DOE/EA-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 Energy 

Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

 i 

TABLE OF CONTENTS 

1.0 PURPOSE AND NEED FOR 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 Environmental 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 Material 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 Energy and United States Enrichment 

Corporation, Paducah Gaseous Diffusion Plant, Paducah, Kentucky ...... 18 

3.1.2 United States Department of Energy 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 Storage Impacts under the Enrichment 

Alternative................................................................................................. 81 

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

4.3 Direct Sale Alternative.......................................................................................... 85 
Final 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 IRRETRIEVABLE COMMITMENT 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 Enhancement of Long-Term Productivity ................... 97 

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

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

APPENDIX B: TRANSMITTAL LETTERS AND DISTRIBUTION 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 Product, and DU Tails Characteristics ........................... 10 

Table 4-1. Summary of Impacts from National Enrichment Facility Construction, 

Operation, and Decommissioning......................................................................... 44 

Table 4-2. Summary of Impacts from American 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 Distances and Population Densities ............................................. 59 

Table 4-5. Characteristics of Selected Uranium Cylinders .................................................... 62 

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

Proposed Action.................................................................................................... 62 

Table 4-7. Radionuclide Inventory 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 ................................... 67 
Final Environmental Assessment: 

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Table 4-9. Maximum Individual Impacts from Truck Shipmentsa ........................................ 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 Shipmentsa ........................................... 73 

Table 4-12. Assumed Exposed Populations along Barge and Truck Routes ........................... 74 

Table 4-13. Radiological Consequences for the Population from Severe Transportation 

Accidents Involving Depleted Uranium Hexafluoridea

........................................ 77 

Table 4-14. Radiological Consequences for the Maximally Exposed Individual from 

Severe Transportation Accidents Involving Depleted Uranium Hexafluoride..... 77 

Table 4-15. Chemical Consequences for the Population from Severe Transportation 

Accidents Involving Depleted Uranium Hexafluoride a

....................................... 80 

Table 4-16. Chemical Consequences for the Maximally Exposed Individual from Severe 

Transportation Accidents Involving Depleted Uranium Hexafluoride................. 80 

Table 4-17. Occupational Radiation Doses at FFFs in 2006.................................................... 85 

Table C-1. Other NEPA Documents 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, North 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 .......................................................................................... 60 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

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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 

CaF2 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 

DUF6 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 Organization for Standardization 

LCF latent cancer fatality 

LES Louisiana Energy Services 

LEU low-enriched uranium 

LEUF6 low-enriched uranium hexafluoride 

LLMW low-level mixed waste 

LLW low-level waste 

μCi/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 applicable 
Final Environmental Assessment: 

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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 

NUF6 natural uranium hexafluoride 

pCi/g picocuries per gram 

PEIS programmatic environmental impact statement 

PM2.5 particulate matter with a diameter of 2.5 microns or less 

PM10 particulate matter with a diameter 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 

U3O8 triuranium octoxide 

UDS Uranium Disposition Services, LLC 

UF6 uranium hexafluoride 

UO2 uranium dioxide 

UO2F2 uranyl fluoride 

USEC United States Enrichment Corporation 

VOC volatile organic compound 

WEC Westinghouse Electric Corporation 
Final 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 and manages an inventory of depleted uranium 

(DU), natural uranium (NU), and low-enriched uranium (LEU) that is currently stored in large 

cylinders as depleted uranium hexafluoride (DUF6), natural uranium hexafluoride (NUF6), and 

low-enriched uranium hexafluoride (LEUF6) at the DOE Paducah site in western Kentucky 

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

Portsmouth)1

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

needs. 

On March 11, 2008, the Secretary of Energy issued a policy statement (the Secretarial Policy 

Statement) on the management of DOE’s excess uranium inventory (Appendix A). The policy 

statement commits DOE to manage all of its excess 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 involving non-U.S. Government entities in a transparent and 

competitive manner, unless the Secretary of Energy determines in writing that overriding 

Departmental mission needs dictate otherwise; and (4) is consistent with and supportive of the 

maintenance of a strong domestic nuclear industry. 

In accordance with this policy, DOE proposes to disposition 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 sale2 to appropriately licensed entities (the Direct Sale Alternative). Under the 

Enrichment Alternative, DOE could enrich DU to the 235U content of NU (i.e., 0.711 percent 

235U), and DOE could enrich DU, NU, and/or LEU (with a current 235U content of less than 

4.95 percent) up to 4.95 percent 235U 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 market, 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 excess inventory that DOE currently proposes to disposition is 

stored as UF6 at the DOE Portsmouth site in Ohio and the DOE Paducah site in Kentucky. DOE 

also anticipates the potential identification of additional amounts of LEU with a 235U 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 could be recovered during facility decontamination and 

decommissioning [D&D]). In addition, the DOE uranium inventory 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 

 viii 

truck or rail to one or more of three enrichment facilities in the United States or to a foreign 

enrichment facility. A facility in France is identified as a representative foreign facility for the 

purposes of assessing potential 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 Orleans, Louisiana, then by ship to France. The 

LEU product could be stored at up to three U.S. commercial nuclear fuel fabrication facilities 

(FFFs) in North Carolina, South Carolina, and Washington State, and/or at DOE’s Portsmouth or 

Paducah sites. When DU is enriched to NU, it would be stored at enrichment facilities in 

Kentucky, New Mexico, and/or Ohio, and/or at DOE’s Portsmouth 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 environmental impacts associated with this Proposed 

Action and a No Action Alternative. The potential 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) documents. This EA focuses on previously 

unanalyzed impacts: (1) health and safety impacts from transportation of the excess inventory, 

LEU product, NU, and DU tails; (2) impacts associated with accidents and intentional 

destructive acts (terrorism, sabotage); and (3) economic impacts of the 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 options, for all domestic and foreign enrichment 

facility locations, and for all storage options, transportation of the entire inventory of DU, 

NU, and LEU subject to this EA is estimated to result in up to 3 transportation-related 

fatalities3

 over approximately 25 years4. For overseas transportation, this includes 

impacts from sea transit, U.S. port operations, and overland transport. These 

transportation impacts include the radiological and nonradiological 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 materials 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 impacts 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 

 ix 

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 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 probability of an LCF for the MEI along the rail transportation routes was almost 

identical to truck transport, 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 transporting the uranium to New Orleans by barge 

would be less than the impacts of transporting the uranium there by truck or rail due to 

the fewer number of required shipments and the fact that the exposed population would 

be smaller for barge transport. 

• Severe rail accidents would have higher consequences 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 accidents for truck shipments 

(probability of occurrence × consequence summed over a complete spectrum of 

accidents, including the severe accidents discussed below) ranged from 0.042 to 0.96 

LCFs over 25 years.

• DOE also estimated the consequences of severe truck accidents. For a severe truck 

accident involving one cylinder of depleted uranium hexafluoride (DUF6), 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 transportation 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 accident. For the MEI, the probability of an 

LCF would be 0.002 or 0.0036 if three or five 30B cylinders, respectively, were breached 

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 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 were 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 accidents for rail shipments 

(probability of occurrence × consequence summed over a complete spectrum of 

accidents, including the severe accidents discussed below) ranged from 0.051 to 0.97 

LCFs over 25 years. The radiological risks for rail and truck transportation accidents are 

similar because the total number of cylinders shipped by rail and truck is the same. 

• DOE also estimated the consequences of severe rail accidents. For a severe rail accident 

involving four cylinders of DUF6, the population radiation dose 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 estimated to be as high as 3.7 rem, and 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 transportation accident involved NU feed or product, the radiological 

consequences would be higher—about 110 LCFs in the assumed exposed population and 

the probability of an LCF for the MEI would 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 breached during the severe accident. 

For the MEI, the probability of an LCF would 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 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 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

 xi 

would 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 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 that according to the 2000 census, the average 

population density within 50 miles of the center of the 20 highest population urbanized 

areas in the United States is about 380 people per square kilometer, so the consequences 

would likely be lower if a severe truck or rail 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 consequences would be substantially lower. For example, if 

the severe truck accident involving LEU product 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 would be about 12 LCFs, substantially lower 

than 310 LCFs. 

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

four individuals could suffer irreversible health effects from severe rail accidents due to 

the chemical toxicity associated with UF6, hydrogen fluoride (HF), and uranyl fluoride 

(UO2F2). No fatalities are estimated to result from chemical exposure.5 

• Although it is not possible to predict the probability of an intentional 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 for 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 estimated 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 estimated 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 includes respiratory irritation or skin rash associated with lower chemical 

concentrations. An irreversible adverse health effect generally 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 may impair daily functions. Of those individuals receiving an 

irreversible adverse health effect, approximately 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 UF6; 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. 

• The potential market impacts (including socioeconomic impacts) on the domestic 

uranium mining, conversion, and enrichment industries (i.e., domestic uranium industry) 

from direct sales or transfers 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 inventory at DOE’s Paducah and Portsmouth 

sites as analyzed in this EA. 

• Cumulative impacts under the Enrichment Alternative 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 throughput. Under the Direct Sale 

Alternative, DOE assumes that actions by the purchasers would be essentially 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 Enrichment Alternative. The cumulative impacts that 

would occur under the No Action Alternative assessed in this EA are the same as the 

cumulative impacts identified for the two new conversion facilities at Paducah and 

Portsmouth. 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

 1 

Uranium Hexafluoride (UF6) 

Uranium hexafluoride (UF6) 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 UF6 is a white, dense, crystalline 

material that resembles rock salt. UF6 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 UF6 comes 

into contact with water, such as water vapor in the 

air, the UF6 and water react, forming corrosive 

hydrogen fluoride (HF) and a uranium-fluoride 

compound called uranyl fluoride (UO2F2). For this 

reason, UF6 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 

(DUF6), natural uranium hexafluoride 

(NUF6), and low-enriched uranium 

hexafluoride (LEUF6) at the DOE Paducah 

site in western Kentucky (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 statement (the Secretarial Policy 

Statement) on the management of DOE’s excess uranium inventory (Appendix A). The policy 

statement commits DOE to managing all of its excess 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 involving non-U.S. Government entities in a transparent and 

competitive manner, unless the Secretary of Energy determines in writing that overriding 

Departmental mission needs dictate otherwise; and (4) is consistent with and supportive of the 

maintenance of a strong domestic nuclear industry. 

In accordance with the principles set forth in the Secretarial Policy Statement, DOE is proposing 

to disposition excess NU, DU and LEU inventory by enriching it, and then storing or selling the 

resultant product, and/or selling excess NU, DU and LEU inventory, to appropriately licensed 

entities. Hereafter in this environmental assessment (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 the excess inventory are discussed further in 

Section 2.0, Description of the Proposed 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 could be recovered during facility decontamination and 

decommissioning [D&D]). In addition, the DOE uranium inventory 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: 

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 2 

1.2 Purpose and Need 

The purpose of the Proposed Action is to disposition DOE’s excess inventories of NU, DU, and 

LEU to reduce expenses associated with storing, managing, and securing DOE’s excess uranium 

inventory. Changes in the relative market prices for DU, NU, LEU, and enrichment services may 

affect the economic advantages to the enrichment 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 Statement provides the framework within which DOE 

would make decisions concerning future disposition of the excess inventory. 

1.3 The National Environmental Policy Act and Related Procedures 

Before deciding whether to implement the Proposed Action, DOE must comply with the 

National Environmental Policy Act (NEPA), 42 U.S. C. §§ 4321 et seq. Consequently, DOE is 

preparing this EA to determine if the Proposed Action 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 render the impacts of the 

Proposed Action not significant. This EA has been prepared in accordance with NEPA 

regulations issued by the Council on Environmental Quality (CEQ) (40 CFR Parts 1500–1508) 

and DOE (10 CFR Part 1021), as well as guidance 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 fabricators, 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 (238U), uranium-235 (235U), and 

uranium-234 (234U). The 235U 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 explosion. Of the three naturally occurring uranium 

isotopes, only 235U 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 235U. Through gaseous diffusion or centrifugation enrichment 

processes, the concentration of 235U can be increased (enriched), and the resultant uranium is called 

either low-enriched uranium (LEU) or highly enriched uranium (HEU). LEU has a concentration of 235U less than 20 percent. HEU has a concentration of 235U 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 235U. 

After increasing the concentration of 235U in a portion of the uranium mixture during the enrichment 

process, the remaining uranium mixture has a reduced concentration of 235U. This is called depleted 

uranium (DU) or sometimes DU tails. The U.S. Nuclear Regulatory Commission (NRC) definition of 

DU is uranium in which the percentage fraction by weight of 235U is less than 0.711 percent, although 

enrichment normally results in DU having much lower levels of 235U. 
Final Environmental Assessment: 

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 3 

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 assessed 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 sources 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. 
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2.0 DESCRIPTION OF THE PROPOSED 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 product and subsequent storage or sale of the 

resultant NU or LEU product (the Enrichment Alternative), and (2) direct sale7 to appropriately 

licensed entities (the Direct Sale Alternative). Under the Enrichment Alternative, DOE could 

enrich DU to the 235U content of NU (i.e., 0.711 percent 235U), and DOE could enrich DU, NU, 

and/or LEU (with a current 235U content of less than 4.95 percent) up to 4.95 percent 235U 

content. A target enrichment level for LEU of 4.95 percent 235U content was selected for analysis 

in this EA because it is near the upper end of the range of enrichment (3 to 5 percent 235U ) used 

in fuel for most commercial light-water power reactors. In practice, DOE might choose to enrich 

to lower-percentage 235U content. This chapter describes these two action alternatives, including 

options within them, and the No Action Alternative (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 235U8

), and LEU (having an assay greater 

than 0.711 percent 235U but less than 4.95 percent 235U) as UF6. 

DOE would contract with appropriate 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 diffusion plant (GDP) in Paducah, Kentucky; (2) the 

USEC American Centrifuge Plant (ACP) near Piketon, Ohio, which is scheduled to begin 

enrichment operations in late 2009 or 2010; and (3) the Louisiana Energy Services (LES) 

National Enrichment Facility (NEF) 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 miles) north of the port of Marseilles. This EA 

presents impacts associated with transportation to and from France as representative of potential 

impacts associated with enrichment at any foreign facility. Potential impacts would vary in 

proportion to the distance traveled if a facility 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 Japan. 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 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 implementing the Proposed Action evaluated in the EA, DOE may occasionally select 

cylinders with slightly less than 0.35 percent 235U (e.g., a cylinder with 0.345 to 0.349 percent 235U) for sale or 

enrichment in order to avoid extra handling of cylinders (and the risks associated with such handling). 
Final Environmental Assessment: 

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U.S. facility enrichment operations (including enrichment technologies; feed material, end 

product, and waste product handling; logistics; and facility management) have been described in 

detail in applicable DOE and NRC NEPA documents. Those documents describe the enrichment 

operations, the enrichment facilities, the waste management activities, and the environmental 

impacts that would be applicable to the enrichment 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 France 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 Portsmouth. If DOE contracts for the enrichment of DU, 

NU, or LEU to obtain LEU with up to 4.95 percent 235U content, DOE would contract to 

transport the LEU product to, and store it at, one or more of five domestic sites. Three of these 

sites are commercial nuclear fuel 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 Carolina. 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 product 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 logistics of uranium cylinders. 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 potentially affected domestic sites; Figures 2-2 

through 2-6 illustrate the domestic and international 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 that the DU tails would have a 0.20 percent 235U content. 

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

content than the DU that would serve as feed for enrichment operations. As part of the Proposed 

Action, DOE would contract with the enrichment facility to store and/or dispose of the DU tails 

or, in the case of domestic enrichment facilities, 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 Conversion Facility at the Portsmouth, OH, Site (69 FR 44649). 

DOE assumes DU tails from enrichment in France would not be returned to the United States but 

would be disposed of in France in accordance with French policies and regulations. DOE may 

contract with the enricher to store, convert, and dispose of the tails. 
Final Environmental Assessment: 

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 7 

Figure 2-1. Domestic Facility Locations 

Figure 2-2. Excess Inventory Shipments to Domestic Enrichment Facilities 
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 8 

Figure 2-3. NU Product Shipments 

Figure 2-4. LEU Product Shipments to Five Optional Storage Locations 
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 9 

Figure 2-5. Excess Inventory Shipments 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: 

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 10 

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 10,776a

 - LEU feed 2,000b

 296 

Alternative potential products, and DU tails that would result from the production of that product 

 - LEU product 4,919 3,195 

 - DU tails 89,972c

 10,931 

 - NU product 22,213 3,445 

 - DU tails 53,083d

 6,450 

a. This EA uses 10,776 DU cylinders for its estimate of impacts. In Appendix D, comment #4 from USEC noted that the 

actual DU cylinder count would be less, later 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 estimate of impacts. In light of the 

already low estimates of potential impacts, this recalculation was not performed. 

b. DOE currently has identified approximately 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 from 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 sites 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. Minor upgrades to existing sidings or rail terminals 

could be implemented, if necessary, to accommodate or allow for rail shipments. The decision 

whether to undertake any rail upgrades would be DOE’s responsibility only at DOE Paducah or 

DOE Portsmouth, and DOE would evaluate the need for related NEPA analysis if such a 

proposal were under consideration. 

The excess inventory to be shipped from DOE Paducah or DOE Portsmouth to France could be 

transported to New Orleans, Louisiana, by barge, rail, and/or truck, and 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 (that is, larger estimated impacts than if the LEU 

product were shipped directly from France to an FFF). Uranium could be exported to and 

imported from France via U.S. marine terminal ports other than the port of New Orleans. Other 

options include the ports of Providence, Rhode Island; New York, New York; Elizabeth, New 

Jersey; Philadelphia, Pennsylvania; Baltimore, Maryland; Hampton Roads, Virginia; Morehead 
Final Environmental Assessment: 

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 11 

City, North Carolina; Charleston, South Carolina; Savannah, Georgia; Jacksonville, Florida; 

Fernandina, Florida; and Houston, Texas. However, of these and other optional marine terminal 

ports, only New Orleans can be reached directly or nearly directly by barge from DOE Paducah 

and DOE Portsmouth. Commercial carriers would decide which ports to use. Impacts would be 

generally similar at any port capable of handling the materials because the operations would be 

the same or similar. In a 1994 EA, DOE found no significant difference in comparative 

transportation-related risks among 13 optional ports of entry for importing LEU into the United 

States (DOE 1994). Based on the availability of direct barge access and the previously 

determined comparability of transportation-related risk to optional ports, DOE has determined 

that analyzing only New Orleans as a marine terminal port is sufficient for the purposes of this 

EA. If other marine terminal ports were proposed, 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 the 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 maintenance of a strong domestic nuclear industry. 

Consistent with this principle, the Department believes that, as a general matter, the introduction 

into the domestic market of uranium from Departmental inventories in amounts that do not 

exceed 10 percent of the total annual fuel requirements 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 Department anticipates, 

however, that in any given year, it may introduce into the domestic market less than that amount, 

or, for certain special purposes (such as the provision of initial core loads for new reactors), more 

than that amount. These annual amounts would include uranium introduced into the domestic 

uranium market from all Departmental inventories, including LEU generated via the downblending of highly enriched uranium (HEU) in the ongoing National Nuclear Security 

Administration (NNSA) HEU disposition program (61 FR 40619). 

The specific annual amounts would be determined on an ongoing basis; the amounts would 

depend upon market analyses for particular 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 inventory 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: 

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 12 

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 required later during re-loading. For the purposes of this EA, DOE 

has conservatively assumed that such events could 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 include, 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 the Proposed Action would be somewhat 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 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. 

2.1.3 Regulations Governing Material Shipments: United States 

Within the United States, uranium would be shipped in accordance with U.S. Department of 

Transportation (DOT) and NRC regulations governing the transport of radioactive materials—in 

particular, 49 CFR Part 173, subpart I, “Class 7 (Radioactive) Materials.” Among other things, 

49 CFR 173.420 requires that each UF6 cylinder be designed, fabricated, inspected, tested, and 

marked in accordance with the version of American 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 requirements are referred to as “nonconforming” 

because they are overfilled, over-pressurized, or structurally substandard. Any UF6 currently 

stored in a nonconforming cylinder would not be transported without 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, International Atomic Energy Agency (IAEA) Safety Standards 
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 13 

Regulations for the Safe Transport of Radioactive Material (IAEA 2005), IAEA Interim 

Guidance on the Safe Transport of Uranium Hexafluoride (IAEA 1991), and the pertinent 

provisions of the International Organization for Standardization. As with domestic shipments, 

any UF6 currently stored in a cylinder that did not conform to all applicable regulations would 

not be transported without prior preparation sufficient to make the cylinder conform to all 

applicable regulatory requirements. This would include transferring the UF6 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 excess 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 the market annually through any combination of 

enrichment and sales. 

DOE assumes that licensed purchasers would take delivery, transport and enrich the excess 

inventory, and transport and store the NU or LEU product in essentially the same manner and 

using essentially the same facilities as would DOE under the Enrichment Alternative. DU tails 

resulting from the ultimate enrichment of DOE’s sold 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 enrichment 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 Alternative. Consequently, with the exception of the 

economics analysis in Section 4.3.2, Direct Sale Alternative activities and impacts are not further 

described or analyzed. The potential impacts of the Enrichment Alternative are similar to the 

impacts of a combination alternative; consequently, 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 impacts of alternative DOE management strategies for DUF6 stored at 

three DOE sites: Paducah, Portsmouth, and the East Tennessee Technology Park (ETTP) at Oak 

Ridge, Tennessee (DOE 1999b). The PEIS considered the environmental impacts, benefits, costs, 

and institutional and programmatic needs associated with the management and use of 

approximately 700,000 MT tons of DUF6. The alternatives analyzed in the PEIS included no 

action, long-term storage as UF6, 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 the absence of an appropriate 

waiver, the UF6 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: 

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 14 

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

following: 

“DOE has decided to promptly convert the depleted UF6 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 future 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 DUF6 from the East Tennessee Technology Park (ETTP) in 

Oak Ridge, Tennessee, to its storage facilities at DOE’s enrichment facility at 

Portsmouth, Ohio...” 

Subsequently, in 2004 DOE issued two site-specific EISs (DOE 2004a, 2004b) and associated 

RODs (69 FR 44654; 69 FR 44649) for construction and operation of two DUF6 conversion 

facilities, one at the DOE Paducah site (DOE 2004a) and one at the DOE Portsmouth site (DOE 

2004b). These two new facilities are nearing completion, and operations are projected to begin in 

2010. 

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

at Portsmouth and Paducah to a more stable chemical form suitable for use or disposal consistent 

with the two RODs cited above. However, in accordance 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 consistent with the two RODs cited above and would not enrich or sell 

any of its excess DU inventory as proposed in this EA. Under the No Action Alternative, DOE 

would also continue to store excess NU and LEU in their current configurations at Portsmouth 

and Paducah. The two DU conversion facility EISs (DOE 2004a and 2004b) evaluated continued 

storage of NU and LEU cylinders as part of their 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 Portsmouth 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 that are expected to be 

operating in 2009 and 2010, although other new facilities have been announced or are planned 

for the future. Such facilities could be considered if they became available. There are two new 

U.S. facilities that are in the licensing stage: GE Hitachi’s Global Laser Enrichment Facility 
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 15 

(Wilmington, North Carolina, on the same grounds as GNF-A) and AREVA’s Eagle Rock 

Enrichment Facility (Idaho Falls, Idaho). 

This EA presents impacts associated with transportation to and from France as representative of 

potential impacts associated with enrichment at any foreign facility. Potential impacts would 

vary in proportion to the distance traveled if a facility 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 Japan. 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 France (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 AREVA 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 UF6. 

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 France, 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 materials is typically used for rapid delivery when the half-life of the 

material is short or immediate use of the material is required. If speed of delivery is not a 

consideration (as is the case with this Proposed Action), large, frequent shipments of radioactive 

materials by air are unwarranted. 

2.4.5 Use of Great Lakes Ports 

Uranium could conceivably be exported and imported using Great Lakes ports. However, doing 

so would require using the Great Lakes St. Lawrence Seaway System, a deep-draft waterway 

extending 3,700 kilometers (2,340 miles) from the Atlantic Ocean to the head of the Great Lakes. 

The St. Lawrence Seaway portion of the system extends 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 option was not analyzed further. 
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3.0 AFFECTED ENVIRONMENTS 

This chapter describes two classes of environment—geographic and economic—that are 

potentially affected by DOE’s Proposed Action. The affected geographic environment comprises 

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

LEU and DU tails could be stored11. The economic environment is the existing uranium market. 

A third potentially affected environment, the transportation corridors and global commons over 

which uranium could be transported is described in Section 4.2.1 (Transportation Impacts). For 

domestic shipments, uranium could be transported by truck and/or rail; for shipments to France, 

uranium would be transported by truck, 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 could 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 enrichment site, and proposed 

NU, LEU, and DU tails storage; 

• Louisiana Energy Services (LES) National Enrichment Facility (NEF), Eunice, New 

Mexico: proposed enrichment site, and proposed 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 locations either currently hosts a DOE site or has been licensed by 

NRC to host an existing or under-construction uranium enrichment facility, DUF6 conversion 

facility, or nuclear FFF. Therefore, each of these affected environments has been previously and 

extensively described and categorized in a DOE or NRC EA, EIS, or other agency document. 

These existing documents provide detailed site maps and descriptions of the environments that 

would be affected by agency actions. Sections 3.1.1 through 3.1.6 of this EA provide site locator 

maps, summary site descriptions, and summaries of those aspects 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 resource areas that would not be affected by DOE’s 

Proposed Action (including, for example, ecological resources, endangered species, wetlands, 

noise, construction-related impacts) are also found in these existing documents. 

 

11 The affected environment and impacts associated with uranium import and enrichment 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 with regulatory requirements of that country. 
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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 Paducah site and USEC GDP in rural McCracken 

County in far western Kentucky. The affected environment as summarized below is described in 

detail in the following documents, which are incorporated into this EA by reference: 

• Final Environmental Impact Statement for Construction 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 Map 
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• Final Environmental Impact Assessment of the Paducah Gaseous Diffusion Plant Site

(DOE 1982). DOE/EA-0155. August 1982. 

http://www.osti.gov/bridge/product.biblio.jsp?osti_id=6727682. 

• Final Programmatic Environmental Impact Statement 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/documents/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 the 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 (2,781-acre) West Kentucky Wildlife Management 

Area, which was conveyed by DOE to the Commonwealth of Kentucky for wildlife conservation 

and for recreational purposes. The City of Paducah is the largest urban area 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 site is located in an area with an established 

transportation network. The area is served by one interstate highway (I-24), several U.S. and 

state highways, several rail lines, a barge terminal, and a regional airport. 

The Paducah GDP occupies a 303-hectare (750-acre) 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 combined 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 Disposition Services, LLC (UDS) to design, build, 

and operate DUF6 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 UF6 (mostly DUF6) stored in outdoor facilities, 

commonly referred to as cylinder storage yards. Additional cylinders are added to the DOE 

inventory periodically as a result of formal agreements with the USEC. The site has 13 storage 

yards used to store DOE-generated DUF6 cylinders; an additional 4 yards are used to store 

USEC-generated cylinders that are now managed by DOE. Over several years, most of the 

storage yards that previously had gravel bases have been reconstructed with concrete bases to 

better control water infiltration and runoff. 

 

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

UDS. 
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Radiation Environment 

The average annual radiation dose to people in the 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) requires that exposure of members of the public to 

radiation sources as a consequence of all routine DOE activities shall not cause, in a year, an 

effective dose equivalent greater than 100 mrem (DOE 1990). U.S. Environmental Protection 

Agency (EPA) regulations establish additional public dose limits for exposures to several 

selected sources or exposure modes: regulations implementing the Clean Air Act (40 CFR Part 

61) establish a dose limit of 10 mrem from airborne 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 pathways potentially contributing to dose include ingestion of 

surface water, ingestion of sediments, 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 facilities and with the inhalation of radionuclides released from 

processes conducted on the site. Off-site members of the public are exposed to radionuclides 

discharged from on-site facilities with airborne and/or waterborne emissions and, in some cases, 

to radiation emanating from radioactive materials handled in the on-site facilities. 

For 2005, the highest estimated dose a maximally exposed individual (MEI) might have received 

from all combined DOE exposure pathways (worst-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 location 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 series of earthquakes centered in the New Madrid fault zone 

destroyed the town of New Madrid, Missouri. These quakes are considered to be the largest 

recorded earthquakes to have occurred in the contiguous United States. Based 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). 
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The seismic hazards at the Paducah site have been 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 independent review indicated that 

the seismic sources, recurrence rates, 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 deterministic analyses were also performed to 

estimate the ground motions at the site in the case 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 results for the probabilities associated with the 

recurrence of the New Madrid earthquake of 1811–1812. 

Groundwater 

Contamination has been detected in off-site and on-site groundwater. Beta activity, 

trichloroethylene (TCE) and technetium-99 (99Tc) 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 water. DOE is actively addressing 

the groundwater contamination through source removal actions and groundwater 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. McCracken County currently is designated as being 

in attainment for all criteria pollutants (40 CFR 81.318). 

Waste Management 

The Paducah site generates wastewater, nonhazardous waste, nonradioactive hazardous waste, 

low-level waste (LLW), and low-level mixed waste (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-site 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 Portsmouth site and USEC ACP in rural Pike County 

in south-central Ohio. The affected environment as summarized below is described in detail in 

the following documents, which are incorporated into this EA by reference. 

• Final Environmental Impact Statement for the Proposed American Centrifuge Plant in 

Piketon, Ohio (NRC 2006). NUREG-1834, Vol.1. April 2006. 
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• Environmental Assessment of the USEC Inc. American Centrifuge Lead Cascade Facility 

at Piketon, Ohio (NRC 2004). January 2004. 

• Final Environmental Impact Statement for Construction 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 Environmental Report for 2005 (DOE 2007b). August 2007. 

http://www.lpports.com/05%20Annual%20Environmental%20Report.htm.

• Final Programmatic Environmental Impact Statement 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/documents/nepacomp/peis/index.cfm. 

Figure 3-2. Piketon, Ohio, Locator Map 
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Site Description 

The NRC issued a construction and operating license to USEC for the ACP in April 2007. The 

license, which is valid for 30 years, includes authorization to enrich uranium up to an assay level 

of 10 percent 235U. 

The DOE Portsmouth site is located in Pike County, Ohio, approximately 35 kilometers 

(22 miles) north of the Ohio River and 5 kilometers (3 miles) southeast of the town of Piketon. 

The two largest cities in the vicinity are Chillicothe, located 42 kilometers (26 miles) north of the 

site, and Portsmouth, 35 kilometers (22 miles) south. The Portsmouth site includes the 

Portsmouth GDP, which was previously operated by DOE and later by USEC. Uranium 

enrichment operations were discontinued in May 2001. 

The Portsmouth site occupies 1,500 hectares (3,714 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 support facilities, and vacant land. Wayne National Forest borders 

the plant site on the east and southeast, and Brush Creek State Forest is located to the southwest, 

slightly more than 1.6 kilometers (1 mile) from 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 transportation by public road 

from the Portsmouth site. 

The ACP is being constructed by USEC within the 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 UF6 cylinder storage yards (the existing X-745G-2 and 

proposed X-745H), occupying a total of 11 hectares (27 acres), will be located 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 DUF6 conversion plants 

at the DOE Paducah and Portsmouth sites. The contract includes cylinder surveillance and 

maintenance, which began June 27, 2005. Construction of the Portsmouth conversion plant is 

complete, the facility is preparing for its operational readiness review, and start-up is projected 

for March 2010.14 

The Portsmouth site houses over 20,000 DUF6 cylinders. The cylinders are located in two 

storage yards that have concrete bases. The cylinders are stacked two high. All 10- and 14-ton 

(9- and 13-tonne) cylinders stored in these yards have been or are being inspected and 

repositioned. They have been placed on new concrete 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. 
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 24 

Radiation Environment 

Past operations at the Portsmouth site resulted in radiation exposures to on-site workers and offsite members of the public. Exposures of on-site workers generally were associated with the 

handling of radioactive materials used in the on-site facilities and with the inhalation of 

radionuclides released from processes conducted on the site. Off-site members of the public were 

exposed to radionuclides discharged from on-site facilities with airborne and/or waterborne 

emissions and, in some cases, to radiation emanating 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 radionuclides 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 buildings 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 from 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 released to the Scioto River, 1.1 mrem from direct radiation 

from DU cylinder storage yards, and 0.53 mrem based 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 the 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 facility 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 cylinder 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 Portsmouth 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 TCE) and radionuclides (e.g., uranium, and 99Tc). 

Data from annual groundwater monitoring (DOE 2007b) showed that no contaminants exceeded 

their primary drinking water standards at off-site locations near the Portsmouth site. TCE was 
Final Environmental Assessment: 

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 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 contamination through a variety 

of groundwater remediation and containment systems, including phytoremediation, pump-andtreat systems, and barrier walls. 

Air Quality 

The Portsmouth site is located in the Wilmington-Chillicothe-Logan Intrastate Air Quality 

Control Region, which covers the south-central part of Ohio. 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 waste management program directs the storage, 

treatment, and disposal of waste generated by its operations at the DOE reservation at Piketon. 

The company must satisfy NRC, EPA, Ohio EPA, and Ohio Department of Health regulations as 

part of these activities. Waste generated by USEC at the DOE reservation and then transferred to 

DOE for storage, treatment, or disposal is subject to DOE Orders. Additional policies have been 

implemented by USEC for management of radioactive, hazardous, and mixed wastes generated 

at the site. The USEC is currently operating in accordance with an NRC Certificate of 

Compliance issued under 10 CFR Part 76. Waste collection and segregation activities are 

completed in accordance with applicable state and federal rules and regulations and site 

procedures. Wastes are collected and packaged, where feasible, at the location where the waste is 

generated. Wastes are also segregated into the various waste streams and handled accordingly to 

minimize the generation of hazardous 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. Solid nonradioactive hazardous waste is sent to 

permitted disposal facilities, and liquid nonradioactive hazardous waste streams are sent to 

approved treatment/disposal facilities such as the 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 Enrichment 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: 

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 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) located 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 which LES would purchase the land from Lea 

County. Before NEF construction began, the entire site was undeveloped with the exception of 

an underground carbon dioxide pipeline 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 feet). The nearest permanent resident is 

4.3 kilometers (2.6 miles) west of the proposed site near the junction of New Mexico 

Highway 234 and New Mexico Highway 18. 

New Mexico Highway 234 is a two-lane highway located 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 highway provides direct access to 

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

Figure 3-3. Eunice, New Mexico, Locator Map 
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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 site include isolated, small clusters of low- to 

moderate-size events (i.e., Richter magnitude earthquakes of 3 to 5.9). A review of earthquake 

data collected for the site and the vicinity indicates 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 attainment for all criteria air pollutants. 

Waste Management 

In Eunice and Hobbs, solid-waste-disposal 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 Eunice just across from the proposed NEF site. The 

landfill accepts all types 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, just within the northern limits of the City of 

Richland in Benton County, Washington. The fenced 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: 

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Figure 3-4. Richland, Washington, Locator Map 

The facility contains numerous buildings plus various outside facilities/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 production facilities, a number of 

SNM-handling production support facilities (product storage warehouses, waste treatment 

facilities, etc.), and a large number of non-SNM-handling production and administrative support 

facilities (materials warehouses, craft shops, office buildings, etc.). There is a UF6 cylinder 

storage facility for the receipt, handling, and storage of full, empty, and heel quantity UF6

cylinders, including weighing and assaying of cylinder contents. There is also a UF6 cylinder 

recertification facility. 

There are no public facilities (schools, hospitals, parks) in the immediate vicinity of the plant 

site. The nearest schools, Washington State University at Tri-Cities and the Hanford High 

School, are approximately 3 kilometers (2 miles) southeast of the plant, and the northernmost 

portion of Leslie Groves Park along the Columbia River is about 5 kilometers (3 miles) southeast 

of the site. The West Richland Public Golf Course 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 residential 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 approximately 2.4 kilometers (1.5 miles) to the east, and the Yakima 

River, a tributary to the Columbia, passes approximately 3 kilometers (2 miles) to the west. The 
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Columbia River is regulated by multiple dams upstream 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 relatively 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 manufacturing facility, the Richland plant can potentially 

impact the surrounding environment via plant effluents associated with routine or abnormal 

conditions. For the Richland plant, these effluents 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 impacts 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 AREVA NC, has been extensively investigated for 

earthquake potential. The records of eastern Washington show infrequent, low-intensity, deep 

earthquakes. During the past 100 years, there have been three earthquakes of intensity large 

enough to cause moderate damage to structures within 50 to 100 kilometers (30 to 60 miles) of 

the site, though no damage has been reported at AREVA NC. 

Groundwater 

Groundwater contamination in the shallow unconfined aquifer below the Richland facility is 

attributed to historic 1970s-era releases from the site’s former surface impoundment system. By 

the early 1980s, the impoundments were double-lined with inter-liner leachate 

detection/collection capability and not implicated in further environmental releases. More 

recently (1996-2006), the impoundment system has been removed from service under a 

Washington Department of Ecology (Ecology)-regulated cleanup/closure action. Under that 

action, the impoundments were emptied of their inventory and physically dismantled, and soil 

was remediated (removed and disposed of) to uranium, fluoride, and nitrate soil cleanup limits 

derived in accordance with Ecology’s Model 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 

235U enrichment of 3.5 percent. This limit was conservatively calculated in accordance with 

Ecology criteria to be protective of groundwater down to the EPA drinking water limit for 

uranium of 30 parts per billion (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 both constituents in the groundwater are lower than 

their respective EPA drinking water limits. 
Final Environmental Assessment: 

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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, nonradioactive, hazardous, or mixed wastes. These waste categories, their 

control strategies, and an estimate of release quantities are described in Section 2.1.2 of the EA 

for Siemens Power Corporation’s license renewal (NRC 1995). 

3.1.5 Global Nuclear Fuel-Americas, Wilmington, North Carolina 

Figure 3-5 illustrates the location 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 Energy 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 Map 
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Site Description 

GNF-A is situated on a 673-hectare (1,664-acre) tract of land located next to NC Highway 133 

(formerly designated Highway 117) and is approximately 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 County to the north. Due to the curving 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 sea level and is characterized by gently rolling land, with rivers 

and creeks and adjoining swamps and/or marshlands. 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 with 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 approximately 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; and 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 future railroad right-of-way, three potable water 

supply wells, and temporary truck parking. The south property line for approximately 900 meters 

(3,000 feet) is bordered by a new highway (Wilmington 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 concentrations are measured routinely at the southern fence line 

and are typically on the order of 4 × 10-15 microcuries per cubic centimeter (μCi/cc). 

Direct inhalation of airborne releases 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 population center 3 kilometers (2 miles) south 

of the facility and 2005 air stack releases. All releases were assumed to be 234U (Class Y 

insoluble). When direct data were not available, 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 individual dose at this population center to the 

entire 200,000 persons (2000 census) in the surrounding 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. Therefore, the average annual dose received by an 
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individual in the surrounding population from releases at this facility 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 radiation dose for the average individual in the surrounding area 

is typical of that received from natural background radiation in this location or elsewhere in the 

United States. Relative to the 10 CFR 20.1301 NRC off-site individual exposure limit of 

100 mrem per year, the annual dose during 1995-2005 to the nearest (potentially 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 activity 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 outfall was sampled for gross alpha concentrations 

during the 1995-2005 period. The highest average concentration during that period was 

1.23 × 10-7

μCi/cc in 2005. Compared with the 10 CFR Part 20 Appendix B limit, the 2005 site 

discharge was 41 percent 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 area 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 earthquake damage. Earthquakes produced by small faults along the 

Atlantic seaboard have the potential to cause damage, even if the faults do not reach the surface. 

The earthquake causing the most damage in North Carolina had an epicenter 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 surficial 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 rainfall and is not used for drinking water supplies. 

There has been no radiological impact to the principal aquifer. All monitoring data from the 

principal aquifer show uranium concentrations to be less than or at the minimum detectable 

level. Similarly, gross alpha activity concentration data from three process water supply wells 

continue to be at natural background levels (at or near the detection limit). 

Air Quality 

New Hanover County is designated as being in attainment for all criteria air pollutants. 
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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 monitored to demonstrate compliance with 

regulations. Liquid wastes are treated and sampled prior to discharge. Various solid wastes are 

generated from the manufacturing processes. These 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 management program provides the capability to 

select the most suitable management technique for a specific waste. The management concepts 

employed include eliminating waste; reducing volume through source separation; compacting 

and incinerating wastes; recycling and reusing wastes; and selling used sodium hydroxide and 

aqueous hydrogen fluoride (HF) (<50 percent). Waste materials are collected according to the 

following two primary classifications: uranium-contaminated or contamination-free. Exhibit C-7 

in the GNF-Americas Wilmington environmental report supplement (GNF-A 2007) represents 

the GNF-A waste management program by primary classification and end use or disposal 

method. 

3.1.6 Westinghouse Electric Corporation CFFF, Columbia, South Carolina 

Figure 3-6 illustrates the location 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 Westinghouse 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 the 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 unimproved roads. Much of the land within the site 

boundary is designated agricultural. A variety of activities are conducted in the undeveloped 

portion of the site. These activities include managing the forested areas for timber production 

and harvesting hay fields. Recreational facilities in the undeveloped portion of the site include a 

fitness trail, softball field, and a picnic pavilion for employee use. Employees are permitted to 

fish and hunt in designated areas on the CFFF property. 
Final Environmental Assessment: 

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

The land around the CFFF site is used for a variety of purposes. Two schools are located within 

an 8-kilometer [5-mile] radius of the CFFF. South Carolina Electric and Gas is constructing a 

new commercial electrical substation on approximately 2.8 hectares [7 acres] along the 

northwest border of the CFFF property on land purchased 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 land 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 kilometers (5 miles) southeast of the CFFF is the 

Congaree National Park. Other facilities in the vicinity include the Richland County Detention 

Center located 8 kilometers (5 miles) to the north. Two major military installations are located 

near the CFFF: Fort Jackson Military Reservation approximately 11 kilometers (7 miles) north, 

and McEntire Joint National Guard Station approximately 9.7 kilometers (6 miles) northeast. 

Columbia and the surrounding area contain a well-developed and maintained system of 

interstate, regional, and local highways that provide easy year-round access. Three interstate 

highways serve Columbia. The CFFF site can be accessed by state highway SC 48. Although 

CSX Transportation Inc. operates two rail lines close to the CFFF site, there are no rail lines or 

spurs on the property. 
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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 airborne pathway. Typical cumulative 

CFFF stack emissions would result in a total effective dose of less than 0.4 mrem to a 

hypothetical exposed individual living at the site boundary. For the 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 from air emissions cited in 10 CFR 20.1101. In 

contrast, the annual radiological total effective dose from liquid effluents is only 3 × 10-4 mrem. 

The annual total effective dose from the combined effluent 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 tectonic 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 characterized by small-magnitude background earthquakes 

and very infrequent moderate-to-large intra-continental 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 located 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-ground 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 collected quarterly and analyzed for radiological 

components. Analysis results indicate small radiological impacts to groundwater 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 levels 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 around 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. Pending final EPA action, the state 
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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 the site. Gaseous effluents from the radioactive 

material operations are treated and sampled before being released to the environment. Several 

types of liquid effluents streams are produced. These effluent streams are treated to remove 

radiological and nonradiological contaminants and 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 that could be affected by DOE’s Proposed Action. 

Unless otherwise noted, the following description of the uranium market is based largely on a 

discussion of the uranium market available on the 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 fuel, it must undergo four intermediary processing 

steps, which collectively comprise the “front end” of the uranium fuel cycle: 

• mining and milling to produce triuranium octoxide (U3O8), also called yellow cake or 

urania, 

• refining and conversion to produce UF6 and uranium dioxide (UO2), 

• 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. 
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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 U3O8); (2) from conversion services that convert U3O8 to UF6; (3) from 

enrichment (the process of enriching UF6 to LEU), and (4) from downblending HEU. Together, 

U3O8 plus UF6 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 countries within the former Soviet Union, Eastern 

Europe, and China. Most of the fuel required for nuclear power plants in these countries is 

supplied from their own stockpiles. Often, producers within these countries also supply uranium 

and fuel products to the western world market, thereby increasing competition. Fewer than 

100 companies buy and sell uranium in the western world market. 

Figure 3-7 Uranium Fuel Cycle 
Final Environmental Assessment: 

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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 and 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 relatively few countries. In 2007, seven companies 

marketed 85 percent of the estimated world uranium mine production of 41,279 tonnes U308

(WNA 2008). 

Since 1985, western world uranium production has fallen short of western world utility uranium 

consumption. This shortfall has been covered by a number of secondary sources. Excess 

inventories held by utilities, producers, other fuel cycle participants, 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 reprocessed uranium and plutonium derived from used reactor fuel as a 

source of supply. In recent years, another source 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 weapons has become a significant source of LEU 

supply. 

Demand Factors 

Demand for uranium is directly linked to the level 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 factors 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 electricity markets in many countries. Historically, 

electric power utilities in the western world have operated in regulated electricity markets. 

Typically, a government regulator allowed each utility to serve a captive market area and earn a 

prescribed rate of return on its assets. The focus was on delivering 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 varying degrees in Europe and the Far 

East. 

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

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

unclear. The new bottom-line focus has necessitated changes in utilities’ planning and 

operations, including improving operating methods, lowering unit production costs, and 

optimizing the use of assets. Faced with the challenge of deregulation, electric utilities worldwide have been restructuring through mergers and acquisitions. 

U.S. nuclear utilities have dramatically improved the operating performance of their reactors. 

One measure of performance is the capacity factor. In 2007, the 104 U.S. nuclear power reactors 

generated a record 806.5 billion kilowatt-hours and achieved an average 91.8 percent capacity 
Final Environmental Assessment: 

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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, uranium has historically not been traded on an 

organized commodity exchange. Instead, it is traded in most cases 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 provide 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, such as the uranium spot price, and rules for 

escalation. In base-escalated contracts, the buyer and seller agree on a base price that escalates 

over time on the basis of an agreed-upon formula, 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 consists of just one delivery and is typically priced at or near the 

published spot market price at the time 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 the month prior to the delivery date. Spot market 

delivery quantities vary from 23,000 kilograms (50,000 pounds) to a few hundred thousand 

pounds U3O8. Over the last few years, about 15 percent 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-term, multi-year contracts 

with deliveries starting 1 to 3 years after contract award. Long-term 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 the buyer to vary the size of each delivery within 

prescribed limits. For example, delivery quantities may vary from the prescribed annual volume 

by plus or minus 15 percent. 

To diversify market risks, producers and utility customers often maintain a mix of contract terms 

and pricing mechanisms in their contract portfolios. Buyers are often willing to pay a premium in 

long-term contracts compared to spot prices, because they can achieve secure supply at prices 

that are more predictable. 
Final Environmental Assessment: 

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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. Subchapter A of Title III of Public Law 104-134, the 

USEC Privatization Act, in Section 3103, authorized USEC’s Board of Directors, with approval 

of the Secretary of the Treasury, to transfer the interest of the United States in USEC to the 

private sector in a manner that provides for the 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 uranium mining, enrichment 

and conversion services, and, to the extent not inconsistent with 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 may be delivered to the United States by Russia. The dismantled 

weapons contain a valuable resource for Russia. HEU can be blended down into LEU and sold in 

the western world market as reactor fuel for hard currency. 

In 1994, the USEC, as agent for the U.S. government, 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 companies, AREVA and RWE Nukem (now part of 

EnergySolutions), concluded an agreement with Russia whereby they have the option to 

purchase the majority of the natural feed component of LEU. This agreement is officially called 

the UF6 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 predictable revenue to the Russians. 
Final Environmental Assessment: 

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4.0 ENVIRONMENTAL IMPACTS 

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

the No Action Alternative. Consistent with DOE and CEQ guidance, this assessment focuses on 

those areas where there is a potential for impacts to occur. 

4.1 Existing Analyses and Scope of Impact Assessment 

This section reviews existing, relevant NEPA documents; identifies resource areas that DOE 

believes would not be impacted by the Proposed Action 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 scheduled. The enrichment operations that would be 

implemented under DOE’s Proposed Action would use existing work forces and existing plant 

and community infrastructures, and would not involve construction or expansion of any new 

uranium enrichment or uranium fuel fabrication 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 storage, 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 facilities would be unchanged, 

either adversely or beneficially, by the Proposed 

Action. Any potential incremental impacts at the three 

nuclear fuel facilities from DOE’s Proposed Action would be associated with on-site delivery 

and storage of LEU product, which is currently occurring at the facilities and has been previously 

assessed in NRC licensing and NEPA documents. 

Because the Proposed Action involves no new construction 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, historical, or archaeological resources; visual 

resources; ambient noise levels; threatened or endangered species or their critical habitats; 

wetlands; or floodplains. The existing and projected enrichment facility and FFF operational 

work forces previously analyzed would not change 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 criteria air pollutant emissions beyond 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 technology. 
Final Environmental Assessment: 

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activities would occur complies with applicable ambient air quality standards17. Health impacts 

related to air emissions resulting from transportation 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, which identified no environmental justice impacts 

due either to the absence of minority or low-income populations, or to the absence of adverse 

impacts to any population. 

The NEPA documents prepared by DOE and NRC for the enrichment facilities and FFFs that 

could be used to implement the Proposed Action are summarized below and are incorporated by 

reference in accordance with 40 CFR 1502.21. The following subsections summarize the impacts 

from previous DOE and NRC analyses of uranium 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 impacts of the sale of approximately 35.7 million 

pounds of natural uranium equivalent [U3O8 (e)] (approximately 13,730 MTU) of surplus NU 

and LEU in the form of UF6, stored at the department’s GDPs near Piketon, Ohio, and at 

Paducah, Kentucky (DOE 1996).18 That EA analyzed six categories of potential impacts: 

radiation exposure under normal operations, transportation 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 environment within the meaning of NEPA.19 

The 1996 EA demonstrated that the proposed sale would not have a significant impact on 

collective radiological doses to workers or the public due to transportation 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 radiological dose to workers in the mining 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 slight increase in dose to 

port workers and cylinder handlers at the GDPs. Impacts 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 potentially fatal exposures to HF could result if a cylinder were to 

fall and be punctured while its UF6 contents were temporarily in liquid form (heated) for 

purposes of sampling; however, the probability 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 EISs 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 associated with uranium enrichment operations at 

the Paducah GDP (DOE 1982) and subsequent NRC 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 substantial modification, is not a Federal action 

significantly affecting the quality of the human environment.” 

However, the modes of operation at the Paducah GDP have evolved since the DOE’s 1982 

NEPA review and FONSI. In March 2001, NRC amended USEC’s operating certificate for the 

Paducah GDP. The amendment permits USEC to enrich uranium to levels up to 5.5 percent 235U. 

NRC reviewed environmental impacts associated with higher assay operations at the facility. As 

reported in an October 2000 Compliance Evaluation Report (NRC 2000): 

“NRC reviewed available environmental review documentation for the PGDP that 

was prepared in accordance with the National Environmental Policy Act. Available 

NEPA documents include site-wide environmental assessments by both the 

Department of Energy and the United States Enrichment Corporation, and an NRC 

environmental assessment for approving USEC’s compliance plan that was 

associated with their initial certificate application. The NRC staff conducted this 

review to ensure that environmental effects associated with facility changes in 

support of higher assay operations remained 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 NRC staff finds that issuance of the 

Certificate Evaluation Report for higher assay operation at the PGDP will not result 

in any significant new environmental impact.” (Italicized emphasis added.) 
44 

Table 4-1. Summary of Impacts from National Enrichment Facility Construction, Operation, and Decomm

Resource Area Impact Summary 

Land Use Small Impact. Construction activities would occur on about 81 hectares (200 acres) of a 220-hectare (543-ac

fenced. The land is currently undisturbed except for a gravel access road, cattle grazing, and the presence of a 

Historical and Cultural 

Small Impact. There are seven archaeological sites on the proposed site. These sites are considered eligible f

Register of Historic Places. Two sites would be impacted by construction activities and a third is along the ac

Visual and Scenic Small Impact. Impacts from construction activities would be limited to fugitive dust emissions that can be co

suppression techniques. The cooling towers could contribute to the creation of fog 0.5 percent of the total hou

year). The proposed NEF site received the lowest scenic-quality rating using the U.S. Bureau of Land Manag

inventory process. 

Air Quality Small Impact. Air concentrations of the criteria pollutants predicted for vehicle emissions and emissions of p

than 10 microns in diameter (PM10) from fugitive dust during construction would all be below the NAAQS. F

would be temporary and localized. A National Emissions Standards for Hazardous Air Pollutants Title V perm

required for operations due to the low levels of estimated emissions. All stack emissions would be monitored

Geology and Soils Small Impact. Construction-related impacts on the geology and soil would occur within the 81-hectare (200-

which the proposed NEF structures would be built. Clay and gravel from a nearby site might be used during ccontamination would be expected during construction and operations. A plan would be in place to address anThere would be no construction or operational impacts on unique mineral deposits or geological resources. 

Water Resources Small Impact. There are no existing surface water resources. Impacts on water use would be small because o

excess capacity in the Hobbs and Eunice water supply systems. The proposed NEF’s indirect use of the Ogal

through the Eunice and Hobbs water supply systems would constitute a small portion of the aquifer reserves i

Ecological Resources 

Small Impact. Construction, operation, and decommissioning of the proposed NEF would have small impactresources. There are no wetlands or unique habitats for threatened or endangered plant or animal species on thA large part of the site would remain undisturbed and in its natural state. The impacts of the use of water dete

would be small because animal-friendly fencing and netting or other suitable material over the basins would b

animal intrusion. Revegetation using native plant species would be conducted in any areas impacted by propodesign and construction of the electrical transmission lines would address the protection of birds from electric 

Socioeconomics Small Impact. During the 8-year construction period, the estimated employment would average nearly 400 j

increase in the number of school-aged children during construction would average about 40. The impact on thbe small—less than one new student per grade. Tax revenue impacts during construction would be moderate. proposed NEF would employ a maximum of 210 people annually and would indirectly create an additional 1local employment would be moderate—approximately 1 percent of the jobs in the area. The increase in demawould be small. Decontamination and decommissioning (D&D) would generally have small impacts.
45 

Table 4-1. Summary of Impacts from National Enrichment Facility Construction, Operation, and Decomm

Resource Area Impact Summary 

Environmental Justice 

Small Impact. Although the impacts to the general population were small to moderate, an examination of the pathways by which populations could be affected found no disproportionately high and adverse impacts from or decommissioning on minority and low-income populations living near the proposed NEF or along the tranand out of the proposed NEF. 

Noise Small Impact. Noise would come predominantly from traffic. Noise levels during operations would be withi

Housing and Urban Development guidelines. 

Transportation Small 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 oHighway 234. Workforce traffic would also have a small impact on New Mexico Highway 234, with less thathan one fatality expected annually due to traffic accidents. Truck shipments of feed, product, and waste mate

would result in two latent cancer fatalities (LCFs) to the general population over the life of the proposed NEF emissions and fewer than 3 × 10-2 LCFs due to direct radiation. All rail shipments of feed, product, waste mat

cylinders would result in fewer than 8 × 10-2 LCFs to the general population over the life of the proposed NE

emissions and 1 × 10-1 LCFs from direct radiation. If a rail accident involving the shipment of DUF6 occurred 

28,000 people could suffer adverse but temporary health effects with no fatalities due to chemical impacts. A the shipment of DUF6 in an urban area could have temporary adverse chemical impacts on as many as 1,700 

Small Impact during Decommissioning. Small impacts would occur if DUF6 were temporarily stored at the 

duration of operations. Assuming that all of the material were shipped during the first 8 years (the final radiat

decontamination would occur during the ninth year), the proposed NEF would ship approximately 1,966 tructrucks were limited to weekday, non-holiday shipments, approximately 10 trucks per day or 21⁄2 railcars per dfor the DUF6 conversion facility.

Public and Occupational Health and Safety 

Small Impact during Construction and Normal Operations. During normal operations, there would be ap

injuries per year and no fatalities, based on statistical probabilities. A typical operations or maintenance technto 100 mrem of radiation annually. A typical cylinder yard worker could be exposed to 300 mrem of radiation radiological exposures would be significantly below the 10 CFR Part 20 regulatory limit of 100 mrem and the regulatory limit of 25 mrem annually for uranium fuel cycle facilities. The nearest resident would receive less 

due to normal NEF operations. Small to Moderate Impact for Accidents. The most severe accident is estimated to be the release of UF6 ca

overfilled and/or overheated cylinder, which could result in a collective population dose of 12,000 person-rem 

design of the proposed NEF would include certain features to significantly reduce the likelihood of this event
46 

Table 4-1. Summary of Impacts from National Enrichment Facility Construction, Operation, and Decomm

Resource Area Impact Summary 

Waste Management 

Small Impact. Solid wastes would be generated during construction and operations. Existing disposal faciliti

capacity to dispose of the nonhazardous solid wastes. In particular, impacts on the Lea County landfill would 

be enough existing national capacity to accept the low-level radioactive waste that would be generated at the Small to Moderate Impact for DUF6 Waste Management. Public and occupational exposures would be mo

to meet NRC regulations for radiation protection. LES identified two potential means for disposing of DUF6: 

and disposal facilities or by DOE through Section 3113 of the USEC Privatization Act. LES’s preferred stratefacilities outside of the State of New Mexico to convert and dispose of the DUF6 byproduct. No final location 

for a private conversion facility, but the EIS contemplated potential DUF6 conversion at a non-DOE facility. 

would process the DUF6 by extending the operation of its conversion facilities. This would prolong the impac

facilities, as described in DOE’s NEPA documentation. A private conversion facility would have much the saplanned DOE conversion facilities at Paducah, Kentucky, and Portsmouth, Ohio. 

Source: NRC 2005. 
47 

Table 4-2. Summary of Impacts from American Centrifuge Plant Construction, Operation, and Decommiss

Resource Area Impact Summary 

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

comprises about 1 percent of the total 1,497-hectare (3,700-acre) DOE reservation. These changes would cdisturbed land (e.g., managed lawns, fields, and forests) on the DOE reservation to developed areas. The laprime farmland, and changes would be consistent with current land use. It is anticipated that after decommare completed, existing buildings and structures would remain on-site and the site would remain categorize

Historical/ Archaeological 

Small Impact. NRC identified the Portsmouth GDP historic district, thirteen historic farmsteads, and one p

scatter as being potentially eligible for inclusion on the National Register of Historic Places. In addition, N

properties located around the perimeter in its consideration of potential effects. There would be no adverse 

effect on these sites. 

Visual Small Impact. Construction of the proposed ACP would not alter the site’s Bureau of Land Management V

Management rating system classification of Class III or IV (moderate to little scenic value). There are no sc

preserves, or unique visual resources in the proposed project area. 

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

quality standards, with the possible exception of short-term increases in particulate matter that could excee

standard up to a distance of 1,000 meters (3,280 feet) beyond the fenceline. Radiological releases from soil from activities to refurbish existing buildings that would be used for the ACP would be small and controlle

diesel generators would not cause air quality problems, and maximum predicted concentrations of HF resuloperations are below safe levels. 

Geology and Soils Small Impact. There is little likelihood of impact from soil compaction or subsidence, and there are no uni

or geologic resources that stand to be affected. The flat terrain where the ACP buildings would be located, 

low moisture content, and vegetative cover in the area of a new 10-hectare (24-acre) cylinder storage yard another spot on the reservation make landslides unlikely. Construction activities would not alter current dradisturb any soils that qualify for protection as prime farmland. There would be a potential for increased ero

streams near the construction site of the new large cylinder storage yard, but both of these potential impactminimized by the use of standard best management practices. The potential for soil contamination resulting operations would be small. A plan would be in place to address any spills that might occur. 

Water Resources Small Impact. Groundwater withdrawals would increase by 10 percent over current usage rates, but would 

31 percent of the total design capacity of the site’s well fields, would not affect groundwater availability, an

increased risk of subsidence. Wastewater would continue to discharge from permitted National Pollutant DSystem outfalls. Discharge rates, though increased above current levels, would represent only 75 percent of 

system’s design capacity. USEC does not anticipate any liquid discharges of radioactive materials from the from cooling water, storm water runoff, or sanitary water). The potential for leaks or spills that could conta

resources would be limited by an approved Spill Prevention Control and Countermeasures Plan. 
48 

Table 4-2. Summary of Impacts from American Centrifuge Plant Construction, Operation, and Decommiss

Resource Area Impact Summary 

Ecological Resources Small Impact. Construction of the new large cylinder storage yard referenced in the section on geology a

in increased erosion, stormwater runoff, and loss of 10 hectares (24 acres) of vegetation but, with planned practices, would result in small impacts to the flora and fauna in and around the tributaries of Little Beave

cylinder storage yard would also be located within 500 meters (1,640 feet) of suitable summer habitat for 

Indiana bat, although studies have not documented the presence of this bat species on the DOE reservation

construction activities would occur in wetlands. However, some construction would occur adjacent to smastandard erosion control measures would be used to limit sedimentation in these areas. 

Socioeconomics Small to Moderate Impact. During construction, full-time employment is estimated to be 3,362 jobs. Th

employment during construction would be approximately 3.5 percent, which is considered moderate. The during construction is expected to be small, generating 0.03 percent of Ohio individual income tax receiptsales tax. The impact to tax revenue is considered small. The impact to population characteristics is considapproximately 0.13 percent of the regional population. The impact to area housing, community services, awould also be small. During the ACP operations phase between the years 2010 and 2040, 1,500 jobs woulregion of influence. These impacts to regional employment are considered moderate, based on existing emregion. During operations, there would be a small increase in regional tax revenues as well as small impaccharacteristics, housing resources, community and social services, and public utilities. 

Environmental Justice 

Small Impact. An examination of the various environmental pathways by which low-income and minoritaffected found no disproportionately high or adverse impacts from construction, operation, or decommissipopulations. 

Noise Small Impact. No adverse noise impacts from routine ACP operations are expected at the closest residen

operational noise, the attenuation provided by the building facade, and distance attenuation of over 900 m

Catastrophic failure of a centrifuge could cause a sudden, brief loud noise due to the high rotational speed However, the likelihood of a single centrifuge catastrophically failing is very low. Noise levels during D&

to be small and similar to those generated during construction of the ACP. 

Transportation Small to Moderate Non-radiological Impacts from Routine Transportation. 

Increased truck and vehicle traffic associated with proposed ACP operations should result in small change

congestion and delays on U.S. Route 23 and Ohio State Road 32. Traffic associated with proposed operatiin small increases in the number of traffic accidents resulting in injuries or fatalities. Substantially greater requirements during the construction phase could result in moderate impacts during the 5-year period in wproposed construction activity is projected to occur. The NRC estimates that increased traffic during constemporarily decrease the level of service on U.S. Route 23 and, to a lesser extent, on Ohio State Road 32. 

U.S. Route 23 would temporarily increase traffic density, affect the ability to maneuver within the traffic 
49 

Table 4-2. Summary of Impacts from American Centrifuge Plant Construction, Operation, and Decommiss

Resource Area Impact Summary 

travel speeds somewhat. It is also expected that construction traffic accidents would result in about 18 injuemployees traveling to and from their jobs, and 1 fatality over the entire construction period. These same rates would be expected if the same employees were driving to different employers. Small Radiological Impacts from Routine Transportation and Transportation Accidents. The transpcontaining radionuclides would result in some increased risk of cancer both to the occupational workers trhandling the material and to members of the public driving along the roads or living along the transportatitransport of all materials is estimated to result in approximately 0.014 LCFs per year of operation from exradiation during “incident-free” transport (i.e., shipping that does not involve the breach of a shipping con

release of radioactive material), and an additional 0.008 LCFs per year from accidents that result in the re

material into the environment. The total LCFs is estimated to be 0.02 per year of operation, or less than onthe 30 years of operation. Moderate Non-Radiological Impacts from Transportation Accidents. Transportation accidents involv

which is the form of uranium that would be transported the most to and from the proposed ACP, could alsimpacts to drivers and the surrounding public. When released from a shipping cylinder, UF6 reacts with th

atmosphere to form HF and uranyl fluoride (UO2F2), both of which can cause adverse effects due to chem

opposed to radiation hazards) if exposures are high enough. The analysis shows that the probability of a seaccident that released sufficient quantities of UF6 that could pose a health risk is low, but that the consequ

accident, should it occur, are high. Based on the analysis, the impacts associated with such an accident as 

action are considered moderate. Small Impact During D&D. Traffic associated with material and equipment transportation to the site durbe much lower than that during site preparation and construction. D&D activities, including waste generatwould require almost 5,000 truck shipments for off-site disposal over the 5-year decommissioning period Because this volume of truck traffic is far less than the estimated 17,870 truck trips needed during the 5-y

construction period, the transportation impacts associated with the decommissioning truck traffic should bdescribed for site preparation and construction. The number of LCFs from the incident-free transportation estimated to be less than one, and there are no projected deaths resulting from the release of radioactive maccidents during such shipments. 
50 

Table 4-2. Summary of Impacts from American Centrifuge Plant Construction, Operation, and Decommiss

Resource Area Impact Summary 

Public and Occupational Health and Safety 

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

at the site, though still less than historical levels. Construction and process areas would be segregated, and 

programs would be implemented, to minimize worker exposures to annual radiation doses of less than the limit of 5,000 mrem. The maximum dose to members of the public resulting from routine radiation exposu1 mrem per year, for a hypothetical person living on the northern boundary of the DOE reservation. This esignificantly below the 10 CFR Part 20 regulatory limit of 100 mrem per year and 40 CFR Part 190 regulaper year for uranium fuel-cycle facilities. Analytical results also indicate that plausible radiological accidents at the proposed ACP pose low risks. Ioccupational exposures to non-radiological contaminants are projected to be less than applicable limits. Oduring on-site D&D would be bounded by the potential exposures during operation. At the end of plant lifcontaining residual uranium would be purged, leaving radioactive material in amounts significantly less thoperations. Because systems containing this residual contamination would be opened, decontaminated (wiradioactive material processed and packaged for disposal), and dismantled, an active environmental and dinternal) program would be conducted to maintain as low as reasonably achievable (ALARA) doses to wo

individual members of the public as required by 10 CFR Part 20.

Waste Management Small Impact. Site preparation, construction, and operations would generate varying amounts of low-leve

level mixed, hazardous, sanitary/industrial, and recyclable wastes. All of these wastes would be managed 

existing procedures for controlling contaminant releases and exposures. With the exception of the DU, all 

also 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 

material. Production of DUF6 for the 10 percent enrichment scenario would be less than this amount. All o

converted to a more stable chemical form at a new conversion facility that DOE is constructing near Piketrequire DOE to significantly extend the life of this facility. The converted material would then be shipped acceptable western disposal site, where sufficient capacity exists and where the disposal impacts should b

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 construction and operation of proposed UF6 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 during conversion facility 

construction; (2) impacts to workers from facility construction and operations; (3) impacts from 

small amounts of DU and other hazardous compounds released to the environment through 

normal conversion plant air effluents; (4) impacts from the cylinder preparation, shipment of 

cylinders, conversion products, and waste products; 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 construction (now complete at Portsmouth and nearly 

complete at Paducah) rather than the future operation of the new conversion 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 assessed 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 facility EISs evaluated continued storage of NU 

and LEU cylinders as part of their 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. Table 4-3 summarizes the 

impacts for DU conversion assessed in the PEIS 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 DUF6 cylinders for off-site 

transportation. DUF6 cylinders were designed, built, tested, 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 1999b). As one option, cylinders that do not meet 

DOT requirements could be placed inside protective metal “overcontainers” for shipment. These 

reusable overcontainers, which would be slightly larger than a cylinder, would be designed to 

meet all DOT requirements. Another option is to transfer a cylinder’s contents to a new cylinder. 

Under this option, the DUF6 in cylinders that do not meet DOT requirements would be 

transferred to new cylinders capable of being transported. Activities associated with transfer to 

another cylinder include general maintenance and monitoring of cylinders and the valves, 

inspections, painting, repairs, and use of a heating 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). 
52 

Table 4-3. Summary of Expected Impacts from Operation of the Paducah and the Portsmouth Conversion 

Resource Area Impact 

Land Use Negligible. Cultural Resources None. Resource Requirements 

Resource requirements include construction materials, fuel, electricity, process chemicals, and containers. I

there would be a negligible effect on the local or national availability of these resources. 

Air Quality During general operations, it is estimated that total concentrations for all criteria pollutants (except for PM2

well within standards. The background level of annual average PM2.5 in the area of both sites approaches or 

standard. The total concentrations of VOCs, uranium, and fluoride would also be well below applicable stanstandard cylinder preparation at Paducah, concentrations of criteria pollutants would be below 0.03% of the standards. Overcontainer and transfer operations would be below 0.08% of standards for criteria pollutants. from 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 

conversion facilities because no contaminated liquid effluents are anticipated and because airborne emission

at very low levels (e.g., < 0.25 grams per year of uranium). For cylinder preparation activities, there would negligible impacts to surface water and groundwater. 

Ecological Concentrations of contaminants in the environment during operations would be below harmful levels. Impa

vegetation and wildlife would be negligible. 

Socioeconomics An estimated 150 jobs would be generated during construction of the cylinder yard, and an estimated 280 jo

generated during construction of the conversion facility. There would be an approximate 0.1 percent annual jobs. With limited in-migration of population expected, there would be a marginal impact on local housing, financing, or local service employment. 

Environmental Justice 

No disproportionately high and adverse human health or environmental impacts are expected to minority or populations. 

Noise Estimated operational noise levels at the nearest residence would be below the EPA guideline of 55 A-weig

(dB[A]) as day-night average sound level for residential zones. 
53 

Transportation During normal transportation operations, radioactive material and chemicals would be contained within thei

packages. Health impacts to crew members (i.e., workers) and members of the public along the routes could 

they were exposed to low-level external radiation in the vicinity of uranium material shipments. In additionvehicle emissions (engine exhaust and fugitive dust) could potentially cause latent fatalities from inhalationTraffic accidents could occur during the transportation of radioactive materials and chemicals. These accide

potentially affect the health of workers (i.e., crew members) and members of the public, either from the acc

from 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 tstatistics on shipments by both truck and rail. If the aqueous HF was sold, about 1 traffic facility would be eunder both transportation modes. If HF were neutralized to calcium fluoride (CaF2), about 2 fatalities would 

estimated for the truck option and 1 fatality for the rail option. Severe transportation accidents could also result in a release of radioactive material or chemicals from a shi

consequences of such a release would depend on the material released, location of the accident, and atmosp

conditions at the time. Potential consequences would be greatest in urban areas because more people could 

Human Health and Safety – Normal Operations 

For general operations, the estimated potential exposures of workers and members of the public to radiation chemicals would be well within applicable public health standards and regulations during normal facility op(including 10 CFR Part 835, 40 CFR Part 61 Subpart H, and DOE Order 5400.5). The estimated doses and rradiation and/or chemical exposures of the public and noninvolved workers would be very low, with zero Lexpected among these groups over the time periods considered, and with minimal adverse health impacts fr

exposures expected. The estimated risks for involved workers would be as follows: preparation of standard cylinders: zero to 0.0overcontainer: 0.07 to 0.2 LCFs; transfer: 0.2 to 0.4 LCFs. There would be no impacts to the noninvolved wgeneral public from preparation of standard cylinders or overcontainers. Impacts from transfer operations fononinvolved worker are estimated at 2 × 10-8 to 5 × 10-8 LCFs, while impacts to the general public are estim

6 × 10-7 to 1 × 10-6 LCFs. No chemical impacts would be anticipated. The impacts at Portsmouth are estima

slightly less than those at Paducah.

Table 4-3. Summary of Expected Impacts from Operation of the Paducah and the Portsmouth Conversion 

(continued)

Resource Area Impact 
54 

Human Health and Safety – Facility Accidents 

For general operations, workers could be injured as a result of operational accidents unrelated to radiation o

exposure. About 8 injuries per year during operations could occur. It is possible that accidents could release chemicals to the environment, potentially affecting both the workers and members of the general public. Of 

accidents considered, those involving DUF6 cylinders and those involving chemicals at the conversion facil

have the largest potential effects. For cylinder preparation operations at Paducah, bounding radiological accidents with a frequency in the ran10,000 years to one in a million years: 

• The impacts to noninvolved workers are estimated at 6 × 10-3 LCFs, 

• 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 geare estimated to be slightly less at Portsmouth. The impacts from chemical accidents at Paducah with the same frequency of occurrence are estimated to be noninvolved 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 stpreparation and overcontainer activities, and 440 noninvolved workers would have irreversible adverse effetransfer operations. For both sites, the impacts to the general public from chemical accidents are estimated to be 1 person with iadverse effects from the preparation of standard cylinders and overcontainer operations, and zero impacts froperations. Potential impacts to groundwater, surface water, and soil under storage accident conditions were evaluated 

2004a and DOE 2004b. Impacts were found to be below all standards and health-based guides used for com

D&D Activities D&D impacts to involved workers would be primarily from external radiation; expected exposures would b

fraction of operational doses; no LCFs would be expected. It is estimated that no fatalities and up to five injresult from occupational accidents. Impacts from waste management would include a total generation of ab275 cubic yards (210 cubic meters) of LLW, 157 cubic yards (120 cubic meters) of LLMW, and 157 cubic (120 cubic meters) of hazardous waste; these volumes would result in low impacts compared with projected generation volumes. 

Waste Management Waste generated during operations would have negligible impacts on the waste management operations at b

with the exception of possible impacts from disposal of CaF2. Industrial experience indicates that HF, if pro

would contain only trace amounts of DU (less than 1 part per million). It is expected that HF would be sold sold, the sale would be subject to review/approval by DOE in coordination with the NRC, depending on the 

Table 4-3. Summary of Expected Impacts from Operation of the Paducah and the Portsmouth Conversion 

(continued)

Resource Area Impact 
55 

Table 4-3. Summary of Expected Impacts from Operation of the Paducah and the Portsmouth Conversion 

(continued)

Resource Area Impact 

Cumulative Impacts The cumulative collective radiological exposure to the off-site population would be well below the maximu

limit of 100 mrem per year to the off-site MEI and below the limit of 25 mrem/yr specified in 40 CFR Part 

uranium fuel cycle facilities. Annual individual doses to involved workers would be monitored to maintain below 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. 

cumulative maximum dose to the MEI along the transportation route near the site entrance would be les1 mrem per year under for all transportation modes. At Portsmouth, up to 6,800 rail shipments and 12,3shipments of radioactive material could occur. The cumulative maximum dose to the MEI along the tra

route 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 PM2.5 concentrati

(for Paducah) or exceeds (for Portsmouth) the regulatory standard. Cumulative impacts would not affecstatus. 

 Data from the 2000 annual groundwater monitoring showed that four pollutants (for Paducah) and five 

Portsmouth) exceeded primary drinking water regulation levels in groundwater. Good engineering and practices should ensure that indirect cumulative impacts on groundwater associated with the conversion would be minimal. 

 Cumulative ecological impacts on habitats and biotic communities, including wetlands, would be neglig

minor. 

 Cumulative land use impacts are anticipated to be negligible to minor.  Given the absence of high and adverse cumulative impacts for any impact area considered, no environm

cumulative impacts are anticipated despite the presence of disproportionately high percentages of low-ipopulations in the vicinity of both sites. 

 Socioeconomic impacts under all alternatives considered are anticipated to be generally positive, often 

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 DUF6 cylinders currently do not meet the DOT 

transportation requirements. If a cylinder failed 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 assessed in the two DU conversion facility EISs 

are very nearly identical. This reflects the fact that these facilities 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 234U and 235U. 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 assay of 0.20 percent would have a slightly lower 

radiological hazard than DU tails with an assay of 0.35 percent because of the decreased 234U. 

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 than the impacts of enriching NU. 

In the context of impacts at conversion facilities, 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 234U. In addition, given equal amounts of 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. Therefore, DOE has determined that the impacts of converting DU tails with an 

assay of 0.20 percent would be similar to or slightly less than the impacts of converting DU tails 

with an assay of 0.35 percent. At the Portsmouth conversion facility, the number of DU cylinders 

could increase slightly, from 20,931 to 21,086 (0.7 percent), as a result of the Proposed Action in 

this EA. At the Paducah conversion facility, the number of DU cylinders could also increase 

slightly, from 41,013 to 41,168 (0.4 percent), as a result 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 facilities and conversion facilities, DOE has determined 

that impacts to the human environment due to enrichment operations and conversion of DU tails 

from enrichment (1) have been adequately characterized 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 previously 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 LEU 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 Portsmouth and Paducah GDPs to the location(s) where it 

could be enriched. Enrichment could 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-central 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 accident 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 activities related to transportation practices and 

accidents. DOE Order 460.2A requires that DOE organizations conduct operations in compliance 

with all applicable international, federal, state, local, and tribal laws, rules, and regulations 

governing materials transportation that 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 set of standard transportation practices for DOE to use in 

planning and executing off-site shipments of radioactive materials. These practices establish a 

standardized process and framework for interacting with state, tribal, and local authorities, other 

federal agencies, and transportation contractors and carriers regarding DOE radioactive material 

shipments. Practices are described for the following topics: 

• Transportation planning—the transportation planning activities that take place after the 

need for shipment has been identified; 

• Emergency planning—DOE emergency planning activities with state and tribal 

jurisdictions; 

• Projected shipment planning information—provision of information regarding projected 

shipments; 
Final Environmental Assessment: 

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 58 

• Routing—practices to identify and select transportation routes; 

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

• Carrier/driver requirements—practices to ensure that shipments use high-quality carriers 

and drivers; 

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

• Transportation operational contingencies—operational contingencies that may interrupt 

normal transport operations; 

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

communication with the drivers/crew of the vehicles; 

• Inspections—inspections of shipments, including verifications of vehicle roadworthiness 

and radiological condition of containers loaded on the vehicles; 

• Safe parking—the criteria to be used in selecting appropriate parking locations in the 

event that transportation operational contingencies occur; 

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

DOE itself has received notification, of a transportation emergency; 

• Emergency response—DOE response to a transportation emergency; 

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

accident or incident. 

In addition, DOT regulation 49 CFR 171.15 contains requirements for notifications of 

transportation incidents involving hazardous materials. 

After enrichment, DOE could ship the LEU product to, 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 storage. If the NU product was stored, it would be done so in 

accordance with the NRC licenses or DOE requirements 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 from the enrichment, storage, and commercial nuclear FFFs were 

determined using the WebTRAGIS routing computer code (Johnson and Michelhaugh 2003). 

The routes conform with current routing practices and applicable routing regulations and 

guidelines. Route characteristics include the distances and population densities in rural, 

suburban, and urban population density zones. The populations that might be exposed along 
Final 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 transportation routes. Figure 4-1 illustrates the rail and truck 

routes. Barge traffic would be on the Mississippi River. Population data 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/km2) 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 30.4 780.7 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 18.5 957.1 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 2,873.4 
Final 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, incident-free transportation of radioactive materials result from 

exposure to the external radiation 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 UF6 containers ranges from about 0.2 to 1 mrem per hour (NRC 2005, 

NRC 2006). In this analysis, the radiation 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 UF6. 

Radiological impacts were determined for crew workers and the general population during 

normal, incident-free transportation. For truck shipments, the crew were drivers of the shipment 

vehicles. For rail shipments, the crew were workers in close proximity to the shipping containers 

during railcar inspection or classification. The general population was the individuals within 

800 meters (2,600 feet) of the road or railway (off-link), sharing the road or railway (on-link), 

and at stops. Collective doses for the crew and general population were calculated using the 

RADTRAN 5 computer code (Neuhauser and Kanipe 2000; Neuhauser et al. 2000). Individual 

radiation doses were also estimated for people along the route at a distance of 30 meters 

(100 feet) from the highway or railroad. Nonradiological incident-free impacts were also 

determined for exhaust and fugitive dust emissions from highway and rail traffic. 
Final Environmental Assessment: 

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 61 

Human health impacts could also result from transportation accidents in which no radioactive 

material would be released (i.e., traffic fatalities), 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 risks (probability of 

occurrence × consequence) expressed as the number of latent cancer fatalities (LCFs) summed 

over a complete spectrum of accidents, including the severe accidents presented in 

Section 4.2.1.5. Impacts were evaluated for the population within 80 kilometers (50 miles) of the 

road or railway using the RADTRAN 5 computer code. DOE assumed that people would be 

exposed through inhalation, direct external dose from radioactive material that has deposited on 

the ground after being dispersed from the accident site (referred to as groundshine), and direct 

external dose from the passing cloud of dispersed radioactive material (referred to as 

cloudshine). In addition to transportation accident risks, the radiological and toxicological 

consequences of severe transportation accidents involving UF6 releases were also evaluated. 

The total impacts of transportation are the sum of the radiological and nonradiological incidentfree and accident impacts. For incident-free transportation, the impacts are (1) the radiological 

impacts from exposure to low levels of radiation from the UF6 cylinders, and (2) the 

nonradiological impacts from truck or train exhaust (vehicle emissions). For accidents, the 

impacts are (1) the radiological risks associated with the UF6 being shipped, and 

(2) nonradiological traffic fatalities. The toxicological accident risks associated with the UF6

being shipped were not included with the estimate of accident risk because these risks were 

previously shown to be small relative to radiological 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 exposure to low or chronic levels of 

radiation. Radiological health impacts are expressed as the incremental changes in the number of 

expected fatal cancers (referred to as latent cancer 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, NRC, DOE, Department of 

Defense, Department of Homeland Security, DOT, Occupational Safety and Health 

Administration, and Department of Health and Human Services), three federal observer agencies 

(the Office of Science and Technology Policy, Office 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 general 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 UF6, 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 UF6 Manual, Good Handling 

Practices for Uranium Hexafluoride (USEC 2006). The characteristics of other cylinders used to 

ship or store UF6 are presented in Table 2 of the UF6 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 Cylinder 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 (ft3

) 108.9 142.7 139.0 26.0 

Weight limit (MT UF6) 9.539 12.501 12.174 2.277 

Weight limit (MTU) 6.45 8.45 8.23 1.54 

Maximum enrichment (weight percent 235U) 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 10,776a 10,776 2,695 167 

LEU feed 296 296 75 7 

LEU product 3,195 1,065 267 17 

DU tailsb

 10,931 10,931 2,733 169 

NU product 3,445 3,445 862 53 

DU tailsc

 6,450 6,450 1,613 100 

a. This EA uses 10,776 DU cylinders for its estimate of impacts. In Appendix D, comment #4 from USEC noted that the 

actual DU cylinder count would be less, later 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 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 LEU 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 enrichment greater than 

1.0 percent but less than 4.5 percent is typically shipped in 30B cylinders. However, most excess 

LEU feed is currently stored in 48X and 48G cylinders. The 48X cylinder is slightly smaller than 

the 48G cylinder. Therefore, the number of LEU feed cylinders was estimated 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 estimate of impacts. In light 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: 

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 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 cylinders. Therefore, the 

30B cylinder was used to estimate the number of LEU product cylinders. 

To estimate the radiological impacts associated 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, which tends to increase incident-free impacts, and 

is also the largest of the cylinders commonly used to ship NU and DU, which tends to increase 

radiological accident impacts. 

The radionuclide content of UF6 is due to the naturally occurring isotopes of uranium (234U, 235U, 

and 238U) and their short-lived radioactive progeny. Table 4-7 lists the radionuclide inventories 

of 234U, 235U, and 238U contained in the cylinders. 

Table 4-7. Radionuclide Inventory of Uranium Cylinders 

Material 

234U Inventory 

(Ci) 

235U Inventory 

(Ci) 

238U Inventory 

(Ci) 

NU feed or producta 2.8 0.13 2.8 

DU feedb 1.1 0.064 2.8 

LEU feedc

 7.4 0.31 2.8 

LEU productd

 4.4 0.16 0.49 

DU tailse

 0.50 0.037 2.8 

a. NU feed or product assumed to be 0.711 weight percent 235U. 

b. DU feed has a range of enrichments from 0.35 to less than 0.711 weight percent 235U. In this analysis, the DU feed 

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

page 5. 

c. LEU feed assumed to be 1.7 weight percent 235U. 

d. LEU product assumed to be 4.95 weight percent 235U. 

e. DU tails assumed to be 0.20 weight percent 235U. 

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 cylinders, one cylinder was assumed to be shipped 

on a truck. For 30B cylinders, typically three to five cylinders are shipped on a truck (NRC 2005; 

USEC 2006). Because three cylinders per truck would yield higher estimates of the number of 

shipments than five cylinders per truck, three cylinders were assumed 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: 

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 64 

4.2.1.1 Impacts from Truck Shipments 

For truck shipments of UF6, radiation doses were evaluated for workers and members of the 

public. Workers included the drivers of the trucks carrying the UF6, workers involved in loading 

and unloading the UF6 cylinders, and workers who inspected UF6 shipments. For members of the 

public, radiation doses were estimated for people 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 radiological accident risks were also estimated. The radiological and 

toxicological impacts of severe transportation accidents are discussed in Section 4.2.1.5. 

Transportation impacts were estimated for enrichment of NU, DU, and LEU feed to LEU 

product, for enrichment of DU feed to NU product, and for enrichment of DU feed to NU 

product followed by subsequent enrichment of NU product to LEU product. Transportation 

impacts also include transportation of LEU product to FFFs. Impacts are presented for enriching 

the entire surplus DOE inventory, and for enriching 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 truck shipments of UF6 are listed in Tables 4-8a, 4-8b, and 4-8c. Impacts are 

quantified in terms of total fatalities, which are the sum of radiation-related LCFs, vehicle 

emission health effects, and traffic 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 occurred 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 motor vehicle accidents in the United States (DOT 

2007). 

For enrichment of DU feed to NU product, the estimated 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 year ranged from 0.016 to 0.18, and the estimated 

number of fatalities from enriching the equivalent of 4,000 MTU of NU in a given year ranged 

from 0.030 to 0.32. 

For enrichment of DU feed to NU product followed by subsequent enrichment 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 enrichment 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. 
65 

Table 4-8a. Total Transportation Impacts from Truck Shipments of Uranium Hexafluoride under the Proposed Ac

Case Public (LCFs) Worker (LCFs) 

Vehicle Emission 

Health Effects 

(LCFs) 

Radiological Accident 

Risk (LCFs) Traffic Fatalities 

Enrichment to LEU at the Paducah GDP NU, DU, LEU feed 1.7 × 10-2 8.3 × 10-2 2.3 × 10-2 8.7 × 10-2 9.9 × 1LEU product 

(on-site storage) -- 5.2 × 10-3 -- -- 

LEU product if shipped 

to FFFsa 4.0 × 10-3 to 1.0 × 10-2 1.2 × 10-2 to 2.5 × 10-2 3.7 × 10-3 to 7.5 × 10-3 4.9 × 10-2 to 1.2 × 10-1 1.4 × 10-2 to 5.2 × 1

Total 1.7 × 10-2 to 2.7 × 10-2 8.9 × 10-2 to 1.1 × 10-1 2.3 × 10-2 to 3.0 × 10-2 8.7 × 10-2 to 2.1 × 10-1 9.9 × 10-2 to 1.5 × 1Enrichment of DU to NU at the Paducah GDP DU feed 1.3 × 10-2 6.7 × 10-2 1.8 × 10-2 6.3 × 10-2 7.9 × 1NU product 

(on-site storage) -- 8.0 × 10-3 -- -- 

Total 1.3 × 10-2 7.5 × 10-2 1.8 × 10-2 6.3 × 10-2 7.9 × 1Enrichment to LEU at the ACP (Portsmouth) NU, DU, LEU feed 1.1 × 10-2 6.5 × 10-2 1.5 × 10-2 5.7 × 10-2 6.5 × 1LEU product 

(on-site storage) -- 5.2 × 10-3 -- -- 

LEU product if shipped 

to FFFsa 3.4 × 10-3 to 1.2 × 10-2 1.3 × 10-2 to 2.8 × 10-2 4.2 × 10-3 to 8.3 × 10-3 6.3 × 10-2 to 1.2 × 10-1 1.1 × 10-2 to 5.9 × 1

Total 1.1 × 10-2 to 2.3 × 10-2 7.1 × 10-2 to 9.3 × 10-2 1.5 × 10-2 to 2.3 × 10-2 5.7 × 10-2 to 1.8 × 10-1 6.5 × 10-2 to 1.2 × 1Enrichment of DU to NU at the ACP (Portsmouth)DU feed 9.0 × 10-3 5.3 × 10-2 1.2 × 10-2 4.2 × 10-2 5.3 × 1NU product 

(on-site storage) -- 8.0 × 10-3 -- -- 

Total 9.0 × 10-3 6.1 × 10-2 1.2 × 10-2 4.2 × 10-2 5.3 × 1Enrichment to LEU at the NEF NU, DU, LEU feed 6.6 × 10-2 2.2 × 10-1 9.3 × 10-2 4.2 × 10-1 4.1 × 1LEU producta 6.1 × 10-3 to 1.0 × 10-2 1.6 × 10-2 to 2.4 × 10-2 5.2 × 10-3 to 8.1 × 10-3 8.0 × 10-2 to 1.4 × 10-1 2.7 × 10-2 to 5.1 × 1DU tails (to Portsmouth 

or Paducah) 4.0 × 10-2 to 6.3 × 10-2 1.6 × 10-1 to 2.0 × 10-1 5.3 × 10-2 to 9.1 × 10-2 1.8 × 10-1 to 3.1 × 10-1 2.8 × 10-1 to 3.7 × 1

Total 1.1 × 10-1 to 1.4 × 10-1 3.9 × 10-1 to 4.4 × 10-1 1.5 × 10-1 to 1.9 × 10-1 6.7 × 10-1 to 8.7 × 10-1 7.2 × 10-1 to 8.3 × 1

Enrichment to NU at the NEFDU feed 5.3 × 10-2 1.8 × 10-1 7.5 × 10-2 3.0 × 10-1 3.3 × 1NU producta 1.3 × 10-2 to 2.0 × 10-2 4.9 × 10-2 to 6.2 × 10-2 1.7 × 10-2 to 2.9 × 10-2 9.6 × 10-2 to 1.7 × 10-1 8.9 × 10-2 to 1.2 × 1DU tails (to Portsmouth 

or Paducah) 2.4 × 10-2 to 3.7 × 10-2 9.2 × 10-2 to 1.2 × 10-1 3.2 × 10-2 to 5.4 × 10-2 1.0 × 10-1 to 1.8 × 10-1 1.7 × 10-1 to 2.2 × 1

Total 8.9 × 10-2 to 1.1 × 10-1 3.2 × 10-1 to 3.5 × 10-1 1.2 × 10-1 to 1.6 × 10-1 5.0 × 10-1 to 6.5 × 10-1 5.9 × 10-1 to 6.7 × 1Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEU Total 0.0090 to 0.15 0.072 to 0.49 0.012 to 0.21 0.042 to 0.96 0.053 to 0a. Range in product results is due to shipping product to various off-site storage locations. 
66 

Table 4-8b. Transportation Impacts from Truck Shipments of 2,000 MTU of Uranium Hexafluoride in a Given Yea

Action 

Case Public (LCFs) Worker (LCFs) 

Vehicle Emission 

Health Effects 

(LCFs) 

Radiological Accident 

Risk (LCFs) Traffic Fatalities 

Enrichment to LEU at the Paducah GDP NU, DU, LEU feed 6.7 × 10-4 3.3 × 10-3 9.0 × 10-4 3.5 × 10-3 3.9 × 1LEU product 

(on-site storage) -- 2.1 × 10-4 -- -- 

LEU product if shipped 

to FFFsa 1.6 × 10-4 to 4.1 × 10-4 4.8 × 10-4 to 9.9 × 10-4 1.5 × 10-4 to 3.0 × 10-4 2.0 × 10-3 to 4.7 × 10-3 5.7 × 10-4 to 2.1 × 1

Total 6.7 × 10-4 to 1.1 × 10-3 3.5 × 10-3 to 4.3 × 10-3 9.0 × 10-4 to 1.2 × 10-3 3.5 × 10-3 to 8.2 × 10-3 3.9 × 10-3 to 6.0 × 1Enrichment of DU to NU at the Paducah GDP DU feed 1.2 × 10-3 6.1 × 10-3 1.6 × 10-3 5.7 × 10-3 7.2 × 1NU product 

(on-site storage) -- 7.3 × 10-4 -- -- 

Total 1.2 × 10-3 6.8 × 10-3 1.6 × 10-3 5.7 × 10-3 7.2 × 1Enrichment to LEU at the ACP (Portsmouth) NU, DU, LEU feed 4.4 × 10-4 2.6 × 10-3 5.9 × 10-4 2.3 × 10-3 2.6 × 1LEU product 

(on-site storage) -- 2.1 × 10-4 -- -- 

LEU product if shipped 

to FFFsa 1.4 × 10-4 to 4.9 × 10-4 5.1 × 10-4 to 1.1 × 10-3 1.7 × 10-4 to 3.3 × 10-4 2.5 × 10-3 to 4.9 × 10-3 4.6 × 10-4 to 2.4 × 1

Total 4.4 × 10-4 to 9.3 × 10-4 2.8 × 10-3 to 3.7 × 10-3 5.9 × 10-4 to 9.2 × 10-4 2.3 × 10-3 to 7.2 × 10-3 2.6 × 10-3 to 5.0 × 1Enrichment of DU to NU at the ACP (Portsmouth)DU feed 8.2 × 10-4 4.8 × 10-3 1.1 × 10-3 3.8 × 10-3 4.8 × 1NU product 

(on-site storage) -- 7.3 × 10-4 -- -- 

Total 8.2 × 10-4 5.6 × 10-3 1.1 × 10-3 3.8 × 10-3 4.8 × 1Enrichment to LEU at the NEF NU, DU, LEU feed 2.6 × 10-3 8.8 × 10-3 3.7 × 10-3 1.7 × 10-2 1.6 × 1LEU producta 2.5 × 10-4 to 4.1 × 10-4 6.5 × 10-4 to 9.5 × 10-4 2.1 × 10-4 to 3.2 × 10-4 3.2 × 10-3 to 5.6 × 10-3 1.1 × 10-3 to 2.0 × 1DU tails (to Portsmouth 

or Paducah) 1.6 × 10-3 to 2.5 × 10-3 6.2 × 10-3 to 7.8 × 10-3 2.1 × 10-3 to 3.7 × 10-3 7.0 × 10-3 to 1.2 × 10-2 1.1 × 10-2 to 1.5 × 1

Total 4.5 × 10-3 to 5.6 × 10-3 1.6 × 10-2 to 1.8 × 10-2 6.1 × 10-3 to 7.7 × 10-3 2.7 × 10-2 to 3.5 × 10-2 2.9 × 10-2 to 3.3 × 1Enrichment of DU to NU at the NEF DU feed 4.8 × 10-3 1.6 × 10-2 6.8 × 10-3 2.7 × 10-2 3.0 × 1NU producta 1.2 × 10-3 to 1.8 × 10-3 4.5 × 10-3 to 5.6 × 10-3 1.5 × 10-3 to 2.6 × 10-3 8.8 × 10-3 to 1.5 × 10-2 8.1 × 10-3 to 1.1 × 1DU tails (to Portsmouth 

or Paducah) 2.2 × 10-3 to 3.4 × 10-3 8.4 × 10-3 to 1.1 × 10-2 2.9 × 10-3 to 4.9 × 10-3 9.4 × 10-3 to 1.7 × 10-2 1.5 × 10-2 to 2.0 × 1

Total 8.1 × 10-3 to 1.0 × 10-2 2.9 × 10-2 to 3.2 × 10-2 1.1 × 10-2 to 1.4 × 10-2 4.6 × 10-2 to 6.0 × 10-2 5.3 × 10-2 to 6.1 × 1Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEU Total 8.2 × 10-4 to 1.4 × 10-2 6.5 × 10-3 to 4.4 × 10-2 1.1 × 10-3 to 1.9 × 10-2 3.8 × 10-3 to 8.7 × 10-2 4.8 × 10-3 to 8.1 × 1a. Range in product results is due to shipping product to various off-site storage locations. 
67 

Table 4-8c. Transportation Impacts from Truck Shipments of 4,000 MTU of Uranium Hexafluoride in a Given Yea

Proposed Action 

Case Public (LCFs) Worker (LCFs) 

Vehicle Emission 

Health Effects 

(LCFs) 

Radiological Accident 

Risk (LCFs) Traffic Fatalities 

Enrichment to LEU at the Paducah GDP NU, DU, LEU feed 1.4 × 10-3 6.9 × 10-3 1.9 × 10-3 7.3 × 10-3 8.2 × 10LEU product 

(on-site storage) -- 4.4 × 10-4 -- -- 

LEU product if shipped 

to FFFsa 3.3 × 10-4 to 8.6 × 10-4 9.9 × 10-4 to 2.1 × 10-3 3.1 × 10-4 to 6.2 × 10-4 4.1 × 10-3 to 9.9 × 10-3 1.2 × 10-3 to 4.3 × 10

Total 1.4 × 10-3 to 2.3 × 10-3 7.4 × 10-3 to 9.0 × 10-3 1.9 × 10-3 to 2.5 × 10-3 7.3 × 10-3 to 1.7 × 10-2 8.2 × 10-3 to 1.3 × 10Enrichment of DU to NU at the Paducah GDP DU feed 2.2 × 10-3 1.1 × 10-2 3.0 × 10-3 1.0 × 10-2 1.3 × 10NU product 

(on-site storage) -- 1.3 × 10-3 -- -- 

Total 2.2 × 10-3 1.2 × 10-2 3.0 × 10-3 1.0 × 10-2 1.3 × 10Enrichment to LEU at the ACP (Portsmouth) NU, DU, LEU feed 9.1 × 10-4 5.4 × 10-3 1.2 × 10-3 4.8 × 10-3 5.4 × 10LEU product 

(on-site storage) -- 4.4 × 10-4 -- -- 

LEU product if shipped 

to FFFsa 2.8 × 10-4 to 1.0 × 10-3 1.1 × 10-3 to 2.3 × 10-3 3.5 × 10-4 to 6.9 × 10-4 5.2 × 10-3 to 1.0 × 10-2 9.6 × 10-4 to 4.9 × 10

Total 9.1 × 10-4 to 1.9 × 10-3 5.9 × 10-3 to 7.7 × 10-3 1.2 × 10-3 to 1.9 × 10-3 4.8 × 10-3 to 1.5 × 10-2 5.4 × 10-3 to 1.0 × 10Enrichment of DU to NU at the ACP (Portsmouth) DU feed 1.5 × 10-3 8.9 × 10-3 2.0 × 10-3 7.0 × 10-3 8.8 × 10NU product 

(on-site storage) -- 1.3 × 10-3 -- -- 

Total 1.5 × 10-3 1.0 × 10-2 2.0 × 10-3 7.0 × 10-3 8.8 × 10Enrichment to LEU at the NEF NU, DU, LEU feed 5.5 × 10-3 1.8 × 10-2 7.8 × 10-3 3.5 × 10-2 3.4 × 10LEU producta 5.1 × 10-4 to 8.6 × 10-4 1.4 × 10-3 to 2.0 × 10-3 4.3 × 10-4 to 6.7 × 10-4 6.7 × 10-3 to 1.2 × 10-2 2.3 × 10-3 to 4.3 × 10DU tails (to Portsmouth 

or Paducah) 3.3 × 10-3 to 5.2 × 10-3 1.3 × 10-2 to 1.6 × 10-2 4.5 × 10-3 to 7.6 × 10-3 1.5 × 10-2 to 2.6 × 10-2 2.3 × 10-2 to 3.1 × 10

Total 9.3 × 10-3 to 1.2 × 10-2 3.3 × 10-2 to 3.7 × 10-2 1.3 × 10-2 to 1.6 × 10-2 5.6 × 10-2 to 7.2 × 10-2 6.0 × 10-2 to 7.0 × 10Enrichment of DU to NU at the NEF DU feed 8.8 × 10-3 3.0 × 10-2 1.3 × 10-2 5.0 × 10-2 5.5 × 10NU producta 2.1 × 10-3 to 3.3 × 10-3 8.2 × 10-3 to 1.0 × 10-2 2.8 × 10-3 to 4.8 × 10-3 1.6 × 10-2 to 2.8 × 10-2 1.5 × 10-2 to 2.0 × 10DU tails (to Portsmouth 

or Paducah) 4.0 × 10-3 to 6.2 × 10-3 1.5 × 10-2 to 1.9 × 10-2 5.3 × 10-3 to 9.0 × 10-3 1.7 × 10-2 to 3.0 × 10-2 2.8 × 10-2 to 3.7 × 10

Total 1.5 × 10-2 to 1.8 × 10-2 5.3 × 10-2 to 5.9 × 10-2 2.1 × 10-2 to 2.6 × 10-2 8.4 × 10-2 to 1.1 × 10-1 9.8 × 10-2 to 1.1 × 10Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEU Total 1.5 × 10-3 to 2.5 × 10-2 1.2 × 10-2 to 8.1 × 10-2 2.0 × 10-3 to 3.5 × 10-2 7.0 × 10-3 to 1.6 × 10-1 8.8 × 10-3 to 1.5 × 10a. 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 product would not be shipped, resulting in lower 

transportation impacts. 

For enrichment at the NEF, transportation impacts would be 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 enrichment facility or potentially shipped back to 

DOE Paducah or DOE Portsmouth. In addition, NU product could be shipped back to Paducah or 

Portsmouth, resulting in higher 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 

UF6 (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 kilometers (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 Shipmentsa

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 UF6. 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 using general freight; dedicated trains have not 

historically been used for UF6 shipments. For rail shipments of UF6, radiation doses were 

estimated for workers and members of the public. Workers included workers involved with the 

classification of railcars at stops and workers involved in loading and unloading the UF6

cylinders. For members of the public, 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 the radiological accident risks were also estimated. 

The radiological and toxicological impacts of severe transportation accidents are discussed in 

Section 4.2.1.5. 

Transportation impacts were estimated for enrichment of NU, DU, and LEU feed to LEU 

product, for enrichment of DU feed to NU product, and for enrichment of DU feed to NU 
Final 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 transportation of LEU product to FFFs. Impacts are presented for 

enriching the entire surplus DOE inventory, and for enriching 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 UF6 are listed in Tables 4-10a, 4-10b, and 4-10c. Impacts are 

quantified in terms of total fatalities, which are the sum of radiation-related LCFs, vehicle 

emission health effects, and traffic 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 occurred 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 railroad accidents and incidents in the United States 

(DOT 2007). 

For enrichment of DU feed to NU product, the estimated 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 year ranged from 0.015 to 0.17, and the estimated 

number of fatalities from enriching the equivalent of 4,000 MTU of NU in a given year ranged 

from 0.027 to 0.30. 

For enrichment of DU feed to NU product followed by subsequent enrichment 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 enrichment 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 impacts 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 enrichment facility or shipped back to DOE 

Paducah or DOE Portsmouth. In addition, NU product could be shipped back to Paducah or 

Portsmouth, resulting in higher transportation impacts. 
70 

Table 4-10a. Total Transportation Impacts from Rail Shipments of Uranium Hexafluoride under the Proposed Act

Case Public (LCFs) Worker (LCFs) 

Vehicle Emission 

Health Effects 

(LCFs) 

Radiological Accident 

Risk (LCFs) Traffic Fatalities 

Enrichment to LEU at the Paducah GDP NU, DU, LEU feed 2.1 × 10-3 3.5 × 10-2 1.3 × 10-2 1.1 × 10-1 1.3 × 1LEU product 

(on-site storage) -- 5.3 × 10-3 -- -- 

LEU product if shipped 

to FFFsa 1.2 × 10-3 to 1.1 × 10-3 6.1 × 10-3 to 7.1 × 10-3 3.0 × 10-3 to 3.1 × 10-3 7.7 × 10-2 to 8.2 × 10-2 2.5 × 10-2 to 7.8 × 1

Total 2.1 × 10-3 to 3.2 × 10-3 4.0 × 10-2 to 4.2 × 10-2 1.3 × 10-2 to 1.6 × 10-2 1.1 × 10-1 to 1.9 × 10-1 1.3 × 10-1 to 2.0 × 1Enrichment of DU to NU at the Paducah GDP DU feed 1.6 × 10-3 2.8 × 10-2 1.0 × 10-2 7.6 × 10-2 1.0 × 1NU product 

(on-site storage) -- 8.0 × 10-3 -- -- 

Total 1.6 × 10-3 3.6 × 10-2 1.0 × 10-2 7.6 × 10-2 1.0 × 1Enrichment to LEU at the ACP (Portsmouth) NU, DU, LEU feed 1.3 × 10-3 3.4 × 10-2 8.2 × 10-3 7.0 × 10-2 8.3 × 1LEU product 

(on-site storage) -- 5.3 × 10-3 -- -- 

LEU product if shipped 

to FFFsa 6.5 × 10-4 to 1.5 × 10-3 6.0 × 10-3 to 7.2 × 10-3 1.3 × 10-3 to 4.9 × 10-3 2.9 × 10-2 to 1.5 × 10-1 2.0 × 10-2 to 8.1 × 1

Total 1.3 × 10-3 to 2.8 × 10-3 3.9 × 10-2 to 4.1 × 10-2 8.2 × 10-3 to 1.3 × 10-2 7.0 × 10-2 to 2.2 × 10-1 8.3 × 10-2 to 1.6 × 1Enrichment of DU to NU at the ACP (Portsmouth) DU feed 1.1 × 10-3 2.7 × 10-2 6.7 × 10-3 5.1 × 10-2 6.8 × 1NU product 

(on-site storage) -- 8.0 × 10-3 -- -- 

Total 1.1 × 10-3 3.5 × 10-2 6.7 × 10-3 5.1 × 10-2 6.8 × 1Enrichment to LEU at the NEF NU, DU, LEU feed 1.0 × 10-2 4.3 × 10-2 5.2 × 10-2 4.0 × 10-1 6.2 × 1LEU producta 1.1 × 10-3 to 1.7 × 10-3 6.4 × 10-3 to 7.1 × 10-3 2.9 × 10-3 to 6.7 × 10-3 7.7 × 10-2 to 2.2 × 10-1 4.0 × 10-2 to 7.8 × 1DU tails (to Portsmouth 

or Paducah) 6.3 × 10-3 to 9.6 × 10-3 3.4 × 10-2 to 3.6 × 10-2 3.0 × 10-2 to 5.1 × 10-2 1.7 × 10-1 to 3.0 × 10-1 4.1 × 10-1 to 5.7 × 1

Total 1.8 × 10-2 to 2.1 × 10-2 8.4 × 10-2 to 8.7 × 10-2 8.5 × 10-2 to 1.1 × 10-1 6.4 × 10-1 to 9.2 × 10-1 1.1 to Enrichment of DU to NU at the NEF DU feed 8.2 × 10-3 3.5 × 10-2 4.2 × 10-2 2.9 × 10-1 5.0 × 1NU producta 2.0 × 10-3 to 3.0 × 10-3 1.1 × 10-2 to 1.1 × 10-2 9.5 × 10-3 to 1.6 × 10-2 9.1 × 10-2 to 1.6 × 10-1 1.3 × 10-1 to 1.8 × 1DU tails (to Portsmouth 

or Paducah) 3.7 × 10-3 to 5.7 × 10-3 2.0 × 10-2 to 2.1 × 10-2 1.8 × 10-2 to 3.0 × 10-2 9.8 × 10-2 to 1.8 × 10-1 2.4 × 10-1 to 3.4 × 1

Total 1.4 × 10-2 to 1.7 × 10-2 6.6 × 10-2 to 6.8 × 10-2 6.9 × 10-2 to 8.8 × 10-2 4.8 × 10-1 to 6.3 × 10-1 8.7 × 10-1 to Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEU Total 0.0011 to 0.023 0.046 to 0.11 0.0067 to 0.12 0.051 to 0.97 0.068 to a. Range in product results is due to shipping product to various off-site storage locations. 
71 

Table 4-10b. Transportation Impacts from Rail Shipments of 2,000 MTU of Uranium Hexafluoride in a Given Year 

Action 

Case Public (LCFs) Worker (LCFs) 

Vehicle Emission 

Health Effects 

(LCFs) 

Radiological Accident 

Risk (LCFs) Traffic Fatalities 

Enrichment to LEU at the Paducah GDP NU, DU, LEU feed 8.2 × 10-5 1.4 × 10-3 5.0 × 10-4 4.2 × 10-3 5.1 × LEU product 

(on-site storage) -- 2.1 × 10-4 -- -- 

LEU product if shipped 

to FFFsa 4.8 × 10-5 to 4.6 × 10-5 2.5 × 10-4 to 2.8 × 10-4 1.2 × 10-4 to 1.2 × 10-4 3.1 × 10-3 to 3.3 × 10-3 1.0 × 10-3 to 3.1 × 

Total 8.2 × 10-5 to 1.3 × 10-4 1.6 × 10-3 to 1.7 × 10-3 5.0 × 10-4 to 6.2 × 10-4 4.2 × 10-3 to 7.5 × 10-3 5.1 × 10-3 to 8.2 × Enrichment of DU to NU at the Paducah GDP DU feed 1.5 × 10-4 2.6 × 10-3 9.1 × 10-4 6.9 × 10-3 9.2 × NU product 

(on-site storage) -- 7.3 × 10-4 -- -- 

Total 1.5 × 10-4 3.3 × 10-3 9.1 × 10-4 6.9 × 10-3 9.2 × Enrichment to LEU at the ACP (Portsmouth) NU, DU, LEU feed 5.4 × 10-5 1.3 × 10-3 3.3 × 10-4 2.8 × 10-3 3.3 × LEU product 

(on-site storage) -- 2.1 × 10-4 -- -- 

LEU product if shipped 

to FFFsa 2.6 × 10-5 to 6.0 × 10-5 2.4 × 10-4 to 2.9 × 10-4 5.4 × 10-5 to 2.0 × 10-4 1.2 × 10-3 to 5.9 × 10-3 8.0 × 10-4 to 3.2 × 

Total 5.4 × 10-5 to 1.1 × 10-4 1.6 × 10-3 to 1.6 × 10-3 3.3 × 10-4 to 5.3 × 10-4 2.8 × 10-3 to 8.7 × 10-3 3.3 × 10-3 to 6.6 × Enrichment of DU to NU at the ACP (Portsmouth) DU feed 1.0 × 10-4 2.5 × 10-3 6.1 × 10-4 4.6 × 10-3 6.2 × NU product 

(on-site storage) -- 7.3 × 10-4 -- -- 

Total 1.0 × 10-4 3.2 × 10-3 6.1 × 10-4 4.6 × 10-3 6.2 × Enrichment to LEU at the NEF NU, DU, LEU feed 4.1 × 10-4 1.7 × 10-3 2.1 × 10-3 1.6 × 10-2 2.5 × LEU producta 4.6 × 10-5 to 6.8 × 10-5 2.6 × 10-4 to 2.8 × 10-4 1.2 × 10-4 to 2.7 × 10-4 3.1 × 10-3 to 8.6 × 10-3 1.6 × 10-3 to 3.1 × DU tails (to Portsmouth 

or Paducah) 2.5 × 10-4 to 3.8 × 10-4 1.4 × 10-3 to 1.5 × 10-3 1.2 × 10-3 to 2.0 × 10-3 6.6 × 10-3 to 1.2 × 10-2 1.6 × 10-2 to 2.3 × 

Total 7.0 × 10-4 to 8.6 × 10-4 3.4 × 10-3 to 3.5 × 10-3 3.4 × 10-3 to 4.4 × 10-3 2.6 × 10-2 to 3.7 × 10-2 4.3 × 10-2 to 5.1 × Enrichment of DU to NU at the NEF DU feed 7.4 × 10-4 3.2 × 10-3 3.8 × 10-3 2.6 × 10-2 4.6 × NU producta 1.8 × 10-4 to 2.8 × 10-4 9.8 × 10-4 to 1.0 × 10-3 8.6 × 10-4 to 1.5 × 10-3 8.3 × 10-3 to 1.5 × 10-2 1.2 × 10-2 to 1.6 × DU tails (to Portsmouth 

or Paducah) 3.4 × 10-4 to 5.2 × 10-4 1.8 × 10-3 to 1.9 × 10-3 1.6 × 10-3 to 2.7 × 10-3 8.9 × 10-3 to 1.6 × 10-2 2.2 × 10-2 to 3.1 × 

Total 1.3 × 10-3 to 1.5 × 10-3 6.0 × 10-3 to 6.2 × 10-3 6.3 × 10-3 to 8.0 × 10-3 4.4 × 10-2 to 5.7 × 10-2 7.9 × 10-2 to 9.3 × Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEU Total 1.0 × 10-4 to 2.1 × 10-3 4.2 × 10-3 to 9.7 × 10-3 6.1 × 10-4 to 1.1 × 10-2 4.6 × 10-3 to 8.8 × 10-2 6.2 × 10-3 to 1.2 × a. Range in product results is due to shipping product to various off-site storage locations. 
72 

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

Action 

Case Public (LCFs) Worker (LCFs) 

Vehicle Emission 

Health Effects 

(LCFs) 

Radiological Accident 

Risk (LCFs) Traffic Fatalities 

Enrichment to LEU at the Paducah GDP NU, DU, LEU feed 1.7 × 10-4 2.9 × 10-3 1.0 × 10-3 8.8 × 10-3 1.1 × LEU product 

(on-site storage) 0.0 4.4 × 10-4 0.0 0.0 

LEU product if shipped 

to FFFsa 1.0 × 10-4 to 9.5 × 10-5 5.1 × 10-4 to 5.9 × 10-4 2.5 × 10-4 to 2.5 × 10-4 6.5 × 10-3 to 6.8 × 10-3 2.1 × 10-3 to 6.5 × 

Total 1.7 × 10-4 to 2.7 × 10-4 3.4 × 10-3 to 3.5 × 10-3 1.0 × 10-3 to 1.3 × 10-3 8.8 × 10-3 to 1.6 × 10-2 1.1 × 10-2 to 1.7 × Enrichment of DU to NU at the Paducah GDP DU feed 2.7 × 10-4 4.7 × 10-3 1.7 × 10-3 1.3 × 10-2 1.7 × NU product 

(on-site storage) -- 1.3 × 10-3 -- -- 

Total 2.7 × 10-4 6.0 × 10-3 1.7 × 10-3 1.3 × 10-2 1.7 × Enrichment to LEU at the ACP (Portsmouth) NU, DU, LEU feed 1.1 × 10-4 2.8 × 10-3 6.9 × 10-4 5.8 × 10-3 6.9 × LEU product 

(on-site storage) 0.0 4.4 × 10-4 0.0 0.0 

LEU product if shipped 

to FFFsa 5.5 × 10-5 to 1.2 × 10-4 5.0 × 10-4 to 6.0 × 10-4 1.1 × 10-4 to 4.1 × 10-4 2.4 × 10-3 to 1.2 × 10-2 1.7 × 10-3 to 6.8 × 

Total 1.1 × 10-4 to 2.4 × 10-4 3.2 × 10-3 to 3.4 × 10-3 6.9 × 10-4 to 1.1 × 10-3 5.8 × 10-3 to 1.8 × 10-2 6.9 × 10-3 to 1.4 × Enrichment of DU to NU at the ACP (Portsmouth) DU feed 1.8 × 10-4 4.5 × 10-3 1.1 × 10-3 8.5 × 10-3 1.1 × NU product 

(on-site storage) -- 1.3 × 10-3 -- -- 

Total 1.8 × 10-4 5.9 × 10-3 1.1 × 10-3 8.5 × 10-3 1.1 × Enrichment to LEU at the NEF NU, DU, LEU feed 8.4 × 10-4 3.6 × 10-3 4.3 × 10-3 3.4 × 10-2 5.2 × LEU producta 9.5 × 10-5 to 1.4 × 10-4 5.3 × 10-4 to 5.9 × 10-4 2.4 × 10-4 to 5.6 × 10-4 6.4 × 10-3 to 1.8 × 10-2 3.3 × 10-3 to 6.5 × DU tails (to Portsmouth 

or Paducah) 

5.2 × 10-4 to 8.0 × 10-4 2.8 × 10-3 to 3.0 × 10-3 2.5 × 10-3 to 4.2 × 10-3 1.4 × 10-2 to 2.5 × 10-2 3.4 × 10-2 to 4.8 × 

Total 1.5 × 10-3 to 1.8 × 10-3 7.0 × 10-3 to 7.2 × 10-3 7.1 × 10-3 to 9.1 × 10-3 5.4 × 10-2 to 7.6 × 10-2 8.9 × 10-2 to 1.1 × Enrichment of DU to NU at the NEF DU feed 1.4 × 10-3 5.8 × 10-3 7.0 × 10-3 4.8 × 10-2 8.3 × NU producta 3.3 × 10-4 to 5.1 × 10-4 1.8 × 10-3 to 1.9 × 10-3 1.6 × 10-3 to 2.7 × 10-3 1.5 × 10-2 to 2.7 × 10-2 2.2 × 10-2 to 3.0 × DU tails (to Portsmouth 

or Paducah) 6.2 × 10-4 to 9.5 × 10-4 3.4 × 10-3 to 3.6 × 10-3 3.0 × 10-3 to 5.0 × 10-3 1.6 × 10-2 to 2.9 × 10-2 4.0 × 10-2 to 5.6 × 

Total 2.3 × 10-3 to 2.8 × 10-3 1.1 × 10-2 to 1.1 × 10-2 1.2 × 10-2 to 1.5 × 10-2 8.0 × 10-2 to 1.1 × 10-1 1.5 × 10-1 to 1.7 × Enrichment of DU to NU Followed By Subsequent Enrichment of NU to LEU Total 1.8 × 10-4 to 3.8 × 10-3 7.7 × 10-3 to 1.8 × 10-2 1.1 × 10-3 to 2.0 × 10-2 8.5 × 10-3 to 1.6 × 10-1 1.1 × 10-2 to 2.3 × a. Range in product results is due to shipping product to various off-site storage locations. 
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 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 

UF6 (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 kilometers (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 Shipmentsa

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 UF6. 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 UF6 from the 

Portsmouth and Paducah GDPs to the Russian Federation. In addition, DOE (1994) evaluated the 

impacts of shipping 15,250 MTU of LEU as UF6 from the Russian Federation to the Portsmouth 

and Paducah GDPs. The total amount of UF6 evaluated in the Proposed Action, would be 

99,810 MTU23, assuming that the DU tails would not be shipped back to the United States, 

which is the standard industry practice. 

Based on these analyses and using the Port of Houston, 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 and 0.054 transportation-related fatalities from 

shipping 15,250 MTU of LEU from the Russian Federation to the United States. These impacts 

included sea transit, port operations, and overland truck transport24 and were estimated to result 

in 2.9 total fatalities. In addition, based on the radiological and nonradiological impacts 

presented in DOE (1999a) and DOE (1994), the impacts 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 UF6 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: 

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 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 shipping 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 feed, 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 UF6 to DOE’s Portsmouth or Paducah facilities. If the UF6 were subsequently 

shipped to an FFF, it is estimated that the number of fatalities would increase slightly, from 

about 2.0 fatalities to about 2.2 fatalities. If the UF6 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 shipping distance would be less. 

If barges were used to transport the uranium to the Port of New Orleans for shipment to the 

Tricastin nuclear complex for enrichment, and from the Port of New Orleans to Portsmouth or 

Paducah after enrichment at the Tricastin nuclear 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 exposed population using truck routes (Table 4-12). 

Therefore, the impacts of transporting the uranium 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 UF6 to the Tricastin nuclear complex require 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 UF6 from the Russian Federation to the Portsmouth and Paducah GDPs. DOE (1999a) 

also analyzed the impacts on global commons of shipping 135,000 MTU of NU as UF6 from the 

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

National Marine Fisheries Service indicated that, under normal transport conditions, shipment of 

LEU by commercial vessel would be indistinguishable from any other commercial shipment and 

that there would be no impact on the marine environment, since marine flora and fauna would 

not be exposed to UF6. 

The North Atlantic right whale (Eubalaena glacialis) is on the federal endangered species list 

and is also protected internationally under the Convention for the Regulation of Whaling. There 
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 75 

are currently about 300 right whales in the North Atlantic, with ship strikes accounting for about 

50 percent of their known deaths. Calving right whales usually winter in the waters between 

Savannah, Georgia, and West Palm Beach, Florida, with an area of high density between 

Brunswick, Georgia, and St. Augustine, Florida (DOE 2008a). The Maritime Safety Committee 

of the International Maritime 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 whales 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 certain locations and at certain times of the 

year along the east coast of the U.S. Atlantic seaboard. 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 species of sea turtles are on the federal endangered species list and 

are found throughout the central and northern Pacific 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, however, females and their young stay in latitudes 

less than 40, and only the males venture into the polar waters. The total number of sperm whales 

in the world is not well known, with estimates ranging from 200,000 to 2 million. The sea turtle 

is found throughout the Atlantic Ocean and the Pacific Ocean but is usually vulnerable to harm 

only on coastal shores. In the United States, the sea turtle is most prevalent on and just off the 

central Florida coast. Endangered marine species 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-Louis sank after colliding with a ferry. The 

cargo included thirty (30) Type 48Y cylinders of UF6. In view of the nature of the cargo, 

particularly its value, it was decided to salvage the UF6 cylinders as quickly as possible and to 

recover the material. All 30 containers were recovered. They were all intact except one, which 

had a slight leak in the valve. 

Moreover, there is no significant risk to the marine environment even in the event that one or 

more cylinders were lost at sea and not retrieved. The oceans contain significant 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 UF6 are designed, constructed, and tested to withstand a severe collision, so 

unretrieved cylinders lost as the result of an accident at sea are likely 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 would result in only slight increases in the exposure of marine 
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 76 

organisms, which tend to be more radiation-resistant than terrestrial mammals and which are 

already exposed to similar concentrations of uranium. 

As a result of the large volume of water, the mixing mechanisms within it, the background 

concentrations of uranium, and the radiation resistance of aquatic organisms, the radiological 

impact of the very low probability accident releasing 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 UF6. This would practically 

eliminate the possibility of multiple containers slowly corroding and releasing their contents over 

time. Even if a cylinder were not retrievable, the impact of a slow release would be even less 

severe than a catastrophic failure of a cylinder. 

The second aspect of a marine accident is the chemical hazard. UF6 reacts with water in an 

exothermic reaction that releases uranyl fluoride (UO2F2) 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 UO2F2 are the toxicological agents 

responsible for physiologic effects from a potential release of UF6 in ocean water. If an 

instantaneous, complete hydrolysis of the contents of a single cylinder is assumed, the peak 

concentrations of H+ and F- ions from a total release of UF6 from a container would be 

approximately 2 micrograms per liter at a distance of 100 meters. These concentrations are 

below toxic levels. The UO2F2 formed would settle on the sea bed and slowly dissolve. 

4.2.1.5 Consequences of Severe Transportation Accidents 

DOE estimated that the radiological risks of transportation accidents for truck shipments 

(probability of occurrence × consequence summed over a complete spectrum of accidents, 

including the severe accidents) ranged from 0.042 to 0.96 LCFs over 25 years (see Table 4-8a). 

For rail shipments, DOE estimated that the radiological risks of transportation accidents 

(probability of occurrence × consequence summed 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 radiological consequences of a severe transportation accident 

involving DUF6. These accidents are characterized by extreme mechanical and thermal forces, 

and accidents of this severity would be expected to be extremely rare (Biwer et al. 2001). 

Because DOE postulated a hypothetical accident that could occur at any location, the results are 

not route-dependent. DOE evaluated 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 areas (1,600 persons per square 

kilometer [4,000 persons per square mile]). Radiation 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: 

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 77 

Tables 4-13 and 4-14 list the radiological 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 DUF6, the population radiation dose could be as high as 32,000 personrem 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 if stable atmospheric conditions 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 the Population from Severe Transportation 

Accidents Involving Depleted Uranium Hexafluoridea

Neutral Atmospheric Conditions Stable Atmospheric Conditions 

Mode Ruralb

 Suburban Urbanc Ruralb Suburban Urbanc 

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 kilometer for suburban zones, and 1,600 persons 

per square kilometer for urban zones. Potential 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 consequences in suburban areas because 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 radiation dose from the ingestion of contaminated food stuffs. 

c. It is important to note that the urban population density generally applies to relatively small urbanized area—very few, if 

any, urban areas have a population density as high as 1,600 persons per square kilometer extending 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. 

d. LCFs are calculated by multiplying the 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 Maximally Exposed Individual from Severe 

Transportation Accidents Involving Depleted Uranium Hexafluoride 

Neutral Atmospheric Conditions Stable Atmospheric Conditions Mode 

Dose (rem) Probability of LCFa

 Dose (rem) Probability of LCFa

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). 
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 78 

If the severe transportation 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 0.0008. 

If the severe transportation accident involved LEU product, the radiological consequences would 

also be higher—about 75 to 125 LCFs in the assumed exposed population, assuming that all 

three to five 30B cylinders, respectively, in a truck shipment were 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 breached 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 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 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 involving four cylinders of DUF6, 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 population radiation dose, it was estimated that there 

could be 80 LCFs in the assumed exposed population 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 transportation 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. 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 

also be higher—about 310 LCFs in the assumed exposed population, assuming 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 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 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 4.3 × 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 for the population within a 50-mile (80-km) radius, assuming that 
Final Environmental Assessment: 

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 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 within 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 truck or rail 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 consequences would be substantially lower. For example, if the severe truck 

accident involving LEU product 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 would be about 12 LCFs, substantially lower than 310 LCFs. 

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

DUF6. If UF6 is released to the atmosphere, it reacts with water vapor in the air to form HF and 

UO2F2, independent of the enrichment of the UF6 (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 enough concentrations. In addition, uranium is a heavy metal that, 

in addition to being radioactive, can have toxic chemical effects (primarily on the kidneys) if it 

enters the body by way of ingestion and/or inhalation. 

Because DOE postulated a hypothetical accident that could occur at any location, the results are 

not route-dependent. DOE evaluated chemical impacts to 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 areas (1,600 persons per square kilometer 

[4,000 persons per square mile]). Chemical impacts are not dependent on enrichment of the 

uranium, only on the amount of uranium in the container. For this reason, if the severe 

transportation accident involved NU or enriched uranium, the chemical consequences would be 

similar. 

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

irreversible adverse health effects. An adverse health effect includes respiratory irritation or skin 

rash associated with lower chemical concentrations. An irreversible adverse health effect 

generally 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 may impair daily functions. Of those individuals receiving 

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

Tables 4-15 and 4-16 list the chemical consequences of these severe transportation 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 conditions (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 that 
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Table 4-15. Chemical Consequences for the Population from Severe Transportation Accidents 

Involving Depleted Uranium Hexafluoride a

Neutral Atmospheric Conditions Stable Atmospheric Conditions Mode 

Rural Suburban Urbanb Rural Suburban Urbanb 

Number of People with the Potential 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 Effectsc

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. Potential impacts were estimated for the population within a 50-mile (80-kilometer) 

radius, assuming a uniform population density for each zone. 

b. It is important to note that the urban population density generally applies to relatively small urbanized area— very few, if

any, urban areas have a population density as high as 1,600 persons per square kilometer extending 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 approximately 1 percent or less of those persons 

experiencing irreversible adverse effects. 

Table 4-16. Chemical Consequences for the Maximally Exposed Individual from Severe 

Transportation Accidents Involving Depleted Uranium Hexafluoride 

Neutral Atmospheric Conditions Stable Atmospheric Conditions 

Mode 

Adverse Effects Irreversible 

Adverse Effectsa Adverse Effects Irreversible 

Adverse Effectsa

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 approximately 1 percent or less of those persons 

experiencing irreversible adverse effects. 

approximately four persons might experience irreversible adverse effects (such as lung or kidney 

damage) from exposure to HF and uranium. The number 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 intentional destructive 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 density device such as an armorpiercing weapon (i.e., an anti-tank weapon), and (3) hijacking (stealing) a shipping cylinder. 

DOE (1999a) concluded that the consequences of an intentional destructive act would be less 

than or similar to the consequences of severe transportation accidents for a given number of 

cylinders with similar contents. 
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According to U.S. Department of Transportation regulations (49 CFR Part 172), shipments of 

uranium hexafluoride would require a security plan. 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 information 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 the possibility that unauthorized persons may 

gain access to the hazardous materials covered by the security plan or to transport 

conveyances being prepared for 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 route from origin to destination, including 

shipments stored incidental to movement. 

Although it is not possible to predict the probability of an intentional destructive act, 

implementation of these requirements is judged to make these occurrences very unlikely. 

Although judged very unlikely to actually occur, the consequences of intentional destructive acts 

would be similar to the consequences discussed above for severe truck and rail accidents 

involving DU, NU, and LEU. 

4.2.2 Low-Enriched Uranium Storage Impacts under the Enrichment Alternative 

In the two EISs analyzing construction and operation of proposed UF6 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 Paducah, a total 

of 44,077 cylinders (41,013 DUF6 cylinders, 2,769 non-DUF6 cylinders, and 295 empty 

cylinders) were evaluated. At Portsmouth, a total of 25,231 cylinders (20,931 DUF6 cylinders, 

3,795 non-DUF6 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 would 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 number 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 construction and operation of proposed UF6 conversion facilities at DOE 

Paducah (DOE 2004a) and DOE Portsmouth (DOE 2004b).25

 

25 The Portsmouth and Paducah conversion facility EISs evaluated a total of 2,507 cylinders of LEU and a total of 

2,955 cylinders of NU located at Portsmouth, Paducah, and 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. Updated cylinder counts will differ from those presented in earlier documents due 

to these transactions. 
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If DU feed were enriched to NU product, the number of DU cylinders would decrease from 

10,776 to 6,450. The number of NU cylinders would increase from 2,270 to 5,715, and the 

number of LEU cylinders would be unchanged. The total number of cylinders would decrease 

from 13,342 to 12,461. If DU feed were enriched 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 cylinders 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 the two EISs analyzing construction and operation of proposed UF6

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

In the conversion facility EIS for the Portsmouth site, the average worker 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 maintenance activities for 40 years (the duration of 

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

The collective radiation dose for workers conducting 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 collective radiation dose is estimated to result in 

0.28 LCFs. 

In the conversion facility EIS for the Portsmouth 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 dose is estimated to result in 4.2 × 10-5 LCFs. 

Accidents involving cylinders were also evaluated in the conversion facility EIS for the 

Portsmouth site. The accident with the highest consequences was a fire resulting in the rupture of 

three 48G cylinders containing DUF6. The radiation dose for an individual member of the public 

from this accident was estimated to be 0.013 rem, 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 equivalent to 0.020 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 UF6; 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. 

If the accident involved NU, the radiological consequences would be higher—about 0.030 LCFs 

in the exposed population, assuming that three cylinders were involved 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 would 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. 
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In the conversion facility EIS for the Paducah site, 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 maintenance 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, this collective radiation dose is estimated to result in 0.78 LCFs. 

In the conversion facility EIS for the Paducah site, the maximum individual 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 through 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 highest consequences was a fire resulting in the rupture of three 

48G cylinders containing DUF6. 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 dose from this accident was estimated to be 

29 person-rem, which is equivalent to 0.017 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 UF6; 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. 

If the accident involved NU, the radiological consequences would be higher—about 0.025 LCFs 

in the exposed population, assuming that three cylinders were involved 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 would 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 UF6 cylinders at the NEF 

(NRC 2005). The radiation dose from storage of UF6 cylinders for a person located at one of 

three nearby businesses was 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. 
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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 UF6 cylinder containing 

LEU product in the blending and liquid sampling area was evaluated. The radiation dose to an 

individual located at the controlled 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 UF6; 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. 

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 UF6 cylinders at the ACP 

(NRC 2006). At the ACP, the presence of existing storage yards was found to have a minimal 

effect, if any, on the exposure rate at the site boundary. Along the northern boundary near an 

existing cylinder storage yard, where a member of the public might actually stand, the maximum 

amount of radiation exposure above the ambient 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), that person would receive on the order 

of 0.87 mrem per year additional exposure when the 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 not 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 facility EIS for the ACP site (NRC 

2006), which states that the most significant accident consequences are those associated with the 

release of UF6 caused by a breach of an overpressurized cylinder. Consequences are not 

presented for accidents; however, NRC (2006) states 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 occupational radiation doses reported to the NRC by the FFFs in 2006 

(NRC 2007b). These radiation doses include all activities at the FFFs, including cylinder storage 

activities. Because DOE’s LEU would not differ from other LEU that would be stored at the 

FFFs, it is not expected that storage of DOE LEU would appreciably alter these occupational 

radiation doses. Direct radiation data for members of the public are not reported for AREVA NC 

(NRC 1995), CFFF (NRC 2007a), and GNF-A (NRC 1997). 
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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 0.00022 262.457 0.16 

Source: NRC (2007b). 

Accidents at AREVA NC, CFFF, and GNF-A were evaluated by the NRC. For the CFFF (NRC 

2007a), one accident was identified, but the details of the accident were not provided and 

accident consequences were not reported. For AREVA NC (NRC 1995), four accidents were 

evaluated, but none of the accidents were related to cylinder storage. For GNF-A (NRC 1997), 

seven accidents were evaluated. One accident was relevant to cylinder storage, a fire involving a 

single 30B UF6 cylinder containing LEU product on a storage 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 other sites, the results 

would vary depending on the amount of material involved in the accident; the enrichment of the 

UF6; 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 intentional 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 transportation 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 that would be introduced into the domestic 

uranium market would be the same (see Section 2.1.2) under the Enrichment Alternative as 

under the Direct Sale Alternative, or a combination 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 and store the LEU product in essentially the same 

manner and using essentially the same facilities 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 existing practices at the enrichment facilities, and DU 

tail (waste) disposal practices are analyzed in existing enrichment facility and DUF6 conversion 

facility NEPA documents and NRC licenses. For that reason, DOE assumes that the 
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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 applicable 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 transfers 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 mining, 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) analyzed the potential effects 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 would introduce into the domestic market an amount of uranium 

that would not generally exceed 10 percent of the 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. requirements for uranium concentrates (U3O8) and 

conversion services would represent 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 percent per pound of U3O8, 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 reflect 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 change 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 potential 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 committed 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 reasonable expectation that the domestic services for uranium 

concentrates, conversion, and enrichment will increase. ERI (2008) notes that the domestic 
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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 that 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 option and should be able to sell their annual 

production in a competitive market. Domestic conversion services are in similar position in a 

competitive market. DOE sales of enrichment services 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 domestic 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 uncertainty regarding DOE’s potential future sales or enrichment 

transactions. This perception of risk may pose the greatest impact 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 uranium 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 construction 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 facilities currently under development have been 

analyzed in prior NEPA documents. To the extent 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 Statement, 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 proceed with a particular 

sale or transfer for NU or LEU following a determination by the Secretary that there would be no 

material adverse impact to the domestic mining, conversion, 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 analysis prior to any sales or transfers of DU to 

ensure there would be no potentially significant impacts to the domestic uranium industries. 

In years where sales or transfers would be limited 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 determination(s) or other appropriate analyses by the 

Department that the particular sales or transfers would not result in potentially significant 

impacts to the domestic uranium industry. While there may be some temporary adjustments in 

uranium prices related to the DOE uranium transactions, 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. 
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In years where sales or transfers would exceed 2,000 MTU, any such transactions also would be 

preceded by applicable Secretarial determination(s) or other appropriate analyses by the 

Department that the particular sales or transfers would not result in potentially significant 

impacts to the domestic uranium industries. Accordingly, the potential impacts 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 Alternative is defined as the status quo. The 

environmental impacts that would result under the 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 

DUF6 and non-DUF6 cylinders indefinitely in yards at the Paducah and Portsmouth sites, with 

continued cylinder surveillance and maintenance activities. These non-DUF6 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 facility26 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 incorporated 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 the 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 beneficial or adverse, to the current uranium production, conversion, or 

enrichment industries; nor to associated employment; 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 from 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 person undertakes such other actions. Cumulative impacts can result 

from individually minor but collectively significant actions taking place over a period of time 

(40 CFR § 1508.7). The following sections summarize and generally incorporate by reference, 

based on review of existing NEPA documents, relevant cumulative impacts analyses that were 

 

26 Available online at http://web.ead.anl.gov/uranium/pdf/PAD-Summary.pdf. 27 Available online at http://web.ead.anl.gov/uranium/pdf/PORT-Summary.pdf. 
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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 where 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 feed at the ACP, these enrichment services 

would be a part of the enrichment services normally provided by the ACP 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 capacity 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 where 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 feed at the NEF, these enrichment services 

would be a part of the enrichment services normally provided by the NEF and would not add to 

the enrichment capacity or throughput provided at the NEF. Because enriching DOE's uranium 

inventory would not increase the enrichment capacity 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 Operation 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 enrichment operations by USEC, waste management 

activities, waste disposal activities, environmental restoration activities, and DUF6 management 
Final Environmental Assessment: 

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activities. Actions occurring near the Paducah site 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 Joppa, Illinois, power plant; and the Honeywell 

International uranium conversion plant in Metropolis, Illinois. 

• The cumulative collective radiological exposure 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 involved workers would be monitored to maintain 

exposure below the regulatory limit of 5 rem per year. 

• Under the EIS’s no action alternative cumulative 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). Under the EIS’s action alternatives, 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 year under all alternatives and for all 

transportation modes. 

• The Paducah site is located in an attainment region. However, the background annualaverage concentration of particulate matter less than 2.5 microns in diameter (PM2.5) is 

near the regulatory standard. Cumulative impacts would not affect attainment status. 

• Data from the 2000 annual groundwater monitoring showed that four pollutants exceeded 

primary drinking water regulation levels in groundwater at the Paducah site. Good 

engineering and construction practices should ensure that indirect cumulative impacts on 

groundwater associated with the conversion 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 Indiana bat; however, this federal- and statelisted endangered species is not known to utilize these areas. 

• No cumulative land use impacts are anticipated for any of the alternatives. 

• It is unlikely that any noteworthy cumulative 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 considered are anticipated to be generally 

positive, often temporary, and relatively small. 
Final Environmental Assessment: 

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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 enrichment 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, the cumulative impacts evaluated in DOE 2004a 

would not be changed by the cumulative impacts 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 operation of a large research complex on DOE 

property located about 1.6 kilometers (1 mile) from AREVA NC: Construction and Operation of 

a Physical Sciences Facility (PSF) at the Pacific Northwest National Laboratory, Richland, 

Washington (DOE 2007c).28 In January 2007, DOE issued a FONSI for the PSF EA29 which 

found that “no noticeable cumulative impacts” with 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 delivery 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 deliveries are consistent with current AREVA NC 

operations.30 Because construction and operation of the 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 impacts 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 the renewal of the CFFF license (License No. 

SNM-1107) (NRC 2007a). The EA included the following assessment of cumulative impacts: 

“The NRC staff has evaluated whether cumulative environmental effects could 

result from the incremental impacts of the SNM–1107 license renewal for the site 

when added to relevant past, present, or reasonably foreseeable future actions in the 

area. No significant cumulative effects were 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: 

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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 standards 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 reasonably 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 cumulative 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 likely 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 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 the CFFF. Such deliveries are consistent with current CFFF operations. Because the 

Proposed Action would not impact or expand the CFFF operations, the cumulative impacts 

evaluated in NRC 2007a would not be changed by the cumulative impacts expected to occur at 

the CFFF under the Enrichment Alternative assessed in this EA. 

Global Nuclear Fuel–Americas 

To assess the potential for cumulative impacts 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 responded 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 (River 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 Facility. The ATC II office complex will be 

located adjacent to the existing ATC I office building in the southeastern portion of 

the Eastern Site Sector, near the south gate Wilmington site entrance. The entire 

project will disturb approximately 30 acres (12 hectares) of the Wilmington site. In 

preparation for the new office complex, the site has constructed a stormwater 

retention pond and has installed a new parking lot and a set of temporary trailers in 

front of the existing ATC I building. The temporary trailers will serve as offices 
Final Environmental Assessment: 

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until the new complex is completed. There will be no effluents from these activities 

aside from those associated with construction and sanitary waste. The facility will 

require an estimated 7,500 gallons (28,400 liters) 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 and that the same volumes of process and 

sanitary wastewaters would be generated for treatment in the existing Wilmington 

site final process lagoon facility 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 facilities 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 are 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 changed by the cumulative impacts expected to occur 

at GNF-A under the Enrichment Alternative assessed in this EA. 

4.5.1.2 Cumulative Transportation Impacts 

In Section 8.4.1.5 in DOE (2008c), cumulative impacts 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 the public, and 130 traffic fatalities. 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: 

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4.5.1.3 Cumulative Storage Impacts 

The possession limits for uranium at NRC-licensed FFFs are typically given in terms of 

kilograms of 235U. At an enrichment of 4.95 percent, 1 kilogram of uranium contains 

0.0495 kilograms of 235U. NRC licenses allow for the possession of 75,000 kilograms of 235U at 

AREVA NC, 50,000 kilograms of 235U at GNF-A, and 75,000 kilograms of 235U at the CFFF. 

DOE would not store 235U at the FFFs in excess of these amounts 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 235U, or about 

9,700 kilograms per year of 235U 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 store up to 670 MTU of LEU containing about 

33,200 kilograms of 235U 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 entire 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 construction and operation of proposed UF6 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 UF6 (140,000 MTU)31 was analyzed; at the Paducah site, about 

450,000 MT of UF6 (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 analyzed at Paducah. Furthermore, 

the LEU would be the result of enrichment of UF6 stored at DOE Paducah and DOE Portsmouth 

and would not represent a net increase 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 same manner and using essentially the same 

facilities as would 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 Enrichment Alternative. 

4.5.3 No Action Alternative 

Under the No Action Alternative, DOE would not enrich and/or sell any of the excess inventory 

but rather would continue with existing plans to convert the excess DU stored 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 being stored at these two sites. The cumulative 

 

31 To convert MT of UF6 to MTU, multiply by 0.67612 (USEC 2006, Table 5). 
Final Environmental Assessment: 

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impacts that would occur under the No Action Alternative assessed in this EA are the same as 

the cumulative impacts identified for the two new conversion facilities in Table 4-3, Summary of 

Expected Impacts from Operation of the Paducah and the Portsmouth Conversion Facilities. 
Final Environmental Assessment: 

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5.0 IRREVERSIBLE AND IRRETRIEVABLE 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 nonrenewable 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 resources. 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 Action, 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 alternatives contemplate the potential 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-Term Uses of the Human Environment and 

the Maintenance and Enhancement of Long-Term Productivity 

The Proposed Action does not involve major new construction. It would be implemented at 

existing sites or sites currently under construction, and over existing transportation 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. 
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APPENDIX A: SECRETARY OF ENERGY’S MARCH 2008 POLICY STATEMENT 
Final Environmental Assessment: 

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 A-2 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

 A-3 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

 A-4 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-1 

APPENDIX B: TRANSMITTAL LETTERS AND DISTRIBUTION LISTS 

This appendix contains (1) copies of the transmittal letters sent to the agencies, organizations, 

and individuals receiving the draft 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 Letters 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-3 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-4 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-5 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-6 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-7 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-8 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-9 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-10 
Final Environmental Assessment: 

Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium 

B-11 

Final EA Transmittal Letter 
Final 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 98504-7703 
Final 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 Regulatory 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 80111 
Final 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 DUF6

Final EIS for the Proposed American Centrifuge Plant in Piketon, Ohio 

NUREG-1834 (April 2006) 

http://www.nrc.gov/reading-rm/doc-collections/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), source material, and byproduct 

material at the proposed American Centrifuge Plant (ACP), a 

gas centrifuge uranium enrichment 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 Enrichment Facility in Lea County, New Mexico 

NUREG-1790 (June 2005) 

http://www.nrc.gov/reading-rm/doc-collections/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 (235U) 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 Depleted 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 DUF6 inventory into DU oxide 

(primarily U3O8) and other conversion products. The action 

includes construction, operation, maintenance, and D&D of the 

proposed DUF6 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 CaF2 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 Depleted 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 DUF6 inventory into DU oxide 

(primarily U3O8) and other conversion products. The action 

includes construction, operation, maintenance, and D&D of the 

proposed DUF6 conversion facility at the Portsmouth site; 

transportation of DUF6 cylinders from ETTP to Portsmouth for 

conversion, and transportation of non-DUF6 cylinders from 

ETTP to Portsmouth; construction 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 CaF2 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 Statement 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/documents/nepacomp/peis/index.cfm

This 1999 PEIS assessed the potential impacts of alternative 

DOE management strategies for DUF6 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, Tennessee. The alternatives analyzed 

in the PEIS included no action, long-term storage as UF6, longterm storage as uranium oxide, use as uranium oxide, use as 

uranium metal, and disposal. 

DOE decided to 

promptly convert 

the DUF6

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, interim storage at the Department’s Y12 Plant in Oak Ridge, Tennessee. 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, except 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 presented 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 Russian 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/product.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 weapons 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, North 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 Portsmouth 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 pursuant to the USEC Privatization 

Act, which requires the Secretary 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: Westinghouse Electric Company, LLC 

The proposed action in this 2007 EA is to renew the SNM1107 license for a 20-year period, thereby authorizing WEC to 

continue manufacturing nuclear fuel at the CFFF. The current 

license authorizes WEC to receive, 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 warranted, 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 Facility, 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 UO2 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 UF6 to UO2, 

which would eventually replace the current ammonium 

diuranate process. An interim period 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 radioactive 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 UF6 to UO2 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 Operation 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 EA 
D-2 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

1. United States 

Enrichment Corporation (USEC) 

Typical truck shipments of 30B cylinders are 5 cylinders per truck not 3 per truck as assumed in the study. 

Three cylinders per truck werassumptions contained in the Impact Statement for the PropEnrichment Facility in Lea C(NRC 2005). In general, assuper truck instead of five cylinresult in higher estimates of tshipments, and correspondingincident-free transportation imfatalities. Similarly, the consetransportation accidents woulhigher if five cylinders per truthe other hand, the probability transportation accident would lower because fewer shipmenRadiological accident risks wif five cylinders per truck werhigher consequences of accidthe lower probability of accidshipments. 

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 more attractive"? 

Line #4 now reads: “Changes prices for NU, DU, LEU, and may affect the economic advaenrichment of NU, DU, and L
D-3 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

3. USEC Page 5, Line # 16: Limiting the scope of the enrichment alternative 

to only those tails cylinders exceeding 0.35% should be reevaluated 

since the economics may favor additional processing under 0.35%. In addition, a large inventory of DU is just below 0.35% and should not be excluded. 

The scope of this EA was estwith the Department’s currenconsideration of the potential those DU tails with an assay 0.35% 235U. It should be note

the Proposed Action, DOE mcylinders with slightly less th

cylinder with 0.345 to 0.349% 

enrichment in order to avoid cylinders (and the risks assochandling). Additional NEPA conducted, as appropriate, if planning or proposed activitie

4. USEC Page 10, Table 2.1: The number cylinders listed for the DU Feed 

does not agree with the MTU quantity. DOE DU Feed >0.35% is almost entirely stored in 48G cylinders containing 8.4 - 8.6 MTU per cylinder. This would result in around 8,860 cylinders not 10,776 cylinders as listed in the table. The MTU/cylinder appears to be incorrect 

A corrected cylinder count wSummary, Tables 2-1 and 4-6

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 the quantity sold in a given year not necessarily the amount produced. 

For example, 6,000 MTU might be produced in one year and sold over a 3 year period. 

Your comment is noted. DOE action plan aimed at mitigatinsignificant impacts on the domunder the Proposed Action. 

6. USEC Page 12, Line # 30: Almost all of the subject DU Feed cylinders 

are stored in "thin-wall" 48G cylinders. Due to recent changes in DOT requirements, all of these cylinders must be shipped domestically in protective overpacks. The shipment of 48G cylinders internationally is an unknown since it is not currently allowed. International shipments would require a more extensive Certificate of Compliance and agreement of the competent authorities or alternatively transferring the material into compliant cylinders. The international community utilizes the requirements specified by the IAEA for determination of transportation safety. 

Section 4.1 of the EA was mocylinder preparation activities discussion presented in AppeDUF6 (DOE 1999b). This inc

(1) placing nonconforming cymetal overcontainers for ship(2) transferring UF6 from non

to new cylinders. The impactwere added to Table 4-3 in th

7. USEC Page 19, Line # 17: The area is served by one interstate highway 

(1-24). 

Line # 17 now reads: “The ainterstate highway (I-24).” 

8. USEC Page 19, Line # 22: The Paducah GDP has operated since 1952 Line # 22 now reads: “The P

operated since 1952.” 
D-4 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

9. USEC Page 37, Line #’s 17 -19: Update: In 2007, seven companies 

marketed 85% of the estimated world uranium mine production of 41,279 tonnes U308 Source: WNA World Uranium Mining 

Information Paper, July 2008 

The suggested text and referesuggested. Reference link: ht

nuclear.org/info/inf23.html. 

10. USEC Page 38, Line # 31: Update: In 2007, the 104 US nuclear power 

reactors generated a record 806.5 billion kWh and achieved an average 91.8% capacity factor Source: WNA Nuclear Power in the USA Information Paper, January 2009 

The suggested text and referesuggested. Reference link: ht

nuclear.org/info/inf41.html#c

11. USEC Page 39, Line # 6: Replace gross national product with gross 

domestic product. 

Change made as suggested. 

12. USEC Page 55, Line # 29: ACP is scheduled to begin enrichment 

operations in 2010 

Change made as suggested. 

13. USEC Page 59, Line # 12: DOE tails >0.35% assay are almost entirely 

stored in 48G cylinders (not 48Y) 

The text of the EA was modifprimarily stored in 48G cylinadded to state that DU could 30A, 48H, 48O, 48OM, 48X, 

14. USEC Page 59, Line # 16: LEU with enrichment >1.0% is typically 

transported in 30B cylinders. There are no overpacks currently licensed to ship enriched product in 48 inch cylinders. 

The text of the EA was modifwith enrichment > 1 percent i30B cylinders, but that becaufeed is currently stored in 48X that the 48X cylinder was useAlso, text was added to the imEA to provide the impacts of the LEU feed. See Comment cylinder transfer impacts. 

15. AREVA We would like to express our appreciation to the Department for 

their efforts to clarify sales of inventory by issuing the Excess Uranium Inventory Management Plan, dated December 16, 2007. We believe that the Plan is a positive step toward effective disposition of excess inventories. 

Your comment is noted. 
D-5 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

16. 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 the Department’s excess uranSecretary’s Policy Statement DOE’s Excess Uranium Inve2008 (Secretarial Policy StateAction analyzed in this EA is Secretarial Policy Statement. anticipates that it may introduany given year, amounts up to annual fuel requirements of apower plants, or, in some yeapurposes such as the provisiofor new reactors, more than thissued a mitigation action plaany potentially significant imuranium industry under the P

17. AREVA If the Department continues to conduct regular (semi annually, or 

quarterly) auctions of uranium material in the spot market, but suspends such spot sales if the spot price falls below a reasonable minimum level related to US miners' total costs (plus reasonable profit), it would effectively ensure that Department sales do not undermine the US miners' operations and investments, while optimizing return to the Department. 

Your comment is noted. 

18. AREVA Employing only spot market transactions would simplify the 

Department's objective evaluation of offers. Long term sales are complex, have multi-year impact on demand, and are less transparent than spot sales because long-term contracts can vary greatly in pricing methodology and terms and conditions. 

Your comment is noted. 

19. Global Nuclear 

Fuel (GNF) 

 GNF-A very much looks forward to this program because handling 

UF6 is a core competency for GNF-A and one that will serve the 

DOE well. We stand ready to assist you as matters progress. We have performed a comprehensive review of the Reference document and find no additional comments are warranted with respect to the Wilmington site or our capabilities. 

Your comment is noted. 
D-6 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

20. LES On page 14, in 2.4.1 Other Enrichment Facilities there is an error 

that begins in line 33. The statement in the document, "however, France is the only foreign country where the necessary agreements are already in place." There are in place existing international agreements between the United States and Euratom that would allow this work to be done in those European countries that have enrichment capability. The draft environmental assessment should take this agreement into account. 

This text now beginning on libeen changed to read, “This Eassociated with transportation representative of potential imenrichment at any foreign facwould vary in proportion to thfacility in another country wathe French facility in Tricastienrichment facilities are operEuropean countries, as well athis time, the United States ha(Section 123 of the Atomic EPeaceful Nuclear Cooperation countries such as Japan, and wpart of the European Atomic (Euratom), including France foreign enrichment facilities cthe future if the necessary agrimplemented.” 

21. Commonwealth 

of Kentucky (Division of Water) 

This project has the potential to be a massive environmental problem. The Paducah Gaseous Diffusion Plant does not have a good track record with discharge limits and bioassay tests. 

Your comment is noted. The environmental assessment is potential environmental impaactivity. The potential impactenrichment operations and thhave been previously analyzedocuments. See Section 3.1.1Table 4.3 for specific discussPaducah site. The EA assumePaducah Gaseous Diffusion PDUF6 Conversion Facility wo

compliance with all applicabllocal regulations. Please see E2007b for information regardcompliance, monitoring, and Paducah site. 
D-7 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

22. Commonwealth 

of Kentucky (Division of Water) 

Water Quality Management - This will not directly impact water management planning, floodplain construction or water withdrawal permitting. 

Your comment is noted. 

23. Commonwealth 

of Kentucky (Division of Water) 

The Division of Enforcement does not object to the project proposed by the applicant. 

Your comment is noted. 

24. Commonwealth 

of Kentucky (Division for Air Quality) 

The Division for Air Quality would like to stress the importance of the following comments since the Paducah area is borderline for PM2.5 24-hour standard nonattainment. 

Kentucky Division for Air Quality Regulation 401 KAR 63:010 Fugitive Emissions states that no person shall cause, suffer, or allow any material to be handled, processed, transported, or stored without taking reasonable precaution to prevent particulate matter 

from becoming airborne. Please note the Fugitive Emissions Fact Sheet located at http://www.air.ky.gov/homepage_repository/eClearinghouse.htm. 

Additional requirements include the covering of open bodied trucks, operating outside the work area transporting materials likely to become airborne, and that no one shall allow earth or other material being transported by truck or earth moving equipment to be deposited onto a paved street or roadway. Kentucky Division for Air Quality Regulation 401 KAR 63:005 states that open burning is prohibited. Open Burning is defined as the burning of any matter in such a manner that the products of combustion resulting from the burning are emitted directly into the outdoor atmosphere without passing through a stack or chimney. However, open burning may be utilized for the expressed purposes listed on the Open Burning Fact Sheet located at http://www.air.ky.gov/homepage_repository/e-Clearinghouse.htm. 

The EA assumes that operatioGaseous Diffusion Plant and 

Conversion Facility would be compliance with all applicabllocal regulations, including th

fugitive emissions, transport bodied trucks, and open burnSection 4.1, and Table 4.3 for related to the Paducah site. PlDOE 2007b for information rcompliance, monitoring, and Paducah site. 
D-8 

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25. Commonwealth 

of Kentucky (Division for Air Quality) 

The Division also suggests an investigation into compliance with applicable local government regulations. 

The EA assumes that operatioGaseous Diffusion Plant and 

Conversion Facility would be compliance with all applicabllocal regulations. Please see E2007b for information regardcompliance, monitoring, and Paducah site. 

26. Uranium 

Producers of America 

UPA members strongly believe that a robust domestic uranium producing industry is critical to our country's energy independence and national security. Present domestic production of natural uranium is simply too low to achieve these goals. 

Your comment is noted. 

27. Uranium 

Producers of America 

The DOE must make any disposition of excess government inventories in such a manner as to not impact the commercial uranium market and to not prevent domestic fuel suppliers from gaining the necessary investment to reestablish a successful uranium producing industry that will assure the nation's energy independence in the nuclear arena. 

The principles and framework the Department’s excess uranSecretarial Policy Statement iaddition, DOE has issued a maimed at mitigating any potenimpacts on the domestic uranProposed Action. 

28. Uranium 

Producers of America 

UPA supports the DOE's December 16, 2008 Excess Uranium Inventory Plan ("Plan"). The Plan incorporates a nuclear industry consensus for introducing government excess uranium inventories into the commercial market. The Plan's adoption of a gradual introduction of excess material will lessen the impact of such excess uranium disposition on domestic producers. The Plan properly recognizes the limited near term spot market availability for such excess material. The Plan also recognizes the benefits of long-term contracts to reduce the adverse impacts of government sales. Finally, the Plan acknowledges the necessity to conduct a comprehensive Secretarial Determination of the potential adverse impact to the domestic fuel suppliers prior to each government sale or disposition of excess inventory material. 

Your comment is noted. 
D-9 

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29. Uranium 

Producers of America 

At page 81 of the Environmental Assessment, it is noted that DOE's authorization to sell the government's excess uranium under the Atomic Energy Act of 1954, as amended, is derived from Section 3112(d) of the 1996 USEC Privatization Act, Public Law 104-134 (42 U.S.C. 2297h, et .seq.). This Act requires a Secretarial Determination that any such sale of excess uranium inventories will not have an "adverse material impact" on the domestic mining, conversion and enrichment industry. UPA members, as potentially impacted stakeholders from such sales, urge DOE to make the required "determinations" more open and transparent than these determinations have been in the past. 

In Section 4.3.2 of the EA, Dauthority to sell excess uraniuauthorized to sell its excess uAtomic Energy Act of 1954, provisions of the 1996 United Corporation Privatization AcSection 3112(d) of that Act stother things, prior to selling NDepartment’s excess inventorEnergy must determine that tadverse material impact on thmining, conversion, and enricConsistent with the Secretariatransactions involving non-Uwill be undertaken in a transpmanner, unless the Secretary writing that overriding Depardictate otherwise. 

30. Uranium 

Producers of America 

Input from the impacted stakeholders would provide the Department with market information and potential impacts of which the DOE may be unaware. For example, DOE conducted a sale of excess inventories in August 2006, that resulted in material adverse impacts on the domestic uranium industry. The sale into the spot market took place during August, a known slow period for uranium sales in a calendar year. The sale also was conducted in a manner that failed to achieve fair market value for the materials, thus contrary to the requirements of the Privatization Act. The August 2006 sale, while relatively small in pounds of uranium, had a material adverse impact on the price of uranium and the ability of domestic producers to obtain necessary investment necessary to proceed with new operations. The Secretarial Determination and conduct of this sale was flawed. In order to avoid adverse impacts from future inventory sales, DOE should conduct future determinations with more transparency and input from affected stakeholders. 

Your comment is noted. ConSecretarial Policy Statement, non-U.S. Government entitietransparent and competitive mSecretary of Energy determinoverriding Department missiootherwise. 
D-10 

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31. Uranium 

Producers of America 

At pages 81-82 of the Environmental Assessment, it is noted that DOE commissioned a report from Energy Resources International, Inc., entitled Quantification of the Potential Impact on Commercial Nuclear Fuel Markets of the Sale by the U.S. Government of Selected Inventory. The ERI assumed sales by DOE of approximately 10 percent of the average annual U.S. requirements 

for uranium concentrates in its analysis. UPA disagrees with ERI's 

analysis that such sales would not have an adverse impact, particularly on producers that are working to bring new production sites online through the rigorous permitting process required for today's uranium mines and mills. Specifically, contrary to ERI's analysis, planned operations do not have committed production levels with forward future sales. 

Information obtained and useindicates that some level of foestablished by the domestic uindustry. DOE has issued a maimed at mitigating any potenimpacts on the domestic uranProposed Action. 

32. Uranium 

Producers of America 

However, DOE's December 16, 2008 Plan mitigates UPA's concerns with ERI's analysis. The Plan properly recognizes the importance of smaller inventory disposition sales in the near term and does not contemplate assumed sales of 10 percent of the average U.S. requirements for uranium concentrates in the near term. 

Your comment is noted. DOE action plan aimed at mitigatinsignificant impacts on the domunder the Proposed Action. 

33. Uranium 

Producers of America 

DOE’s Excess Uranium Inventory Management Plan does incorporate the Industry Consensus suggestion that the Department conduct sales to U.S. utilities requiring initial cores for new built reactors. These initial core sales will meet the Department's near term sales needs and are endorsed by UPA. 

Your comment is noted. 

34. Uranium 

Producers of America 

UPA agrees with ERI at page 82 of the Environmental Assessment that the perceived uncertainty in the investment communities concerning future DOE disposition of excess uranium material has created a perception of risk for investment in new uranium production operations. It is imperative to generate continued new investment for new uranium operations that the Plan be followed in the future for disposition of government uranium materials. 

Your comment is noted. 

35. Uranium 

Producers of America 

The ERI report fails to adequately consider the potential impacts of DOE inventory disposition sales on the ability of new producers to acquire the necessary investment to permit and construct new domestic uranium mines and mills. 

Information obtained and useindicates that some level of foestablished by the domestic uindustry. In addition, DOE haaction plan aimed at mitigatinsignificant impacts on the domunder the Proposed Action. 
D-11 

Comment 

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36. Uranium 

Producers of America 

New U.S. uranium production is critical for our nation's national security and energy independence. However, the DOE Plan addresses this impact in a more positive manner, by ramping up sales of uranium materials over time. 

Your comment is noted. 

37. Uranium 

Producers of America 

UPA agrees with the Environmental Assessment to the extent that it recognizes that the demand for uranium is growing and there is a need for new domestic production. The nation's reactors are over reliant on foreign uranium and this is shortsighted policy. New domestic mines can compete with foreign production and should be encouraged. 

Your comment is noted. 

38. Uranium 

Producers of America 

UPA agrees with the statement at page 82 of the Environmental Assessment that domestic uranium producers should be able to sell their annual production in a competitive market. It must be recognized, however, that in these difficult economic times, the investment necessary to build new uranium production facilities can be impeded by government sales. Future government sales of excess uranium inventories must be carefully scrutinized in the Secretarial Determinations and not simply subjected to a cursory review of market impacts. Again, failure to conduct stringent, transparent determinations will result in less than fair market values for excess government uranium material and will adversely impact the domestic production industry. 

DOE has issued a mitigation mitigating any potentially sigdomestic uranium industry unAction. Consistent with the SStatement, transactions involvGovernment entities will be utransparent and competitive mSecretary of Energy determinoverriding Department missiootherwise. 

39. Uranium 

Producers of America 

The Environmental Assessment concludes that sales of government excess uranium inventories are expected to have small impacts on the uranium industries. UPA believes that the sales on a schedule like that set forth in the DOE Plan, together with careful, transparent scrutiny applied in the Secretarial Determination accompanying these sales can have a lesser impact than simply selling 10 percent of the total annual fuel requirements of all licensed U.S. nuclear power plants. UPA urges DOE to follow its Plan. 

Your comment is noted. 
D-12 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

40. Commonwealth 

of Virginia (Department of Environmental Quality [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 and decommissioning of facilities. However, the EA does not address the environmental impacts to surface waters in the case of an accident or act of terrorism. 

Previous analyses of transporhave shown that accident impradioactive material is releaseopposed to being released to the relative importance of the versus the drinking water or aas routes of exposure. This teSection 4.2.1. Estimated impagroundwater, soil, and ecologbeen established in DOE 200are discussed in Table 4-3 anEA. 

41. Commonwealth 

of Virginia (DEQ) 

The EA does not discuss the off-loading or handling requirements from vessel to rail or truck. 

The impacts discussed in Secimpacts from port operationsimpacts from port operations DOE 1994 and DOE 1999a. A requirements for UF6 is conta

More details can be found in Transportation regulations su174, 176, 177, and 178, and UCommission regulations such 

42. Commonwealth 

of Virginia (DEQ) 

The DEQ Office of Wetlands and Water Protection states that the 

effects of a uranium spill in Virginia within surface waters, including wetlands, would depend on the material released, location of the accident and atmospheric conditions at the time. 

Previous analyses of transporhave shown that accident impradioactive material is releaseopposed to being released to the relative importance of the versus the drinking water or aas routes of exposure. This teSection 4.2.1. Estimated impagroundwater, soil, and ecologbeen established in DOE 200are discussed in Table 4-3 anEA 

43. Commonwealth 

of Virginia (DEQ) 

Should a uranium spill occur in Virginia within surface waters, including wetlands, appropriate cleanup and remediation would be required. Immediate notification of a hazardous material incident by a carrier is required at the earliest practical moment to the 

Department of Emergency Management or local emergency 

DOE Order 460.2A requires tconduct operations in compliinternational, federal, state, lorules, and regulations governtransportation that are not inc
D-13 

Comment 

Number 

Reviewer Name/ 

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responders. regulations. This would inclu

Transportation hazardous ma

contained in 49 CFR 171 throCarrier Safety Administration in 49 CFR 395 and 397, and URegulatory Commission reguCFR 71, as applicable. DOE establishes a set of standard tfor DOE to use in planning anshipments of radioactive mateestablish a standardized proceinteracting with state, tribal, aother federal agencies, and trand carriers regarding DOE rshipments. Practices are desctopics: 

• Transportation plannin

planning activities that need for shipment has 

• Emergency planning—

planning activities with jurisdictions; 

• Projected shipment pla

provision of informatioshipments; 

• Routing—practices to 

transportation routes; 

• Security—actions take

of shipments; 

• Carrier/driver requirem

ensure that shipments uand drivers; 

• Shipment prenotificatio

notification activities f

• Transportation operatio

operational contingenc
D-14 

Comment 

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normal transport opera

• Tracking—DOE practi

location of shipments acommunication with thvehicles; 

• Inspections—inspectio

including verifications roadworthiness and radcontainers loaded on th

• Safe parking—the crite

selecting appropriate pevent that transportatiocontingencies occur; 

• Emergency notification

uses to notify state and DOE itself has receivetransportation emergen

• Emergency response—

transportation emergen

• Recovery and cleanup—

actions taken to recoveaccident or incident. 

In addition, U.S. Department regulation 49 CFR 171.15 conotification of transportation hazardous materials. This text has been added to S

44. Commonwealth 

of Virginia (DEQ) 

If the size or scope of the project changes, additional review by the DEQ Office of Wetlands and Water Protection may be necessary. 

Such changes to the DOE Protrigger an additional NEPA rereview and the nature of stakwould vary depending upon tchanges to the Proposed Acti
D-15 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

45. Commonwealth 

of Virginia (DEQ) 

The Department of Conservation and Recreation (DCR) performed a 2-mile radius search from the representative rail and truck transportation routes displayed in the EA (figure 4-1, page 58) According to the information currently in DCR's files, there are several occurrences of natural heritage resources that could potentially be impacted. Also there are several Threatened and Endangered Species Waters with the 2-mile radius. 

As discussed in the response transportation routing is one oestablished in DOE Manual 4were made through Virginia, resources and Threatened and Waters would be considered to the extent required by regupracticable. 

46. Commonwealth 

of Virginia (DEQ) 

The routes pass through extensive areas of karst topography in Wythe, Bland and Scott counties as well as some other karst areas in Russell and Wise counties. Any accident involving the release of hazardous materials, such as uranium, could contaminate karst aquifers along the route. These karst aquifers supply water for public drinking water supplies and also provide water for domestic and agricultural users. 

As discussed in the response transportation routing is one oestablished in DOE Manual 4were made through Virginia, be considered in the routing prequired by regulations and a

47. Commonwealth 

of Virginia (DEQ) 

Threatened and Endangered Plant and Insect Species. Under a Memorandum of Agreement established between the Virginia Department of Agriculture and Consumer Services (VDACS) and DCR, DCR has the authority to report for VDACS on state-listed plant and insect species. DCR found that the proposed activity may impact several state-protected plants and deferred to VDACS, which has regulatory authority to conserve rare and endangered plant and insect species through the Virginia Endangered Plant and Insect Species Act. However, VDACS did not respond to DEQ's request for comments. 

As discussed in the response transportation routing is one oestablished in DOE Manual 4were made through Virginia, would be considered in the roextent required by regulation

48. Commonwealth 

of Virginia (DEQ) 

Conservation sites that are located around natural heritage resources should be incorporated into emergency response plans developed for the transportation corridors. Conservation sites are areas located 

around one or more rare plant, animal or natural communities and 

are designed to include the species and its habitat in order to allow for the species conservation. Conservation sites are given a biodiversity significance ranking based on the rarity, quality and number of occurrences they contain on a scale of 1-5, 1 being the most significant. 

The development of local emthat incorporate entities such are the responsibility of state officials. 
D-16 

Comment 

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49. Commonwealth 

of Virginia (DEQ) 

DCR strongly suggests that hydrologic investigations be performed along the course of the transportation route where it passes through karst terrain or is upstream from karst terrain in order to determine 

the boundaries and extent of these karst groundwater basins, in order to facilitate required emergency responses and better enable the mitigation work that would follow any accidents resulting in the release of hazardous materials. DCR recommends the investigations include dye tracer studies to determine the associated groundwater flow paths and the identification of sinkholes and other associated karst features including springs and wells that could be affected by spills of hazardous materials along the primary transportation corridors. 

As discussed in the response transportation routing is one o

established in DOE Manual 4were made through Virginia, be considered in the routing prequired by regulations and aof the low probability of an arelease of UF6 occurring in an 

topography, hydrologic invesconducted unless such an acc

50. Commonwealth 

of Virginia (DEQ) 

Coordinate with the U.S. Fish and Wildlife Service (FWS), Virginia Department of Game and Inland Fisheries (DGIF) and VDACS to ensure compliance with protected species legislation. 

As discussed in the response Manual 460.2-1A establishes and framework for interacting local authorities, and other fewould include coordination wWildlife Service, the Virginia and Inland Fisheries, and VD

and required by regulations, twith protected species legisla

51. Commonwealth 

of Virginia (DEQ) 

Implement safety measures and notify localities of when and where 

the transportation of nuclear waste will occur. 

As discussed in the response shipment prenotification is onestablished in DOE Manual 4practices established in the mmeasures, such as routing, carequirements, and inspections

52. Commonwealth 

of Virginia (DEQ) 

According to DGIF's records, there are a variety of listed species known from these regions. However, based on the information provided, new construction and/or impacts to wildlife resources under DGIF's jurisdiction are not proposed. 

The EA does not contemplate 

53. Commonwealth 

of Virginia (DEQ) 

Provided all nuclear material is safely contained and appropriately handled and transport on existing transportation infrastructure can 

be accomplished in a safe manner and is not subject to transportation accident, direct attack, and/or other incident that 

would result in impacts to wildlife resources under DGIF's jurisdiction, DGIF does not anticipate that the project would result in adverse impact to such resources. 

Your comment is noted. 
D-17 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

54. Commonwealth 

of Virginia (DEQ) 

DGIF recommends that the applicant coordinate with the U.S. Fish and Wildlife Service regarding potential impact to federally-listed species. 

As discussed in the response Manual 460.2-1A establishes and framework for interacting local authorities, and other fewould include coordination wWildlife Service, as appropriaregulations, regarding the potfederally listed species. 

55. Commonwealth 

of Virginia (DEQ) 

Solid and Hazardous Wastes and Hazardous Materials. The DEQ Waste Division recommends that for each area in Virginia where transportation of nuclear materials will occur, DOE should conduct an environmental investigation on and near the work area to identify any solid or hazardous waste sites or issues before the work commences. The investigation should include a search of waste related databases. 

As discussed in the response transportation routing is one oestablished in DOE Manual 4were made through Virginia, hazardous waste sites or issuein the routing process, to the regulations and as practicable

56. Commonwealth 

of Virginia (DEQ) 

Air Quality Impacts. The impact of the proposed project to dispose excess depleted uranium on Virginia air quality will be emissions arising from the use of truck, rail or barge transportation in the event the Portsmouth site is utilized. Incremental increase in the transportation load due to this project is not likely to be significant enough to have any perceptible impact on air quality. In the event of a severe rail or road accident, particle pollution may temporarily increase due to a collision, but its effect is far less than the radiation effects outlined in the EA. 

The analysis in the EA indicaUF6 using existing transporta

would have minimal air quali

57. Commonwealth 

of Virginia (DEQ) 

Transportation Impacts. Transport by Barge/Ship. The Virginia Port Authority (VPA) states that Virginia International Terminals (VIT), 

the marine terminal operator for the Virginia Port Authority, is prepared to accept Class 7 hazardous materials at the Virginia Port Authority 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 is required, the shipment will be considered Certain Dangerous Cargo and additional handling charges will be required. The VPA welcomes opportunity to receive additional freight and is prepared to discuss future shipment options with DOE. 

Your comment is noted. 
D-18 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

58. Commonwealth 

of Virginia (DEQ) 

Transportation Impacts. Transport by Trucks. The Virginia Department of Transportation (VDOT) has reviewed the information provided for the above referenced project and commented on the potential for impacts to the existing and proposed transportation facilities. In the southwestern area of the state, the primary route identified for truck shipments is Interstate 77 (Figure 4.1, Page 58) which requires passage through two tunnels (Big Walker Mountain and East River Tunnel). At present, these tunnels have no restrictions for hazmat loads; however, an 

increased transportation security issue is generated due to terrorism during passage. While it may be a matter of national security, early notification and preparation will be critical to ensure safe passage. In addition, the potential risk from radiological release in a confined space should be considered in the event an accident or mechanical malfunction occurs in the tunnels. 

As discussed in the response transportation routing is one o

established in DOE Manual 4are made through Virginia, emissues would be considered in the extent required by regulat

59. Commonwealth 

of Virginia (DEQ) 

Transportation Impacts. The transport of these hazardous materials through the rural regions of Virginia poses an increased risk of exposure to emergency response workers in the event of an accident. Education and training of these responders is a key risk factor in the event of an accident. Consideration should be given to providing specific training for the volunteer agencies. In lieu of 

additional training, DOE should provide a traveling Hazmat Team to monitor and secure each of these loads. 

The DOE Office of EnvironmTransportation Emergency Prconducts Modular Emergency Radiological Transportation Tprovided throughout the year United States. DOE does not provide traveling Hazmat Tea

60. Commonwealth 

of Virginia (DEQ) 

The final issue to address in the southwestern corridor of the state is related to weather conditions on the identified route. This section of Interstate 77 from Interstate 81 to North Carolina State Line experiences adverse wind and fog conditions through each season of the year. Potential exists for increased accidents due to these conditions and should be accounted for during load transport. 

The accident rates used to estinclude accidents caused by b
D-19 

Comment 

Number 

Reviewer Name/ 

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61. Commonwealth 

of Virginia (DEQ) 

In the more urban areas of the state, there is an increased potential 

for congestion if oversized trucks will be utilized for transport of the material. The EA did not clearly state whether any effort or coordination beyond that normally required for the transport of hazardous materials will be required for these shipments. Such considerations as escort vehicles, routing of oversize or overweight vehicles, incident response, security for sensitive cargo, and coordination with federal officials may already be covered in hazardous material transport regulations but any efforts or 

coordination beyond that already required should be mentioned in the final document. 

It is not anticipated that shipm

made using overweight or ovseparate escort vehicles woulanticipated that coordination U.S. Department of Transporbe required for the UF6 shipm

62. Commonwealth 

of Virginia (DEQ) 

Should the scope of the project change, DRPT would like the opportunity to provide additional comments. 

Such changes to the DOE Protrigger an additional NEPA. Tand the nature of stakeholder vary depending upon the natuProposed Action. 

63. Commonwealth 

of Virginia (DEQ) 

Prior to the transportation of hazardous waste through Virginia, notify the appropriate localities and contact the Virginia Department of Emergency Management at (804) 897-6500. 

As discussed in the response shipment prenotification is onestablished in DOE Manual 4

64. Commonwealth 

of Virginia (DEQ) 

In the final document, DOE should address potential impacts on the transportation network or reference other documents that include this information, address potential human health impacts to public and maintenance staff in tunnels in the event there is radiological release; account for adverse wind and fog conditions through each 

season and the potential for increased accidents when transporting uranium; and include a description of coordination with escort vehicles, routing of oversize or overweight vehicles, incident response, security for sensitive cargo and federal officials. 

See responses to Comments #

65. Commonwealth 

of Virginia (DEQ) 

The EA (pages 58-66) seems to indicate that the potential hazards from truck shipment to highway work zone crews and the general populace are negligible. VDOT suggests including a clear statement to that effect in the final document. 

As shown by the analyses preimpacts to workers and membsmall, ranging from 0.22 to 2truck shipments. 
D-20 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

66. Commonwealth 

of Virginia (DEQ) 

Consider providing specific training for first responders or provide a traveling hazmat team to monitor and secure each load. 

The DOE Office of EnvironmTransportation Emergency Prconducts Modular Emergency Radiological Transportation Tprovided throughout the year United States. DOE does not provide traveling hazmat team

67. Commonwealth 

of Virginia (DEQ) 

Health Impacts. The VDH Division of Radiological Health Program states that the Department of Energy's (DOE) draft EA does not appear to create any significant radiological risk to the Commonwealth of Virginia. The proposed plan describes transportation of uranium in various forms through the southwestern portion of the Commonwealth either by truck on Interstate 77 or by rail. 

Your comment is noted. 

68. Commonwealth 

of Virginia (DEQ) 

The radioactivity of the proposed DOE shipments is less hazardous than many of the radioactive materials that are currently being transported through Virginia. The Commonwealth has not experienced any significant transportation accidents involving radioactive materials for about two decades. 

Your comment is noted. 

69. Commonwealth 

of Virginia (DEQ) 

VDH is supportive of a DOE conclusion for issuing a Finding of No Significant Impact. 

Your comment is noted. 

70. Commonwealth 

of Virginia (DEQ) 

Geologic and Mineral Resources. The Department of Mines, Minerals, and Energy (DMME) does not anticipate an impact to mineral resources. The geology of southwestern Virginia (and the Coastal Plain, if a shipment is made through Norfolk) is variable and could be a factor in limiting or increasing the scope of an impact from a rail or truck accident. The depth to bedrock, permeability of bedrock or sediment, orientation of bedding or fractures, presence of karst features, and topographic setting could 

be additional factors. 

Your comment is noted. 

71. Commonwealth 

of Virginia (DEQ) 

The Hampton Roads Planning District Commission states that the proposed plans are generally consistent with local and regional plans and policies. 

Your comment is noted. 

72. Commonwealth 

of Virginia (DEQ) 

The Commonwealth has no objection to the proposed disposition of uranium or the subsequent transportation of uranium through or from Virginia provided that all applicable state and federal laws and regulations are followed. 

Your comment is noted. 
D-21 

Comment 

Number 

Reviewer Name/ 

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73. Commonwealth 

of Virginia (DEQ) 

If an accident or an intentional destructive act happens, DOE must notify the appropriate emergency officials and implement effective cleanup efforts. 

The EA assumes that during t

applicable U.S. Department ostate regulations would be folinvolving notification after acdestructive events. If such an destructive event occurred, thbe remediated, as determined 

74. Commonwealth 

of Virginia (DEQ) 

The Commonwealth strongly encourages DOE to consider and plan for mitigation of potential impacts on Virginia's natural resources, including karst topography and protected species, in the event of an accident or an act of sabotage or terrorism. 

As discussed in the response transportation planning, emersecurity are three of the practManual 460.2-1A. Accidents terrorism would be considereextent required by regulation

75. Commonwealth 

of Virginia (DEQ), Water Division 

There are no fuel fabrication facilities in Virginia and because the Proposed Action involves no new construction in Virginia, there would be no potential for the Proposed Action to impact current land use; biotic communities; cultural, historical, or archaeological resources; visual resources; ambient noise levels; threatened or endangered species or their critical habitats; wetlands; or floodplains. 

Your comment is noted. 

76. Commonwealth 

of Virginia (DEQ), Water Division 

The report does not discuss the off-loading or handling requirements from vessel to rail or truck. 

The impacts discussed in Secimpacts from port operationsimpacts from port operations DOE 1994 and DOE 1999a. A requirements for UF6 is conta

More details can be found in Transportation regulations su

174, 176, 177, and 178, and UCommission regulations such 
D-22 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

77. Commonwealth 

of Virginia (DEQ), Water Division 

The report does [not] discuss potential environmental impacts to surface waters including wetlands should a traffic accident or spill occur. 

Previous analyses of transporhave shown that accident impradioactive material is releaseopposed to being released to the relative importance of the versus the drinking water or aas routes of exposure. This teSection 4.2.1. Estimated impagroundwater, soil, and ecologbeen established in DOE 200are discussed in Table 4-3 anEA. Also, see response to Comme

78. Commonwealth 

of Virginia (DEQ), Water Division 

Should a uranium spill occur in Virginia within surface waters, including wetlands, appropriate clean up and remediation would be required. The consequences of such a release would depend on the material released, location of the accident, and atmospheric conditions at the time. Immediate notification of a hazardous material incident by a carrier is required at the earliest practical moment to the Department of Emergency Management or local emergency responders. 

See response to Comment # 4

79. Commonwealth 

of Virginia (DEQ), Water Division 

Should the size or scope of the project change, additional review may be necessary. 

Such changes to the DOE Protrigger an additional NEPA rereview and the nature of stakwould vary depending upon tchanges to the Proposed Acti

80. Commonwealth 

of Virginia, Virginia Port Authority (VPA) 

Virginia International Terminals, Inc., the marine terminal operator for the Virginia Port Authority, is prepared to accept class 7 hazardous materials at the Virginia Port Authority terminals, in Norfolk, Portsmouth and Newport News. VIT will accept all types of class 7 hazardous material; however, if the transport index is over 10 and a route control is required the shipment will be considered Certain Dangerous Cargo and additional handling charges will be required. The Virginia Port Authority welcomes opportunity to receive additional freight and is prepared to discuss future shipment options with the Department of Energy. 

Your comment is noted. 
D-23 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

81. Commonwealth 

of Virginia, Department of Transportation 

In the southwestern area of the state, the primary route identified for truck shipments is Interstate 77 (Figure 4.1 Page 58) which requires passage through two tunnels (Big Walker Mountain and East River Tunnel). At present, these tunnels have no restrictions for hazmat loads; however, an increased transportation security 

issue is generated due to terrorism during passage. While it may be a matter of national security, early notification and preparation will 

be critical to ensure safe passage. In addition, the potential risk from radiological release in a confined space should be considered, 

should an accident or mechanical malfunction occur in the tunnels. 

Potential human health impacts to public and maintenance staff in these facilities should be reviewed and determined. 

As discussed in the response transportation routing is one o

established in DOE Manual 4are made through Virginia, emissues would be considered in the extent required by regulat

82. Commonwealth 

of Virginia, Department of Transportation 

The transport of these hazardous materials through the rural regions of Virginia poses an increased risk of exposure to emergency 

response workers in the event of an accident. Education and training of these responders is a key risk factor in the event of an accident. Consideration should be given to providing specific training for the volunteer agencies. In lieu of additional training, DOE should provide a traveling Hazmat Team to monitor and secure each of these loads. 

The DOE Office of EnvironmTransportation Emergency Prconducts Modular Emergency Radiological Transportation Tprovided throughout the year United States. DOE does not provide traveling Hazmat Tea

83. Commonwealth 

of Virginia, Department of Transportation 

The final issue to address in the southwestern corridor of the state is related to weather conditions on the identified route. This section of Interstate 77 from Interstate 81 to North Carolina State Line experiences adverse wind and fog conditions through each season of the year. Potential exists for increased accidents due to these conditions and should be accounted for during load transport. 

The accident rates used to estinclude accidents caused by b

84. Commonwealth 

of Virginia, Department of Transportation 

In the more urban areas of the state, there is an increased potential 

for congestion if oversized trucks will be utilized for transport of the material. The EA did not clearly state whether any effort or coordination beyond that normally required for the transport of hazardous materials will be required for these shipments. Such considerations as escort vehicles, routing of oversize or overweight vehicles; incident response, security for sensitive cargo, and coordination with Federal officials may already be covered in hazardous material transport regulations but any efforts or 

coordination beyond that already required should be mentioned in the EA. 

It is not anticipated that shipm

made using overweight or ovseparate escort vehicles woulanticipated that coordination U.S. Department of Transporbe required for the UF6 shipm
D-24 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

85. Commonwealth 

of Virginia, Department of Transportation 

It is desired to see the EA address the potential impacts on the transportation network or to have references made to other documents that do include such information. 

See responses to Comments # 

86. Commonwealth 

of Virginia, Department of Transportation 

The EA material (especially pages 58-66) seems to indicate that the potential hazards from truck shipment to highway work zone crews and the general populace are negligible, but a clear statement to that 

effect would be helpful. 

As shown by the analyses preimpacts to workers and membsmall, ranging from 0.22 to 2truck shipments. 

87. Commonwealth 

of Virginia, Department of Rail and Public Transportation 

Should the scope of the project change or if you have any questions concerning the projects impacts to rail lines, please contact [Virginia Department of Rail and Public Transportation]. 

Such changes to the DOE Protrigger an additional NEPA rereview and the nature of stakwould vary depending upon tchanges to the Proposed Acti

88. Commonwealth 

of Virginia, Department of Rail and Public Transportation 

Impact of the proposed project to dispose excess depleted uranium on Virginia air quality will be that arising from the use of truck, rail or barge transportation in the event Portsmouth site is chosen for the purpose. Incremental increase in the transportation load due to this project is not likely to be significant to have any perceptible impact on air quality. In the event of severe rail or road accident considered in the EIR, there is a likelihood of temporary increase in 

particulate pollution but its effect is far less than the radiation effects outlined. 

The analysis in the EA indicaUF6 using existing transporta

would have minimal air quali

89. Commonwealth 

of Virginia, Department of Conservation and Recreation 

DCR performed a 2-mile radius from the representative rail and truck transportation routes displayed on Fig. 4-1 (Rail and Truck Routes), pg.58. Disposition of DOE Excess Depleted Uranium, Natural Uranium, and Low-Enriched Uranium. According to the information currently in our files, there are several occurrences of natural heritage resources that could potentially be impacted 

As discussed in the response transportation routing is one oestablished in DOE Manual 4were made through Virginia, resources and Threatened and Waters would be considered to the extent required by regupracticable. 
D-25 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

90. Commonwealth 

of Virginia, Department of Conservation and Recreation 

DCR recommends incorporation of the conservation sites zones around these natural heritage resources to be incorporated into emergency response plans developed for these transportation corridors. Conservation sites are polygons built around one or more rare plant, animal, or natural community designed to include the element and, where possible, its associated habitat, and buffer or other adjacent land thought necessary for the element's conservation. Conservation sites are given a biodiversity significance ranking based on the rarity, quality, and number of element occurrences they contain; on a scale of 1-5, 1 being most significant. 

The development of local emthat incorporate entities such are the responsibility of state officials. 

91. Commonwealth 

of Virginia, Department of Conservation and Recreation 

Due to the legal status of many of these natural heritage resources, DCR recommends coordination with the United States Fish and Wildlife Service (USFWS) and the Virginia Department of Game and Inland Fisheries (VDGIF) to ensure compliance with protected 

species legislation. 

As discussed in the response Manual 460.2-1A establishes and framework for interacting local authorities, and other fewould include coordination wWildlife Service and the VirgGame and Inland Fisheries, arequired by regulations, regarimpact to federally listed spec

92. Commonwealth 

of Virginia, Department of Conservation and Recreation 

There are several VDGIF's "Threatened and Endangered Species Waters" within the 2 miles radius of the representative rail and truck transportation routes. DCR recommends coordination with VDGIF to ensure compliance with protected species legislation. 

As discussed in the response transportation routing is one oestablished in DOE Manual 4were made through Virginia, resources and Threatened and Waters would be considered to the extent required by regupracticable. Furthermore, as dresponse to Comment # 43, Destablishes a standardized prointeracting with state, tribal, aand other federal agencies. Thcoordination with the U.S. Fiand the Virginia Department Fisheries, as appropriate and regarding the potential impacspecies. 
D-26 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

93. Commonwealth 

of Virginia, Department of Conservation and Recreation 

Any accident involving the release of hazardous materials such as uranium could contaminate karst aquifers along the route. These karst aquifers supply water for public drinking water supplies also provide water for domestic and agricultural uses all along the routes. 

As discussed in the response transportation routing is one oestablished in DOE Manual 4were made through Virginia, be considered in the routing prequired by regulations and a

94. Commonwealth 

of Virginia, Department of Conservation and Recreation 

In order to facilitate required emergency response as well as to better enable the mitigation work that would necessarily follow any accidents resulting in the release of hazardous materials into the environment, DCR strongly suggests that hydrologic investigations be performed along the course of the route where it passes through karst terrain or is upstream from karst terrain in order to determine 

the boundaries and extent of these karst groundwater basins. DCR also recommends investigations include dye tracer studies to determine the associated groundwater flow paths and the identification of sinkholes and other associated karst features including springs and wells that could be affected by any spill of hazardous material along these primary transportation corridors. 

As discussed in the response transportation routing is one o

established in DOE Manual 4were made through Virginia, be considered in the routing prequired by regulations and aof the low probability of an arelease of UF6 occurring in an 

topography, hydrologic invesconducted unless such an acc

95. Commonwealth 

of Virginia, Department of Conservation and Recreation 

DCR recommends implementation of safety measures and to notify localities of when and where the transportation of nuclear waste will occur. 

As discussed in the response shipment prenotification is onestablished in DOE Manual 4practices established in the mmeasures, such as routing, carequirements, and inspections

96. Commonwealth 

of Virginia, Department of Game and Inland Fisheries 

According to our records, there are a variety of listed species known from these regions. However, based on the information provided, new construction and/or impacts to wildlife resources under our jurisdiction are not proposed. Therefore, provided all nuclear material is safely contained and appropriately handled, and transport on existing transportation infrastructure can be accomplished in a safe manner and is not subject to transportation accident, direct attack, and/or other incident that would result in impacts to wildlife resources under our jurisdiction; then we do not anticipate the project would result in adverse impact to such 

resources. 

Your comment is noted. 
D-27 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

97. Commonwealth 

of Virginia, Department of Game and Inland Fisheries 

We recommend the applicant coordinate with the USFWS regarding potential impact to federally listed species. 

As discussed in the response Manual 460.2-1A establishes and framework for interacting local authorities, and other fewould include coordination thWildlife Service, as appropriaregulations, regarding the potfederally listed species. 

98. Commonwealth 

of Virginia, Department of Environmental Quality, Waste Division 

This is a multi-state project and the scope is extensive. For each area in Virginia where any work is to take place, the applicant 

needs to conduct an environmental investigation on and near the property to identify any solid or hazardous waste sites or issues 

before work can commence. This investigation should include a search of waste-related databases. 

As discussed in the response transportation routing is one o

established in DOE Manual 4were made through Virginia, hazardous waste sites or issuein the routing process, to the regulations and as practicable

99. Commonwealth 

of Virginia, Department of Environmental Quality, Waste Division 

Any soil that is suspected of contamination or wastes that are 

generated must be tested and disposed of in accordance with applicable Federal, State, and local laws and regulations. 

The EA assumes that any conthat resulted from a transporttested and disposed of, as appwith applicable federal, state, regulations. 

100. Commonwealth 

of Virginia, Department of Environmental Quality, Waste Division 

Structures to be demolished should be checked for asbestoscontaining materials (ACM) and lead-based paint (LBP) prior to demolition. If ACM or LBP are found, in addition to the federal waste-related regulations mentioned above. State regulations 9VAC 20-80-640 for ACM and 9VAC 20-60-261 for LBP must be followed. 

No structures would be demowith this Proposed Action. 

101. Commonwealth 

of Virginia, Department of Environmental Quality, Waste Division 

Please note that DEQ encourages all construction projects and facilities to implement pollution prevention principles, including the reduction, reuse, and recycling of all solid wastes generated. All generation of hazardous wastes should be minimized and handled appropriately. 

This project does not include employs pollution prevention minimization techniques at ea
D-28 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

102. Commonwealth 

of Virginia, Department of Environmental Quality, Waste Division 

The DEQ Waste Division recommends that for each area in Virginia where transportation of nuclear materials will occur, DOE should conduct an environmental investigation on and near the work area to identify any solid or hazardous waste sites or issues before the work commences. The investigation should include a search of waste related databases). 

As discussed in the response transportation routing is one oestablished in DOE Manual 4were made through Virginia, hazardous waste sites or issuein the routing process, to the regulations and as practicable

103. Commonwealth 

of Virginia, Division of Radiological Health 

The Department of Energy's (DOE) draft environmental assessment entitled "Disposition of DOE Excess Depleted Uranium, Natural Uranium, And Low-Enriched Uranium"' does not appear to create any significant radiological risk to the Commonwealth of Virginia. 

Your comment is noted. 

104. Commonwealth 

of Virginia, Division of Radiological Health 

I am supportive of a DOE conclusion for issuing a Finding of No Significant Impact. 

Your comment is noted. 

105. Commonwealth 

of Virginia, Department of Mines, Minerals and Energy 

Based on the scope of this activity, I do not anticipate an impact to mineral resources. 

Your comment is noted. 

106. Commonwealth 

of Virginia, Department of Mines, Minerals and Energy 

The geology of southwestern Virginia (and the Coastal Plain, if a shipment is made through Norfolk) is variable and could be a factor in limiting or increasing the scope of an impact from a rail or truck accident. The depth to bedrock, permeability of bedrock or sediment, orientation of bedding or fractures, presence of karst features, and topographic setting could all be factors. 

Your comment is noted. 

107. Commonwealth 

of Virginia, Hampton Roads Planning District Commission 

Based on this review [of the EA], the proposal is generally consistent with local and regional plans and policies. 

Your comment is noted. 
D-29 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

108. State of 

Louisiana, Department of Environmental Quality, Emergency & Radiological Services Division 

What is the current amount of uranium products and other radioactive material that annually pass through the Port of New Orleans? 

DOE does not have a databasinformation. This information from other agencies (Port of NGuard) but not provided. 

109. State of 

Louisiana, Department of Environmental Quality, Emergency & Radiological Services Division 

How will this proposal, DOE/EA-1607, to ship through New Orleans, increase the amount of uranium products passing through the Port of New Orleans? 

The Proposed Action describof uranium that could pass thOrleans under the Proposed ASection 4.2.1.3, Impacts from and footnote for the volume oof the United States and the pUnited States. 

110. Nuclear 

Regulatory Commission (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 Columbia Fuel Fabrication Facility, but the others do not use FFF at all. 

Document changed as sugges

111. NRC Section 3.1.4: Same for AREVA-Richland - they do not use the 

term FFF. 

Document changed as sugges

112. NRC Section 3.1.5: The correct company name is Global Nuclear Fuel - 

Americas (GNF-A). 

Document changed as sugges

113. NRC Section 3.1.5: Global Nuclear Fuels Americas (GNF-A) generates 

low level radioactive wastes, hazardous wastes, and mixed wastes (page 30). Consider a waste management paragraph similar to AREVA. 

Document changed as sugges

114. NRC Section 3.1.6: Throughout: a name that is used by Westinghouse is 

Columbia Fuel Fabrication Facility (CFFF). 

Document changed as sugges

115. NRC Section 3.1.6: Waste generation paragraph appears to be missing. Waste management paragrap
D-30 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

116. NRC For the Louisiana Energy Services (LES), GNF-A, and AREVA 

facilities cited, NRC understands from this document that the facility may receive a feedstock delivery from an alternate source and that an increase to the facilities production will not occur from these deliveries. However, when reading the EA this is not clearly stated. It reads "...if DOE contracts for the enrichment of DU, NU, or LEU to obtain LEU with up to 4.95 percent U235 content, DOE would contract to transport the LEU product to, and store it at, one or more of five domestic sites ... AREVA in Richland ... Global Nuclear Fuel ... 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." Does DOE project any changes to storage than previously assessed (licensed)? 

The Department does not proas a result of the Proposed Ac

117. NRC NRC is currently performing environmental assessments for the 40 

year license renewal of the AREVA Richland Washington and Global Nuclear Fuels-America facilities. DOE briefly mentions a portion of this action in their assessment. DOE’s references are 

dated. 

DOE has not been able to detreferences that NRC believes were made. 

118. NRC In the description of the NRC licensed facilities, the specifics are 

not consistently stated. For instance, at the AREVA Richland facility, a mention is made of the golf course, the schools and the hospital. However the report does not mention a large residential neighborhood associated with the golf course and several older, smaller neighborhoods nearby. 

Text has been added stating tareas near the golf course and 
D-31 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

119. NRC NRC recommends revising the description of the impact for the 

AREVA Richland facility. In NRC's draft EA for the AREVA facility, NRC discusses the small to moderate impacts from transportation that may occur by 2025. City and State officials have projected significant transportation problems by the year 2025 if further transportation capacity is not achieved (i.e., construction of a bridge, access changes to major roads, etc.). Based on the City's proactive stance, they have added turn lanes and lighting to ease near term capacity problems in the vicinity of the site, yet these changes are insufficient to address long-term transportation capacity in the area of potential effect. 

NRC’s final EA for license reFuel Fabrication Facility at R(NRC 2009) indicated that thimpacts are small and the lonimpacts are small to moderatethat traffic from the regions l(Hanford Site) will significan30 years. Also, the City of Rprepares a Six-Year TransporProgram that is used as a planpriorities to improve city streof the interstate highway. Stacity adopt this planning tool pyear. Thus, it is anticipated thimprovements would occur. SRichland, Washington, websihttp://www.ci.richland.wa.us/

ndex.cfm?pagenum=72. 

120. NRC NRC is currently evaluating two construction licensing applications 

for uranium enrichment: GE Hitachi's Global Laser Enrichment (Wilmington NC - on the same grounds as GNF-A) and AREVA Eagle Rock Enrichment Facility (Idaho Falls, Idaho). The potential exists that both of these facilities may come on-line within the 25 years proposed by DOE's EA. 

These two facilities are in the development and are now addOther Enrichment Facilities. AREVA Eagle Rock Enrichmsimilar to LES. GE Hitachi’s Enrichment is in the conceptuinsufficient information is cudetermine the potential envirocould be associated with this 
D-32 

Comment 

Number 

Reviewer Name/ 

Company Comment Respon

121. Ux Consulting The draft EA states that France is the only nation with the 

regulations in place to enrich DOE's uranium. The EA also says that Japan lacks the regulatory agreements. 

This text now beginning on libeen changed to read, “This Eassociated with transportation representative of potential imenrichment at any foreign facwould vary in proportion to thfacility in another country wathe French facility in Tricastienrichment facilities are operEuropean countries, as well athis time, the United States ha(Section 123 of the Atomic EPeaceful Nuclear Cooperation countries such as Japan, and wpart of the European Atomic (Euratom), including France foreign enrichment facilities cthe future if the necessary agrimplemented.” 
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Title: Uranium EA 12-11 

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Creation Date: 6/25/2009 9:41:00 AM 

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