DOE/EA-1651 

Final 

Environmental Assessment for U-233 Material Downblending and 

Disposition Project at the Oak Ridge National Laboratory 

Oak Ridge, Tennessee 

U. S. Department of Energy 

Oak Ridge Office 

Oak Ridge, Tennessee 

January 2010 

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 

- 1 -
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 

- 2 -
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 

- 3 -
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 

- 4 -
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 

- 5 -
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 

- 6 -


DOE/EA-1651 

FINAL 

Environmental Assessment for U-233 Material Downblending and 

Disposition Project at Oak Ridge National Laboratory 

Oak Ridge, Tennessee 

Date Issued-January 2010 

Prepared for the 

U.S. Department of Energy 

Office of Environmental Management 

Isotek Systems, LLC 

Under Contract DE-AC05-04OR22860 

for the 

U.S. DEPARTMENT OF ENERGY

U-233 Material Downblending and Disposition Environmental Assessment 

i 

TABLE OF CONTENTS 

LIST OF TABLES......................................................................................................................... iv 

LIST OF FIGURES ....................................................................................................................... iv 

ACRONYMS...................................................................................................................................v 

1.0 INTRODUCTION AND PURPOSE AND NEED.......................................................... 1-1 

1.1 Introduction.......................................................................................................... 1-1 

1.2 Background/Overview ......................................................................................... 1-1 

1.2.1 Project History and Status........................................................................ 1-1 

1.2.2 Building 3019 Complex........................................................................... 1-2 

1.2.3 U-233 Inventory Description ................................................................... 1-3 

1.2.4 Savannah River Site Depleted Uranium Oxide ....................................... 1-4 

1.3 Purpose and Need for Proposed Action............................................................... 1-4 

1.4 Scope of this Environmental Assessment ............................................................ 1-4 

1.5 Relationship to Other Regulatory Activities........................................................ 1-6 

1.6 Public Involvement .............................................................................................. 1-7 

1.7 Organization of Environmental Assessment........................................................ 1-7 

2.0 PROPOSED ACTION AND ALTERNATIVES ............................................................ 2-1 

2.1 No Action Alternative.......................................................................................... 2-1 

2.2 Proposed Action Alternative................................................................................ 2-1 

2.2.1 Demolition, Construction, and Equipment Installation ........................... 2-1 

2.2.2 Transport of DUO from SRS to Oak Ridge, TN ..................................... 2-4 

2.2.3 Temporary Storage of DUO at a Storage Facility in Oak Ridge, TN...... 2-4 

2.2.4 Transport of DUO from Oak Ridge to NFS............................................. 2-4 

2.2.5 Transport of DUN from NFS to ORNL................................................... 2-4 

2.2.6 Perform U-233 Downblend Activities in the Building 3019 

Complex................................................................................................... 2-5 

2.2.7 Dry, Package, and Prepare Downblended Material for Off-site 

Transport.................................................................................................. 2-5 

2.2.8 Transport Downblended Material to a Licensed Disposal Facility ......... 2-8 

2.2.9 Disposition of Secondary Waste.............................................................. 2-8 

2.2.10 Facility Shutdown, Surveillance, and Maintenance................................. 2-8 

2.3 Alternatives Considered But Eliminated From Detailed Consideration.............. 2-9 

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS ....................... 3-1 

3.1 Introduction.......................................................................................................... 3-1 

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

3.2.1 Affected Environment.............................................................................. 3-1 

3.2.2 No Action Alternative.............................................................................. 3-1 

3.2.3 Proposed Action Alternative.................................................................... 3-2 
U-233 Material Downblending and Disposition Environmental Assessment 

ii 

TABLE OF CONTENTS (continued) 

3.3 Infrastructure........................................................................................................ 3-2 

3.3.1 Affected Environment.............................................................................. 3-2 

3.3.2 No Action Alternative.............................................................................. 3-3 

3.3.3 Proposed Action Alternative.................................................................... 3-3 

3.4 Air Quality ........................................................................................................... 3-4 

3.4.1 Affected Environment.............................................................................. 3-4 

3.4.2 No Action Alternative.............................................................................. 3-5 

3.4.3 Proposed Action Alternative.................................................................... 3-6 

3.5 Noise .................................................................................................................... 3-8 

3.5.1 Affected Environment.............................................................................. 3-8 

3.5.2 No Action Alternative.............................................................................. 3-9 

3.5.3 Proposed Action Alternative.................................................................... 3-9 

3.6 Geology and Soils.............................................................................................. 3-10 

3.6.1 Affected Environment............................................................................ 3-10 

3.6.2 No Action Alternative............................................................................ 3-10 

3.6.3 Proposed Action Alternative.................................................................. 3-11 

3.7 Water Resources ................................................................................................ 3-11 

3.7.1 Affected Environment............................................................................ 3-11 

3.7.2 No Action Alternative............................................................................ 3-12 

3.7.3 Proposed Action Alternative.................................................................. 3-12 

3.8 Ecological Resources......................................................................................... 3-13 

3.8.1 Affected Environment............................................................................ 3-13 

3.8.2 No Action Alternative............................................................................ 3-13 

3.8.3 Proposed Action Alternative.................................................................. 3-13 

3.9 Cultural Resources............................................................................................. 3-13 

3.9.1 Affected Environment............................................................................ 3-13 

3.9.2 No Action Alternative............................................................................ 3-14 

3.9.3 Proposed Action Alternative.................................................................. 3-14 

3.10 Socioeconomics ................................................................................................. 3-15 

3.10.1 Affected Environment............................................................................ 3-15 

3.10.2 No Action Alternative............................................................................ 3-19 

3.10.3 Proposed Action Alternative.................................................................. 3-19 

3.11 Visual Resources................................................................................................ 3-21 

3.11.1 Affected Environment............................................................................ 3-21 

3.11.2 No Action Alternative............................................................................ 3-21 

3.11.3 Proposed Action Alternative.................................................................. 3-22 

3.12 Waste Generation and Management .................................................................. 3-22 

3.12.1 Affected Environment............................................................................ 3-22 

3.12.2 No Action Alternative............................................................................ 3-23 

3.12.3 Proposed Action Alternative.................................................................. 3-23 

3.13 Human Health .................................................................................................... 3-25 

3.13.1 Affected Environment............................................................................ 3-25 

3.13.2 No Action Alternative............................................................................ 3-26 

3.13.3 Proposed Action Alternative.................................................................. 3-28 
U-233 Material Downblending and Disposition Environmental Assessment 

iii 

TABLE OF CONTENTS (continued) 

3.14 Transportation.................................................................................................... 3-29 

3.14.1 Affected Environment............................................................................ 3-29 

3.14.2 No Action Alternative............................................................................ 3-30 

3.14.3 Proposed Action Alternative.................................................................. 3-30 

3.15 Accidents............................................................................................................ 3-33 

3.15.1 Affected Environment............................................................................ 3-33 

3.15.2 No Action Alternative............................................................................ 3-33 

3.15.3 Proposed Action Alternative.................................................................. 3-33 

4.0 CUMULATIVE IMPACTS............................................................................................. 4-1 

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

4.2 Current and Planned Industrial Activities in the Region ..................................... 4-1 

4.3 Cumulative Assessment....................................................................................... 4-2 

4.3.1 Land Use .................................................................................................. 4-2 

4.3.2 Infrastructure............................................................................................ 4-2 

4.3.3 Air Quality ............................................................................................... 4-2 

4.3.4 Socioeconomics ....................................................................................... 4-2 

4.3.5 Transportation.......................................................................................... 4-3 

4.3.6 Waste Management.................................................................................. 4-3 

4.3.7 Human Health .......................................................................................... 4-3 

4.4 Cumulative Impacts Summary............................................................................. 4-4 

5.0 PERMITS AND ENVIRONMENTAL REGULATION................................................. 5-1 

5.1 Permits ................................................................................................................. 5-1

5.2 Environmental Regulation ................................................................................... 5-1 

6.0 AGENCIES CONTACTED............................................................................................. 6-1 

7.0 REFERENCES ................................................................................................................ 7-1 

APPENDIX A - SHPO Letter 1

APPENDIX B - SHPO Letter 2 

APPENDIX C – Public Comment Response Table 
U-233 Material Downblending and Disposition Environmental Assessment 

iv 

LIST OF TABLES 

Table 2.2-1 Main Activities Included in the U-233 Project.................................................... 2-2 

Table 3.4-1 Anticipated Radiological Emissions from the 3166 Stack .................................. 3-7 

Table 3.10-1 Demographic and Economic Characteristics in the ROI ................................... 3-17 

Table 3.10-2 Housing Characteristics for the ROI, Year 2000............................................... 3-18 

LIST OF FIGURES 

Figure 1.2-1 Location of ORNL on the ORR........................................................................... 1-3 

Figure 1.2-2 Building 3019 Complex....................................................................................... 1-4 

Figure 2.2-1 Proposed Site Plan for the Building 3019 Complex ............................................ 2-3 

Figure 2.2-2 Conceptual U-233 Project Downblend Process................................................... 2-6 

Figure 3.10-1 Location of Oak Ridge Reservation and Regional Counties. ............................ 3-16 
U-233 Material Downblending and Disposition Environmental Assessment 

v 

ACRONYMS 

AERMOD American Meteorological Society/Environmental Protection Agency 

Regulatory Model 

ALARA as low as reasonably achievable 

BJC Bechtel Jacobs LLC 

BLM Bureau of Land Management 

CAA Clean Air Act 

CAP88 Clear Air Act Assessment Package 1988

CEQ Council on Environmental Quality 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

cfm cubic feet per minute 

CFR Code of Federal Regulations 

COG Cell off-gas 

CRK Clinch River kilometer 

D&D Decontamination and Decommissioning 

dBA A-weighted decibels 

DNFSB Defense Nuclear Facilities Safety Board 

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation 

DUN depleted uranyl nitrate 

DUO depleted uranium oxide 

EA environmental assessment 

EAD Environmental Assessment Determination 

EDE effective dose equivalent 

EM Environmental Management 

EIS Environmental Impact Statement 

EPA U.S. Environmental Protection Agency 

FeSO4 iron sulfate 

FONSI Finding of No Significant Impact 

FBI Federal Bureau of Investigation 

FTE full time equivalent 

FY Fiscal Year 

GBOG Glovebox off-gas 

GC-1 Process to combine depleted uranyl nitrate with U-233 

GC-2 Process to dry and package product from GC-1 

HEPA high efficiency particulate air 

HQ hazard quotient 

IES Institute of Education Sciences 

IFDP Integrated Facility Disposition Project 

I/I intake/chronic daily intake ratio 

kg kilograms 

KOH potassium hydroxide 

LCF latent cancer fatality 

LLC Limited Liability Corporation 

LLLW liquid low-level waste 
U-233 Material Downblending and Disposition Environmental Assessment 

vi 

LLW low-level waste 

LOG Laboratory off-gas 

Mg(OH)2 magnesium hydroxide 

MSC Manufacturing Sciences Corporation 

MVSTs Melton Valley Storage Tanks 

NAAQS National Ambient Air Quality Standards 

NaOH sodium hydroxide 

NEPA National Environmental Policy Act 

NESHAP national emission standards for hazardous air pollutants 

NFS Nuclear Fuel Services 

NRC Nuclear Regulatory Commission 

NRHP National Register of Historic Places 

NPDES National Pollutant Discharge Elimination System 

NTS Nevada Test Site 

ORNL Oak Ridge National Laboratory 

ORO Oak Ridge Operations 

ORR Oak Ridge Reservation 

OSHA Occupational Safety and Health Administration 

PCB polychlorinated biphenyl 

PCs performance categories 

PPE Personnel Protective Equipment 

RADTRAN RADTRAN, Transportation Risk Assessment Computer Code 

RCRA Resource Conservation and Recovery Act 

ROI Region of Influence 

SHPO State Historic Preservation Office 

SR State Route 

SRS Savannah River Site 

TCRA time-critical removal action 

TDEC Tennessee Department of Environment and Conservation 

TRAGIS Transportation Routing Analysis Geographic Information System 

TRU transuranic 

TSCA Toxic Substances Control Act 

TWPC Transuranic Waste Processing Center 

U-233 Project U-233 Material Downblending and Disposition Project 

U-233 uranium-233 

U-235 uranium-235 

USCB United States Census Bureau 

USFA United States Fire Association 

VOG Vessel off-gas 

VRM Visual Resource Management 

WIPP Waste Isolation Pilot Plant 
U-233 Material Downblending and Disposition Environmental Assessment 

1-1 

1.0 INTRODUCTION AND PURPOSE AND NEED 

1.1 INTRODUCTION

Uranium-233 (U-233) is a special nuclear material currently stored at the Oak Ridge National 

Laboratory (ORNL) in the Building 3019 Complex. Special nuclear material is defined by Title I 

of the Atomic Energy Act of 1954 (USC 1954) as plutonium, U-233, or uranium enriched in the 

isotopes of U-233 or uranium-235 (U-235). These materials are radioactive, fissile, and can be 

formed into nuclear weapons. In powder form, these materials can pose a serious health hazard. 

The U-233 Material Downblending and Disposition Project (U-233 Project) was developed by 

the U.S. Department of Energy (DOE) to resolve security and safety issues associated with the 

U-233 inventory and its storage facility; specifically, the safety issues identified by the Defense 

Nuclear Facilities Safety Board (DNFSB) in Recommendation 97-1, Safe Storage of U-233 

(DNFSB 1997). The main actions to be performed by the U-233 Project are to: 

• Process, downblend, and package the DOE inventory of U-233 (and the 715 gallons of 

U-233-contaminated thorium nitrate stored in Tank P-24) to eliminate the need for 

safeguards, security, and nuclear criticality controls, and render these materials suitable 

for safe disposition 

• Remove the U-233 material from the Building 3019 Complex 

• Transport the downblended material to one or more licensed disposal facilities 

• Place the Building 3019 Complex in safe and stable shutdown condition 

To evaluate the potential environmental impacts associated with the U-233 Project, DOE 

prepared two environmental assessments (EAs) (see Section 1.2.1). An Environmental 

Assessment Determination (EAD 2008-0004) issued by DOE on January 23, 2009, states that 

preparation of an additional EA is necessary to assess potential environmental impacts associated 

with proposed operational changes and facility modifications (DOE 2008a). 

1.2 BACKGROUND/OVERVIEW

1.2.1 Project History and Status 

In response to DNFSB Recommendation 97-1, DOE formulated a three-phase programmatic 

plan to satisfy the DNFSB recommendations. Phase I encompasses preliminary planning and 

design activities; Phase II would involve project execution; and Phase III would include the 

shutdown of the Building 3019 Complex for eventual Decontamination and Decommissioning 

(D&D). 

In the initial Phase I plan, DOE proposed a U-233 Project that would operate an ion-exchange 

process to separate Thorium-229 from the U-233 stockpile for medical use; downblend the 

U-233 material with depleted uranyl nitrate (DUN); transport the downblended material to an 

ORNL storage facility; and place the Building 3019 in a safe and stable shutdown condition. The 

initial project plan and associated impacts are detailed in DOE/EA-1488 and are not repeated 

here (DOE 2004). 
U-233 Material Downblending and Disposition Environmental Assessment 

1-2 

In the November 2005 Conference Report for the Energy and Water Development and Related 

Agencies Appropriations Act for Fiscal Year (FY) 2006, the conferees provided no funding for 

the Medical Isotope Production and Building 3019 Complex Shutdown project. The conferees 

action directed DOE to terminate promptly the Medical Isotope Production and Building 3019 

Complex Shutdown project. Per DOE’s recommendation, the responsibility for disposition of the 

U-233 was transferred to the DOE Environmental Management (EM) program. The conferees 

provided FY 2006 funds in the Defense EM appropriation for disposition of the material stored 

in the Building 3019 Complex and directed the Department to provide a report within 60 days 

detailing a path forward for managing the material. The Department issued its report to Congress 

in February 2006 (“Management of U-233 Stored at Building 3019, Oak Ridge National 

Laboratory, Oak Ridge, Tennessee, Preliminary Report to Congress,” dated February 8, 2006, to 

The Honorable Pete V. Domenici, et al.) (DOE 2007). 

Before implementation of the revised project plan, the scope of activities for the U-233 Project 

was again revised. Based on the present scope of the U-233 Project, some project activities fall 

under the aegis of the Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA). Consistent with the Secretarial Policy Statement on the National Environmental 

Policy Act, DOE’s process for review of actions under CERCLA addresses NEPA values 

(DOE 1994). Separate NEPA analysis is applied for activities not covered under the aegis of 

CERCLA. 

CERCLA actions include the demolition of the Buildings 3074, 3136, and the 3020 Stack 

(DOE 2009a). Non-CERCLA actions include the balance of activities associated with the U-233 

Project. Some or all of the CERCLA actions would likely occur before the non-CERCLA actions 

are implemented. The scope of the subject CERCLA and non-CERCLA activities is described in 

Chapter 2 of this EA. 

1.2.2 Building 3019 Complex 

ORNL is located in south-central region of the Oak Ridge Reservation (ORR) in East Tennessee 

as shown in Figure 1.2-1. The Building 3019 Complex, located in Bethel Valley in the northcentral area of ORNL, consists of a main building, several support facilities, grounds defined by 

a perimeter fence, and access driveways as shown in Figure 1.2-2. Building 3019 is the main 

building in the Building 3019 Complex. The western portion of this building is designated as 

3019B, and the eastern portion is designated as 3019A. Building 3019A was originally 

constructed in 1943 as a chemical separations pilot plant for the Manhattan Project. Because of 

its historical significance, Building 3019 is eligible for listing on the National Register of 

Historic Places (NRHP). Although the majority of the Building 3019 Complex support facilities 

would not be required to process the U-233 inventory, ancillary equipment such as ventilation 

systems and stacks that support the entire Building 3019 Complex would continue to be shared 

consistent with their intended purpose. DOE/EA-1574 contains additional information about the 

Building 3019 Complex. (DOE 2007) 
U-233 Material Downblending and Disposition Environmental Assessment 

1-3 

1.2.3 U-233 Inventory Description 

The ORNL inventory consists of about 450 kilograms (kg) of U-233 in about 1,000 canisters in 

various forms, quantities, and matrices. The U-233 inventory at the Building 3019 Complex is 

primarily in the form of uranium oxides but also includes metals and other compounds. 

DOE/EA-1488 (DOE 2004) and DOE/EA-1574 (DOE 2007) give additional information on the 

U-233 inventory at ORNL. 

In addition to the ORNL inventory of U-233, as much as 50 kg of U-233 stored at other DOE 

facilities may be processed along with the ORNL inventory as part of the U-233 Project. This 

EA, therefore, considers a U-233 inventory of 500 kg. 

Figure 1.2-1—Location of ORNL on the ORR 

Source: ORNL 2008 
U-233 Material Downblending and Disposition Environmental Assessment 

1-4 

Figure 1.2-2—Building 3019 Complex 

Source: DOE 2007 

1.2.4 Savannah River Site Depleted Uranium Oxide 

The downblend process would use depleted uranium oxide (DUO) that is currently stored at the 

Savannah River Site (SRS), near Aiken, South Carolina. This material is in the form of uranium 

trioxide. To perform the proposed downblend activities, around 805 drums of DUO would be 

transported to Oak Ridge for temporary interim storage until needed. Provisions of the American 

Recovery and Reinvestment Act of 2009 provide SRS a financial incentive to transfer the 

material within a limited time window. The potential environmental impacts associated with the 

transport of the DUO from SRS were previously addressed in DOE/EA-1393 (DOE 2002a). 

Evaluation of these transportation activities is incorporated by reference. 

1.3 PURPOSE AND NEED FOR PROPOSED ACTION

Continued storage of U-233 in the Building 3019 Complex at ORNL in its present form and 

present containers represents a significant safety, safeguards and security, and financial burden 

(DOE 2007). As there are no facilities licensed and/or permitted to accept the U-233 in its 

present form, isotopic downblend has been selected as the preferred method to satisfy the 

nonproliferation and safety issues associated with this material, consistent with the DNFSB 97-1 

recommendations (DOE 2009b). As described in Section 1.4, this EA evaluates the impacts on 

the human environment of the additional actions not already evaluated in DOE/EA-1488 

(DOE 2004), DOE/EA-1574 (DOE 2007), and the CERCLA process. 

1.4 SCOPE OF THIS ENVIRONMENTAL ASSESSMENT

This EA assesses the potential consequences of non-CERCLA project activities on the human 

environment in accordance with the Council on Environmental Quality (CEQ) regulations 
U-233 Material Downblending and Disposition Environmental Assessment 

1-5 

(40 Code of Federal Regulations [CFR] Parts 1500 – 1508) for National Environmental Policy 

Act (NEPA) implementation and with DOE NEPA Implementation Procedures (10 CFR 1021). 

If the impacts associated with the proposed action are not identified as significant as a result of 

this EA, DOE shall issue a Finding of No Significant Impact (FONSI) and would proceed with 

the action. If impacts are identified as potentially significant, an Environmental Impact Statement 

(EIS) would be prepared. 

This EA: (1) describes the affected environment relevant to potential impacts of the proposed 

operational changes and facility modifications to the U-233 Project; (2) analyzes potential 

environmental impacts that could result from the proposed operational changes and facility 

modifications to the U-233 Project; (3) identifies and characterizes cumulative impacts that could 

result from the proposed operational changes and facility modifications to the U-233 Project in 

relation to other current or proposed activities within the area; and (4) provides DOE with 

environmental information to prescribe restrictions to protect, preserve, and enhance the human 

environment and natural ecosystems. 

To follow the analysis presented herein, it is important to understand the distinction between the 

scope of the U-233 Project and the scope of this EA. As described in Section 1.2.1, the U-233 

Project includes (1) actions that fall under the aegis of CERCLA and are evaluated consistent 

with NEPA values and (2) non-CERCLA actions that require separate NEPA evaluation. 

Collectively both the CERCLA actions and the non-CERCLA actions are necessary to fulfill the 

goals of the U-233 Project. 

The potential impacts for actions performed under CERCLA are evaluated separately from this 

EA, and that evaluation is not repeated here. U-233 Project actions that fall under CERCLA 

include the demolition of Building 3074, Building 3136, and the 3020 Stack, as identified in 

DOE/OR/01-2407&D1, Time-Critical Removal Action Memorandum for Buildings 3074 and 

3136, and the 3020 Stack at the Oak Ridge National Laboratory (DOE 2009a). 

The scope of activities evaluated in this EA includes: 

(1) construction of the 3166 Stack to replace the 3020 Stack 

(2) temporary storage of the DUO from SRS at Manufacturing Sciences Corporation (MSC) 

facility, in Oak Ridge, Tennessee 

(3) transport of DUO from Oak Ridge to Nuclear Fuel Services (NFS) in Erwin, Tennessee 

(4) transport of DUN solution from NFS to ORNL 

(5) construction and operation of an annex within the Building 3019 Complex to dry and 

package the downblended material for off-site transport (construction and operation of the 

annex would not occur if the material is transferred to the Transuranic Waste Processing 

Center (TWPC) as described in item 6) 

(6) facility modifications necessary to transfer the downblended material to the TWPC to be 

dried and packaged for off-site transport, in lieu of construction of the above annex 

(7) off-site transport of downblended material and secondary waste to one or more licensed 

disposal facilities 
U-233 Material Downblending and Disposition Environmental Assessment 

1-6 

Two process options are evaluated herein for actions that fall under NEPA. One option involves 

the construction of an annex within the Building 3019 Complex where the downblended material 

would be dried and packaged for off-site transport. The other option involves the transfer of 

aqueous downblended material via underground pipeline to the TWPC at ORNL, where the 

material would then be processed and packaged for off-site transport. 

1.5 RELATIONSHIP TO OTHER REGULATORY ACTIVITIES

To reduce redundancy with previous but relevant documents, CEQ regulations encourage 

Federal agencies to eliminate repetitive discussions and to focus the decision process on the 

pertinent issues “ripe for decisions at each level of environmental review” (40 CFR 1502.20). 

This approach refers to the coverage of general matters in broad-scope documents, with 

subsequent narrower scope documents that incorporate by reference the general discussions and 

concentrate primarily on the specific issues associated with the current proposal (40 CFR 

1508.28). Such an approach entails references to specific analyses, discussions, and conclusions 

of these documents without inclusion of detailed discussion in the present EA. This EA is based, 

in part, on earlier NEPA documentation. 

Consistent with CEQ guidance, the following NEPA studies and associated FONSIs relevant to 

the proposed action of this EA are incorporated by reference: 

• Environmental Assessment for the U-233 Disposition, Medical Isotope Production, and 

Building 3019 Complex Shutdown at the Oak Ridge National Laboratory, Oak Ridge 

Tennessee, DOE/EA-1488 (DOE 2004) 

• Environmental Assessment for U-233 Stabilization, and Building 3019 Complex 

Shutdown at the Oak Ridge National Laboratory, Oak Ridge, Tennessee, DOE/EA-1574

(DOE 2007) 

• Programmatic Environmental Assessment for the U. S. Department of Energy, Oak Ridge 

Operations Implementation of a Comprehensive Management Program for the Storage, 

Transportation, and Disposition of Potentially Reusable Uranium Materials, DOE/EA1393 (DOE 2002a) 

The removal of the 3020 Stack and two other facilities located within the Building 3019 

Complex would be conducted under the authority of a CERCLA time-critical removal action 

(TCRA) Memorandum (DOE 2009a). The NEPA values applied by the CERCLA review process 

provide sufficient NEPA coverage. Environmental analysis of CERCLA actions is therefore 

excluded from this EA. These are separate actions with different regulatory requirements and are 

referenced in this EA to the extent that they influence the facility needs and timing of the actions 

considered in this EA. Cumulative impacts from the Proposed Action and other actions in the 

region are described in Chapter 4. 
U-233 Material Downblending and Disposition Environmental Assessment 

1-7 

1.6 PUBLIC INVOLVEMENT

Public involvement is an integral part of the NEPA process. On December 6, 2006, DOE 

informed stakeholders and posted notice of this proposed action on the DOE Oak Ridge 

Operations (ORO) Information Site. As the U-233 Project has developed, programmatic changes 

have been posted on the ORO Information Site (DOE 2007). On March 25, 2009, DOE notified 

the Tennessee Department of Environment and Conservation (TDEC), the City of Oak Ridge, 

and other stakeholders of proposed changes to the U-233 Project and of its intention to prepare 

this EA. DOE plans to provide stakeholders a copy of the Draft EA for review. After a 30-day 

review and comment period, DOE will address any comments from the review in the Final EA 

and will appended comment response documentation. 

1.7 ORGANIZATION OF ENVIRONMENTAL ASSESSMENT

This EA is organized as follows: 

Chapter 1 – Introduction and Purpose and Need. Presents an overview of the EA, 

summarizes the background information necessary to understand the purpose and need for the 

proposed action, presents additional, relevant NEPA documents, and includes an overview of the 

public involvement process. 

Chapter 2 –Proposed Action and Alternatives. Provides more detailed background 

information on the proposed action and provides a description of the alternatives, including a 

discussion of alternatives that were considered and eliminated from detailed analysis. This 

chapter also identifies the preferred alternative. 

Chapter 3 – Affected Environment and Environmental Impacts. Presents information 

describing the existing environment at ORNL and how the environment might be affected by the 

No Action Alternative and the Proposed Action. Impacts are compared to the environmental 

conditions that would be expected if continuing the status quo (i.e., the No Action Alternative). 

Chapter 4 – Cumulative Impacts. Presents information on other proposed actions (both Federal 

and non-Federal) which could effect the environment both by themselves and in conjunction 

with the actions proposed by this EA. 

Chapter 5 – Permits and Environmental Regulation. Presents a discussion of the permits and 

environmental regulations that apply to the project. 

Chapter 6 – Agencies Contacted. Identifies agencies contacted as part of the EA process. 

Chapter 7 – References. Identifies documents referenced in the text of the EA. 

Appendix A – State Historic Preservation Office (SHPO) Letter 1 

Appendix B – SHPO Letter 2 
U-233 Material Downblending and Disposition Environmental Assessment 

1-8 

Appendix C – Public Comment Response Table 
U-233 Material Downblending and Disposition Environmental Assessment 

2-1 

2.0 PROPOSED ACTION AND ALTERNATIVES 

2.1 NO ACTION ALTERNATIVE

The No Action Alternative has not changed since the issue of DOE/EA-1574 (DOE 2007). 

Under the No Action Alternative, the ORNL inventory of U-233 would remain stored within the 

Building 3019 Complex. Continued storage in the Building 3019 Complex would require major 

capital upgrades and retrofits to critical facility systems that have nearly reached the end of their 

effective design life or have deteriorated beyond cost-effective repair. Significant additional 

operational expenses would also be incurred to repackage about 400 containers to satisfy current 

DOE storage standards for U-233 (DOE 2002a) and to provide protection against potential 

nuclear criticality accidents or theft of the material. Extended storage of the U-233 in the 

Building 3019 Complex would require additional structural and confinement systems upgrades 

with a preliminary estimated cost of $20 million. (DOE 2007) However, no engineering analysis 

of the upgrades has been completed (DOE 2007). 

Under the No Action Alternative, DOE would fail to satisfy a commitment to Congress. On 

February 17, 2006, DOE informed Congress of its intent to safely process and stabilize the 

U-233 inventory stored in Building 3019A (DOE 2007). Because of the fissile content of the 

U-233 material, the material must be processed before final disposition. 

2.2 PROPOSED ACTION ALTERNATIVE

The Proposed Action is to proceed with design and execution of the U-233 Project to achieve 

closure of DNFSB 97-1, to disposition the U-233 inventory, and to facilitate safe shutdown of 

the Building 3019 Complex. The main activities of the Proposed Action are covered under both 

CERCLA and NEPA as shown in Table 2.2-1. CERCLA actions, though part of the Proposed 

Action, are not within the scope of this EA as described in Section 1.4. Similarly, some Proposed 

Action activities have been evaluated in previous EAs and are therefore not evaluated in this EA. 

Additional details for the Proposed Action are given in the subsections below. Chapter 3 

describes the potential environmental impacts for activities within the scope of this EA. 

2.2.1 Demolition, Construction, and Equipment Installation 

As part of the Proposed Action, in April 2009, DOE issued a CERCLA TCRA Memorandum to 

address removal of three structures within the Building 3019 Complex: Building 3074, Building 

3136, and the 3020 Stack (DOE 2009a). Because this removal action is subject to the provisions 

of CERCLA, the impacts of the activities authorized in the TCRA Memorandum are not 

evaluated in this EA. Although the CERCLA activities are not evaluated in this EA, they are a 

necessary part of the Proposed Action for the U-233 Project, and would only be performed to 

support the U-233 Project. 
U-233 Material Downblending and Disposition Environmental Assessment 

2-2 

Table 2.2-1—Main Activities Included in the U-233 Project 

Activity Evaluation 

Remove Buildings 3074 and 3136 and the 3020 Stack CERCLA TCRA 

(DOE/OR/01-2407& 

D1) (DOE 2009a) 

Construct the 3166 Stack to replace the 3020 Stack and perform modifications to the 

Building 3019 Complex as needed to support the planned downblend activities. 

DOE/EA-1651 

(current document) 

Transport DUO from SRS to Oak Ridge, Tennessee DOE/EA-1393 

(DOE 2002a) 

Temporary Interim Storage of DUO at a storage facility in Oak Ridge, Tennessee DOE/EA-1651 

(current document) 

Transport of DUO to NFS in Erwin, TN for conversion to DUN DOE/EA-1651 

(current document) 

Transport of DUN from NFS to the Building 3019 Complex at ORNL DOE/EA-1651 

(current document) 

Perform U-233 Downblend Activities in the Building 3019 Complex DOE/EA-1574 

(DOE 2007) 

Dry, package, and prepare downblended material for off-site transport 

Annex Option: Construct and operate the 3019 Annex facility to dry, package, and 

load the downblended material on a truck for off-site transport to a licensed disposal 

facility 

DOE/EA-1651 

(current document) 

TWPC Option: Perform the modifications to the TWPC as needed to dry, package, 

and load the downblended material on a truck for off-site transport to a licensed 

disposal facility. This would include transfer of the downblended material through an 

extant underground pipeline from the Building 3019 Complex to the TWPC. 

DOE/EA-1651 

(current document) 

Transport the downblended material and secondary waste material via truck to a licensed 

disposal facility, preferably the Nevada Test Site (NTS) or the Waste Isolation Pilot Plant 

(WIPP) 

DOE/EA-1651 

(current document) 

Shutdown of the Building 3019 Complex in safe and stable shutdown condition for 

eventual D&D 

DOE/EA-1574 

(DOE 2007) 

The 3020 Stack is located north of the Building 3019 Complex as illustrated in Figure 1.2-2. The 

3020 Stack was originally constructed in the 1940s to support Building 3019 operations as part 

of the Manhattan Project. The 3020 Stack is a 200 foot masonry structure with an interior brick 

liner and a concrete outer liner. The 3020 Stack has supported emissions from the operations 

conducted within the Building 3019 Complex under Title V Operating Permit issued by TDEC in 

conjunction with the U.S. Environmental Protection Agency (EPA). The 3020 Stack is known to 

be radiologically contaminated due to the nature of emissions and past operational upsets; 

asbestos containing materials and polychlorinated biphenyl (PCB) containing materials may also 

be associated with the stack structure (DOE 2009a). Removal of the 3020 Stack would be 

conducted only after a new permitted stack is built and placed in operation. During removal 

activities, a negative pressure downdraft would be applied to the 3020 Stack and the down 
U-233 Material Downblending and Disposition Environmental Assessment 

2-3 

drafted air would be vented through an air pollution control system and discharged under the 

requirements of an air emissions permit to be issued by TDEC. 

 

A new replacement stack (the 3166 Stack) would be constructed to support the U-233 downblend 

activities. The 3166 Stack would use the existing Cell off-gas (COG), Glovebox off-gas 

(GBOG), and Laboratory off-gas (LOG) ventilation ductwork from Building 3019A and would 

be sited north of Building 3019A as shown in Figure 2.2-1. 

Figure 2.2-1—Proposed Site Plan for the Building 3019 Complex 

Based on preliminary design plans for the Annex Option (construction of the 3019 Annex to dry 

and package the downblended material), the 3166 Stack (1) would have a design flow capacity of 

33,000 to 44,000 cubic feet per minute (cfm) with a minimum discharge velocity of 3,000 feet 

per minute and (2) would be approximately 80 feet tall based on the results of an optimization 

study performed by Isotek (Isotek 2008). The specifications of the 3166 Stack, however, may 

change as the project engineering design is finalized. Additionally, the 3166 Stack parameters 

may be different if the TWPC Option is selected; however, a 3166 Stack analysis has not been 

performed for the TWPC Option. For either option, construction materials and supplies would be 

temporarily staged at construction laydown areas which may be located either inside or outside 

of the ORNL plant boundary. Areas where land has been previously disturbed are the preferred 

locations for construction laydown areas; construction laydown areas are estimated to cover less 

than two acres. 

Hillside Avenue 

3rd Street 

Existing Security Fence 

Proposed Security Fence 

Modification

Proposed Location for 3166 

Stack 
U-233 Material Downblending and Disposition Environmental Assessment 

2-4 

2.2.2 Transport of DUO from SRS to Oak Ridge, TN 

Various sources of DUO were evaluated for use in the downblend process, based on material 

availability and characteristics (e.g. physical and chemical composition, contaminants, potential 

emissions). The only available source of DUO in sufficient quantities and with the required 

attributes is located at the DOE SRS (DOE 2007). 

To perform the proposed downblend activities, an estimated 1,038,000 pounds (472,000 kg) of 

DUO would be packaged into about 805 drums and transported to Oak Ridge for temporary 

interim storage at a licensed storage facility until needed. Environmental impacts for this 

transportation activity are described in DOE/EA-1393 (DOE 2002a). 

2.2.3 Temporary Storage of DUO at a Storage Facility in Oak Ridge, TN 

DUO transported from SRS would be delivered to a storage facility in Oak Ridge for temporary 

storage. Before these deliveries begin; however, Isotek would ensure that the selected storage 

facility is licensed by the appropriate regulatory authorities for the storage of DUO. Based on 

current plans, the preferred storage location is the MSC facility owned and operated by 

EnergySolutions. The MSC facility was originally constructed in the early 1980s to cast and roll 

uranium for defense and energy applications. DUO would be received, stored, and shipped to 

NFS in the same Sea-Land containers in which the DUO is received. No material handling is 

expected while the DUO is in temporary storage at MSC. 

2.2.4 Transport of DUO from Oak Ridge to NFS 

About 805 drums of DUO would be transported from the temporary storage facility in Oak 

Ridge to the NFS uranium operations facility located in Erwin, Tennessee. Each truckload would 

include about 23 drums of DUO packaged in a 20-foot Sea-Land Container. At the NFS facility, 

the drums of DUO would be stored temporarily prior to conversion to DUN solution. 

2.2.5 Transport of DUN from NFS to ORNL 

An estimated 1.43 million pounds (650,455 kg) of DUN would be transported by tanker truck 

from NFS to ORNL. The DUN solution would be transferred via Department of Transportation 

(DOT)-compliant 3,500-gallon tanker trucks (or equivalent), at a rate of one to five tanker trucks 

per month, for transport to the 3019 Building Complex. Each truckload would carry around 

6,102 pounds (2,768 kg) of material that includes roughly 3,678 pounds (1,671 kg) of uranium. 

Upon arrival at ORNL, the liquid DUN would be transferred from the tanker truck to a stationary 

tank located adjacent to Building 3019A. The stationary tank is a 10,000-gallon stainless steel 

tank located adjacent to Building 3019A in a concrete bunker. The bunker is partially below 

ground and is accessible by removal of concrete shield hatches. The tank would be equipped 

with a high level alarm to assist in overflow prevention. 
U-233 Material Downblending and Disposition Environmental Assessment 

2-5 

2.2.6 Perform U-233 Downblend Activities in the Building 3019 Complex 

The primary purpose of downblend operations is to reduce the concentration of fissile material. 

The downblend process is designed to achieve a fissile content of less than 0.96 percent U-235 

equivalent (one gram of U-233 has a fissile equivalent to 1.4 grams of U-235). Nuclear criticality 

safety and analysis generally evaluates fissile material on a U-235 equivalency basis. Below the 

0.96 percent concentration, the safeguards significance and the nuclear criticality controls would 

no longer be necessary, as the material would be non-weapons usable, would not pose criticality 

concerns, and would satisfy the original DNFSB concerns for this material. 

The Proposed Action would be performed in two stages. The first stage involves the downblend 

operations performed in Building 3019A. The process for this stage is termed GC-1. A 

conceptual process diagram for GC-1 is presented in the top portion of Figure 2.2-2. The second 

stage would include operations to dry, package, and prepare the downblended material for 

transport to NTS or other licensed disposal facilities. The second stage is described in Subsection 

2.2.7. 

Downblend activities would begin with the retrieval and inspection of the U-233 containers. The 

containers would then be opened with robotic manipulators in shielded workstations. Various 

types of retrieval equipment will be designed into the operational configuration for use to 

accommodate the configuration of each container in the inventory. Inspection equipment would 

allow visual inspection of the container surface and labels. Retrieval equipment would not need 

to be changed out unless a repair was necessary. Contingencies for equipment change-out will be 

incorporated into the design and project schedule. 

The next step would involve the oxidation of the uranium, if necessary, in a small furnace. The 

material would then be dissolved in nitric acid. When dissolved, the total uranium in a batch 

would be determined based on a certified analytical procedure. The storage containers that 

formerly held the material would be assayed, characterized, and routed for disposal as low-level 

secondary waste. Size reduction techniques for the U-233 inventory, such as crushing, to 

enhance the dissolution process may be used. The furnace, crusher station, and dissolvers would 

all be housed in a shielded workstation in Building 3019A. 

2.2.7 Dry, Package, and Prepare Downblended Material for Off-site Transport 

In the second stage of the Proposed Action, the downblended material would be dried, packaged, 

and prepared for off-site transport. This EA evaluates two mutually exclusive options for this 

stage. The preferred option involves the construction of an annex facility (hereafter called the 

3019 Annex) adjacent to Building 3019A. A second option involves the transfer of downblended 

material via underground pipelines to the TWPC. If the TWPC Option is selected, then 

construction and operation of the 3019 Annex would not occur. 
U-233 Material Downblending and Disposition Environmental Assessment 

2-6 

Figure 2.2-2—Conceptual U-233 Project Downblend Process 

Source: DOE 2009b 
U-233 Material Downblending and Disposition Environmental Assessment 

2-7 

Both of these options would perform the same basic functions—that is, they would dry, package, 

and load the downblended material onto a truck for off-site transport; however, the GC-2 option 

would render the downblended material in the form of uranium salt monoliths, and the TWPC 

Option would render the downblended material in the form of cementitious grout monoliths. 

Regardless of the process option selected, the final waste form produced will not be a RCRAregulated waste. A conceptual process diagram for GC-2 is presented in the bottom portion of 

Figure 2.2-2. Processes performed at the TWPC are described in detail in DOE/EIS-0305-F 

(DOE 2000). 

Annex Option

The proposed 3019 Annex would be constructed on less than an acre of land where Building 

3074 is presently located. In the 3019 Annex, chemical and pH adjustments would be performed 

through the addition of iron sulfate [FeSO4], sodium hydroxide [NaOH] and/or potassium 

hydroxide [KOH], and magnesium hydroxide [Mg(OH)2] to convert the material into a stable 

uranium salt. The material would be routed to a dryer to remove moisture and other volatile 

materials. Steam condensate and nitrogen oxides would be collected in a scrubber and off-gas 

collection system. The stable uranium salt monoliths would then be packaged in DOE-approved, 

dual-layer containers. These containers would be constructed of stainless steel and would include 

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

filtration, or other suitable technology. The containers would be placed in lead-lined, shielded 

over-packs to allow the material to be contact-handled. The material would be removed from the 

shielded over-packs and placed into shipping casks for transport to NTS or other licensed 

disposal facilities. 

TWPC Option

Based on preliminary analysis, DOE believes that the transuranic (TRU) content of the 

downblended U-233 is sufficiently low such that co-processing the U-233 materials with 

material from the Melton Valley Storage Tanks (MVSTs) waste campaign at the TWPC would 

allow the combined waste stream to be dispositioned at NTS. The ability to co-process waste 

would help reduce overall waste quantities required for disposal. 

The TWPC is located in the southwestern region of ORNL and is operated by EnergX for the 

DOE. The TWPC Option would use the ORNL network of underground liquid low-level waste 

(LLLW) pipelines to transfer downblended material, in liquid form, to the TWPC. These 

pipelines are double-walled stainless steel and are designed to carry LLLW. A pipeline for 

LLLW extends from the 3019 facility to the Bethel Valley Evaporator System, Building 2537. 

From Building 2537, the material could be transferred to the MVSTs. The material would be 

stored there until transfer to the TWPC. 

Use of the LLLW pipelines would require the material to be highly alkaline and well mixed. The 

solids content of the transferred slurry would typically be less than 5 percent and would therefore 

require significant water additions to facilitate transfer. The TWPC evaporator could reconcentrate the slurried materials in the MVSTs. To accommodate the downblended material, 
U-233 Material Downblending and Disposition Environmental Assessment 

2-8 

modifications would be required for the LLLW pipeline, the interim storage tanks and systems, 

and the TWPC. 

2.2.8 Transport Downblended Material to a Licensed Disposal Facility 

Whether the GC-2 process (Annex Option) or the TWPC process (TWPC Option) is selected, the 

downblended, end-product material would be packaged in DOT-compliant/Nuclear Regulatory 

Commission (NRC)-licensed containers and transported off-site via truck to NTS or another 

licensed disposal facility. Waste forms from the GC-2 process would be packaged in 55-gallon 

drums (IP-1 containers); the drums would be shipped to NTS or other licensed disposal facility 

in a shielded 10-160B shipping cask (NRC-licensed Type-B). Each shipment of GC-2 waste 

would contain 10 drums. Waste forms from the TWPC process would be packaged and 

transported to NTS or another licensed disposal facility in DOT Type A containers. Additional 

details regarding processes, waste forms, and shipping from the TWPC can be found in 

DOE/EIS-0305-F (DOE 2000). 

2.2.9 Disposition of Secondary Waste 

Secondary waste would be generated by demolition and construction activities; U-233 

downblend and preparation activities; and facility stabilization, shutdown, surveillance, and 

maintenance activities. Secondary waste does not include downblended material or material that 

has a future use. Examples of secondary waste include items such as used personal protective 

equipment, construction and demolition debris, filters from air handling equipment, and 

sampling equipment. Secondary waste would also include any DUO not consumed during the 

downblending project. Secondary wastes are expected to be generated throughout all phases of 

the project and would be managed in accordance with all federal, state, and local laws and 

regulations. All wastes expected to be generated from the U-233 Project are similar in nature to 

wastes already generated on a regular basis from current ORNL activities. Secondary waste and 

disposition pathways are further described in Section 3.12. DOE/EA-1393 (DOE 2002a) 

addresses transportion and disposal of secondary waste. 

2.2.10 Facility Shutdown, Surveillance, and Maintenance 

When the downblend program is completed and the downblended material has been transported 

off-site, plans would be developed to place the Building 3019 Complex in a safe and stable 

shutdown condition for eventual D&D activities. These plans would be consistent with 

applicable functional end points specified by DOE to meet facility stabilization/transition 

requirements. As part of this transition, all process systems and equipment used for the U-233 

downblend operations would be cleaned so as to minimize the amount of contaminated material. 

The pipes and tanks would be flushed to remove all unattached solid waste materials. These 

systems and equipment would then be characterized for subsequent disposal. Additionally, 

remaining process materials or wastes would be removed and disposed of in accordance with all 

applicable regulatory requirements (DOE 2007). 

Because only a portion of Building 3019A would be utilized for the operations phase of the 

project, at DOE’s direction, shutdown activities could begin during ongoing operations in unused 
U-233 Material Downblending and Disposition Environmental Assessment 

2-9 

portions of the facility. Activities would include removal of processing residues and radioactive 

and hazardous materials. Radiological control practices and procedures would be implemented to 

minimize the potential for airborne contamination and spread of contamination, with particular 

emphasis on in-use areas. After building shutdown is complete, surveillance and monitoring 

activities would be provided for the Building 3019 Complex and associated facilities until the 

facility is transferred to D&D. 

2.3 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED CONSIDERATION

In addition to the Proposed Action and No Action Alternatives, other alternatives were 

considered but not evaluated. With the exception of an expression of interest from the National 

Nuclear Security Administration for a small quantity of U-233 in support of weapons test 

programs, there is no programmatic use for the U-233 inventory (DOE 2004). Therefore, reuse 

options were eliminated from further evaluation. Four alternatives to the proposed aqueous 

process were considered but were eliminated based on cost and/or the technological basis. Other 

downblend alternatives considered are described in Section 2.3 of DOE/EA-1574 (DOE 2007). 
This page is intentionally left blank. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-1 

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS 

3.1 INTRODUCTION

This chapter provides background information to evaluate the potential environmental impacts of 

the Proposed Action Alternative and the No Action Alternative. This chapter references 

information presented in DOE/EA-1488 (DOE 2004), DOE/EA-1574 (DOE 2007), and 

DOE/EA-1393 (DOE 2002a). Referenced information is generally summarized to give the reader 

an overview of the analysis presented in other documents. 

The main activities associated with the Proposed Action are described in Chapter 2. At ORNL, 

these activities include material downblend activities within Building 3019A (the GC-1 process) 

and one of two mutually exclusive options (the GC-2 process and the TWPC process) to dry, 

package, and prepare the downblended material for off-site transport. 

The Annex Option (GC-2 process) involves the construction and operation of the 3019 Annex 

within the Building 3019 Complex. The Annex Option would yield a waste product in the form 

of chemically stable uranium salt monoliths. The TWPC Option involves the transfer of 

downblended material to the TWPC via underground pipeline. Operations at the TWPC would 

solidify the downblended material into hardened cementitious grout monoliths. Impacts for both 

options are addressed in the subsections below. 

3.2 LAND USE

3.2.1 Affected Environment 

The main ORNL site encompasses facilities in two valleys (Bethel and Melton Valleys) on 1,100 

acres of land within the ORR. Within the main area of ORNL, the DOE land use designation is 

“institutional and research.” ORNL supports research and development mission activities in 

science and technology, energy resources, environmental quality, and national security. The 

Building 3019 Complex is located within the heavily developed Bethel Valley area of ORNL. 

The TWPC is located near the MVSTs in the southwestern portion of ORNL about 1.1 miles 

south of the Building 3019 Complex. The region south of the TWPC is wooded and generally 

undeveloped. The area north of the TWPC includes ORNL waste operations facilities. 

3.2.2 No Action Alternative 

Based on a review of the Oak Ridge National Laboratory Land and Facilities Plan

(ORNL 2002), there would be no change to the existing land use for the area in and around the 

Building 3019 Complex under the No Action Alternative. The Building 3019 Complex would 

continue to operate as the storage location for the U-233 inventory, and the surrounding area is 

expected to continue to be used for institutional and research purposes. The Building 3019 

Complex would require major capital upgrades and retrofits to critical facility systems that have 

nearly reached the end of their effective design life or have deteriorated beyond cost-effective 

repair. Significant additional operational expenses would also be incurred to repackage about 

400 containers to satisfy current DOE storage standards for U-233 (DOE 2002a) and to provide 
U-233 Material Downblending and Disposition Environmental Assessment 

3-2 

protection against potential nuclear criticality accidents or theft of the material. However, facility 

improvements needed for the No Action alternative would not impact land use. 

3.2.3 Proposed Action Alternative 

Annex Option

Land disturbance associated with the Annex Option of the Proposed Action would total less than 

one acre. Buildings 3074 and 3136 would be demolished; and the 3019 Annex would be 

constructed in the area currently occupied by these buildings. Prior to demolition of the 3020 

Stack, the 3166 Stack would be constructed on previously disturbed land within the 3019 

Complex. This land disturbance would have no impact on land use at or in the immediate 

vicinity of the Building 3019 Complex since the area is currently used for institutional and 

research purposes and is part of the industrialized portion of ORNL. Previously disturbed areas 

outside of ORNL may be temporarily used as laydown areas and are not expected to exceed two 

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

TWPC Option

Land disturbance for the TWPC Option would include the demolition of the 3020 Stack and the 

construction of the 3166 Stack. Land disturbance would have no impact on land use at or in the 

immediate vicinity of the Building 3019 Complex. Although system modifications would be 

required, these modifications would be to current operating systems at LLLW facilities and at the 

TWPC; therefore, there will be no impact to undisturbed land. 

3.3 INFRASTRUCTURE

3.3.1 Affected Environment 

In terms of infrastructure, ORNL is similar to a small city, supported by a dedicated fire 

department, a medical center, a security force, a wastewater treatment plant, and a steam plant. 

Major utilities required for ORNL operations, such as electricity, natural gas, water, and 

telecommunications, are available. These utilities are supplied by external entities. ORNL 

produces steam and compressed air and operates and maintains systems for the collection and 

treatment of sanitary, process, and industrial-type wastes. Utilities available to the Building 3019 

Complex from ORNL include steam; potable, process and fire water; electricity; plant air; storm 

sewer; and sanitary sewer. ORNL transportation and infrastructure information is described in 

the Oak Ridge National Laboratory Land and Facilities Plan (ORNL 2002). In addition, Section 

3.8 of DOE/EA-1574 (DOE 2007) also provides information on roads, electrical, natural gas, 

sewage, water, stormwater collection system, fire protection, compressed air, steam, and 

telecommunications. This information is incorporated by reference and is not repeated here. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-3 

3.3.2 No Action Alternative 

Under the No Action Alternative, normal operations of the Building 3019 Complex and any 

future upgrades or modifications of the Building 3019 Complex would pose little or no increase 

in utility usage, and current building space allocation would not be affected. Changes to utilities 

would be limited to normal maintenance activities. There would be no expected changes to the 

utilization of the existing infrastructure and it is expected that the current infrastructure would be 

sufficient to satisfy future program needs. 

3.3.3 Proposed Action Alternative 

For the Proposed Action Alternative, estimated material requirements for construction of the 

3166 Stack include 25 cubic yards of concrete and less than three tons of steel. Associated base 

and duct supports would require an additional 10 cubic yards of concrete. Construction of the 

Annex would require around 700 cubic yards of concrete and 25 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. 

For project operations, all equipment used to downblend, dry, and package the material for offsite transport would be electrically powered. Equipment would be laboratory-scale with 

moderate power requirements. 

Emergency Power – For both the Annex Option and the TWPC Option, the diesel generators that 

now serve the Building 3019 Complex are adequate to support the power requirements within the 

Building 3019 Complex, and therefore no new emergency power infrastructure would be needed. 

Likewise, the emergency power system at the TWPC is adequate to support the Proposed Action, 

and no new emergency power infrastructure would be needed. Therefore, the Proposed Action 

would have no impact on Emergency Power infrastructure. 

Electrical Power – Since the project would occur within an existing facility within an industrial 

complex, it is expected that the current electrical power supply and transmission system would 

be adequate to supply the needed electricity without major modifications or upgrades. Whether 

the Annex Option or the TWPC Option is selected, power requirements would not pose an 

appreciable increase in demand from the ORNL grid, and the impacts to the ORNL power 

system would be small. Electrical service would be provided under site use agreements with 

ORNL such as is currently in place. 

Potable and Process Water – For either the Annex Option or the TWPC Option, the maximum 

anticipated water usage (potable and process) would range from 1,000 to 3,000 gallons per day 

above the No Action Alternative water use levels. This estimated usage could be readily 

accommodated by the existing ORNL water supply system. Therefore, impacts on potable and 

process water systems would be small. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-4 

Sanitary Wastewater – For either the Annex Option or the TWPC Option, project operations 

could generate from 1,000 to 3,000 gallons of sanitary wastewater per day above the No Action 

Alternative wastewater generation levels. This water would be discharged into existing sewage 

lines for subsequent treatment at the ORNL Sewage Treatment Plant. The ORNL Sewage 

Treatment Plant has adequate capacity to handle the expected additional discharge of the sanitary 

wastewater that would be generated from U-233 Project operations. Therefore, impacts to the 

sanitary wastewater systems would be small. 

After the Building 3019 Complex is placed in safe and stable shutdown, the major utility systems 

that serve the facility would remain operational until D&D occurs. Infrastructure requirements 

for the Proposed Action are small and could easily be satisfied by the existing infrastructure. 

3.4 AIR QUALITY

3.4.1 Affected Environment 

Ambient air quality is a measure of pollutant concentrations in the ambient air. In 1970, the 

Clean Air Act (CAA) was promulgated to address air quality concerns. CAA regulations limit 

the ambient concentration of seven specific pollutants known to cause adverse health effects. 

These pollutants, known as criteria pollutants, include carbon monoxide, lead, nitrogen dioxide, 

ozone, particulates less than 10 microns in diameter, particulates less than 2.5 microns in 

diameter, and sulfur dioxide. National Ambient Air Quality Standards (NAAQS) identify the 

federal, time-averaged concentration limits for these pollutants (40 CFR 50). Regional air 

monitors provide the data necessary to determine whether or not a region satisfies the NAAQS. 

Areas known to satisfy the NAAQS are designated as attainment areas, and areas that do not 

satisfy the NAAQS are designated as nonattainment areas. Areas that lack sufficient data to 

determine NAAQS compliance are designated as unclassifiable. Because there are seven criteria 

pollutants, an area can be designated as attainment for some pollutants and nonattainment for 

other pollutants. The 3019 Complex is located in a portion of Roane County which is designated 

as attainment or unclassifiable for all NAAQS (40 CFR 81.343). 

Authority for implementation and enforcement of the CAA has been delegated to TDEC by 

EPA. TDEC has adopted NAAQS as the state standards, and has also adopted regulations to 

specify permissible short term and long term concentrations of hazardous and toxic air pollutants 

(TDEC 2006). 

The TDEC Division of Air Pollution Control issues air permits for stationary emission sources 

(non-radiological and radiological) at ORNL. Nine major sources of air emissions from ORNL 

operations are covered under a CAA Title V Operating Permit (Number 556850). The primary 

sources of non-radioactive emissions from ORNL include the steam plant located in the main 

plant area of ORNL, four small package-unit boilers located at the 7600-area, and the Spallation 

Neutron Source. TDEC performed a regulatory inspection of ORNL air emission sources in year 

2007 and all were found to be in compliance (DOE 2008b). 

Radioactive airborne discharges at ORNL consist primarily of ventilation air from radioactively 

contaminated or potentially contaminated areas, vents from tanks and processes, and ventilation 
U-233 Material Downblending and Disposition Environmental Assessment 

3-5 

for reactor facilities (DOE 2007). Radiological airborne emissions from ORNL consist of solid 

particulates, tritium, and other gases, both absorbable and nonabsorbable. Radiological emissions 

are treated and then routed through high efficiency particulate air (HEPA) and/or charcoal filters 

before discharge to the atmosphere. The primary radiological emission point sources for ORNL 

consist of seven stacks located in Bethel and Melton Valleys, as listed below (DOE 2008b): 

• 2026 Radioactive Materials Analytical Laboratory 

• 3020 Radiochemical Development Facility 

• 3039 central off-gas and scrubber system, which includes Building 3019A VOG System, 

and serves the 3500 and 4500 areas cell ventilation system, isotope solid-state ventilation 

system, 3025 and 3026 areas cell ventilation system, 3042 ventilation system, and 3092 

central off-gas system; 

• 7503 Molten Salt Reactor Experiment Facility 

• 7880 TWPC 

• 7911 Melton Valley complex which includes the High Flux Isotope Reactor and the 

Radiochemical Engineering Development Center 

• 8915 Spallation Neutron Source Central Exhaust Facility Stack 

The ORR Annual National Emission Standards for Hazardous Air Pollutants (NESHAP) Report 

identifies emissions for 171 individual isotopes for year 2008. The combined radiological 

content of these emissions from ORNL was 8,590 curies. Isotopes of argon, carbon, cesium, and 

krypton represented about 95 percent of the total curies released, which included 67 percent from 

argon-41, 9 percent from cesium-138, 3 percent from carbon-11, and 16 percent from various 

isotopes of krypton. Collectively, the other radionuclides represented less than five percent of the 

total curies released. Based on radiological emissions for year 2008, the maximum off-site dose 

was estimated at 0.4 mrem (DOE 2009c). 

Vessel off-gas (VOG) emissions from the Building 3019 Complex are exhausted through the 

3039 Stack, which is managed by Bechtel Jacobs LLC (BJC) under TDEC Permit 547563. All 

other emissions are exhausted through the 3020 Stack (DOE 2007) under TDEC Permit 560898 

managed by Isotek Systems, LLC. 

3.4.2 No Action Alternative 

As described in DOE/EA-1574 (DOE 2007), air quality impacts associated with the No Action 

Alternative would be small and within established regulatory limits. Surveillance and 

maintenance activities would continue for the U-233 inventory stored at the Building 3019 

Complex. Some off-gas emissions from present operations are discharged through the 3020 

Stack and some are vented through the 3039 Stack Ventilation System. In year 2007, the Curie 

content in emissions from the 3020 Stack and the 3039 Stack represented 0.0000000324 percent 

and 0.37 percent of combined Curie content from all ORNL stack emissions, respectively (DOE 

2008b). 

Extended storage of the U-233 in the Building 3019 Complex could require additional structural 

and confinement system upgrades. These upgrades could result in temporary and localized 

criteria pollutant emissions from operation of any heavy equipment and transportation vehicles 
U-233 Material Downblending and Disposition Environmental Assessment 

3-6 

associated with construction activities. Off-gas emissions from current operations would be 

expected to remain unchanged (DOE 2007). 

3.4.3 Proposed Action Alternative 

Primary construction activities for the Proposed Action that are common to both the Annex 

Option and the TWPC Option include site preparation and construction of the 3166 Stack, 

internal modifications to Building 3019, and the operation of delivery trucks that transfer 

materials to and from the Building 3019 Complex and temporary laydown areas. Operation of 

construction equipment and delivery trucks would generate combustion tailpipe emissions and 

fugitive dust emissions. These emissions could produce odors that are temporarily noticeable to 

site workers near the construction area; however, these impacts would cease when site 

preparation and construction activities were completed. Best management practices would 

include the application of water on unpaved surfaces to reduce fugitive emissions, and the use of 

newer trucks and equipment that generate reduced emission levels. Emission levels from these 

construction activities would be very small compared to other emissions sources at ORNL, and 

the impact of these emissions would be small and temporary. Isotek would acquire a construction 

permit from TDEC before construction activities begin. 

Emissions generated by construction activities within Building 3019 could include criteria 

pollutants, asbestos, and radiologically contaminated particulates. These emissions would be 

vented through a HEPA filtration system and exhausted through the 3020 Stack or the 3166 

Stack. Overall, emission levels from construction activities would be very small compared to 

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

temporary. 

Off-site emissions associated with the Proposed Action would include combustion tailpipe 

emissions and fugitive dust generated by truck deliveries of process materials, such as uranyl 

nitrate, nitric acid, sodium hydroxide, magnesium hydroxide, ferrous sulfate, and other materials 

required to support demolition, construction, and process activities. The per-mile emissions from 

delivery trucks are relatively small, the number of truck deliveries would be limited, and truck 

emissions would be distributed over a wide area and a relatively long period of time. For these 

reasons, regional impacts to the existing air quality would be small. 

The Building 3019 Complex has four ventilation systems. The purpose of these ventilation 

systems is to safely and efficiently collect gaseous waste streams, provide the necessary 

filtration, monitor the streams for radionuclide and hazardous material contents, and discharge 

the combined streams to the atmosphere at a central location. The systems are designed to 

provide continuous, uninterrupted operation. A detailed description of these systems is presented 

in DOE/EA-1574 (DOE 2007) and is not repeated here. For the Proposed Action, portions of 

these systems would be reconfigured to exhaust through the 3166 Stack. Emissions associated 

with current and proposed process operations may include filterable particulates, entrained nitric 

acid, uranium oxides, sodium hydroxide (GC-2 only), magnesium hydroxide (GC-2 only), iron 

sulfate (GC-2 only), and trace radioactive contaminants. Emissions from the Building 3019A 

VOG System would continue to be exhausted through the 3039 Stack; however, as a result of the 

Proposed Action, the nature of the 3019A contribution to the 3039 Stack emissions could change 
U-233 Material Downblending and Disposition Environmental Assessment 

3-7 

slightly as thorium nitrate is removed from tank P-24 and uranyl nitrate is placed in a stationary 

tank adjacent to 3019A. 

Radionuclide emissions from each process (GC-1, GC-2, and TWPC) would be subject to Title 

40 of CFR Part 61 (40 CFR 61), Subpart H – National Emission Standard for Emissions of 

Radionuclides other than Radon from Department of Energy Facilities. When the design for the 

Proposed Action is sufficiently complete, the air permit application/modification process would 

be initiated. The applicable air permits would outline the applicable 40 CFR 61, Subpart H 

requirements to monitor and report radiological stack emissions to ensure regulatory compliance 

and public safety. 

Upon completion of all downblend activities, Building 3019 would be placed in safe and stable 

shutdown and in preparation for D&D. Potential air emissions from the current storage activities 

would be eliminated, and no additional emissions would be expected from facility shutdown. 

Annex Option

For the Annex Option, process emissions generated by the GC-1 and GC-2 activities would pass 

through a charcoal filtration system and HEPA filtration system before discharge through the 

3166 Stack. The combined estimated annual radiological emissions from GC-1 and GC-2 

operations are listed in Table 3.4-1. These emissions represent less than 0.2 percent of the 

radiological stack emissions at ORNL for year 2008. For the Annex Option, emissions from the 

3039 Stack are expected to be as described above. 

Table 3.4-1—Anticipated Radiological 

Emissions from the 3166 Stack 

Radionuclide Estimated Annual Emissions (Ci) 

Am-241 2.19E-04 

Cm-244 1.84E-05 

Cs-137 1.26E-03 

Tl-208 6.30E-01 

Bi-212 2.18E+00 

Pb-212 1.02E+01 

Pu-238 1.26E-04 

Pu-239 2.33E-04 

Rn-220 2.00E+00 

Total-Sr (as Sr-90) 1.21E-03 

U-232 4.66E-09 

U-234 9.09E-05 

U-235/U-236 (as U-235) 8.39E-06 

U-238 5.59E-06 

TOTAL 1.50E+01 

Source: Isotek 2008 

EPA-approved fate and transport models AERMOD and CAP88 were applied to determine dose 

impacts from proposed facility operations for a range of stack heights for the Annex Option. The 

estimated emissions presented in Table 3.4-1 are based on a preliminary design height of 80 feet 

for the 3166 Stack; the final design stack height may change. The selected stack height will 
U-233 Material Downblending and Disposition Environmental Assessment 

3-8 

(1) cost-effectively satisfy the as low as reasonably achievable (ALARA) principle, (2) ensure 

the radiological exposure to workers in all occupied on-site buildings (outside the Building 3019 

Complex) is less than 1.0 mrem per year, and (3) ensure the radiological exposure to the off-site 

maximally exposed individual (members of the public) would not exceed 0.3 mrem per year as a 

result of the downblend operations. Radiological exposure to each member of the public (from 

ORR operations) would be well within the 10 mrem per year limit established in 40 CFR 61, 

Subpart H. The 3166 Stack emissions would also comply with the 10 CFR 835 limit of 

100 mrem per year for near field exposure to the on-site worker (Isotek 2008). The Title V 

Permit would outline the requisite mitigation measures for regulatory compliance and public 

safety. Isotek anticipates the permit process will begin in December 2009. 

TWPC Option

Radiological emissions for the TWPC Option would be similar to those for the Annex Option; 

however, unlike the Annex Option, which would exhaust through the 3039 and 3166 Stacks, the 

TWPC Option would exhaust through the 3039 Stack, the 3166 Stack, and the TWPC emissions 

system. For the TWPC Option, emissions from the 3039 Stack are expected to be as described 

above. Also, because project emissions for the TWPC Option would be distributed between 

stacks, separated by more than a mile, it is anticipated that the overall impacts on the region 

would not be appreciably different from the impacts for the Annex Option. Additionally, it is 

expected that if the TWPC Option is selected, the dose to the public attributable to processing 

downblended U-233 material will not be significantly different than the dose to the public from 

current operations at the TWPC. Air permit modifications attributable to implementation of the 

TWPC Option, if necessary, would outline the necessary mitigation measures to ensure 

regulatory compliance and public safety. 

3.5 NOISE

3.5.1 Affected Environment 

Noise is generally defined as unwanted sound. Noise energy naturally attenuates (lessens) with 

distance from the source. Grass-covered ground surfaces tend to absorb noise energy to enhance 

noise attenuation. Paved surfaces tend to reflect noise energy and do little to attenuate noise 

energy. Barriers, such as buildings or trees, also absorb noise energy which enhances noise 

attenuation. 

Both mobile and stationary noise sources contribute to noise levels at ORNL. Mobile noise 

sources are associated with the travel of vehicles and equipment. Mobile sources pose a 

temporary increase in ambient noise levels for short durations. Peak traffic flow along Bethel 

Valley Road can pose a noticeable increase in noise levels in some areas of ORNL. Stationary 

noise sources are those that do not move or that move relatively short distances. Stationary noise 

sources in the vicinity of the Building 3019 Complex include ventilation systems, air 

compressors, generators, power transformers, and construction equipment. Beyond a few 

hundred feet away, noise levels from stationary sources are generally not distinguishable from 

background noise levels. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-9 

Occupational Safety and Health Administration (OSHA) standards (29 CFR 1910.95) define 

noise exposure limits for occupational workers. OSHA standards are implemented through the 

ORNL safety procedures. Allowable noise exposures are based on a combination of the noise 

exposure levels and exposure duration. As necessary, administrative controls, engineered 

controls (such as noise barriers and mufflers), and personal protective equipment (ear muffs or 

ear plugs) provide the means to protect workers from excessive noise levels. 

3.5.2 No Action Alternative 

Sound energy generated by current operations within the Building 3019 Complex are generally 

confined within the building. Current noise levels at the Building 3019 Complex are typical of an 

active industrial area and are primarily associated with traffic, stationary equipment operation, 

and nearby construction activities. Beyond the 3019 fenced area, these noise levels are generally 

indistinguishable from background noise levels. Routine maintenance activities associated with 

the continued storage of U-233 at the Building 3019 Complex generally do not generate noise 

levels that would pose a hazard to facility workers. All planned maintenance activities are 

subjected to a safety evaluation, and the potential for hazardous noise exposures are identified 

and mitigated in accordance with project safety procedures. 

The No Action Alternative would eventually require facility upgrades. Noise hazards associated 

with these upgrades would be evaluated, and the appropriate levels of noise mitigation would be 

identified and implemented in accordance with project safety procedures. Construction activities 

associated with facility upgrades would pose a modest but noticeable increase in noise levels 

beyond the fenced area; however, the impacts would be temporary and small. 

3.5.3 Proposed Action Alternative 

Site preparation and construction activities associated with the 3019 annex and the 3166 Stack 

would contribute to current noise levels in the 3000 area of ORNL. Peak noise levels associated 

with site preparation and construction activities could exceed 85 A-weighted decibels (dBA); 

however, peak noise levels would generally be of short duration, and would attenuate to 

moderate levels within a few hundred feet of the source. The noise could pose a minor and 

temporary annoyance to ORNL workers near the construction site. Increased noise at the 

construction laydown area would be intermittent and temporary and would generally only occur 

in daytime hours. Construction activities associated with the TWPC Option would occur at 

existing LLLW facilities and at the TWPC; construction activities would affect existing systems 

generally located on the interior of buildings and would not pose a discernable increase in 

outdoor noise levels. OSHA requirements, implanted through project health and safety 

procedures, would require the use of ear protection for on-site construction workers exposed to 

noise levels above safe threshold levels. Best Management Practices, such as the installation of 

temporary noise barriers, would be applied as necessary to mitigate problematic noise levels 

caused by site preparation and construction activities. 

Noise would also be generated by material transfer trucks that travel to and from the Building 

3019 Complex. Noise levels associated with truck operations would be temporary and would 

attenuate quickly with distance. Noise levels from truck operations at the Building 3019 
U-233 Material Downblending and Disposition Environmental Assessment 

3-10 

Complex would have little impact on the overall noise levels at ORNL and would not be 

expected to pose an annoyance to workers outside the Building 3019 Complex. No need for 

noise mitigation is anticipated. 

The operation of equipment for the proposed downblend process would also contribute to noise 

levels in the area; however, most of the noise sources would be contained within a structure, and 

the increase in noise levels above current background levels, at and beyond the 3019 fenced area, 

would be small and would likely pose no annoyance to site workers nearby. Upon completion of 

the downblend process, the Building 3019 Complex facilities would be placed in a shutdown 

mode, and noise generated at the facility would return to the current levels. 

3.6 GEOLOGY AND SOILS

3.6.1 Affected Environment 

Bedrock beneath the main plant area of ORNL in Bethel Valley is composed of limestone, 

siltstone, and calcareous shale facies of the Ordovician Chickamauga Group. Bedrock beneath 

the Building 3019 Complex area includes the Fleanor Formation, Rockdell Formation, and the 

lower portion of the Benbolt Formation. Heterogeneous soils overlying bedrock include a 

mixture of fill, reworked soils, and native residual soils. During construction of the existing 

facilities of the Building 3019 Complex, soils were extensively modified by the excavation and 

refill of areas around waste storage tanks, underground pipes, and buildings (DOE 2007). 

Because structures are ultimately supported by the soils upon which they are built, the soil 

characteristics influence the ability of a structure to withstand a seismic event. Above-ground 

structure design also influences seismic resistance. DOE-STD-1021-93 defines five levels of 

seismic performance, or performance categories (PCs), for structures based on the potential 

adverse impacts that may occur due to structure failure in a seismic event. Performance 

categories range from the most stringent design seismic requirements (PC-4) to the least 

stringent seismic design requirements (PC-0) (DOE 2002b). The process cells and storage tube 

vaults within Building 3019A are designated as a PC-3 structure. The rest of the facility is 

designated as a PC-1 structure, with one area which is PC-2. 

3.6.2 No Action Alternative 

Foundation soils for the Building 3019 Complex are predominantly residual clays with fair to 

hard consistencies. Generally, these types of clays are not susceptible to liquefaction, a condition 

whereby soils transition from a solid form to the form of a heavy liquid. Soil liquefaction hinders 

the ability of the soil to support a structure. The soils that support foundations of the Building 

3019 Complex should therefore remain stable against liquefaction during and after a seismic 

event (ORNL 2004). 

No effects to geological resources would occur under the No Action Alternative since the 

activities associated with the continued storage of U-233 at Building 3019 Complex and any 

future facility upgrades would occur within the existing facility in a previously disturbed area 

used for institutional and research applications. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-11 

3.6.3 Proposed Action Alternative 

Construction activities would disturb the soil, most of which is similar in nature to the original 

soil of the area and was imported for fill at the time the earlier structures were constructed. Soil 

disturbances would be temporary and would occur within previously disturbed areas used for 

industrial applications. Additional soil, if necessary, would be delivered to the facility from an 

external source. It is anticipated that construction laydown areas would be located on previously 

disturbed soils; however, if otherwise, the construction laydown areas would be sited and 

prepared such that soils are not significantly impacted. 

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. 

Potential impacts associated with seismicity would be similar to those described for the No 

Action Alternative. Although modifications would occur to Building 3019A, and potentially to 

the TWPC and LLLW facilities, these modifications would be to existing systems generally 

internal to the structures and are not anticipated to disturb soils. It is anticipated that seismic 

design requirements of the 3019 Annex would be mitigated by the stability of the soils within the 

Building 3019 Complex. Best Management Practices for construction would provide adequate 

mitigation for the planned activities. 

3.7 WATER RESOURCES

3.7.1 Affected Environment 

Surface Water

The Building 3019 Complex is located in the Bethel Valley Watershed. White Oak Creek is the 

main receiving surface water body in Bethel Valley. Its watershed comprises about 2,098 acres 

of Bethel Valley and includes three tributaries: Northwest Tributary (along the west side of the 

West Campus); First Creek (divides the west end of ORNL from the central area and receives 

drainage from both); and Fifth Creek (through the middle of central ORNL). Flow from White 

Oak Creek in Bethel Valley flows downstream to White Oak Lake, and eventually discharges to 

the Clinch River (DOE 1999). Surface runoff from the impervious surfaces around the Building 

3019 Complex is routed to Fifth Creek via storm drains. Fifth Creek discharges into White Oak 

Creek via NPDES-permitted stormwater outfalls. No wetlands are present in the immediate 

vicinity of the Building 3019 Complex, and the area is not located within a floodplain. ORNL 

routinely monitors surface waters as described in the 2008 ORR Annual Site Environmental 

Report (DOE 2008b). Stormwater from the 3019 Complex discharges via Outfall 302. 

Groundwater

Groundwater flow in Bethel Valley is generally from the northeast to the southwest (i.e., parallel 

to the strike direction). Some of the limestone bedrock beneath the area is subject to chemical 

attack and dissolution from weather to produce karst features such as cavities and conduits which 

strongly influence groundwater flow and transport of contaminants. In addition, extensive 
U-233 Material Downblending and Disposition Environmental Assessment 

3-12 

modification of the soils profile has altered the soil hydrology and created numerous preferential 

seepage pathways, which provides a preferred pathway for groundwater flow and contaminant 

transport in the shallow groundwater zone (DOE 1999). DOE/EA-1574 (DOE 2007) gives 

additional information about ORNL groundwater quality. 

3.7.2 No Action Alternative 

Under the No Action Alternative, surface and groundwater monitoring programs would be 

continued at ORNL. The Building 3019 Complex contains several drain sources that send 

wastewaters, process wastewaters, domestic wastewater, stormwater runoff, cooling water, and 

condensate via piped collection systems to ORNL treatment facilities or outfalls, depending on 

the nature of the wastewater. The No Action Alternative would not result in any changes to these 

sources, and no additional adverse effects to water resources would be expected to occur. 

Impacts to surface water or groundwater could occur as the result of a spill or leak of fuel or 

hazardous material from current operations. Surface and groundwater protection measures, such 

as spill prevention and spill response plans, are already in place at ORNL. These measures would 

be continued under the No Action Alternative. 

3.7.3 Proposed Action Alternative 

The Building 3019 Complex area is a primarily impervious surface that would not be appreciably 

altered. The present stormwater collection system in this area would continue to collect runoff 

from the project area, and no new stormwater facilities would be required. Construction of the 

3166 Stack would be required for both the Annex Option and the TWPC Option. Construction 

laydown areas would be located on previously disturbed land and would therefore not be 

expected to alter the flow of surface waters or contribute to turbidity of drainage tributaries in the 

region. 

Stormwater runoff from the Building 3019 Complex and the construction laydown area would be 

controlled through implementation of appropriate Best Management Practices. Exterior storage 

vessels would be placed in diked areas for spill control. 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 the current NPDES limits. There would be no impacts to surface water 

at the TWPC because TWPC modifications would be limited to upgrades to existing ventilation 

and piping systems. Neither option would draw from or discharge to groundwater sources and 

would therefore have no impact on groundwater resources under normal operations. 

The safe and secure shutdown of the Building 3019 Complex at the completion of the proposed 

processing activities would not substantially change the amount of stormwater runoff generated 

and discharged, and would reduce the potential for a spill or release into the stormwater 

collection system or groundwater, which would be a net positive benefit. The application of Best 

Management Practices would provide adequate mitigation to minimize impacts to water 

resources. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-13 

3.8 ECOLOGICAL RESOURCES

3.8.1 Affected Environment 

Vegetation in the vicinity of the Building 3019 Complex is limited, highly disturbed, and mostly 

maintained by lawn equipment. Grasses and herbaceous vegetation dominate the vegetative 

cover except for some Virginia pines located to the north and south of the building. 

Since there is very little habitat available for native animals, the majority of the animal species 

found in the vicinity are species that adapt well to disturbance and the presence of humans, such 

as small rodents, birds such as starlings and pigeons, reptiles and waterfowl, especially Canada 

geese. There would be no changes to the existing habitat under the Proposed Action. 

Furthermore, existing routine disturbances from lawnmowers, traffic, fences, and industrial 

activities currently preclude the presence of rare, threatened, and endangered plant and animal 

species (DOE 2007). 

3.8.2 No Action Alternative 

The No Action Alternative is described in DOE/EA-1574 (DOE 2007). Under the No Action 

Alternative, no adverse environmental impacts would be expected to occur to any habitat or 

wildlife. The Building 3019 Complex is located in a highly disturbed area of ORNL used for 

institutional and research purposes. Habitat in the vicinity of the Building 3019 Complex is 

limited and mostly maintained by lawn equipment. The U.S. Fish and Wildlife Service, in a letter 

dated May 17, 2004, stated that available endangered species collection records do not indicate 

that federally listed or proposed endangered or threatened species occur within the impacted area 

of the proposed project (DOE 2007). 

3.8.3 Proposed Action Alternative 

No adverse environmental impacts would be expected to occur to any habitat or wildlife for the 

Proposed Action. All activities associated with the U-233 Project and the shutdown of the 

Building 3019 Complex would occur within previously disturbed areas continuously utilized for 

institutional and research purposes over an extended period of time. Habitat in the vicinity of the 

Building 3019 Complex is already highly disturbed and mostly maintained by lawn equipment. 

This type of habitat precludes the presence of rare, threatened, and endangered plant and animal 

species. Therefore, impacts to ecological resources would be small. 

3.9 CULTURAL RESOURCES

3.9.1 Affected Environment 

Building 3019A is considered to contribute to the ORNL Main Facilities Complex Historic 

District and is eligible to be listed in the NRHP (Thomason 2004). The facility, which was part 

of the Manhattan Project, was completed in December 1943. The purpose of the facility was to 

serve as a pilot plant to process and separate plutonium from irradiated slugs produced in the 

adjacent Graphite Reactor. The design and technology developed for this chemical processing 
U-233 Material Downblending and Disposition Environmental Assessment 

3-14 

plant were used for the construction of a full-scale plant at Hanford, Washington. After World 

War II, Building 3019A served as a pilot plant for the development of other chemical separation 

processes that have played a major role in the advancement of chemical reprocessing techniques 

used worldwide (Carver/Slater 1994). 

The original facility was comprised solely of seven concrete cells that rise from a basement level 

to about one story above ground and a wood-frame office and control gallery attached to the 

north side of the cells. In 1950, a new structure was built around the cells for containment, 

laboratory space, and control rooms. In 1954, a “hot analytical facility”, Building 3019B, was 

built onto the west end of Building 3019A. Past interior alterations include the removal of all 

original process equipment, modernization of equipment in the control rooms, and installation of 

a new ventilation system (Carver/Slater 1994). 

3.9.2 No Action Alternative 

Current activities at the Building 3019 Complex would not be expected to impact the historical 

integrity of the Building 3019 Complex. Normal facility maintenance and facility upgrades 

necessary to continue present storage activities could require facility modifications or alterations. 

Prior to any such upgrades, DOE would conduct a review of the National Historic Preservation 

Act Historic Preservation Plan for the Oak Ridge National Laboratory, approved in 2005, and 

make such changes only after a determination was made that such actions would not adversely 

affect the potential listing of eligible buildings on the NRHP (ORNL 2005). DOE would consult 

with the Tennessee SHPO and furnish the SHPO with such determinations. 

3.9.3 Proposed Action Alternative 

Although there have been modifications to the structures, much of the original integrity of the 

Building 3019 Complex remains intact. However, the interior of the facility has lost its historical 

integrity because of extensive internal modifications that were made to provide support for past 

and current missions (DOE 2007). As part of the Proposed Action, additional modifications 

would be made to accommodate various process activities. 

Based on the preliminary design, modifications would be made to Cell 2, Room 201, and Room 

147 to support the installation of new process equipment. Rooms would be altered as necessary 

to allow for the installation of new process equipment. The building utility systems would be 

modified as necessary to support the project, and pipelines would be installed at various 

locations to permit the transfer of material and waste solutions. Chemical storage tanks and 

hazardous material transfer and storage areas would be constructed. Solution transfer equipment 

and spill containment would be modified and/or installed as necessary. Access to Building 3100 

might need to be improved to facilitate drum storage, and additional construction access might 

be needed on two sides of Building 3019A to facilitate delivery of large equipment. In addition, 

the Proposed Action would include removal of the 3020 Stack, authorized via CERCLA TCRA 

Memorandum (DOE 2009a), and construction of the 3166 Stack and the 3019 Annex. 

DOE prepared a letter to the SHPO, dated March 18, 2008 (DOE 2008c). In this letter DOE 

outlined the planned modifications to Building 3019A to enable the U-233 Project. DOE further 
U-233 Material Downblending and Disposition Environmental Assessment 

3-15 

indicated that no adverse impacts to buildings eligible for listing as historic properties would 

occur. The SHPO responded to DOE on April 11, 2008, to concur with this assessment. (TDEC 

2008) 

The National Historic Preservation Act Historic Preservation Plan for Oak Ridge National 

Laboratory (ORNL 2005) is currently under DOE review, and existing Project Summary and 

Archeological and Historical Reviews prepared for this project to determine if the proposed 

construction of a new Building 3019 Annex and the construction of the new 3166 Stack are 

consistent with these analyses. It is expected that such a review will conclude that these two 

actions are consistent with analyses already conducted and would have no adverse impacts to 

buildings eligible for listing as historic properties, as the new stack would be smaller and less 

prominent than the original stack and the proposed Building 3019 Annex would not alter or 

distract from existing buildings in the Building 3019 Complex. Once this analysis is completed, 

any required assessment and notification to the SHPO would be performed. 

3.10 SOCIOECONOMICS

3.10.1 Affected Environment 

Region of Influence

The Region of Influence (ROI) is defined as the geographic region that is most affected by a 

Proposed Action. The ROI for the socioeconomic analysis consists of a four-county area in 

Tennessee that includes Anderson, Knox, Loudon, and Roane Counties. Figure 3.10–1 shows the 

regional counties influenced by ORR. About 40 percent of the current ORR workforce resides in 

Knox County, 29 percent in Anderson County, 16 percent in Roane County, and 6 percent in 

Loudon County. The other 9 percent of the workforce resides in other counties across Tennessee, 

none of which are home to more than 3 percent of the workforce (BEA 2009). Figure 3.10-1 

shows the location of the ORR and the surrounding counties. 

Demographic and Economic Characteristics

Table 3.10-1 summarizes population, per capita income, and total employment from years 2003 

to 2007, the most recent years for which data are available. Population for the ROI has increased 

about 1.4 percent over the 5-year period from 562,845 in year 2003 to 595,518 in year 2007. 

Employment for the region rose slightly at 2.4 percent from 366,895 in year 2003 to 403,993 in 

year 2007. Total per capita income grew over the same period at a rate of about 4.3 percent 

(BEA 2009). 

The average per capita income in the ROI was $32,597 in year 2007, an 18.4 percent increase 

from the year 2003 level of $27,541. Per capita income in year 2007 in the ROI ranged from a 

low of $30,278 in Roane County to a high of $35,491 in Knox County (BEA 2009). 

The average employment rate in the ROI improved from 65.2 percent in year 2003 to 67.8 

percent in year 2007. In years 2003 to 2007, the highest average employment rates in the ROI 

were 72.5 percent in Anderson County and 71.8 percent in Knox County. Employment rates in 
U-233 Material Downblending and Disposition Environmental Assessment 

3-16 

Roane County and Loudon County were much lower at 40.7 percent and 42.1 percent, 

respectively. (BEA 2009). 

Figure 3.10-1—Location of Oak Ridge Reservation and Regional Counties 

Source: DOE 2001 

Population and Housing

Between 1960 and 1990, population growth in the ROI was slightly slower than population 

growth in the State of Tennessee. The ROI population increased at an average annual rate of 

1 percent while the state population increased 1.2 percent, annually. Between years 1990 and 

2002, ROI population growth increased 1.2 percent, annually while the state population 

increased 1.6 percent, annually. Loudon County experienced the fastest rate of population 

growth at 2.5 percent annually between years 1990 and 2002, while Anderson County population 

has increased an average of only 0.4 percent annually (USCB 2005). 
U-233 Material Downblending and Disposition Environmental Assessment 

3-17 

Table 3.10-1—Demographic and Economic Characteristics in the ROI 

County 2003 2004 2005 2006 2007 

Average 

Annual 

Growth 

2003 – 2007 

(percent) 

Anderson 

Population 71970 72,244 71,725 72,735 73,246 0.440% 

Per capita income ($) 27,664 28,588 29,010 30,165 31,077 2.951% 

Total employment 51,907 51,693 52,707 52,987 52,906 0.478% 

Roane 

Population 52,557 52,920 52,569 53,040 53,306 0.354% 

Per capita income ($) 24,949 26,051 27,852 29,144 30,278 4.959% 

Total employment 20,847 20,606 21,741 22,126 22,245 1.636% 

Knox 

Population 396,672 400,061 408,809 416,014 423,603 1.656% 

Per capita income ($) 30,265 32,040 32,430 33,996 35,491 4.036% 

Total employment 277,519 286,689 294,496 301,529 309,116 2.732% 

Loudon 

Population 41,646 42,237 43,194 44,281 45,363 2.160% 

Per capita income ($) 27,286 29,270 30,697 32,037 33,543 5.297% 

Total employment 16,622 17,330 18,567 19,092 19,726 4.373% 

Region Totals 

Population 562,845 567,462 576,297 586,070 595,518 1.421% 

Per capita income ($) 27,541 28,987 29,997 31,336 32,597 4.304% 

Total employment 366,895 376,318 387,511 395,734 403,993 2.437% 

Source: BEA 2009

Knox County is the largest county in the ROI with a year 2007 population of 423,603. Knox 

County includes the city of Knoxville, the largest city in the ROI. Loudon County is the smallest 

county in the ROI had a year 2007 total population of 45,363. The city of Oak Ridge and the 

ORR are located in both Roane and Anderson Counties which had populations of 53,306 and 

73,246 in year 2007, respectively (BEA 2009). 

 

There were a total of 244,536 housing units in the ROI in year 2000. A summary of ROI housing 

characteristics is shown in Table 3.10-2. About 8 percent of the housing units were vacant, 

although some vacant units were used for seasonal, recreational, or other occasional purposes. 

Rental vacancy rates ranged from 9.0 percent in Loudon County to 13.1 percent in Roane 

County, while homeowner vacancy rates ranged from 1.7 percent in Roane County, to 

2.5 percent in Knox County. Owner-occupied housing units accounted for 64 percent of the total 

housing units while renter-occupied units accounted for about 28 percent (USCB 2001). In year 

2000, the median value of owner-occupied housing units ranged from $86,500 in Roane County 

to $98,500 in Knox County and the median contract rent ranged from $398 in Roane County to 

$493 in Knox County. Housing characteristics for the ROI are shown in Table 3.10-2. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-18 

Table 3.10-2—Housing Characteristics for the ROI, Year 2000 

County 

Total 

Number of 

Housing 

Units 

Number of 

OwnerOccupied 

Units 

Homeowner 

Vacancy 

Rates 

(percent) 

Median 

Value 

Number of 

Occupied 

Rental 

Units 

Rental 

Vacancy 

Rates 

(percent) 

Median 

Monthly 

Contract 

Rent 

Anderson 32,451 21,592 1.9 $87,500 8,188 12.8 $450 

Knox 171,439 105,562 2.5 $98,500 52,310 10.0 $493 

Loudon 17,277 12,612 1.9 $97,300 3,332 9.0 $462 

Roane 23,369 16,453 1.7 $86,500 4,747 13.1 $398 

ROI 244,536 156,219 NA NA 68,577 NA NA 

Note: NA - Not applicable. 

Source: USCB 2000 

Distribution of Minority and Economically Disadvantaged Populations and Environmental 

Justice Concerns

For the purpose of this analysis, a minority population consists of any census tract in which 

minority representation is greater than the national average of 30.7 percent. Minorities include 

individuals classified by the U.S. Census Bureau as Black or African-American, American 

Indian and Alaska Native, Asian, Native Hawaiian and Other Pacific Islander, and Hispanic or 

Latino, and those classified under “two or more races.” This provides a conservative estimate 

consistent with Office of Management and Budget guidance (OMB 2000). Hispanics may be of 

any race and are excluded from the totals for individual races to avoid double counting. 

The distribution of minority and economically disadvantaged populations changed little between 

years 1990 and 2000. Only one of the census tracts near the ORR currently includes a minority 

population greater than the national average of 30.7 percent. As of the 2000 census, minorities 

represented 40.1 percent of the population in Tract 201. As of year 1990, Black or 

African-American residents comprised the largest group (29.6 percent). The proportion of 

minority residents in all other Oak Ridge census tracts was below the national average with a 

range from 8.8 in Tract 206 to 17.4 percent in Tract 205 (USCB 2001). No federally recognized 

Native American groups live within 50 miles of ORNL. 

Based on the 2000 Census, 12.4 percent of the United States population and 13.5 percent of the 

Tennessee population had incomes below the poverty level in year 1999. In this analysis, a lowincome population consists of any census tract in which the proportion of individuals below the 

poverty level exceeds the national average. Within the ROI, 13.1 percent of the population in 

Anderson County had incomes below the poverty level. The proportion in Knox County was 

12.6 percent, in Loudon County it was 10.0 percent, and in Roane County it was 13.9 percent 

(USCB 2001). 

Economic Benefits of DOE Activities on the ORR

DOE employment and outlays generate additional benefits to the ROI and state economies 

through the creation of additional jobs. An analysis of the economic impacts of DOE operations 

conducted by the Center for Business and Economic Research at the University of Tennessee 

revealed that: 
U-233 Material Downblending and Disposition Environmental Assessment 

3-19 

• Expenditures by DOE and its contractors led to an increase of nearly 4 billion dollars in 

the state of Tennessee gross state domestic product in year 2008(Murray 2009). 

• Total personal income generated in the state of Tennessee by DOE-related activities was 

roughly 2.3 billion dollars in 2008. Each dollar of income directly paid by DOE in the 

state translates into a total of $2.08 in personal income for Tennessee residents (Murray 

2009). 

• DOE-related activities generated 90.1 million dollars in state and local sales tax revenue 

in Tennessee in year 2008 (Murray 2009). 

• 45,372 full-time jobs were created in Tennessee either directly or indirectly by the DOE 

in 2008, which means that for every one DOE job there were 3.7 other jobs created across 

the state economy(Murray 2009). 

Community Services

Community services in the ROI include public schools, law enforcement, fire suppression, and 

medical services. There are 7 school districts with 144 schools that serve the ROI. Educational 

services are provided for 87,568 students by 5,434 teachers for the 2008 to 2009 school year 

(IES 2009). The student-to-teacher ratio in these school districts ranges from a high of 16.8:1 in 

the Loudon County School District to a low of 13.7:1 in the Oak Ridge School District. The 

average student-to-teacher ratio in the ROI is 16.8:1 (IES 2009). 

Based on 2007 data, counties within the ROI collectively employ 494 full time police officers 

(FBI 2007). The ROI also includes a total of 95 fire stations with 644 career firefighters, 495 

volunteer firefighters, and 166 paid-per-call firefighters (USFA 2008). There are 14 hospitals in 

the four county ROI that serve the regional population (US News 2009). 

3.10.2 No Action Alternative 

Current operational expenses for routine storage, security, and maintenance activities for the No 

Action Alternative are estimated at $5 to $6 million per year and account for roughly 31 

full-time-equivalent (FTE) jobs. Repackaging activities are expected to cost an additional $8 to 

$10 million per year for five to six years, and construction activities to upgrade the facility are 

estimated to cost about $20 million. It is assumed that continued surveillance and maintenance 

after these activities are completed would require the same 31 positions that are currently 

assigned to this task. No demographic or environmental justice impacts would be expected to 

occur under the No Action Alternative. 

3.10.3 Proposed Action Alternative 

Construction of the replacement 3166 Stack would generate an estimated 25 construction jobs 

that would last about 6 months. Construction of the Building 3019 Annex would generate about 

50 construction jobs and that would last about 24 months. Facility modifications within Building 

3019 would generate an estimated 15 construction jobs that would last for about 6 months. If the 

TWPC Option was selected, necessary modifications to the TWPC and LLLW facilities would 

generate an estimated 25 construction jobs and last about 9 months. Relative to the ROI 

population, these impacts would represent less than a one percent increase in the total regional 
U-233 Material Downblending and Disposition Environmental Assessment 

3-20 

employment, and would have little impact on housing, schools, medical services, or emergency 

services in the ROI. The impacts, though small, would be positive for the community. No 

demographic or environmental justice impacts would be expected to occur as a result of 

construction. 

For the Annex Option, an estimated peak level of 127 direct jobs would be generated to support 

operations for Phase II execution of the project and would continue for about 30 months. About 

31 of these jobs would be associated with continued storage and maintenance activities in 

Building 3019A, and 96 jobs would be generated for other project operations. Since employment 

changes associated with other phases of the project would be considerably lower, this represents 

an upper bound for project employment. Relative to the ROI population, these impacts would 

represent less than a one percent increase in the total regional employment, and would have little 

impact on housing, schools, medical services, or emergency services in the ROI. The impacts, 

though small, would be positive for the community. Employment levels for the TWPC Option 

would be slightly lower than the Annex Option. 

Once the Proposed Action is complete, employment levels would be reduced to support 

long-term surveillance and maintenance until D&D activities begin. No demographic or 

environmental justice impacts would be expected to occur as a result of operations. 

Population

Based on the small number of jobs created and the pool of qualified local residents available, no 

impact on population is anticipated as a result of the Proposed Action. 

Environmental Justice

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations, requires agencies to identify and address 

disproportionately high and adverse human health or environmental effects their activities may 

have on minority and low-income populations. Current information suggests that there would be 

no high and adverse human health or environmental impacts under normal operations. As 

discussed in earlier in this section, only one Tract in the ORR region includes a higher proportion 

of minorities in the population than the national average. Other tracts in the ROI have low 

proportions of minorities in their populations. Since no socioeconomic impacts are expected, no 

disproportionate impacts to minority or low income populations would be expected. 

Employment and Income

This analysis assumes that the Proposed Action would create a net gain of 75 jobs for 

construction and 96 new jobs for peak operations, for a total of 171 jobs. These figures represent 

a very small increase (less than 0.1 percent) from the 2007 ROI employment total shown in 

Table 3.10-1. As a whole, the number of DOE employees and contractors exceed 13,700 in 

Tennessee, and most live within the ROI. These jobs have an average salary of nearly $65,000 in 

comparison to the statewide average of less than $45,000 (Murray 2009). Based on an average 

annual income of $65,000, 171 additional jobs would add about $11 million to the overall 
U-233 Material Downblending and Disposition Environmental Assessment 

3-21 

income of the ROI or less than 0.1 percent of the 2007 ROI income. When the U-233 Project is 

completed, it would be expected that most or all of the 31 jobs associated with current 3019A 

operations would be eliminated. This employment level is a small percentage of the total ORNL 

or ROI employment and would not be expected to have any socioeconomic impacts. 

Community Services

The small increases in employment and the lack of impacts on population and tax revenues 

indicate that there would be no impact on the existing community services of the ROI. 

3.11 VISUAL RESOURCES

3.11.1 Affected Environment 

The landscape at ORNL is characterized by a series of ridges and valleys that trend in a 

northeast-to-southwest direction. The vegetation is dominated by deciduous forest mixed with 

some coniferous forest. Most of the original open field areas on the site have been planted in 

shortleaf and loblolly pine, although smaller areas have been planted in a variety of deciduous 

and coniferous trees. The viewshed, which is the extent of the area that may be viewed from the 

ORR, consists mainly of rural land. The City of Oak Ridge is the only conterminous urban area. 

Viewpoints affected by DOE facilities are primarily associated with the public access roadways, 

the Clinch River/Melton Hill Lake, and the bluffs on the opposite side of the Clinch River. 

Views are limited by the hilly terrain, heavy vegetation, and generally hazy atmospheric 

conditions. 

The Bureau of Land Management (BLM) Visual Resource Management (VRM) Classification 

System was applied to rate the scenic quality of ORNL and surrounding areas. Although this 

classification system is designed for undeveloped and open land managed by BLM, it is one of 

the only systems of its kind available for the analysis of visual resource management and 

planning activities. Currently, there is no BLM classification for ORNL; however, the level of 

development at ORNL is consistent with VRM Class IV, which is used to describe a highly 

developed area. ORNL structures are mostly low profile, masonry or concrete construction, 

generally three stories or less, and built mainly in the 1940s and 1950s. Facilities at ORNL are 

visible at night because they are brightly illuminated. 

3.11.2 No Action Alternative

The No Action Alternative is described in DOE/EA-1574 (DOE 2007). Under the No Action 

Alternative, ORNL would proceed with current long-term plans to consolidate operations and 

reduce the number of excess facilities. This mission would continue for the foreseeable future. 

Although there would be some reduction in the density of industrial facilities as a result of such 

consolidation, ORNL would still remain a highly developed area with an industrial appearance, 

and no change to the VRM classification would be expected. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-22 

3.11.3 Proposed Action Alternative 

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. Minor visual impacts may also occur due to fugitive dust and dark 

tailpipe emissions generated by construction equipment. Other visual impacts would be posed by 

construction of the 3166 Stack and the 3019 Annex. These impacts would be minor, temporary, 

and consistent with those of an industrial area. After construction of the facilities, construction 

materials, equipment, and construction debris would be removed, and construction laydown 

areas would be graded and seeded. There would be no impacts to visual resources associated 

with construction at the TWPC and LLLW facilities because all facility modifications would be 

incorporated into existing systems. 

During the operation of the U-233 Project no significant changes to the existing visual 

appearances at ORNL would be expected. The 3166 Stack would be shorter and less prominent 

to the skyline than the 3020 Stack. The 3019 Annex would occupy the area now occupied by two 

other buildings slated for near-term removal under the CERCLA TCRA Memorandum 

(DOE 2009a), and would therefore pose no appreciable difference in appearance to the area. At 

some point activities of the U-233 Project would be completed and would allow for the D&D 

and ultimate removal of the entire Complex. Additional storage tanks would be small and would 

be located next to existing structures which would minimize their prominence. Consequently, 

operations for the Proposed Action would not be expected to degrade the visual resources of the 

Building 3019 Complex. 

3.12 WASTE GENERATION AND MANAGEMENT

3.12.1 Affected Environment 

Over the years, use of the facilities, rehabilitation, and construction have generated waste at the 

Building 3019 Complex. As a result, facilities and procedures to allow for the proper 

management of these wastes were developed by ORNL. As the use of these facilities has shifted 

to storage, volumes of waste generation decreased dramatically. Section 3.9 of DOE/EA-1574 

(DOE 2007) explains the various categories of waste and describes the manner in which ORNL 

has managed this waste. This information is incorporated by reference and is not repeated here. 

The U-233 Project is now responsible for the waste management activities for the Building 3019 

Complex and has adopted waste management procedures which are similar to those of ORNL. 

ORNL waste management activities include the transport of waste off-site to commercially 

licensed treatment and disposal facilities for Resource Conservation and Recovery Act (RCRA) 

waste, Toxic Substances Control Act (TSCA) waste, and low-level waste (LLW). Solid waste is 

transported to municipal landfills and TRU waste is transferred to BJC (DOE 2007). 

TWPC waste operations are described in DOE/EIS-0305-F (DOE 2000). Waste management 

procedures at the TWPC are also similar to those of ORNL. In general, the TWPC immobilizes 

TRU waste and/or alpha LLW into cementitious grout monoliths and then transfers the material 
U-233 Material Downblending and Disposition Environmental Assessment 

3-23 

to a Type A waste container. After the waste/grout matrix is adequately cured (dry), the 

container is sealed and placed on a truck for off-site transport to a licensed disposal facility – 

generally the WIPP located in Carlsbad, New Mexico (DOE 2000). 

3.12.2 No Action Alternative 

Under the No Action Alternative, waste storage, transport, and disposal activities associated with 

the Building 3019 Complex would be minimal. Waste generation would be associated with 

normal routine maintenance activities. Facility upgrades would be required to support security 

and safety requirements; therefore, waste generation would increase periodically over current 

rates until the inventory is removed and the facility placed in safe shutdown (DOE 2007). 

Current operations generate around 3,500 cubic feet of LLW debris and scrap metal annually. 

This material is packaged and sent to NTS for disposal. 

Similarly, the current waste activities performed at the TWPC would continue to meet current 

DOE project and programmatic objectives. Waste volumes generated by the TWPC are 

described in DOE/EIS-0305-F (DOE 2000). 

3.12.3 Proposed Action Alternative 

Annex Option

Excavations required for construction of the 3166 Stack and the 3019 Annex would generate 

excess soils, concrete, scrap metal, and debris which may be contaminated from previous ORNL 

activities. Excavated materials would be characterized to determine the appropriate manner of 

disposal. The nature of contamination for these materials could be radiological, RCRA, or 

TSCA. An estimated 16,240 cubic feet of LLW would be generated by construction activities. 

This material would be routed to NTS or other suitable facility for disposal. In addition, an 

estimated 1,000 cubic feet of chromium contaminated scrap metal (mixed LLW) would be 

generated. This material would likely be treated locally then routed to NTS or other suitable 

facility for disposal. Clean materials would be sent to a local construction and demolition waste 

landfill for disposal. 

Facility modifications to Building 3019A would generate an estimated 10,000 cubic feet of LLW 

mainly in the form of scrap metal, debris, and concrete. This material would be packaged and 

sent to NTS for disposal. 

The P-24 tank contains an estimated 715 gallons of thorium nitrate. This material would be 

addressed in a detailed P-24 Tank Content Disposition Plan. The plan would include collection 

of additional characterization data, identification of environmental requirements, and evaluation 

of specific treatment and disposition approaches. The P-24 Tank liquids could be transported to a 

commercial waste treatment facility for stabilization then routed for disposal at an appropriately 

permitted facility. Alternatively, these liquids could be processed along with the U-233 

inventory. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-24 

Downblended material from Building 3019A would be transferred to the 3019 Annex where the 

GC-2 process would be performed. Primary waste generated by the GC-2 process would include 

LLW in the form of a dry monolithic uranium salt and LLLW. 

Primary LLW would be packaged in stainless steel, 55-gallon, Type B, IP-1 containers for offsite transport. Each container would be equipped with a HEPA vent filter and a radon-220 decay 

tube, or other suitable means to address radon-220 formation within the drum. The estimated 

surface dose rate from each drum would range from 5 to 7 rad per hour. The total volume of 

primary waste is estimated at 3,667 drums. Waste drums would be secured in an NRC licensed 

Type-B shielded cask (10-160B). Each cask would contain 10 drums, and each cask would 

constitute a truckload. The surface dose rate from the cask would not exceed 0.5 mRad per hour. 

When GC-2 operations begin, an estimated three truckloads per week would be delivered to NTS 

or other licensed disposal facility. An estimated 367 truckloads would be required to transfer the 

downblended material off-site. 

The GC-2 process would generate an estimated 211 gallons of condensate per week. This 

material would be discharged to the ORNL LLLW treatment facility. 

Solid, secondary waste materials would also be generated by the GC-1 and GC-2 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. An estimated 220 cubic feet of secondary waste would be 

generated weekly. DOE/EA-1393 (DOE 2002a) addresses transportation and disposal of 

secondary waste. 

The volume of waste materials generated by facility modifications and process operations would 

be minimized through Best Management Practices and project waste management procedures. 

ORR, local, and off-site treatment and disposal facilities have adequate capacity to accommodate 

all forms of waste generated by construction of the 3166 Stack, Building 3019A modifications, 

and downblend operations. Waste management impacts would be small. 

TWPC Option

The TWPC Option would necessitate facility modifications to the LLLW transfer system and the 

TWPC. These modifications have the potential to generate small volumes of LLW, LLLW, and 

RCRA waste. Radiologically contaminated waste materials would be transported to NTS or other 

suitable facility for disposal. Non-radioactive RCRA hazardous waste would be transported offsite to RCRA-permitted commercial treatment and disposal facilities. Non-radioactive 

construction debris would be sent to a local construction and demolition waste landfill for 

disposal. Other solid waste would be routed to a local municipal solid waste landfill for disposal. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-25 

When operations begin, downblended material (from the GC-1 process in Building 3019A) 

would be transferred via the ORNL LLLW pipeline system to the TWPC. The primary waste 

form generated by the TWPC process would be LLW in the form of cementitious grout 

monoliths. This material would be packaged in Type A containers for off-site disposal. The 

TWPC process would potentially generate a slightly larger primary waste volume than the GC-2 

process (no more than 20 percent larger). Secondary solid LLW for the TWPC Option would 

include PPE, contaminated trash, and waste generated by maintenance and repair operations. 

Secondary waste would also be packaged in Type A containers for off-site transport. It is 

anticipated the quantity of secondary waste would not be significantly different than from the 

Annex Option. LLLW generated by the TWPC process would be transferred to the ORNL 

LLLW treatment facility. 

ORNL, local, and off-site disposal facilities have adequate capacity to accommodate all forms of 

waste generated by the TWPC process. Waste minimization would be achieved through Best 

Management Practices and adherence to project procedures. Impacts would be small and 

additional mitigation is not anticipated. 

3.13 HUMAN HEALTH

3.13.1 Affected Environment 

Radionuclides and chemicals are present in the regional soils and waterbodies due to past 

activities on the ORR. The Oak Ridge Reservation Annual Site Environmental Report for 2007

summarizes pollutant releases and environmental contamination levels of chemicals and 

radiation for year 2007. Chemical and radiological hazards also occur naturally in the soils and 

waterbodies, and the sun poses a natural source of background radiation. ORNL releases and 

natural background sources collectively pose the potential to cause chemical and radiological 

exposure, both on-site and off-site (DOE 2008b). 

In general, human exposure pathways include direct contact, inhalation, and ingestion. Radiation 

exposure is commonly categorized as either external or internal (i.e. ingestion and inhalation). 

Ingestion of radionuclides can occur through the intake of water or food (e.g., vegetation and 

fish). DOE Order 5400.5, Radiation Protection of the Public and the Environment (DOE 1998), 

limits the annual radiological effective dose equivalent (EDE) that an off-site individual may 

receive through all exposure pathways and all radionuclides released from ORR to a maximum 

of 100 mrem. DOE regulations (10 CFR 835, Occupational Radiation Protection) establish 

radiation protection standards and program requirements for DOE and DOE contractor 

operations with respect to the protection of workers from harmful radiation. For all DOE 

facilities, occupational radiation exposure is administratively limited to a maximum of 

2,000 mrem per person per year. As outlined in the Isotek Radiation Protection Program Plan, 

the U-233 Project will administratively control worker radiological exposure below 500 mrem 

per person per year. 

To quantify the potential for adverse health effects from chemical exposure, noncarcinogenic 

hazards are reported as hazard quotients (HQs) such that an HQ of one or more represents a 

potential for adverse health effects, and an HQ less than one indicates an unlikely potential for 
U-233 Material Downblending and Disposition Environmental Assessment 

3-26 

adverse health effects. The sum of more than one HQ for multiple toxicants and/or multiple 

exposure pathways is called a hazard index. Pathways of concern for noncarcinogens are defined 

as those with a hazard index greater than one. (DOE 2007) 

3.13.2 No Action Alternative 

Radiological Exposure to the Workers

The radiological hazards at the 3019 Complex are mainly attributable to the U-233 stored in 

containers within the storage vaults. The duration of the hazard is indefinite, given that the No 

Action Alternative is to continue long-term surveillance and maintenance of the facility. It 

should be noted that the facility was constructed more than sixty years ago. Aging structures and 

components increase the risk of a failure that could result in an environmental release and/or 

increased worker exposure. Facility upgrades would therefore be required to mitigate this risk. 

The hazards associated with routine operations are predominantly radiation exposure to the 

facility worker, in particular, when containers of radioactive material are retrieved from storage. 

This exposure is maintained well below the DOE guidelines for radiation workers and is 

controlled through strict adherence to the Project Radiological Protection program. On-site 

workers and the public are shielded from external radiation exposure by engineered structures 

and by the physical structure of the process cells. 

Another potential radiation exposure hazard for the worker from routine operations, particularly 

maintenance activities, is the disturbance of fixed radioactive contamination, which could 

produce a respirable hazard. The presence of fixed contamination is due to decades of facility 

operation and residue from a 1959 chemical explosion in the facility. The facility ventilation 

system continuously replaces the air to flush out airborne contaminants. In this way, the 

ventilation system provides mitigation for the potential exposure to respirable hazards. 

Therefore, it is anticipated that normal operations within the Building 3019 Complex would 

continue to have a negligible impact on operations personnel. 

Radiological Exposure to the Public

Radiological exposure effects to the public for the No Action Alternative are described in 

DOE/EA-1574 (DOE 2007). For residents of the United States, the average background 

radiological exposure, in terms of the effective dose equivalent (EDE), from natural and manmade sources is 360 mrem per year. Natural sources (such as radon, cosmic radiation) represent 

300 of the 360 mrem. Based on the national average, natural external radiation sources represent 

55 of the 300 mrem of total natural background radiation exposure. In the State of Tennessee, the 

average background external radiation exposure from natural sources is about 42 mrem, slightly 

lower than the national average of 55 mrem (DOE 2007). 

For year 2007, the calculated radiation dose to the maximally exposed off-site individuals 

attributable to ORNL airborne releases was 0.26 mrem for a receptor located 3.1 miles east of the 

3039 Stack and 2.6 miles east northeast of the 7911 Stack. The majority of the total dose was 

attributable to the release of Ar-41 (54.2 percent), Cs-138 (22.9 percent), Pb-212 (12.2 percent), 
U-233 Material Downblending and Disposition Environmental Assessment 

3-27 

and Kr-88 (4.2 percent). The contribution of ORNL emissions to the collective effective 

population dose within 50 miles of ORO was calculated at 17.2 person-rem. Combined 

radioactive airborne emissions from the 3020 Stack and the 3039 Stack represented less than 0.4 

percent of the total stack emissions from ORNL (DOE 2008b) and represent only a small portion 

of the total dose to the public. 

Chemical Exposure to Workers

The potential for chemical exposures to workers in the Building 3019 Complex for the No 

Action Alternative is described in DOE/EA-1574 (DOE 2007) and are summarized here. 

Chemical hazards present in the Building 3019 Complex include uncoated lead shields, lead 

paint, PCBs, asbestos, combustible foam insulation, and perchlorate contamination. RCRA 

hazardous wastes are generated in the course of routine operations and facility maintenance. A 

portion of the U-233 inventory is known to contain cadmium which was deliberately added to act 

as a neutron poison. Oversight for control of occupational chemical exposures at the Building 

3019 Complex currently is under the responsibility of the Project Environment, Safety and 

Health Organization, which ensures compliance with the provisions of 10 CFR 851, Worker 

Safety and Health Program. 

Chemical Exposure to the Public

The potential for chemical exposure to the public for the No Action Alternative is described in 

DOE/EA-1574 (DOE 2007) and summarized here. Health effects attributed to chemical 

exposures can be categorized as carcinogenic or noncarcinogenic. Chemical carcinogenic risks 

are reported as a lifetime probability to develop an excess cancer. EPA defines a target cancer 

risk range from 1 in 10,000 to 1 in 1,000,000. This range determines when remediation actions 

are to be considered under the CERCLA (DOE 2007). 

DOE has estimated the human health risks from chemicals found in the environs of the ORR. 

The primary exposure pathways considered are ingestion of potable water and fish. For ingestion 

of potable water, HQs were estimated upstream (Clinch River kilometer [CRK] 70) and 

downstream (CRK 16) of ORR discharge points. HQs were less than one for detected chemical 

analytes for which there are reference doses or maximum contaminant levels (i.e., barium, 

manganese, zinc, etc.) (DOE 2007). 

To evaluate the potential health effects from the fish consumption pathway, HQs were estimated 

for the consumption of noncarcinogens, and intake/chronic-daily-intake ratios, I/I(10-5), were 

estimated for the consumption of carcinogens detected in sunfish and catfish collected both 

upstream and downstream of the ORR discharge points. For consumption of sunfish and catfish, 

an HQ greater than one was calculated for Aroclor-1260 (a PCB) at all three locations (CRK 70, 

CRK 32, and CRK 16). I/I (10-5) ratios greater than one were calculated for the intake of 

Aroclor-1260 found in sunfish and catfish collected at all three locations. In catfish, an I/I (10-5) 

ratio greater than one was calculated for aldrin at CRK 16 (DOE 2007). 
U-233 Material Downblending and Disposition Environmental Assessment 

3-28 

3.13.3 Proposed Action Alternative 

Radiological Exposure to the Workers

Construction of the Building 3019 Annex and the 3166 Stack would be expected to disturb a 

small area of land. It is possible that these soils could be radiologically contaminated. Before 

land preparation activities begin, characterization activities would be performed to identify the 

nature and extent of soils contamination (if any). If radiological contamination were found, 

measures would be applied to remove these soils in a safe manner in accordance with project 

safety and health procedures. Radiological exposure levels for site characterization workers and 

construction workers would be maintained within DOE administrative limits. 

Radiological worker exposures associated with the GC-1 process (those involved in the U-233 

Project) are described in DOE/EA-1574 (DOE 2007). Radiological worker exposures would also 

occur for GC-2 (Annex Option) process workers (or the TWPC process workers if the TWPC 

Option were to be selected). Dose rates would vary by activity and by location within the 

Building 3019 Annex. The highest worker dose rates are associated with preparation of a 

10-160B cask for transport. 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). To ensure the protection of site workers nearby, the 

facility design and operations would ensure that the average annual dose rate at the 3019 fence 

line would not exceed 0.025 mR per hour. 

Radiological Exposure to Public

Construction activities that would disturb the soil and allow for the migration of any 

contaminants would be local and would not be expected to migrate to the extent that it would 

cause any radiological exposure to the public. Radiological emissions from operations in the 

3019 Annex would be filtered and exhausted through the 3166 Stack. The maximum annual 

radiological exposure to any member of the public attributable to the downblend program would 

be expected to be no greater than 0.3 mrem. Radiological emissions from the 3019 Complex are 

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

completed. The TWPC Option would require modifications to the existing ventilation systems to 

address radon-220 formation. After the modifications are applied, the impacts of radiological 

stack emissions would be expected to be comparable to the historical levels for this facility. 

Chemical Exposure to the Workers

Bulk chemicals used in the GC-1 process are described in DOE/EA-1574 (DOE 2007) and is 

incorporated by reference. Bulk chemicals used in the GC-2 process include the downblended 

uranyl nitrate, 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. Project health and safety 

procedures would govern the receipt, storage, and use of these chemicals to ensure worker 
U-233 Material Downblending and Disposition Environmental Assessment 

3-29 

safety. Similarly, normal operations at the TWPC would not expose workers to chemical 

hazards. 

Chemical Exposure to Public

Chemicals used in the GC-2 process would be captured by the ventilation system, HEPA filtered, 

exhausted out the 3166 Stack, and dispersed in the atmosphere. Similarly, chemical releases to 

the public for normal operations at the TPWC would be filtered and routed out the facility 

ventilation system. Under normal operations, the quantities and concentrations of the chemicals 

involved for either option would not pose any chemical exposure hazard to members of the 

public. 

3.14 TRANSPORTATION

In general, transportation impacts of a proposed action can include (1) traffic delays, (2) risk of 

injury from a traffic accident, or (3) the risk of a latent cancer fatality (LCF) to the truck drivers 

and to members of the public caused by radiation shine from routine transportation or by 

exposure to radioactive materials released in a traffic accident. The potential for traffic delays are 

determined based on current traffic levels, roadway capacities, and the anticipated changes in 

traffic levels. To determine the increased risk of injury from a traffic accident, regional traffic 

accident statistics are applied to the anticipated increase in traffic levels. DOE software 

RADTRAN and TRAGIS, developed by Sandia National Laboratories and ORNL, respectively, 

are applied to estimate the risk of latent cancer fatality from routine transportation activities and 

for the accidental release of radiological materials. Because all activities involve some level of 

risk, professional judgment must be applied to determine whether the calculated risks are 

acceptable relative to the expected benefits of the Proposed Action. 

3.14.1 Affected Environment 

ORNL main site locations are accessible only by road. Vehicle circulation at ORNL may be 

divided into two groups, off-site and on-site circulation. Off-site circulation consists of staff 

movements to and from work and among the various Oak Ridge installations for work 

assignments and to deliver materials. Off-site roads include State Route (SR) 95 (White Wing 

Road), which provides access to the west end of the Bethel Valley area, and SR 62 and Scarboro 

Road, which provide access to the eastern end of Bethel Valley and the ORNL facilities. On-site 

circulation consists of materials handling, movement of personnel between buildings and to and 

from parking lots, and contractor and vendor personnel movement. (DOE 2007) 

The main ORNL access road in Bethel Valley is Bethel Valley Road, which is currently closed 

to non-authorized traffic. This east-west road provides access to the site and leads to all the 

parking lots. Completion of several construction and expansion projects has helped alleviate 

some of the chronic parking problems experienced at the Bethel Valley site. Several main roads 

and access roads provide on-site transportation. The primary north and south corridors are First, 

Second, Third, Fourth, and Fifth streets. The major east and west corridors are White Oak and 

Central Avenues. Materials are transported via the same routes used by employees and visitors. 

(DOE 2007) 
U-233 Material Downblending and Disposition Environmental Assessment 

3-30 

The main roads in Melton Valley are Melton Valley Drive, Ramsey Drive, and Melton Valley 

Access Road. These roads lead to the principal experimental facilities, including the High Flux 

Isotope Reactor, the Consolidated Fuel Reprocessing Center, and the Robotics and Process 

Systems Complex. Several other access roads serve the numerous solid waste storage areas. 

(DOE 2007) 

More than 4,000 workers commute to ORNL each day, and a small portion of these workers 

carpool. There are many delivery trucks that travel to and from ORNL each day to support the 

various site missions. The average round-trip commute of an ORNL site employee is about 35 

miles. Peak traffic occurs between 7 a.m. and 8 a.m. with the arrival of workers at the site, and 

between 4 p.m. and 5 p.m. with their departure. Minimal traffic delays are experienced during 

these peaks since work shifts are staggered, car and vanpooling are practiced, and most deliveries 

to and shipments from ORNL are timed to avoid the rush hour. Road maintenance and the 

movement of heavy equipment or escorted shipments typically occur during the workday after 

traffic flow has subsided. 

Transportation of hazardous substances or radioactive materials poses the risk of injury. There is 

the risk of an accident whereby the release of materials leads to hazardous exposure, and in the 

case of radiological materials, the radiological shine poses the potential for LCF in the exposed 

population. Sandia National Laboratories developed software packages to quantify transportation 

risk. Quantitative results are presented in terms of the probability of a fatality. If transportation 

involves carcinogenic or radioactive materials, there is the potential for risk from an LCF. 

3.14.2 No Action Alternative 

Transportation impacts for the No Action Alternative are described in DOE/EA-1574 

(DOE 2007) and are summarized here. Under the No Action Alternative, the U-233 inventory 

would continue to be stored at the Building 3019 Complex at ORNL. Therefore, there would be 

no transportation or transportation risk other than normal shipment of waste generated from 

inspection and maintenance activities and from the transport of employees to conduct such 

activities. Traffic would likely continue to remain close to current levels, and no impacts would 

be expected to occur. 

3.14.3 Proposed Action Alternative 

Transportation associated with the Proposed Action is grouped into six general categories: 

(1) transport of construction materials and equipment; (2) transport of DUO from SRS to Oak 

Ridge; (3) transport of the DUO to NFS in Erwin Tennessee; (4) transport of DUN from NFS to 

ORNL; (5) transport of downblended material via underground pipeline to the TWPC; and 

(6) transport of the downblended U-233 off-site for off-site disposal to NTS or other licensed 

disposal facilities. Each of these transportation categories is described in more detail below. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-31 

Construction

The transport of materials and equipment associated with the limited construction and 

modification activities at the Building 3019 Complex would be over regional and local roadways 

to the site. Demolition and construction activities are expected to last over a period of 54 months 

with transportation of materials and equipment to the facility. Similar transportation of materials 

to and through the ORNL occurs routinely, however the Proposed Action would produce a minor 

increase in the overall traffic flow. The number of trucks that enter and leave the Building 3019 

Complex would increase from the No Action Alternative over the 54 months of demolition and 

construction. The present fence line would be expanded to allow for safer and more secure truck 

access along Hillside Avenue. The destination for inbound deliveries would be moved from the 

north side of the Building 3019A to a proposed new delivery area that would be constructed 

south of Building 3001. 

Compared to the traffic associated with daily material delivery trucks and the more than 4,000 

workers who commute to ORNL, the increase in traffic from construction workers and delivery 

trucks for the Proposed Action would be small and would pose only a modest additional delay 

along the main roads, and would have little impact on the risk for a traffic accident. Construction 

workers generally begin work earlier in the day than much of the ORNL operations staff, which 

would also reduce the overall impact of construction traffic on peak traffic levels. 

DUO From SRS to Oak Ridge

DUO for the project would be delivered via truck from SRS to Oak Ridge for interim storage 

before transport to the NFS facility in Erwin, Tennessee for conversion to DUN. The preferred 

route would use Interstates 26 and 40 and would pass through Columbia, South Carolina, and 

Asheville, North Carolina. 

A maximum of 35 truckloads would be required to transport the required amount of DUO from 

SRS to Oak Ridge, a distance of about 340 miles. Each shipment would consist of about 23 

drums of material inside a Sea-Land-type container. This transportation scenario is addressed in 

DOE/EA-1393 (DOE 2002a). 

Transportation of DUO from Oak Ridge to NFS 

Transportation of DUO from Oak Ridge to the NFS facility would require a maximum of 35 

shipments (about 13,485 kg DUO per shipment) over a distance of about 145 miles. Each 

shipment would contain 23 drums secured within a Sea-Land type container. 

The methods to determine radiological and non-radiological impacts for the transportation of 

radioactive materials are described in a calculation package (Tetra Tech 2009). The nonradiological impacts (including fatalities due to accidents and inhalation of emissions) of the 35 

DUO shipments were estimated to be 1.27×10-4. The incident-free radiological impacts were 

estimated to be 1.52×10-4 fatalities and the LCFs due to release of radioactive materials due to 

transportation accidents were estimated at 8.38×10-15 (Tetra Tech 2009). 
U-233 Material Downblending and Disposition Environmental Assessment 

3-32 

Transportation of DUN from NFS to ORNL

An estimated 650,455 kg of aqueous DUN would be transported from NFS to the Building 3019 

Complex at ORNL. The DUN solution would be transported from Erwin in liquid cargo tank 

trailers or other DOT-compliant IP-1 type packages. The NFS facility in Erwin is about 145 

miles from ORNL. Transport of this product would require about 235 truckloads of DUN 

solution. Each truckload would contain around 2,768 kg of DUN on a dry weight basis. The 

increase in traffic levels from this small number of truckloads would pose no impact on traffic 

flow. 

The non-radiological impacts (including fatalities due to accidents and inhalation of emissions) of 

the 235 DUN shipments were estimated at 8.50×10-3 fatalities. The incident-free radiological 

impacts were estimated to be 4.11×10-5 fatalities, and the LCFs due to release of radioactive 

materials due to transportation accidents were estimated at 3.57×10-14. (Tetra Tech 2009). 

On-site Transport of Downblended Material 

The TWPC Option would transfer the material from Building 3019A to the TWPC through an 

existing underground LLLW pipeline system. Because the transfer would occur underground in a 

double-contained pipeline, and because material transfers would be periodic and would occur for 

a limited timeframe, the potential risk to ORNL personnel would be small. Engineering design, 

operational procedures, and Best Management Practices would provide the necessary mitigation 

for this activity. 

Transportation of Downblended Material Off Site for Long Term Management

For the Annex Option, downblended U-233 material would be in the form of stable uranium salt 

monoliths and would be packaged into 55-gallon drums (IP-1 containers). Over the project 

period, approximately 3,667 drums of the downblended product would be expected to be 

generated. These drums would be loaded in shielded 10-160B casks. Each Type B cask would 

hold ten 55-gallon drums. Each truckload would consist of one 10-160B cask. Current plans call 

for delivery of three truckloads per week, for a total of 367 deliveries over the life of the project. 

The downblended product would be transported to NTS or other licensed commercial LLW 

treatment and disposal facilities. The approximately 367 deliveries are expected to yield between 

0.0137 to 0.0152 non-radiological fatalities (accident fatalities and deaths due to inhalation of 

diesel emissions). The incident-free radiological impacts were estimated to be 0.00569 fatalities 

and the LCF due to release of radioactive materials due to transportation accidents are estimated 

to be between 3.52×10-12 and 7.40×10-12 (Tetra Tech 2009). 

For the TWPC Option, the final waste form would be cementitious grout monoliths. This 

material would be packaged in Type A containers for off-site disposal. Although the TWPC 

process would potentially generate a slightly larger primary waste volume than the Annex 

Option (GC-2), it is anticipated the number of shipment would be roughly equivalent to the 

Annex Option. As a result, the transportation impacts are judged to be not significantly different 

than for the Annex Option. 
U-233 Material Downblending and Disposition Environmental Assessment 

3-33 

3.15 ACCIDENTS

3.15.1 Affected Environment 

The accidental release of material stored in Building 3019A would pose radiological hazard and 

a chemical exposure hazard. Facility operations and the associated potential for accidents are 

identified and evaluated in the facility safety basis (ORNL 2004). The safety basis also identifies 

engineering and administrative controls to protect facility workers and to mitigate the potential 

for a release of radioactive or hazardous materials. 

3.15.2 No Action Alternative 

Under the No Action Alternative, the ORNL inventory of U-233 would remain stored within the 

Building 3019 Complex. Major facility upgrades and retrofits would be required to ensure the 

continued safe storage of the material, and an estimated 400 containers would have to be 

repackaged to ensure adequate protection against potential nuclear criticality accidents or theft of 

the material. A detailed discussion of potential accidents for the No Action alternative is 

provided in DOE/EA-1574 (DOE 2007). 

3.15.3 Proposed Action Alternative 

Most of the key elements of the Proposed Action have not changed since the issuance of 

DOE/EA-1574 (DOE 2007). The key difference between the DOE/EA-1574 (DOE 2007) 

Proposed Action and the current Proposed Action is the potential construction and operation of 

the 3019 Annex for the GC-2 process or the use of the TWPC process to dry and package the 

material for off-site disposal. DOE/EA-1574 (DOE 2007) provides a detailed description of 

accident scenarios and their impacts. The results of the DOE/EA-1574 (DOE 2007) accident 

analysis demonstrate that accidents do not pose an unacceptable risk of injury to the facility 

worker, ORNL workers, or the public. Accidents and their impacts for the current Proposed 

Action are not expected to be significantly different from the accidents presented in 

DOE/EA-1574 (DOE 2007). 
This page is intentionally left blank. 
U-233 Material Downblending and Disposition Environmental Assessment 

4-1 

4.0 CUMULATIVE IMPACTS 

4.1 INTRODUCTION

CEQ regulations that implement the procedural provisions of NEPA define cumulative impact as 

the “impact on the environment which results from the incremental impact of the action when 

added to past, present, and reasonably foreseeable future actions regardless of what agency 

(Federal or non-Federal) or person undertakes such other actions” (40 CFR Part 1500-1508). A 

cumulative impact analysis is only conducted for those resource areas with potential for 

cumulative impacts. Resource areas identified for cumulative impact analysis in this EA include 

land use, infrastructure, air quality, socioeconomics, waste management, human health, 

transportation, and accidents. This cumulative assessment is conducted in accordance with CEQ 

NEPA regulations and the CEQ handbook, Considering Cumulative Effects Under the National 

Environmental Policy Act (CEQ 1997), on the preparation of cumulative impact assessments. To 

assess cumulative impacts, current and planned initiatives are identified and described below. 

4.2 CURRENT AND PLANNED INDUSTRIAL ACTIVITIES IN THE REGION

Current, large-scale industrial activities in the region include demolition and site remediation 

activities at ETTP; normal operations at the Spallation Neutron Source facility in Bethel Valley 

and the TWPC in Melton Valley; normal operations, building demolition, and facility 

modernization and consolidation activities at ORNL and Y-12; operation of the 950 MW, coalfired, Bull Run Utility Plant; operation of the 1456 MW, coal-fired, Kingston Utility Plant; and 

remediation activities for the 300 acres damaged by the Kingston Utility Plant ash spill from 

December 2008. 

Significant future industrial activities are planned for ORNL and Y-12 as proposed by the 

Integrated Facility Disposition Project (IFDP). The main goals of the IFDP are to eliminate high 

risk legacies of the Manhattan Project and Cold War, achieve environmental remediation, and to 

modernize ORNL and Y-12. IFDP would be funded out of the EM budget, and may be 

accelerated by funds from the American Reinvestment and Recovery Act. The scope of work 

includes decontamination, deactivation, and demolition of contaminated facilities; restoration of 

soil and groundwater contamination areas; legacy waste disposal and facility operations; utility 

reroutes, non-mission equipment removal, and facility construction and improvements. Footprint 

reductions include the removal of 327 ORNL facilities (1.5 million square feet) and 112 Y-12 

facilities (3.9 million square feet) for a total footprint reduction of 5.4 million square feet. The 

target completion range is 15 to 25 years. The estimated volume of debris would exceed 

2 million cubic yards. 
U-233 Material Downblending and Disposition Environmental Assessment 

4-2 

4.3 CUMULATIVE ASSESSMENT

4.3.1 Land Use 

After downblend activities are completed and the material has been transported off-site, the 

U-233 Project would place the Building 3019 Complex in safe-shutdown for eventual 

demolition. The demolition of these facilities along with the IFDP would free an area of land for 

future redevelopment at ORNL. Therefore, the net cumulative impact of the Proposed Action 

and planned contemporaneous actions would yield a net positive impact on land use at ORNL. 

4.3.2 Infrastructure 

Utility infrastructure at ORNL is adequate to support current operations. The Proposed Action 

would pose only a minimal demand above and beyond current electrical, gas, steam, and water 

demands and will continue for less than five years. Road improvements would be local to the 

3019 Complex and would be very small. As planned demolition and construction activities are 

completed, the overall demand on ORNL infrastructure (for power, water, fuels, natural gas, and 

other resources) would diminish. In the long term, the Proposed Action would contribute to a 

cumulative reduction in the infrastructure demand and would therefore yield a small net positive 

benefit. 

4.3.3 Air Quality 

Current ORNL and Y-12 operations contribute the vast majority of radiological impacts to the 

region. Radiological impacts from the Proposed Action represent a small fraction of the current 

conditions. Once downblend activities are completed and the Building 3019 Complex is 

demolished, the cumulative radiological impacts would be slightly reduced. 

Facility demolition, site preparation, and construction associated with the Proposed Action 

would generate modest levels of fugitive dust and tailpipe emissions. These emissions would 

combine with similar emissions from other regional sources (such as the fossil-fired Tennessee 

Valley Authority power plants) and from planned demolition and construction activities at 

ORNL (such as those identified in the IFDP). It is expected that the cumulative emissions could 

pose a small and temporary deterioration of regional air quality; however, as the ORNL 

demolition and construction projects are completed, overall air quality impacts would improve, 

as there would be fewer facilities to heat and cool and therefore less demand for power from the 

nearby fossil energy plants. The cumulative impacts of the Proposed Action may pose a small 

and temporary degradation to air quality, but would ultimately yield a cumulative air quality 

improvement. 

4.3.4 Socioeconomics 

Although additional planners, construction workers, and operations workers would be needed 

for the Proposed Action, the number of additional workers would be small compared to the 

regional workforce or the workforce at ORNL. Activities identified by the IFDP would also 

require additional workers; however, the number of workers needed would not represent a 
U-233 Material Downblending and Disposition Environmental Assessment 

4-3 

substantial portion of the current ORNL workforce. The workforce available in the ROI would 

be adequate to satisfy the demand for additional workers. Housing, public services, hospital 

resources, and other socioeconomic resources are adequate to accommodate the anticipated 

workforce and their families. Therefore, it is not anticipated that the Proposed Action and other 

proposed activities in the region would yield any adverse cumulative socioeconomic impacts. 

4.3.5 Transportation 

Demolition and construction activities for the Proposed Action would yield a small net increase 

in the flow of traffic to and from ORNL. The Proposed Action would contribute approximately 

three truck shipments per week to the current traffic load for about two and one-half years. 

Proposed remediation, demolition, and construction activities identified by the IFDP would also 

yield a net increase in ORNL traffic levels; however, these activities would be performed over a 

15 or 20 year time span, which would mitigate large increases in traffic. Based on the current 

ORNL traffic flow along Bethel Valley Road, it is not anticipated that the net increase in traffic 

levels from the Proposed Action and reasonably foreseeable actions would pose an adverse 

cumulative impact on transportation. 

4.3.6 Waste Management 

Remediation, demolition, and construction activities associated with proposed IFDP activities 

and the Kingston ash spill would generate large waste volumes. Local and off-site disposal 

facilities may need to develop additional capacity to accommodate these waste volumes. 

Demolition and construction activities for the Proposed Action would also generate waste, but 

the volume would be very small compared to other planned activities in the region, and would 

contribute little to the cumulative impact on available waste disposal capacity. 

The downblended U-233 would represent an estimated 3,667 drums of waste. The proposed 

disposal facility (NTS) has adequate capacity to accept this waste; disposal of legacy waste from 

IFDP activities could contribute to this total. Cumulative impacts of the Proposed Action and 

other foreseeable actions may pose a large demand for waste disposal facilities, which could 

potentially lead to the need for additional disposal capacity. 

4.3.7 Human Health 

Operations included under the Proposed Action would pose a small increase in chemical and 

radiological emissions at ORNL. These emissions would combine with emissions from other 

regional sources; however, because the emission levels are very small compared to emissions 

from regional sources, the cumulative impacts would not be significant and would not require 

additional mitigation. Completion of the U-233 Project would have many positive impacts, 

including the elimination of need for safeguards, security, and nuclear criticality controls for the 

U-233 material. Placement of the facility in a safe and stable shutdown for D&D would also 

have a positive cumulative impact on human health for workers and the public. 
U-233 Material Downblending and Disposition Environmental Assessment 

4-4 

4.4 CUMULATIVE IMPACTS SUMMARY

Although it is not possible to precisely determine all projects that may occur over the next 

several years, a good faith effort has been made to determine probable project possibilities and 

assess the impacts associated with those projects. When considered as a whole, the impacts of all 

of the above listed projects are not expected to substantially degrade environmental conditions. 

The areas with the most impacts would be waste generation and air pollution associated with 

demolition of legacy facilities and new construction activities. Most of the major activities 

remediate the environment and remove or stabilize future sources of contamination. 
U-233 Material Downblending and Disposition Environmental Assessment 

5-1 

5.0 PERMITS AND ENVIRONMENTAL REGULATION 

5.1 PERMITS

Federal, state, and local regulatory authorities have established requirements that govern 

demolition; construction; operations; treatment and release of effluents; waste management; 

transportation; and other aspects of the Proposed Action. Some of the proposed activities would 

require an approved permit from the regulatory authority. A permit is essentially a contract 

between the applicant (Isotek and/or DOE) and the agency with regulatory authority (e.g. TDEC) 

that describes the activity and the conditions and parameters by which the activity can legally be 

performed. The permit process ensures that all applicable regulatory requirements are satisfied. 

There are several permits already in place that cover current operations at the Building 3019 

Complex, the LLLW transfer pipelines, and the TWPC. Proposed activities that fall outside the 

parameters of established permits must be modified; and similarly, a new permit must be 

obtained for activities not covered by current permits. 

Isotek currently manages emissions (3020 Stack) from the 3019 Complex under the Title V 

Major Source Operating Permit Number 560898 issued by TDEC. Permit 560898 became 

effective July 27, 2009, and expires on July 26, 2014. Pursuant to the Rules of the TDEC Bureau 

of Environment, Division of Air Pollution Control in Chapter 1200-03-09-.01 (TDEC 2001), 

Isotek must submit an air construction permit application for the U-233 Project process, which is 

considered a new air contaminant source according to these provisions. The application must be 

submitted to TDEC at least 90 days prior to the estimated starting date of construction of the 

process. Construction can begin upon issuance of the construction permit by TDEC. After 

construction, Isotek will need to amend the Title V permit to include operating limits and 

conditions associated with the new process. A modification may also be required for National 

Pollutant Discharge Elimination System (NPDES) permit number TN0002941. This NPDES 

permit was issued by TDEC and became effective on August 1, 2008; the permit expires on 

July 30, 2013. 

The U-233 Project would not proceed with construction or operations until all necessary permits 

and authorizations are established. Permits related to the U-233 Project would be routine, and no 

unusual circumstances are expected. Sufficient information exists to prepare applications, and it 

is expected that permits could be received in a timely manner. 

5.2 ENVIRONMENTAL REGULATION

Activities conducted at ORNL are required to be in compliance with environmental standards 

established by Federal and state statutes and regulations, executive orders, DOE Orders, 

contract-based standards, and compliance and settlement agreements. Principal among the 

regulatory agencies are TDEC and the EPA. These agencies issue permits, review compliance 

reports, participate in joint monitoring programs, inspect facilities and operations, and oversee 

compliance with applicable regulations. In addition, DOE has an extensive set of Environmental 

Orders which identify programs to assure compliance with environmental regulatory 

requirements and safety for both the worker and members of the public. 
This page is intentionally left blank. 
U-233 Material Downblending and Disposition Environmental Assessment 

6-1 

6.0 AGENCIES CONTACTED 

Over the past 18 months the U-233 Project Team contacted the Tennessee State Historic Office 

on two occasions to describe the activities associated with the Proposed Action and to seek 

approval. Two separate response letters were provided from the SHPO, and each letter confirmed 

that impacts to the proposed activities are adequately mitigated pursuant to the requirements of 

Section 106 of the National Historic Preservation Act. These letters are included as Appendix A 

and B. No other agencies were contacted in the preparation of this EA. DOE/EA-1488 

(DOE 2004) and DOE/EA-1574 (DOE 2007) contain relevant information about agencies 

contacted regarding the Proposed Action. 
This page is intentionally left blank. 
U-233 Material Downblending and Disposition Environmental Assessment 

7-1 

7.0 REFERENCES 

10 CFR Part 1021 DOE, “Energy, National Environmental Policy Act 

Implementation Procedures,” Code of Federal Regulations, Office 

of the Federal Register, National Archives and Records 

Administration, U.S. Government Printing Office, Washington, 

D.C., January 1, 2007. 

10 CFR Part 835 DOE, “Occupational Radiation Protection,” Code of Federal 

Regulations, Office of the Federal Register, National Archives and 

Records Administration, U.S. Government Printing Office, 

Washington, D.C., Revised January 1, 2007. 

10 CFR Part 851 DOE, “Worker Safety and Health Program,” Code of Federal 

Regulations, Office of the Federal Register, National Archives and 

Records Administration, U.S. Government Printing Office, 

Washington, D.C., Revised January 1, 2007. 

29 CFR 1910.95 Occupational Safety and Health Administration (OSHA) standards. 

40 CFR Part 50 U.S. Environmental Protection Agency (EPA), “National Primary 

and Secondary Ambient Air Quality Standards,” Code of Federal 

Regulations, Office of the Federal Register, National Archives and 

Records Administration, U.S. Government Printing Office, 

Washington, D.C., July 1, 2008. 

40 CFR Part 61 EPA, “Protection of the Environment, National Emission 

Standards for Hazardous Air Pollutants,” Code of Federal 

Regulations, Office of the Federal Register, National Archives and 

Records Administration, U.S. Government Printing Office, 

Washington, D.C., July 1, 2008. 

40 CFR 81.343 U.S. Environmental Protection Agency, Designation Of Areas for 

Air Quality Planning Purposes, Office of the Federal Register, 

National Archives and Records Administration, U.S. Government 

Printing Office, Washington, D.C., July 2008. 

40 CFR Parts 1500-1508 Council on Environmental Quality (CEQ), “Regulations for 

Implementing the Procedural Provisions of the National 

Environmental Policy,” Code of Federal Regulations, Office of the 

Federal Register, National Archives and Records Administration, 

U.S. Government Printing Office, Washington, D.C., Revised 

July 1, 2008. 

BEA 2009 Bureau of Economic Analysis, Economic Statistics, Washington, 

D.C., Available at: bea.doc.gov/ 
U-233 Material Downblending and Disposition Environmental Assessment 

7-2 

Carver/Slater 1994 Architectural/Historical Assessment of the Oak Ridge National 

Laboratory, Oak Ridge Reservation, Anderson and Roane 

Counties, Tennessee, ORNL/M3244, prepared for Martin Marietta 

Energy Systems, Inc., Oak Ridge, Tennessee, January 1994. 

CEQ 1997 Council on Environmental Quality. Considering Cumulative 

Effects Under the National Environmental Policy Act. January. 

 http://ceq.hss.doe.gov/nepa/ccenepa/ccenepa.htm 

DNFSB 1997 Uranium-233 Storage Safety at Department of Energy Facilities, 

Recommendation 97-1. February. 

DOE 1994 Memorandum from Secretary of Energy Hazel O'Leary titled 

"Secretarial Policy Statement on the National Environmental 

Policy Act”. June. 

DOE 1998 DOE Order 5400.5, Radiation Protection of the Public and the 

Environment. July. 

DOE 1999 Remedial Investigation/Feasibility Study for Bethel Valley 

Watershed at Oak Ridge National Laboratory, Oak Ridge, 

Tennessee, DOE/OR/01-1748/V 1, and D2, U.S. Department of 

Energy, Washington, D.C. 

DOE 2000 DOE DOE/EIS-0305-F, Final Environmental Impact Statement for 

Treating Transuranic (TRU)/Alpha Low-Level Waste at the Oak 

Ridge National Laboratory. June. 

DOE 2001 DOE, Final Site-Wide Environmental Impact Statement for the 

Y-12 National Security Complex, DOE/EIS-0309, September. 

DOE 2002a Programmatic Environmental Assessment for the U. S. Department 

of Energy, Oak Ridge Operations Implementation of a 

Comprehensive Management Program for the Storage, 

Transportation, and Disposition of Potentially Reusable Uranium 

Materials, DOE/EA-1393. October. 

DOE 2002b DOE-STD-1021-93, DOE Standard, Natural Phenomena Hazards 

Performance Categorization Guidelines for Structures, Systems, 

and Components, U.S. DOE, Washington, D.C., April. 

DOE 2004 Environmental Assessment for the U-233 Disposition, Medical 

Isotope Production, and Building 3019 Complex Shutdown at the 

Oak Ridge National Laboratory, Oak Ridge Tennessee, DOE/EA1488. December. 
U-233 Material Downblending and Disposition Environmental Assessment 

7-3 

DOE 2007 Environmental Assessment for U-233 Stabilization, and Building 

3019 Complex Shutdown at the Oak Ridge National Laboratory, 

Oak Ridge, Tennessee, DOE/EA-1574, U.S. DOE Oak Ridge 

Office, Oak Ridge, Tennessee, March. 

DOE 2008a EAD 2008-0004. Environmental Assessment Determination for 

Proposed Uranium-233 Project Operational Changes and Facility 

Modifications at ORNL. January. 

DOE 2008b Annual Site Environmental Report for the Oak Ridge Reservation, 

DOE/ORO-2261, September 

. 

DOE 2008c Letter from Katatra C. Vasquez of the Department of Energy to Dr. 

Joseph Y. Garrison of the Tennessee Historical Commission titled 

" National Historic Preservation Act, Section 106 Compliance, 

Proposed Undertaking for Modifications to Building 3019A and 

3020, Oak Ridge National Laboratory, Oak Ridge, Tennessee". 

March 

DOE 2009a Time-Critical Removal Action Memorandum for Buildings 3074 

and 3136, and the 3020 Stack at the Oak Ridge National 

Laboratory, Oak Ridge, Tennessee, DOE/OR/01-2407& D1, 

April 9. 

DOE 2009b External Technical Review of the U-233 Downblend and 

Disposition Project at Oak Ridge, Interim Report, U.S. DOE, Oak 

Ridge, Tennessee, March. 

DOE 2009c Calendar Year 2008 Radionuclide National Emission Standards for 

Hazardous Air Pollutants Report for the Department of Energy 

Oak Ridge Reservation. August. 

Executive Order 12898 Federal Actions to Address Environmental Justice in Minority 

Populations and Low Income Populations. February. 

FBI 2007 U.S. Federal Bureau of Investigation, Police Employee Data 

http://www.fbi.gov/ucr/cius2007/police, accessed September 2009. 

IES 2009 IES, U.S. Department of Education, Search for Tennessee Public 

School Districts, Institute of Education Services, Web access in 

July, from http://nces.ed.gov/ccd/districtsearch/. 

Isotek 2008 3020 Replacement Stack, ISO-RAD-PP-004 Rev 1, September. 
U-233 Material Downblending and Disposition Environmental Assessment 

7-4 

MSC 2009 Manufacturing Sciences Website, General Services Information 

http://www.mfgsci.com/, accessed August. 

Murray 2009 The Economic Benefits of the U.S. Department of Energy for the 

State of Tennessee: Fiscal Year 2008. Knoxville, Tennessee: 

University of Tennessee, Center for Business and Economic 

Research, April 2009. Available at: 

http://cber.utk.edu/pubs/mnm115c.pdf 

OMB 2000 Guidance on Aggregation and Allocation of Data on Race for Use 

in Civil Rights Monitoring and Enforcement, Office of 

Management and Budget, March 9. Available at: 

http://www.whitehouse.gov/omb/bulletins/b00-2.html. 

ORNL 2002 Oak Ridge National Laboratory Land and Facilities Plan, 

ORNL/TM-2002/1, Oak Ridge National Laboratory, Oak Ridge, 

Tennessee, August. 

ORNL 2004 Safety Analysis Report for the Building 3019 Complex – 

Radiochemical Development Facilities, ORNL/CTD/3019/SAR. 

Rev. 2, Oak Ridge National Laboratory, Oak Ridge, Tennessee. 

ORNL 2005 National Historic Preservation Act Historic Preservation Plan for 

the Oak Ridge National Laboratory, ORNWTM-2004162. 

TDEC 2001 Rules of Tennessee Department of Environment and Conservation, 

Bureau of Environment, Division of Air Pollution Control. Chapter 

1200-03-09, Construction and Operating Permits. April. 

TDEC 2006 Tennessee Ambient Air Quality Standards, October. 

TDEC 2008 Letter from the Tennessee Historical Commission to DOE, April 

18, titled " Re: DOE, ORNL Buildings 3019a and 3020". April. 

Tetra Tech 2009 Transportation Calculations in Support of DOE/EA-1651. Tetra 

Tech, Inc., Arlington, Virginia, September.

Thomason 2004 National Historic Preservation Act Historic Preservation Plan for 

the Oak Ridge National Laboratory. April. 

USCB 2001 State and County Quick Facts, U.S. Census Bureau, available at 

http://quickfacts.census.gov/qfd/. 

USCB 2005 USCB, Tennessee QuickFacts: People QuickFacts. September. 

Available online at http://quickfacts.census.gov. 
U-233 Material Downblending and Disposition Environmental Assessment 

7-5 

USFA 2008 Fire Stations and Fire Fighter Personnel. for year 2007 as listed by 

the United States Fire Association. Available at 

http://www.usfa.dhs.gov/applications/census/states.cfm. 

U.S.C. 1954 Atomic Energy Act of 1954, 42 U.S.C. § 2011 et seq. 

US News 2009 U.S. News and World Report - List of Hospitals in Tennessee, 

September. Available at http://health.usnews.com/health/besthospitals/index/TN. 
This page is intentionally left blank. 
A-1
This page is intentionally left blank. 
DOE/EA-1651 - Appendix B B-1
This page is intentionally left blank. 
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐1 of 18

John Owsley, Tennessee Department of Environment and Conservation, DOE Oversight Division, Oak Ridge, Tennesse

No. Section Comment Response1 General The document should discuss other disposition

alternatives for the downblended waste, should DOE fail

to satisfy the NTS disposition deadline of 2010. DOE

should outline plans for other disposition outlets for the

mixed waste, if the WIPP acceptance criteria are not met.

A design goal for the U‐233 down

produce a waste form that does n

Characteristic Leaching Procedure 

hazardous waste, and therefore w

definition of mixed low level was

form produced by the U‐233 dow

low‐level waste (LLW). Conseque

is not applicable.

2 General DOE should have a detailed plan for the management of

any unused DUO obtained for this project.

The project baseline (schedule, bu

revised at the 90% design maturit

unused DUO will be included in t

statement is added to sections 2.2

disposition of unused DUO. It sho

the SRS DUO is currently approve

EnergySolutions Clive, Utah facilit

3 Section 2.2.5,

Transport of

DUN from NFS

to ORNL

Because it is liquid, a spill of DUN would be difficult to

recover. Identify the precautions taken to ensure tanker

trucks will not leak in the event of an accident.

The project will use DOT complia

transport DUN. Such shipping co

withstand impacts from accidents 

use consistent with project require

4 Section 2.2.6,

Perform U‐233

DownblendActivities at theBuilding 3019Complex

DNFSB is not spelled correctly [Concur] Correction applied.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐2 of 18

No. Section Comment Response

5 Section 2.2.7 Please add more discussion of the chemical species that

would emerge from the two treatment options.

Presumably, the annex option would result in a very low

solubility salt and the TWPC option would produce

uranyl nitrate absorbed in a cement block. Identify the

specific salt that would be produced by the annex option

and how the uranyl nitrate would perform in a leach test.

It should be noted that the MVST waste is TRU waste and

that a mixture of this waste with the U‐233 could divert

the MVST waste from the WIPP.

The annex option would produce 

salt waste form. It is currently ant

primarily in the form of sodium d

current formulation has not been 

final form of the waste salt may b

currently anticipated, it would sti

stable, low‐solubility salt that is su

In the TWPC option, the uranyl n

blended into the matrix of the cemprocess/formulation would ensur

suitable for disposition at NTS. Re

of downblended uranyl nitrate, M

through the TWPC is not program

disposition at WIPP. Mixture of dnitrate with MVST waste would h

disposition.If the waste form produced by the 

satisfy TCLP criteria, the TWPC o

dismissed from consideration.

6 Section 3.2.3,

Proposed ActionAlternative

Why does the TWPC option have any impact on the 3020

and 3166 stacks?

Construction of the 3166 Stack and 

Stack would occur for either the A

7 Section 3.3.2, No

ActionAlternative

It seems that an impact on infrastructure should include

continued maintenance of the U‐233 storage facility and

associated safeguards such as security and criticality

alarms.

The subject of infrastructure in thi

potential impacts on available util

potable and process water, electri

gas. Safeguards, security, and crit

considered infrastructure. No incr

infrastructure will result from the 
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐3 of 18

No. Section Comment Response

8 Section 3.4.1,

AffectedEnvironment

What are VOG emissions? The acronym is not included

in the list of acronyms and may be a typographical error

[Concur] VOG is an acronym for V

added to the acronym list.

9 Section 3.4.2, No

ActionAlternative

Identify the U‐233 inventory operations that result in off‐

gas emissions?

Static storage requires the reliable 

ventilation systems to ensure any 

captured and handled consistent w

TDEC air permit.

10 Section 3.4.3

Proposed Action

Alternative

Please explain how the 3166 stack would impact the

TWPC option.

The design of the 3166 Stack woul

anticipated emissions. Fewer emis

exhausted out the 3166 Stack if th

selected due to the elimination of 
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐4 of 18

E. Patrick McIntyre, Jr., Tennessee Historical Commission – Department of Environment and Conservation, Nashville, T

No. Section Comment Response

11 General In response to your request, received on Monday,

October 5, 2009, we have reviewed the documents you

submitted regarding your proposed undertaking. Our

review of and comment on your proposed undertaking

are among the requirements of Section 106 of the

National Historic Preservation Act. This Act requires

federal agencies or applicant for federal assistance to

consult with the appropriate State Historic Preservation

Office before they carry out their proposed undertakings.

The Advisory Council on Historic Preservation has

codified procedures for carrying out Section 106 review

in 36 CFR 800. You may wish to familiarize yourself with

these procedures (Federal Register, December 12, 2000,

pages 77698‐77739) if you are unsure about the Section106 process. You may find additional information

concerning the Section 106 process and the Tennessee

SHPO’s documentation requirements at:

http://www.tennessee.gov/environment/hsit/federal/sect106.shtml.Considering available information, we find that the

project as currently proposed will NOT ADVERSELY

AFFECT ANY PROPERTY THAT IS ELIGIBLE FOR

LISTING IN THE NATIONAL REGISTER OF HISTORICPLACES. Therefore, this office has no objection to the

implementation of this project. Please direct any

questions and comments to Joe Garrison (615) 532‐1550‐

103.

Noted.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐5 of 18

Oak Ridge Reservation Local Oversight Committee, Citizens’ Advisory Panel

No. Section Comment Response

12 General The Citizens Advisory Panel (CAP) of the Oak Ridge

Reservation Local Oversight Committee (LOC) has

reviewed and commented on the Draft EA for the U‐233

Material Downblend and Disposition Project at ORNL.

We agree with the need to disposition this material, but

we strongly disagree with the decision not to recover the

thorium‐229 that is the precursor for actinium‐225 and

bismuth‐213, progeny isotopes used for medical

purposes. Uranium‐233 is the only source of Th‐220, and

the ORNL stockpile is the only significant amount of U‐

233 available in the country. Consequently, the CAP

rejects both the permanent disposal options outlined in

the EA and prefers instead that DOE keep the

downblended material in safe storage.

DOE/EA‐1574 titled “Environmen

U‐233 Stabilization and Building 3

Shutdown at the Oak Ridge Natio

proposed to downblend the U‐233 

in storage until a decision could b

disposal. Subsequent studies have 

inventory can be safely processed 

disposal at the Nevada Test Site. T

been made regarding disposition 

Building 3019 are consistent with 

Conference Report for the Energy Development and Related Agenci

for Fiscal Year (FY) 2006. In this re

DOE to terminate promptly the M

Production and Building 3019 Com

Project and provided FY 2006 funappropriations for disposition of t

Building 3019.To not pursue the permitted dispo

stored at Building 3019 would be 

Congressional direction.

13 General A general comment is that the subject EA (DOE/EA‐1651)

should explicitly outline the proposed differences in

approach from those stated in DOE/EA‐1574.

The purpose of the EA is to analyz

environmental impacts of propose

associated with the U‐233 downbl

proposed operational changes, the 

and the scope of the EA are explai
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐6 of 18

No. Section Comment Response

14 Section 2.3 In May 2009, the Inspector General (IG) released Special

Report DOE/IG‐0795 ʺMeeting Medical and Research

Needs for Isotopes Derived from Uranium‐233ʺ that

criticizes the decision by DOE and the Congress to not

recover the Th‐229. The IG recognizes the national

shortage of the progeny isotopes from Th‐220 for medical

uses.

In August 2008, the Office of Science held a workshop

ʺThe National Needs for Isotopes: Present and Futureʺ 

documented in Report DOE/SC‐0107. A discussion of the

projected needs for Ac‐225 and Bi‐213 derived from Th‐

229 begins on page 21 of this report. By year 2014 over

50,000 mCi of these isotopes will be needed to support

medical research and development and clinical trials; this

is an amount far in excess of what is available from

existing research holdings of Th‐229. The current status is

that limited supplies are preventing clinical trials.

The subject EA states in Section 2.3 ʺWith the exception of

an expression of interest from the National Nuclear

Security Administration for a small quantity of U‐233 in

support of weapons test programs, there is no

programmatic use for the U‐233 inventoryʺ citing the

2004 DOE/EA‐1488. In fact, the 2008 ORNL report on the

national need for isotopes documents that there is a

pressing national need for U‐233 progeny isotopes.

Because the isotope production mission has beenassigned to the Office of Science, Environmental

Management must ensure that the Office of Science has

the opportunity to make a formal determination of its

need for U‐233.

The reports on the need for medic

withstanding, the request from N

inquiry relative to the material sto

No other organization, agency, or 

has expressed interest in receiving 

stored at Building 3019.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐7 of 18

No. Section Comment Response

15 General In the prior EA on this project (DOE/EA‐1574), the

preferred DOE option was to put the downblended U‐233

material into safe storage. At the public meeting for that

EA, DOE officials assured the public that Th‐229 could

still be extracted from the downblended material. In the

current EA, DOE proposes permanent and irretrievable

disposal of the downblended material, which would

prevent the extraction of Th‐229. Consequently, the CAP

is opposed to both of the disposal options in the subject

EA.

As stated above, pursuant to a Co

DOE is executing the U‐233 down

disposition the material stored in 

affect the safe shutdown of the Bu

16 General Considering that the EA for the U‐233 Material

Downblend and Disposition Project proposes major

changes to the action, DOE should hold a public meeting

to explain the new approach and extend the comment

period. Past public meetings on the U‐233 project have

had substantial stakeholder interest.

The EA is published to inform the 

potential environmental impacts a

proposed operational changes ass

downblending project. DOE has c

operational changes and associate

a level that would necessitate exte

period or holding additional publ

is not planning any public meetin

DOE is willing to meet with your 

project information.

Phillip H. Roush, Tennessee Department of Environment and Conservation, DOE Oversight Division, Oak Ridge, Tenne

No. Section Comment Response

17 Acronyms Define AERMOD as American Meteorological

Society/Environmental Protection Agency Regulatory

Model

[Concur] Acronym added.

18 Acronyms Define CAP88 as Clear Air Act Assessment Package 1988 [Concur] Acronym added.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐8 of 18

No. Section Comment Response

19 Acronyms Define LLC as Limited Liability Corporation [Concur] Acronym added.20 Acronyms Define VOG as Vessel off‐gas [Concur] Acronym added.21 Page 2‐3 Replace ʺCell Off‐Gasʺ with ʺHot Cell Off‐Gasʺ  The system is termed cell off‐gas.22 Page 2‐3 Replace ʺprevious disturbedʺ with ʺpreviously disturbedʺ  [Concur]23 Page 2‐4, Section

2.2.5, Second

Paragraph

Replace ʺstainless steel tank locatedʺ with ʺstainless steel

tank, encased in a concrete bunker, locatedʺ 

No change. The tank is located in 

encased, in our opinion, gives a in

24 Page 2‐4, Section

2.2.5, Second

Paragraph

Replace ʺhigh level alarmʺ with ʺhigh level alarm to assist

in overflow prevention.ʺ 

[Concur] Suggested change applie

25 Page 2‐5, Section

2.2.6, FirstParagraph

Replace ʺDNSFBʺ with ʺDNFSBʺ  [Concur] Suggested change applie

26 Page 2‐5, Section

2.2.6, Second

Paragraph

Replace ʺThe process for this stage is termed GC‐1, and a

conceptualʺ with ʺThe process for this stage is termed

GC‐1. A conceptualʺ 

[Concur] Suggested change applie

27 Page 2‐5, Section

2.2.6, Third

Paragraph

Replace ʺequipment change outʺ with ʺequipment

change‐outʺ 

[Concur] Suggested change applie

28 Page 2‐5, Section

2.2.6, Fourth

Paragraph

Replace ʺThe storage containersʺ with ʺThe old storage

containersʺ 

No change.

29 Page 2‐7, Annex

Option

Replace ʺSteam and nitrogenʺ with ʺCondensate and

nitrogenʺ 

Replaced with “Steam condensate 

30 Page 2‐7, Annex

Option

Replace ʺwould include a meansʺ  with ʺwould include

technologyʺ 

[Concur] Suggested change applie
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐9 of 18

No. Section Comment Response

31 Page 2‐7, Annex

Option

Replace ʺwould be placed intoʺ with ʺwould be placed inʺ  [Concur] Suggested change applie

32 Page 2‐8, Section

2.2.9

Replace ʺsample equipmentʺ with ʺsampling equipmentʺ  [Concur] Suggested change applie

33 Page 2‐9, Section

2.2.10

Replace ʺwould be provided for the Buildingʺ with

ʺwould be provided for Buildingʺ 

The complex is consistently called 

Complex.

34 Page 3‐1, Section

3.1, Last Paragraph

Is the word ʺcementitiousʺ necessary The word “cementitious” is deem

clarifies an important difference b

products generated by the Annex 

versus the TWPC process (cement

35 Page 3‐5, Section

3.4.1, LastParagraph

VOG is not defined [Concur] Acronym added.

36 Page 3‐5, Section

3.4.2, FirstParagraph

The value ʺ0.0000000324ʺ, is this a decimal or a real

percent?

The value was calculated from da

5.14 (pages 5‐33 through 5‐37) of t

Environmental Report for the Oak R

DOE/ORO‐2261, September 2008. 

the draft EA is a percentage.

37 Page 3‐5, Section

3.4.2, Second

Paragraph

Replace ʺconfinement systemsʺ with ʺconfinement

systemʺ 

[Concur] Suggested change applie

38 Page 3‐8, Section

3.4.3

Replace ʺoffsiteʺ with ʺoff‐siteʺ  [Concur] Change applied globally

39 Page 3‐21, Section

3.11.1

Replace ʺshortleaf and loblolly pineʺ with ʺShortleaf and

Loblolly Pineʺ 

Shortleaf and loblolly pines are ty

not require capitalization. Sugges

applied.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐10 of 18

No. Section Comment Response40 Page 3‐21, Section

3.11.1

Add a comma after ʺVRM Class IVʺ  [Concur] Suggested change applie

41 Page 3‐22, Section

3.11.3

Replace ʺAfter construction of the facilities is complete,

construction materials and equipment would be

removed, construction debris would be removed, and

construction laydown areas would be graded and

seeded.ʺ With ʺAfter construction of the facilities,

construction materials, equipment, and construction

debris would be removed, and construction laydown

areas would be graded and seeded.

[Concur] Suggested change applie

John Wojtowicz, Tennessee Department of Environment and Conservation, DOE Oversight Division, Oak Ridge, TenneNo. Section Comment Response42 Page ii, Table of

Contents

3.12.3 Proposed Action Alternative; Listed as pg. 3‐24,

should be pg 3‐23

[Concur] Correction applied.

43 Page 1‐1,

Introduction,

Paragraph 1, Line 3

The Atomic Energy Act of 1954 should be placed in

Section 7.0 References

[Concur] Reference added

44 Page 1‐2, Paragraph

2, Line 6

EM is not in the list of acronyms [Concur] EM added to acronyms

45 Page 1‐2, Paragraph

2, Lines 10‐12.

ʺManagement of U‐233 Stored at Building 3019, ORNL,

Preliminary Report to Congressʺ dated Feb 08, 2006, to

The honorable Pete V. Domenici, et al) (DOE 2007) is not

included in Section 7 References section

This information came from DOE

2007.

46 Page 1‐2, Paragraph

3, Line 6

DOE 1994 is not in Section 7.0 References [Concur] Reference added
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐11 of 18

No. Section Comment Response47 Page 1‐2, Paragraph

4, Line 2

ʺassociated with U‐233 Projectʺ should read ʺassociated

with the U‐233 Projectʺ 

[Concur] Correction applied.

48 Page 1‐2, Last

Paragraph, Lines 9

and 12:

DOE 2007 should be DOE 2007b This information came from DOE

2007.

49 Page 1‐3, Paragraph

1, Line 4:

ʺDOE/EA‐1488 and DOE/EA‐1574 give additional

information . . . ʺ , using DOE 2004, and DOE 2007b here

would make it easier for the reader to find what

references are meant

[Concur] Reference callouts added

50 Page 1‐6, Second

Bullet, Line 3.

DOE 2007 should be DOE 2007b This information came from DOE

2007.

51 Page 1‐7, Paragraph

1, Line 4.

DOE 2007 should be DOE 2007b This information came from DOE

2007.

52 Page 1‐7, Paragraph

3, Chapter 1, Line 1

ʺIntroduction, Purpose and Need for Action, and Scopeʺ 

should be more appropriately titled ʺIntroduction and

Purpose and Need as Stated in the Table of Contents

[Concur] Correction applied.

53 Page 1‐7, Paragraph

4, Chapter 2, Line 1

ʺThe Proposed Action and Alternativesʺ should be more

appropriately titled ʺProposed Action and Alternativesʺ 

as stated in the Table of Contents

[Concur] Correction applied.

54 Page 1‐7, Paragraph

5, Chapter 3, Line 1

ʺAffected Environment and Environmental

Consequencesʺ should more appropriately be titled

ʺAffected Environment and Environmental Impactsʺ as

stated in the Table of Contents

[Concur] Correction applied.

55 Page 1‐7, Appendix

A, Line 1

The Acronym SHPO should be defined here [Concur] Acronym added.

56 Page 2‐1, Paragraph

1, Line 1

DOE/EA‐1574 should be cited here as DOE 2007b This information came from DOE

2007.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐12 of 18

No. Section Comment Response57 Page 2‐1, Paragraph

1, Lines 10 & 11

DOE 2007 should be DOE 2007b This information came from DOE

2007.

58 Page 2‐1, Paragraph

2, Lines 1‐3

ʺOn February 17, 2006, DOE informed Congress of its

intent to safely process and stabilize the U‐233 inventory

stored in Building 3019A.ʺ This should probably appear

in Section 7.0 References

DOE 2007 citation added.

59 Table 2.2‐1 Evaluation Column.

For the sake of clarity, the Documents listed here should

be cited appropriately.DOE/OR/01‐2407&D1 as DOE 2009a

DOE/EA‐1651 as Current Document

DOE/EA‐1393 as DOE 2002a

DOE/EA‐1574 as DOE 2007b

[Concur] Corrections applied.

60 Page 2‐4, Paragraph

1, Line 4.

DOE 2007 should be DOE 2007b This information came from DOE

2007.

61 Page 2‐4, Paragraph

2, Line 4

DOE/EA‐1393 should be cited as DOE 2002a [Concur] Correction applied.

62 Page 2‐4, Paragraph

5, Lines 1‐4

The first two sentences of this paragraph should be

rewritten (perhaps combined) to eliminate redundancy

and flow more clearly

No change made.

63 Page 2‐7, Paragraph

2, Line 12

ʺcontact handledʺ here should be ʺcontact‐handledʺ to

make it consistent with the usage in the line above

[Concur] Correction applied.

64 Page 2‐7, Paragraph

2, Line 14

DOE 2007 should be DOE 2007b Citation is removed.

65 Page 2‐8, Paragraph

1, Line 2

Should DOT‐NRC (both acronyms appear in the acronym

list) be clarified here as Department of Transportation –

Nuclear Regulatory Commission (DOT‐NRC)?

[Concur] Correction applied.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐13 of 18

No. Section Comment Response66 Page 2‐8, Paragraph

3, Last Line

DOE 2007 should be DOE 2007b This information came from DOE

2007.

67 Page 2‐9, Paragraph

2, Last Line

ʺin Section 2.3 of DOE/EA‐1574ʺ should be cited as DOE

2007b for clarity

Citation DOE 2007 added.

68 Page 3‐1, Paragraph

1, Line 3

DOE 2007 should be DOE 2007b This information came from DOE

2007.

69 Page 3‐2, Last

Paragraph 1, Line

10

DOE/EA‐1574 should be DOE 2007b Citation DOE 2007 added.

70 Page 3‐5, Paragraph

1, Line 1

DOE 2007 should be DOE 2007b This information came from DOE

2007.

71 Page 3‐5, third

bullet line 1

VOG is not in the list of acronyms [Concur] VOG added to acronym

72 Page 3‐5, Paragraph

3, Line 3

DOE 2007 should be DOE 2007b This information came from DOE

2007.

73 Page 3‐5, Paragraph

4, Line 1

DOE/EA‐1574 should be cited as DOE 2007b to facilitate

location in the References section

Citation DOE 2007 added.

74 Page 3‐6, Paragraph

1, Line 2

DOE 2007 should be DOE 2007b This information came from DOE

2007.

75 Page 3‐6, Last

Paragraph 1, Line 6

DOE/EA‐1574 should be DOE 2007b Citation DOE 2007 added.

76 Page 3‐7, Last

Paragraph, Line 1.

Should AERMOD be included in the Acronyms as

American Meteorological Society / Environmental

Protection Agency Regulatory Model?

[Concur] AERMOD is added to ac

77 Page 3‐7, Last

Paragraph 1, Line 1

Should CAP88 be included in the Acronyms as Clear Air

Act Assessment Package 1988

[Concur] CAP88 is added to acron
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐14 of 18

No. Section Comment Response78 Page 3‐10,

Paragraph 4, Line 3

DOE‐STD‐1021‐93 is named in the text of the document

and the reader is referred to DOE 2002b; however, the

Reference for DOE 2002b does not specifically mention

that it is DOE‐STD‐1021‐93

Reference callout modified as app

79 Page 3‐12,

Paragraph 1, Line 3

DOE/EA‐1574 should be DOE 2007b Citation DOE 2007 added.

80 Page 3‐13,

Paragraph 2, Line 7

DOE 2007 should be DOE 2007b This information came from DOE

2007.

81 Page 3‐13,

Paragraph 3, Lines

1 & 8

DOE 2007 should be DOE 2007b This information came from DOE

2007.

82 Page 3‐14,

Paragraph 4, Line 4

DOE 2007 should be DOE 2007b This information came from DOE

2007.

83 Page 3‐14, Last

Paragraph, Lines 10

& 11

CERCLA TCRA Memorandum should be cited as DOE

2009a

[Concur] Correction applied.

84 Page 3‐15,

Paragraph 1

Why is the SHPO letter cited in the references, but the

DOE letter in the first line not?

[Concur] Letter added to the refer

added to the paragraph as DOE 2

85 Page 3‐15,

Paragraph 2, Line 1.

Is this the same plan as ORNL 2005 in the References? If

so, should it not be cited as such? Otherwise, should

there be an additional reference?

[Concur] ORNL 2005 citation add

86 Page 3‐16, Last

Paragraph, Line 7

USCB is not in the Acronyms list. [Concur] USCB added to acronym

87 Page 3‐17, Last

Paragraph, Line2

ʺTable 4.10.2‐2ʺ should be ʺTable 3.10‐2ʺ  [Concur] Correction applied.

88 Page 3‐17, Last

Paragraph, Line 7.

USCB 2000 is not found in the Section 7.0 References [Concur] Reference callout correct
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐15 of 18

No. Section Comment Response89 Page 3‐19,

Paragraph 1, Line 4.

IES is not found in the list of acronyms [Concur] Acronym added.

90 Page 3‐19,

Paragraph 2, Line 2

FBI is not in the list of acronyms [Concur] Acronym added.

91 Page 3‐19,

Paragraph 2, Line 2

USFA is not in the list of acronyms [Concur] Acronym added.

92 Page 3‐21, Last

Paragraph, Line 1

DOE 2007 should be DOE 2007b This information came from DOE

2007.

93 Page 3‐22,

Paragraph 2, Line 4

CERCLA TCRA Memorandum should be cited as DOE

2009a

[Concur] Citation added.

94 Page 3‐22,

Paragraph 3, Line 4.

DOE 2007 should be DOE 2007b This information came from DOE

2007.

95 Page 3‐22,

Paragraph 4, Line 6.

DOE 2007 should be DOE 2007b This information came from DOE

2007.

96 Page 3‐22,

Paragraph 5, Line 1

DOE/EIS‐0305‐F should be cited as DOE 2000 [Concur] Citation added.

97 Page 3‐23,

Paragraph 2, Line 5

DOE 2007 should be DOE 2007b This information came from DOE

2007.

98 Page 3‐23,

Paragraph 3 Line 3

DOE/EIS‐0305‐F should be cited as DOE 2000 [Concur] Citation added.

99 Page 3‐23,

Paragraph 1, Line 4

PPE is not in the list of acronyms [Concur] Acronym added.

100 Page 3‐25,

Paragraph 4, Line 4

DOE Order 5400.5 does not appear in the Section 7.0

References

[Concur] Citation added.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐16 of 18

No. Section Comment Response101 Page 3‐25, Last

Paragraph, Last

Line

DOE 2007 should be DOE 2007b This information came from DOE

2007.

102 Page 3‐26,

Paragraph 1, Line 4

ʺAging structures and components increases the risk of a

failureʺ should read ʺAging structures and components

increase the risk of a failureʺ 

[Concur] Correction applied.

103 Page 3‐26,

Paragraph 4, Line 2

DOE 2007 should be DOE 2007b This information came from DOE

2007.

104 Page 3‐26,

Paragraph 4, Line 8

DOE 2007 should be DOE 2007b This information came from DOE

2007.

105 Page 3‐26,

Paragraph 5, Lines

2 & 3

Would the statement ʺlocated 3.1 miles east of X3039 and

2.6 miles east northeast of X‐7911ʺ be more clearly stated

as ʺlocated 3.1 miles east of the 3039 stack and 2.6 miles

east northeast of the 7911 Stack?

[Concur] Correction applied.

106 Page 3‐27,

Paragraph 2, Line 2

DOE/EA‐1574 should be cited here as DOE 2007b Citation DOE 2007 added.

107 Page 3‐27,

Paragraph 2

Should Uranium and Plutonium be included in this

discussion for their chemical toxicity?

In the context of this project, the r

exposure are considered to govern 

108 Page 3‐27,

Paragraph 2, Line 9

10 CFR 851 is not included in the Section 7.0 References. [Concur] Citation added to Sectio

109 Page 3‐27,

Paragraph 3, Line 2

DOE/EA‐1574 should be cited here as DOE 2007b Citation DOE 2007 added.

110 Page 3‐27,

Paragraph 3, Line 6

DOE 2007 should be cited here as DOE 2007b This information came from DOE

2007.

111 Page 3‐27,

Paragraph 4, Line 6

DOE 2007 should be cited here as DOE 2007b This information came from DOE

2007.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐17 of 18

No. Section Comment Response112 Page 3‐27,

Paragraph 5, Line 2

I/I(10‐5) should probably be included in the list of

Acronyms

[Concur] Acronym added.

113 Page 3‐27,

Paragraph 5, Line 8

DOE 2007 should be cited here as DOE 2007b This information came from DOE

2007.

114 Page 3‐28,

Paragraph 2, Line 2

DOE/EA‐1574 should be cited as DOE 2007b Citation DOE 2007 added.

115 Page 3‐28,

Paragraph 4, Line 1

DOE/EA‐1574 should be cited as DOE 2007b Citation DOE 2007 added.

116 Page 3‐29,

Paragraph 1, Line 8

Should RADTRAN and TRAGIS be added to the list of

acronyms?

[Concur] Acronyms added.

117 Page 3‐29,

Paragraph 2, Line 8

RADTRAN is a Sandia National Lab product, but isnʹt

TRAGIS an ORNL product?

[Concur] Correction applied.

118 Page 3‐29,

Paragraph 3, Line 8

DOE 2007 should be cited as DOE 2007b This information came from DOE

2007.

119 Page 3‐29,

Paragraph 4, Line 8.

DOE 2007 should be cited as DOE 2007b This information came from DOE

2007.

120 Page 3‐30,

Paragraph 1, Line 5

DOE 2007 should be cited as DOE 2007b This information came from DOE

2007.

121 Page 3‐30,

Paragraph 4, Line 1

DOE/EA‐1574 should be cited as DOE 2007b Citation DOE 2007 added.

122 Page 3‐31,

Paragraph 4, Line 4

DOE/EA‐1393 should be cited as DOE 2002a [Concur] Correction applied.

123 Page 3‐33,

Paragraph 2, Line 6

DOE/EA‐1574 should be cited as DOE 2007b Citation DOE 2007 added.
DOE/EA‐1651 – Appendix C: Public Comment Response Table

C‐18 of 18

No. Section Comment Response124 Page 3‐33,

Paragraph 3, Lines

2, 5, 6, & 9

DOE/EA‐1574 should be cited as DOE 2007b Citation DOE 2007 added.

125 Page 4‐1, Paragraph

1, Line 10

CEQ 1997 is not cited in 7.0 References Citation added to Section 7.0 refer

126 Page 5‐1, Paragraph

2, Lines 3 & 4

The statement ʺPursuant to the TDEC regulations in 1200‐

3‐9‐01ʺ might be better stated as ʺPursuant to the Rules of

the TDEC Bureau of Environment, Division of Air

Pollution Control in Chapter 1200‐03‐09‐01ʺ This

reference should also be placed in 7.0 References

[Concur] Correction applied.

127 Page 6‐1, Paragraph

1, Lines 6 & 7

DOE/EA‐1488 and DOE/EA‐1574 should be cited as DOE

2004 and DOE 2007b, respectively.

[Concur] Correction applied.

128 Page 7‐2 DOE 2008a. More information should be provided than

ʺEAD 2008‐0004ʺ.

[Concur] The following title is add

reference: “Environmental Assess

Proposed Uranium‐233 Project Op

Facility Modifications at ORNL”.