B–1

APPENDIX B 

IMPACT ASSESSMENT METHODOLOGY 

This appendix briefly describes the methods used to assess the potential direct, indirect, and 

cumulative effects of the alternatives in this Long-Term Management and Storage of Elemental 

Mercury Environmental Impact Statement. Included are impact assessment methods for land use and 

visual resources; geology and soils; water resources; meteorology, air quality, and noise; ecological 

resources; cultural and paleontological resources; site infrastructure; waste management; 

socioeconomics; environmental justice; and cumulative impacts. Each section includes a description of 

the affected resource, including the associated region of influence and the impact assessment method. 

Detailed descriptions of the methods for the evaluation of occupational and public health and safety 

and ecological risk from normal operations, facility accidents, and mercury transportation are presented 

separately in Appendix D. 

B.1 INTRODUCTION 

Methods for assessing environmental impacts vary for each resource area (discipline). In addition, 

disciplines are analyzed in a manner commensurate with their importance and the expected level of 

impact on them under a specific alternative—the sliding-scale assessment approach. This is consistent 

with U.S. Department of Energy (DOE) guidance contained in its Recommendations for the Preparation 

of Environmental Assessments and Environmental Impact Statements (known as The Green Book) 

(DOE 2004:1, 2, 19, 20), in which DOE expands on Council on Environmental Quality (CEQ) 

instructions for preparing environmental impact statements (EISs) (40 CFR 1502.2) by stating that 

impacts should be discussed in proportion to their significance and specifically recommending the use of 

the sliding scale for impact identification and quantification. 

For air quality, for example, pollutant emissions from the mercury1

 storage activities were evaluated for 

their effect on ambient concentrations and compliance with ambient air quality standards. Comparison 

with regulatory standards is a commonly used method for benchmarking environmental impacts and is 

conducted—where appropriate—to provide perspective on the magnitude of identified impacts. Impacts 

in all resource areas were analyzed consistently; that is, the impact values were estimated using a 

consistent set of input variables and computations. Moreover, efforts were made to ensure that 

calculations in all areas used accepted protocols and up-to-date models. 

In this Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement

(Mercury Storage EIS), impacts are typically described in terms of intensity and duration. The term 

“impact,” when used in this EIS, refers to adverse, long-term impacts, unless otherwise stated. A set of 

standardized impacts terminology was developed for use. Beneficial impacts are those that would 

improve current conditions, while adverse impacts would degrade current conditions. Intensities are 

categorized as negligible, minor, moderate, or major, with durations classified as either short term (less 

than or equal to 5 years) or long term. These categories are defined as follows: 

 Negligible: There would be little or no impact on the resource in the region of influence (ROI). 

Where slight impacts occur, they would be relatively short term, and/or the impacts would not be 

of any perceptible consequence over the long term. 

 Minor: Effects on the resource in the ROI would be detectable, although localized, relatively 

small, and of little long-term consequence to the overall makeup of the ROI. Resource loss, 

consumption, or change would be a small percentage (i.e., generally between 1 and 10 percent) of 

the resource or resource indicator in the ROI. There would be no loss, damage, or alteration of 

 

1

 Unless indicated otherwise, elemental mercury is referred to hereafter simply as “mercury” in this environmental impact 

statement. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

B–2

any rare, unique, special status, or other legally protected resources (e.g., threatened and 

endangered species or critical habitat). 

 Moderate: Effects on the resource would be readily detectable, generally long term, and localized; 

the impact on the ROI would be moderate. Resource loss, consumption, or change would be a 

sizable percentage (i.e., generally between 10 and 40 percent) of the resource or resource 

indicator in the ROI. Such impacts may prompt consideration of specific project design changes 

and/or compensatory mitigation for resource loss. Moderate effects may also denote resource 

conditions that are not expected to affect or impair project implementation but that could prompt 

consideration of special design or construction mitigation. 

 Major: Effects on the resource would be obvious and long term and would have substantial 

consequences; the impact on the ROI would be major. Either substantial project design changes 

and/or compensatory mitigation for resource loss would be evaluated. Major effects may also 

denote resource conditions (e.g., presence of active geologic fault) prompting consideration of 

substantial changes in project implementation in terms of location and/or special design or 

construction mitigation. 

These terms are used for the analysis of impacts for all resources areas, exclusive of occupational and 

public health and safety and ecological risk, which are presented separately in Appendix D. The ROIs for 

each resource are described in the following sections. 

B.2 LAND USE AND VISUAL RESOURCES 

B.2.1 Land Use 

B.2.1.1 Description of Affected Resources 

Analysis of land use includes the land on and adjacent to each candidate mercury storage site, the physical 

features that influence current or proposed uses, pertinent land use plans and regulations, and land 

ownership and availability. The ROI for land use varies due to the extent of land ownership, adjacent 

land use patterns and trends, and other geographic or safety considerations. 

B.2.1.2 Description of Impact Assessment 

The amount of land disturbed and conformity with existing land use were considered to evaluate potential 

impacts (see Table B–1). The Mercury Storage EIS evaluates the impacts of mercury storage alternatives 

on land use within each candidate mercury storage site, adjacent Federal or state lands, adjacent 

communities, and wildlife or resource areas. The analysis focuses on the net land area affected, its 

relationship to conforming and nonconforming land uses, current growth trends, and other factors 

pertaining to land use. Land use impacts could vary from site to site, depending on existing facility land 

use configurations, adjoining land uses, and proximity to residential areas. 

Evaluation of existing land use at each of the potentially affected sites entailed review of available facility 

land use plans. Where land adjacent to the candidate site is managed by local government, applicable 

community general plans, zoning ordinances, and population growth trend data were reviewed. Where 

such land is managed under the jurisdiction of a Federal or state land management agency, the respective 

agency resource management plans and policies were reviewed. 

Total additional land area requirements include those areas to be occupied by the footprint of facility 

modifications or new facilities in conjunction with any additional paved roads, parking areas, graveled 

areas, construction laydown areas, as well as land graded and cleared of vegetation to support the 

proposed action. 
Impact Assessment Methodology 

B–3

Table B–1. Land Use and Visual Resources Impact Assessment Protocol 

Required Data 

Resource Affected Environment Alternative Measure of Impact 

Land use Areal extent of site 

location affected and 

existing land use 

designations 

Facility acreage 

requirements (hectares); 

location of facility on the 

site; expected 

modifications of site 

activities and uses to 

accommodate the 

alternatives 

Area converted to project 

use and incompatibility 

with existing or future 

land use 

Visual resources Current appearance of 

mercury storage site and 

current visual resource 

management classification 

Location of facility on the 

site; facility dimensions 

and appearance 

Change in appearance 

of mercury storage site and 

current visual resource 

management classification 

B.2.2 Visual Resources 

B.2.2.1 Description of Affected Resources 

Visual resources are the natural and manmade features that give a particular landscape its character and 

aesthetic quality. Landscape character is determined by the visual elements of form, line, color, and 

texture. All four elements are present in every landscape; however, they exert varying degrees of 

influence. The stronger the influence exerted by these elements in a landscape, the more interesting the 

landscape. The ROI for visual resources includes the geographic area from which the mercury storage 

facilities may be seen. 

B.2.2.2 Description of Impact Assessment 

Visual resource assessments are based on a description of the viewshed and the U.S. Bureau of Land 

Management’s visual resource management classification (DOI 1986). A qualitative visual resource 

analysis was conducted to determine whether disturbances associated with mercury storage activities 

would alter the visual environment of the candidate mercury storage sites. Classifications of visual 

contrast settings are provided in Table B–2. Classifications were derived from an inventory of scenic 

qualities, sensitivity levels, and distance zones for particular areas. 

Table B–2. U.S. Bureau of Land Management Visual Resources Classifications 

Classification Visual Settings 

Class I Very limited management activity; natural ecological change. 

Class II Management activities may be seen, but should not attract the attention of the casual 

observer, such as solitary small buildings or dirt roads. 

Class III Management activities may attract attention, but should not dominate the view of the casual 

observer; the natural landscape still dominates buildings, utility lines, and secondary roads. 

Class IV Management activities may dominate the view and major focus of viewer attention, such as 

clusters of two-story buildings, large industrial or office complexes, primary roads, and 

limited clearcutting for utility lines or ground disturbances. 

Source: DOI 1986:6, 7. 

The visual resources analysis focuses on the degree of contrast between the proposed action and the 

surrounding landscape, the location and sensitivity levels of public vantage points, and the visibility of the 

proposed action from the vantage points. The distance from a vantage point to the affected area and 

atmospheric conditions were also taken under consideration, as distance and haze can diminish the degree 

of contrast and visibility. A qualitative assessment of the degree of contrast between proposed facility 

construction or modification and operations and the existing visual landscape is presented, as applicable. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

B–4

B.3 GEOLOGY AND SOILS 

B.3.1 Description of Affected Resources 

Geologic resources encompass consolidated and unconsolidated earth materials, including rock and 

mineral assets, such as ore and aggregate materials (e.g., sand, gravel), and fossil fuels, such as coal, oil, 

and natural gas. Geologic conditions include hazards such as earthquakes, faults, volcanoes, landslides, 

sinkholes, and other conditions leading to land subsidence and unstable soils. Soil resources include the 

loose surface materials of the earth in which plants grow, usually consisting of mineral particles from 

disintegrating rock, organic matter, and soluble salts. Certain soils are important farmlands that are 

designated as such by the U.S. Department of Agriculture Natural Resources Conservation Service. 

Important farmlands include prime farmland, unique farmland, and other farmland of statewide or local 

importance, as defined in “Prime and Unique Farmlands: Identification of Important Farmlands” 

(7 CFR 657.5), that may be subject to the Farmland Protection Policy Act (7 U.S.C. 4201 et seq.). 

Geology and soils were considered with respect to those attributes and geologic and soil resources that 

could be affected by the alternatives, as well as those geologic conditions that could affect each 

alternative and associated facility site. The ROI for geology and soils includes the project site and nearby 

offsite areas subject to disturbance by mercury management activities during facility construction or 

modification and operations and those areas beneath an existing or new facility that would remain 

inaccessible for the life of the facility. Conditions that could affect the integrity and safety of the mercury 

storage facilities under the alternatives include large-scale geologic hazards (e.g., earthquakes, volcanic 

activity, landslides, land subsidence, and erosional processes) and local hazards associated with the 

site-specific attributes of the soil and bedrock beneath candidate sites. Thus, the area in which these 

geologic conditions exist is also used to define the ROI for this resource area. 

B.3.2 Description of Impact Assessment 

Facility construction or modification and operational activities under each of the mercury storage 

alternatives were considered from the perspective of impacts on specific geologic resources and soil 

attributes to encompass the consumption of geologic resources. Key factors in the analysis were the 

(1) land area to be disturbed and geologic resources consumed to support the alternatives considered; 

(2) depth and extent of excavation work to support facility construction and/or 

refurbishment/modification; (3) land areas occupied during operations; and (4) identification of unstable 

geologic strata (such as soils or sediments prone to subsidence, liquefaction, shrink-swell, or erosion) 

(see Table B–3). 

The geology and soils impact analysis also considered risks to proposed facilities (existing, new, or 

modified/refurbished) from large-scale geologic hazards such as faulting and earthquakes, lava extrusions 

and other volcanic activity, landslides, and sinkholes (i.e., conditions that tend to affect broad expanses of 

land). In general, the facility hazard assessment was based on the presence of any identified hazard and 

the distance of the facilities from it. This element of the assessment includes collection of site-specific 

information regarding the potential for impacts on site facilities from local and large-scale geologic 

conditions. Historical seismicity within a given radius of the candidate mercury storage sites was 

reviewed, and potential earthquake source areas (including proximity to potentially active geologic faults) 

were identified as a means of assessing the potential for future earthquake activity and seismic risk. 
Impact Assessment Methodology 

B–5

Table B–3. Geology and Soils Impact Assessment Protocol 

Required Data 

Resource Affected Environment Alternative Measure of Impact 

Geologic hazards Presence of geologic 

hazards within the region 

of influence 

Location of facility Potential for damage to 

facility 

Mineral and energy 

resources 

Presence of any rare and/or 

valuable mineral or energy 

resources on the site 

location and availability of 

geologic resources within 

the region of influence 

Location of facility and 

projected resource 

demands 

Potential to consume, 

destroy, or render 

resources inaccessible 

Important farmland 

soils 

Presence of prime or other 

important farmland soils 

near the site location 

Location of facility Conversion of important 

farmland soils to 

nonagricultural use 

Earthquakes are described in this Mercury Storage EIS in terms of classification scheme and parameters, 

as presented in Table B–4. Probabilistic earthquake ground-motion data that include peak (horizontal) 

ground acceleration were specifically evaluated to provide a comparative assessment of seismic hazard. 

Estimates of probabilistic ground motion at a particular location consider earthquake-shaking at all future 

possible earthquake magnitudes and at all possible distances from the location (USGS 2009a). Peak 

ground acceleration indicates what an object on the ground would experience during an earthquake and 

approximates what a short structure would be subjected to in terms of horizontal force (USGS 2009b). 

Peak ground acceleration is one parameter used by the U.S. Geological Survey National Seismic Hazard 

Mapping Project. The U.S. Geological Survey hazard maps have been adapted for use in the seismic 

design portions of the International Building Code (Petersen 2008; USGS 2009b, 2009c). 

DOE Order 420.1B and its companion guide (DOE Guide 420.1-2) require that nuclear and nonnuclear 

DOE facilities be designed, constructed, and operated so that the public, workers, and environment are 

protected from the adverse impacts of natural phenomena hazards, including earthquakes. The Order 

stipulates natural phenomena hazards mitigation requirements for DOE facilities and specifically provides 

for reevaluation and upgrade of existing DOE facilities when there is a significant degradation in the 

safety basis for the facility. Standards 1020-2002 and 1023-95 implement DOE Order 420.1B and 

provide criteria for design of new structures, systems, and components, as well as for evaluation, 

modification, or upgrade of existing structures, systems, and components, so that DOE facilities can 

safely withstand the effects of natural phenomena hazards such as earthquakes. The criteria specifically 

reflect adoption of the seismic design and construction provisions and associated seismic hazard maps of 

the International Building Code as the minimum standard for design and evaluation of DOE facilities 

(i.e., for Performance Category 1 and 2 structures, systems, and components). For structures, systems, 

and components requiring a higher level of performance from a safety perspective (i.e., Performance 

Category 3 and 4), a more-rigorous design analysis is required, including performance of a probabilistic 

seismic hazard assessment to determine the design-basis earthquake. 

An evaluation was also performed to estimate requirements for rock, aggregate, soil, and products derived 

from rock and mineral resources used to support mercury storage activities, including facility construction 

or modification and operations. The analysis of impacts on geologic resources also included a 

determination of whether the mercury storage activities under each alternative could destroy or preclude 

the use of valuable rock, mineral, or energy resources. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

B–6

Table B–4. The Modified Mercalli Intensity Scale of 1931, with Generalized Correlations to 

Magnitude, Earthquake Classification, and Peak Ground Acceleration 

Modified 

Mercalli 

Intensitya Observed Effects of Earthquakea Approximate 

Magnitudeb Class 

Peak Ground 

Accelerationc(g)

I Usually not felt except by a very few persons under very 

favorable conditions. Less than 3 Micro Less than 0.0017 

II Felt by only a few persons at rest, especially on the upper 

floors of buildings. 

III 

Felt quite noticeably by persons indoors, especially on upper 

floors of buildings. Many people do not recognize it as an 

earthquake. Standing motorcars may rock slightly. 

Vibrations similar to the passing of a truck. 

3 to 3.9 Minor 0.0017 to 0.014 

IV 

Felt indoors by many; outdoors by few during the day. At 

night, some awakened. Dishes, windows, doors disturbed; 

walls make cracking sounds. Sensation like heavy object 

striking building. Standing motorcars rock noticeably. 

0.014 to 0.039 

V 

Felt by nearly everyone; many awakened. Some dishes and 

windows broken. Unstable objects overturned. Pendulum 

clocks may stop. 

4 to 4.9 Light 

0.039 to 0.092 

VI Felt by all; many frightened. Some heavy furniture moved; a 

few instances of fallen plaster. Damage slight. 5 to 5.9 Moderate 0.092 to 0.18 

VII 

Damage negligible in buildings of good design and 

construction; slight to moderate in well-built ordinary 

structures; considerable damage in poorly built or badly 

designed structures; some chimneys broken. 

6 to 6.9 Strong 0.18 to 0.34 

VIII 

Damage slight in specially designed structures; considerable 

damage in ordinary substantial buildings, with partial 

collapse. Damage great in poorly built structures. Falling 

chimneys, factory stacks, columns, monuments, walls. 

Heavy furniture overturned. 

0.34 to 0.65 

IX 

Damage considerable in specially designed structures; 

well-designed frame structures thrown out of plumb. 

Damage great in substantial buildings, with partial collapse. 

Buildings shifted off foundations. 

0.65 to 1.24 

X Some well-built wooden structures destroyed; most masonry 

and frame structures destroyed with foundations. Rails bent. 

7 to 7.9 Major 

XI Few, if any (masonry) structures remain standing. Bridges 

destroyed. Rails bent greatly. 

XII Damage total. Lines of sight and level are distorted. Objects 

thrown into the air. 

8 and higher Great 

1.24 and higher 

a Intensity is a unitless expression of observed effects of earthquake-produced ground shaking. Effects may vary greatly between locations 

based on earthquake magnitude, distance from the earthquake, and local subsurface geology. The descriptions given are abbreviated from the 

Modified Mercalli Intensity Scale of 1931. b Magnitude is a logarithmic measure of the strength (size) of an earthquake related to the strain energy released by it. There are several 

magnitude “scales” (mathematical formulas) in common use, including local “Richter” magnitude, body-wave magnitude, and surface-wave 

magnitude. Each has applicability for measuring particular aspects of seismic signals and may be considered equivalent within each scale’s 

respective range of validity. For very large earthquakes, the moment magnitude scale provides the best overall measurement of earthquake 

size. c Acceleration is expressed as a factor that should be multiplied by Earth’s gravitational acceleration (g) (i.e., g is equal to 980 centimeters 

[386 inches] per second squared). Given values are correlated to Modified Mercalli Intensity based on measurements of California 

earthquakes (Wald et al. 1999). Site-specific earthquake history, ground motion, and risk assessment data for candidate mercury storage sites 

are presented in Chapter 3. 

Source: Compiled from USGS 2009d, 2009e; Wald et al. 1999. 

Pursuant to the Farmland Protection Policy Act of 1981 (7 U.S.C. 4201 et seq.) and its implementing 

regulations, the presence of important farmland soils, including prime farmland, was also evaluated. This 

act requires agencies to make Farmland Protection Policy Act evaluations part of the National 

Environmental Policy Act process to reduce the conversion of farmland to nonagricultural uses by Federal 

projects and programs. However, otherwise qualifying farmlands in or already committed to urban 

development; lands acquired for a project on or prior to August 4, 1984; and lands acquired or used by a 
Impact Assessment Methodology 

B–7

Federal agency for national defense purposes are exempt from the act’s provisions (7 CFR 658.2 

and 658.3). Based on the foregoing and other factors, none of the candidate mercury storage sites were 

found to have qualifying important farmland soils. 

B.4 WATER RESOURCES 

B.4.1 Description of Affected Resources 

Water resources are the surface and subsurface waters that are suitable for human consumption, aquatic or 

wildlife propagation, agricultural purposes, irrigation, or industrial or commercial purposes. The ROI 

used for water resources encompasses those surface-water and groundwater systems on and adjacent to 

each candidate site that could be impacted by water withdrawals, effluent discharges, and spills or 

stormwater runoff associated with facility construction or modification and operational activities under 

the mercury storage alternatives. 

B.4.2 Description of Impact Assessment 

Analysis of the potential impacts on water resources consisted of comparing site-generated data and best 

available engineering-basis estimates of water use and effluent discharges associated with proposed 

mercury storage activities with applicable regulatory standards, design parameters and standards 

commonly used in the water and wastewater engineering fields, and recognized measures of 

environmental impact. Certain assumptions were made to facilitate the impacts assessment: (1) all water 

supply production and treatment and waste effluent treatment facilities would be available and approved 

by the governing approval authority; (2) the waste effluent treatment facilities would meet the effluent 

limitations imposed by the respective National Pollutant Discharge Elimination System permits and/or the 

state-issued discharge permits; and (3) any stormwater runoff from construction and operations activities 

would be addressed in accordance with the regulations of the appropriate permitting authority. It was also 

assumed that, during construction and other land-disturbing activities, sediment fencing or other erosioncontrol devices would be used to mitigate short-term adverse impacts of sedimentation and, as 

appropriate, stormwater holding ponds would be constructed to lessen the impacts of runoff on surfacewater quality. 

B.4.2.1 Water Use and Availability 

This analysis involved the review of engineering estimates of expected surface-water and/or groundwater 

use and effluent discharge associated with facility construction or modification and operations for each 

alternative and the impacts on local and regional water availability in terms of quantity and quality. 

Impacts on water use and availability were generally assessed by determining changes in the volume of 

current water usage and effluent discharge as a result of the proposed activities. For facilities intending to 

use surface water, no credit was taken for effluent discharges back to surface waters. The impact of 

discharging withdrawn groundwater to surface waters or back to the subsurface was also considered, as 

appropriate. A separate analysis (see below) was performed as necessary to determine the potential for 

impacts of mercury storage activities on ambient surface-water or groundwater quality, based in part on 

the results of the effluent treatment capacity analysis. 

Because water use and withdrawals from water sources were found to be relatively small, and no routine 

effluent discharges (except for uncontaminated stormwater) from the candidate mercury storage sites and 

facilities are expected, additional detailed analyses to include comparison with design capacity of existing 

water supply systems or effluent treatment facilities were not performed. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

B–8

B.4.2.2 Water Quality 

The water quality impact assessment for this Mercury Storage EIS analyzed how any routine effluent 

discharges and nonroutine releases (e.g., spills, containment failure) to surface water, as well as 

discharges reaching groundwater, from new or modified facilities required under each alternative could 

potentially affect current water quality over the short term. The impacts of the alternatives were assessed 

by comparing the projected effluent quality with relevant regulatory standards and implementing 

regulations under the Clean Water Act (33 U.S.C. 1251 et seq.), Safe Drinking Water Act 

(42 U.S.C. 300(f) et seq.), state laws, and existing site permit conditions, as summarized in Table B–5. 

The impact analyses evaluated the potential for contaminants to affect the water quality of waterways 

receiving spills and other releases under the alternatives. Separate analyses were conducted for 

surface-water and groundwater impacts. 

Table B–5. Water Quality Impact Assessment Protocol 

Required Data 

Resource Affected Environment Alternative Measure of Impact 

Surface-water quality Surface waters near the 

facility location in terms 

of stream classifications 

and water quality 

Expected contaminants 

and contaminant 

concentrations in 

discharges to surface 

waters 

Potential for exceedance 

of relevant surface-waterquality criteria or 

standards under the Clean 

Water Act or state 

regulations and existing 

permits 

Groundwater quality Groundwater near the 

facility location in terms 

of classification, presence 

of designated sole-source 

aquifers, and quality of 

groundwater 

Expected contaminants 

and contaminant 

concentrations in 

discharges that could 

reach groundwater 

Potential for contaminant 

concentrations in 

groundwater to exceed 

relevant standards or 

criteria established in 

accordance with the Safe 

Drinking Water Act or 

state regulations and/or 

existing permits 

Surface-Water Quality. The evaluation of surface-water-quality impacts focused on the quality and 

quantity of any effluents (including stormwater) that could be discharged during facility construction or 

modification or operations, as well as other releases, and the quality of the receiving stream upstream and 

downstream from the discharges. Factors that currently degrade water quality were also identified, where 

relevant. 

During facility construction and substantial facility modifications that result in ground disturbance, 

surface waters could be affected by site runoff and siltation and possibly spills (e.g., fuels from 

equipment). Such impacts relate to the amount of land disturbed, the type of soil at the site, the 

topography, and weather conditions. They would be minimized by application of standard management 

practices for stormwater and erosion control (e.g., sediment fences, mulching disturbed areas) and 

adherence to spill prevention and material-handling practices. 

During operations, surface waters could be affected by increased runoff from impervious surfaces 

(e.g., buildings) or cleared areas. Stormwater from these areas could be contaminated with materials 

deposited by airborne pollutants, automobile exhaust and residues, materials-handling releases (such as 

spills), and process effluents. Impacts of stormwater discharges could be highly variable and 

site-specific, and mitigation would depend on management practices, the design of holding facilities (if 

any), the topography, and adjacent land use. Data from existing water quality data sources were 

compared with expected discharges from the facilities to determine the potential for impacts on surface 

waters. 
Impact Assessment Methodology 

B–9

Groundwater Quality. Potential groundwater quality impacts associated with effluent discharges and 

other contaminant releases during facility construction or modifications and operations were examined. 

Available engineering estimates of contaminant concentrations were weighed against applicable Federal 

and state groundwater quality standards, effluent limitations, and drinking water standards to determine 

the impacts of each alternative. Also evaluated were the consequences of groundwater use and effluent 

discharge on other groundwater conditions at each site, as appropriate. 

B.4.2.3 Waterways and Floodplains 

The locations of waterways (e.g., ponds, lakes, streams) and delineated floodplains or zones were 

identified from maps and other existing documents to assess the potential for impacts resulting from 

proposed new facility construction and facility modification and operations, including direct effects on 

hydrologic characteristics. No construction or other activities would occur within a floodplain at any site. 

Although the Kansas City Plant is located within a mapped floodplain, the area is protected by engineered 

floodwalls to ensure compliance with Executive Order 11988, Floodplain Management. Therefore, 

preparation of a floodplain assessment is not required, pursuant to “Compliance with Floodplain and 

Wetland Environmental Review Requirements” (10 CFR 1022). 

B.5 METEOROLOGY, AIR QUALITY, AND NOISE 

B.5.1 Meteorology and Air Quality 

B.5.1.1 Description of Affected Resources 

Meteorology is the science that deals with the atmosphere. For the purposes of this EIS, the conditions 

that exist near the surface of the Earth, especially as they would have an effect on the dispersion of air 

pollutants or the design of a storage facility, are of primary importance. For each candidate mercury 

storage site, historical information on wind, temperature, precipitation, and meteorological events was 

obtained and summarized. Historical meteorological data for candidate sites were summarized, where 

available, and supplemented with data from nearby National Climatic Data Center stations, as necessary. 

Information on meteorological events from the National Climatic Data Center storm events database was 

summarized; data on tornadoes, hailstorms, snowfall, thunderstorms, high winds, and hurricanes were 

included. 

Air pollution refers to the introduction, directly or indirectly, of any substance into the air that could 

endanger human health and harm living resources and ecosystems, as well as material property, and 

impair or interfere with the comfortable enjoyment of life and other legitimate uses of the environment. 

For the purposes of this Mercury Storage EIS, only outdoor air pollutants were addressed. They may be 

in the form of solid particles, liquid droplets, gases, or a combination of these forms. Generally, they can 

be categorized as primary pollutants (those emitted directly from identifiable sources) or secondary 

pollutants (those produced in the air by interaction between two or more primary pollutants or by reaction 

with normal atmospheric constituents that may be influenced by sunlight). Air pollutants are transported, 

dispersed, or concentrated by meteorological and topographical conditions. Thus, air quality is affected 

by air pollutant emission characteristics, meteorology, and topography. 

Ambient air quality in a given location can be described by comparing the concentrations of various 

pollutants in the atmosphere with the appropriate standards. The ambient air quality standards established 

by Federal and state agencies allow an adequate margin of safety for the protection of public health and 

welfare from the adverse effects of pollutants in the ambient air. Pollutant concentrations higher than the 

corresponding standards are considered unhealthy; those below such standards are considered acceptable. 

Pollutants of concern are primarily those for which Federal and state ambient air quality standards have 

been established, including criteria air pollutants, hazardous air pollutants, and other toxic air compounds. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

B–10

Criteria air pollutants are listed in “National Primary and Secondary Ambient Air Quality Standards” 

(40 CFR 50). Hazardous air pollutants and other toxic compounds are those listed in Title I of the Clean 

Air Act, as amended (42 U.S.C. 7401 et seq.); those regulated by the National Emission Standards for 

Hazardous Air Pollutants (40 CFR 61); and those that have been proposed or adopted for regulation by 

the applicable state or are listed in state guidelines. States may set ambient standards that are more 

stringent than the National Ambient Air Quality Standards (NAAQS). The more stringent of the Federal 

or state standards are used in this EIS. 

Areas with air quality better than the NAAQS for criteria air pollutants are designated as “attainment,” 

while areas with air quality worse than the NAAQS for such pollutants are designated as “nonattainment.” 

Areas may be designated as “unclassified” when sufficient data for attainment-status designation are 

lacking. Attainment-status designations are assigned by county, metropolitan statistical area, consolidated 

metropolitan statistical area or portions thereof, or air quality control regions. Air quality control regions 

designated by the U.S. Environmental Protection Agency (EPA) are listed in “Designation of Areas for 

Air Quality Planning Purposes” (40 CFR 81). 

For locations within an attainment area for criteria air pollutants, Prevention of Significant Deterioration 

regulations limit pollutant emissions from new or modified sources and establish allowable increments of 

pollutant concentrations. Three Prevention of Significant Deterioration classifications are specified using 

the criteria established in the Clean Air Act. Class I areas include national wilderness areas; memorial 

parks larger than 2,020 hectares (5,000 acres); national parks larger than 2,430 hectares (6,000 acres); and 

areas that have been redesignated as Class I. Class II areas include all areas not designated as Class I. No 

Class III areas have been designated (42 U.S.C. 7472 et seq.). 

The ROI for air quality encompasses an area surrounding a site that is potentially affected by air pollutant 

emissions caused by implementation of the alternatives. The air quality impact area normally evaluated is 

the area in which concentrations of criteria pollutants would increase more than a significant amount in a 

Class II area (based on the averaging period and pollutant: 1 microgram per cubic meter for the annual 

average for sulfur dioxide, nitrogen dioxide, and particulate matter with an aerodynamic diameter less 

than or equal to 10 micrometers [PM10]; 5 for the 24-hour average for sulfur dioxide and PM10; 500 for 

the 8-hour average for carbon monoxide; 25 for the 3-hour average for sulfur dioxide; and 

2,000 micrograms for the 1-hour average for carbon monoxide (40 CFR 51.165). Generally, this ROI 

covers a few kilometers downwind from the source. Further, for sources within 100 kilometers (60 miles) 

of a Class I area, the air quality impact area evaluated would include the Class I area if the increase in 

concentration of any air pollutants for which there are Prevention of Significant Deterioration increments 

is greater than 1 microgram per cubic meter (24-hour average). The area of the ROI depends on emission 

source characteristics, pollutant types, emission rates, and meteorological and topographical conditions. 

For the purpose of this analysis, impacts were evaluated qualitatively based on estimated emissions from 

construction, operation, and shipping. 

Baseline air quality is typically described in terms of pollutant concentrations modeled for existing 

sources at each potential site and background air pollutant concentrations measured near the sites. For 

this analysis, concentrations for existing sources were obtained from existing source documents such as 

preliminary assessments, site investigations, EISs, annual environment reports, and the EPA database for 

nearby monitoring sites. These concentrations were compared with Federal and state standards or 

guidelines. 

B.5.1.2 Description of Impact Assessment 

Potential air quality impacts of pollutant emissions from facility construction or modification and normal 

operations were evaluated for each of the alternatives (see Table B–6). All of the alternatives considered 

had minor emissions from onsite activities, which were discussed qualitatively. Transportation emissions 

were estimated for truck and rail shipments of mercury. 
Impact Assessment Methodology 

B–11

Table B–6. Air Quality Impact Assessment Protocol 

Required Data

Resource Affected Environment Alternative Measure of Impact

Criteria air pollutants 

and other regulated 

pollutantsa

Toxic and hazardous 

air pollutantsb

Measured and modeled 

ambient concentrations 

(micrograms per cubic 

meter) from existing 

sources at site location 

Emission rate (kilograms 

per year) of air pollutants 

from facility site; source 

characteristics 

Alternative emissions of 

each pollutant quantified 

and potential impacts 

discussed qualitatively 

a Criteria pollutants and ozone precursors that would be emitted under the alternatives evaluated include carbon monoxide, 

nitrogen oxides, particulate matter with an aerodynamic diameter less than or equal to 10 micrometers, particulate matter with 

an aerodynamic diameter less than or equal to 2.5 micrometers, sulfur dioxide, and volatile organic compounds. 

b Clean Air Act, Section 112, hazardous air pollutants: pollutants regulated under the National Emissions Standards for 

Hazardous Air Pollutants and other state-regulated pollutants. Hazardous air pollutants emitted from construction equipment 

that were evaluated include ammonia, benzene, 1-,3-butadiene, formaldehyde, toluene, and xylene. 

The Clean Air Act, as amended, requires that Federal actions conform to the host state’s “state 

implementation plan.” A state implementation plan provides for the implementation, maintenance, and 

enforcement of NAAQS for the six criteria pollutants: sulfur dioxide, PM10, carbon monoxide, ozone, 

nitrogen dioxide, and lead. Its purpose is to eliminate or reduce the severity and number of violations of 

NAAQS and to expedite the attainment of these standards. No department, agency, or instrumentality of 

the Federal Government shall engage in or support in any way (i.e., provide financial assistance for, 

license or permit, or approve) any activity that does not conform to an applicable implementation plan. 

The final rule for “Determining Conformity of General Federal Actions to State or Federal 

Implementation Plans” (40 CFR 51.850–51.860) took effect on January 31, 1994. Areas currently 

designated as attainment for criteria air pollutants are not affected by the provisions of the conformity 

rule. Applicability of the conformity rule was assessed for each site. Because all the candidate sites are 

in attainment areas, no additional conformity analysis is required. 

Emissions of potential stratospheric ozone-depleting compounds such as chlorofluorocarbons were not 

evaluated because no emissions of these pollutants were identified in the mercury storage alternatives. 

However, emissions of pollutants thought to contribute to global climate change were evaluated. 

B.5.2 Noise 

B.5.2.1 Description of Affected Resources 

Sound results from the compression and expansion of air or some other medium when an impulse is 

transmitted through it. Sound requires a source of energy and a medium for transmitting the sound wave. 

Propagation of sound is affected by various factors, including meteorology, topography, and barriers. 

Noise is undesirable sound that interferes or interacts negatively with the human or natural environment. 

Noise may disrupt normal activities (e.g., hearing, sleeping), damage hearing, or diminish the quality of 

the environment. 

Noise-level measurements used to evaluate the effects of nonimpulsive sound on humans are adjusted by 

an A-weighting scale that accounts for the hearing response characteristics (i.e., frequency) of the human 

ear. Noise levels are expressed in decibels (dB) or, in the case of A-weighted measurements, decibels 

A-weighted (dBA). EPA has developed noise-level guidelines for different land use classifications 

(EPA 1974). The EPA guidelines identify a 24-hour average exposure level (energy-equivalent sound 

level) of no more than 70 dBA of intermittent environmental noise to prevent hearing loss. Likewise, 

day-night average levels of 55 dBA outdoors and 45 dBA indoors are identified as the limits to prevent 

activity interference and annoyance. State and local noise regulations were identified for each candidate 

site. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

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Noise from facility operations and associated traffic could affect human and animal populations. The 

ROI for each candidate site includes the site and surrounding area, including transportation corridors, 

where proposed activities might increase noise levels. Transportation corridors most likely to experience 

increased noise levels are those roads within a few miles of the site boundary that carry most of the site’s 

employee and shipping traffic. 

Noise-level data representative of site environs were obtained from existing reports. The acoustic 

environment was further described in terms of existing noise sources for the proposed locations and 

traffic noise levels along access routes. 

B.5.2.2 Description of Impact Assessment 

Noise impacts associated with the alternatives may result from facility construction or modification and 

operations, including increased traffic (see Table B–7). Impacts of proposed mercury storage activities at 

each site location were assessed according to the types of noise sources and the facility site locations 

relative to the site boundary and noise-sensitive receptors. Potential traffic noise impacts were assessed 

based on the likely increase in traffic volume. The increase in employee and truck traffic from the 

discussion of local traffic presented in Chapter 4 were compared with existing average traffic volume. 

For the purpose of comparison among the alternatives, the increase in traffic noise level in dBA can be 

estimated as 10 times the logarithm of the ratio of the projected traffic volume to the existing traffic 

volume. Possible impacts on wildlife were evaluated based on the possibility of sudden loud noises 

occurring during site activities under each alternative. 

Table B–7. Noise Impact Assessment Protocol 

Required Data 

Resource 

Affected 

Environment Alternative Measure of Impact 

Noise Identification of sensitive 

offsite receptors 

(e.g., nearby residences, 

nearby threatened and 

endangered wildlife 

habitat); description of 

noise levels and noise 

sources in the site vicinity 

Description of noise 

sources; shipment and 

workforce traffic estimates 

Increase in day-night 

average sound level at 

sensitive receptors 

B.6 ECOLOGICAL RESOURCES 

B.6.1 Description of Affected Resources 

Ecological resources include terrestrial and aquatic resources (plants and animals), threatened and 

endangered species, and wetlands that could be affected by the mercury management alternatives. The 

ROI used for habitat impacts encompassed the areas that could potentially be disturbed by proposed 

facility construction or modification and operations. 

Terrestrial resources are defined as those plant and animal species and communities that are most closely 

associated with the land; aquatic resources are those associated with a water environment. Wetlands are 

defined by the U.S. Army Corps of Engineers and EPA as “those areas that are inundated or saturated by 

surface or groundwater at a frequency and duration sufficient to support, and that under normal 

circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. 

Wetlands generally include swamps, marshes, bogs, and similar areas” (33 CFR 328.3). 

Endangered species are defined under the Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.) as 

those in danger of extinction throughout all or a large portion of their range. Threatened species are 
Impact Assessment Methodology 

B–13

defined as those species likely to become endangered within the foreseeable future. The U.S. Fish and 

Wildlife Service and the National Oceanic and Atmospheric Administration propose the addition of 

species to the lists of threatened and endangered species. They also maintain a list of “candidate” species 

for which they have evidence that listing may be warranted, but for which listing is currently precluded by 

the need to list species more in need of Endangered Species Act protection. Candidate species do not 

receive legal protection under the Endangered Species Act but should be considered in project planning in 

case they are listed in the future. Critical habitat for threatened and endangered species is designated by 

the U.S. Fish and Wildlife Service or the National Marine Fisheries Service. Critical habitat is defined as 

a specific area that contains physical and biological features essential to the conservation of species and 

that may require special management consideration or protection. States may also designate species as 

endangered, threatened, sensitive, in need of management, of concern, monitored, or of special concern. 

B.6.2 Description of Impact Assessment 

The proposed alternatives could involve land disturbance during facility modifications. Accordingly, the 

ROI evaluated for ecological impacts encompassed those areas on the candidate mercury storage sites that 

could potentially be disturbed by facility construction or modification and operations. 

Impacts on ecological resources may occur as a result of land disturbance, water use, human activity, and 

noise from construction, modification or expansion, and operation of mercury storage facilities 

(see Table B–8). Night lighting may also impact site ecology. Each of these factors was considered when 

evaluating the potential impacts of the proposed activities. Terrestrial resources could be directly affected 

through destruction or modification of habitat. Likely impacts include increased direct mortality and 

susceptibility to predation. Activities associated with each alternative (e.g., human intrusion and noise) 

could also cause wildlife to move to adjacent areas with similar habitat. If the receiving areas were 

already supporting the maximum sustainable number of individuals, competition for limited resources and 

habitat degradation could result in the loss of some individuals. Therefore, analysis of impacts on 

terrestrial wildlife was based largely on the extent of plant community loss or modification. Indirect 

impacts of factors such as human disturbance, noise, and night lighting were evaluated qualitatively. 

Facility construction, expansion, or modification and operations could directly affect aquatic resources 

through increased runoff and sedimentation, increased flows, and the introduction of chemical changes to 

the water. Impacts on nonsensitive terrestrial and aquatic ecosystems from water use and air and water 

emissions were evaluated based on the results of analyses conducted for air quality and water resources. 

The ecological risk assessment protocol is described in Appendix D. However, various mitigation 

techniques should minimize facility modification impacts, and discharges of contaminants to surface 

waters and air from routine operations are expected to be limited by engineering control practices. 

Project activity impacts on threatened and endangered species, as well as other special status species, and 

their habitats were determined in a manner similar to that used to evaluate impacts on other terrestrial and 

aquatic resources and habitats. A list of sensitive species that could be present at each site was compiled. 

Informal consultations were initiated with the appropriate U.S. Fish and Wildlife Service offices and 

state-equivalent agencies as part of the impact assessment for sensitive species (see Chapter 5). 

Most facility modification impacts on wetlands are related to the displacement of wetlands by filling, 

draining, or dredging activities. Loss of wetlands resulting from modification of the facilities was 

addressed by comparing data on the location and areal extent of wetlands in the ROI with the land area 

requirements for the alternative mercury storage sites. Operational impacts on wetlands could result from 

effluents, surface-water or groundwater withdrawals, or creation of new wetlands. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

B–14

Table B–8. Ecological Resources Impact Assessment Protocol 

Required Data 

Resource Affected Environment Alternative Measure of Impact 

Terrestrial resources Terrestrial vegetation and 

wildlife within the vicinity 

of the site location 

Area disturbed by facility 

site activities, air 

emissions, wastewater 

discharges, and noise 

Loss of or disturbance to 

species and their habitats; 

emissions and noise values 

above levels shown to 

cause impacts on 

terrestrial resources 

Aquatic resources Aquatic resources within 

the vicinity of the site 

location 

Facility area air emissions, 

water source and quantity, 

and wastewater discharge 

locations and quantities 

Discharges above levels 

shown to cause impacts on 

aquatic resources 

Wetlands Wetlands within the 

vicinity of the site location 

Area disturbed by facility 

site activities, air 

emissions, and wastewater 

discharge locations and 

quantities 

Loss of or disturbance to 

wetlands 

Threatened and 

endangered species 

Threatened and 

endangered species, as 

well as their habitats, 

within the vicinity of the 

site location 

Area disturbed by facility 

site activities, air 

emissions, noise, water 

sources and quantities, and 

wastewater discharge 

locations and quantities 

Similar to measures used 

in evaluating other 

terrestrial and aquatic 

resources and habitats 

B.7 CULTURAL AND PALEONTOLOGICAL RESOURCES 

B.7.1 Description of Affected Resources 

Cultural resources are indications of human occupation and use of property as defined and protected by a 

series of Federal laws, regulations, and guidelines. For this Mercury Storage EIS, potential impacts were 

assessed separately for each of the cultural resource categories: prehistoric resources, historic resources, 

and American Indian resources. Paleontological resources are the physical remains, impressions, or 

traces of plants or animals from a former geologic age and may be sources of information on ancient 

environments and the evolutionary development of plants and animals. Although not governed by the 

same historic preservation laws as cultural resources, paleontological resources could be affected by the 

proposed actions in much the same manner and have been assessed as appropriate. 

Prehistoric resources are the physical remains of human activities that predate written records. They 

generally consist of artifacts that may either alone or collectively yield information about the past. 

Historic resources consist of physical remains that postdate the emergence of written records. In the 

United States, they are architectural structures or districts, archaeological objects, and archaeological 

features dating from 1492. Ordinarily, sites less than 50 years old are not considered historic, but 

exceptions are made for properties of particular importance such as structures associated with World 

War II or Cold War themes. American Indian resources include sites, areas, and materials considered 

important to American Indians for religious or heritage reasons. Such interests may include geographic 

features, plants, animals, cemeteries, battlefields, trails, and environmental features. The ROI for the 

cultural and paleontological resource analysis encompasses the candidate mercury storage site locations 

that could potentially be disturbed by facility construction or modification and other activities and 

occupied during the operations of facilities for long-term mercury storage. 
Impact Assessment Methodology 

B–15

B.7.2 Description of Impact Assessment 

The analysis of impacts on cultural and paleontological resources addressed potential direct and indirect 

impacts at each site location (see Table B–9). 

Table B–9. Cultural and Paleontological Resources Impact Assessment Protocol 

Required Data 

Resource Affected Environment Alternative Measure of Impact 

Prehistoric and historic 

resources 

Prehistoric and historic 

resources within the 

vicinity of the site 

location 

Potential for loss, isolation, 

or alteration of the character 

of prehistoric and historic 

resources; neglect of 

resources listed or eligible 

for listing in the National 

Register of Historic Places 

American Indian 

resources 

American Indian 

resources within the 

vicinity of the site 

location 

Potential for loss, isolation, 

or alteration of the character 

of American Indian 

resources 

Paleontological 

resources 

Paleontological resources 

within the vicinity of the 

site location 

Location of facility on 

the site and facility 

acreage requirements 

Potential for loss, isolation, 

or alteration of 

paleontological resources 

Potential indirect impacts include those associated with reduced access to a cultural resource site, as well 

as those associated with increased traffic and visitation to sensitive areas. Direct impacts include those 

resulting from mercury storage facility placement. Consultations were conducted with the appropriate 

State Historic Preservation Officers to comply with Section 106 of the National Historic Preservation Act 

(16 U.S.C. 470 et seq.). Correspondence offering consultation was sent to American Indian tribes local to 

each candidate site, as appropriate (see Chapter 5). 

B.8 SITE INFRASTRUCTURE 

B.8.1 Description of Affected Resources 

Site infrastructure includes the physical resources and aspects composing the ground transportation and 

utility systems required to support mercury storage activities at each candidate site evaluated for 

long-term mercury storage. It specifically comprises the capacities of the (1) onsite road networks; 

(2) electric power transmission and distribution system; (3) natural gas and liquid fuel (i.e., fuel oil, diesel 

fuel, and gasoline) storage and conveyance systems; and (4) water supply system. 

The ROI is generally limited to the boundaries of the candidate sites. However, should infrastructure 

requirements exceed site capacities, the ROI would be expanded (for analysis) to include the sources of 

additional supply. For example, if electrical demand (with added facilities) exceeded site availability, the 

ROI would be expanded to include the likely source of additional power (i.e., the electric power pool 

currently supplying the site). 

B.8.2 Description of Impact Assessment 

In general, utility infrastructure impacts were assessed by evaluating the requirements of each alternative, 

including associated activities and facility demands, against site capacities. Impacts were assessed for 

each utility infrastructure resource (electricity, fuel, and water) for the various alternatives 

(see Table B–10). Tables reflecting site availability and infrastructure requirements were developed for 

each alternative. Data for these tables were obtained from documentation describing the existing 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

B–16

infrastructure at the candidate storage locations and from responses to information requests prepared to 

support this EIS. 

Table B–10. Site Infrastructure Impact Assessment Protocol 

Required Data 

Resource Affected Environment Alternative Measure of Impact 

Electricity (energy 

consumption) 

(megawatt-hours) 

Fuel (natural gas, 

gasoline, diesel fuela) 

(liters) 

Water (liters) 

Site or facility area 

capacity and current usage 

Activity and facility 

requirements 

Additional requirement 

(with added facilities) 

exceeding site or facility 

area capacity 

a Includes No. 2 diesel fuel (road diesel) and heating fuel oil. 

Any projected demand for infrastructure resources exceeding site availability can be regarded as an 

indicator of impact. Whenever projected demand approaches or exceeds capacity, further analysis of that 

resource is warranted. Often, design changes can mitigate the impact of additional demand for a given 

resource. For example, substituting fuel oil for natural gas (or vice versa) for heating or industrial 

processes can be accomplished at little cost during the design of a facility provided the potential for 

impact is identified early. Similarly, a dramatic “spike” in peak demand for electricity can sometimes be 

mitigated by changes to operational procedures or parameters. 

Although ground transportation infrastructure is part of the physical infrastructure, incremental demands 

associated with the alternatives (e.g., new roadways to support project activities) were not separately 

quantified, but were assessed as part of the land use impacts analysis (see Section B.1.1.2). Note that the 

methodology for assessing local roadway traffic impacts, which are related to projected changes in 

facility site employment and local population, is described in Section B.11.2. 

B.9 WASTE MANAGEMENT 

B.9.1 Description of Affected Resources 

Both hazardous and nonhazardous wastes can be expected to be generated in the process of storing and 

maintaining mercury over the long term. Certain mercury-bearing wastes are regulated as hazardous 

wastes under the Resource Conservation and Recovery Act (RCRA) (42 U.S.C. 6901 et seq.) and would 

need to be managed in accordance with RCRA regulations. Other waste materials that would be 

generated could be classified as nonhazardous or hazardous waste. Definitions of these waste types are as 

follows: 

 Hazardous – Under RCRA, a waste that, because of its characteristics, may (1) cause or 

significantly contribute to an increase in mortality or an increase in serious irreversible or 

incapacitating reversible illness, or (2) pose a substantial present or potential hazard to human 

health or the environment when improperly treated, stored, transported, disposed of, or otherwise 

managed. Hazardous wastes appear on special EPA lists or possess at least one of the following 

characteristics: ignitability, corrosiveness, reactivity, or toxicity. 

 Nonhazardous – Discarded material, including solid, liquid, semisolid, or contained gaseous 

material resulting from industrial, commercial, mining, or agricultural operations or community 

activities. 

The mercury storage alternatives could have an impact on existing site waste management facilities. 

Thus, the ROI for waste management comprises the on- or offsite waste management facilities that could 
Impact Assessment Methodology 

B–17

be impacted by waste generation at each mercury storage site. With the exception of some sanitary waste 

and possibly some construction waste, if suitable facilities exist on site, waste management activities and 

facilities are limited to collection and temporary storage of waste for offsite recycling, treatment, or 

disposal. Depending on the mercury storage facility location, leach fields, onsite treatment facilities, or 

municipal sewage treatment facilities would be used for sanitary sewage. 

B.9.2 Description of Impact Assessment 

As shown in Table B–11, impacts were assessed by comparing the projected waste stream volumes 

generated from the proposed activities at each candidate mercury storage site with that site’s waste 

management capacities and generation rates. Projected waste generation rates for the proposed activities 

were compared with each site location’s capacity to manage the waste, either on or off site. 

Table B–11. Waste Management Impact Assessment Protocol 

Required Data 

Resource Affected Environment Alternative Measure of Impact 

Waste management 

capacity 

Hazardous waste 

Nonhazardous waste 

RCRA status 

Annual generation rate 

at facility location 

(cubic meters per 

year) for each waste 

type 

Offsite shipments 

(cubic meters per 

year) for each waste 

type 

Site location 

management 

capacities (cubic 

meters) or rates 

(cubic meters per 

year) for potentially 

affected management 

facilities for each 

waste type 

RCRA status 

Annual generation 

rates from site 

activities 

associated with 

each candidate site 

for each waste type 

Do additional hazardous waste 

generation or treatment 

activities change RCRA 

status? 

Combination of waste 

generation volumes from site 

activities and other site 

generation volumes in 

comparison with the capacities 

of applicable waste 

management facilities 

Key: RCRA=Resource Conservation and Recovery Act. 

B.10 SOCIOECONOMICS 

B.10.1 Description of Affected Resources 

Socioeconomic impacts are defined in terms of changes to the demographic and economic characteristics 

and social conditions of a region. For example, the number of jobs created by the proposed actions could 

affect regional employment, income, and expenditures. Job creation is generally characterized by two 

types: (1) construction-related jobs, which are transient in nature and limited in duration, and thus less 

likely to have a long-term socioeconomic impact and (2) operations-related jobs in support of the 

facility’s mission, which are required for a longer period of time and have a greater potential for 

permanent socioeconomic impacts in the ROI. To accurately reflect the economic impacts of the 

proposed alternatives, the region that is supplying the direct requirements must be considered. The best 

gauge of the direct requirements is the region in which the workforce resides. Therefore, the ROI for 

socioeconomics comprises the counties in which approximately 90 percent of the site workers live. In 

cases where employee residential data by county are unavailable for the candidate site, a labor shed 

analysis of the area was performed using the U.S. Census Bureau’s Local Employment Dynamics to 

determine where the majority of employees reside. The counties that define the socioeconomic ROI must 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

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also be contiguous due to the requirements set by the U.S. Bureau of Economic Analysis for developing 

regional input-output multipliers. 

The socioeconomic environment generally includes regional economic indicators, demographic 

characteristics, and community services available in the area. Economic indicators include employment, 

the civilian labor force, and unemployment rates. Demographic and community service characteristics 

include population, housing, and local transportation information. 

B.10.2 Description of Impact Assessment 

For each county in the ROI, data were compiled on current socioeconomic conditions, including 

employment, the civilian labor force, and unemployment. Census Bureau data were compiled for 

population and housing. Census Bureau population estimates for the ROIs were combined with 

overall estimated workforce requirements for each alternative to determine the extent of impacts on 

regional economic and demographic (population) characteristics and local transportation impacts 

(see Table B–12). 

Table B–12. Socioeconomics Impact Assessment Protocol 

Required Data 

Resource Affected Environment Alternative Measure of Impact 

Regional Economic Characteristics 

Employment Latest available 

employment estimates 

from the U.S. Bureau of 

Labor Statistics, Local 

Area Unemployment 

Statistics 

Estimated construction 

and operations activity 

staffing requirements and 

timeframes 

Potential change in 

employment compared 

with the regional 

workforce 

Demographic Characteristics 

Population and housing Latest available estimates 

by county from the 

U.S. Census Bureau, 

Population Division, and 

the American Community 

Survey

Estimated effect on 

population as a result of 

employment 

Potential effects on 

population 

Local Transportation 

Traffic—number of 

vehicles 

Latest available 

information on traffic 

volumes on each facility 

site’s access roads, 

intrasite roads, and local 

regional transportation 

networks 

Estimated number of 

commuter and truck 

vehicle trips to and from 

the site 

Projected change in traffic 

conditions 

A qualitative assessment was also conducted of the potential impact of facility siting on real estate 

property values. There are many obstacles in attempting to estimate the impact on residential property 

values of homes in communities surrounding any industrial or hazardous waste storage facility. What 

little data exist on the subject suggest it is difficult to make generalizations, and impacts of the magnitude 

and direction of property values are highly dependent on the individual characteristics of each type of 

facility. There have been several studies that attempt to analyze the impacts on property values of 

“Superfund” sites under the Comprehensive Environmental Response, Compensation, and Liability Act. 

These have yielded mixed results. In some cases, analysis has shown that the stigma created from such 

sites has caused property values closer to the site to decrease, some have shown an increase in value due 

to the potential for well-paying jobs, while many others have shown there to be no impact. DOE has 

worked with the public throughout the EIS process to facilitate understanding of the potential risks 
Impact Assessment Methodology 

B–19

presented by the elemental mercury storage alternatives so that opinions can be formulated based on facts 

rather than perception. The primary factor in determining the impact on property values from a facility is 

the perceived risk to human health imposed on residents of a property in close proximity to that facility. 

As presented in the “Occupational and Public Health and Safety” sections of Chapter 4, normal (routine) 

operations of a mercury storage facility would result in little risk of environmental contamination due to 

the design and safety parameters put in place. Similarly, the human health risk to the offsite population 

would be negligible. Furthermore, DOE, the U.S. Department of Defense, and private companies have 

safely stored mercury for more than 50 years. The mercury storage facility(ies) would have the 

appearance of a warehouse(s), so there would be little visible evidence of hazardous waste storage 

activities. 

B.11 ENVIRONMENTAL JUSTICE 

B.11.1 Description of Affected Resources 

Environmental justice assesses the potential for disproportionately high and adverse human health and 

environmental effects on minority and low-income populations resulting from implementation of the 

alternatives in this Mercury Storage EIS. The Census Bureau publishes annual population estimates 

through the American Community Survey: 1-year estimates and 3-year estimates for geographic areas with 

population thresholds of 65,000 and 20,000, respectively. The most recent demographic data available 

are presented for the counties surrounding each candidate storage location. When attempting to identify 

disproportionately high minority and low-income populations residing in the ROI, 2000 decennial census 

data are used to provide greater spatial resolution, as discussed below. In assessing the impacts, the 

following definitions of minority individuals and populations and low-income populations were used. 

 Minority individuals are identified as members of the following population groups: Hispanic or 

Latino, American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian 

or other Pacific Islander, or two or more races. 

 Minority populations are identified where either (1) the minority population of the affected area 

exceeds 50 percent or (2) the minority population percentage of the affected area is meaningfully 

greater than the minority population percentage in the general population or other appropriate unit 

of geographic analysis. 

 Low-income populations are identified in an affected area using the annual statistical poverty 

thresholds from the Census Bureau’s Current Population Reports, Series P60 on Consumer 

Income, Poverty in the United States: 1999, No. P60-210 (DOC 2000). For example, the poverty 

threshold in 1999 for one individual was $8,501. In identifying low-income populations, 

agencies may consider as a community either a group of individuals living in geographic 

proximity to one another or a set of individuals (such as migrant workers or American Indians), 

where either type of group experiences common conditions of environmental exposure or effect. 

 The ROI for the environmental justice analysis was defined as those minority and low-income 

populations residing within a 16-kilometer (10-mile) radius centered on the candidate mercury 

storage sites. The radius was selected to provide a comparative basis for analysis across all sites, 

including all DOE sites where a smaller radius might not capture members of the public off site. 

An additional ROI of those residing within an approximately 3.2-kilometer (2-mile) radius of 

each candidate site was used as a subset of the 16-kilometer (10-mile) ROI in order to guard 

against inadvertently diluting represented minority and low-income populations most likely to 

experience any potentially adverse impacts associated with mercury storage. In areas where a 

disproportionately high number of minority or low-income individuals were identified, 

environmental justice concerns were considered in greater detail. In these areas, additional 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

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efforts were made to identify potentially susceptible populations. Such populations may include 

children, the elderly, and the medically underserved. 

Tables B–13 and B–14 present the thresholds used for identifying minority and low-income populations 

surrounding the candidate mercury storage sites. These thresholds were developed consistent with CEQ 

guidance (CEQ 1997:25) for identifying minority populations, as described above, using either the 

50 percent threshold or another percentage deemed “meaningfully greater” than the percentage of 

minority or low-income individuals in the general population. “Meaningfully greater” is defined here as 

20 percentage points higher than the percentage of minority or low-income individuals in the general 

population. The general population percentage of minority or low-income individuals is defined in this 

analysis as the lower of the average percentage of minority or low-income individuals living in the 

counties that are at least partially included within the ROI or living in the state(s) in which the ROI lies. 

The geographic area with the lower percentage of minority or low-income individuals is used to provide 

for greater conservatism. As the tables show, the thresholds of the two ROIs differ in some cases due to 

changes in the geographic areas included in the general population percentage, as defined above. Sites 

not included in Tables B–13 and B–14 have no such populations within the specified radius of the site. 

Table B–13. Site-Specific Thresholds for Identification of Minority and Low-Income Populations 

Within the 16-Kilometer (10-Mile) Region of Influence 

Population 

Grand 

Junction 

Disposal 

Site 

Hawthorne 

Army 

Depot 

Idaho 

National 

Laboratory 

Kansas 

City 

Plant 

Savannah 

River 

Site 

Waste 

Control 

Specialists, 

LLC 

Y–12 

National 

Security 

Complex 

Minority 

population 33.2% 49.9% 32.0% 36.5% 50.0% 50.0% 30.4% 

Low-income 

population 29.3% 30.5% 31.8% 29.2% 33.4% 35.6% 32.7% 

Note: The highlighted thresholds indicate the state(s) as the lower general population percentage. 

Table B–14. Site-Specific Thresholds for Identification of Minority and 

Low-Income Populations Within the 3.2-Kilometer (2-Mile) Region of Influence 

Population 

Grand 

Junction 

Disposal 

Sites 

Kansas 

City Plant 

Waste 

Control 

Specialists, 

LLC 

Y–12 

National 

Security 

Complex 

Minority population 33.0% 36.2% 50.0% 27.3% 

Low-income population 29.3% 31.7% 35.6% 33.1% 

Note: The highlighted thresholds indicate the state(s) as the lower general population percentage. 

B.11.2 Description of Impact Assessment 

The environmental justice analysis focused on potential health risks resulting from normal operations and 

accidents that could occur during activities associated with implementation of the alternatives for mercury 

storage. Low-income and minority populations-at-risk are composed of the low-income and minority 

sub-populations identified within the general population subject to mercury exposures that could result 

from such accidents. The consequences and risks of postulated accidents are identical to those used in the 

human health impacts analysis. 

The CEQ issued its guidance for evaluation of environmental justice in December 1997, Environmental 

Justice Guidance Under the National Environmental Policy Act (CEQ 1997). The CEQ’s guidance was 

used as the basis for this evaluation of environmental justice (see Table B–15). 

The analysis of environmental justice used block group spatial resolution. Demographic data are 

aggregated by the Census Bureau in a variety of ways that include states, counties, census tracts, block 
Impact Assessment Methodology 

B–21

groups, and blocks. Block groups provide the finest spatial resolution available for evaluation of 

low-income populations. The boundaries of block groups generally do not coincide with boundaries of 

the potentially affected area. As a result, some block groups will lie partially inside and partially outside 

of the potentially affected area. To estimate the at-risk population residing in partially included blocks 

groups, it was assumed that the population of partially included block groups is uniformly distributed. 

Thus, if “X” percent of a block group lies within the potentially affected area, then it is assumed that “X” 

percent of the population of that block group is at risk. 

Table B–15. Environmental Justice Impact Assessment Protocol 

Required Data 

Resource Affected Environment Measure of Impact 

Minority populations Latest baseline demographic data with 

block group resolution from the U.S. 

Census Bureau’s 2000 decennial 

census, Summary File 1 (DOC 2009a). 

Low-income 

populations 

Latest baseline demographic data with 

block group resolution from the U.S. 

Census Bureau’s 2000 decennial 

census, Summary File 3 (DOC 2009b). 

Disproportionately high and adverse impacts 

on minority and low-income populations are 

identified where health effects, measured in 

risks and rates, are significant or above 

generally accepted norms, and where the risk 

or rate of hazard exposure to a minority or 

low-income population appreciably exceeds 

the risk or rate to the general population. 

Impacts are determined based on the results 

from the occupational and public health and 

safety risk analysis, land use, cultural and 

paleontological resources, socioeconomics, 

and other resource area impact analyses, as 

appropriate. 

B.12 CUMULATIVE IMPACTS 

B.12.1 Description of Affected Resources 

The cumulative impacts analysis discusses potential impacts resulting from other facilities, operations, 

and activities that, in combination with the potential impacts of each proposed alternative, may contribute 

to cumulative impacts. Cumulative impacts are impacts on the environment that result from the 

incremental impact of each proposed alternative when added to other past, present, and reasonably 

foreseeable future actions, regardless of the agency (Federal or non-Federal) or person that undertakes 

other such actions (40 CFR 1508.7). Although uncertainties may exist with respect to identifying 

reasonably foreseeable future actions, CEQ regulations allow for the inclusion of uncertainties in the 

analysis provided that the agency preparing the EIS makes it clear that incomplete or unavailable 

information was used in the analysis (40 CFR 1502.22). A “reasonably foreseeable future action,” as 

used in this analysis, includes those actions with a high probability of being implemented. 

Because cumulative impacts accrue to resources, the analysis of impacts must focus on specific resources 

or impact areas as opposed to merely aggregating all of the actions occurring in and around the proposed 

facilities and attempting to form conclusions regarding the effects of the many unrelated actions. 

Narrowing the scope of the analysis to resources that are likely to accrue impacts from the proposed 

action and other past, present, and reasonably foreseeable actions also supports the intent of the National 

Environmental Policy Act process, which is “to reduce paperwork and the accumulation of extraneous 

background data; and to emphasize real environmental issues and alternatives” (40 CFR 1500.2(b)). 

B.12.2 Description of Impact Assessment 

The cumulative impacts analysis for this Mercury Storage EIS involved combining the impacts of the 

action alternatives on each resource area with the impacts of other present and reasonably foreseeable 

activities within a 16-kilometer (10-mile) ROI. Potential contributions to cumulative impacts at 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

B–22

non-DOE mercury storage sites under the No Action Alternative were not evaluated because potential 

locations of and impacts at mercury storage sites are highly speculative. DOE’s Y–12 National Security 

Complex was not evaluated since, under the No Action Alternative, no change is expected to occur at the 

site relative to mercury management and storage. 

The general approach to the analysis involved the following process: 

 Baseline impacts from past and present actions were identified (i.e., these are the baseline

conditions described in Chapter 3). 

 The potential impacts produced by the management and storage alternatives were identified (as

described in Chapter 4, Sections 4.3 through 4.9). 

 Reasonably foreseeable future actions were identified. 

 Cumulative impacts of the proposed action at the candidate mercury storage sites were estimated. 

Reasonably foreseeable future actions that may contribute to cumulative impacts include on- and offsite 

projects conducted by government agencies, businesses, or individuals that are within the 16-kilometer 

(10-mile) ROI considered in this Mercury Storage EIS. Information on these actions was gathered based 

on a review of local (i.e., city and county) and Federal government information, as well as any known 

plans in the private sector. Additionally, National Environmental Policy Act documents were reviewed to 

determine if the actions they describe could affect the cumulative impacts analysis. 

In keeping with CEQ regulations (40 CFR 1500.7), those resource areas that were predicted to be 

impacted in at least a minor way were evaluated for their potential to contribute to cumulative impacts 

within the ROI. Where impacts were predicted not to occur or were negligible, cumulative impacts were 

generally not analyzed since there would be either no, or only a very small incremental increase in 

impacts on the resource within the ROI. One additional criterion used to determine whether impacts 

could be cumulative was new construction, that is, if there would be new land disturbance. 

Finally, a qualitative assessment was performed to consider the mercury storage alternatives’ potential 

incremental contributions to the public’s exposure to small amounts of mercury vapor, to ozone depletion, 

and to global climate change. 

B.13 REFERENCES 

CEQ (Council on Environmental Quality), 1997, Environmental Justice Guidance Under the National 

Environmental Policy Act, Executive Office of the President, Washington, D.C., December 10. 

DOC (U.S. Department of Commerce), 2000, Current Population Reports, Series P60 on Consumer 

Income, Poverty in the United States: 1999, No. P60-210, U.S. Census Bureau, Washington, D.C., 

September. 

DOC (U.S. Department of Commerce), 2009a, United States Census 2000, Summary File 1 (SF 1), U.S. 

Census Bureau, accessed through http://www.census.gov/Press-Release/www/2001/sumfile1.html. 

DOC (U.S. Department of Commerce), 2009b, United States Census 2000, Summary File 3 (SF 3), 

U.S. Census Bureau, accessed through http://www.census.gov/Press-Release/www/2002/sumfile3.html. 

DOE (U.S. Department of Energy), 2004, Recommendations for the Preparation of Environmental 

Assessments and Environmental Impact Statements, 2nd ed., Office of NEPA Policy and Compliance, 

Washington, D.C., December. 
Impact Assessment Methodology 

B–23

DOI (U.S. Department of Interior), 1986, Visual Resource Contrast Rating, BLM Manual Handbook 

H-8431-1, Bureau of Land Management, Washington, D.C., January 17. 

EPA (U.S. Environmental Protection Agency), 1974, Information on Levels of Environmental Noise 

Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety, EPA-550/9-74-004, 

Office of Noise Abatement and Control, Washington, D.C., March. 

Petersen, M.D., et al., 2008, 2008 United States National Seismic Hazard Maps, U.S. Geological Survey 

Fact Sheet 2008–3018, April, accessed through http://pubs.usgs.gov/fs/2008/3018/pdf/ 

FS08-3018_508.pdf. 

USGS (U.S. Geological Survey), 2009a, Earthquake Hazards 201 — Technical Information, What is 

probabilistic ground motion?, A Simple Description of Seismic Hazard Maps, Earthquake Hazards 

Program, accessed through http://earthquake.usgs.gov/research/hazmaps/haz101/faq/psha01.php, 

January 29. 

USGS (U.S. Geological Survey), 2009b, Earthquake Hazards 201 — Technical Information, What is 

probabilistic ground motion?, Uses for the Seismic Hazard Maps, Earthquake Hazards Program, accessed 

through http://earthquake.usgs.gov/research/hazmaps/haz101/faq/psha02.php, January 29. 

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Figures (Static Maps), Earthquake Hazards Program, accessed through http://earthquake.usgs.gov/ 

research/hazmaps/products_data/2008, April 14. 

USGS (U.S. Geological Survey), 2009d, FAQ Measuring Earthquakes, What are the earthquake 

magnitude classes?, What is intensity?, What is the Modified Mercalli Intensity Scale?, What is the 

difference between intensity scales and magnitude scales?, What are the different magnitude scales, and 

why are there so many?, Earthquake Hazards Program, accessed through http://earthquake.usgs.gov/ 

learning/faq/?categoryID=2, June 9. 

USGS (U.S. Geological Survey), 2009e, Earthquake Topics – Intensity, Magnitude/Intensity Comparison, 

Earthquake Hazards Program, Earthquake Topics Page, accessed through http://earthquake.usgs.gov 

/learning/topics/mag_vs_int.php, February 18. 

Wald, D.J., V. Quitoriano, T.H. Heaton, and H. Kanamori, 1999, Earthquake Spectra, “Relationships 

Between Peak Ground Acceleration, Peak Ground Velocity and Modified Mercalli Intensity in 

California,” Vol. 15 (3), pp. 557–564, accessed through www-socal.wr.usgu.gov/shake/pubs/regress/ 

regress.html. 

Code of Federal Regulations

7 CFR 657.5, U.S. Department of Agriculture, “Identification of Important Farmlands.” 

7 CFR 658.2, U.S. Department of Agriculture, “USDA Assistance with Federal Agencies’ Reviews of 

Policies and Procedures.” 

7 CFR 658.3, U.S. Department of Agriculture, “Applicability and Exemptions.” 

10 CFR 1022, U.S. Department of Energy, “Compliance with Floodplain and Wetland Environmental 

Review Requirements.” 

33 CFR 328.3, Army Corps of Engineers, U.S. Department of the Army, “Definition of Waters of the 

United States.” 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

B–24

40 CFR 50, U.S. Environmental Protection Agency, “National Primary and Secondary Ambient Air 

Quality Standards.” 

40 CFR 51.165, U.S. Environmental Protection Agency, “Permit Requirements.” 

40 CFR 51.850–51.860, U.S. Environmental Protection Agency, “Determining Conformity of General 

Federal Actions to State or Federal Implementation Plans.” 

40 CFR 61, U.S. Environmental Protection Agency, “National Emission Standards for Hazardous Air 

Pollutants.” 

40 CFR 81, U.S. Environmental Protection Agency, “Designation of Areas for Air Quality Planning 

Purposes.” 

40 CFR 1500–1508, U.S. Environmental Protection Agency, “Council on Environmental Quality 

Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act.” 

United States Code 

7 U.S.C. 4201 et seq., Farmland Protection Policy Act of 1981. 

16 U.S.C. 470 et seq., National Historic Preservation Act of 1966. 

16 U.S.C. 1531 et seq., Endangered Species Act of 1974. 

33 U.S.C. 1251 et seq., Clean Water Act of 1972. 

42 U.S.C. 300(f) et seq., Safe Drinking Water Act of 1974. 

42 U.S.C. 6901 et seq., Resource Conservation and Recovery Act of 1976. 

42 U.S.C. 7401 et seq., Clean Air Act of 1970. 

42 U.S.C. 7472 et seq., Prevention of Significant Deterioration of Air Quality. 

Executive Order

Executive Order 11988, Floodplain Management, May 24, 1997, as amended. 

U.S. Department of Energy Guides, Orders, and Standards

DOE Order 420.1B, Facility Safety, December 22, 2007. 

DOE Guide 420.1-2, Guide for the Mitigation of Natural Phenomena Hazards for DOE Nuclear 

Facilities and Nonnuclear Facilities, March 28, 2000. 

DOE Standard 1020-2002, Natural Phenomena Hazards Design and Evaluation Criteria for Department 

of Energy Facilities, January 2002. 

DOE Standard 1023-95, Natural Phenomena Hazards Assessment Criteria, April 2002.