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CHAPTER 2

FACILITY DESCRIPTION, ALTERNATIVES, AND COMPARISON OF 

ENVIRONMENTAL CONSEQUENCES 

Chapter 2 provides descriptions of basic design requirements for new and existing facilities that may be used for 

the long-term management and storage of elemental mercury; the alternative locations that are being considered; 

and alternatives that were considered but eliminated from detailed analysis in this Long-Term Management and 

Storage of Elemental Mercury Environmental Impact Statement. The chapter concludes with a comparison and 

summary of impacts. 

2.1 INTRODUCTION 

As previously discussed in Chapter 1, Section 1.2, “Purpose and Need for Agency Action,” the 

U.S. Department of Energy (DOE) estimates that up to approximately 10,000 metric tons (11,000 tons) of 

excess elemental mercury may be eligible for long-term management and storage in a DOE-designated 

facility(ies) based on a 40-year period of analysis.1, 2

 DOE’s selection of a mercury storage facility(ies) 

would comply with the requirements of Section 5(a) of the Mercury Export Ban Act of 2008 (referred to 

hereafter as “the Act”), entitled “Designation of a Facility.” Specifically, Section 5(d) of the Act, entitled 

“Management Standards for a Facility,” requires DOE to construct and operate the facility(ies) in 

accordance with the Solid Waste Disposal Act (SWDA), as amended by the Resource Conservation and 

Recovery Act (RCRA) (42 U.S.C. 6901 et seq.). A designated facility in existence on or before 

January 1, 2013, would be authorized to operate under interim status in accordance with the SWDA until 

a final decision is made on a permit application. No later than January 1, 2015, the Administrator of the 

U.S. Environmental Protection Agency (EPA) (or authorized state) must issue a final decision on the 

permit application (P.L. 110-414). The mercury to be stored at the DOE facility(ies) must be elemental 

with a purity of 99.5 percent or greater by volume (DOE 2009).3

Potential sources of excess mercury in the United States that may require long-term storage in a DOE 

facility(ies) include (1) that resulting from closure of chlor-akali plants or conversion to non-mercury-cell 

technology; (2) that generated as a byproduct of the gold-mining process; (3) that reclaimed from 

recycling and waste recovery activities; (4) DOE mercury at the Y–12 National Security Complex 

(Y–12); and (5) other relatively minor sources. 

In March 2004, the Defense Logistics Agency (DLA) Defense National Stockpile Center (DNSC) issued 

the Final Mercury Management Environmental Impact Statement (MM EIS) (DLA 2004), which analyzed 

alternatives for managing the U.S. Department of Defense stockpile of mercury. The MM EIS analyzed 

 

1

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

statement. 2

 The Mercury Export Ban Act of 2008 does not require that mercury be stored in a DOE mercury storage facility(ies), nor does 

the Act specify how long such a facility(ies) would need to be operated. The U.S. Environmental Protection Agency projected 

in the report Mercury Storage Cost Estimates (EPA 2007), that, in addition to governmental stockpiles of mercury, 7,500 to 

10,000 metric tons (8,300 to 11,000 tons) of mercury may become excess over the next 40 years. In preparing this Long-Term 

Management and Storage of Elemental Mercury Environmental Impact Statement, DOE has reexamined these estimates. For 

purposes of analysis, DOE assumes the operation of a mercury storage facility(ies) with a capacity of 10,000 metric tons 

(11,000 tons) over a 40-year period of analysis. These are estimates with a degree of uncertainty; therefore, it is possible that 

more or less than 10,000 metric tons (11,000 tons) of mercury could eventually require storage for a period longer or shorter 

than 40 years. Additional National Environmental Policy Act analysis may be required to expand the facility(ies) to accept 

more than 10,000 metric tons (11,000 tons) of mercury or extend its operations beyond the 40-year period of analysis. 3

 The treatment standard for wastes containing high concentrations of mercury (greater than 260 parts per million) is recovery 

through roasting or retorting, which is performed at various commercial waste recovery facilities. This process yields high 

purity (e.g., elemental mercury that is at least 99.5 percent pure by volume) that is generally acceptable for reintroduction back 

into commerce and is analogous to the materials proposed to be stored in a DOE facility(ies). Therefore, only mercury with 

greater than 99.5 percent purity by volume would be accepted for long-term storage in a DOE facility(ies). 
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consolidated long-term storage at several candidate DNSC and non-DNSC sites. In the Record of 

Decision, DLA amended its selection of consolidated storage at one location (69 FR 23733) and DLA 

selected the Hawthorne Army Depot in Nevada, a non-DNSC candidate site analyzed in the MM EIS, for 

storage of approximately 4,400 metric tons (4,900 tons) of mercury. This quantity of defense-related 

mercury is not included in the estimates of excess mercury that may require long-term storage in a 

DOE-designated facility(ies), although, as previously noted, the Hawthorne Army Depot site is evaluated 

in this environmental impact statement (EIS) for storage of the additional mercury for which DOE would 

be responsible. 

2.2 MERCURY STORAGE FACILITY(IES) 

As required by Section 5 of the Act (P.L. 110-414), DOE has developed guidance, entitled 

U.S. Department of Energy Interim Guidance on Packaging, Transportation, Receipt, Management, and 

Long-Term Storage of Elemental Mercury (Interim Guidance) (DOE 2009) establishing basic standards 

and procedures for the receipt, management, and long-term storage of mercury at a DOE facility(ies). 

The guidance is based on laws, regulations, DOE Orders, and best management practices. The Interim 

Guidance discusses DOE’s anticipated waste acceptance criteria for discarded mercury to be stored at the 

facility(ies). All mercury to be stored at the facility(ies) must meet these requirements. Further, it 

describes the procedures DOE would use to receive, store, and monitor the mercury. In addition, spill and 

emergency response procedures are described. 

Major characteristics of DOE’s mercury storage facility(ies) would include, but would not necessarily be 

limited to, the following (74 FR 31723; DOE 2009): 

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

procedures 

 Security and access control 

 Fire suppression systems 

 Ventilated storage and handling area(s) 

 Fully enclosed weather-protected building 

 Reinforced-concrete floors able to withstand structural loads of mercury storage 

Additionally, as described in Appendix C, Section C.2.1, the mercury storage facility(ies) would have the 

following functional areas: Receiving and Shipping Area, Handling Area, Storage Area, and an Office 

Administration Area. The Office Administration Area is likely to be in a separate building, where all the 

management, operations, training, and other administrative functions would be conducted. If necessary, 

transfer of mercury from failed containers into new containers would occur in the Handling Area. 

A typical mercury storage facility would be dominated by the Storage Area, which 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 

other functional areas would occupy the remaining 10 percent of the facility(ies). 

The mercury storage facility(ies) would accept two types of mercury containers: 3-liter (3-L) 

(34.6-kilogram [76-pound]) flasks and 1-metric-ton (1-MT) (1.1-ton) containers. Other types of 

containers would be considered on a case-by-case basis. 

Figure 2–1 shows the typical 3-L flask and 1-MT container that are used to store and transport mercury. 

These containers are typically made of carbon steel or stainless steel and also satisfy the U.S. Department 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

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of Transportation hazardous materials regulations for mercury transport (49 CFR 172.101). A DOE 

storage facility with a capacity to store 10,000 metric tons (11,000 tons) of mercury could store up to 

approximately 116,000 of the 3-L flasks and 6,000 of the 1-MT containers. The numbers of containers 

are based on an assumed 40:60 percent split between the amount of mercury that is expected to be stored 

in 3-L flasks (4,000 metric tons [4,400 tons]) and the amount that is expected to be stored in 1-MT 

containers (6,000 metric tons [6,600 tons]) (DOE 2009). 

Figure 2–1. Typical Elemental Mercury Storage Containers 

2.2.1 New Facility 

If constructed, a new mercury storage facility would be designed and built for the specific purpose of 

providing the safe and secure long-term storage of mercury. Figure 2–2 provides an illustration of what 

the exterior of a new mercury storage facility might look like, and Figure 2–3 provides a conceptual 

layout of the interior of a full-size facility (i.e., with a storage capacity of 10,000 metric tons 

[11,000 tons]) and how the mercury containers might be stored. Appendix C provides additional details 

and data related to requirements for construction and operation of a new facility. 

Figure 2–2. Exterior Representation of a New Mercury Storage Facility 
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Figure 2–3. Potential Conceptual Layout of a New Mercury Storage Facility 

If built, a new mercury storage facility with a 10,000-metric-ton (11,000-ton) capacity would require 

approximately 13,610 square meters (146,500 square feet) of storage space. The 1-MT containers may be 

single- or double-stacked and the 3-L flasks may be single-, double-, or triple-stacked, depending on 

seismic and safety considerations, as well as the requirements of a state-issued RCRA permit. If 

constructed, the height of the building would be approximately 6.1 meters (20 feet) to accommodate the 

potential triple stacking of 3-L flasks. The new facility would have a reinforced-concrete floor, strong 

enough to withstand the heavy loads from mercury storage. The floors would also be treated with an 

epoxy sealant to add strength and make them impervious to mercury leaks and spills and water from fire 

suppression systems. Mercury containers would be stored in spill trays designed to contain at least 

10 percent of the volume of mercury stored in each spill tray in the unlikely event one of the containers 

were to leak. The exterior of the storage facility would likely be sheet metal panels fastened to structural 

steel supports and connected together to form a weather-protected structure. The Receiving and Shipping 

Area would have a loading dock with large rollup doors. Lighting, ventilation, fire suppression, and 

security monitoring systems would be incorporated into the facility design. Monitoring systems could 

include security alarms and surveillance cameras. A new facility boundary would encompass 

approximately 3.1 hectares (7.5 acres) and would include a paved area for delivery truck access and 

vehicle parking. The facility would also need to be RCRA regulated and permitted, and thus would 

require, among other things, secondary containment (e.g., curbing), regular inspection of stored materials, 

strict record-keeping, and periodic reporting. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

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2.2.2 Existing Facilities 

Existing facilities proposed and selected for the storage of mercury would also be required to comply with 

the functional and performance standards as defined in the Interim Guidance (DOE 2009). Existing 

facilities would need to be modified, where necessary, to meet the requirements of the Interim Guidance 

and the terms of an RCRA permit. Alternative locations with existing facilities that have been proposed 

and analyzed in this Long-Term Management and Storage of Elemental Mercury Environmental Impact 

Statement (Mercury Storage EIS) include storage buildings at the Hawthorne Army Depot, the 

Radioactive Waste Management Complex (RWMC) at Idaho National Laboratory (INL), the Main 

Manufacturing Building at Kansas City Plant (KCP), and the Container Storage Building (CSB) at the 

Waste Control Specialists, LLC (WCS), site. Descriptions of the existing facilities proposed as candidate 

sites, and of any minor modifications that may be necessary, are specific to each location and are 

discussed in detail in Section 2.4, “Alternative Sites Evaluated.” Existing facilities were considered only 

if their former use is consistent with the storage of hazardous waste. 

2.3 CONSTRUCTION AND OPERATIONS REQUIREMENTS 

2.3.1 Construction Requirements 

Construction of a new mercury storage facility(ies) with a 10,000-metric-ton (11,000-ton) capacity would 

require the disturbance of approximately 3.1 hectares (7.5 acres) of land for building construction and 

equipment laydown areas. When completed, the building footprint would be approximately 1.6 hectares 

(3.9 acres). Construction of a full-size storage facility would require approximately 6 months; however, 

due to the uncertainty regarding the timing of the availability of mercury that would require long-term 

storage, a new facility could be constructed in a modular fashion to accommodate storage of mercury on 

an as-needed basis. The ability to build the storage facility in a modular fashion would also ensure that 

the facility is sized correctly for the amount of mercury that would eventually require storage. For 

example, the Storage Areas of the facility could be built in two sections, one section at a time, with each 

section capable of storing 5,000 metric tons (5,500 tons) of mercury. 

Construction would entail leveling and grading an area large enough to accommodate the storage building 

or an area large enough to accommodate each module, which would be built as necessary to meet 

anticipated storage needs. The foundation would consist of heavily compacted aggregate stone overlain 

with a reinforced-concrete slab approximately 30 centimeters (12 inches) thick. With the exception of 

small trenches for connecting to utilities or installing concrete footers, excavation for preparing the site 

and laying the foundation is not expected to exceed a depth of 0.6 meters (2 feet). Electricity during 

construction would be provided by portable generators. Complete construction of a full-size facility 

would require an average of 18 full-time construction workers during a 6-month construction period. 

Resource requirements for construction of a new mercury storage facility with a 10,000-metric-ton 

(11,000-ton) capacity are discussed in Chapter 4, Section 4.13.2, and Appendix C, Section C.2.3. 

Modifications to existing facilities that may be used for the long-term storage of mercury would likely not 

require any new disturbance of land. However, minor modifications to candidate existing facilities might 

include the reconfiguration of space. Examples of possible modifications include installing security 

monitoring systems, fire suppression systems, and equipment in the Handling Area; upgrading ventilation 

systems; and implementing spill prevention and containment measures. Descriptions of the existing 

facilities proposed as candidate sites, and of any minor modifications that may be necessary, are specific 

to each location and are discussed in detail in Section 2.4. 

2.3.2 Operations Requirements 

Worker activity levels at the storage facility(ies) would increase or decrease with the receipt of mercury 

shipments. If DOE elects to transfer any excess mercury stored at Y–12, it is assumed that this mercury 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

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would be shipped to the designated storage facility(ies) within the first 2 years of operation. Closure of 

the four chlor-alkali plants that use mercury-cell technology, or conversion to mercury-free processes, is 

expected to be completed by 2020. However, the timing of these closures and/or conversions is difficult 

to predict; therefore, the frequency of these mercury shipments to the storage facility(ies) is uncertain. 

Projected shipments to the new storage facility(ies), based on estimated mercury inventories that may 

become available for long-term storage, are discussed in Appendix D, Section D.2.7. The amount of 

mercury in each shipment could vary, ranging from a single container up to the maximum load allowable 

by transportation regulations. 

Operations personnel would include management and administrative staff, facility technicians, facility 

maintenance staff, subject matter experts, and security staff. Administrative staff would be responsible 

for permit maintenance, fee collection, record-keeping, and reporting. The Office Administration Area 

would require heating, ventilating, and air conditioning for occupants. The Handling Area would be 

ventilated through the use of a high-negative draw system for removing high-concentration vapors from 

mercury “sources” (e.g., container residues, open containers, small spills). The exhaust air would pass 

through a mercury vapor filter (e.g., sulfur) and be discharged to the outside. An air conditioning unit 

would be available for maintaining interior temperatures below 21 degrees Celsius (70 degrees 

Fahrenheit) during times when mercury is being handled to keep its volatility low. The Storage Area 

would be ventilated using low-vacuum, high-volume, industrial-sized roof- or wall-mounted fans sized to 

provide multiple air exchanges over a short period of time and to evacuate low-concentration vapors that 

may accumulate in the storage spaces over time. These fans would operate on an as-needed basis prior to 

and during occupancy. Facility technicians would be responsible for inspections and leak and small-spill 

response. Facility maintenance staff would be responsible for maintaining the operability of the building. 

Subject matter experts would prepare health and safety plans and quality assurance plans and perform 

industrial hygiene duties. Security provided for the facility(ies) would reduce the threat of inadvertent or 

deliberate unauthorized access to the facility(ies) and the Storage Area(s). Security measures might 

include fences, barriers, gates, locks, television monitoring, or surveillance with guards. During the first 

7 years of operations, when the facility(ies) is receiving the highest frequency of shipments, 

approximately eight full-time workers would be required. During the later years of operations, when the 

frequency of shipments is expected to be much lower, approximately five full-time workers would be 

required. Appendix C, Section C.1, discusses in more detail the projected timing of shipments to the 

DOE facility(ies). 

Resource requirements for the operation of a mercury storage facility with a 10,000-metric-ton 

(11,000-ton) capacity are discussed in Chapter 4, Section 4.13.2, and Appendix C, Section C.2.4. 

Operations would include tasks such as facility security, shipping and receiving, inspections, monitoring 

and long-term storage of mercury, record-keeping, and emergency and small-spill response, as described 

below (DOE 2009). 

 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. It is conservatively assumed for labor estimates that security 

personnel would guard the facility 24 hours per day, 7 days per week, although this level of 

security may not be required at all times. Security alarms and surveillance cameras may also be 

used. 

 Shipping and Receiving. Mercury containers (3-L flasks and 1-MT containers) would be 

inspected and prepared for “ready storage” at the originating facility prior to shipment to the 

mercury storage facility(ies). All containers shall have sufficient integrity to be transported and 

placed into long-term storage. Shipments of mercury would most likely be conducted by 

third-party transportation companies in accordance with regulations governing the transportation 

of hazardous waste. See Appendix C, Section C.1, for a detailed discussion of shipping 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

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containers and methods. After arriving at the facility, if visible mercury contamination or leaking 

containers are observed, the mercury may be immediately moved to the Handling Area for 

emergency overpacking or reflasking and may subsequently be returned to the generator, at the 

generator’s expense. 

 Inspections. Upon arrival at the mercury storage facility(ies), concentrations of mercury vapor 

would be measured and verified to be below any actionable levels. A visual inspection would 

follow to detect any obvious problems that may have occurred while on the truck or railcar. If the 

initial inspections and manifest documentation are acceptable, then the mercury would be moved 

to the Shipping and Receiving Area, where additional visual inspections would be performed to 

check for leaks, structural integrity of pallets and containers, approved container types, corrosion, 

etc. The mercury would then be moved to the Handling Area for any additional verification that 

it meets waste acceptance criteria (e.g., 99.5 percent purity). The containers and pallets that pass 

the acceptance/verification process would be placed into long-term storage and location data 

would be recorded. 

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

performed in accordance with RCRA regulations within the Storage Area to ensure that no 

containers are corroding or leaking. Prior to and during occupancy, the Storage Area would be 

ventilated using low-vacuum, 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 and maintained in accordance with RCRA regulations. These documents would 

be stored in the Office Administration Area. 

 Emergency and Small-Spill Response. Spill response would be handled in accordance with the 

facility’s RCRA contingency plan. The Handling Area would be used for transferring mercury 

from corroding or leaking containers or from containers that have failed inspection upon arrival at 

the facility to new containers. The likelihood of these types of occurrences is considered small. 

When technicians are working with open containers in the Handling Area, the area would be 

negatively ventilated using a hooded duct system equipped with a filter (e.g., sulfur) designed to 

remove mercury vapors from the air. Filtered air would be vented to the outside via a small 

exhaust stack. Personal protective equipment, rags, and spent filters would be placed in 55-gallon 

(208-liter) drums, characterized, and disposed of off site at an appropriate facility. 

2.4 ALTERNATIVE SITES EVALUATED 

As discussed in Chapter 1, Section 1.5.1, DOE selected the seven action alternative sites, listed below, to 

be evaluated in this Mercury Storage EIS. The names and locations of the action alternative sites are 

presented in Figure 2–4; the No Action Alternative is discussed separately in Section 2.4.1. This Mercury 

Storage EIS also analyzes the potential impacts associated with the No Action Alternative. Potential 

alternative sites considered but eliminated from further consideration are discussed in Section 2.6. 

 New construction at the Grand Junction Disposal Site (GJDS) 

 New construction at the Hanford Site (Hanford) in the 200-West Area 

 Existing storage buildings at the Hawthorne Army Depot in the Central Magazine Area4

 

4

 DOE has interpreted Section 5 of the Act to authorize DOE to designate existing and/or new storage facilities at property 

owned or leased by DOE. Accordingly, if DOE decides to designate a facility that currently is owned by a commercial entity 

or by another Federal agency, DOE would acquire an appropriate ownership or leasehold interest in that facility to comply 

with Section 5 of the Act. DOE would ensure that any such facility currently owned by a commercial entity or by another 

Federal agency would afford DOE the same level of responsibility and control over stored mercury as a facility owned by 
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 New construction at INL’s Idaho Nuclear Technology and Engineering Center (INTEC) 

 Existing storage buildings at INL’s RWMC 

 Existing building at the Bannister Federal Complex’s KCP 

 New construction at the Savannah River Site (SRS) E Area 

 New construction at WCS

Figure 2–4. Alternative Sites for Long-Term Storage of Mercury 

GJDS, the 200-West Area of Hanford, INTEC at INL, E Area at SRS, and WCS would involve 

construction of a new facility. Hawthorne Army Depot, RWMC at INL, and KCP would involve the use 

of existing buildings. WCS may also involve the use of an existing RCRA-permitted storage building 

(i.e., the CSB) until construction of a new mercury storage facility with up to a 10,000-metric-ton 

(11,000-ton) capacity could be completed elsewhere on the site. The CSB could store up to 2,000 metric 

tons (2,200 tons) of mercury. 

2.4.1 No Action Alternative 

As discussed in Chapter 4, Section 4.2, under the No Action Alternative, DOE would not designate a 

facility(ies) for the long-term management and storage of mercury. Potential U.S. sources of excess 

mercury that could require long-term storage are illustrated in Figure 2–5 and include (1) mercury 

resulting from closure of chlor-akali plants or conversion to mercury-free processes; (2) mercury 

generated as a byproduct of the gold-mining process; (3) mercury reclaimed from recycling and waste 

recovery activities; (4) DOE mercury at Y–12; and (5) other relatively minor sources. Only 

 

DOE. This would apply to the proposed buildings at Hawthorne Army Depot and the proposed new facility at WCS, as well 

as interim use of the existing CSB at WCS. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

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four chlor-alkali plants are expected to still be using mercury-cell technology beyond 2010: Ashta 

Chemical in Ohio, PPG Industries in West Virginia, and Olin Corporation in Tennessee and Georgia 

(Chlorine Institute 2008). Mining in the state of Nevada accounts for more than 80 percent of gold 

production and produces almost all of the byproduct mercury in the United States, although South Dakota 

reportedly generates small amounts (less than 1 metric ton [1.1 tons]) of byproduct mercury (Miller and 

Jones 2005; Townsend 2009). Comparatively, the latest available data for Nevada in 2002 report the 

generation of approximately 97 metric tons (107 tons) of byproduct mercury (Miller and Jones 2005). 

Alaska, California, Colorado, and Utah are active gold-mining states; however, the mines located in these 

states reportedly do not generate byproduct mercury (Clinkenbeard 2009; Krahulec 2009; Mannon 2009; 

Szumigala 2009). As reported by the U.S. Geological Survey in 2009, the six reclamation and recycling 

companies shown on the map in Figure 2–5 account for the majority of secondary mercury reclamation 

and recycling efforts (USGS 2009). However, virtually all commodity-grade (e.g., elemental) mercury 

used in the United States is ultimately supplied by Bethlehem Apparatus Company in Pennsylvania or 

DFG Mercury Corporation in Illinois. These two companies have the high-level purification equipment 

necessary for producing commercial-grade mercury (EPA 2005). 

Figure 2–5. Potential Sources of Mercury in the United States 

The No Action Alternative would affect all sources of mercury. Excess mercury that could not be sold 

would be stored as a commodity 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(ies). 

Approximately 1,200 metric tons (1,300 tons) of DOE mercury would continue to be stored at Y–12. 

This DOE mercury is currently stored in approximately 35,000 of the 3-L flasks at Y–12. 
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2.4.2 Long-Term Mercury Management and Storage at Grand Junction Disposal 

Site 

GJDS is located approximately 29 kilometers (18 miles) southeast of Grand Junction, Colorado. The 

146-hectare (360-acre) site is owned by DOE and managed by DOE’s Office of Legacy Management. 

Currently, the site has a 38-hectare (94-acre) area used to dispose of uranium mill tailings. There are 

several small administrative and maintenance buildings on site that support disposal operations. The 

entire site is surrounded by a perimeter fence and accessed via a gated entrance. This site currently has 

truck access, but has no direct rail access. An aerial photograph of the site is presented in Figure 2–6. 

Figure 2–6. Grand Junction Disposal Site in State of Colorado 

This alternative involves construction of a new facility, as described in Sections 2.2.1 and 2.3.1 and 

Appendix C. The new facility would be located in the northwestern corner of the site, as illustrated in 

Figure 2–7. A full-size mercury storage facility with a 10,000-metric-ton (11,000-ton) capacity would 

essentially occupy all of the available (approximately 3.1-hectare [7.5-acre]) area proposed for locating 

the facility. 

As discussed in Chapter 1, Section 1.7.1, DOE and the Mesa County Board of Commissioners (Mesa 

County) entered into a Memorandum of Understanding (1996 MOU) (DOE and Mesa County 1996) to 

provide meaningful consultation with and participation of Mesa County in DOE’s use of GJDS. Mesa 

County’s position is that the use of GJDS is restricted per the 1996 MOU and that DOE is obligated to 

honor this agreement. DOE currently is evaluating the applicability of the 1996 MOU to determine 

whether it would affect the viability of this site as a reasonable alternative. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

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Figure 2–7. New Facility at Grand Junction Disposal Site in State of Colorado 
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2.4.3 Long-Term Mercury Management and Storage at Hanford Site 

Hanford occupies 151,775 hectares (375,040 acres) along the Columbia River in the southeastern portion 

of the state of Washington. Hanford is owned by the Federal Government and is managed by DOE. A 

general map of Hanford is illustrated in Figure 2–8. 

This alternative involves construction of a new facility, as described in Sections 2.2.1 and 2.3.1 and 

Appendix C. The new facility would be located in the 200-West Area of Hanford at the Central Waste 

Complex (CWC). Figure 2–9 presents an aerial photograph of the CWC; Figure 2–10 illustrates the 

proposed location of the new facility at the CWC. A full-size mercury storage facility with a 

10,000-metric-ton (11,000-ton) capacity would occupy 3.1 hectares (7.5 acres) of the available 

(approximately 22-hectare [54-acre]) area proposed for locating the facility. 
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Figure 2–8. Hanford Site in State of Washington 
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The 200 Areas, which include the 200-East and 200-West Areas, are on the Central Plateau of Hanford. 

Together, these two areas cover about 5,064 hectares (12,513 acres). Historically, these areas were 

devoted to nuclear fuel processing; plutonium processing, fabrication, and storage; and waste 

management and disposal. Located in the 200-West Area, the CWC receives, stores, and distributes solid 

radioactive and nonradioactive waste. The CWC includes multiple storage structures that provide interim 

storage for solid waste awaiting appropriate treatment and final disposal that are dedicated to other 

Hanford cleanup activities. Truck and rail access are available in the 200-West Area. 

Figure 2–9. Central Waste Complex at the Hanford Site 
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Figure 2–10. New Facility in 200-West Area at the 

Central Waste Complex at the Hanford Site 
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2.4.4 Long-Term Mercury Management and Storage at Hawthorne Army Depot 

The Hawthorne Army Depot is located approximately 16 kilometers (10 miles) from Hawthorne, Nevada. 

The 59,500-hectare (147,000-acre) site is owned and managed by the U.S. Department of Defense. The 

Hawthorne Army Depot contains 2,427 magazines and 488 buildings with a combined storage capacity of 

714,000 square meters (7,685,000 square feet). A general photograph of the Hawthorne Army Depot is 

presented in Figure 2–11. Fourteen of these buildings have been designated and modified for the 

consolidated storage of the DNSC mercury. The design of the 14 buildings consists of reinforcedconcrete walls, floors, and foundations. The roof materials are steel truss systems covered with asbestos 

concrete (transite) roofing material. 

Figure 2–11. Existing Storage Buildings at the Hawthorne Army Depot 

in State of Nevada 

Under this alternative, DOE would designate a maximum of 29 buildings in the Central Magazine Area, 

the current location designated for DNSC mercury storage, which would provide up to approximately 

27,000 square meters (290,000 square feet) of storage space for DOE storage of mercury. These 

29 buildings are similar to the 14 buildings designated for DNSC storage of mercury before they were 

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

and might include reinforcing and epoxy-sealing the floor; installing spill control measures, utilities, and 

security monitors; and servicing the rail spur. Figure 2–12 illustrates the location of the 29 storage 

buildings in relation to the DNSC mercury storage buildings and other buildings within the Hawthorne 

Army Depot. Truck and rail access are available in the Central Magazine Area. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–17

Figure 2–12. Existing Buildings in Central Magazine Area at 

Hawthorne Army Depot in State of Nevada 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–18

2.4.5 Long-Term Mercury Management and Storage at Idaho National Laboratory 

The INL site is a 230,323-hectare (569,135-acre) area located in southeastern Idaho. INL consists of 

several facility areas situated on an expanse of otherwise undeveloped, cool desert terrain. Most 

buildings and structures at INL are within these developed site areas, which are typically less than a few 

square miles in size and separated from each other by miles of primarily undeveloped land. DOE owns 

and manages the land within INL. Two options for long-term storage of mercury at INL have been 

identified: (1) new construction at INTEC and (2) reuse of existing RWMC buildings. Figure 2–13 shows 

INL and the relative locations of INTEC and RWMC. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–19

Figure 2–13. Idaho National Laboratory in State of Idaho 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–20

2.4.5.1 Idaho Nuclear Technology and Engineering Center Option 

Known as the Idaho Chemical Processing Plant until 1998, INTEC was established in the 1950s to 

recover usable uranium from spent nuclear fuel used in DOE and U.S. Department of Defense reactors. 

Current operations at INTEC include management of sodium-bearing waste, special nuclear material 

disposition, spent nuclear fuel storage, nuclear material disposition, environmental remediation, and 

demolition of excess facilities (INL 2008). An aerial photograph of INTEC is presented in Figure 2–14. 

Figure 2–14. Idaho Nuclear Technology and Engineering Center at 

Idaho National Laboratory 

This alternative involves construction of a new facility, as described in Sections 2.2.1 and 2.3.1 and 

Appendix C. The new facility would be located at INTEC, as illustrated in Figure 2–15. Truck and rail 

access are available at INTEC. A full-size mercury storage facility with a 10,000-metric-ton (11,000-ton) 

capacity would essentially occupy all of the available (approximately 3.1-hectare [7.5-acre]) area 

proposed for locating the facility. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–21

Figure 2–15. New Facility at Idaho Nuclear Technology and Engineering Center at 

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

2–22

2.4.5.2 Radioactive Waste Management Complex Option 

RWMC has a number of buildings in the Transuranic Storage Area currently dedicated to storage, 

staging, characterization, and shipping of transuranic (TRU) waste. This alternative involves using seven 

Type II storage modules for the DOE storage of mercury. These Type II storage modules are a series of 

buildings that are covered by an existing RCRA permit and were designed and built for hazardous waste 

storage. With each building providing approximately 2,700 square meters (29,000 square feet) of storage, 

a total of approximately 19,000 square meters (205,000 square feet) of storage space would be available 

for long-term mercury storage. While currently in use, the TRU waste mission is anticipated to be 

completed by 2015 pursuant to the provisions of the October 1995 Settlement Agreement among the State 

of Idaho, the U.S. Department of the Navy, and the U.S. Department of Energy.5

 One of the Type II 

storage modules could be made available starting in 2013 for DOE storage of mercury; the other six could 

be made available by 2015. These are prefabricated modular structures built on a sealed 

concrete foundation. An aerial photograph of the RWMC and the seven storage models is presented in 

Figure 2–16. Minor modifications to the existing buildings might include reapplying epoxy floor sealant, 

modifying some of the space to function as the Handling Area, installing security monitors, and servicing 

the rail spur. Figure 2–17 illustrates the location of the seven storage modules in relation to other 

buildings within RWMC. Truck and rail access are available at RWMC. 

Figure 2–16. Radioactive Waste Management Complex at Idaho National Laboratory 

 

5

 This agreement settles claims made in the cases Public Service Co. of Colorado v. Batt (Civil No. CV 91-0035-SEJL) and United States v. Batt (Civil No. CV-91-0054-S-EJL). 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–23

Figure 2–17. Existing Buildings in Radioactive Waste Management Complex at 

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

2–24

2.4.6 Long-Term Mercury Management and Storage at Kansas City Plant 

KCP is part of the 125-hectare (310-acre) Bannister Federal Complex located 13 kilometers (8 miles) 

south of downtown Kansas City, Missouri. KCP occupies 55 hectares (136 acres) of the complex and is 

under the custody and control of DOE’s National Nuclear Security Administration (NNSA). KCP is 

contiguous with U.S. General Services Administration facilities, which are also part of the Bannister 

Federal Complex. KCP manufactures electrical, mechanical, plastic, and other nonnuclear components of 

nuclear weapons (GSA and NNSA 2008). Under the Kansas City Responsive Infrastructure 

Manufacturing and Sourcing Project, NNSA is in the process of relocating KCP operations to a new 

facility located approximately 13 kilometers (8 miles) south of the Bannister Federal Complex. The 

relocation is scheduled to begin in 2011 and be completed in 2013. Initially, approximately 

14,000 square meters (150,000 square feet) of storage space could be available for the long-term storage 

of mercury. If NNSA operations move to another location as planned, additional space could become 

available (Holecek 2009). An aerial photograph of the Kansas City Plant is presented in Figure 2–18. 

Modifications to the storage building would be required prior to storage of mercury and might include 

reapplying epoxy floor sealant, upgrading ventilation systems, installing security monitors, and servicing 

the rail spur. Figure 2–19 illustrates the location of the proposed storage building within the Bannister 

Federal Complex. Truck and rail access are available at KCP. 

Figure 2–18. Kansas City Plant in State of Missouri 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–25

Figure 2–19. Existing Building at Kansas City Plant in State of Missouri 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–26

2.4.7 Long-Term Mercury Management and Storage at Savannah River Site 

SRS is located in south-central South Carolina and occupies approximately 80,290 hectares 

(198,400 acres) in Aiken, Barnwell, and Allendale Counties. The site was established in 1950 and is 

approximately 24 kilometers (15 miles) southeast of Augusta, Georgia, and 19 kilometers (12 miles) 

south of Aiken, South Carolina. A general map of SRS is illustrated in Figure 2–20. 

This alternative involves construction of a new facility, as described in Sections 2.2.1 and 2.3.1 and 

Appendix C. The new facility would be located in E Area of SRS. Figure 2–21 presents an aerial 

photograph of E Area; Figure 2–22 illustrates the proposed location of the new facility at E Area. A 

full-size mercury storage facility with a 10,000-metric-ton (11,000-ton) capacity would occupy 

3.1 hectares (7.5 acres) of the available (approximately 32-hectare [78-acre]) area proposed for locating 

the facility. 

E Area is located in the central part of SRS and covers approximately 134 hectares (330 acres). The 

current land use designation for E Area is Site Industrial Use. E Area, which includes the Old Burial 

Ground, Mixed Waste Management Facility, TRU waste pads, and E Area Vaults, receives low-level 

solid, TRU, and mixed waste from all site areas. Low-level radioactive waste is disposed of in the E Area 

Vaults or trenches. TRU waste is characterized and prepared for shipment to the Waste Isolation Pilot 

Plant for ultimate disposal (DOE 2005). Truck and rail access are available in E Area. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–27

Figure 2–20. Savannah River Site in State of South Carolina 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–28

Figure 2–21. E Area at the Savannah River Site 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–29

Figure 2–22. New Facility in the Savannah River Site E Area 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–30

2.4.8 Long-Term Mercury Management and Storage at Waste Control 

Specialists, LLC 

WCS, a commercial entity, owns and operates a large 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. The site is surrounded by a 5,460-hectare (13,500-acre) tract of land also owned by 

WCS. The WCS facility is RCRA permitted for storage of hazardous waste. The CSB, which is located 

within the WCS facility, is covered under the existing RCRA permit; the CSB is presently configured to 

store hazardous waste and could provide temporary storage of mercury. The CSB could provide 

approximately 2,650 square meters (28,500 square feet) of storage space. An aerial photograph of the site 

is presented in Figure 2–23. 

Figure 2–23. Waste Control Specialists in State of Texas 

This alternative is the construction of a new facility, as described in Sections 2.2.1 and 2.3.1 and 

Appendix C. The new facility would be located within the areas illustrated in Figure 2–24. A full-size 

mercury storage facility with up to a 10,000-metric-ton (11,000-ton) capacity would occupy 3.1 hectares 

(7.5 acres) of the available (approximately 102-hectare [252-acre]) area proposed for locating the facility. 

The CSB could be used on an interim basis, if necessary, to store mercury until construction of a new 

facility is completed. The CSB would be capable of storing approximately 2,000 metric tons (2,200 tons) 

of mercury. Figure 2–24 also illustrates the location of the CSB within the WCS site. Truck and rail 

access are available at the site. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–31

Figure 2–24. New and Existing Facilities at Waste Control Specialists, LLC, in 

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

2–32

2.5 PREFERRED ALTERNATIVE 

DOE has identified long-term mercury storage at WCS of Andrews, Texas, as the Preferred Alternative. 

The WCS site is located near the New Mexico border and has been extensively characterized and studied 

due to the wide range of waste management activities that occur there. The area around this location has 

a very low population density. In addition, WCS is not located near any major surface-water bodies; the 

nearest surface-water body is more than 16 kilometers (10 miles) away. The site also has the benefit of an 

existing rail line. This mercury storage facility would be compatible with existing waste management 

activities at the site, as well as site land use plans and regulatory agreements. 

2.6 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED 

ANALYSIS

A number of alternatives were considered but were not evaluated in detail. As required by Council on 

Environmental Quality regulations (40 CFR 1502.14(a)), this section discusses the reasons for elimination 

of the alternatives from detailed study. Alternatives may be eliminated from further consideration 

because of technical immaturity, regulatory unacceptability, or because they do not support the purpose 

and need for the proposed action. 

2.6.1 Storage-Related Alternatives 

The Act specifies that the DOE-designated mercury storage facility(ies) shall not include Y–12 or any 

other portion or facility of 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. 

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

Knoxville, Tennessee, comprising Lowland Environmental Services; Sustainable Construction and 

Consulting; and 840, LLC, responded to the Request for Expressions of Interest that DOE published in 

the Federal Register. Both parties were interested in constructing a long-term mercury storage facility for 

DOE. However, neither party fulfilled the basic requirement to propose a specific location for siting such 

a facility. Veolia ES Technical Solutions, LLC, later withdrew itself from consideration for long-term 

storage of mercury. Because neither of these companies proposed a specific candidate site to be 

evaluated and because Veolia ES Technical Solutions, LLC, withdrew its Expression of Interest 

submission, both of these Expressions of Interest were eliminated from detailed study in this Mercury 

Storage EIS. Additionally, Meritex Enterprises, Inc., from 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. 

DOE considered but eliminated from detailed study several other potential facilities, including the Fuels 

and Materials Examination Facility (FMEF), located in the 400 Area of Hanford; the CPP-691 Fuel 

Processing Restoration (FPR) Facility, located at INL’s INTEC; and buildings in N Area and F Area at 

SRS. As noted in Chapter 1, Section 1.5.1, DOE developed criteria for screening proposed candidate 

facility locations. Among these criteria are: (1) the facility(ies) will not create significant conflict with 

any existing DOE site mission and will not interfere with future mission compatibility; (2) the candidate 

host location has an existing facility(ies) suitable for mercury storage with the capability and flexibility 

for operational expansion, if necessary; (3) the facility(ies) is, or potentially will be, capable of complying 

with RCRA permitting requirements; and (4) storage of mercury at the facility(ies) is compatible with 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–33

local and regional land use plans. Another criterion is that the building will need to be available in a 

timely fashion such that the facility will be ready to accept mercury for long-term storage by 

January 1, 2013. 

FMEF is located in the 400 Area of Hanford. Although land in the 400 Area is designated for industrial 

use, including reactor operations, manufacturing, warehousing, and related activities, FMEF currently has 

the following limitations: its design and internal configuration are not optimal for waste storage; it is not 

RCRA permitted; and it would require significant modifications to meet statutory and regulatory storage 

requirements. FPR is located in INL’s INTEC. The facility was designed and constructed as a fuel 

reprocessing facility with heavily reinforced walls and multiple levels. Similar to FMEF, FPR is not 

RCRA permitted, and it would likewise require substantial modifications to meet RCRA standards for 

waste storage. Therefore, because these two options are not conducive to waste storage operations and 

would likely require significant modifications to meet RCRA requirements, DOE has eliminated FMEF at 

Hanford and FPR at INL from further consideration as potential sites. 

SRS is accelerating cleanup and decommissioning of many of its buildings with funds received under the 

American Recovery and Reinvestment Act of 2009 (P.L. 111-5). SRS has a stated objective to reduce its 

footprint up to 40 percent by 2011. SRS plans to consolidate waste storage operations from B and 

N Areas into E Area (Belencan 2009). Pursuant to these objectives, Buildings 645-N, 645-4N, and 

645-2N are scheduled for decontamination and demolition. If these buildings were considered in this EIS 

as a potential alternative site, the scheduled decontamination and demolition of these buildings would 

have to be significantly delayed until a final decision is made regarding the location of a long-term 

mercury storage facility. Therefore, because this option is not compatible with future site missions, these 

buildings were removed from further consideration. 

DOE also considered SRS Buildings 221-12F, 221-21F, and 221-22F in F Area as potential storage sites 

for mercury. However, these buildings have previously been committed to support the Mixed Oxide Fuel 

Program and would not be available to support the long-term storage of mercury. Therefore, because 

these buildings are committed to another future DOE mission, these buildings were eliminated from 

further consideration. 

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. 

2.6.2 Treatment Alternatives 

EPA regulates the treatment and disposal of mercury-containing wastes through waste management 

regulations under RCRA. The intent of these regulations is to encourage the recovery of mercury for 

reuse from wastes that contain high concentrations of mercury. The treatment standard for mercury 

wastes with concentrations greater than 260 milligrams per kilogram is roasting or retorting of mercury 

and subsequently condensing the volatilized mercury for reclamation, yielding high-purity elemental 

mercury (40 CFR 268). 

EPA issued an Advanced Notice of Proposed Rulemaking on May 28, 1999 (64 FR 28949), declaring its 

intent to consider revisions to the “Land Disposal Restrictions,” treatment standards applicable to 

mercury-bearing wastes (40 CFR 268). With this notice, EPA also stated its intent to conduct a 

comprehensive reevaluation of the treatment standards for mercury-bearing hazardous wastes, as well as 

various options, issues, and data needs related to potential mercury treatment standards. 

On January 29, 2003, EPA published a Notice of Data Availability in the Federal Register (68 FR 4481) 

making available two studies conducted on mercury waste treatment. The results of the two studies are 

provided in the following reports: (1) Technical Background Document: Mercury Wastes–Evaluation of 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–34

Treatment of Mercury Surrogate Waste and (2) Technical Background Document: Mercury Wastes–

Evaluation of Treatment of Bulk Elemental Mercury. The studies were intended to help EPA determine 

whether it could propose treatment and disposal alternatives to the current land disposal restrictions for 

mercury-bearing wastes. The studies were performed to assess conditions that affect the stability of waste 

residues resulting from the treatment of high-concentration mercury and elemental mercury wastes 

destined for disposal. Based on these studies and the general lack of technological maturity, EPA 

concluded that it could not establish new national treatment standards for disposal of high-concentration 

mercury and elemental mercury wastes. As of 2009, no further action has been taken by EPA to establish 

alternative treatment and disposal requirements for mercury-bearing wastes exceeding concentrations of 

260 milligrams per kilogram (high-concentration mercury subcategory wastes) or elemental mercury. 

Therefore, DOE is not considering treatment options for detailed evaluation in this Mercury Storage EIS. 

2.6.3 Transportation Methods Not Considered in Detail 

Transportation by air or barge is not analyzed in this Mercury Storage EIS. Air transport is not 

considered a reasonable option because of the additional cost and handling that would be required to 

move the mercury by truck or rail to and from the airports. The weight of the mercury would also limit 

the amount of mercury that could be transported per trip. 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 that would be required to move the mercury by truck or rail to and from the 

barge route. 

2.7 COMPARISON OF ALTERNATIVES 

This section presents a comparison of alternatives analyzed in this Mercury Storage EIS, including the 

No Action Alternative. Table 2–1 presents a comparison of key physical setting and location factors, 

i.e., those factors that provide some means of discerning the differences among action alternative sites 

regarding their surroundings, operational experience, or land use compatibility. These factors, among 

others, are discussed in more detail in Chapter 3. 

Depending on the resource area, environmental consequences would be negligible, similar with no 

discernible differences between alternatives, or vary from one alternative to another. Table 2–2 presents a 

summary comparison of environmental consequences across action alternatives for some resource areas. 

Those resource area environmental consequences that are projected to be negligible or very low under all 

action alternatives have not been included in Table 2–2. Resource areas not included in this table are 

water, noise, ecological, cultural and paleontological, waste management, and socioeconomics. 

Environmental consequences for all resource areas are summarized in Section 2.7.1 and discussed in 

detail in Chapter 4. 

Because of the various sites and circumstances in which mercury would be stored under the No Action 

Alternative, environmental consequences would be highly speculative and are not readily quantifiable or 

comparable to the individual storage sites analyzed under the action alternatives. Mercury storage 

locations under the No Action Alternative are largely undefined; thus, the potential environmental 

consequences of storage could be greater or smaller than those presented for the action alternatives. 

Environmental consequences to land use and visual resources, geology and soils, ecological resources, 

and cultural and paleontological resources are dependent on the affected environment disturbed and 

amount of land disturbance that might occur. Because the No Action Alternative could involve expansion 

and/or modification of storage capacities at multiple locations, it is possible that more or less land, or land 

with more-or-less sensitive resources than those analyzed under the action alternatives, could be affected. 

Potential environmental consequences to water resources would depend on the specific location and 

proximity to surface-water bodies and groundwater aquifers and the current use of these water resources. 

Therefore, the environmental consequences to water resources could be more or less than under the action 

alternatives. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–35

Impacts on infrastructure and waste management would depend on the specific infrastructure and waste 

management capabilities available to support the mercury storage facility(ies). Impacts on 

socioeconomics and environmental justice would be related to the changes in employment due to changes 

in mercury storage and the minority and low-income composition of the communities near the mercury 

storage facility(ies). Because impacts on infrastructure, waste management, socioeconomics, and 

environmental justice are indeterminate for the No Action Alternative, impacts could be more or less than 

under the action alternatives. 

Under the No Action Alternative, the management and storage of mercury may or may not be conducted 

in accordance with RCRA regulations. As such, it would be reasonable to conclude that there could be a 

heightened risk associated with facility accidents and the inconsistent management and storage of 

mercury containers. This could lead to greater environmental consequences associated with air quality, 

occupational and public health and safety, and ecological resources. In contrast, because much of the 

excess mercury would remain at the generating facilities and would not be transferred to a DOE long-term 

storage facility, it is reasonable to expect that environmental consequences associated with transportation 

would be somewhat less than those predicted to occur under the action alternatives. 

There would be no environmental consequences under the No Action Alternative at any of the candidate 

sites because a DOE-operated mercury storage facility(ies) would not be constructed and/or operated. 

Conversely, under any of the action alternatives, there would be beneficial environmental consequences at 

the various locations where excess mercury is currently stored, including Y–12, because the mercury 

would be transferred to a DOE facility(ies) for long-term storage. 

Action alternatives that involve using existing buildings would result in construction-related impacts that 

would be very low when compared to action alternatives that involve construction of a new mercury 

storage facility. In other words, action alternatives in which new construction occurs would likely show 

higher impacts than those in which an existing facility(ies) is modified with respect to certain resource 

areas, e.g., land use, visual resources, air quality, short-term impacts, and commitment of resources. 
2–36

Table 2–1. Comparison of Action Alternatives – Physical Setting and Location Factors 

a This factor does not imply that a permit already exists for the storage of mercury; rather, this factor is intended to establish a candidate site’s experience operating under 

Alternatives That Use Existing Buildings Alternatives That Require New Con

Site/Resource 

Factor 

INL 

RWMC 

Hawthorne Army 

Depot KCP GJDS 

Hanford 

200-West Area 

SRS 

E Area 

Site size in hectares (acres) 

INL: 230,323 

(569,135) 

RWMC: 76 

(187) 

59,500 

(147,000) 

55 

(136) 

146 

(360) 

Hanford: 151,775

(375,040) 

200 Areas: 5,064

(12,513) 

SRS: 80,290

(198,400) 

E Area: 134 

(330) 

Enti

Fa

Compatible with land use plans? 

Yes Yes; facility use 

agreement between DoD 

and DOE may be 

required. 

Yes Concern: 1996 

MOU possible 

restriction on 

land use and 

current zoning – 

under 

evaluation. 

Yes Yes 

Facility or site operates under existing RCRA storage permits.a

Yes Yes No No Yes Yes 

Seismic riskb 0.12 g 0.57 g 0.05 g 0.14 g 0.18 g 0.17 g Nearest surface-water feature 

Big Lost River 

Channel 1.6 km 

(1 mile) northwest. 

Diversion spread 

areas (intermittent 

and seasonal) 

1.6 km (1 mile) 

west. 

Walker Lake 5.0 km 

(3.1 miles) northwest. 

Blue River borders site 

to the east and Indian 

Creek borders site to 

the south. 

Cheney 

Reservoir 

0.6 km (1 mile) 

southeast. 

Columbia River 

10 km (6.2 miles) 

north. 

Cold Creek 

(ephemeral) 

4.8 km (3 miles) 

south. 

Upper Three 

Runs Creek 

500 m 

(1,640 feet) 

north. 

N

fea

16 k

R

dr

(inte

seas

(0

s

Site in 100-year floodplain? 

No No Yes; flood protection 

system designed for 

500-year flood event. 

No No No 

Residential population within 16-km (10-mile) radius 

257 3,561 700,041 2,119 0 7,103 

Environmental justice within 16-km (10-mile) radius 

No minority or 

low-income census 

block groups. 

No minority or lowincome census block 

groups. 

172 minority only, 

2 low-income only, 

and 74 that are both 

minority and 

low-income census 

block groups (out of 

671 blocks). 

No minority or 

low-income 

census block 

groups. 

No minority or 

low-income census 

block groups. 

Four minority 

and no lowincome census 

block groups 

(out of 

14 blocks). 

One 

no 

ce

gro

8 

Site employment 8,485 (INL) 500 2,400 7 9,759 (Hanford) 8,400 (SRS) 

b Seismic risk is based on predicted peak acceleration for an earthquake event expected to occur once in 2,500 years. Earthquake-produced ground motion is expresse

acceleration relative to that of Earth’s gravity). 

Note: Various mercury storage locations, many of which are undetermined, would be involved under the No Action Alternative; therefore, these locations are not prese

presents a discussion comparing the potential environmental consequences of the No Action Alternative against those of the action alternatives. 

Key: DoD=U.S. Department of Defense; DOE=U.S. Department of Energy; GJDS=Grand Junction Disposal Site; Hanford=Hanford Site; INL=Idaho National Laboratory

and Engineering Center; KCP=Kansas City Plant; km=kilometers; m=meters; MOU=Memorandum of Understanding; RCRA=Resource Conservation and RecoverManagement Complex; SRS=Savannah River Site; WCS=Waste Control Specialists, LLC. 
2–37

Table 2–2. Comparison of Action Alternatives – Environmental Consequences 

Alternatives That Use Existing Buildings Alternatives That Require New Cons

Resource/Site 

INL 

RWMC 

Hawthorne 

Army Depot KCP GJDS 

Hanford 

200-West 

Area 

SRS 

E Area 

Land use and visual resources 

New land would not be disturbed nor would any of the proposed existing buildings have to be expanded to accommodate the long-term storage of mercury. Therefore, there would be no impacts on land use or visual resources. 

Construction of a new mercury storage facility would disturb (7.5 acres) of land, which represents 3 percent or less of eacsize. Because of the low percentage of relative land disturbanew storage building, there would be minimal impacts on la(Note: For GJDS only; 1996 MOU possible restriction on launder evaluation.) 

Geology and soils None 

May require minor trenching for utility connections. 

None 

Potentially would disturb and expose up to 3.1 hectares (7.5 approximately 60 centimeters (24 inches) for 6 months. Geofor construction of a new facility would include approximate(6,220 cubic yards) of concrete and 3,875 cubic meters (5,07stone. 

Air quality 

Negligible air emissions would occur for modification of existing buildings. Operation of a long-term mercury storage facility(ies) would not involve the treatment or processing of mercury; therefore, air emissions would be negligible and limited to employee vehicles, trucks, semiannual testing of emergency generators, and venting of residual mercury vapors. Truck and/or rail transport of mercury would result in negligible emissions of criteria and toxic air pollutants. 

Minor short-term air quality impacts would occur during confacility, primarily due to dust generation and emissions from of a long-term mercury storage facility(ies) would not involvof mercury; therefore, air emissions would be negligible and vehicles, trucks, semiannual testing of emergency generatormercury vapors. Truck and/or rail transport of mercury wouemissions of criteria and toxic air pollutants. 

Carbon dioxide would be generated from fuel-burning equipment used in construction of a new facility, if applicable, and 

mercury to the storage facility; however, emissions (maximum of 3,699 metric tons [4,077 tons]) would be negligible com

worldwide generation of carbon dioxide (estimated at 26.4 billion metric tons [29.1 billion tons]) and would have a negligclimate. 

Infrastructure 

Negligible; capacity would meet increased demands. 

Negligible; capacity would meet increased demands. 

Negligible; capacity would meet increased demands. 

Moderate; electrical capacity would have to be increased. No public water supply. No rail access. 

Negligible; capacity would meet increased demands. 

Negligible; capacity would meet increased demands. 

Ncawinde

Occupational and public health and safetyaNormal operationsb, c

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

Facility accidentsc Consequences range from SL-I to -II with an associated negligible-to-low risk to involved workers and noninvolved work

outside spills. Consequences of SL-I with an associated negligible risk to public receptors from inside and outside spills. 
2–38

Table 2–2. Comparison of Action Alternatives – Environmental Consequences (continued) 

Alternatives That Use Existing Buildings Alternatives That Require New Const

Resource/Site 

INL 

RWMC 

Hawthorne 

Army Depot KCP GJDS 

Hanford 

200-West Area

SRS 

E Area 

Transportationa, dTruck kilometers (miles) 

2,662,210 

(1,654,297) 

3,127,892 

(1,943,672) 

2,230,117 

(1,385,795) 

2,509,474 

(1,559,387) 

3,399,774 

(2,112,620) 

2,707,719 

(1,682,577) 

(

Annual truck accident fatalitiese 9.2×10-4 1.1×10-3 7.8×10-4 8.7×10-4 1.2×10-3 9.4×10-4 Truck accident –human healthc

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

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

acute-inhalation consequences could be in the range from SL-I to -III with an associated low (SL-II) or negligible (SL-I or 

scenarios. The corresponding consequences following deposition on the ground could be SL-I with an associated negligibof mercury into water, the consequences could be SL-I or -II with an associated negligible-to-low risk (but with a large de

Rail kilometers (miles) 

600,133 

(372,923) 

635,564 

(394,939) 

403,890 

(250,997) 

510,579 

(317,274) 

729,541 

(453,337) 

489,769 

(304,342) 

Annual rail accident fatalitiese 1.5×10-4 1.6×10-4 1.0×10-4 1.3×10-4 1.9×10-4 1.2×10-4 Rail accident – human healthc, f

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

associated risk. For transportation accidents with fires, acute-inhalation consequences could be in the range from SL-I to -

(SL-II) or negligible (SL-I or SL-III) risk. The corresponding consequences following deposition on the ground could be negligible risk. For direct spillages of mercury into water, the consequences could be SL-I or -II with an associated negliglarge degree of uncertainty). 

Ecological impactsa, c

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

potentially having somewhat greater consequences. The associated risk to ecological receptors would range from negligibof wet deposition with rail transport, for which the risk would be negligible to all receptors. The highest ecological risk w

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

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. 

None None 

A transportation 

accident at or near 

the facility could 

disproportionately

impact minority 

individuals. 

disp

i

l

and

i

a Risk is an assessment that is a function of the frequency of an event and the magnitude of its potential impact. See Chapter 4 and Appendix D for detailed discussion on 

moderate, and high) risk assessment. 

b Negligible risk to involved workers, noninvolved workers, and public receptors. 

c 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 

d The greatest transportation impact under either Truck Scenario 1 or 2 is presented in this table; see Chapter 4 and Appendix D for more details. 

e 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 fata

of this environmental impact statement. f Potential transportation impacts by rail to GJDS would involve intermodal transportation: rail transport to Grand Junction, transfer from rail to truck, and truck transport t

Note: Various mercury storage locations, many of which are undetermined, would be involved under the No Action Alternative; therefore, these locations are not presen

presents a discussion comparing the potential environmental consequences of the No Action Alternative against those of the action alternatives. 

Key: GJDS=Grand Junction Disposal Site; Hanford=Hanford Site; INL=Idaho National Laboratory; INTEC=Idaho Nuclear Technology and Engineering 

MOU=Memorandum of Understanding; RWMC=Radioactive Waste Management Complex; SL=severity level; SRS=Savannah River Site; WCS=Waste Control Specialist
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–39

2.7.1 Summary of Environmental Consequences 

This section summarizes the potential impacts on resources under the Mercury Storage EIS alternatives. 

Detailed descriptions and in depth discussions of impacts on resources are provided in Chapter 4. The 

action alternatives evaluate the impacts on resource areas of the transportation, receipt, and long-term 

storage of mercury at a designated facility, whether the alternative involves new construction or 

modification to an existing building. 

As described in Section 2.3.1, a new mercury storage facility could be built in a modular fashion by 

constructing sections of the Storage Area on an as-needed basis. The analysis in this EIS assumes that the 

entire facility (10,000-metric-ton [11,000-ton] capacity) would be constructed at the same time, thereby 

evaluating the maximum or peak impacts that could reasonably be expected. If the facility were to be 

constructed in a modular fashion, impacts would occur at different times; however, the peak of these 

impacts would be less. 

The No Action Alternative would affect all sources of mercury. Excess mercury that could not be sold 

would be stored as a commodity 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. Therefore, the potential 

impacts of such storage are speculative. The approximately 1,200 metric tons (1,300 tons) of DOE 

mercury currently stored in 35,000 of the 3-L flasks at Y–12 would continue to be managed and stored in 

this location. No new construction would be required at Y–12, nor would any incremental increase in 

impacts on resource areas occur because storage operations at Y–12 would not change. Additional 

discussion on environmental consequences under the No Action Alternative is provided in Chapter 4. 

2.7.1.1 Land Use and Visual Resources 

Impacts on land use can be evaluated by comparing new land disturbance to the size of the proposed site 

that would have the potential to be impacted. Table 2–3 presents the size of each proposed site and the 

relative percentage of land at each site that would be affected under each alternative. 

No impacts on land use or visual resources are expected under action alternatives involving the use of 

existing buildings because no new construction or substantial external modifications to the buildings 

would be required. 

For the 200-West Area at Hanford, INTEC at INL, and E Area at SRS, the land required to construct a 

new facility would be negligible compared with the relative size of the candidate site. Therefore, the 

impacts on land use would be negligible. 

Under all action alternatives involving construction of a new facility, the relative impacts on land use and 

visual resources are expected to range from negligible to minor and, in all cases, would not change the 

U.S. Bureau of Land Management visual resource management classifications. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–40

Table 2–3. Relative Land Use Impacts 

Alternative 

Site Size in 

Hectares (Acres) 

Percentage of New Land 

Disturbancea

Grand Junction Disposal Site 146 (360) 2.0 percent 

Hanford Site, 200-West Area Hanford: 151,775 (375,040) 

200 Areas: 5,064 (12,513) 

Negligible (Hanford) 

< 0.1 percent (200 Areas) 

Hawthorne Army Depot 59,500 (147,000) Not applicable 

(existing building) 

Idaho National Laboratory, 

Idaho Nuclear Technology and 

Engineering Center 

INL: 230,323 (569,135) 

INTEC: 107 (264) 

Negligible (INL) 

3.0 percent (INTEC) 

Idaho National Laboratory, 

Radioactive Waste Management 

Complex 

INL: 230,323 (569,135) 

RWMC: 76 (187) 

Not applicable 

(existing building) 

Kansas City Plant 55 (136) Not applicable 

(existing building) 

Savannah River Site, E Area SRS: 80,290 (198,400) 

E Area: 134 (330) 

Negligible (SRS) 

2.3 percent 

Waste Control Specialists, LLC Entire site: 5,460 (13,500) 

Facilities: 541 (1,308) 

< 0.1 percent (entire site) 

1.0 percent (facilities) a No new land disturbance would occur under the action alternatives that propose to use existing buildings. New land 

disturbance would be 3.1 hectares (7.5 acres) under alternatives proposing to construct a new facility. Percentage of new 

land disturbance is the relative size of a new facility to the size of the candidate site. 

Key: <=less than; Hanford=Hanford Site; INL=Idaho National Laboratory; INTEC=Idaho Nuclear Technology and Engineering 

Center; RWMC=Radioactive Waste Management Complex; SRS=Savannah River Site. 

Under the remaining alternatives, the required land disturbance of 3.1 hectares (7.5 acres) would still 

represent only between 2 and 3 percent of each proposed site’s overall size. Additionally, the low profile 

of a long-term mercury storage building, if it were to be constructed, would have minimal impacts on 

visual resources. 

As discussed in Chapter 1, Section 1.7.1, DOE and Mesa County entered into the 1996 MOU (DOE and 

Mesa County 1996) to provide meaningful consultation with and participation of Mesa County in DOE’s 

use of GJDS. Mesa County’s position is that the use of GJDS is restricted per the 1996 MOU and that 

DOE is obligated to honor this agreement. DOE currently is evaluating the applicability of the 

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

current zoning at GJDS is not compatible with the proposed action and would need to be modified. 

2.7.1.2 Geology, Soils, and Geologic Hazards 

The action alternatives involving use of existing buildings would have negligible impacts on geology and 

soils because these candidate sites have been previously developed, and modifications to existing 

buildings would not include any major earthmoving activities. However, at Hawthorne Army Depot, 

small trenches may need to be excavated to connect utilities to the proposed buildings. 

Action alternatives involving construction of a new storage facility would expose surficial soils for a 

duration of up to 6 months. These activities would disturb up to 3.1 hectares (7.5 acres) at a depth less 

than 60 centimeters (24 inches) for the installation of a reinforced-concrete slab and asphalt-covered lots 

on a compacted gravel base. Some trenching may be required below 60 centimeters (24 inches) for the 

installation of utilities or concrete footers. Adherence to best management practices for erosion and 

sediment control would be implemented during periods of construction to mitigate impacts due to soil 

erosion and loss. Geologic resources would include approximately 4,755 cubic meters (6,220 cubic 

yards) of concrete and 3,875 cubic meters (5,070 cubic yards) of crushed stone. These resources are 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–41

commonly available, and the quantities are relatively small for a construction project and would not 

impact regional supplies. 

Geologic hazards from earthquakes would potentially have an adverse effect on a mercury storage 

facility(ies) and the surrounding area. The predicted peak ground acceleration from a seismic event with 

an annual probability of occurrence of once in 2,500 years for each candidate site and a qualitative 

description of predicted damage for such an event are presented in Table 2–4. The final design for 

construction of a new facility or modification to existing buildings would take seismic risk into 

consideration to protect the public, workers, and the environment from potential adverse effects of a 

significant seismic event. Therefore, facilities built in an area of higher seismic risk could involve 

additional design and construction considerations than facilities built in an area of lower seismic risk. 

Table 2–4. Seismic Risk for Candidate Sitesa

Alternative Seismic Riskb Qualitative Assessment 

Grand Junction Disposal Site 0.14 g Slight damage to ordinary structures; 

no damage to properly designed and 

constructed buildings 

Hanford Site, 200-West Area 0.18 g Slight to moderate damage to ordinary 

structures; no damage to properly 

designed and constructed buildings 

Hawthorne Army Depot 0.57 g Considerable damage to ordinary 

structures; slight damage to properly 

designed and constructed buildings 

Idaho National Laboratory, 

Idaho Nuclear Technology and 

Engineering Center 

0.12 g Slight damage to ordinary structures; 

no damage to properly designed and 

constructed buildings 

Idaho National Laboratory, 

Radioactive Waste Management 

Complex 

0.12 g Slight damage to ordinary structures; 

no damage to properly designed and 

constructed buildings 

Kansas City Plant 0.05 g No damage to ordinary structures or 

properly designed and constructed 

buildings 

Savannah River Site, E Area 0.17 g Slight to moderate damage to ordinary 

structures; no damage to properly 

designed and constructed buildings 

Waste Control Specialists, LLC 0.12 g Slight damage to ordinary structures; 

no damage to properly designed and 

constructed buildings 

a Seismic risk values represent predicted peak acceleration for an earthquake event expected to occur once 

in 2,500 years. 

b Earthquake-produced ground motion is expressed in units of percent g (i.e., force of acceleration relative 

to that of Earth’s gravity). 

2.7.1.3 Water Resources 

All ground-disturbing activities performed under action alternatives involving the construction of a new 

mercury storage facility (at GJDS, 200-West Area at Hanford, INTEC at INL, E Area at SRS, or WCS) 

would be conducted in accordance with current National Pollutant Discharge Elimination System and 

state general wastewater discharge permits. A stormwater pollution prevention plan would be developed 

and implemented. Construction of a new mercury storage facility would require approximately 

1,270,000 liters (336,000 gallons) of water over the 6-month construction period for dust suppression and 

for potable and sanitary needs. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–42

During operation of a mercury storage facility(ies) under all action alternatives, best management 

practices for storage of mercury would be employed to prevent spills and releases of mercury into the 

environment, including the use of spill trays under mercury containers, spill containment features, and 

regular inspections in accordance with RCRA regulations. Operation of a mercury storage facility(ies) 

under all action alternatives would require 88,500 liters (23,375 gallons) of water per year for potable and 

sanitary needs. 

2.7.1.4 Air Quality and Noise 

Minor short-term air quality impacts would occur under those alternatives involving construction of a new 

storage facility. These impacts would include a small increase in criteria and toxic air pollutant emissions 

from construction equipment and earth-disturbing activities in the immediate vicinity of the construction 

site that would occur only during working hours. Emissions would occur over a 6-month construction 

period and would not exceed any ambient air quality standard. Air emissions during modification of 

existing buildings for mercury storage would be negligible. 

Operation of a long-term mercury storage facility(ies) would not involve the treatment or processing of 

mercury; therefore, air emissions are projected to be negligible and limited to employee vehicles, trucks, 

semiannual testing of emergency generators, and the occasional exhausting of air from the Storage Areas. 

Occasionally, mercury containers would need to be emptied and repackaged in the Handling Area. 

Repackaging of mercury in new containers would generate some mercury vapors. The Handling Area 

would be outfitted with a vacuum air exhaust and mercury vapor filter, which would maintain air 

emissions exhausted to the outside at negligible concentrations during repackaging operations. 

Truck and/or rail transport of mercury from various facilities to the DOE long-term mercury storage 

facility(ies) would generate air emissions along routes of transport. The peak year of emissions from 

transport of mercury is expected to occur in 2013, the first year of facility operation. The frequency of 

truck and/or rail shipments is expected to decrease over time. Maximum air emissions from transporting 

the mercury would occur under the Hanford 200-West Area alternative; expected emissions are directly 

proportional to the number of miles required to transport the mercury to the facility. Truck transport to 

Hanford is predicted to yield the highest concentrations of carbon monoxide, nitrogen dioxide, volatile 

organic compounds, particulate matter, and carbon dioxide, and rail transport to Hanford is predicted to 

yield the highest concentrations of sulfur dioxide. Under the Hanford 200-West Area alternative, 

transport of mercury would require up to approximately 170,000 truck miles or 56,000 rail miles in 2013. 

Carbon dioxide is a compound associated with global climate change. Carbon dioxide emissions 

generated from construction of a new facility, regardless of location, would be approximately 259 metric 

tons (286 tons). The amount of carbon dioxide generated from construction activities and transportation 

of mercury to the selected facility is presented in Table 2–5. Comparing these values with the 26.4 billion 

metric tons (29.1 billion tons) of global carbon dioxide emissions estimated to have occurred worldwide 

from fossil fuel use annually from 2000 through 2005 and U.S. carbon dioxide annual emissions of 

5.98 billion metric tons (6.59 billion tons) in 2006 (IPCC 2007), it can be concluded that the addition of 

carbon dioxide from implementation of any of the action alternatives would have a negligible effect on 

the global climate. 

Construction of a new facility or modification of existing buildings could increase noise levels for a short 

period of time at some sites that are close to a sensitive area (e.g., residences). The predicted maximum 

impact could be at KCP, where the nearest sensitive area is approximately 150 meters (500 feet) away. 

However, because these activities would be indoors, noise impacts on the public would be negligible. All 

action alternatives are not predicted to produce noise above background levels at the nearest sensitive 

area. Therefore, increased noise levels resulting from implementation of any of the action alternatives 

would be very small. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–43

Operational activities associated with the long-term storage of mercury would not result in a measureable 

increase in noise above background levels. The receipt of mercury shipments by truck or rail during 

normal working hours would also not result in a significant increase in noise above current vehicular or 

rail activity. 

Table 2–5. Total and Peak Annual Carbon Dioxide Emissions 

Carbon Dioxide Emissions in Metric Tons (Tons) 

Alternative Constructiona Operationsb Totalc Peak Annuald

Grand Junction Disposal Site 259 (285) 2,540 (2,800) 2,799 (3,085) 259 (285) 

Hanford Site 200-West Area 259 (285) 3,444 (3,796) 3,703 (4,082) 380 (419) 

Hawthorne Army Depot 0 3,160 (3,483) 3,160 (3,483) 367 (405) 

Idaho National Laboratory, 

Idaho Nuclear Technology and 

Engineering Center 

259 (285) 2,690 (2,965) 2,949 (3,251) 304 (335) 

Idaho National Laboratory, 

Radioactive Waste Management 

Complex 

0 2,690 (2,965) 2,690 (2,965) 304 (335) 

Kansas City Plant 0 2,250 (2,480) 2,250 (2,480) 145 (160) 

Savannah River Site, E Area 259 (285) 2,740 (3,020) 2,999 (3,306) 259 (285) 

Waste Control Specialists, LLC 259 (285) 2,940 (3,241) 3,199 (3,526) 259 (285) 

a Construction would occur for 6 months in year 2012. 

b The greatest transportation impact under either Truck Scenario 1 or 2 is presented in this table; this impact would be 

higher than that associated with rail transport (see Chapter 4 and Appendix D for more details). 

c Total emissions include the aggregate for construction and operations during the 40-year analysis period. 

d Peak annual carbon dioxide emissions would occur during year 2013, the year when the maximum number of mercury 

transportation trips are projected to occur, except for the Grand Junction Disposal Site, Savannah River Site E Area, 

and Waste Control Specialists, LLC, for which the peak annual emissions would occur during construction. 

2.7.1.5 Ecological Resources 

No impacts on terrestrial resources are expected under the action alternatives involving the use of existing 

buildings because no new construction or external modifications to the buildings would be required. 

Alternatives requiring construction of a new facility are expected to have little to no impacts on terrestrial 

resources as well because these sites are characterized as consisting largely of previously disturbed land 

within a developed setting. However, under the GJDS and WCS alternatives, construction of a new 

facility may impact some areas that have not previously been disturbed, although none of these areas 

contain critical habitat or protected plant or animal species. 

None of the alternatives proposed are expected to adversely impact wetlands or aquatic species. No 

threatened or endangered species are known or expected to occur within areas proposed under any of the 

alternatives. Therefore, none of the alternatives analyzed are expected to adversely affect any ecological 

resources. 

2.7.1.6 Cultural and Paleontological Resources 

No impacts on cultural or paleontological resources are expected under the action alternatives involving 

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

would be required. 

Although GJDS, Hanford, INL, and surrounding areas contain a high density of cultural and 

paleontological resources, there are no known cultural or paleontological resources existing on the 

proposed sites for construction of a new storage facility, thus impacts are not expected to occur. Hanford 

has various land features that are culturally important to American Indian tribes, such as those associated 

with Gable Mountain and Gable Butte, and INL is situated on the Shoshone-Bannock ancestral homeland. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–44

However, in both cases the proposed location for construction of a new storage facility is not expected to 

have an impact on American Indian resources. 

There are no known prehistoric, historic, American Indian, or paleontological resources in the vicinity of 

SRS’s E Area or the WCS site. Therefore, under these alternative sites, no impacts on cultural or 

paleontological resources are expected to occur. 

2.7.1.7 Site Infrastructure 

Infrastructure impacts could occur if installation of new infrastructure is required where service does not 

currently exist, if project demands exceed or approach available capacity, or if implementation of the 

alternative would otherwise disrupt service. Infrastructure resources include roads and railways, 

electricity, fuel, and water supplies. Projected impacts on infrastructure under each of the alternatives are 

summarized in Table 2–6. 

Table 2–6. Infrastructure Impacts 

Alternative Impacts Assessment 

Grand Junction Disposal Site Electric consumption would be approximately 2.5 times 

current capacity and would require upgrades to electrical 

distribution system. Public water not available at site; bottled 

water would be delivered to meet potable water needs. Direct 

rail access is not available at the site; this mode would require 

transfer of mercury to trucks and intermodal transport. 

Hanford Site 200-West Area Negligible impacts; existing infrastructure is sufficient to 

support a mercury storage facility. 

Hawthorne Army Depot Negligible impacts; existing infrastructure is sufficient to 

support a mercury storage facility. Transportation by rail is 

possible; however, permission would have to be obtained from 

the Walker River Paiute Reservation prior to shipment by rail 

through this area. Proposed existing buildings would need to 

be connected to the site’s electrical distribution system. 

Idaho National Laboratory, 

Idaho Nuclear Technology and 

Engineering Center 

Negligible impacts; existing infrastructure is sufficient to 

support a mercury storage facility. 

Idaho National Laboratory, 

Radioactive Waste Management 

Complex 

Negligible impacts; existing infrastructure is sufficient to 

support a mercury storage facility. 

Kansas City Plant Negligible impacts; existing infrastructure is sufficient to 

support a mercury storage facility. 

Savannah River Site, E Area Negligible impacts; existing infrastructure is sufficient to 

support a mercury storage facility. 

Waste Control Specialists, LLC Negligible impacts; existing infrastructure is sufficient to 

support a mercury storage facility. 

The frequency of mercury shipments is projected to be very small compared with baseline truck and rail 

traffic; therefore, existing road and rail systems would be adequate for supporting the transfer of mercury. 

However, direct rail shipments to GJDS would not be possible; this mode of transportation would require 

rail transport to Grand Junction, transfer of mercury to trucks, and truck transport of mercury from the 

Grand Junction railhead to the DOE facility. 

Action alternatives involving the use of existing buildings would have negligible impacts on 

infrastructure during the construction phase, in which minor modifications to the proposed buildings 

would be completed to accommodate the storage of mercury. However, at Hawthorne Army Depot, the 

existing buildings do not have electrical service and would need to be connected. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–45

Action alternatives involving the construction of a new facility are projected to require 193,000 liters 

(51,000 gallons) of diesel fuel and 1,270,000 liters (336,000 gallons) of water over a 6-month 

construction period. Electricity would be supplied by a diesel-fired generator. Water and fuel would be 

delivered by tanker truck as needed. Therefore, construction of a new facility would have negligible 

impacts at any of the sites because the existing infrastructure would not be used to supply any of the 

necessary utility resources. 

Regardless of whether the storage facility would be new construction or an existing building, operations 

are projected to consume equivalent utility resources. Impacts are measured by a site’s current capacity 

to meet the increased demands on use. Annual operation of a mercury storage facility(ies) is projected to 

require 253 megawatt-hours of electricity, 606 liters (160 gallons) of diesel fuel, and 88,500 liters 

(23,400 gallons) of water. Diesel fuel would be delivered to the site as needed to meet demand and would 

not impact existing infrastructure. 

Under all alternatives, with the exception of GJDS, the existing infrastructure and capacities would be 

sufficient to meet construction and/or operational demands. Operational requirements for electricity 

would exceed current capacities at GJDS; therefore, the tie-in to the regional power distribution system 

would have to be upgraded. 

2.7.1.8 Waste Management 

Action alternatives involving the use of existing buildings would produce small quantities of 

construction-related waste during the construction phase, when minor modifications to the proposed 

buildings would be completed to accommodate the storage of mercury. 

Action alternatives involving the construction of a new facility are projected to generate approximately 

271 cubic meters (355 yards) of nonhazardous solid waste construction debris and 9,841 liters 

(2,600 gallons) of sanitary liquid waste. These volumes are comparable to a typical construction site and 

are expected to have negligible impacts on regional facilities. 

The operation of a mercury storage facility(ies) is expected to generate approximately 23 drums 

(208 liters [55 gallons] each) of hazardous waste and 59,000 liters (15,575 gallons) of sanitary liquid 

waste annually. The hazardous waste, consisting of cleaning rags, personal protective equipment, spill 

response materials, and mercury vapor filters, would be shipped for offsite treatment and/or disposal in a 

licensed facility. Since the mercury storage facility(ies) would not involve any treatment or processing of 

mercury, the rate of hazardous waste generation would remain very low. Existing sanitary systems at all 

of the alternative sites can meet the projected sanitary liquid waste volume. 

Therefore, waste management impacts of new construction, modification of existing buildings, and 

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

2.7.1.9 Occupational and Public Health and Safety 

This section provides a summary of human health consequences and associated risks to workers and 

members of the public. The analysis considers various scenarios. Scenarios were developed for the 

following activities: (1) normal operations, (2) facility accidents, (3) transportation, and (4) intentional 

destructive acts (IDAs). The respective sections of Chapter 4 discuss human health consequences and 

associated risk analysis in detail under each alternative, and Appendix D discusses the development of 

specific scenarios considered in this EIS. This summary presents the most conservative (i.e., maximum) 

consequence, and thus risk, to a human receptor that could be expected to occur under certain scenarios. 

Consequences are presented in terms of severity levels (SLs), with SL-I representing negligible-to-verylow consequences and SL-IV representing the most severe consequences. SLs are defined for various 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–46

receptor scenarios in Appendix D, Section D.1.1.2. Overall risk is a function of the frequency at which an 

event might occur and the probable severity of the event. 

Normal Operations 

Normal operations for the long-term storage of mercury would not involve any processing or treatment of 

mercury. Normal operations would involve the receipt and storage of mercury for extended periods of 

time. Exposures could arise during normal operating conditions from small amounts of mercury vapor 

accumulating in the Storage Areas. This scenario can best be described as a chronic, slow release of 

mercury vapor within the storage building resulting from an undetected leaking container or external 

contamination of a container. Under all alternatives, the consequences and associated risks to involved 

workers, noninvolved workers, or members of the public are predicted to be negligible (e.g., SL-I). 

Facility Accidents 

Facility accidents are exposure scenarios initiated by failure of engineered systems or caused by human 

error. Accidents could include mercury spills inside or outside of the storage building. Of the various 

scenarios considered, those with the highest probability of occurring would likely be (1) a container or 

pallet drop during transfer from the transport vehicle to permanent storage (e.g., by forklift), (2) a collapse 

of storage racks, (3) an earthquake event, or (4) a flood event. The consequences of the flood event are 

bounded by the earthquake analysis. 

The consequences and associated risks to human health receptors would be identical under all action 

alternatives evaluated and are summarized in Table 2–7. 

Table 2–7. Summary of Consequences and Risks 

from All Onsite Mercury Spill Scenarios 

Scenario 

Consequence 

(Risk) 

Spills Inside Building 

Involved worker SL-I to -II 

(Negligible to low) 

Noninvolved workera SL-I 

(Negligible) 

Member of the public SL-I 

(Negligible) 

Spills Outside Building 

Involved worker SL-I to -II 

(Negligible to low) 

Noninvolved workera SL-I to -II 

(Negligible to low) 

Member of the public SL-I 

(Negligible) a A noninvolved worker is nearby (outside the building) but still on site. 

Key: SL=severity level. 

Transportation 

Transportation consequences under all alternatives are a function of the methods of transportation 

(i.e., truck or rail), the number of miles traveled, and the nature of the accident. Table 2–8 presents the 

number of kilometers that would be traveled under each alternative and the annual frequency of fatal 

accidents that are projected to occur. The greatest transportation impact under either Truck Scenario 1 

or 2 is presented in the following two tables. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–47

Table 2–8. Transportation Kilometers and Frequency Analysis for Transport Accidents 

Alternative 

Truck 

Kilometersa

(miles) 

Annual Frequency 

of Fatal Truck 

Accidentsb

Rail 

Kilometers 

(miles) 

Annual Frequency 

of Fatal Rail 

Accidentsb

Grand Junction Disposal Sitec 2,509,474 

(1,559,387) 8.7×10-4 510,579 

(317,274) 1.3×10-4

Hanford Site 200-West Area 3,399,774 

(2,112,620) 1.2×10-3 729,541 

(453,337) 1.9×10-4

Hawthorne Army Depot 3,127,892 

(1,943,672) 1.1×10-3 635,564 

(394,939) 1.6×10-4

Idaho National Laboratory, 

Idaho Nuclear Technology and 

Engineering Center 

2,662,210 

(1,654,297) 9.2×10-4 600,133 

(372,923) 1.5×10-4

Idaho National Laboratory, 

Radioactive Waste Management 

Complex 

2,662,210 

(1,654,297) 9.2×10-4 600,133 

(372,923) 1.5×10-4

Kansas City Plant 2,230,117 

(1,385,795) 7.8×10-4 403,890 

(250,977) 1.0×10-4

Savannah River Site, E Area 2,707,719 

(1,682,577) 9.4×10-4 489,769 

(304,342) 1.2×10-4

Waste Control Specialists, LLC 2,907,276 

(1,806,381) 1.0×10-3 634,260 

(394,129) 1.6×10-4

a The greatest transportation impact under either Truck Scenario 1 or 2 is presented in this table.

b Fatality caused by mechanical impact, not exposure to mercury. 

c The Grand Junction Disposal Site does not have direct rail access. Potential transportation impacts by rail to Grand Junction 

Disposal Site would involve intermodal transportation: rail transport to Grand Junction, transfer from rail to truck, and truck

transport to Grand Junction Disposal Site. 

In addition to fatal accidents due to mechanical impact, exposure to mercury from spills that could result 

from transportation accidents could impact human health. Table 2–9 summarizes the consequences and 

associated risk to human health receptors under certain scenarios evaluated for all action alternatives. 

Table 2–9. Summary of Transportation Consequences 

and Risks to Human Receptors 

Trucka Railcar 

Scenario 

Consequence 

(Risk) 

Spill onto ground SL-I/-III 

(Negligible) or 

SL-II 

(Low) 

SL-I to -III 

(Negligible) 

Spill into waterb SL-I to -II 

(Negligible to low) 

SL-I to -II 

(Negligible to low) 

Spill with fire – inhalation SL-I/-III 

(Negligible) or 

SL-II 

(Low) 

SL-I/-III 

(Negligible) or 

SL-II 

(Low) 

Spill with fire – dry deposition SL-I 

(Negligible) 

SL-I 

(Negligible) 

Spill with fire – wet deposition SL-I 

 (Negligible) 

SL-I 

 (Negligible) a The greatest transportation impact under either Truck Scenario 1 or 2 is presented in this table. 

b Due to a large range of uncertainty, estimating the consequences of this scenario is difficult. 

Key: SL=severity level. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–48

Intentional Destructive Acts 

The most plausible scenario for an IDA in the context of mercury would be the deliberate crash of a 

gasoline tanker into a truck or railcar carrying mercury with a subsequent fire. Other scenarios involving 

an attack on a storage facility other than during unloading of a truck or railcar are judged to be less likely 

because of the distribution of mercury within the facility, security measures, and facility design features 

that would mitigate the impacts of mercury releases into the environment. Therefore, the IDA analysis 

summarized below applies to all the action alternatives similarly. 

Human exposure pathways from an IDA include atmospheric inhalation and dry or wet deposition. The 

most severe case for atmospheric exposure pathways would be those concentrations of mercury between 

Acute Exposure Guideline Levels 2 and 3 (AEGL)-2 and AEGL-3 that could occur between 

approximately 100 meters (330 feet) and 5.6 kilometers (3.5 miles) downwind of the release point. 

However, the deposition benchmark of 180 milligrams per kilogram would not be exceeded anywhere. 

2.7.1.10 Ecological Impacts 

Consequences and, hence, risks to ecological receptors would be negligible except if there is a fire. The 

frequency of onsite fires sufficient to cause a release of mercury at any of the storage sites is predicted to 

be negligible; consequently, the ecological risk would also be negligible. Ecological risk would be 

evident only in the event of a transportation accident with fire; thus, the ecological risk would be similar 

under all action alternatives. Table 2–10 presents the ecological risk to various sensitive receptors. 

Table 2–10. Summary of Consequences and Risk to Ecological Receptors – 

Transportation Accident with Pallet Fire 

Trucka Railcar 

Deposition Pathway

Dry Wet Dry Wet 

Receptor 

Consequence 

(Risk) 

Sediment-dwelling biota SL-IV 

(High) 

SL-IV 

(Moderate) 

SL-IV 

(Moderate) 

b 

(Negligible) 

Soil invertebrates SL-IV 

(High) 

SL-IV 

(Moderate) 

SL-IV 

(Moderate) 

b 

(Negligible) 

Plants SL-II 

 (Low) 

SL-IV 

(Moderate) 

SL-II 

 (Low) 

b 

(Negligible) 

American robin SL-II 

 (Low) 

SL-IV 

(Moderate) 

SL-II 

 (Low) 

b 

(Negligible) 

River otter SL-II 

 (Low) 

SL-II 

 (Low) 

SL-II 

 (Low) 

b 

(Negligible) 

Aquatic biota SL-I 

(Negligible) 

SL-II 

 (Low) 

SL-II 

 (Low) 

b 

(Negligible) 

Short-tailed shrew SL-I 

(Negligible) 

SL-II 

 (Low) 

SL-I 

(Negligible) 

b 

(Negligible) 

Great blue heron SL-I 

(Negligible) 

SL-II 

 (Low) 

SL-I 

(Negligible) 

b 

(Negligible) 

Red-tailed hawk SL-I 

(Negligible) 

SL-I 

(Negligible) 

SL-I 

(Negligible) 

b 

(Negligible) 

a The greatest transportation impact under either Truck Scenario 1 or 2 is presented in this table. 

b The predicted frequency of railcar crashes with pallet fires in the presence of rain is negligible; therefore, the 

associated risks would be negligible and consequences are not presented in the table. 

Key: SL=severity level. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–49

2.7.1.11 Socioeconomics 

Action alternatives involving construction of a new facility are projected to require the employment of 

approximately 18 people for approximately 6 months. Action alternatives involving the use of existing 

buildings would require fewer employees than that to complete modifications or upgrades that might be 

needed. Operation of the mercury storage facility(ies) is estimated to require approximately 8 individuals 

for routine maintenance and support activities during the first 7 years, when higher volumes of shipments 

are expected, and then approximately 5 individuals for the remainder of the analysis period. The 

projected employment for construction and operations and associated indirect employment would have a 

negligible impact on socioeconomic conditions (i.e., overall employment, population trends, and traffic) 

under all alternatives. 

During construction of a new storage facility, it is estimated that construction-related transportation would 

average 45 vehicle trips per day. During operations of a mercury storage facility(ies), the greatest impacts 

would occur in the first 2 years. During this time, it is estimated that approximately 12 vehicle trips per 

day would occur, including trips associated with facility employment and mercury delivery. The minimal 

increase in the number of vehicle trips projected during construction or operations of a mercury 

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

2.7.1.12 Environmental Justice 

Analysis of census population block groups within a region of influence (ROI), defined as a 16-kilometer 

(10-mile) radius surrounding a site, identified minority and low-income communities at the KCP, SRS, 

and WCS candidate sites. None of the other candidate sites were determined to have minority or 

low-income communities within their respective ROIs. Under all alternatives, no disproportionately high 

and adverse effects are expected for either minority or low-income populations. 

Of the 671 census blocks located within 16 kilometers (10 miles) of KCP, 172 have a disproportionately 

high minority population only, 2 have a disproportionately high low-income population only, and 74 have 

a disproportionately high minority and low-income population. Within a smaller 3.2-kilometer (2-mile) 

radius, there are 41 census blocks, 16 of which contain a disproportionately high minority population 

and 1 contains a disproportionately high minority and low-income population. Impacts on these 

communities are not expected to result from construction or operations of a mercury storage facility; 

however, it is reasonable to conclude that a transportation accident at or near the facility could impact 

minority and low-income individuals disproportionately. 

Of the 14 census blocks located within 16 kilometers (10 miles) of SRS, 4 have a disproportionately high 

minority population and none have a disproportionately high low-income population. Within a smaller 

3.2-kilometer (2-mile) radius, there are no census blocks; however, 3 of the 4 minority blocks identified 

within the larger ROI are adjacent to South Carolina Highway 19 and adjoining U.S. Route 278. Impacts 

on these communities are not expected to result from construction or operations of a mercury storage 

facility; however, it is reasonable to conclude that a transportation accident at or near the facility entrance 

at South Carolina Highway 19 could impact minority individuals disproportionately. 

Of the eight census blocks located within 16 kilometers (10 miles) of WCS, one has a disproportionately 

high minority population and none have a disproportionately high low-income population. Within a 

smaller 3.2-kilometer (2-mile) radius, there are two census blocks, neither of which contains a 

disproportionately high minority or low-income population. Impacts are not expected to result from 

construction or operations of a mercury storage facility. A transportation accident at or near the facility 

entrance would not disproportionately impact minority or low-income populations. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–50

2.7.2 Summary of Cumulative Impacts 

The Council on Environmental Quality regulations implementing the National Environmental Policy Act 

define cumulative effects as “impacts on the environment which result from the action when added to 

other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or 

non-Federal) or person undertakes such other actions” (40 CFR 1508.7). Actions that may contribute to 

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

individuals that are within the ROIs of the actions considered in this Mercury Storage EIS. The ROIs 

used in the cumulative impacts analysis were generally assumed to be within a 16-kilometer (10-mile) 

radius of each facility location. 

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 impacts on the resources within the ROI. 

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 GJDS, Hanford, INL, SRS, and WCS; visual resources 

for GJDS and WCS; infrastructure for GJDS; and ecological resources for WCS. It was determined that 

the potential contribution to cumulative impacts on those resource areas evaluated would be negligible. 

Table 2–11 summarizes the potential contributions to cumulative impacts for these resource areas. 

Chapter 4, Section 4.11, provides a detailed discussion of the cumulative impacts assessment and 

potential contributing actions that were considered, including a discussion of global commons cumulative 

impacts. 

Table 2–11. Summary of Cumulative Impacts Assessment 

Alternative Resource Area Cumulative Impacts 

Contribution of 

Proposed Action to 

Cumulative Impacts 

Land use Negligible 

Visual resources

Rural area; limited development 

expected within the 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 

Air quality No exceedance of air quality standards. Negligible 

Grand Junction Disposal 

Site 

Infrastructure No substantial cumulative impacts on 

regional power consumption. Negligible 

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 

Hanford Site, 200-West Area 

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 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–51

Table 2–11. Summary of Cumulative Impacts Assessment (continued) 

Alternative 

Resource 

Area Cumulative Impacts 

Contribution of 

Proposed Action to 

Cumulative Impacts 

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 Idaho National Laboratory, 

Idaho Nuclear Technology 

and Engineering Center 

Air quality No exceedance of air quality standards. Negligible 

Idaho National Laboratory, 

Radioactive Waste 

Management Complex 

Air quality 

No exceedance of air quality standards. 

Negligible 

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

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 

Savannah River Site, E Area 

Air quality 

No exceedance of air quality standards, 

although the existing SRS contribution 

to 24-hour particulate matter 

concentrations approach the standard. 

Negligible 

Land use Negligible 

Visual resources

Rural area; numerous projects within 

ROI along the Highway 176 corridor. 

Substantial recent local changes to land 

use and visual resources. 

Negligible 

Air quality No exceedance of air quality standards. Negligible Waste Control Specialists, 

LLC 

Ecological 

resources 

Numerous projects within ROI along 

the Highway 176 corridor. Substantial 

recent local loss of low desert grassland 

and rangeland habitat. 

Negligible 

Key: Hanford=Hanford Site; INL=Idaho National Laboratory; ROI=region of influence; SRS=Savannah River Site.

2.8 REFERENCES 

Belencan, H., 2009, “SRS Recovery Act Footprint Reduction Project,” Presentation to Governor’s 

Nuclear Advisory Council, Savannah River Operations Office, Savannah River, South Carolina, June 11. 

Chlorine Institute, 2008, Eleventh Annual Report to EPA, Arlington, Virginia, September. 

Clinkenbeard, J., 2009, California Department of Conservation, California Geological Survey, personal 

communication to K. Prindiville, Science Applications International Corporation, Richland, Washington, 

“California Gold Mining,” November 18. 

DLA (Defense Logistics Agency), 2004, Final Mercury Management Environmental Impact Statement, 

Defense National Stockpile Center, Fort Belvoir, Virginia, March. 

DOE (U.S. Department of Energy), 2002, Final Environmental Impact Statement for the Proposed 

Relocation of Technical Area 18 Capabilities and Materials at the Los Alamos National Laboratory, 

DOE/EIS-0319, National Nuclear Security Administration, Washington, D.C., August. 
Draft Long-Term Management and Storage of Elemental Mercury Environmental Impact Statement 

2–52

DOE (U.S. Department of Energy), 2005, Savannah River Site End State Vision, Office of Environmental 

Management, Aiken, South Carolina, July 26. 

DOE (U.S. Department of Energy), 2009, U.S. Department of Energy Interim Guidance on Packaging, 

Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, November 13. 

DOE and Mesa County (U.S. Department of Energy and Mesa County Board of Commissioners), 1996, 

Memorandum of Understanding Between the United States Department of Energy and the Mesa County 

Board of Commissioners Regarding Utilization of the Cheney Repository, April 24. 

Duncan, J.P., ed., 2007, Hanford Site National Environmental Policy Act (NEPA) Characterization, 

PNNL-6415, Rev. 18, Pacific Northwest National Laboratory, Richland, Washington, September. 

EPA (U.S. Environmental Protection Agency), 2005, Global Mercury Commodity Market Study, 

Washington, D.C., May. 

EPA (U.S. Environmental Protection Agency), 2007, Mercury Storage Cost Estimates, Office of 

Pollution Prevention and Toxics and Office of Solid Waste and Emergency Response, Washington, D.C., 

November. 

GSA and NNSA (U.S. General Services Administration and National Nuclear Security Administration), 

2008, Environmental Assessment for the Modernization of Facilities and Infrastructure for the 

Non-nuclear Production Activities Conducted at the Kansas City Plant, DOE/EA-1592, Kansas City, 

Missouri, April 21. 

Holecek, M., 2009, Identifying a Storage Facility for Elemental Mercury, Response to Request for 

Expressions of Interest, U.S. Department of Energy, National Nuclear Security Administration, Kansas 

City Site Office, Kansas City, Missouri, April 24. 

INL (Idaho National Laboratory), 2008, Idaho National Laboratory Site Environmental Report Calendar 

Year 2007, DOE/ID-12082(07), Idaho Operations Office, Idaho Falls, Idaho, September. 

IPCC (Intergovernmental Panel on Climate Change), 2007, A Report of Working Group I of the 

Intergovernmental Panel on Climate Change, Summary for Policymakers, Cambridge, United Kingdom, 

and New York, New York. 

Krahulec, K., 2009, Utah Geologic Survey, Energy and Minerals Group, personal communication to K. 

Prindiville, Science Applications International Corporation, Richland, Washington, “Utah Gold Mining,” 

November 16. 

Mannon, J., 2009, Cripple Creek and Victor Gold Mining Company, Victor, Colorado, personal 

communication to K. Prindiville, Science Applications International Corporation, Richland, Washington, 

“Byproduct Mercury from Cresson Gold Mine,” November 17. 

Miller, G., and G. Jones, 2005, Mercury and Modern Gold Mining in Nevada, Final Report to 

U.S. Environmental Protection Agency Region IX, University of Nevada, Reno, Nevada, October 25. 

NMA (National Mining Association), 2009, Gold Production By State, accessed through 

http://www.nma.org/pdf/g_production.pdf, August 11. 

Szumigala, D., 2009, Alaska Division of Geological and Geophysical Surveys, personal communication 

to K. Prindiville, Science Applications International Corporation, Richland, Washington, “Alaska Gold 

Mining,” September 4. 
Facility Description, Alternatives, and Comparison of Environmental Consequences 

2–53

Townsend, B., 2009, South Dakota Department of Environment and Natural Resources, Minerals and 

Mining Program, personal communication to K. Prindiville, Science Applications International 

Corporation, Richland, Washington, “South Dakota Gold Mining,” November 13. 

USGS (U.S. Geological Survey), 2009, Mineral Commodities Summary, accessed through 

http://minerals.usgs.gov/minerals/pubs/commodity/mercury/mcs-2009-mercu.pdf, August 15. 

Code of Federal Regulations

40 CFR 1502.14(a), Council on Environmental Quality, “Environmental Impact Statement: Alternatives 

Including the Proposed Action.” 

40 CFR 1508.7, Council on Environmental Quality, “Cumulative Impact.” 

40 CFR 268, U.S. Environmental Protection Agency, “Land Disposal Restrictions.” 

49 CFR 172.101, Pipeline and Hazardous Materials Safety Administration, U.S. Department of 

Transportation, “Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, 

Emergency Response Information, Training Requirements, and Security Plans: Purpose and Use of 

Hazardous Materials Table.” 

Federal Register

64 FR 28949, U.S. Environmental Protection Agency, 1999, “Potential Revisions to the Land Disposal 

Restrictions Mercury Treatment Standards,” May 28. 

68 FR 4481, U.S. Environmental Protection Agency, 2003, “Land Disposal Restrictions: Treatment 

Standards for Mercury-Bearing Hazardous Waste; Notice of Data Availability,” January 29. 

69 FR 23733, Defense Logistics Agency, Defense National Stockpile Center, 2004, “Record of Decision 

for the Final Mercury Management Environmental Impact Statement,” April 30. 

74 FR 31723, U.S. Department of Energy, 2009, “Notice of Intent to Prepare an Environmental Impact 

Statement for the Long-Term Management and Storage of Elemental Mercury,” July 2. 

United States Code

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

U.S. Public Laws

P.L. 110-414, Mercury Export Ban Act of 2008. 

P.L. 111-5, American Recovery and Reinvestment Act of 2009.