News

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 (g/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 g/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.