DOE/EA-1308

ENVIRONMENTAL ASSESSMENT

FOR THE

OFFSITE TRANSPORTATION OF CERTAIN

LOW-LEVEL AND MIXED RADIOACTIVE

WASTE FROM THE SAVANNAH RIVER SITE

FOR TREATMENT AND DISPOSAL AT

COMMERCIAL AND GOVERNMENT

FACILITIES

FEBRUARY 2001

U. S. DEPARTMENT OF ENERGY

SAVANNAH RIVER OPERATIONS OFFICE

SAVANNAH RIVER SITE
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TABLE OF CONTENTS

Page

1.0 INTRODUCTION 1

1.1 Background 1

1.2 Purpose and Need for Action 6

2.0 PROPOSED ACTION AND ALTERNATIVES 6

2.1 Proposed Action 6

2.2 Alternatives to the Proposed Action 11

2.2.1 No Action, Continue to Store These Waste Forms

at SRS 11

2.2.2 Construct and Operate Onsite Treatment and

Disposal Facilities 11

3.0 ENVIRONMENTAL CONSEQUENCES OF THE

PROPOSED ACTION AND ALTERNATIVES 12

3.1 Onsite Loading Operations 12

3.2 Transportation Impacts 12

3.2.1 Analyzed Scenarios 12

3.2.2 Assumptions 13

3.2.3 Radiological Consequences 14

3.2.4 Non-radiological Transportation Accidents 30

3.2.5 Environmental Justice 30

3.2.6 Conclusion 31

3.3 Waste Processing Centers Operations 31

3.4 Environmental Consequences of the Alternatives 31

3.5 Cumulative Impacts 32

4.0 REGULATORY AND PERMITTING PROVISIONS

CONSIDERED 32

4.1 National Environmental Policy Act of 1969, as

amended (42 USC 4321 et seq.) 33

4.2 Waste Shipment Regulations 33

4.3 Occupational Safety and Health Act of 1970, as

amended (29 USC 651 et seq.) 33

5.0 AGENCIES AND PERSONS CONSULTED 33

6.0 REFERENCES 34

APPENDIX A - Glossary

APPENDIX B – Response to Public Comments
iv

LIST OF TABLES

 Page

Table 1-1. Low-level radioactive waste (LLW) and mixed low-level

 radioactive waste (MLLW) forms proposed for

 transportation to offsite commercial and Government

 treatment and disposal facilities. 3

Table 2-1. Listing of the offsite waste processing centers considered

 in this EA. 8

Table 3-1. Isotopic composition for the five cases (Hang 2000,

 Hang and Thoman 2000, Thoman 2000). 14

Table 3-2. Transport information for each case. 15

Table 3-3. Routing parameters for offsite SRS solid waste truck

 shipments. 16

Table 3-4. Routing parameters for offsite SRS solid waste rail

 shipments. 17

Table 3-5. RADTRAN input data for truck and rail shipments. 18

Table 3-6. Radiation dose field ratios for truck and rail waste forms. 19

Table 3-7. Incident-free radiological consequences (Hang and

 O’Kula 2000, WSMS 2000). 20

Table 3-8. Sum of accident radiological consequences (Hang and

 O’Kula 2000, WSMS 2000). 22

Table 3-9. Number of potential latent cancer fatalities for incident-free

 and accident transportation (Hang and O’Kula 2000, WSMS

 2000). 24

Table 3-10. Results of volumetric dilution assessment for an acute

 release of Pu239 into surface water streams (Jannik 2001). 26

Table 3-11. Expected accident levels for the designated truck travel

 routes (O’Kula 2000, WSMS 2000). 27

Table 3-12. Expected accident levels for the designated rail travel

 routes (O’Kula 2000). 29
v

LIST OF FIGURES

 Page

Figure 1-1. Location of the Savannah River Site (SRS), South Carolina. 2

Figure 2-1. National map showing the locations of the Savannah River

Site (SRS) and the six destinations being considered within

the proposed action of this EA. The rail end at Pocatello,

Idaho, is also depicted. 9
vi

LIST OF ABBREVIATIONS/ACRONYMS

The following is an alphabetized list of the abbreviations and acronyms found

within the text of this document:

CFR - Code of Federal Regulations

cfs - cubic feet per second

Ci - curie (a unit of measure of radioactivity)

CIF - Consolidated Incineration Facility

cm - centimeter

DC - District of Columbia

DOE - U. S. Department of Energy

DOT - U. S. Department of Transportation

dpm - disintegrations per minute

EA - environmental assessment

EDE - effective dose equivalent

EH - Environment, Safety, and Health

EIS - environmental impact statement

ER - Environmental Restoration

FRA - Federal Railroad Administration

ft - feet

g - gram

HAZMAT - Hazardous Materials Transportation Act

HIGHWAY 3.4 - computerized road/highway routing model

HNUS - Halliburton NUS Corporation

ID - Idaho

INTERLINE - computerized railroad routing model

LLC - Limited Liability Corporation

LCF - Latent Cancer Fatality

LDR - Land Disposal Requirement

LLW - low-level radioactive waste

LSA - Low Specific Activity

m - meter

MLLW - mixed low-level radioactive waste

mrem - millirem, i.e., 1/1000 roentgen equivalent man

mSv - millisievert

N/A - Not Applicable

nCi - nanocurie

NEPA - National Environmental Policy Act

NM - New Mexico

NRC - U. S. Nuclear Regulatory Commission

NV - Nevada

OSHA - Occupational, Health and Safety Administration

PCB - Polychlorinated biphenyl
vii

LIST OF ABBREVIATIONS/ACRONYMS (continued)

Pu239 - Plutonium-239

QA/QC - Quality Assurance/Quality Control

rad - radiation absorbed dose

RADTRAN 4 - computerized model used to calculate radiological impacts

resulting from transportation

RCRA - Resource Conservation and Recovery Act

rem - Unit of dose equivalent of radiation

ROD - Record of Decision

SC - South Carolina

SCDHEC - South Carolina Department of Health and Environmental

Control

SR - Savannah River Operations Office

SRS - Savannah River Site

SRWMEIS - Final EIS, Savannah River Site, Waste Management

TEPP - Transportation Emergency Preparedness Program

TN - Tennessee

TR - Technical Report

TSCA - Toxic Substance Control Act

U235 - Uranium-235

U236 - Uranium-236

USC - United States Code

UT - Utah

WA - Washington

WCS - Waste Control Specialists

WMPEIS - Final Programmatic EIS for Managing Treatment, Storage

and Disposal of Radioactive and Hazardous Waste

WSMS - Westinghouse Safety Management Solutions

WSRC - Westinghouse Savannah River Company

yr - year
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1

1.0 INTRODUCTION

The U. S. Department of Energy (DOE) prepared this environmental assessment (EA) to

analyze the potential environmental impacts of the proposed offsite transportation of

certain low-level radioactive waste (LLW) and mixed (i.e., hazardous and radioactive)

low-level radioactive waste (MLLW) from the Savannah River Site (SRS), located near

Aiken, South Carolina (Figure 1-1). DOE needs to take action because treatment and

disposal capabilities for these wastes do not exist at the site and/or it is more beneficial to

DOE to dispose of the waste at another location. DOE proposes to transport five forms of

LLW or MLLW (Table 1-1) to offsite commercial and Government facilities for

treatment and/or final disposal.

This document was prepared in compliance with the National Environmental Policy Act

(NEPA) of 1969, as amended; the requirements of the Council on Environmental Quality

Regulations for Implementing NEPA (40 CFR 1500-1508); and the DOE Regulations for

Implementing NEPA (10 CFR 1021). NEPA requires the assessment of environmental

consequences of Federal actions that may affect the quality of the human environment.

Based on the potential for impacts described herein, DOE will either publish a Finding of

No Significant Impact or prepare an environmental impact statement (EIS).

1.1 Background

At SRS, operations, waste management, environmental restoration, and decontamination

and decommissioning activities generate a variety of LLW and MLLW streams each year.

By definition, LLW is radioactive waste that is not classified as high-level waste,

transuranic waste, or spent nuclear fuel, and does not contain waste designated as

hazardous by either the Resource Conservation and Recovery Act (RCRA) (42 USC 6901

et seq.) or the Toxic Substances Control Act (TSCA) (40 CFR 116 et seq.). LLW

management is subject to the provisions of the Atomic Energy Act (42 USC 2011 et seq.),

DOE Order 435.1 (Radioactive Waste Management), and the accompanying DOE manual

(DOE 1999b). LLW is categorized as either contact-handled (i.e., external surface dose

rate does not exceed 200 millirem per hour) or remote-handled (i.e., external surface dose

rate exceeds 200 millirem per hour), and as alpha or nonalpha on the basis of the waste

forms and levels of radioactivity present.

Most LLW consists of relatively large volumes of waste materials contaminated with

small amounts of radionuclides, such as contaminated equipment, protective clothing,

paper, rags, packaging material, and solidified sludges. Most LLW contains short-lived

radionuclides and generally can be handled without shielding or remote handling

equipment.

MLLW contains both hazardous waste subject to regulation under RCRA and LLW

subject to regulations under the Atomic Energy Act. MLLW includes such materials as

tritiated mercury, tritiated oil contaminated with mercury, other mercury-contaminated

materials, radioactively contaminated solvents, radioactively contaminated



5

polychlorinated biphenyls (PCBs), radioactively contaminated lead shielding, and

equipment from the tritium facilities in H Area (DOE 1995a, 1997a).

The proposed management of the five waste forms included in this EA (Table 1-1) was

previously addressed in two different EISs prepared and issued by DOE: the Final EIS,

Savannah River Site, Waste Management, DOE/EIS-0217 (SRWMEIS) (DOE 1995a),

and the Final Programmatic EIS for Managing Treatment, Storage and Disposal of

Radioactive and Hazardous Waste, DOE/EIS-0200-F (WMPEIS) (DOE 1997a).

In the SRWMEIS, DOE’s preferred alternative for managing these waste forms was

through either shallow land or RCRA-licensed disposal at SRS. In addition, either onsite

or offsite treatment preceded disposal for some specific wastes in four of the five general

waste forms. However, treatment residuals were to be returned to SRS for onsite storage

or disposal. DOE decided to implement this option and issued a Record of Decision

(ROD) on October 30, 1995 (DOE 1995b).

In the WMPEIS, the five waste forms in this EA were encompassed in the two broad

waste types of LLW and MLLW for evaluation. DOE's preferred alternative consisted of

minimum treatment of LLW although each site may perform additional treatment if cost

effective. The preferred alternative for disposal of LLW was to continue to the extent

practicable onsite disposal as well as selection of Hanford Site and Nevada Test Site as

regional disposal locations. DOE's preferred alternative for MLLW treatment consisted

of onsite and regional treatment at Hanford Site, Idaho National Engineering and

Environmental Laboratory, Oak Ridge Reservation and SRS consistent with Site

Treatment Plans. The preferred alternative for MLLW disposal consisted of two regional

disposal sites, Hanford Site and Nevada Test Site. DOE decided to implement the

preferred alternative and issued a ROD on February 25, 2000 (DOE 2000a). The

decisions did not preclude DOE's use of commercial treatment and disposal facilities,

consistent with current DOE Orders and Policy.

While these two EISs addressed treatment and disposal of LLW and MLLW at SRS, the

onsite treatment and disposal facilities for most of the five waste forms being addressed

in this EA do not exist. For various reasons, the proposed projects that would have

provided the facilities, such as new low-activity waste and RCRA disposal vaults, have

been cancelled. Some of the reasons for cancellation include recognition of existing DOE

complex capacity, inability to meet current South Carolina Department of Health and

Environmental Control (SCDHEC) RCRA waste disposal facility requirements, and

funding limitations. DOE’s inability to meet South Carolina’s waste disposal

requirements is the primary problem, and it is not correctable. SRS does not have a

naturally occurring confining clay layer of sufficient thickness to meet South Carolina

requirements for a RCRA disposal unit as defined in South Carolina Hazardous Waste

Management Regulations R.61-104.IV.C.1.a. Because of this, DOE has no plans to

construct and operate such facilities at SRS. Therefore, DOE is proposing to use offsite

commercial and Government facilities for treatment and disposal of these wastes.
6

1.2 Purpose and Need for Action

DOE needs a viable near-term treatment and disposal option for the five LLW and

MLLW forms listed in Table 1-1 that are generated at SRS. DOE needs to take action in

a cost-effective and timely manner because onsite treatment and disposal capabilities for

these waste forms do not exist at SRS at this time and/or it is more beneficial to DOE to

dispose of the waste at another location. In addition, these waste forms would comprise

an estimated volume of approximately 136,057 cubic meters (4,804,282 cubic feet). If

not dispositioned upon generation, storage of this volume of waste would likely exceed

RCRA and TSCA regulatory limits. Storage without treatment would not be consistent

with the agreements between DOE and the State of South Carolina concerning MLLW

management under the SRS Site Treatment Plan that was developed pursuant to the

Federal Facility Compliance Act of 1992. Violating these agreements could result in

fines and penalties for DOE as well as suspension of the site's RCRA Permit.

2.0 PROPOSED ACTION AND ALTERNATIVES

2.1 Proposed Action

DOE proposes to transport, by rail or truck, certain SRS LLW and MLLW forms (Table

1-1) to commercial and Government facilities for treatment and disposal. SRS activities

that would generate these waste forms have been evaluated in other NEPA reviews (e.g.,

DOE 1987, 1992, 1994, 1995a, 1998a, 1998b, 1998c, 1998d). Although the treatment

and disposal operations at the commercial and Government facilities are beyond the

scope of this EA, the Government facilities are separately covered through appropriate

NEPA documentation (DOE, 1995c, 1996, 1997a, 1999a). Additionally, DOE would

ensure all commercial facilities are properly licensed to receive the radioactive material

prior to shipment and perform reviews of the facility's operations. None of these wastes,

or residuals or secondary waste generated during the offsite treatment, would be returned

to SRS under the proposed action. The estimated volume that would be shipped under

this proposed action on an annual basis would range from 5,664 to 12,744 cubic meters

(200,000 to 450,000 cubic feet).

The shipping vendor would be responsible for providing the modes of transportation

(either rail or truck), equipment, security and health and safety requirements to ship the

waste from SRS. The shipping containers would be provided by either DOE or the

vendor. SRS personnel would be responsible for loading the waste into the appropriate

U. S. Department of Transportation (DOT)-approved shipping containers. The vendor

would take custody of the packaged waste at the SRS staging area. DOE would ensure

that external contamination to the containers leaving SRS does not exceed DOT limits.

The vendors would be responsible for ensuring that all DOT and DOE regulations and

Orders are met for LLW and MLLW shipments. The vendors would also be responsible

for ensuring compliance with all Federal, State, and local licenses, permits, and other

required documentation to treat and/or dispose of LLW and MLLW.
7

The proposed action would include the transportation of the LLW and MLLW to seven

potential offsite-processing locations for treatment and disposal (Zecha 2000). The seven

commercial or Government facilities located within a general area are grouped such that

the calculations for six destinations cover the seven potential offsite-processing locations,

as well as future/additional locations that are near the six destinations (Table 2-1). The

destinations chosen are: 1) Idaho Falls, Idaho; 2) Eunice, New Mexico; 3) Mercury,

Nevada; 4) Oak Ridge, Tennessee; 5) Clive, Utah; and 6) Richland, Washington (Figure

2-1). The Waste Control Specialists (WCS) facility, although located at a remote site

approximately 48 kilometers (30 miles) west of Andrews, in Andrews County, Texas, is

geographically positioned closer to Eunice, Lea County, New Mexico. Because the

specific WCS location is not contained within the computer models (i.e., HIGHWAY 3.3

and INTERLINE) used in this EA, the town of Eunice will be substituted as the modeling

endpoint for the transportation analyses of the waste shipments going from SRS to WCS

(Section 3.2). All destination facilities are accessible by both rail and truck, except rail

ends at Pocatello, Idaho, and Mercury, Nevada. Therefore, results are presented for two

separate legs consisting of 1) rail from SRS to Pocatello, Idaho, and 2) truck from

Pocatello to Idaho Falls, Idaho. Rail-to-truck shipments to Mercury, Nevada, were not

considered in this EA.

Although DOE-SR has cradle-to-grave responsibility for its wastes, the transportation of

the treated waste from those facilities to the final disposal facility would be the

responsibility of vendor. DOE does not evaluate transporting the treated waste from

commercial treatment facilities to the final disposal facility in this EA. However, since

the waste constituents would have been either immobilized, thermally treated, thermally

encapsulated, solidified, amalgamated, volume reduced, or containerized at the

commercial treatment facilities, and the radiation levels or hazard volumes of the waste

have not been increased, the transportation impacts would be no greater than those that

would result from transporting the untreated waste from SRS to final disposal facility,

and those impacts are evaluated in this EA. The various commercial vendor facilities are

accessible by either rail or truck. Each of these offsite facilities would be required by law

to have in place all necessary U. S. Nuclear Regulatory Commission (NRC), State, and

local licenses and/or permits to either treat or dispose of the waste forms in questions.

DOE would ensure the receiving facility is properly licensed prior to shipment of the

waste. In addition it should be noted that in the case of transportation accidents, the

Federal Government is ultimately responsible for the cleanup after the bond limit of the

carrier is exceeded.

DOE Order 435.1, Radioactive Waste Management, and DOE Manual 435.1 (which

describes how the Order is implemented) identify the requirements that DOE must follow

and the controls and oversight that must be in place before DOE ships waste to a

commercial facility for treatment, storage or disposal. In making a decision to use a

commercial facility for managing DOE radioactive waste, the DOE Field Element

Manager must ensure that the decision is protective of the public and the environment.

This responsibility is effected by ensuring the following: (1) the commercial facility is

properly licensed and/or permitted; (2) the facility complies with applicable regulations;
8

Table 2-1. Listing of the offsite waste processing centers considered in this EA.

Name of Facility Type of Facility Waste Management

Function(s)

Location a

Nevada Test Site Government Disposal Mercury, Nevada

Envirocare of Utah,

Inc.

Commercial Treatment and

Disposal

Clive, Utah

Waste Control

Specialists

Commercial Treatment and

Disposal

Andrews County,

Texas

Idaho National

Environmental and

Engineering

Laboratory

Government Treatment Idaho Falls, Idaho

East Tennessee

Technology Park

Commercial Treatment Oak Ridge, Tennessee

Allied Technology

Group

Commercial Treatment Richland, Washington

Hanford Site Government Treatment and

Disposal

Richland, Washington

a

 - or nearest municipality

and (3) the facility has an acceptable history of operational and regulatory performance.

Based on the characteristics of the waste that is being considered for transfer to the

commercial facility, a review would be conducted of the licenses and permits held by the

facility to determine if they provide appropriate coverage for management of the waste.

This would be accomplished through a reading of the licenses and permits and through

discussions with the issuing authority (Federal, State, or local licensing/permitting

authority). This review would confirm that the facility is authorized to receive the

radionuclides in the waste to be transferred, and, if the waste contains constituents subject

to RCRA or TSCA, that the facility has the appropriate authorization to receive and

manage those constituents. Discussions with regulatory authorities and reviews of

10

inspection reports would also be used to determine whether the facility has a history of

acceptable operational and regulatory performance. Once a determination has been made

by a DOE organization that a commercial facility has an acceptable operational and

regulatory history, this determination can be used by other DOE organizations, e.g., a

DOE organization can use the results of a review performed by another DOE organization

or DOE contractor in making a decision on the acceptability of the commercial facility's

performance. However, it is the responsibility of a DOE organization using a commercial

facility to ensure, on an annual basis, that the facility is maintaining an acceptable

performance record, either through their own review or that conducted by another DOE

organization or contractor. Documentation of the results of the evaluation of regulatory

compliance and acceptable operational history as discussed above is adequate for

showing that the use of the commercial facility will be protective of public health and the

environment.

The facility's waste acceptance criteria are essential to the proper operation of the

radiological waste treatment/disposal facility. SRS will comply with the facility's waste

acceptance criteria through auditable waste characterization and certification activities.

This would enable DOE Savannah River Operations Office and the facility’s host State to

ensure that all safety, health physics/radiation monitoring procedures, Quality

Assurance/Quality Control (QA/QC) procedures, transportation procedures, volume

reduction procedures, and laboratory procedures at the disposal facility would be met.

Further, meeting the waste acceptance criteria for disposal of MLLW is driven by RCRA.

These criteria must be met before these waste forms could be offered to any commercial

or Government facility for final disposal. In the event that these criteria can’t be met for a

specific volume of waste to be shipped, then those materials would remain at SRS until

an alternative management option can be determined.

The commercial facility's activities would be closely scrutinized by way of a number of

controls and oversight mechanisms throughout the process as demonstrated by the

following QA/QC requirements included in the terms of the contract:

• Current NRC and/or state radioactive materials licenses;

• Health Protection/radiation monitoring procedures;

• QA/QC plans;

• Return of empty containers and equipment, as required;

• Shipping papers and manifests, as appropriate; and

• Record of waste treatment/disposal

Oversight of these activities at these facilities would be conducted by DOE, NRC, the

U. S. Environmental Protection Agency, and State agencies that regulate the management

of radiological and hazardous waste.

If the proposed action were selected, an amended ROD would have to be issued by DOE

for the SRWMEIS. The decision in the ROD would be to further implement the

Moderate Treatment Configuration Alternative through the offsite transportation of
11

certain LLW and MLLW for treatment and/or final disposal at commercial and

Government facilities.

2.2 Alternatives to the Proposed Action

In accordance with NEPA regulations, DOE examined the following alternatives to the

proposed action:

• No action, continue to store these waste forms at SRS

• Construct and operate onsite treatment and disposal facilities

2.2.1 No Action, Continue to Store these Waste Forms at SRS

One alternative to the proposed action is to take no action. DOE would continue to store

these waste forms onsite. The impacts associated with the proposed action would not

occur. DOE would not provide onsite treatment or disposal capabilities for these waste

forms. Storage space and disposal capacity needs would increase each year as waste was

generated. Environmental restoration and decontamination and decommissioning

projects at SRS would have to be postponed because of lack of available storage space

and treatment and disposal capacity to handle the waste generated by these activities. If

not dispositioned upon generation, storage of these waste forms could also result in

violations of RCRA and TSCA regulatory limits. The potential outcome of this could be

significant fines and penalties for SRS. Also, the average costs associated with the proper

management of stored waste is approximately $45 per 1.0 cubic meter (35.3 cubic feet)

per year. These costs would be in addition to the ultimate treatment and/or disposal costs

for these SRS waste forms.

2.2.2 Construct and Operate Onsite Treatment and Disposal Facilities

One alternative to the proposed action would be to construct and operate onsite treatment

and disposal facilities for these waste forms. This would include the construction and

operation of the following new facilities: a non-alpha vitrification facility, a containment

building, 3 low-activity waste disposal vaults, and 26 RCRA disposal vaults. The

environmental impacts and administrative decisions associated with these facilities were

addressed in DOE (1995a, 1995b, and 1997b). However, expenditure of capital funds for

new treatment and disposal facilities while offsite capacity exists for these waste forms is

not a cost-effective solution. Because of the previously mentioned lack of a clay

confining layer in the area of SRS, RCRA disposal vaults could not be built onsite that

would meet current SCDHEC requirements for such facilities. In addition, given the

current funding limitations and alternatives available for these waste forms, DOE does

not plan to build the previously proposed treatment and disposal facilities.
12

3.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED

ACTION AND ALTERNATIVES

SRS occupies an area of approximately 803 square kilometers (310 square miles) in

southwestern South Carolina (Figure 1-1). The site borders the Savannah River for about

27 kilometers (17 miles) near Augusta, Georgia, and Aiken and Barnwell, South

Carolina. SRS contains five non-operational nuclear production reactor areas, two

chemical separations facilities, waste treatment, storage and disposal facilities, and

various supporting facilities. The final EIS for the management of spent nuclear fuel at

SRS (DOE 2000b) and the most recent socio-economic survey of the six-county SRS area

of influence (HNUS 1997) contain additional information on SRS facilities and the areas

surrounding the site.

3.1 Onsite Loading Operation

Site personnel would load the waste into the appropriate shipping containers at the onsite

staging area. The vendor would take custody of the packaged waste prior to shipping.

The container loading/packaging activities would be conducted in conjunction with

ongoing site activities associated with the generation and storage of these waste forms.

The site workforce involved with these efforts would be approximately 5 to 20 employees

per loading operation. Appropriate protective clothing would be worn by the workers

conducting these activities.

Site personnel working in waste management operations at SRS received an average

annual dose of 0.037 rem (DOE 1995a). The current DOE worker exposure limit is 5 rem

per year, and the SRS sitewide administrative exposure guideline is 0.5 rem per year. The

average annual worker dose would not be expected to change under the proposed action.

Arnett and Mamatey (1998a, 1998b) contain more information about SRS worker

exposure.

The Occupational Safety and Health Act (OSHA) requires that employers comply with

the safety and health standards set by the act (29 CFR 1910) to provide each employee

with a worksite that is free from recognized hazards that are likely to cause death or

serious injury. Aside from unforeseen accidents, DOE expects no impacts to human

health and worker safety associated with the loading operations portion of the proposed

action. Any spills which might occur during the loading operations would be cleaned-up

immediately. No additional impacts would be expected as a result of the proposed action.

3.2 Transportation Impacts

3.2.1 Analyzed Scenarios

The proposed action would include the offsite transportation of LLW and MLLW

generated at SRS. Waste shipments would originate at SRS and be transported offsite by

either rail or truck conveyance for final treatment and/or disposal. As discussed in the
13

scope of the proposed action, the destinations addressed in this EA include: 1) Idaho

Falls, Idaho; 2) Eunice, New Mexico; 3) Mercury, Nevada; 4) Oak Ridge, Tennessee; 5)

Clive, Utah; and 6) Richland, Washington.

The LLW and MLLW proposed for shipment offsite may be in one of five forms (Table

1-1). The first case involves M-Area blended uranium immobilized in glass. The second

and third cases consider miscellaneous debris at a contamination level of 99 nCi Pu239 per

gram for volumes corresponding to 4.41E+06 ft3

 and 45,000 drums (3.31E+05 ft3),

respectively. The fourth case considers 5000 drums of liquid with a concentration of 99

nCi Pu239 per gram. This material is shipped in a Type A shipping container, a Low

Specific Activity (LSA) drum or the equivalent of one of these. The fifth case also

involves liquids with a concentration of 99 nCi Pu239 per gram. However, this waste

would be shipped in ten tanker trailers, each with a volume of 12,869 liters (3,400

gallons).

3.2.2 Assumptions

Isotopic contents of the first case were developed from laboratory analysis and

accountability reports (Thoman 2000). It should be noted that the second through fifth

cases are hypothetical worst case scenarios. This is only an assumption for use in the

RADTRAN model; furthermore, there are presently no known LLW or MLLW forms

planned for offsite shipment that approach the hypothetical level of radioactivity of 99

nCi/g. These source terms were chosen to provide worst case bounding scenarios within

the context of this EA.

Transport of the material would be containers in exclusive use vehicles. Table 3-1

presents the isotopic composition of each of the five cases. Table 3-2 presents the

number of containers per shipment and the total number of shipments for each case.

Both incident-free and accident radiological impacts for the shipment of LLW and

MLLW from SRS were analyzed. Routing conditions (including population densities,

distance and time traveled, and fraction of highway and rail travel in urban, suburban and

rural population zones) were obtained from the HIGHWAY 3.4 (Johnson et al. 1993,

Maheras and Pippen 1995) and INTERLINE (Maheras and Pippen 1995) computer codes

for truck and rail transport, respectively. Routing parameters are listed in Tables 3-3 and

3-4 for truck and rail shipments, respectively, and include the distance traveled and the

percent of route in rural, suburban, and urban areas. Routing conditions, dose rates, and

neutron-gamma fractions were used as inputs to the RADTRAN 4 computer code

(Neuhauser and Kanipe 1992, 1995, Maheras and Pippen 1995) to calculate radiological

impacts. The exact route chosen to ship the material depends on many factors and will be

similar but probably not identical to the route projected here.

Input to RADTRAN 4 is described in Table 3-5 below for truck and rail shipments.

Pathways analyzed for human exposure include direct exposure from contained material,

and inhalation and airborne immersion from accidentally released material.
14

Table 3-1. Isotopic composition for the five cases (Hang 2000, Hang and Thoman 2000,

Thoman 2000).

Case

Number

Isotope Total Activity

(in Ci)

Average

Activity per

Drum ( in Ci)

Average

Activity per

Railcar (in Ci)

Average

Activity per

Truck (in Ci)

1 U235 1.86E-01 6.53E-05 1.63E-02 3.93E-03

U238 9.59E+00 3.36E-03 8.41E-01 2.02E-01

2 Pu239 1.90E+04 3.16E-02 8.6E+00 1.90E+00a

3 Pu239 1.42E+03 3.16E-02 N/A b 1.90E+00

4 Pu239 1.65E+02 3.31E-02 N/A b 1.97E+00

5 Pu239 1.97E+01 N/A c N/A b 1.97E+00

a

 - Rail transport ends at Pocatello, ID. Therefore, truck was analyzed only for one case:

from Pocatello to Idaho Falls, ID b

 - The volume of material in this case is transported solely via trucks

c

 - The volume of material in Case 5 is transported solely via tanker trailer.

This analysis did not attempt to quantify risks from agricultural products contaminated as

a result of dispersal of the material being transported and involved in a serious accident.

Emergency Action Guidelines applicable to the area surrounding an accident would

require interdiction of crops, cattle, and milk at specific thresholds, and these foodstuffs

would thus be taken out of the market. In addition, any impacted surface waters used for

human consumption would likewise be restricted from further use until determined to be

safe. As a result, the options dealing with this analysis were set to the “off” condition,

and no calculations were made by the software to assign risk values to food pathways.

All other accidental exposure pathways were considered.

3.2.3 Radiological Consequences

Incident-Free Conditions – The level of the incident-free consequence depends on the

dose rate at the external surface of the transport vehicle. The current analysis is based on

identifying an external radiation field from the transported waste that is equivalent to the

maximum allowable by Part 173 of the Code of Federal Regulations under Title 49,
15

Table 3-2. Transport information for each case.

Case

Number

Drums or

Volume per

Railcar

Drums or

Volume per

Trainload a

Total

Number of

Trainloads

Drums

per

Truck

Total Number

of Truckloads

1 250 2,850 1 60 50

2 57 m3

(2,000 ft3)

1,132.80 m3

(~ 40,000 ft3)

56 60 5,000

3 N/A N/A N/A 60 750

4 N/A N/A N/A 60 84

5 N/A N/A N/A N/A 10 b

a

 Assuming a maximum of 20 railcars per trainload (Hang 2000, Hang and Thoman

2000)

b

 Case 5 is transported via tanker trailer

Transportation (CFR 1999), or 0.1 mSv/h (10 mrem/hour) at 2 meters distance from the

package.

A limited radiation transport study was performed to evaluate the ratio of dose rate as a

function of distance, given the package dimension and resulting field from the various

waste forms (White 2000). The study indicated the ratio of 1-meter dose rate to the

2-meter dose rate in the same direction from the waste container varies from about 2 to a

little above 3, and is maximum for the field at package “end” (Table 3-6). As a

conservatism, the effective dose equivalent (EDE) field input to RADTRAN was scaled

by a factor of 4 from the 49 CFR 173 limit of 0.1 mSv/h (10 mrem/hour) at 2 meters, to

0.4 mSv/h (40 mrem/hour) at 1 meter.

The EDE field is used in RADTRAN to predict worker and general public exposure

during transit as part of the incident-free risk. In the RADTRAN analysis, the dose field

parameter is not specific to radiation decay energies associated with the waste package

radionuclide composition; rather as stated above, it is tied to a bounding limit allowed by

49 CFR 173. As recommended by the RADTRAN code user’s manual, the external

radiation field is attributed entirely to gamma radiation.
16

Table 3-3. Routing parameters for offsite SRS solid waste truck shipments.

Destination

Total Distance

in Kilometers

(in Miles)

Percent

Rural

Percent

Suburban

Percent

Urban

SRS to Idaho Falls, Idaho 3,471.3

(2,157.0)

82.9 15.3 1.8

SRS to Eunice, New Mexico 2,349.6

(1,460.0)

77.7 21.0 1.3

SRS to Mercury, Nevada 3,559.8

(2,212.0)

83.9 14.4 1.7

SRS to Oak Ridge, Tennessee 539.1

(335.0)

66.7 32.5 0.8

SRS to Clive, Utah 3,479.3

(2,162.0)

83.2 15.2 1.6

SRS to Richland, Washington 4,240.5

(2,635.0)

84.2 14.2 1.6

Pocatello, Idaho to Idaho

Falls, Idaho

90.1

(56.0)

71.7 24.5 3.8

Additional key parameters include the exposure time and distance of the receptors, and

the number of receptors involved in the transport process. Additionally, on-link receptors

not involved in the transport process are exposed, as are off-link receptors near the

transport path. On-link receptors are members of the general public assumed to be on the

transportation corridor (both railway and roadway) in other vehicles. Off-link receptors

are members of the general public assumed to live or work near the transportation

corridor. Table 3-7 provides the incident-free consequence results for transport of the

five waste forms to the six treatment and/or disposal locations (Hang and O’Kula 2000).

Additionally, Table 3-7 lists the natural background dose for the same population. By

default, RADTRAN locates the maximum individual at a distance of 30 meters from the

transport link (highway or rail line). Crew and handler dose calculations are based on the

number of packages per shipment, the dose rate from the packages, and the average time

of exposure.
17

Table 3-4. Routing parameters for offsite SRS solid waste rail shipments.

Destination

Total Distance

in Kilometers

(in Miles)

Percent

Rural

Percent

Suburban

Percent

Urban

SRS to Pocatello, Idaho 3,885.8

(2,414.6)

85.4 13.2 1.4

SRS to Eunice, New Mexico 2,745.8

(1,706.2)

77.7 20.1 2.2

SRS to Oak Ridge, Tennessee 636.6

(395.6)

64.2 33.9 1.9

SRS to Clive, Utah 3,804.5

(2,364.1)

84.8 13.4 1.8

SRS to Richland, Washington 5,017.3

(3,117.8)

82.0 15.7 2.3

Accident Consequences – Radiological risks from accidentally released material due to

transport vehicle collision would result primarily from the release of respirable

radioactive particulates and subsequent inhalation by individuals downwind of the

accident, either directly or after resuspension. Other exposure pathways of significance

include direct radiation from the cloud of airborne material and from contamination on

the ground. Consequences involving contaminated agricultural products or surface

drinking water sources as a result of dispersion of the accidentally released material are

not considered. Emergency Action Guidelines applicable to the area surrounding an

accident would require diversion of crops, cattle, and milk at specific thresholds, and

these foodstuffs would thus be taken out of the market. Impacted surface waters used for

human consumption would likewise be restricted from further use until determined to be

safe for drinking.

Consequences of an accident depend upon the severity and population density at the

location of the accident. Table 3-8 provides the sum of the accident risks for transport of

the five waste forms to the six treatment and/or disposal facilities (Hang and O’Kula

2000). Table 3-8 also lists the natural background dose for the same population.
18

Table 3-5. RADTRAN input data for truck and rail shipments.

Input Variable Value or Source of Data

Truck Rail

Material Dispersion

Category

Immobile (Case 1), Small

Powder (Cases 2 and 3),

Liquid (Cases 4 and 5)

Immobile (Case 1), Small

Powder (Case 2)

Packages per Shipment See Table 3-2 See Table 3-2

Number of Shipments See Table 3-2 See Table 3-2

External Radiation Field 40 mrem/h at 1 m 40 mrem/h at 1 m

Fraction of Gamma

Radiation

1 1

Length of Package 0.86 metersa 20 meters

Isotopes in Package See Table 3-1 See Table 3-1

Activity in Package See Table 3-1 See Table 3-1

Distance Traveled (Hang, 2000) (Hang, 2000)

Fraction of Travel in

Population Zone

(Hang, 2000) (Hang, 2000)

Accident Severity

Categories

8 8

Accident Rates

(Accident Per Kilometer)

1.4E-6 rural

1.4E-6 suburban

1.4E-6 urban

2.4E-6 rural

2.4E-6 suburban

2.4E-6 urban

a

 Except for Case 5 tanker truck
19

Table 3-6. Radiation dose field ratios for truck and rail waste forms.

Case Description Ratio of Dose rate at 1

m/Dose rate at 2 m

Side Top End

1/Truck Vitrified uranium in drums, transported by truck 1.94 1.75 2.72

1/Rail Vitrified uranium in drums, transported by rail 1.44 1.70 1.99

2/Rail Plutonium in soil and debris in drums,

transported by rail

1.53 1.69 2.10

2/Truck Plutonium in soil and debris in drums,

transported by truck

1.97 1.72 2.76

3/Truck Plutonium in soil and debris in drums,

transported by truck

1.97 1.72 2.76

4/Truck Plutonium in solution in drums, transported by

truck

1.97 1.72 2.77

5/Truck Plutonium in solution, transported by tanker

truck

1.71 1.71 3.11

Health Effects – Tables 3-7 and 3-8 present doses for transportation under both

incident-free and accident conditions. Health effects, measured as the number of

potential latent cancer fatalities (LCFs), were calculated by multiplying the population

consequence (in units of person-rem) by the cancer risk factor of 5E-4 potential LCFs per

person-rem (DOE 1993). For maximum individual exposures, this same value is used to

calculate cancer mortality probability. Table 3-9 presents the maximum calculated total

incidence of potential LCFs for incident-free transport and due to an accident from

shipments of LLW and MLLW from SRS.

Consequences of an accident depend upon the severity and population density at the

location of the accident. Table 3-8 provides the sum of the accident risks for transport of

the five source terms to the six treatment and/or disposal facilities. Additionally, Table

3-8 lists the natural background dose for the same population.
20

Table 3-7. Incident-free radiological consequences (Hang and O’Kula 2000, WSRC

2000).

Route

Case - Mode

Incident-free

workers

exposure

(person – rem)

Incident-free

general public

exposure

(person – rem)

Maximum

individual

general public

dose (rem)

Exposed

population –

incident-free

(persons)

Natural

background dose

to incident-free

general public

(person – rem) a

SRS to Clive, UT

Case 1 - Rail 1.45E+00 1.23E-01 8.40E-05 5.41E+05 1.62E+05

Case 2 - Rail 2.26E+02 1.37E+01 1.55E-02 5.41E+05 1.62E+05

Case 1 - Truck 1.80E+01 9.33E+00 9.38E-04 5.21E+05 1.56E+05

Case 3 - Truck 2.71E+02 1.40E+02 1.41E-02 5.21E+05 1.56E+05

Case 4 - Truck 3.03E+01 1.57E+01 1.58E-03 5.21E+05 1.56E+05

Case 5 - Truck 2.70E+01 2.82E+01 7.00E-05 5.21E+05 1.56E+05

SRS to Eunice,

NM

Case 1 - Rail 1.42E+00 1.18E-01 8.40E-05 5.49E+05 1.65E+05

Case 2 - Rail 2.23E+02 1.31E+01 1.55E-02 5.49E+05 1.65E+05

Case 1 - Truck 1.25E+01 6.39E+00 9.38E-04 3.91E+05 1.17E+05

Case 3 - Truck 1.87E+02 9.59E+01 1.41E-02 3.91E+05 1.17E+05

Case 4 - Truck 2.10E+01 1.07E+01 1.58E-03 3.91E+05 1.17E+05

Case 5 - Truck 1.84E+01 1.93E+01 7.00E-05 3.91E+05 1.17E+05

SRS to Oak

Ridge, TN

Case 1 - Rail 1.34E+00 5.12E-02 8.40E-05 1.61E+05 4.83E+04

Case 2 - Rail 2.14E+02 5.69E+00 1.55E-02 1.61E+05 4.83E+04

Case 1 - Truck 3.02E+00 1.51E+00 9.38E-04 1.03E+05 3.09E+04

Case 3 - Truck 4.53E+01 2.26E+01 1.41E-02 1.03E+05 3.09E+04

Case 4 - Truck 5.07E+00 2.52E+00 1.58E-03 1.03E+05 3.09E+04

Case 5 - Truck 4.24E+00 4.55E+00 7.00E-05 1.03E+05 3.09E+04

SRS to

Hanford, WA

Case 1 - Rail 1.50E+00 1.76E-01 8.40E-05 8.98E+05 2.69E+05

Case 2 - Rail 2.32E+02 1.95E+01 1.55E-02 8.98E+05 2.69E+05

Case 1 - Truck 2.18E+01 1.13E+01 9.38E-04 6.14E+05 1.84E+05

Case 3 - Truck 3.28E+02 1.70E+02 1.41E-02 6.14E+05 1.84E+05

Case 4 - Truck 3.67E+01 1.90E+01 1.58E-03 6.14E+05 1.84E+05

Case 5 - Truck 3.29E+01 3.43E+01 7.00E-05 6.14E+05 1.84E+05
21

Table 3-7. (Continued).

Route

Case - Mode

Incident-free

workers

exposure

(person – rem)

Incident-free

general public

exposure

(person – rem)

Maximum

individual

general public

dose (rem)

Exposed

population –

incident-free

(persons)

Natural

background dose

to incident-free

general public

(person – rem) a

SRS to

Mercury, NV

Case 1 – Rail NAb NAb NAb NAb NAb

Case 2 – Rail NAb NAb NAb NAb NAb

Case 1 – Truck 1.84E+01 9.54E+00 9.38E-04 5.44E+05 1.63E+05

Case 3 – Truck 2.76E+02 1.44E+02 1.41E-02 5.44E+05 1.63E+05

Case 4 – Truck 3.09E+01 1.60E+01 1.58E-03 5.44E+05 1.63E+05

Case 5 – Truck 2.77E+01 2.88E+01 7.00E-05 5.44E+05 1.63E+05

SRS to Idaho

Falls, ID

Case 1 – Rail NAc NAc NAc NAc NAc

Case 2 – Rail NAc NAc NAc NAc NAc

Case 1 – Truck 1.80E+01 9.33E+00 9.38E-04 5.53E+05 1.66E+05

Case 3 – Truck 2.70E+02 1.40E+02 1.41E-02 5.53E+05 1.66E+05

Case 4 – Truck 3.03E+01 1.57E+01 1.58E-03 5.53E+05 1.66E+05

Case 5 – Truck 2.71E+01 2.83E+01 7.00E-05 5.53E+05 1.66E+05

SRS to

Pocatello, ID

Case 1 – Rail 1.45E+00 1.23E-01 8.40E-05 4.94E+05 1.48E+05

Case 2 – Rail 2.27E+02 1.36E+01 1.55E-02 4.94E+05 1.48E+05

Pocatello, ID

to Idaho Falls,

ID

Case 1 – Truck 5.01E-01 2.55E-01 9.38E-04 2.78E+04 8.34E+03

Case 2 – Truck 1.00E+02 5.10E+01 1.88E-01 2.78E+04 8.34E+03

a Based on an average individual background dose of 300 mrem/yr (Kathren, 1984).

b There is no rail access to the Nevada Test Site.

c Rail ends at Pocatello, ID. Results are presented in table for two separate legs consisting of: (1) rail from

SRS to Pocatello, ID, and (2) truck from Pocatello to Idaho Falls, ID.

Impacts of Accidental Releases – Impacts of radioactive waste transportation accidents

were evaluated as a consequence of an acute liquid release into aquatic environments.
22

Table 3-8. Sum of accident radiological consequences (Hang and O’Kula 2000, WSMS

2000).

Route

Case - Mode

Accident risk

general public

(person – rem)

Exposed general

public – accident

(persons)

Natural background

dose to accident exposed

general public

(person – rem) a

SRS to Clive, UT

Case 1 - Rail 6.69E-07 3.34E+06 1.00E+06

Case 2 - Rail 3.28E+02 3.34E+06 1.00E+06

Case 1 - Truck 3.58E-07 3.39E+06 1.02E+06

Case 3 - Truck 1.31E+01 3.39E+06 1.02E+06

Case 4 - Truck 3.07E+02 3.39E+06 1.02E+06

Case 5 - Truck 3.63E+01 3.39E+06 1.02E+06

SRS to Eunice, NM

Case 1 - Rail 7.36E-07 3.35E+06 1.01E+06

Case 2 - Rail 3.61E+02 3.35E+06 1.01E+06

Case 1 - Truck 3.13E-07 3.13E+06 9.38E+05

Case 3 - Truck 1.14E+01 3.13E+06 9.38E+05

Case 4 - Truck 2.69E+02 3.13E+06 9.38E+05

Case 5 - Truck 3.17E+01 3.13E+06 9.38E+05

SRS to Oak Ridge, TN

Case 1 - Rail 2.56E-07 3.10E+06 9.31E+05

Case 2 - Rail 1.26E+02 3.10E+06 9.31E+05

Case 1 - Truck 9.42E-08 2.94E+06 8.81E+05

Case 3 - Truck 3.45E+00 2.94E+06 8.81E+05

Case 4 - Truck 8.09E+01 2.94E+06 8.81E+05

Case 5 - Truck 9.56E+00 2.94E+06 8.81E+05

SRS to Hanford, WA

Case 1 - Rail 1.09E-06 3.41E+06 1.02E+06

Case 2 - Rail 5.37E+02 3.41E+06 1.02E+06

Case 1 - Truck 4.14E-07 3.39E+06 1.02E+06

Case 3 - Truck 1.52E+01 3.39E+06 1.02E+06

Case 4 - Truck 3.56E+02 3.39E+06 1.02E+06

Case 5 - Truck 4.20E+01 3.39E+06 1.02E+06

SRS to Mercury, NV

Case 1 – Rail NAb NAb NAb

Case 2 – Rail NAb NAb NAb

Case 1 – Truck 3.61E-07 3.48E+06 1.04E+06

Case 3 – Truck 1.32E+01 3.48E+06 1.04E+06

Case 4 – Truck 3.10E+02 3.48E+06 1.04E+06

Case 5 – Truck 3.67E+01 3.48E+06 1.04E+06
23

Table 3-8. (Continued).

Route

Case - Mode

Accident risk

General public

(person – rem)

Exposed general

public – accident

(persons)

Natural background

dose to accident exposed

general public

(person – rem) a

SRS to Idaho Falls, ID

Case 1 – Rail NAc NAc NAc

Case 2 – Rail NAc NAc NAc

Case 1 – Truck 3.67E-07 3.41E+06 1.02E+06

Case 3 – Truck 1.35E+01 3.41E+06 1.02E+06

Case 4 – Truck 3.16E+02 3.41E+06 1.02E+06

Case 5 – Truck 3.73E+01 3.41E+06 1.02E+06

SRS to Pocatello, ID

Case 1 – Rail 6.57E-07 3.36E+06 1.01E+06

Case 2 – Rail 3.23E+02 3.36E+06 1.01E+06

Pocatello, ID to Idaho

Falls, ID

Case 1 – Truck 1.92E-08 3.14E+06 9.41E+05

Case 2 – Truck 9.37E+00 3.14E+06 9.41E+05

a

 Based on an average individual background dose of 300 mrem/yr (Kathren, 1984)

b

 There is no rail access to the Nevada Test Site.

c

 Rail ends at Pocatello, ID. Results are presented in table for two separate legs consisting of: (1) rail

from SRS to Pocatello, ID, and (2) truck from Pocatello to Idaho Falls, ID.

These assessments estimated the potential ecological impacts of an accident spilling the

entire contents of a tanker truck shipment of LLW into various surface water streams. A

simple volumetric dilution assessment was then performed for estimating the impact in

the form of a radiation dose to aquatic biota in those drainages (Jannik 2001).

The bounding accident scenario (that is, the single largest potential release under the

proposed action) used in these assessments involves a 12,869-liter (3,400-gallon) tanker

truck carrying liquid LLW with an average activity of 1.97 Ci of Pu239 (that is, Case 5 in

Tables 3-1 and 3-2) The postulated accident ruptures the tank wall, releasing the total

contents into a stream over a two-hour time frame. This accident scenario was assessed

using streams of different size classes ranging from a small first order headwater stream

(a flow rate of one ft3

 per second or cfs) to a tenth order major continental river (a flow

rate of 10,000 cfs). An aquatic biotic concentration guide (BCG) for Pu239 of 200 pCi/L

was used to estimate the dose to the affected stream biota. This would equate to

approximately one rad per day (Jannik 2001).
24

Table 3-9. Number of potential latent cancer fatalities for incident-free and accident

transportation (Hang and O’Kula 2000, WSMS 2000).

Route

Case - Mode

Potential LCFs for

workers for incident-free

transportation

Potential LCFs for

general public for

incident-free

transportation

Potential LCFs for

accident exposed

population

SRS to Clive, UT

Case 1 - Rail 7.25E-04 6.16E-05 3.35E-10

Case 2 - Rail 1.13E-01 6.83E-03 1.64E-01

Case 1 - Truck 9.01E-03 4.67E-03 1.79E-10

Case 3 - Truck 1.36E-01 7.02E-02 6.55E-03

Case 4 - Truck 1.52E-02 7.86E-03 1.54E-01

Case 5 - Truck 1.35E-02 1.41E-02 1.82E-02

SRS to Eunice, NM

Case 1 - Rail 7.08E-04 5.91E-05 3.68E-10

Case 2 - Rail 1.11E-01 6.56E-03 1.81E-01

Case 1 - Truck 6.25E-03 3.19E-03 1.57E-10

Case 3 - Truck 9.36E-02 4.79E-02 5.70E-03

Case 4 - Truck 1.05E-02 5.37E-03 1.35E-01

Case 5 - Truck 9.19E-03 9.67E-03 1.59E-02

SRS to Oak Ridge, TN

Case 1 - Rail 6.69E-04 2.56E-05 1.28E-10

Case 2 - Rail 1.07E-01 2.84E-03 6.30E-02

Case 1 - Truck 1.51E-03 7.53E-04 4.71E-11

Case 3 - Truck 2.27E-02 1.13E-02 1.73E-03

Case 4 - Truck 2.54E-03 1.26E-03 4.05E-02

Case 5 - Truck 2.12E-03 2.27E-03 4.78E-03

SRS to Hanford, WA

Case 1 - Rail 7.50E-04 8.80E-05 5.45E-10

Case 2 - Rail 1.16E-01 9.76E-03 2.69E-01

Case 1 - Truck 1.09E-02 5.66E-03 2.07E-10

Case 3 - Truck 1.64E-01 8.51E-02 7.60E-03

Case 4 - Truck 1.84E-02 9.52E-03 1.78E-01

Case 5 - Truck 1.65E-02 1.71E-02 2.10E-02

SRS to Mercury, NV

Case 1 – Rail NAa NAa NAa

Case 2 – Rail NAa NAa NAa

Case 1 – Truck 9.19E-03 4.77E-03 1.81E-10

Case 3 – Truck 1.38E-01 7.18E-02 6.60E-03

Case 4 – Truck 1.55E-02 8.02E-03 1.55E-01

Case 5 – Truck 1.38E-02 1.44E-02 1.84E-02
25

Table 3-9. (Continued).

Route

Case - Mode

Potential LCFs for

workers for incident-free

transportation

Potential LCFs for

general public for

incident-free

transportation

Potential LCFs for

accident exposed

population

SRS to Idaho Falls, ID

Case 1 – Rail NAb NAb NAb

Case 2 – Rail NAb NAb NAb

Case 1 – Truck 9.02E-03 4.67E-03 1.84E-10

Case 3 – Truck 1.35E-01 6.98E-02 6.75E-03

Case 4 – Truck 1.52E-02 7.83E-03 1.58E-01

Case 5 – Truck 1.35E-02 1.41E-02 1.87E-02

SRS to Pocatello, ID

Case 1 – Rail 7.26E-04 6.14E-05 3.29E-10

Case 2 – Rail 1.13E-01 6.81E-03 1.62E-01

Pocatello, ID to Idaho

Falls, ID

Case 1 – Truck 2.51E-04 1.27E-04 9.60E-12

Case 2 – Truck 5.02E-02 2.55E-02 4.69E-03

a

 There is no rail access to the Nevada Test Site.

b Rail ends at Pocatello, ID. Results are presented in table for two separate legs consisting of (1) rail from

SRS to Pocatello, ID and (2) truck from Pocatello to Idaho Falls, ID.

The estimated dilution factors and concentrations of Pu239 in the various receiving

streams following the accident re provided in Table 3-10. These estimated concentrations

of Pu239 would exceed the 200 pCi/L BCG. However, the BCG is conservatively based

on an annual average exposure, where equilibrium has been reached in the aquatic

environment. The Pu239 in the receiving streams would be transported downstream and

further diluted with the distance traveled. The Pu239 BCG equating to 1 rad from an

assumed 2-hour exposure duration is 2,400 pCi/L. All estimated Pu239 concentrations in

the receiving streams, except for the 10,000 cfs stream, exceed this concentration (Jannik

2001).

Observable detrimental effects will occur in fish populations at exposures of about 400

rad. The Pu239 BCG equating to 400 rad from a 2-hour exposure duration is 960,000

pCi/L. The estimated Pu239 concentrations in the 1, 5, and 10 cfs receiving streams

exceed this concentration. For fish, the lethal dose for 50 percent of a given population

(LD-50) occurs at about 550 rad. The Pu239 BCG equating to 550 rad from a 2-hour

exposure duration is 1,320,000 pCi/L. The estimated Pu239 concentrations in the 1 and 5
26

Table 3-10. Results of volumetric dilution assessment for an acute release of Pu239 into

surface water streams (Jannik 2001).

Receiving Stream

Flow rate (CFS)

Receiving Stream

Flow rate (L/s)

Dilution Factor Pu239 Concentration

in Stream (pCi/L)

1 28 17 9.19E+06 a, b

5 140 79 1.93E+06 a, b

10 280 157 9.72E+05 a

50 1,400 783 1.95E+05

100 2,800 1,565 9.77E+04

1,000 28,000 15,643 9.78E+03

10,000 280,000 156,426 9.78E+02

a

 Observable detrimental effects would occur

b

 LD-50 would occur

cfs receiving streams exceed this concentration. However, not many fish can reside in

such small headwater drainages (Jannik 2001). Therefore, no adverse affect to fish

populations is expected.

Within the scope of the proposed action, there would only be ten shipments of this type

(i.e., a 12,869-liter (3,400-gallon) tanker truck carrying liquid LLW). Based on the same

truck accident rate used in the RADTRAN modeling and assuming that all ten trucks

went to the furthest destination (i.e., Richland, Washington), no accidents would be

expected to occur within this subset of the overall action. Again, the assumptions

associated with this bounding accident scenario are hypothetical; there are presently no

known LLW or MLLW forms planned for offsite shipment that approach this level of

radioactivity of 99 nCi/g.

Emergency Planning and Response – DOE is committed to conducting all

transportation-related activities in a safe and efficient manner. The Department follows

applicable Federal, State, tribal and local requirements for shipments of radioactive

materials, including applicable DOE Orders. Shipments of LLW and MLLW will be

packaged and transported in accordance with these requirements, which effectively

minimize the risk to the public during transportation operations. However, should an

incident occur involving these shipments SRS has established an emergency management

plan and implementing procedures to ensure appropriate notifications and response

actions are initiated on a 24-hour basis.
27

Table 3-11. Expected accident levels for the designated truck travel routes (O’Kula

2000, WSMS 2000).

Route

Case

Expected Number of

Nonfatal Accidents

Expected Number of

Fatal Accidents

SRS to Clive, UT

Case 1 2.44E-01 1.83E-02

Case 3 3.65E+00 2.74E-01

Case 4 4.09E-01 3.07E-02

Case 5 4.87E-02 3.65E-03

SRS to Eunice, NM

Case 1 1.64E-01 1.23E-02

Case 3 2.47E+00 1.85E-01

Case 4 2.76E-01 2.07E-02

Case 5 3.29E-02 2.47E-03

SRS to Oak Ridge, TN

Case 1 3.77E-02 2.83E-03

Case 3 5.66E-01 4.25E-02

Case 4 6.34E-02 4.75E-03

Case 5 7.55E-03 5.66E-04

SRS to Hanford, WA

Case 1 2.97E-01 2.23E-02

Case 3 4.45E+00 3.34E-01

Case 4 4.99E-01 3.74E-02

Case 5 5.94E-02 4.45E-03

SRS to Mercury, NV

Case 1 2.49E-01 1.87E-02

Case 3 3.74E+00 2.81E-01

Case 4 4.19E-01 3.14E-02

Case 5 4.99E-02 3.74E-03
28

Table 3-11. (Continued)

Route

Case

Expected Number of

Nonfatal Accidents

Expected Number of

Fatal Accidents

SRS to Idaho Falls, ID

Case 1 2.43E-01 1.82E-02

Case 3 3.64E+00 2.73E-01

Case 4 4.08E-01 3.06E-02

Case 5 4.86E-02 3.64E-03

Pocatello, ID to Idaho Falls,

ID

Case 1 6.31E-03 4.73E-04

Case 2 1.26E-00 9.46E-03

State, tribal, and local governments having jurisdiction over areas through which these

shipments will pass have the responsibility for protecting the public and the environment

and for establishing incident command for incidents involving these shipments. The

carrier for these shipments is responsible for providing emergency response assistance

and recovery/restoration actions, if required. DOE-SR (Savannah River Operations

Office) will provide technical advice and assistance to these authorities and ensure that

the carrier of these shipments performs the necessary cleanup and site

recovery/restoration activities. DOE-SR will also coordinate with the appropriate DOE

Regional Coordinating Office and/or DOE Headquarters to provide additional

radiological support or technical assistance from the DOE Emergency Response Assets

(e.g., Radiological Assistance Program teams, etc.) as necessary.

To provide an adequate response for transportation incidents, State, tribal, and local

governments are responsible for developing emergency response plans and procedures;

organizing, training, and deploying first responders; and negotiating mutual aid

agreements for incidents close to jurisdictional boundaries. Many States also maintain

specialized Hazardous Materials Transportation Act (HAZMAT) and/or radiological

response teams that already possess the capabilities for responding to the most plausible

incidents involving LLW and MLLW. To assist in establishing and maintaining these

capabilities, DOE has developed planning and training materials through the

Transportation Emergency Preparedness Program (TEPP) to help provide the incremental

skills necessary for response to incidents involving DOE radioactive material shipments.
29

Table 3-12. Expected accident levels for the designated rail travel routes (O’Kula 2000).

Route

Case

Expected Number of

Nonfatal Accidents

Expected Number of

Fatal Accidents

SRS to Clive, UT

Case 1 9.13E-03 7.40E-04

Case 2 1.01E+00 8.21E-02

SRS to Eunice, NM

Case 1 6.59E-03 5.34E-04

Case 2 7.31E-01 5.92E-02

SRS to Oak Ridge, TN

Case 1 1.53E-03 1.24E-04

Case 2 1.70E-01 1.37E-02

SRS to Hanford, WA

Case 1 1.20E-02 9.75E-04

Case 2 1.34E+00 1.08E-01

SRS to Pocatello, ID

Case 1 9.33E-03 7.55E-04

Case 2 1.04E+00 8.38E-02

The planning materials can be accessed through the DOE Office of Transportation and

Emergency Management web site, http://www.em.doe.gov/otem. In addition, each DOE

Regional Coordinating Office has appointed a TEPP Coordinator to ensure emergency

planning and preparedness activities are integrated into the transportation planning

process. The TEPP Coordinator can provide assistance to State, tribal, and local agencies

in preparing for DOE transportation activities (e.g., assist in using the TEPP planning

products, coordinate delivery of DOE training, provide technical assistance, resolve

emergency preparedness issues, etc.).
30

3.2.4 Non-radiological Transportation Accidents

The nonfatal and fatal accident probabilities per shipment for material transported along

the postulated truck routes are listed in Table 3-11. The average nonfatal accident rate for

vehicles is 1.4E-06 accidents per kilometer (DOT 1999b). The traffic fatality rate used in

the analysis is from DOT 1998 data for large trucks (DOT 1999b). DOE assumes that the

percent of accidents resulting in a fatality would be the same as that for interstate travel

by truck, 7.5 percent (DOT 1989). This is conservative with respect to the 1998 DOT

data which shows that only 1.2 percent of large truck accidents resulted in fatalities (DOT

1999b).

Based on the data from the third column, this proposed action is not expected to result in

a fatal accident. As indicated in the second column, some nonfatal accidents may be

expected from the proposed action.

The nonfatal and fatal accident probabilities per shipment for material transported along

the postulated rail routes are listed in Table 3-12. For train events, the 1998 accident rate

was 3.77 accidents per million train miles, corresponding to an accident probability rate

of 2.4E-06 accidents per kilometer (DOT 1999a). Fatal accident probabilities were not

provided by DOT, although 8.1 percent of all reported casualties were fatal. Based on the

data from the third column of Table 3-12, this proposed action is not expected to result in

a fatal accident. As indicated in the second column, some nonfatal accidents may be

expected from the proposed action.

3.2.5 Environmental Justice

In general, the consequences associated with incident free and accident conditions of the

offsite transportation were small for the exposed population. This is due to the low

expected frequency of such accident scenarios and the ability to mitigate the impacts of

such events with the existing training and technology for controlling spills or releases

from vehicles. These rare events would also be expected to occur randomly in time with

equal distribution throughout various types of communities. Based on the percentage

breakdown of the routes analyzed, the highest risk would be along rural interstate

highways (Table 3-3). Minorities are found to be disproportionately lower in

representation in the populations residing near interstate highways (DOT 1992).

Therefore, there would be little to no potential for a disproportionately high adverse

impact on either poor or minority communities from the proposed shipments from SRS to

the offsite commercial and Government facilities.

Based on the radioactive and hazardous materials transportation analyses conducted in

support of the DOE programmatic waste management EIS (DOE 1997a), minority or

low-income populations in either the Hanford Site, Idaho National Engineering

Laboratory, Nevada Test Site, SRS or Oak Ridge areas would not be expected to

experience disproportionately high adverse health impacts associated with LLW or

MLLW shipments from the DOE sites at those locations. The Envirocare of Utah, Inc.,
31

and Waste Control Specialists vendor facilities are located in such remote, unpopulated

areas that no environmental justice impacts would be expected.

3.2.6 Conclusion

Doses have been calculated from each of the transportation options using the RADTRAN

4 computer code for the following conservative assumptions:

• 99 nCi/g Pu239 (maximum amount of worst case isotope for low-level waste)

• 10 mrem/hour @ 2 meters (interpretation of maximum radiation field allowed by

49 CFR 173)

The health effects, measured as the number of potential LCFs, due to exposure from the

radioactive waste during incident free and accident conditions of transportation are

specified in Table 3-9. To conservatively determine the cumulative effects from

transporting all five waste forms, the highest number for each case should be added

together. This results in a potential LCF to workers of 0.437, to the public of 0.184, and

during an accident of 0.475 (assuming an accident occurs for each waste type). No LCFs

are expected from the proposed action since the numbers are all less than 1. The

expected number of nonfatal and fatal accidents from truck and rail transportation is

specified in Tables 3-11 and 3-12, respectively. To conservatively determine the

cumulative effects of transportation the highest number for each case should be added

together to determine the overall expected number of accidents, both non-fatal and fatal.

Statistically, based on these transportation analyses, there is a probability of about nine

non-fatal accidents and no fatal accidents as a result of implementing the proposed action.

3.3 Waste Processing Centers Operations

This EA does not assess local impacts associated with the ongoing operation of an

already-licensed offsite vendor facility proposed to receive DOE waste for treatment or

disposal. DOE’s proposed waste load associated with this ongoing operation will be a

small part of that facility’s throughput. The facility would operate well within its

established standards and the vendor’s part of this proposal is of low potential for

significant impacts. Under the terms of the proposed contracts, the vendors would be

responsible for identifying and complying with all applicable laws and regulations

governing the operation of the offsite facility and transportation of LLW and MLLW

from SRS. The waste treatment and/or disposal operations at the Government facilities

(i.e., Hanford Site, Idaho National Environmental and Engineering Laboratory, and

Nevada Test Site) were addressed in DOE (1995c, 1996, 1997a, 1999a).

3.4 Environmental Consequences of the Alternatives

The no-action alternative would create none of the transportation impacts associated with

the proposed action. However, implementation of the no-action alternative would

ultimately result in a shortage of interim storage and disposal space for the five waste
32

forms. This situation would create problems associated with the management of large

and increasing volumes of waste in these storage areas. There would be an increase in

onsite land use to accommodate these larger waste volumes. However, all of this would

likely be in already developed or industrialized areas onsite. In addition, the worker

exposure would be higher because of increased time period in storage. Moreover, storage

without treatment would not be consistent with the agreements between DOE and the

State of South Carolina concerning MLLW management under the SRS Site Treatment

Plan that was developed pursuant to the Federal Facility Compliance Act of 1992.

Violating these agreements could result in fines and penalties for DOE as well as

suspension of the site's RCRA permit.

The alternative to construct and operate treatment and disposal capabilities at SRS would

result in a variety of impacts associated with these facilities. The impacts resulting from

this alternative were addressed in DOE (1995a). These consequences would include land

use, socioeconomic, and human health impacts. The new facilities would require a

minimum of approximately 40 hectares (99 acres) of currently undeveloped land onsite.

Depending upon the specific location for these facilities, other impacts (e.g., hydrological,

ecological, and archaeological) could also be realized. In addition, since the project

planning for such facilities has not even been initiated at this time, the storage of existing

waste inventories and those volumes generated in the near-term would also present

problems similar to those stated for the no-action alternative. The cost of this alternative

would also be significantly greater than the proposed action.

3.5 Cumulative Impacts

The principle cumulative impacts from the proposed action would be those associated

with the offsite transportation of the five waste forms. There would be no change in the

site workforce. No excess LCFs would be expected to result from radiation doses

resulting from non-incident and accident scenarios during transportation of the waste

forms in this proposed action. The human population exposures resulting from this

proposed action are several orders of magnitude less than naturally occurring background

radiation exposure to the same population; thus, no impacts are expected on human

health. Although nine accidents may be expected from transportation of the proposed

action, no fatalities associated with these accidents are expected. In addition, no

disproportionately high adverse environmental justice impacts would be expected from

the proposed action.

4.0 REGULATORY AND PERMITTING PROVISIONS CONSIDERED

DOE policy is to carry out its operations in compliance with all applicable Federal, State

and local laws and regulations, as well as all DOE Orders. This section provides a

discussion of the major regulatory permit programs that might be applicable to the

proposed action.
33

4.1 National Environmental Policy Act of 1969, as amended (42 USC

4321 et seq.)

This EA has been prepared in accordance with NEPA of 1969, as amended, and with the

requirements of the Council of Environmental Quality Regulations for Implementing

NEPA (40 CFR 1500-1508), DOE Regulations (10 CFR 1021), and DOE Order 451.1B.

NEPA, as amended, requires "all agencies of the Federal Government" to prepare a

detailed statement on the environmental effects of proposed "major Federal actions

significantly affecting the quality of the human environment." This EA has been written

to comply with NEPA and assess the environmental effects of the proposed offsite

transportation of certain LLW and MLLW from SRS.

4.2 Waste Shipment Regulations

The vendor must comply with DOT regulation 49 CFR 173 for shipments of radioactive

and hazardous materials and any applicable State regulations for transportation of

radioactive and hazardous materials. The shipping vendor/motor carrier must pass a

pre-trip inspection checklist in conformance with the requirements of the Federal Motor

Carrier Safety Regulations (49 CFR 390-399).

4.3 Occupational Safety and Health Act of 1970, as amended (29 USC

651 et seq.)

The Occupational Safety and Health Act and the regulations thereunder do not directly

apply to Federal agencies or Government–owned corporations. However, Section 19 of

the Act (29 USC 668) requires all Federal agencies to have occupational safety programs

“consistent” with the Occupational Safety and Health Act standards. This requirement

has been applied to Government-owned corporations, as well as agencies, through 5 USC

7902 and Executive Order 12196.

5.0 AGENCIES AND PERSONS CONSULTED

Westinghouse Safety Management Services, LLC. were consulted during the preparation

of this EA.
34

6.0 REFERENCES

Arnett, M. W., and A. R. Mamatey (editors), 1998a. Savannah River Site Environmental

Report for 1998, WSRC-TR-98-000312, Westinghouse Savannah River Company,

Savannah River Site, Aiken, South Carolina.

Arnett, M. W., and A. R. Mamatey (editors), 1998b. Savannah River Site Environmental

Data for 1998, WSRC-TR-98-00314, Westinghouse Savannah River Company,

Savannah River Site, Aiken, South Carolina.

CFR (Code of Federal Regulations), (1999). Shippers – General Requirements for

Shipments and Packagings, Title 49 – Transportation, Section 173.441 Radiation

Level Limitations, Revised 1 October 1999, Washington, DC.

DOE (U. S. Department of Energy), 1987. Final Environmental Impact Statement: Waste

Management Activities for Groundwater Protection, Savannah River Plant, Aiken,

South Carolina, DOE/EIS-0120, Savannah River Operations Office, Aiken, South

Carolina.

DOE (U. S. Department of Energy), 1992. Environmental Assessment: Consolidated

Incineration Facility - Savannah River Site, DOE/EA-0400, Savannah River

Operations Office, Aiken, South Carolina.

DOE (U. S. Department of Energy), 1993. Recommendations for the Preparation of

Environmental Assessments and Environmental Impact Statements, Office of NEPA

Oversight (EH-25), U.S. Department of Energy, Washington, DC.

DOE (U. S. Department of Energy), 1994. Environmental Assessment: Treatment of

M-Area Mixed Wastes at the Savannah River Site, DOE/EA-0918, Savannah River

Operations Office, Aiken, South Carolina.

DOE (U. S. Department of Energy), 1995a. Final Environmental Impact Statement:

Savannah River Site Waste Management, DOE/EIS-0217, Savannah River Operations

Office, Aiken, South Carolina.

DOE (U. S. Department of Energy), 1995b. Record of Decision; Savannah River Site

Waste Management, Savannah River Operations Office, Aiken, SC, Federal Register

60(209):55249-55254.

DOE (U. S. Department of Energy), 1995c. Department of Energy Programmatic Spent

Nuclear Fuel Management and Idaho National Engineering Laboratory

Environmental Restoration and Waste Management Programs Final Environmental

Impact Statement, DOE/EIS-0203-F, Idaho Operations Office, Idaho Falls, Idaho.
35

DOE (U. S. Department of Energy), 1996. Final Environmental Impact Statement for the

Nevada Test Site and Off-Site Locations in the State of Nevada, DOE/EIS-0243,

Nevada Operations Office, Las Vegas, Nevada.

DOE (U. S. Department of Energy), 1997a. Final Waste Management Programmatic

Environmental Impact Statement for Managing Treatment, Storage, and Disposal of

Radioactive and Hazardous Waste, DOE/EIS-0200-F, Office of Environmental

Management, Washington, DC.

DOE (U. S. Department of Energy), 1997b. Supplemental Record of Decision; Savannah

River Site Waste Management, Savannah River Operations Office, Aiken, South

Carolina, Federal Register 62(96):27241-27242.

DOE (U. S. Department of Energy), 1998a. Environmental Assessment for the Tritium

Facility Modernization and Consolidation Project at the Savannah River Site,

DOE/EA-1222, Savannah River Operations Office, Aiken, South Carolina.

DOE (U. S. Department of Energy), 1998b. Environmental Assessment for the

Construction, Operation, and Decommissioning of the Waste Segregation Facility at

the Savannah River Site, DOE/EA-1229, Savannah River Operations Office, Aiken,

South Carolina.

DOE (U. S. Department of Energy), 1998c. Environmental Assessment for the Reuse of

TNX as a Multi-Purpose Pilot Plant Campus at the Savannah River Site,

DOE/EA-1231, Savannah River Operations Office, Aiken, South Carolina.

DOE (U. S. Department of Energy), 1998d. NEPA Values Impact Assessment:

Remediation of the Chemicals, Metals, and Pesticides Pits at the Savannah River Site,

DOE/VIA-0001, Savannah River Operations Office, Aiken, South Carolina.

DOE (U. S. Department of Energy), 1999a. Advanced Mixed Waste Treatment Project

Final Environmental Impact Statement, DOE/EIS-0290, Idaho Operations Office,

Idaho Falls, Idaho.

DOE (U. S. Department of Energy), 1999b. Radioactive Waste Management Manual,

DOE M 435.1-1, Office of Environmental Management, Washington, DC.

DOE (U. S. Department of Energy), 2000a. Record of Decision for the Department of

Energy’s Waste Management Program: Treatment and Disposal of Low-level Waste

and Mixed Low-level Waste; Amendment of the Record of Decision for the Nevada

Test Site, Federal Register 65(38):10061-10066.

DOE (U. S. Department of Energy), 2000b. Savannah River Site, Spent Nuclear Fuel

Management Final Environmental Impact Statement, DOE/EIS-0279, Savannah

River Operations Office, Aiken, South Carolina.
36

DOT (U. S. Department of Transportation), 1989. Accidents Reported by Motor Carriers

of Property 1989, FHWA/MC-92/018, U.S. Department of Transportation,

Washington, DC.

DOT (U. S. Department of Transportation), 1992. 1990 National Personal

Transportation Survey, Federal Highway Administration, Washington, DC.

DOT (U. S. Department of Transportation), 1999a. Railroad Safety Statistics: Annual

Report 1998, Federal Railroad Administration, Office of Safety Analysis, U. S.

Department of Transportation, Washington, DC.

DOT (U. S. Department of Transportation), 1999b. Traffic Safety Facts 1998: A

Compilation of Motor Vehicle Crash Data from the Fatality Analysis Reporting

System and the General Estimates System, National Highway Traffic Safety

Administration, National Center for Statistics and Analysis, U. S. Department of

Transportation, Washington, DC.

Hang, P., 2000. National Environmental Policy Act (NEPA) Transportation Analysis (U),

WSMS-SAE-00-0187, Westinghouse Safety Management Solutions LLC, Aiken,

South Carolina.

Hang, P., and K. R. O’Kula, 2000. Revised Transportation Risk Evaluation for Offsite

Waste Shipment Options, WSMS-SAE-00-0270, Westinghouse Safety Management

Solutions LLC, Aiken, South Carolina.

Hang, P., and D. C. Thoman, 2000. Consequence Analysis of Off Site Transportation of

Solid Waste (U), S-CLC-G-00185 Rev. 2., Westinghouse Safety Management

Solutions LLC, Aiken, South Carolina.

HNUS (Halliburton NUS Environmental Corporation), 1997. Socioeconomic

Characteristics of Selected Counties and Communities Adjacent to the Savannah

River Site, June 1997, Halliburton NUS Corporation, Aiken, South Carolina.

Jannik, G. T., 2001. Volumetric Dilution Assessment of an Acute Pu-239 Aqueous

Release (U), SRT-EST-2001-0000-114, Westinghouse Savannah River Company,

Aiken, South Carolina.

Johnson, P. E., D. S. Joy, D. B. Clarke, and J. M. Jacobi, 1993. Highway 3.1 - An

Enhanced Highway Routing Model: Program Description, Methodology, and

Revised User's Manual, ORNL/TM-12124, U.S. Department of Energy, Washington,

DC.

Kathren, R. L., 1984. Radioactivity in the Environment: Sources, Distribution, and

Surveillance, Harwood Academic Publishers, Reading, United Kingdom.
37

Maheras, S. J. and H. K. Pippen, 1995. Validation of the Transportation Computer Codes

HIGHWAY, INTERLINE, RADTRAN 4, and RISKIND, DOE/ID-10511, Idaho

National Engineering and Environmental Laboratory, Idaho Falls, Idaho.

Neuhauser, K. S., and F. L. Kanipe, 1992. RADTRAN 4, Volume III: User Guide,

SAND89-2370, Sandia National Laboratories, Albuquerque, New Mexico.

Neuhauser, K. S., and F. L. Kanipe, 1995. RADTRAN 4, Volume II: Technical Manual

Revision 1, SAND89-2370, Sandia National Laboratories, Albuquerque, New

Mexico.

O’Kula, K. R., 2000. Non-Radiological NEPA Transportation Analysis: New Case

Supplement, WSMS-SAE-00-0196, Westinghouse Safety Management Solutions

LLC, Aiken, South Carolina.

Thoman, D. C., 2000. The Source Term For Use in the NEPA Transport Analysis (U),

S-CLC-G-00183, Rev. 2., Westinghouse Safety Management Solutions LLC, Aiken,

South Carolina.

White, T. L., 2000. Dose Rate Results Supporting NEPA Transportation Analysis,

WSMS-CRT-00-0108, Westinghouse Safety Management Solutions LLC, Aiken,

South Carolina.

WSMS (Westinghouse Safety Management Solutions, LLC), 2000. Recalculation of Risk

Using Mercury, Nevada Termination Point, Aiken, South Carolina.

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SWD-SWE-99-0063, Rev. 1, Westinghouse Savannah River Company, Aiken, South

Carolina.
38

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A-1

APPENDIX A

Glossary
A-2

GLOSSARY

The following is a glossary of definitions of technical terms found within the text of this

document:

Atomic Energy Act of 1954 – A Federal statute that, along with other related legislation

(including the Energy Reorganization Act of 1974 and the Department of Energy

Organization Act of 1977), provides the U. S. Department of Energy with the authority

for developing generally applicable standards for protecting the environment from

radioactive materials.

Background Dose – Radiation dose from cosmic sources, naturally occurring radioactive

materials, including radon (except as a decay product of source or special nuclear

material), and global fallout as it exists in the environment from the testing of nuclear

explosive devices.

Bounding – In the context of accident analysis, bounding is a term used to identify

conservative assumptions that will likely overestimate actual risks or consequences.

Cancer – A group of diseases characterized by uncontrolled cellular growth. Increased

incidence of cancer can be caused by exposure to radiation or chemicals at sufficient

concentrations and exposure durations.

Code of Federal Regulations (CFR) – All Federal regulations in force are published in

codified form in the Code of Federal Regulations.

Contact-Handled Waste – Waste with a surface dose rate that does not exceed 200

millirem per hour.

Contamination – The deposition of unwanted radioactive or hazardous material on the

surfaces of structures, areas, objects, or personnel.

Cradle-to-Grave – In the context of waste management, cradle-to-grave means from the

time of generation through permanent disposal.

Cumulative Impact - The impact on the environment that results from the incremental

impact of the action when added to other past, present, and reasonably foreseeable future

actions. Cumulative impacts can result from individually minor but collectively

significant actions taking place over a period of time.

Curie – The basic unit used to describe the intensity of radioactivity in a sample of

material. The curie is equal to 37 billion disintegrations per second, which is

approximately the rate of decay of 1 gram of radium. A curie is also a quantity of any

radionuclide that decays at a rate of 37 billion disintegrations per second.
A-3

Decommissioning – The process of removing a facility from operation, followed by

decontamination, entombment, dismantlement, or conversion to another use.

Decontamination – The actions taken to reduce or remove substances that pose a

substantial present or potential hazard to human health or the environment, such as

radioactive contamination from facilities, soil, or equipment by washing, chemical action,

mechanical cleaning, or other techniques.

Dose (of Radiation Dose) – The amount of energy deposited in body tissue as result of

radiation exposure.

Dose Equivalent - The product of the absorbed dose in the tissue or organ of interest, the

applicable quality factor(s), and all other necessary modifying factors at the point of

interest.

Dose Rate – The radiation dose from a shipping package delivered per unit time (for

example, rem per year).

Effective Dose Equivalent – The summation of products of the dose equivalent received

by specified tissues (or organs) 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 individuals. 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.

Environmental Impact Statement - A detailed written statement that helps public

officials make decisions that are based on understanding of environmental consequences

and to take actions that protect, restore, and enhance the environment.

Environmental Justice – The fair treatment of people of all races, cultures, and income

with respect to the development, implementation, and enforcement of environmental

laws, regulations, and policies.

Environmental Restoration – Cleanup and restoration of sites, and decontamination and

decommissioning of facilities contaminated with radioactive and/or hazardous substances

during past production, accidental releases, or disposal activities.

Exclusive Use Vehicles - Vehicles that, per a contractual arrangement, would only be

shipping the contracted waste packages, and no other cargo. In addition, that vehicle

would be involved in shipments where the waste packaging/containers are handled by

only the shipper and the receiver. Further, the dose rate for external radiation during

normal transportation must be maintained below the following limits (49 CFR Part 173):

(1) dose of 10 mrem/hr at any point 2 m from the vertical planes projected by the outer

lateral surfaces of the car or vehicle; and (2) dose of 2 mrem/hr in any normally occupied

position in the car or vehicle.
A-4

Federal Facility Compliance Act (FFCAct) – Federal law signed in October 1992

amending the Resource Conservation and Recovery Act. The objective of the FFCAct is

to bring all Federal facilities into compliance with applicable Federal and State hazardous

waste laws, to waive Federal sovereign immunity under those laws, and to allow the

imposition of fines and penalties. The law also requires the U. S. Department of Energy

to submit an inventory of all of its mixed waste and to develop a treatment plan for mixed

wastes.

Hazardous Waste - Wastes that are designated as hazardous by the EPA or State

regulations. Hazardous waste, defined under RCRA, is waste from production or

operation activities that poses a potential hazard to human health or the environment

when improperly treated, stored, or disposed. Hazardous wastes that appear on special

EPA lists or possess at least one of the following characteristics: ignitability, corrosivity,

reactivity, and toxicity.

High-Level Waste – The highly radioactive waste material that results from the

reprocessing of spent nuclear fuel, including liquid waste produced directly from

reprocessing and any solid waste derived from the liquid that contains a combination of

transuranic and fission product nuclides in quantities that require permanent isolation.

High-level waste may include other highly radioactive material that the U. S. Nuclear

Regulatory Commission, consistent with existing law, determines by rule requires

permanent isolation.

Impact – The positive or negative effect of an action (past. present, or future) on the

environment.

Isotope – A variation of an element that has the same number of protons, but a different

weight because the number of neutrons differs from that of its other isotope(s). A given

element may have many isotopes. For example, uranium occurs naturally in three forms:

uranium-234 (142 neutrons), uranium-235 (143 neutrons), and uranium-238 (146

neutrons); each of these isotopes has 92 protons. Various isotopes of the same element

may have different radioactive behaviors – some are highly unstable (that is, they decay

spontaneously and/or emit radiation).

Low-Level Radioactive Waste - Radioactive waste not classified as high-level waste,

transuranic waste, or spent nuclear fuel, or tailing or wastes produced by the extraction or

concentration of uranium or thorium from any ore processed primarily for its source

material content. Test specimens of fissionable material irradiated for research and

development only, and not for the production of power or plutonium, may be classified as

low-level waste, provided the concentration of transuranic elements is less than 100 nCi

per gram.

Mixed Waste - Waste containing both radioactive and hazardous components, as defined

by the Atomic Energy Act and RCRA, respectively.
A-5

Radiation - The emissions, either electromagnetic or particulate, resulting from the

transformation of an unstable atom or nucleus.

Radioactive Waste - Solid, liquid, or gaseous material that contains radioactive nuclides

regulated under the Atomic Energy Act of 1954, as amended, and of negligible economic

value considering costs of recovery.

Record of Decision - A public document that explains which alternative will be selected

from the area of concern.

Rem (Roentgen Equivalent Man) – A unit of individual dose of absorbed ionizing

radiation used to measure the effect on human tissue. The dosage of an ionizing radiation

that will cause the same biological effect as one roentgen of x-ray or gamma-ray

exposure.

Resource Conservation and Recovery Act (RCRA) – A Federal law addressing the

management of waste. Subtitle C of the law addresses hazardous waste under which a

waste must either be “listed” on one of the U. S. Environmental protection Agency’s

(EPA’s) hazardous waste lists or meet one of EPA’s four hazardous characteristics of

ignitability, corrosivity, reactivity, or toxicity, as measured using the toxicity

characterization leaching procedure. Cradle-to-grave mangement of wastes classified as

RCRA hazardous wastes must meet stringent guidelines for environmental protection as

required by law. These guidelines include regulation of transportation, treatment, storage,

and disposal of RCRA-defined hazardous waste. Subtitle D of the law addresses the

mangement of nonhazardous, nonradioactive solid waste, such as municipal wastes.

Significant - The common meaning of significant is “having or likely to have

considerable influence or effect”. As it pertains to NEPA, “significant” requires that both

context and intensity be considered in evaluating impacts (40 CFR 1508). Context could

include surrounding circumstances such as society as a whole, the affected region, the

affected interests, and the locality. Intensity refers to the severity of the impact, and

requires that several factors be evaluate. These factors may include the degree to which

public health and safety are affected, unique characteristics of the geographic area, and

others.

Spent Nuclear Fuel – Fuel that has been withdrawn from a nuclear reactor after

irradiation, the constituent elements of which have not been separated.

Transportation Accident – In a mobile event, the harmful effects of an unplanned event

on the human environment with respect to both safety and health.
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B-1

APPENDIX B

Response to Public Comments
B-2

Table of Contents

Number Title Page

Section I Introduction B-3

Section II Public Comments and DOE-SR Responses B-5

L1 Savannah River Site’s Citizen’s Advisory Board B-6

DOE-SR Response B-9

L2 City of Las Vegas B-12

DOE-SR Response B-15

L3 State of Missouri, Office of Administration B-17

L4 State of Tennessee, Department of Environment

and Conservation B-18

DOE-SR Response B-20

L5 Oak Ridge Reservation Local Oversight Committee B-23

DOE-SR Response B-27

L6 State of New Mexico, Environment Department B-32

DOE-SR Response B-34

L7 State of Nevada, Agency for Nuclear Projects B-37

DOE-SR Response B-41

L8 State of Washington, Department of Ecology B-46

DOE-SR Response B-48

L9 State of Texas, Office of the Governor B-51

DOE-SR Response B-57

L10 City of Oak Ridge, Tennessee B-59

DOE-SR Response B-61

L11 Clark County, Nevada B-64

DOE-SR Response B-67

L12 North Carolina, Department of Administration B-71

DOE-SR Response B-77

L13 State of Tennessee, Office of the Governor B-80

DOE-SR Response B-84

L14 State of South Carolina, State Budget and Control

Board B-89
B-3

Section I. Introduction

In early 1999, the Department of Energy (DOE) Savannah River Operations Office

decided to initiate the preparation of an environmental assessment (EA) for the proposed

offsite transportation of certain low-level radioactive waste and mixed (i.e., hazardous

and radioactive) low-level radioactive waste from the Savannah River Site (SRS). This

document preparation effort was implemented in compliance with the National

Environmental Policy Act (NEPA) of 1969, as amended, the requirements of the Council

on Environmental Quality Regulations for Implementing NEPA (40 CFR 1500-1508),

and the DOE Regulations for Implementing NEPA (10 CFR 1021). The assessment of

environmental consequences of Federal actions that may affect the quality of the human

environment is required under NEPA. Based on the potential for impacts described in the

resultant document, DOE would either publish a Finding of No Significant Impact

(FONSI) or prepare an environmental impact statement (EIS).

An initial internal scoping meeting was held on March 25, 1999, for this EA pursuant to

the guidelines specified in the Savannah River Site NEPA Program Quality

Assurance Plan Preparation and Review: Environmental Assessments, NEPA

Values Impact Assessments, Environmental Impact Statements (U)

(WSRC-RP-2000-00283). The proposed action, alternatives, specific assessment studies

needed, project time frame, and public participation were discussed at that meeting.

Notification was sent to the States of South Carolina and Georgia on June 17, 1999,

regarding DOE’s intent to prepare this EA. On June 25, 1999, a notice was published in

the SRS Environmental Bulletin announcing to the general public DOE’s intent to

prepare this EA. Additional notifications to States along the potential routes were mailed

out on July 7, 1999. Over the next 12 months, the status of the preparation of the draft

EA was reported in the SRS Environmental Bulletin.

On June 27, 2000, the Waste Management Committee (WMC) of the SRS Citizen’s

Advisory Board (CAB) discussed the proposed action in the EA as part of the planned

meeting agenda. This action had been requested by one the WMC’s members. As a

follow-up to that meeting, several members of the CAB’s WMC met with DOE on

August 24, 2000, to discuss the results of the WMC’s June meeting. To address

questions that the WMC had on the proposed action in the EA, a presentation was made

before the WMC during a meeting on September 11, 2000. Based on that presentation,

the CAB issued Recommendation No. 131 on the draft EA, requesting three clarifications

on or corrections to the document.

The preliminary draft EA was completed by August 2000. As required in 10 CFR 1021,

the predecisional draft EA was transmitted to American Indian Tribes, the host States of

South Carolina and Georgia, States along the potential shipping routes, and potentially

interested Federal and State agencies on September 13, 2000, for review and comment.

The associated State comment period, scheduled for 14-30 days as per DOE NEPA

regulations, began on September 20, 2000, the date of receipt of the draft EA transmittal
B-4

package by both States. The availability of the predecisional draft EA for the proposed

action was announced in the October 18, 2000, issue of the SRS Environmental

Bulletin, which had been distributed to several thousand stakeholders in both South

Carolina and Georgia, including Federal, State, and local agencies, Government officials,

and members of environmental interest groups as well as interested citizens. At the

request of several State agencies, the public comment period was extended to allow for

the submittal of additional comments. This comment period was closed on November 30,

2000, after the receipt of those additional comment letters. A total of fourteen responses

were received, ranging in length from one to seven pages. State and local agency

responses numbered ten. The remaining two were provided by private sector stakeholder

groups.

The remainder of this appendix is contained in one section. That section (i.e., Section II)

presents the unedited text of all letters received and the direct response to each question

or comment raised or references another location where the issue has already been

addressed in the EA.
B-5

Section II. Public Comments and DOE-SR Responses

The following pages include the public comment letters received on the draft EA and the

DOE-SR letters sent in response to those comment letters. These documents are arranged

with the comments first and the associated response letter immediately following.
B-6

Comment L1. Page 1 of 3.
B-7

Comment L1. Page 2 of 3.
B-8

Comment L1. Page 3 of 3.
B-9

Comment L1 Response. Page 1 of 3.
B-10

Comment L1 Response. Page 2 of 3.
B-11

Comment L1 Response. Page 3 of 3.
B-12

Comment L2. Page 1 of 3.
B-13

Comment L2. Page 2 of 3.
B-14

Comment L2. Page 3 of 3.
B-15

Comment L2 Response. Page 1 of 2.
B-16

Comment L2 Response. Page 2 of 2.
B-17

Comment L3. Page 1 of 1.
B-18

Comment L4. Page 1 of 2.
B-19

Comment L4. Page 2 of 2.
B-20

Comment L4 Response. Page 1 of 3
B-21

Comment L4 Response. Page 2of 3
B-22

Comment L4 Response. Page 3 of 3.
B-23

Comment L5. Page 1 of 4.
B-24

Comment L5. Page 2 of 4.
B-25

Comment L5. Page 3 of 4.
B-26

Comment L5. Page 4 of 4.
B-27

Comment L5 Response. Page 1 of 5.
B-28

Comment L5 Response. Page 2 of 5.
B-29

Comment L5 Response. Page 3 of 5.
B-30

Comment L5 Response. Page 4 of 5.
B-31

Comment L5 Response. Page 5 of 5.
B-32

Comment L6. Page 1 of 2.
B-33

Comment L6. Page 2 of 2.
B-34

Comment L6 Response. Page 1 of 3.
B-35

Comment L6 Response. Page 2 of 3.
B-36

Comment L6 Response. Page 3 of 3.
B-37

Comment L7. Page 1 of 4.
B-38

Comment L7. Page 2 of 4.
B-39

Comment L7. Page 3 of 4.
B-40

Comment L7. Page 4 of 4.
B-41

Comment L7 Response. Page 1 of 5.
B-42

Comment L7 Response. Page 2 of 5.
B-43

Comment L7 Response. Page 3 of 5.
B-44

Comment L7 Response. Page 4 of 5.
B-45

Comment L7 Response. Page 5 of 5.
B-46

Comment L8. Page 1 of 2.
B-47

Comment L8. Page 1 of 2.
B-48

Comment L8 Response. Page 1 of 3.
B-49

Comment L8 Response. Page 2 of 3.
B-50

Comment L8 Response. Page 3 of 3.
B-51

Comment L9. Page 1 of 6.
B-52

Comment L9. Page 2 of 6.
B-53

Comment L9. Page 3 of 6.
B-54

Comment L9. Page 4 of 6.
B-55

Comment L9. Page 5 of 6.
B-56

Comment L9. Page 6 of 6.
B-57

Comment L9 Response. Page 1 of 2.
B-58

Comment L9 Response. Page 2 of 2.
B-59

Comment L10. Page 1 of 2.
B-60

Comment L10. Page 2 of 2.
B-61

Comment L10 Response. Page 1 of 3.
B-62

Comment L10 Response. Page 2 of 3.
B-63

Comment L10 Response. Page 3 of 3.
B-64

Comment L11. Page 1 of 3.
B-65

Comment L11. Page 2 of 3.
B-66

Comment L11. Page 3 of 3.
B-67

Comment L11 Response. Page 1 of 4.
B-68

Comment L11 Response. Page 2 of 4.
B-69

Comment L11 Response. Page 3 of 4.
B-70

Comment L11 Response. Page 4 of 4.
B-71

Comment L12. Page 1 of 6.
B-72

Comment L12. Page 2 of 6.
B-73

Comment L12. Page 3 of 6.
B-74

Comment L12. Page 4 of 6.
B-75

Comment L12. Page 5 of 6.
B-76

Comment L12. Page 6 of 6.
B-77

Comment L12 Response. Page 1 of 3.
B-78

Comment L12 Response. Page 2 of 3.
B-79

Comment L12 Response. Page 3 of 3.
B-80

Comment L13. Page 1 of 4.
B-81

Comment L13. Page 2 of 4.
B-82

Comment L13. Page 3 of 4.
B-83

Comment L13. Page 4 of 4.
B-84

Comment L13 Response. Page 1 of 5.
B-85

Comment L13 Response. Page 2 of 5.
B-86

Comment L13 Response. Page 3 of 5.
B-87

Comment L13 Response. Page 4 of 5.
B-88

Comment L13 Response. Page 5 of 5.
B-89

Comment L14. Page 1 of 7.
B-90

Comment L14. Page 2 of 7.
B-91

Comment L14. Page 3 of 7.
B-92

Comment L14. Page 4 of 7.
B-93

Comment L14. Page 5 of 7.
B-94

Comment L14. Page 6 of 7.
B-95

Comment L14. Page 7 of 7.
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