DOE/EA-1776

Idaho National Laboratory

Radiological Response Training Range

Environmental Assessment

Final

October 2010

DOE/EA-1776

Idaho National Laboratory

Radiological Response Training Range

Environmental Assessment

Final

October 2010

Prepared for the

U.S. Department of Energy

Idaho Operations Office
i

CONTENTS 

GLOSSARY ................................................................................................................................................ iii

EXECUTIVE SUMMARY .......................................................................................................................... v

1.0 PURPOSE AND NEED ..................................................................................................................... 1

2.0 ALTERNATIVES .............................................................................................................................. 2

2.1 Background .............................................................................................................................. 2

2.2 Range of Reasonable Alternatives and Siting Analysis Criteria .............................................. 3

2.3 Alternative 1 – North and South Training Ranges ................................................................... 4

2.3.1 Alternative 1a – Maximizing Training Flexibility ...................................................... 9

2.3.2 Alternative 1b – Minimizing Project Impacts ........................................................... 11

2.4 Alternative 2 – No Action ...................................................................................................... 11

2.5 Operational Controls .............................................................................................................. 12

3.0 AFFECTED ENVIRONMENT ........................................................................................................ 13

4.0 ENVIRONMENTAL CONSEQUENCES ....................................................................................... 15

4.1 Alternative 1 – North and South Training Range .................................................................. 15

4.1.1 Risk Assessment ....................................................................................................... 15

4.1.2 Biological Resources................................................................................................. 17

4.1.3 Cultural Resources .................................................................................................... 21

4.1.4 Other Resources ........................................................................................................ 23

4.2 Alternative 2 – No Action ...................................................................................................... 23

4.3 Summary of Proposed Impacts .............................................................................................. 24

5.0 COORDINATION AND CONSULTATION .................................................................................. 24

6.0 REFERENCES ................................................................................................................................. 25

Appendix A: Public Comment and Response ............................................................................................ 28

FIGURES 

Figure 1. Idaho National Laboratory. ............................................................................................................ 2

Figure 2. INL's Radiological Response Training Range. .............................................................................. 5

Figure 3. Berm/Ditch, Looking from north to south from the  ̳Arc‘ road toward the T-28 Gravel Pit ......... 9

Figure 4. South Training Range area during initial testing activities.......................................................... 11

TABLES 

Table 1. Project activities related to (1) preparing, (2) operating, (3) training, and (4) post training 

and post exercises activities at the sites. ....................................................................................................... 6

Table 2. Operational controls to avoid or lessen impacts to natural, ecological, and cultural 

resources. .................................................................................................................................................... 12

Table 3. Regulatory Dose Requirements, Calculated Project Dose, and Perspectives. .............................. 18
ii

ACRONYMS 

AGL Above Ground Level 

BEA Battelle Energy Alliance 

CAA Clean Air Act 

CEQ Council on Environmental Quality 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CFA Central Facilities Area 

CFR Code of Federal Regulations 

DoD U. S. Department of Defense 

DHS U. S. Department of Homeland Security 

DOE U. S. Department of Energy 

DoJ U. S. Department of Justice 

DOT U. S. Department of Transportation 

EOD Explosive Ordnance Disposal 

EA Environmental Assessment 

EDE Effective Dose Equivalent 

EPA U. S. Environmental Protection Agency 

ESA Endangered Species Act 

FHBC Fort Hall Business Council 

GHG Greenhouse Gas 

INL Idaho National Laboratory 

MFC Materials and Fuels Complex 

NAAQS National Ambient Air Quality Standards 

NERP National Environmental Research Park 

NEPA National Environmental Policy Act 

NESHAP National Emissions Standard for Hazardous Air Pollutants 

NRAD Neutron Radiography Reactor 

NRC U. S. Nuclear Regulatory Commission 

PPE Personal Protective Equipment 

PSD Prevention of Significant Deterioration 

RRTR Radiological Response Training Range 

RWMC Radioactive Waste Management Complex 

SRPA Snake River Plain Aquifer 

STP Sewage Treatment Plant 

TAN Test Area North 

TSF Technical Services Facility 

UAV Unmanned Aerial Vehicles 

U. S. United States 
iii

GLOSSARY 

Attainment Area: An area considered to have air quality as good as or better than the National Ambient Air Quality 

Standards (NAAQS) as defined in the Clean Air Act (CAA). An area may be an attainment for one pollutant and a 

nonattainment area for others. 

By-Product Material: In this document, the term "by-product material" under the Atomic Energy Act) refers to any 

radioactive material (except special nuclear material) yielded in or made radioactive by exposure to the radiation 

incident to the process of producing or utilizing special nuclear material. 

Cairns: Rock piles constructed historically and prehistorically to mark features on the landscape, such as travel 

corridors, caves, or campsites. 

Clean Air Act (CAA): The Federal Clean Air Act, or ―CAA,‖ is the basis for the national air pollution control effort. 

Basic elements of the act include national ambient air quality standards for major air pollutants, hazardous air 

pollutants, state attainment plans, motor vehicle emission standards, stationary source emission standards and 

permits, acid rain control measures, stratospheric ozone protection, and enforcement provisions. 

Clean Water Act (CWA): The Clean Water Act is the primary federal law in the United States (U. S.) governing 

water pollution. Commonly abbreviated as the ―CWA,‖ the act established the goals of eliminating releases to water 

of high amounts of toxic substances, eliminating additional water pollution by 1985, and ensuring that surface 

waters would meet standards necessary for human sports and recreation by 1983. 

Comprehensive Environmental Response, Compensation, and Liability Act: The Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA), commonly known as ―Superfund,‖ created a tax on the 

chemical and petroleum industries and provided broad federal authority to respond directly to releases of hazardous 

substances that may endanger public health or the environment. CERCLA established prohibitions and requirements 

concerning closed and abandoned hazardous waste sites; provided for liability of persons responsible for releases of 

hazardous wastes; and established a trust fund to provide for cleanup when no responsible party could be identified. 

Curie: A unit of radioactivity equal to 3.7×1010 disintegrations per second. 

Effective Dose Equivalent: The summation of the products of the dose equivalent received by specified tissues of 

the body and a tissue-specific weighting factor. This sum is a risk-equivalent value and can be used to estimate the 

health-effects risk of the exposed individual. The tissue-specific weighting factor represents the fraction of the total 

health risk resulting from uniform whole-body irradiation that would be contributed by that particular tissue. The 

effective dose equivalent, or EDE, includes the committed EDE from internal deposition of radionuclides and the 

EDE due to penetrating radiation from sources external to the body. The EDE is expressed in units of rem.

National Ambient Air Quality Standards (NAAQS): Standards established by the U. S. Environmental Protection 

Agency (EPA) under authority of the CAA that apply for outdoor air throughout the country. Primary standards are 

designed to protect human health with an adequate margin of safety, including sensitive populations (such as 

children, the elderly, and individuals suffering from respiratory disease). Secondary standards are designed to 

protect public welfare from any known or anticipated adverse effects of a pollutant. 

National Environmental Research Park: Idaho National Laboratory (INL) is categorized as National Environmental 

Research Park, or NERP. NERPs are outdoor laboratories that provide opportunities for environmental studies on 

protected lands that act as buffers around U. S. Department of Energy (DOE) facilities. DOE uses these research 

parks to evaluate the environmental consequences of energy use and development, as well as strategies to mitigate 

these effects and demonstrate possible environmental and land-use options. The seven NERPs located in the U. S. 

are administered through their regional DOE Operations Offices and are coordinated and guided by the Office of 

Science. 

National Emission Standards for Hazardous Air Pollutants for Radionuclides (Rad NESHAPS): The CAA requires 

the EPA to regulate airborne emissions of hazardous air pollutants (HAPs) (including radionuclides) from a specific 

list of industrial sources called "source categories." Each source category that emits radionuclides in significant 

quantities must meet technology requirements to control them and is required to meet specific regulatory limits. 

These standards are the National Emission Standards for Hazardous Air Pollutants for Radionuclides. 
iv

Nonattainment Area: The CAA and its Amendments of 1990 define a ―nonattainment area‖ as a locality where air 

pollution levels persistently exceed NAAQS (see glossary), or that contribute to ambient air quality in a nearby area 

that fails to meet those standards. The EPA gives nonattainment areas a classification based on the severity of the 

violation and the type of air quality standard they exceed. EPA designations of nonattainment areas are only based 

on violations of national air quality standards for carbon monoxide, lead, ozone (1-hour), particulate matter 

(PM-10), and sulfur dioxide. 

Prevention of Significant Deterioration: This term applies to new major sources or major modifications at existing 

sources for pollutants where the area the sources are located is in attainment or unclassifiable with the NAAQS. It 

requires the installation of Best Available Control Technology, air quality analysis, additional impacts analysis, and 

public involvement. 

Radioactive Materials: For the purpose of this document ―radioactive materials‖ include (1) sealed radioactive 

sources; (2) special form sealed radioactive sources; (3) contained (or unsealed) radioactive sources; and 

(4) dispersible radioactive material. Project personnel would use these materials to produce radiation fields for 

detection and training during exercises. 

Sealed Radioactive Sources – These sources are small metal containers in which a specific amount of a 

radioactive material is sealed. Manufacturers of these devices must demonstrate protectiveness to receive a 

license to manufacture and sell them. 

Special Form Sealed Radioactive Sources – Commercially manufactured sealed radioactive sources that meet 

the test requirements specified by the U. S. Nuclear Regulatory Commission (NRC) under 10 CFR 71.25. 

Special form sealed radioactive sources are preferred for temporary placement in outdoor areas due to their 

robustness of construction to simulate external radiation fields during tests.

Contained (or Unsealed) Radioactive Sources – A contained or unsealed radioactive source is encapsulated 

radioactive material that cannot escape to the environment and cause contamination but does not meet the 

regulatory standards (10 CFR 71.25) for sealed sources. Some radioactive materials that may be used must be 

produced at the INL for measurement. These include sources such as irradiated glass that contain trace 

quantities of isotopes that may be of interest to specific scenarios. INL must produce many of these sources, 

since they are not all available commercially. The adequacy of the source containment is evaluated on a caseby-case basis prior to use during training exercises. INL‘s Radiological Protection Program would evaluate the 

adequacy of the containment and authorize the use during an exercise. 

Dispersed Radioactive Material – Activated potassium bromide (KBr) that project personnel would disperse at 

the training sites. This is a short-lived radioactive by-product material that decays to background levels in about 

two weeks. 

Radiological Work Permit: The RWP is an administrative mechanism used to establish radiological controls for 

intended work activities. The RWP informs workers of area radiological conditions and entry requirements and 

provides a mechanism to relate worker exposure to specific work activities.

Vadose Zone: The region of aeration above the water table, which extends from the top of the ground surface to the 

water table. 
v

EXECUTIVE SUMMARY 

An important aspect of United States (U. S.) national security is to develop and maintain an 

effective response capability for major radiological incidents. Developing and maintaining the 

capability to identify the origin of material in response to one of these incidents is a national priority 

as noted in the Nuclear Forensics and Attribution Act of 2010 (Public Law 111-140). Idaho National 

Laboratory (INL) has the technical resources necessary to provide direct support to federal agencies 

responsible for the nuclear forensics mission. Further, INL has a unique capability to provide a large 

outdoor testing and training range where short-lived dispersed radioactive materials can be 

disseminated or radioactive sources (i.e., sealed, special form sealed, and contained, see glossary) 

placed to provide direct support to federal agencies responsible for the nuclear forensics mission. 

The objective of this environmental assessment (EA) is to evaluate the potential environmental 

impacts of creating and operating a radiological response training range by evaluating two alternative 

approaches to achieve the proposed action and a  ̳No Action‘ alternative. The U. S. Department of 

Energy (DOE) reviewed several possible on-site and off-site alternatives and determined that the 

reasonable alternative included two on-site locations; no off-site locations met the site-selection 

criteria. 

Alternative 1 (North and South Training Ranges) focuses radiological activities near Test Area 

North (TAN) (North Training Range) and near the Radioactive Waste Management Complex 

(RWMC) (South Training Range). DOE divided the on-site locations into two sub-alternatives: 

Alternative 1a,  ̳Maximize Project Flexibility,‘ and Alternative 1b,  ̳Minimize Project Impacts.‘ This 

EA describes the environmental impacts of the two sub-alternatives and the  ̳No Action‘ alternative 

on air, water, biological, and cultural resources. 

These sites would be used to train personnel, test sensors, and develop detection capabilities (both 

aerial and ground-based) under a variety of scenarios in which radioactive materials (see glossary) 

are used to create a radioactive field for training in activities such as contamination control, site 

characterization, and field sample collection activities. A typical training exercise would include its 

own prepared plan and schedule, and involve up to 75 people and 15 vehicles at the range proper.

The dispersed radioactive materials source term was based on the dispersal of 1 curie (see 

glossary) of irradiated potassium bromide. The radiation dose from the release of this source term was 

modeled for airborne (inhalation), surface (ingestion, inhalation, and external exposure), and ground 

water (ingestion) release. The CAP88-PC Version 3.0 code was used to compute doses from the 

atmospheric pathway, GWSCREEN was used to compute groundwater concentrations and doses, and 

RESRAD Version 6.5 code was used to compute surface pathway doses to an individual living at the 

range after testing has been completed. The sum of the atmospheric, surface, and groundwater models 

show the public dose would be about 0.01% of the INL Administrative Control Level for the Public. 

While activities would occur in relatively disturbed areas, the surrounding and nearby areas 

consist of natural vegetation containing wildlife and cultural resources. The impact on Greater sagegrouse and pygmy rabbits and their habitat differs between alternatives, including the sub-alternatives 

1a and 1b. Alternative 1a would remove sage-grouse and pygmy rabbit habitat and cause 

fragmentation of the remaining habitat within the proposed training range. Alternative 1b would not 

remove sage-grouse and pygmy rabbit habitat or increase habitat fragmentation. Proposed operational 

controls would minimize potential impacts to sensitive resources, such as sage-grouse, pygmy rabbits, 

migratory birds, and cultural and archaeological resources. 
1

Idaho National Laboratory 

Radiological Response Training Range 

Environmental Assessment

1.0 PURPOSE AND NEED 

An important aspect of United States (U. S.) national security is to develop and maintain an effective 

response capability for major radiological incidents. Developing and maintaining the capability to identify 

the origin of material in response to one of these incidents is a national priority as noted in the Nuclear 

Forensics and Attribution Act of 2010. Idaho National Laboratory (INL) supports training personnel, 

technology evaluation, and demonstration for federal agencies responsible for the nuclear forensics 

mission. INL support for these agencies is authorized under the Economy Act of 1932, as amended 

(31 U.S.C. 1535), and Section 309 of the Homeland Security Act of 2002 (Public Law 107-296, 2002). 

Under these authorities, the U. S. Department of Homeland Security (DHS) and other federal agencies 

may access and use the highly specialized expertise and unique capabilities and facilities resident at U. S. 

Department of Energy (DOE) national laboratories and sites in carrying out their missions. 

In the event of an incident, U. S. agencies/authorities must be able to quickly gather and evaluate 

nuclear forensic information. To maintain this capability, the U. S. national security agencies need to be 

able to conduct safe, well-characterized, and orchestrated training exercises and technology 

demonstrations in controlled radiological environments. Responders to any major radiological incident 

must be able to use a variety of specialized equipment in an effective, timely, and integrated manner to 

characterize the event. 

The INL has supported several exercises and training venues for the nuclear forensics and emergency 

response communities (i.e., DOE Radiological Assistance Program, DOE‘s Federal Radiation Monitoring 

and Assessment Center, DOE Aerial Measurements System, U. S. Department of Defense [DoD] and 

Department of Justice [DoJ] explosive ordnance disposal [EOD] teams, and National Guard Civil Support 

teams).a With the exception of a small exercise held at INL in 2008, training and exercises conducted by 

the forensics community have been limited to gamma radiation fields produced using large special form 

sealed radioactive sources (see glossary). Current training scenarios are deficient since they have not 

used dispersed radioactive materials to develop and test advanced response skills. These skills include 

radiological protection, decontamination and contamination control, field characterization, and sample 

collection. 

This environmental assessment (EA) evaluates constructing and operating training ranges where field 

exercises would simulate conditions expected during a major radiological incident. INL has been the only 

DOE laboratory to conduct indoor and outdoor exercises using specifically designed and characterized 

radiation/contamination fields that used radioactive materials and sources to support the unique needs of 

agencies responsible for nuclear forensics. This range would also support larger-scale training, exercises, 

and technology development activities that emulate radiation and contamination fields that would be 

encountered by emergency responders. 

 

a. In addition, other Federal Agencies that deal with consequence management, such as the U. S. Environmental Protection 

Agency (EPA), have expressed interest in utilizing the Radiological Response Training Range (RRTR). 
2

2.0 ALTERNATIVES 

2.1 Background 

DOE proposes to locate a Radiological Response Training Range (RRTR) on the INL Site. The INL, 

an 890-square-mile reservation in southeastern Idaho (see Figure 1), is managed and operated by Battelle 

Energy Alliance (BEA). INL hosts the materials, facilities, and people needed to accommodate a 

radiological response training and demonstration range. INL also has a large diverse inventory of 

radioactive sources and materials that, in conjunction with the ability to produce short-lived radioisotopes, 

would establish a well-characterized environment representative of agency-specified scenarios and 

training objectives. 

Figure 1. Idaho National Laboratory. 

As used in this document, the term ―dispersed radioactive material,‖ is a general reference to 

radioactive ―by-product material‖ governed by the Atomic Energy Act and regulated by DOE 

(specifically, potassium bromide [KBr]) that decays to background levels in about two weeks. KBr, when 

irradiated in a reactor such as INL‘s Neutron Radiography (NRAD) reactor, will produce a number of 

radioactive isotopes that are considered ―short-lived‖ radioactive isotopes. The irradiation will also 

produce an ultra-trace quantity of three long-lived isotopes (i.e., Ar-39, K-40, and Cl-36). All three occur 

naturally (Clark and Fritz, 1997). Ar-39 is a noble gas that dissipates in air, while K-40 and Cl-36 occur 

in such small amounts that they are not distinguishable from the natural background radiation. The 
3

short-lived isotope with the longest half-life produced by the irradiation of the salt, excluding Ar-39, 

K-40, Cl-36, is Br-82, which has a half-life of 1.47 days (35.3 hours). Br-82 contributes the most to the 

overall decay rate of the activated compound and defines the period of time that the compound remains 

radioactive—as a rule of thumb—10 half-lives can be used to estimate the amount of time that the Br-82 

will take to decay to the stable isotope Kr-82. For KBr, after 353 hours, or about 15 days, the quantity of 

radioactive material remaining from use in the training exercises will be no longer measurable from 

natural background radiation. 

The objective of this EA is to evaluate the potential environmental impacts of creating and operating 

a radiological response training range by evaluating and comparing alternative approaches to achieve the 

proposed action and  ̳No Action‘ alternatives. This document was prepared in accordance with the 

requirements of the National Environmental Policy Act (NEPA) of 1969 (Public Law 91 190), as 

amended; the Council on Environmental Quality‘s (CEQ) NEPA Regulations (40 Code of Federal 

Regulations [CFR] Parts 1500 1508); DOE Order 451.1; and DOE NEPA Implementing Regulations 

(10 CFR Part 1021). 

INL has an extensive inventory of radiological material and sources, and has the unique ability to 

produce the high purity short-lived radioisotopes (i.e., KBr) that will be necessary to support the 

envisioned radiological exercises. The NRAD reactor and Analytical Laboratory at INL‘s Materials and 

Fuels Complex (MFC) are assets that can readily prepare and produce the irradiated KBr on demand and 

without introduction of unwanted istopes with longer half-lives. 

2.2 Range of Reasonable Alternatives and Siting Analysis Criteria 

The CEQ‘s NEPA regulations require agencies to identify and assess reasonable alternatives 

(40 CFR 1500.2(e)) when proposing new activities. DOE has developed a set of site-selection criteria, 

based on programmatic objectives to help identify alternatives, meet the purpose and need, and satisfy 

program requirements (see inset box on the next page). DOE searched for an appropriate training range 

site at INL because one of the most important criteria is access to a facility capable of producing short 

half-life radioactive materialb

. DOE also looked at other DOE facilities, but found that such facilities did 

not meet the program expectations of conducting and supporting the described training that can be 

accomplished at INL. Further, no other DOE location satisfies all of the listed criteria. 

With respect to the INL Site, DOE looked for areas that would minimize potential environmental 

impacts from these proposed activities. DOE considered disturbed sites at INL, including legacycontaminated areas such as Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA) (see glossary) sites, gravel pits, other ―ranges‖ or test areas, and recently demolished facility 

areas. DOE eliminated using CERCLA sites because: (1) the program required an accurate determination 

of the radionuclide inventory in an area for a broad range of radionuclides and the characterization data 

does not meet project requirements due to the presence of legacy radionuclides that are stratified at 

different soil depths and may confound test activities; (2) the background contamination may complicate 

quantifying the activated KBr; and (3) they would not represent sites with only fallout and radioactive 

materials dispersed on surfaces. 

DOE chose to analyze a set of three locations as the proposed alternative that would accomplish the 

agency‘s purpose and need and meet all of the siting criteria (see Section 2.3). In addition, based on 

biological and cultural resource surveys, DOE chose to expand alternative 1 to two sub-alternatives 

related to the north location: (1)  ̳maximizing training flexibility‘ and (2)  ̳minimizing project impacts.‘ 

In addition, per CEQ regulations, this document analyzes a  ̳No Action‘ alternative (see Section 2.4) 

as well. 

 

b. Note: Because the materials needed for testing decay quickly, it is essential to have the reactor producing and the laboratory 

confirming the purity of the short-lived isotopes close to the training location. INL personnel have unique expertise and 

training in producing and handling radioactive materials to support the described activities. 
4

2.3 Alternative 1 – North and South Training Ranges 

Alternative 1 establishes two outdoor Radiological Response Training Ranges—a North Training 

Range and a South Training Range. The North Training Range consists of a short section (<1 mile) of

T-28 (north of the gravel pit), a section (~0.4 miles) of access road (south of the gravel pit), an  ̳arching‘ 

road across the top of the area (~1.0 mile), the T-28 Gravel Pit (9 acres), a berm/ditch structure 

(0.75 miles), a large area (825 acres) surrounding the gravel pit, the TAN parking lot (~2.5 acres), and an 

area consisting of the old TAN Facility (23.5 acres) (see Figure 2). The South Training Range consists of 

a radiological work area (~7.5 acres), a smaller area (~3.0 acres) just adjacent to and west of the 

radiological work area, two small areas (~3.4 and 0.3 acres) along the access road, and the parking area 

(~5.0 acres) just south of INL‘s Radioactive Waste Management Complex (RWMC) (see Figure 2). 

INL would continue to use the gravel pit to mine gravel for on-site uses; however, access may be 

restricted during and after training exercises while radioactive levels decay to pre-test background levels. 

These sites would be used to train personnel, test sensors, and develop detection capabilities (both 

aerial and ground-based) under a variety of scenarios using (1) sealed radioactive sources (see glossary), 

(2) Special Form Sealed Radioactive Sources (see glossary), (3) Contained (or Unsealed) Radioactive 

Sources (see glossary), and (4) dispersed radioactive material (see glossary). Training would include: (1) 

evaluation of command and control protocols; (2) site characterization with aerial surveys and remote 

radiation measurements on well-defined gamma emitting radiation fields; (3) activities that support 

ground-based sample collections; and (4) contamination control and decontamination operations. The 

different locations allow range users flexibility in planning their training activities. INL personnel would 

conduct training and demonstrations on an as-needed basis and incorporate the respective areas that best 

satisfy the specific training objectives. Project activities include: (1) preparing the site; (2) operating the 

site; (3) performing training exercises at the site; and (4) post training and post exercise activities (see 

Table 1 for specifics). Table 2 (in Section 2.5) describes ―operational controls‖ necessary to avoid or limit 

impacts to natural, ecological, or cultural resources, and to avoid contaminating the environment or 

exposing the public or employees to radioactive materials. 

Site Selection Criteria

Location in close proximity to facilities that produce the radioactive materials:

o to minimize shipping distances

o to minimize loss of activity from radioactive decay of the materials.

Location in close proximity to facilities that can produce a diverse inventory of radioactive materials.

Locations must not have legacy radionuclides that may confound sample collection and field characterization 

activities.

Locations must have specialized infrastructure and expertise to handle these materials in choreographed training 

and exercise scenarios.

Test areas must be able to tailor the environment to required scenarios by varying contamination levels, patterns, 

and emplacement of radioactive sources with varied dispersal methods.

Locations must be remote and isolated from the public.

Locations must be semi-arid to minimize the likelihood of short-lived dispersed contamination being diluted or 

washed away.

Locations must be able to accommodate aircraft (both manned and unmanned) for aerial surveillance and 

characterization.

Locations must be able to restrict access until radiation levels have returned to background levels (about two 

weeks).

Locations must provide for sufficient staging area to support assembly and command post operations.

Locations must provide readily accessible radiological facilities (i.e., hot cells, radioanalytical laboratories, etc.) and 

forensics expertise necessary to design and choreograph, setup, and execute a variety of exercise scenarios and 

demonstrations.
5

Figure 2. INL's Radiological Response Training Range. 
6

Table 1. Project activities related to (1) preparing, (2) operating, (3) training, and (4) post training and 

post exercises activities at the sites. 

Activities to Prepare Sites

Contour the gravel pit area to grade/compact the earth.

Mow vegetation (grasses and brush) where project activities would place command posts or laydown areas.

Use about 600 gallons/test water to apply the KBr. Store water in several 200–500 gallon polyethylene containers on-site. 

Apply about 1000 gallons/day of water for dust control on roadways and parking lots.

Construct small temporary structures or appropriate props to simulated urban environments.

Establish tent set-up areas for decontaminating personnel and equipment.

Establish a base area for tents or trailers to support equipment storage, mission planning and data assessment activities, 

communication activities, and sleeping and eating accommodations.

Conduct pre-survey (i.e., soils, etc.) for legacy radioactive contaminants and as appropriate surveys for cultural and 

biological resources (i.e., archaeological and nesting bird surveys). Note: Surveys for radioactive contaminants and 

cultural resources only occur once; however, nesting bird surveys may need to occur throughout the nesting season 

depending on the frequency of project activities in the area.

Operating Activities

Control site access for security in accordance with a project security plan

Irradiate KBr at an irradiation facility (project personnel receive a  ̳purity statement‘ attesting to the purity of the isotope, 

assuring that project personnel know the isotopes produced during irradiation).

Determine the maximum amount of KBr salt (up to 500 grams, but less than 1 curie, [see glossary]) to be used for each 

test and identify/quantify any chemical contaminants present.

Transport the KBr to the testing site using U. S. Department of Transportation (DOT) approved methods and transport 

containers.

Verify the curie content and isotopic distribution.

Disperse the short-lived KBr in accordance with scenario requirements. It is expected that 12 or fewer tests would occur 

annually. These tests may include:

o Application as powders using spreaders

o Dissolving in water and applying with sprayers (for precise control of KBr levels and deposition pattern)

o Using CO2 or compressed air gas jet to disperse the KBr radionuclide as a powder with a specified particle size 

without explosive residues

o Using explosives, such as C-4 or equivalent (about 1⁄2-pound), to disperse the KBr radionuclide and the materials.

Radioactive sources may be used to calibrate instruments and radioactive materials may be used as training materials.

The following list is representative, but not a comprehensive sampling, of isotopes that may be used for training: 137Cs, 

60Co, 192Ir, 75Se, 226Ra, and isotopes of U, Pu, Am, and Th (Note: Source material under the Atomic Energy Act is 

uranium, thorium, or any other material which is determined by the Commission to be source material; or ores containing 

one or more of the foregoing materials, in such concentration as the Commission may determine from time to time).

Project personnel would use the INL radiological control and work permit process with other hazard identification and 

mitigation procedures to select and control the isotopes used for training events.

Dispersal of KBr would occur only when wind speeds are less than 10 miles per hour. Wind speed would be monitored 

and dispersal of KBr would be terminated if wind speeds exceed 10 miles per hour. Project personnel will use a hand 

held anemometer, such as the Speedtech Windmate 300. These hand held instruments have an accuracy within three 

percent. The height for wind speeds will be at 5 feet from ground level at the point of release. Project personnel will 

record wind speed and direction for each release, and will monitor at the time of release, or for spraying applications, the 

duration of the spraying period. 

Project activities at the T-28 Gravel Pit would not occur during high water.
7

Training Exercise Activities

Use gasoline/diesel generators for electrical power.

Use ground robots for sample collection and site surveillance activities.

Use portable toilets or sanitary facilities.

Place cargo containers, old vehicles, and similar objects in the training range to test sample collection methodologies.

Use stakes to anchor equipment and spray paint, stakes, and rope to mark areas as appropriate.

Collect ground soil samples and surface smears off objects located in the training range.

Use surrogate materials (CaCl2 etc.) to test application methods (~200 grams per test).

Transport personnel and equipment in all-terrain or utility (gators) vehicles (ATVs) along approved roads, berms, T-28 

Gravel Pit in the North Training Area, and the Radiological Work Area in the South Training Area for characterization and 

sample collection.

Practice decontamination procedures on personnel and equipment with cloth and wet (water spray) methods.

Dismantle, store, and dispose of temporary structures following testing.

Store contaminated equipment and clothing until all detectable radionuclides are decayed then disposed as conditional 

waste or surveyed as free for release and reuse. Large contaminated equipment and structures will remain within the 

Test range until the INL Radiological Control personnel clears them for release. Contaminated clothing will be stored in 

radiation bags in cargo containers at the Test Range until disposed as low-level waste (MFC).

Dispose cold waste through Waste Generator Services.

Training personnel will collect samples as part of the exercise.

Conduct interrogation and characterization of surrogate suspect packages and devices using a variety of high-energy 

techniques including X-ray, flash x-ray, portable isotopic neutron spectroscopy, and radiation generating devices.

Use aerial platforms, including fixed or rotary wing (including fueling the helicopter) aircraft or unmanned aerial vehicles,

to fly over the RRTR (T-28 Gravel Pit and surrounding area). These aircraft would have onboard sensor platforms to 

detect radioactivity and provide mapping of the area. Aircraft would fly over the range at varying altitude above ground

levels. The flights may involve multiple flyovers in patterns or a single flyover. The number of flights per exercise would

vary with the training requirements. Not all exercises would require aircraft activity.

Post-Training and Post Exercise Activities

Radiation levels (as measured with a micro-rem meter) will be monitored after release of activated KBr, which is done to 

limit access to the area until released by Radiation Control.

The continued use of the gravel pit to mine gravel will be on-going. Access would be controlled during and after training 

and exercises until the area is released for unrestricted use.

Perform a Radiological Assessment (see Table 2).

Waste Management:

Operations at the RRTR would generate several types of waste: (1) common trash; (2) low-level 

radioactive waste; and (3) liquid waste. Common trash would consist of routine office trash, 

non-radioactive personal protective equipment (PPE) (i.e., gloves, etc), and PPE which was initially 

radioactive, but was stored until radioactive constituents decayed to background levels. Routine office 

trash and non-radioactive PPE would be disposed at the state-regulated INL landfill. 

Non-liquid low-level radioactive waste would include PPE used to enter the training area and sample 

material generated during training (i.e., analytical waste, soil, and wipes). All non-liquid low-level 

radioactive waste would be stored in accordance with INL procedures to allow decay of the radioactive 

constituents. After decay, the non-soil solid waste would be disposed at the state-regulated INL landfill, 

and soil samples would be returned to the training area. 

Liquid low-level radioactive waste would include water used to decontaminate personnel exiting the 

training area, liquid laboratory analytical waste, and sewage. All low-level decontamination water would 
8

be stored in accordance with INL procedures to allow decay to background levels of the radioactive 

constituents. 

After decay, the decontamination wastewater would be disposed to INL‘s Central Facilities Area 

(CFA) Sewage Treatment Plant (STP), since requirements do not allow disposal of decontamination 

wastewater off the INL Site. Project personnel would obtain approval from INL Facilities and Site 

Services for disposing decontamination wastewater to the CFA STP. Laboratory analytical waste would 

be solidified, allowed to decay if radioactive, and disposed at the state-regulated INL landfill; none of the 

laboratory waste is expected to be classified as hazardous waste. 

A commercial vendor, holding a valid State of Idaho permit, would supply and pump portable toilets 

for the use of those participating in the training exercises at the remote locations (i.e., North and South 

Training Ranges). Wastewater pumped from the portable toilets must be discharged to the CFA STP. The 

CFA STP must be included on the commercial vendors‘ State of Idaho approved list of disposal sites 

prior to discharge. INL Facilities and Site Services must grant project personnel approval to dispose 

wastes to the CFA STP. 

Project personnel would manage any hazardous waste generated in accordance with state regulations 

and disposed at a permitted off-INL facility. 

Typical Training Exercise:

Each training exercise could include up to 75 people and 15 vehicles at the range and conducted 

according to its own carefully prepared plan and schedule. Before the exercise, project personnel would 

perform a radiation background check and place monitoring equipment (such as air samplers for radiation 

monitoring) to verify initial conditions. Support equipment would include items such as radios, 

generators, and cargo containers, and command tents would also be set up as required. The radiological 

materials to be used would be carefully packaged and transported to the training ground and placed and/or 

dispersed according to the previously approved plan. The entire area would be carefully controlled in 

accordance with the security plan to prevent unauthorized persons from inadvertently entering. INL 

personnel would thoroughly brief training participants before each exercise about what is to take place, 

any potential hazards that may exist, and the expected course of the exercise events. 

For some exercises, INL personnel would place sealed radioactive sources, special form sealed 

radioactive sources, and contained (or unsealed) radioactive sources in approved areas. The sealed and 

contained sources will be removed from the exercise area on a daily basis and before the training event 

has concluded. For other exercises, INL personnel would disperse minute quantities of material in a liquid 

sprayed on the ground, spread dry, or in the air (through aerosol or small explosive dispersal). Trainees 

would use specialized equipment (see Table 1,  ̳Training Exercise Activities‘) to characterize the radiation 

fields or areas, obtain radiation readings, train with disablement tools, and collect samples in the test area 

to gain proficiency in using instruments and techniques to characterize an incident scene. Laboratory 

personnel will take measurements on samples of KBr obtained from the field or radioactive source 

materials and will store samples in locked containers that are appropriately shielded. When possible, nontoxic shielding (i.e., tungsten, bismuth) will be used in place of lead shot/shielding. 

The activities would continue for several days, depending on the exercise being conducted, and may 

include aerial-based monitoring of the test area. After each exercise, project personnel would remove and 

store test equipment and any sealed and contained source materials, and continue monitoring the test area 

until background radiation levels return to normal pre-test levels. DOE would then release the test area for 

unrestricted use. 

This EA analyzes two sub-alternatives: Alternative 1a  ̳Maximizing Training Flexibility‘ (see 

Section 2.3.1, refer to Figure 2) and Alternative 1b  ̳Minimizing Project Impacts‘ (see Section 2.3.2, refer 

to Figure 2), as well as the following descriptions. 
9

2.3.1 Alternative 1a – Maximizing Training Flexibility 

This alternative gives DOE the maximum training flexibility in conducting training exercises, as 

described above and below at the following locations. 

North Training Range:

T-28 Gravel Pit: Project personnel would use the T-28 gravel pit for radiological work (i.e., 

dispersing irradiated KBr via mechanisms such as spraying [liquid] on the ground or dispersing 

[aerosol] through the air using explosives or other mechanisms [i.e., gas, guns, etc.], and placement 

of sealed radioactive sources, special form sealed radioactive sources, and contained (or unsealed) 

radioactive sources. Mowing, grading, and leveling of small areas of the pit to remove or reduce 

vegetation for command centers, radiological source preparation, decontamination areas, and 

equipment storage. Project activities would not extend beyond the obvious boundaries of the gravel 

pit; in cases where the boundary is not clearly defined, project personnel would work with those 

responsible for the pit to place markers to identify the boundary. 

T-28 Road (North of the T-28 Gravel Pit): Project personnel would use T-28 for placement of the 

command centers and for travel to the west side of the larger area. Project personnel would identify 

two locations (100 x 100-feet each) to place command centers along the road (some adjustments 

would occur to protect sensitive cultural resources or wildlife). Project personnel would place 

sealed radioactive sources, special form sealed radioactive sources, and contained (or unsealed) 

radioactive sources in the approved exercise areas. To meet wildland fire requirements, mowing 

may occur to allow for a 30-foot buffer within the area for the command posts; however, mowing 

will not occur in culturally sensitive areas. 

T-28 Road and Access Road (South of the T-28 Gravel 

Pit) and the arc road and the berm/ditch structure 

(Northeast of the T-28 Gravel Pit): Project personnel 

would use the berm leading out of the northeast part of 

the gravel pit, the arch road across the top of the area, 

and T-28 to travel around the area on small vehicles to 

place and detect sealed sources. Project personnel would 

leave vehicles on the road and travel on foot to place 

sealed sources within the larger area. Further, there 

would be no off-road vehicle travel, or any extended 

stay, along those two-track roads or berm/ditch (see 

Figure 3). Project personnel would limit travel on the 

berm/ditch to ATVs, but may use light trucks on T-28 

and the arc two-track roads. In addition, project 

personnel would use the small disturbed areas just 

outside the south boundary of the gravel pit (right and left of the entrance road) as equipment 

laydown/storage areas along the southeast road for placement of command posts (100 x 100 feet). 

Large area surrounding the T-28 Pit: Project personnel would use this area to place sealed and 

contained sources; no other radiological work, other than allowed by the above description, would 

occur within this boundary. Entry to this area would be via foot traffic only. 

Fly Over: Project personnel would conduct flyovers of the North Training Range (T-28 Gravel Pit 

and surrounding area) to detect irradiated isotopes and sealed sources up to 12 week-long exercises 

per year: 

o Project activities may include using aerial platforms (such as fixed or rotary wing aircraft or 

unmanned aerial vehicles [UAV]) to fly over the RRTR. These aircraft would have sensor 

platforms to detect radioactivity and provide mapping of the area. Aircraft would fly over the 

range at varying above ground levels (AGL), possibly as low as 100 feet AGL or higher. The 

Figure 3. Berm/Ditch, Looking from 

north to south from the  ̳Arc‘ road 

toward the T-28 Gravel Pit.
10 

flights may involve multiple flyovers in patterns using paths determined by the trainees 

(e.g., along a north-south grid followed by an east-west grid on 100-meter flight line centers at 

multiple locations and speeds) or a single flyover. The number of flights per exercise would 

vary with the training requirements. Not all exercises would require aircraft activity. Some 

exercises may require multiple daily flyovers or flights during the exercise period. Fixed or 

rotary wing aircraft or UAVs may be leased and/or controlled by DOE or the group undergoing 

training (e.g., a military aircraft). 

o Overflights would be restricted to North and South Training Ranges. Overflights of occupied 

facilities at the INL would not occur in relation to the RRTR activities without a separate 

evaluation. Some rotary wing aircraft may land at the INL for refueling. In addition, project 

activities involving UAV‘s may use INL‘s UAV landing strip. 

o All aircraft operational activities would require extensive INL coordination and review 

processes, including flight planning, refueling plans, frequency reviews, security planning, and 

associated concerns. 

TAN/TSF Area: Project personnel would use the TAN/TSF area as equipment laydown and 

storage, including the storage and placement of sealed and contained sources for aerial and ground 

surveys. 

TAN Parking Lot: Project personnel would use the parking lot area to place sealed and contained 

sources; no other radiological work would occur in this area. Aerial and ground surveys to detect 

sealed and contained sources would occur in this area as well. 

South Training Range:

Parking lot near RWMC: Project personnel would use this area of the South Training Range for 

parking and non-radioactive equipment storage only. To meet wildland fire requirements, mowing 

may occur to allow for a 30-foot buffer within the current disturbed area; however, mowing will not 

occur in culturally sensitive areas. Project personnel would not use radioactive material in the 

parking lot. 

Road to Radiological Work Areas: Other than the ―West Gate Area‖ and the ―Center Area,‖ project 

personnel would only use the road to travel to and from the Radiological Work Area. Project 

personnel would not use areas along the road, other than those identified below, for purposes other 

than travel. Project personnel would not conduct any radiological work, including the use of sealed 

sources, in this area. 

West Gate Area: Project personnel would use this area for parking and the placement of command 

centers. Parking and the placement of the command centers would occur only on previously 

disturbed parts of the area. To meet wildland fire requirements, mowing may occur to allow for a 

30-foot buffer within the current disturbed area; however, mowing will not occur in culturally 

sensitive areas. There would be no radiological work done at this area. 

Center Area (along road to radiological work areas): Project personnel would use this area for 

parking and the placement of command centers. Parking and the placement of the command centers 

would occur only on previously disturbed parts of the area. To meet wildland fire requirements, 

mowing may occur to allow for a 30-foot buffer within the current disturbed area; however, 

mowing will not occur in culturally sensitive areas. Project personnel would not conduct any 

radiological work, including the use of sealed sources, in this area. 

Radiological Work Area: Radiological work would occur within the radiological work area 

(see Figure 2 & Figure 4) Project personnel would use the radiological work area to prepare and 

disperse irradiated KBr via mechanisms such as spraying [liquid] on the ground or dispersing 

[aerosol] using other mechanisms and placement of sealed radioactive sources, special form sealed 

radioactive sources, and contained (or unsealed) radioactive sources. Project personnel would 
11 

restrict their activities in the area adjacent to and west 

of the radiological work area to previously disturbed 

areas. To meet wildland fire requirements, mowing 

may occur to allow for a 30-foot buffer within the 

current disturbed area; however, mowing will not 

occur in culturally sensitive areas. No work with 

sealed and contained sources would occur at this site 

outside the Radiological Work Area boundaries. 

Project personnel would place a camera (with a sealed 

source) on the berm, but would not go farther out 

beyond the berm. 

2.3.2 Alternative 1b – Minimizing Project 

Impacts 

This alternative restricts project activities in the areas surrounding the T-28 Gravel Pit to minimize 

impact to biological and cultural resources. The project activities at the other locations (i.e., TAN/TSF, 

TAN Parking Lot, and the South Training Range) would remain the same as described in Alternative 1a. 

North Training Range:

T-28 Road (North of the T-28 Gravel Pit): Project personnel would not use T-28 for placement of 

the command centers; however, project activities would use T-28 (north of the gravel pit) to place 

and detect sealed sources in the larger area around the gravel pit. No activities along T-28 (north of 

the gravel pit) would require mowing to protect against wildland fire. 

All other activities around the T-28 Gravel Pit would remain unchanged from Alternative 1a, 

including:

o T-28 Gravel Pit

o T-28 Road and Access Road (South of the T-28 Gravel Pit) and the arc road and the berm/ditch 

structure (Northeast of the T-28 Gravel Pit)

o Large area surrounding the T-28 pit

o Flyovers

o TAN/TSF Area

o TAN Parking Lot.

South Training Range:

Same as in Alternative 1a. 

2.4 Alternative 2 – No Action 

DOE must consider a no action alternative in all of its EAs; the selection of the no action alternative 

means that the proposed activity, as described in Section 2.3, would not take place. For this EA, that 

means personnel would not receive training at INL to execute effective responses to major radiological 

incidents, including developing and testing tools and field methodology under realistic scenarios. 

 ̳No action‘ does not meet the purpose and need for the RRTR, and would decrease the ability to respond 

to major radiological incidents and increase risks to first responders, characterization personnel, and the 

public. 

INL would continue to use the gravel pit to mine gravel for various on-site uses. The TAN/TSF and 

parking area and areas south of RWMC would be available for other uses or reclamation activities. 

Figure 4. South Training Range area 

during initial testing activities.
12 

KBr Source Term (in curies)

Radionuclide Curies

Half-life

(Years)

P-33 1.357E-12 6.95E-02

Cl-36 2.258E-10 3.01E+05

Cl-38 2.890E-12 7.07E-05

Ar-39 1.479E-6 2.69E+02

Ar-41 2.106E-6 2.07E-04

K-40 3.803E-9 1.28E+09

K-42 4.260E-2 1.41E-03

K-43 1.133E-9 2.58E-03

Se-81 5.417E-14 3.52E-05

Se-81m 3.669E-14 1.09E-04

Br-80 2.500E-1 3.31E-05

Br-80m 2.339E-1 5.04E-04

Br-82 4.731E-1 4.03E-03

Br-82m 000E+00 1.17E-05

Br-83 1.936E-8 2.73E-04

Kr-79 9.409E-12 4.00E-03

Kr-83m 6.532E-8 3.48E-06

Total 1.00E+00 --

2.5 Operational Controls 

If DOE selects the proposed action, they would adopt operational controls as an integral part of its 

plan to help reduce the impacts of the action, and lower the potential for significant impacts (see Table 2). 

Table 2. Operational controls to avoid or lessen impacts to natural, ecological, and cultural resources. 

Activity Control

Vegetation removal or soil disturbance Conduct nesting bird surveys before vegetation removal or disturbance 

between May 1 and September 1.

Conduct pygmy rabbits surveys before removing vegetation or disturbing 

likely rabbit habitat.

Limit size of areas disturbed.

Revegetate project-related disturbed area with native species when closing 

the training range.

Project personnel will follow INL‘s Sitewide Noxious Weed Management Plan 

(Plan 611) to protect against the spread of noxious and invasive weeds—Soil 

and vegetation disturbing activities, including those associated with mowing, 

blading, and grubbing, have the potential to increase noxious weeds and 

invasive plant species that would be managed according to 7 USC § 2814, 

―Management of Undesirable Plants on Federal Lands,‖ and Executive Order 

13112, ―Invasive Species.‖ Project personnel would follow the applicable 

requirements to manage undesirable plants in the project areas, including 

spraying for noxious and invasive weeds.

Release of radionuclides to the 

environment

Periodically (no less than five years) perform a biota dose assessment at the 

North and South Training Range (see Section 4.1.2.1,  ̳Radiological 

Assessment‘ for details of methodologies, measurements and species 

assessed).

Project personnel will use signs posted on sawhorse type mounts or fence 

posts at the entrances to the training ranges and other access points to the 

radiologically controlled 

areas. The entrance 

areas are already highly 

disturbed with gates, 

roads, ditches, and so 

forth. Project personnel 

will control access at 

the North Training 

Range by locking the 

gate at the entrance to 

the radiation areas and 

placing 

radiation/contamination 

boundary signs. In 

addition, project 

personnel will notify INL 

Security for periodic 

patrols of the area.

Verify the curie content 

and isotopic 

distribution—both of the curies of the major, intended isotopes, and any from 

tramp contaminantsc(maximum of 1 curie at time of dispersal—see inset 

table for isotope breakdown) (ECAR-334, 2008).

 

c. Unwanted or unneeded trace or minor constituents. 
13 

Limiting access to the TAN Breeding 

Bird Survey route

Coordinate range operation to allow access to conduct the TAN Breeding 

Bird Survey route at the appropriate time.

Inset: Part of the ‘TAN’ 

Breeding route runs along the 

eastern and southern 

boundary of the North 

Training Range, then across 

the southern part of the 

‘sealed and contained source 

area’.

Soil disturbance at the following project 

area:

Parking Lot near RWMC

Road to Radiological Work Area

West Gate Command, Storage, 

and Parking Area

Center Command, Storage, and 

Parking Area

Radiological Work Area

TSF Administrative Area

Parking Lot east of TSF Area

T-28 South Gravel Pit

T-28 Road Corridor

Project Boundary surrounding T-28 

South Gravel Pit

Minimize ground disturbance.

Project personnel would notify and receive approval from Cultural Resource 

Management personnel before setting up and staging temporary command 

post to avoid impacts to cultural resources.

Periodically (or as needed to assure project activities do not cause adverse 

impact) complete cultural resource monitoring in sensitive areas with authority 

to redirect work to avoid any sensitive materials discovered.

Implement a stop work procedure to guide the assessment and protection of 

any unanticipated discoveries of cultural materials.

Complete cultural resource sensitivity training for project personnel to 

discourage unauthorized artifact collection, off-road vehicle use, and other 

activities that may impact cultural resources. Encourage a sense of 

stewardship for cultural resources, including tribally sensitive plants and 

animals.

Minimize disturbance to wildlife species important to the Shoshone-Bannock 

Tribes by using appropriate methods, which could include seasonal or timeof-day restrictions, good housekeeping, and awareness training.

3.0 AFFECTED ENVIRONMENT 

INL consists of eight major facilities, each less than 2-square miles, situated on an 890-square-mile 

expanse of otherwise undeveloped, cool, desert terrain, and with most INL buildings and structures 

occurring within these developed site areas and separated by miles of primarily undeveloped land. DOE 

controls all INL Site land (see Figure 1), which occupies portions of five Idaho counties: Butte, Bingham, 

Bonneville, Clark, and Jefferson. Population centers in the region include large cities (>10,000) such as 

Idaho Falls, Pocatello, Rexburg, and Blackfoot, located greater than 30 miles to the east and south, and 

several smaller cities/communities (<10,000) located around the site (about 1-30 miles away), such as 

Arco, Howe, Mud Lake, Fort Hall Indian Reservation, and Atomic City (see Figure 1). Craters of the 

Moon National Monument is less than 20 miles to the west; Yellowstone and Grand Teton National Parks 

and the city of Jackson, WY are located more than 70 miles northeast. No permanent residents exist on 

the INL Site.

The five Idaho counties that are part of the INL Site are all in attainment area (see glossary) or are 

unclassified for National Ambient Air Quality Standards (NAAQS) status under the Clean Air Act (CAA)

(see glossary). The nearest nonattainment area (see glossary) is located about 50 miles south of INL in 

Power and Bannock counties. INL is classified under the Prevention of Significant Deterioration (PSD)

(see glossary) regulations as a Class II area—an area with reasonable or moderately good air quality. 

Surface waters on the site include the Big Lost River and Birch Creek; both streams carry water on an 

irregular basis, with the majority of the flow diverted for irrigation before entering INL. During high 

water years or during the shutdown of the diversion, Birch Creek has the potential to flow down its 
14 

historic channel and through parts of T-28 and the gravel pit. Most of INL is underlain by the Snake River 

Plain Aquifer (SRPA), which lies between 220 feet (at TAN) to 610 feet (at the South Training Range) 

below the site. The geology above the SRPA, the vadose zone (see glossary), is generally comprised of 

basalt (95%) with a layer of soil (loess) and/or sediment on top of the basalt with thin layers of sediments 

(1 to 20-foot intervals) between basalt flows. The SRPA has similar geology as the overlying vadose zone 

and is generally 250 to 900-feet thick. 

The natural vegetation of the INL consists of a shrub overstory with a grass and forbs understory. The 

most common shrub is Wyoming big sagebrush, where basin big sage may dominate or co-dominate in 

areas with deep or sandy soils (Shumar and Anderson 1986). Other common shrubs include green 

rabbitbrush, winterfat, spiney hopsage, gray horsebrush, gray rabbitbrush, and prickly phlox (Anderson et 

al. 1996). The shrub understory consists of native grasses, thickspiked wheatgrass, Indian ricegrass, 

bottlebrush squirreltail, needle-and-thread grass, Nevada bluegrass, and bluebunch wheatgrass and native 

forbs (i.e., tabertip hawksbeard, Hood‘s phlox, hoary false yarrow, paintbrush, globe-mallow, buckwheat, 

lupine, milkvetches, and mustards) (Anderson et al. 1996). In a 1999 proclamation, the Secretary of 

Energy designated a portion of INL as the Sagebrush Steppe Ecosystem Reserve with a mission to 

provide research opportunities and preserve sagebrush steppe habitat. Representatives of the Bureau of 

Land management, U. S. Fish and Wildlife Service, and the Idaho Department of Fish and Game cosigned the proclamation. In addition, the INL Site is designated as National Environmental Research 

Park (NERP) (see glossary). 

A wide range of vertebrate species are located within the site; several species are considered 

sagebrush-obligate species, meaning that they rely upon sagebrush for survival. These species include 

sage sparrow, Brewer‘s sparrow, northern sagebrush lizard, Greater sage-grouse, and pygmy rabbit. 

There are currently no species that occur on the INL that are listed as Endangered or Threatened; 

however, several Species of Concern or Candidate Species, including sage-grouse, long-eared myotis, 

small-footed myotis, Townsend‘s big-eared bat, pygmy rabbit, Merriam‘s shrew, sage-grouse, long-billed 

curlew, ferruginous hawk, northern sagebrush lizard, and loggerhead shrike, do occur on the site. 

Geographically, INL is included within a large territory once inhabited by, and still of importance to, 

the Shoshone-Bannock tribes. To the Shoshone-Bannock people, cultural resources include not only 

archaeological sites affiliated with their history, but also many kinds of natural resources as well, such as 

traditionally used plants and animals. Finally, features of the natural landscape, such as buttes, rivers, and 

caves, often have particular significance to the tribes. 

The INL Site has a rich and varied cultural resource record due to its continuous access restriction and 

geographic remoteness. This includes localities that provide an important paleontological context for the 

region and the many prehistoric archaeological sites. These campsites, cairns (see glossary), and hunting 

blinds provide information about the activities of aboriginal hunting and gathering groups who inhabited 

the area for at least 13,500 years. The archaeological sites, pictographs, caves, and many other features 

are important to contemporary Native American groups for historic, religious, and traditional reasons. 

Many historic sites document the area‘s use during the late 1800s and early 1900s, including the 

abandoned town of Pioneer/Powell, a northern spur of the Oregon Trail known as Goodale‘s Cutoff, 

many small homesteads, irrigation canals, sheep and cattle camps, and stage and wagon trails. During 

World War II, the military used the central portion of the INL to test fire ordnance used by the Pacific 

Fleet and evidence of this era remain. Finally, many scientific and technical facilities have preserved 

important information on the historic development of nuclear science in America (DOE-ID, 2009). 

The proposed ranges are intentionally located at or near previously disturbed sites to minimize further 

disturbance to the natural and cultural environment. Much of the proposed test locations (see Figure 2) 

have been subjected to disturbance, such as construction and demolition activities, gravel pits, roads and 

other infrastructure, or previous research activities; however, a portion of the area north of the TAN 

gravel pit is primarily undisturbed (see Figure 2).
15 

4.0 ENVIRONMENTAL CONSEQUENCES 

The following sections evaluate direct, indirect, and cumulative environmental impacts that are likely 

to occur from the alternatives described in Section 2. Section 4.1 discusses the environmental impacts 

associated with Alternative 1, with discussion on environmental impacts divided between the two 

sub-alternatives as described in Sections 2.3.1 and 2.3.2. Section 4.2 discusses the environmental impacts 

associated with  ̳no action.‘ Each section discusses cause and effect relationships, including cumulative 

impacts, of the proposed actions on INL‘s natural, biological, and cultural resources; mitigative measures 

needed to lessen impacts; and those permits and regulations required to protect the resources. 

During the EA scoping meeting, resource personnel identified that air, water, biological, and cultural 

resources are most likely to be affected by the proposed actions. Therefore, the environmental 

consequences of those resource areas are the focus of this EA. The following sections discuss the 

environmental impacts of both alternatives on the above resources: Risk Analysis (air/water), Biological 

Resources, and Cultural/Historical Resources. 

4.1 Alternative 1 – North and South Training Range 

4.1.1 Risk Assessment 

The risk assessment uses three environmental transport and dose assessment models to analyze dose 

to the public and employee from dispersed radioactive material. These models estimate transport and 

radiological dose from the atmospheric, surface, and groundwater pathways. Risk for this assessment is 

quantified in terms of radiological dose. Radiological dose is quantified in terms of the effective dose 

equivalent (EDE) dand includes the dose from external radiation and the 50-year committed dose from 

radionuclides ingested or inhaled. The EDE is the weighted sum of the dose equivalent to each organ of 

interest and has units of rem. The dose equivalent is the adsorbed dose (i.e., the energy imparted to tissue 

by ionizing radiation) to a given organ times a quality factor which is a measure of the relative biological 

effect of the radiation type. 

This risk assessment evaluates the radiological doses to human associated with the use of dispersed 

radioactive materials for this training exercise. Atmospheric, surface, and groundwater pathway dose 

codes were used to calculate the EDE to hypothetical individuals for several exposure scenarios. 

Interrogation activities such as a variety of high-energy techniques including X-ray, flash x-ray, 

portable isotopic neutron spectroscopy, and radiation generating devices would occur within the T-28 

Gravel Pit and TAN/TSF area in the North Training area and the Radiological Work Area in the South 

Training Area when workers are present. Interrogation techniques such as these are already in use at INL 

location and would not result in additional risk to the environment or the worker. Worker exposure would 

be controlled in accordance with the radiological work permit (see glossary); there would be no exposure 

to the public from sealed radioactive sources, special form sealed radioactive sources, and contained (or 

unsealed) radioactive sources. 

Atmospheric Pathway:

This section discusses the methodology used to determine the EDE to the maximum exposed 

individual at the site boundary and to employees located at facilities near the training grounds. Refer to 

ECAR 1109 (2010) for details on methodology, source terms, and radionuclide specific information. 

Federal regulation 40 CFR 61 Subpart H establishes a dose limit to the public of 10 millirem/yr EDE 

from DOE activities. The estimated EDE to the public from the proposed work would be far below the 

allowed limit. 

 

d. Effective dose equivalent is expressed in units of rem/year. 
16 

In accordance with Federal regulations 40 CFR 61 subpart H (Radiological NESHAP, see glossary), 

the atmospheric transport and radiological dose code, CAP88 PC Version 3 (EPA 2007), was used to 

calculate EDEs to a maximum exposed individual located at the nearest site boundary using the 

methodology described in the 2009 Radiological NESHAP report (DOE-ID 2010). EDEs were calculated 

by assuming the total releases from 12 exercises over a period of a year. EDEs were calculated for the 

maximum exposed individual at the site boundary (public) and for an employee located 1,384 meter from 

the North Training Range at TAN and 1,480 meter from the South Training Range at RWMC. These 

distances represent the distance to the nearest facility from the training grounds where a employee may 

potentially be exposed. In this document, EDEs to the maximum exposed individual at the site boundary 

and the employee are reported separately for the two proposed training ranges. 

The EDE for the average annual release scenarioeat the closest site boundary (EDE to the public) is 

0.000588 millirem/year for the North Training Range (specifically the T-28 Gravel Pit), and 0.000706 

millirem/year for the South Training Range (specifically, the radiological work area). Corresponding EDE 

values to the nearest site facility (EDE to the employee) is 0.0412 millirem/year for the North and 0.0365 

for the South Training Ranges (see Table 3). 

The maximum EDE to the public at the North Training Range location for the annual average release 

scenario is almost 17,000 times less than the 10 millirem/yr EDE limit (INL Administrative Control Level 

for the Public), and about 185 times less than the 10 millirem/yr EDE limit for the maximum release 

scenario. For the South Training Range location, the annual average release scenario is almost 14,000 

times less than the 10 millirem/yr EDE limit and about 155 times less than the 10 millirem/yr EDE limit 

for the maximum release scenariof(see Table 3). The maximum site boundary is located 12,522 meters 

northeast of TAN and 7,976 meters southwest of RWMC. 

Surface Pathway

The second model uses a surface pathway code (RESRAD Version 6.5) that computes the EDE if a 

person were to move on to the training range after 15 years of dispersing the radioactive material on the 

ground with the assumption that 12 exercises were performed each year. The person is assumed to grow 

vegetables, raise beef, and ingest milk from livestock feeding on the contaminated ground. Other 

exposure pathways include direct external exposure, soil ingestion, and inhalation of re-suspended soil 

surface particulates. The surface pathway model calculated an EDE of 0.000164 millirem/yr to a person 

(see Table 3).

Groundwater Pathway:

The groundwater pathway methodology used a 2-step screening process: (1) Radionuclides with a 

half-life less than a year were eliminated from groundwater pathway assessment because of the length of 

time it takes to get to the groundwater, and (2) Radionuclides with a half-life greater than a year and were 

not noble gases were evaluated with the GWSCREEN (Rood 2003) model. 

Federal and state drinking water regulations establish a radioactive dose limit of 4 millirem/yr dose 

equivalent from man-made radionuclides. This limit applies to public drinking water sources. For the 

purpose of this evaluation, it was assumed that a public drinking water well was located at the testing 

ranges; the nearest off-site, down-gradient public well is actually located near Arco. In accordance with 

Federal and State drinking water regulations, groundwater concentrations and ingestion doses are based 

on drinking 2 liters of water per day for 365 days per year and 12 exercises each year for 15 years. The 

resulting estimated doses are substantially below the Maximum Contaminant Level for Cl-36 of 700 

picocuries/liter (EPA 2000). Groundwater ingestion EDEs are less than 0.0002 millirem/yr (see Table 3). 

 

e. Annual average release scenario assumes 8-hour release rate times 12 exercises per year. 

f. Maximum release scenario assumes experiments are continuous for 24 hours per day, 365 days per year. 
17 

Regulatory Requirements:g

INL conducts radiological operations in a manner that ensures the health and safety of all general 

employees, contractors, and the public. To achieve this objective, the INL ensures that radiation 

exposures to its employees and the public and releases of radioactivity to the environment are maintained 

below regulatory limits; in addition, deliberate efforts are taken to further reduce exposures and releases 

as low as reasonably achievable (ALARA). 

The proposed activities at the RRTR create a potential for multiple types of exposure. The handling of 

activated KBr and the placement of sealed sources at the training range generates dose. Surface 

contamination and airborne radioactivity is generated by the distribution of the KBr solution over the 

designated fields at the training range. 

The rules in 10 CFR 835, ―Department of Energy (DOE) Occupational Radiation Protection,‖ 

establishes radiation protection standards, limits, and program requirements for protecting employees and 

the public from all ionizing radiation resulting from the conduct of DOE activities. The dose limit from 

DOE sources to employees is 5000 millirem per year (millirem/yr) EDE. 10 CFR 835 also establishes a 

dose limit for the public entering a controlled area at 100 millirem/yr EDE. DOE Order 5400.5, 

―Radiation Protection of the Public and the Environment,‖ also establishes a dose limit of 100 millirem/yr 

EDE for the public. 

The ALARA process is an approach to radiological control to further reduce and control individual 

and collective radiation exposures through appropriate control of radioactive material, contamination, and 

airborne radioactivity. The purpose of the INL ALARA Program is to reduce and maintain radiation 

exposures as far below the applicable controlling limits of 10 CFR 835 and the INL Radiological Control 

Manual (RCM) as is reasonably achievable. Therefore, laboratory management at INL has set an 

administrative control level for all activities to limit possible exposures to the public to 10% of the 

regulatory limit, which equates to 10 millirem per year. The INL administrative control level limit for 

possible exposures to employees is 14% of the regulatory limit, which equates to 700 millirem/yr. 

Putting Calculated Dose In Perspective:

The majority of radionuclides generated by the irradiated KBr have a short half-life and completely 

decay in about two weeks. The few remaining radionuclides with longer half-lives are at very low 

concentrations and have been modeled in extremely conservative environmental scenarios to determine 

the risk of exposure to employees and the public. 

The sum of the atmospheric, surface, and groundwater models show the public dose would be about 

0.01% of the INL Administrative Control Level for the Public. In addition, to put these doses in 

perspective, other radiation dose producing activities have been included in the table for comparison; for 

example, the average annual radiation dose to all of the U. S. general population from natural background 

radiation sources is approximately 310 millirem. (compare to  ̳Regulatory Requirements‘ and  ̳Other 

Radiation Dose Producing Activities‘ in Table 3. 

4.1.2 Biological Resources 

Potential impacts to vegetation communities, such as sensitive plant species and species of 

ethnobotanical (the plant lore and agricultural customs of a people) concern, associated with the proposed 

activity would be minimized by limiting the footprint of the disturbance, revegetating the areas that have 

been disturbed, and implementing a weed management plan. Revegetating with a diverse mix of native 

species similar in composition to the existing plant community may help maintain the diversity of those 

communities. Revegetation in sagebrush steppe is generally successful in only one of three years because 

of the variability in availability and the timing of precipitation. 

 

g. Non DOE regulatory requirements are discussed under Section 4.1 ( ̳Atmospheric Pathway‘ and  ̳Groundwater Pathway‘). 
18 

Certain proposed activities would have unavoidable impacts to wildlife, such as: (1) loss of grounddwelling wildlife species and associated habitat, (2) displacement of certain wildlife species due to 

increased habitat fragmentation, and (3) an increase in the potential for negative interaction between 

wildlife and humans (Blew et al. 2010). The control measures that would reduce the impact on wildlife 

include seasonal timing of activities, nesting bird surveys, and awareness programs. 

Wildlife species of concern include sage-grouse, all migratory birds (including raptors), pygmy 

rabbits, Great Basin rattlesnakes, and all large mammal species (Blew et. al. 2010). Nesting bird surveys 

would be conducted before any soil or vegetation disturbance occurring between May 1 and September 1. 

No critical habitat for threatened or endangered species, as defined in the Endangered Species Act (ESA), 

exists on the INL Site. Sage-grouse is a Candidate Species for listing under ESA. It is likely that the 

proposed activity would have a direct impact on pygmy rabbits and indirect effects on sage-grouse, 

pygmy rabbits, or other sensitive species through habitat alteration (Blew et al. 2010). Impact from using 

interrogation devices (as described in Section 2 [see Table 3] and Section 4.1 (under  ̳Risk Assessment‘) 

would not result in additional risk to biological resources. 

Table 3. Regulatory Dose Requirements, Calculated Project Dose, and Perspectives. 

4.1.2.1 Regulatory Requirements (Federal & INL) Effective Dose Equivalent (EDE)

(millirem/yr)

Federal Regulatory Limit for Public (40 CFR 61 subpart H) 10

40 CFR 141 Safe Drinking Water Act 4

Federal Regulatory Limit for Employees (10 CFR 835) 5000

INL Administrative Control Level for Employees 700

Federal Regulatory Limit for the Public

(10 CFR 835 & DOE 5400.5) 100

INL Administrative Control Level for the Public 10

Project Calculated Dose

Average Annual

Release

Scenario

Maximum Release

Scenario**

Atmospheric Pathway (Model 1 – Public)

Release to North Training Range 0.000588 0.0537

Release to South Training Range 0.000706 0.0645

Atmospheric Pathway (Model 1 – Employee)

Release to North Training Range 0.0412 3.76

Release to South Training Range 0.0365 3.33

Surface Pathway Model Ingestion Dose (Model 2) 0.000164

Groundwater Pathway Model Ingestion Dose (Model 3) 0.0002

Other Radiation Dose Producing Activities Average Dose (millirem)

Dose to all US Population from natural background radioactive 

sources per year

310

Airline Flight from New York to London 4

1 Abdominal X-Ray 70

Mammography 40

X-Ray Spine series 500

Abdominal CT Scan 800

** The doses for this scenario assume KBr training is continuous over the year (i.e., 24-hours per day, 365 days per year). The total activity released in this 

scenario is 91 times the total activity released from the 12 releases expected for a year. The purpose of the scenario is to assure that it is not feasible to 

estimate a dose greater than 10 millirem/yr to the maximum exposed individual from operation of the KBr training facility.
19 

Alternative 1a ‘Maximizing Project Flexibility’ 

Sage-Grouse:

Surveys found suitable habitat for sage-grouse in the North and South Training Ranges. In the North 

Training Range sage-grouse habitat occurs along both sides of T-28 (North of the T-28 Gravel Pit). While 

the placement of command posts along the northern section of T-28 would remove vegetation, the 

impacts to sage-grouse and their habitat would be minimal due to the limited amount of disturbance (i.e., 

two 100-foot x100-foot areas for command posts) planned in the areas with habitat. Setting up and 

operating command posts may be disruptive to sage-grouse using the area along the road for rearing 

offspring. While placing command posts along the access road (South of the T-28 Gravel Pit) would not 

affect sage-grouse or their habitat, it could still disturb or destroy nesting migratory birds. At the South 

Training Range, project activities would be limited to the road and previously disturbed areas; therefore, 

training exercises conducted in that area would not impact sage-grouse habitat. Project personnel can 

minimize these impacts by limiting the disturbance footprint, implementing a weed management strategy 

to control invasive and noxious weeds, and following up with revegetation when the training ranges close. 

Any activity potentially disturbing vegetation or soils would require a nesting bird survey prior to 

disturbance. 

Pygmy Rabbit:

Pygmy rabbit habitat occurs in the North and South Training Ranges. Surveys found extensive pygmy 

rabbit habitat and signs at the North Training Range, areas west of the gravel pit, and along both sides of 

the T-28 road (North of the T-28 Gravel Pit), as well as numerous locations containing actual sightings, 

burrow systems, and scat. Due to the mature stands of basin big sagebrush along the road and ample cover 

and forage as well as deep soils, this becomes an ideal setting for the rabbits. Any vegetation disturbance 

to this section of the project area would result in a direct loss of habitat for pygmy rabbits and possible 

loss of individuals as well. Setting up and operating command posts may be disruptive to pygmy rabbits 

using the area along the road. At the South Training Range, project activities would be limited to the road 

and previously disturbed areas; therefore, training exercises conducted in that area would not impact 

pygmy rabbit habitat. 

Habitat Fragmentation:

Nearly all of the sites where the proposed activities would remove habitat have been previously 

disturbed. The exception is the portion of T-28 road extending north from the T-28 gravel pit. Although 

this road already exerts some force on fragmentation, the loss of vegetation at multiple locations along 

that road would likely increase fragmentation of sagebrush habitat. Project personnel can minimize these 

impacts by limiting the disturbance footprint, implementing a weed management strategy to control 

invasive and noxious weeds, and following up with revegetation when the training ranges close. 

Radiological Assessment:

Radiological impacts to plants and animals are unlikely due to the short radiological half-lives (most 

less than 24 hours) and low concentrations. In addition, the long-lived radionuclides in the dispersed 

radioactive material (Ar-39, Cl-36, and K-40) are naturally occurring in the environment (see Table 1), 

and the addition of the concentrations proposed are insignificant compared to those naturally occurring. 

Sealed radioactive sources, special form sealed radioactive sources, and the contained (or unsealed) 

radioactive sources would be in the area only when people are actively working; thus, lessening the 

opportunity of animals being present. However, to ascertain no impacts to animals and plants are 

occurring, a biota dose assessment would be conducted periodically as required by DOE Orders 450.1a 

(2008) and 5400.5 (1993) (see Table 2). 

RESRAD Biota Dose Assessment Program (DOE 2004) will be used for the assessment of doses received 

and biota dose guidelines (DOE 2002, ICRP 2004) for the evaluation of impacts from those doses. 
20 

RESRAD Biota calculates a ratio for terrestrial plant and animal scenarios based on potential hazards 

associated with limits of 10 mGy d-1 (1 rad d-1) and 1 mGy d-1 (0.1 rad d-1) for terrestrial plants and 

animals respectively. The program assesses the impacts on small mammals that would likely receive the 

highest doses due to their small home ranges and the potential for them to reside consistently in a 

potentially contaminated area. If specific evaluations are needed for additional species, the program 

permits entering data to allow this. However, this scenario would only be used if the initial evaluations 

exceeded the guidelines (DOE 2002). 

Ecological Research and Monitoring:

Several long-term breeding bird surveys exist on the INL to help in monitoring breeding bird 

populations potential impacts of activities across the site. One of those routes travels along and through 

parts of the North Training Area (see Table 2). Limiting access to the large area at the North Training 

Range would adversely affect the continuity and utility of a long-term Breeding Bird Survey route. 

Coordinating timing of access to this route as an operational control would eliminate this impact. 

Continuation of the monitoring route would also provide information on the potential impacts the 

proposed action may have on local bird populations. 

Cumulative Effects:

Those resources that would be most at risk to cumulative impacts from project activities include 

native vegetation, sage grouse, pygmy rabbits, and cultural resources. These resources are found 

throughout the INL Site, including near the proposed North and South training ranges as described in this 

EA. The geographic boundaries of these species vary from locally to regionally: Sage-grouse on the INL 

migrate off site and travel many miles both on- and off-site. Pygmy rabbits also occur throughout the site, 

but likely move little. Both species are sagebrush obligates and closely associate with sagebrush on the 

INL Site. Cultural resources are found in very specific areas across the INL, including certain locations 

within the project areas. 

The INL Site is (and has been) the home to different projects and includes several primary facility 

areas situated on an expanse of otherwise undeveloped, high-desert terrain. Most facilities are located 

within facility boundaries, and are generally contained within 2-square mile facility areas. Current 

facilities and activities located near the proposed ranges include the Specific Manufacturing Capability 

(SMC), Test Area North (TAN), and the T-28 gravel pit (near the North Training Range) and the 

Radioactive Waste Management Complex and EBR-I, a National Historical Landmark (near the South 

Training Range) (See Figure 2). SMC is an active facility, while DOE has demolished most of the TAN 

buildings. The T-28 gravel pit (part of the North Training Range) is active and project personnel would 

coordinate project-related activities with the need to mine the pit for gravel. RWMC and EBR-I are both 

active facilities near the South Training Range. In addition, the South Training Range is located within an 

area previously used for similar experiments, only on a much smaller scale. 

DOE is always planning for future projects on the INL Site. Recent and ongoing EAs are indicative of 

foreseeable future actions, such as the Low-level Waste Disposal Facility, Multipurpose Haul Road 

within the Idaho National Laboratory Site (DOE/EA-1772), and the proposed Stand-Off Experiment 

(SOX) Range (DOE/EA-1822). The SOX Range project is adjacent to the North Test Range. In addition, 

there are a number of non-paved (two-track) roads throughout the INL Site and adjacent to and within the 

proposed training ranges. 

Section 3.0  ̳Affected Environment‘, Section 4.1  ̳Alternative 1‘, and the referenced report (Blew, et 

al., 2010) give a baseline for sage grouse and pygmy rabbits both on the INL and specific to the project 

areas. In addition, recent fires on the INL resulted in a substantial loss of sagebrush on the INL Site; 

however, the additional loss of sagebrush, as a result of this project (Alternative 1a or 1b), does not 

significantly increase the impact caused by that wildland fire. 
21 

DOE reviewed the resources at risk; their geographic boundaries; past, present, and reasonable 

foreseeable future actions; and baseline information in determining the significance of cumulative 

impacts. The impacts associated with Alternative 1a have a small footprint, low intensity, and are near 

areas with much larger impacts to ecological and cultural resources. Operational controls described in 

Section 2 (Table 2) would help keep direct and indirect impacts to sage-grouse, pygmy rabbit, migratory 

birds, and cultural resources small. Placing command posts along the access road (North of the T-28 

Gravel Pit) would remove less than 0.5 acres (2-100 x100-foot areas along T-28) of sagebrush habitat, but 

could potentially adversely affect nesting migratory birds, but would avoid cultural resources. Project 

personnel would minimize these impacts by limiting the disturbance footprint, implementing a weed 

management strategy to control invasive and noxious weeds, and follow up with revegetation when the 

training ranges close. Additionally, by completing cultural resource sensitivity training, implementing 

stop work procedures, and including an archaeologist in pre-project planning activities with the objective 

to avoid known cultural resources would minimize the potential for cumulative impacts. Any activity 

potentially disturbing vegetation or soils would require a nesting bird survey before disturbance, and if 

nesting migratory birds are found, no disturbance will be allowed during the nesting season. Therefore, 

while impacts and cumulative effects to those species and their habitat are not zero, they are likely low 

given other habitat exists on the INL. 

4.1.2.2 Alternative 1b ‘Minimizing Project Impacts’ 

Removing T-28 (North of the Gravel Pit) from consideration for command posts reduces the level of 

impacts to sage-grouse, pygmy rabbits, and habitat fragmentation. While some disruptive activities may 

still occur from traveling the road to place and detect radiological sources, those will likely be short-term. 

There would likely be no direct impacts to sage-grouse or pygmy rabbits or their habitat. While placing 

command posts along the access road (South of the T-28 Gravel Pit) would not affect sage-grouse or 

pygmy rabbits or their habitat, it could still disturb or destroy nesting migratory birds. Alternative 1b 

would continue to have similar potential for radiological impacts, and may limit access to ecological and 

monitoring activities. Project personnel would minimize these impacts by limiting the disturbance 

footprint, implementing a weed management strategy to control invasive and noxious weeds, and 

following up with revegetation when the training ranges close. Any activity potentially disturbing 

vegetation or soils would require a nesting bird survey before disturbance and if nesting migratory birds 

are found, no disturbance will be allowed during the nesting season. At the South Training Range, project 

activities would be limited to the road and previously disturbed areas; therefore, training exercises 

conducted in that area would not impact sage-grouse or pygmy rabbit habitat. 

Regulatory Requirements:

Soil and vegetation-disturbing activities, including those associated with mowing, blading, and 

grubbing, have the potential to increase noxious weeds and invasive plant species that would be managed 

according to 7 USC § 2814, ―Management of Undesirable Plants on Federal Lands,‖ and Executive Order 

13112, ―Invasive Species.‖ INL would follow the applicable requirements to manage undesirable plants. 

In analyzing the potential ecological impacts of the action alternative for this project, DOE-ID has 

followed the requirements of the Endangered Species Act (16 USC §1531 et seq.) and has reviewed the 

most current lists for threatened and endangered plant and animal species. Other federal laws that may 

apply include the Fish and Wildlife Coordination Act (16 USC § 661 et seq.), the Bald Eagle Protection 

Act (16 USC § 668), and the Migratory Bird Treaty Act (16 USC § 715–715s). If a species such as the 

sage-grouse or pygmy rabbit are listed before or during construction of the facility, DOE would initiate 

formal consultation with the U.S. Fish and Wildlife Service. 

4.1.3 Cultural Resources 

The proposed action described in alternative 1a or 1b would cause minor direct and indirect impacts 

on the cultural resources and archaeological sites at the North Training Range (near the T-28 gravel pit); 
22 

impacts at the South Training Range (near RWMC) are unlikely. Impact from using interrogation devices 

(as described in Section 2 (Table 2) and Section 4.1 (under  ̳Risk Assessment‘) would not result in 

additional risk to cultural resources. 

4.1.3.1 Alternative 1a ‘Maximizing Project Flexibility’ 

The North Training Range is located within the Birch Creek Sinks where several historic channels of 

Birch Creek traverse the project area. The proposed project area is also adjacent to the historic shoreline 

of Pleistocene Lake Terreton. Given these factors and based on observations from past archaeological 

surveys, it has been determined that the area within and surrounding the North Training Range is highly 

sensitive archaeologically, except for the TAN/TSF and parking lot areas. Anticipated prehistoric 

archaeological resources could range from 13,500-year-old hunting camps to historic agricultural 

activities dating from 60 to 150 years. 

Due to the nature and extent of cultural resources already identified that may be directly and 

indirectly impacted by project activities within the defined areas of potential effect, cultural surveys 

would be required before starting any soil disturbing activities. INL‘s Cultural Resource Management 

Office would assess all newly recorded resources for eligibility to the National Register of Historic Places 

and for project effects (impacts to cultural or historic resources) in consultation with the Idaho State 

Historic Preservation Office and Shoshone-Bannock Tribes. 

In addition, archaeological sites and Native American resources identified within the project area 

would also be subject to indirect impacts during project activities because of higher visibility on the 

landscape and overall increases in human activity levels in an area that has previously been somewhat 

remote. Artifacts may be subject to unauthorized collection or affected by unauthorized off-road vehicle 

use. Resident and migratory birds and animals of importance to the Shoshone-Bannock Tribes may be 

disturbed and noxious and invasive weeds may increase, to the detriment of native plant species with 

tribal value. 

Three previous cultural resource investigations have been conducted in the general vicinities of the 

project areas under consideration for the RRTR; two in the T-28 gravel pit area (Miller 1985; Ross et al. 

1986) and one at the South Training Range (INL CRMO Project Files: BEA-08-26). The two previous 

surveys conducted within the North Training Range identified eight prehistoric sites and four isolated 

finds within the administrative boundaries of the T-28 gravel pit; however, these past surveys are older 

than ten years. As such, Cultural Resource personnel would need to conduct new surveys in the area and 

along T-28 as described in Table 2. Preliminary investigations have shown extensive prehistoric land use 

dating to 11,000 years before present. 

Cultural resource personnel previously surveyed the TAN/TSF, TAN parking lot, and the areas 

consisting of the South Training Range; therefore, no further cultural surveys would need to be conducted 

at those areas, unless soil disturbance uncovers items of interest. 

Project activities would include operational controls before and during project activities to minimize 

the potential for adverse direct and indirect impacts to cultural resources using a tiered approach with 

initial efforts focusing on identification and assessment, followed by various protection strategies as 

discussed in Table 2. While there is the potential for cumulative impacts to cultural resources, operational 

controls, as described in the document would avoid adverse impact. 

4.1.3.2 Alternative 1b ‘Minimizing Project Impacts’ 

Alternative 1b has the same impacts as Alternative 1a, with the exception that removing the 

placement of command posts along the northern portion of the T-28 road (north of the Gravel Pit) reduces 

the level of impacts to cultural resources in this sensitive area. While disruptive activities may still occur 

along this portion of roadway from traffic along the road and walking out into the sagebrush to place and 

detect radiological sources, those would likely be minimal. Project personnel would follow the 
23 

operational controls outlined in Table 2 to avoid adverse impacts to cultural resources. Mowing would not 

be required along the T-28 road (north of the gravel pit) to protect from wildfires. 

Regulatory Requirements:

A variety of laws, regulations, and statutes manage or protect cultural resources. Such resources 

include buildings, sites, structures, or objects; each of which may have historical, architectural, 

archaeological, cultural, and scientific importance. Most of these requirements have been tailored to the 

unique needs of the INL through Programmatic Agreement between DOE-ID, the Idaho SHPO, and the 

Advisory Council on Historic Preservation. The requirements include: 

• Antiquities Act of 1906 (Public Law 59-209) 

• Reservoir Salvage Act of 1960 (Public Law 86-523) 

• National Historic Preservation Act of 1966 (Public Law 89-665); Section 106 of this act and its 

implementing procedures require federal agencies to take into account the potential effects of 

proposed projects on historic properties listed on or potentially eligible for listing on the National 

Register of Historic Places 

• National Environmental Policy Act of 1969 (42 USC § 4321 et seq.) 

• Protection and Enhancement of the Cultural Environment (Executive Order 11593) 

• Archaeological and Historic Preservation Act of 1974 (Public Law 93-291) 

• Archaeological Resources Protection Act of 1979 (Public Law 96-95) 

• Native American Graves Protection and Repatriation Act of 1990 (43 CFR 10). 

4.1.4 Other Resources 

Section 4.1.1,  ̳Risk Assessment,‘ considers the potential impacts to air, soil, and water resources 

(groundwater). This section briefly discusses potential impacts from greenhouse gas (GHG) emissions 

and climate change. Currently, INL estimates its contribution of GHG emissions to be about 

100,000 metric tons annually. Those INL activities contributing to this value include purchased electricity 

(~65,000 Metric Ton CO2-equivalent), stationary combustion (gas boilers, non-emergency diesel 

generators) (~15,000 Metric Ton CO2-equivalent), and mobile combustion (car and bus fleet) 

(~10,000 Metric Ton CO2-equivalent). Project activities that would contribute to the GHG emissions 

include the use of light-duty vehicles, air transportation (fixed wing and helicopters), and portable 

generators. The intermittent use of ground and air transportation and use of generators during project 

activities (up to 12 exercises per year) is likely an insignificant portion of INL‘s total GHG emissions. 

4.2 Alternative 2 – No Action 

The no action alternative means that none of the actions described in Alternatives 1a or 1b would 

occur at any of the locations. DOE would have to turn to other locations across the complex to meet the 

purpose and need described in Section 1. Environmental impacts, as described in Section 4, would not 

occur on the INL from actions described in this document. However, as with Alternatives 1a or 1b, DOE 

would continue to mine the T-28 gravel pit, clean up the TAN/TSF, and use the South Training Range for 

other purposes. 
24 

4.3 Summary of Proposed Impacts 

Following is a summary of proposed impacts: Risk Assessment (air and water resources), Biological 

Resources, Cultural Resources, and Cumulative Impacts. 

Risk Assessment:

The sum of the atmospheric, surface, and groundwater models show the public dose would be about 

0.01% of the INL Administrative Control Level for the Public (see Table 3). These small doses would not 

produce any adverse impacts. In addition, the risk to workers would be managed and mitigated in 

accordance with the INL Radiation Protection Program. 

Biological Resources:

The proposed actions described in Alternative 1a would likely impact some wildlife species by 

removing sage-grouse and pygmy rabbit habitat and causing disruptive activities along T-28. In addition, 

the disruptive behavior would magnify the habitat fragmentation already caused by the road and its use. 

Those activities described in Alternative 1b would have no or minimal impact on sage-grouse and pygmy 

rabbits along T-28, and would likely not contribute to any habitat fragmentation. Proposed operational 

controls would lessen impacts to these resources for both Alternatives 1a and 1b. 

Cultural Resources:

The proposed action in Alternative 1a or 1b would cause minor direct and indirect impacts on the 

cultural resources and archaeological sites at the North Training Range (near the T-28 gravel pit); impacts 

at the South Training Range (near RWMC) are unlikely. To minimize potential impacts, project personnel 

would work with Cultural Resource personnel to complete required archaeological surveys, and locate 

areas along the south access road and around the T-28 gravel pit to place command posts and to avoid 

sensitive cultural resources. 

Cumulative Impacts:

Project activities have the potential to affect cultural and biological resources by their activities, 

which includes traveling T-road, removing vegetation and disturbing soil, flying over the sites, and other 

disruptive activities. However, from a cumulative impact perspective, the incremental amount is likely not 

significant. The North and South Range are within 1 to 2 miles of INL facilities (SMC, TAN, and 

RWMC), situated along T-roads (which are traveled by security and other site personnel), and make up a 

small percentage of the total area of INL. The RRTR (both North and South) would use about 900 acres 

out of 569,600 acres, or less than 0.2% of INL land. The primary training area in the North Training 

Range is an operating gravel pit. Considering the widely spread nature of INL facilities and that most of 

the site remains pristine, the cumulative impact of the training ranges is likely small. Cumulative impacts 

to cultural artifacts, sage-grouse, pygmy rabbits, and other resources is low. 

5.0 COORDINATION AND CONSULTATION 

DOE-ID consulted with several federal, state, county, and tribal governments, including the U. S. 

Army Corp of Engineers, the Idaho State Historic Preservation Office, the Advisory Council on Historic 

Preservation, and the Shoshone-Bannock Tribes. DOE-ID conducted separate notifications and briefings 

to the Idaho Governor‘s and Congressional Delegation Offices, Butte County; Idaho Commissioners; and 

the Department of Environmental Quality (INL Oversight Program). In addition, two separate tours were 

provided: one to U. S. Fish & Wildlife Service personnel by DOE-ID, and one to a representative of the 

State of Idaho DEQ by a BEA representative. The RRTR North Training Range was visited and project 

activities were discussed during each tour. 
25 

U. S. Army Corp of Engineers:

DOE contacted the U.S. Army Corp of Engineers, Idaho Falls, ID Regulatory Field Office, on June 

15, 2010, to discuss the proposed establishment of the Radiological Response Training Range and the use 

of the two  ̳training ranges‘ on the INL: North Training Range and South Training Range (see Figure 2). 

The potential activities would not be subject to Section 404 Clean Water Act (see glossary) permit 

requirements administered by the U.S. Army Corps of Engineers as they would not result in discharges of 

dredged or fill material into waters of the U. S.

Idaho State Historic Preservation Office, the Advisory Council on Historic Preservation, 

and the Shoshone-Bannock Tribes:

In 2004, DOE-ID entered into a programmatic agreement with the Idaho State Historic Preservation 

Office and the Advisory Council on Historic Preservation. The agreement legitimizes the INL Cultural 

Resource Management Plan (DOE-ID 2009), by which INL complies with Section 106 of the National 

Historic Preservation Act and its implementing regulations (36 CFR 800), as well as various other 

sections of the National Historic Preservation Act and cultural resource laws to meet the unique needs of 

the INL Site. DOE-ID‘s ―Agreement in Principle‖ with the Shoshone-Bannock Tribes ensures an active 

tribal role in cultural resource impact assessment and protection. INL would continue to comply with the 

National Historic Preservation Act, Section 106, through the INL Cultural Resource Management Plan, 

and the plan would be used to develop a strategy to protect cultural resources from adverse impact. A 

cultural resource protection plan would be developed for the RRTR project in consultation with the Idaho 

State Historic Preservation Office and Shoshone-Bannock Tribes. 

Shoshone-Bannock Tribal Briefing:

On July 7, 2010, the Department of Energy-Idaho Operations Office (DOE-ID) provided a detailed 

technical briefing on the Radiological Response Training Range (RRTR) project to the Fort Hall Business 

Council (FHBC) of the Shoshone-Bannock Tribes. This discussion talked about the scope of the activity, 

potential locations, and the need for this capability. It was discussed, and the FHBC recognized, that the 

Tribes' Cultural Resource personnel (Heritage Tribal Office) have worked with DOE-ID and BEA to 

assess impacts on cultural resources at the project sites. The land area for INL is within the ShoshoneBannock Tribes' ancestral and aboriginal homeland. Therefore, they proclaim a vested interest in all 

activities at INL. DOE-ID has negotiated a series of Agreements in Principle that acknowledge the Tribes' 

interests and connectivity to this area and recognizes the viability of their 1868 Fort Bridger Treaty as a 

law of the land that establishes their sovereignty. The FHBC recognized the critical nature of this and any 

future related projects that support National Defense and Homeland Security and serve to protect the 

United States of America. The FHBC provides a consensual blessing and wishes that their support be 

acknowledged because of their spiritual and ancestral connection to this land. They support the project 

and the use of the land for these purposes, and wish to be considered as a helping partner and have these 

interests expressed to those who would use the RRTR and be trained. This briefing with the Tribes did not 

constitute formal government-to-government consultation. 

6.0 REFERENCES 

10 CFR Part 835, ―Department of Energy Occupational Radiation Protection,‖ Code of Federal 

Regulations, Office of the Federal Register. 

10 CFR Part 1021, ―DOE NEPA Implementing Regulations,‖ Code of Federal Regulations, Office of the 

Federal Register. 

36 CFR 800, 2004, ―Protection of Historic Properties,‖ Code of Federal Regulations, Office of the 

Federal Register. 

40 CFR 61, ―National Emission Standards For Hazardous Air Pollutants‖, Code of Federal Regulations, 

Office of the Federal Register. 
26 

40 CFR Parts 1500-1508, ―CEQ Regulations for Implementing NEPA,‖ Code of Federal Regulations, 

Office of the Federal Register. 

43 CFR 10, 2010, ―Native American Graves Protection and Repatriation Regulations,‖ Code of Federal 

Regulations, Office of the Federal Register. 

7 USC § 2814, 2006, ―Management of Undesirable Plants on Federal Lands,‖ United States Code. 

16 USC § 661 et seq., 1960, ―Fish and Wildlife Coordination Act,‖ United States Code. 

16 USC § 668, 1940, ―Bald Eagle Protection Act,‖ United States Code. 

16 USC § 715-715s, 1918, ―Migratory Bird Treaty Act,‖ United States Code. 

16 USC § 1531 et seq., 1973, ―Endangered Species Act,‖ United States Code. 

31 USC § 1535, 2009, ―Economy Act of 1932,‖ United States Code. 

42 USC § 4321 et seq., 1970, ―National Environmental Policy Act of 1969,‖ United States Code. 

Anderson, J.E., K.T. Ruppel, J.M. Glennon, K.E. Holte, and R.C. Rope. 1996. Plant communities, 

ethnoecology, and flora of the Idaho National Engineering Laboratory. ESRF-005. Idaho Falls, 

111 pp. 

Blew, R.D., J.R. Hafla, J.C. Whiting, D.K. Halford, and R. Starck. 2010. Ecological Resources 

Assessment for the Radiological Response Test Range Environmental Assessment. Stoller-ESER 

Report No. 133. 26pp. 

Clark, Ian D., Fritz, Peter.,1997, Environmental Isotopes in Hydrogeology, Lewis Publishers, Boca 

Raton. 

DOE-ID, 2009, Idaho National Laboratory Cultural Resource Management Plan, DOE/ID-10997, Rev 3, 

U.S. Department of Energy Idaho Operations Office. 

DOE Order 450.1a, 2008, ―Environmental Protection Program.‖ U.S. Department of Energy. 

DOE Order 451.1b, 2006, ―National Environmental Policy Act Compliance Program.‖

DOE Order 5400.5, 1993, ―Radiological Control & Clearance Property, Change 2.‖

DOE. 2002. DOE Standard. A Graded Approach for Evaluating Radiation Doses to Aquatic and 

Terrestrial Biota. DOE-STD-1153-2002, July 2002, U.S. Department of Energy, Washington, D.C. 

20585 

DOE. 2004. RESRAD-BIOTA: A Tool for Implementing a Graded Approach to Biota Dose Evaluation. 

DOE/EH 0676, ISCORS Technical Report 2004-02, January 2004. 

ECAR 1109, 2010, Atmospheric, Groundwater, and Surface Exposure Doses from Radionuclides released 

from the KBr Training Exercise, July, 2010 

ECAR 334, 2008, Hazard Categorization of a Training Exercise to Detect Contamination in an Outdoor 

Environment, Engineering Calculations and Analysis Report, Idaho National Laboratory, 

August 25, 2008. 

Executive Order 11593, 1971, ―Protection and Enhancement of the Cultural Environment.‖

Executive Order 13112, 1999, ―Invasive Species,‖ Federal Register, Vol. 64, No. 25. 

ICRP. 2004. A Framework for Assessing the Impact of Ionising Radiation on Non-Human Species, ICRP 

Publication 91. 

INL Cultural Resource Management Office Project Files: BEA-08-26 ―Infiltration Basin Reuse.‖
27 

Miller, S.J., 1985, ―A Cultural Resources Inventory of the Perimeter Boundary, Grazing Boundary, and 

1984 Project Areas, Idaho National Engineering Laboratory, Southeastern Idaho,‖

EG&G C84-110380. 

Public Law 59-209, 1906, ―Antiquities Act of 1906,‖ as promulgated in 16 USC 431–433. 

Public Law 89-665, 1966, ―National Historic Preservation Act of 1966,‖ as amended, as promulgated in 

16 USC 470, et seq. 

Public Law 93-291, 1976, ―Archaeological and Historic Preservation Act of 1974,‖ as amended, as 

promulgated in 16 USC 469–469c. 

Public Law 96-95, ―Archaeological Resources Protection Act of 1979,‖ as amended, as promulgated in 

16 USC 470aa-mm. 

Public Law 107-296, 2002, ―Homeland Security Act of 2002.‖

Public Law 111-140, 2010, ―Nuclear Forensics and Attribution Act of 2010.‖

Rood, A. S., 2003, GWSCREEN: A Semi-Analytical Model for Assessment of the Groundwater Pathway 

from Surface or Buried Contamination: Theory and User's Manual Version 2.5, INEEL/EXT-98-

00750, Rev. 1b, Idaho National Engineering and Environmental Laboratory, April 2003 

Ross, J.W., B.L. Ringe, and W.G. Reed, 1986, ―Archaeological Surveys of Three INEL Gravel Pit 

Locations,‖ Swanson/Crabtree Anthropological Research Laboratory Reports of Investigations No. 

86-61, Idaho State University, Pocatello, Idaho. 

Shumar, M.L. and J.E. Anderson. 1986. Gradient analysis of vegetation dominated by two sub-species of 

big sagebrush. Journal of Range Management 39(2):156-160. 
28 

Appendix A: Public Comment and Response 

DOE-ID published the draft EA on August 4, 2010, making it available to the public and agencies for review 

and comment through September 3, 2010. In addition, DOE-ID sent out news releases and posted the draft EA on 

DOE-ID‘s website and sent out postcards to stakeholders, including federal and state agencies (e.g., U. S. Fish & 

Wildlife Service, Bureau of Land Management, Idaho Department of Fish and Game, and the sage-grouse local 

working groups). 

DOE-ID received six comment letters and/or emails: three from members of the public, two from government 

agencies, and one from the Shoshone Tribes. The following tables summarize the comments received on the draft 

EA and DOE-ID‘s response to those comments. 

Comments and Responses

Comments from Egon Lamprecht (Idaho Falls, Idaho) – Comment 1

Comment 1: ―I think the idea of a field training facility is a great (sic) for not only on site folks but those out in 

the world that could encounter a radiation emergency.‖

Response: Thank you for your comment. DOE agrees that this project is important to our nation‘s security.

Comment from Kevin L. Young (received before the start of the public comment period) – Comment 2

Comment 2: ―It's really good to see this concept is moving forward.‖

Response: Thank you for your comment.

Comments from Dr. Peter Rickards (Idaho Families for the Safest Energy) – Comments 3–9

Note: Since Dr. Rickards‘ comments were numbered and punctuated, they are  ̳reproduced‘ as received with  ̳bold‘ 

and  ̳underlined‘ emphasis.

Comment 3: ―1) The EA, on page 6 (or webpage 14 of 33) quietly announces that C-4 explosives can be used 

to disperse the radioactive KBr. Yet nowhere in the dose analysis details does this explosion appear analyzed. 

I FOIA‘d the documents of dose analysis referenced in the EA, ie, ECAR 1109 & 334. These documents speak only 

of spreading the KBr in a water sprayer. No explosions are mentioned to estimate the dust plume height nor 

width these C-4 explosions will produce. This plume from the explosions can leave INL easily. This analysis is 

essential to documenting the true environmental impacts that planned events, and accidents can expose the public 

to.‖

Response: This assumption is conservative because any initial dispersal of material will result in lower air 

concentrations and thereby lower doses to the public. This analysis can be done by utilizing a non-point source 

emission. However, the radiation dose would only decrease, or at the worst, remain the same from what has 

already been calculated. The dose analysis assumed a ground level release with no initial dispersion of the 

material from either the C-4 or water sprayer dispersal techniques; resulting in a maximum dose to the public.

Since considering the plume height and width in the analysis for maximum dose to the public would have 

potentially decreased the potential dose to the public, DOE chose to be conservative in its assumptions and 

concludes that these parameters are covered within the bounding analysis that was performed.

Comment 4: ―2) ECAR 334 (webp 3/7) states ―The area uses the infiltration pond that is a bermed area and 

provides a good ground level barrier to excessive winds. The training event period was selected in late August where 

winds typically do not exceed 8 mph historically.‖

 Certainly the August wildfires at INL had winds exceeding 8 MPH, and the bermed area did not deter that wind. 

While the EA mentions they won't test if the winds exceed 10 MPH, and will stop if that wind changes, once the 
29 

Comments from Dr. Peter Rickards (Idaho Families for the Safest Energy) – Comments 3–9

dirty bomb simulation test explosion has been detonated, it can not (sic) be retrieved if the unpredictable winds 

exceed 10 MPH.

 Analysis of a fetus and a pregnant women changing a tire on Rt 20 during a common inversion layer should be 

done for if she is caught in this plume that is emitting gamma x-rays shortly after explosion, ie, external air bath 

dose, inhalation, and ingestion of undissolved KBr salt particles, from the powder form planned for dispersion on 

p 6 (wp 14/33). Only dilute dissolved single atoms of KBr are analyzed, hiding the larger dose from larger 

particles.

 One curie release per explosion is a lot of gamma emissions from these very short lived radionuclides, making 

the exposure much higher than the diversionary analysis done of someone living on the site after years of testing 

these short-lived radionuclides.

The EA claims to do an analysis of someone directly in the plume all year long, but the details shared only 

analyze other scenarios‖

Response: The analysis considered that all activated KBr is dispersed and transported into the atmosphere, 

and that all of the activity can be inhaled. In reality, some of the KBr will deposit on the ground and some will 

be attached to particles too large to inhale. The conservative (and bounding scenario) assumes that exercises 

take place every 8 hours for 365 days/yr, and that a person is located at the site boundary for 365 days/yr. This 

scenario overestimates the potential doses because only twelve exercises per year will take place. Nevertheless, 

this scenario was run to bound any single release where a person would be located in the path of the plume. 

Doses were still well below regulatory limits.

Comment 5: ―3) The FOIA’d ECAR 1109 specifically avoiding listing the separate inhalation doses, and the 

external air bath doses. While this is claimed to be a ―conservative‖ estimate that greatly exceeds any real dose, 

note on page 10 they eliminate the high dose of the one curie short lived radionuclides, and bury the remaining 

2 isotopes 15 cm deep in the soil. The Surface Pathway analysis of growing food there AFTER the tests conclude is 

absurdly inappropriate, and an intentional diversion, for the short-lived radionuclides dispersed.‖

Response: The dose analysis for the short-lived radionuclides are in the atmospheric dose assessment. The 

atmospheric doses include submersion and inhalation doses. The objective of the surface pathway assessment is 

to assess impacts from long-lived radionuclides, which are assumed to be on the surface, but are later mixed to a 

depth of 15-cm to assess food-chain uptake because the soil must be tilled in order to grow crops.

Comment 6: ―4) ECAR 334 dismisses the need for criticality analysis but only details the uranium sealed 

source used. However, the EA quietly admits the staff may chose (sic) to use plutonium during the testing. No 

plutonium isotope is specified either. No accidental misplacement of pu and the C-4 is analyzed. No disgruntled 

employee scenario is analyzed. INL is NOT immune from disgruntled employees, starting with the SL-1 reactor 

criticality‘s rumored lover‘s triangle gone awry. In modern times, despite psychological screening, an armed INL 

―Security‖ guard barricaded themselves in a NO-GO area, and another employee intentionally put a plutonium laden 

HEPA filter in an unsecured garbage can hoping to expose unprotected workers.

 These are real potential environmental impacts that need to be honestly analized (sic). This is not a windmill INL 

is testing. They are handing employees C-4 and plutonium, and both accidents and intentional sabatoge (sic) require 

analysis.‖

Response: The quantity of uranium or Pu used in the irradiated source material is less than 1 gram U-235 

equivalent, several orders of magnitude less than the minimum critical mass for Uranium and does not warrant a 

criticality analysis. Larger quantities of U or Pu will be packaged in special form containers or contained in 

DOT shipping containers approved for these kinds and quantities of radioactive material.

The INL implements stringent source control requirements. These source control requirements have a specific 

process for procurement, registration, labeling, transfer, storage, movement, use, and a semi-annual inventory 

and accountability process. Each accountable sealed radioactive source is identified by a Manufacturer‘s ID 

number and INL unique identification number. These source control requirements were developed to meet the 

requirements of Part 835 of the Code of Federal Regulations. They are also implemented in accordance with the 
30 

Comments from Dr. Peter Rickards (Idaho Families for the Safest Energy) – Comments 3–9

INL Radiological Controls Manual and detailed procedure documents. The probability of losing or misplacing a 

source is very low. In addition, the EA states ―sealed and contained sources will be removed from the exercise 

area on a daily basis and before the training event has concluded,‖ thus making misplacing of the source highly 

unlikely (see Section 2.3, page 8,  ̳Typical Training Exercise‘). The only radioactive material that will be 

exposed to explosive or other dispersal actions will be the irradiated KBr. Sealed sources will not be part of or

affected by dispersal actions.

All explosives stored on site, including C-4, are protected in magazines that are alarmed or patrolled or both by 

INL security personnel. In addition, the use and movement of explosives is monitored by security across the 

INL Site with appropriate safeguards in place depending on the type and amount of explosives to protect the 

misuse of the explosive. These administrative controls, including the precautions taken by INL Security, render 

a scenario of misplacing or misusing explosives an extremely low probability and not a reasonable scenario to

analyze.

Comment 7: ―5) The ECAR 334 (p5/7) claims to have done soil samples at INL, and claims it only found 

Cesium-137. It is impossible not to have found plutonium in the soil at INL, and other radionuclides! This is 

an outright lie. The plutonium already in the soil needs specific analysis. Any pu-238 particle made airborne by 

the explosions can greatly exceed the legal limit of 10 mrem exposure. I paste below the DOE worker dose paper by 

Dr Scott, which is peer-reviewed and published. While Dr Scott is very pro-nuclear, his paper admits that a worker 

who inhales 3 particles of pu-238 will exceed his 5,000 mrem annual limit, meaning if a citizen inhales one pu-238 

particle, they exceed over 1,700 mrem. This all calls for an honest EIS!‖

Response: Soil samples for the project were analyzed using gamma spectroscopy because the radionuclides 

in the KBr experiment are gamma emitters. Gamma spectroscopy would not detect Pu-238 or Pu-239. However, 

historical sampling at the INL has shown Pu-238 and Pu-239 to be present in INL soils. The commenter is 

correct in that the dose from inhalation of a few particles of Pu-238 can exceed 5 rem, as confirmed by our own 

calculations and those of Scott and Fencl (1999 Rad Protection Dosimetry 83(3) 221-232). However, the

commenter does not recognize the main point of the Scott and Fencl paper; that is, with the inhalation of such 

particles, the probability of inhalation needs to be accounted for because very few discrete particles would be 

present in the air. Additionally, the paper discussed plutonium aerosols in the workplace and not an 

environmental setting.

To receive the dose discussed in the Scott and Fencl paper, one would have to inhale a 10 μm aerodynamic 

equivalent diameter (AED) particle of pure Pu-238 in the oxide form. The AED is defined as:

where dp is the physical diameter of the particle (μm) and ρu = the density of the particle divided by a unit 

density of 1 g/cm3. The density of a plutonium oxide aerosol particle reported by Scott and Fencl was 10 g/cm3. 

Therefore, the physical diameter of the particle would be:

Assuming a sphere, the mass of this particle would be:

The specific activity for Pu-238 is 17.119 Ci/g. Therefore, the activity of one 10 μm AED Pu-238 particle is 

17.119 Ci/g × 1.65 × 10–10 g = 2.82 × 10–9 Ci or 2,828 pCi.

Rood et al. (1996) provides summary statistics and upper confidence intervals for Pu-238 concentrations on the 

INL site. The mean concentration from Table 23 was 0.0014 pCi/g with a minimum of less than zero and a 
31 

Comments from Dr. Peter Rickards (Idaho Families for the Safest Energy) – Comments 3–9

maximum of 0.0056 pCi/g. The upper 95% and 99% tolerance limits with 95% confidence for composite and 

grab samples was 0.0061 pCi/g for composite samples and 0.012 pCi/g for grab samples. Assuming our source 

term is composed of these Pu-238 particles then the mass of soil that would hold one of these particles would 

be:

2,828 pCi/0.0061 pCi/g = 463.7 kg ~ 1⁄2 ton.

Therefore, about 1⁄2 ton of soil would have to be ejected in order to get one particle of plutonium-238. Assuming 

only about 10% of this soil mass can be inhaled and remain airborne long enough for inhalation to occur, then 

the mass fraction of Pu-238 in air is 1.65×10–10 g / 4.637×104g = 3.55 × 10–15. Therefore, it is very unlikely that 

even if a particle was emitted a person would inhale that single particle. Furthermore, if, the soil contained 

discrete particles of Pu-238, then the sampling would show much larger variance than indicated by the results in 

Rood et al. (1996). That is, the difference between the mean and maximum concentration would be much 

greater than what was observed.

The dose from plutonium isotopes emitted from soil from detonation of C-4 can be conservatively evaluated by:

where D = dose (mrem), Cs = soil concentration (pCi/g), MLF = mass loading factor (g/m3), BR = breathing rate 

(m3/hr), and DCF = dose conversion factor (mrem/pCi). For this exercise, the model conservatively assumes the 

dust remains airborne for 1 hour, a person is present at the site for 1 hour, and breathes 1 m3/hr (based on 

RESRAD default breathing rate of 8400 m3/yr). Mean soil concentrations for Pu-239 and Pu-238 were taken 

from Table 23 in Rood et al. (1996). The mass loading factor was conservatively assumed to be 100 times the 

RESRAD default value of 1 × 10–4g/m3(i.e., 0.01 g/m3or 10,000 μg/m3. Visibility would be impaired at dust 

concentrations this high. This value is not realistic and was conservatively selected to be an over estimate of 

actual conditions one may experience. Dose conversion factors were taken from Federal Guidance Report 11 

(EPA-520/1-88-020, September, 1988). The dose calculation is for a person in the vicinity of the exercise. 

Doses for members of the public would be orders of magnitude lower because of air dispersion. The calculated

Effective Dose Equivalent (EDE) (see Table 1) is well below 0.001 mrem and therefore should not be a concern 

for a worker or member of the public.

Table 1. Dose calculations for Pu-239 and Pu-238 in soil ejected during an exercise.

Comment 8: ―... I want to add we need analysis of a pregnant women & her fetus who is taking a tour of INL 

inhaling and ingesting the particle size of the powder KBr et al, and her dose with all the aforementioned scenarios. 

Thank you...Peter‖

Response: See response (Comment #4).

Comment 9: ―... meant to say the full EIS is required, and if explosion of radionuclides is reallly deemed 

SOOOOO important it must be done, a comparative analysis should be done for moving this open air experiment to 

Nevada Test Site, and hopefully, not only from NTS when the wind is blowing toward idaho (sic), as Idaho 

downwinders (sic) regret from all the previous explosions aimed at the ―low population use‖ people of Idaho, the 

greatest State in the Greatest nation...Peter‖

Radionuclide

Soil Conc. 

(pCi/g)

Air Conc. 

(pCi/m3)

1-hr intake 

(uCi)

DCF 

(mrem/uCi) EDE (mrem)

Pu-238 0.0014 0.000014 1.16E-11 3.92E+05 4.57E-06

Pu-239 0.024 0.00024 2.0E-10 3.08E+05 6.16E-05
32 

Comments from Dr. Peter Rickards (Idaho Families for the Safest Energy) – Comments 3–9

Response: U. S, Department of Energy (DOE) (10 CFR 1021.300-322) requirements state that ―DOE may 

prepare an EA on any action at any time in order to assist agency planning and decision making.‖ DOE 

prepared this EA to help answer questions on environmental impacts and significance related to the use of 

radionuclides and disturbance of biological and cultural resources. Based on the results of the EA, and after 

review of this and other comments, DOE determined that the project would not result in significant 

environmental impacts. DOE concluded that preparation of an Environmental Impact Statement (EIS) is not 

required; therefore, we instead prepared a Finding of No Significant Impact (FONSI) [(10 CFR 

1021.400(d)(1)(2)]. The FONSI is in the front of this EA.

DOE considered other DOE facilities, including the Nevada Test Site, but found that other sites did not meet the 

program expectations of conducting and supporting the training requirements that be accomplished at INL. The 

INL was the only site that met all of the site selection criteria (see Section 2.2, page 4,  ̳Site Selection Criteria‘). 

Specifically, the Nevada Test Site did not meet several criteria, such as (1) proximity to facility that produces a 

diverse inventory of radionuclides, including the dispersed radioactive material, (2) previous experience with 

KBr irradiation and dispersal, and (3) lack of expertise in National Technical Nuclear Forensics exercise 

planning or training.

Susan Burke, INL Coordinator, Department of Environmental Quality (State of Idaho) – Comments 10–15

Comment 10: ―Please note that any that any (sic) activities at a CERCLA site will require completion of a Notice 

of Soil Disturbance.‖

Response: The proposed North Range is adjacent to a CERCLA site. The site is under institutional controls 

and entry is restricted. The proposed RRTR project does not intend to enter, use, or otherwise disturb the 

CERCLA site. Project personnel will conduct briefings as an administrative control to those involved in training 

exercises on the location of CERCLA sites and the requirement to not enter those restricted sites.

Comment 11: ―Under Table 1, Activities to Prepare Sites, it is unclear what amount of KBr will be at a range at 

any one time. The EA states that DOE will use ―about 600 gallons/test water to apply the KBr‖. Does that mean 

there will be 600 gallons of KBr present at the exercise? Is there secondary containment for the KBr mixed with test 

water? Will the KBr be transported on public highways in liquid form?‖

Response: The total amount of KBr at the range can be up to 500 grams, containing a total activity of 1 Ci. 

The KBr (up to 500 grams) will be mixed with up to 600 gallons of water to allow the material to be dispersed 

appropriately. There is no secondary container; the sprayer is loaded in the test site and is the primary container. 

No radioactive liquids are shipped over the road.

Comment 12 ―Please clarify how often wind speeds will be measured and monitored. Also clarify where the wind 

speeds will be measures, i.e. at ground level or at some predetermined height.‖

Response: Project personnel will use a hand-held anemometer, such as the Speedtech Windmate 300. These 

hand-held instruments have an accuracy within three percent. The height for wind speeds will be at 5 feet from 

ground level at the point of release. Wind speed and direction will be recorded for each release. They will only 

be monitored at the time of release, or for spraying applications for the duration of the spraying period.

Changes to EA: See changes to Section 2.3, Table 1, under Operational Activities, page 6.

Comment 13: ―Under Table 2, Releases of radionuclides to the environment, the EA states that periodic biota does 

(sic) assessment will be performed at either the North or South Training Range. It is not clear why this assessment 

would not be performed at both the North and South Training Range. Also, please clarify where specific information 

on the biota assessments (methodologies, types of measurements, list of species, etc.) can be found.‖
33 

Susan Burke, INL Coordinator, Department of Environmental Quality (State of Idaho) – Comments 10–15

Response: The INL will conduct biological assessments at both the North and South Training Range.

Changes to EA: See changes to Section 2.5, Table 2, page 12 and Section 4.1.2.1, page 19, Radiological 

Assessment and Section 6.0, page 25, References DOE 2002; DOE 2004; and !CRP 2004.

Comment 14: The EA states that contaminated equipment, temporary structures, and clothing will be stored until 

radionuclides are decayed to levels below detection but it does not address where the items will be stored ... Will 

the items be shipped as low-level radioactive waste to some location?‖

Response: Large contaminated equipment, structures will remain within the Test range until the INL 

Radiological Control personnel clears them for release. Contaminated clothing will be stored in radiation bags 

in cargo containers at the Test Range until disposed as Low level waste (MFC). 

Changes to EA: See changes to Section 2.3, Table 1, under Training Exercise Activities, page 7.

Comment 15: ―The EA should identify any physical controls and their effects. For example if fencing will be used, 

the impact on soils and wildlife should be addressed. It is also unclear how control will be established around a 

working gravel pit.‖

Response: Project personnel will use signs posted on sawhorse type mounts or fence posts at the entrances to 

the training ranges and other access points to the radiologically controlled areas. The entrance areas are already 

highly disturbed with gates, roads, ditches, and so forth. Project personnel will control access at the North 

Training Range by locking the gate at the entrance to the radiation areas and placing radiation/contamination 

boundary signs. In addition, project personnel will notify INL Security for periodic patrols of the area.

Changes to EA: See changes to Section 2.5, Table 2, page 12.

Christine B. Reichgott, Manager, Environmental Review and Sediment Management Unit,

U. S. Environmental Protection Agency, Region 10 – Comments 16–20

Comment 16: ―The DEA does not currently quantify iimpacts (sic) to these habitat and wildlife resources

[sage-grouse and pygmy rabbit and their habitat] making it difficult to clearly distinguish between the proposed

sub-alternatives. Under NEPA, the EA document should contain supporting data and references that convincingly 

show the proposed action would not significantly affect environmental and other resources within and around the 

analysis area.‖

Response: DOE believes the information given in the draft EA gives sufficient information to distinguish 

between sub-alternatives and convincingly support the conclusion that neither sub-alternative would result in 

significant environmental impacts. The draft EA does quantify and summarizes current survey data gathered 

specifically for this project (see Section 4.1.2, 4.1.2.1 and 4.1.2.2, pages 17-21) and the referenced document 

Blew, et al., 2010, discusses survey results over the INL Site. The draft EA specifically mentions the loss of 2-

100 x 100 foot sagebrush areas north of the gravel pit (Alternative 1a), and no loss of habitat south of the gravel 

pit (Alternative 1b).

The data contained in the draft EA (see Sections 4.1.2, 4.1.2.1, & 4.1.2.2, pages 17-21) gives sufficient 

information to state that neither sub-alternative would result in a significant loss to sage grouse or pygmy rabbit 

populations or their habitat on the INL (see above paragraph). The loss of 2-100 x 100 foot areas of habitat due 

to sub-alternative 1a is minimal in context to the overall populations and habitat on the INL and within the 

region. In addition, direct impacts to sage grouse, pygmy rabbits and cultural resources would be unlikely 

because the EA requires surveys for nesting bird, pygmy rabbits, and cultural resource surveys before disturbing 

areas to place command centers (see Section 2.5, Table 2, page 12).

Comment 17: Given the usage of the project area by sage-grouse, pygmy rabbits and other sensitive wildlife 

species (p. 18) and lack of current survey data for the species, it is important that DOE work with the U. S. Fish and 
34 

Christine B. Reichgott, Manager, Environmental Review and Sediment Management Unit,

U. S. Environmental Protection Agency, Region 10 – Comments 16–20

Wildlife Service (USFWS) and the Idaho Department of Fish and Game (IDFG) to determine the level of risk to the 

species and identify effective ways to reduce the risk.‖

Response: The draft EA does summarize current survey data gathered specifically for this project (see 

Section 4.1.2, page 17). In addition, the referenced document, Blew, R.D. et al., 2010, discusses survey data for 

sage-grouse and pygmy rabbits from across the INL.

As described in Section 5 of the EA, DOE notified the U. S. Fish and Wildlife Service and the Idaho 

Department of Fish and Game through the public notification of all stakeholders. In addition, the U. S. Fish and 

Wildlife Service and DOE visited the North Training Range and discussed project activities. DOE also sent a 

personal invitation for the Sage-Grouse local working group, of which the Idaho Department of Fish and Game 

is a member to review and comment on the draft EA (see lead-in paragraph to this Appendix). In addition to the 

stakeholder notifications, DOE and the U.S. Fish and Wildlife Service are working on a Candidate Conservation 

Agreement to help protect and reduce risk to sage-grouse and pygmy rabbits and their habitat.

Comment 18: ―EPA also encourages DOE to select the Sub-alternative 1b and South Training Range for 

implementation of the project because these options would result in the least impacts to biological resources‖

Response: DOE also recognizes the difference in potential impact between the two sub-alternatives. 

However, neither alternative represents an adverse or significant impact on cultural or biological resources 

when considering the operational controls placed on project activities.

Comment 19: ―The final EA should evaluate cumulative effects consistent with the EPA guidance mentioned 

above.‖

Response: DOE concurs and added additional information in the EA to address (1) those resources that may 

be affected by cumulative impacts; (2) their geographic boundaries, (3) past, present, and reasonable 

foreseeable activities; (4) baseline conditions, and (5) thresholds.

Changes to EA: See Section 4.1.2.1 Alternative 1a  ̳Maximizing Project Flexibility‘ under  ̳Cumulative 

Impacts‘ on page 20.

Comment 20: ―We recommend expanding public involvement to other potentially interested and affected entities 

such as IDFG and private citizens. The final EA should then include a summary of issues raised by these entities 

about the project, and a discussion on how the issues will be resolved.‖

Response: DOE believes there was sufficient involvement with public entities and the public through briefings, 

tours, and stakeholder notifications. As described in Comment #17, the U. S. Fish and Wildlife Service, Idaho 

Department of Fish and Game, and the Sage-Grouse Local Working group, as well as other public agencies 

received copies of the EA for comment. In addition, DOE gave briefings to the Idaho Department of 

Environmental Quality, the Army Corps of Engineers, and the Shoshone-Bannock Tribes. DOE received 

comments from Idaho DEQ and the Tribes (See Section 5 of the EA). The FWS and Idaho DEQ took the 

opportunity to tour the parts of the RRTR locations.
35 

Mr. Willie Preacher, Shoshone-Bannock Tribal/DOE Director & Ms. Christina Cutler, Shoshone-Bannock 

Tribal DOE Environmental Specialist – Comments 21–28

Comment 21: ―... we want to reiterate the utmost protection of the environment (flora, fauna, and the aquifer), the 

safety of training range personnel, INL workers, or others that may be impacts by this training range. Tribes 

sometimes utilize some of the areas on the INL and the concern for contamination outside of the training range may 

impact them.‖

Response: DOE will take the utmost precautions when conducting training exercises to protect the 

environment, the public, and the worker. The EA describes project controls that project personnel will follow to 

protect resources and people. Appropriate notifications and barriers will make individuals coming on site aware 

of ongoing training exercises and contamination areas.

Also see response to Comment #15.

Comment 22: Is there a ―possibility [of the Tribes] taking some baseline soil samples and analyze for background 

contamination and do so periodically on or near the training range.‖

Response: Yes, the Tribes would have the opportunity to conduct co-sampling activities at the RRTR 

Training Ranges pursuant to the Agreement in Principle and as provided by the Cooperative Agreement. Tribal 

co-sampling would occur as part of INL‘s monitoring and sampling program in support of the RRTR to help 

verify data and maintain quality assurance. DOE will provide sufficient advance notice of opportunities for 

Tribal representatives to participate in co-sampling efforts at the range, in conjunction with project sampling 

activities for short and long-lived radionuclides.

Comment 23: The Tribes would also like to have a periodic update on the progress of the training range and the 

results and how this will assist in the safety of the United States national security.‖

Response: DOE appreciates the Tribes interest in knowing that the RRTR is being effectively used to further 

our national security interests. DOE will provide updates on the use of the RRTR upon request in coordination 

with the DOE Tribal Liaison as appropriate opportunities and the level of use warrant.

Comment 24: ―After the training range‘s mission is complete what will be done to ―cleanup‖ this area and is there 

a plan [to] restore the area to its original state back prior to the development of the training range.‖

Response: Before using the range(s), DOE‘s M&O Contractor will sample the soil located within the range 

as well as downwind from the range(s). When use of the ranges has ceased, DOE will again sample soils, 

analyzing for short- and long-lived radionuclides. Based on the small amounts of material released and the short 

half-lives of most of the material, it is expected the ranges will be released for unrestricted use. In other words, 

it is expected that the concentration of radioactive material will be very similar to what was present before 

testing. No remediation or Long Term Stewardship is anticipated.

Comment 25: ―Will there be a need for a long term stewardship plan for this area?‖

Response: See response to Comment #24.

Comment 26: ―Will the Tribes Emergency Response personnel get to participate in the training activities?‖

Response: DOE appreciates the Tribes interest in having their emergency response personnel participate in 

training activities at the RRTR. Training activities will be uniquely tailored to satisfy sponsor requirements. It is

envisioned that some activities will provide opportunity for joint training with cooperating organizations. In 

these cases, DOE will communicate the opportunity and coordinate that participation through the DOE Tribal 

Liaison.
36 

Mr. Willie Preacher, Shoshone-Bannock Tribal/DOE Director & Ms. Christina Cutler, Shoshone-Bannock 

Tribal DOE Environmental Specialist – Comments 21–28

Comment 27: ―Can the Tribes conduct multimedia environmental sampling in this area?

Response: Consistent with the response to Comment 22 the Tribes would be allowed to co-sample in 

conjunction with environmental sampling conducted in support of the RRTR. In addition to soil samples, INL 

will periodically conduct biological assessments (see response to Comment 13) for which the Tribes would be 

welcome to conduct co-sampling activities. As analyzed in the EA there is no potential for the activity to 

impact water resources as a result no additional environmental sampling will be performed.

Comment 28: ―What is the agencies (sic) preferred alternative and why isn‘t there a section on this in the draft 

handout from August 2010?‖

Response: The  ̳Proposed Action‖ may be the same, but not necessarily the agencies‘  ̳Preferred Alternative‘. 

Because DOE‘s intent was to determine if the proposed action had the potential for significant environmental 

impact and either Alternative 1a or 1b would meet the purpose and need. DOE believed it was not necessary to 

declare either option as the  ̳Preferred Alternative‘. DOE believes that while Alternative 1b may be the 

 ̳Environmental Preferred‘ alternative, both alternatives can achieve the purpose and need without significant 

impacts to natural, cultural, or biological resources or create significant health risks to a member of the public or 

worker.