ENVIRONMENTAL ASSESSMENT AND (FONSI) OPERATION OF THE HB-LINE FACILITY AND FRAME WASTE

ENVIRONMENTAL ASSESSMENT AND (FONSI)
OPERATION OF THE HB-LINE FACILITY AND
FRAME WASTE RECOVERY PROCESS FOR
PRODUCTION OF PU-238 OXIDE AT THE
SAVANNAH RIVER SITE
TABLE OF CONTENTS

ENVIRONMENTAL ASSESSMENT AND (FONSI)
OPERATION OF THE HB-LINE FACILITY AND
FRAME WASTE RECOVERY PROCESS FOR
PRODUCTION OF PU-238 OXIDE
AT THE SAVANNAH RIVER SITE

ENVIRONMENTAL ASSESSMENT OPERATION OF THE
HB-LINE FACILITY AND FRAME WASTE RECOVERY PROCESS FOR
PRODUCTION OF PU-238 OXIDE AT THE SAVANNAH RIVER SITE
TABLE OF CONTENTS
1.0 PURPOSE AND NEED
1.1 Background
1.1.1 Power Systems for NASA Missions
1.1.2 Pu-238 from Weapons Returns
1.1.3 Recent HB-Line Operations
2.0 PROPOSED ACTION AND ALTERNATIVES
2.1 Proposed Action
2.2 Alternatives to the Proposed Action
2.2.1 No Action
2.2.2 Alternative Processing Facility
2.2.3 Alternative Vault Storage Facility
2.2.4 Processing at the National Laboratories
2.2.5 Purchase of Pu-238 from Foreign Nations
2.2.6 Alternative Packaging and Storage of Pu-238
3.0 OPERATION DESCRIPTION
3.1 Facility Description
3.1.1 HB-Line Facilities
3.1.2 Frame Waste Recovery Process
3.1.3 HB-Line Vault
3.2 Processing Description
3.2.1 Scrap Recovery Facility (HB-Line Phase I)
3.2.2 Frame Waste Recovery (FWR) Process
3.2.3 Plutonium Oxide Facility (HB-Line Phase III)
3.3 Management & Operation
3.4 Description of Transportation Activities
4.0 AFFECTED ENVIRONMENT
4.1 Geography, Demography, and Socioeconomics
4.2 Radiation Environment
4.3 Waste Management
5.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION
5.1 Normal Facility Operations
5.1.1 Socioeconomics
5.1.2 Ecology and Cultural Resources
5.1.3 Air Emissions
5.1.4 Surface Water Effluents
5.1.5 Worker Health Effects
5.1.6 Waste Management
5.2 Accident Analysis
5.2.1 HB-Line Facilities (Phases I and III)
5.2.2 Frame Waste Recovery (FWR)
5.2.3 Onsite (SRS) Transportation Accidents
5.2.4 Incident-Free Off-site Transportation
5.2.5 Transportation Accidents
5.2.6 Nonradiological Transportation Accidents
5.2.7 Health Effects
5.3 Effects of Radiological Doses
5.3.1 Collective Doses
5.3.2 Individual Doses
6.0 REGULATORY CONSIDERATIONS
6.1 National Environmental Policy Act of 1969
6.2 Solid Waste Regulations
6.3 Air Emissions Regulations
6.4 Liquid Discharge Regulations
6.5 Transportation Regulations
7.0 PERSONS AND AGENCIES CONSULTED
8.0 REFERENCES

APPENDIX A: COMMENTS RECEIVED ON THE
DRAFT HB-LINE ENVIRONMENTAL ASSESSMENT, AND DOE RESPONSES

1.0 COMMENTS TRANSMITTED TO DOE FROM THE
ENERGY RESeaRCH FOUNDATION (ERF), DECEMBER 8, 1994
1.1 ERF Comment 1
1.1.1 DOE Response
1.2 ERF Comment 2
1.2.1 DOE Response
1.3 ERF Comment #3
1.3.1 DOE Response
1.4 ERF Comment #4
1.4.1 DOE Response
1.5 ERF Comment #5
1.5.1 DOE Response
1.6 ERF Comment #6
1.6.1 DOE Response

2.0 COMMENTS TRANSMITTED TO DOE FROM
MR. W. LEE POE, JR., DECEMBER 9, 1994
2.1 Mr. Poe's Comment 1
2.1.1 DOE Response
2.2 Mr. Poe's Comment 2
2.2.1 DOE Response
2.3 Mr. Poe's Comment 3
2.3.1 DOE Response
2.4 Mr. Poe's Comment 4
2.4.1 DOE Response

3.0 COMMENTS RECEIVED AT THE
PUBLIC MEETING HELD IN NORTH AUGUSTA, SOUTH CAROLINA, DECEMBER 6, 1994
3.1 Comment by Mr. Bob Overman
3.1.1 DOE Response
3.2 Comment by Mr. Lee Poe
3.2.1 DOE Response

4.0 COMMENTS RECEIVED AT THE
PUBLIC MEETING HELD IN SAVANNAH, GEORGIA, DECEMBER 8, 1994
4.1 Comment by Mr. George Minot
4.1.1 DOE Response
4.2 Comment by Mr. George Minot
4.2.1 DOE Response
4.3 Comment by The Reverend Susan S. Dulany
4.3.1 DOE Response

5.0 COMMENTS AND QUESTIONS RECEIVED AT THE
WORKSHOP HELD IN NORTH AUGUSTA, SOUTH CAROLINA, JANUARY 18, 1994
5.1. Question
5.1.1 DOE Response
5.2 Question
5.2.1 DOE Response

6.0 COMMENTS AND QUESTIONS RECEIVED AT THE
WORKSHOP HELD IN SAVANNAH, GEORGIA, JANUARY 20, 1994
6.1 Question
6.1.1 DOE Response
6.2 Question
6.2.1 DOE Response
6.3 Question
6.3.1 DOE Response
6.4 Question
6.4.1 DOE Response
6.5 Question
6.5.1 DOE Response

FINDING OF NO SIGNIFICANT IMPACT
OPERATION OF THE HB-LINE FACILITY AND
FRAME WASTE RECOVERY PROCESS FOR
PRODUCTION OF Pu-238 OXIDE AT THE
SAVANNAH RIVER SITE
SUMMARY:
PUBLIC AVAILABILITY:
BACKGROUND:
PROPOSED ACTION:
ALTERNATIVES CONSIDERED:
ENVIRONMENTAL IMPACTS:
DETERMINATION:
Issued at
LIST OF FIGURES (Not available in electronic format)
Page
Figure 3-1. H-Canyon Building and HB-Line Facilities 9
Figure 3-2. Pu-238 Material Flow Diagram 9
Figure 3-3. Pu-238 Process Flow Diagram 12
Figure 4-1. Operational Areas at SRS 15
LIST OF TABLES
Page
Table 1-1 Estimated Pu-238 Fuel Requirements 3
Table 5-1 Non-Radiological Air Pollutants for Processing Pu-238 16
Table 5-2 Atmospheric Radiological Emissions 16
Table 5-3 Liquid Radiological Effluents 17
Table 5-4 HB-Line and FWR Waste Generation 19
Table 5-5 Facility Worker Qualitative Hazard Evaluation 22
Table 5-6 Maximum Accident Dose Summary Scrap Recovery Facility 23
Table 5-7 Maximum Accident Dose Summary Plutonium Oxide Facility 23
Table 5-8 Maximum Accident Dose to Populations 24
Table 5-9 Facility Worker Qualitative Hazard Evaluation 24
Table 5-10 Maximum Accident Dose Summary Frame Waste Recovery 25
Table 5-11 Maximum Accident Dose to Populations Frame Waste Recovery 25
Table 5-12 Onsite Transportation Accident Summary 26
Table 5-13 Incident-Free Transportation Impacts for Shipments to SRS 27
Table 5-14 Number and Probability of Latent Cancer Fatalities
for Incident-Free Transportation to SRS 29
Table 5-15 Predicted Number of Latent Cancer Fatalities 30

TABLE OF CONTENTS
ENVIRONMENTAL ASSESSMENT AND (FONSI)
OPERATION OF THE HB-LINE FACILITY AND
FRAME WASTE RECOVERY PROCESS FOR
PRODUCTION OF PU-238 OXIDE AT THE
SAVANNAH RIVER SITE

DOE/ea-0948
ENVIRONMENTAL ASSESSMENT
OPERATION OF THE HB-LINE FACILITY
AND
FRAME WASTE RECOVERY PROCESS
FOR PRODUCTION OF PU-238 OXIDE
AT THE
SAVANNAH RIVER SITE
APRIL 1995
UNITED STATES DEPARTMENT OF ENERGY
SAVANNAH RIVER OPERATIONS OFFICE
SAVANNAH RIVER SITE

#1.0 PURPOSE AND NEED
The National Aeronautics and Space Administration (NASA) is planning several space missions
for the future that require a special plutonium-238 (Pu-238) oxide heat source fuel due to the
duration and environmental conditions of the missions. This Environmental Assessment (EBA)
examines the impacts of operation of the HB-Line Facility and the Frame Waste Recovery (FWR)
Process at the Savannah River Site (SRS) to process Pu-238 in support of these national program
goals in space science applications. The BA evaluates alternatives to the proposed operation,
including a new processing facility, alternate vault storage facility, processing at the National
laboratories, purchase of Pu-238 from foreign nations, processing the inventQry of Pu-238 Stored
at SRS for long term storage, and not operating the HB-Line facility following completion of
processing to support NASA's Cassini mission (no action).
The purpose of this agency action is to preserve DOE's capability to provide Pu-238 oxide heat
source fuel with the required chemical and isotopic specifications in support of national program
goals in space science applications. No other radioisotope is available, qualified, or economically
and technically practical to fulfill the unique requirements imposed by long term and independent
operation in a space environment.
DOE prepares a budget each year for congressional approval which projects all programs and
activities for the next five years. DOE prepares this budget by requesting its customers to project
all work anticipated to occur within the next five years. Although Congress may approve the five
year budget, they review and approve each year's annual budget in more detail the year prior to
which the activities are scheduled to occur (e.g. the actual FY 1997 budget will be reviewed and
approved in FY 1996). Lately, Congress has been drastically reducing the budgets of many
Federal agencies within the year prior to the activity taking place.
NASA, one of DOE's customers, must also prepare its budget in the same manner. They prepare a
list of projected missions and request funding to support these missions. DOE has an agreement
with NASA to provide Pu-238 fueled power systems for space missions when these systems are
systems are required by mission objectives. In order to provide the Pu-238 for some of the NASA missions,
DOE requires Congress to approve funds approximately 4 years prior to the scheduled launch date
to enable processing to begin. In these instances, the DOE budget to process Pu-238 would be
approved and funded by Congress; however, Congress would not approve the NASA budget for
the launch until approximately a year immediately prior to the scheduled launch date. This enables
DOE to perform the necessary planning and long lead time activities (such as Pu-238 processing)
to take place. Although there is uncertainty associated with final congressional approval of any
NASA launch, Congress shows support for specific missions by approving the budget necessary
for preparatory work.
Upon completion of the current campaign at SRS to process Pu-238 oxide to be used by DOE to
support NASA's Cassini mission, about 52 kilograms (kg) of Pu-238 will exist in the U.S.
civilian inventory in various forms and isotopic contents that are mostly unusable as heat source
fuel without further processing. This includes five kg recently purchased from Russia and
received at the SRS and includes an additional 10 kg from weapons returns (see section 1.1.2). To
be available to satisfy. projected mission requirements, these Pu-238 materials, consisting mostly of
recycle or scrap Pu-238 generated by pellet fabrication processes, safety testing activities, research
and development programs, and quality assurance activities, must be processed at SRS facilities to
remove chemical and isotopic impurities and to blend a resultant product with uniform Pu-238
isotopic properties suitable for use. Because the steps involved in transforming Pu-238 into
assembled and fully qualified Radioisotope Thermoelectric Generators (RTGs) and Radioisotope
Heater Units (RHUs) require several years, Pu-238 of the required chemical and isotopic
specifications must be made available years ahead of planned mission launches. DOE expects that
Any future Pu-238 purchased from Russia would meet DOE specifications and would be able to be
used directly in fuel pellet fabrication operations without the need for prior processing.
DOE needs to process the various forms of Pu-238 that exist in the U.S. civilian inventory to
specification Pu-238 based on NASA's requirements for RTGs and RHUs (Huntress, 1993).
These requirements are shown in Table 1-1. Missions may be added to or deleted from this list
through subsequent NASA planning. These requirements are known as flight or "fly-away"
quantities and do not represent the total quantity of Pu-238 oxide necessary to support each
mission. During Pu-238 processing and fabrication, quantities of Pu-238 oxide become
unavailable for mission use due to requirements for analytical test samples, generation of Pu-238
scrap from product characterization and safety testing operations, fabrication of spare mission
hardware, and products not meeting specifications and requiring recycle. Additionally, the Pu-238
inventory is reduced by the natural decay of the material at 0.7 % per year. Pu-238 scrap materials
generated through product characterization, safety testing, and fabrication programs may approach
25 % of mission quantities. This Pu-238 scrap is not usable to satisfy mission requirements
without additional processing into a uniform product.

1.1 Background

1.1.1 Power Systems for NASA Missions
The Atomic Energy Act of 1954, as amended, authorizes DOE to develop nuclear energy systems
in support of other governmental organizations and for its own programs. The Act also authorizes
DOE to produce such systems and directs DOE to take necessary actions to assure such systems
are used in a safe manner. Under this charter, DOE has developed and provided Pu-238 fueled
radioisotope power systems for space and terrestrial missions for over 30 years. These power
systems, known as RTGs, convert the heat from the natural decay of Pu-238 directly into
electricity. RTGs fueled with Pu-238 oxide have provided electrical power for a number of NASA
space missions. Due to the relatively long half-life of Pu-238 (87.8 years) and the absence of any
moving parts, RTGs provide long-term, reliable sources of electrical power to spacecraft and
scientific experiments. In addition, Pu-238 fueled light-weight RHUs can be used as localized heat
sources on spacecraft. Historically, the HB-Line facilities at the SRS have been used to process
Pu-238 into an oxide powder to meet the required chemical, physical, and isotopic specifications
for use in RTGs and RHUs.
The Galileo spacecraft, launched in 1989 to study Jupiter, and the Ulysses spacecraft, launched in
1990 to study the polar regions of the Sun, are powered by Pu-238 oxide fueled RTGs. These
missions could not be accomplished without RTGs due to mission duration and distance from the
Sun, rendering the use of chemical batteries or solar panels infeasible. To gain sufficient energy
for its trajectory, the Ulysses spacecraft executed a gravity assisted flyby of Jupiter where the solar
intensity is only four percent that of Earth. The scientific and technical knowledge gained from
these and other missions is vastly expanding our knowledge of the universe. Pu-238 fueled RTGs
have been used to provide electrical power to scientific instrument packages on the surfaces of both
the Moon and Mars, and have provided electrical power to several Pioneer and Voyager spacecraft,
the first spacecraft to reach the outer planets of Jupiter, Saturn, Uranus, and Neptune. These
spacecraft provided the first detailed photographs of these distant planets, and the scientific data
returned from these missions has broadened our understanding of the origins and evolution of the
planets and planetary systems.
The NASA updated strategic plan for the Solar System Exploration Program identified a series of
space exploration missions to achieve national goals, including a broadly based set of individual
missions ranging from flybys, to orbiters and simple landers, to sophisticated robotic missions. A
series of precursor missions to the Moon and Mars have also been considerecL From this broad set
of potential missions, NASA has identified missions for which Pu-238 fueled RTGs and RHUs
are being considered. These planetary exploration and space science missions may not be feasible
without the availability and use of Pu-238 fueled systems due to the distance from the Sun and
mission duration, conditions precluding the use of solar panels or chemical batteries as electrical
power sources. The numbers of RTGs and RHUs required for these missions were provided to
DOE by NASA's Associate Administrator for Space Science (Huntress, 1993). These missions,
which could require 70 kg of Pu-238 through the year 2005 for flight power supplies, include
Cassini, Pluto Fast Flyby, Mars Environmental Survey, Solar Probe, Mars Sample Return, and
other outer planetary missions. DOE is currently processing Pu-238 in SRS HB-Line facilities to
be available for use on the Cassini mission, scheduled for launch to Saturn in 1997. The current
Pu-238 inventory available for RTG use (including 5 kg purchased from Russia) is 68.2 kg.
Cassini mission flight requirements will reduce this inventory by 26 kg. Additionally,
approximately 10 kg of Pu-238 from weapons returns is expected to be available for use. Thus
about 52 kg would be available for processing following completion of the current operation for
the Cassirn mission. These quantities do not reflect natural radioactive decay or the Pu-238
required for testing as discussed in Section 1.0, or losses due to the efficiency of the process lines.
In 1993, DOE prepared an ea (DOE, 1993a) that evaluated the potential environmental impacts of
importing up to 40 kg of Pu-238 from Russia over the next five years to supplement the current
U.S. inventory. A Finding of No Significant Impact was issued on June 25, 1993. In February
of 1994, the first 5 kg of Pu-238 purchased from Russia was received by DOE at the Savannah
River Site. This first 5 kg of Pu-238 contains impurities which do not meet DOE's specification
requirements; therefore, additional processing is necessary.
Table 1-1
National Aeronautics and Space Administration Missions1
(modified from Brolin, 1993)
% Activities % Completion Funding
Total Pu-238 Completed at of All Activities Approved for Program Approved for
Year of Number of Required SRS to Support SRS to Process NASA Mission7
Mission Launch RTGs (kilograms) 3/95^4 Mission 3/95^5 Pu-238^6
Cassini 1997 3 26 95% 60% Yes Yes
Pluto Flyby 1999 1 5^8 N/A^8 0% N/A8 No (Expected l998)
2000 1 2.5^8 N/A^8 0% NA8 No (Expected 1999)
Mars 2000 4 10 0% 0% Yes No (Expected l999)
Environment 2003 4 10 0% 0% Yes No (Expected 20O2)
Survey
UR
SotarProbe 2004 1 2.5 0% 0% Yes No (Expected 2003)
Mars Sample 2005 2 5 0% 0% Yes No (Expected 2004)
Return Lander
Outerplanetary after 2005 3 9 0% 0% Yes. No(expected after 2005)
Missions^2
Total 70^9
1 Missions, launch dates, and RTG requirements have been developed for planning purposes. Missions
may be added or deleted from this list through subsequent NASA planning. Assumes use of current
thermoelectric conversion technology.
2 Missions and power supplies are assumed for post-2000 planning purposes; missions have not been finalized.
3 Estimated number of power supplies, final configurations not yet determined.
4 Represents the current (3/95) percentage of Pu-238 that has been processed at SRS with respect to the
total required for each mission.
5 Represents the current (3/95) percentage of activities that have been compleLed to support the mission.
6 Funding has been approved for SRS for process the required quantities of Pu-238 to support the missions
when each overall mission is eventually funded. The funding for Pu-238 processing is not mission specific.
7 Funding for the overall mission is generally not approved by Congress until the year immediately prior to the
launch date. Long lead time activities (such as Pu-238 processing) is funded separately and in advance of the
overall mission funding.
8 DOE and NASA are currently evaluating the use of fuel from an existing RTG (spare RTG designted
for previous Galileo and Ulysses missions). It is not anticipated that processing Pu-238 will be
required to support these mission.
9 The total quantity of Pu-238 required to be processed for post Cassini missions is 32.5 kg. This
does not include the additional quantities necessary for characterization, testing. and fabrication;
however, it does take into account the 7.5 kg. to support the two Pluto Flyby missions which is
expected to come from a spare RTG, and the 4 kg. of material that is expected to be purchased from Russia in 1995.
A second purchase of approximately 4 kg has been approved for purchase during early Fiscal Year
1995. This material will be sent directly to the Los Alamos National Lab because DOE expects that
additional processing will not be necessary prior to fuel pellet fabrication. The contract with
Russia provides options for the purchase of an additional 31 kg. Additional purchases depend on
funding availability and administration approval; however, due to budgetary limitations in Fiscal
Years 1995-1997, DOE does not anticipate purchasing any further Pu-238 from Russia under this
existing contract which expires in 1997. If additional Pu-238 is purchased from Russia, DOE does
not anticipate processing of the material in HB-Line prior to use.

1.1.2 Pu-238 from Weapons Returns
Quantities of Pu-238 exist in nuclear weapons systems scheduled for dismantlement as a result of
recent Presidential nuclear weapons policy declarations (dated September 27, 1991; January 28,
1992; and June 16, 1992). This Pu-238 is referred to as "weapons return". An evaluation was
performed to determine if any suitable weapons return Pu-238 would be available for processing
during the planned time frame of the proposed action. DOE received information confirming that
approximately 10 kg of Pu-238 from weapons return will be available. DOE is considering
processing this material, provided the properties meet the requirements necessary for use in space
power systems.

1.1.3 Recent HB-Line Operations
This ea is being prepared to assess the environmental impacts of operating the HB-Line Facility
and Frame Waste Recovery units following completion of current operations which support
NASA's Cassini mission. It is being prepared as a result of a settlement of a lawsuit filed against
the Department of Energy by the Energy Research Foundation (ERF) of Columbia, South
Carolina, on January 4, 1993. Operations were assessed in an BA prepared in 1991 (DOE, 1991);
a Finding of No Significant Impact was issued in July 1991 and HB-Line resurned operations.
Seven days after restart, operations in HB-Line were suspended due to radiological contamination
of five workers resulting from conduct of operations inadequacies involving Pu-238 scrap stored
in the HB-Line vault. Operations resumed in October 1991. One month later operations were
suspended again due to an inadvertent transfer of zirconium within the HB-Line. Operations then
resumed in December 1991. In March 1992 operations in HB-Line and H-Canyon were
suspended because of a safety question concerning the air exhaust stack liner. There was concern
that the stack liner (not the stack) would collapse in the event of a design basis earthquake and
prevent proper ventilation. These concerns were resolved in December 1992 with adequate
compensatory measures put in place to ensure proper ventilation in the event the stack liner
collapsed.
Operations resumed in January 1993 and have continued to the present. In June 1994 the H-
Canyon building steam system was damaged by failure of a steam isolation valve. This occurrence
caused the Frame Waste Recovery process to be shut down. Consequently HB-Line operations
were suspended and the down time was utilized for maintenance activities. Operations have since
resumed. Regnlar shipments of Pu-238 oxide have been made to the Los Alamos National
Laboratory, the second site involved in the process of producing RTGs.
Prior to restart to support the Cassini mission, the Defense Nuclear Facilities Safety Board
(DNFSB) had raised concerns about the Operational Readiness Reviews (ORR's) that were
conducted prior to startup in June 1991. In response to the DNFSB recommendations,
Westinghouse Savannah River Company (WSRC) and DOE conducted new reviews to determine
if the facility was safe to start and operate. DOE identified items that required resolution before
restarting the facility. The findings included items such as inadequate conduct of operations, and
inadequate training, qualifications, certification, and oversight by the DOE Savannah River
Operations Office (SR) facility representative, and inadequate audit closure of corrective actions for
restait All findings were corrected and validated as closed by WSRC, DOE-SR, and the DOE-HQ
Office of Nuclear Safety. The DNFSB held a public hearing in Aiken, South Carolina on these
issues in December, 1992. Operations resumed January 7, 1993.
The Energy Research Foundation of Columbia, South Carolina, filed suit against the Department
on January 4, 1993. The complaint sought relief in the form of a declaration that the Department
was in violation of NEPA for failing to prepare an Environmental Impact Statement (eis) for HB-
Line operations and an injunction prohibiting the Department from starting up HB-Line until an
ElS was prepared, circulated for comment, and considered in the decision-making process. In a
settlement agreement dated November 17, 1993, DOE and BRF agreed to the preparation of this
ea to address issues raised by ERF and the future operation of HB-Line.
DOE is currently preparing eiss which are related to operation of the HB-Line. The Waste
Management eis (Draft published January 27, 1995) addresses an SRS strategy for management
of waste resulting from past, current, and future SRS operations. Wastes generated as a result of
the proposed action described in this ea would be considered in the Waste Management eis. The
Interim Management of Nuclear Materials eis (Draft published March 17, 1995) and the F-Canyon
Plutonium Solutions ElS (Final published December 30, 1994) address operations to process any
materials for which the Department has an identified programmatic need and materials that are
determined to represent an unacceptable risk, stored in their current form, to SRS workers, the
public, or the environment.

2.0 PROPOSED ACTION AND ALTERNATIVES

2.1 Proposed Action
The proposed action is for DOE to continue to operate and maintain the Pu-238 processing facilities
at the Savannah River Site (SRS) and process of Pu-238 scrap material into a usable oxide powder
to preserve the capability to support NASA missions. A flight quantity of approximately 32.5 kg
of Pu-238 needs to be processed into a usable product to satisfy current projections of Pu-238
needed to support post Cassini NASA missions as indicated in Table 1-1. Additional quantities
would be required for analytical samples, characterization, and testing. Processing of the Pu-238
purchased from Russia and shipped to SRS in 1994 is included in the proposed action. This five
kg of Pu-238 requires processing because it contains impurities which do not meet DOE's
specification requirements. The proposed action also includes processing approximately 10 kg of
Pu-238 from weapons returns, provided the properties meet the required properties necessary for
use in space power systems. The proposed action does not include disposition of the HB-Line
facility and Frame Waste Recovery process; DOE will prepare additional NEPA reviews when
proposals for decontamination and decommissioning or alternative uses are prepared.
The proposed action includes shipment of Pu-238 scrap material (Pu-238 in forms and isotopic
content that is not usable as heat source fuel without processing) from DOE's Mound Laboratory,
Miamisburg, Ohio (Mound), and the Los Alamos National Laboratory, Los Alamos, New Mexico
(LANL), to the Savannah River Site.
DOE's Office of Nuclear Energy is conducting a study to evaluate the capability of facilities- to
ensure that infrastructure will be in place to support long-term RTG requirements. The study
involves evaluations of LANL, Mound, Oak Ridge, the Idaho National Engineering Laboratory
(INEL), and the Hanford Site. Therefore, storage of Pu-238 at Savannah River prior to shipment
to the appropriate site is considered part of the proposed action evaluated in this BA. Should a new
Pu-238 mission be proposed for Oak Ridge, INEL, or Hanford, or a continued Pu-238 mission
proposed for Mound or LANL, analysis of Pu-238 transportation from the Savannah River Site to
the appropriate site and any required storage at that site would be included in the NEPA review
prepared for that proposal.
Fabrication of the Pu-238 heat source units for NASA's Cassini mission at the Los Alamos
National Laboratory from the plutonium oxide produced at SRS was addressed in an
Environmental Assessment completed in 1991. The ea (DOE, 1991) was the basis for a Finding
of No Significant Impact (FONSI) issued in July 1991.
The proposed action would include operation of the following processes located within the H-Area
Canyon and B-Line Buildings:
- Scrap Recovery Facility (HB-Line Phase I). This facility would be used to dissolve and
blend existing inventories of Pu-238 oxide and Pu-238 scrap materials.
- Plutonium Oxide Facility (HB-Line Phase III). This facility would be used to convert
plutonium nitrate solution to a powder oxide form via a precipitation process.
- Frame Waste Recovery (FWR). This facility located within H-Canyon would be used to
purify the plutonium solutions using an ion exchange process.
- HB-Line Vault. This facility would be used to safely store Pu-238 product material.
- Transportation of scrap Pu-238 material from DOE Mound Plant and Los Alamos National
Laboratory to the Savannah River Site.

2.2 Alternatives to the Proposed Action

2.2.1 No Action
Under the no action alternative, the Pu-238 processing facilities would continue to operate until
completion of the campaign for the Cassini mission, estimated to be completed by June 1995.
Once this mission had been fulfilled, operation of these facilities to support Pu-238 processing
would be terminated. This alternative does not allow for the processing of material for future use
as a heat source in RTGs or RHUs.

2.2.2 Alternative Processing Facility
This alternative would involve processing Pu-238 material in facilities other than HB-Line. Except
as discussed below, because no other such facilities currently exist construction of new facilities
would be required. Because this would be very costly, and because process efficiency or safety of
the technology incorporated in the HB-Line facilities would not be improved upon, this is not
considered a reasonable alternative.

2.2.3 Alternative Vault Storage Facility
This alternative would involve using an SRS vault other than the HB-Line vault for storage of
processed Pu-238. DOE investigated three existing SRS vaults, all located in F-Area: the Building
247-F vault, vaults in Building 235-F, and the Plutonium Storage Facility located in the F-Canyon.
Each of these facilities would require extensive modification to accommodate storage of Pu-238,
including installation of equipment for cooling the storage containers. The HB-Line vault is.
currently fully capable of storing Pu-238; therefore DOE does not consider modification of other
facilities a reasonable alternative.

2.2.4 Processing at the National Laboratories
In the United States (U.S.), only the SRS has a current capability to chemically process Pu-238
into the usable specification oxide powder form. The Los Alamos National Laboratory (LANL)
has proposed adding the capability to conduct small scale Pu-238 processing for scrap recovery in
the existing plutonium handling facility. New equipment and facility modifications, followed by
extensive testing and demonstration, would be required prior to the commencement of Pu-238
processing at LANL. A new Pu-238 processing capability at LANL would be limited to
approximately 100 to 300 grams per month, compared to SRS's 2000 to 4000 grams per month
capacity. Due to the necessary equipment procurement and facility modifications, testing and
demonstration requirements, start-up approvals, and limited capacity for Pu-238 processing at
LANL, this alternative could delay the availability of specification Pu-238 for use in projected
mission applications, and is not considered by DOE to be a reasonable alternative to completing the
processing of the U.S. Pu-238 inventory at SRS using existing, operating facilities.

2.2.5 Purchase of Pu-238 from Foreign Nations
This alternative would involve purchasing Pu-238 from foreign nations rather than processing the
U.S. Pu-238 inventory into specification oxide powder using SRS facilities. Discussions with
France and Great Britain have concluded that kilogram quantities of Pu-238 could be made
available by these countries sometime after 1999, but only after significant investment in new
facilities. The U.S. has a contract in place with Russia for the purchase of up to 40 kg of Pu-238
through 1997. The U.S. purchased the first 5 kg of Pu-238 under this contract in 1994. This first
5 kg is in storage at the SRS pending processing as part of this proposed action. The necessary
approvals and funding have been received for a second purchase of approximately 4 kg. DOE
expects to complete this second purchase in early 1995. The Pu-238 oxide powder in the second
purchase should not require chemical processing in U.S. facilities prior to use in fuel pellet
fabrication operations. Funding for additional purchases of Pu-238 is not included in the planned
DOE budgets for fiscal years 1995 and 1996. Due to these budgetary limitations, DOE does not
anticipate purchasing any further Pu-238 from Russia under the existing contract which expires in
1997. Therefore, the foreign purchase alternative is not considered viable if DOE is to be
responsive to NASA's requirements as they develop in the near term. The existing U.S. Pu-238
inventory needs to be processed into a usable form to support post Cassini NASA missions as
indicated in Table 1-1.

2.2.6 Alternative Packaging and Storage of Pu-238
Under this alternative, the pu-238 processing facilities would continue to operate until completion
of the campaign for the cassini mission, estimated to be completed by june 1995. Once this
mission had been fulfilled, these facilities would operate to stabilize pu-238 scrap material stored at
the srs to meet the long-term storage criteria for plutonium (doe, 1994). The pu-238 scrap could
generally be stabilized by simply heating and repackaging the material. This would consist of a
glovebox being added to an existing or new facility (i.E., Proposed actinide packaging facility) to
heat plutonium oxide and to package oxide and metal in a non reactive atmosphere without the use
of plastic wrapping. The packaged material would then be placed in a srs vault. This alternative
would ensure that material remaining at the SRS would meet the long-term storage criteria;
however, this alternative alone is not considered if DOE is to be responsible to NASA's
requirements.

3.0 OPERATION DESCRIPTION
The plutonium processing facilities are located on top of the H-Area Canyon Building 221-H
(Figure 3-1) and include the Scrap Recovery Facility (Phase I) and the Plutonium Oxide Facility
(Phase III). The Frame Waste Recovery process is located within the 221-H building. The HB-
Line facility also houses a vault for the storage of Pu-238 oxide product and scrap material. A
material flow diagram for the Pu-238 operations descnbed in this section is given in Figure 3-2.
H-Area is depicted in relation to surrounding areas in Figure 4-1.
The HB-Line facility proposed for operation under this action was built on top of the Canyon in the
early 1980s, replacing an existing facility located on the 3rd and 4th levels of the H-Canyon. The
HB-Line facility operated between 1985 and 1987. Operations in the HB-Line facility to fulfill the
Cassini mission requirements resumed in July 1991.

3.1 Facility Description
The canyon building is a blast resistant reinforced-concrete structure, 835 feet long, 122 feet wide,
and 66 feet high, with 52 feet extending above grade. Processing equipment is isolated from the
operating personnel, the environment, and the public in two parallel canyons (hot canyon and
warm canyon) 15 feet wide at the bottom and 30 feet wide at the top, separated by a central
operating and service section. The HB-Line facilities were constructed on top of the H-Canyon
building and the Frame Waste Recovery process occupies a small area within the hot canyon of the
H-Canyon building. A figure of the canyon building including HB-Line is provided below in
Figure 3-1. Figure 3-2 is a Pu-238 material flow diagram

3.1.1 HB-Line Facilities
The facilities were designed incorporating the lessons learned from over twenty years of operating
experience. The HB-Line Facility incorporates improvements in engineering controls for nuclear
safety; cabinet integrity and engineered barriers to minimize potential for personnel exposure to
Figure 3-1. H-Canyon Building and HB-Line Facilities.
Figure 3-2. Pu-238 Material Flow Diagram
airborne contamination; shielding and remote operations to decrease radiation exposure; and
equipment and ventilation design. Confinement and shielding are provided by glove boxes, which
are exhausted through two stages of independently testable High Efficiency Particulate Air (HEPA)
filters. Process service systems (electrical, air, water, HVAC, and instruments and controls) are
designed with engineered features (fail-safe, redundancy, multiplicity) to prevent the escalation of
possible abnormalities.
The processing of Pu-238 begins with dissolving Pu-238 oxides in various forms. This takes
place in the Scrap Recovery Facility in what are called "glove boxes". The glove box sections
contain the charge preparation areas, valves, product filters, most of the piping, and other
miscellaneous equipment. Glove boxes are cabinets constructed of stainless steel-lead-water-
stainless steel with acrylic/lead glass windows. Operators have access through glove ports such
that the operator never breaches containment of the glove box and process area. The glove ports
have also been designed to allow replacement of the gloves with a much reduced chance of
breaching containment. While working in the glove boxes, all operators and personnel in the
process rooms are required to wear protective clothing and respiratory protection as an additional
precaution against external and internal contamination.

3.1.2 Frame Waste Recovery Process
The Frame Waste Recovery process is located within the H-Canyon "hot canyon" where the more
highly radioactive, remote operations are carried out. The process consists of a column feed tank
which receives solutions from the Scrap Recovery facility, an ion exchange column, and a product
hold tank from which solutions are sent to the Plutonium Oxide facility.

3.1.3 HB-Line Vault
The storage vault, located in 221-H in the HB-Line facility, is constructed with reinforced concrete
walls, ceilings, and floors. The vault has stainless steel product storage tanks which house storage
locations in a critically safe array for product containers. These stainless steel takks contain water
to cool the stored containers. The water is then cooled by the HB-Line cooling water system. The
HB-Line cooling water system is a non-contact internal recirculating "loop" which is independent
of any other cooling water system.
The vault complies with the requirements of DOE Order 5632.2A, Physical Protection of Special
Nuclear Material and Vital Equipment. Vault security features include two independent door locks,
card reader personnel accountability system, door tamper indications, motion detectors, and
cameras. The vault contains ceiling mounted smoke detectors which are designed to automatically
activate and release the fire suppression system and shut down the ventilation exhaust upon
actuation. The vault also contains a set of Nuclear Incident Monitors for detection of a nuclear
incident and actuation of an alarm bell to alert personnel.

3.2 Processing Description

3.2.1 Scrap Recovery Facility (HB-Line Phase I)
Figure 3-3 pictures a simplified flow diagram for processing Pu-238 through HB-Line and the
Frame Waste Recovery Unit. The processing of Pu-238 begins with dissolving Pu-238 scrap in
various forms. This takes place in the Scrap Recovery Facility in what are called "glove boxes
The oxide feed material is removed from its unique container inside the glove box and put into a
dissolver. The scrap oxide is dissolved with nitric acid and a fluoride catalyst. The resulting
nitrate solution is then filtered and sent to a hold tank before being transferred to the Frame Waste
Recovery unit in the H-Canyon.

3.2.2 Frame Waste Recovery (FWR) Process
The purpose of the Frame Waste Recovery (FWR) system is to purify and concentrate Pu-238 for
processing and to transfer the associated waste solutions to the waste tanks.
Solutions entering the remotely operated FWR process are chemically adjusted with nitric acid
(HNO3), ferrous sulfamate, and hydrazine in the column feed tank. The plutonium is then
oxidized by heating the solution to a temperature between 50-60 C for thirty minutes.
The adjusted solutions are then pumped through an ion exchange column where Pu-238 is
adsorbed onto the resin. The resin bed is washed with nitric acid to remove fission products and
chemical impurities. The Pu-238 is then removed from the resin column and sent to a hold tank
until transferred to the Plutonium Oxide Facility for further processing.
Acid solutions containing the fission products and chemical impurities from the resin column are
evaporated to recover the acid. The concentrated unevaporated solutions are neutralized and
transferred to the 241-H Tank Farm Facility as radioactive liquid waste. Table 5-4 provides the
volume estimates for this waste stream.

3.2.3 Plutonium Oxide Facility (HB-Line Phase III)
The purified Pu-238 solution from FWR is then returned to the Plutonium Oxide Facility for
processing into an oxide. The nitrate solution is adjusted with ascorbic acid and hydrazine. The.
adjusted nitrate solution is then added to the oxalic acid in a precipitator to precipitate the Pu-238.
The precipitated Pu-238 is filtered and washed using in-line filter boats. The filter boat containing
the oxalate cake is then transferred to the calcining furnace. The oxalate cake is then calcined using
ultra-pure oxygen-16 to reduce neutron emissions from the oxide. The powder is then loaded into
a stainless steel shipping container for transfer to LANL for use in fuel pellet fabrication
operations.

3.3 Management & Operation
The HB-Line facility and FWR are managed and operated by the Westinghouse Savannah River
Company (WSRC) under contract to DOE. Operation of the facilities is conducted in accordance
with requirements established by DOE Orders. The Department of Energy uses DOE Orders to set
standards, criteria, and requirements for operation of its facilities in compliance with regulations
and law. WSRC then implements the DOE Orders through formalized procedures. The facilities
are periodically reviewed and assessed against these requirements by the Savannah River
Operations Office (SR), the Energy Department's Office of Environment, Safety and Health (EH),
and independently of DOE by the Defense Nuclear Facility Safety Board (DNFSB).

3.4 Description of Transportation Activities
The proposed action includes receipt of scrap plutonium oxide shipments from Mound and Los
Alamos National Laboratory (LANL). A maximum of 10 and 35 kilograms of material would be
received from Mound and LANL, respectively (Jacobson 1994a). These quantities include up to
10 kg of weapons return Pu-238 from LANL. Product Pu-238 oxide would be stored at SRS
(Jacobson 1994b).
Shipment of scrap Pu-238 material to the Savannah River Site would be made by DOE
Albuquerque Operations Office's Transportation Safeguards Division (TSD). The shipments
would be made in accordance with U. S. Department of Transportation regulations (49 CFR 171 -
179) and DOE Orders.
Figure 3-3. Pu-238 Process Flow Diagram.
Pu-238 material would be shipped in Type B containers carried in Safe Secure Trailers (SSTs)
operated by TSD. The material to be shipped would be packaged in Department of Transportation
(DOT) Type B containers prior to shipment. The Type B shipping containers expected to be used
for shipments under the Proposed Action are the "5320" container (Jacobson 1994a, 1994b)
although the Type B Mound "1KW" container may be used (Jacobson 1994a). The SST
transporting the Pu-238 would be accompanied by gnarded escort enroute and its traveling times
are limited, thereby minimizing the occurrence of potential accidents.
The DOE-TSD safety standards effectively minimize the probability of accidents. DOB-TSD has
never experienced an accident causing a fatality or release of radiological material in over 70 million
miles of highway transport; the DOE-TSD safety record is several times better than that of the
commercial trucking industry (DOE, 1993). Shipments of materials are constantly monitored and
tracked to ensure prompt attention and proper notification of authorities in the event of an accident.
If an accident should occur, drivers are trained to make a preliminary assessment of the situation.
If necessary, radiological assistance teams are available to help mitigate consequences of the
accident.

4.0 AFFECTED ENVIRONMENT
A comprehensive discussion of SRS and environs is presented in the Reactor Operation
Environmental Impact Statement (DOE, 1990a), and in the Reactor Operation Environmental
Information Documents, Volumes I, II, & Ill (WSRC, 1989a; WSRC, 1989b; WSRC, 1989c).
The affected environments highlighted below are those areas that are most likely to be impacted by
the proposed action.

4.1 Geography, Demography, and Socioeconomics
The SRS encompasses approximately 773 square kilometers (300 square miles) adjacent to the
Savannah River principally in Aiken and Barnwell counties in southwestern South Carolina, In
1990, the population of the six counties surrounding the SRS was 425,607 including a work force
of 208,984. Approximately 20,000 SRS workers, or about 9 percent of the available regional
work force live in the six-county area. The most recent socioeconomic survey of the six-county
SRS area of influence (NUS, 1992) contains additional information.
The HB-Line and FWR facilities are located in H-Area on the Savannah River Site. Fignre 4-1
shows H-Area in relation to SRS boundaries and the surrounding areas.

4.2 Radiation Environment
Natural radiation sources contribute about 315 mrem per year, or 83 percent of the annual radiation
dose of 380 mrem received by the average individual residing in the SRS regional area from all
sources. Other contributions to individual radiological dose are from medical applications and
consumer products which contribute 54 mrem (14 percent) and 10 mrem (3 percent), respectively.
The SRS total radiation dose contributes less than one percent of the total annual dose received by
the maximally exposed individual (WSRC, 1993a).

4.3 Waste Management
The SRS generates liquid, solid, and semisolid wastes originating in reactor and support facility
operations, maintenance, and renovation. This BA describes the wastes that would be generated as
a result of implementation of the proposed action and the potential impacts of those waste streams
on existing SRS waste management capabilities. NEPA review of SRS waste management
activities has been and currently is being prepared separate from this ea. On April 6,1994, DOE
its intent to prepare an eis to address the generation, minimization, treatment, storage,
and disposal of high-level, low-level, transuranic, mixed, and hazardous waste at the SRS. The
Draft Savannah River Site Waste Management ElS (DOE, 1995) was published on January 27,
1995. DOE prepared an eis on the Defense Waste Processing Facility (DWPF) in 1982 (DOE,
1982) and published a Supplemental DWPF ElS on November 24, 1994 (DOE, 1994a) to address
system changes that have been implemented since 1982 and their environmental impacts. These
eiss address the management of waste streams including those that would be generated as a result
of the proposed action described in this ea.

5.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION

5.1 Normal Facility Operations
The environmental consequences presented below represent the expected annual impact of
operating HB-Line and the Frame Waste Recovery unit.

5.1.1 Socioeconomics
The HB-Line is an existing facility that has been operating in several stages since 1985. Since no
modernization, construction activities, or additional employees would be required to implement the
proposed action, the only socioeconomic impact would be from the operational and maintenance
personnel required to run the facility. Present plans call for approximately 200 operational and
support employees to operate and support HB-Line Phases I & III and the Frame Waste Recovery
unit. These employees are part of the existing SRS operational work forces and are now working
to complete the Pu-238 fuel processing requirements for the Cassini mission. SRS currently
employs approximately 20,000 workers. Because no socioeconomic impacts are expected as a
result of the proposed action, no differential impacts on minority or low income communities
would result.

5.1.2 Ecology and Cultural Resources
No ecological or cultural resource impacts would be expected from the proposed action. The new
HB-Line facility was constructed in 1985 and is part of a previously developed and highly
industrial area. As a result, no endangered species, wetlands, cultural resources or other
environmentally sensitive resources will be directly or indirectly impacted by the proposed action.

5.1.3 Air Emissions
Processing Pu-238 results in releases of both radiological and non-radiological pollutants. The
non-radiological pollutants are nitric acid, nitrogen oxides (NOx), di-nitrogen oxide (N20),
hydrogen fluoride (HF) and carbon monoxide (CO). Table 5-1 lists the estimated emissions for
these non-radiological pollutants per gram of Pu-238. The estimated totals are also provided and
are based upon current mission requirements from Table 1-1.
Estimated annual atmospheric radiological releases typical of HB-Line operation are shown in
Table 5-2. The estimate is based on 1993 actual emissions from the 291-H stack (WSRC, 1993b).
Methods and models used for dose calculations are provided in the SRS Environmental Report
(WSRC, l993a). Since this is the emission source for H-Canyon (including Frame Waste
Recovery) in addition to the HB-Line facilities, the estimate is considered typical for normal
0peration. The cumulative SRS atmospheric dose including operation of HB-Line and FWR
would be less than 3% of the DOE annual limit of 10 mrem (DOE 1990b). The effects of
rddiological dose are analyzed in Section 5.3.
Figure 4-1. Operational Areas on SRs.
The 221-H and HB-Line ventilation systems control the spread of radioactive material~to clean
areas by constantly pulling air from areas of lower contamination to areas of higher contamination.
This air is filtered and then released through the 291-H stack. These building ventilation systems
would remain operational independent of Pu-238 production needs. Therefore, emissions from the
291-H stack would continue to contribute to the off-site dose from SRS. Under the "No Action"
alternative, emissions for HB-Line processing would continue until completion of the Cassini
mission, estimated to be completed by June 1995, with emissions dropping off slightly after this
when operations to support the Cassini mission would cease.
Table 5-1
Non-Radiological Air Pollutants for Processing Pu-238
Estimated Total based on
Pollutant Estimated Actual mission requirements(1)
(lbs/g Pu-238) (Total lbs)
Nitric Acid 4.49 x 10-05 2.33 x 10 0
HF 7.85 x 10-07 4.08 x 10-02
NOx (Total) 9.59 x 19-04 4.99 x 10+01
NO2 5.82 x 10-04 3.03 x 10+01
N20 3.77 x 10-04 1.96 x 10+01
CO 2.38 x 10-02 1.24 x 10+03
(1) An estimated 52 kg is currently available for processing
Table 5-2
Atmospheric Radiological Emissions
Maximally Exposed DOE
Offsite Individual Dose Umit
[mrem/year] [mrem/year]
H-Area Main Stack 0.005 N/A(1)
SRS Total 0.229 10
(1)Limit applies to the entire site release and not to each source.

5.1.4 Surface Water Effluents
Estimated annual liquid releases typical of HB-Line operation are shown in Table 5-3. The
estimate is based on 1993 actual emissions from H-Area (WSRC, 1993b). Methods and models
used for dose calculations are provided in the SRS Environmental Report (WSRC, 1993a). Since
several facilities drain into the same outfall it is difficult to isolate the contribution from only the
HB-Line and FWR facilities. Therefore, the estimated dose from H-Area is considered to be
bounding since it includes other facilities. The total SRS cumulative dose from water pathways
would remain less than 1% of the DOE annual dose limit of 4 mrem through water pathways. The
effect of radiological dose to individuals is discussed below in Section 5.3.
Effluent from Building 221-H from normal operation of HB-Line and FWR generally includes
rainwater runoff, non-process cooling water, and condensate from steam lines or from
Heating, Ventilation and Air Condition (HVAC) systems. Liquid effluents associated with the H-Canyon building
are currently permitted by the South Carolina Department of Health and
Environmental Control (SCDHEC) under the National Pollution Discharge Elimination System
(NPDBS) permit number SC0000l75.
Table 5-3
Liquid Radiological Effluents
Maximally Exposed DOE
Offsite Individual Dose Limit
[mrem/year] [mrem/year]
H-Area 0.0017 N/A(1)
SRS Total 0.0308 . 4
(1)Limit applies to the entire site release and not to each source.

5.1.5 Worker Health Effects
HB-Line and FWR worker exposures to radiation under normal operations would be controlled
under established procedures that require doses to be kept As Low As Reasonably Achievable
(ALARA) and limit any individual's dose to less than 5 rem per year. WSRC has placed further
administrative limits on worker dose to 1.5 rem/year (WSRC, 1992a). Based on operations in
1993 and a maximum of 200 workers, DOE expects that the average annual dose for HB-Line
facility radiation workers (operators, mechanics, health physics inspectors,. support personnel etc.)
from the proposed action would be less than 0.5 rem per year. The cumulative worker dose would
not exceed 100 person-rem per year (WSRC, 1993c). Under normal operation, based on an
occupational risk factor of 4 x 10A fatal cancers per person-rem (NRC 1991), workers engaged in
the operation of HB-Line and the Frame Waste Recovery would not be expected to incur any
harmful health effects from radiation exposures they receive.
Other worker health effects would be exposures to chemical hazards. There are no chemical
hazards associated with cold feed preparation and storage so long as the chemicals remain within
the confines of the intended vessels and piping. Unconfined, the hazards are toxicity, corrosion,
fire, and carcinogenicity.

5.1.6 Waste Management
Processing of Pu-238 oxide results in the generation of low-level radioactive solid waste (LLW),
transuranic (TRU) waste (including mixed TRU waste), and radioactive liquid waste. Liquid
waste would be transferred to the 241-H waste tank where it would be stored until it can be
converted to borosilicate glass and saltstone. Waste generation rates for current HB-Line and
FWR operations, which are expected to continue if the proposed action is implemented, are shown
in Table 5-4.
DOE recently issued the Final Supplemental eis for the Defense Waste Processing Facility (DOE,
1994a). A Record of Decision was issued on March 28, 1995, in which DOE describes the
decision to complete construction and startup testing and operate the Defense Waste Processing
Facility as currently designed. This decision means that liquid radioactive waste generated as a
result of the proposed action described in this ea would be transferred to the 241-H waste tank for
storage prior to processing in the Defense Waste Processing Facility. As shown in Table 5-4, the
current inventory of liquid waste awaiting processing in the DWPF is about 34,600,000 gallons,
and continuing SRS operations (including HB-Line and FWR operations) are expected to generate
an additional 5,810,000 gallons over the next 30 years (DOE, 1995). The environmental impacts
of processing this liquid waste in the DWPF and associated facilities are fully described in DWPF
Final Supplemental eis (DOE, 1994a). Because the waste generated by the proposed action
represents a small fraction of the total, and because the liquid waste has the same characteristics
and would be managed in the same manner, the incremental environmental impacts resulting from
the proposed action would be a small fraction of the impacts resulting from management of the
current and forecasted SRS liquid waste inventory.
DOE recently issued the Draft eis on Waste Management at the Savannah River Site (DOE, 1995).
The Draft eis describes alternatives for management of the current and projected inventory of
waste types at the Savannah Site, including waste that would be generated as a result of the
proposed action described in this ea. The eis describes the environmental impacts of the
construction and operation of the specific treatment, storage, and disposal facilities proposed in
each of three management alternatives: Limited Treatment, Moderate Treatment, and Extensive
Treatment. In addition, the eis describes the impacts of managing minimum, maximum, and
expected (best estimate) quantities of waste by waste type for each management alternative. Table
5-4 shows the volumes of low-level solid waste and TRU waste that would be generated by the
proposed action described in this ea, and compares them to the expected inventory of the same
types of waste requiring management as described in Draft Waste Management ElS. Because the
waste generated by the proposed action represents a small fraction of the total, and because the
low-level solid and TRU waste has the same characteristics and would be managed in the same
manner, the incremental environmental impacts resulting from the proposed action would be a
small fraction of the impacts resulting from management of the current and forecasted SRS low-
level solid and TRU waste inventory.
Table 5-4
HB-Line, FWR and Forecasted Waste Generation
HB-Line, FWR Inventory and Management
WASTE TYPE GENERATION Forecasted FACILITY
Generation
Low-Level Solid^[a] 11,000 ft^3/yr 51,000,000 ft^3^c Solid Waste
Disposal Facility
TRU Waste^[a] 2,000 ft^3/yr 972,200 ft^3^c TRU Waste Storage
Pad
Liquid Waste^[b] 2,290 gal/kg 34,600,000 gal^c 241-H Waste Tank
Pu-238 5,810,000gal^d DWPF,Saltstone
Facility
[a] December 1993 Facility Solid Waste Generation Report (Lambert, 1994).
[b] Frame Waste Recovery waste volume estimates (Pickett, 1991).
[c] Expected Case 30 year waste generation estimate, including Current inventory
(DOE, 1995)
[d] Expected Case 30-year waste generation estimate (DOE, 1995)

5.2 Accident Analysis
Accident analysis methodology, assumptions, and source terms are provided in detail for the Scrap
Recovery Facility (Phase I) and the Plutonium Oxide Facility (Phase III) in the Safety Analysis
Report (SAR) (DuPont, 1991) and the Justification for Continued Operation (JCO)
(WSRC, 1992b, WSRC, 1994a). Information in the SAR has been simplified in the discussions
presented in this ea. Calculations were recently updated to provide the co-located worker, on-site
population, and off-site population doses for this assessment based on the new meteorological and
population databases (DelGenio, 1994a; DelGenio, 1994b). The updated analysis shows that
accident consequences remain within the authorization basis outlined in the SAR and JCO. This
was expected since the effects of the new meteorological and population databases on the calculated
results has been previously evaluated and found generally to lower the estimated dose consequence
(Huang and Hang, 1993).
Accident analysis methodology, assumptions, and source terms are provided in detail for the
Frame Waste Recovery Unit in the H-Canyon SAR (DuPont, 1986) and consequences have been
re-evaluated for Frame Waste Recovery with revised source terms and frequencies in Addendum 4
(WSRC, 1994b). The Addendum incorporates new source terms, meteorological and population
databases, and new receptors. The evaluation considers the following accidents:
Frame Waste Recovery HB-Line
Earthquake Earthquake
Externally induced Failures Externally Induced Failures
Criticality Criticality
Fire Fire
Uncontrolled Reaction Uncontrolled Reaction
Transfer Error Transfer Error
Overflow Overflow
Leak Leak
Coil and Tube Failure
Residual activity releases, although abnormal and analyzed in the SARs, are expected and do occur
throughout the year. Since these are accounted for in the measured yearly releases due to normal
operation these incidents are not analyzed in this section. For doses due to normal operation which
include residual releases throughout the year see Section 5.1.
Accident consequence calculations do not take credit for any mitigating actions or systems such as
operator response or redundant process controls. The only preventive actions or systems
considered in the accident analyses are safety related systems and their automatic operation.
Accident mitigation systems for which credit is taken are:
- the passive containment of the building and ventilation system structure if the ventilation
system fans fail, or
- the ventilation ducts and sand filter if the canyon ventilation fans continue to operate. The
accident analysis assumes the ventilation system fails completely for a point strike tornado
or an earthquake.
The offsite doses and onsite population dose is calculated using 99.5 percentile meteorology using
the new 1987-1991 meteorology database. The word percentile is a statistical term applied to a
normal distribution of observable weather conditions. The co-located worker doses are evaluated
for an individual 640 meters from the release point at 50 percentile meteorology. The distance of
640 meters from the release point is the threshold distance which differentiates an exposed person
as either a co-located worker or a facility worker. A co-located worker is defined as a person who
is located at a distance equal to or greater than 640 meters. The impacts to facility (involved)
workers were determined through a qualitative analysis and are shown in Table 5-5. The 1994
population was estimated from 1990 census data and 1992 onsite population database. Doses
provided below represent 50 year committed effective doses. Fifty year committed effective dose
refers to the resultant cumulative dose up to 50 years following the exposure.
Consequences to facility workers have been evaluated on a qualitative basis (Heal et al., 1995).
Facility workers are typically in close proximity to operations and are the populations principally at
risk from potential consequences associated with facility hazards. Programmatic commitments,
such as policies, programs, and procedures in addition to facility design features have been
developed to protect facility workers. Emphasis has been placed on the integration of various
regulation design codes, and programs into a Process Safety Management Program. Safety
management programs ensures facility safety on a day-to-day basis through (1) adequate level of
worker safety from routine industrial hazards, (2) adequate level of worker and public safety from
normal operational releases and exposures, and (3) adequate level of worker and general public
safety from postulated accidental releases of radioactive and chemical hazardous material.
Safety management is a abroad discipline covering several topics, from hazard identification and
assessment to hazard control that are related to worker safety include criticality protection, radiation
protection, hazardous material protection, training, conduct of operations, and emergency
preparedness. Protection against process hazards is provided by distance, shielding and
confinement barriers.
A qualitative analysis has been performed on the hazards to which facility workers are exposed.
The results from this qualitative analysis are summarized along with the results from the
quantitative analysis performed for the maximum off-site individual, on-site worker, the off-site
population, and the on-site population.

5.2.1 HB-Line Facilities (Phases I and III)
Table 5-5 summarizes the qualitative hazards to facility workers. Table 5-6 through Table 5-8
summarize the accident scenarios which result in the highest doses from the Scrap Recovery
Facility and Plutonium Oxide Facility in HB-Line. The consequences provided below are for
failure of both HEPA stages. A description of the events follows.
A medium energetic event is one which will cause penetration of the primary confinement barrier
and bypass of the secondary barrier for a short period of time (e.g., vessel penetrated and cabinet
temporarily breached). The following medium energetic events were analyzed: cabinet fire,
uncontrolled reaction, and criticality. The expected frequency for a medium energetic event is the
sum of the frequencies for each event. The frequencies for fire and uncontrolled reaction are based
on the historical average for these events in the "old" HB-Line. Pu-238 processed in HB-Line
must be within specific isotopic limits consistent with the ANSI Standards fro Special Actinide
Elements subcritical limit. This limit is included in the HB-Line Operational Safety Requirements.
The significant decay heat generated by Pu-238 precludes the assembly of a critical mass of the
isotope. Administrative controls are established in HB-Line on Pu-238 quantities, and the
impracticality of assembling the isotope in quantity renders criticality an incredible event.
A low energetic event is one which may cause penetration of the primary confinement barrier
(vessel). The following low energetic events were analyzed: process equipment leaks, transfer
errors, overfiows, and spills. The expected frequencies are also based on the historical average of
events occurring in the "old" HB-Line and are also considered conservative when applied to the
existing HB-Line facility.
A propagated fire is a fire that spreads uncontrollably throughout the facility.
Table 5-5
Facility Worker Qualitative Hazard Evaluation
-------------------------------------------------------------------------------------
Area Hazard Frequency Potential Impact
-------------------------------------------------------------------------------------
Scrap Recovery Small Fire A Minor
Process
Large Fire U Considerable injury
or even death
Explosion in Dissolver A Considerable impact
-large quantity Pu-
238 in dissolver
Hydrogen Explosion in Filtrate U Minor
Tank
Hydrogen Explosion in Product U Considerable impact-
Hold Tank large quantity Pu-
238 in hold tank
Air Reversal A Minor
Leaks A Minor
Dropped Container A Minor
Overflow of Process Vessel A Considerable impact-
Moderate quantities
radioacnve waste
released
Overflow of Chemical Hold Tank A Minor
Uncontrolled Chemical Reaction A Minor
Punctured or Damaged Glove A Minor
Plutonium Oxide Small Frre A Minor
Process
LargeFrre U Considerable impact-
up to batch quantities
Pu-238
Air Reversal A Minor
Punc~ or Damaged Glove A Minor
Inadvenent Criticality I Considerable impact
or even death
Waste Handling Line Small Kue A Minor
Dropped Container A Minor
HB Line Building Lightning Strike to Building A Minor
Criticality in Vault I Considerable injury
or even death
Earthquake U Considerable injury
or even death
Tornado U Minor
-------------------------------------------------------------------------------------
A=Anticipated=greater than 1 x 10e-2 event year.
U=Unlikely=between 1 x 10e-2 and 1 x 10e-4 events per year.
I=1ncredibl=~iess than 1 x 10e-6 events per year.
-------------------------------------------------------------------------------------
Table 5-6
Maximum Accident Dose Summary
Scrap Recovery Facility
SCRAP RECOVERY Maximum
off-site On-Site
Frequency Risk[1] Individual Worker[2]
Accident (per year) (mrem/yr) (mrem) (mrem)
Propagated Fire 0.0044 0.594 135 250
Medium Energetic Event 0.0037 0.0435 11.8 21.8
Earthquake 0.00017 0.00214 12.6 101
Low Energetic Event 0.21 1.23 5.87 10.9
[1]Risk for the Maximum Off-Site Individual. Risk is obtained by multiplying the dose by the
frequency.
[2] Dose to a worker 640 meters from the stack at 50 percentile meteorology.
Table 5-7
Maximum Accident Dose Summary
Plutonium Oxide Facility
PLUTONIUM OXIDE Maximum
offsite On-Site
Frequency Risk^[1] Individual Worker^[2]
Accident (per year) (mrem/yr) (mrem) (mrem)
Propagated Fire 0.0066 0.304 46.0 85.0
Medium Energetic Event 0.0007 0.00297 4.24 7.85
Earthquake 0.00017 0.00073 4.3 34.4
Low Energetic Event 0.06 0.0126 0.210 0.389
[1] Risk provided in the Table 5-7 is for the Maximum Off-Site Individual. The Risk is obtained by multiplying the
dose by the frequency.
[2] Dose to a worker 640 meters from the stack at 50 percentile meteorology.
Table 5-8
HB-Line (Phases I and III) Maximum Accident Dose to Populations
PHASE I PHASE 111
SCRAP RECOVERY PLUTONIUM OXIDE
off-site On-site off-site On-site
Population Population Population Population
Accident (person-rem) (person-rem) (person-rem) (person-rem)
Propagated Fire 1,210 418 324 112
Medium Energetic Event 143 49.2 51.4 17.7
Earthquake 77.4 46.3 20.7 12.4
Low Energetic Event 71.1 24.5 2.55 0.879

5.2.2 Frame Waste Recovery (FWR)
Table 5-9 summarizes the hazardards to workers from Frame Waste Recovery process operation.
Presented in Tables 5-10 and Table 5-11 is a summary of the maximum doses resulting from
accident scenarios in the FWR Unit. The maximum consequences are derived from maximum
source terms and are therefore considered bounding in estimating off-site dose. Since the
frequencies and the release values are calculated means, it is inappropriate to apply these mean
frequencies to maximum consequences. However, although not a realistic estimate, the mean
frequencies are a conservative estimate for defining the beginning of the frequency range for a
given accident. The frequencies for a Maximum Fire and Maximum Transfer Error were analyzed
more closely and more appropriate frequencies were calculated (WSRC, 1994b).
Table 5-9
Facility Worker Qualitative Hazard Evaluation
Area Hazard Frequency Potential Impact
Frame Waste Puncture wound from Considerable injury or
Recovery sample needle even death
Sample vial of A Considerable impact to
radioactive material is facility worker
dropped
Failure to apply A Considerable impact to
process air after facility worker
completion of a
solution transfer
A=Anticipated = greater than 1x10-2 event per year
Table 5-10
Maximum Accident Dose Summary
Frame Waste Recovery Facility
Maximum
offsite On-Site
Frequency Risk^[1] Individual Worker^[2]
Accident (per year) (mrem/yr) (mrem) (mrem)
Earthquake 0.000200 0.220 1,100 1,090
External Impact <=0.00876 <=0.141 16.0 29.8
Fire <=0.0000211 <=0.00639 303 562
Uncontrolled Reaction <=0.0790 <=2.5 31.6 58.6
TransferErrortoSump <=0.0810 <=1.3 16.0 29.8
Transfer Error to Outside <=0.000404 <=0.271 672 1,250
Overflow <=0.248 <=3.97 16.0 29.8
Leak <=0.576 <=7.83 13.6 25.1
Coil&TubeFailure <=0.0150 <=4.35 290 N/A^l2]
[1]Risk is for the Maximum Offsite Individual. Risk for other population groups can be obtained by
multiplying the dose by the frequency.
[2]There are no on-site receptors for this release pathway.
Table 5-11
Frame Waste Recovery Process
Maximum Accident Dose to Populations
Frequency Off-site Population On-site Population
Accident (per year) (person-rem) (person-rem)
Earthquake 0.000200 9,030 5,490
External Impact <=0.00876 192 67.5
Fire <=0.0000211 3,630 1,270
Uncontrolled Reaction <=0.0790 31.6 133
Transfer Error to Sump <=0.0810 192 67.5
Transfer Error to Outside <=0.000404 8,050 2,820
Overflow <=0.248 192 67.5
Leak <=0.576 162 57.0
Coil&TubeFailure <=0.0150 7,600 N/A^[1]
(1]There are no on-site receptors for this release pathway.
The maximum dose in operating the Frame Waste Recovery Facility occurs in the event of a 0.2g
earthquake. This is an extremely low probability event, and therefore the risk (dose times
frequency) is less than that for higher frequency, lower dose events.

5.2.3 Onsite (SRS) Transportation Accidents
Consequences and risks to the off-site public and on-site population from potential accidents
during on-site transportation of radioactive materials have been analyzed in Safety Analysis -
Evaluation of Accident Risks in the Transportation of Hazardous Materials by
Truck and Rail at the Savannah River Site (WSRC, 1989d). The accident with the highest
risk and the highest dose was found to be a breach or puncture of a transuranic waste drum. The
most frequent accident was calculated to be an accidental release to the atmosphere from a low level
waste trailer. The doses and frequencies are summarized in Table 5-12.
Table 5-12
Onsite Transportation Accident Summary
Maximum
Offsite Offsite Onsite
Accident Frequency Individual Population Population
(per year) (mrem) (person-rem) (person-rem)
Breacho TRU Drum
(highest consequence) 0.00003
Low Level Waste Trailer 0.10 0.000089 0.00030 0.000051
Atmospheric Release
(most frequent)

5.2.4 Incident-Free Off-site Transportation
DOE analyzed both incident-free and accident radiological impacts for the shipping of plutonium
scrap. Routing conditions (including population densities, distance and time traveled, and fraction
of travel in different population zone types (rural, suburban, and urban)) were obtained from the
HIGHWAY computer code (Johnson et. al. 1993). Concentrations of identified isotopes were
calculated based on an assumed isotopic distribution (Jacobson 1994c). Shipping package
radioactivity and SST loading were based on safety analysis information supplied for each package
type. Gamma dose rates from each shipping package were derived similarly (HNUS 1994).
Routing demographics, dose rates, and neutron-gamma fractions were used as input to the
computer code RADTRAN 4 (Neuhauser 1992) to obtain radiological impacts.
The magnitude of incident-free radiation exposure depends on the dose rate on the external surface
of the transport vehicle, the exposure time and distance, and the number of people exposed.
During incident-free transport, external radiation exposure would occur to the transportation
workers (loading and unloading crews and transport vehicle crew), persons sharing the
transportation link at the time of shipment (escort vehicles and general public), and persons near
the transportation link as the shipment passes. Table 5-13 provides the results of the incident-free
analysis for shipping the plutonium scrap from Mound and LANL to SRS for both package types
and full and half-load SST capacities. Maximum and typical packaging configurations were
analyzed. The maximum exposed individual (MEl) is located by RADMAN at 30 meters from the
road.
Table 5-13
Incident-Free Transportation Impacts for Shipments to SRS
Origin/ Load grams/ Ship- Public Dose MEI* Handler Dose Crew dose
Pkg Type Type package ments (person-rem) (rem) (person-rem) (person-rem)
Mound Full 196 3 5.19E-02 l.91B-07 3.04E+OO 2.17E-01
(10 kg) Half 196: 6 5.00E-02 9.20E-08 2.03E+OO 2.18E-01
5320 Full 160 4 4.94E-O2 1.56E-07 2.89E+00 2.06E-01
Half 160 7 4.76B-02 7.51E-08 2.48E+00 2.08E-01
1 kW Full 884 3 1.02E-01 3.75E-07 8.41E-01 2.49E-01
Half 884 6 1.31E-01 2.42E-07 8.21E-01 3.84E-01
Full 720 4 1.lOE-01 3.05E-07 8.OOE-01 2.37E-01
Half 720 7 1.25E-01 1.97E-07 7.80E-01 3.64E-01
LANL Full 196 10 2.59E-01 1.91E-07 1.01E+O1 1.81E+00
(35 kg) Half 196 20 2.50E-01 9.20E-08 6.70E+00 1.82E+OO
5320 Full 160 12 2.53E-01 1.56E-07 9.92E+00 1.77E+OO
Half 160 24 2.44E-01 7.51E-08 6.61E+00 1.79E+00
1 kW Full 884 10 5.20E-01 3.75E-07 2.80E+O0 2.08E+OO
Half 884 20 6.72E-01 2.42E-07 2.74E+OO 3.22E+OO
Full 720 12 5.08E-01 3.05E-07 2.74E+00 2.04E+OO
Half 720 24 6.57E-01 1.97E-07 2.67E+00 3.13E+00
1MEI values indicate the probability of a latent cancer fatality

5.2.5 Transportation Accidents
Radiological consequences from an accident due to transport vehicle collision would result
primarily from release of respirable radioactive particulates and subsequent inhalation by
individuals downwind of the accident, either directly or after re suspension. Other exposure
pathways would include direct radiation from the cloud of airborne material and from
contamination on the ground.
The magnitude of accident consequence depends on the amount of radioactive material the
individual(s) are exposed to, the exposure time, and the number of people exposed. NUREG-
0170 (USNRC 1977) provides criteria for determining the magnitude and probability of a given
severity of an accident based on impact and thermal forces the transport vehicle and its contents
could be exposed to. It would be necessary for an SST to be exposed to the most severe accident
(the lowest probability of all accident types) conditions (Category VIII) to release any material by
breaching shipping packages. The highest probability of any accident occurring would be for a
Category I accident; however, no radioactive material would be released due to the low impact to
the package. For any accident other than a Category VIII there would be no release of material and
consequences would be similar to the incident-free conditions previously described. Accident
probability for a Category VIII accident was adapted from NUREG-0170 (HNUS 1994) and
found to be less than 4x10-10 (less than 4 chances in a trillion). Because possibility of such an
accident is so remote, the consequences have not been analyzed further.

5.2.6 Nonradiological Transportation Accidents
The nonfatal and fatal accident probabilities per shipment for material transport along the longest
route postulated in the analysis are calculated to be 2.OE-3 and 1.5E-4, respectively. The average
nonfatal accident rate for vehicles such as SSTs is 4.6E-7 accidents per kilometer (USNRC 1977).
The traffic fatality rate used in the analysis is from Department of Transportation (DOT 1989) data
for the commercial shipping industry for trucks and is based on millions of total vehicle-kilometers
of travel. DOE assumes that the percent of accidents resulting in a fatality would be the same as
that for interstate travel by truck (7.5 percent) (DOT 1989). Therefore, the traffic fatality rates in
the analysis are conservatively assumed to be equal to the national average for commercial
shipping.

5.2.7 Health Effects
Health effects measured as the number of latent cancer fatalities (LCFs) were calculated by
multiplying the resultant worker and general public consequences by the risk factors of 4E-4 and
5E-4 LCFs per person-rem (DOE 1993b), respectively. For individual exposures, these same
values are used to calculate cancer mortality probability.
Table 5-14 presents the calculated total incidence and maximum probability of LCFs for incident-
free shipments to SRS.

5.3 Effects of Radiological Doses
In this analysis the major impact from operation of these facilities under both normal and accident
conditions is exposure to radiation or radiation dose. The following discussion is provided to aid
in understanding the effects of these doses.
Table 5-14
Number and Probability of Latent Cancer Fatalities for
Incident-Free Transportation to SRS
Origin I Iced grams/ Ship- Public MEI1 Worker
Pkg Type Type package ments LCFs LCFs LCFs
Mound Full 196 3 3E-05 lE-lO 1E-03
(10 kg) Half 196 6 3E-O5 5E-lI 9E-O4
5320 Full 160 4 2E-O5 8E-11 lE-03
Half 160 7 2E-05 4E-11 1E-03
1 kW Full 884 3 5E-05 2E-10 4E-04
Half 884 6 7E-05 lE-lO SE-04
Full 720 4 6E-05 2E-10 4E-04
Half 720 7 6E-O5 lE-lO 5E-04
LANL Full 196 10 lE-04 lE-lO 5E-03
(35 kg) Half 196 20 1E-04 5E-1l 3E-03
5320 Full 160 12 1E-04 8E-11 5E-03
Half 160 24 1E-04 4E-11 3E-03
1 kW Full 884 10 3E-04 2E-10 2E-03
Half 884 20 3E-04 lE-lO 2E-03
Full 720 12 3E-04 2E-10 2E-03
Half 720 24 3E-04 lE-lO 2E-03
1MEI values indicate the probability of a latent cancer fatality

5.3.1 Collective Doses
Because there is much uncertainty concerning the effects of radiation at low doses and dose rates,
scientists conservatively use a linear model to extrapolate the cancer risks known from higher
doses and dose rates. The conversion factor for excess cancer mortality in the general population
from radiation exposure is 5.0x10-4 Latent Cancer Fatalities (LCFs) per person-rem and for
workers is 4.0x10-4 LCFs per person-rem (NRC, 1991). The difference in risk factors is
attributable to the presence of children in the general population. Table 5-15 provides the predicted
number of LCFs for the doses in this analysis.

5.3.2 Individual Doses
Because the probability of cancer in a specific individual cannot be predicted, the probability of
latent fatal cancer for specific individuals was not calculated. Effects of individual radiation doses
are best interpreted by comparing them to similar levels encountered in daily life and to regulatory
limits. The following facts are provided as a frame of reference to compare the individual doses
provided in this analysis.
- The average annual dose from natural sources (radon, terrestrial radiation, cosmic
radiation, and from ingested natural radioisotopes, especially potassium-40) to an
individual living in the SRS area is about 315 mrem (WSRC, 1993a).
- In 1993, the dose to the maximally exposed offsite individual from SRS operations was
0.27mrem (WSRC, 1993a).
- The DOE annual limits on dose to the member of the public receiving the maximum
exposure are 100 mrem from all pathways, 10 mrem from the airborne pathway, and 4
mrem from the drinking water pathway (DOE, 1990b).
- The DOE annual dose limit for a radiation worker is 5,000 mrem; SRS further restricts
this limit to 1,500 mrem (DOE Order 5480.11; WSRC, 1992a).
Table 5-15
Predicted Number of Latent Cancer Fatalities
Collective Risk Factor Potential
Population Dose (LCFs per Number of
Description Exposed (person-rem) person-rem) LCFs
Normal Operation (per year) Radiation 100 4.0 x 10^-4 0.04
(Section 5.1.5) Workers
Earthquake On-site 5490 4.0 x 10^-4 2
(Table 5-11) Off-site 9030 5.0 x 10^-4 5
Propagated Fire On-site 418 4.0 x 10^-4 0.2
(Table 5-8) Off-site 1210 5.0 x 10^-4 0.6
Coil & Tube Failure On-site N/A^[1] 4.0 x 10^-4 N/A^[1]
(Table 5-11) Off-site 7600 5.0 x 10^-4 4
Bounding Onsite On-site 27 4.0 x 10^-4 0.01
Transportation Accident Off-site 130 5.0 x 10^-4 0.07
(Table 5-12)
OffsiteTransportation Public 0.657 5.O x 10^-4 0.0003
(Table 5-13) Workers 11.7 4.0 x 10^-4 0.005
[1]There are no receptors for this release pathway.

6.0 REGULATORY CONSIDERATIONS
DOE policy is to perform its operations in compliance with all existing applicable federal, state, and
local laws and regulations, and with all DOE orders. This section discusses the major regulatory
permit programs that might be applicable to the proposed action.

6.1 National Environmental Policy Act of 1969
NEPA, as amended (42 USC 4321 et seq.), requires "all agencies of the Federal Government" to
prepare a detailed statement on the environmental effects of proposed "major federal actions
significantly affecting the quality of the human environment. In compliance with the National
Environmental Policy Act (NEPA), the requirements of the Council on Environmental Quality (40
CFR 1500-1508), DOE Regulations 10 CFR 1021, and DOE Order 5440.lE, this Environmental
Assessment (ea) addresses the potential environmental consequences of continued operation of
HB-Line and Frame Waste Recovery at the Savannah River Site (SRS) to aid in determining
whether a detailed environmental impact statement should be prepared.

6.2 Solid Waste Regulations
Miscellaneous non-radioactive, non-hazardous trash from routine operations (e.g., office waste
paper, maintenance shop waste) would be disposed in the SRS Solid Waste Landfill.
Any radioactive solid waste that would be generated would be subject to the requirements of DOE
Order 5820.2, "Radioactive Waste Management".
Disposal of any hazardous or mixed-wastes would be subject to the additional requirements of the
Resource Conservation and Recovery Act (RCRA) and the South Carolina Hazardous Waste
Management Regulations (SCHWMR) R.61-79.

6.3 Air Emissions Regulations
The air emissions from the 291-H stack are currently permitted by the SCDHEC. Pursuant to
regulation 40 CFR 61 of the National Emissions Standards for Hazardous Air Pollutants
(NESHAP), this stack requires continuous isokinetic monitoring. Per a Federal Facilities
Compliance Agreement (FFCA) between the Environmental Protection Agency, Region W (EPA-
IV) and DOE-SR, effective October 31, 1991, the 291-H stack emissions monitoring system was
upgraded to include isokinetic sampling in April 1993.

6.4 Liquid Discharge Regulations
Liquids discharged from 221-H Building are subject to the provisions of the Clean Water Act of
1977 as amended by the Water Quality Control Act of 1987 (P.L. 100-4) and the South Carolina
Pollution Control Act (S.C. Code of Laws, 1976, Title 48, Chapter 1). HB-Line and Frame
Waste Recovery are currently permifled under the SRS NPDES permit SC0000175.

6.5 Transportation Regulations
Routine activities for operation of HB-Line would involve transportation of Plutonium-238 to and
from the Savannah River Site. Such transportation would be in accordance with Department of
Transportation (DOT) regulations (49 CFR 171-179) and DOE Orders. In addition, applicable
requirements of the Nuclear Regulatory Commission (10 CFR Part 71) would be followed and
State transportation requirements applicable to transportation of radioactive material (e.g., routing
requirements) would be followed to the extent that such requirements are not inconsistent with
federal regulations.

7.0 PERSONS AND AGENCIES CONSULTED
DOE cosulted the National Aeronautics and Space Administration and Mr. Brian Costner of the
Energy Research Foundation, Columbia, South Carolina, during preparation of this ea.

8.0 REFERENCES
Brolin, E. C., 1993. Letter from E. C. Brolin, June 14, 1993 Acting Director, Office of Nuclear
Energy, Department of Energy, to W. T. Huntress, Jr., Associate Administrator for Space
Science, National Aeronautics and Space Administration.
DelGenio, M. E., 1994. Update of HB-Line Consequences Based on New
Meteorological and Population Databases in AXAIRS9Q, WSRC-RP-94-250,
Westinghouse Savannah River Company, Savannah River Site, Aiken, S.C.
DelGenio, M. E., 1994b. Response to ESH&QA Comments on the HB-Line JCO Rev.
1 (U), EPD-CAT-94-0040, Westinghouse Savannah River Company, Savannah River
Site, Aiken, SC.
DOE (U.S. Department of Energy), 1982. Final Environmental Impact Statement,
Defense Waste Processing Facility, Savannah River Plant, Aiken, South
Carolina, DOE/eis4-0082, Washington, D. C.
DOE (U.S. Department of Energy), 1990a. Final Environmental Impact Statement,
Continued Operation of K-, L- and P-Reactors, Savannah River Site,
DOE/eis-O147, Savannah River Operations Office, Aiken, S.C.
DOE (U.S. Department of Energy), 1990b. DOE Order 5400.5, Radiation Protection of
the Public and the Environment, U. S. Department of Energy, Washington, DC.
DOE (U.S. Department of Energy), 1991. Environmental Assessment for Radioisotopic
Heat Source Fuel Reprocessing and Fabrication, DOE/ea-0534, U.S.
Department of Energy, Offices of Special Applications, Washington, D. C.
DOE (U.S. Department of Energy), 1993a. Environmental Assessment of the Import of
Russian Plutonium-238, DOE/ea-0841, U.S. Departmerit of Energy, Office of
Nuclear Energy, Washington, D. C.
DOE (U.S. Department of Energy), 1993b. DOE NEWS Fact Sheet - Transporting and
Safeguarding Special Nuclear Material, U.S. Department of Energy, Transportation
Safeguards Division, Albuquerque, New Mexico.
DOE (U.S. Department of Energy), 1993c. "Recommendations for the Preparation of
Environmental Assessments and Environmental Impact Statements", Office of
NEPA Oversight (EH-25) U. S. Department of Energy, Washington, D.C.
DOE (U.S. Department of Energy), 1994. Final Supplemental Environmental Impact
Statement, Defense Waste Processing Facility, DOE/eis-0082, Savannah River
Operations Office, Aiken, South Carolina
DOE (U.S. Department of Energy), 1995. Draft Environmental Impact Statement, Waste
Management, DOE/eis-O217D, Savannah River Site, Aiken, South Carolina
DOT (U.S. Department of Transportation), 1989. Acddents Reported by Motor Carriers
of Property 1989, FHWA/MC-92/018, U.S. Department of Transportation, Federal
Highway Administration, Office of Motor Carriers, Washington, D.C.
DuPont (E.I. du Pont Nemours & Co.), 1986. Safety Analysis - 200 Area Savannah
River Plant, H-Canyon Operations, DPSTSA-200-10-2-SUPP 5, Savannah River
Plant, Aiken, S.C.
DuPont (E.I. du Pont Nemours & Co.), 1991. Safety Analysis - 200 Area, Separations
Area Operations, Building 221-H, B-Line, Scrap Recovery Facility and
Plutonium Oxide Facility, Rev. 1, DPSTSA-200-10-2, Savannah River Plant,
Aiken, S.C.
HNUS (Halliburton NUS Corporation), 1994. Transportation Radiological Analysis -
Savannah River Site Pu-238 Processing Environmental Assessment, Aiken,
South Carolina
Heal, D,W., Paik, I.K., and Swenson, G.R., 1995. HB-Line and H-Canyon Worker
Safety (U), WSRC-TR-95-0095, Rev. 0, Westinghouse Savannah River
Company,Savannah River Site, Aiken, S.C.
Huang, J. C. and P. Hang, 1993. Impact of the New (1987-1991) SRS Meteorological
Database on AXAIR89Q Dose Calculations (U), WSRC-RP-93-551,
Westinghouse Savannah River Company,Savannah River Site, Aiken, S.C.
Huntress, W. T., Jr., 1993. Letter from W. T. Huntress, Jr., Associate Administrator for Space
Science, National Aeronautics and Space Administration, to E. C. Brolin, Assistant
Secretary for Nuclear Energy (Acting), Department of Energy, April 28.
Jacobson, R. Y., 1994a. Westinghouse Savannah River Company, Transportation Data Request,
Interoffice memorandum to R. J. Smith, Halliburton NUS Corporation, Aiken, South
Carolina, July 7.
Jacobson, R. Y., 1994b. Westinghouse Savannah River Company, HB-Line ea Information
(U), Interoffice memorandum to S.W. McAlhany, U.S. Department of Energy, Aiken,
South Carolina, June 20.
Jacobson, R. Y., 1994c. Westinghouse Savannah River Company, HB-Line ea Data Request
(U), Interoffice memorandum to R. J. Smith, Halliburton NUS Corporation, Aiken, South
Carolina, June 9.
Johnson, P. E., D. S. Joy, D. B. Clarke, and J. M. Jacobi, 1993. Highway 3.1 - An
Enhanced Highway Routing Model: Program Description, Methodology,
and Revised User's Manual, ORNL/TM-12124, U.S. Department of Energy,
Washington, D. C.
Lambert, D. 5., 1994. December 1993 - Facility Solid Waste Generation Report,
WER-SWD-940021, Westinghouse Savannah River Company, Aiken, S.C
Neuhauser, K. S. and F. L. Kanipe, 1992. RADTRAN 4: Volume 3 User Guide,
SAND89-2370; TTC-0943; UC-722, Sandia National Laboratories, Albuquerque, New
Mexico.
NRC (U. S. Nuclear Regulatory Commission), 1991. Preamble to Standards for
Protection Against Radiation, 56 FR 23363, Nuclear Regulatory Commission,
Washington, DC.
NUS (Halliburton NUS), 1992. Socioeconomic Characteristics of Selected Counties
and Communities Adjacent to the Savannah River Site, Halliburton NUS,
Aiken, S.C.
Pickett, C. E., 1991. Predicted Waste Volume and Composition from Pu-238 Scrap
Recovery Operations, NMP-STH-910213, Westinghouse Savannah River Company,
Aiken, S.C.
USNRC (U.S. Nuclear Regulatory Commission), 1977. Final Environmental Impact
Statement on the Transportation of Radioactive Material by Air and Other
Modes, NUREG-017O, U.S. Nuclear Regulatory Comrnission, Washington, D.C.
WSRC (Westinghouse Savannah River Company), 1989a. Reactor Operation
Environmental Information Document, Volume I, Geology, Seismology,
Subsurface Hydrology, WSRC-RP-89-815, Savannah River Site, Aiken, S.C.
WSRC (Westinghouse Savannah River Company), 1989b. Reactor Operation
Environmental Information Document, Volume II, Ecology, WSRC-RP-89-
816, Savannah River. Site, Aiken, S.C.
WSRC (Westinghouse Savannah River Company), 1989c. Reactor Operation
Environmental Information Document, Volume III, Meteorology, Surface
Hydrology (Transport Impacts), WSRC-RP-89-817, Savannah River Site, Aiken,
S.C.
WSRC (Westinghouse Savannah River Company), 1989d. Safety Analysis - Evaluation of
Accident Risks in the Transportation of Hazardous Materials by Truck and
Rail at the Savannah River Site, WSRC-RP-89-7 15, Savannah River Site, Aiken,
S.C.
WSRC (Westinghouse Savannah River Company), 1992a. Radiological Control, Manual
5Q, Savannah River Site, Aiken, S.C.
WSRC (Westinghouse Savannah . River Company), 1992b. Savannah River Site Scrap
Recovery Facility, Plutonium Oxide Facility Justification for Continued
Operation, WSRC-RP-92-981, Savannah River Site, Aiken, S.C.
WSRC (Westinghouse Savannah River Company), 1993a. Savannah River Site
Environmental Report for 1992, WSRC-TR-93-075, Savannah River Site, Aiken,
S.C.
WSRC (Westinghouse Savannah River Company), 1993b. December 1993 Radioactive
Releases Report, ESH-EMS-93-O128, Savannah River Site, Aiken, S.C.
WSRC (Westinghouse Savannah River Company), 1993c. Nuclear Materials Processing
Division Separations H-Area Facilities ALARA Performance Indicators
Program, Savannah River Site, Aiken, S.C.
WSRC (Westinghouse Savannah River Company), 1994a. Savannah River Site Scrap
Recovery Facility, Plutonium Oxide Facility Justification for Continued
Operation, WSRC-RP-92-981, Revision 1, Savannah River Site, Aiken, SC.
WSRC (Westinghouse Savannah River Company), 1994b. H-Canyon SAR Addendum for
Frame Waste Recovery, DPSTSA-200-10 SUPP-5, Addendum 4, Savannah River
Site, Aiken, S.C.

APPENDIX A: COMMENTS RECEIVED ON THE DRAFT HB-LINE
ENVIRONMENTAL ASSESSMENT, AND DOE RESPONSES

1.0 COMMENTS TRANSMITTED TO DOE FROM THE ENERGY RESeaRCH
FOUNDATION (ERF), DECEMBER 8, 1994

1.1 ERF Comment 1
An important point in our case for a new ea was that the purpose and need had changed
significantly since 1991, and in the settlement agreement, DOE explicifly agreed to consider the
need for future Pu-238 reprocessing at SRS. It is important that this discussion of need be
complete, accurate, and based on timely information.
During Mondays conference call, we raised several concerns regarding the draft ea's explanation
for the need for future Pu-238 operations. For example, the draft ea refers to "terrestrial
missions" (p. 4) without offering any indication of what these missions might be. Our
understanding from the call is that this phrase may simply be remaining from an earlier draft and
that no such missions are planned. The revised ea should explain this point, documenting the
current status of all missions for which Pu-238 might be needed and whether in fact there are
terrestrial requirements for Pu-238.
For another example, Table 2-1 lists estimated NASA mission requirements for Pu-238. The draft
ea does not, however, specify which of these missions is funded, the state of planning for each
mission, or other factors which would document the actual need for additional quantities of Pu-
238. The final ea should provide enough information so that the reader can evaluate the crlibility
of claimed Pu-238 requirements.
Also, the ea should better describe the inventory of weapons return Pu-238 and any plans for its
reprocessing. The draft refers to two February 1994 memos as evidence that there are no current
plans to process this material (pp.2 & 3) The revised ea should contain more timely information,
including a declassified inventory of weapons return Pu-238.

1.1.1 DOE Response
This comments raises several concerns involving the purpose and need to process Pu-238 at SRS.
A response has been provided for each concern identified.
Concern #1 The ea fails to discuss the purpose and need to processing Pu-238 to support
terrestrial missions.
Response #1: The ea has been revised to delete "terrestrial missions" from section 1.0,
"Summary" and in section 2.2, "Purpose and Need for Agency Action." This phrase was
inadvertenfly left over from an earlier version of the draft ea. There are no current plans or
projected plans to process Pu-238 for any terrestrial missions.
Concern #2: The ea does not clearly define the current status of all missions for which Pu-238
might be needed.
Response #2: Table 1-1 has been added to the ea and lists all the missions for which Pu-238
might be needed. Table 1-1 also indicates the current status (as of March 1995) of each of these
missions. The status identifies the current status of Pu-238 production for each mission as well as
the overall status of those activities needed to support each mission.
Concern #3: The ea does not specify which of the missions listed in Table 2-1 are funded or the
current status of planning for each mission.
Response #3: Table 1-1 has been included in the ea to indicate which of the missions has been
funded. The table indicates that funding has been approved for Pu-238 processing at SRS to
support all NASA's missions; however, the funding for each individual mission is not expected to
be approved until the year prior to the scheduled launch dates. A discussion concerning the
funding and budget process has been included in section 1.0 of the ea. Table 1-1 also indicates
the current status (as of March 1995) of each of these missions. The status identifies the current
status of Pu-238 production for each mission as well as the overall status of those activities needed
to support each mission.
Concern #4: The ea should better describe and provide more timely information concerning the
inventory of weapons return Pu-238 and its plans for reprocessing.
Response #4: Section 1.1.2 of the ea has been revised to clearly identify the inventory of
weapons return Pu-238, and current plans for reprocessing this material. When the BA was
originally transmitted for review and comment (October 1994), DOE had insufficient information
on the availability of weapons return Pu-238, and initially determined that weapons return Pu-238
would not be used for NASA missions. Since October 1994; however, DOE received information
that approximately 10 kilograms of Pu-238 will be available from weapons returns and is
considering using this material if it is suitable for space power systems. This additional 10
kilograms has been added to the total inventory of Pu-238 that is available for processing, bringing
the total inventory to 52 kilograms.

1.2 ERF Comment 2
The ea should better analyze alternatives to future HB-Line operations. TA-55 at the Los Alamos
National Laboratory is not considered a viable alternative because it "could only produce gram
quantities of Pu-238." (p. 6) The draft ea does not indicate whether "gram quantities" refers to
production of only a few grams over several months or hundreds of grams per month. Moreover,
the draft ea does not examine modification of the TA-S S facility in order to increase its
throughpuL The revised draft ea should include these and other details in a meaningful review of
the use of TA-55 for some or all Pu-238 processing.
In evaluating the alternative of purchasing Pu-238 from Russia, the draft ea states: "Even if this
35 kg is purchased the existing U.S. inventory needs to be processed into a usable product to
satisfy current projections of Pu-238 needed to support NASA missions as indicated in Table 2-1."
(p. 7) In fact, though, Table 2-1 does not demonstrate that the U.S. inventory would still need to
be reprocessed. The table lists a requirement for 26 kg for Cassini which is already being
processed in HB-Line. There are only requirements for another 44 kg of Pu-238, and apparenfly
these requirements are not for funded missions. At the very least, purchasing Pu-238 from Russia
would significantly reduce the amount of future reprocessing needed at SRS. The revised draft ea
should provide more details about the prospect of purchasing Pu-238 and more carefully describe
the impacts of such action on future processing requirements.

1.2.1 DOE Response
This comment ratses several concerns involving the failure of the ea to adequately discuss several
alternatives to processing Pu-238. A response has been provided for each concern.
Concern #1: The draft BA does not clearly identify the Pu-238 processing rate of the TA-55
facility and how this rate affects future Pu-238 processing.
Response #1: Section 2.2.4 of the ea has been revised to clearly identify that the Savannah River
Site is currently the only facility in the U.S. that has the capability to process Pu-238 into a usable
form. The TA-S S facility at the Los Alamos National Laboratory currently does not have the
capability of processing Pu-238. Therefore, unless facility modifications were made to the TA-SS
facility (discussed in concern #2 below), there would be no affect that TA-55 would have on future
Pu-238 processing.
Concern #2: The draft ea does not examine possible modification of the TA-55 facility in order to
increase its processing rate and how modification of this facility could affect future Pu-238
processing.
Response #2: Section 2.2.4 of the ea has been revised to clearly identify the Pu-238 production
rate that would be possible at the TA-55 facility at the Los Alamos National Laboratory. New
equipment and facility modifications, followed by extensive testing and demonstration, would be
required to begin processing Pu-238 at TA-55. The new processing capability would be limited to
100 to 300 grams of Pu-238 per month. This represents the maximum potential capacity for
processing Pu-238 at the TA-55 facility. (Note: For reference, HB-Line's capacity is 2000 to
4000 grams of Pu-238 per month.) Although modifying the TA-55 facility is an alternate method
for supplying Pu-238 to NASA, there is no reason to c6nsider that the environmental impacts of
processing Pu-238 at TA-55 would be significantly different than processing Pu-238 at SRS.
Since the environmental impacts would not be significantly reduced, and since additional funding
would be required to modify the facility, perform testing, and conduct startup reviews, modifying
the TA-55 facility is not considered an to be a reasonable alternative for processing Pu-238 to
suppon NASA missions.
Section 2.2.4 of the ea has also been revised to discuss that modifying the TA-55 facility would
not have a significant affect on future Pu-238 processing, and is not considered to be a reasonable
alternative for supporting Pu-238 requirements for NASA missions. The next mission for which
Pu-238 must be supplied is the Mars Environmental Survey (MESUR) launch in the year 2000.
This mission requires 10 kg of material. Due to the steps involved in transforming the Pu-238 into
assembled and fully qualified RTGs, the 10 kgs of Pu-238 must be processed by approximately
1998. Assuming that Pu-238 processing at the TA-55 facility to support MESUR could not begin
until 1996 (time would be required to modify the facility, perform testing, and perform the
necessary startup approvals), there would be approximately 24 months before the Pu-238 would
have to be delivered to begin RTG fabrication. At an maximum production rate of 300 grams per
month, TA-55 would only be able to supply 7.2 kilograms by 1998, 2.8 kilograms below the
requirement. This deficit would need to be supplied by alternate means, such as additional
purchases from Russia or other foreign nations (see concern #4), or continued operation of the
lIB-Line facility at SRS.
Purchasing the additional material irom Russia to make up the 2.8 kg deficit is not considered to be
a reasonable alternative (as noted in the response to concern #4) since the cost of purchasing Pu-
238 exceeds the cost of processing the material at the HB-Line facility. Even if there were no cost
savings, there is no reason to consider that the environmental impacts of processing Pu-238 in
Russia would be significantly different than processing Pu-238 in the U.S.
The 2.8 kg deficit could also be made up by operating the HB-Line facility. Operating both the
TA-55 facility and the HB-Line facility is not considered to be a reasonable alternative. The lIB-
Line facility, by itself, can support the NASA missions. Therefore, there is no reason to supply
additional funding to TA-55 to perform facility modifications, testing and startup reviews to obtain
the capability to process Pu-238, when Pu-238 processing capabilities already exist within the HB-
Line facility. Even if there were no costs associated with providing TA-55 the capability to process
Pu-238, there is no reason to consider that the environmental impacts of processing Pu-238 at the
TA-55 facility would be significantly different than processing Pu-238 at the HB-Line facility.
Based upon the above discussions, a modified TA-55 facility, by itself, would not be capable of
supplying the necessary quantities of Pu-238 to support NASA missions. Therefore, DOE has
concluded that the proposed action is to continue to operate and maintain the Pu-238 processing
facilities at SRS.
Concern #3: Table 2-1 does not demonstrate that the U.S. inventory of Pu-238 would still need to
be processed into a usable product to support NASA missions even if 35 kg of Pu-238 is
purchased from Russia.
Response #3: Section 2.2.5 of the BA has been revised to clarify that the entire existing U.S.
inventory of Pu-238 does not need to be processed to support the NASA missions. This is
independent of whether additional material is purchased from Russia The ea has also been
revised to clarify that purchasing additional materials is not a reasonable alternative for processing
Pu-238 at SRS to support NASA missions.
Table 1-1 indicates that a total of 70 kgs of Pu-238 are required to support NASA missions.
Subtracting 26 kg. for the Cassini mission (the Pu-238 required to be processed is nearly
complete), and subtracting 7.5 kg for the Pluto Flyby missions (the Pu-238 required for these
missions is expected to be provided from an existing spare RTG) results in a total of 36.5 kgs
which are needed to support the remaining missions. This is the flight quantity of processed fuel
that could be required after Cassini, but it is not the total quantity of Pu-238 required to be
processed. In addition to the flight quantity, additional fuel would require processing to account
for analytical samples, product characterization, safety testing, spare hardware, and out of
specification products. As discussed in section 1.0 of the BA, these "non-flight" quantities may
approach 25% of the flight quantities. Therefore, it is reasonable to consider that 45.7 kg of Pu-
238 would be required to be processed so that 36.5 kg will be available as the flight quantity.
DOE has an existing contract with Russia to purchase an additional 35 kg. of Pu-238. A second
purchase of Pu-238 from Russia is anticipated to occur during early Fiscal Year 1995. This
purchase will consist of approximately 4 kg of material which will not require processing prior to
fuel pellet fabrication. This reduces the quantity of Pu-238 to support NASA missions from 36.5
kg. to 32.5 kg. It also reduces the quantity of Pu-238 that is available to be purchased from Russia
from 35 kg. to 31 kg. Therefore, it "appears that if the remaining 31 kg. of Pu-238 is purchased
form Russia, only a 1.5 kg. deficit would result. This would "imply" that only a small quantity of
the U.S. inventory of Pu-238 would require processing to meet NASA mission needs.
However, DOE only has $9.1 million allocated towards the Pu-238 program through Fiscal Year
1996. Due to budgetary limitations, DOE does not anticipate that additional funds will be available
for the Pu-238 program in later years. Therefore, there is only $9.1 million available to support
the NASA missions. DOE has two options: 1)purchase $9.1 million in Pu-238 from Russia under
the existing contract; or 2) operate HB-Line at a cost of $1.1 million per month and process that
quantity of Pu-238 until the $9.1 million is depleted.
If DOE purchases $9.1 million in Pu-238 from Russia, the U.S. will receive approximately 6.5 kg
of material. This is based upon the cost of $1,409 per gram, and does not include the cost increase
of 5.5% per year. The 6.5 kg. purchased can be combined with the 4 kg. of Pu-238 recently
approved for purchase for a total of 19.5 kg. This will support the MESUR launch in 2000, but
will not support any other NASA missions.
If DOE operates HB-Line, 20 kg. of Pu-238 can be processed for $9.1 million. This is based
upon processing for 8 months at an average capacity of 2.5 kg per month. At a operating cost of
$ 1.1 million per month, this would cost $8.8 million. The remaining $0.3 million would be used
to flush dut the lines. The 20 kg. processed through HB-Line can be combined with the 4 kg.
recently approved for purchase from Russia, for a total of 24 kg. This would not support all of the
NASA missions; however, it supports more missions than purchasing the material from foreign
nations.
In addition to the cost of the Pu-238, there is no reason to consider that the environmental impacts
of processing Pu-238 in Russia would be significantly different than processing Pu-238 in the
U.S.
With the budget available, DOE cannot support all of the NASA missions. There is enough
material in the U.S. inventory to support NASA's needs; however, the funds are not available to
support processing all the material that is required. Based upon a cost(benefit analysis as well as
evaluating the environmental impacts of purchasing versus processing, DOE has concluded that the
proposed action is to continue to operate and maintain the Pu-238 processing facilities at SRS.
Concern #4: The draft ea should provide more details about the prospects of purchasing Pu-238
and describe the impacts that this action would have on future Pu-238 processing.
Response #4: Sections 1.1.1 and 2.2.5 of the ea has been revised to provide more details
concerning purchasing additional material from foreign nations.
A second purchase of Pu-238 from Russia has been approved which is anticipated to occur during
early Fiscal year 1995. This purchase will consist of approximately 4 kg of material which will not
require processing prior to fuel pellet fabrication. This would reduce the flight quantity of Pu-238
required to support post Cassini NASA missions from 36.5 kg. to 32.5 kg (see response to
concern #3). Additional purchases from Russia under this existing contract, or from other foreign
nations, are not anticipated due to budget limitations. Therefore, 32.5 kg of flight quantity Pu-238
from the existing U.S. inventory would require processing to support the post Cassini NASA
missions.
Discussion with Great Britain and France have concluded that kilogram quantities of Pu-238 would
not be available until sometime after 1999, after significant investment in new facilities have been
completed. Receiving material in the year 1999 would not support the proposed launch of
MESUR in the year 2000 due to the long lead time necessary to fabricate the RTGs~(see response
to concern #2)
Based upon the above discussions, DOE has concluded that the proposed action to best support the
post Cassini NASA missions is to continue to operate and maintain the Pu-238 processing facilities
at SRS.

1.3 ERF Comment #3
A substantial concern raised about the 1991 ea was its incomplete consideration of waste
management impacts. Unfortunately, the current draft is even less adequate in this regard. The
draft ea merely references two ongoing Environmental Impact Statements (eis), with the Waste
Management eis apparently being most considerate of future HB-Line operations. (pp. 3, 12, &
16) The Waste Management eis, however, won't be complete for several months. Consequently,
a decision soon on the ea would not be based on any meaningful review of waste management
impacts associated with HB-Line operations. To correct this problem, the revised draft ea should
thoroughly describe the waste streams which would be generated by HB-Line operations, how the
waste will be handled, and potential impacts.
Despite the incomplete discussion in the draft ea, the proposed Finding of No Significant Impact
presents the conclusion that, "Waste generated as a result of the proposed action would be a small
fraction of the waste being managed at the SRS and would require no new waste management
facilities or process." (p. 4) If this is DOE's conclusion, then the revised draft ea must Provide
supporting evidence.

1.3.1 DOE Response
Section 4.3 of the ea has been revised to clearly describe the waste streams which are generated
by HB-Line operations, the method that the waste is handled, and the potential impacts of the
waste. This discussion supports the conclusion provided in the FONSI that waste generated as a
result of the proposed action would be a small fraction of the waste being managed at the SRS and
would require no new waste management facilities or process.
Based upon a review of the waste management impacts, DOE has determined that the proposed
action does not significantly affect the quality of the human environment within the meaning of
NEPA. Therefore, DOE has concluded that the preparation of an Environmental Impact Statement
is not required, and is proposing to issue a Finding of No Significant Impac~

1.4 ERF Comment #4
The draft ea does not calculate doses from accidents to involved facility workers. The rationale
provided is that the estimates rely on many assumptions and that in most cases "DOE believes that
accident response procedures and engineered safety systems would limit worker doses to the range
shown for co-located workers." (p. 18) The final ea should provide risk information for workers
involved in accidents, or at the very least offer a clear explanation of why such information is not
included. This information should not be based solely on historical practices, but rather it should
reflect current expectations about the operation of DOE nuclear facilities.

1.4.1 DOE Response
Table 5-5 has been included in the final ea to provide risk information for workers involved in
potential accidents. The request to include this information in the ea is consistent with the
guidance presented in "Recommendation for the Preparation of Environmental Assessments and
Environmental Impact Statements," U.S. Department of Energy, Office of NEPA Oversight, May
1993. Specifically, section 6.2 states, "Aim to provide estimates of potential health effects from
chemical or radiological exposure for three subsets of populations and maximally exposed
individuals in those populations: (1) workers that would be involved in the proposed action, (2)
noninvolved workers (workers that would be on the site of the proposed action but not involved in
the action), and (3) members of~the general public.
Historically, DOE provided estimates of potential health effect to noninvolved workers (e.g. co-
located workers) and members of the general public; however, DOE did not specifically identify
the health effects to the actual worker. It was believed that accident response procedures and
engineered safety systems would limit worker doses to the range determined for co-located
workers. In addition, any uncertainties associated with modeling of accident at small distances
(e.g. within the building) would be extremely large, and the consequences resulting from such
models would tend to vary by orders of magnitude, depending on the selection of assumptions.
In order to more closely follow the suggestion to "aim to provide estimates of potential health
effects to workers that would be involved in the proposed action," a qualitative analysis was
performed to evaluate the hazards to the facility workers. The results of this analysis are presented
in section 5 of the BA. The results are summarized from a Preliminary Hazards Analysis (PHA)
which was conducted for the facility following the guidelines presented in DOE Standards DOE-
STD-301 1-94, "Guidance for Preparation of DOE 5480.22 (TSR) and DOE 5480.23 (SAR)
Implementation Plans." Based upon the information obtained in the PHA, a qualitative accident
analysis was performed to evaluate the hazards, the cause of each hazard, the frequency, the
consequences, and the preventive or mitigative systems that are in place to protect the workers.
Based upon the review of the hazards to the facility workers, DOE has determined that the
proposed action does not significantly affect the quality of the human environment within the
meaning of NEPA. Therefore, DOE has concluded that the preparation of an Environmental
Impact Statement is not required, and is proposing to issue a Finding of No Significant Impact.

1.5 ERF Comment #5
The revised draft ea should describe recent operating experience of the HB-Line and explain the
risks associated with the operations.

1.5.1 DOE Response
Section 1.1.3 of the BA provides an adequate discussion of operations from January 1991 to the
present. This subsection includes a brief discussion on the June 1994 H-Canyon Water Hammer
incident which caused the Frame Waste Recovery process to shut down. The facility recovered
form the incident and operations have resumed. DOE considers that listing every occurrence
associated with HB-Line is outside the scope of the ea. A description of all occurrences
associated with HB-Line, as well as summaries of production activities, are provided to you
through monthly status reports.
The risks associated with operations are discussed in sections 5.1 and 5.3 of the ea. Section
5.1.5 concludes that under normal operations, workers engaged in the operations of HB-Line and
Frame Waste Recovery would not be expected to incur any harmful health effects from radiation
exposures they receive. Section 5.3.1 quantifies the risks and estimates that there would be 0.04
Latent Cancer Fatalities per years during normal operations. DOE considers that this does not
present a significant affect on the quality of the human environment within the meaning of NEPA.

1.6 ERF Comment #6
There are several other specific concerns addressed in Court documents which are not adequately
discussed in the draft BA. For example, we raised detailed concerns about hazards associated with
Pu-238, on-site and off-site radiological impacts, several specific concerns about accidents, and
safety issues such as fire protection, procedures and training, and Order compliance. Each of these
should be covered in the revised draft ea.

1.6.1 DOE Response
The specific concerns raised in comment #6 were identified in court documents (Motion for
Summary Judgment, Civil Action No. 3:93-0001-19, transmitted to the Secretary of Energy on
June 29, 1993) and are identified below. For each concern listed, a response is provided;
however, the ea may not have been revised as requested. DOE considers that the scope of several
of the concerns (e.g. DOE Order compliance) are outside the scope of the ea. In these instances,
the response provides the necessary details to resolve the concern.
Concern #1 : Hazards Associated with Plutonium-238 - The comments raised in court documents
suggest. that the ea does not address the potential health effects associated with plutonium-238.
Response #1: The hazards associated with Pu-238 are described in section 5 of the ea. The ea
addresses the hazards associated Pu-238 that are present during normal operations and credible
accidents, and describes the effects these hazards have on the workers, the public, and the
environment. Specifically, section 5.3 of the ea discusses that the major impact from operation of
HB-Line under both normal and accident conditions is exposure to radiation. The BA identifies in
Table 5-14 that during normal operations there is a potential for 0.04 latent cancer fatalities (LCFs)
due to radiation exposure. The greatest number of LCFs is expected during an earthquake which is
expected to result in 2 LCFs on-site and 5 LCFs off-site. Numerous references are cited from
which additional details concerning detailed analyses and excess cancer mortality conversion
factors for on-site and off-site exposure to Pu-238 can be obtained. This will enable the reviewer
to independently verily the information contained in the ea.
Based upon a review of the hazards of Pu-238 which are summarized in the ea, DOE has
determined that the proposed action does not significantly affect the quality of the human
environment within the meaning of NEPA. Therefore, DOE has concluded that the preparation of
an Environmental Impact Statement is not required, and is proposing to issue a Finding of No
Significant Impact.
Concern #2: On-site and off-site radiological impacts - The comments raised in court documents
suggest that the ea offers no support that there are no significant radiological impacts from
processing Pu-238.
Response #2: The BA adequately describes the on-site and off-site radiological impacts in section
5. Spocifically, the radiological impacts are identified for the on-site (co-located) worker, the on-
site (facility) worker, the on-site population, the maximum off-site individual, and the off-site
population. Similar to the concern raised about the hazards associated with Pu-238 (discussed
above), the ea discusses that the major impact from operation of HB-Line under both normal and
accident conditions is exposure to radiation. Numerous references are cited from which additional
details concerning accident analysis and dispersion models which were used to determine the
radiological impacts can be obtained. This will enable the reviewer to independently verify the
information contained in the ea. New qualitative analysis has been performed to identify the risks
to on-site facility workers and calculations were recently updated based upon new meteorological
and population databases.
Based upon the on-site and off-site radiological impacts summarized in the ea, DOE has
determined that the proposed action does not significantly affect the quality of the human
environment within the meaning of NEPA. Therefore, DOE has concluded that the preparation of
an Environmental Impact Statement is not required, and is proposing to issue a Finding of No
Significant Impact.
Concern #3: Accidents - The comments raised in court documents suggest that the ea does not
properly summarize data from various safety analysis documents and that the ea does not identify
those accidents which result in the highest doses and risks.
Response #3: The ea adequately describes in section 5.2 the potential credible accidents which
could occur within the HB-Line facility, and summarizes the accident scenarios which result in the
highest doses (propagated fire) and highest risks (low energetic event). Calculations were recently
updated to provide the co-located worker, on-site population, and off-site population doses based
upon the new meteorological and population databases. The updated analysis shows that accident
consequences remain within the authorization basis outlined in the Safety Analysis Report and
Justification for Continued Operation. In addition, the results of a qualitative analysis have been
summarized in the ea which identifies the consequences to facility workers from numerous
hazards within the facilities.
The current draft ea contains information from the Safety Analysis Report and the Justification for
Continued Operation, as well as several new, updated analyses that have been conducted.
Numerous references are cited in the ea from which additional details concerning accident
scenarios and new analyses can be obtained. This will enable the reviewer to independently verify
the information contained in the ea.
Concern #4: Fire Protection - The comments raised in court documents suggest that the ea failed
to recognize deficiencies with the HB-Line fire protection systems.
Response #4: The July 1991 ea and the current draft ea are not required to make direct mention
of risks associated with the fire protection systems. The risks associated with these systems are
discussed in detail in section 3.6.2 of the Justification for Continued Operation which is referenced
in the ea. The analysis presented in the JCO identifies the risks and consequences resulting from
a propagated fire. This analysis assumes failure of the existing fire detection, Halon fire
suppression, and HEPA filtration systems within the facility. These assumptions therefore
eliminate any issues associated with the deficiencies andlor risks of these fire protection systems.
The only safety system for which credit is taken is the passive sand filter. These assumptions
result in a very conservative analysis, the conclusions of which indicate that a propagated fire is the
accident resulting in the highest dose to any receptor. Although the propagated fire is the accident
with the highest doses, the doses are acceptable. (Note: The accident which results in the highest
risk is a low energetic event, and is discussed in the response to the concern involving "Procedures
and Training".)
Since the JCO accounted for failure of the existing fire detection, Halon fire suppression, and
HEPA filtration systems, DQB considers that the analysis discussed in the JCO is adequate in that
it accounts for any deficiencies andlor risks associated with the fire protection systems. Since the
potential doses from a propagated fire are acceptable and do not significantly affect the quality of
the human environment within the meaning of NEPA, DOE considers that the ea is adequate.
Concern #5: Procedures and Training - The comments raised in court documents suggest that
inadequacies in procedures and training compromise the assumptions in the accident analyses, thus
compromising the results summarized in the ea.
Response #5: The ea identifies that the maximum risk from operating HB-Line is due to a low
energetic event. The assumptions for a low energetic event documented in the Safety Analysis
Report conservatively take no credit for operator response, the operator being properly trained, or
the facility having procedures in place to mitigate an abnormal situation. These assumptions
therefore eliminate any issues associated with inadequacies in the procedures and training
programs. These assumptions result in a very conservative analysis, the conclusions of which
indicate that a low energetic event is the accident resulting in the highest risk. Although the low
energetic event is the accident with the highest risk, the risk is acceptable. (Note: The accident
which results in the highest dose is a propagated fire, and is discussed in the response to the
concern involving "Fire Protection".)
Since the SAR accounted for failure of an operator to respond to an abnormal situation, failure to
properly train personnel, and failure to have procedures in place, DOE considers that analysis
discussed in the SAR is adequate in that it accounts for any inadequacies in procedures and
training. Since the potential risk from a low energetic event is acceptable and do not significantly
affect the quality of the human environment within the meaning of NEPA, DOE considers that the
ea is adequate.
Concern #6: Order Compliance - The comments raised in court documents suggest that lack of
compliance with DOE Orders potentially invalidates assumptions upon which the ea is based.
Response #6: Although DOE considers ihat the general issue of DOE Order compliance is not
relevant to the adequacy/validity of the ea (with the exception of DOE Order 5440.1C, "National
Environmental Policy Act Compliance Program"), documentation of compliance with DOE Orders
is complete as documented in the Justification for Continued Operation. The HB-Line facility has
performed compliance assessment for all DOE Orders important to the health and safety of the
workers, the public, and the environment. All non-compliances have been identified, along with
compensatory and corrective actions, and documented. The non-compliances did not invalidate
any assumptions upon which the ea is based, thus DOE considers that the ea is adequate.

2.0 COMMENTS TRANSMITTED TO DOE FROM MR. W. LEE POE, JR.,
DECEMBER 9, 1994

2.1 Mr. Poe's Comment 1
The principal thrust of this ea is to process scrap materials and produce specification grade
plutonium oxide for future NASA missions. From the information given in the ea and from
comments made at the public meeting on December 6, the available Pu-238 at SRS plus that
shipped to SRS from Mound and Los Alamos exceed demand by 30 to 35 kg. In addition the ea
considers a possible additional 35 Kg from future Russian stocks. Section 3.1 and other parts of
the ea, as appropriate, should be expanded to include discussion of the DOE plans for safe storage
of this excess Pu-238. This should include expectations on types of materials that will be stored,
how stored and in what from, their safety in long-term storage, schedules for achieving safe
storage, etc. It is recognized that the recent Plutonium ES&H Vulnerability Assessment identified
several HB-Line vulnerabilities associated with Pu-238. Bringing the Mound, Los Alamos scrap
materials and the Russian Pu-238 to SRS, as authorized under this ea, complicate this long-term
issue at SRS and as a result, it should be addressed in this NEPA document.

2.1.1 DOE Response
Section 1.0 and Table 1-1 of the ea have been extensively revised to more fully explain DOE's
obligation to provide Pu-238 for NASA missions and describe the existing Pu-238 inventory
(including' the potential for further purchases from Russia). In addition, DOE has provided a
detailed discussion of the issue of need for specification Pu-238 in sections 1.1.1 and 1.2.1 of this
Appendix.
Continued safe management and storage of nuclear materials at the Savannah River Site (including
Pu-238) is evaluated in the draft Interim Management of Nuclear Materials eis (DOE/eis-0220D),
issued in March 1995.

2.2 Mr. Poe's Comment 2
Since this ea excludes some Pu-238 materials (e.g., weapons returns) what NEPA document
covers recovery processing, storage, etc. of these excluded materials.

2.2.1 DOE Response
The proposed action has been revised to include processing of about 10 kg of weapons returns Pu-
238 (see section 1.1.2). There are currently no plans to process additional weapons returns Pu-
238. Recovery and storage of nuclear materials from dissassembled weapons is currently being
evaluated in the Pantex Plant Site-wide eis and other ongoing NEPA reviews, including the ea
for storage of enriched' uranium at Oak Ridge and the eis on storage and disposition of weapons-
usable fissile materials.

2.3 Mr. Poe's Comment 3
The alternative discussion in this ea seem extremely terse. Section 3.2 identifies five alternatives
to the proposed action. There are 1) No Action, 2) Alternative Processing Facility, 3) Alternative
Vault Storage Facility, 4) Processing at the National 1-aboratories, and 5) Purchase of Pu-238 from
Foreign Nations. Each of these alternatives were written off with a few sentences of prose. None
of the alternatives were analyzed to show environmental effects.

2.3.1 DOE Response
DOE has revised the discussion of alternative in the ea and added a sixth alternative, Alternative
Packaging and Storage of Pu-238, as described in section 2.2.6. Additional explanation of the
alternatives is given in the response to ERF comment 2, section 1.2.1 in Appendix A.
DOE guidance on discussion of alternatives in environmental assessments indicates that"... eas
often can focus the quantitative analysis on the proposed action; that is, discussions of alternatives
in eas generally can be qualitative." This ea presents a broad range of reasonable alternatives.
If, on the basis of the analysis of the proposed action in this ea, the Department determined that
potentially significant impacts to the human environment could result from implementation of the
proposed action, the Department would prepare an eis which would quantitatively evaluate the
impacts of the alternatives.

2.4 Mr. Poe's Comment 4
Do the environmental effects of the proposed action, given in Section 6.0, properly reflect the post
Cassini effects of Pu-238 processing at SRS? The environmental effects shown in Section 6.1 are
expressed as either impact/year or impactlg or Kg Pu-238. No, specific operation period was
identified nor quantity of Pu-238 processed. Table 6-1 does, provide the expected emissions per
gram Pu-238 and the total emissions. This allo'ws me to figure out the Kg of Pu-238 considered.
It turns out to be about 43 Kg Pu-238 of the amount of Pu-238 in the NASA demand. This
doesn't seem to cover the full amount of Pu-238 planned to be processed. Please show
information that allows total environmental effects from normal operations to be determined.

2.4.1 DOE Response
The information given in the section on Environmental Consequences (section 5.0) reflects the
impacts of processing the currently available inventory of Pu-238. This inventory, as indicated in
Table 5-1, is approximately 52 kg. Most impacts of normal operations are presented in section 5.0
on an annual or per unit Pu-238 basis. DOE chose this presentation because the quantity of. Pu-
238 that would be processed after completion of the Cassini mission is not precisely known.
Similarly, the exact period of time required to process the inventory can be estimated (based on the
current average processing rate of 2.5 kg per month, approximately 21 months would be required
to process the 52 kg inventory) but cannot be known exactly.

3.0 COMMENTS RECEIVED AT THE PUBLIC MEETING HELD IN NORTH
AUGUSTA, SOUTH CAROLINA, DECEMBER 6, 1994

3.1 Comment by Mr. Bob Overman
You are wasting the taxpayers money to write an eis every time a product is used for a different
purpose. The lines have been running but since the purpose has changed, you have to do an eis.
But ,the process hasn't changed. Plutonium is plutonium. The hazards are the same no matter how
you re going to use it. I support the preferred alternative. I vote in favor of keeping going
(continued operation).

3.1.1 DOE Response
DOE agrees that the hazards involved in operating the HB-Line to support post-Cassini missions
are the same as those involved in current and previous operations. The preparation of this ea is
the result of the settlement of a suit filed against the Department by the Energy Research
Foundation of Columbia, South Carolina, as described in section 1.1.3. of the ea.

3.2 Comment by Mr. Lee Poe
You ought to include information on scrap and residue processing in the ea.

3.2.1 DOE Response
See the DOE response to Mr. Poe's similar question in Appendix A, section 2.2.1.

4.0 COMMENTS RECEIVED AT THE PUBLIC MEETING HELD IN
SAVANNAH, GEORGIA, DECEMBER 8, 1994

4.1 Comment by Mr. George Minot
Publish the information such as waste generation, in terms the public can understand.

4.1.1 DOE Response
Waste generation from HB-Line operations is given in section 5.1.6 of the ea. Table 5-4
describes the volume of waste, by waste type, generated by HB-Line operations, and shows the
total quantity of those wastes that exist at the Savannah River Site. Waste generation and waste
management at the Savannah River Site is a complex issue, and is the subject of an environmental
impact statement publish in draft in January 1995 (Savannah River Site Waste Management Draft
Environmental Impact Statement, DOB/eis-0217D).

4.2 Comment by Mr. George Minot
My concern is that I haven't read or heard in this meeting any real good reason to keep the process
running. The public needs more substantiation or commitment from NASA and the budget
process. I believe the HB-Line should be shut down or placed in a standby mode.

4.2.1 DOE Response
Section 1.0 and Table 1-1 of the ea have been extensively revised to more fully explain DOE's
obligation to provide Pu-238 for NASA missions, describe the existing Pu-238 inventory, and
explain the Federal budget process. In addition, DOE has provided a detailed discussion of the
issue of need for specification Pu-238 in sections 1.1.1 and 1.2.1 of this Appendix.

4.3 Comment by The Reverend Susan S. Dulany
I do not want spent nuclear fuel rods coming to Savannah, Georgia. I do not want it to get any
worse. I understand that SRS is one of the most dangerous sites in the United States.

4.3.1 DOE Response
The proposed action addressed in this environmental assessment does not involve shipment of
spent nuclear fuel to the United States. The Department is preparing an environmental Impact
Statement on a Proposed Nuclear Weapons Nonproliferation Policy Concerning Foreign Research
Reactor Spent Nuclear Fuel. The Draft eis will be available in April 1995 and a public meeting
will be held in Savannah, Georgia in May, 1995. This proposal could involve shipment of spent
nuclear fuel to the Savannah River Site. Savannah is one of 10 potential ports of entry for these
shipments.

5.0 COMMENTS AND QUESTIONS RECEIVED AT THE WORKSHOP HELD
IN NORTH AUGUSTA, SOUTH CAROLINA, JANUARY 18, 1994

5.1. Question
Is there an H-Canyon and HB-Line exhaust system emergency back-up? If not, the existing
exhaust stack could shut down the H-Canyon and HB-Line process when the stack liner collapses
and blocks the exhausted air.

5.1.1 DOE Response
The H-Canyon and HB-Line exhaust systems have multiple exhaust fans supplied by multiple
power sources.' However, the air exhausted from the H-Canyon and the HB-Line facilities flows
through only one stack. There is not an alternate flow path. A detailed safety review study of the
impact from the exhaust stack liner collapsing was evaluated, and concluded that the exhaust
airflow could be restored within 48 hours. This was determined to be an acceptable amount of
time to restore a ventilation flow path. The risk analysis of this event showed that static conditions
and typical air reversals would have negligible releases of radioactive materials.

5.2 Question
Does the negotiated settlement with ERF include/affect any SRS facilities besides FiB-Line? If so,
what are they and what are the provisions of the settlement?

5.2.1 DOE Response
The negotiated settlement between the Energy Research Foundation (ERF) and the Department of
Energy (DOE) only affects the HB-Line facility at the Savannah River Site. The provisions of the
settlements are described below.
1. DOE will prepare an Environmental Assessment (BA) that will address the National
Environmental Policy Act (NEPA) related issues raised by the plaintiffs in their motion
for partial summary judgment concerning the reprocessing of Plutonium (Pu)-238 in
HB-Line Phases I and III, including the impacts of reprocessing Pu-238 purchased
from Russia and the remaining U.S. inventory, and the need for future Pu-238
reprocessing at SRS.
2. DOE is reviewing its classification policies with a view to decrease the amount of
information that is classified and, consistent with that, DOE will review the classified
information that is relied on by the ea and will attempt to declassify all or as much of
the information as possible, but will prepare a classified appendix if necessary that
would include, if appropriate, the classified inventory of Pu-238, any proposed
classified uses of Pu-238 and related information.
3. DOE will issue a draft ea and, if appropriate, a proposed Finding of No Significant
Impact (FONSI), will solicit public comments, and will consider and respond to all
public comments received in issuing the final ea, and, if appropriate, the FONSI or
other appropriate final agency action.
4. Prior to completion of this new NEPA process, DOE will continue operating HB-Line
Phase I and III only to reprocess that quantity of Pu-238 needed to support the National
Aeronautics and Space Administration's Cassini mission.
5. DOE will provide ERF with a monthly update on the status of progress on the ea and
efforts to fulfill Cassini requirements.
6. The monthly updates described above will cease upon completion of the NEPA process
on the ea or upon completion of reprocessing Pu-238 in support of the Cassini
mission, whichever is later.
7. This Stipulation in no way limits the rights of plaintiffs to challenge the adequacy of the
ea to be prepared pursuant to this Stipulation.

6.0 COMMENTS AND QUESTIONS RECEIVED AT THE WORKSHOP HELD
IN SAVANNAH, GEORGIA, JANUARY 20, 1994

6.1 Question
If the Pu-238 is purchased from Russia or any other overseas country, how will it be shipped to
SRS?

6.1.1 DOE Response
The Russian material is contained in welded, stainless steel cans which~ are placed in a "Mound 1
Kilowatt Thermal (KW) Package." The Mound 1KW Packages are provided to Russia by the
United States. The Mound 1KW Packages have been evaluated analytically and tested to determine
its compliance with the applicable regulations for certification.
The Mound 1KW Packages are then placed inside International Shipping Organization (ISO)
containers which are locked and sealed with tamper indicating devices. The ISO containers are
transported by rail to St. Petersburg, a Russian seaport. The ISO containers are then loaded by
crane onto a Russian cargo vessel. The material then proceeds by ship, non-stop, to a designated
port.
Upon arrival in the designated port, the tamper indicating devices on the ISO containers are
inspected, and an exterior radiation survey is conducted. The ISO containers are then off loaded
from the Russian cargo vessel by crane onto the dock. The ISO containers are transferred to a
designated handling area where the Mound 1KW Packages are removed.~ Following removal from
the ISO containers, the Mound 1KW Packages are transferred by forklift onto Safe Secure Trailers
(SSTs). The SSTs are then transported by truck over interstate highways to SRS by the
Department of Energy Albuquerque Operations Office's Transportation Safeguards Division.

6.2 Question
Why, with all the past, present,. and future potential for contamination, do we continue to
manufacture or reprocess the elements, other than national security? Is the Cassini worth the risk?

6.2.1 DOE Response
The current and future mission of HB-Line Phases I and Ill is focused on processing plutonium
(Pu)-238 to be used in power sources for space exploration missions by the National Aeronautics
and Space Administration (NASA).
The safety of using the Pu-238 fueled power sources, called Radioisotope Thermoelectric
Generators (RTGs), on any particular mission is carefully analyzed, and then reviewed by an
Interagency Nuclear Safety Review Panel. This panel reports its results to the White House. The
decision to launch a satellite with nuclear materials aboard is made at the White House, either by
the Office of Science and Technology Policy, or by the PresidenL The decision is made on a risk-
benefit basis. The existing Environmental Assessment (ea) for HB-Line describes in detail the
risks associated with processing Pu-238 in the HB-Line facility. The ea currently being prepared
for processing Pu-238 for post-Cassini space missions, will also describe the risk of processing
Pu-238.
The RTGs are the only power systems that can meet the needs of deep space planetary missions.
These missions are too far from the Sun for solar panels to be effective, and the missions take too
long to use batteries. RTGs are referred to as an "enabling technology" for deep space missions.
The Voyager, Galileo, and Ulysses spacecrafts are examples of NASA missions that have used
RTGs to power instruments-on the spacecrafts. The Department of Energy has developed and
provided radioisotopes power systems for space and terrestrial missions for the past 30 years. The
scientific and technical knowledge gained from these space missions are vastly expanding our
knowledge of the universe.
Cassini, the first spacecraft to orbit Saturn and its moons, will conduct detailed studies of Saturn's
atmosphere, rings, magnetosphere, and moons. Information gathered from these studies may lead
to a better understanding of the evolution of the Earth's atmosphere.

6.3 Question
There is no treatment for exposure, once exposed, it is on a molecular level and you are a time-
bomb. Are there any special medical personnel to deal with the individual, or God forbid, mass
contamination?

6.3.1 DOE Response
Exposure levels at the Savannah River Site are maintained at or below the established Federal and
Department of Energy Savannah River Operations Office (DOE-SR) guidelines. For example the
Federal occupational exposure limit is 5 rem/year, while the DOE-SR occupational exposure limit
is 2 rem/year. Based on analysis, this level of exposure on an annual basis would not result in any
harmful effects.
The issue of a "time-bomb" would only apply in an acute case (a large dose over a very short
period of time) of exposure which SRS has never experienced. Medical and Radiological Control
Organization personnel are trained to handle contamination cases, whether individual or in mass.
The facilities are also equipped to handle personnel decontamination.
There are special medical techniques available, such as chelation and iodine pills, that help reduce
the body's absorption of radionuclides. The Eisenhower Medical Center at Fort Gordon in
IIAugusta, Georgia has special facilities to deal with contaminated and injured people. If the mass
contamination was external contamination, it would be handled onsite. However, if the accident
lead to large numbers of people with internal contamination, it would be handled by the
Eisenhower Medical Center.

6.4 Question
What do we as a community and a public have to gain directly and what is its ratio to the risk?

6.4.1 DOE Response
The benefit that the community and public receives from space exploration is in the advancement in
the understanding of our universe, while at the same time, providing economic support to the
communities.
The current and future mission of HB-Line Phases I and III are focused on processing Plutonium
(Pu)-238 to be used in power sources for space exploration missions by the National Aeronautics
and Space Administration (NASA).
The safety of using the Pu-238 fueled power sources, called Radioisotope Thermoelectric
Generators (RTGs), on any particular mission is carefully analyzed, and then reviewed by an
Interagency Nuclear Safety Review Panel. This panel reports its results to the White House. The
decision to launch a satellite with nuclear materials aboard is made at the White House, either by
the Office of Science and Technology Policy, or by the President. The decision is made on a risk-
benefit basis. The existing Environmental Assessment (ea) for HB-Line describes in detail the
risks associated with processing Pu-238 in the HB-Line facility. The ea currently being prepared
for processing Pu-238 for post-Cassini space missions, will also describe the risk of processing
Pu-238.
The RTGs are the only power systems that can meet the needs of deep space planetary missions.
These missions are too far from the Sun for solar panels to be effective, and the missions take too
long to use batteries. RTGs are referred to as an "enabling technology" for deep space missions.
The Voyager, Galileo, and Ulysses spacecrafts are examples of NASA missions that have used
RTGs to power instruments on the spacecrafts. The Department of Energy has developed and
provided radioisotopes power systems for space and terrestrial missions for the past 30 years. The
scientific and technical knowledge gained from these space missions are vastly expanding our
knowledge of the universe.
Cassini, the first spacecraft to orbit Saturn and its moons, will conduct detailed studies of Saturn's
atmosphere, rings, magnetosphere, and moons. Information gathered from these studies may lead
to a better understanding of the evolution of the Earth's atmosphere.

6.5 Question
With NASA cutbacks also forthcoming, will the Cassini mission be at all jeopardized?

6.5.1 DOE Response
NASA's fiscal year 1995 budget request of $14.5 billions contains full funding for the Cassini
mission, and NASA remains confident that its budget request will be supported by Congress. If
the full amount requested is provided, the Cassini mission will not be jeopardized. If however, the
full amount is not provided, a careful decision will be made as to which programs will not be
funded.

FINDING OF NO SIGNIFICANT IMPACT
OPERATION OF THE HB-LINE FACILITY AND
FRAME WASTE RECOVERY PROCESS FOR
PRODUCTION OF Pu-238 OXIDE
AT THE SAVANNAH RIVER SITE
AGENCY: Department of Energy
ACTION: Finding of No Significant Impact

SUMMARY: The Department of Energy (DOE) has prepared an environmental assessment
(ea), DOE/ea-0948, addressing future operations of the HB-Line facility and the Frame Waste
Recovery process at the Savannah River Site (SRS), near Aiken, South Carolina. Based on the
analyses in the ea, DOE has determined that the proposed action is not a major Federal action
significantly affecting the quality of the human environment within the meaning of the National
Environmental Policy Act (NEPA) of 1969. Therefore, DOE has concluded that the preparation
of an environmental impact statement is not required, and is issuing this Finding of No
Significant Impact.

PUBLIC AVAILABILITY:
Public meetings concerning the proposed future operation of HB-Line were held in North
Augusta, South Carolina, and Savannah, Georgia, on January 18 and 20, 1994, respectively. The
draft ea was forwarded to the States of South Carolina and Georgia and interested persons for
comment in October 1994. Public meetings to discuss the proposed action and the draft ea were
held in North Augusta, South Carolina, on December 6, 1994, and in Savannah, Georgia, on
December 8, 1994.
Copies of the ea and FONSI and further information on the DOE NEPA process are available
from:
A. B. Gould, Jr.
SR NEPA Compliance Officer
Savannah River Operations Office
U. S. Department of Energy
P. 0. Box A
Aiken, South Carolina 29802
Voice mail or facsimile transmission: 1-800-242-8269

BACKGROUND: The HB-Line facility and Frame Waste Recovery process are used to
produce plutonium-238 (Pu-238) oxide for use as a heat source in radioisotope thermoelectric
generators and light-weight radioisotope heater units for National Aeronautics and Space
Administration missions. DOE is currently producing Pu-238 oxide in the HB-Line facility and
the Frame Waste Recovery process for the National Aeronautics and Space Administration's
Cassini mission. DOE has prepared an ea to assess the environmental impacts of operating the
HB-Line facility and the Frame Waste Recovery process following completion of current
operations. The ea was prepared as a result of a settlement of a lawsuit filed against DOE by
the Energy Research Foundation of Columbia, South Carolina, on January 4, 1993. Current
operations were assessed in an ea prepared in 1991; a Finding of No Significant Impact was
issued in July 1991.

PROPOSED ACTION: The proposed action is for DOE to continue to operate and maintain
the Pu-238 processing facilities at the Savannah River Site and process the available inventory of
Pu-238 scrap material into a usable oxide powder to preserve the capability to support NASA
missions. Processing of the five kilograms of Pu-238 purchased from Russia and shipped to the
SRS in 1994 is included in the proposed action. The proposed action also includes shipment of
Pu-238 scrap material (Pu-238 in forms and isotopic content that is not usable as heat source fuel
without reprocessing) from DOE's Mound Laboratory, Miamisburg, Ohio, and the Los Alamos
National Laboratory, Los Alamos, New Mexico, to the Savannah River Site.

ALTERNATIVES CONSIDERED: In addition to the proposed action, DOE considered the
following alternatives:
(1)No Action. If this alternative were implemented, the Pu-238 processing facilities would
continue to operate until completion of the campaign for the Cassini Mission, currently
estimated to be June, 1995. Once this mission had been fulfilled, operation of these
facilities to support Pu-238 processing would be terminated. This alternative does not allow
for the processing of material to support future missions.
(2)Alternative Processing Facility. Implementation of this alternative would involve
processing Pu-238 material in facilities other than HB-Line and the Frame Waste Recovery
process. Except as discussed below, because no other such facilities currently exist
construction of new facilities would be required. Because this would be very costly, and
because process efficiency or safety of the technology incorporated in the HB-Line facilities
would not be improved upon, this is not considered a reasonable alternative.
2
(3)Alternative Vault Storage Facility. This alternative would involve using an SRS vault other
than the HB-Line vault for storage of Processed Pu-238. Other vault facilities would require
extensive modification to accommodate storage of Pu-238, while the HB-Line vault is
currently fully capable of storing Pu-238. Therefore, DOE does not consider modification
of other facilities to be a reasonable alternative.
(4)Processing at the National Laboratories. In the United States, only the SRS and the Los
Alamos National Laboratory have any capability to process Pu-238. The Los Alamos
National Laboratory (LANL) has proposed adding the capability to conduct small scale Pu-
238 processing for scrap recovery in the existing plutonium handling facility. A new Pu-238
processing capability at LANL would be limited to approximately 100 to 300 grams per
month, compared to SRS's 2,000 to 4,000 grams per month capacity. This is not considered
a reasonable alternative to completing the processing of the U.S. Pu-238 inventory at SRS
using existing, operating facilities at the SRS.
(5)Purchase of Pu-238 from Foreign Nations. This alternative would involve purchasing Pu-
238 from foreign nations rather than processing the U.S. inventory into specification oxide
powder using SRS facilities. Discussions with France and Great Britain have concluded that
kilogram quantities of Pu-238 could be made available by these countries sometime after
1999, but only after significant investment in new facilities. The U.S. has a contract in place
with Russia for the purchase of up to 40 kg of Pu-238 through 1997. Five kg of Pu-238
have been purchased from Russia and are currently stored at the SRS pending processing as
part of this proposed action. The necessary approvals and funding have been received for a
second purchase of approximately 4 kg. The Pu-238 oxide powder in the second purchase
should not require chemical processing in U.S. facilities prior to use in fuel pellet fabrication
operations. Funding for additional purchases of Pu-238 is not included in the planned DOE
Budgets for fiscal years 1995 and 1996. This alternative is not considered viable if DOE is
to be responsive to NASA requirements as they arrive in the near term.
(6)Alternative Packaging and Storage of Pu-238. This alternative would involve continued
operation of the Pu-238 processing facilities until completion of the campaign for the
Cassini mission. Once this mission had been completed, these facilities would operate to
stabilize Pu-238 scrap materials stored at the SRS to meet the long-term storage criteria for
plutonium. This alternative would require use of a new facility (the Actinide Packaging
Facility) being considered for other purposes at the SRS. The stabilized, packaged Pu-238
3
would be placed in an SRS vault. This alternative would ensure that material remaining at
SRS would meet the long-term storage criteria, but is not considered viable is DOE is to be
responsive to NASA requirements.

ENVIRONMENTAL IMPACTS: The potential consequences of the proposed action and
alternatives were considered in the environmental assessment to determine whether there would
be significant impacts due to the proposed action and the alternatives to ecological and cultural
resources, the socioeconomic conditions in communities surrounding the SRS, and air, water,
and the health and safety of the public and SRS workers.
No impacts to ecological or cultural resources, or to the socioeconomic conditions in
communities surrounding the SRS, are expected as a result of the proposed action. The HB-Line
is an existing facility that has been operating in several stages since 1985. Because no
modernization, construction, or additional employees would be required to implement the
proposed action, the only socioeconomic impact would be from the continued employment of
operational and maintenance personnel required to run the facility. Because no socioeconomic
impacts would result from the proposed action, no differential impacts on minority or low
income communities would result. The HB-Line facility was constructed in 1985 and is within a
previously developed and highly industrialized area. Therefore, no endangered species,
wetlands, cultural resources or other environmentally sensitive resources would be directly or
indirectly impacted by the proposed action.
Normal Pu-238 processing would result in air and surface water emissions. Principal non-
radiological air emissions would be carbon monoxide, nitrogen oxides, di-nitrogen oxide, nitric
acid, and hydrogen fluoride. Emissions would be within air quality limits. Pu-238 processing
operations would result in radiological emissions that would result in a dose of 0.005 millirem
per year to the maximally exposed offsite individual. Radiological emissions to surface water as
a result of H-Area operations, including Pu-238 processing, would result in a dose to the
maximally exposed offsite individual of 0.0017 millirem per year to the maximally exposed
offsite individual. Liquid effluent emissions are permitted by the South Carolina Department of
Health and Environmental Control under the National Pollutant Discharge Elimination System.
Air and water emissions resulting from normal operation of Pu-238 processing facilities are not
expected. to result in any adverse effects to the environment or human health and safety.
SRS worker exposures to radiation under normal operations would be controlled by established
procedures that require doses be kept As Low As Reasonably Achievable (ALARA) and limit
any individual's dose to 1.5 rem per year. Based on operations in 1993 and a maximum of 200
workers, DOE expects the average annual dose for Pu-238 processing facility radiation workers
from the proposed action would be less than 0.5 rem (or 500 millirem) per year. The cumulative
worker dose would not exceed 100 person-rem per year. Based on an occupational risk factor of
4 x 10-4 fatal cancers per person-rem, workers engaged in the operation of Pu-238 processing
facilities would not be expected to incur any health effects from radiation exposure.
Three types of waste would be generated from Pu-238 processing operations: low-level
radioactive waste, transuranic waste (including mixed transuranic waste), and radioactive liquid
waste. Liquid waste would be transferred from the Frame Waste Recovery Process to the high-
level waste tanks where it would be stored until it can be converted to borosilicate glass and
saltstone. Waste generated as a result of the proposed action would be a small fraction of the
waste being managed at the SRS and would require no new waste management facilities or
processes.
The consequences of facility accidents are evaluated in the environmental assessment. The
highest consequence accident, a severe earthquake, could result in two latent cancer fatalities in
the onsite population and five latent cancer fatalities in the offsite population. The probability of
this accident occurring is calculated as 1.7 x 10-4 per year. Impacts of other accidents are less
severe. There is no credible transportation accident that would result in the release of radioactive
material.

DETERMINATION: Based on the information and analyses in the BA, DOE has determined
that the proposed future operation of HB-Line and the Frame Waste Recovery process at SRS
does not constitute a major Federal action significantly affecting the quality of the human
environment within the meaning of NEPA. Therefore, an environmental impact statement is not
required.

Issued at Aiken, South Carolina, this 27 day of April, 1995.
Mario P. Fiori, Manager
Savannah River Operations Office
5

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ENVIRONMENTAL ASSESSMENT AND (FONSI) OPERATION OF THE HB-LINE FACILITY AND FRAME WASTE RECOVERY PROCESS FOR PRODUCTION OF PU-238 OXIDE AT THE SAVANNAH RIVER SITE

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