The US Uranium Enrichment Establishment is designed to serve as a reference tool, presenting the basic facts about the establishment woven into a coherent whole. Our aim is to enable readers to better understand, follow, and, to the extent possible, influence developments in the industry and at the enrichment plants. It is not an investigative report. Much of our information comes from official sources. We hope, however, that the report will give people wanting to examine in depth particular aspects of the industry a starting point for their research and a framework within which to work.

The report opens with background information on the process of uranium enrichment and the history of uranium enrichment in the United States. It then presents the roles of the major companies and agencies involved with the enrichment establishment starting with the United States Enrichment Corporation (USEC), created in 1993 and privatized in 1998, and the agency that now regulates enrichment operations, the US Nuclear Regulatory Commission. It outlines operations and facilities at the Paducah, Kentucky, and Portsmouth, Ohio, gaseous diffusion plants, the only two US plants that enrich uranium today, and notes major buildings at a third gaseous diffusion plant, located at Oak Ridge, Tennessee, which is no longer in operation. It then looks at USEC, or as appropriate, USEC and the US Department of Energy (DOE), in terms of a series of concerns: plant safety, national security, social issues, and the environment.

In regard to plant safety, the report notes that a fire in December 1998 in a process building at Portsmouth demonstrated weaknesses in emergency preparedness, and that at Paducah, which has operated with less down time because of equipment failures and incidents than has Portsmouth, earthquakes pose a threat that USEC has still not adequately countered. In terms of national security, the report shows that USEC plays a major role as US executive agent of the Russian HEU agreement but that the company has always been a somewhat reluctant player. Social issues are treated in terms of jobs and health. For workers at the plants, the possibility of layoffs has been a pressing matter ever since the US Congress began preparing the way for the privatization of enrichment operations, but massive cutbacks have not yet occurred; equally pressing for many former workers and for area residents is the question of the impacts of the plants on health, a question never adequately addressed. In our section on the environment, DOE is the main subject, since the agency, which owns and once ran the three gaseous diffusion plants, is responsible for cleaning up contamination and disposing of waste produced prior to 1993 and for decommissioning the facilities. DOE’s handling of contaminated scrap metal at the former K-25 plant at Oak Ridge, now known as the East Tennessee Technology Park, is setting a frightening precedent for the eventual decontamination and decommissioning of the Paducah and Portsmouth plants. Release of the metal is spreading radioactive material outside the plants, a situation that appears likely to repeat itself in regard to management of the massive amounts of depleted uranium hexafluoride, a byproduct of the enrichment process, stored at the enrichment sites.

The report closes with a look at uranium enrichment in terms of finances. USEC ended its 1999 fiscal year, June 30, 1999, on an upbeat note, as its revenue for FY 99 exceeded that for FY 98 despite a dim showing in the third quarter of FY 99. One of the reasons for the upturn was USEC’s indefinite suspension of plans to build a facility that would enrich uranium by the Atomic Vapor Laser Isotope Separation (AVLIS) process. AVLIS has never been deployed on the commercial level, and its abandonment appears to have been wise. However, USEC has yet to find the means of remaining profitable in future decades. Reliance on facilities almost fifty years old that devour electricity will not allow it to stay competitive indefinitely in the tight enrichment market.

In a sense, this report is a work in progress. The subject is vast, and the situation within the enrichment establishment is constantly changing. We hope to continue our monitoring and would welcome comments and observations on this presentation.

In September, 1998, Public Citizen and the Union of Concerned Scientists accused the NRC of concealing problems at the Paducah and Portsmouth plants in order to expedite the initial offering of stock to the public. They called on the Justice Department and the Securities and Exchange Commission to “‘immediately commence an investigation of this government-business coverup.’” According to Ralph Nader, the NRC brushed aside, in the weeks before and after the sale, a series of safety shortcomings listed in one of its own internal memos. The NRC and USEC denied the charges, stating that problems at the plants had been publicly aired.

The NRC underlined the need for safe management of the plants when it insisted that USEC pay an annual certification fee greater than that regularly applied to facilities with low-enriched uranium. It explained that gaseous diffusion plants “are subject to a relatively large number of credible accidents most of which have multiple initiating events. The potential on-site and off-site consequences posed by these accidents are significantly greater than those applicable to low-enriched uranium facilities.”

The NRC’s reports to Congress summarize the status of the plants from the point of view of the agency.

The most serious “event” at the two plants since the NRC took over regulation occurred December 9, 1998, and thus will appear in the third annual report to Congress. On that date a fire largely destroyed a cell in a side purge cascade in process building, X-326, at Portsmouth.

USEC hypothesizes that the fire resulted when an aluminum component of the process equipment became so hot that it initiated an aluminum/uranium hexafluoride reaction. Such a reaction is highly exothermic. NRC’s augmented inspection team (AIT) agreed with USEC’s evaluation of the cause but were critical of what the fire showed about firefighter training and emergency planning, and of some of the post-fire procedures at Portsmouth. For instance, the operations staff did not cut off the oil supply to the burning cell, emergency personnel failed to communicate the severity of the fire to management, and the plant did not properly inform government authorities of the accident.

USEC reported to the US EPA that radioactive material was released through the vents/stacks in the X-326 building and through fugitive emissions caused by the fire’s breaching the process piping and cell housing. In the latter case the radionuclides were released into the process building; subsequently an unknown quantity escaped to the atmosphere through roof ventilators. The interior metal surfaces in the side purge cascade where the fire took place were contaminated with technetium. Apparently the fire heated metal surfaces within the side purge cascade sufficiently to vaporize technetium that was sticking to them. “The chemical traps on the process vents became saturated and technetium was emitted to the atmosphere.”

A Lockheed Martin memo of January 6, 1999, states that an estimated 16.6 pounds of UF6 were released during the fire and that the estimated uranium to technetium ration was apparently between 0.4:1 and 0.17:1. . .

June 30, 1999 the NRC announced that it had proposed a $55,000 fine against USEC for failing to declare an alert under its emergency plan during the fire.

Both reports to Congress begin their sections on performance, with reservations about the condition of the plants. “The GDPs at Paducah and Portsmouth are more than 40 years old… They were built at a time when design standards and quality assurance standards were significantly different from current requirements, and documentation requirements were less stringent. The age of the facilities, some poor documentation of design and safety bases, and the requirements in effect when the plants were constructed have resulted in difficulties in maintaining the physical condition of the facilities. These shortcomings have challenged USEC’s performance during the period; however, both the material condition of the plants and the design and safety basis documentation are being upgraded.”

The 1997 report states that operational performance at both plants is “acceptable” but needs further improvement. USEC needs to increase its understanding of “the required level of performance and operational rigor,” among other things. The 1998 report distinguishes between the two plants. At Paducah overall performance was “adequate and continued to improve.” “However… plant staff training continues to be an area requiring improvement.” Early in the second review period, the NRC noted a decline “in the rigor and quality of some engineering analysis, “ but that decline was stemmed. The evaluation of Portsmouth was harsher.

At Portsmouth, overall performance was “adequate” and the conduct of plant operations “acceptable,” but “consistent implementation of Technical Safety Requirements, adherence to plant policies and procedures, and communications across plant organizations were areas in which improvements continued to be warranted.” . .

NRC indicated in its second annual report to Congress that USEC had completed or was scheduled to complete by the end of 1998 all Compliance Plan commitments for issues common to both plants, except Autoclave Upgrades scheduled to be complete by January 2, 1901, and Procedures Program, scheduled to be complete by March 3, 2002. Only three items awaited completion by the end of 1998. All issues specific to Portsmouth had been completed, except the removal of uranium enriched to greater than 10% uranium 235, which was to be resolved by January 31, 1999. All issues specific to Paducah had been completed, except the improvements in Seismic Capability of buildings C-331 and C-335. The last is not a minor matter.

The compliance plan to which USEC committed itself in November 1996 when the NRC granted the gaseous diffusion plants certificates of compliance required USEC to improve seismic safeguards in two buildings of the Paducah plants by December 31, 1997. The buildings were the C-331 and C-335 process buildings, which are similar to one another. The following year USEC asked for a delay in implementing the upgrades on the grounds that a delay would allow the NRC staff to review “new information...[that] calls into question the need for and effectiveness of the planned seismic upgrades.” The NRC moved the date for completion to June 30, 1999.

The agency recapitulated its position in the Compliance Plan section of the Compliance Evaluation Report for The Renewal of Certificate of Compliance GDP-1, issued in January 1999. “During the SAR upgrade project, DOE identified structural weaknesses in two of the main process buildings. Structural seismic loading capacity analyses indicated that significant structural damage could occur at peak ground acceleration levels...above 0.05 g. Buildings C-331 and C-335 were the affected buildings. At peak ground acceleration levels above 0.05 g, buildings C-331 and C-335 would suffer collapse of 20-foot wide sections of the roof and all four levels above ground. These sections traverse each building in three places. USEC is to modify buildings to strengthen building structures and increase the seismic capacity of the floor and roof sections to withstand a 0.16 g seismic event. The modifications are to be complete by June 30, 1999. The original completion date was December 31, 1997.”

Nevertheless, USEC is now seeking a further extension. According to Nuclear Fuel, Steven Toelle, USEC regulatory policy manager, wrote December 15, 1998 to NRC’s Robert Pearson, that the seismic modifications to C-331 and C-335 have “proven to be substantially more difficult than originally anticipated.” These problems, “coupled with the reduced worker productivity experienced in the high heat conditions of the process buildings, are projected to more than double the original estimated cost of the project and will result in a delay of approximately 12 months in the overall construction schedule.” USEC is asking that the compliance date be June 30, 2000. The original cost of the modifications was estimated to be $23 million, according to USEC’s Elizabeth Stuckle. USEC sent its desired change in the compliance plan to DOE December 11, 1998. After the company received DOE approval, it requested a delay from the NRC.2 The NRC posted a notice in the Federal Register of June 17, 1999, stating that it had received an amendment application from USEC and that it would receive comments for thirty days. Thus, the deadline for completion of the seismic upgrades passed before the NRC decided whether to extend the time limit.

Meanwhile, USEC has completed seismic modifications to equipment in buildings C-310 and C-315. These modifications were not part of the original Compliance Plan (the buildings’ accumulators, which contain UF6 and could have failed at a seismic level of 0.05g had been overlooked because their capacity was incorrectly reported in the site’s SAR). The equipment was the subject of a Confirmatory Order Modifying Certificate in April 1998. The accumulators and other items have now been strengthened to withstand an acceleration of 0.165g.

Radioactive scrap metal and depleted uranium are found in enormous quantities at the gaseous diffusion plants. If DOE goes ahead with current plans, products made from both materials are likely to be widely used outside of nuclear plants.

The NRC is in the process of making a rule concerning management of “materials and equipment having residual radioactivity ,” and has already determined that the rule will permit release and reuse of these materials. A memorandum of June 30, 1998, from John C. Hoyle, Secretary of the Commission, to L. Joseph Callan, Executive Director for Operations, stated “The rulemaking should focus on the codified clearance levels above background for unrestricted use that are adequately protective of public health and safety. This level should be based on realistic scenarios of health effects from low doses that still allows quantities of materials to be released. The rule should be comprehensive and apply to all metals, equipment, and materials, including soil. If problems that would delay completing the rulemaking arise in certain categories of solid materials, then a decision can be made to narrow the scope of the rule.” (italics added; underlining in source)

The EPA, after taking tentative steps towards establishing a standard for release of slightly contaminated materials, has in effect handed the issue over to the NRC. Under the leadership of the NRC, an Interagency Steering Committee on Radiation Standards met June 10, 1999. “Facilitated public meetings” on NRC’s rulemaking will be held in Chicago, Atlanta, San Francisco, and Washington, DC in late summer and fall of 1999. The deadline for comments from the public is November 15, 1999. Meanwhile, DOE is quietly releasing radioactive metal on a case by case basis from sites across the country. The metal goes to metal processing facilities and then to manufacturers of products, without any warning label. Consumers who buy contaminated items will not know the suspect origin of the metal in their purchases. Items made from radioactive metal may be freely melted down and the metal reused.

DOE has selected Oak Ridge as the lead site for its National Scrap Metal Reuse/Recycle Program. Oak Ridge is thus, DOE says, to “play a major role in reducing waste dispositioning costs across the DOE complex. Commitment by other DOE sites to supply scrap metal and use the finished products is the key to the success of the program.”1 Presumably most, if not all, scrap metal from Portsmouth and Paducah deemed to be recyclable will be sent to Oak Ridge for handling. The Oak Ridge-based program was in 1997 “developing a business plan to identify opportunities and commitments at other sites.” It intended to “establish commitments” in 1998 and 1999.

August 25, 1997, DOE entered into a $284 million, six-year, noncompetitive contract with British Nuclear Fuels Ltd. (BNFL) for the decommissioning of the K-29, K-31, and K-33 process buildings at ETTP. In the words of CROET, the company will “clean up” the buildings “for eventual industrial use, plus recycle a vast majority of the valuable material recovered from the buildings for reuse. This is a first-of-a-kind contract to decontaminate and decommission U.S. gaseous diffusion plants.” That it is the first means that it sets a dangerous precedent.

By the terms of the contract BNFL receives title to radioactive metal within the buildings and can remove from the buildings and sell for profit up to an estimated 126,000 tons of radioactive nickel, aluminum, copper, and steel scrap. BNFL will subcontract for disposition of the metal with its subsidiary the metal smelter Manufacturing Sciences Corporation (MSC), which is licensed by the state of Tennessee. Tennessee regulators will therefore determine up to what level of radiation, material can be released and reused. The contract put no limitations on end use. Thus the metal will be able to be melted down and used in consumer products. Possible uses range from cookware, through children’s gym sets, to dental braces. On March 26, 1999, the Tennessee Department of Environmental Conservation (TDEC) approved, without public input, an amendment to the license of Manufacturing Sciences Corporation allowing it to release nickel from the uranium enrichment cascades that has volumetric contamination, i.e. radioactivity throughout rather than only on the surface.

The Oil, Chemical, and Atomic Workers Union (OCAW; now PACE), the Nuclear Information and Resource Service (NIRS), and various other organizations sued DOE and BNFL under the National Environmental Policy Act. They asked for a full environmental review before execution of the cleanup. Judge Gladys Kessler ruled for the government, June 30, 1999. She agreed with DOE that BNFL’s plan to sell metal for reuse was “an integral part of the overall project under Superfund” and “not subject” to a separate review under NEPA, but she noted that there is “ample evidence that the proposed recycling significantly affects the quality of human environment.”

The Green Scissors campaign, sponsored by Friends of the Earth, Taxpayers for Common Sense, and the U.S. Public Interest Research Group and supported by a wide variety of consumer, health, and environmental organizations called on DOE to cancel the contract with BNFL, saying that cancellation would save taxpayers $251.6 million over the remaining years of the contract, that leaving the buildings in their current state does not “pose a high-priority health and safety risk compared with the rest of the Oak Ridge site,” and that retaining the contract will result in production of consumer goods that will cause “continuous, routine and unwitting exposure to radioactivity.”