## DOE/E A -1607



# FINAL ENVIRONMENTAL ASSESSMENT

DISPOSITION OF DOE EXCESS DEPLETED URANIUM, NATURAL URANIUM,
AND LOW-ENRICHED URANIUM

June 2009

U.S. Department of Energy

Office of Nuclear EnergyFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### TABLE OF CONTENTS

1.0 PURPOSE AND NEED FO R AGENCY ACTION ........................................................... 1
1.1 Background............................................................................................................. 1 1.2 Purpose and Need ................................................................................................... 2 1.3 The National Environmental Policy Act and Related Procedures.......................... 2 1.4 Relationship to Other National Envi ronmental Policy Act Documents ................. 3

2.0 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES ..................... 5

2.1 Enrichment Alternative........................................................................................... 5 2.1.1 Uranium Shipments and Involved Facilities............................................... 5 2.1.2 Maximum Annual Amount and Program Duration .................................. 11 2.1.3 Regulations Governing Material Shipments: United States ..................... 12 2.1.4 Regulations Governing Materi al Shipments: Overseas ............................ 12

2.2 Direct Sale Alternative.......................................................................................... 13

2.3 No Action Alternative........................................................................................... 13 2.4 Enrichment Options Considered but Not Analyzed in Detail............................... 14

2.4.1 Other Enrichment Facilities ...................................................................... 14 2.4.2 Other LEU Product Storage Sites ............................................................. 15 2.4.3 Other French Ports of Exit and Entry ....................................................... 15 2.4.4 Other Modes of Transport: Air Transport................................................. 15

2.4.5 Use of Great Lakes Ports .......................................................................... 15

3.0 AFFECTED ENVIRONMENTS...................................................................................... 17

3.1 Affected Facilities................................................................................................. 17 3.1.1 United States Department of En ergy and United States Enrichment Corporation, Paducah Gaseous Diffu sion Plant, Paducah, Kentucky ...... 18 3.1.2 United States Department of En ergy and United States Enrichment Corporation, Portsmouth American Centrifuge Plant, Portsmouth,

Ohio........................................................................................................... 21 3.1.3 Louisiana Energy Services National Enrichment Facility, Eunice, New

Mexico ...................................................................................................... 25 3.1.4 AREVA NC, Richland, Washington ........................................................ 27 3.1.5 Global Nuclear Fuel-Americas, Wilmington, North Carolina.................. 30 3.1.6 Westinghouse Electric Corporation CFFF, Columbia, South Carolina.... 33

3.2 Uranium Market.................................................................................................... 36

4.0 ENVIRONMENTAL IMPACTS...................................................................................... 41
4.1 Existing Analyses and Scope of Impact Assessment............................................ 41

4.2 Enrichment Alternative......................................................................................... 57 4.2.1 Transportation Impacts under the Enrichment Alternative....................... 57 4.2.2 Low-Enriched Uranium Storag e Impacts under the Enrichment

Alternative................................................................................................. 81 4.2.3 Impacts on the Uranium Market Under the Enrichment Alternative........ 85

4.3 Direct Sale Alternative.......................................................................................... 85Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### 4.3.1 Transportation, Enrichment, and Storage Impacts under the Direct Sale

Alternative................................................................................................. 85 4.3.2 Impacts on the Uranium Market under the Direct Sale Alternative ......... 86

4.4 No Action Alternative........................................................................................... 88 4.4.1 Environmental Impacts under the No Action Alternative ........................ 88 4.4.2 Impacts on the Uranium Market under the No Action Alternative .......... 88 4.5 Cumulative Impacts .............................................................................................. 88

4.5.1 Enrichment Alternative............................................................................. 89

4.5.2 Direct Sale Alternative.............................................................................. 94

4.5.3 No Action Alternative............................................................................... 94

5.0 IRREVERSIBLE AND I RRETRIEVABLE COMMITM ENT OF RESOURCES

AND SHORT-TERM USES OF THE ENVIRONMENT VS. LONG-TERM

PRODUCTIVITY............................................................................................................. 97

5.1 Irreversible and Irretrievable Commitment of Resources..................................... 97 5.2 The Relationship between Local Short- Term Uses of the Human Environment

and the Maintenance and Enhancem ent of Long-Term Productivity ................... 97

6.0 REFERENCES ................................................................................................................. 99

APPENDIX A: SECRETARY OF ENERGY’S MARCH 2008 POLICY STATEMENT ... A-1

APPENDIX B: TRANSMITTAL LETTER S AND DISTRIBUTI ON LISTS...................... B-1

APPENDIX C: OTHER NEPA DOCUMENTS CONSIDERED.......................................... C-1

APPENDIX D: RESPONSES TO COMMENTS ON THE DRAFT EA .............................. D-1

LIST OF TABLES

Table 2-1. Excess Inventory, LEU Produc t, and DU Tails Characteristics ........................... 10 Table 4-1. Summary of Impacts from Na tional Enrichment Facility Construction, Operation, and Decommissioning......................................................................... 44 Table 4-2. Summary of Impacts from Am erican Centrifuge Plant Construction, Operation, and Decommissioning......................................................................... 47 Table 4-3. Summary of Expected Impacts from Operation of the Paducah and the

Portsmouth Conversion Facilities......................................................................... 52 Table 4-4. Transportation Distan ces and Population Densities ............................................. 59

Table 4-5. Characteristics of Selected Uranium Cylinders .................................................... 62 Table 4-6. Number of Cylinders and Tr uck, Rail, and Barge Shipments under the Proposed Action.................................................................................................... 62

Table 4-7. Radionuclide Invent ory of Uranium Cylinders..................................................... 63 Table 4-8a. Total Transportation Impacts from Truck Shipments of Uranium Hexafluoride under the Proposed Action.................................................................................... 65 Table 4-8b. Transportation Impacts from Truck Shipments of 2,000 MTU of Uranium

Hexafluoride in a Given Year under the Proposed Action ................................... 66 Table 4-8c. Transportation Impacts from Truck Shipments of 4,000 MTU of Uranium

Hexafluoride in a Given Year under the Proposed Action ................................... 67Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Table 4-9. Maximum Individual Impacts from Truck Shipments a 

### ........................................ 68 Table 4-10a. Total Transportation Impacts from Rail Shipments of Uranium Hexafluoride under the Proposed Action.................................................................................... 70 Table 4-10b. Transportation Impacts from Rail Shipments of 2,000 MTU of Uranium

Hexafluoride in a Given Year under the Proposed Action ................................... 71 Table 4-10c. Transportation Impacts from Rail Shipments of 4,000 MTU of Uranium

Hexafluoride in a Given Year under the Proposed Action ................................... 72 Table 4-11. Maximum Individual Impacts from Rail Shipments a 

### ........................................... 73 Table 4-12. Assumed Exposed Populati ons along Barge and Truck Routes ........................... 74 Table 4-13. Radiological Consequences for th e Population from Severe Transportation Accidents Involving Deplet ed Uranium Hexafluoride a 

### ........................................ 77 Table 4-14. Radiological Consequences fo r the Maximally Exposed Individual from Severe Transportation Accidents Involv ing Depleted Uranium Hexafluoride..... 77 Table 4-15. Chemical Consequences for th e Population from Severe Transportation Accidents Involving Deplet ed Uranium Hexafluoride a 

### ....................................... 80 Table 4-16. Chemical Consequences for the Maximally Exposed Individual from Severe Transportation Accidents Involving De pleted Uranium Hexafluoride................. 80 Table 4-17. Occupational Radiat ion Doses at FFFs in 2006.................................................... 85

Table C-1. Other NEPA Do cuments Considered.................................................................. C-1

LIST OF FIGURES

Figure 2-1. Domestic Facility Locations ................................................................................... 7 Figure 2-2. Excess Inventory Shipments to Domestic Enrichment Facilities ........................... 7 Figure 2-3. NU Product Shipments ........................................................................................... 8 Figure 2-4. LEU Product Shipments to Five Optional Storage Locations ................................ 8 Figure 2-5. Excess Inventory Shipments to, and NU Product and/or LEU Product Shipments from, France.......................................................................................... 9 Figure 2-6. DU Tails Shipments for Storage at Paducah or Portsmouth................................... 9 Figure 3-1. Paducah, Kentucky, Locator Map......................................................................... 18 Figure 3-2. Piketon, Ohio, Locator Map.................................................................................. 22 Figure 3-3. Eunice, New Mexico, Locator Map...................................................................... 26 Figure 3-4. Richland, Washington, Locator Map.................................................................... 28 Figure 3-5. Wilmington, Nort h Carolina, Locator Map .......................................................... 30 Figure 3-6. Columbia, South Carolina, Locator Map.............................................................. 34 Figure 3-7 Uranium Fuel Cycle.............................................................................................. 37 Figure 4-1. Rail and Truck Routes .......................................................................................... 60Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### LIST OF ACRONYMS AND ABBREVIATIONS

ACP American Centrifuge Plant ALARA as low as reasonably achievable

ANSI American National Standards Institute

CaF 2 

### calcium fluoride CEQ Council on Environmental Quality CFFF Columbia Fuel Fabrication Facility CFR U.S. Code of Federal Regulations D&D decontamination and decommissioning dB[A] A-weighted decibel DCP dry conversion process DOE U.S. Department of Energy DOT U.S. Department of Transportation DU depleted uranium

DUF 6 

### depleted uranium hexafluoride

EA environmental assessment EIS environmental impact statement EPA U.S. Environmental Protection Agency ERI Energy Resources International, Inc. ETTP East Tennessee Technology Park FONSI Finding of No Significant Impact FFF fuel fabrication facility g acceleration due to Earth’s gravity GDP gaseous diffusion plant

GNF-A Global Nuclear Fuel–Americas HEU highly enriched uranium HF hydrogen fluoride IAEA International Atomic Energy Agency ISO International Organi zation for Standardization LCF latent cancer fatality LES Louisiana Energy Services

LEU low-enriched uranium

LEUF 6 

### low-enriched uranium hexafluoride

LLMW low-level mixed waste

LLW low-level waste

μ Ci/cc microcuries per cubic centimeter MAP mitigation action plan MEI maximally exposed individual mg/kg milligrams per kilogram

mrem millirem

mSv millisievert

MT metric ton

MTCA Model Toxics Control Act

MTU metric tons of uranium N/A not applicableFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### NAAQS National Ambient Air Quality Standards NEF National Enrichment Facility NEPA National Environmental Policy Act

NRC U.S. Nuclear Regulatory Commission

NU natural uranium

NUF 6 

### natural uranium hexafluoride pCi/g picocuries per gram PEIS programmatic envir onmental impact statement

PM 2.5 

### particulate matter with a di ameter of 2.5 microns or less

PM 10 

### particulate matter with a di ameter of 10 microns or less PSF Physical Sciences Facility RAI request for additional information

ROD Record of Decision SAR safety analysis report SNM special nuclear material SWU separative work unit

Tc technetium TCE trichloroethylene

U 3 

### O 8 

### triuranium octoxide UDS Uranium Disposition Services, LLC

UF 6 

### uranium hexafluoride

UO 2 

### uranium dioxide

UO 2 

### F 2 

### uranyl fluoride USEC United States Enrichment Corporation VOC volatile organic compound WEC Westinghouse Electric CorporationFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### SUMMARY

The U.S. Department of Energy (DOE) owns a nd manages an inventory of depleted uranium (DU), natural uranium (NU), and low-enriched uran ium (LEU) that is currently stored in large cylinders as depleted uranium hexafluoride (DUF 6 

### ), natural uranium hexafluoride (NUF 6 

### ), and low-enriched uranium hexafluoride (LEUF 6 

### ) at the DOE Paducah site in western Kentucky (DOE Paducah) and the DOE Portsmouth site n ear Piketon in south-central Ohio (DOE Portsmouth) 1 

### . This inventory exceeds DOE’s current a nd projected energy and defense program

needs.

On March 11, 2008, the Secretary of Energy issued a policy stat ement (the Secretarial Policy Statement) on the management of DOE’s exces s uranium inventory (Appendix A). The policy statement commits DOE to manage all of its exce ss uranium inventories in a manner that (1) is consistent with all applicable legal requirements; (2) maintains sufficient uranium inventories at all times to meet the current and reasonably foreseeable needs of Departmental missions; (3) undertakes transactions i nvolving non-U.S. Government en tities in a tr ansparent and competitive manner, unless the Secretary of Energy determines in writing that overriding Departmental mission needs dictate otherwise; a nd (4) is consistent with and supportive of the maintenance of a strong do mestic nuclear industry.

In accordance with this policy, DOE proposes to di sposition part of its excess uranium inventory using one or a combination of two methods: (1) enrichment to either NU or LEU product, and subsequent storage or sale of the resultant NU or LEU product (the Enrichment Alternative), and (2) direct sale 2 

### to appropriately licensed entities (the Direct Sale Alternative). Under the Enrichment Alternative, DOE could enrich DU to the 235 

### U content of NU (i.e., 0.711 percent

235 

### U), and DOE could enrich DU, NU, and/or LEU (with a current 235 

### U content of less than 4.95 percent) up to 4.95 percent 235 

### U content. This environmental assessment (EA) assumes that the Proposed Action would result in the annual enrichment and/or sale of amounts of the excess inventory that, combined with other DOE sales or transfers to the mark et, generally would not exceed 10 percent of the total annual fuel requirements of all licensed U.S. nuclear power plants—that is, approximately 2,000 metric tons of uranium (MTU). In some years, the annual amount enriched and/or sold could be greater than 2,000 MTU (for example, due to startup of new reactors, which requires approximately two times the amount of natural uranium needed for subsequent routine re-loads).

As mentioned previously, the ex cess inventory that DOE currently proposes to disposition is

stored as UF 6 

### at the DOE Portsmouth site in Ohio a nd the DOE Paducah site in Kentucky. DOE also anticipates the potential identification of additional amounts of LEU with a 235 

### U content of less than 4.95 percent. Under the Enrichment Alternative, the uranium could be transported by

1 DOE also has additional uranium of varying levels of enrichment that, in the future, may be added to the excess DU, NU, and LEU inventory (e.g., uranium that coul d be recovered during facility decontamination and decommissioning [D&D]). In addition, the DOE uranium i nventory includes quantities of highly enriched uranium (HEU), which is being dispositioned through an ongoing National Nuclear Security Administration (NNSA) program and is not addressed in this EA.

2 In this EA, the term “sale” includes direct sales, transfers, or other transactions the Department may undertake to disposition its excess uranium inventory.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### truck or rail to one or more of three enrichment facilities in th e United States or to a foreign enrichment facility. A facility in France is identif ied as a representative foreign facility for the purposes of assessing pote ntial impacts. Shipments to France could be via any of several eastcoast or gulf-coast U.S. ports; however, this EA assumes, for purposes of analysis, that the uranium would be transported by barge to New Orl eans, Louisiana, then by ship to France. The LEU product could be stored at up to three U.S. commercial nuclea r fuel fabrication facilities (FFFs) in North Carolina, South Carolina, and Wa shington State, and/or at DOE’s Portsmouth or Paducah sites. When DU is enriched to NU, it would be stored at enri chment facilities in Kentucky, New Mexico, and/or Oh io, and/or at DOE’s Portsmout h or Paducah sites. The DU that would result from the enrichment process, called “DU tails”, would be stored and managed at the enrichment facility or be transported to and stored and managed at DOE’s Portsmouth or

Paducah sites.

In this EA, DOE assesses the potential environm ental impacts associated with this Proposed Action and a No Action Alternative. The potenti al impacts of all aspects of enrichment operations and the conversion of DU tails, per se , have been previously addressed in existing National Environmental Policy Act (NEPA) doc uments. This EA focuses on previously unanalyzed impacts: (1) health and safety impact s from transportation of the excess inventory, LEU product, NU, and DU tails; (2) impacts as sociated with accidents and intentional destructive acts (terrorism, sabotage); and (3 ) economic impacts of th e Proposed Action on the domestic uranium industry.

In general, the impacts identified for the Enrichment and Direct Sale Alternatives are similar if not identical. The potential impacts are summarized as follows:

• For all truck, rail, and barge transport opti ons, for all domestic and foreign enrichment facility locations, and for all storage options, transportation of the en tire inventory of DU, NU, and LEU subject to this EA is estimated to result in up to 3 transportation-related

fatalities 3 

### over approximately 25 years 4 

### . For overseas transpor tation, this includes impacts from sea transit, U.S. port ope rations, and overland transport. These transportation impacts incl ude the radiological and nonr adiological impacts from incident-free transportation and transportation accidents. The range in impacts presented in this EA is primarily due to differences in the amounts of mate rials that would be shipped for each case analyzed and differences in the distances over which the materials would be shipped.

• For enrichment at the National Enrichment Facility (NEF) near Eunice, New Mexico, the truck or rail transportation im pacts would be higher than for enrichment at Paducah, Kentucky, or Portsmouth, Ohio, because the NU, LEU, or DU feed would be shipped

3 For perspective, over the period 2002 to 2006, about 43,000 people were killed each year in motor vehicle accidents and about 900 people were killed each year in railroad accidents and incidents in the United States (DOT 2007).

4 Because the actual annual amounts of excess inventory enriched would likely be less than the maximum annual amount, and because it would probably change from year to year, DOE is not limiting the Proposed Action to a particular number of years. However, for purposes of modeling the impacts of processing the entire inventory, 25 years is used.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### greater distances; the DU tails and NU product, could be stored/dispositioned by NEF, or could be shipped back to Paducah or Portsmouth.

• The probability of a latent cancer fatality (LCF) for the maximally exposed individual (MEI) along the truck transportation routes was estimated to range from 8.3 × 10 -8 

### to
5.3 × 10 -7 

### over 25 years. For the analysis, the MEI was located 30 meters from the highway and was exposed to all truck shipment s. The shipments are assumed to travel at a speed of 24 kilometers (15 miles) per hour, which is representative of speeds in urban

areas.

• The probability of an LCF for the MEI along th e rail transportation routes was almost identical to truck transp ort, ranging from 8.2 × 10 -8 

### to 5.2 × 10 -7 

### over 25 years. For the analysis, the MEI was located 30 meters from the railroad and was exposed to all rail shipments. The shipments are assumed to travel at a speed of 24 kilometers (15 miles) per hour, which is representative of speeds in urban areas.

• The transportation-related impacts of transp orting the uranium to New Orleans by barge would be less than the impacts of transporti ng the uranium there by truck or rail due to the fewer number of required shipments and the fact that the e xposed population would be smaller for barge transport.

• Severe rail accidents would have higher cons equences than truck accidents because each railcar would carry four cylinders of DU, NU , or LEU (feed), compared with only one for each truck. For LEU product, each railcar would carry 12 cylinders, compared with 3 to 5

for each truck.

• DOE estimated that the radiological risks of transportation accident s for truck shipments (probability of occurrence × consequen ce summed over a complete spectrum of accidents, including the severe accidents di scussed below) ranged from 0.042 to 0.96 LCFs over 25 years.

• DOE also estimated the consequences of se vere truck accidents. For a severe truck accident involving one cylinder of depleted uranium hexafluoride (DUF 6 

### ), the population radiation dose could be as high as 32,000 person-rem in an urban area if stable atmospheric conditions existed at the time of the accident. Based on this population radiation dose, it was estimated that there could be 20 LCFs in the assumed exposed population of about 3 million people. The radiation dose for the MEI was estimated to be as high as 0.91 rem and the probability of an LCF for this individual was estimated to be 0.0005. The probability of this accident ranged from 8.1 × 10 -4 

### to 0.016 over 25 years.

If the severe transportati on accident involved NU feed or product, the radiological consequences would be higher—about 28 LCFs in the assumed exposed population. For the MEI, the probability of an LCF would be 8 × 10 -4 

### . The probability of this accident ranged from 1.5 × 10 -4 

### to 0.0055 over 25 years for those cases where NU is shipped. However, for several cases, NU would not be shipped and the probability of this accident

would be zero.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### If the severe transportation accident involved LEU product, the radiological consequences would range from about 75 to 125 LCFs in the assumed exposed population, assuming that all three or five 30B cylinders, respectively, in a truck shipment were breached during the severe a ccident. For the MEI, th e probability of an

LCF would be 0.002 or 0.0036 if three or five 30 B cylinders, respectivel y, were breached during the severe accident. If three 30B cy linders were involved in the accident, the probability of the accident would range from 2.2 × 10 -4 

### to 9 × 10 -4 

### over 25 years for those cases where LEU is shipped. If five 30B cyli nders were involved in the accident, the probability would range from 1.3 × 10 -4 

### to 5.4 × 10 -4 

### over 25 years for those cases were LEU is shipped. However, for several cas es, LEU would not be shipped and the probability of this accident would be zero. In addition, the probability associated with this accident does not incorporate the effects of the protective overpack surrounding the 30B cylinders, which would reduce the probability of the accident to a range of 4.4 × 10 -5 

### to
1.8 × 10 -4 

### over 25 years if three 30B cylinders we re involved or a range of 2.7 × 10 -5 

### to
1.1 × 10 -4 

### over 25 years if five 30B cylinders were involved

• DOE estimated that the radiological risks of transportation accide nts for rail shipments (probability of occurrence × consequenc e summed over a complete spectrum of accidents, including the severe accidents di scussed below) ranged from 0.051 to 0.97 LCFs over 25 years. The radiological risks fo r rail and truck transportation accidents are similar because the total number of cylinde rs shipped by rail and truck is the same.

• DOE also estimated the consequences of severe rail accidents. For a severe rail accident involving four cy linders of DUF 6 

### , the population radiation do se could be as high as 130,000 person-rem in an urban area if stable atmospheric conditions existed at the time of the accident. Based on this population radiation dose, it was estimated that there could be 80 LCFs in the assumed exposed population of about 3 million people. Under this scenario, the radiation dose for the MEI was es timated to be as high as 3.7 rem, and the probability of an LCF for th is individual was estimated to be 0.002. The probability of this accident ranged from 2.4 × 10 -4 

### to 0.003 over 25 years.

If the severe transportati on accident involved NU feed or product, the radiological consequences would be higher—about 110 LC Fs in the assumed exposed population and the probability of an LCF for the MEI woul d be 0.003. The probability of this accident ranged from 4.4 × 10 -5 

### to 0.0011 over 25 years for those cases where NU is shipped. However, for several cases, NU would not be shipped and the probability of this accident

would be zero.

If the severe transportation accident involved LEU product, the radiological consequences would be about 310 LCFs in the assumed exposed populations, assuming that all twelve 30B cylinders in a rail shipment were breach ed during the severe accident. For the MEI, the probability of an LCF w ould be 0.009. The probability of this accident ranged from 4.3 × 10 -5 

### to 2.6 × 10 -4 

### over 25 years for those cases where LEU is shipped. However, for several cases, LEU would not be shipped a nd the probability of this accident would be zero. In addition, the probabi lity associated with this accident does not incorporate the effects of the protective overpack surrounding the 30B cylinders, whichFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### would reduce the probabili ty of the accident to a range of 4.3 × 10 -6 

### to 2.6 × 10 -5 

### over 25

years.

• For both the truck and rail severe transporta tion accidents, the accidents were assumed to take place in an urban area with a popul ation density of 1,600 people per square kilometer. Potential consequences were es timated for the population within a 50-mile (80-kilometer) radius, assuming that this population density extended out to 50 miles (80 kilometers). It is important to note th at according to the 2000 census, the average population density within 50 miles of the cen ter of the 20 highes t population urbanized

areas in the United States is about 380 people per square kilo meter, so the consequences would likely be lower if a severe truck or ra il accident took place in an urban area. In addition, the severe accidents were assumed to take place during stable atmospheric conditions. As illustrated in Table 4-13, if the accidents took place during neutral atmospheric conditions, the cons equences would be substantially lower. For example, if the severe truck accident involving LEU pr oduct occurred during neutral atmospheric conditions, the consequences would range from 3 to 5 LCFs, substantially lower than 75

to 125 LCFs. If the severe rail accident involving LEU product occurred during neutral atmospheric conditions, the consequences woul d be about 12 LCFs, substantially lower

than 310 LCFs.

• Three individuals could suffer irreversible he alth effects from severe truck accidents and

four individuals could suffer irreversible health effects from severe rail accidents due to the chemical toxicity associated with UF 6 

### , hydrogen fluoride (HF), and uranyl fluoride (UO 2 

### F 2 

### ). No fatalities are estimated to result from chemical exposure. 5



### • Although it is not possible to predict the proba bility of an inten tional destructive act, implementation of elements identified in the Department of Transportation-required security plan (personnel security, unauthorized access, and en route security) are judged to make these occurrences very unlikely. The consequences of such acts would be similar to the consequences discussed above fo r severe truck and rail accidents involving DU, NU, and LEU.

• If a severe accident involving stored LEU product were to occur, the accident would result in an estimated population dose. For example, at Global Nuclear Fuel–Americas (GNF-A), a severe accident was estimat ed to result in a population dose of 29,000 person-rem. In the assumed exposed population around the GNF-A facility, this

radiation dose is estimated to result in 17 LCFs. The radiation dose for an individual located 2 kilometers from the facility was es timated to be 5 rem. The probability of an LCF for this person is estimated to be 0.003. If this accident occurred at other sites, the results would vary depending on the amount of material involved in the accident; the

5 The toxic effects, or chemical impacts, can be categorized as adverse health effects or irreversible adverse health

effects. An adverse health effect in cludes respiratory irritation or skin rash associated with lower chemical concentrations. An irreversible adverse health effect ge nerally occurs at higher chemical concentrations and is permanent in nature. Irreversible adverse health effects include death, impaired organ function (such as central nervous system or lung damage), and other effects that ma y impair daily functions. Of t hose individuals receiving an irreversible adverse health effect, approxim ately 1 percent or less would die from it.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

xii 

### enrichment of the UF 6 

### ; the release fractions, aerosoliz ed fractions, and respirable fractions; release assumptions such as whether the release was elevated or from ground level; the number of people exposed; atmo spheric conditions; and radiation dosimetry assumptions.

• The potential market impacts (including socioeconomic impacts) on the domestic uranium mining, conversion, and enrichment indu stries (i.e., domestic uranium industry)

from direct sales or transf ers of uranium under the Proposed Action are expected to be small. In any event, DOE has prepared a mitigation action plan (MAP) to mitigate any potentially significant impacts on the domestic uranium industry from DOE decisions to disposition the excess NU, DU, and LEU inve ntory at DOE’s Paducah and Portsmouth sites as analyzed in this EA.

• Cumulative impacts under the Enrichment Altern ative would essentially be the same as those previously evaluated for the sites involved because DOE’s uranium inventory

would not increase the sites’ enrichment capacity or throughp ut. Under the Direct Sale Alternative, DOE assumes that actions by the pu rchasers would be esse ntially the same as

DOE under the Enrichment Alternative. For that reason, DOE finds that the cumulative transportation, enrichment, and storage impacts of the Direct Sale Alternative would be essentially identical to those of the Enrichme nt Alternative. The cumulative impacts that

would occur under the No Action Alternative a ssessed in this EA are the same as the cumulative impacts identified for the two ne w conversion facilities at Paducah and

Portsmouth.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

1 Uranium Hexafluoride (UF 6 )
Uranium hexafluoride (UF 6 ) is the chemical form of uranium that is used during the uranium enrichment process. Within a reasonable range of temperature and pressure, it can be a solid, liquid, or gas. Solid UF 6 is a white, dense, crystalline

material that resembles rock salt. UF 6 does not react with oxygen, nitrogen, carbon dioxide, or dry air, but it does react with water or water vapor (including humidity in the air). When UF 6 comes into contact with water, such as water vapor in the air, the UF 6 and water react, forming corrosive hydrogen fluoride (HF) and a uranium-fluoride compound called uranyl fluoride (UO 2 F 2 ). For this reason, UF 6 is always handled in leak-tight containers and processing equipment. 

### 1.0 PURPOSE AND NEED FOR AGENCY ACTION

1.1 Background

The U.S. Department of Energy (DOE) owns and manages an inventory of depleted uranium (DU), natural uranium (NU), and low-enriched uranium (LEU). This inventory is currently stored in large cylinders as depleted uranium hexafluoride (DUF 6 

### ), natural uranium hexafluoride (NUF 6 

### ), and low-enriched uranium hexafluoride (LEUF 6 

### ) at the DOE Paducah

site in western Kent ucky (DOE Paducah)

and the DOE Portsmouth site near Piketon in south-central Ohio (DOE Portsmouth) 6



### . This inventory exceeds DOE’s current and projected energy and defense program

needs.

On March 11, 2008, the Secretary of Energy issued a policy stat ement (the Secretarial Policy Statement) on the management of DOE’s exces s uranium inventory (Appendix A). The policy statement commits DOE to managing all of its excess uran ium inventories in a manner that (1) is consistent with all applicable legal requirements; (2) maintains sufficient uranium inventories at all times to meet the current and reasonably foreseeable needs of Departmental missions; (3) undertakes transactions i nvolving non-U.S. Government en tities in a tr ansparent and competitive manner, unless the Secretary of Energy determines in writing that overriding Departmental mission needs dictate otherwise; a nd (4) is consistent with and supportive of the maintenance of a strong do mestic nuclear industry.

In accordance with the principles set forth in the Secretarial Po licy Statement, DOE is proposing to disposition excess NU, DU and LEU inventory by enriching it, a nd then storing or selling the resultant product, and/or selling excess NU, DU and LEU inventory, to appropriately licensed

entities. Hereafter in this environmental assessm ent (EA), “excess inventory” means that part of DOE’s excess NU, DU, and LEU inventory that would be dispositioned under DOE’s Proposed Action. The characteristics and quantities of th e excess inventory are discussed further in Section 2.0, Description of the Pr oposed Action and Alternatives.

6 DOE also has additional uranium of varying levels of enrichment that, in the future, may be added to the excess DU, NU, and LEU inventory (e.g., uranium that coul d be recovered during facility decontamination and decommissioning [D&D]). In addition, the DOE uranium i nventory includes quantities of highly enriched uranium (HEU), which is being dispositioned through an ongoing National Nuclear Security Administration (NNSA) program and is not addressed in this EA.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### 1.2 Purpose and Need

The purpose of the Proposed Action is to dispos ition DOE’s excess inventories of NU, DU, and LEU to reduce expenses associated with stor ing, managing, and securing DOE’s excess uranium inventory. Changes in the relativ e market prices for DU, NU, LEU , and enrichment services may affect the economic advantages to the enrichme nt of NU, DU, and LEU. Implementation of the Proposed Action also could enhance DOE’s ability to support a healthy domestic nuclear infrastructure. The Secretarial Policy Statem ent provides the framework within which DOE would make decisions concerning future disposition of the excess inventory.

1.3 The National Environmental Poli cy Act and Related Procedures

Before deciding whether to implement the Proposed Action, DOE must comply with the National Environmental Policy Ac t (NEPA), 42 U.S. C. §§ 4321 et seq . Consequently, DOE is preparing this EA to determine if the Proposed Ac tion would result in significant impacts to the human environment. Based on the findings of this EA, DOE will either prepare an environmental impact statement (EIS) or issue a Finding of No Significant Impact (FONSI). A FONSI would identify commitments to mitigation, if any, that are essential to rende r the impacts of the Proposed Action not significant. This EA ha s been prepared in accordance with NEPA regulations issued by the Council on Envir onmental Quality (CEQ) (40 CFR Parts 1500–1508) and DOE (10 CFR Part 1021), as well as guid ance by both agencies. The draft EA was distributed to the host/affected states, the U. S. Nuclear Regulatory Commission (NRC), uranium producers and enrichers, fuel fabr icators, and other interested parties. Appendix B contains a copy of the transmittal letters and distribution list. Uranium-235: DU, LEU, and HEU Uranium exists as three naturally occurring isotopes: uranium-238 ( 238 U), uranium-235 ( 235 U), and uranium-234 ( 234 U). The 235 U isotope can fission, or split, into lighter fragments when bombarded with neutrons. This process can release energy either in a controlled manner in a nuclear reactor or an uncontrolled manner in a nuclear weapon explosi on. Of the three naturally occurring uranium isotopes, only 235 U can sustain an energy-releasing chain reaction.

Natural uranium (NU) refers to refined uranium ore with the same isotopic ratio found in nature; it contains approximately 0.711 percent 235 U. Through gaseous diffusion or centrifugation enrichment processes, the concentration of 235 U can be increased (enriched), and the resultant uranium is called either low-enriched uranium (LEU) or highly enric hed uranium (HEU). LEU has a concentration of

235 U less than 20 percent. HEU has a concentration of 235 U of 20 percent or greater. For use in commercial light water reactors, the most prevalent power reactors in the world, uranium is enriched to LEU having 3 to 5 percent 235 U.

After increasing the concentration of 235 U in a portion of the uranium mixture during the enrichment process, the remaining uranium mixture has a reduced concentration of 235 U. This is called depleted uranium (DU) or sometimes DU tails. The U.S. Nuclear Regulatory Commissi on (NRC) definition of DU is uranium in which the percentage fraction by weight of 235 U is less than 0.711 percent, although enrichment normally results in DU having much lower levels of 235 U.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### 1.4 Relationship to Other National Environmental Policy Act Documents

Since 1993, DOE and the NRC have proposed and, in some instances, implemented agency actions related in greater or lesser degrees to the Proposed Action asse ssed in this EA. The impacts of these actions have been assessed in a series of EISs and EAs. Those NEPA documents were reviewed, used as existing s ources of information, and, when appropriate, incorporated by reference into this EA. Appendix C lists those NEPA documents, summarizes their content, and indicates how they were used in the preparation of this EA.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### 2.0 DESCRIPTION OF THE PROPOS ED ACTION AND ALTERNATIVES

DOE proposes to disposition its excess uranium inventory using one or a combination of two methods: (1) enrichment to either NU or LEU pr oduct and subsequent storage or sale of the resultant NU or LEU product (the Enrich ment Alternative), and (2) direct sale 7 

### to appropriately licensed entities (the Direct Sa le Alternative). Under the Enri chment Alternative, DOE could

enrich DU to the 235 

### U content of NU (i.e., 0.711 percent 235 

### U), and DOE could enrich DU, NU, and/or LEU (with a current 235 

### U content of less than 4.95 pe rcent) up to 4.95 percent 235 

### U content. A target enrichment level for LEU of 4.95 percent 235 

### U content was selected for analysis in this EA because it is near the upper end of the range of enrichment (3 to 5 percent 235 

### U ) used in fuel for most commercial light-water power re actors. In practice, DOE might choose to enrich to lower-percentage 235 

### U content. This chapter describes th ese two action alternatives, including options within them, and the No Action Alte rnative (i.e., continuing the status quo).

2.1 Enrichment Alternative

2.1.1 Uranium Shipments and Involved Facilities

Under the Enrichment Alternative, DOE would contract to ship and enrich excess NU, DU (having an assay equal to or greater than 0.35 percent 235 

### U 8 

### ), and LEU (having an assay greater than 0.711 percent 235 

### U but less than 4.95 percent 235 

### U) as UF 6



### .

DOE would contract with appropria te commercial carriers (truck, rail, barge, and/or ship) to transport the excess inventory to one or more of four enrichment facilities (three domestic and one foreign). The U.S. enrichment facilities are (1) the currently operating United States Enrichment Corporation (USEC) gaseous diffusi on plant (GDP) in Paducah, Kentucky; (2) the USEC American Centrifuge Pl ant (ACP) near Piketon, Ohio, which is scheduled to begin enrichment operations in late 2009 or 2010; an d (3) the Louisiana Energy Services (LES) National Enrichment Facility (N EF) near Eunice, New Mexico, which is scheduled to begin enrichment operations in late 2009. The foreign enrichment facility is operated by AREVA and is located at the Tricastin nuclear complex in south-central France on a diversion canal of the Rhone River, approximately 130 kilometers (80 mile s) north of the port of Marseilles. This EA presents impacts associated with transportation to and from Fran ce as representative of potential impacts associated with enrichment at any fore ign facility. Potential impacts would vary in proportion to the distance traveled if a facility in another country was us ed. In addition to the French facility in Tricastin, other foreign enrichme nt facilities are operati ng in various European countries, as well as Russia and Japan. At th is time, the United States has 123 Agreements (Section 123 of the Atomic Energy Act of 1954) for Peaceful Nuclear Cooperation with multiple countries such as Japan, and with countries that are part of the European Atomic Energy Community (Euratom), including France (DOE 2008a). Other foreign enrichment facilities could be considered in the future if the necessary agreements were implemented.

7 In this EA, the term “sale” includes direct sales, transfers, or other transactions the Department may undertake to disposition its excess uranium inventory.

8 It should be noted that in implem enting the Proposed Action evaluated in the EA, DOE may occasionally select cylinders with slightly less than 0.35 percent 235 U (e.g., a cylinder with 0.345 to 0.349 percent 235 U) for sale or enrichment in order to avoid extra handling of cylinders (and the risks associated with such handling).Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### U.S. facility enrichment operations (including enrichment technologies; feed material, end product, and waste product handling; logistics; and facility manage ment) have been described in detail in applicable DOE and NRC NEPA documen ts. Those documents describe the enrichment operations, the enrichment facilities, the wast e management activities, and the environmental impacts that would be applicable to the en richment activities that would occur under the Proposed Action. Those descriptions are summarized and incorporated into this EA by reference (NRC 2005 [LES NEF]; NRC 2006 [USEC ACP]; DOE 1982 [Paducah GDP]). The French enrichment plant uses a gas diffusion process to enrich uranium into reactor-grade LEU for some

100 nuclear reactors in Fran ce and throughout the world.

If DOE contracts for the enrichment of DU to NU, DOE would contract for the storage of the resultant NU at the enrichment facility performing the enrichment operations, or for the transport

of the NU to DOE Paducah and/or DOE Portsmout h. If DOE contracts for the enrichment of DU, NU, or LEU to obtain LEU with up to 4.95 percent 235 

### U content, DOE would contract to transport the LEU product to, and st ore it at, one or more of five domestic sites. Three of these

sites are commercial nuclear fu el fabrication facilities (FFFs ) operated by AREVA NC in Richland, Washington; by Westinghouse Electric Corporation (WEC) at its Columbia Fuel Fabrication Facility (CFFF) near Columbia , South Carolina; and by Global Nuclear Fuel– Americas (GNF-A) near Wilmington, North Carolin a. DOE considers on-site storage at these FFFs to be desirable because they require LEU as process feedstock and already store quantities of LEU on-site. In total, up to 670 metric tons of uranium (MTU) could be stored at the FFFs. DOE also could contract to ship the LEU pr oduct to DOE Paducah and/or DOE Portsmouth and store or sell it. Both DOE sites have the required infrastructure and security, as well as extensive experience in the safe management, storage, and l ogistics of uranium cylinde rs. If other sites are proposed in the future for storage, additional NEPA analysis would be prepared, as appropriate.

Figure 2-1 shows the locations of the six poten tially affected domestic sites; Figures 2-2 through 2-6 illustrate the domestic and intern ational uranium transportation options.

Enriching the excess inventory to either NU or LEU product would result in the production of “DU tails”. In this EA, it is assumed th at the DU tails would have a 0.20 percent 235 

### U content. The DU tails are an end product that results from uranium enrichment; they have a lower 235 

### U

content than the DU that would serve as feed fo r enrichment operations. As part of the Proposed Action, DOE would contract with the enrichment f acility to store and/or dispose of the DU tails or, in the case of domestic enrichment facil ities, to ship the DU tails from the domestic

enrichment facilities to DOE Paducah and/ or DOE Portsmouth for storage, pending final disposition consistent with the DOE decisions announced in the Record of Decision for Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Paducah, KY, Site (69 FR 44654); and Record of Decision for Construction and Operation of a Depleted Uranium Hexafluoride Conversi on Facility at the Portsmouth, OH, Site (69 FR 44649).

DOE assumes DU tails from enrichment in France w ould not be returned to the United States but would be disposed of in France in accordance with French policies a nd regulations. DOE may contract with the enricher to store, convert, and dispose of the tails.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Figure 2-1. Domestic Facility Locations

Figure 2-2. Excess Inventory Shipments to Domestic Enrichment FacilitiesFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Figure 2-3. NU Product Shipments

Figure 2-4. LEU Product Shipments to Five Optional Storage LocationsFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Figure 2-5. Excess Inventory Shipmen ts to, and NU Product and/or LEU Product Shipments from, France

Figure 2-6. DU Tails Shipments for Storage at Paducah or Portsmouth (AREVA NC)Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Table 2-1 summarizes the weight and number of cylinders of excess NU, DU, and LEU inventory that would be enriched and/or sold and the number of cylinders of NU product, LEU product and DU tails that would result.

Table 2-1. Excess Inventory, LEU Product, and DU Tails Characteristics

Material Type MTU Number of Cylinders

Excess Inventory

- NU feed 17,595 2,270

- DU feed 75,296 10,776 a

- LEU feed 2,000 b 296
Alternative potential products, and DU tails that would result from the pro duction of that product
- LEU product 4,919 3,195

- DU tails 89,972 c 10,931
- NU product 22,213 3,445

- DU tails 53,083 d 6,450
a. This EA uses 10,776 DU cylinders fo r its estimate of im pacts. In Appendix D, comment #4 from USEC noted that the actual DU cylinder count would be less, la ter determined to be 8, 871 for DU feed. This correc tion would normally provide the basis for a recalculation of estimated impacts, and, in this case, would lower the estimate of impacts. In light of the already low estimates of potential impacts, this recalculation was not performed. b. DOE currently has identified approximate ly 1,110 MTU of LEU feed. The analysis in this EA uses a larger quantity because DOE anticipates that additional LEU may be identified as excess inventory. c. DU tails from enriching NU feed, DU feed, and LEU feed to LEU product. d. DU tails from enriching DU feed to NU product.



### The excess inventory would be shipped fr om DOE Paducah or DOE Portsmouth to U.S. enrichment facilities by either truck or rail. The NU and LEU product and DU tails would also be shipped to storage sites by either truck or rail. This EA analyzes the possibility of rail shipments, assuming that potentially affected s ites have serviceable rail sidings and transfer

terminals within a reasonable distance. DOE has not identified any need for major new rail infrastructure as part of the Proposed Action. Mi nor upgrades to existing sidings or rail terminals could be implemented, if necessary, to accommod ate or allow for rail shipments. The decision whether to undertake any rail upgrades would be DOE’s responsib ility only at DOE Paducah or DOE Portsmouth, and DOE would evaluate the n eed for related NEPA analysis if such a proposal were under consideration.

The excess inventory to be shi pped from DOE Paducah or DOE Portsmouth to France could be transported to New Orleans, Louisiana, by barge, rail, and/or truck, a nd then transported to Marseilles by ship. LEU or NU product imported from France could be first returned to DOE Portsmouth or DOE Paducah via New Orleans, and then shipped to one or more of the three FFFs by truck or rail. This two-step shipment scenario for importing LEU product from France would provide conservative impact estimates (tha t is, larger estimated impacts than if the LEU product were shipped directly from France to an FFF). Uranium coul d be exported to and imported from France via U.S. marine terminal po rts other than the port of New Orleans. Other options include the ports of Providence, Rhode Island; New York, Ne w York; Elizabeth, New Jersey; Philadelphia, Pennsylvania; Baltimore, Maryland; Hampton Roads, Virginia; MoreheadFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### City, North Carolina; Charleston, South Carolina; Savannah, Geor gia; Jacksonville, Florida; Fernandina, Florida; and Houston, Texas. However, of these and other optional marine terminal ports, only New Orleans can be re ached directly or nearly dire ctly by barge from DOE Paducah

and DOE Portsmouth. Commer cial carriers would decide which ports to use. Impacts would be generally similar at any port capable of handli ng the materials because the operations would be the same or similar. In a 1994 EA, DOE f ound no significant difference in comparative transportation-related risks among 13 optional por ts of entry for importing LEU into the United States (DOE 1994). Based on the availability of direct barg e access and the previously determined comparability of transportation-related risk to optional ports, DOE has determined that analyzing only New Orleans as a marine term inal port is sufficient for the purposes of this EA. If other marine terminal ports were propos ed, DOE would evaluate the need for additional NEPA analysis.

DOE’s estimates of the number of requisite shipments of excess inventory, NU product, LEU product, and DU tails that would occur using th e various transportation options are shown in Section 4.2.1 (Transportation Impacts under the Enrichment Alternative).

2.1.2 Maximum Annual Amount and Program Duration

Under the Enrichment Alternative, enrichment of excess inventory would be managed consistent with applicable law

and in a manner tailored to avoid or mitigate impacts to the domestic uranium industry. In accordance with the Secretarial Policy Statement, to the extent practicable, the Department will manage

its uranium inventories in a manner that is consistent with and supportive of the mainte nance of a strong dome stic nuclear industry. Consistent with this principle, the Department believes that, as a general matter, the introduction

into the domestic market of uranium from Departmental inve ntories in amounts that do not exceed 10 percent of the total annual fuel require ments of all licensed nuclear power plants—that is, approximately 2,000 MT NU equivalent based on current requirements—should not have an adverse material impact on the market or uranium industry. The De partment anticipates, however, that in any given year, it may introduce in to the domestic market less than that amount, or, for certain special purposes (suc h as the provision of initial core loads for new reactors), more

than that amount. These annual amounts would in clude uranium introduced into the domestic uranium market from all Departmental invent ories, including LEU ge nerated via the downblending of highly enriched uranium (HEU ) in the ongoing National Nuclear Security Administration (NNSA) HEU dis position program (61 FR 40619).

The specific annual amounts would be determ ined on an ongoing basis; the amounts would depend upon market analyses for pa rticular sales. Because precise annual enrichment or sale quantities would be uncertain and would change from year to year, for purposes of assessing environmental impacts in this EA, DOE assumes that the Proposed Action could result in the

annual enrichment and/or sale of excess inve ntory sufficient to introduce into the domestic Section 3112(d) of the 1996 USEC Privatization Act requires the Secretary of Energy to determine
that the sale or transfer of NU or LEU will not have an adverse material impact on the domestic uranium mining, conversion, or enrichment industry; DOE also must receive a price that is at least equal to the fair market value of the material.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### market in a given year up to approximately 2,000 MT NU equivalent. This EA also analyzes the impacts of introducing approximately 4,000 MT NU equivalent in the event the Department determines, in any given year, that circumstances warrant the introduction of the greater amount into the market. Such circumstances might arise, for example, as new reactors are scheduled to begin operating, thereby increasing the short-term demand for uranium. This increase in demand would arise because loading the core of a new reactor requires approximately three times as

much LEU fuel as would be re quired later during re-loading. For the purposes of this EA, DOE has conservatively assumed that such events co uld lead to a doubling of the amount of uranium introduced into the market in a given year (i.e., 4,000 MT NU, rather than 2,000 MT NU).

Because these annual amounts could also includ e, for example, LEU entering the domestic market via the NNSA HEU disposition program, it is likely that the amount of excess inventory

enriched and/or sold under th e Proposed Action would be so mewhat less than the amount sufficient to introduce approximately 2,000 MT NU equivalent or 4,000 MT NU equivalent, respectively, into the domestic market.

Further, this EA assumes that for any given year, the enrichment of either the 2,000 MT NU equivalent or a doubling of that amount could occur at any of the four optional enrichment facilities. However, DOE believes this to be unlikely and believes that enrichment would probably occur at some combination of the four facilities.

Similarly, DOE believes it unlikely that the total amount of NU or LEU product would be stored at only one of the optional storage facilities.

Because the actual annual amounts of excess invent ory enriched would likely be less than the maximum annual amount, and because it would probably change from year to year, DOE is not limiting the Proposed Action to a particular number of years. However, for purposes of modeling the impacts of processing the enti re inventory, 25 years is used.

2.1.3 Regulations Governing Material Shipments: United States

Within the United States, uranium would be sh ipped in accordance with U.S. Department of Transportation (DOT) and NRC regulations governi ng the transport of radi oactive materials—in particular, 49 CFR Part 173, subpart I, “Class 7 (Radioactive) Materials.” Among other things, 49 CFR 173.420 requires that each UF 6 

### cylinder be designed, fabri cated, inspected, tested, and

marked in accordance with the version of Am erican National Standards Institute (ANSI) N14.1, Uranium Hexafluoride - Packaging for Transport that was in effect at the time the cylinder was manufactured. Cylinders not meeting these re quirements are referred to as “nonconforming” because they are overfilled, over-pressuri zed, or structurally substandard. Any UF 6 

### currently stored in a nonconforming cylinde r would not be transported wit hout prior preparation, such as obtaining a DOT exemption, placing the nonconforming cylinder in an over-pack, or transferring the material to a conforming cylinder.

2.1.4 Regulations Governing Material Shipments: Overseas

Uranium would be shipped to and from France in accordance with applicable DOT regulations, applicable French regulations, Intern ational Atomic Energy Agency (IAEA) Safety StandardsFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Regulations for the Safe Trans port of Radioactive Material (IAEA 2005), IAEA Interim Guidance on the Safe Transport of Uranium Hexafluoride (IAEA 1991), and the pertinent provisions of the Intern ational Organization for Standardizat ion. As with domestic shipments, any UF 6 

### currently stored in a cylinder that did not conform to all applicab le regulations would not be transported without prio r preparation sufficient to make the cylinder conform to all applicable regulatory requirements. Th is would include transferring the UF 6 

### to a conforming cylinder. 9 

### With regard to international shipments, it is noteworthy that in 2004, the NRC issued a final rule, effective October 2004, that amended its regulations on packaging and transporting

radioactive material. This rule made NRC regulations compatible with the latest version of the IAEA standards and codified other applicable requirements. 10



### 2.2 Direct Sale Alternative

Under the Direct Sale Alternative, sales of ex cess inventory would be managed consistent with applicable law and in a manner tailored to avoid or mitigate certain impacts to the domestic uranium industry. The annual amounts discussed in Section 2.1.2 would also apply to the amount of excess inventory DOE would introduce into th e market annually through any combination of

enrichment and sales.

DOE assumes that licensed purchasers would ta ke delivery, transport and enrich the excess inventory, and transport and stor e the NU or LEU product in esse ntially the same manner and using essentially the same facilities as woul d DOE under the Enrichment Alternative. DU tails resulting from the ultimate enrichment of DOE’s so ld excess inventory would be disposed of in a manner consistent with existing practices at the enrichment facilities, and DU tail (waste) disposal practices are analyzed in existing enri chment facility and DU tails conversion facility

NEPA documents and NRC licenses. For that reason, DOE assumes that the transportation, enrichment, and storage activities (and impacts) of the Direct Sale Alternative would be similar to the potential impacts of the Enrichment Alte rnative. Consequently, w ith the exception of the economics analysis in Section 4.3.2, Direct Sale Alterna tive activities and imp acts are not further described or analyzed. The potential impacts of the Enrichment Alternative are similar to the impacts of a combination alternative; conseque ntly, combination alternative impacts are not analyzed.

2.3 No Action Alternative

In 1999, DOE prepared and issued a programmatic environmental impact statement (PEIS) that assessed the potential impact s of alternative DOE management strategies for DUF 6 

### stored at three DOE sites: Paducah, Portsmouth, and the Ea st Tennessee Technology Park (ETTP) at Oak Ridge, Tennessee (DOE 1999b). The PEIS considered the environmental impact s, benefits, costs, and institutional and programmatic needs asso ciated with the management and use of approximately 700,000 MT tons of DUF 6 

### . The alternatives analyzed in the PEIS included no action, long-term storage as UF 6 

### , long-term storage as uranium oxide, use as uranium oxide, use

9 For example, international shipment of 48G cylinders is not currently allowed, and, in th e absence of an appropriate waiver, the UF 6 contained in these cylinders would have to be transferred to conforming cylinders.

10 Available online at http://www.epa.gov/EPA-IMPACT/ 2004/January/Day-26/i35.htm

.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### as uranium metal, and disposal. In its Record of Decision (ROD) (64 FR 43358), DOE stated the following:

“DOE has decided to promp tly convert the depleted UF 6 

### inventory to depleted uranium oxide, depleted uranium metal, or a combination of both. The depleted uranium oxide will be used as much as possible and the remaining depleted uranium oxide will be stored for potential fu ture uses or disposal, as necessary.”

In 2003, DOE amended the ROD (68 FR 53603), stating the following:

“The DOE has now decided to transfer up to 1,700 of the approximately 4,700 cylinders containing DUF 6 

### from the East Tennessee Technology Park (ETTP) in Oak Ridge, Tennessee, to its storage facili ties at DOE’s enrichment facility at Portsmouth, Ohio...”

Subsequently, in 2004 DOE issued two site-spe cific EISs (DOE 2004a, 2004b) and associated RODs (69 FR 44654; 69 FR 44649) for c onstruction and operation of two DUF 6 

### conversion facilities, one at the DOE Paducah site (DOE 2004a) and one at the DOE Portsmouth site (DOE 2004b). These two new facilities ar e nearing completion, and operations are projected to begin in

2010.

Prior to the Secretarial Policy St atement, DOE planned to convert all excess DU inventory stored

at Portsmouth and Paducah to a more stable chemi cal form suitable for use or disposal consistent with the two RODs cited above. However, in acco rdance with the Secretarial Policy Statement and other considerations, DOE is now proposing to enrich or sell part of the excess DU inventory

as described above in the Enrichment and Direct Sale Alternatives.

The No Action Alternative for this EA is defined as continuation of the status quo; that is, DOE would continue with existing plans to convert all DU to a more stable chemical form at the two

new conversion facilities consiste nt with the two RODs cited above and would not enrich or sell any of its excess DU inventory as proposed in th is EA. Under the No Action Alternative, DOE

would also continue to store excess NU and LEU in their curren t configurations at Portsmouth and Paducah. The two DU conversion facility EI Ss (DOE 2004a and 2004b) evaluated continued storage of NU and LEU cylinders as part of thei r no action alternatives. This storage option is comparable to the No Action Alternative in this EA and is also comparable to the storage of NU and LEU cylinders after enrichment at Portsmout h and Paducah in the Proposed Action of this

EA.

2.4 Enrichment Options Considered but Not Analyzed in Detail

2.4.1 Other Enrichment Facilities

DOE considered enriching the excess inventory at other U.S. and foreign facilities. However, the three U.S. facilities proposed for enrichment are the only U.S. facilities th at are expected to be operating in 2009 and 2010, although other new facili ties have been announced or are planned

for the future. Such facilities could be consider ed if they became available. There are two new U.S. facilities that are in the licensing stage: GE Hitachi’s Global Laser Enrichment FacilityFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### (Wilmington, North Carolina, on the same gr ounds as GNF-A) and AREVA’s Eagle Rock Enrichment Facility (Idaho Falls, Idaho).

This EA presents impacts associat ed with transportation to and fr om France as representative of potential impacts associated with enrichment at any foreign f acility. Potential impacts would vary in proportion to the distance traveled if a fa cility in another country was used. In addition to the French facility in Tricastin, other foreign enrichment facilities are operating in various European countries, as well as Russia and Japa n. At this time, the United States has 123 Agreements (Section 123 of the Atomic Energy Act of 1954) for Peaceful Nuclear Cooperation with multiple countries such as Japan, and with countries that are part of the European Atomic Energy Community (Euratom), including Fran ce (DOE 2008a). Other foreign enrichment

facilities could be considered in the future if the necessary agreements were implemented.

2.4.2 Other LEU Product Storage Sites

DOE considered storing LEU product at an AR EVA nuclear facility in Lynchburg, Virginia. This site was eliminated from further analysis because this facility uses uranium feed in the form of uranium oxide, not UF 6



### .

2.4.3 Other French Ports of Exit and Entry

The port of Marseilles in France was identified as the most reasonable French port of entry due to its proximity (approximately 130 river kilometers [80 river miles]) to Tricastin. Entry via Le Havre on the English Channel in northern Fran ce, an alternate port of entry, would require approximately 800 kilometers (500 miles) of additional overland transportation in France.

2.4.4 Other Modes of Transport: Air Transport

Air transport of radioactive materi als is typically used for rapid de livery when the half-life of the

material is short or immediate use of the materi al is required. If speed of delivery is not a consideration (as is the case with this Proposed Action), large, fr equent shipments of radioactive materials by air are unwarranted.

2.4.5 Use of Great Lakes Ports

Uranium could conceivably be exported and im ported using Great Lakes ports. However, doing so would require using the Great Lakes St. La wrence Seaway System, a deep-draft waterway extending 3,700 kilometers (2,340 miles) from the Atla ntic Ocean to the head of the Great Lakes. The St. Lawrence Seaway portion of the system ex tends from Montreal to mid-Lake Erie. The St. Lawrence Seaway includes 13 Canadian and 2 U.S. locks. Because of the likely logistical and diplomatic complexities, this opt ion was not analyzed further.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### 3.0 AFFECTED ENVIRONMENTS

This chapter describes two classes of e nvironment—geographic a nd economic—that are potentially affected by DOE’s Proposed Action. Th e affected geographic environment comprises

the six sites where the excess uranium is now st ored, where enrichment could occur, and where

LEU and DU tails could be stored 11 

### . The economic environment is the existing uranium market.

A third potentially affected environment, the transportation corridors and global commons over which uranium could be transpor ted is described in Section 4. 2.1 (Transportation Impacts). For domestic shipments, uranium coul d be transported by truck and/or rail; for shipments to France, uranium would be transported by tr uck, rail, barge, and/or ship.

3.1 Affected Facilities

The six domestic facilities where the excess uranium is now stored, where enrichment could occur, and where NU, LEU, and DU tails c ould be stored (see Figure 2-1) are:

• 

### DOE Paducah/USEC Paducah GDP : current storage, proposed enrichment site, and proposed NU, LEU, and DU tails storage;

• 

### DOE Portsmouth/USEC ACP : current storage, proposed en richment site, and proposed NU, LEU, and DU tails storage;

• 

### Louisiana Energy Services (LES) National En richment Facility (NEF), Eunice, New

Mexico : proposed enrichment site, and pr oposed temporary storage for NU;

• 

### AREVA NC, Richland, Washington : proposed LEU storage;

• 

### GNF-A, Wilmington, North Carolina: proposed LEU storage; and

• 

### CFFF, Columbia, South Carolina : proposed LEU storage.

Each of these six geographic loca tions either currently hosts a DOE site or has been licensed by NRC to host an existing or under-constr uction uranium enrichment facility, DUF 6 

### conversion facility, or nuclear FFF. Therefore, each of these affected envir onments has been previously and extensively described and categorized in a DOE or NRC EA, EIS, or other agency document. These existing documents provide de tailed site maps and descriptions of the environments that would be affected by agency acti ons. Sections 3.1.1 through 3.1.6 of this EA provide site locator maps, summary site descriptions , and summaries of those aspect s of the environment that may affect, or be affected by, DOE’s Proposed Action based on the descriptions in these existing documents. More detailed descriptions of res ource areas that would not be affected by DOE’s Proposed Action (including, for example, ecologi cal resources, endangered species, wetlands, noise, construction-rela ted impacts) are also found in these existing documents.

11 The affected environment and impacts associated with uranium import and en richment operations at the Tricastin facility in France are not addressed in this document. Activities occurring within the territorial limits of France will be evaluated by French authorities in accordance w ith regulatory requirements of that country.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

18 

### 3.1.1 United States Department of Energy and United States Enrichment Corporation, Paducah Gaseous Diffusion Plant, Paducah, Kentucky

Figure 3-1 shows the location of the DOE Paduc ah site and USEC GDP in rural McCracken County in far western Kentucky. The affected envi ronment as summarized below is described in detail in the following documents, which are in corporated into this EA by reference:

• Final Environmental Impact Statement for C onstruction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky, Site (DOE 2004a).

DOE/EIS-0359. June 2004. http://web.ead.anl.gov/uranium/documents/paddeis/index.cfm

.

• Paducah Annual Site Environmental Report for Calendar Year 2005 (DOE 2007a). PRS-ENM-0002. August 2007. http://www.prs-llc.net/aser/2005.html

.

Figure 3-1. Paducah, Kentucky, Locator MapFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

19 

### • Final Environmental Impact Assessment of the Paducah Gaseous Diffusion Plant Site (DOE 1982). DOE/EA-0155. August 1982. http://www.osti.gov/bridge/produc t.biblio.jsp?osti_id=6727682

.

• Final Programmatic Environmental Impact Stat ement for Alternative Strategies for the Long-term Management and Use of Depleted Uranium Hexafluoride (DOE 1999b). DOE/EIS-0269. April 1999. http://web.ead.anl.gov/uranium/doc uments/nepacomp/peis/index.cfm

.

Site Description

The DOE Paducah site/USEC GDP is located in rural McCracken County, Kentucky, approximately 16 kilometers (10 miles) west of th e City of Paducah and 6 kilometers (3.6 miles)

south of the Ohio River. The site consists of 1,439 hectares (3,556 acres ) currently held by DOE. The site is surrounded by the 1,125-hectare (2,7 81-acre) West Kentucky Wildlife Management Area, which was conveyed by DOE to the Commonw ealth of Kentucky for wildlife conservation and for recreational purposes. The City of Paducah is the largest urban ar ea in the six counties surrounding the site. The six-county area is primarily rural, with industrial uses accounting for less than 5 percent of land use. The Paducah si te is located in an area with an established transportation network. The area is served by on e interstate highway (I-24), several U.S. and state highways, several rail lines, a ba rge terminal, and a regional airport.

The Paducah GDP occupies a 303-hectare (750-acr e) complex within the DOE Paducah site and is surrounded by a security fence. The plant, previously operated by DOE and now operated by USEC, includes about 115 buildings with a co mbined floor space of approximately 0.76 million square meters (8.2 million square feet). The Paducah GDP has operated since 1952.

In 2002, DOE awarded a contract to Uranium Dis position Services, LLC (UDS) to design, build, and operate DUF 6 

### conversion plants at the DOE Paducah and Portsmouth sites. The contract includes cylinder surveillance and maintenance, which began June 2005. The Paducah conversion plant is currently under construction; it has a projected January 2010 completion date and June 2010 start-up date. 12



### At the end of 2003, the Paducah site managed an inventory of approximately 38,000 cylinders containing approximately 454,000 MT of UF 6 

### (mostly DUF 6 

### ) stored in outdoor facilities, commonly referred to as cylinde r storage yards. Additional cy linders are added to the DOE inventory periodically as a result of formal agre ements with the USEC. The site has 13 storage yards used to store DOE-generated DUF 6 

### cylinders; an additional 4 yards are used to store USEC-generated cylinders that are now manage d by DOE. Over several years, most of the storage yards that previously had gravel bases ha ve been reconstructed wi th concrete bases to

better control water inf iltration and runoff.

12 Personal communication: telephone conversation, May 27, 2008; William Fallon, Battelle; and Barry Tilden,

UDS.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

20 

### Radiation Environment

The average annual radiation dose to people in th e United States from all sources of natural background radiation is 300 millirem (mrem) (DOE 2007b). DOE Order 5400.5 (Radiation Protection of the Public and the Environment) re quires that exposure of me mbers of the public to radiation sources as a consequen ce of all routine DOE activities shall not cause, in a year, an effective dose equivalent gr eater than 100 mrem (DOE 1990). U.S. Environmental Protection Agency (EPA) regulations estab lish additional public dose lim its for exposures to several selected sources or exposure modes: regulati ons implementing the Clean Air Act (40 CFR Part 61) establish a dose limit of 10 mrem from air borne emissions, and regulations implementing the Safe Drinking Water Act (40 CFR Part 141) establish a dose limit of 4 mrem from beta-emitting radionuclides in drinking water.

Operations at the Paducah site result in radiation exposure to on-site workers and off-site members of the public. Exposure pa thways potentially contributing to dose include ingestion of surface water, ingestion of sedime nts, ingestion of deer meat, direct radiation, and atmospheric releases. Exposures of on-site workers generally are associated with the handling of radioactive

materials used in the on-site fa cilities and with th e inhalation of radionuclides released from processes conducted on the site. Off-site members of the public are exposed to radionuclides discharged from on-site facilitie s with airborne and/or waterbor ne emissions and, in some cases, to radiation emanating from radioactive ma terials handled in th e on-site facilities.

For 2005, the highest estimated dose a maximally exposed individual (MEI) might have received from all combined DOE exposure pathways (wor st-case scenario) was 0.55 mrem. This dose is less than 1 percent of the applicable federal standard of 100 mrem per year. 13 

### The closest

location that would be accessible to the public in 2005 resulted in external radiation exposures below background. Based on results from this locati on and other data obtained from all locations, the dose to the MEI member of the public from DOE operations was zero.

In 2001, the measured external radiation doses for Paducah cylinder yard workers was 254 mrem, well below the maximum dose limit of 5,000 mrem per year set for radiation workers (10 CFR Part 835).

Seismic Environment

In late 1811 and early 1812, a se ries of earthquakes centered in the New Madrid fault zone destroyed the town of New Madr id, Missouri. These quakes are c onsidered to be the largest recorded earthquakes to have occurred in the co ntiguous United States. Ba sed on the effects of these earthquakes, it has been estimated that they would have had a magnitude of about 8.0 on

the Richter scale.

13 Regulatory dose limits are set well below levels where measurable health effects have been observed. The total radiation dose limit for individual members of the public as defined by the Code of Federal Regulations (10 CFR 20.1301) is 1 millisievert (mSv) per year (100 mrem per year), not including the dose contribution from background radiation. Limits on emissions of radionuclides (other than radon) to the air from certain DOE facilities are set such that they will not result in a dose greater than 0.1 mSv per year (10 mrem per year) to any member of the public (40 CFR 61.92).Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

21 

### The seismic hazards at the Paducah site have be en studied extensively. A 1997 safety analysis report (SAR) for this site provided comprehensive analyses and discussions of seismic hazards at the site (DOE 2004a). The analyses considered the possibility of large-magnitude earthquakes similar to the New Madrid earthquakes of 1811–1812. The analyses performed by DOE were independently reviewed by the U. S. Geological Survey. This inde pendent review indicated that the seismic sources, recurrence ra tes, maximum magnitudes, and attenuation functions used in the SAR analyses were representative of a wide range of professional opinion and were suitable for obtaining probabilistically based seismic hazard estimates. Because of the proximity of the site to the New Madrid seismic zone, special de terministic analyses were also performed to estimate the ground motions at the site in the cas e of recurrence of an earthquake of the same magnitude as the 1811–1812 New Madrid earthquakes. The results of the deterministic analyses were similar to the probabilistic seismic hazard re sults for the probabilities associated with the recurrence of the New Madrid earthquake of 1811–1812.

Groundwater

Contamination has been detected in off-s ite and on-site groundw ater. Beta activity, trichloroethylene (TCE) and technetium-99 ( 99 

### Tc) are found in the off-site and on-site contamination plumes. DOE protects members of the public from contaminated groundwater by providing landowners affected by the plume with municipal wate r. DOE is actively addressing the groundwater contamination through source re moval actions and grou ndwater pump-and-treat systems. Descriptions of the groundwater monitoring program and sampling results are contained in Chapter 9 of DOE 2007a.

Air Quality

The Paducah site is located in the Paducah-Cairo Interstate Air Quality Control Region, which covers the westernmost parts of Kentucky. McCr acken County currently is designated as being in attainment for all criteria pollutants (40 CFR 81.318).

Waste Management

The Paducah site generates wastewater, nonhazar dous waste, nonradioactive hazardous waste, low-level waste (LLW), and low-level mixed wa ste (LLMW). Wastewater is discharged through permitted outfalls; nonhazardous solid waste is disposed of at an on-site landfill; and

nonradioactive hazardous waste is stored on-s ite and sent to permitted treatment/disposal

facilities. LLMW and LLW are sent to approved treatment/disposal facilities.

3.1.2 United States Department of Energy and United States Enrichment Corporation, Portsmouth American Centrifuge Plant, Portsmouth, Ohio

Figure 3-2 shows the location of the DOE Portsm outh site and USEC ACP in rural Pike County

in south-central Ohio. The affected environment as summarized below is de scribed in detail in the following documents, which are incor porated into this EA by reference.

• Final Environmental Impact Statement for th e Proposed American Centrifuge Plant in Piketon, Ohio (NRC 2006). NUREG-1834, Vol.1. April 2006.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

22 

### • Environmental Assessment of the USEC Inc. American Centrifuge Lead Cascade Facility at Piketon, Ohio (NRC 2004). January 2004.

• Final Environmental Impact Statement for C onstruction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio, Site (DOE 2004b).

DOE/EIS-0360. June 2004. http://web.ead.anl.gov/uranium/ documents/portdeis/index.cfm

.

• Portsmouth Annual Site En vironmental Report for 2005 (DOE 2007b). August 2007. http://www.lpports.com/05%20Annual%20Environmental%20Report.htm

.



### • Final Programmatic Environmental Impact Stat ement for Alternative Strategies for the Long-term Management and Use of Depleted Uranium Hexafluoride (DOE 1999b). DOE/EIS-0269. April 1999. http://web.ead.anl.gov/uranium/doc uments/nepacomp/peis/index.cfm

.

Figure 3-2. Piketon, Ohio, Locator MapFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

23 

### Site Description

The NRC issued a construction and operating li cense to USEC for the ACP in April 2007. The license, which is valid for 30 year s, includes authorizati on to enrich uranium up to an assay level of 10 percent 235 

### U.

The DOE Portsmouth site is located in Pike County, Ohio, approximately 35 kilometers (22 miles) north of the Ohio River and 5 kilomete rs (3 miles) southeast of the town of Piketon. The two largest cities in the vicinity are Chillicot he, located 42 kilometers (26 miles) north of the site, and Portsmouth, 35 kilometers (22 mile s) south. The Portsmouth site includes the Portsmouth GDP, which was previously ope rated by DOE and later by USEC. Uranium enrichment operations were discontinued in May 2001.

The Portsmouth site occupies 1,500 hectares (3,7 14 acres) of land, with a 320-hectare (800-acre)

fenced core area that contains the former production facilities . The 1,180 hectares (2,914 acres)

outside the core area include restricted buffers , waste management areas, plant management and administrative facilities, GDP s upport facilities, and vacant land. Wayne National Forest borders the plant site on the east and southeast, and Brush Creek State Fo rest is located to the southwest, slightly more than 1.6 kilometers (1 mile) fr om the site boundaries. The Portsmouth site has direct access to major highway and rail systems, a nearby regional airport, and barge terminals on the Ohio River. Use of the Ohio River barge terminals requires transp ortation by public road

from the Portsmouth site.

The ACP is being constructed by USEC within th e confines of the Portsmouth site. It will be situated on approximately 81 hectares (200 acres) of the southwest quadrant of the controlled access area. In addition to this space, two UF 6 

### cylinder storage yards (t he existing X-745G-2 and proposed X-745H), occupying a total of 11 hectares (27 acres), will be loca ted in the northeast part of the DOE reservation just north of the Perimeter Road. The ACP will consist of refurbished existing buildings and land formerly used for the Portsmouth GDP as well as newly

constructed facilities in that same area.

In 2002, DOE awarded a contract to UDS to design, build, and operate DUF 6 

### conversion plants

at the DOE Paducah and Portsmouth sites. The contract includes cy linder surveillance and maintenance, which began June 27, 2005. Construc tion of the Portsmouth conversion plant is complete, the facility is preparing for its opera tional readiness review, an d start-up is projected

for March 2010. 14



### The Portsmouth site houses over 20,000 DUF 6 

### cylinders. The cylinders are located in two storage yards that have concrete bases. The cy linders are stacked two high. All 10- and 14-ton (9- and 13-tonne) cylinders stored in these ya rds have been or ar e being inspected and repositioned. They have been placed on new c oncrete saddles with sufficient room between cylinders and cylinder rows to permit adequate visual inspection of cylinders.

14 Personal communication: telephone conversation, May 27, 2008; William Fallon, Battelle; and Barry Tilden,

UDS.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

24 

### Radiation Environment

Past operations at the Portsmouth site resulted in radiation expos ures to on-site workers and offsite members of the public. Exposures of on-site workers generally were associated with the handling of radioactive material s used in the on-site faciliti es and with the inhalation of radionuclides released from processes conducted on th e site. Off-site members of the public were exposed to radionuclides discharged from on-site facilities with airbor ne and/or waterborne emissions and, in some cases, to radiation emana ting from radioactive materials handled in the

on-site facilities.

Environmental monitoring data collected at DOE Portsmouth are used to assess potential impacts

to human health and the environment from radionuc lides released by current and historical site operations. Radiation exposure can be caused by radionuclides released to air and/or water, or radiation emanating directly from build ings or other objects at the site.

The Portsmouth site environmental report for 2005 (DOE 2007b) reported that the maximum dose a member of the public could receive fr om radiation released by DOE Portsmouth in 2005 was 1.67 mrem, based on a maximum dose of 0.012 mrem from airborne radionuclides,

0.025 mrem from radionuclides releas ed to the Scioto River, 1.1 mrem from direct radiation from DU cylinder storage yards, and 0.53 mrem ba sed on exposure to radionuclides detected at off-site monitoring locations in 2005. This dose (1.67 mrem) was well below the 100-mrem-peryear limit set by DOE for the dose to a member of the public from radionuclides from all potential pathways. The dose to a member of th e public from airborne radionuclides released by DOE Portsmouth (0.012 mrem) was approximately 1,000 times less than the 10-mrem-per-year standard set by EPA. Operation of the Portsmouth conversion fac ility would add a very small increment to the current public dose. The MEI dose from operation of the conversion facility was

modeled to be less than 3.0 × 10 -5 

### mrem per year (DOE 2004b).

In 2001, the average dose for Portsmouth cylinde r yard workers was 64 mrem per year, well below the maximum dose limit of 5,000 mrem per year set for radiation workers (10 CFR Part 835) (DOE 2004b).

Seismic Environment

The Portsmouth site is within 96 kilometers ( 60 miles) of the Bryant Station-Hickman Creek

Fault. No correlation has been made between this fault and historical seismicity. The seismic hazards at the Portsmouth site were analyzed and documented in a March 1997 SAR (Lockheed Martin Energy Systems, Inc. 1997).

Groundwater

On-site groundwater at and around the Portsmout h site is monitored for radioactive and

nonradioactive constituents at more than 400 wells. On site, five areas of groundwater

contamination have been identified that contain contaminants. The main contaminants are volatile organic compounds (VOCs) (mostly TC E) and radionuclides (e.g., uranium, and 99 

### Tc). Data from annual groundwater monitoring (DOE 2007b) showed that no contaminants exceeded their primary drinking water standards at off-s ite locations near the Portsmouth site. TCE wasFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

25 

### detected in three on-site monitoring wells in concentrations exceeding the drinking water standard. However, TCE has not been detected in an off-site well adjacent to Portsmouth above the drinking water standard. DOE is addressing the groundwater contamina tion through a varietyof groundwater remediation and containment systems, including phytoremediation, pump-andtreat systems, and barrier walls.

Air Quality

The Portsmouth site is located in the Wilmi ngton-Chillicothe-Logan Intrastate Air Quality Control Region, which covers th e south-central part of Ohi o. Currently, Pike County is designated as being in attainment for all criteria pollutants.

Waste Management

Section 3.1.4 of the Portsmouth conversion facility EIS (DOE 2004b) describes the solid, hazardous, radioactive, and mixed (i.e., hazardous plus radioactive) wastes currently generated and managed by USEC at DOE Portsmouth and describes the existing waste management practices used by USEC at the DOE site. Most of these practices would also be used to manage wastes from the proposed ACP. USEC’s wast e management program directs the storage, treatment, and disposal of waste generated by it s operations at the DOE reservation at Piketon. The company must satisfy NRC, EPA, Ohio EPA, and Ohio Department of Health regulations as part of these activities. Waste generated by USEC at the DOE rese rvation and then transferred to DOE for storage, treatment, or disposal is subj ect to DOE Orders. Additional policies have been implemented by USEC for management of radio active, hazardous, and mixed wastes generated at the site. The USEC is currently operati ng in accordance with an NRC Certificate of Compliance issued under 10 CFR Part 76. Waste collection and segreg ation activities are completed in accordance with applicable stat e and federal rules and regulations and site procedures. Wastes are collected and packaged, wh ere feasible, at the location where the waste is generated. Wastes are also segreg ated into the various waste str eams and handled accordingly to minimize the generation of hazardous waste, LLMW, and low-level radioactive waste.

The DOE Portsmouth site generates wastewater , nonhazardous waste, nonradioactive hazardous waste, LLW, and LLMW. Wastewater is treated and discharged through permitted outfalls; nonhazardous solid waste is disposed of at an off- site landfill. Nonradioactive hazardous waste is stored on-site until treatment or disposal. So lid nonradioactive hazardous waste is sent to permitted disposal facilities, and liquid nonradio active hazardous waste streams are sent to approved treatment/disposal facilities such as th e incinerator at the ETTP. The LLW is sent to off-site treatment/disposal facilities. Some LLW has been sent to the DOE Hanford site (Washington) for disposal.

3.1.3 Louisiana Energy Services National En richment Facility, Eunice, New Mexico

Figure 3-3 shows the location of the NEF near Eunice in Lea County, New Mexico. The affected

environment as summarized below is described in detail in the following document, which is incorporated into this EA by reference:Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

26 

### • Final Environmental Impact Statement for the Proposed National Enrichment Facility in Lea County, New Mexico (NRC 2005). NUREG-1790, Vol.1.

Site Description

The NEF site covers about 220 hectares (543 acres) lo cated 8 kilometers (5 miles) east of the city of Eunice, New Mexico. Lea County currently owns the property; however, on December 8, 2004, LES began a lease for 30 years, after wh ich LES would purchase the land from Lea County. Before NEF construction began, the entire site was undeveloped w ith the exception of an underground carbon dioxide pipelin e and a gravel road. The site was previously used for cattle grazing. There is no permanent surface water on the site, and appreciable groundwater reserves are deeper than 340 meters (1,115 f eet). The nearest permanent resident is 4.3 kilometers (2.6 miles) west of the propos ed site near the junction of New Mexico Highway 234 and New Mexico Highway 18.

New Mexico Highway 234 is a two-lane highway lo cated on the southern border of the proposed NEF site. It has 3.6-meter (12-foot ) wide driving lanes, 2.4-meter (8-foot) wide shoulders, and a 61-meter (200-foot) right-of-way easement on either side. The hi ghway provides direct access to

the site. The northern side of the si te is bordered by a railroad spur.

Figure 3-3. Eunice, New Mexico, Locator MapFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

27 

### Radiation Environment

Because the site is not yet operational, there is only natural background radiation.

Seismic Environment

Earthquakes in the vicinity of the proposed NEF s ite include isolated, sma ll clusters of low- to moderate-size events (i.e., Richter magnitude ear thquakes of 3 to 5.9). A review of earthquake data collected for the site and the vicinity indi cates that most earthquakes that occurred near the proposed NEF site likely were induced by gas/oil recovery operations and were not tectonic in origin. A magnitude 5.0 earthquake occurred in the area of Eunice in 1992. This earthquake is attributed to a tectonic origin.

Air Quality

Lea County is designated as being in a ttainment for all crite ria air pollutants.

Waste Management

In Eunice and Hobbs, solid-waste-d isposal pickup is contracted to Waste Management, Inc. Pickups are offered once or twice a week. Solid wastes are disposed of in the Lea County landfill located about 8 kilometers (5 miles) east of E unice just across from the proposed NEF site. The landfill accepts all type s of residential, commercial , special wastes, and sludges.

3.1.4 AREVA NC, Richland, Washington

Figure 3-4 shows the location of AREVA NC in Richland, Washington. The affected

environment as summarized below is described in detail in the following documents, which are incorporated into this EA by reference. A new EA to support an NRC license renewal application is currently in preparation.

• Environmental Assessment for Renewal of Special Nuclear Material License SNM-1227,

Docket 70-1257 (NRC 1995). Siemens Power Corporation Richland, Washington. (June)

• Supplement to Applicant’s Environmental Report (AREVA 2006). E06-04-004. October

2006.

Site Description

AREVA NC is located at 2101 Horn Rapids Road, ju st within the northern limits of the City of Richland in Benton County, Washington. The fe nced exclusion area of approximately 20 hectares (50 acres) lies within 130 hectares (320 acres) of land owned by AREVA NC within the Horn Rapids Industrial Park. Stevens Drive, the primary route south into Richland, is approximately 1,200 meters (4,000 feet) to the east.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

28 

### Figure 3-4. Richland, Washington, Locator Map

The facility contains numerous buildings plus various outside f acilities/structures (tank farms, storage pads, etc.). The buildings and structures are confined within a secured fenced area and include the major special nuclear material (SNM)-processing produc tion facilities, a number of SNM-handling production support facilities (p roduct storage warehouses, waste treatment facilities, etc.), and a larg e number of non-SNM-handling prod uction and administrative support facilities (materials warehous es, craft shops, office buildings, etc.). There is a UF 6 

### cylinder storage facility for the receipt, handling, and storage of full, empty, and heel quantity UF 6 

### cylinders, including weighing and assaying of cylinder contents. There is also a UF 6 

### cylinder recertification facility.

There are no public facili ties (schools, hospitals, parks) in the immediate vicinity of the plant site. The nearest schools, Washington State Un iversity at Tri-Citie s and the Hanford High School, are approximately 3 kilometers (2 miles) southeast of the plan t, and the northernmost portion of Leslie Groves Park along the Columbia Ri ver is about 5 kilometers (3 miles) southeast

of the site. The West Richland Public Golf Cour se is approximately 5.6 kilometers (3.5 miles) southwest of the plant. The nearest hospital, Kadlec Hospital, is located approximately 8 kilometers (5 miles) south of the plant in Richland. There are resident ial areas near the golf course and hospital.

There are no bodies of surface water adjacent to or in the immediate vicinity of the plant. The Columbia River is located approxi mately 2.4 kilometers (1.5 miles) to the east, and the Yakima River, a tributary to the Columb ia, passes approximately 3 kilomete rs (2 miles) to the west. TheFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

29 

### Columbia River is regulated by multiple dams upstr eam of Richland. At its closest point, the site lies approximately 8 meters (25 feet) above the normal level of the Columbia. The immediate area surrounding the site is a re latively flat and essentially featureless plain. There are no significant geographic features that may impact accident analyses within 1.6 kilometers (1 mile)

of the site.

Radiation Environment

As a nuclear/chemical processing and manufacturi ng facility, the Richland plant can potentially impact the surrounding environment via plant effl uents associated with routine or abnormal conditions. For the Richland plant, these effluent s may be airborne, liquid, or solid wastes. In practice, these impacts are managed in accordance with applicable regulations, licenses, and permits via an integrated system of process and effluent controls, backed by effluent and environmental monitoring programs. These imp acts on environmental media are discussed in Sections 3.1.1 through 3.1.4 of the supplement to the applicant’s environmental report (AREVA 2006).

Seismic Environment

The DOE Hanford site, which is adjacent to ARE VA NC, has been extensively investigated for earthquake potential. The records of eastern Wa shington show infrequent, low-intensity, deep earthquakes. During the past 100 ye ars, there have been three ear thquakes of intensity large enough to cause moderate damage to structures w ithin 50 to 100 kilometers (30 to 60 miles) of the site, though no damage has been reported at AREVA NC.

Groundwater

G roundwater contamination in the shallow unconfi ned aquifer below the Richland facility is

attributed to historic 1970s-era releases from the site’s form er surface impoundment system. By the early 1980s, the impoundments were double-lined with in ter-liner leachate detection/collection capability and not implicat ed in further environm ental releases. More recently (1996-2006), the impoundment system has been removed from service under a Washington Department of Ec ology (Ecology)-regulated clea nup/closure action. Under that action, the impoundments were emptied of their inventory and physically dismantled, and soil was remediated (removed and disposed of) to uran ium, fluoride, and nitrate soil cleanup limits derived in accordance with Ecology’s Mode l Toxics Control Act (MTCA) (WAC 173-340).

With respect to uranium, the Ecology soil cleanup limit was 12.1 milligrams per kilogram (mg/kg) (parts per million), or approximately 29 picocuries per gram (pCi/g) for uranium at a

235 

### U enrichment of 3.5 percent. This limit was c onservatively calculated in accordance with Ecology criteria to be protect ive of groundwater down to the EPA drinking water limit for uranium of 30 parts per billi on (also the MTCA groundwater cleanup limit for uranium). DOE monitors groundwater immediately downgradient of AREVA NC for uranium and TCE. Based on the latest available data (2005), levels of bot h constituents in the groundwater are lower than their respective EPA drinking water limits.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

30 

### Air Quality

Benton County, and all of Washington State, is designated as being in attainment for all criteria air pollutants.

Waste Management

Gaseous, liquid, and solid wastes are produced at the site. These wastes are categorized as lowlevel radioactive, nonra dioactive, hazardous, or mixed wast es. These waste categories, their control strategies, and an estimate of release qu antities are described in Section 2.1.2 of the EA for Siemens Power Corporati on’s license renewal (NRC 1995).

3.1.5 Global Nuclear Fuel-Americas, Wilmington, North Carolina

Figure 3-5 illustrates the locati on of GNF-A near Wilmington, North Carolina. The affected

environment as summarized below is described in detail in the following documents, which are incorporated into this EA by reference:

• Environmental Assessment for the Renewal of Special Nuclear Material License SNM1097, General Electric Company, Nuclear Ener gy Production Facility, Wilmington, NC (NRC 1997). (May).

• GNF–Americas Wilmington Environmental Report Supplement (GNF-A 2007). For the period 1995-2005. March 30, 2007.

Figure 3-5. Wilmington, North Carolina, Locator MapFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Site Description

GNF-A is situated on a 673-hectar e (1,664-acre) tract of land located next to NC Highway 133 (formerly designated Highway 117) and is approxim ately 10 kilometers (6 miles) north of the City of Wilmington in New Hanover County. New Hanover County is situated in the coastal plains section of southeastern North Carolina with the Atlantic Ocean to the east, Cape Fear River to the west, and Pender Count y to the north. Due to the curv ing coastline in this area, the ocean lies approximately 16 kilometers (10 miles) east and 42 kilometers (26 miles) south of the GNF-A Wilmington site.

The surrounding terrain is typical for coastal Carolina. It has an average elevation of less than 12 meters (40 feet) above mean s ea level and is characterized by gently rolling land, with rivers and creeks and adjoining swamps and/or marshl ands. Approximately 74 hectares (182 acres) of the southwest portion of the GNF-A Wilmington property are classified as swamp forest.

The region around the site is lightly settled w ith large areas of heavily timbered tracts, occasionally penetrated by short roads. Farms, single-family dwellings, and light commercial activities are located along NC Highway 133. Castle Hayne, the nearest community, is approximately 5 kilometers (3 miles) north of GNF-A. Jacksonville, North Carolina, and Camp Lejeune (U.S. Marine Corps base) are located ap proximately 100 kilometers (60 miles) to the

northeast of GNF-A.

The major portion of the site is bordered on the east by NC Highway 133, on the southwest perimeter by the Northeast Cape Fear River; a nd on the north, and for most of the south property line, by undeveloped forestlands. Approximately 10 hectares (24 acres) are east of NC Highway 133 and contain an employee recreation area, a futu re railroad right-of-way, three potable water supply wells, and temporary truck parking. The so uth property line for approximately 900 meters (3,000 feet) is bordered by a new highway (Wilmi ngton Bypass I-140). Due to road construction and the new Bypass I-140, US Highway 117 is now designated NC Highway 133.

Radiation Environment

The gamma radiation exposure levels measured at the site boundary are at background levels. Gross alpha ambient airborne con centrations are measured routinel y at the southern fence line and are typically on the order of 4 × 10 -15 

### microcuries per cubic centimeter ( μ Ci/cc).

Direct inhalation of airborne re leases is the most likely intake pathway. The off-site population dose estimates have been calculated using EPA’s COMPLY code. An individual dose of

8.5 × 10 -4 

### mrem was calculated using the nearest populat ion center 3 kilometers (2 miles) south of the facility and 2005 air stack releas es. All releases were assumed to be 234 

### U (Class Y insoluble). When direct data were not availa ble, conservative assumptions were made. Thus, there is a high degree of confidence that dose equivalent values are not underestimated. A conservative assumption was made to apply the in dividual dose at this pop ulation center to the entire 200,000 persons (2000 census) in the su rrounding area. The estimated 0.17 person-rem for the surrounding population can be compared to the annual average 60,000 person-rem received by this population due to natural background. Theref ore, the average annual dose received by anFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

32 

### individual in the surrounding populat ion from releases at this fa cility is several orders of magnitude less than 1 mrem. There are no potential health effects which might be predicted from

such doses.

The annual natural background radia tion dose for the average indivi dual in the surrounding area is typical of that received from natural background radiation in th is location or elsewhere in the

United States. Relative to the 10 CFR 20.1301 NRC off-site indivi dual exposure limit of 100 mrem per year, the annual dose during 1995- 2005 to the nearest (pot entially most highly exposed) resident using EPA’s COMPLY code ranged from 0.03 mrem to 0.4 mrem. In 2005, the dose was 0.03 percent of the NRC limit. The dose has been decreasing over the years.

The uranium concentration and gross alpha activ ity concentration of the discharge to the Northeast Cape Fear River are determined from analysis of the samples collected at the final process basin outfalls. The final process basin outf all was sampled for gross alpha concentrations during the 1995-2005 period. The highest averag e concentration during that period was

1.23 × 10 -7 

### μ Ci/cc in 2005. Compared with the 10 CF R Part 20 Appendix B limit, the 2005 site discharge was 41 perc ent of the limit.

Seismic Environment

North Carolina lies within an intraplate region of the North American tectonic plate and has relatively low seismic activity. The Wilmington ar ea has had nine reported earthquakes since 1800. The 1884 and 1958 Wilmington area earthquakes rated 5 on the Modified Mercalli scale.

The site is located in Zone 1 of the 1973 Uniform Building Code. The code requirements

indicate that structures in Zone 1 must withstand intensities of 5 and 6 on the Modified Mercalli scale without receiving earthqua ke damage. Earthquakes produced by small faults along the Atlantic seaboard have the potenti al to cause damage, even if the faults do not reach the surface. The earthquake causing the most damage in Nort h Carolina had an epi center near Charleston, South Carolina, approximately 250 kilometers (155 miles) southwest of Wilmington. This earthquake, a 7.2 on the Richter scale, occurred in 1886 and caused chimneys and plaster to

crack.

Groundwater

GNF-A has a shallow aquifer, also called the surfici al aquifer, and a deeper aquifer known as the principal aquifer. Typically, the shallow aquifer is 1.5 to 6 meters (5 to 20 feet) below the land surface. The shallow aquifer is recharged by rainfa ll and is not used for drinking water supplies. There has been no radiological impact to the pr incipal aquifer. All m onitoring data from the principal aquifer show uranium concentrations to be less than or at the minimum detectable level. Similarly, gross alpha activ ity concentration data from three process water supply wells continue to be at natural background le vels (at or near the detection limit).

Air Quality

New Hanover County is designate d as being in attainment fo r all criteria ai r pollutants.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Waste Management

Gaseous, liquid, and solid wastes are produced at the site. These wastes are described in Sections 2.1.3, 2.1.4, 2.1.5, and 2.2 of the EA for the license renewal for GNF-A (NRC 1997).

Gaseous effluents have effluent controls and are monitore d to demonstrate compliance with regulations. Liquid wastes are trea ted and sampled prior to discha rge. Various solid wastes are generated from the manufacturing processes. Th ese wastes range in form and type from packaging and construction materials, worn-out tools and equipment, spent process chemicals, and oils to uranium sludges. The GNF-A waste ma nagement program provides the capability to select the most suitable management technique for a specific waste. The management concepts employed include eliminating waste; reducing vo lume through source separation; compacting and incinerating wastes; recycli ng and reusing wastes; and sell ing used sodium hydroxide and aqueous hydrogen fluoride (HF) (< 50 percent). Waste materials ar e collected according to the following two primary classifications: uranium-cont aminated or contamination-free. Exhibit C-7 in the GNF-Americas Wilmington environmenta l report supplement (GNF-A 2007) represents the GNF-A waste management program by primar y classification and end use or disposal

method

.

3.1.6 Westinghouse Electric Corporatio n CFFF, Columbia, South Carolina

Figure 3-6 illustrates the locati on of the CFFF near Columbia, South Carolina. The affected

environment as summarized below is described in detail in the following document, which is incorporated into this EA by reference:

• Final Environmental Assessment for the Renewal of U.S. Nuclear Regulatory Commission License No. SNM-1107 for Westi nghouse Columbia Fuel Fabrication Facility (NRC 2007a). April.

Site Description

The CFFF site occupies a 469-hectare (1,158-acre) area of semi-rural land in Richland County, South Carolina, approximately 13 kilometers [8 miles] southeast of the city of Columbia. The various facilities occupy approximately 24 hectares [60 acres] or about 5 percent of the property area. The remaining 445 hectares [1,100 acres] are undeveloped.

The CFFF is bounded by state highway SC 48 to the north and private property owners in all

other directions. The CFFF site lies within th e flood basin of the Congaree River, which flows approximately 6.4 kilometers [4 miles] southwest of the main plant. The site consists of timbered tracts and wetland areas penetrated by unimprove d roads. Much of the land within the site boundary is designated agricultura l. A variety of activities ar e conducted in the undeveloped portion of the site. These activ ities include managing the forested areas for timber production and harvesting hay fields. Recreatio nal facilities in the undevelope d portion of the site include a fitness trail, softball field, a nd a picnic pavilion for employee use. Employees are permitted to fish and hunt in designated areas on the CFFF property.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Figure 3-6. Columbia, South Carolina, Locator Map

The land around the CFFF site is used for a vari ety of purposes. Two school s are located within an 8-kilometer [5-mile] radius of the CFFF. S outh Carolina Electric and Gas is constructing a

new commercial electrical subs tation on approximately 2.8 hectares [7 acres] along the northwest border of the CFFF property on land pu rchased from WEC. The new facility should improve reliability of electrical service to the CFFF and other customers in the vicinity and will not routinely be staffed with personnel. The la nd sale and right-of-way issuance was completed in 2005. Two public parks are near the CFFF site: Bluff Road Park is located approximately 5.6 kilometers (3.5 miles) to the north, and Hopkins Park is approximately 4 kilometers (2.5 miles) to the east. Located approximately 8 k ilometers (5 miles) southeast of the CFFF is the Congaree National Park. Other faci lities in the vicinity includ e the Richland County Detention Center located 8 kilometers (5 miles) to the no rth. Two major military installations are located near the CFFF: Fort Jackson Military Reservatio n approximately 11 kilometers (7 miles) north, and McEntire Joint National Guard Station approx imately 9.7 kilometers (6 miles) northeast. Columbia and the surrounding ar ea contain a well-de veloped and maintained system of interstate, regional, and local highways that provide easy year-round acces s. Three interstate highways serve Columbia. The CFFF site can be accessed by state highway SC 48. Although CSX Transportation Inc. operates two rail lines cl ose to the CFFF site, there are no rail lines or spurs on the property

.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Radiation Environment

Radiological doses to the public from the CFFF operations are primarily from air emissions. Over 99 percent of the off-site dose originates from the airbor ne pathway. Typical cumulative

CFFF stack emissions would resu lt in a total effective dose of less than 0.4 mrem to a hypothetical exposed individual liv ing at the site boundary. For th e 6-year period from 2000 to 2005, this annual dose ranged between 0.30 mrem and 0.38 mrem. This is approximately 4 percent of the 10-mrem annual dose limit fr om air emissions cited in 10 CFR 20.1101. In contrast, the annual radiologica l total effective dose from liquid effluents is only 3 × 10 -4 

### mrem. The annual total effective dose from the combined e ffluent releases for the nearest actual resident to the licensed operations is approximately 3 × 10 -2 

### mrem. This is approximately 0.03 percent of the 100-mrem annual dose limit from all pathways imposed by 10 CFR 20.1301.

Seismic Environment

The CFFF site is not located near an active tect onic margin. The nearest major seismic source is the Charleston seismic zone, located approximately 145 kilometers (90 miles) southeast of the CFFF site. Seismicity in the area is charac terized by small-magnitude background earthquakes and very infrequent moderate-to-large intra-cont inental earthquakes. The U.S. Geological Survey reports that 69 earthquakes have occurred within a 200-kilometer (120-mile) radius of the CFFF site since 1973, ranging in magnitude from 1.1 to 4.9 on the Richter scale. The largest of these recent earthquakes occurred in 1974 and was locate d 144 kilometers (89.5 miles) from the CFFF site. However, an earthquake of magnitude 7.2 on the Richter scale occurred near Charleston, South Carolina, in 1886, killing 60 people and causing major damage in the area. The site has a 10-percent probability of exceeding a peak-groun d acceleration of approximately 0.1 g (rate of change of ground motion as compared to Earth’ s gravitational acceleration) and a 2-percent chance of exceeding a peak-ground acceleration of approximately 0.3 g in a 50-year period.

Groundwater

Groundwater samples from the site are collec ted quarterly and analyzed for radiological components. Analysis results indicate small ra diological impacts to gr oundwater from CFFF operations. In 1998, radiological sample results from three wells exceeded the gross beta investigation limit. In response, WEC implemented corrective actions to the CFFF operations and facilities, which eliminated the source causing the elevated gross beta levels.

Air Quality

Air pollutant concentration leve ls in Richland County are lower than the established National Ambient Air Quality Standards (NAAQS) for all pollutants except ozone. Portions of Lexington and Richland Counties, including the area ar ound the CFFF, have exceeded the NAAQS ozone standard. The EPA has deferred designating this area as nonattainment because the counties have successfully participated in the Early Action Compact. Pendi ng final EPA action, the stateFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

36 

### considers Richland County, especially southern Richland County where the CFFF is located, to

be an attainment area for ozone. 15



### Waste Management

Gaseous, liquid, and solid wastes are produced at th e site. Gaseous effluents from the radioactive material operations are treated a nd sampled before being released to the environment. Several types of liquid effluents stream s are produced. These effluent st reams are treated to remove radiological and nonradiological contaminants an d are sampled for regulatory compliance before being discharged. Low-level radioactive solid waste is also produced, which is sorted into one of two categories: combustible or noncombustible. Combustible waste is incinerated on-site; noncombustible waste is disposed of off-site at an NRC-approved and licensed low-level radioactive disposal facility such as the Barnwell site. Nonhazardous solid wastes are disposed of off-site at a state-permitted landfill.

3.2 Uranium Market

This section describes the uranium market th at could be affected by DOE’s Proposed Action. Unless otherwise noted, the followi ng description of th e uranium market is based largely on a

discussion of the uranium market available on th e copyrighted website of Cameco Corporation, a publicly traded uranium company (Cameco 2007); that description is used here by permission. 16



### Sources and Production

The only significant commercial use for uranium is to fuel nuclear reactors for the generation of electricity. In the United States, there are 104 operating commercial power reactors (NRC 2008). Before uranium is ready for use as nuclear fu el, it must undergo four intermediary processing steps, which collectively comprise the “fr ont end” of the uranium fuel cycle:

• mining and milling to produce triuranium octoxide (U 3 

### O 8 

### ), also called yellow cake or urania,

• refining and conversion to produce UF 6 

### and uranium dioxide (UO 2 

### ),

• enrichment to produce LEU, and

• fuel fabrication to produce the fuel assemblies or bundles used in reactors.

15 Personal communication: telephone conversation, May 19, 2008; William Fallon, Battelle; and Jack Porter, South Carolina Department of Health and Environmental Control.

16 Personal communication: e-mail, May 28, 2008; from Jennifer Skinner, Manager, Communication Projects, Cameco, to William Fallon, Battelle.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### Figure 3-7 illustrates the uranium fuel cycle.

LEU can be generated from several sources or processes, including (1) from NU (the mine

concentrates or U 3 

### O 8 

### ); (2) from conversion services that convert U 3 

### O 8 

### to UF 6 

### ; (3) from enrichment (the process of enriching UF 6 

### to LEU), and (4) from downblending HEU. Together,

U 3 

### O 8 

### plus UF 6 

### conversion is referred to as the “NU feed” component of the fuel.

Nuclear utilities, the end users of nuclear fuel , purchase uranium in all of these intermediate forms. Typically, a fuel buyer from power utilities contracts separately with suppliers at each step of the process. Sometimes, the fuel buyer may purchase enriched uranium product, the end product of mining/milling, conversion, and enrichment and contract separately for fabrication. Sellers consist of suppliers in each of the stages as well as brokers and traders.

In addition to being sold in different forms, uranium markets are differentiated by geography. The global trading of uranium has evolved into two distinct markets shaped by historical and political forces. The first, the western world market, comprises the Americas, Western Europe, and the Far East. A second market comprises count ries within the former Soviet Union, Eastern Europe, and China. Most of the fuel required fo r nuclear power plants in these countries is supplied from their own stockpiles. Often, producer s within these countries also supply uranium and fuel products to the western world mark et, thereby increasing competition. Fewer than 100 companies buy and sell uranium in the western world market.

Figure 3-7 Uranium Fuel CycleFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### New production from uranium mines supplies about 60 percent of the requirements of power utilities. The balance comes from secondary sources. Secondary supplies include existing inventories held by utilities a nd other fuel cycle companies, inventories held by governments, used reactor fuel that has been reprocessed, excess materials from military nuclear programs, and uranium in DU stockpiles. The uranium production industry is international in scope, with a small number of companies operating in relati vely few countries. In 2007, seven companies marketed 85 percent of the estimated worl d uranium mine produc tion of 41,279 tonnes U 3 

### 0 8 

### (WNA 2008).

Since 1985, western world uranium production has fallen short of we stern world utility uranium consumption. This shortfall has been covered by a number of secondary sources. Excess inventories held by utilities, produ cers, other fuel cycle participan ts, and governments have been and continue to be a significant source of supply, but availability is declining. Recycled products, including reprocessed uranium, mixed oxide fuel, and re-enriched tails materials, have been a source. Some utilities use repro cessed uranium and plutonium derive d from used reactor fuel as a source of supply. In recent years, another sour ce of supply has been the use of excess Russian enrichment capacity to re-enrich DU tails held by European enrichers. Finally, HEU derived from the dismantling of Russian nuclear wea pons has become a sign ificant source of LEU supply.

Demand Factors

Demand for uranium is directly linked to the le vel of electricity generated by nuclear power plants. Reactor capacity is growing slowly, and at the same time the reactors are being run more productively, with higher capacity fa ctors and reactor power levels.

An external factor expected to have a particularly important impact on the prospects for nuclear power is the trend toward the liberalization of el ectricity markets in many countries. Historically, electric power utilities in the western world have operated in regulated electricity markets. Typically, a government regulator allowed each util ity to serve a captive market area and earn a prescribed rate of retu rn on its assets. The focus was on deliver ing a reliable supply of electricity. Since the mid-1990s, however, there has been a transition toward market liberalization. This trend began in the United States and has been adopted to varyi ng degrees in Europe and the Far

East.

In theory, deregulation in the el ectrical generation industry should result in utilities competing

for market share on the basis of price, although the degree to whic h this is actually happening is

unclear. The new bottom-line focus has necessi tated changes in utilities’ planning and operations, including improving operating methods , lowering unit produ ction costs, and optimizing the use of assets. Faced with the cha llenge of deregulation, electric utilities worldwide have been restructuring th rough mergers and acquisitions.

U.S. nuclear utilities have dramatically impr oved the operating performa nce of their reactors. One measure of performance is the capacity f actor. In 2007, the 104 U.S. nuclear power reactors generated a record 806.5 billi on kilowatt-hours and achieved an average 91.8 per cent capacityFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

39 

### factor (WNA 2009). Improved reactor performance translates into greater uranium consumption and to more demand for nuclear services in general.

Uranium Sales Contracts

Unlike other metals such as copper or nickel, ur anium has historically not been traded on an organized commodity exchange. Inst ead, it is traded in most cas es through contracts negotiated directly between a buyer and a seller. However, in April 2007, the New York Mercantile Exchange announced a 10-year agreement to provi de for the trade of on- and off-exchange

uranium futures contracts.

The structure of uranium supply contracts varies widely. Pricing can be as simple as a single fixed price, or they can be based on various reference prices with economic indices built in. Contracts traditionally specify a base price, su ch as the uranium spot price, and rules for

escalation. In base-escalated cont racts, the buyer and seller agr ee on a base price that escalates over time on the basis of an agreed-upon formul a, which may take economic indices, such as gross domestic product and inflation factors, into consideration. Delivery quantities, schedules, and prices vary from contract to contract and often from delivery to delivery within the term of a

contract.

The Spot Market

A spot market contract usually cons ists of just one delivery and is typically priced at or near the published spot market price at the ti me of contract award. When a contract is priced at spot, it is usually the value quoted by one of the several market information services, such as Ux Consulting, TradeTech, or Nukem, at the end of th e month prior to the delivery date. Spot market delivery quantities vary from 23,000 kilograms (50,000 pounds) to a few hundred thousand pounds U 3 

### O 8 

### . Over the last few years, about 15 pe rcent of the western world's uranium requirements have been procured in the spot market—that is, for delivery within 12 months of

contract award.

The Long-term Market

Historically, some 85 percent of all uranium has been sold under long-te rm, multi-year contracts with deliveries starting 1 to 3 years after contract award. Long-te rm contract terms range from 2 to 10 years or more, with the first delivery occurring within 24 months of contract award. Commercial terms are specified in the contract for each individual (usually annual) delivery, although those terms may vary from delivery to delivery over the duration of the contract. Longterm contracts may include a clause that allows th e buyer to vary the size of each delivery within prescribed limits. For example, delivery quantit ies may vary from the prescribed annual volume by plus or minus 15 percent.

To diversify market risks, producers and utility cu stomers often maintain a mix of contract terms and pricing mechanisms in their contract portfoli os. Buyers are often willing to pay a premium in long-term contracts compared to spot prices, becau se they can achieve secure supply at prices that are more predictable.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### The U.S.-Russian HEU Agreement

The Energy Policy Act of 1992, Public Law 102-486, amended the Atomic Energy Act of 1954 by establishing USEC as a wholly-owned government corporation to take over the operation of DOE’s uranium enrichment enterprise. Subchapt er A of Title III of Public Law 104-134, the USEC Privatization Act, in Sect ion 3103, authorized USEC’s Boar d of Directors, with approval of the Secretary of the Treasury, to transfer the interest of th e United States in USEC to the private sector in a manner that provides for th e long-term viability of USEC, provides for the continuation by USEC of the operation of DOE’s GDPs, provides for the protection of the public interest in maintaining a reliable and economical domestic source of ur anium mining, enrichment and conversion services, and, to the extent not inconsistent wi th such purposes, secures the maximum proceeds to the United States.

In 1993, the United States and Russia entered into an agreement whereby Russia would dismantle a significant portion of its nuclear weapons by 2013. This agreement is known as the U.S.-Russian HEU agreement, or the “megatons-to-megawatts” agreement. It stipulates the annual quantities of HEU that ma y be delivered to the United States by Russia. The dismantled weapons contain a valuable resource for Russia. HE U can be blended down into LEU and sold in

the western world market as re actor fuel for hard currency.

In 1994, the USEC, as agent for the U.S. governme nt, and Russia signed an agreement whereby USEC would purchase the enrichment component of the LEU upon delivery to the United States. In 1999, Cameco and two other western compan ies, AREVA and RWE Nukem (now part of EnergySolutions), concluded an agreement w ith Russia whereby they have the option to purchase the majority of the natural feed compon ent of LEU. This agreement is officially called

the UF 6 

### Feed Component Implementing Contract. In November 2001, the western companies agreed to exercise a portion of their options to bring predictability to the program—predictable supply to the western market and pr edictable revenue to the Russians.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### 4.0 ENVIRONMENTAL IMPACTS

This chapter assesses the environmental impacts of DOE’s two Proposed Ac tion alternatives and

the No Action Alternative. Consistent with DOE and CEQ guidance, this assessment focuses on those areas where there is a poten tial for impacts to occur.

4.1 Existing Analyses and Scope of Impact Assessment

This section reviews ex isting, relevant NEPA documents; id entifies resource areas that DOE believes would not be impacted by the Proposed Ac tion and DOE’s basis for this position; and identifies the resource areas which DOE has identified as having a potential for impacts.

If implemented, the Proposed Action (Enrichment or Direct Sale Alternative) would result in a new source of feedstock for two operating and two soon-to-be-operating uranium enrichment facilities. Regardless of DOE’s Proposed Action, enrichment operations at these four facilities would continue or commence as currently schedul ed. The enrichment operations that would be implemented under DOE’s Proposed Action would us e existing work forces and existing plant and community infrastructures, and would not involve construc tion or expansion of any new

uranium enrichment or uranium fuel fabricati on plants. The environmental impacts of these ongoing and soon-to-be-ongoing enrichment and fuel fabrication plant operations have been previously analyzed in existing NEPA documents. Operations and impacts previously analyzed at these faculties would be unaffected, either adversely or beneficially, by the Proposed Action.

Plant operations, including st orage, at the three FFFs (AREVA NC, CFFF, and GNF-A) have also been addressed in existing NRC licensing and NEPA documents. Current or projected operations previously analyzed at these three faci lities would be unchanged, either adversely or bene ficially, by the Proposed Action. Any potential increm ental impacts at the three

nuclear fuel facilities from DO E’s Proposed Action would be asso ciated with on-site delivery and storage of LEU product, which is currently occurring at the fac ilities and has been previously assessed in NRC licensing and NEPA documents.

Because the Proposed Action involves no new constr uction and no on-site or off-site disturbance of previously undisturbed land, there would be no potential for the Proposed Action to impact current land use; biotic communities; cultural, hi storical, or archaeological resources; visual resources; ambient noise levels; threatened or endangered species or their critical habitats; wetlands; or floodplains. The existing and proj ected enrichment facility and FFF operational work forces previously analyzed would not ch ange as a result of DOE’s Proposed Action. The impacts to current or projected utility and public safety infrastructures in the communities where these plants are located would not differ from those impacts previously analyzed. The Proposed

Action would not result in criter ia air pollutant emissions be yond those already assessed in existing NEPA documents. The ambient air quality in the regions where enrichment and storage Separative Work Unit
The separative work unit (SWU) is a

uranium enrichment unit related to the amount of uranium processed, the composition of the starting material, and the degree to which it is enriched. The SWU is proportional to the total machine operation time required to achieve a desired level of enrichment, but it is defined independent of the

enrichment technolo gy

.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### activities would occur complies with app licable ambient air quality standards 17 

### . Health impacts related to air emissions resulting from transporta tion activities are addressed in the transportation impacts section (Section 4.2.1). There would be no environmental justice impacts beyond those discussed in the existing NEPA documents, whic h identified no environmental justice impacts due either to the absence of minority or low-in come populations, or to the absence of adverse impacts to any population.

The NEPA documents prepared by DOE and NRC fo r the enrichment facilities and FFFs that could be used to implement the Proposed Acti on are summarized below and are incorporated by

reference in accordance with 40 CFR 1502.21. The fo llowing subsections summarize the impacts from previous DOE and NRC analyses of uran ium enrichment and conversion operations and

uranium sales.

U.S. Department of Energy 1996 Assessment of Sale of Surplus Natural Uranium and LowEnriched Uranium

In 1996, DOE prepared an EA evaluating the imp acts of the sale of approximately 35.7 million pounds of natural uranium equivalent [U 3 

### O 8 

### (e)] (approximately 13,730 MTU) of surplus NU

and LEU in the form of UF 6 

### , stored at the department’s GDPs near Piketon, Ohio, and at Paducah, Kentucky (DOE 1996). 18 

### That EA analyzed six cate gories of potential impacts: radiation exposure under normal operations, tran sportation impacts, socioeconomic impacts, accidents, cumulative impacts, and environmental justice. DOE determined that the proposed sale or disposition of the excess uranium did not constitute a major federal action significantly affecting the quality of the human envi ronment within the meaning of NEPA. 19



### The 1996 EA demonstrated that the proposed sa le would not have a significant impact on collective radiological doses to wo rkers or the public due to tr ansportation or normal operations. In some cases, there would be a decrease in radiological dose due to reduced handling and transportation activities. Sale of all of the material in 1 year could result in a substantial

reduction in the collective radiol ogical dose to workers in the mi ning and conversion industries. Only if the uranium were all sold for foreign end use and shipped abroad for enrichment would there be an increase in risk due to transportation. The analysis showed a sli ght increase in dose to port workers and cylinder handlers at the GDPs. Im pacts resulting from a transportation accident and effects on the global commons were analyzed and shown to be minimal. The analysis of severe accidents indicated that pote ntially fatal exposures to HF could result if a cylinder were to fall and be punctured while its UF 6 

### contents were temporarily in liquid form (heated) for purposes of sampling; however, the probabi lity of such accidents was very low.

17 EPA classifies the northern half of Richland County, South Carolina, as a non-attainment area for 8-hour ozone. However, the state is an Early Action Compact state and the southern portion of Richland County, where the CFFF is located, is considered an attainment area by the state. (Personal communication: telephone conversation, May 19, 2008, W.E. Fallon, Battelle, and Jack Porter, South Carolina Department of Health and Environmental Control).

18 The amount of uranium proposed to be sold or enriched under DOE’s current Proposed Action (see Table 2-1)— 4,919 MTU of LEU product equivalent or 22,213 MTU of NU product equivalent—would exceed the 13,730 MTU proposed for sale in 1996.

19 EPA summary of EA and FONSI available online at http://www.epa.gov/ fedrgstr/EPAIMPACT/1996/October/Day-22/pr-17077.html

.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

43 

### U.S. Nuclear Regulatory Commission Analyses of Proposed National Enrichment Facility and American Centrifuge Plant

Under DOE’s Proposed Action, excess uranium could be enriched at two soon-to-be-operational enrichment facilities, the NEF and the ACP. To identify the impacts of operations at these facilities, DOE reviewed the recent NRC EI Ss for the NEF (NRC 2005) and ACP (NRC 2006). These analyses, which are incorporated into this EA by reference, are summarized in Tables 4-1 and 4-2. As characterized in these two EISs, the impacts are predominantly small, occasionally small to moderate, and in all instances could be mitigated. Most of the impacts are constructionrelated and therefore would not apply to DOE’s Proposed Action.

U.S. Department of Energy and U.S. Nuclear Regulatory Commission Analysis of Paducah Gaseous Diffusion Plant Operations

DOE reviewed existing analyses of impacts associ ated with uranium enrichment operations at the Paducah GDP (DOE 1982) and subsequent N RC assessments of USEC operations at the Paducah GDP. These analyses, which are summarized below, are incorporated into this EA by reference. In March 1982, DOE issued a FONSI indicating that “the operation of the Paducah GDP in the current [1982] mode, without any su bstantial modification, is not a Federal action significantly affecting the quality of the human environment.”

However, the modes of operation at the Pa ducah GDP have evolved since the DOE’s 1982 NEPA review and FONSI. In March 2001, NRC am ended USEC’s operating certificate for the Paducah GDP. The amendment permits USEC to enrich uranium to levels up to 5.5 percent 235 

### U. NRC reviewed environmental impacts associated w ith higher assay operations at the facility. As reported in an October 2000 Compliance Evaluation Report (NRC 2000):

“NRC reviewed available environmental re view documentation for the PGDP that was prepared in accordance with the Nati onal Environmental Policy Act. Available

NEPA documents include site-wide e nvironmental assessments by both the Department of Energy and the United Stat es Enrichment Corporation, and an NRC environmental assessment for approvi ng USEC’s compliance plan that was

associated with their initia l certificate application. The NRC staff conducted this

review to ensure that environmental eff ects associated with facility changes in support of higher assay operations rema ined appropriately bounded by previous NEPA analyses. Upon completion of this review, the NRC staff affirmed that there are no new and significant environmental impacts associated with higher assay operations at the PGDP . Therefore, consistent with the bases for the 10 CFR 51.22(c)(19) categorical exclusion, the N RC staff finds that issuance of the Certificate Evaluation Report for higher a ssay operation at the PGDP will not result in any significant new environmental im pact.” (Italicized emphasis added.)Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

44Table 4-1. Summary of Impacts from National Enrichment Facility Construction, Operation, and DecommissioningResource AreaImpact SummaryLand UseSmall Impact. Construction activities would occur on about 81 hectares (200acres) of a 220-hectare (543-acre) site that would befenced. The land is currently undisturbed except for a gravel access road, cattle grazing, and the presence ofa carbon dioxidepipeline.Historical andCulturalSmall Impact. There are seven archaeological sites on the proposed site.These sites are considered eligible for listing on the NationalRegister of Historic Places. Two siteswould be impacted by construction activities and a third is along the access road.Visual and ScenicSmall Impact. Impacts from construction activities would be limited to fugitive dust emissions that can be controlled using dustsuppression techniques. The cooling towers could contribute to the creation of fog 0.5 percent of the total hours per year (44hours peryear). The proposed NEF site received the lowest scenic-quality rating using the U.S. Bureau of Land Management visual resourceinventory process.Air QualitySmall Impact. Air concentrations of the criteria pollutants predicted for vehicle emissions and emissions of particulate matter of lessthan 10 microns in diameter (PM10) from fugitive dust during construction would all be below the NAAQS. Fugitive dust emissionswould be temporary and localized. A National Emissions Standards for Hazardous AirPollutants Title V permit would not berequired for operations due to the low levels of estimated emissions. All stack emissions would be monitored.Geology and SoilsSmall Impact. Construction-related impacts on the geology and soil would occur within the 81-hectare (200-acre) part of the site onwhich the proposed NEF structures would be built. Clay and gravel from a nearby site might be used during construction. No soilcontamination would be expectedduring construction and operations. A plan would be in place toaddress any spills that might occur.There would be no construction or operational impacts on unique mineral deposits or geological resources.Water ResourcesSmall Impact. There are no existing surface water resources. Impacts on water use would besmall because of the availability ofexcess capacity in the Hobbs and Eunice water supply systems. The proposed NEF’s indirect use of theOgallala Aquifer’s waterthrough the Eunice and Hobbs water supply systems would constitute a small portion of the aquifer reserves in New Mexico.EcologicalResourcesSmall Impact. Construction, operation, and decommissioning of the proposed NEF would have small impacts on ecologicalresources. There are no wetlands or unique habitats for threatened or endangered plantor animal species on the proposed NEF site.A large part of the site would remain undisturbed and in its natural state. The impacts of the use of water detention/retentionbasinswould be small because animal-friendly fencing and netting or other suitable material over the basins would be used to minimizeanimal intrusion. Revegetation using native plant species would be conducted in any areas impacted by proposed NEF activities.Thedesign and construction of the electrical transmission lines would address the protection of birds from electric shock.SocioeconomicsSmall Impact.During the 8-year construction period, the estimated employment would average nearly 400 jobs per year. Theincrease in the number of school-aged children during construction would average about 40. The impact on the school system wouldbe small—less than one new student per grade. Tax revenue impacts during construction would be moderate. During operation, theproposed NEF would employ a maximum of 210 people annually and would indirectly create an additional 173 jobs. The impact onlocal employment would be moderate—approximately 1 percent of the jobs in the area. The increase in demand for public serviceswould be small. Decontamination and decommissioning (D&D) would generally have small impacts.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

45Table 4-1. Summary of Impacts from National Enrichment Facility Construction, Operation, and Decommissioning (continued)Resource Area Impact SummaryEnvironmentalJusticeSmall Impact. Although the impacts to the general population were small to moderate, an examination of the various environmentalpathways by which populations could be affected found no disproportionately high and adverse impacts from construction, operation,or decommissioning on minority and low-income populations living near the proposed NEF or along the transportation routes intoand out of the proposed NEF.NoiseSmall Impact. Noise would come predominantly from traffic. Noise levels during operations would be within the U.S. Department ofHousing and Urban Development guidelines.TransportationSmall Impact during Normal Operations;Small to Moderate during Accidents.Truck trips removing nonradioactive waste and delivering supplies would have a small impact on the traffic on New MexicoHighway 234. Workforce traffic would also have a small impact on New Mexico Highway 234, with less than one injury and lessthan one fatality expectedannually due to traffic accidents. Truck shipments of feed, product, and waste materials (includingDUF6)would result in two latent cancer fatalities (LCFs) to the general population over the life of the proposed NEF due to vehicleemissions and fewer than 3 × 10-2LCFs due to direct radiation. All rail shipments of feed, product, waste materials, and emptycylinders would result in fewer than 8 × 10-2LCFs to the general population over the life of the proposed NEF due to vehicleemissions and 1 × 10-1LCFs from direct radiation. If a railaccident involving the shipment of DUF6occurred in an urban area, up to28,000 people could suffer adverse but temporary health effects with no fatalities due to chemical impacts. A truck accident involvingthe shipment of DUF6in an urban area could have temporary adverse chemical impacts on as many as 1,700 people.Small Impact during Decommissioning. Small impacts would occur if DUF6were temporarily stored at the proposed NEF for theduration of operations. Assuming that all of the material wereshipped during the first 8 years (the final radiation survey anddecontamination would occur during the ninth year), the proposed NEF would ship approximately 1,966 truckloads per year. If thetrucks were limited to weekday, non-holiday shipments, approximately 10 trucks per day or 21⁄2 railcars per day would leave the sitefor the DUF6conversion facility.Public andOccupationalHealth and SafetySmall Impact during Construction and Normal Operations.During normal operations, there would be approximately eightinjuries per year and no fatalities, based on statistical probabilities. A typical operations or maintenance technician could be exposedto 100 mrem of radiation annually. A typical cylinder yard worker could be exposed to 300 mrem of radiation annually. All publicradiological exposures would be significantly below the 10 CFR Part 20 regulatory limit of 100 mrem and the 40 CFR Part 190regulatory limit of 25 mrem annually for uranium fuel cyclefacilities. The nearest resident would receive less than 1.3 × 10-3mremdue to normal NEF operations.Small to Moderate Impact for Accidents. The most severe accident is estimated to be the release of UF6caused by the rupture of anoverfilled and/or overheated cylinder, which could result in a collective population dose of 12,000 person-rem and seven LCFs.Thedesign of the proposed NEF would include certain features to significantly reduce the likelihood of this event.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

46Table 4-1. Summary of Impacts from National Enrichment Facility Construction, Operation, and Decommissioning (continued)Resource Area Impact SummaryWasteManagementSmall Impact. Solid wastes would be generated during constructionand operations. Existing disposal facilities would have thecapacity to dispose of the nonhazardous solid wastes. In particular, impacts on the Lea County landfill would be small. There wouldbe enough existing national capacity to accept the low-level radioactive waste that would be generated at the proposed NEF.Small to ModerateImpact for DUF6Waste Management. Public and occupational exposures would be monitored and controlledto meet NRC regulations for radiation protection. LESidentified two potential means for disposing of DUF6: by private conversionand disposal facilities or by DOE through Section 3113 of the USECPrivatization Act. LES’s preferred strategy is to use privatefacilities outside of the State of New Mexico to convert and dispose of the DUF6byproduct. No final location has yet been determinedfor a private conversion facility, but the EIS contemplated potential DUF6conversion at a non-DOEfacility. Alternatively, DOEwould process the DUF6by extending the operation of its conversion facilities. This would prolong the impacts of DOE’s conversionfacilities, as described in DOE’s NEPA documentation. A private conversion facility would have much the same impacts as theplanned DOE conversion facilities at Paducah, Kentucky, and Portsmouth, Ohio.Source: NRC 2005.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

47Table 4-2. Summary of Impacts from American Centrifuge Plant Construction, Operation, and DecommissioningResource AreaImpact SummaryLand UseSmall Impact. Site preparation and construction activities would occur onapproximately 22 hectares (55 acres) of land, whichcomprises about 1 percent of the total 1,497-hectare (3,700-acre) DOE reservation. These changes would convert previouslydisturbed land (e.g., managed lawns, fields, and forests) on the DOE reservation to developed areas. The land is not consideredprime farmland, and changes would be consistent with current land use. It is anticipated that after decommissioning activitiesare completed, existing buildings and structures would remain on-site and the site would remaincategorized for industrial use.Historical/ArchaeologicalSmall Impact. NRC identified the Portsmouth GDP historic district, thirteen historic farmsteads, and one prehistoric lithicscatter as being potentially eligible for inclusion on the National Register of Historic Places. In addition, NRC included threeproperties located around the perimeter in its consideration of potential effects. There would be no adverse indirect or directeffect on these sites.VisualSmall Impact. Construction of the proposed ACP would not alter the site’s Bureau of Land Management Visual ResourcesManagement rating system classification of Class III or IV (moderate to little scenic value). There are no scenic rivers, naturepreserves, or unique visual resources in the proposed project area.Air QualitySmall to Moderate Impact. Airborne emissions from site preparation and construction should not result in exceedances of airquality standards, with the possible exception of short-term increases in particulate matter that could exceed the applicablestandard up to a distance of 1,000 meters (3,280 feet) beyondthe fenceline. Radiological releases from soil disturbances andfrom activities to refurbish existing buildings that would be used for the ACP would be small and controlled. Emissions fromdiesel generators would not cause air quality problems, andmaximum predicted concentrations of HF resulting from ACPoperations are below safe levels.Geology and SoilsSmall Impact. There is little likelihood of impact from soil compaction orsubsidence, and there are no unique mineral depositsor geologic resources that stand to be affected. The flat terrain where the ACP buildings would be located, and the dense soil,low moisture content, and vegetative cover in the area of a new 10-hectare (24-acre) cylinder storage yard to be located inanother spot on the reservation make landslides unlikely. Construction activities would not alter current drainage and would notdisturb any soils that qualify for protection as prime farmland. There would be a potential for increased erosion and siltationofstreams near the construction site of the new large cylinder storage yard, but both of these potential impacts should beminimized by the use of standard best management practices. The potential for soil contamination resulting from ACPoperations would be small. A plan would be inplace to address any spills that might occur.Water ResourcesSmall Impact.Groundwater withdrawals would increase by 10 percent over current usage rates, but would still be only31 percent of the total design capacity of the site’s well fields, would not affect groundwater availability, and would not pose anincreased risk of subsidence. Wastewater would continue to discharge from permitted National Pollutant Discharge EliminationSystem outfalls. Discharge rates, though increased above current levels, would represent only 75 percent of the existingsystem’s design capacity. USEC does notanticipate any liquid discharges of radioactive materials from the proposed ACP (i.e.,from cooling water, storm water runoff, or sanitary water).The potential for leaks or spillsthat could contaminate waterresources would be limited by an approved Spill Prevention Control and Countermeasures Plan.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

48Table 4-2. Summary of Impacts from American Centrifuge Plant Construction, Operation, and Decommissioning (continued)Resource AreaImpact SummaryEcological ResourcesSmall Impact. Construction of the new large cylinder storage yard referenced in the section on geology and soils would resultin increased erosion, stormwater runoff, and loss of 10 hectares (24 acres) of vegetation but, with planned best managementpractices, would result in small impacts to the flora and fauna inand around the tributaries ofLittle Beaver Creek. That samecylinder storage yard would also be located within 500 meters(1,640 feet) of suitable summer habitat for the endangeredIndiana bat, although studies have not documented the presence ofthis bat species on the DOE reservation. None of the siteconstruction activities would occur in wetlands. However, someconstruction would occur adjacent to small wetlands, andstandard erosion control measures would be used to limit sedimentation in these areas.SocioeconomicsSmall to Moderate Impact. During construction, full-time employment is estimated to be 3,362 jobs. The impact to regionalemployment during construction would be approximately 3.5 percent, which is considered moderate. The impact to tax revenueduring construction is expected to be small, generating 0.03 percent of Ohio individual income tax receipts and 0.06 percent ofsales tax. The impact to tax revenue is considered small. The impact to population characteristics is considered small,approximately 0.13 percent of the regional population. The impact to area housing, community services, and public utilitieswould also be small. During the ACP operations phase between the years 2010 and 2040, 1,500 jobs would be created in theregion of influence. These impacts to regional employment are considered moderate, based on existing employment levels in theregion. During operations, there would be a small increase in regional tax revenues as well as small impacts to populationcharacteristics, housing resources, community and social services, and public utilities.EnvironmentalJusticeSmall Impact. An examination of the various environmental pathways by which low-income and minority populations could beaffected found no disproportionately high or adverse impacts from construction, operation, or decommissioning on any of thesepopulations.NoiseSmall Impact.No adverse noise impacts from routine ACP operationsare expected at the closest residence due to lowoperational noise, the attenuation providedby the building facade, and distance attenuation of over900 meters (3,000 feet).Catastrophic failure of a centrifuge could cause a sudden, brief loud noise due to the high rotational speed of the centrifuge.However, the likelihood of a single centrifuge catastrophically failing is very low. Noise levels during D&D are also anticipatedto be small and similar to those generated during construction of the ACP.TransportationSmall to Moderate Non-radiological Impacts from Routine Transportation.Increased truck and vehicle traffic associated with proposed ACP operations should result in small changes in current levels ofcongestion and delays on U.S. Route 23 and Ohio State Road 32.Traffic associated with proposed operations should also resultin small increases in the number of traffic accidents resultingin injuries or fatalities. Substantially greater transportationrequirements during the construction phase could result in moderate impacts during the 5-year period in which most of theproposed construction activity is projected to occur. The NRC estimates that increased traffic during construction wouldtemporarily decrease the level of service onU.S. Route 23 and, to a lesser extent,on Ohio State Road32. The changes onU.S. Route 23 would temporarily increase traffic density, affectthe ability to maneuver within the traffic stream, and reduceFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

49Table 4-2. Summary of Impacts from American Centrifuge Plant Construction, Operation, and Decommissioning (continued)Resource AreaImpact Summarytravel speeds somewhat. It is also expectedthat construction traffic accidents would result in about 18 injuries a year involvingemployees traveling to and from their jobs, and 1 fatality overthe entire construction period. These same injury and fatalityrates would be expected if the same employees were driving to different employers.Small Radiological Impacts from Routine Transportation and Transportation Accidents.The transportation of materialscontaining radionuclides would result in some increased risk of cancer both to the occupational workers transporting andhandling the material and to members of the public driving along the roads or living along the transportation routes. Thetransport of all materials is estimated to result in approximately 0.014 LCFs per year of operation from exposure to directradiation during “incident-free” transport(i.e., shipping that does not involve the breach of a shipping container and subsequentrelease of radioactive material), and anadditional 0.008 LCFs per year from accidents that result in the release of radioactivematerial into the environment. The total LCFs is estimated to be0.02 per year of operation, or less than one cancer fatality overthe 30 years of operation.Moderate Non-Radiological Impacts from Transportation Accidents. Transportation accidents involving the release of UF6,which is the form of uranium that would be transported the mostto and from the proposed ACP, could also result in chemicalimpacts to drivers and the surrounding public. When released from a shipping cylinder, UF6reacts with the moisture in theatmosphere to form HF and uranyl fluoride (UO2F2), both of which can cause adverse effects due to chemical toxicity (asopposed to radiation hazards) if exposures are high enough. Theanalysis shows that the probability of a severe transportationaccident that released sufficient quantities of UF6that could pose a health risk is low, but that the consequences of such anaccident, should it occur, are high. Based on the analysis, the impacts associated with such anaccident as part of the proposedaction are considered moderate.Small Impact During D&D. Traffic associated with material and equipmenttransportation to the siteduring this phase wouldbe much lower than that during site preparation and construction. D&D activities, including waste generation and handling,would require almost 5,000 truck shipments for off-site disposal over the 5-year decommissioning period proposed by USEC.Because this volume of truck traffic is far less than the estimated 17,870 truck trips needed during the 5-year proposed ACPconstruction period, the transportation impacts associated with the decommissioning truck traffic should be far less than thatdescribed for site preparation and construction. The number of LCFs from the incident-free transportation of all D&D waste isestimated to be less than one, and there are no projected deathsresulting from the release of radioactive material as a result ofaccidents during such shipments.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

50Table 4-2. Summary of Impacts from American Centrifuge Plant Construction, Operation, and Decommissioning (continued)Resource AreaImpact SummaryPublic andOccupational Healthand SafetySmall Impact. The proposed action would result in small increases in the current number of occupational injuries and illnessesat the site, though still less than historical levels. Construction and process areas would be segregated, and personnel monitoringprograms would be implemented, to minimize worker exposures to annual radiation doses of less than the 10 CFR § 20.1201limit of 5,000 mrem. The maximum dose to members of the public resulting from routine radiation exposures is estimated to be1 mrem per year, for a hypothetical person living on the northern boundary of the DOE reservation. This estimated dose issignificantly below the 10 CFR Part 20 regulatory limit of 100 mrem per year and 40 CFR Part 190 regulatory limit of 25 mremper year for uranium fuel-cycle facilities.Analytical results also indicate that plausible radiological accidents at the proposed ACP pose low risks. In addition, publicandoccupational exposures to non-radiological contaminants are projected to be less than applicable limits. Occupational exposuresduring on-site D&D would be bounded by the potential exposures during operation. At the end of plant life, gas centrifugescontaining residual uranium would be purged, leaving radioactive material in amounts significantly less than handled duringoperations. Because systems containing this residual contamination would be opened, decontaminated (with the removedradioactive material processed and packaged for disposal), and dismantled, an active environmental and dosimetry (external andinternal) program would be conducted to maintain as low asreasonably achievable (ALARA)doses to workers and doses toindividual members of the public as required by 10 CFR Part 20.Waste ManagementSmall Impact. Site preparation, construction, and operations would generate varying amounts of low-level radioactive, lowlevel mixed, hazardous, sanitary/industrial, and recyclable wastes. All of these wastes would be managed in accordance withexisting procedures for controlling contaminant releases and exposures. With the exception of the DU, all of the wastes wouldalso be generated at volumes that are well within existing management capacities.The ACP would generate approximately 41,105 cylinders of DUF6, containing approximately 512,730 MT (535,200 tons) ofmaterial. Production of DUF6for the 10 percent enrichment scenario would be less than this amount. All of this DUF6could beconverted to a more stable chemical form at a new conversionfacility that DOE is constructing near Piketon, which wouldrequire DOE to significantly extend the life of this facility.The converted material would then be shipped by rail to anacceptable western disposal site, where sufficient capacity exists and where the disposal impacts should be small.Source: NRC 2006.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

51 

### U.S. Department of Energy Analysis of Uranium Hexafluoride Conversion Facilities at

Paducah and Portsmouth

In three EISs analyzing constr uction and operation of proposed UF 6 

### conversion facilities (two DU conversion facility EISs [DOE 2004a, DOE 2004b] and a PEIS [DOE 1999b]), DOE found that environmental impacts associated with the proposed action alternatives would include (1) impacts to local air, water, soil, ecological, and cultural resources du ring conversion facility construction; (2) impacts to workers from fac ility construction and operations; (3) impacts from

small amounts of DU and other hazardous co mpounds released to the environment through normal conversion plant air effluents; (4) impact s from the cylinder prep aration, shipment of cylinders, conversion products, and waste product s; and (5) impacts from potential accidents involving the release of radioactive material or hazardous chemicals. However, most of the identified impacts were associated with the cons truction (now complete at Portsmouth and nearly complete at Paducah) rather than the future operation of the new conve rsion facilities. As discussed in Section 2.3, the No Action Alternative for this EA relative to DU is the status quo; that is, DOE would implement the currently planned operation of these two new facilities rather than implementing either of the Proposed Action alternatives described in Sections 2.1 and 2.2. Consequently, the operational impacts DOE asse ssed in its two DU conversion facility EISs (DOE 2004a, 2004b) are tantamount to the impacts of the No Action Alternative for DU assessed in this EA. In addition, the two DU conversion fa cility EISs evaluated continued storage of NU and LEU cylinders as part of th eir no action alternatives, which is comparable to the No Action Alternative in this EA and is also comparable to the storage of NU and LEU cylinders after

enrichment at Portsmouth and Paducah in the Proposed Action of this EA. Therefore, DOE anticipates no new or previously unrecognized or unanalyzed impacts. Ta ble 4-3 summarizes the impacts for DU conversion assessed in the PE IS and the two conversion facility EISs. 20 

### The impacts are predominantly small to moderate and can be mitigated. Impacts that are

construction-related would not apply to DOE’s Proposed Action.

Cylinder preparation refers to the activities necessary to prepare DUF 6 

### cylinders for off-site transportation. DUF 6 

### cylinders were designed, built, te sted, and certified to meet DOT requirements for shipment by truck and rail. However, after several decades in storage, some cylinders no longer meet these requirements. Two options for preparing these cylinders for shipment were evaluated in the PEIS (DOE 1999 b). As one option, cylinders that do not meet DOT requirements could be placed inside protec tive metal “overcontainers” for shipment. These reusable overcontainers, which woul d be slightly larger than a cylinder, would be designed to meet all DOT requirements. Anothe r option is to transfer a cylinde r’s contents to a new cylinder. Under this option, the DUF 6 

### in cylinders that do not m eet DOT requirements would be transferred to new cylinders capab le of being transported. Activitie s associated with transfer to another cylinder include genera l maintenance and monitoring of cylinders and the valves, inspections, painting, repairs, and use of a heatin g process to facilitate the actual transfer.

20 A full description of these impacts is available online at http://web.ead.anl.gov/uranium/pdf/PAD-Summary.pdf (Paducah facility) and http://web.ead.anl.gov/uranium/pdf/PORT-Summary.pdf (Portsmouth facility).Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

52Table 4-3. Summary of Expected Impacts from Operation of the Paducah and the Portsmouth Conversion FacilitiesResource AreaImpactLand UseNegligible.Cultural Resources None.ResourceRequirementsResource requirements include constructionmaterials, fuel, electricity, process chemicals, and containers. In general,there would be a negligible effect on the local or national availability of these resources.Air Quality During general operations, it is estimated thattotal concentrations for all criteria pollutants (except for PM2.5) would bewell within standards. The background level of annual average PM2.5in the area of both sites approaches or exceeds thestandard. The total concentrations of VOCs, uranium, and fluoride would also be well below applicable standards. Forstandard cylinder preparation at Paducah, concentrations of criteria pollutants would be below 0.03% of the respectivestandards. Overcontainer and transfer operations would be below 0.08% of standards for criteria pollutants. Impactsfrom Portsmouth operations would be slightly less.Water and Soil For general operations, there would be no appreciable impacts on surface water,groundwater, or soils from theconversion facilities because no contaminated liquid effluents are anticipated and because airborne emissions would beat very low levels (e.g., < 0.25 grams per year of uranium). For cylinder preparation activities, there would be zero tonegligible impacts to surface water and groundwater.Ecological Concentrations of contaminants in the environment during operations would be below harmful levels. Impacts tovegetation and wildlife would be negligible.Socioeconomics An estimated 150 jobs would be generated duringconstruction of the cylinder yard, and an estimated 280 jobs would begenerated during construction of the conversion facility. There would be an approximate 0.1 percent annual growth injobs. With limited in-migration of population expected, there would be a marginal impact on local housing, publicfinancing, or local service employment.EnvironmentalJusticeNo disproportionately high and adverse human health or environmental impacts are expected to minority or low-incomepopulations.NoiseEstimated operational noise levels at the nearest residence would be below the EPA guideline of 55 A-weighted decibels(dB[A]) as day-night average sound level for residential zones.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

53Transportation During normal transportation operations, radioactive material and chemicals wouldbe contained within their transportpackages. Health impacts to crew members (i.e., workers) and members of the public along the routes could occur ifthey were exposed to low-level external radiation in the vicinity of uranium material shipments. In addition, exposure tovehicle emissions (engine exhaust and fugitive dust) could potentially cause latent fatalities from inhalation.Traffic accidents could occur during the transportation of radioactive materials and chemicals. These accidents couldpotentially affect the health of workers(i.e., crew members) and members of thepublic, either from the accident itself orfrom accidental releases of radioactive materials or chemicals.The total number of traffic fatalities (unrelated to the type of cargo) was estimated on the basis of national trafficstatistics on shipments by both truck and rail. If the aqueous HF was sold, about 1 traffic facility would be estimatedunder both transportation modes. If HF were neutralized to calcium fluoride (CaF2), about 2 fatalities would beestimated for the truck option and 1 fatality for the rail option.Severe transportation accidents could also result in a releaseof radioactive material orchemicals from a shipment. Theconsequences of such a release would depend on the material released, location of the accident, and atmosphericconditions at the time. Potential consequences would be greatest in urban areas because more people could be exposed.Human Health andSafety –Normal OperationsFor general operations, the estimated potential exposures ofworkers and members of the public to radiation andchemicals would be well within applicable public healthstandards and regulations during normal facility operations(including 10 CFR Part 835, 40 CFR Part 61 Subpart H, and DOE Order 5400.5). The estimated doses and risks fromradiation and/or chemical exposures of the public and noninvolved workers would be very low, with zero LCFsexpected among these groups over the time periods considered, and with minimal adverse health impacts from chemicalexposures expected.The estimated risks for involved workers would be as follows: preparation of standard cylinders: zero to 0.09 LCFs;overcontainer: 0.07 to 0.2 LCFs; transfer: 0.2 to 0.4 LCFs. There would be no impacts to the noninvolved worker or thegeneral public from preparation of standard cylinders or overcontainers. Impacts from transfer operations for thenoninvolved worker are estimated at 2 × 10-8to 5 × 10-8LCFs, while impacts to the general public are estimated at6 × 10-7to 1 × 10-6LCFs. No chemical impacts would be anticipated. The impacts at Portsmouth are estimated to beslightly less than those at Paducah.Table 4-3. Summary of Expected Impacts from Operation of the Paducah and the Portsmouth Conversion Facilities(continued)Resource AreaImpactFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

54Human Health andSafety –Facility AccidentsFor general operations, workers could be injured as a resultof operational accidents unrelated to radiation or chemicalexposure. About 8 injuries per year duringoperations could occur. It is possiblethat accidents could release radiation orchemicals to the environment,potentially affecting both the workers andmembers of the general public. Of all theaccidents considered, those involving DUF6cylinders and those involving chemicals at the conversion facilities wouldhave the largest potential effects.For cylinder preparation operations at Paducah, bounding radiological accidents with a frequency in the range of one in10,000 years to one in a million years:•The impacts to noninvolved workers are estimated at 6 × 10-3LCFs,•The impacts to the general public within 80 kilometers (50 miles) are estimated at 0.01 LCF.The impacts for noninvolved workers are estimated to be similar at Portsmouth, while the impacts to the general publicare estimated to be slightly less at Portsmouth.The impacts from chemical accidents at Paducah with the same frequency of occurrence are estimated to be 300 to 330noninvolved workers with irreversible adverse effects from all cylinder preparation activities.At Portsmouth, it is estimated that 110 noninvolved workers would have irreversible adverse effects from standardpreparation and overcontainer activities, and 440 noninvolvedworkers would have irreversible adverse effects fromtransfer operations.For both sites, the impacts tothe general public from chemical accidents areestimated to be 1 person with irreversibleadverse effects from the preparation of standard cylinders and overcontainer operations, and zero impacts from transferoperations.Potential impacts to groundwater, surface water, and soil under storage accident conditions were evaluated in DOE2004a and DOE 2004b. Impacts were found to be below all standards and health-based guides used for comparison.D&D Activities D&D impacts to involved workers would be primarily from external radiation; expected exposures would be a smallfraction of operational doses; no LCFs would be expected. Itis estimated that no fatalities and up to five injuries wouldresult from occupational accidents. Impacts from waste management would include a total generation of about275 cubic yards (210 cubic meters) of LLW, 157 cubic yards (120 cubic meters) of LLMW, and 157 cubic yards(120 cubic meters) of hazardous waste; these volumes would result in low impactscompared with projected site annualgeneration volumes.Waste Management Waste generated during operations would have negligible impacts on the waste management operations at both sites,with the exception of possible impacts from disposal of CaF2. Industrial experience indicates that HF, if produced,would contain only trace amounts of DU (less than 1 part per million). It is expected that HF would be sold for use. Ifsold, the sale would be subject to review/approval by DOE incoordination with the NRC, depending on the specific use.Table 4-3. Summary of Expected Impacts from Operation of the Paducah and the Portsmouth Conversion Facilities(continued)Resource AreaImpactFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

55Table 4-3. Summary of Expected Impacts from Operation of the Paducah and the Portsmouth Conversion Facilities(continued)Resource AreaImpactCumulative Impacts The cumulative collective radiological exposure to the off-site population would be well below the maximumDOE doselimit of 100 mrem per year to the off-site MEI and belowthe limit of 25 mrem/yr specified in 40 CFR Part 190 foruranium fuel cycle facilities. Annual individual doses to involved workers would be monitored to maintain exposurebelow the regulatory limit of 5 rem per year.At Paducah, up to 6,000 rail shipments and 18,600 truck shipments of radioactive material could occur. Thecumulative maximum dose to the MEI along the transportation route near the site entrance would be less than1 mrem per year under for all transportation modes. At Portsmouth, up to 6,800 rail shipments and 12,300 truckshipments of radioactive material could occur. The cumulative maximum dose to the MEI along the transportationroute near the site entrance would be less than 1 mrem per year under for all transportation modes.The sites are located in attainment regions.However, the background annual-average PM2.5concentration is near(for Paducah) or exceeds (for Portsmouth) the regulatory standard. Cumulative impacts would not affect attainmentstatus.Data from the 2000 annual groundwater monitoring showed that four pollutants (for Paducah) and five (forPortsmouth) exceeded primary drinking water regulation levels in groundwater. Goodengineering and constructionpractices should ensure that indirect cumulative impacts on groundwater associated with the conversion facilitieswould be minimal.Cumulative ecological impacts on habitats and biotic communities, including wetlands, would be negligible tominor.Cumulative land use impacts are anticipated to be negligible to minor.Given the absence of high and adverse cumulative impactsfor any impact area considered, no environmental justicecumulative impacts are anticipated despite the presence of disproportionatelyhigh percentages of low-incomepopulations in the vicinity of both sites.Socioeconomic impacts under all alternatives considered are anticipated to be generally positive, often temporary,and relatively small.Sources: DOE 2004a, 2004b.PM2.5= particulate matter with a diameter of 2.5 microns or less; PM10= particulate matter with a diameter of 10 microns or less.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

56 

### It is unknown exactly how many of the DUF 6 

### cylinders currently do not meet the DOT transportation requirements. If a cylinder fa iled an inspection for compliance with DOT regulations, it would be prepared using one of these cylinder preparation options (DOE 1999b).

As seen in Table 4-3, the operational impacts a ssessed in the two DU conversion facility EISs are very nearly identical. This reflects the fact that these facili ties are physically and operationally very nearly identical and would be operated by the same firm.

Conclusion

In the context of impacts at enrichment facilities , DU feed is similar chemically and physically to NU feed. DU feed would have slightly lower radiological hazard than NU feed because of

decreased 234 

### U and 235 

### U. Given equal amounts of DU or NU feed, there would also be a slightly lesser amount of DU tails with an assay of 0.20 percent than DU tails with an assay of 0.35 percent. In addition, DU tails with an assa y of 0.20 percent would have a slightly lower radiological hazard than DU tails with an a ssay of 0.35 percent because of the decreased 234 

### U. Enrichment activities would also take place within the NRC-licensed capacities at the enrichment facilities. Therefore, DOE has determined that the impacts of enriching DU tails would be similar to or slightly less th an the impacts of enriching NU.

In the context of impacts at conversion facilitie s, DU tails with an assay of 0.20 percent would have a slightly lower radiological hazard than DU tails with an assay of 0.35 percent, again

because of decreased 234 

### U. In addition, given equal amounts of feed, there would also be a slightly lesser amount of DU tails with an assa y of 0.20 percent than DU tails with an assay of 0.35 percent. Therefore, DOE has determined that the impacts of converting DU tails with an assay of 0.20 percent would be sim ilar to or slightly less than the impacts of converting DU tails with an assay of 0.35 percent. At the Portsmouth conversion facilit y, the number of DU cylinders could increase slightly, from 20,931 to 21,086 (0.7 pe rcent), as a result of the Proposed Action in this EA. At the Paducah conversion facility, th e number of DU cylinde rs could also increase slightly, from 41,013 to 41,168 (0.4 percent), as a re sult of the Proposed Action in this EA. The impacts from these incremental changes would be minor.

Based on the nature of the Proposed Action and on DOE’s review of existing NEPA documents

as summarized above for the enrichment faciliti es and conversion faciliti es, DOE has determined that impacts to the human environment due to enrichment operations and conversion of DU tails from enrichment (1) have been adequately ch aracterized in existing DOE and NRC documents and (2) are small to moderate in nature. In addition, DOE has determined that the primary potential for impacts under the Proposed Action is related to (1) health, safety, and accident impacts associated with additional and previ ously unanalyzed transportation of the excess inventory to proposed enrichment sites; (2) health, safety and accident impacts associated with transportation and storage of NU product and LE U product and transportation of DU tails; and (3) relevant socioeconomic impacts. These impact areas and the impacts associated with the No Action Alternative are assessed in the following sections.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

57 

### 4.2 Enrichment Alternative

4.2.1 Transportation Impacts under the Enrichment Alternative

DOE analyzed the potential impacts of shipping part of its excess NU, LEU, and DU feed from its current storage locations at the Portsmout h and Paducah GDPs to the location(s) where it

could be enriched. Enrichment c ould occur at four sites: (1) the currently operating Paducah GDP in Paducah, Kentucky; (2) the ACP near Piketon, Ohio, which is scheduled to begin enrichment operations in 2010; (3) the NEF near Eunice, New Mexico, which is scheduled to begin enrichment operations in late 2009; and (4) the French enrichment facility operated by

AREVA that is located at the Tricastin nuclear complex in south-centr al France on a diversion canal of the Rhone River, approximately 130 kilometers (80 miles) north of the port of

Marseilles.

Previous EIS analyses of transportation accid ent impacts (2004a and 2004b) have shown that accident impacts are larger when the radioactive material is released to the atmosphere as opposed to being released to surface water, due to the relative importance of the inhalation pathway versus the drinking water or aquatic food pathways as routes of exposure. Analyses in

both of those EISs indicated that the contents of a cylinder released to a pool of standing water would not impact members of the general public and would have negligible impacts on the ecology. Thus, the analysis in this EA focuses on human health impacts from releases to the atmosphere and traffic fatalities.

Several federal regulations govern required activ ities related to transp ortation practices and accidents. DOE Order 460.2A requires that DOE or ganizations conduct operations in compliance with all applicable international, federal, state, local, and tribal laws, rules, and regulations governing materials transportation th at are not inconsistent with federal regulations. This would include DOT hazardous materials regulations contained in 49 CFR Parts 171 through 180, Federal Motor Carrier Safety Administration regulations contained in 49 CFR 395 and 397, and NRC regulations contained in 10 CFR 71, as applicable.

DOE Manual 460.2-1A establishes a se t of standard transportation practices for DOE to use in planning and executing off-site shipments of radi oactive materials. These practices establish a standardized process and framework for interacting with state, tribal, and local authorities, other federal agencies, and transporta tion contractors and carriers rega rding DOE radioactive material shipments. Practices are described for the following topics:

• Transportation planning—the transportation pl anning activities that take place after the need for shipment has been identified;

• Emergency planning—DOE emergency planni ng activities with state and tribal jurisdictions;

• Projected shipment planning information—pr ovision of information regarding projected shipments;Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

58 

### • Routing—practices to identify and select transpor tation routes;

• Security—actions taken to ensure the security of shipments;

• Carrier/driver requirements—practices to ensure that shipments use hi gh-quality carriers and drivers;

• Shipment prenotification—near-term notif ication activities for pending shipments;

• Transportation operational contingencies—ope rational contingencies that may interrupt normal transport operations;

• Tracking—DOE practices for tracking the location of shipments and facilitating

communication with the driver s/crew of the vehicles;

• Inspections—inspections of shipments, includi ng verifications of vehicle roadworthiness and radiological conditi on of containers loaded on the vehicles;

• Safe parking—the criteria to be used in se lecting appropriate parking locations in the event that transportation opera tional contingencies occur;

• Emergency notification—the process DOE uses to notify state and trib al officials, after

DOE itself has received notificati on, of a transportation emergency;

• Emergency response—DOE response to a transportation emergency;

• Recovery and cleanup—post-emer gency actions taken to recover and clean up from an

accident or incident.

In addition, DOT regulation 49 CFR 171.15 contai ns requirements for notifications of transportation incidents involving hazardous materials.

After enrichment, DOE could ship the LEU product t o, and store it at, one or more of five sites: (1) AREVA NC in Richland, Washington; (2) the CFFF near Columbia, South Carolina; (3) GNF-A near Wilmington, North Carolina; (4) DOE Portsmouth; and (5) DOE Paducah. NU product could be stored at the enrichment site or it could be shipped to the DOE Paducah or Portsmouth facilities for storag e. If the NU product was stored, it would be done so in accordance with the NRC licenses or DOE require ments at these facilities, as applicable.

The transportation impacts of shipping NU feed and product, LEU feed and product, DU feed,

and DU tails were evaluated under both incident -free and accident conditions. Representative highway, rail, and barge routes fr om the enrichment, storage, a nd commercial nuclear FFFs were determined using the WebTRAGIS routing co mputer code (Johnson and Michelhaugh 2003). The routes conform with current routing prac tices and applicable routing regulations and guidelines. Route characteristic s include the distances and p opulation densities in rural, suburban, and urban population density zones. The populations that might be exposed alongFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

59 

### these routes were determined using data from the 2000 census. Table 4-4 lists the distances and the population densities for the tr ansportation routes. Figure 4-1 illustrate s the rail and truck routes. Barge traffic would be on the Mississippi River. Population da ta were extrapolated to the year 2035 to account for the duration of the Proposed Action.

Table 4-4. Transportation Distances and Population Densities
Distance (km) Population Density (people/km 2 ) Origin Destination Rural Suburban Urban Total Rural Suburban Urban

Truck Routes

Portsmouth

GDP/ACP GNF-A 546.5 408.8 33.8 989.0 18.3 359.6 2,150.2

Portsmouth

GDP/ACP CFFF 419.5 330.9 30.4 78 0.7 17.6 367.7 2,277.5

Portsmouth

GDP/ACP AREVA NC 3,236.8 725.6 61.1 4,023.0 11.4 294.0 2,259.0

Portsmouth

GDP/ACP Paducah GDP 558.9 310.2 18.0 886.9 20.8 283.6 2,186.4

Portsmouth

GDP/ACP NEF 1,717.8 673.5 77.4 2,468.4 14.5 323.1 2,246.4

Paducah GDP GNF-A 729.1 555.2 31.5 1,315.8 19.1 331.9 2,086.5

Paducah GDP CFFF 569.5 384.4 21 .1 975.0 18.8 301.8 2,144.6 Paducah GDP AREVA NC 2,880.9 558.3 65.9 3,505.1 9.3 318.2 2,203.0 Paducah GDP NEF 1,405.7 420.8 41.5 1,867.8 12.3 313.2 2,270.7 NEF GNF-A 1,907.8 838.9 68.0 2,814.6 14.5 306.4 2,191.0

NEF CFFF 1,615.1 692.2 64.4 2, 371.6 14.1 314.8 2,192.6

NEF AREVA NC 2,911.3 485.4 81.8 3,478.4 7.6 341.9 2,323.2

Rail Routes

Portsmouth

GDP/ACP GNF-A 733.3 349.9 25.7 1,109.1 17.5 367.1 2,013.5

Portsmouth

GDP/ACP CFFF 657.8 280.5 18.5 95 7.1 17.6 340.3 2,020.3

Portsmouth

GDP/ACP AREVA NC 3,204.1 558.6 127.6 3,890.2 7.0 373.7 2,355.7

Portsmouth

GDP/ACP Paducah GDP 577.4 184.6 40.3 802.1 14.9 381.3 2,466.4

Portsmouth

GDP/ACP NEF 1,968.1 603.9 112.8 2,684.7 11.6 419.0 2,286.8

Paducah GDP GNF-A 899.6 505.6 62.0 1,467.2 14.9 403.9 2,101.7

Paducah GDP CFFF 694.7 447.5 62.3 1,204.6 15.4 408.1 2,113.3 Paducah GDP AREVA NC 3,205.7 450.1 67.3 3,723.2 6.1 356.9 2,203.4 Paducah GDP NEF 1,467.7 386.8 60.5 1,914.9 9.4 435.1 2,200.6 NEF GNF-A 2,169.6 808.4 122.6 3,100.5 11.2 413.8 2,225.7

NEF CFFF 1,920.9 790.9 108.9 2, 820.2 12.5 419.7 2,201.2

NEF AREVA NC 2,932.1 620.8 180.2 3,733.2 7.8 376.9 2,567.8 Barge Routes

Portsmouth

GDP Port of New

Orleans 2,081.9 119.0 21.4 2,222.4 5.1 296.4 2,566.6

Paducah GDP Port of New

Orleans 1,313.7 25.9 7.9 1,347.5 2.7 254.0 2,873.4Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

60 

### Figure 4-1. Rail and Truck Routes

Radiological dose during normal, in cident-free transportation of ra dioactive materials result from exposure to the external radiati on field that surrounds the shipping containers. The dose is a function of the number of people exposed, their proximity to the containers, their length of time of exposure, and the intensity of the radiation field surrounding the containers. The radiation

dose rate at 1 meter from UF 6 

### containers ranges from about 0.2 to 1 mrem per hour (NRC 2005, NRC 2006). In this analysis, the ra diation dose rate was estimated to be 1 mrem per hour at a distance of 1 meter (3 feet) from the cylinders used to ship the UF 6



### .

Radiological impacts were determined for cr ew workers and the ge neral population during normal, incident-free transportati on. For truck shipments, the crew were drivers of the shipment vehicles. For rail shipments, the crew were work ers in close proximity to the shipping containers during railcar inspection or classification. The general popula tion was the individuals within 800 meters (2,600 feet) of the road or railway (o ff-link), sharing the road or railway (on-link), and at stops. Collective doses for the crew a nd general population were calculated using the RADTRAN 5 computer code (Ne uhauser and Kanipe 2000; Neuhaus er et al. 2000). Individual radiation doses were also estimated for peopl e along the route at a distance of 30 meters (100 feet) from the highway or railroad. Nonr adiological incident-free impacts were also determined for exhaust and fugitive dust emissions from highway and rail traffic.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

61 

### Human health impacts could also result from tr ansportation accidents in which no radioactive material would be released (i.e., traffic fatali ties), and from transportation accidents in which

radioactive material could be released from a cylinder. For transportation accidents involving a release of radioactive material, DOE estimated radiological accident ri sks (probability of occurrence × consequence) expressed as the num ber of latent cancer fatalities (LCFs) summed over a complete spectrum of accidents, incl uding the severe accidents presented in Section 4.2.1.5. Impacts were evaluated for the popul ation within 80 kilometers (50 miles) of the road or railway using the RADTRAN 5 comput er code. DOE assumed that people would be exposed through inhalation, direct external dose fr om radioactive material that has deposited on the ground after being dispersed from the accident si te (referred to as groundshine), and direct external dose from the passing cloud of disper sed radioactive material (referred to as cloudshine). In addition to tran sportation accident risks, the radiological and toxicological consequences of severe tran sportation accidents involving UF 6 

### releases were also evaluated.

The total impacts of transportation are the sum of the radiological and nonradiological incidentfree and accident impacts. For incident-free tran sportation, the impacts ar e (1) the radiological impacts from exposure to low le vels of radiation from the UF 6 

### cylinders, and (2) the nonradiological impacts from truck or train e xhaust (vehicle emissions). For accidents, the impacts are (1) the radiological risks associated with the UF 6 

### being shipped, and (2) nonradiological traffic fatalities. The toxicological accident risks associated with the UF 6 

### being shipped were not included with the estimat e of accident risk because these risks were previously shown to be small relative to radiol ogical accident risks and nonradiological traffic fatalities (Biwer et al. 2001). The range in impacts presented in this EA is primarily due to

differences in the amounts of materials that would be shipped for each case analyzed and differences in the distances over which the materials would be shipped.

Cancer is the principal potential risk to human health from exposur e to low or chronic levels of radiation. Radiological health im pacts are expressed as the increm ental changes in the number of expected fatal cancers (referred to as latent can cer fatalities, or LCFs) for populations and as the incremental increases in lifetime probabilities of contracting a fatal cancer for an individual. The

estimates are based on the dose received and on dose-to-health-effect conversion factors recommended by the Interagency Steering Committee on Radiation Standards (Lawrence 2002). The steering committee consists of eight federal agencies (the EPA, NR C, DOE, Department of Defense, Department of Homeland Securi ty, DOT, Occupational Safety and Health Administration, and Department of Health and Human Services), three federal observer agencies (the Office of Science and Technology Policy, O ffice of Management and Budget, and Defense Nuclear Facilities Safety Board), and two state observer agencies (Illinois and Pennsylvania). The steering committee estimated that for the ge neral population and workers, a collective dose of 1 person-rem would yield 6 × 10 -4 

### excess LCFs.

Table 4-5 summarizes the characteristics of cylinders commonly used to ship or store UF 6 

### , and Table 4-6 presents the number of cylinders that would be shipped under the Proposed Action. More information on these cylinders may be found in The UF 6 

### Manual, Good Handling Practices for Urani um Hexafluoride (USEC 2006). The characteristics of other cylinders used to ship or store UF 6 

### are presented in Table 2 of the UF 6 

### manual.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

62 

### Table 4-5. Characteristics of Selected Uranium Cylinders

Parameter 48X Cylinder 48Y Cyli nder 48G Cylinder 30B Cylinder

Material Steel Steel Steel Steel
Nominal length (inches) 119 150 146 81

Nominal diameter (inches) 48 48 48 30

Wall thickness (inches) 0.625 0.625 0.3125 0.5

Volume (ft 3 ) 108.9 142.7 139.0 26.0
Weight limit (MT UF 6 ) 9.539 12.501 12.174 2.277
Weight limit (MTU) 6.45 8.45 8.23 1.54
Maximum enrichment (weight percent 235 U) 4.5 4.5 1.0 5.0

Source: USEC 2006.



### Table 4-6. Number of Cylinders and Truck, Rail, and Barge Shipments under the Proposed

Action

Material Number of Cylinders Truck Shipments Rail Shipments Barge Shipments

NU feed 2,270 2,270 568 36

DU feed 10,776 a 10,776 2,695 167

LEU feed 296 296 75 7

LEU product 3,195 1,065 267 17

DU tails b 10,931 10,931 2,733 169

NU product 3,445 3,445 862 53

DU tails c 6,450 6,450 1,613 100

a. This EA uses 10,776 DU cylinders fo r its estimate of im pacts. In Appendix D, comment #4 from USEC noted that the actual DU cylinder count would be less, la ter determined to be 8, 871 for DU feed. This correc tion would normally provide the basis for a recalculation of estimated impacts, and, in this case, would lower the estimate of impacts. In light of the already low estimates of potential impacts, this recalculation was not performed. b DU tails from enrichment of NU feed, DU feed, and LEU feed to LEU product. c. DU tails from enrichment of DU feed to NU product.



### The number of cylinders of NU feed, DU feed, and 1,100 MTU of LE U feed represent the actual number of cylinders in DOE’s inventory. 21 

### DU tails are primarily stored in 48G cylinders, although 48Y cylinders might also be used (NRC 2005) 22 

### . The 48G cylinder is slightly smaller than the 48Y cylinder. Therefore, the number of DU tails cylinders was estimated using the 48G cylinder. An additional 900 MTU of LEU feed was also analyzed. This additional 900 MTU of

LEU feed was assumed to have an enrichment of 1.7 percent. LEU with en richment greater than 1.0 percent but less than 4.5 percent is typically shipped in 30 B cylinders. However, most excess LEU feed is currently stored in 48X and 48G cyli nders. The 48X cylinder is slightly smaller than the 48G cylinder. Therefore, the number of LEU feed cylinders was es timated using the 48X

21 This draft EA used 10,776 DU cylinders for its estimate of impacts. During comment resolution, the actual DU cylinder count was determined to be 8,871 for DU feed. This correction would normally provide the basis for a

recalculation of estimated impacts, and, in this case, would lower the esti mate of impacts. In lig ht of the already low estimates of potential impacts, this recalculation was not performed.

22 Existing DU tails are also stored in 12A, 30A, 48H, 48O, 48OM, and 48X cylinders.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

63 

### cylinder. NU is typically shipped in 48X or 48Y cylinders. The 48X cylinder is slightly smaller than the 48Y cylinder. Therefore, the number of NU product cylinders was estimated using the 48X cylinder. LEU enriched to 4.95 percent is typically shipped in 30B cylinde rs. Therefore, the 30B cylinder was used to estimate th e number of LEU product cylinders.

To estimate the radiological impacts associat ed with transportation, the 48X, 48Y, and 48G cylinders were modeled as if they were 48Y cylinders. A 48Y cylinder is the longest of the cylinders commonly used to ship NU or DU, whic h tends to increase in cident-free impacts, and is also the largest of the cyli nders commonly used to ship NU and DU, which tends to increase radiological accident impacts.

The radionuclide content of UF 6 

### is due to the naturally occurring isotopes of uranium ( 234 

### U, 235 

### U,

and 238 

### U) and their short-lived radioactive progen y. Table 4-7 lists the radionuclide inventories

of 234 

### U, 235 

### U, and 238 

### U contained in the cylinders.

Table 4-7. Radionuclide Inventory of Uranium Cylinders

Material 234 U Inventory

(Ci) 235 U Inventory

(Ci) 238 U Inventory

(Ci)

NU feed or product a 2.8 0.13 2.8

DU feed b 1.1 0.064 2.8

LEU feed c 7.4 0.31 2.8

LEU product d 4.4 0.16 0.49

DU tails e 0.50 0.037 2.8

a. NU feed or product assumed to be 0.711 weight percent 235 U. b. DU feed has a range of enrichments fro m 0.35 to less than 0.711 weight percent 235 U. In this analysis, the DU feed

enrichment was assumed to be 0.35 weight percent 235 U, which maximizes the amount of DU tails. Also see footnote 5 on page 5.

c. LEU feed assumed to be 1.7 weight percent 235 U. d. LEU product assumed to be 4.95 weight percent 235 U. e. DU tails assumed to be 0.20 weight percent 235 U.



### The numbers of cylinders that would be necessary to ship and store the feed, product, and tails are listed in Table 4-6. For 48X, 48Y, or 48G cy linders, one cylinder was assumed to be shipped on a truck. For 30B cylinders, typically three to five cylinders are ship ped on a truck (NRC 2005; USEC 2006). Because three cylinde rs per truck would yield higher estimates of the number of shipments than five cylinders pe r truck, three cylinders were assu med to be shipped on a truck. Because impacts could be higher if five cylinders were involved in a severe accident, the impacts are presented for severe accidents involving three cylinders or five cylinders. For rail shipments, four 48X, 48Y, or 48G cylinders or twelve 30B cylinders were assumed to be shipped on a railcar. For barge shipments, sixty-five 48X, 48Y , 48G, or 30B cylinders were assumed to be shipped on a barge based on the number of cylinders shipped in the barge illustrated in Figure 46

in USEC 2006.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

64 

### 4.2.1.1 Impacts from Truck Shipments

For truck shipments of UF 6 

### , radiation doses were evaluated for workers and members of the public. Workers included the driver s of the trucks carrying the UF 6 

### , workers involved in loading and unloading the UF 6 

### cylinders, and workers who inspected UF 6 

### shipments. For members of the public, radiation doses were estimated for peopl e along the route, people sharing the route (in traffic), and people at stops. The number of health effects from vehicle emissions, the number of traffic fatalities, and the radiol ogical accident risks were also estimated. The radiological and toxicological impacts of seve re transportation ac cidents are discussed in Section 4.2.1.5.

Transportation impacts were estimated for en richment of NU, DU, and LEU feed to LEU product, for enrichment of DU feed to NU pr oduct, and for enrichment of DU feed to NU product followed by subsequent enrichment of NU product to LEU product. Transportation impacts also include transporta tion of LEU product to FFFs. Impacts are presented for enriching the entire surplus DOE inventory, and for enri ching the equivalent of 2,000 MTU of NU and enriching the equivale nt of 4,000 MTU of NU in a given year.

The impacts from truck shipments of UF 6 

### are listed in Tables 4-8a, 4-8b, and 4-8c. Impacts are quantified in terms of total fatalities, which are the sum of radiati on-related LCFs, vehicle emission health effects, and tra ffic fatalities. For enrichment of NU, DU, and LEU feed to LEU product, the estimated number of total fatalities ranged from 0.22 to 2.5, depending on where the enrichment of the NU, DU, and LEU feed o ccurred and where the LEU product and DU tails were shipped. If 30B cylinders were used to transport LEU feed material instead of 48X cylinders, the impacts would also range from 0.22 to 2.5 total fatalities. The estimated number of fatalities from enriching the equivalent of 2,000 MTU of NU in a given year ranged from 0.0087 to 0.092, and the estimated number of fatalities from enriching the equivalent of 4,000 MTU of NU in a given year ranged from 0.018 to 0.21. For perspective, over the period 2002 to 2006, about 43,000 people were killed each year in moto r vehicle accidents in the United States (DOT 2007).

For enrichment of DU feed to NU product, the estim ated number of total fatalities ranged from 0.18 to 1.9, depending on where the enrichment of the DU feed occurred and where the NU product and DU tails were shipped. The estimated number of fatalities from enriching the equivalent of 2,000 MTU of NU in a given ye ar ranged from 0.016 to 0.18, and the estimated

number of fatalities from en riching the equivalent of 4,000 MT U of NU in a given year ranged

from 0.030 to 0.32.

For enrichment of DU feed to NU product followe d by subsequent enrich ment of NU product to LEU product, enrichment at more than one enrichment facility could occur. The estimated number of total fatalities ranged from 0.19 to 2.7, depending on where the enrichment of the DU feed to NU product occurred, where the enrichme nt of the NU product to LEU product occurred, where DU tails were shipped, and where the LEU product was shipped. The estimated number of fatalities from enriching the equivalent of 2,000 MTU of NU in a given year ranged from 0.017 to 0.25, and the estimated number of fatalities from enriching the equivalent of 4,000 MTU of NU in a given year ranged from 0.031 to 0.45.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

65Table 4-8a. Total Transportation Impacts from Truck Shipments of Uranium Hexafluoride under the Proposed ActionCasePublic (LCFs) Worker (LCFs)Vehicle EmissionHealth Effects(LCFs)Radiological AccidentRisk (LCFs)Traffic FatalitiesTotalFatalitiesEnrichment to LEU at the Paducah GDPNU, DU, LEU feed1.7 × 10-28.3 × 10-22.3 × 10-28.7 × 10-29.9 × 10-23.1 × 10-1LEU product(on-site storage)-- 5.2 × 10-3------5.2 × 10-3LEU product if shippedto FFFsa4.0 × 10-3to 1.0 × 10-21.2 × 10-2to 2.5 × 10-23.7 × 10-3to 7.5 × 10-34.9 × 10-2to 1.2 × 10-11.4 × 10-2to 5.2 × 10-28.3 × 10-2to 2.1 × 10-1Total1.7 × 10-2to 2.7 × 10-28.9 × 10-2to 1.1 × 10-12.3 × 10-2to 3.0 × 10-28.7 × 10-2to 2.1 × 10-19.9 × 10-2to 1.5 × 10-13.1 × 10-1to 5.2 × 10-1Enrichment of DU to NU at the Paducah GDPDU feed1.3 × 10-26.7 × 10-21.8 × 10-26.3 × 10-27.9 × 10-22.4 × 10-1NU product(on-site storage)-- 8.0 × 10-3------8.0 × 10-3Total1.3 × 10-27.5 × 10-21.8 × 10-26.3 × 10-27.9 × 10-22.5 × 10-1Enrichment to LEU at the ACP (Portsmouth)NU, DU, LEU feed1.1 × 10-26.5 × 10-21.5 × 10-25.7 × 10-26.5 × 10-22.1 × 10-1LEU product(on-site storage)-- 5.2 × 10-3------5.2 × 10-3LEU product if shippedto FFFsa3.4 × 10-3to 1.2 × 10-21.3 × 10-2to 2.8 × 10-24.2 × 10-3to 8.3 × 10-36.3 × 10-2to 1.2 × 10-11.1 × 10-2to 5.9 × 10-29.4 × 10-2to 2.3 × 10-1Total1.1 × 10-2to 2.3 × 10-27.1 × 10-2to 9.3 × 10-21.5 × 10-2to 2.3 × 10-25.7 × 10-2to 1.8 × 10-16.5 × 10-2to 1.2 × 10-12.2 × 10-1to 4.4 × 10-1Enrichment of DU to NUat the ACP (Portsmouth)DU feed9.0 × 10-35.3 × 10-21.2 × 10-24.2 × 10-25.3 × 10-21.7 × 10-1NU product(on-site storage)-- 8.0 × 10-3------8.0 × 10-3Total9.0 × 10-36.1 × 10-21.2 × 10-24.2 × 10-25.3 × 10-21.8 × 10-1Enrichment to LEU at the NEFNU, DU, LEU feed6.6 × 10-22.2 × 10-19.3 × 10-24.2 × 10-14.1 × 10-11.2LEU producta6.1 × 10-3to 1.0 × 10-21.6 × 10-2to 2.4 × 10-25.2 × 10-3to 8.1 × 10-38.0 × 10-2to 1.4 × 10-12.7 × 10-2to 5.1 × 10-21.4 × 10-1to 2.3 × 10-1DU tails (to Portsmouthor Paducah)4.0 × 10-2to 6.3 × 10-21.6 × 10-1to 2.0 × 10-15.3 × 10-2to 9.1 × 10-21.8 × 10-1to 3.1 × 10-12.8 × 10-1to 3.7 × 10-17.1 × 10-1to 1.0Total 1.1 × 10-1to 1.4 × 10-13.9 × 10-1to 4.4 × 10-11.5 × 10-1to 1.9 × 10-16.7 × 10-1to 8.7 × 10-17.2 × 10-1to 8.3 × 10-12.0 to 2.5Enrichment to NU at the NEFDU feed5.3 × 10-21.8 × 10-17.5 × 10-23.0 × 10-13.3 × 10-19.4 × 10-1NU producta1.3 × 10-2to 2.0 × 10-24.9 × 10-2to 6.2 × 10-21.7 × 10-2to 2.9 × 10-29.6 × 10-2to 1.7 × 10-18.9 × 10-2to 1.2 × 10-12.6 × 10-1to 4.0 × 10-1DU tails (to Portsmouthor Paducah) 2.4 × 10-2to 3.7 × 10-29.2 × 10-2to 1.2 × 10-13.2 × 10-2to 5.4 × 10-21.0 × 10-1to 1.8 × 10-11.7 × 10-1to 2.2 × 10-14.2 × 10-1to 6.1 × 10-1Total8.9 × 10-2to 1.1 × 10-13.2 × 10-1to 3.5 × 10-11.2 × 10-1to 1.6 × 10-15.0 × 10-1to 6.5 × 10-15.9 × 10-1to 6.7 × 10-11.6 to 1.9Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEUTotal0.0090 to 0.15 0.072 to 0.490.012 to 0.210.042 to 0.960.053 to 0.890.19 to 2.7a. Range in product results is due to shipping product to various off-site storage locations.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

66Table 4-8b. Transportation Impacts from Truck Shipments of 2,000 MTU of Uranium Hexafluoride in a Given Year under the ProposedActionCasePublic (LCFs) Worker (LCFs)Vehicle EmissionHealth Effects(LCFs)Radiological AccidentRisk (LCFs)Traffic FatalitiesTotalFatalitiesEnrichment to LEU at the Paducah GDPNU, DU, LEU feed6.7 × 10-43.3 × 10-39.0 × 10-43.5 × 10-33.9 × 10-31.2 × 10-2LEU product(on-site storage)-- 2.1 × 10-4------2.1 × 10-4LEU product if shippedto FFFsa1.6 × 10-4to 4.1 × 10-44.8 × 10-4to 9.9 × 10-41.5 × 10-4to 3.0 × 10-42.0 × 10-3to 4.7 × 10-35.7 × 10-4to 2.1 × 10-33.3 × 10-3to 8.5 × 10-3Total6.7 × 10-4to 1.1 × 10-33.5 × 10-3to 4.3 × 10-39.0 × 10-4to 1.2 × 10-33.5 × 10-3to 8.2 × 10-33.9 × 10-3to 6.0 × 10-31.3 × 10-2to 2.1 × 10-2Enrichment of DU to NU at the Paducah GDPDU feed1.2 × 10-36.1 × 10-31.6 × 10-35.7 × 10-37.2 × 10-32.2 × 10-2NU product(on-site storage)-- 7.3 × 10-4------7.3 × 10-4Total1.2 × 10-36.8 × 10-31.6 × 10-35.7 × 10-37.2 × 10-32.3 × 10-2Enrichment to LEU at the ACP (Portsmouth)NU, DU, LEU feed4.4 × 10-42.6 × 10-35.9 × 10-42.3 × 10-32.6 × 10-38.5 × 10-3LEU product(on-site storage)-- 2.1 × 10-4------2.1 × 10-4LEU product if shippedto FFFsa1.4 × 10-4to 4.9 × 10-45.1 × 10-4to 1.1 × 10-31.7 × 10-4to 3.3 × 10-42.5 × 10-3to 4.9 × 10-34.6 × 10-4to 2.4 × 10-33.8 × 10-3to 9.2 × 10-3Total4.4 × 10-4to 9.3 × 10-42.8 × 10-3to 3.7 × 10-35.9 × 10-4to 9.2 × 10-42.3 × 10-3to 7.2 × 10-32.6 × 10-3to 5.0 × 10-38.7 × 10-3to 1.8 × 10-2Enrichment of DU to NUat the ACP (Portsmouth)DU feed8.2 × 10-44.8 × 10-31.1 × 10-33.8 × 10-34.8 × 10-31.5 × 10-2NU product(on-site storage)-- 7.3 × 10-4------7.3 × 10-4Total8.2 × 10-45.6 × 10-31.1 × 10-33.8 × 10-34.8 × 10-31.6 × 10-2Enrichment to LEU at the NEFNU, DU, LEU feed2.6 × 10-38.8 × 10-33.7 × 10-31.7 × 10-21.6 × 10-24.8 × 10-2LEU producta2.5 × 10-4to 4.1 × 10-46.5 × 10-4to 9.5 × 10-42.1 × 10-4to 3.2 × 10-43.2 × 10-3to 5.6 × 10-31.1 × 10-3to 2.0 × 10-35.4 × 10-3to 9.3 × 10-3DU tails (to Portsmouthor Paducah) 1.6 × 10-3to 2.5 × 10-36.2 × 10-3to 7.8 × 10-32.1 × 10-3to 3.7 × 10-37.0 × 10-3to 1.2 × 10-21.1 × 10-2to 1.5 × 10-22.8 × 10-2to 4.1 × 10-2Total4.5 × 10-3to 5.6 × 10-31.6 × 10-2to 1.8 × 10-26.1 × 10-3to 7.7 × 10-32.7 × 10-2to 3.5 × 10-22.9 × 10-2to 3.3 × 10-28.2 × 10-2to 9.9 × 10-2Enrichment of DU to NU at the NEFDU feed4.8 × 10-31.6 × 10-26.8 × 10-32.7 × 10-23.0 × 10-28.5 × 10-2NU producta1.2 × 10-3to 1.8 × 10-34.5 × 10-3to 5.6 × 10-31.5 × 10-3to 2.6 × 10-38.8 × 10-3to 1.5 × 10-28.1 × 10-3to 1.1 × 10-22.4 × 10-2to 3.6 × 10-2DU tails (to Portsmouthor Paducah)2.2 × 10-3to 3.4 × 10-38.4 × 10-3to 1.1 × 10-22.9 × 10-3to 4.9 × 10-39.4 × 10-3to 1.7 × 10-21.5 × 10-2to 2.0 × 10-23.8 × 10-2to 5.5 × 10-2Total8.1 × 10-3to 1.0 × 10-22.9 × 10-2to 3.2 × 10-21.1 × 10-2to 1.4 × 10-24.6 × 10-2to 6.0 × 10-25.3 × 10-2to 6.1 × 10-21.5 × 10-1to 1.8 × 10-1Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEUTotal8.2 × 10-4to 1.4 × 10-26.5 × 10-3to 4.4 × 10-21.1 × 10-3to 1.9 × 10-23.8 × 10-3to 8.7 × 10-24.8 × 10-3to 8.1 × 10-21.7 × 10-2to 2.5 × 10-1a. Range in product results is due to shipping product to various off-site storage locations.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

67Table 4-8c. Transportation Impacts from Truck Shipments of4,000 MTU of Uranium Hexafluoride in a Given Year under theProposed ActionCasePublic (LCFs) Worker (LCFs)Vehicle EmissionHealth Effects(LCFs)Radiological AccidentRisk (LCFs)Traffic FatalitiesTotalFatalitiesEnrichment to LEU at the Paducah GDPNU, DU, LEU feed1.4 × 10-36.9 × 10-31.9 × 10-37.3 × 10-38.2 × 10-32.6 × 10-2LEU product(on-site storage)-- 4.4 × 10-4------4.4 × 10-4LEU product if shippedto FFFsa3.3 × 10-4to 8.6 × 10-49.9 × 10-4to 2.1 × 10-33.1 × 10-4to 6.2 × 10-44.1 × 10-3to 9.9 × 10-31.2 × 10-3to 4.3 × 10-36.9 × 10-3to 1.8 × 10-2Total1.4 × 10-3to 2.3 × 10-37.4 × 10-3to 9.0 × 10-31.9 × 10-3to 2.5 × 10-37.3 × 10-3to 1.7 × 10-28.2 × 10-3to 1.3 × 10-22.6 × 10-2to 4.3 × 10-2Enrichment of DU to NU at the Paducah GDPDU feed2.2 × 10-31.1 × 10-23.0 × 10-31.0 × 10-21.3 × 10-24.0 × 10-2NU product(on-site storage)-- 1.3 × 10-3------1.3 × 10-3Total2.2 × 10-31.2 × 10-23.0 × 10-31.0 × 10-21.3 × 10-24.1 × 10-2Enrichment to LEU at the ACP (Portsmouth)NU, DU, LEU feed9.1 × 10-45.4 × 10-31.2 × 10-34.8 × 10-35.4 × 10-31.8 × 10-2LEU product(on-site storage)-- 4.4 × 10-4------4.4 × 10-4LEU product if shippedto FFFsa2.8 × 10-4to 1.0 × 10-31.1 × 10-3to 2.3 × 10-33.5 × 10-4to 6.9 × 10-45.2 × 10-3to 1.0 × 10-29.6 × 10-4to 4.9 × 10-37.9 × 10-3to 1.9 × 10-2Total9.1 × 10-4to 1.9 × 10-35.9 × 10-3to 7.7 × 10-31.2 × 10-3to 1.9 × 10-34.8 × 10-3to 1.5 × 10-25.4 × 10-3to 1.0 × 10-21.8 × 10-2to 3.7 × 10-2Enrichment of DU to NU atthe ACP (Portsmouth)DU feed1.5 × 10-38.9 × 10-32.0 × 10-37.0 × 10-38.8 × 10-32.8 × 10-2NU product(on-site storage)-- 1.3 × 10-3------1.3 × 10-3Total1.5 × 10-31.0 × 10-22.0 × 10-37.0 × 10-38.8 × 10-33.0 × 10-2Enrichment to LEU at the NEFNU, DU, LEU feed5.5 × 10-31.8 × 10-27.8 × 10-33.5 × 10-23.4 × 10-21.0 × 10-1LEU producta5.1 × 10-4to 8.6 × 10-41.4 × 10-3to 2.0 × 10-34.3 × 10-4to 6.7 × 10-46.7 × 10-3to 1.2 × 10-22.3 × 10-3to 4.3 × 10-31.1 × 10-2to 1.9 × 10-2DU tails (to Portsmouthor Paducah) 3.3 × 10-3to 5.2 × 10-31.3 × 10-2to 1.6 × 10-24.5 × 10-3to 7.6 × 10-31.5 × 10-2to 2.6 × 10-22.3 × 10-2to 3.1 × 10-25.9 × 10-2to 8.6 × 10-2Total9.3 × 10-3to 1.2 × 10-23.3 × 10-2to 3.7 × 10-21.3 × 10-2to 1.6 × 10-25.6 × 10-2to 7.2 × 10-26.0 × 10-2to 7.0 × 10-21.7 × 10-1to 2.1 × 10-1Enrichment of DU to NU at the NEFDU feed8.8 × 10-33.0 × 10-21.3 × 10-25.0 × 10-25.5 × 10-21.6 × 10-1NU producta2.1 × 10-3to 3.3 × 10-38.2 × 10-3to 1.0 × 10-22.8 × 10-3to 4.8 × 10-31.6 × 10-2to 2.8 × 10-21.5 × 10-2to 2.0 × 10-24.4 × 10-2to 6.6 × 10-2DU tails (to Portsmouthor Paducah)4.0 × 10-3to 6.2 × 10-31.5 × 10-2to 1.9 × 10-25.3 × 10-3to 9.0 × 10-31.7 × 10-2to 3.0 × 10-22.8 × 10-2to 3.7 × 10-27.0 × 10-2to 1.0 × 10-1Total1.5 × 10-2to 1.8 × 10-25.3 × 10-2to 5.9 × 10-22.1 × 10-2to 2.6 × 10-28.4 × 10-2to 1.1 × 10-19.8 × 10-2to 1.1 × 10-12.7 × 10-1to 3.2 × 10-1Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEUTotal1.5 × 10-3to 2.5 × 10-21.2 × 10-2to 8.1 × 10-22.0 × 10-3to 3.5 × 10-27.0 × 10-3to 1.6 × 10-18.8 × 10-3to 1.5 × 10-13.1 × 10-2to 4.5 × 10-1a. Range in product results is due to shipping product to various off-site storage locations.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

68 

### For enrichment at the Paducah GDP or the ACP, transportation impacts would be lower if the NU, DU, or LEU feed were obtained on-site and the NU or LEU product were stored on-site, and the only impacts would be for workers who loaded and unloaded cylinders for on-site movements. In addition, DU tails and NU produc t would not be shipped, resulting in lower transportation impacts.

For enrichment at the NEF, transportation impact s would be slightly higher because the NU, DU, or LEU feed would be shipped from DOE Paduc ah or DOE Portsmouth to Eunice, New Mexico, and the DU tails would be dispositioned by the enrich ment facility or poten tially shipped back to DOE Paducah or DOE Portsmouth. In addition, NU pr oduct could be shipped back to Paducah or Portsmouth, resulting in highe r transportation impacts.

Table 4-9 lists the impacts for the MEI along the transportation route. This individual was assumed to be located 30 meters (100 feet) from the route and to be exposed to all shipments of

UF 6 

### (i.e., NU feed, NU product, DU feed, DU tails, LEU feed, and LEU product). The shipments were assumed to travel at a speed of 24 kilomete rs (15 miles) per hour, which is representative of speeds in urban areas. The probability of an LCF for the MEI along the transportation route was estimated to range from 8.3 × 10 -8 

### to 5.3 × 10 -7 

### over 25 years.

Table 4-9. Maximum Individual Impacts from Truck Shipments a

Case Mode LCFs

Enrichment to LEU at Paducah GDP Truck 1.9 × 10 -7

Enrichment of DU to NU at Paducah GDP Truck 1.2 × 10 -7

Enrichment to LEU at Portsmouth ACP Truck 1.3 × 10 -7

Enrichment of DU to NU at Portsmouth ACP Truck 8.3 × 10 -8

Enrichment to LEU at NEF Truck 5.0 × 10 -7

Enrichment of DU to NU at NEF Truck 4.0 × 10 -7

Enrichment of DU to NU followed by subsequent

enrichment of NU to LEU Truck 9.9 × 10 -8 to 5.3 × 10 -7

a. Impacts are based on a person located 30 meters from the highway. The person was assumed to be exposed to all shipments of UF 6 . The shipments were assumed to travel at a speed of 24 kilometers per hour.



### 4.2.1.2 Impacts from Rail Shipments

Rail shipments were assumed to be made usi ng general freight; dedicated trains have not historically been used for UF 6 

### shipments. For rail shipments of UF 6 

### , radiation doses were estimated for workers and members of the public . Workers included worker s involved with the

classification of railcars at stops and workers involved in loading and unloading the UF 6 

### cylinders. For members of the pub lic, radiation doses were estimated for people along the route and people sharing the route (in other trains). The number of health effects from vehicle emissions, the number of traffic fatalities, and th e radiological accident risks were also estimated. The radiological and toxicological impacts of se vere transportation accidents are discussed in

Section 4.2.1.5.

Transportation impacts were estimated for en richment of NU, DU, and LEU feed to LEU product, for enrichment of DU feed to NU pr oduct, and for enrichment of DU feed to NUFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

69 

### product followed by subsequent enrichment of NU product to LEU product. Transportation impacts also include the tran sportation of LEU product to FF Fs. Impacts are presented for enriching the entire surplus DOE inventory, and for enrich ing the equivalent of 2,000 MTU of NU and enriching the equivalent of 4,000 MTU of NU in a given year.

The impacts from rail shipments of UF 6 

### are listed in Tables 4-10a , 4-10b, and 4-10c. Impacts are quantified in terms of total fatalities, which are the sum of radiati on-related LCFs, vehicle emission health effects, and tra ffic fatalities. For enrichment of NU, DU, and LEU feed to LEU product, the estimated number of total fatalities ranged from 0.20 to 2.4, depending on where the enrichment of the NU, DU, and LEU feed o ccurred and where the LEU product and DU tails were shipped. If 30B cylinders were used to transport LEU feed material instead of 48X cylinders, the impacts would also range from 0.20 to 2.4 total fatalities. The estimated number of fatalities from enriching the equivalent of 2,000 MTU of NU in a given year ranged from 0.0080 to 0.096, and the estimated number of fatalities from enriching the equivalent of 4,000 MTU of NU in a given year ranged from 0.017 to 0.20. For perspective, over the period 2002 to 2006, about 900 people were killed each year in railro ad accidents and incidents in the United States (DOT 2007).

For enrichment of DU feed to NU product, the estim ated number of total fatalities ranged from 0.16 to 1.8, depending on where the enrichment of the DU feed occurred and where the NU product and DU tails were shipped. The estimated number of fatalities from enriching the equivalent of 2,000 MTU of NU in a given ye ar ranged from 0.015 to 0.17, and the estimated

number of fatalities from en riching the equivalent of 4,000 MT U of NU in a given year ranged

from 0.027 to 0.30.

For enrichment of DU feed to NU product followe d by subsequent enrich ment of NU product to LEU product, enrichment at more than one enrichment facility could occur. The estimated number of total fatalities ranged from 0.17 to 2.6, depending on where the enrichment of the DU feed to NU product occurred, where the enrichme nt of the NU product to LEU product occurred, where DU tails were shipped, and where the LEU product was shipped. The estimated number of fatalities from enriching the equivalent of 2,000 MTU of NU in a given year ranged from 0.016 to 0.23, and the estimated number of fatalities from enriching the equivalent of 4,000 MTU of NU in a given year ranged from 0.029 to 0.43.

For enrichment at the Paducah GDP or the ACP, transportation impacts were lower if the NU, DU, or LEU feed were obtained on-site and the NU or LEU product were stored on-site, and the only impacts were for workers who loaded and unloaded cylinders for on-site movements. In addition, DU tails and NU product would not be shipped, resulting in lower transportation impacts.

For enrichment at the NEF, transportation impact s were slightly higher because the NU, DU, or LEU feed would be shipped from DOE Paducah or DOE Portsmouth to Eunice, New Mexico, and the DU tails would be dispositioned by the en richment facility or shipped back to DOE Paducah or DOE Portsmouth. In addition, NU produc t could be shipped back to Paducah or Portsmouth, resulting in highe r transportation impacts.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

70Table 4-10a. Total Transportation Impacts from Rail Shipments of Uranium Hexafluoride under the Proposed ActionCasePublic (LCFs) Worker (LCFs)Vehicle EmissionHealth Effects(LCFs)Radiological AccidentRisk (LCFs)Traffic Fatalities Total FatalitiesEnrichment to LEU at the Paducah GDPNU, DU, LEU feed2.1 × 10-33.5 × 10-21.3 × 10-21.1 × 10-11.3 × 10-12.8 × 10-1LEU product(on-site storage)-- 5.3 × 10-3------5.3 × 10-3LEU product if shippedto FFFsa1.2 × 10-3to 1.1 × 10-36.1 × 10-3to 7.1 × 10-33.0 × 10-3to 3.1 × 10-37.7 × 10-2to 8.2 × 10-22.5 × 10-2to 7.8 × 10-21.1 × 10-1to 1.7 × 10-1Total2.1 × 10-3to 3.2 × 10-34.0 × 10-2to 4.2 × 10-21.3 × 10-2to 1.6 × 10-21.1 × 10-1to 1.9 × 10-11.3 × 10-1to 2.0 × 10-12.9 × 10-1to 4.5 × 10-1Enrichment of DU to NU at the Paducah GDPDU feed1.6 × 10-32.8 × 10-21.0 × 10-27.6 × 10-21.0 × 10-12.2 × 10-1NU product(on-site storage)-- 8.0 × 10-3------8.0 × 10-3Total1.6 × 10-33.6 × 10-21.0 × 10-27.6 × 10-21.0 × 10-12.2 × 10-1Enrichment to LEU at the ACP (Portsmouth)NU, DU, LEU feed1.3 × 10-33.4 × 10-28.2 × 10-37.0 × 10-28.3 × 10-22.0 × 10-1LEU product(on-site storage)-- 5.3 × 10-3------5.3 × 10-3LEU product if shippedto FFFsa6.5 × 10-4to 1.5 × 10-36.0 × 10-3to 7.2 × 10-31.3 × 10-3to 4.9 × 10-32.9 × 10-2to 1.5 × 10-12.0 × 10-2to 8.1 × 10-25.7 × 10-2to 2.4 × 10-1Total1.3 × 10-3to 2.8 × 10-33.9 × 10-2to 4.1 × 10-28.2 × 10-3to 1.3 × 10-27.0 × 10-2to 2.2 × 10-18.3 × 10-2to 1.6 × 10-12.0 × 10-1to 4.4 × 10-1Enrichment of DU to NU atthe ACP (Portsmouth)DU feed1.1 × 10-32.7 × 10-26.7 × 10-35.1 × 10-26.8 × 10-21.5 × 10-1NU product(on-site storage)-- 8.0 × 10-3------8.0 × 10-3Total1.1 × 10-33.5 × 10-26.7 × 10-35.1 × 10-26.8 × 10-21.6 × 10-1Enrichment to LEU at the NEFNU, DU, LEU feed1.0 × 10-24.3 × 10-25.2 × 10-24.0 × 10-16.2 × 10-11.1LEU producta1.1 × 10-3to 1.7 × 10-36.4 × 10-3to 7.1 × 10-32.9 × 10-3to 6.7 × 10-37.7 × 10-2to 2.2 × 10-14.0 × 10-2to 7.8 × 10-21.3 × 10-1to 3.1 × 10-1DU tails (to Portsmouthor Paducah)6.3 × 10-3to 9.6 × 10-33.4 × 10-2to 3.6 × 10-23.0 × 10-2to 5.1 × 10-21.7 × 10-1to 3.0 × 10-14.1 × 10-1to 5.7 × 10-16.5 × 10-1to 9.7 × 10-1Total1.8 × 10-2to 2.1 × 10-28.4 × 10-2to 8.7 × 10-28.5 × 10-2to 1.1 × 10-16.4 × 10-1to 9.2 × 10-11.1 to 1.31.9 to 2.4Enrichment of DU to NU at the NEFDU feed8.2 × 10-33.5 × 10-24.2 × 10-22.9 × 10-15.0 × 10-18.8 × 10-1NU producta2.0 × 10-3to 3.0 × 10-31.1 × 10-2to 1.1 × 10-29.5 × 10-3to 1.6 × 10-29.1 × 10-2to 1.6 × 10-11.3 × 10-1to 1.8 × 10-12.4 × 10-1to 3.8 × 10-1DU tails (to Portsmouthor Paducah) 3.7 × 10-3to 5.7 × 10-32.0 × 10-2to 2.1 × 10-21.8 × 10-2to 3.0 × 10-29.8 × 10-2to 1.8 × 10-12.4 × 10-1to 3.4 × 10-13.8 × 10-1to 5.7 × 10-1Total1.4 × 10-2to 1.7 × 10-26.6 × 10-2to 6.8 × 10-26.9 × 10-2to 8.8 × 10-24.8 × 10-1to 6.3 × 10-18.7 × 10-1to 1.01.5 to 1.8Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEUTotal0.0011 to 0.0230.046 to 0.11 0.0067 to 0.120.051 to 0.970.068 to 1.40.17 to 2.6a. Range in product results is due to shipping product to various off-site storage locations.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

71Table 4-10b. Transportation Impacts from Rail Shipments of 2,000 MTU of Uranium Hexafluoride in a Given Year under the ProposedActionCasePublic (LCFs) Worker (LCFs)Vehicle EmissionHealth Effects(LCFs)Radiological AccidentRisk (LCFs)Traffic Fatalities Total FatalitiesEnrichment to LEU at the Paducah GDPNU, DU, LEU feed8.2 × 10-51.4 × 10-35.0 × 10-44.2 × 10-35.1 × 10-31.1 × 10-2LEU product(on-site storage)-- 2.1 × 10-4------2.1 × 10-4LEU product if shippedto FFFsa4.8 × 10-5to 4.6 × 10-52.5 × 10-4to 2.8 × 10-41.2 × 10-4to 1.2 × 10-43.1 × 10-3to 3.3 × 10-31.0 × 10-3to 3.1 × 10-34.5 × 10-3to 6.8 × 10-3Total8.2 × 10-5to 1.3 × 10-41.6 × 10-3to 1.7 × 10-35.0 × 10-4to 6.2 × 10-44.2 × 10-3to 7.5 × 10-35.1 × 10-3to 8.2 × 10-31.1 × 10-2to 1.8 × 10-2Enrichment of DU to NU at the Paducah GDPDU feed1.5 × 10-42.6 × 10-39.1 × 10-46.9 × 10-39.2 × 10-32.0 × 10-2NU product(on-site storage)-- 7.3 × 10-4------7.3 × 10-4Total1.5 × 10-43.3 × 10-39.1 × 10-46.9 × 10-39.2 × 10-32.0 × 10-2Enrichment to LEU at the ACP (Portsmouth)NU, DU, LEU feed5.4 × 10-51.3 × 10-33.3 × 10-42.8 × 10-33.3 × 10-37.8 × 10-3LEU product(on-site storage)-- 2.1 × 10-4------2.1 × 10-4LEU product if shippedto FFFsa2.6 × 10-5to 6.0 × 10-52.4 × 10-4to 2.9 × 10-45.4 × 10-5to 2.0 × 10-41.2 × 10-3to 5.9 × 10-38.0 × 10-4to 3.2 × 10-32.3 × 10-3to 9.7 × 10-3Total5.4 × 10-5to 1.1 × 10-41.6 × 10-3to 1.6 × 10-33.3 × 10-4to 5.3 × 10-42.8 × 10-3to 8.7 × 10-33.3 × 10-3to 6.6 × 10-38.0 × 10-3to 1.8 × 10-2Enrichment of DU to NU atthe ACP (Portsmouth)DU feed1.0 × 10-42.5 × 10-36.1 × 10-44.6 × 10-36.2 × 10-31.4 × 10-2NU product(on-site storage)-- 7.3 × 10-4------7.3 × 10-4Total1.0 × 10-43.2 × 10-36.1 × 10-44.6 × 10-36.2 × 10-31.5 × 10-2Enrichment to LEU at the NEFNU, DU, LEU feed4.1 × 10-41.7 × 10-32.1 × 10-31.6 × 10-22.5 × 10-24.5 × 10-2LEU producta4.6 × 10-5to 6.8 × 10-52.6 × 10-4to 2.8 × 10-41.2 × 10-4to 2.7 × 10-43.1 × 10-3to 8.6 × 10-31.6 × 10-3to 3.1 × 10-35.1 × 10-3to 1.2 × 10-2DU tails (to Portsmouthor Paducah) 2.5 × 10-4to 3.8 × 10-41.4 × 10-3to 1.5 × 10-31.2 × 10-3to 2.0 × 10-36.6 × 10-3to 1.2 × 10-21.6 × 10-2to 2.3 × 10-22.6 × 10-2to 3.9 × 10-2Total7.0 × 10-4to 8.6 × 10-43.4 × 10-3to 3.5 × 10-33.4 × 10-3to 4.4 × 10-32.6 × 10-2to 3.7 × 10-24.3 × 10-2to 5.1 × 10-27.6 × 10-2to 9.6 × 10-2Enrichment of DU to NU at the NEFDU feed7.4 × 10-43.2 × 10-33.8 × 10-32.6 × 10-24.6 × 10-28.0 × 10-2NU producta1.8 × 10-4to 2.8 × 10-49.8 × 10-4to 1.0 × 10-38.6 × 10-4to 1.5 × 10-38.3 × 10-3to 1.5 × 10-21.2 × 10-2to 1.6 × 10-22.2 × 10-2to 3.4 × 10-2DU tails (to Portsmouthor Paducah)3.4 × 10-4to 5.2 × 10-41.8 × 10-3to 1.9 × 10-31.6 × 10-3to 2.7 × 10-38.9 × 10-3to 1.6 × 10-22.2 × 10-2to 3.1 × 10-23.5 × 10-2to 5.2 × 10-2Total1.3 × 10-3to 1.5 × 10-36.0 × 10-3to 6.2 × 10-36.3 × 10-3to 8.0 × 10-34.4 × 10-2to 5.7 × 10-27.9 × 10-2to 9.3 × 10-21.4 × 10-1to 1.7 × 10-1Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEUTotal1.0 × 10-4to 2.1 × 10-34.2 × 10-3to 9.7 × 10-36.1 × 10-4to 1.1 × 10-24.6 × 10-3to 8.8 × 10-26.2 × 10-3to 1.2 × 10-11.6 × 10-2to 2.3 × 10-1a. Range in product results is due to shipping product to various off-site storage locations.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

72Table 4-10c. Transportation Impacts from Rail Shipments of 4,000 MTU of Uranium Hexafluoride in a Given Year under the ProposedActionCasePublic (LCFs) Worker (LCFs)Vehicle EmissionHealth Effects(LCFs)Radiological AccidentRisk (LCFs)Traffic Fatalities Total FatalitiesEnrichment to LEU at the Paducah GDPNU, DU, LEU feed1.7 × 10-42.9 × 10-31.0 × 10-38.8 × 10-31.1 × 10-22.3 × 10-2LEU product(on-site storage)0.0 4.4 × 10-40.00.00.04.4 × 10-4LEU product if shippedto FFFsa1.0 × 10-4to 9.5 × 10-55.1 × 10-4to 5.9 × 10-42.5 × 10-4to 2.5 × 10-46.5 × 10-3to 6.8 × 10-32.1 × 10-3to 6.5 × 10-39.4 × 10-3to 1.4 × 10-2Total1.7 × 10-4to 2.7 × 10-43.4 × 10-3to 3.5 × 10-31.0 × 10-3to 1.3 × 10-38.8 × 10-3to 1.6 × 10-21.1 × 10-2to 1.7 × 10-22.4 × 10-2to 3.8 × 10-2Enrichment of DU to NU at the Paducah GDPDU feed2.7 × 10-44.7 × 10-31.7 × 10-31.3 × 10-21.7 × 10-23.6 × 10-2NU product(on-site storage)-- 1.3 × 10-3------1.3 × 10-3Total2.7 × 10-46.0 × 10-31.7 × 10-31.3 × 10-21.7 × 10-23.7 × 10-2Enrichment to LEU at the ACP (Portsmouth)NU, DU, LEU feed1.1 × 10-42.8 × 10-36.9 × 10-45.8 × 10-36.9 × 10-31.6 × 10-2LEU product(on-site storage)0.0 4.4 × 10-40.00.00.04.4 × 10-4LEU product if shippedto FFFsa5.5 × 10-5to 1.2 × 10-45.0 × 10-4to 6.0 × 10-41.1 × 10-4to 4.1 × 10-42.4 × 10-3to 1.2 × 10-21.7 × 10-3to 6.8 × 10-34.8 × 10-3to 2.0 × 10-2Total1.1 × 10-4to 2.4 × 10-43.2 × 10-3to 3.4 × 10-36.9 × 10-4to 1.1 × 10-35.8 × 10-3to 1.8 × 10-26.9 × 10-3to 1.4 × 10-21.7 × 10-2to 3.7 × 10-2Enrichment of DU to NU atthe ACP (Portsmouth)DU feed1.8 × 10-44.5 × 10-31.1 × 10-38.5 × 10-31.1 × 10-22.6 × 10-2NU product(on-site storage)-- 1.3 × 10-3------1.3 × 10-3Total1.8 × 10-45.9 × 10-31.1 × 10-38.5 × 10-31.1 × 10-22.7 × 10-2Enrichment to LEU at the NEFNU, DU, LEU feed8.4 × 10-43.6 × 10-34.3 × 10-33.4 × 10-25.2 × 10-29.4 × 10-2LEU producta9.5 × 10-5to 1.4 × 10-45.3 × 10-4to 5.9 × 10-42.4 × 10-4to 5.6 × 10-46.4 × 10-3to 1.8 × 10-23.3 × 10-3to 6.5 × 10-31.1 × 10-2to 2.6 × 10-2DU tails (to Portsmouthor Paducah)5.2 × 10-4to 8.0 × 10-42.8 × 10-3to 3.0 × 10-32.5 × 10-3to 4.2 × 10-31.4 × 10-2to 2.5 × 10-23.4 × 10-2to 4.8 × 10-25.4 × 10-2to 8.1 × 10-2Total1.5 × 10-3to 1.8 × 10-37.0 × 10-3to 7.2 × 10-37.1 × 10-3to 9.1 × 10-35.4 × 10-2to 7.6 × 10-28.9 × 10-2to 1.1 × 10-11.6 × 10-1to 2.0 × 10-1Enrichment of DU to NU at the NEFDU feed1.4 × 10-35.8 × 10-37.0 × 10-34.8 × 10-28.3 × 10-21.5 × 10-1NU producta3.3 × 10-4to 5.1 × 10-41.8 × 10-3to 1.9 × 10-31.6 × 10-3to 2.7 × 10-31.5 × 10-2to 2.7 × 10-22.2 × 10-2to 3.0 × 10-24.0 × 10-2to 6.3 × 10-2DU tails (to Portsmouthor Paducah)6.2 × 10-4to 9.5 × 10-43.4 × 10-3to 3.6 × 10-33.0 × 10-3to 5.0 × 10-31.6 × 10-2to 2.9 × 10-24.0 × 10-2to 5.6 × 10-26.4 × 10-2to 9.5 × 10-2Total2.3 × 10-3to 2.8 × 10-31.1 × 10-2to 1.1 × 10-21.2 × 10-2to 1.5 × 10-28.0 × 10-2to 1.1 × 10-11.5 × 10-1to 1.7 × 10-12.5 × 10-1to 3.0 × 10-1Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEUTotal1.8 × 10-4to 3.8 × 10-37.7 × 10-3to 1.8 × 10-21.1 × 10-3to 2.0 × 10-28.5 × 10-3to 1.6 × 10-11.1 × 10-2to 2.3 × 10-12.9 × 10-2to 4.3 × 10-1a. Range in product results is due to shipping product to various off-site storage locations.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

73 

### Table 4-11 lists the impacts for the MEI along the transportation route. This individual was assumed to be located 30 meters (100 feet) from the route and to be exposed to all shipments of

UF 6 

### (i.e., NU feed, NU product, DU feed, DU tails, LEU feed, and LEU product). The shipments were assumed to travel at a speed of 24 kilomete rs (15 miles) per hour, which is representative of speeds in urban areas. The probability of an LCF for the MEI along the transportation route was estimated to range from 8.2 × 10 -8 

### to 5.2 × 10 -7 

### over 25 years.

Table 4-11. Maximum Individual Impacts from Rail Shipments a

Case Mode LCFs

Enrichment to LEU at Paducah GDP Rail 1.9 × 10 -7

Enrichment of DU to NU at Paducah GDP Rail 1.2 × 10 -7

Enrichment to LEU at Portsmouth ACP Rail 1.4 × 10 -7

Enrichment of DU to NU at Portsmouth ACP Rail 8.2 × 10 -8

Enrichment to LEU at NEF Rail 5.0 × 10 -7

Enrichment of DU to NU at NEF Rail 3.9 × 10 -7

Enrichment of DU to NU followed by subsequent

enrichment of NU to LEU Rail 1.0 × 10 -7 to 5.2 × 10 -7

a. Impacts are based on a person located 30 meters from the railroad. The person was assumed to be exposed to all shipments

of UF 6 . The shipments were assumed to travel at a speed of 24 kilometers per hour.



### 4.2.1.3 Impacts from Overseas Shipments

DOE (1999a) evaluated the impacts of shipping 135,000 MTU of NU as UF 6 

### from the

Portsmouth and Paducah GDPs to the Russian Fe deration. In addition, DOE (1994) evaluated the impacts of shipping 15,250 MTU of LEU as UF 6 

### from the Russian Federation to the Portsmouth

and Paducah GDPs. The total amount of UF 6 

### evaluated in the Proposed Action, would be
99,810 MTU 23 

### , assuming that the DU tail s would not be shipped back to the United States, which is the standard industry practice.

Based on these analyses and using the Port of H ouston, Texas, as an example, it was estimated that there would be 2.8 transportation-related fatalities from shipping 135,000 MTU of NU from

the United States to the Russian Federation a nd 0.054 transportation-rela ted fatalities from shipping 15,250 MTU of LEU from the Russian Fe deration to the United States. These impacts included sea transit, port operati ons, and overland truck transport 24 

### and were estimated to result in 2.9 total fatalities. In addition, based on the radiological and nonr adiological impacts presented in DOE (1999a) and DOE (1994), the imp acts of using New Orleans or other ports would be similar to the impacts of using the Port of Houston, Texas. The impacts of transporting

DU tails were not included in the above analyses.

23 The 99,810 MTU consists of 17,595 MTU of NU feed, 75,296 MTU of DU feed, 2,000 MTU of LEU feed, and 4,919 MTU of LEU product. Only the LEU product would be shipped back to the United States. If DU feed were enriched to NU product, the amount of UF 6 shipped would be slightly less, about 98,000 MTU (75,296 MTU of DU feed, and 22,213 MTU of NU product), and only the NU product would be shipped back to the United States.

24 These impacts have been updated to use the current dose-to-health effects conversion factor of 0.0006 LCFs per person-rem (Lawrence 2002).Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

74 

### Shipping NU, LEU, or DU from the United States to the Tricastin nuclear complex, and shipping NU or LEU product from the Tricastin nuclear complex to the United States, would involve activities similar to those associated with ship ping NU from the United States to the Russian

Federation and LEU from the Russian Federation to the United States.

Based on the analyses presented in DOE (1999a) and DOE (1994), there would be an estimated 2 fatalities from shipping 99,810 MTU of NU fee d, DU feed, and LEU feed to the Tricastin nuclear complex, and NU or LEU product back to the United States. These impacts were based on shipping UF 6 

### to DOE’s Portsmouth or Paducah facilities. If the UF 6 

### were subsequently shipped to an FFF, it is estimated that the numbe r of fatalities would in crease slightly, from

about 2.0 fatalities to about 2.2 fatalities. If the UF 6 

### were shipped directly to an FFF instead of having an intermediate stop at the Portsmouth or Paducah GDPs, the impacts would likely be less because the total shippi ng distance would be less.

If barges were used to trans port the uranium to the Port of New Orleans for shipment to the Tricastin nuclear complex for enrichment, and fr om the Port of New Orleans to Portsmouth or

Paducah after enrichment at the Tricastin nucle ar complex, the number of barge shipments would be less than the number of truck shipments (see Table 4-6). In addition, the exposed population using barge routes would be less than the expos ed population using truck routes (Table 4-12). Therefore, the impacts of transporting the uran ium by barge would be less than the impacts of transporting the uranium by truck. Because the impacts of shipping by barge were lower than the impacts of shipping by truck, the impacts of shipping by barge were not quantified.

Table 4-12. Assumed Exposed Populations along Barge and Truck Routes

Route Assumed Exposed Population from Barge Route Assumed Exposed Population from

Truck Route

Paducah to New Orleans 53,000 240,000

Portsmouth to New Orleans 150,000 340,000



### 4.2.1.4 Global Commons

Shipments of UF 6 

### to the Tricastin nuclear complex requi re that impacts on the global commons be assessed. In accordance with DOE’s implementation guidance for Executive Order 12114 (46 FR 1007), DOE (1994) analyzed impacts on the global commons of shipping 15,250 MTU of

LEU as UF 6 

### from the Russian Federation to the Portsmouth and Paducah GDPs. DOE (1999a) also analyzed the impacts on global co mmons of shipping 135,000 MTU of NU as UF 6 

### from the

Portsmouth and Paducah GDPs to the Russian Federation. Informal consultation with the

National Marine Fisherie s Service indicated that, under normal transport conditions, shipment of LEU by commercial vessel would be indistinguisha ble from any other commercial shipment and that there would be no impact on the marine envi ronment, since marine flora and fauna would not be exposed to UF 6



### .

The North Atlantic right whale ( Eubalaena glacialis ) is on the federal endangered species list and is also protected internat ionally under the Convention for the Regulation of Whaling. ThereFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

75 

### are currently about 300 right whales in the North Atlantic, with sh ip strikes accounting for about 50 percent of their known deaths. Calving right wh ales usually winter in the waters between Savannah, Georgia, and West Pa lm Beach, Florida, with an area of high density between Brunswick, Georgia, and St. Augustine, Florida (DOE 2008a). The Maritime Safety Committee

of the International Ma ritime Organization adopted a mandatory ship-reporting system that took effect in 1999. Under this system, ships off the southeastern coast of the United States are required to report whale sightings in the major shipping lanes from November 15 to April 15, so as to include the calving season for the right whal es in this area, and ships off the northeastern coast, where the whales have been sighted year-round, are required to report sightings throughout the year. In addition, the National Marine Fisheries Service has established regulations to implement speed restrictions of no more than 10 knots applying to all vessels 65 feet (19.8 meters) or greater in overall length in cer tain locations and at certain times of the year along the east coast of the U.S. Atlantic se aboard. The purpose of the regulations is to

reduce the likelihood of deaths and serious injuries to endangered North Atlantic right whales that result from collisions with ships (73 FR 60173).

The sperm whale and all six specie s of sea turtles are on the federal endangered species list and are found throughout the central and northern Paci fic Ocean and the equatorial region of the Atlantic Ocean. Sperm whales migrate between mating and calving grounds near the equator and feeding areas in higher latitudes. Generally, how ever, females and their young stay in latitudes less than 40, and only the males ve nture into the polar waters. The total number of sperm whales in the world is not well known, with estimat es ranging from 200,000 to 2 million. The sea turtle is found throughout the Atlantic Ocean and the Paci fic Ocean but is usually vulnerable to harm only on coastal shores. In the United States, the s ea turtle is most prevalent on and just off the central Florida coast. Endangered marine speci es in the Pacific Ocean also include the dugong, sea lion, sea otter, and seals (DOE 2008a).

It is also extremely unlikely, if not impossible, that the proposed shipments would present any significant risk from an accident to the marine environment, as discussed in the following paragraphs. In 1984, the French cargo ship Mont-Loui s sank after collidi ng with a ferry. The cargo included thirty (30) Type 48Y cylinders of UF 6 

### . In view of the nature of the cargo, particularly its value, it was decided to salvage the UF 6 

### cylinders as quickly as possible and to

recover the material. All 30 containers were reco vered. They were all in tact except one, which had a slight leak in the valve.

Moreover, there is no significant risk to the mari ne environment even in the event that one or more cylinders were lost at sea and not retrie ved. The oceans contain si gnificant quantities of uranium and its daughter products due to naturally occurring processes. As a result, marine organisms are exposed to relatively high levels of background radiation. The cylinders that

contain the UF 6 

### are designed, constructed, and tested to withstand a severe collision, so unretrieved cylinders lost as the result of an accident at sea are likel y to remain intact.

Because uranium has not been found to bioamplify in fish (and only slightly in other marine organisms) in the marine environment, even in the extremely unlikely event that a cylinder failed, an accidental release woul d result in only slight increa ses in the exposure of marineFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

76 

### organisms, which tend to be more radiation-re sistant than terrestrial mammals and which are already exposed to similar c oncentrations of uranium.

As a result of the large volume of water, the mixing mechanisms w ithin it, the background concentrations of uranium, and the radiation resistance of aquatic orga nisms, the radiological impact of the very low probability accident rel easing uranium into the ocean would be localized and of short duration. Also, any cylinders accidentally lost in the ocean or coastal waters would be retrieved, if at all possible, because of the economic value of the UF 6 

### . This would practically eliminate the possibility of multiple containers sl owly corroding and releasing their contents over time. Even if a cylinder were not retrievable, th e impact of a slow release would be even less severe than a catastrophic failure of a cylinder.

The second aspect of a marine acci dent is the chemical hazard. UF 6 

### reacts with water in an

exothermic reaction that re leases uranyl fluoride (UO 2 

### F 2 

### ) and HF. The reaction is not explosive. The HF produced would dissolve very quickly in the sea water. When dissolved, the HF

dissociates into H + 

### and F - 

### ions. These ions and the UO 2 

### F 2 

### are the toxicological agents responsible for physiologic effect s from a potential release of UF 6 

### in ocean water. If an instantaneous, complete hydrolysis of the cont ents of a single cylinde r is assumed, the peak

concentrations of H + 

### and F - 

### ions from a total release of UF 6 

### from a container would be approximately 2 micrograms per liter at a distan ce of 100 meters. These concentrations are

below toxic levels. The UO 2 

### F 2 

### formed would settle on the se a bed and slowly dissolve.

4.2.1.5 Consequences of Severe Transportation Accidents

DOE estimated that the radiological risks of transportation accident s for truck shipments (probability of occurrence × consequence summ ed over a complete spectrum of accidents, including the severe accidents) ranged from 0.042 to 0.96 LCFs ove r 25 years (see Table 4-8a). For rail shipments, DOE estimated that the radiological risks of tr ansportation accidents (probability of occurrence × consequence summ ed over a complete spectrum of accidents, including the severe accidents) ranged from 0.051 to 0.97 LCFs over 25 years (see Table 4-10a).

DOE (2004a, 2004b) evaluated the radi ological consequences of a severe transportation accident involving DUF 6 

### . These accidents are characterized by extreme mechanical and thermal forces, and accidents of this severity w ould be expected to be extrem ely rare (Biwer et al. 2001). Because DOE postulated a hypothetical accident that could occur at any location, the results are not route-dependent. DOE evaluate d the radiological consequences to people in rural areas (6 persons per square kilometer [15 persons per square mile]), suburban areas (719 persons per square kilometer [1,798 persons per square mile]), and urban ar eas (1,600 persons per square kilometer [4,000 persons per square mile]). Ra diation doses were estimated under neutral atmospheric conditions (Stability Class D with a wind speed of 14 kilometers [9 miles] per hour) and stable atmospheric conditions (Stability Class F with a wind speed of 3.5 kilometers [2.2 miles] per hour).Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

77 

### Tables 4-13 and 4-14 list the radi ological consequences of these severe transportation accidents based on the radionuclide inventories presented in Table 4-7. For a severe truck accident involving one cylinder of DUF 6 

### , the population radiation dose c ould be as high as 32,000 personrem in an urban area if stable atmospheric condi tions existed at the time of the accident. Based on this population radiation dose, it was estimated that there could be 20 LCFs in the assumed exposed population of about 3 million people. The radiation dose for the MEI was estimated to be as high as 0.91 rem if stable atmospheric c onditions existed at the time of the accident. The probability of an LCF for this individual was estimated to be 0.0005. The probability of this accident ranged from 8.1 × 10 -4 

### to 0.016 over 25 years.

Table 4-13. Radiological Consequences for th e Population from Severe Transportation Accidents Involving Depleted Uranium Hexafluoride a

Neutral Atmospheric Conditions St able Atmospheric Conditions

Mode Rural b Suburban Urban c Rural b Suburban Urban c

Radiological Dose (person-rem)

Truck 590 580 1,300 15,000 15,000 32,000

Rail 2,400 2,300 5,200 60,000 58,000 130,000
Radiological Risk (LCF) d

Truck 0.4 0.3 0.8 9 9 20

Rail 1 1 3 40 30 80

Source: DOE (2004a, 2004b). a. National average population densities were used for the accident consequence assessment, corresponding to densities of 6 persons per square kilometer for rural zones, 719 persons per square kilomete r for suburban zones, and 1,600 persons per square kilometer for urban zones. Po tential impacts were estimated for the population within a 50-mile (80-kilometer) radius, assuming a uniform population density for each zone. b. The consequences in rural areas equal or exceed the cons equences in suburban areas beca use the consequences in rural

areas include the radiation dose from the ingestion of contaminated food stuffs. The consequences in suburban and urban

areas do not include the radia tion dose from the ingestion of contaminated food stuffs. c. It is important to note that the urba n population density generally applies to rela tively small urbanized area—very few, if any, urban areas have a population density as high as 1,600 pe rsons per square kilometer exte nding as far as 50 miles. That urban population density corresponds to approximately 32 million people within the 50-mile radius, well in excess of the total populations along the rout es considered in this assessment. d. LCFs are calculated by multiplying th e radiation dose by the health risk conversion factor of 0.0006 fatal cancers per person-rem (Lawrence 2002).



### Table 4-14. Radiological Consequences for the M 

### aximally Exposed Individual from Severe Transportation Accidents Involving Depleted Uranium Hexafluoride
Neutral Atmospheric Conditions St able Atmospheric Conditions Mode Dose (rem) Probability of LCF a Dose (rem) Probability of LCF a

Truck 0.43 0.0003 0.91 0.0005

Rail 1.7 0.001 3.7 0.002

Source: DOE (2004a, 2004b). a. LCFs are calculated by multiplying the radiation dose by the health risk conversion factor of 0.0006 fatal cancers per person-rem (Lawrence 2002).Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

78 

### If the severe transportation accident involved NU f eed or product, the radiological consequences would be higher—about 28 LCFs in the assu med exposed population. For the MEI, the probability of an LCF would be 0.0008.

If the severe transportation acci dent involved LEU product, the radiological consequences would also be higher—about 75 to 125 LCFs in th e assumed exposed population, assuming that all three to five 30B cylinders, resp ectively, in a truck shipment we re breached during the severe accident. For the MEI, the probability of an LCF would be 0.002 or 0.0036 if three or five 30B cylinders, respectively, were brea ched during the severe accident. If three 30B cylinders were involved in the accident, the probability of the accident would range from 2.2 × 10 -4 

### to 9 × 10 -4


### over 25 years for those cases where LEU is shipped. If five 30B cylinders were involved in the accident, the probability would range from 1.3 × 10 -4 

### to 5.4 × 10 -4 

### over 25 years for those cases were LEU is shipped. However, for several cases , LEU would not be shipped and the probability

of this accident would be zero. In addition, the probability associat ed with this accident does not incorporate the effects of the protective ove rpack surrounding the 30B cylinders, which would reduce the probability of the accident to a range of 4.4 × 10 -5 

### to 1.8 × 10 -4 

### over 25 years if three 30B cylinders were involved or a range of 2.7 × 10 -5 

### to 1.1 × 10 -4 

### over 25 years if five 30B cylinders were involved.

For a severe rail accident i nvolving four cylinders of DUF 6 

### , the population radiation dose could be as high as 130,000 person-rem in an urban area when stable atmospheric conditions exist at the time of the accident. Based on this populatio n radiation dose, it was estimated that there could be 80 LCFs in the assumed exposed populati on of 3 million people. The radiation dose for the MEI was estimated to be as high as 3.7 rem if stable atmospheric conditions existed at the time of the accident. The probability of an LCF for this individual was estimated to be 0.002. The probability of this accident ranged from 2.4 × 10 -4 

### to 0.003 over 25 years.

If the severe rail transpor tation accident involved NU feed or product, the radiological consequences would be higher—about 110 LCFs in the assumed exposed population. For the MEI, the probability of an LCF would be 0.003. Th e probability of this accident ranged from 4.4

× 10 -5 

### to 0.0011 over 25 years for those cases where NU is shipped. However, for several cases, NU would not be shipped and the probability of this accident would be zero.

If the severe transportation acci dent involved LEU product, the radiological consequences would also be higher—about 310 LCFs in the assume d exposed population, assu ming that all twelve 30B cylinders in a rail shipment were breached during the severe accident. For the MEI, the probability of an LCF would be 0.009. The proba bility of this accident ranged from 4.3 × 10 -5 

### to
2.6 × 10 -4 

### over 25 years for those cases where LEU is shipped. However, for several cases, LEU would not be shipped and the pr obability of this accident w ould be zero. In addition, the probability associated with this accident does not incorporate the effects of the protective overpack surrounding the 30B cylinders, which woul d reduce the probability of the accident to a range of 4.3 × 10 -6 

### to 2.6 × 10 -5 

### over 25 years.

For both the truck and rail severe transportation accidents, the accidents were assumed to take place in an urban area with a population density of 1,600 people per square kilometer. Potential consequences were estimated fo r the population within a 50-mile (80-km) radius, assuming thatFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

79 

### this population density extended out to 50 miles (80- km). It is important to note that according to the 2000 census, the average population density w ithin 50 miles of the center of the 20 highest population urbanized areas in the U.S. is about 380 people per square kilometer, so the consequences would likely be lower if a severe truc k or rail accident took pl ace in an urban area. In addition, the severe accidents were assu med to take place during stable atmospheric conditions. As illustrated in Table 4-13, if the accidents took place during neutral atmospheric conditions, the consequences woul d be substantially lower. For example, if the severe truck accident involving LEU product occurred dur ing neutral atmospheric conditions, the consequences would range from 3 to 5 LCFs, s ubstantially lower than 75 to 125 LCFs. If the

severe rail accident involvi ng LEU product occurred during neut ral atmospheric conditions, the consequences would be about 12 LCFs , substantially lower than 310 LCFs.

DOE (2004a, 2004b) evaluated the chemical conse quences of a transportation accident involving

DUF 6 

### . If UF 6 

### is released to the atmosphere, it reacts with water vapor in the air to form HF and

UO 2 

### F 2 

### , independent of the enrichment of the UF 6 

### (i.e., natural, enriched, or depleted). The products are chemically toxic to humans. HF is extremely corrosive; it can damage the lungs and cause death if inhaled at high e nough concentrations. In addition, uranium is a heavy metal that, in addition to being radioactive, can have toxic ch emical effects (primarily on the kidneys) if it enters the body by way of i ngestion and/or inhalation.

Because DOE postulated a hypothetical accident that could occur at any location, the results are not route-dependent. DOE evaluated chemical im pacts to rural areas (6 persons per square kilometer [15 persons per square mile]), subur ban areas (719 persons per square kilometer [1,798 persons per square mile]), and urban areas (1,600 persons per square kilometer [4,000 persons per square mile]). Chemical impa cts are not dependent on enrichment of the uranium, only on the amount of uranium in the container. For this r eason, if the severe transportation accident involved NU or enriched ur anium, the chemical consequences would be

similar.

The toxic effects, or chemical impacts, can be categorized as adve rse health effects or

irreversible adverse health effects. An adverse he alth effect includes respir atory irritation or skin

rash associated with lower chemical concentrat ions. An irreversible adverse health effect generally occurs at higher chemi cal concentrations and is perm anent in nature. Irreversible

adverse health effects include de ath, impaired organ function (such as central nervous system or lung damage), and other effects that may impair daily functions. Of those individuals receiving

an irreversible adverse health effect, approximately 1 percen t or less would die from it.

Tables 4-15 and 4-16 list the chemical consequen ces of these severe tr ansportation accidents.

Severe rail accidents could have higher consequences than truck accidents because each railcar would carry four times as many cylinders relative to a truck. The consequences of such an accident were estimated on the basis of the assumption that the accident occurred in an urban area under stable atmospheric conditi ons (such as at night-time) when there is less dispersion of released material than during neutral atmospheric conditions. In such a case, it was estimated thatFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

80 

### Table 4-15. Chemical Consequences for the Popul ation from Severe Transportation Accidents Involving Depleted Uranium Hexafluoride a

Neutral Atmospheric Conditions St able Atmospheric Conditions Mode Rural Suburban Urban b Rural Suburban Urban b

Number of People with the Pote ntial for Adverse Health Effects

Truck 0 2 4 6 760 1,700

Rail 4 420 940 110 13,000 28,000
Number of People with the Potential for Irreversible Health Effects c

Truck 0 1 2 0 1 3

Rail 0 1 3 0 2 4

Source: DOE (2004a, 2004b). a. National average population densities were used for the accident consequence assessment, corresponding to densities of 6 persons per square kilometer for rural zones, 719 persons per square kilometer for suburban zones, and 1,600 persons per square kilometer for urban zones. Pote ntial impacts were estimated for the popu lation within a 50-mile (80-kilometer) radius, assuming a uniform population density for each zone. b. It is important to note that the urba n population density generally applies to rela tively small urbanized area— very few, if any, urban areas have a population density as high as 1,600 pers ons per square kilometer extendi ng as far as 50 miles. That urban population density corresponds to approximately 32 million people within the 50-mile radius, well in excess of the total populations along the routes considered in this assessment. c. Exposure to HF or uranium compounds is estimated to result in fatality to approx imately 1 percent or less of those persons experiencing irreversible adverse effects.



### Table 4-16. Chemical Consequences for the M 

### aximally Exposed Individual from Severe Transportation Accidents Involving Depleted Uranium Hexafluoride
Neutral Atmospheric Conditions St able Atmospheric Conditions

Mode Adverse Effects Irreversible

Adverse Effects a Adverse Effects Irreversible

Adverse Effects a

Truck Yes Yes Yes Yes

Rail Yes Yes Yes Yes

Source: DOE (2004a, 2004b). a. Exposure to HF or uranium compounds is estimated to result in fatality to approx imately 1 percent or less of those persons experiencing irreversible adverse effects.



### approximately four persons might experience irreve rsible adverse effects (such as lung or kidney damage) from exposure to HF and uranium. The nu mber of fatalities expected following an HF or uranium chemical exposure is expected to be somewhat less than 1 percent of those persons experiencing irreversible adverse effects. Thus, no fatalities would be expected (1 percent of 4).

4.2.1.6 Intentional Destructive Acts

DOE (1999a) evaluated the consequences of inte ntional destruc tive acts (sabotage, terrorism) involving the transport of NU. Three scenarios were evaluated: (1) exploding a bomb near a shipping cylinder (2) attacking a cylinder with a high-energy dens ity device such as an armorpiercing weapon (i.e., an anti-tank weapon), and (3) hi jacking (stealing) a shipping cylinder. DOE (1999a) concluded that the consequences of an intentional destruc tive act would be less than or similar to the consequences of severe transportation accident s for a given number of cylinders with similar contents.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

81 

### According to U.S. Department of Transportatio n regulations (49 CFR Pa rt 172), shipments of uranium hexafluoride would require a security pl an. This security plan must include an assessment of possible transportation security risks and appropriate measures to address the assessed risks. At a minimum, a security plan must include the following elements:

• Personnel security. Measures to confirm info rmation provided by job applicants hired for
positions that involve access to and handling of the hazardous materials covered by the
security plan.

• Unauthorized access. Measures to address th e possibility that unauthorized persons may
gain access to the hazardous materials covere d by the security pl an or to transport conveyances being prepared fo r transportation of the hazardous materials covered by the
security plan.

• En route security. Measures to address the security risks of shipments of hazardous
materials covered by the security plan en r oute from origin to de stination, including
shipments stored incidental to movement.

Although it is not possible to predict the proba bility of an inten tional destructive act, implementation of these requirements is judge d to make these occu rrences very unlikely. Although judged very unlikely to actually occur, the consequences of intentional destructive acts would be similar to the consequences discusse d above for severe truc k and rail accidents involving DU, NU, and LEU.

4.2.2 Low-Enriched Uranium Storage Impa cts under the Enrichment Alternative

In the two EISs analyzing constr uction and operation of proposed UF 6 

### conversion facilities at DOE Paducah (DOE 2004a) and DOE Portsmouth (DOE 2004b), DOE evaluated the continued storage of DU, NU, and LEU cylinders as part of the no action alternativ es. At Paducah, a total of 44,077 cylinders (41,013 DUF 6 

### cylinders, 2,769 non-DUF 6 

### cylinders, and 295 empty cylinders) were evaluated. At Portsm outh, a total of 25,231 cylinders (20,931 DUF 6 

### cylinders, 3,795 non-DUF 6 

### cylinders, and 505 empty cylinders) were evaluated. As a result of enrichment activities analyzed in this EA, if DU feed, NU feed, and LEU feed were enriched to LEU product, the number of DU cylinders woul d increase slightly, from 10,776 to 10,931. The number of LEU cylinders would increase from 296 to 3,195, and the number of NU cylinders would decrease from 2,270 to 0. The total numbe r of cylinders would increase from 13,342 to 14,126. These numbers of cylinders are well within the numbers of cylinders evaluated in the two EISs analyzing constructi on and operation of proposed UF 6 

### conversion facilities at DOE Paducah (DOE 2004a) and DOE Portsmouth (DOE 2004b). 25

25 The Portsmouth and Paducah conversion facility EISs eval uated a total of 2,507 cylinders of LEU and a total of 2,955 cylinders of NU located at Portsmouth, Paducah, an d the ETTP. Not all these cylinders are included in the Proposed Action evaluated in this EA. Numerous sales transactions have occurred since publication of the conversion facility EISs in 2004. Upda ted cylinder counts will differ from those presented in earlier documents due

to these transactions.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

82 

### If DU feed were enriched to NU product, the nu mber of DU cylinders would decrease from 10,776 to 6,450. The number of NU cylinders w ould increase from 2,270 to 5,715, and the number of LEU cylinders would be unchanged. Th e total number of cylinders would decrease from 13,342 to 12,461. If DU feed were enrich ed to NU product followed by subsequent enrichment of this NU product to LEU product, the number of DU cylinders would decrease from 10,776 to 8,859. The number of NU feed cyli nders would decrease from 5,715 to 0, and the number of LEU cylinders would increase from 296 to 1,849. The total number of cylinders would decrease from 13,342 to 12,978. These numbers of cylinders are well within the numbers of cylinders evaluated in th e two EISs analyzing construc tion and operation of proposed UF 6 

### conversion facilities at DOE Paducah ( DOE 2004a) and DOE Portsmouth (DOE 2004b).

In the conversion facility EIS for the Portsmout h site, the average work er individual radiation dose was estimated to be about 600 mrem per year , which is equivalent to an LCF risk of 0.00036. For a worker engaged in cylinder maintena nce activities for 40 years (the duration of

the no action alternative ev aluated in DOE [2004b]), the risk of an LCF is estimated to be 0.014.

The collective radiation dose for workers conduc ting cylinder maintenance activities at the Portsmouth site was estimated to be 460 person-rem over the time period 1999 through 2039. In the exposed population of workers, this collectiv e radiation dose is es timated to result in

0.28 LCFs.

In the conversion facility EIS for the Portsmout h site, the maximum individual radiation dose to a person near the Portsmouth site boundary was estimated to be less than 0.1 mrem per year, which is equivalent to an LCF risk of 6.0 × 10 -8 

### . Over 40 years, this would be equivalent to an

LCF risk of 2.4 × 10 -6 

### . The collective radiation dose for people around the Portsmouth site was estimated to be 0.07 person-rem over the time period 1999 through 2039. In the exposed population, this collective radiation do se is estimated to result in 4.2 × 10 -5 

### LCFs.

Accidents involving cylinders we re also evaluated in the conversion facility EIS for the

Portsmouth site. The accident with the highest consequences was a fi re resulting in the rupture of three 48G cylinders containing DUF 6 

### . The radiation dose for an individual member of the public

from this accident was estimated to be 0.013 re m, which is equivalent to an LCF risk of

7.8 × 10 -6 

### . For the exposed population, the collective radiation dose from this accident was estimated to be 34 person-rem, which is equiva lent to 0.020 LCFs in the exposed population. If

this accident occurred at othe r sites, the results would vary depending on the amount of material involved in the accident; the enrichment of the UF 6 

### ; the release fractions, aerosolized fractions, and respirable fractions; release assumptions such as whether the release was elevated or from ground level; the number of people exposed; atmo spheric conditions; and radiation dosimetry assumptions.

If the accident involved NU, th e radiological consequences would be higher—about 0.030 LCFs in the exposed population, assuming that three cylinders were invol ved in the accident. For the MEI, the probability of an LCF would be 1.1 × 10 -5 

### . If the accident involved LEU, the radiological consequences woul d also be higher—about 0.055 LCFs in the exposed population, assuming that three cylinders were involved in the accident. For the MEI, the probability of an

LCF would be 2.1 × 10 -5



### .Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

83 

### In the conversion facility EIS for the Paducah si te, the average individual worker radiation dose was estimated to be 740 mrem per year, which is equivalent to an LCF risk of 0.00044. For a worker engaged in cylinder maintenance activities for 40 years (the duration of the no action alternative evaluated in DOE [2004a]), the risk of an LCF is estimated to be 0.018. The

collective radiation dose for workers conducting cylinder mainte nance activities at the Paducah site was estimated to be 1,300 person-rem over the time period 1999 through 2039. In the exposed population of workers, th is collective radiation dose is estimated to result in 0.78 LCFs.

In the conversion facility EIS for the Paducah si te, the maximum individu al radiation dose to a person near the Paducah site boundary was estimated to be less than 0.1 mrem per year, which is equivalent to an LCF risk of 6.0 × 10 -8 

### . Over 40 years, this would be equivalent to an LCF risk of

2.4 × 10 -6 

### . The collective radiation dose for people around the Paducah site was estimated to be 0.3 person-rem over the time period 1999 throug h 2039. In the exposed population, this

collective radiation dose is estimated to result in 1.8 × 10 -4 

### LCFs.

Accidents involving cylinders were also evaluated in the conversion facility EIS for the Paducah site. The accident with the highe st consequences was a fire re sulting in the rupture of three 48G cylinders containing DUF 6 

### . The radiation dose for an individual member of the public from this accident was estimated to be 0.015 rem, which is equivalent to an LCF risk of 9.0 × 10 -6 

### . For the exposed population, the collective radiation do se from this accident was estimated to be 29 person-rem, which is equivalent to 0.017 LCFs in the exposed populati on. If this accident occurred at other sites, the results would vary depending on the amount of material involved in the accident; the enrichment of the UF 6 

### ; the release fractions, aerosolized fractions, and respirable fractions; release assumptions such as whether the release was elevated or from ground level; the number of people exposed; atmo spheric conditions; and radiation dosimetry assumptions.

If the accident involved NU, th e radiological consequences would be higher—about 0.025 LCFs in the exposed population, assuming that three cylinders were invol ved in the accident. For the MEI, the probability of an LCF would be 1.3 × 10 -5 

### . If the accident involved LEU, the radiological consequences woul d also be higher—about 0.047 LCFs in the exposed population, assuming that three cylinders were involved in the accident. For the MEI, the probability of an

LCF would be 2.4 × 10 -5



### .

In the enrichment facility EIS for the NEF site, the NRC evaluated the radiation doses from direct gamma exposures for members of the public from storage of UF 6 

### cylinders at the NEF (NRC 2005). The radiation dose from storage of UF 6 

### cylinders for a person located at one of three nearby businesses wa s found to be less than 3 mrem per year, which is equivalent to an LCF probability of 2 × 10 -6 

### . Collective radiation doses from direct gamma exposures were not

estimated.

In the enrichment facility EIS for the NEF site, the radiation dose for a worker involved with cylinder handling at the NEF was estimated to be 300 mrem per year, which is equivalent to an

LCF risk of 0.00018. Collective radiation doses from direct gamma exposures were not

estimated.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

84 

### In the enrichment facility EIS for the NEF site, cylinder storage accidents were not evaluated. However, an accident involving the hydraulic rupture of a single 48Y UF 6 

### cylinder containing LEU product in the blending and liquid sampling area was evaluated. The radiation dose to an

individual located at the c ontrolled area boundary was estimated to be 0.97 rem, which is equivalent to an LCF risk of 0.00058. For the exposed population, the collective radiation dose from this accident was estimated to be 12,000 person- rem, which is equivalent to 7.2 LCFs in the exposed population. If this accident occurred at other sites, the results would vary depending on the amount of material involved in the accident; the enrichment of the UF 6 

### ; the release fractions, aerosolized fractions, and respirable fractions; re lease assumptions such as whether the release was elevated or from ground level; the number of people exposed; atmospheric conditions; and radiation dosimetry assumptions.

In the enrichment facility EIS for the ACP site, the NRC also evaluated the radiation doses from direct gamma exposures for members of the public from storage of UF 6 

### cylinders at the ACP (NRC 2006). At the ACP, the presence of existi ng storage yards was found to have a minimal effect, if any, on the exposure rate at the si te boundary. Along the nor thern boundary near an existing cylinder storage yard, where a member of the public might actually stand, the maximum amount of radiation exposure above the ambien t background amounts over the course of a year

was estimated to be less than 13 mrem for an unshielded receptor spending 100 percent of the year standing at that location. If a person were actually living at that northern boundary location near this location (nobody currently resides in that area), th at person would rece ive on the order of 0.87 mrem per year additional exposure when th e effects of shielding and residence time are

included. Collective radiation doses from direct gamma exposures were not estimated.

Occupational radiation doses at the ACP were no t estimated in the enrichment facility EIS for the ACP site (NRC 2006). However, NRC (2006) states that the average dose to cylinder

workers at the Portsmouth reservation in 2003 was 29 mrem, which is equivalent to an LCF risk

of 1.7 × 10 -5 

### . Collective radiation doses from direct gamma exposures were not estimated.

Accidents at the ACP were also evaluated in the enrichment faci lity EIS for the ACP site (NRC 2006), which states that the most significant accide nt consequences are those associated with the

release of UF 6 

### caused by a breach of an overpressurized cylinder. Consequences are not presented for accidents; however, NRC (2006) stat es that accidents at the proposed ACP would result in small to moderate impacts to workers, the environment, and the public.

Table 4-17 lists the occupati onal radiation doses reported to the NRC by the FFFs in 2006 (NRC 2007b). These radiation doses include all activ ities at the FFFs, including cylinder storage

activities. Because DOE’s LEU would not differ fr om other LEU that would be stored at the FFFs, it is not expected that storage of DOE LEU would appreciably al ter these occupational

radiation doses. Direct radiati on data for members of the public are not reported for AREVA NC (NRC 1995), CFFF (NRC 2007a), and GNF-A (NRC 1997).Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

85 

### Table 4-17. Occupational Radiation Doses at FFFs in 2006

Facility Average Individual Dose (rem) LCFs Collective Dose (person-rem) LCFs

AREVA NC 0.230 0.00014 80.347 0.048

GNF-A 0.094 0.000056 58.994 0.035

CFFF 0.370 0.000 22 262.457 0.16
Source: NRC (2007b).



### Accidents at AREVA NC, CFFF, and GNF-A we re evaluated by the NRC. For the CFFF (NRC 2007a), one accident was identified, but the de tails of the accident were not provided and accident consequences were not reported. Fo r AREVA NC (NRC 1995), four accidents were evaluated, but none of the accidents were relate d to cylinder storage. For GNF-A (NRC 1997),

seven accidents were evaluated. One accident was re levant to cylinder storage, a fire involving a single 30B UF 6 

### cylinder containing LEU product on a stor age pad. This accident was estimated to result in a population radiation dose of 29,000 person-rem. In the assumed exposed population, this radiation dose is estimated to result in 17 LCFs. The radiation dose for an individual located 2 kilometers from the facility was estimated to be 5 rem. The probability of an LCF for this person is estimated to be 0.003. If this accident occurred at ot her sites, the results would vary depending on the amount of material i nvolved in the accident; the enrichment of the

UF 6 

### ; the release fractions, aerosolized fractions, and respirable fractions; release assumptions

such as whether the release was elevated or from ground level; the number of people exposed; atmospheric conditions; and radiation dosimetry assumptions.

Section 4.2.1.6 discusses the consequences of inte ntional destructive acts involving the transport

of NU. As discussed in Section 4.2.1.6, the consequences of such an event would be less than or similar to the consequences of severe transpor tation accidents discussed in Section 4.2.1.5 for a given number of cylinders with similar contents.

4.2.3 Impacts on the Uranium Market Under the Enrichment Alternative

Because the annual amount of excess inventory th at would be introduced into the domestic uranium market would be the same (see Sect ion 2.1.2) under the Enrichment Alternative as under the Direct Sale Alternative, or a combin ation of the two, the economic impacts would be essentially identical for the Enrichment Alternative and the Direct Sale Alternative.

4.3 Direct Sale Alternative

4.3.1 Transportation, Enrichment, and Storage Impacts under the Direct Sale Alternative

Under the Direct Sale Alternative, DOE assumes that purchasers would take delivery, transport and enrich the excess inventory, and transport an d store the LEU product in essentially the same manner and using essentially the same fac ilities as would DOE under the Enrichment Alternative. Tails resulting from the ultimate enrichment of DOE’s sold excess inventory would be disposed of in a manner consistent with ex isting practices at the enrichment facilities, and DU tail (waste) disposal practices are analyzed in existing enrichment facility and DUF 6 

### conversion facility NEPA documents and NRC licenses. For that reason, DOE assumes that theFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

86 

### transportation, enrichment, and storage impacts of the Direct Sale Alternative would be essentially identical to those of the Enrichment Alternative.

4.3.2 Impacts on the Uranium Market under the Direct Sale Alternative

DOE is authorized to sell the government's excess uranium under the Atomic Energy Act of 1954, as amended, and consistent with the applicab le provisions of the 1996 USEC Privatization Act, Public Law 104-134 (42 U.S.C. 2297h et seq .). Section 3112(d) of the USEC Privatization Act stipulates that prior to certain sales or tr ansfers of NU or LEU from DOE's excess inventory, the Secretary of Energy must make a determination that the sale or transfer will not have an “adverse material impact” on the domestic mi ning, conversion, and enrichment industry; DOE

will receive not less than the fair market value for the materials; and the material is not necessary for national security needs.

In 2008, Energy Resources International (ERI) anal yzed the potential e ffects on the domestic uranium production (mining and milling), conversion, and enrichment markets of the sale by the U.S. government of a portion of the government ’s excess uranium inventory during a 10-year period (2008-2017) that equates to about 2,000 MTU per year (ERI 2008). That impact analysis was based on (1) ERI’s published supply and demand forecasts from April 2008, and (2) an implied assumption that DOE w ould introduce into the domestic market an amount of uranium that would not generally exceed 10 percent of th e total annual fuel requirements of all licensed U.S. nuclear power plants.

For the purposes of its analysis, ERI (2008) assumed that the sale by DOE of approximately 10 percent of the average annual U.S. re quirements for uranium concentrates (U 3 

### O 8 

### ) and conversion services would represen t just under 5 percent of the U. S. requirement for enrichment services on an average annual basis. The potential effects on long-term prices from the average

annual DOE sale were estimated to be a reduction of 3.5 per cent per pound of U 3 

### O 8 

### , 2 percent per kilogram of uranium for conversion services, and 1.4 percent per separative work unit (SWU) in enrichment services. The estimates by ERI (2008) do not reflect other events that could impact the market prices, nor do they refl ect the fact that some of these DOE sales are already anticipated by market participants. ERI (2008) summarizes that the potential reductions in prices for conversion services are approximately equal to the cha nge in price in the near term (generally 12 months or less) or in the long term (greater than 12 months). That is, the potential price impact from DOE sales was shown to be similar to the impact from routine market fluctuations for conversion services. The potenti al price impact from DOE sales for uranium concentrates was 19 percent of the near-term and 13 percent of the long-term prices compared to 2007. The potential price impact from DOE sales for enrichment services was estimated at 26 percent of the near-term and 30 percent of the long-term prices, also compared to 2007.

ERI (2008) discusses three industry activities that will provide a mitigating effect on the market impacts of any DOE actions. First, the domestic industries of uranium concentrates, conversion of uranium, and enrichment have already co mmitted to production levels and sales through 2009

with some amount of additional forward sales. DOE sales would not displace those committed actions. Second, there is a reason able expectation that the do mestic services for uranium concentrates, conversion, and enrichment will increase. ERI (2008) notes that the domesticFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### uranium concentrate production may double by 2011, domestic conversion may see a 30 percent increase over the next 7 years, and domestic enrichment services may double over the next 7 years. Finally, ERI (2008) acknowledges th at each of these industries operate on an international basis so they are not entirely reliant upon, or subject to, fluctuations in the domestic market. Domestic producers are not the high-cost op tion and should be able to sell their annual production in a competitive market. Domestic conve rsion services are in similar position in a competitive market. DOE sales of enrichment se rvices are not expected to displace only domestic enrichment supply. U.S. buyers use multiple international sources as well as domestic. Nearly 100 percent of competitively priced dom estic enrichment is under contract through 2009, and 50 to 60 percent of domestic enrichment capacity is committed through 2017 (ERI 2008).

ERI (2008) notes a perceived uncer tainty regarding DOE’s potential future sales or enrichment transactions. This perception of risk may pose the greatest im pact on the uranium markets. However, DOE has mitigated this perceived risk of uncertainty by preparing and releasing to the public its Excess Uranium Inventory Management Plan (DOE 2008b), which identifies DOE’s plans for disposition of certain excess uraniu m inventories that are currently ongoing and/or planned, are under consideration, or may be considered by DOE in the future.

DOE’s Proposed Action would not involve construc tion or operation of new uranium conversion facilities, enrichment facilities, or FFFs. The potential socioeconomic impacts related to the construction or operation of existing or other fa cilities currently under development have been analyzed in prior NEPA documents. To the exte nt there are potential socioeconomic impacts under the Proposed Action, such impacts would be derived from the potential uranium market impacts associated with the direct sale or enrichment of DOE’s excess uranium inventory.

Consistent with the Secretarial Policy Statemen t, DOE will manage its excess uranium inventory in a manner that meets its national security and energy missions and is supportive of the maintenance of a strong domestic nuclear industry. In addition, consistent with section 3112(d) of the USEC Privatization Act, if applicable, the Department would proc eed with a particular sale or transfer for NU or LEU following a determ ination by the Secretary that there would be no material adverse impact to the domestic mining, c onversion, or enrichment industries. Further, to mitigate any potentially significant impacts from the sale or transfer of its DU consistent with Departmental policies, DOE would conduct an analys is prior to any sales or transfers of DU to ensure there would be no potenti ally significant impacts to the domestic uranium industries.

In years where sales or transfers would be lim ited to 2,000 MTU per year, the potential impacts to the domestic uranium markets are expected to be small (ERI 2008), and, in any event, would be preceded by applicable Secretarial determinat ion(s) or other appropriate analyses by the Department that the particular sales or transfers would not re sult in potentially significant impacts to the domestic uranium industry. While there may be some temporary adjustments in uranium prices related to the DOE uranium tran sactions, the impacts to the uranium industries are expected to be small. The potential impacts to tax revenues are also expected to be small. Finally, in the geographic regions where the transactions took place, corresponding impacts to area housing, community services , and public utilities are also expected to be small.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### In years where sales or transfers would exceed 2,0 00 MTU, any such transactions also would be preceded by applicable Secretarial determinati on(s) or other appropriate analyses by the Department that the particular sales or transfers would not re sult in potentially significant impacts to the domestic uranium industries. Acco rdingly, the potential im pacts to the domestic uranium markets would be expected to be small.

4.4 No Action Alternative

4.4.1 Environmental Impacts under the No Action Alternative

As described in Section 2.3, the No Action A lternative is defined as the status quo. The environmental impacts that would result under th e No Action Alternative assessed in this EA have been assessed and documented in the two EISs that DOE issued in 2004 (DOE 2004a, 2004b) for the two new DU conversion facilities at the Portsmouth and Paducah sites. A text box on page S-16 of both of these two EISs specifies that the No Action Alternative is storage of

DUF 6 

### and non-DUF 6 

### cylinders indefinitely in yards at th e Paducah and Portsmouth sites, with continued cylinder surveillance and ma intenance activities. These non-DUF 6 

### cylinders contain LEU or NU. The impacts associated with the No Action alternatives evaluated in the two DU conversion facility EISs are delineated in Summary Table S-6 (DOE 2004a) for the Paducah conversion facility 26 

### and Summary Table S-6 (DOE 2004b) for the Portsmouth conversion facility, 27 

### and include the impacts of storing DU, NU, and LEU cylinders, although the impacts are not delineated separately for DU, NU, and LEU cylinders.

Based on the numbers of cylinders evaluated in the two DU conversion EISs, the environmental impacts identified and assessed in these EISs bound the impacts under the No Action Alternative for this EA and are incorpor ated into it by reference.

4.4.2 Impacts on the Uranium Market under the No Action Alternative

If DOE decided not to enrich or to sell any of th e excess inventory but to continue with plans to

convert it to a more stable chemical form at two new conversion facilities, there would be no noticeable impact, either benefici al or adverse, to the curren t uranium production, conversion, or enrichment industries; nor to associated employm ent; nor to the price of uranium other than the socioeconomic impacts identified in Table 4-3 for operation of the new conversion facilities at

Portsmouth and Paducah.

4.5 Cumulative Impacts

Cumulative impacts are the impacts that result fr om the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions, regardless of what agency (federal or non-federal) or pe rson undertakes such other actions . Cumulative impacts can result from individually minor but collectively signif icant actions taking plac e over a period of time (40 CFR § 1508.7). The following sections summari ze and generally incorporate by reference, based on review of existing NEPA documents, re levant cumulative impacts analyses that were

26 Available online at http://web.ead.anl.gov/ura nium/pdf/PAD-Summary.pdf

. 27 Available online at http://web.ead.anl.gov/uranium/pdf/PORT-Summary.pdf

.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### performed as part of those NEPA analyses . These existing NEPA documents address the enrichment of uranium, conversion of DU tails , fuel fabrication, or the transportation of

radioactive material.

4.5.1 Enrichment Alternative

4.5.1.1 Facilities

American Centrifuge Plant

Cumulative impacts that could occur as a result of construction and operation of the ACP were extensively analyzed by NRC in Section 4.3 of the 2006 ACP EIS (NRC 2006). This analysis considered all reasonably foreseeable future activities, including construction and operation of

new DU conversion facilities at DOE Paducah and Portsmouth. With the exception of socioeconomics, for all resource areas wher e NRC identified the potential for cumulative impacts, NRC determined the cumulative impact would be “small”. For socioeconomics, the potential cumulative impact was considered to be small to medium and generally positive. If the DOE chose to enrich NU feed, DU feed, or LEU f eed at the ACP, these enrichment services would be a part of the enrichment services normally provided by the AC P and would not add to the enrichment capacity or throughput provided at the ACP. Because enriching DOE's uranium inventory would not increase the enrichment cap acity or throughput at ACP, the cumulative impacts evaluated in NRC 2006 would not be changed by the cumulative impacts expected to

occur at ACP under the Enrichment Alternative assessed in this EA.

National Enrichment Facility

Cumulative impacts that could occur as a result of construction and operation of the NEF were extensively analyzed by NRC in Section 4.4 of the NEF EIS (NRC 2005). These analyses considered all reasonably foreseeable future activities, including construction and operation of

new DU conversion facilities at DOE Paducah and Portsmouth. With the exception of socioeconomics, for all resource areas wher e NRC identified the potential for cumulative impacts, NRC determined the cumulative impact would be “small”. For socioeconomics, the potential cumulative impact was considered to be small to medium and generally positive. If the DOE chose to enrich NU feed, DU feed, or LEU f eed at the NEF, these enrichment services would be a part of the enrichment services normally provided by the NE F and would not add to the enrichment capacity or thr oughput provided at the NEF. Be cause enriching DOE's uranium inventory would not increase the enrichment cap acity or throughput at NEF, the cumulative impacts evaluated in NRC 2005 would not be changed by the cumulative impacts expected to

occur at NEF under the Enrichment Alternative assessed in this EA.

Paducah Site

Section S.5.16 of DOE’s Final EIS for Construction and Oper ation of a Depleted Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky, Site (DOE 2004a) considered cumulative impacts in the vicinity of the Paducah site. Actions planned at the Paducah site

included the continuation of uranium enrich ment operations by USEC, waste management activities, waste disposal activities, environmental restoration activities, and DUF 6 

### managementFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### activities. Actions occurring near the Paducah s ite that, because of their diffuse nature, could contribute to existing or future impacts on the site include continued operation of the Tennessee Valley Authority’s Shawnee power plant; the Jo ppa, Illinois, power plant; and the Honeywell International uranium conversion plant in Metropolis, Illinois.

• 

### The cumulative collective radiological exposur e to the off-site population would be well

below the maximum DOE dose limit of 100 mrem per year to the off-site MEI and below the limit of 25 mrem per year specified in 40 CFR Part 190 for uranium fuel cycle

facilities. Annual individual doses to involve d workers would be monitored to maintain exposure below the regulatory limit of 5 rem per year.

• 

### Under the EIS’s no action alternative cumula tive impacts assessment, although less than 1 shipment per year of radioactive wastes is expected from cylinder management activities, up to 14,400 truck shipments could be associated with existing and planned actions (no rail shipments are expected). U nder the EIS’s action a lternatives, up to 6,000 rail shipments and 18,600 truck shipments of radioactive material could occur. The cumulative maximum dose to the MEI along the transportation route near the site entrance would be less than 1 mrem per ye ar under all alternatives and for all transportation modes.

• 

### The Paducah site is located in an atta inment region. However, the background annualaverage concentration of particulate matte r less than 2.5 microns in diameter (PM 2.5 

### ) is near the regulatory standard. Cumulative imp acts would not affect attainment status.

• 

### Data from the 2000 annual groundwater monitori ng showed that four pollutants exceeded primary drinking water regulation levels in groundwater at the Paducah site. Good engineering and construction pr actices should ensure that indirect cumulative impacts on groundwater associated with the conv ersion facility would be minimal.

• 

### Cumulative ecological impacts on habitats and biotic communities, including wetlands, would be negligible to minor under all alternatives . Construction of a conversion facility might remove a type of tree preferred by the In diana bat; however, this federal- and statelisted endangered species is not known to utilize these areas.

• 

### No cumulative land use impacts are antic ipated for any of the alternatives.

• 

### It is unlikely that any noteworthy cumulativ e impacts on cultural resources would occur under any alternative, and any such impacts would be adequately mitigated before activities for the chosen action would begin.

• 

### Given the absence of high and adverse cumulative impacts for any impact area considered in the Paducah EIS, no environmental justice cumulative impacts are anticipated for the Paducah site, despite the presence of disproportionately high percentages of low-income populations in the vicinity.

• 

### Socioeconomic impacts under all alternatives co nsidered are anticipated to be generally positive, often temporary, and relatively small.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### If the DOE chose to enrich NU feed, DU feed, or LEU feed at the Paducah GDP, these enrichment services would be a part of the enrichment services normally provided by the

Paducah GDP and would not add to the enrich ment capacity or throughput provided at the Paducah GDP. Because enriching DOE’s uranium inventory would not increase the enrichment capacity or throughput at the Paducah GDP, th e cumulative impacts evaluated in DOE 2004a would not be changed by the cumulative impact s expected to occur at the Paducah GDP under

the Enrichment Alternative assessed in this EA.

AREVA NC

In 2007, DOE prepared an EA that assessed the impacts, including cumulative impacts, associated with proposed construction and ope ration of a large research complex on DOE property located about 1.6 kilome ters (1 mile) from AREVA NC: Construction and Operation of a Physical Sciences Facility (PSF) at the Pa cific Northwest National Laboratory, Richland, Washington (DOE 2007c). 28 

### In January 2007, DOE issued a FONSI for the PSF EA 29 

### which found that “no noticeable cumulative impacts” w ith other ongoing operations in the region were expected.

The PSF EA specifically cited AREVA NC as a neighboring, potentially affected operation. The Proposed Action assessed in this EA would likely result in deliver y of fewer than 3,195 30B cylinders of LEU product to AREVA NC . About 3,200 LEU product cylinders would be produced during the enrichment of NU feed, DU feed, and LEU feed evaluated in this EA. Based on a 25-year duration of the Proposed Action, about 130 LEU product cylinders would be shipped annually to AREVA NC. Such deliver ies are consistent with current AREVA NC operations. 30 

### Because construction and operation of th e PSF (which included assessments of radiological safety and environmental impacts) essentially adjacent to AREVA NC would have no cumulative impacts on the neighboring facilities or region, and because the Proposed Action would not impact or expand AREVA NC operations , the cumulative impacts evaluated in DOE 2007c would not be changed by the cumulative imp acts expected to occur at AREVA NC under

the Enrichment Alternative assessed in this EA.

Westinghouse Electric Corporation CFFF

In April 2007, the NRC issued an EA for th e renewal of the CFFF license (License No. SNM-1107) (NRC 2007a). The EA included the fo llowing assessment of cumulative impacts:

“The NRC staff has evaluated whether cumulative environmental effects could result from the incremental impacts of the SNM–1107 license re newal for the site when added to relevant past, present, or r easonably foreseeable future actions in the area. No significant cumulative effects we re identified for the areas within the

28 Available online at http://gc.energy.gov/NEPA/nepa_documents/ea/ea1562/EA_1562.pdf

. 29 Available online at http://gc.energy.gov/NEPA/nepa_documents/ea/ea1562/FONSI.pdf

. 30 Because the actual annual amounts of excess inventory enriched would likely be less than the maximum annual amount, and because it would probably change from year to year, DOE is not limiting the Proposed Action to a particular number of years. However, for purposes of modeling the impacts of processing the entire inventory, 25 years is used.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

92 

### affected environments described. For example, the water usage for the Congaree River is less than 1 percent of the total water usage in the watershed. The site is in compliance with relevant environmental st andards and regulations, as well as NRC regulations related to radiation dose to the public and facility workers. Further, the facility utilizes an as low as reas onably achievable (ALARA) program, routine environmental and radiation monitoring, a radiation safety program, a chemical safety program, and an environmental protection program to minimize the associated direct, indirect, and cumulativ e effects. Finally, WEC also conducts program audits and self-assessments as a way to minimize adverse environmental

effects.”

The Proposed Action assessed in this EA would lik ely result in delivery of fewer than 3,195 30B cylinders of LEU product to the CFFF. About 3,200 LEU product cylinders would be produced during the enrichment of NU fee d, DU feed, and LEU feed evalua ted in this EA. Based on a 25- year duration of the Proposed Action, about 130 LEU product cylinders would be shipped annually to the CFFF. Such deliveries are consis tent with current CFFF operations. Because the Proposed Action would not impact or expand the CFFF operations, th e cumulative impacts evaluated in NRC 2007a would not be changed by the cumulative impacts expected to occur at

the CFFF under the Enrichment Altern ative assessed in this EA.

Global Nuclear Fuel–Americas

To assess the potential for cumulative impact s to the area surrounding GNF-A, DOE reviewed GNF-A’s March 2008 response to an NRC Environmental Assessment Request for Additional Information (RAI) to support GNF-A’s application for a 40-year license renewal (GNF-A 2008). Among other things, the RAI requested that GNF -A identify reasonably foreseeable future actions and cumulative impacts. GNF-A re sponded to this RAI as follows:

“Most of the industrial development in the vicinity of the Wilmington site is on the northeast side of the Northeast Cape Fear River. No new industrial developments are known to be planned in the immediate vicinity of the Wilmington site on the east side of the river. A developer is proposing a new 237-acre (95-hectares) continuing care retirement community (Riv er Bluffs subdivision) that would be built on the undeveloped land parcel bounded by the Wilmington site’s southern property line, I-140, and the Northeast Cape Fear River.

“There are four on-site planned future actions not related to fuel fabrication operations that may cumulatively impact the affected areas. These actions include the ATC II Complex, the Tooling Development Center, the Global Laser Enrichment Test Loop and Commercial Faci lity. The ATC II office complex will be located adjacent to the existing ATC I offi ce building in the sout heastern portion of the Eastern Site Sector, near the south gate Wilmington site entrance. The entire project will disturb approxima tely 30 acres (12 hectares) of the Wilmington site. In preparation for the new office complex, th e site has constructed a stormwater retention pond and has installed a new parki ng lot and a set of te mporary trailers in front of the existing ATC I building. The temporary trailers will serve as officesFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### until the new complex is completed. There wi ll be no effluents from these activities

aside from those associated with constructi on and sanitary waste. The facility will require an estimated 7,500 gallons (28,400 lit ers) of potable water, and it is conservatively assumed that there will be no consumptive losses and that the same volumes of sanitary wastewater would be generated for treatment in the existing Wilmington site sanitary WTF, which can accommodate the increase. The Tooling Development Center will be located in the southwestern portion of the Eastern Site Sector. It will consist of five new buildings and will disturb approximately 30 acres (12 hectares) of the Wilmington site.

“The facility will require an estimated 5,000 gallons (18,900 liters) of process water and 11,000 gallons (41,600 liters) of potable water, and it is conservatively assumed that there will be no consumptive losses a nd that the same volumes of process and sanitary wastewaters would be generated for treatment in the existing Wilmington site final process lagoon fac ility and sanitary WTF, respectively which can be accommodated by the treatment facilities. No radioactive material will be used in the Tooling Development Center buildings , and no air permits will be required. Approximately 0.75 mile (1.2 kilometers) of new road will be constructed in the

Eastern Site Sector in order to access the Center.

“The cumulative impacts of the GLE Test Loop are minimal as discussed in the SNM-1097 Test Loop license amendment request. The impacts from the Commercial Facility are expected to be small and will be addressed in a separate Environmental Report submittal for the GLE Commercial Facility license application.

“The cumulative impacts of the facil ities and actions described above are anticipated to be small.”

The Proposed Action assessed in this EA would likely result in delivery of fewer than 3,195 30B cylinders of LEU product to GNF-A. About 3,200 LEU product cylinders would be produced during the enrichment of NU feed, DU feed, and LEU feed evaluated in this EA. Based on a 25-year duration of the Proposed Action, about 130 LEU product cylinders would be shipped annually to GNF-A. Such deliveries ar e consistent with current GNF-A operations. Because the Proposed Action would not impact or expand GNF-A operations, the cumulative impacts described in the RAI would not be chan ged by the cumulative impacts expected to occur

at GNF-A under the Enrichment A lternative assessed in this EA.

4.5.1.2 Cumulative Transportation Impacts

In Section 8.4.1.5 in DOE (2008c), cumulative impact s of transporting radioactive material were evaluated for the period 1943 through 2073. Over this time, DOE estimated that there could be 240 LCFs for workers, 210 LCFs for members of th e public, and 130 traffic fa talities. In this EA,

less than 1 LCF would be estimated to occur for workers and for members of the public, and about 1 traffic fatality would be estimated to occur.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### 4.5.1.3 Cumulative Storage Impacts

The possession limits for uranium at NRC-licen sed FFFs are typically given in terms of kilograms of 235 

### U. At an enrichment of 4.95 percent, 1 kilogram of uranium contains 0.0495 kilograms of 235 

### U. NRC licenses allow for the possession of 75,000 kilograms of 235 

### U at AREVA NC, 50,000 kilograms of 235 

### U at GNF-A, and 75,000 kilograms of 235 

### U at the CFFF.

DOE would not store 235 

### U at the FFFs in excess of these am ounts without NRC approval. About 4,900 MT of LEU product would be produced by enriching all the surplus NU, DU, and LEU feed. This LEU product would contain about 240,000 kilograms of 235 

### U, or about 9,700 kilograms per year of 235 

### U over the 25-year time period of the Proposed Action. Therefore, the enrichment of the surplus NU, DU, and LEU feed, would account for only about 13 to 19 percent of the annual storage capacity at the FFFs.

It is also possible that DOE would stor e up to 670 MTU of LEU containing about 33,200 kilograms of 235 

### U at the FFFs as an inventory for future DOE use in accordance with applicable DOE policies and the Secretarial Policy Statement. This would account for 44 to 66 percent of the licensed storage capacity at an FFF. This entir e inventory is unlikely to be stored at a single FFF, and a portion could be stored at the DOE Portsmouth and/or DOE

Paducah facilities.

In the two EISs analyzing constr uction and operation of proposed UF 6 

### conversion facilities at DOE Paducah (DOE 2004a) and DOE Portsmouth (DOE 2004b), DOE evaluated the continued storage of DU, NU, and LEU cylinders as part of the no action alternatives. At the Portsmouth site, about 210,000 MT of UF 6 

### (140,000 MTU) 31 

### was analyzed; at the Paducah site, about 450,000 MT of UF 6 

### (310,000 MTU) was analyzed. The 4,900 MTU of LEU product that would be produced under the Proposed Action described in this EA is about 3 percent of the uranium analyzed at Portsmouth and about 2 percent of the uranium anal yzed at Paducah. Furthermore,

the LEU would be the resu lt of enrichment of UF 6 

### stored at DOE Paducah and DOE Portsmouth and would not represent a net in crease in the uranium managed at the combined facilities.

4.5.2 Direct Sale Alternative

Under the Direct Sale Alternative, DOE assumes that purchasers would take delivery, transport and enrich the NU, DU, and LEU feed material, and transport and store the resultant NU and LEU product and DU tails in essentially the sa me manner and using essentially the same

facilities as would DOE under the Enrichment Alternative. For th at reason, DOE finds that the cumulative transportation, enrichment, and storage impacts of the Direct Sale Alternative would be essentially identical to those of the Enrichment Alternative.

4.5.3 No Action Alternative

Under the No Action Alternative, DOE would not en rich and/or sell any of the excess inventory but rather would continue with existing plans to convert the excess DU st ored at Portsmouth and

Paducah to a more stable chemical form at the two new conversion facilities and would continue to store excess NU and LEU as it is currently bei ng stored at these two sites. The cumulative

31 To convert MT of UF 6 to MTU, multiply by 0.67612 (USEC 2006, Table 5).Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### impacts that would occur under the No Action Alte rnative assessed in this EA are the same as the cumulative impacts identified for the two ne w conversion facilities in Table 4-3, Summary of Expected Impacts from Operation of the Padu cah and the Portsmouth Conversion Facilities.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### 5.0 IRREVERSIBLE AND IRRETRIEVAB LE COMMITMENT OF RESOURCES

AND SHORT-TERM USES OF THE ENVIRONMENT VS. LONG-TERM

PRODUCTIVITY

5.1 Irreversible and Irretrievable Commitment of Resources

An irreversible commitment of resources is defined as the loss of future options. The term applies primarily to the effects of using nonrenew able resources (such as minerals or cultural resources) or resources that are renewable only over long periods (such as soil productivity). It could also apply to the loss of an experience as an indirect effect of a “permanent” change in the

nature or character of the land. An irretrievable commitment of resources is defined as the loss of production, harvest, or use of natural re sources. The amount of production forgone is irretrievable, but the action is not irreversible . If the use changes, it is possible to resume production.

Under both alternatives in DOE’s Proposed Ac tion, DOE assumes that the excess inventory would be enriched to NU and/or up to LEU and then, presumably, used to manufacture nuclear reactor fuel. Therefore, these al ternatives contemplate the poten tial use of DU, that otherwise would be disposed, to produce nuclear reactor fuel.

The irreversible and irretrievable commitments of resources associated with the Proposed Action are the use and cost of transportation fuel, energy to run nuclear fuel cycle plants, the use of uranium fuel in nuclear reactors to produce electricity, labor, materials, and funds. There would

be no irretrievable commitments of biological productivity or resources.

5.2 The Relationship between Local Short-T erm Uses of the Human Environment and the Maintenance and Enhancement of Long-Term Productivity

The Proposed Action does not involve major ne w construction. It would be implemented at existing sites or sites currentl y under construction, and over ex isting transporta tion corridors. There would be no incremental loss of long-term biological productivity or open-space values. The Proposed Action could reduce reliance on fossil fuels.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

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### 6.0 REFERENCES

46 FR 1007. Implementation of Executi ve Order 12114, Environmental Effects Abroad of Major
Federal Actions; Final Guideline . January 5, 1981.

61 FR 40619. Record of Decision for Di sposition of Surplus Highl y Enriched Uranium Final Environmental Impact Statement . August 5, 1996. Ava ilable online at: http://gc.energy.gov/NEPA/nepa_documents/rods/1996/5au6rod.pdf

.

64 FR 43358. Record of Decision for Long-Term M anagement and Use of Depleted Uranium Hexafluoride . August 10, 1999. Available online at http://gc.energy.gov/NEPA/nepa_documents/rods/2003/43358.pdf

.

68 FR 53603. Amendment to the Record of Decision for the Department of Energy’s Final Programmatic Environmental Impact Statem ent for Long-Term Management and Use of Depleted Uranium Hexafluoride . September 11, 2003. Available online at http://gc.energy.gov/NEPA/nepa_documents/rods/2003/53603.pdf

.

69 FR 44649. Record of Decision for Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, OH, Site . July 27, 2004. Available

online at http://web.ead.anl.gov/uranium/documents/portdeis/index.cfm

.

69 FR 44654. Record of Decision for Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facili ty at the Paducah, KY, Site . July 27, 2004. Available online

at http://web.ead.anl.gov/uranium /documents/paddeis/index.cfm

.

73 FR 60173. Endangered Fish and Wildlife; Final Rule to Implement Speed Restrictions to Reduce the Threat of Ship Collisions with North Atlantic Right Whales . October 10, 2008.

Available online at http://www.nmfs.noaa.gov/pr/pdfs/fr/fr73-60173.pdf

.

AREVA. 2006. Supplement to Applicant’s Environmental Report. E06-04-004. October.

Biwer et al. (B.M. Biwer, F.A. Mone tte, L.A. Nieves, and N.L. Ranek). 2001. Transportation Impact Assessment for Shipment of Uranium Hexafluoride (UF 6 

### ) Cylinders from East Tennessee Technology Park to the Portsm outh and Paducah Gaseous Diffusion Plants

. Report No. ANL/EAD/TM-112, Argonne National Inventory, Argonne, Illinois. October.

Cameco (Cameco Corporation). 2007. Uranium Markets . Available online at http://www.cameco.com/uranium_101/markets/ . Dated April 9, 2007. Accessed May 30,

2008.

DOE (U.S. Department of Energy). 2008a. Draft Global Nuclear Energy Partnership Programmatic Environmental Impact Statement . DOE/EIS-0396. October. Available online

at http://www.gc.doe.gov/NEPA/1003.htm

.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

100 

### DOE (U.S. Department of Energy). 2008b. Excess Uranium Inventory Management Plan . Office of Nuclear Energy. December 16. Available online at http://www.nuclear.gov/pdfFiles /inventory_plan_unclassified.pdf

.

DOE (U.S. Department of Energy). 2008c. Final Supplemental Environmental Impact Statement for a Geologic Repository for the Dispos al of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada . DOE/EIS-0250F-S1. Office of Civilian Radioactive Waste Management, Las Vegas, Nevada. June. Available online at http://adamswebsearch2.nrc.gov/idmws/Vi ewDocByAccession.asp?AccessionNumber=ML0

81750191

.

DOE (U.S. Department of Energy). 2007a. Paducah Annual Site Environmental Report for

Calendar Year 2005. PRS-ENM-0002. August. Available online at http://www.prsllc.net/aser/2005.html

.

DOE (U.S. Department of Energy). 2007b. Portsmouth Annual Site Environmental Report for

2005 . August. Available online at http://www.lpports.com/05%20Annual%20Environmental%20Report.htm

DOE (U.S. Department of Energy). 2007c. Environmental Assessmen t for Construction and Operation of a Physical Sciences Facility (PSF) at the Pacific Northwest National Laboratory, Richland, Washington . DOE/EA-1562. Pacific Northw est Site Office. January.

Available online at http://gc.energy.gov/NEPA/nepa_documents/ea/ea1562/EA_1562.pdf

.

DOE (U.S. Department of Energy). 2004a. Final Environmental Impact Statement for Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky, Site . DOE/EIS-0359. June. Available online at http://web.ead.anl.gov/uranium/documents/paddeis/index.cfm

.

DOE (U.S. Department of Energy). 2004b. Final Environmental Impact Statement for Construction and Operation of a Depleted Ur anium Hexafluoride Conversion Facility at Portsmouth, Ohio, Site . DOE/EIS-0360. June. Available online at http://web.ead.anl.gov/uranium/ documents/portdeis/index.cfm

.

DOE (U.S. Department of Energy). 1999a. Environmental Assessment, Disposition of Russian

Federation Titled Natural Uranium . Report No. DOE/EA-1290.

DOE (U.S. Department of Energy). 1999b. Final Programmatic Environmental Impact Statement for Alternative Strategies for th e Long-term Management and Use of Depleted Uranium Hexafluoride . DOE/EIS-0269. April. Available online at http://web.ead.anl.gov/uranium/doc uments/nepacomp/peis/index.cfm

.

DOE (U.S. Department of Energy). 1996. DOE Sale of Surplus Natural and Low Enriched

Uranium . DOE/EA-1172. Available online at http://www.ne.doe.gov/pdfFiles/finalea.pdf

.

DOE (U.S. Department of Energy). 1994. Environmental Assessment for the Purchase of

Russian Low Enriched Uranium De rived from the Dismantlement of Nuclear Weapons in theFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

101 

### Countries of the Former Soviet Union . DOE/EA-0837 (USEC/EA 94001). Prepared by U.S. Enrichment Corporation, Bethesda, Maryland. January. Available online at http://www.osti.gov/bridge/produc t.biblio.jsp?osti_id=10144278

.

DOE (U.S. Department of Energy). 1990. Radiation Protection of the Public and the

Environment , DOE Order 5400.5, Washington, D.C., February 8.

DOE (U.S. Department of Energy). 1982. Final Environmental Im pact Assessment of the Paducah Gaseous Diffusion Plant Site . DOE/EA-0155. August.

DOT (U.S. Department of Transportation). 2007. Transportation Statistics Annual Report 2007. U.S. Department of Transportation, Resear ch and Innovative Tec hnology Administration, Bureau of Transportation St atistics, Washington, D.C.

ERI (Energy Resources International, Inc.). 2008. Quantification of the Potential Impact on Commercial Nuclear Fuel Markets of the Sale by the U.S. Government of Selected Inventory

. April.

GNF-A (Global Nuclear Fuel-Americas). 2008. Response to (NRC) Environmental Assessment Request for Additional In formation (TAC L32670) . Dated March 27. Agencywide Documents Access and Management System (ADAMS) Access #ML081350536.

GNF-A (Global Nuclear Fuel-Americas). 2007. GNF-Americas Wilmington Environmental Report Supplement . March 30, 2007.

IAEA (International Atomic Energy Agency). 2005. Safety Standards Regulations for the Safe Transport of Radioactive Material.

IAEA (International Atomic Energy Agency). 1991. Interim Guidance on the Safe Transport of Uranium Hexafluoride

Johnson, P.E. and Michelhaugh, R.D. 2003. Transportation Routing Analysis Geographic Information System (TRAGIS) User's Manual . Report No. ORNL/NTRC-006, Rev. 0. Oak Ridge National Laboratory, Oak Ridge, Tennessee.

Lawrence, A. 2002. “Radiation Risk Estimation from Total Effective Dose Equivalents (TEDEs).” Memorandum from A. Lawrence (DOE) to distribution, August 9, 2002, with

attachments.

Lockheed Martin Energy Systems, Inc. 1997. Safety Analysis Report, Portsmouth Gaseous Diffusion Plant, Piketon, Ohio. POEF-LMES-89, revision R0-A. Portsmouth, Ohio.

Neuhauser, K.S., and F.L. Kanipe. 2000. RADTRAN 5 User Guide . Report No. SAND2000-

1257. Sandia National Laborat ories, Albuquerque, NM.

Neuhauser et al. (K.S. Neuhauser, F. L. Kanipe, and R.F. Weiner). 2000. RADTRAN 5 Technical

Manual . Report No. SAND2000-1256. Sandia Nationa l Laboratories, Albuquerque, NM.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

102 

### NRC (U.S. Nuclear Regulatory Commission). 2009. Environmental Assessment for the Renewal of U.S. Nuclear Regulatory Commission License No. SNM-1227 for AREVA NP, Inc Richland Fuel Fabrication Facility. February.

NRC (U.S. Nuclear Regulatory Commission). 2008. Find Operating Nuclear Power Reactors by

Location or Name . Available online at http://www.nrc.gov/info-finder/reactor/ . Updated February 14, 2008. Accessed July 8, 2008.

NRC (U.S. Nuclear Regulatory Commission). 2007a. Final Environmental Assessment for the Renewal of NRC License No. SNM-1107 for Westinghouse Columbia Fuel Fabrication Facility, Columbia, South Carolina. April.

NRC (U.S. Nuclear Regulatory Commission). 2007b. Occupational Radiation Exposure at

Commercial Nuclear Power Reac tors and Other Facilities 2006 . NUREG-0713, Vol. 28.

November.

NRC (U.S. Nuclear Regulatory Commission). 2006. Final Environmental Impact Statement for the Proposed American Centrifuge Plant in Piketon, Ohio . NUREG-1834. April. Available

online at http://www.nrc.gov/reading-rm/doc-c ollections/nuregs/staff/sr1834/

.

NRC (U.S. Nuclear Regulatory Commission). 2005. Final Environmental Impact Statement for the Proposed National Enrichment Fa cility in Lea County, New Mexico . NUREG-1790.

June. Available online at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1790/

.

NRC (U.S. Nuclear Regulatory Commission). 2004. Environmental Assessment of the USEC Inc. American Centrifuge Lead Cascade Facility at Piketon, Ohio . January.

NRC (U.S. Nuclear Regulatory Commission). 2000. Compliance Evaluation Report: Application Dated October 20, 2000; Higher Assay Upgrade Project

.

NRC (U.S. Nuclear Regulatory Commission). 1997. Environmental Assessment for the Renewal of NRC License No. SNM-1097 for General El ectric Company Nuclear Energy Production Facility, Wilmington, North Carolina . May.

NRC (U.S. Nuclear Regulatory Commission). 1995. Environmental Assessment for the Renewal of NRC License No. SNM-1227 for Siemens Power Corporation, Richland, Washington

. June.

USEC (United States Enrichment Corporation). 2006. The UF 6 

### Manual, Good Handling Practices for Urani um Hexafluoride . Report No. USEC-651, Revision 9. July.

WNA (World Nuclear Association). 2009. ”Nuclear Power in the USA.” Information paper. January. Available online at http://www.wo rld-nuclear.org/info/inf41.html#capacity.

WNA (World Nuclear Association). 2008. “World Uranium Mining.” Information paper. July. Available online at http://www.wo rld-nuclear.org/info/inf23.html.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

A-1 

### APPENDIX A: SECRETARY OF ENERGY’S M ARCH 2008 POLICY STATEMENTFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

A-2Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

A-3Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

A-4Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-1 

### APPENDIX B: TRANSMITTAL LETTERS A ND DISTRIBUTION LISTS

This appendix contains (1) copies of the transm ittal letters sent to th e agencies, organizations, and individuals receiving the draf t and this final EA, and (2) the distribution lists containing the names of those receiving the EA.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-2 

### Draft EA Transmittal LettersFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-3Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-4Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-5Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-6Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-7Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-8Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-9Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-10Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-11 

### Final EA Transmittal LetterFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-12 

### Distribution List

State Agencies

Mr. Larry C. Taylor

Environmental Scientist IV

Office of the Commissioner Department for Environmental Protection

300 Fair Oaks Lane Frankfort, Kentucky 40601

Dr. Harold Leggett Secretary Office of the Secretary Louisiana Dept. of Environmental Quality

PO Box 4301 Baton Rouge, LA 70821-4301

Mr. Ron Curry Secretary New Mexico Environment Department

1190 St. Francis Drive Santa Fe, NM 87502

Ms. Valerie W. McMillan Director, State Environmental Policy Act Department of Administration

1301 Mail Service Center Raleigh, North Carolina 27699-1301 Mr. Tom Winston Chief, Office of Federal Facility Oversight

401 East Fifth Street Dayton, Ohio 45402-2911

State Clearinghouse Office of State Budget 1201 Main Street, Suite 870 Columbia, South Carolina 29201

Ms. Ellie L. Irons Environmental Impact Review Manager Virginia Department of Environmental Quality

P.O. Box 1105 Richmond, Virginia 23218

SEPA Unit SEPA Unit Supervisor Washington Department of Ecology

P.O. Box 47703 Olympia, Washington 98504-7703Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-14 

### General Distribution

Director Office of Nuclear Materials Safety and Safeguards Mail Stop EBB1-D2M

U. S. Nuclear Re gulatory Commission

6003 Executive Boulevard Rockville, MD 20852

Mr. Steve Penrod General Manager

USEC

P.O. Box 1410-5600 Paducah, KY 42002-1410

Cheryl Collins Uranium Management Services GE Hitachi Nuclear Energy 3901 Castle Hayne Road

Mail Code J20 Wilmington, NC 28402

Frank Masseth Commercial Project Manager

AREVA NP Inc. An AREVA and Siemens company

3315 Old Forest Road OF-11 Lynchburg, Va. 24501 Jim Andreen Westinghouse Electric Company

MS10

Drawer R Columbia, SC 29250

Jim Andreen Westinghouse Electric Company

MS10

5801 Bluff Rd Hopkins, SC 29061

Mr. John Indall

P.O. Box 669 Santa Fe, NM 87504-0669

Mr. Jim Graham

President & CEO ConverDyn 7800 East Dorado Place, Suite 200 Englewood, CO 80111Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

B-14 

### This page intentionally left blank.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

C-1 

### APPENDIX C: OTHER NEPA DOCUMENTS CONSIDERED

Table C-1. Other NEPA Documents Considered
Description of the Proposed Action ROD Comments

EISs for Uranium Enrichment and Conversion Facilities and Programmatic EIS for Managing DUF 6


### Final EIS for the Proposed American Centrifuge Plant in Piketon, Ohio NUREG-1834 (April 2006)

http://www.nrc.gov/reading-rm/doc-c ollections/nuregs/staff/sr1834/ The proposed action considered in this 2006 EIS was for the NRC to issue a license authorizing the United States Enrichment Corporation (USEC) to possess and use special nuclear material (SNM), so urce material, and byproduct material at the proposed Ameri can Centrifuge Plant (ACP), a gas centrifuge uranium enrichme nt facility. If a license were issued, USEC would construct, operate, and decommission the proposed ACP. The ACP would be located at the same site as DOE’s Portsmouth Gaseous Diffusion Plant (GDP), which has been shut down since May 2001. The ACP would consist of refurbished existing buildings, newly constructed facilities, and adjacent grounds owned by DOE and leased by USEC.

The enriched uranium would be used in commercial nuclear power plants. The NRC has

issued a license to

USEC. This EA incorporates by reference the description of the

ACP site environment and the impacts associated with operation of the ACP.



### Final EIS for the Proposed National Enrichme nt Facility in Lea County, New Mexico NUREG-1790 (June 2005)

http://www.nrc.gov/reading-rm/doc-c ollections/nuregs/staff/sr1790/ The proposed action considered in this 2005 EIS was for the NRC to issue a license authorizing Louisiana Energy Services (LES) to possess and use SNM, source material, and byproduct material at the proposed National Enrichment Facility (NEF), a gas centrifuge uranium enrichment facility proposed to be located at a site near the city of Eunice in Lea County, New Mexico. If a license were issued, LES would construct, operate, and decommission the proposed NEF. The proposed NEF property and facilities would remain the property of Lea County until they were deeded over to LES at license termination. The proposed NEF would produce enriched uranium-235 ( 235 U) up to 5 weight percent by the gas centrifuge process. The enriched uranium would be used in commercial nuclear power plants. The NRC has

issued a license to

LES. This EA incorporates by reference the description of the

NEF site environment and the impacts associated with operation of the NEF.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

C-2 

### Table C-1. Other NEPA Documents Considered (continued)
Description of the Proposed Action ROD Comments



### Final EIS for Construction and Operation of a Depl eted Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky, Site DOE/EIS-0359 (June 2004)

http://web.ead.anl.gov/uranium/documents/paddeis/index.cfm The proposed action evaluated in this 2004 EIS is for DOE to construct and operate a facility at the Paducah site for converting the Paducah DUF 6 inventory into DU oxide (primarily U 3 O 8 ) and other conversion products. The action includes construction, operation, maintenance, and D&D of the proposed DUF 6 conversion facility at the Paducah site; transportation of DU conversion products and waste materials to a disposal facility; transportation and sale of the HF produced as a conversion co-product; and neutralization of HF

to CaF 2 and its sale or disposal in the event that the HF product

is not sold. DOE decided to

construct and operate the

conversion facility in the

south-central portion of the

Paducah site. This EA incorporates by reference the description of

the Paducah site and its DU/NU inventory. It also summarizes and incorporates operational impacts at the conversion facility as the impacts for the No Action

Alternative for this EA.



### Final EIS for Construction and Operation of a Depl eted Uranium Hexafluoride Conversion Facility at Portsmouth, Ohio, Site DOE/EIS-0360 (June 2004)

http://web.ead.anl.gov/uranium/ documents/portdeis/index.cfm The proposed action evaluated in this 2004 EIS is for DOE to construct and operate a facility at the Portsmouth site for converting the Portsmouth DUF 6 inventory into DU oxide (primarily U 3 O 8 ) and other conversion products. The action includes construction, operation, maintenance, and D&D of the proposed DUF 6 conversion facility at the Portsmouth site; transportation of DUF 6 cylinders from ETTP to Portsmouth for conversion, and transportation of non-DUF 6 cylinders from ETTP to Portsmouth; constructi on of a new cylinder storage yard at Portsmouth (if required) for ETTP cylinders; transportation of DU conversion products and waste materials to a disposal facility; transportation and sale of the HF produced as a conversion co-product; and neutralization of HF

to CaF 2 and its sale or disposal if the HF product is not sold. DOE decided to

construct and operate the

conversion facility in the

west-central portion of the

Portsmouth site. This EA incorporates by reference the description of

the Portsmouth site and its DU/NU inventory. It also summarizes and incorporates operational impacts at the conversion facility as the impacts for the No Action

Alternative for this EA.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

C-3 

### Table C-1. Other NEPA Documents Considered (continued)
Description of the Proposed Action ROD Comments DOE EISs (2) Addressing Transportation Impacts



### Final Programmatic Environmental Impact Statemen t for Alternative Strategies for the Long-Term Management and Use of Depleted Uranium Hexafluoride DOE/EIS-0269 (April 1999)

http://web.ead.anl.gov/uranium/doc uments/nepacomp/peis/index.cfm This 1999 PEIS assessed the potential impacts of alternative DOE management strategies for DUF 6 stored at three DOE sites: Paducah site near Paducah, Kentucky; Portsmouth site near Portsmouth, Ohio; and K-25 site on the Oak Ridge Reservation, Oak Ridge, Tenness ee. The alternatives analyzed in the PEIS included no action, long-term storage as UF 6 , longterm storage as uranium oxide, use as uranium oxide, use as uranium metal, and disposal. DOE decided to promptly convert

the DUF 6 inventory to DU oxide, DU metal,

or a combination

of both. This EA considers the transportation risks that were

evaluated for all of the

materials that are relevant to this EA. Transportation impacts were estimated for shipment by both truck and

rail modes for most materials.



### Final EIS on Disposition of Surplus Highly Enriched Uranium DOE/EIS-0240-S (June 1996)

http://www.fas.org/nuke/control/fmd/docs/summary.pdf ; http://www.epa.gov/ fedrgstr/EPAIMPACT/1995/October/Day-26/pr-1440.html This 1996 EIS assessed environmental impacts of five reasonable alternatives identified for the disposition of up to

nominal 200 MT of excess HEU. This included HEU that had already been declared excess ( 175 MT) as well as additional weapons-usable HEU that could be declared excess in the future. The material was located at facilities throughout the Department’s nuclear weapons complex, but the majority was in, or was destined for, interi m storage at the Department’s Y12 Plant in Oak Ridge, Tenne ssee. Except for the no action alternative, all reasonable alternatives involved blending HEU with depleted, natural, or LEU to make LEU, which is not weapons-usable, and the majority of which would have potential commercial value as non-defense, nuclear power plant fuel feed. The alternatives, excep t for the no action alternative, reflected blending different proportions of the HEU to LEU for commercial use versus blending it to LEU for disposal as waste. The alternatives also pres ented different combinations of blending sites and blending processes. DOE decided to implement a program to make

excess HEU nonweapons-usable by blending it

down to LEU. Although the 1996 EIS is not directly related to this EA, it was reviewed for background and transportation impact insights.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

C-4 

### Table C-1. Other NEPA Documents Considered (continued)
Description of the Proposed Action ROD Comments DOE EA (1) Addressing Transportation Impacts



### Environmental Assessment for the Purchase of Ru ssian Low Enriched Uranium Derived from the Dismantlement of Nuclear Weapons in the Countries of the Former Soviet Union DOE/EA-0837, January (USEC/EA 94001)

http://www.osti.gov/bridge/produ ct.biblio.jsp?osti_id=10144278 The United States proposed to purchase from the Russian Federation low LEU derived from HEU resulting from the dismantlement of nuclear weap ons in the countries of the former Soviet Union. This 1994 EA assessed the following: (1) shipment of the LEU from St. Petersburg, Russia, via the Gulf of Finland, Baltic Sea, No rth Sea, and Atlantic Ocean to one or more of seven proposed ports of entry (Port of Hampton Roads, Virginia; Port of Baltimore, Maryland; Port of Philadelphia and South New Jersey, Pennsylvania and New Jersey; Port of New York and New Jersey, New York and New Jersey; Port of Houston, Texas; Port of Charleston, South Carolina; and Port of Savannah , Georgia) by commercial ocean freighter; (2) transport of the LEU by commercial truck from the port of entry to the Portsm outh GDP; and (3) placement of the LEU in the GDP inventory where it would be made available to USEC utility customers to be fabricated into fuel as

orders were received. N/A This EA considers the overseas transportation impacts assessed in the 1994

EA.

DOE EA (1) Addressing Economic Impacts of Uranium Sales



### DOE Sale of Surplus Natural and Low Enriched Uranium

DOE/EA-1172

http://www.ne.doe.gov/pdfFiles/finalea.pdf This 1996 EA evaluated the economic impacts associated with the proposed sale or disposition of excess uranium, both natural and low enriched, stored at the Department’s GDPs near Piketon, Ohio, and at Paducah, Kentucky. The uranium from the Department’s inventory being considered for sale or disposition in the EA was declared excess to national security

needs and therefore could be used for commercial purposes. In addition to this uranium, DOE proposed to sell “Russian” NU transferred from the USEC pursua nt to the USEC Privatization Act, which requires the Secretar y to sell this material within 7 years of the date of enactment (April 26, 1996). N/A This EA considers and uses the economic analyses in the

1996 EA.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

C-5 

### Table C-1. Other NEPA Documents Considered (continued)
Description of the Proposed Action ROD Comments NRC EAs for Nuclear Fuel Company License Renewals and DOE EA for Research Facility near AREVA NC



### Environmental Assessment for the Renewal of NRC License No. SNM 1107 for Westinghouse Columbia Fuel Fabrication Facility, Columbia, South Carolina (April 2007)

Current Licensee: Westinghou se Electric Company, LLCThe proposed action in this 2007 EA is to renew the SNM1107 license for a 20-year peri od, thereby authorizing WEC to continue manufacturing nuclear fuel at the CFFF. The current

license authorizes WEC to recei ve, possess, use, and transfer SNM at the facility in accordance with the requirements of 10 CFR Part 70. The renewed license would provide the same

continued authorization to WEC.

The NRC staff concludes that the renewal of license SNM– 1107 involving the continued operation of the facility will not result in a significant impact to the environment. The facility already exists, and no substantial changes to the facility or its operation are associated with the license renewal. The Proposed Action can be considered a continuation of impacts and was evaluated based on impacts from past operations. Gaseous emissions and liquid effluents are within regulatory limits for nonradiological and radiological components. Public and occupation radiological dose exposures are below 10 CFR Part 20 regulatory limits.

The environmental impacts of the Proposed Action have been

evaluated in accordance with the requirements presented in 10 CFR Part 51. The NRC staff has determined that the Proposed Action would not have a significant impact on the human

environment. No EIS is warrant ed, and a FONSI is appropriate

in accordance with 10 CFR 51.31. N/A This EA incorporates the description of the CFFF site environment and safety analyses.



### Environmental Assessment for the Renewal of NRC License No. SNM-1097 for General Electric Company Nuclear Energy Production Fa cility, Wilmington, North Carolina (May 1997)

Current Licensee: GNF-Americas, LLC The proposed action in this 1997 EA is the renewal of NRC

Materials License SNM-1097. This would allow GE to continue producing UO 2 powder, pellets, and fuel rods, and continue support operations such as scrap recovery, waste disposal, laboratory analyses, and manufacturing technology development. In addition, GE would begin operation of a new dry conversion process (DCP) for converting UF 6 to UO 2 , which would eventually replace the current ammonium diuranate process. An interim pe riod of 1 year was estimated where both processes would be concurrently operated, allowing the DCP to gradually come up to production capacity.

Renewal of the GE materials license SNM-1097 would result N/A This EA incorporates the description of the GNF-A site environment and safety analyses.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

C-6 

### Table C-1. Other NEPA Documents Considered (continued)
Description of the Proposed Action ROD Comments

in continued release of ra dioactive and nonradioactive effluents. However, the impact to human health and the

environment from these releases has been determined to be insignificant, and GE has committed to effluent monitoring, environmental monitoring, and ALARA programs to ensure continued minimal impact. The small adverse impacts are outweighed by the positive impacts from continued operation of the facility, mainly from economic benefits to the surrounding community.



### Environmental Assessment for the Renewal of NRC License No. SNM-1227 for Siemens Power Corporation, Richland, Washington (June 1995)

Current Licensee: AREVA NC Inc. Note: A new EA to support a license renewal is currently being prepared The proposed action in this 1995 EA is the renewal of the SPC License SNM-1227 for 10 years with expansion of the DCP. With this renewal, SPC would expand the capacity of the DCP

to convert UF 6 to UO 2 and would continue to manufacture fuel assemblies for light-water reactors. N/A This EA incorporates the description of the AREVA

NC site environment and safety analyses.



### Environmental Assessment for Construction and Opera tion of a Physical Sciences Facility (PSF) at the Pacific Northwest National Laboratory, Richland, Washington (January 2007)
The proposed action was construction and operation of a large research complex on DOE property located about 1.6 kilometers (1 mile) from AREVA NC. N/A This EA reviewed and incorporated the cumulative impacts cited in this EA.

N/A = not applicable.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-1 

### APPENDIX D: RESPONSES TO COMMENTS ON THE DRAFT EAFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-2CommentNumberReviewer Name/CompanyCommentResponse1.United StatesEnrichmentCorporation(USEC)Typical truck shipments of 30B cylinders are 5 cylinders per trucknot 3 per truck as assumed in the study.Three cylinders per truck were assumed based on theassumptions contained in theFinal EnvironmentalImpact Statement for the Proposed NationalEnrichment Facility in Lea County, New Mexico(NRC 2005). In general, assuming three cylindersper truck instead of five cylinders per truck wouldresult in higher estimates of the number ofshipments, and correspondingly higher estimates ofincident-free transportation impacts and trafficfatalities. Similarly, the consequences of severetransportation accidents would be correspondinglyhigher if five cylinders per truck were assumed. Onthe other hand, the probability of a severetransportation accident would be correspondinglylower because fewer shipments would be required.Radiological accident risks would be about the sameif five cylinders per truck were assumed, because thehigher consequences of accidents would be offset bythe lower probability of accidents due to fewershipments.2.USEC Page 2, Line # 4: The comment is made that the enrichment of DU,NU and LEU is more attractive due to the price of uranium -wouldn't that really only apply to the enrichment of DU?Should this be "the enrichment of DU into NU and LEU is moreattractive"?Line #4 now reads: “Changes in the relative marketprices for NU, DU, LEU,and enrichment servicesmay affect the economic advantages to theenrichment of NU, DU, and LEU.”Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-3CommentNumberReviewer Name/CompanyCommentResponse3.USEC Page 5, Line # 16: Limiting the scope of the enrichment alternativeto only those tails cylinders exceeding 0.35% shouldbe reevaluatedsince the economics may favor additional processing under 0.35%.In addition, a large inventory of DU is just below 0.35% and shouldnot be excluded.The scope of this EA was established in accordancewith the Department’s current planning andconsideration of the potential sale or enrichment ofthose DU tails with an assay equal to or greater than0.35%235U. It should be noted that in implementingthe Proposed Action, DOEmay occasionally selectcylinders with slightly less than 0.35%235U (e.g., acylinder with 0.345 to 0.349%235U) for sale orenrichment in order to avoid extra handling ofcylinders (and the risks associated with suchhandling). Additional NEPA analyses would beconducted, as appropriate, if the Department’s futureplanning or proposed activities changed.4.USEC Page 10, Table 2.1: The number cylinders listed for the DU Feeddoes not agree with the MTU quantity. DOE DU Feed >0.35% isalmost entirely stored in 48G cylinders containing 8.4 - 8.6 MTUper cylinder. This would result in around 8,860 cylinders not10,776 cylinders as listed in the table. The MTU/cylinder appearsto be incorrectA corrected cylinder count was noted in theSummary, Tables 2-1 and 4-6, and Section 4.2.1.5.USEC Page 11, Line # 21: It would seem that the 2,000 MTU limit(corresponding to 10% of the US market) would apply to thequantity sold in a given year notnecessarily the amount produced.For example, 6,000 MTU might be produced in one year and soldover a 3 year period.Your comment is noted. DOE has issued a mitigationaction plan aimed at mitigating any potentiallysignificant impacts on the domestic uranium industryunder the Proposed Action.6.USEC Page 12, Line # 30: Almost all of the subject DU Feed cylindersare stored in "thin-wall" 48G cylinders. Due to recent changes inDOT requirements, all of these cylinders must be shippeddomestically in protective overpacks. The shipment of 48Gcylinders internationally is an unknown since it is not currentlyallowed. International shipments would require a more extensiveCertificate of Compliance andagreement of the competentauthorities or alternatively transferring the material into compliantcylinders. The international community utilizes the requirementsspecified by the IAEA for determination of transportation safety.Section 4.1 of the EA was modified to discusscylinder preparation activities based on thediscussion presented in Appendix E of the PEIS forDUF6(DOE 1999b). This included discussion of(1) placing nonconforming cylinders in protectivemetal overcontainers for shipment, and(2) transferring UF6from nonconforming cylindersto new cylinders. The impacts from these activitieswere added to Table 4-3 in the EA.7.USEC Page 19, Line # 17: The area is served by one interstate highway(1-24).Line # 17 now reads: “The area is served by oneinterstate highway (I-24).”8.USEC Page 19, Line # 22: The Paducah GDP has operated since 1952 Line # 22 now reads: “The Paducah GDP hasoperated since 1952.”Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-4CommentNumberReviewer Name/CompanyCommentResponse9.USEC Page 37, Line #’s 17 -19: Update: In 2007, seven companiesmarketed 85% of the estimated world uranium mine production of41,279 tonnes U308Source: WNA World Uranium MiningInformation Paper, July 2008The suggested text and reference has been inserted assuggested. Reference link:http://www.worldnuclear.org/info/inf23.html.10.USEC Page 38, Line # 31: Update: In 2007, the 104 US nuclear powerreactors generated a record 806.5 billion kWh and achieved anaverage 91.8% capacity factorSource: WNA Nuclear Power inthe USA Information Paper,January 2009The suggested text and reference has been inserted assuggested. Reference link:http://www.worldnuclear.org/info/inf41.html#capacity.11.USEC Page 39, Line # 6: Replace gross national product with grossdomestic product.Change made as suggested.12.USEC Page 55, Line # 29: ACP is scheduled to begin enrichmentoperations in 2010Change made as suggested.13.USEC Page 59, Line # 12: DOE tails >0.35% assay are almost entirelystored in 48G cylinders (not 48Y)The text of the EA was modified to state that DU isprimarily stored in 48G cylinders. A footnote wasadded to state that DU could also be stored in 12A,30A, 48H, 48O, 48OM, 48X, and 48Y cylinders.14.USEC Page 59, Line # 16: LEU with enrichment >1.0% is typicallytransported in 30B cylinders. There are no overpacks currentlylicensed to ship enriched product in 48 inch cylinders.The text of the EA was modified to state that LEUwith enrichment > 1 percent is typically shipped in30B cylinders, but that because most of the LEUfeed is currently stored in 48X and 48G cylinders,that the 48X cylinder was used to estimate impacts.Also, text was added to the impacts sections of theEA to provide the impacts of using 30B cylinders forthe LEU feed. See Comment # 6 for a discussion ofcylinder transfer impacts.15.AREVA We would like to express our appreciation to the Department fortheir efforts to clarify sales of inventory by issuing the ExcessUranium Inventory ManagementPlan, dated December 16, 2007.We believe that the Plan is a positive step toward effectivedisposition of excess inventories.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-5CommentNumberReviewer Name/CompanyCommentResponse16.AREVA We assume that all Department disposition of uranium (sales,barter, blend-down, loans. etc) fall within the annual limit of 10%of demand.The principles and framework for the disposition ofthe Department’s excess uranium are set forth in theSecretary’s Policy Statement on the Management ofDOE’s Excess Uranium Inventory, issued March2008 (Secretarial Policy Statement). The ProposedAction analyzed in this EA is consistent with theSecretarial Policy Statement. The Departmentanticipates that it may introduce into the market, inany given year, amounts up to 10 percent of the totalannual fuel requirementsof all licensed nuclearpower plants, or, in some years for certain specialpurposes such as the provision of initial core loadsfor new reactors, more than that amount. DOE hasissued a mitigation action plan aimed at mitigatingany potentially significant impacts on the domesticuranium industry under the Proposed Action.17.AREVA If the Department continues toconduct regular (semi annually, orquarterly) auctions of uranium material in the spot market, butsuspends such spot sales if the spot price falls below a reasonableminimum level related to US miners' total costs (plus reasonableprofit), it would effectively ensure that Department sales do notundermine the US miners' operations and investments, whileoptimizing return to the Department.Your comment is noted.18.AREVA Employing only spot market transactions would simplify theDepartment's objective evaluation of offers. Long term sales arecomplex, have multi-year impact on demand, and are lesstransparent than spot sales because long-term contracts can varygreatly in pricing methodology and terms and conditions.Your comment is noted.19.Global NuclearFuel (GNF)GNF-A very much looks forwardto this program because handlingUF6is a core competency for GNF-A and one that will serve theDOE well. We stand ready to assist you as matters progress.We have performed a comprehensive review of the Referencedocument and find no additional comments are warranted withrespect to the Wilmington site or our capabilities.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-6CommentNumberReviewer Name/CompanyCommentResponse20.LES On page 14, in 2.4.1 Other Enrichment Facilities there is an errorthat begins in line 33. The statement in the document, "however,France is the only foreign country where the necessary agreementsare already in place." There are in place existing internationalagreements between the United States and Euratom that wouldallow this work to be done in those European countries that haveenrichment capability. The draft environmental assessment shouldtake this agreement into account.This text now beginning on line 3 of page 15 hasbeen changed to read, “This EA presents impactsassociated with transportation to and from France asrepresentative of potential impacts associated withenrichment at any foreign facility. Potential impactswould vary in proportion to the distance traveled if afacility in another country was used. In addition tothe French facility in Tricastin, other foreignenrichment facilities are operating in variousEuropean countries, as well as Russia and Japan. Atthis time, the United States has 123 Agreements(Section 123 of the Atomic Energy Act of 1954) forPeaceful Nuclear Cooperation with multiplecountries such as Japan, and with countries that arepart of the European Atomic Energy Community(Euratom), including France (DOE 2008a). Otherforeign enrichment facilities could be considered inthe future if the necessary agreements wereimplemented.”21.Commonwealthof Kentucky(Division ofWater)This project has the potential to be a massive environmentalproblem. The Paducah Gaseous Diffusion Plant does not have agood track record with discharge limits and bioassay tests.Your comment is noted. The purpose of theenvironmental assessment is to disclose and describepotential environmental impacts from a proposedactivity. The potential impacts of all aspects ofenrichment operations and the conversion of DU tailshave been previously analyzed in existing NEPAdocuments. See Section 3.1.1, Section 4.1, andTable 4.3 for specific discussions related to thePaducah site. The EA assumes that operations at thePaducah Gaseous Diffusion Plant and the PaducahDUF6Conversion Facility would be conducted incompliance with all applicable federal, state, andlocal regulations. Please see EA reference DOE2007b for information regarding environmentalcompliance, monitoring, and permits at the DOEPaducah site.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-7CommentNumberReviewer Name/CompanyCommentResponse22.Commonwealthof Kentucky(Division ofWater)Water Quality Management - This will not directly impact watermanagement planning, floodplain construction or water withdrawalpermitting.Your comment is noted.23.Commonwealthof Kentucky(Division ofWater)The Division of Enforcement does not object to the projectproposed by the applicant.Your comment is noted.24.Commonwealthof Kentucky(Division for AirQuality)The Division for Air Quality would like to stress the importance ofthe following comments since thePaducah area is borderline forPM2.524-hour standard nonattainment.Kentucky Division for Air Quality Regulation 401 KAR 63:010Fugitive Emissions states that no person shall cause, suffer, orallow any material to be handled, processed, transported, or storedwithout taking reasonable precaution to prevent particulate matterfrom becoming airborne. Please note the Fugitive Emissions FactSheet located athttp://www.air.ky.gov/homepage_repository/eClearinghouse.htm.Additional requirements include the covering of open bodiedtrucks, operating outside the workarea transporting materials likelyto become airborne, and that no one shall allow earth or othermaterial being transported by truck or earth moving equipment tobe deposited onto a paved street or roadway.Kentucky Division for Air Quality Regulation 401 KAR 63:005states that open burning is prohibited. Open Burning is defined asthe burning of any matter in such a manner that the products ofcombustion resulting from the burning are emitted directly into theoutdoor atmosphere without passing through a stack or chimney.However, open burning may be utilized for the expressed purposeslisted on the Open Burning Fact Sheet located athttp://www.air.ky.gov/homepage_repository/e-Clearinghouse.htm.The EA assumes that operations at the PaducahGaseous Diffusion Plant and the Paducah DUF6Conversion Facility would be conducted incompliance with all applicable federal, state, andlocal regulations, including those related to PM2.5,fugitive emissions, transport of material in openbodied trucks, and open burning. See Section 3.1.1,Section 4.1, and Table 4.3 for specific discussionsrelated to the Paducah site. Please see EA referenceDOE 2007b for information regarding environmentalcompliance, monitoring, and permits at the DOEPaducah site.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-8CommentNumberReviewer Name/CompanyCommentResponse25.Commonwealthof Kentucky(Division for AirQuality)The Division also suggests an investigation into compliance withapplicable local government regulations.The EA assumes that operations at the PaducahGaseous Diffusion Plant and the Paducah DUF6Conversion Facility would be conducted incompliance with all applicable federal, state, andlocal regulations. Please see EA reference DOE2007b for information regarding environmentalcompliance, monitoring, and permits at the DOEPaducah site.26.UraniumProducers ofAmericaUPA members strongly believe that a robust domestic uraniumproducing industry is critical to our country's energy independenceand national security. Presentdomestic production of naturaluranium is simply too low to achieve these goals.Your comment is noted.27.UraniumProducers ofAmericaThe DOE must make any disposition of excess governmentinventories in such a manner asto not impactthe commercialuranium market and to not prevent domestic fuel suppliers fromgaining the necessary investment to reestablish a successfuluranium producing industry that will assure the nation's energyindependence in the nuclear arena.The principles and framework for the disposition ofthe Department’s excess uranium are set forth in theSecretarial Policy Statement issued March 2008. Inaddition, DOE has issued a mitigation action planaimed at mitigating any potentially significantimpacts on the domestic uranium industry under theProposed Action.28.UraniumProducers ofAmericaUPA supports the DOE's December 16, 2008 Excess UraniumInventory Plan ("Plan"). The Planincorporates a nuclear industryconsensus for introducing government excess uranium inventoriesinto the commercial market. The Plan's adoption of a gradualintroduction of excess material will lessen the impact of suchexcess uranium disposition on domestic producers. The Planproperly recognizes the limited near term spot market availabilityfor such excess material. The Planalso recognizes the benefits oflong-term contracts to reduce theadverse impacts of governmentsales. Finally, the Plan acknowledges the necessity to conduct acomprehensive Secretarial Determination of the potential adverseimpact to the domestic fuel suppliers prior to each government saleor disposition of excess inventory material.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-9CommentNumberReviewer Name/CompanyCommentResponse29.UraniumProducers ofAmericaAt page 81 of the Environmental Assessment, it is noted that DOE'sauthorization to sell the government's excess uranium under theAtomic Energy Act of 1954, as amended, is derived from Section3112(d) of the 1996 USEC Privatization Act, Public Law 104-134(42 U.S.C. 2297h, et .seq.). This Act requires a SecretarialDetermination that any such sale of excess uranium inventories willnot have an "adverse material impact" on the domestic mining,conversion and enrichment industry. UPA members, as potentiallyimpacted stakeholders from such sales, urge DOE to make therequired "determinations" more open and transparent than thesedeterminations have been in the past.In Section 4.3.2 of the EA, DOE explains itsauthority to sell excess uranium, noting that it isauthorized to sell its excess uranium under theAtomic Energy Act of 1954, and consistent with theprovisions of the 1996 United States EnrichmentCorporation Privatization Act, Public Law 104-134.Section 3112(d) of that Act stipulates that, amongother things, prior to selling NU and LEU from theDepartment’s excess inventory, the Secretary ofEnergy must determine that the sale will not have anadverse material impact on the domestic uraniummining, conversion, and enrichment industry.Consistent with the Secretarial Policy Statement,transactions involving non-U.S. Government entitieswill be undertaken in a transparent and competitivemanner, unless the Secretary of Energy determines inwriting that overriding Department mission needsdictate otherwise.30.UraniumProducers ofAmericaInput from the impacted stakeholders would provide theDepartment with market information and potential impacts ofwhich the DOE may be unaware. For example, DOE conducted asale of excess inventories in August 2006, that resulted in materialadverse impacts on the domestic uranium industry. The sale into thespot market took place during August, a known slow period foruranium sales in a calendar year. The sale also was conducted in amanner that failed to achieve fairmarket value for the materials,thus contrary to the requirementsof the Privatization Act. TheAugust 2006 sale, while relatively small in pounds of uranium, hada material adverse impact on the price of uranium and the ability ofdomestic producers to obtain necessary investment necessary toproceed with new operations. The Secretarial Determination andconduct of this sale was flawed. In order to avoid adverse impactsfrom future inventory sales, DOE should conduct futuredeterminations with more transparency and input from affectedstakeholders.Your comment is noted. Consistent with theSecretarial Policy Statement, transactions involvingnon-U.S. Government entities will be undertaken in atransparent and competitive manner, unless theSecretary of Energy determines in writing thatoverriding Department mission needs dictateotherwise.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-10CommentNumberReviewer Name/CompanyCommentResponse31.UraniumProducers ofAmericaAt pages 81-82 of the Environmental Assessment, it is noted thatDOE commissioned a report from Energy Resources International,Inc., entitled Quantification of the Potential Impact on CommercialNuclear Fuel Markets of the Saleby the U.S. Government ofSelected Inventory. The ERI assumed sales by DOE ofapproximately 10 percent of the average annual U.S. requirementsfor uranium concentrates in its analysis. UPA disagrees with ERI'sanalysis that such sales would not have an adverse impact,particularly on producers that are working to bring new productionsites online through the rigorous permitting process required fortoday's uranium mines and mills.Specifically, contrary to ERI'sanalysis, planned operations do not have committed productionlevels with forward future sales.Information obtained and used by ERI in its analysisindicates that some level of forward sales has beenestablished by the domestic uranium productionindustry. DOE has issued a mitigation action planaimed at mitigating any potentially significantimpacts on the domestic uranium industry under theProposed Action.32.UraniumProducers ofAmericaHowever, DOE's December 16,2008 Plan mitigates UPA'sconcerns with ERI's analysis. The Plan properly recognizes theimportance of smaller inventory disposition sales in the near termand does not contemplate assumed sales of 10 percent of theaverage U.S. requirements for uranium concentrates in the nearterm.Your comment is noted. DOE has issued a mitigationaction plan aimed at mitigating any potentiallysignificant impacts on the domestic uranium industryunder the Proposed Action.33.UraniumProducers ofAmericaDOE’s Excess Uranium Inventory Management Plan doesincorporate the Industry Consensussuggestion that the Departmentconduct sales to U.S. utilities requiring initial cores for new builtreactors. These initial core sales will meet the Department's nearterm sales needs and are endorsed by UPA.Your comment is noted.34.UraniumProducers ofAmericaUPA agrees with ERI at page 82 of the Environmental Assessmentthat the perceived uncertainty in the investment communitiesconcerning future DOE disposition of excess uranium material hascreated a perception of risk for investment in new uraniumproduction operations. It is imperative to generate continued newinvestment for new uranium operations that the Plan be followed inthe future for disposition of government uranium materials.Your comment is noted.35.UraniumProducers ofAmericaThe ERI report fails to adequately consider the potential impacts ofDOE inventory disposition sales on the ability of new producers toacquire the necessary investment to permit and construct newdomestic uranium mines and mills.Information obtained and used by ERI in its analysisindicates that some level of forward sales has beenestablished by the domestic uranium productionindustry. In addition, DOE has issued a mitigationaction plan aimed at mitigating any potentiallysignificant impacts on the domestic uranium industryunder the Proposed Action.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-11CommentNumberReviewer Name/CompanyCommentResponse36.UraniumProducers ofAmericaNew U.S. uranium production is critical for our nation's nationalsecurity and energy independence. However, the DOE Planaddresses this impact in a more positive manner, by ramping upsales of uranium materials over time.Your comment is noted.37.UraniumProducers ofAmericaUPA agrees with the EnvironmentalAssessment to the extent that itrecognizes that the demand for uranium is growing and there is aneed for new domestic production.The nation's reactors are overreliant on foreign uranium and this is shortsighted policy. Newdomestic mines can compete with foreign production and should beencouraged.Your comment is noted.38.UraniumProducers ofAmericaUPA agrees with the statement atpage 82 of the EnvironmentalAssessment that domestic uranium producers should be able to selltheir annual production in a competitive market. It must berecognized, however, that in these difficult economic times, theinvestment necessary to build new uranium production facilitiescan be impeded by government sales. Future government sales ofexcess uranium inventories must becarefully scrutinized in theSecretarial Determinations and not simply subjected to a cursoryreview of market impacts. Again,failure to conduct stringent,transparent determinations will result in less than fair market valuesfor excess government uranium material and will adversely impactthe domestic production industry.DOE has issued a mitigation action plan aimed atmitigating any potentially significant impacts on thedomestic uranium industry under the ProposedAction. Consistent with the Secretarial PolicyStatement, transactions involving non-U.S.Government entities will be undertaken in atransparent and competitive manner, unless theSecretary of Energy determines in writing thatoverriding Department mission needs dictateotherwise.39.UraniumProducers ofAmericaThe Environmental Assessment concludes that sales of governmentexcess uranium inventories are expected to have small impacts onthe uranium industries. UPA believes that the sales on a schedulelike that set forth in the DOE Plan, together with careful,transparent scrutiny applied inthe Secretarial Determinationaccompanying these sales can havea lesser impact than simplyselling 10 percent of the total annual fuel requirements of alllicensed U.S. nuclear power plants. UPA urges DOE to follow itsPlan.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-12CommentNumberReviewer Name/CompanyCommentResponse40.Commonwealthof Virginia(Department ofEnvironmentalQuality [DEQ])Water Quality and Wetlands. The EA (pages 44, 48, 54 and 86)addresses the potential environmental impacts to surface waters,including wetlands, during the construction, operation anddecommissioning of facilities. However, the EA does not addressthe environmental impacts to surface waters in the case of anaccident or act of terrorism.Previous analyses of transportation accident impactshave shown that accident impacts are larger whenradioactive material is released to the atmosphere asopposed to being released to surface water, due tothe relative importance of the inhalation pathwayversus the drinking water or aquatic food pathwaysas routes of exposure. This text was added inSection 4.2.1. Estimatedimpacts to surface water,groundwater, soil, and ecology from accidents havebeen established in DOE 2004a and DOE 2004b andare discussed in Table 4-3 and Section 4.2.1 of theEA.41.Commonwealthof Virginia (DEQ)The EA does not discuss the off-loading or handling requirementsfrom vessel to rail or truck.The impacts discussed in Section 4.2.1.3 include theimpacts from port operations. Port operations and theimpacts from port operations are also discussed inDOE 1994 and DOE 1999a. A summary of shippingrequirements for UF6is contained in USEC 2006.More details can be found in U.S. Department ofTransportation regulations such as 49 CFR Parts 173,174, 176, 177, and 178, and U.S. Nuclear RegulatoryCommission regulations such as 10 CFR Part 71.42.Commonwealthof Virginia (DEQ)The DEQ Office of Wetlands and Water Protection states that theeffects of a uranium spill in Virginia withinsurface waters,including wetlands, would depend on the material released, locationof the accident and atmospheric conditions at the time.Previous analyses of transportation accident impactshave shown that accident impacts are larger whenradioactive material is released to the atmosphere asopposed to being released to surface water, due tothe relative importance of the inhalation pathwayversus the drinking water or aquatic food pathwaysas routes of exposure. This text was added inSection 4.2.1. Estimatedimpacts to surface water,groundwater, soil, and ecology from accidents havebeen established in DOE 2004a and DOE 2004b andare discussed in Table 4-3 and Section 4.2.1 of theEA43.Commonwealthof Virginia (DEQ)Should a uranium spill occur in Virginia within surface waters,including wetlands, appropriate cleanup and remediation would berequired. Immediate notification ofa hazardous material incidentby a carrier is required at the earliest practical moment to theDepartment of Emergency Management or local emergencyDOE Order 460.2A requires that DOE organizationsconduct operations in compliance with all applicableinternational, federal, state, local, and tribal laws,rules, and regulations governing materialstransportation that are notinconsistent with FederalFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-13CommentNumberReviewer Name/CompanyCommentResponseresponders.regulations. This would include U.S. Department ofTransportation hazardousmaterials regulationscontained in 49 CFR 171 through 180, Federal MotorCarrier Safety Administration regulations containedin 49 CFR 395 and 397, and U.S. NuclearRegulatory Commission regulations contained in 10CFR 71, as applicable. DOE Manual 460.2-1Aestablishes a set of standard transportation practicesfor DOE to use in planning and executing off-siteshipments of radioactive materials. These practicesestablish a standardized process and framework forinteracting with state, tribal, and local authorities,other federal agencies, andtransportation contractorsand carriers regarding DOE radioactive materialshipments. Practices are described for the followingtopics:•Transportation planning—the transportationplanning activities that take place after theneed for shipment has been identified;•Emergency planning—DOE emergencyplanning activities with state and tribaljurisdictions;•Projected shipment planning information—provision of information regarding projectedshipments;•Routing—practices to identify and selecttransportation routes;•Security—actions taken to ensure the securityof shipments;•Carrier/driver requirements—practices toensure that shipments use high-quality carriersand drivers;•Shipment prenotification—near-termnotification activities for pending shipments;•Transportation operational contingencies—operational contingencies that may interruptFinal Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-14CommentNumberReviewer Name/CompanyCommentResponsenormal transport operations;•Tracking—DOE practicesfor tracking thelocation of shipments and facilitatingcommunication with thedrivers/crew of thevehicles;•Inspections—inspections of shipments,including verifications of vehicleroadworthiness and radiological condition ofcontainers loaded on the vehicles;•Safe parking—the criteria to be used inselecting appropriate parking locations in theevent that transportation operationalcontingencies occur;•Emergency notification—the process DOEuses to notify state and tribal officials, afterDOE itself has received notification, of atransportation emergency;•Emergency response—DOE response to atransportation emergency;•Recovery and cleanup—post-emergencyactions taken to recover and clean up from anaccident or incident.In addition, U.S. Department of Transportationregulation 49 CFR 171.15 contains requirements fornotification of transportation incidents involvinghazardous materials.This text has been added to Section 4.2.1.44.Commonwealthof Virginia (DEQ)If the size or scope of the project changes, additional review by theDEQ Office of Wetlands and Water Protection may be necessary.Such changes to the DOE Proposed Action couldtrigger an additional NEPA review. The scope of thatreview and the nature of stakeholder involvementwould vary depending upon the nature of thechanges to the Proposed Action.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-15CommentNumberReviewer Name/CompanyCommentResponse45.Commonwealthof Virginia (DEQ)The Department of Conservation and Recreation (DCR) performeda 2-mile radius search from the representative rail and trucktransportation routes displayed in the EA (figure 4-1, page 58)According to the information currently in DCR's files, there areseveral occurrences of natural heritage resources that couldpotentially be impacted. Also there are several Threatened andEndangered Species Waters with the 2-mile radius.As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, natural heritageresources and Threatened and Endangered SpeciesWaters would be considered in the routing process,to the extent required by regulations and aspracticable.46.Commonwealthof Virginia (DEQ)The routes pass through extensive areas of karst topography inWythe, Bland and Scott counties as well as some other karst areasin Russell and Wise counties. Anyaccident involving the release ofhazardous materials, such as uranium, could contaminate karstaquifers along the route. Thesekarst aquifers supply water forpublic drinking water supplies and also provide water for domesticand agricultural users.As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, karst topography wouldbe considered in the routing process, to the extentrequired by regulations and as practicable.47.Commonwealthof Virginia (DEQ)Threatened and Endangered Plant and Insect Species. Under aMemorandum of Agreement established between the VirginiaDepartment of Agriculture and Consumer Services (VDACS) andDCR, DCR has the authority to report for VDACS on state-listedplant and insect species. DCR found that the proposed activity mayimpact several state-protected plants and deferred to VDACS,which has regulatory authority to conserve rare and endangeredplant and insect species through the Virginia Endangered Plant andInsect Species Act. However, VDACS did not respond to DEQ'srequest for comments.As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, state-protected plantswould be considered in the routing process, to theextent required by regulations and as practicable.48.Commonwealthof Virginia (DEQ)Conservation sites that are located around natural heritage resourcesshould be incorporated into emergency response plans developedfor the transportation corridors. Conservation sites are areas locatedaround one or more rare plant, animal or natural communities andare designed to include the species and its habitat in order to allowfor the species conservation. Conservation sites are given abiodiversity significance ranking based on the rarity, quality andnumber of occurrences they contain on a scale of 1-5, 1 being themost significant.The development of local emergency response plansthat incorporate entities such as conservation sitesare the responsibility of state and local public safetyofficials.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-16CommentNumberReviewer Name/CompanyCommentResponse49.Commonwealthof Virginia (DEQ)DCR strongly suggests that hydrologic investigations be performedalong the course of the transportation route where it passes throughkarst terrain or is upstream from karst terrain in order to determinethe boundaries and extent of these karst groundwater basins, inorder to facilitate required emergency responses and better enablethe mitigation work that would follow any accidents resulting in therelease of hazardous materials. DCR recommends the investigationsinclude dye tracer studies to determine the associated groundwaterflow paths and the identification of sinkholes and other associatedkarst features including springs andwells that could be affected byspills of hazardous materials along the primary transportationcorridors.As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, karst topography wouldbe considered in the routing process, to the extentrequired by regulations and as practicable. Becauseof the low probability of an accident involving arelease of UF6occurring in an area containing karsttopography, hydrologic investigations would not beconducted unless such anaccident actually occurred.50.Commonwealthof Virginia (DEQ)Coordinate with the U.S. Fish and Wildlife Service (FWS),Virginia Department of Game and Inland Fisheries (DGIF) andVDACS to ensure compliance withprotected species legislation.As discussed in the response to Comment # 43, DOEManual 460.2-1A establishes a standardized processand framework for interacting with state, tribal, andlocal authorities, and other federal agencies. Thiswould include coordination with the U.S. Fish andWildlife Service, the Virginia Department of Gameand Inland Fisheries, and VDACS, as appropriateand required by regulations, to ensure compliancewith protected species legislation.51.Commonwealthof Virginia (DEQ)Implement safety measures and notify localities of when and wherethe transportation of nuclear waste will occur.As discussed in the response to Comment # 43,shipment prenotification is one of the practicesestablished in DOE Manual 460.2-1A. Several of thepractices established in the manual relate to safetymeasures, such as routing, carrier/driverrequirements, and inspections.52.Commonwealthof Virginia (DEQ)According to DGIF's records, there are a variety of listed speciesknown from these regions. However, based on the informationprovided, new construction and/or impacts to wildlife resourcesunder DGIF's jurisdiction are not proposed.The EA does not contemplate any new construction.53.Commonwealthof Virginia (DEQ)Provided all nuclear material issafely contained and appropriatelyhandled and transport on existingtransportation infrastructure canbe accomplished in a safe manner and is not subject totransportation accident, direct attack, and/or other incident thatwould result in impacts to wildlife resources under DGIF'sjurisdiction, DGIF does not anticipate that the project would resultin adverse impact to such resources.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-17CommentNumberReviewer Name/CompanyCommentResponse54.Commonwealthof Virginia (DEQ)DGIF recommends that the applicant coordinate with the U.S. Fishand Wildlife Service regarding potential impact to federally-listedspecies.As discussed in the response to Comment # 43, DOEManual 460.2-1A establishes a standardized processand framework for interacting with state, tribal, andlocal authorities, and other federal agencies. Thiswould include coordination with the U.S. Fish andWildlife Service, as appropriate and required byregulations, regarding the potential impact tofederally listed species.55.Commonwealthof Virginia (DEQ)Solid and Hazardous Wastes andHazardous Materials. The DEQWaste Division recommends thatfor each area in Virginia wheretransportation of nuclear materials will occur, DOE should conductan environmental investigation on and near the work area toidentify any solid orhazardous waste sites or issues before the workcommences. The investigation should include a search of wasterelated databases.As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, the presence of solid orhazardous waste sites or issues would be consideredin the routing process, to the extent required byregulations and as practicable.56.Commonwealthof Virginia (DEQ)Air Quality Impacts. The impact of the proposed project to disposeexcess depleted uranium on Virginia air quality will be emissionsarising from the use of truck, rail or barge transportation in theevent the Portsmouth site is utilized. Incremental increase in thetransportation load due to this project is not likely to be significantenough to have any perceptible impact on air quality. In the eventof a severe rail or road accident, particle pollution may temporarilyincrease due to a collision, but its effect is far less than the radiationeffects outlined in the EA.The analysis in the EA indicates that the transport ofUF6using existing transportation infrastructurewould have minimal air quality impacts.57.Commonwealthof Virginia (DEQ)Transportation Impacts. Transport by Barge/Ship. The Virginia PortAuthority (VPA) states that Virginia International Terminals (VIT),the marine terminal operator for the Virginia Port Authority, isprepared to accept Class 7 hazardous materials at the Virginia PortAuthority terminals in Norfolk, Portsmouth and Newport News.VIT will accept all types of Class 7 [hazardous materials]; however,if the transport index is more than 10 and a route control isrequired, the shipment will be considered Certain Dangerous Cargoand additional handling charges will be required. The VPAwelcomes opportunity to receive additional freight and is preparedto discuss future shipment options with DOE.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-18CommentNumberReviewer Name/CompanyCommentResponse58.Commonwealthof Virginia (DEQ)Transportation Impacts. Transport by Trucks. The VirginiaDepartment of Transportation (VDOT) has reviewed theinformation provided for the above referenced project andcommented on the potential for impacts to the existing andproposed transportation facilities. In the southwestern area of thestate, the primary route identified for truck shipments is Interstate77 (Figure 4.1, Page 58) which requires passage through twotunnels (Big Walker Mountain andEast River Tunnel). At present,these tunnels have no restrictionsfor hazmat loads; however, anincreased transportation security issue is generated due to terrorismduring passage. While it may be a matter of national security, earlynotification and preparation will becritical to ensure safe passage.In addition, the potential risk from radiological release in aconfined space should be considered in the event an accident ormechanical malfunction occurs in the tunnels.As discussed in the response to Comment #43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentsare made through Virginia, emergency planningissues would be considered in the routing process, tothe extent required by regulations and as practicable.59.Commonwealthof Virginia (DEQ)Transportation Impacts. The transport of these hazardous materialsthrough the rural regions of Virginia poses an increased risk ofexposure to emergency response workers in the event of anaccident. Education and training of these responders is a key riskfactor in the event of an accident. Consideration should be given toproviding specific training forthe volunteer agencies. In lieu ofadditional training, DOE should provide a traveling Hazmat Teamto monitor and secure each of these loads.The DOE Office of Environmental ManagementTransportation Emergency Preparedness Programconducts Modular Emergency ResponseRadiological Transportation Training. Training isprovided throughout the year at locations across theUnited States. DOE does not anticipate the need toprovide traveling Hazmat Teams .60.Commonwealthof Virginia (DEQ)The final issue to address in the southwestern corridor of the state isrelated to weather conditions on the identified route. This section ofInterstate 77 from Interstate 81 to North Carolina State Lineexperiences adverse wind and fog conditions through each seasonof the year. Potential exists for increased accidents due to theseconditions and should be accounted for during load transport.The accident rates used to estimate accident risksinclude accidents caused by bad weather.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-19CommentNumberReviewer Name/CompanyCommentResponse61.Commonwealthof Virginia (DEQ)In the more urban areas of the state, there is an increased potentialfor congestion if oversized trucks will be utilized for transport ofthe material. The EA did not clearly state whether any effort orcoordination beyond that normally required for the transport ofhazardous materials will be required for these shipments. Suchconsiderations as escort vehicles, routing of oversize or overweightvehicles, incident response, security for sensitive cargo, andcoordination with federal officials may already be covered inhazardous material transport regulations but any efforts orcoordination beyond that already required should be mentioned inthe final document.It is not anticipated that shipments of UF6would bemade using overweight or oversized vehicles, or thatseparate escort vehicles would be required. It is notanticipated that coordinationbeyond that required byU.S. Department of Transportation regulations wouldbe required for the UF6shipments.62.Commonwealthof Virginia (DEQ)Should the scope of the project change, DRPT would like theopportunity to provide additional comments.Such changes to the DOE Proposed Action couldtrigger an additional NEPA. The scope of that reviewand the nature of stakeholder involvement wouldvary depending upon the nature of the changes to theProposed Action.63.Commonwealthof Virginia (DEQ)Prior to the transportation of hazardous waste through Virginia,notify the appropriate localities and contact the VirginiaDepartment of Emergency Management at (804) 897-6500.As discussed in the response to Comment #43,shipment prenotification is one of the practicesestablished in DOE Manual 460.2-1A..64.Commonwealthof Virginia (DEQ)In the final document, DOE should address potential impacts on thetransportation network or reference other documents that includethis information, address potential human health impacts to publicand maintenance staff in tunnels in the event there is radiologicalrelease; account for adverse windand fog conditions through eachseason and the potential for increased accidents when transportinguranium; and include a description of coordination with escortvehicles, routing of oversize oroverweight vehicles, incidentresponse, security for sensitivecargo and federal officials.See responses to Comments ## 43, 58, 60, and 61.65.Commonwealthof Virginia (DEQ)The EA (pages 58-66) seems to indicate that the potential hazardsfrom truck shipment to highway work zone crews and the generalpopulace are negligible. VDOT suggests including a clear statementto that effect in the final document.As shown by the analyses presented in the EA, theimpacts to workers and members of the public aresmall, ranging from 0.22 to 2.5 total fatalities fortruck shipments.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-20CommentNumberReviewer Name/CompanyCommentResponse66.Commonwealthof Virginia (DEQ)Consider providing specific training for first responders or providea traveling hazmat team to monitor and secure each load.The DOE Office of Environmental ManagementTransportation Emergency Preparedness Programconducts Modular Emergency ResponseRadiological Transportation Training. Training isprovided throughout the year at locations across theUnited States. DOE does not anticipate the need toprovide traveling hazmat teams.67.Commonwealthof Virginia (DEQ)Health Impacts. The VDH Division of Radiological HealthProgram states that the Department of Energy's (DOE) draft EAdoes not appear to create any significant radiological risk to theCommonwealth of Virginia. The proposed plan describestransportation of uranium in various forms through thesouthwestern portion of the Commonwealth either by truck onInterstate 77 or by rail.Your comment is noted.68.Commonwealthof Virginia (DEQ)The radioactivity of the proposedDOE shipments is less hazardousthan many of the radioactive materials that are currently beingtransported through Virginia. The Commonwealth has notexperienced any significant transportation accidents involvingradioactive materials for about two decades.Your comment is noted.69.Commonwealthof Virginia (DEQ)VDH is supportive of a DOE conclusion for issuing a Finding ofNo Significant Impact.Your comment is noted.70.Commonwealthof Virginia (DEQ)Geologic and Mineral Resources. The Department of Mines,Minerals, and Energy (DMME) does not anticipate an impact tomineral resources. The geology of southwestern Virginia (and theCoastal Plain, if a shipment is made through Norfolk) is variableand could be a factor in limiting or increasing the scope of animpact from a rail or truck accident. The depth to bedrock,permeability of bedrock or sediment, orientation of bedding orfractures, presence of karst features, and topographic setting couldbe additional factors.Your comment is noted.71.Commonwealthof Virginia (DEQ)The Hampton Roads Planning District Commission states that theproposed plans are generally consistent with local and regionalplans and policies.Your comment is noted.72.Commonwealthof Virginia (DEQ)The Commonwealth has no objection to the proposed disposition ofuranium or the subsequent transportation of uranium through orfrom Virginia provided that all applicable state and federal laws andregulations are followed.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-21CommentNumberReviewer Name/CompanyCommentResponse73.Commonwealthof Virginia (DEQ)If an accident or an intentional destructive act happens, DOE mustnotify the appropriate emergency officials and implement effectivecleanup efforts.The EA assumes that during the transport of UF6, allapplicable U.S. Department of Transportation andstate regulations would be followed, including thoseinvolving notification after accidents or intentionaldestructive events. If such an accident or intentionaldestructive event occurred, the affected area wouldbe remediated, as determined to be appropriate.74.Commonwealthof Virginia (DEQ)The Commonwealth strongly encourages DOE to consider and planfor mitigation of potential impacts on Virginia's natural resources,including karst topography and protected species, in the event of anaccident or an act of sabotage or terrorism.As discussed in the response to Comment #43,transportation planning, emergency planning, andsecurity are three of the practices established in DOEManual 460.2-1A. Accidents and acts of sabotage orterrorism would be considered in this planning to theextent required by regulations.75.Commonwealthof Virginia(DEQ), WaterDivisionThere are no fuel fabrication facilities in Virginia and because theProposed Action involves no new construction in Virginia, therewould be no potential for the Proposed Action to impact currentland use; biotic communities; cultural, historical, or archaeologicalresources; visual resources; ambient noise levels; threatened orendangered species or their critical habitats; wetlands; orfloodplains.Your comment is noted.76.Commonwealthof Virginia(DEQ), WaterDivisionThe report does not discuss the off-loading or handlingrequirements from vessel to rail or truck.The impacts discussed in Section 4.2.1.3 include theimpacts from port operations. Port operations and theimpacts from port operations are also discussed inDOE 1994 and DOE 1999a. A summary of shippingrequirements for UF6is contained in USEC 2006.More details can be found in U.S. Department ofTransportation regulations such as 49 CFR Parts173,174, 176, 177, and 178, and U.S. Nuclear RegulatoryCommission regulations such as 10 CFR Part 71.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-22CommentNumberReviewer Name/CompanyCommentResponse77.Commonwealthof Virginia(DEQ), WaterDivisionThe report does [not] discuss potential environmental impacts tosurface waters including wetlandsshould a traffic accident or spilloccur.Previous analyses of transportation accident impactshave shown that accident impacts are larger whenradioactive material is released to the atmosphere asopposed to being released to surface water, due tothe relative importance of the inhalation pathwayversus the drinking water or aquatic food pathwaysas routes of exposure. This text was added inSection 4.2.1. Estimatedimpacts to surface water,groundwater, soil, and ecology from accidents havebeen established in DOE 2004a and DOE 2004b andare discussed in Table 4-3 and Section 4.2.1 of theEA.Also, see response to Comment # 43.78.Commonwealthof Virginia(DEQ), WaterDivisionShould a uranium spill occur in Virginia within surface waters,including wetlands, appropriate clean up and remediation would berequired. The consequences of such a release would depend on thematerial released, location of the accident, and atmosphericconditions at the time. Immediate notification of a hazardousmaterial incident by a carrier isrequired at the earliest practicalmoment to the Department of Emergency Management or localemergency responders.See response to Comment # 43.79.Commonwealthof Virginia(DEQ), WaterDivisionShould the size or scope of the project change, additional reviewmay be necessary.Such changes to the DOE Proposed Action couldtrigger an additional NEPA review. The scope of thatreview and the nature of stakeholder involvementwould vary depending upon the nature of thechanges to the Proposed Action.80.Commonwealthof Virginia,Virginia PortAuthority (VPA)Virginia International Terminals, Inc., the marine terminal operatorfor the Virginia Port Authority, is prepared to accept class 7hazardous materials at the VirginiaPort Authority terminals, inNorfolk, Portsmouthand Newport News. VIT will accept all typesof class 7 hazardous material; however, if the transport index isover 10 and a route control is required the shipment will beconsidered Certain Dangerous Cargo and additional handlingcharges will be required. The Virginia Port Authority welcomesopportunity to receive additional freight and is prepared to discussfuture shipment options with the Department of Energy.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-23CommentNumberReviewer Name/CompanyCommentResponse81.Commonwealthof Virginia,Department ofTransportationIn the southwestern area of the state, the primary route identifiedfor truck shipments is Interstate 77 (Figure 4.1 Page 58) whichrequires passage through two tunnels (Big Walker Mountain andEast River Tunnel). At present, these tunnels have no restrictionsfor hazmat loads; however, anincreased transportation securityissue is generated due to terrorism during passage. While it may bea matter of national security, early notification andpreparation willbe critical to ensure safe passage. In addition, the potential riskfrom radiological release in a confined space should be considered,should an accident or mechanicalmalfunction occur in the tunnels.Potential human health impacts to public and maintenance staff inthese facilities should be reviewed and determined.As discussed in the response to Comment #43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentsare made through Virginia, emergency planningissues would be considered in the routing process, tothe extent required by regulations and as practicable.82.Commonwealthof Virginia,Department ofTransportationThe transport of these hazardous materials through the rural regionsof Virginia poses an increasedrisk of exposure to emergencyresponse workers in the eventof an accident. Education andtraining of these responders is a key risk factor in the event of anaccident. Consideration should be given to providing specifictraining for the volunteer agencies. In lieu of additional training,DOE should provide a traveling Hazmat Team to monitor andsecure each of these loads.The DOE Office of Environmental ManagementTransportation Emergency Preparedness Programconducts Modular Emergency ResponseRadiological Transportation Training. Training isprovided throughout the year at locations across theUnited States. DOE does not anticipate the need toprovide traveling Hazmat Teams .83.Commonwealthof Virginia,Department ofTransportationThe final issue to address in the southwestern corridor of the state isrelated to weather conditions on the identified route. This section ofInterstate 77 from Interstate 81 to North Carolina State Lineexperiences adverse wind and fog conditions through each seasonof the year. Potential exists for increased accidents due to theseconditions and should be accounted for during load transport.The accident rates used to estimate accident risksinclude accidents caused by bad weather.84.Commonwealthof Virginia,Department ofTransportationIn the more urban areas of the state, there is an increased potentialfor congestion if oversized trucks will be utilized for transport ofthe material. The EA did not clearly state whether any effort orcoordination beyond that normally required for the transport ofhazardous materials will be required for these shipments. Suchconsiderations as escort vehicles, routing of oversize or overweightvehicles; incident response, security for sensitive cargo, andcoordination with Federal officials may already be covered inhazardous material transport regulations but any efforts orcoordination beyond that already required should be mentioned inthe EA.It is not anticipated that shipments of UF6would bemade using overweight or oversized vehicles, or thatseparate escort vehicles would be required. It is notanticipated that coordinationbeyond that required byU.S. Department of Transportation regulations wouldbe required for the UF6shipments.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-24CommentNumberReviewer Name/CompanyCommentResponse85.Commonwealthof Virginia,Department ofTransportationIt is desired to see the EA address the potential impacts on thetransportation network or to have references made to otherdocuments that do include such information.See responses to Comments # 43, 58, 60, and 6186.Commonwealthof Virginia,Department ofTransportationThe EA material (especially pages 58-66) seems to indicate that thepotential hazards from truck shipment to highway work zone crewsand the general populace are negligible, but a clear statement to thateffect would be helpful.As shown by the analyses presented in the EA, theimpacts to workers and members of the public aresmall, ranging from 0.22 to 2.5 total fatalities fortruck shipments.87.Commonwealthof Virginia,Department ofRail and PublicTransportationShould the scope of the project change or if you have any questionsconcerning the projects impacts to rail lines, please contact[Virginia Department of Rail and Public Transportation].Such changes to the DOE Proposed Action couldtrigger an additional NEPA review. The scope of thatreview and the nature of stakeholder involvementwould vary depending upon the nature of thechanges to the Proposed Action.88.Commonwealthof Virginia,Department ofRail and PublicTransportationImpact of the proposed project todispose excess depleted uraniumon Virginia air quality will be that arising from the use of truck, railor barge transportation in the event Portsmouth site is chosen forthe purpose. Incrementalincrease in the transportation load due tothis project is not likely to be significant to have any perceptibleimpact on air quality. In the event of severe rail or road accidentconsidered in the EIR, there is alikelihood of temporary increase inparticulate pollution but its effect is far less than the radiationeffects outlined.The analysis in the EA indicates that the transport ofUF6using existing transportation infrastructurewould have minimal air quality impacts.89.Commonwealthof Virginia,Department ofConservation andRecreationDCR performed a 2-mile radius from the representative rail andtruck transportation routes displayed on Fig. 4-1 (Rail and TruckRoutes), pg.58. Disposition of DOE Excess Depleted Uranium,Natural Uranium, and Low-Enriched Uranium. According to theinformation currently in our files,there are several occurrences ofnatural heritage resources that could potentially be impactedAs discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, natural heritageresources and Threatened and Endangered SpeciesWaters would be considered in the routing process,to the extent required by regulations and aspracticable.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-25CommentNumberReviewer Name/CompanyCommentResponse90.Commonwealthof Virginia,Department ofConservation andRecreationDCR recommends incorporation of the conservation sites zonesaround these natural heritage resources to be incorporated intoemergency response plans developed for these transportationcorridors. Conservation sites are polygons built around one or morerare plant, animal, or natural community designed to include theelement and, where possible, its associated habitat, and buffer orother adjacent land thought necessary for the element'sconservation. Conservation sites are given a biodiversitysignificance ranking based on the rarity, quality, and number ofelement occurrences they contain;on a scale of 1-5, 1 being mostsignificant.The development of local emergency response plansthat incorporate entities such as conservation sitesare the responsibility of state and local public safetyofficials.91.Commonwealthof Virginia,Department ofConservation andRecreationDue to the legal status of many of these natural heritage resources,DCR recommends coordination with the United States Fish andWildlife Service (USFWS) and the Virginia Department of Gameand Inland Fisheries (VDGIF) toensure compliance with protectedspecies legislation.As discussed in the response to Comment # 43, DOEManual 460.2-1A establishes a standardized processand framework for interacting with state, tribal, andlocal authorities, and other federal agencies. Thiswould include coordination with the U.S. Fish andWildlife Service and the Virginia Department ofGame and Inland Fisheries, as appropriate andrequired by regulations, regarding the potentialimpact to federally listed species.92.Commonwealthof Virginia,Department ofConservation andRecreationThere are several VDGIF's "Threatened and Endangered SpeciesWaters" within the 2 miles radius of the representative rail andtruck transportation routes. DCR recommends coordination withVDGIF to ensure compliance withprotected species legislation.As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, natural heritageresources and Threatened and Endangered SpeciesWaters would be considered in the routing process,to the extent required by regulations and aspracticable. Furthermore, as discussed in theresponse to Comment # 43, DOE Manual 460.2-1Aestablishes a standardizedprocess and framework forinteracting with state, tribal, and local authorities,and other federal agencies. This would includecoordination with the U.S. Fish and Wildlife Serviceand the Virginia Department of Game and InlandFisheries, as appropriate and required by regulations,regarding the potential impact to federally listedspecies.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-26CommentNumberReviewer Name/CompanyCommentResponse93.Commonwealthof Virginia,Department ofConservation andRecreationAny accident involving the releaseof hazardous materials such asuranium could contaminate karst aquifers along the route. Thesekarst aquifers supply water for public drinking water supplies alsoprovide water for domestic and agricultural uses all along theroutes.As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, karst topography wouldbe considered in the routing process, to the extentrequired by regulations and as practicable.94.Commonwealthof Virginia,Department ofConservation andRecreationIn order to facilitate required emergency response as well as tobetter enable the mitigation work that would necessarily follow anyaccidents resulting in the releaseof hazardous materials into theenvironment, DCR strongly suggests that hydrologic investigationsbe performed along the course of the route where it passes throughkarst terrain or is upstream from karst terrain in order to determinethe boundaries and extent of these karst groundwater basins.DCR also recommends investigations include dye tracer studies todetermine the associated groundwater flow paths and theidentification of sinkholes and other associated karst featuresincluding springs and wells that could be affected by any spill ofhazardous material along theseprimary transportation corridors.As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, karst topography wouldbe considered in the routing process, to the extentrequired by regulations and as practicable. Becauseof the low probability of an accident involving arelease of UF6occurring in an area containing karsttopography, hydrologic investigations would not beconducted unless such anaccident actually occurred.95.Commonwealthof Virginia,Department ofConservation andRecreationDCR recommends implementation of safety measures and to notifylocalities of when and where thetransportation of nuclear wastewill occur.As discussed in the response to Comment # 43,shipment prenotification is one of the practicesestablished in DOE Manual 460.2-1A. Several of thepractices established in the manual relate to safetymeasures, such as routing, carrier/driverrequirements, and inspections.96.Commonwealthof Virginia,Department ofGame and InlandFisheriesAccording to our records, thereare a variety of listed speciesknown from these regions. However, based on the informationprovided, new construction and/or impacts to wildlife resourcesunder our jurisdiction are not proposed. Therefore, provided allnuclear material is safely contained and appropriately handled, andtransport on existing transportation infrastructure can beaccomplished in a safe manner and is not subject to transportationaccident, direct attack, and/or other incident that would result inimpacts to wildlife resources under our jurisdiction; then we do notanticipate the project would result in adverse impact to suchresources.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-27CommentNumberReviewer Name/CompanyCommentResponse97.Commonwealthof Virginia,Department ofGame and InlandFisheriesWe recommend the applicant coordinate with the USFWSregarding potential impact to federally listed species.As discussed in the response to Comment # 43, DOEManual 460.2-1A establishes a standardized processand framework for interacting with state, tribal, andlocal authorities, and other federal agencies. Thiswould include coordination the U.S. Fish andWildlife Service, as appropriate and required byregulations, regarding the potential impact tofederally listed species.98.Commonwealthof Virginia,Department ofEnvironmentalQuality, WasteDivisionThis is a multi-state project and the scope is extensive. For eacharea in Virginia whereany work is to takeplace, the applicantneeds to conduct an environmental investigation on and near theproperty to identify any solid orhazardous waste sites or issuesbefore work can commence. This investigation should include asearch of waste-related databases.As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, the presence of solid orhazardous waste sites or issues would be consideredin the routing process, to the extent required byregulations and as practicable.99.Commonwealthof Virginia,Department ofEnvironmentalQuality, WasteDivisionAny soil that is suspected of contamination or wastes that aregenerated must be tested and disposed of in accordance withapplicable Federal, State, and local laws and regulations.The EA assumes that any contaminated soil or wastethat resulted from a transportation accident would betested and disposed of, as appropriate, in accordancewith applicable federal, state, and local laws andregulations.100.Commonwealthof Virginia,Department ofEnvironmentalQuality, WasteDivisionStructures to be demolished should be checked for asbestoscontaining materials (ACM) and lead-based paint (LBP) prior todemolition. If ACM or LBP are found, in addition to the federalwaste-related regulations mentioned above. State regulations 9VAC20-80-640 for ACM and 9VAC 20-60-261 for LBP must befollowed.No structures would be demolished in connectionwith this Proposed Action.101.Commonwealthof Virginia,Department ofEnvironmentalQuality, WasteDivisionPlease note that DEQ encourages all construction projects andfacilities to implement pollution prevention principles, includingthe reduction, reuse, and recycling of all solid wastes generated. Allgeneration of hazardous wastes should be minimized and handledappropriately.This project does not include any construction. DOEemploys pollution prevention principles and wasteminimization techniques at each of its facilities.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-28CommentNumberReviewer Name/CompanyCommentResponse102.Commonwealthof Virginia,Department ofEnvironmentalQuality, WasteDivisionThe DEQ Waste Division recommends that for each area inVirginia where transportation ofnuclear materials will occur, DOEshould conduct an environmental investigation on and near thework area to identify any solid orhazardous waste sites or issuesbefore the work commences. Theinvestigation should include asearch of waste related databases).As discussed in the response to Comment # 43,transportation routing isone of the practicesestablished in DOE Manual 460.2-1A. If shipmentswere made through Virginia, the presence of solid orhazardous waste sites or issues would be consideredin the routing process, to the extent required byregulations and as practicable.103.Commonwealthof Virginia,Division ofRadiologicalHealthThe Department of Energy's (DOE) draft environmental assessmententitled "Disposition of DOE Excess Depleted Uranium, NaturalUranium, And Low-Enriched Uranium"' does not appear to createany significant radiological risk to the Commonwealth of Virginia.Your comment is noted.104.Commonwealthof Virginia,Division ofRadiologicalHealthI am supportive of a DOE conclusion for issuing a Finding of NoSignificant Impact.Your comment is noted.105.Commonwealthof Virginia,Department ofMines, Mineralsand EnergyBased on the scope of this activity, I do not anticipate an impact tomineral resources.Your comment is noted.106.Commonwealthof Virginia,Department ofMines, Mineralsand EnergyThe geology of southwestern Virginia (and the Coastal Plain, if ashipment is made through Norfolk) is variable and could be a factorin limiting or increasing the scope of an impact from a rail or truckaccident. The depth to bedrock, permeability of bedrock orsediment, orientation of bedding or fractures, presence of karstfeatures, and topographic setting could all be factors.Your comment is noted.107.Commonwealthof Virginia,Hampton RoadsPlanning DistrictCommissionBased on this review [of theEA], the proposal is generallyconsistent with local and regional plans and policies.Your comment is noted.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-29CommentNumberReviewer Name/CompanyCommentResponse108.State ofLouisiana,Department ofEnvironmentalQuality,Emergency &RadiologicalServices DivisionWhat is the current amount of uranium products and otherradioactive material that annually pass through the Port of NewOrleans?DOE does not have a database that contains thisinformation. This information has been requestedfrom other agencies (Port of New Orleans and CoastGuard) but not provided.109.State ofLouisiana,Department ofEnvironmentalQuality,Emergency &RadiologicalServices DivisionHow will this proposal, DOE/EA-1607, to ship through NewOrleans, increase the amount of uranium products passing throughthe Port of New Orleans?The Proposed Action describes the potential volumesof uranium that could pass through the Port of NewOrleans under the Proposed Action. Please seeSection 4.2.1.3,Impacts from Overseas Shipments,and footnote for the volume of material shipped outof the United States and the product returned to theUnited States.110.NuclearRegulatoryCommission(NRC)Section 3.1, page 17, affected facilities: Avoid using “FFF,”certainly not as if it is the formal name in lines 19, 21, 23.Westinghouse uses CFFF (not WEC FFF) to designate its ColumbiaFuel Fabrication Facility, but theothers do not use FFF at all.Document changed as suggested.111.NRC Section 3.1.4: Same for AREVA-Richland - they do not use theterm FFF.Document changed as suggested.112.NRC Section 3.1.5: The correct company name is Global Nuclear Fuel -Americas (GNF-A).Document changed as suggested.113.NRC Section 3.1.5: Global NuclearFuels Americas (GNF-A) generateslow level radioactive wastes, hazardous wastes, and mixed wastes(page 30). Consider a waste management paragraph similar toAREVA.Document changed as suggested.114.NRC Section 3.1.6: Throughout: a name that is used by Westinghouse isColumbia Fuel Fabrication Facility (CFFF).Document changed as suggested.115.NRC Section 3.1.6: Waste generation paragraph appears tobe missing. Waste management paragraph has been added.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-30CommentNumberReviewer Name/CompanyCommentResponse116.NRC For the Louisiana Energy Services (LES), GNF-A, and AREVAfacilities cited, NRC understands from this document that thefacility may receive a feedstock delivery from an alternate sourceand that an increase to the facilities production will not occur fromthese deliveries. However, when reading the EA this is not clearlystated. It reads "...if DOE contracts for the enrichment of DU, NU,or LEU to obtain LEU with up to 4.95 percent U235 content, DOEwould contract to transport the LEUproduct to, and store it at, oneor more of five domestic sites ... AREVA in Richland ... GlobalNuclear Fuel ... DOE considers on-sitestorage at these FFFs to bedesirable because they require LEU as process feedstock andalready store quantities of LEU on-site." Does DOE project anychanges to storage than previously assessed (licensed)?The Department does not project any license changesas a result of the Proposed Action.117.NRC NRC is currently performing environmental assessments for the 40year license renewal of the AREVA Richland Washington andGlobal Nuclear Fuels-America facilities. DOE briefly mentions aportion of this action in theirassessment. DOE’s references aredated.DOE has not been able to determine whichreferences that NRC believes are dated. No changeswere made.118.NRC In the description of the NRClicensed facilities, the specifics arenot consistently stated. For instance, at the AREVA Richlandfacility, a mention is made of the golf course, the schools and thehospital. However the report does not mention a large residentialneighborhood associated with the golf course and several older,smaller neighborhoods nearby.Text has been added stating that there are residentialareas near the golf course and hospital.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-31CommentNumberReviewer Name/CompanyCommentResponse119.NRC NRC recommends revising the description of the impact for theAREVA Richland facility. In NRC's draft EA for the AREVAfacility, NRC discusses the small to moderate impacts fromtransportation that may occur by 2025. City and State officials haveprojected significant transportation problems by the year 2025 iffurther transportation capacity isnot achieved (i.e., construction ofa bridge, access changes to major roads, etc.). Based on the City'sproactive stance, they have added turn lanes and lighting to easenear term capacity problems in the vicinity of the site, yet thesechanges are insufficient to address long-term transportationcapacity in the area ofpotential effect.NRC’s final EA for license renewal for the AREVAFuel Fabrication Facility at Richland, Washington(NRC 2009) indicated that the short-term local trafficimpacts are small and the long-term local trafficimpacts are small to moderate. The NRC EA notedthat traffic from the regions largest employer(Hanford Site) will significantly lessen over the next30 years. Also, the Cityof Richland, Washington,prepares a Six-Year Transportation ImprovementProgram that is used as a planning tool to identifypriorities to improve city streets and local stretchesof the interstate highway. State law requires that thecity adopt this planning tool prior to July 1 of eachyear. Thus, it is anticipated that continualimprovements would occur. See the City ofRichland, Washington, website athttp://www.ci.richland.wa.us/RICHLAND/Utilities/index.cfm?pagenum=72.120.NRC NRC is currently evaluating two construction licensing applicationsfor uranium enrichment: GE Hitachi's Global Laser Enrichment(Wilmington NC - on the same grounds as GNF-A) and AREVAEagle Rock Enrichment Facility (Idaho Falls, Idaho). The potentialexists that both of these facilitiesmay come on-line within the 25years proposed by DOE's EA.These two facilities are in the early stages ofdevelopment and are now addressed in Section 2.4.1,Other Enrichment Facilities. Impacts from theAREVA Eagle Rock Enrichment Facility would besimilar to LES. GE Hitachi’s Global LaserEnrichment is in the conceptual stage andinsufficient information is currently available todetermine the potential environmental impacts thatcould be associated with this facility.Final Environmental Assessment: Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium

D-32CommentNumberReviewer Name/CompanyCommentResponse121.Ux Consulting The draft EA states that France is the only nation with theregulations in place to enrich DOE's uranium. The EA also saysthat Japan lacks the regulatory agreements.This text now beginning on line 3 of page 15 hasbeen changed to read, “This EA presents impactsassociated with transportation to and from France asrepresentative of potential impacts associated withenrichment at any foreign facility. Potential impactswould vary in proportion to the distance traveled if afacility in another country was used. In addition tothe French facility in Tricastin, other foreignenrichment facilities are operating in variousEuropean countries, as well as Russia and Japan. Atthis time, the United States has 123 Agreements(Section 123 of the Atomic Energy Act of 1954) forPeaceful Nuclear Cooperation with multiplecountries such as Japan, and with countries that arepart of the European Atomic Energy Community(Euratom), including France (DOE 2008a). Otherforeign enrichment facilities could be considered inthe future if the necessary agreements wereimplemented.”

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Title: Uranium EA 12-11 Subject:

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