DOE/EA-1393

FINAL

Programmatic Environmental Assessment 

for the 

U.S. Department of Energy, Oak Ridge Operations 

Implementation of a Comprehensive Management Program 

for the Storage, Transportation, and Disposition of 

Potentially Reusable Uranium Materials 
FINDING OF NO SIGNIFICANT IMPMZT

PROGR4MMATIC ENVIRONMENTAL ASSESSME?X

FOR THE

U.S. DEPARTMENT OF ENERGY, OAK RIDGE OPER4TIOSS

IMPLEMENTATION OF A COMPREHENSIVE MANAGEMEKT PROGK4hl

FOR THE STORAGE, TRANSPORTATION, AND DISPOSITION OF

POTENTIALLY REUSABLE URANJUh4 MATERIALS

AGEhCY: U.S. DEPARTMENT OF ENERGY (DOE)

ACTION: FINDI?iG OF NO SIGNIFICANT 1~IPAC-I

SUMI\!L4RY: The U. S. DOE has completed a Programmatic Environmental Assessment (PE:,4)

(DOE/E?,- 1393), which is incorporated herein by this reference. Tile purpose of the

PEA is in assess potential enJ?ronmental impacts of the implementation of a

comprehek-e management program for potentiaIly reusable ICW enriched uranium

(LEU). norr,:al uranium (NU), and depleted uranium (DU). --l?prosimately 14,200

MTU (h?etric Tons of Uranium) of potentially reusable uranium is located at 15s

sites. DOE has evaluated various optioils for interim centralized storage and interim

consolidated storage at six DOE locations and two commercial sites. Ultimate

disposition !IZS also been evaluated. to the extent practicab!el as part of this

managem 31 program. Based on the results of the impacts analysis reported in the

PEA, DOE has determined that the proposed action is not a major Federal action that

would significantly affect the quaky of the human environment within the context

of the National Environmental Policy Act of 1969 @EPA). Therefore, preparation

of an Environmental Impact Statement (EIS) is not necessary, and DOE is issuing

this Finding of No Significant Impact (FONSI).

PUBLIC AVAILABILITY OF PEA Ah?) FONST: The PEA and FONSI may be reviewed at, and

copies of the document obtained from:

DOE Information Center

475 Oak Ridge Turnpike

Ozz~kRirlu~ --- ----E’, T~nnas~eg * “*I&A” 37830

Phone: (865) 24 l-4780

U.S. Department of Energy

Carolyne Thomas, Senior Project Manager

Uranium h4anagement Division

Post Office Box 2001

Oak Ridge, Tennessee 3783 1

Phone: (865) 576-2690

DOE Paducah Environmental Information Center

115 Memorial Drive

Paducah, Kentucky 42201

Phone: (270) 554-6979

02-169(doc)/082102 1

DOE Savannah River Operations Office

Pub1 ic Reading Room

17 1 University Parkway

Aiken, South Carolina 2980 1

Phone: (803) 725-2497

DOE Idaho Operations Office

Public Reading Room

INEEL Technical Library

1776 Science Center Drive

Idaho Falls, Idaho 83415

Phone: (208) 526-l 244

DOE Portsmouth Environmental Information Cente:

3930 U.S. Koute 23 South, Perimeter Road

Piketon, Ohio 45661

Phone: (740) 289-33 17

DOE Headquarters F01A/Pt1bIic Reading Room

Room lE-190

1000 Independence Avenue. S15;

\Vashington, DC 205 S5

Phone: (302) 5S6-5955

FURTHER INFOFWIATION ON THE NEPA PROCESS: For fur-thftr information on the NEPA

process, contact:

David R. Allen

NEPA Compliance Officer

U.S. Department of Energy

Post Office Box 200 1

Oak Ridge, Tennessee 3783 1

Phone: (S65) 576-04 11

BACKGROUND: The U.S. Department of Energy (DOE) proposes to implement a comprehensive

management program to safely, efficiently, and effectively manage its potentially reusable low enriched

uranium (LEU), normal uranium (NU), and depleted uranium (DT3>. ?JiZiiiiiiZ niateriais, which are

presently located at multiple sites, would be consolidated by transporting the materials to one or several

storage locations, to facilitate ultimate disposition. Management would include the storage, transport, and

ultimate disposition of these materials.

This action is needed because of DOE’s current missions and functions; increasing budget pressures; the

continuing need for good stewardship of resources, including materials in inventory; and continuing DOE

attention to considerations of environment, safety, and health. Also, increased pressure on the federal

budget requires that DOE take a closer look at materials management in order to ensure maximum cost

effectiveness. This includes an examination of feasible uses of this material, consistent with DOE’S

mission, as well as an examination of management methods that are consistent with environmental

requirements and budgetary constraints. DOE needs to implement a long-term (greater than 20 years)

management plan for its inventory of potentially reusabIe LEU, NU, and DU.

02-l 69(doc)/062 102 2

DOE prepared a PEA to address the proposed action. The comprehensible management program addressed

in this PEA looks at transportation, including preparation of uranium materials for safe shipment. lon_eterm storage, maintenance and disposition. The PEA addresses 14,200 metric tons of uranium (!L~TL‘)

materials thought to be potentially reusable; thus, uranium wastes are not part of the scope. Reusable is

defined as “uranium material having an economically viable disposition path.” The management plan

covers uranium materials that are currently in the form of oxides, metals, and other stable compounds,

and which are located at various sites around the United States. The plan does not include irradiated

material, material in the form of uranium hexafluoride (UT& uranium that is enriched to 20% or greater

in 235U, or uranium enriched in 233U.

Storage would occur until future sale or reuse alternatives are ready for decision-making. DOE evaluated

in the PEA several proposed alternative DOE storage sites: the Portsmouth Gaseous Diffusion Plant

(PORTS) in Ohio; the Paducah Gaseous Diffusion Plant (PGDP) in Kentucky; the Y-12 National Securinr

Complex (Y-12) and East Tennessee Technology Park (ETTP) in Tennessee; the Savannah Ri\Jer Site

(SRS) in South Carolina; and the Idaho National Engineering and Environmental Laboratory (INEEL‘, in

Idaho. Also considered were western and eastern commercial sites. Approximately 14:200 MTU \+,ould be

stored in either one (centralized) location or several (consolidated) locations based on the pr~.in:it~~ of

sites or the uranium product form. DOE now has potentially reusable uranium materials in 15 II locations

in the United States; however, the vast majority of these materials are located at only a fex;s. sires. Ti~es~

sites have additional uranium materials, which are not part of the Liranium Mana~eme;lt Grc?:;;: I T VT, :C; 1

inventory and not addressed by the proposed action.

DOE proposes to implement a ion,O-term (greater than 20 years) management plan for its i!:\ enti\r\’ 57

potentially reusable LEU, NU, and DU. Uranium materials, which are presently located at multiple sii-cs.

are proposed to be consolidated by transporting the materials to one or several storage locations. to

facilitate ultimate disposition. The management plan would address the packaging and transport of

potentially reusable uranium materials from DOE sites and university loan/lease returns and their receipt

and storage at a site under cognizance of the UMG. This action will also cover material shipment from the

UMG and disposition. A Secretarial Determination is required, under certain circumstances, for uranium

in the UMG inventory to be sold. Twenty years would provide time for additional reviews required for

any future related actions that may be desirable to help accomplish ultimate disposition.

Since disposition of this material is currently undefined, a “bounding” analysis was perfomled to estimate

the potential impacts from commercial processing of this materia1, use of this material in research

activities, provision of this material to other Government agencies, and/or the sale

(international/domestic) of this material upon completion of a Secreterial Determination. Disposition is a

component of each of the action alternatives and impacts wou!d differ based only on differences in

transportation. Some wastes would be produced during this disposition process.

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

alternative. The no action alternative would continue ongoing storage activities at all existing facilities.

This alternative includes the continued storage of uranium materials in existing facilities (DOE and

private). Monitoring and surveillance of the uranium materials at each site would continue, as \J.ouId tlx

handling necessary to continue proper management of these materials, including repackaging if needed.

The uranium inventory would not be dispositioned.

Alternatives analyzed under the proposed action included: Interim Centralized Storage at a Single DOE

Site; Interim Centralized Storage at a Single Commercial Site; Partially Consolidated Storage at Several

DOE Sites; Partially Consolidated Storage at One Western and One Eastern DOE Site; Partial]>

Consolidated Storage at One Western and One Eastern Commercial Site; and Partial]>, Consolidated

Storage by Physical Form.

02- 169(doc)/082102 3

DOE must be able to transfer small quantities (less than 0.1 MTU) from any one of the potential

consolidated or centralized storage sites to a second location (such as a university). This option usas

considered as a component of each alternative under the proposed action. It was not itself a stand-alone

alternative.

ENVIRONMENTAL IMPACTS:

NO ACTION

Under this alternative, the uranium currently stored at the various DOE sites, non-DOE sites, universities,

and other commercial locations would remain at those sites. The uranium is currently in various container

types, including 55gallon steel drums, T-hoppers, half-high boxes, and sea-land containers.

Normal Operations. Under normal operations, iand use, geolo,g and soils, water resources, cultural

resources, and the infrastructure remain unchanged. Air effluents associated with uranium inventor)

maintenance would be minimal and would remain the same as they are now. Because here is 110 neu

construction and there are no effluents from the stored uranium, plant and animal species would not be

adversely affected and cultural resources would not be impacted. Some continued maintenance of

facilities would be required, and monitoring and surveillance at the current sites would continue. The

socioeconomic impact analysis assumes little or no construction activity and continued uranium

monitoring by current employees. Under these assumptions, there is no change in expenditure or

employment and, consequently, no impact. Even if additional workers were hired for monitoring at each

potential centralized or consolidated storage site, they would represent a minimal increase to the large

number (several hundred thousand) of wage and salary earners present in counties that contain the larger

DOE uranium storage sites. In the absence of important impacts, environmental justice concerns do not

arise.

The 3,900 MTU at the 152 locations other than the six DOE locations would remain at these sites. The

amount at each individual site is very small and -is typically associated with university or other types of

research. No substantial environmental impacts are expected from the continued use and/or storage at

these locations; however, these sites do not have a long-term mission for uranium storage and expect to

ship materials back to DOE when the research work is completed.

FaciIity Accidents. The highest acute consequences to the public or to a co-located worker are due to a

fire or earthquake at PORTS, with aerial dispersion of uranium materia!s, t3’1t are still neg$gib;e. This

result is based on the large amount of uranium materials currently stored at PORTS (4,400 MTU or -3 1%

of the total of 14,200 MTU). Acute radiological and toxicological consequences are negligible at a11 sites.

Accidents at all facilities are expected to cause negligible to low chronic risks to humans and ecological

receptors.

Transportation. There are no transportation activities associated with theno action alternative.

PROPOSED ACTION

Normal operations result in no more than negligible acute or chronic consequences and risk at any site under

any storage alternative or disposition option. Environmental impacts associated with normal operations vary

from alternative to alternative and, occasionally, by site within a given alternative. General handling

accidents result in no more than negligible acute or chronic consequences and risk at any site under any

02-l 69(doc)/082102 4

storage altemarive or disposition option. Chronic human health and ecological consequences and risk are

negligible to Iow for all sites under all alternatives. The highest transportation consequences and risk are for

alternatives that involve moving uranium materials to a western location, either to a commercial site or to

INEEL.

Comparison of Alternatives

When comparing the environmental impacts of the various alternatives, the following emerge as general

trends:

l There were none-to-minor impacts for all of the alternatives considered and negligible-to-low

impacts from the standpoint of facility accidents (fire and seismic) for all the alternatives, while

transportation effects for the alternatives generally reflected the extent of material transport

associated with the alternative being analyzed.

l The greater the centralization or consolidation of the uranium inventory, the greater the potential for

normal operations impacts. Greater centralization or consolidation means that ncu’ storage space has

to be built: which means accompanyin,(J costs and commitment of land, and uranium materials wili

have to be shipped greater distances with increased risk of accidents.

0 The action alternztive with the fewest environmental impacts and that is the least expensive ($7.3M)

is “Interim Partially Consolidated Storage at Several DOE Sites. ” This alternative takes advantage of

the current storage of the majority of these DOE sites already. Thus, construction costs and

associated environmental impacts would be less than other action aIternatives.

a Similarly, the PORTS site would have the fewest environmental impacts and would be the least

expensive ($8.4M) of the DOE facilities considered for interim centraIized storage. It should be

noted that DOE would be committed to using the existing UMG facility at PORTS; therefore other

buildings would not be upgraded and the upgrade costs computed in the PEA for other buildings

would not be spent. Only very minor upgrades to the existing storage facility would be needed.

PDGP and commercial sites would be the most expensive centralized storage.

0 Excess Latent Cancer Fatalities (LCF!) due to transportation and traffic fatalities are minimal for all

alternatives but greatest for the interim storage at the single site alternatives. The increase in excess

LCFs to the public from radiological exposures during transportation is less than one for all

alternatives.

a Western sites would tend to have slightly higher trafic fatalities associated with them than eastern

ones due to the larger volumes of uranium materials to be shipped over greater distances.

0 Commercial sites would have slightly greater impacts than DOE sites (except for PGDP) when

comparing similar alternatives (interim centralized storage at a single DOE site versus a single

commercial site and interim partially consolidated storage at two DOE sites versus two commercial

sites).

Interim Centralized Storage at a Single Commercial Site Alternative. Considering the combination of

normal operations, facility accidents and transportation, the “Interim Centralized Storage at a Single

Commercial Site” alternative and the PGDP site for “Interim Consolidated Storage at a Single DOE Site”

alternative have the greatest potential for environmental impacts. For normal operations, the western and

eastern commercial sites and PGDP have equal impact potential. Any of these sites would have 305

first-year construction workers, 14 new permanent workers, $12.2M in new construction costs, and seven

02-169(doc)/082102 5

acres of land commitment and habitat disturbance. Facility accidents \Jfould resuit in negligible to low acute

and chronic risks.

Interim Centralized Storage at a Single DOE Site. Impacts are very similar to the single commercial

site alternative discussed above; however, there are some differences in impacts among the DOE sites.

Because PORTS has sufrpicient existing storage space, normal operations impacts, including

socioeconomics, would be minimal at this site. Upgrading existing buildings at PORTS would not result

in commitments of land or destruction of wildlife habitat that would be necessary at all other DOE sites.

Due to the very small amount of uranium storage space at PGDP, the impacts of normal operations would

be almost identical to interim centralized storage at a single commercial site as noted above.

Interim Partially Consolidated Storage at Two Commercial Sites. Because none of the 14,200 MTU

uranium inventory is now at these commercial sites, the normal operations impacrs ascnriated with this

Jtclnativt: are very similar to those for the “Interim Centralized Storage at a Single Commercial Site”

alternative, except that environmental impacts would be shared by the two sites.

Interim PartiaIly Consolidated Storage at Two DOE Sites. Environmental impacts from normal

operations would tend to be less than from consolidation at two commercial sites. because some of the

uranium inventory is already at INEEL and PORTS. Thus, less construction-related inlpacts would

result. Human health and ecological risks from facility accidents \tTould bf: the same as for

ConsoIidation at two commercial sites.

Interim Partially Consolidated Storage at SeveraI DOE Sites. Because most of the uranium

inventory would remain at the six prime DOE locations and only the 3,900 hll3-J at 152 other sites

would be relocated, the normal operations impacts would be substantially less than all the other action

alternatives. Additional space requirements, and the impacts associated with construction of this space,

would be sharply reduced when compared to the other action alternatives. This alternative most closely

resembles the No Action alternative.

CUMULATMZ IMPACTS

Cumulative impacts are impacts associated with the proposed action when combined with other past,

present, or reasonably foreseeable future impacts. There are no significant impacts associated with the

proposed action under normal operations. When the negligible-to-minor environmental and

socioeconomic impacts associated with normal operations (construction of new storage facilities, facilities

upgrades, and daily maintenance and surveillance) and any nf t!~ action 2!temxivcs aie added to tie

baseline environment, cumulative impacts are minor.

For facility accidents, the potential for negligible to low acute consequences and risk, due to either storage

area fires or seismic events, exists for the “Interim Centralized Storage at a Single DOE Site” alternative

and “Interim Centralized Storage at a Single Commercial Site.” Under a major seismic event scenario

sufficient to mobilize uranium oxide into the environment, it is reasonable to assume that other material

releases and other risks would be posed to workers at the site. Therefore, risks from uranium oxides

would be one of several environmental and health risks that workers at the sites would face. For other

accidents and other forms of uranium materials, the acute and chronic human health risk and ecological

risk are negligible or low.

Due to a small increase in vehicular traffic to transport uranium materials, there would be a slight increase

in traffic accidents and fatalities on the nation’s highways. These cumulative impacts would be very

02-I 69(doc)/082 102 6

minor in comparison to the baseline. Likewise, exposures of the public and ;I\ <I Ti:erS dLlril1,~ Llraj]jTL;~

transport would increase very slightly the risks of LCFs.

At some time in the future, the uranium inventory would be eventually disposirioneii. I’arious disposition

options including commercial processing and domestic sales of the entire inventq. disposition of limited

quantities (50 MTU) at research facilities, disposition of 2,500 MTU to other go\‘ermxent agencies, and

foreign sales of 4,050 MTU may occur. Impacts’associated with these options are considered as a part of

each of the interim storage alternatives. In addition, potential cumulative impacts (such as temporq

storage costs, new construction, and additional labor) could occur should an exisring ixventory of uranium

materials be increased at any of these disposition option locations.

SRS. There is a large inventory (-19,000 MTU) of uranium, mostiy oxides, at the SRS, M*hich is not psrr

of the UMG inventory. For an accident risk perspective, cumulative impacts could ‘0s important at SRS

(due principally to this existin,,0 non-UMG uranium oxide inventory). Cen~raiized storage would aciti

I 1,300 MTU to the 2,400 MTU already included in the Uh4G inventory.

In addition, up to seven acres of site habitat at SRS ;isould be devoted 10 IX-L; ;~~:-._;:rLl~~iGn. 1k31110\~iJ~~

these acres from current use. This acreage, when considered from a total sile yerqxcti\.e. lx.ould be 2

minimal cumulative impact since portions of SRS are undergoing remediatiq?:: :‘: +einrz dedicated ::,

greater environmental uses.

PDGP. The PDGP site would need the largest amotin’: of new construction !:i:l:Z!;!g sel'en acres cf

permanent habitat disruption. This disruption would occur at a site und~r~~~i:?~ sround-disturbi:!,

remediation efforts, which also affect wildlife habitat: albeit of low quality in K~X zcses. Because of 111~

small workforce at PDGP, direct construction-related increases in employmen? \l:~b:::i be greatest at this

site. Due to declining DOE employment at the site, howe\rer, the overall curnulzi\ e :xlpact \?Jould like]!.

be temporary but beneficial for the regional economy.

PORTS. The PORTS site has an existing inventory of uranium materials. Should the approximateI>

9,800 MTU of additional inventory evaluated in this EA be added to the existins inventory, then the

potential for cumulative impacts due to accidental releases would increase. Since PORTS currently has

sufficient existing storage space for the 14,200 MTU, the site has the lowest potential for cumulative

impacts due to construction/renovation. However, as noted, DOE would be committed to using the

existing UMG storage facility and upgrades to other building for uranium storage for this program would

not occur.

INEEL. Like the PDGP site, INEEL would require substantia! ~WJ CCX~~:C~C~ *ccit!i associated

permanent habitat disruption. This seven acre commitment would occur at a hi$:ly developed site

undergoing other ground disturbances associated with remediation. This site also 1~s uranium inventor!

that is not part of the proposed action so cumulative impacts from accidental releases ET= possible.

Y-12 and ETTP. The two sites at Oak Ridge would also require a Colnmilmei;: of land for neA

construction. Even though there are also other uranium inventories in Oak Ridse. 111s ?Il\rsicaI separation

of the two sites lessens the potential for cumulative impacts due to accidental rele=ise_;.

DETERMINATION: Based on the findings in this PEA, DOE has determineci that none of the

alternatives under the proposed action to implement a long-term (greater than 20 years‘) management plan

for its inventory of potentially reusable LEU, NU, and DU have potentialI>* significant adverse

environmental impacts; thus the proposed action does not constitute a major federal action that would

significantly affect the quality of the human environment within the contexT of the National

Environmental Policy Act. Therefore, preparation of an environmental impact statement is not required.

02-l 69(doc)/082 102 7

U.S. Department of Energ

Oak Ridge Operations

Oak Ridge, Tennessee

02-l 69(doc)/082102

S

01-217(doc)/093002 iii

TABLE OF CONTENTS

LIST OF FIGURES ....................................................................................................................................vii

LIST OF TABLES......................................................................................................................................vii

ACRONYMS............................................................................................................................................... ix

1. INTRODUCTION..............................................................................................................................1-1

1.1 PURPOSE AND NEED FOR AGENCY ACTION ................................................................1-1

1.2 SCOPE OF THIS ENVIRONMENTAL ASSESSMENT .......................................................1-1

2. DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES..............................................2-1

2.1 BACKGROUND .....................................................................................................................2-1

2.2 NO ACTION ALTERNATIVE ...............................................................................................2-9

2.3 PROPOSED ACTION .............................................................................................................2-9

2.3.1 Interim Centralized Storage at a Single DOE Site......................................................2-10

2.3.2 Interim Centralized Storage at a Single Commercial Site ..........................................2-10

2.3.3 Interim Partially Consolidated Storage at Several DOE Sites....................................2-10

2.3.4 Interim Partially Consolidated Storage at One Western and One Eastern DOE 

Site .............................................................................................................................2-10

2.3.5 Interim Partially Consolidated Storage at One Western and One Eastern 

Commercial Site.........................................................................................................2-11

2.3.6 Interim Partially Consolidated Storage by Physical Form .........................................2-11

2.3.7 Transfer of Small Quantities.......................................................................................2-11

2.3.8 Disposition Options....................................................................................................2-11

2.4 ALTERNATIVES CONSIDERED BUT NOT PROPOSED FOR ANALYSIS ..................2-12

3. AFFECTED ENVIRONMENT .........................................................................................................3-1

3.1 PORTSMOUTH GASEOUS DIFFUSION PLANT ...............................................................3-1

3.1.1 Human Health...............................................................................................................3-1

3.1.2 Climate and Air Quality ...............................................................................................3-1

3.1.3 Water Resources...........................................................................................................3-1

3.1.4 Geology and Soils ........................................................................................................3-1

3.1.5 Ecological Resources....................................................................................................3-2

3.1.6 Socioeconomics and Environmental Justice.................................................................3-2

3.1.7 Land Use.......................................................................................................................3-2

3.1.8 Infrastructure ................................................................................................................3-2

3.1.9 Cultural Resources........................................................................................................3-3

3.2 PADUCAH GASEOUS DIFFUSION PLANT .......................................................................3-3

3.2.1 Human Health...............................................................................................................3-3

3.2.2 Climate and Air Quality ...............................................................................................3-3

3.2.3 Water Resources...........................................................................................................3-3

3.2.4 Geology and Soils ........................................................................................................3-4

3.2.5 Ecological Resources....................................................................................................3-4

3.2.6 Socioeconomics and Environmental Justice.................................................................3-4

3.2.7 Land Use.......................................................................................................................3-4

3.2.8 Infrastructure ................................................................................................................3-5

3.2.9 Cultural Resources........................................................................................................3-5

3.3 Y-12 National security complex ..............................................................................................3-5

3.3.1 Human Health...............................................................................................................3-5
01-217(doc)/093002 iv

3.3.2 Climate and Air Quality ...............................................................................................3-5

3.3.3 Water Resources...........................................................................................................3-6

3.3.4 Geology and Soils ........................................................................................................3-6

3.3.5 Ecological Resources....................................................................................................3-6

3.3.6 Socioeconomics and Environmental Justice.................................................................3-7

3.3.7 Land Use.......................................................................................................................3-7

3.3.8 Infrastructure ................................................................................................................3-7

3.3.9 Cultural Resources........................................................................................................3-8

3.4 EAST TENNESSEE TECHNOLOGY PARK ........................................................................3-8

3.4.1 Human Health...............................................................................................................3-8

3.4.2 Climate and Air Quality ...............................................................................................3-8

3.4.3 Water Resources...........................................................................................................3-9

3.4.4 Geology and Soils ........................................................................................................3-9

3.4.5 Ecological Resources....................................................................................................3-9

3.4.6 Socioeconomics and Environmental Justice...............................................................3-10

3.4.7 Land Use.....................................................................................................................3-10

3.4.8 Infrastructure ..............................................................................................................3-10

3.4.9 Cultural Resources......................................................................................................3-10

3.5 SAVANNAH RIVER SITE...................................................................................................3-10

3.5.1 Human Health.............................................................................................................3-11

3.5.2 Climate and Air Quality .............................................................................................3-11

3.5.3 Water Resources.........................................................................................................3-11

3.5.4 Geology and Soils ......................................................................................................3-12

3.5.5 Ecological Resources..................................................................................................3-12

3.5.6 Socioeconomics and Environmental Justice...............................................................3-12

3.5.7 Land Use.....................................................................................................................3-13

3.5.8 Infrastructure ..............................................................................................................3-13

3.5.9 Cultural Resources......................................................................................................3-13

3.6 IDAHO NATIONAL ENGINEERING AND ENVIRONMENTAL LABORATORY........3-14

3.6.1 Human Health.............................................................................................................3-14

3.6.2 Climate and Air Quality .............................................................................................3-14

3.6.3 Water Resources.........................................................................................................3-14

3.6.4 Geology and Soils ......................................................................................................3-15

3.6.5 Ecological Resources..................................................................................................3-15

3.6.6 Socioeconomics and Environmental Justice...............................................................3-15

3.6.7 Land Use.....................................................................................................................3-16

3.6.8 Infrastructure ..............................................................................................................3-16

3.6.9 Cultural Resources......................................................................................................3-16

4. ENVIRONMENTAL CONSEQUENCES.........................................................................................4-1

4.1 METHODS ..............................................................................................................................4-1

4.2 CONSEQUENCES COMMON TO ALL ALTERNATIVES.................................................4-3

4.3 NO ACTION ALTERNATIVE ...............................................................................................4-4

4.3.1 Normal Operations .......................................................................................................4-4

4.3.2 Facility Accidents.........................................................................................................4-4

4.3.3 Transportation ..............................................................................................................4-4

4.4 INTERIM CENTRALIZED STORAGE AT A SINGLE DOE SITE .....................................4-4

4.4.1 Normal Operations .......................................................................................................4-5

4.4.2 Facility Accidents.........................................................................................................4-7

4.4.3 Transportation ..............................................................................................................4-7

4.5 INTERIM CENTRALIZED STORAGE AT A SINGLE COMMERCIAL SITE ..................4-8
01-217(doc)/093002 v

4.5.1 Normal Operations .......................................................................................................4-8

4.5.2 Facility Accidents.........................................................................................................4-8

4.5.3 Transportation ..............................................................................................................4-8

4.6 INTERIM PARTIALLY CONSOLIDATED STORAGE AT SEVERAL DOE SITES.........4-9

4.6.1 Normal Operations .......................................................................................................4-9

4.6.2 Facility Accidents.......................................................................................................4-10

4.6.3 Transportation ............................................................................................................4-11

4.7 INTERIM PARTIALLY CONSOLIDATED STORAGE AT TWO DOE SITES ...............4-11

4.7.1 Normal Operations .....................................................................................................4-11

4.7.2 Facility Accidents.......................................................................................................4-12

4.7.3 Transportation ............................................................................................................4-13

4.8 INTERIM PARTIALLY CONSOLIDATED STORAGE AT TWO COMMERCIAL 

SITES.....................................................................................................................................4-13

4.8.1 Normal Operations .....................................................................................................4-13

4.8.2 Facility Accidents.......................................................................................................4-14

4.8.3 Transportation ............................................................................................................4-14

4.9 INTERIM PARTIALLY CONSOLIDATED STORAGE BASED ON PHYSICAL 

FORM ....................................................................................................................................4-14

4.9.1 Normal Operations .....................................................................................................4-15

4.9.2 Facility Accidents.......................................................................................................4-16

4.9.3 Transportation ............................................................................................................4-16

4.10 DISPOSITION.......................................................................................................................4-17

4.10.1 Commercial Processing and Domestic Sales..............................................................4-17

4.10.2 Transfer to Research Facility......................................................................................4-18

4.10.3 Transfer to Other Government Agency ......................................................................4-18

4.10.4 Foreign Sales ..............................................................................................................4-18

4.11 SUMMARY AND CONCLUSIONS ....................................................................................4-19

4.11.1 Comparison of Alternatives........................................................................................4-19

4.12 CUMULATIVE IMPACTS...................................................................................................4-21

4.12.1 SRS.............................................................................................................................4-21

4.12.2 PGDP..........................................................................................................................4-21

4.12.3 PORTS........................................................................................................................4-22

4.12.4 INEEL ........................................................................................................................4-22

4.12.5 Oak Ridge...................................................................................................................4-22

5. REFERENCES...................................................................................................................................5-1

6. LIST OF PREPARERS......................................................................................................................6-1

7. LIST OF AGENCIES/INDIVIDUALS CONSULTED.....................................................................7-1

APPENDIX A. HAZARD AND ACCIDENT ANALYSIS FOR URANIUM MANAGEMENT 

PROGRAMMATIC ENVIRONMENTAL ASSESSMENT ............................................................A-1 

APPENDIX B. TRANSPORTATION ANALYSIS FOR URANIUM MANAGEMENT 

PROGRAMMATIC ENVIRONMENTAL ASSESSMENT ............................................................ B-1 

APPENDIX C. ANALYSIS OF CHRONIC RISK TO HUMANS AND ECOLOGICAL RECEPTORS 

FROM URANIUM DEPOSITED ON SOIL AND SURFACE WATER FOR URANIUM 

MANAGEMENT PROGRAMMATIC ENVIRONMENTAL ASSESSMENT .............................. C-1 
01-217(doc)/093002 vi

APPENDIX D. COMMENTS AND RESPONSE TO COMMENTS......................................................D-1 
01-217(doc)/093002 vii

LIST OF FIGURES

2.1 Example of the 55-gallon drums and metal storage containers used at PORTS. .............................2-8

LIST OF TABLES

2.1 Uranium management inventory......................................................................................................2-2

2.2 Uranium management PEA interim storage alternatives .................................................................2-4

2.3 Packaging assumptions for uranium management PEA...................................................................2-6

2.4 Container assumptions for uranium management PEA....................................................................2-6

2.5 Transportation assumptions for uranium management PEA............................................................2-6

2.6 Uranium management PEA interim storage requirements...............................................................2-7

2.7 Uranium management PEA disposition options ..............................................................................2-7

3.1 Population, income, and employment in the PORTS region of influence for Pike County 

and Scioto County............................................................................................................................3-2

3.2 Population and income in the Y-12 National Security Complex Region of Influence 

for Roane and Anderson Counties for 1999.....................................................................................3-7

3.3 Population and income in the Savannah River site region of influence for 1999 ..........................3-13

3.4 Population and income in the INEEL site region of influence for 1999........................................3-15

4.1 Risks due to accidents for No Action alternative.............................................................................4-5

4.2 Storage requirements for interim centralized storage at a single DOE site......................................4-5

4.3 Impacts for interim centralized storage at a single DOE site ...........................................................4-6

4.4 Risks due to accidents for interim centralized storage at a single DOE site ....................................4-7

4.5 Transportation effects for interim centralized storage at a single DOE site.....................................4-7

4.6 Impacts for interim centralized storage at a single commercial site.................................................4-8

4.7 Transportation effects for interim centralized storage at a commercial site.....................................4-9

4.8 Storage requirements for interim partially consolidated storage at several DOE sites ....................4-9

4.9 Impacts for interim partially consolidated storage at several DOE sites........................................4-10

4.10 Risks due to accidents for interim partially consolidated storage at several DOE sites.................4-11

4.11 Transportation effects for interim partially consolidated storage at several DOE sites .................4-11

4.12 Storage requirements for interim partially consolidated storage at two DOE sites........................4-12

4.13 Impacts for interim partially consolidated storage at two DOE sites.............................................4-12

4.14 Risks due to accidents for interim partially consolidated storage at two DOE sites......................4-13

4.15 Transportation effects for interim partially consolidated storage at two DOE sites ......................4-13

4.16 Impacts for interim partially consolidated storage at two commercial sites ..................................4-14

4.17 Transportation effects for interim partially consolidated storage at two commercial sites............4-14

4.18 Storage requirements for interim partially consolidated storage based on physical form..............4-15

4.19 Impacts for interim partially consolidated storage based on physical form...................................4-16

4.20 Risks due to accidents for interim partially consolidated storage based on physical form............4-16

4.21 Transportation effects for interim partially consolidated storage based on physical form ............4-17
01-217(doc)/093002 viii
01-217(doc)/093002 ix

ACRONYMS

DCG derived concentration guideline 

DOE U.S. Department of Energy 

DU depleted uranium 

EA environmental assessment 

EDE effective dose equivalent 

EPA U.S. Environmental Protection Agency 

ETTP East Tennessee Technology Park 

FEMP Fernald Environmental Management Project 

FR Federal Register 

FY fiscal year 

gpd gallons per day 

HEU highly enriched uranium 

ICPP Idaho Chemical Processing Plant 

INEEL Idaho National Engineering and Environmental Laboratory 

LCF latent cancer fatalities 

LEU low enriched uranium 

MTU metric tons of uranium 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act of 1969 

NERP National Environmental Research Park 

NMIA Nuclear Material Inventory Assessment 

NNSA National Nuclear Security Administration 

NOAA National Oceanic and Atmospheric Administration 

NRHP National Register of Historic Places 

NU normal uranium 

ORNL Oak Ridge National Laboratory 

ORR Oak Ridge Reservation 

PEA programmatic environmental assessment 

PEIS programmatic environmental impact statement 

PGDP Paducah Gaseous Diffusion Plant 

PORTS Portsmouth Gaseous Diffusion Plant 

PSD prevention of significant deterioration 

ROI region of influence 

SRS Savannah River Site 

TVA Tennessee Valley Authority 

UBC Uniform Building Code 

UMG Uranium Management Group 

USEC United States Enrichment Corporation 

U3O8 oxide ore 

UF4 uranium tetrafluoride 

UF6 uranium hexafluoride 

UO3 uranium trioxide 
01-217(doc)/093002 x
01-217(doc)/093002 1-1

1. INTRODUCTION

1.1 PURPOSE AND NEED FOR AGENCY ACTION 

 The U.S. Department of Energy (DOE) proposes to implement a comprehensive management program to 

safely, efficiently, and effectively manage its potentially reusable low enriched uranium (LEU), normal 

uranium (NU), and depleted uranium (DU). Uranium materials, which are presently located at multiple sites, 

are to be consolidated by transporting the materials to one or several storage locations, to facilitate ultimate 

disposition. Management would include the storage, transport, and ultimate disposition of these materials. 

 This action is needed because of DOE’s current missions and functions; increasing budget pressures; the 

continuing need for good stewardship of resources, including materials in inventory; and continuing DOE 

attention to considerations of environment, safety, and health. Also, increased pressure on the federal budget 

requires that DOE take a closer look at materials management in order to ensure maximum cost effectiveness. 

This includes an examination of feasible uses of this material, consistent with DOE’s mission, as well as an 

examination of management methods that are consistent with environmental requirements and budgetary 

constraints. DOE needs to implement a long-term (greater than 20 years) management plan for its inventory 

of potentially reusable LEU, NU, and DU. 

1.2 SCOPE OF THIS ENVIRONMENTAL ASSESSMENT 

 DOE is preparing a programmatic environmental assessment (PEA) to address the proposed action 

discussed in Section 1.1. The comprehensive management program addressed in this PEA looks at 

transportation, including preparation of uranium materials for safe shipment, long-term storage, maintenance 

and disposition. The PEA addresses 14,200 metric tons of uranium (MTU) of uranium materials thought to be 

potentially reusable; thus, uranium wastes are not part of the scope. Reusable is defined as “uranium material 

having an economically viable disposition path.” The management plan will cover uranium materials that are 

currently in the form of oxides, metals, and other stable compounds, and which are located at various sites 

around the United States. The plan will not include irradiated material, material in the form of uranium 

hexafluoride (UF6), uranium that is enriched to 20% or greater in 235U, or uranium enriched in 233U. 

 Storage would occur until future sale or reuse alternatives are ready for decision making. DOE will 

evaluate several proposed alternative DOE storage sites under consideration: the Portsmouth Gaseous 

Diffusion Plant (PORTS) in Ohio, the Paducah Gaseous Diffusion Plant (PGDP) in Kentucky, the 

Y-12 National Security Complex and East Tennessee Technology Park (ETTP) in Tennessee, the Savannah 

River Site (SRS) in South Carolina, and the Idaho National Engineering and Environmental Laboratory 

(INEEL) in Idaho. Also both western and eastern commercial sites will be considered. Approximately 

14,200 MTU will be stored in either one (centralized) location or several (consolidated) locations based on the 

proximity of sites or the uranium product form. DOE now has potentially reusable uranium materials in 

158 locations in the United States; however, the vast majority of these materials are located at only a few 

sites. These sites have additional uranium materials, which are not part of the Uranium Management Group 

(UMG) inventory and not addressed by the proposed action. 

 Because many DOE sites have existing and potential future storage space conflicts, specific buildings 

and on-site locations could not be accurately determined. A midpoint location within each site is assumed 

unless otherwise indicated. In addition, the commercial sites to be evaluated are generic sites; that is, they are 

assumed to be located in the western or eastern United States, but their specific locations are not determined. 

Consequently, a relative comparison of alternatives is made, and the analysis is programmatic in nature. 
01-217(doc)/093002 1-2

The disposition of this surplus material is undefined at this time; however, to provide future flexibility 

for the disposition of this material, a “bounding” analysis is performed. The objective of this analysis is to 

establish a bounding scenario such that potential environmental impacts from a variety of disposition options 

have been considered. The scope of this analysis includes: commercial processing of the material, use of this 

material in research activities, provision of this material to other government agencies, and/or the sale 

(international/domestic) of this material. While the uranium materials covered in this PEA are potentially 

reusable and are not wastes, it is possible that some portion of the inventory could, in the future, be declared 

waste. Also, in the disposition process, some wastes could be generated. For example, product containers, 

once emptied, could become waste. The analysis in this PEA addresses, among other things, handling, 

repackaging, and transportation of the uranium product. The analysis also covers these aspects of waste 

production associated with the UMG Program. It is understood that a disposition option not covered by the 

bounding analysis may require further National Environmental Policy Act of 1969 (NEPA) activities. 
01-217(doc)/093002 2-1

2. DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES

2.1 BACKGROUND 

 Uranium is a radioactive element that occurs naturally as an oxide ore (U3O8) in the Earth’s crust. In 

order to make the uranium useful for nuclear fuel or military applications, the ore is usually concentrated and 

then fluorinated to yield UF6, which is further processed to achieve an end-use product. End-use products are 

typically in the chemical form of uranium metal or the oxide. UF6 is not included in this PEA. 

 In its natural state, uranium consists of several different isotopes, notably 238U and 235U, which make up 

~99.3% and 0.711%, respectively, of the total uranium mass. (Man-made uranium materials have been created 

that achieve the same 235U% as the natural uranium. In this PEA, NU refers to 0.711% 235U materials created 

through synthetic processes as well as to natural uranium.) NU is, thus, referred to as “normal” uranium, a 

term widely used in the uranium industry. In most nuclear reactors, the ability to use uranium for controlled 

fission in nuclear chain reactions depends on increasing the proportion of 235U in the material relative to 238U. 

This isotopic separation process is called “enrichment.” In this process, a stream of UF6 containing both 235U 

and 238U is divided into separate streams. One is increased, or enriched, in its percentage of 235U (typically to 

3.5%) and is commonly referred to as LEU. The other is reduced, or depleted, in its percentage of 235U 

(typically to 0.25%) and is commonly referred to as DU. (When the 235U is increased by 20% or more, the 

material is commonly referred to as highly enriched uranium (HEU), which is not in the scope of this PEA.) 

 During World War II, the Manhattan Project established a system of nuclear weapons sites that came to 

be known as the nuclear weapons complex. During the Cold War, this complex was expanded and maintained 

by DOE and its predecessor agencies. The mission of many sites was the processing of uranium in different 

chemical forms, followed by the fabrication of weapons components. With the end of the Cold War, a number 

of DOE sites were left with large uranium inventories in various chemical forms that are now excess to 

national security needs. The mission of some of the former nuclear weapons complex sites is environmental 

remediation, and DOE is now dispositioning uranium from these sites in support of agreements with state and 

federal regulatory agencies. 

 In addition to defense missions, some of the DOE sites processed uranium for use in commercial nuclear 

power plants and for research and development programs. Under these programs, many colleges and universities 

and other government agencies possess DOE-owned uranium materials obtained through contractual or 

loan/lease agreements. Some of this loaned or leased material is now being returned to the DOE inventory. 

 DOE’s inventories of excess LEU, NU, and DU, within the scope of this PEA, total approximately 

14,200 MTU and reside at more than 150 different sites as shown in Table 2-1. Large inventories, however, 

are found at only a few sites. These sites have different missions and different types of uranium material. All 

of the approximately 14,200 MTU at the various sites is anticipated to move to an interim storage location 

prior to final disposition. 

 The data summarized in Table 2-1 and included within the scope of this PEA are taken from a 2000 DOE 

Nuclear Material Inventory Assessment (NMIA). It includes LEU, NU, and DU considered “excess” (i.e., no 

longer required for the national defense mission) but potentially reusable in the future. The data from the 

NMIA were increased by 10% to reflect ongoing uranium material transfer activities (i.e., amounts of uranium 

materials currently stored at a specific location may be higher than those indicated by these data). 
01-217(doc)/093002 2-2

Table 2.1. Uranium management inventory 

Site Amount, MTU

Potential interim storage locations

INEEL 1,521 

PGDP 1 

PORTS 4,393 

SRS 2,995 

Oak Ridge (Y-12 Complex, ETTP, and ORNL)a

 1,445 

Total 10,355 

Other DOE Sites 

Sandia National Laboratories 18 

Los Alamos National Laboratory 12 

Fermi National Accelerator Laboratory 287 

Argonne National Laboratory, Illinois 19 

Argonne National Laboratory, Idaho 228 

Brookhaven National Laboratory 22 

Fernald 691 

Hanford 1,325 

Pacific Northwest Laboratory 7 

Lawrence Livermore 38 

Miscellaneous (9 sites total) ~1 

Total 2,648 

 

Other locations 

Foreign (3 ports of entry) 600 

Non-DOE sites (45 sites total) 51 

Universities (79 sites total) 560 

Total 1,211 

 

Total for all locations (158 sites total) 14,215

a

ORNL is not a potential interim storage location. 

DOE = U.S. Department of Energy. 

ETTP = East Tennessee Technology Park. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

MTU = metric tons of uranium. 

ORNL = Oak Ridge National Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

Y-12 Complex = Y-12 National Security Complex. 

 The mission of the Y-12 Complex has been and continues to be the refining, fabrication, and stockpiling 

of uranium. 

 The mission of ETTP, PGDP, and PORTS has historically been to enrich uranium in the chemical form 

of UF6. PGDP continues this mission today, while ETTP is undergoing reindustrialization, decontamination 

and decommissioning, and environmental restoration. The largest inventory of uranium at each of the three 

sites is DU in the form of UF6, which is not within the scope of this PEA. However, PORTS received uranium 

from the Fernald site in Ohio and the Hanford Site in Washington per two environmental assessments (EAs) 

[DOE 1999 and 2000]. The Fernald and Hanford uranium materials are discussed in the next paragraph. 

Neither ETTP nor Paducah has appreciable quantities of uranium that fall within the scope of this PEA. 

However, each site does have a continuing uranium mission or facilities. 
01-217(doc)/093002 2-3

 PORTS has received and is storing almost all of the uranium materials evaluated in the two 

environmental assessments mentioned above. The Fernald and Hanford sites desire to disposition their 

remaining stored uranium, including their potentially reusable quantities of LEU, NU, and DU that fall within the 

scope of this PEA. Fernald’s primary mission today is environmental restoration. Historically, it conducted 

uranium refining and fabrication operations. The largest inventories of uranium at Fernald that fall within the 

scope of this PEA are DU in the form of metal and uranium tetrafluoride (UF4), NU in the form of metal, and 

LEU in the form of metal and oxide. Most of this uranium has already been sent to the Portsmouth Site. 

Hanford’s primary mission today is also environmental restoration. Historically, it conducted fuel fabrication, 

reactor operations, and chemical separation activities. The largest inventory of uranium at Hanford that falls 

within the scope of this PEA is LEU in the form of metal and oxide. 

 SRS has historically conducted fuel fabrication, reactor operations, and chemical separation activities. In 

addition, DOE recently decided to locate one key plutonium disposition facility at SRS. The majority of the 

approximately 19,500 MTU of uranium trioxide at SRS is likely to remain there for the foreseeable future and 

is not considered within the scope of this PEA. These oxides are not part of the UMG inventory. The largest 

inventory of uranium at SRS that falls within the scope of this PEA is DU in the form of metal. 

 INEEL has conducted chemical separation activities for spent fuels from the U.S. Navy and research reactors. 

The largest inventory of uranium at INEEL that falls within the scope of this PEA is DU in the form of metal.

 Table 2.2 provides a summary of the various interim storage alternatives to be considered in the PEA, the 

amount of uranium indicated in the 2000 NMIA data as stored at each of the major DOE sites, and the amount 

of uranium product potentially to be moved (including the estimated number of trucks or railcars needed for 

shipment). These amounts are 10% higher than the actual 2000 NMIA data. Tables 2.3, 2.4, and 2.5 show the 

packaging assumptions and transportation assumptions used to derive the number of containers, trucks, and 

railcars shown in Table 2.2. Estimates of storage space requirements at each site are shown in Table 2.7. 

 It should be noted that the NMIA data used for this study did not identify numbers of containers or 

container types for the various types of uranium material included in the PEA. This information is necessary 

to determine transportation impacts and storage requirements. Therefore, the number of containers shown in 

Table 2.2 may not reflect current storage conditions; rather, the assumptions outlined in Tables 2.3 and 2.4 

and described below were used in order to evaluate all materials consistently. For example, SRS indicates the 

site has 3,861 wooden and cardboard boxes containing uranium metal (DU, NU and LEU) and 381 drums of 

LEU oxide. However, if these materials were repackaged for shipment to a different interim storage location, 

using the assumption in Tables 2.3 and 2.4, the number of containers would be reduced. In addition, the 

storage requirements shown in Table 2.6 may not reflect current storage configurations, but rather assume that 

all materials at a site are stored in a consistent storage array under similar conditions. The following 

assumptions were used to derive the number of containers either currently in storage, or anticipated to be 

moved, and the storage space requirements for each alternative: 

• Two types of containers were considered: (1) 55-gal drums and (2) full-size (7 × 4 × 4 ft), strong, tight 

metal boxes (Fig. 2.1). Table 2.3 indicates the capacity of each type of container and the types of material 

assumed to be placed in those containers. Each line item of data in the NMIA database provided for this 

study was considered separately in order to determine which type of container it would be placed in (i.e., 

items were not combined in order to reduce the number of containers). 

• Amounts of material that can be packaged in single containers are shown in Table 2.4. These values are 

based on container capacity for DU and NU fissile material limits for 235U (10 Code of Federal 

Regulations 71.24) for Type A containers for LEU. Material types (DU, LEU, and NU) are not mixed in a 

single container. 
01-217(doc)/093002 2-4 Table 2.2. Uranium management PEA interim storage alternatives Assumed storagea Additional material

Interim storage alternative Description Site/form Amount (103 MTU) Number of containers Amount (103 MTU) Number of containers Numbe

of site

No Action Continued storage at current sites. Total material included in the PEA is ~14,200 MTU INEEL PGDP PORTS SRS Oak Ridge All others 1.5 <0.1 4.4 3.0 1.4 3.9 639 8 24,765 2,867 6,431 37,124 N/A N/A N/A Interim centralized storage at a single DOE site All material transferred to a single, centralized DOE storage location INEEL PGDP PORTS SRS Oak Ridge 1.5 <0.1 4.4 3.0 1.4 639 8 24,765 2,867 6,431 12.7 14.2 9.8 11.2 12.8 71,195 71,826 47,069 68,967 65,403 157 157 157 157 157 Interim centralized storage at a single commercial site All material transferred to a single, centralized commercial storage location (east or west) East, West N/A N/A 14.2 71,834 158 Interim partially consolidated storage at several DOE sites 

Material moved to the closest consolidated storage location 

INEEL 

PGDP 

PORTS 

SRS 

Oak Ridge 

1.5 

<0.1 

4.4 3.0 1.4 

639 

8 

24,765 

2,867 6,431 

1.7 0.4 1.4 

<0.1 

0.4 

21,391 

400 

13,458 

63 

1,812 

46 24 66 

7 

10 

Interim partially consolidated storage at two DOE sites 

Material consolidated at PORTS and INEEL 

PORTS 

INEEL 

4.4 1.5 

24,765 

639 

6.6 1.7 

24,940 21,490 

92 64 

Interim partially consolidated storage at two commercial sites 

Material consolidated at one Eastern and one Western commercial site

East, West N/A 

N/A 

N/A N/A 

11.0 

3.2 

49,705 22,129 

93 65 
01-217(doc)/093002 2-5 Table 2.2. Uranium management PEA interim storage alternatives (continued) Assumed storagea Additional material

Interim storage alternative Description Site/form Amount (103 MTU) Number of containers Amount (103 MTU) Number of containers Numbe

of site

Interim partially consolidated storage based on physical form Material consolidated by physical form (i.e., the site with the largest quantity of a specific physical form is the preferred storage location for all materials of that form) Compound (PORTS) Metal (SRS) Misc. (PORTS) Oxide (PORTS) Reactor fuel (INEEL) Residue (INEEL) Source (INEEL) 1.7 2.9 0 0.9 0.5 <0.1 <0.1 7,221 1,088 0 15,333 184 55 8 <0.1 6.0 1.2 0.5 0.4 <0.1 <0.1 1,034 32,918 4,998 7,807 827 174 187 12 21 121 17 25 7 21 

DOE = U.S. Department of Energy. INEEL = Idaho National Engineering and Environmental Laboratory. MTU = metric tons of uranium. PEA = programmatic environmental assessment. PGDP = Paducah Gaseous Diffusion Plant. PORTS = Portsmouth Gaseous Diffusion Plant. N/A = not applicable. SRS = Savannah River Site. aIt should be noted that the Nuclear Material Inventory Assessment data used for this study did not identify numbers of containers or container ty

uranium material included in the programmatic environmental assessment. This information is necessary to determine transportation impacts and stor

the number of containers shown in Table 2.2 may not reflect current storage conditions; rather, the assumptions outlined in Tables 2.3 and 2.4 were usmaterials consistently. For example, Savannah River Site indicates the site has 3,861 wooden and cardboard boxes containing uranium metal (depleteand low enriched uranium) and 381 drums of LEU oxide. However, if these materials were repackaged for shipment to a different interim storage locain Tables 2.3 and 2.4, the number of containers would be reduced. 
01-217(doc)/093002 2-6

Table 2.3. Packaging assumptions for uranium management PEA 

Physical form(s) 

Assumed container 

typea

Compound Drum 

Metal (>540 lb) 

Metal (<540 lb) 

Metal box 

Drum 

Miscellaneous Drum 

Oxide (>540 lb) 

Oxide (<540 lb) 

Metal box 

Drum 

Reactor fuel (>540 lb) 

Reactor fuel (<540 lb) 

Metal box 

Drum 

Residue Drum 

Source Drum 

a

Assumes no mixing of material type and physical form in a 

single container. All low-enriched uranium (LEU) materials, 

regardless of amount or physical form, are packaged in drums. 

PEA = programmatic environmental assessment. 

Table 2.4. Container assumptions for uranium management PEA 

a

Based on fissile material limits of 800 g/container at 1.35% 235U (10 Code of 

Federal Regulations 71.20 for Type A containers). 

DU = depleted uranium. 

LEU = low-enriched uranium. 

NU = normal uranium. 

PEA = programmatic environmental assessment. 

Table 2.5. Transportation assumptions for uranium management PEA 

Transport vehicle Material type(s) Container type Maximum numbera

DU, NU Drums 64

LEUb Drums 12 

Truck 

DU, NU Metal boxes 6 

DU, NU Drums 240

LEUb Drums 12 

Railcar 

DU, NU Metal boxes 26 

a

Maximum number based on weight and/or 235U limits. Assumes no stacking for trucks or any LEU containers; railcar 

pallets and boxes stacked two high for DU, NU. b

Based on fissile material limits of 10,000 g/consignment (i.e., single truck or railcar) at 1.35% 235U (10 Code of 

Federal Regulations 71.20 for Type A containers). 

DU = depleted uranium. 

LEU = low-enriched uranium. 

NU = normal uranium. 

PEA = programmatic environmental assessment. 

Material type(s) Assumed container type

Amount per container 

(lb)

DU, NU Drum 

Metal box 

540 

5,850 

LEUa Drum 130 
01-217(doc)/093002 2-7

Table 2.6. Uranium management PEA interim storage requirements 

Alternative Site 

Amount 

(103

 MTU)

Number of 

containers

Estimated storage 

requirement (ft2

)

No Action INEEL 

PGDP 

PORTS 

SRS 

Oak Ridge 

1.5 

<0.1 

4.4 

3.0 

1.4 

639 

8 

24,765 

2,867 

6,431 

7,000 

100 

75,000 

19,000 

25,000 

Interim centralized storage at a 

single DOE or commercial site 

Any 14.2 71,834 243,000 

Interim partially consolidated 

storage at several DOE sites 

INEEL 

PGDP 

PORTS 

SRS 

Oak Ridge 

3.2 

0.4 

5.8 

3.0 

1.9 

22,030 

408 

38,223 

2,930 

8,243 

79,000 

2,000 

116,000 

19,000 

28,000 

Interim partially consolidated 

storage at two DOE or two 

commercial sites 

PORTS/East 

INEEL/West 

11.0 

3.2 

49,705 

22,129 

165,000 

79,000 

Interim partially consolidated 

storage based on physical form 

PORTS 

SRS 

INEEL 

4.4 

8.9 

0.9 

36,393 

34,006 

1,435 

100,000 

136,000 

7,000

DOE = U.S. Department of Energy.

INEEL = Idaho National Engineering and Environmental Laboratory. 

MTU = metric tons of uranium. 

PEA = programmatic environmental assessment. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

Table 2.7. Uranium management PEA disposition options

Disposition option Description 

Material 

type(s) 

Amount 

(103

 MTU)

Number of 

containers 

Number of 

trucks 

Number of 

railcars 

Commercial 

processing/domestic 

sales 

All material transferred from 

interim storage to a single 

commercial processing facility or 

single sales distribution point 

(east or west) 

All 14.2 71,834 5,529 4,882 

Transfer to research 

facilities 

Transfer ~50 MTU from interim 

storage to the furthest DOE or 

other research location 

DU, NU 

LEU 

0.05 

0.05 

204 

844 

4 

71 

1 

71 

Transfer to other 

government agencies 

Transfer ~2,500 MTU 

from interim storage to 

unspecified location (use furthest 

distance already evaluated) 

DU, NU 

LEU 

2.5 

2.5 

10,186 

42,188 

160 

3,516 

43 

3,516 

Foreign sales All LEU/NU (~4,050 MTU) 

transferred to eastern or western 

port for overseas shipment 

LEU 

NU 

3.3 

0.7 

56,408 

1.432 

4,701 

49 

4,701 

13 

DOE = U.S. Department of Energy. 

DU = depleted uranium. 

LEU = low-enriched uranium. 

MTU = metric tons of uranium. 

NU = normal uranium. 

PEA = programmatic environmental assessment 
01-217(doc)/093002 2-8

Fig. 2.1. Example of the 55-gallon drums and metal storage containers used at PORTS.
01-217(doc)/093002 2-9

• Shipments were based on truck and railcar capacities as shown in Table 2.5. Storage alternatives were 

evaluated using both rail and truck transport, except in those instances in which the amount of material to 

be shipped was small enough to fit into a single truck, in which case only truck shipment was evaluated. 

However, containers and material types are not mixed in a single shipment (i.e., if there are not enough 

drums to fill an entire truck, metal boxes are not added). This assumption also tends to result in a 

conservative estimation of the number of trucks and railcars.

• Storage requirements (Table 2.6) are based on an assumed storage configuration that includes four drums 

per pallet, with pallets stacked four high and metal boxes stacked four high for DU and NU. Containers 

with LEU are stacked two high. Stacks of drums and boxes are arranged two deep so that access by 

material handling equipment is ensured. Also, aisle space is allowed every 40 ft and around the perimeter.

2.2 NO ACTION ALTERNATIVE 

The No Action alternative would continue ongoing storage activities at all existing facilities. This 

alternative includes the continued storage of uranium materials in existing facilities (DOE and private).

Monitoring and surveillance of the uranium materials at each site would continue, as would the handling 

necessary to continue proper management of these materials, including repackaging if needed. The uranium 

inventory would not be dispositioned (see Section 2.3.8). 

2.3 PROPOSED ACTION 

 DOE proposes to implement a long-term (greater than 20 years) management plan for its inventory of 

potentially reusable LEU, NU, and DU. Uranium materials, which are presently located at multiple sites, are 

to be consolidated by transporting the materials to one or several storage locations, to facilitate ultimate 

disposition. The management plan will address the packaging and transport of potentially reusable uranium 

materials from DOE sites and university loan/lease returns and their receipt and storage at a site under 

cognizance of the UMG. This action will also cover material shipment from the UMG and disposition. A 

Secretarial Determination is required, under certain circumstances, for uranium in the UMG inventory to be 

sold. Twenty years will provide time for additional reviews required for any future related actions that may 

be desirable to help accomplish ultimate disposition. Impacts evaluated in Chapter 4 cover the 20-year period 

of this management plan. 

 The management plan will cover uranium materials that are currently in the form of oxides, metals, and 

other stable compounds such as UF4. The quantity of uranium within the scope of this PEA is estimated to be 

14,200 MTU and is primarily located at a few DOE locations (INEEL, PORTS, SRS, and Oak Ridge). These 

DOE locations have other uranium materials which are not part of the UMG inventory and not part of the 

14,200 MTU addressed in the proposed action. This number is based on the 2000 NMIA data increased by 

approximately 10% to reflect uncertainties in material shipment. The plan will not include irradiated material, 

UF6, enrichment of 20% or greater 235U, or 233U. 

 DOE must determine the safest, most effective, and most efficient approach for the consolidation and 

storage of this material. Consideration will be given only to those locations (DOE and commercial) within the 

continental United States that have a long-term mission for the handling and storage of uranium material. This 

material would be stored in either one (centralized) location or several (consolidated) locations. Approximately 

14,200 MTU may be consolidated into one or more storage locations. This material is the primary focus of this 

PEA. 
01-217(doc)/093002 2-10

 Since disposition of this material is currently undefined, a “bounding” analysis is performed to estimate 

the potential impacts from commercial processing of this material, use of this material in research activities, 

provision of this material to other Government agencies, and/or the sale (international/domestic) of this 

material upon expiration of the current moratorium. Disposition is a component of each of the action 

alternatives and impacts would differ based only on differences in transportation. Some wastes would be 

produced during this disposition process. 

2.3.1 Interim Centralized Storage at a Single DOE Site 

 This alternative would consolidate all 14,200 MTU uranium materials at one DOE location. The 

potential storage sites are as follows: 

• PORTS, in Pike County, Ohio; 

• PGDP, near Paducah, Kentucky; 

• INEEL, near Idaho Falls, Idaho; 

• the Y-12 Complex and ETTP, in Oak Ridge, Tennessee; and 

• SRS, near Aiken, South Carolina. 

 These six DOE sites have an existing inventory totaling approximately 10,300 MTU of LEU, NU, and 

DU in the scope of this EA. In addition, there is a relatively small amount (3,900 MTU) at 152 other sites 

located around the United States. The DOE preferred alternative would be to locate all these materials at the 

PORTS. PORTS is preferred because of its combination of characteristics: 

• successful on-going receipt and storage of the uranium materials from Fernald and Hanford and 

universities, 

• the existence of a uranium management infrastructure, 

• personnel experienced in all relevant aspects of uranium operations, 

• the availability of buildings with requisite floor space and nuclear safety alarm systems, and 

• an ongoing uranium mission or facilities. 

2.3.2 Interim Centralized Storage at a Single Commercial Site 

 This alternative assumes that all 14,200 MTU within the scope of this EA at existing DOE sites would be 

consolidated at a single commercial site. A commercial site in either the western or eastern United States 

would receive all the uranium materials. DOE has not identified specific commercial sites at this time. 

However, DOE must consider this possibility in the event that a commercial site is identified in the future. 

Therefore, for analysis purposes, especially transportation which requires definitive travel routes, a generic 

western (Utah) site and an eastern (South Carolina) site have been assumed. These sites should provide a 

reasonable bound for the transportation impacts. 

2.3.3 Interim Partially Consolidated Storage at Several DOE Sites 

 Under this alternative, the six major DOE sites considered as single, consolidated storage sites will retain 

their existing uranium material inventory. In addition, the 3,900 MTU of uranium materials at the other 

152 sites will be moved to these six sites based on proximity (closest distance). 

2.3.4 Interim Partially Consolidated Storage at One Western and One Eastern DOE Site 

 Under this alternative two DOE sites, one in the western United States (INEEL) and one in the eastern 

Untied States (PORTS), will retain their existing uranium material inventories. The remaining inventory in 
01-217(doc)/093002 2-11

the three major DOE sites, plus the 3,900 MTU of uranium materials at the other 157 sites, will be moved to 

these two sites based on proximity. 

2.3.5 Interim Partially Consolidated Storage at One Western and One Eastern Commercial Site 

 This alternative assumes that all 14,200 MTU at existing DOE sites would be consolidated at two 

commercial sites, one in the western United States and one in the eastern United States. Materials would be 

shipped to these two sites based on closest distance. DOE has not identified specific commercial sites at this 

time. 

2.3.6 Interim Partially Consolidated Storage by Physical Form 

 Under this alternative, the 14,200 MTU of uranium materials would be consolidated at three DOE sites 

(PORTS, SRS, and INEEL) based on physical form. It is assumed that PORTS would receive all the 

compounds, miscellaneous, and oxide uranium materials (about 4,400 MTU), while SRS would receive the 

metals (more than 8,900 MTU) and INEEL would receive the reactor fuel, residue, and sources (about 

900 MTU). The sites with the largest inventory of a particular form (such as metals at SRS) would receive all 

of that form from every site. 

2.3.7 Transfer of Small Quantities 

 DOE must be able to transfer small quantities (less than 0.1 MTU) from any one of the potential 

consolidated or centralized storage sites to a second location (such as a university). This option will be 

considered as a component of each alternative under the proposed action. It is not itself a stand-alone 

alternative. The impacts are bounded under the disposition option discussed below. 

2.3.8 Disposition Options 

Disposition is a component of each of the interim storage alternatives and not a separate alternative. DOE 

may dispose of all, or part, of the uranium materials in one of several ways. These reuse scenarios are 

speculative at this time, especially in regard to the quantities of uranium and timing of movement for a 

particular disposition path. Table 2.7 indicates the final disposition options and the amounts of uranium 

materials that are expected to be sent to each of these options from their respective interim storage locations. 

Any material not included in a specific disposition option can be included with any of the other disposition 

options. The disposition options are an integral constituent of each alternative, and all four options are 

included with each alternative when impacts are analyzed. 

2.3.8.1 Commercial Processing/Domestic Sales 

 One option is the sale of some of the uranium materials to the domestic commercial nuclear fuel market 

after the sales moratorium on certain uranium materials has expired in 2008. Metals and oxides could be sold 

to commercial nuclear vendors for the manufacture of nuclear fuel for commercial nuclear power plants. 

Another scenario is the use of the uranium materials to down-blend HEU in conjunction with arms reduction 

treaties; the resulting LEU could be readily used in commercial nuclear power plants. The total quantity of 

14,200 MTU may be reprocessed commercially or sold domestically. A generic eastern and a generic western 

processing site, or sales distribution point, will be assumed for analysis purposes. 

2.3.8.2 Transfer to Research Facilities 

 Approximately 50 MTU would be potentially received by research facilities. This is based on material 

that is stored by the UMG that is in an acceptable form to be received by these facilities. The total 50 MTU 
01-217(doc)/093002 2-12

would be transferred to a single site assumed to be the greatest distance from one of the six proposed DOE 

interim storage locations. 

2.3.8.3 Transfer to Other Government Agencies 

 There would be approximately 2,500 MTU that could be provided to other government agencies. The 

uranium materials would be the Fernald Environmental Management Project (FEMP) DU and FEMP and 

Hanford uranium trioxide (UO3). The military could use uranium metal in the armoring of military vehicles 

and in the manufacture of military vehicle penetrators. The total 2,500 MTU would be transferred to a single, 

unspecified location assumed to be the greatest distance from one of the six proposed DOE interim storage 

locations. 

2.3.8.4 Foreign Sales 

 One option is the sale of some of the uranium materials to the international commercial nuclear fuel 

market after the sales moratorium on certain uranium materials has expired in 2008. The total LEU and NU 

would be approximately 4,050 MTU for international sales. This assumes that DU would not be a desired 

commodity internationally. The LEU and NU would be transferred from their interim storage locations to the 

closest international port (assumed to be Hampton Roads as an eastern port or San Diego for a western port) 

and shipped via cargo vessel to the farthest port in Asia or the Far East.

2.4 ALTERNATIVES CONSIDERED BUT NOT PROPOSED FOR ANALYSIS 

 An alternative DOE considered is to declare all of the uranium materials (14,200 MTU) included in the 

PEA scope as waste and dispose of them. DOE believes there is an essential need (current and ongoing) to 

effectively manage its existing uranium materials inventory as a government asset. Therefore, DOE believes 

an alternative involving the disposition of the uranium materials as waste is not reasonable. However, prior to 

transport and storage, the uranium material inventory addressed in this proposed action would be evaluated to 

ensure that none of these materials is waste. DOE has additional uranium inventories which are not reusable 

and might be declared waste. Also, DOE has other inventories which are not waste but, for various 

Department reasons, are not addressed in this EA. 
01-217(doc)/093002 3-1

3. AFFECTED ENVIRONMENT 

3.1 PORTSMOUTH GASEOUS DIFFUSION PLANT 

 PORTS is located approximately 35 km (22 miles) northeast of Portsmouth in Pike County, Ohio, and 

occupies 3714 acres. Construction of the site began in late 1952 and ended in 1956, one year after the start of 

uranium enrichment processing at the site. On July 1, 1993, DOE leased portions of PORTS to the United 

States Enrichment Corporation (USEC) to manage and operate the uranium enrichment enterprise. DOE 

retains responsibility for the unleased portions of the site, which consist primarily of environmental 

restoration and waste management activities. 

3.1.1 Human Health 

 The radiation dose from airborne radionuclides to a maximally exposed individual was 0.260 mrem, 

and the collective radiological dose from airborne emissions to the site region of influence (ROI) health risk 

population was 3.0 person-rem (DOE 1997a). 

3.1.2 Climate and Air Quality 

 Prevailing winds at PORTS are from the south to southwest, with the south averaging the highest at just 

over 11% of the time. Wind speeds average 5 mph, with winds up to 75 mph on record. The average annual 

temperature measured at the site in 1992 was 55°F (DOE 1997a), with 112 days/year at or below 32°F in the 

winter with only 27 days/year at or above 90°F in the summer (MMES 1991). 

 Pike County is classified by the U.S. Environmental Protection Agency (EPA) as an attainment area for 

all six National Ambient Air Quality Standards (NAAQS) criteria air pollutants. The major sources of criteria 

pollutant emissions are three coal-fired boilers at the X-600 steam plant. Sources of radionuclide and fluoride 

emissions include purge cascade vents, cold recovery and wet evacuation vents, the X-344 evacuation vent, 

and six seal exhaust vents. 

3.1.3 Water Resources 

Surface Water

 Major surface water features include the Scioto River and its on-site tributaries – Little Beaver Creek and 

Big Run Creek. There are no federally designated Wild and Scenic Rivers in the ROI. The Scioto River and 

an alluvial aquifer supply water to the site, and the on-site streams and Scioto River receive treated 

wastewater. The site is located outside the 500-year floodplain. 

Groundwater

 Major groundwater units include the Mississippian shale and sandstone bedrock aquifer and the 

unconsolidated sediment aquifer. 

3.1.4 Geology and Soils 

 The site is on gently rolling land about 40 m (130 ft) above the Scioto River and 204 m (670 ft) above 

sea level. The predominant landform in the area is a relatively level, filled valley of the preglacial Portsmouth 

River, which runs north to south. Major rock units include, from oldest to youngest, the Ohio Shale, the 

Bedford Shale, the Berea Sandstone, the Sunbury Shale, and the Cuyahoga Shale. The site is in an abandoned 
01-217(doc)/093002 3-2

river valley filled with fluvial materials. The soils in the fenced area are mostly urban land covered by roads, 

parking lots, buildings, and railroads. Other soils are well-drained upland soils. No major geologic faults exist 

in the ROI, and the potential for volcanic activity is small. 

3.1.5 Ecological Resources 

 Vegetation consists of pastureland, old fields, oak-hickory, upland mixed hardwood, bottomland mixed 

hardwood, pine, second-growth hardwood, and scrub thicket. All forests and old fields are second growth. 

There are 45 wetlands totaling 13.9 ha (34.36 acres) at PORTS (DOE 2001a). The federally protected, 

endangered Indiana bat has been identified in the vicinity of the site, but no threatened or endangered species 

have been located on-site. Several state-listed species are known for the vicinity but none presently on-site. 

The sharp-shinned hawk, Carolina yellow-eyed grass, Virginia meadow beauty and rough green snake have 

been found on-site in the past. 

3.1.6 Socioeconomics and Environmental Justice 

Socioeconomics

 The PORTS ROI includes both Pike County, where the facility is located, and Scioto County, which 

includes Portsmouth, the nearest city. Table 3.1 summarizes population, per capita income, and total person 

income for both counties from 1999, the last year for which figures were available. Total personal income was 

more than $2 billion (U.S. Bureau of Economic Analysis 2002a). Combined wage and salary employment for 

the region was nearly 39,817 in 2000 (U.S. Bureau of Economic Analysis 2002b). Total site employment in 

1998 was 2700 (DOE 2002a). 

Table 3.1. Population, income, and employment in the PORTS region of influence 

for Pike County and Scioto County

Region/Variable Pike County Scioto County 

Population 27,988 80,533 

Per capita personal income ($) 18,353 18,978 

Total personal income (million $) 514 1,524 

Environmental Justice

 There are no federally recognized Native American tribes in the ROI. There are no minority populations 

within a 32-km (20-mile) radius of the PORTS site. However, the vast majority of a 32-km (20-mile) radius of 

the plant has low-income populations (based on population proportions greater than the national average of 

13.1%). 

3.1.7 Land Use 

 The site covers approximately 6.3 mile2

 (4003 acres), of which 800 acres are developed and 3203 acres 

are undeveloped. Of the land that is undeveloped, nearly all is available for future site development. Land use 

surrounding the site is predominantly rural. 

3.1.8 Infrastructure 

 One on-site facility and 31 off-site wells provide an average of 14 million gallons of water per day. An 

on-site facility receives an average of 0.35 million gallons of sewage per day. The Ohio Electric Corporation 
01-217(doc)/093002 3-3

supplies power via an electrical and coal-fired system; the historical load is over 1500 MW and 4500 tons of 

coal/month use; however, the current load is less than 100 MW/month. Transportation in the region consists 

of local access roads (such as Piketon Hill Road and State Route 32) and major roads (such as Interstate 70 

and U.S. Highways 23, 52, and 50). The Chesapeake & Ohio Railroad and the Norfolk & Western Railroad 

are the primary providers of rail service to the PORTS region. 

3.1.9 Cultural Resources 

 A 1997 archaeological survey identified 39 archaeological resources, which includes prehistoric 

components, isolated finds, and lithic scatters. A couple of resources contain prehistoric and historic 

components; another is a prehistoric, isolated find in a historic cemetery; another is a prehistoric lithic scatter 

and a lithic scatter in a historic farmstead (DOE 2002). Two architectural historic surveys have been 

completed at PORTS, and several structures have been identified that may have historical significance (DOE 

2002). 

3.2 PADUCAH GASEOUS DIFFUSION PLANT 

 The PGDP Reservation covers 3425 acres in western Kentucky, 17 km (10 miles) west of Paducah, and 

employs 1868 people. Paducah has been an active uranium enrichment facility since 1952. Enriched uranium 

is produced by the USEC for the commercial sector as fuel for nuclear power reactors in the United States and 

overseas. PGDP was a feed facility for PORTS. 

3.2.1 Human Health 

 The radiation dose from airborne radionuclides to the maximally exposed individual was 0.0045 mrem, 

and the collective dose from radionuclide emissions to the site ROI health risk population was 

0.017 person-rem. The ROI population was estimated at 500,502 based on 1990 census data. 

3.2.2 Climate and Air Quality 

 The average prevailing wind in the area is from south to southwest at approximately 16 km/h (9.8 mph). 

Generally stronger winds are observed when winds are from the southwest or northwest (DOE 2000). January 

is the coldest month, with a daily average temperature of 35°F, while July is the warmest month with an 

average temperature of 79°F. 

 McCracken County is classified by the EPA as a marginal attainment area for ozone. The county is in 

attainment for the other criteria pollutants. The major sources of criteria air pollutant emissions are coal-, oil-, 

and gas-fired boilers. Sources of radionuclide emissions in 1997 were the cascade purge vent/stack at the 

C-310 purge and products building, decontamination activities at the C-400 cleaning building, and emissions 

from laboratory hoods in the C-710 building. 

3.2.3 Water Resources 

Surface Water

 Major surface water features include the Ohio River, which is less than 3 km (2 miles) from PGDP, 

Metropolis Lake [2.4 km (1.5 miles) northeast], and two small tributaries to the Ohio River (Big Bayou Creek 

and Little Bayou Creek) that provide surface drainage to the site. There are no federally designated Wild and 

Scenic Rivers in the ROI. The site is above the probable 500-year flood level. The site receives fresh water from 

the Ohio River, and both the two on-site streams and the Ohio River receive treated wastewater from the site. 
01-217(doc)/093002 3-4

Groundwater 

 Major groundwater units include, from bottom to top, the McNairy Flow System (interbedded sand, silt 

and clay), the terrace gravels, the Regional Gravel Aquifer (the primary aquifer in the area, composed of sand 

and gravel units), and the Upper Continental Recharge System (clayey silt with interbedded sand and gravel). No 

aquifers are considered sole-source aquifers. Two major plumes of groundwater contamination extend off-site. 

3.2.4 Geology and Soils 

 The topography slopes slightly from more than 137 m (450 ft) in the southern part of the site to near 

91 m (300 ft) near the Ohio River. Surface sediments consist of valley fill deposits, which underlie most of 

the site, extending northward to the Ohio River. Major rock units include, from oldest to youngest, basement 

rocks, Tuscaloosa Formation basal gravels, the McNairy Formation, the Porters Creek Clay, continental 

deposits of gravel and clay-sand units, and a 10- to 30-ft layer of loess (windblown sediment). Soils beneath 

the site are nearly level and somewhat poorly drained. Geologic hazards include the potential for earthquakes. 

The site is near two active seismic zones, the New Madrid Fault Zone and the Wabash Valley Fault Zone. The 

potential for volcanic activity is small. 

3.2.5 Ecological Resources 

 Nonforested areas consisting of mowed grass and developed area cover most of the Paducah site; 

forested areas are small and dominated by mature hardwood upland and riparian forests. On-site wetlands 

consist of forested wetlands (mature riparian hardwood forest). A wetland in the West Kentucky Wildlife 

Management Area (the buffer area surrounding the production facilities) has been designated an area of 

ecological concern. 

 Federally listed endangered species that have been identified, or could be identified, in the vicinity of the 

Paducah site include the Indiana bat, the interior least tern, and four species of pearly mussels. Another 

species of pearly mussel is federally listed as threatened, as is the bald eagle. No federally listed plant species 

are known to occur in the vicinity of Paducah. 

3.2.6 Socioeconomics and Environmental Justice 

Socioeconomics

 The Paducah ROI includes McCracken County, Kentucky, where the facility is located. McCraken 

County had a population of 64,407, per capita personal income of $23,227, and a total person income of 

$1.8 billion in 1999 (U.S. Bureau of Economic Analysis 2002a). Wage and salary employment for the region 

was more than 41,859 in 2000 (US Bureau of Economic Analysis 2002b). Total site employment in 1998 was 

2209 (DOE 2002b). 

Environmental Justice

 There are both low-income and minority populations near the plant site, with minority populations in the 

city of Paducah. There are no federally recognized Native American tribes in the area. 

3.2.7 Land Use 

 The site occupies approximately 3425 acres, of which 750 acres are developed and 2675 acres are 

undeveloped. Land use surrounding the site is predominantly undeveloped natural area. 
01-217(doc)/093002 3-5

3.2.8 Infrastructure 

 The Ohio River supplies an average of 15 million gal of water per day; the water is treated on-site by 

chemical and physical processes. An on-site treatment plant receives an average of 0.2 million to 0.4 million 

gal of sewage per day. Sewage is treated on-site. Electric Energy, Inc., supplies power; the current site load is 

1564 MW. The site also uses approximately 82 tons of coal per day. Transportation in the region consists of 

local access roads (State Routes 1154 and 358) and major roads (Interstate 24 and U.S. Highways 45, 60, and 

63). The Burlington Northern Railroad, Paducah Railroad, Louisville, and the on-site U.S. Government 

Railroad are primary providers of rail service to the Paducah region. 

3.2.9 Cultural Resources 

 The site has three recorded archaeological or historic sites, and others have been identified in areas near 

the Paducah plant site. The site has not been subject to any systematic cultural resources surveys. 

3.3 Y-12 NATIONAL SECURITY COMPLEX 

 The Y-12 Complex (formerly the Y-12 Plant) is one of three installations on the DOE Oak Ridge 

Reservation (ORR). The early missions of the site included separation of 235U from normal uranium by the 

electromagnetic separation process and manufacturing weapons components from uranium and lithium 

(DOE 2001b). 

 During 2000, the U.S. Congress established the National Nuclear Security Administration (NNSA). 

Its mission is to carry out National Security responsibilities of DOE (DOE 2001).

3.3.1 Human Health 

 The calculated radiation doses to maximally exposed off-site individuals from airborne releases from all 

sources on the ORR were 0.40 mrem (ORNL 2001). The collective radiological dose from airborne 

radionuclide emissions to the site ROI health risk population was 43 person-rem (DOE 1997a). 

3.3.2 Climate and Air Quality 

 The climate of eastern Tennessee may be broadly classified as humid continental, although it is very near 

the region of temperate continental climate to the north. The Cumberland Mountains/Plateau to the northwest 

and the Great Smoky Mountains to the southeast influence the patterns of temperature and precipitation over 

the region, with cooler temperatures and greater precipitation generally occurring at the higher elevations. The 

average annual temperature in Oak Ridge, based on a 30-year period from 1961 to 1990, is 56.6°F, and 

precipitation is 136.7 cm (53.8 in.) per year. Precipitation is fairly evenly distributed most of the year. The 

average wind speed is approximately 4 mph (at 10 m above the ground), and the highest wind speed, 79 mph, 

was associated with a tornado in Bear Creek Valley during the afternoon of February 21, 1993. Prevailing 

wind directions are from the northeast and southwest, reflecting the channeling of winds parallel to the ridges 

and valleys in the area. 

 The air quality control region in which the Y-12 Complex is located is in attainment for NAAQS criteria 

pollutants. The nearest nonattainment area is Polk County, which is about 64 km (40 miles) south of the Y-12 

Complex. Air quality in the region is generally good. However, the ozone standard is occasionally exceeded 

per monitoring data from Anderson County (DOE 2001b). 
01-217(doc)/093002 3-6

 The release of radiological contaminants, primarily uranium, into the atmosphere at the Y-12 Complex 

occurs almost exclusively as a result of plant production, maintenance, and waste management activities 

(ORNL 2001). In 2000, only 9.16 × 10-3 curies of uranium (2.2 kg) were released from the Y-12 Complex 

(ORNL 2001). Measurements at the perimeter of the ORR indicate ambient air concentrations are less than 

1% of their respective derived concentration guidelines (DCGs) given in DOE Order 5400.5 (DOE 1997a). A 

DCG is a concentration of a given radionuclide for one exposure pathway (e.g., inhalation) that would result 

in an effective dose equivalent (EDE) of 100 mrem per year to a reference individual, as defined by the 

International Commission on Radiological Protection. 

 The prevention of significant deterioration (PSD) Class I area nearest to the Y-12 Complex is the Great 

Smoky Mountains National Park, approximately 48 km (30 miles) south of the facility. The Joyce Kilmer 

Wilderness Area, which is also a Class I area, is just south of the western end of the Great Smoky Mountains 

National Park. The median visibility range at the park is 39 km (24 miles), with a summer median of 19 km 

(12 miles). 

3.3.3 Water Resources 

 The Y-12 Complex is approximately 3 km (2 miles) from the Melton Hill Reservoir and Clinch River. 

On-site, two streams originate approximately in the middle of the plant. Bear Creek flows directly west from 

its headwaters at the Y-12 Complex, while East Fork Poplar Creek flows east before turning north and west 

and flowing through the residential area of Oak Ridge. These two creeks merge near ETTP, which is 

approximately 16 km (10 miles) west of the Y-12 Complex. The major groundwater unit for the ORR is the 

Knox Aquifer, composed of the Knox Group and the Maynardville Limestone. No aquifers are considered 

sole-source aquifers (DOE 1997b). 

3.3.4 Geology and Soils 

 On a regional scale, the ORR, which includes the Y-12 Complex, is located on the western part of the 

Valley and Ridge Province (DOE 1998a). The stratigraphic section of the ORR is stacked along three major 

thrust faults. The eastern portion of the Y-12 Complex is located on the White Mountain thrust sheet. This 

fault has not been historically active (DOE 1998a). 

 Bear Creek Valley, to the west, is underlain by rocks of three regionally important stratigraphic units: the 

Rome Formation, the Conasauga Formation, and the Knox Group, which typically dip 45° to the southeast 

(DOE 1997b). The geology of Bear Creek Valley displays an inclined layer, cake-style stratigraphy that is 

observed on a variety of scales: on a regional scale, where limestone- and dolomite-dominated rock groups 

are interbedded with predominantly clastic shale groups, and on the scale of outcrops, where clastic beds are 

interlayered with carbonate beds. This layered structure exerts a strong influence on groundwater flow 

(DOE 1997b). 

3.3.5 Ecological Resources 

 The ORR consists of diverse habitats and supports a rich variety of flora and fauna. Vegetation is 

characteristic of that found in the intermountain regions of central and southern Appalachia. The Y-12 Complex 

is covered in mowed grass, concrete, gravel, asphalt, and industrial structures. Thus, the site does not have 

unique habitats or a wide diversity of flora or fauna. Upper East Fork Poplar Creek lacks riparian vegetation 

because much of the stream is channelized and maintained. Lake Reality is a 2.5-acre, plastic-lined, 

flat-bottomed settling and spill control structure located near the east end of the facility on East Fork Poplar 

Creek. 
01-217(doc)/093002 3-7

 There are no federally protected threatened or endangered species known on the Y-12 Complex. 

However, the U.S. Fish and Wildlife Service (FWS) notes that the federally listed endangered speciesthe 

gray bat (Myotis grisescens), the Indiana bat (Myotis sodalis), and the pink mucket (Lampsilis abrupta)are 

known from, or have the potential to occur within, the project impact areas on the ORR. A Biological 

Assessment has been prepared covering these three species for the ORR (see Chapter 7). Although surveys for 

protected species are not comprehensive enough to rule out all possible federal- or state-listed vertebrates, the 

likelihood of finding such species seems very low (DOE 1998a). 

 There is a small wetland (0.45 acre) in a small, wooded area between New Hope Cemetery and Bear 

Creek Road. 

3.3.6 Socioeconomics and Environmental Justice 

 The Y-12 Complex is one of three sites located on the DOE ORR, which includes portions of both 

Anderson and Roane counties in Tennessee. This region also includes the city of Oak Ridge, which provides 

a substantial portion of the work force for the three facilities. To generate the most conservative estimates of 

potential impact, the ROI includes only these two counties. Actual impacts are likely to be distributed over a 

wider area, since Anderson County is also part of the metropolitan statistical area for the much larger city of 

Knoxville and draws commuters from at least 12 counties in eastern Tennessee.1

 Table 3.2 summarizes population, per capita income, and total personal income from 1999 (U.S. Bureau of 

Economic Analysis 2002a). Total personal income was more than $2.8 billion. Wage and salary employment for 

the region was 60, 311 in 2000 (U.S. Bureau of Economic Analysis 2002b). The Scarboro Community, which 

borders the fenceline of the plant’s northern boundary, is predominantly an African-American community. 

Table 3.2. Population and income in the Y-12 National Security Complex Region 

of Influence for Roane and Anderson Counties for 1999 

Region/variable Roane County Anderson County 

Population 50,008 71,004 

Per capita personal income ($) 21,728 25,548 

Total personal income (million $) 1,087 1,788 

3.3.7 Land Use 

 The Y-12 Complex is an industrial site that has been in operation since World War II. The residential 

portion of Oak Ridge forms much of the northern boundary to the site, and the Tennessee Valley Authority’s 

(TVA’s) Melton Hill Reservoir and the Clinch River are located to the south and west. Recreational uses of 

the surrounding area include fishing, boating, hunting, swimming, and camping. Several recreational areas are 

within 8 km (5 miles) of the site. 

3.3.8 Infrastructure 

 Sanitary wastewater from the Y-12 Complex is discharged to the city of Oak Ridge publicly owned 

treatment works under an industrial and commercial wastewater discharge permit. Sanitary sewer radiological 

sample results at the Y-12 Complex are routinely reviewed to determine compliance with DOE Order 500.5, 

“Radiological Protection of the Public and the Environment.” No radiological parameter that is monitored 

(including uranium) has exceeded a DCG (ORNL 1998). Typically, sample results indicate the Y-12 Complex 

 

1

Commuting data taken from Oak Ridge Chamber of Commerce website, www.orcc.org/labor.html. 
01-217(doc)/093002 3-8

radiological discharges are three orders of magnitude below their respective DCGs (ORNL 1998). During 

2000, the wastewater flow averaged about 670,000 gal/day (ORNL 2001). 

3.3.9 Cultural Resources 

 Native American occupation of the Oak Ridge area began about 12,000 years ago. European settlement 

began in the 18th century. Much of the current Y-12 Complex was farmed before World War II, when the site 

was secured by the federal government as part of the Manhattan Project. A cultural resources survey 

conducted in February 1995 identified an historic district with 92 contributing structures and 53 

noncontributing structures and 4 structures not contiguous with the historic district that are eligible for 

inclusion in the National Register of Historic Places (NRHP) (Sousa et al. 2001). 

3.4 EAST TENNESSEE TECHNOLOGY PARK 

 ETTP, formerly known both as the Oak Ridge Gaseous Diffusion Plant and as the Oak Ridge K-25 Site, 

is located in Roane County, Tennessee, and is one of three large facilities on the ORR. The site is located on a 

level, 1500-acre tract of land near the confluence of Poplar Creek and the Clinch River. ETTP is 

approximately 56 km (35 miles) west of Knoxville and approximately 13 km (8 miles) southwest of the city 

of Oak Ridge. 

3.4.1 Human Health 

 The calculated radiation doses to maximally exposed off-site individuals from airborne releases from all 

sources on the ORR were 0.40 mrem (ORNL 2001). The collective radiological dose from airborne 

radionuclide emissions to the site ROI health risk population was 43 person-rem (DOE 1997a). 

3.4.2 Climate and Air Quality 

 The climate of eastern Tennessee may be broadly classified as humid continental, although it is very near 

the region of temperate continental climate to the north. The Cumberland Mountains/Plateau to the northwest 

and the Great Smoky Mountains to the southeast influence the patterns of temperature and precipitation over 

the region, with cooler temperatures and greater precipitation generally occurring at the higher elevations. The 

average annual temperature in Oak Ridge, based on a 30-year period from 1961 to 1990, is 56.6°F and 

precipitation is 136.7 cm (53.8 in.) per year. Precipitation is fairly evenly distributed most of the year. The 

average wind speed is approximately 4 mph (at 10 m above the ground), and the highest wind speed, 79 mph, 

was associated with a tornado in Bear Creek Valley during the afternoon of February 21, 1993. Prevailing 

wind directions are from the northeast and southwest, reflecting the channeling of winds parallel to the ridges 

and valleys in the area. 

 Roane County and all surrounding counties are in attainment for NAAQS criteria pollutants. The nearest 

nonattainment area is in Polk County, about 72 km (45 miles) south of ETTP. Air quality in the region is 

generally good. The ozone standard is occasionally exceeded in Knoxville; however, Knox County is in 

attainment of the ozone standard. 

 The PSD Class I area nearest to ETTP is the Great Smoky Mountains National Park, 56 km (35 miles) 

south of the facility. The Joyce Kilmer Wilderness Area, which is also a Class I area, is just south of the 

western end of the Great Smoky Mountains National Park. The median visibility range at the park is 39 km 

(24 miles), with a summer median of 19 km (12 miles). 
01-217(doc)/093002 3-9

3.4.3 Water Resources 

Surface Water

 ETTP is directly adjacent to the Clinch River along the northwest boundary of the ORR. Poplar Creek is 

a moderately wide (30- to 70-ft) stream that enters the north side of ETTP about 0.5 km (0.3 mile) 

downstream of the confluence of the east and west forks of Poplar Creek. The lower reach of Poplar Creek 

meanders sharply along the southwest side of ETTP and enters the Clinch River. 

 TVA performed an analysis of floods on the Clinch River and Poplar Creek. TVA concluded that most of 

ETTP is above the probable maximum flood level. The only facilities identified at risk during major floods 

were the K-25 power plant and the pumping station for ETTP’s water filtration plant. The source of flooding 

at ETTP would be backwater from the Clinch River near the confluence of Poplar Creek. All proposed 

storage locations are above the 100-year flood level. 

Groundwater

 Groundwater occurs at ETTP in both the unconsolidated overburden and underlying bedrock as a single, 

unconfined water table aquifer. With few exceptions, the water table occurs in the overburden overlying 

bedrock with the saturated overburden ranging up to 21 m (70 ft). In general, the water table is encountered 

within several feet of the surface, adjacent to major water features and in incised ravines. 

 Groundwater flows in bedrock are controlled by hydraulic gradients, fracture networks, and karst 

solution features. Typically, bedrock flowpaths tend to follow geologic strike. Karst features are present in 

bedrock at ETTP, but conduit-dominated flow has been confirmed only in portions underlain by Knox 

carbonate along Blackoak Ridge. 

 The nearest domestic water supply wells are located approximately 3 km (2 miles) southwest of ETTP on 

the opposite side of the Clinch River. It is unlikely that these wells could be affected by groundwater 

flowpaths from ETTP, should such a pathway exist. Additionally, there are nearly a dozen domestic wells 

along Blackoak Ridge, west of the DOE boundary. Four of these wells were sampled recently and found to be 

uncontaminated. 

3.4.4 Geology and Soils 

 In general, ETTP is underlain by bedrock that can be broadly characterized as carbonate (Chickamauga 

and Knox Group) or clastic (Rome Formation). The carbonates underlie the majority of the main plant area. 

The eastern part of the site is underlain by clastic bedrock of the Cambrian Rome Formation. The structural 

geology of ETTP is complex; the principal faults in the area include the White Oak Fault, a major regional 

thrust fault located along the south side of the ETTP. Seismic activity in the southern Appalachian Mountains 

that has affected the site area has been recorded 45 times since 1800. The probability of future seismic 

damage is moderate. 

3.4.5 Ecological Resources 

 The ORR consists of diverse habitats and supports a rich variety of flora and fauna. Vegetation is 

characteristic of that found in the intermountain regions of central and southern Appalachia. Vegetation 

around the buildings within the fenced area on the ETTP proper is a mixture of mowed grasses with a few 

shrubs and trees. Many of the shrubs and trees have been planted as landscaping, although some native 

species are found in unmowed areas around ponds and waterways. 
01-217(doc)/093002 3-10

 Since ETTP proper is planted primarily in nonnative grasses, it has very little habitat available for native 

animals except along Poplar Creek. The majority of animal species found within ETTP’s boundaries are 

species that adapt well to disturbance and the presence of humans. There are no known federally protected 

plant or animal species on the ETTP site, although suitable habitat exists for the endangered bald eagle on 

Melton Hill Reservoir and the Clinch River. Sixteen plant species and 18 animal species that are considered 

rare, threatened, or endangered by the state of Tennessee are found on or near ETTP. However, the FWS 

notes that the federally listed endangered speciesthe gray bat (Myotis grisescens), the Indiana bat (Myotis 

sodalis), and the pink mucket (Lampsilis abrupta)are known from, or have the potential to occur within, the 

project impact areas on the ORR. 

 The Lower Poplar Creek Rookery is the only environmentally sensitive area within ETTP. It is 

approximately 6.5 acres and is located on the north bank of Poplar Creek in the middle of the plant site. 

3.4.6 Socioeconomics and Environmental Justice 

 Like the Y-12 Complex, ETTP is located on the DOE ORR, and the region of impact is identical to the ROI 

for the Y-12 Complex alternative. See Section 3.3.6 for summaries of population, income, and employment 

within the region. ETTP is in proximity to low-income populations on Blair Road (which runs behind the park). 

3.4.7 Land Use 

 The approximately 1500 acres of land in the ETTP site are industrial. The site formerly produced 

enriched uranium using a gaseous diffusion process. Portions of the site have been used for waste storage 

since the facility ceased enrichment operations. Efforts are under way to convert existing buildings into 

productive use through reindustrialization. 

3.4.8 Infrastructure 

 Treatment of domestic wastewater is performed at the ETTP Sewage Treatment Plant, which operates 

within a National Pollutant Discharge Elimination System permit. The operating capacity of the treatment 

plant is about 600,000 gal/day with a current load of half that capacity (DOE 1997c). The ETTP water 

treatment plant is currently producing from 800,000 gal/day to 1.4 mgd of potable water. Capacity of the 

system is roughly three times the current use. Highways in the area include State Routes 95 and 58. 

3.4.9 Cultural Resources 

 The K-25 Site was established as part of the Manhattan Project to develop and produce HEU for use in 

nuclear weapons. The Manhattan Project created the first industrial process for separating uranium isotopes 

by the gaseous diffusion method. A summer 1994 cultural resources survey of the former K-25 Site identified 

a Main Plant Historic District with 120 contributing structures and 37 noncontributing structures, and 

11 structures that are not contiguous with the historic district, that are eligible for inclusion on the NRHP 

(Sousa et al. 2001). 

3.5 SAVANNAH RIVER SITE 

 SRS is located in southwestern South Carolina adjacent to the Savannah River, which forms the 

boundary between South Carolina and Georgia. SRS encompasses approximately 800 km2 (300 mile2

) within 

the Atlantic Coastal Plain physiographic province. SRS is approximately 40 km (25 miles) southeast of 

Augusta, Georgia, and 32 km (20 miles) south of Aiken, South Carolina. The site was constructed during the 
01-217(doc)/093002 3-11

early 1950s to produce the basic materials used in the fabrication of nuclear weapons, primarily tritium and 

239Pu, in support of the nation’s defense programs. 

3.5.1 Human Health 

 The ROI population used in the Final Waste Management programmatic environmental impact statement 

(PEIS) to determine human health risk was 620,618 based on 1990 census data (DOC 1991). The radiation 

dose to a maximally exposed individual was 0.04 mrem for airborne radionuclides and 0.140 mrem for liquid 

releases (SRS 2001). In 2000, the collective radiological dose from airborne radionuclide emissions to the site 

ROI health risk population was 2.3 person rem (SRS 2001). 

 Releases of radioactivity to the environment from SRS account for less than 0.1% of the total annual 

average environmental radiation dose to individuals within 80 km (50 miles) of SRS (Arnett, Karapatakis, and 

Mamatey 1994). Standard population dose analyses for air releases are based on an 80-km (50-mile) radius, 

because expected dose levels beyond that distance are very small. 

 Worker doses at SRS have consistently been well below the DOE worker exposure limits. The 

all-pathway dose standard for site workers in 2000 was 100 mrem per year per DOE Order 5400.5 (SRS 

2001). 

3.5.2 Climate and Air Quality 

 SRS and surrounding counties are classified by EPA as attainment areas for all six of the NAAQS 

criteria air pollutants. The major sources of criteria air pollutants are nine coal-burning and four fuel oilburning boilers, and the process facilities for fuel and target fabrication. Non-SRS sources of toxic air 

pollutants consist primarily of industrial installations, small manufacturing shops, and residual wood 

combustion. 

 Prevailing winds at the Bush Field Airport in 1992 are uniformly distributed, with winds from the 

west−southwest 7% of the time and from the west−northwest 6% of the time on a yearly basis. The highest 

occurrence of wind speed is 5 to 7 mph, with an annual occurrence of 35%. The annual average temperature is 

66°F, with seasonal temperatures ranging from an average summertime daily maximum of 91°F to an average 

daily minimum in January of 38°F. 

3.5.3 Water Resources 

 Major surface water resources include the Savannah River, which runs along the southwestern border of 

the site for 32 km (20 miles); on-site drainages such as Upper Three Runs, Fourmile Branch, Beaver Dam 

Creek, Pen Branch, Steel Creek, and Lower Three Runs; and numerous Carolina bays. No federally 

designated Wild and Scenic Rivers exist in the area. Groundwater wells and the Savannah River supply water 

for the site. On-site streams and the Savannah River receive treated wastewater. The 100-year floodplain does 

not encroach on existing facilities. 

 Major groundwater units are the interbedded sandy clays and clayey sands of the coastal plain sediments. 

The sandy beds generally form aquifers, and the clay rich beds act as aquitards. No sole source aquifers occur 

in the area. 

 In 2000, 24,806 radiological analyses and 125,924 non-radiological analyses were performed on 

groundwater samples collected from 1,188 monitoring wells. Various groundwater contaminants with 

estimated plumes have been identified in the A-Area and M-Area; C-Area; D-Area and TNX; the general 
01-217(doc)/093002 3-12

separations and waste management areas; K-Area; L-Area and chemicals, metals, and pesticides (CMP) pits; 

N-Area; and P-Area (SRS 2001). 

3.5.4 Geology and Soils 

 The topography of the area is generally flat, with some rolling hills and knolls. Elevations range 

from 26 to 130 m (85 to 427 ft) above mean sea level. Major rock units include, from oldest to youngest, 

the crystalline basement rocks, the Dunbarton Triassic Basin, and the Atlantic Coastal Plain sediments. 

 Soils in the area are primarily sandy loams that occur on alluvial terraces of the Savannah River and on 

the Aiken Plateau. Several interbasinal faults are located in the down-faulted Dunbarton Triassic Basin. 

However, no conclusive evidence exists of recent displacement along any fault within 300 km (186 miles) of 

SRS. 

 Two major earthquakes have occurred within 300 km (186 miles) of the site. The probability of future 

seismic damage is moderate. 

3.5.5 Ecological Resources 

 Major plant communities include cypress-gum and lowland hardwood swamps, sandhills, and old 

agricultural fields. Ninety percent of the SRS land cover is upland pine forest and bottomland hardwood 

forest. Important terrestrial habitats include old fields, sandhills, upland pine forests, bottomland and upland 

hardwood forests, and swamp forests. Longleaf pine/wiregrass communities support sensitive species, such 

as the red-cockaded woodpecker. SRS was designated a National Environmental Research Park (NERP) in 

1972. 

 SRS contains approximately 43,000 acres of wetlands (20% of SRS), consisting of emergent marsh, 

cypress/tupelo, bottomland hardwood, and open water. These wetlands include the Savannah River Swamp 

(about 10,000 acres). More than 200 Carolina bays are scattered throughout the SRS. 

 The site provides refuge for several federally protected endangered or threatened species of plants and 

animals, including the red-cockaded woodpecker, the bald eagle, the smooth coneflower, the woodstork, the 

short-nosed sturgeon, and the pondberry (see FWS letter dated July 16, 2002, in Chapter 7). There are another 

dozen species which are listed as of special concern. 

 The SRS is one of the most biologically diverse areas in the southeast 

(http://www.srs.gov/general/enviro/SRFS.htm; April 24, 2002). There are 60 mammal, 107 reptile and 

amphibian, 80 fish, and 174 bird species on the site. Over 1300 species of vascular plants have been collected 

at SRS (http://www.srs.gov/general/enviro/SRFS.htm; April 24, 2002). The National Marine Fisheries Service 

has listed federally protected species also (see MNFS letter to DOE dated June 28, 2002 in Chapter 7). 

3.5.6 Socioeconomics and Environmental Justice 

 The ROI for SRS includes Aiken, Barnwell, Allendale, and Bamberg counties in South Carolina and 

Burke, Columbia, Richmond, and Screven counties in Georgia. At least 90% of the states’ employees 

reside in these counties. Table 3.3 summarizes population, per capita income, and total personal income 

from 1999 (U.S. Bureau of Economic Analysis 2002a). Total personal income for this eight-county region 

was more than $11.5 billion. Total SRS site employment in 2002 is 13,800 (SRS Fact Sheet 2002). 

 The total population in the ROI in 1999 was 506,101. Population demographics include Native 

Americans at 0.2% and urban at 69.6%. Owner-occupied housing was 67.1% and renter-occupied 32.9%. 
01-217(doc)/093002 3-13

 Sensitive populations include children under 15 years old – 23.7%, women of child-bearing age (15 to 

44) – 24.3%, and adults over age 65 – 10.3%. 

Table 3.3. Population and income in the Savannah River site region of influence for 1999 

Region/variable Population 

Per capita 

personal 

income ($) 

Total personal 

income 

($ Millions) 

South Carolina 

Aiken County 135,401 18,353 3,300 

Allendale County 11,325 17,321 196 

Bamberg County 16,289 18,606 303 

Barnwell County 21,784 23,858 520 

Georgia 

Burke County 23,217 16,386 232 

Columbia County 93,312 22,931 2,140 

Richmond County 190,310 23,980 4,564 

Screven County 14,463 19,181 277 

 Three Native American groups, the Yuchi Tribal Organization, the Nubiunal Council of Muskogee 

Creek, and the Indian’s People Muskogee Tribal Town Confederacy, have expressed general concerns about 

SRS and the Central Savannah River area regarding several plant species traditionally used in tribal 

ceremonies. 

3.5.7 Land Use 

 The site occupies 198,000 acres of land, most of which serves as a forestry research center. SRS was 

designated a National Environmental Research Park (NERP) in 1972. Of the total area, approximately 

15,840 acres are developed and 182,162 are undeveloped. Of the undeveloped land, approximately 

145,400 acres are available for future site development. Land use surrounding the site is predominantly rural. 

3.5.8 Infrastructure 

 On-site wells provide an average of 1.6 million gal of water per day. On-site treatment plants receive an 

average of 0.5 million gal of sewage per day. South Carolina Gas and Electric Company and on-site 

generation provide power. The current site load is 130 MW. 

 Transportation in the area consists of local access roads (such as U.S. 278 and State Route 125) and 

major roads (such as Interstates 20 and 95). The Seaboard Coast and Southern Railroads are the primary 

providers of rail service to the SRS region, including on-site rail spurs. 

3.5.9 Cultural Resources 

 Native American population in the area began about 11,000 years ago. More than 800 prehistoric sites 

and about 400 historic sites have been identified at the SRS. Fifty-five sites have been determined eligible for 

the NRHP. 
01-217(doc)/093002 3-14

3.6 IDAHO NATIONAL ENGINEERING AND ENVIRONMENTAL LABORATORY 

 INEEL is a 2305-km2

 (890-mile2) DOE research facility located in southeastern Idaho. The physical and 

biological environment of INEEL and the region has been described extensively. 

3.6.1 Human Health 

 Radiation in southeast Idaho in the vicinity of the INEEL consists of natural background radiation from 

cosmic, terrestrial, and internal body sources; manmade nuclear fallout; and radiation from consumer and 

industrial products. In 1997, INEEL activities added 0.03 mrem, 0.008% of background, to the maximally 

exposed individual’s total EDE. These sources result in an estimated total EDE of 362 mrem/year to an 

average member of the public residing in southeastern Idaho (DOE 1998b). 

3.6.2 Climate and Air Quality 

 The area surrounding INEEL is classified under the Clean Air Act of 1970 as a PSD Class II area, an area 

with reasonable or moderately good air quality that allows moderate industrial growth. To the west, about 19 km 

(12 miles), is the Craters of the Moon National Monument and Wilderness Area, classified as a PSD Class I 

Area. 

 The climate of INEEL has been studied extensively for many years. The National Oceanic and 

Atmospheric Administration (NOAA) operates 26 monitoring stations on or near INEEL. Detailed 

climatological information has been published by NOAA. Severe weather on INEEL consists of 

thunderstorms and funnel clouds. On average, two to three thunderstorms occur during each of the summer 

months. Small hail may accompany the thunderstorms, but hail damage has not occurred at INEEL. NOAA 

records indicate five funnel clouds and no tornadoes on INEEL since 1950. 

3.6.3 Water Resources 

 Naturally occurring surface waters at the INEEL consist of three intermittent streams, the Big Lost River, 

Little Lost River, and Birch Creek. These streams drain adjacent mountain valleys and flow onto INEEL. All 

of the streams infiltrate, disappearing in the underlying aquifer. No surface water flows leave the INEEL. 

 Studies have shown that the projected 100-year flood of the Big Lost River on the INEEL would be 

adequately contained by the river channel with the utilization of an existing diversion area constructed near 

the point at which the river enters the INEEL (Bennett 1986). The flood control system was constructed on 

the Big Lost River in 1958. The system consists of a dam that diverts water into a series of spreading areas. In 

1984, the dikes were raised so that the flood control system could contain a flood with an average return 

period of 300 years or more. In recent years, all of the water in the Big Lost River has been stored or diverted 

for irrigation upstream of the INEEL. 

 The Snake River Plain Aquifer is the principal groundwater feature in southeastern Idaho, underlying 

nearly all of the plain. Because groundwater supplies more than 50% of the drinking water consumed within 

the eastern Snake River Plain and an alternative drinking water source or combination of sources is not 

available, the EPA designated the Snake River Plain Aquifer a sole-source aquifer in 1991 (56 FR 50634, 

1991). Aquifer depths within the INEEL range from 61 to 274 m (200 to 900 ft). This aquifer discharges 

approximately 8.0 billion m3 (6.5 million acre-ft) of water annually through springs and irrigation wells. 

Discharges from the springs contribute substantially to the flow of the Snake River. 
01-217(doc)/093002 3-15

3.6.4 Geology and Soils 

 The INEEL is on the Snake River Plain and is bordered on the north and northeast by the Lost River, 

Lemhi, and Bitterroot mountain ranges. Elevations on the INEEL range from 1585 m (5200 ft) in the 

northeast, to 1448 m (4750 ft) in the southwest. 

 The surface of the INEEL is relatively flat and composed of basaltic lava flows interbedded with 

sedimentary strata. A 30-ft layer of mixed sediments covers a deeper layer of underlying basalt. A 

grayish-brown gravelly silt loam, derived from loess mixed with alluvium from the Big Lost River, makes up 

the topsoil. Gravels occupy 50% to 75% of the surface area, and the erosion hazard is slight. The soil is 

moderately permeable, well drained, and generally nonalkaline. However, alkalinity increases with depth, and 

hardpan zones may occur at depths from 50 cm (20 in.) to 7 m (20 ft). 

 The INEEL is in a seismic zone 2B, defined by the Uniform Building Code (UBC) as an area where 

destructive earthquakes may occur. Extensive seismic evaluations have been performed for the INEEL. 

Numerous small earthquakes have been recorded in the region. Epicenters of most earthquakes have been in 

the surrounding mountains. In October 1983, a large earthquake (Richter magnitude 7.3) occurred 24 km 

(15 miles) northwest of Mackay, Idaho. 

3.6.5 Ecological Resources 

 Flora and fauna of the INEEL have been surveyed and studied since the late 1950s. No substantial 

impacts caused by operation of INEEL facilities have been identified. Biological resources at the INEEL, in 

general, and Idaho Chemical Processing Plant (ICPP), in particular, are extensively described in 

DOE/EA-0306 (DOE 1991). 

 No species on the federal list of threatened or endangered species are known to permanently reside on the 

INEEL. No unique habitats are located on the INEEL. 

 No known endangered or threatened species nests in or inhabits the INEEL. However, the bald eagle 

(Haliaeetus leucocephalus), a federally-protected species, has been observed wintering on or near the INEEL 

(Martin 1995). The FWS, in addition, lists the Canada lynx, gray wolf, bull trout, Bliss Rapids snail, and the 

Ute ladies-tresses as species that may occur in the area (see FWS letter to DOE dated July 1, 2002, in 

Chapter 7). Several additional species are on the state of Idaho watch list, including the bobcat, ferruginous 

hawk, long-billed curlew, and merlin. A list of the most common species of animals found at the INEEL can 

be found in DOE (1998b). 

3.6.6 Socioeconomics and Environmental Justice 

 The ROI for INEEL includes seven Idaho counties (see Table 3.4). Table 3.4 summarizes population, 

per capita income, and total personal income from 1999 (U.S. Bureau of Economic Analysis 2002a). Total 

population in the ROI in 1999 was 247,224, and total personal income for this seven-county region was 

almost $4.9 billion. The average per capita personal income for the ROI was $19,069. 

Table 3.4. Population and income in the INEEL site region of influence for 1999 

Region/variable Population 

Per capita 

personal 

income ($) 

Total personal 

income 

($ Millions) 

Idaho 

Bannock County 74,881 20,252 1,516 
01-217(doc)/093002 3-16

Bingham County 42,127 17,321 742 

Bonnevile County 81,536 22,408 1,827 

Butte County 3,012 19,376 58 

Clark County 913 22,022 20 

Jefferson County 19,949 16,947 338 

Madison County 24,806 14,861 368 

INEEL = Idaho National Engineering and Environmental Laboratory. 

 Employment at the INEEL rose steadily since the mid-1980s to a yearly average of approximately 

12,387 [fiscal year (FY) 91]. However, employment in 1997 was 7,828 (DOE 2000) and is projected to 

decline to around 7,250 by 2004. 

 The majority of employees reside in Bonneville and Bingham counties east of INEEL. In FY 1991, an 

average of 8,500 employees commuted daily to INEEL facilities, primarily using the INEEL bus transit 

system. 

 The population surrounding INEEL is 7% minority and 14% low income (DOE 2000). 

3.6.7 Land Use 

 The INEEL occupies 2305 km2

 (890 mile2, 569,600 acres) in the southeastern Idaho desert. In addition to 

activities related to nuclear energy, the area has been designated as an NERP. 

 Developed facilities at the INEEL cover only a small portion (approximately 2%) of the total land area. 

Of the 550,000 acres of undeveloped land, approximately 330,000 acres are used for controlled grazing of 

cattle and sheep. The available area for future site development is approximately 22,330 acres. 

3.6.8 Infrastructure 

 On-site wells and storage tanks provide an average of 5.242 million gal of water per day. On-site 

treatment facilities treat an average of 0.254 million gal of sewage per day. The Idaho Power Company 

supplies power, and the current load is 41.8 MW. 

 Transportation in the area consists of local access roads such as U.S. Routes 20 and 26. Interstate 

15 passes to the east of the site and intersects Interstate 84 to the south. Rail lines, including an on-site spur 

connecting to the Union Pacific Railroad, also serve the region. 

3.6.9 Cultural Resources 

 Several archeological and cultural resource surveys have been conducted in association with 

development (Reed et al. 1987). The only important site identified by these surveys was an historic homestead 

(Smithsonian Site # 10-BT-269). The site consists of a dugout shelter and associated historic debris 

characteristic of an occupation period between 1900 and 1930. The site is a considerable distance from any 

activity related to the proposed action and would not be affected by these efforts. 

 In the event that paleontological or cultural resources were encountered during subsurface activities, 

work would stop until a qualified professional assessed the significance of the resources. 
01-217(doc)/093002 4-1

4. ENVIRONMENTAL CONSEQUENCES 

 The first part of this chapter (Section 4.1) establishes the methodology used to calculate public and 

worker risk under both routine operations and various accident scenarios. Uranium source terms, assumed 

accident frequencies, and other parameters needed to model facility accident scenarios are defined in 

Appendix A. The transportation analysis is described in Appendix B. Ecological and human health 

methodology and detailed analysis are presented in Appendix C. Detailed results of the modeling are 

presented in tables showing all storage alternatives and disposition options under all credible accident 

scenarios. Section 4.2 addresses environmental consequences common to all alternatives and options. 

Sections 4.3 through 4.9 summarize the environmental consequences for each storage alternative. Section 

4.10 summarizes the environmental consequences for each disposition option. Section 4.11 provides a 

summary comparing the impacts of each storage alternative coupled with disposition options, and Section 

4.12 addresses cumulative impacts. 

4.1 METHODS 

 This section describes environmental and socioeconomic impact methods and risk to the public, a 

co-located worker, and a facility worker due to continued storage of uranium materials at their current 

locations (No Action alternative), and receipt, interim storage, and disposition of these materials at other sites 

as described in Chapter 2. Risks are evaluated for routine operations and nonroutine (accident) conditions. 

 Routine or normal operations include construction of any new storage facilities, upgrades to existing 

facilities, and maintenance and surveillance. Construction costs and the number of permanent workers 

(maintenance and surveillance) are estimated based on the space needed for uranium materials storage and 

disposition. The number of construction workers is estimated assuming that half the construction costs are labor 

and each worker earns $20,000 per year. The permanent labor force to monitor storage in various warehousing 

locations is assumed to be one worker/18,000 ft2

 of storage space. Land for new building construction is assumed 

to be 25% greater than floor space needs, and single-story buildings are assumed to be used. 

 In addition, various disposition options are considered. These include commercial processing and 

domestic sales of the entire inventory, disposition of limited quantities (50 MTU) at research facilities, 

disposition of 2,500 MTU to other government agencies, and foreign sales of 4,050 MTU. Bounding analyses 

are provided for these options; disposition options should be considered a possible component of each interim 

storage alternative. 

 The number of parameters that could affect the off-site human health and environmental consequences of 

a catastrophic release is vast. For example, the assumptions regarding wind speed, wind direction, height of 

plume, the amount of uranium affected, the amount of dilution, and the area of deposition could vary in some 

cases by orders of magnitude. Because of the complexity involved with multiple varying assumptions, 

worst-case assumptions for off-site transport and human health dose at each potential storage location are 

employed according to the rationale described in this section. 

 For assessment of environmental consequences, the worst-case accident is assumed to be a seismic event 

and resulting fire that breaches a large number of containers and results in a plume that entrains a large 

portion of the uranium source material. It is further assumed that the plume moves directly via the shortest 

distance from the release point to a potential receptor at the facility boundary and that all of the uranium in the 

plume is respirable. Even though this scenario is considered to be extremely unlikely, it is still assumed that a 

resulting plume from a seismic event and fire would be the most likely worst-case accident to get the highest 

concentration of source material to the nearest off-site receptor (i.e., compared to a tornado). This is especially 
01-217(doc)/093002 4-2

true given the form of the majority of the uranium (e.g., oxides or other physical forms that may be more 

readily dispersible than solid forms such as ingots or recyclable pieces of metal). The hypothetical seismic/fire 

scenario also results in the worst-case exposure pathway (inhalation), because uranium is predominately an 

alpha-particle emitter. This is addressed in greater detail in Appendix C. 

 Uranium released from primary containers under the accident scenario described above and modeled 

later in this section can be deposited on surface soils and be subject to movement with soil water through the 

vadose zone into groundwater. The material could also be deposited directly into water bodies or move from 

the surface soil overland into water bodies. As described below, any exposure pathway to human receptors via 

soil, groundwater, or surface water would be relatively unimportant compared to the inhalation pathway to the 

nearest off-site receptor. 

 Upon deposition of the uranium entrained in the plume, the fate and transport of uranium is a function of the 

environmental site characteristics and the physical/chemical properties of uranium. Such properties include 

uranium’s solubility in water, the tendency of uranium to transform or degrade (e.g., 238U has a half-life of 

4.5 billion years), and chemical affinity for solids or organic matter (described as a partitioning coefficient Kd). An 

average Kd value for uranium is 15 L/kg, although the possible range of Kds can vary widely (Sheppard and 

Thibault 1990). Contaminants with small Kds will be leached more effectively into the groundwater (i.e., be more 

mobile) than those with larger Kds. For example, uranium is much less mobile than 99Tc, which has a Kd of 0.1 

L/kg. 

 In addition, uranium can be transformed to other oxidation states in soil, further reducing its mobility. If 

organic matter, clay, and hydrous oxides are present in the receiving soils, adsorption of the uranium metal 

may occur onto these materials, also reducing the uranium’s mobility and toxicity. The soils described in 

Chapter 3 are generally rich in clay and organic matter and would be effective in retarding the mobility of 

uranium. Further, even if resuspended and available to an off-site receptor via inhalation, uranium 

concentrations would be diluted compared to the concentrations available in the original plume. 

 Each of the potential storage locations described in Chapter 3 is located within water-rich environments 

(i.e., each site is near major rivers). Therefore, even though the previous paragraph supports minimal mobility 

of uranium in the soil, a fraction of the uranium could enter the water system upon any accidental release, 

especially by direct deposition from the plume. The mobility of uranium deposited onto water depends upon 

the type of complex (cationic or anionic) formed as a result of the physical processes acting on the uranium. 

Cationic species tend to adsorb to soil, and anionic species tend to move with water. Uranium released in a 

fire would be oxidized (be cationic) and would tend to adsorb to the soil particles entrained in the water. As 

with uranium deposited upon the soil, the doses to a receptor in contact with uranium in water or associated 

sediment would be less important than those of the receptor exposed to the initial plume. 

 Once in the off-site environment, the source material is assumed to intercept a human receptor. In general, 

uranium compounds are not easily absorbed across the gastrointestinal tract. Soluble uranium compounds 

demonstrate the best absorption, but this absorption is still low. Uranium is known to be a chemical toxicant, 

exposure to which leads to nephritis in the kidney. Uranium can also induce cancer when organs and tissues are 

exposed to alpha particles emitted from decaying uranium atoms. While other energetic emissions from 

radioactive decay of atoms, such as beta particles and gamma rays, also cause molecular ionization, these 

radiations do not produce the density of ionizations that alpha particles do when inside the human body. The 

ionization events cause biological damage, which is believed to be responsible for inducing cells to become 

cancerous. The types of uranium (e.g., natural, enriched, and depleted) under consideration are important because 

different types of uranium have different specific activities (the amount of radioactivity per unit mass). The 

difference between natural, low-enriched, and depleted uranium is defined by the percent 235U mass enrichment. 

As the 235U enrichment increases, the specific activity of the mixture increases. The different quantities of source 

material and their associated activities are considered in the quantitative assessment that follows. 
01-217(doc)/093002 4-3

 The potential adverse effects of the uranium source material in environmental media, such as 

groundwater, surface water, soil, or sediment, are relatively unimportant when compared to a release of the 

source material into the air from various accident scenarios. Therefore, the quantitative assessment provided 

in this section will address the inhalation exposure pathway and the resulting calculated dose from both 

routine operations and various accident scenarios. 

 For risks due to transportation, the excess latent cancer fatalities (LCFs) were computed from Table B.4 

by adding the LCFs from both incident-free and accident situations for both truck only and truck plus rail 

transport. This shows the total LCFs to the public from all transportation sources. The average individual 

consequences and traffic fatalities are also totals computed from Appendix B tables. 

4.2 CONSEQUENCES COMMON TO ALL ALTERNATIVES 

 Regardless of the alternative, there are some actions common to all, and the resulting consequences are 

the same for all alternatives. For each alternative, including No Action, there will be routine handling and 

monitoring of the uranium inventory. In instances where packaging needs to be upgraded, the materials would 

be overpacked or otherwise repackaged to meet safety requirements. However, it is assumed that for both the 

centralized and consolidated storage alternatives that require some or all of the uranium materials to be 

shipped, a much more substantial repackaging effort would be required than for No Action. Both acute and 

chronic consequences and risk due to accidents that may occur during container handling activities are 

negligible under all alternatives. 

 During interim storage of uranium materials, workers could be exposed to direct radiation from surface 

contamination on the storage containers. However, the containers have been checked and would be 

overpacked if this is deemed necessary. Therefore, worker exposure due to routine operations associated with 

surveillance and maintenance of stored materials is expected to be less than detectable levels. Normal 

operations under any alternative are expected to cause negligible acute and chronic risks from airborne 

uranium. 

 In addition to surface contamination, non-contact radiation dose from the stored uranium materials can 

be expected. Dose rates from any single stored container are no more than 3 to 4 mrem/h. The dose rate at a 

distance of 0.3 m (1 ft) from a container is ~1 mrem/h, and the dose rate at a distance of 6 m (20 ft) is 

<0.05 mrem/h (approximately the same as normal background radiation doses) (DOE 1999). These dose rates 

are not affected by stacking the containers, because the containers and the materials themselves provide 

substantial shielding. For worker and collocated worker exposure, the shielding was assumed to cancel out the 

effect of adding additional containers. However, when calculating doses to the public, the more conservative 

assumption of no shielding was used. These dose rates are considered negligible to any receptor (facility 

worker, co-located worker, or public). 

 For all the action alternatives, small quantities of uranium materials would be shipped to and from 

university and other sites. The consequences of small quantity (less than 0.1 MTU) shipments are 

inconsequential, would not be a substantial cumulative impact when added to the 14,200 MTU under 

consideration, and would vary little from alternative to alternative. The impacts associated with the various 

disposition options are common to all alternatives. 

 Regarding Intentional Destructive Acts such as sabotage or terrorism, there are no known or reasonably 

anticipated scenarios that would result in human consequences greater than those already evaluated for fires, 

which are negligible. The types of uranium materials covered in this PEA are not considered to be reasonable 

targets for terrorists. 
01-217(doc)/093002 4-4

4.3 NO ACTION ALTERNATIVE 

 Under this alternative, the uranium currently stored at the various DOE sites, non-DOE sites, 

universities, and other commercial locations would remain at those sites. The uranium is currently in various 

container types, including 55-gal steel drums, T-hoppers, half-high boxes, and sea-land containers. 

4.3.1 Normal Operations 

 Under normal operations, land use, geology and soils, water resources, cultural resources, and the 

infrastructure remain unchanged. Air effluents associated with uranium inventory maintenance would be 

minimal and would remain the same as they are now. Because there is no new construction and there are no 

effluents from the stored uranium, plant and animal species would not be adversely affected and cultural 

resources would not be impacted. Some continued maintenance of facilities would be required, and 

monitoring and surveillance at the current sites would continue. The socioeconomic impact analysis assumes 

little or no construction activity and continued uranium monitoring by current employees. Under these 

assumptions, there is no change in expenditure or employment and, consequently, no impact. Even if 

additional workers were hired for monitoring at each potential centralized or consolidated storage site, they 

would represent a minimal increase to the large number (several hundred thousand) of wage and salary 

earners present in counties that contain the larger DOE uranium storage sites. In the absence of important 

impacts, environmental justice concerns do not arise. 

 The 3,900 MTU at the 152 locations other than the six DOE locations would remain at these sites. The 

amount at each individual site is very small and is typically associated with university or other types of 

research. No substantial environmental impacts are expected from the continued use and/or storage at these 

locations; however, these sites do not have a long-term mission for uranium storage and expect to ship 

materials back to DOE when the research work is completed. 

4.3.2 Facility Accidents 

 Acute consequences associated with facility fires and seismic events are evaluated in Appendix A and 

summarized in Table 4.1. The highest acute consequences to the public or to a co-located worker are due to a 

fire or earthquake at PORTS, with aerial dispersion of uranium materials, but is still negligible. This result is 

based on the large amount of uranium materials currently stored at PORTS (4,400 MTU or ~31% of the total 

of 14,200 MTU). Acute radiological and toxicological consequences are negligible at all other sites. 

 Human health and ecological risk are evaluated in Appendix C and summarized in Table 4.1. Accidents 

at all facilities are expected to cause negligible to low chronic risks to humans and ecological receptors. 

4.3.3 Transportation 

 There are no transportation activities associated with the No Action alternative. 

4.4 INTERIM CENTRALIZED STORAGE AT A SINGLE DOE SITE 

 This alternative involves moving all uranium materials to one of six DOE sites (INEEL, PGDP, PORTS, 

SRS, or Oak Ridge – Y-12 Complex and ETTP). The total amount to be moved depends on the amount currently 

stored at the site. Once all the materials have been moved, the total at any site is the same (14,200 MTU). 
01-217(doc)/093002 4-5

Table 4.1. Risks due to accidents for No Action alternative

Maximum 

acute risk 

Chronic 

human health risk 

Chronic 

ecological risk 

Accident 

scenario Site(s) 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

INEEL, PGDP, 

SRS, Oak Ridge, 

Max othera

Facility Negligible Negligible Negligible Negligible Negligible Negligible

fire 

PORTS Negligible Negligible Negligible Negligible Negligible Negligible

INEEL, PGDP, 

SRS, Oak Ridge, 

Max othera

Seismic Negligible Negligible Negligible Negligible Negligible Negligible

PORTS Negligible Negligible Negligible Negligible Low Low 

a

Max other represents the largest single amount at any site other than the DOE consolidated storage locations. 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site.

 

4.4.1 Normal Operations 

 Under this alternative, the amount of uranium stored at one of the six DOE sites would increase from 

current levels to 14,200 MTU, as shown in Table 4.2. The total floor space required for storage would also 

increase to ~243,000 ft2

. 

 Table 4.2. Storage requirements for interim centralized storage at a single DOE site

Assumed storage Materials to be moved 

Site 

Amount, 

103

 MTU 

Number of 

containers 

Storage 

requirement, 

ft2

Amount, 

103 MTU 

Number of 

containers 

Additional 

storage 

requirement, ft2

INEEL 1.5 639 7,000 12.7 71,195 ~236,000 

PGDP <0.1 8 100 14.1 71,821 ~243,000 

PORTS 4.4 24,765 75,000 9.8 47,069 ~168,000a

SRS 3.0 2,876 19,000 11.2 68,967 ~224,000 

Oak Ridge 1.4 6,431 25,000 12.8 65,403 ~218,000 

a

∼450,000 ft2 existing space available at PORTS. 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

MTU = metric tons of uranium. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

Additional requirements, activities, and environmental impacts are summarized in Table 4.3. 
01-217(doc)/093002 4-6

Table 4.3. Impacts for interim centralized storage at a single DOE site

Requirements Activities Environmental impacts 

Site 

Initial 

workers 

Permanent 

workers 

Estimated 

upgrades 

New 

construction 

Availability 

of space 

Air, water, 

etc. Socioeconomics 

INEEL 413 13 $16.5M Yes Unknown Minor Minor 

PGDP 425 14 $17.0M Yes Unknown Minor Minor 

PORTS 210 9 $8.4M None Yes Minimal Minimal 

SRS 393 12 $15.7M Yes Unknown Minor Minor 

Oak Ridge 383 12 $15.3M Yes Unknown Minor Minor 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

MTU = metric tons of uranium. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

 

 PORTS is the only DOE site with sufficient existing storage space to accommodate the entire uranium 

material inventory. PORTS has several large buildings with sufficient capacity to store these materials. These 

buildings were evaluated for uranium storage suitability (DOE 1999), and over 450,000 ft2

 of space is still 

available in them. Some minor work would be required to prepare the buildings, but no new construction 

would be anticipated. Under normal operations, land use, geology and soils, water resources, cultural 

resources, and the infrastructure at PORTS would remain unchanged. Air effluents associated with uranium 

inventory maintenance would be minimal and would remain the same as present. Because there is no new 

construction and there are no effluents from the stored uranium, plant and animal species would not be 

adversely affected, and cultural resources would not be impacted. 

 While existing storage space is available at this time, various potential changes at PORTS could 

eliminate some of this space. Therefore, it is assumed that up to 125,000 ft2

 of new space could be 

constructed. Under this assumption, the upgrades cost would increase from $8.4M to $10.9M, and the number 

of construction workers from 210 to 273. Environmental impacts and socioeconomic impacts would increase 

from minimal to minor. Even with some new construction, the PORTS site would still be the least expensive 

site for this alternative. 

 DOE has not identified existing buildings at INEEL, PGDP, SRS, or Oak Ridge (either the Y-12 

Complex or ETTP) to accommodate these additional uranium materials at this time. Therefore, for analysis 

purposes, it is assumed that new storage space would have to be constructed. It is further assumed that such 

construction would occur in areas of the site that are already industrialized. This would minimize potential 

impacts to sensitive species but would permanently eliminate the habitat for existing biota on up to 7 acres 

committed to the project (for new buildings and associated landscaping). Infrastructure would be slightly 

affected, because utilities would have to be run to these new facilities. Construction would result in minor 

fugitive dust emissions and disturbance of soils. However, water resources and cultural resources are not 

expected to be affected. 

 The socioeconomic analysis assumes $8.4M in building upgrades at PORTS and from $15.3M at 

Oak Ridge to $17.0M at the PGDP for new construction (Table 4.3). The uranium materials maintenance and 

surveillance workers currently located at various existing storage locations are assumed to be replaced with a 
01-217(doc)/093002 4-7

comparable number at the single DOE storage location. Thus, additional workers would be added to the site 

payroll. 

 Minor socioeconomic impacts include less than 1% increase in regional expenditures and approximately 

1% increase in worker employment compared to the ROI during the first year (construction and transport) at 

the PGDP site; all other DOE sites have smaller increases. Permanent site employment would also increase 

less than 1%, and temporary construction-related employment would increase the site workforce during the 

first year by approximately 19% at PGDP, all other DOE sites have smaller increases. Such minor increases in 

expenditures and employment are not substantial. 

4.4.2 Facility Accidents 

 Acute consequences associated with facility fires and seismic events are evaluated in Appendix A and 

summarized in Table 4.4. Both facility fires and seismic events result in high acute toxicological 

consequences due to the potential for large quantities of uranium to become airborne in a fire. This is because 

most of the airborne source term (~ 73%) results from compounds, oxides, and other miscellaneous forms that 

are relatively more dispersible than other physical forms considered in this study. The consequences are 

similar at all sites because the total amount of material to be stored at each site is the same (14,200 MTU). 

Table 4.4. Risks due to accidents for interim centralized storage at a single DOE site 

Maximum acute risk Chronic human health risk Chronic ecological risk 

Accident 

scenario 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

Storage area fire Negligible Negligible Negligible Negligible Negligible Negligible 

Seismic Low Low Low Low Negligible Negligible 

DOE = U.S. Department of Energy. 

 Human health and ecological risk are evaluated in Appendix C and summarized in Table 4.4. 

Accidents at all facilities are expected to cause negligible to low chronic risks to humans and ecological 

receptors. In Table 4.5 the LCFs to the public are a sum of all transportation sources (incident-free and 

accidents from both truck only and truck plus rail transport). The average individual consequences and traffic 

fatalities are also totals computed from Appendix B tables. 

4.4.3 Transportation 

 The potential effects of transporting uranium materials for long-term centralized storage at a single DOE 

site are evaluated in Appendix B and summarized in Table 4.5. 

Table 4.5. Transportation effects for interim centralized storage at a single DOE site 

Destination location 

Average individual 

consequences, mrem 

Excess latent cancer 

fatalities Traffic fatalities 

INEEL 0.0059 0.024 0.017 

PGDP 0.0091 0.020 0.011 

PORTS 0.0084 0.019 0.010 

SRS 0.0109 0.029 0.012 

Oak Ridge 0.0092 0.021 0.010 
01-217(doc)/093002 4-8

DOE = U.S. Department of Energy 

INEEL = Idaho National Engineering and Environmental Laboratory 

PGDP = Paducah Gaseous Diffusion Plant 

PORTS = Portsmouth Gaseous Diffusion Plant 

SRS = Savannah River Site

4.5 INTERIM CENTRALIZED STORAGE AT A SINGLE COMMERCIAL SITE 

 This alternative involves moving all uranium materials to a single commercial site in either the eastern or 

the western United States. The total amount to be moved and stored would be 14,200 MTU. 

4.5.1 Normal Operations 

 Under this alternative, the amount of uranium stored at a commercial site is the same as the total of 

14,200 MTU. The total floor space required for storage is ∼243,000 ft2

; all would be new construction. These 

are the same total storage requirements discussed in Section 4.4.1. 

 DOE has not identified specific locations for commercial sites; however, for purposes of evaluation, a 

western or eastern site has been hypothesized as a potential alternative. Since the sites are generically 

identified, no existing buildings have been assumed to be available. This assumption produces a reasonable 

worst case in terms of impacts. Table 4.6 summarizes expected impacts from normal operations. 

Table 4.6. Impacts for interim centralized storage at a single commercial site

Requirements Activities Environmental impacts 

Site 

Initial 

workers 

Permanent 

workers 

Estimated 

upgrades 

New 

construction 

Availability 

of space 

Air, water, 

etc. Socioeconomics 

Western or 

eastern 

425 14 $17.0M Yes Unknown Minor Minor 

 At either site, the number of initial workers for the first-year construction, the number of permanent 

workers, and the costs of construction would equal or exceed those for the DOE sites considered for centralized 

storage. Approximately 7 acres of land would be required for the storage facilities, and the biota occupying this 

land would be permanently displaced and their habitat lost. It is assumed that previously developed land with no 

known cultural resources would be used. Assuming best management practices are followed during construction 

(such as use of silt fences, reseeding disturbed areas, etc.), impacts to any surface waters would be minor and 

short-term. Socioeconomic impacts would be minor and include less than 1% increase in regional expenditures 

and less than 1% increase in worker employment in the region during the first-year construction phase. 

4.5.2 Facility Accidents 

 Acute consequences associated with storage area fires and seismic events are evaluated in Appendix A. 

Human health and ecological risk are evaluated in Appendix C. Both acute and chronic consequences and risk 

are the same as for centralized storage at a DOE site (see Table 4.4) because the total amount of material to be 

stored at each site is the same (14,200 MTU). 

4.5.3 Transportation 

 The potential effects of transporting uranium materials for long-term centralized storage at a single 

commercial site are evaluated in Appendix B and summarized in Table 4.7. 
01-217(doc)/093002 4-9

Table 4.7. Transportation effects for interim centralized storage at a commercial site 

Destination location 

Average individual 

consequences, 

mrem 

Excess latent cancer 

fatalities (total) 

Traffic fatalities 

(total) 

Western 0.0041 0.013 0.012 

Eastern 0.0047 0.022 0.017 

4.6 INTERIM PARTIALLY CONSOLIDATED STORAGE AT SEVERAL DOE SITES 

 This alternative involves moving uranium materials from their current storage location to the closest of 

six DOE sites (INEEL, PGDP, PORTS, SRS, Y-12 Complex, and ETTP). The total amount to be moved 

depends on the amount now stored at the sites. In addition, the total amounts to be stored at any given location 

vary depending on the number of other sites and amounts of material that are considered closest to the 

consolidation location. Unlike the two centralized alternatives in which the impacts at each site are 

independent (i.e., inputs would occur at one site), the consolidated storage alternative results in impacts at all 

six DOE sites. 

4.6.1 Normal Operations 

 Under this alternative, the existing uranium materials inventory at any one of the six DOE consolidation 

sites would remain at its respective location, and the 3,900 MTU currently at the 152 other locations would be 

transported and stored at the six DOE consolidated storage sites. The materials at each of the 152 sites would 

be stored at the geographically closest DOE consolidation site. The amount of uranium stored at each of the 

six DOE sites would increase from current levels to the levels shown in Table 4.8. The total floor space 

required for storage would also increase. 

Table 4.8. Storage requirements for interim partially consolidated storage at several DOE sites

Assumed storage Materials to be moved 

Site 

Amount, 

103

 MTU 

Number of 

containers 

Storage 

requirement, 

ft2

Amount, 

103 MTU 

Number of 

containers 

Additional 

storage 

requirement, ft2

INEEL 1.5 639 7,000 1.7 21,391 71,000 

PGDP <0.1 8 100 0.4 400 2,000 

PORTS 4.4 24,765 75,000 1.4 13,458 40,000 

SRS 3.0 2,867 19,000 <0.1 63 <100 

Oak Ridge 1.4 6,431 25,000 0.4 1,812 2,500 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

MTU = metric tons of uranium. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 
01-217(doc)/093002 4-10

 Because of the small amount of additional uranium material to be received at each consolidated storage 

site, the impacts are similar to the No Action alternative (see Section 4.3.1). Since INEEL would receive the 

most additional materials (1,700 MTU), this site serves as the worst case for normal operations impacts as 

shown in Table 4.9. 

Table 4.9. Impacts for interim partially consolidated storage at several DOE sites

Requirements Activities Environmental impacts 

Site 

Initial 

workers 

Permanent 

workers 

Estimated 

upgrades 

New 

construction 

Availability 

of space 

Air, water, 

etc. Socioeconomics 

INEEL 125 4 $5.0M Yes Unknown Minor Minimal 

PGDP 4 <1 $140K Yes Unknown Minor Minimal 

PORTS 50 3 $2.0M No Yes Negligible Minimal 

SRS 0 0 0 Yes Unknown Minimal Minimal 

Oak Ridge 4 <1 $175K Yes Unknown Minimal Minimal 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

K = thousand dollars. 

M = million dollars. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

 INEEL would have the largest construction cost, most workers, and 2 acres of land permanently 

committed to new storage space. Environmental impacts are minor. Impacts for the other consolidation sites 

would be minor or minimal. The impacts at PORTS would be negligible, because there would be no new 

construction at this site. 

 For this alternative the cumulative construction/upgrades cost of ∼$7.3M for all the sites should be 

considered as the total construction-related cost even though the bulk ($5.0M) would be at INEEL. 

Socioeconomic impacts would be minimal at all sites. 

4.6.2 Facility Accidents 

 Acute consequences associated with facility fires and seismic events are evaluated in Appendix A and 

summarized in Table 4.10. Both storage area fires and seismic events at PORTS can result in greater than 

negligible toxicological consequences due to the potential for large quantities of uranium to become airborne 

in a fire. This result is based on the large amount of oxides currently stored at PORTS and the relatively 

dispersible nature of these materials compared to the other physical forms considered in this study. Acute 

radiological and toxicological consequences are negligible at all other sites. 

 Human health and ecological risk are evaluated in Appendix C and summarized in Table 4.10. Accidents 

at all facilities are expected to cause negligible to low chronic risks to humans and ecological receptors. 

Accident risk is expected to occur at all six DOE sites. 
01-217(doc)/093002 4-11

Table 4.10. Risks due to accidents for interim partially consolidated storage at several DOE sites

Maximum acute risk 

Chronic human health 

risk Chronic ecological risk 

Accident 

scenario Site(s) 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

INEEL, PGDP, SRS, 

Oak Ridge 

Facility fire Negligible Negligible Negligible Negligible Negligible Negligible 

PORTS Low Low Negligible Negligible Negligible Negligible 

INEEL, PGDP, 

Oak Ridge 

Seismic Negligible Negligible Negligible Negligible Negligible Negligible 

PORTS Low Low Negligible Negligible Low Low 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

4.6.3 Transportation 

 The potential effects of transporting uranium materials for consolidated storage at several DOE sites are 

evaluated in Appendix B and summarized in Table 4.11. 

Table 4.11. Transportation effects for interim partially consolidated storage at several 

DOE sites 

Destination location 

Average individual 

consequences, 

mrem 

Excess latent cancer 

fatalities (total) 

Traffic fatalities 

(total) 

All 0.0016 0.003 0.005 

DOE = U.S. Department of Energy. 

 These effects represent total effects for transporting materials to all six potential DOE storage locations. 

The effects are less than those for the centralized storage alternatives because materials are transported to the 

closest site, thus minimizing transport miles. 

4.7 INTERIM PARTIALLY CONSOLIDATED STORAGE AT TWO DOE SITES 

 This alternative involves moving uranium materials from their current storage location to the closest of 

two DOE sites (INEEL or PORTS). The total amount to be moved depends on the amount now stored at the 

sites. In addition, the total amounts to be stored at any given location vary depending on the number of other 

sites and amounts of materials that are considered closest to the consolidation location. 

4.7.1 Normal Operations 

 Under this alternative, the uranium materials stored at the two DOE sites would increase from current 

levels to the levels shown in Table 4.12. The total floor space required for storage would also increase at both 

sites. 
01-217(doc)/093002 4-12

Table 4.12. Storage requirements for interim partially consolidated storage at two DOE sites

Assumed storage Materials to be moved 

Site 

Amount, 

103

 MTU 

Number of 

containers 

Storage 

requirement, ft2

Amount, 

103 MTU 

Number of 

containers 

Additional 

storage 

requirement, ft2

INEEL 1.5 639 7,000 1.7 21,490 72,000 

PORTS 4.4 24,765 75,000 6.6 24,940 89,000 

DOE = U.S. Department of Energy 

INEEL = Idaho National Engineering and Environmental Laboratory 

MTU = metric tons of uranium 

PORTS = Portsmouth Gaseous Diffusion Plant 

 Additional requirements, activities, and environmental impacts are summarized in Table 4.13. 

 For this alternative, the cumulative construction/upgrades cost of $9.5M should be considered as the 

construction-related cost. At INEEL, because the amount of additional material to be stored is the same as that 

discussed in Section 4.6.1, the environmental impacts from normal operations would also be the same. For the 

PORTS site, even though there would be up to 111 workers during the first year for building upgrades, upgrade 

activities do not require additional land and habitat, nor do they result in large emissions to air and water. Thus, 

environmental impacts at PORTS would tend to be negligible. Because the regional economy and workforce 

at PORTS are smaller than for INEEL, socioeconomic effects are slightly larger but are still minor with 

approximately 2.4% increase in regional expenditures and 5% increase in construction-related employment. 

Table 4.13. Impacts for interim partially consolidated storage at two DOE sites

Requirements Activities Environmental impacts 

Site 

Initial 

workers 

Permanent 

workers 

Estimated 

upgrades 

New 

construction 

Availability 

of space 

Air, water, 

etc. Socioeconomics 

INEEL 125 4 $5.0M Yes Unknown Minor Minimal 

PORTS 111 5 $4.5M No Yes Negligible Minor 

DOE = U.S. Department of Energy 

INEEL = Idaho National Engineering and Environmental Laboratory 

PORTS = Portsmouth Gaseous Diffusion Plant 

4.7.2 Facility Accidents 

 Acute consequences associated with facility fires and seismic events are evaluated in Appendix A and 

summarized in Table 4.14. The seismic event at PORTS can result in low toxicological consequences due to 

the potential for large quantities of uranium to become airborne in a fire. This is because most of the airborne 

source term (~ 90%) results from compounds and oxides that are relatively more dispersible than other 

physical forms considered in this study. Radiological and toxicological consequences are negligible at 

INEEL. 
01-217(doc)/093002 4-13

Table 4.14. Risks due to accidents for interim partially consolidated storage at two DOE sites 

Maximum acute risk 

Chronic human health 

risk Chronic ecological risk 

Accident 

scenario Site(s) 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

Facility fire INEEL Negligible Negligible Negligible Negligible Negligible Negligible 

PORTS Negligible Negligible Negligible Negligible Negligible Negligible 

Seismic INEEL Negligible Negligible Negligible Negligible Negligible Negligible 

PORTS Low Low Negligible Negligible Negligible Negligible 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

 Human health and ecological risk are evaluated in Appendix C and summarized in Table 4.14. Accidents 

at both facilities are expected to cause negligible to low chronic risks to humans and ecological receptors. 

4.7.3 Transportation 

 The potential effects of transporting uranium materials for consolidated storage at two DOE sites are 

evaluated in Appendix B and summarized in Table 4.15. 

Table 4.15. Transportation effects for interim partially consolidated storage at two 

DOE sites 

Destination location 

Average individual 

consequences, 

mrem 

Excess latent cancer 

fatalities (total) 

Traffic fatalities 

(total) 

All 0.0020 0.007 0.006 

DOE = U.S. Department of Energy. 

 These effects represent total effects for transporting materials to two potential DOE storage locations. 

The effects are less than those for the centralized storage alternatives because materials are transported to the 

closest site, thus minimizing transport miles. 

4.8 INTERIM PARTIALLY CONSOLIDATED STORAGE AT TWO COMMERCIAL SITES 

 This alternative involves moving uranium materials from their current storage locations to one of two 

commercial sites (one in the western one in the eastern United States). The total amount to be moved is 

14,200 MTU, because these sites do not currently have any material stored. The total amounts to be stored at 

either location vary, depending on the number of sites and amounts of materials that are considered closest to 

the consolidation location. 

4.8.1 Normal Operations 

 Under this alternative, the 14,200 MTU would be consolidated at two commercial sites, and the total 

floor space required would be at the levels shown in Table 4.12. It is assumed that all storage space would 
01-217(doc)/093002 4-14

have to be built. Additional requirements, activities, and environmental impacts are summarized in 

Table 4.16. The total construction cost is $17M for this alternative, and 7 acres of land would be disturbed. 

Table 4.16. Impacts for interim partially consolidated storage at two commercial sites

Requirements Activities Environmental impacts 

Site 

Initial 

workers 

Permanent 

workers 

Estimated 

upgrades 

New 

construction 

Availability 

of space 

Air, water, 

etc. Socioeconomics 

Western 138 5 $5.5M Yes Unknown Minor Minor 

Eastern 288 9 $11.5M Yes Unknown Minor Minor 

4.8.2 Facility Accidents 

 Acute consequences associated with facility fires and seismic events are evaluated in Appendix A and 

are the same as those for storage at PORTS and INEEL. Both storage area fires and seismic events at 

the eastern site can result in high toxicological consequences due to the potential for large quantities of 

uranium to become airborne in a fire. Radiological and toxicological consequences are negligible at the 

western site. 

 Human health and ecological risk are evaluated in Appendix C and are the same as those for storage at 

PORTS and INEEL (see Table 4.14). Accidents at both facilities are expected to cause negligible to low 

chronic risks to humans and ecological receptors. 

4.8.3 Transportation 

 The potential effects of transporting uranium materials for consolidated storage at two commercial sites 

are evaluated in Appendix B and summarized in Table 4.17. 

Table 4.17. Transportation effects for interim partially consolidated storage at two 

commercial sites 

Destination location 

Average individual 

consequences, 

mrem 

Excess latent cancer 

fatalities (total) 

Traffic fatalities 

(total) 

All 0.061 0.016 0.081 

 These effects represent total effects for transporting materials to two potential commercial storage 

locations. The effects are greater than those for the consolidated storage alternative at two DOE sites, 

because some materials are already stored at the DOE sites, thus increasing transport miles for this 

alternative. 

4.9 INTERIM PARTIALLY CONSOLIDATED STORAGE BASED ON PHYSICAL FORM 

 This alternative involves moving uranium materials from their current storage locations to a DOE site 

based on the physical form of the materials (i.e., the site with the largest quantity of a specific physical 

form is the preferred storage location for all materials of that form). The total amount to be moved depends 
01-217(doc)/093002 4-15

on the amount of that physical form currently stored at the site. The storage plan for these materials is 

shown below: 

Physical form

Preferred storage 

 location 

Compound 

Metal 

Miscellaneous 

Oxide 

Reactfuel 

Residue 

Source 

PORTS 

SRS 

PORTS 

PORTS 

INEEL 

INEEL 

INEEL 

4.9.1 Normal Operations 

 Under this alternative, ~8,200 MTU would be relocated to three DOE sites as shown in Table 4.18. This 

includes amounts that are moved from one of the three sites because that site is not the preferred site for that 

physical form. The net increase in total floor space required for storage is also shown in Table 4.18. 

 Table 4.18. Storage requirements for interim partially consolidated storage based on physical form

Assumed storagea Materials to be moved 

Site 

Amount, 

103

 MTU 

Number of 

containers 

Storage 

requirement, ft2

Amount, 

103 MTU 

Number of 

containers 

Additional 

storage 

requirement, ft2

PORTS 4.4 24,765 75,000 1.7 13,839 ~25,000 

SRS 3.0 2,867 19,000 6.0 32,918 ~117,000 

INEEL 1.5 639 7,000 0.4 1,188 ~0 

a

Includes some materials that are moved to other sites so that like physical forms can be consolidated. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

 Additional requirements, activities, and environmental impacts are summarized in Table 4.19. The total 

amount is $9.5M. 

 Approximately 3.4 acres of land would be committed to new storage space at SRS, with 

accompanying loss of habitat for wildlife. At PORTS, existing storage space would be used and, absent 

new construction, environmental impacts would be minimal. At INEEL, there are no additional storage 

requirements, workers or construction costs. At SRS, only minor air and water emissions would be 

expected, and at both PORTS and SRS, socioeconomic impacts would be minimal in relation to the 

regional economy and labor base. 
01-217(doc)/093002 4-16

Table 4.19. Impacts for interim partially consolidated storage based on physical form

Requirements Activities Environmental impacts 

Site 

Initial 

workers 

Permanent 

workers 

Estimated 

upgrades 

New 

construction 

Availability 

of space 

Air, water, 

etc. Socioeconomics 

PORTS 31 2 $1.3M No Yes Minimal Minimal 

SRS 205 7 $8.2M Yes Unknown Minor Minimal 

INEEL 0 0 $0K No NA Negligible Negligible 

INEEL = Idaho National Engineering and Environmental Laboratory. 

K = thousand dollars. 

M = million dollars. 

NA = not applicable. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

4.9.2 Facility Accidents 

 Acute consequences associated with facility fires and seismic events are evaluated in Appendix A and 

summarized in Table 4.20. The seismic event at PORTS can result in low toxicological consequences due 

to the potential for large quantities of uranium to become airborne in a fire. This is because most of the 

airborne source term (~ 90%) results from compounds and oxides that are relatively more dispersible than 

other physical forms considered in this study. Radiological and toxicological consequences are negligible 

at INEEL and SRS. 

 Human health and ecological risk are evaluated in Appendix C and summarized in Table 4.20. 

Accidents at all facilities are expected to cause negligible to low chronic risks to humans and ecological 

receptors. 

Table 4.20. Risks due to accidents for interim partially consolidated storage based on physical form 

Maximum acute risk Chronic human health risk Chronic ecological risk 

Accident 

scenario Site(s) 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

Consequence 

level 

Overall 

risk 

Facility PORTS Negligible Negligible Negligible Negligible Negligible Negligible

fire INEEL, SRS Negligible Negligible Negligible Negligible Negligible Negligible

Seismic PORTS Low Low Negligible Negligible Low Low 

INEEL, SRS Negligible Negligible Negligible Negligible Negligible Negligible

INEEL = Idaho National Engineering and Environmental Laboratory 

PORTS = Portsmouth Gaseous Diffusion Plant 

SRS = Savannah River Site 

4.9.3 Transportation 

 The potential effects of transporting uranium materials for consolidated storage at two commercial sites 

are evaluated in Appendix B and summarized in Table 4.21. 
01-217(doc)/093002 4-17

Table 4.21. Transportation effects for interim partially consolidated storage based on 

physical form 

Destination location 

Average individual 

consequences, 

mrem 

Excess latent cancer 

fatalities (total) 

Traffic fatalities 

(total) 

All 0.0022 0.003 0.005 

4.10 DISPOSITION 

 Each of the alternatives analyzed for some type of interim storage will also potentially have impacts 

related to final disposition. In Section 4.10, impacts due to the various disposition options are determined. 

These impacts due to disposition must be added to the impacts of each action alternative considered. The 

impacts of disposition are presented here as bounding conditions since many details of disposition can only be 

assumed at this time. As discussed in Section 2.3.8, disposition could involve commercial processing and 

domestic sales, use in research, use by other government agencies, and foreign sales. 

 Depending on the disposition option(s) employed and the specific processes involved (such as 

downblending for example), there would be some wastes generated. In addition, the product containers, once 

emptied for any option, would have to be reused as is, disposed as waste, or cleaned for reuse (generating 

waste in the cleaning process). These wastes would be disposed in compliance with the applicable regulations 

governing such waste materials. Disposition would likely take place over an extended period of time and 

could involve several disposition options. Thus, impacts associated with waste streams are expected to be 

minor since they would be intermittent and part of the expected normal operations at the disposition sites. 

 An estimate of the uranium inventory that would be included in each disposition option is provided. It is 

probable that a combination of commercial processing and domestic sales, transfer to research facilities and 

other government agencies, and foreign sales could occur. Since all the inventory would eventually be 

disposed, a rough bounding of environmental impacts would be to double the environmental impacts for the 

alternative(s) that have the greatest impacts already identified for them. That is, one would assume a doubling 

of the impacts identified for the interim storage at a single site (DOE or commercial) alternative (Sects. 4.3 

and 4.4) when the impacts of disposition are added. However, there are several factors, which would 

realistically tend to lessen these impacts, and they are discussed below. 

4.10.1 Commercial Processing and Domestic Sales 

 The total quantity of 14,200 MTU may be reprocessed commercially. It is likely that any commercial 

entities that acquired the uranium inventory would already have processing facilities and would likely take 

possession of the uranium inventory in such a way as to minimize or eliminate the need for building new 

storage facilities at the processing locations. Thus no new construction is probable. However, should 

construction be needed, any construction-related impacts should already be approximated by the storage at a 

single commercial site alternative (Section 4.5.1). That is, a temporary work force of ~300 construction 

workers, approximately a dozen permanent staff, and >$12M in construction costs are assumed. Processing 

operations costs could run several million dollars per year depending on the process and the amount of 

inventory reprocessed. Reprocessing activities would be likely to have relatively minor environmental and 

socioeconomic impacts. The potential for airborne releases during reprocessing exists but should be 

controlled to acceptable limits by the operating permits of the facilities. 
01-217(doc)/093002 4-18

 Both acute and chronic consequences and risk associated with this option are the same as that for 

centralized storage at a single commercial site (see Section 4.5.2) because the total amount of material to be 

processed is the same (14,200 MTU). 

 The potential effects of transporting uranium materials to a commercial reprocessing facility are also the 

same as transporting the materials to a single centralized storage location (see Section 4.5.3). 

4.10.2 Transfer to Research Facility 

 Under this option, ~50 MTU would be transferred to a single research facility assumed to be the greatest 

distance from an interim storage location. It is possible that there would be no new construction or building 

upgrades required since any research facility needing these materials would already have the personnel and 

facilities to handle it. However, should some new construction or upgrades be required, the storage/research 

space would be a few thousand square feet at most and costs, environmental impacts, and socioeconomic 

impacts would likely be minimal. 

 Acute consequences associated with facility fires and seismic events are evaluated in Appendix A. 

Because the total material transferred to any given site is substantially less than the amounts transferred to any 

of the six potential DOE storage locations evaluated for the partially consolidated storage alternative, the 

acute and chronic consequences and risk for human and ecological receptors are negligible or low (see Table 

4.10). Transportation effects are also less than those estimated for the partially consolidated storage 

alternative (see Table 4.11). 

4.10.3 Transfer to Other Government Agency 

 Under this option, ~2,500 MTU could be provided to other government agencies. The total 2,500 MTU 

would be transferred to a single, unspecified location assumed to be the greatest distance from one of the interim 

storage locations. The specific environmental impacts experienced would be related to how much of the 

inventory goes to any specific agency location; however, impacts can be assumed to approximate those for the 

interim partially consolidated storage at several DOE sites alternatives discussion (Section 4.6). That is, 

assuming, as a reasonable worst case, that new construction for temporary storage is required at the receiving 

agency, then up to 90 construction workers, $3.6M in building costs, and minor environmental impacts would 

occur.

 Acute consequences associated with facility fires and seismic events are evaluated in Appendix A. The 

total material (~2,500 MTU) is similar to amounts transferred to some of the six potential DOE storage 

locations evaluated for the partially consolidated storage alternative. Acute and chronic consequences and risk 

to human and ecological receptors are either negligible or low (see Table 4.10). Transportation effects are also 

less than those estimated for the partially consolidated storage alternative (see Table 4.11). 

4.10.4 Foreign Sales 

 Under this option, ~4,050 MTU of LEU/NU could be sold to the commercial nuclear fuel market. The 

total 4,050 MTU would be transferred from their interim storage locations to the closest international port and 

shipped via cargo vessel to the farthest port in Asia or the Far East. 

 Impacts due to normal operations would be negligible and associated with repackaging and transport 

from DOE sites to U.S. ports and from there to foreign ports-of-entry. 

 Acute consequences associated with facility fires and seismic events are evaluated in Appendix A. The 

total material (~4,050 MTU) is similar to amounts transferred to PORTS as evaluated for the partially 
01-217(doc)/093002 4-19

consolidated storage alternative. Acute and chronic consequences and risk are either negligible or low (see 

Table 4.10). Transportation effects are also less than those estimated for the partially consolidated storage 

alternative (see Table 4.11). 

 For overseas shipment, there is no consequence to any member of the public (i.e., only the ship’s crew is 

exposed). The average consequence to a member of a ship’s crew is estimated to be approximately 1.8 mrem 

per person per day for each shipment of material. A dock worker loading containers could potentially receive 

an external dose of ~2 mrem. 

 There are no anticipated adverse consequences to the marine environment from overseas shipment. 

However, in the very unlikely event of a ship sinking or cargo loss due to some unforeseen accident, uranium 

product could be deposited in the sea. Impacts would vary by location and form of uranium lost. The National 

Marine Fisheries Service has listed federally protected species, which could conceivably be affected (see 

NMFS letter to DOE, dated June 28, 2002, in Chapter 7).

4.11 SUMMARY AND CONCLUSIONS 

 Normal operations result in no more than negligible acute or chronic consequences and risk at any site 

under any storage alternative or disposition option. Environmental impacts associated with normal operations 

vary from alternative to alternative and, occasionally, by site within a given alternative. General handling 

accidents result in no more than negligible acute or chronic consequences and risk at any site under any storage 

alternative or disposition option. Chronic human health and ecological consequences and risk are negligible to 

low for all sites under all alternatives. The highest transportation consequences and risk are for alternatives that 

involve moving uranium materials to a western location, either to a commercial site or to INEEL. 

4.11.1 Comparison of Alternatives 

 When comparing the environmental impacts of the various alternatives, the following emerge as general 

trends: 

• There were none-to-minor impacts for all of the alternatives considered and negligible-to-low impacts 

from the standpoint of facility accidents (fire and seismic) for all the alternatives, while transportation 

effects for the alternatives generally reflected the extent of material transport associated with the 

alternative being analyzed. 

• The greater the centralization or consolidation of the uranium inventory, the greater the potential for 

normal operations impacts. Greater centralization or consolidation means that new storage space has to 

be built, which means accompanying costs and commitment of land, and uranium materials will have to 

be shipped greater distances with increased risk of accidents. 

• The action alternative with the fewest environmental impacts and that is the least expensive ($7.3M) is 

“Interim Partially Consolidated Storage at Several DOE Sites.” This alternative takes advantage of the 

current storage of the majority of these DOE sites already. Thus, construction costs and associated 

environmental impacts would be less than other action alternatives. 

• Similarly, the PORTS site would have the fewest environmental impacts and would be the least 

expensive ($8.4M) of the DOE facilities considered for interim centralized storage. PGDP and 

commercial sites would be the most expensive centralized storage. 
01-217(doc)/093002 4-20

• Excess LCFs due to transportation and traffic fatalities are minimal for all alternatives but greatest for 

the interim storage at the single site alternatives. The increase in excess LCFs to the public from 

radiological exposures during transportation is less than one for all alternatives. 

• Western sites would tend to have slightly higher traffic fatalities associated with them than eastern ones 

due to the larger volumes of uranium materials to be shipped over greater distances. 

• Commercial sites would have slightly greater impacts than DOE sites (except for PGDP) when 

comparing similar alternatives (interim centralized storage at a single DOE site versus a single 

commercial site and interim partially consolidated storage at two DOE sites versus two commercial 

sites). 

 Interim Centralized Storage at a Single Commercial Site Alternative. Considering the combination of 

normal operations, facility accidents and transportation, the “Interim Centralized Storage at a Single Commercial 

Site” alternative and the PGDP site for “Interim Consolidated Storage at a Single DOE Site” alternative have the 

greatest potential for environmental impacts. For normal operations, the western and eastern commercial sites 

and PGDP have equal impact potential. Any of these sites would have 305 first-year construction workers, 14 

new permanent workers, $12.2M in new construction costs, and 7 acres of land commitment and habitat 

disturbance. Facility accidents would result in negligible to low acute and chronic risks. 

 Interim Centralized Storage at a Single DOE Site. Impacts are very similar to the single commercial 

site alternative discussed above; however, there are some differences in impacts among the DOE sites. 

Because PORTS has sufficient existing storage space, normal operations impacts, including socioeconomics, 

would be minimal at this site. Upgrading existing buildings at PORTS would not result in commitments of 

land or destruction of wildlife habitat that would be necessary at all other DOE sites. 

 Due to the very small amount of uranium storage space at PGDP, the impacts of normal operations 

would be almost identical to interim centralized storage at a single commercial site as noted above. 

 Interim Partially Consolidated Storage at Two Commercial Sites. Because none of the 14,200 MTU 

uranium inventory is now at these commercial sites, the normal operations impacts associated with this 

alternative are very similar to those for the “Interim Centralized Storage at a Single Commercial Site” 

alternative, except that environmental impacts would be shared by the two sites. 

 Interim Partially Consolidated Storage at Two DOE Sites. Environmental impacts from normal 

operations would tend to be less than from consolidation at two commercial sites, because some of the 

uranium inventory is already at INEEL and PORTS. Thus, less construction-related impacts would result. 

Human health and ecological risks from facility accidents would be the same as for consolidation at two 

commercial sites. 

 Interim Partially Consolidated Storage at Several DOE Sites. Because most of the uranium 

inventory would remain at the six prime DOE locations and only the 3900 MTU at 152 other sites would 

be relocated, the normal operations impacts would be substantially less than all the other action 

alternatives. Additional space requirements, and the impacts associated with construction of this space, 

would be sharply reduced when compared to the other action alternatives. This alternative most closely 

resembles the No Action alternative. 

 No Action. Because there is no new construction at any site, this alternative has the least normal 

operations impacts of any alternative and no transportation impacts. Facility accidents would result in low to 

negligible acute and chronic risks. 
01-217(doc)/093002 4-21

4.12 CUMULATIVE IMPACTS 

 Cumulative impacts are impacts associated with the proposed action when combined with other past, 

present, or reasonably foreseeable future impacts. There are no substantial impacts associated with the 

proposed action under normal operations. When the negligible-to-minor environmental and socioeconomic 

impacts associated with normal operations (construction of new storage facilities, facilities upgrades, and 

daily maintenance and surveillance) and any of the action alternatives are added to the baseline environment, 

cumulative impacts are minor. 

 For facility accidents, the potential for negligible to low acute consequences and risk, due to either 

storage area fires or seismic events, exists for the “Interim Centralized Storage at a Single DOE Site” 

alternative and “Interim Centralized Storage at a Single Commercial Site.” Under a major seismic event 

scenario sufficient to mobilize uranium oxide into the environment, it is reasonable to assume that other 

material releases and other risks would be posed to workers at the site. Therefore, risks from uranium oxides 

would be one of several environmental and health risks that workers at the sites would face. For other 

accidents and other forms of uranium materials, the acute and chronic human health risk and ecological risk 

are negligible or low. 

 Due to a small increase in vehicular traffic to transport uranium materials, there would be a slight 

increase in traffic accidents and fatalities on the nation’s highways. These cumulative impacts would be very 

minor in comparison to the baseline. Likewise, exposures of the public and workers during uranium transport 

would increase very slightly the risks of LCFs. 

 At some time in the future, the uranium inventory would be eventually dispositioned. Various disposition 

options including commercial processing and domestic sales of the entire inventory, disposition of limited 

quantities (50 MTU) at research facilities, disposition of 2,500 MTU to other government agencies, and 

foreign sales of 4,050 MTU may occur. Impacts associated with these options are considered as a part of each 

of the interim storage alternatives. In addition, potential cumulative impacts (such as temporary storage costs, 

new construction, and additional labor) could occur should an existing inventory of uranium materials be 

increased at any of these disposition option locations. 

4.12.1 SRS 

 There is a large inventory (~19,000 MTU) of uranium, mostly oxides, at the SRS, which is not part of the 

UMG inventory. For an accident risk perspective, cumulative impacts could be important at SRS (due 

principally to this existing, non-UMG uranium oxide inventory). Centralized storage would add 11,300 MTU 

to the 2400 MTU already included in the UMG inventory. 

 In addition, up to 7 acres of site habitat at SRS would be devoted to new construction, removing these 

acres from current use. This acreage, when considered from a total site perspective, would be a minimal 

cumulative impact since portions of SRS are undergoing remediation or being dedicated to greater 

environmental uses. 

4.12.2 PGDP 

 The PGDP site would need the largest amount of new construction including 7 acres of permanent 

habitat disruption. This disruption would occur at a site undergoing ground-disturbing remediation efforts, 

which also affect wildlife habitat, albeit of low quality in most cases. Because of the small workforce at 

PGDP, direct construction-related increases in employment would be greatest at this site. Due to declining 

DOE employment at the site, however, the overall cumulative impact would likely be temporary but 

beneficial for the regional economy. 
01-217(doc)/093002 4-22

4.12.3 PORTS 

 The PORTS site has an existing inventory of uranium materials. Should the approximately 9800 MTU of 

additional inventory evaluated in this EA be added to the existing inventory, then the potential for cumulative 

impacts due to accidental releases would increase. Since PORTS currently has sufficient existing storage 

space for the 14,200 MTU, the site has the lowest potential for cumulative impacts due to 

construction/renovation. However, as noted, DOE is committed to using the existing UMG storage facility 

and upgrades to other buildings for uranium storage associated with the UMG program would not occur. 

4.12.4 INEEL 

 Like the PGDP site, INEEL would require substantial new construction with associated permanent 

habitat disruption. This 7-acre commitment would occur at a highly developed site undergoing other ground 

disturbances associated with remediation. This site also has uranium inventory that is not part of the proposed 

action so cumulative impacts from accidental releases are possible. 

4.12.5 Oak Ridge 

 The two sites at Oak Ridge would also require a commitment of land for new construction. Even though 

there are also other uranium inventories in Oak Ridge, the physical separation of the two sites lessens the 

potential for cumulative impacts due to accidental releases. 
01-217(doc)/093002 5-1

5. REFERENCES 

Bennett, C. M. 1986. Capacity of the Diversion Channel Below the Flood-Control Dam on the Big Lost River 

at the Idaho National Engineering Laboratory, Idaho, U.S. Geological Survey, Water Resources 

Investigative Report 86-4204. 

DOC (U.S. Department of Commerce). 1991. Department of Commerce, Region and County Projections, 

U.S. Department of Commerce, Bureau of the Census, Washington, D.C., November. 

DOE (U.S. Department of Energy). 1991. Draft Environmental Impact Statement for the Siting, Construction, 

and Operation of New Production Reactor Capacity, DOE/EA-0306, U.S. Department of Energy. 

DOE (U.S. Department of Energy). 1997a. Final Waste Management Programmatic Environmental Impact 

Statement for Managing Treatment, Storage, and Disposal of Radioactive and Hazardous Waste, 

DOE/EIS-200-F, Office of Environmental Management, Washington, D.C. 

DOE (U.S. Department of Energy). 1997b. Report on the Remedial Investigation of Bear Creek Valley at the 

Oak Ridge Y-12 Plant, Oak Ridge Tennessee, Volume I, DOE/OR/01-1455/V1&D2, U.S. Department of 

Energy, Office of Environmental Management, Oak Ridge, TN. 

DOE (U.S. Department of Energy). 1997c. Final Environmental Assessment, Lease of Land and Facilities 

within the East Tennessee Technology Park, Oak Ridge, Tennessee, DOE/EA-1175, U.S. Department of 

Energy, Oak Ridge Operations, Oak Ridge, TN. 

DOE (U.S. Department of Energy). 1998a. Report on the Remedial Investigation of Upper East Fork Poplar 

Creek Characterization Area at the Oak Ridge Y-12 Plant, Oak Ridge, Tennessee, Volume I, DOE/OR/01-

1641/V1&V2, U.S. Department of Energy, Office of Environmental Management, Oak Ridge, TN. 

DOE (U.S. Department of Energy). 1998b. INEEL Site Environmental Report for Calendar Year 1998 

DOE/ID-12082 (97), ESRF-030, U.S. Department of Energy. 

DOE (U.S. Department of Energy). 1999. Final Environmental Assessment for the U.S. Department of 

Energy, Oak Ridge Operations, Receipt and Storage of Uranium Materials from the Fernald 

Environmental Management Project Site, DOE/EA-1299, U.S. Department of Energy. 

DOE (U.S. Department of Energy). 2000. Environmental Assessment for the Disposition of Surplus Hanford 

Site Uranium, DOE/EA-1319, U.S. Department of Energy. 

DOE (U.S. Department of Energy). 2001a. Wetlands Assessment, Reindustrialization Program at the 

Portsmouth Gaseous Diffusion Plant, Piketon, Ohio, December. 

DOE (U.S. Department of Energy). 2001b. Final Sitewide Environmental Impact Statement for the Y-12 

National Security Complex, DOE/EIS-0309, U.S. Department of Energy, Oak Ridge Y-12 Area Office, 

National Nuclear Security Administration. 

DOE (U.S. Department of Energy). 2002. Draft Environmental Assessment, Reindustrialization Program at 

the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio, DOE/EA-1346. 

Martin, S. B. 1995. INEL-DOE Species List Update, Letter from Susan B. Martin, Acting Supervisor, Snake 

River Basin Office, U.S. Department of the Interior, Fish and Wildlife Service, to Dr. Tim Reynolds, 

Environmental Science and Research Foundation, September 22, 1995. 
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MMES (Martin Marietta Energy Systems, Inc.). 1991. Portsmouth Gaseous Diffusion Plant Environmental 

Report for 1990, ES/ESH-18/V4. 

ORNL (Oak Ridge National Laboratory). 1998. Oak Ridge Reservation Annual Site Environmental Report for 

1997, ES/ESH-78, October, Oak Ridge National Laboratory, Environmental Sciences Division, Oak Ridge, 

TN. 

ORNL (Oak Ridge National Laboratory). 2001. Oak Ridge Reservation Annual Site Environmental Report for 

2000, DOE/ORO/2119, Oak Ridge National Laboratory and Oak Ridge Y-12 National Security Complex 

and East Tennessee Technology Park, Oak Ridge, TN, September. 

Reed, W. G., Ros, J. W., Ringe, B. L., and Holmer, R N. 1987. Archaeological Investigations on the Idaho 

National Engineering Laboratory: 1984-1985, Revised Edition, Swanson/Crabtree Anthropological 

Research Laboratory Reports of Investigations No. 87-2, Pocatello, ID. 

Sheppard, M. I., and Thibault, D. H. 1990. “Default soil solid/liquid partition coefficients, Kds for four major 

soil types: a compendium,” Health Phys. 59: 471−482. 

Sousa, P. A., DuVall, G. D., Tinker, N., and Hart, M. J. 2001. Cultural Resource Management Plan, 

Department of Energy Oak Ridge Operations Office, Anderson and Roane Counties, Tennessee,

DOE/ORO-2085. 

SRS (Savannah River Site). 2001. Savannah River Site Environmental Report for 2000, WSRC-TR-2000-

00328. 

U.S. Bureau of Economic Analysis. 2002a. http://www.bea.gov/bea/regional/bear facts, U.S. Department of 

Commerce, Bureau of Economic Analysis, Washington, D.C. 

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Commerce, Bureau of Economic Analysis, Washington, D.C. 
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6. LIST OF PREPARERS 

Name Degree/Discipline Professional Experience Responsibility

Wayne Tolbert Ph.D., Ecology 25 years experience in 

environmental compliance; 

20 years in NEPA compliance 

Project Manager; primary 

customer point of contact; overall 

responsibility for EA; affected 

environment and normal 

operations impacts 

Carol Mason M.S., Chemical 

Engineering 

22 years experience in 

engineering, radiation safety, and 

safety analysis 

Accident analysis development 

and calculations 

Dave King M.S., Radiation 

Protection 

Engineering 

8 years experience in health 

physics and radiation protection; 

Certified Health Physicist 

Human health risks 

Chuck Hadden Ph.D., Microbiology 29 years experience in 

environmental risk assessment, 

microbiology, and microbial 

genetics; 10 years experience in 

NEPA ecorisk assessment 

Ecorisks 

Ruth Weiner Ph.D., Physical 

Chemistry 

40 years experience in chemistry 

and environmental studies and 

research 

Ran transportation computer 

models 

Aparajita Morrison B.S., Health Physics 16 years experience in health 

physics and 8 in NEPA analysis 

Transportation accident risks; 

health physics 

Stephen Mitz M.S., Aquatic 

Toxicology 

19 years experience in aquatic 

toxicology, chemistry, and NEPA 

aquatic impact assessment 

Aquatic ecology and ecorisks 

Diane McDaniel B.S., Wildlife and 

Fisheries Science 

10 years experience in wildlife 

biology; 8 years in NEPA 

compliance 

Affected environment SRS and 

INEEL 

Carolyne Thomas M.S., Civil and 

Environmental 

Engineering 

9 years experience in engineering, 

5 years in Project Management 

DOE Project Manager and 

technical reviewer 

DOE = U.S. Department of Energy. 

EA = Environmental Assessment. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

NEPA = National Environmental Policy Act. 

SRS = Savannah River Site. 
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7. LIST OF AGENCIES/INDIVIDUALS CONSULTED 

 This chapter contains copies of correspondence with the State Historic Preservation Officers (SHPOs) in 

Tennessee, Kentucky, South Carolina, Ohio, and Idaho and with the FWS, the National Marine Fisheries 

Service, and state conservation departments. 
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01-217(doc)/093002 

Endangered Species Act 

BIOLOGICAL ASSESSMENT 

for 

Implementation of a Comprehensive Management Program 

for the Storage, Transportation, and Disposition of 

Potentially Reusable Uranium Materials 

at the Oak Ridge Reservation, 

Oak Ridge, Tennessee

Prepared by 

Science Applications International Corporation 

151 Lafayette Drive 

Oak Ridge, Tennessee 37831 

Prepared for 

U.S. Department of Energy 

Oak Ridge Operations Office 

Oak Ridge, Tennessee 37831 

July 2002 
01-217(doc)/093002 

SCIENCE APPLICATIONS INTERNATIONAL CORPORATION 

 Contributed to the preparation of this document and 

 should not be considered an eligible contractor for its review. 
01-217(doc)/093002 iii

CONTENTS 

FIGURES...................................................................................................................................................... v

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

EXECUTIVE SUMMARY.........................................................................................................................vii

1. INTRODUCTION................................................................................................................................. 1

1.1 PURPOSE AND NEED FOR AGENCY ACTION ................................................................... 1

1.2 PROPOSED ACTION ................................................................................................................ 1

1.3 ECOLOGICAL DESCRIPTION OF THE SITES...................................................................... 3

1.3.1 Y-12 Complex ................................................................................................................. 3

1.3.2 East Tennessee Technology Park .................................................................................... 4

2. ECOLOGICAL DESCRIPTION AND POTENTIAL IMPACTS OF THE PROPOSED 

PROJECT ON LISTED SPECIES........................................................................................................ 4

2.1 Gray Bat (Myotis grisescens)...................................................................................................... 5

2.2 Indiana bat (Myotis sodalis)........................................................................................................ 6

2.3 Pink Mucket (Lampsilis abrupta) ............................................................................................... 8

3. REFERENCES...................................................................................................................................... 9
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01-217(doc)/093002 v

FIGURES 

1 Location of Y-12 Complex and ETTP on the DOE's Oak Ridge Reservation.................................... 2

ACRONYMS 

BA biological assessment 

DOE U.S. Department of Energy 

DU depleted uranium 

EFPC East Fork Poplar Creek 

ETTP East Tennessee Technology Park 

FWS U.S. Fish and Wildlife Service 

LEFPC Lower East Fork Poplar Creek 

LEU low enriched uranium 

MTU metric tons of uranium 

NU normal uranium 

ORR Oak Ridge Reservation 

PEA programmatic environmental assessment 

TVA Tennessee Valley Authority 

UEFPC Upper East Fork Poplar Creek 

UMG Uranium Management Group 

Y-12 Complex Y-12 National Security Complex 
01-217(doc)/093002 vi
01-217(doc)/093002 vii

EXECUTIVE SUMMARY 

This biological assessment (BA) assesses potential impacts on three federally listed animal species that 

could result from the implementation of a comprehensive management program to store, transport, and 

dispose of potentially reusable uranium materials by the U.S. Department of Energy (DOE) at one of two sites 

the Y-12 National Security Complex (hereafter referred to as the Y-12 Complex) or East Tennessee 

Technology Park (ETTP) on the Oak Ridge Reservation (ORR). The species discussed in this BA are those 

mentioned in comments received from the U.S. Fish and Wildlife Service (FWS) to DOE, dated June 10, 

2002.2

 The FWS comments were specifically directed toward potential impacts resulting from implementing 

the proposed uranium management program on the ORR. 

The three species include two listed endangered mammals, the gray bat (Myotis grisescens) and the 

Indiana bat (Myotis sodalis), and a listed endangered freshwater mussel, the pink mucket (Lampsilis abrupta). 

None of these species is likely to be present on either of the proposed sites, and proposed or designated 

critical habitats for the species are not present on or near either of the proposed sites. However, caves that 

could provide potential roosting habitat for the gray bat are present within 6.4 km (4 miles) of the ORR. 

Suitable roosting habitat for the Indiana bat is also present within the vicinity of the proposed project. In 

addition, the Clinch River (Melton Hill Reservoir), an impoundment on the Clinch River that forms the 

southern boundary of the ORR, and Poplar Creek, which flows through ETTP, provide suitable foraging 

habitat for the gray bat and Indiana bat. The pink mucket is known to occur in the Clinch River (Melton Hill 

Lake). All surface water from Y-12 Complex drainage eventually enters the Clinch River near ETTP. Both 

Bear Creek, a tributary to East Fork Poplar Creek (EFPC), and EFPC rise at the Y-12 Complex. EFPC flows 

into Poplar Creek, which flows through ETTP before entering the Clinch River. 

DOE staff conclude, based on the information presented in this BA, that implementation of the proposed 

action at either site on the ORR is not likely to adversely affect any of the listed species because the proposed 

action involves potential warehouse construction on already developed, industrialized areas on the ORR. The 

ORR does not contain any proposed or designated critical habitat for the gray bat or the Indiana bat, so none 

would be affected. In addition, any potential adverse impacts to the Indiana bat would be expected to be 

negligible due to the lack of suitable summer roosting habitat at both sites. Although the ultimate use of either 

site may eventually require the removal of trees, any potential roosting habitat at the site is, at best, marginal. 

Also, there are adequate numbers of suitable and potentially suitable roost trees available immediately 

adjacent to the two sites. The proposed action would not affect any potentially suitable habitat for the pink 

mucket in the Clinch River or its tributaries. It is unlikely that the proposed action would result in any off-site 

releases of sediment or potential contaminants that would adversely affect this mussel. DOE requests the 

concurrence of the FWS with these conclusions. 

 

2

Letter from Dr. Lee A. Barclay, U.S. Fish and Wildlife Service, Cookeville, Tennessee, to Mr. David Allen, U.S. Department 

of Energy, Oak Ridge, Tennessee, June 10, 2002. 
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1. INTRODUCTION 

This biological assessment (BA) only evaluates the effect of the proposed action on threatened and 

endangered species for two sites in Oak Ridge, the Y-12 National Security Complex (hereafter referred to as the 

Y-12 Complex) and East Tennessee Technology Park (ETTP) [Figure 1]. 

1.1 PURPOSE AND NEED FOR AGENCY ACTION 

The U.S. Department of Energy (DOE) proposes to implement a comprehensive management program to 

safely, efficiently, and effectively manage its potentially reusable low enriched uranium (LEU), normal 

uranium (NU), and depleted uranium (DU). Uranium materials, which are presently located at multiple sites, 

are to be consolidated by transporting the materials to one, or several, storage locations to facilitate ultimate 

disposition. Management would include the storage, transport, and ultimate disposition of these materials. 

This action is needed because of DOE’s current missions and functions; increasing budget pressures; the 

continuing need for good stewardship of resources, including materials in inventory; and continuing DOE 

attention to considerations of environment, safety, and health. Also, increased pressure on the federal budget 

requires that DOE take a closer look at materials management in order to ensure maximum cost effectiveness. 

This includes an examination of feasible uses of this material, consistent with DOE’s mission, as well as an 

examination of management methods that are consistent with environmental requirements and budgetary 

constraints. DOE needs to implement a long-term (greater than 20 years) management plan for its inventory 

of potentially reusable LEU, NU, and DU. 

1.2 PROPOSED ACTION 

DOE proposes to implement a long-term (greater than 20 years) management plan for its inventory of 

potentially reusable LEU, NU, and DU. Uranium materials, which are presently located at multiple sites, are 

to be consolidated by transporting the materials to one, or several, storage locations to facilitate ultimate 

disposition. The management plan will address the packaging and transport of potentially reusable uranium 

materials from DOE sites and university loan/lease returns and their receipt and storage at a site under 

cognizance of the Uranium Management Group (UMG). This action will also cover material shipment from 

the UMG and disposition. A Secretarial Determination is required, under certain conditions, for uranium in 

the UMG inventory to be sold. Twenty years will provide time for additional reviews required for any future 

related actions that may be desirable to help accomplish ultimate disposition. Impacts evaluated in Chapter 4 

of the Draft Programmatic Environmental Assessment (PEA) prepared for this project (DOE 2002) cover the 

20-year period of this management plan. 

The management plan will cover uranium materials that are currently in the form of oxides, metals, and 

other stable compounds such as UF4. The quantity of uranium within the scope of this PEA is estimated to be 

14,200 metric tons of uranium (MTU) and is primarily located at a few DOE locations (Idaho National 

Engineering and Environmental Laboratory, Portsmouth Gaseous Diffusion Plant, Savannah River Site, and 

Oak Ridge). These DOE locations have other uranium materials, which are not part of the UMG inventory 

and not part of the 14,200 MTU addressed in the proposed action. This number is based on the 2000 Nuclear 

Material Inventory Assessment data increased by approximately 10% to reflect uncertainties in material 

shipment. The plan will not include irradiated material, UF6, enrichment of 20% or greater 235U, or 233U. 
01-217(doc)/093002 2

Fig. 1. Location of Y-12 Complex and ETTP on the DOE's Oak Ridge Reservation.
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DOE must determine the safest, most effective, and most efficient approach for the consolidation and 

storage of this material. Consideration will be given only to those locations (DOE and commercial) within the 

continental United States that have a long-term mission for the handling and storage of uranium material. This 

material would be stored in either one (centralized) location or several (consolidated) locations. 

Approximately 14,200 MTU may be consolidated into one or more storage locations. This material is the 

primary focus of this PEA. Several alternatives were evaluated in detail for the Draft PEA prepared for this 

project (DOE 2002). 

1.3 ECOLOGICAL DESCRIPTION OF THE SITES 

1.3.1 Y-12 Complex 

The Y-12 Complex (formerly the Y-12 Plant) is one of three installations on the DOE ORR. The early 

missions of the site included separation of 235U from normal uranium by the electromagnetic separation 

process and manufacturing weapons components from uranium and lithium (DOE 2001a). 

During 2000, the U.S. Congress established the National Nuclear Security Administration. Its mission is 

to carry out National Security responsibilities of DOE (DOE 2001b).

1.3.1.1 Water resources 

The Y-12 Complex is approximately 3 km (2 miles) from the Melton Hill Reservoir and Clinch River. 

On-site, two streams originate approximately in the middle of the complex. Bear Creek flows directly west 

from its headwaters at the Y-12 Complex, while EFPC flows east before turning north and west and flowing 

through the residential area of Oak Ridge. These two creeks merge near ETTP, which is approximately 16 km 

(10 miles) west of the Y-12 Complex. The major groundwater unit for the ORR is the Knox Aquifer, 

composed of the Knox Group and the Maynardville Limestone. No aquifers are considered sole-source 

aquifers (DOE 1997a). 

1.3.1.2 Ecological resources 

The ORR consists of diverse habitats and supports a rich variety of flora and fauna. Vegetation is 

characteristic of that found in the inter-mountain regions of central and southern Appalachia. The 

Y-12 Complex is covered in mowed grass, concrete, gravel, asphalt, and industrial structures. Thus, the site 

does not have unique habitats or a wide diversity of flora or fauna. Upper East Fork Poplar Creek (UEFPC) 

lacks riparian vegetation because much of the stream is channelized and maintained. Lake Reality is a 

1.0-hectare (2.5-acre), plastic-lined, flat-bottomed settling and spill control structure located near the east end 

of the facility on EFPC. Upper Bear Creek is also channelized, but, generally, it has somewhat better habitat 

quality and a better-defined riparian zone than UEFPC. There are mature hardwood forests in upper Bear 

Creek valley within 1.6 km (1.0 mile) of the Y-12 Complex. There is a small wetland [0.18 hectare (0.45 

acre)] in a small, wooded area between New Hope Cemetery and Bear Creek Road. Bear Creek valley 

contains several wetlands that cover a total area of several hectares. 

There are no federally protected threatened or endangered species known on the Y-12 Complex. 

However, the FWS notes that the federally listed endangered speciesthe gray bat (Myotis grisescens), the 

Indiana bat (Myotis sodalis), and the pink mucket (Lampsilis abrupta)are known from, or have the potential 

to occur within, the project impact areas on the ORR. Although surveys for protected species are not 

comprehensive enough to rule out all possible federal- or state-listed vertebrates, the likelihood of finding 

such species seems very low (DOE 1998a). 
01-217(doc)/093002 4

1.3.2 East Tennessee Technology Park 

ETTP, formerly known both as the Oak Ridge Gaseous Diffusion Plant and as the Oak Ridge K-25 Site, 

is located in Roane County, Tennessee, and is one of three large facilities on the ORR. The site is located on a 

level, 607-hectare (1500-acre) tract of land near the confluence of Poplar Creek and the Clinch River. ETTP is 

approximately 56 km (35 miles) west of Knoxville and approximately 13 km (8 miles) southwest of the city 

of Oak Ridge. 

1.3.2.1 Surface water 

ETTP is directly adjacent to the Clinch River along the northwest boundary of the ORR. Poplar Creek is 

a moderately wide [9- to 21-m (30- to 70-ft)] stream that enters the north side of ETTP about 0.5 km 

(0.3 mile) downstream of the confluence of the east and west forks of Poplar Creek (DOE 1997b). The lower 

reach of Poplar Creek meanders sharply along the southwest side of ETTP and enters the Clinch River. 

The Tennessee Valley Authority (TVA) performed an analysis of floods on the Clinch River and Poplar 

Creek. TVA concluded that most of ETTP is above the probable maximum flood level. The only facilities 

identified at risk during major floods were the K-25 power plant and the pumping station for ETTP’s water 

filtration plant. The source of flooding at ETTP would be backwater from the Clinch River near the 

confluence of Poplar Creek. All proposed storage locations are above the 100-year flood level. 

1.3.2.2 Ecological resources 

The ORR consists of diverse habitats and supports a rich variety of flora and fauna. Vegetation is 

characteristic of that found in the intermountain regions of central and southern Appalachia. Vegetation 

around the buildings within the fenced area on the ETTP proper is a mixture of mowed grasses with a few 

shrubs and trees. Many of the shrubs and trees have been planted as landscaping, although some native 

species are found in unmowed areas around ponds and waterways. There are several hectares of wetlands in 

and around ETTP. The Lower Poplar Creek Rookery is the only environmentally sensitive area within ETTP. 

It is approximately 2.6 hectares (6.5 acres) and is located on the north bank of Poplar Creek in the middle of 

the plant site. 

Since ETTP proper is planted primarily in non-native grasses, it has very little habitat available for native 

animals except along Poplar Creek. The majority of animal species found within ETTP’s boundaries are 

species that adapt well to disturbance and the presence of humans. There are no known federally protected 

plant or animal species on the ETTP site, although suitable habitat exists for the endangered bald eagle on 

Melton Hill Reservoir and the Clinch River. Sixteen plant species and 18 animal species that are considered 

rare, threatened, or endangered by the state of Tennessee are found on or near ETTP. However, the FWS 

notes that the federally listed endangered speciesthe gray bat (Myotis grisescens), the Indiana bat (Myotis 

sodalis), and the pink mucket (Lampsilis abrupta)are known from, or have the potential to occur within, the 

project impact areas on the ORR. 

2. ECOLOGICAL DESCRIPTION AND POTENTIAL IMPACTS OF THE 

PROPOSED PROJECT ON LISTED SPECIES 

The general ecology of federally listed species that are known to occur near the site and the expected 

potential impacts on them from the project are summarized below. Unless otherwise noted, general biological 
01-217(doc)/093002 5

information on the species is derived from the published literature, reports, and Internet resources listed under 

each species heading. 

2.1 GRAY BAT (Myotis grisescens) 

Unless otherwise noted or referenced, the following general biological information on the gray bat is 

derived from FWS (1991), Harvey (1992), and Kentucky Bat Working Group (KBWG) [2000]. The core 

range of the endangered gray bat encompasses the cave regions of Alabama, northern Arkansas, Kentucky, 

Missouri, and Tennessee, but a few occur in northwestern Florida, western Georgia, southwestern Kansas, 

south Indiana, south and southwestern Illinois, northeastern Oklahoma, northeastern Mississippi, western 

Virginia, and possibly western North Carolina. Gray bats are restricted to caves or cave-like habitats, and few 

caves meet their specific roost requirements. These restrictions result in about 95% of the populations 

hibernating in only eight or nine caves. For hibernation, the roost site must have an average temperature of 

5.6°C to 11.1°C (42°F to 52°F). Most of the caves used by gray bats for hibernation have deep vertical 

passages with large rooms that function as cold air traps. Summer caves must be warm, between 13.9°C to 

25.0°C (57°F and 77°F), or have small rooms or domes that can trap the body heat of roosting bats. Summer 

caves are normally located close to rivers or lakes where the bats feed. Gray bats have been known to fly as 

far as 12 miles or more from their colony to feed. 

Gray bats roost, breed, rear young, and hibernate in caves year-round. They migrate between summer 

and winter caves and will use transient or stopover caves along the way. One-way migrating distance between 

winter and summer caves may vary from as little as 16 km (10 miles) to well over 322 km (200 miles). 

Mating occurs as bats return to winter caves in September and October. By November most gray bats are 

hibernating. Adult females begin to emerge in late March, followed by juveniles and adult males. Females 

store sperm over the winter and become pregnant the following spring. A few hundred to many thousands of 

pregnant females congregate to form maternity colonies. Males and nonreproductive females gather in smaller 

groups to form what are known as bachelor colonies. A single pup is born in late May or early June. The 

young begin to fly 20 to 25 days after birth. Gray bats primarily feed on flying insects over lakes, rivers, and 

streams. Aquatic insects, particularly mayflies, make up most of their diet. 

Information about the occurrence of gray bats on the ORR is limited. In November 1994, a single, dead 

gray bat was found in a display cabinet in a building at the Oak Ridge Y-12 Plant. The bat was probably an 

isolated, individual juvenile that became lost, disoriented, and trapped. Mist netting for bats was conducted on 

the Lower East Fork Poplar Creek (LEFPC) and its tributaries in May 1992 and again in May–June 1997 

(Harvey 1997). The 1997 survey included portions of lower Bear Creek near its confluence with LEFPC. The 

creeks in this area provided good gray bat foraging habitat at the time of the surveys. No gray bats were 

recorded among the six species captured. More than 20 caves have been identified on the ORR. Seven of the 

caves (Copper Ridge, Flashlight Heaven, Walker Branch, Big Turtle, Little Turtle, Pinnacle, and Bull Bluff) 

were surveyed by Mitchell et al. (1996), but no gray bats were found. There is an unverified report of ten gray 

bats roosting in Little Turtle Cave in September 1996. These bats were observed roosting and were not further 

disturbed; therefore, a definite, in-the-hand identification was not made (Webb 1996). Examination of 

photographs taken of the roosting bats indicate that they appeared to be Myotis and more than likely were 

gray bats, but the species could not be positively determined [Major (2000) and Henry (2000)]. 

Although no caves are present within the area of the proposed project, several caves are located within 

6.4 km (4 miles) of the proposed site location, and two of the caves are located within 2.4 km (1.5 miles). 

None of the caves has been completely and systematically surveyed for bats, except for the limited surveys 

reported in Mitchell et al. (1996) and the 1996 report of Myotis roosting in Little Turtle Cave. The caves 

within the vicinity of the project area may not provide adequate hibernacula for gray bats, but they could 

provide transient or stopover roosting habitat for migrating gray bats. Suitable foraging habitat for gray bats 
01-217(doc)/093002 6

within the vicinity of the proposed facility includes the Clinch River (Melton Hill Lake), which is located 

about mile south of the Y-12 complex. Both Bear Creek and East Fork Poplar Creek are narrow, small 

streams and are considered suboptimal for frequent foraging for gray bats. 

Both the Y-12 Complex and ETTP are highly industrialized areas with little natural habitat that remains 

immediately surrounding the complex. No caves would be disturbed by the proposed action, and activities 

would also not directly impact any of the potential foraging habitat that exists in the vicinity. If construction 

of new facilities were required, it would occur only during the day, so any foraging by gray bats would not be 

disrupted. Activities associated with the operation of the proposed facility would also primarily occur during 

the day and would not disrupt any gray bats that might forage near the site. In addition, no significant 

emissions or effluents would be produced by the facility that could directly impact foraging gray bats or 

indirectly affect aquatic insect fauna on which the gray bats would prey. Thus, the proposed project is 

unlikely to adversely affect the gray bat or its habitat. 

2.2 INDIANA BAT (Myotis sodalis) 

Unless otherwise noted or referenced, the following general biological information on the Indiana bat is 

derived from FWS (1991, 1999a, 1999b, 2000), Harvey (1992), and KBWG (1997, 2000). The Indiana bat is 

a migratory species found throughout much of the eastern half of the United States from Oklahoma, Iowa, and 

Wisconsin east to Vermont and south to northwestern Florida. For hibernation, Indiana bats prefer limestone 

caves with stable temperatures of 3.3°C to 6.1°C (38°F to 43°F) and high relative humidity. As with the gray 

bat, few caves meet the specific roost requirements of the species. Subsequently, more than 85% of the 

population hibernates in only nine sites. However, Indiana bats have been found hibernating in a few 

abandoned mines, a tunnel, and a hydroelectric dam. The bats hibernate from October to April, depending on 

climatic conditions. Density in tightly packed clusters is usually estimated at 3228 bats per square meter (300 

bats per square foot), although as many as 5165 bats per square meter (480 per square foot) have been 

reported. 

Female Indiana bats depart hibernation caves before males and arrive at summer maternity roosts in 

mid-May. A single offspring is born between late June and early July. The young bats can fly within a month 

of birth. Early researchers considered floodplain and riparian forest to be the primary roosting and foraging 

habitats used during the summer by the Indiana bat, and these forest types unquestionably are important. 

More recently, upland forest has been shown to be used by Indiana bats for roosting. Within the range of the 

species, the existence of Indiana bats in a particular area may be governed by the availability of natural roost 

structures, primarily standing dead trees with loose bark. The suitability of any tree as a roost site is 

determined by (1) its condition (dead or alive), (2) the quantity of loose bark, (3) the tree’s solar exposure and 

location in relation to other trees, and (4) the tree’s spatial relationship to water sources and foraging areas. 

The most important characteristic of roost trees is probably not species but structure (i.e., exfoliating bark 

with space for bats to roost between the bark and the bole of the tree). To a limited extent, tree cavities and 

crevices are also used for roosting. Maternity colonies use multiple primary roost trees, which are used by a 

majority of the bats most of the summer, and a number of “secondary” roosts, which are used intermittently 

and by fewer bats, especially during periods of precipitation or extreme temperatures. The summer roost of 

adult males is often near maternity roosts, but where most spend the day is unknown. Others remain near the 

hibernaculum, and a few males are found in other caves during summer. Researchers have found that primary 

roosts are generally in openings or at the edge of forest stands, while alternate roosts can be either in the open 

or in the interior of the forest stands. Indiana bats use roosts in the spring and fall similar to those selected 

during the summer. During the fall, when Indiana bats swarm and mate at their hibernacula, male bats roost in 

trees nearby during the day and fly to the cave during the night. 
01-217(doc)/093002 7

Indiana bats forage in and around the tree canopy of floodplain, riparian, and upland forest. In riparian 

areas, Indiana bats primarily forage around and near riparian and floodplain trees (e.g., sycamore, 

cottonwood, black walnut, black willow, and oaks), and solitary trees and forest edge on the floodplain. 

Streams, associated floodplain forests, and impounded bodies of water (e.g., ponds, wetlands, and reservoirs) 

are preferred foraging habitat for pregnant and lactating Indiana bats, some of which may fly up to 1.5 miles 

from upland roosts. Indiana bats also forage within the canopy of upland forests, over clearings with early 

successional vegetation (e.g., old fields), along the borders of croplands, along wooded fencerows, and over 

farm ponds in pastures. Indiana bats return nightly to their foraging areas. Indiana bats feed strictly on flying 

insects, and their selection of prey items reflects the environment in which they forage. Both aquatic and 

terrestrial insects are consumed. Moths, caddisflies, flies, mosquitoes, and midges are major prey items. Other 

prey include bees, wasps, flying ants, beetles, leafhoppers, and treehoppers. During September, the bats depart 

for hibernation caves. 

Information about the occurrence of Indiana bats on the ORR is limited. Mist netting for bats was 

conducted on LEFPC and its tributaries in May 1992 and again in May–June 1997 (Harvey 1997). The 1997 

survey included portions of lower Bear Creek near its confluence with LEFPC. The creeks in this area 

provided Indiana bat summer roosting and foraging habitat at the time of the surveys. No Indiana bats were 

recorded among the six species captured. 

In Tennessee, the nearest hibernating population of Indiana bats exists in White Oak Blowhole Cave, 

located in Blount County in the western end of the Great Smoky Mountains National Park. This cave has been 

designated as critical habitat for this species. A few Indiana bats also hibernate in Bull Cave, also located in 

Blount County. No maternity roosts have been located on the ORR, or as yet in Tennessee. However, in July 

1999, a small colony of Indiana bats was discovered roosting in a dead hemlock tree on the Cheoah Ranger 

District of the Nantahala National Forest in Graham County, North Carolina. This discovery represents the 

first record of a reproductive female Indiana bat being found south of Kentucky. Recent collections of 

individual Indiana bats have also been recorded from the Cherokee National Forest near Tellico Lake in 

Monroe County, Tennessee. These reports indicate that summer colonies of the species may be present in east 

Tennessee. The habitat from which these individuals were collected is similar to suitable habitat found on the 

ORR. 

Although there is no suitable summer roosting habitat for the Indiana bat on the ORR, there is probably 

suitable habitat along forested portions of Chestnut Ridge and Pine Ridge, which border the Y-12 complex to 

the south and north, respectively, in upper Bear Creek Valley. Suitable foraging habitat for Indiana bats 

within the vicinity of the proposed facility includes the Clinch River (Melton Hill Lake) and Poplar Creek at 

ETTP. Upper Bear Creek and EFPC are narrow, small streams and are considered suboptimal for frequent 

foraging for Indiana bats. Although unlikely, a maternity colony, an adult male colony, or individual Indiana 

bats could use roosting habitat located in the vicinity of the proposed project in upper Bear Creek Valley. Any 

potential adverse impacts to the Indiana bat would be eliminated by not cutting down any trees during the 

Indiana bat’s summer roosting season from May through September. Such actions should prevent the loss of 

any bats that otherwise might be using the trees for rearing young and should also eliminate the need for mist 

netting or detailed surveys. 

Both the Y-12 Complex and ETTP are highly industrialized areas with little natural habitat that remains 

immediately surrounding the complex. Additional clearing of the woodland at either site should not affect 

bats because of the poor quality habitat. If new construction was required, these activities would also not 

directly impact any of the potential foraging habitat that exists in the vicinity. Any construction activities 

would occur only during the day, so any foraging by Indiana bats would not be disrupted. Activities 

associated with the operation of the proposed facility would also primarily occur during the day and would 

not disrupt any foraging Indiana bats near the site. In addition, no significant emissions or effluents would be 
01-217(doc)/093002 8

produced by the facility that could directly impact foraging Indiana bats or indirectly affect aquatic insect 

fauna that the Indiana bats would prey on. 

2.3 PINK MUCKET (Lampsilis abrupta) 

The endangered pink mucket (also called pink mucket pearlymussel, L. orbiculata) is a freshwater 

mussel in the Unionidae family (CMI−FWIE 2002; EPA 2000). The pink mucket is found in medium to large 

rivers. It seems to prefer larger rivers with moderate to fast-flowing water, at depths from 0.5 to 8.0 m (1.6 to 

26.2 ft). The species has been found in substrates including gravel, cobble, sand, or boulders. Silt clogs the 

species’ siphon so silty substrates and water columns are not conducive to the species being present. Habitat 

of the glochidia is initially within the gills of the female, then in the water column, and finally attached to a 

suitable fish host. Habitat requirements for the juvenile stage are unknown. Any alteration of the life-stagespecific habitats during the pink mucket’s lifecycle would likely affect the long-term success of a population. 

In addition, impoundments and surface water contaminants are known to adversely affect this species and 

contribute to its decline in numbers. 

The species has an elliptical-shaped shell and is generally about 10.2 cm (4 in.) long, 6.1 cm (2.4 in.) 

wide, and 7.6 cm (3 in.) high (CMI−FWIE 2002; EPA 2000). The valves are heavy and thick. The species is 

sexually dimorphic, with both males and females having rounded anterior margins, but with males having a 

pointed posterior margins and females a truncated, expanded posterior to accommodate the gravid condition. 

Young mussels have a yellow to brown shell that is smooth and glossy with green rays, while older specimens 

are dull brown. The nacre color varies from white to pink, with the posterior margin iridescent. The early life 

stage of the mussel, glochidia, is an obligate parasite on the gills or fins of fish, but the required fish host 

species are unknown. The adult mussels are filter feeders and consume particulate matter that is suspended in 

the water column. Identifiable stomach contents from mussels invariably include mud, desmids, diatoms, 

protozoa, and zooplankton. However, studies on the food habits for this species have not been conducted, so 

its specific food requirements are not known. The species has no known commercial value. The reproductive 

cycle of the pink mucket is presumed to be similar to that of other freshwater mussels. Males release sperm 

into the water column, which is then taken up by the females during siphoning and results in the eggs being 

fertilized. The embryos develop into the glochidia inside the female and are then released into the water 

column. The glochidia must then attach to a suitable fish host for metamorphosis to the free-living juvenile 

stage. There is no information on the population biology for this species. 

Currently, the pink mucket is known in 16 rivers and tributaries from 7 states, with the greatest 

concentrations in the Tennessee (Tennessee, Alabama) and Cumberland (Tennessee, Kentucky) rivers and in 

the Osage and Meramec rivers in Missouri. Smaller populations have been found in the Clinch River 

(Tennessee); Green River (Kentucky); Kanawha River (West Virginia); Big, Black, and Little Black and 

Gasconde rivers (Missouri); and Current and Spring rivers (Arkansas). The FWS indicated that the pink 

mucket is known to occur near the project area (FWS 2002). Pink muckets have been found in the Clinch 

River adjacent to the ORR. However, pink muckets have not been observed at the Y-12 Complex or ETTP. 

Furthermore, the aquatic habitat in the streams closest to the proposed facility (Bear Creek, and EFPC) is not 

appropriate to support the pink mucket. Both are small streams with low flow. Both streams also receive low 

levels of various contaminant inputs from several sources. Appropriate engineering controls, administrative 

procedures, and emergency management protocols would prevent any releases and off-site migration of 

potential contaminants from either site. Therefore, the combination of unsuitable stream sizes, improper 

habitat, and presence of contaminants leads DOE to conclude that the presence of pink mucket pearlymussel 

on or near the Y-12 Complex or ETTP is extremely unlikely. Likewise, implementation of the uranium 

management program at the Y-12 Complex would not have any adverse impacts on this species. 
01-217(doc)/093002 9

3. REFERENCES 

CMI−FWIE (Conservation Management Institute−Fish and Wildlife Information Exchange). 2000. TN00194 

Pink Musket Pearly Mussel Lampsilis orbiculata orbiculata, Tennessee Animal Biogeographic System 

(TABS). Web site: http://fwie.fw.vt.edu/TN/TN00194.htm. Date April 2000. Conservation Management 

Institute, College of Natural Resources, Virginia Tech, Blacksburg, Virginia. 

DOE (U.S. Department of Energy). 1997a. Report on the Remedial Investigation of Bear Creek Valley at the 

Oak Ridge Y-12 Plant, Oak Ridge Tennessee, Volume I, DOE/OR/01-1455/V1&D2, U.S. Department of 

Energy, Office of Environmental Management, Oak Ridge, TN. 

DOE. 1997b. Final Environmental Assessment, Lease of Land and Facilities within the East Tennessee 

Technology Park, Oak Ridge, Tennessee, DOE/EA-1175, U.S. Department of Energy, Oak Ridge 

Operations, Oak Ridge, TN. 

DOE. 1998. Report on the Remedial Investigation of Upper East Fork Poplar Creek Characterization Area at 

the Oak Ridge Y-12 Plant, Oak Ridge, Tennessee, Volume I, DOE/OR/01-1641/V1&V2, U.S. Department 

of Energy, Office of Environmental Management, Oak Ridge, TN. 

DOE. 1999. Construction/Relocation of Access Road at Oak Ridge National Laboratory, Oak Ridge, 

Tennessee, CX-TRU-98-007, U.S. Department of Energy, Oak Ridge Operations Office, Oak Ridge, 

Tennessee. 

DOE. 2001a. Final Sitewide Environmental Impact Statement for the Y-12 National Security Complex, 

DOE/EIS-0309, U.S. Department of Energy, Oak Ridge Y-12 Area Office, National Nuclear Security 

Administration. 

DOE. 2001b. Wetlands Assessment, Reindustrialization Program at the Portsmouth Gaseous Diffusion Plant,

Piketon, Ohio, December. 

DOE. 2002. Draft Programmatic Environmental Assessment (PEA) for the U.S. Department of Energy, Oak 

Ridge Operations Implementation of a Comprehensive Management Program for the Storage, 

Transportation, and Disposition of Potentially Reusable Uranium Materials, DOE/EA-1393. Prepared 

for the U.S. Department of Energy by Science Applications International Corporation, Oak Ridge, 

Tennessee, May. 

EPA (U.S. Environmental Protection Agency). 2000. “Pink mucket pearly mussel [Lampsilis orbiculata].” Office 

of Pesticide Programs. Available at <http://www/epa.gov/espp/arkansas/seviert.htm>.

FWS (U.S. Fish and Wildlife Service). 1991. Endangered and Threatened Species of the Southeastern United 

States (The Red Book), FWS Region 4. February 1991.

FWS. 1999a. Indiana Bat. Asheville Field Office. August 1999. 

FWS. 1999b. Agency Draft Indiana Bat (Myotis sodalis) Revised Recovery Plan. Fort Snelling, Minnesota. 

53 pp. 

FWS. 2000. The Indiana Bat in Western North Carolina, A Status Summary Update. Asheville Field Office. 

April.
01-217(doc)/093002 10

FWS. 2002. Letter from Dr. Lee A. Barclay, U.S. Fish and Wildlife Service, Cookeville, Tennessee, to 

Mr. David Allen, U.S. Department of Energy, Oak Ridge, Tennessee, June 10. 

Harvey, Michael J. 1992. Bats of the Eastern United States. Arkansas Game and Fish Commission and U.S. 

Fish and Wildlife Service. February. 46 pp. 

Harvey, Michael J. 1997. Survey for Endangered and Threatened Bats on Parcel ED-1, Oak Ridge 

Reservation. July. 24 pp. 

Henry, Hill. 2000. Personal communication from Hill Henry, Tennessee Valley Authority, to Mike Deacon, 

Science Applications International Corporation, May 4, 2000. 

KBWG (Kentucky Bat Working Group). 1997. “Protection and Enhancement Plan for the Indiana Bat.” 

Available at <http://www.biology.eku.edu/bats/indbat-recmanageplan.htm>. June 1997. 

KBWG. 2000. “The Bats of Kentucky.” Available at <http://www.biology.eku.edu/bats>. 

Major, Smoot. 2000. Personal communication from Smoot Major, Tennessee Department of Environment and 

Conservation, Division of Natural Heritage, to Mike Deacon, Science Applications International 

Corporation, May 4, 2000. 

Mitchell, J. M., E. R. Vail, J. W. Webb, J. W. Evans, A. L. King, P. A. Hamlett. 1996. Survey of Protected 

Terrestrial Vertebrates on the Oak Ridge Reservation, ES/ER/TM-188/R1, Final Report. Oak Ridge 

National Laboratory, Oak Ridge, Tennessee. 

Sousa, P.A., DuVall, G.D., Tinker, N., and Hart, M.J. 2001. Cultural Resource Management Plan, 

Department of Energy Oak Ridge Operations Office, Anderson and Roane Counties, Tennessee.

DOE/ORO-2085. 

Webb, Warren. 1996. Personal communication with Deborah Awl, JAYCOR , September 18, 1996. 
01-217(doc)/093002

APPENDIX A 

HAZARD AND ACCIDENT ANALYSIS 

FOR 

URANIUM MANAGEMENT PROGRAMMATIC ENVIRONMENTAL 

ASSESSMENT 
01-217(doc)/093002
01-217(doc)/093002 A-iii 

TABLE OF CONTENTS 

LIST OF FIGURES .................................................................................................................................A-iv

LIST OF TABLES...................................................................................................................................A-iv

ACRONYMS...........................................................................................................................................A-iv

A.1 INTRODUCTION.............................................................................................................................A-1

A.2 ROUTINE OPERATIONS ...............................................................................................................A-3

A.3 ACCIDENTS ....................................................................................................................................A-4

A.3.1 Postulated Accident Scenarios................................................................................................A-4

A.3.1.1 Fires..........................................................................................................................A-5

A.3.1.2 Container breach ......................................................................................................A-6

A.3.1.3 Natural phenomena...................................................................................................A-6

A.3.2 Development of Source Terms for Accident Sequences.........................................................A-7

A.3.3 Evaluation of Source Term Parameters and Frequencies........................................................A-7

A.3.3.1 Container breach accidents.......................................................................................A-8

A.3.3.2 Facility fires..............................................................................................................A-8

A.3.3.3 Seismic event............................................................................................................A-9

A.3.4 Results...................................................................................................................................A-10

A.3.4.1 Source terms for bounding accident scenarios .......................................................A-10

A.3.4.2 Consequences for bounding accident scenarios .....................................................A-12

A.4 PUBLIC AND WORKER RISK SUMMARY...............................................................................A-18

A.5 REFERENCES................................................................................................................................A-22
01-217(doc)/093002 A-iv 

LIST OF FIGURES 

A.1 Frequency and consequence ranking matrix ...............................................................................A-19

LIST OF TABLES 

A.1 Uranium management interim storage alternatives .......................................................................A-1

A.2 Uranium management disposition options ....................................................................................A-2

A.3 Uranium management interim storage inventories........................................................................A-2

A.4 Uranium management disposition option inventories ...................................................................A-3

A.5 Postulated accidents identified for uranium management activities..............................................A-4

A.6 Frequency classes considered in accident analysis........................................................................A-5

A.7 Natural phenomena intensities.......................................................................................................A-6

A.8 Source term parameters for container breach accidents ................................................................A-8

A.9 Source terms due to bounding accident scenarios .......................................................................A-10

A.10 Distances and dispersion parameters for ground-level releases ..................................................A-12

A.11 Radiological consequences due to bounding accident scenarios.................................................A-14

A.12 Toxicological consequences due to bounding accident scenarios...............................................A-16

A.13 Consequence categories for public exposure...............................................................................A-18

A.14 Consequence categories for worker exposure .............................................................................A-18

A.15 Risks due to normal operations and accidents.............................................................................A-20

ACRONYMS 

ARF airborne release fraction 

DOE U.S. Department of Energy 

DR damage ratio 

ERPG Emergency Response Planning Guideline 

HC-2 Hazard Category 2 

IDLH Immediately Dangerous to Life and Health 

INEEL Idaho National Engineering and Environmental Laboratory 

LEU low-enriched uranium 

MAR material-at-risk 

mph miles per hour 

MTU metric tons of uranium 

N/A not applicable 

NU normal uranium 

PC-3 Performance Category 3 

PEA programmatic environmental assessment 

PGDP Paducah Gaseous Diffusion Plant 

PORTS Portsmouth Gaseous Diffusion Plant 

RF respirable fraction 

SRS Savannah River Site 
01-217(doc)/093002 A-1 

APPENDIX A 

HAZARD AND ACCIDENT ANALYSIS FOR 

URANIUM MANAGEMENT PROGAMMATIC ENVIRONMENTAL 

ASSESSMENT

A.1 INTRODUCTION 

 This appendix discusses the systematic identification and assessment of hazards associated with 

uranium management activities for the U.S. Department of Energy (DOE). This analysis includes a 

semiquantitative evaluation of the potential internal hazards, natural phenomena hazards, and other 

external events that could cause the identified hazards to develop into accidents. This appendix presents 

the potential consequences and risks to workers (immediate and co-located) and members of the public. 

Risks are evaluated for routine operations and nonroutine (accident) conditions. 

 Hazards and accidents are considered for a number of interim storage alternatives and disposition 

options, as described in Chap. 2 of the programmatic environmental assessment and summarized in 

Tables A.1 and A.2. Inventories for each interim storage alternative and disposition option are shown in 

Tables A.3 and A.4. 

Table A.1. Uranium management interim storage alternatives 

Alternative Discussion 

No Action Continued storage at current sites. Total material included 

in the PEA is 14,200 MTU 

Centralized storage at a single DOE site All material transferred to a single, centralized DOE 

storage location 

Centralized storage at a single 

commercial site 

All material transferred to a single, centralized commercial 

storage location (east or west) 

Partially consolidated storage at several 

DOE sites 

Material is moved to the closest consolidated storage 

location 

Partially consolidated storage at two DOE 

sites 

Consolidate at one eastern DOE site (PORTS) and one 

western DOE site (INEEL) 

Partially consolidated storage at two 

commercial sites 

Consolidate at one eastern commercial site and one western 

commercial site 

Partially consolidated storage based on 

physical form 

Consolidate by physical form (i.e., the site with the largest 

quantity of a specific physical form is the preferred storage 

location for all materials of that form) 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

MTU = metric tons of uranium. 

PEA = programmatic environmental assessment. 

PORTS = Portsmouth Gaseous Diffusion Plant. 
01-217(doc)/093002 A-2 

Table A.2. Uranium management disposition options

Option Discussion 

Commercial processing/domestic sales All material transferred from interim storage to a single 

commercial processing facility or single sales distribution 

point (east or west). Total material included is 14,200 MTU 

Transfer to research facilities Transfer ~50 MTU from interim storage to the furthest 

DOE or other research location 

Transfer to other government agencies Transfer ~2,500 MTU from interim storage to unspecified 

location (use furthest distance already evaluated) 

Foreign sales All LEU/NU (~4,050 MTU) transferred to eastern or 

western port for overseas shipment 

DOE = U.S. Department of Energy. 

LEU = low enriched uranium. 

MTU = metric tons of uranium. 

NU = normal uranium. 

PEA = programmatic environmental assessment. 

Table A.3. Uranium management interim storage inventories

Current storage 

 Additional materials to 

be moved 

Alternative Site/form 

Amount, 

103

 MTU 

Number of 

containers 

 Amount, 

103 MTU 

Number of 

containers 

No Action INEEL 

PGDP 

PORTS 

SRS 

Oak Ridge 

All others 

1.5 

<0.1 

4.4 

3.0 

1.4 

3.9 

639 

8 

24,765 

2,867 

6,431 

37,124 

 N/A N/A 

Centralized storage at single 

DOE site 

INEEL 

PGDP 

PORTS 

SRS 

Oak Ridge 

1.5 

<0.1 

4.4 

3.0 

1.4 

639 

8 

24,765 

2,867 

6,431 

 12.7 

14.2 

9.8 

11.2 

12.8 

71,195 

71,826 

47,069 

68,967 

65,403 

Centralized storage at single 

commercial site 

East, West N/A N/A 14.2 71,834 

Partially consolidated 

storage at several DOE sites 

INEEL 

PGDP 

PORTS 

SRS 

Oak Ridge 

1.5 

<0.1 

4.4 

3.0 

1.4 

639 

8 

24,765 

2,867 

6,431 

 1.7 

0.4 

1.4 

<0.1 

0.4 

21,391 

400 

13,458 

63 

1,812 

Partially consolidated 

storage at two DOE sites 

PORTS 

INEEL 

4.4 

1.5 

24,765 

639 

 6.6 

1.7 

49,705 

22,129 

Partially consolidated 

storage at two commercial 

sites 

East 

West 

N/A 

N/A 

N/A 

N/A 

 11.0 

3.2 

49,705 

22,129 
01-217(doc)/093002 A-3 

Table A.3. Uranium management interim storage inventories (continued)

Current storage 

 Additional materials to 

be moved 

Alternative Site/form 

Amount, 

103

 MTU 

Number of 

containers 

 Amount, 

103 MTU 

Number of 

containers 

Partially consolidated 

storage based on physical 

form 

Compound (PORTS) 

Metal (SRS) 

Misc (PORTS) 

Oxide (PORTS) 

Reactfuel (INEEL) 

Residue (INEEL) 

Source (INEEL) 

1.7 

2.9 

0 

0.9 

0.5 

<0.1 

<0.1 

7,221 

1,088 

0 

15,333 

184 

55 

8 

 <0.1 

6.0 

1.2 

0.5 

0.4 

<0.1 

<0.1 

1,034 

32,918 

4,998 

7,807 

827 

174 

187 

DOE = U.S. Department of Energy. N/A = not applicable. 

INEEL = Idaho National Engineering and PGDP = Paducah Gaseous Diffusion Plant. 

 Environmental Laboratory. PORTS = Portsmouth Gaseous Diffusion Plant. 

MTU = metric tons of uranium. SRS = Savannah River Site. 

Table A.4. Uranium management disposition option inventories

Disposition option Description Material type(s)

Amount 

(103

 MTU) 

Number of 

containers 

Commercial 

processing/domestic 

sales 

All material transferred from interim 

storage to a single commercial 

processing facility or single sales 

distribution point (east or west) 

All 14.2 71,834 

Transfer to research 

facilities 

Transfer ~50 MTU from interim storage 

to the furthest DOE or other research 

location 

DU, NU 

LEU 

0.05 

0.05 

204 

844 

Transfer to other 

government agencies 

Transfer ~2,500 MTU from interim 

storage to unspecified location (use 

furthest distance already evaluated) 

DU, NU 

LEU 

2.5 

2.5 

10,186 

42,188 

Foreign sales All LEU/NU (~4,050 MTU) transferred 

to eastern or western port for overseas 

shipment 

LEU 

NU 

3.3 

0.7 

56,408 

1,432 

DOE = U.S. Department of Energy. MTU = metric tons of uranium. 

DU = depleted uranium. N/A = not applicable. 

LEU = low-enriched uranium. NU = normal uranium. 

 An additional activity to be evaluated for each alternative is the potential to ship small quantities 

[<0.01 metric tons of uranium (MTU)] from any storage location, either centralized or consolidated, to a 

second location such as a university or commercial facility. 

A.2 ROUTINE OPERATIONS 

 During storage or disposition of uranium materials at any of the proposed sites, workers could be 

exposed to direct radiation from surface contamination on storage containers. However, all containers will 

have been checked, overpacked if necessary, and certified for transport before storage. Therefore, worker 

exposure due to routine operations associated with surveillance and maintenance of uranium materials is 

expected to be less than detectable levels. 
01-217(doc)/093002 A-4 

 In addition to surface contamination, radiation dose from the uranium materials can be expected. 

Dose rates from any single container are no more than 3 to 4 mrem/h. The dose rate at a distance of 0.3 m 

(1 ft) from a container is ~1 mrem/h, and the rate at a distance of 6 m (20 ft) is <0.05 mrem/h 

(approximately the same as normal background radiation doses). These dose rates are not affected by 

stacking the containers, because the containers and the materials themselves provide significant shielding. 

These dose rates are considered negligible to any receptor (e.g., facility worker, co-located worker, or 

public). 

A.3 ACCIDENTS 

 Accidents that could occur under the proposed storage alternatives and disposition options are 

analyzed in this section. Potential accidents could be initiated during initial packaging, transportation of 

materials to one or more centralized or consolidated storage locations, storage, and transportation to one 

or more disposition options. Accidents can also be caused by natural phenomena (earthquake and wind). 

Reasonably foreseeable accidents have been screened, and the accidents with the greatest consequences to 

co-located workers and the public have been identified. These are the “bounding” accidents that provide 

an envelope for the consequences of other accidents with less impact. 

 Each consolidated or centralized storage location or disposition site is assumed to consist of one or 

more areas dedicated to the storage (either interim or until further processing or disposition occurs) of 

uranium materials. Fire-suppression systems may be available for storage or disposition in existing buildings. 

On-site fire department response, however, is assumed for all storage alternatives and disposition options. 

A.3.1 Postulated Accident Scenarios 

 A hazard survey of the activities involved in packaging, transporting, and storing various forms and 

quantities of uranium was conducted for six potential storage locations and two generic commercial 

locations. The hazards identified for the storage alternatives are considered bounding for any accidents 

that might occur during the disposition options. The primary focus of the hazard survey was to identify 

those specific hazards that exist for each identified alternative and to evaluate the potential for that hazard 

to develop into an accident. 

 Accidents that could occur during implementation of the proposed action(s) can be grouped into two 

classes. As shown in Table A.5, these classes are fire and container breach. The accidents shown in 

Table A.5 are determined to be “credible,” a term that is used in safety analysis to mean that the accident 

has an annual probability of 1E-6 or greater. Evaluation of accident frequency is largely qualitative and 

results in an estimate of the postulated accident scenarios’ frequencies of occurrence. These are then 

assigned to high, moderate, low, or negligible categories of frequency, such as in the example shown in 

Table A.6. This table is adapted from CCPS (1992) and is similar to a table given in DOE (1994a). 

 The accidents shown in Table A.5 were selected to represent the range of postulated accidents that 

could occur under the proposed alternatives. Accidents are shown for general handling and storage 

operations and are applicable for all alternatives except as noted. Bounding accidents are selected for each 

major type of event in order to establish maximum consequences and risks for each alternative. These 

bounding accidents are discussed below. 

Table A.5. Postulated accidents identified for uranium management activities

Operational events External events 

Activity Fire Container breach Natural phenomena 
01-217(doc)/093002 A-5 

Table A.5. Postulated accidents identified for uranium management activities

Operational events External events 

Activity Fire Container breach Natural phenomena 

Forklift impact with 

stored containers 

Packaging, handling, loading, 

and unloading (not applicable 

for No Action alternative) 

Forklift fire affecting 

small number of 

containers Container(s) dropped 

during handling 

Not applicable 

Containers handled for 

short period of time 

Transportation (not applicable 

for No Action alternative) 

Transport vehicle fire Transport vehicle 

accident 

Not applicable 

Containers handled for 

short period of time 

Forklift impact with 

stored containers 

General handling in storage or 

disposition facility 

Forklift fire affecting 

small number of 

containers Container(s) dropped 

during handling 

Not applicable 

Containers handled for 

short period of time 

Large fire affecting 

multiple containers in 

single area 

Forklift impact with 

containers 

Storage or processing (includes 

surveillance and maintenance) 

Small fire affecting 

limited number of 

containers 

Corrosion, degradation 

of containers 

Direct release, small 

fires in storage or 

processing area 

Table A.6. Frequency classes considered in accident analysis

Frequency 

category 

Estimated annual 

frequency of occurrence Description 

Anticipated f > 1E-2 Incidents that may occur several times during the lifetime 

of the facility (incidents that occur commonly). 

Unlikely 1E-2 ≥ f > 1E-4 Accidents that are not anticipated to occur during the 

lifetime of the facility. Natural phenomena of this 

probability class include design basis earthquake, 100-year 

flood, maximum wind gust, etc. 

Extremely unlikely 1E-4 ≥ f > 1E-6 Accidents that will probably not occur during the life cycle 

of the facility. This class includes most design basis 

accidents. 

Beyond extremely 

unlikely 

f < 1E-6 Accidents that are not credible. 

A.3.1.1 Fires 

 Fires resulting in releases of uranium are postulated for handling, transportation, storage, and 

disposition operations. The types of fire include gasoline/diesel fuel fires caused by forklift accidents, 

transport vehicle fires, and building fires that spread to involve multiple containers. Due to activation of 

the fire-suppression system and/or fire department response, a building fire would be limited to a 

relatively small area. This is an extremely unlikely event due to minimal ignition sources and combustible 

loading. Forklift fires, involving limited numbers of containers, are more likely but result in substantially 

smaller releases to the atmosphere. 
01-217(doc)/093002 A-6 

A.3.1.2 Container breach 

 Container breach includes events such as releases from leaking (primarily due to long-term 

corrosion); forklift puncture during movement of other containers; dropping during packaging, loading, 

placement into interim storage, or movement in a disposition facility; and damage as the result of a 

transport vehicle accident. 

 Single-container handling accidents are considered “bounding”; these events dominate the risk to 

workers because of their relatively high frequency and the proximity of the workers to any such release. 

Such events include overpacking containers prior to shipment, and moving containers to/from loading 

docks during shipment/receipt. These activities are prone to mechanical stresses in industrial accidents 

such as drops or punctures by a forklift; however, airborne releases resulting from breaches in a single 

container are relatively insignificant compared with releases involving fires. As a result, these events 

usually constitute little hazard to the general public. 

A.3.1.3 Natural phenomena 

 Natural phenomena events, such as high wind and earthquake, have the potential to cause damage to 

buildings and structures leading to consequences that equal or exceed the consequences of operational 

events. With respect to natural phenomena, each potential storage or disposition location can be 

considered Performance Category 3 (PC-3) in accordance with DOE guidelines (DOE 1993). In 

accordance with DOE criteria (DOE 1994b), PC-2 facilities are required to withstand the earthquake, 

tornado, and high wind intensities shown in Table A.7. Although not explicitly determined, it is assumed 

that the uranium storage and disposition facilities are Hazard Category 2 (HC-2) facilities based on DOE 

criteria (DOE 1992). The frequencies shown in Table A.7 represent the frequencies of facility failure 

under challenge from natural phenomena. 

Table A.7. Natural phenomena intensities 

Event Site Intensity Frequency/year 

INEEL 0.17g 

PGDP 0.35g 

PORTS 0.19g 

SRS 0.18g 

Oak Ridge 0.19g 

Generic eastern (assumed 

same as PORTS) 

0.19g 

Earthquake 

Generic western (assumed 

same as INEEL) 

0.17g 

5E-4 

INEEL N/A 

PGDP 144 mph 

PORTS 110 mph 

SRS 137 mph 

Oak Ridge 113 mph 

Generic eastern 110 mph 

Tornado 

Generic western N/A 

2E-5 

Straight wind All 70 mph 1E-3 

INEEL = Idaho National Engineering and Environmental Laboratory. 

mph = miles per hour. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 
01-217(doc)/093002 A-7 

 During the seismic event defined above, all facility structures are assumed to be destroyed, and 

nothing but rubble remains. All utilities, including fire suppression, are lost. All releases are at ground 

level. Hazardous materials that can be suspended in air in respirable form and be available for transport 

are considered to be released from direct seismic accelerations. 

 Following the direct seismic event, a number of small fires may occur due to electrical shorts or 

downed power lines. Any fires would be scattered throughout the rubble and would be exposed to the 

outside elements, since no building structure remains. The top layer of rubble would consist primarily of 

noncombustible materials such as reinforced concrete and structural steel from buildings, or structural 

supports from tension-support structures. The fire is assumed to be slow-burning amid rubble and 

fallen/breached containers. All fire mitigation facilities are assumed destroyed, and all roadways are 

blocked by debris. Therefore, there is no fire mitigation by either the on-site fire department or other 

outside agencies. 

 Seismic events are used as the surrogate initiator for straight winds or tornadoes, because standard 

atmospheric dispersion modeling predicts greater dispersion (and, therefore, greatly reduced airborne 

concentration) for high wind conditions than for the stable wind conditions assumed to be present during 

earthquakes (Hanna et al. 1982). Existing analyses in DOE safety analysis reports suggest that seismic 

events generally bound the risks of winds or tornadoes, including the risks from wind-driven projectiles. 

With respect to such projectiles, unpublished preliminary analyses for waste drums stored on outdoor 

pads show that damage from projectiles could exceed damage caused by seismic events primarily because 

of the stability of the drum-stacking arrangement and the lack of protection against projectiles. The same 

phenomenon is assumed to apply to the containers proposed for uranium storage and disposition. To 

appropriately bound potential damage by projectiles to unprotected areas, the damage assumed for 

seismic events is conservatively defined to have higher damage ratios than those that might otherwise be 

used to bound the damage caused by high winds or wind-driven projectiles. 

A.3.2 Development of Source Terms for Accident Sequences 

 The approach taken in this assessment is to convert material-at-risk (MAR) quantities to atmospheric 

source terms using conservative release factors (Hanna et al. 1982). These source term factors, based on 

DOE (1994c), take into account the physical mechanism through which material becomes airborne as well 

as the fraction of airborne materials in the respirable particle size range (<10 microns). The source term 

associated with each accident is the product of four factors that vary for type of materials affected by the 

accident: 

Source term = MAR × DR × ARF × RF , 

where 

 MAR = material at risk, 

 DR = damage ratio, 

 ARF = airborne release fraction, 

 RF = respirable fraction. 

A.3.3 Evaluation of Source Term Parameters and Frequencies 

 This section describes the development of frequency and source term data for handling, 

transportation, storage, and disposition accidents. 
01-217(doc)/093002 A-8 

A.3.3.1 Container breach accidents 

 The dominant contributor to worker risk from hazardous material releases is expected to result from 

mechanical breaches of containers during handling accidents. This expectation stems from the relatively 

high frequency of such occurrences and the proximity of the worker to the point of release in such events. 

Handling accidents include container breaches caused by drops or by impact from forklifts or other 

vehicles. Although one container would generally be breached in an accident, rupture of multiple 

containers could occur in instances when several containers are being handled at a time. 

 Source Term Parameters. The MAR for handling activities generally varies from one to four 

drums, depending on the method of stacking and the arrangement of the array. The maximum MAR for 

each physical form of material and container type is shown in Table A.8. The damage ratio (DR) for the 

MAR depends on several factors, including the physical form of the MAR and the severity of the accident 

stress. In general, breached containers with solid uranium forms (i.e., metal, reactfuel, source) are 

assumed to have DRs no greater than 0.10 (i.e., no more than 10% of the material is directly impacted or 

damaged by the event). For other containers with oxides or other unspecified forms, the single-container 

DR is assumed to be 0.25. The combined airborne release fraction (ARF) × respirable fraction (RF) for 

oxides and other forms subjected to free-fall spill and impaction stress is ~1E-5. The combined ARF × RF 

for solid materials is essentially negligible but is estimated to be 1E-6 as a conservative assumption. 

Table A.8. Source term parameters for container breach accidents

Physical form 

Type of 

container DR ARF × RF 

Compound Drum 0.25 1E-5 

Metal Metal box 1E-6 

 Drum 

0.10 

Miscellaneous Drum 0.25 1E-5 

Oxide Metal box 1E-5 

 Drum 

0.25 

Reactfuel Metal box 1E-6 

 Drum 

0.10 

Residue Drum 0.25 1E-5 

Source Drum 0.25 1E-5 

ARF = airborne release fraction. 

DR = damage ratio. 

RF = respirable fraction. 

 Frequency. On the basis of numerous studies evaluated for other environmental impact statements, a 

probability of one handling error per 10,000 containers handled is used in this analysis (WSRC 1994). It 

is assumed that two severe breaches of confinement occur for each inventory of 10,000 containers 

handled. All containers will be packaged, loaded for transport, and moved into an interim storage location 

within a relatively short period of time (assumed to be no more than 6 months). All containers will be 

handled again for transport to a disposition option. Based on the estimated total number of containers 

handled at any given location (see Tables A.3 and A.4), the frequency of container breach due to handling 

accidents is >1E-2/year (anticipated). 

A.3.3.2 Facility fires 

 For the purposes of this assessment, fire in a storage or disposition facility is assumed to bound the 

risk to workers and the public from fires involving smaller numbers of containers due to forklift or other 
01-217(doc)/093002 A-9 

vehicle accidents. This event is a facility fire mitigated by the fire-suppression system and/or fire 

department response, and involves a limited area at a storage or disposition location. 

 Source Term Parameters. The MAR is assumed to be no more than 10% of the inventory at a storage 

or disposition location under any alternative (see Tables A.2 and A.3). The DR for materials in metal 

containers exposed to fires is 0.1. In addition, no more than 10% of the surface area of the solid forms (i.e., 

metal, reactfuel, and source) are exposed to the fire and subject to oxidation (overall DR of 0.01 for these 

materials). The ARF and RF for airborne release of particulates during relatively low-temperature (<900o

C) 

oxidation are 1E-4 and 1.0, respectively. For composite solids (all other physical forms), the ARF and RF are 

6E-3 and 1E-2, respectively. 

 Frequency. Although fire data from DOE sites indicate that facility fires are credible, fires of this 

magnitude in storage or disposition facilities with low combustible loading and limited ignition sources 

are considered unlikely. 

A.3.3.3 Seismic event 

 The dominant contributor to risk from uranium releases is expected to result from breaches of 

containers in an earthquake followed by a number of small fires. The event would impact all containers in 

a facility. 

 Source Term Parameters. The MAR is shown in Tables A.3 and A.4. The DR for the direct release 

is based on an evaluation of waste container storage in a DOE facility similar to those that might be used 

for storing these materials (Hand 1998). Overall DRs for stacked storage containers include the following: 

• Five percent of the containers on the lowest level fall, as do 10% from the middle layer(s) and 

15% from the top layer, for an overall fraction of 10% for containers falling from stacked storage 

arrays. This fraction applies to DU and NU materials that are stacked four high, and is conservative 

for LEU materials that are only stacked two high. 

• Of the containers that fall, ~25% are breached. 

• Of the containers that are breached, ~25% of the material is spilled outside the container for solid 

materials and 100% for composite materials. 

 Therefore, the DRs for materials initially released during a seismic event are: 

• Solids: DR = 0.10 × 0.25 × 0.25 = 0.00625. 

• Composites: DR = 0.10 × 0.25 × 1.0 = 0.025. 

 The combined ARF × RFs for solids and composite forms are the same as those for container 

handling events. Release factors for subsequent fires are the same as those described for facility fires; 

however, the MAR is 10% of the actual inventory because the fires are small, distributed throughout the 

facility, and impact only the outside layers of the rubble and fallen/breached containers. 

 Frequency. The annual frequencies of seismic events exceeding the design basis for HC-2 facilities 

were shown in Table A.7. Conditional probabilities are estimated to be 0.10 for inducing a number of 

unmitigated fires. The overall frequency for each site is, therefore, 5E-5/year (extremely unlikely). 
01-217(doc)/093002 A-10 

A.3.4 Results 

 Radiological and toxicological source terms and consequences for the bounding accident scenarios 

are discussed in this section. 

A.3.4.1 Source terms for bounding accident scenarios 

 Radiological airborne source terms are estimated based on MARs and release parameters identified in 

Sect. A.3.3 and are expressed in units of grams. The activity (Ci/g) for each type of material released is 

based on an assumed 20% 235U for low-enriched uranium with a specific activity of 7.0E-7 Ci/g. This 

activity is considered bounding for all types of uranium considered in this evaluation because the actual 

distribution of material is ~71% depleted uranium, which has a specific activity of ~3.4E-7 Ci/g. The higher 

activity is used to estimate all radiological airborne source terms in units of curies. These source term 

estimates are shown in Table A.9 for the interim storage alternatives and disposition options. For the 

disposition options, it is assumed that the maximum amount for each option (shown in Table A.4) is moved 

to a single disposition location. The distribution of physical form of the materials included in the transfer to 

research facility and transfer to other government agency is assumed to be the same as the overall 

distribution of physical forms shown in Table A.1. The distribution of physical form for the foreign sales 

option is the same as that for the entire inventory of 4050 MTU of LEU/NU included in that option. 

 Toxicological airborne release rates are estimated based on an assumed release duration of 1 h for the 

total amount released and are expressed in units of mg/sec. These release rate estimates are also shown in 

Table A.9. 

Table A.9. Source terms due to bounding accident scenarios

Alternative/ 

Option Accident scenario Site 

Airborne source 

term, Ci 

Airborne release 

rate, mg/sec 

All General container handling All 1.71E-06 1.84E+00 

INEEL 1.08E-04 4.28E+01 

PGDP 4.38E-07 1.74E-01 

PORTS 1.25E-03 4.94E+02 

SRS 2.46E-04 9.78E+01 

Oak Ridge 1.18E-04 4.69E+01 

No Action Facility fire 

Max othera

 1.46E-04 5.79E+01 

INEEL 7.32E-06 2.90E+00 

PGDP 1.83E-07 7.25E-02 

PORTS 4.77E-04 1.89E+02 

SRS 3.11E-05 1.23E+01 

Oak Ridge 1.46E-05 5.80E+00 

Seismic (direct release) 

Max othera

 6.08E-05 2.41E+01 

INEEL 7.05E-06 2.80E+00 

PGDP 1.10E-07 4.35E-02 

PORTS 2.89E-04 1.15E+02 

SRS 2.37E-05 9.40E+00 

Oak Ridge 1.12E-05 4.45E+00 

No Action (continued) Seismic (fire) 

Max othera

 3.65E-05 1.45E+01 
01-217(doc)/093002 A-11 

Table A.9. Source terms due to bounding accident scenarios (continued)

Alternative/ 

Option Accident scenario Site 

Airborne source 

term, Ci 

Airborne release 

rate, mg/sec 

Facility fire All 2.56E-03 1.01E+03 

Seismic (direct release) All 8.24E-04 3.27E+02 

Centralized storage at a 

single site (includes 

commercial 

processing/domestic 

sales disposition 

option) 

Seismic (fire) All 5.11E-04 2.03E+02 

INEEL 2.49E-04 9.89E+01 

PGDP 3.73E-05 1.48E+01 

PORTS 1.73E-03 6.80E+02 

SRS 2.52E-04 1.00E+02 

Facility fire 

Oak Ridge 3.04E-04 1.21E+02 

INEEL 2.67E-05 1.06E+01 

PGDP 7.50E-06 2.98E+00 

PORTS 6.64E-04 2.63E+02 

SRS 3.35E-05 1.33E+01 

Seismic (direct release) 

Oak Ridge 9.21E-05 3.66E+01 

INEEL 2.15E-05 8.52E+00 

PGDP 5.07E-06 2.01E+00 

PORTS 4.02E-04 1.59E+02 

SRS 2.51E-05 9.97E+00 

Partially consolidated 

storage at several DOE 

sites 

Seismic (fire) 

Oak Ridge 5.77E-05 2.29E+01 

Facility fire East 2.30E-03 9.13E+02 

West 2.57E-04 1.02E+02 

Seismic (direct release) East 7.94E-04 3.15E+02 

West 2.99E-05 1.19E+01 

East 4.88E-04 1.94E+02 

Partially consolidated 

storage at two sites 

Seismic (fire) 

West 2.34E-05 9.29E+00 

Facility fire PORTS 1.86E-03 4.38E+02 

 SRS 6.22E-04 2.47E+02 

 INEEL 7.60E-05 3.01E+01 

Seismic (direct release) PORTS 7.75E-04 3.07E+02 

 SRS 3.89E-05 1.54E+01 

 INEEL 1.01E-05 4.01E+00 

Seismic (fire) PORTS 4.65E-04 1.84E+02 

 SRS 3.89E-05 1.54E+01 

Partially consolidated 

storage based on 

physical form 

 INEEL 7.58E-06 3.01E+00 

Facility fire Generic 8.98E-06 3.56E+00 

Seismic (direct release) Generic 2.89E-06 1.15E+00 

Transfer to research 

facility 

Seismic (fire) Generic 1.80E-06 7.13E-01 

Facility fire Generic 4.49E-04 1.78E+02 

Seismic (direct release) Generic 1.45E-04 5.74E+01 

Transfer to other 

government agency 

Seismic (fire) Generic 8.98E-05 3.56E+01 
01-217(doc)/093002 A-12 

Table A.9. Source terms due to bounding accident scenarios (continued)

Alternative/ 

Option Accident scenario Site 

Airborne source 

term, Ci 

Airborne release 

rate, mg/sec 

Facility fire Generic 8.88E-04 3.52E+02 

Seismic (direct release) Generic 3.12E-04 1.24E+02 

Foreign sales 

Seismic (fire) Generic 1.91E-04 7.60E+01 

a

Max other represents the largest single amount at any site other than the DOE consolidated storage locations. 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

A.3.4.2 Consequences for bounding accident scenarios 

 Consequences to facility workers, co-located workers (assumed to be 100 m from the release 

point), and the public are estimated for each bounding accident scenario for each storage or disposition 

location. For the facility worker and co-located worker, the consequences are the same regardless of 

site. For the public, consequences vary depending on distances to the site boundaries. Distances and 

associated dispersion parameters for each site are shown in Table A.10 for ground-level releases 

(container breach events and direct seismic event). 

Table A.10. Distances and dispersion parameters for ground-level releases

Storage location 

Distance to site 

boundary, m 

Dispersion parameter 

χ/Q, sec/m3

INEEL 526 1.56E-03 

PGDP 511 1.56E-03 

PORTS 715 8.47E-04 

SRS 727 8.47E-04 

Oak Ridge 537 1.56E-03 

Generic eastern (assumed 

same as PORTS) 

N/A 8.47E-04 

Generic western (assumed 

same as INEEL) 

N/A 1.56E-03 

Max other; disposition 

options (worst-case) 

N/A 1.56E-03 

INEEL = Idaho National Engineering and Environmental Laboratory. 

N/A = not applicable. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

 For fires, the release point is elevated due to hot air buoyancy effects from fires. Although not 

specifically evaluated, the release height is estimated based on the model described in U.S. Army 

(1981). The maximum dispersion parameter occurs at a distance of 270 m from the release point for an 

elevated release. This value (3.51E-04 sec/m3

) is used for releases due to fires for all sites regardless of 
01-217(doc)/093002 A-13 

distance to the site boundary and is, therefore, conservative (i.e., dispersion parameters due to elevated 

releases for receptors located at other distances are lower). 

 Dispersion parameters are based on a point-source Gaussian dispersion model described by Hand et 

al. (1982) and are evaluated for F-Class wind stability with wind speed of 1.5 m/sec. All receptors are 

considered to be at ground level. 

 Consequences are shown in Tables A.11 and A.12 for all receptors. Other parameters used in 

estimating consequences include the following: 

• Breathing rate of 3.3E-4 m3

/sec based on recommendations from the International Commission on 

Radiological Protection. 

• Inhalation 50-year committed effective dose equivalent dose conversion factor for uranium of 

1.2E+8 rem/Ci (DOE 1988). 

• Consequences to facility workers based on instantaneous dispersion into a hemisphere 10 m in 

diameter. The worker walks through the hemisphere at a rate of 1 m/sec for a maximum 

exposure time of 10 sec. Consequences to facility workers during fires or natural 

phenomena events are considered to be negligible because these workers are assumed to evacuate 

the area before significant exposure can occur. This assumption is based on standard DOE 

site emergency response procedures that require facility worker evacuation in the event of 

accidents. 

 For fires, it is assumed that the co-located worker and the public are both exposed to the 

maximum downwind consequences. This is a conservative assumption because, in most cases, the 

location of maximum consequence occurs at a distance beyond the location of the co-located worker 

(i.e., 270 m vs. 100 m for the co-located worker). If actual dispersion parameters for elevated releases 

and receptors at 100 m were used, the estimated consequences would be significantly less. 

 Exposure duration is assumed to be the same as release duration for all events. This is a 

conservative assumption for fires, because downwind receptors are not likely to remain in a smoke 

plume once a fire is detected, and fire duration is several hours. For container handling events or direct 

release from a seismic event, it is also a conservative assumption because the material forms are such 

that no hazardous materials must become dislodged before they become airborne, and the overall 

release rate is slow relative to the rate of uptake by the receptor. 
01-217(doc)/093002 A-14 Table A.11. Radiological consequences due to bounding accident scenarios Radiological consequences, rem Alternative/ Option Accident scenario Site Facility worker Co-located worker Public 

INEEL, PGDP, Oak Ridge All General container 7.08E-03 6.36E-03 2.89E-04 

handling PORTS, SRS 7.08E-03 6.36E-03 1.57E-04 

INEEL Negligible 1.51E-03 1.51E-03 

PGDP Negligible 6.15E-06 6.15E-06 

PORTS Negligible 1.75E-02 1.75E-02 

SRS Negligible 3.46E-03 3.46E-03 

Oak Ridge Negligible 1.66E-03 1.66E-03 

Facility fire Max othera Negligible 2.05E-03 2.05E-03 

INEEL Negligible 1.01E-02 5.55E-04 

PGDP Negligible 2.52E-04 1.29E-05 

PORTS Negligible 6.57E-01 2.02E-02 

SRS Negligible 4.29E-02 1.38E-03 

Oak Ridge Negligible 2.02E-02 1.07E-03 

No Action Seismic Max othera Negligible 8.39E-02 4.30E-03 

Facility fire All Negligible 3.59E-02 3.59E-02 

INEEL, PGDP, Oak 

Ridge 

Negligible 1.14E+00 5.85E-02 

Centralized storage at a single site (includes commercial processing/ domestic sales disposition option) 

Seismic 

PORTS, SRS Negligible 1.14E+00 3.50E-02 

INEEL Negligible 3.50E-03 3.50E-03 

PGDP Negligible 5.23E-04 5.23E-04 

PORTS Negligible 2.40E-02 2.40E-02 

SRS Negligible 3.53E-03 3.53E-03 

Facility fire 

Oak Ridge Negligible 4.27E-03 4.27E-03 

INEEL Negligible 3.69E-02 1.97E-03 

PGDP Negligible 1.03E-02 5.39E-04 

PORTS Negligible 9.15E-01 2.81E-02 

SRS Negligible 4.67E-02 1.49E-03 

Partially consolidated storage at several DOE sites 

Seismic 

Oak Ridge Negligible 1.27E-01 6.55E-03 

Partially consolidated East Negligible 3.23E-02 3.23E-02 storage at two sites 

Facility fire 

West Negligible 3.61E-03 3.61E-03 
01-217(doc)/093002 A-15 Table A.11. Radiological consequences due to bounding accident scenarios Radiological consequences, rem Alternative/ Option Accident scenario Site Facility worker Co-located worker Public 

Seismic East Negligible 1.09E+00 3.37E-02 

West Negligible 4.14E-02 2.19E-03 

PORTS Negligible 1.07E+00 3.27E-02 

SRS Negligible 5.38E-02 1.86E-03 

Facility fire INEEL Negligible 1.40E-02 7.36E-04 

PORTS Negligible 6.51E-01 2.00E-02 

SRS Negligible 4.96E+00 1.52E-01 

Partially consolidated storage based on physical form Seismic INEEL Negligible 5.43E-03 2.99E-04 Transfer to research Facility fire Generic Negligible 1.26E-04 1.26E-04 facility Seismic Generic Negligible 3.99E-03 2.06E-04 Transfer to other Facility fire Generic Negligible 6.30E-03 6.30E-03 government agency Seismic Generic Negligible 2.00E-01 1.03E-02 Foreign sales Facility fire Generic Negligible 1.25E-02 1.25E-02 

Seismic Generic Negligible 4.31E-01 2.22E-02 

aMax other represents the largest single amount at any site other than the DOE consolidated storage locations. 

DOE = U.S. Department of Energy. INEEL = Idaho National Engineering and Environmental Laboratory. PGDP = Paducah Gaseous Diffusion Plant. PORTS = Portsmouth Gaseous Diffusion Plant. SRS = Savannah River Site. 
01-217(doc)/093002 A-16 Table A.12. Toxicological consequences due to bounding accident scenarios Toxicological consequences, mg/m3 Alternative/ Option Accident scenario Site Facility worker Co-located worker Public 

INEEL, PGDP, Oak Ridge All General container 7.03E-02 6.32E-02 2.87E-03 

handling PORTS, SRS 7.03E-02 6.32E-02 1.56E-03 

INEEL Negligible 1.50E-02 1.50E-02 

PGDP Negligible 6.11E-05 6.11E-05 

PORTS Negligible 1.74E-01 1.74E-01 

SRS Negligible 3.43E-02 3.43E-02 

Oak Ridge Negligible 1.65E-02 1.65E-02 

Facility fire Max othera Negligible 2.03E-02 2.03E-02 

INEEL Negligible 1.01E-01 5.51E-03 

PGDP Negligible 2.50E-03 1.28E-04 

PORTS Negligible 6.53E+00 2.00E-01 

SRS Negligible 4.26E-01 1.37E-02 

Oak Ridge Negligible 2.00E-01 1.06E-02 

No Action Seismic Max othera Negligible 8.33E-01 4.27E-02 

Facility fire All Negligible 3.56E-01 3.56E-01 

INEEL, PGDP, 

Oak Ridge 

Negligible 1.13E+01 5.81E-01 

Centralized storage at a single site (includes commercial processing/domestic sales disposition option) 

Seismic 

PORTS, SRS Negligible 1.13E+01 3.48E-01 

INEEL Negligible 3.47E-02 3.47E-02 

PGDP Negligible 5.19E-03 5.19E-03 

PORTS Negligible 2.39E-01 2.39E-01 

SRS Negligible 3.51E-02 3.51E-02 

Facility fire 

Oak Ridge Negligible 4.24E-02 4.24E-02 

INEEL Negligible 3.66E-01 1.95E-02 

PGDP Negligible 1.03E-01 5.35E-03 

PORTS Negligible 9.09E+00 2.79E-01 

SRS Negligible 4.59E-01 1.47E-02 

Partially consolidated storage at several DOE sites 

Seismic 

Oak Ridge Negligible 1.26E+00 6.51E-02 
01-217(doc)/093002 A-17 Table A.12. Toxicological consequences due to bounding accident scenarios Toxicological consequences, mg/m3 Alternative/ Option Accident scenario Site Facility worker Co-located worker Public 

Facility fire East Negligible 1.09E+01 3.35E-01 

West Negligible 4.11E-02 2.18E-02 

East Negligible 5.53E+01 1.70E+00 

Partially consolidated storage at two sites Seismic West Negligible 4.31E-01 2.29E-02 

PORTS Negligible 2.59E-01 2.59E-01 

SRS Negligible 8.66E-02 8.66E-02 

Facility fire INEEL Negligible 1.06E-02 1.06E-02 

PORTS Negligible 1.06E+01 3.25E-01 

SRS Negligible 5.34E-01 1.85E-02 

Partially consolidated storage based on physical form Seismic INEEL Negligible 1.39E-01 7.31E-03 Transfer to research Facility fire Generic Negligible 1.25E-03 1.25E-03 facility Seismic Generic Negligible 3.96E-02 2.04E-03 Transfer to other Facility fire Generic Negligible 6.26E-02 6.26E-02 government agency Seismic Generic Negligible 1.98E+00 1.02E-01 Foreign sales Facility fire Generic Negligible 1.24E-01 1.24E-01 

Seismic Generic Negligible 4.28E+00 2.20E-01 

aMax other represents the largest single amount at any site other than the DOE consolidated storage locations. 

DOE = U.S. Department of Energy. INEEL = Idaho National Engineering and Environmental Laboratory. PGDP = Paducah Gaseous Diffusion Plant. PORTS = Portsmouth Gaseous Diffusion Plant. SRS = Savannah River Site. 
01-217(doc)/093002 A-18 

 Tables A.11 and A.12 also indicate the maximum consequence level for each scenario for each 

alternative. These levels are based on consequence categories shown in Tables A.13 and A.14. These are 

based on prevailing regulations, DOE Orders, and other DOE standards such as “DOE 1994d.” 

Table A.13. Consequence categories for public exposure

Consequence level 

Consequence category Description Radiological Toxicological 

Negligible Less than low off-site impact <0.1 rem <0.1 × ERPG-2 

Low Negligible off-site impact >0.1 to <5 rem <ERPG-2 

Moderate Minor off-site impact >5 to <25 rem Not defined 

(subjective) 

High Considerable off-site impact >25 rem >ERPG-2 

ERPG = Emergency Response Planning Guideline. 

Table A.14. Consequence categories for worker exposure 

Consequence level 

Consequence category Description Radiological Toxicological 

Negligible Negligible on-site impact <1 rem <0.1 x IDLH 

Low Minor on-site impact >1 to <5 rem <IDLH 

Moderate Moderate on-site impact >5 to <100 rem Not defined 

(subjective) 

High Considerable on-site impact >100 rem >IDLH 

IDLH = Immediately Dangerous to Life and Health. 

 The toxicological consequence levels are expressed in terms of Emergency Response Planning 

Guideline (ERPG) concentrations developed by the American Industrial Hygiene Association. ERPG-2 is 

defined as a threshold concentration that, for exposures of up to 1 h, will not produce irreversible health 

effects in the large majority of the general population. This value (1 mg/m3

 for uranium) is applied for 

public exposure. However, for workers, the Immediately Dangerous to Life and Health (IDLH) value is 

more appropriate. This value (10 mg/m3

 for uranium) is based on effects that might occur to unprotected 

workers as a consequence of a 30-min exposure. Therefore, IDLH values as defined by the National 

Institute for Occupational Safety and Health (NIOSH 1997) are used to define high consequences to 

facility and co-located workers. 

A.4 PUBLIC AND WORKER RISK SUMMARY 

 Public and worker risks due to normal operations and accidents are shown in Table A.15. The risk 

categories are based on the accident frequency and maximum radiological or toxicological consequence 

level as shown in Fig. A.1. These accident scenarios that fall within Regions 7, 8, and 9 of the matrix are 

considered high risk, and those that fall within Regions 4, 5, and 6 are considered moderate risk. Those 

accident scenarios that fall within Regions 1 through 3 of the matrix are considered low risk and represent 

less than a marginal concern. 
01-217(doc)/093002 A-19 

Low Moderate High

Anticipated Unlikely Extremely

Unlikely

Beyond

Extremely

Unlikely

Severity of Consequences

Frequency of Release

Negligible

 1

 2

 3

 4

 5

 6

 7

 8

 9

Combinations that identify situations of concern

Combinations that identify situations of major concern

Fig. A.1. Frequency and consequence ranking matrix.
01-217(doc)/093002 A-20 Table A.15. Risks due to normal operations and accidents Alternative/Option Accident scenario Site Frequency Maximum radiological consequence Maximum toxicologic

consequen

All Normal operations All Anticipated Negligible NegligiblAll General handling events All Anticipated Negligible Negligibl

INEEL, PGDP, SRS, Oak Ridge, Max othera Facility fire Negligible Negligibl

PORTS Unlikely Negligible Low 

INEEL, PGDP, SRS, Oak Ridge, Max othera Negligible Negligibl

No Action Seismic PORTS Extremely unlikely Negligible Low Centralized storage at Facility fire All Unlikely Negligible Low a single site (includes commercial processing/domestic sales disposition option) Seismic All Extremely unlikely Low High 

INEEL, PGDP, SRS, Oak Ridge Facility fire Negligible Negligibl

PORTS 

Unlikely 

Negligible Low 

INEEL, PGDP, SRS, 

Oak Ridge 

Negligible Negligibl

Partially consolidated storage at several DOE sites 

Seismic 

PORTS 

Extremely unlikely 

Negligible Low 

Facility fire East Negligible Low 

West 

Unlikely 

Negligible Negligibl

East Low High 

Partially consolidated storage at two sites 

Seismic 

West 

Extremely unlikely 

Negligible Negligibl

Facility fire PORTS Negligible Low 

INEEL, SRS 

Unlikely 

Negligible Negligibl

PORTS Low High 

Partially consolidated storage based on physical form Seismic 

SRS, INEEL 

Extremely unlikely 

Negligible Negligibl

Transfer to research Facility fire All Unlikely Negligible Negligiblfacility Seismic All Extremely unlikely Negligible NegligiblTransfer to other Facility fire All Unlikely Negligible Negligiblgovernment agency Seismic All Extremely unlikely Negligible Low 
01-217(doc)/093002 A-21 Table A.15. Risks due to normal operations and accidents Alternative/Option Accident scenario Site Frequency Maximum radiological consequence Maximum toxicologic

consequen

Foreign sales Facility fire All Unlikely Negligible Low 

Seismic All Extremely unlikely Negligible Low 

aMax other represents the largest single amount at any site other than the DOE consolidated storage locations. DOE = U.S. Department of Energy. INEEL = Idaho National Engineering and Environmental Laboratory. PGDP = Paducah Gaseous Diffusion Plant. PORTS = Portsmouth Gaseous Diffusion Plant. SRS = Savannah River Site.
01-217(doc)/093002 A-22 

A.5 REFERENCES 

AIHA (American Industrial Hygiene Association). Reference for ERPG-2. 

CCPS (Center for Chemical Process Safety). 1992. Guidelines for Hazard Evaluation Procedures, 

Second Edition with worked examples, American Institute of Chemical Engineers, New York, NY. 

DOE (U.S. Department of Energy). 1988. Internal Dose Conversion Factors for Calculation of Dose to 

the Public, DOE/EH-0071, Washington, D.C. 

DOE (U.S. Department of Energy). 1992. Hazard Categorization and Accident Analysis Techniques for 

Compliance with DOE Order 5480.23, Nuclear Safety Analysis Reports, DOE-STD-1027-92, 

Washington, D.C., Change Notice No. 1, 1997. 

DOE (U.S. Department of Energy). 1993. Natural Phenomena Hazards Performance Categorization 

Guidelines for Structures, Systems, and Components, DOE-STD-1021-93, Washington, D.C. 

DOE (U.S. Department of Energy). 1994a. Preparation Guide for U.S. Department of Energy Nonreactor 

Nuclear Facility Safety Analysis Reports, DOE-STD-3009-94, Washington, D.C. 

DOE (U.S. Department of Energy). 1994b. Natural Phenomena Hazards Design and Evaluation Criteria 

for Department of Energy Facilities, DOE-STD-1020-94, Washington, D.C. 

DOE (U.S. Department of Energy). 1994c. Airborne Release Fractions/Rates and Respirable Fractions 

for Nonreactor Nuclear Facilities, DOE-HDBK-3010-94, Washington, D.C. 

DOE (U.S. Department of Energy). 1994d. Guidance for Preparation of DOE 5480.22 (TSR) and DOE 

5480.23 (SAR) Implementation Plans, DOE-STD-3011-94, Washington, D.C. 

Hand, Frank. 1998. Seismic Evaluation of T, SW/R, WD and HH Buildings and Buildings 22 and 23 at the 

DOE Mound Site, Revision 2, Los Alamos Technical Associates, Inc., Albuquerque, NM. 

Hanna, S.R., et al. 1982. Handbook on Atmospheric Diffusion, DOE/TIC-11223, Atmospheric Turbulence 

and Diffusion Laboratory, National Oceanic and Atmospheric Administration, U.S. Department of Energy, 

Technical Information Center, Oak Ridge, TN. 

NIOSH (National Institute for Occupational Safety and Health). 1997. NIOSH Pocket Guide to Chemical 

Hazards, Washington, D.C. 

U.S. Army. 1981. Handbook for Chemical Hazard Prediction, DARCOM Handbook No. 385-2.1-80, 

U.S. Army Material Development and Readiness Command, National Technical Information Service, 

Springfield, VA. 

WSRC (Westinghouse Savannah River Company). 1994. Savannah River Site Human Error Data Base 

Development for Nonreactor Nuclear Facilities, WSRC-TR-93-581, Aiken, SC. 
01-217(doc)/093002

APPENDIX B 

TRANSPORTATION ANALYSIS 

FOR 

URANIUM MANAGEMENT PROGRAMMATIC 

ENVIRONMENTAL ASSESSMENT
01-217(doc)/093002
01-217(doc)/093002 B-iii

TABLE OF CONTENTS 

LIST OF TABLES...................................................................................................................................B-iii

ACRONYMS...........................................................................................................................................B-iii

B.1 PURPOSE......................................................................................................................................... B-1

B.2 METHOD ......................................................................................................................................... B-1

B.3 ASSUMPTIONS............................................................................................................................... B-2

B.4 COMPUTER SOFTWARE/MODELS............................................................................................. B-3

B.5 RESULTS ......................................................................................................................................... B-4

B.6 REFERENCES ................................................................................................................................. B-7

LIST OF TABLES 

B.1 Fractions of uranium isotopes in DU, NU, and LEU ....................................................................... B-3

B.2 Public collective dose for uranium transportation............................................................................ B-4

B.3 Average individual public dose (mrem)........................................................................................... B-5

B.4 Potential excess latent cancer fatalities (LCFs)................................................................................ B-6

B.5 Collective crew dose ........................................................................................................................ B-6

B.6 Potential traffic fatalities and airborne uranium concentrations....................................................... B-7

ACRONYMS 

DOE U.S. Department of Energy 

DU depleted uranium 

ICRP International Commission on Radiological Protection 

INEEL Idaho National Engineering and Environmental Laboratory 

LCF latent cancer fatality 

LEU low-enriched uranium 

NU normal uranium 

PGDP Paducah Gaseous Diffusion Plant 

PORTS Portsmouth Gaseous Diffusion Plant 

SRS Savannah River Site 

TRAGIS Transportation Routing Analysis Geographic Information System 

vph vehicles per hour 
01-217(doc)/093002 B-iv
01-217(doc)/093002 B-1 

APPENDIX B 

TRANSPORTATION ANALYSIS FOR 

URANIUM MANAGEMENT PROGRAMMATIC 

ENVIRONMENTAL ASSESSMENT 

B.1 PURPOSE 

The purpose of this calculation package is to provide details of the risk analysis of transporting normal 

uranium (NU), depleted uranium (DU), and low-enriched uranium (LEU) to and from a number of sites. 

B.2 METHOD 

Routes were calculated for highway from the 155 origin sites to 11 alternate destinations in the 

United States: 

1. the nearest U.S. Department of Energy (DOE) consolidation site; 

2. Savannah River Site (SRS); 

3. Portsmouth Gaseous Diffusion Plant (PORTS); 

4. Paducah Gaseous Diffusion Plant (PGDP); 

5. Idaho National Engineering and Environmental Laboratory (INEEL); 

6. Oak Ridge National Laboratory and other Oak Ridge facilities; 

7. a “western commercial site,” for which Envirocare in Utah was selected; 

8. an “eastern commercial site,” for which Barnwell in South Carolina was selected; 

9. the nearest DOE consolidation site when consolidating by material form; 

10. PORTS or INEEL, whichever is closer to the origin site; and 

11. Envirocare or Barnwell, whichever is closer to the origin site. 

Rail routes were calculated where appropriate. Route distances and population densities for rural, 

suburban, and urban route segments were calculated using the Transportation Routing Analysis 

Geographic Information System (TRAGIS).1

Two modal options were analyzed: 

1. all shipment by truck, and 

2. shipment by rail where rail was appropriate, and all other shipment by truck (this is called the 

“truck/rail” option). 

Public and occupational doses for incident-free transportation and dose risks for transportation 

accidents were estimated by calculating unit risk factors using RADTRAN 52

 (a transportation risk 

 1

TRAGIS is a routing analysis tool combining graphical interfaces with an extensive highway, rail, and waterway database. 

TRAGIS can be used to calculate detailed routes based on user-specified parameters, and replaces the legacy HIGHWAY and 

INTERLINE routing models. 

2

RADTRAN is the world standard for transportation risk assessment. The code was developed at Sandia National Laboratories. 

RADTRAN combines user-determined meteorological, demographic, transportation, packaging, and material data with health 

physics data to calculate the expected radiological consequences and accident risk of transporting radioactive materials. 
01-217(doc)/093002 B-2 

assessment computer code) [Neuhauser, Kanipe, and Weiner 2000; Chap. 3, 4, and 5] and multiplying the 

unit risk factors by the appropriate route distances and population densities. 

Collective accident dose risks were calculated using the national average truck and rail accident rates 

from Saricks and Tompkins (1999; Tables 4 and 6). Accident dose risks were calculated by calculating a 

unit risk factor (that includes severity and release fractions) using RADTRAN 5, and multiplying by the 

accident rates, distances, and population densities. Traffic fatalities were also taken from Saricks and 

Tompkins (1999; Tables 4 and 6). 

Per-shipment and per-container occupational doses for trans-Atlantic and trans-Pacific shipping were 

calculated using RADTRAN 5 and using data from Appendix J of the Yucca Mountain Environmental 

Impact Statement (DOE 2002). 

B.3 ASSUMPTIONS 

For the incident-free transportation analyses: 

• Trucks were assumed to travel only on interstate or U.S. primary highways, and the speed was taken to 

be 88 km/hour, except during rush hour. Ten percent of urban and suburban truck travel was assumed 

to be during rush hour. Rush hour speed was assumed to be half of the non-rush hour speed. 

• Vehicle densities were assumed to be the standard RADTRAN values: (1) rural: 470 vehicles per 

hour (vph), (2) suburban: 780 vph, and (3) urban: 2800 vph. Rush hour vehicle densities were 

assumed to be twice the non-rush hour vehicle density. 

• Per the truck stop model of Griego, Smith, and Neuhauser (1996), trucks with onboard restroom facilities 

were assumed to stop every 525 miles for rest and refueling for an average time of 20 minutes. Two 

drivers per truck were assumed. 

• Truck crew members were assumed to be 3 m from the cargo and their dose regulated at 2 mrem/hr. 

At stops, one crew member was assumed to stay in the truck at all times. 

• Rail speeds were the standard RADTRAN speeds: (1) rural: 64 kph, (2) suburban: 40 kph, and 

(3) urban: 24 kph. 

• External dose rate (TI) at one meter from the surface is assumed to be 1 mrem/hr from a drum or 

standard waste box, so that adjacent drums would have a total TI of 2 mrem/hr and two layers of 

adjacent drums, 4 mrem/hr. These are conservative assumptions. 

• Crew members aboard transoceanic freighters were assumed to spend two hours per day at a distance 

between one and 16 m from the containers, and half of the time 30 m from the containers. No credit 

was taken for shielding. 

• The maximum transoceanic distance assumed was 14,400 km, port to port. 
01-217(doc)/093002 B-3 

For the transportation accident analysis: 

• All radioactive material released is assumed to be particulate matter with a settling velocity or 0.01 

m/sec. 

• The cargo was assumed to include containers containing DU, NU, and LEU. Accident unit risk 

factors were calculated for DU, NU, and LEU using RADTRAN and using fractions of uranium 

isotopes shown in Table B.1. 

Table B.1. Fractions of uranium isotopes in DU, NU, and LEU 

Radionuclide Fraction in DU Fraction in NU Fraction in LEU 

238U 0.007 0.992 0.969 

235U 0.0025 0.00711 0.03 

234U 0.001 0.0009 0.001 

DU = depleted uranium. 

LEU = low-enriched uranium. 

NU = normal uranium. 

U = uranium. 

• Accident rates were the national average truck and rail accident rates from Saricks and Tompkins 

(1999; Tables 4 and 6). 

• Conditional accident probabilities (severity fractions) and release and aerosol fractions are the same 

as given in Appendix A. 

• It as assumed that 1% of the accidents would result in release of radioactive material, and 99% 

would not result in any damage to cargo. 

• National average meteorological conditions were assumed. Dispersion was calculated using 

RADTRAN, which incorporates a Gaussian dispersion model. The same model and assumptions 

were used to calculate airborne concentrations of uranium.

• Fatality rates for truck and rail accidents are from Saricks and Tompkins (1999; Tables 4 and 6). 

For transoceanic transportation: 

• The longest distance that would be traveled would be 14,400 km, from either the west or east coasts 

of the United States. 

• While the ship is at sea, there is no dose to any member of the public. Only the ship’s crew is 

exposed. An average crew member spends 2 hours per day within 16 m of the cargo, and 22 hours 

per day at 30 m from the cargo. No shielding is assumed. 

B.4 COMPUTER SOFTWARE/MODELS 

Unit risk factors were calculated using RADTRAN 5 (Neuhauser, Kanipe, and Weiner 2000). Route 

segment lengths and population densities were calculated using WebTRAGIS (Johnson and Michelhaugh 

2000). Other calculations were done with a Microsoft Excel spreadsheet. 
01-217(doc)/093002 B-4 

B.5 RESULTS 

Table B.2 shows the collective dose to the public for the two modal options. As is evident from 

Table B.2, collective dose is directly proportional to the total distance traveled; the two consolidation 

options yield the smallest collective dose, and the two east/west options yield collective doses that are not 

much larger. When rail transportation is used, the collective dose is decreased still further, for two 

reasons: (1) rural population densities along rail routes are about 50% to 60% of rural population densities 

along highway routes, and 45% to 75% of any route is rural; and (2) the origin sites that can use rail 

transportation are those that ship the largest number of containers, thus emphasizing the smaller results 

for rail shipment. It should be noted that one railcar is one shipment, so the number of cars in a single 

train that carry uranium does not affect the analysis. 

Accident dose risks are several orders of magnitude smaller than incident-free doses. Even if 10% of 

the accidents were assumed to result in release of radioactive material, the accident dose risks would 

increase by a factor of ten but would still be negligible compared to the incident-free doses. Accident 

dose risks for the truck/rail option are somewhat larger than for the truck-only option, because rail 

accident rates are somewhat larger than heavy truck accident rates. 

Table B.2. Public collective dose for uranium transportation 

Public dose and dose risk (person rem) 

Truck only Truck and rail 

Interim storage alternative Destination Incident-free Accident Incident-free Accident

SRS 34.9 0.0036 23.3 0.0137 

Oak Ridge 23.1 0.00198 18.7 0.00775 

PGDP 22.3 0.00165 18.5 0.0154 

PORTS 18.5 0.00123 18.5 0.00477 

Centralized storage at a 

single DOE site 

INEEL 38.1 0.00379 9.44 0.0233 

Eastern 

(Barnwell) 

Centralized storage at a 34.6 0.00206 22.1 0.013 

single commercial site 

Western 

(Envirocare) 

38.9 0.00414 36.2 0.00341 

Partially consolidated storage 

at two DOE sites 

INEEL/PORTS 6.28 8.74E-04 6.85 0.0037 

Partially consolidated storage 

at two commercial sites 

Eastern/western 21 0.003 10.1 0.0117 

Partially consolidated By physical form 4.36 7.10E-04 2.15 2.94E-03

By closest site 4.37 7.07E-04 2.15 2.94E-03

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

The average dose to an individual member of the public was calculated by dividing the doses (and 

dose risks) shown in Table B.2 by the populations in a mile-wide band along each route. The results are 

shown in Table B.3. 
01-217(doc)/093002 B-5 

Table B.3. Average individual public dose (mrem) 

Truck only Truck and rail 

Destination Incident-free Accident Incident-free Accident 

SRS 6.51E-03 5.41E-06 4.41E-03 2.30E-05 

Oak Ridge 5.02E-03 3.13E-06 4.12E-03 1.34E-05 

PGDP 4.89E-03 2.51E-06 4.14E-03 2.61E-05 

PORTS 4.16E-03 1.86E-06 4.25E-03 7.95E-06 

INEEL 5.83E-03 5.65E-06 0.00E+00 3.86E-05 

Eastern (Barnwell) 6.58E-03 3.16E-06 4.22E-06 1.99E-05 

Western (Envirocare) 5.93E-03 5.99E-06 5.46E-03 5.56E-05 

INEEL/PORTS 2.03E-03 1.31E-06 2.28E-03 6.14E-06 

Eastern/western 5.87E-02 4.44E-06 2.45E-03 1.60E-05 

By physical form 1.59E-03 1.12E-06 8.04E-04 5.03E-06 

By closest site 1.63E-03 1.12E-06 8.22E-04 5.04E-06 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

The average background radiation dose for a person living in the United States is 360 mrem/year. 

Thus the dose from the proposed shipments of uranium is less than 1/10,000 of the average background 

dose. 

Another comparison that may be made is to calculate possible health effects from these exposures. 

International Commission on Radiological Protection (ICRP) Publication 60 (ICRP 1991) projects 0.0005 

latent cancer fatalities (LCFs) per rem of exposure. The results of applying this factor to the data in Table 

B.2 are shown in Table B.4. 

These projected LCFs are in excess of the potentially fatal cancers projected to occur in 

the populations along the routes. As Table B.4 shows, less than 1/50 LCF is projected for any 

alternative. 

Table B.5 shows the collective occupational (crew) doses for the various alternatives. These 

collective doses appear to be quite large, especially since trucks carry a crew of two people. However, 

truck crew members are considered radiation workers, and both the dose rate and the cumulative dose are 

limited by regulation. One cannot say at this time how many truck crew members would be involved in 

these shipping campaigns. 

Rail crew members on a train that is in transit (in motion) have no exposure because they are too far 

from the radioactive material and too well shielded. The collective doses cited in Table B.5 for the 

truck/rail option include doses to rail classification yard workers. 
01-217(doc)/093002 B-6 

Table B.4. Potential excess latent cancer fatalities (LCFs) 

Potential excess latent cancer fatalities (total) 

Truck only Truck and rail

Interim storage alternative Destination Incident-free Accident Incident-free Accident

SRS 0.0175 1.80E-06 0.0117 6.85E-06 

Oak Ridge 0.0116 9.90E-07 0.0094 3.88E-06 

PGDP 0.0112 8.25E-07 0.0093 7.70E-06 

PORTS 0.0093 6.15E-07 0.0093 2.39E-06 

Centralized storage at a single 

DOE site 

INEEL 0.0191 1.90E-06 0.0047 1.17E-05 

Eastern 

(Barnwell) 

Centralized storage at a single 0.0173 1.03E-06 0.0111 6.50E-06 

commercial site 

Western 

(Envirocare)

0.0195 2.07E-06 0.0181 1.71E-06 

Partially consolidated storage 

at two DOE sites 

INEEL/PORTS 0.0031 4.37E-07 0.0034 1.85E-06 

Partially consolidated storage 

at two commercial sites 

Eastern/western 0.0105 1.50E-06 0.0051 5.85E-06 

Partially consolidated By physical form 0.0022 3.55E-07 0.0011 1.47E-06 

By closest site 0.0022 3.54E-07 0.0011 1.47E-06 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

Table B.5. Collective crew dose 

Collective crew dose 

(person-rem) 

Interim storage alternative Destination Truck only Truck and rail 

SRS 245 11.1 

Oak Ridge 188 9.73 

PGDP 192 8.71 

PORTS 157 9.38 

Centralized storage at a single 

DOE site 

INEEL 342 5.33 

Eastern 

(Barnwell) 

Centralized storage at a single 246 11.1 

commercial site 

Western 

(Envirocare)

346 6.25 

Partially consolidated storage 

at two DOE sites 

INEEL/PORTS 48.8 2.07 

Partially consolidated storage 

at two commercial sites 

Eastern/western 220 3.34 

Partially consolidated By physical form 36.7 1.84 

By closest site 36.7 1.77 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 
01-217(doc)/093002 B-7 

Table B.6 shows projected potential traffic fatalities from truck and rail accidents, which are 

comparable to projected LCFs. The table also includes airborne concentrations of uranium and uranium 

compounds. The toxicity threshold for airborne uranium and uranium compound particles is 2 mg/m3

(Lewis 1993). 

Table B.6. Potential traffic fatalities and airborne uranium concentrations 

Traffic fatalities (total) 

Destination Truck only Truck and rail

Airborne 

concentration of 

uranium (μg/m3

) 

SRS 0.00427 0.0078 0.0771 

Oak Ridge 0.00374 0.00676 0.0714 

PGDP 0.00374 0.0069 0.081 

PORTS 0.00357 0.00635 0.0319 

INEEL 0.00595 0.0106 0.0797 

Eastern (Barnwell) 0.00426 0.0077 0.081 

Western (Envirocare) 0.00591 0.0109 0.081 

INEEL/PORTS 0.00215 0.0037 0.0306 

Eastern/western 0.00256 0.00447 0.081 

By physical form 0.0019 0.00309 0.0172 

By closest site 0.00183 0.00301 0.017 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

Radiological impacts of transoceanic transportation were also calculated. While the freighter 

carrying the uranium is at sea, there is no dose to the public. Projected impacts, based on assumptions in 

Section B.3, would be: 

• the average dose to a crew member would be approximately 1.8 mrem per person per day for each 

shipment of material, and 

• a dock worker loading containers could potentially receive an external dose of 2 mrem. 

The total number of shipments needed could not be estimated because this cargo would probably be 

carried with other cargo, and the amount in each shipment would depend on the rate of arrival at the 

debarcation port. 

B.6 REFERENCES 

Griego, N. R., Smith, J. D., and Neuhauser, K. S. 1996. Investigation of Radtran Stop Model Input 

Parameters for Truck Stops, SAND96-0714C, Sandia National Laboratories, Albuquerque, NM. 

DOE (U.S. Department of Energy). 2002. Final Environmental Impact Statement for a Geologic 

Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca 

Mountain, Nye County, Nevada, DOE/EIS-0250, Volume II, U.S. Department of Energy, Office of 

Civilian Radioactive Waste Management, Washington, D.C. 
01-217(doc)/093002 B-8 

ICRP (International Commission on Radiological Protection). 1991. “1990 Recommendations of the 

International Commission on Radiological Protection,” Vol. 21, No. 1-3 of Annals of the ICRP, 

ICRP Publication 60, Pergamon Press, New York. 

Lewis, R. J., Sr. 1993. Hawley’s Condensed Chemical Dictionary, Van Nostrand, New York. 

Neuhauser, K. S., Kanipe, F. L., and Weiner, R. F. 2000. RADTRAN 5, Technical Manual, SAND2000-

1256, Sandia National Laboratories, Albuquerque, NM. 

Saricks, C. L., and Tompkins, M. M. 1999. State-Level Accident Rates of Surface Freight Transportation: 

A Reexamination, ANL/ESD/TM-150, Argonne National Laboratory, Argonne, IL. 
01-217(doc)/093002 

APPENDIX C 

ANALYSIS OF CHRONIC RISK TO 

HUMANS AND ECOLOGICAL RECEPTORS 

FROM URANIUM DEPOSITED ON SOIL AND SURFACE WATER 

FOR 

URANIUM MANAGEMENT PROGRAMMATIC 

ENVIRONMENTAL ASSESSMENT
01-217(doc)/093002 
01-217(doc)/093002 C-iii

TABLE OF CONTENTS 

LIST OF TABLES................................................................................................................................... C-iv

ACRONYMS............................................................................................................................................ C-v

C.1 INTRODUCTION........................................................................................................................... C-1

C.2 DEVELOPMENT OF SOURCE TERMS FOR CONTAMINATED SOIL, SURFACE 

WATER, AND SEDIMENT........................................................................................................... C-1

C.2.1 Deposition Rates ................................................................................................................ C-1

C.2.1.1 Parameters ........................................................................................................... C-2

C.2.1.2 Deposition model results ..................................................................................... C-2

C.2.2 Media Concentrations.......................................................................................... C-5

C.2.2.1 Soil....................................................................................................................... C-5

C.2.2.2 Surface water....................................................................................................... C-5

C.2.2.3 Sediment.............................................................................................................. C-9

C.3 ASSESSMENT OF CHRONIC HUMAN EXPOSURE TO URANIUM ...................................... C-9

C.3.1 Exposure Point Concentrations........................................................................................ C-10

C.3.2 Exposure Pathways .......................................................................................................... C-19

C.3.3 Toxicity Assessment ........................................................................................................ C-19

C.3.4 Characterization of Consequences ................................................................................... C-19

C.3.4.1 Method............................................................................................................... C-20

C.3.4.2 Results ............................................................................................................... C-20

C.3.5 Overall Risk Evaluation ................................................................................................... C-20

C.4 ALTERNATIVE-SPECIFIC EVALUATION OF IMPACTS TO ECOLOGICAL 

RECEPTORS ................................................................................................................................ C-21

C.4.1 General Approach ............................................................................................................ C-21

C.4.2 Hazard Identification........................................................................................................ C-21

C.4.3 Exposure Assessment....................................................................................................... C-21

C.4.3.1 Terrestrial biota exposed to chemical toxicity of uranium ................................ C-26

C.4.3.2 Terrestrial biota exposed to radiological effects of uranium............................. C-26

C.4.3.3 Aquatic biota exposed to chemical toxicity of uranium .................................... C-30

C.4.3.4 Aquatic biota exposed to radiological effects of uranium................................. C-32

C.4.4 Effects Assessment .......................................................................................................... C-34

C.4.4.1 Chemical effects ................................................................................................ C-34

C.4.4.2 Irradiation .......................................................................................................... C-34

C.4.5 Consequence Evaluation .................................................................................................. C-34

C.4.5.1 Soil..................................................................................................................... C-34

C.4.5.2 Surface water and sediment............................................................................... C-44

C.4.6 Overall Risk Evaluation ................................................................................................... C-44

C.5 SUMMARY .................................................................................................................................. C-44

C.6 REFERENCES.............................................................................................................................. C-51
01-217(doc)/093002 C-iv

LIST OF TABLES 

C.1 Rates and amounts of deposition of uranium resulting from bounding accident scenariosa........... C-3

C.2 Concentrations of uranium in soil, surface water, and sediment resulting from deposition of 

uranium after accidentsa

.................................................................................................................. C-6

C.3 Human health exposure parameters for the uranium accident and hazard analysis ...................... C-11

C.4 Summary of cancer risks............................................................................................................... C-12

C.5 Summary of radiological dose....................................................................................................... C-13

C.6 Summary of non-carcinogenic hazard........................................................................................... C-14

C.7 Toxicity values for human health risk and dose calculations........................................................ C-15

C.8 Uranium source term..................................................................................................................... C-16

C.9 Summary of chronic radiation risks to human receptors due to deposition of uranium on 

soil under bounding accident scenarios.........................................................................................C-22

C.10 Summary of chronic chemical risks to human receptors due to deposition of uranium on 

soil under bounding accident scenarios.........................................................................................C-25

C.11 Chemical toxicity rates to ecological receptors from uranium in soila ......................................... C-27

C.12 Radiation dose rates to ecological receptors from uranium in soila .............................................. C-29

C.13 Chemical toxicity rates to ecological receptors from uranium in surface water and 

sedimenta

....................................................................................................................................... C-31

C.14 Radiation dose rates to ecological receptors from uranium in surface water and sedimenta ........ C-33

C.15 Uranium toxicity benchmarks for ecological receptors ................................................................ C-35

C.16 Chemical toxicity consequences to ecological receptors due to deposition of uranium on 

soil under bounding accident scenarios.........................................................................................C-36

C.17 Radiological consequences to ecological receptors due to deposition of uranium on soil 

under bounding accident scenarios ............................................................................................... C-38

C.18 Chemical toxicity consequences to ecological receptors due to deposition of uranium on 

surface water under bounding accident scenarios......................................................................... C-40

C.19 Radiological consequences to ecological receptors due to deposition of uranium on surface 

water under bounding accident scenarios ..................................................................................... C-42

C.20 Summary of chronic risks to ecological receptors due to deposition of uranium on soil 

under bounding accident scenarios ............................................................................................... C-45

C.21 Summary of chronic risks to ecological receptors due to deposition of uranium on surface 

water under bounding accident scenarios ..................................................................................... C-48
01-217(doc)/093002 C-v

ACRONYMS 

AF adherence factor 

AT averaging time 

BW body weight 

CASRN Chemical Abstract Services Registry Number 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 

CF conversion factor 

Ci/g curies per gram 

CSFx cancer slope factor (pathway x) 

DCFx dose conversion factor (pathway x) 

DNA deoxyribonucleic acid 

DOE U.S. Department of Energy 

ED exposure duration 

EF exposure frequency 

EFetx exposure frequency (gamma) 

EM emergency management 

EPA U.S. Environmental Protection Agency 

EPC exposure point concentration 

ET exposure time 

GI gastrointestinal 

HQ hazard quotient 

ICRP International Commission on Radiological Protection 

INEEL Idaho National Engineering and Environmental Laboratory 

IRair inhalation rate (dust) 

IRsoil ingestion rate (soil) 

NOAEL No observed adverse effect level 

PEA programmatic environmental assessment 

PEF particulate emission factors 

PGDP Paducah Gaseous Diffusion Plant 

PORTS Portsmouth Gaseous Diffusion Plant 

RAGS Risk Assessment Guidance 

RfD reference dose 

SA surface area 

Se gamma shielding factor 

SRS Savannah River Site 

Te gamma exposure time 

TRV toxicity reference value 

UT total uranium 
01-217(doc)/093002 C-vi
01-217(doc)/093002 C-1

C.1 INTRODUCTION 

 This appendix presents an assessment of chronic risks to humans and ecological receptors of airborne 

uranium deposited on soil and surface water and from water to sediment. It does the following: 

• describes methods to calculate deposition rates of particulate and particulate-bound airborne uranium 

under conditions described in Appendix A; 

• presents methods to determine the concentrations of uranium in surface soil, surface water, and sediment 

and the calculated concentrations after releases resulting from accidents described in Appendix A; 

• assesses exposure of nearby human receptors to the chronic chemical, radiological, and carcinogenic 

effects of uranium in soil; and 

• assesses exposure of terrestrial and aquatic ecological receptors and consumers of aquatic and benthic 

(sediment-dwelling) biota to the chemical and radiological effects of uranium in soil, surface water, and 

sediment. 

 The resulting hazards and risks are organized into categories according to the severity of the 

consequences (negligible, low, moderate, and high). These consequence categories are combined with the 

expected frequencies of the associated accidents to predict the overall risk from each proposed alternative at 

each location. 

C.2 DEVELOPMENT OF SOURCE TERMS FOR CONTAMINATED SOIL, 

SURFACE WATER, AND SEDIMENT 

 An accident that releases airborne uranium will result in deposition of uranium on soil and water and 

from water to sediment in a downwind direction from the release. Humans and ecological receptors located in 

the area of deposition will be chronically exposed to the contaminated soil, surface water, and sediment. This 

section describes the calculation of concentrations in those media as a result of deposition. 

C.2.1 DEPOSITION RATES 

 Deposition rates in the downwind direction were modeled for dry air. It was assumed that all of the 

airborne uranium is particulate or becomes associated with particles and is deposited as the particles settle. 

Deposition of particles was modeled with a simple Gaussian plume model in which the horizontal axis of the 

plume descends with distance from the source as particles settle out (Pasquill 1974). The accident scenarios 

result in release to the atmosphere of uranium in amounts that vary with the scenario and the location. In all 

cases, it was assumed that all of the uranium that is released is released in 1 hour (Appendix A, Sect. A.3.4.1). 

Although that is not likely to be true in any given case, the entire released source term is accounted for, so the 

assumption is acceptable. 

 The equation for deposition rate was adapted from Pasquill (1974) by omitting the term Q for release 

rate, which is different for different scenarios. The result of the equation is equivalent to the rate of deposition 

when the release rate is 1 g/s. The equation is as follows: 
01-217(doc)/093002 C-2





























σ















 −−−

















σ

−

σσπ = 2

2

2

2

2 2 2 )(

U

xv

)zh(

exp

)(

y exp U

v

Ds

z

s

zy y

s

where 

Ds = relative deposition rate per unit area (m-2), 

vs = deposition velocity (m/s), 

U = average wind velocity (m/s), 

σy = crosswind dispersion coefficient (m), 

σz = vertical dispersion coefficient (m), 

y = lateral distance of the deposition point from the plume centerline at the downwind location (m), 

h = elevation of the initial centerline of the plume above the release point (m) , 

z = elevation of the deposition point above the release point (m), 

x = distance downwind from the release point (m). 

C.2.1.1 Parameters 

 The deposition velocity was assumed to be 2 cm/s (2 × 10-2 m/s), a typical velocity for particles of 

approximately 10 μm in diameter (Hanna, Briggs, and Hosker 1982). The average wind velocity (1.5 m/s) and 

crosswind dispersion coefficient (calculated for atmospheric stability class F, which is the most stable, thus 

providing the least mixing and, as a result, the most conservative class) were discussed in Appendix A, 

Sect. A.3.4.2. Releases to the environment from a fire were assumed to occur at a height of 15 m, and releases 

from a seismic event were assumed to begin at a height of 5 m. 

C.2.1.2 Deposition model results 

 The deposition model predicts that the concentrations are highest along the centerline of the plume 

(directly downwind from the release), decreasing with lateral distance from the centerline. The maximum 

deposition rates occurred about 550 m from the release point in the case of fires and at 175 m in the case of 

seismic events. 

 As a conservative estimate of exposure, the habitats in which biota are exposed were assumed to be 

located directly downwind of the release point. The deposition rate was the maximum deposition rate for the 

condition (fire or seismic event), regardless of the size of the habitat. Deposition rates and total uranium 

deposited per unit area are shown in Table C.1. Concentrations of uranium in soil, surface water, and 

sediment were calculated from the amount of uranium deposited per unit area. 
01-217(doc)/093002 C-3

Table C.1. Rates and amounts of deposition of uranium resulting from bounding accident scenariosa

Alternative Accident scenario Site 

Airborne 

release rate

(mg/s) 

Maximum 

deposition rateb

(mg/m2

/s) 

Total 

depositionc

(mg/m2) 

All 

General container 

handling All 1.84E+00 1.28E-04 4.61E-01 

No Action Storage area fire INEEL 4.28E+01 3.35E-04 1.21E+00 

 PGDP 1.74E-01 1.36E-06 4.91E-03 

 PORTS 4.94E+02 3.87E-03 1.39E+01 

 SRS 9.78E+01 7.66E-04 2.76E+00 

 Oak Ridge 4.69E+01 3.68E-04 1.32E+00 

 Max other 5.79E+01 4.54E-04 1.63E+00 

Seismic (direct release) INEEL 2.90E+00 2.02E-04 7.26E-01 

 PGDP 7.25E-02 5.04E-06 1.82E-02 

 PORTS 1.89E+02 1.31E-02 4.73E+01 

 SRS 1.23E+01 8.55E-04 3.08E+00 

 Oak Ridge 5.80E+00 4.03E-04 1.45E+00 

 Max other 2.41E+01 1.68E-03 6.03E+00 

 Seismic (fire) INEEL 2.80E+00 2.19E-05 7.90E-02 

 PGDP 4.35E-02 3.41E-07 1.23E-03 

 PORTS 1.15E+02 9.01E-04 3.24E+00 

 SRS 9.40E+00 7.37E-05 2.65E-01 

 Oak Ridge 4.45E+00 3.49E-05 1.26E-01 

 Max other 1.45E+01 1.14E-04 4.09E-01 

Centralized storage at Storage area fire All 1.01E+03 7.91E-03 2.85E+01 

a single site Seismic (direct release) All 3.27E+02 2.27E-02 8.19E+01 

 Seismic (fire) All 2.03E+02 1.59E-03 5.73E+00 

Partially consolidated Storage area fire INEEL 9.89E+01 7.75E-04 2.79E+00 

storage at several PGDP 1.48E+01 1.16E-04 4.18E-01 

DOE sites PORTS 6.80E+02 5.33E-03 1.92E+01 

 SRS 1.00E+02 7.84E-04 2.82E+00 

 Oak Ridge 1.21E+02 9.48E-04 3.41E+00 

Seismic (direct release) INEEL 1.06E+01 7.37E-04 2.65E+00 

 PGDP 2.98E+00 2.07E-04 7.46E-01 

 PORTS 2.63E+02 1.83E-02 6.59E+01 

 SRS 1.33E+01 9.25E-04 3.33E+00 

 Oak Ridge 3.66E+01 2.55E-03 9.16E+00 

 Seismic (fire) INEEL 8.52E+00 6.68E-05 2.40E-01 

 PGDP 2.01E+00 1.58E-05 5.67E-02 

 PORTS 1.59E+02 1.25E-03 4.49E+00 

 SRS 9.97E+00 7.81E-05 2.81E-01 

 Oak Ridge 2.29E+01 1.79E-04 6.46E-01 

Partially consolidated Storage area fire East 9.13E+02 7.15E-03 2.58E+01 

storage at two sites West 1.02E+02 7.99E-04 2.88E+00 

Seismic (direct release) East 3.15E+02 2.19E-02 7.89E+01 

 West 1.19E+01 8.28E-04 2.98E+00 

 Seismic (fire) East 1.94E+02 1.52E-03 5.47E+00 

 West 9.29E+00 7.28E-05 2.62E-01 
01-217(doc)/093002 C-4

Table C.1. Rates and amounts of deposition of uranium resulting from bounding accident scenariosa

(continued) 

Alternative Accident scenario Site 

Airborne 

release rate

(mg/s) 

Maximum 

deposition rateb

(mg/m2

/s) 

Total 

depositionc

(mg/m2) 

Partially consolidated Storage area fire PORTS 4.38E+02 3.43E-03 1.24E+01 

storage based on SRS 2.47E+02 1.94E-03 6.97E+00 

physical form INEEL 3.01E+01 2.36E-04 8.49E-01 

Seismic (direct release) PORTS 3.07E+02 2.14E-02 7.69E+01 

 SRS 1.54E+01 1.07E-03 3.86E+00 

 INEEL 4.01E+00 2.79E-04 1.00E+00 

 Seismic (fire) PORTS 1.84E+02 1.44E-03 5.19E+00 

 SRS 1.54E+01 1.21E-04 4.34E-01 

 INEEL 3.01E+00 2.36E-05 8.49E-02 

Transfer to research Facility fire Generic 3.56E+00 2.79E-05 1.00E-01 

facility Seismic (direct release) Generic 1.15E+00 9.01E-06 3.24E-02 

 Seismic (fire) Generic 7.13E-01 5.59E-06 2.01E-02 

Transfer to other Facility fire Generic 1.78E+02 1.39E-03 5.02E+00 

government agencies Seismic (direct release) Generic 5.74E+01 4.50E-04 1.62E+00 

 Seismic (fire) Generic 3.56E+01 2.79E-04 1.00E+00 

Foreign sales Facility fire Generic 3.52E+02 2.76E-03 9.93E+00 

Seismic (direct release) Generic 1.24E+02 9.72E-04 3.50E+00 

 Seismic (fire) Generic 7.60E+01 5.96E-04 2.14E+00 

a

Airborne release rates from Appendix A, Table A-7. 

b

Q (mg/s) × max unit deposition (m-2). c

Max rate × 3600 sec. 

DOE = U.S. Department of Energy. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 
01-217(doc)/093002 C-5

C.2.2 Media Concentrations 

 Concentrations of uranium in soil, surface water, and sediment as a consequence of accidental releases 

were calculated as described below. 

C.2.2.1 Soil 

 Uranium concentrations in the upper 5 cm (2 in.) of dry soil were calculated using a U.S. Environmental 

Protection Agency (EPA) model (EPA 1999). The calculation was done with the following equation: 

Cs = Q × Ds × t × 1000 / (0.05 × 1600) , 

where 

Cs = concentration in the soil (mg/kg), 

Q = release rate (g/s) [Appendix A, Table A-7], 

Ds = relative deposition rate per unit area (m-2), 

t = duration of release (s), 

1000 = conversion factor (mg/g), 

0.05 = volume conversion factor (m-3 per m-2), 

1600 = density of soil (kg/m3

). 

 To illustrate the distribution of uranium concentrations in soil downwind from a release, a fractional 

release rate was calculated, with Q equal to 1 g/s. As previously described, the release was assumed to occur 

over a period of 1 hour and to include the entire airborne source term in that time period. The resulting soil 

concentrations per unit area (mg/kg) in soil are shown in Table C.2. 

C.2.2.2 Surface water 

 Uranium was assumed to be deposited in a pond with an average depth of 2 m. Concentrations of 

uranium in the surface water were assumed to be determined by the ratios of dissolved-to-sediment-bound 

uranium as well as the deposition rate. The fraction of uranium in the water column (Fw) was calculated by 

using an equation presented by EPA (Eq. B-2-10, EPA 1999): 

Fwc = [(1 + Kdsw × TSS × 10-6) × dwc/dz] / [(1 + Kdsw × TSS × 10-6) × dwc/dz) + (qbs + Kdbs × BS) × dbs/dz] , 

where 

Fwc = fraction of deposited uranium concentration in the water column, 

Kdsw = suspended sediment/water partitioning coefficient (450 L/kg), 

TSS = total suspended solids (assumed to be 10 mg/L), 

10-6 = conversion factor (kg/mg), 

dwc = depth of the water column (assumed to be 2 m), 

dbs = depth of the upper sediment layer [0.03 m, default value (EPA 1999)], 

dz = combined depth of water column and sediment layer (2.03 m), 

Kdbs = bed sediment/water partitioning coefficient (450 L/kg), 

qbs = bed sediment porosity (0.6 L water/L sediment, EPA default [EPA 1999]), 

BS = benthic solids concentration (1 kg/L). 

 Using these parameters, the value of Fwc was calculated as 0.13. 
01-217(doc)/093002 C-6 Table C.2. Concentrations of uranium in soil, surface water, and sediment resulting from deposition of uranium aft

Untilled soil (5-cm depth) Tilled soil Surface water (2-m depth) 

Alternative Accident scenario Site Concen- trationb (mg/kg) Activityc (pCi/g) Concen- tratione (mg/kg) Activityd (pCi/g) Concen- trationd (mg/L) Activity

(pCi/L

All General container handling All 5.76E-03 4.03E-03 1.44E-03 1.01E-03 2.94E-05 2.06E-0No Action Storage area fire INEEL 1.51E-02 1.06E-02 3.77E-03 2.64E-03 7.81E-05 5.47E-0

PGDP 6.14E-05 4.30E-05 1.53E-05 1.07E-05 3.18E-07 2.22E-0

PORTS 1.74E-01 1.22E-01 4.36E-02 3.05E-02 9.02E-04 6.31E-0

SRS 3.45E-02 2.41E-02 8.62E-03 6.04E-03 1.78E-04 1.25E-0

Oak Ridge 1.65E-02 1.16E-02 4.13E-03 2.89E-03 8.56E-05 5.99E-0

Max other 2.04E-02 1.43E-02 5.10E-03 3.57E-03 1.06E-04 7.40E-0

Seismic (direct release) INEEL 9.08E-03 6.35E-03 2.27E-03 1.59E-03 4.70E-05 3.29E-0

PGDP 2.27E-04 1.59E-04 5.67E-05 3.97E-05 1.17E-06 8.22E-0

PORTS 5.92E-01 4.14E-01 1.48E-01 1.04E-01 3.06E-03 2.14E+0

SRS 3.85E-02 2.69E-02 9.62E-03 6.74E-03 1.99E-04 1.39E-0

Oak Ridge 1.82E-02 1.27E-02 4.54E-03 3.18E-03 9.40E-05 6.58E-0

Max other 7.54E-02 5.28E-02 1.89E-02 1.32E-02 3.90E-04 2.73E-0

 Seismic (fire) INEEL 9.87E-04 6.91E-04 2.47E-04 1.73E-04 5.11E-06 3.58E-0

 PGDP 1.53E-05 1.07E-05 3.83E-06 2.68E-06 7.94E-08 5.56E-0

 PORTS 4.06E-02 2.84E-02 1.01E-02 7.10E-03 2.10E-04 1.47E-0

 SRS 3.31E-03 2.32E-03 8.29E-04 5.80E-04 1.72E-05 1.20E-0

 Oak Ridge 1.57E-03 1.10E-03 3.92E-04 2.75E-04 8.12E-06 5.69E-0

Max other 5.11E-03 3.58E-03 1.28E-03 8.95E-04 2.65E-05 1.85E-0

Centralized storage Storage area fire All 3.56E-01 2.49E-01 8.90E-02 6.23E-02 1.84E-03 1.29E+0

at a single site Seismic (direct release) All 1.02E+00 7.16E-01 2.56E-01 1.79E-01 5.30E-03 3.71E+0

Seismic (fire) All 7.16E-02 5.01E-02 1.79E-02 1.25E-02 3.70E-04 2.59E-0

Partially consolidated Storage area fire INEEL 3.49E-02 2.44E-02 8.72E-03 6.10E-03 1.80E-04 1.26E-0storage at several PGDP 5.22E-03 3.65E-03 1.30E-03 9.13E-04 2.70E-05 1.89E-0DOE sites PORTS 2.40E-01 1.68E-01 5.99E-02 4.20E-02 1.24E-03 8.69E-0

 SRS 3.53E-02 2.47E-02 8.82E-03 6.17E-03 1.83E-04 1.28E-0

Oak Ridge 4.27E-02 2.99E-02 1.07E-02 7.47E-03 2.21E-04 1.55E-0
01-217(doc)/093002 C-7 Table C.2. Concentrations of uranium in soil, surface water, and sediment resulting from deposition of uranium after acc

Untilled soil (5-cm depth) Tilled soil Surface water (2-m depth) 

Alternative Accident scenario Site Concen- trationb (mg/kg) Activityc (pCi/g) Concen- tratione (mg/kg) Activityd (pCi/g) Concen- trationd (mg/L) Activity

(pCi/L

Seismic (direct release) INEEL 3.32E-02 2.32E-02 8.29E-03 5.81E-03 1.72E-04 1.20E-0

PGDP 9.33E-03 6.53E-03 2.33E-03 1.63E-03 4.83E-05 3.38E-0

PORTS 8.23E-01 5.76E-01 2.06E-01 1.44E-01 4.26E-03 2.98E+0

SRS 4.16E-02 2.91E-02 1.04E-02 7.28E-03 2.15E-04 1.51E-0

Oak Ridge 1.15E-01 8.02E-02 2.86E-02 2.00E-02 5.93E-04 4.15E-0

Seismic (fire) INEEL 3.00E-03 2.10E-03 7.51E-04 5.26E-04 1.55E-05 1.09E-0

PGDP 7.09E-04 4.96E-04 1.77E-04 1.24E-04 3.67E-06 2.57E-0

PORTS 5.61E-02 3.92E-02 1.40E-02 9.81E-03 2.90E-04 2.03E-0

SRS 3.52E-03 2.46E-03 8.79E-04 6.15E-04 1.82E-05 1.27E-0

Oak Ridge 8.08E-03 5.65E-03 2.02E-03 1.41E-03 4.18E-05 2.93E-0

Partially consolidated Storage area fire East 3.22E-01 2.25E-01 8.05E-02 5.63E-02 1.67E-03 1.17E+0

storage at two sites West 3.60E-02 2.52E-02 8.99E-03 6.29E-03 1.86E-04 1.30E-0

Seismic (direct release) East 9.86E-01 6.90E-01 2.46E-01 1.73E-01 5.10E-03 3.57E+0

 West 3.72E-02 2.61E-02 9.31E-03 6.52E-03 1.93E-04 1.35E-0

 Seismic (fire) East 6.84E-02 4.79E-02 1.71E-02 1.20E-02 3.54E-04 2.48E-0

West 3.28E-03 2.29E-03 8.19E-04 5.73E-04 1.70E-05 1.19E-0

Partially consolidated Storage area fire PORTS 1.54E-01 1.08E-01 3.86E-02 2.70E-02 7.99E-04 5.60E-0storage based on SRS 8.71E-02 6.10E-02 2.18E-02 1.52E-02 4.51E-04 3.16E-0physical form INEEL 1.06E-02 7.43E-03 2.65E-03 1.86E-03 5.49E-05 3.85E-0

Seismic (direct release) PORTS 9.61E-01 6.73E-01 2.40E-01 1.68E-01 4.97E-03 3.48E+0

 SRS 4.82E-02 3.37E-02 1.20E-02 8.43E-03 2.49E-04 1.75E-0

 INEEL 1.26E-02 8.79E-03 3.14E-03 2.20E-03 6.50E-05 4.55E-0

 Seismic (fire) PORTS 6.49E-02 4.54E-02 1.62E-02 1.14E-02 3.36E-04 2.35E-0

 SRS 5.43E-03 3.80E-03 1.36E-03 9.50E-04 2.81E-05 1.97E-0

INEEL 1.06E-03 7.43E-04 2.65E-04 1.86E-04 5.49E-06 3.85E-0

Transfer to research Facility fire Generic 1.26E-03 8.79E-04 3.14E-04 2.20E-04 6.50E-06 4.55E-0

facility Seismic (direct release) Generic 4.06E-04 2.84E-04 1.01E-04 7.10E-05 2.10E-06 1.47E-0

Seismic (fire) Generic 2.51E-04 1.76E-04 6.29E-05 4.40E-05 1.30E-06 9.11E-0
01-217(doc)/093002 C-8 Table C.2. Concentrations of uranium in soil, surface water, and sediment resulting from deposition of uranium after acc

Transfer to other Facility fire Generic 6.28E-02 4.39E-02 1.57E-02 1.10E-02 3.25E-04 2.27E-0

government agencies Seismic (direct release) Generic 2.02E-02 1.42E-02 5.06E-03 3.54E-03 1.05E-04 7.33E-0

Seismic (fire) Generic 1.26E-02 8.79E-03 3.14E-03 2.20E-03 6.50E-05 4.55E-0

Foreign sales Facility fire Generic 1.24E-01 8.69E-02 3.10E-02 2.17E-02 6.42E-04 4.50E-0

Seismic (direct release) Generic 4.37E-02 3.06E-02 1.09E-02 7.65E-03 2.26E-04 1.58E-0

Seismic (fire) Generic 2.68E-02 1.88E-02 6.70E-03 4.69E-03 1.39E-04 9.71E-0

aCalculated from data in Table C.1 using methods discussed in Sect. 5. bDeposition (mg/m2) / (0.05 m3/m2 at 5 cm depth * 1600 kg/m3 density of soil). cConcentration (mg U/kg soil) * 1E-3 kg soil/g soil * 1E-3 g U/mg U * 7E-7 Ci/g U * 1E12 pCi/Ci = 7E-1 pCi/g per mg/kg. dCalculated as described in Sect. 2.2.2. eC mg U/L * 1E-3 g U/mg U * 7E-7 Ci/g U * 1E12 pCi/Ci = 7E2 pCi/L per mg/L. fCalculated as described in Sect. 2.2.3. 

DOE = U.S. Department of Energy. INEEL = Idaho National Engineering and Environmental Laboratory. PGDP = Paducah Gaseous Diffusion Plant. PORTS = Portsmouth Gaseous Diffusion Plant. SRS = Savannah River Site.
01-217(doc)/093002 C-9

 The concentration of uranium in the surface water is given (Eq. B-2-17, EPA 1999) by: 

Cwctot = Fwc × Cwtot × dz/dwc , 

where 

Cwctot = total uranium concentration in the water column (mg/L), 

Fwc = fraction of uranium in the water column (0.13 from equation above), 

Cwtot = total uranium concentration including water and bed sediment (total deposited per m2

/2.03 m), 

dz = combined depth of water column and sediment layer (2.03 m), 

dwc = depth of water column (2 m). 

 Cwctot was calculated to be 6.37 × 10-5 mg/L per mg/m2

 deposited. The resulting concentrations in surface 

water are shown in Table C.2. 

C.2.2.3 Sediment 

 Concentrations in pond sediment were estimated by assuming that the uranium is deposited on a pond. It 

was assumed that in the long-term, the total mass of uranium comes to equilibrium between sediment and 

surface water. The uranium was assumed to become adsorbed to sediment particles in the upper 2 cm of 

bottom sediment. 

 The fraction of uranium in bed sediment (Fbs) is 1-Fwc = 0.87, and the concentration of uranium in the 

sediment is given (Eq. B-2-19, EPA 1999) by: 

Csed = Fbs × Cwtot × [Kdbs/(qbs + Kdbs × BS)] × [(dwc + dbs)/dbs] , 

where 

Csed = concentration in bed sediment (mg/kg), 

Fbs = fraction of uranium in bed sediment (0.87), 

Cwtot = total uranium concentration including water and bed sediment (total deposited per m2

/2.03 m), 

Kdbs = bed sediment/water partitioning coefficient (450 L/kg), 

qbs = bed sediment porosity [0.6 L water/L sediment, EPA default (EPA 1999)], 

BS = benthic solids concentration (1 kg/L), 

dwc = depth of water column (2 m), 

dbs = depth of bed sediment (0.03 m). 

 Csed was calculated to be 1.81 × 10-2 mg/kg per mg/m2

 deposited on the water surface. The resulting 

concentrations in sediment are shown in Table C.2. 

C.3 ASSESSMENT OF CHRONIC HUMAN EXPOSURE TO URANIUM

 The purpose of this assessment is to evaluate chronic exposure to uranium potentially released from the 

U.S. Department of Energy’s uranium management activities. This assessment considered three exposure 

scenarios, including an emergency management (EM) cleanup worker, a standard industrial worker, and a 

standard resident. The standard resident was presented as a worst-case scenario for comparison, although 

residential exposure is considered implausible under current site conditions. All receptors were assumed to be 

exposed to uranium deposited over surface soils. Exposure pathways include soil ingestion, dust inhalation, 
01-217(doc)/093002 C-10

dermal contact, and external gamma exposure. Carcinogenic risks, non-carcinogenic hazards, and radiological 

doses were estimated for these pathway and receptor combinations. 

 This assessment was performed with the initial assumption that all chronic exposures would be within or 

below tolerable limits where tolerable limits are defined as follows: 

1. radiological dose less than 1 mrem/year was considered de minimus; 

2. noncarcinogenic risk (hazard) less than 0.1 was considered de minimus; 

3. carcinogenic risk less than 10-6 was considered de minimus; and 

4. carcinogenic risk within the Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980 (CERCLA) target risk range of 10-4 to 10-6 was considered tolerable. 

 Using this approach, dose and risk calculations were performed using the highest modeled soil 

concentrations. If risk or dose estimates were above tolerable limits, additional calculations were performed to 

identify those areas that pose the highest dose and risk under chronic exposure conditions. If risk and dose 

estimates using the highest modeled soil concentrations were below tolerable limits, no additional evaluation 

was performed. 

 The following sections provide a more detailed description of methods used to estimate receptor risk and 

dose estimates. This description is supplemented by the information tabulated in Tables C.3 through C.8. In 

general, the methods follow those described in Risk Assessment Guidance (RAGS) Part A (EPA 1989). 

C.3.1 EXPOSURE POINT CONCENTRATIONS

 Based on the data presented in the programmatic environmental assessment (PEA), the maximum 

uranium concentration is 1.02 mg/kg, which is associated with a direct release during a seismic incident at a 

central storage facility at a single site (Table C.2). While concentrations in mg/kg are sufficient for 

noncarcinogenic risk estimates, concentrations must be expressed per radioisotope in pCi/g units in order to 

complete carcinogenic risk and radiological dose estimates. This conversion was completed in two steps 

beginning with the conversion from mg/kg uranium to total uranium (UT) activity: 

UT (pCi/g) = UT (mg/kg) * 1 ́10-6 kg soil/mg soil * 7 ́10-7 Ci/g U * 1 ́1012 pCi/Ci 

UT = 3.55 pCi/g 

 The value 7 × 10-7 curies per gram of uranium (Ci/g) represents the specific activity of normal uranium. 

Normal uranium was assumed, although the PEA indicates that the uranium distribution would be 

85% depleted, with a specific activity of ~3.5E-7 Ci/g. The more conservative conversion factor is used to 

provide an upper-bound estimate of carcinogenic risk and radiological dose (there is no impact to 

noncarcinogenic risk). 
01-217(doc)/093002 C-11 Table C.3. Human health exposure parameters for the uranium accident and hazard analysis EF ED BW AT CFa IRsoil ET IRair SA AF Se Te 

Receptor (d/y) (y) (kg) (d) (g/kg) (kg/d) (hr/hr) (m3/d) (m2/d) (mg/cm2) (unitless) (hr/hr) 

EM workerb 5 1 70 365 1000 5.E-05 1.0 20 0.53 1.0 0.2 0.333 

Industrialc 250 25 70 9125 1000 5.E-05 1.0 20 0.53 1.0 0.2 0.333 

Residentd 350 30 70 10950 1000 1E-04 1.0 20 0.53 1.0 0.2 1.0 

aFor dermal: 0.01 = CFd = (kg-cm2)/(mg-m2). 

Also w/ dermal: 0.01 = ABS = absorption fraction.  1.0 = FI = fraction ingested.  AT for dermal pathway only.  SA for average surface area for head, hands, forearm, and lower legs for an adult. Variable Description

 AF for soil. 

bEM (emergency management) worker assumed to be present for cleanup activities only–40-h total. cAssumed to be standard default industrial worker–8 h/day for 250 days/year. dAssumed to be standard adult resident–24 h/day for 350 days/year. 

Radiological risk equations

Ingestion risk = EPC * IRsoil * EF * ED * CF * CSFing Inhalation risk = EPC *IRair * (1/PEF) * ET * EF * ED * CF * CSFinh External exposure risk = EPC * (1-Se) * Te * EFext * ED * CSFext Non-carcinogenic risk equations

Dermal hazard = EPC * CFd * AF * ABS * SA * ED * EF * (1/RfD) / (AT * BW) Oral hazard = EPC * FI * IRsoil * ED * EF * (1/RfD) / (AT * BW) Radiological dose equations

Ingestion dose = EPC * IRsoil * EF * CF * DCFing Inhalation dose = EPC *IRair * (1/PEF) * ET * EF * CF * DCFinh External dose = EPC * (1-Se) * Te * EFext * DCFext 

AF adherence factAT averaging time BW body weight CF conversion facCSFx cancer slope faDCFx dose conversioED exposure duratEF exposure frequEFetx exposure frequEPC exposure point ET exposure time IRair inhalation rate IRsoil ingestion rate (PEF particulate emiRfD reference dose SA surface area Se gamma shieldiTe gamma exposu
01-217(doc)/093002 C-12

Table C.4. Summary of cancer risks 

 EPCa

 Cancer intakes (pCi)b Cancer risks 

Analyte (pCi/g) Ingestion Inhalation External Ingestion Inhalation Externalc Total 

Short-term Emergency Worker 

Uranium-234 3.50E-01 8.8E-02 6.5E-06 1.3E-03 1.4E-11 7.4E-14 3.2E-13 1.4E-11

Uranium-235+D 1.61E-02 4.0E-03 3.0E-07 5.9E-05 6.6E-13 3.0E-15 3.2E-11 3.3E-11

Uranium-238+D 3.50E-01 8.8E-02 6.5E-06 1.3E-03 1.8E-11 6.1E-14 1.5E-10 1.6E-10

 

Pathway total 3.3E-11 1.4E-13 1.8E-10 2.1E-10

Standard Industrial Worker 

Uranium-234 3.50E-01 1.1E+02 8.1E-03 1.6E+00 1.7E-08 9.3E-11 4.0E-10 1.8E-08

Uranium-235+D 1.61E-02 5.0E+00 3.7E-04 7.4E-02 8.2E-10 3.8E-12 4.0E-08 4.1E-08

Uranium-238+D 3.50E-01 1.1E+02 8.1E-03 1.6E+00 2.3E-08 7.6E-11 1.8E-07 2.1E-07

 

Pathway total 4.1E-08 1.7E-10 2.2E-07 2.6E-07

Standard Adult Resident 

Uranium-234 3.50E-01 3.7E+02 1.4E-02 8.1E+00 5.8E-08 1.6E-10 2.0E-09 6.0E-08

Uranium-235+D 1.61E-02 1.7E+01 6.3E-04 3.7E-01 2.8E-09 6.4E-12 2.0E-07 2.0E-07

Uranium-238+D 3.50E-01 3.7E+02 1.4E-02 8.1E+00 7.7E-08 1.3E-10 9.2E-07 1.0E-06

 

Pathway total 1.4E-07 2.9E-10 1.1E-06 1.3E-06

a

EPC = Exposure point concentration; maximum values used to provide conservative exposure estimate. b

Or pCi*yr/g for external gamma. 

c

Using slope factors for infinite depth. 
01-217(doc)/093002 C-13

Table C.5. Summary of radiological dose 

 EPCa

 Intakes (pCi/yr)b Dose (mrem/yr) 

Analyte (pCi/g) Ingestion Inhalation External Ingestion Inhalation Externalc Total 

Short-term Emergency Worker 

Uranium-234 3.50E-01 8.8E-02 6.5E-06 1.3E-03 2.5E-05 5.1E-08 5.1E-07 2.5E-05

Uranium-235+D 1.61E-02 4.0E-03 3.0E-07 5.9E-05 1.1E-06 2.2E-09 4.5E-05 4.6E-05

Uranium-238+D 3.50E-01 8.8E-02 6.5E-06 1.3E-03 2.4E-05 4.6E-08 1.6E-04 1.9E-04

 

Pathway total 4.9E-05 1.0E-07 2.1E-04 2.6E-04

Standard Industrial Worker 

Uranium-234 3.50E-01 4.4E+00 3.3E-04 6.4E-02 1.2E-03 2.6E-06 2.6E-05 1.3E-03

Uranium-235+D 1.61E-02 2.0E-01 1.5E-05 2.9E-03 5.4E-05 1.1E-07 2.2E-03 2.3E-03

Uranium-238+D 3.50E-01 4.4E+00 3.3E-04 6.4E-02 1.2E-03 2.3E-06 8.2E-03 9.4E-03

 

Pathway total 2.5E-03 5.0E-06 1.1E-02 1.3E-02

Standard Adult Resident 

Uranium-234 3.50E-01 1.2E+01 4.6E-04 2.7E-01 3.5E-03 3.6E-06 1.1E-04 3.6E-03

Uranium-235+D 1.61E-02 5.6E-01 2.1E-05 1.2E-02 1.5E-04 1.5E-07 9.4E-03 9.5E-03

Uranium-238+D 3.50E-01 1.2E+01 4.6E-04 2.7E-01 3.3E-03 3.2E-06 3.5E-02 3.8E-02

 

Pathway total 6.9E-03 7.0E-06 4.4E-02 5.1E-02

a

EPC = Exposure point concentration; maximum values used to provide conservative exposure estimate. b

Or pCi*yr/g for external gamma. 

c

Using slope factors for infinite depth. 
01-217(doc)/093002 C-14

Table C.6. Summary of non-carcinogenic hazard 

 EPCa

 Intakes (mg/kg-day) Hazard 

Analyte (mg/kg) Ingestion Dermal Ingestion Dermal Total 

Short-term Emergency Worker 

Uranium 1.02E+00 1.0E-08 1.1E-08 6.0E-12 5.4E-12 1.1E-11 

 

Pathway total 6.0E-12 5.4E-12 1.1E-11 

Standard Industrial Worker 

Uranium 1.02E+00 5.0E-07 5.3E-07 3.0E-10 2.7E-10 5.7E-10 

 

Pathway total 3.0E-10 2.7E-10 5.7E-10 

Standard Adult Resident 

Uranium 1.02E+00 1.4E-06 7.4E-07 8.4E-10 3.8E-10 1.2E-09 

 

Pathway total 8.4E-10 3.8E-10 1.2E-09 

a

EPC = Exposure point concentration; maximum values used to provide conservative exposure estimate.
01-217(doc)/093002 C-15 Table C.7. Toxicity values for human health risk and dose calculations Radionuclide CASRN ICRP lung type Soil ingestion (Risk/pCi) Inhalation (Risk/pCi) External exposure (Risk/yr/ pCi/g) Oral chronic RfD (mg/kg- day) Dermal chronic RfD (mg/kg- day) GI absorption factor Dermal absorption factor Soil ingesti

(mrem/

Uranium-234 013966-29-5 M 1.58E-10 1.14E-08 2.52E-10 2.84E-Uranium-235+D 015117-96-1(+D) M 1.63E-10 1.01E-08 5.43E-07 2.68E-Uranium-238+D 007440-61-1(+D) M 2.10E-10 9.35E-09 1.14E-07 2.68E-Uranium NA 6.00E-04 5.10E-04 0.8500 0.001 Dose factors from Federal Guidance Reports 11 and 12 Ingestion dose conversion factor Inhalation dose conversion factor External infinite Isotopes Sv/Bq mrem/pCi basis Sv/Bq mrem/pCi basis Sv per mrem/s per mrem/yr per Effective Effective Effective Effective Bq s m-3 pCi/m3 pCi/g Uranium-234 7.66E-08 2.8E-04 0.05 2.13E-06 7.89E-03 W 2.15E-21 7.96E-18 4.02E-04 Uranium-235+D 7.23E-08 2.68E-04 1.97E-06 7.30E-03 4.06E-18 1.50E-14 7.58E-01 U-235 7.19E-08 2.66E-04 0.05 1.97E-06 7.30E-03 W 3.86E-18 1.43E-14 7.21E-01 Th-231 3.65E-10 1.35E-06 2.33E-10 8.63E-07 W 1.95E-19 7.22E-16 3.64E-02 Uranium-238+D 7.25E-08 2.68E-04 1.91E-06 7.07E-03 6.90E-19 2.56E-15 1.29E-01 U-238 6.88E-08 2.55E-04 0.05 1.90E-06 7.04E-03 W 5.52E-22 2.04E-18 1.03E-04 Th-234 3.69E-09 1.37E-05 8.04E-09 2.98E-05 W 1.29E-19 4.78E-16 2.41E-02 Pa-234m 4.80E-19 1.78E-15 8.97E-02 Pa-234 5.84E-10 2.16E-06 1.98E-10 7.33E-07 W 6.18E-17 2.29E-13 1.15E+01 For lung class, W = M. 

CASRN = Chemical Abstract Services Registry Number. 

GI = gastrointestinal. ICRP = International Commission on Radiological Protection. RfD = reference dose. 
01-217(doc)/093002 C-16 Table C.8. Uranium source term Norma

Accident scenario Site Material Concentration (mg/kg) U-total activitya (pCi/g) U-234 activityb (pCi/g) 

All General container handling Composite/T Hopper 5.76E-03 4.03E-03 1.97E-03 No Action Storage area fire INEEL 1.51E-02 1.06E-02 5.16E-03 

PGDP 6.14E-05 4.30E-05 2.10E-05 

PORTS 1.74E-01 1.22E-01 5.96E-02 

SRS 3.45E-02 2.41E-02 1.18E-02 

Oak Ridge 1.65E-02 1.16E-02 5.66E-03 

Max other 2.04E-02 1.43E-02 6.99E-03 

Seismic (direct release) INEEL 9.08E-03 6.35E-03 3.11E-03 

PGDP 2.27E-04 1.59E-04 7.76E-05 

PORTS 5.92E-01 4.14E-01 2.02E-01 

SRS 3.85E-02 2.69E-02 1.32E-02 

Oak Ridge 1.82E-02 1.27E-02 6.21E-03 

Max other 7.54E-02 5.28E-02 2.58E-02 

Seismic (fire) INEEL 9.87E-04 6.91E-04 3.38E-04 

PGDP 1.53E-05 1.07E-05 5.25E-06 

 PORTS 4.06E-02 2.84E-02 1.39E-02 

 SRS 3.31E-03 2.32E-03 1.13E-03 

 Oak Ridge 1.57E-03 1.10E-03 5.37E-04 

Max other 5.11E-03 3.58E-03 1.75E-03 

Long-term Storage area fire All 3.56E-01 2.49E-01 1.22E-01 

centralized storage Seismic (direct release) All 1.02E+00 7.16E-01 3.50E-01 

Seismic (fire) All 7.16E-02 5.01E-02 2.45E-02 

Consolidate at Storage area fire INEEL 3.49E-02 2.44E-02 1.19E-02 several sites PGDP 5.22E-03 3.65E-03 1.79E-03  PORTS 2.40E-01 1.68E-01 8.20E-02 

 SRS 3.53E-02 2.47E-02 1.21E-02 

Oak Ridge 4.27E-02 2.99E-02 1.46E-02 
01-217(doc)/093002 C-17 Table C.8. Uranium source term (continued) Norma

Accident scenario Site Material Concentration (mg/kg) U-total activitya (pCi/g) U-234 activityb (pCi/g) 

Seismic (direct release) INEEL 3.32E-02 2.32E-02 1.14E-02 

PGDP 9.33E-03 6.53E-03 3.19E-03 

PORTS 8.23E-01 5.76E-01 2.82E-01 

SRS 4.16E-02 2.91E-02 1.42E-02 

Oak Ridge 1.15E-01 8.02E-02 3.92E-02 

Seismic (fire) INEEL 3.00E-03 2.10E-03 1.03E-03 

PGDP 7.09E-04 4.96E-04 2.43E-04 

PORTS 5.61E-02 3.92E-02 1.92E-02 

SRS 3.52E-03 2.46E-03 1.20E-03 

Oak Ridge 8.08E-03 5.65E-03 2.76E-03 

Consolidate at Storage area fire East 3.22E-01 2.25E-01 1.10E-01 

one western West 3.60E-02 2.52E-02 1.23E-02 site and one Seismic (direct release) East 9.86E-01 6.90E-01 3.37E-01 eastern site West 3.72E-02 2.61E-02 1.27E-02 

 Seismic (fire) East 6.84E-02 4.79E-02 2.34E-02 

 West 3.28E-03 2.29E-03 1.12E-03 

Consolidate by Storage area fire PORTS/compound, misc., oxide 1.54E-01 1.08E-01 5.28E-02 

physical form SRS/metal 8.71E-02 6.10E-02 2.98E-02 

 INEEL/reactfuel, source 1.06E-02 7.43E-03 3.63E-03 

Seismic (direct release) PORTS/compound, misc., oxide 9.61E-01 6.73E-01 3.29E-01 

 SRS/metal 4.82E-02 3.37E-02 1.65E-02 

 INEEL/reactfuel, source 1.26E-02 8.79E-03 4.29E-03 

Seismic (fire) PORTS/compound, misc., oxide 6.49E-02 4.54E-02 2.22E-02 

 SRS/metal 5.43E-03 3.80E-03 1.86E-03 

INEEL/reactfuel, source 1.06E-03 7.43E-04 3.63E-04 

Transfer to research Storage area fire Generic 1.26E-03 8.79E-04 4.30E-04 facility Seismic (direct release) Generic 4.06E-04 2.84E-04 1.39E-04 

Seismic (fire) Generic 2.51E-04 1.76E-04 8.60E-05 
01-217(doc)/093002 C-18 Table C.8. Uranium source term (continued) Norma

Accident scenario Site Material Concentration (mg/kg) U-total activitya (pCi/g) U-234 activityb (pCi/g) 

Transfer to other Storage area fire Generic 6.28E-02 4.39E-02 2.15E-02 government agencies Seismic (direct release) Generic 2.02E-02 1.42E-02 6.93E-03 

Seismic (fire) Generic 1.26E-02 8.79E-03 4.30E-03 

Foreign sales Storage area fire Generic 1.24E-01 8.69E-02 4.25E-02 

Seismic (direct release) Generic 4.37E-02 3.06E-02 1.50E-02 

Seismic (fire) Generic 2.68E-02 1.88E-02 9.17E-03 

1.02E+00 7.16E-01 3.50E-01 

amg U/kg soil * 1E-3 kg soil/g soil * 1E-3 g U/mg U * 7E-7 Ci/g U * 1E12 pCi/Ci = 7E-1 pCi/g per mg/kg. bTotal-U (pCi/g)/2.046 for U-234 and U-238 or Total-U (pCi/g)*0.046/2.046 for U-235. 

 U-235 = (21.6 * %enrichment * 0.01 * U-238) / {3.35*[1-(%enrichment*0.01)]}.  U-234 = U-235 × {27.18 - 0.3004(U-238/U-235) + [0.00143(U-238/U-235)]2}. 

 Estimated based on a best-fit curve from Fig. 2-2 of the Health Physics Manual of Good Practices for Uranium Facilities. 

INEEL = Idaho National Engineering and Environmental Laboratory. PGDP = Paducah Gaseous Diffusion Plant. PORTS = Portsmouth Gaseous Diffusion Plant. SRS = Savannah River Site. 
01-217(doc)/093002 C-19

 The second step of unit conversions was to partition the total activity among uranium isotopes. This was 

accomplished using guidance from the Health Physics Manual of Good Practices for Uranium Facilities

(DOE 1988). Concentrations of individual uranium isotopes were calculated based on the following 

equations: 

U-234 (pCi/g) = U-238 (pCi/g) = UT (pCi/g) / 2.046 = 3.55 / 2.046 = 1.73 pCi/g 

U-235 (pCi/g) = UT (pCi/g) * 0.046 / 2.046 = (3.55*0.046) / 2.046 = 0.080 pCi/g 

 This approach assumes a concentration ratio of 1.0-to-0.046-to-1.0 for 234U, 235U, and 238U, respectively. 

For this assessment it was also assumed that short-lived decay products (i.e., with half-life less than 6 months) 

of 235U and 238U were present at equilibrium concentrations. Modeled soil concentrations are tabulated in 

Table C.8. 

C.3.2 EXPOSURE PATHWAYS

 The complete exposure pathway is dependent on the following four conditions: 

• a source of contamination, 

• a route of transport to an exposure point, 

• a receptor at the exposure point, and 

• a route of exposure to the receptor. 

 For the accident condition considered, the soil is the source of contamination, and it is assumed that the 

identified receptors will be exposed to the contaminated soil. Routes of exposure are inhalation, ingestion, 

dermal contact, and external exposure to radiation. 

 Three receptors were evaluated in this assessment: an EM worker, an industrial worker, and a resident. 

The EM worker is assumed to be exposed to contaminants for 40 hours while conducting cleanup activities. 

The industrial worker is assumed to work in the area and is exposed for 8 hours/day, 250 days/year, for 

25 years. The resident is assumed to live on-site and is exposed for 24 hours/day, 350 days/year, for 30 years. 

The receptors have been chosen to represent a range of hypothetical exposures and provide an upper-bound 

estimate on potential health risks, although the residential receptor is not considered plausible under current 

site conditions The exposure parameters used in the evaluation are presented in Table C.3 and are used along 

with toxicity data presented in the following section to calculate risks and hazards. 

C.3.3 TOXICITY ASSESSMENT

 Table C.7 presents toxicity data, including cancer slope factors, reference doses (RfDs), and dose 

conversion factors. Slope factors were taken from EPA’s Health Effects Assessment Summary Table, and 

RfDs were taken from EPA’s Integrated Risk Information System. The dose conversion factors were derived 

from Federal Guidance Report No. 11 (EPA 1988) and Federal Guidance Report No. 12 (EPA 1993a). 

C.3.4 CHARACTERIZATION OF CONSEQUENCES

 The exposure parameters and toxicity data are used to calculate the overall risks, doses, and hazards to 

the exposed receptors. 
01-217(doc)/093002 C-20

C.3.4.1 Method

 Risks from the uranium isotopes were evaluated using the following equations per RAGS, Part A (see 

Table C.3 for details): 

• Ingestion risk = EPC * IRsoil * EF * ED * CF * CSFing

• Inhalation risk = EPC *IRair * (1/PEF) * ET * EF * ED * CF * CSFinh

• External exposure risk = EPC * (1-Se) * Te * EFext * ED * CSFext

 Hazards associated with total uranium were calculated with the following equations: 

• Oral hazard = EPC * FI * IRsoil * ED * EF * (1/RfD) / (AT * BW) 

• Dermal hazard = EPC * CFd * AF * ABS * SA * ED * EF * (1/RfD) / (AT * BW) 

 Doses were estimated for the uranium isotopes, with the following equations using modified RAGS, 

Part A, equations for dose versus risk estimates: 

• Ingestion dose = EPC * IRsoil * EF * CF * DCFing

• Inhalation dose = EPC *IRair * (1/PEF) * ET * EF * CF * DCFinh

• External dose = EPC * (1-Se) * Te * EFext * DCFext

 Total risk, hazard, and dose calculations were performed for each receptor and were calculated by 

summing across exposure pathways. The results of the carcinogenic risk, radiological dose, and 

noncarcinogenic hazard are presented in Tables C-4, C-5, and C-6, respectively. 

C.3.4.2 Results

 The maximum total risks for all isotopes are 2.1 × 10-10 for the EM worker, 2.6 × 10-7 for the standard 

industrial worker, and 1.3 × 10-6 for the standard resident. While only the EM worker risk is de minimus, all 

carcinogenic risk estimates are within or below the CERCLA target range of 10-4 to 10-6. The maximum 

calculated dose is 0.051 mrem/year for the implausible standard resident; thus, all doses are considered de 

minimus. The maximum calculated hazard is 1.2 × 10-9 for the implausible standard resident; thus, all hazards 

are considered de minimus. Overall the risks, doses, and hazards are within, or below, tolerable limits even 

using the conservative residential scenario and using the maximum modeled concentrations. These results 

indicate a low probability of adverse health effects from chronic exposure associated with the most serious 

accident scenario. 

C.3.5 OVERALL RISK EVALUATION

 Overall risks were evaluated by combining the consequences of an alternative-specific accident and the 

likelihood of the accident, as shown in Appendix A, Fig. A.1. Following are cancer risk categories: <10-6, 

negligible; between 10-6 and 10-5, low; between 10-5 and 10-4, moderate; and >10-4, high. Radiological 

consequence categories are shown in Appendix A, Tables A.11 and A.12. Following are toxicological 

consequence categories: hazard quotient (HQ) <0.1, negligible; HQ between 0.1 and 1, low; and HQ >1, high 
01-217(doc)/093002 C-21

(the moderate consequence category is not defined). The accident frequency and consequence categories for 

the proposed alternatives are shown in Tables C-9 and C-10, along with the resulting overall risks. 

C.4 ALTERNATIVE-SPECIFIC EVALUATION OF IMPACTS TO 

ECOLOGICAL RECEPTORS 

C.4.1 GENERAL APPROACH 

 Potential ecological exposures were evaluated for each alternative. It was assumed that airborne uranium 

will be deposited on soil and surface water. From surface water it will accumulate in sediment. Plants and 

terrestrial invertebrates are exposed to uranium by direct uptake from soil. Terrestrial vertebrates are exposed by 

direct uptake from soil and by ingestion of contaminated food. Aquatic biota and benthic invertebrates are 

exposed directly to uranium in surface water and sediment, respectively. Also evaluated are carnivores that 

prey on aquatic and benthic biota. All indicator receptors are exposed to the chemical effects of incorporated 

uranium as well as both external radiation from contaminated media and internal radiation from incorporated 

uranium. 

C.4.2 HAZARD IDENTIFICATION 

 The indicator terrestrial vertebrates used in this evaluation are short-tailed shrews and American robins, 

which are highly exposed to soil contaminants because they ingest relatively large quantities of soil along 

with a diet of plants and terrestrial invertebrates. The indicator vertebrate exposed to contaminants in water is 

the great blue heron, which is highly exposed because it ingests water and sediment as well as fish and 

sediment-dwelling benthic invertebrates. Because uranium does not bioaccumulate up the food chain, these 

receptors are expected to be more exposed than carnivores at a higher trophic level. For simplicity, it is 

assumed that the habitats of all of the indicator receptors occur within the path of the airborne uranium. 

C.4.3 EXPOSURE ASSESSMENT 

 The following three subsections describe the assessment of exposure of the ecological receptors, 

evaluation of the environmental toxicity of uranium, and an evaluation of the risks resulting from deposition 

of uranium after the hypothetical accidents described in the description of alternatives. 

 The exposure assessment includes an estimate of exposure concentrations at the locations where biota are 

expected to be maximally exposed under each alternative at each site. Concentrations of uranium in soil and 

water were based on estimates of the rate of deposition of airborne uranium released by accidents under each 

alternative. Estimates of media concentrations were made as described in Chap. 5. 

 Terrestrial biota are assumed to be exposed to uranium by uptake or ingestion and by direct exposure to 

contaminated soil. Aquatic biota and predators of aquatic biota are assumed to be exposed by uptake or 

ingestion and by direct exposure to contaminated surface water and sediment. It was assumed that the 

uranium in soil had the isotopic distribution of normal uranium (i.e., 48.8% of total U activity as 234U, 2.4% as 

235U, and 48.8% as 238U). 
01-217(doc)/093002 C-22 Table C.9. Summary of chronic radiation risks to human receptors due to deposition of uranium on soil under bounding 

Radiation risk Rad

Alternative Accident scenario Site Frequency Maximum risk Consequence level Risk Maximum dose C

All General container handling All Anticipated 7.6E-09 Negligible Negligible 3.1E-04 No Action Storage area fire INEEL Extremely 2.0E-08 Negligible Negligible 8.0E-04 

PGDP unlikely 8.1E-11 Negligible Negligible 3.3E-06 

PORTS 2.3E-07 Negligible Negligible 9.3E-03 SRS 4.6E-08 Negligible Negligible 1.8E-03 

Oak Ridge 2.2E-08 Negligible Negligible 8.8E-04 

Max other 2.7E-08 Negligible Negligible 1.1E-03 

Seismic (direct release) INEEL Extremely 1.2E-08 Negligible Negligible 4.8E-04 

PGDP unlikely 3.0E-10 Negligible Negligible 1.2E-05 

PORTS 7.8E-07 Negligible Negligible 3.2E-02 SRS 5.1E-08 Negligible Negligible 2.1E-03 

Oak Ridge 2.4E-08 Negligible Negligible 9.7E-04 

Max other 1.0E-07 Negligible Negligible 4.0E-03 

Seismic (fire) INEEL Extremely 1.3E-09 Negligible Negligible 5.3E-05 

PGDP unlikely 2.0E-11 Negligible Negligible 8.2E-07 

 PORTS 5.4E-08 Negligible Negligible 2.2E-03  SRS 4.4E-09 Negligible Negligible 1.8E-04 

 Oak Ridge 2.1E-09 Negligible Negligible 8.4E-05 

Max other 6.8E-09 Negligible Negligible 2.7E-04 

Centralized storage at a single site 

Storage area fire All Extremely

unlikely 

4.7E-07 Negligible Negligible 1.9E-02 

Seismic (direct release) All Extremely

unlikely 

1.4E-06 Low Low 5.5E-02 

Seismic (fire) All Extremely

unlikely 

9.5E-08 Negligible Negligible 3.8E-03 

Partially consolidated Storage area fire INEEL Extremely 4.6E-08 Negligible Negligible 1.9E-03 storage at several PGDP unlikely 6.9E-09 Negligible Negligible 2.8E-04 

DOE sites PORTS 3.2E-07 Negligible Negligible 1.3E-02 

 SRS 4.7E-08 Negligible Negligible 1.9E-03 

Oak Ridge 5.6E-08 Negligible Negligible 2.3E-03 
01-217(doc)/093002 C-23 Table C.9. Summary of chronic radiation risks to human receptors due to deposition of uranium on soil under bounding accide

Radiation risk Rad

Alternative Accident scenario Site Fre- quency Maximum risk Consequence level Risk Maximum dose C

Seismic (direct release) INEEL Extremely 4.4E-08 Negligible Negligible 1.8E-03 

PGDP unlikely 1.2E-08 Negligible Negligible 5.0E-04 

PORTS 1.1E-06 Low Low 4.4E-02 

SRS 5.5E-08 Negligible Negligible 2.2E-03 

Oak Ridge 1.5E-07 Negligible Negligible 6.1E-03 

Seismic (fire) INEEL Extremely 4.0E-09 Negligible Negligible 1.6E-04 

PGDP unlikely 9.4E-10 Negligible Negligible 3.8E-05 

PORTS 7.4E-08 Negligible Negligible 3.0E-03 SRS 4.6E-09 Negligible Negligible 1.9E-04 

Oak Ridge 1.1E-08 Negligible Negligible 4.3E-04 

Partially consolidated Storage area fire East Extremely 4.3E-07 Negligible Negligible 1.7E-02 

storage at two sites West unlikely 4.8E-08 Negligible Negligible 1.9E-03 

Seismic (direct release) East Extremely 1.3E-06 Low Low 5.3E-02 

West unlikely 4.9E-08 Negligible Negligible 2.0E-03 

Seismic (fire) East Extremely 9.0E-08 Negligible Negligible 3.6E-03 

West unlikely 4.3E-09 Negligible Negligible 1.7E-04 

Partially consolidated Storage area fire PORTS Extremely 2.0E-07 Negligible Negligible 8.2E-03 

storage based on SRS unlikely 1.2E-07 Negligible Negligible 4.6E-03 physical form INEEL 1.4E-08 Negligible Negligible 5.7E-04 

Seismic (direct release) PORTS Extremely 1.3E-06 Low Low 5.1E-02 

 SRS unlikely 6.4E-08 Negligible Negligible 2.6E-03 

 INEEL 1.7E-08 Negligible Negligible 6.7E-04 

 Seismic (fire) PORTS Extremely 8.6E-08 Negligible Negligible 3.5E-03  SRS unlikely 7.2E-09 Negligible Negligible 2.9E-04 

INEEL 1.4E-09 Negligible Negligible 5.7E-05 

Transfer to research Facility fire Generic Extremely 1.7E-09 Negligible Negligible 6.7E-05 

facility Seismic (direct release) Generic unlikely 5.4E-10 Negligible Negligible 2.2E-05 

Seismic (fire) Generic 3.3E-10 Negligible Negligible 1.3E-05 
01-217(doc)/093002 C-24 Table C.9. Summary of chronic radiation risks to human receptors due to deposition of uranium on soil under bounding accide

Radiation risk Rad

Alternative Accident scenario Site Fre- quency Maximum risk Consequence level Risk Maximum dose C

Transfer to other Facility fire Generic Extremely 8.3E-08 Negligible Negligible 3.3E-03 government agencies Seismic (direct release) Generic unlikely 2.7E-08 Negligible Negligible 1.1E-03 

Seismic (fire) Generic 1.7E-08 Negligible Negligible 6.7E-04 

Foreign sales Facility fire Generic Extremely 1.6E-07 Negligible Negligible 6.6E-03 

Seismic (direct release) Generic unlikely 5.8E-08 Negligible Negligible 2.3E-03 Seismic (fire) Generic 3.5E-08 Negligible Negligible 1.4E-03 

DOE = U.S. Department of Energy. HQ = hazard quotient. INEEL = Idaho National Engineering and Environmental Laboratory. PGDP = Paducah Gaseous Diffusion Plant. PORTS = Portsmouth Gaseous Diffusion Plant. SRS = Savannah River Site. 
01-217(doc)/093002 C-25

Table C.10. Summary of chronic chemical risks to human receptors due to deposition of uranium on 

soil under bounding accident scenarios 

 Chemical exposure

Alternative Accident scenario Site Frequency

Maximum 

HQ

Consequence 

level Risk

All 

General container 

 handling All Anticipated 4.8E-12 Negligible Negligible

No Action Storage area fire INEEL Extremely 1.3E-11 Negligible Negligible

 PGDP unlikely 5.1E-14 Negligible Negligible

 PORTS 1.4E-10 Negligible Negligible

 SRS 2.9E-11 Negligible Negligible

 Oak Ridge 1.4E-11 Negligible Negligible

 Max other 1.7E-11 Negligible Negligible

Seismic (direct release) INEEL Extremely 7.5E-12 Negligible Negligible

 PGDP unlikely 1.9E-13 Negligible Negligible

 PORTS 4.9E-10 Negligible Negligible

 SRS 3.2E-11 Negligible Negligible

 Oak Ridge 1.5E-11 Negligible Negligible

 Max other 6.2E-11 Negligible Negligible

 Seismic (fire) INEEL Extremely 8.2E-13 Negligible Negligible

 PGDP unlikely 1.3E-14 Negligible Negligible

 PORTS 3.4E-11 Negligible Negligible

 SRS 2.7E-12 Negligible Negligible

 Oak Ridge 1.3E-12 Negligible Negligible

 Max other 4.2E-12 Negligible Negligible

Centralized storage at 

a single site 

Storage area fire All Extremely

unlikely 

3.0E-10 Negligible Negligible

Seismic (direct release) All Extremely

unlikely 

8.5E-10 Negligible Negligible

 Seismic (fire) All Extremely

unlikely 

5.9E-11 Negligible Negligible

Partially consolidated Storage area fire INEEL Extremely 2.9E-11 Negligible Negligible

storage at several PGDP unlikely 4.3E-12 Negligible Negligible

DOE sites PORTS 2.0E-10 Negligible Negligible

 SRS 2.9E-11 Negligible Negligible

 Oak Ridge 3.5E-11 Negligible Negligible

Seismic (direct release) INEEL Extremely 2.7E-11 Negligible Negligible

 PGDP unlikely 7.7E-12 Negligible Negligible

 PORTS 6.8E-10 Negligible Negligible

 SRS 3.4E-11 Negligible Negligible

 Oak Ridge 9.5E-11 Negligible Negligible

 Seismic (fire) INEEL Extremely 2.5E-12 Negligible Negligible

 PGDP unlikely 5.9E-13 Negligible Negligible

 PORTS 4.6E-11 Negligible Negligible

 SRS 2.9E-12 Negligible Negligible

 Oak Ridge 6.7E-12 Negligible Negligible
01-217(doc)/093002 C-26

Table C.10. Summary of chronic chemical risks to human receptors due to deposition of uranium on 

soil under bounding accident scenarios (continued)

 Chemical exposure

Alternative Accident scenario Site Frequency

Maximum 

HQ

Consequence 

level Risk

Partially consolidated Storage area fire East Extremely 2.7E-10 Negligible Negligible

storage at two sites West unlikely 3.0E-11 Negligible Negligible

Seismic (direct release) East Extremely 8.2E-10 Negligible Negligible

 West unlikely 3.1E-11 Negligible Negligible

 Seismic (fire) East Extremely 5.7E-11 Negligible Negligible

 West unlikely 2.7E-12 Negligible Negligible

Partially consolidated Storage area fire PORTS Extremely 1.3E-10 Negligible Negligible

storage based on SRS unlikely 7.2E-11 Negligible Negligible

physical form INEEL 8.8E-12 Negligible Negligible

Seismic (direct release) PORTS Extremely 8.0E-10 Negligible Negligible

 SRS unlikely 4.0E-11 Negligible Negligible

 INEEL 1.0E-11 Negligible Negligible

 Seismic (fire) PORTS Extremely 5.4E-11 Negligible Negligible

 SRS unlikely 4.5E-12 Negligible Negligible

 INEEL 8.8E-13 Negligible Negligible

Transfer to research Facility fire Generic Extremely 1.0E-12 Negligible Negligible

facility Seismic (direct release) Generic unlikely 3.4E-13 Negligible Negligible

 Seismic (fire) Generic 2.1E-13 Negligible Negligible

Transfer to other Facility fire Generic Extremely 5.2E-11 Negligible Negligible

government agencies Seismic (direct release) Generic unlikely 1.7E-11 Negligible Negligible

 Seismic (fire) Generic 1.0E-11 Negligible Negligible

Foreign sales Facility fire Generic Extremely 1.0E-10 Negligible Negligible

Seismic (direct release) Generic unlikely 3.6E-11 Negligible Negligible

 Seismic (fire) Generic 2.2E-11 Negligible Negligible

DOE = U.S. Department of Energy. 

HQ = hazard quotient. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 

C.4.3.1 Terrestrial biota exposed to chemical toxicity of uranium 

 Plants and earthworms are exposed by direct contact and uptake of uranium from the surrounding soil. 

The concentration of uranium in plant and earthworm tissues is calculated by multiplying the soil 

concentration by a soil-to-tissue bioconcentration factor (Table C.11). Exposure of shrews and robins, the 

indicator receptors, is calculated by multiplying their rates of ingestion of plants, earthworms, and soil by the 

concentration of uranium in each of those ingested materials. Ingestion rates were published by EPA (1993b). 

The dose per unit body weight was calculated using body weights published by EPA (1993b). Daily doses in 

mg/kg body weight/day per mg U/kg soil were calculated as shown in Table C.11. 

C.4.3.2 Terrestrial biota exposed to radiological effects of uranium 

 The terrestrial receptors are exposed to external radiation from the surrounding soil and to internal 

radiation from incorporated uranium. External radiation doses were calculated for both surface exposure and 

subsurface exposure. 
01-217(doc)/093002 C-27 Table C.11. Chemical toxicity rates to ecological receptors from uranium in soila Receptor Fraction of time below ground surfaceb (Fbelow) Fraction of time above ground surfaceb (Fabove) BCFc (soil to tissue) (g soil/ g tissue) Bac (food to tissue) (d/kg) IRd (kg/d) BAFe (food to tissue) (g food/ g tissue) Tissue concen- trationf (mg/kg) Doseg (mg/kg or mg/kg/day) 

(

m

Plant 0 1 1.70E-03 NA NA 1.70E-03 1 Earthworm 0.9 0.1 3.30E-03 NA NA 3.30E-03 1 Shrew 0.25 0.75 NA 2.00E-04 Plant 1.24E-03 2.47E-07 NA 4.20E-10 Earthworm 8.27E-03 1.65E-06 NA 5.45E-09 Soil 1.24E-03 2.47E-07 NA 2.47E-07 Total 2.53E-07 Robin 0 0.5 NA 2.00E-04 Plant 6.08E-02 1.22E-05 NA 2.07E-08 Earthworm 6.08E-02 1.22E-05 NA 4.01E-08 Soil 1.26E-02 2.53E-06 NA 2.53E-06 Total 2.59E-06 

aDoses were calculated for a concentration of 1 mg/kg in soil. 

bAssumed values. cBioconcentration factors: 

 For plants, taken from Baes et al. (1984), adjusted to wet-weight basis by multiplying by 0.2, assuming earthworm is 80% water. 

 For earthworms, taken from DOE (1997), Appendix G, Table G.39, mean uptake value.  For mammals and birds, Ba is the biotransfer factor taken from Baes et al. (1984). dIngestion rate (EPA 1993b). 

eBa × IR. fSoil concentration (1 mg/kg) × BCF. gFor plants and earthworms, soil concentration; for shrews and robins, BAF × ingested soil and tissue concentration. hSee Table C.15. 

HQ = hazard quotient. NA = not applicable. TRV = toxicity reference value. 
01-217(doc)/093002 C-28

External subsurface exposure. The equation for subsurface exposure by immersion in soil is modified 

(Sample et al. 1997) from an equation for immersion in water (Blaylock, Frank, and O’Neal 1993): 

Dsub (rad/d) = 1.05 × Fbelow × CFa × Csoil × (Fb × Ebnb + Fg × Egng) , 

where 

Dsub = dose (rad/d) from uranium in soil by immersion in soil, 

1.05 = conversion factor to account for immersion in soil rather than water, 

Fbelow = fraction of time spent below ground surface (unitless; Table C.12), 

CFa = conversion factor to convert MeV/event to rad/d per pCi/g = 5.12 × 10-5, 

Csoil = activity of uranium in soil (pCi/g), 

Fb_ = absorbed fraction of energy E_ = 1 (Blaylock, Frank, and O’Neal 1993; Table C.12), 

Ebnb = beta energy of the radionuclide (MeV) × proportion of disintegrations producing a g-particle 

(Table A.1, EPA 1993a; Table C.12), 

Fg_ = absorbed fraction of energy E_ (Blaylock, Frank, and O’Neal 1993 and DOE 1997; Table C.12), 

Egng = photon energy emitted during transition from a higher to a lower energy state (MeV) ×

proportion of disintegrations producing a g-particle (Table A.1, EPA 1993a; Table C.12). 

 The external subsurface dose rates per pCi/g of total uranium in soil were calculated to be 0 for plants, 

6.47 × 10-7 for earthworms, 1.83 × 10-7 for shrews, and 0 for robins (Table C.12). 

External surface exposure. The equation for external radiation from surface exposure to uranium in soil 

(Sample et al. 1977) is: 

Dsur = Csoil × Fruf × CFb × DCFsoil × ECF , 

where 

Dsur = dose from surface soil (rad/d), 

Csoil = activity of uranium in soil (pCi/g), 

Fabove = fraction of time spent above ground (unitless, Table C.12), 

Fruf = dose rate reduction factor accounting for ground roughness (unitless) = 0.7 (Sample et al. 

1997), 

CFb = conversion factor to convert Sv/s per Bq/m3

 to rad/d per pCi/g = 5.12 × 1011, 

DCFsoil = external dose conversion factor for soil contaminated to a depth of 5 cm for 234U (1.82 × 10-21), 

235U (2.65 × 10-18), or 238U (5.45 × 10-22) [Table III.5 EPA 1993a; Table C.12], 

ECF = elevation correction factor to adjust dose coefficients to value representative of effective 

height of receptor above ground (Sample et al. 1997; Table C.12). 

 The external surface dose rates per pCi/g of total uranium in soil were calculated to be 4.72 × 10-8 for 

plants, 4.72 × 10-9 for earthworms, 3.54 × 10-8 for shrews, and 2.36 × 10-8 for robins (Table C.12). 
01-217(doc)/093002 C-29 Table C.12. Radiation dose rates to ecological receptors from uranium in soila Radiation dose 

Receptor Fraction of time below ground Surfaceb (Fbelow) Fraction of time above ground Surfaceb (Fabove) BCFc (soil to tissue) (g soil/ g tissue) Bac (food to tissue) (d/kg) IRd (kg/d) BAFe (food to tissue) (g food/ g tissue) Tissue activityf (pCi/ g tissue) Subsurface Surfa

Plant 0 1 1.70E-03 NA NA 1.70E-03 0.00E+00 4.72E-Earthworm 0.9 0.1 3.30E-03 NA NA 3.30E-03 6.47E-07 4.72E-Shrew 0.25 0.75 NA 2.00E-04 Plant 1.24E-03 2.47E-07 4.20E-10 Earthworm 8.27E-03 1.65E-06 5.45E-09 Soil 1.24E-03 2.47E-07 2.47E-07 Total 2.53E-07 1.83E-07 3.54E-Robin 0 0.5 NA 2.00E-04 Plant 6.08E-02 1.22E-05 2.07E-08 Earthworm 6.08E-02 1.22E-05 4.01E-08 Soil 1.26E-02 2.53E-06 2.53E-06 Total 2.59E-06 0.00E+00 2.36E-

aDoses were calculated for an activity of 1 pCi/g in soil. bAssumed values. cBioconcentration factors (EPA 1999). dIngestion rate (EPA 1993b). eBa × IR. fSoil concentration (1 mg/kg) × BCF. gCalculated by equipments found in Sect. C.4.3.2. Radiation dose parameters are as follows: 

 Isotope U-234 U-235 U-238 Fg_ for: U-234 U-235 U-238 

 DCF 1.82E-21 2.65E-18 5.45E-22 Plants 0.63 0.008 0.63  E_n_ 4.46 4.4 4.19 Earthworms 0.63 0.008 0.63  E_n_ 0.013 0.049 0.01 Shrew 0.79 0.0115 0.79  E_n_ 0.002 0.156 0.001 Robin 0.79 0.0115 0.79 
01-217(doc)/093002 C-30

Internal exposure. Internal exposures were calculated by multiplying the tissue activity by decay energy 

and absorption factors and conversion factors (Blaylock, Frank, and O’Neal 1993; Sample et al. 1997): 

Dint = Ctiss × CFa × (QF × Fa × Eana + Fb × Ebnb + FgEgng) , 

where 

Dint = internal radiation dose from incorporated uranium (rad/d), 

Ctiss = uranium activity in receptor tissues (pCi/g tissue), 

CFa = conversion factor to convert MeV/event to rad/d per pCi/g = 5.12 × 10-5, 

QF = quality factor to account for greater biological effectiveness of alpha particles = 5, 

Fa = absorbed fraction of energy E_ = 1 (Blaylock, Frank, and O’Neal 1993), 

Eana = alpha energy of the radionuclide (MeV) × proportion of disintegrations producing an a-particle 

 (Table A.1, EPA 1993a; Table C.12), 

Fb = absorbed fraction of energy E_ = 1 (Blaylock, Frank, and O’Neal 1993), 

Ebnb = beta energy of the radionuclide (MeV) × proportion of disintegrations producing a b-particle 

 (Table A.1, EPA 1993a; Table C.12), 

Fg = absorbed fraction of energy E_ (Blaylock, Frank, and O’Neal 1993 and DOE 1997; Table C.12), 

Egng = photon energy emitted during transition from a higher to a lower energy state (MeV) 

× proportion of disintegrations producing a g-particle (Table A.1, EPA 1993a; Table C.12). 

 Alpha radiation has a higher biological effect on biological tissue than beta and gamma radiation because 

of the momentum carried by the large mass of the alpha particle. To account for the higher effect of alpha 

radiation, the alpha radiation dose is multiplied by a quality factor of 5. 

 The internal dose rates per pCi/g of total uranium in soil were calculated to be 1.88 × 10-6 for plants, 

4.30 × 10-6 for earthworms, 2.19 × 10-7 for shrews, and 2.64 × 10-8 for robins (Table C.12). 

C.4.3.3 Aquatic biota exposed to chemical toxicity of uranium 

 Aquatic biota (represented by fish) and benthic invertebrates are exposed by direct contact and uptake of 

uranium from the surrounding surface water and sediment. The concentration of uranium in fish tissues is 

calculated by multiplying the surface water concentration by a water-to-tissue bioconcentration factor 

[50 L/kg tissue (NRC 1992); Table C.13]. The concentration of uranium in benthic invertebrate tissues was 

calculated by multiplying the sediment concentration by a sediment-to-tissue bioconcentration factor [0.9 kg 

sediment/kg tissue (EPA 1999); Table C.13]. Exposure of great blue herons, the indicator receptors, was 

calculated by multiplying their rates of ingestion of fish, benthic invertebrates, surface water, and sediment by 

the concentration of uranium in each of those ingested materials. Ingestion rates were published by EPA 

(1993b). The dose per unit body weight was calculated using body weights published by EPA (1993b). Daily 

doses in mg/kg body weight/day per mg U/L water were calculated as shown in Table C.13. The daily dose 

for herons was calculated to be 6.40 × 10-3 mg/kg/d per mg/L (Table C.13). 
01-217(doc)/093002 C-31 Table C.13. Chemical toxicity rates to ecological receptors from uranium in surface water and sedimen

Receptor Fraction of time exposed to sedimentb (Fsed) Fraction of time exposed to waterb (Fwater) BCFc (medium to tissue) (kg sed or L water/ kg tissue) Bac (food to tissue) (d/kg) IRd (kg/d or L/d)) BAFe (food to tissue) (g food/ g tissue) Tissue concen- trationf (mg/kg) Doseg (mg/kg or mg/L or mg/kg/day) 

Aquatic biota 0 1 5.00E+01 NA NA 5.00E+01 1.00E+00 Sed. Inverts 0.9 0.1 9.00E-01 NA NA 2.52E+02 2.80E+02 Heron 0 0.5 Fish NA 2.00E-04 4.09E-01 8.17E-05 NA 4.09E-03 Inverts NA 2.00E-04 2.15E-02 4.30E-06 NA 1.08E-03 Water NA 2.00E-04 1.08E-01 2.15E-05 NA 2.15E-05 Sediment NA 2.00E-04 2.15E-02 4.30E-06 NA 1.20E-03 Total 6.40E-03 

aDoses were calculated for a concentration of 1 mg/L in surface water. 

bAssumed values. cBioconcentration factors (EPA 1999). 

 For aquatic biota, taken from NRC (1992).  For benthic invertebrates, taken from EPA (1999).  For great blue herons, Ba is the biotransfer factor taken from Baes et al. (1984). dIngestion rate (EPA 1993b). 

eBa × IR. fSurface water concentration (1 mg/L) × BCF; also multiplied by 280 to account for binding of uranium to sediment. gFor aquatic biota, surface water concentration; for benthic invertebrates, sediment concentration. hSee Table C.15. 

HQ = hazard quotient. NA = not applicable. TRV = toxicity reference value. 
01-217(doc)/093002 C-32

C.4.3.4 Aquatic biota exposed to radiological effects of uranium 

 The aquatic receptors are exposed to external radiation from the surrounding water and sediment and to 

internal radiation from incorporated uranium. External radiation doses were calculated for both immersion in 

surface water and immersion in sediment. 

 External exposure to surface water. The equation for external exposure by immersion in surface water is 

given by Blaylock, Frank, and O’Neal (1993): 

Dsw = Fbelow × CFa × Csw × 0.001 × Egng × (1- Fg) , 

where 

Dsw = dose from uranium by immersion in surface water (rad/d), 

Fbelow = fraction of time spent immersed in water or, for the heron, close enough to the water surface to 

receive external radiation (unitless, Table C.14), 

CFa = conversion factor to convert MeV/event to rad/d per pCi/g water = 5.12 × 10-5, 

Csw = activity of uranium in surface water (pCi/L), 

0.001 = L water/g water, 

Egng = photon energy emitted during transition from a higher to a lower energy state (MeV) ×

proportion of disintegrations producing a g-particle (Table A.1, EPA 1993a; Table C.14), 

Fg = absorbed fraction of energy Eg (Blaylock, Frank, and O’Neal 1993 and DOE 1997; Table C.14). 

 The external water dose rates per pCi/L of total uranium in surface water were calculated to be 1.81 ×

10-10 for fish, 2.21 × 10-11 for benthic invertebrates, and 9.38 × 10-11 for great blue herons (Table C.14). 

External exposure to surface water. The equation for external exposure by immersion in sediment is 

given by Blaylock, Frank, and O’Neal (1993): 

Dsw = Fbelow × CFa × Csw × 280 × Egng × (1- Fg) , 

where 

Dsw = dose from uranium by immersion in sediment (rad/d), 

Fbelow = fraction of time spent immersed in sediment (unitless, Table C.14), 

CFa = conversion factor to convert MeV/event to rad/d per pCi/g sediment = 5.12 × 10-5, 

Csw = activity of uranium in surface water (pCi/L), 

280 = mg U/kg sediment per mg U/L water, 

Egng = photon energy emitted during transition from a higher to a lower energy state (MeV) ×

proportion of disintegrations producing a g-particle (Table A.1, EPA 1993a; Table C.14), 

Fg = absorbed fraction of energy Eg (Blaylock, Frank, and O’Neal 1993 and DOE 1997; Table C.14). 

 The external sediment dose rates per pCi/L of total uranium in surface water were calculated to be 0 for 

fish, 9.80 × 10-5 for benthic invertebrates, and 0 for great blue herons (Table C.14). 

Internal exposure to incorporated uranium. Internal exposures of fish, benthic invertebrates, and 

herons were calculated as described for terrestrial receptors and are shown in Table C.14. The internal dose 

rates per pCi/L total uranium in surface water were calculated to be 4.05 × 10-6 for fish, 1.18 × 10-4 for benthic 

invertebrates, and 9.97 × 10-8 for great blue herons (Table C.14). 
01-217(doc)/093002 C-33 Table C.14. Radiation dose rates to ecological receptors from uranium in surface water and sedimenta Radiation dose (ra

Receptor Fraction of time exposed to sedimentb (Fsed) Fraction of time exposed to waterb (Fwater) BCFc (medium to tissue) (kg sed or L water/ kg tissue) Bac (food to tissue) (d/kg) IRd (kg/d or L/d) BAFe (food to tissue) (g food/ g tissue) Tissue activity (pCi/ g tissue) Sediment Water 

Aquatic biota 0 1 5.00E+01 NA NA 5.00E-02 0.00E+00 1.81E-10 Sed. Inverts 0.9 0.1 9.00E-01 NA NA 2.52E-01 9.80E-05 2.21E-11 

Heron 0 0.5 Fish NA 2.00E-04 4.09E-01 8.17E-05 4.09E-06 Inverts NA 2.00E-04 2.15E-02 4.30E-06 1.08E-06 Water NA 2.00E-04 1.08E-01 2.15E-05 2.15E-05 Sediment NA 2.00E-04 2.15E-02 4.30E-06 1.20E-03 Total 1.23E-03 0.00E+00 9.38E-11 

aDoses were calculated for a concentration of 1 mg/L in surface water. 

bAssumed values. cBioconcentration factors (EPA 1999). dIngestion rate (EPA 1993b). eBa × IR. fSurface water concentration (1 mg/L) × BCF; also multiplied by 280 to account for binding of uranium to sediment. gFor aquatic biota, surface water concentration; for benthic invertebrates, sediment concentration; for herons, BAF × ingested water, sedimenhCalculated by equations found in Section C.4.3.2. Radiation dose parameters are as follows: 

Isotope U-234 U-235 U-238 Fg for: U-234 U-235 U-238 

DCF 1.82E-21 2.65E-18 5.45E-22 Aquatic biota 0.94 0.0949 0.94 

Eana 4.46 4.4 4.19 Benthic invertebrates 0.63 0.008 0.63 Ebnb 0.013 0.049 0.01 Heron 0.94 0.06 0.94 

Egng 0.002 0.156 0.001 

 NA = not applicable.
01-217(doc)/093002 C-34

C.4.4 EFFECTS ASSESSMENT 

C.4.4.1 Chemical effects 

 The toxic effects of uranium were evaluated for all receptors. Effects evaluated were toxicity of uranium 

in soil to plants (Efroymson et al. 1997) and earthworms (Efroymson, Will, and Suter 1997); toxicity of 

ingested uranium to shrews, robins, and herons (Sample, Opresko, and Suter 1996); toxicity of uranium in 

water to fish (Suter and Tsao 1996); and toxicity of uranium in sediment to benthic invertebrates (Jones, 

Suter, and Hull 1997). The toxicity endpoints, benchmarks used, and their sources are described in 

Table C.15. 

C.4.4.2 Irradiation 

 Ionizing radiation (alpha, beta, and gamma radiation) interacts with biological molecules to produce free 

radicals and ions. High doses can cause death from radiation sickness induced by high levels of damage. 

However, at low doses, the major concern is damage to deoxyribonucleic acid (DNA). DNA damage that is not 

repaired by the organism can cause cancerous tumors, leukemia, and heritable genetic damage. The endpoint for 

radiation toxicity to ecological receptors is maintenance of populations. The benchmark values given by the 

International Atomic Energy Agency (IAEA 1992) are 0.1 rad/day for terrestrial mammals and birds and 

1 rad/day for plants, invertebrates, and aquatic biota. These values were used as benchmarks in this assessment. 

C.4.5 CONSEQUENCE EVALUATION 

 Hypothetical accident scenarios, identified in Sect. 1.2 and evaluated for acute risk to humans in 

Sect. 1.3, are evaluated in this section for chronic risk to the environment. Accident scenarios are described in 

detail in Sect. 1.3 and are referred to only by alternative in this section. For each alternative, each location, 

and each receptor, the daily dose was divided by the benchmark dose to calculate the HQ. If the HQ is above 

1, exposure above the benchmark is indicated and further evaluation is required to determine whether 

unacceptable ecological risks are indicated. Consequences of exposure to uranium in soil were evaluated by 

comparing the modeled chemical and radiological doses to benchmarks for toxicity to plants and soil 

invertebrates (earthworms), which are exposed directly to soil contaminants, and to small mammals (shrews) 

and songbirds (robins), which are exposed by eating soil and prey that have accumulated uranium from the 

soil (Tables C.16 and C.17). Consequences of exposure to uranium in surface water were evaluated by 

comparing concentrations in water or chemical and radiological doses to benchmarks for aquatic biota (fish), 

which are exposed directly to waterborne contaminants; to benthic invertebrates, which are exposed directly 

to sediment contaminants; and to herons, which are exposed by ingesting prey that have accumulated uranium 

from the water, surface water, and sediment and by direct exposure to surface water (Tables C.18 and C.19). 

C.4.5.1 Soil 

 Tables C.16 and C.17 show that no alternative resulted in unacceptable risks to terrestrial receptors. The 

highest chemical risk, with an HQ of 0.205 (Table C.16), was to plants exposed to uranium in soil after a 

direct seismic release under centralized storage at a single site. This HQ is rather uncertain for a large 

population of plants for a number of reasons. First, it assumes that all plants are exposed at the maximum soil 

concentration, whereas the deposition model shows that the concentrations fall off rapidly with both lateral 

and longitudinal distance from the maximum point. Second, the model assumes that the wind blows in only 

one direction, whereas variable wind directions will realistically result in a variety of downwind directions, so 

deposition will be dispersed rather than along a single centerline of the plume. Third, exceeding the toxicity 

benchmark by 1% may inhibit growth of plants but is not likely to be detrimental to the plant population. The 

highest chemical HQ for other terrestrial animal receptors is 1.7 × 10-7 for exposure of robins to soil uranium.
01-217(doc)/093002 C-35

Table C.15. Uranium toxicity benchmarks for ecological receptors 

Receptor 

Concentration 

or dose Justification Reference 

Terrestrial plants 5 mg/kg Inhibition of 

root growth 

Efroymson et al. 1997 

Earthworms No data Not applicable Not applicable 

Short-tailed shrew 3.07 mg/kg BW/day Chronic NOAEL for 

decreased reproduction 

American robin 16.0 mg/kg BW/day No observed effect from 

subchronic exposure at 

160 mg/kg; uncertainty factor 

of 10 used to estimate chronic 

NOAEL 

Sample, Opresko, 

and Suter 1996 

Aquatic biota 2.6 mg/L Tier II Secondary 

chronic value 

Suter and Tsao 1996 

Benthic invertebrates No data Not applicable Not applicable 

Great blue heron 16.0 mg/kg BW/day No observed effect from 

subchronic exposure at 

160 mg/kg; uncertainty factor 

of 10 used to estimate chronic 

NOAEL 

Sample, Opresko, 

and Suter 1996 

BW = body weight. 

NOAEL = No observed adverse effect level. 
01-217(doc)/093002 C-36

Table C.16. Chemical toxicity consequences to ecological receptors due to deposition of uranium on 

soil under bounding accident scenarios 

 

Untilled 

soil HQ for ecological receptors

Alternative Accident scenario Site

concentration

(mg/kg) Plants Shrews Robins

All 

General container 

handling All 5.76E-03 1.15E-03 4.75E-10 9.33E-10 

No Action Storage area fire INEEL 1.51E-02 3.02E-03 1.24E-09 2.45E-09 

 PGDP 6.14E-05 1.23E-05 5.06E-12 9.94E-12 

 PORTS 1.74E-01 3.48E-02 1.44E-08 2.82E-08 

 SRS 3.45E-02 6.90E-03 2.84E-09 5.59E-09 

 Oak Ridge 1.65E-02 3.31E-03 1.36E-09 2.68E-09 

 Max other 2.04E-02 4.08E-03 1.68E-09 3.31E-09 

Seismic (direct release) INEEL 9.08E-03 1.82E-03 7.48E-10 1.47E-09 

 PGDP 2.27E-04 4.54E-05 1.87E-11 3.68E-11 

 PORTS 5.92E-01 1.18E-01 4.87E-08 9.58E-08 

 SRS 3.85E-02 7.70E-03 3.17E-09 6.24E-09 

 Oak Ridge 1.82E-02 3.63E-03 1.50E-09 2.94E-09 

 Max other 7.54E-02 1.51E-02 6.22E-09 1.22E-08 

 Seismic (fire) INEEL 9.87E-04 1.97E-04 8.14E-11 1.60E-10 

 PGDP 1.53E-05 3.07E-06 1.26E-12 2.49E-12 

 PORTS 4.06E-02 8.11E-03 3.34E-09 6.57E-09 

 SRS 3.31E-03 6.63E-04 2.73E-10 5.37E-10 

 Oak Ridge 1.57E-03 3.14E-04 1.29E-10 2.54E-10 

 Max other 5.11E-03 1.02E-03 4.21E-10 8.28E-10 

Centralized storage at Storage area fire All 3.56E-01 7.12E-02 2.93E-08 5.77E-08 

a single site Seismic (direct release) All 1.02E+00 2.05E-01 8.43E-08 1.66E-07 

 Seismic (fire) All 7.16E-02 1.43E-02 5.90E-09 1.16E-08 

Partially consolidated Storage area fire INEEL 3.49E-02 6.98E-03 2.87E-09 5.65E-09 

storage at several PGDP 5.22E-03 1.04E-03 4.30E-10 8.45E-10 

DOE sites PORTS 2.40E-01 4.80E-02 1.98E-08 3.88E-08 

 SRS 3.53E-02 7.05E-03 2.91E-09 5.71E-09 

 Oak Ridge 4.27E-02 8.53E-03 3.52E-09 6.91E-09 

Seismic (direct release) INEEL 3.32E-02 6.64E-03 2.73E-09 5.37E-09 

 PGDP 9.33E-03 1.87E-03 7.69E-10 1.51E-09 

 PORTS 8.23E-01 1.65E-01 6.78E-08 1.33E-07 

 SRS 4.16E-02 8.33E-03 3.43E-09 6.74E-09 

 Oak Ridge 1.15E-01 2.29E-02 9.44E-09 1.86E-08 

 Seismic (fire) INEEL 3.00E-03 6.01E-04 2.48E-10 4.87E-10 

 PGDP 7.09E-04 1.42E-04 5.84E-11 1.15E-10 

 PORTS 5.61E-02 1.12E-02 4.62E-09 9.08E-09 

 SRS 3.52E-03 7.03E-04 2.90E-10 5.70E-10 

 Oak Ridge 8.08E-03 1.62E-03 6.65E-10 1.31E-09 

Partially consolidated Storage area fire East 3.22E-01 6.44E-02 2.65E-08 5.22E-08 

storage at two sites West 3.60E-02 7.19E-03 2.96E-09 5.83E-09 

Seismic (direct release) East 9.86E-01 1.97E-01 8.12E-08 1.60E-07 

 West 3.72E-02 7.45E-03 3.07E-09 6.03E-09 

 Seismic (fire) East 6.84E-02 1.37E-02 5.64E-09 1.11E-08 

 West 3.28E-03 6.55E-04 2.70E-10 5.31E-10 
01-217(doc)/093002 C-37

Table C.16. Chemical toxicity consequences to ecological receptors due to deposition of uranium on 

soil under bounding accident scenarios (continued) 

 

Untilled 

soil HQ for ecological receptors

Alternative Accident scenario Site

concentration

(mg/kg) Plants Shrews Robins

Partially consolidated Storage area fire PORTS 1.54E-01 3.09E-02 1.27E-08 2.50E-08 

storage based on SRS 8.71E-02 1.74E-02 7.18E-09 1.41E-08 

physical form INEEL 1.06E-02 2.12E-03 8.75E-10 1.72E-09 

Seismic (direct release) PORTS 9.61E-01 1.92E-01 7.92E-08 1.56E-07 

 SRS 4.82E-02 9.64E-03 3.97E-09 7.81E-09 

 INEEL 1.26E-02 2.51E-03 1.03E-09 2.03E-09 

 Seismic (fire) PORTS 6.49E-02 1.30E-02 5.35E-09 1.05E-08 

 SRS 5.43E-03 1.09E-03 4.47E-10 8.80E-10 

 INEEL 1.06E-03 2.12E-04 8.75E-11 1.72E-10 

Transfer to research Facility fire Generic 1.26E-03 2.51E-04 1.03E-10 2.03E-10 

facility Seismic (direct release) Generic 4.06E-04 8.11E-05 3.34E-11 6.57E-11 

 Seismic (fire) Generic 2.51E-04 5.03E-05 2.07E-11 4.07E-11 

Transfer to other Facility fire Generic 6.28E-02 1.26E-02 5.17E-09 1.02E-08 

government agencies Seismic (direct release) Generic 2.02E-02 4.05E-03 1.67E-09 3.28E-09 

 Seismic (fire) Generic 1.26E-02 2.51E-03 1.03E-09 2.03E-09 

Foreign sales Facility fire Generic 1.24E-01 2.48E-02 1.02E-08 2.01E-08 

Seismic (direct release) Generic 4.37E-02 8.75E-03 3.60E-09 7.08E-09 

 Seismic (fire) Generic 2.68E-02 5.36E-03 2.21E-09 4.34E-09 

 2.05E-01 8.43E-08 1.66E-07 

DOE = U.S. Department of Energy. 

HQ = hazard quotient. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 
01-217(doc)/093002 C-38

Table C.17. Radiological consequences to ecological receptors due to deposition of uranium on soil under 

bounding accident scenarios 

Untilled

soil HQ for ecological receptors 

Alternative Accident scenario Site 

activity

(pCi/g) Plants 

Soil 

invertebrates Shrews Robins 

All 

General container 

handling All 4.03E-03 7.78E-09 1.73E-08 8.83E-10 1.06E-10

No Action Storage area fire INEEL 1.06E-02 2.04E-08 4.54E-08 2.31E-09 2.79E-10

 PGDP 4.30E-05 8.29E-11 1.85E-10 9.41E-12 1.13E-12

 PORTS 1.22E-01 2.35E-07 5.24E-07 2.67E-08 3.22E-09

 SRS 2.41E-02 4.66E-08 1.04E-07 5.29E-09 6.37E-10

 Oak Ridge 1.16E-02 2.23E-08 4.98E-08 2.54E-09 3.06E-10

 Max other 1.43E-02 2.76E-08 6.15E-08 3.13E-09 3.77E-10

Seismic (direct release) INEEL 6.35E-03 1.23E-08 2.73E-08 1.39E-09 1.68E-10

 PGDP 1.59E-04 3.07E-10 6.83E-10 3.48E-11 4.19E-12

 PORTS 4.14E-01 7.99E-07 1.78E-06 9.07E-08 1.09E-08

 SRS 2.69E-02 5.20E-08 1.16E-07 5.90E-09 7.11E-10

 Oak Ridge 1.27E-02 2.45E-08 5.46E-08 2.78E-09 3.35E-10

 Max other 5.28E-02 1.02E-07 2.27E-07 1.16E-08 1.39E-09

 Seismic (fire) INEEL 6.91E-04 1.33E-09 2.97E-09 1.51E-10 1.82E-11

 PGDP 1.07E-05 2.07E-11 4.62E-11 2.35E-12 2.83E-13

 PORTS 2.84E-02 5.48E-08 1.22E-07 6.22E-09 7.49E-10

 SRS 2.32E-03 4.48E-09 9.98E-09 5.08E-10 6.13E-11

 Oak Ridge 1.10E-03 2.12E-09 4.72E-09 2.41E-10 2.90E-11

 Max other 3.58E-03 6.91E-09 1.54E-08 7.84E-10 9.45E-11

Centralized storage at Storage area fire All 2.49E-01 4.81E-07 1.07E-06 5.46E-08 6.58E-09

a single site Seismic (direct release) All 7.16E-01 1.38E-06 3.08E-06 1.57E-07 1.89E-08

 Seismic (fire) All 5.01E-02 9.67E-08 2.15E-07 1.10E-08 1.32E-09

Partially consolidated Storage area fire INEEL 2.44E-02 4.71E-08 1.05E-07 5.35E-09 6.44E-10

storage at several PGDP 3.65E-03 7.05E-09 1.57E-08 8.00E-10 9.64E-11

DOE sites PORTS 1.68E-01 3.24E-07 7.22E-07 3.68E-08 4.43E-09

 SRS 2.47E-02 4.76E-08 1.06E-07 5.41E-09 6.52E-10

 Oak Ridge 2.99E-02 5.76E-08 1.28E-07 6.54E-09 7.89E-10

Seismic (direct release) INEEL 2.32E-02 4.48E-08 9.99E-08 5.09E-09 6.13E-10

 PGDP 6.53E-03 1.26E-08 2.81E-08 1.43E-09 1.72E-10

 PORTS 5.76E-01 1.11E-06 2.48E-06 1.26E-07 1.52E-08

 SRS 2.91E-02 5.62E-08 1.25E-07 6.38E-09 7.69E-10

 Oak Ridge 8.02E-02 1.55E-07 3.45E-07 1.76E-08 2.12E-09

 Seismic (fire) INEEL 2.10E-03 4.06E-09 9.04E-09 4.61E-10 5.55E-11

 PGDP 4.96E-04 9.58E-10 2.13E-09 1.09E-10 1.31E-11

 PORTS 3.92E-02 7.57E-08 1.69E-07 8.60E-09 1.04E-09

 SRS 2.46E-03 4.75E-09 1.06E-08 5.39E-10 6.50E-11

 Oak Ridge 5.65E-03 1.09E-08 2.43E-08 1.24E-09 1.49E-10

Partially consolidated Storage area fire East 2.25E-01 4.35E-07 9.69E-07 4.94E-08 5.95E-09

storage at two sites West 2.52E-02 4.86E-08 1.08E-07 5.51E-09 6.65E-10

Seismic (direct release) East 6.90E-01 1.33E-06 2.97E-06 1.51E-07 1.82E-08

 West 2.61E-02 5.03E-08 1.12E-07 5.71E-09 6.88E-10

 Seismic (fire) East 4.79E-02 9.24E-08 2.06E-07 1.05E-08 1.26E-09

 West 2.29E-03 4.43E-09 9.86E-09 5.02E-10 6.05E-11
01-217(doc)/093002 C-39

Table C.17. Radiological consequences to ecological receptors due to deposition of uranium on soil under 

bounding accident scenarios (continued) 

Untilled

soil HQ for ecological receptors 

Alternative Accident scenario Site 

activity

(pCi/g) Plants 

Soil 

invertebrates Shrews Robins 

Partially consolidated Storage area fire PORTS 1.08E-01 2.09E-07 4.65E-07 2.37E-08 2.85E-09

storage based on SRS 6.10E-02 1.18E-07 2.62E-07 1.34E-08 1.61E-09

physical form INEEL 7.43E-03 1.43E-08 3.19E-08 1.63E-09 1.96E-10

Seismic (direct release) PORTS 6.73E-01 1.30E-06 2.89E-06 1.47E-07 1.78E-08

 SRS 3.37E-02 6.51E-08 1.45E-07 7.39E-09 8.91E-10

 INEEL 8.79E-03 1.70E-08 3.78E-08 1.92E-09 2.32E-10

 Seismic (fire) PORTS 4.54E-02 8.77E-08 1.95E-07 9.95E-09 1.20E-09

 SRS 3.80E-03 7.34E-09 1.63E-08 8.33E-10 1.00E-10

 INEEL 7.43E-04 1.43E-09 3.19E-09 1.63E-10 1.96E-11

Transfer to research Facility fire Generic 8.79E-04 1.70E-09 3.78E-09 1.92E-10 2.32E-11

facility Seismic (direct release) Generic 2.84E-04 5.48E-10 1.22E-09 6.22E-11 7.49E-12

 Seismic (fire) Generic 1.76E-04 3.40E-10 7.57E-10 3.85E-11 4.65E-12

Transfer to other Facility fire Generic 4.39E-02 8.48E-08 1.89E-07 9.62E-09 1.16E-09

government agencies Seismic (direct release) Generic 1.42E-02 2.73E-08 6.09E-08 3.10E-09 3.74E-10

 Seismic (fire) Generic 8.79E-03 1.70E-08 3.78E-08 1.92E-09 2.32E-10

Foreign sales Facility fire Generic 8.69E-02 1.68E-07 3.74E-07 1.90E-08 2.29E-09

Seismic (direct release) Generic 3.06E-02 5.91E-08 1.32E-07 6.70E-09 8.08E-10

 Seismic (fire) Generic 1.88E-02 3.62E-08 8.07E-08 4.11E-09 4.95E-10

 Max 1.38E-06 3.08E-06 1.57E-07 1.89E-08

DOE = U.S. Department of Energy. 

HQ = hazard quotient. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 
01-217(doc)/093002 C-40

Table C.18. Chemical toxicity consequences to ecological receptors due to deposition of uranium on 

surface water under bounding accident scenarios 

Surface 

water 

HQ for 

ecological receptors 

Alternative Accident scenario Site 

concentration

(mg/L) 

Aquatic 

biota Herons 

All 

General container 

 handling All 2.94E-05 1.13E-05 1.17E-08 

No Action Storage area fire INEEL 7.81E-05 3.01E-05 3.12E-08 

 PGDP 3.18E-07 1.22E-07 1.27E-10 

 PORTS 9.02E-04 3.47E-04 3.61E-07 

 SRS 1.78E-04 6.87E-05 7.14E-08 

 Oak Ridge 8.56E-05 3.30E-05 3.42E-08 

 Max other 1.06E-04 4.07E-05 4.23E-08 

Seismic (direct release) INEEL 4.70E-05 1.81E-05 1.88E-08 

 PGDP 1.17E-06 4.52E-07 4.70E-10 

 PORTS 3.06E-03 1.18E-03 1.22E-06 

 SRS 1.99E-04 7.67E-05 7.97E-08 

 Oak Ridge 9.40E-05 3.62E-05 3.76E-08 

 Max other 3.90E-04 1.50E-04 1.56E-07 

 Seismic (fire) INEEL 5.11E-06 1.97E-06 2.04E-09 

 PGDP 7.94E-08 3.06E-08 3.18E-11 

 PORTS 2.10E-04 8.08E-05 8.40E-08 

 SRS 1.72E-05 6.60E-06 6.86E-09 

 Oak Ridge 8.12E-06 3.13E-06 3.25E-09 

 Max other 2.65E-05 1.02E-05 1.06E-08 

Centralized storage at Storage area fire All 1.84E-03 7.10E-04 7.37E-07 

a single site Seismic (direct release) All 5.30E-03 2.04E-03 2.12E-06 

 Seismic (fire) All 3.70E-04 1.43E-04 1.48E-07 

Partially consolidated Storage area fire INEEL 1.80E-04 6.95E-05 7.22E-08 

storage at several PGDP 2.70E-05 1.04E-05 1.08E-08 

DOE sites PORTS 1.24E-03 4.78E-04 4.96E-07 

 SRS 1.83E-04 7.03E-05 7.30E-08 

 Oak Ridge 2.21E-04 8.50E-05 8.83E-08 

Seismic (direct release) INEEL 1.72E-04 6.61E-05 6.87E-08 

 PGDP 4.83E-05 1.86E-05 1.93E-08 

 PORTS 4.26E-03 1.64E-03 1.70E-06 

 SRS 2.15E-04 8.29E-05 8.62E-08 

 Oak Ridge 5.93E-04 2.28E-04 2.37E-07 

 Seismic (fire) INEEL 1.55E-05 5.99E-06 6.22E-09 

 PGDP 3.67E-06 1.41E-06 1.47E-09 

 PORTS 2.90E-04 1.12E-04 1.16E-07 

 SRS 1.82E-05 7.01E-06 7.28E-09 

 Oak Ridge 4.18E-05 1.61E-05 1.67E-08 

Partially consolidated Storage area fire East 1.67E-03 6.42E-04 6.67E-07 

storage at two sites West 1.86E-04 7.17E-05 7.45E-08 

Seismic (direct release) East 5.10E-03 1.96E-03 2.04E-06 

 West 1.93E-04 7.42E-05 7.71E-08 

 Seismic (fire) East 3.54E-04 1.36E-04 1.42E-07 

 West 1.70E-05 6.53E-06 6.78E-09 
01-217(doc)/093002 C-41

Table C.18. Chemical toxicity consequences to ecological receptors due to deposition of uranium on 

surface water under bounding accident scenarios (continued) 

Surface 

water 

HQ for 

ecological receptors 

Alternative Accident scenario Site 

concentration

(mg/L) 

Aquatic 

biota Herons 

Partially consolidated Storage area fire PORTS 7.99E-04 3.08E-04 3.20E-07 

storage based on SRS 4.51E-04 1.74E-04 1.80E-07 

physical form INEEL 5.49E-05 2.11E-05 2.20E-08 

Seismic (direct release) PORTS 4.97E-03 1.91E-03 1.99E-06 

 SRS 2.49E-04 9.60E-05 9.98E-08 

 INEEL 6.50E-05 2.50E-05 2.60E-08 

 Seismic (fire) PORTS 3.36E-04 1.29E-04 1.34E-07 

 SRS 2.81E-05 1.08E-05 1.12E-08 

 INEEL 5.49E-06 2.11E-06 2.20E-09 

Transfer to research Facility fire Generic 6.50E-06 2.50E-06 2.60E-09 

facility Seismic (direct release) Generic 2.10E-06 8.08E-07 8.40E-10 

 Seismic (fire) Generic 1.30E-06 5.01E-07 5.21E-10 

Transfer to other Facility fire Generic 3.25E-04 1.25E-04 1.30E-07 

government agencies Seismic (direct release) Generic 1.05E-04 4.03E-05 4.19E-08 

 Seismic (fire) Generic 6.50E-05 2.50E-05 2.60E-08 

Foreign sales Facility fire Generic 6.42E-04 2.47E-04 2.57E-07 

Seismic (direct release) Generic 2.26E-04 8.71E-05 9.05E-08 

 Seismic (fire) Generic 1.39E-04 5.34E-05 5.55E-08 

 2.04E-03 2.12E-06 

DOE = U.S. Department of Energy. 

HQ = hazard quotient. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 
01-217(doc)/093002 C-42

Table C.19. Radiological consequences to ecological receptors due to deposition of uranium on 

surface water under bounding accident scenarios 

Surface 

water HQ for ecological receptors 

Alternative Accident scenario Site 

activity

(pCi/L) 

Aquatic

biota 

Sediment 

invertebrates Herons 

All 

General container 

 handling All 2.06E-02 8.32E-08 2.43E-06 2.05E-09

No Action Storage area fire INEEL 5.47E-02 2.21E-07 6.45E-06 5.45E-09

 PGDP 2.22E-04 9.00E-10 2.62E-08 2.22E-11

 PORTS 6.31E-01 2.56E-06 7.45E-05 6.29E-08

 SRS 1.25E-01 5.06E-07 1.47E-05 1.25E-08

 Oak Ridge 5.99E-02 2.43E-07 7.07E-06 5.97E-09

 Max other 7.40E-02 3.00E-07 8.73E-06 7.37E-09

Seismic (direct release) INEEL 3.29E-02 1.33E-07 3.88E-06 3.28E-09

 PGDP 8.22E-04 3.33E-09 9.70E-08 8.20E-11

 PORTS 2.14E+00 8.68E-06 2.53E-04 2.14E-07

 SRS 1.39E-01 5.65E-07 1.65E-05 1.39E-08

 Oak Ridge 6.58E-02 2.66E-07 7.76E-06 6.56E-09

 Max other 2.73E-01 1.11E-06 3.22E-05 2.72E-08

 Seismic (fire) INEEL 3.58E-03 1.45E-08 4.22E-07 3.57E-10

 PGDP 5.56E-05 2.25E-10 6.56E-09 5.54E-12

 PORTS 1.47E-01 5.95E-07 1.73E-05 1.46E-08

 SRS 1.20E-02 4.86E-08 1.42E-06 1.20E-09

 Oak Ridge 5.69E-03 2.30E-08 6.71E-07 5.67E-10

 Max other 1.85E-02 7.50E-08 2.19E-06 1.85E-09

Centralized storage at Storage area fire All 1.29E+00 5.23E-06 1.52E-04 1.29E-07

a single site Seismic (direct release) All 3.71E+00 1.50E-05 4.38E-04 3.70E-07

 Seismic (fire) All 2.59E-01 1.05E-06 3.06E-05 2.59E-08

Partially consolidated Storage area fire INEEL 1.26E-01 5.12E-07 1.49E-05 1.26E-08

storage at several PGDP 1.89E-02 7.66E-08 2.23E-06 1.89E-09

DOE sites PORTS 8.69E-01 3.52E-06 1.03E-04 8.66E-08

 SRS 1.28E-01 5.17E-07 1.51E-05 1.27E-08

 Oak Ridge 1.55E-01 6.26E-07 1.82E-05 1.54E-08

Seismic (direct release) INEEL 1.20E-01 4.87E-07 1.42E-05 1.20E-08

 PGDP 3.38E-02 1.37E-07 3.99E-06 3.37E-09

 PORTS 2.98E+00 1.21E-05 3.52E-04 2.97E-07

 SRS 1.51E-01 6.11E-07 1.78E-05 1.50E-08

 Oak Ridge 4.15E-01 1.68E-06 4.90E-05 4.14E-08

 Seismic (fire) INEEL 1.09E-02 4.41E-08 1.28E-06 1.09E-09

 PGDP 2.57E-03 1.04E-08 3.03E-07 2.56E-10

 PORTS 2.03E-01 8.23E-07 2.40E-05 2.03E-08

 SRS 1.27E-02 5.16E-08 1.50E-06 1.27E-09

 Oak Ridge 2.93E-02 1.18E-07 3.45E-06 2.92E-09

Partially consolidated Storage area fire East 1.17E+00 4.72E-06 1.38E-04 1.16E-07

storage at two sites West 1.30E-01 5.28E-07 1.54E-05 1.30E-08

Seismic (direct release) East 3.57E+00 1.45E-05 4.21E-04 3.56E-07

 West 1.35E-01 5.46E-07 1.59E-05 1.35E-08

 Seismic (fire) East 2.48E-01 1.00E-06 2.92E-05 2.47E-08

 West 1.19E-02 4.81E-08 1.40E-06 1.18E-09
01-217(doc)/093002 C-43

Table C.19. Radiological consequences to ecological receptors due to deposition of uranium on 

surface water under bounding accident scenarios (continued) 

Surface 

water HQ for ecological receptors 

Alternative Accident scenario Site 

activity

(pCi/L) 

Aquatic

biota 

Sediment 

invertebrates Herons 

Partially consolidated Storage area fire PORTS 5.60E-01 2.27E-06 6.60E-05 5.58E-08

storage based on SRS 3.16E-01 1.28E-06 3.72E-05 3.15E-08

physical form INEEL 3.85E-02 1.56E-07 4.54E-06 3.83E-09

Seismic (direct release) PORTS 3.48E+00 1.41E-05 4.11E-04 3.47E-07

 SRS 1.75E-01 7.07E-07 2.06E-05 1.74E-08

 INEEL 4.55E-02 1.84E-07 5.37E-06 4.53E-09

 Seismic (fire) PORTS 2.35E-01 9.52E-07 2.77E-05 2.34E-08

 SRS 1.97E-02 7.97E-08 2.32E-06 1.96E-09

 INEEL 3.85E-03 1.56E-08 4.54E-07 3.83E-10

Transfer to research Facility fire Generic 4.55E-03 1.84E-08 5.37E-07 4.53E-10

facility Seismic (direct release) Generic 1.47E-03 5.95E-09 1.73E-07 1.46E-10

 Seismic (fire) Generic 9.11E-04 3.69E-09 1.07E-07 9.08E-11

Transfer to other Facility fire Generic 2.27E-01 9.21E-07 2.68E-05 2.27E-08

government agencies Seismic (direct release) Generic 7.33E-02 2.97E-07 8.65E-06 7.31E-09

 Seismic (fire) Generic 4.55E-02 1.84E-07 5.37E-06 4.53E-09

Foreign sales Facility fire Generic 4.50E-01 1.82E-06 5.31E-05 4.48E-08

Seismic (direct release) Generic 1.58E-01 6.42E-07 1.87E-05 1.58E-08

 Seismic (fire) Generic 9.71E-02 3.93E-07 1.15E-05 9.68E-09

 1.50E-05 4.38E-04 3.70E-07

DOE = U.S. Department of Energy. 

HQ = hazard quotient. 

INEEL = Idaho National Engineering and Environmental Laboratory. 

PGDP = Paducah Gaseous Diffusion Plant. 

PORTS = Portsmouth Gaseous Diffusion Plant. 

SRS = Savannah River Site. 
01-217(doc)/093002 C-44

 The highest risk from radiation exposure in soil (Table C.17) is an HQ of 3.1 × 10-6 for exposure of 

earthworms as a result of a direct seismic release under centralized storage at a single site. Because all other 

risks are below this level, there is no unacceptable risk from radiation exposure of terrestrial receptors. 

C.4.5.2 Surface water and sediment 

 Tables C.18 and C.19 show that no alternative resulted in unacceptable risks to aquatic biota, benthic 

invertebrates, and predators of aquatic biota and benthic invertebrates. The highest chemical risk was an HQ 

of 2.0 × 10-3 for exposure of aquatic biota as a result of a direct seismic release under centralized storage at a 

single site (Table C.18). Because all other risks are below this level, there is no unacceptable risk from 

chemical exposure of receptors of uranium deposited in surface water. 

 The highest risk of radiation exposure from uranium deposited in surface water is an HQ of 3.0 × 10-3 for 

exposure of great blue herons as a result of a direct seismic release under centralized storage at a single site 

(Table C.19). Because all other risks are below this level, there is no unacceptable risk from radiation 

exposure of receptors of uranium deposited in surface water. 

C.4.6 OVERALL RISK EVALUATION

 The overall risk from each alternative was evaluated by combining the predicted frequency of accidents 

with the consequences of those accidents as shown in Appendix A, Fig. A.1. The predicted frequency of each 

accident is shown in Appendix A, Table A.13. Ecological consequences were assigned categories as follows: 

HQ <0.1, negligible; HQ between 0.1 and 1, low; HQ between 1 and 10, moderate; and HQ greater than 10, 

high. Overall risks are shown in Tables C.20 (terrestrial receptors) and C.21 (receptors of uranium deposited 

in surface water). These tables show that overall risks under all alternatives are negligible. 

C.5 SUMMARY

 Airborne uranium released after potential accidents would be deposited downwind onto soil and surface 

water. Humans and ecological receptors would be exposed to the chemical toxicity of uranium and to the 

effects of radiation from contact, inhalation, and ingestion of contaminated soil, water, sediment, and food. 

This analysis calculates the concentrations of uranium in soil, surface water, and sediment that would result 

from each of the accident scenarios described in Appendix A. 

 Risks to EM workers, industrial workers, and residents who live on, and are surrounded by, 

contaminated soil were evaluated. Cancer risk, chronic radiation dose, and chronic chemical toxicity were 

assessed. Under all alternatives, all three types of consequences were negligible or low. 
01-217(doc)/093002 C-45 Table C.20. Summary of chronic risks to ecological receptors due to deposition of uranium on soil under bounding acc

Chemical exposure Rad

Alternative Accident scenario Site Frequency Maximum HQ Consequence level Risk Maximum HQ C

All General container handling All Anticipated 1.2E-03 Negligible Negligible 1.7E-08 No Action Storage area fire INEEL Extremely 3.0E-03 Negligible Negligible 4.5E-08 

PGDP unlikely 1.2E-05 Negligible Negligible 1.8E-10 

PORTS 3.5E-02 Negligible Negligible 5.2E-07 

SRS 6.9E-03 Negligible Negligible 1.0E-07 

Oak Ridge 3.3E-03 Negligible Negligible 5.0E-08 

Max other 4.1E-03 Negligible Negligible 6.1E-08 

Seismic (direct release) INEEL Extremely 1.8E-03 Negligible Negligible 2.7E-08 

PGDP unlikely 4.5E-05 Negligible Negligible 6.8E-10 

PORTS 1.2E-01 Low Low 1.8E-06 

SRS 7.7E-03 Negligible Negligible 1.2E-07 

Oak Ridge 3.6E-03 Negligible Negligible 5.5E-08 

Max other 1.5E-02 Negligible Negligible 2.3E-07 

Seismic (fire) INEEL Extremely 2.0E-04 Negligible Negligible 3.0E-09 

PGDP unlikely 3.1E-06 Negligible Negligible 4.6E-11 

 PORTS 8.1E-03 Negligible Negligible 1.2E-07  SRS 6.6E-04 Negligible Negligible 1.0E-08 

 Oak Ridge 3.1E-04 Negligible Negligible 4.7E-09  Max other 1.0E-03 Negligible Negligible 1.5E-08 

Centralized storage at a single site Storage area fire All 

Extremely

unlikely 7.1E-02 Negligible Negligible 1.1E-06 

Seismic (direct release) All 

Extremely

unlikely 2.0E-01 Low Low 3.1E-06 

Seismic (fire) All 

Extremely

unlikely 1.4E-02 Negligible Negligible 2.2E-07 

Partially consolidated Storage area fire INEEL Extremely 7.0E-03 Negligible Negligible 1.0E-07 storage at several PGDP unlikely 1.0E-03 Negligible Negligible 1.6E-08 

DOE sites PORTS 4.8E-02 Negligible Negligible 7.2E-07 

 SRS 7.1E-03 Negligible Negligible 1.1E-07 

Oak Ridge 8.5E-03 Negligible Negligible 1.3E-07 
01-217(doc)/093002 C-46 Table C.20. Summary of chronic risks to ecological receptors due to deposition of uranium on soil under bounding accident 

Chemical exposure Rad

Alternative Accident scenario Site Frequency Maximum HQ Consequence level Risk Maximum HQ C

Seismic (direct release) INEEL Extremely 6.6E-03 Negligible Negligible 1.0E-07 

PGDP unlikely 1.9E-03 Negligible Negligible 2.8E-08 

PORTS 1.6E-01 Low Low 2.5E-06 

SRS 8.3E-03 Negligible Negligible 1.3E-07 

Oak Ridge 2.3E-02 Negligible Negligible 3.4E-07 

Seismic (fire) INEEL Extremely 6.0E-04 Negligible Negligible 9.0E-09 

PGDP unlikely 1.4E-04 Negligible Negligible 2.1E-09 

PORTS 1.1E-02 Negligible Negligible 1.7E-07 

SRS 7.0E-04 Negligible Negligible 1.1E-08 

Oak Ridge 1.6E-03 Negligible Negligible 2.4E-08 

Partially consolidated Storage area fire East Extremely 6.4E-02 Negligible Negligible 9.7E-07 

storage at two sites West unlikely 7.2E-03 Negligible Negligible 1.1E-07 

Seismic (direct release) East Extremely 2.0E-01 Low Low 3.0E-06 

West unlikely 7.4E-03 Negligible Negligible 1.1E-07 

Seismic (fire) East Extremely 1.4E-02 Negligible Negligible 2.1E-07 

West unlikely 6.6E-04 Negligible Negligible 9.9E-09 

Partially consolidated Storage area fire PORTS Extremely 3.1E-02 Negligible Negligible 4.6E-07 

storage based on SRS unlikely 1.7E-02 Negligible Negligible 2.6E-07 

physical form INEEL 2.1E-03 Negligible Negligible 3.2E-08 

Seismic (direct release) PORTS Extremely 1.9E-01 Low Low 2.9E-06 

 SRS unlikely 9.6E-03 Negligible Negligible 1.5E-07 

 INEEL 2.5E-03 Negligible Negligible 3.8E-08 

 Seismic (fire) PORTS Extremely 1.3E-02 Negligible Negligible 2.0E-07 

 SRS unlikely 1.1E-03 Negligible Negligible 1.6E-08 

INEEL 2.1E-04 Negligible Negligible 3.2E-09 

Transfer to research Facility fire Generic Extremely 2.5E-04 Negligible Negligible 3.8E-09 

facility Seismic (direct release) Generic unlikely 8.1E-05 Negligible Negligible 1.2E-09 

Seismic (fire) Generic 5.0E-05 Negligible Negligible 7.6E-10 
01-217(doc)/093002 C-47 Table C.20. Summary of chronic risks to ecological receptors due to deposition of uranium on soil under bounding accident 

Chemical exposure Rad

Alternative Accident scenario Site Frequency Maximum HQ Consequence level Risk Maximum HQ C

Transfer to other Facility fire Generic Extremely 1.3E-02 Negligible Negligible 1.9E-07 government Agencies Seismic (direct release) Generic unlikely 4.0E-03 Negligible Negligible 6.1E-08 

Seismic (fire) Generic 2.5E-03 Negligible Negligible 3.8E-08 

Foreign sales Facility fire Generic Extremely 2.5E-02 Negligible Negligible 3.7E-07 

Seismic (direct release) Generic unlikely 8.7E-03 Negligible Negligible 1.3E-07 Seismic (fire) Generic 5.4E-03 Negligible Negligible 8.1E-08 

DOE = U.S. Department of Energy. PGDP = Paducah Gaseous Diffusion Plant. HQ = hazard quotient. PORTS = Portsmouth Gaseous Diffusion Plant. INEEL = Idaho National Engineering and Environmental Laboratory. SRS = Savannah River Site. 
01-217(doc)/093002 C-48 Table C.21. Summary of chronic risks to ecological receptors due to deposition of uranium on surface water under boundin

Chemical exposure Rad

Alternative Accident scenario Site Frequency Maximum HQ Consequence level Risk Maximum HQ C

All General container handling All Anticipated 1.1E-05 Negligible Negligible 2.4E-06 No Action Storage area fire INEEL Extremely 3.0E-05 Negligible Negligible 6.5E-06 

PGDP unlikely 1.2E-07 Negligible Negligible 2.6E-08 

PORTS 3.5E-04 Negligible Negligible 7.4E-05 SRS 6.9E-05 Negligible Negligible 1.5E-05 

Oak Ridge 3.3E-05 Negligible Negligible 7.1E-06 

Max other 4.1E-05 Negligible Negligible 8.7E-06 

Seismic (direct release) INEEL Extremely 1.8E-05 Negligible Negligible 3.9E-06 

PGDP unlikely 4.5E-07 Negligible Negligible 9.7E-08 

PORTS 1.2E-03 Negligible Negligible 2.5E-04 SRS 7.7E-05 Negligible Negligible 1.6E-05 

Oak Ridge 3.6E-05 Negligible Negligible 7.8E-06 

Max other 1.5E-04 Negligible Negligible 3.2E-05 

Seismic (fire) INEEL Extremely 2.0E-06 Negligible Negligible 4.2E-07 

PGDP unlikely 3.1E-08 Negligible Negligible 6.6E-09 

 PORTS 8.1E-05 Negligible Negligible 1.7E-05  SRS 6.6E-06 Negligible Negligible 1.4E-06 

 Oak Ridge 3.1E-06 Negligible Negligible 6.7E-07  Max other 1.0E-05 Negligible Negligible 2.2E-06 Centralized storage at a single site Storage area fire All 

Extremely

unlikely 7.1E-04 Negligible Negligible 1.5E-04 

Seismic (direct release) All 

Extremely

unlikely 2.0E-03 Negligible Negligible 4.4E-04 

Seismic (fire) All 

Extremely

unlikely 1.4E-04 Negligible Negligible 3.1E-05 

Partially consolidated Storage area fire INEEL Extremely 6.9E-05 Negligible Negligible 1.5E-05 storage at several PGDP unlikely 1.0E-05 Negligible Negligible 2.2E-06 

DOE sites PORTS 4.8E-04 Negligible Negligible 1.0E-04 

 SRS 7.0E-05 Negligible Negligible 1.5E-05 

Oak Ridge 8.5E-05 Negligible Negligible 1.8E-05 
01-217(doc)/093002 C-49 Table C.21. Summary of chronic risks to ecological receptors due to deposition of uranium on surface water under boundin

(continued) Chemical exposure Rad

Alternative Accident scenario Site Frequency Maximum HQ Consequence level Risk Maximum HQ C

Seismic (direct release) INEEL Extremely 6.6E-05 Negligible Negligible 1.4E-05 

PGDP unlikely 1.9E-05 Negligible Negligible 4.0E-06 

PORTS 1.6E-03 Negligible Negligible 3.5E-04 SRS 8.3E-05 Negligible Negligible 1.8E-05 

Oak Ridge 2.3E-04 Negligible Negligible 4.9E-05 

Seismic (fire) INEEL Extremely 6.0E-06 Negligible Negligible 1.3E-06 

PGDP unlikely 1.4E-06 Negligible Negligible 3.0E-07 

PORTS 1.1E-04 Negligible Negligible 2.4E-05 SRS 7.0E-06 Negligible Negligible 1.5E-06 

Oak Ridge 1.6E-05 Negligible Negligible 3.5E-06 

Partially consolidated Storage area fire East Extremely 6.4E-04 Negligible Negligible 1.4E-04 

storage at two sites West unlikely 7.2E-05 Negligible Negligible 1.5E-05 

Seismic (direct release) East Extremely 2.0E-03 Negligible Negligible 4.2E-04 

West unlikely 7.4E-05 Negligible Negligible 1.6E-05 

 Seismic (fire) East Extremely 1.4E-04 Negligible Negligible 2.9E-05 

West unlikely 6.5E-06 Negligible Negligible 1.4E-06 

Partially consolidated Storage area fire PORTS Extremely 3.1E-04 Negligible Negligible 6.6E-05 

storage based on SRS unlikely 1.7E-04 Negligible Negligible 3.7E-05 physical form INEEL 2.1E-05 Negligible Negligible 4.5E-06 

Seismic (direct release) PORTS Extremely 1.9E-03 Negligible Negligible 4.1E-04 

 SRS unlikely 9.6E-05 Negligible Negligible 2.1E-05 

 INEEL 2.5E-05 Negligible Negligible 5.4E-06 

 Seismic (fire) PORTS Extremely 1.3E-04 Negligible Negligible 2.8E-05  SRS unlikely 1.1E-05 Negligible Negligible 2.3E-06 

INEEL 2.1E-06 Negligible Negligible 4.5E-07 

Transfer to research Facility fire Generic Extremely 2.5E-06 Negligible Negligible 5.4E-07 

facility Seismic (direct release) Generic unlikely 8.1E-07 Negligible Negligible 1.7E-07 

Seismic (fire) Generic 5.0E-07 Negligible Negligible 1.1E-07 

Transfer to other Facility fire Generic Extremely 1.3E-04 Negligible Negligible 2.7E-05 

government agencies Seismic (direct release) Generic unlikely 4.0E-05 Negligible Negligible 8.7E-06 

Seismic (fire) Generic 2.5E-05 Negligible Negligible 5.4E-06 
01-217(doc)/093002 C-50 Table C.21. Summary of chronic risks to ecological receptors due to deposition of uranium on surface water under boundin

(continued) Chemical exposure Rad

Alternative Accident scenario Site Frequency Maximum HQ Consequence level Risk Maximum HQ C

Foreign sales Facility fire Generic Extremely 2.5E-04 Negligible Negligible 5.3E-05 

Seismic (direct release) Generic unlikely 8.7E-05 Negligible Negligible 1.9E-05 Seismic (fire) Generic 5.3E-05 Negligible Negligible 1.1E-05 

DOE = U.S. Department of Energy. HQ = hazard quotient. INEEL = Idaho National Engineering and Environmental Laboratory. PGDP = Paducah Gaseous Diffusion Plant. PORTS = Portsmouth Gaseous Diffusion Plant. SRS = Savannah River Site. 
01-217(doc)/093002 C-51

 Risks to terrestrial plants, soil invertebrates, and consumers of contaminated soil, plants, and 

invertebrates were evaluated. The indicator receptors for these groups were plants, earthworms, and 

short-tailed shrews and American robins, respectively. Chronic chemical toxicity and radiation dose were 

assessed. The consequences of chemical toxicity to plants were negligible or low; consequences of chemical 

toxicity to other receptors and of radiation dose to all receptors were negligible. 

 Risks to terrestrial aquatic biota, benthic invertebrates, and animal consumers of contaminated surface 

water, sediment, aquatic biota, and benthic invertebrates were evaluated. The indicator receptor animal was 

the great blue heron. Chronic chemical toxicity and radiation dose were assessed. Under all alternatives, all 

types of consequences were negligible for all receptors. 

 Consequence levels were combined with the expected frequency of occurrence of the associated 

accidents to determine the overall risk to ecological receptors from each alternative. Overall risks were 

negligible or low for all alternatives. 

C.6 REFERENCES

Baes, C. F., III, Sharp, R. D., Sjoren, A. L., and Shor, R. W. 1984. A Review and Analysis of Parameters for 

Assessing Transport of Environmentally Released Radionuclides through Agriculture, ORNL-5786, 

Oak Ridge National Laboratory, Oak Ridge, TN. 

Blaylock, B. G., Frank, M. L., and O’Neal, B. R. 1993. Methodology for Estimating Radiation Dose Rates to 

Freshwater Biota Exposed to Radionuclides in the Environment, ES/ER/TM-78, Oak Ridge National 

Laboratory, Oak Ridge, TN. 

DOE (U.S. Department of Energy). 1988. Health Physics Manual of Good Practices for Uranium Facilities, 

EGG-2530, U.S. Department of Energy, prepared by Idaho National Engineering and Environmental 

Laboratory, Idaho Falls, ID. 

DOE (U.S. Department of Energy). 1997. Report on the Remedial Investigation of Bear Creek Valley at the 

Oak Ridge Y-12 Plant, Oak Ridge, Tennessee, DOE/OR/01-1455/V6&D2, U.S. Department of Energy, 

Office of Environmental Management, Oak Ridge, TN. 

Efroymson, R. A., Will, M. E., Suter II, G. W., and Wooten, A. C. 1997. Toxicological Benchmarks for 

Screening Contaminants of Potential Concern for Effects on Terrestrial Plants: 1997 Revision,

ES/ER/TM-85/R3, Lockheed Martin Energy Systems, Oak Ridge National Laboratory, Oak Ridge, TN. 

Efroymson, R. A., Will, M. E., and Suter II, G. W. 1997, Toxicological Benchmarks for Screening 

Contaminants of Potential Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process: 

1997 Revision, ES/ER/TM-126/R2, Lockheed Martin Energy Systems, Oak Ridge National Laboratory, 

Oak Ridge, TN. 

EPA (U.S. Environmental Protection Agency). 1988. Limiting Values of Radionuclide Intake and Air 

Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion, Federal 

Guidance Report No. 11, EPA-520/1-88-020, U.S. Environmental Protection Agency, Washington, D.C. 

EPA (U.S. Environmental Protection Agency). 1989. Risk Assessment Guidance Part A. for Superfund 

Volume I: Human Health Evaluation Manual, EPA/540/1-89/002, U.S. Environmental Protection 

Agency, Office of Emergency and Remedial Response, Washington, D.C. 
01-217(doc)/093002 C-52

EPA (U.S. Environmental Protection Agency). 1993a. External Exposure to Radionuclides in Air, Water, and 

Soil, Federal Guidance Report No. 12, EPA-402-R-93-081, U.S. Environmental Protection Agency, 

Washington, D.C. 

EPA. (U.S. Environmental Protection Agency). 1993b. Wildlife Exposure Factors Handbook, Vol. I of II, 

EPA/600/R-93/187a U.S. Environmental Protection Agency, Office of Health and Environmental 

Assessment, Office of Research and Development, Washington, D.C. 

EPA. (U.S. Environmental Protection Agency). 1999. Screening Level Ecological Risk Assessment Protocol 

for Hazardous Waste Combustion Facilities (Peer Review Draft), EPA 530-D-99-001A, U.S. 

Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington, D.C. 

Hanna, S. R., Briggs, G. A., and Hosker Jr., R. P. 1982. Handbook on Atmospheric Diffusion, DOE/TIC11223, U.S. Department of Energy , Office of Health and Environmental Research, Office of Energy 

Research, Washington, D.C. 

IAEA (International Atomic Energy Agency). 1992. Effects of Ionizing Radiation on Plants and Animals at Levels 

Implied by Current Radiation Protection Standards, IAEA Technical Report Series 332, Vienna, Austria. 

Jones, D. S., Suter II, G. W., and Hull, R. N. 1997. Toxicological Benchmarks for Screening Contaminants of 

Potential Concern for Effects on Sediment-Associated Biota: 1997 Revision, ES/ER/TM-95/R4, 

Lockheed Martin Energy Systems, Oak Ridge National Laboratory, Oak Ridge, TN. 

NRC (Nuclear Regulatory Commission). 1992. Residual Radioactive Contamination from Decommissioning,

NUREG/CR-5512. U.S. Nuclear Regulatory Commission, Washington, D.C. 

Pasquill, F. 1974. Atmospheric Diffusion, John Wiley, New York. 

Sample, B. E., Opresko, D. M., and Suter II, G.W. 1996. Toxicological Benchmarks for Wildlife: 1996 Revision,

ES/ER/TM-86/R3, Lockheed Martin Energy Systems, Oak Ridge National Laboratory, Oak Ridge, TN. 

Sample, B. E., Aplin, M. S., Efroymson, R. A., Suter II, G. W., and Welsh, C. J. E. 1997. Methods and Tools 

for Estimation of the Exposure of Terrestrial Wildlife to Contaminants, ORNL/TM-13391, Oak Ridge 

National Laboratory, Environmental Sciences Division, Oak Ridge, TN. 

Suter, G. W. II, and Tsao, C. L. 1996. Toxicological Benchmarks for Screening Potential Contaminants of 

Concern for Effects on Aquatic Biota: 1996 Revision, ES/ER/TM-96/R2, Lockheed Martin Energy 

Systems, Oak Ridge National Laboratory, Oak Ridge, TN. 
01-217(doc)/093002

APPENDIX D 

COMMENTS AND 

RESPONSE TO COMMENTS 
01-217(doc)/093002
01-217(doc)/093002 D-iii 

TABLE OF CONTENTS 

APPENDIX D.1. COMMENTS RECEIVED...........................................................................................D-1

APPENDIX D.2 COMMENTS AND RESPONSES..............................................................................D-51
01-217(doc)/093002 D-iv 
01-217(doc)/093002 D-1 

APPENDIX D.1. COMMENTS RECEIVED 

DRAFT URANIUM MANAGEMENT PROGAMMATIC 

ENVIRONMENTAL ASSESSMENT 
01-217(doc)/093002 D-2 












































PIKE COUNTY

CHAMBER OF COMMERCE

P,O. BOX 107 l 12455 STATE ROUTE la?

WAVERLY, OHIO 45690

740-947-7715 l FAX 740-947-7716

June I 1,2002

Mr. David Allen

US Department of Energy

SE-30- 1

P-0. Box 2001

Oak Ridge, TN 3783 I

Dear Mr. Allen,

I am submitting writtcm comments to the Department of Energy on the proposed use of

the Portsmouth Gaseous Diffusion Plant at Piketon as a storage facility for umnium that may or

may not have a marketable value.

There are two issues here. First, any movement of uranium from other sites to Piketon

holds the obvious potential that the material will remain at Piketon. We in Pike County have

become increasingly concerned, as production has ceased at Piketon, that the government will not

expend the necessary finds to clean the site. An even more fundamental concern is, ifmoney

were available whether or not the Department of Energy has the technological expertise to

dispose of the nuclear waste produced in the last halfcentury. Moving more material into Pike

County wouId increase the pos&iJity that the Piketon plant’s ultimate fate would be a dump site.

That leads into the second issue. The people of Pike County will not willingty agree to

receive any material at Piketon without an iron-clad agreement with DOE that the uranium wiiI

either be marketed or removed in a timely manner.

That brings an even more fiu&rnental question? What is an iron-clad guarantee? Over

the past five years, Pike Countians have experienced the following:

1. Privatization. The Gaseous Dition plant at Piketon could handle all phases of

enrichment; a sister plant in Kentucky could not. Piketon ceases operation.

2. After discarding lazer isotope technology, the Department of Energy seems committed

to a centrifkge process. The Piketon facility may get the new centrifuge process. In 1985,

Pilceton was ready to go online with centrifuge when the govemment pulled the plug.

3. Congressman Strickland, Congressman Portman and Governor TafI have expended

endless time and influence on the Piketon plant. Congress passed a law providing for the

construction of two DUF6 conversion facilities, and appropriated monies for a conversion plant at

Piketon and P&U&. Thcrc have been mmors of one plant, no plant, not much talk of two

pkints. One thing is certain; No construction contracts have been let for Piketon.

Lx39
Page 2

4. The Department of Energy assigns a site management team to Piketon. The team has

rcpcatedly shown its &&cation to the site and the community. It is the local site team the catches

most of the flak from frustrated Pike Countians. The actual decision makers are burrowed deep in

murky bureaucracies in Oak Ridge and Washington th;it m&t% it imposstble for the average

citizen in Pike County to reach them.

5. For the past four years, the Southern Ohio Diversification Initiative has been

negotiating with DOE to obtain land not king utiI&d by DOE or USEC. In particular, 3 340 -

acre parcel was proposed as the site of a $I biGon coal-fired electric generating plant. The land

was not transferred to SOD1 in a timely manner, and the project, with a loss ofjobs and tax

money to Pike County, is now dead. In fact the only land returned to SOD1 f&n the 3900- acre

government reservation is a two-acre site for a cemetery in Scioto Township.

It is very difficult for the people of Pike County to accept mere rcassur~s from the

Department of Energy about the ultimate fate of the material currentiy being proposed to be

brought to Piketon. The simplest way to handle the situation to the satisfaction of every Pike

Countian is to choose one of the other sites in consideration. Perhaps DOE’s credibility is better

in those locations:.

Sincerely,

Elaine Reekman

Executive Director

cc: P-0. Box 700

Piketon, Of I

D-50
APPENDIX D.2 COMMENTS AND RESPONSES 

DRAFT URANIUM MANAGEMENT PROGAMMATIC 

ENVIRONMENTAL ASSESSMENT 

01-217(doc)/082602 D-49 
01-217(doc)/082602 D-50 
APPENDIX D.2. COMMENTS AND RESPONSES 

Response to Comments on the Programmatic Environmental Assessment 

for the U.S. Department of Energy, Oak Ridge Operations 

Implementation of a Comprehensive Management Program for the Storage, 

 Transportation, and Disposition of Potentially Re-usable Uranium Materials 

(DOE/EA-1393) 

Gregory L. Simonton 

Executive Director 

Southern Ohio Diversification Initiative 

1. Please identify any other potentially reusable uranium material/uranium feed currently located at 

PORTS. 

Response: Materials deposited throughout the cold standby and shutdown cells are a source of 

future potentially reusable uranium. 

2. What buildings would be used at PORTS for this project? 

Response: Due to security concerns, specific building locations cannot be identified in the PEA. 

However, should an alternative involving the PORTS site be selected, the UMG Program commits 

not to exceed the storage capacity of the existing UMG storage facility. This commitment to limit 

material within the confines of the existing UMG facility will further ensure that the disposition of 

material remains a priority. As uranium in the inventory is dispositioned, additional uranium materials 

in the UMG inventory at other DOE sites could then be stored at PORTS on an interim basis. However, 

should an alternative involving the PORTS site be selected, the UMG Program commits not to 

exceed the storage capacity of the existing UMG storage facility. This commitment to limit material 

within the confines of the existing UMG facility will further ensure that the disposition of material 

remains a priority. As uranium in the inventory is dispositioned, additional uranium materials in 

the UMG inventory at other DOE sites could then be stored at PORTS on an interim basis. 

3. What building(s) are included in the 450,000 square feet of available building space cited in the Draft 

Environmental Assessment (DOE/EA 1393)? 

Response: See response to comment #2. 

4. What other facilities would be required to support the DOE preferred option to consolidate all of the 

material at PORTS? 

Response: The PEA identifies the need for approximately 168,000 ft2

 of additional storage space. 

Assuming additional space is required, then with the exception of temporary use of roads and the 

equipment needed to offload and store the uranium materials, no other facility use is anticipated. 

However, in consideration of comments received, the UMG Program does not plan to use additional 

buildings at PORTS. DOE anticipates storage at PORTS will be limited to the current UMG 

storage facility. 

5. Why is the material considered “valuable” and “reusable”? 

Response: These materials have a market value and have potential reuse in various government 

and commercial applications. There is an expressed interest by third parties to acquire some of 

01-217(doc)/082202 D-51 
these materials in the near future. It is anticipated that other potential users of these materials will 

be found. Reusing this material helps protect the environment since recycling avoids having to bury 

the material in the earth. Its potential use as in down-blending with highly enriched uranium 

promotes nonproliferation goals.

6. If more potentially reusable material is shipped to PORTS, please identify the impacts/restrictions on 

other buildings and facilities at the site (in the context of production reuse). 

Response: Should an alternative involving the PORTS site be selected, the UMG Program commits 

not to exceed the storage capacity of the existing UMG facility. As uranium in the inventory is 

dispositioned, additional uranium materials in the UMG inventory at other DOE sites could then be 

stored at PORTS on an interim basis. Thus, there should be no impacts or restrictions on the other 

buildings and facilities. 

7. Please identify the method of shipment, mode of transportation, and route(s). 

Response: Routing was calculated using the Transportation Routing Analysis Information System 

(TRAGIS) with two modes being considered—all shipment by truck and shipment by rail where 

appropriate with all other shipment by truck (termed the “truck/rail option”). See Appendix B for 

more details regarding routing assumptions and calculations. 

8. What guarantees will the local community receive regarding the ultimate disposition date? 

Response: DOE will attempt to disposition the uranium materials as quickly as reasonably possible 

and is committed to making periodic reassessments of materials in storage. 

9. Please provide the proposed schedule of re-classification to ensure the material is reusable, 

marketable, and not deemed a waste. 

Response: The UMG Program is proposing a review and documentation of material assessment not 

to exceed 5 years. 

10. What happens to the material if it is subsequently determined to be a waste? 

Response: It will be handled and disposed as a waste. 

11. Please identify the markets for this material. 

Response: The potential markets are discussed in Section 2.3.8. They include commercial 

processing and domestic sales to commercial nuclear vendors for the manufacture of nuclear fuel 

for commercial nuclear power plants, maintenance of a strategic reserve, down-blending of HEU in 

conjunction with arms reductions treaties (with the resulting LEU available for use in commercial 

nuclear power plants), use by research facilities, other government agencies and foreign sales. 

12. When did the DOE preferred option first receive consideration? 

Response: During the internal DOE scoping process for this proposed action several alternatives 

were formulated including an alternative for Interim Consolidated storage at a Single DOE site. 

Recent successful DOE experience at PORTS in storing the Fernald and Hanford uranium 

materials suggested that PORTS would be the preferred site under this alternative. 

01-217(doc)/082202 D-52 
13. How would the importation of the material affect current clean up project? Future D&D activities? 

Response: No impact to cleanup or D&D activities is anticipated. 

14. How many permanent jobs are associated with this project? Newly created full-time permanent 

positions with the DOE preferred option? 

Response: The number of permanent workers (and initial construction workers) is shown for each 

site under each alternative in Chapter 4. See specifically Tables 4.3, 4.6, 4.9, 4.13, 4.16 and 4.19. For 

the Interim Storage at a Single DOE Site, the analysis performed in the PEA assumes an additional 

168,000 ft2 of space would need to be upgraded. As shown in Table 4.3, this results in 9 new 

permanent workers at PORTS (and 210 temporary construction workers). This assumes upgrades 

of buildings to increase effective storage space. However, as noted in response to comment #4, the 

UMG Program has decided to limit storage to the existing UMG storage facility. Therefore, 

permanent workers shown in the table would be significantly less. 

15. Please identify the community benefits associated with the importation of this material to PORTS. 

Response: This proposed action would continue to use the uranium-experienced and trained work 

force at PORTS. PORTS, with the uranium conversion plant and UMG activities, would be 

considered a multipurpose site versus a closure or DoD site. 

16. Will the full proceeds, including applicable taxes, of the sale of this material be returned to the 

community? 

Response: Proceeds will be used to cover costs incurred by the sale of the material, salaries, 

handling, and shipping at the PORTS site. Surplus would be returned to the U.S. Treasury as 

required by law. 

17. Will the DOE utilize the designated CRO for disposal/sale of this material? 

Response: Current plans are for the UMG to sale/disposition this material. 

18. Define temporary storage. 

Response: As stated in Section 2.3, DOE proposes to implement a long-term (greater than 20 years) 

management plan for its inventory of potentially re-usable LEU, NU and DU. Six interim storage 

alternatives are considered. Each of these alternatives also has associated with them the disposition 

of these uranium materials. Thus, the action will cover a greater than 20-year period. Further, this 

PEA does not provide for permanent storage at Portsmouth. 

19. Assuming there is a market for this material, is there a prohibition or moratorium that would prevent 

or affect its sale? 

Response: Under the disposition options discussed in Section 2.3.8, commercial process/domestic 

sales, transfer to research facilities and transfer to other government agencies can proceed in 

compliance with existing laws and regulations governing such sales or transfers. Before these 

materials can be sold, a Secretarial Determination is required to evaluate the potential for adverse 

impact on the market. 

01-217(doc)/082202 D-53 
20. Does USEC have any need for any of this material? 

Response: No. USEC uses UF6 for their Paducah enrichment operations, which is not in the scope of 

the PEA. 

21. Has the DOE considered transferring ownership of any of the material to USEC? 

Response: USEC cannot use this material in its current form. USEC uses UF6, which is not in the 

scope of this PEA. 

22. Will additional security be needed at PORTS if any of the material is imported? 

Response: DOE will review the security needs at PORTS should a decision be made to move these 

materials there. DOE is committed to ensuring appropriate security forces are maintained. 

23. Has DOE consulted with and sought the input of the Ohio Congressional Delegation regarding the 

importation of nuclear material to PORTS? If so, what was the outcome? 

Response: DOE has hosted several public meetings with attendance from members of the Ohio 

delegation. The delegation accepted the program and holds DOE accountable for maintaining 

interim storage in DOT-certified containers; not storing waste; and not receiving funding as part of 

the Portsmouth cleanup plan. DOE is obligated to honor the commitments for the UMG Program 

in the same manner as has been maintained for the Hanford, Fernald, and university materials 

received to date. 

24. Of the 158 sites currently storing the material, is there any more “reusable” or “potentially 

marketable” material being generated? If yes, will it automatically be transferred to the storage site 

chosen during this action? 

Response: The 14,200 MTU of uranium inventory is all this is addressed in this PEA. No other 

materials are being considered for consolidation. 

25. Has any of this material ever been classified as a waste? 

Response: No. All material is carefully screened prior to acceptance. 

26. Please identify all of the sites currently storing this material and provide a brief description of the 

material at those sites. 

Response: Table 2.1 provides the uranium management inventory (amount in MTU) at the various 

sites. Table A.3 gives some indication of types of uranium at some of the larger DOE sites. However, 

for security reasons the exact amount by type is not shown for all sites. 

27. Please explain the relationship (on page 3-2/Environmental Justice Section) between race, income and 

the decisions to store this material at any location. 

Response: DOE is required to determine if low-income or minority populations would be adversely 

and disproportionately affected by the proposed action. If this is the case then DOE must take this 

into consideration when making a final decision. There were no adverse environmental effects 

which would disproportionately affect low-income or minority populations for any of the 

alternatives considered. 

01-217(doc)/082202 D-54 
28. Please provide brief details on the nature of retrofitting/upgrade required at PORTS for the DOE 

preferred alternative. 

Response: The Uranium PEA analysis assumes 168,000 ft2

 of building upgrades. This would result 

in the receiving capability for loading/unloading needing to be improved. However, DOE is 

committed to using only the UMG storage facility. Some additional modification to the current 

storage facility may be required as well as continued upgrades for the UMG facility. 

29. Who will be used to complete retrofitting required at PORTS? 

Response: Prior to the start of retrofitting existing facilities or new construction (should that be 

required), a labor determination will be made to identify the work force that will be required to 

perform the work. This determination will take into consideration the type and extent of work to be 

performed. 

30. Who regulates the safe storage of the material at PORTS? 

Response: The program to ensure the safe storage of the uranium material at PORTS is 

administered by U.S.DOE. 

31. On behalf of the southern Ohio region, and before any decision on this matter is made, we 

respectfully request a meeting with the Secretary of Energy or his designee with authority to make 

decisions regarding this issue. 

Response: Comment noted. 

32. We believe this proposed action is contrary to our efforts, the stated DOE mission to reindustrialize, 

and the tireless efforts of our elected representatives in Columbus and Washington for productive, job 

intensive reuse of the PORTS facility in Piketon. Therefore, the SODI Board of Directors opposes the 

subject material being stored at the Piketon site. The residents of Southern Ohio desire projects that 

have recognizable value and benefit for the community. We want input into our future, the goals for 

the site, and new missions. 

Response: Comment noted. 

Graham E. Mitchell 

Chief 

Office of Federal Facilities Oversight 

State of Ohio Environmental Protection Agency 

33. During the meeting on June 4, it was noted that funding just became available to help with proper 

disposition of the uranium material currently stored at the Portsmouth facility and that additional 

funding would be needed to continue to find a new use for this material. Please state how US DOE 

intends to continue funding this program so that material will not be stored in perpetuity but rather 

shipped to other entities for re-use. US DOE must make funding this program a priority within each 

budget in order to continue disposition of the uranium material. Without proper funding, the 

necessary research to determine potential uses for this material cannot be accomplished. The cost for 

management and research for re-use of this material should not come from the budget for the clean up 

and remediation of the Portsmouth facility. 

01-217(doc)/082202 D-55 
Response: Funding for specific activities associated with disposition of material will continue to be 

requested as part of the annual budget process. Requests for this funding continue to be separate 

from funding requests for cleanup and remediation of the Portsmouth facility. 

34. Portions of the revenues generated from the Uranium Management Group should be maintained in 

Portsmouth to off set the cost of storing the material as well as cleanup activities. 

Response: Comment noted. See response to comment #16. 

35. Ohio EPA understands US DOE’s goal to consolidate uranium materials to reduce costs and promote 

more efficient management of these materials. However, to really develop credibility, US DOE is 

going to have to prove that this material does have economic value and other companies or 

government agencies are interested in it. Uranium materials need to be leaving the site rather than just 

arriving for storage. US DOE should establish goals and commitments to stakeholders to remove a 

certain percentage of material per year. These commitments could be in the form of a letter of intent 

or other type of agreement with the State of Ohio. 

Response: Comment noted. The UMG is developing a disposition plan to move the material from 

the site. 

36. The draft EA noted that US DOE considers 20 years or greater to be interim storage. At what point 

within the 20 years will US DOE determine that this material is no longer of value and deem that it 

should no longer be stored but treated as a waste? What plan(s) does US DOE have to evaluate this 

material over the next 20 years to determine if it is of value? Because of past problems with 

storage of materials that later became waste, US DOE must make a commitment in the EA to 

establish a process where the inventory is reevaluated on a regular basis (3-5 years) to ensure that it 

still has economic value. Please refer to the comment above in regard to establishing an agreement 

with the State of Ohio to continually evaluate the material and remove a percentage of this material 

from the site each year. US DOE cannot continually accept material at the Portsmouth facility 

without establishing that the material is of economic value. 

Response: The UMG is developing a disposition plan to move the material off the site. A process to 

re-evaluate the material in order to make sure it is not waste will be incorporated into the 

disposition plan. 

37. US DOE mentions that disposition is a major function of this uranium management effort. US DOE 

must also include disposition as waste as an additional component of this effort. Over time, as US 

DOE reevaluates this material, some of it may no longer have economic value and US DOE should be 

able to disposition it as waste under this EA. US DOE must ensure that funding is available to remove 

the material that is no longer of economic value as a waste. 

Response: Text has been added to Sections 1.2, 2.3, and 4.10 to address potential waste streams. If 

material is declared waste, additional funding would be requested from the appropriate 

DOE Program. 

38. The material currently at Portsmouth was moved there in order for US DOE to meet its regulatory 

requirements at several other sites. US DOE-Portsmouth has a regulatory requirement to address 

contamination at the site per the requirements of the Ohio Consent Decree. Currently, the material 

stored on site is in a building, which sits upon and is adjacent to a groundwater plume, which is to be 

addressed during the next fiscal year. The storage of the uranium material may interfere with the overall 

01-217(doc)/082202 D-56 
site clean up. Please state how US DOE will ensure that storage of the additional material will not 

interfere with the requirements of the Ohio Consent Decree to clean-up the site. US DOE 

should conduct environmental characterization of buildings to be upgraded to meet the potential storage 

needs for incoming material. This effort could avoid future disruption of uranium management efforts. 

Response: As noted in responses to comments #2 and #6, the UMG Program is committing not to 

exceed the storage capacity of the existing UMG facility. Thus, no conflicts with the Ohio Consent 

Decree are anticipated. No activities that conflict with planned or ongoing remediation are 

anticipated. 

39. Please state how storage of this material will not interfere with the other potential missions at the 

US DOE-Portsmouth site? For example, if Portsmouth were to become a D&D site, would it still be 

a good location for this facility? How does the storage of this material fit in with the current mission 

of Portsmouth to clean-up the current contamination at the site and potential re-use of the site for 

future industrial purposes? 

Response: PORTS is an active DOE site with a uranium mission. It is not anticipated that interim 

warehousing of these uranium materials would adversely affect DOE’s ability to conduct its other 

mission requirements at the site nor would this action interfere with ongoing cleanup efforts. 

40. US DOE should evaluate the long-term storage of the uranium material at a facility such as the 

Nevada Test Site. The material could be easily obtained if it is determined to be of economic value 

and should US DOE determine that it is a waste the material may not have to be moved again for final 

disposition. Storing the uranium material in this manner may save the US DOE valuable economic 

resources. 

Response: The Nevada Test Site (NTS) handles some forms of nuclear waste for the Department. 

The uranium materials evaluated in this PEA are not wastes and would not be appropriate to be 

stored at the NTS. 

41. Please state if the material will be tested for evaluation of RCRA characteristics including TCLP prior 

to shipping and storing the material to ensure that it meets regulatory requirements? Prior to shipping 

US DOE should make this evaluation to avoid potential regulatory issues at the site. As you are aware 

this site is not permitted to accept any hazardous waste from other facilities, to do so would be a 

violation of the permit. 

Response: Uranium materials are evaluated prior to acceptance by the UMG for shipment. UMG 

does not accept any materials that are determined to be waste. Therefore, the RCRA/TCLP testing 

would be unnecessary. 

42. If additional buildings/space will be needed for this effort, US DOE should coordinate with SODI in 

an effort to make the best future use of buildings. 

Response: Should an alternative be selected involving the PORTS site, the UMG Program commits 

to using the existing UMG storage facility. 

43. US DOE should evaluate who the likely users of the material may be prior to shipment to Portsmouth. 

US DOE should avoid shipment of material over long distances for storage only to have the material 

re-locate to a user near its origin (e.g. shipping the material from the Hanford Facility to Portsmouth 

then back to a western user). Conducting this type of evaluation up front will save US DOE economic 

01-217(doc)/082202 D-57 
resources as well as avoid potential risks associated with transportation of this material over long 

distances. 

Response: Comment noted. 

Larry Scaggs 

Seal Township 

Pike County Ohio Trustees 

44. I am writing on behalf of the Seal Township, Pike County, Ohio, Trustees to oppose the DOE 

bringing in wastes from other sites to store at Piketon. The Piketon Gaseous Diffusion Plant is 

partially located in Seal Township. I am also a Board Member of the Southern Ohio Diversification 

Initiative. 

Response: The UMG has no intent to accept waste materials. 

45. DOE has called this waste a valuable material, but cannot explain how or why it is valuable. 

Furthermore, by bringing this waste to Piketon, 157 other sites will be cleaned up. We want to know 

why 157 other communities are more important than Piketon. 

Response: See response to comment #5. Since the uranium materials at all 158 sites listed in 

Table 2.1 are product and not a waste, the other 157 sites are not being “cleaned up.” DOE is 

attempting to consolidate the materials to increase efficiency and reduce costs. 

46. I do support projects that accelerate the cleanup of the Piketon site and provide a safe environment for 

our residents. The DOE should build and operate the DUF6 plant and accelerate cleanup of the lands 

and buildings, such as the 340 acres SODI tried to get for economic development. These project 

benefit the community be creating jobs and cleaning up our environment. Storing waste here for 20 

years does not. 

Response: Comment noted. 

Teddy L. West 

Scioto Township Trustee 

47. I am a Scioto Township Trustee elected by the residents surrounding the Piketon gaseous diffusion 

plant, a member of the Southern Ohio Diversification Initiative Board of Directors, and owner of 

property adjoining the Piketon gaseous diffusion plant. I am opposed to the storage of uranium waste 

that is described as “reusable material” in the draft programmatic environmental assessment 

DOE/EA-1393. As a neighbor of the plant and representative of the people surrounding the plant, I do 

not want our community to become DOE’s dumping ground. How can you tell our community that 

the waste is valuable material, yet you can tell the other communities that the material is a waste and 

they are now cleaned up? As a SODI Board member and Scioto Township Trustee, I support projects 

that will benefit our community by providing jobs and a safe environment for our people. We want 

DOE to accelerate cleanup, building the DUF6 plant, transfer land to SODI, and bring new 

enrichment technology to Piketon. 

Response: Comment noted. The uranium materials evaluated in this EA are potentially re-usable 

and, thus, valuable materials. They are not wastes. 

01-217(doc)/082202 D-58 
Gilbert D. Drexel 

Manager of Projects 

Portsmouth Site Office 

48. Sec. 1.1 (“Purpose and Need for Agency Action”, pg. 1-1). We suggest that the paragraph be revised 

by adding a new sentence (shown in italics), so that the paragraph reads as follows: 

“The U.S. Department of Energy (DOE) proposes to implement a comprehensive management 

program to safely, efficiently, and effectively manage its potentially reusable low enriched uranium 

(LEU), normal uranium (NU) and depleted uranium (DU). Uranium materials which are presently 

located at multiple sites are to be consolidated by transporting the materials to one or several storage 

locations, to facilitate ultimate disposition. Management would include the storage, transport, and 

ultimate disposition of these materials.” 

Response: Text added as recommended. 

49. Sec. 2.2 (“No Action Alternative”, pg. 2-9). In the last sentence in the paragraph, suggest changing 

“disposed” to “dispositioned”. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

50. Sec. 2.3 (“Proposed Action”, pg. 2-9). In the first paragraph, we suggest that the 1st sentence be 

revised to create two sentences, to read, “DOE proposes to implement a long-term (greater than 20 

years) management plan for its inventory of potentially reusable LEU, NU, and DU. Uranium 

materials which are presently located at multiple sites are to be consolidated by transporting the 

materials to one or several storage locations, to facilitate ultimate disposition. 

Response: Text changed as suggested. 

51. Sec. 2.3 (“Proposed Action”, pg. 2-9). In the third paragraph, suggest revising the first sentence to 

read, “DOE must determine the safest, most effective, and most efficient approach for the 

consolidation and storage of this material.” 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

52. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The 1st paragraph currently reads as follows: 

“Normal operations result in no more than negligible acute or chronic consequences and risk at any 

site under any storage alternative or disposition option. Environmental impacts associated with 

normal operations vary substantially from alternative to alternative and, occasionally, by site within a 

given alternative. General handling accidents result in no more than negligible acute or chronic 

consequences and risk at any site under any storage alternative or disposition option. Chronic human 

health and ecological consequences and risk are negligible to low for all sites under all alternatives. 

The highest transportation consequences are for alternatives that involve moving uranium materials to 

a western location, either to a commercial site or to INEEL.” 

We suggest that this summary paragraph be reworded to more broadly discuss the PEA’s 

conclusions. The conclusion/summary as we see the overall PEA analysis is that there were noneto-minor impacts for all of the alternatives from the standpoint of environmental impact; negligible01-217(doc)/082202 D-59 
to-low impacts from the standpoint of facility accidents (fire and seismic) for all the alternatives; 

while transportation effects for the alternatives generally reflected the extent of material 

transport associated with the alternative being analyzed. The overall conclusion is that potential 

impacts appear not be significant for any of the material consolidation alternatives which were 

analyzed. 

Response: Text in the Summary and Conclusions in the PEA has been modified. Should DOE 

determine that a Finding of No Significant Impact (FONSI) is warranted, the FONSI will be where 

“significance” of impacts will be discussed. 

53. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. We also suggest that discussion be added to the 

paragraph to summarize the reasons for proposing the PORTS option, given that at least one other 

option (i.e., the partial consolidated storage at several DOE sites) is forecast to have a less 

expensive construction cost. The reasons for proposing the PORTS option, are that a single 

consolidated storage location affords greater flexibility and ease of future disposition of the 

material, and reduces the overall expected future cost for facility surveillance & maintenance 

(S&M) and material accountability/material S&M, than if the material was at several locations. 

These benefits outweigh the potentially greater up-front renovation/construction costs. 

Response: Comment noted. The focus of the PEA is to address the potential environmental 

impacts associated with each of the alternatives considered. The PORTS site due to the existence 

of sufficient storage space to accommodate the entire uranium inventory under consideration has 

the least environmental impacts of a single consolidated storage site. DOE can consider factors in 

addition to environmental impacts when making an agency decision. In addition to those noted in 

the comment, PORTS has a work force trained in handling uranium materials and a very recent, 

successful experience in storing uranium materials from the Fernald and Hanford sites. 

54. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. Consideration should be given to adding an overall 

summary table (example attached). 

Response: Comment noted. 

55. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The statement that “environmental impacts ...vary 

substantially from alternative to alternative” appears inconsistent with the analysis, which indicated 

that for all the alternatives, the environmental impacts were negligible, minimal, or at most minor. 

“Vary substantially” seems to imply that there are significant impacts, when the analysis says there 

were none or minimal. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

56. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The statement that “General handling accidents 

result in no more than negligible acute or chronic consequences... appears correct, based on the 

analysis. However, “general handling” is part of “normal operations” – which from the 1st sentence 

have no impacts. It is unclear as to why the extra emphasis is being given to the impacts from 

“Normal operations”. 

Response: The PEA addresses both accident conditions and normal operations (meaning those 

situations and activities in which accidents are not occurring). 

01-217(doc)/082202 D-60 
57. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The paragraph omits discussion of the negligibleto-low risk associated with facility accidents (fire and seismic). 

Response: Text added to Section 4.11.1. 

58. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. The 3rd paragraph currently reads as 

follows: 

“In addition to surface contamination, radiation dose from the stored uranium materials can be 

expected. Dose rates from any single stored container are no more than 3 to 4 mrem/h. The dose rate 

at a distance of 0.3 m (ft.) from a container is about 1 mrem/h, and the dose rate at a distance of 6 m 

(20 ft.) is < 0.5 mrem/hr (approximately the same as normal background radiation doses). These dose 

rates are not affected by stacking the containers, because the containers and the materials themselves 

provide substantial shielding. These dose rates are considered negligible to any receptor (facility 

worker, co-located worker, or public).” 

Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. Suggest specifying whether the “3 to 

4 mrem/h” dose rate is “on contact”. Also, we suggest to citing the basis for indicating the dose is 3 – 

4 mrem/h maximum. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

59. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. Based on calculations, a dose at 6 m 

(20 ft.) would be < 0.05 mrem/hr. Suggest using “<0.05 mrem/hr” – rather than “<0.5 mrem/hr.” 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

60. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. It is unclear as to what the 

information in the parenthesis – “(approximately the same as normal background radiation doses)” 

refers to. If what is being referred to is 0.5 mrem/hr, this would not seem to be “approximately 

background”, as 0.5 mrem/hr at 2000 hrs/year would result in 1 rem/yr., which exceeds background. 

On the other hand, if what is being referred to is 0.05 mrem/yr, then this does more closely 

approximate background. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

61. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. The phrase “dose rates not affected 

by stacking the containers” is somewhat unclear. “Stacking” typically refers to one container on top 

of another. We would think that dose rate would be affected if there were multiple containers stacked 

on top of each other, or containers side by side. The next statement regarding containers providing 

shielding seems to be referring to the containers behind one another – not container “stacking”. 

Suggest clarifying whether we’re referring to “stacking” containers on top of one another, or those 

behind each other. Overall, while there may be mitigation of dose from shielding, it would also seem 

that there could be dose contribution from adjacent or stacked containers. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

01-217(doc)/082202 D-61 
The assumption is that the shielding (side-by-side locating of containers) cancels out the two-deep 

stacking of containers. However, for the purposes of calculating doses to the public, the more 

conservative assumption of no shielding is used. 

62. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. The conclusion that “these dose rates 

are considered negligible to any receptor” may be correct, but it is not clear from this paragraph how 

this is so, given the above comments. 

Response: Corrections and clarifications made in the Draft PEA hopefully make this clear. 

63. Sec. 4, “Consequences” – General. Consideration should be given in Sec. 4 (“Consequences”) to 

adding specific Appendix references so that the reader can easily trace the amounts given in Sec. 4 

back to where the amounts were calculated and appear in the appendices. As an example, for the 

“transportation effects” amount shown in table 4.17, add a reference or footnote to indicate where 

these amounts are shown in Appendix B (“Transportation Analysis”). 

Response: Chapter 4 addresses the environmental consequences of the various alternatives. 

Detailed information supporting the chapter 4 discussion is contained in various appendices, to 

which the reader is directed for more detailed information. 

64. In Sec. 4 (“Environmental Consequences”), in the “Impacts” tables – tables 4.3, 4.6, 4.9, 4.13, 4.16, 

and 4.19 – the cost of upgrades appears in each table. This is referred to in each table as 

“construction/upgrades cost”. From the methodology (Sec. 4.1, “Methods”, 2nd paragraph, pg. 4-1), 

it appears that the intent of these cost figures is that they include not only the cost of 

construction/upgrades but also the cost of surveillance & maintenance (S&M). However, it is 

not clear that S&M costs – either facility S&M or material S&M (which would also 

include maintaining nuclear material control & accountability) – are fully included by this 

approach. 

Response: The cost numbers in the tables cited are for construction costs only. They represent a 

one-time impact occurring over a short period of time (assumed to be one year). As such these 

costs help demonstrate the socioeconomic differences among the various alternatives. They are 

used to estimate job creation and to quantify the effects of the action on the economic region of 

concern. S&M costs are not included; however, the number of permanent workers is estimated. 

65. Sec. 4, “Consequences” – General. It may be more appropriate to base facility and material S&M 

costs on the total square footage of storage space for the material – not just on the upgraded space. 

The conclusion that would likely emerge is that there would be a significant cost component 

associated with S&M, at each facility where material would be stored. Eliminating this duplicative 

S&M cost at multiple storage facilities would appear to be a strong supporting rationale for the 

proposed approach – consolidating material at a single DOE site. Consideration should be given to 

discussing these S&M costs and/or including S&M costs in the affect “impact” tables. 

Response: See response to previous comment. 

01-217(doc)/082202 D-62 
Harry Rider 

Vice Chairman 

Pike County Board of Commissioners 

Waverly, Ohio 

66. This proposed action raises numerous concerns. Specifically, safe transportation concerns, and 

security of all material at the Piketon Plant is in question. Health of workers, residents and 

environmental safety issues are also of major concern. 

Response: Comment noted. Transportation, facility accidents, and normal operations have been 

evaluated for all alternatives with risks to workers and the public identified. 

67. The perception of Pike County, our home, being a national dump site for the governments excess 

waste is appalling, to say the least. 

Response: Comment noted. The uranium materials evaluated in this PEA are not wastes but 

potentially reusable materials. 

68. This project has no financial, environmental, education or social benefits to Pike County and its 

people. For these reasons, I am very much opposed to bringing any material to Piketon for storage. 

Response: Comment noted. To date approximately $5.7 million dollars have been spent at 

Portsmouth for previous uranium management activities. It also provided five direct jobs and 

numerous indirect jobs for the area. 

Tom Reiser 

Vern Riffe, III 

Opal M. Spears 

Scioto County Commissioners 

69. Whereas, the Scioto County Board of Commissioners believe the storage of this excess uranium and 

the marketing of these materials over a 20+ year time frame will have a negative effect on our current 

and future marketing of the PGDP and GCEP sites for re-use and on the marketing of industrial sites 

for new business development in south central Ohio. 

Response: Comment noted. 

70. Whereas, the Scioto County Board of Commissioners also have a matter of concern over the 

downgrading of security forces at the PGDP in recent years. 

Response: Comment noted. 

Lee A. Barclay, Ph.D. 

Field Supervisor 

U.S. Fish and Wildlife Service 

U.S. Department of the Interior 

71. The draft PEA does not include copies of correspondence requesting informal Section 7 consultation 

with U.S. Fish and Wildlife Service (Service) Ecological Services Field Offices in Ohio, South 

01-217(doc)/082202 D-63 
Carolina, or Idaho. Service personnel have reviewed the information submitted and offer the 

following comments relative to the PGDP in McCracken County, Kentucky and the Oak Ridge 

Reservation (ORR) in Roane and Anderson Counties, Tennessee, for consideration. 

Response: DOE sent letters requesting informal consultation to subject USFWS offices on May 20, 

2002. Copies of these letters and letters of response have been added to Chapter 7. 

72. The description of Federally endangered and threatened species present in the vicinity of PGDP 

(Section 3.2.5) generally reflects information provided by this office to DOE on February 23, 2001. 

The evening bat (Nycticeius humeralis) does not currently have Federal protection pursuant to the 

Endangered Species Act. 

Response: Text in 3.2.5 was modified. 

73. According to our records, the following federally listed endangered species are known from or have 

the potential to occur within the project impact areas on the ORR: 

gray bat Myotis grisescens 

Indiana bat Myotis sodalis 

pink mucket Lampsilis abrupta 

We recommend that qualified biologists assess potential impacts and determine if the proposed ORR 

alternative may affect the species. We recommend that you submit a copy of your assessment and 

finding to this office for review and concurrence. A finding of “may affect” could require the 

initiation of formal consultation procedures. 

Response: Text in Sections 3.3.5 and 3.4.5 has been modified to reflect information provided. Since 

the potential acreage to be impacted would be in the middle of already industrial sites, it is 

reasonable to assume the potential for impacts to the species noted above is virtually non-existent. 

A Biological Assessment was prepared and sent to your office under separate cover; it is also 

included as part of the agency correspondence in Chapter 7 of this PEA. 

74. Since the Portsmouth Gaseous Diffusion Plant has been tentatively selected as the preferred 

alternative storage location, we recommend that the ecological resources section of this draft PEA 

referenced above be modified to accurately reflect the current extent of knowledge regarding 

biological/ecological resources of the Y-12 and ETTP areas, including East Fork Poplar Creek, Poplar 

Creek, and the Clinch River. 

Response: See response to comment #73. 

75. Since the American robin (Turdus migratorius) was modeled in the risk assessment in Appendix C of 

this draft PEA and given the responsibilities placed on Federal agencies by Executive Order 13186, 

we believe it would also be prudent to include discussions regarding migratory birds. 

Response: The interior forest habitat required by many species of migratory birds has been 

evaluated for the Oak Ridge Reservation with particular emphasis on the lands surrounding the 

ETTP site (SAIC 2002, Draft Land Use Technical Report, June). The proposed action would not 

affect interior forest habitat and the bird species that utilize them at any of the DOE sites. Some 

migratory birds, such as the American Robin, use more open, often man-altered habitats. It is 

possible that new construction in the middle of these industrialized sites could affect the foraging 

and nesting areas for some migratory bird species. 

01-217(doc)/082202 D-64 
James A. Brushart 

Chairman 

Pike County Board of Commissioners 

Waverly, Ohio 

76. In Pike County, we are trying to pick up the pieces and make economic development attractive. If we 

are made a dumping ground for the governments waste to be stored, this will severely hamper any 

possibilities of economic development in the future. Pike County would be recognized as a national 

dumping site for waste, thus creating a more negative image of Southern Ohio. 

Response: Comment noted. The uranium materials covered by the proposed action are potentially 

re-usable and would be stored temporarily until they could be dispositioned. These materials are 

not wastes. 

77. In closing, I ask you on behalf of thousands of Pike County Constituents, to please take your waste 

elsewhere. I challenge the Department of Energy to do something good for Pike County and its 

people. We certainly deserve much better treatment than what we have received in the past. 

Response: Comment noted. 

H. E. King 

8339 SR 139 

Minford, Ohio 45253 

78. Please please don’t let Washington and Cincinnati dump excess uranium at the Portsmouth Diffusion 

Plant in Pike County. Southern Ohio has a rate of more cancer here than any place of the U.S. We 

have fought for years to have it cleaned up. EPA says its safe one month and unsafe the next month. It 

is densely populated in this area. There are many other places to take it like Idaho Falls and Hanford, 

Washington and others more safe. We do not want it here and pray you don’t dump it on us. 

Response: Comment noted. 

Cindy Newsom 

2315 Grandview Avenue 

Portsmouth, Ohio 45662 

79. I am writing in response to the June 7, 2002, article in the Portsmouth Daily Times. I would like to 

strongly suggest that you find somewhere else to store your material (other than at the Portsmouth 

Gaseous Diffusion Plant). I support Rep. Ted Strickland when he said, “You can’t trust them 

(DOE) on anything they’ve said to us. They’ve lied to us before.” I do not think that using PGD 

Plant is in the best interest of our area – we have enough problems without needing dumped on 

with nuclear waste. I don’t believe the DOE will “re-use” or re-sale the material. A dump site is a 

dump site. 

Response: Comment noted. 

01-217(doc)/082202 D-65 
D. E. Culver 

878 Shawnee Road 

W. Portsmouth, Ohio 45665 

80. No! No! No! No more excess uranium or any uranium at Portsmouth Gaseous Diffusion Plant. 

We’ve had this killer here since the 50’s. No More. The fish in Scioto River are covered with sores, 

the bottom feeders are already dead. The wells are contaminated. The trees are dying. People are 

dying – go to hospital in Columbus nurses ask “Where are you from?” Your reply “Portsmouth”. 

Their response “Oh the Cancer Capital of the state.” 

Response: Comment noted. The risks to the workers and general population from transportation 

and interim storage of these materials at each site, including PORTS, were determined in the PEA. 

The risks were negligible to low. 

81. You clean this killer up at Fernald and Hanford and ship it someplace else to contaminate another 

place. How stupid can you get? For years you’ve talked “Jobs” well you know what you can do with 

your “Jobs”. 

Response: Comment noted. 

Norman A. Mulvenon 

Chair 

LOC Citizen’s Advisory Panel 

82. The CAP reviewers find the document poorly written and the alternatives presented in an unclear and 

confusing manner, such that the average reader cannot make an intelligent evaluation. It appears that 

no quality assurance was performed on this document prior to release for public comment. At the very 

minimum, the subcontractor, Science Applications International Corporation, should have read their 

own material for content and used the appropriate annotated outline to guarantee that all text material 

was included and properly organized to allow proper evaluation. At the maximum, all involved 

parties as listed on page 6-1 should have properly reviewed and vetted this document. The CAP’s 

primary recommendation is that DOE retract the document and have it internally reviewed, rewritten, 

corrected, amended, and then re-issued for public comment. 

Response: Comment noted. 

83. The PEA lacks an Executive Summary. 

Response: A Summary and Conclusions section (4.11) summarizes many aspects of the PEA results. 

An Executive Summary is not required for a PEA. 

84. The preferred alternative – Portsmouth – is not stated until pages 2-10. Even then, it is unclear 

whether this is the preferred alternative of all alternatives or only of the DOE sites under 

consideration. The PEA should present the compelling rational for the preference. The reasons listed 

are not “unique” as most are applicable to the Y-12 National Security Complex also. 

Response: Section 2.3.1 is the appropriate section in which to address PORTS as the preferred 

interim storage location. DOE’s preferred alternative is to locate these materials at PORTS; thus, it 

is preferred among all the alternatives not just among the DOE sites. The combination of the 

characteristics listed in Section 2.3.1 makes PORTS preferred. The word “unique” has been deleted 

from the text in Section 2.3.1. 

01-217(doc)/082202 D-66 
85. The various alternatives are not numbered or consistently named in such a way as to easily identify 

them for comparison. The various alternatives also appear in random order throughout the document 

causing additional confusion for the reader. An example of this is the final interim storage alternative 

listed in Table 2.2 “interim partially consolidated storage based on physical form” which is apparently 

the same as “Interim Partially Consolidated Storage at Several DOE Sites” in Section 4.11.1, 

Comparison of Alternatives. 

Response: The order in which the alternatives are evaluated in Chapter 4 parallels the order in 

which they are introduced in Chapter 2. The reference to “One DOE site” in the alternative title 

has been changed to “a Single DOE site” to be consistent. The discussion in Section 4.11, “Summary 

and Conclusions,” addresses the alternative with the greatest potential for environmental impacts 

(Interim Storage at a Single Commercial Site) first and the alternative with the least environmental 

impact (No Action) last. 

86. There are errors or unexplained inconsistencies between the final interim storage alternative listed in 

Table 2.2 “interim partially consolidated storage based on physical form: and the unnumbered, 

unnamed table in Section 4.9 that shows the storage plan for materials based on physical form. 

Response: Table 2.2 has been corrected. The referenced material in Section 4.9 is intended as text 

not a table. 

87. NU in the acronym list is defined as normal uranium. The definition used in Appendix A, page A-iv 

is natural uranium. The terms “natural uranium” and “normal uranium” are interchangeably and 

randomly used throughout the EA text and appendices. This is confusing to the reader and technically 

inaccurate, as “natural uranium” is the proper term. 

Response: The definitions will be changed to reflect the following: Natural uranium, as found in 

nature, is unaltered isotopically with an isotopic content of 0.711% 235U. Normal uranium contains 

the same percent of 235U as occurs in nature, but the 0.711% 235U signature may have been attained 

by blending uranium of different isotopic compositions or by processing in a gaseous diffusion 

cascade. 

88. The missions of the various sites for storage were not properly considered. 

• Portsmouth is no longer used as a gaseous diffusion facility and its future role may be limited to 

being one of the two sites for a conversion plant for depleted uranium hexafluoride (Paducah 

being the other site). 

• The three sites at Oak Ridge are lumped together in Table 2.1 and Oak Ridge is the only 

designator listed in later tables. In reality, the three major DOE sites in Oak Ridge have separate 

missions and two of the sites are not suitable for the proposed storage mission. ETTP is a closure 

site, and DOE has stated an intention to transfer the site to other ownership by 2008. ETTP 

should not even be on the list of alternatives, in that there is no future DOE mission contemplated 

once the site is cleaned up and closed. ORNL is listed in Table 2.1, but then is not included in any 

of the analyses. As a national laboratory, it is a poor candidate for a storage site. 

Response: Section 2.1, “Background,” discusses the historical missions of the various DOE sites. It 

was noted (p. 2-2) that ETTP is undergoing reindustrialization, D&D, and environmental 

restoration. ETTP is a DOE site; DOE has not transferred the land. Thus, DOE believes that, under 

the NEPA, the ETTP would be a reasonable site. The intent of Table 2.1 is to show where the UMG 

uranium inventory is located; 1,445 MTU are located at the three DOE sites in Oak Ridge. Later in 

01-217(doc)/082202 D-67 
the EA, DOE explains that both ETTP and Y-12 (but not ORNL) are considered as potential 

interim storage sites. 

89. Information is scattered and difficult to find in the PEA. For example, on page 2-3 it is stated that the 

uranium trioxide at SRS is not considered within the scope of this PEA. We don’t learn why (that 

these oxides are not part of the UMG inventory) until page 4-21. 

Response: Text on page 2-3 clarified. 

90. The option of transportation by barge is not evaluated. 

Response: Comment noted. This option was not evaluated because it is unlikely that the material 

would be transferred by this mode of transportation.

91. The PEA doesn’t seem to focus on the most logical analysis of alternatives for interim storage. This 

would be the consolidation of uranium at sites with compatible enrichment forms or with potential 

future uses. Some examples: 

1. Portsmouth and Paducah will both have facilities for conversion of depleted uranium hexafluoride 

to oxide or metallic forms. Either of these locations would be a logical choice for the national 

stockpile of DU. 

2. Paducah has a continuing mission of gaseous diffusion enrichment of uranium for commercial 

nuclear fuel. It would be a logical location for the storage of LEU. 

3. Y-12 has exceptional capabilities for handling and storing HEU, and could act as a repository for 

any of the forms, particularly those that are more reactive such as metallic uranium. Because 

proposals for future disposition of HEU include down-blending to a lower enrichment, Y-12 

might be a logical place to store compatible forms that could be used for this purpose at a later 

date. 

Response: Comment noted. Each of these facilities was evaluated in the PEA. 

92. The transportation analysis relies too heavily on computer modeling without actual analysis of the 

existing roads. Portsmouth is not accessible by interstate and for this reason would be a poor choice 

for storage of all forms/enrichments, making it a hub for a major shipping campaign involving 

sensitive cargos. It is more logical to minimize transportation on secondary roads and express a 

preference for sites close to interstate highways or other major bulk transportation options (rail or 

barge). In particular, if multiple shipments of a particular form or enrichment to a variety of end users 

are likely, the preferred storage location should weigh access to good transportation routes more 

heavily. 

Response: Comment noted. The transportation analysis focused on the potential environmental 

impacts associated with shipment of the uranium materials. 

93. With so much uncertainty about end states, one wonders why DOE has undertaken an assessment at 

this time. It also makes little sense that DOE’s huge stock of depleted uranium hexafluoride in 

cylinders – soon to be converted to a more stable chemical form – is outside the scope of the PEA. 

Response: Comment noted. An EIS is being prepared for this DUF6. The UMG inventory of 

uranium does not include UF6. Other forms of uranium that are included in the PEA have been 

addressed. 

01-217(doc)/082202 D-68 
LOC/CAP Member 

94. I also find the document exasperating, in that information is either not there or hard to find. I haven’t 

found the form the uranium is at the various sites. With so much uncertainty about end states, one 

wonders why DOE is bothering with an assessment at this time. Particularly when the gorilla of 

depleted uranium hexafluoride in cylinders appears to be outside the scope. 

Response: Information on the form of uranium at various sites is in Table 2.2, page 2-5, under the 

“Interim partially consolidated storage based on physical form” alternative. 

The uncertainties associated with final disposition do not preclude the need for DOE to find a more 

efficient management plan for its UMG inventory in the interim. 

Larry R. Hurley 

(email)—no address or affiliation provided 

95. Feedback: I’d like to see this material stored at the Yucca Mountain site (along with all the rest of the 

nation’s nuclear materials). 

Response: Comment noted. 

Lee Poe 

(email)-- no address or affiliation provided 

96. I am reading the PEA on uranium and I find that it doesn’t include most of the uranium at SRS. 

Please provide me with the rational on why the uranium selected was selected and why other uranium 

at DOE sites was not included? On the surface it sounds like the PEA should consider all of DOE’s 

U. (Please note that this comment has been modified because of security concerns.) 

Response: The material selected for consideration is viewed to be high quality, stable material with 

a substantial volume for potential reuse. 

97. Why was UF6 not covered in the EA? 

Response: It is outside the scope of the Department’s analysis for this PEA. UF6 is being addressed 

in an EIS. 

98. Was scoping performed on this NEPA document? If so, please send me the scoping document 

summary. 

Response: Scoping is not required for a PEA. 

Kathleen E. Trever 

Coordinator-Manager 

INEEL Oversight 

99. In stating a need for this EA, DOE emphasizes increasing budget pressures, good stewardship of 

resources, and ensuring maximum cost-effectiveness. DOE does not, however, provide a clear 

01-217(doc)/082202 D-69 
explanation of how its alternatives for moving materials around before deciding on their disposition 

addresses these goals. This explanation is essential to supporting a sound policy decision. 

Response: The consolidation of the potentially reusable DOE uranium material provides an 

opportunity to retain a valuable asset while supporting the critical mission of DOE nuclear facility 

closures. For example, in the case of the Fernald site, a sizable quantity of potentially reusable 

uranium had to be dispositioned in order to support the site clean-up schedule. Fernald’s review of 

the options for disposition of this material concluded that ~ $23M was saved in the shipment of the 

material to PORTS versus the site removal and burial option. In addition, Fernald estimated that if 

the PORTS option had not been available, the costs due to schedule delays may have exceeded 

$75M. Each of the UMG activities to date, and future UMG activities to relocate potentially 

reusable uranium, have/will utilize a deliberate decision-making process. 

100. Although DOE may be able to “bound” impacts based on hypothetical disposition paths, the 

geographical locations for disposition of the various physical forms could form a discriminator 

among alternatives that require transport, facility upgrade or construction. If, for example, there may 

be future activities using materials at their current or nearby location, it probably does not make 

sense to “consolidate” them elsewhere. 

Response: DOE makes decisions based on the best information available at the time of an action. If 

changes occur in the future, previous decisions will be re-evaluated to determine if adjustments 

need to be made. 

101. To support a sound decision, DOE should also provide information as to whether other activities at 

the storage facilities in question would still require similar monitoring or upkeep regardless of 

whether the reusable uranium materials remain. To enable fair evaluation of the alternative for 

consolidation by physical form versus solely geographical approaches, DOE should also provide 

information as to how physical form can relate to ultimate disposition, as well as identifying any 

differences in interim storage needs. 

Response: DOE estimated the manpower required to monitor the storage sites. Under the No 

Action alternative, the current level of monitoring would presumably continue at the various sites. 

At PORTS the existing buildings proposed for storage, under several alternatives, would have some 

level of monitoring if none of these alternatives is selected and the buildings continue in their 

present state. The level of monitoring for present uses was not estimated but is assumed to be 

similar to the proposed action. 

Regarding consolidation by physical form, DOE has received inquiries and expressions of interest 

in some of the uranium materials in the UMG inventory; however, there is not sufficient certainty 

in the final disposition paths to allow a detailed analysis. 

102. The document’s simplified assumptions prevent much quantitative analysis, but do allow some 

qualitative comparisons. 

Response: Transportation risks, various accident scenarios, and socioeconomic impacts (including 

construction costs, permanent and temporary jobs, and acres potentially affected by new 

construction) have been quantified using a variety of assumptions documented in the PEA. 

01-217(doc)/082202 D-70 
103. The fundamental, outstanding question left by the EA, however, is to what extent the alternatives can 

achieve DOE’s stated purpose of achieving management efficiencies. 

Response: The PEA addresses a portion of that question, namely what would be the expected 

environmental impacts of implementing the various alternatives. Estimates of construction costs 

are part of this analysis. DOE will also consider other costs, such as surveillance and maintenance, 

transportation, and facility upgrades, as well as other factors in reaching a decision on interim 

storage. 

Richard Demming 

104. All references to aircraft impact as shown on page 4-1, last paragraph, last sentence. This suggestion 

is made after the 9/11 attack. Replace references with external events. 

Response: Reference to aircraft impact has been removed. 

Carolyne Thomas 

Senior Project Manager 

Uranium Management Divison 

105. Table 2.2, page 2-5 contradicts with page 2-11, Section 2.3.6. Please correct the Table to reflect the 

information in Section 2.3.6, which is consistent with Appendix A. 

Response: Table 2.2 has been corrected. 

Steven T. Carter 

Executive Director 

Scioto County Economic Development Office 

106. The Scioto County Economic Development Office and the Scioto County Commissioners, along 

with U.S. Congressman Ted Strickland, are opposed to the siting of the 14,200 metric tons of reusable excess uranium from other DOE sites that are proposed to be stored at DOE’s Portsmouth 

Gaseous Diffusion Plant. Even though we are a rural/small city community, our region is densely 

populated. We believe there are other DOE sites that are much larger than our 3,700 acre site 

where these materials can be stored and marketed over time. We also believe the storage of these 

materials over a 20+ year time frame will have a negative effect on our current marketing efforts 

of the site for re-use and on the marketing of industrial sites for new business development in 

South Central Ohio. 

Response: Comment noted. More important than the size of the plant are the amount and 

availability of storage space and a trained/qualified workforce. PORTS has sufficient existing 

storage space to accommodate the entire 14,200 MTU inventory. PORTS is already storing 

approximately 4,500 MTU. However, as noted in the response to comment #4, the UMG Program 

commits to limiting use to the existing UMG storage facility. 

107. Another major concern has been the downgrading of security forces in both manpower and 

armaments of PGD’s security forces over the last several years. 

Response: Comment noted. 

01-217(doc)/082202 D-71 
W. Lee Poe, Jr. (Additional Comments—received after close of comment period) 

108. P2-1, 1st Paragraph. Broaden this paragraph to cover UO3 and state why UF6 is not included. This 

sets the stage for the NEPA document. 

Response: The information in this paragraph is general background and is not intended as a 

detailed list of what is included in the PEA. UF6 is not part of the UMG inventory because the UMG 

is seeking uranium materials with minimal nuclear safety requirements. A PEIS was prepared for 

DUF6, and a separate EIS is being prepared to further address DUF6. UO3 is included in the PEA. 

109. Table 2.1 on P 2-2 should be expanded to include other uranium materials stored for reuse or 

disposition. 

Response: Text acknowledges that other uranium materials are at several DOE sites, which are not 

part of the UMG inventory and are not part of the proposed action. They are addressed as 

appropriate under the cumulative impacts analysis but are not included as part of the tables 

referenced. 

110. P 2-3 states most of the uranium is in the form of uranium metal. Where is this covered in the EA? 

How much of the 14,200 MTU is metal. EA should provide a table that provides the breakdown of 

the inventory into it associated form. 

Response: Table 2.1 provides the uranium management inventory (amount in MTU) at the various 

sites. Table A.3 gives some indication of types of uranium at the larger DOE sites. However, for 

security reasons, the exact amount by type is not shown for all sites. 

111. In the fourth paragraph on P 2-3 the SRS inventory is described as contained in wooden boxes, 

cardboard boxes for metal and drums for LEU Oxide. I was never able to determine if the EA 

contained environmental consequences from repackaging of that inventory. Later the EA discusses 

storage of drums and steel boxes. 

Response: The impacts associated with repackaging are covered in Section 4.2 of the PEA.

112. Figure 2.1 shows example storage of metal boxes and drum storage. This figure is unclear in the 

printed version of the EA. It is basically a black photo with a large white box in the center. When 

I looked at the electronic version, it was legible. Should be legible in all forms of the EA. The 

title of the figure should specify the multi-stack storage being discussed when the figure was 

called out. 

Response: Commented noted. The intent of the figure is to show the relative sizes of drums and 

boxes, which contain uranium materials. 

113. The No Action alternative described in Section 2.2 on P 2-9 should provide clarify the small site 

storage. How many sites are assumed to store this uranium and for how long? The last sentence says 

the uranium would not be dispositioned. In my mind this means very long term consequences and 

none were discussed in the EA. 

Response: The first sentence in Section 2.2 states that ongoing storage would continue at all existing 

facilities. The impacts of the No Action Alternative are discussed in Section 4.3. 

01-217(doc)/082202 D-72 
114. As already pointed out the scope of the EA needs be expanded to discuss the other uranium being 

stored and discusses in fifth paragraph on P 2-9. 

Response: Comment noted. 

115. The last paragraph on P 2-9 says the analysis associated with the action alternatives discusses the 

bounding assumption associated with disposition. There is very little additional information in the 

EA on the bounding assumptions. 

Response: The bounding assumptions are discussed in Section 4.10. Additional text has been added 

on waste streams. 

116. P 2-10 in Section 2.3.2 says that DOE has not selected a commercial site for uranium consolidation 

in this alternative but for analysis purposes, a western and an eastern site were selected for the 

transportation analysis. Does the selection of Utah and South Carolina maximize transportation 

consequences? The justification for this selection should be given a few more sentences of 

description to convince the reader that this assumption is reasonable. 

Response: The selection of these two sites for transportation analysis does not result in the absolute 

maximum distance. The sites are realistic possibilities and serve as a “reasonable worst case.” More 

text was added to Section 2.3.2. 

117. The alternative for interim partially consolidated storage by physical form described on P 2-11 in 

paragraph 2.3.6 calls for SRS to be the metal storage site. I could find no information to support 

metal storage at SRS. In my technical judgment, metal storage has much larger consequence that 

does storage of oxides. As I indicated in my earlier letter, metal has a unique hazard, not analyzed in 

this EA, of metal fire potential which is exaggerated in long-term storage. 

Response: Comment noted. We found that oxides have a potential greater than metal for 

environmental impact in the case of an accidental release (from a fire, etc.). Powdered oxides are 

readily transported to the atmosphere and, subsequently, to a number of potential receptors in a 

fire scenario. 

118. Paragraph 2.4 discusses DOE's belief that uranium storage is a government asset. Two sentences 

later it says DOE might declare other inventory a waste. This seems to be a two-forked statement. 

This paragraph should be rewritten to eliminate this apparently inconsistency. I would really like to 

know what it is saying. What makes some uranium a national asset and other uranium a waste 

product? 

Response: Section 2.4 states that the uranium materials in the UMG inventory and, thus, part of 

this PEA are potentially re-usable. Therefore, the alternative of addressing them as waste is not 

considered further. This statement recognizes the fact that DOE has other uranium materials, 

which have been legally declared as wastes. 

119. Section 3 discusses the affected environment at Portsmouth, Paducah, Y-12, K-25 (both in 

Oak Ridge), and Savannah River Site. There is no mention of the other sites that currently store some 

of the uranium or those planned as alternatives for possible storing and managing uranium within 

this EA. These sites should be discussed in this section, but probably not in the detail of the five 

major sites. 

Response: The affected environment of sites DOE is considering for interim storage is discussed in 

Chapter 3. 

01-217(doc)/082202 D-73 
120. The Method’s section (P 4-1 in Section 4.1) says that 14 people are required for managing the 

uranium inventory. This seems like a low staffing level to manage 243,000 square foot of storage 

space with ~71,900 containers in storage. I could find no further information on what these personnel 

were assumed to do. If this uranium is a true national asset, it probably has the lowest surveillance 

staff of any of our national treasurers. The uranium management staffing should be reexamined. 

Response: The UMG staff would be primarily responsible for surveillance and maintenance, 

inventory tracking and related activities, and to some extent security. The UMG storage facility has 

been configured to require minimum staffing levels, and the storage of material has been 

established to ensure cost-effective service. 

121. In the fourth paragraph of Section 4.1, I find the statement “worst case assumptions ... are 

employed”. As I have said, I do not think this statement is correct. One such statement is that 14 

people can manage this uranium. I will point out other assumptions I do not think appropriate as I 

proceed with these comments. 

Response: Comment noted. See response to comment #120. 

122. The EA should analyze and present sabotage scenarios. These might range from theft of uranium 

(remember it is a national asset) for its value to those that would blow it up to disperse the 

radionuclides and cause bad publicity. Those 14 people would not be able to prevent either. 

Response: DOE considers the discussion of sabotage scenarios in a public document to be neither 

prudent nor wise. The Department addresses site security, including sabotage, for these materials, 

but details are not discussed in a public forum. 

123. The third paragraph on P 4-2 lists Kd units as L/kg. Please correct the units on this term. 

Response: The units have been re-evaluated and have been determined to be correct. 

124. P 4-6 Table 4-3 lists PORT upgrade cost as $8.4M and the second paragraph says it is considered to 

be $10.9M. Please correct all tables listing the earlier value. The other values in the table for PORT 

should also be corrected. 

Response: On page 4-6, paragraph 2, the $10.9M refers to the PORTS construction costs if 

125,000 ft2

 of space is built new instead of using all existing space and upgrading it. While existing 

storage space is available, it seemed prudent to indicate what impacts could be expected if, for some 

reason, not all of this space could be used. Also, see responses to comments #2 and #6.

125. P 4-6. It is obvious that DOE from major sites other than PORTS and also at the minor site have not 

been consulted on this EA. I make this judgment based upon the many tables in this section have say 

space availability is unknown. This lack of communication with other DOE site personnel should be 

eliminated and the same level of knowledge applied for each site. The lead statement in the third 

paragraph on this page confirms the lack of communication. 

Response: All DOE sites considered for interim storage were consulted and specifically asked to 

provide information about existing space, which could be used for uranium storage. 

01-217(doc)/082202 D-74 
126. Table 4.5 (P 4-7), Table 4.7 and Appendix B need units added for the two columns giving 

transportation fatalities. Are these fatalities per year or per activity? 

Response: The columns for latent cancer fatalities and traffic fatalities are totals for all 

transportation required for a specific destination/alternative. Column headings have been revised 

to say “Excess latent cancer fatalities (total)” and “Traffic fatalities (total).” 

127. Section 4.7 on P 4-17 is a very weak analysis for disposition. As I indicated earlier in this set of 

comments and in my General Comments, the section talks about bounding conditions and impacts 

then makes an arbitrary statement that all they did was double the impacts of storage. If these are 

bounding, please explain how you know since no analysis was performed. 

Response: In Section 4.10, DOE states that a rough bounding of impacts would be to take the 

alternative with the greatest environmental impacts and double them; however, several factors 

would lessen this effect. These are then discussed in detail in the subsections that follow. 

128. Third bullet on P 4-19 gives the $8.4M that was later changed to $10.5M. (See P4-6 comment.) 

Response: See response to comment #124. 

129. Combine the fourth and fifth bullets on P 4-19. They seem to be saying the same thing. 

Response: Comment noted. 

130. Expand the sixth bullet. It is not clear where the judgment came from. It says that commercial sites 

are less efficient than DOE sites. I continually hear from DOE that they want to do things using 

commercial approaches since it is more efficient than the DOE system. At best what does this add? 

Response: It is assumed that a commercial site would have to build the entire 243,000 ft2

 of storage 

space to accommodate this material. Thus, impacts from construction would be the greatest at 

commercial (and the PDGP) sites. 

131. Section A.2 describes overpacking all containers prior to shipping. Where are the environmental 

impacts of this action included in the EA. If they are not included, why not? 

Response: See Section 4.2. 

132. The last sentence on P A-2 says worker dose commitment from surveillance and maintenance of this 

uranium is expected to be less than detectable. I doubt this is a correct statement. The top paragraph 

on P A-4 goes on to describe the expected radiation dose from containers. These doses were 

detectable. The last sentence of this top paragraph goes on to make an unsupported conclusion. It 

says “these dose rates are considered negligible to any receptor”. What about doses to workers who 

purified this uranium and developed illnesses that DOE (or the government) is now paying for? 

Response: The intermittent nature of surveillance and maintenance activities, combined with a dose 

rate at 6 meters, which approximates background, would result in dose rates that are considered 

negligible. 

133. Second paragraph in Section A.3.1 on P A-4 uses a slang approach (1E-6) with no description of 

what is meant by that notation. Use the proper scientific notation then describe what it means. 

Response: Comment noted. 

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134. As I read Section A.3.1.1 on P A-5, particularly the last couple of sentences, I do not know what 

conclusion you are trying to make. 

Response: Comment noted. 

135. Section A.3.1.2 on PA-6 describes a single container breach as being a bounding accident. This same 

event could breach multiple containers on adjacent pallets. Why then is a single breach bounding? 

Response: Section A.3.1.2 states that single-container handling accidents are bounding for the 

accident category “container breach” because these events dominate risk to workers. A container 

breach is not bounding for all types of accidents. 

136. The next to last sentence in Section A.3.1.2 says that container breach is insignificant compared with 

a fire. Multiple drum ruptures are speculated above. The logic that shows fire is more significant 

than rupture should be clearly made or both analysis given. 

Response: Some fires can result in multiple containers breached whereas a forklift rupture or 

dropping of a drum would more likely result in a single container rupture. Also, fire provides a 

mechanism for airborne transport once containers are breached. Thus, a multiple container breach 

with fire to mobilize the uranium materials is a more serious accident than a single or multiple 

container breach without an associated fire. 

137. The basis for the frequencies given in Table A.7 should be given. 

Response: This is discussed in Section A.3.1.3. 

138. How can the frequencies for tornadoes at all sites be the same as shown on Table A.7? I likewise 

have the same comment for earthquakes. 

Response: The frequencies in Table A.7 are not the frequencies of earthquake or tornado 

occurrences at the DOE sites. These vary from site to site. Frequencies shown in Table A.7 indicate 

the threshold earthquake or tornado loading for which damage is expected from the event. The 

frequencies are the same because, for example, a higher-intensity earthquake at Paducah occurs at 

the same frequency as a lesser-intensity earthquake at Oak Ridge. 

139. P A-7. Describe your judgment of how long seismically damaged facilities will be left in the 

damaged condition while personnel repair other higher risk damaged facilities. This duration of 

exposure to the elements should be included in the analysis for these facilities. 

Response: Because the vast majority of the materials released would occur during and/or 

immediately after the seismic event, the assumptions used in the analysis will bound the risks. No 

estimate of how long damaged facilities would remain damaged is included in the analysis. It should 

be noted that depletion of the initial source term occurs over time, so the assumption of all material 

released during the initial phase of the event is conservative. 

140. P A-7 second paragraph references reinforced concrete and structural steel debris as fire mitigation. 

All storage facilities will not be constructed of concrete thus the concrete and steel should not be 

relied upon as a fire mitigator. It is unclear from the text of that paragraph how much reliance is 

afforded by this building material. 

Response: As noted in Section A.3.1.3, following a direct seismic event, a number of small fires may 

occur. No building structure is assumed to remain, and fire suppression systems are assumed to be 

01-217(doc)/082202 D-76 
totally destroyed. The buildings are assumed to be constructed of steel and concrete, and these 

materials, unlike wooden structures for example, would not readily support combustion. In 

addition, the debris and rubble act as shields to prevent the subsequent small fires from spreading 

and involving the entire stored material inventory. 

141. The second paragraph on page A-8 seems to use the MAR yet MAR is not given on Table A.8. 

Response: Your observation is correct. In order to reduce the complexity of the tables, the MAR 

and release factor values were not repeated in Table A.9. 

142. The DRs in Table A.8 seem to be totally subjective. Support for the values used should be provided 

in this appendix. 

Response: References for release factors are given in Section A.3.2. 

143. The ARF × RIF values given in Table A.8 should be referenced. 

Response: References for release factors are given in Section A.3.2. 

144. Add a section describing storage facilities (similar to that given in Section 2 of the EA) to this 

appendix on page A-9 to support the analysis given in Section A.3.3.2. 

Response: Comment noted. The addition of this information will not affect the intent of the 

document. 

145. U metal is pyrophoric and when ignited, I would expect that all of the metal would be at risk. U fires 

are not easily extinguished. 

Response: Comment noted. The degree to which uranium material ignites depends on several 

factors, including the physical form. For example, uranium metal shavings are easily ignitable, 

whereas uranium metal in large ingots is not. This factor is included in the assignment of DR, ARF, 

and RF values for fires involving metals. 

146. The source terms discussed in the second paragraph are very subjective. Add information so your 

reader will understand why the values were picked. References, showing why values were picked, 

are always beneficial. 

Response: References for many factors have been provided. See responses to comments #142 and 

#143, for example. 

147. The frequency of facility fires is stated to be unlikely. Be more quantitative. Is this one chance in 

10 years or a frequency of 0.1/year. My judgment says it is a frequency of 10-4 to 10-6 is unlikely. 

DOE experience of fires is probably in the range of 10-2 to 10-3 and with the number of facilities 

described in this EA fires can be expected to occur during the time interval for this uranium 

storage. 

Response: DOE guidance for accident analysis states that qualitative estimates of frequency are 

sufficient and that a frequency range of 1E-2 to 1E-4/year is unlikely. This frequency applies 

independently to each storage location and alternative; it is not additive. 

01-217(doc)/082202 D-77 
148. In Section A.3.3.3 include the long-term consequences as well as short-term consequences. Material 

lost from containment during a seismic event will probably remain in an exposed condition (to the 

environment) for weeks and some of it will be transported to surface streams before the low priority 

uranium cleanup can be accomplished. 

Response: Comment noted. See response to comment #140. 

149. Identify the basis for the 10% and 15% of drums forecasted to be dislodged from the storage array in 

the first bullet on P A-9. 

Response: These assumptions are documented in the cited reference (Hand 1998). 

150. The third bullet identifies 25% of the material spilled. What is the basis for value? If spilled what is 

assumed on cleanup and when. 

Response: These assumptions are documented in the cited reference (Hand 1998). 

151. Again metal fires should be considered in a seismic event consequences. 

Response: Comment noted. See response to comment #145. 

152. The second line on P A-10 uses the term conditional probability to reduce the risk from seismic 

event by a factor of 10. What is the basis for this factor of ten reduction. The arbitrariness of all of 

these values leaves the EA reader questioning the analysis. Try to support conclusions and not make 

them so arbitrary. 

Response: Comment noted. As noted on page A-10, this value is an estimate. 

153. Near the middle of P A-10, duration of 1 hour is assumed for airborne release. The longer-term 

aspects of resuspension of released material should be included for the time the material has not been 

cleaned up. 

Response: Comment noted. See response to comment #139. 

154. The third bullet, on P A-13, assumes the facility workers will be exposed for 10 seconds. This seems 

very short for workers who are trying to mitigate consequences or to a worker who is hurt from a 

seismic event and cannot escape. 

Response: The assumption of 10 seconds is standard for facility worker response to an accident 

(i.e., “see and flee” policies). Subsequent recovery actions are not included in accident analysis 

evaluations, as accident response personnel are adequately protected to respond safely to events. 

155. The conclusions given in Tables A.11 and A.12 that facility workers will receive negligible dose and 

maximum consequence seems inconsistent with co-located workers and the public receiving doses. 

Calculated values should be given in the Appendix so reviewers can make their own judgment as to 

its significance. 

Response: Comment noted. See, also, response to comment #154. 

01-217(doc)/082202 D-78 
156. Appendix C is very difficult to understand. It is full of technical terms and it is not written so it can 

be understood by a technically trained stakeholder and I do not think it is of any value to a decision 

maker or to the general public. 

Response: Comment noted. In order to provide a complete analysis, an assessment of chronic risks 

to humans and ecological receptors of airborne uranium deposited on soil and surface water and 

from water to sediment is provided in Appendix C. 

157. On P C-2, in Section C.2.1.1, need to say why Stability Category F was assumed. 

Response: Stability Category F was assumed because it is the most stable (results in least mixing or 

dilution) and, thus, provides the most conservative risk estimate. Text was added to Section C.2.1.1. 

158. In Section C.2.2.2, why was the assumption made that uranium was deposited in a pond with an 

average depth of 2 meters? It would seem to me to be worse to deposit it in surface creeks that allow 

easy access to animals and other ecological system varmints. 

Response: Moving water, such as creeks, permits much more mixing (dilution) than a pond; thus, 

assuming standing water is a more conservative approach, which results in a greater potential for 

ecological impacts. 

 

159. Section C.3, on P C-9, makes the judgment that residential exposure is considered implausible under 

current site conditions. It is unclear that this is a reasonable judgment. Obviously if one can limit 

exposure, the consequence of this EA are negligible. This condition should be proven by reasonable 

analysis not assumed away. 

Response: The risks to residents were calculated and documented in Section C.3 even though such 

exposure is unlikely. Risks were not “assumed away.” 

160. The table set up of the summary tables (Table C.20 and C.21) is poor. I presume that the last three 

columns are Radiation Exposure. Likewise three columns are Chemical Exposure. Fix the tables so 

this differentiation is clear. Add units to the table. 

Response: Table headings have been clarified per comment. Hazard quotients (HQs) are unitless. 

161. My conclusion is that calculated data should be given in tables in the appendix so the reader can 

see the results of calculations. Information in the Appendix should not be decided to be low 

or negligible. That conversion is not appropriate here nor in Section 4 until the analysis is 

being summarizing. (This EA did not summarize the analysis in Section 4 nor did it have a 

Summary). 

Response: The numerical definitions of high, moderate, low, and negligible risks are presented in 

Section C.3.5. The summary tables in Appendix C use these word definitions instead of specific 

numerical values to aid reader understanding. 

01-217(doc)/082202 D-79 
R. L. Huskin 

Savannah River Operations Office 

162. Page 2-1, Section 2.1, 2nd Paragraph, 9th Line; The stated typical percentage of 235U in depleted 

uranium (DU) does not agree with the value shown in Table B.1 on page B-3. Page 2-1 says DU 

typically contains 0.25% 235U while Table B.1 says 0.10%. 

Response: The values citied in Table B.1 are the values used in the analysis. While the percentage 

differs from the typical DU of 0.25%, 235U use of 0.10% would produce only a very minor difference 

in the results. This was verified by re-running the analysis using 0.25% U235. 

163. Page 4-6, Section 4.4.1, 3 rd Paragraph; Paragraph states “DOE has not identified existing buildings 

at (sites other than PORTS) to accommodate these additional uranium materials at this time. 

Therefore, for analytical purposes, it is assumed new storage space would have to be constructed.” 

This begs the question of has DOE even made any attempt to identify such existing facilities at sites 

other than PORTS. Without any such attempt, it would appear any estimates, such as those shown in 

Table 4.3, would be wholly inaccurate and deliberately skewed in favor of PORTS. This hardly 

appears to be an unbiased assessment of the adequacy and availability of sites about the DOE 

complex. 

Response: See the response to comment #125. 

164. Page 4-20, Section 4.12, 3 rd Paragraph, 1st Sentence; As written, the statement leaves the impression 

that uranium shipments will increase traffic accidents and fatalities because the cargo is uranium, 

rather than clearly stating any increase in such events would simply be the result of additional 

vehicles on the nation’s roads, regardless of cargo. 

Response: Text cited has been modified to clarify this point. 

165. Page 4-20, Section 4.12, 3 rd Paragraph, 3rd Sentence; I don’t believe this can be substantiated with 

the data presented. To state there would be an increase in LCFs to workers and the public from this 

transportation program, one must calculate both the potential LCFs resulting from the program and 

the LCFs potentially suffered by workers in the vicinity of the materials in a no-action alternative. I 

didn’t see any such estimate for the no-action alternative in Section 4.3 nor any table presenting 

estimated LCFs from incident-free operations such as presented in Table 4.1 for accidents. Therefore 

there is no comparison of the no-action alternative to the other scenarios to determine if there was a 

net increase or decrease in LCFs. 

Response: The text, as written, indicates that the increased LCFs are due to exposure during 

transport. Since the uranium materials would be stored somewhere under any alternative, 

including No Action, the transport risk is in addition to storage risks. 

166. Page A-12, Table A.10; The values, in meters, for the distance to site boundaries for several sites 

such as INEEL and SRS seem inappropriately low. Are values of 526 meters and 727 meters correct 

for INEEL and SRS, respectively? While not familiar with the assumed locations for the materials at 

these sites, I can say several sites, such as INEEL and SRS are very large, with site centers greater 

than 10 miles from their boundaries. 

Response: Because specific storage locations were not provided for several sites, a location central 

to roads, warehouses, and other similar facilities was postulated. Actual distances may be greater; 

however, the shorter distances used in this analysis are conservative.

01-217(doc)/082202 D-80 
167. Page B-2, Section B.3, 8th Dot; I believe the estimated duration of 10 days grossly underestimates 

the likely transit time for 14,400 km. This would equate to an average vessel speed of 33 knots. I 

don’t believe you’ll find many freighters with such speed. The ones currently in use for transporting 

foreign research reactor spent nuclear fuel back to the U.S. typically are capable of only about 

11-12 knots. Only about 1/3 of the apparent speed of the uranium carriers. If one were to state the 

distances may range from X to 14,400 km with an average of about 5,000 km, an average transit time 

of 10 days would seem much more reasonable. 

Response: The text has been changed to indicate that 14,400 km is the maximum distance 

port-to-port. The dose to crew members is now stated in mrem per person per day to account 

for various distances of shipments. 

168. Page B-3, Table B.1; See 1st comment concerning page 2-1. 

Response: The values cited in Table B.1 are the actual values used in the analysis. See the response 

to comment #162. 

169. Page B-3, Section B.3, 5th Dot; There is no basis provided for the assumption that 1% of accidents 

would result in release of radioactive materials. Most other stated assumptions appear to have a 

stated basis. 

Response: The 1% value is a conservative engineering estimate. The only good test and modeling 

data that exist are for Type B spent fuel casks and TRUPACT-II containers, and those values range 

from 0.01% to 0.1%. Sandia has historically used, and currently is using, 1% for Type A and IP3 

packages. It has been used in previous DOE NEPA projects [for example: DOE/EA-1290, 

Environmental Assessment: Disposition of Russian Federation Titled Natural Uranium (1999)].

170. Page B-3, Section B.3, Last 4 Dots; These are redundant, considering content of the last two dots on 

page B-2. They should be consolidated. 

Response: The bullets were consolidated. 

171. Page B-4, Table B.2; The Eastern Centralized Commercial Storage Site (Barnwell) is located on the 

SRS Site boundary. Why then, would their values for “Truck Only – Dose Risk” be so different; 

0.0036 (SRS) verses 0.00206 (Barnwell)? The values for all other categories for SRS verses 

Barnwell are almost identical, as they should be. 

Response: The Barnwell site was selected to represent the location for an eastern centralized 

commercial storage site since it has existing infrastructure and experience in handling these 

materials. Other locations in the eastern United States could have been selected. The actual storage 

location, should a commercial storage site alternative be selected, could be anywhere in the eastern 

United States. However, we concur with the logic presented in the comment that adjacent storage 

sites should have virtually identical risk results. 

The values in Table B.2 are different because in selecting the nodes to use in the TRAGIS routing 

code, there are several SRS nodes from which to select and two nodes for Barnwell to choose from. 

Most likely, the nodes selected to run the analysis are not exactly at the Barnwell LLW site, and the 

SRS node is almost certainly not at the exact location of the material to be shipped or at the fence 

line adjacent to the Barnwell site. We used the same node for each origin and destination in all of 

the analyses. Differences in routing will result in differences in collective dose risks since the 

RADTRAN code allocates a population weighting factor to rural, suburban, and urban portions of 

a given route. 

01-217(doc)/082202 D-81 
Neither routing results in appreciable risks due to transport; however, since we know that the 

Barnwell and SRS destinations are essentially in the same place, the reader can use the Barnwell 

route results in Table B.2 for both Barnwell and SRS destinations. 

172. Page B-7, Section B.5, 2 Dots and last Paragraph; The last paragraph states the total number of 

shipments could not be estimated because the amount of material in each shipment may not be 

known. Without an assumption of the quantity of material in each shipment, how were estimates 

made of the average doses to the crewmembers? If the estimate is made based on the assumed dose 

rates on the drums as explained in Section 4.2 on page 4-3, I believe 159 mrem per crewmember per 

shipment, as stated here and at the bottom of page 4-18, is a gross overestimate. The potentials for 

such exposures would mandate implementation of a radiation protection program that, in turn, would 

find such exposures to not be ALARA.) 

Response: DOE concurs that the assumptions used were overly conservative and overstated the 

risk. Some assumptions have been modified (e.g., 2-hour exposure per crew member to 

material between 1 and 16 m, instead of 12 hours, and 4 mrem/hour instead of 6 mrem/hour to 

be consistent with packaging calculations). The dose rate is 1.8 mrem/hour per crew member. 

173. Page C-12, Table C.4; When using the values for Intakes in Table C.5, I can reproduce the various 

values for Dose in Table C.5 and Cancer Intakes in Table C.4, but I can’t arrive at the same dose 

values shown for Cancer Risks in Table C.4. I am assuming the Cancer Risk values are a product of 

the CEDE derived from the Cancer Intakes and the appropriate risk values from ICRP-60 (i.e., 1 

LCF per 2,000 Person-Rem for the “Resident” and 2,500 Person-Rem for the “Standard Worker”. If 

this is the correct method, it appears the Cancer Risk values are too high by a factor of between 2 and 

30. It appears as if the dose-to-risk conversion values vary greatly and range between 70 rem and 

1150 rem instead of the expected values of 2,500 rem and 2,000 rem for workers and the public, 

respectively. 

Response: Cancer risks are estimated by multiplying the intake (pCi or pCi-yr/g)) in Table C.4 by 

the cancer slope factor (risk/pCi or risk/yr/pCi/g) in Table C.7. For example, the risk to the 

Short-term Emergency Worker from ingestion of U-234 is 8.8E-02 (pCi) × 1.58E-10 (risk/pCi) = 

1.4E-11. Slope factors are from HEAST, per standard risk assessment practice. 

174. Page C-15, Table C.7, Upper Table; The issue described above for page C.12 also applies here. Put 

another way, the Risk/pCi appears to be based on something other than the expected 2,000 or 2,500 

(as appropriate) rem/LCF. For example, in the specific case of Inhalation (Risk/pCi) for 

Uranium-235+D, the stated value appears to be based on a risk-to-dose factor of 756 rem/LCF. 

Response: See response to comment #173. Slope factors are from HEAST, per standard risk 

assessment practice. 

175. Page C-15, Table C.7: It appears some of the footnotes are not shown beneath the table. 

Response: Table has been modified. The extraneous footnoting was removed. 

01-217(doc)/082202 D-82 
01-217(doc)/082202 D-83 

John Owsley 

Director 

Tennessee Department of Environment and Conservation 

DOE Oversight Division 

176. Acknowledging that uranium wastes are not part of the scope of this PEA, the document should 

identify and address any waste streams associated with the re-usable uranium materials. The PEA 

should provide maps of probable transportation sources.

Response: Text in the PEA has been added to acknowledge waste streams associated with 

disposition or in the event product is later declared to be a waste. Since the waste streams are 

dependent on the specific end use, and these are only known in general terms, this was not 

evaluated in detail in the PEA. However, the many thousands of containers used to transport the 

uranium product would eventually become a waste stream. Either the containers are considered 

waste and disposed or they are cleaned for reuse, creating a waste stream from the cleaning 

operations. It is unlikely that the empty containers could be reused as is, except in very limited 

circumstances. 

177. The PEA should provide maps of probably transportation routes. 

Response: Transportation routes were identified for analysis purposes in the PEA using the 

TRAGIS routing model. Potential impacts from accidents and exposure were addressed in the 

PEA; however, for security reasons, DOE cannot publish map routes. 

178. The state of Tennessee reiterates its position on not being willing to accept any materials designated 

for recycle/reuse without definite disposition pathways which may accumulate to long term storage 

or any waste that may require long term storage prior to treatment/disposal. 

Response: Comment noted. 

179. Section 2.1 Page 2-1, the typical end-use products are stated as metal or UO2. On page 2-3, 

Fernald’s largest inventories that fall within the scope of this PEA are stated to be in the form of 

metal and UF4. The UF4 should be added to the statement on page 2-1 that defines the scope. 

Response: The intent of the introductory paragraphs in Section 2.1 is to provide general 

background information on uranium, not to provide an exhaustive list of all uranium forms 

covered by the PEA. 
01-217(doc)/093002 D-51 

APPENDIX D.2 COMMENTS AND RESPONSES 

DRAFT URANIUM MANAGEMENT PROGAMMATIC 

ENVIRONMENTAL ASSESSMENT 
01-217(doc)/093002 D-52 
01-217(doc)/093002 D-53

APPENDIX D.2. COMMENTS AND RESPONSES 

Response to Comments on the Programmatic Environmental Assessment 

for the U.S. Department of Energy, Oak Ridge Operations 

Implementation of a Comprehensive Management Program for the Storage, 

 Transportation, and Disposition of Potentially Re-usable Uranium Materials 

(DOE/EA-1393) 

Gregory L. Simonton 

Executive Director 

Southern Ohio Diversification Initiative 

1. Please identify any other potentially reusable uranium material/uranium feed currently located at 

PORTS. 

Response: Materials deposited throughout the cold standby and shutdown cells are a source of 

future potentially reusable uranium. 

2. What buildings would be used at PORTS for this project? 

Response: Due to security concerns, specific building locations cannot be identified in the PEA. 

However, should an alternative involving the PORTS site be selected, the UMG Program commits 

not to exceed the storage capacity of the existing UMG storage facility. This commitment to limit 

material within the confines of the existing UMG facility will further ensure that the disposition of 

material remains a priority. As uranium in the inventory is dispositioned, additional uranium materials 

in the UMG inventory at other DOE sites could then be stored at PORTS on an interim basis. 

3. What building(s) are included in the 450,000 square feet of available building space cited in the Draft 

Environmental Assessment (DOE/EA 1393)? 

Response: See response to comment #2. 

4. What other facilities would be required to support the DOE preferred option to consolidate all of the 

material at PORTS? 

Response: The PEA identifies the need for approximately 168,000 ft2

 of additional storage space. 

Assuming additional space is required, then with the exception of temporary use of roads and the 

equipment needed to offload and store the uranium materials, no other facility use is anticipated. 

However, in consideration of comments received, the UMG Program does not plan to use additional 

buildings at PORTS. DOE anticipates storage at PORTS will be limited to the current UMG 

storage facility. 

5. Why is the material considered “valuable” and “reusable”? 

Response: These materials have a market value and have potential reuse in various government 

and commercial applications. There is an expressed interest by third parties to acquire some of 

these materials in the near future. It is anticipated that other potential users of these materials will 

be found. Reusing this material helps protect the environment since recycling avoids having to bury 

the material in the earth. Its potential use in down-blending with highly enriched uranium 

promotes nonproliferation goals.
01-217(doc)/093002 D-54

6. If more potentially reusable material is shipped to PORTS, please identify the impacts/restrictions on 

other buildings and facilities at the site (in the context of production reuse). 

Response: Should an alternative involving the PORTS site be selected, the UMG Program commits 

not to exceed the storage capacity of the existing UMG facility. As uranium in the inventory is 

dispositioned, additional uranium materials in the UMG inventory at other DOE sites could then be 

stored at PORTS on an interim basis. Thus, there should be no impacts or restrictions on the other 

buildings and facilities. 

7. Please identify the method of shipment, mode of transportation, and route(s). 

Response: Routing was calculated using the Transportation Routing Analysis Information System 

(TRAGIS) with two modes being considered—all shipment by truck and shipment by rail where 

appropriate with all other shipment by truck (termed the “truck/rail option”). See Appendix B for 

more details regarding routing assumptions and calculations. 

8. What guarantees will the local community receive regarding the ultimate disposition date? 

Response: DOE will attempt to disposition the uranium materials as quickly as reasonably possible 

and is committed to making periodic reassessments of materials in storage. 

9. Please provide the proposed schedule of re-classification to ensure the material is reusable, 

marketable, and not deemed a waste. 

Response: The UMG Program is proposing a review and documentation of material assessment not 

to exceed 5 years. 

10. What happens to the material if it is subsequently determined to be a waste? 

Response: If material is declared waste, additional funding will be requested from appropriate 

DOE Programs to dispose as waste. 

11. Please identify the markets for this material. 

Response: The potential markets are discussed in Section 2.3.8. They include commercial 

processing and domestic sales to commercial nuclear vendors for the manufacture of nuclear fuel 

for commercial nuclear power plants, maintenance of a strategic reserve, down-blending of HEU in 

conjunction with arms reductions treaties (with the resulting LEU available for use in commercial 

nuclear power plants), use by research facilities, other government agencies and foreign sales. 

12. When did the DOE preferred option first receive consideration? 

Response: During the internal DOE scoping process for this proposed action several alternatives 

were formulated including an alternative for Interim Consolidated storage at a Single DOE Site. 

Recent successful DOE experience at PORTS in storing the Fernald and Hanford uranium 

materials suggested that PORTS would be the preferred site under this alternative. 

13. How would the importation of the material affect current clean up project? Future D&D activities? 

Response: No impact to cleanup or D&D activities is anticipated. 
01-217(doc)/093002 D-55

14. How many permanent jobs are associated with this project? Newly created full-time permanent 

positions with the DOE preferred option? 

Response: The number of permanent workers (and initial construction workers) is shown for each 

site under each alternative in Chapter 4. See specifically Tables 4.3, 4.6, 4.9, 4.13, 4.16 and 4.19. For 

the Interim Storage at a Single DOE Site, the analysis performed in the PEA assumes an additional 

168,000 ft2 of space would need to be upgraded. As shown in Table 4.3, this results in 9 new 

permanent workers at PORTS (and 210 temporary construction workers). This assumes upgrades 

of buildings to increase effective storage space. However, as noted in response to comment #4, the 

UMG Program has decided to limit storage to the existing UMG storage facility. Therefore, 

permanent workers shown in the table would be significantly less. 

15. Please identify the community benefits associated with the importation of this material to PORTS. 

Response: This proposed action would continue to use the uranium-experienced and trained work 

force at PORTS. PORTS, with the uranium conversion plant and UMG activities, would be 

considered a multipurpose site versus a closure or D&D site. 

16. Will the full proceeds, including applicable taxes, of the sale of this material be returned to the 

community? 

Response: Proceeds will be used to cover costs incurred by the sale of the material, salaries, 

handling, and shipping at the PORTS site. Surplus would be returned to the U.S. Treasury as 

required by law. 

17. Will the DOE utilize the designated CRO for disposal/sale of this material? 

Response: Current plans are for the UMG to sale/disposition this material. 

18. Define temporary storage. 

Response: As stated in Section 2.3, DOE proposes to implement a long-term (greater than 20 years) 

management plan for its inventory of potentially re-usable LEU, NU and DU. Six interim storage 

alternatives are considered. Each of these alternatives also has associated with them the disposition 

of these uranium materials. Thus, the action will cover a greater than 20-year period. Further, this 

PEA does not provide for permanent storage at Portsmouth. 

19. Assuming there is a market for this material, is there a prohibition or moratorium that would prevent 

or affect its sale? 

Response: Under the disposition options discussed in Section 2.3.8, commercial process/domestic 

sales, transfer to research facilities and transfer to other government agencies can proceed in 

compliance with existing laws and regulations governing such sales or transfers. Before these 

materials can be sold, a Secretarial Determination is required to evaluate the potential for adverse 

impact on the market. 

20. Does USEC have any need for any of this material? 

Response: No. USEC uses UF6 for their Paducah enrichment operations, which is not in the scope of 

the PEA. 
01-217(doc)/093002 D-56

21. Has the DOE considered transferring ownership of any of the material to USEC? 

Response: USEC cannot use this material in its current form. USEC uses UF6, which is not in the 

scope of this PEA. 

22. Will additional security be needed at PORTS if any of the material is imported? 

Response: DOE will review the security needs at PORTS should a decision be made to move these 

materials there. DOE is committed to ensuring appropriate security forces are maintained. 

23. Has DOE consulted with and sought the input of the Ohio Congressional Delegation regarding the 

importation of nuclear material to PORTS? If so, what was the outcome? 

Response: DOE has hosted several public meetings with attendance from members of the Ohio 

delegation. The delegation accepted the program and holds DOE accountable for maintaining 

interim storage in DOT-certified containers; not storing waste; and not receiving funding as part of 

the Portsmouth cleanup plan. DOE is obligated to honor the commitments for the UMG Program 

in the same manner as has been maintained for the Hanford, Fernald, and university materials 

received to date. 

24. Of the 158 sites currently storing the material, is there any more “reusable” or “potentially 

marketable” material being generated? If yes, will it automatically be transferred to the storage site 

chosen during this action? 

Response: The 14,200 MTU of uranium inventory is all this is addressed in this PEA. No other 

materials are being considered for consolidation. 

25. Has any of this material ever been classified as a waste? 

Response: No. All material is carefully screened prior to acceptance. 

26. Please identify all of the sites currently storing this material and provide a brief description of the 

material at those sites. 

Response: Table 2.1 provides the uranium management inventory (amount in MTU) at the various 

sites. Table A.3 gives some indication of types of uranium at some of the larger DOE sites. However, 

for security reasons the exact amount by type is not shown for all sites. 

27. Please explain the relationship (on page 3-2/Environmental Justice Section) between race, income and 

the decisions to store this material at any location. 

Response: DOE is required to determine if low-income or minority populations would be adversely 

and disproportionately affected by the proposed action. If this is the case then DOE must take this 

into consideration when making a final decision. There were no adverse environmental effects 

which would disproportionately affect low-income or minority populations for any of the 

alternatives considered. 

28. Please provide brief details on the nature of retrofitting/upgrade required at PORTS for the DOE 

preferred alternative. 

Response: The Uranium PEA analysis assumes 168,000 ft2

 of building upgrades. This would result 

in the receiving capability for loading/unloading needing to be improved. However, DOE is 
01-217(doc)/093002 D-57

committed to using only the UMG storage facility. Some additional modification to the current 

storage facility may be required as well as continued upgrades for the UMG facility. 

29. Who will be used to complete retrofitting required at PORTS? 

Response: Prior to the start of retrofitting existing facilities, a labor determination will be made to 

identify the work force that will be required to perform the work. This determination will take into 

consideration the type and extent of work to be performed. 

30. Who regulates the safe storage of the material at PORTS? 

Response: The program to ensure the safe storage of the uranium material at PORTS is 

administered by U.S.DOE. 

31. On behalf of the southern Ohio region, and before any decision on this matter is made, we 

respectfully request a meeting with the Secretary of Energy or his designee with authority to make 

decisions regarding this issue. 

Response: Comment noted. 

32. We believe this proposed action is contrary to our efforts, the stated DOE mission to reindustrialize, 

and the tireless efforts of our elected representatives in Columbus and Washington for productive, job 

intensive reuse of the PORTS facility in Piketon. Therefore, the SODI Board of Directors opposes the 

subject material being stored at the Piketon site. The residents of Southern Ohio desire projects that 

have recognizable value and benefit for the community. We want input into our future, the goals for 

the site, and new missions. 

Response: Comment noted. 

Graham E. Mitchell 

Chief 

Office of Federal Facilities Oversight 

State of Ohio Environmental Protection Agency 

33. During the meeting on June 4, it was noted that funding just became available to help with proper 

disposition of the uranium material currently stored at the Portsmouth facility and that additional 

funding would be needed to continue to find a new use for this material. Please state how US DOE 

intends to continue funding this program so that material will not be stored in perpetuity but rather 

shipped to other entities for re-use. US DOE must make funding this program a priority within each 

budget in order to continue disposition of the uranium material. Without proper funding, the 

necessary research to determine potential uses for this material cannot be accomplished. The cost for 

management and research for re-use of this material should not come from the budget for the clean up 

and remediation of the Portsmouth facility. 

Response: Funding for specific activities associated with disposition of material will continue to be 

requested as part of the annual budget process. Requests for this funding continue to be separate 

from funding requests for cleanup and remediation of the Portsmouth facility. 
01-217(doc)/093002 D-58

34. Portions of the revenues generated from the Uranium Management Group should be maintained in 

Portsmouth to off set the cost of storing the material as well as cleanup activities. 

Response: Comment noted. See response to comment #16. 

35. Ohio EPA understands US DOE’s goal to consolidate uranium materials to reduce costs and promote 

more efficient management of these materials. However, to really develop credibility, US DOE is 

going to have to prove that this material does have economic value and other companies or 

government agencies are interested in it. Uranium materials need to be leaving the site rather than just 

arriving for storage. US DOE should establish goals and commitments to stakeholders to remove a 

certain percentage of material per year. These commitments could be in the form of a letter of intent 

or other type of agreement with the State of Ohio. 

Response: Comment noted. The UMG is developing a disposition strategy to remove the material 

from the site as quickly and reasonably as possible. DOE will provide a letter of intent to the State 

of Ohio regarding this strategy. The disposition strategy will include DOE’s commitment to make 

periodic, not to exceed five years, assessments and documentation of the material in storage in 

order to ensure that the material continues to have reuse potential. 

36. The draft EA noted that US DOE considers 20 years or greater to be interim storage. At what point 

within the 20 years will US DOE determine that this material is no longer of value and deem that it 

should no longer be stored but treated as a waste? What plan(s) does US DOE have to evaluate this 

material over the next 20 years to determine if it is of value? Because of past problems with 

storage of materials that later became waste, US DOE must make a commitment in the EA to 

establish a process where the inventory is reevaluated on a regular basis (3-5 years) to ensure that it 

still has economic value. Please refer to the comment above in regard to establishing an agreement 

with the State of Ohio to continually evaluate the material and remove a percentage of this material 

from the site each year. US DOE cannot continually accept material at the Portsmouth facility 

without establishing that the material is of economic value. 

Response: The UMG is developing a disposition strategy to move the material off the site as quickly 

and reasonably as possible. A process to re-evaluate the material in order to make sure it is not 

waste will be incorporated into the disposition strategy, as noted in response 35 above. 

37. US DOE mentions that disposition is a major function of this uranium management effort. US DOE 

must also include disposition as waste as an additional component of this effort. Over time, as US 

DOE reevaluates this material, some of it may no longer have economic value and US DOE should be 

able to disposition it as waste under this EA. US DOE must ensure that funding is available to remove 

the material that is no longer of economic value as a waste. 

Response: Comment noted. Text has been added to Sections 1.2, 2.3, and 4.10 to address potential 

waste streams. The UMG has received funding to evaluate disposition activities. If the material in 

storage is declared waste in the future, additional funding will be requested from the appropriate 

DOE program. 

38. The material currently at Portsmouth was moved there in order for US DOE to meet its regulatory 

requirements at several other sites. US DOE-Portsmouth has a regulatory requirement to address 

contamination at the site per the requirements of the Ohio Consent Decree. Currently, the material 

stored on site is in a building, which sits upon and is adjacent to a groundwater plume, which is to be 

addressed during the next fiscal year. The storage of the uranium material may interfere with the overall 

site clean up. Please state how US DOE will ensure that storage of the additional material will not 

interfere with the requirements of the Ohio Consent Decree to clean-up the site. US DOE 
01-217(doc)/093002 D-59

should conduct environmental characterization of buildings to be upgraded to meet the potential storage 

needs for incoming material. This effort could avoid future disruption of uranium management efforts. 

Response: As noted in responses to comments #2 and #6, the UMG Program is committing not to 

exceed the storage capacity of the existing UMG facility. Thus, no conflicts with the Ohio Consent 

Decree are anticipated. No activities that conflict with planned or ongoing remediation are 

anticipated. 

39. Please state how storage of this material will not interfere with the other potential missions at the 

US DOE-Portsmouth site? For example, if Portsmouth were to become a D&D site, would it still be 

a good location for this facility? How does the storage of this material fit in with the current mission 

of Portsmouth to clean-up the current contamination at the site and potential re-use of the site for 

future industrial purposes? 

Response: PORTS is an active DOE site with a uranium mission. It is not anticipated that interim 

warehousing of these uranium materials would adversely affect DOE’s ability to conduct its other 

mission requirements at the site nor would this action interfere with ongoing cleanup efforts. 

40. US DOE should evaluate the long-term storage of the uranium material at a facility such as the 

Nevada Test Site. The material could be easily obtained if it is determined to be of economic value 

and should US DOE determine that it is a waste the material may not have to be moved again for final 

disposition. Storing the uranium material in this manner may save the US DOE valuable economic 

resources. 

Response: The Nevada Test Site (NTS) handles some forms of nuclear waste for the Department. 

The uranium materials evaluated in this PEA are not wastes and would not be appropriate to be 

stored at the NTS. 

41. Please state if the material will be tested for evaluation of RCRA characteristics including TCLP prior 

to shipping and storing the material to ensure that it meets regulatory requirements? Prior to shipping 

US DOE should make this evaluation to avoid potential regulatory issues at the site. As you are aware 

this site is not permitted to accept any hazardous waste from other facilities, to do so would be a 

violation of the permit. 

Response: Uranium materials are evaluated prior to acceptance by the UMG for shipment. UMG 

does not accept any materials that are determined to be waste. Therefore, the RCRA/TCLP testing 

would be unnecessary. In addition, these materials are “source materials” as defined by the Atomic 

Energy Act of 1954, and are exempt from the requirements by RCRA. 

42. If additional buildings/space will be needed for this effort, US DOE should coordinate with SODI in 

an effort to make the best future use of buildings. 

Response: Should an alternative be selected involving the PORTS site, the UMG Program commits 

to using the existing UMG storage facility. 

43. US DOE should evaluate who the likely users of the material may be prior to shipment to Portsmouth. US 

DOE should avoid shipment of material over long distances for storage only to have the material re-locate 

to a user near its origin (e.g. shipping the material from the Hanford Facility to Portsmouth then back to a 

western user). Conducting this type of evaluation up front will save US DOE economic resources as well 

as avoid potential risks associated with transportation of this material over long distances. 

Response: Comment noted. 
01-217(doc)/093002 D-60

Larry Scaggs 

Seal Township 

Pike County Ohio Trustees 

44. I am writing on behalf of the Seal Township, Pike County, Ohio, Trustees to oppose the DOE 

bringing in wastes from other sites to store at Piketon. The Piketon Gaseous Diffusion Plant is 

partially located in Seal Township. I am also a Board Member of the Southern Ohio Diversification 

Initiative. 

Response: The UMG has no intent to accept waste materials. 

45. DOE has called this waste a valuable material, but cannot explain how or why it is valuable. 

Furthermore, by bringing this waste to Piketon, 157 other sites will be cleaned up. We want to know 

why 157 other communities are more important than Piketon. 

Response: See response to comment #5. Since the uranium materials at all 158 sites listed in 

Table 2.1 are product and not a waste, the other 157 sites are not being “cleaned up.” DOE is 

attempting to consolidate the materials to increase efficiency and reduce costs. 

46. I do support projects that accelerate the cleanup of the Piketon site and provide a safe environment for 

our residents. The DOE should build and operate the DUF6 plant and accelerate cleanup of the lands 

and buildings, such as the 340 acres SODI tried to get for economic development. These project 

benefit the community be creating jobs and cleaning up our environment. Storing waste here for 20 

years does not. 

Response: Comment noted. 

Teddy L. West 

Scioto Township Trustee 

47. I am a Scioto Township Trustee elected by the residents surrounding the Piketon gaseous diffusion 

plant, a member of the Southern Ohio Diversification Initiative Board of Directors, and owner of 

property adjoining the Piketon gaseous diffusion plant. I am opposed to the storage of uranium waste 

that is described as “reusable material” in the draft programmatic environmental assessment 

DOE/EA-1393. As a neighbor of the plant and representative of the people surrounding the plant, I do 

not want our community to become DOE’s dumping ground. How can you tell our community that 

the waste is valuable material, yet you can tell the other communities that the material is a waste and 

they are now cleaned up? As a SODI Board member and Scioto Township Trustee, I support projects 

that will benefit our community by providing jobs and a safe environment for our people. We want 

DOE to accelerate cleanup, building the DUF6 plant, transfer land to SODI, and bring new 

enrichment technology to Piketon. 

Response: Comment noted. The uranium materials evaluated in this EA are potentially re-usable 

and, thus, valuable materials. They are not wastes. 
01-217(doc)/093002 D-61

Gilbert D. Drexel 

Manager of Projects 

Portsmouth Site Office 

48. Sec. 1.1 (“Purpose and Need for Agency Action”, pg. 1-1). We suggest that the paragraph be revised 

by adding a new sentence (shown in italics), so that the paragraph reads as follows: 

“The U.S. Department of Energy (DOE) proposes to implement a comprehensive management 

program to safely, efficiently, and effectively manage its potentially reusable low enriched uranium 

(LEU), normal uranium (NU) and depleted uranium (DU). Uranium materials which are presently 

located at multiple sites are to be consolidated by transporting the materials to one or several storage 

locations, to facilitate ultimate disposition. Management would include the storage, transport, and 

ultimate disposition of these materials.” 

Response: Text added as recommended. 

49. Sec. 2.2 (“No Action Alternative”, pg. 2-9). In the last sentence in the paragraph, suggest changing 

“disposed” to “dispositioned”. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

50. Sec. 2.3 (“Proposed Action”, pg. 2-9). In the first paragraph, we suggest that the 1st sentence be 

revised to create two sentences, to read, “DOE proposes to implement a long-term (greater than 20 

years) management plan for its inventory of potentially reusable LEU, NU, and DU. Uranium 

materials which are presently located at multiple sites are to be consolidated by transporting the 

materials to one or several storage locations, to facilitate ultimate disposition. 

Response: Text changed as suggested. 

51. Sec. 2.3 (“Proposed Action”, pg. 2-9). In the third paragraph, suggest revising the first sentence to 

read, “DOE must determine the safest, most effective, and most efficient approach for the 

consolidation and storage of this material.” 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

52. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The 1st paragraph currently reads as follows: 

“Normal operations result in no more than negligible acute or chronic consequences and risk at any 

site under any storage alternative or disposition option. Environmental impacts associated with 

normal operations vary substantially from alternative to alternative and, occasionally, by site within a 

given alternative. General handling accidents result in no more than negligible acute or chronic 

consequences and risk at any site under any storage alternative or disposition option. Chronic human 

health and ecological consequences and risk are negligible to low for all sites under all alternatives. 

The highest transportation consequences are for alternatives that involve moving uranium materials to 

a western location, either to a commercial site or to INEEL.” 

We suggest that this summary paragraph be reworded to more broadly discuss the PEA’s 

conclusions. The conclusion/summary as we see the overall PEA analysis is that there were noneto-minor impacts for all of the alternatives from the standpoint of environmental impact; negligible-
01-217(doc)/093002 D-62

to-low impacts from the standpoint of facility accidents (fire and seismic) for all the alternatives; 

while transportation effects for the alternatives generally reflected the extent of material 

transport associated with the alternative being analyzed. The overall conclusion is that potential 

impacts appear not be significant for any of the material consolidation alternatives which were 

analyzed. 

Response: Text in the Summary and Conclusions in the PEA has been modified. Should DOE 

determine that a Finding of No Significant Impact (FONSI) is warranted, the FONSI will be where 

“significance” of impacts will be discussed. 

53. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. We also suggest that discussion be added to the 

paragraph to summarize the reasons for proposing the PORTS option, given that at least one other 

option (i.e., the partial consolidated storage at several DOE sites) is forecast to have a less 

expensive construction cost. The reasons for proposing the PORTS option, are that a single 

consolidated storage location affords greater flexibility and ease of future disposition of the 

material, and reduces the overall expected future cost for facility surveillance & maintenance 

(S&M) and material accountability/material S&M, than if the material was at several locations. 

These benefits outweigh the potentially greater up-front renovation/construction costs. 

Response: Comment noted. The focus of the PEA is to address the potential environmental 

impacts associated with each of the alternatives considered. The PORTS site due to the existence 

of sufficient storage space to accommodate the entire uranium inventory under consideration has 

the least environmental impacts of a single consolidated storage site. DOE can consider factors in 

addition to environmental impacts when making an agency decision. In addition to those noted in 

the comment, PORTS has a work force trained in handling uranium materials and a very recent, 

successful experience in storing uranium materials from the Fernald and Hanford sites. 

54. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. Consideration should be given to adding an overall 

summary table (example attached). 

Response: Comment noted. 

55. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The statement that “environmental impacts ...vary 

substantially from alternative to alternative” appears inconsistent with the analysis, which indicated 

that for all the alternatives, the environmental impacts were negligible, minimal, or at most minor. 

“Vary substantially” seems to imply that there are significant impacts, when the analysis says there 

were none or minimal. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

56. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The statement that “General handling accidents 

result in no more than negligible acute or chronic consequences... appears correct, based on the 

analysis. However, “general handling” is part of “normal operations” – which from the 1st sentence 

have no impacts. It is unclear as to why the extra emphasis is being given to the impacts from 

“Normal operations”. 

Response: The PEA addresses both accident conditions and normal operations (meaning those 

situations and activities in which accidents are not occurring). Normal operations, including 

general handling accidents, have no more than negligible acute or chronic consequences. 
01-217(doc)/093002 D-63

57. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The paragraph omits discussion of the negligibleto-low risk associated with facility accidents (fire and seismic). 

Response: Text added to Section 4.11.1. 

58. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. The 3rd paragraph currently reads as 

follows: 

“In addition to surface contamination, radiation dose from the stored uranium materials can be 

expected. Dose rates from any single stored container are no more than 3 to 4 mrem/h. The dose rate 

at a distance of 0.3 m (ft.) from a container is about 1 mrem/h, and the dose rate at a distance of 6 m 

(20 ft.) is < 0.5 mrem/hr (approximately the same as normal background radiation doses). These dose 

rates are not affected by stacking the containers, because the containers and the materials themselves 

provide substantial shielding. These dose rates are considered negligible to any receptor (facility 

worker, co-located worker, or public).” 

Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. Suggest specifying whether the “3 to 

4 mrem/h” dose rate is “on contact”. Also, we suggest to citing the basis for indicating the dose is 3 – 

4 mrem/h maximum. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

59. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. Based on calculations, a dose at 6 m 

(20 ft.) would be < 0.05 mrem/hr. Suggest using “<0.05 mrem/hr” – rather than “<0.5 mrem/hr.” 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

60. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. It is unclear as to what the 

information in the parenthesis – “(approximately the same as normal background radiation doses)” 

refers to. If what is being referred to is 0.5 mrem/hr, this would not seem to be “approximately 

background”, as 0.5 mrem/hr at 2000 hrs/year would result in 1 rem/yr., which exceeds background. 

On the other hand, if what is being referred to is 0.05 mrem/yr, then this does more closely 

approximate background. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 

61. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. The phrase “dose rates not affected 

by stacking the containers” is somewhat unclear. “Stacking” typically refers to one container on top 

of another. We would think that dose rate would be affected if there were multiple containers stacked 

on top of each other, or containers side by side. The next statement regarding containers providing 

shielding seems to be referring to the containers behind one another – not container “stacking”. 

Suggest clarifying whether we’re referring to “stacking” containers on top of one another, or those 

behind each other. Overall, while there may be mitigation of dose from shielding, it would also seem 

that there could be dose contribution from adjacent or stacked containers. 

Response: This comment presumably refers to the text in the Preliminary Draft PEA (internal 

DOE review copy). This change has already been made in the Draft PEA. 
01-217(doc)/093002 D-64

The assumption is that the shielding (side-by-side locating of containers) cancels out the two-deep 

stacking of containers. However, for the purposes of calculating doses to the public, the more 

conservative assumption of no shielding is used. 

62. Sec. 4.2, “Consequences Common to All Alternatives”, pg. 4-3. The conclusion that “these dose rates 

are considered negligible to any receptor” may be correct, but it is not clear from this paragraph how 

this is so, given the above comments. 

Response: Corrections and clarifications made in the Draft PEA hopefully make this clear. 

63. Sec. 4, “Consequences” – General. Consideration should be given in Sec. 4 (“Consequences”) to 

adding specific Appendix references so that the reader can easily trace the amounts given in Sec. 4 

back to where the amounts were calculated and appear in the appendices. As an example, for the 

“transportation effects” amount shown in table 4.17, add a reference or footnote to indicate where 

these amounts are shown in Appendix B (“Transportation Analysis”). 

Response: Chapter 4 addresses the environmental consequences of the various alternatives. 

Detailed information supporting the chapter 4 discussion is contained in various appendices, to 

which the reader is directed for more detailed information. 

64. In Sec. 4 (“Environmental Consequences”), in the “Impacts” tables – tables 4.3, 4.6, 4.9, 4.13, 4.16, 

and 4.19 – the cost of upgrades appears in each table. This is referred to in each table as 

“construction/upgrades cost”. From the methodology (Sec. 4.1, “Methods”, 2nd paragraph, pg. 4-1), 

it appears that the intent of these cost figures is that they include not only the cost of 

construction/upgrades but also the cost of surveillance & maintenance (S&M). However, it is 

not clear that S&M costs – either facility S&M or material S&M (which would also 

include maintaining nuclear material control & accountability) – are fully included by this 

approach. 

Response: The cost numbers in the tables cited are for construction costs only. They represent a 

one-time impact occurring over a short period of time (assumed to be one year). As such these 

costs help demonstrate the socioeconomic differences among the various alternatives. They are 

used to estimate job creation and to quantify the effects of the action on the economic region of 

concern. S&M costs are not included; however, the number of permanent workers is estimated. 

65. Sec. 4, “Consequences” – General. It may be more appropriate to base facility and material S&M 

costs on the total square footage of storage space for the material – not just on the upgraded space. 

The conclusion that would likely emerge is that there would be a significant cost component 

associated with S&M, at each facility where material would be stored. Eliminating this duplicative 

S&M cost at multiple storage facilities would appear to be a strong supporting rationale for the 

proposed approach – consolidating material at a single DOE site. Consideration should be given to 

discussing these S&M costs and/or including S&M costs in the affect “impact” tables. 

Response: See response to previous comment. 
01-217(doc)/093002 D-65

Harry Rider 

Vice Chairman 

Pike County Board of Commissioners 

Waverly, Ohio 

66. This proposed action raises numerous concerns. Specifically, safe transportation concerns, and 

security of all material at the Piketon Plant is in question. Health of workers, residents and 

environmental safety issues are also of major concern. 

Response: Comment noted. Transportation, facility accidents, and normal operations have been 

evaluated for all alternatives with risks to workers and the public identified. 

67. The perception of Pike County, our home, being a national dump site for the governments excess 

waste is appalling, to say the least. 

Response: Comment noted. The uranium materials evaluated in this PEA are not wastes but 

potentially reusable materials. 

68. This project has no financial, environmental, education or social benefits to Pike County and its 

people. For these reasons, I am very much opposed to bringing any material to Piketon for storage. 

Response: Comment noted. To date approximately $5.7 million dollars have been spent at 

Portsmouth for previous uranium management activities. It also provided five direct jobs and 

numerous indirect jobs for the area. 

Tom Reiser 

Vern Riffe, III 

Opal M. Spears 

Scioto County Commissioners 

69. Whereas, the Scioto County Board of Commissioners believe the storage of this excess uranium and 

the marketing of these materials over a 20+ year time frame will have a negative effect on our current 

and future marketing of the PGDP and GCEP sites for re-use and on the marketing of industrial sites 

for new business development in south central Ohio. 

Response: Comment noted. 

70. Whereas, the Scioto County Board of Commissioners also have a matter of concern over the 

downgrading of security forces at the PGDP in recent years. 

Response: Comment noted. 

Lee A. Barclay, Ph.D. 

Field Supervisor 

U.S. Fish and Wildlife Service 

U.S. Department of the Interior 

71. The draft PEA does not include copies of correspondence requesting informal Section 7 consultation 

with U.S. Fish and Wildlife Service (Service) Ecological Services Field Offices in Ohio, South 
01-217(doc)/093002 D-66

Carolina, or Idaho. Service personnel have reviewed the information submitted and offer the 

following comments relative to the PGDP in McCracken County, Kentucky and the Oak Ridge 

Reservation (ORR) in Roane and Anderson Counties, Tennessee, for consideration. 

Response: DOE sent letters requesting informal consultation to subject USFWS offices on May 20, 

2002. Copies of these letters and letters of response have been added to Chapter 7. 

72. The description of Federally endangered and threatened species present in the vicinity of PGDP 

(Section 3.2.5) generally reflects information provided by this office to DOE on February 23, 2001. 

The evening bat (Nycticeius humeralis) does not currently have Federal protection pursuant to the 

Endangered Species Act. 

Response: Text in 3.2.5 was modified. 

73. According to our records, the following federally listed endangered species are known from or have 

the potential to occur within the project impact areas on the ORR: 

gray bat Myotis grisescens 

Indiana bat Myotis sodalis 

pink mucket Lampsilis abrupta 

We recommend that qualified biologists assess potential impacts and determine if the proposed ORR 

alternative may affect the species. We recommend that you submit a copy of your assessment and 

finding to this office for review and concurrence. A finding of “may affect” could require the 

initiation of formal consultation procedures. 

Response: Text in Sections 3.3.5 and 3.4.5 has been modified to reflect information provided. Since 

the potential acreage to be impacted would be in the middle of already industrial sites, it is 

reasonable to assume the potential for impacts to the species noted above is virtually non-existent. 

A Biological Assessment was prepared and sent to your office under separate cover; it is also 

included as part of the agency correspondence in Chapter 7 of this PEA. 

74. Since the Portsmouth Gaseous Diffusion Plant has been tentatively selected as the preferred 

alternative storage location, we recommend that the ecological resources section of this draft PEA 

referenced above be modified to accurately reflect the current extent of knowledge regarding 

biological/ecological resources of the Y-12 and ETTP areas, including East Fork Poplar Creek, Poplar 

Creek, and the Clinch River. 

Response: See response to comment #73. 

75. Since the American robin (Turdus migratorius) was modeled in the risk assessment in Appendix C of 

this draft PEA and given the responsibilities placed on Federal agencies by Executive Order 13186, 

we believe it would also be prudent to include discussions regarding migratory birds. 

Response: The interior forest habitat required by many species of migratory birds has been 

evaluated for the Oak Ridge Reservation with particular emphasis on the lands surrounding the 

ETTP site (SAIC 2002, Draft Land Use Technical Report, June). The proposed action would not 

affect interior forest habitat and the bird species that utilize them at any of the DOE sites. Some 

migratory birds, such as the American Robin, use more open, often man-altered habitats. It is 

possible that new construction in the middle of these industrialized sites could affect the foraging 

and nesting areas for some migratory bird species. 
01-217(doc)/093002 D-67

James A. Brushart 

Chairman 

Pike County Board of Commissioners 

Waverly, Ohio 

76. In Pike County, we are trying to pick up the pieces and make economic development attractive. If we 

are made a dumping ground for the governments waste to be stored, this will severely hamper any 

possibilities of economic development in the future. Pike County would be recognized as a national 

dumping site for waste, thus creating a more negative image of Southern Ohio. 

Response: Comment noted. The uranium materials covered by the proposed action are potentially 

re-usable and would be stored temporarily until they could be dispositioned. These materials are 

not wastes. 

77. In closing, I ask you on behalf of thousands of Pike County Constituents, to please take your waste 

elsewhere. I challenge the Department of Energy to do something good for Pike County and its 

people. We certainly deserve much better treatment than what we have received in the past. 

Response: Comment noted. 

H. E. King 

8339 SR 139 

Minford, Ohio 45253 

78. Please please don’t let Washington and Cincinnati dump excess uranium at the Portsmouth Diffusion 

Plant in Pike County. Southern Ohio has a rate of more cancer here than any place of the U.S. We 

have fought for years to have it cleaned up. EPA says its safe one month and unsafe the next month. It 

is densely populated in this area. There are many other places to take it like Idaho Falls and Hanford, 

Washington and others more safe. We do not want it here and pray you don’t dump it on us. 

Response: Comment noted. 

Cindy Newsom 

2315 Grandview Avenue 

Portsmouth, Ohio 45662 

79. I am writing in response to the June 7, 2002, article in the Portsmouth Daily Times. I would like to 

strongly suggest that you find somewhere else to store your material (other than at the Portsmouth 

Gaseous Diffusion Plant). I support Rep. Ted Strickland when he said, “You can’t trust them 

(DOE) on anything they’ve said to us. They’ve lied to us before.” I do not think that using PGD 

Plant is in the best interest of our area – we have enough problems without needing dumped on 

with nuclear waste. I don’t believe the DOE will “re-use” or re-sale the material. A dump site is a 

dump site. 

Response: Comment noted. 
01-217(doc)/093002 D-68

D. E. Culver 

878 Shawnee Road 

W. Portsmouth, Ohio 45665 

80. No! No! No! No more excess uranium or any uranium at Portsmouth Gaseous Diffusion Plant. 

We’ve had this killer here since the 50’s. No More. The fish in Scioto River are covered with sores, 

the bottom feeders are already dead. The wells are contaminated. The trees are dying. People are 

dying – go to hospital in Columbus nurses ask “Where are you from?” Your reply “Portsmouth”. 

Their response “Oh the Cancer Capital of the state.” 

Response: Comment noted. The risks to the workers and general population from transportation 

and interim storage of these materials at each site, including PORTS, were determined in the PEA. 

The risks were negligible to low. 

81. You clean this killer up at Fernald and Hanford and ship it someplace else to contaminate another 

place. How stupid can you get? For years you’ve talked “Jobs” well you know what you can do with 

your “Jobs”. 

Response: Comment noted. 

Norman A. Mulvenon 

Chair 

LOC Citizen’s Advisory Panel 

82. The CAP reviewers find the document poorly written and the alternatives presented in an unclear and 

confusing manner, such that the average reader cannot make an intelligent evaluation. It appears that 

no quality assurance was performed on this document prior to release for public comment. At the very 

minimum, the subcontractor, Science Applications International Corporation, should have read their 

own material for content and used the appropriate annotated outline to guarantee that all text material 

was included and properly organized to allow proper evaluation. At the maximum, all involved 

parties as listed on page 6-1 should have properly reviewed and vetted this document. The CAP’s 

primary recommendation is that DOE retract the document and have it internally reviewed, rewritten, 

corrected, amended, and then re-issued for public comment. 

Response: Comment noted. 

83. The PEA lacks an Executive Summary. 

Response: A Summary and Conclusions section (4.11) summarizes many aspects of the PEA results. 

An Executive Summary is not required for a PEA. 

84. The preferred alternative – Portsmouth – is not stated until pages 2-10. Even then, it is unclear 

whether this is the preferred alternative of all alternatives or only of the DOE sites under 

consideration. The PEA should present the compelling rational for the preference. The reasons listed 

are not “unique” as most are applicable to the Y-12 National Security Complex also. 

Response: Section 2.3.1 is the appropriate section in which to address PORTS as the preferred 

interim storage location. DOE’s preferred alternative is to locate these materials at PORTS; thus, it 

is preferred among all the alternatives not just among the DOE sites. The combination of the 

characteristics listed in Section 2.3.1 makes PORTS preferred. The word “unique” has been deleted 

from the text in Section 2.3.1. 
01-217(doc)/093002 D-69

85. The various alternatives are not numbered or consistently named in such a way as to easily identify 

them for comparison. The various alternatives also appear in random order throughout the document 

causing additional confusion for the reader. An example of this is the final interim storage alternative 

listed in Table 2.2 “interim partially consolidated storage based on physical form” which is apparently 

the same as “Interim Partially Consolidated Storage at Several DOE Sites” in Section 4.11.1, 

Comparison of Alternatives. 

Response: The order in which the alternatives are evaluated in Chapter 4 parallels the order in 

which they are introduced in Chapter 2. The reference to “One DOE site” in the alternative title 

has been changed to “a Single DOE site” to be consistent. The discussion in Section 4.11, “Summary 

and Conclusions,” addresses the alternative with the greatest potential for environmental impacts 

(Interim Storage at a Single Commercial Site) first and the alternative with the least environmental 

impact (No Action) last. 

86. There are errors or unexplained inconsistencies between the final interim storage alternative listed in 

Table 2.2 “interim partially consolidated storage based on physical form: and the unnumbered, 

unnamed table in Section 4.9 that shows the storage plan for materials based on physical form. 

Response: Table 2.2 has been corrected. The referenced material in Section 4.9 is intended as text 

not a table. 

87. NU in the acronym list is defined as normal uranium. The definition used in Appendix A, page A-iv 

is natural uranium. The terms “natural uranium” and “normal uranium” are interchangeably and 

randomly used throughout the EA text and appendices. This is confusing to the reader and technically 

inaccurate, as “natural uranium” is the proper term. 

Response: The definitions will be changed to reflect the following: Natural uranium, as found in 

nature, is unaltered isotopically with an isotopic content of 0.711% 235U. Normal uranium contains 

the same percent of 235U as occurs in nature, but the 0.711% 235U signature may have been attained 

by blending uranium of different isotopic compositions or by processing in a gaseous diffusion 

cascade. 

88. The missions of the various sites for storage were not properly considered. 

• Portsmouth is no longer used as a gaseous diffusion facility and its future role may be limited to 

being one of the two sites for a conversion plant for depleted uranium hexafluoride (Paducah 

being the other site). 

• The three sites at Oak Ridge are lumped together in Table 2.1 and Oak Ridge is the only 

designator listed in later tables. In reality, the three major DOE sites in Oak Ridge have separate 

missions and two of the sites are not suitable for the proposed storage mission. ETTP is a closure 

site, and DOE has stated an intention to transfer the site to other ownership by 2008. ETTP 

should not even be on the list of alternatives, in that there is no future DOE mission contemplated 

once the site is cleaned up and closed. ORNL is listed in Table 2.1, but then is not included in any 

of the analyses. As a national laboratory, it is a poor candidate for a storage site. 

Response: Section 2.1, “Background,” discusses the historical missions of the various DOE sites. It 

was noted (p. 2-2) that ETTP is undergoing reindustrialization, D&D, and environmental 

restoration. ETTP is a DOE site; DOE has not transferred the land. Thus, DOE believes that, under 

the NEPA, the ETTP would be a reasonable site. The intent of Table 2.1 is to show where the UMG 

uranium inventory is located; 1,445 MTU are located at the three DOE sites in Oak Ridge. Later in 
01-217(doc)/093002 D-70

the EA, DOE explains that both ETTP and Y-12 (but not ORNL) are considered as potential 

interim storage sites. 

89. Information is scattered and difficult to find in the PEA. For example, on page 2-3 it is stated that the 

uranium trioxide at SRS is not considered within the scope of this PEA. We don’t learn why (that 

these oxides are not part of the UMG inventory) until page 4-21. 

Response: Text on page 2-3 clarified. 

90. The option of transportation by barge is not evaluated. 

Response: Comment noted. This option was not evaluated because it is unlikely that the material 

would be transferred by this mode of transportation.

91. The PEA doesn’t seem to focus on the most logical analysis of alternatives for interim storage. This 

would be the consolidation of uranium at sites with compatible enrichment forms or with potential 

future uses. Some examples: 

1. Portsmouth and Paducah will both have facilities for conversion of depleted uranium hexafluoride 

to oxide or metallic forms. Either of these locations would be a logical choice for the national 

stockpile of DU. 

2. Paducah has a continuing mission of gaseous diffusion enrichment of uranium for commercial 

nuclear fuel. It would be a logical location for the storage of LEU. 

3. Y-12 has exceptional capabilities for handling and storing HEU, and could act as a repository for 

any of the forms, particularly those that are more reactive such as metallic uranium. Because 

proposals for future disposition of HEU include down-blending to a lower enrichment, Y-12 

might be a logical place to store compatible forms that could be used for this purpose at a later 

date. 

Response: Comment noted. Each of these facilities was evaluated in the PEA. 

92. The transportation analysis relies too heavily on computer modeling without actual analysis of the 

existing roads. Portsmouth is not accessible by interstate and for this reason would be a poor choice 

for storage of all forms/enrichments, making it a hub for a major shipping campaign involving 

sensitive cargos. It is more logical to minimize transportation on secondary roads and express a 

preference for sites close to interstate highways or other major bulk transportation options (rail or 

barge). In particular, if multiple shipments of a particular form or enrichment to a variety of end users 

are likely, the preferred storage location should weigh access to good transportation routes more 

heavily. 

Response: Comment noted. The transportation analysis focused on the potential environmental 

impacts associated with shipment of the uranium materials. 

93. With so much uncertainty about end states, one wonders why DOE has undertaken an assessment at 

this time. It also makes little sense that DOE’s huge stock of depleted uranium hexafluoride in 

cylinders – soon to be converted to a more stable chemical form – is outside the scope of the PEA. 

Response: Comment noted. An EIS is being prepared for this DUF6. The UMG inventory of 

uranium does not include UF6. Other forms of uranium that are included in the PEA have been 

addressed. 
01-217(doc)/093002 D-71

LOC/CAP Member 

94. I also find the document exasperating, in that information is either not there or hard to find. I haven’t 

found the form the uranium is at the various sites. With so much uncertainty about end states, one 

wonders why DOE is bothering with an assessment at this time. Particularly when the gorilla of 

depleted uranium hexafluoride in cylinders appears to be outside the scope. 

Response: Information on the form of uranium at various sites is in Table 2.2, page 2-5, under the 

“Interim partially consolidated storage based on physical form” alternative. 

The uncertainties associated with final disposition do not preclude the need for DOE to find a more 

efficient management plan for its UMG inventory in the interim. 

Larry R. Hurley 

(email)—no address or affiliation provided 

95. Feedback: I’d like to see this material stored at the Yucca Mountain site (along with all the rest of the 

nation’s nuclear materials). 

Response: Comment noted. 

Lee Poe 

(email)-- no address or affiliation provided 

96. I am reading the PEA on uranium and I find that it doesn’t include most of the uranium at SRS. 

Please provide me with the rational on why the uranium selected was selected and why other uranium 

at DOE sites was not included? On the surface it sounds like the PEA should consider all of DOE’s 

U. (Please note that this comment has been modified because of security concerns.) 

Response: The material selected for consideration is viewed to be high quality, stable material with 

a substantial volume for potential reuse. 

97. Why was UF6 not covered in the EA? 

Response: It is outside the scope of the Department’s analysis for this PEA. UF6 is being addressed 

in an EIS. 

98. Was scoping performed on this NEPA document? If so, please send me the scoping document 

summary. 

Response: Scoping is not required for a PEA. 

Kathleen E. Trever 

Coordinator-Manager 

INEEL Oversight 

99. In stating a need for this EA, DOE emphasizes increasing budget pressures, good stewardship of 

resources, and ensuring maximum cost-effectiveness. DOE does not, however, provide a clear 
01-217(doc)/093002 D-72

explanation of how its alternatives for moving materials around before deciding on their disposition 

addresses these goals. This explanation is essential to supporting a sound policy decision. 

Response: The consolidation of the potentially reusable DOE uranium material provides an 

opportunity to retain a valuable asset while supporting the critical mission of DOE nuclear facility 

closures. For example, in the case of the Fernald site, a sizable quantity of potentially reusable 

uranium had to be dispositioned in order to support the site clean-up schedule. Fernald’s review of 

the options for disposition of this material concluded that ~ $23M was saved in the shipment of the 

material to PORTS versus the site removal and burial option. In addition, Fernald estimated that if 

the PORTS option had not been available, the costs due to schedule delays may have exceeded 

$75M. Each of the UMG activities to date, and future UMG activities to relocate potentially 

reusable uranium, have/will utilize a deliberate decision-making process. 

100. Although DOE may be able to “bound” impacts based on hypothetical disposition paths, the 

geographical locations for disposition of the various physical forms could form a discriminator 

among alternatives that require transport, facility upgrade or construction. If, for example, there may 

be future activities using materials at their current or nearby location, it probably does not make 

sense to “consolidate” them elsewhere. 

Response: DOE makes decisions based on the best information available at the time of an action. If 

changes occur in the future, previous decisions will be re-evaluated to determine if adjustments 

need to be made. The PEA is an input to these future decisions. 

101. To support a sound decision, DOE should also provide information as to whether other activities at 

the storage facilities in question would still require similar monitoring or upkeep regardless of 

whether the reusable uranium materials remain. To enable fair evaluation of the alternative for 

consolidation by physical form versus solely geographical approaches, DOE should also provide 

information as to how physical form can relate to ultimate disposition, as well as identifying any 

differences in interim storage needs. 

Response: DOE estimated the manpower required to monitor the storage sites. Under the No 

Action alternative, the current level of monitoring would presumably continue at the various sites. 

At PORTS the existing buildings proposed for storage, under several alternatives, would have some 

level of monitoring if none of these alternatives is selected and the buildings continue in their 

present state. The level of monitoring for present uses was not estimated but is assumed to be 

similar to the proposed action. 

Regarding consolidation by physical form, DOE has received inquiries and expressions of interest 

in some of the uranium materials in the UMG inventory; however, there is not sufficient certainty 

in the final disposition paths to allow a detailed analysis. 

102. The document’s simplified assumptions prevent much quantitative analysis, but do allow some 

qualitative comparisons. 

Response: Transportation risks, various accident scenarios, and socioeconomic impacts (including 

construction costs, permanent and temporary jobs, and acres potentially affected by new 

construction) have been quantified using a variety of assumptions documented in the PEA. 
01-217(doc)/093002 D-73

103. The fundamental, outstanding question left by the EA, however, is to what extent the alternatives can 

achieve DOE’s stated purpose of achieving management efficiencies. 

Response: The PEA addresses a portion of that question, namely what would be the expected 

environmental impacts of implementing the various alternatives. Estimates of construction costs 

are part of this analysis. DOE will also consider other costs, such as surveillance and maintenance, 

transportation, and facility upgrades, as well as other factors in reaching a decision on interim 

storage. 

Richard Demming 

104. All references to aircraft impact as shown on page 4-1, last paragraph, last sentence. This suggestion 

is made after the 9/11 attack. Replace references with external events. 

Response: Reference to aircraft impact has been removed. 

Steven T. Carter 

Executive Director 

Scioto County Economic Development Office 

105. The Scioto County Economic Development Office and the Scioto County Commissioners, along 

with U.S. Congressman Ted Strickland, are opposed to the siting of the 14,200 metric tons of reusable excess uranium from other DOE sites that are proposed to be stored at DOE’s Portsmouth 

Gaseous Diffusion Plant. Even though we are a rural/small city community, our region is densely 

populated. We believe there are other DOE sites that are much larger than our 3,700 acre site 

where these materials can be stored and marketed over time. We also believe the storage of these 

materials over a 20+ year time frame will have a negative effect on our current marketing efforts 

of the site for re-use and on the marketing of industrial sites for new business development in 

South Central Ohio. 

Response: Comment noted. More important than the size of the plant are the amount and 

availability of storage space and a trained/qualified workforce. PORTS has sufficient existing 

storage space to accommodate the entire 14,200 MTU inventory. PORTS is already storing 

approximately 4,500 MTU. However, as noted in the response to comment #4, the UMG Program 

commits to limiting use to the existing UMG storage facility. 

106. Another major concern has been the downgrading of security forces in both manpower and 

armaments of PGD’s security forces over the last several years. 

Response: Comment noted. 

W. Lee Poe, Jr. (Additional Comments—received after close of comment period) 

107. P2-1, 1st Paragraph. Broaden this paragraph to cover UO3 and state why UF6 is not included. This 

sets the stage for the NEPA document. 

Response: The information in this paragraph is general background and is not intended as a 

detailed list of what is included in the PEA. UF6 is not part of the UMG inventory because the UMG 

is seeking uranium materials with minimal nuclear safety requirements. A PEIS was prepared for 

DUF6, and a separate EIS is being prepared to further address DUF6. UO3 is included in the PEA. 
01-217(doc)/093002 D-74

108. Table 2.1 on P 2-2 should be expanded to include other uranium materials stored for reuse or 

disposition. 

Response: Text acknowledges that other uranium materials are at several DOE sites, which are not 

part of the UMG inventory and are not part of the proposed action. They are addressed as 

appropriate under the cumulative impacts analysis but are not included as part of the tables 

referenced. 

109. P 2-3 states most of the uranium is in the form of uranium metal. Where is this covered in the EA? 

How much of the 14,200 MTU is metal. EA should provide a table that provides the breakdown of 

the inventory into it associated form. 

Response: Table 2.1 provides the uranium management inventory (amount in MTU) at the various 

sites. Table A.3 gives some indication of types of uranium at the larger DOE sites. However, for 

security reasons, the exact amount by type is not shown for all sites. 

110. In the fourth paragraph on P 2-3 the SRS inventory is described as contained in wooden boxes, 

cardboard boxes for metal and drums for LEU Oxide. I was never able to determine if the EA 

contained environmental consequences from repackaging of that inventory. Later the EA discusses 

storage of drums and steel boxes. 

Response: The impacts associated with repackaging are covered in Section 4.2 of the PEA.

111. Figure 2.1 shows example storage of metal boxes and drum storage. This figure is unclear in the 

printed version of the EA. It is basically a black photo with a large white box in the center. When 

I looked at the electronic version, it was legible. Should be legible in all forms of the EA. The 

title of the figure should specify the multi-stack storage being discussed when the figure was 

called out. 

Response: Commented noted. The intent of the figure is to show the relative sizes of drums and 

boxes, which contain uranium materials. 

112. The No Action alternative described in Section 2.2 on P 2-9 should provide clarify the small site 

storage. How many sites are assumed to store this uranium and for how long? The last sentence says 

the uranium would not be dispositioned. In my mind this means very long term consequences and 

none were discussed in the EA. 

Response: The first sentence in Section 2.2 states that ongoing storage would continue at all existing 

facilities. The impacts of the No Action Alternative are discussed in Section 4.3. 

113. As already pointed out the scope of the EA needs be expanded to discuss the other uranium being 

stored and discusses in fifth paragraph on P 2-9. 

Response: Comment noted. 

114. The last paragraph on P 2-9 says the analysis associated with the action alternatives discusses the 

bounding assumption associated with disposition. There is very little additional information in the 

EA on the bounding assumptions. 

Response: The bounding assumptions are discussed in Section 4.10. Additional text has been added 

on waste streams. 
01-217(doc)/093002 D-75

115. P 2-10 in Section 2.3.2 says that DOE has not selected a commercial site for uranium consolidation 

in this alternative but for analysis purposes, a western and an eastern site were selected for the 

transportation analysis. Does the selection of Utah and South Carolina maximize transportation 

consequences? The justification for this selection should be given a few more sentences of 

description to convince the reader that this assumption is reasonable. 

Response: The selection of these two sites for transportation analysis does not result in the absolute 

maximum distance. The sites are realistic possibilities and serve as a “reasonable worst case.” More 

text was added to Section 2.3.2. 

116. The alternative for interim partially consolidated storage by physical form described on P 2-11 in 

paragraph 2.3.6 calls for SRS to be the metal storage site. I could find no information to support 

metal storage at SRS. In my technical judgment, metal storage has much larger consequence that 

does storage of oxides. As I indicated in my earlier letter, metal has a unique hazard, not analyzed in 

this EA, of metal fire potential which is exaggerated in long-term storage. 

Response: Comment noted. We found that oxides have a potential greater than metal for 

environmental impact in the case of an accidental release (from a fire, etc.). Powdered oxides are 

readily transported to the atmosphere and, subsequently, to a number of potential receptors in a 

fire scenario. 

117. Paragraph 2.4 discusses DOE's belief that uranium storage is a government asset. Two sentences 

later it says DOE might declare other inventory a waste. This seems to be a two-forked statement. 

This paragraph should be rewritten to eliminate this apparently inconsistency. I would really like to 

know what it is saying. What makes some uranium a national asset and other uranium a waste 

product? 

Response: Section 2.4 states that the uranium materials in the UMG inventory and, thus, part of 

this PEA are potentially re-usable. Therefore, the alternative of addressing them as waste is not 

considered further. This statement recognizes the fact that DOE has other uranium materials, 

which have been legally declared as wastes. 

118. Section 3 discusses the affected environment at Portsmouth, Paducah, Y-12, K-25 (both in 

Oak Ridge), and Savannah River Site. There is no mention of the other sites that currently store some 

of the uranium or those planned as alternatives for possible storing and managing uranium within 

this EA. These sites should be discussed in this section, but probably not in the detail of the five 

major sites. 

Response: The affected environment of sites DOE is considering for interim storage is discussed in 

Chapter 3. 

119. The Method’s section (P 4-1 in Section 4.1) says that 14 people are required for managing the 

uranium inventory. This seems like a low staffing level to manage 243,000 square foot of storage 

space with ~71,900 containers in storage. I could find no further information on what these personnel 

were assumed to do. If this uranium is a true national asset, it probably has the lowest surveillance 

staff of any of our national treasurers. The uranium management staffing should be reexamined. 

Response: The UMG staff would be primarily responsible for surveillance and maintenance, 

inventory tracking and related activities, and to some extent security. The UMG storage facility has 

been configured to require minimum staffing levels, and the storage of material has been 

established to ensure cost-effective service. 
01-217(doc)/093002 D-76

120. In the fourth paragraph of Section 4.1, I find the statement “worst case assumptions ... are 

employed”. As I have said, I do not think this statement is correct. One such statement is that 14 

people can manage this uranium. I will point out other assumptions I do not think appropriate as I 

proceed with these comments. 

Response: Comment noted. See response to comment #120. 

121. The EA should analyze and present sabotage scenarios. These might range from theft of uranium 

(remember it is a national asset) for its value to those that would blow it up to disperse the 

radionuclides and cause bad publicity. Those 14 people would not be able to prevent either. 

Response: Text has been added to Section 4.2. 

122. The third paragraph on P 4-2 lists Kd units as L/kg. Please correct the units on this term. 

Response: The units have been re-evaluated and have been determined to be correct. 

123. P 4-6 Table 4-3 lists PORT upgrade cost as $8.4M and the second paragraph says it is considered to 

be $10.9M. Please correct all tables listing the earlier value. The other values in the table for PORT 

should also be corrected. 

Response: On page 4-6, paragraph 2, the $10.9M refers to the PORTS construction costs if 

125,000 ft2

 of space is built new instead of using all existing space and upgrading it. While existing 

storage space is available, it seemed prudent to indicate what impacts could be expected if, for some 

reason, not all of this space could be used. Also, see responses to comments #2 and #6.

124. P 4-6. It is obvious that DOE from major sites other than PORTS and also at the minor site have not 

been consulted on this EA. I make this judgment based upon the many tables in this section have say 

space availability is unknown. This lack of communication with other DOE site personnel should be 

eliminated and the same level of knowledge applied for each site. The lead statement in the third 

paragraph on this page confirms the lack of communication. 

Response: All DOE sites considered for interim storage were consulted and specifically asked to 

provide information about existing space, which could be used for uranium storage. 

125. Table 4.5 (P 4-7), Table 4.7 and Appendix B need units added for the two columns giving 

transportation fatalities. Are these fatalities per year or per activity? 

Response: The columns for latent cancer fatalities and traffic fatalities are totals for all 

transportation required for a specific destination/alternative. Column headings have been revised 

to say “Excess latent cancer fatalities (total)” and “Traffic fatalities (total).” 

126. Section 4.7 on P 4-17 is a very weak analysis for disposition. As I indicated earlier in this set of 

comments and in my General Comments, the section talks about bounding conditions and impacts 

then makes an arbitrary statement that all they did was double the impacts of storage. If these are 

bounding, please explain how you know since no analysis was performed. 

Response: In Section 4.10, DOE states that a rough bounding of impacts would be to take the 

alternative with the greatest environmental impacts and double them; however, several factors 

would lessen this effect. These are then discussed in detail in the subsections that follow. 
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127. Third bullet on P 4-19 gives the $8.4M that was later changed to $10.5M. (See P4-6 comment.) 

Response: See response to comment #124. 

128. Combine the fourth and fifth bullets on P 4-19. They seem to be saying the same thing. 

Response: Comment noted. 

129. Expand the sixth bullet. It is not clear where the judgment came from. It says that commercial sites 

are less efficient than DOE sites. I continually hear from DOE that they want to do things using 

commercial approaches since it is more efficient than the DOE system. At best what does this add? 

Response: It is assumed that a commercial site would have to build the entire 243,000 ft2

 of storage 

space to accommodate this material. Thus, impacts from construction would be the greatest at 

commercial (and the PDGP) sites. 

130. Section A.2 describes overpacking all containers prior to shipping. Where are the environmental 

impacts of this action included in the EA. If they are not included, why not? 

Response: See Section 4.2. 

131. The last sentence on P A-2 says worker dose commitment from surveillance and maintenance of this 

uranium is expected to be less than detectable. I doubt this is a correct statement. The top paragraph 

on P A-4 goes on to describe the expected radiation dose from containers. These doses were 

detectable. The last sentence of this top paragraph goes on to make an unsupported conclusion. It 

says “these dose rates are considered negligible to any receptor”. What about doses to workers who 

purified this uranium and developed illnesses that DOE (or the government) is now paying for? 

Response: The intermittent nature of surveillance and maintenance activities, combined with a dose 

rate at 6 meters, which approximates background, would result in dose rates that are considered 

negligible. 

132. Second paragraph in Section A.3.1 on P A-4 uses a slang approach (1E-6) with no description of 

what is meant by that notation. Use the proper scientific notation then describe what it means. 

Response: Comment noted. 

133. As I read Section A.3.1.1 on P A-5, particularly the last couple of sentences, I do not know what 

conclusion you are trying to make. 

Response: Comment noted. 

134. Section A.3.1.2 on PA-6 describes a single container breach as being a bounding accident. This same 

event could breach multiple containers on adjacent pallets. Why then is a single breach bounding? 

Response: Section A.3.1.2 states that single-container handling accidents are bounding for the 

accident category “container breach” because these events dominate risk to workers. A container 

breach is not bounding for all types of accidents. 
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135. The next to last sentence in Section A.3.1.2 says that container breach is insignificant compared with 

a fire. Multiple drum ruptures are speculated above. The logic that shows fire is more significant 

than rupture should be clearly made or both analysis given. 

Response: Some fires can result in multiple containers breached whereas a forklift rupture or 

dropping of a drum would more likely result in a single container rupture. Also, fire provides a 

mechanism for airborne transport once containers are breached. Thus, a multiple container breach 

with fire to mobilize the uranium materials is a more serious accident than a single or multiple 

container breach without an associated fire. 

136. The basis for the frequencies given in Table A.7 should be given. 

Response: This is discussed in Section A.3.1.3. 

137. How can the frequencies for tornadoes at all sites be the same as shown on Table A.7? I likewise 

have the same comment for earthquakes. 

Response: The frequencies in Table A.7 are not the frequencies of earthquake or tornado 

occurrences at the DOE sites. These vary from site to site. Frequencies shown in Table A.7 indicate 

the threshold earthquake or tornado loading for which damage is expected from the event. The 

frequencies are the same because, for example, a higher-intensity earthquake at Paducah occurs at 

the same frequency as a lesser-intensity earthquake at Oak Ridge. 

138. P A-7. Describe your judgment of how long seismically damaged facilities will be left in the 

damaged condition while personnel repair other higher risk damaged facilities. This duration of 

exposure to the elements should be included in the analysis for these facilities. 

Response: Because the vast majority of the materials released would occur during and/or 

immediately after the seismic event, the assumptions used in the analysis will bound the risks. No 

estimate of how long damaged facilities would remain damaged is included in the analysis. It should 

be noted that depletion of the initial source term occurs over time, so the assumption of all material 

released during the initial phase of the event is conservative. 

139. P A-7 second paragraph references reinforced concrete and structural steel debris as fire mitigation. 

All storage facilities will not be constructed of concrete thus the concrete and steel should not be 

relied upon as a fire mitigator. It is unclear from the text of that paragraph how much reliance is 

afforded by this building material. 

Response: As noted in Section A.3.1.3, following a direct seismic event, a number of small fires may 

occur. No building structure is assumed to remain, and fire suppression systems are assumed to be 

totally destroyed. The buildings are assumed to be constructed of steel and concrete, and these 

materials, unlike wooden structures for example, would not readily support combustion. In 

addition, the debris and rubble act as shields to prevent the subsequent small fires from spreading 

and involving the entire stored material inventory. 

140. The second paragraph on page A-8 seems to use the MAR yet MAR is not given on Table A.8. 

Response: Your observation is correct. In order to reduce the complexity of the tables, the MAR 

and release factor values were not repeated in Table A.9. 
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141. The DRs in Table A.8 seem to be totally subjective. Support for the values used should be provided 

in this appendix. 

Response: References for release factors are given in Section A.3.2. 

142. The ARF × RIF values given in Table A.8 should be referenced. 

Response: References for release factors are given in Section A.3.2. 

143. Add a section describing storage facilities (similar to that given in Section 2 of the EA) to this 

appendix on page A-9 to support the analysis given in Section A.3.3.2. 

Response: Comment noted. The addition of this information will not affect the intent of the 

document. 

144. U metal is pyrophoric and when ignited, I would expect that all of the metal would be at risk. U fires 

are not easily extinguished. 

Response: Comment noted. The degree to which uranium material ignites depends on several 

factors, including the physical form. For example, uranium metal shavings are easily ignitable, 

whereas uranium metal in large ingots is not. This factor is included in the assignment of DR, ARF, 

and RF values for fires involving metals. 

145. The source terms discussed in the second paragraph are very subjective. Add information so your 

reader will understand why the values were picked. References, showing why values were picked, 

are always beneficial. 

Response: References for many factors have been provided. See responses to comments #142 and 

#143, for example. 

146. The frequency of facility fires is stated to be unlikely. Be more quantitative. Is this one chance in 

10 years or a frequency of 0.1/year. My judgment says it is a frequency of 10-4 to 10-6 is unlikely. 

DOE experience of fires is probably in the range of 10-2 to 10-3 and with the number of facilities 

described in this EA fires can be expected to occur during the time interval for this uranium 

storage. 

Response: DOE guidance for accident analysis states that qualitative estimates of frequency are 

sufficient and that a frequency range of 1E-2 to 1E-4/year is unlikely. This frequency applies 

independently to each storage location and alternative; it is not additive. 

147. In Section A.3.3.3 include the long-term consequences as well as short-term consequences. Material 

lost from containment during a seismic event will probably remain in an exposed condition (to the 

environment) for weeks and some of it will be transported to surface streams before the low priority 

uranium cleanup can be accomplished. 

Response: Comment noted. See response to comment #140. 

148. Identify the basis for the 10% and 15% of drums forecasted to be dislodged from the storage array in 

the first bullet on P A-9. 

Response: These assumptions are documented in the cited reference (Hand 1998). 
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149. The third bullet identifies 25% of the material spilled. What is the basis for value? If spilled what is 

assumed on cleanup and when. 

Response: These assumptions are documented in the cited reference (Hand 1998). 

150. Again metal fires should be considered in a seismic event consequences. 

Response: Comment noted. See response to comment #145. 

151. The second line on P A-10 uses the term conditional probability to reduce the risk from seismic 

event by a factor of 10. What is the basis for this factor of ten reduction. The arbitrariness of all of 

these values leaves the EA reader questioning the analysis. Try to support conclusions and not make 

them so arbitrary. 

Response: Comment noted. As noted on page A-10, this value is an estimate. 

152. Near the middle of P A-10, duration of 1 hour is assumed for airborne release. The longer-term 

aspects of resuspension of released material should be included for the time the material has not been 

cleaned up. 

Response: Comment noted. See response to comment #139. 

153. The third bullet, on P A-13, assumes the facility workers will be exposed for 10 seconds. This seems 

very short for workers who are trying to mitigate consequences or to a worker who is hurt from a 

seismic event and cannot escape. 

Response: The assumption of 10 seconds is standard for facility worker response to an accident 

(i.e., “see and flee” policies). Subsequent recovery actions are not included in accident analysis 

evaluations, as accident response personnel are adequately protected to respond safely to events. 

154. The conclusions given in Tables A.11 and A.12 that facility workers will receive negligible dose and 

maximum consequence seems inconsistent with co-located workers and the public receiving doses. 

Calculated values should be given in the Appendix so reviewers can make their own judgment as to 

its significance. 

Response: Comment noted. See, also, response to comment #154. 

155. Appendix C is very difficult to understand. It is full of technical terms and it is not written so it can 

be understood by a technically trained stakeholder and I do not think it is of any value to a decision 

maker or to the general public. 

Response: Comment noted. In order to provide a complete analysis, an assessment of chronic risks 

to humans and ecological receptors of airborne uranium deposited on soil and surface water and 

from water to sediment is provided in Appendix C. 

156. On P C-2, in Section C.2.1.1, need to say why Stability Category F was assumed. 

Response: Stability Category F was assumed because it is the most stable (results in least mixing or 

dilution) and, thus, provides the most conservative risk estimate. Text was added to Section C.2.1.1. 
01-217(doc)/093002 D-81

157. In Section C.2.2.2, why was the assumption made that uranium was deposited in a pond with an 

average depth of 2 meters? It would seem to me to be worse to deposit it in surface creeks that allow 

easy access to animals and other ecological system varmints. 

Response: Moving water, such as creeks, permits much more mixing (dilution) than a pond; thus, 

assuming standing water is a more conservative approach, which results in a greater potential for 

ecological impacts. 

158. Section C.3, on P C-9, makes the judgment that residential exposure is considered implausible under 

current site conditions. It is unclear that this is a reasonable judgment. Obviously if one can limit 

exposure, the consequence of this EA are negligible. This condition should be proven by reasonable 

analysis not assumed away. 

Response: The risks to residents were calculated and documented in Section C.3 even though such 

exposure is unlikely. Risks were not “assumed away.” 

159. The table set up of the summary tables (Table C.20 and C.21) is poor. I presume that the last three 

columns are Radiation Exposure. Likewise three columns are Chemical Exposure. Fix the tables so 

this differentiation is clear. Add units to the table. 

Response: Table headings have been clarified per comment. Hazard quotients (HQs) are unitless. 

160. My conclusion is that calculated data should be given in tables in the appendix so the reader can 

see the results of calculations. Information in the Appendix should not be decided to be low 

or negligible. That conversion is not appropriate here nor in Section 4 until the analysis is 

being summarizing. (This EA did not summarize the analysis in Section 4 nor did it have a 

Summary). 

Response: The numerical definitions of high, moderate, low, and negligible risks are presented in 

Section C.3.5. The summary tables in Appendix C use these word definitions instead of specific 

numerical values to aid reader understanding. 

R. L. Huskin 

Savannah River Operations Office 

161. Page 2-1, Section 2.1, 2nd Paragraph, 9th Line; The stated typical percentage of 235U in depleted 

uranium (DU) does not agree with the value shown in Table B.1 on page B-3. Page 2-1 says DU 

typically contains 0.25% 235U while Table B.1 says 0.10%. 

Response: The values citied in Table B.1 are the values used in the analysis. While the percentage 

differs from the typical DU of 0.25%, 235U use of 0.10% would produce only a very minor difference 

in the results. This was verified by re-running the analysis using 0.25% U235. 

162. Page 4-6, Section 4.4.1, 3 rd Paragraph; Paragraph states “DOE has not identified existing buildings 

at (sites other than PORTS) to accommodate these additional uranium materials at this time. 

Therefore, for analytical purposes, it is assumed new storage space would have to be constructed.” 

This begs the question of has DOE even made any attempt to identify such existing facilities at sites 

other than PORTS. Without any such attempt, it would appear any estimates, such as those shown in 

Table 4.3, would be wholly inaccurate and deliberately skewed in favor of PORTS. This hardly 
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appears to be an unbiased assessment of the adequacy and availability of sites about the DOE 

complex. 

Response: See the response to comment #125. 

163. Page 4-20, Section 4.12, 3 rd Paragraph, 1st Sentence; As written, the statement leaves the impression 

that uranium shipments will increase traffic accidents and fatalities because the cargo is uranium, 

rather than clearly stating any increase in such events would simply be the result of additional 

vehicles on the nation’s roads, regardless of cargo. 

Response: Text cited has been modified to clarify this point. 

164. Page 4-20, Section 4.12, 3 rd Paragraph, 3rd Sentence; I don’t believe this can be substantiated with 

the data presented. To state there would be an increase in LCFs to workers and the public from this 

transportation program, one must calculate both the potential LCFs resulting from the program and 

the LCFs potentially suffered by workers in the vicinity of the materials in a no-action alternative. I 

didn’t see any such estimate for the no-action alternative in Section 4.3 nor any table presenting 

estimated LCFs from incident-free operations such as presented in Table 4.1 for accidents. Therefore 

there is no comparison of the no-action alternative to the other scenarios to determine if there was a 

net increase or decrease in LCFs. 

Response: The text, as written, indicates that the increased LCFs are due to exposure during 

transport. Since the uranium materials would be stored somewhere under any alternative, 

including No Action, the transport risk is in addition to storage risks. 

165. Page A-12, Table A.10; The values, in meters, for the distance to site boundaries for several sites 

such as INEEL and SRS seem inappropriately low. Are values of 526 meters and 727 meters correct 

for INEEL and SRS, respectively? While not familiar with the assumed locations for the materials at 

these sites, I can say several sites, such as INEEL and SRS are very large, with site centers greater 

than 10 miles from their boundaries. 

Response: Because specific storage locations were not provided for several sites, a location central 

to roads, warehouses, and other similar facilities was postulated. Actual distances may be greater; 

however, the shorter distances used in this analysis are conservative.

166. Page B-2, Section B.3, 8th Dot; I believe the estimated duration of 10 days grossly underestimates 

the likely transit time for 14,400 km. This would equate to an average vessel speed of 33 knots. I 

don’t believe you’ll find many freighters with such speed. The ones currently in use for transporting 

foreign research reactor spent nuclear fuel back to the U.S. typically are capable of only about 

11-12 knots. Only about 1/3 of the apparent speed of the uranium carriers. If one were to state the 

distances may range from X to 14,400 km with an average of about 5,000 km, an average transit time 

of 10 days would seem much more reasonable. 

Response: The text has been changed to indicate that 14,400 km is the maximum distance 

port-to-port. The dose to crew members is now stated in mrem per person per day to account 

for various distances of shipments. 

167. Page B-3, Table B.1; See 1st comment concerning page 2-1. 

Response: The values cited in Table B.1 are the actual values used in the analysis. See the response 

to comment #162. 
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168. Page B-3, Section B.3, 5th Dot; There is no basis provided for the assumption that 1% of accidents 

would result in release of radioactive materials. Most other stated assumptions appear to have a 

stated basis. 

Response: The 1% value is a conservative engineering estimate. The only good test and modeling 

data that exist are for Type B spent fuel casks and TRUPACT-II containers, and those values range 

from 0.01% to 0.1%. Sandia has historically used, and currently is using, 1% for Type A and IP3 

packages. It has been used in previous DOE NEPA projects [for example: DOE/EA-1290, 

Environmental Assessment: Disposition of Russian Federation Titled Natural Uranium (1999)].

169. Page B-3, Section B.3, Last 4 Dots; These are redundant, considering content of the last two dots on 

page B-2. They should be consolidated. 

Response: The bullets were consolidated. 

170. Page B-4, Table B.2; The Eastern Centralized Commercial Storage Site (Barnwell) is located on the 

SRS Site boundary. Why then, would their values for “Truck Only – Dose Risk” be so different; 

0.0036 (SRS) verses 0.00206 (Barnwell)? The values for all other categories for SRS verses 

Barnwell are almost identical, as they should be. 

Response: The Barnwell site was selected to represent the location for an eastern centralized 

commercial storage site since it has existing infrastructure and experience in handling these 

materials. Other locations in the eastern United States could have been selected. The actual storage 

location, should a commercial storage site alternative be selected, could be anywhere in the eastern 

United States. However, we concur with the logic presented in the comment that adjacent storage 

sites should have virtually identical risk results. 

The values in Table B.2 are different because in selecting the nodes to use in the TRAGIS routing 

code, there are several SRS nodes from which to select and two nodes for Barnwell to choose from. 

Most likely, the nodes selected to run the analysis are not exactly at the Barnwell LLW site, and the 

SRS node is almost certainly not at the exact location of the material to be shipped or at the fence 

line adjacent to the Barnwell site. We used the same node for each origin and destination in all of 

the analyses. Differences in routing will result in differences in collective dose risks since the 

RADTRAN code allocates a population weighting factor to rural, suburban, and urban portions of 

a given route. 

Neither routing results in appreciable risks due to transport; however, since we know that the 

Barnwell and SRS destinations are essentially in the same place, the reader can use the Barnwell 

route results in Table B.2 for both Barnwell and SRS destinations. 

171. Page B-7, Section B.5, 2 Dots and last Paragraph; The last paragraph states the total number of 

shipments could not be estimated because the amount of material in each shipment may not be 

known. Without an assumption of the quantity of material in each shipment, how were estimates 

made of the average doses to the crewmembers? If the estimate is made based on the assumed dose 

rates on the drums as explained in Section 4.2 on page 4-3, I believe 159 mrem per crewmember per 

shipment, as stated here and at the bottom of page 4-18, is a gross overestimate. The potentials for 

such exposures would mandate implementation of a radiation protection program that, in turn, would 

find such exposures to not be ALARA.) 

Response: DOE concurs that the assumptions used were overly conservative and overstated the 

risk. Some assumptions have been modified (e.g., 2-hour exposure per crew member to 
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material between 1 and 16 m, instead of 12 hours, and 4 mrem/hour instead of 6 mrem/hour to 

be consistent with packaging calculations). The dose rate is 1.8 mrem/hour per crew member. 

172. Page C-12, Table C.4; When using the values for Intakes in Table C.5, I can reproduce the various 

values for Dose in Table C.5 and Cancer Intakes in Table C.4, but I can’t arrive at the same dose 

values shown for Cancer Risks in Table C.4. I am assuming the Cancer Risk values are a product of 

the CEDE derived from the Cancer Intakes and the appropriate risk values from ICRP-60 (i.e., 1 

LCF per 2,000 Person-Rem for the “Resident” and 2,500 Person-Rem for the “Standard Worker”. If 

this is the correct method, it appears the Cancer Risk values are too high by a factor of between 2 and 

30. It appears as if the dose-to-risk conversion values vary greatly and range between 70 rem and 

1150 rem instead of the expected values of 2,500 rem and 2,000 rem for workers and the public, 

respectively. 

Response: Cancer risks are estimated by multiplying the intake (pCi or pCi-yr/g)) in Table C.4 by 

the cancer slope factor (risk/pCi or risk/yr/pCi/g) in Table C.7. For example, the risk to the 

Short-term Emergency Worker from ingestion of U-234 is 8.8E-02 (pCi) × 1.58E-10 (risk/pCi) = 

1.4E-11. Slope factors are from HEAST, per standard risk assessment practice. 

173. Page C-15, Table C.7, Upper Table; The issue described above for page C.12 also applies here. Put 

another way, the Risk/pCi appears to be based on something other than the expected 2,000 or 2,500 

(as appropriate) rem/LCF. For example, in the specific case of Inhalation (Risk/pCi) for 

Uranium-235+D, the stated value appears to be based on a risk-to-dose factor of 756 rem/LCF. 

Response: See response to comment #173. Slope factors are from HEAST, per standard risk 

assessment practice. 

174. Page C-15, Table C.7: It appears some of the footnotes are not shown beneath the table. 

Response: Table has been modified. The extraneous footnoting was removed. 

John Owsley 

Director 

Tennessee Department of Environment and Conservation 

DOE Oversight Division 

175. Acknowledging that uranium wastes are not part of the scope of this PEA, the document should 

identify and address any waste streams associated with the re-usable uranium materials. The PEA 

should provide maps of probable transportation sources.

Response: Text in the PEA has been added to acknowledge waste streams associated with 

disposition or in the event product is later declared to be a waste. Since the waste streams are 

dependent on the specific end use, and these are only known in general terms, this was not 

evaluated in detail in the PEA. However, the many thousands of containers used to transport the 

uranium product would eventually become a waste stream. Either the containers are considered 

waste and disposed or they are cleaned for reuse, creating a waste stream from the cleaning 

operations. It is unlikely that the empty containers could be reused as is, except in very limited 

circumstances. 
01-217(doc)/093002 D-85

176. The PEA should provide maps of probably transportation routes. 

Response: Transportation routes were identified for analysis purposes in the PEA using the 

TRAGIS routing model. Potential impacts from accidents and exposure were addressed in the 

PEA; however, for security reasons, DOE cannot publish map routes. 

177. The state of Tennessee reiterates its position on not being willing to accept any materials designated 

for recycle/reuse without definite disposition pathways which may accumulate to long term storage 

or any waste that may require long term storage prior to treatment/disposal. 

Response: Comment noted. 

178. Section 2.1 Page 2-1, the typical end-use products are stated as metal or UO2. On page 2-3, 

Fernald’s largest inventories that fall within the scope of this PEA are stated to be in the form of 

metal and UF4. The UF4 should be added to the statement on page 2-1 that defines the scope. 

Response: The intent of the introductory paragraphs in Section 2.1 is to provide general 

background information on uranium, not to provide an exhaustive list of all uranium forms 

covered by the PEA. The list of materials included in the PEA is detailed in Section 2.3. 

179. Moving more material into Pike County would increase the possibility that the Piketon plant’s 

ultimate fate would be a dump site. 

Response: The UMG is developing a disposition strategy to move the material offsite as quickly and 

reasonably as possible. As noted in responses 35 and 36, the UMG is committed to provide a letter 

of intent to the State of Ohio regarding this strategy. The disposition strategy will include DOE’s 

commitment to make periodic, not to exceed 5 years, assessments and documentation of the 

material in storage in order to ensure that the material continues to have reuse potential. 

180. The people of Pike County will not willingly agree to receive any material at Piketon without an 

iron-clad agreement with DOE that the uranium will either be marketed or removed in a timely 

manner. 

Response: DOE has committed to aggressively and periodically evaluate disposition strategies at 

Portsmouth. See response to 179 above. 
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