Dr Draafftt

Long-Term Management and

Storage of Elemental Mercury

Environmental Impac vironmental Impact Statement t Statement

Summary and Guide for Stakeholders

U.S. Department of Energy

Office of Environmental Management

Washington, DC

DOE/EIS-0423D

January 2010
AVAILABILITY OF THE

DRAFT LONG-TERM MANAGEMENT AND

STORAGE OF ELEMENTAL MERCURY

ENVIRONMENTAL IMPACT STATEMENT

For information or to submit comments on this 

Draft Mercury Storage EIS, contact:

David Levenstein, Document Manager

Office of Environmental Compliance (EM–41)

U.S. Department of Energy

Post Office Box 2612

Germantown, MD 20874

Website: http://www.mercurystorageeis.com

Fax: 877-274-5462

Printed with soy ink on recycled paper
COVER SHEET 

Lead Agency: U.S. Department of Energy (DOE) 

Cooperating Agencies: U.S. Environmental Protection Agency (EPA) 

Mesa County Board of Commissioners, Mesa County, Colorado 

Title: Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact 

Statement (Mercury Storage EIS) (DOE/EIS-0423D) 

Candidate Locations for Storage Facility(ies): Colorado, Idaho, Missouri, Nevada, South Carolina, 

Texas, Washington 

Contacts: For copies of this draft environmental impact statement (EIS), visit the Mercury Storage EIS

website at http://www.mercurystorageeis.com or contact David Levenstein at the address below. 

For information or to submit comments on 

this Draft Mercury Storage EIS, contact: 

David Levenstein, Document Manager 

Office of Environmental Compliance (EM–41) 

U.S. Department of Energy 

Post Office Box 2612 

Germantown, MD 20874 

Website: http://www.mercurystorageeis.com 

Fax: 877-274-5462 

For general information on the DOE National 

Environmental Policy Act (NEPA) process, contact: 

Carol M. Borgstrom, Director 

Office of NEPA Policy and Compliance (GC–54) 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585 

Website: http://www.gc.energy.gov/NEPA 

Telephone: 202-586-4600, 

 or leave a message at 800-472-2756 

Abstract: Pursuant to the Mercury Export Ban Act of 2008 (P.L. 110-414), DOE has been directed to 

designate a facility or facilities for the long-term management and storage of elemental mercury generated 

within the United States. DOE is analyzing the storage of up to 10,000 metric tons (11,000 tons) of 

elemental mercury in a facility(ies) constructed and operated in accordance with the Solid Waste Disposal 

Act, as amended by the Resource Conservation and Recovery Act (74 FR 31723). DOE has prepared this 

Mercury Storage EIS in accordance with the National Environmental Policy Act of 1969 (NEPA), as 

amended (42 U.S.C. 4321 et seq.), the Council on Environmental Quality (CEQ) implementing 

regulations (40 CFR 1500–1508), and DOE’s NEPA implementing procedures (10 CFR 1021) to evaluate 

the reasonable alternatives for a facility(ies) for the long-term management and storage of elemental 

mercury. This Mercury Storage EIS analyzes the potential environmental, human health, and 

socioeconomic impacts of elemental mercury storage at seven candidate locations: Grand Junction 

Disposal Site near Grand Junction, Colorado; Hanford Site near Richland, Washington; Hawthorne Army 

Depot near Hawthorne, Nevada; Idaho National Laboratory near Idaho Falls, Idaho; Kansas City Plant in 

Kansas City, Missouri; Savannah River Site near Aiken, South Carolina; and Waste Control Specialists, 

LLC, near Andrews, Texas. As required by CEQ NEPA regulations, the No Action Alternative is also 

analyzed as a basis for comparison. DOE intends to decide (1) where to locate the elemental mercury 

storage facility(ies) and (2) whether to use existing buildings, new buildings, or a combination of existing 

and new buildings. DOE’s Preferred Alternative is storage in a combination of an existing facility and a 

new facility at Waste Control Specialists, LLC, near Andrews, Texas. 
Public Comments: On July 2, 2009, DOE issued a Notice of Intent in the Federal Register

(74 FR 31723) soliciting public input on development of this draft EIS, and DOE has considered all 

comments received during the scoping period (July 2 through August 24, 2009) in preparing this draft 

EIS. Comments on this draft EIS may be submitted during the 60-day comment period, which will begin 

upon publication of EPA’s Notice of Availability in the Federal Register. Public hearings on this draft 

EIS will be held during this 60-day comment period. The dates, times, and locations of these public 

hearings will be published in a DOE Federal Register notice and also will be announced through other 

media. DOE will consider any comments received after the comment period ends to the extent 

practicable. 
PREDECISIONAL REVIEW DRAFT - DELIBERATIVE - DO NOT CITE, QUOTE, OR DISTRIBUTE—NOVEMBER 17, 2009 iii

A Message to Stakeholders 

I am pleased to present for your review and comment the Draft Long-Term Management and 

Storage of Elemental Mercury Environmental Impact Statement (Mercury Storage EIS). It is a 

key step in carrying out the intent of Congress in the Mercury Export Ban Act of 2008 to reduce 

mercury in the global environment. The U.S. Environmental Protection Agency and Mesa 

County Board of Commissioners are cooperating agencies on the preparation of this Mercury 

Storage EIS. 

DOE’s goal is to provide safe, secure, long-term mercury storage by establishing a facility(ies) 

that can accept U.S. elemental mercury and begin storage operations by January 2013. The 

Mercury Storage EIS is intended to provide decisionmakers and the public with clear, reliable, 

and credible information about the impacts of the proposed action and reasonable mercury 

storage alternatives. To that end, we have prepared this Summary and Guide for Stakeholders to 

summarize the major components of the full draft environmental impact statement (EIS) and to 

guide readers to additional detail in the complete document. Technical terms have been avoided 

where possible or defined. A short list of acronyms and abbreviations has been included to 

further ensure clarity. You can also find supplementary information on the EIS website at 

www.mercurystorageeis.com and in the Reading Rooms listed in Section 5 of this summary and 

guide. 

I look forward to receiving your comments on this draft EIS, and I hope you will continue to 

participate in the decisionmaking process as we develop the final EIS and the Record of 

Decision. 

David Levenstein

EIS Document Manager 

U.S. Department of Energy 

For information or to submit comments on this Draft Mercury Storage EIS, contact: 

David Levenstein, Document Manager 

Office of Environmental Compliance (EM–41) 

U.S. Department of Energy 

Post Office Box 2612 

Germantown, MD 20874 

Website: http://www.mercurystorageeis.com 

Fax: 877-274-5462 

Summary and Guide for Stakeholders 

v

Table of Contents 

1. Introduction ..........................................................................................................................1

Why Reduce the Amount of Mercury in the Environment?............................................................... 2

What Are DOE’s Objectives in This EIS? ......................................................................................... 3

How Much Mercury Would DOE Manage and Store? ...................................................................... 3

Where Would the Mercury Come From? ........................................................................................... 4

2. What Does This Draft EIS Address?..................................................................................5

Decisions to Be Made......................................................................................................................... 5

Scope of This EIS............................................................................................................................... 5

Resource Areas of Analysis................................................................................................................ 5

Affected Environment ........................................................................................................................ 6

3. Mercury Storage Site Alternatives Considered in This EIS ............................................7

How Were Potential Storage Sites Identified? ................................................................................... 7

Description of Candidate Sites........................................................................................................... 8

What Would the DOE Mercury Storage Facility(ies) Include?........................................................ 14

New Storage Facility Design and Construction ............................................................................... 14

Existing Facility Modification and Upgrades................................................................................... 15

Alternatives Considered but Eliminated from Detailed Analysis.................................................... 17

4. Comparison of Impacts and Alternatives ........................................................................18

Major Conclusions............................................................................................................................ 19

Cumulative Impacts.......................................................................................................................... 23

The Preferred Alternative ................................................................................................................. 24

5. Public Involvement.............................................................................................................26

Public Scoping Meetings.................................................................................................................. 26

Public Comments on the Scope of This EIS..................................................................................... 27

How Can I Participate?..................................................................................................................... 30

Attend a Public Hearing ........................................................................................................................................30

Visit a Reading Room............................................................................................................................................31

Go to the EIS Website............................................................................................................................................32

Submit Comments ..................................................................................................................................................33

Watch for the Final EIS.........................................................................................................................................33

6. Helpful Information ...........................................................................................................34

How This EIS is Organized.............................................................................................................. 34

Finding Answers to Your Questions ................................................................................................ 36

Acronyms and Abbreviations........................................................................................................... 38
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

vi

Figures 

Figure 1. Potential Sources of Mercury in the United States..............................................................4 

Figure 2. Alternative Sites Analyzed for U.S. Department of Energy Storage of Mercury ...........8 

Figure 3. Representation of the Exterior of a New Mercury Storage Facility................................14 

Figure 4. Representation of the Interior of a New Mercury Storage Facility.................................15 

Figure 5. Risk Matrix .............................................................................................................................22

Figure 6. The Mercury Storage Environmental Impact Statement Timeline..................................39 

Tables 

Table 1. Estimated U.S. Mercury Inventory That DOE Could Manage and Store ........................3 

Table 2. General Regions of Influence for the Affected Environment ............................................6 

Table 3. Comparison of Impacts.........................................................................................................20 

Table 4. Summary of Cumulative Impacts Assessment...................................................................25 
Summary and Guide for Stakeholders 

1

1. INTRODUCTION 

The U.S. Department of Energy (DOE) has prepared this Draft Long-Term Management and Storage of 

Elemental Mercury Environmental Impact Statement (Mercury 

Storage EIS) as part of DOE’s process to establish a facility(ies) 

for storing elemental mercury in accordance with the Mercury 

Export Ban Act of 2008 (the Act). The U.S. Environmental 

Protection Agency (EPA) and the Mesa County Board of 

Commissioners are cooperating agencies on this environmental 

impact statement (EIS). 

The text box at left provides a synopsis of the relevant features of 

the Act, while Appendix A of the main volume of this EIS 

contains a full copy of the Act. 

The Act prohibits the sale, distribution, or transfer of elemental 

mercury by Federal agencies to other government agencies and 

private entities, effective October 14, 2008, as well as the export 

of elemental mercury from the United States, effective 

January 1, 2013. Banning the export of mercury from the 

United States is expected to result in surplus inventories. 

Therefore, the Act states that DOE must designate a facility(ies) 

and be ready to accept custody of elemental mercury and begin 

storage operations by January 1, 2013. 

DOE’s purpose and need for action is thus to provide a capability 

for managing and storing elemental mercury on a long-term 

basis. Accordingly, DOE’s proposed action is to construct one or 

more new facilities and/or select one or more existing facilities 

(including modifications as needed) as mandated by Section 5 

of the Act. 

The National Environmental Policy Act of 1969 (NEPA) requires 

Federal agencies to integrate environmental values into their 

decisionmaking by considering the environmental impacts of 

proposed actions and the range of reasonable alternatives to those 

actions. For major Federal actions significantly affecting the 

quality of the human environment, agencies must prepare an EIS, which considers the potentially affected 

environment, including the natural physical environment (e.g., air, water, geology, soils, plant and animal 

life) and the relationship between humans and the environment (e.g., health, safety, jobs, schools, 

housing, cultural resources, and aesthetics). Environmental justice, the process of ensuring that no 

group—ethnic, racial, or socioeconomic—of people bears a disproportionate share of adverse impacts, is 

also a key component of an EIS. The NEPA process emphasizes public outreach to ensure that 

stakeholders are provided opportunities to learn about the proposed action and to provide the Government 

with their input in the form of public comments. 

This Summary and Guide for Stakeholders presents a 

concise overview of the major issues addressed in this 

draft EIS and directs readers to more-detailed information 

in the full document. A compact disk of the full draft EIS 

and appendices is enclosed. 

The Mercury Export Ban Act 

 of 2008 (the Act) 

 The Act bans the export of elemental 

mercury from the United States as of 

January 1, 2013. 

 It prohibits the sale, distribution, or 

transfer of mercury by Federal 

agencies to other government 

agencies and private entities as of 

October 14, 2008. 

 The U.S. Department of Energy 

(DOE) must designate a facility(ies) 

for long-term management and 

storage of mercury generated in the 

United States and have it operational 

by January 1, 2013. 

 Any such facility(ies) must comply 

with applicable requirements of the 

Solid Waste Disposal Act, as 

amended by the Resource 

Conservation and Recovery Act 

(42 U.S.C. 6901 et seq.). 

 The Act does not specify how long 

mercury may require storage at the 

DOE-designated facility(ies). 

 DOE is required to charge a fee to 

cover the cost of mercury storage. 

 The Act requires the U.S. Environmental Protection Agency (EPA) to 

report to Congress on whether to 

expand the export ban to cover one 

or more mercury compounds. This 

report was issued in October 2009. 

 EPA must report to Congress by 

January 1, 2017, on the global supply 

and trade of elemental mercury, 

including whether additional primary 

mercury mining has occurred as a 

consequence of the Act. 

Stakeholders are the people or organizations who 

have an interest in, or may be affected by, a proposed 

action, including the general public; representatives of 

environmental and educational groups, industry, 

unions, and other organizations; and representatives of 

Congress, Federal agencies, American Indian tribes, 

state agencies, and local governments. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2

The Mercury Cycle 

Why Reduce the Amount of Mercury in the Environment? 

Mercury is a naturally occurring element that enters the environment as a result of natural processes 

(e.g., volcanoes, wildfires, surface emissions) and human activities. Mercury and its compounds are 

toxic; therefore, they pose human health and ecological 

risks. The potential effects are widespread because 

mercury is easily dispersed throughout the environment. 

Moreover, the free trade of elemental mercury on the world 

market has encouraged its continued use, resulting in increasingly higher levels of mercury available in 

the global environment. This has increased the risk of neurological and reproductive effects for humans 

and wildlife, and it 

means mercury is a 

pollutant of 

environmental 

concern throughout 

the world. By 

banning the export 

of U.S. mercury, 

Congress anticipated 

reducing the amount 

of mercury available 

worldwide, thus 

reducing the 

associated 

health risks. 

Elemental mercury—the form DOE would manage and store—has long been used in manufacturing 

processes, because it is a good conductor of electricity and it alloys (mixes) readily with other 

metals. Historically, it was used in 

batteries, paint, thermometers, 

thermostats, medical devices such 

as blood pressure monitors, auto 

lighting switches, fluorescent lights, 

and dental fillings. Many of these 

uses have been curtailed in 

recent years. 

For purposes of this environmental impact 

statement, “mercury” refers to elemental 

mercury unless otherwise indicated. 

Mercury was once used extensively in manufacturing. 
Summary and Guide for Stakeholders 

3

What Are DOE’s Objectives in This EIS? 

DOE has developed this draft EIS to evaluate the potential impacts of the proposed action, i.e., to 

establish a facility(ies) for the long-term management and storage of mercury. In accomplishing this, 

DOE is committed to the following overall objectives for its mercury storage program: 

 Protect human health and the environment and ensure the safety of workers and the public. 

 Meet the requirements of the Mercury Export Ban Act of 2008. 

 Comply with applicable Federal, state, and local laws and regulations. 

How Much Mercury Would DOE Manage and Store? 

Based on the best available information, DOE anticipates that approximately 10,000 metric tons 

(11,000 tons) of excess mercury will need to be managed and stored in a facility designed to last at least 

40 years, although more or less mercury could require shorter or longer storage. 

Potential sources of mercury in the United States include mercury that is used in chlorine and caustic soda 

manufacturing (i.e., chlor-alkali industry), reclaimed from recycling and waste recovery activities, and 

generated as a byproduct of gold mining. In addition, DOE currently stores approximately 1,200 metric 

tons (1,300 tons) of mercury at its Y–12 National Security Complex in Oak Ridge, Tennessee. Table 1 

shows the DOE-estimated inventory of mercury that could be available for storage over the next 40 years. 

That estimate does not include U.S. Department of Defense–related mercury (4,400 metric tons 

[4,900 tons]) because the Defense Logistics Agency has already determined to store its mercury inventory 

at the Hawthorne Army Depot in Nevada. 

Table 1. Estimated U.S. Mercury Inventory That DOE Could Manage and Store 

Years Sent 

Quantity in 

Metric Tons 

Source to Storage a (tons) 

DOE Y–12 National Security Complex in Oak Ridge, Tennessee 2013–2014 1,200 

(1,300) 

Closure of four chlor-alkali plants or conversion to non-mercury-cell 

technology 

2013–2019 1,100 

(1,200) 

Waste reclamation and recycling facilities 2013–2052 2,500 

(2,800) 

Byproduct of gold mining 2013–2052 3,700–4,900 

(4,100–5,400) 

Total 8,500–9,700 

(9,400–10,700) 

a For purposes of analysis, it was assumed that the elemental mercury from DOE’s Y–12 National Security Complex could be 

shipped to the DOE-designated storage facility(ies) in the first 2 years of operation; chlor-alkali plant elemental mercury would 

be shipped in the first 7 years of operation; and waste reclamation and recycling facility and gold-mining byproduct elemental 

mercury would be shipped over the entire 40-year period of analysis. 

Key: DOE=U.S. Department of Energy.
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

4

Where Would the Mercury Come From? 

Potential sources of mercury that may require long-term storage are shown in Figure 1. They include: 

four chlor-alkali plants expected to still be using mercury-cell technology beyond 2010; gold mining in 

the state of Nevada, which produces the majority of U.S. byproduct mercury (i.e., the latest available data 

in 2002 report approximately 97 metric tons [107 tons]), and to a lesser extent South Dakota; six 

companies that account for most of the secondary mercury waste reclamation and recycling; and, 

potentially, some or all of the mercury currently stored at the Y–12 National Security Complex. 

Figure 1. Potential Sources of Mercury in the United States 

Estimates of the amount of mercury that DOE will be called upon to manage are uncertain, because, for 

example, mercury from gold mining depends on how much gold is mined. There may be less gold 

mining in the future as existing deposits are depleted, or there could be more mining if additional gold 

deposits are discovered. Similarly, the amount of mercury from waste reclamation and recycling facilities 

will depend on the volume of material processed. That amount may decrease as initiatives to collect 

mercury-containing thermometers, thermostats, switches, and natural-gas-metering devices are 

completed. In addition, some chlor-alkali plants may discontinue mercury-cell processes before 2013. 
Summary and Guide for Stakeholders 

5

2. WHAT DOES THIS DRAFT EIS ADDRESS? 

This EIS concerns the range of reasonable 

alternatives for the long-term safe, secure storage of 

elemental mercury generated in the United States. 

More specifically, this EIS addresses the short- and 

long-term potential health and environmental effects 

of establishing and operating a facility(ies) to 

provide the necessary capability for this storage. 

Decisions to Be Made 

In making long-term mercury management decisions, DOE will consider the results of this EIS, public 

comments, and other relevant factors. DOE intends to make the following decisions: 

 Where to locate the mercury storage facility(ies) 

 Whether to use existing buildings, new buildings, or a combination of existing and new buildings 

for mercury storage 

Scope of This EIS 

This draft EIS includes the following: 

 Identification of potential candidate sites for the mercury storage facility(ies) 

 Consideration of the No Action Alternative 

 Consideration of new construction and modification of existing facilities 

 Potential health and environmental effects, including transportation to each potential storage 

facility(ies), and cumulative effects of establishing and operating a storage facility(ies) at each 

candidate site 

 Comparison of the analytic results for all sites 

 The issues and concerns raised by stakeholders during the scoping period for this EIS, along with 

DOE’s responses 

 The DOE Preferred Alternative 

Resource Areas of Analysis 

This EIS presents the results of DOE’s analysis of potential impacts for each of the alternative candidate 

sites, as well as for a No Action Alternative, as required under NEPA for use as a basis of comparison. In 

this EIS, the No Action Alternative, contrary to the requirements of the Act, assumes DOE would not 

establish a facility(ies) for the long-term storage of elemental mercury. 

Typical Mercury Storage Flasks 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

6

Areas analyzed for each alternative site include: land use and visual resources; geology, soils, and 

geologic hazards; water resources; meteorology, air quality, and noise; ecological resources; cultural and 

paleontological resources; site infrastructure; waste management; occupational and public health and 

safety; ecological risk; socioeconomics; and environmental justice. 

The potential impacts analyzed from construction and modification of a mercury storage facility include 

those related to land disturbance, resource use, air emissions, and employment. Operational impacts, 

including those related to resource use, emissions, and human health effects, are also presented. See 

Section 4, “Comparison of Impacts and Alternatives” of this Summary and Guide. Transportation 

impacts, including those related to air emissions, human health, and ecological risk, are also analyzed. 

The scope of this draft EIS is introduced in this section and detailed further in Section 6. 

Affected Environment 

The affected environment described in this draft EIS includes land use and visual resources; geology, 

soils, and geologic hazards; water resources; meteorology, air quality and noise; ecological resources; 

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

health and safety; socioeconomics; and environmental justice. 

DOE evaluated the environmental impacts of the proposed action within defined regions of influence 

specific to each resource area and site evaluated. Regions of influence encompass the geographic areas 

within which any meaningful impact is expected to occur, and can include the area within which the 

proposed action would take place, the site as a whole, or offsite areas. For example, impacts on historic 

resources were evaluated at specific facility locations within each site, whereas human health risks to the 

general public were assessed for an area within a 16-kilometer (10-mile) radius of the facility location. 

Brief descriptions of the regions of influence for each resource area are given in Table 2. 

Table 2. General Regions of Influence for the Affected Environment 

Environmental Resource Area Region of Influence 

Land use and visual resources The project location, the site, and nearby offsite areas 

Geology, soils, and geologic hazards The project location, the site, and nearby offsite areas 

Water resources The project location, the site, and adjacent surface-water bodies 

and groundwater 

Air quality and noise For air quality, the site and nearby offsite areas potentially 

affected by air pollutant emissions; for noise, project location, the 

site, and surrounding areas, including transportation corridors 

Ecological resources The project location, the site, and nearby offsite areas 

Cultural and paleontological resources The project location and adjacent areas 

Site infrastructure The project location, the site, and local areas supporting the site 

Waste management Site waste management facilities 

Occupational and public health and safety The site, offsite areas within 16 kilometers (10 miles) of the site, 

and the transportation corridors 

Socioeconomics The counties where at least 90 percent of site employees reside 

Environmental justice The area within 16 kilometers (10 miles) of the site and the area 

within 3.2 kilometers (2 miles) of the site as a subset of the 

16-kilometer (10-mile) area 
Summary and Guide for Stakeholders 

7

3. MERCURY STORAGE SITE ALTERNATIVES CONSIDERED IN 

THIS EIS 

As required by NEPA, this EIS evaluates a No Action Alternative to serve as a basis for comparison with 

the action or site alternatives. Under the No Action Alternative, DOE would not establish a facility(ies) 

for long-term management and storage of mercury, as required by the Act. Because the Act prohibits the 

export of mercury after January 1, 2013, companies in the United States would have to find another way 

to manage their excess mercury. Thus, any excess mercury would remain the responsibility of its owners 

or would be sent to commercial waste management facilities. Approximately 1,200 metric tons 

(1,300 tons) of DOE mercury currently stored at the DOE Y–12 National Security Complex in Tennessee 

would continue to be managed and stored at this location. However, to meet the requirements of the Act, 

DOE proposes to designate one or more existing or new facilities for the long-term management and 

storage of mercury. 

How Were Potential Storage Sites Identified? 

To begin the process of identifying potential mercury storage sites, DOE published a Request for 

Expressions of Interest in Federal Business Opportunities and the Federal Register in March 2009. DOE 

also issued an internal memorandum asking offices within DOE to determine whether they have facilities 

that could be used for mercury storage, as well as the feasibility of new construction. 

Positive responses were received from the following Government sites and private companies: 

 DOE Grand Junction Disposal Site, Grand Junction, Colorado 

 DOE Hanford Site, Richland, Washington 

 Hawthorne Army Depot, Hawthorne, Nevada 

 DOE Idaho National Laboratory, Idaho Falls, Idaho 

 DOE Kansas City Plant, Kansas City, Missouri 

 Lowland Environmental Services et al., Knoxville, Tennessee 

 Meritex Enterprises, Inc., Lenexa, Kansas 

 DOE Savannah River Site, Aiken, South Carolina 

 Veolia ES Technical Solutions, LLC, Henderson, Colorado 

 Waste Control Specialists, LLC, Andrews, Texas 

At the same time, DOE developed the following criteria for identifying candidate sites within the scope of 

this EIS: 

 The facility(ies) will not create significant conflict with any existing DOE site mission and will 

not interfere with future mission compatibility. 

 The candidate location has an existing facility(ies) suitable for mercury storage with the 

capability and flexibility for operational expansion, if necessary. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

8

 As required by the Act, the facility(ies) is, or potentially will be, capable of complying with 

Resource Conservation and Recovery Act (RCRA) permitting requirements (see Chapter 5, 

Sections 5.2.4 and 5.3), including siting requirements. 

 The facility(ies) has supporting infrastructure and a capability or potential capability for flooring 

that would support mercury loadings. 

 Storage of mercury at the facility(ies) is compatible with local and regional land use plans, and 

new construction would be feasible, as may be required. 

 The facility(ies) is accessible to major transportation routes. 

 The candidate location has sufficient information on hand to adequately characterize the site. 

Description of Candidate Sites 

Applying the DOE screening criteria confirmed that seven of the ten potential storage sites appeared to be 

reasonable alternative locations (see Figure 2). The seven candidate sites evaluated in this EIS are briefly 

described below and in more detail in Chapter 2. The reasons for not evaluating three of the ten potential 

storage sites are described on page 17 “Alternatives Considered but Eliminated from Detailed Analysis.” 

Figure 2. Alternative Sites Analyzed for U.S. Department of Energy Storage of Mercury 
Summary and Guide for Stakeholders 

9

DOE Grand Junction Disposal Site, Colorado 

The Grand Junction Disposal Site is located on DOE-owned land, 29 kilometers (18 miles) southeast of 

Grand Junction, Colorado. The site occupies 146 hectares (360 acres) in a rural setting. It is accessed 

from a two-lane paved road off U.S. Route 50. Currently, a 38-hectare (94-acre) area is used for disposal 

of uranium mill tailings. The entire site is surrounded by a perimeter fence and it has a gated entrance. 

The site has road/truck access, but no direct rail access. A new mercury storage facility would be located 

in the northwest corner of the site. It would occupy 3.1 hectares (7.5 acres). 

Grand Junction 

Disposal Site 

In 1996, DOE and Mesa County Board of Commissioners (Mesa County) entered into a Memorandum of 

Understanding (1996 MOU) to provide meaningful consultation with and participation of Mesa County in 

DOE’s use of the Grand Junction Disposal Site. The position of Mesa County, a cooperating agency for 

purposes of this EIS, is that use of the Grand Junction Disposal Site is restricted per the 1996 MOU 

between DOE and Mesa County, and that the 1996 MOU governs any proposed mercury storage at the 

Grand Junction Disposal Site. Mesa County believes the agreement is clear and that Grand Junction 

Disposal Site is only to be used for uranium mill tailings, almost exclusively of local origin. Mesa 

County further asserts that DOE assured the citizens of Mesa County that the disposal site would never be 

used to store any wastes other than mill tailings. Mesa County believes DOE is obligated to honor this 

agreement. 

DOE acknowledges that the 1996 MOU stipulates that DOE must consult with Mesa County regarding 

decisions related to operations at the site. DOE will evaluate the applicability of the 1996 MOU to the 

long-term management and storage of elemental mercury at the Grand Junction Disposal Site to 

determine whether the 1996 MOU would affect the viability of this site as a reasonable alternative. 

DOE Hanford Site, Washington 

The DOE Hanford Site occupies 151,775 hectares (375,040 acres) along the Columbia River in 

southeastern Washington State. It is owned by the Federal Government and managed by DOE. It is 

situated to the northwest of the Tri-Cities (Richland, Kennewick, and Pasco) and encompasses large areas 

of open land interspersed by a number of industrial facilities. The site is accessed from Richland via 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

State Route 240 and George Washington Way. The new mercury storage facility would be located in the 

Central Waste Complex of 200-West Area. Both truck and rail access are available. 

Central Waste 

Complex 

at the 

Hanford Site 

Hawthorne Army Depot, Nevada 

The Hawthorne Army Depot encompasses 59,500 hectares (147,000 acres) of open land in the high 

desert of southwestern Nevada. The installation is accessible from U.S. Route 95. The Central 

Magazine Area, the area within which mercury would be stored, is located about 6.4 kilometers (4 miles) 

north of the town of Hawthorne, Nevada. Under this alternative, DOE would designate up to 

29 buildings in the Central Magazine Area for DOE mercury storage. There are 14 other similar 

buildings in that area which are currently designated for storage of Defense Logistics Agency mercury. 

This would provide approximately 27,000 square meters (290,000 square feet) of space for DOE 

storage of mercury. Modifications to the proposed buildings would be required prior to DOE storage 

of mercury and could include reinforcing and epoxy-sealing the floor; installing spill control measures, 

utilities, and security monitors; and servicing the rail spur. Both truck and rail access are available. 

Existing 

Storage 

Buildings in 

the Central 

Magazine 

Area at the 

Hawthorne 

Army Depot 

10
Summary and Guide for Stakeholders 

11

DOE Idaho National Laboratory, Idaho 

Idaho National Laboratory is owned by DOE and occupies a 230,323-hectares (569,135-acre) area 

in southeastern Idaho. It consists of several facility areas in an expanse of otherwise undeveloped, 

cool desert terrain. It is 39 kilometers (24 miles) west of Idaho Falls, Idaho, and is accessed from that city 

via U.S. Route 20. Two options for long-term storage of mercury have been identified: new construction 

and reuse of existing buildings. New-construction would take place at the Idaho Nuclear Technology and 

Engineering Center. Current operations at the center include management of sodium-bearing waste, spent 

nuclear fuel storage, nuclear material disposition, environmental remediation, and demolition of excess 

facilities. The reuse of existing buildings would take place at the Radioactive Waste Management 

Complex and would involve reuse of up to seven storage buildings in the Transuranic Storage Area. 

These seven buildings could provide a total of 19,000 square meters (205,000 square foot) of storage 

space. Truck and rail access are available at both locations. 

Idaho Nuclear 

Technology 

and 

Engineering 

Center at Idaho 

National 

Laboratory 

Existing 

Storage 

Buildings 

at the 

Radioactive 

Waste 

Management 

Complex at 

Idaho National 

Laboratory 

DOE Kansas City Plant, Missouri 

The Kansas City Plant is a DOE-owned site situated on 55 hectares (136 acres) of the 125-hectare 

(310-acre) Bannister Federal Complex. It is located within Kansas City, Missouri, 19 kilometers 

(12 miles) south of the downtown area. The surrounding area is characterized by single- and multiplefamily dwellings, commercial establishments, industrial districts, and public use lands. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

Existing Main 

Manufacturing 

Building at the 

Kansas City 

Plant 

The plant, which is very compact and highly developed, is served by two four-lane city streets: 

Troost Avenue to the west and Bannister Road to the south. The Kansas City Plant has adequate floor 

space in existing buildings to support a mercury storage facility. Both truck and rail access are available. 

DOE Savannah River Site, South Carolina 

The Savannah River Site is a DOE-owned site that occupies 80,290 hectares (198,400 acres) in 

southwestern South Carolina. The site is approximately 19 kilometers (12 miles) south of Aiken, 

South Carolina, and 24 kilometers (15 miles) southeast of Augusta, Georgia. The Savannah River Site is 

accessed via South Carolina Highway 125 from Augusta and South Carolina Highway 19 from Aiken. 

About 90 percent of the site consists of natural forests and managed pine plantations; the surrounding area 

is largely rural. Under this alternative, a new facility would be constructed in E Area, which is 

134 hectares (330 acres) designated for industrial use. Truck and rail access are available. 

E Area 

at the 

Savannah 

River Site 

12
Summary and Guide for Stakeholders 

13

Waste Control Specialists, LLC, Texas – DOE’s Preferred Alternative 

Waste Control Specialists, LLC, is a commercial entity that owns and operates a 541-hectare (1,338-acre) 

site for the treatment, storage, and landfill disposal of various hazardous and radioactive wastes. 

The site is located approximately 50 kilometers (31 miles) west of Andrews, Texas, and 10 kilometers 

(6 miles) east of Eunice, New Mexico. It is surrounded by a 5,460-hectare (13,500-acre) tract of land also 

owned by Waste Control Specialists. The facility is currently permitted under RCRA for storage of 

hazardous waste. Under this alternative, a new facility would be constructed either north or south of the 

existing commercial hazardous waste storage facilities. The Container Storage Building, within the 

Waste Control Specialists site, is covered under the existing RCRA permit and could be used to store 

mercury on an interim basis until the new storage facility could be constructed. The Container Storage 

Building is configured to store hazardous waste, would be suitable for storage of mercury, and could 

provide up to approximately 2,650 square meters (28,500 square feet) of storage space. Truck and rail 

access are available at the site. 

Waste 

Control 

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

14

What Would the DOE Mercury Storage Facility(ies) Include? 

The DOE mercury storage facility(ies) would include the following characteristics: 

 RCRA-regulated/permitted design with proper spill containment features and emergency 

response procedures 

 Security and access control 

 Fire suppression systems 

 Ventilated storage area(s) 

 Fully enclosed weather-protected building(s) 

 Reinforced-concrete floors able to accommodate mercury storage 

The mercury storage facility(ies) would have areas for administration, receiving and shipping, storage, 

and handling. The storage area would constitute approximately 90 percent of the floor space. The 

storage area would generally be a large open space similar to a warehouse, where storage, inspection, and 

monitoring could be effectively performed. The mercury storage facility(ies) would accept two types of 

mercury containers: 3-liter (34.6-kilogram [76-pound]) flasks and 1-metric-ton (1.1-ton) containers. 

Other containers could be approved and accepted on a case-by-case basis. The 3-liter (34.6-kilogram 

[76-pound]) flasks would be single-, double- or triple-stacked, and the 1-metric-ton (1.1-ton) containers 

would be single- or double-stacked. 

New Storage Facility Design and Construction 

If a new mercury storage facility(ies) were built, it would be designed and constructed to provide the 

safe and secure long-term storage of up to 10,000 metric tons (11,000 tons) of mercury for at least 

40 years. Figure 3 illustrates what the exterior of a new mercury storage facility(ies) might look like, and 

Figure 4 provides a potential conceptual layout of the interior and how the mercury containers might be 

stored. Appendix C provides additional details and data related to the requirements for construction and 

operations of a new facility(ies). 

Figure 3. Representation of the Exterior of a New Mercury Storage Facility 
Summary and Guide for Stakeholders 

15

Figure 4. Representation of the Interior of a New Mercury Storage Facility 

A new mercury storage facility(ies) could require up to approximately 13,610 square meters 

(146,500 square feet) of storage space. The height of the building(s) would be approximately 6.1 meters 

(20 feet) to accommodate the potential for triple stacks of pallets of 3-liter (34.6-kilogram [76-pound]) 

flasks. The new facility would have a reinforced-concrete floor, strong enough to withstand the heavy 

loads from mercury storage. The floors would be treated with an epoxy sealant to add strength and 

spill containment properties. Lighting, ventilation, fire suppression, and security systems would be 

incorporated into the facility design. Monitoring systems could include security alarms and surveillance 

cameras. A new full size standalone facility would encompass approximately 3.1 hectares (7.5 acres). 

The facility would be RCRA regulated and permitted, and, as such, would require secondary containment 

(e.g., curbing), regular inspection of stored materials, strict record-keeping, and periodic reporting to 

the state. 

Existing Facility Modification and Upgrades 

Existing facilities were considered only if their former use is consistent with the storage of hazardous 

materials, thus keeping the need for modifications to a minimum. Alternative locations with existing 

facilities analyzed in this Mercury Storage EIS are the storage buildings at the Hawthorne Army Depot, 

the Radioactive Waste Management Complex at the DOE Idaho National Laboratory, and the Main 

Manufacturing Building at DOE’s Kansas City Plant in Missouri. The Container Storage Building at 

the Waste Control Specialists site was also considered for interim storage pending construction of a new 

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

16

Loading Dock at a U.S. Department of Energy Storage Facility 

Regardless of the candidate site chosen, mercury storage operations would include the following: 

 Facility Security. The mercury storage facility(ies) would be within a fenced and secure area 

with controlled access to the premises. Only authorized vehicles and personnel would be allowed 

access within the facility boundary. Security alarms, surveillance cameras, and security guards 

may be used. 

 Shipping and Receiving. Mercury containers would be inspected and prepared for storage at the 

originating facility prior to shipment to the DOE mercury storage facility(ies). All containers 

would have sufficient integrity to be transported and placed in long-term storage. Shipments of 

mercury would most likely be conducted by third-party transportation companies in accordance 

with regulations governing transportation of hazardous waste. 

 Inspections. Upon arrival at the mercury storage facility, concentrations of mercury vapor would 

be measured to verify that they are below actionable levels. A visual inspection would follow to 

detect obvious problems that may have occurred during transport. If initial inspections and 

manifest documentation are acceptable, the mercury would be moved to the Shipping and 

Receiving Area where additional visual inspections would be performed. The mercury would 

then be moved to the Handling Area for additional verification that it meets waste acceptance 

criteria (e.g., 99.5 percent purity). Containers and pallets that pass the acceptance/verification 

process would be placed into long-term storage. Containers that fail inspection would be returned 

to the sender. 

 Monitoring and Long-Term Storage. Regular inspections of the mercury containers would be 

performed within the Storage Area(s) to ensure that no containers are corroding or leaking. These 

Storage Area(s) would be naturally ventilated when not occupied; however, prior to and during 

occupancy, they would be ventilated using high-volume industrial-sized roof- or wall-mounted 

vent fans. Monitoring would include testing the airspace for elevated concentrations of mercury 

vapors. 

 Record-Keeping. Manifests, inspection records, training logs, and required reports would need 

to be completed regularly. These documents would be stored in the Office Administration Area. 
Summary and Guide for Stakeholders 

17

Alternatives Considered but Eliminated from Detailed Analysis 

The following alternatives were initially considered but were not evaluated in detail in this EIS: 

 Storage at the DOE Y–12 National Security Complex, Oak Ridge Reservation. The Act 

specifies that the DOE-designated mercury storage facility(ies) shall not include Y-12 National 

Security Complex or any other portion or facility at the Oak Ridge Reservation in Oak Ridge, 

Tennessee (42 U.S.C. 6939f(a)(1)). DOE may sometimes include reasonable alternatives that are 

outside the scope of what Congress has approved. However, in the case of this action, where 

Congress has expressly prohibited a potential alternative, DOE finds that it is reasonable to 

forego its consideration. Accordingly, DOE has eliminated this option as an action alternative. 

 Fuels and Materials Examination Facility at the Hanford Site. The Fuels and Materials 

Examination Facility at Hanford was constructed in the late 1970s and early 1980s to perform 

fuel fabrication and development and examination of breeder reactor fuels. Although it is a 

robust building with thick walls and heavy shielding, the design and internal configuration are not 

optimal for waste storage; the building is not RCRA permitted; and modifications that would be 

required would be substantial. Therefore, DOE eliminated this facility from further consideration 

as a potential site. 

 N and F Area Buildings at the Savannah River Site. This option is not compatible with future 

site missions. DOE plans to consolidate waste storage operations followed by decontamination 

and demolition of storage buildings in N Area. Therefore, DOE eliminated N Area existing 

buildings from further consideration. Buildings in F Area were previously committed to support 

the mixed oxide fuel program and would not be available to support long-term storage of 

mercury. 

 Veolia ES Technical Solutions, LLC, of Henderson, Colorado, and a business partnership, 

Lowland Environmental Services, et al., of Knoxville, Tennessee, responded to the Request for 

Expressions of Interest DOE published in the Federal Register. Neither company proposed a 

specific candidate site to be evaluated. Lowland later withdrew its Expression of Interest, and 

both were eliminated from detailed study in this Mercury Storage EIS. 

 Meritex Enterprises, Inc., of Lenexa, Kansas, submitted a potential site in Cumberland Furnace, 

Tennessee, for consideration by DOE. This site is a commercial subterranean storage facility 

developed within a former limestone mine. Due to concerns about permitting and operating an 

underground facility for long-term storage of mercury and concerns about mercury storage being 

incompatible with storage of other materials, DOE has eliminated this option from further 

consideration. 

 Multiple-Site Strategy – DOE considered the possibility of using a “hybrid” or multiple-site 

strategy composed of candidate sites being evaluated in this Mercury Storage EIS. DOE 

eliminated such a strategy from further evaluation because the duplicative resources that would 

be required would not be cost-effective. 

 Treatment Alternatives. The EPA has not yet established treatment and disposal standards for 

the elemental mercury waste DOE would store. Therefore, DOE is not considering treatment and 

storage or disposal for detailed evaluation in this Mercury Storage EIS. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

18

 Transportation Options. This draft EIS contemplates transport of mercury from current 

locations to the DOE storage facility(ies) by truck or rail. Transportation by air is not analyzed 

because of the additional cost and handling required to move the mercury to and from the 

airports. The weight of mercury 

would limit the amount of mercury 

that could be transported per trip, 

resulting in much higher costs for 

air transit. The movement of 

mercury within the continental 

United States by barge is not a 

reasonable option due to the limited 

number of barge routes and the 

additional handling required to 

move the mercury to and from the 

barge route. 

4. COMPARISON OF IMPACTS AND ALTERNATIVES 

The overall conclusion of the impact analyses in this EIS is that there would be no major differences in 

impacts on resource areas among the mercury storage site alternatives. 

Table 3 presents a comparison of impacts on resources from the transportation, receipt, and long-term 

storage of mercury at the candidate mercury storage sites. Environmental consequences for all resource 

areas are summarized further in Chapter 2 and discussed in detail in Chapter 4. 

The No Action Alternative would affect all sources of mercury and would involve various mercury 

storage locations, many of which are undetermined; therefore, these locations are not presented in Table 3 

with the action alternatives. Excess mercury that could not be sold would be stored to the extent allowed 

by law. Some mercury would likely be considered waste and would be stored in accordance with law. 

Such storage would not necessarily occur at the sites identified as potential sources of excess mercury. 

This storage service might be provided by a commercial waste management company or companies. In 

brief, such facilities could vary in location, size, natural and human environments, and in the nature of 

their operations. Because of the various sites and circumstances in which mercury would be stored under 

the No Action Alternative, environmental consequences would be highly speculative. Non-DOE storage 

facilities may be constructed and some non-DOE storage sites may need to modify their storage capacity 

by constructing additional storage space. It could be argued that the biggest impact of the No Action 

Alternative would be widely dispersed storage. The potential benefit of Federal action would be longterm storage and maintenance of this material as opposed to continued, dispersed storage by multiple 

private entities. The approximately 1,200 metric tons (1,300 tons) of DOE mercury currently stored in 

35,000 of the 3-liter (34.6-kilogram [76-pound]) flasks at the Y–12 National Security Complex would 

continue to be managed and stored in this location. No new construction would be required at the 

Y–12 National Security Complex, nor would any incremental increase in impacts on resource areas occur 

because storage operations at the Y–12 National Security Complex would not change. A more-detailed 

discussion comparing the impacts of the No Action Alternative with the action alternatives can be found 

in Chapter 2, Section 2.7. 
Summary and Guide for Stakeholders 

19

Major Conclusions 

The impacts on the various resource areas at each site from construction and operation of a mercury 

storage facility(ies) would range from none to minor. No resource area at any site evaluated was 

predicted to be subject to impacts greater than minor. The analyses in this EIS support the following 

conclusions: 

 Impacts on land use and visual resources are expected to range from negligible to minor at all 

candidate sites. 

 In the areas of geology, soils, and geologic hazards, construction of a new storage facility would 

expose surface soil for up to 6 months. Although unlikely to occur over the 40-year analysis 

period, geologic hazards such as earthquakes could potentially have an adverse effect on a mercury 

storage facility(ies). However, design for construction of a new facility or modification of existing 

buildings would take seismic risk into consideration to minimize potential adverse impacts. 

 Construction and/or operation of a mercury storage facility(ies) are not expected to have any 

impact on surface-water or groundwater resources. Under all alternatives, best management 

practices, including adherence to an integrated contingency plan and spill prevention, 

control, and countermeasures plan for mercury storage would be employed to prevent 

spills and releases, including the use of spill trays under mercury containers, spill containment 

features, and regular inspections. 

 Minor, short-term (6-month) air quality impacts would occur under alternatives involving 

construction of a new storage facility(ies). Impacts would include a small increase in air pollutant 

emissions from activities in the immediate vicinity of the construction site during working hours. 

 Air emissions associated with operations using 

existing buildings for mercury storage would be 

negligible and limited to employee vehicles, 

trucks, semiannual testing of emergency 

generators, and small amounts of mercury 

vapor from storage containers or residual 

contamination, where applicable. Occasionally, 

some mercury vapors would result from 

repackaging of mercury in new containers. The 

Handling Area would be outfitted with a vacuum 

air exhaust and mercury vapor filter that would 

maintain air emissions exhausted to the outside 

at negligible concentrations. 

 Engine exhaust emissions from transporting 

mercury would be in proportion to the number 

of miles required to transport the mercury to the storage facility(ies). Truck and/or rail transport 

from various locations to the DOE long-term mercury storage facility(ies) would generate engine 

exhaust air emissions along routes of transport. Peak exhaust emissions from transport of 

mercury are expected to occur in 2013, the first year of facility(ies) operation. The frequency of 

truck and/or rail shipments is expected to decrease over time. 

Air Sampling at a 

U.S. Department of Energy Site 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

20

Table 3. Comparison of Impacts 

Mercury Storage in Existing Buildings 

Key Resource Areas 

Idaho National Laboratory – 

RWMC 

Hawthorne 

Army Depot DOE Kansas City Plant 

Land use and visual 

resources 

No additional land use or visual resource impacts. 

Geology and soils None Utility connections may 

require minor trenching. None 

Earthquake risk Risk of slight damage to ordinary 

buildings. 

Risk of considerable damage 

to ordinary buildings. 

Negligible risk of damage. 

Water resources Negligible water use for 

modifications and operations 

compared with availability. No 

impact on water resources from 

construction or normal 

operations; located above 

sole-source aquifer; negligible 

risk from flooding. 

Negligible water use for 

modifications and operations 

compared with availability. 

No impact on water 

resources from construction 

or normal operations; 

negligible risk from flooding.

Negligible water use for modifications and 

operations compared with availability. No 

direct impact on water resources from 

construction or normal operations, but close 

proximity to surface-water bodies; existing 

system protects site from riverine flooding but 

must be manually operated. 

Air quality Negligible increase in air emissions from modification of existing buildings. 

Emissions from operations would be limited to employee vehicles, trucks, periodic generator testing and venting 

of residual mercury vapors. Operational emissions would not exceed air quality standards. Transport of mercury 

would result in negligible emissions of criteria and toxic pollutants. 

Site infrastructure Negligible impact; existing site capacity would easily meet increased utility demands. 

Occupational and public 

health and safety 

Normal operations a SL-I consequences and negligible risk to involved workers, noninvolved workers, and members of the public at all 

sites. 

Facility accidents a Consequences range from SL-I to -II with an associated negligible-to-low risk to involved workers and 

noninvolved workers from both inside and outside spills. Consequences of SL-I with an associated negligible risk 

to public receptors from inside and outside spills. 

Transportation 

Annual truck accident 

fatalities b 9.2×10-4 1.1×10-3 7.8×10-4

Truck accident – human 

health a

For spillages of mercury onto the ground, consequences could be SL-II with a low risk under Truck Scenario 2 

and a negligible risk under Truck Scenario 1. Consequences of these scenarios could also be SL-III, but with a 

negligible risk. For transportation accidents with fires, acute-inhalation consequences could be at SL-I with a 

negligible risk under both truck scenarios. The corresponding consequences following deposition on the ground 

could be SL-I with a negligible risk. For direct spillages of mercury into water, the consequences could be 

SL-I or -II with a negligible-to-low risk (but with a large degree of uncertainty). 

Annual rail accident 

fatalities b 1.5×10-4 1.6×10-4 1.0×10-4

Rail accident – human 

health a

For spillages of mercury onto the ground, consequences could be SL-II with a negligible risk. Consequences 

could also be SL-III, but with a negligible risk. For transportation accidents with fires, acute-inhalation 

consequences could be at SL-I with a negligible risk. The corresponding consequences following deposition on 

the ground could be SL-I with a negligible risk. For direct spillages of mercury into water, the consequences 

could be SL-I or -II with a negligible-to-low risk (but with a large degree of uncertainty). 

Ecological impacts a For truck or railcar spills with a pallet fire, consequences could range from SL-I to -IV for both dry and wet 

deposition pathways, with wet deposition potentially having somewhat greater consequences. The associated risk 

to ecological receptors would range from negligible to high except in the case of wet deposition with rail transport, 

for which the risk would be negligible to all receptors. The highest ecological risk would be to sediment-dwelling 

biota and soil invertebrates in the case of truck transportation accidents with fires and dry deposition. In contrast, 

risk to the red-tailed hawk would be negligible in all transportation scenarios. 

Environmental justice 

None None 

A transportation accident at or near the facility 

could disproportionately impact low-income 

and/or minority individuals. 

Key: DOE = U.S. Department of Energy; INTEC = Idaho Nuclear Technology and Engineering Center; RWMC = Radioactive Waste 

Management Complex; SL = severity level. 

Note: Yellow shading indicates resource areas with increased potential for impacts compared with other alternatives. 

 =Mercury Storage in Existing Buildings, =Mercury Storage in New Buildings 
Summary and Guide for Stakeholders 

21

Mercury Storage in New Buildings 

DOE Grand Junction 

Disposal Site 

DOE Hanford 200-West 

Area Site 

DOE Savannah River Site 

E Area 

Waste Control 

Specialists, LLC 

DOE Idaho National 

Laboratory – INTEC 

Land use of 3.1 hectares (7.5 acres) and visual impacts on landscape would be minimal compared with total available site area. (Note: For 

Grand Junction Disposal Site only: 1996 Memorandum of Understanding possible restriction on land use and current zoning – under evaluation.

Minor trenching for concrete footers and utility connections. Small inconsequential consumption of geologic resources. Soil disturbance and 

increased risk of soil erosion for up to 6 months during construction activities. 

Risk of slight damage to 

ordinary buildings. 

Risk of slight-to-moderate 

damage to ordinary 

buildings. 

Risk of slight-to-moderate 

damage to ordinary 

buildings. 

Risk of slight damage to ordinary buildings. 

Negligible water use for construction and operations compared with availability. No impact on water 

resources from construction or normal operations; negligible risk from flooding. 

Negligible water use for 

construction and operations 

compared with availability. 

No impact on water resources 

from construction or normal 

operations; located above 

sole-source aquifer; minor risk 

from riverine flooding. 

Short-term increase in air pollutant emissions from construction activities, including use of heavy equipment and trucks. Emissions from 

operations would be limited to employee vehicles, trucks, periodic generator testing and venting of residual mercury vapors. Operational 

emissions would not exceed air quality standards. Transport of mercury would result in negligible emissions of criteria and toxic pollutants. 

Moderate impact; electrical 

capacity would have to be 

increased. No public water 

supply. No rail access. 

Negligible impact; existing site capacity would meet increased demands. 

SL-I consequences and negligible risk to involved workers, noninvolved workers, and members of the public at all sites. 

Consequences range from SL-I to -II with an associated negligible-to-low risk to involved workers and noninvolved workers from both inside 

and outside spills. Consequences of SL-I with an associated negligible risk to public receptors from inside and outside spills. 

8.7×10-4 1.2×10-3 9.4×10-4 1.0×10-3 9.2×10-4

For spillages of mercury onto the ground, consequences could be SL-II with a low risk under Truck Scenario 2 and a negligible risk under 

Truck Scenario 1. Consequences of these scenarios could also be SL-III, but with a negligible risk. For transportation accidents with fires, 

acute-inhalation consequences could be at SL-I with a negligible risk under both truck scenarios. The corresponding consequences following 

deposition on the ground could be SL-I with a negligible risk. For direct spillages of mercury into water, the consequences could be SL-I or -II 

with a negligible-to-low risk (but with a large degree of uncertainty). 

1.3×10-4 1.9×10-4 1.2×10-4 1.6×10-4 1.5×10-4

For spillages of mercury onto the ground, consequences could be SL-II with a negligible risk. Consequences could also be SL-III, but with a 

negligible risk. For transportation accidents with fires, acute-inhalation consequences could be at SL-I with a negligible risk. The 

corresponding consequences following deposition on the ground could be SL-I with a negligible risk. For direct spillages of mercury into 

water, the consequences could be SL-I or -II with a negligible-to-low risk (but with a large degree of uncertainty). 

For truck or railcar spills with a pallet fire, consequences could range from SL-I to -IV for both dry and wet deposition pathways, with wet 

deposition potentially having somewhat greater consequences. The associated risk to ecological receptors would range from negligible to high 

except in the case of wet deposition with rail transport, for which the risk would be negligible to all receptors. The highest ecological risk 

would be to sediment-dwelling biota and soil invertebrates in the case of truck transportation accidents with fires and dry deposition. In 

contrast, risk to the red-tailed hawk would be negligible in all transportation scenarios. 

None None 

A transportation accident at 

or near the facility could 

disproportionately impact 

minority individuals. 

No disproportionate 

impacts on low 

income and/or 

minority individuals 

None 

a

 Consequences are presented by SLs, with SL-I representing negligible-to-very-low consequences and SL-IV representing the most severe 

consequences. SLs are defined in Appendix D, Section D.1.1.2. b

 Annual fatalities for truck or rail transportation are due to mechanical impacts only and represent the predicted annual average occurrence 

of an accident involving a fatality over the 40-year analysis period of this environmental impact statement. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

22

 Noise levels would not increase substantially above background levels at any of the 

candidate sites. 

 There would be negligible impacts on ecological resources at candidate sites whether a new 

facility(ies) is built or existing buildings are used. 

 No impacts on cultural and paleontological resources are expected under site alternatives 

involving the use of existing buildings because no new construction or external modifications of 

the buildings would be required. New facility construction would result in negligible impacts on 

cultural resources because it would occur in previously disturbed industrialized areas, except at 

the DOE Grand Junction Site in Colorado, where additional analysis is needed. 

 Adverse impacts on a potential site’s infrastructure could occur if available capacity is 

approached or exceeded. Infrastructure includes roads and railways, electricity, fuel, and water 

supplies. Existing utility infrastructure is adequate and could easily accommodate utility 

demands for facility construction and operations at all candidate sites except at the DOE Grand 

Junction Disposal Site in Colorado. 

 Impacts on the site’s waste management infrastructure of construction and operation of a 

mercury storage facility(ies) would be negligible under all alternatives. 

 Impacts on human health during normal operations at the mercury storage facility(ies) were 

determined to be negligible for workers and the public under all alternatives evaluated. Risks 

were determined using the risk matrix approach, which defines levels of risk in terms of 

frequency of release and severity of consequence (see Figure 5). DOE, EPA, and other 

Government agencies use this approach. Events have a high (level IV) frequency if they occur 

once in 100 years or more frequently; 

moderate (level III) between once in 

10,000 years and once in 100 years; low 

(level II) between once in 1 million years 

and once in 10,000 years; and negligible 

(level I) less than once in 1 million years. 

Consequence severity levels depend on the 

receptor (human or ecological) and the 

pathway (e.g., inhalation or ingestion). For 

example, for acute (up to about 8-hour) 

inhalation exposures, severity level IV 

corresponds to the possibility of fatality; 

severity level III to severe, nonlethal health 

effects; severity level II to reversible health 

effects; and severity level I to negligible 

health effects or minor irritation. Risks are 

considered negligible if either frequency or 

severity is at level I. Frequency levels and 

severity levels are discussed in more detail 

in Chapter 4, Section 4.2.9.1.1, and 

Appendix D, Section D.1.1. 

Figure 5. Risk Matrix 
Summary and Guide for Stakeholders 

23

 Human health impacts from facility accidents would range from severity level I to level II with 

an associated negligible to low risk at all candidate sites evaluated.

Transportation impacts under all alternatives are dependent on the method of transportation 

(i.e., truck or rail), the number of miles traveled, and the nature of the accident. For truck travel, 

the projected frequency of fatalities due to mechanical impact would range from 1.2 × 10-3 to 

9.4 × 10-4 per year for the action alternatives. For rail travel, the range would be slightly lower 

from 1.0 × 10-4 to 1.9 × 10-4 fatalities per year. In addition to the possibility of fatal accidents due 

to mechanical impact, exposure to mercury from spills could impact human health. For truck 

spills onto the ground, the consequences could range from severity level II with low risk to 

severity level III with negligible risk. For rail spills onto the ground, the consequences could 

range from severity level I to III, all with negligible risk. For truck or rail spills into water, the 

consequences could be as high as severity level II with negligible-to-low risk. For truck and 

rail spills with fire, the consequences from the inhalation pathway could be severity level II 

with low risk or as high as severity level III with negligible risk. For truck or rail spills with 

fire, the consequences from deposition pathways could be severity level I with an associated 

negligible risk. 

Socioeconomic impacts would be negligible to minor on overall employment and population 

trends under all alternatives. 

The minimal increase in the number of vehicle trips projected for construction and operations of a 

mercury storage facility(ies) over baseline traffic would be negligible for all alternative sites. 

Census data indicate that minority and/or low-income populations are present within the 

16-kilometer (10-mile) region of influence (ROI) at the DOE Kansas City Plant, the DOE 

Savannah River Site, and Waste Control Specialists. However, environmental justice analyses 

for this EIS indicate that no disproportionately high and adverse effects on minority or lowincome populations would be expected at any of the candidate sites due to construction or 

operations of a mercury storage facility. Within a smaller 3.2-kilometer (2-mile) radius, there are 

disproportionately high minority and/or low-income populations at the DOE Kansas City Plant. 

At the DOE Savannah River Site several of the minority blocks are adjacent to transportation 

arteries. Therefore, it would be reasonable to conclude that a transportation accident at or near 

the facility could impact minority and low-income populations disproportionately at the DOE 

Kansas City Plant or the DOE Savannah River Site.









Cumulative Impacts 

Cumulative impacts are those impacts on the environment that would result from the proposed action 

when added to other past, present, and reasonably foreseeable future actions. Actions that may contribute 

to cumulative impacts include on- and offsite projects conducted by government agencies, businesses, or 

individuals within an ROI of 16 kilometers (10 miles) of the actions considered. 

Projected impacts on the various resource areas of constructing and operating a mercury storage facility 

range from none, to negligible, to minor. Those resource areas that were predicted to be impacted in 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 not analyzed since there 

would be either no or only a very small incremental increase in impacts on the resources within the ROI. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

24

Regardless of the projected level of impact, land disturbance associated with new construction and air 

quality impacts resulting from mercury emissions were evaluated for their potential to contribute to 

cumulative impacts within the ROI. Based on the criteria noted above, the analysis included an 

evaluation of air quality for all sites; land use for the DOE Grand Junction Disposal Site, DOE Hanford 

Site, DOE Idaho National Laboratory, DOE Savannah River Site, and Waste Control Specialists, LLC; 

visual resources for the Grand Junction Disposal Site and Waste Control Specialists, LLC; infrastructure 

for the Grand Junction Disposal Site; and ecological resources for the Waste Control Specialists, LLC. 

As presented in Table 4, it was determined that the potential contribution to cumulative impacts on those 

resource areas evaluated would be negligible. 

The Preferred Alternative 

The Preferred Alternative in an EIS is the alternative that the agency believes would best fulfill its 

statutory mission and responsibilities, giving consideration to economic, environmental, technical, and 

other factors. 

Why Did DOE Identify Waste Control Specialists, LLC, as the Preferred Alternative? 

DOE has identified Waste Control Specialists, LLC, near Andrews, Texas, as the Preferred Alternative 

location for long-term storage of U.S. mercury, based on the following factors: 

 Compatibility with existing waste management activities, land use plans, and regulatory 

agreements 

Remote location 

Low population density in surrounding area 

No nearby major bodies of surface water 

Existing rail line 

Environmental impacts similar to those at other candidate sites 

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No final decision will be made until this draft EIS has been subject to public review and comment, the 

final EIS has been published, and a Record of Decision (ROD) has been issued. The ROD will present 

DOE’s rationale for selecting a mercury storage site based on analyses in this EIS and other studies, as 

well as mission and policy considerations. 
Summary and Guide for Stakeholders 

25

Table 4. Summary of Cumulative Impacts Assessment 

Alternative 

Resource 

Area Cumulative Impacts 

Contribution of 

Proposed Action to 

Cumulative Impacts 

U.S. Department of 

Energy (DOE) Grand 

Junction Disposal Site 

Land use Rural area; limited development expected 

within the region of influence (ROI). Delta 

County solid waste landfill planned that 

will occupy 45 hectares (110 acres). No 

substantial cumulative impacts on land 

use or visual resources. 

Negligible 

Visual resources Negligible 

Air quality No exceedance of air quality standards. Negligible 

Infrastructure No substantial cumulative impacts on 

regional power consumption. 

Negligible 

DOE Hanford Site 

(Hanford), 200-West Area 

Land use Numerous projects could disturb up to 

1,100 hectares (2,720 acres) across 

Hanford. Most development is or would 

be within areas designated as Industrial 

and Industrial-Exclusive. Potential for 

minor cumulative impacts. 

Negligible 

Air quality No exceedance of air quality standards 

except potential impacts from carbon 

monoxide and particulate emissions from 

Hanford tank closure and waste 

management activities. 

Negligible 

Hawthorne Army Depot Air quality No exceedance of air quality standards. Negligible 

DOE Idaho National 

Laboratory (INL), Idaho 

Nuclear Technology and 

Engineering Center 

Land use Limited development expected within 

the ROI. Development would take place 

within the Central Core Area of INL. 

No substantial cumulative impacts 

within ROI. 

Negligible 

Air quality No exceedance of air quality standards. Negligible 

DOE Idaho National 

Laboratory, Radioactive 

Waste Management 

Complex 

Air quality No exceedance of air quality standards. Negligible 

DOE Kansas City Plant Air quality No exceedance of air quality standards. Negligible 

DOE Savannah River 

Site (SRS), E Area 

Land use Several onsite projects within ROI. 

Development is, or would be, within the 

Industrial Core Management Area. The 

major offsite project within the ROI is 

expansion of the Vogtle Electric 

Generating Plant. No substantial 

cumulative impacts. 

Negligible 

Air quality No exceedance of air quality standards, 

although the existing SRS contribution to 

24-hour particulate matter concentrations 

approach the standard. 

Negligible 

Waste Control 

Specialists, LLC 

Land use Rural area; numerous projects within ROI 

along the Highway 176 corridor. 

Substantial recent local changes to land 

use and visual resources. 

Negligible 

Visual resources Negligible 

Air quality No exceedance of air quality standards. Negligible 

Ecological 

resources 

Numerous projects within ROI along the 

Highway 176 corridor. Substantial recent 

local loss of low desert grassland and 

rangeland habitat. 

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

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5. PUBLIC INVOLVEMENT 

DOE is committed to communicating with the public to help ensure that potentially affected communities 

and other interested parties understand DOE’s proposed actions and are given opportunities to participate 

in decisions that may affect them. Public involvement for the Mercury Storage EIS began with 

publication of the Notice of Intent in the Federal Register (74 FR 31723) on July 2, 2009, and 

establishment of a Mercury Storage EIS website (www.mercurystorageeis.com) to give the public access 

to information on the NEPA process, this EIS, and public involvement opportunities. Display 

advertisements were subsequently published in local newspapers to announce the dates and locations of 

eight public scoping meetings and the mechanisms for submitting comments by email through the 

website, by toll-free fax (1-877-274-5462), and by U.S. mail. 

Public Scoping Meetings 

Approximately 300 people attended Mercury Storage EIS public scoping meetings at which DOE 

provided information on the Mercury Export Ban Act of 2008 and the scope of this EIS. The scoping 

period extended from July 2, 2009, to August 24, 2009. During this time, DOE solicited comments from 

stakeholders, including Federal, state, and local agencies; American Indian tribal representatives; and the 

general public to assist in defining the proposed action, alternatives, and issues requiring analysis. Public 

scoping meetings were held on the following dates in locations near the parenthetically listed candidate 

mercury storage sites: 

 July 21, 2009 – Grand Junction, Colorado 

[DOE Grand Junction Disposal Site] 

July 23, 2009 – Kansas City, Missouri 

[DOE Kansas City Plant] 

July 28, 2009 – Richland, Washington 

[DOE Hanford Site] 

July 30, 2009 – North Augusta, South 

Carolina [DOE Savannah River Site] 

August 4, 2009 – Hawthorne, Nevada 

[Hawthorne Army Depot] 

August 6, 2009 – Andrews, Texas 

[Waste Control Specialists, LLC] 

August 11, 2009 – Idaho Falls, Idaho 

[DOE Idaho National Laboratory] 

August 13, 2009 – Portland, Oregon [DOE Hanford Site] 

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Summary and Guide for Stakeholders 

27

Public Comments on the Scope of This EIS 

DOE received 507 comment documents (emails, faxes, letters, and transcripts of oral comments) 

containing 1,244 individual comments during the scoping period. DOE considered all oral and written 

public comments in refining the scope of this EIS. 

Comments received during the public scoping period 

focused primarily on the amount and sources of 

U.S. mercury; the process for identifying potential 

mercury storage facility locations; the mercury 

storage site alternatives; storage protocols; 

transportation issues; health and safety concerns, 

including accidents; potential environmental 

impacts; socioeconomics, including environmental 

justice concerns; American Indian issues; regulatory 

compliance concerns; public meeting notifications; 

and costs. Comments are presented in more detail 

along with DOE responses in Chapter 1. 

Representative comments in major categories of 

concern and DOE responses are summarized below: 

 How much mercury would be stored? 

DOE estimates that approximately 

10,000 metric tons (11,000 tons) of mercury 

may be received for storage. 

 Where would the mercury come from? DOE expects mercury to come primarily from closing 

chlor-alkali plants, gold mining, and waste reclamation and recycling. The DOE mercury 

inventory currently at the Y–12 National Security Complex in Tennessee could also be sent to the 

new facility(ies) for storage. 

Would the mercury be privately owned or owned by the Government? Upon acceptance for 

storage, DOE would own the mercury stored in the facility(ies). 

Mercury should not be stored at a site near a population center or surface water and 

groundwater, or one with a strong likelihood of natural hazards such as tornadoes and 

earthquakes. DOE could choose to store mercury at any of the alternative locations analyzed in 

this EIS. The range of alternatives analyzed includes sites (1) near and distant from population 

centers and water sources; (2) near mercury source locations; (3) of different sizes; and 

(4) subject to different degrees of natural hazard risk. However, no significant risks to human 

health or ecology were identified at any of the candidate sites in the Human Health and 

Ecological Risk Assessment Analysis, Appendix D. 

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

28

 DOE should store mercury at a Government site because a private company could go 

bankrupt. The Mercury Export Ban Act of 2008 requires DOE to designate a facility or 

facilities for storage of mercury. DOE has interpreted the Act to authorize storage at a facility 

owned or leased by DOE. The mercury would be owned and monitored by DOE. 

Why were other DOE facilities not evaluated? Chapter 1 describes the methods used to solicit 

sites interested in, and capable of, hosting the mercury storage facility(ies) and the evaluation 

criteria used to determine if the potential sites were reasonable alternatives for mercury storage. 

A range of reasonable alternatives was considered for analysis in this EIS. 

What would happen after the 40-year storage period? The Act contemplates indefinite 

storage at the DOE-designated storage facility(ies). For purposes of analysis, it was assumed that 

the mercury storage facility(ies) would operate over a 40-year timeframe. Forty years is the 

period of analysis in this EIS because it is the Government’s planning projection for receipt of 

mercury for storage. If treatment and disposal options become available, DOE would initiate 

additional NEPA analysis to identify and evaluate treatment and disposal alternatives and provide 

additional opportunities for public participation. Moreoever, additional NEPA analyses may be 

required if DOE extends its operations beyond the 40-year period of analysis. 

DOE should evaluate currently available treatment technologies to make mercury safer for 

long-term storage, and as an alternative to long-term storage. There is currently no 

EPA-approved method for the treatment of high-purity elemental mercury wastes for land 

disposal. 

How would the mercury be stored and monitored? The DOE mercury storage facility(ies) 

would be under the control and authority of DOE and would include appropriate security. It 

would be a weather-protected structure with a reinforced-concrete floor. The floor would be 

curbed and treated with an epoxy sealant to contain spills. Lighting, ventilation, fire suppression, 

and monitoring systems would be incorporated. Monitoring would include leak detection and 

mercury vapor monitors, as well as security systems. The facility would be RCRA regulated and 

permitted, and, as such, regular inspections, strict record-keeping, and periodic reporting would 

be required. More detail is available in DOE’s interim guidance, as well as in Chapters 2 and 4 of 

this EIS. 

What security would there be at the DOE mercury storage site? The facility(ies) would be 

located in an area under the control and authority of DOE. A perimeter barbed-wired fence 

would be used to further control unauthorized access. Remote surveillance may also be 

employed. 

How would mercury be transported to the DOE mercury storage site? Transportation of 

mercury would be in accordance with RCRA hazardous waste and U.S. Department of 

Transportation hazardous material shipping requirements for commercial truck and rail routes. 

Appendix C provides a description of the shipping modes and containers that would be used to 

transport mercury. Mercury has been safely transported for many years as an industrial 

commodity and as a hazardous waste. 

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Summary and Guide for Stakeholders 

29

 What would the risks be to site workers, individuals near the mercury storage site, and 

sensitive populations such as children, pregnant women, and the elderly? Chapter 4 

describes the risks from exposure to mercury during normal operations and accidents. Risks were 

considered for all reasonable exposure routes, including air and soil exposure. Risks to workers 

and the public from mercury exposure during normal operations and accidents would be 

negligible to low at all candidate mercury storage sites. Risks to workers and the public include 

consideration of risks to sensitive groups such as children, pregnant women, and the elderly. 

Concerns about accidents, response measures, and cleanup costs. Risks to workers and the 

public from mercury released during facility accidents would be negligible to low. The EIS risk 

analysis includes consideration of accidents initiated by natural disasters, such as earthquakes and 

tornadoes, and human-initiated spills, leaks, and other events, such as aircraft crashes. Chapter 4 

includes an assessment of intentional destructive acts, which indicates that the mercury stockpile 

is not a likely target for terrorists. In the event of an accident, emergency responders would 

contain any released mercury to minimize public exposure. Emergency response personnel 

would be responsible for assessing the significance of an accident and determining if the 

evacuation of nearby residents is warranted. Additional hazardous materials response teams 

could be called in to help assess, contain, and clean up the contamination. DOE or the contractor 

responsible for operating the facility would be responsible for the costs of accident cleanup and 

payment of damages to affected parties. 

Concerns about impacts on the environment. Chapter 4 contains analyses of potential impacts 

on the natural and manmade environment at the candidate sites evaluated. Impacts were 

evaluated for land use and visual resources; geology, soils, and geologic hazards; water 

resources; air quality and noise; ecological resources; cultural and paleontological resources; site 

infrastructure; waste management; occupational and public health and safety; ecological risk; 

socioeconomics; and environmental justice. Cumulative impacts and measures that could be used 

to mitigate adverse impacts are described in Chapter 4. 

What are the economic benefits and concerns regarding construction and operation of the 

proposed mercury storage facility? All of the site alternatives would likely have negligible 

socioeconomic impacts in terms of employment, population trends, and traffic. Although 

publicity regarding the DOE mercury storage facility(ies) may produce short-term impacts on 

local home sales and property values, long-term impacts are not expected. Socioeconomic 

impacts were analyzed in Chapter 4 for each of the alternatives, which are summarized in 

Chapter 2. The minority and low-income populations within 16 kilometers (10 miles) and 

3.2 kilometers (2 miles) of the candidate mercury storage sites are described in Chapter 3, and 

Chapter 4 includes an analysis of potential environmental justice impacts. 

DOE should consider impacts on American Indian interests and lifestyles. Construction and 

operation of a mercury storage facility(ies) are expected to have little or no environmental, 

socioeconomic, or cultural resource impacts. Human health risks during normal operations would 

be negligible. Therefore, adverse impacts on American Indians are not expected. As described in 

the Cultural Resources sections of Chapter 4, if American Indian artifacts were discovered during 

construction, the land-disturbing activities would be suspended, and DOE would contact the 

appropriate tribal representative and State Historic Preservation Office. 

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

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 DOE should have provided earlier notification of the public scoping meetings. DOE’s 

notification of public scoping meetings was in compliance with all NEPA requirements. In 

addition to Federal Register announcements, notification of the scoping meetings was provided 

in local newspapers and on the EIS website (www.mercurystorageeis.com). However, to 

further ensure prompt notification, DOE is mailing notices of the availability of this draft EIS, 

with comment submission and public hearing information, to all stakeholders on the Mercury 

Storage EIS mailing list. Public hearings will be held on this draft EIS. 

How Can I Participate? 

DOE is soliciting comments on this draft EIS during a 60-day public comment period, during 

which public hearings will be held to provide interested members 

of the public with opportunities to learn more about the content of 

this draft EIS, hear DOE representatives present a summary of 

the results of the EIS analyses, ask clarifying questions, and 

provide oral and written comments. The EIS website, 

www.mercurystorageeis.com, will further inform the public about 

this draft EIS, public hearings, comment submission, and other 

pertinent information. 

Attend a Public Hearing 

Public hearing dates, times, and locations will be announced in the 

Federal Register, in local newspapers, and on the EIS website 

(www.mercurystorageeis.com). Members of the public who have 

expressed interest and are on the DOE mailing list for this draft EIS 

will be notified by U.S. mail regarding hearing dates, times, and 

locations. 
Summary and Guide for Stakeholders 

31

Visit a Reading Room 

Review copies of the draft EIS and other pertinent information are available at the following reading 

rooms. 

Colorado 

Mesa County Library 

530 Grand Avenue 

Grand Junction, CO 81502-5019 

(970) 243-4442 

U.S. Department of Energy 

Office of Legacy Management 

2597 B 3⁄4 Road 

Grand Junction, CO 81503 

(970) 248-6089 

District of Columbia

U.S. Department of Energy 

Freedom of Information 

Reading Room 

1000 Independence Avenue, SW 

Room 1G-033 

Washington, D.C. 20585 

(202) 586-5955 

Georgia

Augusta State University 

Reese Library 

2500 Walton Way 

Augusta, GA 30904 

(706) 737-1745 

Savannah State University 

Asa H. Gordon Library 

2200 Tompkins Road 

Savannah, GA 31404 

(912) 356-2183 

Idaho

U.S. Department of Energy 

Public Reading Room 

1776 Science Center Drive 

Idaho Falls, ID 83402 

(208) 526-0833 

Missouri

Mid-Continent Public Library 

Blue Ridge Branch 

9253 Blue Ridge Boulevard 

Kansas City, MO 64138 

(816) 761-3382 

Nevada

Mineral County Library 

First & “A” Street 

Hawthorne, NV 89415 

(775) 945-2778 

New Mexico

Eunice Public Library 

1039 10th Street 

Eunice, NM 88231 

(575) 394-2336 

Oregon

Portland State University 

Government Information 

Branford Price Millar Library 

1875 SW Park Avenue 

Portland, OR 97201 

(503) 725-5874 

South Carolina

University of South Carolina–

Aiken 

Gregg-Graniteville Library 

471 University Parkway 

Aiken, SC 29801 

(803) 641-3320 

South Carolina State Library 

1500 Senate Street 

Columbia, SC 29211 

(803) 734-8026 

Texas

Andrews County Library 

109 NW 1st Street 

Andrews, TX 79714 

(432) 523-9819 

Washington

U.S. Department of Energy 

Public Reading Room 

Consolidated Information Center 

2770 University Drive 

Room 101L 

Richland, WA 99352 

(509) 372-7443 

University of Washington 

Suzzallo-Allen Library 

Government Publications Division 

Seattle, WA 98195 

(206) 543-1937 

Gonzaga University 

Foley Center Library 

101-L East 502 Boone 

Spokane, WA 99258 

(509) 313-5931 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

32

Go to the EIS Website 

This draft EIS is available on the website, http://www.mercurystorageeis.com 
Summary and Guide for Stakeholders 

33

Submit Comments 

To submit written comments or request more information: 

Email through the EIS website: www.mercurystorageeis.com 

Fax toll-free: 1-877-274-5462 

U.S. mail: Mr. David Levenstein, Document Manager 

Office of Environmental Compliance (EM–41) 

U.S. Department of Energy 

Post Office Box 2612 

Germantown, MD 20874 

Watch for the Final EIS 

When the final EIS is published, its availability will be announced in the Federal Register, in local 

newspapers, and via U.S. mail. This Summary and Guide for Stakeholders, as well as the full EIS, will be 

sent to those who request it in compact disk or print formats. It also will be available on the EIS website 

and for review in public reading rooms. Oral and written comments received during the public comment 

period will be considered equally in preparing the final EIS, and DOE responses will be presented in a 

comment response document that will be published as part of the final EIS. 

Based on the final EIS and other considerations, DOE will announce a decision regarding future actions 

in a ROD to be published in the Federal Register no sooner than 30 days after the EPA Notice of 

Availability for the final EIS is published (see Figure 6). The ROD will describe the alternative selected 

for implementation and explain how environmental impacts will be avoided, minimized, or mitigated. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

34

6. HELPFUL INFORMATION 

In this section, the content and organization of the full EIS is described, the reader is directed to specific 

chapters and sections to find information on a series of topics, and a short acronym list is provided. 

How This EIS is Organized 

The main volume of the Draft Mercury Storage EIS consists of the following chapters and appendices: 

 Chapter 1, Introduction and Purpose and Need for Agency Action, describes the proposed action, 

provides background information on the Mercury Export Ban Act of 2008, and describes the 

scope of this EIS and other relevant NEPA documents. 

Chapter 2, Facility Descriptions, Alternatives, and Comparison of Environmental Consequences, 

describes the existing and new mercury storage buildings analyzed in this EIS; the alternatives for 

management of the mercury, including the No Action Alternative; how the alternatives were 

developed; the activities that would take place under each alternative; and alternatives that 

initially were considered and subsequently eliminated from detailed study. This chapter also 

provides a summary of impacts of the alternatives and a description of DOE’s Preferred 

Alternative. 

Chapter 3, Affected Environment, describes the potentially affected environments at the 

candidate sites and the approach taken in describing these affected environments. The level of 

detail presented for each resource (e.g., air quality, water resources) depends on the likelihood 

that the resource would be affected by mercury storage activities. 

Chapter 4, Environmental Consequences, describes the potential impacts on the affected 

environments (presented in Chapter 3) of the proposed mercury storage alternatives (described in 

Chapter 2), including cumulative impacts and unavoidable adverse impacts. It also discusses 

potential future closure activities, irreversible and irretrievable commitments of resources, and the 

relationship between short-term uses of the environment and long-term productivity. 

Chapter 5, Environmental Laws, Regulations, Permits, and Other Potentially Applicable 

Requirements, describes potentially applicable environmental and health and safety compliance 

and permit requirements and the status of consultations with Federal and state agencies and 

American Indian tribal governments. 

Chapters 6, 7, 8, and 9 are, respectively, the Glossary, List of Preparers, Distribution List, 

and Index. 

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Summary and Guide for Stakeholders 

35

The following appendices include descriptions of methods used to estimate environmental impacts of the 

alternatives and the detailed information to support the impact analyses: 

 Appendix A – The Mercury Export Ban Act of 2008, Federal Register Notices, and Other Public 

Notices 

Appendix B – Impact Assessment Methodology 

Appendix C – Storage Facility Construction and Operations Data 

Appendix D – Human Health and Ecological Risk Assessment Analysis 

Appendix E – Common and Scientific Names of Plant and Animal Species 

Appendix F – Cooperating Agency Agreements 

Appendix G – Contractor and Subcontractor National Environmental Policy Act Disclosure 

Statements 

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

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Finding Answers to Your Questions 

If You Have A Question About... See: 

Affected environment Chapter 3 

Air quality and noise Chapter 2, Section 2.7.1.4; Chapter 3, Sections 3.2.4, 

3.3.4, 3.4.4, 3.5.4, 3.6.4, 3.7.4, 3.8.4, 3.9.4; Chapter 4, 

Sections 4.2.4, 4.3.4, 4.4.4, 4.5.4, 4.6.4, 4.7.4, 4.8.4, 4.9.4; 

Appendix B, Section B.5 

Alternatives considered but Chapter 2, Section 2.6 

eliminated from detailed analysis 

Alternatives evaluated in this EIS Chapter 2, Section 2.4 

Applicable laws and regulations Chapter 5; Appendix A, Section A.1 

Comparison of impacts Chapter 2, Section 2.7 

Construction of new facilities Chapter 2, Section 2.3.1; Appendix C, Section C.2.3 

Cultural resources Chapter 2, Section 2.7.1.6; Chapter 3, Sections 3.2.6, 

3.3.6, 3.4.6, 3.5.6, 3.6.6, 3.7.6, 3.8.6, 3.9.6; Chapter 4, 

Sections 4.2.6, 4.3.6, 4.4.6, 4.5.6, 4.6.6, 4.7.6, 4.8.6, 4.9.6; 

Appendix B, Section B.7 

Cumulative impacts Chapter 2, Section 2.7.2; Chapter 4, Section 4.11; 

Appendix B, Section B.12 

Decisions to be made Chapter 1, Section 1.4 

Ecological resources Chapter 2, Section 2.7.1.5; Chapter 3, Sections 3.2.5, 

3.3.5, 3.4.5, 3.5.5, 3.6.5, 3.7.5, 3.8.5, 3.9.5; Chapter 4, 

Sections 4.2.5, 4.3.5, 4.4.5, 4.5.5, 4.6.5, 4.7.5, 4.8.5, 4.9.5; 

Appendix B, Section B.6; Appendix E 

Ecological impacts Chapter 2, Section 2.7.1.10; Chapter 4, Sections 4.2.10, 

4.3.10, 4.4.10, 4.5.10, 4.6.10, 4.7.10, 4.8.10, 4.9.10; 

Appendix D, Sections D.1.1.2, D.5, D.6.4.2, D.7.2 

Environmental justice Chapter 2, Section 2.7.1.12; Chapter 3, Sections 3.2.11, 

3.3.11, 3.4.11, 3.5.11, 3.6.11, 3.7.11, 3.8.11, 3.9.11; 

Chapter 4, Sections 4.2.12, 4.3.12, 4.4.12, 4.5.12, 4.6.12, 

4.7.12, 4.8.12, 4.9.12; Appendix B, Section B.11 

Geology, soils, and geologic hazards Chapter 2, Section 2.7.1.2; Chapter 3, Sections 3.2.2, 

3.3.2, 3.4.2, 3.5.2, 3.6.2, 3.7.2, 3.8.2, 3.9.2; Chapter 4, 

Sections 4.2.2, 4.3.2, 4.4.2, 4.5.2, 4.6.2, 4.7.2, 4.8.2, 4.9.2; 

Appendix B, Section B.3 

Human health effects Chapter 2, Section 2.7.1.9; Chapter 4, Sections 4.2.9.1, 

4.3.9.1, 4.4.9.1, 4.5.9.1, 4.6.9.1, 4.7.9.1, 4.8,9.1, 4.9.9.1; 

Appendix D, Sections D.1.1.2, D.3, D.4, D.6.4.1 

Land use and visual resources Chapter 2, Section 2.7.1.1; Chapter 3, Sections 3.2.1, 

3.3.1, 3.4.1, 3.5.1, 3.6.1, 3.7.1, 3.8.1, 3.9.1; Chapter 4, 

Sections 4.2.1, 4.3.1, 4.4.1, 4.5.1, 4.6.1, 4.7.1, 4.8.1, 4.9.1; 

Appendix B, Section B.2 
Summary and Guide for Stakeholders 

37

If You Have A Question About... See: 

Mercury 

Mitigation measures 

No Action Alternative 

Occupational and public health and 

safety 

Operations of facilities 

Preferred Alternative 

Public involvement 

Purpose and need for agency action 

Scope of this EIS 

Site infrastructure 

Socioeconomics 

Transportation 

Waste management 

Water resources 

Chapter 1, Sections 1.1, 1.3.1; Appendix D, Section D.3 

Chapter 4, Section 4.12 

Chapter 2, Section 2.4.1, 2.7.1; Chapter 3, Section 3.9; 

Chapter 4, Section 4.2 

Chapter 2, Section 2.7.1.9; Chapter 3, Sections 3.2.9, 

3.3.9, 3.4.9, 3.5.9, 3.6.9, 3.7.9, 3.8.9, 3.9.9; Chapter 4, 

Sections 4.2.9, 4.3.9, 4.4.9, 4.5.9, 4.6.9, 4.7.9, 4.8.9, 4.9.9 

Chapter 2, Section 2.3.2; Appendix C, Section C.2.4 

Chapter 2, Section 2.5 

Chapter 1, Section 1.6 

Chapter 1, Section 1.2 

Chapter 1, Section 1.5 

Chapter 2, Section 2.7.1.7; Chapter 3, Sections 3.2.7, 

3.3.7, 3.4.7, 3.5.7, 3.6.7, 3.7.7, 3.8.7, 3.9.7; Chapter 4, 

Sections 4.2.7, 4.3.7, 4.4.7, 4.5.7, 4.6.7, 4.7.7, 4.8.7, 4.9.7; 

Appendix B, Section B.8 

Chapter 2, Section 2.7.1.11; Chapter 3, Sections 3.2.10, 

3.3.10, 3.4.10, 3.5.10, 3.6.10, 3.7.10, 3.8.10, 3.9.10; 

Chapter 4, Sections 4.2.11, 4.3.11, 4.4.11, 4.5.11, 4.6.11, 

4.7.11, 4.8.11, 4.9.11; Appendix B, Section B.10 

Chapter 2, Section 2.6.3, 2.7.1.9; Chapter 3, 

Sections 3.2.7.1, 3.2.9.3, 3.2.10.3, 3.3.7.1, 3.3.9.3, 

3.3.10.3, 3.4.7.1, 3.4.9.3, 3.4.10.3, 3.5.7.1, 3.5.9.3, 

3.5.10.3, 3.6.7.1, 3.6.9.3, 3.6.10.3, 3.7.7.1, 3.7.9.3, 

3.7.10.3, 3.8.7.1, 3.8.9.3, 3.8.10.3, 3.9.7.1, 3.9.9.3, 

3.9.10.3; Chapter 4, Sections 4.2.9.3, 4.3.9.3, 4.4.9.3, 

4.5.9.3, 4.6.9.3, 4.7.9.3, 4.8.9.3, 4.9.9.3; Appendix C, 

Section C.1; Appendix D, Section D.2.7 

Chapter 2, Section 2.7.1.8; Chapter 3, Sections 3.2.8, 

3.3.8, 3.4.8, 3.5.8, 3.6.8, 3.7.8, 3.8.8, 3.9.8; Chapter 4, 

Sections 4.2.8, 4.3.8, 4.4.8, 4.5.8, 4.6.8, 4.7.8, 4.8.8, 4.8.9; 

Appendix B, Section B.9 

Chapter 2, Section 2.7.1.3; Chapter 3, Sections 3.2.3, 

3.3.3, 3.4.3, 3.5.3, 3.6.3, 3.7.3, 3.8.3, 3.9.3; Chapter 4, 

Sections 4.2.3, 4.3.3, 4.4.3, 4.5.3, 4.6.3, 4.7.3, 4.8.3, 4.9.3; 

Appendix B, Section B.4 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

38

Acronyms and Abbreviations 

DOE – U.S. Department of Energy 

EIS – environmental impact statement 

EPA – U.S. Environmental Protection Agency 

Mercury Storage EIS – Draft Long-Term Management and Storage of Elemental Mercury 

Environmental Impact Statement

MOU – Memorandum of Understanding

NEPA – National Environmental Policy Act of 1969 

RCRA – Resource Conservation and Recovery Act 

ROD – Record of Decision 

ROI – region of influence 

the Act – Mercury Export Ban Act of 2008 
Summary and Guide for Stakeholders 

39

Figure 6. The Mercury Storage Environmental Impact Statement Timeline