## 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~ T~nnas~eg 37830

--- ----E’, * “*I&A” 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 1DOE 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 2DOE 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 3DOE 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 4storage 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 5acres 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 6minor 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 7U.S. Department of Energ Oak Ridge Operations Oak Ridge, Tennessee

02-l 69(doc)/082102 S01-217(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 FO R AGENCY ACTION ................................................................1-1
1.2 SCOPE OF THIS ENVIRONMENTAL ASSESSMENT .......................................................1-1

2. DESCRIPTION OF PROPOSED ACTION AND ALTER NATIVES..............................................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 E NVIRONMENT ........................................................................................................ .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............................................................................................................. ..3-501-217(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 TEC HNOLOGY 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..................................................................................................3-1 2
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..................................................................................................3-1 5
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 ..................4-801-217(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 .....................................................................................................4-1 1 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 .....................................................................................................4-1 3 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 .....................................................................................................4-1 5 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 C ONCLUSIONS ....................................................................................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/I NDIVIDUALS CONS ULTED.....................................................................7-1

APPENDIX A. HAZARD AND ACCIDENT ANALYSIS FOR URANIUM MANAGEMENT
PROGRAMMATIC ENVIRONM ENTAL ASSESSMENT ............................................................A-1

APPENDIX B. TRANSPORTATION ANALYSIS FOR URANIUM MANAGEMENT
PROGRAMMATIC ENVIRONM ENTAL 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-101-217(doc)/093002 vi APPENDIX D. COMMENTS AND R ESPONSE TO COMMENTS......................................................D-101-217(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 th e PORTS region of influence for Pike County and Scioto County............................................................................................................................3-2 3.2 Population and income in the Y-12 Nati onal Security Complex Region of Influence
for Roane and Anderson Counties for 1999.....................................................................................3- 7 3.3 Population and income in the Savannah Ri ver 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 centra lized storage at a single DOE site......................................4-5 4.3 Impacts for interim centralized storage at a singl e DOE site ...........................................................4-6
4.4 Risks due to accidents for interim centr alized storage at a single DOE site ....................................4-7 4.5 Transportation effects for interim centr alized storage at a single DOE site.....................................4-7 4.6 Impacts for interim centralized st orage at a single commercial site.................................................4-8 4.7 Transportation effects for interim centr alized storage at a commercial site.....................................4-9 4.8 Storage requirements for interim partially c onsolidated 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 consolidat ed storage at two commercial sites ..................................4-14 4.17 Transportation effects for interim partially c onsolidated 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 ............4-1701-217(doc)/093002 viii01-217(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

U 3 O 8 oxide ore

UF 4 uranium tetrafluoride

UF 6 uranium hexafluoride
UO 3 uranium trioxide01-217(doc)/093002 x01-217(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 poten tially reusable low enriched uranium (LEU), normal uranium (NU), and depleted uranium (DU). Uranium mate rials, 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, tr ansport, 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, in cluding 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 consis tent with environmental requirements and budgetary constraints. DOE needs to implement a long-term (great er 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 mana gement program addressed in this PEA looks at transportation, including preparation of uranium material s 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 ma nagement plan will cover uranium materials that are currently in the form of oxides, metals, and other st able compounds, and which are located at various sites around the United States. The plan will not include irradi ated material, material in the form of uranium hexafluoride (UF 6 ), uranium that is enriched to 20% or greater in 235 U, or uranium enriched in 233 U.

Storage would occur until future sale or reuse a lternatives 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 G aseous 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 Ida ho National Engineering and Environmental Laboratory (INEEL) in Idaho. Also both western and eastern co mmercial sites will be considered. Approximately 14,200 MTU will be stored in either one (centralized) lo cation 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 ma jority 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 St ates, 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 environm ental impacts from a variety of disposition options have been considered. The scope of this analysis incl udes: commercial processing of the material, use of this material in research activities, provision of this mate rial to other government agencies, and/or the sale (international/domestic) of this material. While the ur anium materials covered in this PEA are potentially reusable and are not wastes, it is possible that some porti on of the inventory could, in the future, be declared waste. Also, in the disposition process, some wastes c ould 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 produc t. The analysis also covers these aspects of waste production associated with the UMG Program. It is unde rstood that a disposition option not covered by the bounding analysis may require further National E nvironmental 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 (U 3 O 8 ) in the Earth’s crust. In
order to make the uranium useful for nuclear fuel or m ilitary applications, the ore is usually concentrated and then fluorinated to yield UF 6 , 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. UF 6 is not included in this PEA.

In its natural state, uranium consists of several different isotopes, notably 238 U and 235 U, 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 235 U% as the natural uranium. In this PEA, NU refers to 0.711% 235 U 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 nuc lear reactors, the ability to use uranium for controlled fission in nuclear chain reactions depends on increasing the proportion of 235 U in the material relative to 238 U. This isotopic separation process is called “enri chment.” In this process, a stream of UF 6 containing both 235 U
and 238 U is divided into separate streams. One is increased, or enriched, in its percentage of 235 U (typically to 3.5%) and is commonly referred to as LEU. The other is reduced, or depleted, in its percentage of 235 U (typically to 0.25%) and is commonly referred to as DU. (When the 235 U is increased by 20% or more, the material is commonly referred to as highly enriched uran ium (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 inventor ies 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 program s. Under these programs, many colleges and universities and other government agencies possess DOE-owned ur anium materials obtained through contractual or loan/lease agreements. Some of this lo aned or leased material is now being returned to the DOE inventory.

DOE’s inventories of excess LEU, NU, and DU, with in 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 in cludes LEU, NU, and DU considered “excess” (i.e., no longer required for the national defense mission) but pot entially 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 ma y 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 Gase ous Diffusion Plant.
SRS = Savannah River Site. Y-12 Complex = Y-12 National Security Complex.

The mission of the Y-12 Complex has been and continu es to be the refining, fa brication, and stockpiling
of uranium.

The mission of ETTP, PGDP, and PORTS has historically been to enrich uraniu m in the chemical form
of UF 6 . 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 UF 6 , 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 dispos ition their remaining stored uranium, including their potentially reu sable 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 operati ons. 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 (UF 4 ), NU in the form of metal, and
LEU in the form of metal and oxide. Most of this ur anium has already been sent to the Portsmouth Site. Hanford’s primary mission today is also environmental re storation. 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, r eactor 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 sp ent fuels from the U.S. Na vy 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 st orage 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 th e 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 th is study did not identify numbers of containers or container types for the various types of uranium mate rial included in the PEA. This information is necessary to determine transportation impacts and storage requireme nts. 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 a ll 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 differen t 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 cu rrent storage configurations, but rather assume that
all materials at a site are stored in a consiste nt 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 consider ed: (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 ite m 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 235 U (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 2-4Table 2.2. Uranium managementPEA interim storage alternativesAssumed storageaAdditional materials to be movedInterim storagealternative Description Site/formAmount(103MTU)Number ofcontainersAmount(103MTU)Number ofcontainersNumberof sitesNumber oftrucksNumber ofrailcarsNo Action Continued storage atcurrent sites. Totalmaterial included in thePEA is ~14,200 MTUINEELPGDPPORTSSRSOak RidgeAll others1.5<0.14.43.01.43.9639824,7652,8676,43137,124N/A N/A N/A N/A N/AInterim centralizedstorage at a singleDOE siteAll material transferredto a single, centralizedDOE storage locationINEELPGDPPORTSSRSOak Ridge1.5<0.14.43.01.4639824,7652,8676,43112.714.29.811.212.871,19571,82647,06968,96765,4031571571571571575,4255,5253,8995,1954,9584,8574,8843,4174,6934,369Interim centralizedstorage at a singlecommercial siteAll material transferredto a single, centralizedcommercial storagelocation (east or west)East, West N/A N/A 14.2 71,834 158 5,526 4,884Interim partiallyconsolidated storageat several DOE sitesMaterial moved to theclosest consolidatedstorage locationINEELPGDPPORTSSRSOak Ridge1.5<0.14.43.01.4639824,7652,8676,4311.70.41.4<0.10.421,39140013,458631,8124624667101,814499957331,7571490409Interim partiallyconsolidated storageat two DOE sitesMaterial consolidated atPORTS and INEELPORTSINEEL4.41.524,7656396.61.724,94021,49092641,9661,8321,6331,757Interim partiallyconsolidated storageat two commercialsitesMaterial consolidated atone Eastern and oneWestern commercial siteEast, WestN/AN/AN/AN/A11.03.249,70522,12993653,5931,9333,1001,78401-217(doc)/093002 2-5Table 2.2. Uranium management PEA interim storage alternatives (continued)Assumed storageaAdditional materials to be movedInterim storagealternative Description Site/formAmount(103MTU)Number ofcontainersAmount(103MTU)Number ofcontainersNumberof sitesNumber oftrucksNumber ofrailcarsInterim partiallyconsolidated storagebased on physicalformMaterial consolidated byphysical form (i.e., thesite with the largestquantity of a specificphysical form is thepreferred storagelocation for all materialsof that form)Compound (PORTS)Metal (SRS)Misc. (PORTS)Oxide (PORTS)Reactor fuel (INEEL)Residue (INEEL)Source (INEEL)1.72.900.90.5<0.1<0.17,2211,088015,333184558<0.16.01.20.50.4<0.1<0.11,03432,9184,9987,807827174187122112117257211062,9032206761111742782,676256486559DOE = 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 didnot identify numbers of containers or container types for the various types ofuranium material included in the programmaticenvironmental assessment. 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 were used in order to evaluate allmaterials consistently. For example, Savannah River Site indicates the site has3,861 wooden and cardboard boxes containing uranium metal (depleted uranium, normal uranium,and low enriched uranium) and 381 drums of LEU oxide. However, ifthese materials were repackaged for shipment to a different interim storage location, using the assumptionsin 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 type a 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 envi ronmental assessment.

Table 2.4. Container assumption s for uranium management PEA

a Based on fissile material limits of 800 g/container at 1.35% 235 U (10 Code of Federal Regulations 71.20 for Type A containers). DU = depleted uranium.
LEU = low-enriched uranium.
NU = normal uranium. PEA = programmatic envi ronmental assessment.

Table 2.5. Transportation assump tions for uranium management PEA

Transport vehicle Material type(s) Container type Maximum number a
DU, NU Drums 64

LEU b Drums 12 Truck

DU, NU Metal boxes 6
DU, NU Drums 240

LEU b Drums 12 Railcar

DU, NU Metal boxes 26

a Maximum number based on weight and/or 235 U 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% 235 U (10 Code of Federal Regulations 71.20 for Type A containers). DU = depleted uranium.
LEU = low-enriched uranium.
NU = normal uranium. PEA = programmatic envi ronmental assessment. Material type(s) Assumed container type Amount per container (lb)
DU, NU Drum
Metal box 540 5,850

LEU a Drum 13001-217(doc)/093002 2-7 Table 2.6. Uranium management PEA interim storage requirements

Alternative Site Amount (10 3 MTU) Number of
containers Estimated storage requirement (ft 2 )

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 envi ronmental assessment.
PGDP = Paducah Gaseous Diffusion Plant.
PORTS = Portsmouth Gase ous Diffusion Plant.
SRS = Savannah River Site.

Table 2.7. Uranium management PEA disposition options

Disposition option Description Material type(s) Amount (10 3 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 envi ronmental assessment01-217(doc)/093002 2-8 Fig. 2.1. Example of the 55-gallon drums a nd 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 truc k, in which case only truck shipment was evaluated. However, containers and material types are not mixe d 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 assu med storage configuration that includes four drums per pallet, with pallets stacked four high and meta l 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, aisl e space is allowed every 40 ft and around the perimeter.

2.2 NO ACTION ALTERNATIVE

The No Action alternative would continue ongoing st orage activities at all existing facilities. This alternative includes the continued storage of uraniu m 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 materi als, including repackaging if needed. The uranium inventory would not be dis positioned (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 pack aging and transport of potentially reusable uranium materials from DOE sites and university loan/lease retu rns 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 ci rcumstances, for uranium in the UMG inventory to be sold. Twenty years will provide time for additional revi ews required for any future related actions that may be desirable to help accomplish ultimate disposition. Im pacts 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 UF 4. 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, SR S, 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 num ber is based on the 2000 NMIA data increased by approximately 10% to reflect uncertain ties in material shipment. The plan will not include irradiated material,

UF 6 , enrichment of 20% or greater 235 U, or 233 U.

DOE must determine the safest, most effective, a nd most efficient approach for the consolidation and storage of this material. Consideration will be given onl y 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 (consolidat ed) 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 ma terial, use of this material in research activities, provision of this material to other Government agen cies, 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 di fferences 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 MT U 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 altern ative 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 th e 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 even t 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 consid ered 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 th e western United States (INEEL) and one in the eastern Untied States (PORTS), will retain their existing uranium material inventories. The remaining inventory in01-217(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 ma terials 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 material s (about 4,400 MTU), while SRS would receive the metals (more than 8,900 MTU) and INEEL would recei ve the reactor fuel, residue, and sources (about 900 MTU). The sites with the largest inventory of a partic ular 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 sec ond 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 storag e alternatives and not a separate alternative. DOE may dispose of all, or part, of the uranium materi als in one of several ways. These reuse scenarios are speculative at this time, especially in regard to th e 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 th ese options from their respective interim storage locations. Any material not included in a specific disposition opti on can be included with any of the other disposition options. The disposition options are an integral constitu ent 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 mate rials 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 MTU01-217(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 coul d be provided to other government agencies. The
uranium materials would be the Fernald Environm ental Management Project (FEMP) DU and FEMP and Hanford uranium trioxide (UO 3 ). 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 distan ce 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 mate rials 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 i nventory 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 ma terial 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 la te 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 a nd 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 th e 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 th e 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 rela tively 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 abandoned01-217(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 upla nd 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 hardw ood, 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 speci es are known for the vicinity but none presently on-site. The sharp-shinned hawk, Carolina yellow-eyed grass, Vi rginia 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 su mmarizes population, per capita income, and total person income for both counties from 1999, the last year for whic h 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 empl oyment 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 populati on proportions greater than the national average of 13.1%).

3.1.7 Land Use

The site covers approximately 6.3 mile 2 (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 Corporation01-217(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 Stat e 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 archaeo logical resources, which includes prehistoric components, isolated finds, and lithic scatters. A c ouple 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 Ke ntucky, 17 km (10 miles) west of Paducah, and employs 1868 people. Paducah has been an active uraniu m 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 a ttainment 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 ac tivities 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 proba ble 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 Aquife r (the primary aquifer in the area, composed of sand and gravel units), and the Upper Continental Recharge Sy stem (clayey silt with interbedded sand and gravel). No aquifers are considered sole-source aquifers. Two majo r 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 c onsist of valley fill deposits , which underlie most of the site, extending northward to the Ohio River. Majo r rock units include, from oldest to youngest, basement rocks, Tuscaloosa Formation basal gr avels, the McNairy Formation, th e 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 Ma drid 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 de veloped area cover most of the Paducah site; forested areas are small and dominated by mature ha rdwood upland and riparian forests. On-site wetlands consist of forested wetlands (mature riparian hardw ood forest). A wetland in the West Kentucky Wildlife Management Area (the buffer area surrounding the produc tion facilities) has been designated an area of ecological concern.

Federally listed endangered species that have been identif ied, or could be identified, in the vicinity of the Paducah site include the Indiana bat, the interior l east 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, Kent ucky, where the facility is located. McCraken County had a population of 64,407, pe r 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 minor ity populations near the plant site, with minority populations in the city of Paducah. There are no federally rec ognized 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. Electri c 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 ro ads (Interstate 24 and U.S. Highways 45, 60, and 63). The Burlington Northern Railroad, Paducah Railr oad, 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 subj ect 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 235 U from normal uranium by the electromagnetic separation process and manufacturi ng 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 classi fied as humid continental, although it is very near the region of temperate continental climate to the nor th. The Cumberland Mountains/Plateau to the northwest and the Great Smoky Mountains to the southeast influe nce the patterns of temperature and precipitation over the region, with cooler temperatures and greater preci pitation 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, refl ecting the channeling of winds parallel to the ridges and valleys in the area.

The air quality control region in which the Y-12 Comp lex 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 c oncentration guidelines (DCGs) give n 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 pe r year to a reference individual, as defined by the International Commission on Radiological Protection.

The prevention of significant deterioration (PSD) Cl ass 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 mil es) from the Melton Hill Reservoir and Clinch River. On-site, two streams originate approximately in the middl e 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 Ma ynardville Limestone. No aquifers are considered sole-source aquifers (DOE 1997b).

3.3.4 Geology and Soils

On a regional scale, the ORR, whic h includes the Y-12 Complex, is lo cated on the western part of the Valley and Ridge Province (DOE 1998a). The stratigraphi c 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 rock s 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 stru cture exerts a strong influence on groundwater flow (DOE 1997b).

3.3.5 Ecological Resources

The ORR consists of diverse hab itats 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 struct ures. 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 main tained. Lake Reality is a 2.5-acre, plastic-lined, flat-bottomed settling and spill control structure located n ear 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 coveri ng these three species for the ORR (s ee 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 al so includes the city of Oak Ridge, which provides a substantial portion of the work force for the three f acilities. 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 me tropolitan 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 persona l income was more than $2.8 billion. Wage and salary employment for the region was 60, 311 in 2000 (U.S. Bureau of Econom ic 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 b een in operation since World War II. The residential portion of Oak Ridge forms much of the northern bounda ry 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 di scharged to the city of Oak Ridge publicly owned
treatment works under an industrial and commercial wastew ater discharge permit. Sanitary sewer radiological sample results at the Y-12 Complex are routinely revi ewed to determine compliance with DOE Order 500.5, “Radiological Protection of the Public and the Envir onment.” 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 magnit ude 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 Comp lex 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 identifie d 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 th ree 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 classi fied as humid continental, although it is very near the region of temperate continental climate to the nor th. The Cumberland Mountains/Plateau to the northwest and the Great Smoky Mountains to the southeast influe nce the patterns of temperature and precipitation over the region, with cooler temperatures and greater preci pitation 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, refl ecting the channeling of winds parallel to the ridges and valleys in the area.

Roane County and all surrounding coun ties 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 ente rs the north side of ETTP about 0.5 km (0.3 mile)
downstream of the confluence of the east and west fork s 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 onl y facilities identified at risk during major floods were the K-25 power plant and the pumping station fo r ETTP’s water filtration plant. The source of flooding
at ETTP would be backwater from the Clinch River n ear the confluence of Poplar Creek. All proposed storage locations are above the 100-year flood level.

Groundwater

Groundwater occurs at ETTP in bot h 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 hy draulic 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 b een 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 unlikel y that these wells could be affected by groundwater flowpaths from ETTP, should such a pathway exist. A dditionally, there are nearly a dozen domestic wells along Blackoak Ridge, west of the DO E 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 carbona tes underlie the majority of the main plant area. The eastern part of the site is underlain by clastic bedr ock 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 si de of the ETTP. Seismic activity in the southern Appalachian Mountains
that has affected the site area h as been recorded 45 times since 1800. The probability of future seismic damage is moderate.

3.4.5 Ecological Resources

The ORR consists of diverse hab itats and supports a rich variety of flora and fauna. Vegetation is characteristic of that found in the intermountain regi ons of central and southe rn 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 ha ve 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 gr asses, 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 presen ce of humans. There are no known federally protected plant or animal species on the ETTP site, although suitabl e habitat exists for the endangered bald eagle on Melton Hill Reservoir and the Clinch River. Sixteen pl ant 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. Porti ons of the site have been used for waste storage since the facility ceased enrichment operations. Effort s 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 Sy stem 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 Manha ttan Project to develop and produce HEU for use in nuclear weapons. The Manhattan Project created the fi rst industrial process for separating uranium isotopes by the gaseous diffusion method. A summer 1994 cultural re sources survey of the former K-25 Site identified
a Main Plant Historic District with 120 contribu ting 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 km 2 (300 mile 2 ) within the Atlantic Coastal Plain physiographic province. SR S 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 the01-217(doc)/093002 3-11 early 1950s to produce the basic materials used in the fabrication of nuclear weapons, primarily tritium and

239 Pu, 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 ai r 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 insta llations, 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 annua l 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 Ri ver, 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 clay s 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-Ar ea and M-Area; C-Area; D-Area and TNX; the general01-217(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, w ith 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 lo cated 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 a nd lowland hardwood swamps, sandhills, and old agricultural fields. Ninety percent of the SRS land cover is upland pine for est and bottomland hardwood forest. Important terrestrial habitats include old fiel ds, sandhills, upland pine for ests, bottomland and upland hardwood forests, and swamp forests. Longleaf pine /wiregrass communities suppor t 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 in clude 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 ba ld eagle, the smooth coneflower, the woodstork, the short-nosed sturgeon, and the pondberry (see FWS letter da ted 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/gene ral/enviro/SRFS.htm; April 24, 2002). Th e 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, Alle ndale, 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 populati on, 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-occ upied 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 sev eral plant species traditionally used in tribal
ceremonies.

3.5.7 Land Use

The site occupies 198,000 acres of land, most of wh ich serves as a forestry research center. SRS was designated a National Environmental Research Park (N ERP) in 1972. Of the total area, approximately 15,840 acres are developed and 182,162 are undevelope d. 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 cu rrent 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-km 2 (890-mile 2 ) 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 natu ral background radiation from cosmic, terrestrial, and internal body sources; manmad e nuclear fallout; and radiation from consumer and industrial products. In 1997, INEEL ac tivities 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 m onitoring 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 drai n adjacent mountain valleys and flow onto INEEL. All of the streams infiltrate, disappearing in the underlyi ng 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 u tilization of an existing diversion area constructed near the point at which the river enters the INEEL (Be nnett 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 se ries 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 wa ter 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 mo re than 50% of the drinking water consumed within
the eastern Snake River Plain and an alternative dri nking 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 m 3 (6.5 million acre-ft) of water annually through springs and irrigation wells. Discharges from the springs contribute substan tially 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 borde red on the north and northeast by the Lost River, Lemhi, and Bitterroot mountain ranges. Elevati ons 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 co mposed of basaltic lava flows interbedded with sedimentary strata. A 30-ft layer of mixed sedimen ts covers a deeper layer of underlying basalt. A grayish-brown gravelly silt loam, derived from loess mixe d with alluvium from the Big Lost River, makes up the topsoil. Gravels occupy 50% to 75% of the surf ace 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 ear thquake (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 e ndangered 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 leucocephalu s), a federally-protected species, has been observed wintering on or near the INEEL (Martin 1995). The FWS, in addition, lists the Canada ly nx, 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 1,51601-217(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% mi nority and 14% low income (DOE 2000).

3.6.7 Land Use

The INEEL occupies 2305 km 2 (890 mile 2 , 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, approximate ly 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 aver age 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 su rveys 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 r esources 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) est ablishes 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 describ ed 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 altern ative coupled with dispos ition options, and Section 4.12 addresses cumulative impacts.

4.1 METHODS

This section describes environmental and socioec onomic impact methods and risk to the public, a co-located worker, and a facility worker due to con tinued storage of uranium materials at their current locations (No Action alternative), and receipt, interim stor age, and disposition of these materials at other sites as described in Chapter 2. Risks ar e evaluated for routine operations and nonroutine (accident) conditions.

Routine or normal operations incl ude construction of any new storage facilities, upgrades to existing facilities, and maintenance and surveillance. Constr uction costs and the number of permanent workers (maintenance and surveillance) are estimated based on the space needed for uraniu m materials storage and disposition. The number of construction workers is estimat ed assuming that half the construction costs are labor and each worker earns $20,000 per year. The permanent la bor force to monitor storage in various warehousing locations is assumed to be one worker/18,000 ft 2 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; dispos ition options should be considered a possible component of each interim storage alternative.

The number of parameters that could affect the off-s ite human health and environmental consequences of a catastrophic release is vast. For example, the assumpti ons 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 comple xity 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 environmen tal consequences, the worst-case accident is assumed to be a seismic event and resulting fire that breaches a large number of contai ners 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 th e facility boundary and that all of the uranium in the plume is respirable. Even though this scenario is consider ed 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 to rnado). This is especially01-217(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 r ecyclable pieces of metal). The hypothetical seismic/fire scenario also results in the worst-case exposure pathwa y (inhalation), because uranium is predominately an alpha-particle emitter. This is addressed in greater detail in Appendix C.

Uranium released from primary containers under th e accident scenario described above and modeled later in this section can be deposited on surface soils a nd 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 pathwa y 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, th e fate and transport of uranium is a function of the environmental site characteristics and the physical/chemi cal properties of uranium. Such properties include uranium’s solubility in water, the tendency of uranium to transform or degrade (e.g., 238 U has a half-life of 4.5 billion years), and chemi cal affinity for solids or organic matter (described as a partitioning coefficient K d ). An average K d value for uranium is 15 L/kg, although the possible range of K d s can vary widely (Sheppard and Thibault 1990). Contaminants with small K d s will be leached more effectively into the groundwater (i.e., be more mobile) than those with larger K d s. For example, uranium is much less mobile than 99 Tc, which has a K d 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 uran ium’s mobility and toxicity. The soils described in Chapter 3 are generally rich in clay and organic matte r and would be effective in retarding the mobility of uranium. Further, even if resuspended and availa ble 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, ev en though the previous paragraph supports minimal mobility of uranium in the soil, a fraction of the uranium c ould enter the water system upon any accidental release, especially by direct deposition from the plume. The mobility of uranium depos ited 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 so il, and anionic species tend to move with water. Uranium released in a fire would be oxidized (be cationic) and would tend to ad sorb to the soil particles entrained in the water. As with uranium deposited upon the soil, the doses to a recepto r 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. Uran ium can also induce cancer when organs and tissues are exposed to alpha particles emitted from decaying uran ium 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 th at alpha particles do when inside the human body. The ionization events cause biological damage, which is belie ved to be responsible for inducing cells to become cancerous. The types of uranium (e.g., natural, enriched, and depleted) under considera tion are important because different types of uranium have different specific ac tivities (the amount of radioactivity per unit mass). The difference between natural, low-enriched, and depleted uranium is defined by the percent 235 U mass enrichment.
As the 235 U enrichment increases, the specific activity of th e mixture increases. The different quantities of source
material and their associated activities are consid ered in the quantitative assessment that follows.01-217(doc)/093002 4-3 The potential adverse effects of the uranium s ource material in environmental media, such as groundwater, surface water, soil, or sediment, are relativ ely 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 acti ons 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 wher e 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, worker s 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, work er exposure due to routine operations associated with
surveillance and maintenance of stored materials is e xpected 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 ra diation 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 b ackground 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 ar e 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 fro m alternative to alternative. The impacts associated with the various disposition options are common to all alternatives.

Regarding Intentional Destructive Acts such as sa botage or terrorism, there are no known or reasonably anticipated scenarios that would result in human conseque nces greater than those already evaluated for fires, which are negligible. The types of uranium materials cove red 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 locati ons 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 so ils, water resources, cultural resources, and the infrastructure remain unchanged. Air effluents associat ed 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 a nd continued uranium monitoring by current employees. Under these assumptions, there is no change in expenditure or em ployment and, consequently, no impact. Even if additional workers were hired for monitoring at each poten tial 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 si x DOE locations would remain at these sites. The amount at each individual site is very small and is ty pically associated with university or other types of research. No substantial environmental impacts are exp ected 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 th e research work is completed.

4.3.2 Facility Accidents

Acute consequences associated with facility fires a nd seismic events are evaluated in Appendix A and summarized in Table 4.1. The highest acute consequences to the public or to a co-lo cated worker are due to a fire or earthquake at PORTS, with aerial dispersion of ur anium 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 c onsequences 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 associ ated with the No Action alternative.

4.4 INTERIM CENTRALIZED STORAGE AT A SINGLE DOE SITE

This alternative involves moving all uranium materi als 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 m oved, the total at any site is the same (14,200 MTU).01-217(doc)/093002 4-5 Table 4.1. Risks due to accide nts 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 other a Negligible Negligible Negligible Negligible Negligible Negligible Facility
fire

PORTS Negligible Negligible Negligib le Negligible Negligible Negligible INEEL, PGDP, SRS, Oak Ridge,
Max other a Negligible Negligible Negligible Negligible Negligible Negligible Seismic

PORTS Negligible Negligible Negligible Negligible Low Low

a Max other represents the largest singl e 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 Gase ous Diffusion Plant.
SRS = Savannah River Site.

4.4.1 Normal Operations

Under this alternative, the amount of uranium st ored 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 ft 2

.

Table 4.2. Storage requirements for interi m centralized storage at a single DOE site

Assumed storage Materials to be moved

Site Amount,
10 3 MTU Number of
containers Storage requirement,
ft 2 Amount,
10 3 MTU Number of
containers Additional storage requirement, ft 2

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 ~168,000 a

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 ft 2 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 Gase ous 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 Gase ous Diffusion Plant.
SRS = Savannah River Site.

PORTS is the only DOE site with sufficient exis ting 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 st orage suitability (DOE 1999), and over 450,000 ft 2 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 a nd 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 ft 2 of new space could be constructed. Under this assumption, the upgrades co st would increase from $8.4M to $10.9M, and the number

of construction workers from 210 to 273. Environmenta l impacts and socioeconomic impacts would increase
from minimal to minor. Even with some new constructi on, 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 ar e already industrialized. This would minimize potential impacts to sensitive species but would permanently elim inate the habitat for existing biota on up to 7 acres committed to the project (for new buildings and associat ed landscaping). Infrastructure would be slightly affected, because utilities would have to be run to th ese new facilities. Construction would result in minor fugitive dust emissions and disturbance of soils. Ho wever, 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 existi ng storage locations are assumed to be replaced with a01-217(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 in creases. Permanent site employment would also increase less than 1%, and temporary construction-related empl oyment 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 a nd 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 uran ium to become airborne in a fire. This is because most of the airborne source term (~ 73%) results fro m compounds, oxides, and other miscellaneous forms that are relatively more dispersible than other physical fo rms 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 interi m centralized storage at a single DOE site

Maximum acute risk Chronic human he alth risk Chronic ecological risk
Accident
scenario Consequence
level Overall
risk Consequence
level Overall
risk Consequence
level Overall
risk
Storage area fire Negligible Negligible Neg ligible 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 neglig ible 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 transpor t). 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 material s 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 st orage 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 0.01001-217(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 stor ed at a commercial site is the same as the total of 14,200 MTU. The total floor space required for storage is

∼ 243,000 ft 2 ; 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 pot ential 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 su mmarizes expected impacts from normal operations.

Table 4.6. Impacts for interim centraliz ed 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 th e first-year construction, the number of permanent workers, and the costs of construction would equal or ex ceed those for the DOE sites considered for centralized storage. Approximately 7 acres of la nd 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, et c.), impacts to any surface waters would be minor and short-term. Socioeconomic impacts would be minor and in clude 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 fir es and seismic events are evaluated in Appendix A. Human health and ecological risk are evaluated in Appe ndix 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 materi als for long-term centralized storage at a single commercial site are evaluated in Appe ndix B and summarized in Table 4.7.01-217(doc)/093002 4-9 Table 4.7. Transportation e ffects 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 fro m 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 additi on, 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 a lternatives 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 material s 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 stor age sites. The materials at each of the 152 sites would be stored at the geographically closest DOE consolida tion site. The amount of uranium stored at each of the
six DOE sites would increase from current levels to th e levels shown in Table 4.8. The total floor space required for storage would also increase.

Table 4.8. Storage requirements for interim partia lly consolidated storage at several DOE sites

Assumed storage Materials to be moved

Site Amount,
10 3 MTU Number of
containers Storage requirement,
ft 2 Amount,
10 3 MTU Number of
containers Additional storage requirement, ft 2

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 Gase ous Diffusion Plant.
SRS = Savannah River Site.01-217(doc)/093002 4-10 Because of the small amount of additional uranium mate rial to be received at each consolidated storage site, the impacts are similar to the No Action altern ative (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 co nsolidated 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 Gase ous 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 a nd 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 potentia l 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 cau se 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 Negligible Negligible Negligible Negligible Negligible Negligible Facility fire

PORTS Low Low Negligible Negligible Negligible Negligible
INEEL, PGDP, Oak Ridge Negligible Negligible Negligible Negligible Negligible Negligible Seismic

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 Gase ous Diffusion Plant.
SRS = Savannah River Site.

4.6.3 Transportation

The potential effects of transporting uranium material s for consolidated storage at several DOE sites are evaluated in Appendix B and summarized in Table 4.11.

Table 4.11. Transportation eff ects for interim partially cons olidated 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 th e centralized storage alternatives becau se 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 fro m 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 de pending on the number of other
sites and amounts of materials that are consid ered closest to the consolidation location.

4.7.1 Normal Operations

Under this alternative, the uranium materials st ored at the two DOE sites would increase from current
levels to the levels shown in Table 4.12. The total fl oor space required for storage would also increase at both
sites.01-217(doc)/093002 4-12 Table 4.12. Storage requirements for interim part ially consolidated storage at two DOE sites

Assumed storage Materials to be moved

Site Amount,
10 3 MTU Number of
containers Storage requirement, ft 2 Amount,
10 3 MTU Number of
containers Additional storage requirement, ft 2

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 worker s during the first year for building upgrades, upgrade activities do not require additional land a nd habitat, nor do they result in large emissions to air and water. Thus, environmental impacts at PORTS would tend to be ne gligible. 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 a nd 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 air borne 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

INEEL Negligible Negligible Negligible Negligible Negligible Negligible Facility fire

PORTS Negligible Negligible Negligible Negligible Negligible Negligible

INEEL Negligible Negligible Negligible Negligible Negligible Negligible Seismic

PORTS Low Low Negligible Negligible Negligible Negligible

DOE = U.S. Department of Energy. INEEL = Idaho National Engineering and Environmental Laboratory.
PORTS = Portsmouth Gase ous 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 materi als for consolidated storage at two DOE sites are evaluated in Appendix B and summarized in Table 4.15.

Table 4.15. Transportation effects for int erim 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 transporti ng materials to two potential DOE storage locations.
The effects are less than those for th e centralized storage alternatives becau se 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 east ern United States). The total amount to be moved is 14,200 MTU, because these sites do not currently have any ma terial stored. The total amounts to be stored at either location vary, depending on the num ber 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 c onsolidated 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 would01-217(doc)/093002 4-14 have to be built. Additional requirements, activiti es, 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 co nsolidated 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 a nd 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 con sequences 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 f acilities are expected to cause negligible to low chronic risks to humans and ecological receptors.

4.8.3 Transportation

The potential effects of transporting uranium material s for consolidated storag e at two commercial sites are evaluated in Appendix B and summarized in Table 4.17.

Table 4.17. Transportation effects for int erim 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 transpor ting 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 depends01-217(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 relocat ed 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 re quired for storage is also shown in Table 4.18.

Table 4.18. Storage requirements for interim part ially consolidated storage based on physical form

Assumed storage a Materials to be moved

Site Amount,
10 3 MTU Number of
containers Storage requirement, ft 2 Amount,
10 3 MTU Number of
containers Additional storage requirement, ft 2

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 Gase ous Diffusion Plant.
SRS = Savannah River Site.

Additional requirements, activities, and environmenta l 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 co nsolidated 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 Gase ous Diffusion Plant.
SRS = Savannah River Site.

4.9.2 Facility Accidents

Acute consequences associated with facility fires a nd seismic events are evaluated in Appendix A and
summarized in Table 4.20. The seismic event at PORT S 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 a nd oxides that are relatively more dispersible than other physical forms considered in this study. Radiol ogical 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 neglig ible to low chronic risks to humans and ecological
receptors.

Table 4.20. Risks due to accidents for interim part ially consolidated storage based on physical form

Maximum acute risk Chronic human he alth risk Chronic ecological risk
Accident scenario Site(s) Consequence

level Overall
risk Consequence

level Overall
risk Consequence

level Overall
risk

PORTS Negligible Negligible Negligible Negligible Negligible Negligible Facility
fire INEEL, SRS Negligible Negligible Negligib le Negligible Negligible Negligible

PORTS Low Low Negligible Negligible Low Low Seismic

INEEL, SRS Negligible Negligible Negligib le 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 material s for consolidated storag e 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 e ffects 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 th e impacts of each action alternative considered. The impacts of disposition are presented here as bounding cond itions 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 cl eaned for reuse (generating waste in the cleaning process). These wastes would be di sposed in compliance with the applicable regulations governing such waste materials. Disposition would lik ely take place over an extended period of time and could involve several disposition options. Thus, impacts associated with waste str eams are expected to be minor since they would be intermittent and part of th e 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 occu r. Since all the inventory would eventually be disposed, a rough bounding of environmental impacts woul d 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 inte rim 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 al ready 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 pr obable. However, should construction be needed, any construc tion-related impacts should already be approximated by the storage at a single commercial site alternative (Section 4.5.1). Th at is, a temporary work force of ~300 construction workers, approximately a dozen permanent staff, a nd >$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 lik ely 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 asso ciated with this option are the same as that for centralized storage at a single commercial site (see Sec tion 4.5.2) because the total amount of material to be processed is the same (14,200 MTU).

The potential effects of transporting uranium material s to a commercial reprocessing facility are also the same as transporting the materials to a single cen tralized 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 possibl e that there would be no new construction or building upgrades required since any research facility needing th ese materials would already have the personnel and facilities to handle it. However, should some new cons truction or upgrades be required, the storage/research space would be a few thousand square feet at most a nd 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 subs tantially 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 neg ligible or low (see Table 4.10). Transportation effects are also less than tho se 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 construc tion 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 a nd 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 storag e alternative. Acute and ch ronic 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 cons olidated 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 negligib le 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 a nd seismic events are evaluated in Appendix A. The total material (~4,050 MTU) is similar to amounts tr ansferred to PORTS as evaluated for the partially01-217(doc)/093002 4-19 consolidated storage alternative. Acute and chronic consequences and risk are eith er 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 doc k 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. Envi ronmental impacts associated with normal operations vary from alternative to alternative and, occasionally, by site within a given a lternative. 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 a nd 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 locati on, either to a commercial site or to INEEL.

4.11.1 Comparison of Alternatives

When comparing the environmental impacts of the va rious alternatives, the following emerge as general
trends:

• There were none-to-minor impacts for all of the alte rnatives considered and negligible-to-low impacts from the standpoint of facility accidents (fire and seism ic) 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 commitmen t 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 sit es 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 fataliti es are minimal for all alternatives but greatest for the interim storage at the single site alterna tives. 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 tra ffic 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 im pacts than DOE sites (e xcept 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 norma l operations, the western and eastern commercial sites and PGDP have equal impact potential. Any of these s ites 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 ne gligible 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, nor mal operations impacts, including socioeconomics, would be minimal at this site. Upgrading existing bu ildings 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 storag e 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 “Inter im Centralized Storage at a Single Commercial Site” alternative, except that environmental imp acts 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 consolida tion at two commercial sites, because some of the uranium inventory is already at INEEL and PORTS. T hus, less construction-related impacts would result. Human health and ecological risks from facility accide nts 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 loca tions 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 othe r action alternatives. This alternative most closely
resembles the No Action alternative.

No Action. Because there is no new construction at any s ite, 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 asso ciated with the proposed action wh en combined with other past, present, or reasonably foreseeable future impacts. Th ere are no substantial impacts associated with the proposed action under normal operations. When the neg ligible-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 acti on 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 uraniu m oxide into the environment, it is reasonable to assume that other material releases and other risks would be posed to work ers at the site. Therefore, risks from uranium oxides
would be one of several environmental and health ri sks 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 tran sport 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, exposur es 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 dispos itioned. Various disposition options including commercial processing and domestic sal es 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 w ith 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 labo r) 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 MT U) 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 under going 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-distur bing remediation efforts, which also affect wildlife habitat, albeit of low qua lity 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 uran ium 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. Sin ce PORTS currently has sufficient existing storage space for the 14,200 MTU, the site has the low est potential for cumulative impacts due to construction/renovation. However, as noted, DOE is co mmitted 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 o ccur at a highly developed site undergoing other ground
disturbances associated with remediation. This site also has uranium inventor y 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 Statemen t 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 Investigati on 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 Technol ogy 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 Re port 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, 1995.01-217(doc)/093002 5-2 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 a nd 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 Inves tigations No. 87-2, Pocatello, ID.

Sheppard, M. I., and Thibault, D. H. 1990

. “Default soil solid/liquid partition coefficients, K d s 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.b ea.gov/bea/regional/bear facts, U.S. Department of Commerce, Bureau of Economic Analysis, Washington, D.C.

U.S. Bureau of Economic Analysis. 2002b. http://www.bea.gov/bea/regional/reis/, U.S. Department of Commerce, Bureau of Economic Analysis, Washington, D.C.01-217(doc)/093002 6-1 

## 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.01-217(doc)/093002 6-201-217(doc)/093002 7-1 

## 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.01-217(doc)/093002 7-201-217(doc)/093002 7-301-217(doc)/093002 7-401-217(doc)/093002 7-501-217(doc)/093002 7-601-217(doc)/093002 7-901-217(doc)/093002 7-1001-217(doc)/093002 7-701-217(doc)/093002 7-801-217(doc)/093002 7-1101-217(doc)/093002 7-1201-217(doc)/093002 7-1301-217(doc)/093002 7-1401-217(doc)/093002 7-1501-217(doc)/093002 7-1601-217(doc)/093002 7-3101-217(doc)/093002 7-3201-217(doc)/093002 7-3301-217(doc)/093002 7-3401-217(doc)/093002 7-3501-217(doc)/093002 7-3601-217(doc)/093002 7-3301-217(doc)/093002 7-3401-217(doc)/093002 7-3501-217(doc)/093002 7-3601-217(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 200201-217(doc)/093002 SCIENCE APPLICATIONS INTERNATIONAL CORPORATION

Contributed to the preparation of this document and should not be considered an elig ible 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 DESCRI PTION 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 LI STED 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.................................................................................................................. .................... 901-217(doc)/093002 iv01-217(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 Complex01-217(doc)/093002 vi01-217(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 comprehensiv e 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 to ward 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 ba t are present within 6.4 km (4 miles) of the ORR. Suitable roosting habitat for the Indiana bat is also pr esent 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 muck et is known to occur in the Clinch River (Melton Hill Lake). All surface water from Y-12 Complex drainage ev entually 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 info rmation presented in this BA, that implementation of the proposed action at either site on the ORR is not likely to adver sely affect any of the listed species because the proposed action involves potential warehouse construction on alread y developed, industrialized areas on the ORR. The ORR does not contain any proposed or designated critical ha bitat for the gray bat or the Indiana bat, so none would be affected. In addition, any potential adverse im pacts to the Indiana bat would be expected to be negligible due to the lack of suitable summer roosting ha bitat at both sites. Although the ultimate use of either site may eventually require the removal of trees, any poten tial 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 acti on would result in any off-site releases of sediment or potential contaminants that w ould 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, 2002.01-217(doc)/093002 viii01-217(doc)/093002 1 

## 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 Na tional Security Complex (hereafter referred to as the Y-12 Complex) and East Tennessee T echnology 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 poten tially reusable low enriched uranium (LEU), normal uranium (NU), and depleted uranium (DU). Uranium mate rials, 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, tr ansport, 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, in cluding 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 consis tent with environmental requirements and budgetary constraints. DOE needs to implement a long-term (great er 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 pack aging and transport of potentially reusable uranium materials from DOE sites and university loan/lease retu rns and their receipt and storage at a site under cognizance of the Uranium Management Group (UMG). Th is 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 provi de time for additional reviews required for any future related actions that may be desirable to help accomplis h 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 UF 4 . The quantity of uranium within the sc ope of this PEA is estimated to be 14,200 metric tons of uranium (MTU) and is primar ily located at a few DOE locations (Idaho National Engineering and Environmental Laboratory, Portsmout h Gaseous Diffusion Plant, Savannah River Site, and Oak Ridge). These DOE locations have other uranium ma terials, which are not part of the UMG inventory and not part of the 14,200 MTU addressed in the propo sed action. This number is based on the 2000 Nuclear Material Inventory Assessment data increased by approxi mately 10% to reflect uncertainties in material shipment. The plan will not include irradiated material, UF 6 , enrichment of 20% or greater 235 U, or 233 U.01-217(doc)/093002 2 Fig. 1. Location of Y-12 Complex and ETTP on the DOE's Oak Ridge Reservation.01-217(doc)/093002 3 DOE must determine the safest, most effective, and most efficient approach for the consolidation and storage of this material. Considera tion will be given only to those locati ons (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 (centra lized) 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 ev aluated 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 235 U 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 Nationa l 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 middl e of the complex. Bear Creek flows directly west from its headwaters at the Y-12 Complex, while EFPC fl ows 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 Li mestone. No aquifers are considered sole-source aquifers (DOE 1997a).

1.3.1.2 Ecological resources

The ORR consists of diverse hab itats 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 gr ass, 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 settli ng and spill control structure located near the east end of the facility on EFPC. Upper Bear Creek is also cha nnelized, 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 Co mplex. 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 th ree 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 a pproximately 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 th e northwest boundary of the ORR. Poplar Creek is a moderately wide [9- to 21-m (30- to 70-ft)] str eam that enters the north side of ETTP about 0.5 km (0.3 mile) downstream of the confluence of the east a nd west forks of Poplar Creek (DOE 1997b). The lower reach of Poplar Creek meanders sharply along the s outhwest side of ETTP and enters the Clinch River.

The Tennessee Valley Authority (TVA) performed an anal ysis 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 woul d be backwater from the Clinch River near the confluence of Poplar Creek. All proposed storag e locations are above the 100-year flood level.

1.3.2.2 Ecological resources

The ORR consists of diverse hab itats and supports a rich variety of flora and fauna. Vegetation is characteristic of that found in the intermountain regi ons of central and southe rn 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 ha ve 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 gr asses, 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 presen ce of humans. There are no known federally protected plant or animal species on the ETTP site, although suitabl e habitat exists for the endangered bald eagle on Melton Hill Reservoir and the Clinch River. Sixteen pl ant 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 biological01-217(doc)/093002 5 information on the species is derive d 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 Kentuc ky 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 ai r 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 wher e 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 cav es 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 Septem ber 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 coloni es. 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 th e 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, disorien ted, 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 habita t 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, Bi g 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 r oosting and were not further disturbed; therefore, a definite, in-the-hand iden tification was not made (Webb 1996). Examination of photographs taken of the r oosting bats indicate that they appeared to be Myotis and more than likely were gray bats, but the species could not be positivel y determined [Major (2000) and Henry (2000)].

Although no caves are present within the area of the pr oposed project, several cav es are located within 6.4 km (4 miles) of the proposed site location, and tw o of the caves are located within 2.4 km (1.5 miles). None of the caves has been completely and systematically surveyed for bats, ex cept 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 migrati ng gray bats. Suitable foraging habitat for gray bats01-217(doc)/093002 6 within the vicinity of the proposed facility includes th e Clinch River (Melton Hill Lake), which is located about mile south of the Y-12 complex. Both Bear Cr eek 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 industriali zed 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 fora ging 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 th e proposed facility would also primarily occur during the day and would not disrupt any gray bats that mi ght 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 gr ay 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 ge neral 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 Flor ida. 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, I ndiana 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 ripa rian 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 th e 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 num ber of “secondary” roosts, which are used intermittently and by fewer bats, especially during periods of precip itation 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 swar m 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 lactati ng Indiana bats, some of which may fly up to 1.5 miles from upland roosts. Indiana bats also forage within th e canopy of upland forests, over clearings with early successional vegetation (e.g., old fields), along the borders of croplands, along w ooded 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, f lies, mosquitoes, and midges are major prey items. Other prey include bees, wasps, flying ants, beetles, leafhoppe rs, 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 a nd 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 I ndiana bats exists in White Oak Blowhole Cave, located in Blount County in the western end of the Gr eat Smoky Mountains National Park. This cave has been designated as critical habitat for this species. A few Indian a 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 be ing found south of Kentucky. Recent collections of
individual Indiana bats have also been recorded fro m 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 fo r 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 th e Clinch River (Melton Hill Lake) and Poplar Creek at ETTP. Upper Bear Creek and EFPC are narrow, small st reams 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 Sept ember. 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 industriali zed 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 cons truction was required, these activities would also not directly impact any of the potential foraging habitat th at 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 be01-217(doc)/093002 8 produced by the facility that could directly impact fora ging 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 ar e not conducive to the species being present. Habitat of the glochidia is initially within the gills of the fema le, then in the water column, and finally attached to a suitable fish host. Habitat requirements for the juven ile stage are unknown. Any alteration of the life-stagespecific habitats during the pink mucket’s lifecycle woul d likely affect the long-term success of a population. In addition, impoundments and surface water contaminan ts are known to adversely affect this species and
contribute to its decline in numbers.

The species has an elliptical-shaped shell and is genera lly 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 havi ng 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 smoot h 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 th e females during siphoning and results in the eggs being fertilized. The embryos develop into the glochidia insi de 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 (Te nnessee, Alabama) and Cumberland (Te nnessee, Kentucky) rivers and in the Osage and Meramec rivers in Missouri. Smalle r populations have been found in the Clinch River (Tennessee); Green River (Kentucky); Kanawha River (W est Virginia); Big, Black, and Little Black and Gasconde rivers (Missouri); and Cu rrent 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 ha ve 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 st reams with low flow. Both streams also receive low levels of various contaminant inputs from several sour ces. Appropriate engineering controls, administrative procedures, and emergency management protocols w ould 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 c onclude 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 Informa tion 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 Compreh ensive Management Program for the Storage, Transportation, and Disposition of Pote ntially Reusable Uranium Materials , DOE/EA-1393. Prepared for the U.S. Department of Energy by Science A pplications 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. Fi sh 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 He nry, Tennessee Valley Authority, to Mike Deacon, Science Applications Internati onal Corporation, May 4, 2000.

KBWG (Kentucky Bat Working Group). 1997. “Protecti on 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 Mi ke 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
ASSESSMENT01-217(doc)/09300201-217(doc)/093002 A-iii 

## TABLE OF CONTENTS

LIST OF FIGURES ................................................................................................................ .................A-iv

LIST OF TABLES................................................................................................................. ..................A-iv

ACRONYMS...........................................................................................................................................A-iv

A.1 INTR ODUCTION.............................................................................................................................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 Term s for Accident Sequences.........................................................A-7
A.3.3 Evaluation of Source Term Pa rameters and Fr equencies........................................................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-2201-217(doc)/093002 A-iv 

## LIST OF FIGURES

A.1 Frequency and consequence ranking matrix ...............................................................................A- 19



## LIST OF TABLES

A.1 Uranium management interi m storage alte rnatives .......................................................................A-1 A.2 Uranium management disposition options ....................................................................................A -2 A.3 Uranium management interim storage inventories........................................................................A-2 A.4 Uranium management dispos ition 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 parame ters 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-1 8 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 Site01-217(doc)/093002 A-1 

## APPENDIX A

HAZARD AND ACCIDENT ANALYSIS FOR
URANIUM MANAGEMENT PROGAMMATIC ENVIRONMENTAL
ASSESSMENT

A.1 INTRODUCTION

This appendix discusses the systematic identifi cation 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 th e identified hazards to develop into accidents. This appendix presents the potential consequences and risks to workers (imme diate and co-located) and members of the public. Risks are evaluated for routine operati ons and nonroutine (accident) conditions.

Hazards and accidents are considered for a numbe r of interim storage alternatives and disposition options, as described in Chap. 2 of the progra mmatic environmental assessment and summarized in
Tables A.1 and A.2. Inventories for each interim stor age 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 mate rial 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 envi ronmental assessment.
PORTS = Portsmouth Gase ous 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 di stance 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 envi ronmental assessment.

Table A.3. Uranium management interim storage inventories

Current storage Additional materials to
be moved

Alternative Site/form Amount,
10 3 MTU Number of
containers Amount,
10 3 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 22,12901-217(doc)/093002 A-3 Table A.3. Uranium management interim storage inventories (continued)

Current storage Additional materials to
be moved

Alternative Site/form Amount,
10 3 MTU Number of
containers Amount,
10 3 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 P GDP = Paducah Gaseous Diffusion Plant. Environmental Laboratory. PORTS = Portsmouth Gaseous Diffusion Plant.
MTU = metric tons of uraniu m. SRS = Savannah River Site.

Table A.4. Uranium management disposition option inventories

Disposition option Descri ption Material type(s) Amount (10 3 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 a lternative 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 su rveillance 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 th e materials themselves provide significant shielding. These dose rates are considered neglig ible 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, a nd 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 assume d 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 availa ble for storage or disposition in existing buildings. On-site fire department response, however, is assumed for all storage alternativ es 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 potentia l 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 pr imary focus of the hazard survey was to identify those specific hazards that exist for each identified alternative and to ev aluate 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 fi re 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. Eval uation of accident frequency is largely qualitative and results in an estimate of the postulated accident scenarios’ frequencies of o ccurrence. These are then assigned to high, moderate, low, or negligible categor ies 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. Accide nts 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 maximu m consequences and risks for each alternative. These bounding accidents are discussed below.

Table A.5. Postulated accidents identi fied for uranium management activities

Operational events External events Activity Fire Container breach Natural phenomena01-217(doc)/093002 A-5 Table A.5. Postulated accidents identi fied 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 antic ipated to occur during the lifetime of the facility. Natural phenomena of this probability class include desi gn 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 gaso line/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 c ontainers, 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 rel eases from leaking (primarily due to long-term corrosion); forklift puncture during movement of othe r 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 th e 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 hazar d 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 th at 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 fac ilities 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 Gase ous 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 ai r 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 sm all fires may occur due to electrical shorts or downed power lines. Any fires would be scattered th roughout 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 fac ilities are assumed destroyed, and all roadways are blocked by debris. Therefore, there is no fire mitiga tion 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 disp ersion (and, therefore, greatly reduced airborne concentration) for high wind conditions than for th e 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 tornado es, including the risks from wind-driven projectiles. With respect to such projectiles, unpublished pre liminary 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 highe r 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 respirab le particle size range (<10 microns). The source term associated with each accident is the product of four factor s 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 fre quency 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 h azardous material releases is expected to result from mechanical breaches of containers during handling acci dents. 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 w ould generally be breached in an accident, rupture of multiple
containers could occur in instances when sever al 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 th an 10% of the material is directly impacted or damaged by the event). For other containers with oxi des 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 confinemen t occur for each inventory of 10,000 containers handled. All containers will be packaged, loaded for tr ansport, 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 st orage or disposition facility is assumed to bound the risk to workers and the public from fires involving sma ller numbers of containers due to forklift or other01-217(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 Tabl es A.2 and A.3). The DR for materials in metal containers exposed to fires is 0.1. In addition, no mo re 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 (<900 o 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 uraniu m releases is expected to result from breaches of containers in an earthquake followed by a number of sm all 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 compos ite forms are the same as those for container handling events. Release factors for subsequent fires are the same as those describ ed for facility fires; however, the MAR is 10% of the actual inventory b ecause 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 ar e 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 ba sed on MARs and release pa rameters 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% 235 U for low-enriched uranium with a sp ecific activity of 7.0E-7 Ci/g. This activity is considered bounding for all types of uraniu m 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 st orage alternatives and disposition options. For the disposition options, it is assumed that the maximum am ount 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 ha ndling 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 other a 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 other a 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 other a 3.65E-05 1.45E+0101-217(doc)/093002 A-11 Table A.9. Source terms due to boundi ng 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

East 2.30E-03 9.13E+02 Facility fire

West 2.57E-04 1.02E+02

East 7.94E-04 3.15E+02 Seismic (direct release)

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+0101-217(doc)/093002 A-12 Table A.9. Source terms due to boundi ng 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 singl e 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 Gase ous 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 wo rker, 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/m 3

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 Gase ous 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 estim ated 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/m 3 ) is used for releases due to fires for all sites regardless of01-217(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 m 3 /sec based on recommendations from the International Commission on Radiological Protection.

• Inhalation 50-year committed effective dose equiva lent dose conversion factor for uranium of 1.2E+8 rem/Ci (DOE 1988).

• Consequences to facility workers based on instan taneous 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 negligib le 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 con servative assumption because, in most cases, the location of maximum consequence occurs at a dist ance 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 estimat ed 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 r eceptors are not likely to remain in a smoke plume once a fire is detected, and fire duration is sev eral hours. For container handling events or direct release from a seismic event, it is also a conserva tive assumption because the ma terial 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-14Table A.11. Radiological consequencesdue to bounding accident scenariosRadiological consequences, remAlternative/OptionAccidentscenario SiteFacility workerCo-locatedworker PublicMaximumconsequencecategoryINEEL, PGDP,Oak Ridge7.08E-03 6.36E-03 2.89E-04 NegligibleAll GeneralcontainerhandlingPORTS, SRS 7.08E-03 6.36E-03 1.57E-04 NegligibleINEEL Negligible 1.51E-03 1.51E-03 NegligiblePGDP Negligible 6.15E-06 6.15E-06 NegligiblePORTS Negligible 1.75E-02 1.75E-02 NegligibleSRS Negligible 3.46E-03 3.46E-03 NegligibleOak Ridge Negligible 1.66E-03 1.66E-03 NegligibleFacility fireMax otheraNegligible 2.05E-03 2.05E-03 NegligibleINEEL Negligible 1.01E-02 5.55E-04 NegligiblePGDP Negligible 2.52E-04 1.29E-05 NegligiblePORTS Negligible 6.57E-01 2.02E-02 NegligibleSRS Negligible 4.29E-02 1.38E-03 NegligibleOak Ridge Negligible 2.02E-02 1.07E-03 NegligibleNo ActionSeismicMax otheraNegligible 8.39E-02 4.30E-03 NegligibleFacility fireAll Negligible 3.59E-02 3.59E-02 NegligibleINEEL, PGDP, OakRidgeNegligible 1.14E+00 5.85E-02 LowCentralized storage ata single site (includescommercialprocessing/ domesticsales dispositionoption)SeismicPORTS, SRS Negligible 1.14E+00 3.50E-02 LowINEEL Negligible 3.50E-03 3.50E-03 NegligiblePGDP Negligible 5.23E-04 5.23E-04 NegligiblePORTS Negligible 2.40E-02 2.40E-02 NegligibleSRS Negligible 3.53E-03 3.53E-03 NegligibleFacility fireOak Ridge Negligible 4.27E-03 4.27E-03 NegligibleINEEL Negligible 3.69E-02 1.97E-03 NegligiblePGDP Negligible 1.03E-02 5.39E-04 NegligiblePORTS Negligible 9.15E-01 2.81E-02 NegligibleSRS Negligible 4.67E-02 1.49E-03 NegligiblePartially consolidatedstorage at severalDOE sitesSeismicOak Ridge Negligible 1.27E-01 6.55E-03 NegligibleEast Negligible 3.23E-02 3.23E-02 NegligiblePartially consolidatedstorage at two sitesFacility fireWest Negligible 3.61E-03 3.61E-03 Negligible01-217(doc)/093002 A-15Table A.11. Radiological consequencesdue to bounding accident scenariosRadiological consequences, remAlternative/OptionAccidentscenario SiteFacility workerCo-locatedworker PublicMaximumconsequencecategoryEast Negligible 1.09E+00 3.37E-02 LowSeismicWest Negligible 4.14E-02 2.19E-03 NegligiblePORTS Negligible 1.07E+00 3.27E-02 LowSRS Negligible 5.38E-02 1.86E-03 NegligibleFacility fireINEEL Negligible 1.40E-02 7.36E-04 NegligiblePORTS Negligible 6.51E-01 2.00E-02 NegligibleSRS Negligible 4.96E+00 1.52E-01 LowPartially consolidatedstorage based onphysical formSeismicINEEL Negligible 5.43E-03 2.99E-04 NegligibleFacility fire Generic Negligible 1.26E-04 1.26E-04 NegligibleTransfer to researchfacilitySeismic Generic Negligible 3.99E-03 2.06E-04 NegligibleFacility fire Generic Negligible 6.30E-03 6.30E-03 NegligibleTransfer to othergovernment agencySeismic Generic Negligible 2.00E-01 1.03E-02 NegligibleFacility fire Generic Negligible 1.25E-02 1.25E-02 NegligibleForeign salesSeismic Generic Negligible 4.31E-01 2.22E-02 NegligibleaMax other represents the largest single amount at any site other than theDOE 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-16Table A.12. Toxicological consequencesdue to bounding accident scenariosToxicological consequences, mg/m3Alternative/OptionAccidentscenario SiteFacility workerCo-locatedworkerPublicMaximumconsequencecategoryINEEL, PGDP,Oak Ridge7.03E-02 6.32E-02 2.87E-03 NegligibleAll GeneralcontainerhandlingPORTS, SRS 7.03E-02 6.32E-02 1.56E-03 NegligibleINEEL Negligible 1.50E-02 1.50E-02 NegligiblePGDP Negligible 6.11E-05 6.11E-05 NegligiblePORTS Negligible 1.74E-01 1.74E-01 LowSRS Negligible 3.43E-02 3.43E-02 NegligibleOak RidgeNegligible 1.65E-02 1.65E-02 NegligibleFacility fireMax otheraNegligible 2.03E-02 2.03E-02 NegligibleINEEL Negligible 1.01E-01 5.51E-03 NegligiblePGDP Negligible 2.50E-03 1.28E-04 NegligiblePORTS Negligible 6.53E+00 2.00E-01 LowSRS Negligible 4.26E-01 1.37E-02 NegligibleOak RidgeNegligible 2.00E-01 1.06E-02 NegligibleNo ActionSeismicMax otheraNegligible 8.33E-01 4.27E-02 NegligibleFacility fireAllNegligible 3.56E-01 3.56E-01LowINEEL, PGDP,Oak RidgeNegligible 1.13E+01 5.81E-01 HighCentralized storage ata single site (includescommercialprocessing/domesticsales dispositionoption)SeismicPORTS, SRS Negligible 1.13E+01 3.48E-01 HighINEEL Negligible 3.47E-02 3.47E-02 NegligiblePGDP Negligible 5.19E-03 5.19E-03 NegligiblePORTS Negligible 2.39E-01 2.39E-01 LowSRS Negligible 3.51E-02 3.51E-02 NegligibleFacility fireOak Ridge Negligible 4.24E-02 4.24E-02 NegligibleINEEL Negligible 3.66E-01 1.95E-02 NegligiblePGDP Negligible 1.03E-01 5.35E-03 NegligiblePORTS Negligible 9.09E+00 2.79E-01 LowSRS Negligible 4.59E-01 1.47E-02 NegligiblePartially consolidatedstorage at severalDOE sitesSeismicOak Ridge Negligible 1.26E+00 6.51E-02 Low01-217(doc)/093002 A-17Table A.12. Toxicological consequencesdue to bounding accident scenariosToxicological consequences, mg/m3Alternative/OptionAccidentscenario SiteFacility workerCo-locatedworkerPublicMaximumconsequencecategoryEast Negligible 1.09E+01 3.35E-01 HighFacility fireWest Negligible 4.11E-02 2.18E-02 NegligibleEast Negligible 5.53E+01 1.70E+00 HighPartially consolidatedstorage at two sitesSeismicWest Negligible 4.31E-01 2.29E-02 NegligiblePORTS Negligible 2.59E-01 2.59E-01 LowSRS Negligible 8.66E-02 8.66E-02 NegligibleFacility fireINEEL Negligible 1.06E-02 1.06E-02 NegligiblePORTS Negligible 1.06E+01 3.25E-01 HighSRS Negligible 5.34E-01 1.85E-02 NegligiblePartially consolidatedstorage based onphysical formSeismicINEEL Negligible 1.39E-01 7.31E-03 NegligibleFacility fireGenericNegligible 1.25E-03 1.25E-03 NegligibleTransfer to researchfacilitySeismic Generic Negligible 3.96E-02 2.04E-03 NegligibleFacility fireGenericNegligible 6.26E-02 6.26E-02 NegligibleTransfer to othergovernment agencySeismic Generic Negligible 1.98E+00 1.02E-01 NegligibleFacility fireGenericNegligible 1.24E-01 1.24E-01LowForeign salesSeismic Generic Negligible 4.28E+00 2.20E-01 LowaMax other represents the largest single amount at any site other than theDOE 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 maximu m 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 ca tegories 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 e xpressed in terms of Emergency Response Planning Guideline (ERPG) concentrations developed by the Am erican 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/m 3 for uranium) is applied for public exposure. However, for workers, the Immediat ely Dangerous to Life and Health (IDLH) value is more appropriate. This value (10 mg/m 3 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 ma ximum 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 HighAnticipatedUnlikelyExtremelyUnlikelyBeyondExtremelyUnlikely Severity of ConsequencesFrequency 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-20Table A.15. Risks due to normal operations and accidentsAlternative/Option AccidentscenarioSiteFrequencyMaximumradiologicalconsequenceMaximumtoxicologicalconsequence RiskAll Normaloperations All Anticipated Negligible Negligible NegligibleAllGeneral handling eventsAllAnticipated Negligible Negligible NegligibleINEEL, PGDP, SRS,Oak Ridge, Max otheraNegligible Negligible NegligibleFacility firePORTSUnlikelyNegligible Low LowINEEL, PGDP, SRS,Oak Ridge, Max otheraNegligible Negligible NegligibleNo ActionSeismicPORTSExtremely unlikelyNegligible Low LowFacility fireAllUnlikely NegligibleLowLowCentralized storage ata single site (includescommercialprocessing/domesticsales dispositionoption)Seismic All Extremely unlikely Low High ModerateINEEL, PGDP, SRS,Oak RidgeNegligible Negligible NegligibleFacility firePORTSUnlikelyNegligible Low LowINEEL, PGDP, SRS,Oak RidgeNegligible Negligible NegligiblePartially consolidatedstorage at severalDOE sitesSeismicPORTSExtremely unlikelyNegligible Low LowEast NegligibleLowLowFacility fireWestUnlikelyNegligible Negligible NegligibleEast LowHighModeratePartially consolidatedstorage at two sitesSeismicWestExtremely unlikelyNegligible Negligible NegligiblePORTS NegligibleLowLowFacility fireINEEL, SRSUnlikelyNegligible Negligible NegligiblePORTS LowHighModeratePartially consolidatedstorage based onphysical formSeismicSRS, INEELExtremely unlikelyNegligible Negligible NegligibleFacility fireAllUnlikely Negligible Negligible NegligibleTransfer to researchfacilitySeismic All Extremely unlikely Negligible Negligible NegligibleFacility fireAllUnlikely Negligible Negligible NegligibleTransfer to othergovernment agencySeismic All Extremely unlikely Negligible Low Low01-217(doc)/093002 A-21Table A.15. Risks due to normal operations and accidentsAlternative/Option AccidentscenarioSiteFrequencyMaximumradiologicalconsequenceMaximumtoxicologicalconsequence RiskFacility fireAllUnlikely NegligibleLowLowForeign salesSeismic All Extremely unlikely Negligible Low LowaMax 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 In stitute 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. De partment 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/R ates 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 Atmosphe ric Administration, U.S. Department of Energy, Technical Information Center, Oak Ridge, TN.

NIOSH (National Institute for Occ upational 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 Co mmand, 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 ASSESSMENT01-217(doc)/09300201-217(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 fata lities (LCFs)........................................................................... ..... B-6
B.5 Collective crew dose ....................................................................................................... ................. B-6
B.6 Potential traffic fatalities and ai rborne 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 hour01-217(doc)/093002 B-iv01-217(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-enrich ed uranium (LEU) to and from a number of sites.

B.2 METHOD

Routes were calculated for highway from the 155 orig in 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 wh ich Envirocare in Utah was selected; 8. an “eastern commercial site,” for whic h 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. R oute distances and population densities for rural, suburban, and urban route segments were calcula ted 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 tr ansportation and dose risks for transportation accidents were estimated by calculating unit risk factors using RADTRAN 5 2 (a transportation risk

1 TRAGIS is a routing analysis tool combining graphical interf aces with an extensive highway, rail, and waterway database.
TRAGIS can be used to calculate detailed routes based on us er-specified parameters, and replaces the legacy HIGHWAY and INTERLINE routing models.

2 RADTRAN is the world standard for trans portation risk assessment. The code was de veloped at Sandia National Laboratories.
RADTRAN combines user-determined meteorol ogical, demographic, transportation, packag ing, and material data with health physics data to calculate the expected radiological consequen ces and accident risk of transporting radioactive materials.01-217(doc)/093002 B-2 assessment computer code) [Neuhauser, Kanipe, and Wein er 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). A ccident 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. Tr affic 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 standa rd RADTRAN values: (1) rural: 470 vehicles per hour (vph), (2) suburban: 780 vph, and (3) urba n: 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 Neuha user (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 su rface is assumed to be 1 mrem/hr from a drum or standard waste box, so that adjacent drums would ha ve 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 us ing 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

238 U 0.007 0.992 0.969

235 U 0.0025 0.00711 0.03

234 U 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 we re assumed. Dispersion was calculated using RADTRAN, which incorporates a Gaussian disp ersion model. The same model and assumptions
were used to calculate airborne concentrations of uranium.

• Fatality rates for truck and rail accidents are fro m 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 hour s 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 RADTR AN 5 (Neuhauser, Kanipe, and Weiner 2000). Route segment lengths and population densities were calculated using WebTRAGI S (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, th e 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 ra dioactive material, the accident dose risks would increase by a factor of ten but would still be neglig ible compared to the incident-free doses. Accident dose risks for the truck/rail option are somewhat la rger than for the truck-only option, because rail accident rates are somewhat larger than heavy truck accident rates.

Table B.2. Public collective do se 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) 34.6 0.00206 22.1 0.013 Centralized storage at a 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

By physical form 4.36 7.10E-04 2.15 2.94E-03 Partially consolidated 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 Gase ous 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 Gase ous 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 uran ium is less than 1/10,000 of the average background
dose.

Another comparison that may be made is to calcu late possible health effects from these exposures. International Commission on Radiological Protecti on (ICRP) Publication 60 (ICRP 1991) projects 0.0005 latent cancer fatalities (LCFs) per rem of exposure. The r esults 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 poten tially 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 (c rew) 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 worker s, 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 la tent 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) 0.0173 1.03E-06 0.0111 6.50E-06 Centralized storage at a single
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

By physical form 0.0022 3.55E-07 0.0011 1.47E-06 Partially consolidated 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 Gase ous 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) 246 11.1 Centralized storage at a single
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

By physical form 36.7 1.84 Partially consolidated 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 Gase ous Diffusion Plant.
SRS = Savannah River Site.01-217(doc)/093002 B-7 Table B.6 shows projected potential traffic fa talities from truck and rail accidents, which are comparable to projected LCFs. The table also includ es airborne concentrations of uranium and uranium compounds. The toxicity threshold for airborne uranium and uranium compound particles is 2 mg/m 3
(Lewis 1993).

Table B.6. Potential traffi c fatalities and airborne uranium concentrations

Traffic fatalities (total)

Destination Truck only Truck and rail Airborne
concentration of uranium ( μ g/m 3 )

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 Gase ous Diffusion Plant.
SRS = Savannah River Site.

Radiological impacts of transoceanic transportati on 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 ship ment 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 ASSESSMENT01-217(doc)/09300201-217(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 FO R 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 wate r....................................................................................................... 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 A ssessment ........................................................................................................ 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-2 1
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-3 4
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-5101-217(doc)/093002 C-iv 

## LIST OF TABLES

C.1 Rates and amounts of deposition of uran ium resulting from bounding accident scenarios a ........... C-3 C.2 Concentrations of uranium in soil, surface water, and sediment resulting from deposition of
uranium after accidents a .................................................................................................................. 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-car cinogenic 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 hu man receptors due to deposition of uranium on soil under bounding accident scenarios......................................................................................... C-22 C.10 Summary of chronic chemical risks to hum an 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 soil a ......................................... C-27 C.12 Radiation dose rates to ecological receptors from uranium in soil a .............................................. C-29 C.13 Chemical toxicity rates to ecological receptors from uranium in surface water and
sediment a ....................................................................................................................................... C-31 C.14 Radiation dose rates to ecological receptors from uranium in surface water and sediment a ........ C-33 C.15 Uranium toxicity benchmarks for ecological receptors ................................................................ C-35 C.16 Chemical toxicity consequences to ecol ogical 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 ecol ogical 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-4 2 C.20 Summary of chronic risks to ecological receptors due to depositi on of uranium on soil under bounding accident scenarios .............................................................................................. . C-45 C.21 Summary of chronic risks to ecological r eceptors due to deposition of uranium on surface water under bounding accident scenarios ..................................................................................... C-4 801-217(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

U T total uranium01-217(doc)/093002 C-vi01-217(doc)/093002 C-1 

## C.1 INTRODUCTION

This appendix presents an assessment of chronic ri sks 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, su rface water, and sediment
and the calculated concentrations after releases r esulting from accidents described in Appendix A;

• assesses exposure of nearby human receptors to th e 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 radiolog ical 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 pr edict the overall risk from ea ch 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 re sult 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 mode led 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 Gaussi an plume model in which the horizontal axis of the plume descends with distance from the source as partic les settle out (Pasquill 1974). The accident scenarios result in release to the atmosphere of uranium in amount s that vary with the scenario and the location. In all cases, it was assumed that all of the uranium that is re leased is released in 1 hour (Appendix A, Sect. A.3.4.1). Although that is not likely to be true in any given case, th e 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 resu lt of the equation is equivale nt 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

y zy s

where

Ds = relative deposition rate per unit area (m -2 ),

v s = deposition velocity (m/s), U = average wind velocity (m/s),

σ y = crosswind dispersion coefficient (m),

σ z = vertical dispersion coefficient (m), y = lateral distance of the deposition point from th e 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 μ m in diameter (Hanna, Briggs, and Hosker 1982) . The average wind velocity (1.5 m/s) and crosswind dispersion coefficient (calculated for atmosphe ric 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 concentra tions 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 poi nt 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 si ze of the habitat. Deposition rates and total uranium deposited per unit area are shown in Table C.1. Concen trations 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 scenarios a

Alternative Accident scenario Site Airborne
release rate (mg/s) Maximum deposition rate b (mg/m 2 /s) Total deposition c

(mg/m 2 )

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) IN EEL 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) IN EEL 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-0101-217(doc)/093002 C-4 Table C.1. Rates and amounts of deposition of uranium resulting from bounding accident scenarios a (continued)

Alternative Accident scenario Site Airborne
release rate (mg/s) Maximum deposition rate b (mg/m 2 /s) Total deposition c

(mg/m 2 ) 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 fi re 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) Generi c 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 rel ease) 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. Depart ment of Energy. INEEL = Idaho National Engineering and Environmental Laboratory.
PGDP = Paducah Gase ous Diffusion Plant.
PORTS = Portsmouth Gase ous 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 cal culation 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/m 3 ).

To illustrate the distribution of uranium concentr ations in soil downwind from a release, a fractional release rate was calculated, with Q equal to 1 g/s. As previously described, th e 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 de termined by the ratios of dissolved-to-sediment-bound uranium as well as the deposition rate. The fr action of uranium in the water column (F

w ) was calculated by using an equation presented by EPA (Eq. B-2-10, EPA 1999):

F
wc = [(1 + Kd

sw × TSS × 10 -6 ) × d

wc /d

z ] / [(1 + Kd

sw × TSS × 10 -6 ) × d

wc /d

z ) + (q bs + Kd bs × BS) × d bs /d

z ] ,

where

F
wc = fraction of deposited uranium concentration in the water column,
Kd

sw = suspended sediment/water partitioning coefficient (450 L/kg), TSS = total suspended solids ( assumed to be 10 mg/L),
10 -6 = conversion factor (kg/mg),
d

wc = depth of the water column (assumed to be 2 m),
d bs = depth of the upper sediment layer [0.03 m, default value (EPA 1999)],
d

z = combined depth of water column and sediment layer (2.03 m),
Kd bs = bed sediment/water partitioning coefficient (450 L/kg),

q bs = 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 F

wc was calculated as 0.13.01-217(doc)/093002 C-6Table C.2. Concentrations of uranium in soil, surface water, and sediment resulting from deposition of uranium after accidentsaUntilled soil(5-cm depth)Tilled soilSurface water(2-m depth)Sediment(3-cm depth)AlternativeAccident scenarioSiteConcen-trationb(mg/kg)Activityc(pCi/g)Concen-tratione(mg/kg)Activityd(pCi/g)Concen-trationd(mg/L)Activitye(pCi/L)Concen-trationf(mg/kg)Activityc(pCi/g)AllGeneral containerhandlingAll 5.76E-03 4.03E-03 1.44E-03 1.01E-03 2.94E-05 2.06E-02 8.36E-03 5.85E-03No Action Storage area fire INEEL 1.51E-02 1.06E-023.77E-03 2.64E-03 7.81E-055.47E-02 2.19E-02 1.53E-02PGDP 6.14E-054.30E-051.53E-05 1.07E-05 3.18E-072.22E-04 8.90E-05 6.23E-05PORTS1.74E-011.22E-014.36E-02 3.05E-02 9.02E-046.31E-01 2.53E-01 1.77E-01SRS 3.45E-022.41E-028.62E-03 6.04E-03 1.78E-041.25E-01 5.00E-02 3.50E-02OakRidge1.65E-021.16E-02 4.13E-03 2.89E-03 8.56E-05 5.99E-02 2.40E-02 1.68E-02Max other 2.04E-02 1.43E-02 5.10E-033.57E-03 1.06E-04 7.40E-02 2.96E-02 2.07E-02Seismic (direct release)INEEL 9.08E-03 6.35E-032.27E-03 1.59E-03 4.70E-053.29E-02 1.32E-02 9.22E-03PGDP 2.27E-041.59E-045.67E-05 3.97E-05 1.17E-068.22E-04 3.29E-04 2.30E-04PORTS5.92E-014.14E-011.48E-01 1.04E-01 3.06E-032.14E+00 8.58E-01 6.01E-01SRS 3.85E-022.69E-029.62E-03 6.74E-03 1.99E-041.39E-01 5.59E-02 3.91E-02OakRidge1.82E-021.27E-02 4.54E-03 3.18E-03 9.40E-05 6.58E-02 2.63E-02 1.84E-02Max other 7.54E-02 5.28E-02 1.89E-021.32E-02 3.90E-04 2.73E-01 1.09E-01 7.66E-02Seismic(fire) INEEL9.87E-04 6.91E-04 2.47E-04 1.73E-04 5.11E-06 3.58E-03 1.43E-03 1.00E-03PGDP 1.53E-051.07E-053.83E-06 2.68E-06 7.94E-085.56E-05 2.23E-05 1.56E-05PORTS4.06E-022.84E-021.01E-02 7.10E-03 2.10E-041.47E-01 5.88E-02 4.12E-02SRS 3.31E-032.32E-038.29E-04 5.80E-04 1.72E-051.20E-02 4.81E-03 3.37E-03OakRidge1.57E-031.10E-03 3.92E-04 2.75E-04 8.12E-06 5.69E-03 2.28E-03 1.59E-03Max other 5.11E-03 3.58E-031.28E-03 8.95E-04 2.65E-051.85E-02 7.42E-03 5.19E-03Centralized storage Storage area fire All 3.56E-01 2.49E-01 8.90E-02 6.23E-02 1.84E-03 1.29E+00 5.17E-01 3.62E-01at a single site Seismic (direct release) All1.02E+00 7.16E-01 2.56E-01 1.79E-01 5.30E-03 3.71E+00 1.49E+00 1.04E+00Seismic (fire) All7.16E-02 5.01E-02 1.79E-02 1.25E-02 3.70E-04 2.59E-01 1.04E-01 7.27E-02Partially consolidated Storage area fire INEEL 3.49E-02 2.44E-028.72E-03 6.10E-03 1.80E-041.26E-01 5.06E-02 3.54E-02storage at severalPGDP 5.22E-03 3.65E-03 1.30E-03 9.13E-04 2.70E-05 1.89E-02 7.57E-03 5.30E-03DOE sitesPORTS 2.40E-01 1.68E-01 5.99E-02 4.20E-02 1.24E-03 8.69E-01 3.48E-01 2.44E-01SRS 3.53E-022.47E-028.82E-03 6.17E-03 1.83E-041.28E-01 5.12E-02 3.58E-02Oak Ridge 4.27E-02 2.99E-02 1.07E-027.47E-03 2.21E-04 1.55E-01 6.19E-02 4.33E-0201-217(doc)/093002 C-7Table C.2. Concentrations of uranium in soil, surface water, and sediment resulting from deposition of uranium after accidentsa(continued)Untilled soil(5-cm depth)Tilled soilSurface water(2-m depth)Sediment(3-cm depth)AlternativeAccident scenarioSiteConcen-trationb(mg/kg)Activityc(pCi/g)Concen-tratione(mg/kg)Activityd(pCi/g)Concen-trationd(mg/L)Activitye(pCi/L)Concen-trationf(mg/kg)Activityc(pCi/g)Seismic (direct release)INEEL 3.32E-02 2.32E-028.29E-03 5.81E-03 1.72E-041.20E-01 4.81E-02 3.37E-02PGDP 9.33E-036.53E-032.33E-03 1.63E-03 4.83E-053.38E-02 1.35E-02 9.47E-03PORTS8.23E-015.76E-012.06E-01 1.44E-01 4.26E-032.98E+00 1.19E+00 8.36E-01SRS 4.16E-022.91E-021.04E-02 7.28E-03 2.15E-041.51E-01 6.04E-02 4.23E-02Oak Ridge 1.15E-01 8.02E-02 2.86E-022.00E-02 5.93E-04 4.15E-01 1.66E-01 1.16E-01Seismic(fire) INEEL3.00E-03 2.10E-03 7.51E-04 5.26E-04 1.55E-05 1.09E-02 4.36E-03 3.05E-03PGDP 7.09E-044.96E-041.77E-04 1.24E-04 3.67E-062.57E-03 1.03E-03 7.20E-04PORTS5.61E-023.92E-021.40E-02 9.81E-03 2.90E-042.03E-01 8.14E-02 5.69E-02SRS 3.52E-032.46E-038.79E-04 6.15E-04 1.82E-051.27E-02 5.10E-03 3.57E-03Oak Ridge 8.08E-03 5.65E-03 2.02E-031.41E-03 4.18E-05 2.93E-02 1.17E-02 8.20E-03Partially consolidated Storage area fire East 3.22E-01 2.25E-018.05E-02 5.63E-02 1.67E-031.17E+00 4.67E-01 3.27E-01storage at two sitesWest 3.60E-02 2.52E-028.99E-03 6.29E-03 1.86E-041.30E-01 5.22E-02 3.65E-02Seismic (direct release) East9.86E-01 6.90E-012.46E-01 1.73E-01 5.10E-033.57E+00 1.43E+00 1.00E+00West 3.72E-022.61E-029.31E-036.52E-03 1.93E-04 1.35E-01 5.40E-02 3.78E-02Seismic(fire) East 6.84E-02 4.79E-02 1.71E-02 1.20E-02 3.54E-04 2.48E-01 9.93E-02 6.95E-02West 3.28E-03 2.29E-03 8.19E-04 5.73E-04 1.70E-05 1.19E-02 4.75E-03 3.33E-03Partially consolidated Storage area fire PORTS 1.54E-01 1.08E-013.86E-02 2.70E-02 7.99E-045.60E-01 2.24E-01 1.57E-01storage based onSRS8.71E-026.10E-02 2.18E-02 1.52E-02 4.51E-04 3.16E-01 1.26E-01 8.85E-02physical formINEEL 1.06E-02 7.43E-03 2.65E-03 1.86E-03 5.49E-05 3.85E-02 1.54E-02 1.08E-02Seismic (direct release) PORTS 9.61E-01 6.73E-012.40E-01 1.68E-01 4.97E-033.48E+00 1.39E+00 9.76E-01SRS 4.82E-023.37E-021.20E-02 8.43E-03 2.49E-041.75E-01 6.99E-02 4.90E-02INEEL1.26E-028.79E-033.14E-03 2.20E-03 6.50E-054.55E-02 1.82E-02 1.27E-02Seismic(fire) PORTS6.49E-02 4.54E-02 1.62E-02 1.14E-02 3.36E-04 2.35E-01 9.41E-02 6.59E-02SRS 5.43E-033.80E-031.36E-03 9.50E-04 2.81E-051.97E-02 7.88E-03 5.52E-03INEEL 1.06E-03 7.43E-04 2.65E-04 1.86E-04 5.49E-06 3.85E-03 1.54E-03 1.08E-03Transfer to research Facility fireGeneric 1.26E-03 8.79E-043.14E-04 2.20E-04 6.50E-064.55E-03 1.82E-03 1.28E-03facilitySeismic (direct release)Generic 4.06E-04 2.84E-041.01E-04 7.10E-05 2.10E-061.47E-03 5.88E-04 4.12E-04Seismic (fire) Generic 2.51E-04 1.76E-04 6.29E-05 4.40E-05 1.30E-06 9.11E-04 3.65E-04 2.55E-0401-217(doc)/093002 C-8Table C.2. Concentrations of uranium in soil, surface water, and sediment resulting from deposition of uranium after accidentsa(continued)Transfer to other Facility fire Generic 6.28E-02 4.39E-02 1.57E-02 1.10E-02 3.25E-04 2.27E-01 9.11E-02 6.38E-02government agencies Seismic (direct release) Generic 2.02E-02 1.42E-02 5.06E-03 3.54E-03 1.05E-04 7.33E-02 2.94E-02 2.06E-02Seismic (fire) Generic 1.26E-02 8.79E-03 3.14E-03 2.20E-03 6.50E-05 4.55E-02 1.82E-02 1.28E-02Foreign sales Facility fire Generic 1.24E-01 8.69E-02 3.10E-02 2.17E-02 6.42E-044.50E-01 1.80E-01 1.26E-01Seismic (direct release) Generic 4.37E-02 3.06E-02 1.09E-02 7.65E-03 2.26E-041.58E-01 6.34E-02 4.44E-02Seismic (fire) Generic 2.68E-02 1.88E-02 6.70E-03 4.69E-03 1.39E-04 9.71E-02 3.89E-02 2.72E-02aCalculated from data in Table C.1 using methods discussed in Sect. 5.bDeposition (mg/m2) / (0.05 m3/m2at 5 cm depth * 1600 kg/m3density 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:

C wctot = F
wc × C wtot × d

z /d

wc ,

where

C wctot = total uranium concentration in the water column (mg/L),

F
wc = fraction of uranium in the water column (0.13 from equation above),
C wtot = total uranium concentration including wa ter and bed sediment (total deposited per m 2 /2.03 m),
d

z = combined depth of water column and sediment layer (2.03 m),
d

wc = depth of water column (2 m).

C wctot was calculated to be 6.37 × 10 -5 mg/L per mg/m 2 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 assume d to become adsorbed to sedimen t particles in the upper 2 cm of
bottom sediment.

The fraction of uranium in bed sediment (F bs ) is 1-F

wc = 0.87, and the concentration of uranium in the sediment is given (Eq. B-2-19, EPA 1999) by:

C sed = F bs × C wtot × [Kd bs /(q bs + Kd bs × BS)] × [(d

wc + d bs )/d bs ] ,

where

C sed = concentration in bed sediment (mg/kg),

F bs = fraction of uranium in bed sediment (0.87),
C wtot = total uranium concentration including water and bed sediment (total deposited per m 2 /2.03 m),
Kd bs = bed sediment/water partitioning coefficient (450 L/kg),

q bs = bed sediment porosity [0.6 L water/ L sediment, EPA default (EPA 1999)], BS = benthic solids concentration (1 kg/L),
d

wc = depth of water column (2 m),
d bs = depth of bed sediment (0.03 m).

C sed was calculated to be 1.81 × 10 -2 mg/kg per mg/m 2 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 chr onic exposure to uranium potentially released from the U.S. Department of Energy’s uranium management ac tivities. 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 presen ted as a worst-case scenario for comparison, although residential exposure is considered implausible under curre nt 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. Carci nogenic risks, non- carcinogenic hazards, and radiological doses were estimated for these pathway and receptor combinations.

This assessment was performed with the initial assump tion that all chronic exposures would be within or
below tolerable limits where tole rable 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 Envi ronmental 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 us ed 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 Ri sk Assessment Guidance (R AGS) 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 estim ates. This conversion was completed in two steps beginning with the conversion from mg/kg uranium to total uranium (U T ) activity:

U T (pCi/g) = U T (mg/kg) * 1 ́10 -6 kg soil/mg soil * 7 ́10 -7 Ci/g U * 1 ́10 12 pCi/Ci

U T = 3.55 pCi/g

The value 7 × 10 -7 curies per gram of uranium (Ci/g) represen ts the specific activity of normal uranium. Normal uranium was assumed, although the PEA i ndicates that the uranium distribution would be 85% depleted, with a specific activ ity of ~3.5E-7 Ci/g. The more conservative conversion factor is used to provide an upper-bound estimate of ca rcinogenic risk and ra diological dose (there is no impact to noncarcinogenic risk).01-217(doc)/093002 C-11Table C.3. Human health exposure parameters for the uranium accident and hazard analysisEF ED BW AT CFaIRsoilET IRairSA AF Se Te EFextPEFReceptor (d/y) (y) (kg) (d) (g/kg) (kg/d) (hr/hr) (m3/d) (m2/d) (mg/cm2) (unitless) (hr/hr) (d/d) (m3/kg)EM workerb5 1 70 365 1000 5.E-05 1.0 20 0.53 1.0 0.2 0.333 0.014 5.38E+09Industrialc250 25 70 9125 1000 5.E-05 1.0 20 0.53 1.0 0.2 0.333 0.685 5.38E+09Residentd350 30 70 10950 1000 1E-04 1.0 20 0.53 1.0 0.2 1.0 0.959 5.38E+09aFor 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 DescriptionAF for soil.bEM (emergency management) workerassumed 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 equationsIngestion risk = EPC * IRsoil * EF * ED * CF * CSFingInhalation risk = EPC *IRair * (1/PEF) * ET * EF * ED * CF * CSFinhExternal exposure risk = EPC * (1-Se) * Te * EFext * ED * CSFextNon-carcinogenic risk equationsDermal 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 equationsIngestion dose = EPC * IRsoil * EF * CF * DCFingInhalation dose = EPC *IRair * (1/PEF) * ET * EF * CF * DCFinhExternal dose = EPC * (1-Se) * Te * EFext * DCFextAF adherence factorAT averaging timeBW body weightCF conversion factorCSFx cancer slope factor (pathway x)DCFx dose conversion factor (pathway x)ED exposure durationEF exposure frequencyEFetx exposure frequency (gamma)EPC exposure point concentrationET exposure timeIRair inhalation rate (dust)IRsoil ingestion rate (soil)PEF particulateemission factorsRfD reference doseSA surface areaSe gamma shielding factorTe gamma exposure time01-217(doc)/093002 C-12 Table C.4. Summary of cancer risks

EPC a Cancer intakes (pCi) b Cancer risks Analyte (pCi/g) Ingestion Inhalation External Ingestion Inhalation External c 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 Indust rial 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 conserva tive 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

EPC a Intakes (pCi/yr) b Dose (mrem/yr) Analyte (pCi/g) Ingestion Inhalation External Ingestion Inhalation External c 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 Indust rial 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 conserva tive 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

EPC a Intakes (mg/kg-day) Hazard Analyte (mg/kg) Ingestion Derm al 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 Indust rial 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 conserva tive exposure estimate.01-217(doc)/093002 C-15Table C.7. Toxicity values for human health risk and dose calculationsRadionuclide CASRNICRPlung typeSoilingestion(Risk/pCi)Inhalation(Risk/pCi)Externalexposure(Risk/yr/pCi/g)OralchronicRfD(mg/kg-day)DermalchronicRfD(mg/kg-day)GIabsorptionfactorDermalabsorptionfactorSoilingestion(mrem/pCi)Inhalation(mrem/pCi)Externalexposure(mrem/yr/pCi/g)Uranium-234 013966-29-5 M 1.58E-10 1.14E-08 2.52E-10 2.84E-04 7.89E-03 4.02E-04Uranium-235+D 015117-96-1(+D) M 1.63E-10 1.01E-085.43E-07 2.68E-04 7.30E-03 7.58E-01Uranium-238+D 007440-61-1(+D) M 2.10E-10 9.35E-091.14E-07 2.68E-04 7.07E-03 1.29E-01Uranium NA 6.00E-04 5.10E-04 0.8500 0.001Dose factors from Federal Guidance Reports 11 and 12Ingestion dose conversion factor Inhalationdose conversion factor External infiniteIsotopesSv/Bq mrem/pCi basis Sv/Bq mrem/pCi basis Sv per mrem/s per mrem/yr perEffective Effective Effective Effective Bq s m-3 pCi/m3 pCi/gUranium-234 7.66E-08 2.8E-04 0.05 2.13E-06 7.89E-03 W 2.15E-21 7.96E-18 4.02E-04Uranium-235+D 7.23E-08 2.68E-04 1.97E-06 7.30E-03 4.06E-18 1.50E-14 7.58E-01U-235 7.19E-08 2.66E-04 0.05 1.97E-06 7.30E-03 W 3.86E-18 1.43E-14 7.21E-01Th-231 3.65E-10 1.35E-06 2.33E-10 8.63E-07 W 1.95E-19 7.22E-16 3.64E-02Uranium-238+D 7.25E-08 2.68E-04 1.91E-06 7.07E-03 6.90E-19 2.56E-15 1.29E-01U-238 6.88E-08 2.55E-04 0.05 1.90E-06 7.04E-03 W 5.52E-22 2.04E-18 1.03E-04Th-234 3.69E-09 1.37E-05 8.04E-09 2.98E-05 W 1.29E-19 4.78E-16 2.41E-02Pa-234m 4.80E-19 1.78E-15 8.97E-02Pa-234 5.84E-10 2.16E-06 1.98E-10 7.33E-07 W 6.18E-17 2.29E-13 1.15E+01For 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-16Table C.8. Uranium source termNormal uraniumAccident scenarioSiteMaterialConcentration(mg/kg)U-totalactivitya(pCi/g)U-234activityb(pCi/g)U-235activityb(pCi/g)U-238activityb(pCi/g)AllGeneral container handling Composite/T Hopper 5.76E-034.03E-031.97E-03 9.06E-05 1.97E-03No ActionStorage area fireINEEL1.51E-02 1.06E-025.16E-03 2.38E-04 5.16E-03PGDP6.14E-054.30E-052.10E-05 9.66E-07 2.10E-05PORTS1.74E-011.22E-015.96E-02 2.74E-03 5.96E-02SRS3.45E-022.41E-021.18E-02 5.43E-04 1.18E-02OakRidge 1.65E-021.16E-02 5.66E-03 2.60E-04 5.66E-03Max other2.04E-02 1.43E-02 6.99E-03 3.21E-04 6.99E-03Seismic (direct release)INEEL9.08E-03 6.35E-033.11E-03 1.43E-04 3.11E-03PGDP2.27E-041.59E-047.76E-05 3.57E-06 7.76E-05PORTS5.92E-014.14E-012.02E-01 9.31E-03 2.02E-01SRS3.85E-022.69E-021.32E-02 6.06E-04 1.32E-02OakRidge 1.82E-021.27E-02 6.21E-03 2.86E-04 6.21E-03Max other7.54E-02 5.28E-02 2.58E-02 1.19E-03 2.58E-02Seismic(fire) INEEL9.87E-046.91E-04 3.38E-041.55E-05 3.38E-04PGDP1.53E-051.07E-055.25E-06 2.41E-07 5.25E-06PORTS4.06E-022.84E-021.39E-02 6.38E-04 1.39E-02SRS3.31E-032.32E-031.13E-03 5.22E-05 1.13E-03OakRidge 1.57E-031.10E-03 5.37E-04 2.47E-05 5.37E-04Max other5.11E-03 3.58E-03 1.75E-03 8.05E-05 1.75E-03Long-termStorage area fire All3.56E-01 2.49E-01 1.22E-01 5.61E-03 1.22E-01centralized storage Seismic (direct release)All 1.02E+00 7.16E-01 3.50E-01 1.61E-02 3.50E-01Seismic (fire)All7.16E-025.01E-02 2.45E-021.13E-03 2.45E-02Consolidate at Storage areafire INEEL 3.49E-02 2.44E-02 1.19E-02 5.49E-04 1.19E-02several sitesPGDP5.22E-03 3.65E-03 1.79E-03 8.21E-05 1.79E-03PORTS2.40E-011.68E-018.20E-02 3.77E-03 8.20E-02SRS3.53E-022.47E-021.21E-02 5.55E-04 1.21E-02Oak Ridge4.27E-02 2.99E-02 1.46E-02 6.72E-04 1.46E-0201-217(doc)/093002 C-17Table C.8. Uranium source term (continued)Normal uraniumAccident scenarioSiteMaterialConcentration(mg/kg)U-totalactivitya(pCi/g)U-234activityb(pCi/g)U-235activityb(pCi/g)U-238activityb(pCi/g)Seismic (direct release)INEEL3.32E-02 2.32E-021.14E-02 5.22E-04 1.14E-02PGDP9.33E-036.53E-033.19E-03 1.47E-04 3.19E-03PORTS8.23E-015.76E-012.82E-01 1.30E-02 2.82E-01SRS4.16E-022.91E-021.42E-02 6.55E-04 1.42E-02Oak Ridge1.15E-01 8.02E-02 3.92E-02 1.80E-03 3.92E-02Seismic(fire) INEEL3.00E-032.10E-03 1.03E-034.73E-05 1.03E-03PGDP7.09E-044.96E-042.43E-04 1.12E-05 2.43E-04PORTS5.61E-023.92E-021.92E-02 8.82E-04 1.92E-02SRS3.52E-032.46E-031.20E-03 5.53E-05 1.20E-03Oak Ridge8.08E-03 5.65E-03 2.76E-03 1.27E-04 2.76E-03Consolidate at Storage area fire East3.22E-01 2.25E-01 1.10E-01 5.07E-03 1.10E-01one westernWest3.60E-02 2.52E-02 1.23E-02 5.66E-04 1.23E-02site and one Seismic (direct release) East9.86E-016.90E-013.37E-01 1.55E-02 3.37E-01eastern siteWest3.72E-02 2.61E-02 1.27E-02 5.86E-04 1.27E-02Seismic(fire) East6.84E-024.79E-02 2.34E-021.08E-03 2.34E-02West 3.28E-03 2.29E-031.12E-03 5.16E-05 1.12E-03Consolidate by Storage area fire PORTS/compound, misc., oxide1.54E-01 1.08E-015.28E-02 2.43E-03 5.28E-02physical formSRS/metal8.71E-026.10E-02 2.98E-021.37E-03 2.98E-02INEEL/reactfuel,source 1.06E-027.43E-033.63E-03 1.67E-04 3.63E-03Seismic (direct release) PORTS/compound, misc., oxide9.61E-01 6.73E-013.29E-01 1.51E-02 3.29E-01SRS/metal 4.82E-023.37E-02 1.65E-02 7.59E-04 1.65E-02INEEL/reactfuel,source 1.26E-028.79E-034.29E-03 1.98E-04 4.29E-03Seismic (fire)PORTS/compound, misc., oxide6.49E-02 4.54E-02 2.22E-02 1.02E-03 2.22E-02SRS/metal 5.43E-033.80E-03 1.86E-03 8.55E-05 1.86E-03INEEL/reactfuel, source1.06E-03 7.43E-04 3.63E-041.67E-05 3.63E-04Transfer to research Storage area fire Generic1.26E-03 8.79E-04 4.30E-04 1.98E-05 4.30E-04facilitySeismic (direct release) Generic4.06E-04 2.84E-04 1.39E-04 6.38E-06 1.39E-04Seismic (fire)Generic2.51E-04 1.76E-04 8.60E-053.96E-06 8.60E-0501-217(doc)/093002 C-18Table C.8. Uranium source term (continued)Normal uraniumAccident scenarioSiteMaterialConcentration(mg/kg)U-totalactivitya(pCi/g)U-234activityb(pCi/g)U-235activityb(pCi/g)U-238activityb(pCi/g)Transfer to other Storage area fire Generic 6.28E-02 4.39E-02 2.15E-02 9.88E-04 2.15E-02government agencies Seismic (direct release) Generic 2.02E-02 1.42E-02 6.93E-03 3.19E-04 6.93E-03Seismic (fire)Generic1.26E-02 8.79E-03 4.30E-031.98E-04 4.30E-03Foreign sales Storage area fire Generic1.24E-01 8.69E-02 4.25E-02 1.95E-03 4.25E-02Seismic (direct release) Generic4.37E-02 3.06E-02 1.50E-02 6.88E-04 1.50E-02Seismic (fire)Generic2.68E-02 1.88E-02 9.17E-034.22E-04 9.17E-031.02E+007.16E-013.50E-01 1.61E-02 3.50E-01amg 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 theHealth 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 uraniu m isotopes were calculated based on the following equations:

U-234 (pCi/g) = U-238 (pCi/g) = U T (pCi/g) / 2.046 = 3.55 / 2.046 = 1.73 pCi/g

U-235 (pCi/g) = U T (pCi/g) * 0.046 / 2.046 = (3.55*0.046) / 2.046 = 0.080 pCi/g

This approach assumes a concentrati on ratio of 1.0-to-0.046-to-1.0 for 234 U, 235 U, and 238 U, respectively. For this assessment it was also assumed that short-lived decay products (i.e., with half-life less than 6 months)
of 235 U and 238 U were present at equilibrium concentrations. Modeled soil concentrations are tabulated in
Table C.8.

C.3.2 EXPOSURE PATHWAYS

The complete exposure pathway is depe ndent 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 extern al 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 ar ea 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 follo wing 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 Assess ment Summary Table, and RfDs were taken from EPA’s Integrat ed 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 * IR soil * EF * ED * CF * CSF ing

• Inhalation risk = EPC *IR air * (1/PEF) * ET * EF * ED * CF * CSF inh

• External exposure risk = EPC * (1-S

e ) * Te * EF ext * ED * CSF ext

Hazards associated with total uranium were calculated with the following equations:

• Oral hazard = EPC * FI * IR soil * ED * EF * (1/RfD) / (AT * BW)

• Dermal hazard = EPC * CF d * 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 * IR soil * EF * CF * DCF ing

• Inhalation dose = EPC *IR air * (1/PEF) * ET * EF * CF * DCF inh

• External dose = EPC * (1-S

e ) * T

e * EF ext * DCF ext

Total risk, hazard, and dose calculations were pe rformed 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. Whil e 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 implausibl e 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 usin g the maximum modeled concentrations. These results indicate a low probability of adverse health effects fr om chronic exposure associated with the most serious
accident scenario.

C.3.5 OVERALL RISK EVALUATION

Overall risks were evaluated by combining the conse quences 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, high01-217(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 surf ace 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 inges tion of contaminated food. Aquatic biota and benthic invertebrates are exposed directly to uranium in surf ace water and sediment, re spectively. 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 contamin ated media and internal ra diation 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 becau se it ingests water and sediment as well as fish and sediment-dwelling benthic invertebrates. Because uran ium 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 recepto rs occur within the path of the airborne uranium.

C.4.3 EXPOSURE ASSESSMENT

The following three subsections describe the assessment of exposu re 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 d escribed in the description of alternatives.

The exposure assessment includes an estimate of expos ure concentrations at the locations where biota are expected to be maximally exposed under each alternativ e 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 concentrati ons were made as described in Chap. 5.

Terrestrial biota are assumed to be exposed to uran ium 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 nor mal uranium (i.e., 48.8% of total U activity as 234 U, 2.4% as

235 U, and 48.8% as 238 U).01-217(doc)/093002 C-22Table C.9. Summary of chronic radiation risks to human receptors due to deposition of uranium on soil under bounding accident scenariosRadiation riskRadiation exposureAlternative Accident scenario Site FrequencyMaximumriskConsequencelevel RiskMaximumdoseConsequencelevel RiskAllGeneral containerhandlingAll Anticipated 7.6E-09 Negligible Negligible 3.1E-04 Negligible NegligibleNo ActionStorage area fire INEEL Extremely 2.0E-08 Negligible Negligible 8.0E-04 Negligible NegligiblePGDP unlikely8.1E-11NegligibleNegligible 3.3E-06 Negligible NegligiblePORTS2.3E-07NegligibleNegligible 9.3E-03 Negligible NegligibleSRS4.6E-08NegligibleNegligible 1.8E-03 Negligible NegligibleOakRidge2.2E-08NegligibleNegligible 8.8E-04 Negligible NegligibleMax other 2.7E-08 Negligible Negligible 1.1E-03 Negligible NegligibleSeismic (direct release) INEEL Extremely 1.2E-08 Negligible Negligible 4.8E-04 Negligible NegligiblePGDP unlikely3.0E-10NegligibleNegligible 1.2E-05 Negligible NegligiblePORTS7.8E-07NegligibleNegligible 3.2E-02 Negligible NegligibleSRS5.1E-08NegligibleNegligible 2.1E-03 Negligible NegligibleOakRidge2.4E-08NegligibleNegligible 9.7E-04 Negligible NegligibleMax other 1.0E-07 Negligible Negligible 4.0E-03 Negligible NegligibleSeismic(fire)INEELExtremely1.3E-09Negligible Negligible 5.3E-05 Negligible NegligiblePGDP unlikely2.0E-11NegligibleNegligible 8.2E-07 Negligible NegligiblePORTS5.4E-08NegligibleNegligible 2.2E-03 Negligible NegligibleSRS4.4E-09NegligibleNegligible 1.8E-04 Negligible NegligibleOakRidge2.1E-09NegligibleNegligible 8.4E-05 Negligible NegligibleMax other 6.8E-09 Negligible Negligible 2.7E-04 Negligible NegligibleCentralized storage ata single siteStorage area fire All Extremelyunlikely4.7E-07 Negligible Negligible 1.9E-02 Negligible NegligibleSeismic (direct release) AllExtremelyunlikely1.4E-06 Low Low 5.5E-02 Negligible NegligibleSeismic (fire) AllExtremelyunlikely9.5E-08 Negligible Negligible 3.8E-03 Negligible NegligiblePartially consolidated Storagearea fire INEEL Extremely 4.6E-08 NegligibleNegligible 1.9E-03 Negligible Negligiblestorage at severalPGDP unlikely 6.9E-09 Negligible Negligible 2.8E-04 Negligible NegligibleDOE sitesPORTS3.2E-07 Negligible Negligible 1.3E-02 Negligible NegligibleSRS4.7E-08NegligibleNegligible 1.9E-03 Negligible NegligibleOak Ridge 5.6E-08 Negligible Negligible 2.3E-03 Negligible Negligible01-217(doc)/093002 C-23Table C.9. Summary of chronic radiation risks to human receptors due to deposition of uranium on soil under bounding accident scenarios (continued)Radiation risk Radiation exposureAlternative Accident scenario SiteFre-quencyMaximumriskConsequencelevel RiskMaximumdoseConsequencelevel RiskSeismic (direct release) INEEL Extremely 4.4E-08 Negligible Negligible 1.8E-03 Negligible NegligiblePGDP unlikely1.2E-08NegligibleNegligible 5.0E-04 Negligible NegligiblePORTS1.1E-06LowLow4.4E-02 Negligible NegligibleSRS5.5E-08NegligibleNegligible 2.2E-03 Negligible NegligibleOak Ridge 1.5E-07 Negligible Negligible 6.1E-03 Negligible NegligibleSeismic(fire)INEELExtremely4.0E-09Negligible Negligible 1.6E-04 Negligible NegligiblePGDP unlikely9.4E-10NegligibleNegligible 3.8E-05 Negligible NegligiblePORTS7.4E-08NegligibleNegligible 3.0E-03 Negligible NegligibleSRS4.6E-09NegligibleNegligible 1.9E-04 Negligible NegligibleOak Ridge 1.1E-08 Negligible Negligible 4.3E-04 Negligible NegligiblePartially consolidated Storagearea fire EastExtremely 4.3E-07 NegligibleNegligible 1.7E-02 Negligible Negligiblestorage at two sitesWestunlikely 4.8E-08 Negligible Negligible 1.9E-03 Negligible NegligibleSeismic (direct release) EastExtremely 1.3E-06 Low Low 5.3E-02 Negligible NegligibleWest unlikely4.9E-08NegligibleNegligible 2.0E-03 Negligible NegligibleSeismic(fire)East Extremely9.0E-08Negligible Negligible 3.6E-03 Negligible NegligibleWestunlikely 4.3E-09 Negligible Negligible 1.7E-04 Negligible NegligiblePartially consolidated Storagearea fire PORTS Extremely 2.0E-07 NegligibleNegligible 8.2E-03 Negligible Negligiblestorage based onSRSunlikely 1.2E-07 NegligibleNegligible 4.6E-03 Negligible Negligiblephysical formINEEL1.4E-08 NegligibleNegligible 5.7E-04 Negligible NegligibleSeismic (direct release) PORTS Extremely 1.3E-06 Low Low 5.1E-02 Negligible NegligibleSRS unlikely6.4E-08NegligibleNegligible 2.6E-03 Negligible NegligibleINEEL1.7E-08NegligibleNegligible 6.7E-04 Negligible NegligibleSeismic(fire)PORTSExtremely8.6E-08Negligible Negligible 3.5E-03 Negligible NegligibleSRS unlikely7.2E-09NegligibleNegligible 2.9E-04 Negligible NegligibleINEEL1.4E-09 Negligible Negligible 5.7E-05 Negligible NegligibleTransfer to research Facility fire Generic Extremely 1.7E-09 Negligible Negligible 6.7E-05 Negligible NegligiblefacilitySeismic (direct release) Generic unlikely 5.4E-10 Negligible Negligible 2.2E-05 Negligible NegligibleSeismic (fire) Generic3.3E-10 NegligibleNegligible 1.3E-05 Negligible Negligible01-217(doc)/093002 C-24Table C.9. Summary of chronic radiation risks to human receptors due to deposition of uranium on soil under bounding accident scenarios (continued)Radiation risk Radiation exposureAlternative Accident scenario SiteFre-quencyMaximumriskConsequencelevel RiskMaximumdoseConsequencelevel RiskTransfer to other Facility fire Generic Extremely 8.3E-08 Negligible Negligible 3.3E-03 Negligible Negligiblegovernment agencies Seismic (direct release) Generic unlikely 2.7E-08 Negligible Negligible 1.1E-03 Negligible NegligibleSeismic (fire) Generic1.7E-08 NegligibleNegligible 6.7E-04 Negligible NegligibleForeign sales Facility fire Generic Extremely 1.6E-07Negligible Negligible 6.6E-03 Negligible NegligibleSeismic (direct release) Generic unlikely 5.8E-08 Negligible Negligible 2.3E-03 Negligible NegligibleSeismic (fire) Generic3.5E-08 NegligibleNegligible 1.4E-03 Negligible NegligibleDOE = 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 ch emical risks to human receptors du e 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 releas e) 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 Extremel y 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 Storag e 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 releas e) 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 Extremel y 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 Negligible01-217(doc)/093002 C-26 Table C.10. Summary of chronic ch emical risks to human receptors du e 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 Gene ric 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. Depart ment of Energy. HQ = hazard quotient. INEEL = Idaho National Engineering and Environmental Laboratory.
PGDP = Paducah Gase ous Diffusion Plant.
PORTS = Portsmouth Gase ous 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 cont act and uptake of uranium from the surrounding soil. The concentration of uranium in plant and earthwo rm 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 ra tes 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 b ody 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 radi ation doses were calculated for both surface exposure and subsurface exposure.01-217(doc)/093002 C-27Table C.11. Chemical toxicity rates to ecological receptors from uranium in soilaReceptorFraction oftime belowgroundsurfaceb(Fbelow)Fraction oftime abovegroundsurfaceb(Fabove)BCFc(soil totissue)(g soil/g tissue)Bac(food totissue)(d/kg)IRd(kg/d)BAFe(food totissue)(g food/g tissue)Tissueconcen-trationf(mg/kg)Doseg(mg/kg ormg/kg/day)TRVh(mg/kg ormg/kg/day)HQ permg/kg soil(dose/TRV)Plant 0 1 1.70E-03 NA NA 1.70E-03 1 5 0.2Earthworm 0.9 0.1 3.30E-03 NANA 3.30E-03 1 No TRV NoneShrew 0.25 0.75 NA 2.00E-04Plant 1.24E-03 2.47E-07 NA 4.20E-10Earthworm 8.27E-03 1.65E-06 NA 5.45E-09Soil 1.24E-03 2.47E-07 NA 2.47E-07Total 2.53E-07 3.07E+00 8.24E-08Robin 0 0.5 NA 2.00E-04Plant 6.08E-02 1.22E-05 NA 2.07E-08Earthworm 6.08E-02 1.22E-05 NA 4.01E-08Soil 1.26E-02 2.53E-06 NA 2.53E-06Total 2.59E-06 1.60E+01 1.62E-07aDoses 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 immersi on in water (Blaylock, Frank, and O’Neal 1993):

D sub (rad/d) = 1.05 × F below × CFa × C soil × (F b × E b n b + F g × E g n g ) ,

where

D sub = dose (rad/d) from uranium in soil by immersion in soil,
1.05 = conversion factor to account for immersion in soil rather than water,

F below = 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

, C soil = activity of uranium in soil (pCi/g),

F b_ = absorbed fraction of energy E

_ = 1 (Blaylock, Frank, and O’Neal 1993; Table C.12),

E b n b = beta energy of the radionuclide (MeV) × proportion of disintegrations producing a g-particle (Table A.1, EPA 1993a; Table C.12),

F g_ = absorbed fraction of energy E

_ (Blaylock, Frank, and O’Neal 1993 and DOE 1997; Table C.12),

E g n g = photon energy emitted during transition from a higher to a lower energy state (MeV) × proportion of disintegrations producing a g-pa rticle (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:

D
sur = C soil × F ruf × CFb × DCF soil × ECF ,

where

D
sur = dose from surface soil (rad/d),
C soil = activity of uranium in soil (pCi/g),

F above = fraction of time spent above ground (unitless, Table C.12),

F ruf = dose rate reduction factor accounting for ground roughness (unitless) = 0.7 (Sample et al. 1997), CFb = conversion factor to convert Sv/s per Bq/m 3 to rad/d per pCi/g = 5.12 × 10 11

, DCF soil = external dose conversion factor for so il contaminated to a depth of 5 cm for 234 U (1.82 × 10 -21 ),

235 U (2.65 × 10 -18 ), or 238 U (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 gr ound (Sample et al. 1997; Table C.12).

The external surface dose rates per pCi/g of tota l 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-29Table C.12. Radiation dose rates to ecological receptors from uranium in soilaRadiation dose (rad/d) per pCi/g soilgReceptorFraction oftime belowgroundSurfaceb(Fbelow)Fraction oftime abovegroundSurfaceb(Fabove)BCFc(soil totissue)(g soil/g tissue)Bac(food totissue)(d/kg)IRd(kg/d)BAFe(food totissue)(g food/g tissue)Tissueactivityf(pCi/g tissue)Subsurface Surface Internal TotalPlant 0 1 1.70E-03 NA NA 1.70E-030.00E+00 4.72E-081.88E-06 1.93E-06Earthworm 0.9 0.1 3.30E-03 NA NA 3.30E-03 6.47E-07 4.72E-09 3.65E-06 4.30E-06Shrew 0.25 0.75 NA 2.00E-04Plant 1.24E-03 2.47E-07 4.20E-10Earthworm 8.27E-03 1.65E-06 5.45E-09Soil 1.24E-03 2.47E-07 2.47E-07Total 2.53E-07 1.83E-07 3.54E-08 2.80E-10 2.19E-07Robin 0 0.5 NA 2.00E-04Plant 6.08E-02 1.22E-05 2.07E-08Earthworm 6.08E-02 1.22E-05 4.01E-08Soil 1.26E-02 2.53E-06 2.53E-06Total 2.59E-06 0.00E+00 2.36E-08 2.87E-09 2.64E-08aDoses 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-238DCF 1.82E-21 2.65E-18 5.45E-22 Plants 0.63 0.008 0.63E_n_4.46 4.4 4.19 Earthworms 0.63 0.008 0.63E_n_0.013 0.049 0.01 Shrew 0.79 0.0115 0.79E_n_0.002 0.156 0.001 Robin 0.79 0.0115 0.7901-217(doc)/093002 C-30 Internal exposure. Internal exposures were calculated by multiplying the tissue activity by decay energy and absorption factors and conversion factors (Blayloc k, Frank, and O’Neal 1993; Sample et al. 1997):

D int = C tiss × CFa × (QF × F
a × E
a n a + F b × E b n b + F g E g n g ) ,

where

D int = internal radiation dose from incorporated uranium (rad/d),
C tiss = uranium activity in r eceptor 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,

F
a = absorbed fraction of energy E

_ = 1 (Blaylock, Frank, and O’Neal 1993),

E
a n a = alpha energy of the radionuclide (MeV) × proportion of disintegrations producing an a-particle (Table A.1, EPA 1993a; Table C.12),

F b = absorbed fraction of energy E

_ = 1 (Blaylock, Frank, and O’Neal 1993),

E b n b = beta energy of the radionuclide (MeV) × proportion of disintegrations producing a b-particle (Table A.1, EPA 1993a; Table C.12),

F g = absorbed fraction of energy E

_ (Blaylock, Frank, and O’Neal 1993 and DOE 1997; Table C.12),

E g n g = 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 al pha 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 inverteb rates 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 concentra tion by a water-to-tissue bioconcentration factor [50 L/kg tissue (NRC 1992); Table C.13]. The concentrati on of uranium in benthic invertebrate tissues was calculated by multiplying the sediment concentration by a sediment-to-tissue biocon centration 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 ingest ed 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-31Table C.13. Chemical toxicity rates to ecological receptors from uranium in surface water and sedimentaReceptorFraction oftimeexposed tosedimentb(Fsed)Fraction oftimeexposed towaterb(Fwater)BCFc(medium totissue)(kg sed or Lwater/kg tissue)Bac(food totissue)(d/kg)IRd(kg/d orL/d))BAFe(food totissue)(g food/g tissue)Tissueconcen-trationf(mg/kg)Doseg(mg/kg ormg/L ormg/kg/day)TRVh(mg/kg ormg/L ormg/kg/day)HQdose/TRVAquatic biota 0 1 5.00E+01 NA NA 5.00E+01 1.00E+00 2.60E+00 3.85E-01Sed. Inverts 0.9 0.1 9.00E-01 NA NA2.52E+02 2.80E+02 No TRV NoneHeron 0 0.5Fish NA 2.00E-04 4.09E-01 8.17E-05 NA 4.09E-03Inverts NA 2.00E-04 2.15E-02 4.30E-06 NA 1.08E-03Water NA 2.00E-04 1.08E-01 2.15E-05 NA 2.15E-05Sediment NA 2.00E-04 2.15E-02 4.30E-06 NA 1.20E-03Total 6.40E-03 1.60E+01 4.00E-04aDoses 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 calcu lated for both immersion in
surface water and immersion in sediment.

External exposure to surface water. The equation fo r external exposure by imme rsion in surface water is given by Blaylock, Frank, and O’Neal (1993):

D
sw = F below × CFa × C
sw × 0.001 × E g n g × (1- F g ) ,

where

D
sw = dose from uranium by immersion in surface water (rad/d),

F below = 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

, C
sw = activity of uranium in surface water (pCi/L), 0.001 = L water/g water,

E g n g = photon energy emitted during transition from a higher to a lower energy state (MeV) × proportion of disintegrations producing a g-pa rticle (Table A.1, EPA 1993a; Table C.14),

F g = absorbed fraction of energy E g (Blaylock, Frank, and O’Ne al 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):

D
sw = F below × CFa × C
sw × 280 × E g n g × (1- F g ) ,

where

D
sw = dose from uranium by immersion in sediment (rad/d),

F below = 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

, C
sw = activity of uranium in surface water (pCi/L), 280 = mg U/kg sediment per mg U/L water,

E g n g = photon energy emitted during transition from a higher to a lower energy state (MeV) × proportion of disintegrations producing a g-par ticle (Table A.1, EPA 1993a; Table C.14),

F g = absorbed fraction of energy E g (Blaylock, Frank, and O’Ne al 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 surfa ce 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-33Table C.14. Radiation dose rates to ecological receptors from uranium in surface water and sedimentaRadiation dose (rad/d per pCi/L)ReceptorFraction oftimeexposed tosedimentb(Fsed)Fraction oftimeexposed towaterb(Fwater)BCFc(medium totissue)(kg sed orL water/kg tissue)Bac(food totissue)(d/kg)IRd(kg/dor L/d)BAFe(food totissue)(g food/g tissue)Tissueactivity(pCi/g tissue)SedimentWaterInternalTotalAquatic biota 0 1 5.00E+01 NA NA 5.00E-02 0.00E+00 1.81E-10 4.05E-06 4.05E-06Sed. Inverts 0.9 0.1 9.00E-01 NA NA 2.52E-01 9.80E-05 2.21E-11 2.04E-05 1.18E-04Heron 0 0.5Fish NA 2.00E-04 4.09E-01 8.17E-05 4.09E-06Inverts NA 2.00E-04 2.15E-02 4.30E-06 1.08E-06Water NA 2.00E-04 1.08E-01 2.15E-05 2.15E-05Sediment NA 2.00E-04 2.15E-02 4.30E-06 1.20E-03Total 1.23E-03 0.00E+00 9.38E-11 9.96E-08 9.97E-08aDoses 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, sediment, and tissue concentration.hCalculated by equations foundin Section C.4.3.2. Radiationdose parameters are as follows:Isotope U-234 U-235 U-238 Fgfor: U-234 U-235 U-238DCF 1.82E-21 2.65E-18 5.45E-22Aquatic biota 0.94 0.0949 0.94Eana4.46 4.4 4.19 Benthic invertebrates 0.63 0.008 0.63Ebnb0.013 0.049 0.01 Heron 0.94 0.06 0.94Egng0.002 0.156 0.001NA = 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 earthwo rms (Efroymson, Will, and Suter 1997); toxicity of ingested uranium to shrews, robins, and herons (Sample, Opresko, and Su ter 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, benc hmarks 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. Hi gh doses can cause death from radiation sick ness 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 gene tic damage. The endpoint for radiation toxicity to ecological r eceptors 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 alternativ e in this section. For each a lternative, each location, and each receptor, the daily dose was divided by the be nchmark dose to calculate the HQ. If the HQ is above 1, exposure above the benchmark is indicated and fu rther 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 ra diological 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 expos ed by ingesting prey that have accumulated uranium from the water, surface water, and sediment and by dir ect 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 as sumes that all plants are exposed at the maximum soil concentration, whereas the deposition model shows that th e concentrations fall off rapidly with both lateral and longitudinal distance from the maximum point. Sec ond, the model assumes that the wind blows in only one direction, whereas variable wind directions will realis tically result in a variety of downwind directions, so deposition will be dispersed rather than along a single cen terline 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 be nchmarks 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/d ay 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/d ay 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 eco logical receptors due to de position 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 rel ease) 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-0 2 2.93E-08 5.77E-08 a single site Seismic (direct release) All 1.02E+00 2.05E-0 1 8.43E-08 1.66E-07 Seismic (fire) All 7.16E -02 1.43E-02 5.90E-09 1.16E-08 Partially consolidated Stor age area fire INEEL 3.49E-0 2 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 rel ease) 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 Stor age area fire East 3.22E-0 1 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-1001-217(doc)/093002 C-37 Table C.16. Chemical toxicity consequences to eco logical receptors due to de position 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 Stor age area fire PORTS 1.54E-0 1 3.09E-02 1.27E-08 2.50E-08 storage based on SRS 8.71E-0 2 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) Ge neric 4.06E-04 8.11E-0 5 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 Ge neric 6.28E-02 1.26E-0 2 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 Generi c 1.24E-01 2.48E-02 1.02E-08 2.01E-08 Seismic (direct release) Generi c 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. Depart ment of Energy. HQ = hazard quotient. INEEL = Idaho National Engineering and Environmental Laboratory.
PGDP = Paducah Gase ous Diffusion Plant.
PORTS = Portsmouth Gase ous Diffusion Plant.
SRS = Savannah River Site.01-217(doc)/093002 C-38 Table C.17. Radiological consequen ces 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-0 8 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 releas e) 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-0 8 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-0 9 4.72E-09 2.41E-10 2.90E-11

Max other 3.58E-03 6.91E-0 9 1.54E-08 7.84E-10 9.45E-11 Centralized storage at Storage area fire A ll 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 Storag e area fire INEEL 2.44E-02 4.71E -08 1.05E-07 5.35E-09 6.44E-10 storage at several PGDP 3.65E-0 3 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 releas e) 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 Storag e 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-0 7 5.51E-09 6.65E-10 Seismic (direct release) East 6.90E -01 1.33E-06 2.97E-0 6 1.51E-07 1.82E-08

West 2.61E-02 5.03E-0 8 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-0 9 9.86E-09 5.02E-10 6.05E-1101-217(doc)/093002 C-39 Table C.17. Radiological consequen ces 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 Storag e 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-0 6 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-0 9 3.19E-09 1.63E-10 1.96E-11 Transfer to research Facility fire Gene ric 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-0 4 3.40E-10 7.57E-10 3.85E-11 4.65E-12 Transfer to other Facility fire Generi c 4.39E-02 8.48E-08 1.89E -07 9.62E-09 1.16E-09 government agencies Seismic (direct release) Ge neric 1.42E-02 2.73E-08 6. 09E-08 3.10E-09 3.74E-10 Seismic (fire) Generic 8.79E-0 3 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-0 7 1.90E-08 2.29E-09 Seismic (direct release) Generic 3.06E -02 5.91E-08 1.32E-0 7 6.70E-09 8.08E-10 Seismic (fire) Generic 1.88E-0 2 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. Depart ment of Energy. HQ = hazard quotient. INEEL = Idaho National Engineering and Environmental Laboratory.
PGDP = Paducah Gase ous Diffusion Plant.
PORTS = Portsmouth Gase ous Diffusion Plant.
SRS = Savannah River Site.01-217(doc)/093002 C-40 Table C.18. Chemical toxicity consequences to eco logical receptors due to de position of uranium on
surface water under bound ing 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 IN EEL 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-0 5 3.30E-05 3.42E-08

Max other 1.06E-04 4.07E-05 4.23E-08 Seismic (direct release) IN EEL 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-0 5 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-0 6 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 rel ease) 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-0 4 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) IN EEL 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) Ea st 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-0901-217(doc)/093002 C-41 Table C.18. Chemical toxicity consequences to eco logical receptors due to de position 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) PO RTS 4.97E-03 1.91E-03 1.99E-06

SRS 2.49E-04 9.60E-05 9.98E-08

INEEL 6.50E-0 5 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-0 6 2.11E-06 2.20E-09 Transfer to research Facility fi re Generic 6.50E-0 6 2.50E-06 2.60E-09 facility Seismic (direct release) Generic 2.10E-06 8.08E-07 8.40E-10 Seismic (fire) Generi c 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 rel ease) Generic 1.05E-0 4 4.03E-05 4.19E-08 Seismic (fire) Generi c 6.50E-05 2.50E-05 2.60E-08 Foreign sales Facility fire Ge neric 6.42E-04 2.47E-04 2.57E-07 Seismic (direct release) Ge neric 2.26E-04 8.71E-05 9.05E-08 Seismic (fire) Generi c 1.39E-04 5.34E-05 5.55E-08

2.04E-03 2.12E-06

DOE = U.S. Depart ment of Energy. HQ = hazard quotient. INEEL = Idaho National Engineering and Environmental Laboratory.
PGDP = Paducah Gase ous Diffusion Plant.
PORTS = Portsmouth Gase ous Diffusion Plant.
SRS = Savannah River Site.01-217(doc)/093002 C-42 Table C.19. Radiological consequences to ecologi cal receptors due to depo sition of uranium on
surface water under bound ing 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-0 8 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 rel ease) 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-0 6 1.52E-04 1.29E-07 a single site Seismic (direct release) All 3.71E+00 1.50E-0 5 4.38E-04 3.70E-07 Seismic (fire) All 2.59E -01 1.05E-06 3.06E-05 2.59E-08 Partially consolidated Stor age area fire INEEL 1.26E-0 1 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 rel ease) 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 Stor age area fire East 1.17E+0 0 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-0901-217(doc)/093002 C-43 Table C.19. Radiological consequences to ecologi cal receptors due to depo sition 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 Stor age area fire PORTS 5.60E-0 1 2.27E-06 6.60E-05 5.58E-08 storage based on SRS 3.16E-0 1 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) Ge neric 1.47E-03 5.95E-0 9 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 Ge neric 2.27E-01 9.21E-0 7 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 Generi c 4.50E-01 1.82E-06 5.31E-05 4.48E-08 Seismic (direct release) Generi c 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. Depart ment of Energy. HQ = hazard quotient. INEEL = Idaho National Engineering and Environmental Laboratory.
PGDP = Paducah Gase ous Diffusion Plant.
PORTS = Portsmouth Gase ous 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 ri sk from radiation exposure of terrestrial receptors.

C.4.5.2 Surface water and sediment

Tables C.18 and C.19 show that no alternative resu lted in unacceptable risks to aquatic biota, benthic invertebrates, and predators of aqua tic 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 dir ect seismic release under cen tralized 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 evaluate d 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. Ecologi cal consequences were assigned categories as follows: HQ <0.1, negligible; HQ between 0.1 and 1, low; HQ be tween 1 and 10, moderate; and HQ greater than 10, high. Overall risks are shown in Tables C.20 (terrestri al receptors) and C.21 (receptors of uranium deposited in surface water). These tables show that overa ll risks under all alternatives are negligible.



## C.5 SUMMARY

Airborne uranium released after potential accident s 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, chroni c 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-45Table C.20. Summary of chronic risks to ecological receptors due to deposition of uranium on soil under bounding accident scenariosChemical exposureRadiation exposureAlternative Accident scenario Site FrequencyMaximumHQConsequencelevelRiskMaximumHQConsequencelevelRiskAllGeneral containerhandlingAll Anticipated 1.2E-03 Negligible Negligible 1.7E-08 Negligible NegligibleNo ActionStorage area fire INEEL Extremely 3.0E-03 Negligible Negligible 4.5E-08 Negligible NegligiblePGDP unlikely1.2E-05NegligibleNegligible 1.8E-10 Negligible NegligiblePORTS3.5E-02NegligibleNegligible 5.2E-07 Negligible NegligibleSRS6.9E-03NegligibleNegligible 1.0E-07 Negligible NegligibleOakRidge3.3E-03NegligibleNegligible 5.0E-08 Negligible NegligibleMax other 4.1E-03 Negligible Negligible 6.1E-08 Negligible NegligibleSeismic (direct release) INEEL Extremely 1.8E-03 Negligible Negligible 2.7E-08 Negligible NegligiblePGDP unlikely4.5E-05NegligibleNegligible 6.8E-10 Negligible NegligiblePORTS1.2E-01LowLow1.8E-06 Negligible NegligibleSRS7.7E-03NegligibleNegligible 1.2E-07 Negligible NegligibleOakRidge3.6E-03NegligibleNegligible 5.5E-08 Negligible NegligibleMax other 1.5E-02 Negligible Negligible 2.3E-07 Negligible NegligibleSeismic(fire)INEELExtremely2.0E-04Negligible Negligible 3.0E-09 Negligible NegligiblePGDP unlikely3.1E-06NegligibleNegligible 4.6E-11 Negligible NegligiblePORTS8.1E-03NegligibleNegligible 1.2E-07 Negligible NegligibleSRS6.6E-04NegligibleNegligible 1.0E-08 Negligible NegligibleOakRidge3.1E-04NegligibleNegligible 4.7E-09 Negligible NegligibleMaxother1.0E-03NegligibleNegligible 1.5E-08 Negligible NegligibleCentralized storage at asingle siteStorage area fire AllExtremelyunlikely 7.1E-02 Negligible Negligible 1.1E-06 Negligible NegligibleSeismic (direct release) AllExtremelyunlikely 2.0E-01 Low Low 3.1E-06 Negligible NegligibleSeismic (fire) AllExtremelyunlikely1.4E-02 Negligible Negligible 2.2E-07 Negligible NegligiblePartially consolidated Storagearea fire INEEL Extremely 7.0E-03 NegligibleNegligible 1.0E-07 Negligible Negligiblestorage at severalPGDP unlikely 1.0E-03 Negligible Negligible 1.6E-08 Negligible NegligibleDOE sitesPORTS4.8E-02 Negligible Negligible 7.2E-07 Negligible NegligibleSRS7.1E-03NegligibleNegligible 1.1E-07 Negligible NegligibleOak Ridge 8.5E-03 Negligible Negligible 1.3E-07 Negligible Negligible01-217(doc)/093002 C-46Table C.20. Summary of chronic risks to ecological receptors due to deposition of uranium on soil under bounding accident scenarios (continued)Chemical exposureRadiation exposureAlternative Accident scenario Site FrequencyMaximumHQConsequencelevel RiskMaximumHQConsequencelevel RiskSeismic (direct release) INEEL Extremely 6.6E-03 Negligible Negligible 1.0E-07 Negligible NegligiblePGDP unlikely1.9E-03NegligibleNegligible 2.8E-08 Negligible NegligiblePORTS1.6E-01LowLow2.5E-06 Negligible NegligibleSRS8.3E-03NegligibleNegligible 1.3E-07 Negligible NegligibleOak Ridge 2.3E-02 Negligible Negligible 3.4E-07 Negligible NegligibleSeismic(fire)INEELExtremely6.0E-04Negligible Negligible 9.0E-09 Negligible NegligiblePGDP unlikely1.4E-04NegligibleNegligible 2.1E-09 Negligible NegligiblePORTS1.1E-02NegligibleNegligible 1.7E-07 Negligible NegligibleSRS7.0E-04NegligibleNegligible 1.1E-08 Negligible NegligibleOakRidge1.6E-03NegligibleNegligible 2.4E-08 Negligible NegligiblePartially consolidated Storagearea fire EastExtremely 6.4E-02 NegligibleNegligible 9.7E-07 Negligible Negligiblestorage at two sitesWestunlikely 7.2E-03 Negligible Negligible 1.1E-07 Negligible NegligibleSeismic (direct release) EastExtremely 2.0E-01 Low Low 3.0E-06 Negligible NegligibleWest unlikely7.4E-03NegligibleNegligible 1.1E-07 Negligible NegligibleSeismic(fire)East Extremely1.4E-02Negligible Negligible 2.1E-07 Negligible NegligibleWestunlikely 6.6E-04 Negligible Negligible 9.9E-09 Negligible NegligiblePartially consolidated Storagearea fire PORTS Extremely 3.1E-02 NegligibleNegligible 4.6E-07 Negligible Negligiblestorage based onSRSunlikely 1.7E-02 NegligibleNegligible 2.6E-07 Negligible Negligiblephysical formINEEL2.1E-03 NegligibleNegligible 3.2E-08 Negligible NegligibleSeismic (direct release) PORTS Extremely 1.9E-01 Low Low 2.9E-06 Negligible NegligibleSRS unlikely9.6E-03NegligibleNegligible 1.5E-07 Negligible NegligibleINEEL2.5E-03NegligibleNegligible 3.8E-08 Negligible NegligibleSeismic(fire)PORTSExtremely1.3E-02Negligible Negligible 2.0E-07 Negligible NegligibleSRS unlikely1.1E-03NegligibleNegligible 1.6E-08 Negligible NegligibleINEEL2.1E-04 Negligible Negligible 3.2E-09 Negligible NegligibleTransfer to research Facility fire Generic Extremely 2.5E-04 Negligible Negligible 3.8E-09 Negligible NegligiblefacilitySeismic (direct release) Generic unlikely 8.1E-05 Negligible Negligible 1.2E-09 Negligible NegligibleSeismic (fire) Generic5.0E-05 NegligibleNegligible 7.6E-10 Negligible Negligible01-217(doc)/093002 C-47Table C.20. Summary of chronic risks to ecological receptors due to deposition of uranium on soil under bounding accident scenarios (continued)Chemical exposureRadiation exposureAlternative Accident scenario Site FrequencyMaximumHQConsequencelevel RiskMaximumHQConsequencelevel RiskTransfer to other Facility fire Generic Extremely 1.3E-02 Negligible Negligible 1.9E-07 Negligible Negligiblegovernment Agencies Seismic (direct release) Generic unlikely 4.0E-03 Negligible Negligible 6.1E-08 Negligible NegligibleSeismic (fire) Generic2.5E-03 NegligibleNegligible 3.8E-08 Negligible NegligibleForeign sales Facility fire Generic Extremely 2.5E-02Negligible Negligible 3.7E-07 Negligible NegligibleSeismic (direct release) Generic unlikely 8.7E-03 Negligible Negligible 1.3E-07 Negligible NegligibleSeismic (fire) Generic5.4E-03 NegligibleNegligible 8.1E-08 Negligible NegligibleDOE = U.S. Department ofEnergy. 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-48Table C.21. Summary of chronic risks to ecological receptors due to deposition of uranium on surface water under bounding accident scenariosChemical exposureRadiation exposureAlternative Accident scenario Site FrequencyMaximumHQConsequencelevel RiskMaximumHQConsequencelevel RiskAllGeneral containerhandlingAll Anticipated 1.1E-05 Negligible Negligible 2.4E-06 Negligible NegligibleNo ActionStorage area fire INEEL Extremely 3.0E-05 Negligible Negligible 6.5E-06 Negligible NegligiblePGDP unlikely1.2E-07NegligibleNegligible 2.6E-08 Negligible NegligiblePORTS3.5E-04NegligibleNegligible 7.4E-05 Negligible NegligibleSRS6.9E-05NegligibleNegligible 1.5E-05 Negligible NegligibleOakRidge3.3E-05NegligibleNegligible 7.1E-06 Negligible NegligibleMax other 4.1E-05 Negligible Negligible 8.7E-06 Negligible NegligibleSeismic (direct release) INEEL Extremely 1.8E-05 Negligible Negligible 3.9E-06 Negligible NegligiblePGDP unlikely4.5E-07NegligibleNegligible 9.7E-08 Negligible NegligiblePORTS1.2E-03NegligibleNegligible 2.5E-04 Negligible NegligibleSRS7.7E-05NegligibleNegligible 1.6E-05 Negligible NegligibleOakRidge3.6E-05NegligibleNegligible 7.8E-06 Negligible NegligibleMax other 1.5E-04 Negligible Negligible 3.2E-05 Negligible NegligibleSeismic(fire)INEELExtremely2.0E-06Negligible Negligible 4.2E-07 Negligible NegligiblePGDP unlikely3.1E-08NegligibleNegligible 6.6E-09 Negligible NegligiblePORTS8.1E-05NegligibleNegligible 1.7E-05 Negligible NegligibleSRS6.6E-06NegligibleNegligible 1.4E-06 Negligible NegligibleOakRidge3.1E-06NegligibleNegligible 6.7E-07 Negligible NegligibleMaxother1.0E-05NegligibleNegligible 2.2E-06 Negligible NegligibleCentralized storage ata single site Storage area fire AllExtremelyunlikely 7.1E-04 Negligible Negligible 1.5E-04 Negligible NegligibleSeismic (direct release) AllExtremelyunlikely 2.0E-03 Negligible Negligible 4.4E-04 Negligible NegligibleSeismic (fire) AllExtremelyunlikely1.4E-04 Negligible Negligible 3.1E-05 Negligible NegligiblePartially consolidated Storagearea fire INEEL Extremely 6.9E-05 NegligibleNegligible 1.5E-05 Negligible Negligiblestorage at severalPGDP unlikely 1.0E-05 Negligible Negligible 2.2E-06 Negligible NegligibleDOE sitesPORTS4.8E-04 Negligible Negligible 1.0E-04 Negligible NegligibleSRS7.0E-05NegligibleNegligible 1.5E-05 Negligible NegligibleOak Ridge 8.5E-05 Negligible Negligible 1.8E-05 Negligible Negligible01-217(doc)/093002 C-49Table C.21. Summary of chronic risks to ecological receptors due to deposition of uranium on surface water under bounding accident scenarios(continued)Chemical exposureRadiation exposureAlternative Accident scenario Site FrequencyMaximumHQConsequencelevelRiskMaximumHQConsequencelevelRiskSeismic (direct release) INEEL Extremely 6.6E-05 Negligible Negligible 1.4E-05 Negligible NegligiblePGDP unlikely1.9E-05NegligibleNegligible 4.0E-06 Negligible NegligiblePORTS1.6E-03NegligibleNegligible 3.5E-04 Negligible NegligibleSRS8.3E-05NegligibleNegligible 1.8E-05 Negligible NegligibleOakRidge2.3E-04NegligibleNegligible 4.9E-05 Negligible NegligibleSeismic(fire)INEELExtremely6.0E-06Negligible Negligible 1.3E-06 Negligible NegligiblePGDP unlikely1.4E-06NegligibleNegligible 3.0E-07 Negligible NegligiblePORTS1.1E-04NegligibleNegligible 2.4E-05 Negligible NegligibleSRS7.0E-06NegligibleNegligible 1.5E-06 Negligible NegligibleOak Ridge 1.6E-05 Negligible Negligible 3.5E-06 Negligible NegligiblePartially consolidated Storagearea fire EastExtremely 6.4E-04 NegligibleNegligible 1.4E-04 Negligible Negligiblestorage at two sitesWestunlikely 7.2E-05 Negligible Negligible 1.5E-05 Negligible NegligibleSeismic (direct release) EastExtremely 2.0E-03 Negligible Negligible4.2E-04 Negligible NegligibleWest unlikely7.4E-05NegligibleNegligible 1.6E-05 Negligible NegligibleSeismic(fire)East Extremely1.4E-04Negligible Negligible 2.9E-05 Negligible NegligibleWestunlikely 6.5E-06 Negligible Negligible 1.4E-06 Negligible NegligiblePartially consolidated Storagearea fire PORTS Extremely 3.1E-04 NegligibleNegligible 6.6E-05 Negligible Negligiblestorage based onSRSunlikely 1.7E-04 NegligibleNegligible 3.7E-05 Negligible Negligiblephysical formINEEL2.1E-05 NegligibleNegligible 4.5E-06 Negligible NegligibleSeismic (direct release) PORTS Extremely 1.9E-03 Negligible Negligible4.1E-04 Negligible NegligibleSRS unlikely9.6E-05NegligibleNegligible 2.1E-05 Negligible NegligibleINEEL2.5E-05NegligibleNegligible 5.4E-06 Negligible NegligibleSeismic(fire)PORTSExtremely1.3E-04Negligible Negligible 2.8E-05 Negligible NegligibleSRS unlikely1.1E-05NegligibleNegligible 2.3E-06 Negligible NegligibleINEEL2.1E-06 Negligible Negligible 4.5E-07 Negligible NegligibleTransfer to research Facility fire Generic Extremely 2.5E-06 Negligible Negligible 5.4E-07 Negligible NegligiblefacilitySeismic (direct release) Generic unlikely 8.1E-07 Negligible Negligible 1.7E-07 Negligible NegligibleSeismic (fire) Generic5.0E-07 NegligibleNegligible 1.1E-07 Negligible NegligibleTransfer to other Facility fire Generic Extremely 1.3E-04 Negligible Negligible 2.7E-05 Negligible Negligiblegovernment agencies Seismic (direct release) Generic unlikely 4.0E-05 Negligible Negligible 8.7E-06 Negligible NegligibleSeismic (fire) Generic2.5E-05 NegligibleNegligible 5.4E-06 Negligible Negligible01-217(doc)/093002 C-50Table C.21. Summary of chronic risks to ecological receptors due to deposition of uranium on surface water under bounding accident scenarios(continued)Chemical exposureRadiation exposureAlternative Accident scenario Site FrequencyMaximumHQConsequencelevelRiskMaximumHQConsequencelevelRiskForeign sales Facility fire Generic Extremely 2.5E-04Negligible Negligible 5.3E-05 Negligible NegligibleSeismic (direct release) Generic unlikely 8.7E-05 Negligible Negligible 1.9E-05 Negligible NegligibleSeismic (fire) Generic5.3E-05 NegligibleNegligible 1.1E-05 Negligible NegligibleDOE = 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 recept ors for these groups were plants, earthworms, and
short-tailed shrews and American r obins, 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 inverteb rates, 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 e xpected frequency of occurrence of the associated accidents to determine the overall risk to ecological re ceptors 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 Re leased 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 Investigati on 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 fo r 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 So il 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 Hea lth 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 Radiat ion Protection Standards, IAEA Technical Report Series 332, Vienna, Austria.

Jones, D. S., Suter II, G. W., and Hull, R. N. 1997. Toxicological Benchmarks fo r 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 System s, Oak Ridge National La boratory, 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 T errestrial Wildlife to Contaminants, ORNL/TM-13391, Oak Ridge National Laboratory, En vironmental 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 COMMENTS01-217(doc)/09300201-217(doc)/093002 D-iii 

## TABLE OF CONTENTS

APPENDIX D.1. COMM ENTS RECEIVED...........................................................................................D-1

APPENDIX D.2 COMMEN TS AND RESPONSES..............................................................................D-5101-217(doc)/093002 D-iv01-217(doc)/093002 D-1 

## APPENDIX D.1. COMMENTS RECEIVED

DRAFT URANIUM MANAGEMENT PROGAMMATIC
ENVIRONMENTAL ASSESSMENT01-217(doc)/093002 D-2PIKE 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.

Lx39Page 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-4901-217(doc)/082602 D-50

### APPENDIX D.2. COMMENTS AND RESPONSES

Response to Comments on the Progr ammatic 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 co ld 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 invent ory 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 st orage 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 ft 2 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, th e 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-51these materials in the near future. It is anticipa ted that other potential users of these materials will be found. Reusing this material helps protect th e 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 PO RTS 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 Transp ortation Routing Analysis Information System (TRAGIS) with two modes being considered—all sh ipment 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 r eceive regarding the ultimate disposition date? Response: DOE will attempt to disposition the uran ium 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 op tion first receive consideration? Response: During the internal DOE scoping process for this proposed action several alternatives were formulated including an alternative for Int erim 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-5213. 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 init ial 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 co nstruction 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 w ith 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 co nversion 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 in curred 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 transf er 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-5320. Does USEC have any need for any of this material? Response: No. USEC uses UF 6 for their Paducah enrichment operation s, which is not in the scope of
the PEA.

21. Has the DOE considered transferring owne rship of any of the material to USEC? Response: USEC cannot use this materi al in its current form. USEC uses UF 6 , which is not in the scope of this PEA.

22. Will additional security be needed at PO RTS if any of the material is imported? Response: DOE will review the security needs at PO RTS 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 stor ing 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, F ernald, 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 ev er been classified as a waste? Response: No. All material is carefully screened prior to acceptance.

26. Please identify all of the sites currently storing th is 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 la rger 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/Envir onmental Justice Section) between race, income and the decisions to store this material at any location. Response: DOE is required to determine if low-in come 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 deci sion. There were no adverse environmental effects which would disproportionately affect low-inco me or minority populations for any of the
alternatives considered.

01-217(doc)/082202 D-5428. 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 ft 2 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, a nd 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 representativ es 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 mate rial 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-55Response: Funding for specific activities associated wi th disposition of material will continue to be requested as part of the annual budget process. Re quests 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 Ur anium 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 do es have economic value and other companies or government agencies are interested in it. Uranium materi als 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 commitm ents 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 per centage of this material from the site each year. US DOE cannot continua lly 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 additi onal 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 fundi ng 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-Por tsmouth 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-56site 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 buildi ngs 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 a nd #6, the UMG Program is committing not to exceed the storage capacity of the existing UMG fa cility. Thus, no conflicts with the Ohio Consent Decree are anticipated. No activities that conf lict 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 Portsm outh 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 ad versely 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 obtai ned if it is determined to be of economic value
and should US DOE determine that it is a waste the ma terial 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 so me 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 evaluati on 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 invol ving 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 ty pe of evaluation up front will save US DOE economic

01-217(doc)/082202 D-57resources 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 Bo ard 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 oth er 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 th e Piketon site and provide a safe environment for our residents. The DOE should build and operate the DUF 6 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 cleani ng 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 plan t. 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 DUF 6 plant, transfer land to SODI, and bring new enrichment technology to Piketon. Response: Comment noted. The uranium materials e valuated in this EA are potentially re-usable and, thus, valuable materials. They are not wastes.

01-217(doc)/082202 D-58Gilbert 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 mana ge 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 al ready been made in the Draft PEA.

50. Sec. 2.3 (“Proposed Action”, pg. 2-9). In the first paragraph, we suggest that the 1 st sentence be revised to create two sentences, to read, “DOE pr oposes 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 s ites 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 thir d paragraph, suggest revising the first sentence to read, “DOE must determine the safest, most eff ective, 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 al ready been made in the Draft PEA.

52. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The 1 st 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 storag e 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 alte rnatives 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’sconclusions. The conclusion/summary as we see the overall PEA analysis is that there were noneto-minor impacts for all of the alternatives from th e standpoint of environmental impact; negligible01-217(doc)/082202 D-59to-low impacts from the standpoint of facility accide nts (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 Conclusion s in the PEA has been modified. Should DOE determine that a Finding of No Significant Impa ct (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 great er up-front renovation/construction costs. Response: Comment noted. The focus of the PE A is to address the potential environmental impacts associated with each of the alternativ es 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 conso lidated 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 materi als 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” appear s 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 al ready 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 ch ronic consequences... appears correct, based on the analysis. However, “general handling” is pa rt of “normal operations” – which from the 1 st sentence have no impacts. It is unclear as to why the ex tra emphasis is being given to the impacts from “Normal operations”. Response: The PEA addresses both accident condi tions and normal operations (meaning those situations and activities in which accidents are not occurring).

01-217(doc)/082202 D-6057. 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 3 rd 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 containe r 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 al ready been made in the Draft PEA.

59. Sec. 4.2, “Consequences Common to All Alterna tives”, 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 al ready been made in the Draft PEA.

60. Sec. 4.2, “Consequences Common to All Alterna tives”, 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 mr em/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 al ready been made in the Draft PEA.

61. Sec. 4.2, “Consequences Common to All Alterna tives”, pg. 4-3. The phrase “dose rates not affected by stacking the containers” is somewhat unclear. “S tacking” 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 “stacki ng” containers on top of one another, or those behind each other. Overall, while there may be m itigation 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 al ready been made in the Draft PEA.

01-217(doc)/082202 D-61The assumption is that the shielding (side-by-side locating of containers) cancels out the two-deep stacking of containers. However, for the pur poses of calculating doses to the public, the more conservative assumption of no shielding is used.

62. Sec. 4.2, “Consequences Common to All Alternativ es”, 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. Considerati on should be given in Sec. 4 (“Consequences”) to adding specific Appendix references so that the r eader can easily trace the amounts given in Sec. 4 back to where the amounts were calculated and app ear 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 discu ssion is contained in various appendices, to
which the reader is directed fo r 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 ta ble. This is referred to in each table as “construction/upgrades cost”. From the methodology (Sec. 4.1, “Methods”, 2 nd 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 surv eillance & 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 a re 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 soci oeconomic 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 mo re 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 materi al would be stored. Eliminating this duplicative S&M cost at multiple storage facilities would app ear 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-62Harry 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, facilit y accidents, and normal operations have been
evaluated for all alternatives with risk s to workers and the public identified.

67. The perception of Pike County, our home, be ing a national dump site for the governments excess waste is appalling, to say the least. Response: Comment noted. The uranium material s 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 approxima tely $5.7 million dollars have been spent at Portsmouth for previous uranium management acti vities. 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 Commissi oners 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 corres pondence 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-63Carolina, or Idaho. Service personnel have re viewed the information submitted and offer the following comments relative to the PGDP in Mc Cracken County, Kentucky and the Oak Ridge Reservation (ORR) in Roane and Anderson Counties, Tennessee, for consideration. Response: DOE sent letters requesting informal cons ultation 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 e ndangered and threatened species present in the vicinity of PGDP (Section 3.2.5) generally reflects information provi ded 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 federa lly 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 concurren ce. 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 potentia l 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 re flect 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 pl aced 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 pa rticular 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, u se more open, often man-altered habitats. It is possible that new construction in the middle of th ese industrialized sites could affect the foraging and nesting areas for some migratory bird species.

01-217(doc)/082202 D-64James 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 c overed by the proposed action are potentially re-usable and would be stored temporarily until th ey 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 Ener gy to do something good for Pike County and its people. We certainly deserve much better treatme nt 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 say s 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 stor e your material (other than at the Portsmouth Gaseous Diffusion Plant). I support Rep. Ted Stri ckland 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-65D. 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 “Whe re are you from?” Your reply “Portsmouth”. Their response “Oh the Cancer Capital of the state.” Response: Comment noted. The risks to the work ers 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 Hanfor d 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 pr ior to release for public comment. At the very minimum, the subcontractor, Science Applications In ternational Corporation, should have read their own material for content and used the appropriate a nnotated outline to guarantee that all text material was included and properly organized to allow pr oper evaluation. At the maximum, all involved parties as listed on page 6-1 shoul d have properly reviewed and ve tted 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 compelli ng 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 sect ion 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 PO RTS preferred. The word “unique” has been deleted
from the text in Section 2.3.1.

01-217(doc)/082202 D-6685. The various alternatives are not numbered or cons istently named in such a way as to easily identify them for comparison. The various alternatives al so 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 Stor age 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 ref erence to “One DOE site” in the alternative title has been changed to “a Single DOE site” to be co nsistent. The discussion in Section 4.11, “Summary and Conclusions,” addresses the alternative with th e greatest potential fo r 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 be tween 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. Th is is confusing to the reader and technically inaccurate, as “natural uranium” is the proper term. Response: The definitions will be changed to refl ect the following: Natural uranium, as found in nature, is unaltered isotopically with an isotopic content of 0.711% 235 U. Normal uranium contains the same percent of 235 U as occurs in nature, but the 0.711% 235 U signature may have been attained by blending uranium of different isotopic compos itions 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 plan t 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 tran sfer 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 liste d 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 hist orical 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 locate d at the three DOE sites in Oak Ridge. Later in

01-217(doc)/082202 D-67the 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 eval uated 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 w ith 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 loca tions 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 ar e 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 inters tate 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 partic ular 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 an alysis 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 DUF 6 . The UMG inventory of
uranium does not include UF 6 . Other forms of uranium that are included in the PEA have been
addressed.

01-217(doc)/082202 D-68LOC/CAP Member

94. I also find the document exasperating, in that inform ation 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 cylinde rs appears to be outside the scope. Response: Information on the form of uranium at var ious 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 uran ium 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 UF 6 not covered in the EA? Response: It is outside the scope of the Department’s analysis for this PEA. UF 6 is being addressed
in an EIS.

98. Was scoping performed on this NEPA documen t? 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-69explanation of how its alternatives for moving materials around before deciding on their disposition addresses these goals. This explanation is essen tial 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 support ing the critical mission of DOE nuclear facility closures. For example, in the case of the Fernal d site, a sizable quantity of potentially reusable uranium had to be dispositioned in order to suppo rt 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 co sts 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 vari ous physical forms could form a discriminator among alternatives that require transport, facility upgr ade 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 in formation available at the time of an action. If changes occur in the future, prev ious 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 st orage, 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 presen t 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 in ventory; 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 socioecono mic 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-70103. 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 qu estion, 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 ot her costs, such as surv eillance 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. Repl ace 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, whic h 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, alongwith 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 ru ral/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/qualif ied 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 downgr ading 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-71W. Lee Poe, Jr. (Additional Comments—recei ved after close of comment period)

108. P2-1, 1 st Paragraph. Broaden this paragraph to cover UO 3 and state why UF 6 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. UF 6 is not part of the UMG inventory because the UMG is seeking uranium materials with minimal nuclear safety requirements. A PEIS was prepared for
DUF 6 , and a separate EIS is being prepared to further address DUF 6 . UO 3 is included in the PEA.

109. Table 2.1 on P 2-2 should be e xpanded to include other uranium materials stored for reuse or disposition. Response: Text acknowledges that other uranium ma terials 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 inve ntory 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 repackag ing of that inventory. Later the EA discusses storage of drums and steel boxes. Response: The impacts associated with repack aging 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-72114. As already pointed out the scope of the EA n eeds 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 acti on 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 selec tion 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 transpor tation analysis does not result in the absolute maximum distance. The sites are realistic possibilit ies and serve as a “reasonable worst case.” More
text was added to Section 2.3.2.

117. The alternative for interim partially consolidat ed storage by physical form described on P 2-11 in paragraph 2.3.6 calls for SRS to be the metal st orage 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 oxid es have a potential greater than metal for environmental impact in the case of an accident al release (from a fire, etc.). Powdered oxides are readily transported to the atmosphere and, sub sequently, to a number of potential receptors in a
fire scenario.

118. Paragraph 2.4 discusses DOE's belief that uran ium storage is a government asset. Two sentences later it says DOE might declare other inventory a w aste. This seems to be a two-forked statement. This paragraph should be rewritten to eliminate this apparently incons istency. 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 sec tion, 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-73120. 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 coul d find no further information on what these personnel
were assumed to do. If this uranium is a true na tional asset, it probably has the lowest surveillance staff of any of our national treasurers. The uran ium management staffing should be reexamined. Response: The UMG staff would be primarily responsible for surveilla nce and maintenance, inventory tracking and related activities, and to some extent security. The UMG storage facility has been configured to require minimum staffing le vels, 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 st atement 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 scen arios. 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 secu rity, including sabotage, for these materials, but details are not discussed in a public forum.

123. The third paragraph on P 4-2 lists K d 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 ft 2 of space is built new instead of using all ex isting space and upgrading it. While existing storage space is available, it seemed prudent to indi cate 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 othe r 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 communi cation with other DOE s ite 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 st orage were consulted and specifically asked to provide information about existing space, which could be used for uranium storage.

01-217(doc)/082202 D-74126. 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 (to tal)” and “Traffic fatalities (total).”

127. Section 4.7 on P 4-17 is a very weak analysis fo r disposition. As I indicated earlier in this set of comments and in my General Comments, the sec tion 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 ro ugh bounding of impacts would be to take the alternative with the greatest environmental im pacts and double them; ho wever, 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 h ear 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 ft 2 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 comm itment 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 ra diation dose from containers. These doses were detectable. The last sentence of this top paragr aph 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.

01-217(doc)/082202 D-75134. As I read Section A.3.1.1 on P A-5, particular ly 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 adjacen t pallets. Why then is a single breach bounding? Response: Section A.3.1.2 states that single-c ontainer 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 co ntainers 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 a re 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 s ites 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 wh ich 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 sei smically damaged facilities will be left in the damaged condition while personnel re pair 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 assumption s 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 conc rete 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 remai n, and fire suppression systems are assumed to be

01-217(doc)/082202 D-76totally destroyed. The buildings are assumed to be constructed of steel and concrete, and these materials, unlike wooden structures for exampl e, 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 subjec tive. Support for the values used should be provided in this appendix. Response: References for release facto rs are given in Section A.3.2.

143. The ARF × RIF values given in Table A.8 should be referenced. Response: References for release facto rs 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 exp ect 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 b een 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-77148. In Section A.3.3.3 include the long-term conse quences 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 tran sported 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 docume nted in the cited reference (Hand 1998).

150. The third bullet identifies 25% of the material spille d. What is the basis for value? If spilled what is assumed on cleanup and when. Response: These assumptions are docume nted in the cited reference (Hand 1998).

151. Again metal fires should be consider ed in a seismic event consequences. Response: Comment noted. See response to comment #145.

152. The second line on P A-10 uses the term conditiona l 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 an alysis. 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 standa rd 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 ade quately 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-78156. 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 a nd 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 ur anium 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 ri sk estimate. Text was added to Section C.2.1.1.

158. In Section C.2.2.2, why was the assumption ma de 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 a pproach, 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 neglig ible. This condition should be proven by reasonable analysis not assumed away. Response: The risks to residents were calculated a nd 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 calculate d 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, modera te, 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-79R. L. Huskin Savannah River Operations Office

162. Page 2-1 , Section 2.1, 2 nd Paragraph, 9 th Line; The stated typical percentage of 235 U 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% 235 U 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%, 235 U 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 ne w 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 w ould appear any estimates, such as those shown in Table 4.3, would be wholly inaccurate and deliber ately skewed in favor of PORTS. This hardly appears to be an unbiased assessment of the adequ acy 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, 1 st Sentence; As written, the statement leaves the impression that uranium shipments will increase traffic accide nts 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, 3 rd Sentence; I don’t believe this can be substantiated with the data presented. To state there would be an in crease 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 alte rnative 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 woul d 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 th e 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 familia r 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 no t 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-80167. Page B-2 , Section B.3, 8 th Dot; I believe the estimated duration of 10 days grossly underestimates the likely transit time for 14,400 km. This would e quate 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 st ated in mrem per person per day to account for various distances of shipments.

168. Page B-3 , Table B.1; See 1 st comment concerning page 2-1. Response: The values cited in Table B.1 are the ac tual values used in the analysis. See the response
to comment #162.

169. Page B-3 , Section B.3, 5 th 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 engin eering estimate. The only good test and modeling data that exist are for Type B spent fuel cask s 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 prev ious DOE NEPA projects [for example : DOE/EA-1290, Environmental Assessment: Disposition of Ru ssian 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 Commercia l Storage Site (Barnwell) is located on the SRS Site boundary. Why then, would their values fo r “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 th e 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 alternat ive be selected, could be anywhere in the eastern United States. However, we concur with the l ogic presented in the comment that adjacent storage sites should have virtually identical risk results.

The values in Table B.2 are different because in sel ecting the nodes to use in the TRAGIS routing code, there are several SRS nodes from which to sel ect 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-81Neither 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 rea der 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 pa ge 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 ra diation protection program that, in turn, would find such exposures to not be ALARA.) Response: DOE concurs that the assumptions u sed 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 Intak es 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 th e 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. Th e extraneous footnoting was removed.

01-217(doc)/082202 D-8201-217(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 docum ent should identify and address any waste streams associated w ith the re-usable uranium materials. The PEA should provide maps of pr obable transportation sources. Response: Text in the PEA has been added to acknowledge waste streams associated with disposition or in the event product is later decl ared to be a waste. Si nce 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 wa ste stream. Either the co ntainers are considered waste and disposed or they a re cleaned for reuse, creating a wa ste stream from the cleaning operations. It is unlikely that the empty contain ers 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 reaso ns, DOE cannot publish map routes.

178. The state of Tennessee reiterates its position on not being willing to accept any m aterials designated for recycle/reuse without definite disposition path ways 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 UO 2 . 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 UF 4 . The UF 4 should be added to the statement on page 2-1 that defines the scope. Response: The intent of the introductory par agraphs in Section 2.1 is to provide general background information on uranium, not to provi de 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 ASSESSMENT01-217(doc)/093002 D-5201-217(doc)/093002 D-53 

### APPENDIX D.2. COMMENTS AND RESPONSES

Response to Comments on the Progr ammatic 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 uran ium material/uranium feed currently located at
PORTS. Response: Materials deposited throughout the co ld 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 buildin g locations cannot be identified in the PEA. However, should an alternative involving the PO RTS site be selected, the UMG Program commits not to exceed the storage capacity of the existing UMG storage fac ility. This commitment to limit material within the confines of the existing UMG fa cility 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 th en be stored at PORTS on an interim basis.

3. What building(s) are included in the 450,000 squa re 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 ft 2 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 a nd 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 anticipate d 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 th e impacts/restrictions on other buildings and facilities at the site (in the context of production reuse). Response: Should an alternative involving the PO RTS 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 th e 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 Transp ortation 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-class ification 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 decla red 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 th e 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 Int erim 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 in itial 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 anal ysis 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 co nstruction 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 wi th 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 co nversion 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 c over 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, comme rcial process/domestic sales, transfer to research facilities and transf er 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 UF 6 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 owne rship of any of the material to USEC? Response: USEC cannot use this materi al in its current form. USEC uses UF 6 , which is not in the scope of this PEA.

22. Will additional security be needed at PO RTS if any of the material is imported? Response: DOE will review the security needs at PO RTS should a decision be made to move these
materials there. DOE is committed to ensuri ng appropriate security forces are maintained.

23. Has DOE consulted with and s ought the input of the Ohio Cong ressional 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 stor ing 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 caref ully screened prior to acceptance.

26. Please identify all of the sites currently storing th is 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/Enviro nmental Justice Section) between race, income and the decisions to store this material at any location. Response: DOE is required to determine if low-in come or minority populations would be adversely and disproportionately affected by the proposed acti on. 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-inco me 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 ft 2 of building upgrades. This would result in the receiving capability for loading/unloadin g needing to be improved. However, DOE is01-217(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 ret rofitting existing facilities, a la bor determination will be made to identify the work force that will be required to p erform 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, an d 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 stat ed 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. Th e 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 ne w use for this material. Please state how US DOE intends to continue funding this program so that ma terial 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 materi al should not come from the budget for the clean up and remediation of the Portsmouth facility. Response: Funding for specific activities associated wi th 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 remed iation of the Portsmouth facility.01-217(doc)/093002 D-58 34. Portions of the revenues generated from the Ur anium 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 materi als to reduce costs and promote more efficient management of these materials. Howe ver, 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 materi als 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 commitm ents 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 dispositio n strategy will include DOE’s commitment to make periodic, not to exceed five years, assessments a nd documentation of the material in storage in
order to ensure that the material co ntinues to have reuse potential.

36. The draft EA noted that US DOE considers 20 year s 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 tr eated 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 esta blishing an agreement
with the State of Ohio to continua lly evaluate the material and remove a percentage of this material from the site each year. US DOE cannot continuall y accept material at the Portsmouth facility without establishing that the material is of economic value. Response: The UMG is developing a disposition strate gy 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 disposit ion 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 additio nal 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 evalua te 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-Po rtsmouth 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 materi al 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 DOE01-217(doc)/093002 D-59 should conduct environmental characte rization 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 a nd #6, the UMG Program is committing not to exceed the storage capacity of the existing UMG fa cility. Thus, no conflicts with the Ohio Consent Decree are anticipated. No activities that conf lict 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 Portsmou th 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 ad versely 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 obtain ed if it is determined to be of economic value
and should US DOE determine that it is a waste the ma terial may not have to be moved again for final disposition. Storing the uranium material in th is 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 potenti al regulatory issues at the site. As you are aware this site is not permitted to accept any hazardous w aste from other facilities, to do so would be a violation of the permit. Response: Uranium materials are evaluated prio r 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 a re “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 in volving 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 dist ances 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 th is 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 Bo ard Member of the Southern Ohio Diversification
Initiative. Response: The UMG has no intent to accept waste materials.

45. DOE has called this waste a va luable 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 th e 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 DUF 6 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 environm ent. Storing waste here for 20 years does not. Response: Comment noted.

Teddy L. West Scioto Township Trustee

47. I am a Scioto Township Trust ee elected by the residents surroundi ng the Piketon gaseous diffusion plant, a member of the Southern Ohio Diversifi cation Initiative Board of Directors, and owner of property adjoining the Piketon gaseous diffusion plan t. 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 repr esentative 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 DUF 6 plant, transfer land to SODI, and bring new enrichment technology to Piketon. Response: Comment noted. The uranium materials e valuated 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 ma nage its potentially reusab le 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 th e 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 al ready been made in the Draft PEA.

50. Sec. 2.3 (“Proposed Action”, pg. 2-9). In the first paragraph, we suggest that the 1 st sentence be revised to create two sentences, to read, “DOE pr oposes 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 s ites 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 thir d paragraph, suggest revising the first sentence to read, “DOE must determine the safest, most e ffective, 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 al ready been made in the Draft PEA.

52. Sec. 4.11, “Summary and Conclusions”, pg. 4-19. The 1 st 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 a nd, 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 storag e 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 alte rnatives 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 th e standpoint of environmental impact; negligible-01-217(doc)/093002 D-62 to-low impacts from the standpoint of facility acci dents (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 anal yzed. The overall conclusion is that potential impacts appear not be significan t for any of the material consolidation alternatives which were analyzed. Response: Text in the Summary and Conclusion s in the PEA has been modified. Should DOE determine that a Finding of No Significant Impa ct (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 th at 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 affo rds 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, th an if the material was at several locations. These benefits outweigh the potentially great er up-front renovation /construction costs. Response: Comment noted. The focus of the PE A is to address the potential environmental impacts associated with each of the alternativ es 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 consol idated 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 materi als and a very recent, successful experience in storing uranium materi als 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” appear s inconsistent with the analysis, which indicated that for all the alternatives, the environmental impa cts 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 al ready been made in the Draft PEA.

56. Sec. 4.11, “Summary and Conc lusions”, pg. 4-19. The statement that “General handling accidents result in no more than negligible acute or ch ronic consequences... appears correct, based on the analysis. However, “general handling” is pa rt of “normal operations” – which from the 1 st 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 condit ions and normal operations (meaning those
situations and activities in which accidents ar e not occurring). Normal operations, including general handling accidents, have no more than negligible acute or chronic consequences.01-217(doc)/093002 D-6357. 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 3 rd 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 containe r 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 specify ing 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 al ready 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 al ready been made in the Draft PEA.

60. Sec. 4.2, “Consequences Common to All Alterna tives”, 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 mr em/hr, this would not seem to be “approximately background”, as 0.5 mrem/hr at 2000 hrs/year woul d 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 al ready been made in the Draft PEA.

61. Sec. 4.2, “Consequences Common to All Alternativ es”, pg. 4-3. The phrase “dose rates not affected by stacking the containers” is somewhat unclear. “S tacking” 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 al ready 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 pur poses of calculating doses to the public, the more conservative assumption of no shielding is used.

62. Sec. 4.2, “Consequences Common to All Alternativ es”, 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. Considerati on 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 app ear 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 Con sequences”), 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”, 2 nd 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 & mainte nance (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 mate rial control & accountability) – are fully included by this approach. Response: The cost numbers in the tables cited a re 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 differe nces among the various al ternatives. 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 includ ed; however, the number of perm anent workers is estimated.

65. Sec. 4, “Consequences” – General. It may be mo re 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 facili ty where material would be stor ed. Eliminating this duplicative S&M cost at multiple storage facilities would app ear 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, bei ng a national dump site for the governments excess waste is appalling, to say the least. Response: Comment noted. The uranium material s 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 approximate ly $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 tim e frame will have a negative effect on our current and future marketing of the PGDP and GCEP sites fo r 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 corres pondence requesting informal Section 7 consultation with U.S. Fish and Wildlife Service (Service) Ecological Services Field Offices in Ohio, South01-217(doc)/093002 D-66 Carolina, or Idaho. Service personnel have re viewed the information submitted and offer the following comments relative to the PGDP in Mc Cracken County, Kentucky and the Oak Ridge Reservation (ORR) in Roane and Anderson Counties, Tennessee, for consideration. Response: DOE sent letters requesting informal cons ultation 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 e ndangered and threatened species pr esent in the vicinity of PGDP (Section 3.2.5) generally reflects information provi ded 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 federa lly 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 poten tial impacts and determine if the proposed ORR alternative may affect the species. We recomme nd that you submit a copy of your assessment and finding to this office for review and concurrenc e. 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 prep ared 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 th e 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 plac ed on Federal agencies by Executive Order 13186, we believe it would also be prudent to in clude 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, u se more open, often man-altered habitats. It is possible that new construction in the middle of th ese 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 wast e 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 c overed by the proposed action are potentially re-usable and would be stored temporarily until th ey could be dispositioned. These materials are

not wastes.

77. In closing, I ask you on behalf of thousands of Pike County Cons tituents, 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 treatme nt 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 say s 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, arti cle in the Portsmouth Daily Times. I would like to strongly suggest that you find so mewhere 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 “r e-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 ar e contaminated. The trees are dying. People are dying – go to hospital in Columbus nurses ask “W here are you from?” Y our reply “Portsmouth”. Their response “Oh the Cancer Capital of the state.” Response: Comment noted. The risks to the work ers 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 Hanfor d 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 pr ior to release for public comment. At the very minimum, the subcontractor, Science Applications In ternational Corporation, should have read their own material for content and used the appropriate an notated outline to guarantee that all text material was included and properly organized to allow pr oper evaluation. At the maximum, all involved parties as listed on page 6-1 s hould have properly reviewed and vetted this document. The CAP’s primary recommendation is that DOE retract the docum ent 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 – Po rtsmouth – 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 compelli ng 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 sect ion 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 cons istently 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 referen ce to “One DOE site” in the alternative title has been changed to “a Single DOE site” to be co nsistent. 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 in terim storage alternative listed in Table 2.2 “interim partially consolidated stor age 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 uraniu m. 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 refl ect the following: Natural uranium, as found in nature, is unaltered isotopically with an isotopic content of 0.711% 235 U. Normal uranium contains the same percent of 235 U as occurs in nature, but the 0.711% 235 U signature may have been attained by blending uranium of different isotopic compos itions 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 f acility and its future role may be limited to being one of the two sites for a conversion plan t for depleted uranium hexafluoride (Paducah being the other site).

• The three sites at Oak Ridge are lumped toge ther 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 transf er 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 liste d 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 tran sferred 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 locate d at the three DOE sites in Oak Ridge. Later in01-217(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 op tion 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 loca tions 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 ar e 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 minimi ze 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 part icular 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 an alysis 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 DUF 6 . The UMG inventory of
uranium does not include UF 6 . 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 inform ation 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 var ious 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 uran ium 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 UF 6 not covered in the EA? Response: It is outside the scope of the Department’s analysis for this PEA. UF 6 is being addressed
in an EIS.

98. Was scoping performed on this NEPA documen t? 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-effectiv eness. DOE does not, however, provide a clear01-217(doc)/093002 D-72 explanation of how its alternatives for moving ma terials around before deciding on their disposition addresses these goals. This explanation is ess ential 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 support ing the critical mission of DOE nuclear facility closures. For example, in the case of the Fernal d site, a sizable quantity of potentially reusable uranium had to be dispositioned in order to supp ort the site clean-up schedule. Fernald’s review of the options for disposition of this material conc luded 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 co sts 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” impact s based on hypothetical disposition paths, the geographical locations for disposition of the vari ous physical forms could form a discriminator among alternatives that require transport, facility up grade 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 in formation 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 pr ovide 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 st orage, 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 phy sical form, DOE has received inqui ries and expressions of interest
in some of the uranium materials in the UMG inve ntory; 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 socioecono mic 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 ot her costs, such as surv eillance 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 imp act 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 Offi ce 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 ov er 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/qualif ied 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, 1 st Paragraph. Broaden this paragraph to cover UO 3 and state why UF 6 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. UF 6 is not part of the UMG inventory because the UMG is seeking uranium materials with minimal nuclear safety requirements. A PEIS was prepared for
DUF 6 , and a separate EIS is being prepared to further address DUF 6 . UO 3 is included in the PEA.01-217(doc)/093002 D-74 108. Table 2.1 on P 2-2 should be expanded to incl ude other uranium materials stored for reuse or disposition. Response: Text acknowledges that other uranium ma terials 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 manageme nt 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 inve ntory 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 repackag ing of that inventory. Later the EA discusses storage of drums and steel boxes. Response: The impacts associated with repack aging 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 fi gure 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 mi nd 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 n eeds 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. Ther e 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 sel ected a commercial site fo r uranium consolidation in this alternative but for analysis purposes, a w estern and an eastern site were selected for the transportation analysis. Does the selection of Ut ah and South Carolina maximize transportation consequences? The justification for this selec tion 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 transp ortation analysis does not result in the absolute maximum distance. The sites are realistic possibilit ies and serve as a “reasonable worst case.” More
text was added to Section 2.3.2.

116. The alternative for interim partially consolidat ed storage by physical form described on P 2-11 in paragraph 2.3.6 calls for SRS to be the metal stor age 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 oxid es 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 uran ium storage is a government asset. Two sentences later it says DOE might declare other inventory a wast e. 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 uran ium 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 al ternative of addressing them as waste is not considered further. This statement recognizes th e 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 sect ion, 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 s quare foot of storage space with ~71,900 containers in storage. I coul d 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 uran ium 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 le vels, 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 peop le 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 K d 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 ft 2 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 ot her 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 comm unication 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/al ternative. 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 secti on 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 ro ugh bounding of impacts would be to take the alternative with the greatest environmental im pacts and double them; ho wever, several factors
would lessen this effect. These are then discussed in detail in the subsections that follow.01-217(doc)/093002 D-77 127. 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 th e 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 ft 2 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. Wher e 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 ra diation dose from containers. These doses were detectable. The last sentence of this top paragr aph 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 a nd 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, particular ly 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 cont ainer breach as being a bounding accident. This same event could breach multiple containers on adjacen t pallets. Why then is a single breach bounding? Response: Section A.3.1.2 states that single-c ontainer 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.01-217(doc)/093002 D-78 135. 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 co ntainers 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 sit es 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 re pair other higher risk damaged facilities. This duration of exposure to the elements should be incl uded 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 assumption s 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 re ferences reinforced concrete and structural steel debris as fire mitigation. All storage facilities will not be constructed of conc rete thus the concrete and steel should not be relied upon as a fire mitigator. It is unclear from th e 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 remai n, and fire suppression syst ems 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.9.01-217(doc)/093002 D-79 141. The DRs in Table A.8 seem to be totally subjec tive. Support for the values used should be provided in this appendix. Response: References for release fact ors are given in Section A.3.2.

142. The ARF × RIF values given in Table A.8 should be referenced. Response: References for release fact ors 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 an alysis 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 exp ect 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 exampl e, 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 paragrap h 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 b een provided. See respon ses 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 fo r 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 conse quences 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 tran sported 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 document ed in the cited reference (Hand 1998).01-217(doc)/093002 D-80 149. The third bullet identifies 25% of the material sp illed. What is the basis fo r value? If spilled what is assumed on cleanup and when. Response: These assumptions are document ed 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 qu estioning 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 standa rd 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 ad equately 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 unde rstand. It is full of technical terms and it is not written so it can be understood by a technically trained stakeholder a nd 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 co mplete analysis, an assessment of chronic risks to humans and ecological receptors of airborne ur anium 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 a ssumed because it is the most stable (results in least mixing or dilution) and, thus, provides the most conservative ri sk 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 ma de 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 a pproach, which results in a greater potential for ecological impacts.

158. Section C.3, on P C-9, makes the judgment that residential exposure is c onsidered 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 negligib le. 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 co lumns 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 th e 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, modera te, 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, 2 nd Paragraph, 9 th Line; The stated typical percentage of 235 U 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% 235 U 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%, 235 U 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 the se 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 hardly01-217(doc)/093002 D-82 appears to be an unbiased assessme nt 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, 1 st Sentence; As written, the statement leaves the impression that uranium shipments will incr ease 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, 3 rd Sentence; I don’t believe this can be substantiated with the data presented. To state there would be an in crease in LCFs to workers and the public from this transportation program, one must calculate both th e potential LCFs resulting from the program and the LCFs potentially suffered by workers in the vicini ty 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 familia r 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 no t 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, 8 th Dot; I believe the estimated duration of 10 days grossly underestimates the likely transit time for 14,400 km. This would e quate 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 av erage of about 5,000 km, an average transit time of 10 days would seem much more reasonable. Response: The text has been changed to indica te that 14,400 km is the maximum distance port-to-port. The dose to crew me mbers is now stated in mrem per person per day to account for various distances of shipments.

167. Page B-3 , Table B.1; See 1 st 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 #162.01-217(doc)/093002 D-83 168. Page B-3 , Section B.3, 5 th 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 engine ering estimate. The only good test and modeling data that exist are for Type B spent fuel cask s 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 Ru ssian 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 fo r “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 iden tical, as they should be. 

### Response: The Barnwell site was selected to represen t 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 alternat ive 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 se lecting the nodes to use in the TRAGIS routing code, there are several SRS nodes from which to se lect 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 am ount of material in each shipment may not be known. Without an assumption of the quantity of ma terial 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 mr em 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 implem entation of a radiation protecti on program that, in turn, would find such exposures to not be ALARA.) Response: DOE concurs that the assumptions us ed were overly conservative and overstated the risk. Some assumptions have been modified (e.g., 2-hour exposure per crew member to01-217(doc)/093002 D-84 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). Th e dose rate is 1.8 mrem/hour per crew member.

172. Page C-12 , Table C.4; When using the values for Intak es 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 th e 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 Ri sk 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 in gestion 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 facto rs 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. Th e 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 w ith 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 decl ared to be a waste. Since the waste streams are dependent on the specific end use, and these a re 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 wast e 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 contain ers 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 reaso ns, 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 path ways 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 UO 2 . 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 UF 4 . The UF 4 should be added to the statement on page 2-1 that defines the scope. Response: The intent of the introductory par agraphs in Section 2.1 is to provide general background information on uranium, not to provi de 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 woul d increase the possibility that the Piketon plant’s ultimate fate would be a dump site. Response: The UMG is developing a disposition stra tegy to move the material offsite as quickly and reasonably as possible. As noted in responses 35 a nd 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 th e 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 w ill either be marketed or removed in a timely

manner. Response: DOE has committed to aggressively and p eriodically evaluate disposition strategies at Portsmouth. See response to 179 above.01-217(doc)/093002 D-86