# DOE/EA-1651



# Final

Environmental Assessment for U-23 3 Material Downblending and

Disposition Project at the Oa k 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 NAT IONAL 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 Assess ment for U-233 Material

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

This environmental assessm ent (EA) evaluates the impacts of pl anned activities to modify selected

Oak Ridge Nation al Laboratory (ORNL) fac ilities; process the ORNL inventory of uranium-233

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

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

project objectives are: to m odify 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 tr ansport the downblended material to a licensed dis posal facility;

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

and decommissioning (D&D). DOE ha s 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 acti ons have been completed, substantial landlo rd costs would be eliminated,

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

(DNFSB) Recommendation 97-1 woul d 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 co mment in September 2009 and was revised as appropriate based on

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

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

that would significantly affect the quality of the human environm ent within the context of the

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

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

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

copies of the documents obtained from:

U.S. Department of Energy

Information Center

475 Oak Ridge Turnpike

Oak Ridge, Tennessee 37830

Phone: (865) 241-4780

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

contact:

Gary S. Hartman

NEPA Compliance Officer

U.S. Department of Energy

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

Oak Ridge, Tennessee 37831

Phone: (865) 576-0273

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

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

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

integrity of the U-233 storage canisters. DOE th en 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 termina tion of the planned medical isotope production

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

transfer of the projec t 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 asso ciated with (1) the installation of new process

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

material; and (3) placement of the Building 3 019 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 research ed historical documents and has determined that the majority

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

for disposal at the Nevada Test Site (NTS). Th is 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 materi al 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 curren t 3020 Stack and replace it with a new emissions

stack to support the Buil ding 3019 Complex operations.

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

requirements of DNFSB Reco mmendation 97-1; (2) addre ss 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) m odify the existing facility

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

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

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

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

Ridge, Tennessee, was awarde d the U-233 disposition contra ct by DOE on October 9, 2003.

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

Complex for eventual D&D. Th ese 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 facili ty located in Erwin, Tennessee;

and receive DUN at Building 3019A;

• Demolish the 3020 Stack and construct a replacement stack;

• Remove equipment from hot cells an d 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 st orage facilities necessary to process

downblended material at the TWPC;

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

• Dissolve and downblend the U-233 inventory;

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

for transportation and disposal;

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

• Dispose secondary waste; and

• Stabilize the Building 3019 Complex in prep aration 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, im pacts were evaluated for the no action

alternative. If no action were taken, DOE would con tinue to have responsibi lity for the operation

of the Building 3019 Complex, and the ORNL inve ntory 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 n early reached the end of th eir effective design life,

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

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

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

potential nuclear criticality accide nts or theft of the material.

DOE dismissed from further analysis alternat ives 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 Ri ver Site. These alternatives were considered

- 3 -

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

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

potential users for the safe transfer of material.

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

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

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

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

assessed.

Under the proposed action, ther e would be no impact on la nd 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 fac ilities. Previously disturbed areas outside of

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

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

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

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

provided by local suppliers without prior notifi cation. 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 vehicl e/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 ac tion 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 HE PA 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 containe rs to reduce the exposures to

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

radiological emissions from the proposed ac tion 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 build ings would be less than 1.0 mrem per year and the radiological exposure to

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

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

conditions of permits issued by the Tennessee De partment 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 ge nerated by the project would be produced during construction of

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

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

vicinity, no adverse nois e 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 er osion practices would be app lied throughout the construction

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

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

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

would continue to collect runoff from the projec t areas, and no new stormw ater facilities would

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

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

conventional pollutants and radionu clides 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 resour ces. 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 di scharged, 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 re sult in any adverse impacts to ecological

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

and mostly maintained by lawn equipment. This ty pe of habitat also prec ludes the presence of

rare, threatened, and endangered plant and animal species.

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

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

and Historical Review for the proposed modifica tions 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 determ ined that no exterior archeological resources

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

Officer has concurred with the DOE determinati on. 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 en vironmental 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 constructi on activities at the Building 3019 Complex would

include construction materials and equipment a nd 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 c onstruction of the 3166 Stack and

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

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

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

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

The proposed action would generate primary a nd secondary wastes. Pr imary waste generated

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

LLW (LLLW). The total volume of primary LLW wa ste 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 prim ary waste volume are expected to be roughly

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

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

construction and facility modifications associat ed with the proposed action and would generate

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

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

Uncontaminated debris generated from project ac tivities 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 materi als would include items such

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

decontamination waste, gas filtration media, pe rsonal protective equipment, maintenance waste,

and DUO not consumed by the project. Small vol umes 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 disman tlement activities. Sec ondary waste materials

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

The volume of waste materials generated by cons truction, 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 chem ical exposure to workers and

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

Building 3019 Complex or the TWPC. As specified in the Isotek Radia tion 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 fac ility design features (radiation shields) and

administrative controls (limited worker expo sure 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 e xpected to be no greate r 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 downble nd operations are completed and D&D activities

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

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

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

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

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

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# 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 Re gulatory Activities........................................................ 1-6

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

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

2.0 PROPOSED ACTION A ND 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 SR S to Oak Ridge, TN ..................................... 2-4

2.2.3 Temporary Storage of DUO at a Stor age 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 Eliminat ed 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 Includ ed 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 Characteristic s 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 fo r the Building 3019 Complex ............................................ 2-3

Figure 2.2-2 Conceptual U-233 Proj ect Downblend Process................................................... 2-6

Figure 3.10-1 Location of Oak Ridge Rese rvation 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 Re sponse, 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

FeSO 4 

# 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 deplet ed 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 standard s 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 a nd 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 Analys is Geographic Information System

TRU transuranic

TSCA Toxic Substances Control Act

TWPC Transuranic Waste Processing Center

U-233 Project U-233 Material Downbl ending 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 I NTRODUCTION



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

Laboratory (ORNL) in the Buildi ng 3019 Complex. Special nuclear ma terial 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 ma terials are radioactive, fissile, and can be

formed into nuclear weapons. In powder form, th ese 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 fa cility; 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 nucle ar criticality controls, and render these materials suitable

for safe disposition

• Remove the U-233 material fr om the Building 3019 Complex

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

• Place the Building 3019 Complex in sa fe and stable shutdown condition

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

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

Assessment Determination (EAD 2008-0004) issu ed 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 B ACKGROUND 

# /O VERVIEW



# 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. Ph ase 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 even tual Decontamination and Decommissioning

(D&D).

In the initial Phase I plan, DOE proposed a U-2 33 Project that would op erate an ion-exchange

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

U-233 material with depleted ur anyl nitrate (DUN); transport th e 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 th e 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 appropria tion for disposition of the material stored

in the Building 3019 Complex and directed the Depa rtment 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 St ored at Building 3019, Oak Ridge National

Laboratory, Oak Ridge, Tennessee, Preliminary Re port to Congress,” date d February 8, 2006, to

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

Before implementation of the revised project pl an, 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 Environm ental Response, Compensation, and Liability

Act (CERCLA). Consistent with the Secretaria l 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 applie d 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 bala nce of activities associ ated with the U-233

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

are implemented. The scope of the subject CERCL A 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 th e Oak Ridge Reservation (ORR) in East Tennessee

as shown in Figure 1.2-1. The Building 3019 Comple x, located in Bethel Valley in the northcentral area of ORNL, consists of a main building, several s upport 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 wester n portion of this building is designated as

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

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

its historical significance, Building 3019 is elig ible 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 proce ss the U-233 inventory, ancillary equipment su ch as ventilation

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

consistent with their intende d purpose. DOE/EA-1574 contains a dditional 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 kilo grams (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 invent ory 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 Carolin a. 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 st orage until needed. Provis ions of the American

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

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

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

Evaluation of these transportation activi ties is incorporated by reference.

1.3 P URPOSE AND 

# N EED FOR 

# P ROPOSED 

# A CTION



# 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 f acilities licensed and/or perm itted to accept the U-233 in its

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

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

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

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

(DOE 2004), DOE/EA-1574 (DOE 2 007), and the CERCLA process.

1.4 S COPE OF THIS 

# E NVIRONMENTAL 

# A SSESSMENT



# This EA assesses the potential consequences of non-CERCLA project ac tivities 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] Part s 1500 – 1508) for National Environmental Policy

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

If the impacts associated with the proposed actio n are not identified as si gnificant as a result of

this EA, DOE shall issue a Fi nding 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 cumula tive impacts that could

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

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

environmental information to prescribe restrictio ns to protect, preserve , and enhance the human

environment and natural ecosystems.

To follow the analysis presented herein, it is im portant 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 acti ons and the non-CERCLA actions ar e necessary to fulfill the

goals of the U-233 Project.

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

EA, and that evaluation is not repeated he re. 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 Me morandum 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 Scien ces Corporation (MSC)

facility, in Oak Ridge, Tennessee

(3) transport of DUO from Oak Ridge to Nuclear Fuel Servi ces (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 ma terial is transferred to th e Transuranic Waste Processing

Center (TWPC) as described in item 6)

(6) facility modifications necessa ry 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 downbl ended material and secondary wa ste 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 Build ing 3019 Complex where th e 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 th e TWPC at ORNL, where the

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

1.5 R ELATIONSHIP TO 

# O THER 

# R EGULATORY 

# A CTIVITIES



# To reduce redundancy with previous but rele vant documents, CEQ regulations encourage

Federal agencies to eliminate repetitive discus sions 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 ge neral matters in broad-scope documents, with

subsequent narrower scope documen ts that incorporate by referen ce 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 inclusio n 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 Dis position, 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 L aboratory, Oak Ridge, Tennessee, DOE/EA-1574

(DOE 2007)

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

Operations Implementation of a Comprehe nsive Management Program for the Storage,

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

The removal of the 3020 Stack and two other f acilities 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 valu es applied by the CERCLA review process

provide sufficient NEPA coverage. Environmenta l analysis of CERCLA actions is therefore

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

referenced in this EA to the extent that they in fluence 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 P UBLIC 

# I NVOLVEMENT



# 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 an d 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 O RGANIZATION OF 

# E NVIRONMENTAL 

# A SSESSMENT



# 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 th e 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 e ffect the environment both by th emselves 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 th at 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 N O 

# A CTION 

# A LTERNATIVE



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

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

Building 3019 Complex. Continued storage in th e Building 3019 Complex would require major

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

effective design life or have deteriorated be yond 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) an d to provide protecti on against potential

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

Building 3019 Complex would require additional structural and confinement systems upgrades

with a preliminary estimated cost of $20 millio n. (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 fi ssile content of the

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

2.2 P ROPOSED 

# A CTION 

# A LTERNATIVE



# 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 th e 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 th e activities authorized in the TCRA Memorandum are not

evaluated in this EA. Although th e CERCLA activities ar e 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 302 0 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 storag e 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 Build ing 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 tr uck for off-site tran sport 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 second ary 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 i llustrated 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 St ack is a 200 foot masonry stru cture with an interior brick

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

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

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

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

asbestos containing materials and polychlorinate d 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 th rough 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 ex isting Cell off-gas (COG), Glovebox off-gas

(GBOG), and Laboratory off-gas (LOG) ventila tion 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 Anne x Option (construction of the 3019 Annex to dry

and package the downblended material), the 3166 St ack (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 sp ecifications 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 select ed; however, a 3166 Stack analysis has not been

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

temporarily staged at constructi on laydown areas which may be locat ed either inside or outside

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

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

than two acres. Hillside Avenue3rdStreet 

# 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 characteristic s (e.g. physical and chemical co mposition, 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 dow nblend activities, an esti mated 1,038,000 pounds (472,000 kg) of

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

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

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

2.2.3 Temporary Storage of DUO at a St orage 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 appr opriate regulatory aut horities for the storage of DUO. Based on

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

Energy Solutions . The MSC facility was originally construc ted in the early 1980s to cast and roll

uranium for defense and energy applications. DUO would be received, st ored, 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 loca ted 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 temporar ily 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 transpor ted by tanker truck

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

(DOT)-compliant 3,500-gallon tanker tr ucks (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 tran sferred from the tanker truck to a stationary

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

tank located adjacent to Building 3019A in a concrete bunke r. 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 a ssist in overflow prevention.

# U-233 Material Downblending and Disposition Environmental Assessment

2-5 

# 2.2.6 Perform U-233 Downblend Activiti es 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 equi valent 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 significan ce and the nuclear critic ality controls would

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

concerns, and would satisf y 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 pr ocess for this stage is termed GC-1. A

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

stage would include operations to dry, packag e, 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 inspecti on 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 in to the operational configuration for use to

accommodate the configuration of each containe r 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 th e 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 analyt ical procedure. The storage containers that

formerly held the material would be assayed, char acterized, 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. Th e furnace, crusher station, and dissolvers would

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

2.2.7 Dry, Package, and Prepare Downble nded 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 ev aluates two mutually exclusive options for this

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

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

material via underground pipelines to the TW PC. If the TWPC Opti on is selected, then

construction and operation of the 3019 Annex would not occur.U-233 Material Downblending and Disposition Environmental Assessment2-6Figure 2.2-2—Conceptual U-233 Project Downblend ProcessSource: DOE 2009b

# U-233 Material Downblending and Disposition Environmental Assessment

2-7 

# Both of these options would perf orm the same basic functions—tha t 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 opti on 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 [FeSO 4 

# ], sodium hydroxide [Na OH] and/or potassium

hydroxide [KOH], and ma gnesium 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 monolith s would then be packaged in DOE-approved,

dual-layer containers. These contai ners would be constructed of st ainless steel and would include

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

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

over-packs to allow the material to be contact-handled. The materi al 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 th at the transuranic (TRU) content of the

downblended U-233 is sufficiently low such th at 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 disposi tioned at NTS. The ability to co-process waste

would help reduce overall waste quantities require d for disposal.

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

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

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

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

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

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

stored there until transfer to the TWPC.

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

solids content of the transferred slurry would typi cally be less than 5 per cent and would therefore

require significant water additions to facilita te transfer. The TWPC evaporator could reconcentrate the slurried materials in the MV STs. To accommodate the downblended material,

# U-233 Material Downblending and Disposition Environmental Assessment

2-8 

# modifications would be required for the LLLW pipe line, 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 p ackaged in DOT-compliant/Nuclear Regulatory

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

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

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

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

would contain 10 drums. Wast e forms from the TWPC pro cess 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 de molition and construction activities; U-233

downblend and preparation activiti es; and facility stabilization, shutdown, surveillance, and

maintenance activities. Secondary waste does not in clude 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 al so include any DUO not consumed during the

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

the project and would be managed in accordance w ith 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 desc ribed in Section 3.12. DOE/EA-1393 (DOE 2002a)

addresses transportion and dis posal 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 th e 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 characte rized 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. Activi ties would include removal of pr ocessing residues and radioactive

and hazardous materials. Radiological control prac tices 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 shutdo wn is complete, surveillance and monitoring

activities would be provided fo r the Building 3019 Comple x and associated f acilities until the

facility is transferred to D&D.

2.3 A LTERNATIVES 

# C ONSIDERED 

# B UT 

# E LIMINATED 

# F ROM 

# D ETAILED 

# C ONSIDERATION



# In addition to the Proposed Action and No Ac tion Alternatives, othe r 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 th e U-233 inventory (DOE 2004). Therefore, reuse

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

process were considered but were eliminated ba sed on cost and/or the te chnological basis. Other

downblend alternatives consider ed 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 A ND ENVIRONMENTAL IMPACTS

3.1 I NTRODUCTION



# This chapter provides background in formation to evaluate the poten tial environmental impacts of

the Proposed Action Alternative and the No Ac tion 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 asso ciated 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 exclusiv e options (the GC-2 process an d the TWPC process) to dry,

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

The Annex Option (GC-2 process) involves th e construction and opera tion of the 3019 Annex

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

of chemically stable uraniu m salt monoliths. The TWPC Opti on involves the transfer of

downblended material to the TWPC via undergr ound 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 L AND 

# U SE



# 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 qualit y, and national security. The

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

The TWPC is located near th e 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 ope rations 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 ch ange to the existing land use for the area in and around the

Building 3019 Complex under the No Action A lternative. The Building 3019 Complex would

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

expected to continue to be used for instit utional and research pu rposes. The Building 3019

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

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

repair. Significant additional ope rational 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 accide nts or theft of the mate rial. 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 Opti on 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 OR NL. Previously disturbed areas

outside of ORNL may be temporarily used as la ydown 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 imp act on land use at or in the

immediate vicinity of the Building 3019 Comple x. Although system modi fications would be

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

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

3.3 I NFRASTRUCTURE



# 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 s ecurity force, a wastewater treat ment plant, and a steam plant.

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

telecommunications, are available. These utili ties 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 Laborator y Land and Facilities Plan (ORNL 2002). In addition, Section

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

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

telecommunications. This information is incorpor ated 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 oper ations 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 alloca tion would not be affecte d. 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 t ons 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 conc rete and 25 tons of steel. These are small

quantities for an industrial construction project a nd could easily be provid ed by local suppliers

without prior notifi cation. Construction would also require m odest quantities of water, electrical

power, diesel fuel, and propane; however, thes e modest demands on infr astructure 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 emerge ncy power infrastructure would be needed.

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

and no new emergency power infrastructure woul d 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 electr ical power supply and tr ansmission system would

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

the Annex Option or the TWPC Option is sele cted, 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. Electri cal 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 leve ls. This estimated usage could be readily

accommodated by the existing ORNL water supply sy stem. 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 san itary wastewater per day above the No Action

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

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

Treatment Plant has adequate capac ity to handle the expected addi tional discharge of the sanitary

wastewater that would be genera ted from U-233 Project operati ons. 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 sma ll and could easily be satisfied by the existing infrastructure.

3.4 A IR 

# Q UALITY



# 3.4.1 Affected Environment

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

Clean Air Act (CAA) was promulgated to addre ss 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, l ead, nitrogen dioxide,

ozone, particulates less than 10 microns in diam eter, particulates less than 2.5 microns in

diameter, and sulfur dioxide. National Ambien t 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 nonattainmen t areas. Areas that lack sufficient data to

determine NAAQS compliance are designated as uncla ssifiable. Because there are seven criteria

pollutants, an area can be desi gnated 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 unclassifiabl e 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 sta ndards, and has also adopted regulations to

specify permissible short term and long term con centrations of hazardous and toxic air pollutants

(TDEC 2006).

The TDEC Division of Air Pollutio n 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 consis t primarily of ventilation air from radioactively

contaminated or potentially contaminated areas, vents from tanks and pro cesses, 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 abso rbable and nonabsorbable. Radiological emissions

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

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

consist of seven stacks located in Bethel a nd Melton Valleys, as lis ted 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 ventilati on 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 Cent ral Exhaust Facility Stack

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

identifies emissions for 171 individual isotop es 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 em issions for year 2008, the maximum off-site dose

was estimated at 0.4 mrem (DOE 2009c).

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

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

other emissions are exhaus ted 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 qual ity impacts associated with the No Action

Alternative would be small and within esta blished regulatory limits. Surveillance and

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

Complex. Some off-gas emissions from presen t operations are discha rged through the 3020

Stack and some are vented th rough the 3039 Stack Ventilation Sy stem. In year 2007, the Curie

content in emissions from the 3020 Stack and the 3039 Stack repr esented 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 upgrad es could result in te mporary 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-ga s 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 pr eparation and construction of the 3166 Stack,

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

materials to and from the Building 3019 Comple x and temporary laydow n areas. Operation of

construction equipment and delive ry trucks would generate com bustion tailpipe emissions and

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

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

preparation and construction activities were completed. Best management practices would

include the application of wate r on unpaved surfaces to reduce fugi tive emissions, and the use of

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

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

the impact of these emissions w ould be small and temporary. Isot ek would acquire a construction

permit from TDEC before c onstruction activities begin.

Emissions generated by constr uction activities within Building 3019 could include criteria

pollutants, asbestos, and radiologically contam inated 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 constructi on activities would be ve ry small compared to

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

temporary.

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

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

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

required to support demolition, construction, and pr ocess 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 exis ting 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 op eration. 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 exha ust through the 3166 Stack. Emissions associated

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

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

sulfate (GC-2 only), and trace radioactive contaminants. Emi ssions 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 contri bution 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 ai r permit application/modification process would

be initiated. The applicable air permits w ould 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, Build ing 3019 would be placed in safe and stable

shutdown and in preparation for D&D. Potential ai r 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 generate d 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 emissi ons 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 AERM OD 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 reason ably achievable (ALARA) principle, (2) ensure

the radiological exposure to workers in all occu pied on-site buildings (o utside the Building 3019

Complex) is less than 1.0 mrem pe r year, and (3) ensure the radiol ogical exposure to the off-site

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

result of the downblend operati ons. 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 m easures 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 Opti on, which would exhaust through the 3039 and 3166 Stacks, the

TWPC Option would exhaust through the 3039 St ack, 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 th e TWPC Option would be distributed between

stacks, separated by more than a mile, it is an ticipated that the overal l impacts on the region

would not be appreciably different from the im pacts for the Annex Opti on. Additionally, it is

expected that if the TWPC Opti on is selected, the dose to the publ ic 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 modifi cations attributable to implementation of the

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

regulatory compliance and public safety.

3.5 N OISE



# 3.5.1 Affected Environment

Noise is generally defined as unwanted sound. No ise energy naturally atte nuates (lessens) with

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

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

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

attenuation.

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

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

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

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

noise sources are those that do not move or that move relatively sh ort 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 fr om stationary sources are gene rally not distinguishable from

background noise levels.

# U-233 Material Downblending and Disposition Environmental Assessment

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# Occupational Safety and Hea lth Administration (OSHA) st andards (29 CFR 1910.95) define

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

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

exposure levels and exposure duration. As nece ssary, administrative controls, engineered

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

ear plugs) provide the means to protec t 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 Comp lex are typical of an

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

and nearby construction activitie s. Beyond the 3019 fenced area, th ese noise levels are generally

indistinguishable from background noise levels. Routine maintenan ce activities asso ciated with

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

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

subjected to a safety ev aluation, and the potential for hazar dous noise exposures are identified

and mitigated in accordance with project safety procedures.

The No Action Alternative would eventually requ ire 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 proj ect safety procedures. Construction activities

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

beyond the fenced area; however, the imp acts 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 activitie s could exceed 85 A-weighted decibels (dBA);

however, peak noise levels w ould generally be of short dur ation, and would attenuate to

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

temporary annoyance to ORNL workers near th e construction site. In creased noise at the

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

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

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

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

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

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

noise levels above safe threshol d levels. Best Management Practi ces, such as the installation of

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

caused by site preparation a nd construction activities.

Noise would also be gene rated by material transfer trucks th at travel to and from the Building

3019 Complex. Noise levels associated with tr uck 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 imp act on the overall noise levels at ORNL and would not be

expected to pose an annoyance to workers outside the Buil ding 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 so urces would be contained within a structure, and

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

would be small and would likely pose no annoyan ce 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 G EOLOGY AND 

# S OILS



# 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. Heter ogeneous soils overlyi ng 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 st orage 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 ab ility of a structure to withst and 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 struct ure 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) (D OE 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, thes e types of clays are not suscepti ble to liquefacti on, a condition

whereby soils transition from a so lid form to the form of a hea vy liquid. Soil liquefaction hinders

the ability of the soil to support a structure. The soils that support fou ndations of the Building

3019 Complex should therefore re main stable against liquefac tion during and after a seismic

event (ORNL 2004).

No effects to geological resources would o ccur under the No Action Alternative since the

activities associated with the continued stor age 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 distur b 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 occu r within previously disturbed areas used for

industrial applications. A dditional soil, if necessary, would be delivered to the facility from an

external source. It is anticipated that construc tion laydown areas would be located on previously

disturbed soils; however, if otherwise, the construction laydown areas would be sited and

prepared such that soils ar e not significantly impacted.

Standard soil retention and er osion practices would be app lied throughout the construction

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

Potential impacts associated with seismicity w ould 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 modificati ons would be to exis ting systems generally

internal to the structures and ar e not anticipated to disturb soils. It is anticipated that seismic

design requirements of the 3019 Annex would be mitig ated by the stability of the soils within the

Building 3019 Complex. Best Management Practic es for construction would provide adequate

mitigation for the planned activities.

3.7 W ATER 

# R ESOURCES



# 3.7.1 Affected Environment

Surface Water

The Building 3019 Complex is located in the Beth el Valley Watershed. White Oak Creek is the

main receiving surface water body in Bethel Va lley. 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 Fift h Creek (through the middle of cen tral ORNL). Flow from White

Oak Creek in Bethel Valley flows downstream to White Oak Lake, and even tually 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 ar ea 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 fr om 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 trans port of contaminants. In addition, extensive

# U-233 Material Downblending and Disposition Environmental Assessment

3-12 

# modification of the soils profile has altered the soil hyd rology 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 Alterna tive, surface and groundwater monitoring programs would be

continued at ORNL. The Building 3019 Complex co ntains several drain sources that send

wastewaters, process wastewaters, domestic wastewater, stormwat er 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 Alte rnative would not result in any changes to these

sources, and no additional adverse effects to water resources w ould 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. Su rface 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 imp ervious surface that would not be appreciably

altered. The present stormwater collection system in this area would con tinue to collect runoff

from the project area, and no new stormwater f acilities would be required. Construction of the

3166 Stack would be required for both the An nex 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 surf ace waters or contribute to turbidity of drainage tributaries in the

region.

Stormwater runoff from the Bu ilding 3019 Complex and the construction laydown area would be

controlled through implementation of appropriate Best Management Practic es. Exterior storage

vessels would be placed in diked areas for sp ill control. Stormwater discharges would be

controlled, if necessary, to remove soil and any cont aminants before discharge to storm drains or

surface waters. Concentrations of toxic and c onventional 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 groundw ater resources under normal operations.

The safe and secure shutdown of the Building 3019 Complex at the comp letion of the proposed

processing activities would not substantially cha nge 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, wh ich would be a net positive bene fit. 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 E COLOGICAL 

# R ESOURCES



# 3.8.1 Affected Environment

Vegetation in the vicinity of the Building 3019 Co mplex is limited, highly disturbed, and mostly

maintained by lawn equipment. Grasses and herbaceous vegetation dominate the vegetative

cover except for some Virginia pines locat ed to the north and south of the building.

Since there is very little habitat available for na tive animals, the majority of the animal species

found in the vicinity are species that adapt well to di sturbance and the presence of humans, such

as small rodents, birds such as starlings and pi geons, 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 w ould be expected to o ccur to any habitat or

wildlife. The Building 3019 Comple x is located in a highly dist urbed area of ORNL used for

institutional and research purpos es. Habitat in the vicinity of the Building 3019 Complex is

limited and mostly maintained by lawn equipment. Th e U.S. Fish and Wildlife Service, in a letter

dated May 17, 2004, stated that available endangere d species collection records do not indicate

that federally listed or proposed endangered or th reatened species occur w ithin the impacted area

of the proposed project (DOE 2007).

3.8.3 Proposed Action Alternative

No adverse environmental impacts would be expect ed 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 ar eas continuously utilized for

institutional and research purposes over an extended period of tim e. Habitat in the vicinity of the

Building 3019 Complex is already highly disturbe d and mostly maintained by lawn equipment.

This type of habitat precludes the presence of ra re, threatened, and endangered plant and animal

species. Therefore, impacts to ecolo gical resources would be small.

3.9 C ULTURAL 

# R ESOURCES



# 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 (Thomas on 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 pl utonium 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

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# plant were used for the constr uction of a full-scale plant at Hanford, Washington. After World

War II, Building 3019A served as a pilot plant fo r the development of ot her chemical separation

processes that have played a ma jor role in the advancement of chemical reprocessing techniques

used worldwide (Carver/Slater 1994).

The original facility was comprised solely of seve n 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 ar ound 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 in terior alterations incl ude the removal of all

original process equipment, modernization of equi pment 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 w ould 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 Pl an for the Oak Ridge National Laboratory, approved in 2005, and

make such changes only after a determination wa s made that such actions would not adversely

affect the potential listing of eligible buildi ngs 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 modificati ons to the structures, much of the original integrity of the

Building 3019 Complex remains intact. However, the in terior of the facility has lost its historical

integrity because of extensive internal modificati ons that were made to provide support for past

and current missions (DOE 2007). As part of the Proposed Action, addi tional modifications

would be made to accommodate various process activities.

Based on the preliminary design, modifications w ould be made to Cell 2, Room 201, and Room

147 to support the installation of new process equi pment. Rooms would be altered as necessary

to allow for the installation of new process eq uipment. The building u tility 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 w ould 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 facil itate delivery of large equipment. In addition,

the Proposed Action would include removal of the 3020 Stack, authorized via CERCLA TCRA

Memorandum (DOE 2009a), and construc tion of the 3166 Stack and the 3019 Annex.

DOE prepared a letter to the SHPO, dated Ma rch 18, 2008 (DOE 2008c). In this letter DOE

outlined the planned modifications to Building 3 019A to enable the U-233 Project. DOE further

# U-233 Material Downblending and Disposition Environmental Assessment

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# 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 Histor ic Preservation Plan for Oak Ridge National

Laboratory (ORNL 2005) is currently under DOE review, and existing Project Summary and

Archeological and Historical Re views prepared for this projec t 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 pr oposed Building 3019 Annex would not alter or

distract from existing buildings in the Buildin g 3019 Complex. Once this an alysis is completed,

any required assessment and notification to the SHPO would be performed.

3.10 S OCIOECONOMICS



# 3.10.1 Affected Environment

Region of Influence

The Region of Influence (ROI) is defined as th e 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 per cent 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 workfor ce resides in other co unties 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 in come, 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 fr om 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 inco me 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 im proved from 65.2 percent in year 2003 to 67.8

percent in year 2007. In years 2003 to 2007, the highest averag e 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

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# 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 Re servation and Regional Counties

Source: DOE 2001



# Population and Housing

Between 1960 and 1990, population growth in the ROI was sli ghtly slower than population

growth in the State of Tenness ee. The ROI population in creased at an aver age annual rate of

1 percent while the state popul ation increased 1.2 pe rcent, annually. Be tween 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 year s 1990 and 2002, while Anderson County population

has increased an average of onl y 0.4 percent annually (USCB 2005).

# U-233 Material Downblending and Disposition Environmental Assessment

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# 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 Anders on Counties which had populations of 53,306 and

73,246 in year 2007, respectively (BEA 2009).

There were a total of 244,536 housi ng 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 housi ng units were vacant,

although some vacant units were used for season al, recreational, or other occasional purposes.

Rental vacancy rates ranged from 9.0 percen t in Loudon County to 13.1 percent in Roane

County, while homeowner vacancy rates rang ed from 1.7 percent in Roane County, to

2.5 percent in Knox County. Owner-occupied housi ng units accounted for 64 percent of the total

housing units while renter-occupied units accounte d for about 28 percent (USCB 2001). In year

2000, the median value of owne r-occupied housing units ranged from $86,500 in Roane County

to $98,500 in Knox County and the median contract rent ranged from $3 98 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

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# Table 3.10-2—Housing Characteri stics 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 P opulations and Environmental

Justice Concerns

For the purpose of this analysis , a minority population consists of any census tr act in which

minority representation is greate r 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 B udget guidance (OMB 2000). Hispanics may be of

any race and are excluded from the totals fo r individual races to avoid double counting.

The distribution of minority a nd economically disadvantaged popul ations changed little between

years 1990 and 2000. Only one of the census tracts near the ORR currently includes a minority

population greater than the natio nal 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 la rgest group (29.6 percent). The proportion of

minority residents in all other Oak Ridge censu s 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 Un ited 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. With in the ROI, 13.1 percent of the population in

Anderson County had incomes below the povert y level. The proportion in Knox County was

12.6 percent, in Loudon County it was 10.0 percen t, and in Roane Count y it was 13.9 percent

(USCB 2001).

Economic Benefits of DOE Activities on the ORR

DOE employment and outlays ge nerate additional benefits to the ROI and state economies

through the creation of additional jobs. An analys is of the economic impacts of DOE operations

conducted by the Center for Business and Economi c Research at the University of Tennessee

revealed that:

# U-233 Material Downblending and Disposition Environmental Assessment

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# Expenditures by DOE and its contractors led to an increase of nearly 4 billion dollars in

the state of Tennessee gross state dome stic 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 tota l of $2.08 in personal income fo r 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 jo b 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 sc hool districts with 144 schools th at serve the RO I. 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 co llectively employ 494 full time police officers

(FBI 2007). The ROI also includes a total of 95 fi re stations with 644 career firefighters, 495

volunteer firefighters, and 166 paid-per-call fire fighters (USFA 2008). There are 14 hospitals in

the four county ROI that serve the regional populati on (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 activiti es are expected to co st an additional $8 to

$10 million per year for five to six years, and c onstruction activities to upgrade the facility are

estimated to cost about $20 million. It is assu med 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 enviro nmental 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 modifica tions to the TWPC and LLLW facilities would

generate an estimated 25 construction jobs a nd 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 hous ing, schools, medical services, or emergency

services in the ROI. The impacts, though sm all, would be positive for the community. No

demographic or environmental ju stice 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 c ontinued 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 servic es 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, employ ment 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 effect s their activ ities may

have on minority and low-income populations. Current informati on 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 in cludes 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. Si nce no socioeconomic impacts are expected, no

disproportionate impacts to minority or lo w 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 DO E employees and contractors exceed 13,700 in

Tennessee, and most live w ithin the ROI. These jobs have an average salary of nearly $65,000 in

comparison to the statewide av erage of less than $45,000 (Murra y 2009). Based on an average

annual income of $65,000, 171 additional jobs w ould 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 associ ated with current 3019A

operations would be eliminated. Th is 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 employ ment and the lack of impact s on population and tax revenues

indicate that there would be no impact on th e existing community se rvices of the ROI.

3.11 V ISUAL 

# R ESOURCES



# 3.11.1 Affected Environment

The landscape at ORNL is characterized by a se ries 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 loblo lly pine, although smaller areas have be en 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 blu ffs 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 quali ty of ORNL and surround ing areas. Although this

classification system is designed for undevelope d 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, th ere is no BLM classification fo r ORNL; however, the level of

development at ORNL is consistent with VRM Cl ass IV, which is used to describe a highly

developed area. ORNL structures are mostly lo w 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 mi ssion would continue for the foreseeable future.

Although there would be some reducti on 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 classi fication would be expected.

# U-233 Material Downblending and Disposition Environmental Assessment

3-22 

# 3.11.3 Proposed Action Alternative

Visual impacts associated with constructi on activities at the Building 3019 Complex would

include construction materials and equipment a nd 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 equi pment. Other visual impacts would be posed by

construction of the 3166 Stack and the 3019 Anne x. These impacts would be minor, temporary,

and consistent with thos e of an industrial area . After construction of th e facilities, construction

materials, equipment, and construction debr is 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 a nd LLLW facilities because all f acility modifications would be

incorporated into existing systems.

During the operation of the U-233 Project no si gnificant 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 fo r 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 complete d 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 st ructures which would minimize their prominence. Consequently,

operations for the Proposed Action w ould not be expected to degrad e the visual resources of the

Building 3019 Complex.

3.12 W ASTE 

# G ENERATION AND 

# M ANAGEMENT



# 3.12.1 Affected Environment

Over the years, use of the faci lities, rehabilitation, and construc tion 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 OR NL. As the use of these facilities has shifted

to storage, volumes of waste generation decr eased 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 inco rporated by reference and is not repeated here.

The U-233 Project is now responsible for the wa ste management activities for the Building 3019

Complex and has adopted waste management pro cedures which are similar to those of ORNL.

ORNL waste management activitie s include the transport of waste off-site to commercially

licensed treatment and disposal facilities for Resource Conser vation and Recovery Act (RCRA)

waste, Toxic Substances Control Act (TSCA) wast e, 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 th ose 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 Ca rlsbad, New Mexico (DOE 2000).

3.12.2 No Action Alternative

Under the No Action Alternative, waste storage, tr ansport, and disposal activities associated with

the Building 3019 Complex would be minimal. Wa ste generation would be associated with

normal routine maintenance activit ies. Facility upgrades would be required to support security

and safety requirements; therefore, waste gene ration would increase periodically over current

rates until the inventory is removed and the f acility placed in safe shutdown (DOE 2007).

Current operations generate around 3,500 cubic feet of LLW de bris and scrap metal annually.

This material is packaged a nd 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 constr uction of the 3166 St ack and the 3019 Anne x would generate

excess soils, concrete, scrap metal, and debris which may be contaminated from previous ORNL

activities. Excavated materials would be charac terized to determine the appropriate manner of

disposal. The nature of contamination for th ese materials could be radiological, RCRA, or

TSCA. An estimated 16,240 cubic f eet of LLW would be generate d by construction activities.

This material would be routed to NTS or other suitable facility for di sposal. In addition, an

estimated 1,000 cubic feet of chromium contaminated scrap metal (mixed LLW) would be

generated. This material would li kely be treated locally then ro uted 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 Build ing 3019A would generate an es timated 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 Dispos ition Plan. The plan would include collection

of additional characterization data, identificatio n 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 wast e 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 st eel, 55-gallon, Type B, IP-1 containers for offsite transport. Each container would be equi pped with a HEPA vent filter and a radon-220 decay

tube, or other suitable means to address ra don-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. Wast e 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 surf ace dose rate from the cask would not exceed 0.5 mRad per hour.

When GC-2 operations begin, an estimated three tr uckloads per week would be delivered to NTS

or other licensed disposal facil ity. An estimated 367 truckloads w ould 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, decontam ination 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/coat ings and light ballasts during dismantlement

activities. Secondary waste materials would be p ackaged in Type A containers and transported

off-site to a licensed disposal facility. An estimated 220 cubic feet of sec ondary waste would be

generated weekly. DOE/EA-1393 (DOE 2002a) a ddresses transportati on and disposal of

secondary waste.

The volume of waste materials generated by facil ity modifications and process operations would

be minimized through Best Management Practices and project waste ma nagement procedures.

ORR, local, and off-site treatment and disposal fa cilities have adequate capacity to accommodate

all forms of waste generated by construction of the 3166 Stack, Building 3019A modifications,

and downblend operations. Waste manage ment impacts would be small.

TWPC Option

The TWPC Option would necessitate facility modifi cations 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 ma terials would be trans ported to NTS or other

suitable facility for disposal. N on-radioactive RCRA hazardous waste would be transported offsite to RCRA-permitted commercial treatment and disposal faciliti es. 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 proc ess in Building 3019A)

would be transferred via the ORNL LLLW pipe line 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 ge nerate a slightly larger primary waste volume than the GC-2

process (no more than 20 percent larger). Se condary solid LLW for the TWPC Option would

include PPE, contaminated trash, and waste ge nerated by maintenance and repair operations.

Secondary waste would also be p ackaged in Type A containers fo r off-site transport. It is

anticipated the quantity of secondary waste woul d not be significantly different than from the

Annex Option. LLLW generated by the TWPC pr ocess would be transf erred 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 proj ect procedures. Impacts would be small and

additional mitigation is not anticipated.

3.13 H UMAN 

# H EALTH



# 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 oc cur naturally in the soils and

waterbodies, and the sun poses a natural source of background radiation. ORNL releases and

natural background sources collecti vely pose the potential to cause chemical and radiological

exposure, both on-site and off-site (DOE 2008b).

In general, human exposure pathways include dir ect contact, inhalation, a nd 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 wa ter 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 eff ective dose equivalent (EDE) th at an off-site individual may

receive through all exposure path ways and all radionuclides rele ased 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 th e protection of workers from harmful radiation. For all DOE

facilities, occupational radiat ion exposure is administrativel y limited to a maximum of

2,000 mrem per person per year. As outlined in th e 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 a dverse health effects from chem ical 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. Path ways of concern for non carcinogens 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 conti nue long-term surveillance and ma intenance of the facility. It

should be noted that the facility was constructed more than sixt y 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 woul d therefore be required to mitigate this risk.

The hazards associated with routine operations are predominantly radiation exposure to the

facility worker, in particular, wh en containers of radioactive mate rial are retrieved from storage.

This exposure is maintained well below the DOE guidelines for radiation workers and is

controlled through strict adhere nce to the Project Radiological Protection program. On-site

workers and the public are shielded from extern al radiation exposure by engineered structures

and by the physical structur e 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 explos ion in the facility. Th e facility ventilation

system continuously replaces the air to flush out airborne contaminants. In this way, the

ventilation system provides mitigation for th e potential exposure to respirable hazards.

Therefore, it is anticipate d 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 re sidents of the United States, the average background

radiological exposure, in terms of the effectiv e dose equivalent (EDE), from natural and manmade sources is 360 mrem per year. Natural sour ces (such as radon, cosmic radiation) represent

300 of the 360 mrem. Based on the national average, natural extern al radiation sources represent

55 of the 300 mrem of to tal natural background radiation exposur e. 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 ra diation 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 north east of the 7911 Stack. The major ity 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 St ack and the 3039 Stack represented less than 0.4

percent of the total st ack 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 work ers 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 in sulation, 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 oc cupational 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 Altern ative is described in

DOE/EA-1574 (DOE 2007) and summa rized 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 un der 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 inge stion of potable water and fish. For ingestion

of potable water, HQs were estimated upstr eam (Clinch River kilometer [CRK] 70) and

downstream (CRK 16) of ORR disc harge 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 th e fish consumption pathway, HQs were estimated

for the consumption of noncarcinogens, and intake/chronic-daily-i ntake ratios, I/I(10 -5 

# ), were

estimated for the consumption of carcinogens detected in sunfis h and catfish collected both

upstream and downstream of the ORR discharge point s. For consumption of sunfish and catfish,

an HQ greater than one was calculated for Aroclo r-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 ca tfish collected at all three lo cations. In catfish, an I/I (10 -5 

# )

ratio greater than one was calculate d 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 th e 3166 Stack would be expected to disturb a

small area of land. It is possible that these soil s 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 (thos e involved in the U-233

Project) are described in DOE/EA-1574 (DOE 2 007). 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 ra tes 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 rema in below 500 mrem per year. This goal would be

achieved through a combination of facility design features (radiation shie lds) and administrative

controls (limited worker exposure times). To ensu re the protection of si te 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 th e soil and allow for the migration of any

contaminants would be local and would not be exp ected to migrate to the extent that it would

cause any radiological exposure to the public. Radiological emi ssions from operations in the

3019 Annex would be filtered and exhauste d through the 3166 Stack. The maximum annual

radiological exposure to any memb er of the public attr ibutable 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 dow nblend operations are completed and D&D activities have been

completed. The TWPC Option would require modificat ions to the existing ventilation systems to

address radon-220 formation. After the modificati ons are applied, the impacts of radiological

stack emissions would be expected to be comparab le to the historical levels for this facility.

Chemical Exposure to the Workers

Bulk chemicals used in the GC-1 process ar e described in DOE/EA-15 74 (DOE 2007) and is

incorporated by reference. Bulk chemicals used in the GC-2 process include the downblended

uranyl nitrate, sodium hydroxide, iron sulf ate, 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 th e ventilation system. Proj ect health and safety

procedures would govern the receipt, storage, a nd use of these chemical s 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 ca ptured 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 w ould be filtered and routed out the facility

ventilation system. Under normal operations, the qua ntities and concentrations of the chemicals

involved for either option would not pose any ch emical exposure hazard to members of the

public.

3.14 T RANSPORTATION



# 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 fa tality (LCF) to the truck drivers

and to members of the public caused by radiati on shine from routine transportation or by

exposure to radioactive materials released in a tr affic accident. The potential for traffic delays are

determined based on current traffic levels, road way 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 anticipa ted increase in traffic levels. DOE software

RADTRAN and TRAGIS, developed by Sandia Nati onal Laboratories and ORNL, respectively,

are applied to estimate the risk of latent cancer fatality from routine tran sportation 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 circ ulation. Off-site circulation consists of staff

movements to and from work and among the va rious 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, move ment of personnel between buildings and to and

from parking lots, and contractor an d 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 seve ral 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 ma jor east and west corridors are White Oak and

Central Avenues. Materials are transported via th e 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 Repr ocessing Center, and the Robotics and Process

Systems Complex. Several other access roads serv e 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 trav el to and from ORNL each day to support the

various site missions. The averag e 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 a void the rush hour. Road maintenance and the

movement of heavy equipment or escorted ship ments typically occur during the workday after

traffic flow has subsided.

Transportation of hazardous substances or radioactiv e materials poses the risk of injury. There is

the risk of an accident whereby the release of ma terials leads to hazardous exposure, and in the

case of radiological materials, the radiological sh ine poses the potential for LCF in the exposed

population. Sandia National Laborator ies developed software packages to quantify transportation

risk. Quantitative results are presented in terms of the probability of a fatality. If transportation

involves carcinogenic or radioactiv e materials, there is the pote ntial for risk from an LCF.

3.14.2 No Action Alternative

Transportation impacts for the No Action Alternative are desc ribed 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 30 19 Complex at ORNL. Therefore, there would be

no transportation or transportati on risk other than normal shipment of waste generated from

inspection and maintenance activities and from the transport of empl oyees to conduct such

activities. Traffic would likely continue to rema in close to current levels, and no impacts would

be expected to occur.

3.14.3 Proposed Action Alternative

Transportation associated with the Proposed Ac tion is grouped into six general categories:

(1) transport of construction material s and equipment; (2) transport of DUO from SRS to Oak

Ridge; (3) transport of the DUO to NFS in Erwin Tennessee; (4) transpor t of DUN from NFS to

ORNL; (5) transport of downblended material via underground pipe line to the TWPC; and

(6) transport of the downblended U-233 off-site for o ff-site disposal to NT S 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 a nd 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 ar e 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 A lternative over the 54 months of demolition and

construction. The present fence line would be expa nded to allow for safer and more secure truck

access along Hillside Avenue. The destination fo r 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 constructi on 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 c onstruction traffic on peak traffic levels.

DUO From SRS to Oak Ridge

DUO for the project would be delivered via truc k from SRS to Oak Ridge for interim storage

before transport to the NFS f acility in Erwin, Tennessee for c onversion to DUN. The preferred

route would use Interstates 26 and 40 and woul d 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 mile s. Each shipment would consist of about 23

drums of material inside a Sea-La nd-type container. This transpor tation 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) ov er a distance of about 145 miles. Each

shipment would contain 23 drums secured within a Sea-Land t ype container.

The methods to determine radiological and non-ra diological impacts for the transportation of

radioactive materials are described in a cal culation package (TetraTech 2009). The nonradiological impacts (including fa talities due to accidents and i nhalation 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 tr ansported from Erwin in liquid cargo tank

trailers or other DOT-compliant IP-1 type pa ckages. The NFS facility in Erwin is about 145

miles from ORNL. Transport of this product woul d require about 235 truckloads of DUN

solution. Each truckload woul d contain around 2,768 kg of DUN on a dry weight basis. The

increase in traffic levels from this small number of truckloads would po se 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 incide nt-free radiological

impacts were estimated to be 4.11×10 -5 

# fatalities, and the LCFs due to release of radioactive

materials due to transportation acci dents 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 tr ansfers 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 w ould 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 sh ielded 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 tota l 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 materi als 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 contai ners for off-site dispos al. Although the TWPC

process would potentially genera te 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 impact s are judged to be not significantly different

than for the Annex Option.

# U-233 Material Downblending and Disposition Environmental Assessment

3-33 

# 3.15 A CCIDENTS



# 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 protec t 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 inve ntory of U-233 would remain stored within the

Building 3019 Complex. Major facility upgrades a nd retrofits would be required to ensure the

continued safe storage of the material, and an estimated 400 c ontainers would have to be

repackaged to ensure adequate protection against pot ential nuclear criticality accidents or theft of

the material. A detailed discussi on 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 Ac tion have not changed since the issuance of

DOE/EA-1574 (DOE 2007). The key differe nce 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 re sults 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. Accident s 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).

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# U-233 Material Downblending and Disposition Environmental Assessment

4-1 

# 4.0 CUMULATIVE IMPACTS

4.1 I NTRODUCTION



# CEQ regulations that implement the procedural pr ovisions of NEPA define cumulative impact as

the “impact on the environment which results fro m the incremental impact of the action when

added to past, present, and re asonably foreseeable future acti ons regardless of what agency

(Federal or non-Federal) or pe rson undertakes such other ac tions” (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 cu mulative impact analysis in this EA include

land use, infrastructure, air quality, socioe conomics, waste management, human health,

transportation, and accidents. Th is cumulative assessment is c onducted 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 in itiatives are identified and described below.

4.2 C URRENT AND 

# P LANNED 

# I NDUSTRIAL 

# A CTIVITIES IN THE 

# R EGION



# Current, large-scale industrial activities in the region includ e demolition and site remediation

activities at ETTP; normal operation s at the Spallation Neutron Sour ce 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; opera tion of the 1456 MW, coal-fire d, 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 pl anned for ORNL and Y-12 as proposed by the

Integrated Facility Disposition Project (IFDP). Th e main goals of the IFDP are to eliminate high

risk legacies of the Manhattan Project and Cold War, achieve e nvironmental 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 Reinvest ment and Recovery Act. The scope of work

includes decontamination, deactivation, and demoliti on of contaminated facilities; restoration of

soil and groundwater contaminati on areas; legacy waste disposal and facility ope rations; utility

reroutes, non-mission equipment removal, and faci lity construction and improvements. Footprint

reductions include the removal of 327 ORNL f acilities (1.5 million square feet) and 112 Y-12

facilities (3.9 million square feet) for a total fo otprint 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 C UMULATIVE 

# A SSESSMENT



# 4.3.1 Land Use

After downblend activities are comp leted and the material has been transported off-site, the

U-233 Project would place the Building 3019 Co mplex in safe-shutdown for eventual

demolition. The demolition of these facilities along w ith 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 yiel d 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 electr ical, gas, steam, and water

demands and will continue for less than five y ears. 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 infrastructu re (for power, water, fuels, natural gas, and

other resources) would diminish. In the long term, the Proposed Action would cont ribute to a

cumulative reduction in the infrastructure demand and would therefore yi eld 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 Ac tion represent a small fraction of the current

conditions. Once downblend activ ities are completed and th e Building 3019 Complex is

demolished, the cumulative radiological impacts would be slightly reduced.

Facility demolition, site preparation, and cons truction associated with the Proposed Action

would generate modest levels of fugitive dust and tailpipe emissions. These emissions would

combine with similar emissions from other regi onal sources (such as the fossil-fired Tennessee

Valley Authority power plants) and from planned demolition and cons truction activities at

ORNL (such as those identified in the IFDP). It is expected that the cumulative emissions could

pose a small and temporary dete rioration of regional air quali ty; however, as the ORNL

demolition and construction projects are complete d, overall air quality impacts would improve,

as there would be fewer facilitie s to heat and cool and therefor e less demand for power from the

nearby fossil energy plants. The cumulative imp acts of the Proposed Action may pose a small

and temporary degradation to ai r quality, but would ultimately yield a cumulative air quality

improvement.

4.3.4 Socioeconomics

Although additional planners, c onstruction workers, and operati ons workers woul d be needed

for the Proposed Actio n, 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 work ers; however, the number of work ers needed would not represent a

# U-233 Material Downblending and Disposition Environmental Assessment

4-3 

# substantial portion of the current ORNL workfo rce. The workforce available in the ROI would

be adequate to satisf y the demand for additiona l workers. Hous ing, public serv ices, hospital

resources, and other socioeconomic resources are adequate to accommodate the anticipated

workforce and their families. Theref ore, it is not antici pated that the Proposed Action and other

proposed activities in the regi on would yield any adverse cumula tive socioeconomic impacts.

4.3.5 Transportation

Demolition and construction activities for the Propos ed Action would yield a small net increase

in the flow of traffic to and from ORNL. Th e 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; how ever, these activities w ould be performed over a

15 or 20 year time span, which would mitigate larg e 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 Acti on 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 activiti es for the Proposed Action would also generate waste, but

the volume would be very small compared to ot her 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 es timated 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 co ntribute to this tota l. Cumulative impacts of the Proposed Action and

other foreseeable actions may pose a large dema nd for waste disposal f acilities, 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 shutdow n for D&D would also

have a positive cumulative impact on huma n health for workers and the public.

# U-233 Material Downblending and Disposition Environmental Assessment

4-4 

# 4.4 C UMULATIVE 

# I MPACTS 

# S UMMARY



# Although it is not possible to prec isely determine all projects th at 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 wast e generation and air pollution associated with

demolition of legacy facilities and new construc tion activities. Most of the major activities

remediate the environment and remove or st abilize future sources of contamination.

# U-233 Material Downblending and Disposition Environmental Assessment

5-1 

# 5.0 PERMITS AND ENVIRONM ENTAL REGULATION

5.1 P ERMITS



# Federal, state, and local regulatory authoritie s have established requirements that govern

demolition; construction; operations; treatment and release of effluents; waste management;

transportation; and other aspect s of the Proposed Action. Some of the proposed activities would

require an approved permit from the regulatory au thority. A permit is e ssentially a contract

between the applicant (Isotek and/or DOE) and th e 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 a pplicable regulatory requi rements are satisfied.

There are several permits already in place that cover current operations at the Building 3019

Complex, the LLLW transfer pipe lines, and the TWPC. Proposed ac tivities that fall outside the

parameters of established permits must be modified; and similarly, a new permit must be

obtained for activities not cove red by current permits.

Isotek currently manages emissions (3020 St ack) 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. Pu rsuant 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 constr uction 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 effec tive on August 1, 2008; the permit expires on

July 30, 2013.

The U-233 Project would not procee d with construction or operati ons until all necessary permits

and authorizations are establishe d. Permits related to the U-233 Pr oject would be routine, and no

unusual circumstances are expected. Sufficient inform ation exists to prepare applications, and it

is expected that permits could be received in a timely manner.

5.2 E NVIRONMENTAL 

# R EGULATION



# Activities conducted at ORNL are required to be in compliance with environmental standards

established by Federal and stat e statutes and regulations, ex ecutive orders, DOE Orders,

contract-based standards, and compliance and settlement agreements. Principal among the

regulatory agencies are TDEC and the EPA. Th ese agencies issue permits, review compliance

reports, participate in joint monitoring programs, inspect facilities and operations, and oversee

compliance with applicable regul ations. 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.

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# 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 asso ciated with the Proposed Action and to seek

approval. Two separate response letters were pr ovided from the SHPO, and each letter confirmed

that impacts to the proposed activities are adeq uately 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.

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# 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 Sa fety 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 Hea lth Administration (OSHA) standards.

40 CFR Part 50 U.S. Environmental Protect ion 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 Environmen tal Quality (CEQ), “Regulations for

Implementing the Procedural Provisions of the National

Environmental Policy,” Code of Fe deral Regulations, Office of the

Federal Register, National Archiv es and Records Administration,

U.S. Government Printing Offi ce, Washington, D.C., Revised

July 1, 2008.

BEA 2009 Bureau of Economic Analysis , Economic Statistics, Washington,

D.C., Available at: bea.doc.gov/

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7-2 

# Carver/Slater 1994 Architectural/Histori cal 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 Qu ality. 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 Secretar y 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, a nd 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 Environmenta l 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 Guide lines 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.

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# DOE 2007 Environmental Assessment for U-233 Stabilization, and Building

3019 Complex Shutdown at the Oak Ridge National Laboratory

, Oak Ridge, Tennessee, DOE/E A-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 Re port 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 Tennesse e Historical Commission titled

" National Historic Preservati on 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 Radionucli de National Emission Standards for

Hazardous Air Pollutants Report fo r the Department of Energy

Oak Ridge Reservation. August.

Executive Order 12898 Federal Actions to A ddress Environmental Justice in Minority

Populations and Low Income Populations. February.

FBI 2007 U.S. Federal Bureau of I nvestigation, 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.

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# 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, Cent er 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 Nati onal 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 Labor atory, Oak Ridge, Tennessee.

ORNL 2005 National Historic Preservati on Act Historic Pres ervation 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 Hi storical 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 Preservati on Act Historic Pres ervation 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.

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# USFA 2008 Fire Stations and Fire Fight er Personnel. for year 2007 as listed by

the United States Fire A ssociation. Available at

http://www.usfa.dhs.gov/appli cations/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 Repor t - List of Hospitals in Tennessee,

September. Available at http://health.usnews.com/health/besthospitals/index/TN.

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blank.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐1of18JohnOwsley,TennesseeDepartmentofEnvironmentandConservation,DOEOversightDivision,OakRidge,TennesseeNo.SectionCommentResponse1GeneralThedocumentshoulddiscussotherdispositionalternativesforthedownblendedwaste,shouldDOEfailtosatisfytheNTSdispositiondeadlineof2010.DOEshouldoutlineplansforotherdispositionoutletsforthemixedwaste,iftheWIPPacceptancecriteriaarenotmet.AdesigngoalfortheU‐233downblendprojectistoproduceawasteformthatdoesnotexceedToxicityCharacteristicLeachingProcedure(TCLP)criteriaforhazardouswaste,andthereforewillnotmeetthedefinitionofmixedlowlevelwaste(MLLW).ThewasteformproducedbytheU‐233downblendprojectwillbelow‐levelwaste(LLW).Consequently,theNTSdeadlineisnotapplicable.2GeneralDOEshouldhaveadetailedplanforthemanagementofanyunusedDUOobtainedforthisproject.Theprojectbaseline(schedule,budget,andplan)willberevisedatthe90%designmaturity.DispositionofunusedDUOwillbeincludedintherevisedbaseline.Astatementisaddedtosections2.2.9and3.12toaddressdispositionofunusedDUO.ItshouldalsobenotedthattheSRSDUOiscurrentlyapprovedfordispositionattheEnergySolutionsClive,UtahfacilityorNTS.3Section2.2.5,TransportofDUNfromNFStoORNLBecauseitisliquid,aspillofDUNwouldbedifficulttorecover.Identifytheprecautionstakentoensuretankertruckswillnotleakintheeventofanaccident.TheprojectwilluseDOTcomplianttankertruckstotransportDUN.Suchshippingcontainersaredesignedtowithstandimpactsfromaccidentsandareapprovedforuseconsistentwithprojectrequirements.4Section2.2.6,PerformU‐233DownblendActivitiesattheBuilding3019ComplexDNFSBisnotspelledcorrectly[Concur]Correctionapplied.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐2of18No.SectionCommentResponse5Section2.2.7Pleaseaddmorediscussionofthechemicalspeciesthatwouldemergefromthetwotreatmentoptions.Presumably,theannexoptionwouldresultinaverylowsolubilitysaltandtheTWPCoptionwouldproduceuranylnitrateabsorbedinacementblock.Identifythespecificsaltthatwouldbeproducedbytheannexoptionandhowtheuranylnitratewouldperforminaleachtest.ItshouldbenotedthattheMVSTwasteisTRUwasteandthatamixtureofthiswastewiththeU‐233coulddiverttheMVSTwastefromtheWIPP.Theannexoptionwouldproduceastable,low‐solubilitysaltwasteform.Itiscurrentlyanticipatedthissaltwillbeprimarilyintheformofsodiumdiuranate;however,thecurrentformulationhasnotbeenfinalized.Althoughthefinalformofthewastesaltmaybeslightlydifferentfromcurrentlyanticipated,itwouldstillbeintheformofastable,low‐solubilitysaltthatissuitablefordisposal.IntheTWPCoption,theuranylnitratematerialwouldbeblendedintothematrixofthecement,andtheprocess/formulationwouldensureawasteformthatissuitablefordispositionatNTS.Regardlessoftheadditionofdownblendeduranylnitrate,MVSTwasteprocessedthroughtheTWPCisnotprogrammedforfinaldispositionatWIPP.MixtureofdownblendeduranylnitratewithMVSTwastewouldhavenoimpactonfinaldisposition.IfthewasteformproducedbytheTWPCcouldnotsatisfyTCLPcriteria,theTWPCoptionwouldbedismissedfromconsideration.6Section3.2.3,ProposedActionAlternativeWhydoestheTWPCoptionhaveanyimpactonthe3020and3166stacks?Constructionofthe3166Stackandremovalofthe3020StackwouldoccurforeithertheAnnexorTWPCoption.7Section3.3.2,NoActionAlternativeItseemsthatanimpactoninfrastructureshouldincludecontinuedmaintenanceoftheU‐233storagefacilityandassociatedsafeguardssuchassecurityandcriticalityalarms.ThesubjectofinfrastructureinthisEAaddressesthepotentialimpactsonavailableutilitiessuchassewer,potableandprocesswater,electricalpower,andnaturalgas.Safeguards,security,andcriticalityalarmsarenotconsideredinfrastructure.Noincreasedneedforinfrastructurewillresultfromthenoactionalternative.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐3of18No.SectionCommentResponse8Section3.4.1,AffectedEnvironmentWhatareVOGemissions?Theacronymisnotincludedinthelistofacronymsandmaybeatypographicalerror[Concur]VOGisanacronymforVesseloff‐gas.Itisaddedtotheacronymlist.9Section3.4.2,NoActionAlternativeIdentifytheU‐233inventoryoperationsthatresultinoff‐gasemissions?Staticstoragerequiresthereliableoperationofventilationsystemstoensureanyoff‐gasemissionsarecapturedandhandledconsistentwiththeapplicableTDECairpermit.10Section3.4.3ProposedActionAlternativePleaseexplainhowthe3166stackwouldimpacttheTWPCoption.Thedesignofthe3166Stackwouldbeafunctionoftheanticipatedemissions.Feweremissionswouldbeexhaustedoutthe3166StackiftheTWPCalternativeisselectedduetotheeliminationoftheAnnexfacility.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐4of18E.PatrickMcIntyre,Jr.,TennesseeHistoricalCommission–DepartmentofEnvironmentandConservation,Nashville,TennesseeNo.SectionCommentResponse11GeneralInresponsetoyourrequest,receivedonMonday,October5,2009,wehavereviewedthedocumentsyousubmittedregardingyourproposedundertaking.OurreviewofandcommentonyourproposedundertakingareamongtherequirementsofSection106oftheNationalHistoricPreservationAct.ThisActrequiresfederalagenciesorapplicantforfederalassistancetoconsultwiththeappropriateStateHistoricPreservationOfficebeforetheycarryouttheirproposedundertakings.TheAdvisoryCouncilonHistoricPreservationhascodifiedproceduresforcarryingoutSection106reviewin36CFR800.Youmaywishtofamiliarizeyourselfwiththeseprocedures(FederalRegister,December12,2000,pages77698‐77739)ifyouareunsureabouttheSection106process.YoumayfindadditionalinformationconcerningtheSection106processandtheTennesseeSHPO’sdocumentationrequirementsat:http://www.tennessee.gov/environment/hsit/federal/sect106.shtml.Consideringavailableinformation,wefindthattheprojectascurrentlyproposedwillNOTADVERSELYAFFECTANYPROPERTYTHATISELIGIBLEFORLISTINGINTHENATIONALREGISTEROFHISTORICPLACES.Therefore,thisofficehasnoobjectiontotheimplementationofthisproject.PleasedirectanyquestionsandcommentstoJoeGarrison(615)532‐1550‐103.Noted.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐5of18OakRidgeReservationLocalOversightCommittee,Citizens’AdvisoryPanelNo.SectionCommentResponse12GeneralTheCitizensAdvisoryPanel(CAP)oftheOakRidgeReservationLocalOversightCommittee(LOC)hasreviewedandcommentedontheDraftEAfortheU‐233MaterialDownblendandDispositionProjectatORNL.Weagreewiththeneedtodispositionthismaterial,butwestronglydisagreewiththedecisionnottorecoverthethorium‐229thatistheprecursorforactinium‐225andbismuth‐213,progenyisotopesusedformedicalpurposes.Uranium‐233istheonlysourceofTh‐220,andtheORNLstockpileistheonlysignificantamountofU‐233availableinthecountry.Consequently,theCAPrejectsboththepermanentdisposaloptionsoutlinedintheEAandprefersinsteadthatDOEkeepthedownblendedmaterialinsafestorage.DOE/EA‐1574titled“EnvironmentalAssessmentforU‐233StabilizationandBuilding3019ComplexShutdownattheOakRidgeNationalLaboratory”proposedtodownblendtheU‐233inventoryandplaceitinstorageuntiladecisioncouldbemaderegardingdisposal.SubsequentstudieshavedeterminedthattheinventorycanbesafelyprocessedtoastableformfordisposalattheNevadaTestSite.ThedecisionsthathavebeenmaderegardingdispositionofthematerialstoredatBuilding3019areconsistentwiththeNovember2005,ConferenceReportfortheEnergyandWaterDevelopmentandRelatedAgenciesAppropriationsActforFiscalYear(FY)2006.Inthisreport,CongressdirectedDOEtoterminatepromptlytheMedicalIsotopeProductionandBuilding3019ComplexShutdownProjectandprovidedFY2006fundsintheDefenseEMappropriationsfordispositionofthematerialstoredatBuilding3019.TonotpursuethepermitteddisposalofthematerialstoredatBuilding3019wouldbecontrarytoCongressionaldirection.13GeneralAgeneralcommentisthatthesubjectEA(DOE/EA‐1651)shouldexplicitlyoutlinetheproposeddifferencesinapproachfromthosestatedinDOE/EA‐1574.ThepurposeoftheEAistoanalyzethepotentialenvironmentalimpactsofproposedoperationalchangesassociatedwiththeU‐233downblendingproject.Theproposedoperationalchanges,thescopeoftheproject,andthescopeoftheEAareexplainedinSection1.4.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐6of18No.SectionCommentResponse14Section2.3InMay2009,theInspectorGeneral(IG)releasedSpecialReportDOE/IG‐0795ʺMeetingMedicalandResearchNeedsforIsotopesDerivedfromUranium‐233ʺthatcriticizesthedecisionbyDOEandtheCongresstonotrecovertheTh‐229.TheIGrecognizesthenationalshortageoftheprogenyisotopesfromTh‐220formedicaluses.InAugust2008,theOfficeofScienceheldaworkshopʺTheNationalNeedsforIsotopes:PresentandFutureʺdocumentedinReportDOE/SC‐0107.AdiscussionoftheprojectedneedsforAc‐225andBi‐213derivedfromTh‐229beginsonpage21ofthisreport.Byyear2014over50,000mCioftheseisotopeswillbeneededtosupportmedicalresearchanddevelopmentandclinicaltrials;thisisanamountfarinexcessofwhatisavailablefromexistingresearchholdingsofTh‐229.Thecurrentstatusisthatlimitedsuppliesarepreventingclinicaltrials.ThesubjectEAstatesinSection2.3ʺWiththeexceptionofanexpressionofinterestfromtheNationalNuclearSecurityAdministrationforasmallquantityofU‐233insupportofweaponstestprograms,thereisnoprogrammaticusefortheU‐233inventoryʺcitingthe2004DOE/EA‐1488.Infact,the2008ORNLreportonthenationalneedforisotopesdocumentsthatthereisapressingnationalneedforU‐233progenyisotopes.BecausetheisotopeproductionmissionhasbeenassignedtotheOfficeofScience,EnvironmentalManagementmustensurethattheOfficeofSciencehastheopportunitytomakeaformaldeterminationofitsneedforU‐233.Thereportsontheneedformedicalisotopesnotwithstanding,therequestfromNNSAhasbeentheonlyinquiryrelativetothematerialstoredatBuilding3019.Nootherorganization,agency,orDOEProgramOfficehasexpressedinterestinreceivinganyofthematerialstoredatBuilding3019.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐7of18No.SectionCommentResponse15GeneralInthepriorEAonthisproject(DOE/EA‐1574),thepreferredDOEoptionwastoputthedownblendedU‐233materialintosafestorage.AtthepublicmeetingforthatEA,DOEofficialsassuredthepublicthatTh‐229couldstillbeextractedfromthedownblendedmaterial.InthecurrentEA,DOEproposespermanentandirretrievabledisposalofthedownblendedmaterial,whichwouldpreventtheextractionofTh‐229.Consequently,theCAPisopposedtobothofthedisposaloptionsinthesubjectEA.Asstatedabove,pursuanttoaCongressionaldirective,DOEisexecutingtheU‐233downblendingprojecttodispositionthematerialstoredinBuilding3019andtoaffectthesafeshutdownoftheBuilding3019Complex.16GeneralConsideringthattheEAfortheU‐233MaterialDownblendandDispositionProjectproposesmajorchangestotheaction,DOEshouldholdapublicmeetingtoexplainthenewapproachandextendthecommentperiod.PastpublicmeetingsontheU‐233projecthavehadsubstantialstakeholderinterest.TheEAispublishedtoinformthepublicaboutthepotentialenvironmentalimpactsassociatedwiththeproposedoperationalchangesassociatedwiththeU‐233downblendingproject.DOEhasconcludedtheproposedoperationalchangesandassociatedimpactsdonotrisetoalevelthatwouldnecessitateextendingthecommentperiodorholdingadditionalpublicmeetings.WhileDOEisnotplanninganypublicmeetingsregardingthisEA,DOEiswillingtomeetwithyourorganizationtodiscussprojectinformation.PhillipH.Roush,TennesseeDepartmentofEnvironmentandConservation,DOEOversightDivision,OakRidge,TennesseeNo.SectionCommentResponse17AcronymsDefineAERMODasAmericanMeteorologicalSociety/EnvironmentalProtectionAgencyRegulatoryModel[Concur]Acronymadded.18AcronymsDefineCAP88asClearAirActAssessmentPackage1988[Concur]Acronymadded.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐8of18No.SectionCommentResponse19AcronymsDefineLLCasLimitedLiabilityCorporation[Concur]Acronymadded.20AcronymsDefineVOGasVesseloff‐gas[Concur]Acronymadded.21Page2‐3ReplaceʺCellOff‐GasʺwithʺHotCellOff‐GasʺThesystemistermedcelloff‐gas.22Page2‐3Replaceʺpreviousdisturbedʺwithʺpreviouslydisturbedʺ[Concur]23Page2‐4,Section2.2.5,SecondParagraphReplaceʺstainlesssteeltanklocatedʺwithʺstainlesssteeltank,encasedinaconcretebunker,locatedʺNochange.Thetankislocatedinaconcretebunker;encased,inouropinion,givesaincorrectdescription.24Page2‐4,Section2.2.5,SecondParagraphReplaceʺhighlevelalarmʺwithʺhighlevelalarmtoassistinoverflowprevention.ʺ[Concur]Suggestedchangeapplied.25Page2‐5,Section2.2.6,FirstParagraphReplaceʺDNSFBʺwithʺDNFSBʺ[Concur]Suggestedchangeapplied.26Page2‐5,Section2.2.6,SecondParagraphReplaceʺTheprocessforthisstageistermedGC‐1,andaconceptualʺwithʺTheprocessforthisstageistermedGC‐1.Aconceptualʺ[Concur]Suggestedchangeapplied.27Page2‐5,Section2.2.6,ThirdParagraphReplaceʺequipmentchangeoutʺwithʺequipmentchange‐outʺ[Concur]Suggestedchangeapplied.28Page2‐5,Section2.2.6,FourthParagraphReplaceʺThestoragecontainersʺwithʺTheoldstoragecontainersʺNochange.29Page2‐7,AnnexOptionReplaceʺSteamandnitrogenʺwithʺCondensateandnitrogenʺReplacedwith“Steamcondensateandnitrogen,...”30Page2‐7,AnnexOptionReplaceʺwouldincludeameansʺwithʺwouldincludetechnologyʺ[Concur]Suggestedchangeapplied.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐9of18No.SectionCommentResponse31Page2‐7,AnnexOptionReplaceʺwouldbeplacedintoʺwithʺwouldbeplacedinʺ[Concur]Suggestedchangeapplied.32Page2‐8,Section2.2.9Replaceʺsampleequipmentʺwithʺsamplingequipmentʺ[Concur]Suggestedchangeapplied.33Page2‐9,Section2.2.10ReplaceʺwouldbeprovidedfortheBuildingʺwithʺwouldbeprovidedforBuildingʺThecomplexisconsistentlycalledtheBuilding3019Complex.34Page3‐1,Section3.1,LastParagraphIsthewordʺcementitiousʺnecessaryTheword“cementitious”isdeemednecessary,asitclarifiesanimportantdifferencebetweenthewasteproductsgeneratedbytheAnnexprocess(saltmonolith)versustheTWPCprocess(cementitiousgroutmonolith)35Page3‐5,Section3.4.1,LastParagraphVOGisnotdefined[Concur]Acronymadded.36Page3‐5,Section3.4.2,FirstParagraphThevalueʺ0.0000000324ʺ,isthisadecimalorarealpercent?ThevaluewascalculatedfromdatapresentedinTable5.14(pages5‐33through5‐37)oftheAnnualSiteEnvironmentalReportfortheOakRidgeReservation,DOE/ORO‐2261,September2008.ThevalueshowninthedraftEAisapercentage.37Page3‐5,Section3.4.2,SecondParagraphReplaceʺconfinementsystemsʺwithʺconfinementsystemʺ[Concur]Suggestedchangeapplied.38Page3‐8,Section3.4.3Replaceʺoffsiteʺwithʺoff‐siteʺ[Concur]Changeappliedglobally39Page3‐21,Section3.11.1ReplaceʺshortleafandloblollypineʺwithʺShortleafandLoblollyPineʺShortleafandloblollypinesaretypesofpinetreesanddonotrequirecapitalization.Suggestedchangeisnotapplied.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐10of18No.SectionCommentResponse40Page3‐21,Section3.11.1AddacommaafterʺVRMClassIVʺ[Concur]Suggestedchangeapplied.41Page3‐22,Section3.11.3ReplaceʺAfterconstructionofthefacilitiesiscomplete,constructionmaterialsandequipmentwouldberemoved,constructiondebriswouldberemoved,andconstructionlaydownareaswouldbegradedandseeded.ʺWithʺAfterconstructionofthefacilities,constructionmaterials,equipment,andconstructiondebriswouldberemoved,andconstructionlaydownareaswouldbegradedandseeded.[Concur]Suggestedchangeapplied.JohnWojtowicz,TennesseeDepartmentofEnvironmentandConservation,DOEOversightDivision,OakRidge,TennesseeNo.SectionCommentResponse42Pageii,TableofContents3.12.3ProposedActionAlternative;Listedaspg.3‐24,shouldbepg3‐23[Concur]Correctionapplied.43Page1‐1,Introduction,Paragraph1,Line3TheAtomicEnergyActof1954shouldbeplacedinSection7.0References[Concur]Referenceadded44Page1‐2,Paragraph2,Line6EMisnotinthelistofacronyms[Concur]EMaddedtoacronyms45Page1‐2,Paragraph2,Lines10‐12.ʺManagementofU‐233StoredatBuilding3019,ORNL,PreliminaryReporttoCongressʺdatedFeb08,2006,toThehonorablePeteV.Domenici,etal)(DOE2007)isnotincludedinSection7ReferencessectionThisinformationcamefromDOE/EA‐1574,citedasDOE2007.46Page1‐2,Paragraph3,Line6DOE1994isnotinSection7.0References[Concur]ReferenceaddedDOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐11of18No.SectionCommentResponse47Page1‐2,Paragraph4,Line2ʺassociatedwithU‐233ProjectʺshouldreadʺassociatedwiththeU‐233Projectʺ[Concur]Correctionapplied.48Page1‐2,LastParagraph,Lines9and12:DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.49Page1‐3,Paragraph1,Line4:ʺDOE/EA‐1488andDOE/EA‐1574giveadditionalinformation...ʺ,usingDOE2004,andDOE2007bherewouldmakeiteasierforthereadertofindwhatreferencesaremeant[Concur]Referencecalloutsadded.50Page1‐6,SecondBullet,Line3.DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.51Page1‐7,Paragraph1,Line4.DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.52Page1‐7,Paragraph3,Chapter1,Line1ʺIntroduction,PurposeandNeedforAction,andScopeʺshouldbemoreappropriatelytitledʺIntroductionandPurposeandNeedasStatedintheTableofContents[Concur]Correctionapplied.53Page1‐7,Paragraph4,Chapter2,Line1ʺTheProposedActionandAlternativesʺshouldbemoreappropriatelytitledʺProposedActionandAlternativesʺasstatedintheTableofContents[Concur]Correctionapplied.54Page1‐7,Paragraph5,Chapter3,Line1ʺAffectedEnvironmentandEnvironmentalConsequencesʺshouldmoreappropriatelybetitledʺAffectedEnvironmentandEnvironmentalImpactsʺasstatedintheTableofContents[Concur]Correctionapplied.55Page1‐7,AppendixA,Line1TheAcronymSHPOshouldbedefinedhere[Concur]Acronymadded.56Page2‐1,Paragraph1,Line1DOE/EA‐1574shouldbecitedhereasDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐12of18No.SectionCommentResponse57Page2‐1,Paragraph1,Lines10&11DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.58Page2‐1,Paragraph2,Lines1‐3ʺOnFebruary17,2006,DOEinformedCongressofitsintenttosafelyprocessandstabilizetheU‐233inventorystoredinBuilding3019A.ʺThisshouldprobablyappearinSection7.0ReferencesDOE2007citationadded.59Table2.2‐1EvaluationColumn.Forthesakeofclarity,theDocumentslistedhereshouldbecitedappropriately.DOE/OR/01‐2407&D1asDOE2009aDOE/EA‐1651asCurrentDocumentDOE/EA‐1393asDOE2002aDOE/EA‐1574asDOE2007b[Concur]Correctionsapplied.60Page2‐4,Paragraph1,Line4.DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.61Page2‐4,Paragraph2,Line4DOE/EA‐1393shouldbecitedasDOE2002a[Concur]Correctionapplied.62Page2‐4,Paragraph5,Lines1‐4Thefirsttwosentencesofthisparagraphshouldberewritten(perhapscombined)toeliminateredundancyandflowmoreclearlyNochangemade.63Page2‐7,Paragraph2,Line12ʺcontacthandledʺhereshouldbeʺcontact‐handledʺtomakeitconsistentwiththeusageinthelineabove[Concur]Correctionapplied.64Page2‐7,Paragraph2,Line14DOE2007shouldbeDOE2007bCitationisremoved.65Page2‐8,Paragraph1,Line2ShouldDOT‐NRC(bothacronymsappearintheacronymlist)beclarifiedhereasDepartmentofTransportation–NuclearRegulatoryCommission(DOT‐NRC)?[Concur]Correctionapplied.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐13of18No.SectionCommentResponse66Page2‐8,Paragraph3,LastLineDOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.67Page2‐9,Paragraph2,LastLineʺinSection2.3ofDOE/EA‐1574ʺshouldbecitedasDOE2007bforclarityCitationDOE2007added.68Page3‐1,Paragraph1,Line3DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.69Page3‐2,LastParagraph1,Line10DOE/EA‐1574shouldbeDOE2007bCitationDOE2007added.70Page3‐5,Paragraph1,Line1DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.71Page3‐5,thirdbulletline1VOGisnotinthelistofacronyms[Concur]VOGaddedtoacronymslist.72Page3‐5,Paragraph3,Line3DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.73Page3‐5,Paragraph4,Line1DOE/EA‐1574shouldbecitedasDOE2007btofacilitatelocationintheReferencessectionCitationDOE2007added.74Page3‐6,Paragraph1,Line2DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.75Page3‐6,LastParagraph1,Line6DOE/EA‐1574shouldbeDOE2007bCitationDOE2007added.76Page3‐7,LastParagraph,Line1.ShouldAERMODbeincludedintheAcronymsasAmericanMeteorologicalSociety/EnvironmentalProtectionAgencyRegulatoryModel?[Concur]AERMODisaddedtoacronymslist.77Page3‐7,LastParagraph1,Line1ShouldCAP88beincludedintheAcronymsasClearAirActAssessmentPackage1988[Concur]CAP88isaddedtoacronymslist.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐14of18No.SectionCommentResponse78Page3‐10,Paragraph4,Line3DOE‐STD‐1021‐93isnamedinthetextofthedocumentandthereaderisreferredtoDOE2002b;however,theReferenceforDOE2002bdoesnotspecificallymentionthatitisDOE‐STD‐1021‐93Referencecalloutmodifiedasappropriate.79Page3‐12,Paragraph1,Line3DOE/EA‐1574shouldbeDOE2007bCitationDOE2007added.80Page3‐13,Paragraph2,Line7DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.81Page3‐13,Paragraph3,Lines1&8DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.82Page3‐14,Paragraph4,Line4DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.83Page3‐14,LastParagraph,Lines10&11CERCLATCRAMemorandumshouldbecitedasDOE2009a[Concur]Correctionapplied.84Page3‐15,Paragraph1WhyistheSHPOlettercitedinthereferences,buttheDOEletterinthefirstlinenot?[Concur]LetteraddedtothereferencesandcitationaddedtotheparagraphasDOE2008c85Page3‐15,Paragraph2,Line1.IsthisthesameplanasORNL2005intheReferences?Ifso,shoulditnotbecitedassuch?Otherwise,shouldtherebeanadditionalreference?[Concur]ORNL2005citationadded.86Page3‐16,LastParagraph,Line7USCBisnotintheAcronymslist.[Concur]USCBaddedtoacronyms.87Page3‐17,LastParagraph,Line2ʺTable4.10.2‐2ʺshouldbeʺTable3.10‐2ʺ[Concur]Correctionapplied.88Page3‐17,LastParagraph,Line7.USCB2000isnotfoundintheSection7.0References[Concur]ReferencecalloutcorrectedtoUSCB2001DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐15of18No.SectionCommentResponse89Page3‐19,Paragraph1,Line4.IESisnotfoundinthelistofacronyms[Concur]Acronymadded.90Page3‐19,Paragraph2,Line2FBIisnotinthelistofacronyms[Concur]Acronymadded.91Page3‐19,Paragraph2,Line2USFAisnotinthelistofacronyms[Concur]Acronymadded.92Page3‐21,LastParagraph,Line1DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.93Page3‐22,Paragraph2,Line4CERCLATCRAMemorandumshouldbecitedasDOE2009a[Concur]Citationadded.94Page3‐22,Paragraph3,Line4.DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.95Page3‐22,Paragraph4,Line6.DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.96Page3‐22,Paragraph5,Line1DOE/EIS‐0305‐FshouldbecitedasDOE2000[Concur]Citationadded.97Page3‐23,Paragraph2,Line5DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.98Page3‐23,Paragraph3Line3DOE/EIS‐0305‐FshouldbecitedasDOE2000[Concur]Citationadded.99Page3‐23,Paragraph1,Line4PPEisnotinthelistofacronyms[Concur]Acronymadded.100Page3‐25,Paragraph4,Line4DOEOrder5400.5doesnotappearintheSection7.0References[Concur]Citationadded.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐16of18No.SectionCommentResponse101Page3‐25,LastParagraph,LastLineDOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.102Page3‐26,Paragraph1,Line4ʺAgingstructuresandcomponentsincreasestheriskofafailureʺshouldreadʺAgingstructuresandcomponentsincreasetheriskofafailureʺ[Concur]Correctionapplied.103Page3‐26,Paragraph4,Line2DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.104Page3‐26,Paragraph4,Line8DOE2007shouldbeDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.105Page3‐26,Paragraph5,Lines2&3Wouldthestatementʺlocated3.1mileseastofX3039and2.6mileseastnortheastofX‐7911ʺbemoreclearlystatedasʺlocated3.1mileseastofthe3039stackand2.6mileseastnortheastofthe7911Stack?[Concur]Correctionapplied.106Page3‐27,Paragraph2,Line2DOE/EA‐1574shouldbecitedhereasDOE2007bCitationDOE2007added.107Page3‐27,Paragraph2ShouldUraniumandPlutoniumbeincludedinthisdiscussionfortheirchemicaltoxicity?Inthecontextofthisproject,theradiologicalaspectsofexposureareconsideredtogovernfortheseelements.108Page3‐27,Paragraph2,Line910CFR851isnotincludedintheSection7.0References.[Concur]CitationaddedtoSection7.0references109Page3‐27,Paragraph3,Line2DOE/EA‐1574shouldbecitedhereasDOE2007bCitationDOE2007added.110Page3‐27,Paragraph3,Line6DOE2007shouldbecitedhereasDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.111Page3‐27,Paragraph4,Line6DOE2007shouldbecitedhereasDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐17of18No.SectionCommentResponse112Page3‐27,Paragraph5,Line2I/I(10‐5)shouldprobablybeincludedinthelistofAcronyms[Concur]Acronymadded.113Page3‐27,Paragraph5,Line8DOE2007shouldbecitedhereasDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.114Page3‐28,Paragraph2,Line2DOE/EA‐1574shouldbecitedasDOE2007bCitationDOE2007added.115Page3‐28,Paragraph4,Line1DOE/EA‐1574shouldbecitedasDOE2007bCitationDOE2007added.116Page3‐29,Paragraph1,Line8ShouldRADTRANandTRAGISbeaddedtothelistofacronyms?[Concur]Acronymsadded.117Page3‐29,Paragraph2,Line8RADTRANisaSandiaNationalLabproduct,butisnʹtTRAGISanORNLproduct?[Concur]Correctionapplied.118Page3‐29,Paragraph3,Line8DOE2007shouldbecitedasDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.119Page3‐29,Paragraph4,Line8.DOE2007shouldbecitedasDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.120Page3‐30,Paragraph1,Line5DOE2007shouldbecitedasDOE2007bThisinformationcamefromDOE/EA‐1574,citedasDOE2007.121Page3‐30,Paragraph4,Line1DOE/EA‐1574shouldbecitedasDOE2007bCitationDOE2007added.122Page3‐31,Paragraph4,Line4DOE/EA‐1393shouldbecitedasDOE2002a[Concur]Correctionapplied.123Page3‐33,Paragraph2,Line6DOE/EA‐1574shouldbecitedasDOE2007bCitationDOE2007added.DOE/EA‐1651–AppendixC:PublicCommentResponseTableC‐18of18No.SectionCommentResponse124Page3‐33,Paragraph3,Lines2,5,6,&9DOE/EA‐1574shouldbecitedasDOE2007bCitationDOE2007added.125Page4‐1,Paragraph1,Line10CEQ1997isnotcitedin7.0ReferencesCitationaddedtoSection7.0references.126Page5‐1,Paragraph2,Lines3&4ThestatementʺPursuanttotheTDECregulationsin1200‐3‐9‐01ʺmightbebetterstatedasʺPursuanttotheRulesoftheTDECBureauofEnvironment,DivisionofAirPollutionControlinChapter1200‐03‐09‐01ʺThisreferenceshouldalsobeplacedin7.0References[Concur]Correctionapplied.127Page6‐1,Paragraph1,Lines6&7DOE/EA‐1488andDOE/EA‐1574shouldbecitedasDOE2004andDOE2007b,respectively.[Concur]Correctionapplied.128Page7‐2DOE2008a.MoreinformationshouldbeprovidedthanʺEAD2008‐0004ʺ.[Concur]ThefollowingtitleisaddedtoDOE2008reference:“EnvironmentalAssessmentDeterminationforProposedUranium‐233ProjectOperationalChangesandFacilityModificationsatORNL”.