## 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 SITEiii This page is intentionally left blankiii 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 Commentsiv 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 Pu 239into 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). 29v 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. 9vi 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 biphenylvii LIST OF ABBREVIATIONS/ACRONYMS (continued)
Pu 239 - 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 U 235 - Uranium-235 U 236 - 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 - yearviii This page is intentionally left blank1 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 contaminated5 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 of10 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 of11 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 the13 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 Pu 239 per gram for volumes corresponding to 4.41E+06 ft 3 and 45,000 drums (3.31E+05 ft 3 ), respectively. The fourth case considers 5000 drums of liquid with a concentration of 99 nCi Pu 239per 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 Pu 239per 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 U 235 1.86E-01 6.53E-05 1.63E-02 3.93E-03
U 238 9.59E+00 3.36E-03 8.41E-01 2.02E-01
2 Pu 239 1.90E+04 3.16E-02 8.6E+00 1.90E+00 a
3 Pu 239 1.42E+03 3.16E-02 N/Ab 1.90E+00
4 Pu 239 1.65E+02 3.31E-02 N/Ab 1.97E+00 5 Pu 239 1.97E+01 N/Ac N/Ab 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 Trainloada Total Number of Trainloads Drums per Truck Total Number of Truckloads

1 250 2,850 1 60 50 2 57 m 3 (2,000 ft 3 ) 1,132.80 m 3 (~ 40,000 ft 3 ) 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

aAssuming a maximum of 20 railcars per trainload (Hang 2000, Hang and Thoman 2000) bCase 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 meters a 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

aExcept for Case 5 tanker truck19 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+0521 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 NA c NA c NA c NA c NA c Case 2 – Rail NA c NA c NA c NA c NA c 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+0623 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 NA c NA c NA c Case 2 – Rail NA c NA c NA c 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

aBased on an average individual background dose of 300 mrem/yr (Kathren, 1984) bThere is no rail access to the Nevada Test Site.

cRail 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 Pu 239(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 ft 3 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 Pu 239 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 NA a NA a NA a Case 2 – Rail NA a NA a NA a 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-0225 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

aThere 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 Pu 239in the various receiving streams following the accident re provided in Table 3-10. These estimated concentrations of Pu 239would 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 Pu 239in the receiving streams would be transported downstream and further diluted with the distance traveled. The Pu 239BCG equating to 1 rad from an assumed 2-hour exposure duration is 2,400 pCi/L. All estimated Pu 239concentrations 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 Pu 239BCG equating to 400 rad from a 2-hour exposure duration is 960,000 pCi/L. The estimated Pu 239concentrations 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 Pu 239BCG equating to 550 rad from a 2-hour exposure duration is 1,320,000 pCi/L. The estimated Pu 239concentrations in the 1 and 526 Table 3-10. Results of volumetric dilution assessment for an acute release of Pu 239into surface water streams (Jannik 2001).
Receiving Stream Flow rate (CFS) Receiving Stream Flow rate (L/s) Dilution Factor Pu 239 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

aObservable detrimental effects would occur bLD-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-0328 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 Pu 239(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 waste32 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. Zecha, D. J., 2000. National Environmental Policy Act (NEPA) Transportation Analysis, SWD-SWE-99-0063, Rev. 1, Westinghouse Savannah River Company, Aiken, South Carolina.38 This page is intentionally left blankA-1 

# APPENDIX A GlossaryA-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.A-6 This page is intentionally left blankB-1 

# APPENDIX B Response to Public CommentsB-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-89B-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 Bulletinannouncing 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 transmittalB-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 3B-21 Comment L4 Response . Page 2of 3B-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.B-96 This page is intentionally left blank