The draft EIS will identify the unavoidable adverse impacts

and irreversible and irretrievable commitments of resources. It will also address the

relationship between local, short-term uses of the environment and the maintenance

and enhancement of long-term productivity. Associated mitigative measures and

environmental monitoring will be presented, if applicable.

* Public and Occupational Health. The draft EIS will include a determination of potentially

adverse effects on human health that result from chronic and acute exposures to

ionizing radiation and hazardous chemicals as well as from physical safety hazards.

These potentially adverse effects on human health might occur during facility

refurbishment, construction, or operation. Impacts associated with the implementation

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of the proposed action will be assessed under normal operation and credible accident

scenarios.

*- Waste Management. The draft EIS will discuss the management of wastes, including

by-product materials, generated from the refurbishment, construction, and operation of

the ACP to assess the impacts of generation, storage, and disposal. Onsite storage of

wastes will also be included in the assessment.

* ~Depleted Uranium Disposal. The draft EIS will discuss the DUF6 material, or tails, that

results from the enrichment operation over the lifetime of the proposed plant's operation.

These concerns include the safe and secure storage and ultimate removal of the

material from the site, and the potential conversion of the DUF6 to U308 and ultimate

disposition.

* Decommissioning. The draft EIS will include a discussion of facility decommissioning

and associated impacts.

* Cumulative Impacts. The draft EIS will address the potential cumulative impacts from

past, present, and reasonably foreseeable activities at and near the site

* Environmental Justice. The draft EIS will address environmental impacts of the

proposed ACP on low-income or minority populations if disproportionately high and if

low-income or minority populations are identified. The impacts that could be evaluated

include health, ecological (including water quality), social, cultural, and economic

resources.

4. ISSUES CONSIDERED TO BE OUTSIDE THE SCOPE OF THE ENVIRONMENTAL

IMPACT STATEMENT

The purpose of an EIS is to assess the potential environmental impacts of a proposed action in

order to assist in an agency's decision-making process - in this case, NRC's licensing decision.

As noted in Section 2.2, some issues and concerns raised during the scoping process are not

relevant to the draft EIS because they are not directly related to the assessment of potential

impacts or to the decision-making process. The lack of in-depth discussion in the draft EIS,

however, does not mean that an issue or concern lacks value. Issues beyond the scope of the

draft EIS either may not yet be at the point where they can be resolved, or are more

appropriately discussed and decided in other venues.

Some of the issues raised during the public scoping process (e.g., the Carnegie Report, the

uHobson Doctrine," and the uMegatons to Megawatts" program) will not be addressed in the

draft EIS. Other issue areas including nonproliferation concerns, security and safety issues

(e.g., the domino effect, tornado effects due to climate change), and credibility are also beyond

the scope of the EIS. In The Matter of Private Fuel Storage, LLC (Independent Spent Fuel

Storage Installation), 56 NRC 340 (2002), the Commission held that NRC staff is not required to

consider terrorism in its ElSs. The Commission indicated, "the possibility of a terrorist attack...is

speculative and simply too far removed from the natural or expected consequences of agency

action to require a study under NEPA."

Some of the issues raised during the public scoping process for the proposed facility are

outside the scope of the draft EIS, but they will be analyzed in the SER. For example, health

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I,

and safety issues will be considered in detail in the SER prepared by NRC staff for the

proposed action and will be summarized in the EIS. The draft EIS and the SER are related in

that they may cover the same topics and may contain similar information, but the analysis in the

draft EIS is limited to an assessment of potential environmental impacts. In contrast, the SERprimarily deals with safety evaluations and procedural requirements or license conditions to

ensure the health and safety of workers and the general public. The SER also covers other

aspects of the proposed action such as demonstrating that the applicant will provide adequate

funding for the proposed facility in compliance with NRC's financial assurance regulations.

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1.
1 APPENDIX 

B

2 CONSULTATION LETTERS
December 28, 2004

Mr. Mark Epstein, Department Head

Ohio Historic Preservation Office

Resource Protection and Review

567 East Hudson Street

Columbus, OH 43211-1030

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT

SECTION 106 PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Epstein:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas

centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium -235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two preliminary phase I archaeological surveys and one draft cultural resource report have

been completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed).

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding other parties that may be entitled to be consulting parties by this action. As required

by 36 CFR 800.4(a), the NRC is requesting the views of the State Historic Preservation Officer

and your office on further actions to identify historic properties that may be affected by the

proposed ACP.

B-1
If

M. Epstein -2-

As part of the EIS preparation, the NRC will be hosting a public scoping meeting on Tuesday,

January 18, 2005, at the Zahns Comer Middle School in Piketon from 7:00 - 9:45. The meeting

will include NRC staff presentations on the environmental review process, after which members

of the public will be given the opportunity to present their comments. This scoping information,

along with any information you provide, and material provided by USEC in the ER, will be used

to document affects in accordance with 36 CFR 800.4 and 800.5. Additionally, we intend to use

the EIS process for Section 106 purposes as described in 36 CFR 800.8.

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRAJ

B. Jennifer Davis, Chief

Environmental and Performance

Assessment Branch

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-2
Ohio Historic Preservation Office

567 East Hudson Street

Columbus. Ohio 43211-1030

6141298.2000 Fax:6141298-2037

Visit us at www.ohohistoorg

- ~OHIO : - February2,2D -- HISTORICAL SOCIETY

Ron nionSINCE 1885 Environmental and Performance Assessment Branch

Nuclear Regulatory Commission

Washington, DC 20555-0001

Re: Docket No. 70-7004, American Centrifuge Commercial Plant

Portsmouth Gaseous Diffusion Plant (PORTS), Pike County, Ohio -

Dear Mr. Unton,

This Is In response to correspondence from your office dated December 28,2004 (received January 3)

regarding the above referenced project. The comments of the Ohio Historic Preservation Office (OHPO)

are submitted in accordance with provisions of the National Historic Preservation Act of 1966, as

amended (16 U.S.C. 470 L36 CFR 800]); the Department of Energy serves as the lead federal agency.

Your correspondence initiates consultation by the Nuclear Regulatory Commission (NRC) for the above

referenced project. We acknowledge that the NRC will be following regulations at 36 CFR 800.8 in the

review process Integrating the Section 106 review with the development of the Environmental Report (ER)

for this project. Your correspondence also requests Information on consulting parties.

This office has previously reviewed Information on the proposed project and has responded to the position

that the proposed new construction will include buildings of similar design and size to the nearby buildings

and that there will be similar functions carried out In these new buildings. Given the available Information

on the size, design, and function of the existing and the proposed buildings, we were able to offer our

opinion that the proposed project will not adversely affect the Portsmouth Gaseous Diffusion Plant historic

property.

As you are aware, private citizens have raised concerns about the potential for this project to affect:

historic properties, Including prehistoric archaeological sites. The National Historic Preservation Act

encourages federal agencies to Include comments and concerns from the public throughout the Section

106 review process.

In addition to other consulting parties that your agency may have identified, we recommend that you

consider notifying Native American Federally-Recognized Tribal authorities that are historically associated

with south-central Ohio and mayhave Information on historic properties in this area. Attached please find

a partial list of Tribes with historical ties to Ohio. We believe that this list may be helpful in finalizing your

list of potential consulting parties to whom you will be providing notification of the project.

I think that It Is Important for you to clearly convey to consulting parties and to the public the extent of the

efforts to identify historic properties and to assess the potential for the project to adversely affect historic

properties. I am concerned that the discussions In your correspondence and In the attached sections from

the draft ER should be clearer and more precise. For example, the archaeological surveys were not

preliminary, but their conclusions are preliminary and we are still working at interpreting the results and

developing a consensus on the findings. In some cases it might be appropriate to describe an

archaeological survey as preliminary, especially when the primary objective of the work for a survey Is to

B-3
Mr. Ron Union

February 2, 2005

Page 2

lay the ground work for the next phase of an Intended and expected survey. The predictive model work

that you reference might be described as preliminary but it also provides important information on the

distribution of known sites In the vicinity of the Portsmouth Gaseous Dilfusion Plant. Also, at least one

additional archaeological study has been conducted within the facility at archaeological site 33-PK*21 0.

This study may not be relevant to this project, but language in the draft ER might lead some to conclude

that all of the previous archaeological work Is referenced rather than only a portion of the previously

completed work. The survey methods employed In the predictive model work are likely quite different

from the survey methods employed In IdentificatIon efforts.

I think that it would be more helpful to describe the conclusions of the Schweikart 1997 archaeological

survey as recommendations, not as determTnatlons. In the past we have encountered some confusion in

descriptions of known archaeological sites both within and In the general area surrounding the facility. For

example, not all archaeological sites with prehistoric components are burial grounds and many

archaeological sites are quite small, less than 100 square meters.

Similar kinds of concerns could also be raised concerning the presentation of the information on

architectural properties in the Environmental Report.

In summary, it would be helpful for the documentation to provide greater clarity and to provide greater

precision to facilitate the integration the discussions on archaeological sites, architectural properties, and

other kinds of cultural resources within the overall assessment of effects.

Any questions concerning this matter should be addressed to David Snyder at (614) 298-2000, between

the hours of 8 am. to 5 pm. Thank you for your cooperation.

Sincerely,

David Snyder, Archaeology Reviews Manager

Resource Protection and Review

DMS/ds (OHPO Seiiai Number 105834)

Enclosure

84
To assist you In the event that consultation with federally recognized tribal authorities is needed,

OHPO maintains a list of federally recognized tribal authorities including listings from the Bureau of

Indian's Affairs' Tribal Leadets Directory. 'This list Is not all-inclusive; it represents a first step In'

developing procedures to address issues of disposition and repatriation. There are currently no

federally recognized tribal authorities in Ohio since Ohio does not have any Native American

Reservations or Land. However, there are many active Native American groups and organizations

in Ohio. Also, In some cases, the Ohio Historic Preservation Office may be able to assist agencies

and individuals contact Individuals who have expressed an Interest In the issues involving reburial.

If the need develops we can provide assistance to get you started In compiling a list of Interested

parties.

Endnote. For further information, you may wish to contact the following:

Tim McKeown, National Center for Cultural Resources, National Park Service, P.O. Box

37127, Washington, D.C. 20013-7127, (202) 343-1142

Francis McManamon, National Center for Cultural Resources, National Park Service, P.O.

Box 37127, Washington, D.C. 20013-7127, (202) 343-4101

The following are representatives of Federally-recognized Tribal Authorities of some tribes having

historic connections to Ohio (basied on the Tribal Leaders Directory, Bureau of Indian Affairs,

Division of Tribal Govemment Services, January 1992- for more information phone: 202/208--

4400):

B-5
I I

Mr. James Leaffe, Chief

Cayuga Nation

P.O. Box 11

Versailles; NY. 14168

Attn: Mr. Clint Halftown, THPO

Representative

Telephone: 716-532-4847

Cherokee Nation of Oklahoma

P.O. Box 948

Ada, OK 74820

Turtle Mountain Band of Chippewa Indians

P.O. Box 900

Belcourt, ND 58316

Attn: Mr. Kade M. Ferris, Tribal Historic

Preservation Officer, Office of

Archaeology and Historic

Preservation

THPO: Mr. Kade M. Ferris

Mr. Bruce Gonzales, President

Delaware Tribe of Western Oklahoma

P.O. Box 825

Anardarko, OK 73005

Attn: Ms. Tamara Francis, Delaware

Nation NAGPRA Office

Tclephone: 405-247-2448

FAX: 405-247-9393

Email: aapanahkih@westemdelaware.nsn.us

Mr. John Pryor, Executive Officer

Miami Tribe of Oklahoma

P.O. Box 1326

202 South Eight Tribes Trail

Miami, OK 74355

Attn: Ms. Julie Olds, THPO

THPO: Ms. Julie Olds

Telephone: 918-542-1445 Xl6 (Olds)

FAX: 918-542-7260

Email: jolds@miamination.com

Mr. Charles Todd, Chief

Ottawa Tribe of Oklahoma

P.O. Box 110

Miami, OK 74355

Attn: Mr. Roy Ross

Telephone: 918-540-1536

FAX: 918-542-3214

Mr. John P. Froman, Chief

Peoria Tribe of Oklahoma

P.O. Box 1527

118 S. Eight Tribes Trail

Miami, OK 74355

Attn: Mr. Bud Ellis, Repatriation

Committee Chairman

Telephone: 918-540-2535

FAX: 918-540-2538

Mr. Harold Frank, Chairperson

Forest County Potawatomi

P.O. Box 340

Community of Wisconsin Potawatomi

Crandon, WI 54520

Attn: Ms. Clarice M. Werle, NAGPRA

Tclephone:

FAX:

Contact

715-478-7381 (Werle)

715-478-7385

Mr. John A. Barrett, Jr., Chairperson

Citizen Potawatomi Nation

1601 S. Gordon Cooper Drive

Shawnee, OK 74801

Attn: Mr. Jeremy Finch

Telephone: 405-275-3121

FAX: 405-275-0198

800 Number: 800-880-9880

Mr. Calvin John, President

Seneca Nation of Indians

P.O. Box 231

Salamanca, NY 14779

Attn: Ms. Kathleen Mitchell, THPO

TIHPO: Ms. Kathleen Mitchell

Telephone: 716-945-9427

FAX: 716-945-1989

Email: snithoo(i-netscape.net B-6
Mr. Jerry Dilliner, Chief

Seneca-Cayuga Tribe of Oklahoma

P.O. Box 1283

R2301 E. Steve Owens Blvd.

Miami, OK 74355

Attn: Mr. Paul Barton

Telephone: 918-542-6609

FAX: 918-542-3684

Email: maimit5fonenet.net

Mr. Charles D. Enyart, Chief

Eastern Shawnee Tribe of Oklahoma

P.O. Box 35D

Seneca, MO 64865

Attn: R.C. Kissee

Telephone- 918-666-2435X241

FAX: 918-666-3325

Email: estochieftlhotmail.com

Mr. James Squirrel

Loyal Shawnee Tribe

Route 4, Box 30

Jay, OK 74346

Mr. Kenneth Daugherty, Tribal Secretary

Absentee-Shawnee Tribe of Oklahoma

2025 S. Gordon Cooper Drive

Shawnee, OK 74801-9381

Attn: Ms. Karen Kaniatobe

Telephone: 405-275-4030 X124

FAX: 405-275-1922

Email: lenniferme-astribe.com

Mr. Leaford Bearskin, Chief

Wyandotte Nation

P.O. Box 250 -

Wyandotte, OK 74370

Attn: Ms. Sherri Clemons

B-7
J I I

March 14, 2005

Mr. James Leaffe, Chief

Cayuga Nation

P.O. Box 11

Versailles, NY 14168

Attn: Mr. Halftown, THPO

Representative

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Leaffe:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-8
J. Leaffe - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRA/

B. Jennifer Davis, Section Chief,

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety.

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-9
March 14, 2005

Cherokee Nation of Oklahoma

P.O. Box 948

Ada, OK 74820

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Cherokee Nation of Oklahoma:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 1 0-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-10
Cherokee Nation of Oklahoma - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRA

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-1I
March 14, 2005

Turtle Mountain Band

of Chippewa Indians

Attn: Mr. Kade M. Ferris

Tribal Historic Preservation Officer

Office of Archaeology

and Historic Preservation

P.O. Box 900

Belcourt, ND 58316

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Ferris:

The United States Nuclear Regulatory Commission (NRC) has received a license application from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-1 2
K. Ferris - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRA,

B. Jennifer Davis, Section Chief

Environmental and Low-Level

* Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-13
1.

March 14, 2005

Mr. Bruce Gonzales, President

Delaware Tribe of Western Oklahoma

P.O. Box 825

Anardarko, OK 73005

Attn: Ms. Tamara Francis, Delaware

Nation NAGPRA Office

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Gonzales:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas

centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing

if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-14
B. Gonzales -2-

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRA/

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste.Management,

Hand Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

.. I

- .; 7

B-15
lo

March 14, 2005

Mr. John Pryor, Executive Officer

Miami Tribe of Oklahoma

P.O. Box 1326

202 South Eight Tribes Trail

Miami, OK 74355

Attn: Ms. Julie Olds, THPO

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Pryor

The United States Nuclear Regulatory Commission (NRC) has received a license application from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

8-16
-

J. Pryor - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

/RA

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-17
March 14, 2005

Mr. Charles Todd, Chief

Ottawa Tribe of Oklahoma

P.O. Box I 1 0

Miami, OK 74355

Attn: Mr. Roy Ross

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Todd:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas

centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 1 0-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing

if you have specific knowledge of any sites that ybu believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

818
C. Todd -2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRAN

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-19
- -I.

March 14, 2005

Mr. John P. Froman, Chief

Peoria Tribe of Oklahoma

P.O. Box 1527

118 S. Eight Tribes Trail

Miami, OK 74355

Attn: Mr. Bud Ellis, Repatriation

Committee Chairman

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Froman:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas

centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing

if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

8-20
J. Forman - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRAJ

B. Jennifer Davis, Section Chief

Environmental and Low-Level -

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure:-Section 3.8 and 4.8 Environmental Report

B-21
March 14, 2005

Mr. Harold Frank, Chairperson

Forest County Potawtomi

P.O. Box 340

Community of Wisconsin Potawtomi

Crandon, WI 54520

Attn: Ms. Clarice M. Werle, NAGPRA

Contact

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Frank:

The United States Nuclear Regulatory Commission (NRC) has received a license application from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-22
H. Frank

If you any questions or comments, or need

(301) 415-7777.

-2 -

additional information, please contact Ron Linton at

Sincerely,

IRAJ

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report - . . . .

.

.

..... .. . . .

. - . . .

. . ...

-

. 7

B-23
U

March 14, 2005

Mr. John A. Barret, Jr., Chairperson

Citizen Potawatomi Nation

1601 S. Gordon Cooper Drive

Shawnee, OK 74801

Attn: Mr. Jeremy Finch

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Barrett:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas

centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing

if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-24
J. Barrett - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

/RAI

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-25
March 16, 2005

Mr. Calvin John, President

Seneca Nation of Indians

P.O. Box 231

Salamanca, NY 14779

Attn: Ms. Kathlenn Mitchell, THPO

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. John:

The United States Nuclear Regulatory Commission (NRC) has received a license application from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP).. The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (e, the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-26
C. John - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRAI

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

- -and Environmental Protection

Office of Nuclear Mate'rial Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-27
March 14, 2005

Mr. Jerry Dilliner, Chief

Seneca-Cayuga Tribe of Oklahoma

P.O. Box 1283

R2301 E. Steve Owens Blvd.

Miami, OK 74355

Attn: Mr. Paul Barton

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Dilliner

The United States Nuclear Regulatory Commission (NRC) has received a license application from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-28
J. Dilliner - 2-

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRAI

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

. . I

.. ... . .

. .

... . .

- . .

. . .

Be29
I'

March 14, 2005

Mr. Charles D. Enyart, Chief

Eastern Shawnee Tribe of Oklahoma

P.O. Box 350

Seneca, MO 64865

Attn: R.C. Kissee

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Enyart:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas

centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing

if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-30
-

C. Enyart - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRA/

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-31
1.

March 14, 2005

Mr. Kenneth Daughtery, Tribal Secretary

Absentee-Shawnee Tribe of Oklahoma

2025 S. Gordon Cooper Drive

Shawnee, OK 74801-9381

Attn: Ms. Karen Kaniatobe

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Daughtery:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas

centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing

if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-32
K. Daughtery - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

/RAB. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

.. . r :; .

B-33
11

March 14, 2005

Mr. James Brushart

President, Pike County Commissioners

230 Waverly Plaza, Suite 1000

Waverly, Ohio 45690

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Brushart:

The United States Nuclear Regulatory Commission (NRC) has received a license application from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing

if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-34
J. Brushart - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

/RAI

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-35
March 14, 2005

Mr. Leaford Bearskin, Chief

Wyandotte Nation

P.O. Box 250

Wyandotte, OK 74370

Attn: Ms. Sherri Clemons

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Bearskin:

The United States Nuclear Regulatory Commission (NRC) has received a license application from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). .The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-36
L. Bearskin - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

/RAI

B. Jennifer Davis, Section Chief

-Environmental and Low-Level

Waste Section -

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-37
March 14, 2005

Mr. James Squirrel

Loyal Shawnee Tribe

Route 4, Box 30

Jay, OK 74346

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Squirrel:

The United States Nuclear Regulatory Commission (NRC) has received a license application from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B-38
J. Squirrel -2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

/RAI

B..Jennifer Davis, Section Chief -

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-39
March 18, 2005

Mr. Ron Sparkman

Shawnee Tribe

P.O. Box 189

Miami, OK 74355

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Sparkman:

The United States Nuclear Regulatory Commission (NRC) has received a license application from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmental Report (ER) that will be used to support the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B40
R. Sparkman -2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

/RAI

B. Jennifer Davis, Section Chief

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-41
It

March 18, 2005

Mr. Rey Kitchkumme

Prairie Band of Potawatomi Nation

16277 Q Road

Mayetta, KS 66509-8970

SUBJECT: INITIATION OF THE NATIONAL HISTORIC PRESERVATION ACT SECTION 106

CONSULTATION PROCESS FOR THE PROPOSED AMERICAN CENTRIFUGE

COMMERCIAL PLANT, PIKE COUNTY, OHIO

Dear Mr. Kitchkumme:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

NRC is in the initial stages of developing an Environmental Impact Statement (EIS) for the

proposed facility to be located at the Department of Energy (DOE) reservation in Piketon, Ohio.

USEC's license application contained an Environmenta! Report (ER) that will be used to support

the NRC's development of an EIS for the ACP. The proposed facility will use gas centrifuge

technology to enrich the isotope Uranium-235 in uranium hexaflouride (UF6), up to 10-weight

percent. The proposed ACP will have a design capacity of seven million separative work units.

The forthcoming EIS will document the impacts associated with the construction, operation, and

decommissioning of the facility.

Two phase I archaeological surveys and one draft cultural resource report have been

completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed section 3.8 of the ER (enclosed). Historical and cultural resource impacts are

discussed in section 4.8 of the ER (enclosed). The Area of Potential Effects (APE) is defined

as the DOE reservation in Piketon, Ohio.

As required by 36 CFR 800.3 (f), the NRC is requesting any information you may have

regarding historic sites or cultural resources within the APE. The NRC is interested in knowing

if you have specific knowledge of any sites that you believe have traditional religious and

cultural significance. In addition, we are interested in knowing if you are aware of or are

concerned for any site, or object, eligible for inclusion on the National Register of Historic

Places. This will assure appropriate consideration in the Section 106 process.

Any information you provide may be used to document affects in accordance with 36 CFR

800.4 and 800.5. Additionally, we intend to use the EIS process for Section 106 purposes as

described in 36 CFR 800.8.

B42
-

R. Kitchkumme - 2 -

If you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

/RAI

B. Jennifer Davis, Section Chief.

Environmental and Low-Level

Waste Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

I -

Docket No.: 70-7004

cc: USEC Service List

Enclosure: Section 3.8 and 4.8 Environmental Report

B-43
II

PEORIA TRIBE OF INDIANS OF OKLAHOMA '

118 S. Eight Tirbes Trall (918) 540-2535 FAX (918)540-2538 JoHIEP.Fra

P.O. Box 1527

MIAMI, OKLAHOMA 74355 SECOND CHIEF

Joe Goforth

Q @Q //24z//? /

6f/we 7B(

March 23, 2005

Chief, Rules and Directives Branch __ _

-Division of Admi nifve ic- s__-_ -- 

Mail Stop T-6 D59

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

RE: Initiation of the National Historic Reservation Act Section 106 Consultation Process for the

Proposed American Centrifuge Commercial Plant, Pike County, Ohio

Thank you for notice of the referenced project. The Peoria Tribe of Indians of Oklahoma is currently

umaware of any documentation directly linking Indian Religious Sites to the proposed construction. In the

event any items falling under the Native American Graves Protection and Repatriation Act (NAGPRA)

are discovered during construction, the Peoria Tribe request notification and firther consultation.

The Peoria Tribe has no objection to the proposed construction. However, if any human skeletal remains

and/or any objects falling under NAGPRA are uncovered during construction, the construction should

stop immediately, and the appropriate persons, including state and tribal NAGPRA representatives

contacted.

John P. Froman

Chief

xc: Bud Ellis, RepatriationlNAGPRA Committee Chairman

TREASURER SECRETARY FIRST COUNCILMAN SECOND COUNCILMAN THIRD COUNCILMAN

John Sharp Hank Downrn Claude8*lders Jennypimpey Jason Dode

>eZ zd -,Im /3 /. A Z(/ FP)

B-44
I

I, )n Linton - 106 Consultation -pagei I

fl UfltOfl -106 Consultation Page 11

From: 'Eastem Shawnee Tribe Chief Enyart' <estochiefthotrmafl.com>'

To: crcl1 Onrc.gov>

Date: 6/3/05 4:52PM

Subject: 106 Consultati6r

June 3. 2005

RE: PROPOSED AMERICAN CENTRIFUGE COMMERCIAL PLANT, PIKE COUNTY, OH

To Whom It May Concern:

Thank you for notice of the referenced project(s). The Eastern Shawnee

Tnbe of Oklahoma Is currently unaware of any documentation directly linking

Indian Religious Sites to the proposed construction. In the event any items

falling under the Native American Graves Protection and Repatriation Act

(NAG PRA) are discovered during construction, the Eastern Shawnee Tribe

request notification and further consultation.

.. I . 1 I

The Eastern Shawnee Tribe has no objection to the proposed construction.

However, If any human skeletal remains and/or any objects falling under

NAGPRA are uncovered during construction, the construction should stop

Immediately, and the appropriate persons, Including state and tribal NAGPRA

representatives contacted.

Sincerely,

Jo Ann Beckham, Administrative Assistant

Eastern Shawnee Tribe of Oklahoma -

B45
. I .I

* eneca 5ZNaion Yrihat Elistoric £Presert'iion.

£Kafhlei 3. 0. 4iikel1

office

467 Center St. Salarnanca. NY 14779

Phone: (7161 945-9427 -. Fax: (716) 945-0351

-.ERTil: snithpoS(nycbnhty.com

: * - *- *

* Xana;9lC CWalU

Cultural Resource Tec.

April 5, 2005

Attention: Mr. Ron Linton

MS T7Jos

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

RE: Proposed Armerican Centrifuge C

Dear Mr. Linton,

Our office has completed'a re6

referenced project proposal?.ii

requesting that copiesCfh i1e]

completed Phase II ripoits be

These commnents areioffered tc

Historic Preservation' Act of 1'

Respectfully,

Kathleen Mitchell

Tribal Historic Preservation 0

ng the above

r of the project we are

is along with any

,si convenience.

16 ,of the National

B46

I I
May 20, 2005

ACHP, Office of Federal Agency Programs

Attention: Don Klima, Director

1100 Pennsylvania Avenue NW, Suite 809

Washington, D.C. 20004

SUBJECT: COORDINATION OF NATIONAL HISTORIC PRESERVATION ACT

SECTION 106 REQUIREMENTS AND NATIONAL ENVIRONMENTAL POLICY

ACT REVIEW FOR THE PROPOSED AMERICAN CENTRIFUGE PLANT, PIKE

COUNTY, OHIO

Mr. Klima:

The United States Nuclear Regulatory Commission (NRC) has received a license application

from USEC, Inc. (USEC) for the construction, operation, and decommissioning of a gas

centrifuge uranium enrichment facility known as the American Centrifuge Plant (ACP). The

proposed facility is to be located at the Department of Energy (DOE) reservation in Piketon,

Ohio. USEC's license application contained an Environmental Report (ER) that will be used to

support the NRC's development of an environmental impact statement (EIS) as required by the

NRC's National Environmental Policy Act (NEPA) implementing regulations. The proposed

facility will use gas centrifuge technology to enrich the isotope uranium-235 in uranium

hexaflouride (UF6), up to 10-weight percent. The proposed ACP will have a design capacity of

seven million separative work units. The forthcoming EIS will document the impacts associated

with the construction, operation, and decommissioning of the proposed facility.

Two preliminary phase I archaeological surveys and one draft cultural resource report have

been completed for the DOE reservation. Archaeological surveys and the cultural report results

are discussed in section 3.8 of USEC's ER (enclosed). Historical and cultural resource impacts

are discussed in section 4.8 of USEC's ER (enclosed).

As described in 36 CFR 800.8 we are notifying you that we intend to use the NRC's NEPA

review process for Section 106 purposes. In using the NRC's NEPA process in lieu of the

procedures set forth in 36 CFR 800.3 through 800.6 we will ensure the standards set forth in

800.8(c)(1) through 800.8(c)(5) are met.

We have previously notified the Ohio State Historical Preservation Officer of our intent to utilize

the NRC's NEPA review process to comply with Section 106 requirements in a letter dated

December 28, 2004 (enclosed). Additionally, we have solicited information from 17 Indian

tribes and one local official in letters dated March 14, 2005 and March 18, 2005. Also, as part

of our NEPA review process, we hosted a NEPA public scoping meeting on January 18, 2005,

in Piketon, Ohio. At this meeting, we solicited information on cultural and historic properties. A

full transcript of this meeting as well as all project related correspondence is available at the

NRC's public web site: http://www.nrc.gov/reading-rm/adams.html.

1-47
-2-

We plan to a issue the draft EIS in September 2005 and will include you in our distribution. If

you any questions or comments, or need additional information, please contact Ron Linton at

(301) 415-7777.

Sincerely,

IRA/

B. Jennifer Davis, Section Chief

Environmental Review Section

Division of Waste Management

and Environmental Protection

Office of Nuclear Material Safety

and Safeguards

Docket No.: 70-7004

cc: USEC Service List

Enclosures:

1. Section 3.8 and Section 4.8 of USEC's Environmental Report (ML043550029) 2. December 28, 2004 letter to Ohio SHPO (ML043520095)

B48

l I
I APPENDIX 

C

2 RADIOLOGICAL DOSE ANALYTICAL METHODOLOGY
1 - APPENDIX C

2 RADIOLOGICAL DOSE ANALYTICAL METHODOLOGY

3

4 This appendix discusses the following topics:

6 * The dose assessment analysis for site' preparation and construction activities for the proposed ACP;

7 and

8

9 * Environmental transport and calculation of dose and risk.

10

11 C.1 Radiological Impacts from Site Preparation and Construction

12

13 Radiological impacts during site preparation and construction are primarily to the construction workers

14 performing those activities. Exposures to off-site personnel are greatly below those of the construction

15 workers themselves because of atmospheric dispersion of airborne material and distance from'sources of

16 external dose.

17

18 C.1.1 Dose to Construction Workers During Site Preparation and Construction

19

20 The primary modes of exposure for construction personnel are: (1) inhalation of radionuclides that are in

21 the dust suspended by construction activities; (2) external exposure from radionuclides contained in the

22 soil suspended in the air; (3) external exposure from radionuclides in the soil on the ground; and'(4)

23 external exposure from existing sources nearby on the site.

24

25 C.1.1.1 Construction Worker Exposure from Inhalation of Radionuclides in Air

26

27 The dose and risk calculation for inhalation is based on the methods of Federal Guidance Report 13

28 (EPA, 1999), which are themselves based on the models recommended by the International Commission

29 on Radiological Protection. In this method, the computation of committed effective dose equivalent for a

30 nuclide is arrived at by computing the intake quantity of the nuclide and multiplying that amount by a

31 coefficient that converts intake quantity to committed effective dose equivalent.

32

33 The following linear exposure model will be used to calculate inhalation dose of the ith radionuclide from

34 inhalation:

35

36 XCdxDCF,

36 DSR1i 1 - (Eq. 1)

37

38 where:

39 B = the volume of air inhaled per hour (m3/hr)

40 Cd the concentration of respirable dust in the air (ghm3)

41 DCFi = the adult inhalation dose conversion factor of radionuclide i from Federal Guidance

42 Report 13 (mrem/pCi)

43 Fp the assigned protection factor for respirators from 10 CFR 20 Appendix A (NRC, 1991)

44 -

45 Dose Conversion Factors in Federal Guidance Report 13 are a function of not just the radionuclide, but

46 also the inhalation Type. The Type classification scheme, introduced in International Commission on

47 Radiation Protection Publication 66 (ICRP, 1994), rep~laced the inhalation Class nomenclature previously

48 used in most inhalation dose modeling. Inhalation Type is one of three values, F, M, or S. The dose

49 conversion factor selected for a nuclide in ihis analysis will be the default fecommended Type listed in

C-l
I Federal Guidance Report 13 if one exists. If a default recommended Type does not exist, then Type M

2 will be used.

3

4 For a few elements, the Dose conversion factor is also a function of the chemical state. For example, the

5 Dose conversion factor for tritium (H-3) in Federal Guidance Report 13 is not only a function of Type,

6 but also a function of whether the tritium is bound as a particulate, water vapor, organic, or in an7 elemental state. The element of interest in this analysis is uranium, for which Federal Guidance Report

8 13 has dose factors for only the particulate state.

9

10 Federal Guidance Report 13 contains dose conversion factors as a function of age. This analysis uses the

11 adult dose conversion factors since all workers are expected to be over the age of 18. Federal Guidance

12 Report 13 also contains risk coefficients for both mortality and morbidity that are analogous to the Dose

13 Conversion Factors. An inhalation mortality risk for each isotope can be calculated using the same

14 equation, but replacing the Dose Conversion Factor for an isotope with an analogous mortality risk

15 coefficient from Federal Guidance Report 13.

16

17 The total inhalation dose from all radionuclides can be estimated by summing all the inhalation doses

18 from the individual radionuclides.

19

20 TotalInhalationDose = EdE(DSRm,,1xA 1) (Eq. 2)

21

22 where

23 Ai = the activity concentration of radionuclide i in dust (pCi/g)

24 Ed = the number of hours per year that the worker is exposed (hr/yr)

25

26 The inhalation analysis uses the following parameters, which provide for an analysis that should produce

27 a high estimate of dose:

28

29 * 40 hours/week exposure, 48 weeks per year at job site (52 less 2 vacation and 2 weeks equivalent for

30 holidays/sick time);

31

32 * No respiratory protection (Fp = 1);

33

34 * Breathing Rate is 1.4 cubic meters per hour from EPA Exposure Factors Handbook (EPA, 1997);

35

36 * The average uranium concentration in soil is 7.7 micrograms per gram soil from Table 3.3.2-1 in the

37 ACP Environmental Report (USEC, 2004);

38

39 * On-site air contains 313 micrograms of soil per cubic meter (maximum hourly concentration from

40 construction air modeling results);

41

42 * All the soil in the air comes from on-site soil with the average uranium concentrations; there is no

43 contribution from off-site;

44

45 * The uranium in the soil is Type F for selecting inhalation dose conversion factors, technicium-99 is

46 type S. These provide the maximum dose conversion factors;

47

48 * Technicium-99 activity in soil is one half of the maximum value in Table 3.3.2-1 of USEC, 2005; and

49

50 * All radioactive materials in the air exist in a fully respirable particle size.

C-2

! I
1 The isotopic activity ratio for the site should average to approximately natural uranium. The mass

2 fractions for the various isotopes of uranium are thus expected to be 0.9926 uranium-238, 0.0073

3 uranium-235, and 0.000054 uranium-234. The activity ratio is then the specific activity times the mass

4 fraction as seen in Table C-l:

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

Table C-1 Site Isotopic Activity Ratio

IMass F .t Specific Activity A c . Activity in Soil

Isotope rac non Ci/gram _____ pCi/gram

U-234 * 5.4 x 10-5. 6.2 x 1003 3.4 x i07 - 2.59

U-235 7.3 x 10 2.2 x 10 - . 1.6 x 10" 0.12

U-238 

- 2 . . 9.9x 1 ------.- !3 3 x 0f -3--- 3.3 x10 ------. ---- 22.57

Tc-99 . - . - . - 6.3

Notes:

Ci = curie; pCi = picocuric.

Information on isotopic ratios of natural uranium and specific activity is from the Chart of the Nuclides,

Twelfth Edition, General Electric Company, San Jose, CA, 1977.

The uranium activity concentration in soil is then calculated from

Ai = 102xARx C (Eq. 3)

where:

Ai

AR.

C

1012

= the isotopic activity in soil in pCi/gram for isotope i;

= the activity ratio for isotope i in Ci/gram of uranium;

= the concentration of uranium in the soil in microgram U/gram soil;

= a factor to convert Ci to pCi.

Table C-2 describes the resulting dose from inhalation by isotope:

Table C-2 Inhalation Dose by Isotope

Isotope Type Dose Conversion Factor Dose Isotope Type (mrem/pCi) (mrem/yr)

U-234 F 2.1 x 10 . 1A.5 x104 __ _ . ______ __~~~~~~.______._._-..s .-_-._._....- --~- -25F 1.9 x 10I9X

U-238 F 1.9x1 _ _.4.0xl0_ TC 9 ................... ` ............... . .... ! T - f... Tc-99 *. S .4.9x 10 . 2.6 x10~i _ ._ ___ ____ _ __ -. _.__..__._._._.._._._...._._._.__.__._.__._..

Total - -- 9.0x10

Notes:

mnrem = millirem; pCi = picocurie; yr = year.

C-3
-u

I

2

3

4

5

6

7

8

9

10

11

12

C.1.1.2 Construction Worker Exposure from Submersion

Dose to construction workers will occur from external exposure to radiation emitted by radionuclides that

are in soil where the construction activities are taking place. The dominant sub-pathways for exposure to

these radionuclides include air submersion and direct soil exposure. These exposures can be calculated

using a method similar to that used for inhalation:

DSR&I = Cd x DCFtbl (Eq. 4)

DCFSb i is in units of millirem per Ci-yr per meter cubed.

With the DSR known, the submersion dose can then be calculated from:

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

Total Dosefrom Submersion = EDE(DSRSbi xA,) (Eq. 5)

The dust concentrations and exposure times are the same as those used for inhalation. Table C-3

describes the dose to workers from submersion.

Table C-3 Worker Dose from Dust Submersion

Dose Conversion Factor Submersion Dose

(mrem-ml/Ci-yr) (mremlyr)

U-234 7.2x10+ . 4.1x 1049

U-235 7.6 x 10 .* _0"

U-238 *2.9 x 10" 1.7 x 10

Tc-99 : 3.4 x 10' 4.6 x. 10-

Total 2.5 x 100

Notes:

mrem-m3 = millirem-cubic meter, Ci-yr = curie-year, mremfyr = millirem per year.

C.1.1.3 Construction Worker External Dose from Radionuclides in Soil

Workers will also be subject to exposure from exposure to radionuclides in the soil. Dose from this

exposure is calculated using the equation:

DSR., I = Ct xDCF., (Eq. 6)

DCFC.,4;, is the Dose conversion factor for exposure to external radiation in soil, is in units of millirem per

- pCi-yr per gram.

The exposure time and soil concentrations used are identical to those used in the inhalation calculation.

Again, with the DSR known the total external dose from radionuclides in soil can be calculated from:

43

44

Total Dose from Radionuclides in Soil _ EDE(DSRS,,xA1)

i (Eq. 7)

C4
I Table C-4 describes the total external dose to workers from radionuclides in soil.

2

3 Table C-4 Total Worker External Dose from Soil

4

5

6

7

8

9

10

I1

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

I 46

47

48

Dose Conversion Factor External Dose Isotope (mrem-glpCi-yr) - (mrem/yr)

U-234 3.4x 1044 . 2.0x 14O

U-235 6.6 x 10 - 1.7 x IO"

U-238 *8.0 x 10' *4.5 x I

Tc-99 *11x 10- 1.5 x 10'

Total . 1.8 x 1042

Notes:

mrem-g = millirem per gram; pCi-yr = picocurie-year; mrcm/yr millirem per year.

C.1.l.4 Construction Worker External Dose from Existing Sources

DOE has maintained a set of thermoluminescent dosimeters both on and offsite to measure the direct

radiation exposure at various locations from the totality of on-site sources, including the cylinder storage

pads and other secondary sources. Thermoluminescent dosimeters provide the best estimate of the

external radiation exposure rates at various locations around the site. Work related to the proposed ACP

is expected to occur primarily at and around the existing X-3001 and X-3002 buildings, with some

additional work being done to build the new X-745H cylinder storage pad approximately 200 yards north

of the existing X-745G cylinder storage pad.

In 2003 the environmental exposure rate in the vicinity of the X-3001 and X-3002 buildings was

approximately 20 millirem per quarter based on the thermoluminescent dosimeter in that region, TLD

1404A (DOE, 2004). Environmental thermoluminescent dosimeters record information around the clock,

or about 2,190 hours per quarter. Assuming a 40 hour work week for a thirteen week quarter, a

construction worker in -the vicinity of the X-3001 or X-3002 buildings would receive a maximum external

radiation dose of 0.5 millisieverts (5 millirem) per quarter or 0.20 millisieverts (20 millirem) per year.

The ambient dose rate in the vicinity of the X-745H cylinder storage pad is expected to be greater than

that near the X-3001 and X-3002 buildings. Thermoluminescent dosimeters near the existing storage

yards show wide variance in their measured exposure rates; for example, the three thermoluminescent

dosimeters nearest the expected location of the X-745H pad record exposure rates at approximately 20

millirem per quarter, while others slightly farther away record higher values, with one thermoluminescent

dosimeter reading a value as high as 1.87 millisieverts (187 millirem) per quarter (DOE, 2004). The

variation is the result of a number of factors, including the distance and geometry of the

thermoluminescent dosimeter relative to the existing storage yards, and any work that may have

temporarily placed a source in the vicinity of the thermoluminescent dosimeter.. Using a very

conservative assumption that the exposure rate at the X-745H construction site is I millisievert (100

millirem) per quarter (4 millisieverts [400 millirem] per year),'a construction worker working 40 hours

per week for 48 weeks at that job site would receive a maximum external dose of approximately 88

millirem for the year, which is- below the public dosi 'limit of I millisievert (100 'iiillireii) per year

contained in 10 CFR 20.1301(a)(1). The most likely radiation dose to workers at the X-745H pad is

expected to be much less, on the order of 0.20 millisieverts (20 millirem) per year, based on the readings

from the nearby thermoluminescent dosimeters and the fact that the average annual dose for storage pad

workers was 0.29 millisieverts (29 millirem) in 2003. A dose of 0.20 millisieverts (20 millirem), is on the

same scale as the variations in individual dose caused by the fluctuation in natural background.

C-S
I Background radiation dose in the United States averages approximately 3.6 millisieverts (360 millirem)

2 per year (NRC, 2005).

3

4 The estimate for external dose from other sources is, for a number of reasons, likely to be significantly

5 exaggerated relative to any actual dose received by a construction worker. First, construction of the pad

6 is not expected to last a full calendar year even though the dose estimate assumes an annual exposure

7 period. Second, the analysis implicitly assumes the same personnel are used in the higher dose rate area

8 for the entire year regardless of the fact that the specific tasks may be changing (i.e. grading versus

9 pouring concrete). Third, the analysis assumes that these personnel spend 100 percent of their work time

10 in the higher dose rate region. The analysis is useful in demonstrating that even with these assumptions in

11 place the maximum dose would still be below the applicable NRC public dose limit.

12

13 C.1.1.5 Total Potential Dose to Construction Workers

14

15 Total occupational exposures from all four pathways are expected to be less than I millisievert (100

16 millirem) per year, even for estimates combining the most conservative analytical assumptions. This dose

17 presents a nearly negligible risk, representing a lifetime excess cancer risk of approximately 5 x 10"6

18 when using a risk coefficient of 5 x I0' risk per rem (EPA, 1994). Based on this assessment, the impact

19 to workers, from radiological exposure during site preparation and construction is SMALL.

20

21 C.1.2 Dose to Off-Site Public from Site Preparation and Construction

22

23 Exposures to off-site personnel will be significantly smaller than that for construction workers,

24 particularly since off-site personnel will not have any potential for measurable exposure from the depleted

25 uranium storage pads. The off-site public will also not be exposed to dose from on-site soil containing

26 concentrations of radionuclides above background concentrations.

27

28 Estimates of dose to the off-site public from site preparation and construction are limited to two of the

29 pathways used in the analysis of dose to construction workers, inhalation and air submersion. The

30 methodology used to calculate inhalation and submersion dose to the offsite public is the same as that

31 used to calculate the doses to construction workers; only the concentration of dust in air and the exposure

32 duration in hours per year are changed. The airborne dust concentration used in the off-site inhalation

33 exposure is 22.7 micrograms per cubic meter, which represents the maximum fenceline one hour

34 concentration. The exposure duration is considered to be 8,760 hours per year, or full time occupancy.

35 Using these values in the previous models results in the following inhalation dose values in millirem per

36 year of exposure (Table C-5):

37

38 Table C-5 Dose to the Off-Site Public

39

40

41

42

43

44

45

46

47

48

Inhalation Dose Submersion Dose Isotope (mSv/yr) (mSv/yr)

U-234 4.5 x 10-°5 0

... x i19 10 . 0

U-238 i40x1~

Total 8.9 x 1041 5 0 .

Notes:

mSv/yr = millisievert per year.

To convert millisievcrt to millirem multiply by 100.

C-6
1 The maximum exposure to off-site personnel is estimated to be much less than 0.01 millisieverts

2 (Imillirem) per year, so the impact to off-site personnel from site preparation and construction is

3 SMALL.

4

5 C.2 Estimation of Dose and Risk

6

7 The purpose of this section is to present the mathematical models and equations used in CAP88-PC for

8 environmental transport and estimation of dose and risk from air'transport of radioactive material.

9

10 C.2.1 Environmental Transport

11

12

13

14

15

16

17

* 18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

CAP88-PC incorporates a modified version of the AIRDOS-EPA (Moore, 1979) program to calculate

environmental transport. Relevant portions of this document are reproduced here, as referenced.

C.2.1.1 Plume Rise

CAP88-PC calculates plume rise in the subroutine CONCEN using either Rupp's equation (Ru48) for

momentum dominated plume rise, or Briggs' equations (Br69) for hot bu-oyant plumes (Mo79). CAP88-

PC also accepts user-supplied values for plume rise for each Pasquill stability class. The plume rise, Dh,

is added to the actual physical stack height, h, to determine the effective sfiack height, H. The plume

centerline is shifted from the physical height, h, to H as it moves downwind. The plume centerline

remains at H unless gravitational settling of particulates produces a downward tilt, or until meteorological

conditions change.

Rupp's equation for momentum dominated plumes is:

1.5vd Ah = (Eq. 1)

where:

Ah = plume rise

v = effluent stack gas velocity (mlsec)"

d = inside stack diameter (in)

I = wind velocity (in/sec)

CAP88-PC models Briggs' buoyant plume rise for stability categories A, B, C, and D with:

_h 1.6 FMxx". A I - (Eq. 2)

where:

Ah = plumr

F = 3.7x

QH = heat

x = dowi

t = wind

ke rise

IO-, QH

emission from stack gases (cal/sec)

awind distance (mn)

I speed (m/sec)

C-7
__jI

I This equation is valid until the downwind distance is approximately ten times the stack height, I Oh, where

2 the plume levels off. For downwind distances greater than 1 Oh, the equation used is:

3

4 A 1.6 F"3 x (lOh)2 3 (Eq. 3)

5

6 Equation (2) is also used to a distance of X = 2.4 [LS" for stable categories E, F, and G, beyond which the

7 plume is assumed to level off. For higher values of x, the stability parameter, S. is used in the equation:

8

9 Ah = 2.9 (FI/)" 3 (Eq. 4)

10

11 in which:

12 S = (g/T8)(dTj/dz+G) (Eq. 5)

13 g = gravitational acceleration (m/sec2 )

14 T. = air temperature (

0K)

15 dTj/dz = vertical temperature gradient (

0K/rn)

16 z = vertical distance above stack (in)

17 G = adiabatic lapse rate of atmosphere (0.0098° K/m)

18

19 The value of the vertical temperature gradient, dT/dz, is positive for stable categories. In CAP88-PC,

20 dT,/dz values are:

21

22 7.280E-02 °K/mr for Pasquill category E

23 1.090E-01 K/m for Pasquill category F

24 1.455E-0l IK/m for Pasquill category G

25

26 The true-average wind speed for each Pasquill stability category is used in CAP88-PC to estimate plume

27 rise, as it is greater than the reciprocal-averaged wind speed, and produces a smaller, more conservative

28 plume rise. This procedure does not risk underestimating the significant contribution of relatively calm

29 periods to downwind nuclide concentrations which could result from direct use of a plume rise calculated

30 for each separate wind-speed category. This procedure avoids calculating an infinite plume rise when

31 wind speed is zero (during calms), since both momentum and buoyancy plume rise equations contain

32 wind speed in the denominator (Moore, 1979).

33

34 CAP88-PC also accepts user-supplied plume rise values, for situations where actual measurements are

35 available or the supplied equations are not appropriate. For example, plume rises of zero may be used to

36 model local turbulence created by building wakes.

37

38 For this analysis, the plume rise was set to zero for each Pasquill category.

39

40 C.2.1.2 Plume Dispersion

41

42 Plume dispersion is modeled with the Gaussian plume equation of Pasquill (Pasquill, 1961, and Moore,

43 1979), as modified by Gifford:

44

45 X 2 .. exp[-'A(y/o) 2](e~xp[-Y2((z-H)/o,) 2]+exp[-'A((z+H)/0 )

2]) (Eq. 6) 2 4ror

46

C-8
I where:

2 X = concentration in air (chi) at x meters downwind, y meters crosswind, and z meters above

3 ground (Ci/m3)

4 Q = Release rate from stack (Ci/sec)

5 l.= wind speed (m/sec)

6

7 ay= horizontal dispersion coefficient (m)

8 az = vertical dispersion coefficient (m)

9 H = effective stack height (m)

10 y = crosswind distance (m)

11 z = vertical distance (m)

12

13 The downwind distance x comes into Equation (6) through a. and a., which are functions of x as well as

14 the Pasquill atmospheric stability category applicable during emission from the stack. CAP88-PC

15 converts X in Equation (6) and other plume dispersion equations from units of curies per cubic meter to

16 units of picocuries per cubic centimeter.

17

18 Annual-average meteorological data sets usually include frequencies for several wind-speed categories

19 for each wind direction and Pasquill atmospheric stability category. CAP88-PC uses reciprocal-averaged

20 wind speeds in the atmospheric dispersion equations, which permit a single calculation for each wind21 speed category. Equation (6) is applied to ground-level concentrations in air at the plume centerline by

22 setting y and z to zero, which results in:

23 0-

24 X 7raa exp[- V2l J2 (Eq. 7)

25

26 The average ground-level concentration in air over a sector of 22.50 can be approximated by the

27 expression:

28

29 X = fX (Eq. 8)

30

31 where f is the integral of the exponential expression:

32

33 exp,

34

35 in Equation (6) from a value of y equals zero to infinity divided by y, the value of y at the edge of the

36 22.50 sector, which is the value of the downwind distance, x, multiplied by the tangent of half the sector

37 angle. The expression is:

38

39 0 _2 (Eq. 9)

Ys

C-9
I The definite integral in the numerator of Equation (9) is evaluated as

2

3 cy (sT/2)

4

5 Since y, = x tan (11.25°),

6

6.300836o1

7 f =(Eq. x 1 0)

8

9 The equation for sector-averaged ground level concentration in air is therefore:

10

I1 I ' - exp[-'2(H)/o/]2 (Eq. 11) O. 15871lrxop

12

13 This method of sector-averaging compresses the plume within the bounds of each of the sixteen 22.50

14 sectors for unstable Pasquill atmospheric stability categories in which horizontal dispersion is great

15 enough to extend significantly beyond the sector edges. It is not a precise method, however, because the

16 integration over the y-axis, which is perpendicular to the downwind direction, x, involves increasing

17 values for x as y is increased from zero to infinity.

18

19 An average lid for the assessment area is provided as part of the input data. The lid is assumed not to

20 affect the plume until x becomes equal to 2 XL, where XL is the value of x for which ar = 0.47 times the

21 height of the lid (Turner, 1969). For values of x greater than 2 XL, vertical dispersion is restricted and

22 radionuclide concentration in air is assumed to be uniform from ground to lid.

23

24 The average concentration between ground and lid, which is the ground-level concentration in air for

25 values of x greater than 2 XL, may be expressed by:

26

27 x=. dz (Eq. 12)

28

29 where X is taken from Equation (6) and L is lid height. The value of H in Equation (6) may be set at zero

30 since X,.. is not a function of the effective stack height.

31

32 The resulting simplified expression may be evaluated for constant x and y values (sy and s. held constant)

33 by using a definite integral similar to that in Equation (10):

34

35 )xp ex)dz 2 (Eq. 13)

36

37 The result is:

38

39 X = Q exp[-v I (Eq. 14) 25066o0a

40

C-10
I One obtains the sector-averaged concentration at ground level by replacing the exponential expression

2 containing y by f in Equation (11):

3

4 Xr,. = Q/O.397825xLp (Eq. 15)

* 5

6 It should be noted at this point that for values of the downwind distance greater than 2 XL dispersion, as

7 expressed in Equation (16), no longer can be said to be represented by the Pasquill equation. The model

8 is simply a uniform distribution with a rectangle of dimensions LID and 2x tan (11.250).

9

10 Gravitational settling is handled by tilting the plume downward after it has leveled off at height H by

11 subtracting V. x/m from H in the plume dispersion equations. For CAP88-PC V. is set at the default

12 value of zero and cannot be changed by the user.

13

14 C.2.13 Dry Deposition

15

16 Dry deposition is modeled as being proportional to the ground-level concentration of the radionuclide

17 (Moore, 1979):

18

19 Rd =VdX (Eq. 16)

20

21 where:

22 Rd = surface deposition rate (pCi/cm2 -sec)

23 Vd = deposition velocity (cm/sec)

24 X = ground-level concentration (chi) in air (pCi/cm3 )

25

26 Although Vd has units of velocity, it is only a proportionality constant and is usually higher than the

27 actual, measured velocity of radionuclides falling to the ground. The proportionality constant must

28 include deposition from fallout interception by foliage, which subsequently falls to the ground and so

29 adds to ground deposition. Defaults for deposition velocity used by CAP88-PC are 3.5 x 1042 meters per

30 second for Iodine, 1.8 x 1 03 meters per second for particulates, and zero for gases.

31

32 C.2.1.4 Precipitation Scavenging

33

34 The deposition rate from precipitation scavenging (Moore, 1979), which occurs when rain or snow

35 removes particles from the plume, is modeled with:

36

37 R, = OX., L (Eq. 17)

38

39 where:

40 R. = surface deposition rate (pCi/cm2 -sec)

41 D = scavenging coefficient (sec),

42 X.¢ = average concentration in plume up to lid height (pCi/cm3 )

43 L = lid height (tropospheric mixing layer) (cm)

44

45 The scavenging coefficient, 4) (in secX), is calculated in CAP88-PC by multiplying the rainfall rate in

46 cm/yr, by 1.0 x 1047 yr/cm-sec.-

C-lI
I C.2.1.5 Plume Depletion

2

3 Radionuclides are depleted from the plume by precipitation scavenging, dry deposition, and radioactive

4 decay. Depletion is accounted for by substituting a reduced release rate, Q', for the original release rate

5 Q for each downwind distance x (Slade, 1968). The ratio of the reduced release rate to the original is the

6 depletion fraction. The overall depletion fraction used in CAP88-PC is the product of the depletion

7 fractions for precipitation scavenging, dry deposition and radioactive decay.

8

9 For precipitation scavenging the depletion fraction for each downwind distance (x) is:

10

12 Ie-Q (Eq. 18)

13

14 where:

15 D = scavenging coefficient (sec')

16 t = time (sec) required for the plume to reach the downwind distance x

17

18 The depletion fraction for dry deposition is derived by using Equation (6) with z set to zero for ground19 level concentrations, and subtracting the quantity (Vg x)/U from H for a tilted plume (Van, 1968, and

20 Moore, 1979):

21

22 - d( (Eq. 19)

Q |u.~ 0 a.

23

24 where:

25 Vd = deposition velocity (m/sec)

26 [i= wind speed (m/sec)

27 a.= vertical dispersion coefficient (m)

28 Vg= gravitational velocity (m/sec)

29 H = effective stack height (m)

30 x = downwind distance (m)

31

32 The integral expression must be evaluated numerically. Values for the vertical dispersion coefficient s.

33 are expressed as functions of x in the form xD/F where D and F are constants with different values for

34 each Pasquill atmospheric stability category, to facilitate integrations over x.

35

36 Values for the depletion fraction for cases where V. is zero are obtained from the subroutine QY in CAP37 88. Subroutine QY obtains depletion fractions for the conditions Vd = 0.01 rm/sec and p = I m/sec for

38 each Pasquill stability category from the data file REFA.DAT. This file contains values for release

39 heights (meters) of:

40

41 1, 1.5, 2, 3,4, 5, 6, 7, 8, 9, 10, 12.5, 15, 17.5, 20, 25, 30, 35, 40, 50, 60, 70, 80, 90, 100, 120, 140, 160,

42 180, 200, 240, 260, 300 and 400;

C-12
I and for downwind distances (meters) of:

2

3 35, 65, 100, 150, 200, 300, 400, 500, 650, 800, 1,000, 1,500, 2,000, 4,000, 7,000, 10,000, 25,000, 60,000,

4 90,000, and 200,000.

5

* 6 The stored depletion fractions were calculated numerically with a Simpson's rule routine. CAP88-PC

7 uses a linear interpolation to produce a fraction for the required downwind value, release height and

8 Pasquill category for Vd = 0.01 m/sec and [L = I rn/sec. The value is then converted to the appropriate

9 value for the actual deposition velocity and wind speed by use of the equation:

10

11 (Q'/Q)2 = (QI/Q)IIoovd& (Eq 20)'

12

13 in which subscript 2 refers to the desired value and subscript 1 refers to the value for Vd = 0.01 1/sec and

14 m=lm/sec.

15

16 For downwind distances greater than 2 XL where Equation 15 applies to the ground-level concentrations in

17 air, the depletion is modeled with (Moore, 1979):

18

19 Q., = exp[ Vd 2x (X (Eq. 21)

20

21 Which shows the reduced release rates at distances x and 2 XL, respectively.

22

23 The depletion fraction for radioactive decay is:

24

QI 25 = exp(-At) (Eq. 22)

26

27 where:

28 A, = effective decay constant in plume

29 t = time required for plume travel

30

31 The decay constant used is referred to as the "effective decay constant" since it is not the true radiological,

32 decay constant in all cases. For example, if a radionuclide is a short-lived decay product in equilibrium

33 with a longer-lived parent, the effective decay constant would be equal to the true radiological decay

34 constant of the parent.

35

36 The atmospheric dispersion equations use the reciprocal-averaged wind speed, but neither this value nor

37 the true average wind speed can adequately be used to calculate reduced release rates to account for

38 radiological decay and scavenging losses because averaging of exponential terms is required. CAP88-PC

39 uses an approximate method of calculation for this purpose, which establishes three wind speeds (I m/sec,

40 the average wind speed, and 6 m/sec) to simulate the actual wind-speed spectrum for each specific wind

41 direction and Pasquill category. The wind speeds 1 and 6 m/sec were chosen because they approximate

42 the upper and lower bounds in most meteorological data sets.

C-13
I If fl, f2 and f3 are designated as the time fractions for the three wind speeds, then:

2

3 f, + (g. f2) + 6f 3 =

4

5 f, + (f2 /p4 + f3

1/6 = I/l,

6

7 and

8

9 f, +f2 +f 3=l

10

1 1 where:

12 Pa = Arithmetic-average wind speed

13 Pr = Reciprocal-average wind speed

14

15 Solving the three simultaneous equations yields:

16

17 f, = 1 - f2 - f3

18

19 f2 = (7/6) - (uJ/6) -(1Iu.

20 (7/6) - (p1 /6) - (1/tij

21

22 f3 = _l_- E___ 

23 5

24

25 The depletion fraction to account for radioactive decay is then approximated by:

26

27 f, exp(-A~x) + f

2 exp[-X,(x/pj] + f3 exp[-X,(x/6)]

28

29 where:

30 A, = effective decay constant in plume (sec')

31 Pa = Arithmetic-average wind speed

32 x = downwind distance (m)

33

34 For precipitation scavenging losses, the depletion fraction is:

35

36 f2 exp(-,tx) + f2 exp[-,D(x/tlp)] + f3 exp[-cD(x/6)]

37

38 where CD is the scavenging coefficient (sec-').

39

40 The overall depletion fraction is calculated by multiplying the depletion fraction for dry deposition by the

41 fraction for radioactive decay and precipitation scavenging.

42

43 C.2.1.6 Dispersion Coefficients

44

45 Horizontal and vertical dispersion coefficients (sy and sj) used for dispersion calculation in CONCEN and

46 for depletion fraction determination in QY are taken from recomrnendations by G.A. Briggs of the

47 Atmospheric Turbulence and Diffusion Laboratory at Oak Ridge, Tennessee (Moore, 1979, and Gifford,

48 1976). The coefficients are different functions of the downwind distance x for each Pasquill stability

49 category for open-country conditions, as shown in Table C-6:

C-14
I

1

2

3

4

5

6

7

8

9

10

Table C-6 Coefficients for Open-Country Conditions -

iPasquill Cy

category (m) | (m)

A 0.22 x (1+0.0001x)-'* 0.20 x ... _._._._._ ._;._........_._......._..... . .. . ..... _....._ . . ......__...__...

'B 0. 16 x (I1+0.0001x) 0.12 x

-C *. II x(I+O.OO Ix)s -(1+O.0002xYv

D 0.08 x (1+0.0001x) % 0.06 x (I1+0.001I5x)-l/

E . 0.06 x (1+0.0001 x)- . 0.03 x (1+0.0003x)-'

F. . 0.04 x (1+0.0001x)- . 0.016 x (1+0.0003x)' ~~~~~~~--------------t....._...__ .. .A_ . _

11 G calculated by subtracting half the difference between values for categories E and F

from the value for category F.

12

13 where:

14 x = downwind distance

15

16 CAP88-PC uses the functions in the form of

17

18 aY = XA/C

19 a: = xD /F

20

21 to facilitate integrations over x. Values for A, C, D, and F for each stability category and downwind

22 distance are stored in a data statement.

23

24 C.2.1.7 Ground Surface Concentrations

25

26 Ground surface and soil concentrations are calculated for those nuclides subject to deposition due to dry

27 deposition and precipitation scavenging. The deposition accumulation time is defined by the user. This

28 value corresponds to establishing a cutoff for the time following a release when any significant intake or

29 external exposure associated with deposition on soil might take place.

30

31 Ingrowth from a parent radionuclide is calculated using the Bateman decay equations for all chains

32 contained in the isotope database from Federal Guidance Report 13. Ingrowth is calculated for the entire

33 chain based on the decay time input by the user. The default decay time is 100 years.

34

35 Radionuclide concentrations in meat, milk, and vegetables are calculated using elemental transfer factors

36 from Report 123 of the National Council on Radiation Protection (NCRP, 1996). The concentration in

37 soil for each isotope is multiplied by the appropriate elemental transfer factor to generate a concentration

38 in each of the ingestion pathways media for that isotope in that sector. This information is then supplied

39 to the dose and risk calculation models via an intermediate output file.

40

41 C.2.2 Dose and Risk Estimates

42

43 CAP88-PC uses a modified version of DARTAB (ORNL, 1981) and a database of dose and risk factors

44 from Federal Guidance Report 13 (EPA, 1999) for estimating dose and risk. Relevant portions of these

45 documents are reproduced here, as referenced.

46

47 Dose and risk conversion factors include the effective dose equivalent calculated with the weighting

48 factors in International Commission on Radiation Protection Publication Number 72 (ICRP, 1996). Dose

C-15
I and risk factors are provided for the pathways of ingestion and inhalation intake, ground level air

2 immersion, and ground surface irradiation. Factors are further broken down by particle size, clearance

3 category chemical form, and gut-to-blood transfer factors. These factors are stored in a database for use

4 by the program. At this time CAP88-PC only uses dose and risk factors for adult populations, for particle

5 sizes of 1 micron, and for cancer mortality.

6

7 For assessments where radon-222 decay products are not considered, estimates of dose and risk are made

8 by combining the inhalation and ingestion intake rates, air and ground surface concentrations with the

9 appropriate dose and risk conversion factors. CAP88-PC lists the dose and risk to the maximum

10 individual and the collective population. CAP88-PC calculates dose to the 23 internal organs in

11 International Commission on Radiation Protection Publication 72 (ICRP, 1996) in addition to the 50 year

12 effective dose equivalent. Risks are estimated for 15 cancer sites, including leukemia, bone, thyroid,

13 breast, lung, stomach, colon, liver, pancreas, ovaries, skin, kidneys, esophagus, and bladder. Doses and

14 risks can be further tabulated as a function of radionuclide, pathway, location, and organ.

15

16 For each assessment, CAP88-PC tabulates the frequency distribution of risk, that is, the number of people

17 at various levels of risk (lifetime risk). The risk categories are divided into powers of ten, from one in ten

18 to one in one million. The number of health effects is also tabulated for each risk category.

19

20 C.2.2.1 Air Immersion

21

22 Individual dose is calculated for air immersion with the general equation:

23

24 E-(k DFj 1 K1

25 P(k)

i

I

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

where:

Ejj(k)

DFjP

P(k)

* YN

= exposure rate, person-pCi/cm3

= Dose rate factor, mrem/nCi-yr/m 3

= number of exposed people

= 0.001 nCi/pCi x 1,000,000 cm3/m3 (proportionality factor)

Risk is calculated similarly, by substituting the risk conversion factor, for the dose conversion factor. The

risk conversion factor is in units of risk/nCi-yr/m3 .

C.2.2.2 Surface Exposure

Individual dose is calculated for ground surface exposure with the general equation:

,

1(k) DF- 1 K1

P(k)

where:

Ej(k)

DFijj

P(k)

KJ

= exposure rate, person-pCi/cm2

= Dose rate factor, mrem/nCi-yr/m2

= number of exposed people

= 0.001 nCi/pCi x 10,000 cm2/m2 (proportionality factor)

50 Risk is calculated by substituting the risk conversion factor for the dose conversion factor. The risk

51 conversion factor is in units of risk/nCi-yr/m2.

C-16
I C.2.2.3 Ingestion and Inhalation

2

3 Individual dose is calculated for the ingestion and inhalation exposure pathway with the general equation:

4

5 -(k) DFI K1

6 P(k)

7

8 where:

9 Ej,(k) = exposure rate, person-pCi/cm3

10 DFjj, = Dose rate factor, mrem/nCi-yr/m3

11 P(k) = number of exposed people

12 Kj = 0.001 nCi/pCi x -1,000,000 cm3/m3 (proportionality factor)

13

14 Risk is calculated by substituting the risk conversion factor or the dose conversion factor.

16 C.2.2.4 Maximally-Exposed Individual '

17

18 Doses for the maximally-exposed individual in population runs are estimated by CAP88-PC for the

19 location, or sector-segment in the radial assessment grid, of highest risk where at least one individual

20 actually, resides. The effective dose equivalent for' the maximally-exposed individual is tabulated in

21 mrem/yr for a 50 year exposure. The reported risk associated with the 50 year Total Effective Dose -

22 Equivalent based on the risk coefficients contained in Federal Guidance Report 13.

23

24 When performing assessments of individual dose in CAP88-PC, the code will calculate the maximum

25 individual dose based on the result from the highest grid point input by the user for that individual case.

26 Alternatively, the user may specify the grid location where CAP88-PC is to generate the maximum

27 exposed individual. This is done using the ILOC and JLOC parameters on the individual assessment grid

28 input screen.

29

30 C.2.2.5 Collective Population

31

32 Collective population dose and risk are found by summing, for all sector segments, the intake and

33 exposure rates multiplied by the appropriate dose or risk'conversicn factors from Federal Guidance

34 Report 13. Collective population dose is reported by person-Rem per year (not millirem), and collective

35 risk is reported in deaths per year.

36

37 C.3 References

38

39 (Briggs, 1969) Briggs, G.A., "Plume Rise, AEC Critical Review Series." TID-25075. 1969.

40

41 (DOE, 2003) Portsmouth Site Annual Environmental Report for 2002, DOE/OR/i 1-3132 & Dl, U.S.

42 Department of Energy, Washington, DC. October' 2003.

43

44 (DOE, 2004) Portsmouth Site Annual Environmental Report for 2002, DOE/OR/I 1-3153 & DI, U.S.

45 Department of Energy, Washington, DC. November 2004.

46

47 (EPA, 1994) Estimating Radiogenic Cancer Risks, EPA 402-R-93-076, United States Environmental

48 Protection Agency, Office of Radiation and Indoor Air, Washington, DC. June 1994.

C-17
- - l

I (EPA, 1997) Exposure Factors Handbook Update to EPA/600/8-89/043, EPA/600/P-95/002Fa, United

2 States Enviromnental Protection Agency, Office of Research and Development, National Center for

3 Environmental Assessment, Washington, DC. 1997.

4

5 (EPA, 1999) EPA 402-R-99-001 Federal Guidance Report 13, "Cancer Risk Coefficients for

6 Environmental Exposure to Radionuclides", USEPA Office of Radiation and Indoor Air, Washington,

7 DC. 1999.

8

9 (Gifford, 1976) Gifford, F.A., Jr., "Turbulent diffusion-typing schemes: A review," Nuclear Safety

10 17(1):68-86, 1976.

11

12 (ICRP, 1994) Human Respiratory Tract Model for Radiological Protection, International Commission on

13 Radiological Protection, ICRP Publication 66, Pergamon Press, Oxford, UK. 1994.

14

15 (ICRP, 1996) International Commission on Radiological Protection, "Age Dependent Doses to Members

16 of the Public from Intake of Radionuclides, Part 5. Compilation of Ingestion and Inhalation Dose

17 Coefficients," ICRP Publication 72, Pergamo n Press, Oxford, UK. 1996.

18

19 (Moore, 1979) Moore, RE., Baes, C.F.1II, McDowell-Boyer, L.M., Watson, A.P., Hoffman, F.O.,

20 Pleasant, J.C., Miller, C.W., "AIRDOS-EPA: A Computerized Methodology for Estimating

21 Environmental Concentrations and Dose to Man from Airborne Releases of Radionuclides," (Reprint of

22 ORNL- 5532), EPA 520/1-79-009, U.S. EPA Office of Radiation Programs, Washington, DC 20460.

23 1979.

24

25 (NRC, 2005) U.S. Nuclear Regulatory Commission. "What Are Sources Of Radiation." Fact sheet on

26 radiation published at <http://www.nrc.gov/what-we-do/radiation/sources.html>. 2005.

27

28 (NCRP, 1996) National Council on Radiation Protection and Measurements, "Screening Models for

29 Releases of Radionuclides to Atmosphere, Surface Water, and Ground," NCRP Report 123 Volume 1,

30 National Council on Radiation Protection and Measurements, Bethesda, MD. 1996.

31

32 (ORNL, 1981) ORNL-5692/DE81030434 DARTAB: A Program to Combine Airborne Radionuclide

33 Environmental Exposure Data With Dosimetric Health Effect Data to Generate Tabulations of Predicted

34 Health Impact, Oak Ridge National Laboratory, Oak Ridge, Tennessee. November 1981.

35

36 (Pasquill, 1961) Pasquill, F., "The Estimation of the Dispersion of Windborne Material,"Meteorology

37 Magazine, 90:33. 1961.

38

39 (Rupp, 1948) Rupp, E.M., Beall, S.E., Bornwasser, L.P., Johnson, D.H., "Dilution of Stack Gases in

40 Cross Winds," USAEC Report AECD-1811 (CE-1620), Clinton Laboratories. 1948.

41

42 (Slade, 1968) Slade, D.H. (ed.), "Meteorology and Atomic Energy - 1968," U.S. Atomic Energy

43 Commission/Division of Technical Information, USAED TID-24190. 1968.

44

45 (Turner, 1969) Turner, D.B. "Workbook of Atmospheric Dispersion Estimates," Air Pollution Control

46 Administration, Cincinnati, Ohio. 1969.

47

48 (USEC, 2005) United States Enrichment Corporation. "Environmental Report for the American

49 Centrifuge Plan in Piketon, Ohio." Revision 3. Docket No. 70-7004. July 2005.

C-18
I (Van, 1968) Van der Hoven, I., "Deposition of particles and gasses," pp. 202-208, In Slade, D. (ed.),

2 Meteorology and Atomic Energy - 1968, U.S. Atomic Energy Commission, USAED TID-24190. 1968.

C-i9
I APPENDIX D

2 TRANSPORTATION ANALYSIS METHODOLOGY, ASSUMPTIONS, AND IMPACTS
1 -APPENDIX D

2 TRANSPORTATION ANALYSIS METHODOLOGY, ASSUMPTIONS, AND IMPACTS

3

* 4 D.1 Introduction

5

6 This appendix presents the methodology and assumptions used to evaluate the potential impacts from the

7 transportation of radiological materials to and from the proposed American Centrifuge Plant (ACP) near

* 8 Piketon, Ohio. Transportation of radiological materials would include shipments of feed materials to the

9 ACP, shipments of product materials from the proposed ACP, shipments of radioactive waste from the

10 proposed ACP during the operation of the facility, and the eventual shipment of depleted uranium to a

11 disposal site after its conversion from uranium hexafluoride (UF6) to triuranium octaoxide (U 3 08), a

12 chemical form more suitable for disposal.

13

14 D.2 Radioactive Materials Description

1 5

16 The feed material consists of natural UF6 and is transported in Type 48Y or Type 48X cylinders. The

17 product consists of enriched UF6 and is transported in Type 30B cylinders. Specifications for these

18 cylinders are given in Table D-1. Two other radioactive materials requiring transportation that result

19 from the conversion of UF6 are depleted U30, and calcium fluoride (CaP2), contaminated with uranium.

20 Assuming no change in isotopic concentration of the uranium isotopes, the U30, material would have the

21 same isotopic ratios as the depleted UF6 tails. The CaF2 could have about 55 becquerels (1.5 picocuries)

22 per gram of depleted uranium as a radioactive contaminate (DOE, 2004). Finally radioactive waste

23 resulting from routine operations and the eventual decontamination and decommissioning (D&D) of the

24 plant would be transported to a waste disposal site. Specifications for 55-gallon drums and B-25 boxes,

25 used to transport radioactive waste are give in Table D-2.

D-1
1

2

3

4

5

16

17

8

10

12

13

14

15

i 16

17

18

19

20

21

22

23

24

i 25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

Table D-1 Specifications for Type 30B, 48X, and 48Y Cylinders

Cylinder Specification 30B | 48X | 48Y

Nominal Diameter 76 cm 122 cm 122 cm

Nominal Length *. 206 cm . 302 cm. 380 cm

Wall Thickness 1.3 cm 1.6 cm 1.6 cm .------.----....... _-.......--.

Nominal Tare Weight 635 kg 2,000 kg . 2,359 kg .. . . . . .. 4 . . . . . . .... _ __......._. i

Maximum Net Weight 2,300 kg 9,540 kg 12,500 kg

Nominal Gross Weight 2,900 kg 11,600 kg 14,800 kg . ....- . .-..-......-.--.-.- 4---- . .. i....... .... ... ..... . .....

Minimum Volume 0.74 m* 3.05 m3 4.04 m3

. . ................. ...... * . .. .. ..... ........ .. ..

Basic Construction Material . Steel: ASTM-516 Steel: ASTM-516 Steel: ASTM-516 . ...... . ..... - --- .-... .... . . . . ... ...... ... -....-.- ..... 

Service Pressure * 1,380 kPa gage 1,380 kPa gage 1,380 kPa gage ............ .... ......... . -.-- *--t----.. -- - ----...... .------

Hydrostatic Test Pressure 2,760 kPa gage 2,760 kPa gage 2,760 kPa gage . .-..-. - _ ..-.... _..... _._..._....-.._.- 

Isotopic Content Limit (Max. i 5.0 % U-235 4.5 % U-235 (5.0% i 4.5 % U-235

with Moderation Control) i in-plant use) . . . .... . . .. .. .- - - - -- ---- - .-- -. ........ .. t .-.. 

Valve Used . 2.54 cm valve 1 2.54 cm valve 2.54 cm valve

Notes:

cm = centimetersm3 = cubic meter; kg = kilogram; kPa = kilopascal; psi = pounds per square inch; ASTM =

American Society for Testing and Materials.

To convert cm to inches multiply by 0.394.

To convert m3 to ft3 multiply by 35.3.

To convert kg to lb multiply by 2.2.

To convert kPa to psi multiply by 0.144.

Source: USEC, 1995.

Table D-2 Specifications for 55-Gallon Drums and B-25 Boxes

Cylinder Specification 55-Gallon Drum B-25 Box

Nominal Diameter 61 cm 122 cm x 183 cm ..........-......- ..~ ..... . ... ___....--- .- . .... t.........

Nominal Length i.89 cm . 122 cm . -.-..- - - -.- -. -... . ...... ... . . . . .. . ...

Minimum Volume 259 L . 2,720 L .*---- - .- .-- _ - .- _ *- - .- . . -t-. . . . ..- . - _ _ - t ... _ __ .- ..

Material of Construction Steel Steel

Notes:

cm = centimeter, L = liter

To convert cm to inches multiply by 0.394.

To convert L to ft} multiply by 0.35.

Source: USEC, 2005.

Table D-3 provides the isotopic mass fractions used to calculate the activities of the individual

radionuclides in the various shipping containers. The calculated activity of the uranium isotopes and their

D-2
I

2

3

4

5

6

7

8

9

10

most prevalent progeny are given in Table D-4. The activities of the various isotopes of protactinium

and thorium are calculated assuming one year of decay. These progeny along with the uranium isotopes

account for more than 99 percent of the total activity of the radioactive materials described in Section

D. 1. While other progeny are present in very small quantities, their contribution to the total risk is

negligible.

Table D-3 Uranium Isotopic Mass Fractions

Radionuclide Mass Fraction

Feed Material Product Materials I Depleted Tails

|________ (%) |(%) | (%)!

U-234 0.0054 0.047 0.00052

U-235 0.7 4.7 0.3 ........ .3 ....- .. 2*99.7

U-238 99.3 - 95.2 99.7

11

12

13

14

D-3
2

3

4

5

6

7

8

9

10

I 1

12

13

14

15

16

17

18

19

20

Table D-4 Activities of Uranium, Protactinium, and Thorium Radlonuclides in Various Shipping Containers (becquerels)

Radionuclide Feed Material Product Heels Radioactive Waste' Depleted Calcium

48X C 30B 30B Uranium Fluoride 48Y 30B Cyllnder Cylinder 55-Gallon B-25 Bulk Bag Bulk Bag Cylinder Cylinder Cylinder Drum

Th-230 7.4 x I96 0 .x106 I .x106

Th-23 3. x 1

o 0 5 T T 9.6 4 810 x 10si 1.6 x 1.6 x 5.2 x 10-' . x0 59 1 9 i 29 ' 7 x0 6 T 7.4lo i - l o$9 T o l ....- ..................

96!.01 Th-231 3.7 x109 4.8 x109 5.9 x109 5.9x 10 109 2.9 x107 .4 7.47.4xI0 7 2.1 xlog .x0

Th-234 i 8.1 x 10'° i 1.0 x 10" 1 1.9 x I I ...... I 10'° T 1.9 x 10'0 1 9.3 x 10' 1.2 x 10' 1.6 x 109 T 1.2 x 10" . 5.6 x I0 . ........ .. ........... .......... . .......................................................... .. ..........- i.

Pa-231 ' 7.8 x IO 1. X0 x 10' 1.2 x 10' T 1.2 x 10' 1 5.9x102 O 0 1 0 i 4.4 x 104 T 2.1 x 10 .......... ..... ............. . ........... .................. 4....1......... . ..................

Pa-234 1. Ox lo 1.4x 10' 2.4X 107 2.4x107 i l.2x 1 I0 0' ° 1.6 x 10'2 ............ 4.. . ..... I........................ . ... . .......... . ..........- ..

Pa-234m i 8 x lo 1.0 x lO, 1.9 x lo i 1.9 x 101. i 9.3 x 107 j1.2 x 10' 16 x 109 1.2 x 10 T 56 x0 .............................. ......... ,,,t........................ ................. .. ... U-234 8.1 x 10' 0 1.0 x 10"1 1.7 x 1011 I 1.7 x 10^ I 8.1 x lo,.. U -2 3 5 i 8. 7x l 1 1 0 9 . T . 8x l 1 1 . 6x 1 0 9 T . 6x 1 0 .2x 1 0 'x i .6 x 1 0 9 1 .1 x 1 0 10 5 .6 x 1 0 4

.............................. .I.. - -.-

U-3 .x0 14BI' 1.x0 .x0 .x0 7.4 x106 7.4 1 7 I2.1xO - 0 I 1.0X 104

U-238 i 8.1 x 101'0 1.0 x 10 1 1.9 x 1010 I 1.9 x 10'° i 9.3 x 10 10 1.6 x 109 1.2 x 10" 5.6 x 10' t 1.2........ x.............J

Total Curies T 3.3 x 10" 4.1 x 1011 i 2.4 x 101 i 2.4 x 10" 1.x 10' 5.2 x 10' 6.7 x 10' 3.7 x 10" 1.7 x 106

Notes:

I curie (Ci) = 3.7 x 10'0 becquerels

'Source: USEC, 2005.

D4

ii
I D3 Transportation Routes

2

3 Transportation of radiological materials would include shipments of feed material (natural UF6) to the

4 proposed ACP, shipments of product materials (enriched UF6) from the proposed ACP, and shipments of

5 radioactive waste from the proposed ACP (USEC, 2005). Depleted UF6 is assumed to be stored onsite

6 until it is converted from UF6 to U308, a more stable chemical form, and then transported by railcar to a

7 low-level radioactive waste disposal site. According to the ACP Environmental Report, feed materials

8 will be transported from Metropolis, Illinois; Port Hope, Ontario, Canada; and Wilmington, Delaware in

9 Type 48Y, Type 48X , and Type 30B cylinders, respectively. Product materials will be shipped to

10 Richland, Washington; Columbia, South Carolina; Wilmington, North Carolina; and Seattle, Washington

11 in Type 30B cylinders. Wilmington, Delaware is the shipping port for feed materials from Russia, while

12 Seattle is the port for product shipments to Korea, and Japan. Low-level radioactive waste (LLRW) will

13 be shipped to Gainsville, Florida; Clive, Utah; and the Nevada Test Site. The transportation of

14 radiological materials is subject to NRC and DOT regulations. Table D-5 presents a matrix of the

15 shipping origins and destinations for the various radioactive materials.

16

17 In addition to the transport of radioactive materials during the operation of the proposed ACP, low-level

18 radioactive waste will be shipped to disposal sites during decontamination and decommissioning (D&D)

19 waste are expected to include of the proposed ACP. Shipments of decontamination and decommissioning

20 waste are expected to be 5,100 shipments to the Nevada Test Site; 105 shipments to Clive, Utah; and 60

21 shipments to Kingston, Ohio.

22

23 WebTragis (ORNL, 2003) was used to generate the routing information. WebTragis is a web-based

24 version of Tragis (Transport Routing Analysis Geographic Information System) and is used to calculate

25 highway, rail, or waterway routes within the United States. WebTragis generates routing distance,

26 population density within 800 meters (0.5 mile), and for the truck routes, the number of rest stops and

27 stops for State inspections. Table D-6 presents the output from WebTragis to be used in this risk

28 assessment. For Port Hope, Ontario, an additional 241 kilometers (150 miles) of route distance was

29 added to the TRAGIS output to account for that portion of the route located in Canada. Even though

30 transportation regulations by truck do not require restricted routing for the shipment of natural uranium,

31 low-enriched uranium, or depleted uranium, routing restrictions were applied as follows (USEC, 2005):

32

33 * Highway Route Controlled Quantity preferred route with two drivers;

34 * Prohibit use of links prohibiting truck use; and

35 * Prohibit use of ferry crossing; prohibit use of roads with hazardous materials prohibition.

D-5
1

2

.3

4

5

6

7

8

9

10

I11

12

13

14

15

16

17

18

Table D-5 Radioactive Waste Shipment Routes

Route Radioactive Shipments

Feed Product Heeled LowLevel Mixed Low-Level Depleted Calcium

Material (Enriched Containers Radioactive Low- Level Liquid Uranium Fluoride

(Natural UF,) Waste Radioactive Radioactive (U30,) (CaF2)

UFJ Waste Waste

Metropolis, IL to ACP i / . |.Iii. *-------- .......----................ ......... .. . ......... ..

Port Huron, ON to ACP ' / . i i ...............

Wilmington, DE to ACP / i I i

ACPtoRichland, WA . / j...i / .......... .. ...... A - -------------I..........

ACP to Columbia, SC I , / / i... .

............................................................. .......................... ........... ............... ........ . ...... . .. ............................... ................ ....... ................

ACP to Wilmington, NC i / * i i

ACP to Seattle, WA / t

ACP to Clive, UT , . / i I / I / ..................... ............... .. . .. .. .. .............. ;..... .............. .................. .............

ACP to Ncvada Test Sitc, NV. / . .. .... .. i ................. ........................... ... ........................... ........... . ... . ..................... ........................... t.. .- ...--..----.-.-------------.-----.------.---.--

ACP to Gainsville, FL 

------------- --- ----------------------.....----.......................... i i 

.................... i / * i

------------....................---------------....... ........ .......................... I . - .. - t ... .. -... 1. .........

ACP to Oak Ridge, TN * i. i . i ti ___ i__

Source: USEC, 2005.

D-6
I Table D-6 Route Information as Generated by TRAGIS

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

Destination/ Distance (km) Elapsed Weighted Population (people/km2) Population

Origin Time within 800 m

O Rural Suburban Urban Total (hh:mm) Rural Suburban Urban Buiffer Zone

Metropolis, IL . 554.1 307.3 I 17.7 879.1 9:31 20.6 282 2,193 | 174,192

(63.0%) (35,0%) (2.0%) ( 00%) i..1* 3i. ................. ........- ------------- --- ................. ......... ............ . .... .............. ........... ............. ........................ .......... L"..............j.......... .......... J.... ......... .5.8 327 (82. 898.7 10.2

Port Hope, ON 457.8 392.7 48.2 i 898.7 i 10:26 j 21 i 305.2 j 2,444 i 316,151

50.9%) 43.7%/°) (5.4%) (100%) i 1 i . .......................... -,.----. ...... . ..................... - -......- -..

Wilmington, DE 474.4 355.3 44.3 j 873.9 , 10:06 j 19 t 330.6 j 2,316 . 308,509

(54.3%) . (40.7%) (5.1%) (100%) j ................................................................. ... ....... ........................... ......................... . .......

Richland, WA | 3,130.9 *t 653.4 60.8 3,844.8 1 41:27 1 10.9 j 298.3 ! 2,235 1 494,741

- (81.4%) 5 (17.0%) t (1.6%) (100%) t . . .4.

............................................. .... .,.,.

Columbia, SC 422.2 331.8 30.4 784.3 8:02 17.6 367 2,278 256,008

i (53.8%) * (42.3%) (3.9%) (100%) t i.... . ------------------------- - _ .-... .. t. ............... . .

Wilmington, NC . 549.2 i 409.7 i 33.8 992.6 i 10:26 18.3 359.1 2,150 * 305,803

*(413%)| (3.4) 100%/) *. I . . ~ (55.3%) .J...................... ........................

Seattle, WA 3,229.9 j 743.8 ! 103.6 4,077.2 . 44:09 II 1. 320.7 2,319 j 695,631

(79.2%) (18.2%) j (2.5%) j (100%) * i I * ........................ -; . ... _; .

Clive, UT i 2,430.1 j 520.8 60.1 3,010.9 t 31:46 j 11.1 310.4 . 2,292 448,863

1 (80.7%) (17.3%) 1 (2.0%) (1 00%) ° 1 1 ................................. .3..

Nevada Test Site, .2,935.2 617.7 905 3,6431 38:15 10.7 316.2 2,405 i 614,875

NV t .(80.6%) 1 (17.0%) (2.5%) t (100%) * 1 .| * i

Gainsville, FL j 875.3 519.4 1 36.3 1,430.8 t 14:52 15.1 ; 334.6 2,306 343,734

I (61.2%) 1 (36.3%) I (2.5%) (100%) ................... a................................. ............................. ......... .. ....................... ............ .....

OakRidge,TN ! 350.9 ! 226.6 16.3 j 593.3 ! 6:20 i 21 ! 293.8 ! 2,065 ! 131,400

i (59.1%) 1 (38.2%) 1 (2.8%) § (100%) _ 1 ii i i

Notes:

km = kilometer, km2 ' square kilometer -

To convert km to mi multiply by 0.62.

To convert from km2to mi2 multiply by 0.386.

I D-7
, ! I-11

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

D.4 RADTRAN Modeling Inputs and Results

The radiological impacts to occupational workers and the general public from the transport of the

radioactive materials were estimated using RADTRAN 5 (Osborn, 2005), a computer code that calculates

the risks for both the incident-free transport of radioactive-material and for accidents. The term "incident

free" means that no traffic accident or other incident resulted in the release of radioactive material to the

surrounding environment. In this context, accidents refer only to incidents that result in the release of

radioactive material. The risks associated with the transport of radioactive materials include injuries and

fatalities from traffic accidents and an increased risk of cancer fatalities from exposure of persons near the

vehicle to direct radiation.

Exposure to radiation from radioactive shipments is assumed to result in an increased risk of latent cancer

to crews operating the truck or train, persons sharing the route with the shipment (on-link public), persons

living alongside the route (off-link public), and persons at rest stops and inspection stops. These latent

cancers do not occur immediately after exposure, but instead occur a number of years after the exposure.

RADTRAN 5 estimates the number of latent cancer fatalities from the incident free transport of the

materials and accidents.

D.4.1 Incident-Free Parameters

The risks from incident-free transport depend on the external radiation levels of the package being

transported; the length and time duration of the route; and the number of persons sharing the route.

Tables D-7 and D-8 provide a listing of the input parameters to RADTRAN that were used in this risk

assessment.

Table D-7 RADTRAN 'Package" Parameters

Package RADTRAN Parameter

Long | Dose Rate | Gamma Neutron

Dimension (m) (mremlhr)' Fraction Fraction

Feed Material (48X cylinder) 3.0 0.7 1 0 -----------------------.. . .. . .-.... ......

Feed Material (48Y cylinder) 3.8 0.7 * 0 ;. -i--------- - ------ - - a_- - ..... .......... _.. - 4..... .. . ....._

Feed Material (30B cylinder) 2.1 0.7 . 0 _.___.__...____._. .............................. _._ .......... _ ....._........__........_.............. ....._............

Product Material (30B * 2.1 0.4 1 0

cylinder) *-*__-_---_---____ ; . - .- . - - -- . .- -*---------i-------*i.... .

Heels (30B cylinder) 2.1 0.4 I 0 __._._.__.__._t,,_,,,, ._,--- - -- -----...

Waste (55-gallon drums) 0.9 1 I 0 --- *---*-------------------------------~-----------i-*-a-----*----*------------------....... . ......----

Waste (B-25) 1.8 I 1 0 ...-.. ............. ...... ----------.....--- I.....****~

Depleted UF6 (bulk bag) . 8 I I . 0

CaF2 (bulk bag) 8 0.0001 I 1 0

Notes:

'Dose rate is the external dose rate at I m from the package.

m = meter, mrem/hr = millirem per hour

To convert from m to ft multiply by 3.28.

D-8

l I
I Table D-8 RADTRAN "Link" Parameters

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

RADTRAN 1 Link

Parameter

Rural Suburban Urban

Speed (kn/hr) 88.5 40.2 24.1

Vehicle Density (vehicles/hr) . 470 780 2,800 .. . . ... - ----. . --. . . . . . . - - - .. * 4 . . - - . - . .. . . . . . .. I ....- .-.. -...... . - t . .. . -. - . .- ..-----. .

Persons Per Vehicle 2 2 2 -. -. ...- -..-...-... _... -.-..-.. _.....__....* .... ---------..... .-. .. .-.----.... t*------------... ....-.-.. .. .....----- -------

Accident Rate (accidents/vehicle-hour) 3 x 107 . 3 x IC 3 x 107 _ _ _..... _ ;_ .....-.-. . .---.- 1 -_-_-..- --- _-.--.-. .-.-. -- .- * -*i

Zone Rural Suburban Urban ......... ........ .... ---........-..........................---. -

Type Primary Highway . Primary Highway I Primary Highway ... . ......... . .. ---- -- ...

Farm Fraction . 1 0 0

Notes:

km = kilometer

To convert km to mi multiply by 0.62.

D.4.2 - Accident Parameters

To calculate the i-isk associated with accidents that result in the release of radioactive material,

RADTRAN 5 estimates the probability, or likelihood, of an accident and the consequences, or outcome,

of such an accident. The likelihood or frequency of an accident is a function of the type of road and the

number of vehicles using the road. NRC classifies accidents into eight severity categories, based on the

mechanical (impact) and thermal (fire) forces involved (NRC, 1977). Category I is the least severe and

Category VIII is the most severe. Less severe accidents occur more frequently, but have relatively mild

consequences. More severe accidents happen less frequently, but have more significant consequences,

including the release of some or all of the radioactive material in the shipment. NRC has estimated the

fraction of accidents for truck and rail transport that fall within each category. Additionally, NRC has

estimated the fraction of accidents in each category that occur in rural, suburban, and urban areas. As

shown in Table 2-9 less severe accidents are most likely to occur in urban areas, where driving speeds are

typically lower, while more severe accidents are more likely to occur in rural areas where driving speeds

are higher (NRC, 1977). These estimates when combined with average accident rates are used estimate

the number of latent cancer fatalities due to exposure to radiatioh and radioactivity from transportation

accidents. Fatalities to chemical effects and bodily injury are addressed separately. Tables D-9 and D-10

provided the fractional occurrences of accidents by-severity category used in this risk assessment.

D-9
-1

1

2

3

4

Table D-9 Fractional Occurrences of Truck Accidents by Severity Category

5

6

7

8

9

10

11

12

13

14

15

16

17

18

Accident Severity Fractional Fractional Occurrence by Population Zone

Category Occurrences of

Severity Category Rural Suburban Urban

I 0.55 0.1 0.1 0.8 ...... ....... . ... ......... .. ... .... ..... . 4.-.. ..... ,- -. --- .-----

11 0.36 * 0.1 0.1 0.8 _ .. _.- .. .... .- - H--------------- --.-- ......... . ..... ............... I-----*-- ----------- i*--I

*. 0.07 01. 0. 3 0.4 0.3 ... _.......... .. _._ ............ _...__..._ .__....._ __...__.. _..... _..__

IV . 0.016 0.3 0.4 0.3 _........_.... -..-.... --..- _._.g...........-.-... ..-.-... .-.-.- t.-*-*--i-*---.---.-*-.-.---*.. .......................................-

V * 0.0028 0.5 * 0.3 0.2

VI 0.0011 0.7 0.2 0.1 _ ..... ....... .------------.-....................................................... .

Vil 0.000085 0.8 . 0.1 0.1 _........_. ............................. _.. ....... ...........................

Vill . 0.000015 0.9 . 0.05 0.05

Source: NRC, 1977.

Table D-10 Fractional Occurrences of Rail Accidents by Severity Category

Accident Severity Fractional | Fractional Occurrence by Population Zone

Category Occurrences of

Severity Category Rural Suburban' Urban

I -: 0.5 0.1 * 0.1 * 0.8

II.. 0...3 ~ 0.1 ~ 0.1 0.8 _._. . ................ . ... __,_. .... .I-,"'-,-.---........ .... ._.._._. . . ...... ... _._._._

III 0.18 0.3 0.4 0.3 ~~ ..........

IV . 0.018 0.3 . 0.4 0.3 .. ....... . ................... -. - ..---.........-.-- .-. -----........----.-.

V * 0.0018 * 0.5 0.3 0.2 . . .....i .- .- . ..... . ...... .. . . . ....................

VI 0.00013 0.7 * 0.2 0.1 . .. ............. ....... .................

VII 0.00006 0.8 0.1 0.1 . . ....... I_._.___ ...................... _ . ._......

Vill . 0.00001 0.9 . 0.05 0.05

Source: NRC, 1977.

19

20

21

22

23

24

25

26

27

28

D-10
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

Table D-l I provides the release fraction used for each severity category. For purposes of this analysis, all

releases of material are assumed to be airborne and respirable.

Table D-11 Reiease Fractions for Accidents by Severity Category

Accident Severity Category Release Fraction

I 0 ....... ........... .... . .

. . 0.01 ------- . . __.... _..... _ ...__...............__...

III *. 0.1

IV, V, VI, VII, and VIII . I 

Source: DOE, 2002. -

D.43 RADTRAN Results

The transportation of feed material, product, heel cylinders, radioactive waste, and the products from the

conversion of depleted UF6 results in some increased risk of cancer to both the occupational workers

transporting and handling the material and to members of the public driving on the roads or living along

the transportation route. RADTRAN results for the transportation of radioactive materials associated with

operations are given in Tables D-12 and D-13 on an annual basis. The transport of all materials is

estimated to result in approximately 0.014 latent cancer fatalities per year of operation due to direct

radiation exposure during incident-free transport, and an additional 0.008 latent cancer fatalities per year

from accidents that result in the release of radioactive material into the environment. The total latent

cancer fatalities per year is estimated to be 0.02 per year of operation or about one cancer fatality over

thirty years of operation.

In addition to the transport of radioactive materials during the operation of the proposed ACP, low level

radioactive waste will be shipped to disposal sites during decontamination'and decommissioning (D&D)

of the proposed ACP. Tables D-14 and D-15 provide the RADTRAN results for the transportation of

radioactive materials'associated with all decontamination and decommissioning activities of the proposed

ACP. The number of latent cancer fatalities from the transportation of all decontamination and

decommissioning waste is estimated to be 0.3, including 0.005 deaths resulting from the release of

radioactive material from accidents.

The risk assessment described above is for product materials enriched to approximately 5 percent weight

percent of uranium-235. Although it is currently believed to be unlikely, USEC may in the future enrich

relatively small volumes of product up to 10 weight percent of uranium-235. There are currently no 2.5

ton cylinders certified for the shipment of U16. In the event this higher enrichment occurs, USEC would

have to gain the appropriate certification before it shipped 10 percent product in either an existing 2.5-ton

cylinder or in a new 2.5-ton cylinder. External exposure rates surrounding such a cylinder would likely

be similar to those around the 30B cylinders presently used to ship 5 percent product and less than the

external dose equivalent rates used in this assessment, which are considered conservative. For this

reason, the risks associated with the incident free transport of the 10 percent enriched product would not

be significantly than that of the 5 percent enriched product.

D-1
1

2

3

4

5

6

7

8

9

10

21

12

13

14

15

16

17

18

19

20

21

Table D-12 Number of Latent Cancer Fatalities Expected from the Incident-Free Transportation

of Radioactive Materials for One Year of Operation

Route Material Latent Cancer Fatalities

ME1 Drivers 1Off-Link IOn-Link IRest Stop IInspect- ILoading ITotal _ _ _ _ _ _ _ _ _ _ _ _ _ _[ Public Public _ [ i__ on Stop _ _ _

Mctropolis, IL to ACP Fccd Material 6.2 x 10-1 1.2 x 10" 6.8 x 10" 4.4 x 0 81x0 1.1 x 10- 3.0 x i0" 4.0 x 10-3

. ... ......... ....... .................... . .......... , .................. .

Port Hope, ON to ACP Feed Material 9.4 x IO0' 1.4 x IO-'I 1 .4 x0 IO1 1.1 x 10~ j1.2 x l0" 6.9 x 0 5.2 x 0 . 0 .--.-.-. 4 . j----.----.---.......................

Wilndington, DE to ACP I Feed Material 1 1.5 x IO I 2.5 x 10-41 2.2 x I0~ 1.7 x 10-4 l~1 1. 0 It. . I . 0 ......................................... ............ - . * ~-1~...... ... ......

ACP to Richland, WA Prdc . 01 28 l~ i l3 1 ' .1xl104I 2.6xx10 4 i l 104 1 6.5 x10' 8.3K x 10 ........................... ~...- ..... .... ............... t...................... :...........................

ACP to Colur baSCProduct 5.9 x 10.30 1 8.8 x i0-5 0 5 2 x i ~ 1 3 8 f. . K i ~ 7 7 x 1 10.4 

. ...................

ACP to Wiln-ington, NC Product 6.7 x 1-1" 1.2 x 104: 1.2 x 10- 1 7.0 x l0-I 8.7 x i0-5 6.4 x 10-1 8.7 x IO- 1 4.4 x 10o4

..----.............. 1...

A P Sate, t W (K ra) Product 1.3 10 0 1 1. K i0 1 4.0 x 10'6 3.6 x i0- 1 8.3 Kx 0~ 3.3 x 10,5 J 1.6 x 10 -i 2.8 K 10-1

ACP to Seattle, WA (Japan) Product 11.9 x 1030 11.5 x i 17.7 x 10-61 7.0 x IO's1 2.3 x 0 5.4 x IO'sI 2.2 x iO0 I 5.4 x I'~ .................-. ............

Richland, WA to ACP I Heels 8.9 x 10~" 5.l xlIO-' 2.3Kx 10-6 1l.9 x10 5 I 4.7 x10 5

' 1.9x X 0-1 4.9x 10-'I 1.9K x 10 . ... ~~... .... . ........................

Columbia, SC to ACP 89K.l0x i0 .3K l4.9 8.Heels . ,.8. 10l.6x xI x 10"5

AC i ~ e C TLLW 1.3x7.xI0 1.3 6.4 x 10-5 . 4.1K x 0-' 7.3x l0 I 4.7 x 10~

A C P to NC l ada U T es i e,3 L W 1 .4 x 10 10 1.7 0 .6 x 10-6 1X. O . 0 ~ 1 3 8 K i - . I O., .5 X

.................................. .. '............... ..... ........... . ........... . .....------------- ------------. ---------

ACP to Gainsville, FL Mixed LLW 7.3 x 10-' 1 2.5 x 10-s 1.6Kx 10-6 9.3 x 10-6 1 .4 x I-' 1 .4 x IO 1.0 x I0-' 7.5 x IO-s .............. ------------........ ...... ........

Piketon, OH to Clive, UT U30 2 3.2Kx 10-"1 2.2 Kx0- 7.3 x 0 I7.3x 10O' 2.7 x10 5 0 0 12.8 xIO's

Piketon, OH to Clive, UT I CaF2 13.2 x 10`' 2.2 x 10.30 7.3 x 10-" 7.3K 10I-" 2.7K x 0-9 0 1 0 13.1 x 10-'

Totalj 9A4x 10-' 4.0 x 10-3 2.9 x 104 2.2 x10-3 3.3K xi10 2.4Kx 1 0 -3 1.4K xi0-1 1.4 x 10-

D-12
1

2

3

Table D-13 Number of Latent Cancer Fatalities Expected from Accidents Resulting from the

Transportation of Radioactive Materials for One Year of Operation

4

5

6

7

8

9

10

1

12

13

14

15

16

17

18

19

20

21

Route Material Latent Cancer Fatalities

Ground Inhaled Resuspended Cloudshine Total

Metropolis, IL to ACP i Feed Material i 5.2 x 10-' 4.8 x 104 3.2 x 104 3 5 x I W 8.0 X 104 ................... . . - - .....

Port Hope, ON to ACP , Feed Material i 1.3 x 105 1.2 x IO- 8.0 x i 8.8 x 10"' '0 X 1x0. ................. .4.. ............... ................ . ........ . ....... ...................... ............... I............ ........-.... 

Wilmington, DE to ACP s Feed Material 9.8 x 10' 8.0 x 104 52 x .5 x 1.3 x 10- ............. . , . ; . 1..................................................

ACP to Richland, WA Product * 7.5 x 104 1 6.6 x l04 ; 2.1 x lO 2.0 x 10.'° . 8.7 x 104 -.. ....... ......... .. ............................ --.

ACP to Columbia, SC } Product J 4.9 x 10- 6 4.3 x 104, 1.3 x 104 1.3 x 10.20 J 5.6 x 104 - . .i ...................................... ..

ACP to Wilmington, NC i Product 6.5 x 10-6 5.7 x l 1 1.8 x 1 1 1.8 x 10°0 i 7.5 x 104

*----- * *----------------------------- ------- t - - ... --------- ------ ........................................................ ............ 4.... .....................

ACP to Seattle, WA (Korea) . Product j 2.5 x IO0 2.1 x 10 4 6.9 x 10-5 6.6 x 10-'1 2.8 x 10' . . .. ... .. ....... ...... .. . .. .... ..... ...............................................................

., ...-. . . . . .. . . ,... 104... ACP to Seattle, WA (Japan) Product 3 5 x 10 30x104 9.6 x 10-' 9.2 x 10". 3,9 x ... . ............. . ........ .... .... . .. . ......-.-.-.-............-.................-.-..-........-...-.-......................-........-.-. .-......-.i. .-...... .-...-

Richland,WAtoACP | Heels 5.;2 x0 3.2 x 104' | 7.2 x 1 o 1.x 10.20

. .... -. . * ......... -........... 

Columbia, SC to ACP t Heels i 2.8 x 10" l.8x 104 i 4.0 x 10-6 5,5 x 10" ' 5.8 x 10 . -----------------... ................. ............................... ............................... ----------------------------- ....................... .. . ...............................

ACPtoCliveUT , LLW 5 5.2x 10' 44x 10'6 5.1 X 10-6 5.7x 0.2 9.5x 104

ACP to Nevada Test Site, NV j LLW 8.8 x 10'9 5.5 x I0'7 1.7 x 10 i 4.5 x 102 . 2.2 x 106

. ... . ...... .. . -- ,...4.... .. . .. . I.. .. ACP to Gainsville, FL LW 2.0 x 10-9 1.3 x 10-7 57 x i0 i 10 X 10.22 7.0 x 10-7

O H. ... to........d .... LL W . ....... ........... ........ ................. ------------------. -

Piketon,OHt Clive, UT I U3 o0 1 1.7 x IO- I 7.4 x 10 4 6.1 x 10 ~ 9.1 X 10.20 l 7.5 x 1- . .... .. . ... ...... ......... .. .................. ........... .......... .

Piketon, OH to'Clive, UT C I 3.5 x 101 2.9 x 6.I 13 x IO-' 3.6 X lO-' i .6 x 10-' ito; iix 5to 10-; 2I.4 13 23x;0; 3o110_ ; _ ix 10-3

Total j 5.4 x los 5.4 x 10-3" 2.3 x 103" 3.1 x 10-9' 7.8 x i03~

D-13
1

2

3

4

Table D-14 Number of Latent Cancer Fatalities Expected from the Incident-Free Transportation of

Radioactive Materials of All Decontamination and Decommissioning (D&D) Waste

5

6

7

8

9

10

I11

12

13

14

15

16

17

18

Route Material Latent Cancer Fatalities

MEI | Drivers 1 Off-Link On-Link T Rest Stop Inspect- Loading I Total

| | Public Public | | ion Stop | j

ACP to Clive, UT - D&D Waste 4.1 x l0o- 1.4 x 10'3 8.6 x l0' 7.4 x 104 2.2 x IO'! 1.9 x 10- | 4.7 x 104 ! 6.8 x 104 .. ** .................................... . ......

ACP to Nevada Test Site, NV D&D Wastc 1 2.0 x 10'7 8.9 x 02. 5.1 x 10-3 4.8x102 10- .2x0' 3.lx 1-2 2.1x 10-2 3.1x 10' ...................... i *---------------- --------- --------------------------- - --------------------- * .

ACP to Kingston, TN D&D Waste 1.8 x 10' 1 2.7 x 10 i 1.5 x 10-6 1 .0 x12 10 i 1.O X 10-5 I l.l X 10 I 1.7 x 10

Total 2.0 x 10'7 9.1 X 10.2 5.2 x 10-3 4.9X 103 I.2x 10- 3.2x 102 2.1x 10 J 3.2 x 10-

Table D-15 Number of Latent Cancer Fatalities Expected from Accidents Resulting from the

Transportation of Radioactive Materials of All Decontamination and Decommissioning (D&D) Waste

Route [Material Latent Cancer Fatalities

! | Ground | Inhaled ! Resuspended Cloudshine Total

ACP to Clivc, UT D&D Waste t 3.2 X 10' 2.5 x 1O'5 4.7 x 10-i 3.3 x 10" . 7.3 x 10-5

...................................... .' ............ --------- ................ ---------------- ................................ ]---------------------

ACP to NevadaTest Site, NV . D&D Waste i 2.1 x 10-5 I 1.6x 10' , 3.0x 10' 1 2.1 x 109 4.7x 10' . ............... i----------------------------- --.------ ........ - -- i -.- .

ACP to Kingston, TN D&D Waste . 7.5 x 10i9 5.3 x 10' . 1.2 x 10' 6 4.4 x 10'2 1.7 1 x 10'6

Total | 2.1 x l0o- 1.7 x 10 4 3.1 x 10-3 2.1 x 10' J 4.7 x 104

I D-14
-

I However, the accident related radiological risks associated with the transport of the 10 percent enriched

2 product would be somewhat greater than that of the 5 percent enriched product. This primarily due to the

3 higher activity of uranium-234 in the 1O percent enriched product. Uranium-234 does not contribute

4 significantly to the external dose rate, but is an inhalation hazard if released. Table D-16 shows the

5 calculated latent cancer fatalities from the transport of the higher enriched product material for the same

6 routes used previously. The number of expected latent cancer fatalities associated with the transport of

7 product material only would be approximately a factor of three greater than that previously estimated. It

8 should be noted that this factor of three is conservative in that it assumes all the product material is

9 enriched to 10 percent; and that it does not account for the decreased risks associated with lower activities

10 of uranium-234 in shipment of the conversion products.

D-15
1

2

.3

4

5

6

7

8

9

10

I1I

Table D-16 Number of Latent Cancer Fatalities Expected from Accidents Resulting from the

Transportation of Product Material Enriched to 10 Percent for One Year of Operation

Route Material Latent Cancer Fatalities

Ground Inhaled Resuspended [ Cloudshlne [ Total

ACP to Richland, WA * Product 1 1.6 x lo-, 2.3 x10' 1.4x 104 3.6 x 10-10 ' 2.5x 10'

ACP to Columbia, SC Product 1.0 x lO- 1.5 x 103 9.4 x 10 ' i 2.4 x 101 , 1.6 x 103

................ ACP to Wilmington, NC Product , 1.3 x10 1 .2.0 x 103 1.3 | 3.1 x iO- I 2.1 x 104

ACP to Seattlc, 

............... WA (Korea) . Product t 5.2 x 104 6 7.5 x 10- 4 1.1 x 104 1.2 x 10.10 8.6 x 104 .. ........ -'... .... . ............. ......... .*~.........

ACPto Seattle, WA(Japan) Product j 7.3 x 106 1.0 x 10 3 I 1.5 x 0 * .6 x 1010 i 1.2 x 104

Total 5.2 x 105 7.6 x 104 6.2 x 10 1.2 x 10 ' 8.3 x 103

D-16
-

1 D.5 Chemical Impacts from Transportation Accidents

2

3 In addition to the radiological impacts during transportation described above, chemical impacts from a

4 transportation accident involving uranium could also affect the surrounding public. Uranium compounds,

5 in addition to being radioactive, can have toxic chemical effects (primarily on the kidneys) if inhaled or -

6 ingested. The operation of the ACP would result in the transport of UF6 as feed and product material to

7 and from the ACP, as well as the transport of triuranium octaoxide as a conversion product. Calcium

8 fluoride, another conversion product, contains small amounts of uranium as a contaminant.'

9

10 Uranium hexafluoride does not react with nitrogen (N2), oxygen (02), carbon dioxide (CO2) or dry air, but

11 does react rapidly with water vapor to hydrogen fluoride' (HF) and uranyl fluoride (UO2F2):

12

13 UF6 + (2+4 x) H20 - U0 2F2 * 2 H20 + 4 HF * x H20

14

15 Hydrogen fluoride is extremely corrosive and can damage the lungs and cause death if inhaled at high

16 enough concentrations. Irreversible adverse effects resulting' from sufficiently high concentrations of

17 these chemicals include permanent organ damage or the impairment of everyday functions, and possibly

18 death. The number of deaths resulting from the chemical effects of hydrogen fluoride and uranyl'fluoride

19 is estimated to occur in one percent of those experiencing irreversible effects (Policastro et al., 1997). In

20 contrast to the irreversible adverse effects from exposure to higher concentrations of hydrogen fluoride

21 and uranyl fluoride, the adverse effects from exposure to lower concentrations include'skin rash and

22 respiratory irritation.

23

24 To estimate the chemical effects of an accident involving the transport of UF6, the Department of Energy

25 (ANL 2001, DOE 2004) modeled the dispersion of chemical emissions released into the environment

26 from a transportation accident involving a fire. The results were used to determine the number of people

27 whose exposure would exceed the threshold for adverse and irreversible adverse effects. DOE estimated

28 the chemical effects for accidents in rural, suburban, and urban areas. Table D-17 shows the potential

29 chemical impacts to the public from a hypothetical severe transportation accident that involves a fire.

30

31 Table D-17 Potential Chemical Consequences to the Population32 from Severe Transportation Accidents

33

34

35

36

37

38

39

40

41

* 42

43

44

45

Material Mode Number of Persons with Potential Number of Persons with Potential

Adverse Health Effects Irreversible Adverse Health Effects

Rural Suburban Urban Rural Suburban Urban

UF6 Truck 6 . 760 *1,700 . 0 1 I . 3

U3 08 Rail 0 47 100 3 17 38

Source: DOE, 2004.

Based on the total number of trips, the length of the trips, and the mean accident rate, the estimated

number of accidents involving shipments of UF6 is 0.5 accidents per year, or an average of one accident

every two years. Of these accidents, approximately 55 percent will not result in the release of any UF6,

and another 43 percent will result in a release of no more than 10 percent of the U176. About 2 percent of

all accidents are expected to be severe enough to result in the release of all the UF6 present. The

probability of one or more of the fifteen expected accidents being this severe is about 26 percent. Such an

accident is most likely to occur in a rural or suburban area.

D-17
1

2

3

4

5

6

7

8

9

10

I 1

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

D.6 References

(ANL, 2001) Argonne National Laboratory. "Transportation Impact Assessment for Shipment of

Uranium Hexafluoride (UF6) Cylinders from the East Tennessee Technology Park to the Portsmouth and

Paducah Gaseous Diffusion Plants" ANL/EADjTM-1 12. Environmental Assessment Division. October

2001.

(DOE, 2002) U.S. Department of Energy. "A Resource Handbook on DOE Transportation Risk

Assessment." DOE/EM/NTP/HB-0 1. National Transportation Program. July 2002.

(DOE, 2004) U.S. Department of Energy. "Final Environmental Impact Statement for Construction and

Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio, Site."

DOE/EIS-0360. Office of Environmental Management. June 2004.

(NRC 1977) U.S. Nuclear Regulatory Commission. "Final Environmental Statement on the

Transportation of Radioactive Material by Air and Other Modes." NUREG-0 170. 1977.

(Osbom et al., 2005) Osbom et al. "RadCat 2.0 User Guide." SAND2005-0142. Sandia National

Laboratories. January 2005.

(ORNL, 2003) Oak Ridge National Laboratory. "Transport Routing Analysis Geographic Information

System (TRAGIS) User's Manual." ORNLINTRC-006. Revision 0. June 2003.

(Policastro et al., 1997) Policastro, A.J., et al., 1997, Facility Accident Impact Analyses in Support of the

Uranium Hexafluoride Programmatic Environmental Impact Statement, attachment to intraoffice

memorandum from Policastro et al. to H.I. Avci (Argonne National Laboratory, Argonne, Ill.), May.

(USEC, 1995) United States Enrichment Corporation. "Uranium Hexafluoride: A Manual of Good

Handling Practices." USEC-651. Revision 7. January 1995.

(USEC, 2005) United States Enrichment Corporation. "Environmental Report for the American

Centrifuge Plant" LA-3605-0002. Revision 3. NRC Docket No. 70-7004. July 2005.

D-18
1 APPENDIX 

E

2 AIR QUALITY ANALYSIS
I APPENDIX E

2 AIR QUALITY ANALYSIS

3

4 E.1 Air Dispersion Modeling Inputs

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6 This section discusses the inputs used in the application of the ISCLT3 air dispersion model (EPA, 1995)

7 to assess the non-radiological air quality impacts from site preparation and construction as well as from

8 the operation of the proposed ACP. Modeling results can be found in Chapter 4 of the Draft EIS.

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E.1.1 Emissions from Site Preparation and Construction

Emissions during the site preparation and construction phases can be divided into four parts: emissions

from diesel equipment used by the work crews, emissions from gasoline-powered trucks used by the work

crews, emissions from commuter vehicles and delivery trucks, and fugitive dust from construction

activity for the construction of new buildings. Emissions related to work crews, crew trucks, and fugitive

dust were modeled as area sources with the same footprint as the building being constructed or prepared.

Emissions from on-road vehicles were modeled as elongated area sources following the most likely

(shortest distance from main entrance) route of traffic.

During the construction period, four work crews are expected to be active: the steel crew, the electrical

and mechanical crew, the equipment crew, and the utilities crew. Equipment and fuel proposed for use

for each crew are summarized in Table E-1. (USEC, 2005) Diesel equipment is assumed to consume one

gallon of fuel per 10 hp per day with equipment horsepowers were taken from the Means Open Shop

Building Construction Cost Data Book (USEC, 2005). Each crew trucks is assumed to consume 10

gallons of gasoline per day.

Table E-1 Equipment and Fuel Use Associated with each Crew

Steel Crew | Electrical and Mechanical Crews

90T Crane 275 hp I . Bucket Truck . 200 *hp

Wcldin& 50 lhp . 55T Crane 170 : hp

Diesel 260 . al/day 12T Crane 40 . T .p

Gas 40 * g1Ida . Diesel . 328 *.d -'~ .-- -*.-----.--* .- --. 

- Gas 30 gal/day

Utilities Crew _ Equipment Crew ;

Excavator _ ~~~~~~. 240 _._ ..... _._ ........ ... hp _ _ ._._ ........ 90T Crane __ 275 * ... __ _._. ....... _T hp _._..... _.. _

Diesel 192 . alda . Diesel 220 - -- *-*-----*----- ......... - . ----------- - -------- -

Gas - 10 * gal/daVy:. - Gas - 20 gal/day

Notes:

gal/day = gallons per day; hp = horsepower*

The NONROAD model is the EPA's standard method for preparing emissions inventories for mobile

sources that are not classified as being related to on-road traffic, railroads, air traffic,'or water going

vessels (EPA, 2002a). The model was developed to estimate county-level emission inventories, but

contains all of the information needed to develop a facility specific inventory. Thus NRC used the used

the supporting information from the NONROAD model for developing a site-specific emission inventory.

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The NONROAD model uses the following general equation to estimate emissions separately for CO,

NO,, PM (essentially all the PM from combustion is PM2 5 ), and THC:

EMS = EF * HP * LF * ACT* DF (Eq. 1)

where:

EMS = estimated emissions

EF = emissions factor in grams per horsepower hours

HP = peak horsepower

LF = load factor (assumed percentage of peak horsepower)

ACT = Activity in hours of operation per period of operation

DF = Deterioration Factor

The emissions factor (EF) is specific to the equipment type, engine size, and technology type. The

technology type fordiesel equipment can be "Base" (before 1988),TierO(1988-1999), orTier 1(2000-

2005). Tier 2 emissions factors are appropriate for equipment that satisfies 2006 national standards (or

slightly earlier California standards). The range in years represents a phase-in by equipment type, engine

size and technology. Since most construction activity is schedule for the 2007-2010 time period it wasassumed that equipment would meet the Tier I standard. Different emissions factors are applied to

different ranges of engine sizes. These size ranges are lower bound exclusive and upper bound inclusive.

Thus a 175 hp diesel forklift is included in the 100-175 hp range rather than the 175-300 hp range.

The load factor (LF) is specific to the equipment type in the NONROAD model regardless of engine size

or technology type and represents the average fraction of peak horsepower at which the engine is assumed

to operate.

The deterioration factor (DF) is used to estimate increased emissions due to engine age and is calculated

according to the following equation:

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DF = I + A*(AGE)b (Eq. 2)

where:

A,b = factors given specified in the NONROAD model

AGE = normalized age of the engine

The normalized age of each type of engine appearing in the NONROAD model is calculated using

equation 3:

AGE = (cumulative hours of operation) * LF / (median engine life) (Eq. 3)

The median engine life is specified in the NONROAD model's data files and LF is the load factor used in

equation I above. The "cumulative hours of operation" can be calculated by multiplying the age in years of the engine by the average activity assumed by the NONROAD model. For this study we assumed a

nominal equipment age of five years.

The source classification code and name associated by the NONROAD model with each piece of

equipment is presented in Table E-2.

E-2
I Table E-2 Equipment with Source Classification Codes and Names

2 as they appear in the NONROAD Data Tables

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Equipment Source Classification NONROAD Name

Code

Bucket Truck . 2270003010 I Diesel Aerial Lift

Crane 227000205 Diesel Crane

Excavator *2270002036 I Diesel ExcavatorF

Welding .2270006025 IDiesel Light Commercial Welder

10 All of the information needed to estimate the facility specific emissions is available as part of the

11 NONROAD model's data files. Sample calculations for estimating CO emissions from the 240 hp

12 excavator follow.

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14 From the NONROAD model data file ACTIVITY.DAT the following record is associated with diesel

15 powered excavators (some blank spaces have been deleted):

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17 2270002036 Diesel Excavators ALL 0 9999 0.59 hrs/yr 1092 DEFAULT

1 8

19 The fields of interest are the load factor (0.59) and the average hours of operation per year (1092). The

20 other fields appear identical for all equipment and are intended for use in a future version of the model.

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22 The data file with emissions factors for each pollutant is called EXHCO.EMF which contains the exhaust

23 factors for CO. The following lines are associated with diesel excavators between 175 and 300 hp (some

24 blank spaces and additional technology types have been deleted):

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26 2270002036 175 300 Base TO - Ti T2 g/hp-hr CO

27 3.98 4.13 1.14- 1.14

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29 Once again the source classification code appears followed by the minimum and maximum horsepower

30 for the following emissions factors. Because all equipment is assumed to be Tier I (TI) the emissions

31 factor will be 1.14 grams of CO per horsepower-hour. In this case an advance to Tier 2 would not produce

32 an improvement, but it could for other pollutants and/or other equipment types and sizes.

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34 To estimate the emissions per eight-hour day using Equation I all that is needed is to calculate the

35 deterioration factor.

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37 The following record is associated with Tier 1 diesel equipment in the file EXHCO.DAT:

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39 Ti 0.101 1.0 1.0 Co

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41 The second field gives factor "A" from Equation 2; the third field gives factor "b"; and the fourth field

42 gives the emissions cap in median life units (the largest number that can be used for "age" in Equation 2).

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44 To determine the "age" used in Equation 3 it is now necessary to know the cumulative hours of operation

45 and the "median engine life." This information is found from equipment type population survey's

46 available for each state.: For Ohio, the equipnient population file OH.POP gives the expected useful life

47 of a diesel excavator between 175 and 300 hp as 4,667 hours (some blank spaces have been deleted):

48

49 39000 2000 2270002036 Dsl - Excavators 175 300 233.3 4667 DFAULT

50 1577.2

E-3
I It is now possible to calculate CO emissions for the excavator.

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Starting with Equation 3:

AGE = (5 years * 1092 hrs/yr)*0.59/(4667 hours) = 0.69

Then Equation 2:

DF = I + 0.101*(0.69)1 = 1.07

Finally Equation 3:

EMS = (1.14 glhp-hr)*(240 hp)*(0.59)*(8 hr/day)*(1.07)*(0.002205 lb/g) = 3.05 lb/day

The above process was used to estimate emissions of PM, CO, NO., and non-methane hydrocarbons

(NMHC). All PM was assumed to be PMm. S02 emissions were calculated by mass balance using the

2007 nonroad sulfur emission standard (500 ppm) and an average density of 7.1 lbs per gallon of diesel.

Each work crew was assumed to have one truck for every four people (USEC, 2005). Emissions were

estimated assuming that each crew had a truck similar to a Ford F-150 Supercab meeting Tier I standards

with at least 80,500 kilometers (50,000 miles) of use. Such a truck fits into the Heavy Duty-Light Truck

classification. Table E-3 gives the emissions standards for this truck type. Each truck was assumed to be

in use for a full eight-hour day (USEC, 2005) traveling at an average speed of five miles per hour.

Table E-3 Emissions from crew trucks

NMHC CO NOx PM

grams/mile 0.56 . 7.3 1.53 0.12

grarns/day . 22.4 * 292 . 61.2 * 4.8

Notes:

To convert grams to ounces multiply by 0.35.

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SO2 emissions from crew trucks were calculated by mass balance using the 2007 gasoline sulfur standard

(30 ppm) and an average fuel density of 6.1 lbs per gallon of gasoline.

Emissions from on-road heavy-duty delivery trucks and commuter cars and trucks were estimated using

EPA's MOBILE6.2 model (EPA, 2002b). Long-haul diesel truck emission rates were estimated based on

trucks operating in 2010 using national fleet age distribution. Medium-haul diesel trucks were based on

the same parameters. Commuter vehicle emissions rates were applied using national defaults for fleet age

distribution, but assumed that the fleet mix was half light duty gasoline vehicles and half light duty

gasoline trucks. Table E-4 gives emission rates for delivery trucks and commuter vehicles.

Table E4 Emissions rates for on-road vehicles (grams per mile)

._ NMIHC * CO NO PM,, . SO,

Long-Haul Heavy Duty Diesel 0.36 1.3 5.61 0.11 0.01

Delivery Truck_. ... . - ....

Medium-Haul Heavy Duty

Diesel0DeliveTrucks 0.44 1.9 8.32 0.16 001 ... . ...... ..... . . ... .. . ....... ...........

Commuter vehicles 0.83 10.6 0.66 0.03 0.01

Notes:

To convert grams per mile to ounces per mile multiply by 0.035.

E4
- -

I Delivery trucks were modeled as'elongated area sources originating at the facility's main entrance and

2 taking larger roads to the north end of the construction area. Commuter vehicles were modeled as

3 elongated area sources originating at the southwest construction access entrance and following interior

4 roads to the parking lot south of the construction area. During the construction period an average of 28

5 one-way truck trips (9 long-haul and 19 medium-haul) per day and 2,612 one-way commuter trips per day

6 were modeled. This assumed that each construction'worker arrived in a single occupant vehicle.

7

8 Emissions rates for fugitive dust were estimated using guidelines outlined in the Western Regional Air

9 Partnership fugitive dust handbook (WRAP, 2004); Although these guidelines' were developed for use in:

10 western states they assume standard dust mitigation activities, such as wetting, so they were deemed

11 applicable to a Midwestern setting. The handbook offers several options for selecting PM, 0 factors

12 depending on what information is known. Table E-5 shows the possible emissions factors and bases for

13 choosing them.

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15 Table E-5 PM10 emissions factors recommended by the

16 Western Regional Air Partnership Handbook

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Basis for Emission Factor Recommended PM10 Emission Factor

0.11 ton/acre/month (average conditions)

or

Only area and duration known 0.22 ton/acre/month (average, no mitigation)

or

0.43 ton/acre/month (worst-case conditions)

0 0011 ton/acre/month for general construction

PAUS

Volume of earth moved known 0.059 ton/1000 yd3 for on-site cut-fill

plus

.. 0.22 ton/1000yd3 for off-site cut-fill . . _.................. _. .. . ...... . ..... . ..... . _. . . _.... _...... . ... _...... ....... .I

0. 13 lb/acre/work-hr for general construction.

Plus Equipment usage known*' E 49 lb/scraper-hr for on-site haulage

* 94 lb/hr for off-site haulage

Notes:

lb = pounds; yd'= cubic yards; hr = hour

Because equipment usage is known, the third option is most appropriate for the proposed ACP. However,

because the foundations have been dug and the fill has been hauled before the modeled construction

period only the 0.13 pound/acre/work-hour factor was applied. Once PM, 0 was estimated, the Western

Regional Air Partnership recommended fractional factor of 0.209 was used to estimate PM_5 from PM10.

Fugitive dust emissions were only applied to new buildings and then only to the construction phase, not to

other phases such as equipment installation.

E.1.2 Emissions from Plant Operations

Air emissions during plant operation were associated with the use of emergency backup generators

burning diesel fuel as well as the on-road delivery trucks and commuter vehicles. These are the only nonradioactive emissions associated with the normal operation of the proposed proposed ACP.

E-5
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I Emissions factors for on-road vehicles were identical to those used for the construction phase. During

2 plant operations, however, an average of 24 one-way delivery truck trips per day and 1,116 commuter

3 one-way trips per day were modeled.

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A number of diesel-powered emergency generators will be installed at the plant. The generators' total

emissions rates for CO, NOx, PM10, PM23, SO2, and NMHC were modeled using specifications from a

proprietary appendix to the Environmental Report (USEC, 2005).

Each generator was modeled as a point source located at the assigned building as identified in a

proprietary index to the Environmental Report (USEC, 2005). Stack parameters were based on a typical

1,109 hp diesel generator described in Appendix 7 of CARB's Diesel Risk Reduction Plan (CARB, 2000)

with the exception that the stack height was increased from 3 meters to 10 meters to reflect good.

engineering practice to avoid downwash effects assuming that the stacks are located on top of the

building(s). Table E-7 lists the stack parameters used in modeling the generators.

Table E-7 Stack Parameters for Diesel Generators

Stack Temperature Stack Height J Stack Diameter Exit Velocity

787 30m 0.25m . 59.8 m/s

(10 m above roof)

Notes:

K = 'Kelvin; m = meter, mls meters per second.

To convert 'K to IF use the following formula: F = ((0K - 275.15) x 1.8) + 32

To convert meters to feet multiply by 3.3

E.1.3 Emissions from Manufacturing and Assembly

[The information on lines 28 through 48 is being withheld pursuant to 10 CFR 2390.1

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[The information on lines 1 through 30 is being withheld pursuant to 10 CFR 2.390.1

E.2 Meteorological Inputs

Surface meteorological data, including wind data, have been collected at the on-site meteorological tower

at the 10-, 30-, and 60-meters (33-, 98-, and 197-feet) levels. The tower is in the southern part of the

reservation. A comparison of annual wind roses for the period 1995 through 2001 indicates that wind

patterns at the 10-m (33-ft) level are different from those at the 30-mr and 60-meters (98- and 197-feet)

levels. Winds at the 10-mr (33-ft) level appear to be influenced by local topographical and/or vegetative

features. Accordingly, wind data at the 30-meters (98-feet) level, believed to be representative of the site,

E-8
I were used in this analysis. This same meteorological data set was used in the radiological air quality

2 assessment.

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4 Seasonal temperatures from Waverly, OH (NOAA, 2000) and mean mixing heights were obtained from

5 Huntington, WV (Holzworth, 1972). Table E-12 lists temperature data used in modeling and Table E-13

6 gives the mixing heights.

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8 Table E-12 Seasonal temperatures (fK) for Waverly, OH (Climatology:1960-1991, NOAA)

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Minimum Maximum Average

Winter . 267 273 279

. 277 284 291

Summer 28289 296 302

Fall * 278 * 285 292

Notes:

='Kelvin KK 

To convert 'K to IF use the following formula: 0 F = ((fK -275.15) x 1.8) + 32

Table E-13 Mean afternoon mixing heights (meters) for Huntington, WV (Holzworth, 1972)

Winter 1,079

Spring . 91,986 ... _ ______ .. _....._

Summer . 1,641

Fall . 1,340

Notes:

To convert meters to feet multiply by 3.3.

E.2 References

(CARB, 2000) California Air Resources Board. "Risk Reduction Plan to Reduce Particulate Matter from

Diesel-Fueled Engines and Vehicles." Appendix 7, Sacramento, CA. October 2000.

(EPA, 1995) U.S. Environmental Protection Agency. "User's Guide for the Industrial Source Complex

(ISC3) Dispersion Models." Volume 1. EPA-454/B-95-003a. September 1995.

(EPA, 2002a) U.S. Environmental Protection Agency. "User's Guide for the EPA Emissions Model

Draft NONROAD 2002." EPA-420-P-02-013. December 2002.

(EPA, 2002b) User's Guide to MOBILE6.1 and MOBILE6.2: Mobile Source Emission Factor Model

(Draft). EPA420-R-02-010. March 2002.

(Holzworth, 1972) Mixing Heights, Wind Speeds, and Potential for Urban Air Pollution Throughout the

Contiguous United States, EPA, Office of Air Programs, RTP, AP-101. 1972.

(NOAA, 2000) Climatography of the United States No. 20, 1971-2000., Waveriy, Ohio, National Oceanic

Atmospheric Administration, National Climate Data Center, North Carolina. 2000.

(USEC, 2005) Environmental Report for the American Centrifuge Plant in Piketon, Ohio, Revision 3.

LA-3 605-0002, Docket No. 70-7004. July 2005.

E-9
I (WRAP, 2004) Western Regional Air Partnership. "Fugitive Dust Handbook." Prepared by Countess

2 Environmental, 4001 Whitesail Circle, Westlake Village, CA. under contract to the Western Governor

3 Association (WGA), WGA Contract No. 30204-83. November 2004.

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E-10
1 APPENDIX 

F

2 ENVIRONMENTAL.JUSTICE ANALYSIS
1 APPENDIX F

2 ENVIRONMENTAL JUSTICE ANALYSIS

3

4 This appendix provides additional data for the assessment of the potential for disproportionately high and

5 adverse human health or environmental effects on minority and/or low-income populations resulting from

6 the proposed construction, operation, and decommissioning of the proposed American Centrifuge Plant

7 (ACP).

8

9 Tables F-1 and F-2 present detailed year 2000 Census data for the environmental justice analysis at the

10 State and county level, respectively. The tables provide minority and low-income'population data for

11 each Census tract within 80 kilometers (50 miles) of the proposed ACP. Census tracts exceeding

12 minority or low-income criteria are shown in bold.

1 3

14 A summary of the number of Census tracts exceeding minority and/or low-income criteria is presented in

15 Tables F-3 and F4' Table F-3 summarizes information at the State level; Table F-4 summarizes

16 information at the county level.

1 7

18 Refer to Chapter 3 of this Draft Environmental Impact Statement (EIS) for methods and references'

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Table F-1 State Population Data, by Census Tract ab

Below African Native Asian and Other Two or Hispanic .r.

Census Tract Persons Poverty Wites American/ American Pacific Islander Races More Races or Latino Minorities

Level (%) Black (%) (%) (%) (%) (%) (%)

StateofOhio 11353140 10.6 84.9 11.5 0.2 1.2 0.8 1.5 1.9 16

Threshold for EJ Concerns NA 30.6 NA 31.5 20.2 21.2 20.8 21.5 21.9 36

Adams County

39001990100 4868 22.4 96.8 0 1.3 0 0.1 1.7 0.8 3.9

39001990200 4635 13.1 98.4 0 0.2 0.2 0.1 1.1 0.6 1.9

39001990300 6212 12.6 98.8 0.1 0.1 0 0.2 0.8 0.3 1.5

39001990400 4630 17.6 97.8 0 1.3 0 0 1 0 2.2

39001990500 3454 21.7 96.3 0 1.6 0 0 2.1 0 3.7

39001990600 3531 19.6 99 0 0.1 0.1 0 0.8 0.5 1.5

Athens County

39009972800 4272 27.7 97.4 0.4 0.8 0.4 0.3 0.6 1.8 4

39009972900 5362 29.8 90.9 3.1 0.4 3.1 0.3 2.1 0.5 9.5

39009973200 4320 17.4 87.8 3.7 0.5 4.4 0.5 2.5 2.2 13

39009973700 3967 13.9 95.7 1.2 0.6 0.8 0.2 1.6 1.4 5.7

39009973800 4642 11.3 98.4 0.2 0 0.7 0.1 0.5 0.5 2

Brown County

39015951200 9522 6.2 98.3 0.2 0.1 0.3 0 1.1 0 1.7

39015951300 6435 12.3 98.7 0.3 0.2 0.3 0 0.5 0.3 1.6

39015951400 .4408 14.4 98.6 0.4 0 0.1 0 0.8 0.5 1.9

39015951500 4896 12.3 98.5 0 0.9 0.4 0 0.2 0 1.5

39015951600 3869 16.5 97.4 1.1 0.3 0.2 0.2 0.8 1.4 3.5

39015951700 2764 15.3 92.8 4.8 0.1 0.1 0.1 2.1 0.6 7.6

39015951800 4650 12.2 97.4 2 0.2 0.1 0 0.3 0.4 2.9

39015951900 5741 12.1 99 0 0.2 0 0.3 0.5 0.6 1.2

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Table F-i State Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic Minorities

Census Tract Persons Poverty Whites O% American/ American Pacific Islander Races More Races or HipncMnrte Latino (e/ Level ( e) Black (%) (%) (%) (%) (%) (%)

Clinton County

-39027994300 3871 10.3 97.6 0.9 0 0.1 0.4 I 0.1 2.4

39027994400 - 4808 4.4 98.1 0 0.7 0 0 1.2 0.2 2.1

3967 739027995000 79 99.3 - 0.1 0.2 0.1 0 0.4 0.1 0.7

39027995100 4105 8 97 0.1 1.2 0.2 0.9 0.6 1.2 3.2

Fairfield County --

- 39045031200 4901 6.1 99.3 0 0 0.1 0.3 0.3 1.3 1.8

39045032500 5996 6.1 83.8 14 0.4 - 0.1 0.3 1.1 0.7 16.2

39045032600 - 5840 5 99.1 0.1 0.2 0 0.1 0.5 0.4 1.2

Fayette County:

39047985800 3785 9.1 96.9 1.3 ,0.2 0 - 0.8 - 0.8 0.9 - 3.2

39047985900 3847 8.7 95.3 :2.2 0.2 0.1 - - - 0.1 2 0.9 5.2

39047986000 4180 9.4 96.1 0.6 0.4 2.4 0 0.6 0.8 4.7

.39047986100 4132 -- 17.1- 94 4 0 0 .-- 0 2 0. 6

39047986200 4623 10.3 93 3.1 0.2 0.8 1.8 1.1 2.8 8.2

39047986300 3602 11 96.8 2.7 0.1 0 0 0.4 1 4

39047986400 4264 5.5 98.3 1 0 0 0.2 0.5 0.4 1.9

Gallia County ;

39053953500 4929 14.3 94.5 3.4* 0.3 0.8 0.2 0.8 0.4 5.7

39053953600 3974 19.7 95.5 2.3 - 0.2 0.6 0.1 1.3 0.6 4.8

39053953700 4067 27.4 95.6 0.7 0.2 1.2 0.2 1.9 0.3 4.6

39053953800 4322 19.4 98.2 0.3 0 0 1.3 0.7 2

39053953900 6790 13.6 94.4 4.1 0 0.4 0 1.2 0 5.6

39053954000 4489 17.2, 92.4 -- 3.4 0.8 1.5 0.5 -1.5 0.9 8

39053954100 2498 20.7 93.8 3.4 0.3 0 0 2.5 0.4 6.2

'F-3
Table F-1 State Population Data, by Census Tract (continued)

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26

Below African Native Asian and Other Two or Hispanic Mnrte

Census Tract Persons Poverty Whites American/ American Pacific Islander Races More Races or Latino Minorities

Level (%) () Black (%) (%) (%) (%) (%) (%) (%)

Highland County

39071954400 3825 11 97.1 2.2 0.4 0 0.3 0 0.3 2.9

39071954500 4129 10.8 96.9 1.2 0 0 0.1 1.8 1.2 3.9

39071954600 4726 6.8 99 0.6 0 0.1 0 0.3 0 1

39071954700 5976 6.8 98.1 - 0 0.3 0.4 0 1.2 0 1.9

39071954800 4011 17.5 95.1 2.1 0.3 1.4 0.6 0.5 0.1 4.9

39071954900 3757 13.8 87.2 9 0.6 1.3 0 1.9 1 12.8

39071955000 4027 19.1 97.9 0.3 1.8 0 0 0 0.9 2.6

39071955100 5783 14 97.6 0.1 0.5 0.7 0 1 0.1 2.5

39071955200 4641 9.6 99.5 0 0.4 0 0 0.1 0.2 0.6

Hocking County

39073964900 4400 7.3 98.7 0.3 0.7 0 0 0.4 0.1 1.4

39073965000 3888 15.7 99.6 0.2 0.2 0 0 0 0.7 1.1

39073965100 4134 10.5 97.9 0.4 0 0 0 1.7 0 2.1

39073965200 4302 15.9 98.7 0.8 0.2 0 0 0.3 0.2 1.5

39073965300 3548 10.9 99.5 0.4 0.2 - 0 0 0 0.1 0.7

39073965400 3991 18.9 96.1 0.7 0 1.6 0 1.5 0.6 4.2

39073965500 3978 16.2 93.5 4.6 0.1 0 0.3 1.5 0.3 6.5

Jackson County

39079957200 5318 16.7 98.1 0.6 0 0.4 0.2 0.7 0.7 2.4

39079957300 3669 19.7 97 0.2 0.3 0.4 0.2 1.8 0.8 3.5

39079957400 5332 15.3 95.3 2.8 0.3 0.3 0.2 1.1 1.2 4.9

39079957500 5765 16 98.5 1.1 0 0.2 0 0.3 2.6 4.1

39079957600 2822 16.6 96.5 0.2 0.2 0.2 0 2.3 0.4 3.5

39079957700 5188 17.2 97.1 0.6 0.2 . 0.6 0 1.5 1.8 4.7

39079957800 4547 14.8 98.3 0.5 0.9 0 0 0.4 0.1 1.7

F-4

I..
I

2

3

4

5

6

7

8

9

10

I11

12

13

14

15

16

17

18

'9

20

21

22

23

24

25

Table F-1 State Population Data, by Census Tract (continued)

Below Whites African -.Native Asian and Other Two or Hispanic Minorities

Census Tract Persons Poverty (%) American/ American Pacific Islander Races More Races or Latino (%)

Level (%) Black (%) (%) (%) (%) (%) (eo)

Lawrence County

"39087050100 2692 15.2 95.9 2.8 0.2 0 0 1.1 0.8 4.9

39087050200 2524 20.8 97 2.5 0 0- 0 0.5 0.3 3.3

39087050300 2349 33 78.1 19.6 0 1.4 0.2 -0.5 0.9 22.3

39087050400 3155 25.1 97.8 1.6 0.3 0 0 0.3 0.4 2.3

-39087050500- 6585 19.1 -97.6 0.1 0.3 1 0.2 0.7 0.9 2.9

39087050600-- - 1677 28.1 94.5 1.4 0.3 0 0.4 3.5 0.4 5.5

*39087050700 3749 26 99 0 0 0.7 0 0.3 0 1

39087050800 3843 22.6 97.4 1.8 0 0.7 0 0.1 0.2 2.8

39087050900 2279 18.4 98.3 0.3 0.4 0 0.4 0.7 1 2

. 39087051001 4475 13.9 95 3.7 0 0 0 1.3 0 5

39087051002 4316 14.5 96.7 1.6 0 0 0 1.7 0 3.3

39087051100 6977 21.2 92.2 5.7 0.6 0 0.5 1.1 0.5 7.8

39087051200 5299 15.7 98.6 0.3 0.3 0 0.1 0.6 1 1.9

39087051300 3705 18.4 98.7 0.3 0 0.1 0 1 0 1.3

39087051400 8694 12 97.5 1.1 0.3 0.6 0.2 0.3 0.4 2.8

Madison County

39097041200 3282 7.6 97.8 0 0.1 0.9 0.2 1 1.4 3.3

Meigs County .

39105964200 4423 17.3 98.6 0.3 0.1 0 0.1 0.8 0.2 1.5

39105964300 - 4342 21.3 - 96.8 0.3 0.3 0 0.5 2 0.7 4

39105964400- 3676 - 28.2. 94.5 2.2 0.6 0.1 0 2.6 0 5.5

Pickaway County

39129020100 2050 22.9-- 92.6 3.1 2.2 0 0 2.1 0.7 - 8.1

39129020200 2698 10.8 98.3 1.3 0.. 0 0 . 0.4 0.6 2.3

F-5
Table F-I State Population Data, by Census Tract (continued)

1

2

3

4

5

6

7

8

9

10

I11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

Below African Native Asian and Other Two or Hispanic Minorities

Census Tract Persons Poverty Whites American/ American Pacific Islander Races More Races or Latino M ot

Level (%) Black (%) (%) (%) (%) (%) (%)

39129020310 5089 6.2 96.5 1.1 0.2 0.8 0.1 1.2 0 3.5

39129020320 3335 6.8 93.8 2.2 1.1 1.7 1.1 0.2 2.4 7.5

39129020400 2543 25.6 - 98 1 0 0 0.2 0.8 0.3 2.2

39129021100 6910 5.5 97.9 0.1 0.3 0.8 0 1 0.4 2.4

39129021200 6424 8.9 97.3 0.3 0.9 0.1 0.1 1.3 0.5 3.1

39129021400 8992 7.7 88.1 9.8 0.3 0.1 0.1 1.5 0.7 12.2

39129021500 2987 9.2 99.2 0 0.1 0 0 0.7 1.3 1.9

39129021600 3528 12.7 98.1 0.4 0.5 0.1 0.1 0.9 0.1 2

39129021700 4506 7.1 99 0.6 0.4 0 0.1 0 1 1.9

Pike County

39131952200 5592 16.2 94.2 1.9 1.4 0.2 0.6 1.8 0.3 5.9

39131952300 5067 18.6 95.9 1.2 0.3 0.5 0 2.1 0.4 4.4

39131952400 3368 10.7 95.5 1.3 1 1.4 0.1 0.7 0 4.5

39131952500 3753 17.7 97.9 0 0.1 0.5 0 1.5 0.6 2.1

39131952600 5573 20.6 96.9 0.2 2 0 0 1 0.3 3.4

39131952700 4342 25.7 98 0 1.1 0.3 0.3 0.3 1.7 3.4

Ross County

39141955500 5388 5.2 98.6 0.1 0.2 0 0.2 0.8 0.7 1.8

39141955601 2047 7.5 98.5 0.8 O 0 0.3 0 1.9 3.4

39141955602 4954 4.8 57.1 39.3 0.2 0 0 4 2.2 44

39141955603 3861 11.8 98.3 0.6 0.1 0.5 0.2 0.3 0 1.7

39141955700 4267 12.5 98.5 0.4 0.4 0.1 0 0.5 0.4 1.9

39141955800 6824 9.8 94.9 3.5 0 0.1 0.5 1 0.7 5.4

39141955900 4257 10.4 87.9 8.7 0 0.8 0.2 2.5 0.1 12.2

39141956000 4549 12 90.1 6.8 1.3 0 0 1.8 0.2 10.1

39141956100 3774 9.4; 84.9 11.8 0.2 0.8 0 2.3 0.3 15.4

F-6
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

Table F-1 State Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic Minorities

Whites Mnrte

Census Tract Persons . Poverty (% Amerlcan/ American Pacific Islander Races More Races or Latino

Level (%) Black (%) (%) (%) (/(%) (off)

39141956200' 2299 11 90.9 2.9 1.3. 2.3 0.3 2.5 0.8 9.7

-39141956300 2942 14.4 93.6 4.2 0 0.7 0 - 1.3 0.6 6.7

39141956400 3665 15.3 89.1 7.5 0.6 0.2 0.4 2.3 0.7 11.2

39141956500, 4045 16.4 91.3 5.9 0.9 0 - 0 2. 1.7 9.5

39141956600 5044 9.5 98.9 0.2 0 0.6 0 0.2 0.6 1.6

39141956700 5003 13.5 97 I 1.1 0.4 0.3 0.3 1 3.7

39141956800 6026 - 15.4 97.6 0.9 0.1 0.1 0 1.3 1.7 4

39141956900 4400 18- 97.7 0.4 0 0.3 0 1.6 0 2.3

Scioto County,

39145992100 4960 17.4 98.3 0 0.2 0.1 0.6 0.7 0.6 1.7

39145992200 5180 12.8 79.9 16 0.4 0.1 0.3 3.4 2 20.8

39145992300 4867 16.1 96.7 0.2 1.5 .0 0.3- 1.3 0-- 3.3

39145992400 5626 21 97.2 0 0.2 0.7 -0.3- 1.6 - 1 3.2

39145992500 3188 17.8 95.4 0.5 0 0.6 0.5 2.9 1.5 5.1

39145992600 4164 16 98.2 0 0.2 0.1 0.1 1.2 1.4 2.3

39145992700 4538 12.5 96.7 0.2 0.2 0.2 0.1 2.5 0.4 3.3

39145992800 4486 18.8 95.7 2.5 1.1 0.3 0 0.4 0.3 4.7

39145992900 6372 . 15.4 . 98.1 0.7 0.4 0 0 0.8 0 1.9

39145993000 3878 20.8 96.9 0.3 0.9 1.3 0 0.6 0 3.1

39145993100 3495. 21.9 98.5 0 0.4 0.3 0.1 0.6 0.1 1.5

39145993200 1861 31.5 97.6 0.3 0 0 0 2.1 0 2.4

39145993300 2698 14.1 94.6 2.4 0.8 1.8 0 0.5 0.9 6.3

39145993400 3801 28.5 93.1 3.9 0.5 0.2 0.2 2.1 0.3 7.1

39145993500 2859 29.3 97.2 0.2 0.8 0.2 0 1.6 1.5 4.4

39145993600 2596 43.4 88.8 7 0 1.2 0 - 2.9 0 11.2

39145993700 2618 24.6 75.4 20.3 0.4 0* 0 4.2 1.4. 25.6

39145993800 4689 8.1 95.6 0.7 '0.2 1.9 0 1.6- 0.2 -' 4.6

F-7
1

2

3

4

5

6

7

8

9

10

Ii1

12

13

14

15

16

17

18

19

20

21

Table F-1 State Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic *1 norties

Census Tract Persons Poverty Whites American/ American Pacific Islander Races More Races or Latino z ori

Level (%) (%) Black (%) (%) (%) (%) (%) (%) (%)

39145993900 3515 22.6 96.4 0 2.3 0.2 0 1.1 0 3.6

39145994000 3804 20.3 98.1 0.6 0.3 0.3 0.1 0.5 0.3 1.9

Vinton County

39163953000 4509 17.8 98.3 0.3 0.5 0 0.1 0.8 0.4 2

39163953100 5284 21.4 97.3 0.1 0.5 0 0.2 1.9 0.8 3.4

39163953200 3013 20.8 98.4 0 0 0 0 1.6 0.5 2

State of Kentucky 4041769 15.8 90 7.3 0.2 0.7 0.5 1.2 1.4 10.7

Threshold for EJ Concerns NA 35.8 NA 27.3 20.2 20.7 20.5 21.2 21.4 30.7

Boyd County

21019030200 1182 25.9 81.2 9.2 0.5 4.9 1.2 3 0.6 19.4

21019030300

21019030400

21019030500

21019030600

21019030700

21019030800

21019030900

21019031000

21019031100

21019031200

21019031300

2542

2072

4489

4169

3578

3969

5772

8122

7764

3374

2719

32.3

27.9

11.1

9.9

8.7

29.4

13.7

12.6

10.9

11.5

19.2

96.6

93.1

97.3

97

95.8

97.6

99

88.7

98

99.1

97.1

3

2.3

1.6

1.6

0.8

0.5

0.2

7

0.5

0.9

1.1

0

0.2

0.1

0.5

0

0.3

0.4

0

0

0.2

0

0.2

0.9

0.2

0.1

0

0

0.3

0.2

0

0.3

0 0.4

1 3.2

0 0.2

0 1.1

1.1 1.6

0.2 1.8

0 0.5

1.1 2.3

0.1 1

0 0

0.1 1.3

0.2 3.6

2.3 7.1

0 2.7

0.2 3

0.4 4.3

1 3

0.3 1.3

4.7 14.1

0.5 2.1

0 0.9

0 2.9

-

22 Carter County

23 21043960100 3370 26 98.5 0.7 0 0 0 0.8 0.7 2.2

24 21043960200 4334 25.5 99.3 0 0.1 0.3 0 0.3 0.2 0.9

25 21043960300 3080 20.8 100 0 0 0 0 0 0.6 0.6

F-8

- - L-
1

2

3

4

5

6

7

8

9

10

I11

12

13

14

15

16

17

18

19

20

21

Table F-1 State Population Data, by Census Tract (continued)

Below Wh African Native Asian and Other Two or Hispanic Census Tract Persons Poverty (%) Amerlcan/ American Pacific Islander Races More Races or Latino (%) Level (%) Black (%) (%) (%) (%) (%) (%) (/) 21043960400 1696 25.6 98.8 0 0.9 0.2 0 0 0 1.2 21043960500 4183 18 99 0.3 0.5 0 0 0.2 0 1 21043960600- 5863 18.6 99.3 0.2 0 0.2 0.3 0 0.2 0.7

21043960700-- 4363 24.5 98.1 0 0 1.2 0 0.7 1.3 2.9

Fleming County, . 21069980100 3949 16.6 94.9 4.5 0 0 0.1 0.5 0.8 6 21069980200 3184 12.9 98.4 1 0.2 0 0 0.4 1.3 2.7

21069980400 - 4085 24.1 99.1 0.9 0 0 0 0 0 0.9

Greenup County,

21089040100 4375 5.5 98.1 0.2 0.2 0.8 0.3 0.3 1.9 3.5

21089040200 7475 12.2 97.8 0.6 0.2 0.1 0.5 0.8 1.9 3.5

21089040300 4531 11.3 97 0.3 0 - 1.5 0.1 1 0.4 3.3 21089040400 5562 14.6 98.5' 0.6 0 0.2 0.1 0.6 0.2 1.6

21089040500 8110 -18.7 96.7. 1.6 0 0.4 0.2 1.1 0.3 3.4

21089040600 3310 18 98.1 0 0.2 0.2 0 1.5 0 1.9

21089040700' 3528: 17.6 99.1 0 0.2 0.3 0 0.3 0 0.9

Lewis County

21135990100 4716 29.1 99.7 0 0.2 0 0 0.1 0.2 0.5

21135990200 3990 33.6 98.9 0.4 0.2 0 0 0.5 0.5 1.6

21135990300 3293 22.5 97 0.8 0.6 0 0.7 0.9 0.7 3.2

21135990400 2093 27.1 100 0 0 0 0 0-- 0 0

F-9
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

Table F-1 State Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic Minorities

Census Tract Persons Poverty (%)ies American/ American Pacific Islander Races More Races or Latino M ot

Level (%) Black (%) (%) (%) (%) (%) (%)

Mason County

21161960100 3093 14.3 97.3 1.6 0 0 0.2 0.9 0.8 3.3

21161960200 3478 24.7 84.5 12.2 0.2 0 0.9 2.3 1.3 15.7

21161960300 4337 16.8 85.7 10.3 0.1 1.1 0.9 1.9 1.5 15.6

21161960400 4140 11.4 94.7 2.4 0.4 0.7 0.5 1.5 1 5.7

Carter County

21205950100 6103 16.5 94.4 2.2 0.5 0.9 1 1 2 6.5

State of West Virginia 1808344 17.9 95 3.1 0.2 0.5 0.2 1 0.7 5.5

Threshold for EJ Concerns NA 37;9 NA 23.1 20.2 20.5 20.2 21 20.7 25.5

Cabell County

54011000600 1607 58.9 89.3 4 1.2 5 0.4 0 0.9 10.7

54011000900 1852 30.7 95.3 3.2 0 0 0.3 1.2 0.3 4.7

54011001000 2426 29.6 97.7 1.1 0 0 0 1.3 0.4 2.7

54011001100 2096 28.1 93.6 2 0 0 0 4.5 2.6 6.4

54011010700 7160 15.5 98.1 0.3 0 0.3 0.1 1.2 0.4 2.2

Mason County

54053954800 6909 16.3 98.5 0.6 0.2 0 0 0.6 0.2 1.7

54053954900 6750 24 98.8 0.6 0 0.4 0 0.1 0.6 1.7

54053955000 5025 17.6 96.5 1.8 0 1.5 0 0.2 0.5 4

54053955100 7273 21.2 99 0 0.2 0.1 0 0.7 0.2 1.3

Wayne County

54099005100 2181 13.7 98.4 0 0.6 0.7 0 0.3 0 1.6

54099005200 2086 14.1 98.8 0 0 0.9 0.3 0 0.3 1.2

54099020100 2545 13.1 99.3 0.4 0.4 0 0 0 0 0.7

F-10

--L - - .
Table F-1 State Population Data, by Census Tract (continued)

Below Whit African Native Asian and Other Two or Hispanic Minorities

Census Tract Persons Poverty ( American/ American Pacific Islander Races More Races or Latino M(%

Level(%) Black (%) (%) (%) (%) (%) (%)

54099020300 5307 16.4 99 0.4 0 0.2 0.1 0.3 0.4 1.3

54099020400 6219 11.8 99.3 0 0 0 0.2 0.5 1.1 1.6

Notes:

' NA = Not available. b Census tracts exceeding minority/low-income criteria are shown in bold.

I

2

3

4

5

6

F-lI
I Table F-2 County Population Data, by Census Tract"F

*2

Below African Native Asian and Other Two or Hispanic

3 Census Tract Persons PLverty Whites American American Pacific Islander Races More Races or Latino Mi ii

(%) (%) (%) (%) (%) (%) (%)

4 Ohio

5 Adams County 39001 6 17.4 0 0.7 0 0.1 1.2 0.4 2.4

6 Threshold for EJ Concerns NA 26 NA 20 20.7 20 20.1 21.2 20.4 22.4

7 39001990100 4868 22.4 96.8 0 1.3 0 0.1 1.7 0.8 3.9

8 39001990200 4635 13.1 98.4 0 0.2 0.2 0.1 1.1 0.6 1.9

9 39001990300 6212 12.6 98.8 0.1 0.1 0 0.2 0.8 0.3 1.5

10 39001990400 4630 17.6 97.8 0 1.3 0 0 1 0 2.2

11 39001990500 3454 21.7 96.3 0 1.6 0 0 2.1 0 3.7

12 39001990600 3531 19.6 99 0 0.1 0.1 0 0.8 0.5 1.5

13 Ohio

14 Athens County 39009 5 27.4 2.4 0.5 1.8 0.3 1.6 1 7.3

15 Threshold for EJ Concerns NA 25 NA 22.4 20.5 21.8 20.3 21.6 21 27.3

16 39009972800 4272 27.7 97.4 0.4 0.8 0.4 0.3 0.6 1.8 4

17 39009972900 5362 29.8 90.9 3.1 0.4 3.1 0.3 2.1 0.5 9.5

18 39009973200 4320 17.4 87.8 3.7 0.5 4.4 0.5 2.5 2.2 13

19 39009973700 3967 13.9 95.7 1.2 0.6 0.8 0.2 1.6 1.4 5.7

20 39009973800 4642 11.3 98.4 0.2 0 0.7 0.1 0.5 0.5 2

F-12

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1

2

3

4

5

6

7

8

9

10

I11

12

13

14

15

16

17

18

Table F-2 County Population Data, by Census Tract (continued)

Below 1.. African Native IAsian and Other Two or Hispanic

Census Tract Persons Poverty Whites American/ American PacificIslander Races- MoreRaces orLatino Minorities

Level (o) Black (%) (%) (%) (%) - (%)

(%) M%

Ohio

Brown County 39015 8 11.6 0.8 0.2 0.2 0.1 0.7 0.4 2.3

Threshold for EJ Concerns NA 28 NA 20.8 20.2 20.2 20.1 20.7 20.4 22.3

39015951200 9522 6.2 98.3 0.2 0.1 0.3 0 1.1 0 1.7

39015951300 6435 12.3 98.7 0.3 0.2 0.3 _0 0.5 0.3 1.6

39015951400 4408 14.4 98.6 0.4 0 0.1 0 0.8 0.5 1.9

39015951500 4896 12.3 98.5 0 0.9 0.4 0 0.2 0 1.5

39015951600 3869 16.5 97.4 1.1 0.3 0.2 0.2 0.8 1.4 3.5

39015951700 2764 15.3 92.8 4.8 0.1 0.1 0.1 2.1 0.6 7.6

39015951800 4650 12.2 97.4 2 0.2 0.1 0 0.3 0.4 2.9

39015951900 5741 12.1 99 0 0.2 0 0.3 0.5 0.6 1.2

Ohio :

Clinton County 39027 4 8.6 2.1 0.3 0.2 0.4 1.1 0.9 4.7

Threshold for EJ Concerns NA 24 NA 22.1 20.3 20.2 20.4 21.1 20.9 24.7

39027994300 3871 10.3 97.6 0.9 0 0.1 0.4 1 0.1 2.4

39027994400 4808 4.4 98.1 0 0.7 0 0 1.2 0.2

39027995000 3967 7.9 99.3 0.1 0.2 0.1 0 0.4 0.1 0.7

39027995100 4105 8 97 0.1 1.2 0.2 0.9 0.6 1.2 3.2

F-13
1

2

3

4

5

6

7

8

9

10

21

12

13

14

15

16

17

18

19

20

21

22

23

Table F-2 County Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic

Census Tract Persons Povel Whies Blan/ American Pacific Islander Races More Races or Latino Mi t Level (%) Black (%M% % % (%

Ohio

Fairfield County 39045 3 5.9 2.6 0.3 0.7 0.3 1 1 5.5

Threshold for EJ Concerns NA 23 NA 22.6 20.3 20.7 20.3 21 21 25.5

39045031200 4901 6.1 99.3 0 0 0.1 0.3 0.3 1.3 1.8

39045032500 5996 6.1 83.8 14 0.4 0.1 0.3 1.1 0.7 16.2

39045032600 5840 5 99.1 0.1 0.2 0 0.1 0.5 0.4 1.2

Ohio

Fayette County 39047 7 10.1 2.1 0.2 0.5 0.4 1.1 1 4.8

Threshold for EJ Concerns NA 27 NA 22.1 20.2 20.5 20.4 21.1 21 24.8

39047985800 3785 9.1 96.9 1.3 0.2 0 0.8 0.8 0.9 3.2

39047985900 3847 8.7 95.3 2.2 0.2 0.1 0.1 2 0.9 5.2

39047986000 4180 9.4 96.1 0.6 0.4 2.4 0 0.6 0.8 4.7

39047986100 4132 17.1 94 4 0 0 0 2 0 6

39047986200 4623 10.3 93 3.1 0.2 0.8 1.8 1.1 2.8 8.2

39047986300 3602 11 96.8 2.7 0.1 0 0 0.4 1 4

39047986400 4264 5.5 98.3 1 0 0. 0.2 0.5 0.4 1.9

Ohio

Gallia County 39053 7 18.1 2.6 0.2 0.7 0.2 1.4 0.4 5.3

Threshold for EJ Concerns NA 27 NA 22.6 20.2 20.7 20.2 21.4 20.4 25.3

39053953500 4929 14.3 94.5 3.4 0.3 0.8 0.2 0.8 0.4 5.7

39053953600 3974 19.7 95.5 2.3 0.2 0.6 0.1 1.3 0.6 4.8

39053953700 4067 27.4 95.6 0.7 0.2 1.2 0.2 1.9 0.3 4.6

39053953800 4322 19.4 98.2 0.3 0 0 0.2 1.3 0.7 2

F-14
1

2

3

4

5

6

.7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

Table F-2 County Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic

Census Tract Persons Poverty M Anlerlcn/ American Pacific Islander Races More Races or Latino (%) L (%) Black (%) (%) (%) () (%) (

39053953900 6790 13.6 94.4 4.1 0 0.4 0 1.2 0 5.6

39053954000 4489 17.2 92.4 3.4 0.8 1.5 0.5 1.5 0.9 8

39053954100 2498 20.7 93.8 3.4 0.3 0 0 2.5 0.4 6.2

Ohio

Highland County 39071 9 11.8 1.5 0.5 0.4 0.1 0.8 0.4 3.4

Threshold for EJ Concerns NA 29 NA 21.5 20.5 20.4 20.1 20.8 20.4 23.4 _.

.39071954400. 3825 - 11 97.1 2.2 0.4 0 0.3 0 0.3 2.9

39071954500 4129 10.8 96.9 1.2 0 0 0.1 1.8 1.2 3.9

39071954600 4726 6.8 99 0.6 0 0.1 0 0.3 0 1

39071954700 5976 6.8 98.1 0 0.3 0.4 0 1.2 0 1.9

39071954800 4011 17.5 95.1 2.1 0.3 1.4 0.6 - 0.5 0.1 4.9

39071954900 3757 13.8 87.2 9 0.6 1.3 0 1.9 1 12.8

39071955000 4027 19.1 97.9 0.3 1.8 0 0 0 0.9. 2.6

39071955100 5783 14 97.6 0.1 0.5 - 0.7 0 1 0.1 2.5

39071955200 4641 9.6 99.5 0 0.4 0 0 0.1 0.2 0.6

Ohio

Hocking County.- 39073 7 13.5 1 0.2 0.2 0 0.8 0.3 2.5

Threshold for EJ Concerns NA 27 NA 21 20.2 20.2 20 20.8 20.3 22.5

39073964900 4400 7.3 98.7 0.3 0.7 0 0 0.4 0.1 1.4

39073965000 3888 15.7 99.6 0.2 0.2 0 0 0 0.7 1.1

39073965100 4134 10.5 -97.9 0.4 0 0 0 1.7 0 2.1

39073965200 4302 15.9 98.7 0.8 0.2 0 0 0.3 0.2 1.5

39073965300 3548 10.9 99.5 0.4 0.2 0 0 0 0.1 0.7

39073965400 3991 18.9 96.1 0.7 0 1.6 0 1.5 0.6 4.2

F-15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

Table F-2 County Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic

Census Tract Persons Poverty Whites American/ American Pacific Islander Races More Races or Latino Min(or)tes

Level (% Black (%) (%) (% (% (%)

(%) (%

39073965500 3978 16.2 93.5 4.6 0.1 0 0.3 1.5 0.3 6.5

Ohio

Jackson County 39079 7 16.5 0.9 0.3 0.3 0.1 1.1 1.2 3.6

Threshold for EJ Concerns NA 27 NA 20.9 20.3 20.3 20.1 21.1 21.2 23.6

39079957200 5318 16.7 98.1 0.6 0 0.4 0.2 0.7 0.7 2.4

39079957300 3669 19.7 97 0.2 0.3 0.4 0.2 1.8 0.8 3.5

39079957400 5332 15.3 95.3 2.8 0.3 0.3 0.2 1.1 1.2 4.9

39079957500 5765 16 98.5 1.1 0 0.2 0 0.3 2.6 4.1

39079957600 2822 16.6 96.5 0.2 0.2 0.2 0 2.3 0.4 3.5

39079957700 5188 17.2 97.1 0.6 0.2 0.6 0 1.5 1.8 4.7

39079957800 4547 14.8 98.3 0.5 0.9 0 0 0.4 0.1 1.7

Ohio

Lawrence County 39087 15 18.9 2.4 0.2 0.3 0.1 0.8 0.5 4.2

Threshold for EJ Concerns NA 35 NA 22.4 20.2 20.3 20.1 20.8 20.5 24.2

39087050100 2692 15.2 95.9 2.8 0.2 0 0 1.1 0.8 4.9

39087050200 2524 20.8 97 2.5 0 0 0 0.5 0.3 3.3

39087050300 2349 33 78.1 19.6 0 1.4 0.2 0.5 0.9 22.3

39087050400 3155 25.1 97.8 1.6 0.3 0 0 0.3 0.4 2.3

39087050500 6585 19.1 97.6 0.1 0.3 1 0.2 0.7 0.9 2.9

39087050600 1677 28.1 94.5 1.4 0.3 0 0.4 3.5 0.4 5.5

39087050700 3749 26 99 0 0 0.7 0 0.3 0 1

39087050800 3843 22.6 97.4 1.8 0 0.7 0 0.1 0.2 2.8

39087050900 2279 18.4 98.3 0.3 0.4 0 0.4 0.7 1 2

39087051001 4475 13.9 95 3.7 0 0 0 1.3 0 5

F-16

L
Table F-2 County Population Data, by Census Tract (continued)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

Below African Native Asian and Other Two or Hispanic

Census Tract Persons PLeverty Whe Aielcka American Pacific Isiander Races More Races or Latino (@)

Le % e l c % (%) % %)M ( %/)

(% (%) -

39087051002 4316 14.5 96.7 1.6 0 0 0 _1.7 0 3.3

39087051100 6977 21.2 92.2 5.7 0.6 0 . 0.5 1.1 0.5 7.8

39087051200 5299 15.7 98.6 0.3 0.3 -0 0.1 0.6 1 1.9

39087051300, 3705 18.4 98.7 0.3 0 0.1 0 1 . 0 1.3

39087051400 8694 12 97.5 1.1 0.3 0.6 0.2 0.3 0.4 2.8

Ohio

Madison County 39097 1 7.8 6 0.2 0.5 0.2 1.5 0.7 8.7

Threshold for EJ Concerns NA 21 NA 26 20.2 20.5 20.2 21.5 20.7 28.7

39097041200 3282 7.6 97.8 0 0.1 0.9 0.2 1 1.4 3.3

Ohio ; ;

Meigs County 39105 3 19.8 0.6 0.3 0.2 0.3 1.3 0.6 3

Threshold for EJ Concerns NA 23- NA 20.6 20.3 20.2 20.3 21.3 20.6 23

39105964200 4423 17.3 98.6 0.3 0.1 0 0.1 0.8 0.2 1.5

39105964300 4342 21.3 96.8 0.3 0.3 0 0.5 2 0.7 4

39105964400 3676 28.2 94.5 2.2 0.6 0.1 0 2.6 0 5.5

Ohio

Pickaway County: 39129 11 9.5 5.7 . 0.5 0.3 0.2 1.1 0.8 8.3

Threshold for EJ Concerns NA 31 NA 25.7 20.5 20.3 20.2 21.1 20.8 28.3

39129020100 2050 22.9 92.6 3.1 2.2 0 0 2.1 0.7 8.1

39129020200 2698 10.8 98.3 1.3 0 0 0 0.4 0.6 2.3

39129020310 5089 6.2 96.5 1.1, 0.2 0.8 0.1 1.2 0 3.5

39129020320 3335 6.8, 93.8 2.2 1.1 1.7 1.1 0.2 2.4 7.5

39129020400 2543 25.6 98' .I1 0 0 0.2 0.8 0.3 2.2

F-17
1

2

3

4

5

6

7

8

9

10

21

12

13

14

15

16

17

18

19

20

21

22

23

24

Table F-2 County Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic Inorti

Census Tract Persons Poverty Whites Amnerican/ American Pacific Islander Races More Races or Latino (ori

Level ( ) Black (%M% (% (% (%)

39129021100 6910 5.5 97.9 0.1 0.3 0.8 0 1 0.4 2.4

39129021200 6424 8.9 97.3 0.3 0.9 0.1 0.1 1.3 0.5 3.1

39129021400 8992 7.7 88.1 9.8 0.3 0.1 0.1 1.5 0.7 12.2

39129021500 2987 9.2 99.2 0 0.1 0 0 0.7 1.3 1.9

39129021600 3528 12.7 98.1 0.4 0.5 0.1 0.1 0.9 0.1 2

39129021700 4506 7.1 99 0.6 0.4 0 0.1 0 1 1.9

Ohio

Pike County 39131 6 18.6 0.8 1 0.4 0.2 1.3 0.5 4

Threshold for EJ Concerns NA 26 NA 20.8 21 20.4 20.2 21.3 20.5 24

39131952200 5592 16.2 94.2 1.9 1.4 0.2 0.6 1.8 0.3 5.9

39131952300 5067 18.6 95.9 1.2 0.3 0.5 0 2.1 0.4 4.4

39131952400 3368 10.7 95.5 1.3 1 1.4 0.1 0.7 0 4.5

39131952500 3753 17.7 97.9 0 0.1 0.5 0 1.5 0.6 2.1

39131952600 5573 20.6 96.9 0.2 2 0 0 1 0.3 3.4

39131952700 4342 25.7 98 0 1.1 0.3 0.3 0.3 1.7 3.4

Ohio

Ross County 39141 17 12 5.7 0.4 0.3 0.1 1.4 0.8 8.5

Threshold for EJ Concerns NA 37 NA 25.7 20.4 20.3 20.1 21.4 20.8 28.5

39141955500 5388 5.2 98.6 0.1 0.2 0 0.2 0.8 0.7 1.8

39141955601 2047 7.5 98.5 0.8 0.4 0 0.3 0 1.9 3.4

39141955602 4954 4.8 57.1 39.3 0.2 0 0 4 2.2 44

39141955603 3861 11.8 98.3 0.6 0.1 0.5 0.2 0.3 0 1.7

39141955700 4267 12.5 98.5 0.4 0.4 0.1 0 0.5 0.4 1.9

39141955800 6824 9.8 94.9 3.5 0 0.1 0.5 1 0.7 5.4

F-18

-- L.
1

2

3

4

5

6

7

8

9

10

1

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Table F-2 County Population Data, by Census Tract (continued)

BowArcn Native Asian and Other Two or Hispanic Mnrte

Census Tract Persons PLvery hitecs Amerikan/ American Pacific Islander Races More Races or Latino (%)

Level (% Bac

39141955900 4257 10.4 87.9 8.7 0 0.8 0.2 2.5 0.1 -12.2

39141956000 4549 12 90.1 6.8 1.3 0 0 1.8 0.2- 10.1

39141956100 3774 9.4 84.9 11.8 - 0.2 0.8 -0 2.3 0.3 15.4--

39141956200 2299 11 90.9 2.9 1.3- 2.3- 0.3 - 2.5 0.8 9.7

39141956300 2942 14.4 93.6 4.2 0 0.7 0 1.3 0.6 6.7

39141956400 3665 15.3 89.1 7.5 0.6 0.2 0.4 2.3 0.7 11.2

'39141956500 4045 16.4 91.3 5.9 0.9 0 0 2 1.7 9.5

39141956600 5044 9.5 98.9 0.2 0 0.6 0 0.2 0.6 1.6

39141956700 5003 13.5 97 1 1.1 0.4 0.3 0.3 1 3.7

39141956800 6026 15.4 97.6 0.9 0.1 0.1 0 1.3 1.7 4

.39141956900.. 4400 18 97.7 0.4 0 0.3 0- 1.6 0 2.3

Ohio'

Scioto County 39145 20 19.3 2.6 0.5 0.5 0.2 1.5 0.6 5.5

Threshold for EJ Concerns NA 40 NA 22.6 20.5 20.5 20.2 21.5 20.6 25.5

39145992100 4960 17.4 98.3 0 0.2 0.1 0.6 0.7 0.6 1.7

39145992200 5180 12.8 79.9 16 0.4 - 0.1 0.3 3.4 2- 20.8 -

39145992300 4867 16.1 96.7 0.2- 1.5 0 0.3 1.3 0 3.3

39145992400 5626 21 97.2 0 0.2 0.7 0.3 1.6- I 3.2

39145992500 3188 17.8 95.4 0.5 0 0.6 0.5 2.9 1.5 5.1-

39145992600 4164 16 98.2 0 0.2 0.1 0.1 1.2 1.4 2.3

39145992700 4538 12.5 96.7 0.2 0.2 0.2 0.1- 2.5 0.4. - 3.3

39145992800 4486 18.8 95.7 2.5 1.1 0.3 0 0.4 0.3 4.7

39145992900 6372 15.4 98.1 0.7 0.4 0 0 0.8 0 1.9

39145993000 3878 20.8 96.9 0.3 0.9 1.3 0 0.6 0 3.1

39145993100 3495 21.9 98.5 0 0.4 0.3 0.1 0.6 0.1 1.5.

F-I9
2

3

4

5

6

7

8

9

10

I1I

Table F-2 County Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic

Census Tract Peovery W s A can/ American Paciflc Islander Races More Races or Latino (m i

CessTat Pros Level %) Black (%M% % (% (%)

(%) (%

39145993200 1861 31.5 97.6 0.3 0 0 0 2.1 0 2.4

39145993300 2698 14.1 94.6 2.4 0.8 1.8 0 0.5 0.9 6.3

39145993400 3801 28.5 93.1 3.9 0.5 0.2 0.2 2.1 0.3 7.1

39145993500 2859 29.3 97.2 0.2 0.8 0.2 0 1.6 1.5 4.4

39145993600 2596 43.4 88.8 7 0 1.2 0 2.9 0 11.2

39145993700 2618 24.6 75.4 20.3 0.4 0 0 4.2 1.4 25.6

39145993800 4689 8.1 95.6 0.7 0.2 1.9 0 1.6 0.2 4.6

39145993900 3515 22.6 96.4 0 2.3 0.2 0 1.1 0 3.6

39145994000 3804 20.3 98.1 0.6 0.3 0.3 0.1 0.5 0.3 1.9

Ohio

Vinton County 39163 3 20 0.1 0.4 0 0.1 1.4 0.6 2.5

Threshold for EJ Concerns NA 23 NA 20.1 20.4 20 20.1 21.4 20.6 22.5

39163953000 4509 17.8 98.3 0.3 0.5 0 0.1 0.8 0.4 2

39163953100 5284 21.4 97.3 0.1 0.5 0 0.2 1.9 0.8 3.4

39163953200 3013 20.8 98.4 0 0 0 0 1.6 0.5 2

Kentucky

Boyd County 21019 12 15.5 2.2 0.2 0.3 0.4 1.2 1.1 5

Threshold for EJ Concerns NA 32 NA 22.2 20.2 20.3 20.4 21.2 21.1 25

21019030200 1182 25.9 81.2 9.2 0.5 4.9 1.2 3 0.6 19.4

21019030300 2542 32.3 96.6 3 0 0 0 0.4 0.2 3.6

21019030400 2072 27.9 93.1 2.3 0.2 0.2 1 3.2 2.3 7.1

21019030500 4489 11.1 97.3 1.6 0 0.9 0 0.2 0 2.7

21019030600 4169 9.9 97 1.6 0.1 0.2 0 1.1 0.2 3

21019030700 3578 8.7 95.8 0.8 0.5 0.1 1.1 1.6 0.4 4.3.

12

13

14

15

16

17

18

19

20

21

22

23

24

F-20
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

Table F-2 County Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic

Census Tract Persons Poverty Whites Amerlcan/ American PaciPiccslfc ander Races More Races or Latino M o

Level (% Black NO ( ) % (% (%)

21019030800 3969 29.4 97.6 0.5 0 0 0.2 1.8 1 3

21019030900 5772 13.7 99 0.2 0.3 0 0 0.5 0.3 1.3

21019031000 8122 12.6 88.7 7 0.4 0.3 1.1 2.3 4.7 14.1

21019031100 7764 10.9 98 0.5 0 0.2 0.1 1 0.5 2.1

21019031200 3374 11.5 99.1 0.9 0 0 0 0 0 0.9

21019031300, 2719 19.2 97.1 1.1 0.2 0.3 0.1 1.3 0 2.9

Kentucky, .

Carter County' 21043 7 22.3 0.2 0.2 0.3 0.1 0.3 0.4 1.3

Threshold for EJ Concerns' NA 27 NA 20.2 20.2 20.3 20.1 20.3 20.4 21.3

:21043960100 3370 26 98.5 0.7 0 0 0 0.8 0.7 2.2

21043960200 4334 25.5 99.3 0 0.1 0.3 0 0.3 0.2 0.9

21043960300 3080- 20.8 100 0 0 0 0 0 0.6 0.6

21043960400 1696 -25.6- 98.8 0 0.9 - 0.2 0 0 0 1.2

21043960500 ' 4183 18 99 0.3 0.5 .. 0 0 0.2 0 1

21043960600 ' 5863 18.6 99.3 0.2 0 - 0.2 0.3 0 0.2 0.7

21043960700 4363 24.5 98.1 0 0 1.2 0 0.7 1.3 2.9

Kentucky

Fleming County 21069 3 18.6 1.8 0.1 0 0 0.4 0.8 3

Threshold for EJ Concerns NA 23 NA 21.8 20.1 20 20 20.4 20.8 23

21069980100 3949 16.6 94.9 4.5 0 0 0.1 0.5 0.8 6

* 21069980200 3184 12.9 98.4 1 0.2 0 0 0.4 1.3 2.7

21069980400 4085 24.1 99.1 0.9 0 0 0 0 0 0.9

F-21
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

Table F-2 County Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic Mnrte

Census Tract Persons Poverty Whites American/ American Pacific Islander Races More Races or Latino Mni

Level ( ) Black (%M% % % (%)

Kentucky

Greenup County 21089 7 14.1 0.6 0.1 0.4 0.2 0.8 0.8 2.8

Threshold for EJ Concerns NA 27 NA 20.6 20.1 20.4 20.2 20.8 20.8 22.8

21089040100 4375 5.5 98.1 0.2 0.2 0.8 0.3 0.3 1.9 3.5

21089040200 7475 12.2 97.8 0.6 0.2 0.1 0.5 0.8 1.9 3.5

21089040300 4531 11.3 97 0.3 0 1.5 0.1 1 0.4 3.3

21089040400 5562 14.6 98.5 0.6 0 0.2 0.1 0.6 0.2 1.6

21089040500 8110 18.7 96.7 1.6 0 0.4 0.2 1.1 0.3 3.4

21089040600 3310 18 98.1 0 0.2 0.2 0 1.5 0 1.9

21089040700 3528 17.6 99.1 0 0.2 0.3 0 0.3 0 0.9

Kentucky

Lewis County 21135 4 28.5 0.3 0.3 0 0.2 0.4 0.4 1.4

Threshold for EJ Concerns NA 24 NA 20.3 20.3 20 20.2 20.4 20.4 21.4

21135990100 4716 29.1 99.7 0 0.2 0 0 0.1 0.2 0.5

* 21135990200 3990 33.6 98.9 0.4 0.2 0 0 0.5 0.5 1.6

21135990300 3293 22.5 97 0.8 0.6 0 0.7 0.9 0.7 3.2

21135990400 2093 27.1 100 0 0 0 0 0 0 0

F-22

L
Table F-2 County Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic Mnrte

Census Tract Persons Poverty Whites American/ American Paciric Islander Races More Races or Latino M ot Level (% Black (% (% (% (% (%

(% (%

I Kentucky

2 Mason County 21161 4 16.8 6.4 0.1 0.5 0.9 1.5 1.4 9.9

3 Threshold for EJ Concerns NA 24. NA 26.4 20.1 20.5 20.9 21.5 21.4 29.9

4 21161960100 3093 14.3 97.3 1.6 0 0 0.2 0.9 0.8 3.3

5 21161960200 3478 24.7 84.5 12.2 0.2 0 0.9 2.3 1.3 15.7

6 21161960300 4337 16.8 85.7 10.3 0.1 1.1 0.9 1.9 1.5 15.6 _.

7 21161960400 4140 11.4 94.7 2.4 0.4 0.7 0.5 1.5 1 5.7

8 Kentucky

9 Carter County :21043 .7 22.3 0.2 0.2 0.3 0.1 0.3 0.4 1.3

10 Threshold for EJ Concerns NA 27 NA 20.2 20.2 20.3 20.1 20.3 20.4 21.3

I 21205950100 6103 16.5 94.4 2.2 0.5 0.9 ' 1 2 6.5

12 West Virginia

13 CabellCounty . 54011 ,5 19.2 4 0.2 0.9 0.3 1.3 0.6 7

14 Threshold for EJ Concerns NA 25 NA 24 20.2 20.9 20.3 21.3 20.6 27

15 54011000600 1607 58.9 89.3 4 1.2 - 5 0.4 0 0.9 10.7

16 54011000900 1852' 30.7 95.3 3.2 0 0 0.3 1.2 0.3 4.7

17 54011001000 2426 29.6 97.7 1.1 0 0 0 1.3 0.4 2.7

18 54011001100 2096 28.1 93.6 2 0 0 0 4.5 2.6 6.4

19 54011010700 7160 15.5 98.1 0.3 0 0.3 0.1 1.2 0.4 2.2

F-23
1

2

3

4

5

6

7

8

9

10

I11

12

13

14

15

16

17

18

19

Table F-2 County Population Data, by Census Tract (continued)

Below African Native Asian and Other Two or Hispanic Mnrte

Census Tract Persons Poverty Whites American/ American Pacific Islander Races More Races or Latino Minorities

Level (%) Black (%) ( ) (%) (%) (%)

( % ) ( % )

West Virginia

Mason County 54053 4 19.9 0.7 0.1 0.4 0 0.4 0.4 2

Threshold for EJ Concerns NA 24 NA 20.7 20.1 20.4 20 20.4 20.4 22

54053954800 6909 16.3 98.5 0.6 0.2 0 0 0.6 0.2 1.7

54053954900 6750 24 98.8 0.6 0 0.4 0 0.1 0.6 1.7

54053955000 5025 17.6 96.5 1.8 0 1.5 0 0.2 0.5 4

54053955100 7273 21.2 99 0 0.2 0.1 0 0.7 0.2 1.3

West Virginia

Wayne County 54099 5 19.6 0.1 0.2 0.2 0.1 0.5 0.3 1.4

Threshold for EJ Concerns NA 25 NA 20.1 20.2 20.2 20.1 20.5 20.3 21.4

54099005100 2181 13.7 98.4 0 0.6 0.7 0 0.3 0 1.6

54099005200 2086 14.1 98.8 0 0 0.9 0.3 0 0.3 1.2

54099020100 2545 13.1 99.3 0.4 0.4 0 0 0 0 0.7

54099020300 5307 16.4 99 0.4 0 0.2 0.1 0.3 0.4 1.3

54099020400 6219 11.8 99.3 0 0 0 0.2 0.5 1.1 1.6

Notes:

' NA = Not available. b Census tracts exceeding minority/low-income criteria are shown in bold.

F-24
l

2

3

4

5

6

7

8

9

20

I11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Table F-3 Number of Census Tracts Exceeding State Environmental Justice Threshold I

Below African Native Asian and Other Twoor Hispanic Minorities Total Minority

County Poverty American/ atv Pacific Ote w r or Latino (Racial Minorities TtracMnoit Pvelt Black American Iander Races More Races (All Races) plus White Hispanics) cts

State of Ohio(%) 10.6 11.5 0.2 1.2 0.8 1.5 1.9 16 --

Threshold for EJ 30.6 31.5 20.2 21.2 20.8 21.5 21.9 36

Concerns (%)

Adams 0 0 0 0 0 0 0 0 0

Athens 0 0 0 0 0 -0 0 0 0

Brown 0 0 0 0 0 0 0 0 0

Clinton 0 0 0 0 0- 0 0 0 0

Fairfield 0 0 0 0 0 0 0 0 -0

Fayette 0 0 0 0 0 0 0 0 0

Gallia 0 0 0 0 0 0 0 0 0

Highland 0 0 0 0 0 0 0 0 0

Hocking 0- -- 0-- 0 0 0 0 0 0 0

Jackson 0 0 0 0 0 0 0 0 0

Lawrence I 0 0 0 0 0 0 0 NA

Madison 0 0 0 0 0 - -0 0 0 0

Meigs 0 0 0 0 0 0 0 0 0

Pickaway 0 0 0 0 0 0 0 0 0

Pike 0 0 0 0 0 0 0 0 0

Ross 0 1 0 0 0 0 0 1 NA

Scioto 2 0 0 0 0 0 0 0 NA

Vinton 0 0 0 0 0 0 0 0 0

Total Ohio Counties 3 1 0 0 0 0 0 1 NA

F-25
1

2

3

4

5

6

7

8

9

10

I11

12

13

14

15

16

17

18

19

20

21

Table F-3 Number of Census Tracts Exceeding State Environmental Justice Threshold (continued)

Below African Native Asian and Other Two or Hispanic Minorities

County Poverty Amerlcan/ American Pacific Races More Races or Latino (Racial Minorities Total Minority

Level Black Islander (All Races) plus White Hispanics)

State of Kentucky (%) 15.8 7.3 0.2 0.7 0.5 1.2 1.4 10.7 --

Threshold for EJ 35.8 27.3 20.2 20.7 20.5 21.2 21.4 30.7 --

Concerns (%)

Boyd 0 0 0 0 0 0 0 0 0

Carter 0 0 0 0 0 0 0 0 0

Fleming 0 0 0 0 0 0 0 0 0

Grccnup 0 0 0 0 0 0 0 0 0

Lewis 0 0 0 0 0 0 0 0 0

Mason 0 0 0 0 0 0 0 0 0

Carter 0 0 0 0 0 0 0 0 0

Total Kentucky 0 0 0 0 0 0 0 0 0

Counties

State of 17.9 3.1 0.2 0.5 0.2 1 0.7 5.5

West Virginia (%)

Threshold for E 37.9 23.1 20.2 20.5 20.2 21 20.7 25.5 Concerns (%) '

Cabell 1 0 0 0 0 0 0 0 NA

Mason 0 0 0 0 0 0 0 0 0

Wayne 0 0 0 0 0 0 0 0 0

Total West Virginia 1 0 0 0 0 0 0 0 NA

Counties

F-26
Table F-3 Number of Census Tracts Exceeding State Environmental Justice Threshold (continued)

Below African Native Asian and Other Two or Hispanic Minorities Total Minority

County Poverty American NAteiven Pacific Rae oeRcsor Latino (Racial Minorities Tat LveAmerican Races More Races (All Races) plus White Hispanics) Tracts

Grand Total 1 NA

(3 States)

Notes:

NA = Not available.

1

2

3

4

5

F-27
1

2

3

4

5

6

7

8

9

10

21

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

Table F-4 Number of Census Tracts Exceeding County Environmental Justice Threshold a

Below African Native Asian and Other Two or Hispanic Minorities

County Poverty American/ American Pacific Races More Races or Latino (Racial Minorities Block Groups Level Black Islander (All Races) plus White Hispanics)

State of Ohio(%) 10.6 11.5 0.2 1.2 0.8 1.5 1.9 16

Threshold forEJ 30.6 31.5 20.2 21.2 20.8 21.5 21.9 36 Concerns (%)

Adams 0 0 0 0 0 0 0 0 0

Athens 2 0 0 0 0 0 0 0 NA

Brown 0 0 0 0 0 0 0 0 0

Clinton 0 0 0 0 0 0 0 0 0

Fairfield 0 0 0 0 0 0 0 0 0

Fayette 0 0 0 0 0 0 0 0 0

Gallia 1 0 0 0 0 0 0 0 NA

Highland 0 0 0 0 0 0 0 0 0

Hocking 0 0 0 0 0 0 0 0 0

Jackson 0 0 0 0 0 0 0 0 0

Lawrence 0 0 0 0 0 0 0 0 0

Madison 0 0 0 0 0 0 0 0 0

Meigs 1 0 0 0 0 0 0 0 NA

Pickaway 0 0 0 0 0 0 0 0 0

Pike 0 0 0 0 0 0 0 0 0

Ross 0 1 0 0 0 0 0 1 NA

Scioto 1 0 0 0 0 0 0 1 NA

Vinton 0 0 0 0 0 0 0 0 0

Total Ohio Counties 5 1 0 0 0 0 0 2 NA

F-28
- S W *

Table F4 Number of Census Tracts Exceeding County Environmental Justice Threshold (continued)

1

2

3

4

5

6

7

8

9

10

I11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

Blw Arcn Native Asian and Other Two or Hsai Mnotes Total Minority

County Poverty American/ American Pacific Races More Races orLatino (RacialMinorities Block Groups Level Black Islander (All Races) plus White Hispanics)

State of

Kentucky 15.8 7.3 0.2 0.7 0.5 1.2 1.4 10.7 -- Kentucky (%)

Threshold for EJ 35.8 27.3 20.2 20.7 20.5 21.2 21.4 30.7

Concerns (%)

Boyd 1 0 0 0 0 0 0 0 NA

Carter 0 0 0 0 0 0 0 0 0

Fleming 1 0 0 0 0 0 0 0 NA

Greenup 0 0 0 0 0 0 0 0 0

Lewis 3 0 0 0 0 0 0 0 NA

Mason 1 0 0 0 0 0 0 0 NA

Total Kentucky 6 0 0 0 0 0 0 0 NA

Counties

State of WStte V i 17.9 3.1 0.2 0.5 0.2 1 0.7 5.5 --

West Virginia (%)

Threshold for EJ 37.9 23.1 20.2 20.5 20.2 21 20.7 25.5

Concerns (%)

Cabell 4 0 0 0 0 0 0 0 NA

Mason 1 0 0 0 0 0 0 0 0

Wayne 0 0 0 0 0 0 0 0 0

Total West Virginia 5 0 0 0 0 0 0 0 NA

Counties

Grand Total

16 1 0 0 0 0 0 2 NA (3 States)

Notes:

' NA = Not available.

F-29
I APPENDIX 

G

2 COST BENEFIT ANALYSIS
I APPENDIX G

2 COST BENEFIT ANALYSIS

3

4 G.1 Introduction

5

6 This appendix describes the methodology used in preparing the incremental cost benefit analysis that is

7 summarized in Section 7.2.

8

9 An incremental cost benefit analysis measures the impacts of each alternative relative to a baseline, which

10 is how things would be if the alternative were not imposed (i.e., the no-action alternative). The baseline

11 used in this analysis assumes full licensee compliance with existing NRC requirements, including current

12 regulations. This is consistent with the Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory

13 Commission (NRC, 2004), which state that "...in evaluating a new requirement for existing plants, the

14 staff should assume that all existing NRC and Agreement State requirements have been implemented"

15 (NRC, 2004).

16

17 The incremental cost benefit analysis described in this appendix compares the proposed action

18 (construction and operation of the proposed ACP at Piketon, Ohio) with the no-action alternative. For the'

19 purposes of this analysis, the no-action alternative is defined as continued operation of the Paducah

20 Gaseous Diffusion Plant at Paducah, Kentucky. This appendix presents full details of construction and

21 operating costs and the results of a net present value analysis estimating the economic impact of

22 implementing the proposed action compared to the no-action alternative under different discount rates and

23 production capacity assumptions.

24

25 G.2 Methodology and Assumptions

26

27 The incremental cost benefit analysis presented in Section 7.2 considers a limited number of costs and

28 benefits in assessing the net present value of implementing the proposed action compared to the no-action

29 alternative. Specifically, the analysis quantitatively assesses direct costs such as construction costs,

30 manufacturing costs, and decontamination'anid decommissioning costs. The only benefits assessed are

31 those resulting from operating cost savings associated with implementing the proposed action compared

32 to the no-action alternative. Some of the indirect impacts and costs described in Section 7.1.1 are not

33 included as part of this comparative analysis because the effect of these impacts is assumed to be either

34 (1) equal for the proposed action and the no-action alternative as defined above, or (2) too small an

35 impact to materially affect the comparative cost benefit analysis.

36

37 The estimates in this analysis reflect costs and benefits to the U.S. economy and not to USEC. All costs

38 and benefits in this analysis are measured in 2005 real dollars (denoted hereafter as 2005$). Costs and

39 benefits are assumed to accrue at the beginning of the caleidar year over which they actually occur.

40

41 G.3 Costs of the Proposed Action

42

43 Construction Costs: The construction phase of the proposed alternative is estimated to'cost'$i,449

44 million between calendar years 2006 and 2010 (USEC, 2005b). Construction costs are assumed to accrue

45 evenly in each of the calendar years of the construction phase of the proposed action. The construction

46 cost figure USEC provided is not expressed in constant dollars; To be conservative, NRC staff treat these

47 costs as 2005$. This approach overestimates costs, and is therefore a conservative assumption.

G-1
1 Manufacturing Costs: The manufacturing and assembly phase of the proposed alternative is estimated

2 to cost $1,423 million between calendar years 2004 and 2013 (USEC, 2005b). Manufacturing costs are

3 assumed to accrue evenly in each of the calendar years of the manufacturing phase of the proposed action.

4 Again, the USEC cost estimates are not expressed in constant dollars. Similar to the assumption made for,

5 construction costs, the costs derived from the manufacturing and assembly phase are treated as 2005$ in

6 the cost benefit analysis. This is a conservative assumption that likely overstates costs.

7

8 Decontamination and Decommissioning Costs: Decontamination and decommissioning of the

9 proposed alternative is estimated to cost $435 million (2004$) (USEC, 2005b). These costs are adjusted

10 to reflect 2005$ (NASA, 2005). Decontamination and decommissioning costs are assumed to accrue

11 evenly over six years, commencing 30 years after the first year of operation. The cost benefit analysis

12 does not factor in costs associated with tails disposition. It is assumed that for a given production level,

13 the amount of tails generated by the proposed ACP will be equivalent to the amount of tails that would

14 have been generated using Paducah Gaseous Diffusion Plant (USEC, 2005b). Therefore, no incremental

15 tails disposition costs result from the proposed action relative to the no-action alternative.

16

17 G.4 Costs of the No-Action Alternative

18

19 No construction or manufacturing costs are associated with the no-action alternative.

20

21 The decontamination and decommissioning schedule and costs associated with the Paducah Gaseous

22 Diffusion Plant are considered independent of the proposed alternative and are not included in this

23 analysis.

24

25 In addition, this section does not consider the costs and benefits associated with actions pertaining to the

26 Portsmouth Gaseous Diffusion Plant. USEC closed the Portsmouth Gaseous Diffusion Plant in May 2001

27 to reduce operating costs. The NRC staff do not believe that there has been any significant change in the

28 factors that were considered by USEC in its decision to cease uranium enrichment at Portsmouth. For the

29 purposes of this cost benefit analysis, actions pertaining to the Portsmouth Gaseous Diffusion Plant, such

30 as decontamination and decommissioning, are considered unrelated to the no-action alternative and the

31 proposed action.

32

33 G.5 Benefits of the Proposed Action Relative to the No-Action Alternative

34

35 Benefits in a given year are computed as the difference between the operating costs per separative work

36 unit of the no-action alternative and the proposed alternative multiplied by the level of production

37 substituted in that year. Two scenarios are assumed:

38

39 (i) the proposed action substitutes 4.6 million separative work units of production at the Paducah

40 Gaseous Diffusion Plant (this figure reflects the anticipated production levels at the Paducah Gaseous

41 Diffusion Plant in 2005); and,

42 (ii) the proposed action substitutes 7 million separative work units of production at the Paducah

43 Gaseous Diffusion Plant.

44

45 In both scenarios, the proposed ACP is assumed to be producing at the 7 million separative work unit

46 capacity level. The difference is that in the first scenario, the proposed ACP is replacing only 4.6 million

47 separative work units that would otherwise have been produced at the Paducah Gaseous Diffusion Plant.

48 This analysis assumes that the proposed ACP's excess production (2.4 million separative work units)

49 substitutes production from sources that are no more expensive than the proposed ACP. Therefore,

50 incremental benefits from the proposed action do not accrue beyond the 4.6 million separative work units

51 level. In the second scenario, the proposed ACP is substituting 7 million separative work units that would

G-2
I otherwise have been produced at the Paducah Diffusion Gaseous Pian't, the benefits are therefore higher

2 in the second scenario.

3

4 In both scenarios, separative work unit production at the proposed ACP is expected to phase-in according

5 to USEC's proposed schedule (USEC, 2005b). Specifically, the proposed ACP is expected to reach an

6 annual capacity of I 'million separative work units per year in 2010, and is projected to have an annual

7 capacity of 3.5 million separative work units per year in 201 1 (USEC, 2005b). The proposed ACP is

8 assumed to reach full capacity by 2015. These milestones are factored into the cost benefit analysis.

9

10 Operating costs under the no-action alternative are estimated to be approximately four times higher than

11 under the proposed action. These costs'are considered to be proprietary and have been withheld here

12 pursuant to 10 CFR 2.390.

13

14 G.6 Discount Rates

15

16 Three different real discount rates are applied to estimate the net present value of the proposed altemative

17 - zero percent, three percent, and seven percent. These discount rates are consistent with those

18 recommended in NUREG/BR-01 84, RegulatoryAnalysis Technical Evaluation Handbook (NRC, 1997).

19 The higher discount rate places a lower value on benefit streams occurring in the future. Net present

20 value estimates are lower under the higher real discount rate because most of the costs associated with the

21 proposed alternative occur up front while benefits are distributed evenly over time.

22

23 G.7 Limitations

24

25 The cost benefit analysis presented here does not quantitatively estimate potential impacts such as public

26 health effects, occupational health effects, and property value impacts.

27

28 Furthermore, certain benefits associated with the proposed alternative, including domestic energy security

29 policy objectives, are not captured in this economic analysis.

30

31 As stated in Chapter 7, this analysis does not attempt a dynamic general equilibrium modeling of the

32 economic effects of a cheaper source of enriched uranium for nuclear power plants. No attempt is made

33 to model the effects of reduced enriched uranium prices on the ratio of nuclear and non-nuclearpower in

34 the domestic economy, on overall power demand and price, and on the potential economic benefits to

35 consumers and suppliers. Instead, the analysis focuses on estimating the economic savings to society

36 from replacing Paducah Gaseous Diffusion Plant production by a cheaper and less 'resource-intensive

37 source based on centrifuge technology.

38

39 G.8 Results

40

41 Table G-1 presents the net present value of implementing the proposed action instead of the no-action

42 alternative for the two scenarios described above at three alternative real discount rates. The figures

43 represent net benefits of the proposed action when compared to the no-action alternative.

G-3
I

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

Table G-1 Net Present Value of the Net Benefits of

Proposed Alternative Relative to the No-action Alternative

Scenario 1: Proposed ACP Substitutes 4.6 Million Separative Work Units

of Paducah Gaseous Diffusion Plant Production

Net Present Value (3 percent) in 2005 in Millions 2005$ = $3,630

Net Present Value (7 percent) in 2005 in Millions 2005$ $ $966

Net Present Value (0 percent) in 2005 in Millions 2005S ___ _ i$7,992

Scenario 2: Proposed ACP Substitutes 7 Million Separative Work Units

of Paducah Gaseous Diffusion Plant Production

Net Present Value (3 percent) in 2005 in Millions 2005$ $6,417

Net Present Value (7 percent) in 2005 in Millions 2005S $62,290

Net Present Value (0 percent) in 2005 in Millions 2005S $ 13,212

G.9 Conclusions

The analysis indicates that the incremental economic benefits of implementing the proposed action

instead of the no-action alternative are substantially positive under both the scenarios and the three

discount rates considered, even after accounting for all project-related costs.

G.10 References

(NASA, 2005) National Aeronautics and Space Administration. "Gross Domestic Product Deflator

Inflation Calculator." <http://www I jsc.nasa.govibu2/inflateGDP.html> May 25, 2005.

(USEC, 2005a) United States Enrichment Corporations. "Additional Responses to Request for

Additional Information Regarding the Environmental Report (TAC No. L32307) - Proprietary

Information." April 21, 2005.

(USEC, 2005b) United States Enrichment Corporation. "Environmental Report for the American

Centrifuge Plant in Piketon, Ohio." Revision 3. NRC Docket No. 70-7004. July 2005.

(NRC, 1997) U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research.

"Regulatory Analysis Technical Evaluation Handbook, Final Report," NUREG/BR-0184. January 1997.

(NRC, 2004) U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research. "Regulatory

Analysis Guidelines of the U.S. Nuclear Regulatory Commission," NUREG/BR-0058. September 2004.

G4
1 APPENDIX 

H

2 ACCIDENT ANALYSIS FOR THE PROPOSED ACP 3
I The text in this appendix is being withheld pursuant to 10 CFR 2.390.
I APPENDIX 

I

2 GLOSSARY
1 APPENDIX I

2 GLOSSARY

3

4 Acid rain: Rain with a pH of less than 5.6.

5

6 Agreement State: A state that has signed an agreement with the Nuclear Regulatory Commission under

7 which the state regulates the use of byproduct, source, and small quantities of special nuclear material in

8 that state.

9

10 Air pollutant: Any substance in air which could, if in high enough concentration, harm humans,

11 other animals, 'vegetation, or material. Pollutants may include almost any'natural or artificial

12 composition of matter capable of being airborne.-

13

14 Air quality: A measure of the quantity of pollutants, measured individually, in the air. These

15 levels are often compared to regulatory standards.

16

17 ALARA: Acronym for "as low as (is) reasonably achievable." An approach to keep radiation exposures

18 (both to the workforce and the public) and releases of radioactive material to the environment at levels

19 that are as low as social, technical, economic, practical, and public policy considerations allow. ALARA

20 is not a dose limit; it is a practice whose objective is the attainment of dose levels as far below applicable

21 limits as possible.'

22

23 Alluvium: Loose gravel, sand, silt, or clay deposited by streams or running water.

24

25 Alpha particle: A positively charged particle ejected spontaneously from the nuclei of some radioactive

26 elements. It is identical to a helium nucleus that has amass number of 4 and an electrostatic charge of +2.

27 'It has low penetrating power and a short range (a few centimeters in air). The most energetic alpha

28 particle will generally fail to penetrate the dead layers of cells covering the skin and can be easily stopped

29 by a sheet of paper. Alpha particles are hazardous when an alpha-emitting isotope is inside the body.

30

31 Ambient Air Quality Standards: Standards established on a State or Federal level, that define the limits

32 for airborne concentrations of designated "criteria" pollutants (nitrogen dioxide, sulfur dioxide, carbon

33 monoxide, total suspended particulates, ozone, and lead), to protect public health with an adequate margin

34 of safety (primary standards) and to protect public welfare; including plant and animal life, visibility, and

35 materials (secondary standards). -

36

37 Aquifer: A permeable body of rock capable of yielding quantities of groundwater to wells and springs.

38

39 Area of potential effects: The geographic area or areas within which an undertaking may directly'or

40 indirectly cause alterations in the character or use of historic properties, if any such properties exist. The

41 area of potential effects is influenced by the scale and nature of an undertaking and may be different for

42 different kinds of effects' caused by the undertaking (See 36 CFR § 800.16).

43

44 Assay: The qualitative or quantitative analysis of a substance often used to determine the proportion of

45 isotopes in radioactive materials.

1-1
I Atomic EnergyAct of 1954 as amended: A federal law that created the Atomic Energy Commission,

2 which later split into the Nuclear Regulatory Commission and the Energy and Research and Development

3 Administration (ERDA). ERDA became part of the Department of Energy in 1977. This act encouraged

4 the development and use of nuclear energy and research for the general welfare and the security of the

5 United States. This act authorized the Nuclear Regulatory Commission to regulate and license fuel

6 fabrication facilities that seek to receive, possess, use, or transfer special nuclear material.

7

8 Attainment area: A region that meets the U.S. EPA National Ambient Air Quality Standards (NAAQS)

9 for a criteria pollutant under the Clean Air Act.

10

11 Background radiation: Radiation from cosmic sources, naturally occurring radioactive materials,

12 including radon (except as a decay product of source or special nuclear material), and global fallout as it

13 exists in the environment from the testing of nuclear explosive devices. It does not include radiation from

14 source, byproduct, or special nuclear materials regulated by the Nuclear Regulatory Commission. The

15 typically quoted average individual exposure from background radiation is 360 millirems per year.

16

17 Becquerel (Bq): A unit used to measure radioactivity. One Becquerel is that quantity of a

18 radioactive material that will have one transformation in one second. There are 3.7 x 10'0 Bq in

19 one curie (Ci).

20

21 Best Management Practices (BMP): Structural, nonstructural, and managerial techniques recognized to

22 be the most effective and practical means to reduce surface water and groundwater contamination while

23 still allowing the productive use of resources.

24

25 Beta particle: A charged particle emitted from a nucleus during radioactive decay, with a mass equal to

26 1/1837 that of a proton. A negatively charged beta particle is identical to an electron. A positively

27 charged beta particle is called a positron. Large amounts of beta radiation may cause skin bums, and beta

28 emitters are harmful if they enter the body. Beta particles may be stopped by thin sheets of metal or

29 plastic.

30

31 Bound: To estimate or describe a lower or upper limit on a potential environmental or health

32 consequence when uncertainty exists.

33

34 Buffer area: A designated area of land that is designed to permanently remain vegetated in an

35 undisturbed and natural condition in order to protect an adjacent aquatic or wetland site from upland

36 impacts and to provide habitat for wildlife.

37 -

38 Byproduct material: The tailings or wastes produced by the extraction or concentration of uranium or

39 thorium from any ore processed primarily for its source material content. See also, Source Material.

40

41 Carbon monoxide: An odorless, colorless, poisonous gas produced by incomplete burning of carbon in

42 fuels. Exposure to carbon monoxide reduces the delivery of oxygen to the body's organs and tissues.

43 Elevated levels can cause impairment of visual perception, manual dexterity, learning ability, and

44 performance of complex tasks.

45

46 Census tract: An area usually containing between 2,500 and 8,000 persons that is used for

47 organizing and monitoring census data. The geographic dimensions of census tracts vary

48 widely, depending on population density. Census tracts do not cross county borders.

1-2
1 Climatology: The science devoted to the study of the conditions of the natural environment (rainfall,

2 daylight, temperature, humidity, air movement) prevailing in specific regions of the earth.

3

4 Cold standby: Cold standby involves placing those portions of the Gaseous Diffusion Plant needed for 3

5 million separative work units per year production capacity in a non-operational condition. It also includes

6 performing surveillance and maintenance activities necessary to retain the ability to resume operations

7 after a set of restart activities are conducted.

8

9 Contamination: Undesired radioactive material that is deposited on the surface of, or inside structures,

10 areas, objects, or people.

11

12 Cooling water: Water circulated through a nuclear reactor or processing plant to remove heat.'

13

14 Cost-benefit analysis: A formal quantitative procedure comparing costs and benefits of a

15 proposed project or act under a set of preestablished rules.

16

17 Council on Environmental Quality: The President's Council on Environmental Quality (CEQ)

18 was established by the enactment of National Environmental PolicyAct (NEPA): The CEQ is

19 responsible for developing regulations to be followed by all federal agencies'in'developing and'

20 implementing their own specific NEPA implementation policies and procedures.

21

22 Criteria pollutants: Common air pollutants for which National Ambient Air Quality Standards

23 have been established by the U.S. EPA under Title I of the Clean AirAct. Criteria pollutants include

24 sulfur dioxide, nitrogen oxides, carbon monoxide, ozone, particulate matter (PM1O and PM23), and lead.

25 Standards for these pollutants were'developed on the basis of scientific knowledge about their health

26 effects.

27

28 Critical habitat: Specific areas within the geographical range of an endangered species'that is

29 formally designated by the U.S. Fish and Wildlife Service under the Endangered Species Act as

30 essential for conservation.

31

32 Cumulative impacts: Potential impacts when the proposed action is added to other past,

33 present, and reasonable foreseeable future actions. 'Cumulative impacts can result from

34 individually minor but collectively significant actions taking place over a period of time.

35

36 Curie (Ci): The basic unit used to describe the intensity of radioactivity in a sample of material. The

37 curie is equal to 37 billion (3;7 x 10'°) disintegrations per second, which is approximately the activity of 1

38 gram of radium. A curie is also a quantity of any radionuclide that decays at a rate of 37 billion

39 disintegrations per second. It is named for Marie and Pierre Curie, who discovered radium in 1898.

40

41 Day-Night Average Noise Level (DNL): DNL'is a noise metric combining the levels and durations of

42 noise events and the number of events over an extended time period. It is a cumulative average computed

43 over a set of 24-hour periods to represent total noise exposure. -DNL also accounts for more intrusive

44 night time noise, adding a 10 dB penalty for sounds after 10:00 p m. and before 7:00 a.m.

45

46 Decibel (dB):' A standard unit for measuring sound-pressure levels based on a reference '

47 sound pressure of 0.0002 dyne per square centimeter. This is the smallest sound a human can

48 hear. In general, a sound doubles in loudness with every increase of slightly more than

49 3 decibels.

I-3
1 Decibel, A-weighted (dBA): A number representing the sound level which is frequency weighted

2 according to a prescribed frequency response established by the American National Standards Institute

3 and accounts for the response of the human ear.

4

5 Decommissioning: The process of closing down a facility followed by reducing residual radioactivity to

6 a level that permits the release of the property for unrestricted use (see 10 CFR 20.1003).

7

8 Decontamination: The reduction or removal of contaminating radioactive material from a structure,

9 area, object, or person. Decontamination may be accomplished by (1) treating the surface to remove or

10 decrease the contamination, (2) letting the material stand so that the radioactivity is decreased as a result

11 of natural radioactive decay, or (3) covering the contamination to shield or attenuate the radiation emitted

12 (see 10 CFR 20.1003 and 20.1402).

13

14 Depleted uranium: Uranium having a percentage of uranium-235 smaller than the 0.7 percent found in

15 natural uranium. It is obtained from spent (used) fuel elements or as byproduct tails, or residues, from

16 uranium isotope separation.

17

18 Depleted uranium hexalluoride (DUF 6): A compound of uranium and fluorine from which most of the

19 uranium-235 isotope has been removed.

20

21 Direct jobs: The number of workers required at a site to implement an alternative.

22

23 Dose: The absorbed dose, given in rads (or in SI units, grays), that represents the energy absorbed from

24 the radiation in a gram of any material. Furthermore, the biological dose or dose equivalent, given in rem

25 or sieverts, is a measure of the biological damage to living tissue from radiation exposure.

26

27 Dosimetry: The theory and application of the principles and techniques involved in the measurement and

28 recording of radiation doses. Its practical aspect is concerned with the use of various types of radiation

29 instruments with which measurements are made (i.e., film badge, thermoluminescent dosimeter, and

30 Geiger counter).

31

32 Effluent: A gas or fluid discharged into the environment, treated or untreated. Most frequently,

33 the term applies to wastes discharged to surface waters.

34

35 Emissions: Substances that are discharged into the air.

36

37 Endangered species: Any species (plant or animal) that is in danger of extinction throughout

38 all or a significant part of its range. Requirements for declaring a species endangered are found

39 in the Endangered Species Act.

40

41 Endangered SpeciesAct of 1973: An act requiring federal agencies, with the consultation

42 and assistance of the Secretaries of the Interior and Commerce, to ensure that their actions will not likely

43 jeopardize the continued existence of any endangered or threatened species or adversely affect the habitat

44 of such species.

45

46 Erosion: The wearing away of the land surface by wind, water, ice, or other geologic agents. Erosion

47 occurs naturally from weather or runoff but is often intensified by human land use practices.

48

49 Exposure: Being exposed to ionizing radiation or to radioactive material.

1-4

I.
I Exposure pathways: A route or sequence of processes by which a radioactive or hazardous -.

2 material may move through the environment to humans or other organisms. Each exposure

3 pathway includes a source or release from a source, an exposure point, and an exposure route.

4

S Floodplain: Low-lying areas adjacent to rivers and streams that are subject to natural inundations

6 typically associated with precipitation.

7

8 Fuel cycle: The series of steps involved in supplying fuel for nuclear power reactors. It can include

9 mining, milling, isotopic enrichment, fabrication of fuel elements, use in a reactor, chemical reprocessing

10 to recover the fissionable material remaining in'the spent fuel, reenrichment of the fuel material,

11 refabrication into new fuel elements, and waste disposal.

12

13 Fugitive Dust: Any solid particulate matter (PM) that becomes airborne, other than that emitted from an

14 exhaust stack, directly or indirectly as a result of the activities of man. Fugitive dust may include

15 emission from haul roads, wind erosion of exposed soil surfaces, and other activities in which soil is

16 either removed or redistributed.

17

18 Geology and Soils: Those Earth resources that may be described in terms of landforms, geology, and

19 soil conditions.

20

21 Gray (Gy): The international system (SI) unit of absorbed dose. One gray is equal to an absorbed dose

22 of I Joule/kilogram (one gray equals 100 rads) (see 10 CFR 20.1004).

23

24 Groundwater: Water, both fresh and saline, that is stored below the Earth's surface in pores, cracks, and

25 crevices below the water table.

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27 Hazardous Air Pollutants (HAPs): A group of 188 chemicals identified in the 1990

28 Clean Air Act Amendments. Exposure to these pollutants can cause or contribute to cancer, birth defects,

29 genetic damage, and other adverse health effects.

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31 Hazardous waste: According to the Resource Conservation and Recovery Act, a waste that,

32 because of its characteristics, may (1) cause or significantly contribute to an increase in

33 mortality or an increase in serious irreversible illness, or (2) pose a substantial hazard to human

34 health or the environment when improperly treated, stored, transported, disposed of, or

35 otherwise managed. Hazardous wastes possess at least one of the following characteristics:

36 ignitability, corrosivity, reactivity, or toxicity. Hazardous waste is nonradioactive.

37

38 Heels: In the uranium enrichment process, heels refers to the residual solid uranium hexafluoride left

39 after the feed rate declines to a predetermined level.

40

41 Highly enriched uranium (HEU): Uranium enriched in the isotope uranium-235 to 20% or above,

42 which thus becomes suitable for nuclear weapons use.

43

44 Historic and Cultural Resources: Cultural resources include any prehistoric or historic district, site,

45 building, structure, or object resulting from, or modified by, human activity. Historic properties are

46 cultural resources listed in, or eligible for listing in, the National Register of Historic Places. * *

47

48 Holding ponds: Engineered depressions in the land that contain storm-water runoff until it

49 can slowly seep back into the ground or evaporate.

I-5
I Impacts: An assessment of the meaning of changes in all attributes being studies for a given resource.

2 An aggregation of all of the adverse effects, usually measured using a qualitative and nominally

3 subjective technique.

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Indirect jobs: Jobs generated or lost in related industries within a regional economic area as a

result of a change in direct employment.

Ingestion: To take in by mouth. Material that is ingested enters the digestive system.

Inhalation: To take in by breathing. Material that is inhaled enters the lungs.

Isotope: Any two or more forms of an element having identical or very closely related chemical

properties and the same atomic number but different atomic weights or mass numbers.

Land Use: The way land is developed and used in terms of the kinds of anthropogenic activities that

occur (e.g., agriculture, residential areas, industrial areas).

Lead: A heavy metal element formerly added to gasoline and paint for improved performance

characteristics. Lead can be inhaled and ingested in food, water, soil, or dust. High exposure to lead can

cause seizures, mental retardation, and/or behavioral disorders. Low exposure to lead can lead to central

nervous system damage.

Low-enriched uranium (LEU): Uranium enriched in the isotope uranium-235, greater than

0.7% but less than 20% of the total mass. Naturally occurring uranium contains about 0.7%

uranium-235, almost all the rest is uranium-238.

Low-level mixed waste: Low-level waste that also contains hazardous chemical components regulated

under the Resource Conservation and Recovery Act.

Low-level radioactive waste: Wastes containing source, special nuclear, or byproduct material are

acceptable for disposal in a land disposal facility. For the purposes of this definition, low-level waste has

the same meaning as in the Low-Level Radioactive Waste Policy Act, that is, radioactive waste not

classified as high-level radioactive waste, transuranic waste, spent nuclear fuel, or byproduct material as

defined in section I Ie.(2) of the Atomic Energy Act (uranium or thorium tailings and waste).

Maximally exposed individual (MET): A hypothetical person who-because of proximity, activities, or

living habits-could receive the highest possible dose of radiation or of a hazardous chemical from a

given event or process.

Meteorology: The science dealing with the atmosphere and its phenomena, especially as

relating to weather.

Microcurie: One millionth of a curie. That amount of radioactive material that disintegrates (decays) at

the rate of 37 thousand atoms per second.

Mitigation: A series of actions implemented to ensure that projected impacts will result in no

net loss of habitat value or wildlife populations. The purpose of mitigative actions is to avoid,

minimize, rectify, or compensate for any adverse environmental impact.

Millirem (mrem): One thousandth of a rem (0.001 rem).

I 

1-6
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1 Mixing height: The height above the earth's surface thiough which relatively strong' vertical mixing of

2 the atmosphere occurs.

3

4 Modified Mercalli Intensity: A measurement of earthquake intensity based on the effects to peopIe and

5 structures. Ranges from I (low) to XII (total destruction), as opposed to the Richter scale, which

6 measures the energy of the earthquake. Mercalli scale is often used to classify earthquakes that were not

7 recorded on modern seismographs.

8

9 National Environmental Policy Act (NEPA) of1969: A federal law constitutinig the basic

10 national charter for protection of the environment. The act calls for the preparation of an

11 environmental impact statement (EIS) for every major federal action that may significantly affect

12 the quality of the human or natural environment. The main purpose is to ensure that

13 environmental information is provided to decision makers so that their actions are based on an

14 understanding of the potential environmental and socioeconomic consequences of a proposed

15 action and the reasonable alternatives. ' -

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17 National Historic Preservation Act (NHPA): A federal law providing that property resources with

18 significant national historic value be placed on the National Register of Historic Places. It does not

19 require permits; rather, it mandates consultation with the proper agencies whenever it is

20 determined that a proposed action might impact a historic property.

21

22 National Pollutant Discharge Elimination System (NPDES): A federal permitting system

23 controlling the discharge of effluents to surface waters of the United States and regulated

24 through the Clean Water Act, as amended.

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26 National Register of Historic Places (NRBIP): A list of districts sites, buildings, structures,

27 and objects of prehistoric or historic local, state, or national significance. The list is maintained

28 by the Secretary of the Interior.

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30 Nitrogen dioxide: A brownish, highly reactive gas that is present in all urban atmospheres. Nitrogen

31 dioxide can irritate the lungs, cause bronchitis and pneumonia, and lower resistance to respiratory

32 infections. The major mechanism for the formation of nitrogen dioxide in the atmosphere is the oxidation'

33 of the primary air pollutant nitric oxide. Nitrogen oxides, together with volatile organic carbons, play a

34 major role in the atmospheric reactions that produce ozone. Nitrogen oxides form when fuel is burned at

35 high temperatures'.' The two major emissionis sources are transportation and stationary fuel combustion

36 sources such as electric utility and industrial boilers.

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38 Non-Attainment Areas: An area that has been designated by the Environmental Protection Agency, or

39 the appropriate state air quality agency, as exceeding one or more national or state Ambient Air Quality

40 Standards. -

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42 Normal operations: Conditions duringwhich facilities and processes operate as expected or

43 designed. In general, normal operations include the occurrence of some'infrequent events that,

44 although not considered routine, are not classified as accidents.

- I-7
I Ozone: A photochemical (formed in chemical reactions between volatile organic compounds and

2 nitrogen oxides in the presence of sunlight) oxidant and the major component of smog. Exposure to

3 ozone for several hours at low concentrations has been shown to significantly reduce lung function and

4 induce respiratory inflammation in normal, healthy people during exercise. Other symptoms include

5 chest pain, coughing, sneezing, and pulmonary congestion.

6

7 Outfall: The place where effluent is discharged into receiving waters.

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9 Particulate matter: Materials such as dust, dirt, soot, smoke, and liquid droplets that are emitted into the

10 air by sources such as factories, power plants, cars, construction activity, fires, and natural windblown

11 dust. Exposure to high concentrations of particulate matter can affect breathing, aggravate existing

12 respiratory and cardiovascular disease, alter the body's defense systems against foreign materials, damage

13 lung tissue, and cause premature death.

14

15 Personnel monitoring: The use of portable survey meters to determine the amount of radioactive

16 contamination on individuals; or, the use of dosimetry to determine an individual's occupational radiation

17 dose.

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19 Pigtail operations: Refers to the activities related to the connection and disconnection of the valving and

20 hosing associated with feed and withdrawal operations.

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22 Point source: A source of effluents that is small enough in dimensions that it can be treated as

23 if it were a point. A point source can be either a continuous source or a source that emits

24 effluents only in puffs for a short time.

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26 Pollutant: Any material entering the environment that has undesired effects.

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28 Pollution: The addition of an undesirable agent to the environment in excess of the rate at

29 which natural processes can degrade, assimilate, or disperse it.

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31 Pollution prevention: The use of any process, practice, or product that reduces or eliminates

32 the generation and release of pollutants, hazardous substances, contaminants, and wastes,

33 including those that protect natural resources through conservation or more efficient utilization.

34

35 Prime farmland: Land with the best combination of physical and chemical characteristics for

36 economically producing high yields of food, feed, forage, fiber, and oilseed crops with minimum

37 inputs of fuel, fertilizer, pesticides, and labor. Prime farmland includes cropland, pastureland,

38 rangeland, and forestland.

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40 Rad: The special unit for radiation absorbed dose, which is the amount of energy from any type of

41 ionizing radiation (e.g., alpha, beta, gamma, neutrons, etc.) deposited in any medium (e.g., water, tissue,

42 air). A dose of one rad means the absorption of 100 ergs (a small but measurable amount of energy) per

43 gram of absorbing tissue (100 rad = I gray).

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45 Radiation (ionizing radiation): Alpha particles, beta particles, gamma rays, x-rays, neutrons,

46 high-speed electrons, high-speed protons, and other particles capable of producing ions. Radiation, as

47 used in 10 CFR Part 20, does not include non-ionizing radiation, such as radio- or microwaves, or visible,

48 infrared, or ultraviolet light. (see also 10 CFR 20.1003)

1-8
I Radiation standards: Exposure standards, permissible concentrations, rules for safe handling,

2 regulations for transportation, regulations for industrial control of radiation, and control of radioactive

3 material by legislative means.

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5 Radioactivity: The spontaneous decay or disintegration of unstable atomic nuclei,

6 accompanied by the emission of radiation. Eventually the unstable nuclei reach a stable state.

7

8 Radionuclide: An atom that exhibits radioactive properties. Radionuclides can be man-made or

9 naturally occurring, can have a long life, and can have potentially mutagenic or carcinogenic effects on

10 the human body.

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12 Region of influence (ROI): The physical area that bounds the environmental, sociological,

13 economic, or cultural features of interest for the purpose of analysis. A site-specific geographic

14 area that includes the counties where approximately 90% of the site's current employees

15 reside.

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17 Rem: The acronym for roentgen equivalent man is a standard unit that measures the effects of ionizing

18 radiation on humans. The dose equivalent in rems is equal to the absorbed dose in rads multiplied by the

19 quality factor of the type of radiation (see 10 CFR 20.1004).

20

21 Remediation: Action taken to permanently remedy a release, or threatened release, of a

22 hazardous or radioactive substance to the environment, instead of or in addition to removal.

23

24 Resource Conservation and Recovery Act (RCRA): A federal law that provides for a "cradle-to-grave"

25 regulatory program for hazardous waste, including a system for managing hazardous

26 waste from its generation to its ultimate disposal.

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28 Restricted area: Any area to which access is controlled for the protection of individuals from exposure

29 to radiation and radioactive materials.

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31 Roentgen: A unit of exposure to ionizing radiation. It is the amount of gamma or x-rays required to

32 produce ions resulting in a charge of 0.000258 coulombs/kilogram of air under standard conditions.

33 Named after Wilhelm Roentgen, the Germnan scientist who discovered x-rays in 1895.

34

35 Runoff: The portion of rainfall that is not absorbed by soil, evaporated, or transpired by plants, but finds

36 its way into streams directly or as overland surface flows.

37

38 Sanitary/industrial waste: Nonhazardous, nonradioactive liquid and solid waste generated by normal

39 housekeeping activities.

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41 Sediment: Eroded soil particles that are deposited downhill or downstream by surface runoff.

42

43 Shielding: Any material or obstruction that absorbs radiation and thus tends to protect personnel or

44 materials from the effects of ionizing radiation.

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46 Sievert (Sv): A unit of radiation dose used to express a quantity called equivalent dose. This

47 relates the absorbed dose in human tissue to the effective biological damage of the radiation by

48 taking into account the kind of radiation received, the total amount absorbed by the body, and

49 the tissues involved. Not all radiation has the same biological effect, even for the same amount

50 of absorbed dose. One sievert is equivalent to 100 rem.

1-9
I Site characterization: An onsite investigation at a known or suspected contaminated waste or release

2 site to determine the extent and type(s) of contamination.

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4 Source material: Uranium or thorium ores containing 0.05 percent Uranium or Thorium regulated under

5 the Atomic Energy Act. In general, this includes all materials containing radioactive isotopes in

6 concentrations greater than natural and the byproduct (tailings) from the formation of these concentrated

7 materials

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9 Special nuclear material: Plutonium, uranium-233, or uranium enriched in the isotopes uranium-233 or

10 uranium-235.

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State Historic Preservation Officer (SHPO): The state officer charged with the identification

and protection of prehistoric and historic resources in accordance with the National Historic

Preservation Act.

Subsidence: The process of sinking or settling of a land surface due to natural or artificial

causes.

Sulfur dioxide: A gas emitted largely from stationary sources such as coal and oil combustion, steel and

paper mills, and refineries. It is a primary contributor to acid rain and contributes to visibility

impairments in large parts of the country. Exposure to sulfur dioxide can affect breathing and may

aggravate existing respiratory and cardiovascular disease.

Surface water: Water located on the surface of the Earth in water bodies such as lakes, rivers, streams,

ponds, wetlands, and the ocean.

Tails: In the uranium enrichment process, tails refers to gas with a reduced concentration of the

uranium-235 isotope.

Threatened Species: Plant and wildlife species that are likely to become endangered in the foreseeable

future.

Toxic Substances ControlAct (TSCA): A federal law authorizing the U.S. Environmental

Protection Agency to secure information on all new and existing chemical substances and to

control any of these substances determined to cause unreasonable risk to public health or the

environment. This law requires that the health and environmental effects of all new chemicals

be reviewed by the EPA before such chemicals are manufactured for commercial purposes.

Uranium: A radioactive element with the atomic number 92 and, as found in natural ores, an atomic

weight of approximately 238. The two principal natural isotopes are uranium-235 (0.7 percent of natural

uranium), which is fissile, and uranium-238 (99.3 percent of natural uranium), which is fissionable by fast

neutrons and is fertile. Natural uranium also includes a minute amount of uranium-234.

Visual Resource Management (VRM): A process devised by the Bureau of Land

Management to assess the aesthetic quality of a landscape and to design proposed activities in

a way that would minimize their visual impact on that landscape. The process consists of a

rating of site visual quality followed by a measurement of the degree of contrast between the

proposed development activities and the existing landscape.

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I Visual and Scenic Resources: Natural or developed landscapes that provide information for an

2 individual to develop their perceptions of the area. The size, type, gradient, scale, and continuity of

3 landforms, structures, land use patterns, and vegetation are all contributing factors to an area's visual

4 character and how it is perceived.

* 5

6 Volatile Organic Compounds (VOCs): Organic compounds that easily volatize or evaporate and can

7 break down through photodestructive mechanisms. VOCs contribute to air pollution, especially the

8 generation of tropospheric ozone (03).

9

10 Waste management: The planning, coordination, and direction of functions related to

11 generation, handling, treatment, storage, transportation, and disposal of waste. It also includes

12 associated pollution prevention and surveillance and maintenance activities.

13

14 Waste minimization: An action that economically avoids or reduces the generation of waste

15 by source reduction and recycling; or reduces the toxicity of hazardous waste, improving energy

1 6 usage.

17

18 Water resources: This term includes both freshwater and marine systems, wetlands, floodplains, and

19 ground water.

20

21 Well field: Area containing one or more wells that produce usable amounts of water.

22

23 Wetlands: Land or areas exhibiting the following characteristics: hydric soil conditions; saturated or

24 inundated soil during some part of the year and plant species tolerant of such conditions; also, areas that

25 are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support,

26 under normal circumstances, a prevalence of vegetation typically adapted for life in saturated soil

27 conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.

I-1I
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9204) (Assigned by NRC, Add Vol, Supp.. Rev.,

NRCMD 3.7 and Addendum Numbers, IT any.)

BIBLIOGRAPHIC DATA SHEET

(See istfrucons on the reverse) NUREG-1 834

2. TITLE AND SUBTITLE 3. DATE REPORT PUBUSHED

Environmental Impact Statement for the Proposed American Centrifuge Plant in Piketon, OH MONTH YEAR

Draft Report for Comment Auqust I 2005

4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

Technical

7. PERIOD COVERED (incus/ve Dares)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC provile DAision, Office or Region, U.S. Nuclear Regutatory Commnsslon, and marinV address; it contractor.

provide name and malVg address.)

Division of Waste Management and Environmental Protection

Office of Nuclear Material Safety and Safeguards

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (ItNRC type 'Same as above', 11ntracror.provideNRCDMsidn Office orReion U.S. NudearRegulatoryCommssion

and mafit address.)

Same as above

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 words or less)

USEC Inc. (USEC) has submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for a license to construct,

operate, and decommission the American Centrifuge Plant (ACP), a gas centrifuge uranium enrichment facility located on the

U.S. Department of Energy (DOE) reservation in Piketon, Ohio. The American Centrifuge Plant, if licensed, would enrich

uranium for use in commercial nuclear fuel for power reactors. Feed material would be comprised of non-enriched uranium

hexafluoride (UF6). USEC proposes to enrich uranium up to 10 percent by weight of uranium-235. The initial license

application is for a 3.5 million separative work unitl (SW U) per year facility. Because USEC indicated the potential for future

expansion to 7.0 million SWU per year, the environmental review looks at the impacts from a 7.0 million SWU per year facility.

The proposed ACP would be licensed In accordance with the provisions of the Atomic Energy Act. Specifically, an NRC license

under Title 10, 'Energy," of the U.S. Code of Federal Regulations (10 CFR) Parts 30, 40, and 70 would be required to authorize

USEC to possess and use special nuclear material, source material, and byproduct material at the proposed ACP site.

This Draft Environmental Impact Statement (Draft EIS) was prepared In compliance with the National Environmental Policy Act

and the NRC regulations for Implementing the Act. This Draft EIS evaluates the potential environmental impacts of the

proposed action and its reasonable alternatives. This Draft EIS also describes the environment potentially affected by USEC's

proposal, presents and compares the potential environmental impacts resulting from the proposed action and its alternatives,

and describes USEC's environmental monitoring program and mitigation measures.

12. KEY WORDSIDESCRIPTORS (Lit words orpirases that wit assistresearchers hi ocatifhe report) 13. AVAILABILITY STATEMENT

USEC unlimited

gas centrifuge 14. SECURITY CLASSIFICATION

uranium enrichment (This Page)

American Centrifuge Plant unclassified

Piketon (i eot

environmental impact statement

uranium hexafluoride unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER
.I I

Printed

on recycled

paper

Federal Recycling Program
-I

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS