Introduction: A License to Pollute? The U.S. Nuclear Regulatory Commission (NRC) stands poised to approve a significant license amendment for American Centrifuge Operating, LLC (ACO). This amendment, outlined in the Environmental Assessment (EA) for the American Centrifuge Plant (ACP) in Piketon, Ohio, would extend the High-Assay Low-Enriched Uranium (HALEU) demonstration cascade operation until June 30, 2034, and substantially increase its uranium hexafluoride (UF6) possession limit. The EA, issued by the NRC's Environmental Center of Expertise, concludes with a "Finding of No Significant Impact" (FONSI), asserting that the proposed action would not significantly affect the quality of the human environment. This conclusion is based on the premise that the project involves no new construction, no increase in production rates, and its impacts are merely an extension of "previously assessed impacts".

However, a closer examination reveals that this Environmental Assessment is not a neutral scientific document but a carefully constructed narrative designed to facilitate continued operation despite profound, documented environmental and public health consequences. The EA’s conclusion of "no significant impact" is a dangerous fallacy, one that systematically ignores decades of contamination, regulatory failures, and a severe, ongoing health crisis in the surrounding community. This investigative report aims to be the antithesis of the official narrative, meticulously dissecting the EA’s claims and contrasting them with verifiable scientific data, historical records, and the grim realities faced by Piketon residents. The objective is to expose the inherent flaws and omissions, providing honest facts that reveal the true risks of extending nuclear operations in a region already burdened by a toxic legacy.

Chapter 1: A Shadow Over Pike County: The Unacknowledged Past The American Centrifuge Plant does not operate in a vacuum; it sits on the historical grounds of the Portsmouth Gaseous Diffusion Plant (PORTS), a site with a deeply troubling environmental record. PORTS, which began enriching uranium in 1954, is currently undergoing extensive remediation due to widespread environmental contamination. This history is not merely background noise; it is a critical context that the EA largely dismisses, claiming that the proposed action "would have no new impact on socioeconomics, noise, or public health and safety, except that the potential for previously assessed impacts would be extended by up to 9 years". This framing implies that past contamination is either resolved or irrelevant to the current assessment, a profoundly misleading assertion.

Decades of uranium enrichment at PORTS have resulted in pervasive contamination of buildings, structures, soil, sediments, surface water, and groundwater with radioactive and hazardous wastes. The site’s environmental compliance history is a "shocking chronicle of repeated failures," marked by chronic violations of National Pollutant Discharge Elimination System (NPDES) permits for discharges into local waterways. Records are replete with notices of violation, including multiple Total Suspended Solids (TSS) violations, Trichloroethylene (TCE) violations, and frequent fluoride exceedances. Federal findings have identified "systemic issues with Fluor's self-monitoring program" and a pattern of delayed or inadequate reporting of incidents. Disturbingly, radioactive cylinders at PORTS have been confirmed to be leaking, and contaminants like Neptunium-237 (Np-237) and Technetium-99 (Tc-99) have spread, with Np-237 contamination linked to the use of "recycled uranium" from plutonium production reactors. The Np-237 plume at the X-701 location is particularly concerning, as evidence suggests it is discharging directly into Little Beaver Creek. Furthermore, significant accidental releases have occurred, including a massive 1978 UF6 cylinder rupture that released 21,000 pounds, a 1985 uranium release exceeding 50 kilograms, and a 1998 Cascade Fire that released radioactive material.

The EA's assertion that these resources were "all considered in the 2006 environmental impact statement (EIS) for the commercial ACP (NUREG-1834), 2021 EA for HALEU cascade, 2024 EA for possession limit increase, and 2024 EA for additional 6 month operating license" highlights a critical regulatory blind spot. The reliance on this "bounded by previous assessments" approach suggests a dangerous regulatory practice. The EA's logic implies that since the current action does not change the rate of production or involve new construction, the environmental impacts are essentially the same as those previously deemed acceptable, merely extended in time. However, the extensive documented history of chronic, systemic environmental negligence and severe, ongoing public health crises at the PORTS site directly contradicts this. These are not simply "previously assessed impacts" that can be extended; they represent a fundamental failure of past assessments to protect the community. By relying on this approach, the NRC avoids re-evaluating the cumulative, long-term, and potentially escalating impacts of continued operation on an already compromised environment and population. This creates a regulatory loophole where historical failures are not addressed but become the baseline for "acceptable" future impacts, effectively perpetuating harm and undermining the National Environmental Policy Act (NEPA)'s intent to prevent environmental damage.

The human cost of this toxic legacy is starkly evident in Piketon's grim statistics. Pike County bears "the horrific burden of some of the highest cancer and mortality rates in the state," a crisis inextricably linked to the toxic shadow of PORTS. A 2023 health study revealed alarming levels of Tc-99 throughout the region, directly traceable to PORTS. From 2021 to 2023, Pike County's premature death rate for those under 74 years old was 107% higher than the national average, a significant increase from 85% between 2017 and 2020. This period saw over 750 premature deaths in a county with a population of just over 27,000. Cancer rates in Pike and six neighboring counties were 17.5% above the national average from 2015 to 2019. Infant mortality rates in the region were 31.9% higher than the U.S. average from 1999 to 2020, and middle-aged adults experienced mortality rates more than double the national average. In 2019, Zahn's Corner Middle School in Piketon was permanently closed after radioactive isotopes, including enriched uranium and Neptunium-237, were found inside.

The EA's assertion of "no new impact" on public health and safety is a gross misrepresentation, ignoring the cumulative and ongoing health crisis directly tied to the site's operations. By framing the current project as merely an "extension" of "previously assessed impacts," the EA absolves itself of the responsibility to genuinely address the site's historical and current dangers. This demonstrates a profound issue of environmental injustice. Pike County's residents are experiencing severe health consequences directly linked to the PORTS plant, and their anguish is compounded by a "perceived indifference and obfuscation from authorities". The EA, by extending the license and possession limits without a comprehensive re-evaluation of the site's cumulative impacts, effectively perpetuates the exposure of this already vulnerable community to further risks. This reveals a systemic failure to prioritize public health and environmental protection over industrial operations, particularly in communities that have historically borne the brunt of such activities. The facts reveal a pattern where the economic benefits of continued operation are prioritized over the well-being of the local population, a direct contradiction to the spirit of environmental protection.

To underscore the severity of the situation, Pike County's premature death rate for those under 74 years old was 107% higher than the national average from 2021-2023, increasing from 85% between 2017-2020. Cancer rates in Pike and six neighboring counties were 17.5% above the national average from 2015-2019. Infant mortality rates in the region were 31.9% higher than the U.S. average from 1999-2020, and middle-aged adults experienced mortality rates more than double the national average. In 2019, Zahn's Corner Middle School in Piketon was permanently closed due to enriched uranium and Neptunium-237 findings. A 2023 health study found alarming levels of Technetium-99 throughout the region, traced directly to PORTS. This information highlights the stark difference between the EA's dismissive language and the concrete, devastating realities faced by the community.

Chapter 2: Air We Breathe, Truth We Deny: Questioning Emissions and Health Claims The EA's assessment of air quality and radiological impacts relies heavily on meeting regulatory limits, yet a deeper look reveals significant oversights and a fundamental misunderstanding of long-term environmental and health consequences.

The EA identifies hydrogen fluoride (HF) as the "major non-radiological hazardous air emission," stating that its concentrations "would continue to remain many orders of magnitude below the Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (as an eight-hour average) of 2500 µg/m3". This claim, however, relies solely on meeting a single, acute occupational exposure limit and ignores the potential for chronic, low-level exposure effects on the public. HF is a corrosive chemical that, even at lower levels, can severely irritate the eyes and skin, and inhaling it can irritate the lungs, cause pulmonary edema, headaches, dizziness, nausea, and vomiting. More critically, chronic (long-term) exposure to low levels of HF has been linked to irritation and congestion of the nose, throat, and lungs. Prolonged exposure to very high concentrations can lead to "Fluorosis," a debilitating bone disease characterized by fluoride deposits in bones and teeth, causing bone pain, fractures, and disability. The California Environmental Protection Agency (CalEPA), recognizing these long-term risks, has established a chronic inhalation reference exposure level (REL) for HF of 0.014 mg/m3 (14 µg/m3), a level significantly lower than the OSHA PEL and based on bone effects. The EA's reported HF concentrations (e.g., 3.96e-7 µg/m3) are indeed orders of magnitude below the OSHA PEL, but the OSHA PEL is an acute occupational limit, not a chronic one designed for continuous, long-term exposure to the general public. The EA's reliance on this inappropriate benchmark conceals the potential for chronic harm.

Regarding radiological releases, the EA claims the proposed action "would not result in any significant change in effluent released offsite or significantly increase any individual or cumulative occupational radiation exposure". It reports public exposure to the nearest resident as 2.6e-7 mSv (2.6e-05 millirem), stating this is "well below the regulatory limit of 1 mSv (100 mrem)". Uranium concentrations at the site boundary are similarly claimed to be "roughly six orders of magnitude below the NRC regulatory limit of 1e-12 µCi/mL". This assessment fundamentally relies on the linear no-threshold (LNT) model being definitively "safe" at low doses, while simultaneously ignoring the significant chemical toxicity of uranium.

The LNT model, which underpins current radiation regulation, postulates that every fraction of ionizing radiation, no matter how small, carries an increased cancer risk. However, this model is subject to significant scientific debate. Epidemiological data provides "essentially no evidence for detrimental health effects below 100 mSv," and some studies even suggest beneficial (hormetic) effects at low doses. The LNT model is widely considered a "theoretical statistical model," viewed by many as "conservative," with "little scientific evidence that small variations in radiation exposure... result in any increase in cancer risks". Despite this ambiguity, the LNT model remains the basis for current regulation. The EA's reliance on "well below regulatory limits" means it adheres to a model that assumes any dose carries a risk, yet simultaneously dismisses the significance of those low doses. This creates a paradox where the regulatory framework acknowledges a risk at all levels, but the EA then minimizes these risks as "insignificant" when they fall below a certain threshold.

Beyond its radioactivity, uranium is a heavy metal with significant chemical toxicity. It is classified as a CARCINOGEN in humans, with documented links to lung, larynx, and bone cancers. Many scientists contend there is "no safe level of exposure to a carcinogen". Uranium can also damage the kidneys, liver, and blood cells, potentially leading to anemia and permanent scarring of the lungs (pneumoconiosis) from repeated exposure. While kidney damage from ingesting large amounts is the most likely adverse effect, even low concentrations in drinking water can cause nephrotoxic effects. The EA notes that uranium concentrations at process building vacuum vents are below OSHA's PEL for soluble uranium compounds (0.05 mg/m^3 or 5e-11 g/mL). However, similar to HF, this PEL is an 8-hour average, not a chronic exposure limit for the general public. Furthermore, uranium binds to soil and can be taken up by garden produce and forage crops, establishing a pathway for chronic ingestion that is not adequately addressed by air concentration limits.

The EA's use of the "maximally exposed individual" as a statistical construct further obscures the true picture. This individual is defined as being at a former Mobile Equipment Maintenance Shop within the DOE reservation, now an office building "further from the ACP," and this location is used as a "conservative assumption". This theoretical construct fails to account for the real-world, cumulative exposures of residents living in the broader Piketon area, particularly given the site's documented history of widespread contamination.

The EA’s declaration of emissions as safe, based on regulatory limits and "conservative assumptions," does not fully account for chronic, cumulative exposure risks, especially for chemical toxins like HF and uranium. The historical context of Piketon, with its documented widespread contamination and chronic health issues, means that any additional release, even if "below regulatory limits" for a pristine site, contributes to an already elevated cumulative burden on the environment and population. The "maximally exposed individual" concept is a theoretical construct that fails to capture the reality of a community living with decades of accumulated toxic exposure. This exposes a critical flaw in environmental assessments for brownfield or historically contaminated sites: simply meeting standard regulatory limits for new emissions is insufficient when the baseline environment is already severely compromised. The EA fails to conduct a true cumulative impact assessment that accounts for the existing toxic load and the synergistic effects of multiple contaminants, thus providing a misleading picture of safety.

Moreover, the EA's assertion that radiation doses are "well below regulatory limits," while technically compliant with the LNT model, creates a "safe dose" paradox. The LNT model itself, while the basis for regulation, implies any dose carries risk. For a public already experiencing high cancer rates and distrusting authorities due to past cover-ups, such technical assurances ring hollow. The EA's language, while adhering to NRC regulations, does not address the public's legitimate concerns about any additional exposure in an already contaminated environment. This highlights a fundamental disconnect between regulatory compliance and public perception and trust, especially in communities with a history of environmental injustice. The EA's narrow focus on meeting numerical thresholds, without transparently addressing the complexities of low-level radiation science or the cumulative impact on a vulnerable population, erodes public confidence and fuels anti-nuclear sentiment.

A comparison of the ACP's reported emissions against various health thresholds and the historical context of the site highlights discrepancies in the EA's assessment. For Hydrogen Fluoride (HF) Concentration, the EA reports 3.96e-7 µg/m3 (maximally exposed individual) for July-Dec 2024, which is below the OSHA PEL (8-hr avg) of 2500 µg/m3. However, the OSHA PEL is an acute occupational limit, not for chronic public exposure; the CalEPA Chronic REL is 14 µg/m3, and chronic HF exposure can cause irritation, congestion of lungs, and skeletal fluorosis. For Total Public Radiation Exposure (July-Dec 2024), the EA reports 2.6e-7 mSv (2.6e-05 mrem), which is below the NRC Regulatory Limit of 1 mSv (100 mrem). While technically compliant, the LNT model suggests any dose carries risk, and Piketon has elevated cancer rates. Uranium Isotope Concentrations at the Site Boundary (U-234: 2.79e-18 µCi/mL; U-235: 1.95e-19 µCi/mL; U-238: 6.31e-19 µCi/mL) are reported below the NRC Regulatory Limit of 1e-12 µCi/mL. However, uranium is a human carcinogen and chemically toxic to kidneys, liver, and blood cells. For Uranium Chemical Toxicity at Process Building Vents (U-234: 4.7e-15 g/mL; U-235: 9.5e-13 g/mL; U-238: 2.0e-11 g/mL), these are below the OSHA PEL for soluble uranium (8-hr avg) of 5e-11 g/mL. Yet, the OSHA PEL is an acute occupational limit, and uranium binds to soil and crops, posing chronic ingestion risk. Historically, the site's "previously assessed impacts would be extended" rather than re-evaluating the cumulative burden, despite documented widespread contamination including leaking cylinders, Np-237 & Tc-99 plumes in groundwater/air. This information underscores that current regulations may be insufficient to protect public health, especially in historically impacted areas.

Chapter 3: Workers on the Front Lines: Overlooked Hazards and Long-Term Costs The EA's discussion of occupational health and safety is strikingly brief and superficial, asserting that the proposed action "would not result in any significant change... or significantly increase any individual or cumulative occupational radiation exposure". It relies on the 2006 EIS, which concluded "SMALL" impacts due to an "existing radiation protection program" and an administrative limit of 10 mSv (1,000 mrem), well below the NRC limit of 50 mSv (5,000 mrem). This assessment focuses on meeting numerical limits and existing programs, but critically fails to acknowledge the inherent risks and long-term health consequences faced by workers handling radioactive and hazardous materials over decades.

The site's history, however, tells a different story of human cost. The Portsmouth Gaseous Diffusion Plant (PORTS), where the ACP is located, has a documented legacy of worker illnesses. Former A-plant workers have reported suffering from cancer, respiratory, and cardiovascular issues, with some tragically passing away from their illnesses. The local activist group "Don't Dump On Us" maintains a compiled list of cancer victims from the community that "grows every single day," a list that includes workers directly impacted by the plant's operations.

This reality directly contradicts the EA's assurances of "no significant impact." While the EA focuses on compliance with dose limits, the fact that workers are exposed to radioactive and chemically toxic materials like UF6, HF, and various uranium isotopes for extended periods means they are inherently accepting a higher level of risk than the general public. Uranium, for instance, is a known human carcinogen, causing lung, larynx, and bone cancers, and can damage kidneys, liver, and blood cells, potentially leading to permanent scarring of the lungs (pneumoconiosis). Similarly, HF exposure can cause severe respiratory damage and, from chronic exposure, potentially lead to skeletal fluorosis. The EA's framing of these exposures as "SMALL" and "well below regulatory limits" implies that the risk is negligible. However, the documented health issues among former workers directly challenge the notion that these "small" exposures are without significant long-term consequences. The existence of a "growing list of cancer victims" indicates that the "acceptable" limits are not preventing severe harm.

The EA's reliance on an "existing radiation protection program" is also concerning given the historical context. The PORTS site has a documented pattern of "environmental negligence, systemic regulatory failure, and a web of culpability involving the plant's operators, federal and state authorities". This historical record strongly suggests that "existing programs" have been insufficient to prevent widespread contamination and worker harm. This exposes a systemic issue in the nuclear industry where occupational health assessments often prioritize regulatory compliance over the actual long-term well-being of workers. The "administrative limit" being lower than the NRC limit is a token gesture if the cumulative exposures still lead to severe illnesses. It suggests that the industry and regulators implicitly accept a certain level of worker morbidity and mortality as an "externalized cost" of operation, which represents a profound ethical and societal failing.

Documented health impacts on PORTS workers and the community include former A-plant workers reporting cancer, respiratory issues, and cardiovascular issues, with some having passed away from their illnesses linked to plant operations. The "Don't Dump On Us" group maintains a growing list of cancer victims from the community, including workers. Uranium is a known human carcinogen causing lung, larynx, and bone cancers, and can damage kidneys, liver, and blood cells, potentially leading to pneumoconiosis. Chronic exposure to hydrogen fluoride can cause irritation and congestion of the nose, throat, and lungs, as well as skeletal fluorosis. The PORTS site has a history of "environmental negligence, systemic regulatory failure, and a web of culpability". This information highlights the severe, real-world health consequences for both workers and the community, challenging the EA's assurances of safety.

Chapter 4: The Illusion of "No Significant Impact": A Regulatory Farce The core of the EA's argument for extending operations is its "Finding of No Significant Impact" (FONSI). This conclusion is rooted in a narrow interpretation of environmental review, claiming that because the proposed action involves no new construction, no increase in enrichment or production capacity, and operations remain within existing buildings, there are "no new impacts" on most resource areas, and previously assessed impacts would merely be "extended by up to 9 years". This approach, however, represents a fundamental flaw in the application of environmental regulation, transforming NEPA's intent from a "vital guardrail" into a mechanism for perpetuating existing harms.

NEPA requires federal agencies to consider the environmental impacts of their actions, with a tiered approach to reviews: Categorical Exclusions (CATEX), Environmental Assessments (EA) leading to a FONSI, or full Environmental Impact Statements (EIS). An EA is conducted to determine if a full EIS is necessary, and a FONSI is issued if no significant impacts are expected. The EA in question explicitly states that under 10 CFR 51.31, an EIS is not required. This decision is based on the premise that the current activities are merely a continuation of previously approved operations, thus their impacts are "bounded" by prior assessments.

This reliance on "bounded by previous assessments" is a critical regulatory loophole. It suggests that if an activity has been assessed before, even if that assessment was inadequate or if new information reveals chronic, severe impacts, simply continuing the activity at the same rate does not trigger a more rigorous review. The documented history of the PORTS site—with its chronic environmental violations, widespread contamination, and alarming health statistics in Pike County—demonstrates that past assessments, including the 2006 EIS for the commercial ACP, failed to prevent significant environmental damage and public health crises. By framing the current project as merely an "extension" of "previously assessed impacts," the EA absolves itself of the responsibility to genuinely address the site's historical and current dangers. This perpetuates a regulatory blind spot where historical failures are not rectified but become the baseline for "acceptable" future impacts.

Furthermore, the EA's consideration of "Alternatives to the Proposed Action" is perfunctory. It considers only one alternative: the "no-action" alternative, which is defined as denying the proposed action. The EA dismisses this alternative, stating it "would provide no environmental safety or protections compared to the proposed action" and would prevent ACO from meeting its DOE contract terms. This is a profound misrepresentation of the "no-action" alternative's purpose under NEPA. Recent amendments to NEPA, including those in the ADVANCE Act Section 501, require agencies to consider the negative environmental impacts of not implementing a proposed action. This means evaluating the full range of potential environmental, public health, and societal impacts associated with both the proposed action and the no-action alternative, including the overall benefit to society. By narrowly defining "no-action" as simply ceasing operations without acknowledging the potential for alternative, less harmful energy solutions or the benefits of preventing further contamination, the EA fails to meet the spirit and letter of NEPA. It ignores the opportunity to transition away from a problematic technology and instead locks in continued reliance on a facility with a proven track record of harm. The choice is presented as either continuing operations or doing nothing, rather than exploring genuinely safer and more sustainable alternatives.

The EA's approach demonstrates a systemic issue in how environmental reviews are conducted for existing nuclear facilities. By focusing on incremental changes rather than the cumulative, long-term impacts on an already compromised environment and population, the assessment undermines NEPA's fundamental purpose. The NRC, in this instance, appears to be using the EA process to rubber-stamp continued operations rather than to rigorously evaluate and mitigate environmental harm. This narrow interpretation of "significant impact" and the dismissal of meaningful alternatives transform the environmental review process into a bureaucratic exercise rather than a genuine safeguard for public health and the environment.

Chapter 5: The Unseen Burdens: Waste, Transport, and Decommissioning Beyond the immediate operational impacts, the continued enrichment activities at Piketon carry significant long-term burdens related to waste management, transportation, and eventual decommissioning—costs and risks that the EA largely downplays or omits.

The EA states that the proposed action "would not result in any increase in waste shipments" and that waste storage on-site is "largely low-level waste of personal protective equipment and other wastes generated during routine maintenance and operations". It estimates seven B-25 boxes of low-level waste per 3-year option period, totaling up to 21 boxes over 9 years, stored on-site. The EA explicitly states that future waste generated during decontamination or decommissioning is the responsibility of the DOE and not included in its estimates. This omission is a critical flaw.

The long-term storage of nuclear waste, including HALEU and depleted uranium tails, presents immense challenges for which no permanent disposal solution currently exists in the United States. The Department of Energy (DOE) currently manages approximately 700,000 metric tons of depleted uranium tails in about 63,000 metal cylinders at storage yards in Paducah, Kentucky, and Portsmouth, Ohio. These tails are dangerous to human health and the environment, and the uranium hexafluoride in which they are stored is radioactive and forms highly corrosive and potentially lethal compounds if it contacts water. Storing these tails indefinitely incurs significant ongoing costs, estimated at about $4 million per year. The EA's decision to exclude decontamination and decommissioning waste from its assessment is a deliberate sidestepping of a massive, unresolved environmental and financial liability. The cleanup of federal uranium enrichment facilities, including Portsmouth, is a complex challenge estimated to continue for decades, with costs for the Portsmouth site alone projected to be between $11.5 billion and $12.5 billion. Decommissioning nuclear facilities typically takes 15 to 30 years, or many decades more if an interim safe storage period is applied for radioactive decay, with the U.S. requiring completion within 60 years. These immense, long-term costs and environmental responsibilities are externalized from the current EA, creating a misleading picture of the project's overall impact.

Regarding transportation, the EA states that ACO "does not currently ship any HALEU or tails offsite" and the proposed action "does not include any plans to add offsite shipments of HALEU or tails". It notes that continued operations would require approximately two 30B fuel cylinders of feed material shipped to the site per year, for a total of about 18 cylinders over 9 years. The EA concludes that "potential impacts of transportation are bounded by previously assessed impacts". This assessment minimizes the inherent risks associated with transporting nuclear materials. While the number of shipments for this specific project might seem small, the transportation of radioactive and hazardous materials carries significant risks, including potential accidents and security concerns.