FINDING OF NO SIGNIFICANT IMPACT 

URANIUM-233 MATERIAL DOWNBLENDING AND DISPOSITION PROJECT 

AT THE OAK RIDGE NATIONAL LABORATORY, 

OAK RIDGE, TENNESSEE 

AGENCY: U.S. Department of Energy (DOE) 

ACTION: Finding of No Significant Impact (FONSI) 

SUMMARY: DOE has completed the Final Environmental Assessment for U-233 Material 

Downblending and Disposition Project at the Oak Ridge National Laboratory [DOE/EA-1651]. 

This environmental assessment (EA) evaluates the impacts of planned activities to modify selected 

Oak Ridge National Laboratory (ORNL) facilities; process the ORNL inventory of uranium-233 

(U-233); and transport the processed material to a long-term disposal facility. Small quantities of 

similar material currently stored at other DOE sites may also be included in this initiative. The 

project objectives are: to modify the Building 3019 Complex facilities to accommodate the 

necessary process equipment and operations; to process, downblend, and package the U-233 

inventory for final disposal; to transport the downblended material to a licensed disposal facility; 

and to place the Building 3019 Complex in safe and stable shutdown for eventual decontamination 

and decommissioning (D&D). DOE has determined that there is no programmatic use for the U-233 

inventory stored at ORNL. 

DOE action is needed to: (1) address safeguards and security requirements; (2) eliminate long-term 

worker safety and criticality concerns; and (3) provide for final disposal of the U-233 inventory. 

Once the planned DOE actions have been completed, substantial landlord costs would be eliminated, 

and the U-233 safe storage requirements identified by the Defense Nuclear Facilities Safety Board 

(DNFSB) Recommendation 97-1 would be satisfied. Recommendation 97-1 describes actions that 

the DNFSB considers necessary to ensure the safe storage of U-233 materials in the interim and the 

longer term. 

The EA was issued for public comment in September 2009 and was revised as appropriate based on 

public comments. The EA was issued final in December 2009. Based on the results of the analyses 

reported in the Final EA, DOE has determined that the proposed action is not a major federal action 

that would significantly affect the quality of the human environment within the context of the 

National Environmental Policy Act (NEPA) of 1969. Therefore, the preparation of an 

Environmental Impact Statement (EIS) is not required, and DOE is issuing this FONSI. 

PUBLIC AVAILABILITY OF EA AND FONSI: The EA and FONSI may be reviewed at and 

copies of the documents obtained from: 

U.S. Department of Energy 

Information Center 

475 Oak Ridge Turnpike 

Oak Ridge, Tennessee 37830 

Phone: (865) 241-4780 

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INFORMATION ON THE NEPA PROCESS: For further information on the NEPA process, 

contact: 

Gary S. Hartman 

NEPA Compliance Officer 

U.S. Department of Energy 

P.O. Box 2001, SE-30-1 

Oak Ridge, Tennessee 37831 

Phone: (865) 576-0273 

BACKGROUND: Recommendation 97-1 describes actions that the DNFSB considers necessary 

to ensure the safe storage of U-233 bearing material in the interim and the longer term. In 

response to Recommendation 97-1, DOE first initiated an inspection program to evaluate the 

integrity of the U-233 storage canisters. DOE then prepared and issued an EA (DOE/EA-1488) 

in 2004 on its proposal to process the U-233 material. DOE issued a FONSI for that project in 

December 2004. 

In November 2005, Congress directed the termination of the planned medical isotope production 

project, which had been included in the proposed action evaluated in DOE/EA-1488, and the 

transfer of the project from the Office of Nuclear Energy to the Office of Environmental 

Management for disposition of the U-233. In response, DOE modified the original scope and 

prepared a new EA to evaluate the impacts associated with (1) the installation of new process 

equipment in Building 3019; (2) processing, packaging, and on-site interim storage of the U-233 

material; and (3) placement of the Building 3019 Complex in safe and stable shutdown for 

eventual D&D. The EA (DOE/EA-1574) was issued for public comment, revised as appropriate 

based on public comments and was issued as final in February 2007. DOE issued a FONSI for 

these activities in March 2007. 

Since that time, DOE has researched historical documents and has determined that the majority 

of the U-233 inventory can be processed to a matrix which meets the waste acceptance criteria 

for disposal at the Nevada Test Site (NTS). This determination resulted in a process design 

change to render the U-233 material in the form of stable uranium salt monoliths (Annex 

Option). The NTS determination has also allowed for the consideration of an option to process 

and package downblended U-233 material at the Transuranic Waste Processing Center (TWPC) at 

ORNL (TWPC Option). The waste form produced by the TWPC Option would be cementitious 

grout monoliths. If the TWPC Option is selected, the annex facility as currently conceptualized 

will not be constructed. The impacts associated with both options are evaluated in the EA. 

Additionally, DOE plans to dismantle the current 3020 Stack and replace it with a new emissions 

stack to support the Building 3019 Complex operations. 

NEED FOR THE PROPOSED ACTION: DOE action is needed to: (1) satisfy the 

requirements of DNFSB Recommendation 97-1; (2) address safeguards and security 

requirements, (3) eliminate long-term worker safety and criticality concerns; and (4) provide for 

final disposal of the U-233 inventory. 

DESCRIPTION OF PROPOSED ACTION: DOE proposes to: (1) modify the existing facility 

to accommodate new process equipment and support operations; (2) process and package the 

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U-233 stored at ORNL and other small quantities of similar material currently stored at other DOE 

sites; (3) transport the processed material to a disposal facility; and (4) place the Building 3019 

Complex in safe and stable shutdown for eventual D&D. Isotek Systems, LLC, located in Oak 

Ridge, Tennessee, was awarded the U-233 disposition contract by DOE on October 9, 2003. 

Several activities would be required to disposition the U-233 and prepare the Building 3019 

Complex for eventual D&D. These activities are as follows: 

• Transport depleted uranium oxide (DUO) from the DOE Savannah River Site; convert this 

material into depleted uranyl nitrate (DUN) form at a facility located in Erwin, Tennessee; 

and receive DUN at Building 3019A; 

• Demolish the 3020 Stack and construct a replacement stack; 

• Remove equipment from hot cells and laboratories within Building 3019A; 

• Modify Building 3019A to enable dissolution and downblend of the U-233 material; 

• Annex Option: Construct an annex facility to dry and package the downblended material; 

• TWPC Option: Modify piping systems and storage facilities necessary to process 

downblended material at the TWPC; 

• Retrieve and inspect the U-233 containers within Building 3019A; 

• Dissolve and downblend the U-233 inventory; 

• Dry and package the downblended material and package the material in containers suitable 

for transportation and disposal; 

• Transport the downblended inventory to a suitable disposal facility such as NTS; 

• Dispose secondary waste; and 

• Stabilize the Building 3019 Complex in preparation for shutdown and eventual D&D. 

Isotek Systems, LLC would be responsible for design and construction of modifications to 

Building 3019A and its associated facilities in order to implement the proposed action for DOE. 

Building 3019A would be modified and shielded workstations installed to facilitate highradiation work. Criticality safety controls would be in place to prevent an inadvertent nuclear 

criticality. 

ALTERNATIVES: In addition to the proposed action, impacts were evaluated for the no action 

alternative. If no action were taken, DOE would continue to have responsibility for the operation 

of the Building 3019 Complex, and the ORNL inventory of U-233 would remain stored within 

Building 3019A. Continued storage in Building 3019A would require major capital upgrades and 

retrofits to critical facility systems that have nearly reached the end of their effective design life, 

have deteriorated beyond cost-effective repair, or may not satisfy current standards. Significant 

annual costs would be incurred to operate the 3019A facility to handle and repackage about 400 

containers to satisfy current DOE storage standards, and to provide continued protection against 

potential nuclear criticality accidents or theft of the material. 

DOE dismissed from further analysis alternatives based on continued storage of the U-233 

inventory at another location; the use of the material as a tag for Russian highly enriched 

uranium; development and test of a thorium fuel cycle; and use of the material in analytical 

safeguard procedures. DOE also dismissed the option to co-process the U-233 inventory with 

TRU waste and chemical dilution at the Savannah River Site. These alternatives were considered 

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but determined not to be reasonable as they fail to fully address the DOE purpose and need. DOE 

is aware there may be a need for small quantities of U-233 and would continue to cooperate with 

potential users for the safe transfer of material. 

ENVIRONMENTAL IMPACTS: The EA assesses direct and indirect impacts of the proposed 

action on the following: land use, infrastructure, air quality, noise quality, geology and soils, 

water resources, ecological resources, cultural resources, socioeconomics, visual resources, waste 

management, human health, transportation, and accidents. Cumulative impacts were also 

assessed. 

Under the proposed action, there would be no impact on land use immediately around the 

Building 3019 Complex. This area is currently used for industrial purposes and is part of the 

industrialized portion of ORNL. There would be no impact to undisturbed land (in the vicinity of 

the TWPC) if the TWPC Option is implemented. Interim storage of the downblended inventory 

would be temporary and would occur within the Building 3019 Complex. Off-site disposal 

would only occur at suitably permitted/licensed facilities. Previously disturbed areas outside of 

ORNL may be temporarily used as construction laydown areas and are not expected to exceed 

two acres in size; there would be no significant impact on land use at these locations. 

Construction requirements would include around 725 cubic yards of concrete and 28 tons of 

steel. These are small quantities for an industrial construction project and could easily be 

provided by local suppliers without prior notification. Construction would also require modest 

quantities of water, electrical power, diesel fuel, and propane; however, these modest demands 

on infrastructure would pose effectively no impact on ORNL infrastructure. 

Under the proposed action there would be insignificant air quality impacts. Emission levels from 

construction activities and vehicle/equipment operation would be very small compared to other 

emissions sources at ORNL, and the impact of these emissions would be small and temporary. 

Process emissions generated by the proposed action would pass through a charcoal filtration 

system and HEPA filtration system before discharge. The downblended inventory would be 

placed in containers equipped with a vent and HEPA filter to eliminate any pressure build-up, 

and technology to address the formation of radon-220 such as decay tubes, activated carbon 

filtration, or other suitable technology. 

These containers would be placed inside robust over-pack containers to reduce the exposures to 

workers and provide secondary containment in the case of an accident. The estimated annual 

radiological emissions from the proposed action represent less than 0.2 percent of the 

radiological stack emissions at ORNL for year 2008. The radiological exposure to workers in all 

occupied on-site buildings would be less than 1.0 mrem per year and the radiological exposure to 

the off-site maximally exposed individual (member of the public) would not exceed 0.3 mrem 

per year. Isotek Systems, LLC would be required to maintain compliance with the terms and 

conditions of permits issued by the Tennessee Department of Environment and Conservation. 

Safe shutdown of the Building 3019 Complex would also reduce air emissions and have a 

positive long-term effect on air quality in the vicinity of ORNL. 

The highest daily noise levels generated by the project would be produced during construction of 

the annex and replacement stack. Because the Building 3019 Complex is located within an active 

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industrialized area of ORNL and since no sensitive noise receptors are located in the immediate 

vicinity, no adverse noise impacts would occur. 

Under the proposed action, no effects to geological resources would occur and soil disturbances 

would be temporary and occur within previously disturbed areas used for industrial applications. 

Standard soil retention and erosion practices would be applied throughout the construction 

process to minimize or eliminate soil destruction caused by erosion and surface water run-off. 

The Building 3019 Complex and TWPC areas consist of primarily impervious surfaces that 

would not be appreciably altered. The present stormwater collection systems in these areas 

would continue to collect runoff from the project areas, and no new stormwater facilities would 

be required. Stormwater discharges would be controlled, if necessary, to remove soil and any 

contaminants before discharge to storm drains or surface waters. Concentrations of toxic and 

conventional pollutants and radionuclides would be expected to remain within current permit 

limits. The proposed action would not draw from or discharge to groundwater sources and would 

therefore have no impact on groundwater resources. The safe and secure shutdown of the 

Building 3019 Complex at the completion of the proposed action would not substantially change 

the amount of stormwater runoff generated and discharged, but would reduce the potential for a 

spill or release of contaminants into the stormwater collection system, which would be a net 

positive benefit. The proposed action would not result in any adverse impacts to ecological 

resources. Habitat in the vicinity of the Building 3019 Complex and TWPC is highly disturbed 

and mostly maintained by lawn equipment. This type of habitat also precludes the presence of 

rare, threatened, and endangered plant and animal species. 

Building 3019A contributes to the ORNL Historic District and is eligible for listing in the 

National Register of Historic Places. DOE completed a Project Summary and Archaeological 

and Historical Review for the proposed modifications to the facility and determined that the 

proposed action would not have an adverse effect on the exterior physical structure or visual 

appearance of the building. As a result, DOE determined that no exterior archeological resources 

would be adversely affected by the proposed action. The Tennessee State Historic Preservation 

Officer has concurred with the DOE determination. In addition, the proposed action would have 

no adverse impacts on the adjacent Graphite Reactor which is designated as a National Historic 

Landmark. Implementation of the TWPC Option would have no impact on cultural resources. 

Socioeconomic impacts are expected to be positive but small. Based on the small number of jobs 

created and the availability of qualified local workers, no impact on population size is 

anticipated. Likewise, no adverse health and environmental impacts would occur that could have 

a disproportionate effect on low-income or minority populations. Net jobs lost upon the 

completion of the project would have a negligible employment and income impact in the region. 

Visual impacts associated with construction activities at the Building 3019 Complex would 

include construction materials and equipment and additional traffic from construction workers 

and material deliveries. These impacts would be minor, temporary, and consistent with those of 

an industrial area. Other visual impacts would be posed by construction of the 3166 Stack and 

the 3019 Annex. The 3166 Stack would be shorter and less prominent to the skyline than the 

3020 Stack and the 3019 Annex would occupy the area occupied by two other buildings recently 

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removed; therefore, these changes would pose no appreciable difference in appearance to the 

area. Implementation of the TWPC Option would have no impact on visual resources. 

The proposed action would generate primary and secondary wastes. Primary waste generated 

would include low-level waste (LLW) in the form of a dry monolithic uranium salt and liquid 

LLW (LLLW). The total volume of primary LLW waste is estimated at 3,667 55-gallon drums to 

be disposed of at NTS. If the TWPC Option is selected, the primary waste form would differ and 

may potentially result in a slightly larger primary waste volume over the Annex Option. The 

environmental impacts of the increased primary waste volume are expected to be roughly 

equivalent to the Annex Option. An estimated 211 gallons of LLLW condensate per week would 

be discharged to the ORNL LLLW treatment facility. Secondary wastes would be generated by 

construction and facility modifications associated with the proposed action and would generate 

an estimated 30,000 cubic feet of LLW mainly in the form of scrap metal, debris, and concrete. 

This material would be packaged and sent to NTS or other approved facility for disposal. 

Uncontaminated debris generated from project activities would be sent to a local construction 

and demolition waste landfill for disposal. Solid, secondary waste materials would also be 

generated by the downblending and drying processes. These materials would include items such 

as U-233 package waste, hot cell debris waste, empty cans, failed equipment and components, 

decontamination waste, gas filtration media, personal protective equipment, maintenance waste, 

and DUO not consumed by the project. Small volumes of RCRA hazardous waste could be 

generated by laboratory activities. Small volumes of PCB waste could be generated from old 

paint/coatings and light ballasts during dismantlement activities. Secondary waste materials 

would be packaged in Type A containers and transported off-site to a licensed disposal facility. 

The volume of waste materials generated by construction, facility modifications, and process 

operations would be minimized through Best Management Practices and project waste 

management procedures. Local and off-site treatment and disposal facilities anticipated to be 

used have adequate capacity to accommodate all forms of waste generated by the proposed 

action. Waste management impacts would be small. 

The proposed action would result in potential radiological and chemical exposure to workers and 

the public. Radiological worker exposures would vary by activity and by location within the 

Building 3019 Complex or the TWPC. As specified in the Isotek Radiation Protection Program 

Plan, the dose to each worker would be expected to remain below 500 mrem per year. This goal 

would be achieved through a combination of facility design features (radiation shields) and 

administrative controls (limited worker exposure times). Radiological emissions from 

downblending and drying operations would be filtered and exhausted such that radiological 

exposure to any member of the public would be expected to be no greater than 0.3 mrem. If the 

TWPC Option is selected, emissions systems would be modified to address emissions specific to 

the downblended U-233 material; after modification, radiological emissions are expected to be 

similar to historical levels at the TWPC. Radiological emissions from the Building 3019 

Complex are expected to cease after the downblend operations are completed and D&D activities 

have been completed. Bulk chemicals used would include DUN, nitric acid, sodium hydroxide, 

iron sulfate, and magnesium hydroxide. Under normal operations, these chemicals would be 

confined within closed tanks and pipelines, and any chemical exhaust fumes would be captured 

in the ventilation system, HEPA filtered, exhausted out the 3166 Stack, and dispersed in the 

atmosphere. Project health and safety procedures would govern the receipt, storage, and use of 

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