34 Questions the NRC Never Actually Answered About GLE's Laser Enrichment Project

Picture this. Your son or daughter gets hired for a job at GLE's Laser Enrichment Facility. Before their first day, the safety report is supposed to tell them how much radiation they'd actually be exposed to, working in that specific location, doing that specific job, at this specific site. Instead, the number they're handed comes from a safety study written for a different enrichment plant somewhere else, a study that's still just a draft and hasn't even been finished yet. It says "worker exposure is fine," but nobody ever measured the radiation levels in the actual location where your kid would be clocking in for the next couple of years.

If these jobs are coming, and a lot of folks here want them, doesn't it make sense to want them to actually be safe jobs? That's not anti-jobs. That's just making sure the people taking those jobs know what they're walking into.

Here's the part that might surprise you. That story above isn't a metaphor. It's close to what's actually written in the NRC's Draft Environmental Impact Statement (DEIS) for GLE's Laser Enrichment project, and you can check it yourself.

The shortcut, in plain terms

One thing worth being clear about before we go further: this isn't GLE's homework we're picking apart. GLE submitted its own Environmental Report as part of its license application back in June 2025, and that's a separate document. What we're looking at here is the NRC's own Draft Environmental Impact Statement, the federal agency's independent review, prepared under its own NEPA obligations. The DEIS itself says NRC staff "developed evaluations of environmental impacts independently from the applicant" (page 1-6). So when 34 issues get resolved by borrowing from a draft document written for a different kind of facility, that's a call the federal regulator made in its own report, not something that slipped past anyone.

NEPA, the National Environmental Policy Act, exists to make sure federal agencies actually look before they leap. Before the NRC can approve a license for a project like this, the law requires a real evaluation of the environmental effects, the kind of effects that are "reasonably foreseeable" for this site (42 U.S.C. § 4332(2)(C)(i)).

But for 34 separate environmental and safety issues, that's not what happened here.

On page 1-7 of the DEIS, in Section 1.4.3, the NRC explains that it leaned on a document called NUREG-2249, the "Generic Environmental Impact Statement for Licensing of New Nuclear Reactors."

Two things are worth sitting with there. First, that document was written for nuclear reactors, not uranium enrichment facilities like GLE's Laser Enrichment Facility.

Second, and this is the part that should raise eyebrows, it's still a draft. The DEIS says outright that "the NRC is proposing to revise its regulations to codify" it. In other words, it hasn't been finalized or adopted as binding NRC policy. It's an unfinished document, written for a different kind of facility, being used as the foundation for conclusions about ours.

The DEIS describes how staff did a "crosswalk" between that reactor document and GLE's Laser Enrichment Facility, and decided that 34 of the reactor document's "Category 1" issues could be carried over wholesale. The exact sentence, on page 1-7, reads: "This EIS incorporates NR GEIS Category 1 technical analyses and findings... for 34 environmental issues that are relevant to the proposed action."

What that meant in practice

Flip to pages 3-1 and 3-2, and the DEIS spells out what "incorporating" those findings actually involved. The NRC staff writes that for these 34 issues, "staff did not conduct additional site-specific evaluations." Instead, they checked that some generic numerical assumptions from the reactor document, called plant parameter envelopes and site parameter envelopes, were technically "met." That's it. No site-specific modeling. No local data. Just a checkbox exercise confirming that our project falls inside the boundaries of a generic worst-case scenario built for a different technology entirely.

Table 3-1, on page 3-3, lists all 34 issues that got this treatment. It's worth a look, because some of them are exactly the things a community living next to an active Superfund cleanup would want studied carefully. A few examples:

Radiation doses to construction workers, radiation doses to operational workers, and radiation doses to the "maximally exposed individual," meaning whoever lives closest to the fence line, all got generic "small impact" conclusions with no site-specific dose calculation. So did radiation exposure to wildlife and to aquatic life in Little Bayou Creek. So did runoff and sedimentation from construction, water use conflicts, and 40 years of operational noise for the family living 150 feet from the property line.

If you want to see the actual generic assumptions that stood in for real analysis, those are in Appendix C, starting on page C-1, with the detailed table (Table C-1) starting on page C-3.

Here's what that actually looks like for one issue. Page C-6 of Table C-1 covers runoff and sedimentation from construction areas. The generic standard from NUREG-2249 says, in effect, that disturbed land gets revegetated once it's no longer needed for construction, and the applicant gets whatever permit applies. Right next to that generic standard, the table checks GLE's plans against it: GLE's own Environmental Report says it will restore disturbed areas with vegetation and will obtain the required permits. Match confirmed. The generic "small impact" conclusion from the reactor study gets applied to GLE's Laser Enrichment Facility.

Notice what's missing from both columns: anything about Little Bayou Creek itself. No sediment measurements, no water quality baseline for that specific stream, nothing about whether a creek already rated as not supporting warm water aquatic habitat could handle three years of construction runoff on top of what it's already carrying. The entire "supporting information" for this issue comes down to GLE saying it will follow standard practice and get its permits, checked against a generic yardstick built for a different kind of facility. Nobody studied the actual creek.

Why this matters for the cumulative impact question

This is the heart of why Protect McCracken County has been calling for a real, independent cumulative environmental impact study, one that looks at GLE's Laser Enrichment Facility together with General Matter's plant, and the active Superfund cleanup happening next door at the Paducah Gaseous Diffusion Plant, and with other projects proposed for this same stretch of land.

When 34 separate issues get resolved by borrowing conclusions from an unfinished document written for a different type of facility, none of those 34 boxes actually involved someone sitting down with our specific groundwater, our specific creeks, our specific wildlife, or our specific neighbors and asking what 40 years of operation here, right next to an ongoing cleanup, would really mean. NEPA asks for that kind of look. This DEIS, for more than two dozen issues, didn't take it.

We're not saying the cleanup work happening at PGDP is being done poorly. We trust that process. We're saying that nobody, not NRC, not EPA, not the state, has been asked to look at what happens when you build something this size, this close, while that work is still ongoing. The DEIS confirms that for 34 issues, that question simply wasn't asked.

See it for yourself

We'd encourage anyone, especially anyone who's heard us make this point and wondered if it's overstated, to pull up the DEIS and check pages 1-7, 3-1 through 3-3, and Appendix C for yourself. The full document is linked below.