EA-1118; Environmental Assessment and FONSI Refurbishment and Construction of Uranium Hexafluoride Cylinder

EA-1118; Environmental Assessment and FONSI Refurbishment and Construction of Uranium Hexafluoride Cylinder Storage Yards at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky

TABLE OF CONTENTS
FIGURES
ACRONYMS AND ABBREVIATIONS
FINDING OF NO SIGNIFICANT IMPACT
PREFACE
EXECUTIVE SUMMARY
1.0  INTRODUCTION
  1.1 BACKGROUND
  1.2 PURPOSE AND NEED
  1.3 RELATIONSHIP TO OTHER UNITED STATES DEPARTMENT OF ENERGY ACTIONS
2.0  PROPOSED ACTION AND ALTERNATIVES
  2.1 NO ACTION
  2.2 PROPOSED ACTION
    2.2.1 Project Location
    2.2.2 Construction
    2.2.3 Cylinder Movement
    2.2.4 Waste Management
  2.3 OTHER ALTERNATIVES
3.0  AFFECTED ENVIRONMENT
  3.1 GEOLOGY
  3.2 WATER RESOURCES
    3.2.1 Surface Water
    3.2.2 Ground Water
    3.2.3 Floodplains
    3.2.4 Wetlands
  3.3 BIOTA
  3.4 THREATENED AND ENDANGERED SPECIES
  3.5 SOILS AND PRIME FARMLAND
  3.6 CULTURAL RESOURCES
  3.7 AIR QUALITY
  3.8 NOISE
  3.9 SOCIOECONOMICS
  3.10 LAND USE
4.0  POTENTIAL IMPACTS
  4.1 ALTERNATIVE 1 - NO ACTION
  4.2 ALTERNATIVE 2 - PROPOSED ACTION 
    4.2.1 Geology
    4.2.2 Water Resources
      4.2.2.1 Surface water
      4.2.2.2 Ground water
      4.2.2.3 Floodplains
      4.2.2.4 Wetlands
    4.2.3 Biota
    4.2.4 Threatened and Endangered Species
    4.2.5 Soils and Prime Farmland
    4.2.6 Cultural Resources
    4.2.7 Air Quality
    4.2.8 Noise
    4.2.9 Socioeconomics
    4.2.10 Land Use
    4.2.11 Transportation
    4.2.12 Waste Management
  4.3 HEALTH AND SAFETY IMPACTS
    4.3.1 Introduction
      4.3.1.1 Exposure and inhalation /ingestion hazards
      4.3.1.2 Physical hazards
    4.3.2 Impacts of Normal Operation in the C-745-T Yard
    4.3.3 Accident Scenarios 
      4.3.3.1 Construction
      4.3.3.2 Cylinder movement
      4.3.3.3 Accident analysis
  4.4 CUMULATIVE IMPACTS
    4.4.1 Water Resources
      4.4.1.1 Surface water
      4.4.1.2 Ground water
      4.4.1.3 Wetlands
    4.4.2 Sensitive Resources
    4.4.3 Air Quality
    4.4.4 Noise
    4.4.5 Socioeconomics
    4.4.6 Land Use
    4.4.7 Transportation
    4.4.8 Health and Safety
    4.4.9 Waste Management
5.0 COMPLIANCE WITH REGULATORY REQUIREMENTS
6.0  AGENCY CONSULTATION
7.0  LIST OF PREPARERS
8.0  REFERENCES

FIGURES

Figure 1-1.	Paducah Gaseous Diffusion Plant Vicinity Map 1-2
Figure 2-1.	Locations of Current, Proposed, and Alternate Sites for Storage of Uranium Hexafluoride Cylinders at the Paducah Gaseous Diffusion Plant 2-2
Figure 3-1.	Current Land Ownership at the Paducah Gaseous Diffusion Plant 3-2
Figure 3-2.	Surface Water Features and Permitted Effluent Outfalls in the Vicinity of the Paducah Gaseous Diffusion Plant 3-3
Figure 3-3.	Surface Water Flow at the Proposed Location of C-745-T Uranium Hexafluoride Cylinder Yard at the Paducah Gaseous Diffusion Plant 3-5
Figure 3-4.	Wetlands Associated with the Proposed Site for C-745-T Uranium Hexafluoride Cylinder Yard at the Paducah Gaseous Diffusion Plant 3-8
Figure 3-5.	Land Use at the Paducah Gaseous Diffusion Plant 3-13
Figure 4-1.	Construction Staging Area and Site Access for the C-745-T Uranium Hexafluoride Cylinder Yard at the Paducah Gaseous Diffusion Plant 4-2
Figure 4-2.	Locations of Current, Proposed, and Alternate Sites for Storage of Uranium Hexafluoride Cylinders in Relation to Other Applicable Ongoing Projects at the Paducah Gaseous Diffusion Plant 4-16

ACRONYMS AND ABBREVIATIONS

235U: uranium-235
bls: below land surface
BMP: best management practice
C.F.R.: Code of Federal Regulations
cm: centimeter
COE: United States Army Corps of Engineers
CWA: Clean Water Act
DE: district engineer
DGA: dense-grade aggregate
DOE: United States Department of Energy
EA: environmental assessment
ERPG: emergency response planning guideline
ft: foot (feet)
ft²: square feet
ft³: cubic feet
H20: water
HF: hydrogen fluoride
K.A.R.: Kentucky Administrative Regulations
KDEP: Kentucky Department for Environmental Protection
km: kilometer(s)
KSNPC: Kentucky State Nature Preserves Commission
LMES: Lockheed Martin Energy Systems, Inc.
LMUS: Lockheed Martin Utility Services, Inc.
m: meter(s)
m²: square meters
m³: cubic meters
mg: milligram(s)
mrem: millirem
NEPA: National Environmental Policy Act
NRC: Nuclear Regulatory Commission
NRCS: Natural Resources Conservation Service
NWP: Nationwide Permit
PCB: polychlorinated biphenyl(s)
PGDP: Paducah Gaseous Diffusion Plant
pH: logarithm of the reciprocal of the hydrogen-ion concentration
PH: person hours
PHA: Process Hazards Analysis
PEIS: programmatic environmental impact statement
RC: risk coefficient
RCRA: Resource Conservation and Recovery Act
rem: roentgen equivalent man
RGA: Regional Gravel Aquifer
SHPO: State Historic Preservation Officer
T&E: threatened and endangered
U.S.C.: U.S.C.A United States Code Annotated
U3O8: uraninite (or pitchblende)
UCRS: Upper Continental Recharge System
UF6: uranium hexafluoride
UO2: uranium oxide
UO2F2: uranyl fluoride
USEC: United States Enrichment Corporation
USFWS: United States Fish and Wildlife Service
WKWMA: West Kentucky Wildlife Management Area
WQC: Water Quality Certification

FINDING OF NO SIGNIFICANT IMPACT

REFURBISHMENT AND CONSTRUCTION OF
URANIUM HEXAFLUORIDE CYLINDER STORAGE YARDS
AT THE PADUCAH GASEOUS DIFFUSION PLANT, PADUCAH, KENTUCKY

AGENCY: U.S. DEPARTMENT OF ENERGY

ACTION: FINDING OF NO SIGNIFICANT IMPACT

SUMMARY: The U.S. Department of Energy (DOE) has completed an environmental assessment (DOE/EA-1118) entitled Refurbishment of Uranium Hexafluoride (UF6) Cylinder Storage Yards

C-745-K, L, M, and P and Construction of a New Uranium Hexafluoride Cylinder Storage Yard

(C-745-T) at the Paducah Gaseous Diffusion Plant (PGDP) at Paducah, Kentucky. Based on the results of the analysis reported in the EA, DOE has determined that the proposed action is not a major Federal action that would significantly affect the quality of the human environment within the context of the National Environmental Policy Act of 1969 (NEPA). Therefore, preparation of an environmental impact statement (EIS) will not be necessary, and DOE is issuing this Finding of No Significant Impact (FONSI). Additionally, pursuant to Executive Order 11990 and DOE regulation 10 CFR 1022, Compliance with Floodplain/Wetlands Environmental Review Requirements, it is reported in this EA that the loss of less than one acre of wetlands at the proposed project site would not be a significant adverse impact.

PUBLIC AVAILABILITY OF EA AND FONSI: The EA and FONSI may be reviewed at and copies of the documents obtained from

U.S. Department of Energy
Environmental Information Center
West Kentucky Technology Park
175 Freedom Boulevard
Kevil, Kentucky 42053

INFORMATION ON THE NEPA PROCESS: For further information on the NEPA process, contact

Ms. Patricia W. Phillips, NEPA Compliance Officer
U.S. Department of Energy, Oak Ridge Operations Office
P. O. Box 2001
Oak Ridge, Tennessee 37831
Phone: (423) 576-4200.

BACKGROUND: The PGDP is a uranium enrichment facility owned by the DOE and operated by the U.S. Enrichment Corporation. Depleted uranium hexafluoride, a solid at ambient temperature, is a residual of the enrichment process. At PGDP, depleted uranium hexafluoride is stored in 32,200 steel cylinders that hold a maximum of 14 tons each.

The DOE is currently evaluating alternative strategies for Department-wide long-term management of depleted uranium hexafluoride. Engineering, cost, and environmental [Programmatic Environmental Impact Statement (PEIS)] analyses are underway. Until the PEIS is completed and a Record of Decision (ROD) is issued on the preferred long-term management strategy, DOE sites must manage cylinders of depleted uranium hexafluoride in a safe and environmentally sound manner. Storage conditions at PGDP are sub-optimal, and there is a concern that before a long-term management strategy is decided, corroding cylinders will eventually release hydrogen fluoride and uranium compounds to the environment. The cylinders are stored on poorly drained gravel pads, many in direct contact with the pad or ground surface, and they are often too close together to enable a full visual inspection of their integrity.

PROPOSED ACTION: The purpose of the proposed action is to improve short-term storage conditions for uranium hexafluoride cylinders at PGDP. To accomplish this, storage yards must be upgraded, and cylinders must be re-spaced. Storage yards C-745-A, B, C will be abandoned and a new storage yard (C-745-T) built so that all cylinder yards are co-located. The proposed action would be comprised of the following activities: (1) renovation of existing C-745-K, L, M, N, and P cylinder yards, which are contiguous and within the PGDP security fence; (2) construction of a new 4-hectare (10-acre) storage yard (C-745-T) at a proposed site immediately south of the K, L, M, N, and P yards, but outside the PGDP security fence; (3) handling and onsite transport of cylinders among existing yards to accommodate construction; and (4) after refurbishment and construction, re-stacking of cylinders to meet spacing and inspection requirements. The new and renovated cylinder storage yards would be constructed with slab-on-grade concrete and would be equipped with adequate storm water drainage systems and lighting. The existing security fence and lighting system would be removed and a new lighting system, along with an extension of the patrol road and fence, would be constructed to encompass the new yard.

ALTERNATIVES: In accordance with NEPA regulations, the no-action alternative was evaluated as an environmental baseline against which impacts of the proposed action and other alternatives were compared. If DOE takes no action, the PGDP inventory of cylinders containing uranium hexafluoride would continue to be stored in yards C-745-A, B, C, K, L, M, N, and P. Continued storage on poorly drained gravel pads would exacerbate corrosion, and inadequate space between cylinders would continue to hinder visual inspections of cylinder integrity.

The proposed action, no action, and alternate sites for the proposed action at PGDP were the only alternatives evaluated in this EA, because all other reasonably foreseeable alternatives, including other onsite storage options at PGDP and UF6 cylinder management at other DOE sites, will be evaluated in the PEIS for long-term management and use of depleted UF6. Consideration of any of the PEIS alternatives in this EA would be duplicative of this effort and predecisional; therefore, their analysis in this EA would be inappropriate. Also, the action proposed in this EA is allowable under 40 CFR 1506.1 as an interim action that is justified independently of the program and will not prejudice the ultimate decision of the program.

ENVIRONMENTAL IMPACTS: PROPOSED ACTION Geology

Construction and refurbishment would be limited to surface grading and excavation to less than 1 m (3 ft) depths. This would not significantly alter site topography and would not affect other geologic characteristics and features at the proposed site of the new yard or at any of the alternate sites.

Water Resources

The addition of concrete pavement in the new and refurbished cylinder storage yards would result in a small but permanent increase in surface runoff to onsite drainage ditches and ultimately, to National Pollutant Discharge Elimination System (NPDES)-permitted outfalls to PGDP surface waters. Also, during construction, erosion of exposed soils may increase siltation to the same ditches and NPDES- permitted outfalls. Best management practices for erosion and sedimentation control will be implemented by the construction contractor to minimize sediment runoff and subsequent increases in stream turbidity, which in turn may affect aquatic biota. Movement of cylinders among yards and storage of cylinders in the refurbished and new yards would not impact surface water and ground water. There is a very low probability of an accidental cylinder breach; however, occupational injuries from the release of hydrogen fluoride and uranium compounds could occur from an accident (see Health and Safety section below).

Water resource impacts would be the same the proposed new yard were constructed at any of the alternate sites, except that runoff would be discharged via a different permitted outfall if Alternate Site 3 is the location of the new storage yard.

Floodplain

The preferred site for the new yard, Alternate Sites 1 and 3 for the new yard, and the refurbished yards are not located within a 100-year floodplain. Portions of Alternate Site 2 are within the 100- year floodplain of a tributary to Bayou Creek.

Wetlands

At the site of the proposed new cylinder yard, six isolated wetlands covering about 0.32 hectare (0.8 acre) would be affected. The DOE was advised by the U.S. Army Corps of Engineers that filling these wetlands is allowable under Nationwide Permit 26, Headwaters and Isolated Waters Discharges. A Notice of Wetlands Involvement was published in the Federal Register on May 3, 1996, and a wetlands impact assessment was conducted for the proposed action. It concluded that the loss of less than an acre of wetlands at PGDP would not be a significant adverse impact.

Disturbance of wetlands could be avoided at Alternate Site 2, and Alternate Site 3 has no wetlands present. Alternate Site 1 has 1.82 hectares (4.5 acres) of wetlands that would be impacted.

Biota

Construction associated with the proposed action would disturb and/or destroy 2.02 hectares (5.0 acres) of grassland habitat, 1.21 hectares (3 acres) of mixed hardwood forest habitat, and 0.80 hectare (2.0 acres) of thicket habitat, of which 0.32 hectare (0.8 acre) is wetland. Construction at Alternate Site 1 would result in the loss of approximately 1.61 hectares (4 acres) of grassland habitat, 1.61 hectares (4 acres) of mixed hardwood habitat, and 0.8 hectare (2 acres) of thicket habitat. Construction at Alternate Site 2 would result in the loss of approximately 4 hectares (10 acres) of grassland habitat. Construction at Alternate Site 3 would result in the loss of approximately 3.24 hectares (8 acres) of mixed hardwood habitat, 0.4 hectare (1 acre) of thicket habitat, and 0.4 hectare (1 acre) of grassland habitat.

For any of the potential sites, there would be a corresponding displacement of wildlife to similar nearby habitat. If similar habitat is unavailable, wildlife populations may slightly decline. There is also a threat of direct mortality of transient wildlife during operation of heavy construction equipment and vehicles. Storage of cylinders in the new and refurbished yards would not adversely affect vegetation and wildlife, except if an accidental release of UF6 occurs and affects water resources and the food chain.

Threatened and Endangered Species

In compliance with Endangered Species Act regulations, DOE consulted with the U.S. Fish and Wildlife Service (FWS) for current information on federally listed or proposed threatened and endangered species, including their habitat and any critical habitat potentially lost as a result of this project. The FWS advised DOE that its records show no T&E species and protected habitat within the impact area of the project, including alternate sites for the new cylinder yard.

Soils and Prime Farmland

The DOE consulted with the Natural Resources Conservation Service and was advised that prime farmland soils would not be affected by the proposed action.

Cultural Resources

In compliance with Section 106 of the National Historic Preservation Act, DOE consulted with the Kentucky State Historic Preservation Officer, who advised DOE that the proposed action would have no adverse impacts on historic resources listed or eligible for listing on the National Register of Historic Places and that no archaeological surveys are necessary for the preferred site of the new yard and the three alternate sites.

Air Quality

Excavation and grading would disturb soils, and fugitive particulates would be released to the atmosphere. In addition to particulates, vehicle and equipment operations would exhaust carbon monoxide, sulfur dioxide, nitrogen oxides, and unburned hydrocarbons. Onsite ambient concentrations of these pollutants would temporarily increase in the immediate vicinity of construction and vehicle operation. Dust suppressants would be applied to roads and construction areas to minimize fugitive particulate emissions. Offsite ambient concentrations of pollutants regulated under the Clean Air Act would not be expected to increase because of dilution and dispersion of pollutants with increasing distance from the source. Routine storage of re-stacked cylinders would not affect air quality. Atmospheric releases of cylinder contents as a result of an accident could affect occupational health and safety (see Health and Safety section below).

Air quality impacts would be the same if the proposed new yard were constructed at any of the alternate sites.

Noise

During construction, operation of vehicles, heavy machinery, and equipment would cause short-term increases in ambient noise levels. Maintenance of the cylinder yard would sporadically increase ambient noise levels as heavy equipment is used to move cylinders. Increased ambient noise levels from activities at the preferred and alternate sites would not adversely affect the nearest human receptor in Magruder Village, which is 2.4 km (1.5 miles) away.

Socioeconomics

Construction and cylinder yard maintenance personnel would likely be drawn from the PGDP labor pool; therefore, impacts to local employment and economy would be negligible. No minority or economically disadvantaged populations in the PGDP area would be disproportionately affected by the short-term, minor impacts of the proposed action.

Onsite traffic would increase slightly as cylinders are moved among storage yards during construction. Offsite transportation would not be affected.

Land Use

Use of four hectares (10 acres) of land south of the PGDP security fence for the C-745-T Yard and at any of the alternate sites would be compatible with the adjacent industrial use of PGDP.

Transportation

Onsite truck traffic would increase temporarily because of cylinder movement during refurbishment and construction. A modest increase in offsite traffic would result from vehicles transporting construction materials to PGDP.

Waste Management

Wastes generated from earthwork, refurbishment, and construction are expected to be free of radioactive contamination; to ensure proper disposal, wastes will be surveyed prior to handling and transport. All wastes would be sored or sent to disposal at PGDP, with no offsite disposal anticipated.

Health and Safety

Sources of health and safety impacts include (1) construction activities, such as the operation of heavy equipment; (2) radioactive emissions from uranium in the cylinders during handling, transport, and storage, and (3) chemical toxicity from uranium and fluoride, if released during an abnormal event. There would be zero risk of accidents affecting public health and safety during construction because of the distance to the nearest public receptor. Occupational health and safety risk for personnel involved in refurbishment and construction would be similar to the risk associated with general construction projects. No unique hazards were identified for the proposed action.

Current storage of uranium hexafluoride at PGDP presents generally little or no risk to occupational health and safety and no risk to the public during normal activities in the cylinder yards. Occupational radiation exposures are monitored to achieve as-low-as-reasonably-achievable (ALARA) levels. Chemical exposures are extremely rare because uranium hexafluoride is adequately contained in the cylinders. There would be no public health and safety risk during cylinder storage. During an abnormal event, public risk may range from negligible to potentially significant.

More frequent cylinder movement during refurbishment and construction (as opposed to little movement during storage) would slightly increase health and safety risks for PGDP personnel. Occupational risk of physical injury, vehicle accidents, and release from a cylinder rupture would be greatest for movement of cylinders to Alternate Site 3, which is furthest from the existing storage yards. A process hazards analysis of incidents that could occur in PGDP uranium hexafluoride storage yards reported impacts that could result from equipment failure, human error, vehicle accidents, fire, and natural phenomena. Results indicated that a release of solid UF6 would not expose cylinder yard workers, other PGDP workers, and the nearest public receptor to an unacceptable level of hydrogen fluoride and radioactivity. On the other hand, low-probability, but high-consequence events, such as a large fire or cylinder breach, have the potential to cause serious occupational injuries and fatalities.

Cumulative Impacts

Cumulative impacts are those that result from the incremental impacts of an action combined with impacts from past, present, and planned actions. The impacts of the proposed action were considered along with the impacts from the operation of the Northwest Plume Pump and Treat Facility, expansion of UF6 cylinder storage yards C-745-G and -S, and operation and maintenance associated with day-to-day PGDP activities.

Increased runoff from pavement added to the G and S yards would be additive with the increased runoff resulting from the proposed action, and additional runoff from Alternate Site 3 would be additive with flow from the Northwest Plume facility. Detention basins would be used to regulate runoff flow to various permitted outfalls.

Fugitive particulates from construction of all cylinder yard projects would be minimized by the use of dust suppressants. Offsite ambient concentrations of regulated pollutants would not be affected because of dilution and dispersion as distance from the source increases.

Concurrent increased ambient noise levels onsite could result from vehicle and machinery operation during various construction activities. Offsite ambient sound levels would not be affected because of attenuation with distance.

The proposed action, operation of the Northwest Plume Facility, and other cylinder yard refurbishment would be undertaken in previously disturbed areas at PGDP. Thus, they would not cumulatively impact vegetation and wildlife and cultural resources. The proposed action would have no floodplain impacts; therefore, it would contribute an incremental impact to floodplains impacts associated with the other projects. While the preferred location of the proposed action contains wetland areas, the U.S. Army Corps of Engineers Nationwide Permit 26 allows the proposed activities to be undertaken. The proposed action would contribute a small incremental loss of wetlands to total wetlands lost at PDGP because of other projects.

NO ACTION

If no action is taken, there would be a continuation of the occupational health and safety risks associated with a release of hydrogen fluoride and uranium compounds as a result of suboptimal storage of corroding cylinders. There would be no impacts to floodplains, wetlands, cultural resources, air quality, water resources, socioeconomics, environmental justice, ecology, vegetation and wildlife, threatened and endangered species, geology and soils if no action is taken.

DETERMINATION: Based on the findings of the EA, DOE has determined that the proposed refurbishment of cylinder yards C-745-K, L, M, N, and P; construction of a new cylinder storage yard (C-745-T); and re-stacking of cylinders at the PGDP do not comprise a major federal action that would significantly affect the quality of the human environment within the context of the NEPA of 1969. Therefore, preparation of an EIS will not be necessary.

Issued at Oak Ridge, Tennessee, this 25 day of July 1996.

James C. Hall
Manager
U.S. Department of Energy
Oak Ridge Operations Office
Oak Ridge, Tennessee

PREFACE

This Environmental Assessment Refurbishment of Uranium Hexafluoride Cylinder Storage Yards C-745-K, L, M, N, and P and Construction of a New Uranium Hexafluoride Cylinder Storage Yard (C-745-T) at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky (DOE/EA/1118) was prepared in accordance with the requirements of the National Environmental Policy Act. Publication of this document meets a primary document deliverable milestone for the Paducah Gaseous Diffusion Plant Environmental Management and Enrichment Facilities Program. This document provides the United States Department of Energy with documentation of completion of National Environmental Policy Act requirements for the described action.

EXECUTIVE SUMMARY

The Paducah Gaseous Diffusion Plant (PGDP), located in western Kentucky, is a uranium enrichment facility owned by the United States Department of Energy (DOE) and operated by the United States Enrichment Corporation. A residual of the uranium enrichment process is depleted uranium hexafluoride (UF6). Depleted UF6, a solid at ambient temperatures, is stored in large steel cylinders weighing up to 14 tons each. The DOE is responsible for approximately 32,200 cylinders of UF6 stored at the PGDP. Storage conditions are suboptimal and have resulted in accelerated corrosion of cylinders, increasing the potential for a release of hazardous substances. Consequently, the DOE has proposed refurbishment of certain existing yards and construction of a new storage yard.

This environmental assessment (EA) evaluates the impacts of the proposed action and no action and considers alternate sites for the proposed new storage yard. The no action alternative provides a baseline against which impacts of the proposed action can be compared. For the purpose of this assessment, no action means that UF6 cylinders would continue to be stored where they are presently located. The proposed action includes (1) renovating the existing C-745-K, L, M, N, and P cylinder yards; (2) constructing a new UF6 storage yard (C-745-T); (3) handling and onsite transport of cylinders among existing yards to accommodate construction; and (4) after refurbishment and construction, re-stacking of cylinders to meet spacing and inspection requirements. The new and renovated cylinder storage yards would be constructed with slab-on-grade concrete and would be equipped with adequate storm water drainage systems and lighting. The existing security fence and lighting system would be removed and a new lighting system, along with an extension of the patrol road and fence, would be constructed to encompass the new yard.

The findings of this EA are as follows:

PROPOSED ACTION Geology

Construction and refurbishment would be limited to surface grading and excavation to less than 1 m (3 ft) depths. This would not dramatically alter site topography and would not affect other geologic characteristics and features at the proposed site of the new yard or at any of the alternate sites.

Water Resources

The addition of concrete pavement in the new and refurbished cylinder storage yards would result in a small but permanent increase in surface runoff to onsite drainage ditches and ultimately, to Kentucky Pollutant Discharge Elimination System (KPDES)-permitted outfalls to PGDP surface waters. Also, during construction, erosion of exposed soils may increase siltation to the same ditches and KPDES-permitted outfalls. Best management practices for erosion and sedimentation control will be implemented by the construction contractor to minimize sediment runoff and subsequent increases in stream turbidity, which in turn may affect aquatic biota. Movement of cylinders among yards and storage of cylinders in the refurbished and new yards would not impact surface water and ground water. There is a very low probability of an accidental cylinder breach; however, occupational injuries from the release of hydrogen fluoride and uranium compounds could occur from an accident (see Health and Safety section below).

Floodplain

Wetlands

At the site of the proposed new cylinder yard, six isolated wetlands covering about 0.32 hectare (0.8 acre) would be affected. The DOE was advised by the U.S. Army Corps of Engineers that filling these wetlands is allowable under Nationwide Permit 26, Headwaters and Isolated Waters Discharge. Pursuant to the requirements of Executive Order 11990 and DOE regulation 10 CFR 1022, a Notice of Wetlands Involvement was published in the Federal Register on May 3, 1996 and a wetlands assessment was conducted for the proposed action. DOE concluded that the loss of less than one acre of wetlands at the project site would not be a significant adverse impact.

Disturbance of wetlands could be avoided at Alternate Site 2, and Alternate Site 3 has no wetlands present. Alternate Site 1 has 1.82 hectares (4.5 acres) of wetlands that would be impacted.

Biota

Threatened and Endangered Species

Soils and Prime Farmland

The DOE consulted with the Natural Resources Conservation Service and was advised that prime farmland soils would not be affected by the proposed action.

Cultural Resources

Air Quality

Air quality impacts would be the same if the proposed new yard were constructed at any of the alternate sites.

Noise

Socioeconomics

Onsite traffic would increase slightly as cylinders are moved among storage yards during construction. Offsite transportation would not be affected.

Land Use

Use of four hectares (10 acres) of land south of the PGDP security fence for the C-745-T Yard and at any of the alternate sites would be compatible with the adjacent industrial use of PGDP.

Transportation

Waste Management

Wastes generated from earthwork, refurbishment, and construction are expected to be free of radioactive contamination; to ensure proper disposal, wastes will be surveyed prior to handling and transport. All wastes would be stored appropriately or sent to disposal at PGDP, with no offsite disposal anticipated.

Health and Safety

Cumulative Impacts

NO ACTION

1.0 INTRODUCTION

1.1 BACKGROUND

The Paducah Gaseous Diffusion Plant (PGDP), located in western Kentucky (Figure 1-1), is a uranium enrichment facility owned by the United States Department of Energy (DOE). Effective July 1, 1993, the DOE leased the plant production operations facilities to the United States Enrichment Corporation (USEC) which, in turn, contracted with Lockheed Martin Utility Services, Inc. (LMUS) to provide operation and maintenance services. Lockheed Martin Energy Systems, Inc. (LMES) operates the Environmental Management and Enrichment Facilities Program activities and legacy items for the DOE.

Uranium is a naturally occurring radioactive element containing different isotopes, notably uranium-238 and uranium-235 (235U). The use of uranium as an energy source requires increasing the proportion of 235U through the enrichment process. One method for enriching uranium is gaseous diffusion. Gaseous diffusion divides a single stream of gaseous uranium hexafluoride (UF6), a mixture of uranium and fluorine, into two separate streams: one enriched in 235U (enriched uranium), and the other depleted in 235U (depleted UF6). A consequence of the enrichment process is the accumulation of depleted UF6, which is a solid at ambient temperatures. Depleted UF6 is stored in steel cylinders weighing up to 14 tons each. The continued storage of these cylinders at the PGDP is the focus of this document.

1.2 PURPOSE AND NEED

Until a decision is made on the long-term management of depleted UF6, the DOE is responsible for storing approximately 32,200 UF6 cylinders at the PGDP. Current storage conditions for 18,804 cylinders of depleted UF6, at cylinder yards C-745-A, B, C, K, L, M, N, and P are suboptimal and have contributed to accelerated corrosion of the cylinders, increasing the potential for a release of hazardous substances [hydrogen fluoride (HF) and uranium compounds]. The cylinders are stored on poorly drained, large gravel pads. Many of the cylinders are in direct contact with this surface and are too close together to allow a full visual inspection. The purpose of the proposed action is to improve short-term storage conditions for UF6 cylinders. To accomplish this, storage yards must be upgraded and cylinders must be re-spaced. However, there is not sufficient space available in other existing yards to accommodate all cylinders. Consequently, a new storage facility for relocating the cylinders is needed.

1.3 RELATIONSHIP TO OTHER UNITED STATES DEPARTMENT OF ENERGY ACTIONS

The DOE and the Defense Nuclear Facilities Safety Board recently agreed upon a strategy to improve safety at UF6 cylinder storage sites [60 Fed. Reg. 25893 (May 15, 1995) and 60 Fed. Reg. 36789 (July 18, 1995)] in accordance with the Atomic Energy Act of 1954 [42 U.S.C. § 2286(a)(5) (1991)]. Under this strategy, the DOE will focus on:

Figure 1-1. Paducah Gaseous Diffusion Plant Vicinity Map

Repainting cylinders as needed to prevent excessive corrosion;
Relocating cylinders from contact with the ground and keeping all cylinders from further ground contact;
Relocating all cylinders into adequate inspection configuration and maintaining them as such; and
Updating handling and inspection procedures and site-specific safety analysis reports.

In conjunction with the aforementioned, the DOE is conducting engineering and cost analyses and preparing a programmatic environmental impact statement (PEIS) to evaluate alternative strategies for the long-term management of depleted UF6 at various DOE facilities, including the PGDP. A Notice of Intent to prepare the PEIS was published in the Federal Register, Vol. 61, No. 17, p. 2239, January 25, 1996. Alternatives assessed in the PEIS will include long-term storage of depleted uranium as UF6, conversion to an oxide [uranium oxide (UO2) or uraninite (U3O8)] followed by extended storage or disposal, and conversion to UO2 or uranium metal followed by use of this material. Until the PEIS is completed and a long-term strategy is determined, the DOE will provide continued storage of the cylinders in a safe, suitable, and practical manner.

2.0 PROPOSED ACTION AND ALTERNATIVES

2.1 NO ACTION

The no action alternative is considered in accordance with NEPA regulations and provides an environmental baseline against which impacts from the proposed action can be compared. For the purposes of this assessment, no action means that UF6 cylinders would continue to be stored in the existing yards (C-745-A, B, C, K, L, M, N, and P) under current conditions. The cylinders are stored directly on poorly drained, large gravel pads and are too close together to allow a full visual inspection. Continuation of these practices could allow cylinders to further corrode, maintain contact with the ground in places, and prevent adequate visual inspections. Consequently, no action would not remediate health and safety risks associated with cylinder breaches via corrosion. Also, under the no action alternative, cylinders would be occasionally moved. With no action, existing environmental conditions, described in Chapter 3, would be maintained. Consequently, impacts associated with the proposed action, described in Chapter 4, can be compared to baseline conditions described in Chapter 3.

2.2 PROPOSED ACTION

The proposed action includes refurbishment of existing storage yards C-745-K, L, M, N, and P; construction of a new UF6 cylinder storage yard (C-745-T); and

re-stacking the cylinders in the existing and new yard to meet spacing and inspection requirements.

2.2.1 Project Location

Storage yards C-745-K, L, M, N, and P are contiguous and located within the secured area of the PGDP at the southern end of the plant (Figure 2-1). A new cylinder yard, the C-745-T Yard, would provide a storage area of 4 hectares (10 acres). The proposed C-745-T Yard would be located south of the existing yards (Figure 2-1). Existing yards C-745-A, B, and C would no longer be used for UF6 cylinder storage.

The proposed C-745-T Yard would permanently accommodate the cylinders from the C-745-A, B, and C yards and temporarily accommodate cylinders from the C-745-K, L, M, N, and P yards. The C-745-A, B, and C yards currently contain 5,129 DOE cylinders and the C-745-K, L, M, N, and P yards contain 13,675 cylinders. Therefore, a total of 18,804 cylinders would require movement.

Alternate sites for the proposed C-745-T Yard were chosen using the following criteria:

No structures may be placed on property leased to the USEC, or on easements (e.g., power line right-of-way);

Figure 2-1. Locations of Current, Proposed, and Alternate Sites for Storage of Uranium Hexafluoride Cylinders at the Paducah Gaseous Diffusion Plant

Avoid or minimize demolition or relocation of current or planned structures and facilities;
Per security requirements, no structures may be placed within 6 m (20 ft) of the PGDP security fence;
Per the Conceptual Design Report For The Paducah Gaseous Diffusion Plant UF6 Cylinder Storage Yards, Phase IX (MMES, 1995a), a minimum of 4 hectares (10 acres) is required to accommodate cylinders to be relocated as a result of spacing/re-stacking requirements;
The new cylinder storage yard must be reasonably close to existing or planned cylinder yards to minimize risks, costs, and time associated with cylinder relocation (i.e., UF6 cylinders should be collocated to the maximum extent practicable); and
All activities must avoid or minimize impacts to environmentally sensitive resources.

These criteria, in conjunction with the DOE-USEC lease agreement, the latest draft DOE Site Development Plan, available information on environmental site conditions, and appropriate DOE-NEPA guidance, resulted in the selection of four possible sites for the proposed 4 hectares (10 acres) C-745-T Yard (Figure 2-1):

(1) The proposed C-745-T Yard;

(2) An area overlapping and to the west of the proposed C-745-T Yard (Alternate Site 1);

(3) An open, undeveloped area immediately west of existing DOE C-745-K, L, M, N, and P cylinder yards and bounded to the west by the plant access road (Alternate Site 2); and

(4) An area just outside the northwest corner of the plant bounded to the south by Outfall 001, to the west by Transport Road, and to the north by Patrol Road #2 extension (Alternate Site 3).

2.2.2 Construction

During construction, cylinders would be moved to adjacent cylinder yards having available space. The proposed C-745-T Yard would be constructed first. After completion of the proposed C-745-T Yard, cylinders from C-745-A, B, C, and K would be relocated to the proposed C-745-T Yard. Refurbishment of C-745-K Yard would occur next and, once complete, cylinders from C-745-L would be relocated onto the

C-745-K and T yards. Refurbishment of C-745-L, M, N, and P yards would follow, in that order, and cylinders would be moved onto each completed yard as each yard is completed. At this time, all cylinders would be properly located and stacked to allow adequate inspection.

The proposed C-745-T Yard and the refurbished storage yards would be constructed with slab-on grade concrete, appropriate storm water drainage systems, and lighting. The existing security fence and lighting system would be removed and replaced by a new lighting system and an extension of the patrol road and fence.

Vegetation would be cleared prior to contouring and preparation of the subgrade surface. The concrete pad for each of the cylinder storage areas would be of

35 cm (14-inches) thick, unreinforced concrete in 7.5 to 15 m (25 to 50 ft) widths with slight grading to allow for drainage. A storm water drainage system would be constructed of reinforced concrete pipe and precast catch basins around the perimeter of each pad (MMES, 1995a).

The new lighting system would include additional transformers, lighting contactors, and new lighting poles with multiple 400-watt lighting fixtures. Power would be transmitted to the new area through underground power ducts as well as new overhead power lines along the perimeter of the yard. The security fence and patrol road would extend around the perimeter of the new cylinder yard. The patrol road extension would be constructed from dense-grade aggregate (DGA) and asphalt and would allow security monitoring along the entire perimeter of the new cylinder yard.

2.2.3 Cylinder Movement

Trailers equipped with saddles would be used for intraplant cylinder movements. Forklifts would be used to move 2.5-ton cylinders and cylinder stackers would be used to stack and move 2.5-, 10-, and 14-ton cylinders in storage yards within the plant. Standard safety procedures (USEC, 1995) would be followed to ensure that a release of UF6 does not occur. The routes utilized for cylinder movement during the proposed action would be confined to the secured area of the PGDP.

2.2.4 Waste Management

Construction of the proposed C-745-T Yard would require clearing trees and shrubs located south of the southern end of the plant. Site characterization has been completed and results indicated that soil is uncontaminated and could be used as fill over the construction site.

Renovation of the existing C-745-K, L, M, N, and P yards would require removal and disposal of existing wood and metal utility poles, electrical lines, metal fencing, light fixtures and various other materials. An estimated 25 wooden poles, 25 steel poles, and 65 light fixtures/ballasts would require storage or disposal as a result of the cylinder yard refurbishment and expansion. The DGA and subgrade would be removed in order to construct the 35-cm (14-inch) forms. Removal of existing storm drains may also be required before construction.

Wastes would be classified, handled, and stored as appropriate following these PGDP management practices (LMES, 1995; White, 1995):

Concrete, asphalt, and uncontaminated soil would be stored in an existing stockpile area or disposed in the existing on-site landfill;
Steel poles and scrap metal would be stored in the uncontaminated scrap metal storage yard or in the contaminated scrap yard, depending on characterization;
Wooden poles would be stored in the C-747-B Scrap Yard;
Electrical cables would be containerized in strong, tight containers, sampled for PCB, and, if determined uncontaminated, can be disposed in the uncontaminated metal scrap yard;
Lamps and ballasts would be containerized in open-head drums, sampled for PCBs, and stored at C-747-B; and
Any other contaminated material associated with this project would be managed in accordance with PGDP waste management policy and procedures.

2.3 OTHER ALTERNATIVES

Due to stacking requirements, UF6 safe-handling procedures, and a lack of additional space inside the PGDP, no other on-site storage alternatives are feasible (USEC, 1995). Additionally, there are no reasonably foreseeable alternatives to continued on-site storage of depleted UF6 in cylinders. Other management alternatives, such as off-site storage, will be evaluated in an PEIS of the DOE for the long-term management of depleted UF6 resources at several geographical locations as discussed in Section 1.3. Consequently, these management alternatives are not addressed in this environmental assessment (EA). The DOE has not irretrievably or irreversibly committed any resources that would bias the selection of either alternatives or sites for the new cylinder storage yard discussed in this document.

3.0 AFFECTED ENVIRONMENT

At the PGDP, the DOE owns approximately 300 hectares (740 acres) within a security fence that is surrounded by approximately 1,090 hectares (2,695 acres) of which 850 hectares (2,100 acres) are leased to the Commonwealth of Kentucky as part of the West Kentucky Wildlife Management Area (WKWMA) (Figure 3-1). This section describes the various resources present on portions of this land that may be affected by the proposed action. Unless otherwise specified, no impacts to any resources would occur from activities associated with the C-745-A, B, C, K, L, M, N, and P cylinder yards.

3.1 GEOLOGY

Background geologic information on the PGDP area can be found in the Report of the Paducah Gaseous Diffusion Plant Groundwater Investigation Phase III (MMES, 1992) and the draft Northeast Plume Preliminary Characterization Summary Report (DOE, 1995a).

The stratigraphic sequence in the PGDP region consists of Cretaceous, Tertiary, and Quaternary sediments unconformably overlying Paleozoic bedrock.

No mineral deposits have been identified at the PGDP, and the only economic geological resource in the vicinity is the Terrace Gravels, which are mined primarily for use as aggregate in road construction. Currently, gravel pits are located about 2.4 km

(1.5 miles) to the south and west from the plant site.

3.2 WATER RESOURCES

The sources for the following discussion of regional surface water (Section 3.2.1) and ground water hydrology (Section 3.2.2) include the Results of the Site Investigation, Phase II Paducah Gaseous Diffusion Plant, Paducah, Kentucky (CH2M HILL, 1992), the Report of the Paducah Gaseous Diffusion Plant Groundwater Investigation Phase III (MMES, 1992) and the draft Northeast Plume Preliminary Characterization Summary Report (DOE, 1995a) at the PGDP.

3.2.1 Surface Water

Surface water originating from the plant drains into Ohio River tributaries (Figure 3-2). Because of a local drainage divide, the PGDP surface water flow is either to the east and northeast toward Little Bayou Creek, or to the west and northwest toward Bayou Creek. Both Bayou Creek and Little Bayou Creek are perennial streams that discharge into the Ohio River and are designated for all uses by the Commonwealth of Kentucky.

At the PGDP, man-made drainage ditches receive storm water and effluent from the plant which is routed through 18 Kentucky Pollutant Discharge Elimination System (KPDES)-permitted outfalls (Figure 3-2) and eventually discharged into Bayou and Little Bayou creeks. Most of the flow in these creeks can be attributed to effluent water from the plant (MMES, 1994). The 18 outfalls have a combined average daily flow of 18.5 million liters per day (4.88 million gallons per day). All outfalls mentioned in this document are monitored for radionuclides including uranium, various other chemicals and contaminants, and have maximum flow volumes (KPDES Permit No. KY0004049). Cylinder yards C-745-K, L, M, N, and P discharge storm water runoff into outfalls 012 and 013. Flow through these outfalls empties into Little Bayou Creek. Cylinder yards C-745-A, B, and C discharge storm water runoff into outfalls 004, 008, and 015. Flow through these outfalls empties into Bayou Creek. Storm water runoff from the proposed C-745-T Yard site flows mostly to the north and then to the east (Figure 3-3). It then flows through Outfall 013 and on to Little Bayou Creek. On the west side of the site, flow is to the north and west and drains into a northward flowing ditch next to the plant entrance road (Figure 3-3). Eventually, the water flows to the west through Outfall 017 and into Bayou Creek.

Figure 3-1. Current Land Ownership at the Paducah Gaseous Diffusion Plant

Figure 3-2. Surface Water Features and Permitted Effluent Outfalls in the Vicinity of the Paducah Gaseous Diffusion Plant

Storm water runoff from Alternate Site 1 drains mostly to the north and the west. This water then drains to a northward flowing ditch next to the plant entrance road. Eventually, the water flows to the west through Outfall 017 and into Bayou Creek.

Alternate Site 2 storm water runoff flows into ditches at the east and west sides of the site or into the westward trending ditches that cross the site. The surface water in these ditches eventually flows through Outfall 017 and into Bayou Creek.

Alternate Site 3 runoff ultimately discharges into the ditch that borders the site on the east. This ditch carries surface water to the Outfall 001 ditch. The Outfall 001 ditch borders the south side of the site and carries surface flow west through Outfall 001 and into Bayou Creek.

3.2.2 Ground Water

Two units present in the vicinity of the PGDP are the Upper Continental Recharge System (UCRS) and the Regional Gravel Aquifer (RGA). The UCRS is a hydrogeologic unit contained within the loess layer and the Upper Continental Deposits. The ultimate flow direction in the UCRS is downward. The RGA is a hydrogeologic unit that is primarily contained within the Lower Continental Deposits. The RGA also encompasses sands at the base of the Upper Continental Deposits directly overlying the Lower Continental gravels. In addition, the RGA has been found to include sands in the upper part of the McNairy Formation directly below the gravel.

The RGA typically has a relatively high hydraulic conductivity and so serves as the dominant ground water flow system in the area. The predominant flow direction in the RGA is northward toward the Ohio River. The RGA ranges in thickness from 3 to 12.1 m (10 to 40 ft) and pinches out at the base of the Porters Creek Clay Terrace. The RGA has been identified as the uppermost aquifer at the PGDP and is the major water supply aquifer for the region. The ground water level in the area of the proposed C-745-T Figure 3-3. Surface Water Flow at the Proposed Location of C-745-T Uranium Hexafluoride Cylinder Yard at the Paducah Gaseous Diffusion PlantYard, and Alternate Sites 1 and 2, is at approximately 4.6 m (10 ft) below land surface (bls).

Figure 3-3 Surface Water Flow at the Porposed Locations of C-745-T
Uranium Hexaflouride Cylinder Yard at the Paducah Gaseous Diffusion Plant

The existing C-745-K, L, M, N, and P cylinder yards, the proposed C-745-T Yard, and Alternate Sites 1 and 2 are located south of the terrace face where the RGA is not present. The Terrace Gravels would be the only water-bearing zone above the Porters Creek Clay at these sites. Both the UCRS and the RGA are present beneath Alternate Site 3.

3.2.3 Floodplains

Flooding at the PGDP is associated with the Ohio River, Bayou Creek, and Little Bayou Creek. The majority of overland flooding on the DOE reservation is associated with Bayou and Little Bayou creeks.

Floodplains at the PGDP were identified by the United States Army Corps of Engineers (COE) (COE, 1994). The Hydrologic Engineering Center Computer Program model was

used to estimate 100- and 500-year flood elevations. Alternate Site 2 is bisected by a 100-year floodplain contained within a drainage running east and west (COE, 1994). No other floodplains were identified at any of the other sites.

3.2.4 Wetlands

No wetlands are present at the C-745-K, L, M, N, and P yards. Six small, isolated wetlands are present at the proposed C-745-T Yard, totaling 0.32 hectare (0.80 acre) [MMES, 1995c (Appendix A); CDM, 1994] (Figure 3-4). These wetlands are classified as palustrine emergent, palustrine scrub/shrub, and palustrine forested, according to the United States Fish and Wildlife Service (USFWS) wetland classification system (USFWS, 1979). Palustrine wetlands in the vicinity of the PGDP are those less than

8 hectares (20 acres) in surface area with a water depth less than 2 m (6.6 ft) during low water. Emergent vegetation is erect, rooted, non-woody; scrub/shrub vegetation is woody not exceeding 6 m (20 ft) in height, and forested vegetation is woody, exceeding 6 m (20 ft) in height. A description of wetlands at the proposed site is provided in Appendix A.

Alternate Site 1 has approximately 1.82 hectares (4.5 acres) of wetlands and Alternate Site 2 has 0.36 hectares (0.9 acres) of wetlands present (MMES, 1995d; MMES, 1995e). No wetlands are present on Alternate Site 3 (COE, 1994).

3.3 BIOTA

Most of the area in the vicinity of the PGDP has been cleared of vegetation at some time, and much of the grassland habitat is currently mowed by PGDP personnel. A large percentage of the adjacent WKWMA is managed to promote native prairie vegetation using burning, mowing, and various other techniques. These areas have the greatest potential for restoration and establishment of a sizable prairie preserve in the Jackson Purchase area (KSNPC, 1991) and promote native prairie species such as big bluestem (Andropogon gerardii), little bluestem (Schizachyrium scoparium), Indian grass (Sorghastrum nutans), compass plant (Silphium laciniatum), and rattlesnake master (Eryngium yuccafolium), among others. Other common grasses associated with grassland areas include broom sedge (Agropyron virginicus), silver plume grass (Andropogon ternarius), panic grass (Panicum scoparium), and three awn grass (Aristida purpurescens). However, current mowing practices make positive identification of grass species very difficult in many areas.

Dominant overstory species of the mixed hardwood forest area include oaks (Quercus spp.), hickories (Carya spp.), maples (Acer spp.), elms (Ulmus americana and incana), sweetgum (Liquidambar styraciflua), and various others. Understory species include snowberry (Symphoricarpos orbiculatus), poison ivy (Toxicodendron radicans), and Solomon's seal (Smilacina recemosa), among others.

Thicket areas consist predominantly of maples, black locust (Robinia pseudoacacia), sumac (Rhus sp.), persimmon (Diospyros verginiana), and other mixed forest species in the sapling stage with herbaceous ground cover similar to that of the mixed hardwood forest understory.

Wetland vegetation consists of species such as sedges (Carex spp.), rushes (Juncus and Scirpus spp.), spikerushes (Eleocharis spp.), and various other grasses and forbs in the emergent portions; red maple (Acer rubrum), sweet gum (Liquidamber styraciflua), oaks, and hickories in the forested portions; and black willow (Salix nigra) and various other saplings of forested species in the thicket portions. A more detailed description of wetland species present in the proposed C-745-T Yard is given in Appendix A.

The proposed C-745-T Yard and Alternate Site 1 consist of grassland, mixed hardwood, thicket, and wetland habitats. Alternate Site 2 consists of mowed grassland and palustrine emergent wetland habitats. Alternate Site 3 consists of mixed hardwood, thicket, and grassland habitats.

Wildlife commonly found in the area are species indigenous to open grassland, thicket, mixed hardwood, and wetland habitats. Species present in the WKWMA are the same as those found in corresponding habitats in the project area. The following are species that have been documented to occur in the area and would likely be found in the habitats associated with the proposed project.

Small mammal surveys conducted on the WKWMA documented the presence of southern short-tail shrew (Blarina carolinensis), prairie vole (Microtus ochrogaster), house mouse (Mus musculus), rice rat (Oryzomys palustris), and deer mouse (Peromyscus spp.) (KSNPC, 1991). Large mammals commonly present in the area include coyote (Canis latrans), eastern cottontail (Sylvilagus floridanus), opossum (Didelphis marsupialis), groundhog (Marmota monax), whitetail deer (Odocoileus virginianus), raccoon (Procyon lotor), and gray squirrel (Sciurus carolinensis). Typical birds of the area include European starling (Sturnus vulgaris), cardinal (Cardinalis cardinalis), red-winged blackbird (Agelaius phoenicieus), mourning dove (Zenaida macroura), bobwhite quail (Coinus virginianus), turkey (Meleagris gallopavo), killdeer (Charadrius rociferus), American robin (Turdus migratorius), eastern meadowlark (Sturnella magna), eastern bluebird (Sialia sialis), bluejay (Cyanocitta cristata), red-tail hawk (Buteo jamaicensis), and great horned owl (Bubo virginianus).

Figure 3-4. Wetlands Associated with the Proposed Site for C-745-T Uranium Hexafluoride Cylinder Yard at the Paducah Gaseous Diffusion Plant

Amphibians and reptiles present include cricket frog (Acris crepitans), Fowler's toad (Bufo woodhousii fowleri), common snapping turtle (Chelydra serpentina), green treefrog (Hyla cinerea), chorus frog (Pseudacris triseriata), southern leopard frog (Rana utricularia utricularia), eastern fence lizard (Sceloporus undulatus), and red-eared slider (Trechemys scripta elegans) (KSNPC, 1991).

Mist netting activities in the area have captured red bat (Lasiurus borealis), little brown bat (Myotis licifugus), Indiana bat (Myotis sodalis), northern long-eared bat (Myotis septentrionalis), evening bat (Nycticeus humeralis), and eastern pipistrelle (Pipistrellus subflavus) (KSNPC, 1991).

3.4 THREATENED AND ENDANGERED SPECIES

To comply with the Endangered Species Act [16 U.S.C.A. 1531 et seq. (1991)], a threatened and endangered (T&E) species survey was conducted for the proposed action (MMES, 1995e). The results of that survey indicate that no federally listed T&E species, potential habitat, or critical habitat for T&E species is present on the proposed site for the proposed C-745-T Yard or the C-745-K, L, M, N, and P yards. Alternate Sites 1, 2, and 3 were surveyed during the 1994 COE environmental investigation of the PGDP area with the same results (COE, 1994). The USFWS indicated during informal consultation that they have no records of federally listed threatened or endangered species within the impact area of the project and that the requirements of Section 7 of the Endangered Species Act are fulfilled. (Appendix B). No T&E regulations for the Commonwealth of Kentucky are promulgated at this time. However, a species list is maintained by the Kentucky State Nature Preserves Commission for monitoring purposes. Species on this list, that have potential habitat in the project area, were included in the previously mentioned surveys. These surveys conclude that no known populations of species on this list would be impacted by the proposed action as no species were observed or are known to exist in the proposed sites.

3.5 SOILS AND PRIME FARMLAND

Six soil types are associated with the PGDP as mapped by the Natural Resources Conservation Service (NRCS), formerly the Soil Conservation Service (Humphrey, 1976). These soil types are Calloway silt loam, Grenada silt loam, Loring silt loam, Falaya-Collins silt loam, Vicksburg silt loam, and Henry silt loam.

Prime farmland, as defined by the NRCS, is land that is best suited for food, feed, forage, fiber, and oilseed productions, excluding "urban built-up land or water"

[7 C.F.R. §§ 657 and 658 (1994)]. The NRCS determines prime farmland based on soil types found to exhibit properties best suited for growing crops. These characteristics include suitable moisture and temperature regimes, logarithm of the reciprocal of the hydrogen-ion concentration (pH), drainage class, permeability, erodibility factor, and other properties needed to produce sustained high yields of crops in an economical manner. All potential project areas are located on Henry silt loams, which are not prime farmland soils. The NRCS has concurred with this determination (Appendix B).

3.6 CULTURAL RESOURCES

To comply with the National Historic Preservation Act [16 U.S.C.A. § 470 (1991)], a cultural resources assessment was completed for the proposed action. The results of this survey indicate that the proposed C-745-T Yard and Alternate Site 1 have been disturbed as a result of previous construction activities (MMES, 1995g). Alternate sites 2 and 3 also consist of areas considered to be previously disturbed (COE, 1994). Consequently, no cultural resources could be left intact in any of the proposed areas. The State Historic Preservation Officer (SHPO) has concurred with this determination (Appendix B).

3.7 AIR QUALITY

The PGDP is located in the Paducah-Cairo Interstate Air Quality Control Region of Kentucky. This region includes McCracken County and 16 other counties in western Kentucky. The state monitors the regionÕs ambient air quality for pollutants (ozone, nitrogen oxides, carbon monoxide, particulates, lead, and sulfur dioxide) and determines if the area meets the National Ambient Air Quality Standards. McCracken Countyís attainment status for total suspended solids, sulfur dioxide, carbon monoxide, ozone, and nitrogen oxides is classified as ìbetter than standardsî (401 K.A.R. 51:010). In addition to monitoring conducted by the state, the PGDP operates a monitoring system to assess the impact on ambient air quality from various air contaminants emitted by the PGDP. Twelve continuous samplers [four fence-line and eight off-site (MMES, 1994)] are used to monitor gaseous fluorides and radioactive particulates (gross alpha and gross beta). Six additional monitoring stations—one inside the plant, two on DOE property, and three offsite—are operated by LMUS and have been in operation since early summer. In 1992, the off-site ambient concentrations of radionuclides and fluorides at the PGDP were well below the standards set by the United States Environmental Protection Agency (40 C.F.R. § 61.90) and the Kentucky Division of Air Quality (401 K.A.R. 53:010).

3.8 NOISE

Noises associated with plant activities are generally restricted to areas inside buildings located onsite. Currently, noise levels beyond the security fence are limited to wildlife, hunting, traffic moving through the area, construction, and operation and maintenance activities associated with outside waste storage areas located close to the security fence. The nearest residential receptors are 2.4 km (1.5 miles) from the fence.

3.9 SOCIOECONOMICS

The PGDP is located in McCracken County of western Kentucky. The small communities of Grahamville, Heath, and Kevil are within a 4.9-km (3-mile) radius of the DOE property boundary. Larger municipalities such as Paducah and LaCenter, Kentucky, and Joppa and Metropolis, Illinois are within a 16.3- to 32-km (10- to 20-mile) radius of the site.

The population for McCracken County, as of July 1994, was reported at 64,630 persons with 26,853 persons residing in the city of Paducah. Two counties near to McCracken reported the following populations: (1) Ballard County, Kentucky 8,080; and (2) Massac County, Illinois, 15,189 (DOC, 1994a). The total population within an 80.46-km

(50-mile) radius of the plant was estimated at 500,000, with approximately 66,000 residing within a 16.3-km (10-mile) radius of the PGDP (DOC, 1994a).

McCracken CountyÕs labor force in June 1995 was recorded at 33,000 persons. Employment was recorded at 31,900 persons, with unemployment recorded as 1,100 persons (LeVasseur, 1995). Unemployment in McCracken County (3.4%), was less than the Commonwealth of Kentucky (5.0%) and the United States as a whole (5.8%) (LeVasseur, 1995). Construction accounted for 4% of employment, retail sales accounted for 27%, and manufacturing 14% (DOC, 1994b). The PGDP employs approximately 1,750 workers (PGDP, 1995) and the Shawnee Steam Plant employs 425 workers (TVA, 1995). The average 1993 per capita income in McCracken County was $19,647 as compared to 1994 averages of $17,807 per capita in Kentucky and $21,809 in the United States (DOC, 1995). The nearest minority and low-income populations are located within the city limits of Paducah (DOE, 1995b).

3.10 LAND USE

The industrial portion of the PGDP is situated within a fenced security area and makes up about 300 hectares (740 acres). Within this area, designated as industrial land use, are numerous buildings and offices, support facilities, equipment storage areas, and operational and non-operational waste management units. The DOE UF6 cylinder yards are within the secured plant site in the south and northwest areas of the plant. The south area of the plant contains the storage yards in which renovation is planned as well as three of the four identified sites for the proposed new cylinder yard. To the north and northeast of this area are several buildings, the closest being approximately 450 m (1,500 ft), which are currently occupied by approximately 300 workers.

Surrounding the plant are 1,090 hectares (2,695 acres) maintained by the DOE. While approximately 30 m (100 ft) of this area along the perimeter of the fence is mowed, the majority is generally covered with varying amounts of vegetation (including trees and shrubs) and open, grass-covered areas. The entire DOE reservation makes up approximately 1,390 hectares (3,435 acres) of which approximately 850 hectares

(2,100 acres) of land is leased by the DOE to the Commonwealth of Kentucky as part of the WKWMA. The DOE-retained portions are designated as industrial and the portion leased to the WKWMA is designated as recreational. The recreational portion is used periodically for outdoor recreation such as hunting. The nearest residential cluster, consisting of 18 homes, is located 2.4 km (1.5 miles) southwest of the PGDP. Figure 3-5 details the land use surrounding the PGDP.

Figure 3-5. Land Use at the Paducah Gaseous Diffusion Plant

4.0 POTENTIAL IMPACTS

No state or national parks, forests, conservation areas, wild and scenic rivers, or other areas of unique recreational, ecological, scenic, or aesthetic importance occur within the fenced security area or on DOE-owned land. Additionally, no Native Americans and/or minority and low-income populations would be affected by the proposed action. Consequently, additional requirements under NEPA, the Wild and Scenic Rivers Act

[16 U.S.C.A. § 1271 (1991)], the Native Americans Concerns Act [16 U.S.C.A. § 470 (1991)], and Executive Order 12898, Federal Actions to Address Environmental Justice in Minority and Low Income Populations, have been met; therefore, they are not addressed in the following text.

4.1 ALTERNATIVE 1 - NO ACTION

No impacts to the physical and biological environment would result from the no action alternative; current resources would be maintained as described in Chapter 3. However, continued corrosion of cylinders could lead to cylinder breaches, which may affect public and worker health and safety. Present storage conditions are conducive to cylinder degradation, which further increases the probability of a cylinder breach. In addition, cylinder movement in inadequate storage space could result in accidental breaches. During visual inspections, cracked or degraded cylinders and cylinder breaches of improperly stored cylinders may not be noticed. Consequently, the possibility for potential impacts to health and safety would increase with time, and risks from cylinder storage would be greater for the no action alternative than the proposed action. Health and safety impacts of no action are compared with those of the proposed action in Section 4.3.

4.2 ALTERNATIVE 2 - PROPOSED ACTION

Potential impacts were assessed, and results are discussed in the following sections. If no impacts to a specific resource were identified as the result of this action, those resources are not discussed further.

4.2.1 Geology

Construction associated with this project would be limited to surface grading and excavation to a depth of 1 m (3 ft). The C-745-K, L, M, N, and P cylinder yards, the proposed C-745-T Yard, and Alternate Sites 1 and 2 are in an area where the Terrace Gravels are present at a depth of 4.6 to 6.1 m (15 to 20 ft) bls and are 1.5 to 10.7 m

(5 to 35 ft) thick. Because of its depth, the Terrace Gravels would not likely be excavated for construction or other purposes. In addition, Terrace Gravels in these areas are at least partially saturated with ground water, depreciating its economic use as aggregate. Alternate Site 3 is located off the terrace where the Terrace Gravels are not present. Consequently, no effects to economic geologic resources are anticipated from this project.

Figure 4-1 Construction Staging Area and Site Access for the C-745-T
Uranium Hexafluoride Cylinder Yard at Paducah Gasseous Diffusion Plant

4.2.2 Water Resources

The following is a summary of potential impacts to surface water, ground water, floodplains, and wetlands.

4.2.2.1 Surface water

During construction, there is a potential for an increase in the amount of sediment carried in surface water runoff to Bayou Creek from the site. The use of physical barriers such as silt fences would minimize the amount of silt reaching the surface water and reduce direct effects on water quality. If precautions are taken, the surface water would be minimally impacted by construction. No long-term impacts are expected to result from constructing a cylinder yard at the proposed C-745-T Yard. Any runoff would be channeled off the cement pad through a storm sewer system. The only potential adverse effect could be erosion at the storm sewer pipe where it enters Ditch 017. The potential for erosion would be controlled by the use of riprap, or similar force dissipating methods, at this storm sewer exit point.

Impacts for Alternate Sites 1, 2, and 3 would be similar to the proposed action. Consequently, no long-term direct or indirect effects would occur as a result of this project. A short-term increase in sedimentation due to runoff would occur; however, the amount of sedimentation would be reduced by using siltation control devices decreasing the possibility for any effects to biota or water quality.

Precautions would be taken during construction to prevent contaminant spills (e.g., fuel, oil, etc.). The possibility of migration of contaminants to soil, surface water, and ground water would be reduced by limiting construction to dry periods. Additionally, any spills during construction would be immediately cleaned up using the PGDP spill prevention, control, countermeasures, and contingency plans for oils, chemicals, and hazardous waste (MMUS, 1994). Consequently, adverse impacts to surface water and ground water would not result.

4.2.2.2 Ground water

Excavation to a depth of 1 m (3 ft) would not reach the shallow ground water levels associated with the Terrace Gravels and UCRS. Therefore, no notable direct or indirect impacts to ground water would occur as a result of this project.

4.2.2.3 Floodplains

No 100- or 500-year floodplains are present on the proposed C-745-T Yard, Alternate Site 1, or Alternate Site 3. Portions of Alternate Site 2 are within a 100-year floodplain. However, construction design could avoid the floodplain entirely.

4.2.2.4 Wetlands

Pursuant to the requirements of Executive Order 11990 and DOE regulation 10 CFR 1022, a Notice of Wetlands Involvement was published in the Federal Register on May 3, 1996 and a wetlands assessment was conducted for the proposed action. DOE concluded that the loss of less than one acre of wetlands at the project site would not result in adverse impacts for the following reasons.

The maximum wetlands area that would be disturbed by the proposed action is 0.32 hectare (0.8 acre) (See Appendix A.). The Best Management Practices (BMPs) and guidelines listed below would be implemented to minimize impacts. Under Nationwide Permit (NWP) 26, Headwaters and Isolated Waters Discharges, DOE may fill < 0.4 hectare (1 acre) of wetland without notifying the COE, Louisville District (33 CFR ¤ 330). Nevertheless, DOE consulted with the COE about this project and was advised that NWP 26 would cover the proposed action (COE correspondence is provided in Appendix B).

For NWP 26, the total wetlands impacted are calculated by adding wetlands area to be filled and wetlands area that would be affected by flooding, excavation, or drainage. The 0.32 hectare (0.8 acre) wetlands area that would be affected by the proposed action includes a 33-m (100-ft) buffer around the proposed site, which makes this total a conservative estimate. Under NWP 26, the project may proceed without any COE involvement as long as the following guidelines are followed:

Ensure that impacts are kept below the one-acre limit, drainage from the yard would be directed away from adjacent wetlands;
Construction equipment would access the site from the south or northwest corner (Figure 4-1);
Siltation prevention devices (e.g., silt fences or hay bales) would be used to minimize siltation of adjacent wetlands;
Construction would occur during the dry portions of the year; and
Heavy equipment would be stored in specified areas and not stored in or driven through adjacent wetlands (Figure 4-1).

Construction design could avoid wetland impacts at Alternate Site 2 and Alternate Site 3 does not have any wetlands. Alternate Site 1 has approximately 1.82 hectares

(4.5 acres) of wetlands. If this site was to be used, additional regulatory requirements would be triggered. These requirements are detailed in Chapter 5.

4.2.3 Biota

No effects to vegetation would result from refurbishment of the existing yards, as vegetation is almost entirely absent. Any spots of invasive vegetation within the existing yards would be removed; however, very little habitat is created by these plants. Activities associated with the proposed C-745-T Yard would result in the permanent direct loss of approximately 2.02 hectares (5.0 acres) of grassland habitat, approximately 1.21 hectares (3 acres) of mixed hardwood forest habitat, and approximately 0.80 hectare (2.0 acres) of thicket habitat, of which approximately 0.32 hectare (0.8 acre) is wetland. No indirect effects to vegetation are associated with the proposed action or any alternate sites.

At Alternate Site 1, there would be a loss of approximately 1.61 hectares (4 acres) of grassland habitat, 1.61 hectares (4 acres) of mixed hardwood habitat, 0.8 hectare (2 acres) of thicket habitat, of which 1.61 hectares (4 acres) are wetlands.

At Alternate Site 2, there would be a loss of approximately 4 hectares (10 acres) of grassland habitat. At Alternate Site 3, there would be a loss of approximately 3.24 hectares (8 acres) of mixed hardwood forest habitat, 0.4 hectare (1 acre) of thicket habitat, and 0.4 hectare (1 acre) of grassland habitat.

No impacts to wildlife would result from refurbishment of C-745-K, L, M, N, and P yards; however, 4 hectares (10 acres) of mammal, bird, amphibian, and reptile habitat would be permanently lost as a result of the construction of C-745-T Yard. Direct mortality could be caused by heavy equipment during construction. However, noise and activity associated with construction activities would likely displace most wildlife from the area. Wildlife in the surrounding area would adapt to the increased activity, and long-term operation and maintenance of the cylinder yard would have minimal impacts, if any, on their behavior and migration habits.

4.2.4 Threatened and Endangered Species

The USFWS concurs that there would be no impacts to federally listed T&E species or critical habitat, from this project (Appendix B).

4.2.5 Soils and Prime Farmland

No impacts to prime farmland would occur as a result of this project. The NRCS concurs with this determination (Appendix B).

4.2.6 Cultural Resources

No areas of cultural or archaeological significance would be impacted as a result of this project. The SHPO concurs with this determination (Appendix B).

4.2.7 Air Quality

The proposed action would involve excavation, grading, and transportation of cylinders which would result in localized air quality degradation due to increased dust emissions and carbon monoxide and other pollutants discharged as exhaust from heavy equipment. Reasonable precaution would be taken to prevent particulate matter from becoming airborne in accordance with the fugitive emissions standards at 401 K.A.R. 63:010. Such reasonable precaution may include one of the following measures: use of water or chemicals for dust control during land clearing; application and maintenance of asphalt, oil, water, or suitable chemicals on roads and other surfaces which can create airborne dust; and covering, when at all times in motion, open-bodied trucks transporting materials likely to become airborne. Air quality would only be impacted temporarily during the construction phase of the proposed C-745-T Yard project when these activities are taking place. No adverse health effects would be expected because the soil is uncontaminated, and the limited duration of the construction phase would not result in chronic exposure to dust.

Another activity that could affect air quality is the burning of trees and other vegetation which is removed from the area where the proposed C-745-T Yard is to be constructed. The preferred disposal method for trees removed from the construction area would be to sell them to a local company. However, if this is not feasible, the trees would be burned in accordance with local and state regulations and permit requirements, including those codified at 401 K.A.R. 63:050. Specifically, no extraneous materials which tend to produce dense smoke, such as tires or heavy oil, would be used to cause ignition or aid combustion. Furthermore, burning would only occur on sunny days with mild winds.

Air quality degradation due to construction activities and tree burning would not result in any direct impacts to workers or members of the general public because the activities are temporary and limited in duration, and the construction areas are believed to be free of any radiological or chemical contamination. In addition, actions such as wetting the ground surface prior to excavation could be taken to minimize dust emissions. Also, particulate emissions would be monitored and any increases would be noticed and proper actions taken.

Impacts to air quality associated with Alternate Sites 1 and 3 would be the same as those discussed above for the proposed C-745-T Yard with the exception that Alternate Site 3 has a greater amount of trees than the other expansion sites. Therefore, the burning of trees from Alternate Site 3 would have a slightly greater impact on air quality. Alternate Site 2 does not have any trees present, so no burning would occur.

4.2.8 Noise

The PGDP and surrounding facilities do not measure noise levels since there are no local noise ordinances. The K.A.R 244 §§ 30 through 105 (1994) provide the Commonwealth of Kentucky noise regulations; however, the McCracken County attorney indicated that the PGDP has never violated noise ordinances in the past and the proposed construction near the site would not create a noise violation (Grimes, 1995).

Construction activities associated with the proposed action are anticipated to result in a short-term increase in noise levels. Short- and long-term increases in ambient noise levels would not affect the surrounding human community due to the distance to the nearest residential area [2.4 km (1.5 miles)]. Noise increases may temporarily disturb wildlife.

4.2.9 Socioeconomics

The local community would receive short-term benefits in the form of new employment opportunities and revenue generated from tree sales. Operation of the new and refurbished yards would not have any long-term impacts because these areas would be maintained and operated by PGDP personnel. Socioeconomic impacts associated with Alternate Sites 1, 2, and 3 would be similar to those of the proposed action. No minority or low-income populations would be disproportionately affected by the proposed action.

4.2.10 Land Use

There are no anticipated impacts to land use associated with refurbishment and transportation because all of the existing UF6 cylinder yards and transportation routes are within the industrial land use designated area of the PGDP.

The entire proposed C-745-T Yard is outside the security fence on the south side of the plant. While this site is within the buffer zone maintained by the DOE, it would be enclosed by the security fence. The use of the proposed C-745-T Yard would result in the loss of approximately 4 hectares (10 acres) of buffer zone which is considered industrial. Because the buffer area is considered industrial, no changes to land use would result from this project.

Impacts to current land use associated with Alternate Sites 1, 2, and 3 would be the same as those discussed for the proposed C-745-T Yard.

4.2.11 Transportation

During construction of the new C-745-T Yard, Dyke Road may be closed to reduce possible deer accidents associated with displacement. After construction, the roads would resume present traffic conditions.

Upon completion of the new C-745-T Yard, cylinders would be relocated to the new yard and rearranged during refurbishment of the existing yards. The proposed C-745-T Yard would be accessed from the north. Cylinders transported from the yards undergoing refurbishment to the sites immediately south and west of the existing cylinder yards would require less travel time. The greater time and distance required to transport and rearrange cylinders to Alternate Site 3 would increase risks associated with cylinder handling (Section 4.3).

In order to facilitate construction of the storage pads, cylinders would initially be moved from the present locations on gravel-covered corridors and paved roads. These additional cylinder moves should not result in any direct impacts to the environment. Once the cylinders are restacked, transportation would resume to present levels. Indirect impacts from transportation would be increased noise and emissions. These impacts are discussed in sections 4.2.7 and 4.2.8.

4.2.12 Waste Management

Items would be stored onsite until they can be properly disposed onsite in existing storage areas and would follow guidelines outlined in Chapter 5. Site characterization has demonstrated that waste generated from this project would not be contaminated and, therefore, would not impact any contaminated waste storage facilities.

4.3 HEALTH AND SAFETY IMPACTS

The following are potential health and safety impacts associated with no action and the proposed action.

4.3.1 Introduction

During UF6 cylinder storage, handling, and surveillance/maintenance, workers may be exposed to solid or gaseous UF6, inhale/ingest transferable contaminants from the surface of the cylinders, and encounter physical hazards. Following is a brief description of these hazards. The chance of a worker encountering these hazards would increase with the amount of time cylinders are handled. Consequently, risks would increase during the cylinder relocation process and resume to current levels once cylinders are relocated.

4.3.1.1 Exposure and inhalation /ingestion hazards

Uranium hexafluoride is a compound of hexavalent uranium and fluorine. In the gaseous form, it is used in a process at the PGDP to increase the concentration of the fissionable isotope 235U in natural uranium. Within the cylinder storage yards, UF6 is stored in the solid phase. Uranium hexafluoride and hydrogen fluoride are highly corrosive when exposed to air and water. Contact with water expedites the corrosivity furthering cylinder degradation. Solid UF6 reacts with water according to the following equation:

UF6 + 1602H20 Æ UO2F2 (aq, 4HF/1600H20) + heat
(solid) (liquid)		(liquid)

As seen in the reaction, compounds with differing toxic effects are produced, including:

Uranyl fluoride (UO2F2) where the uranium acts as a heavy metal poison that can affect the kidneys and results in an internal radioactive exposure;
Hydrogen fluoride which can cause acid burns on the skin and lungs; and
Fluoride ions which can cause metabolic poisoning in large enough quantities.

Consequences of exposure to UF6 and its products are outlined in Appendix C.

Exposure to ionizing radiation is administratively controlled by limiting the distance and time workers spend within the cylinder storage yard and by the Radiation Protection Program (MMES, 1995h). From 1992 through 1994, average exposures for UF6 cylinder handlers ranged between 50 to 80 millirem (mrem)/year, which are well below the DOE standards for radiation workers. In comparison, the maximum number of medical X-rays a person should be exposed to is two per year. This is equivalent to 103 mrem/year, and does not result in any measurable adverse effects (Shapiro, 1981). Potential for impacts associated with exposure to transferable contaminants and physical hazards are controlled through adherence to health and safety procedures.

4.3.1.2 Physical hazards

Physical hazards to workers during normal operations in the UF6 cylinder yards include falling objects, heavy machinery, noise, heat, and cold. Misuse of machinery while moving cylinders could cause severe injuries and death from blunt impact or crushing. Specific operational procedures are currently in place to minimize this hazard. Noise, heat, and cold are hazards that can be avoided by the use of personal protection equipment and adherence to safety procedures. When noise levels during operations are extremely high, the mandatory use of hearing protection minimizes hearing loss. Ambient temperature would be monitored and periodic breaks would be taken to reduce exposure hazards. Because the cylinder yards are not accessible by the general public, the opportunity for physical hazard occurrences to the general public are eliminated.

4.3.2 Impacts of Normal Operation in the C-745-T Yard

There would be little to no impact to occupational health and safety under normal operation since activities in cylinder yards are performed under strict health and safety polices and procedures (MMES, 1995h; USEC, 1995). Therefore, radiation exposures are monitored and kept as low as possible, while chemical exposures rarely occur. The only likely impacts to workers under normal operations are physical hazards. In addition, there would be no public health and safety impacts because the cylinder yards are not accessible to the public. Consequently, during normal operation of the C-745-T Yard after completion, occupational health and safety would not be impacted.

4.3.3 Accident Scenarios

The following are possible accidents associated with construction of the C-745-T Yard and cylinder movement associated with relocation of the cylinders.

4.3.3.1 Construction

The following are potential physical hazards that would be associated with construction of the proposed action. There would be no physical hazards associated with the no action alternative because no construction would take place.

The probability of construction-related injuries or fatalities is a function of hours worked. The refurbishment and construction work risks may be calculated by the following the equation:

Risk=person hours (PH) x risk coefficient (RC) where:

Risk=risk of injury or fatality;
PH=person hours of construction work; and
RC=injury or fatality risk coefficient (1 injury per 29,400 hours worked and
1 fatality per 2 million hours worked, respectively).

Risk coefficients used in this analysis are from the United States Department of Labor (1988). Using the above equation and the total PH estimated for the UF6 cylinder yard expansion at the proposed C-745-T Yard (42,880 based on the current schedule), the number of construction-related injuries that may be expected is 1.5, and the number of fatalities that may be expected is 0.02. These values indicate that on average, 1 construction-related injury may be expected and no construction-related fatalities may be expected. Construction risks would be the same for Alternate Sites 1, 2, and 3 since the construction techniques and construction times are similar. Because the construction sites are inaccessible to the public, there would be no health and safety impacts to the general public from construction.

4.3.3.2 Cylinder movement

The following potential physical hazards that would be associated with cylinder movement during the proposed action and for the no action alternative.

Proposed action.

Movement of UF6 cylinders between yards is a potential source of health and safety impacts. This activity is estimated to take four workers five years to complete. Therefore, assuming total PH of 41,600, the number of injuries that may be expected is 1.4, and the number of fatalities that may be expected is 0.02. These values indicate

that on average, 1 cylinder moving-related injury may be expected and no cylinder moving-related fatalities may be expected. Moving cylinders to Alternate Sites 1 and 2 would essentially have the same potential for worker injuries due to accidents as those for the proposed site. However, because moving the cylinders to Alternate Site 3 would require a greater transportation distance, slightly higher potential for injuries may be expected due to increased PH required to move cylinders to this location. Because the cylinder yards are inaccessible to the public, there would be no direct physical health and safety impacts to the general public from cylinder movement.

No action.

Impacts to occupational health and safety related to cylinder movement under the no action alternative would be minimal because minimal cylinder movement would occur. Because the cylinder yards are inaccessible to the public, there would be no direct physical hazards to general public health and safety from cylinder movement.

4.3.3.3 Accident analysis

The following is an analysis of exposure, ingestion, and inhalation hazards associated with possible accident scenarios identified for the proposed action.

Storage yard accidents.

A Process Hazards Analysis (PHA) was performed for the existing cylinder storage yards (MMES, 1995b). Operations in the cylinder storage yards were analyzed to identify accidents that could expose workers and the public to the hazards associated with the yards. The PHA considered internal events (e.g., active failures of equipment, passive failures, human error), external events (e.g., vehicle/equipment impacts, fires), natural phenomena (e.g., high wind, tornado, flood, earthquake, lightning), and the probability of occurrence. From this analysis, the following bounding accident scenarios were developed:

Release of solid UF6 due to the failure of a cylinder via corrosion or cylinder handling accident;
Release of gaseous UF6 due to an airplane crash or a fire involving cylinder handling equipment; and
Criticality event.

Results of the accident analysis for the existing yards are representative of risk associated with no action. Consequences were estimated at a distance of 600 m (2,000 ft) to the nearest receptor per the DOE guidance or standards [i.e., negligible, low, moderate, or high consequences (DOE, 1994)]. In addition, the frequency of each accident was evaluated and classified as follows:

Anticipated event:	above 10-2/year (one chance out of 100/year)
Unlikely event:	10-2 to 10-4/year
Extremely unlikely event:	10-4 to 10-6/year
Beyond extremely unlikely events:	below 10-6/year

Using the consequences classification and the frequency classification, each accident was categorized in one of the following risk categories:

Category I - Major;
Category II - Serious;
Category III - Marginal; and
Category IV - Negligible.

Operation in the proposed UF6 cylinder yard would be similar to those of the existing cylinder storage yards. The UF6 cylinders would be stored in the proposed C-745-T Yard and activities within the yards would include handling and moving of the cylinders and periodic surveillance and maintenance on the cylinders, as required. Operation of the proposed C-745-T Yard would not introduce accidents that have not already been evaluated for the existing cylinder storage yards. Therefore, the accident analysis for the existing yards (MMES, 1995b) is applicable to accidents within the proposed C-745-T Yard and the refurbished yards.

Release of solid uranium hexafluoride.

A release of solid UF6 may occur due to a cylinder handling accident or corrosion of a cylinder stored in the yard. The analysis found that the release of a full cylinder, 12,700 kilograms (28,000 pounds) of UF6 enriched to 1.9% 235U, would result in Òlow consequencesÓ as defined in the DOE-STD-3011-94 (DOE, 1994). According to this standard, a radiological accident low-consequence level is defined for workers as solid releases of radioactivity of less than 0.1 roentgen equivalent man (rem) (100 mrem) at 600 m (2,000 ft) or no serious injuries in the facility and less than 0.01 rem (10 mrem) at the site boundary for the public. For comparison purposes, the average background radiation level in the United States is estimated to be 360 mrem/year. This average is based on the range of 100 mrem/year for people who live on sandy soil at sea level, to nearly 1,000 mrem/year for people who live in stone houses at high elevations (NCRP, 1987; NRC, 1994). Also, the 10 mrem/year limit at the site boundary for the public is equivalent to a dose expected for a person who flies across the United States twice.

A chemical accident low-consequence level is defined for workers as releases of chemicals to the air at concentrations less than the emergency response planning guideline (ERPG)-2 at 600 m (2,000 ft) or no serious injuries in the facility and less than the ERPG-1 at the site boundary for the public. The ERPG-1 is defined as Òthe maximum concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing anything more than mild transient health effects,Ó the ERPG-2 is defined as Òthe concentration below which it is believed that nearly all individuals would come to no permanent harm after one-hour exposure period,Ó and the ERPG-3 is defined as Òthe maximum concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing life threatening health effects.Ó For HF, the ERPG-3 is 41.5 milligram (mg)/m3 and the ERPG-2 is 16 mg/m3. There is no ERPG for uranium (MMES, 1995b).

The frequency of a release of solid UF6 was estimated to be greater than 10-2 per year. Therefore, this type of accident was classified as an anticipated event. Using this information, an accident resulting in the release of solid UF6 was categorized as a Category III - marginal risk accident. This analysis concludes that the release of solid UF6 would not expose cylinder yard workers, the approximately 300 workers located nearby the existing cylinder yards and the proposed C-745-T Yard site, or any member of the general public to an unacceptable level of HF. This estimate is conservative for the general public because the analysis assumed a distance of 600 m (2,000 ft) to the nearest resident, while the nearest resident is over 2,370 m (7,900 ft) away. In addition, the potential release of airborne chemicals, particularly HF, would likely not adversely affect nearby workers in the short term (i.e., less than one-hour exposure). The likelihood of an exposure time greater than one hour is low due to the irritating property of HF. Immediate retreat from the area would follow a detection of irritating vapors.

An indirect effect is the possible contamination of soil and surface water due to deposition of contaminants from a release of material from the cylinders. Food crops could be contaminated due to uptake of the contaminants from the soil and surface water used for irrigation. However, because of the small amount of material that would be released from the most likely accident (dropped cylinder resulting in the release of solid UF6), the lack of any agriculture fields inside the fence and within the DOE buffer, and the limited transfer of contaminants through the food chain, the amount of material ingested by a human receptor would be negligible and no adverse effects are anticipated to occur as a result of this project.

The potential for a release of solid UF6 would be higher for the proposed action during cylinder relocation as more cylinders would be moved in a shorter period of time than with the no action alternative. However it should be noted that reconfiguration of existing cylinders would lower the potential for a cylinder breach via corrosion by: allowing adequate inspection and maintenance of cylinders thereby fixing suspect cylinders before they breach; slowing corrosion rates by removing cylinders from contact with the ground; and lessening the amount of time the cylinders are in contact with water that is pooled on the ground surface. Consequently, the proposed action would lower the likelihood of a cylinder breach via corrosion. Accidents associated with Alternate Sites 1, 2, and 3 would generally be the same as those discussed for the proposed C-745-T Yard. However, due to the increased distance required for transport of UF6 cylinders to Alternate Site 3, the potential for accidents may increase during relocation of cylinders to this alternate site.

Release of gaseous uranium hexafluoride.

A release of gaseous UF6 could occur only if there is a fire with sufficiently high temperature and duration to heat the solid UF6 to the point where it undergoes sublimation (change from a solid to a gas without ever becoming a liquid). Two initiators, an airplane crash or a fire involving cylinder handling equipment, were identified. The results of the analysis for a gaseous release indicate that the potential for fatality or serious injury to operating personnel exists. Therefore, using the DOE standard (DOE, 1994), the consequences of this accident would be classified as high. According to this standard, a radiological accident high-consequence level is defined for workers as a release of radioactivity of greater than 25 rem (25,000 mrem) at

600 m (2,000 ft) or prompt death in the facility and greater than 5 rem (5,000 mrem) at the site boundary for the public. For whole body doses between 5 and 74 rem, only temporary effects would result. These effects are normally limited to temporary depression of white blood cell levels and temporary reddening of the skin (erythema) (LaMarsh, 1983). It should be noted that these effects are not observed in all people receiving a dose between 5 and 75 rem (i.e., some people suffer no effects at all).

A chemical accident high-consequence level is defined for workers as releases of chemicals to the air at concentrations greater than or equal to the ERPG-3 at 600 m (2,000 ft) or prompt death in the facility and greater than the ERPG-2 at the site boundary for the public. The frequency for each initiator was determined to be between 10-4 and 10-6 per year such that the accident was classified as an extremely unlikely event. Using the consequence and frequency rankings, an accident of this type involving the release of gaseous UF6 was classified as a Category II - serious risk accident. This analysis suggests that the release of gaseous UF6 under the above scenario would result in workers in the cylinder yards, as well as nearby workers receiving unacceptable doses which may lead to temporary, reversible effects, although a serious radiological accident can be classified as causing fatalities. In addition, this type of release would result in unacceptable exposure to members of the public (at the facility boundary), leading to temporary, reversible effects. It should be noted that actual dose for such residents would likely be lower, as the analysis assumed a distance of 600 m (2,000 ft), while the nearest community is over 2,370 m (7,900 ft) away.

The analysis also suggests that a release of gaseous UF6 under a fire scenario would result in cylinder yard workers and nearby workers being exposed to concentrations of HF that may cause life-threatening health effects should exposure exceed one hour. The likelihood of an exposure time greater than one hour, however, is low due to the irritating property of HF. Immediate retreat from the area would follow a detection of irritating vapors. Also, members of the general public may be exposed to concentrations of HF at the facility boundary that could result in adverse effects should the exposure exceed one hour. Actual airborne concentrations that such residents would be exposed to would be even lower, as the analysis assumed a distance of 600 m (2,000 ft, while the nearest community is over 2,370 m (7,900 ft) away.

Since this accident scenario is not specific to the proposed action (i.e., probabilities are the same for the no action and proposed action alternatives), the consequences of the no action alternative and the proposed action would be the same.

Criticality.

Cylinders may exceed the theoretical minimum mass limit for fissile material. Therefore, the potential for criticality exists if a cylinder is breached and a sufficient quantity of water is available for moderation. A criticality event in the yards would have the potential for serious injury or fatality to operating personnel. Based on this, a criticality accident is classified as Òhigh consequencesÓ per the DOE standard (DOE, 1994). This accident scenario would have the same result as that previously discussed for a fire. However, the frequency of a criticality accident occurring was classified as an extremely unlikely event due to the many safety requirements of the Nuclear Criticality Safety Program (MMES, 1995g) implemented at the PGDP. Using the consequence and frequency rankings, a critical accident was classified as a Category IIÑserious risk accident. This analysis suggests that a criticality accident under the above scenario would only result in workers in the cylinder yards near such a criticality event receiving unacceptable doses which may lead to temporary, reversible effects, although a serious radiological accident can be classified as causing fatalities. Workers in nearby buildings would not likely receive unacceptable doses due to the increased distance from a criticality event in a cylinder yard, as well as the shielding effect by the building structures. It should be noted, however, that current monitoring for a criticality events would alert the facility so that appropriate actions are taken to protect workers. Also, due to distance between the cylinder yards and off-site residents, no unacceptable doses would be expected.

4.4 CUMULATIVE IMPACTS

Cumulative impacts are those effects that result from the incremental impacts of the action when added to other past, present, and reasonably foreseeable future actions regardless of which agency (federal or nonfederal) or person undertakes such actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time.

Specific ongoing and planned actions considered in this section are the Northwest Plume Pump and Treat Facility and phases VII and VIII of the UF6 cylinder yards expansion. The Northwest Plume Pump and Treat Facility is a small sheet metal building constructed on an approximately 30 x 15 m (100 x 50 ft) concrete pad located near the northwest corner of the PGDP (Figure 4-2). This facility receives ground water from north of the building through a pipeline and treats it for contaminants before discharging it through Outfall 001. The phases VIII and VII cylinder yard expansions involve cylinder yards C-745-G and S Figure 4-2. Locations of Current, Proposed, and Alternate Sites for Storage of Uranium Hexafluoride Cylinders in Relation to Other Applicable Ongoing Projects at the Paducah Gaseous Diffusion Plant

located adjacent to the C-745-K, L, M, N, and P cylinder yards (Figure 4-2). These projects are confined within the security fence and are not associated with this project.

Figure 4-2. Locations of Current, Proposed, and Alternate Sites for Storage of Uranium
Hexafluoride Cylinders in Relation to Other Applicable Ongoing Projects at the
Paducah Gaseous Diffusion Plant

4.4.1 Water Resources

The following are potential cumulative surface water and ground water impacts identified with the proposed action.

4.4.1.1 Surface water

The addition of a concrete pad at the proposed C-745-T Yard would increase precipitation runoff to Outfall 017. Concrete pads at existing cylinder yards, C-745-K, L, M, N, and P, as well as a concrete pad added during the phases VII and VIII cylinder yard expansions would also increase precipitation runoff flow through Outfall 017. The increased outfall flow from these multiple actions would need some controls in place to prevent adverse effects to water quality or biota. The velocity and amount of flow entering Ditch 017 during a major storm event as a result of these multiple actions are a potential source of concern. Since each cylinder yard would be constructed with a 1% grade downward toward three center line drain grates, storm water would be allowed to back up in the cylinder yards temporarily to a depth of 1 ft during a major storm event. This design limits velocity of flow to some extent, but riprap would still be necessary to further reduce flow velocity at the pipe exit and reduce ditch erosion. Also, since some sediment would be carried through the pipes with the water, the ditches would need occasional maintenance to prevent siltation over a long period of time. With these controls and maintenance, adverse effects to water quality and biota would be minimized or eliminated.

At Alternate Site 3, increased precipitation runoff flow to Outfall 001, resulting from the proposed action, would be additive with the flow already directed to this outfall from Northwest Plume pump and treat operations. The increase in outfall flow would be minimal, and no adverse cumulative impacts are expected.

4.4.1.2 Ground water

The addition of a concrete pad and a concrete drainage system at any of the sites located on the terrace would reduce recharge in the Terrace Gravels and could potentially reduce ground water flow off the terrace in the vicinity of the site. Also, construction of concrete pads on existing cylinder yards, C-745-K, L, M, N, and P, as well as the construction of a concrete pad for the Phase VIII cylinder yard expansion would further reduce flow to the Terrace Gravels. However, change in recharge would be minimal and would not adversely affect ground water in quantity or quality.

Alternate Site 3 is located approximately 137.2 m (450 ft) from the Northwest Plume Pump and Treat Facility. The presence of a storage area concrete pad and drainage system would reduce ground water recharge beneath the site to sand and gravel lenses within the UCRS. Also, decreased infiltration and recharge to the RGA may lower the ground water level in the vicinity. Small, localized changes to the depth to the surface of the RGA may be caused by reduced recharge to the aquifer, and would be additional to those caused by the Northwest Plume pumping wells.

4.4.1.3 Wetlands

A possible wetland impact has been identified as a result of redirecting surface flow from the cylinder yards. A small drainage to the west of the C-745-S Yard currently receives surface flow from this yard. If flow is redirected away from this drainage, dewatering and subsequent wetland loss may occur. At most, 0.06 hectare (0.15 acre) of wetland may be lost. However, it is likely that overland flow would be sufficient to maintain wetland conditions within this drainage area.

4.4.2 Sensitive Resources

The proposed action would result in negligible impacts to floodplains, biota, T&E species, soils and prime farmland, and cultural resources. Thus, it would not incrementally affect these resources in combination with other projects.

4.4.3 Air Quality

A worst-case scenario would be for the proposed action to occur simultaneously with other construction activities scheduled for the PGDP. The fugitive dust emissions from all construction activities could lead to a short-term degradation of air quality. However, due to dispersion and the widely spaced nature of the activities, the impact on air quality would likely not be notable during these activities. In addition, BMPs would be implemented for each construction activity to limit the fugitive dust emissions.

4.4.4 Noise

Because other construction activities may occur concurrently with the proposed action, there could be a short-term increase in on-site noise; however, this combined amount of noise would not affect off-site receptors.

4.4.5 Socioeconomics

If many projects occurred simultaneously, labor requirements would be met by the local labor pool. Consequently, cumulative effects would be minor.

4.4.6 Land Use

If future expansion continues into the buffer zone, the perimeter of the plant would move closer to the WKWMA and ultimately closer to public thoroughfares. This may present long-term security issues associated with increased public contact (e.g., recreational activities and residences closer to the plant). Also, should a minimum buffer zone be maintained between the security fence and public thoroughfares, a loss of land in the WKWMA may occur, thus resulting in a loss in recreational use of this land. However, most actions associated with the PGDP are within the security fence.

4.4.7 Transportation

A short-term increase in on-site traffic would result from multiple projects occurring simultaneously.

4.4.8 Health and Safety

The total radiological dose that a worker at the PGDP may receive is administratively set by the Radiation Protection Plan (MMES, 1995g). The limits set forth by this plan are in compliance with DOE and Nuclear Regulatory Commission (NRC) requirements. Workers at the PGDP may be involved in numerous activities at several locations around the plant. Some of these activities or locations may involve work with toxic or radioactive material resulting in occupational exposure. Workers who receive a dose while in the cylinder storage yards may also receive additional doses elsewhere at the PGDP. However, the limits of the plan are conservatively set such that the cumulative dose would not result in adverse health effects. Because the UF6 cylinder yards are inaccessible to members of the public, it would not contribute to any cumulative health impacts on the general public.

4.4.9 Waste Management

Excavation and land disturbance during construction would generate DGA and soil. These would be spread over the project site after completion of the cylinder storage yard; thus, waste storage and/or disposal would not be necessary. Because of this, there would be no cumulative effects on waste storage or disposal facilities at PGDP.

5.0 COMPLIANCE WITH REGULATORY REQUIREMENTS

All activities associated with the proposed action would comply with applicable regulatory requirements as indicated in the aforementioned sections. Those requirements will not be reiterated here (e.g., the regulatory requirements for fugitive dust emissions and open burning are in the section discussing impacts to air). This section documents regulatory requirements that would apply if any of the alternate sites were selected. Selection of any of the alternate sites could, at a minimum, require a wetland assessment, T&E species survey, cultural resources survey, and consultation with applicable agencies regarding the specific site selected. Additionally, any modifications to construction plans would require an impact assessment associated with the new plans.

Under Executive Order 11990, Protection of Wetlands, all federal agencies must show that there are no practicable alternatives to the proposed action and that all practicable measures to minimize harm to wetlands which may result from such use have been incorporated. Pursuant to the requirements of Executive Order 11990 and DOE regulation 10 CFR 1022, a Notice of Wetlands Involvement was published in the Federal Register on May 3, 1996 and a wetlands assessment was conducted for the proposed action. DOE concluded that the loss of less than one acre of wetlands at the project site would not be an important adverse impact and that there were no practicable alternatives to locating the action in a wetland.

If Alternate Site 1 was selected, additional regulatory requirements pertaining to wetlands, discussed below, would be triggered. Alternate Site 1 was originally the preferred site for the C-745-T Yard; however, to comply with Executive Order 11990, the DOE selected the proposed C-745-T Yard.

Section 404 (b)(1) guidelines allow that an NWP may be issued for minor activities not representing major adverse impacts to waters of the United States Specific activities covered by an NWP are outlined in 33 C.F.R. ¤ 330. Each NWP has specific requirements (e.g., avoidance, minimization, and BMPs) that must be complied with. If an NWP is applicable, the applicant needs to comply with its terms, and no further action is necessary. Nationwide Permit 26 is applicable to this project and allows fills up to 4 hectares (10 acres) in headwaters (waters with less than 5 ft3 per second mean annual flow) and isolated waters provided the COE district engineer (DE) is notified of fills greater than 0.4 hectare (1 acre) [33 C.F.R. ¤ 330 (Appendix A)]. Procedures applicable to NWP 26 include, but are not limited to, the following: submittal of a wetland delineation report, submittal of consultation correspondences to agencies (e.g., USFWS, SHPO, and NRCS), and mitigation measures to compensate for the wetland loss. Mitigation would be in the form of wetland creation at a 2:1 or 3:1 ratio, depending on the site selected for creation. A formal mitigation report would be required as outlined in Wetland Compensatory Mitigation and Monitoring Plan Guidelines For Kentucky (Kanzinger, 1993).

On January 21, 1992, the Kentucky Department for Environmental Protection (KDEP) Division of Water placed conditions on COE NWP 26 that require applicants to have a Section 401 Water Quality Certification (WQC) prior to COE approval of the NWP. State WQC must be obtained for all projects proposing impacts to wetlands greater than 0.4 hectare (1 acre) and NWP 26 cannot be utilized without it. The WQC application process is typically initiated by the DE upon request for any general or NWP. However, if the impacts are less than 0.4 hectare (1 acre), state WQC need not be obtained.

6.0 AGENCY CONSULTATION

The following agency personnel were contacted during preparation of this EA.

Frank DeGott U.S. Army Corps of Engineers Louisville District P.O. Box 59 Louisville, Kentucky 40201-0059	Dr. Lee A. Barclay Field Supervisor Fish and Wildlife Service United States Department of Interior 446 Neal Street Cookeville, Tennessee 38501
Charlie Logsdon Wildlife Management Area Supervisor West Kentucky Wildlife Management Area 10535 Ogden Landing Road Kevil, Kentucky 42053	U.S. Dept. of Commerce Bureau of Economic Analysis Washington, D.C.
John A. Shely District Conservationist Natural Resources Conservation Service 2715 Olivet Church Road Paducah, Kentucky 42053	Fred Grimes McCracken County Attorney McCracken County Courthouse Paducah, Kentucky 42001
David Morgan Kentucky Heritage Council and State Historic Preservation Officer 300 Washington Street Frankfort, Kentucky 40601	U.S. Bureau of Labor Statistics Department of Labor N-3627 Frances Perkins Building 200 Constitution Ave., NW Washington, D.C. 20210

7.0 LIST OF PREPARERS

This environmental assessment was prepared by the Jacobs ER Team under contract to the DOE. The following personnel contributed to the preparation of this document.

Name	Degree/Expertise	Years Experience	Role
Greg Summers (Jacobs)	B.S. Reclamation M.S. Range Science	6	Task Lead
Don Wilkes (Jacobs)	B.A. Environmental Biology	22	Technical Review
Waynette Roberson (Jacobs)	B.S. Environmental Engineering	2	Editorial Review
Kevin Barber (Jacobs)	B.S. Petroleum Engineering	7	Proposed Action Transportation
Amy Shehee (Jacobs)	B.A. English J.D.	2	Regulatory Compliance
Betty Gamber (Jacobs)	B.A. Geology	4	Geology and Hydrology
David Shehee (Jacobs)	B.A. Chemistry M.S. Chemistry	5	Noise, Demographics, and Socioeconomics
Steve Kucera (Jacobs)	B.S. Environmental Health M.S. Environmental Toxicology	7	Air and Human Health
Phil Howell (Jacobs)	B.S. Nuclear Engineering	7	Land Use and Accident Analysis
Brian Bowers (LMES)	B.S. Geology	7	Technical Review
Kevin White (LMES)	B.S. Electrical Engineering	7	Engineering and Construction
Carlos Alvarado (DOE)	B.S. Electrical Engineering	7	DOE NEPA Document Manager
John Lamb (Enterprise Advisory Services, Incorporated)	Occupational and Radiological Safety and Health	30	Technical Review
Andrea Campbell (DOE)	B.S. Biology M.S. Biology	16	Technical Review

8.0 REFERENCES

CDM, 1994. Investigations of Sensitive Ecological Resources Inside the Paducah Gaseous Diffusion Plant, 7916-0003-FR-BBRY, CDM Federal Programs Corporation, August 19, 1994.

CH2M HILL, 1992. Results of the Site Investigation, Phase II, Paducah Gaseous Diffusion Plant, Paducah, Kentucky, KY/SUB/13B-97777C P-03/1991/1, CH2M HILL Southeast, Inc., Oak Ridge, TN, April 1992.

COE, 1994. Environmental Investigations at the Paducah Gaseous Diffusion Plant and Surrounding Area, McCracken County, Kentucky, United States Army Corps of Engineers, May 1994.

DOC, 1994a. County Business Patterns 1992, Economics and Statistics Administration, Bureau of the Census, United States Department of Commerce, September 1994.

DOC, 1994b. County and City Data Book 1994, 12th Edition, Economics and Statistics Administration, Bureau of the Census, United States Department of Commerce, August 1994.

DOC, 1995. Survey of Current Business, Economics and Statistics Administration, Bureau of Economic Analysis, United States Department of Commerce, Volume 75, Number 4, April 1995.

DOE, 1994. Guidance for Preparation of DOE-5480.22 (TSR) and DOE 5480.33 (SAR) Implementation Plans, DOE-STD-3011-94, United States Department of Energy, Washington, D.C., 1994.

DOE, 1995a. Draft Northeast Plume Preliminary Characterization Summary Report, DOE/OR/07-1339/V1&D1, United States Department of Energy, February 1995.

DOE, 1995b. Draft Waste Management Programmatic Environmental Impact Statement, DOE/EIS-0200-D, Office of Environmental Management, United States Department of Energy, August 1995.

Grimes, 1995. Fred Grimes, McCracken County Attorney, personal communication with David Shehee, Jacobs ER Team, August 17, 1995.

Humphrey, 1976. Soil Survey of Ballard and McCracken Counties, Kentucky, Humphrey, Maurice E., United States Department of Agriculture, Soil Conservation Service in cooperation with the Kentucky Agricultural Experiment Station, 1976.

Kanzinger, 1993. Wetland Compensatory Mitigation and Monitoring Plan Guidelines For Kentucky, Kanzinger, Bob, Louisville District Corps of Engineers, Region IV United States Fish and Wildlife Service, Region IV United States Environmental Protection Agency, Kentucky Division of Water, and the Kentucky Department of Fish and Wildlife Resources, August 2, 1993.

KSNPC, 1991. Biological Inventory of the Jackson Purchase Region of Kentucky, Kentucky State Nature Preserves Commission, Frankfort, KY, 1991.

LaMarsh, 1983. Introduction to Nuclear Engineering, ISBN 0-201-14200-7, LaMarsh,

John R., 1983.

LeVasseur, 1995. Ken LeVasseur, United States Bureau of Labor Statistics, personal communication with Stephanie Davis, Jacobs ER Team, September 6, 1995.

LMES, 1995. On-Site Handling and Disposal of Waste Materials, PMWM-1002, Rev. 0, Lockheed Martin Energy Systems, Inc., August 31, 1995.

MMES, 1992. Report of the Paducah Gaseous Diffusion Plant Groundwater Investigation Phase III, Clausen, J.L., et al., KY/E-150, Martin Marietta Energy Systems, Inc., November 1992.

MMES, 1994. Paducah Gaseous Diffusion Plant Annual Site Environmental Report for 1993, KY/ERWM-18, Martin Marietta Energy Systems, Inc., October 1994.

MMES, 1995a. Conceptual Design Report For The Paducah Gaseous Diffusion Plant UF6 Cylinder Storage Yards, Phase IX, KY/MMES-11, Martin Marietta Energy Systems, Inc., February 1995.

MMES, 1995b. Basis for Interim Operation for the Paducah Gaseous Diffusion Plant Cylinder Yards, Martin Marietta Energy Systems, Inc., Paducah, KY, 1995.

MMES, 1995c. Wetlands Assessment For The Proposed UF6 Cylinder Storage Yards, Phase IX, Paducah Gaseous Diffusion Plant, Paducah, Kentucky, Martin Marietta Energy Systems, Inc., September 1995.

MMES, 1995d. Draft Wetlands Assessment For UF6 Cylinder And Storage Yards, Phase IX At The Paducah Gaseous Diffusion Plant, Paducah, Kentucky, KY/EM-93, Martin Marietta Energy Systems, Inc., July 1995.

MMES, 1995e. Wetlands Delineation For Alternate Site 2 For The UF6 Cylinder Storage Yards, Phase IX, Paducah Gaseous Diffusion Plant, Paducah, Kentucky, KY/EM-111, Martin Marietta Energy Systems, Inc., September 1995.

MMES, 1995f. Threatened And Endangered Species Survey For The Proposed UF6 Cylinder Yard Storage Yards, Phase IX, Paducah Gaseous Diffusion Plant, Paducah, Kentucky, KY/EM-94, Martin Marietta Energy Systems, Inc., September 1995.

MMES, 1995g. Cultural Resources Assessment For The Proposed UF6 Storage Cylinder Yards, Phase IX, Paducah Gaseous Diffusion Plant, Paducah, Kentucky, KY/EM-95, Martin Marietta Energy Systems, Inc., September 1995.

MMES, 1995h. Safety Management Programs Supporting Nuclear and Hazardous Facilities, ES/ESH-66, Rev. 0, Martin Marietta Energy Systems, Inc., Paducah, KY, 1995.

MMUS, 1994. Spill Prevention, Control, Countermeasures, and Contingency Plan for Oils, Chemicals, and Hazardous Waste, KY/B-249 Revision 6, Martin Marietta Utility Services, Inc., Paducah, KY, September 1994.

NCRP, 1987. Ionizing Radiation Exposure of the Population of the United States, NCRP Report No. 93, National Council on Radiation Protection and Measurements, September 1, 1987.

NRC, 1994. Background as a Residual Radioactivity Criterion for Decommissioning, NUREG-1501, United States Nuclear Regulatory Commission, Washington, D.C., August 1994.

PGDP, 1995. Paducah Gaseous Diffusion Plant, Linda Callender, Lockheed Martin Utility Systems, Inc., personal communication with Stephanie Davis, Jacobs ER Team, August 1995.

Shapiro, 1981. Radiation Protection, ISBN 0-674-74584-1, Shapiro, Jacob, 1981.

TVA, 1995. Tennessee Valley Authority Shawnee Steam Plant, Michelle Dalton, personal communication with Stephanie Davis, Jacobs ER Team, August 1995.

USEC, 1995. Uranium Hexafluoride: A Manual of Good Handling Practices, USEC-651 (Revision 7), United States Enrichment Corporation, January 1995.

USFWS, 1979. Classification of Wetlands and Deepwater Habitats of the United States, Cowardin, L. M., V. Carter, F. C. Golet, and E. T. Laroe, United States Fish and Wildlife Service Publication FWS/OBS-79-31, 1979.

White, 1995. White, Kevin L., Project Manager, internal correspondence to Brian Bowers, Lockheed Martin Energy Systems, Inc., August 18, 1995.

NEWSLETTER

Join the GlobalSecurity.org mailing list

Weapons of Mass Destruction (WMD)

EA-1118; Environmental Assessment and FONSI Refurbishment and Construction of Uranium Hexafluoride Cylinder Storage Yards at the Paducah Gaseous Diffusion Plant, Paducah, Kentucky