EA - May 25, 1995
ENVIRONMENTAL ASSESSMENT FOR THE DISPOSITION OF
HIGHLY ENRICHED URANIUM FROM THE REPUBLIC OF KAZAKHSTAN
May 25, 1995
Section 1: INTRODUCTION
1.1 BACKGROUND
On September 27, 1993, President Clinton announced a policy to prevent
the proliferation of weapons of mass destruction. The President
mandated in the Nonproliferation and Export Control Policy (Appendix A)
that the United States would:
* Seek to eliminate, where possible, the accumulation of stockpiles of
highly enriched uranium (HEU); and
* Pursue the purchase of HEU from the former Soviet Union and other
countries and its conversion to peaceful use as reactor fuel.
The Department of Energy (DOE) is the Federal agency responsible for the
management, storage, and disposition of weapons-usable fissile
materials, including HEU. In November 1994, DOE acquired approximately
600 kilograms (kg) of HEU from the former Soviet Republic of Kazakhstan.
This purchase was conducted as a classified operation under the code
name "Project Sapphire." A classified Environmental Assessment (EA) was
prepared to assess the potential environmental impacts associated with
the transportation of Project Sapphire material from Kazakhstan to DOE's
Oak Ridge Reservation (ORR) Y-12 Plant for interim storage (DOE/EA
1006). DOE issued a classified Finding of No Significant Impact (FONSI)
in October 1994, and the Kazakhstan-origin HEU is currently in safe
secure interim storage at the Y-12 Plant. Versions of those documents
with the classified material deleted are currently available to the
public.
The Department now proposes to convert the Kazakhstan-origin HEU to a
material that cannot be used directly for nuclear weapons. DOE proposes
to accomplish this by blending the HEU with a low-enriched uranium (LEU)
blending stock to produce LEU in the form of uranyl nitrate that can be
used to fabricate commercial nuclear reactor fuel.
The Energy Policy Act of 1992 established the United States Enrichment
Corporation (USEC) as a wholly-owned Government corporation responsible
for the United States' uranium enrichment activities. In accordance
with these responsibilities, USEC is obtaining the blending services
associated with the Proposed Action on the behalf of DOE. After the HEU
has been blended to LEU in the form of uranyl nitrate, USEC also would
act on the behalf of DOE in the sale of that material.
On February 7, 1995, USEC issued a Request for Proposal to obtain the
required blending services to the only two commercial facilities in the
United States capable of providing these services: the Babcock & Wilcox
facility in Lynchburg, Virginia (B&W Lynchburg) and the Nuclear Fuel
Services, Inc. facility in Erwin, Tennessee (NFS Erwin). USEC received
proposals from both contractors and is currently evaluating them in
preparation of making a blending contractor selection. Both B&W
Lynchburg and NFS Erwin have indicated that they would likely enter
negotiations with General Electric's Nuclear Energy Production facility
in Wilmington, North Carolina (GE Wilmington) to provide blending stock
conversion services associated with the Proposed Action. Therefore,
this EA considers two blending site options, B&W Lynchburg and NFS
Erwin, and one representative blending stock conversion facility, GE
Wilmington.
In addition to the two commercial blending sites considered in this EA,
there are two DOE sites that could be capable of performing the required
blending services: the Y-12 Plant and the Savannah River Site near
Aiken, South Carolina (SRS).
The Y-12 Plant nuclear operations are currently shut down, and the
facilities that would be required to process the Kazakhstan-origin HEU
are not expected to be returned to service until late 1996 or early
1997.
The facilities at SRS that would have the capability to process the
Kazakhstan-origin HEU would be the F-Canyon or the H-Canyon. The F
Canyon is only partially operational at this time, and even when fully
operational can only process LEU with enrichments of one percent or
less. The H-Canyon is capable of processing all forms and enrichments
of uranium, but would not be available until September 1997, at the
earliest. Under the Proposed Action, the shipments of the HEU and
blending stock would commence by June 1995, and it is anticipated that
the Proposed Action would be completed within one year. Therefore,
neither the Y-12 Plant nor SRS would be capable of providing the
blending services associated with the Proposed Action in a timely manner
and are not considered in this EA.
In evaluating alternatives for the disposition of the Kazakhstan-origin
HEU, DOE considered the following options: blending the material down
to LEU with less than 20 percent but greater than four percent
enrichment and storing the LEU for potential future use; and blending
the material down to waste with an enrichment of less than one percent.
The option of blending to less than 20 percent but greater than four
percent enrichment would require the continued storage of the LEU until
a use was determined. Further blending would be required for use in
commercial nuclear reactor fuel if that disposition method were chosen.
Disposal of this material as waste at this enrichment level (less than
20 percent but greater than four percent) may involve criticality
concerns that would need to be accommodated. The impacts from the
initial blending would likely be similar to the impacts associated with
the Proposed Action. Non-radiological transportation impacts would
likely be slightly smaller than those associated with the Proposed
Action, given the smaller quantity of blending stock and resulting LEU,
with no fatalities occurring under accident-free conditions.
The option of blending to less than one percent enrichment and return to
DOE jurisdiction for disposal as waste would require transportation,
storage (until disposal), and disposal of an even larger quantity of
material. The impacts from the initial blending would likely be similar
to, but slightly greater than, the impacts associated with the Proposed
Action given the larger quantity of blending stock and resulting LEU.
Non-radiological transportation impacts would likely be greater than
those associated with the Proposed Action, but with no fatalities
occurring under accident-free conditions. Storage and disposal costs
would be the responsibility of the government since the material would
not be sold to a commercial vendor. Indirect impacts associated with
further processing of the uranyl nitrate into, and eventual use as,
commercial nuclear reactor fuel (including impacts associated with spent
nuclear fuel) would not occur. However, by not using the material in
commercial nuclear reactor fuel, new material may have to be mined,
milled, fluorinated, and enriched to produce an equivalent amount of
commercial nuclear reactor fuel. The creation of this new fuel material
would likely have a more substantial impact on the environment than LEU
blended from HEU as a result of the greater degree of processing and
transportation required and the creation of mill tails. Neither of
these alternatives would convert the Kazakhstan-origin HEU to peaceful
use as commercial nuclear reactor fuel. Accordingly, the more
reasonable and effective means of disposing of the Kazakhstan-origin HEU
would be to blend it to LEU for use in commercial nuclear reactor fuel
consistent with the President's Nonproliferation Policy.
A detailed cost-benefit analysis for the blending of this HEU was not
prepared for this EA nor required under the National Environmental
Policy Act (NEPA). However, DOE did consider the economic differences
between blending the material for use in commercial nuclear reactor fuel
versus blending it to less than one percent enrichment. The blending of
this HEU to less than one percent enrichment would result in a net cost
to the government, while blending the material to LEU for use in
commercial nuclear reactor fuel would generate revenue to offset the
cost of the purchase and blending of the HEU. Use in commercial nuclear
reactor fuel would also avoid the need to produce an equivalent amount
of new material and the environmental impacts associated with the
mining, processing and transportation of this material and the disposal
of mill tails.
This EA assesses the potential environmental impacts associated with
DOE's Proposed Action. The Proposed Action includes:
* Transportation of approximately 600 kg of Kazakhstan-origin HEU from
the Y-12 Plant to the blending site (B&W Lynchburg or NFS Erwin);
* Transportation of low-enriched uranium hexafluoride (UF6) blending
stock from either USEC's Paducah Gaseous Diffusion Plant in Kentucky
(USEC Paducah) or USEC's Portsmouth Gaseous Diffusion Plant in Ohio
(USEC Portsmouth) to GE Wilmington for conversion into low-enriched
uranium oxide blending stock;
* Transportation of the uranium oxide blending stock to the blending
site;
* Blending of the HEU and uranium oxide blending stock to produce LEU
in the form of uranyl nitrate; and
* Transportation of the uranyl nitrate from the blending site to USEC
Portsmouth.
The Proposed Action is presented in Figure 1.1-1. Figure 1.1-2 shows
the location of the sites involved in the Proposed Action.
A Preapproval Copy of this EA was distributed to representatives of the
affected states and Native American Tribes, and other groups and
individuals, in April 1995, for review and comment. Appendix B contains
a list of the commentors, a summary of their comments, and DOE's
responses to these comments. Based on these comments, a number of
changes have been made throughout the document to improve its clarity,
completeness, and accuracy. Appendix B also explains the modifications
made to this EA in response to these comments.
1.2 KEY ISSUES ADDRESSED
This EA addresses three key issues related to the Proposed Action:
impacts associated with the transportation of the Kazakhstan-origin HEU,
blending stock, and uranyl nitrate; impacts associated with the
conversion of the UF6 blending stock to uranium oxide blending stock;
and impacts associated with the blending of the Kazakhstan-origin HEU
and uranium oxide blending stock, including the scope of the blending
sites' current Nuclear Regulatory Commission (NRC) licenses regarding
the receipt and blending of these materials and the handling and
disposal of associated wastes. The discussion of the licensing issues
specifically considers the beryllium and plutonium constituents of the
Kazakhstan-origin HEU. A summary of the constituents of the Kazakhstan
origin HEU is included in Appendix C.
This EA also addresses potential environmental impacts with respect to
environmental justice issues. On February 11, 1994, President Clinton
signed Executive Order 12898, "Federal Actions to Address Environmental
Justice in Minority Populations and Low-Income Populations." The order
requires each Federal agency to make environmental justice part of its
mission by identifying and addressing, as appropriate,
"disproportionately high and adverse human health or environmental
effects of its programs, policies, and activities on minority
populations and low-income populations."
The Environmental Protection Agency (EPA) has convened an interagency
working group to assist in providing guidance on the implementation of
the Executive Order. In coordination with the working group, DOE is
also in the process of developing implementation guidance. Because this
guidance will describe the extent to which environmental justice issues
should be included in an EA, the approach taken in this EA may differ
somewhat from the guidance that is eventually issued and from the
approach taken in subsequent EAs.
This EA does not analyze in detail the potential impacts to biotic
resources, cultural resources, geologic resources, or socioeconomics
except where these resources may be affected during the transportation
of nuclear materials. The analysis of impacts to water resources is
based on an evaluation of existing environmental documentation. Below
are brief descriptions of why a detailed analysis of potential impacts
is not necessary for these resources.
* Biotic, Cultural, and Geologic Resources: The Proposed Action does
not involve any construction or other ground-disturbing activities, such
as grading, that could potentially impact any biotic, archaeological,
or cultural resources. No habitat would be altered or removed from
natural productivity as a result of the Proposed Action. Additionally,
no structures would be built which could either impact or be impacted by
geologic conditions, such as faulting, or by expansive or erosive soils.
* Socioeconomics: The Proposed Action would not substantially modify
the number of workers or the regional population at any location,
although a small number of additional workers would potentially be
employed at some locations as a result of the Proposed Action.
* Water Resources: Except as discussed in Section 4.3, the Proposed
Action would not require any additional withdrawals from or discharges
to surface water or groundwater other than negligible potable water
withdrawals and sanitary discharges. Section 4.3 considers the potential
impacts to water resources associated with the Proposed Action with
respect to the blending sites' current environmental permits.
This EA does not analyze potential indirect impacts (including
transportation impacts) associated with either further processing of the
uranyl nitrate into commercial nuclear reactor fuel or use in commercial
nuclear reactors to furnish electrical power. Following blending, this
material would be made available and provided to fuel fabricators for
use in fabricating commercial nuclear reactor fuel. Currently, there
are five potential domestic commercial facilities that could process the
uranyl nitrate into commercial nuclear reactor fuel, and 109 domestic
commercial electrical power nuclear reactors that could eventually use
the commercial nuclear reactor fuel. There are also foreign processing
facilities and commercial nuclear reactors. The exact allocation and
site-specific location and timing of the eventual processing and
commercial nuclear reactor use is not known at this time, has not been
specifically proposed, and would be contingent upon the needs and
specifications of the potential customers for the fuel. Therefore, such
indirect impacts would be conjectural, and not subject to meaningful
NEPA analysis. In this regard, potential domestic processing facilities
and commercial nuclear reactors would be subject to NRC-licensing
requirements and appropriate NEPA documentation associated with the
licenses. The domestic spent fuel would be stored, and potentially
disposed of, in a repository or other alternative, pursuant to the
Nuclear Waste Policy Act as amended (42 U.S.C. 10101 et seq.). DOE is
in the process of characterizing and will prepare an Environmental
Impact Statement (EIS) concerning the potential use of the Yucca
Mountain Site as a repository.
1.3 REGULATORY REQUIREMENTS
The Proposed Action involves transporting nuclear materials between a
DOE site, USEC sites, and sites that are regulated by the NRC.
Accordingly, this EA considers a number of environmental statutes and
requirements, including the following:
* The National Environmental Policy Act (NEPA) of 1969 (42 U.S.C. 4321
et seq.);
* The Council on Environmental Quality's (CEQ) Regulations for
Implementing the Procedural Provisions of NEPA (40 Code of Federal
Regulations [CFR] 1500-1508);
* DOE's NEPA Implementing Procedures (10 CFR 1021); and
* NRC's Environmental Protection Regulations for Domestic Licensing and
Related Regulatory Functions (10 CFR 51).
Appendix D provides a detailed listing of related regulatory issues and
authorizing agencies.
1.4 RELATIONSHIP TO OTHER DOE NEPA ACTIONS
On June 21, 1994, DOE published a Notice of Intent (NOI) in the Federal
Register (59 FR 31985) to prepare the Long-Term Storage and Disposition
of Weapons-Usable Fissile Materials Programmatic Environmental Impact
Statement (PEIS). (Weapons-usable fissile materials consist primarily
of HEU and plutonium.) The purpose of the NOI was to inform the public
of the PEIS proposal, solicit public input, and announce that public
scoping would be conducted through October 1994. In the course of the
public scoping process and through subsequent meetings with the public
and industry on HEU disposition, DOE concluded that it would be
appropriate to analyze the environmental impacts of the disposition of
HEU separately from the analysis of plutonium disposition options. In
accordance with this conclusion, DOE announced in the Federal Register
(60 FR 17344) on April 5, 1995, its plans to prepare an EIS to evaluate
alternatives for the disposition of the United States' HEU declared
surplus to national defense needs by the President.
The Kazakhstan-origin HEU is not part of the United States-origin
stockpiles and was obtained through a separate action. The disposition
of this material is not connected to the action to be analyzed in the
EIS, and this EA can proceed independently of the EIS. The disposition
of the Kazakhstan-origin HEU is a high-priority action related to
international goals and arrangements between the United States and the
Republic of Kazakhstan. It involves a small quantity of HEU that is of
foreign origin and must be completed as expeditiously as possible in
order to strengthen international relations and non-proliferation goals,
encourage futurecooperation, and minimize security concerns.
When the United States acquired this HEU from the Republic of Kazakhstan
in consultation with the Russian Federation, the unified purpose of our
governments was to prevent this material from falling into the hands of
those that might want to use it for nuclear weapons. Central to this
course of action is the need to assure trust and confidence among our
governments that these weapons-usable fissile materials would not be
used in the United States nuclear arsenal. Therefore, it is important
to blend the Kazakhstan-origin HEU to LEU as promptly as possible to
demonstrate to other nations, especially the republics of the former
Soviet Union, that the United States has converted the material to a
form that cannot be used for nuclear weapons. In this manner, the
United States hopes to encourage other nations to reduce their
stockpiles of weapons-usable fissile materials and advance global
nonproliferation goals.
The Proposed Action analyzed in this EA for the Kazakhstan-origin HEU
would not affect or trigger decisions to be made pursuant to the EIS for
the disposition of United States-origin surplus HEU, is not a part of
the larger United States-origin surplus HEU action, involves different
reasonable alternatives, and can proceed regardless of any action
eventually taken concerning the United States-origin surplus HEU. The
Proposed Action is independently justified by, among other things, the
need to demonstrate to other nations the United States' commitment to
remove weapons-usable fissile materials from the world's stockpiles and
convert these materials to peaceful use as quickly as possible.
Section 2: PURPOSE AND NEED
The purpose is to blend the Kazakhstan-origin HEU to LEU in the form of
uranyl nitrate that cannot be used directly for nuclear weapons but that
can be used to fabricate commercial nuclear reactor fuel.
The need is to:
* Meet the objectives of the President's Nonproliferation and Export
Control Policy, including the conversion of the HEU to peaceful use in
commercial nuclear reactor fuel (Appendix A);
* Meet the goals of the President and the Secretary of Energy to
commence with the blending of the Kazakhstan-origin HEU within six to
nine months of its arrival in the United States (Appendix E);
* Follow through on the United States' commitment to remove the
proliferation potential of the Kazakhstan-origin HEU;
* Remove the accountability and security concerns regarding these
weapons-usable fissile materials as quickly as possible rather than
depend upon continued storage;
* Demonstrate the ability of the United States to perform this type of
operation in order to create an environment where other nations would
seek to enlist our aid in removing similar weapons-usable fissile
materials from the world's stockpiles;
* Provide an example to other nations of the United States' commitment
to remove weapons-usable fissile materials from the world's stockpiles;
* Encourage other nations to take similar actions towards reducing the
world's stockpiles of weapons-usable fissile materials; and
* Meet all of these needs in the most expeditious and economical manner
possible, and in a manner that allows for the peaceful, economical, and
beneficial use of the material.
Section 3: PROPOSED ACTION
3.1 THE PROPOSED ACTION
The Proposed Action, as detailed in Section 1.1, is to transport
approximately 600 kg of Kazakhstan-origin HEU from the Y-12 Plant to the
blending site; transport approximately 30 metric tons of UF6 blending
stock (LEU) from either USEC Paducah or USEC Portsmouth to GE Wilmington
for conversion into uranium oxide blending stock (LEU); transport
approximately 24 metric tons of uranium oxide blending stock from GE
Wilmington to the blending site; blend the HEU with the uranium oxide
blending stock to produce LEU in the form of uranyl nitrate; and
transport approximately 43 metric tons of uranyl nitrate to USEC
Portsmouth. This EA assesses the potential environmental impacts
associated with the Proposed Action for two alternative blending sites,
B&W Lynchburg and NFS Erwin.
Under the Proposed Action, the shipments of HEU and blending stock would
commence by June 1995. It is anticipated that the Proposed Action would
be completed within one year after the shipments commence.
3.2 NO ACTION
The no action alternative is to leave the Kazakhstan-origin HEU in safe
secure storage at the Y-12 Plant. The following activities would not
occur: transportation of the HEU, blending stock, and uranyl nitrate;
conversion of the blending stock from UF6 to uranium oxide; and blending
of the HEU and blending stock to LEU in the form of uranyl nitrate.
Indirect impacts associated with the following would not occur:
transportation of the uranyl nitrate to a fuel fabricator; fuel
fabrication; transportation of the fuel to commercial nuclear reactors;
use of this fuel to generate power; and the generation and disposal of
spent nuclear fuel. The HEU would remain in a form that could be used
for nuclear weapons and could not be used to fabricate commercial
nuclear reactor fuel without further processing.
The no action alternative would not meet the goals of the
Nonproliferation and Export Control Policy, would not follow through on
the United States' commitment to remove the proliferation potential of
the Kazakhstan-origin HEU, and would not meet the other aspects of the
Purpose and Need.
Section 4: ENVIRONMENTAL IMPACTS
4.1 INTRODUCTION
The six sites involved in the Proposed Action are: DOE's Y-12 Plant,
Oak Ridge, Tennessee; B&W Lynchburg, Virginia; NFS Erwin, Tennessee;
USEC Paducah, Kentucky; USEC Portsmouth, Ohio; and GE Wilmington, North
Carolina (Figure 1.1-2). Appendix F provides a brief description of the
affected environment at each site, and Section 5 provides a list of
reference documents which contain additional environmental information
about each of these sites. This section presents an analysis of the
potential environmental impacts associated with the Proposed Action.
This section includes an analysis of the loading, transportation, and
unloading of the Kazakhstan-origin HEU, UF6 and uranium oxide blending
stock, and uranyl nitrate. Also included is a discussion of the
potential environmental impacts associated with the conversion of the
UF6 blending stock to uranium oxide blending stock, the blending of the
Kazakhstan-origin HEU and uranium oxide blending stock, the receipt and
interim storage of these materials, and the handling and disposal of
associated wastes.
4.2 METHODOLOGY
4.2.1 Transportation Risk Analysis Methodology
For each of the radioactive materials involved, the radiological risk
analyses were performed using the RADTRAN 4 computer code developed and
maintained by Sandia National Laboratories, New Mexico. Health effects
were estimated on a per shipment (truckload) basis for each material for
the routes between each of the sites. The analysis considered the
following elements: mode; weight of material; curies; proximity dose
rates (transport index); type of packaging; and potentially affected
population. Transportation health risks were estimated for accident
radiological dose rates, normal (accident-free) transportation
radiological dose rates, and nonradiological air pollution and accident
impacts (i.e., highway fatalities). Appendix G presents a summary of
the RADTRAN transportation risk analysis methodology.
For transportation, the HEU would be placed in DOE-approved and NRC
certified packaging and transported in DOE-owned and -operated safe
secure trailers (SST). The UF6 and uranium oxide blending stock and the
uranyl nitrate would be placed in approved packaging and transported by
commercial carrier.
Although DOE has experienced traffic accidents related to the intersite
transportation of radioactive materials, there has never been a traffic
accident involving the release of radioactive materials. DOE's
hazardous material (radioactive and nonradioactive) shipments are small
compared to the large shipment volume from non-DOE hazardous material
transport activities. The Department of Transportation (DOT) estimates
that approximately 4 billion tons of regulated hazardous materials are
transported each year and that approximately 500,000 movements of
hazardous materials occur each day. There are also approximately 2
million annual shipments of radioactive materials involving about 2.8
million packages, which represents about two percent of the annual
hazardous materials shipments. Most radioactive shipments involve small
or moderate quantities of material in relatively small packages. In
comparison, DOE ships about 6,200 radioactive packages (commercial and
classified) annually among its sites. DOE's annual shipments of
radioactive packages represents less than 0.3 percent of all radioactive
shipments in the United States, and less than 0.006 percent of all
hazardous material shipments. The volume of radioactive shipments
associated with the Proposed Action would be small, as explained later
in the EA, although the radioactivity of the HEU shipments to the
blending site may exceed the radioactivity of non-DOE shipments
typically transported by the private, non-government sector.
DOE's unclassified radioactive and other hazardous materials are
transported by commercial carrier (truck, rail, and/or air carriers).
Special nuclear material, such as the HEU included in this assessment,
is transported by DOE-owned and -operated SSTs. The SSTs are vehicles
designed specifically for the safety and security of the cargo. These
special nuclear materials receive continual surveillance and
accountability by DOE's Transportation Safeguards Division in
Albuquerque, New Mexico. Shipments by SST are accompanied by armed
guards and are monitored by a tracking system. Appendix H presents a
summary of a general assessment of transport by SST.
Approved packaging refers to a container and all accompanying components
or materials necessary to perform its containment function. Packagings
used by DOE for radioactive and hazardous materials shipments are either
certified to meet specific performance requirements or built to
specifications described in the DOT hazardous materials regulations (49
CFR 100-199). For relatively low-level radioactive materials, DOT
Specification Type A packagings are used. These packagings are designed
to retain their contents under normal transportation conditions. Type A
fissile packaging would be used for the transportation of the uranium
oxide blending stock and uranyl nitrate shipments by commercial carrier.
More sensitive radioactive materials shipments, including HEU and UF6,
require the use of Type B packaging, which is designed to prevent the
release of contents under all credible transportation accident
conditions.
A stainless steel model 6M, Type B packaging, which resembles a 55
gallon drum, would be used for the transportation of HEU from the Y-12
Plant to the blending site in SSTs. A description of the test sequence
performed prior to safety certification for 6M, Type B packaging is
included in Appendix I. Appendix J, Figure J.1-1 presents a graphic
depicting a typical assembly for 6M, Type B packaging. The UF6 blending
stock would be shipped in NRC-certified, Type B packagings (overpacks)
as shown in Appendix J, Figure J.1-2. Historically, the use of Type B
packaging has demonstrated that an accidental release of radioactive
material is extremely unlikely.
Radiological doses to crew members, workers, and the general public were
calculated for each transportation route and for the corresponding
loading and unloading operations.
4.2.2 Additional Environmental Analysis Methodology
In addition to the analysis of potential transportation-related impacts,
this section also addresses potential impacts associated with the
interim storage, conversion, and blending of the materials involved in
the Proposed Action and the handling and disposal of associated wastes.
This analysis is based on the review of current environmental and other
documentation from the sites involved in the Proposed Action. The
analysis focuses on the ability of the sites to receive, store, convert,
and blend the materials involved and to handle and dispose of any waste
associated with these operations. Documentation reviewed include
current NRC licensing NEPA documents, DOE site-specific NEPA documents,
NRC licenses, safety documentation, and other applicable environmental
documents. Section 5 includes a list of the documents referenced in
this EA.
4.3 IMPACTS
4.3.1 Impacts from HEU Loading at the Y-12 Plant
The shipments of Kazakhstan-origin HEU would consist of 1,299 "cans"
(similar in size to one-gallon or smaller paint cans) containing HEU
oxide, uranium-beryllium alloy rods, uranium-beryllium oxide rods,
uranium-beryllium oxide scrap in chunks and powder, HEU graphite, and
assay samples (Appendix C). The HEU is currently stored in 6M, Type B
packagings at the Y-12 Plant and would be shipped to the blending site
in its current packagings. The complete packagings consist of the HEU
cans in Type 2R inner-containers (a containment barrier) with the 2R
inner-containers in 6M, Type B packagings (Appendix J, Figure J.1-1).
Up to three cans are placed in each 6M, Type B packaging.
Eight 6M, Type B packagings would be placed in a cargo restraint
transporter (CRT), which palletizes the cargo and constrains it during
transport. A graphic depicting a typical CRT loaded with 6M, Type B
packagings is shown in Appendix J, Figure J.1-3. Each SST would carry
up to six CRTs.
The HEU would be removed from storage, loaded on SSTs at the storage
facility, and transported off of the Y-12 Plant site. There would be no
other onsite transportation; therefore, onsite risks would be limited to
loading operations. Onsite over-the-road risks are included in the
analysis of the SST transportation to the blending site.
The potential health risks associated with the loading of SSTs at the Y-
12 Plant are based on the following criteria and assumptions:
* There would be approximately 600 kg of HEU material to be transported
in up to six CRTs per SST, or about 56 CRTs in total (this is rounded up
to 60 CRTs for calculation purposes).
* Three SSTs would be required for each of four shipments. This
requirement is due primarily to safeguard and security concerns in
multiple SST shipments. Accordingly, 12 SST shipments would be required
for the transportation of all of the HEU.
* The HEU would be transferred directly from storage into the SSTs
within the Y-12 Plant's "Protected Area."
* It would take about eight hours to prepare and stage the HEU for each
SST load. This includes the preparation of documentation, radiation
surveys, and actual loading. Most of the transportation-related
radiation exposure would occur during the 15 minutes it would take for
two cargo handlers to load each CRT into an SST. The complete transfer
of all CRTs into SSTs would take approximately 96 hours.
* The SSTs would mount flush with the st>
Transfer interrupted!
e of loading.
* Only fork lifts would be utilized to move the HEU from storage, place
it in the CRTs, and load the SSTs for shipment.
* There would be only two cargo handlers. Thirty-five other workers
would be within 50 meters (m) of the loading site. This includes ten
people involved in the loading of the SSTs (warehouse, health physics,
and nuclear material control and accountability personnel).
There has never been a transportation-related accident or incident
involving special nuclear material at the Y-12 Plant (DOE, 1995a).
Because of the low speeds (less than eight km (five miles) per hour)
involved in transferring the Kazakhstan-origin HEU from the storage
facility to the SSTs and the rigid design standards used for 6M, Type B
packagings that allow them to withstand an accident, it is extremely
unlikely that a package would be breached. A summary of the rigorous
testing sequence for the 6M, Type B packaging is presented in Appendix
I.
The estimated probability of a package being damaged so severely (e.g.,
by forklift puncture, high winds, or tornados) that the inner and outer
containers would fail and some fraction of the contents would be
dispersed is extremely low (i.e., less than 1x10E-12). Therefore, the
probability of an accident-induced radiological exposure or fatality
during the transfer of the HEU from storage to SSTs at the Y-12 Plant
would be negligible.
Accident-free radiological exposures to cargo handlers, other workers,
and the public while transferring the HEU from storage to the SSTs are
summarized in Table 4.3.1-1. The exposed groups of workers are the two
cargo handlers and 35 other workers within a 50 m radius.
TABLE 4.3.1-1. Accident-Free Radiological Exposure for HEU Transfer
from Storage to SSTs at the Y-12 Plant
Types of Population Transfer of HEU From Storage to SSTs
Population Dose Latent Cancer
Size Fatalities
Cargo Collective 2 0.051 2.1x10E-5
Handlers Population person-rem
Average 1 0.026 1.0x10E-5
Individual rem
Dose
Other Collective 35 0.012 4.8x10E-7
Workers Population person-rem
Average 1 3.3x10E-4 1.3x10E-7
Individual rem
Dose
Public Collective N/A 0 0
Population
The loading would occur onsite in a secured area away from the general
public; therefore, there would be no exposure to the public under
accident-free conditions.
The highest dose to an average individual would be received by a cargo
handler and is estimated to be a total of 0.026 rem over the duration of
the loading activity. The collective dose to the two cargo handlers is
estimated to be 0.051 person-rem. Using the worker dose-to-risk
conversion factor of 4x10E-4 cancer fatalities per person-rem multiplied
by the collective dose, 2.1x10E-5 latent cancer fatalities are estimated
to result.
The risk of fatalities resulting from additional air pollution caused by
the operation of equipment and from accidents not involving a
radiological release would be negligible.
4.3.2 Impacts from Transportation of the HEU from the Y-12 Plant to the
Blending Site
The Kazakhstan-origin HEU would be transported to the blending site by
DOE-owned and -operated SSTs. Typical SST transport routes were
selected for the analysis. The selected routes maximize the use of
interstate highways, as established by HIGHWAY (a computer routing
code). Urban, suburban, and rural population data were used to define
the populations and characteristics along the routes. Credit was not
given for the special shielding provided by the SST walls, which
provides additional protection and decreases the risk of radiation
exposure. The RADTRAN 4 computer code was used to determine
radiological risks. The selected routes, methodology, and other
criteria were developed by Sandia National Laboratories, New Mexico
(SNL, 1995).
Because there has never been a release of radioactive material during
SST transportation, a postulated SST transport accident scenario was
developed to estimate the risks. Under postulated SST accident
conditions, radiological consequences would result primarily from the
release of respirable radioactive particulates and subsequent inhalation
by persons downwind of the accident, either directly or after
resuspension. Other exposures would include direct radiation from
airborne material and from contamination on the ground. Details of the
postulated accident scenario were developed by Sandia National
Laboratories, New Mexico. A separate assessment for SSTs carrying
special nuclear material in-transit is described in Appendix H.
Under the Proposed Action, the dose due to the bounding SST accident
(that is, the accident with the greatest potential consequences, even
though it has a small probability of occurrence) is estimated to be 5.4
person-rem for the B&W Lynchburg option in an urban area and 4.4 person-
rem for the NFS Erwin option. The probability of the bounding SST
accident occurring in an urban area is estimated to be 3.8x10E-13 for
B&W Lynchburg and 3.9x10E-12 for NFS Erwin. Given the conservative
nature of these estimates and the fact that an SST accident has never
occurred that resulted in the release of radiological material, the
actual probability may be much lower. In addition, the consequences
would be diminished if the accident occurred in a suburban or rural
area. The transportation crew and the public are considered as one
population for the purposes of the accident consequences. The general
population dose-to-risk conversion factor is 5x10E-4 cancer fatalities
per person-rem (ICRP, 1991). The maximum collective dose of 5.4 person
rem in the SST accident would be estimated to result in 2.7x10E-3 latent
cancer fatalities for B&W Lynchburg.
Table 4.3.2-1 summarizes the potential radiological exposure from a
potential urban accident during the transportation of the HEU from the
Y-12 Plant to either B&W Lynchburg or NFS Erwin. The population size
shown in this table represents the maximum population which could be
affected in an urban area along the routes for this scenario.
Radiological risks during normal (accident-free) transportation of the
HEU from the Y-12 Plant to the blending sites are shown in Table 4.3.2
2. The maximum impact would be to the truck crew, and the highest dose
to an average individual crew member is estimated to be 0.014 rem.
TABLE 4.3.2-1. Radiological Exposure for SST Shipments of HEU Due to a
Bounding Accident in an Urban Area
Route Population Probability Population Latent
Size of Dose Cancer
Occurrence (person-rem) Fatalities
Y-12 Plant 2.9x10E6 3.8x10E-13 5.4 2.7x10E-3
to B&W
Lynchburg
Y-12 Plant 2.4x10E6 3.9x10E-12 4.4 2.2x10E-3
to NFS
Erwin
TABLE 4.3.2-2. Accident-Free Radiological Exposure for SST Shipments of
HEU
from the Y-12 Plant to the Blending Site at B&W Lynchburg
Types of Population
Population Dose Latent Cancer
Size Fatalities
Transport Collective 3 0.042 1.7x10E-5
Crew Population person-rem
Average 1 0.014 5.6x10E-6
Individual rem
Dose
Workers at Collective 10 4.1x10E-3 1.6x10E-6
SST Stop Population person-rem
Average 1 4.4x10E-4 1.6x10E-7
Individual rem
Dose
Public Collective 1.1x10E5 1.1x10E-5 0.013
Population person-rem
Maximum 1 6.2x10E-7 3.1x10E-10
Individual rem
(In-transit)
TABLE 4.3.2-2. Accident-Free Radiological Exposure for SST Shipments
of HEU from the Y-12 Plant to the Blending Site at NFS Erwin
Types of Population
Population Dose Latent Cancer
Size Fatalities
Transport Collective 3 0.018 7.4x10E-6
Crew Population person-rem
Average 1 6.1x10E-3 2.5x10E-6
Individual rem
Dose
Workers at Collective N/A 0 0
SST Stop Population
Average N/A 0 0
Individual
Dose
Public Collective 6.5x10E4 7.2x10E-3 3.6x10E-6
Population person-rem person-rem
Maximum 1 6.2x10E-7 3.1x10E-10
Individual rem
(In-transit)
Nonradiological risks of highway transportation (those risks which are
caused by added air pollution or by highway accidents not involving a
radiological release) are low. The risk of fatalities resulting from
additional air pollution caused by the operation of trucks was estimated
on the basis of 1x10E-7 fatalities per kilometer (km) of travel in urban
zones (SNL, 1982). Accident fatalities incurred by the crew and public
were estimated on the basis of fatality rates per km of travel in rural,
suburban, and urban zones. For occupational (crew) risks, these rates
per km are 1.50x10E-8 rural, 3.70x10E-9 suburban, and 2.10x10E-9 urban.
For public risks, these rates per km are 5.30x10E-8 rural, 1.30x10E-8
suburban, and 7.50x10E-9 urban (SNL, 1986).
The nonradiological transportation risks associated with the Proposed
Action are consistently greater than those from radiological effects;
however, they are no greater than similar nonradiological risks
experienced by the vehicle population as a whole. These risks are
summarized in Table 4.3.2-3.
4.3.3 Impacts from Onsite Transportation at the Blending Site
Neither B&W Lynchburg or NFS Erwin has ever experienced a
transportation-related accident involving special nuclear materials
(B&W, 1995; NFS, 1995). Using similar assumptions and the postulated
maximum credible accident scenario for the loading of the SSTs at the Y-
12 Plant presented in Section 4.3.1, the estimated health effects of
unloading the trucks and placing the Kazakhstan-origin HEU into interim
storage at the blending sites have been determined.
TABLE 4.3.2-3. Nonradiological Impacts for SST Shipments of HEU from
the Y-12 Plant to the Blending Site
Health Effects Nonradiological Risk
B&W Lynchburg NFS Erwin
Pollution 1.2x10E-5 1.2x10E-5
(Latent Cancer
Fatalities)
Occupational 1.5x10E-4 5.9x10E-5
Accident
Fatalities
Public Accident 5.2x10E-4 2.1x10E-4
Fatalities
Upon arrival at the blending site, the HEU would be immediately unloaded
from the SSTs and placed in the interim storage facility. Onsite road
risks from the site gate to the unloading dock are included in the
transportation assessment from the Y-12 Plant to the blending site. At
B&W Lynchburg, there would be no other onsite transportation. At NFS
Erwin, the SSTs would be unloaded in a secure area and the HEU
transported by sealed NFS truck under security escort to an interim
storage facility, a distance of approximately 0.6 km (0.4 miles). At
B&W Lynchburg, unloading would take about 15 minutes for each CRT; and
at NFS Erwin, unloading and other handling would take about 30 minutes
for each CRT. Risk analyses are limited to unloading operations and the
transport of HEU to interim storage.
A radiological accident is unlikely to occur during the unloading of
SSTs and the transfer of materials to an interim storage facility. The
estimated probability of a package being damaged so severely (e.g., by
forklift puncture, high winds, or tornados) that the inner and outer
containers would fail and some fraction of the contents would be
dispersed is extremely low (i.e., less than 1x10E-12). Therefore, the
probability of an accident-induced radiological exposure or fatality
during the transfer of the HEU from SSTs to storage at the blending site
would be negligible.
Accident-free radiological exposures to cargo handlers, other workers,
and the public while transferring HEU from the SSTs to the blending site
interim storage facility are summarized in Table 4.3.3-1. The exposed
workers would be the two cargo handlers and 30 other workers (e.g.,
guards) within a 50 m radius. The unloading would occur onsite in a
secured area away from the general public; therefore, there would be no
exposure to the public under accident-free conditions. The highest dose
to an average individual would be received by a cargo handler at NFS
Erwin and is estimated to be 0.051 rem. The collective dose to two
cargo handlers is estimated to be 0.10 person-rem at NFS Erwin and 0.051
person-rem at B&W Lynchburg.
Using the worker dose-to-risk conversion factor of 4x10E-4 cancer
fatalities per person-rem multiplied by the collective dose, 4.1x10E-5
latent cancer fatalities are estimated to result at NFS Erwin.
The risk of fatalities resulting from additional air pollution caused by
the operation of equipment and from accidents not involving a
radiological release would be negligible.
4.3.4 Impacts Associated with Interim Storage and Blending at the
Blending Site
This section discusses the potential environmental impacts associated
with the blending of the Kazakhstan-origin HEU and uranium oxide
blending stock, receipt and interim storage of these materials, and the
handling and disposal of associated wastes at B&W Lynchburg and NFS
Erwin. As detailed in Appendix C, the Kazakhstan-origin HEU contains
primarily uranium and beryllium with small but measurable quantities of
plutonium. The blending stock would be received at the blending site as
uranium oxide.
TABLE 4.3.3-1. Accident-Free Radiological Exposure for HEU Transfer
from SSTs to Interim Storage at the Blending Site
B&W LYNCHBURG:
Types of Population Transfer of HEU From SSTs to Interim Storage
Population Dose Latent Cancer
Size Fatalities
Cargo Collective 2 0.051 2.1x10E-5
Handlers Population person-rem
Average 1 0.026 1.0x10E-5
Individual rem
Dose
Other Collective 30 9.9x10E-3 4.0x10E-6
Workers Population person-rem
Average 1 3.3x10E-4 1.3x10E-7
Individual rem
Dose
Public Collective N/A 0 0
(beyond Population
500m)
Maximum N/A 0 0
Individual
Dose
NFS ERWIN:
Types of Population Transfer of HEU From SSTs to Interim Storage
Population Dose Latent Cancer
Size Fatalities
Cargo Collective 2 0.10 4.1x10E-5
Handlers Population person-rem
Average 1 0.051 2.1x10E-5
Individual rem
Dose
Other Collective 30 9.9x10E-3 4.0x10E-6
Workers Population person-rem
Average 1 3.3x10E-4 1.3x10E-7
Individual rem
Dose
Public Collective N/A 0 0
(beyond Population
500m)
Maximum N/A 0 0
Individual
Dose
Both of the blending sites operate under NRC licenses and have existing
approved NEPA documentation assessing their operations in support of
their licenses. These sites also are required to operate in compliance
with all applicable environmental regulations and permits regarding air
emissions, effluent discharges, and waste management. The discussions
in this section focus on only those materials or operations involved in
the Proposed Action.
4.3.4.1 B&W Lynchburg
B&W Lynchburg operates under NRC License SNM-42, Docket Number 70-27.
The most recent NEPA document addressing its operations is the
Environment Assessment for Renewal of Special Material License No. SNM
42 dated August 1991 (B&W, 1991). That document states that during
normal operations at B&W Lynchburg the dose to the maximally exposed
individual is estimated to be 0.05 mrem per year, and the cumulative
dose to the surrounding population within 80 km (50 miles) of the site
is approximately one person-rem per year.
B&W Lynchburg is licensed to possess up to 60,000 kg (60 metric tons) of
U-235 in any form except UF6 and at any enrichment. The quantities of
Kazakhstan-origin HEU and uranium oxide blending stock would be within
these limits and no UF6 would be received by B&W Lynchburg. The NRC
license also allows B&W Lynchburg to possess and process fission
products and transuranium elements at low concentrations (i.e., less
than 10E-6 grams of plutonium per gram of U-235). Because the
Kazakhstan-origin HEU contains only trace quantities of plutonium in low
concentrations, B&W Lynchburg could receive and process these materials
under the current license without amendment. B&W Lynchburg contacted
the NRC regarding this interpretation and received the NRC's concurrence
(B&W, 1995).
Beryllium, a toxic but nonradioactive material, is not specifically
addressed in the NRC license and is not typically regulated by the NRC.
Although B&W Lynchburg may not require a modification to their NRC
license to process these materials, B&W Lynchburg must ensure that it
would remain in compliance with all applicable environmental regulations
and criteria. B&W Lynchburg would use a recovery process for the
Kazakhstan-origin HEU that consists of dissolution followed by solvent
extraction and neutralization of the liquid waste effluent. Within this
process, there are three potential pathways for beryllium to enter the
environment: air emissions, liquid effluent, and solid waste.
B&W Lynchburg has had limited operational experience processing uranium
material containing high concentrations of beryllium. Because of the
beryllium levels in the Kazakhstan-origin HEU B&W anticipates that
additional controls would be installed for the protection of workers and
the environment. For example, B&W would use both stationary and lapel
air samplers for detecting beryllium. The stationary and lapel air
monitors would be evaluated after each shift and are in addition to the
existing air monitoring devices used to detect uranium exposure. Worker
exposure would be limited to 50 percent of the Occupational Safety and
Health Administration (OSHA) ambient air level limit of two micrograms
per m3 (µg/m3). Current research indicates that workers with existing
and prior respiratory conditions are more susceptible to pneumonitis.
Since it is projected that this project would be a short-term operation
(approximately 38 days), B&W anticipates that a modified medical
compliance program would be utilized. Additional training would be
given by industrial hygienists to alert workers to the hazards of
handling beryllium. Procedures for all operations involving the
material would be reviewed and updated to implement additional safety
measures if necessary.
Since beryllium is both an excellent neutron moderator and reflector, a
new criticality analysis would be performed for all areas where uranium
and beryllium would be co-located. Additional criticality controls
(such as greater spacing of materials in storage, etc.) would be
implemented as necessary.
Dissolution of uranium-beryllium metals would be performed in fume hoods
since there initially would be no particulate matter; however,
dissolution of uranium-beryllium oxides would be performed in gloveboxes
because particulate matter could exist initially. No machining,
polishing, or grinding operations are anticipated but a separate
glovebox is available if necessary for grinding/crushing of the
material. Gloveboxes are under negative pressure to assure that
material is not released to the workers.
The potential beryllium emissions have been evaluated by B&W Lynchburg
to determine what air quality regulations would apply. If the beryllium
emissions exceed exemption levels established in Part V, Rule 5-3, and
Appendix R of the Virginia Air Regulations, a permit for a modified
source would be required. Initial reviews also indicate that Subpart C
of the National Emission Standard for Hazardous Air Pollutants (NESHAP)
(40 CFR 61) may apply. If this standard applies, a stack test would be
required to verify that beryllium emissions would not exceed ten grams
over a 24-hour period. B&W Lynchburg has calculated that the potential
worst-case beryllium emission rate for this process (without emission
controls) would be approximately 3.5x10E-4 grams per hour, which
represents less than one percent of the Virginia permit exemption level.
The emission controls for the ventilation system associated with the
processing of the Kazakhstan-origin HEU would be upgraded by adding a
demister followed by a high efficiency particulate air (HEPA) filter to
the existing scrubber. These controls would further reduce the
potential beryllium emission rate to approximately 6.1x10E-8 grams of
beryllium per hour. Both the process and the projected emissions would
be reviewed with the Virginia Department of Environmental Quality (DEQ)
Air Division prior to implementation. The DEQ has the option of
establishing discharge limits and requiring monitoring, and there is a
high probability that stack sampling would be required to verify
emission levels (B&W, 1995).
The processing of the Kazakhstan-origin HEU would be based on
dissolution with a centrifuge operation to recirculate wet, undissolved
material. The uranium-beryllium solution then would go through a
tertiary solvent extraction to remove over 99 percent of the uranium.
An ion exchange system would then be used on the acidic wastewater to
remove most of the remaining uranium. The acid wastewater then would be
neutralized with caustics generating a filtercake that would be disposed
of as low-level radioactive waste (although B&W also may consider
selling the beryllium filtercake if a sufficient amount of the uranium
has been removed). The filtercake would be a beryllium hydroxide
compound with chemically bound water with a moisture content of
approximately 50 percent. The filtercake pressing operation would not
be done in the waste treatment facility as usual but in the uranium
recovery facility to ensure that the wastewater would not go to the
drying operation in the waste treatment facility. The low-level
radioactive wastewater filtrate would be processed in the onsite waste
treatment system, and would represent only a small fraction of the
average daily amount of wastewater processed.
B&W Lynchburg estimates that a maximum of 450 grams of beryllium would
be discharged to the onsite waste treatment system. The average flow to
the system is approximately 113,500 liters (30,000 gallons) per day;
therefore, the concentration of beryllium in the waste solution is
estimated to be approximately four parts per million (ppm). After the
waste treatment operation is completed, B&W estimates that the discharge
from the system would contain approximately 0.4 ppm of beryllium, and
after mixing with other industrial and sanitary discharges from the
site, the final level of beryllium in the site's Virginia Pollutant
Discharge Elimination System (VPDES) discharge would be 0.08 ppm.
Although no effluent limitations or water quality standards for
beryllium have been established for B&W Lynchburg, the process and
potential discharges would be reviewed with the Virginia DEQ Water
Division prior to implementation. The Virginia DEQ may establish a
discharge level for beryllium as part of B&W Lynchburg's VPDES permit
after this consultation (B&W, 1995).
As described above, low-level radioactive filtercake containing
beryllium would be generated by the processing of Kazakhstan-origin HEU.
The EPA issued a clarification in 1994 that beryllium would only be
considered a hazardous waste if it is in the form of a dust from
beryllium metal, which it would not be in the filtercake because of the
large water content. The Virginia DEQ was contacted by B&W Lynchburg,
and confirmed that this filtercake could be handled as a low-level
radioactive but not a hazardous or mixed (radioactive and hazardous)
waste. B&W Lynchburg would handle this waste in accordance with
established procedures and monitor the filtercake at its point of
generation to ensure that compliance levels established by OSHA for
personnel exposure are met. B&W has not defined the total volume of
wastes associated with the processing of the Kazakhstan-origin material,
but estimates that 20 batches of neutralization filtercake containing a
total of 40.6 kg of beryllium would be generated over the duration of
the project. B&W's waste treatment system typically generates three 55-
gallon drums of low-level radioactive filtercake per day, and this
volume is reduced by a factor of two by using a supercompactor. The
filtercake generated by the waste treatment system would contain the
beryllium (approximately 450 grams) that would not be removed in the
neutralization filtercake. B&W also estimates that approximately 11
HEPA filters that would require handling as low-level waste would be
generated by the operation. These waste volumes would not be a
significant addition to the waste volumes generated at B&W Lynchburg
during normal operations (B&W, 1995).
B&W Lynchburg would dispose of the solid low-level waste containing
beryllium offsite. The Commonwealth of Virginia is a member of the
Southeast Compact which utilizes an NRC/State of South Carolina-licensed
burial facility operated by Chem Nuclear Systems, Inc., in Barnwell,
South Carolina. Until this facility closes on December 31, 1995, B&W
Lynchburg would utilize this facility to dispose of this waste. After
that time, the waste would be staged onsite in an existing licensed
facility until a new licensed Southeast Compact facility is available.
Other waste volumes containing graphite or other non-radioactive, non
hazardous constituents of the Kazakhstan-origin HEU would be recycled or
disposed of as non-hazardous solid waste. Any of these constituents
containing radioactive contamination would be disposed of as low-level
radioactive waste (B&W, 1995).
4.3.4.2 NFS Erwin
NFS Erwin operates under NRC License SNM-124, Docket Number 70-143. The
most recent NEPA document addressing its operations is the Environmental
Assessment for Renewal of Special Nuclear Material License No. SNM-124
dated August 1991 (NFS, 1991). That document states that during normal
operations at NFS Erwin the dose to the maximally exposed individual is
estimated to be 2.3 mrem per year, and the cumulative dose to the
surrounding population within 80 km (50 miles) of the site is
approximately 14.6 person-rem per year.
NFS Erwin is licensed to possess up to 7,000 kg (seven metric tons) of
U-235 in essentially any chemical or physical form and at any
enrichment. The total quantities of Kazakhstan-origin HEU and uranium
oxide blending stock would not exceed these limits. NFS Erwin would,
however, schedule and stage the receipt and processing of these
materials so that the quantity of uranium metal on site would not exceed
any NRC or DOE requirements (NFS, 1995).
On May 7, 1993, the NRC issued Amendment No. 3 to SNM-124 which
authorizes NFS to perform downblending of HEU (NRC-TAC L21676). This
amendment was based on the analysis in the Safety Evaluation Report
(Docket No. 70-143). Upon reviewing the report, the NRC determined that
there would not be a significant impact to health, safety, or the
environment and that because the provisions of 10 CFR 51.22(c)(11) had
been met, neither an EA nor an EIS was necessary for the amendment (NFS,
1995).
Although NFS Erwin is authorized to possess up to 200 grams of plutonium
associated with residual contamination of facilities from previous
operations or in storage as material used in previous operations, this
amendment does not apply specifically to the plutonium present in trace
quantities in the Kazakhstan-origin HEU. The NRC has been contacted
regarding the issue of obtaining an amendment to the license for this
material. Although the NRC has verbally indicated that small amounts
(i.e., in the range of 10E-6 grams of plutonium per gram of U-235) of
plutonium contained in uranium should pose no significant safety
concern, NFS Erwin would be required to obtain an amendment to their
license in order to accept the Kazakhstan-origin HEU for blending. The
blending operation and the quantity of plutonium in the Kazakhstan
origin HEU would fall within the bounds of NFS Erwin's capacity and
capability to process, and would be covered under its current license
and Safety Evaluation Report for the license amendment to perform
downblending operations (NFS, 1995).
Uranium material containing high concentrations of beryllium was handled
at NFS Erwin in the 1970s. Because the facility has not recently
handled similar material, additional controls would be instituted for
protection of the workers and the environment. For example, NFS Erwin
would use stationary and lapel air samplers for determining beryllium
exposure. Both the stationary and lapel air monitors would be evaluated
after each shift in addition to the existing devices used to detect
uranium exposure. Initial operations would be done in respirators until
sufficient data are gathered to assure that worker exposure limits would
not be exceeded. Worker exposure would be limited to 25 percent of the
OSHA ambient air level limit of two µg/m3. Since the operation is
anticipated to last 120 days, workers would be screened for existing
lung conditions. Workers with existing lung conditions would be
excluded from working with this material. Additional training would be
given by industrial hygienists to alert workers to the hazards of
handling beryllium. Procedures for all operations involving the
material would be reviewed and updated as necessary to implement
additional safety measures.
A new criticality analysis has been performed for all areas where
uranium and beryllium would be co-located to establish new mass
criticality safety limits. Uranium-beryllium metals dissolution in
nitric acid would be done in fume hoods since there initially would be
no particulate matter. The fume hoods have a dual layer of air flow to
reduce exposure to the workers. Uranium-beryllium oxide dissolution in
hydrofluoric acid would be done in gloveboxes since particulate matter
could exist. The gloveboxes would be under negative pressure at all
times to assure that material is not released into the worker area.
This division of metals and oxides is already done for all uranium
operations. The first glovebox in the line contains equipment that
would be used if grinding/crushing is required. Preliminary tests would
be done with the material to determine if the acids would completely
dissolve the material or if grinding/crushing would be necessary as a
first step. All operations where particulate material is present would
be posted for workers and noted in the operation procedures.
As noted previously, beryllium is not specifically addressed in the NRC
license and is not typically regulated by the NRC. NFS Erwin would,
however, be required to receive modifications to their Tennessee Air
Pollution and National Pollutant Discharge Elimination System (NPDES)
permits. The maximum allowable effluent discharges would be established
by the State of Tennessee Division of Air Pollution Control and Water
Pollution Control. NFS Erwin has air pollution control systems and
liquid effluent treatment systems in place that would allow the facility
to comply with permit modifications since these current systems enable
the facility to meet permit requirements for uranium and other hazardous
pollutants in accordance with 10 CFR 20 and State of Tennessee Rule
1200-3-11.03 (NFS, 1995).
The ventilation system used for the processing of the Kazakhstan-origin
HEU would be the current system in place. For dissolution of metals in
the hoods, this consists of a prefilter, a venturi scrubber, a demister,
and a HEPA filter. For dissolution of oxides in the gloveboxes, there
is an additional HEPA filter located at the top of the glovebox. This
would limit beryllium emissions in the same manner as similar controls
in place limit uranium emissions. NFS estimates that beryllium
emissions would be limited to less than one percent (approximately
4.2x10E-3 grams per hour) of the ten gram per 24-hour period standard
codified in Tennessee State Rule 1200-3-11-03. Limits below those
specified in the State Rule may be imposed by the State of Tennessee,
and emissions would be monitored to ensure compliance with permit limits
(NFS, 1995).
Most of the beryllium waste would be in either the filter solids after
dissolution or raffinate wastewater after the solvent extraction
process. The raffinate wastewater would be neutralized with caustics,
and the neutralized wastewater then would be discharged into the onsite
waste treatment facility. The wastewater from this process would
represent only a small part of the total liquid waste treated onsite,
the majority of which is from high efficiency process ventilated
scrubbing systems. After treatment, the effluent would be discharged in
accordance with NFS Erwin's State of Tennessee NPDES permit. Although
this permit does not currently include beryllium, a beryllium limit
would be established with the state of Tennessee and effluents would be
monitored to ensure compliance (NFS, 1995).
The process also would generate a filtercake that would be disposed of
as low-level radioactive waste. The filtercake would be a beryllium
hydroxide compound with chemically bound water with a moisture content
of approximately 50 percent. As discussed previously, the beryllium
would only be considered a hazardous waste if it is in the form of a
dust from beryllium metal, which it would not be in the filtercake
because of the large water content. NFS Erwin estimates that the total
quantity of solid waste resulting from this process to be in the range
of 57 to 142 m3, and that it will contain virtually all of the estimated
1,600 kg of beryllium present in the Kazakhstan-origin HEU. Both the
solid and liquid waste streams are estimated to be of the same volume as
those generated during normal operations, although they will contain
beryllium as an impurity. Other waste volumes containing graphite or
other non-radioactive, non-hazardous constituents of the Kazakhstan-
origin HEU would be recycled or disposed of as non-hazardous solid
waste. Any of these constituents containing radioactive contamination
would be disposed of as low-level radioactive waste (NFS, 1995).
NFS Erwin would dispose of the solid low-level waste containing
beryllium offsite. The State of Tennessee is a member of the Southeast
Compact which utilizes an NRC/State of South Carolina-licensed burial
facility operated by Chem Nuclear Systems, Inc., in Barnwell, South
Carolina. Until this facility closes on December 31, 1995, NFS Erwin
would utilize this facility to dispose of this waste. After that time,
the waste would be staged onsite in an existing licensed facility until
a new licensed Southeast Compact facility is available (NFS, 1995).
4.4 TRANSPORTATION AND CONVERSION OF BLENDING STOCK
Both the UF6 and uranium oxide blending stock are LEU materials that are
routinely shipped in NRC-certified shipping containers by commercial
carrier. There are no unusual shipping criteria (as is required for
special nuclear material) other than meeting standards established by
DOT (49 CFR 100-199) and supplemented by state, local, and DOE
regulations. These standards require the shipper to comply with
selecting the proper, authorized packaging for the material; preparing
hazardous materials shipping papers; properly certifying what is being
shipped; properly marking, labeling, loading, blocking, and bracing the
material; and meeting safety requirements.
4.4.1 Transportation of the UF6 Blending Stock from either USEC Paducah
or USEC Portsmouth to GE Wilmington
The UF6 blending stock would be of less than three percent enrichment
and shipped as a solid. The material would be placed in a specification
UF6 cylinder (inner packaging), which is then placed in NRC-certified,
Type B packagings (overpacks) for shipment by commercial carrier. Up to
13 cylinders, each containing approximately 2.3 metric tons, would be
required. It is estimated that three truckloads would be needed to
transport the material. This material has been successfully transported
throughout the world via ship, rail, and truck without loss of life or
property due to a radiological or chemical release. The overall risk of
transporting UF6 is estimated to be low.
The potential health effects from the transportation (loading,
transportation, and unloading) of the blending stock materials are
presented in Table 4.4-1.
4.4.2 Conversion of the Blending Stock from UF6 to Uranium Oxide at GE
Wilmington
GE Wilmington operates under NRC License SNM-1097, Docket Number 70-
1113. The most recent NEPA document addressing its operations is the
Environmental Impact Appraisal for Renewal of Special Nuclear Material
License No. SNM-1097 dated June 1984 (GE, 1984). That document states
that during normal operations at GE Wilmington the dose to the maximally
exposed individual is estimated to be 0.13 mrem per year, and the
cumulative dose to the surrounding population within 80 km (50 miles) of
the site is approximately 0.15 person-rem per year.
This section discusses the potential impacts associated with the
conversion of the UF6 blending stock to uranium oxide blending stock at
GE Wilmington. The conversion of UF6 to uranium oxide is a process that
GE Wilmington currently performs under its NRC License. This license
permits GE Wilmington to possess up to 50,000 kg (50 metric tons) of
uranium enriched to less than six percent U-235 in the form of UF6 or
uranium oxide. Section 1.7.1.1 of their most recent license application
(Revision 21, May 16, 1988) specifically addresses the conversion of UF6
to uranium oxide. Waste handling and disposal activities are addressed
in Section 1.7.5 (Revision 21, May 16, 1990). The quantity of UF6
involved in the Proposed Action represents approximately 2.5 percent of
the average yearly quantity of UF6 converted at GE Wilmington (GE,
1995).
The conversion of the blending stock would use the ammonium diuranate
(ADU) process. The ADU process first vaporizes the UF6, then hydrolyzes
it to soluble uranyl fluoride and hydrofluoric acid, and then ADU slurry
is precipitated by mixing the uranyl fluoride with ammonium hydroxide.
The hydrofluoric acid is mixed with calcium to create calcium fluoride,
which is then either sold for commercial use or disposed of as a non
radioactive, non-hazardous solid waste. The liquid phase is removed
from the slurry, passed through a quarantine filter system for further
uranium removal, and then routed to the onsite waste treatment system.
The ADU product is fed to a defluorinator-calciner where it is dried,
decomposed, and reduced to the uranium oxide product. The offgas from
the defluorinator is scrubbed to remove uranium and fluoride compounds
and then routed to a combined scrubber/HEPA filter exhaust system. The
effluents and emissions associated with this process are uranium
particulate, fluorides, and ammonia. These effluents and emissions are
continuously monitored and are in compliance with all state and Federal
requirements. Solid waste associated with this process are incinerated
onsite and the resultant solids are then compacted to yield a very small
quantity of solid waste requiring disposal (GE, 1995).
GE Wilmington would dispose of the solid low-level waste offsite. The
State of North Carolina is a member of the Southeast Compact which
utilizes an NRC/State of South Carolina-licensed burial facility
operated by Chem Nuclear Systems, Inc., in Barnwell, South Carolina.
Until this facility closes on December 31, 1995, GE Wilmington would
utilize this facility to dispose of this waste. After that time, the
waste would be staged onsite in an existing licensed facility until a
new licensed Southeast Compact facility is available (GE, 1995).
4.4.3 Transportation of the Uranium Oxide Blending Stock from GE
Wilmington to the Blending Site
At GE Wilmington, the UF6 would be converted into uranium oxide, which
would be shipped to either B&W Lynchburg or NFS Erwin. The uranium
oxide would be transported in up to 570 NRC-certified, Type A fissile
packages. Each package would contain between 35 and 60 kg of uranium,
depending upon the material assay. The material would be transported by
up to five commercial truckloads to the blending site. The potential
health effects from the transportation of the blending stock materials
are presented in Table 4.4-1.
GE Wilmington was used as a representative site for the conversion of
UF6 to uranium oxide. If another site were used for this process, the
transportation risks would be slightly different due to differences in
the distance the material would be transported and the population along
the transportation routes; however, impacts would not be expected to
differ substantially from those described in this EA.
4.5 TRANSPORTATION OF THE URANYL NITRATE FROM THE BLENDING SITE TO USEC
PORTSMOUTH
Uranyl nitrate crystals would be the product of the blending process.
Once the Kazakhstan-origin HEU is blended into a material containing
less than five percent enriched uranyl nitrate, the material would be
shipped in NRC-certified, Type A fissile packaging via commercial
carrier to USEC Portsmouth. It is estimated that 14 truckloads would be
required for the shipping of this material. The risk of transporting
this material, in any form, is low.
The material would be transported by commercial truck in compliance with
DOT (49 CFR 100-199) and other regulatory requirements that govern the
movement of hazardous materials. The blending site is under the
compliance jurisdiction of the NRC. The NRC has oversight
responsibilities for these shipments to USEC Portsmouth. The material
being transported, however, contains a low level of radiation that is no
greater risk than other uranium materials that have been shipped
commercially without a radiological release or death in over 40 years.
The transportation health risks for these shipments are shown in Table
4.5-1.
TABLE 4.4-1 Health Effects of Transporting UF6 and Uranium Oxide
Blending Stock
Route Health Risks (Latent Fatal Cancer or Accident
Fatality)
Radiological
Accident Accident-Free
Conditions Transportation
Public Crew
UF6 from 4.5x10E-7 5.1x10E-6 5.9x10E-6
USEC Portsmouth
to GE Wilmington
UF6 from 3.9x10E-7 4.0x10E-6 5.7x10E-6
USEC Paducah
to GE Wilmington
Uranium Oxide 1.5x10E-6 2.1x10E-6 7.6x10E-6
from GE Wilmington
to B&W Lynchburg
Uranium Oxide 2.3x10E-6 2.4x10E-6 1.1x10E-5
from GE Wilmington
to NFS Erwin
Route Health Risks (Latent Fatal Cancer or Accident
Fatality)
Non-Radiological
Accident Air
Fatalities Pollution
Public Crew
UF6 from 3.1x10E-4 8.8x10E-5 7.4x10E-6
USEC Portsmouth
to GE Wilmington
UF6 from 2.3x10E-4 6.4x10E-5 1.1x10E-5
USEC Paducah
to GE Wilmington
Uranium Oxide 1.8x10E-4 5.2x10E-5 4.7x10E-6
from GE Wilmington
to B&W Lynchburg
Uranium Oxide 3.0x10E-4 8.4x10E-5 8.1x10E-6
from GE Wilmington
to NFS Erwin
The transportation of the uranyl nitrate from the blending site to USEC
Portsmouth was used as a representative transportation activity for this
material. If another destination (e.g., a domestic fuel fabricator
selected by USEC) were selected for the uranyl nitrate, the
transportation risks would be slightly different due to differences in
the distance the material would be transported and the population along
the transportation routes; however, impacts associated with
transportation to a domestic fuel fabrication facility would not be
expected to differ substantially from those described in this EA.
Table 4.5-1. Health Effects of Transporting Uranyl Nitrate Crystals
From the Blending Plant to USEC Portsmouth
Route Health Risks (Latent Fatal Cancer or Accident
Fatality)
Radiological
Accident Accident-Free
Conditions Transportation
Public Crew
B&W Lynchburg 4.2x10E-6 0 0
to
USEC Portsmouth
NFS Erwin 5.0x10E-6 0 0
to
USEC Portsmouth
Route Health Risks (Latent Fatal Cancer or Accident
Fatality)
Non-Radiological
Accident Air
Fatalities Pollution
Public Crew
B&W Lynchburg 6.2x10E-4 1.8x10E-4 3.6x10E-5
to
USEC Portsmouth
NFS Erwin 6.3x10E-4 1.8x10E-4 4.3x10E-5
to
USEC Portsmouth
4.6 NO ACTION IMPACTS
Under the no action alternative, which is to leave the Kazakhstan-origin
HEU in safe secure storage at the Y-12 Plant, there would be no
transportation or blending of the HEU and blending stock or
transportation of the uranyl nitrate. Accordingly, there would be no
transportation, blending, or waste-related impacts. As the Kazakhstan
origin HEU is currently stored in 6M, Type B packagings (as described in
Section 4.3.1) in a secure facility, the continued storage of this
material at the Y-12 Plant would result in a negligible risk.
The Department has also completed the predecisional September 1994
Environmental Assessment for the Proposed Interim Storage of Enriched
Uranium Above the Maximum Historical Storage Level at the Y-12 Plant,
Oak Ridge, Tennessee (DOE, 1994a). That document evaluates the
potential environmental impacts of storing up to 500,000 kg (500 metric
tons) of HEU at the Y-12 Plant. Under no action, the 600 kg of
Kazakhstan-origin HEU would remain in storage at the facilities
described and evaluated in that EA.
4.7 SUMMARY OF IMPACTS
Of the potential risks associated with the transportation of all of the
materials addressed in this EA, the maximum number of total fatalities
associated with the Proposed Action that would occur within one year
would not exceed 0.0023. The maximum total risk option includes
transporting the Kazakhstan-origin HEU from the Y-12 Plant to B&W
Lynchburg, the UF6 blending stock from USEC Paducah to GE Wilmington,
the uranium oxide blending stock from GE Wilmington to B&W Lynchburg,
and the uranyl nitrate from B&W Lynchburg to USEC Portsmouth. For NFS
Erwin, the maximum number of total fatalities associated with the
Proposed Action that would occur within one year would not exceed
0.0021. It is unlikely that a fatality would occur as a result of the
transportation activities associated with the Proposed Action regardless
of the blending site.
The analyses of the other activities associated with the Proposed Action
focused on impacts associated with the conversion of the UF6 blending
stock to uranium oxide blending stock and impacts associated with the
blending of the Kazakhstan-origin HEU and uranium oxide blending stock.
As described in previous sections, the potential impacts identified
regarding the receipt and blending of the materials involved in the
Proposed Action, and the handling and disposal of any associated wastes
were small.
With respect to environmental justice issues, high and adverse health
effects are measured in risks and rates that could result in latent
cancer fatalities, as well as other fatal or non-fatal risks to human
health. Disproportionately high and adverse human health effects occur
when the risk or rate for a minority population or low-income population
from an environmental hazard significantly exceeds the risk or rate to
the general population. The Proposed Action would not have high and
adverse impacts that could disproportionately affect minority
populations or low-income populations. The Proposed Action would not
require the selection of any new site; rather, all activities would take
place at existing sites. The potential impacts identified at facilities
considered for interim storage and/or blending activities are small.
Accordingly, because the potential impacts would present no significant
risk and do not constitute a reasonable foreseeable adverse impact to
the surrounding population, no disproportionately high and adverse
effects would be expected for any particular segment of the population,
including minority and low-income populations.
The other potential source of impacts is the transportation of the HEU,
UF6 and uranium oxide blending stock, and uranyl nitrate. The
transportation analyses in this EA are based on representative routes.
The exact transportation routes for the HEU addressed in this EA are
classified and cannot be specifically identified and compared with
minority and low-income population distribution data. However, because
the health risks to the public resulting from the proposed
transportation routes would be low, there would not be
disproportionately high and adverse impacts to minority or low-income
populations.
4.8 CUMULATIVE IMPACTS
Section 4.7 describes the total transportation impacts, including
nonradiological impacts, associated with the Proposed Action.
Cumulative impacts would result from the addition of those impacts to
the impacts resulting from the blending and conversion operations at B&W
Lynchburg, NFS Erwin, and GE Wilmington.
Nonradiological impacts are caused by vehicle accidents and air
pollution, and are not associated with a radiological release. Although
nonradiological impacts are included in the summary of impacts described
above, it should be noted that the total of 34 shipments of radioactive
materials (both HEU and LEU) associated with the Proposed Action
represent only 0.0017 percent of the average annual radioactive
shipments in the United States, and a much smaller percentage of the
total annual domestic truck shipments of all types of materials.
Therefore, the cumulative nonradiological impacts associated with the
Proposed Action are extremely small.
The doses to the maximally exposed individual and collective population
within an 80 km (50 mile) radius during normal operations at B&W
Lynchburg, NFS Erwin, and GE Wilmington are presented in Sections
4.3.4.1, 4.3.4.2, and 4.4.2, respectively. Impacts resulting from these
doses would increase as a result of the transportation impacts
associated with the Proposed Action at these sites. As shown in Section
4.7, it is unlikely that a fatality would occur as a result of the
transportation activities associated with the Proposed Action regardless
of the blending site.
The quantity of UF6 to be converted to uranium oxide represents
approximately 2.5 percent of GE Wilmington's average yearly volume from
normal operations. B&W Lynchburg estimates that the blending activities
associated with the Proposed Action would take approximately 38 days,
and is also a small percentage of their normal operations. Both of
these sites are currently operational, and the addition of the materials
associated with the Proposed Action would not cause either of these
sites to exceed their normal throughput capacities. Therefore, the
normal yearly operation dose estimates for these sites would be
representative of the total doses at these sites over the estimated one
year duration of the Proposed Action.
NFS Erwin estimates that the blending activities associated with the
Proposed Action would take approximately 120 days. If these activities
were to occur at NFS Erwin, the normal operational doses that resulted
during past activities would provide a conservative estimate of the
total doses associated with the Proposed Action.
The cumulative impacts resulting from the addition of transportation and
blending impacts associated with the Proposed Action to the impacts
resulting from the normal operations at the sites involved would still
be extremely low. It would be unlikely that a fatality would occur as a
result of the cumulative impacts associated with the Proposed Action.
Section 5: REFERENCES
B&W, 1991 NRC, Environmental Assessment for Renewal of Special
Nuclear Material License No. SNM-42, Docket No. 70-27, Babcock & Wilcox
Company, Naval Nuclear Fuel Division, Lynchburg, Virginia, prepared by
Office of Nuclear Material Safety and Safeguards, August 1991.
B&W, 1995 Storton, J. M., "UBe Alloy Process Environmental
Evaluation," request for information supplied in memorandum to Ralph A.
Cordani, Project Manager, Babcock & Wilcox Company, Navel Nuclear Fuels
Division, Lynchburg, VA, March 14 and 21, 1995.
Battelle, 1977 Rhoades, R. E., An Overview of Transportation in the
Nuclear Fuel Cycle, BNWL-2066, UC-71, prepared under Contract EY-76-C
06-1830 by Pacific Northwest Laboratories for Energy Research and
Development Administration, May 1977.
DOE, 1994a DOE, Environmental Assessment for the Proposed Interim
Storage of Enriched Uranium Above the Maximum Historical Level at the Y-
12 Plant, Oak Ridge, Tennessee (Predecisional), DOE/EA-0929, September
1994.
DOE, 1994b Kelly, D. L., User's Guide for Shipping Type B Quantities
of Radioactive and Fissile Material, Including Plutonium, in DOT-6M
Specification Packaging Configurations, prepared by Westinghouse Hanford
Company, Richland, WA, for the U.S. Department of Energy, Transportation
Management Division, Office of Environmental Management, DOE/RL-94-68
UC-722, September 1994.
DOE, 1994c Martin Marietta Energy Systems, Inc., Paducah Gaseous
Diffusion Plant Annual Site Environmental Report for 1993, ES/ESH-53
KY/ERWM-18, prepared by Environmental, Safety, and Health Compliance
and Environmental Management staffs, Oak Ridge, TN, and the
Environmental Management Associate Division, Paducah Gaseous Diffusion
Plant, for U.S. Department of Energy under Contract DE-AC05-84OR 214000
and Martin Marietta Utility Services, Inc., for the U.S. Enrichment
Corporation under Contract DE-AC05-76OR 00001, October 1994.
DOE, 1994d Martin Marietta Energy Systems, Inc., Portsmouth Gaseous
Diffusion Plant Annual Site Environmental Report for 1993, ES/ESH-50
POEF-3050, prepared by Environmental, Safety, and Health Compliance and
the Environmental Control Department, Portsmouth Gaseous Diffusion
Plant, for U.S. Department of Energy under Contract DE-AC05-84OR 21400
and Martin Marietta Utility Services, Inc., for the U.S. Enrichment
Corporation under Contract DE-AC-76OR 00001, November 1994.
DOE, 1995a Livesay, M., "Data to Support Environmental Assessment for
the Disposition of Highly Enriched Uranium Material Acquired from
Kazakhstan," memo from Mark Livesay, Acting Branch Chief, Y-12 Program
Management Branch, U.S. Department of Energy, Oak Ridge Operations
Office, Oak Ridge, TN, March 1, 1995.
DOE, 1995b Martin Marietta Energy Systems, Inc., National Security
Program Office Analysis of HEU Samples, K/GH-3550/R1, prepared for the
U.S. Department of Energy, Office of Arms Control and Nonproliferation,
January 1995.
GE, 1984 NRC, Environmental Impact Appraisal for Renewal of Special
Nuclear Material License No. SNM-1097, Docket No. 70-1113, General
Electric Company, Wilmington Manufacturing Department, prepared by
Office of Nuclear Material Safety and Safeguards, June 1984.
GE, 1995 Foleck, R. H. D., "NRC License Application and the Current
NRC License SNM-1097," compilation of data submitted by Rick Foleck,
Senior Licensing Specialist, Fuels and Facility Licensing, General
Electric Nuclear Energy Production, Wilmington, NC, March 1995.
ICRP, 1991 Smith, H. (Editor), 1990 Recommendations of the
International Commission on Radiological Protection, ICRP Publication
60, published for The International Commission on Radiological
Protection by Pergamon Press, NY, 1991.
NFS, 1991 NRC, Environmental Assessment for Renewal of Special
Nuclear Material License No. SNM-124, Nuclear Fuel Services, Inc., Erwin
Plant, Erwin, Tennessee, Docket No. 70-143, prepared by the Office of
Nuclear Material Safety and Safeguards, Division of Industrial and
Medical Nuclear Safety, August 1991.
NFS, 1995 Guinn, F. K., "Environmental Assessment Evaluation,"
request for data provided by Keith Guinn, Principal Scientist, Nuclear
Fuel Services, Inc., Erwin, TN, March 14, 21, and 24, 1995.
NRC, 1977 Office of Standards Development, Final Environmental
Statement on the Transportation of Radioactive Material by Air and Other
Modes, NUREG-0170, Nuclear Regulatory Commission, Washington, DC,
December 1977.
SNL, 1982 Rao, R. D., Nonradiological Impacts of Transporting
Radioactive Material, SAND81-1703, TTC-0236, Sandia National
Laboratories, NM, February 1982.
SNL, 1986 Cashwell, J. W., K. S. Neuhauser, P. C. Reardon, and G. W.
McNair, Transportation Impacts of the Commercial Radioactive Waste
Program, SAND85-271, Sandia National Laboratories, NM, April 1986.
SNL, 1988 SNL, Cargo Restraint Transporter (CRT) Handling
Instructions Illustrating Methods for Loading and Securing Cargo
Handling Systems in DOE's Safe-Secure Trailers (SST), Technical Manual
SM CRT, April 7, 1988.
SNL, 1995 Mills, S., "RADTRAN Analysis," request for information
provided by Scott Mills, Sandia National Laboratories, Transportation
Development Department, Albuquerque, NM, March 29, 1995.
Section 6: AGENCIES AND PERSONS CONSULTED
Babcock & Wilcox
Naval Nuclear Fuels Division
P.O. Box 785
Lynchburg, VA 24505
General Electric Company
P.O. Box 780
Wilmington, NC 28402
Nuclear Fuel Services, Inc.
P.O. Box 337, MS 123
Erwin, TN 37650
The United States Enrichment Corporation
Two Democracy Center, 4th Floor
6903 Rockledge Drive
Bethesda, MD 20817
The Honorable James Hunt, Jr.
Governor of North Carolina
116 West Jones Street
Raleigh, NC 27603-8001
Ms. Chrys Baggett
Director, North Carolina Department of Administration
116 West Jones Street
Raleigh, NC 27603-8003
The Honorable Don Betz
Mayor of Wilmington
2518 Park Avenue
Wilmington, NC 28403
Mr. Greg Richardson
Director, North Carolina Commission of Indian Affairs
217 West Jones Street
Raleigh, NC 27603-1336
The Honorable Don Sundquist
Governor of Tennessee
State Capitol
Nashville, TN 37243-0001
Mr. Dodd Galbreath
Tennessee Department of Environment and Conservation
401 Church Street
14th Floor, L&C Tower
Nashville, TN 37243
Mr. Ray Emanuel
Native American Indian Association
211 Union Street, Suite 932
Nashville, TN 37201-1505
Tennessee Commission of Indian Affairs
401 Church Street
10th Floor, L&C Tower
Nashville, TN 37243-0459
The Honorable Edmund A. Nephew
Mayor of Oak Ridge
P.O. Box 1
Oak Ridge, TN 37831
The Honorable Russel Brackins
Mayor of Erwin
Strawberry Street
P.O. Box 270
Erwin, TN 37061
Mr. Earl Lemming
DOE Oversight for Tennessee
761 Emory Valley Road
Oak Ridge, TN 37830
Ms. Ellen Smith, Chair
Environmental Quality Advisory Board
City of Oak Ridge
P.O. Box 1
Oak Ridge, TN 37831-0001
Dr. Amy Fitzgerald
Oak Ridge Local Oversight Committee
136 S. Illinois Avenue
Suite 208
Oak Ridge, TN 37830
The Honorable George Allen
Governor of Virginia
Capitol Building
3rd Floor
Richmond, VA 23219
Mr. John Marling
Director Environmental Impact Review
P.O. Box 10009
Richmond, VA 23240-0009
The Honorable Roger E. Hedgepeth
Mayor
Town of Blacksburg
P.O. Box 90003
Blacksburg, VA 24060
The Honorable Jim Whitaker
Mayor of Lynchburg, Virginia
P.O. Box 60
Lynchburg, VA 24505
Appendix A: Nonproliferation and Export Control Policy Fact Sheet
This appendix contains a copy of the fact sheet on the President's
Nonproliferation and Export Control Policy released by the White House
on September 27, 1993. The fact sheet describes the major principles
that guide the policy and the key elements of the policy.
THE WHITE HOUSE
Office of the Press Secretary
For Immediate Release
September 27, 1993
FACT SHEET
NONPROLIFERATION AND EXPORT CONTROL POLICY
The President today established a framework for U.S. Efforts to prevent
the proliferation of weapons of mass destruction and the missiles that
deliver them. He outlined three major principles to guide our
nonproliferation and export control policy:
* Our national security requires us to accord higher priority to
nonproliferation, and to make it an integral element of our relations
with other countries.
* To strengthen U.S. economic growth, democratization abroad and
international stability, we actively seek expanded trade and technology
exchange with nations, including former adversaries, that abide by
global nonproliferation norms.
* We need to build a new consensus -- embracing the Executive and
Legislative branches, industry and public, and friends abroad -- to
promote effective nonproliferation efforts and integrate our
nonproliferation and economic goals.
The President reaffirmed U.S. support for a strong, effective
nonproliferation regime that enjoys broad multilateral support and
employs all of the means at our disposal to advance our objectives.
Key elements of the policy follow.
Fissile Material
The U.S. will undertake a comprehensive approach to the growing
accumulation of fissile material from dismantled nuclear weapons and
within civil nuclear programs. Under this approach, the U.S. will:
* Seek to eliminate where possible the accumulation of stockpiles of
highly-enriched uranium or plutonium to ensure that where these
materials already exist they are subject to the highest standards of
safety, security, and international accountability.
* Propose a multilateral convention prohibiting the production of
highly-enriched uranium or plutonium for nuclear explosives purposes or
outside of international safeguards.
* Encourage more restrictive regional arrangements to constrain fissile
material production in regions of instability and high proliferation
risk.
* Submit U.S. fissile material no longer needed for our deterrent to
inspection by the International Atomic Energy Act.
* Pursue the purchase of highly-enriched uranium from the former Soviet
Union and other countries and its conversion to peaceful use as reactor
fuel.
* Explore means to limit the stockpiling of plutonium from civil
nuclear programs, and seek to minimize the civil use of highly-enriched
uranium.
* Initiate a comprehensive review of long-term options for plutonium
disposition, taking into account technical, nonproliferation,
environmental, budgetary and economic considerations. Russia and other
nations with relevant interests and experience will be invited to
participate in this study.
The United States does not encourage the civil use of plutonium and,
accordingly, does not itself engage in plutonium reprocessing for either
nuclear power or nuclear explosive purposes. The United States,
however, will maintain its existing commitments regarding the use of
plutonium in civil nuclear programs in Western Europe and Japan.
Export Controls
To be truly effective, export controls should be applied uniformly by
all suppliers. The United States will harmonize domestic and
multilateral controls to the greatest extent possible. At the same
time, the need to lead the international community or overriding
national security or foreign policy interests may justify unilateral
export controls in specific cases. We will review our unilateral dual
use export controls and policies, and eliminate them unless such
controls are essential to national security and foreign policy
interests.
We will streamline the implementation of U.S. nonproliferation export
controls. Our system must be more responsible and efficient, and not
inhibit legitimate exports that play a key role in American economic
strength while preventing exports that would make a material
contribution to the proliferation of weapons of mass destruction and the
missile that deliver them.
Nuclear Proliferation
The U.S. will make every effort to secure the indefinite extension of
the Non-Proliferation Treaty in 1995. We will seek to ensure that the
International Atomic Energy Agency has the resources needed to implement
its vital safeguards responsibilities, and will work to strengthen the
IAEA's ability to detect clandestine nuclear activities.
Missile Proliferation
We will maintain our strong support for the Missile Technology Control
Regime. We will promote the principles of the MTCR Guidelines as a
global missile nonproliferation norm and seek to use the MTCR as a
mechanism for taking joint action to combat missile proliferation. We
will support prudent expansion of the MTCR's membership to include
additional countries that subscribe to international nonproliferation
standards, enforce effective export controls and abandon offensive
ballistic missile programs. The United States will also promote
regional efforts to reduce the demand for missile capabilities.
The United States will continue to oppose missile programs of
proliferation concern, and will exercise particular restraint in
missile-related cooperation. We will continue to retain a strong
presumption of denial against exports to any country of complete space
launch vehicles or major components.
The United States will not support the development or acquisition of
space-launch vehicles in countries outside the MTCR.
For MTCR member countries, we will not encourage new space launch
vehicle programs, which raise questions on both nonproliferation and
economic viability grounds. The United States will, however, consider
exports of MTCR-controlled items to MTCR member countries for peaceful
space launch programs on a case-by-case basis. We will review whether
additional constraints or safeguards could reduce the risk of misuse of
space launch technology. We will seek adoption by all MTCR partners of
policies as vigilant as our own.
Chemical and Biological Weapons
To help deter violations of the Biological Weapons Convention, we will
promote new measures to provide increased transparency of activities and
facilities that could have biological weapons applications. We call on
all nations -- including our own -- to ratify the Chemical Weapons
Convention quickly so that it may enter into force by January 13, 1995.
We will work with others to support the international Organization for
the Prohibition of Chemical Weapons created by the Convention.
Regional Nonproliferation Initiatives
Nonproliferation will receive greater priority in our diplomacy, and
will be taken into account in our relations with countries around the
world. We will make special efforts to address the proliferation threat
in regions of tension such as the Korean peninsula, the Middle East and
South Asia, including efforts to address the underlying motivations for
weapons acquisition and to promote regional confidence-building steps.
In Korea, our goal remains a non-nuclear peninsula. We will make every
effort to secure North Korea's full compliance with its nonproliferation
commitments and effective implementation of the North-South
denuclearization agreement.
In parallel with our efforts to obtain a secure, just, and lasting peace
in the Middle East, we will promote dialogue and confidence-building
steps to create the basis for a Middle East free of weapons of mass
destruction. In the Persian Gulf, we will work with other suppliers to
contain Iran's nuclear, missile, and CBW ambitions, while preventing
reconstruction of Iraq's activities in these areas. In South Asia, we
will encourage India and Pakistan to proceed with multilateral
discussions of nonproliferation and security issues, with the goal of
capping and eventually rolling back their nuclear and missile
capabilities.
In developing our overall approach to Latin America and South Africa, we
will take account of the significant nonproliferation progress made in
these regions in recent years. We will intensify efforts to ensure that
the former Soviet Union, Eastern Europe and China do not contribute to
the spread of weapons of mass destruction and missiles.
Military Planning and Doctrine
We will give proliferation a higher profile in our intelligence
collection and analysis and defense planning, and ensure that our own
force structure and military planning address the potential threat from
weapons of mass destruction and missile around the world.
Conventional Arms Transfers
We will actively seek greater transparency in the area of conventional
arms transfers and promote regional confidence-building measures to
encourage restraint on such transfers to regions of instability. The
U.S. will undertake a comprehensive review of conventional arms transfer
policy, taking into account national security, arms control, trade,
budgetary and economic competitiveness consideration.
Appendix B: Preapproval Copy EA Comment Summaries and Responses
A Preapproval Copy of this document was distributed to representatives
of the affected states and Native American Tribes, and other groups and
individuals, in April of 1995, for review and comment. This appendix
contains a list of the commentors, a summary of their comments, and
DOE's responses to these comments. Based on these comments, a number of
changes have been made throughout the document to improve its clarity,
completeness, and accuracy. Appendix B also explains the modifications
made to this EA in response to these comments.
Comments were received from the following parties: Ms. Amy Fitzgerald,
Ph.D., Executive Director, Oak Ridge Reservation Local Oversight
Committee (ORR LOC); Mr. Earl C. Leming, Director, Tennessee Department
of Environment and Conservation, DOE Oversight Division (TN DEC); Mr.
Elgan H. Usrey, Assistant Director, Tennessee Emergency Management
Agency (TEMA); Mr. Harry H. Kelso, Director, Enforcement and Policy,
Virginia Department of Environmental Quality (VA DEQ); Mr. Ralph
Hutchison, Coordinator, Oak Ridge Environmental Peace Alliance (Oak
Ridge Env. Peace Alliance); Mr. Gregory A. Richardson, Executive
Director, North Carolina Commission of Indian Affairs, North Carolina
Department of Administration; Mr. Bill Flournoy, State of North
Carolina, Department of Environment, Health and Natural Resources (NC
DEHNR); Mr. Larry Sams, Assistant to the State Highway Administrator
State of North Carolina, Department of Transportation; Ms. Chrys
Baggett, Director, North Carolina State Clearinghouse, Department of
Administration; and Mr. James A. Whitaker, Mayor, the City of Lynchburg,
Virginia.
In addition, correspondence was received from Mr. Don Hancock, Southwest
Research and Information Center (SW Research and Information Center).
1. The public was not given enough time to properly review and comment
on the EA in accordance with NEPA guidelines. In addition, members of
the public were not provided with early notice of preparation of this
EA. DOE also needs to solicit comments from a much larger group of
stakeholders than just the affected states and Native American groups,
to be consistent with the Secretary of Energy's NEPA policy and CEQ
regulations.
No. of Comments 6 Document(s) ORR LOC; TN DEC; TEMA; NC DEHNR ;SW
Research and Information Center; Oak Ridge Env. Peace Alliance
Response: Based on concerns raised by several reviewers, the review
period was extended from April 26, 1995, to May 5, 1995, for a total of
24 days. The original review period was established based on the
discretion given to DOE in 10 CFR 1021.301(d) of 14 to 30 days for
affected state and tribe review. Since the Preapproval Copy EA was
brief, consisting of 26 pages of text plus the appendices, the review
period with the extension is considered to be appropriate by DOE. The
Preapproval Copy review distribution included the potentially affected
states and tribes, and local government officials. In addition, several
communications addressed DOE's plan to prepare the EA. These included
letters to the affected states, Native American tribes, letters to
individuals, and the NOI (60 CFR 17344) for the Disposition of Surplus
HEU EIS. Although not required by NEPA, DOE or CEQ regulations, the
Preapproval EA was distributed to local oversight organizations, and
copies were made available to other interested individuals and groups,
upon timely request, consistent with the Secretary's 1994 Policy on the
National Environmental Policy Act for enhanced public involvement when
possible and the CEQ regulations concerning public involvement. The
final EA will be made available upon request.
2. The Department should have made available for public review all
documents upon which the EA was based. Release of those documents would
have helped members of the public evaluate assertions made in the EA.
The principal documents of concern should have included all reference
documents containing cost/benefit analysis of downblending prepared by
either DOE or its contractors and any classified or previously
classified documents containing information on costs associated with the
acquisition of the Kazakhstan-origin HEU. The price paid to Kazakhstan
and the cost of preparation and transportation of the Kazakhstan-origin
materials are two examples of cost information that should have been
released.
No. of Comments 2 Document(s) TN DEC; Oak Ridge Env. Peace Alliance
Response: All of the documents listed in Section 5 of the EA are
currently available for public review, and copies of specific referenced
documents were provided upon request. The purchase agreement for the
United States acquisition of the Kazakhstan-origin HEU, is classified,
was not used in preparing this EA, and does not address blending of the
material in the United States. A cost/benefit analysis is not required
for an EA. However, the eventual sale of the blended material would
help to offset the costs associated with the purchase and blending of
the Kazakhstan-origin HEU. The Proposed Action would also avoid
additional cost associated with the continued storage of the material at
the Y-12 Plant. Section 1.1 of the EA has been expanded to include an
explanation of why a detailed cost/benefit analysis was not prepared for
the EA.
3. Declassified versions of the EA (DOE/EA-1006) and FONSI issued last
Fall concerning the transportation of Project Sapphire HEU from the
Republic of Kazakhstan to Oak Ridge should have been made available.
No. of Comments 3 Document(s) ORR LOC; TEMA; Oak Ridge Env. Peace
Alliance
Response: The classified EA was not listed or used as a reference for
the preparation of this EA. However, unclassified versions of the EA
and FONSI have now been provided to the Oak Ridge and other public
reading rooms, and copies have been provided to individuals upon
request. While the declassification of the EA was completed on March 6,
1995, administrative and other reviews were not completed and the
document was not released until approximately April 17, 1995. Any delay
in release of the documents was not related to the release of this EA
for review and was not intended to withhold any information from the
reviewers. DOE regrets any inconvenience that this may have caused the
public in reviewing DOE NEPA documents.
4. The EA should have included a list of the agencies and persons
consulted in preparation of the EA as directed under 40 CFR 1508.9(b).
No. of Comments 1 Document(s) TN DEC
Response: A list has been included in Section 6 of the EA.
5. The Proposed Action concerning the Kazakhstan-origin HEU should be
connected with the environmental impact statement (EIS) for the proposed
disposition of the United States-origin stockpiles of surplus weapons
usable HEU. DOE must adopt a "cradle to grave" approach for considering
the disposition of surplus HEU.
No. of Comments 2 Document(s) Oak Ridge Env. Peace Alliance; NC DEHNR
Response: As discussed in Section 1.1 of the EA, the Kazakhstan-origin
HEU was purchased in accordance with the President's Nonproliferation
and Export Control Policy. As discussed in Section 1.4 of the EA, the
HEU considered in the EA is separate from the United States' stockpiles
of HEU because, among other things, it is of foreign origin and is a
small quantity. The purchase and conversion of the Kazakhstan-origin
HEU is a high priority action, separate from the conversion of HEU
material in the United States' stockpiles due to the small quantities
involved and the need to proceed in a timely fashion in order to
demonstrate to the international community our commitment to the
nonproliferation objectives underlying the acquisition of the HEU from
Kazakhstan. Section 1.4 of the EA has been clarified in response to
these comments. Issues related to the nuclear fuel cycle, spent fuel
disposition, and waste disposal are also addressed in comment responses
9 and 17.
6. Why is it necessary for DOE to begin blending the Kazakhstan-origin
HEU within six to nine months? This deadline has been used as a
justification for accelerating the preparation of the EA and ultimately
shortening the comment period for public review.
No. of Comments 2 Document(s) Oak Ridge Env. Peace Alliance; NC DEHNR
Response: A discussion of the reasons for the expeditious timing
surrounding the blending of the Kazakhstan-origin HEU has been expanded
in Section 1.4 of the EA. On November 29, 1994, the White House issued
a press release regarding the transfer, safe storage, and conversion of
the Kazakhstan-origin HEU in the United States. The press release also
contained a general schedule for the disposition of the Kazakhstan-
origin material. As discussed in Section 1.1, Section 2, and Appendix E
of the EA, the White House press release announced that consistent with
the President's Nonproliferation Policy, it was planned that within six
to nine months of receipt of the HEU into safe secure storage in the
United States, the Kazakhstan-origin HEU would be transferred to a
commercial facility where downblending would occur. The safe conversion
of this material to a form that cannot readily be used for nuclear
weapons should proceed as expeditiously as possible in order to
strengthen the United States' commitment to help build a more secure
international environment.
7. The EA did not adequately address environmental justice issues
associated with the Proposed Action. The discussion of these issues did
not describe potential routes for material other than HEU or attempt to
evaluate the potential impact upon any population group living along
those transportation routes. In addition, there is no indication if an
analysis of representative routes was performed. If no such analysis
was done, then an explanation as to why should be included in the EA.
No. of Comments 1 Document(s) NC DEHNR
Response: Section 4.7 has been modified to explain that representative
routes were used for the HEU transportation analysis. Environmental
justice is discussed in Sections 1.2 and 4.7 of the EA. As described in
Section 4.7 of the EA, the potential impacts associated with the
transportation, storage, and blending of the Kazakhstan-origin HEU are
small. As a result, no high and adverse impacts are expected for the
surrounding population. No disproportionately high and adverse impacts
are expected for any segment of the population, particularly minorities
and low-income residents.
8. The HEU material should be further characterized prior to any off
site shipment. The EA fails to identify and evaluate the materials the
EA purports to assess. Most of the material is something other than
HEU. What is the other material and how shall its potential impacts be
assessed?
No. of Comments 2 Document(s) ORR LOC; Oak Ridge Env. Peace Alliance
Response: The Kazakhstan-origin HEU is already in safe secure storage
at the Y-12 Plant. Storage conditions for the HEU material at the Y-12
Plant are discussed in Section 4.6 of the EA. Analysis of the HEU
samples was conducted in Kazakhstan in early April 1994 and subsequently
at the Y-12 Plant in accordance with a sampling program, the objective
of which was to characterize the Kazakhstan-origin material prior to
shipment to the Y-12 Plant (DOE, 1995b). Representative sampling and
analysis, including complete chemical and isotope analysis of samples at
the Y-12 Plant was completed before shipment in accordance with the
plan, and the results are summarized in Appendix C of the EA. The
Kazakhstan-origin material contained HEU metal, uranium oxides, uranium-
beryllium alloy rods, uranium-beryllium alloy scrap, HEU containing
graphite, uranium-236, uranium-232, and plutonium. The HEU is currently
packaged in 1,299 stainless steel cans, as described in Appendix C, each
individually numbered with a mylar seal. These cans are packaged in
NRC-approved shipping containers which are also sealed with tamper-proof
devices. Any additional characterization at the interim storage
location at the Y-12 Plant would require breaking the integrity of this
sealed system. The Y-12 Plant is only a temporary trans-shipment point,
and it was not considered prudent to break the sealed system until the
material was received at the blending facility. No additional
characterization is anticipated prior to offsite shipment.
9. The EA provided an inadequate discussion of the consequences of the
Proposed Action. DOE failed to consider impacts associated with the
creation and disposal of spent nuclear fuel. In addition, the EA did
not provide an explanation of the alternatives it evaluated and why some
of those alternatives were discarded. For example, the EA ignored a
less than four percent blending option, such as a one percent enrichment
or blending to some enrichment level between four percent and 20
percent.
No. of Comments 2 Document(s) Oak Ridge Env. Peace Alliance; NC
DEHNR
Response: As explained in Section 1.2 of the EA, potential indirect
impacts associated with either further processing of the uranyl nitrate
into commercial reactor fuel or its use as a fuel to furnish electrical
power are discussed but are not analyzed in detail in this EA. DOE is
currently characterizing and will prepare an EIS for the disposal of all
spent nuclear fuel, including any spent nuclear fuel that may be
indirectly associated with the commercial reactor fuel derived from the
uranyl nitrate that would result from the Proposed Action. Section 1.1
has been expanded to provide an explanation for blending the material
for use in commercial nuclear reactor fuel rather than blending to some
other enrichment level between greater than four percent and less than
20 percent, or less than one percent enrichment. The commercial
reactors that would potentially use the fuel derived from the
Kazakhstan-origin material would not experience modifications to their
current operations or increased spent fuel generation because this LEU
would be used in place of new LEU. An option to blend the material to
less than four percent (e.g., less than one percent) enrichment was not
analyzed in detail because this option would fail to meet the Purpose
and Need described in Section 2 of the EA. Specifically, this option
would fail to convert the HEU to peaceful use as commercial reactor
fuel.
10. The EA did not provide any rationale for the shipment of uranyl
nitrate to USEC Portsmouth. If the uranyl nitrate is destined for
fabrication into fuel rods, wouldn't the preferred action be to leave
the material at the blending site or ship it to the fabrication site in
order to minimize transportation risks?
No. of Comments 1 Document(s) Oak Ridge Env. Peace Alliance
Response: USEC has storage capacity for the uranyl nitrate (solid form)
in the X330 facility at Portsmouth. As explained in Section 1.2 of the
EA, the exact allocation and site specific location and timing of the
eventual fuel fabrication is not known at this time, has not been
specifically proposed and would be contingent upon the needs and
specifications of potential customers. However, if USEC selects one or
more fuel fabrication facilities prior to completion of the Proposed
Action, DOE may consider transporting uranyl nitrate directly to that
facility. As discussed in Section 4.5 of the EA, transportation of the
uranyl nitrate from the blending site to USEC Portsmouth was considered
as a representative transportation activity for the material. The risk
of transporting the uranyl nitrate is very low, and the material will be
transported by commercial carrier as is routinely done. In addition,
USEC Portsmouth would be required to maintain appropriate safeguards and
security and certifications in order to receive the uranyl nitrate
shipment. As explained in Section 4.5 of the EA, if the uranyl nitrate
were shipped to a domestic destination other than USEC Portsmouth the
transportation impacts would differ slightly but are not expected to
differ substantially.
11. The EA should have provided discussions of the security measures
designed for the weapons-usable HEU at all times and locations.
No. of Comments: 1 Document(s) Oak Ridge Env. Peace Alliance
Response: Under the Proposed Action, there are only four locations
where the HEU material would be located: the Y-12 Plant, NFS and B&W
blending facilities, and an SST. The Y-12 Plant complies with DOE
safeguards and security. Both B&W and NFS are NRC licensed and are
required to have the appropriate safeguards and security to receive
shipments of HEU. SSTs are designed as safe secure packaging for the
materials contained therein even in the event of a serious accident.
12. The EA did not provide any information concerning radiation levels
associated with the handling and transport of the Kazakhstan material.
Specific gamma and neutron radiation exposure rate information for
various parts of the process should have been included. In addition,
there was no clear summary of health effects from the total operation
for all handling, transfer, storage, and blending of the entire stock of
Kazakhstan-origin HEU. As a result, the summary of impacts discussion
should have been expanded to include a discussion of both the overall
and individual risks associated with each component of the Proposed
Action.
No. of Comments 1 Document(s) NC DEHNR
Response: Section 4.3 of the EA provided a discussion of impacts
associated with the Proposed Action. Radiological exposures associated
with routine operations for processing HEU at the B&W and NFS blending
facilities has been added to Sections 4.3.4.1 and 4.3.4.2,
respectively. As discussed in those sections, the cumulative dose for
the maximally exposed individual during normal operations at B&W and
NFS is estimated as 0.05 mrem/year and 2.3 mrem/year respectively. The
cumulative dose to the surrounding population living within an 80 km (50
mile) radius of the plant site is estimated at less than one person-
rem/year for B&W and 14.6 mrem/year for NFS during normal operations.
For normal operations at the GE Wilmington facility, the cumulative dose
to the maximally exposed individual is estimated to be 0.13 mrem/year,
and the cumulative dose to residents within 80 km (50 mile) is estimated
as 0.15 person-rem/year. Radiological exposures associated with each
step in the transportation of the Kazakhstan-origin HEU are presented in
Tables 4.3.1-1, 4.3.2-1, 4.3.2-2, and 4.3.3-1. Section 4.3 includes
discussion of not only the incremental risks but also the overall risks
associated with the Proposed Action. Section 4.7 of the EA summarizes
the transportation impacts associated with the Proposed Action, and
Section 4.8 describes the cumulative impacts of the Proposed Action.
13. The EA states that 600 kg of HEU represents approximately 0.4
percent of the total quantity of HEU at the Y-12 Plant. Providing
information on any incremental increases to criticality issues from the
addition of 600 kg of HEU would be more meaningful because increased
radioactivity is a more significant issue than quantity in this case.
Because beryllium is an effective neutron reflector, extensive
criticality analysis would be needed.
No. of Comments 2 Document(s) TN DEC; TEMA
Response: DOE has evaluated the environmental impacts, including
criticality issues, from storing HEU at the Y-12 Plant in the
predecisional September 1994 Environmental Assessment for the Proposed
Interim Storage of Enriched Uranium Above the Maximum Historical Storage
Level at the Y-12 Plant, Oak Ridge, Tennessee. Section 4.6 of this EA
references the Y-12 EA and discusses potential impacts from storing the
HEU material at the Y-12 Plant. The Y-12 EA includes analysis of storage
of up to 500 metric tons of HEU, of which up to five metric tons could
be from foreign sources. Sections 4.3.4.1 and 4.3.4.2 discuss
additional controls that would be implemented at the blending facilities
to ensure that the beryllium does not cause any criticality concerns.
Before the material was shipped to the Y-12 Plant, criticality safety
evaluations for transportation of those HEU and beryllium materials took
into account the (criticality) reactivity effects (moderation and
reflection) when calculating the neutron multiplication factor for the
various loading limits listed in 49 CFR 173.417. In all cases, the
actual loadings were within these loading limits and are adequately
subcritical in the handling can/storage container configurations. In
addition, these calculations accounted for the neutron production from
the uranium alpha-decay process in which alpha strikes a beryllium atom
nucleus, causing one or more neutrons to be released.
14. The EA did not provide a clear explanation of how population
estimates of 3 million people are derived for the bounding accident
analysis (Section 4.3.2, Table 4.3.2-1). In addition, the EA should
also provide an explanation of how "urban areas" are defined along
transportation routes in the bounding accident analysis and whether
current demographics were used. In the Affected Environment Appendix
the NFS discussion used 1980 census data, which does not lend credence
to the document.
No. of Comments 2 Document(s) ORR LOC; TEMA
Response: Sandia National Laboratories, Albuquerque, New Mexico,
performed the transportation risk analysis using the RADTRAN 4 computer
code and HIGHWAY, a computer highway routing code. The population size
is defined as the product of the number of people per square kilometer
along the link with the highest population density, and the area covered
by the plume at the maximum radius considered, 80 km (50 miles). This
is a conservative method for determining population size due to
variations in meteorological data for the areas considered (e.g., wind
velocity and atmospheric turbulence data for arbitrary points along a
route). Urban population areas are those in which the distance-averaged
population density within 0.8 km of the center of the highway,
calculated by the HIGHWAY code, exceeds 1,670 persons per square
kilometer. The 1980 census data used was quoted by an NFS EA in 1991.
According to the NFS EA, the 1980 census data represented the most
current data available at the time. However, the most recent (1990
census), currently available urban, suburban, and rural population data
was used as input for the HIGHWAY code and for the analyses included in
the EA.
15. The Department appears to be de-emphasizing the potential risks
associated with transporting these materials. Although the number of
shipments is small, the content is extremely large compared to civilian
shipments. Also, the postulated accident in RADTRAN Transportation Risk
Analysis Methodology Appendix only addresses the dispersion of five
percent of the load. A serious accident or terrorist bombing could
disperse much more.
No. of Comments 1 Document(s) TEMA
Response: The analyses discussed in Section 4.2.1 and Appendices G and
H of the EA are extremely conservative, and are based on earlier studies
at one of the DOE facilities. These studies postulated the releases as
a result of an energetic projectile on 1,000 kg of 93 percent enrichment
HEU in an SST load, whereas each SST load for the Proposed Action would
transport only approximately 50 kg. Specific safeguards and security
systems, including armed courier surveillance, are in place to protect
SST shipments from sabotage, terrorism, and other threats; however, the
majority of this information remains classified. SSTs are designed and
rigorously tested to ensure that they provide safe secure protection for
materials contained within, even in the event of a serious accident. In
addition, the SSTs are seldom stationary, utilize secret routes, and are
not visually distinguishable from other trucks. The possibility exists,
however, that a terrorist bomb exploded alongside an SST could disperse
more than five percent of the load, but current security procedures
minimize the likelihood of such an event happening. The release of five
percent of the 1,000 kg load used in this scenario would be equivalent
to the release of an entire 50 kg load of Kazakhstan-origin material for
the Proposed Action. (The enrichment level may be slightly higher or
lower depending on the material.) This scenario would result in a
maximum of two latent cancer fatalities, but it has an even lower
probability of occurring than the bounding accident in an urban area
analyzed for this EA and presented in Section 4.3.2 and Table 4.3.2-1.
The probability of the bounding accident in an urban area analyzed in
this EA is less than 3.9x10E-12 (less than one chance in 200 billion),
and the probability of a terrorist or other attack resulting in the
dispersement of an entire 50 kg load of Kazakhstan-origin material for
the Proposed Action is even lower.
16. The EA should address in more detail the total number of shipments
for all materials and operations, the total number of miles,
transportation routes, and local emergency capabilities along those
routes. States and local communities should be notified of the
transportation of all non-classified materials so they can be better
prepared for potential accidents. In addition, the 12 shipments
required for transportation of all the Kazakhstan-origin HEU constitute
a shipping campaign and as such require prior notification under the
DOE/TEMA/TDEC agreement.
No. of Comments 2 Document(s) TEMA; VA DEQ
Response: The total number of shipments for each material are indicated
in Sections 4.3.1 (12 shipments of HEU to the blending site), 4.4.1
(three truckloads of UF6 blending stock to GE Wilmington), 4.4.3 (five
truckloads of uranium oxide blending stock to the blending site), and
4.5 (14 truckloads of uranyl nitrate to USEC Portsmouth). As discussed
in Section 4.7 of the EA, the transportation routes for the Kazakhstan-
origin HEU are classified and cannot be openly identified and
addressed. DOE and ORR will coordinate all shipments required under the
Proposed Action with appropriate state and local officials. If
requested, DOE will assist appropriate state and local officials with
response plans and if necessary, with resources in accordance with
guidelines established in DOE Order 5530.3. DOE has developed a
Radiological Assistance Program (RAP), also outlined in DOE Order
5530.3, to provide assistance in all types of radiological accidents.
Regional RAP plans include coverage of the states and provide for
maintaining and executing response plans.
17. At present the B&W site has two VPDES permitted facilities in
Virginia. Additional information should be incorporated to address
which facility at B&W will receive the Kazakhstan-origin HEU for
processing and whether permit modifications may be required as a result.
Information on whether there should be any release of radioactive
materials in effluent discharge from the site needs to be added. In
addition, procedures for interacting with appropriate state departments,
agencies, and emergency services to ensure safe shipping and compliance
with state environmental and safety laws should be added.
No. of Comments 2 Document(s) VA DEQ; TEMA
Response: The Naval Nuclear Fuel Division (NNFD) facility, as described
in Appendix F, Section F.2.1, is the B&W site that could receive the
Kazakhstan-origin HEU for processing. Sections 4.3.4.1 and 4.3.4.2 of
the EA, respectively, discuss modifications that may be required to B&W
and NFS' environmental permits prior to the implementation of the
Proposed Action. The EA addresses the types and quantities of wastes
which would be released from the processing operation at B&W and NFS in
these sections, and no mixed wastes would be generated from the
processing operations. Any actions undertaken during implementation of
the Proposed Action will be coordinated with the appropriate state and
local authorities to ensure compliance with all applicable permits and
regulations.
18. The EA does not provide a detailed analysis of potential impacts to
biotic, cultural, geologic, and socioeconomic resources.
No. of Comments 1 Document(s) ORR LOC
Response: The rationale for not including detailed analysis in these
areas is included in Section 1.2 of the EA. No construction activities
are associated with the Proposed Action, so there would be minimal
impacts to biotic, archaeological, geologic, or cultural resources.
Essentially no changes in the number of workers or the regional
population are projected, therefore impacts to socioeconomic resources
would also be minimal. Only minor modifications or upgrades to the
processing systems would be required (i.e., HEPA filters and demisters),
as described in Sections 4.3.4.1, 4.3.4.2, and 4.4.2 of the EA.
19. In the Affected Environment Appendix, the area surrounding ORR
should not be characterized as predominantly rural given that almost 1
million people reside within an 80 km (50 mile) radius of ORR.
No. of Comments 1 Document(s) ORR LOC
Response: The appendix has been reworded to indicate that the land area
immediately surrounding ORR is sparsely populated and rural, while land
area in surrounding counties is often densely populated and urban. The
last sentence of the first paragraph of the ORR description in Appendix
F has been reworded to indicate that ORR is approximately three miles
from downtown Oak Ridge.
20. Section 4.6 of the EA referenced the predecisional September 1994
Environmental Assessment for the Proposed Interim Storage of Enriched
Uranium Above the Maximum Historical Storage Level at the Y-12 Plant,
Oak Ridge, Tennessee. This document is not technically sound because
the historical data presented does not adequately address issues such as
whether proper maintenance of storage buildings has occurred, whether
any risks from incremental increases of stored enriched uranium exist
and whether there is actually enough capacity for storage.
No. of Comments 2 Document(s) TN DEC; Oak Ridge Env. Peace Alliance
Response: Under the no action alternative, the Kazakhstan-origin HEU
would remain in safe secure storage at the Y-12 Plant. No blending,
transportation, or waste-related impacts would result. The analysis of
risks from incremental increases in the quantity of stored enriched
uranium, actual storage capacity, and the proper maintenance of storage
buildings are within the scope of the predecisional September 1994 Y-12
EA and were not addressed in this EA.
21. The Department announced that the Kazakhstan-origin HEU would be
placed under the control of the International Atomic Energy Agency
(IAEA). At this time, approximately six months later, the material has
not been placed under IAEA control, and there are currently no
negotiations between DOE and IAEA concerning such action.
No. of Comments 1 Document(s) Oak Ridge Env. Peace Alliance
Response: IAEA control is not an environmental issue associated with
the Proposed Action. However, the IAEA has been kept informed of the
existence and location of the Kazakhstan-origin HEU. The IAEA met with
representatives of the United States government in February 1995, and
indicated their preference to wait until the material was received at
the blending facility to initiate inspections. In early April 1995, the
United States Mission in Vienna was again informed by the IAEA that
inspections would not be initiated until the material was received at
the selected blending facility. In the interim, the material has been
maintained in safe secure storage at the Y-12 Plant and has remained in
the sealed containment system applied in Kazakhstan (see comment
response #8). The list of United States facilities eligible for IAEA
safeguards includes all commercial nuclear power reactors.
22. The EA evaluated two commercial sites that have limited operational
experience in processing uranium material with high concentrations of
beryllium. The EA did not adequately discuss what additional training
is needed for workers at either of the two sites under the Proposed
Action. Given the lack of operational experience, the EA should have
evaluated the option of keeping the HEU material onsite at Y-12 until
either the commercial workers or Y-12 workers were properly trained to
perform the necessary functions to blend the HEU.
No. of Comments 4 Document(s) ORR LOC; TN DEC; TEMA; Oak Ridge Env.
Peace Alliance
Response: The EA discusses some additional measures that the B&W and
NFS sites may have to implement under the Proposed Action. These
measures are outlined in Sections 4.3.4.1 and 4.3.4.2 of the EA for the
B&W and NFS facilities, respectively. In addition, standard established
industrial safety practices for the handling of beryllium would be
implemented as required. Examples of additional measures include
controls such as air samplers for detecting beryllium and training on
the potential hazards associated with handling beryllium. There are only
two DOE facilities, the Y-12 Plant and SRS, that could provide the
blending services needed for the Proposed Action. The rationale for
eliminating these sites from detailed evaluation is discussed in Section
1.1 of the EA.
23. The EA should address why there are different time estimates for
processing operations at B&W and NFS (38 and 120 days, respectively).
No. of Comments 1 Document(s) ORR LOC
Response: Estimates of time duration were obtained from direct
correspondence with personnel at the sites involved and are based on
capacity and capability.
Appendix C: Constituents of Kazakhstan-origin HEU
There are 1,299 cans of Kazakhstan-origin HEU that would be transported
to the blending site. Laboratory analyses were performed on a number of
representative samples collected in March 1994 (DOE, 1995b). A brief
description of the results of the analyses is presented below.
Additionally, laboratory analysis indicated that the samples contained
some U-236 and U-232 and contain small but measurable quantities of
plutonium. The net mass total of the Kazakhstan-origin material is
approximately 2.4 metric tons.
The cans of HEU are currently packaged in a model 6M, Type B packaging,
which is designed to prevent the release of contents under all credible
transportation accident conditions.
Table C-1.- Constituents of Kazakhstan-origin HEU
Form of Material Number of Cans Total U-235 (kg)
HEU metal consisting of 15 168.7
small cylinders and pellets
Uranium oxides primarily 14 29.7
as powders
Uranium beryllium 315 148.6
alloy rods
Uranium oxide-beryllium 35 1.6
oxide rods
Uranium-beryllium alloy scrap 870 231.5
consisting of powder, rocks,
and chunks
HEU containing graphite 48 0.7
Assay samples 2 0.2
Total 1,299 581.0
Appendix D: Regulatory Issues and Authorizing Agencies
Issue Agency Regulation
Packaging Nuclear Regulatory 10 CFR 71 establishes standards for
Commission (NRC) packaging and transportation of licensed
materials. It further provides
procedures and standards for NRC approval
of packaging and shipping fissile
materials.
DOE DOE Order 5480.3 outlines the safety
requirements and procedures for the
packaging and transportation of hazardous
materials, hazardous substances, and
hazardous waste including fissile
materials.
DOE Order 1540.2 establishes
administrative procedures for the
certification and use of radioactive and
other hazardous materials packaging.
Department of 49 CFR 173 specifies packaging
Transportation requirements for transportation of
(DOT) hazardous materials
Transpor- DOT 49 CFR provides strict regulations and
tation procedures to ensure the safe shipment
of radioactive materials. This includes
restricting the quantity of radioactive
material that can be shipped over
roadways and further requires that
carriers be permitted. DOT regulations
also require the use of appropriate
placards on packages and vehicles to
alert workers, officials, and the
public to the hazardous characteristics
of the material being shipped.
DOE DOE Order 1540.1A establishes policies
and procedures for the management of
materials transportation activities,
including traffic management. The
policies and procedures in this order
include the management of radioactive
materials transport.
DOE Order 5632.2A establishes baseline
protection requirements for special
nuclear materials in transit, providing
appropriately graded levels of protection
for each shipment.
DOE Order 5610.14 ensures that
transportation safeguard system
operations are accomplished in a manner
commensurate with established practices
and procedures for cargo safeguards,
program continuity, and protection of
national security, personnel, the public,
and the environment.
Worker DOE DOE Order 5480.10 establishes procedures
Health and requirements for industrial hygiene
and Safety programs. DOE Order 5483.1A establishes
procedures and requirements for
industrial safety programs.
Occupational 29 CFR 1910 Hazard Communication
Safety and Standard requires that workers are
Health informed and trained to handle hazards
Administration in the workplace. It also establishes
(OSHA) permissible exposure limits for 8-hour
exposures and short-term exposure limits
for 30-minute exposures for workers
handling hazardous materials.
Air Environmental 40 CFR 61 establishes National Emission
Quality Protection Standards for Hazardous Air Pollutants
Agency (EPA) (NESHAPS) which detail air quality
standards and maximum exposure levels.
Appendix E: Transfer of Kazakhstan-origin HEU Press Release
This appendix contains a copy of the statement released by the White
House on November 11, 1994 regarding the transfer of vulnerable nuclear
materials (HEU) from Kazakhstan to safe storage in the United States.
This statement describes the transfer of the HEU into the United States
and establishes a general schedule for its disposition.
THE WHITE HOUSE
Office of the Press Secretary
For Immediate Release
November 29, 1994
The United States and Kazakhstan Announce the Transfer of
Vulnerable Nuclear Materials to Safe Storage
In an historic step toward meeting the proliferation challenges of the
post Cold War era, the United States and Kazakhstan today completed the
successful transfer of vulnerable nuclear materials from Kazakhstan to
safe storage in the United States. The weapons-grade materials remained
in Kazakhstan following the break-up of the Soviet Union.
The government of Kazakhstan approached the United States early in 1994
concerning approximately six hundred kilograms of highly enriched
uranium on its territory. Kazakhstan was concerned about the security
of the material and asked for U.S. assistance in removing it to safe
storage. As part of its commitment to the Nuclear Non-Proliferation
Treaty, Kazakhstan has been taking careful measures to implement full-
scope safeguards under the International Atomic Energy Agency.
Kazakhstan wishes to see the material removed from its territory before
the safeguards are put in place in December.
The United States and Kazakhstan worked closely together to achieve this
important success in securing these vulnerable nuclear materials.
President Clinton congratulates the U.S. and Kazakhstani teams, which
safely carried out the mission, and warmly commends President Nursultan
Nazarbayev for his international leadership in nuclear nonproliferation.
The President looks forward to future cooperation with President
Nazarbayev to achieve our mutual nonproliferation goals.
The President has identified nonproliferation as a key national security
objective for his Administration. With the end of the Cold War, the
risk of proliferation of weapons of mass destruction has increased.
Ensuring the security of nuclear materials is one of the key components
of the Administration's strategy. Through programs such as Nunn-Lugar
and other denuclearization initiatives, important progress has been made
to build a more secure international environment. Today's transfer of
weapons-grade nuclear materials from Kazakhstan to a secure facility in
the United States is another critical part of this effort.
The material that will be stored at Oak Ridge is not considered waste.
It is special nuclear material which can be used in nuclear weapons and
it will be placed under IAEA safeguards.
It is currently planned, consistent with the President's
nonproliferation policy, that the material will be transferred to a
commercial facility within six to nine months, where the material would
be blended down for use in commercial nuclear reactors. The Department
of Energy will issue a Request for Proposal for commercial firms
interested in doing this work.
The Department of Energy has been in close communication with the
Defense Nuclear Facilities Board, which has safety oversight
responsibility, to ensure that storage of this material poses no risk to
the health and safety of the local public. The Department has addressed
all problems raised by the Board with respect to matters of health and
safety.
Appendix F: Affected Environment
This section briefly describes the affected environment of each site
involved in the Proposed Action.
F.1 HEU Interim Storage Site
F.1.1 Oak Ridge Reservation Y-12 Plant
The ORR is a DOE-owned complex that encompasses approximately 140 square
km (54 square miles) in Anderson and Roane Counties in Eastern
Tennessee. ORR is in the incorporated area of the City of Oak Ridge
(Figures F.1.1-1 and F.1.1-2). Much of the land area immediately
surrounding ORR is sparsely populated and rural, while other land in
surrounding counties is often densely populated and urban. Regional
land uses include residential, commercial, recreational, and
agricultural areas. The current estimated residential population within
an 80 km (50 mile) radius of ORR is approximately 880,000 (DOE, 1994a).
Knoxville, Tennessee, located 32 km (20 miles) to the east of ORR, is
the largest urban area with a population of approximately 165,000. The
City of Oak Ridge has a population of approximately 27,000, and ORR is
located approximately 4.8 km (three miles) from downtown Oak Ridge (DOE,
1995a).
The climate is characterized by warm and humid summers and typically
cool winters. Prevailing winds, which are controlled largely by rigid
topography, are northeasterly or southwesterly in direction. ORR has a
comprehensive air pollution control and monitoring system, ensuring the
ambient air meets air quality standards.
The Clinch River, which is regulated by a series of dams, provides the
regional control of both surface water and groundwater flow from ORR.
Radiation levels in the region are similar to national average
background doses, except in two stretches of bank along the Clinch River
and Poplar Creek.
The ORR was placed on the National Priorities List (NPL) in December
1989, making the site subject to the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA).
The Y-12 Plant is located on the eastern boundary of ORR (Figure F.1.1-
2). Prior to 1992, the primary mission of the Y-12 Plant was to produce
and manufacture nuclear weapons components. With the end of the Cold
War, the mission of the Y-12 Plant has been modified to include storage
of nuclear materials; dismantlement of nuclear weapons components;
transfer of technology; decontamination and decommissioning of selected
facilities; and environmental restoration activities (DOE, 1995a).
In addition to the Y-12 Plant, other ORR primary facilities are the Oak
Ridge National Laboratory (ORNL) and the K-25 Site. The basic mission
of ORNL is to perform energy-related research.
Major programs have included fission and fusion energy research;
materials research; biological and ecological effects of radiation; fuel
cycle and isotopes research; isotope production; and chemical
engineering. The K-25 Site, previously referred to as the Oak Ridge
Gaseous Diffusion Plant, is involved in incineration of wastes that are
under regulation by the Toxic Substances Control Act (TSCA); low-level
radioactive waste management; and environmental restoration (DOE,
1995a).
F.2 Blending Sites
F.2.1 B&W Lynchburg
The B&W Lynchburg site is an operating company of McDermott, Inc., a
subsidiary of McDermott International, Inc. It encompasses 2.1 square
km (0.82 square miles) in the northeastern corner of Campbell County,
Virginia, and is bordered by an oxbow of the James River on the
northern, eastern, and western sides (Figures F.2.1-1 and F.2.1-2).
This site is located in a generally rural area, consisting primarily of
rolling hills with gentle slopes, farmland, and woodlands (B&W, 1991).
In this region, approximately 20 percent of the northern areas of
Cambell County are located within the James River Watershed. The James
River, which the U.S. Army Corps of Engineers estimates produces a
discharge rate of 10,700 m3/s (378,000 ft3/s) at the site, is the major
water resource.
Based on 1980 Census data, the estimated residential population within a
80 km (50 mile) radius of the B&W Lynchburg site is approximately
520,000. The City of Lynchburg, located approximately eight km (five
miles) east of the B&W site, is the largest local population center with
an estimated population of approximately 66,000 (B&W, 1991).
The B&W Lynchburg site has an unusual microclimate that does not mirror
that of Lynchburg in terms of wind speeds, directions, or stabilities.
The unusual temperature conditions and reduced air stability is a result
of the river which bounds three sides of the site. The Virginia Central
Valley Region, which includes the greater Lynchburg area and the
facility site, meets or exceeds all national ambient air quality
standards. External radiation levels in the Lynchburg area are mainly
due to natural sources of cosmic and terrestrial origin.
Three facilities are located at the B&W Lynchburg site: the Naval
Nuclear Fuel Division (NNFD); the NNFD Research Laboratory; and the B&W
Fuel Company (BWFC). The NNFD and the Research Laboratory support the
U.S. Navy propulsion program. The basic mission is to fabricate highly
enriched nuclear fuel elements and assemble these elements into complete
reactor cores for the U.S. Navy. Additionally, NNFD activities include
fabricating and manufacturing fuel elements for research and test
activities, and recovering uranium from scrap materials and zero power
fuel elements (B&W, 1991).
F.2.2 NFS Erwin
NFS Erwin, a privately-owned facility, is located on a 0.23 square km
(0.09 square mile) site in Unicoi County, approximately 0.8 km (0.5
miles) southwest of the city limits of Erwin, Tennessee (Figures F.2.2-1
and F.2.2-2). The area adjacent to NFS Erwin consists primarily of
residential, industrial, and commercial areas. A small agricultural
area is located northeast of the site. Three natural water resources
exist in the vicinity of the NFS Erwin site: the Banner Spring Branch,
Martin Creek, and the Nolichucky River.
Based on 1980 Census data, the estimated population within a 80 km (50
mile) radius of the site is approximately 921,000. The total population
of Unicoi County is approximately 16,400 and the majority of these
people (approximately 10,000) are located in the City of Erwin and
surrounding communities. Johnson City, approximately 27.4 km (17 miles)
north of the site, has a population of approximately 84,200 (NFS, 1991).
The NFS Erwin site is characterized by warm, humid summers and
relatively mild winters. Winds in the vicinity of the site generally
emanate from the south 60 percent of the time and from the north to
north-northwest 20 percent of the time. Air quality in Unicoi County
meets or exceeds the national and state standards for particulate
matter, sulfur dioxide, and carbon monoxide but violates standards for
ozone and nitrogen dioxide, as does air quality throughout Tennessee.
External radiation levels in the vicinity of the NFS Erwin site are due
mainly to natural sources of cosmic and terrestrial origin.
The primary mission of NFS Erwin is to convert HEU into a classified
product used in the fabrication of nuclear fuel. Additionally, NFS
Erwin is involved in research on and development of improved
manufacturing techniques; recovery and purification of scrap uranium;
removal and/or recovery of materials generated in manufacturing waste
streams to prevent environmental degradation; and operation of a
chemistry laboratory (NFS, 1991).
F.3 Other Sites Involved in the Proposed action
F.3.1 USEC Sites
The Energy Policy Act of 1992, passed by Congress in November of that
year, established the government-owned USEC to take responsibility for
the uranium enrichment from DOE beginning July 1, 1993. USEC has
responsibility for two gaseous diffusion uranium enrichment plants
located in Portsmouth, Ohio, and Paducah, Kentucky. USEC leases
equipment, supplies, materials, and facilities from DOE to enrich
uranium. The NRC is scheduled to assume direct oversight of USEC
operations in October 1995, through a unique certification and licensing
arrangement. In the interim, and until certification is granted, DOE is
providing oversight of activities, regulated by the NRC (DOE, 1994c).
F.3.1.1 USEC Paducah
The DOE activities at USEC Paducah are managed for DOE by Martin
Marietta Energy Systems, Inc. It is located in southwestern Kentucky,
approximately 64.4 km (40 miles) east of Cape Girardeau, Missouri, 177
km (110 miles) southwest of Evansville, Indiana, and 16 km (ten miles)
west of Paducah, Kentucky, near the Ohio River (Figure F.3.1.1-1). The
plant occupies three square km (1.2 square miles) located on a 13.7
square km (5.3 square mile) tract in McCracken County, which was
previously part of the Kentucky Ordnance Works TNT Plant. The
population of McCracken County is approximately 60,000. The current
population within a 80 km (50 mile) radius of the site is approximately
300,500 (DOE 1994c).
The area surrounding USEC Paducah is mostly rural, with residents and
farms located in all directions. The north, east, and west boundaries
are defined by the West Kentucky Wildlife Management Area on land that
is managed by the Kentucky Department of Fish and Wildlife Resources.
Also adjoining the northern boundary is the Tennessee Valley Authority
Shawnee Steam Plant (DOE, 1994c).
The site is characterized by warm summers and moderately cold winters.
Wind in the vicinity of the site emanates from the south-southwest.
USEC Paducah is situated in the western part of the Ohio River Basin,
approximately 24 km (15 miles) from the confluence of the Ohio River
with the Tennessee River upstream of the site, and approximately 56 km
(35 miles) from the confluence of the Ohio River and the Mississippi
River downstream of the site. The ambient air monitoring network at the
site ensures that air quality meets or exceeds standards for pollutants,
including radioactive particulates. The radiation dose levels are
nominal compared to the DOE annual dose limit. The major contributors
of radiation is external radiation from and ingestion of sediment in the
vicinity of the site.
The site was proposed for listing on the NPL in the Federal Register on
May 10, 1993. The site is subject to CERCLA requirements.
The primary mission at USEC Paducah is the separation of uranium
isotopes through gaseous diffusion. The process produces enriched
uranium, which is used for nuclear fuel in commercial power plants.
F.3.1.2 USEC Portsmouth
The USEC Portsmouth site is located less than eight km (five miles)
outside Piketon, Ohio, in the Ohio River Valley along the Scioto River
in Pike County, approximately 32 km (20 miles) north of Portsmouth and
113 km (70 miles) south of Columbus. The plant occupies approximately
two square km (0.8 square miles) of the 15 square km (5.8 square mile)
DOE-owned complex (Figure F.3.1.2-1). In addition to the Scioto
River, other water resources include Big Beaver Creek, Little Beaver
Creek, and Big Run Creek. Based on 1990 Census data, Pike County has
approximately 24,000 residents and the total population within 80 km (50
miles) of USEC Portsmouth is approximately 900,000 (DOE, 1994d).
South-central Ohio lies in the Appalachian foothills. The terrain
varies from steep to gently rolling hills. The steep hills
characteristically are densely forested, while the rolling hills provide
marginal farmland. The Scioto Valley is farmed extensively, particularly
with grain crops.
The USEC Portsmouth ambient air monitoring network ensures that air
quality meets or exceeds standards, including radioactive particulate
standards, and any problems that may arise would be detected before the
proliferation of pollution. The radiation dose levels at the USEC
Portsmouth site are well below the limit set by the EPA and DOE. USEC
Portsmouth is not on the NPL, and environmental remediation activities
at the site are monitored under the provisions of the Resource
Conservation and Recovery Act (RCRA).
USEC Portsmouth has been operating since 1955 and its primary mission is
to enrich uranium for national defense and commercial nuclear reactors.
The main process at USEC Portsmouth is the separation of uranium
isotopes through gaseous diffusion. This process produces enriched
uranium which is used for nuclear fuel in commercial power plants. Until
1992, the plant also produced HEU for U.S. Navy nuclear reactors (DOE,
1994d).
F.3.2 GE Wilmington
GE Wilmington, owned and operated by GE Nuclear Energy Production, is
located 9.7 km (six miles) north of Wilmington, North Carolina, in the
Carolina Coastal Plain along the Cape Fear River, approximately 242 km
(150 miles) southeast of Raleigh, North Carolina, and 16.1 km (ten
miles) west of the Atlantic Ocean. The plant occupies 1.4 square km
(0.5 square miles) on a 6.7 square km (2.6 square mile) tract of land in
New Hanover County (Figure F.3.2-1). The population of New Hanover
County is 135,000, with 62,000 residing within the Wilmington city
limits. The current population within a 80 km (50mile) radius of the
site is approximately 200,000 (GE, 1995).
The area surrounding GE Wilmington is mostly rural, with some farms and
single-family residences located along U.S. Highway 117. The land is
mostly level with some gently rolling hills and is crossed by many small
streams and marshy areas. The southeast portion of the site contains
0.7 square km (0.3 square miles) of land classified as swamp forest.
The site is surrounded by undeveloped forest lands except on the west
and east, where it is bordered by the Cape Fear River and U.S. Highway
117, respectively (GE, 1995).
GE Wilmington is licensed by the NRC to convert UF6 to uranium oxides
and has been performing that task for over 25 years. GE Wilmington also
develops and fabricates nuclear reactor fuel, fuel elements, fuel
assemblies, and performs various research and development activities
(GE, 1995).
Appendix G: RADTRAN Transportation Risk Analysis Methodology
The transportation risk analysis for this EA was performed using the
RADTRAN 4 computer code, developed by Sandia National Laboratories,
Albuquerque, New Mexico. RADTRAN calculates the collective dose from a
postulated accident to exposed population segments (workers and the
public). It produces conservative estimates (those that tend to
overstate impacts) of integrated population radiation dose rates in a
way that can be supported by available data. RADTRAN combines user-
determined meteorological, demographic, transportation, packaging, and
material factors with health physics data to calculate the expected
radiological consequences for incident-free transportation and accidents
involving radioactive material. User-assigned parameters are defined by
individual route segment links in conjunction with HIGHWAY, a highway
routing data base (computerized road atlas), that currently describes
over 386,400 km (240,000 miles) of major U.S. highways, including
interstates. Environmental parameters that are quantified using values
specific to each transportation link include transport distance,
accident rates, and population density. Traffic densities are assessed
at the recommended RADTRAN values.
The accident model in RADTRAN assigns accident probabilities to a set of
accident categories from the lowest to the highest severity. The lowest
severity category represents low magnitudes of crush force, accident
impact velocities, fire duration, and puncture impact speed. The
highest severity category represents a large crush force, high impact
velocities, a 962 C (1800 F) fire lasting 1.5 hours, and a high-
puncture-impact speed collision into the side of the vehicle to produce
a hypothetical release of radioactive material. For conservatively
assessing the risk, the bounding accident is the highest severity
category accident used in the analysis and is associated with a
probability of occurrence for each population density area (urban,
suburban, and rural).
The Department has operated SSTs to transport radioactive materials for
more than 119 million km (74 million miles) without an accident that
resulted in a release of radioactive material. Accident probabilities
for SST operations are lower than for commercial truck operations.
However, to conservatively assess the probability of postulated
accidents by SST, accident data from the DOT for the entire commercial
shipping industry (i.e., accidents on interstate highways involving at
least one commercial tractor-trailer, regardless of contents) were used.
Appendix H: Assessment for Transport by SST
The safeguards and security systems for SST transportation are designed
to protect against sabotage, terrorism, and other adversarial actions.
Since the RADTRAN model does not address terrorist attack scenarios, the
Explosive Release Atmospheric Dispersal (ERAD) computer model was used
by the Transportation Safeguards Division to analyze consequences due to
attacks. The most immediate and severe threat to workers and members of
the public from a terrorist attack by military-equipped forces is death
or injury from weapons fire. It is quite likely that one or more DOE
transportation workers (couriers), who are trained and responsible for
protecting the shipments, would suffer fatalities during an attack.
Depending on the proximity of members of the public to the shipment at
the time the attack occurs, civilian casualties also may be expected
from the weapons fire.
While the radiological hazard associated with weapons fire is
substantially less than the physical hazard, it is possible for an
accurately aimed, energetic projectile fired at an SST to cause a
dispersal of HEU into the atmosphere. The effects of such a dispersal
can be bounded. Based on tests done for the Nuclear Emergency Search
Team program, the fraction of material dispersed would be less than five
percent for this type of event. The bounding conditions for the
postulated accident were as follows: the accident occurs in an urban
area; there is maximum loading of the SST (equivalent to 1,000 kg of 93
percent enriched uranium); and, quiet nighttime meteorological
conditions prevail, resulting in low dispersion of radioactive
materials. Under these conditions, the area contaminated would be three
square km (1.16 square miles), and the maximum individual dose would not
be expected to exceed 30 mrem. The upper bound for the collective dose
would be approximately 4,000 person-rem, possibly resulting in two
excess latent cancer fatalities. The anticipated impacts due to weapons
fire would be lower than the bounding case, resulting in a contaminated
area of 1.5 square km (0.58 square miles), a maximum individual dose of
five mrem, and either zero or one excess latent cancer fatality in the
collective population. The anticipated impacts are based on yearly
average meteorological data. The threat analysis for SST shipments is
discussed in more detail in the Environmental Assessment for the
Proposed Interim Storage of Enriched Uranium Above the Maximum
Historical Storage Level at the Y-12 Plant (DOE, 1994a).
Appendix I: 6M, Type B Radioactive Materials Shipment Packaging Test
Sequence
In addition to meeting standards demonstrating it can withstand normal
conditions of transport without loss or dispersal of its radioactive
contents, the model 6M, Type B packaging used for DOE shipments must
survive certain severe hypothetical accident conditions that demonstrate
resistance to impact, puncture, fire, and water submersion. Test
conditions do not duplicate accident environments, but rather produce
damage equivalent to extreme and unlikely accidents. The 6M, Type B
packaging is judged as surviving extreme sequential testing if it
retains all its contents except for minuscule allowable releases, and
the dose rate outside the packaging does not exceed one rem/hr at a
distance of one-m from the package surface. Drum sizes (outer package)
can vary from 38 to 416 liters (ten to 110 gallons).
The complete sequence of tests is listed below:
* Drop Test. A nine-m (30-ft) drop onto a flat, essentially
unyielding, horizontal surface, striking the surface in a position for
which maximum damage is expected.
* Puncture Test. A one-m (40-in) drop onto the upper end of a 15-
centimeter (cm) (six-in) diameter solid, vertical, cylindrical, mild
steel bar mounted on an essentially unyielding, horizontal surface.
* Thermal Test. An exposure for not less than 30 minutes to a heat flux
not less than that of a radiation environment of 800 C (1475 F) with an
emissivity coefficient of at least 0.9.
* Water-Immersion Test. A subjection to water pressure equivalent to
immersion under a head of water of at least 15-m (50-ft) for not less
than eight hours.
The regulatory test conditions for the 6M, Type B packaging and other
similar packagings are much more demanding than they might appear. For
example, an impact on a very hard surface (desert caliche) at over 322
km (200 miles) per hour is not as likely to deform the packaging as
would a drop of 9 m (30 ft) onto an unyielding target.
A typical 6M, Type B packaging approved for use by DOE is covered by
Certificate of Compliance Number 9859, dated January 5, 1994.
The 6M, Type B packaging is made up of several component parts, each
playing an integral engineered role in containment and confinement of
the radioactive material being shipped. The applicable DOE Safety
Analysis Report for Packaging provides additional detail thatshows that
the package provides a high level of public safety regardless of the
accidental conditions it might encounter during transportation.
Although 6M, Type B packagings have been involved in severe accidents,
the integrity of the packaging has never been compromised.
Appendix J: Graphics Depicting Transportation Packagings and Methods
The graphics included in this appendix depict some of the packagings
and transportation methods that would be used to safely contain and
transport the Kazakhstan-origin HEU and UF6 blending stock between the
sites involved in the Proposed Action.