AGENCY: Department of Energy
ACTION: Record of Decision
SUMMARY: For the management of low-level waste (LLW) analyzed in the Final
Waste Management Programmatic Environmental Impact Statement (WM PEIS),
the Department of Energy (DOE) has decided to perform minimum treatment at all
sites and continue, to the extent practicable, disposal of on-site LLW at the
Idaho National Engineering and Environmental Laboratory (INEEL), the Los Alamos
National Laboratory (LANL) in New Mexico, the Oak Ridge Reservation (ORR) in
Tennessee, and the Savannah River Site (SRS) in South Carolina. In addition,
the Department has decided to make the Hanford Site in Washington and the
Nevada Test Site (NTS) available to all DOE sites for LLW disposal. INEEL and
SRS also will continue to dispose of LLW generated by the Naval Nuclear
Propulsion Program. For the management of mixed low-level waste (MLLW) analyzed
in the WM PEIS, the Department has decided to treat MLLW at the Hanford Site,
INEEL, ORR and SRS, and to dispose of MLLW at the Hanford Site and NTS. The
Department also has decided to amend its 1996 ROD for the NTS Environmental
Impact Statement, to implement the Expanded Use Alternative for waste
management activities at NTS.
The Department acknowledges the impacts this decision will have in the States of
Nevada and Washington, which will continue their role in supporting the
nation's goal to clean up the nuclear weapons complex, much as they supported
the nation's nuclear weapons program. This decision enables the Department to
integrate waste management activities among sites to promote expeditious,
compliant, and cost effective cleanup.
FOR FURTHER INFORMATION: Copies of the Final WM PEIS and this Record of
Decision (ROD) are available in DOE public reading rooms and selected libraries
located across the United States; the WM PEIS also is available on the internet
at www.osti.gov/bridge
(select "Advanced Search," go to the box labeled "Select Field" and scroll down
to "Identifying Number," then key in "DOE/EIS-0200-F" ). A list of the public
reading rooms can be accessed on this site under "Publications".
To request copies of the WM PEIS, this ROD, or a list of the reading rooms and
public libraries, contact: The Center for Environmental Management Information,
P.O. Box 23769, Washington, DC 20026-3769; telephone 1-800-736-3282 (in
Washington, DC, 202-863-5084).
For further information on the WM PEIS or this ROD, contact: Ms. Karen Guevara,
WM PEIS Program Manager, U.S. Department of Energy, Office of Environmental
Management, 19901 Germantown Road, Germantown, MD 20874; telephone
301-903-4981.
For general information on DOE's National Environmental Policy Act (NEPA)
process, contact: Ms. Carol M. Borgstrom, Director, Office of NEPA Policy and
Assistance (EH-42), U.S. Department of Energy, Office of Environment, Safety
and Health, 1000 Independence Avenue, SW, Washington, DC 20585-0119; telephone
202-586-4600, or leave a message at 1-800-472-2756.
SUPPLEMENTARY INFORMATION:
Background
The WM PEIS (DOE/EIS-0200F), issued in May 1997, studied the potential
nation-wide impacts of managing four types of radioactive waste (LLW, MLLW,
transuranic waste, and high-level waste) and non-wastewater hazardous waste
generated by defense and research activities at 54 sites around the United
States. The WM PEIS analyzes the potential environmental impacts of broad
alternatives for DOE's waste management program, and was designed to provide
part of the basis for DOE decisions on programmatic configurations of sites for
waste management activities. WM PEIS analyses include evaluating potential
impacts associated with transporting wastes by truck and by rail.
Three RODs have been issued under the WM PEIS. These are the transuranic waste
ROD (63 FR 3629, January 23, 1998), the non-wastewater hazardous waste ROD (63
FR 41810, August 5, 1998), and the high-level waste ROD (64 FR 46661, August
26, 1999).
This ROD applies only to the treatment and disposal of LLW and MLLW as analyzed
in the WM PEIS.1 DOE prepared this ROD in
accordance with NEPA (42 U.S.C. §4321 et seq.), the Council on
Environmental Quality's regulations for implementing NEPA (40 CFR Parts
1500-1508), and DOE's NEPA Implementing Procedures (10 CFR Part 1021).
Definitions of LLW and MLLW
Low-Level Waste is all radioactive waste not classified as high-level
waste, transuranic waste, spent nuclear fuel, or by-product tailings containing
uranium or thorium from processed ore (as defined in Section 11(e)2 of the
Atomic Energy Act of 1954 [42 U.S.C. 2011 et seq.]), and not classified
as hazardous waste under the Resource Conservation and Recovery Act (RCRA).
Test specimens of fissionable material irradiated for research and development
only, and not for the production of power or plutonium, may be classified as
LLW provided that the concentration of transuranics is less than 100 nanocuries
per gram. Since the World War II Manhattan Project, DOE and its predecessor
agencies have generated LLW from a variety of activities, including weapons
production, nuclear reactor operations, environmental restoration activities,
and research.
Mixed Low-Level Waste is managed according to requirements established
under RCRA for hazardous waste and the Atomic Energy Act of 1954 for its
radioactive components. The hazardous component of MLLW is subject either to
Environmental Protection Agency regulations promulgated under RCRA or State
hazardous waste regulations promulgated under RCRA. DOE has generated MLLW as a
result of research, development, production of nuclear weapons, and
environmental restoration activities.
Alternatives Considered for Treatment and Disposal of LLW and MLLW
In the WM PEIS, the term "alternative" generally refers to a nationwide
configuration of sites for treating, storing, or disposing of a waste type. The
WM PEIS analyzed No Action, Decentralized, Regionalized, and Centralized
Alternatives for LLW and MLLW treatment and disposal. As shown in Tables 3.4-2
and 3.6-2 for LLW, and Tables 3.4-1 and 3.6-1 for MLLW, the number of sites
considered for treatment and disposal of LLW and MLLW under the action
alternatives is greatest for the Decentralized Alternatives and fewest for the
Centralized Alternatives. The WM PEIS action alternatives for LLW and MLLW did
not include storage alternatives; LLW and MLLW will be stored at the site where
they are generated until they are treated and disposed of.
For LLW treatment, in addition to these categories of alternatives, the WM PEIS
evaluated two treatment approaches: minimum treatment and volume
reduction. Minimum treatment is defined as the least amount of LLW treatment
required to allow either on-site disposal or transportation to another site for
disposal. Minimum LLW treatment includes basic handling, packaging, and
solidification of liquid and fine particulate LLW. Therefore, in all LLW
alternatives, all sites with LLW perform at least minimum treatment on all of
their LLW, regardless of whether the waste is further treated using
volume reduction methods and regardless of whether the waste is to be disposed
of on-site or at another site. For volume reduction, the WM PEIS analyzed
thermal treatment (e.g., incineration), compaction, and size reduction (e.g.,
shredding) to decrease the volume of LLW needing disposal.
For MLLW treatment, the WM PEIS analyzed thermal treatment (e.g., incineration),
separations processes, evaporation, and solidification (e.g., grouting) to meet
RCRA land disposal restrictions.
The following summarizes the alternatives that DOE analyzed for treatment and
disposal of LLW and MLLW.
No Action Alternative. For each waste type, the WM PEIS analyzed a
single "no action" alternative involving the use of currently existing or
planned waste management facilities at DOE sites. Although the no action (or
"status quo") alternative may not comply with applicable laws and regulations,
analysis of such an alternative is required under NEPA regulations, and
provides an environmental baseline against which the impacts of other
alternatives can be compared. Under the No Action Alternative for LLW, LLW
would be treated using existing facilities and then disposed of at the six
existing DOE LLW disposal sites as follows: INEEL, LANL, and ORR would each
dispose of its own LLW; and the Hanford Site, NTS, and SRS would each dispose
of its own waste and waste from specific DOE sites. Under the No Action
Alternative for MLLW, no new facilities would be constructed, not all MLLW
would be treated to meet RCRA land disposal restrictions, and MLLW would be
placed in indefinite storage.
Decentralized Alternative. For each waste type, the WM PEIS analyzed a
single decentralized alternative for treating and disposing of waste at a large
number (16) of DOE sites. Unlike the "no action" alternative, a decentralized
alternative may require the siting, construction and operation of new
facilities or the modification of existing facilities. Under the LLW
Decentralized Alternative, as shown in Table 7.3-2, LLW would undergo only
minimum treatment at all DOE waste generating sites and would be disposed of at
16 DOE sites. Under the MLLW Decentralized Alternative, as shown in Table
6.3-2, MLLW would be treated on-site at DOE waste generating sites and would be
disposed of at 16 DOE sites.
Regionalized Alternatives. For each waste type, the WM PEIS analyzed
several alternatives to consolidate waste management activities by transporting
wastes to fewer sites for treatment or disposal. For LLW, the WM PEIS analyzed
seven Regionalized Alternatives, with volume reduction treatment at 11 or fewer
DOE sites, followed by disposal at up to 12 sites. For MLLW, the WM PEIS
analyzed four Regionalized Alternatives, ranging from treatment at 37 DOE sites
to treatment at only four sites, followed by disposal at 12, six or a single
DOE site.
Centralized Alternatives. For each waste type, the WM PEIS analyzed one
or more alternatives for consolidating waste management activities at a small
number of centralized sites for treatment or disposal. For LLW, the WM PEIS
analyzed five Centralized Alternatives, with volume reduction treatment at
seven sites or at a single site, followed by disposal at a single site. For
MLLW, the WM PEIS analyzed one Centralized Alternative, with MLLW treatment and
disposal occurring at a single site.
Preferred Alternatives. The WM PEIS identified preferred alternatives
using criteria established (after considering public comments) in Section 1.7.3
of the Final WM PEIS. For LLW treatment, DOE identified its preferred
alternative to be minimum treatment of LLW at all sites that generate LLW (the
Decentralized Alternative). For MLLW treatment, DOE identified its
preferred alternative to be a combination of regionalized and decentralized
alternatives, consisting of treatment at the Hanford Site, INEEL, ORR and SRS,
or on-site treatment, as would be consistent with Site Treatment Plans issued
under the Federal Facility Compliance Act, Pub. L. 102-386.
The Final WM PEIS also identified DOE's preferred alternatives for LLW and MLLW
disposal as regional disposal at two or three disposal sites, to be selected
from the six candidate sites at which DOE currently disposes of LLW or MLLW:
the Hanford Site, INEEL, LANL, NTS, ORR, and SRS. On December 10, 1999, DOE
published (64 FR 69241) a Notice of Preferred Alternatives announcing its
preferred LLW and MLLW disposal sites. For LLW disposal, DOE identified
its preferred alternative to be disposal at the Hanford Site and NTS. In
addition, to the extent practicable and consistent with current practice, DOE
would continue disposal of on-site LLW at INEEL, LANL, ORR, and SRS. INEEL and
SRS also would continue to dispose of LLW generated by the Naval Nuclear
Propulsion Program. This preferred alternative for LLW disposal is a
combination of the preferred LLW disposal alternative identified in the Final
WM PEIS (i.e, regionalized disposal at two sites — the Hanford Site and NTS)
and the Decentralized Alternative described in the Final WM PEIS (disposal of
on-site generated LLW at four sites — INEEL, LANL, ORR, and SRS). For MLLW
disposal, DOE identified its preferred alternative to be disposal at
the Hanford Site and NTS (a Regionalized Alternative).
Public Comments on Preferred Alternatives and DOE Responses
In response to the December 1999 Notice, the Department received eight letters
as discussed below.
The Governor of Nevada, in the context of addressing concerns about DOE's
activities regarding Yucca Mountain (which is outside the scope of the WM
PEIS), urged the Secretary of Energy "to continue to assist the state in
assuring that adequate health, safety, and environmental safeguards are in
place to ensure the safety of Nevada's citizens upon receipt of the additional
low-level and mixed waste at the NTS." The "Mitigation of Impacts from
Treatment and Disposal of LLW and MLLW" section of this ROD includes several
commitments that address this request, including: 1) assistance to States,
Tribal and local governments, and other public entities concerning human
health, environmental, and economic impacts; 2) stringent application of
administrative controls, including disposal facility waste acceptance criteria
and stable waste form requirements; 3) implementation of transportation
planning and control programs to reduce transportation risk; and 4) rigorous
quality assurance programs for the characterization of LLW and MLLW.
Previously, the Department entered into a Memorandum of Agreement with the
State of Nevada (July 1998) to provide State regulators with greater
involvement in waste disposal matters.
In a separate letter, the Nevada Department of Transportation indicated concern
with vehicle configuration and routing as it would relate to safe operations on
various highway systems. While the WM PEIS evaluated potential impacts
associated with transporting wastes by truck and by rail (as noted in the
"Background" section of this ROD), this ROD does not make transportation
routing or mode decisions. In implementing this decision, DOE will comply with
all applicable Department of Transportation regulations. In addition, as
mentioned above, a later section of this ROD lists mitigation measures DOE will
continue during LLW and MLLW treatment and disposal; two of these address the
Nevada Department of Transportation's concern: 1) training to ensure DOE and
non-DOE emergency response personnel are knowledgeable of emergency response
procedures; and 2) implementation of transportation planning and control
programs to reduce transportation risk.
The Hanford Advisory Board (one of several site-specific advisory boards
chartered under the Federal Advisory Committee Act) advised that before
off-site LLW and MLLW are imported into the Hanford Site, "there should be
adequate opportunity for public education and involvement." The Department
believes it has provided adequate opportunity for public education and
involvement during the process of reaching the decisions presented in this ROD.
The Department provided a 150-day public comment period for the WM PEIS and
received more than 1,500 comments. The Final WM PEIS responded to these,
including comments of the Hanford Advisory Board. In addition, since
publication of the Final WM PEIS, the Department has continued to share
information and discuss the pending decisions in various public forums. The
pending decision was among the topics discussed in the Intersite Discussions
convened by the League of Women Voters in the Summer of 1998 and a LLW Seminar
sponsored by the Nevada Citizens' Advisory Board in August 1998, both of which
were attended by members of the Hanford Advisory Board. Further, the Department
issued a September 1998 Information Package on Pending LLW and MLLW Disposal
Decisions, which was provided to all site-specific advisory boards
(including the Hanford Advisory Board), and others.
In a separate letter, the Hanford Advisory Board also advised that no off-site
wastes be disposed of in LLW burial grounds on the Hanford Site until
regulators determine whether waste previously disposed of there has been
accurately characterized as LLW and not MLLW. This site-specific implementation
issue is beyond the scope of the WM PEIS. However, DOE will consult with
regulators to determine an appropriate course of action.
An individual from Washington State stated that DOE was in violation of NEPA
when it named preferred disposal sites because the May 1997 WM PEIS only
covered LLW and MLLW treatment. In fact, however, the WM PEIS analyzed
both treatment and disposal of LLW and MLLW.
The State of Arkansas Department of Finance and Administration noted its support
of the Department's stated preferences for LLW and MLLW disposal and offered no
further comments. The State of Missouri Office of Administration stated that
the agency had completed its review and had no comments or recommendations to
offer. A letter from the South Carolina Department of Natural Resources
provided no comments or recommendations on the December 1999 notice.
Upon consideration of comments received during the WM PEIS public comment period
and, as detailed above, on the December 1999 notice, the Department has reached
the following decisions for LLW and MLLW treatment and disposal.
LLW Treatment
Tables 7.16-1 and 7.16-2 in the Final WM PEIS compare alternatives with respect
to the treatment of LLW. In general, the tables present estimates of potential
worker and off-site population fatalities, the ability of sites to meet air and
groundwater quality standards, and costs for the various LLW alternatives
analyzed in the WM PEIS. Chapter 7 also discusses other types of LLW impacts,
including cultural resource and environmental justice concerns. All of the
environmental factors were considered in identifying environmentally preferable
alternatives and in making the decision stated below.
Environmentally Preferable Alternatives: For LLW treatment, seven of
the alternatives analyzed in the WM PEIS (the Decentralized, Regionalized 1, 3,
6 and 7, and Centralized 1 and 2 Alternatives) would result in similarly low
environmental impacts and are the environmentally preferable LLW treatment
alternatives. These alternatives involve only minimum treatment (as defined
earlier), and thus would result in the fewest potential worker fatalities. No
alternative would present environmental justice concerns. None of these
alternatives would result in off-site transportation risks for treatment,
because each site would treat its own waste on-site.
Decision: The Department has decided to implement the Preferred
Alternative specified in the Final WM PEIS for the treatment of LLW. Under this
decision, each site will perform minimum treatment on its LLW, although each
site may perform additional treatment as would be useful to decrease overall
costs. This decision does not preclude DOE's use of commercial treatment
facilities, consistent with current DOE orders and policy.
Basis for Decision: DOE has decided to pursue minimum treatment as its
overall strategy for LLW treatment because volume reduction would not offer
sufficient benefits to offset the increase in human health effects and costs it
would entail. All DOE sites with LLW must perform at least minimum treatment on
all of their LLW, regardless of whether the waste is further treated using
volume reduction methods. A programmatic volume reduction treatment strategy
would pose greater worker hazards, because workers would be exposed to risks
from additional treatment processes. The analyses did not demonstrate that
these more immediate worker risks would be offset by corresponding long-term
human health or environmental risk reduction due to volume reduction. Volume
reduction also could pose additional transportation impacts; because not all
sites have volume reduction treatment facilities, some LLW would have to be
shipped for treatment. Finally, volume reduction would cost twice as much as
minimum treatment, and the increased treatment costs generally would not be
offset by potential savings from disposing of less waste or other benefits.
Disposal of LLW
Tables 7.16-1 and 7.16-2 in the Final WM PEIS compare alternatives with respect
to the disposal of LLW. In general, the tables present estimates of potential
worker and off-site population fatalities, the ability of sites to meet air and
groundwater quality standards, and costs for the various LLW alternatives
analyzed in the WM PEIS. Chapter 7 also discusses other types of LLW impacts,
including cultural resource and environmental justice concerns. All of the
environmental factors were considered in identifying environmentally preferable
alternatives and in making the decision stated below.
Environmentally Preferable Alternatives: For LLW disposal, the
Decentralized and Regionalized Alternatives pose the least environmental
impacts and are the environmentally preferable disposal alternatives. The
Decentralized and all Regionalized Alternatives pose similar transportation
fatality impacts, which are lower than for the Centralized Alternatives.
Potential fatalities from facility operation are low and similar for all
alternatives. No alternative would present environmental justice concerns.
Decision: The Department has decided to establish regional LLW disposal
at two DOE sites: the Hanford Site and NTS. Specifically, the Hanford Site and
NTS will each dispose of its own LLW on-site, and will receive and dispose of
LLW that is generated and shipped (by either truck or rail) by other sites that
meets the waste acceptance criteria. In addition, DOE will continue, to the
extent practicable, disposal of on-site LLW at INEEL, LANL, ORR, and SRS. INEEL
and SRS also will continue to dispose of LLW generated by the Naval Nuclear
Propulsion Program.
Use of the term "regional" disposal does not impose geographical restrictions on
which DOE sites may ship waste to a disposal site; the term is used only to be
consistent with the WM PEIS analysis of regionalized alternatives. This
decision also does not preclude DOE"s use of commercial disposal facilities,
consistent with current DOE orders and policy.
This decision is the preferred alternative that DOE announced in the December
1999 Notice discussed above. Under this decision, DOE will implement a
combination of the preferred LLW disposal alternative identified in the Final
WM PEIS (i.e., regionalized disposal at two DOE sites — the Hanford Site and
NTS) and the Decentralized Alternative (disposal of on-site generated LLW at
four sites — INEEL, LANL, ORR, and SRS).
Basis for Decision: DOE's decision is based on low impacts to human
health, operational flexibility, and relative implementation cost. The Hanford
Site and NTS provide environmental safety benefits inherent to arid sites,
where evaporation rates exceed rainfall by approximately 10 to 1 or more. The
local geology at NTS greatly restricts the potential for any contamination to
move into the groundwater, which is located 800 feet below the surface. Both
the Hanford Site and NTS LLW disposal facilities have expansion capability and
can dispose of a wide range of radionuclides. Using two disposal facilities
provides operational flexibility to align waste streams with facility waste
acceptance criteria and access to an alternate disposal facility should the
other facility's operations be interrupted for any reason.
MLLW Treatment
Tables 6.16-1 and 6.16-2 in the Final WM PEIS compare alternatives with respect
to the treatment of MLLW. In general, the tables present estimates of potential
worker and off-site population fatalities, the ability of sites to meet air and
groundwater quality standards, and costs for the various MLLW alternatives
analyzed in the WM PEIS. Chapter 6 also discusses other types of MLLW impacts,
including cultural resource and environmental justice concerns. All of the
environmental factors were considered in identifying environmentally preferable
alternatives and in making the decision stated below.
Environmentally Preferable Alternatives: For MLLW treatment, all action
alternatives are environmentally preferable because their potential
environmental impacts (including transportation impacts) are not substantially
different, are small, and present long-term benefits. The No Action Alternative
could pose less risk than action alternatives to workers and communities
surrounding DOE's sites for the first 20 years. Longer-term risks from no
action are likely to exceed those for the first 20 years, not only from
continuing routine storage operations, but also from degradation of storage
facilities and containers. (Under the No Action Alternative, MLLW would be
indefinitely stored rather than disposed of.)
Decision: DOE has decided to implement the Preferred Alternative
specified in the Final WM PEIS for the treatment of MLLW. DOE will conduct
regional MLLW treatment at the Hanford Site, INEEL, ORR, and SRS, or on-site,
as would be consistent with current Site Treatment Plans. Current Site
Treatment Plans were negotiated among DOE, the host state, and/or the
Environmental Protection Agency under the Federal Facility Compliance Act, and
may undergo periodic renegotiation. Use of the term "regional" treatment does
not impose geographical restrictions on which DOE sites may ship waste (by
either truck or rail) to a given treatment site; the term is used only to be
consistent with the WM PEIS analysis of regionalized alternatives. DOE's
decision does not preclude DOE's use of commercial treatment facilities,
consistent with DOE orders and policy.
Basis for Decision: The four regional treatment sites offer unique
treatment capabilities needed by other sites in the DOE complex. This decision
takes advantage of infrastructure capabilities that already exist or have been
decided upon at the Hanford Site, INEEL, ORR and SRS — which are capable of
MLLW treatment to meet RCRA land disposal restrictions. The decision also
avoids environmental impacts and costs associated with construction of new
facilities.
Potential impacts from the selected configuration are within those estimated for
regionalized and decentralized alternatives as analyzed in the WM PEIS. With
the appropriate project-specific NEPA review, any site could conduct MLLW
treatment on-site. The potential environmental impacts of all alternatives for
treatment of MLLW evaluated in the WM PEIS are small, with no individual
alternative clearly showing the lowest overall impacts. The No Action
Alternative is not acceptable because it would not meet DOE's long-term waste
management goals nor comply with applicable RCRA requirements.
MLLW Disposal
Tables 6.16-1 and 6.16-2 in the Final WM PEIS compare alternatives with respect
to the disposal of MLLW. In general, the tables present estimates of potential
worker and off-site population fatalities, the ability of sites to meet air and
groundwater quality standards, and costs for the various MLLW alternatives
analyzed in the WM PEIS. Chapter 6 also discusses other types of MLLW impacts,
including cultural resource and environmental justice concerns. All of the
environmental factors were considered in identifying environmentally preferable
alternatives and in making the decision stated below.
Environmentally Preferable Alternatives: For MLLW disposal, all of the
alternatives have low and similar impacts, with Regionalized Alternative 3
being the environmentally preferable alternative because disposal would require
the fewest engineered enhancements to avoid exceeding drinking water standards.
No alternative would present environmental justice concerns.
The No Action alternative is based on indefinite storage and does not prepare
the waste for disposal, i.e., permanent isolation from the human environment.
For the 20-year waste management period considered in the WM PEIS, the
potential impacts under the No Action alternative for MLLW disposal are smaller
than those identified under the action alternatives, and on this short-term
basis, the No Action alternative could be considered to be the environmentally
preferred alternative. However, the No Action alternative does not include
shipment (or transportation impacts) of MLLW for disposal. Further, the No
Action alternative would not protect human health and the environment from such
long-term threats as deteriorating containers or loss of institutional control
and cannot be considered environmentally preferable.
Decision: The Department's decision is to establish regional MLLW
disposal operations at two DOE sites: the Hanford Site and NTS. The Hanford
Site and NTS will each dispose of its own MLLW on-site, and will receive and
dispose of MLLW generated and shipped (by truck or rail) by other sites,
consistent with permit conditions and other applicable requirements. Use of the
term "regional disposal" does not impose geographical restrictions on which DOE
sites may ship waste to a disposal site; the term is used only to be consistent
with the WM PEIS analysis of regionalized alternatives. This decision does not
preclude DOE'>s use of commercial disposal facilities, consistent with
current DOE orders and policy. This decision is the preferred alternative that
DOE announced in its December 10, 1999 Notice of Preferred Alternatives.
Basis for Decision: DOE's decision to regionalize MLLW disposal at the
Hanford Site and NTS is based on low impacts to human health, operational
flexibility, and relative implementation cost. The Hanford Site and NTS are the
only two DOE sites that have MLLW disposal facilities already constructed. Use
of these existing facilities will avoid environmental impacts and costs
associated with facility construction. Further, DOE does not foresee needing a
third regional MLLW disposal facility for the estimated volume of MLLW to be
disposed of during the next 20 years. Using two disposal facilities provides
operational flexibility to align waste streams with facility waste acceptance
criteria and access to an alternate disposal facility should the other
facility's operations be interrupted for any reason.
Mitigation of Impacts from Treatment and Disposal of LLW and MLLW
Chapter 12 of the WM PEIS describes measures that DOE could take to minimize the
potential impacts of its waste management activities. Mitigation measures are
an integral part of the Department's operations, so as to avoid, reduce, or
eliminate potentially adverse environmental impacts. Some of the more important
mitigation measures that DOE will continue during the treatment and disposal of
LLW and MLLW are:
-
Development and implementation of pollution prevention plans.
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Assistance to States, Tribal and local governments, and other public entities
concerning human health, environmental, and economic impacts.
-
Development of "cleaner" waste treatment, storage and disposal technologies.
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Stringent application of administrative controls, including disposal facility
waste acceptance criteria and stable waste form requirements.
-
Maintenance and enhancement of pollution control systems to reduce toxicity of
air and surface water effluents.
-
Reuse of existing facilities rather than construction of new facilities.
-
Training to ensure workers understand operational safety limits within which a
facility can operate while limiting risks and adequately protecting the
environment.
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Training to ensure DOE and non-DOE emergency response personnel are
knowledgeable of emergency response procedures.
-
Implementation of transportation planning and control programs to reduce
transportation risk.
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Rigorous quality assurance programs for the characterization of LLW and MLLW.
These are routine mitigation measures for which a mitigation action plan is not
required. Site-specific, non-routine mitigation measures may also be identified
and implemented in the course of further decision making under site-specific
NEPA reviews.
Amendment of the Record of Decision for NTS
On December 9, 1996, DOE issued a ROD (61 FR 65551) for the Final Environmental
Impact Statement for the Nevada Test Site and Off-Site Locations in the State
of Nevada (NTS EIS). That ROD cited the then-pending Final WM PEIS and
stated that subsequent programmatic decisions "may require changes to the Waste
Management Program at NTS in the future," and "that in the interim, pending
those programmatic decisions, DOE will maintain the current level of LLW and
MLLW management activity as described in the No Action Alternative in the NTS
EIS." For LLW, the decision meant that "disposal of LLW will continue for waste
streams from current [DOE approved] on-site and off-site generators" and that
"approval of other waste generators for disposal is pending future programmatic
decisions." For MLLW, the decision meant that "DOE will continue to manage MLLW
which is currently on-site or which may be generated by DOE at NTS."
The NTS EIS addressed the environmental impacts of four operational scenarios:
1) Continue Current Operations (No Action), 2) Discontinue Operations, 3)
Expanded Use, and 4) Alternate Use of Withdrawn Lands. The ROD identified DOE=s
decision to implement a combination of elements of three of these alternatives.
DOE decided that most activities would be pursued at levels described by the
Expanded Use Alternative. In addition, DOE decided to undertake certain public
education activities analyzed under the Alternate Use of Withdrawn Lands
Alternative. As stated above, DOE also decided that, pending programmatic
decisions, NTS LLW and MLLW management operations would be conducted under the
Continue Current Operations Alternative.
Under the Continue Current Operations Alternative, the NTS EIS analyzed the
environmental impacts for a ten-year period of disposal of 349,294 cubic meters
of LLW in either of two Radioactive Waste Management Sites (Areas 3 and 5) at
the NTS and 18,285 total shipments via legal weight trucks on public highways.
Under the Expanded Use Alternative, the NTS EIS analyzed 1,041,422 cubic meters
of LLW to be disposed of and 39,084 shipments. While there is a substantial
difference in the volumes of waste and numbers of shipments under the two
alternatives, DOE found in the NTS EIS that the incremental environmental
impacts associated with waste management activities of Expanded Use as compared
to Continue Current Operations were negligible.
Inasmuch as DOE is now making complex-wide decisions for its LLW and MLLW waste
management program, which includes continuing to use the NTS for disposal of
LLW and initiating use of the NTS for disposal of MLLW, as addressed in the WM
PEIS, DOE is also hereby amending its December 9, 1996, NTS EIS ROD. DOE will
implement the Expanded Use Alternative for waste management activities at NTS,
including LLW and MLLW disposal. This amendment is based on the analysis in the
NTS EIS and is tiered from the WM PEIS and the associated programmatic
decisions for LLW and MLLW.
Issued in Washington, D.C. this 18th day of February, 2000
Carolyn L. Huntoon
Assistant Secretary
for Environmental Management
____________________________
1
After the Final WM PEIS was issued in May 1997, DOE issued "Accelerating
Cleanup: Paths to Closure." In that document, DOE provided estimates of waste
volumes that would result from the planned operations and accelerated cleanup
processes at DOE sites. Because some of the estimates differed from those
provided in the WM PEIS, DOE examined the LLW and MLLW volumes to determine if
the updated volume estimates constitute significant new information relevant to
environmental concerns that would warrant preparation of a supplemental EIS or
a new PEIS. This examination extended only to LLW and MLLW volumes, because the
transuranic, hazardous and high-level waste volume estimates did not change
from those analyzed in the Final WM PEIS.
The treatment and disposal site locations were chosen based on factors that
would not be affected by the changed waste volume estimates. Waste volume
considerations could have influenced the choice of treatment and disposal sites
only if the estimated volume of LLW, the estimated volume of MLLW, or the
expected nationwide distribution of waste had changed dramatically, none of
which occurred. Therefore, DOE has concluded that its decisionmaking process
for LLW and MLLW can proceed without preparing a supplemental EIS or a new
PEIS.
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